Public Hearing on Ellwood Mesa Monarch Butterfly Habitat Management Plan Development Plan In-Concept Coastal Development Permit - Part 2 (LARGER SIZED FILE) — Goleta City Council, October 17, 2023 (part 3 of 4)

263 2/25/19 Letter Ana Citrin, Law
Offices of Marc
Chytilo, APC, for
Friends of the
Ellwood
Monarchs
The commenter recommends that the MBHMP be revised to
specifically state that removed eucalyptus trees will be replaced in kind and identify blue gum and other eucalyptus species in the identified plant list.

This comment is noted. The MBHMP calls
for maintaining a “living forest within the
outline of pre-drought forest extent,” and
contains a number of policies and actions
supporting eucalyptus growth within the
boundaries of the existing eucalyptus
groves. Such actions include Action 12-1.11,
which calls for a pilot planting for any
eucalyptus species considered for tree
restoration that is not present in the
MBHMP area as of 2018, and Action 12-2.
5, which calls for protecting blue gum
saplings as necessary to encourage natural
recruitment of trees in the eucalyptus
forest. Finally, the 2018 Implementation
Plan calls for planting of 63 eucalyptus trees
within the existing grove boundaries as
mitigation for the 27 trees removed and 2
trees trimmed in 2017. The 2018
Implementation Plan is currently under
review by the CCC.

Restoration
City of Goleta
Ellwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan B-44
No. Date Source Name Comment Staff Response Subject/Topic 264 2/25/19 Letter Ana Citrin, Law
Offices of Marc
Chytilo, APC, for
Friends of the
Ellwood
Monarchs
The commenter recommends changes to Policy 12-1 of the
MBHMP to state that eucalyptus trees in the groves hall be managed to ensure tree health and longevity throughout
the Coverage Area, rather than just in groves containing aggregation sites.

The commenter’s proposed changes to
Policy 12-1 of the MBHMP have been
accepted. Policy 12-1 of the MBHMP has
been revised, as follows:
“Policy 12-1. Eucalyptus trees in the groves
containing monarch butterfly aggregation
sites within the MBHMP coverage area shall
be managed, as feasible, to ensure tree
health and longevity.”
Restoration
265 2/25/19 Letter Ana Citrin, Law
Offices of Marc
Chytilo, APC, for
Friends of the
Ellwood
Monarchs
The commenter recommends a change to Action 12-1.2 of
the MBHMP. Specifically, the commenter suggests that
Table 2 of the MBHMP be revised to include “Planting
eucalyptus trees or planting native trees” as a Potential Action/Tool for Management to correct habitat deficiencies.

This comment is noted. As currently
written, Table 2 allows for planting of trees
to correct habitat deficiencies, such as
sparse overstory, strong winds in the
groves, or tree death, toppling, or removal.

Such trees may be eucalyptus or native,
depending on the location within the
Coverage Area, the conditions at this
location, and the habitat deficiency to be
corrected.

Restoration
266 2/25/19 Letter Ana Citrin, Law
Offices of Marc
Chytilo, APC, for
Friends of the
Ellwood
Monarchs
The commenter recommends changes to Actions 12-1.6 and
12-1.10 of the MBHMP specifying maintenance of a living eucalyptus forest and replanting eucalyptus trees.

Restoration
Final Initial Study – Mitigated Negative Declaration
Public Comments and City of Goleta Responses on the
Draft Ellwood Mesa/Sperling Preserve Open Space Monarch Butterfly Habitat Management Plan Final Initial Study – Mitigated Negative Declaration B-45 No. Date Source Name Comment Staff Response Subject/Topic 267 2/25/19 Letter Ana Citrin, Law
Offices of Marc
Chytilo, APC, for
Friends of the
Ellwood
Monarchs
The commenter recommends changes to Action 10-1.1,
Policy 10-2, Action 10-2.1, and Policy 10-4 expanding the application of these actions and policies to eucalyptus groves and windrows in the Coverage Area, as opposed to monarch butterfly aggregation sites.

This comment is noted. The MBHMP
includes a number of policies and actions
supporting eucalyptus growth within the
existing grove boundaries. Additional
protections included in the MBHMP are
intended to provide an added layer of
management directive to protect known
aggregation sites in the Coverage Area.

They do not preclude larger habitat
restoration efforts from occurring
throughout the Coverage Area, such as
removal of dead trees and debris, planting
trees as needed to maintain grove density
and improve monarch habitat (Action 12-

1.10), or monarch butterfly patrolling
habitat enhancement efforts (Action 12-

2.2).

Restoration
268 2/25/19 Letter Ana Citrin, Law
Offices of Marc
Chytilo, APC, for
Friends of the
Ellwood
Monarchs
The commenter states that Action 2-2.2 allows for payments of compensatory mitigation fees to the Butterfly Fund for projects with limited impacts on monarch butterfly habitat.

The commenter adds that the City should not allow projects that impact monarch butterfly habitat, and Action 2-2.2 should be revised to allow payment of compensatory
mitigation fees only where projects have implemented all available measures to avoid impacts to monarch butterfly habitat, or to directly mitigate impacts on-site where
appropriate.

This comment is noted. Action 2-2.2 allows
for payments of compensatory mitigation
fees into the Butterfly Fund, as deemed
appropriate during project-specific CEQA
analysis for projects with limited impacts on
monarch butterfly habitat. Such projects
would still be required to undergo the
appropriate level of project-specific
environmental review evaluating and
mitigating impacts to monarch butterflies,
as necessary.

Environmental
Impacts and
Mitigation
269 2/25/19 Letter Ana Citrin, Law
Offices of Marc
Chytilo, APC, for
Friends of the
Ellwood
Monarchs
The commenter states that language in the Habitat
Enhancement and Restoration Program is insufficiently clear and requires revision to ensure that restoration activities do not result in the destruction of eucalyptus and monarch habitat and associated potentially significant impacts.

Specifically, the commenter suggests changes to the
Overview language in the MBHMP clarifying that
enhancement or restoration of the Devereux Creek corridor would occur in existing native riparian areas. The
commenter adds that this language is consistent with the language in supporting Policy 14.3, which limits restoration actions to existing native riparian areas, and Policy 14-2, which states that, “areas between eucalyptus groves shall be considered for habitat enhancement and restoration
This comment is noted. The MBHMP is a
long-term management plan intended to
guide habitat restoration and enhancement
efforts through management goals,
policies, and supporting actions. Specific
management activities, including the
location and nature of riparian restorations,
would be identified in annual
Implementation Plans. Pursuant to Action
1-4.2, City staff shall present each annual
Implementation Plan at a public hearing for
stakeholder input and City Council
approval.

Restoration
City of Goleta
Ellwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan B-46
No. Date Source Name Comment Staff Response Subject/Topic alternatives.”
270 2/25/19 Letter Ana Citrin, Law
Offices of Marc
Chytilo, APC, for
Friends of the
Ellwood
Monarchs
The commenter requests a map in the MBHMP showing the
location of existing native riparian areas. Specifically, the commenter requests that the MBHMPM include Figure 2
from the Draft IS-MND showing drainages and vegetation
communities in the Coverage Area. Additionally, the
commenter recommends changes to Action 11-2.4 of the
MBHMP to specify that restoration in the Devereux Creek riparian corridor would be for “existing native riparian areas.”
This comment is noted. The commenter
appears to be referring to Figure 7 of the
Draft IS-MND, which is included in Section
4, Biological Resources, of the document.

As described in the staff response to
Comment 269, above, specific management
activities, including the location and nature
of riparian restorations, would be identified
in annual Implementation Plans. Pursuant
to Action 1-4.2, City staff shall present each
annual Implementation Plan at a public
hearing for stakeholder input and City
Council approval.

Restoration
271 2/25/19 Letter Ana Citrin, Law
Offices of Marc
Chytilo, APC, for
Friends of the
Ellwood
Monarchs
The commenter notes the importance of monitoring and
reporting as key tools necessary to ensure that the MBHMP functions as intended and that provisions of the MBHMP
relied on to self-mitigate impacts to monarch butterflies and their habitat are actually effective at reducing impacts to less than significant levels. The commenter recommends
changes to Policy 20-3 and Action 20-3.1 to firmly require annual Monitoring Reports and present such reports at
public workshops.

The commenter’s proposed changes are
noted. In addition to monitoring actions
proposed in the MBHMP, the MBHMP IS-
MND contains 15 mitigation measures
incorporated to reduce potential impacts to
the environment to a less than significant
level. A Mitigation Monitoring and
Reporting Program (MMRP), included as
Appendix D of the Final IS-MND, requires
the City to monitor the effectiveness of
these mitigation measures and includes
required actions, monitoring timing,
frequency, responsible parties, and
compliance verification steps.

Monitoring
272 2/25/19 Letter Ana Citrin, Law
Offices of Marc
Chytilo, APC, for
Friends of the
Ellwood
Monarchs
The commenter requests changes to Action 1-2.1 of the
MBHMP. Specifically, the commenter request that the
action firmly require pre-activity surveys for nesting birds, monarch butterfly aggregations, and other wildlife, the presence of an environmental monitor during construction, and other protections, as deemed appropriate whenever
vegetation removal, ground disturbance, construction, or other activities are proposed within the Coverage Area by the City or any other entity. Additionally, the commenter requests that the measure be revised to require the City to monitor such activities to ensure environmental protection measures are used and that activities are limited to those permitted.

The commenter’s proposed changes to
Action 1-2.1 of the MBHMP have been
accepted. Action 1-2.1 now reads as
follows:
“Action 1-2.1. Whenever vegetation
removal, ground disturbance, construction,
or other activities with the potential to
significantly disrupt habitat values are
proposed within the MBHMP coverage area
by the City or any other agency or utility,
environmental protection measures shall
be implemented. These measures shall be
determined in coordination with a qualified
Monitoring
Final Initial Study – Mitigated Negative Declaration
Public Comments and City of Goleta Responses on the
Draft Ellwood Mesa/Sperling Preserve Open Space Monarch Butterfly Habitat Management Plan Final Initial Study – Mitigated Negative Declaration B-47 No. Date Source Name Comment Staff Response Subject/Topic biologist, and should normally shall include
at a minimum pre-activity surveys for
nesting birds or other wildlife, pre-activity
surveys for monarch butterfly aggregations,
presence of an environmental monitor
during construction, and other protections,
as deemed appropriate. The City will
monitor these activities to ensure that
environmental protection measures are
used and that activities are limited to those
permitted.”
273 2/22/19 Letter Maeton Freel,
Resident
The commenter states that the MBHMP provides a generic
approach to managing the Coverage Area primarily for
eucalyptus trees, while mentioning other existing wildlife resources and native riparian and upland habitats in and adjacent to the Coverage Area. The commenter
recommends a more balanced approach to better support
both butterflies and other native species. The commenter further recommends use of The Xerces Society’s 2017
publication Protecting California’s Butterfly Groves:

Management Guidelines for Monarch Butterfly
Overwintering Habitat and working with the United States Fish and Wildlife Service (USFWS) in their review of
proposals to have the monarch butterfly listed as
threatened or endangered.

The purpose of the MBHMP is to provide a
programmatic approach to management of
the habitats that support the monarch
butterfly seasonal aggregation areas at the
Ellwood Mesa Open Space, as well as a
variety of other plant and animal species
and coastal access and recreation. The
publication recommended by the
commenter was consulted and is included
as a reference in the MBHMP. Additionally,
the MBHMP notes the ongoing effort by
the USFWS review the monarch butterflies
candidacy for listing as threatened or
endangered under the Federal Endangered
Species Act. Policy 3-1 of the MBHMP
states that the City shall pursue cooperative
relationships with other agencies regarding
regulatory goals and policies that the
partners have in common concerning the
Ellwood Mesa Open Space, in particular,
goals and policies that have an impact on
the management of the monarch butterfly
aggregation sites. Supporting Action 3-1.1
specifically encourages such relationships
with federal agencies such as the USFWS.

MBHMP
Scope/Detail
City of Goleta
Ellwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan B-48
No. Date Source Name Comment Staff Response Subject/Topic 274 2/22/19 Letter Maeton Freel,
Resident
The commenter states that the maps included in the
MBHMP are general and need to be at a scale which
provides for definition of tree densities, areas of dead and dying trees, and other factors critical to managing the habitat.

The MBHMP is a long-term planning
document for the Coverage Area.

Conditions such as tree density, areas of
dead or dying trees, and other factors
critical to managing the habitat, are subject
to changes over time as MBHMP activities
are implemented. Annual Implementation
Plans prepared for the Coverage Area may
contain more detailed maps or other
materials to inform specific management
actions.

MBHMP
Scope/Detail
275 2/22/19 Letter Maeton Freel,
Resident
The commenter states that comments provided by Lisa
Stratton, Director of Ecosystem Restoration at the University of California, Santa Barbara, provide additional factors which need to be included in a sound management plan in order to determine whether an area is actually meeting desired
habitat characteristics for monarch butterflies and other wildlife and plants occurring in the area.

Comments received on the MBHMP,
including those noted by the commenter,
are included in this comment matrix. Please
refer to the responses above.

Public Comments
276 2/24/19 Letter Michael Mills,
Resident
The commenter states that the MBHMP does not
adequately address the extreme risks to property and
human life that would occur due to a fire in the eucalyptus groves. The commenter notes that the plan was prepared by an environmental consulting firm with expertise in monarch butterfly habitat preservation, not fire risk assessment or the development of fire mitigation strategies. The
commenter states that neighborhoods adjacent to the
groves are at significant risk of fire, and concludes that the MBHMP should provide fire risk reduction strategies. Finally, the commenter states that such strategies should be made in consultation with fire risk experts, especially those with expertise in the specific risks posed by fires in eucalyptus groves.

Wildfire
Final Initial Study – Mitigated Negative Declaration
Public Comments and City of Goleta Responses on the
Draft Ellwood Mesa/Sperling Preserve Open Space Monarch Butterfly Habitat Management Plan Final Initial Study – Mitigated Negative Declaration B-49 No. Date Source Name Comment Staff Response Subject/Topic 277 2/25/19 E-mail Laura Maskrey,
Resident
The commenter notes that the MBHMP is not an emergency
response plan, but that there exists a possibility that monarch butterflies may not return to the Coverage Area next year. The commenter recommends that there should
be some urgent discussions about what should be done
before the next year, since this plan may not take effect before then.

The commenter is correct that the MBHMP
is not an emergency response plan.

However, the City published the 2018
Implementation Plan in July 2018, which
calls for conducting nesting bird and
monarch butterfly surveys, installation of
enhancement plantings and signage,
removal of existing closure signs, and long-
term replacement tree monitoring. The
schedule in the 2018 Implementation Plan
calls for installation of enhancement
plantings, signage, and removal of trail
closure signage as early as March 2019.

However, the 2018 Implementation Plan is
currently being reviewed by the CCC, and
requires CCC approval prior to
implementation.

MBHMP
Scope/Detail
City of Goleta
Ellwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan B-50
T
his page intentionally left blank.

Final Initial Study – Mitigated Negative Declaration
City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments Final Initial Study – Mitigated Negative Declaration
Response to Comments
This section includes comments received during the circulation of the Draft Initial Study and Mitigated Negative Declaration (IS-MND) prepared for the Monarch Butterfly Habitat Management Plan (MBHMP).

The Draft IS-MND was circulated for a 30-day public review period that began on January 25, 2019 and concluded on February 24, 2019. The City received nine (9) comment letters on the Draft IS- MND. The commenter and the page number on which each commenter’s letter appears are listed below.

Letter No. and Commenter Page No.
1 Jacqueline Phelps, District Supervisor, California Coastal Commission (CCC) C-2 2 Deborah L. Williams, Resident C-5
3 Ana Citrin, Law Offices of Marc Chytilo on behalf of Friends of the Ellwood Monarchs C-11 4 Maeton Freel, Resident C-27
5 Michael Mills, Resident C-36
6 Cherie Topper, Executive Director, Santa Barbara Audubon Society C-38 7 Christina Lange, Friends of the Ellwood Coast C-60
8 Chuck Davis, Len and Cathleen Grabowski, Matt Graham, and Carolyn Grenier, Residents C-62 9 Laura Maskrey, Resident C-75
The comment letters and responses follow. Each comment letter has been numbered sequentially and each separate issue raised by the commenter, if more than one, has been assigned a number.

The responses to each comment identify first the number of the comment letter, and then the number assigned to each issue (Response 1.1, for example, indicates that the response is for the first issue raised in comment Letter 1).

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Attachment 4 - Appendix C

STATE OF CALIFORNIA--- CALIFORNIA NATURAL RESOURCES AGENCY

CALIFORNIA COASTAL COMMISSION

SOUTH CENTRAL COAST DISTRICT OFFICE
89 SOUTH C ALIFORNJA STREET, SUITE 200
VENTURA, CA 91001-280 I
VOICE (805) 585-1800
FAX (805) 641-1712
WWW COASTAL CA GO\
February 25, 2019
Anne Wells
City of Goleta, Planning Division
130 Cremona Drive, Suite B
Goleta, CA 93117
GAVI!\ �E\\'SOM, ,;uuu,n1<
RE: Ellwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan Initial Study & Mitigated Negative Declaration
Dear Ms. Wells,
Commission staff has reviewed the Initial Study & Mitigated Negative Declaration (IS/MND) for the Ellwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan, and we appreciate the opportunity to provide comments for your consideration. The purpose of the subject IS/MND is to assess the Monarch Butterfly Habitat Management Plan (MBHMP), which has been created to provide an approach to management of monarch butterfly seasonal aggregation habitat, additional species habitats, and public access and recreation. Within the subject MBHMP, 22 programs are identified to guide the overall management approach, and within each program a goal and several policies and objectives for implementation are outlined.

As described within the IS/MND, the eucalyptus trees at Ellwood Mesa are currently threatened by drought and pest infestation. The health of the trees has been compromised, which has resulted in the death of numerous trees and the degradation of aggregation sites. In July 2017, over 1,200 eucalyptus trees were dead, and hundreds more were highly degraded and dying. The IS/MND also describes that the monarch butterfly population at Ellwood Mesa has been in decline for several years. In 2018, the population at Ellwood declined to 230 butterflies. which is approximately 0.5 percent of the 30-year population high (47,500 butterflies in 2011 ).

In September 2017, in order to address 29 trees that were dead and/or at high risk of failure and hazardous to public safety due to their proximity to public trails, the Commission issued Emergency Coastal Development Permit (CDP) Number G-4-17-0048 to allow for removal of the trees. In recognition of the need for a comprehensive approach to habitat and access management at Ellwood, Condition Four of this Emergency CDP requires that the City submit a complete regular CDP application for an Ellwood Mesa Habitat Management Plan to not only address mitigation for the 29 trees removed, but also restoration of the aggregation sites and a strategy for re-opening and maintaining future use of all public trail segments in coordination with habitat management strategies.

The subject MBHMP identifies several goals, policies, and objectives for the comprehensive management of Ellwood, including directives to restore aggregation sites, enhance biodiversity, and maintain public access. However, the MBHMP lacks specific project details and implementing actions. Conditions at Ellwood seem to warrant expedited action as the heath of Letter 1
C-2
the aggregation sites and monarch butterfly population appear to be degrading rapidly. As such, Commission staff recommends that the City incorporate detailed measures into the MBHMP to guide implementation of a comprehensive , ecosystem based approach for management of Ellwood, and that the plan be submitted to the Commission in the context of a CDP application to fulfill the requirements of Condition Four of Emergency CDP G-4-17-0048. The plan should include alternatives for replacing removed and trimmed eucalyptus trees with native tree species and replacing them with a mixture of native and non-native tree species as well as incorporating as many native nectar producing species in the planting palette as possible. A CDP for such a plan would provide the City with the ability to implement all project components expeditiously if necessary , or could be structured to allow for implementation on a programmatic or phased basis as funding sources become available.

Again, we appreciate the opportunity to provide comments for your consideration and we look forward to our continued coordination. If you have any questions regarding these comments, please contact me at 805-585-1800.
2 Sincerely ,
Jacqueline Phelps
District Supervisor
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City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments

Final Initial Study – Mitigated Negative Declaration
Letter 1
COMMENTER: Jacqueline Phelps, District Supervisor, California Coastal Commission DATE: February 25, 2019
Response 1.1
The commenter describes the background and context for the MBHMP, noting the health of eucalyptus groves at Ellwood Mesa has been compromised by drought and pest infestation. The commenter further notes the California Coastal Commission (CCC) issued an Emergency Coastal Development Permit (CDP) to the City in September 2017, authorizing removal of 29 dead or high- risk trees that posed a threat to public safety. As a condition of this Emergency CDP, the City is required to submit a complete CDP application addressing not only mitigation for the removed trees, but also aggregation site restoration, habitat management, and trail repair and maintenance strategies. The commenter states the opinion the MBHMP, as written, lacks specific project details and implementation actions and recommends inclusion of detailed measures into the MBHMP to guide implementation of a comprehensive, ecosystem-based approach for management of Ellwood Mesa to fulfill the requirements of the Emergency CDP. The commenter adds the plan should include alternatives for replacing removed and trimmed eucalyptus trees with native tree species and replacing them with a mixture of native and non-native tree species as well as incorporating as many native nectar producing species in the planting palette as possible.

This comment does not relate to the content or adequacy of the Draft IS-MND, but instead to the content and composition of the MBHMP. Therefore, this comment has been moved to the MBHMP Comment Matrix in Appendix B that was prepared to address comments related specifically to the MBHMP, and a response was provided in the matrix. The MBHMP Comment Matrix will be provided to City Council for its review prior to considering adoption of the MBHMP.

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1 Comments on the Draft Initial Study/Mitigated Negative Declaration (IS/MND) for the Ellwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan (MBHMP)
Submitted by Deborah L. Williams
February 19, 2019
At
tn: Anne Wells, Advance Planning Manager, City of Goleta As
a resident of Goleta, and as someone who both visits Ellwood Mesa/Sperling Preserve regularly and is deeply concerned about the future of monarch butterflies, I respectfully submit the following comments on the Draft Initial Study/Mitigated Negative Declaration (IS/MND) for the Ellwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan (MBHMP).

My comments focus on four areas: (1) the use of insecticides, herbicides, and other pesticides in the areas; (2) the related provisions regarding invasive species eradication; (3) the potential tagging of monarch butterflies; and (4) a correction.

1. The
Management Plan Should be Modified to Preclude the Use of Chemical Insecticides, Herbicides, and other Pesticides, Unless It Is Clearly and Unambiguously Documented that Such Use is Absolutely Necessary for Monarch Survival.

The Draft Initial Study correctly states that:

The long-term decline of the monarch population in California may be attributed to the loss of milkweed and nectar plants (caused by herbicides, drought, and removal), loss and degradation of overwintering groves (removal and aging) and other factors including use of insecticides, disease, and fluctuations in weather and temperatures associated with climate change (The Xerces Society 2017). (p. 65)
Scientists have known for a long time that insecticides, herbicides and other pesticides are harmful to monarch butterflies. As a result, Ellwood Mesa should be designated an herbicide and pesticide-free area, unless it is clearly and unambiguously documented that use of herbicides and pesticides are absolutely necessary for monarch survival.

As currently written, this needed rigorous standard and approach is not adopted. On page 14, the study simply states: “Apply herbicides as needed to control invasive, non-native plant species.” (p.14) The use Letter 2
C-5
2 of the phrase “as needed” is entirely too vague. It is very hard to imagine any circumstances that would require the use of herbicides. Fortunately, we live in a community where citizens enthusiastically volunteer for invasive species removal projects. This strategy should be implemented, where needed.

Alternatively, given the $3.9 million in funds from the State of California, money could be used to hire people for this work. Mechanical removal is a much safer and more appropriate strategy.

Similarly, on page 14, the Study states: “Apply insecticides, herbicides, and other pesticides, as necessary.” The phrase “as necessary” is not defined. While it can be argued that Ellwood Mesa should be an insecticide, pesticide, and herbicide-free zone under all circumstances, at the very least “as necessary” needs to be defined as “it is clearly and unambiguously documented that use of pesticides or herbicides is absolutely necessary for monarch survival.” On page 98 the Study states:

The MBHMP recommends the use of biological control methods such as birds, lady beetles, spiders, and other predators, as the use of chemical control such as pesticides and herbicides may be dangerous to butterflies. Nevertheless, application, handling, and transport of chemical pesticides, herbicides, and fertilizers may be necessary to ensure the long-term viability of new plantings or eradication of invasive species. Chemical applications have the potential to create the unintended release of a hazardous material. (EMPHASIS ADDED) (p. 98).

This statement seems to suggest that it is more important to ensure the long-term viability of new plantings or the eradication of invasive species than ensure the safety of the monarchs. The priority must be the health of the monarch population, and as such, herbicides, insecticides and other pesticides should not be used. There are safer alternatives.

2. The Goal of Eradicating Existing Stands of Invasive Species, Especially If It Requires the Use of Herbicides and is Harmful to Monarchs is Neither Desirable Nor Appropriate.

On page 25 of the Study, the following goal and strategy are described:

Goal: To eradicate existing stands of invasive non-native species and prevent or control new occurrence of invasive non-native plant species within the monarch butterfly habitat at Ellwood Mesa. 15-2: The City shall control all “High,” “Moderate,” and “Limited” priority invasive plant species within the monarch butterfly habitat, as except those species for which monarch butterflies are dependent, as feasible (p.25)
Notably, eucalyptus is a non-native species. During the California Gold Rush in the 1850s, eucalyptus trees were introduced to California by Australians. Just because a species is non-native, this certainly does not mean it is necessarily harmful to monarchs. While it is important to remove, by mechanical means, some unproductive non-native species in some areas to plant species that will help monarchs, it is an overreach, with negative consequences (such as the proposed application of herbicides) to seek to “eradicate existing stands of invasive non-native species.” This should be changed to be more realistic C-6
3 and beneficial. Monarchs first. Monarchs should not be exposed to herbicides to meet a hypothetical, overstated and non-essential goal.

3. Given the Extremely Small Size of the Current Monarch Population, It Is Likely Too Risky to Capture, Tag, and Release Monarch Butterflies for Tracking At This Time (p.15) As the Study notes: “recent data collected during the 2018 winter season showed an all-time low peak population of 230 monarch butterflies observed.” (p. 65). Given this very small population, it is likely too risky and dangerous to capture, tag and release monarch butterflies for tracking at this time. There needs to be a sufficient population of monarchs to do this, and 230 is does not appear to be sufficient.

There should be population parameters established before the goal, set out on page 15 of capturing, tagging and releasing monarch butterflies is allowed or implemented.

4. Errata: The Study states that “Goleta has six City parks and eight open spaces, totaling approximately 482 acres (City of Goleta 2018a).” Goleta has 16 parks.

Thank you for the opportunity to submit these comments.

Deborah Williams
Goleta Resident (451 Barling Terrace)
Lecturer UCSB
[email protected]
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City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments

Final Initial Study – Mitigated Negative Declaration
Letter 2
COMMENTER: Deborah L. Williams, Resident
DATE: February 19, 2019
Response 2.1
The commenter requests the MBHMP be modified to preclude the use of chemical insecticides, herbicides, and other pesticides, unless it is clearly and unambiguously documented that such use is absolutely necessary for monarch survival. The commenter states the opinion insecticides, herbicides, and other pesticides are harmful to monarch butterflies and requests Ellwood Mesa be designated an herbicide and pesticide-free area. The commenter further requests the Project Description in the Draft IS-MND be more specific when discussing the potential use of insecticides, herbicides, or other pesticides, rather than stating such chemicals would be applied “as needed” or “as necessary.” The commenter notes Page 98 of the Draft IS-MND states “application, handling, and transport of chemical pesticides, herbicides, and fertilizers may be necessary to ensure the long-term viability of new plantings or eradication of invasive species.” The commenter concludes this language improperly prioritizes the long-term viability of new plantings over the safety of monarchs.

The purpose of the MBHMP is to provide a programmatic approach to management of the habitats that support the monarch butterfly seasonal aggregation areas at the Ellwood Mesa Open Space, as well as a variety of other plant and animal species and coastal access and recreation. In support of this purpose, new plantings would occur in the Coverage Area, including native species and non- native species critical to monarch butterfly seasonal aggregation areas. Ensuring the long-term viability of these new plantings is essential to fulfill the overarching purpose of the MBHMP. The MBHMP emphasizes the use of a range of pest management strategies to control or eradicate, as feasible, plant, animal, fungal, and other pests that would result in impacts on monarch butterflies or degrade monarch butterfly habitat. In particular, the MBHMP’s Integrated Pest Management Program includes the use of biological control strategies, limiting stress-inducing activities to periods of reduced pest activity, and planting pest-resistant species. However, as noted by the commenter, the use of insecticides, herbicides, and other pesticides may be necessary to support new plantings and habitat restoration efforts. As such, insecticide, herbicide, and other pesticide application is included as a covered activity under the MBHMP, and is evaluated and addressed in the IS-MND.

Mitigation Measure HWQ-2 requires the preparation of a Chemical Application Control Plan prior to commencement of native planting, eucalyptus grove restoration, invasive species eradication, and pest control activities. As specified in the mitigation measure, the Chemical Application Control Plan would specify thresholds to determine when fertilizer, herbicide, or pesticide application would be necessary, as well as the potential chemicals to be used and the rate, timing, and placement of application. The measure further requires the use of chemical forms that are the least toxic to non- target organisms be employed in the event pesticides or herbicides are deemed necessary.

Additionally, as noted in Section 4 of the Draft IS-MND, Biological Resources, Action 10-4.1 of the MBHMP requires all potentially invasive activities to occur between April 1 and September 30 unless authorized by a qualified biologist, which would minimize potential direct impacts to monarch butterflies as the species would not likely be present during this time. Action 10-4.1 of the MBHMP specifically identifies invasive species eradication, which may include application of herbicides, as one such activity subject to this restriction. Section 4 of the Draft IS-MND, Biological Resources, C-8
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Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments

Final Initial Study – Mitigated Negative Declaration
concludes impacts to monarch butterflies would be less than significant with incorporation of Mitigation Measures HWQ-2, as well as BIO-1, BIO-2, and BIO-3, which require site housekeeping, biological monitoring during vegetation removal, and worker environmental awareness training.

Long-term impacts to monarch butterflies associated with implementation of the MBHMP would be beneficial.

Response 2.2
The commenter restates the Goals, Policies, and Actions of the MBHMP’s Invasive Plant Management Program. Specifically, the commenter states just because a species is non-native does not mean it is inherently harmful to monarch butterflies. The commenter opines eradicating existing stands of invasive non-native species is excessive and could result in negative consequences for monarch butterflies, particularly if doing so requires application of herbicides. The commenter further notes mechanical removal of non-native species should be used.

This comment is noted. Covered activities listed under the MBHMP’s Habitat Enhancement and Restoration Program and the Invasive Plant Management Program on Pages 13 and 14 of the Draft IS-MND include both hand removal of invasive non-native plant species and application of herbicides, as needed. Section 4, Biological Resources, on Page 71 of the Draft IS-MND acknowledges that short-term impacts to monarch butterflies could occur due to disturbance of suitable habitat through restoration activities and application of pesticides, herbicides, and insecticides. However, as noted in this section and in Response 2.1 above, Action 10-4.1 of the MBHMP requires all potentially invasive activities be conducted between April 1 and September 30 unless authorized by a qualified biologist, which would reduce impacts to monarch butterflies since the species is generally not present in the Coverage Area during this period. Action 10-4.1 of the MBHMP specifically identifies invasive species eradication as one such activity subject to this restriction. Furthermore, Mitigation Measure HWQ-2 further restricts application of herbicides and pesticides by requiring a Chemical Application Control Plan prior to use of chemical fertilizers, herbicides, and pesticides. The Draft IS-MND concludes that impacts to monarch butterfly would be less than significant, and would be further reduced through implementation of the pesticide restrictions in Mitigation Measure HWQ-2 and the site housekeeping, biological monitoring, and worker awareness provided by Mitigation Measures BIO-1, BIO-2, and BIO-3.

Response 2.3
The commenter opines given the small population of monarch butterflies, it is likely too risky and dangerous to capture, tag, and release monarch butterflies for tracking, which is a covered activity under the MBHMP’s Monarch Research Program. The commenter further requests population parameters be established for this covered activity to occur.

The MBHMP allows for capture, tagging, and release of monarch butterfly individuals in conjunction with approved research efforts to provide information helpful to MBHMP management programs.

Such efforts would be subject to approval by the City and regulated by Scientific Research Permits, as noted in Action 21-1.1 of the MBHMP. Additionally, Action 21-1.2 of the MBHMP requires scientists to use non-invasive research methods at Ellwood Mesa.

The City of Goleta’s Scientific Research Permit Application requires information such as estimated research project duration and dates, summary of proposed research, species and number of individuals to be held captive. The application process allows the City to review proposed research C-9
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efforts prior to their implementation to verify such methods would be non-invasive, consistent with Action 21-1.2 of the MBHMP above. Furthermore, the application includes a checklist to identify other permits required from CDFW or the U.S. Fish and Wildlife Service, including a scientific collecting permit for projects involving collection of vertebrate or invertebrate wild animals or plants, which would include any proposed capture and tagging of monarch butterflies. Review of proposed research methods by the City in addition to other applicable agencies would ensure such methods do not pose a threat to monarch populations at Ellwood Mesa. Therefore, covered activities under the MBHMP’s Monarch Research Program would not result in a potentially significant impact to monarch populations, and impacts to the species would remain less than significant with mitigation incorporated, as noted in Section 4, Biological Resources, of the Draft IS- MND.

Response 2.4
The commenter states the City of Goleta has 16 parks, as opposed to the 6 parks and 8 open spaces noted in Section 16, Recreation, of the Draft IS-MND.

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Goleta has six City16 public parks, 4 private parks, and eight18 public open spaces, totaling approximately 482526 acres (City of Goleta 200618a). This equates to approximately 1516.4 acres per 1,000 residents (based on a current [2018] population of 31,949 [DOF 2018]).

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LAW OFFICE OF MARC CHYTILO, APC
————————————————————————

ENVIRONMENTAL LAW

LAW OFFICE OF MARC CHYTILO, APC
P.O. Box 92233 • Santa Barbara, California 93190
Phone: (805) 682-0585 • Fax: (805) 682-2379
Email(s): [email protected] (Marc); [email protected] (Ana) February 25, 2019
Anne Wells, Advanced Planning Manager By email to [email protected] City of Goleta
130 Cremona Dr. #B
Goleta, CA 93117
RE: Mitigated Negative Declaration for the Ellwood Draft Monarch Butterfly Habitat Management Plan
Dear Ms. Wells:

This office represents the Friends of the Ellwood Monarchs (FOTEM), a community group formed in response to various threats to the Ellwood eucalyptus forest which is critical overwintering habitat for Monarch butterflies. We have reviewed the Draft Mitigated Negative Declaration and Revised Draft Monarch Butterfly Habitat Management Plan (MBHMP) and offer the following comments. Our suggested language changes are indicated in strikethrough and underline.

We appreciate that the revised MBHMP includes many of the revisions that we suggested in our 9/3/18 comment letter on the proposed Draft MBHMP. While we understand and accept that not all of our suggested changes were included, there are several – discussed below - that are critical to ensuring that the MBMHP does not result in potentially significant impacts to monarch butterfly habitat. Moreover, some other changes made in the revised MBHMP actually weaken previous protections for monarch habitat contained in the draft MBHMP. Since the revised MBHMP was prepared, the western monarch population has experienced a dramatic decline. Accordingly, it is more imperative than ever that the City take an extremely cautious approach toward management of the grove to ensure ongoing use by the monarch butterfly (see Goal 10), and only allow habitat restoration that focuses on other habitat values where it also enhances rather than diminishes habitat values for the monarch butterfly. Below we suggest specific language changes necessary to ensure that the MBHMP including restoration activities will not result in potentially significant impacts to the monarch butterfly and its habitat.

Additionally, there are several areas of the MND, including its discussion of aesthetics and historic/cultural resources, that require revision to be consistent with California Environmental Quality Act (CEQA) requirements. We request that the City address the issues raised herein in revisions to the MND and to the MBHMP.

1. CEQA Overview
“The foremost principle under CEQA is that the Legislature intended the act ‘to be interpreted in such manner as to afford the fullest possible protection to the environment within the Letter 3
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reasonable scope of the statutory language.’” (Friends of Mammoth v. Board of Supervisors (1972) 8 Cal.3d 247, 259). CEQA “creates a low threshold requirement for initial preparation of an EIR and reflects a preference for resolving doubts in favor of environmental review when the question is whether any such review is warranted.” (League for Protection of Oakland’s Architectural and Historic Resources v. City of Oakland (1997) 52 Cal. App. 4th 896, 904-905; Pub. Res. Code § 21151.)

An MND may be prepared in lieu of an EIR only where feasible and specific mitigation measures are so clearly effective that no substantial evidence can be produced that the revised project may still have significant environmental effects. (California Environmental Law & Land Use Practice (Matthew Bender & Co., Inc., 2013) § 21.09; Pub. Res. Code § 21080 (c)(2); Guidelines §§ 15064 (f)(2), 15070 (b).)

Here, the MND relies largely on the policies and provisions of the MBHMP to self-mitigate potentially significant impacts including impacts to monarch butterflies and their habitat. As currently drafted, key provisions of the MBHMP are not so clearly effective that no substantial evidence of potentially significant impacts can be produced. Below, we identify areas for clarification and suggest specific policy language that would ensure potentially significant impacts to monarchs, and also to aesthetics and cultural resources, are mitigated to less than significant levels as CEQA requires.

2. Aesthetics

To enable an assessment of whether a project’s environmental effects are likely to be significant, the environmental document must include an accurate description of the environmental setting. (Communities for a Better Environment v. South Coast Air Quality Management Dist. (2010) 48 Cal.4th 310, 315; CEQA Guidelines § 15125 (a).) T he MND’s aesthetic impact discussion begins with a description of the existing setting which describes views and scenic vistas in the area. (Pp. 31-32.) This description is incomplete however, because it omits any description of the existing Ellwood eucalyptus grove which is a dominant visual feature of the Project area landscape. Blue-gum eucalyptus with their substantial height and girth, is the main tree type that characterizes the grove’s aesthetics, and must be expressly identified and included in the environmental setting to enable an adequate discussion of the Project’s aesthetic impacts.

A Project that would “substantially damage scenic resources, including but not limited to, trees…” would result in significant environmental impacts to the aest hetic environment. (MND p.

32.) The MND’s discussion of this potential impact focuses on removal of dead and diseased vegetation improving the eucalyptus grove as a visual resource, however does not discuss how the visual integrity of the grove will be preserved over time as dead and diseased trees are removed.

The draft MBHMP had identified “Planting eucalyptus trees” “To correct habitat deficiencies such as: The overstory has become too sparse…” (draft MBHMP, p. 25, Table 1 (Identified Threats and Potential Response Actions).) However, the revised MBHMP refers only to “Planting trees”. (p.

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30, Table 2 (Identified Threats and Potential Response Actions).) The visual qualities of tree species are distinct, and especially here where no native tree species have similar height and evergreen qualities. (See Monarch Butterfly Overwintering Sites in Santa Barbara County, California, Meade, 1999.) Accordingly, without an express provision calling for replacing lost eucalyptus in kind, the visual character of the grove will eventually be lost, resulting in potentially significant impacts to aesthetics.

To ensure that the Project’s aesthetic impacts are mitigated below significant levels, the MBHMP must be revised to reincorporate the planting of eucalyptus trees when the overstory has become too sparse (Identified Threats and Potential Response Actions Table), and as discussed in section 3 below, include a specific provision calling for the replacement of removed eucalyptus trees in kind and identification of blue gum and other eucalyptus species in the identified plant list.

Additionally, Policy 12-1 should be modified to clarify that not only eucalyptus trees within the aggregation sites are included as follows:

Policy 12-1. Eucalyptus trees in the groves containing monarch butterfly aggregation sites within the Coverage Area shall be managed, as feasible, to ensure tree health and longevity.

As modified, Policy 12-1 not only helps mitigate potential aesthetic impacts from excessive tree loss, but it also better accomplishes the Plan’s goal of ensuring the ongoing use of Ellwood Mesa by the monarch butterfly (further discussion and other proposed changes to Program 12 in section 3.b. below).

3. Biological Resources

a. Importance of Eucalyptus Replacement

The MND and responses to comments on the draft MBHMP are clear that eucalyptus are critical for overwintering monarch butterflies, especially in this area. The MND explains “agencies and resource experts maintain that management of the eucalyptus trees that support the butterflies are paramount to continued overwintering by the species.” (MND p. 65.) The MND relies on tree replacement identified in the MBHMP to conclude the Project would not result in potentially significant impacts to monarch habitat. For example, the MND states:

“implementation of the Natural Resource Program in the MBHMP would maintain and enhance suitable habitat for the monarch butterfly. Replanting habitats where dead or dying eucalyptus trees are removed will help sustain the long-term viability of the eucalypts groves as monarch butterfly habitat.”

(MND p. 71, see also p. 73 “The MBHMP calls for the replacement of the removed trees and enhancement of the groves with planting of eucalyptus in the historical grove footprint only . . . gaps or reductions in the grove caused by tree die off would be replenished”).

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However, as currently drafted, the revised MBHMP does not clearly call for the replacement of dead or dying eucalyptus trees with other eucalyptus trees. A plan whose goal is to manage, preserve, maintain, and improve the eucalyptus forest that is monarch butterfly habitat should describe when and where planting or replanting eucalyptus trees, as well as native trees, may be necessary. Below are specific changes to Program 12 that are necessary to ensure that the specific language of the MBHMP is consistent with the MND, and to ensure that the MBHMP self-mitigates any impacts from eucalyptus tree loss by clearly calling for replacement in kind.

Action 12-1.2. Table 2 should say “Planting eucalyptus trees or planting native trees” as Potential Actions/Tools for Management to “Correct habitat deficiencies” caused by death of trees or insufficient canopy or site protection. To remedy these threats there must be an option to plant eucalyptus trees when indicated to preserve habitat value.

Action 12-1.6 and 12-1.10 require clarification of the type of habitat that should be created within the outline of the pre-drought eucalyptus forest where dead zones have occurred due to tree die-offs.

The re-establishment of eucalyptus forest monarch butterfly habitat in this area should be specified.

A map to clarify the outline of the historic pre-drought eucalyptus forest would facilitate preservation of monarch habitat.

Action 12-1.6. Maintain a living eucalyptus forest within the outline of pre-drought forest extent as determined with historic aerial photographs. Replant sections of the eucalyptus forest where dead zones occur due to multiple tree die-offs.

Action 12-1.10. Plant trees as needed to maintain grove density and improve monarch butterfly habitat. Plant in locations that improve aggregation site conditions as per the best available scientific analysis, and replant eucalyptus in areas within historic eucalyptus grove extent where gaps have occurred from drought die-back.

b. Importance of Unoccupied Groves

The MND states “Grove and windrow areas between aggregation sites have not been recorded to support monarch butterfly aggregations.” (MND p. 53.) However, these areas are valuable to the monarch population, and are identified as monarch ESHA in the City’s General Plan. Moreover the Ellwood-Devereux Coast Open Space and Habitat Management Plan explains the biological significance of the eucalyptus groves outside the aggregation sites and their designation as ESHA despite the fact that no known monarch aggregation sites exist as follows:
“Unoccupied eucalyptus groves within the City of Goleta in areas adjacent to the overwintering sites that contain suitable conditions to support overwintering butterflies are also considered ESHAs because they could be used at any time in the future, and because they provide additional habitat in C-14
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the event that the occupied groves are damaged.” (P. 21.)1 The damaged conditions currently manifesting in and around the Ellwood Open Space aggregation sites underscores the importance of protecting the entire grove and not merely the aggregation areas.

While it appears that the MBHMP is intended to apply to the eucalyptus groves in the coverage area generally and not only the aggregation sites, it is not entirely clear from the document. In the Comment Matrix, the second from last comment on page 25 asks “Is the treatment different for “aggregation areas,” “roosts,” “trees supporting seasonal monarch butterfly aggregation sites,” “aggregation site buffers” or “the eucalyptus forest beyond the buffer.” The response is “There is no difference in the treatments for these various areas.” However, that is not entirely clear from reading some parts of the MBHMP.

In particular, Program 10, Monarch Butterfly Management Program, refers only to the conservation of, the preservation of, and the timing of work in, only “aggregation sites.” The below Program 10 actions and policies should be revised as indicated to clarify that they apply throughout the eucalyptus grove, which is necessary to ensure that the Project will not result in potentially significant impacts to monarch ESHA.

Figure 2 in the MBHMP, Monarch Butterfly Aggregation Sites, depicts the aggregation sites as small red circles. It could be understood that the protections for monarch habitat and eucalyptus trees only apply to these small areas, so this needs to be clarified, and a map such as Figure 7 in the MND which depicts the coverage of the grove should be included in the MBHMP itself for additional clarity.

Action 10-1.1. Implement Program 12, Tree Management Program, to help facilitate the conservation of the eucalyptus groves and windrows in the Monarch Butterfly Habitat Management Plan Coverage Area monarch butterfly aggregation sites.

Policy 10-2. Preservation of the eucalyptus groves and windrows aggregation sites on Ellwood Mesa shall be the focus of management activities, as feasible, and in coordination with Program 9, Catastrophic Event Response Program.

Action 10-2.1. Should one or more catastrophic events result in impacts on the sustainability of monarch butterfly aggregation sites, consider alternative management and recovery strategies

1 As explained in our 9/1/18 comment letter on the draft MBHMP, these valuable unoccupied eucalyptus groves include the un-named City-owned open space, west and north of the Coronado site that that crosses Santa Barbara Shores Dr. and extends north to Hollister between Santa Barbara Shores Dr. and Pebble Beach Dr. which we called “Area S”. To ensure maximum potential monarch habitat is protected, our preference is for the MBHMP to include Area S.

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that incorporate goals for sustaining the eucalyptus groves and windrows aggregation sites at Ellwood Mesa.

Policy 10-4. To avoid impacts on monarch butterflies while they are present at the Ellwood aggregation sites, no maintenance or restoration work shall be conducted in the eucalyptus groves and windrows at Ellwood Mesa aggregation sites from October 1 through March 31 of each year, unless authorized by a qualified biologist.

Additionally, Action 2-2.2 allows payments of compensatory mitigation fees into the Butterfly Fund, for projects with “limited impacts on monarch butterfly habitat.” It is critical that the City not allow projects that impact monarch butterfly habitat, especially now with the precipitous decline observed this past overwintering season. Action 2-2.2 should be revised to clarify that payment of compensatory mitigation fees are only allowed where projects have implemented all available measures to avoid impacts to monarch butterfly habitat, or to directly mitigate impacts on-site where appropriate, before projects may turn to compensatory mitigation.

c. Devereaux Creek Restoration Activities

Program 14, Habitat Enhancement and Restoration Program, calls for restoration activities including replacement with native plant species along the banks of Devereaux Creek. While it appears the intent of this Program is to limit its applicability to areas outside the eucalyptus grove, the language in the MBHMP is insufficiently clear and requires revision to ensure that restoration activities do not result in the destruction of eucalyptus and monarch habitat, and associated potentially significant impacts.

Language in the Overview describing areas where enhancement or restoration can take place should be consistent with language in the following Policies and Actions in this program. The Overview speaks about the “restoration of the Devereux Creek corridor along the northern margin of Ellwood West, Ellwood Main, and Ellwood East groves. However, the northern margins of Ellwood West and Ellwood East are not “existing native riparian areas,” nor are they “areas between eucalyptus groves. “Restoration” is restricted in Action 14.3 to “existing native riparian areas,” and in Action 14-2 to “areas between eucalyptus groves.” In addition, the northern margin of Ellwood East is not within the MBHMPP coverage area because it is on private property. For consistency and accuracy, we suggest the following change to the language of the overview:

Overview: This program focuses on the enhancement of the eucalyptus groves from a native plant and wildlife habitat perspective and on the restoration of the Devereux Creek corridor in existing native riparian areas. along the northern margin of Ellwood West, Ellwood Main, and Ellwood East groves. The mid-canopy vegetation and understory of the eucalyptus groves is generally lacking or in some situations is composed of non-native invasive plant species.

Enhancement of groves with native plant species would benefit native wildlife. Various native plants are present but scattered within the groves. Most of these plant species have fleshy fruits C-16
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and are bird-dispersed. Restoration with native plants of portions of Devereux Creek in areas between associated with eucalyptus groves, as feasible, is consistent with the goal to restore Devereux Creek. This restoration would provide important habitat for native plant and animal species and would potentially improve water quality flowing downstream to Devereux Slough and the Pacific Ocean.

In addition, clarification is required to Policy 14.3, Action 11-2.4, as follows:

Policy 14.3 allows “restoration of Devereux Creek “only in areas that are “existing native riparian areas." However, there is no map that defines where those areas are. The MBHMP should include Figure 2 from the MND showing the Drainages and Vegetation Communities within the MBBHMP coverage areas to clarify this policy.

In Action 11-2.4, the Devereux Creek restoration language should be consistent with language in Policy 14.3, which restricts restoration of Devereux Creek to “the existing native riparian areas.” Specifically, we suggest the following revision:

Action 11-2.4. Implement restoration for the existing native riparian areas in the Devereux Creek riparian corridor to improve functions for wildlife, consistent with the goals of this MBHMP for monarch butterflies.

Without these changes, the MBHMP is insufficiently clear and does not clearly self-mitigate with respect to Program 14 without these changes.

d. Monitoring Activities

Monitoring and reporting are key tools necessary to ensure that the MBHMP functions as intended, and that provisions of the Plan relied on to self-mitigate impacts to monarch butterflies and their habitat are actually effective at reducing impacts below significant levels as CEQA requires. We suggest the following two changes to ensure that monitoring and public reporting are adequately incorporated into the Plan.

Policy 20-3: Create a Monitoring Report, updated annually, when feasible, resulting from the information obtained during the implementation of the various policies and actions called for in this MBHMP.

Action 20-3.1: Track the implementation of this MBHMP in the form of a Monitoring Report, preferably updated on an annual basis, and presented at a public workshop.

Additionally, the City of Goleta is not the only entity that may undertake activities within the MBHMP coverage area. For example, Southern California Edison (SCE) undertakes activities including tree limbing to reduce fire hazards associated with their lines. We appreciate that the C-17
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revised MBHMP includes reference to activities undertaken by other utilities and agencies in Action 1-2.1, however the monitoring component we suggested was not incorporated, and without that it the Plan lacks the enforceability necessary to avoid potentially significant impacts from the tree pruning, removal, and other activities of other entities. Last year, SCE undertook a limbing project which far exceeded the scope of their emergency permit, as noted by Dr. Meade at the September 2018 Council hearing on the draft MBHMP. Accordingly, we ask that you incorporate additional changes to Action 1-2.1, as follows:

Action 1-2.1. Whenever vegetation removal, ground disturbance, construction, or other activities with the potential to significantly disrupt habitat values are proposed within the MBHMP coverage area by the City or any other agency or utility, environmental protection measures shall be implemented. These measures shall be determined in coordination with a qualified biologist, and should normally shall include at a minimum pre-activity surveys for nesting birds or other wildlife, pre-activity surveys for monarch butterfly aggregations, presence of an environmental monitor during construction, and other protections, as deemed appropriate. The City will monitor these activities to ensure that environmental protection measures are used and that activities are limited to those permitted.

4. Historical/Cultural Resources

As with visual resources, the environmental setting for historical/cultural resources is fundamentally flawed and incomplete for failing to recognize the historic and cultural value of the Ellwood eucalyptus groves. It is well recognized that landscapes may be historically or culturally significant – and eligible for listing on the national, state, and local registers of historic resources - including where, as here, they are associated with a historic event, activity, or person. The National Park Service defines a cultural landscape as a geographic area, including both cultural and natural resources and the wildlife or domestic animals therein, associated with a historic event, activity, or person, or exhibiting other cultural or aesthetic values. (https://www.nps.gov/subjects/culturallandscapes/understand-cl.htm.) The City’s General Plan also recognizes historical and cultural landscapes and states an objective “to identify, preserve, protect, and enhance historic landscaping, gardens, and open spaces, including agricultural areas and heritage trees, which contribute to the setting or context of Goleta.” (Visual and Historic Resources Element, Policy VH 6.) Here, the Ellwood eucalyptus groves were planted by Ellwood Cooper in the 1870s, as described and recognized in the City’s Tree and Landscape Study and the City’s Historic Preservation Context Statement (3/5/18, available at https://www.cityofgoleta.org/projects- programs/historic-preservation and incorporated herein by reference.) The MND must describe the historical significance of the Ellwood grove to enable an adequate analysis of the Project’s potentially significant impacts to cultural/historic resources.

A Project that causes a substantial adverse change in the significance of a historical resource results in a significant environmental impact. (MND p. 81; Pub. Res. Code § 21084.1.) Historical C-18
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resources include both listed resources, and resources determined to be eligible for listing. (Id.) It is imperative that the MND be revised to incorporate an analysis of whether the Ellwood grove is eligible for listing as a cultural landscape, and if so, whether the Project may result in potentially significant impacts to that resource. Plan revisions we identified above to ensure that aesthetic and biological resource impacts are adequately mitigated – in particular those clarifying that eucalyptus shall be replaced with eucalyptus – would also appear to mitigate potential cultural resource impacts.

5. Conclusion

We ask that the City incorporate the above identified changes in revisions to the MND and to the MBHMP to ensure that the documents are comprehensive, legally adequate, and that all potentially significant impacts are fully mitigated.

Respectfully submitted,

AW OFFICE OF MARC CHYTILO, APC

Ana Citrin
For FOTEM

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Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments Final Initial Study – Mitigated Negative Declaration
Letter 3
COMMENTER: Ana Citrin, Law Offices of Marc Chytilo, APC, for Friends of the Ellwood Monarchs DATE: February 25, 2019
Response 3.1
The commenter provides background information on the intent of the California Environmental Quality Act (CEQA) and comments the Draft IS-MND relies largely on the policies and provisions of the MBHMP to self-mitigate potentially significant impacts, including impacts to monarch butterflies and their habitat. The commenter opines that, as drafted, key provisions of the MBHMP are not so clearly effective that no substantial evidence of potentially significant impacts can be produced.

The Draft IS-MND assesses the potential environmental impacts associated with implementation of the MBHMP, including covered activities with the potential to occur under the MBHMP’s 22 programs. The purpose of the MBHMP is to provide a programmatic approach to management of the habitats that support the monarch butterfly seasonal aggregation areas at the Ellwood Mesa Open Space, as well as a variety of other plant and animal species and coastal access and recreation.

In light of this purpose, implementation of the MBHMP would largely result in less than significant— and in some cases, beneficial—impacts to several of the resource concerns evaluated pursuant to CEQA, including biological resources, recreation, and wildfire. While many provisions of the MBHMP would result in less than significant or beneficial environmental impacts, the Draft IS-MND does not rely exclusively on such provisions to reduce impacts to a less than significant level. The Draft IS- MND contains Mitigation Measures AQ-1, BIO-1 through BIO-9, CUL-1, GEO-1, HWQ-1 and HWQ-2, and N-1 to reduce impacts to aesthetics, air quality, biological resources, cultural resources, geology and soils, hydrology and water quality, and noise such that they would be less than significant with mitigation incorporated. The effectiveness of these measures in reducing impacts below the level of significance is demonstrated in the impact analyses contained in Section 1, Aesthetics, Section 4, Biological Resources, Section 5, Cultural Resources, Section 7, Geology and Soils, Section 10, Hydrology and Water Quality, Section 13, Noise, and Section 21, Mandatory Findings of Significance, of the Draft IS-MND. Any additional actions not covered by the IS-MND would require separate review under CEQA.

The remainder of this comment is general in nature and do not raise specific environmental concerns about the Draft IS-MND or the MBHMP. Therefore, no further response is required to this portion of the comment. (See Browning-Ferris Indus. v. City of San Jose (1986) 181 Cal.App.3d 852 [where a general comment is made, a general response is sufficient].) Responses to specific resource areas identified by the commenter as lacking substantial evidence of no potentially significant impacts are addressed in subsequent responses below.

Response 3.2
The commenter notes the Draft IS-MND’s description of the existing setting with respect to aesthetics is incomplete because it omits any description of the existing Ellwood eucalyptus grove, which is a dominant visual feature of the Coverage Area. The commenter adds the Draft IS-MND’s discussion of impacts to scenic resources focuses on the removal of dead and diseased vegetation improving the eucalyptus grove as a visual resource, however, the MBHMP only states that dead or diseased eucalyptus trees will be replaced with trees and does not specify that such trees will be C-20
City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments

Final Initial Study – Mitigated Negative Declaration
eucalyptus trees. The commenter notes this may alter the visual character of the groves over time if eucalyptus trees are not replaced with other eucalyptus trees.

The Draft IS-MND addresses potential impacts to the visual character of the Coverage Area in Section 1, Aesthetics. The existing setting on Page 31 of the Draft IS-MND has been revised to include discussion of the visual character of Coverage Area, as follows:

The Coverage Area is located in Ellwood Mesa Open Space, an undeveloped open space area categorized in the General Plan as “Open Space/Passive Recreation” where “significant environmental values or resources, wildlife habitats, significant views, and other open space value” exists (City of Goleta 2006a). The visual character of the Coverage Area is dominated by existing eucalyptus groves, creating a forested landscape. The generally evergreen nature of eucalyptus trees creates a patchy- to fully-shaded setting in the Coverage Area, with hanging bark, leaves, and vegetated understory protruding between tree trunks.

As noted in that section and in the Aesthetic Resources Management Program of the MBHMP, the existing eucalyptus groves suffer from grove senescence, drought, pests, disease, or lack of formal management efforts to maintain consistent aesthetic values. As further noted in Section 1, Aesthetics, the removal of dead and diseased trees or deadfall would not be considered removal of any scenic resources on the Coverage Area as it would benefit the overall health of the groves. The MBHMP Tree Management Program calls for reforestation along with removal of dead and diseased specimens with covered activities that include “plant new eucalyptus trees, native and/or fire- resistant understory species, and native nectar sources” for migrating butterflies. The consistent management structure provided by the MBHMP would maintain the visual character of the Coverage Area by improving the health of the groves and supporting monarch butterfly habitat.

Response 3.3
The commenter recommends the MBHMP be revised to specifically state removed eucalyptus trees will be replaced in kind and identify blue gum and other eucalyptus species in the identified plant list. Additionally, the commenter recommends changes to Policy 12-1 of the MBHMP to state eucalyptus trees in the groves shall be managed to ensure tree health and longevity throughout the Coverage Area, rather than just in groves containing aggregation sites.

This comment does not relate to the content or adequacy of the Draft IS-MND, but instead to the content of the MBHMP. Therefore, this comment has been moved to the MBHMP Comment Matrix in Appendix B that was prepared to address comments related specifically to the MBHMP, and a response was provided in the matrix. The MBHMP Comment Matrix will be provided to City Council for its review prior to considering adoption of the MBHMP.

Response 3.4
The commenter states the Draft IS-MND relies on tree replacement identified in the MBHMP to conclude the MBHMP would not result in potentially significant impacts to monarch habitat.

However, the commenter notes the MBHMP does not clearly call for the replacement of dead or dying eucalyptus trees with other eucalyptus trees. The commenter adds the plan should describe when and where planting or replanting eucalyptus trees, as well as native trees, may be necessary.

Final Initial Study – Mitigated Negative Declaration
activities, including tree replanting actions, are general in nature to reflect the need for adaptive management in the face of changing conditions in the Coverage Area. However, the MBHMP contains actions supporting eucalyptus growth within the boundaries of the existing eucalyptus groves, including Action 12-1.11, which calls for a pilot planting for any eucalyptus species considered for tree restoration that is not present in the MBHMP area as of 2018, and Action 12-2. 5, which calls for protecting blue gum saplings as necessary to encourage natural recruitment of trees in the eucalyptus forest. Additionally, the Draft IS-MND does not rely solely on replanting of eucalyptus trees in its determination that impacts to the monarch butterfly would be less than significant with mitigation incorporated. In Section 4, Biological Resources, the Draft IS-MND also notes that planting native species, eradication of non-native species (excluding eucalyptus), and integrated pest management efforts to reduce pests that stress monarch butterflies or their habitat would further enhance suitable habitat for the species in the Coverage Area.

Response 3.5
The commenter recommends a change to Action 12-1.2 of the MBHMP. Specifically, the commenter suggests that Table 2 of the MBHMP be revised to include “Planting eucalyptus trees or planting native trees” as a Potential Action/Tool for Management to correct habitat deficiencies such as sparse overstory, strong wind speeds in the grove, and tree death, toppling, or removal.

Response 3.6
The commenter recommends changes to Actions 12-1.6 and 12-1.10 of the MBHMP specifying maintenance of a living eucalyptus forest and replanting eucalyptus trees.

Response 3.7
The commenter cites language on Page 53 of the Draft IS-MND, which states, “Grove and windrow areas between aggregation sites have not been recorded to support monarch butterfly aggregations.” The commenter notes unoccupied groves are still valuable to the monarch population and identified as monarch Environmentally Sensitive Habitat Area (ESHA) in the City’s General Plan. The commenter states it is not entirely clear in the MBHMP that the MBHMP is intended to apply to the eucalyptus groves in the Coverage Area generally and not only the aggregation sites. In particular, the commenter notes the Monarch Butterfly Management Program refers only to the conservation of, preservation of, and timing of work in aggregation sites, as opposed to the entire eucalyptus grove. Additionally, the commenter notes Figure 2 of the MBHMP depicts aggregation sites in small red circles, which could be interpreted to mean that protections C-22
City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments

Final Initial Study – Mitigated Negative Declaration
for monarch habitat and eucalyptus trees only apply to these small areas. The commenter recommends this point be clarified, and a figure similar to Figure 7 in the Draft IS-MND, which depicts the coverage of the grove, be included in the MBHMP.

The Draft IS-MND notes the extent of monarch butterfly ESHA within the Coverage Area in Section 4, Biological Resources. Certain supporting policies and actions of the MBHMP are intended to preserve aggregation sites in the Coverage Area, such as Policy 10-2 of the Monarch Butterfly Management Program, which states, “Preservation of aggregation sites on Ellwood Mesa shall be the focus of management activities, as feasible, and in coordination with Program 9, Catastrophic Event Response Program.” Such policies and supporting actions provide an added layer of management directive to protect known aggregation sites in the Coverage Area; they do not preclude larger habitat restoration efforts from occurring throughout the Coverage Area, such as removal of dead trees and debris, planting trees as needed to maintain grove density and improve monarch habitat (Action 12-1.10), or monarch butterfly patrolling habitat enhancement efforts (Action 12-2.2). The application of certain MBHMP policies and actions to aggregation sites is accounted for in the analysis of potential environmental impacts, including those to monarch butterflies and their habitat, described in the Draft IS-MND. Given MBHMP management activities would improve habitat conditions throughout the Coverage Area, as discussed in the Draft IS-MND, it would also provide benefits in the areas outside of established aggregation sites.

Response 3.8
The commenter recommends changes to Action 10-1.1, Policy 10-2, Action 10-2.1, and Policy 10-4 expanding the application of these actions and policies to eucalyptus groves and windrows in the Coverage Area, as opposed to monarch butterfly aggregation sites.

Response 3.9
The commenter states Action 2-2.2 allows for payments of compensatory mitigation fees to the Butterfly Fund for projects with limited impacts on monarch butterfly habitat. The commenter adds the City should not allow projects that impact monarch butterfly habitat, and Action 2-2.2 should be revised to allow payment of compensatory mitigation fees only where projects have implemented all available measures to avoid impacts to monarch butterfly habitat, or to directly mitigate impacts on-site where appropriate.

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City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments

Final Initial Study – Mitigated Negative Declaration
Response 3.10
The commenter states language in the Habitat Enhancement and Restoration Program is insufficiently clear and requires revision to ensure restoration activities do not result in the destruction of eucalyptus and monarch habitat and associated potentially significant impacts.

Specifically, the commenter suggests changes to the Overview language in the MBHMP clarifying enhancement or restoration of the Devereux Creek corridor would occur in existing native riparian areas. The commenter adds this language is consistent with the language in supporting Policy 14.3, which limits restoration actions to existing native riparian areas, and Policy 14-2, which states, “areas between eucalyptus groves shall be considered for habitat enhancement and restoration alternatives.”
This comment does not relate to the content or adequacy of the Draft IS-MND, but instead to the content of the MBHMP. Therefore, this comment has been moved to the MBHMP Comment Matrix in Appendix B that was prepared to address comments related specifically to the MBHMP, and a response was provided in the matrix. The MBHMP Comment Matrix will be provided to City Council for its review prior to considering adoption of the MBHMP.

Response 3.11
The commenter requests a map in the MBHMP showing the location of existing native riparian areas. Specifically, the commenter requests the MBHMP include Figure 2 from the Draft IS-MND showing drainages and vegetation communities in the Coverage Area. Additionally, the commenter recommends changes to Action 11-2.4 of the MBHMP to specify restoration in the Devereux Creek riparian corridor would be for “existing native riparian areas.” This comment does not relate to the content or adequacy of the Draft IS-MND, but instead to the content of the MBHMP. Therefore, this comment has been moved to the MBHMP Comment Matrix in Appendix B that was prepared to address comments related specifically to the MBHMP, and a response was provided in the matrix. The MBHMP Comment Matrix will be provided to City Council for its review prior to considering adoption of the MBHMP.

Response 3.12
The commenter notes the importance of monitoring and reporting as key tools necessary to ensure the MBHMP functions as intended and provisions of the MBHMP relied on to self-mitigate impacts to monarch butterflies and their habitat are actually effective at reducing impacts to less than significant levels. The commenter recommends changes to Policy 20-3 and Action 20-3.1 to firmly require annual Monitoring Reports and present such reports at public workshops.

As noted in Response 3.1, above, the Draft IS-MND contains 15 mitigation measures incorporated to reduce potential impacts to a less than significant level. A Mitigation Monitoring and Reporting Program (MMRP), included as Appendix D, requires the City to monitor the effectiveness of these mitigation measures and includes required actions, monitoring timing, frequency, responsible parties, and compliance verification steps. The remainder of this comment, notably recommended changes to Policy 20-3 and Action 20-3.1 of the MBHMP, does not relate to the content or adequacy of the Draft IS-MND, but instead to the content of the MBHMP. Therefore, this comment has been moved to the MBHMP Comment Matrix in Appendix B that was prepared to address comments related specifically to the MBHMP, and a response was provided in the matrix. The MBHMP C-24
City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments

Final Initial Study – Mitigated Negative Declaration
Comment Matrix will be provided to City Council for its review prior to considering adoption of the MBHMP.

Response 3.13
The commenter states the City is not the only entity that may conduct activities in the Coverage Area, noting previous tree pruning, removal, and other activities by SCE.

Response 3.14
The commenter requests changes to Action 1-2.1 of the MBHMP. Action 1-2.1 of the MBHMP states that pre-activity surveys for nesting birds, monarch butterfly aggregations, and other wildlife, the presence of an environmental monitor during construction, and other protections, as deemed appropriate, should normally occur whenever vegetation removal, ground disturbance, construction, or other activities are proposed within the Coverage Area by the City or any other entity. The commenter requests that this language be revised to indicate that such measures always occur. Additionally, the commenter requests the measure be revised to require the City to monitor such activities to ensure environmental protection measures are used and activities are limited to those permitted.

Response 3.15
The commenter states the opinion the environmental setting for historical/cultural resources contained in the Draft IS-MND is fundamentally flawed and incomplete for failing to recognize the historic and cultural value of the Ellwood eucalyptus groves. The commenter adds that the Draft IS- MND must describe the historical significance of the Ellwood grove to provide adequate analysis of the MBHMP’s potentially significant impacts to cultural/historical resources, including an analysis of whether the Ellwood grove is eligible for listing as a cultural landscape and, if so, whether the MBHMP would result in potentially significant impacts to that resource.

The existing setting in Section 5, Cultural Resources, acknowledges the history of the eucalyptus groves, stating, “In the 1870s, Ellwood Cooper introduced eucalyptus trees to Ellwood Mesa and by the mid-1870s had successfully planted approximately 50,000 trees of more than 50 varieties. The groves have matured and become useful for windbreaks. Today the eucalyptus groves present on Ellwood Mesa are a remnant of Cooper’s early attempt at eucalyptus forestry.” The MBHMP prescribes management directives to enhance, restore, and maintain monarch butterfly habitat within the Coverage Area, including the existing eucalyptus groves. As discussed in C-25
City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments

Final Initial Study – Mitigated Negative Declaration
Response 3.4 above, the MBHMP contains actions targeted at supporting eucalyptus growth within the existing grove boundaries and maintaining a healthy forest system. Covered activities would improve the health and vibrancy of the deteriorating groves and, therefore, would not adversely change the historical or cultural significance of the groves. The MBHMP Tree Management Program calls for reforestation along with removal of dead and diseased specimens with covered activities that include “plant new eucalyptus trees, native and/or fire-resistant understory species, and native nectar sources” for migrating butterflies. In addition, without implementation of the MBHMP, additional eucalyptus trees would deteriorate and the overall health of the grove would decline.

Because of this provision and the ability to manage the health of the grove, no impact to a cultural landscape, if present, would occur.

C-26
February 22, 2019
City of Goleta Planning and Environmental Review
130 Cremona Drive, Suite B
Goleta,CA 93117
FEB 2 5 2mg
Comments on Draft Initial Study-Mitigated Negative Declaration for the Monarch Butterfly Habitat Management Plan (MBHMP)
Attention: Ms. Anne Wells, Advance Planning Manager
Dear Ms. Wells,
In reviewing the draft MBHMP it provided a fairly focused yet generic approach to managing the area primarily for eucalyptus trees while giving some mention for other existing wildlife resources and native riparian and upland habitats in and adjacent to the study area. There is a need for a more balanced approach to truly provide for a "healthy riparian habitat area" which will better support the butterflies along with the other native species which exist here.

There is a need for more specific descriptions of what constitutes the primary constituent elements of habitat critical for the overwintering butterflies, not just planting and watering more eucalyptus trees (which in themselves provide a significant source of fuel for potential wildfires). Use of the Xerces Society 2017 publication: Protecting California's Butterfly Groves: Management Guidelines for Monarch Butterfly Overwintering Habitat would be one source from which to gain said information. Working with the U.S. Fish and Wildlife Service in their review of proposals to have the species listed as threatened or endangered would be another recommendation.

The few maps provided are extremely general and need to be of a scale which provides for definition of densities of trees; areas with dead and dying trees and other factors critical to managing the habitat.

The comment letter provided by Lisa Stratton, Director of Ecosystem Restoration at UC Santa Barbara, provides added factors which need to be included in a sound management plan in order to be able to determine if the area is actually meeting desired habitat characteristics for the butterflies and other unique and sensitive wildlife and plants which may occur in the area.

Both the Community Wildfire Protection Plan( CWPP) and MBHMP address habitat management activities to protect, maintain and enhance the Monarch Butterfly Management Area, except neither of them mention the presence of or maintenance needs relative to the SCE power lines and the potential that these power lines hold to become a significant ignition source for wildfire, which poses the greatest threat to the Monarchs and their habitat in addition to the residents and properties which exist adjacent to the management area.

The following comments are respectfully submitted to address what should qualify as a significant issue which I believe has been overlooked in both the Goleta Community Wildfire Protection Plan (CWPP) of 2012, and the current Draft Monarch Butterfly Habitat Management Plan (MBHMP) and related Draft Mitigated Negative Declaration of 2019.

Letter 4
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C-31
City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments

Final Initial Study – Mitigated Negative Declaration
Letter 4
COMMENTER: Maeton Freel, Resident
DATE: February 22, 2019
Response 4.1
The commenter opines the MBHMP provides a generic approach to managing the Coverage Area primarily for eucalyptus trees, while mentioning other existing wildlife resources and native riparian and upland habitats in and adjacent to the Coverage Area. The commenter recommends a more balanced approach to better support both butterflies and other native species. The commenter further recommends use of The Xerces Society’s 2017 publication Protecting California’s Butterfly Groves: Management Guidelines for Monarch Butterfly Overwintering Habitat and working with the United States Fish and Wildlife Service (USFWS) in its review of proposals to have the monarch butterfly listed as threatened or endangered.

Response 4.2
The commenter provides the opinion the maps included in the MBHMP are general and need to be at a scale which provides for definition of tree densities, areas of dead and dying trees, and other factors critical to managing the habitat.

Response 4.3
The commenter draws attention to comments provided by Lisa Stratton, Director of Ecosystem Restoration at the University of California, Santa Barbara, which provide additional factors for consideration in a sound management plan to determine whether an area is actually meeting desired habitat characteristics for monarch butterflies and other wildlife and plants occurring in the area.

C-32
City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments

Final Initial Study – Mitigated Negative Declaration
Response 4.4
The commenter states neither the Community Wildfire Protection Plan (CWPP) nor the MBHMP mention the presence or maintenance needs of existing Southern California Edison (SCE) power lines in the Coverage Area. The commenter notes power lines are an ignition source for wildfire and discusses State policies requiring vegetation maintenance work along power lines, specifically Public Resources Code 4293 and California Public Utilities Commission General Order 95. The commenter mentions hazard tree pruning activities during the summer of 2018 along the eastern boundary of the Ellwood North aggregation site were necessary to comply with State regulations and have had no known effect on the use of the aggregation site. The commenter adds the Draft IS-MND should include specific tree maintenance standards tied to the power line maintenance activities, allowance of and support for SCE to conduct State-mandated vegetation management programs, and actions by the City to address any further needed vegetation management actions which would preclude hazard trees from contacting or striking SCE power lines in the Ellwood Mesa area.

The Draft IS-MND discusses potential wildfire impacts in Section 20, Wildfire. The discussion contained in this section notes implementation of the MBHMP would reduce potential wildfire risk in the Coverage Area by removing dead, dying, or otherwise hazardous trees and re-planting the understory around aggregation sites with fire-resistant, native plant species. The Draft IS-MND concludes implementation of the MBHMP would result in no impact related to wildfire, and may result in a beneficial effect.

Vegetation and tree removal efforts conducted by SCE in the Coverage Area occur pursuant to permits obtained by the utility. While the City may conduct covered activities in the existing SCE easements in the Coverage Area, it cannot prevent SCE from conducting tree topping, trimming, or removals if such activities are consistent with its easement rights and SCE has obtained necessary permits, such as those issued by the CCC. Such activities would continue as deemed necessary by SCE to reduce wildfire risks associated with its electrical facilities in the Coverage Area. Section 20, Wildfire, of the Draft IS-MND has been amended to include this information, with the following language added:

The MBHMP does not propose construction or maintenance of any new infrastructure which may pose a fire risk. The Coverage Area contains existing power lines owned and operated by SCE. SCE has previously conducted vegetation removal efforts to reduce fuel loads and hazardous trees in the vicinity of these lines. These vegetation removal efforts would continue, subject to SCE’s own permits and easement rights.

The MBHMP would not involve construction of any structures, and therefore would not expose any additional people or structures to risk of wildfire. As noted in Section 9, Hazards and Hazardous Materials, the project would not interfere with an adopted emergency response or evacuation plan.

Given its gentle sloping topography, the Coverage Area would not be susceptible to post-fire flooding, landslides, or slope instability. There would be no impact.

Response 4.5
The commenter cites language in the Draft IS-MND’s Background section stating drought has compromised the health of eucalyptus trees in Ellwood Mesa exacerbating wildfire risk. The commenter states wildfire poses the greatest threat to the Coverage Area and every effort should be undertaken by the City to avoid or minimize potential sources of fire in the Coverage Area.

C-33
City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments

Final Initial Study – Mitigated Negative Declaration
This comment is noted. Please refer to Response 4.4, above, for discussion of how the MBHMP would affect wildfire risk and hazard mitigation efforts.

Response 4.6
The commenter cites language from the CWPP stating the protection of human life and safety is the highest priority for all fire management strategies in Goleta, followed by the protection of property.

The commenter states this language supports efforts by SCE to conduct needed pruning, topping, and removal of any trees with potential to grow into or fall on power lines and that the City should support these efforts.

As discussed in Section 20 of the Draft IS-MND, Wildfire, the MBHMP pledges support for the policies and activities contained in the CWPP, which includes policies intended to reduce fire hazards from fuel loads in the Coverage Area. Please refer to Response 4.4 for discussion of how the MBHMP relates to efforts by SCE to prune, top, or remove trees along power lines in the Coverage Area.

Response 4.7
The commenter notes the CWPP states larger trees in the Fuel Reduction Zone (30-100 feet from structures) should be left in place unless they pose a toppling hazard as defined by the City arborist.

This directive is noted in Table 1 of the Draft IS-MND. The commenter states no arborist can fully predict which trees are likely to fall, and the City should be proactive and support the topping, trimming, and removal of all trees with potential to fall and strike SCE power lines.

As noted by the commenter and described in the Draft IS-MND, the directive to leave larger trees in the Fuel Reduction Zone in place unless they pose a toppling hazard is contained in the CWPP, not the MBHMP. The CWPP was previously approved in 2012, and the MBHMP proposes no changes to the CWPP. Please refer to Response 4.4 for discussion of how the MBHMP relates to efforts by SCE to prune, top, or remove trees along power lines in the Coverage Area.

Response 4.8
The commenter notes Goals, Policies, and Actions, as well as covered activities identified for the MBHMP’s programs support the need to reduce wildfire hazards associated with SCE power lines in the Coverage Area.

This comment is noted. Please refer to Response 4.4 for discussion of how the MBHMP relates to efforts by SCE to prune, top, or remove trees along power lines in the Coverage Area.

Response 4.9
The commenter recommends areas between existing groves of eucalyptus should not be planted with eucalyptus, as this only provides a continuous interconnected supply of highly flammable vegetation. The commenter further states gaps between groves, or fuel breaks, would better support the long-term viability of the aggregation sites by reducing wildfire risk.

As described in Section 20, Wildfire, of the Draft IS-MND, replacement trees would be planted within the boundaries of the existing eucalyptus groves, and no expansion of the existing eucalyptus groves would occur. As a result, implementation of the MBHMP would not increase the supply of C-34
City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments

Final Initial Study – Mitigated Negative Declaration
highly flammable vegetation in the Coverage Area, and would reduce fuel by replacing dead, dying, or otherwise hazardous trees with less fire-prone healthy trees.

Response 4.10
The commenter notes the small grove of eucalyptus trees between Pebble Beach Drive and Santa Barbara Shores Drive is highly susceptible to wind throw due to the extreme height and mass of their canopies coupled with direct exposure to high winds. The commenter adds these trees have weakened root systems due to years of drought and are located on unstable, saturated soils given their proximity to Devereux Creek, making them susceptible to falling. The commenter states the opinion this further qualifies these trees as hazard trees with potential to fall on power lines along the eastern and western boundary of this grove.

The eucalyptus grove between Pebble Beach Drive and Santa Barbara Shores Drive is not located in the Coverage Area, and covered activities of the MBHMP would not occur in this grove. SCE’s tree pruning, topping, and removal efforts may continue in this grove under permits obtained by the utility, as long as such efforts are consistent with SCE’s existing easement rights. Please refer to Response 4.4 for discussion of efforts by SCE to prune, top, or remove trees along power lines in the Coverage Area.

Response 4.11
The commenter cites language in the Draft IS-MND noting some species of eucalyptus on Ellwood Mesa, such as blue gum, have deciduous bark, which poses a fire hazard as streamers from loose bark carry fire into the canopy and cast firebrands ahead of the main fire front. The commenter states this language confirms the hazardous nature of eucalyptus trees and encourages the City to take action to help minimize or prevent a wildfire event by managing the eucalyptus groves in and adjacent to the Coverage Area, including supporting SCE in efforts to trim or remove all trees deemed by them to be a hazard with the potential to contact or strike their power lines.

The MBHMP contains management actions intended to restore and enhance habitat in the Coverage Area, including the existing eucalyptus groves. The Draft IS-MND concludes implementation of the MBHMP would result in no impact related to wildfire, and may result in a beneficial effect by removing dead, dying, or hazardous trees and restoring understory with native, fire-resistant species. Furthermore, as discussed in Response 4.4 above, Section 20, Wildfire, has been revised to indicate that SCE tree pruning, trimming, and removal activities may continue to occur as long as such activities obtain all necessary permits and are consistent with SCE’s existing easement rights.

C-35
To: Ann Wells, Planning Manager, City of Goleta, [email protected] From: Michael Mills, Goleta resident, 7628 Carmel Beach Circle, [email protected] Re: Ellwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan The E
llwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan (or “Plan”) does not adequately address the extreme risks to property and human life that would occur due to a fire in the eucalyptus groves. The author of the Plan, Rincon Associates, is an environmental consulting firm with expertise on preserving Monarch butterfly habitat. They are not experts in fire risk assessment, or the development of fire mitigation strategies. As a result, their Plan does not adequately address these fire risks. Nor does it prioritize human life and property above butterfly habitat preservation.

The neighborhoods adjacent to the groves are at significant risk of fire. Many home fire insurance companies will not underwrite fire insurance in these areas, and, those that have previously are dropping existing policies.

The 1991 Oakland Hills firestorm was largely driven by the extreme flammability of eucalyptus trees.

As noted by Wikipedia, the firestorm:
...ultimately killed 25 people and injured 150 others. The 1,520 acres (620 ha) destroyed included 2,843 single-family dwellings and 437 apartment and condominium units. The economic loss from the fire was estimated at $1.5 billion (1991 USD).

Should a similar conflagration occur here, the City risks very significant legal liability for its failure to mitigate known fire risks posed by the eucalyptus groves.

The Plan needs significant revisions to provide fire risk reduction strategies. Those revisions should be made in consultation with fire risk experts, especially those with expertise in the specific risks posed by fires in eucalyptus groves.

Letter 5
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City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments

Final Initial Study – Mitigated Negative Declaration
Letter 5
COMMENTER: Michael Mills, Resident
DATE: February 24, 2019
Response 5.1
The commenter states the opinion the MBHMP does not adequately address the extreme risks to property and human life that would occur due to a fire in the eucalyptus groves. The commenter notes the plan was prepared by an environmental consulting firm with expertise in monarch butterfly habitat preservation, not fire risk assessment or the development of fire mitigation strategies. The commenter states the opinion neighborhoods adjacent to the groves are at significant risk of fire, and concludes the MBHMP should provide fire risk reduction strategies.

Finally, the commenter states that such strategies should be made in consultation with fire risk experts, especially those with expertise in the specific risks posed by fires in eucalyptus groves.

This comment relates to the content of the MBHMP and does not relate to the content or adequacy of the Draft IS-MND. Therefore, this comment has been included in the MBHMP Comment Matrix in Appendix B that was prepared to address comments related specifically to the MBHMP. The MBHMP Comment Matrix will be provided to City Council for its review prior to considering adoption of the MBHMP.

The Draft IS-MND does, however, include discussion of the relationship between the MBHMP and fire protection. As discussed under the Community Wildfire Protection Program subheading on page 10 of the Draft IS-MND, the MBHMP is not intended to be a wildfire protection or mitigation plan, though it does pledge support for the policies and activities contained in the CWPP, which includes policies intended to reduce fire hazards from fuel loads in the Coverage Area. Instead, the MBHMP is intended to fulfill its stated purpose of supporting habitat for monarch butterflies and other plant and animal species, coastal access, and recreation while not exacerbating wildfire risk in or around the Coverage Area. The Draft IS-MND addressed potential impacts of the MBHMP related to wildfire in Section 20, Wildfire, and found that the MBHMP would result in no impact related to wildfire and may have a beneficial effect by removing dead, dying, or otherwise hazardous trees and re-planting understory vegetation with native, fire-resistant species.

C-37
Santa Barbara Audubon Society
A Chapter of the National Audubon Society
PO Box 5508
Santa Barbara, CA 93150
www.santabarbaraaudubon.org
Date: February 25, 2019
To: City of Goleta Planning & Environmental Review and Public Works Staff Re: MBHMP Initial Study – Mitigated Negative Declaration Dear City of Goleta Planning & Environmental Review and Public Works Staff, This letter provides comments of the Santa Barbara Audubon Society (SBAS) regarding the City’s January 2019 Initial Study – Mitigated Negative Declaration (IS-MND) for the Ellwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan (MBHMP). This is a follow-up to our comments on the July 2018 Draft MBHMP provided in a letter to the City of August 31, 2018.

SBAS works to connect people with birds and nature through education, science-based projects, and advocacy.

SBAS has been a voice for the natural world in the Santa Barbara area for more than 50 years and has over 1,100 members, including hundreds in the City of Goleta.

SBAS continues to be supportive of the City’s approach toward protection and enhancement of the historical monarch butterfly aggregation sites in the Ellwood eucalyptus groves, while balancing the multiple, complex, and interactive elements of the MBHMP in a way that serves the long-term interests not only of monarchs, but of wildlife in general and the wide array of migratory, wintering, and breeding birds that find sustenance at Ellwood. As indicated in our comments of August 31
st, we believe this is best accomplished through
restoration efforts designed to create a diverse ecosystem comprised of a carefully planned mix of eucalyptus and natives that would enhance the long-term value of this habitat for both monarch aggregation sites and other wildlife. We are most appreciative of the City’s detailed and thoughtful responses to our comments that appear in Appendix B of the IS-MND.

We offer the following additional comments on the IS-MND:

1. The first full paragraph on p. 67 acknowledges nearby Devereux Slough as an important migratory bird annual stopover location, and Ellwood Mesa Open Space as a National-Audubon-designated IBA (Important Bird Area). It would be appropriate and helpful to explicitly note that these descriptions apply as well to the Devereux Creek riparian corridor within the project Coverage Area. This would provide a stronger context for the project’s Habitat Enhancement and Restoration Program, as outlined on pp. 13-14 and in section 14 of Table 2, and for demonstrating awareness of the need to ensure that the proposed program activities do not negatively impact the value of this corridor as a migratory bird stopover. As it stands, the generality of the language around planned habitat enhancement/restoration actions (“remove vegetation along Devereux Creek riparian corridor, as needed,” p. 14; “restoration activities include establishment of a riparian area along the banks of Devereux Creek composed of native riparian tree species,” p. 23) leaves unclear, for example, whether such activities could include eucalyptus removal or other elements (e.g., reduction/elimination of water catchment areas within the corridor) that could undermine the migratory stopover value of the area.

Letter 6
C-38

2. Many of the proposed mitigations (and other project activities) are qualified by language regarding their “feasibility” or “practicality.” Within just the Biological Resources section, examples include BIO-5 (“Any ground disturbing activities in riparian and wetland habitats shall be conducted when the channel is dry to the maximum extent feasible”), BIO-6 (“To the maximum extent feasible, tree trimming activities must occur in September…”), and BIO-9 (“Impacts to vernal pools, wetlands, and streambeds shall be avoided to the maximum extent practicable, unless they are affected for the purpose of habitat enhancement. If avoidance is not feasible…”). Such language opens the door to allowing exceptions to critical environmental protections, without any clear definition of “feasibility” or the process by which it would be evaluated. It is crucial that any such contemplated project modifications or exceptions be fully specified and subject to public review and comment prior to their implementation.

3. Regarding the City’s response to our August 31
st comment concerning potential downstream project
impacts (see item #259 in IS-MND Appendix B), even if the City believes that such impacts would be neutral, negligible, or only positive, we suggest that it would be appropriate to make this view explicit in the study, given that these immediately adjacent areas (North Campus Open Space, Coal Oil Point Reserve, Devereux Slough) are of high value, sensitivity, and public interest.

4. The various study references to bird nesting season dates are internally inconsistent (stated as March 15 to August 15 on pp. 12, 19, and 73; stated as February 1 to September 15 on p. 78). We have suggested March through mid-August in our Protect Our Nesting Birds brochure. For more detailed guidance on impact avoidance, see California Department of Fish and Wildlife (CDFW) website section https://www.wildlife.ca.gov/Conservation/Survey-Protocols#377281284-birds) or the attached CDFW document.

SBAS appreciates the opportunity to comment on this project. Please do not hesitate to contact us if further clarification on any of these points is desired.

Sincerely,

Cherie Topper, Santa Barbara Audubon Society Executive Director

C-39
Appendix I
CDFW’s Conservation Measures for Biological
Resources That May Be Affected by Program-level
Actions

C-40
I -1 Conservation Measures
Table I-1. California Department of Fish and Wildlife’s Conservation Measures for Biological Resources that May Be Affected by Program-level Actions
Conservation Measure Description
GC General Conservation Measures
GC-1. Conduct contractor
environmental awareness
training
a. For any project activity that involves construction or ground-disturbing activities, all construction workers will be required to participate in environmental awareness training. The training will educate workers on: (1) special-status species that may occur in the work area, (2) procedures to follow in the event a species is observed, and (3) other environmental BMPs and emergency spill response protocols.

GC-2. Work hours a. All non-emergency work activities will be confined to daylight hours (i.e., sunrise to sunset), unless necessary for assessing or protecting biological resources.

GC-3. Best Management Practices a. Prior to conducting work in streams, CDFW will identify the limits of the required access routes and encroachment into the stream. CDFW will restrict access routes and encroachment into the stream to the maximum extent while still allowing for necessary activities to be completed. CDFW will take care to prevent trampling riparian vegetation during daily visits to Project sites; as necessary, multiple routes to in-channel Project sites will be identified and used. Disturbance of riparian vegetation will be avoided to the greatest extent practicable. Access routes will not be overtly flagged, to prevent drawing attention to Project equipment and possible damage to related riparian habitat by persons not related to the Project. b. A spill prevention plan will be prepared describing measures to be taken to minimize the risk of fluids or other materials used during construction (e.g., oils, transmission and hydraulic fluids, cement, fuel) from entering streams or contaminating adjacent riparian areas. In addition to a spill prevention plan, a cleanup protocol will be developed before construction begins and will be implemented in case of a spill.
c. Stockpiling of materials, including portable equipment, vehicles and supplies (e.g., chemicals), will be restricted to the designated construction staging areas, exclusive of any riparian and wetland areas. d. A qualified biological monitor will be present during construction activities that include clearing, grubbing, pruning and /or trimming of vegetation. The qualified biological monitor will also visit each job site during construction initiation, midway through construction, and at the close of construction to monitor implementation of conservation measures and water quality.

DBC Delta button-celery
DBC-1. Avoid and minimize loss of
habitat and risk of take for
implementation of construction
activities
a. Prior to conducting ground-disturbing activities, suitable habitat within the footprint and a 250-foot buffer around of the proposed activity will be surveyed by a qualified botanist for Delta button-celery in accordance with the Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (CDFG 2009 or current version).

Floristic surveys will include the use of a reference population to increase the likelihood of detection and will be performed during the appropriate bloom period(s).
b. If Delta button-celery plants are found on or adjacent to the Project site, in consultation with the CDFW Regional botanist, a minimum 50-foot no disturbance buffer will be placed around individual plant(s) or population(s) during activities that could result in disturbance. A greater no disturbance buffer may be warranted to ensure the hydrology of the site is not disrupted and the plants and seed bank will not be impacted. The no disturbance buffer will be clearly identified in the field by staking, flagging, or fencing around depressions, swales, or other features containing Delta button-celery plants. Project activity will avoid buffer areas to ensure that the buffer area is not being encroached upon and that effects are being avoided.

PALM Palmate-bracted bird’s beak
C-41
I -2 Conservation Measures
Conservation Measure Description
PALM-1. Avoid and minimize effects to
species
a. Prior to conducting ground-disturbing activities, suitable habitat within the footprint and a 250-foot buffer around the proposed activity will be surveyed by a qualified botanist for palmate-bracted bird’s in accordance with the Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (CDFG 2009 or current version). Floristic surveys will include the use of a reference population to increase the likelihood of detection and will be performed during the appropriate bloom period(s).
b. If palmate-bracted bird’s beak plants are found on or adjacent to the Project site, in consultation with the CDFW Regional botanist, a minimum 50-foot no disturbance buffer will be placed around individual plant(s) or population(s) during activities that could result in disturbance and consistent with recommendations in the Recovery Plan for Upland Species of the San Joaquin Valley, California (USFWS 1998). A greater no disturbance buffer may be warranted to ensure the hydrology of the site is not disrupted and the plants and seed bank will not be impacted. The no disturbance buffer will be clearly identified in the field by staking, flagging, or fencing. Project activity will avoid buffer areas to ensure that the buffer area is not being encroached upon and that effects are being avoided.

PLANTS
PLANTS-1. Avoid and minimize effects
to special-status plants
a. Within one year prior to the commencement of ground -disturbing activities, habitat assessment surveys for the special -status plants listed in Table J -1 of Appendix J, will be conducted by a qualified botanist, in accordance with the Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (CDFG 2009 or current version) and at the appropriate time of year when the target species would be in flower or otherwise clearly identifiable. b. Locations of special -status plant populations will be clearly identified in the field by staking, flagging, or fencing a minimum 100 - foot wide buffer around them prior to the commencement of activities that may cause disturbance. No activity will occur within the buffer area.
c. Some special-status plant species are annual plants, meaning the plant completes its entire lifecycle in one growing season. Other special-status plant species are perennial plants that return year after year u ntil they reach full maturity. Due to the differences in life histories, all general conservation measures will be developed on a case- by-case basis and will include strategies that are species and site-specific to avoid or minimize impacts to special-status plants. d. Minimization measures may include transplanting perennial species, seed collection and dispersal for annual species, and other conservation strategies that will protect the viability of the local population. If minimization measures are implemented, monitoring of plant populations will be conducted annually for 5 years to asse ss the mitigation’s effectiveness. The performance standard for the mitigation will be no net reduction in the size or viability of the local population.

VP Vernal pool habitats, fleshy (succulent) owl’s clover, Hoover’s spurge, Bogg’s Lake hedge-hyssop, Colusa grass, San Joaquin Valley Orcutt grass, hairy Orcutt grass, Conservancy fairy shrimp, longhorn fairy shrimp, vernal pool fairy shrimp, vernal pool tadpole shrimp, and western spadefoot toad VP-1. Avoid effects to species and
habitat
a. If vernal pools have the potential to be disturbed by a project activity, a qualified biologist will identify and map vernal pools and seasonal wetland habitat potentially suitable for listed vernal pool plants, invertebrates, and western spadefoot toad within the footprint. A 250-foot no disturbance buffer will be established from the high water mark of the vernal pool or wetland habitat and will be delineated by staking, flagging or fencing. b. Access, egress, and ground-disturbing activities will be sited to avoid vernal pools.

C-42
I -3 Conservation Measures
Conservation Measure Description
VP-2. Minimize effects to species and
habitat
a. If vernal pools are present, a 250-foot no disturbance buffer will be established from the high water mark of vernal pools and seasonal wetlands that provide suitable habitat for vernal pool crustaceans or vernal pool plants. This buffer will be established prior to ground-disturbing activities, and remain until ground-disturbing activities in that area are completed. Vernal pool habitat and buffer areas will be clearly identified in the field by staking, flagging, or fencing.

VP-3. Compensate for temporary or
permanent loss of habitat
a. If activities occur within the microwatershed or 250-foot buffer for vernal pool habitat, a wetland delineation will be submitted to USACE for verification and mitigation requirements will be determined. CDFW will develop a compensatory mitigation plan consistent with USACE’s and EPA’s April 10, 2008 Final Rule for Compensatory Mitigation for Losses of Aquatic Resources (33 CFR Parts 325 and 332 and 40 CFR Part 230) and other applicable regulations and rules at the time of implementation that will result in no net loss of acreage, function, and value of affected vernal pool habitat. Unavoidable effects will be compensated through a combination of creation, preservation, and restoration of vernal pool habitat or purchase of credits at a mitigation bank approved by the applicable regulatory agency/agencies.
b. As applicable, Project effects and compensation will be determined in consideration of the Vernal Pool Recovery Plan goals for core areas, which call for 95% preservation for habitat in the Grasslands Ecological Area and Madera core areas, and 85% habitat preservation in the Fresno core area (USFWS 2005).
c. Appropriate compensatory ratios for loss of habitat both in and out of core areas would be determined during coordination and consultation with USFWS, as appropriate.
d. If off-site compensation includes dedication of conservation easements, purchase of mitigation credits, or other off-site conservation measures, the details of these measures will be developed as part of the USFWS coordination and consultation process. The plan will include information on responsible parties for long-term management, holders of conservation easements, long-term management requirements, and other details, as appropriate, for the preservation of long-term viable populations.

Any impacts that result in a compensation purchase will be required to do so with an endowment for land management in perpetuity prior to any project groundbreaking activities.

VELB Valley elderberry longhorn beetle
VELB-1. Avoid and minimize effects to
species
a. Prior to conducting all project-related activities, a qualified biologist will identify any elderberry shrubs within the footprint and a 100-foot buffer around of the proposed activity. The qualified biologist will survey potentially affected shrubs for valley elderberry longhorn beetle (VELB) exit holes in stems greater than 1- inch in diameter. b. If elderberry shrubs are found on or adjacent to the site, a 100-foot wide avoidance buffer (measured from the dripline of the plant) will be established around all elderberry shrubs with stems greater than 1-inch diameter at ground level and will be clearly identified in the field by staking, flagging, or fencing. No construction activities involving mechanized equipment will occur within the buffer areas. Human access may be permitted in the buffer, provided that it does not cause disturbance to the shrubs.

Elderberry shrubs cannot be used as an anchor for any in-channel project equipment. Project workers shall receive training prior to installing any such equipment, to allow them to identify and avoid elderberry shrubs.

C-43
I -4 Conservation Measures
Conservation Measure Description
VELB -2. Compensate for temporary or
permanent loss of habitat
a. If impacts to VELB habitat cannot be avoided, CDFW will consult with USFWS to determine appropriate compensation ratios.

Compensatory mitigation measures will be consistent with the Conservation Guidelines for Valley Elderberry Longhorn Beetle (USFWS 1999), or current guidance.
b. Compensatory mitigation for adverse effects may include the transplanting of elderberry shrubs during the dormant season (November 1 to February 15), if feasible, to an area protected in perpetuity as well as required additional elderberry and associated native plantings as approved by the USFWS.
c. If off-site compensation includes dedication of conservation easements, purchase of mitigation credits, or other off-site conservation measures, the details of these measures will be included in the mitigation plan and must occur with full endowments for management in perpetuity. The plan will include information on responsible parties for long-term management, holders of conservations easements, long-term management requirements, and other details, as appropriate, for the preservation of long- term viable populations.

BNLL Blunt-nosed leopard lizard
BNLL-1. Avoid and minimize effects to
species
a. Three locations in the Restoration Area have been identified as having potential blunt-nosed leopard lizard habitat based on aerial maps. These areas include approximately 2,460 acres along the southwest side of the San Joaquin River in Reach 2, approximately 490 acres in a portion of the Eastside Bypass and adjacent lands near Reach 4A of the San Joaquin River, and approximately 2,938 acres encompassing the northern side of the Mariposa Bypass and parcels north of the Mariposa Bypass and west of the Eastside Bypass. Prior to conducting work in these areas, CDFW will perform a focused habitat assessment for blunt-nosed leopard lizard.

Prior to any ground-disturbing activities in any area of potentially suitable habitat (e.g., grassland and shrub scrub habitat that contains required habitat elements such as small mammal burrows; open space patches between suitable habitat elements including disturbed sites and unpaved access roadways) qualified CDFW biologists will conduct protocol-level surveys in accordance with the Approved Survey Methodology for the Blunt-nosed Leopard Lizard (CDFG 2004). If blunt-nosed leopard lizard are detected, in any area where ground-disturbing activities will occur, suitable burrows within and adjacent to potential habitat for blunt-nosed leopard lizard will be avoided by a minimum 50 foot no disturbance buffer and an appropriate number of qualified CDFW biologists will be present during all ground-disturbing activities to ensure that blunt-nosed leopard lizards above ground are not impacted. Any blunt-nosed leopard lizard(s) that may enter an area of Project activity will be allowed to leave unobstructed on its own. If a blunt-nosed leopard lizard is detected in habitat adjacent to an unpaved road that will serve as ingress and egress routes for motorized transport of equipment and staff, exclusion fencing, qualified CDFW biological monitors, and reduced speed limits will be used to guide vehicles to the site and reduce the probability of vehicle strikes. All survey and monitoring results will be provided to the USFWS; negative finding results of the protocol level surveys will be good for one year.

CTS California tiger salamander
CTS-1. Avoid effects to species a. Prior to commencing any ground-disturbing activities, the work area will be assessed by CDFW or a qualified biologist for potential California tiger salamander (CTS) habitat. All potential CTS breeding ponds and upland habitat with 1.3 miles of a potential breeding pond will be considered suitable habitat. Ground-disturbing activities will avoid areas that contain suitable breeding and upland habitat for CTS, whenever possible.

C-44
I -5 Conservation Measures
Conservation Measure Description
CTS-2: Minimize effects to species a. Prior to conducting ground-disturbing activities in suitable CTS habitat, CDFW will conduct a minimum of 2 years of surveys to determine the presence/absence of CTS in accordance with the Interim Guidance on Site Assessment and Field Surveys for Determining Presence or a Negative Finding of the California Tiger Salamander (USFWS 2003). In consultation with the USFWS, CDFW may modify survey protocols to reflect site conditions and known utilization of habitat by CTS. In the absence of protocol surveys, CDFW will assume presence of CTS in all potential breeding and upland refugia habitat. b. To the extent feasible, all ground-disturbing activities will be designed to avoid impacts to suitable CTS upland habitat. Such avoidance measures may include adjusting access routes or choosing alternate locations. c. In the absence of conducting 2 years of protocol surveys or in the event protocol surveys detect CTS, CDFW will consult with the USFWS and after consultation will implement the following minimization measures during construction in suitable CTS habitat:
 Prior to commencing ground disturbing activities, construction workers will be educated regarding CTS, and the measures intended to protect this species.
 When feasible, there will be a 50 -foot no-disturbance buffer around burrows that provide suitable upland habitat for CTS. Burrows considered suitable for CTS will be determined by a qualified biologist, approved by USFWS.  All suitable burrows directly impacted by construction will be hand excavated under the supervision of a qualified wildlife biologist. If CTS are found, the biologist will relocate the organism to the nearest burrow that is outside of the construction impact area.
 All ground-disturbing work will occur during daylight hours in coordination with USFWS, and depending on the level of rainfall and site conditions. CDFW will monitor the National Weather Service (NWS) 72-hour forecast for the work area.

If a 70 % or greater chance of rainfall i s predicted within 72 hours of project activity, all activities in areas within 1.3 miles of potential or known CTS breeding sites will cease until no further rain is forecast. If work must continue when rain is forecast, a qualified biologist will survey the P roject site before construction begins each day rain is forecast. If rain exceeds 0.25 inch during a 24 -hour period, work will ce ase until no further rain is forecast. This restriction is not applicable for areas located greater than 1.3 miles from potential or known CTS breeding sites once they have been encircled with CTS exclusion fencing. However, even after exclusion fencing i s installed, this condition would still apply to construction related traffic moving though areas within 1.3 miles of potential or known CTS breeding sites but outside of the salamander exclusion fencing (e.g. on roads).  F
or work conducted during the CTS migration season (November 1 to May 31), exclusionary fencing will be erected around the construction site during ground- disturbing activities after hand excavation of burrows has been completed.

A qualified biologist will visit the site weekly to ensure that the fencing is in good working condition. Fencing material and design will be subject to the approval of the USFWS. If exclusionary fencing is not used, a qualified biological monitor will be on-site during all ground disturbance activities. Exclusion fencing will also be placed around all spoils and stockpiles.
 For work conducted during the CTS migration season (November 1 to May 31), a qualified biologist will survey the active work areas (including access roads) in mornings following measurable pre cipitation events. Construction may commence once the biologist has confirmed that no CTS are in the work area.  Prior to beginning work each day, underneath equipment and stored pipes greater than 1.2 inches (3 cm) in diameter will be inspected for CTS. If any are found they will be allowed to move out of the construction area under their own C-45
I -6 Conservation Measures
Conservation Measure Description
accord.
 Trenches and holes will be covered and inspected daily for stranded animals. Trenches and holes deeper than 1 foot will contain escape ramps (maximum slope of 2:1) to allow trapped animals to escape uncovered holes or trenches.

Holes and trenches will be inspected prior to filling.
 All food and food- related trash will be enclosed in sealed trash containers at the end of each workday and removed completely from the construction site once every three days to avoid attracting wildlife.  A speed limit of 15 mph will be maintained on dirt roads.  All equipment will be maintained such that there are no leaks of automotive fluids such as fuels, oils, and solvents. Any fuel or oil leaks will be cleaned up immediately and disposed of properly.  Plastic monofilament netting (erosion control matting) or similar material will not be used at the P roject site because CTS may become entangled or trapped. Acceptable substitutes include coconut coir matting or tackified hydroseeding compounds.
 Hazardous materials such as fuels, oils, solvents, etc. will be stored in sealable containers in a designated location that is at least 100 feet from wetlands and the San Joaquin River channel. If it is not feasible to store hazardous materials 100 feet from wetlands and the river channel, then spill containment measures will be implemented to prevent the possibility of accidental discharges to wetlands and waters.

WST Western spadefoot toad
WST-1. Avoid effects to species a. For work conducted during the western spadefoot toad migration and breeding season (November 1 to May 31), a qualified biologist will survey the active work areas (including access roads) in mornings following measurable precipitation events.

Construction may commence once the biologist has confirmed that no spadefoot toads are in the work area. b. When feasible, there will be a 50 -foot no-disturbance buffer around burrows that provide suitable upland habitat for western spadefoot toad. Burrows considered suitable for spadefoot will be identified by a qualified CDFW biologist. The biologist wil l delineate and mark the no-disturbance buffer.
c. If western spadefoot toad is found within the construction footprint, it will be allowed to move out of harm’s way of its own volition or a qualified biologist will relocate the organism to the nearest burrow that is outside of the construction impact area. d. Prior to beginning work each day, a qualified biologist will inspect underneath equipment and stored pipes greater than 1.2 inches (3 cm) in diameter for western spadefoot toad. If any are found they will be allowed to move out of the construction a rea under their own accord.
e. Trenches and holes will be covered and inspected daily for stranded animals. Trenches and holes deeper than one foot deep will contain escape ramps (maximum slope of 2:1) to allow trapped animals to escape uncovered holes or trenches. Holes and trenches will be inspected prior to filling.

GGS Giant garter snake
GGS-1. Avoid effects to species a. Prior to commencing any ground-disturbing activities, a qualified biologist will assess the footprint and a 100-foot buffer around of the proposed activity for potential giant garter snake (GGS) habitat. Potential GGS habitat in the Project Area includes burrows and crevices in which GGS could be present.

C-46
I -7 Conservation Measures
Conservation Measure Description
b. If the suitable habitat is present, then CDFW will avoid ground-disturbing activities, whenever possible. Avoidance of suitable GGS habitat, as determined by USFWS and CDFW, will occur by demarcating and maintaining a 300-foot-wide no disturbance buffer around these areas.

GGS-2. Minimize effects to species a. If impacts to GGS habitat cannot be avoided, pre-construction surveys will be completed by a qualified biologist within a 24-hour period before any ground disturbance of potential giant garter snake habitat. If construction activities stop on the Project site for a period of 2 weeks or more, a GGS survey will be repeated no more than 24 hours before the restart of construction activities b. For Project activities within potential GGS habitat, all activity involving disturbance of potential GGS habitat will be restricted to the period between May 1 and October 1, the active season for the species. The construction site will be re-inspected when a lapse in construction activity of two weeks or greater has occurred. c. Clearing will be confined to the minimal area necessary to facilitate construction activities. GGS habitat within or adjacent to the Project site will be flagged, staked, or fenced and designated as an Environmentally Sensitive Area. No activity will occur within this area and USFWS-approved biological monitoring will be conducted to ensure that avoidance measures are being implemented. Construction activities will be minimized within 200 feet of the banks of GGS habitat. Movement of heavy equipment will be confined to existing roadways to minimize habitat disturbance. d. Vegetation will be hand cleared in areas where GGS are suspected to occur. e. If a GGS is found during construction activities, the USFWS will be immediately notified. The biological monitor, or his/her assignee, will stop construction in the vicinity of the find and allow the snake to leave on its own. The monitor will remain in the area for the remainder of the work day to ensure the snake is not harmed. Escape routes for GGS should be determined in advance of construction and snakes will be allowed to leave on their own. If a GGS does not leave on its own within one working day, USFWS will be consulted.
f. All construction-related holes will be covered to prevent entrapment of individuals. Where applicable, construction areas will be dewatered two weeks prior to the start of activities to allow giant garter snakes and their prey to move out of the area prior to any disturbance.
g. For installation of research and monitoring equipment, t-posts used for anchoring will be placed within the channel when feasible, to minimize impacts to GGS in burrows along the river banks. Prior to t-post installation in the river bank, workers shall inspect the area for burrows and crevices in which GGS could be present. Fyke nets shall be inspected daily to ensure no GGS individuals are caught in the net mesh. If GGS is detected at any time during project activities, workers shall cease working and the individual shall be allowed to leave the site of its own volition before Project activity continues .

C-47
I -8 Conservation Measures
Conservation Measure Description
GGS-3. Compensate for temporary or
permanent loss of habitat.
a. Temporarily affected GGS aquatic habitat will be restored in accordance with criteria listed in the USFWS Mitigation Criteria for Restoration and/or Replacement of Giant Garter Snake Habitat (Appendix A to Programmatic Formal Consultation for U.S. Army Corps of Engineers 404 Permitted Projects with Relatively Small Effects on the Giant Garter Snake within Butte, Colusa, Glenn, Fresno, Merced, Sacramento, San Joaquin, Solano, Stanislaus, Sutter, and Yolo Counties, California (USFWS 1997)) or the most current criteria from USFWS or CDFW.
b. Permanent loss of GGS habitat will be compensated at a ratio and at a manner agreed upon in consultation with the USFWS.

Compensation may include preservation and enhancement of existing populations, restoration or creation of suitable habitat, or purchase of credits at a regulatory agency approved mitigation bank in a sufficient quantity to compensate for the effect. Credit purchases, land preservation or enhancement to minimize effects to giant garter snakes should occur geographically close to the impact area. If off-site compensation is chosen, it will include dedication of conservation easements, purchase of mitigation credits, or other off-site conservation measures, and the details of these measures will be included in the mitigation plan and must occur with full endowments for management in perpetuity. The plan will include information on responsible parties for long- term management, holders of conservations easements, long-term management requirements, and other details, as appropriate, for the preservation of long-term viable populations.

FYLF Foothill yellow-legged frog
FYLF-1. Avoid and minimize loss of
individuals
a. If foothill yellow-legged frog (FYLF) has the potential to be present within a work area, a qualified biologist will make an initial site visit to determine if suitable habitat for the species exists within the vicinity of the work area. b. If work activities occur between April 1 and August 31, CDFW will conduct surveys for FYLF eggs and tadpoles. If FYLF eggs or tadpoles are identified in the work area or within 250 feet downstream of the work area, CDFW will modify the activity to ensure it does not directly or indirectly disturb eggs or tadpoles. c. For research, monitoring and broodstock collection activities, instream sampling equipment (e.g., fyke nets, screw traps) will be inspected daily to ensure no FYLF individuals are caught in the equipment. If FYLF are found in sampling equipment, a biologist will relocate frogs to suitable habitat downstream of the work area.

WPT Western pond turtle
WPT-1. Avoid and minimize loss of
individuals
a. Pre-construction surveys for western pond turtle (WPT) shall be conducted by a qualified biologist 14 days before and 24 hours before the start of ground-disturbing activities where suitable habitat exists (e.g., along riparian areas and freshwater emergent wetlands).
b. If WPT or their nests are observed during pre-construction surveys, a qualified biologist shall be on-site to monitor construction in suitable WPT habitat. WPT found within the construction area will be allowed to leave of its own volition or it will be captured by a qualified biologist and relocated out of harm’s way to the nearest suitable habitat immediately upstream or downstream from the Project site.
c. If WPT nests are identified in the work area during pre-construction surveys, a 300-foot no disturbance buffer shall be established between the nest and any areas of potential disturbance. Buffers shall be clearly marked with temporary fencing. Construction will not be allowed to commence in the exclusion area until hatchlings have emerged from the nest, or the nest is deemed inactive by a qualified biologist.
d. Fo
r research, monitoring and broodstock collection activities, instream sampling equipment (e.g., fyke nets, screw traps) will be inspected daily to ensure no WPT individuals are caught in the equipment. If WPT are found in sampling equipment, a biologist C-48
I -9 Conservation Measures
Conservation Measure Description
will relocate WPT to suitable habitat downstream of the work area.

EAGLE Bald eagle and golden eagle
EAGLE-1. Avoid and minimize effects
to bald and golden eagles (as
defined in the Bald and Golden
Eagle Protection Act)
a. Surveys for bald and golden eagle nests will be conducted within 2 miles of any construction areas supporting suitable nesting habitat and important eagle roost sites and foraging areas. Surveys will be conducted in accordance with the USFWS Interim Golden Eagle Inventory and Monitoring Protocols (USFWS 2010a), and CDFW’s Bald Eagle Breeding Survey Instructions (CDFG 2010), or current guidance.
b. If an active eagle’s nest is found, project disturbance will not occur within 0.5 mile of the active nest site during the breeding season (December 30 through July 1) or any disturbance if that action is shown to disturb the nesting birds. The 0.5 mile no disturbance buffer will be maintained throughout the breeding season or until the young have fledged and are no longer dependent upon the nest or parental care for survival.

SWH Swainson’s hawk and White Tailed Kite
SWH-1. Avoid and minimize impacts to
Swainson’s Hawk
a. If construction activities occur between February 1 and August 31, CDFW will conduct surveys for Swainson’s hawk and white tailed kite in accordance with the Swainson’s Hawk Technical Advisory Committee 2000 guidelines (SHTAC 2000), or current guidance. Surveys will cover a minimum of a 0.5-mile radius around the construction area. If nesting Swainson’s hawks or white tailed kites are detected, CDFW will establish a 0.5 mile no disturbance buffer. Buffers will be maintained until a qualified CDFW biologist has determined that the young have fledged and are no longer reliant upon the nest or parental care for survival.

SWH-2. Compensate for loss of nest
trees
a. If potential nesting trees are to be removed during construction activities, removal will take place outside of Swainson’s hawk and white tailed kite nesting season and CDFW will develop a plan to replace known nest trees at a ratio of 3:1. If replacement planting is implemented, monitoring will be conducted annually for 5 years to assess the mitigation’s effectiveness. The performance standard for the mitigation will be 65% survival of all replacement plantings.

RAPTOR Other nesting raptors
RAPTOR-1. Avoid and minimize loss of
individual raptors
a. Construction activity, including vegetation removal, will only occur outside the typical breeding season for raptors (September 16 to December 31), if raptors are determined to be present. b. If construction occurs between February 1 and August 31, CDFW will conduct surveys for nesting raptors in accordance with established CDFW raptor survey protocols. Surveys will cover a minimum of a 0.5-mile radius around the construction area. If nesting raptors are detected, CDFW will establish buffers around nests that are sufficient to ensure that breeding is not likely to be disrupted or adversely impacted by construction. Buffers around active raptor nests will be 500 feet for non-listed raptors, unless a qualified biologist determines that smaller buffers would be sufficient to avoid impacts to nesting raptors. Factors to be considered for determining buffer size will include: the presence of natural buffers provided by vegetation or topography; nest height; locations of foraging territory; and baseline levels of noise and human activity. Buffers will be maintained until a qualified CDFW biologist has determined that young have fledged and are no longer reliant upon the nest or parental care for survival.

RAPTOR-2. Compensate for loss of
nest trees
a. If potential nesting trees are to be removed during construction activities, removal will take place outside of the raptor nesting season and CDFW will develop a plan to replace known nest trees at a ratio of 3:1. If replacement planting is implemented, monitoring will be conducted annually for 5 years to assess the mitigation’s effectiveness. The performance standard for the mitigation will be 65% survival of all replacement plantings.

BRO Burrowing owl
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I -10 Conservation Measures
Conservation Measure Description
BRO-1. Avoid and minimize impacts to
species
a. Pre-construction surveys for burrowing owls will be conducted in areas supporting potentially suitable habitat and within 30 days prior to the start of construction activities. If ground-disturbing activities are delayed or suspended for more than 30 days after the pre-construction survey, the site will be resurveyed. CDFW will conduct surveys for burrowing owls in accordance with protocols established in the Staff Report on Burrowing Owl Mitigation (CDFG 2012 or current version). b. If burrowing owls are detected, disturbance to burrows will be avoided during the nesting season (February 1 through August 31).

CDFW will establish buffers around occupied burrows in accordance with guidance provided in the Staff Report on Burrowing Owl Mitigation. Buffers around occupied burrows will be a minimum of 656 feet (200 meters) during the nesting season, and 160 feet (100 meters) during the non-breeding season.
c. Outside of the nesting season (February 1 through August 31), passive owl relocation techniques will be implemented. Owls would be excluded from burrows in the immediate impact zone within a 160-foot buffer zone by installing one-way doors in burrow entrances. These doors will be in place at least 48 hours prior to excavation to insure the owls have departed. d. The work area will be monitored daily for 1 week to confirm owl departure from burrows prior to any ground-disturbing activities. e. Where possible, burrows will be excavated using hand tools and refilled to prevent reoccupation. Sections of flexible plastic pipe will be inserted into the tunnels during excavation to maintain an escape route for any animals inside the burrow.

BRO-2. Compensate for impacts to
species
a. If occupied burrows cannot be avoided during the non-breeding season, CDFW will enhance or create burrows in adjacent habitat at a 1:1 ratio of burrow destroyed to created at least one week prior to implementation of passive relocation techniques. If burrowing owl habitat enhancement or creation takes place, CDFW will develop and implement a monitoring and management plan to assess the effectiveness of the mitigation. If monitoring indicates that the actions have not adequately mitigated for the Project’s impacts, CDFW will implement remedial actions (e.g., enhancing or creating additional burrows) that compensate for these impacts.

RNB Riparian nesting birds: Western yellow-billed cuckoo, least Bell’s vireo, and willow flycatcher RNB-1. Avoid effects to species a. If western yellow-billed cuckoo, least Bell’s vireo, or willow flycatcher has the potential to be present within a work area, a qualified biologist will make an initial site visit to determine if suitable habitat for the species exists within the vicinity of the project footprint.
b. Where suitable habitat is present, surveys will be conducted by biologists adhering to guidance offered in Western Yellow-billed Cuckoo Natural History Summary and Survey Methodology (Halterman et al. 2009); Least Bell’s Vireo Survey Guidelines (USFWS 2001); and/or A Survey Protocol for Willow Flycatcher in California (Bombay et al. 2003). c. If nests are detected, CDFW will establish buffers around nests that are sufficient to ensure that breeding is not likely to be disrupted or adversely impacted by construction. No-disturbance buffers around active nests will be a minimum of 500 feet, unless a qualified CDFW biologist determines that smaller buffers would be sufficient to avoid impacts to nesting birds. Factors to be considered for determining buffer size will include: the presence of natural buffers provided by vegetation or topography; nest height; locations of foraging territory; and baseline levels of noise and human activity. Buffers will be maintained until a qualified CDFW biologist has determined that young have fledged and are no longer reliant upon the nest or parental care for survival.

RNB-2. Minimize effects to species a. If western yellow-billed cuckoo, least Bell’s vireo, or willow flycatcher are detected or suspected to be present in the vicinity of the work area based on information collected in RNB-1, then no activities that involve clearing of vegetation, generation of mechanical noise, or ground disturbance will take place during the nesting season of the species that may be present.

MBTA Other birds protected by the Migratory Bird Treaty Act C-50
I -11 Conservation Measures
Conservation Measure Description
MBTA-1. Avoid and minimize effects to
species
a. Whenever possible, impacts to native nesting birds will be avoided by not conducting Project activities that involve clearing of vegetation, generation of mechanical noise, or ground disturbance during the typical breeding season (February 1 to September 1), if species covered under the Migratory Bird Treaty Act and Fish and Game Code sections 3503, 3503.5, and 3513 are determined to be present.
b. If Project activities must be conducted during the nesting bird season, CDFW will conduct surveys for nesting birds within a 1,000-ft radius of the construction area. If nests are detected, CDFW will establish buffers around nests that are sufficient to ensure that breeding is not likely to be disrupted or adversely impacted by construction. Buffers around active nests will be a minimum of 250 feet, unless a qualified CDFW biologist determines that smaller buffers would be sufficient to avoid impacts to nesting birds.

Factors to be considered for determining buffer size will include: the presence of natural buffers provided by vegetation or topography; nest height; locations of foraging territory; and baseline levels of noise and human activity. Buffers will be maintained until young have fledged or the nests become inactive.

BAT Special-status bats
BAT-1: Avoid and minimize loss of
species
a. If suitable roosting habitat for special-status bats will be affected by Project construction (e.g., removal or buildings, modification of bridges), a qualified wildlife biologist will conduct surveys for special-status bats during the appropriate time of day to maximize detectability to determine if bat species are roosting near the work area no less than 7 days and no more than 14 days prior to beginning ground disturbance and/or construction. Survey methodology may include visual surveys of bats (e.g., observation of bats during foraging period), inspection for suitable habitat, bat sign (e.g., guano), or use of ultrasonic detectors (e.g., Anabat, etc.).

Visual surveys will include trees within 0.25 mile of Project construction activities. The type of survey will depend on the condition of the potential roosting habitat. If no bat roosts are found, then no further study is required. b. If evidence of bat use is observed, the number and species of bats using the roost will be determined. Bat detectors may be used to supplement survey efforts.
c. If roosts are determined to be present and must be removed, the bats will be excluded from the roosting site before the facility is removed. A mitigation program addressing compensation, exclusion methods, and roost removal procedures will be developed prior to implementation. Exclusion methods may include use of one-way doors at roost entrances (bats may leave, but not re- enter), or sealing roost entrances when the site can be confirmed to contain no bats. Exclusion efforts may be restricted during periods of sensitive activity (e.g., during hibernation or while females in maternity colonies are nursing young).

BAT-2: Compensate for loss of habitat a. If roosts cannot be avoided or it is determined that construction activities may cause roost abandonment, such activities may not commence until permanent, elevated bat houses have been installed outside of, but near the construction area. Placement and height will be determined by a qualified wildlife biologist, but the height of bat house will be at least 15 feet. Bat houses will be multi-chambered and be purchased or constructed in accordance with CDFW standards. The number of bat houses required will be dependent upon the size and number of colonies found, but at least one bat house will be installed for each pair of bats (if occurring individually), or of sufficient number to accommodate each colony of bats to be relocated.

BAD American Badger
BAD-1: Avoid and minimize loss of
species
a. No less than 14 days and no more than 30 days prior to the beginning of ground disturbance and/or construction activities, CDFW will conduct a survey to determine if American badger den sites are present at the site. If dens are found, they will be monitored for badger activity. If CDFW determines that dens may be active, the entrances of the dens will be blocked with soil, sticks, and debris for three to five days to discourage the use of these dens prior to project disturbance activities. The den entrances will be blocked to an incrementally greater degree over the 3 to 5-day period. After the qualified CDFW biologist determines that badgers C-51
I -12 Conservation Measures
Conservation Measure Description
have stopped using active dens, the dens will be hand-excavated with a shovel to prevent re-use during construction. No disturbance of active dens will take place when cubs may be present and dependent on parental care, as determined by a qualified CDFW biologist.

SJAS San Joaquin antelope squirrel
SJAS-1: Avoid and minimize loss of
individuals
a. If San Joaquin antelope squirrels have the potential to be present within a work area, a qualified biologist will make an initial site visit to determine if suitable habitat for the species may exist within and adjacent to the vicinity of the project footprint. If suitable habitat is present, daytime visual surveys will be conducted using line transects with 10 to 30 meter spacing when temperatures are between 68°- 86° F (20°- 30° C). Focused live trapping may also be required when visual surveys are inconclusive. b. Where suitable habitat is present and neither surveys nor trapping has not been conducted, a 50-foot minimum no disturbance buffer will be maintained from all small mammal burrows of suitable size for San Joaquin antelope squirrel.

FKR Fresno kangaroo rat
FKR-1: Avoid and minimize effects to
species
a. Focused surveys will be conducted by a qualified biologist within 60 days prior to ground-disturbing activities. The biologist will conduct burrow searches by systematically walking transects, which will be adjusted based on vegetation height and topography.

Transects will be used to identify the presence of kangaroo rat burrows. When burrows suitable for use by Fresno kangaroo rat are found within 100 feet of the Proposed Project footprint, focused live trapping surveys will be conducted by a qualified and permitted biologist following a methodology approved in advance by USFWS. b. In all areas of potentially suitable Fresno kangaroo rat habitat, a 50 -foot no disturbance buffer will be implemented around small mammal burrows when live trapping is not conducted or when, in consultation with the USFWS, live trapping results are inconclusive in determining presence/absence for the species.

SJKF San Joaquin kit fox
SJKF-1: Avoid and minimize effects to
species
a. A qualified biologist will conduct pre-construction surveys no less than 14 days and no more than 30 days before the commencement of activities to identify potential dens more than 5 inches in diameter. CDFW will implement USFWS’ Standardized Recommendations for Protection of San Joaquin Kit Fox Prior to or During Ground Disturbance (USFWS 2011 or current version).

CDFW will notify USFWS in writing of the results of the pre-construction survey within 30 days after these activities are completed. b. If potential dens are located within the Proposed Project’s work area and cannot be avoided during construction activities, a USFWS-approved biologist will determine if the dens are occupied. c. If occupied dens are present within the work area, their disturbance and destruction will be avoided. Exclusion zones will be implemented following the most current USFWS procedures (currently USFWS 2011). d. CDFW will notify USFWS immediately if a natal or pupping den is found in the survey area, and will present the results of pre- activity den searches within 5 days after these activities are completed and before the start of construction activities in the area. e. Construction activities will be conducted at a time that is least likely to affect the species (i.e., after the normal breeding season of December through September) (Ahlborn 1999). This timing will be coordinated with USFWS.

SJKF-2: Compensate for loss of habitat a. CDFW, in coordination with USFWS, will determine if kit fox den removal is appropriate. If unoccupied dens need to be removed, the USFWS-approved biologist will remove these dens by hand-excavating them in accordance with USFWS procedures (USFWS 2011).
b. Additional conservation measures will be coordinated with USFWS and DFW, and may include replacing dens, installing off-si te
C-52
I -13 Conservation Measures
Conservation Measure Description
artificial dens, acquisition of compensatory habitat, or other options to be determined. Compensation may include dedicating conservation easements, purchasing mitigation credits, or other off-site conservation measures, and the details of these measures will be included in the mitigation plan and must occur with full endowments for management in perpetuity. The plan will include information on responsible parties for long-term management, holders of conservations easements, long-term management requirements, and other details, as appropriate, for the preservation of long-term viable populations.

DS Delta smelt
DS-1: Avoid and minimize effects to
species
a. A ll work within water s where there is potential for Delta smelt to occur, as defined by the most recent USFWS guidance, will be confined to a seasonal work window of August 1 through November 30 when Delta smelt are least likely to be present. Because this species does not regulate its movements strictly within this time frame, modifications to the work windows may be approved by the USFWS prior to project implementation based on information from the various in-Delta monitoring programs. b. If activities occur within Delta smelt habitat, measures will be taken to maintain or increase shading of suitable willow water habitat. The project will also avoid areas deemed suitable for Delta smelt habitat that have established aquatic vegetation or have not been previously disturbed.

GS Green sturgeon (Southern Distinct Population Segment) GS-1. Avoid and minimize loss of
habitat and individuals
a. W eir and fish sampling equipment placed in the San Joaquin River will be operated in a manner that will allow for passage of green sturgeon, where applicable. To reduce stress on captured fish, all trapping devices will be checked at least once per day.

Untargeted species caught in traps will be released into suitable habitat for the species. Traps will be checked more frequently during times when conditions are stressful (e.g., high temperatures, large amounts of debris during high flow events) to reduce the time that fish are subject to trap-related stress.

CVS Central Valley steelhead
CVS-1. Minimize loss of habitat and risk
of take of species
a. In -channel construction activities that could affect designated critical habitat for Central Valley steelhead will be limited to the low- flow period between June 1 and October 1 to minimize potential for adversely affecting federally listed anadromous salmonids during their emigration period.
b. If individual Central Valley steelhead are observed within a work area, NMFS will be notified. NMFS personnel will have access to construction sites during construction, and following completion, to evaluate species presence and condition and/or habitat conditions.

PL Pacific lamprey
PL-1: Avoid and minimize effects to
species
a. A qualified biologist will conduct pre-construction surveys as outlined in Attachment A of Best Management Practices to Minimize Adverse Effects to Pacific Lamprey (Entosphenus tridentatus)(USFWS 2010b). b. Work in documented areas of Pacific Lamprey presence will be timed to avoid in-channel work during typical lamprey spawning (March 1 to July 1).

RHSNC Riparian habitat and other sensitive natural communities RHSNC-1. Avoid and minimize loss of
riparian habitat and other
sensitive natural communities
a. If effects occur to riparian habitat, emergent wetland, or other sensitive natural communities associated with streams, CDFW will comply with Section 1602 of the California Fish and Game Code; compliance may include measures to protect fish and wildlife resources during the project.

C-53
I -14 Conservation Measures
Conservation Measure Description
RHSNC-2: Compensate for loss of
riparian habitat and other
sensitive natural communities
a. If losses of other sensitive natural communities (e.g., recognized as sensitive by CNDDB, but not protected under other regulations or policies) would not be offset by the benefits of the Proposed Project, then additional compensation will be provided through creating, restoring, or preserving in perpetuity in-kind communities at a sufficient ratio for no net loss of habitat function or acreage. If habitat enhancement or creation takes place, CDFW will develop and implement a monitoring and management plan to assess the effectiveness of the mitigation. If monitoring indicates that the actions have not adequately mitigated for the Project’s impacts, CDFW will implement remedial actions that compensate for these impacts.

WUS Waters of the United States/waters of the State
WUS-1. Identify and quantify wetlands
and other waters of the United
States
a. Before implementing Proposed Project actions that may affect waters of the United States or waters of the State, CDFW will map the distribution of wetlands (including vernal pools and other seasonal wetlands) in the vicinity of the work area. b. CDFW will determine, based on the mapped distribution of these wetlands and waters, the acreage of effects, if any, on waters of the United States. If it is determined that wetlands will be affected by the Proposed Project, CDFW will conduct a delineation of waters of the United States, and submit the delineation to USACE for verification. The delineation will be conducted according to methods established in the USACE Wetlands Delineation Manual (Environmental Laboratory 1987) and Arid West Supplement (Environmental Laboratory 2008).
c. Construction will be designed to minimize effects on waters of the United States and waters of the State and will employ best management practices to avoid indirect effects on water quality.

WUS-2. Obtain permits and
compensate for any loss of wetlands
and other waters of the United
States/waters of the State
a. CDFW, in coordination with USACE, will determine the acreage of effects on waters of the U. S. and waters of the State that will result from implementation of the Proposed Project.
b. CDFW will obtain Section 404 and Section 401 permits and comply with all permit terms. The acreage, location, and methods for compensation will be determined during the Section 401 and Section 404 permitting processes. c. CDFW will adhere to a “no net loss” basis of the acreage of wetlands and other waters of the U. S. and waters of the State that will be removed and/or degraded. Wetland habitat will be restored, enhanced, and/or replaced at an acreage and location and by methods agreeable to USACE, the Central Valley RWQCB, as appropriate, depending on agency jurisdiction. The replacement of waters or wetlands will be equivalent to the nature of the habitat lost, and will be provided at a suitable ratio to ensure that, at a minimum, there is no net loss of habitat acreage or value. The replacement habitat will be set aside in perpetuity for habitat use.

CH Critical habitat
CH-1. Avoid and minimize effects to
critical habitat
a. Designated critical habitat within the vicinity of project activities will be identified. All Proposed Project actions will be designed to avoid direct and indirect adverse modifications to these areas. Minimization measures, such as establishing and maintaining buffers around areas of designated critical habitat will be implemented in the event that avoidance is not feasible.

CH-2. Compensate for unavoidable
adverse effects on Federally designated
critical habitat
a. If critical habitat may be adversely modified by the implementation of Proposed Project actions, the area to be modified will be evaluated by a qualified biologist to determine the potential magnitude of the project effects (e.g., description of primary constituent elements present and quantification of those affected) at a level of detail necessary to satisfy applicable environmental compliance and permitting requirements
b. CDFW will implement compensatory conservation measures developed through consultation with USFWS or NMFS. If off-site compensation includes dedication of conservation easements, purchase of mitigation credits, or other off-site conservation measures. The plan will include information on responsible parties for long-term management, holders of conservation easements, long-term management requirements, and other details, as appropriate, for the preservation of long-term viable C-54
I -15 Conservation Measures
Conservation Measure Description
populations. Any impacts that result in a compensation purchase will be required to do so with an endowment for land management in perpetuity prior to any project groundbreaking activities.

EFH Essential Fish Habitat (Pacific salmonids)
EFH-1. Minimize loss of habitat and risk
of take
a. In -channel construction activities which could affect habitat for Pacific salmonids will be limited to the low-flow period between June 1 and October 1 to minimize potential for adversely affecting federally listed anadromous salmonids during their emigration period.
b. In-channel construction activities which could affect habitat for Pacific salmonids will be limited to daylight hours during weekdays, leaving a nighttime and weekend period of passage for federally listed fish species. c. Construction BMPs for off-channel staging and storage of equipment and vehicles will be implemented to minimize the risk of contamination of the waters of the San Joaquin River by spilled materials. BMPs will also include minimization of erosion and stormwater runoff, as appropriate.
d. Riparian vegetation removed or damaged will be replaced at a ratio, coordinated with the NMFS, within the immediate area of the disturbance to maintain habitat quality.
e. If individuals of listed species are observed present within a work area, then NMFS must be notified. NMFS personnel will have access to construction sites during construction and following completion in order to evaluate species presence and condition and/or habitat conditions.
f. If bank stabilization activities should be necessary, then such stabilization will be constructed to minimize predator habitat, minimize erosion potential, and contain material suitable for supporting riparian vegetation.

References:

Ahlborn, G. 1999. Life History Description for Giant Kangaroo Rat. California Wildlife Habitat Relationship System. Available:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentVersionID=17723 . Accessed: August 9, 2013.

Bombay, H.L., T. M. Benson, B. E. Valentine, and R. A. Stefani. 2003. A Survey Protocol for Willow Flycatcher in California. Available:
http://dfg.ca.gov/wildlife/nongame/docs/wifl_2003_protocol.pdf. Accessed: April 22, 2013.

CNPS. See California Native Plant Society.

California Department of Fish and Game (CDFG). 2004. Approved Survey Methodology for the Blunt-Nosed Leopard Lizard. May. Available:
http://www.dfg.ca.gov/wildlife/nongame/docs/BNLLrevisedprotocol.pdf. A ccessed: June 13, 2013.

California Department of Fish and Game (CDFG). 2012. Staff Report on Mitigation for Disturbance of Burrowing Owl.

California Native Plant Society (CNPS). 1998. Mitigation guidelines regarding impacts to rare, threatened, and endangered plants. California Native Plant Society Scientific Advisory Committee. Prepared February 1991, revised April 1998. Available: http://www.cnps.org/cnps/archive/mitigation.pdf. Accessed: August 24, 2008.

Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual. Available: http://el.erdc.usace.army.mil/elpubs/pdf/wlman87.pdf. Accessed: August 9, 2013.

Environmental Laboratory. 2008. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (Version 2.0). Available:
http://www.usace.army.mil/Portals/2/docs/civilworks/regulatory/reg_supp/trel08-28.pdf. Accessed: August 9, 2009.

Halterman M., M.J. Johnson, J.A Holmes. 2009. Western Yellow-billed Cuckoo Natural History Summary and Survey Methodology. Available:
http://www.southernsierraresearch.org/Workshop/YellowBilledCuckooWorkshop/Materials/cuckoo_methodology_May2010.pdf. Accessed: April 22, 2013.

Swainson’s Hawk Technical Advisory Committee (SHTAC). 2000. Recommended Timing And Methodology For Swainson's Hawk Nesting Surveys In California's Central Valley.

May. Available: http://www.dfg.ca.gov/wildlife/nongame/docs/swain_proto.pdf. Accessed: June 13, 2013.

U.S. Fish and Wildlife Service (USFWS). 1997. Programmatic Formal Consultation for U.S. Army Corps of Engineers 404 Permitted Projects with Relatively Small Effects on the Giant Garter Snake within Butte, Colusa, Glenn, Fresno, Merced, Sacramento, San Joaquin, Solano, Stanislaus, Sutter, and Yolo Counties, California.

C-55
I -16 Conservation Measures
Conservation Measure Description
U.S. Fish and Wildlife Service (USFWS). 1998. Recovery Plan for Upland Species of the San Joaquin Valley, California. Available:
http://ecos.fws.gov/docs/recovery_plan/980930a.pdf. Accessed: August 9, 2013.

U.S. Fish and Wildlife Service (USFWS). 1999. Conservation Guidelines for the Valley Elderberry Longhorn Beetle. Sacramento Fish and Wildlife Office, Sacramento, California.

Available: http://www.fws.gov/sfbaydelta/documents/velb_conservation.pdf. Accessed: August 9, 2013.

U.S. Fish and Wildlife Service (USFWS). 2001. Least Bell’s Vireo Survey Guidelines. January. Available:
http://www.fws.gov/ventura/species_information/protocols_guidelines/docs/lbv/leastbellsvireo_survey-guidelines.pdf. Accessed: August 9, 2013.

U.S. Fish and Wildlife Service (USFWS). 2003. Interim Guidance on Site Assessment and Field Surveys for Determining Presence or a Negative Finding of the California Tiger Salamander. Ventura Fish and Wildlife Office. Available: http://www.fws.gov/ventura/species_information/protocols_guidelines/docs/cts/catigersalamander_survey- protocols.pdf. Accessed: June 4, 2013.

U.S. Fish and Wildlife Service (USFWS). 2005. Recovery Plan for Vernal Pool Ecosystems of California and Southern Oregon. Region 1. Portland, Oregon. Available:
http://www.fws.gov/sacramento/es/Recovery-P lanning/Vernal-Pool/es_recovery_vernal-pool-recovery.htm. Accessed: June 13, 2013.

U.S. Fish and Wildlife Service (USFWS). 2010a. Interim Golden Eagle Inventory and Monitoring Protocols. January. Available:
http://www.fws.gov/southwest/es/oklahoma/documents/te_species/wind%20power/usfws_interim_goea_monitoring_protocol_10march2010.pdf Accessed: July 24, 2013
U.S. Fish and Wildlife Service (USFWS). 2010b. Best Management Practices to Minimize Adverse Effects to Pacific Lamprey (Entosphenus tridentatus). April. Available:
http://www.fws.gov/pacific/fisheries/sphabcon/lamprey/pdf/Best%20Management%20Practices%20for%20Pacific%20Lamprey%20April%202010%20Version.pdf. Accessed:

July 29, 2013.

U.S. Fish and Wildlife Service (USFWS). 2011. Standardized Recommendations for Protection of San Joaquin Kit Fox Prior to or During Ground Disturbance. Available:
http://www.fws.gov/sacramento/es/survey-protocols-guidelines/Documents/kitfox_standard_rec_2011.pdf.Accessed: August 9, 2013.

K
ey:
° C = degrees Celsius
° F = degrees Fahrenheit
BMP = best management practice
BO = Biological Opinion
CFR = Code of Federal Regulations
cfs = cubic feet per second
CNDDB = California Natural Diversity Database
CVP = Central Valley Project
DFW = California Department of Fish and Wildlife
DWR = California Department of Water Resources
EPA = Federal Environmental Protection Agency
NMFS = National Marine Fisheries Service
Reclamation = U.S. Department of the Interior, Bureau of Reclamation RWQCB = Regional Water Quality Control Board
Settlement = Stipulation of Settlement in NRDC, et al,. v. Kirk Rodgers, et al.

State = State of California
SWP = State Water Project
USACE = U.S. Army Corps of Engineers
USFWS = U.S. Fish and Wildlife Service
C-56
City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments Final Initial Study – Mitigated Negative Declaration
Letter 6
COMMENTER: Cherie Topper, Executive Director, Santa Barbara Audubon Society DATE: February 25, 2019
Response 6.1
The commenter notes Page 67 of the Draft IS-MND acknowledges nearby Devereux Slough as an important migratory bird annual stopover location and Ellwood Mesa Open Space as a National- Audubon-designated Important Bird Area (IBA). The commenter recommends that the Draft IS-MND explicitly note these descriptions apply as well to the Devereux Creek riparian corridor within the Coverage Area, in order to provide a stronger context for the project’s Habitat Enhancement and Restoration Program and demonstrate awareness of the need to ensure the proposed program activities do not negatively impact the value of this corridor as a migratory bird stopover. The commenter adds that, as written, the generality of covered activities (e.g., removing vegetation along the Devereux Creek riparian corridor as needed, or establishing riparian area along the banks of Devereux Creek composed of native riparian tree species) leaves uncertainty as to whether such activities could undermine the value of the Coverage Area as a migratory bird stopover.

The commenter is correct that the Devereux Creek riparian corridor within the Coverage Area is part of the Goleta Coast IBA. Page 67 of the Draft IS-MND has been revised as follows:

Ellwood Mesa Open Space, including the Devereux Creek riparian corridor within the Coverage Area, is also part of the Goleta Coast Important Bird Area, designated by the National Audubon Society. It is considered to be globally important due to its location on the Pacific Flyway.

The MBHMP is a long-term management plan intended to guide habitat restoration and enhancement efforts through management goals, policies, and supporting actions. The covered activities are general in nature to reflect the need for adaptive management in the face of changing conditions in the Coverage Area. However, the Draft IS-MND identifies mitigation measures to protect riparian, wetland, and other natural habitat areas in the Coverage Area under the range of covered activities that could occur under the MBHMP. Mitigation Measure BIO-8 would prohibit all staging and temporary stockpiling from occurring in riparian habitats, wetlands, vernal pools, native grasslands, and active nest buffers. Mitigation Measure BIO-9 would require covered activities to avoid impacts to vernal pools, wetlands, and streambeds to the maximum extent practicable. In instances where avoidance is infeasible, Mitigation Measure BIO-9 notes any vegetation trimming or removal or ground disturbance activities would be subject to all applicable permit requirements, including CDFW Streambed Alteration Agreements or Clean Water Act Section 404 requirements.

Response 6.2
The commenter states many proposed mitigation measures and project activities are qualified by language regarding their practicality or feasibility (e.g., “Any ground disturbing activities in riparian and wetland habitats shall be conducted when the channel is dry to the maximum extent feasible”).

The commenter specifically notes examples of such language in Mitigation Measures BIO-5, BIO-6, and BIO-9. The commenter adds this language can undermine critical environmental protections and exceptions to these protections should be fully specified and subject to public review prior to their implementation.

C-57
City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments

Final Initial Study – Mitigated Negative Declaration
As discussed in Response 6.1, the MBHMP is a long-term management plan intended to guide habitat restoration and enhancement efforts through management goals, policies, and supporting actions. Qualifying language is necessary at this time to provide some level of adaptive capacity for the MBHMP over the course of its planning horizon. However, where mitigation measures use such language, the measures also specify the environmental protections to occur in the event an avoidance measure is determined to be infeasible. This includes detailed requirements for nesting bird surveys when ground disturbance or vegetation removal must occur during the nesting season (Mitigation Measure BIO-6) or not allowing work within 50 feet of pools if ground disturbing activities occur in wetland or riparian areas when ponded water is present (Mitigation Measure BIO- 5).

The MBHMP also requires the preparation of annual Implementation Plans specifying specific actions to occur under the MBHMP over the coming year. As detailed in Policy 1-4 of the MBHMP, the Implementation Plans shall identify and describe short-term actions needed to further the goals and objectives of the MBHMP, taking into consideration current conditions and funding levels at the time each Implementation Plan is prepared. Pursuant to Action 1-4.2, City staff shall present each annual Implementation Plan at a public hearing for stakeholder input and City Council approval.

Response 6.3
The commenter refers to their previous comment made on August 31 (Item 259 in Appendix B) suggesting the final plan, particularly the Habitat Restoration and Enhancement Program, include an assessment of the impacts of all proposed actions on potentially affected downstream habitats, such as North Campus Open Space (NCOS) and Coal Oil Point Reserve (COPR). The commenter reiterates that even if the City believes such impacts would be neutral, negligible, or only positive, it would be appropriate to make this view explicit in the study, given that these immediately adjacent areas are of high value, sensitivity, and public interest.

As this comment is general in nature and does not provide any specifics regarding which impacts may potentially affect downstream habitats, a general response to these concerns is provided. (See Browning-Ferris Indus. v. City of San Jose (1986) 181 Cal.App.3d 852 [where a general comment is made, a general response is sufficient].) In general, discussion of impacts to downstream habitats relates to the topics of biological resources and hydrology and water quality. As discussed in Section 4 of the Draft IS-MND, Biological Resources, Mitigation Measures BIO-8 and BIO-9 would reduce impacts to riparian and wetland habitats by prohibiting stockpiling or temporary materials storage and avoiding activities in these areas unless it is for the purpose of habitat enhancement.

Additionally, Mitigation Measures in Section 10, Hydrology and Water Quality, require erosion control practices for all ground disturbing activities and preparation of a Chemical Application Control Plan to reduce the potential for migration of fertilizers, herbicides, or pesticides into waterbodies on-site and downstream. As determined in the impact analyses for these sections, the MBHMP would result in less than significant impacts with mitigation incorporated.

Response 6.4
The commenter notes references to the bird nesting season dates are internally inconsistent throughout the Draft IS-MND document, indicating that the season is marked as March 15 to August 15 on Pages 12, 19, and 73 but February 1 to September 15 in Mitigation Measure BIO-6 (Page 78).

The commenter suggests March through mid-August as a nesting bird season, and also attaches C-58
City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments Final Initial Study – Mitigated Negative Declaration
CDFW’s Conservation Measures for Biological Resources That May Be Affected by Program-level Actions (n.d.) for reference.

The March 15 to August 15 nesting season is noted in the MBHMP in Action 11-1.3 under the Wildlife Habitat Management Program, which seeks to “avoid removal of or disturbance to trees or other woody vegetation during nesting bird season (March 15 to August 15), when feasible.” The instances of these dates appearing in the Draft IS-MND noted by the commenter occur when referencing Action 11-1.3 of the MBHMP. However, the guidance attached by the commenter from CDFW recommends conducting nesting bird surveys for raptor species between February 1 and August 31. The February 1 to September 15 season where nesting bird surveys would be required by Mitigation Measure BIO-6 encompasses the March to mid-August season requested by the commenter, the February 1 to August 31 season suggested by CDFW, the March 15 to August 15 season indicated in Action 11-1.3 of the MBHMP, and includes some additional buffer to provide more conservative environmental protections for nesting birds in the Coverage Area.

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2 Subject: Comments on DRAFT INITIAL STUDY/MITIGATED NEGATIVE DECLARATION for Monarch Butterfly Habitat Management Plan Case No. 13‐087
Planning and Environmental Review
Attention: Anne Wells
Advance Planning Manager
February 25, 2019
Re: Draft IS/MND for Monarch Butterfly HMP
Dear Ms. Wells,
I am writing in support of comments provided by Friends of the Ellwood Monarch/FOTEM as provided by Ana Citrin of the Law Office of Marc Chytilo.

Respectfully,
Christina Lange
Friends of the Ellwood Coast
Letter 7
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City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments

Final Initial Study – Mitigated Negative Declaration
Letter 7
COMMENTER: Christina Lange, Friends of the Ellwood Coast DATE: February 25, 2019
Response 7.1
The commenter notes their support of comments submitted by Ana Citrin of the Law Offices of Marc Chytilo on behalf of the Friends of the Ellwood Monarchs (Letter 3).

This comment is noted. Please refer to Responses 3.1 through 3.15 above.

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Response from The Bluffs Community
to the
Monarch Butterfly Habitat Management Plan (MBHMP)
Background:

The Bluffs Community is located on the Western Side of the Ellwood Mesa Eucalyptus Forest, with the Sandpiper Golf Course to the West and Ellwood Preserve to the West, South and East. The Sandpiper and Ellwood North Monarch Butterfly aggregation sites are both in close
proximity to this community. Specifically:
 We are a community of 62 homes that was established following the 2004 land-swap between the City of Goleta and the builder of the community.  The homeowners in the community are passionate about maintaining the beauty, health and integrity of the preserve that surrounds our homes. We want to make sure that it is there for everyone to enjoy for decades, if not centuries, to come. It is one of the primary reasons that we live here.  The Bluffs community is committed to working with the City of Goleta to ensure that a workable Monarch Butterfly Habitat Management Plan is approved and implemented that protects the forest and all of the natural plant species and wildlife that make it their home. Along with this, there needs to be a balance with the safety, security and fire-mitigation needs of the communities that reside within the Ellwood Mesa Preserve boundaries.

Introduction:

The Bluffs was built in this location so that residents of the community would be able to enjoy the natural beauty of the preserve surrounding us. Homes were built, starting in 2005 and the community was completed by the end of 2013. Since that time, we have been able to enjoy the natural migration patterns of the butterflies and have had hundreds of them flying through our neighborhood during the winter and early Spring. Over the years, the condition of the preserve around us has become more and more a concern for homeowners and there has been a steady decline in the number of butterflies visiting our gardens.

This community did not need the Ellwood Monarch Habitat Assessment Report to inform us that the grove was steadily deteriorating with virtually no steps to manage it being done by the City of Goleta. We could see this progressive change on a constant basis. It is for this reason that we anticipated the arrival of the MBHMP as we felt it could help finally outline a plan for the ongoing maintenance, management and improvement efforts of the Ellwood Mesa Eucalyptus Forest surrounding us.

Residents of The Bluffs community, therefore, read through the MBHMP with the following basic questions in mind
.

Letter 8
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1. Does the implementation of this plan help reduce the risk of fire to the communities living within the boundaries of the Ellwood Mesa Preserve?

2. Does this plan provide improved management of dead/dying and diseased trees and reduce the safety hazards to recreational users and our communities?

3. Will this plan restore the health of the Ellwood Mesa Eucalyptus Preserve in both the short and longer term
for the enjoyment of all?
Ov
erall, we think the plan provides us with a lot of information about how work will be completed and what will be done to protect the plants and living creatures in the area. There are a number of overarching questions, however, that do not seem to be addressed. We believe they are critical to our being able to answer our three foundational questions listed above. Since we already know that a significant number of trees have been identified as needing to be removed (1,260+), it is important to understand the following:

1. Wha
t is the timeframe for the implementation of this plan? If the plan is approved this March, will work begin once the butterfly overwintering period is over (April 1st). How will the bird nesting period impact this work?

2. Wha
t is the plan with respect to the number of trees that the City is planning on trimming, cutting or removing per year? How much of the understory in areas can be cleaned up and removed at the same time?

3. Wha
t is the ratio of trees removed to new trees planted during this period of time?

4. H
ow long does the City of Goleta feel it will need to restore the health to the most critical monarch butterfly aggregation areas?

5. Wha
t near term steps will the City of Goleta take to reduce the potential for fire posed by the dead and fallen trees in the preserve that could potentially devastate both the butterfly preserve and endanger the residents in the area? We wa
nt to encourage the City of Goleta to begin the work of maintaining and improving the Ellwood Mesa Preserve as quickly as possible. It has taken the City nine years to get the MBHMP to this stage during which time minimal maintenance or improvements have been made to the Preserve. The condition of the Eucalyptus forest is not getting better with each passing day. We continue to lose trees in the areas surrounding our community at a frightening rate (seven more trees down in the past few months along the Western Trail alone). Fortunately, none fell towards any of our homes. Although we are thrilled to have had an average amount of rainfall this year, we are always concerned with the overall condition of the preserve around us, the instability of the current trees, and the risk of fire when the dry season arrives.

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Specific responses to MBHMP
Mitigation of Fire Risk to the communities living within the boundaries of the Ellwood Mesa Preserve

1. “Goleta is prone to large wildfires and the combination of hot, dry weather and ignitable vegetation adjacent to structures creates a fire environment that could potentially threaten public safety. In March 2012 the City adopted the Community Wildfire Protection Plan (CWPP). Protection of Human life and safety is the highest priority for all fire management strategies in Goleta, followed by the protection of property.” (MBHMP - Page 5) T
he MBHMP includes the Community Wildfire Protection Program to be consistent with the intent of the City’s CWPP and ensure fire safety and habitat protection are balanced. This program includes actions supporting the implementation of the CWPPs 100-foot-wide fire buffer around homes and structures in the Ellwood Mesa eucalyptus groves. The MBHMP states that implementation of this plan poses no additional fire risk and in fact reduces fire hazard, improves public safety and eliminates trees that threaten the sustainability of the butterfly aggregation sites.

We would like to understand what the City of Goleta will do annually to mitigate the fire risk the grove poses for our community.

While the plan mentions the CWPP there are limited details provided that highlight what is included in this plan. Members of The Bluffs community have worked annually (Since 2010) with the City of Goleta Public Works Department (Bob Morgenstern) to highlight vegetation abatement needs, to inform them of downed trees and branches blocking the trails and/or to report dead/dying or diseased trees that we feared were unstable and could pose a risk to the public or community should they fall or burn. This has frequently resulted in a very modest level of activity, usually the mowing of the perimeter of the community and Open Space Lot 69 to manage the non-native dry grasses growing there or the dragging of a fallen branch or two into the debris-filled understory. In some years, we have had to get the fire department (Fred Tan, Captain/Pre-Fire Engineer of the SBCFD Fire Prevention Division) to further highlight the fire risk that the grasses and dead wood located on the City property posed to our community before action was taken.

The CWPP map that designates the areas that should have vegetation abatement does not include Open Space LOT 69 which is the large open space area between the community and the Western Trail. That area is filled with non-native grasses and a small patch of ice plant and is the area that needs to be mowed or cut back annually. Without some form of treatment, this area grows to a height of 6-9 ft and poses a high fire-risk to that side of The Bluffs Community. The City of Goleta had initially planned on planting low height, drought-resistant native plants in this area but the plans were never approved C-64
and implemented by the City. In addition, the first part of the western trail, immediately abutting the homes nearest Hollister, does not seem to have any abatement or fuel reduction indicators on the map. These are BOTH high areas of concern for our community. A separate attachment of the map with these areas identified for the City will be provided with this response.

2. “The large trees are not the primary fuel of concern in the spread potential of wildfires. Instead., the greater threat is from the understory vegetation, dead-downed trees, and fuels that can create fire ladders. Therefore, fuel treatment activities focus on removing hazardous fuels rather than large trees.” (MBHMP - Page 7).
“S
ome species of Eucalyptus trees found on Ellwood Mesa, including Blue Gum, have deciduous bark, which shed annually and present a fire hazard. The bark catches fire readily and streamers from those loose bark tend to carry fire into the canopy and cast firebrands ahead of the main fire front. The leaf litter, which is the accumulation of dead, dry and oily leaves, is also a fire hazard as it is extremely flammable.” (MBHMP - Pages 28 & 98) We are not clear about how the understory in the groves surrounding us will be cleared out and what will be done with the debris.

Not only is it extremely flammable but it also burns hotter than most other vegetation. It is also known that due to their oil content, leaves and bark will decay at slower rates than other vegetation. An acre of Eucalyptus trees can accumulate 8-12 tons of debris. Because of its slower level of decay, this can easily build to around 30 tons per acre unless active management of the forest is done. This is a lot of flammable debris. As we look at the groves around our community, there are piles of debris that rise 5-8 feet in places.

To further complicate the fire risk, non-native annual grasslands dominate in areas without tree canopy, and are located immediately adjacent to the trees and the large volume of debris described above. In the open spaces surrounding The Bluffs, these grasses can grow to a height of 6-9 ft, especially in years with extensive rainfall. By April, these grassy areas begin to dry out and are the perfect fire-starter unless mowed down to a height of 4” or less. The entire circumference of The Bluffs Community is surrounded by these types of grasses. Lot 69 in particular, highlighted above, is one of those areas.

Improved management of dead/dying and diseased trees to reduce the safety hazards to recreational users and members of our communities?

1. The goal of the Trail Management Program is to develop and maintain public access trails that provide a safe and meaningful experience for visitors while limiting impacts to habitats and wildlife, in particular monarch butterflies and their seasonal aggregation sites.” (MBHMP – Page 10)
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When looking at the trails around The Bluffs this is not being done. Trails are covered with fallen trees and branches and have been this way for several years despite calls to Public Works to clear them for the public. As a result, recreational users are making their own trails through the trees and grasslands to avoid stepping or tripping on these obstacles. This seems to pose a higher risk to the plant and wild life we are all trying to protect.

2. “Taking down dead or dying eucalyptus trees could involve the staging or placement of debris piles, equipment, or personnel in areas where special- status plant species have a potential to occur and would impact these species .” (MBHMP - Page 70).

Large debris piles placed around the base of trees removed could not only impact native species of plants but could also increase fire risk as they are combined with the already debris-filled understory. This is further exacerbated if the grasslands are not properly mowed or maintained. We would like to better understand how all of these risks will be maintained and managed on an annual basis. There are many large piles of debris that have been eft behind by the City for years within the preserve. These piles MUST be a temporary situation, to help with the aggregation and removal efforts, and not left behind as kindling for months or years to come.

3. “The risk management program in the GUFMP ensures proper management of trees to allow for healthy attractive communities while reducing risk.

Implementation of the MBHMP would result in the removal of eucalyptus trees that pose an unacceptable risk to recreational users on the Coverage Area.” (MBHMP – Page 75)

Recreational users? What about residents who live within this area. We have trees within 5-6 feet of the perimeters of our homes. This is true at The Bluffs, Santa Barbara Shores and all Communities adjacent to Ellwood West, Ellwood Main and Ellwood East. The City seems to be listening to those “recreational users” who visit the preserve from time to time and not those who live in the shade of these trees and are in the preserve on a daily basis. Let’s make sure that we are clear about who currently has the “biggest threat to their safety” in this environment.

When the 27 trees were removed in 2018, which posed a public safety risk, NONE were removed within the proximity of our homes at The Bluffs. Only trees on trails that the City wanted to reopen were removed. Homeowners contacted the City Arborist and were told that they did not have the funds to remove those along the Western trail. At the request of a homeowner, a tagged tree was finally removed. Homeowners concerned for their safety petitioned the city to get permits to have the trees pruned at their own expense. ALL permits were granted as it was deemed that the branches did C-66
in fact pose a threat to their homes. These owners had arborists complete the work at their own expense.

4. Many trails in the coverage area have been closed indefinitely since July 2017 due to safety hazards posed by dead or dying trees. Implementation of the MBHMP would remove these hazards, in turn restoring access to trails and improving active transportation opportunities in the Coverage Area. (MBHMP -

Page 129 ends

This is an interesting statement to make considering the Western Trail was one of the trails closed and is within feet of the Common walls of our community. How is it that trails are closed for the protection of recreational users and yet nothing is done to protect the homeowners living within feet of these trees. It was also just announced that the trails are now reopened with

ABSOLUTELY NO WORK DONE BY THE CITY TO MITIGATE RISK TO THE COMMUNITY. Seven trees have fallen this year, many branches are down, the path continues to be blocked in areas by fallen branches and trees, and there is more tree debris and garbage than ever in these locations. Along the top of the western trail, nearest Hollister Avenue there are rusting metal pipes, concrete blocks and other hazardous obstacles along this walkway as well. If anything, the situation is worse and more volatile than when the trail was originally closed to the public.

Restored health of the Ellwood Mesa Eucalyptus Preserve in both the short and longer term for the enjoyment of all?

1. Replanting habitats where dead or dying eucalyptus trees are removed will help sustain the long-term viability of the Eucalyptus groves as monarch butterfly habitats. (MBHMP - Page 71)

Maintain and revegetate moderate cover of understory in and around aggregation sites with fire-resistant native plant species (The Xerces Society 2017 – Appendix 3.)

We agree with this and would love to see a combination of trees planted (not just eucalyptus trees) so that the entire forest becomes more stable.

Additionally, we encourage the planting of the appropriate native ground cover, shrub and mid canopy species of plants. We know there were plans to plant a number of Eucalyptus trees, equal to the 27 removed last year, across from Ellwood School. To our knowledge this was never done, and we have lost almost an entire rainy season which would have helped these trees become initially established in the area.

There were also plans made by the City of Goleta to plant and maintain “native grassland areas” in immediate proximity/adjacent to the homes in our community
. These plans were never implemented as committed to. The C-67
funds for this project were reapportioned to other initiatives within the preserve. The Coastal Commission was of the opinion that these improvements were completed and that based on the plan the area was cultivated and maintained so that no mowing would be required. We need to make sure that it is well documented that no planting or improvements were ever done to Open Space Lot 69 so that it can become part of the CWPP vegetation aggregation plans.

2. The goal of Trail Management is to maintain public access trails that provide a safe and meaningful experience for visitors while also limiting impacts to habitats and wildfires, in particular monarch butterflies and their seasonal aggregation sites. (MBHMP – Page 16)

We strongly support this initiative as the trails today are not maintained and have weathered poorly. In addition, many of them are covered with downed branches, fallen trees or are overgrown with grasses. In some places, the trails seem to almost disappear, and their signage is either damaged or no longer visible with the debris. New trails have been formed by users using the area when the original one is blocked or covered. The new trails and even some of the existing trails are not designed to be trails and many have hazardous obstacles on them that could cause injury if not navigated carefully.

A well-managed trail system will do a lot to enhance the beauty and enjoyment of this preserve by the public visiting it.

We hope that this project gets quick approval and that the work can start as soon as possible. The City of Goleta and the Planning Department have spent far too much time and energy getting “the reports and plans right on paper” with no actual action taking place to start to turn this situation around. We cannot let 2019 go by without having made significant forward progress towards the improved safety and health of this preserve. We hope the City Council understands this and acts to more forward soon!

Thank you!

Chuck Davis
Len and Cathleen Grabowski
Matt Graham
Carolyn Grenier

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City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments Final Initial Study – Mitigated Negative Declaration
Letter 8
COMMENTER: Chuck Davis, Len and Cathleen Grabowski, Matt Graham, and Carolyn Grenier, Residents
DATE: February 25, 2019
Response 8.1
The commenters provide background information on The Bluffs community, located on the western side of the Ellwood Mesa. The commenters state The Bluffs community is committed to working with the City to ensure a workable MBHMP is approved and implemented and the plan balances safety, security, and fire-mitigation needs of the communities surrounding Ellwood Mesa.

This comment will be forwarded to City decision-makers for consideration.

Response 8.2
The commenters provide additional information regarding when The Bluffs community was constructed and note the decline of the surrounding preserve and the number of butterflies. The commenters add they reviewed the MBHMP to see how it would reduce the risk of fire to communities surrounding Ellwood Mesa; provide improved management of dead, dying, or diseased trees; and restore the health of the Ellwood Mesa preserve in the short and long term.

Background information regarding the state of the eucalyptus groves and monarch butterfly populations are included in the Draft IS-MND, beginning on Page 4.

Response 8.3
The commenters request clarification regarding the timeframe for implementation of the MBHMP.

The commenters asked if the MBHMP is approved this March, will work begin once the butterfly overwintering period is over. Additionally, the commenters asked how the bird nesting period would impact work.

The MBHMP provides a long-term conservation strategy built around broad objectives, outcomes, and management policies for Ellwood Mesa monarch butterfly habitat. However, the MBHMP calls for preparation of annual Implementation Plans to identify activities to occur over the coming year.

The 2018 Implementation Plan was released along with the July 2018 draft of the MBHMP and calls for conducting nesting bird and monarch butterfly surveys, installation of enhancement plantings and signage, removal of existing closure signs, and long-term replacement tree monitoring. The schedule in the 2018 Implementation Plan calls for installation of enhancement plantings, signage, and removal of trail closure signage as early as March 2019. However, the 2018 Implementation Plan is currently being reviewed by the CCC, and requires CCC approval prior to implementation.

Certain actions under the MBHMP call for avoidance of vegetation removal or ground disturbance during the nesting bird season. However, vegetation removal or ground disturbance may occur, as necessary, following completion of nesting bird surveys within the identified nesting bird period.

Additionally, Mitigation Measure BIO-6 described in the Draft IS-MND requires surveys for nesting birds and raptors prior to any ground disturbance or vegetation removal work conducted in the nesting season, defined to be February 1 to September 15.

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City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments Final Initial Study – Mitigated Negative Declaration
Response 8.4
The commenters request clarification regarding the number of trees the City is planning on trimming, cutting, or removing per year. Additionally, the commenters request information regarding how much of the understory in areas can be cleaned up and removed at the same time.

As stated above, the MBHMP provides a long-term conservation strategy built around broad objectives, outcomes, and management policies for Ellwood Mesa monarch butterfly habitat. The MBHMP does not prescribe numbers of trees which can be removed or trimmed per year, nor does it limit the amount of understory that can be cleaned up and removed at the same time. Instead, the MBHMP calls for annual Implementation Plans to be prepared identifying activities to occur over the course of the upcoming year. Pursuant to Action 1-4.2, City staff shall present each annual Implementation Plan at a public hearing for stakeholder input and City Council approval.

Response 8.5
The commenters query the ratio of trees removed to new trees planted during this period of time.

The commenter does not specify the period of time to which they are referring. However, specific tree trimming, removal, and replanting information is not contained in the MBHMP and would be provided in subsequent Implementation Plans prepared pursuant to Policy 1-4. The 2018 Implementation Plan currently calls for planting of 63 trees to replace the 27 trees removed and 2 trees trimmed in 2017.

Response 8.6
The commenters asked how long the City will need to restore the health to the most critical monarch butterfly aggregation areas.

The MBHMP includes policies and actions aimed at improving grove health near existing aggregation sites. Restoration of grove health in these areas is dependent on approval of the MBHMP and Implementation Plans, availability of funding, and success of habitat restoration efforts.

Response 8.7
The commenters asked what near term steps the City will take to reduce potential for fire posed by the dead and fallen trees in the preserve that could devastate both the butterfly preserve and endanger residents in the area.

As noted in Response 5.1, the MBHMP is not intended to be a wildfire protection or mitigation plan, though it does pledge support for the policies and activities contained in the CWPP, which includes policies intended to reduce fire hazards from fuel loads in the Coverage Area. The MBHMP is intended to fulfill its stated purpose of supporting habitat for monarch butterflies and other plant and animal species, coastal access, and recreation while not exacerbating wildfire risk in or around the Coverage Area. As noted in Section 20, Wildfire, of the Draft IS-MND, the MBHMP would result in no impact related to wildfire and may have a beneficial effect by removing dead, dying, or otherwise hazardous trees and re-planting understory vegetation with native, fire-resistant species.

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City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments Final Initial Study – Mitigated Negative Declaration
Response 8.8
The commenters encourage the City to begin work maintaining and improving the Ellwood Mesa Preserve as quickly as possible, noting ongoing deterioration in the Preserve such as falling trees and growing fire risk.

This comment will be forwarded to City decision-makers for consideration.

Response 8.9
The commenters ask what the City will do annually to mitigate the fire risk posed by the grove. The commenters note the MBHMP lacks details on this front and mention work by members of The Bluffs community with the City’s Public Works Department to highlight vegetation abatement needs; inform the City of downed trees and branches; and report dead, dying, or diseased trees. The commenters add this has resulted in modest fire abatement activity. The commenters further note the CWPP-related fuel reduction zones within the Coverage Area map (Figure 3 of the MBHMP) does not include Open Space Lot 69, a large open space area between the community and the Western Trail filled with non-native grass that needs to be mowed or cut annually. Additionally, the commenters note areas of the Western Trail immediately abutting homes nearest Hollister Avenue also appear to lack any abatement or fuel reduction indicators on the map.

This comment relates to the content of the previously-approved CWPP. It does not relate to the content or adequacy of the Draft IS-MND. The MBHMP does not propose any changes to the CWPP.

Additionally, the areas noted by the commenter do not show fuel reduction zones on Figure 3 of the MBHMP because these areas are not located within the Coverage Area for the MBHMP.

Response 8.10
The commenters request clarification regarding how the understory in the groves will be cleared and what will be done with debris. The commenters note this debris is extremely flammable and burns hotter than most other vegetation. The commenters further note non-native annual grasslands dominate in areas without tree canopy immediately adjacent to the trees. The commenters particularly note that Lot 69 contains these grasses, which serve as a potential ignition source.

The Draft IS-MND discusses treatment of potential greenwaste, or debris from understory clearing and tree trimming or removals, in Section 19, Utilities and Service Systems. Greenwaste would either be repurposed on-site (e.g., using downed trees for seating or slope stability) or disposed of at the South Coast Recycling and Transfer Station, which was determined to have an adequate maximum permitting capacity to accommodate greenwaste generated by MBHMP activities. As noted in Response 9.9, Open Space Lot 69 is not included in the MBHMP Coverage Area.

Response 8.11
The commenters cite language from Page 10 of the Draft IS-MND, which states, “The goal of the Trail Management Program is to develop and maintain public access trails that provide a safe and meaningful experience for visitors while limiting impacts to habitats and wildlife, in particular monarch butterflies and their seasonal aggregation sites.” The commenters note this is not being done, and trails are covered with fallen trees and branches. The commenters add this has led to recreational users making their own trails through trees and grassland areas.

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City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments Final Initial Study – Mitigated Negative Declaration
The Trail Management Program noted by the commenters is a component of the MBHMP, evaluated in the Draft IS-MND. The MBHMP has not yet been adopted and, therefore, Trail Management Program activities have not yet occurred.

Response 8.12
The commenters cite language from Page 70 of the Draft IS-MND, which states, “Taking down dead or dying eucalyptus trees could involve the staging or placement of debris piles, equipment, or personnel in areas where special-status plant species have a potential to occur and would impact these species.” The commenters state large debris piles around the base of removed trees could also increase fire risk. The commenters add they would like to better understand how all of these risks will be maintained and managed on an annual basis. The commenters note there are large piles of debris that have been left behind by the City for years in the Preserve, and any piles must be temporary to help with aggregation site restoration and tree removal efforts.

In consideration of this concern, Mitigation Measure BIO-8 has been revised to clarify any stockpiling and staging associated with covered activities would be temporary in nature. Mitigation Measure BIO-8 has been revised, as follows:

Staging and stockpiling of debris associated with covered activities shall be temporary in nature, the duration of which shall be specified in the annual Implementation Plan prior to commencement of the covered activity. All staging and temporary stockpiling shall be limited to areas outside of riparian habitats, wetlands, vernal pools, native grasslands, and active nest buffers on site.

Absolutely no staging and/or stockpiling of any materials shall be allowed in these buffers at any time. Locations to be avoided must be clearly identified with fencing, flagging, rope, or other conspicuous material, and the contractor(s) conducting vegetation maintenance activities must be trained on the limits of work prior to commencing work. Placement of chipped woody materials must avoid impacting native grasslands, riparian, and wetland vegetation. The biological monitor would ensure avoidance for the duration of activities near these areas.

Additionally, Section 20, Wildfire, of the Draft IS-MND has been revised to include discussion of stockpiling of debris and greenwaste, with the following language added:

Mitigation measure BIO-8 would require any stockpiling of potentially ignitable debris or greenwaste to be temporary in nature, with the duration of debris stockpiling specified in the annual Implementation Plan prior to commencement of covered activities. Removed dead or dying trees would be replaced with healthy trees, which are less fire-prone, and which, pursuant to mitigation measure BIO-7, would be monitored annually for a period of five years to ensure they remain healthy. Both of these measures would further address community concerns about wildfire impacts associated with implementation of the MBHMP. No expansion of the existing eucalyptus groves would occur.

As noted in Response 8.10 above, greenwaste such as downed trees and understory debris, would either be repurposed on-site (e.g., mulched for trail cover, downed trees or logs serving as seating or erosion control) or disposed of off-site. Furthermore, as previously noted, the MBHMP is not intended to serve as a fire mitigation or abatement plan; however, the MBHMP is intended to support the previously-adopted CWPP and would reduce fire risk by removing dead, dying, or hazardous trees and replanting understory with native, fire-resistant species. For additional analysis of potential wildfire impacts associated with implementation of the MBHMP, please refer to Section 20, Wildfire, of the Draft IS-MND.

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City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments Final Initial Study – Mitigated Negative Declaration
Response 8.13
The commenters cite language from Page 75 of the Draft IS-MND, which states, “The risk management program in the Goleta Urban Forest Management Plan ensures proper management of trees to allow for healthy attractive communities while reducing risk. Implementation of the MBHMP would result in the removal of eucalyptus trees that pose an unacceptable risk to recreational users on the Coverage Area.” The commenters note nearby residents, not just recreational users, face risks from falling trees in the Coverage Area.

Removal of dead, dying, or otherwise hazardous trees would improve safety for residents adjacent to the Coverage Area, as well as recreational users. Page 75 of the Draft IS-MND has been revised as follows:

Implementation of the MBHMP would result in the removal of eucalyptus trees that pose an unacceptable risk to residents and recreational users on within and adjacent to the Coverage Area.

Response 8.14
The commenters note when 27 trees were removed previously, none were removed in proximity to homes in The Bluffs community. The commenters add homeowners contacted the City Arborist and ultimately had trees pruned at their own expense.

As described above, the MBHMP does not identify specific trees to be removed or replanted. Such activities would be identified in subsequently prepared annual Implementation Plans, drafted pursuant to MBHMP Policy 1-4 and presented at public hearings for stakeholder input and City Council approval.

Response 8.15
The commenters cite language from Page 129 of the Draft IS-MND, which states many trails in the Coverage Area have been closed indefinitely since July 2017 due to safety hazards posed by dead or dying trees. The commenters question why more was not done to protect homeowners living within feet of hazardous trees. The commenters also question why trails have reopened, particularly as there is more tree debris and garbage along trails now. The commenters specifically note rusting pipes, concrete blocks, and other hazardous obstacles at the top of the Western Trail nearest Hollister Avenue.

This comment does not directly relate to the content or adequacy of the Draft IS-MND. The portion of the Western Trail near Hollister Avenue is not located within the Coverage Area of the MBHMP.

As noted throughout the Draft IS-MND, covered activities under the MBHMP would continue to improve safety for recreational users by removing dead, dying, or otherwise hazardous trees. As noted in Response 8.13, above, such activities would also improve safety for residents adjacent to the Coverage Area.

Response 8.16
The commenters support efforts to plant a combination of trees (not just eucalyptus) to improve the stability of the groves. Additionally, the commenters encourage the planting of appropriate native ground cover, shrub, and mid-canopy species of plants. The commenters note there were plans to replace the 27 trees removed in 2017 across from Ellwood School, but indicate this was not done.

C-73
City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments Final Initial Study – Mitigated Negative Declaration
The commenters support for the replanting components of the MBHMP is noted. Additionally, the 2018 Implementation Plan details efforts to plant 63 replacement trees in the Coverage Area to mitigate the impacts of removing 27 trees in 2017. According to Figure 4, Enhancement Plan, of the 2018 Implementation Plan, these plantings would be located on 0.58 acre of existing eucalyptus grove south of Hollister Avenue/Ellwood School and east of the existing parking lot. The CCC is currently reviewing the 2018 Implementation Plan.

Response 8.17
The commenters note the City planned to plant and maintain native grassland areas in the immediate vicinity of homes in The Bluffs community, but such plans were never implemented. The commenters seek to make the City aware no such planting or improvements have occurred in Open Space Lot 69.

This comment does not relate to the content or adequacy of the Draft IS-MND. The Open Space Lot 69 is not included within the Coverage Area for the MBHMP, and the MBHMP does not propose any grassland restoration or maintenance efforts on this parcel, nor does it preclude such efforts from occurring.

Response 8.18
The commenters support initiatives noted in the Trail Management Program of the MBHMP to maintain public access trails that provide a safe and meaningful experience for visitors while limiting impacts to habitats and wildlife, in particular monarch butterflies and their seasonal aggregation sites. The commenters note the deterioration of trails in the Coverage Area and support a well- managed trail system.

The commenters support for the trail management activities in the MBHMP is noted and will be forwarded to City decision-makers for consideration.

Response 8.19
The commenters state they hope the project is approved quickly and that work begins as soon as possible. The commenters reiterate the urgency of improving safety and health of the preserve and urge the City Council to act.

The commenters support for approval is noted and will be forwarded to City decision-makers for consideration.

C-74
From: Laura Maskrey <[email protected]>
Sent: Mond
ay, February 25, 2019 4:58 PM
To: Anne Wells <[email protected]>
Subject: Comments ‐ Draft Initial Study/Mitigated Negative Declaration (IS/MND) for the Ellwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan (MBHMP My Name it is Laura Maskrey, I am a Goleta Resident address 7484 Sea Gull Drive, I can be reached at 805‐455‐1653
I have the following general comment on this document: It seems like we are in an emergency with regards to the Monarch population and this is not an emergency response plan, I understand that this is what we have and where we are at, but there seems like a good possibility the monarchs could possibly not come back next year - so at the very least there should be some urgent discussions being had about what we should be doing before the next year - since clearly this plan will not being taking effect before then.

I unfortunately have just not had time to review the specifics of the plan.

Thank you for your consideration
Laura Maskrey
Letter 9
C-75
City of Goleta
Ellwood Mesa/
Sperling Preserve Monarch Butterfly Habitat Management Plan Response to Comments Final Initial Study – Mitigated Negative Declaration
Letter 9
COMMENTER: Laura Maskrey, Residents
DATE: February 25, 2019
Response 9.1
The commenter notes the MBHMP is not an emergency response plan, but there exists a possibility monarch butterflies may not return to the Coverage Area next year. The commenter recommends there should be some urgent discussions about what should be done before the next year, since this plan will not take effect before then.

This comment relates to the content and timing of the MBHMP and does not relate to the content or adequacy of the Draft IS-MND. Therefore, this comment has been moved to the MBHMP Comment Matrix in Appendix B that was prepared to address comments related specifically to the MBHMP, and a response was provided in the matrix. The MBHMP Comment Matrix will be provided to City Council for its review prior to considering adoption of the MBHMP.

C-76
Mitigation Monitoring and Reporting Program

Final Initial Study – Mitigated Negative Declaration D-1 Mitigation Monitoring and Reporting Program
CEQA requires that a reporting or monitoring program be adopted for the conditions of project approval that are necessary to mitigate or avoid significant effects on the environment (Public Resources Code 21081.6). This mitigation monitoring and reporting program (MMRP) is designed to ensure compliance with adopted mitigation measures during implementation of the Monarch Butterfly Habitat Management Plan. For each mitigation measure outlined in the Final Initial Study- Mitigated Negative Declaration, specifications are made herein that identify the action required and the monitoring that must occur. In addition, a responsible agency is identified for verifying compliance with individual conditions of approval contained in this MMRP.

Attachment 4 - Appendix D
City of
Goleta

Ellwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan

D
-
2 Mitigation Measure/

Condition of Approval

Action Required

Monitoring Timing

Monitoring
Frequency

Responsible

Party

Compliance Verification

Initial

Date

Comments

Air
Quality

AQ
-
1 Dust Control

All covered activities shall incorporate the following
dust control measures to reduce potential PM10
emissions during implementation of the MBHMP
.



Covered activities shall minimize the amount of
disturbed area to the
extent feasible



Onsite vehicle speeds shall be limited to 5 miles
per hour or less



The City or City
-
approved contractor shall install
gravel pads at the access points to Ellwood Mesa
Open Space to prevent tracking of dirt/mud onto
public roads



After a grou
nd
-
disturbing activity is completed,
the City or City
-
approved contractor shall treat
the disturbed area by watering, revegetating, or
spreading soil binders

The City

shall comply with the
requirements of this measure.

T
hr
oughout
ground
-
disturbing activities

Periodically during
and at completion
of ground
-
disturbing
activities

City of
Goleta
Public Works

Biological Resources

BIO
-
1 General Housekeeping

General requirements that shall be followed by all
personnel are
listed below.



MBHMP
-
related vehicles shall observe a 5
-
mile
-
per
-
hour speed limit in the Coverage Area at all
times



MBHMP
-
related vehicles and equipment shall
restrict off
-
road travel to approved routes, which
shall be sited by the City to minimize
environm
ental impacts



All food
-
related trash items, such as wrappers,
cans, bottles, and food scraps, generated during
implementation of the MBHMP shall be removed
from the site daily



No deliberate feeding of wildlife shall be allowed



No pets shall be allowed on i
n the Coverage Area

The City

shall comply with the
requirements of this measure.

Th
roughout

MBHMP
activities

Periodically during
MBHMP activities

City of Goleta
Public Works

Mitigation Monitoring and Reporting Program

Final Initial Study
–

Mitigated Negative Declaration

D
-
3 Mitigation Measure/

Condition of Approval

Action Required

Monitoring Timing

Monitoring
Frequency

Responsible

Party

Compliance Verification

Initial

Date

Comments



No firearms shall be allowed in the Coverage
Area



If vehicle or equipment maintenance is necessary
including refueling of equipment, it shall be
performed outside the buffers of ESHAs, bird
nests, and monarch aggregation sites



Any worke
r who inadvertently injures or kills a
special status species or finds one dead, injured,
or entrapped shall immediately report the
incident to the biological monitor. The monitor
shall immediately notify City of Goleta staff. The
City of Goleta shall foll
ow up with written
notification to USFWS and CDFW as appropriate,
depending on the species. The biological monitor
shall also independently notify USFWS of any
unanticipated harm to any federally listed
endangered species associated with
implementation of
the MBHMP. All observations
of federally or State
-
listed threatened or
endangered species shall be recorded on CNDDB
field sheets and sent to CDFW by City of Goleta
or the biological monitor.

City of
Goleta

Ellwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan

D
-
4 Mitigation Measure/

Condition of Approval

Action Required

Monitoring Timing

Monitoring
Frequency

Responsible

Party

Compliance Verification

Initial

Date

Comments

BIO
-
2 Qualified Biological Monitor

A qualified biological monitor shall be present during
all vegetation removal and ground disturbing
activities to
ensure compliance with all mitigation
measures, applicable permit conditions, and any
conditions required by federal and State agencies.

The monitor shall be responsible for:



Ensuring that procedures for verifying
compliance with environmental
mitigation
measures are followed.



Lines of communication and reporting methods.



Daily and weekly reporting of compliance.



MBHMP crew training regarding environmentally
sensitive areas.



Authority to stop work.



Action to be taken in the event of non
-
complian
ce.

The City

shall retain a qualified
biological monitor.

Prior to
ground
-
disturbing and/or
vegetation removal
activity

Once

City of Goleta
Public Works

BIO
-
3 Biological Resources Awareness Training

Before any ground
-
disturbing work or
vegetation
removal/trimming occurs in the Coverage Area, a
qualified biologist shall conduct a mandatory
biological resources awareness training for all
MBHMP personnel about federally and State listed
species that could occur on site. The training shall
i
nclude the natural history, representative
photographs, and legal status of each federally listed
species. Proof of personnel attendance shall be kept
on file. If new MBHMP personnel are added to the
crew, the contractor shall ensure that the new
personnel

receive the mandatory training before
starting work. The subsequent training of personnel
can include videotape of the initial training and/or
the use of written materials rather than in
-
person
training by a biologist.

The q
ualified biologist shall

conduc
t
the pre
-
activity

training for all

MBHMP personnel, and

record and
maintain a record of all those who
have attended this training.

The City

shall review records.

Prior to ground
-
disturbance or
vegetation removal
(conduct training
;
maintain attendance
reco
rd
); as needed
(with the addition of
new personnel
;
maintain attendance
record
);
following
trainings

(review
records)

Once prior to work
(conduct training);
as needed during
MBHMP activities

(with the addition
of new personnel
;
maintain
attendance
record
)
;
periodically
(review records)

City of Goleta
Public Works

Mitigation Monitoring and Reporting Program

Final Initial Study
–

Mitigated Negative Declaration

D
-
5 Mitigation Measure/

Condition of Approval

Action Required

Monitoring Timing

Monitoring
Frequency

Responsible

Party

Compliance Verification

Initial

Date

Comments

BIO
-
4 Special
-
Status Plants

To avoid impacts to special
-
status plants, periodic
rare plant surveys the Coverage
Area must occur at
least once every five years during a normal rainfall
year, following current standard practice for
botanical surveys (CDFW 2018), which may require
multiple passes to detect or rule out all potential
species. If special
-
status plants rem
ain absent from
work areas, no further action is required. If special
-
status plants are detected in work areas, locations
must be mapped, and the plants must be avoided
during MBHMP activities. A pre
-
work training must
be provided to the contractor(s) cond
ucting
vegetation maintenance activities that identifies
special
-
status plants in and near the work area and
locations to be avoided. If weed control is required
in areas supporting special
-
status plants, this work
must be conducted with hand tools. Vegeta
tion
control in these areas must emphasize control of
non
-
native species, avoid flowering and fruiting
seasons of the identified special
-
status plants to the
maximum extent possible, and ensure that activities
do not remove special
-
status plant individuals
.

The City

shall retain a qualified
biologist to conduct surveys and
trainings,
and

shall
review
surveys and
training records
.

During a normal
rainfall year

(
conduct
and
review surveys);
as needed (review
training records
)

At least every five
years

(
conduct and
review surveys
); as
needed (
review
training records
)

City of Goleta
Public Works

BIO
-
5 California Red
-
legged Frog

Any ground disturbing activities in riparian and
wetland habitats shall be conducted when the
channel is dry to the maximum extent feasible.

Additionally, within seven days prior to start of work, a biologist must conduct a survey prior to any
ground distu
rbance to verify that riparian and
wetland areas do not contain ponded water and that
no California red
-
legged frogs are present. If ponded
water is present, no work may occur within 50 feet
of pools. If suitable resident frog habitat is present or frogs a
re noted during the surveys, a biological
monitor must be present during vegetation clearing
The
City shall

comply with the
requirements of thi
s measure
.

The
qualified biologist shall conduct a
survey and a biological monitor will be
present when required per this
measure.

The City
shall coordinate
with USFW/CDFW as needed.

Prior to
ground
-
disturbing activity
(
retain
biologist and
,
if
needed,

biological
monitor); No more
than seven days prior
to ground
disturbance
(perform
/review

surveys); as needed
(field monitoring for
compliance

and
Once (
retain
biologist and, if
needed, biological
monitor
);
o
nce
prior to
ground
disturbance
(perform
/review

surveys); as
needed (field
monitoring

for

compliance and
coordinate with
City of Goleta
Public Works

City of
Goleta

Ellwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan

D
-
6 Mitigation Measure/

Condition of Approval

Action Required

Monitoring Timing

Monitoring
Frequency

Responsible

Party

Compliance Verification

Initial

Date

Comments

and removal activities in riparian and wetland
habitats. The biologist will have the authority to stop work and identify areas that must be avoided. Listed
species

must be fully avoided unless take permits are
obtained from the USFWS and/or CDFW. Only
handheld tools shall be used. Removal of native
vegetation shall be limited to dead, damaged, and
diseased material.

coordinate with

USFWS/CDFW
)

USFWS/CDFW)

BIO
-
6 Nesting Bird Survey

To the maximum extent feasible, tree trimming
activities must occur in
September to ensure that
raptor nests and monarchs are not active in the work
area. Surveys for nesting birds and raptors are
required prior to any ground disturbance or
vegetation removal work conducted in the nesting
season, defined to be February 1 to S
eptember 15.

If ground
-
disturbing or vegetation removal work
does occur during the nesting season, then not more
than three (3) days before ground disturbance
and/or vegetation removal commences, a bird and
raptor survey must be conducted by a City
-
approve
d
biologist in the disturbance footprint plus a 300
-
foot
buffer, as feasible. If the MBHMP activity is phased, a subsequent nesting bird and raptor survey is
required in the Coverage Area before each phase of
the activity. If no raptor or other bird nests
are
observed no further mitigation is required.

Nesting bird and raptor surveys must be conducted
during the time of day when bird species are active
and be of sufficient duration to reliably conclude
presence/absence of nesting birds and raptors in the
30 0
-
foot buffer.

If active nests of species protected by CFG Code
3503 or the MBTA Migratory Bird Treaty Act are
found within 300 feet of the Coverage Area, their
locations must be flagged and then mapped onto an
aerial photograph of the Coverage Area at a
scale no
The City

shall comply with the
requirements of this measure.

The
qualified
biologist shall conduct
surveys and a biological monitor will
be present when required per this
measure.

No more than three
days prior to start of
tree trimming,
ground disturbance
,

and/or vegetation
removal (perform
surveys); as needed
(ensure compliance
)

Once per
commencement of
tree trimming,
ground
-
disturbing
,

and/or vegetation
removal

activities,
if necessary
(
perform
survey);
as needed (ensure
compliance)

City of Goleta
Public Works

Mitigation Monitoring and Reporting Program

Final Initial Study
–

Mitigated Negative Declaration

D
-
7 Mitigation Measure/

Condition of Approval

Action Required

Monitoring Timing

Monitoring
Frequency

Responsible

Party

Compliance Verification

Initial

Date

Comments

less than 1” =200’ and/or recorded with the use of a
GPS unit. If active raptor nests are detected, the map
will include topographic lines, parcel boundaries,
adjacent roads, known historical nests for protected
nesting species, and known roosting

or foraging
areas, as required by Conservation Element Policy

8.3 of the Goleta General Plan. If feasible, the buffer must be 300 feet in compliance with Conservation
Element Policy CE 8.4 of the Goleta General Plan. If
the 300
-
foot buffer is infeasible,
the City approved
biologist may reduce the buffer distance as
appropriate, dependent on the species and the
proposed work activities. If any active non
-
raptor
bird nests are found, a suitable buffer area (varying
from 25
-
300 feet), depending on the species
, must
be established by the City
-
approved biologist. No
ground disturbance can occur in the buffer until the
City
-
approved biologist confirms that the
breeding/nesting is completed, and all the young
have fledged. Alternately, a City
-
approved biologist
mu
st monitor the active nest full
-
time during
MBHMP activities in the buffer to ensure MBHMP
activities are not indirectly impacting protected
nesting birds and raptors.

BIO
-
7 Tree Replacement

All replacement trees planted in the
Coverage Area
must be monitored annually for a minimum period
of 5 years. At the end of the 5
-
year monitoring
period, replacement trees shall be inspected by a
City approved arborist to determine the successful
establishment of the trees. The arborist may
extend
the monitoring period as deemed necessary. If a
replacement tree dies during the monitoring period,
it shall be replaced and monitored as required by
this mitigation measure.

The City
Council
shall review and
approve
annual
implementation
plans
, whi
ch will include the
tree
replacement plan;
The a
rborist shall
inspect trees and
The City

shall

replace dead trees as needed.

Prior to
tree planting

(approve
plan
);
ongoing (
inspection
and replacement
)

Once (approve
plan); periodic
(
inspection and
replacement
)

City Council;
City
of Goleta Public
Works

City of
Goleta

Ellwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan

D
-
8 Mitigation Measure/

Condition of Approval

Action Required

Monitoring Timing

Monitoring
Frequency

Responsible

Party

Compliance Verification

Initial

Date

Comments

BIO
-
8 Native Habitats

All staging and temporary
stockpili
ng shall be limited to areas outside of
riparian habitats, wetlands, vernal pools, native
grasslands, and active nest buffers on site.

Absolutely no staging and/or stockpiling of any
materials shall be allowed in these buffers at any
time. Locations to be
avoided must be clearly
identified with fencing, flagging, rope, or other
conspicuous material, and the contractor(s)
conducting vegetation maintenance activities must
be trained on the limits of work prior to commencing
work. Placement of chipped woody ma
terials must
avoid impacting native grasslands, riparian, and
wetland vegetation. The biological monitor would
ensure avoidance for the duration of activities near
these areas.

The City
Council
shall review and
approve
annual implementation
plans,
which shall include

staging/stockpiling plans;
The
biological monitor will be present
when required per this measure.

Prior to
stockpiling

(approve plan)

; as
needed (ensure
compliance)

Once (approve
plan
)
; as needed
(ensure
compliance)

City Council;
City
of Goleta Public
Works

BIO
-
9 Riparian/Wetland Areas

Impacts to vernal pools, wetlands, and streambeds
shall be avoided to the maximum extent practicable,
unless they are affected for the purpose of habitat
enhancement. If avoidance is not feasible, the City
shall acquire and comply with regulatory permits f
or
any vegetation trimming, removal, or ground
disturbing activities to be completed in potentially
jurisdictional areas including in the vicinity of
Devereux Creek or other riparian/wetland habitats in
the Coverage Area. The CDFW shall be notified and a
S
treambed Alteration Agreement shall be obtained
for any activities that will result in impacts to a
streambed or riparian vegetation. In addition,
authorizations from the U.S. Army Corps of
The City

shall

review activities and
acquire permits from USFW/CDFW as
needed.

Prior to
approving
ground
-
disturbing
and/or vegetation
removal activi
ties

Once

City of Goleta
Public Works

Mitigation Monitoring and Reporting Program

Final Initial Study
–

Mitigated Negative Declaration

D
-
9 Mitigation Measure/

Condition of Approval

Action Required

Monitoring Timing

Monitoring
Frequency

Responsible

Party

Compliance Verification

Initial

Date

Comments

Engineers and Central Coast Regional Water Quality
Control Board (
RWCB) will be secured for any
activities involving discharges of fill material into a wetland or streambed.

Cultural Resources

CR
-
1 Archaeological and Native American Monitoring

Ground
-
disturbing activities associated with the
MBHMP, including but not limited to trail
modification and vegetation and tree
removal, shall
be observed by a qualified archaeological monitor
under the direction of an archaeologist meeting the
Secretary of the Interior’s Professional Qualifications Standards for prehistoric archaeology (National Park
Service 1983) and a local Nati
ve American monitor. If
archaeological resources are encountered during
ground
-
disturbing activities, work in the immediate
area shall halt and the find evaluated for
significance. Archaeological and/or Native American
monitoring may be reduced or halted a
t the
discretion of the monitors as warranted by
conditions including, but not limited to, negative
findings during the first 60 percent of ground
disturbance. If monitoring is reduced to spot
-
checking, spot
-
checking shall occur when ground
-
disturbing acti
vities occur in a new location in the
Coverage Area or when ground disturbance would
extend to depths not previously reached (unless
those depths are within bedrock).

If archaeological resources are identified during
ground disturbance, they shall be left
in place and
avoided when feasible. If avoidance is infeasible, a
Phase II testing and evaluation program shall be
implemented. If resources are determined significant
or unique through Phase II testing and site avoidance
is not possible, appropriate site
-
specific measures
shall be identified in the Phase II evaluation. These
The City shall retain a qualified
archaeologist and
local Native
American monitor
, and comply with
the requirements of this measure
.

The archaeologist and local Native
American monitor shall ensure
compliance.

Prior to
ground
-
disturbing activities

(
retain

archaeologist
and Native American
monitor)
;
throughout ground
-
disturbing activities
(ensure compliance)

Once (approve
archaeologist and
retain Native
American
Monitor)
; as

needed (
ensure
compliance)

City of Goleta
Publ
ic Works

City of
Goleta

Ellwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan

D
-
10 Mitigation Measure/

Condition of Approval

Action Required

Monitoring Timing

Monitoring
Frequency

Responsible

Party

Compliance Verification

Initial

Date

Comments

measures may include, but would not be limited to,
a Phase III data recovery program, capping, or other
appropriate actions to be determined by a qualified
archaeologist in consultatio
n with the Native
American monitor.

Geology and Soils

GEO
-
1 Unanticipated Discovery of Paleontological Resources

In the event of an unanticipated discovery of a
paleontological resource during ground disturbance
from the implementation of the MBHMP, work in
the
immediate area shall be temporarily halted and a
qualified paleontologist (per Society of Vertebrate
Paleontology standards 2010) shall be contacted to
evaluate the find. If the discovery proves to be
significant and cannot be avoided, additional work,
suc
h as salvage excavation, may be required to
address any significant impacts.

The City shall
comply with the
requirements of this measure.

Immedia
tely upon
discovery of resource

As needed

City of Goleta
Public Works

Hydrology and Water Quality

HWQ
-
1 Erosion Control Best Management Practices

Prior to commencement of any ground
-
disturbing
activities not covered by a SWPPP prepared in
compliance with the requirements of the NPDES
Construction General Permit, the City or
City
-
authorized contractor shall implement the following
erosion control BMPs:



Ground
-
disturbing activities shall occur between
April 1 and September 30 to coincide with the
dry season and avoid impacts to overwintering
monarch butterflies.



Silt fencing, s
traw bales composed of rice straw
(that are certified to be free of weed seed), fiber
rolls, gravel bags, mulching erosion control
blankets, soil stabilizers, and storm drain filters
shall be used, in conjunction with other methods,
The City shall

implement the erosion
control BMPs
.

Prior to
and during
ground
-
disturbing
activity

Periodic

City of Goleta
Public Works

Mitigation Monitoring and Reporting Program

Final Initial Study
–

Mitigated Negative Declaration

D
-
11 Mitigation Measure/

Condition of Approval

Action Required

Monitoring Timing

Monitoring
Frequency

Responsible

Party

Compliance Verification

Initial

Date

Comments

to prevent erosion thro
ughout the Coverage
Area and siltation of stream channels and
detention basins.



Temporary berms and sediment basins shall be
constructed to avoid unnecessary siltation into
local waterways during ground
-
disturbing
activities.



Erosion controls which protect

and stabilize
exposed soils shall be used to prevent movement
of materials. Potential erosion control devices
include plastic sheeting held down with rocks or
sandbags over exposed soils and use of silt
fences or berms of hay bales.



Frequency of sediment
removal from detention
basins, locations and types of erosion and
sediment control structures, and materials that
would be used in the Coverage Area during
MBHMP activities shall be specified.



All exposed soils present in and around the
disturbed area shal
l be stabilized within seven
days of ground disturbance using mulch,
geotextile binding fabrics, and/or native,
drought
-
tolerant revegetation, as necessary.

HWQ
-
2 Chemical Application Control Plan

Prior to commencement of native planting,
eucalyptus grove restoration, invasive species
eradication, and pest control activities, the City shall prepare and implement a Chemical Application
Control Plan to be approved by the City Biologist.

The plan shall

identify thresholds to determine when
fertilizer, herbicide, or pesticide application is
necessary, the chemical to be used, and the rate,
timing, and placement of application. Pesticides or
insecticides shall be used only when necessary to
cure a problem

and in positively identified pre
-
emergent situations, not as a preventive measure or
as a regular, periodic application.

The City shall review and approve a
chemical application control plan
.

Prior to
chemical
application

Once

City of Goleta
Public Works

City of
Goleta

Ellwood Mesa/Sperling Preserve Monarch Butterfly Habitat Management Plan

D
-
12 Mitigation Measure/

Condition of Approval

Action Required

Monitoring Timing

Monitoring
Frequency

Responsible

Party

Compliance Verification

Initial

Date

Comments

When pesticide or herbicide application is deemed
necessary, use of chemical forms that are the least
toxic to non
-
target organisms s
hall be employed.

Only slow release organic fertilizers shall be used in
the Coverage Area to minimize the potential for
eutrophication in Devereux Creek. The application of
fertilizers, herbicides, or pesticides shall be
minimized during winter months whe
n the greatest
precipitation is likely to occur.

Noise

N
-
1 Noise Management

Consistent with mitigation recommended in the
City’s Environmental Thresholds and Guidelines
Manual, all noise
-
generating MBHMP activities,
including, but not limited to, tree removal, pruning,
trail maintenance, and riparian restoration, shall be
limited
to between 8:00 a.m. and 5:00 p.m. on
weekdays. Noise
-
generating MBHMP activities shall
not occur on weekends or State holidays.

If diesel
-
powered construction equipment is
necessary, all such equipment shall have properly
maintained sound
-
control devices
, and no
equipment shall have an unmuffled exhaust system.

Equipment shall not be left to idle while not in use.

The City shall
comply with the
requirements of this measure
.

Throughout
noise
-
generating activities

Periodic

City of Goleta
Public Works

Attachment 5
CWPP Prescription Guidance

68 | P a g e C i t y o f G o l e t a
C o m m u n i t y W i l d f i r e P r o t e c t i o n P l a n

Fuels Management Prescription Guidance
Undeveloped VMUS

Table 12 Prescription Guidance in Undeveloped VMUS
Location  Primary Defense Zone (A)
(0 – 30’)*

Fuel Reduction Zone (B)
(30’ – 100’)

Fuel Reduction Zone (C)
(100’ – 150’ - applies to larger areas)
Fuel Type  Based on Defensible Space PRC - 4291 Based on Firefighter Safety Grass/ Forbs
Reduce fuel depth to 4 inches; methods
include mowing, masticating, weed-
whacking, biological browsing
Same treatment as (A); longer grass in
isolated open areas is acceptable
Treatment may be needed in portions
on a case by case basis
Surface dead/down
material
Clear dead/down flammable materials;
methods include raking, hand-
piling/removal, masticating
chipping/dispersal on site
Reduce dead/down flammable material
to < 3” depth; methods same as (A); < 5
tons/acre in isolated logs acceptable.

Reduce heavier pockets of dead/down
flammable material to < 5” depth; < 5-7
tons/acre in isolated logs acceptable.

Brush/ Shrub fuel
Remove to a spacing (between edges of
brush) generally 2x brush height on <20%
slopes; methods include masticating or
hand-cutting, biological browsing
Same Treatment as (A); a pocket or
clump of brush can be treated as one
large shrub in more open site conditions.

Less intensive brush removal; with
spacing approximately 10 ft; and more
clumping of shrubs.

Trees Overstory
(without brush
understory)
Thin smaller trees leaving larger trees at
10-20 ft crown spacing (based on slope,
tree size and type); reduce ladder fuels by
pruning lower branches 6-15 ft up, or
lower 1/3 of tree height on smaller trees;
method likely hand-cut
Thin smaller trees leaving larger trees at
approx. 10 ft crown spacing (based on
slope, tree size and type); reduce ladder
fuels by pruning lower branches 6 ft up,
or lower 1/3 of tree height on smaller
trees; method likely hand-cut.

Reduce ladder fuels by pruning lower
branches of larger trees that have
broken limbs, dead material etc. 6 ft up;
method likely hand-cut.

Trees Overstory
(with brush
understory)
Thinning specs same as Trees Overstory
without brush understory (A). Understory:
remove brush ladder fuel; methods
include masticating or hand-cutting
Thinning specs same as Trees Overstory
without brush understory (B).

Understory: remove brush ladder fuel;
intermittent patches of shrubs and small
trees in openings (non-canopy) is
acceptable; methods include masticating
or hand-cutting
Thinning specs same as Trees Overstory
without brush understory (C).

Understory: less intensive removal of
brush ladder fuel; intermittent patches of
shrubs and small trees in openings (non-
canopy) is acceptable; methods include
masticating or hand-cutting

*For further information specific to homeowner/structure mitigation measures. See Section 6.2.1 69 | P a g e C i t y o f G o l e t a
C o m m u n i t y W i l d f i r e P r o t e c t i o n P l a n

Fuels Mitigation Prescription Guidance
Developed VMUs

Table 13 Prescription Guidance Developed VMUs
Location  Primary Defense Zone (A)
(0 – 30’)*

Fuel Reduction Zone (B)
(30’ – 100’)

Fuel Type  Based on Defensible Space PRC – 4291 and Firefighter Safety Grass/ Forbs Reduce fuel depth to 4 inches; methods include mowing, masticating, weed-whacking, biological browsing
Same treatment as (A); longer grass in isolated open areas is acceptable.

Surface dead/down
material
Clear dead/down flammable materials; methods include
raking, hand-piling/removal, masticating chipping/dispersal on site
Reduce dead/down flammable material to < 3” depth;
methods same as (A).

Brush/ Shrub fuel
Remove to a spacing (between edges of brush) generally
2x brush height on <20% slopes; methods include
masticating or hand-cutting, biological browsing
Same Treatment as (A); a pocket or clump of brush can be treated as one large shrub in more open site conditions.

Trees Overstory
(without brush
understory)
On case-by-case basis**: Thin smaller or unhealthy trees leaving larger trees at 10-20 ft crown spacing (based on slope, tree size and type). Reduce ladder fuels by pruning lower branches 6-15 ft up, or lower 1/3 of tree height on smaller trees; method likely hand-cut
On case-by-case basis**: Thin smaller or unhealthy trees.

Reduce ladder fuels by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees; method likely hand- cut.

Trees Overstory
(with brush
understory)
Thinning specs (case-by-case) same as Trees Overstory
without brush understory (A). Understory: remove brush
ladder fuel; methods include masticating or hand-cutting Thinning specs (case-by-case) same as Trees Overstory
without brush understory (B). Understory: remove brush
ladder fuel; intermittent patches of shrubs and small trees in openings (non-canopy) is acceptable; methods include
masticating or hand-cutting

(Note: Treatments listed are primarily those currently applied by Goleta City Management; the areas are mostly smaller, manic ured park type settings.) *For further information specific to homeowner/structure mitigation measures see Section 6.2.1. **The decision for this treatment need should be from the Goleta City Project Manager overseeing VMU mitigation work. Initial input from a wildland fire specialist is also recommended.
72 | P a g e C i t y o f G o l e t a
C o m m u n i t y W i l d f i r e P r o t e c t i o n P l a n

Table 14 Prescription Guidance for Butterfly Aggregation Areas Adjacent to Structures

*As determined by the Goleta City Project Manager overseeing mitigation work in consultation with a City approved monarch butterfly specialist and a City approved wildland fire specialist.
**As determined by the Goleta City Project Manager and Goleta City arborist. ***For further information specific to homeowner/structure mitigation measures see Section 6.2.1.

Location  Primary Defense Zone (A)***
(0 – 30’)

Fuel Reduction Zone (B***
(30’ – 100’)

Brush/ Shrub fuel
Remove to a spacing (between edges of brush) generally
2x brush height on <20% slopes; methods include
masticating or hand-cutting, biological browsing
Same Treatment as (A); a pocket or clump of brush can be treated as one large shrub in more open site conditions.

Trees Overstory
without brush
understory
Trim or thin only trees that do not provide protection to monarch butterfly aggregation sites* Thin smaller or
unhealthy trees at 10 – 20 ft crown spacing ( as
determined by slope, tree size and type);Leave larger trees unless toppling hazard.** Reduce ladder fuels by pruning lower branches 6-15 ft up, or lower 1/3 of tree height on trees smaller than 18 ft..

Trim or thin only trees that do not provide protection to monarch butterfly aggregation sites* Thin smaller or
unhealthy trees at approximately 10 ft crown spacing (as determined by slope, tree size and type);. Leave larger trees unless toppling hazard.** Reduce ladder fuels by pruning lower branches approximately 6 ft up, or lower 1/3 of tree height on trees smaller than 18 ft..

Trees Overstory
with brush
understory
Trim or thin only vegetation that does not provide protection to monarch butterfly aggregation sites* Thin small or
unhealthy trees at 10-20 ft crown spacing (based on slope, tree size and type). Leave larger trees at 10 ft. crown spacing unless toppling hazard.**( Reduce ladder fuels by pruning lower branches 6-15 ft up, or lower 1/3 of tree height on smaller trees In understory: remove brush ladder fuel. Methods include masticating or hand-cutting.

Trim or thin only vegetation that does not provide protection to monarch butterfly aggregation sites* Thin small or unhealthy trees to approximately 10 ft. crown spacing. Leave larger trees unless toppling hazard.** Reduce ladder fuels by
pruning lower branches approximately 6 ft up, or lower 1/3 of tree height on smaller trees. In understory remove brush ladder fuel. In non-canopied areas, noncontinuous patches of shrubs or small trees in openings is acceptable.. Methods include masticating or hand-cutting.

A
ttachment
6 CWPP Treatment Zones

CWPP Treatment Zones

Exemption Request for California Coastal Commission

6 -
1 Fuel
Reduction
/Treatment Types

Treatment Type

Summary

Unmodified Standard

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Modified Standard

Within 100 feet of structures:

Modify the standard treatment to be less removal, based on site specific conditions

Unmodified Aggregation

Within 100 feet of monarch aggregation sites:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 3 feet

Trim and thin unhealthy trees

Reduce fuel ladders and intermittent patches of shrubs and small trees in openings

Modified Aggregation

Within 100 feet of aggregation sites:

Modify the aggregation treatment to be less re
moval, based on site specific conditions

CWPP Treatment Zones

Grid Number

Zone

Treatment
1 Square Feet

Public Notes

Zone 0

Modified Standard

2,497

Modification is to trim or remove eucalyptus within 10 feet of existing path to create access.

Trim canopies by hand.

Retain eucalyptus stump for wildlife.

Zone 0

Modified Standard

2,016

Modification is to trim or remove eucalyptus within 10 feet of existing path to create access.

Trim canopies by hand.

Remove vegetation overhanging
structures.

Zone 0

Modified Standard

2,026

Modification is to trim or remove eucalyptus within 10 feet of existing path to create access.

Trim canopies by hand.

Zone 0

Modified Standard

2,035

Modification is to trim or remove eucalyptus
within 10 feet of existing path to create access.

Trim canopies by hand.

City of Goleta

Ellwood Mesa Open
Space Fuel Reduction
–

Waiver de Minimis

6 -
2 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

Zone 0

Modified Standard

2,045

Modification is to trim or remove eucalyptus within 10 feet of existing path to create access.

Trim canopies by hand.

Zone 0

Modified
Standard

2,054

Modification is to trim or remove eucalyptus within 10 feet of existing path to create access.

Trim canopies by hand.

Zone 0

Modified Standard

2,063

Modification is to trim or remove eucalyptus within 10 feet of existing path to create access.

Trim canopies by hand.

Zone 0/Zone 1

Modified Standard/

Unmodified Standard

6,291

Zone 0:

Modification is to trim or remove eucalyptus within 10 feet of existing path to create access.

Zone 1:

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 1

Unmodified Standard

7,881

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Z
one 1

Unmodified Standard

8,012

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller
trees

CWPP Treatment Zones

Exemption Request for California Coastal Commission

6 -
3 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

Zone 1

Unmodified Standard

9,966

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning
lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 1

Unmodified Standard

10,000

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy tree
s

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 1

Unmodified Standard

10,000

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 1/

Zone 2

Unmodified Standard/

Unmodified Standard

9,964

Zone 1 and 2:

Within 100

feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

City of Goleta

Ellwood Mesa Open
Space Fuel Reduction
–

Waiver de Minimis

6 -
4 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

Zone 1

Unmodified Standard

5,646

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree hei ght on smaller
trees

Zone 1

Unmodified Standard

9,988

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower
branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 1

Unmodified Standard

10,000

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 1

Unmodified Standard

9,767

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 fee
t

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

CWPP Treatment Zones

Exemption Request for California Coastal Commission

6 -
5 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

Zone 1

Unmodified Standard

818

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the
ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 1

Unmodified Standard

3,030

Within 100 feet of structures:

Mow
grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 1

Unmodified Standard

8,733

Wit
hin 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 1

Unmodified Standard

10,000

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller
trees

City of Goleta

Ellwood Mesa Open
Space Fuel Reduction
–

Waiver de Minimis

6 -
6 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

Zone 1

Unmodified Standard

2,687

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning
lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 1

Unmodified Standard

1,238

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin
unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 1

Unmodified Standard

3,680

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub

height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 1/

Zone 2

Unmodified Standard/

Unmodified Standard

8,144

Zone 1 and 2:

Within 100 feet of
structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

CWPP Treatment Zones

Exemption Request for California Coastal Commission

6 -
7 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

Zone 2

Unmodified St
andard

8,275

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller
trees

Zone 2

Unmodified Standard

2,937

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up,

or lower 1/3 of tree height on smaller
trees

Zone 2

Unmodified Standard

8,406

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel
ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 2

Unmodified Standard

2,618

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

City of Goleta

Ellwood Mesa Open
Space Fuel Reduction
–

Waiver de Minimis

6 -
8 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

Zone 2

Unmodified Standard

8,538

Within 100 feet of structures:

Mow grasses

Clear flam
mable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 2

Unmodified Standard

2,524

Within 100 feet of
structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 2

Unmodified St
andard

8,669

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller
trees

Zone 2

Unmodified Standard

2,628

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft
up, or lower 1/3 of tree height on smaller
trees

CWPP Treatment Zones

Exemption Request for California Coastal Commission

6 -
9 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

Zone 2

Unmodified Standard

8,800

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders

by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 2

Unmodified Standard

3,321

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 2

Unmodified Standard

8,931

Within 100 feet of structures:

Mow grasses

Clear flam
mable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 2

Unmodified Standard

5,646

Within 100 feet of
structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

City of Goleta

Ellwood Mesa Open
Space Fuel Reduction
–

Waiver de Minimis

6 -
10 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

Zone 2

Unmodified Standard

9,072

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree hei ght on smaller
trees

Zone 2

Unmodified Standard

6,969

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower
branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 3

Unmodified Standard

618

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce
fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 3

Unmodified Standard

3,764

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

CWPP Treatment Zones

Exemption Request for California Coastal Commission

6 -
11 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

Zone 3

Unmodified Standard

4,741

Within 100 feet of structures:

Mow grasses

Clear
flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 3

Unmodified Standard

7,311

Within 100 feet o
f structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 3

Unmodified Standard

6,917

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller
trees

Zone 4

Unmodified Standard

5,618

Zone 4:

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by
pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

City of Goleta

Ellwood Mesa Open
Space Fuel Reduction
–

Waiver de Minimis

6 -
12 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

Zone 4/

Zone 5

Unmodified Standard/

Modified Standard

5,314

Zone 4:

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub hei
ght to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 5:

Modification is no thinning of riparian trees.

Zone 5

Modified Standard

6967

Modification is no thinning of riparian trees.

Zone 5

Modified Standard

4,930

Modification is no thinning of riparian trees

Zone 5

Modified Standard

5,003

Modification is no thinning of riparian trees

Zone 5

Modified Standard

9,467

Modification is no thinning of riparian trees

Zone 5

Modified Standard

1,767

Modification is no thinning of riparian trees

Zone 5

Modified Standard

1,192

Modification is no thinning of riparian trees

Zone 5

Modified Standard

4,208

Modification is no thinning of riparian trees

Zone 5

Modified Standard

7,450

Modification is no thinning of riparian trees

Zone 5

Modified Standard

7,302

Modification is no thinning of riparian trees

Zone 5

Modified Standard

441

Modification is no thinning of riparian trees

Zone 5

Modified Standard

1,450

Modification is no thinning of riparian trees

Zone 5

Modified Standard

2,669

Modification is no thinning of riparian trees

Zone 5

Modified Standard

410

Modification is no thinning of riparian trees

Zone 6

Modified Standard

1,183

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

4,976

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

6,793

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

7,024

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

6,257

Modification is no thinning in riparian vegetation

Zone 6

Modified
Standard

5,797

Modification is no thinning in riparian vegetation

CWPP Treatment Zones

Exemption Request for California Coastal Commission

6 -
13 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

Zone 6

Modified Standard

2,817

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

4,238

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

6,843

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

986

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

933

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

6,483

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

430

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

2,185

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

5,156

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

4,314

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

669

Modification is no thinning in riparian
vegetation

Zone 6

Modified Standard

1,845

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

123

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

2,753

Modification is no thinning in
riparian vegetation

Zone 6

Modified Standard

729

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

543

Modification is no thinning in riparian vegetation

Zone 6

Modified Standard

57 Modification is no thinning in
riparian vegetation

Zone 7

Modified Standard

1,451

Modification is to remove all nonnative vegetation.

Zone 8

Unmodified Standard

7,908

Zone 8:

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

City of Goleta

Ellwood Mesa Open
Space Fuel Reduction
–

Waiver de Minimis

6 -
14 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

Zone 8

Unmodified Standard

7,226

Within 100 feet of structures:

Mow grasses

Clear
flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 8

Unmodified Standard

7,081

Within 100 feet o
f structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 8

Unmodified Standard

7,088

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree hei ght on smaller
trees

Zone 8/

Zone 9

Unmodified Standard/

Modified Aggregation

6,717

Zone 8:

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone 9:

Modification is to reduce treatment of trees near aggregation areas, to prevent wind exposure.

Zone 9

Modified Aggregation

7,175

Modification is to reduce treatment of trees near aggregation areas, to prevent wind exposure.

CWPP Treatment Zones

Exemption Request for California Coastal Commission

6 -
15 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

Zone 9

Modified Aggregation

7,025

Modification is to reduce treatment of trees near aggregation areas, to prevent wind exposure.

Zone 9

Modified Aggregat
ion

6,875

Modification is to reduce treatment of trees near aggregation areas, to prevent wind exposure.

Zone 9

Modified Aggregation

5,780

Modification is to reduce treatment of trees near aggregation areas, to prevent wind exposure.

Zone 9

Modified Aggregation

5,609

Modification is to reduce treatment of trees near aggregation areas, to prevent wind exposure.

Zone 9

Modified Aggregation

6,840

Modification is to reduce treatment of trees near aggregation areas, to prevent wind exposure.

Zone 9

Modified Aggregation

6,329

Modification is to reduce treatment of trees near aggregation areas, to prevent wind exposure.

Zone 9

Modified Aggregation

7,043

Modification is to reduce treatment of trees near aggregation areas, to pre vent wind exposure.

10A

Zone 9/

Zone 10

Modified Aggregation/

Unmodified Standard

9,582

Zone 9:

Modification is to reduce treatment of trees near aggregation areas, to prevent wind exposure.

Zone 10:

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

10B

Zone 10

Unmodified Standard

7,374

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

10C

Zone 10

Unmodified Standard

7,106

Within 100 feet of structures:

Mow grasses

Clear fl
ammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

City of Goleta

Ellwood Mesa Open
Space Fuel Reduction
–

Waiver de Minimis

6 -
16 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

10D

Zone 10

Unmodified Standard

5,354

Within 100
feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

11A

Zone 11
-

E
ast
of existing SCE
ROW

Modified Standard

1,188

Modification is to adjust treatment for vegetation east of trail, existing vegetation is largely landscaped with non
-
natives.

11B

Zone 11
-

East
of existing SCE
ROW

Modified Standard

1,027

Modification is to adjust treatment for vegetation east of trail, existing vegetation is largely landscaped with non
-
natives.

11C

Zone 11
-

East
of existing SCE
ROW

Modified Standard

869

Modification is to adjust treatment for vegetation east of trail, ex isting vegetation is largely
landscaped with non
-
natives.

11D

Zone 11
-

East
of existing SCE
ROW

Modified Standard

709

Modification is to adjust treatment for vegetation east of trail, existing vegetation is largely landscaped with
non
-
natives.

11E

Zone 11
-

East
of existing SCE
ROW

Modified Standard

780

Modification is to adjust treatment for vegetation east of trail, existing vegetation is largely landscaped with non
-
natives.

11F

Zone 11
-

East
of existing SCE
ROW

Modified Standa
rd

390

Modification is to adjust treatment for vegetation east of trail, existing vegetation is largely landscaped with non
-
natives.

11G

Zone 11
-

East
of existing SCE
ROW

Modified Standard

229

Modification is to adjust treatment for vegetation east of trail, existing vegetation is largely
landscaped with non
-
natives.

CWPP Treatment Zones

Exemption Request for California Coastal Commission

6 -
17 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

12A

Zone 11
-

East
of existing SCE
ROW /

Zone 12

Unmodified Standard

6,737

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to

2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

12B

Zone 12

Unmodified Standard

6,546

Within 100 feet of structures:

Mow grasses

Clear flammable materials from
the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

12C

Zone 12/

Zone 13

Unmodified Standard

2,596

Within 100 feet of
structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees.

13A

Zone 13

Modified S
tandard

5,853

Modification is to keep native grasses, no mowing.

13B

Zone 13

Modified Standard

7,307

Modification is to keep native grasses, no mowing.

14A

Zone 14

Modified Standard

7,291

Modification is to remove fire prone landscaped
non
-
native vegetation.

14B

Zone 14

Modified Standard

7,659

Modification is to remove fire prone landscaped non
-
native vegetation

15A

Zone 14/

Zone 15

Modified
Standard/Modified
Standard

6,977

Modification is to remove fire prone landscaped
non
-
native vegetation.

15B

Zone 15

Modified Standard

5,289

Modification is to remove fire prone landscaped non
-
native vegetation.

15C

Zone 15

Modified Standard

4,220

Modification is to remove fire prone landscaped non
-
native vegetation.

15D

Zone 15

Modified Standard

2,883

Modification is to remove fire prone landscaped non
-
native vegetation.

City of Goleta

Ellwood Mesa Open
Space Fuel Reduction
–

Waiver de Minimis

6 -
18 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

15E

Zone 15

Modified Standard

5,457

Modification is to remove fire prone landscaped non
-
native vegetation.

16A

Zone 16

Unmodified Standard

10,066

Within 100
feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

16B

Zone 16

Unm
odified Standard

1,937

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller
trees

16C

Zone 16

Unmodified Standard

7,057

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branc
hes 6 ft up, or lower 1/3 of tree height on smaller
trees

16D

Zone 16

Unmodified Standard

7,648

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

CWPP Treatment Zones

Exemption Request for California Coastal Commission

6 -
19 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

16E

Zone 16

Unmodified Standard

7,031

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

16F

Zone 16

Unmodified Standard

6,342

Within 100 feet of structures:

Mow grasses

Clear fl
ammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

17A

Zone 16/

Zone 17

Unmodified
Standard/Modified
Aggregation

6,287

Zone 16:

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lo wer 1/3 of tree height on smaller
trees

Zone 17:

Modification to be determined based on wind model data and with monarch butterfly specialist at the time of treatment. Some trees to be retained for wind protection of aggregation site.

17B

Zone 17

Modified

Aggregation

4,411

Modification to be determined based on wind model data and with monarch butterfly specialist at the time of treatment. Some trees to be retained for wind protection of aggregation site.

17C

Zone 17

Modified Aggregation

4,006

Modification to be determined based on wind model data and with monarch butterfly specialist at the time of treatment. Some trees to be retained for wind protection of aggregation site.

City of Goleta

Ellwood Mesa Open
Space Fuel Reduction
–

Waiver de Minimis

6 -
20 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

17D

Zone 17

Modified Aggregation

4,664

Modification to be determined
based on wind model data and with monarch butterfly
specialist at the time of treatment. Some trees to be retained for wind protection of aggregation site.

18A

Zone 18

Modified Standard

7,097

Modification is to limit pruning of native trees and leave saplings in place. Standard treatment
for nonnative vegetation.

19A

Zone 19

Unmodified Standard

6,074

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Re
duce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

19B

Zone 19

Unmodified Standard

2,624

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

19C

Zone 19

Unmodified Standard

1,023

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

19D

Zone 19

Unmodified Standard

6,143

Within 10
0 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

CWPP Treatment Zones

Exemption Request for California Coastal Commission

6 -
21 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

19E

Zone 19

Unmodified Standard

7,521

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree hei ght on smaller
trees

19F

Zone 19

Unmodified Standard

7,017

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower
branches 6 ft up, or lower 1/3 of tree height on smaller trees

19G

Zone 19

Unmodified Standard

5,294

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

20A

Zone 20

Unmodified Standard

5,547

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 f
eet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

City of Goleta

Ellwood Mesa Open
Space Fuel Reduction
–

Waiver de Minimis

6 -
22 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

20B

Zone 20

Unmodified Standard

7,352

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the
ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

20C

Zone 20/

Zone 21

Unmodified Standard/

Unmodified Standard

7,716

Zone 20 and 21
:

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

21A

Zone 21

Modified Standard

4,322

Modification to be determined in collaboration with the Audubon Society due to high value habitat for migrating birds.

21B

Zone 21

Modified Standard

8,845

Modification to be determined in collaboration with the A udubon Society due to high value
habitat for migrating birds.

21C

Zone 21

Modified Standard

6,156

Modification to be determined in collaboration with the Audubon Society due to high value habitat for migrating birds.

22A

Zone 22

Modified
Standard/
Unmodified Standard

6,573

Zone 21 and Zone 22:

Modification to be determined in collaboration with the Audubon Society due to high value habitat for migrating birds

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the gr
ound

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

CWPP Treatment Zones

Exemption Request for California Coastal Commission

6 -
23 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

22B

Zone 22

Unmodified Standard

6,874

Within 100 feet of structures:

Mow
grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

23A

Zone 22/

Zone 23

Unmodified Standard/

Unmodified
Aggregation

8,350

Zone 22:

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches
6 ft up, or lower 1/3 of tree height on smaller
trees

Zone 23:

Within 100 feet of monarch aggregation sites:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 3 feet

Trim and thin unhealthy trees

Reduce fuel ladders and in
termittent patches of shrubs and small trees in openings

23B

Zone 23

Unmodified
Aggregation

8,972

Within 100
feet

of monarch aggregation sites:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 3 feet

Trim and thin unhealthy trees

Reduce fuel ladders and intermittent patches of shrubs and small trees in openings

Zone A

Modified Standard

21,225

Modification is to leave riparian intact, no thinning of trees.

Zone B

Modified Aggregation

282,126

Modification is to leave wind break of trees on eastern and western boundaries.

Zone C

Modified Standard

28,254

Modification is to leave trees in parking lot planters as is.

City of Goleta

Ellwood Mesa Open
Space Fuel Reduction
–

Waiver de Minimis

6 -
24 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

Zone D

Modified Aggregation

194,610

Modification is to include creation of designed aggregation sites while protecting existing aggregation sites.

Zone E

Modified Standard

198,245

Modification is to leave wind break of trees protecting Zone F.

Zone F

Modifie
d Aggregation

78,263

Modification is to include creation of designed aggregation sites.

Zone G

Modified Aggregation

109,275

Modification is to leave riparian vegetation intact, no thinning of native trees, and leave wind break of trees
protecting Zone F.

Zone H

Modified Standard

23,156

Modification is to leave wind break of trees.

Zone I

Modified Aggregation

147,160

Modification is to leave wind break of trees on southern and western boundaries, and leave riparian vegetation intact.

Zone J

Modified Aggregation

167,515

Modification to include mowing with consideration and avoidance of native grasses (bunching and no
t bunching)

Zone K

Modified Aggregation

297,902

Modification to include cleanup of dead/browning vegetation. Eucalyptus trees to be left in place unless infested with beetles. Treatment of fuels (mostly grasses) on grove margin.

Zone L

Modified

Standard

202,512

Modification is to include felling a high fraction of standing dead eucalyptus trees, limbing down trees, and generally leaving large trunks in place.

Zone M

Modified Aggregation

388,949

Modification is to leave riparian vegeta
tion intact, no thinning of native trees.

Zone N

Modified Aggregation

271,234

Modification is to leave riparian vegetation intact, no tree thinning, and incorporate protection of avian habitat at Coronado Seep.

Zone O

Unmodified Standard

56,634

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zon
e P

Modified Standard

146,288

Modification is no thinning of riparian trees and no disturbance to coastal sage scrub vegetation.

CWPP Treatment Zones

Exemption Request for California Coastal Commission

6 -
25 Grid Number

Zone

Treatment
1 Square Feet

Public Notes

Zone Q

Unmodified Standard

170,051

Within 100 feet of structures:

Mow grasses

Clear flammable materials from the
ground

Reduce brush/scrub height to 2 feet

Trim and thin unhealthy trees

Reduce fuel ladders by pruning lower branches 6 ft up, or lower 1/3 of tree height on smaller trees

Zone R

Unmodified
Aggregation

186,189

Within 100 feet of monarch aggregation sites:

Mow grasses

Clear flammable materials from the ground

Reduce brush/scrub height to 3 feet

Trim and thin unhealthy trees

Reduce fuel ladders and intermittent patches of shrubs and small trees in openings.

1 Both Modified and Unmodified Aggregation treatments retain the trees that provide wind protection to the aggregation sites, v egetation removal is focused on dead and
downed trees and vegetation zero to six feet in height.

Attachment
7 Status and Compliance with
Conditions
from
NOI Permit Application No. 4
-
18 -
1223
Special Conditions of Approval

from

NOI Permit Application No. 4
-
18 -
1223

Ellwood Mesa Open Space Fuel Reduction
–

Waiver de Minimis

7 -
1 Conditions of Approval from NOI Permit Application No. 4 -
18 -
1223

Special Conditions

III. Special Conditions

Completed/In Progress

To Be Completed
During Project
Activities

Special Condition One

1. Final Implementation Plan

Prepare and
submit a Final
Implementation Plan

that clearly
identifies:1) interim and final success
criteria and performance standards
consistent with achieving the identified
restoration plan goals and objectives,
2) measures to be implemented if
success
criteria are not met and; 3)
long
-
term adaptive management of the
restored area.

1.A Submit, for the review and written
approval of the Executive Director, a
final Ellwood Mesa/Sperling Preserve
Open Space 2018 Implementation Plan
for the restoration

of t
he Ellwood North
aggregation sites. See Staff Report for
details.

The MBHMP IP
-

Phase 1 is being
prepared by the City and encompasses
the Ellwood North aggregation site and
includes enhancement details. It will be
submitted to the Coastal Commission in
J
une/July 2023. The MBHMP IP Phase 2
will be submitted in 2024/2025.

1.A. 3.

Submit a Final Monitoring Plan

with success (performance) criteria and
the qualitative and quantitative methods
for measuring success for all species
planted. See Staff Report for details.

The MBHMP IP
-

Phase 1 is being
prepared by the City and includes a final
monitoring plan.

1.A.4.

Submit two full
-
size sets of the
Final Planting Plan
: extent and scope of
enhancement activities, the locations of
existing living vegetation within the
enhancement area, the locations of all
new plantings, water tank and staging
areas.

The MBHMP I
P
-

Phase 1 is being
prepared by the City and includes a Final
Planting Plan and required details.

City of Goleta

Waiver de Minimis

Application Form

7 -
2 Special Condition Two

2. Sensitive Species Surveys

Retain the services of a qualified
biologist or environmental resources
specialist to conduct sensitive species
surveys (including birds and other
terrestrial species) and monitor project
operations.

2. Retain the services of a environmental
resources spe
cialist with appropriate
qualifications acceptable to the
Executive Director to conduct surveys
and monitoring. See Staff Report for
details.

2. A.

Submit the name and qualifications
of the environmental resources

specialist
, for the review and approval

of the Executive Director.

Services have been retained/contracted
and include:

Qualified Biologists

Certified Arborists

Monarch butterfly experts

2.A.1
. Conduct sensitive species surveys

no more than two weeks before any
project enhancement activities to detect
any active sensitive species, reproductive
behavior, and active nests within 500
feet of the project site.

Nest surveys must continue on a
monthly basis throughout the nesting
se
ason or until the project is completed

Sensitive species
surveys will be
conducted

Nesting bird surveys
will be conducted

2.A.5.

Environmental resources
specialist shall monitor
for/identify any
sensitive species/breeding
behavior/nests active within

300 feet
(500 feet for raptors/owls) of any project
enhancement activities. See Staff Report
for details.

Monitoring will be
conducted for active
nest

Special Condition Three

3. Construction Responsibilities

Special Conditions of Approval

from

NOI Permit Application No. 4
-
18 -
1223

Ellwood Mesa Open Space Fuel Reduction
–

Waiver de Minimis

7 -
3 See Staff Report for
Requirements

All construction
responsibilities will
be met during
project actitivities

Special Condition Four

4. Approval of Comprehensive
Management Plan

Submit a complete regular Coastal
Development Permit Application

for a
comprehensive plan to manage and
restore

all the aggregation sites within
Ellwood Mesa.

4. Submit a complete regular Coastal
Development Permit Application

for
the comprehensive plan to manage and
restore the aggregation sites within
Ellwood Mesa.

The MBHMP IP
-

Phase 1 is being
prepared by the City and will be
submitted to the Coastal Commission in
June/July 2023. The MBHMP IP Phase 2
will be submitted in 2024/2025.

Special Condition Five

5. Public Access Plan

Submit a public access
plan
, for review
by the Executive Director, that includes
a description of the methods by which
safe public access to and around the
project area shall be maintained during
all project operations, and also requires
the applicant to post the site with a
no
tice indicating the expected dates of
construction and/or temporary
closures.

5. Submit a public access plan
, for
review by the Executive Director, that
includes a description of the methods by
which safe public access to and around
the project area shall

be maintained
during all project operations, and also
requires the applicant to post the site
with a notice indicating the expected
dates of construction and/or temporary
closures.

The MBHMP IP
-

Phase 1 is being
prepared by the City and includes an
Acces
s Plan.

Special Condition Six

6. Informational/Educational Signage

Submit an informational/educational
signage plan
, that describes the
location, number, size, and contents of
signs to be placed.

6. Submit

an informational/educational
signage plan
, that describes the location,
number, size, and contents of signs to be
placed.

The MBHMP IP
-

Phase 1 is being
prepared by the City and includes a
Signage Plan.

Appendix B
Past Coastal Development Permit Special Conditions Matrix (See Attachment 7 - Special Conditions from NOI Permit
Application 4-18-1223 (above)

Appendix
C

Resource Avoidance Program

Ellwood Mesa MBHMP MND - Mitigation Measures, Ellwood North NOI CDP Special Conditions, and MBHMP Phase 1 Environmental Protection Practices TASK TYPE MEASURE/CONDITION MEASURE NO. DOCUMENT
Pre- Construction
Surveys/ Monitoring
A qualified biological monitor shall be present during all vegetation removal and ground disturbing activities to ensure compliance with all mitigation measures, applicable permit conditions, and any conditions required by federal and State agencies. The monitor shall be responsible for:
Ensuring that procedures for verifying compliance with environmental mitigation measures are followed.

BIO-2 MBHMP ISMND MMs/
MMRP
Lines of communication and reporting methods. BIO-2 MBHMP ISMND MMs/ MMRP
Daily and weekly reporting of compliance. BIO-2 MBHMP ISMND MMs/ MMRP
Authority to stop work. BIO-2 MBHMP ISMND MMs/
MMRP
Action to be taken in the event of non-compliance. BIO-2 MBHMP ISMND MMs/ MMRP
At least 30 calendar days prior to commencement of any enhancement activities, the applicant shall submit the name and qualifications of the environmental resources specialist, for the review and approval of the Executive Director. The applicant shall have the environmental resources specialist ensure that all project enhancement activities are carried out consistent with the following requirements.

Special Condition 2-
Sensitive Species
Ellwood North NOI
CDP No. 4-18-1223
MBHMP crew training regarding environmentally sensitive areas. BIO-2 MBHMP ISMND MMs/ MMRP
Before any ground-disturbing work or vegetation removal/trimming occurs in the Coverage Area, a qualified biologist shall conduct a mandatory biological resources awareness training for all MBHMP personnel about federally and State listed species that could occur on site. The training shall include the natural history, representative photographs, and legal status of each federally listed species. Proof of personnel attendance shall be kept on file. If new MBHMP personnel are added to the crew, the contractor shall ensure that the new personnel receive the mandatory training before starting work. The subsequent training of personnel can include videotape of the initial training and/or the use of written materials rather than in-person training by a biologist.

BIO-3 MBHMP ISMND MMs/
MMRP
Special-Status Plants
To avoid impacts to special-status plants, periodic rare plant surveys the Coverage Area must occur at least once every five years during a normal rainfall year, following current standard practice for botanical surveys (CDFW 2018), which may require multiple passes to detect or rule out all potential species. If special-status plants remain absent from work areas, no further action is required. If special-status plants are detected in work areas, locations must be mapped, and the plants must be avoided during MBHMP activities. A pre-work training must be provided to the contractor(s) conducting vegetation maintenance activities that identifies special- status plants in and near the work area and locations to be avoided. If weed control is required in areas supporting special-status plants, this work must be conducted with hand tools. Vegetation control in these areas must emphasize control of non-native species, avoid flowering and fruiting seasons of the identified special-status plants to the maximum extent possible, and ensure that activities do not remove special-status plant individuals.

BIO-4 MBHMP ISMND MMs/
MMRP
California Red-legged
Frog
Any ground disturbing activities in riparian and wetland habitats shall be conducted when the channel is dry to the maximum extent feasible. Additionally, within seven days prior to start of work, a biologist must conduct a survey prior to any ground disturbance to verify that riparian and wetland areas do not contain ponded water and that no California red-legged frogs are present. If ponded water is present, no work may occur within 50 feet of pools. If suitable resident frog habitat is present or frogs are noted during the surveys, a biological monitor must be present during vegetation clearing and removal activities in riparian and wetland habitats. The biologist will have the authority to stop work and identify areas that must be avoided. Listed species must be fully avoided unless take permits are obtained from the USFWS and/or CDFW. Only handheld tools shall be used. Removal of native vegetation shall be limited to dead, damaged, and diseased material.

BIO-5 MBHMP ISMND MMs/
MMRP
Survey. To the maximum extent feasible, tree trimming activities must occur in September to ensure that raptor nests and monarchs are not active in the work area. Surveys for nesting birds and raptors are required prior to any ground disturbance or vegetation removal work conducted in the nesting season, defined to be February 1 to September 15.

Nesting bird and raptor surveys must be conducted during the time of day when bird species are active and be of sufficient duration to reliably conclude presence/absence of nesting birds and raptors in the 300-foot buffer.

BIO-6 MBHMP ISMND MMs/
MMRP
Nest Flagging. If active nests of species protected by CFG Code 3503 or the MBTA Migratory Bird Treaty Act are found within 300 feet of the Coverage Area, their locations must be flagged and then mapped onto an aerial photograph of the Coverage Area at a scale no less than 1” =200’ and/or recorded with the use of a GPS unit. BIO-6 MBHMP ISMND MMs/ MMRP
Active Raptor Nest. If active raptor nests are detected, the map will include topographic lines, parcel boundaries, adjacent roads, known historical nests for protected nesting species, and known roosting or foraging areas, as required by Conservation Element Policy 8.3 of the Goleta General Plan. If feasible, the buffer must be 300 feet in compliance with Conservation Element Policy CE 8.4 of the Goleta General Plan. If the 300-foot buffer is infeasible, the City approved biologist may reduce the buffer distance as appropriate, dependent on the species and the proposed work activities.

BIO-6 MBHMP ISMND MMs/
MMRP
Active Non-raptor Nest. If any active non-raptor bird nests are found, a suitable buffer area (varying from 25-300 feet), depending on the species, must be established by the City-approved biologist. No ground disturbance can occur in the buffer until the City-approved biologist confirms that the breeding/nesting is completed, and all the young have fledged. Alternately, a City-approved biologist must monitor the active nest full- time during MBHMP activities in the buffer to ensure MBHMP activities are not indirectly impacting protected nesting birds and raptors.

BIO-6 MBHMP ISMND MMs/
MMRP
Qualified Biological
Monitor
Nesting Bird Survey
Biological Resources
Awareness Training
Appendix C - Resource Avoidance Program
Ellwood Mesa MBHMP MND - Mitigation Measures, Ellwood North NOI CDP Special Conditions, and MBHMP Phase 1 Environmental Protection Practices TASK TYPE MEASURE/CONDITION MEASURE NO. DOCUMENT
Survey. The environmental resources specialist shall conduct sensitive species surveys no more than two weeks before any project enhancement activities to detect any active sensitive species, reproductive behavior, and active nests within 500 feet of the project site. Follow-up surveys must be conducted 3 calendar days prior to the initiation of enhancement activities and nest surveys must continue on a monthly basis throughout the nesting season or until the project is completed, whichever comes first. The environmental resources specialist shall be onsite to observe/identify any sensitive species/breeding behavior/nests active within 300 feet (500 feet for raptors/owls) of any project enhancement activities.

Special Condition 2-
Sensitive Species
Ellwood North NOI
CDP No. 4-18-1223
Sensitive Species. In the event that any sensitive species are present in the project area but do not exhibit reproductive behavior and are not within the estimated breeding/reproductive cycle of the subject species, the environmental resources specialist shall implement a resource avoidance program with sufficient buffer areas to ensure adverse impacts to such resources are avoided.

The applicant shall also immediately notify the Executive Director of the presence of such species and which of the above actions are being taken. If the presence of any such sensitive species requires review by the United States Fish and Wildlife Service and/or the California Fish and Wildlife Service, then no development activities shall be allowed or continue until any such review and authorizations to proceed are received, subject to the approval of the Executive Director.

Special Condition 2-
Sensitive Species
Ellwood North NOI
CDP No. 4-18-1223
Active T/E Nest. If an active nest of a federally or state-listed threatened or endangered species, bird species of special concern, or any species of raptor or heron is found, the applicant shall notify the appropriate State and Federal agencies within 24 hours, and shall develop an appropriate action specific to each incident. The applicant shall notify the California Coastal Commission in writing by facsimile or e-mail within 24 hours and consult with the Commission regarding determinations of State and Federal agencies.

Special Condition 2-
Sensitive Species
Ellwood North NOI
CDP No. 4-18-1223
Active T/E Nest. If an active nest of any federally or state listed threatened or endangered species, species of special concern, or other sensitive species is found within 300 feet of enhancement activities (500 feet for raptors), the applicant shall retain the services of an environmental resources specialist with experience conducting bird and noise surveys, to monitor bird behavior and construction noise levels. The environmental resources specialist shall be present at all relevant construction meetings and during all significant enhancement activities (those with potential noise impacts) to ensure that nesting birds are not disturbed by construction- related noise. The environmental resources specialist shall monitor birds and noise every day at the beginning of the project and during all periods of significant enhancement activities. Activities may occur only if construction noise levels are at or below a peak of 65 dB at the nest(s) site. If construction noise exceeds a peak level of 65 dB at the nest(s) site, sound mitigation measures such as sound shields, blankets around smaller equipment, use of mufflers, and minimizing the use of back-up alarms shall be employed. If these sound mitigation measures do not reduce noise levels, enhancement activities within 300 ft. (500 ft. for raptors) of the nesting trees/areas shall cease and shall not recommence until either new sound mitigation can be employed or nesting is complete.

Special Condition 2-
Sensitive Species
Ellwood North NOI
CDP No. 4-18-1223
Monitoring/ Supplemental Program. The environmental resources specialist shall be present during all enhancement activities. The environmental resources specialist shall require the applicant to cease work within the area in question should any breach in permit compliance occur, or if any unforeseen sensitive habitat issues arise. If significant impacts or damage occur to sensitive habitats or to wildlife species, the applicant shall be required to submit a supplemental program to adequately mitigate such impacts. The supplemental program shall be submitted to the Executive Director for review and approval.

Special Condition 2-
Sensitive Species
Ellwood North NOI
CDP No. 4-18-1223
For the purpose of this special condition, “sensitive species” shall be taken to mean any special-status wildlife species. Special-Status Species are species listed as Endangered, Threatened, or Rare under the federal or state Endangered Species Acts, Candidate Species, California Fully Protected Species, and, pursuant to CEQA Guidelines Section 15380(d), all other species tracked by the California Natural Diversity Database (CNDDB), which are considered by the California Department of Fish and Wildlife to be those species of greatest conservation concern, and locally important species including raptors, herons, and songbirds.

Special Condition 2-
Sensitive Species
Ellwood North NOI
CDP No. 4-18-1223
White-Tailed Kite and
Special Status Raptor
Buffer/ Avoidance
Prior to the start of construction and required nesting bird surveys, a qualified avian biologist will review citizen database records including the Santa Barbara Audubon Society (SBAS) Santa Barbara Breeding Bird Study (SBAS 2023), iNaturalist Observations (iNaturalist 2023), and eBird Online Database (eBird 2023) for current and historic records of raptor nesting/breeding activity. If white-tailed kites are observed to be nesting within the Study Area, a minimum 500- foot buffer will be established around the nest site and the City will consult with CDFW to determine appropriate actions. In consultation with CDFW, a qualified biologist will determine passive activities (i.e. foot traffic and restoration/trail management or tree planting) that will be allowed within the buffer and construction activities (ground disturbance and operation of heavy equipment) that will be restricted within the buffer until a qualified biologist determines that the young have fledged and are no longer dependent on the nest site.

Environmental
Protection
Practices
MBHMP Phase 1
Implementation BRA
Construction
Responsibilities
Prior to the commencement of any enhancement activities, the limits of the work areas and staging areas shall be delineated in cooperation with a qualified biologist, limiting the potential area affected by construction and ensuring that all environmentally sensitive habitats adjacent to enhancement areas are avoided during construction. All vehicles and equipment shall be restricted to pre-established work areas and haul routes and to established or designated staging areas. Clearing shall be limited to the minimal footprint necessary and for the shortest time necessary to avoid impact to ESHA.

Special Condition 3-
Sensitive Species
Ellwood North NOI
CDP No. 4-18-1223
Riparian/ Wetland
Areas
Impacts to vernal pools, wetlands, and streambeds shall be avoided to the maximum extent practicable, unless they are affected for the purpose of habitat enhancement. If avoidance is not feasible, the City shall acquire and comply with regulatory permits for any vegetation trimming, removal, or ground disturbing activities to be completed in potentially jurisdictional areas including in the vicinity of Devereux Creek or other riparian/wetland habitats in the Coverage Area. The CDFW shall be notified and a Streambed Alteration Agreement shall be obtained for any activities that will result in impacts to a streambed or riparian vegetation. In addition, authorizations from the U.S. Army Corps of Engineers and Central Coast Regional Water Quality Control Board (RWCB) will be secured for any activities involving discharges of fill material into a wetland or streambed.

BIO-9 MBHMP ISMND MMs/
MMRP
Sensitive Species
Survey & Reporting
Ellwood Mesa MBHMP MND - Mitigation Measures, Ellwood North NOI CDP Special Conditions, and MBHMP Phase 1 Environmental Protection Practices TASK TYPE MEASURE/CONDITION MEASURE NO. DOCUMENT
Pre- construction Bat
Survey
If construction activities with a potential to impact roosting bats (i.e. ground disturbance, operation of heavy machinery, vegetation trimming) occurs within maternity season (March 1 to September 30), a qualified bat biologist with education and experience in bat biology and identification will conduct a pre-construction bat survey of any suitable habitat (loose bark, holes, or crevices in suitable roost trees) for occupied roosts. If an active bat roost is found, the qualified biologist shall establish a no-disturbance buffer around the roost. The width of the buffer should be determined by the qualified bat biologist based on species, specific site conditions, and level of disturbance. The buffer should be maintained until the qualified bat biologist determines the roost is no longer occupied.

Environmental
Protection
Practices
MBHMP Phase 1
Implementation BRA
Woodrat Midden
Avoidance/ Removal
Woodrat middens are assumed to be present within the Study Area due to the presence of dense eucalyptus and oak woodlands. The middens likely belong to the common big-eared woodrat (Neotoma macrotis). If an active woodrat midden is found during the pre-construction surveys and/or daily monitoring, a qualified biologist will flag the middens for avoidance during construction activities (ground disturbance, operation of heavy machinery, and vegetation trimming) and a 10-foot avoidance buffer will be established around the midden.

Environmental
Protection
Practices
MBHMP Phase 1
Implementation BRA
Native Tree Avoidance
The following tree protection measures will be implemented to ensure that impacts to mature native trees are minimized to the extent feasible or avoided, consistent with GP/CLUP Policy CE 9 prior to the start of construction:
A certified arborist or qualified biologist in direct communication with the arborist will monitor any ground disturbance or vegetation trimming activities that have a potential to impact mature native trees. A minimum 3-foot-tall snow fencing will be placed around the tree protection zone (TPZ; dripline) in areas of active construction. Fencing should be maintained and in place through the duration of construction activities.
Any grading, cut-and fill, trenching, or other ground disturbance should be done slowly using hand tools as feasible to avoid ripping or tearing roots. Roots two inches or more in diameter should be avoided to the extent feasible.
Any root pruning should be done at a 90-degree angle with a clean sharp blade, and new cuts should be wetted and covered with absorbent tarp or heavy cloth fabric until backfill is completed. No equipment or materials should be stored within TPZs as feasible. In areas where vehicles or equipment may impact tree roots, steel plates should be installed to protect the root zones as needed. Pruning should be limited to only what is necessary for construction. Inadvertent damage to limbs and branches from equipment should be immediately trimmed with clean blades. All pruning should rely on best practices as determined by the arborist.

Environmental
Protection
Practices
MBHMP Phase 1
Implementation BRA
During Construction
Surveys/ Monitoring
Daily Construction
Monitoring A qualified biological monitor will be present during all construction activities to ensure compliance with all environmental protection practices, mitigation measures, applicable permit conditions, and any conditions required by federal and State agencies.

Environmental
Protection
Practices
MBHMP Phase 1
Implementation BRA
Native Habitats
Staging and stockpiling of debris associated with covered activities shall be temporary in nature, the duration of which shall be specified in the annual Implementation Plan prior to commencement of the covered activity.

All staging and temporary stockpiling shall be limited to areas outside of riparian habitats, wetlands, vernal pools, native grasslands, and active nest buffers on site. Absolutely no staging and/or stockpiling of any materials shall be allowed in these buffers at any time. Locations to be avoided must be clearly identified with fencing, flagging, rope, or other conspicuous material, and the contractor(s) conducting vegetation maintenance activities must be trained on the limits of work prior to commencing work. Placement of chipped woody materials must avoid impacting native grasslands, riparian, and wetland vegetation. The biological monitor would ensure avoidance for the duration of activities near these areas.

BIO-8 MBHMP ISMND MMs/
MMRP
Archeological and
Native American
Monitoring
Ground-disturbing activities associated with the MBHMP, including but not limited to trail modification and vegetation and tree removal, shall be observed by a qualified archaeological monitor under the direction of an archaeologist meeting the Secretary of the Interior’s Professional Qualifications Standards for prehistoric archaeology (National Park Service 1983) and a local Native American monitor. If archaeological resources are encountered during ground-disturbing activities, work in the immediate area shall halt and the find evaluated for significance. Archaeological and/or Native American monitoring may be reduced or halted at the discretion of the monitors as warranted by conditions including, but not limited to, negative findings during the first 60 percent of ground disturbance. If monitoring is reduced to spot-checking, spot-checking shall occur when ground-disturbing activities occur in a new location in the Coverage Area or when ground disturbance would extend to depths not previously reached (unless those depths are within bedrock).

If archaeological resources are identified during ground disturbance, they shall be left in place and avoided when feasible. If avoidance is infeasible, a Phase II testing and evaluation program shall be implemented. If resources are determined significant or unique through Phase II testing and site avoidance is not possible, appropriate site-specific measures shall be identified in the Phase II evaluation. These measures may include, but would not be limited to, a Phase III data recovery program, capping, or other appropriate actions to be determined by a qualified archaeologist in consultation with the Native American monitor.

CR-1 MBHMP ISMND MMs/
MMRP
Unanticipated
Discovery of
Paleontological
Resources
In the event of an unanticipated discovery of a paleontological resource during ground disturbance from the implementation of the MBHMP, work in the immediate area shall be temporarily halted and a qualified paleontologist (per Society of Vertebrate Paleontology standards 2010) shall be contacted to evaluate the find. If the discovery proves to be significant and cannot be avoided, additional work, such as salvage excavation, may be required to address any significant impacts.

GEO- 1 MBHMP ISMND MMs/
MMRP
Ellwood Mesa MBHMP MND - Mitigation Measures, Ellwood North NOI CDP Special Conditions, and MBHMP Phase 1 Environmental Protection Practices TASK TYPE MEASURE/CONDITION MEASURE NO. DOCUMENT
Trash. During enhancement activities, all trash and construction debris shall be properly contained, removed from the worksite, and disposed of on a daily basis, and no construction materials shall be stored at the work site overnight. No construction materials, debris, or waste shall be placed or stored where it may enter sensitive habitat, receiving waters or a storm drain, or be subject to wind, rain, or erosion and dispersion. Any debris inadvertently discharged into coastal waters shall be recovered immediately and disposed of consistent with the requirements of this coastal development permit.

Special Condition 3-
Sensitive Species
Ellwood North NOI
CDP No. 4-18-1223
Stockpiles. Temporarily stockpiles of excavated sediment/vegetation should be protected with geofabric or other appropriate cover. Permanent stockpiling of excavated material on site shall not be allowed. Vegetation and sediment shall be removed from the site on a regular basis during enhancement activities to prevent the accumulation of sediment and debris on the worksite. Excavated sediment and vegetation shall be stockpiled at designated temporary areas on the project site and be removed to a permitted disposal site within 24 hours of completion of the project.

Special Condition 3-
Sensitive Species
Ellwood North NOI
CDP No. 4-18-1223
Equipment Staging. Equipment staging and materials stockpiling areas shall be limited to the locations and sizes specified in the approved final plans. Construction vehicles shall be restricted to designated haul routes.

Construction equipment and materials shall be stored only in designated staging and stockpiling areas as depicted on the final plans approved pursuant to Special Condition One (1).

Special Condition 3-
Sensitive Species
Ellwood North NOI
CDP No. 4-18-1223
Machinery and Fueling BMPs. Machinery and equipment shall be maintained and washed in confined areas specifically designed to control runoff. Thinners or solvents shall not be discharged into sanitary or storm sewer systems.

Any fueling and maintenance of construction equipment shall occur within upland areas outside of environmentally sensitive habitat areas or within designated staging areas. Mechanized heavy equipment and other vehicles used during the enhancement process shall not be refueled or washed within 100 feet of coastal waters.

Special Condition 3-
Sensitive Species
Ellwood North NOI
CDP No. 4-18-1223
Hazardous Materials. The discharge of any hazardous materials, including herbicides, into any receiving waters shall be prohibited Special Condition 3-
Sensitive Species
Ellwood North NOI
CDP No. 4-18-1223
BMPs. Best Management Practices (BMPs) and Good Housekeeping Practices (GHPs) designed to prevent spillage and/or runoff of construction-related materials, and to contain sediment or contaminants associated with construction activity, shall be implemented prior to the on-set of such activity.

All BMPs shall be maintained in a functional condition throughout the duration of enhancement activities.

Special Condition 3-
Sensitive Species
Ellwood North NOI
CDP No. 4-18-1223
Dust Control
All covered activities shall incorporate the following dust control measures to reduce potential PM10 emissions during implementation of the MBHMP. Covered activities shall minimize the amount of disturbed area to the extent feasible Onsite vehicle speeds shall be limited to 5 miles per hour or less The City or City-approved contractor shall install gravel pads at the access points to Ellwood Mesa Open Space to prevent tracking of dirt/mud onto public roads After a ground-disturbing activity is completed, the City or City-approved contractor shall treat the disturbed area by watering, revegetating, or spreading soil binders AQ-1 MBHMP ISMND MMs/
MMRP
Noise Management
Consistent with mitigation recommended in the City’s Environmental Thresholds and Guidelines Manual, all noise-generating MBHMP activities, including, but not limited to, tree removal, pruning, trail maintenance, and riparian restoration, shall be limited to between 8:00 a.m. and 5:00 p.m. on weekdays. Noise-generating MBHMP activities shall not occur on weekends or State holidays.

If diesel-powered construction equipment is necessary, all such equipment shall have properly maintained sound-control devices, and no equipment shall have an unmuffled exhaust system. Equipment shall not be left to idle while not in use.

N- 1 MBHMP ISMND MMs/
MMRP
General requirements that shall be followed by all personnel are listed below. MBHMP-related vehicles shall observe a 5-mile-per-hour speed limit in the Coverage Area at all times MBHMP-related vehicles and equipment shall restrict off-road travel to approved routes, which shall be sited by the City to minimize environmental impacts All food-related trash items, such as wrappers, cans, bottles, and food scraps, generated during implementation of the MBHMP shall be removed from the site daily No deliberate feeding of wildlife shall be allowed
No pets shall be allowed on in the Coverage Area
No firearms shall be allowed in the Coverage Area
If vehicle or equipment maintenance is necessary including refueling of equipment, it shall be performed outside the buffers of ESHAs, bird nests, and monarch aggregation sites Any worker who inadvertently injures or kills a special status species or finds one dead, injured, or entrapped shall immediately report the incident to the biological monitor. The monitor shall immediately notify City of Goleta staff. The City of Goleta shall follow up with written notification to USFWS and CDFW as appropriate, depending on the species. The biological monitor shall also independently notify USFWS of any unanticipated harm to any federally listed endangered species associated with implementation of the MBHMP.

BIO-1 MBHMP ISMND MMs/
MMRP
All observations of federally or State-listed threatened or endangered species shall be recorded on CNDDB field sheets and sent to CDFW by City of Goleta or the biological monitor. BIO-1 MBHMP ISMND MMs/ MMRP
General Housekeeping
Construction
Responsibilities
Ellwood Mesa MBHMP MND - Mitigation Measures, Ellwood North NOI CDP Special Conditions, and MBHMP Phase 1 Environmental Protection Practices TASK TYPE MEASURE/CONDITION MEASURE NO. DOCUMENT
Erosion Control Best
Management Practices
HWQ 1
Prior to commencement of any ground-disturbing activities not covered by a SWPPP prepared in compliance with the requirements of the NPDES Construction General Permit, the City or City-authorized contractor shall implement the following erosion control BMPs:
Ground-disturbing activities shall occur between April 1 and September 30 to coincide with the dry season and avoid impacts to overwintering monarch butterflies. Silt fencing, straw bales composed of rice straw (that are certified to be free of weed seed), fiber rolls, gravel bags, mulching erosion control blankets, soil stabilizers, and storm drain filters shall be used, in conjunction with other methods to prevent erosion throughout the Coverage Area and siltation of stream channels and detention basins. Temporary berms and sediment basins shall be constructed to avoid unnecessary siltation into local waterways during ground-disturbing activities. Erosion controls which protect and stabilize exposed soils shall be used to prevent movement of materials. Potential erosion control devices include plastic sheeting held down with rocks or sandbags over exposed soils and use of silt fences or berms of hay bales.
Frequency of sediment removal from detention basins, locations and types of erosion and sediment control structures, and materials that would be used in the Coverage Area during MBHMP activities shall be specified. All exposed soils present in and around the disturbed area shall be stabilized within seven days of ground disturbance using mulch, geotextile binding fabrics, and/or native, drought-tolerant revegetation, as necessary.

HWQ-1 MBHMP ISMND MMs/
MMRP
Post-Construction
Surveys/ Monitoring
Tree Placement
All replacement trees planted in the Coverage Area must be monitored annually for a minimum period of 5 years. At the end of the 5-year monitoring period, replacement trees shall be inspected by a City approved arborist to determine the successful establishment of the trees. The arborist may extend the monitoring period as deemed necessary. If a replacement tree dies during the monitoring period, it shall be replaced and monitored as required by this mitigation measure.

BIO-7 MBHMP ISMND MMs/
MMRP
Jurisdictional Waters
and Coastal Wetland
Avoidance/Restoration
Impacts to California Coastal Commission (CCC) coastal wetlands and jurisdictional water resources (regulated by CDFW, USACE, and RWQCB) shall be avoided to the maximum extent practicable, unless they are affected for the purpose of habitat enhancement. The construction of the public access improvements would temporarily impact 0.04-acre of jurisdictional water resources, including 0.01-acre of CCC coastal wetland. All temporary impact areas will be restored in place at a 1:1 ratio. The public access improvements will permanently impact 0.09 acres of jurisdictional water resources, including 0.09 acres of CCC coastal wetland. Permanently impacted areas will be restored at a 3:1 ratio, consistent with policies in the City of Goleta General Plan, totaling 0.28-acres to be restored on site. In addition per the MBHMP, the project will implement seven Natural Resources Management Programs, including: Monarch Butterfly Management, Wildlife Habitat Management, Tree Management, Integrated Pest Management, Habitat Enhancement and Restoration, Invasive Plant Management, and Ecosystem-wide Management Coordination. These plans articulate goals, policies, and actions necessary to maintain and improve the many important natural resources within the MBHMP coverage area. In addition, the MBHMP Phase 1 Implementation Plan (Rincon XX) was developed considering the elements within the CCC Suggestions for Resource Management Plans (CCC 2012).

Environmental
Protection
Practices
MBHMP Phase 1
Implementation BRA
Chemical Application
Control Plan
Prior to commencement of native planting, eucalyptus grove restoration, invasive species eradication, and pest control activities, the City shall prepare and implement a Chemical Application Control Plan to be approved by the City Biologist. The plan shall identify thresholds to determine when fertilizer, herbicide, or pesticide application is necessary, the chemical to be used, and the rate, timing, and placement of application. Pesticides or insecticides shall be used only when necessary to cure a problem and in positively identified pre-emergent situations, not as a preventive measure or as a regular, periodic application.

When pesticide or herbicide application is deemed necessary, use of chemical forms that are the least toxic to non-target organisms shall be employed. Only slow release organic fertilizers shall be used in the Coverage Area to minimize the potential for eutrophication in Devereux Creek. The application of fertilizers, herbicides, or pesticides shall be minimized during winter months when the greatest precipitation is likely to occur.

HWQ- 2 MBHMP ISMND MMs/
MMRP

Appendix
D

Ellwood
Mesa/Sperling Preserve Open Space Monarch Butterfly Overwintering Habitat Analysis and Recommendations for Restoration Report

Ellwood Mesa/Sperling Preserve Open Space
Monarch Butterfly Overwintering Habitat
Analysis and Recommendations
For Restoration
Goleta, California

Prepared for

George Thomson, Parks & Open Space Manager
CITY OF GOLETA – PUBLIC WORKS DEPARTMENT
130 Cremona Drive
Goleta, CA 93117

ALTHOUSE AND MEADE, INC.

BIOLOGICAL AND ENVIRONMENTAL SERVICES
1650 Ramada Drive, Suite 180
Paso Robles, CA 93446
(805) 237-9626

April 2023

1107
Appendix D
Althouse and Meade, Inc.

Habitat Analysis and Recommendations for Ellwood Mesa, City of Goleta i April 2023
Technical Report Contributors

Kyle Nessen
TIU Program Manager
Althouse and Meade, Inc.
1650 Ramada Drive, Suite 180
Paso Robles, CA 93446
(805) 237-9626
[email protected]

Stu Weiss, PhD
Principal Scientist
Creekside Science
P.O. Box 1553
Los Gatos, CA 95031
(605) 269-2876
[email protected]

Charis van der Heide
Senior Biologist
Althouse and Meade, Inc.
1650 Ramada Drive, Suite 180
Paso Robles, CA 93446
(805) 237-9626
[email protected]

LynneDee Althouse
Principal Scientist
Althouse and Meade, Inc.
1650 Ramada Drive, Suite 180
Paso Robles, CA 93446
(805) 237-9626
[email protected]

Corbin Matley
GIS Analyst
Althouse and Meade, Inc.
1650 Ramada Drive, Suite 180
Paso Robles, CA 93446
(805) 237-9626
[email protected]

NV5 (formerly Quantum) Geospatial
[LiDAR data collectors]
Andrew Brenner, Ph.D.

Senior Program Director
734-680-6424
[email protected]

In memory of
Daniel E. Meade, PhD.

Althouse and Meade, Inc.

Habitat Analysis and Recommendations for Ellwood Mesa, City of Goleta ii April 2023
Table of Contents
1 EXECUTIVE SUMMARY ............................................................................................ 1 2 INTRODUCTION ........................................................................................................ 3

2.1 History of Ellwood Mesa – 1800s to Present ....................................................... 4 3 MONARCH BUTTERFLY OVERWINTERING HABITAT AND BIOLOGY .................. 8

3.1 Features of Overwintering Monarch Habitat ........................................................ 8

3.2 The Importance of Eucalyptus Trees ................................................................... 9

3.3 Tree Species Consideration and Selection ........................................................ 10

3.4 Tree Species for Restoration of Ellwood Mesa .................................................. 15 4 ELLWOOD MESA BACKGROUND .......................................................................... 20

4.1 Monarchs at Ellwood Mesa ............................................................................... 20

4.2 Ellwood Mesa Monarchs Relative to the Western Population ........................... 20

4.3 Climate and topography at Ellwood Mesa ......................................................... 25

4.4 The 2012 – 2016 Drought: Unprecedented Event ............................................. 29

4.4.1 Impacts of Drought on the Ellwood Forests .................................................. 29

4.4.2 Tree Mortality ................................................................................................ 31

4.4.3 Effects of Tree Mortality on Monarch Habitat ................................................ 32 5 STATUS OF THE HABITAT AT ELLWOOD MESA .................................................. 43

5.1 Overview of Methods ......................................................................................... 43

5.1.1 Direct Observation ........................................................................................ 43

5.1.2 Hemispherical Photography .......................................................................... 44

5.1.3 LiDAR ........................................................................................................... 44

5.1.4 Arboriculture .................................................................................................. 44

5.1.5 Wind Model ................................................................................................... 45

5.2 Ellwood Main ..................................................................................................... 46

5.2.1 Historical Conditions at Ellwood Main: Hemiphotos 1990, 1998, and 2021 .. 50

5.2.2 Current Conditions at Ellwood Main .............................................................. 54

5.2.3 Recommendations for Ellwood Main Restoration Actions ............................. 56

5.3 Ellwood West ..................................................................................................... 68

5.3.1 Current Conditions at Ellwood West ............................................................. 68

5.3.2 Recommendations for Ellwood West Restoration Actions ............................ 69

5.4 Ellwood East ...................................................................................................... 75

5.4.1 Current Conditions at Ellwood East .............................................................. 75

5.4.2 Recommendations for Ellwood East Restoration Actions ............................. 77

5.5 Ellwood North .................................................................................................... 83 Althouse and Meade, Inc.

Habitat Analysis and Recommendations for Ellwood Mesa, City of Goleta iii April 2023

5.5.1 Current Conditions at Ellwood North-Central ................................................ 83

5.5.2 Recommendations for Ellwood North-Central Restoration Actions ............... 84

5.5.3 Current Conditions at Ellwood North-North ................................................... 88

5.5.4 Recommendations for Ellwood North-North Restoration Actions .................. 89

5.6 Ellwood Ironbark ................................................................................................ 93

5.6.1 Current Conditions at Ellwood Ironbark ........................................................ 93

5.6.2 Recommendations for the Creation of a New Site at Ellwood Ironbark ......... 94

5.7 Sandpiper .......................................................................................................... 97

5.8 Ocean Meadows ............................................................................................... 97

5.9 Extent of Forest Death ....................................................................................... 97

5.10 Wind and Monarch Movement between Ellwood Aggregation Sites ............... 100 6 RECOMMENDATIONS ........................................................................................... 102

6.1 Perform Deferred Maintenance ....................................................................... 102

6.1.1 Strategic Fuel Reduction ............................................................................. 102

6.1.2 Prepare Restoration Areas.......................................................................... 103

6.2 Restore Aggregation Trees and Wind Protection ............................................ 104

6.2.1 Restore Aggregation Trees ......................................................................... 104

6.2.2 Protect and Support Existing Live Trees ..................................................... 104

6.2.3 Double Wind Row Design ........................................................................... 105

6.2.4 Wind Modeling at Ellwood Main .................................................................. 109

6.2.5 Ellwood Main Prescriptions ......................................................................... 115

6.2.6 Ellwood West Prescriptions......................................................................... 117

6.2.7 Ellwood North Prescriptions ........................................................................ 119

6.2.8 Ellwood East Prescriptions.......................................................................... 121

6.2.9 Ellwood Ironbark Prescriptions .................................................................... 121

6.2.10 Sandpiper Prescriptions ......................................................................... 121

6.2.11 Ocean Meadows Prescriptions ............................................................... 125 7 DISCUSSION .......................................................................................................... 127 8 REFERENCES ....................................................................................................... 129 9 APPENDICES ......................................................................................................... 134

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Habitat Analysis and Recommendations for Ellwood Mesa, City of Goleta iv April 2023
List of Tables
Table 1. Ranking of Five Eucalyptus species ................................................................ 12 Table 2. Leaf Characteristics of Five Eucalyptus Species ............................................. 14 Table 3. Volume of Dead standing and Downed Wood by Monarch Site areas ............ 32 Table 4. Description of Ellwood Mesa Canopy Slices ................................................... 49 Table 5. Major Site Factors at Two Hemiphoto Sites in Cluster Zone for 1990, 1998, and 2021 .............................................................................................................................. 50 Table 6. Details of 4 Hemiphotos Within Primary Cluster Zone ..................................... 60 Table 7. Descriptions of Hemiphotos in Figure 21 ......................................................... 60 Table 8. Example Hemiphoto Data and Comments at Ellwood West ............................ 68 Table 9. Example Hemiphoto Data and Comments at Ellwood East ............................. 76 Table 10. Example Hemiphoto Data and Comments at Ellwood North-Central ............ 83 Table 11. Example Hemiphoto Data and Comments at Ellwood North-North ............... 88 Table 12. Example Hemiphoto Data and Comments at Ellwood Ironbark ..................... 93 Table 13. Results of 2017 Tree Health Assessment at Ellwood Mesa .......................... 98 Table 14. Double Row Growth Chart ........................................................................... 105

List of Graphs
Graph 1. Peak monarch population at Ellwood Main from 1989 to 2022 ....................... 21 Graph 2. Totals of Western Monarch Population, Santa Barbara County Monarch Population, and Monarchs at Ellwood Main in Logarithmic Scale ................................. 22 Graph 3. Monarch Counts at Ellwood Mesa, 2015-2016 Season .................................. 23 Graph 4. Monarch Counts at Ellwood Mesa, 2021-2022 Season .................................. 24 Graph 5. Monarch Counts at Ellwood Mesa, 2022-2023 Season .................................. 25 Graph 6. Historical temperature observations from 1993 – 2023 .................................. 26 Graph 7. Wind observations from 1993 – 2023 ............................................................. 27 Graph 8. Annual Precipitation at Ellwood Mesa (Oct. 1 – Sept. 30) .............................. 29 Graph 9. Annual Climatic Water Deficit and 4-year Running Average .......................... 30 Graph 10. Annual Potential Evapotranspiration ............................................................ 31

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Habitat Analysis and Recommendations for Ellwood Mesa, City of Goleta v April 2023
List of Figures
Figure 1. General Location of Ellwood Mesa ................................................................... 6 Figure 2. Ellwood Mesa Project Boundary and Monarch Roosting Sites......................... 7 Figure 3. Ellwood Mesa Topography ............................................................................. 28 Figure 4. Dead Wood Volume Zones ............................................................................ 33 Figure 5. Classified Dead Wood - Overview .................................................................. 34 Figure 6. Classified Dead Wood - Ellwood Main ........................................................... 35 Figure 7. Classified Dead Wood - Ellwood West ........................................................... 36 Figure 8. Classified Dead Wood - Ellwood East ............................................................ 37 Figure 9. Classified Dead Wood - Ellwood North .......................................................... 38 Figure 10. Classified Dead Wood - Ellwood Ironbark .................................................... 39 Figure 11. Classified Dead Wood - Sandpiper .............................................................. 40 Figure 12. Classified Dead Wood - Ocean Meadows .................................................... 41 Figure 13. Monarch Observations - Ellwood Main ......................................................... 47 Figure 14. A Profile Through Ellwood Main: Anatomy of a Major Aggregation Site ....... 48 Figure 15. Hemiphotos from Three Years Between 1990 and 2021 at 60 and 70 meters into the Ellwood Main Grove ......................................................................................... 52 Figure 16. Graphic Assessment of canopy Gaps Observed in the Hemiphotos Each of Three Years .................................................................................................................. 53 Figure 17. Graphic Assessment of 2021 Directional Exposure at Three Locations 10 Meters Apart in the Cluster Zone .................................................................................. 53 Figure 18. Hemiphotos Transect Locations at Ellwood Main ......................................... 57 Figure 19. Visible sky .................................................................................................... 58 Figure 20. Directional exposure from 8 directions ......................................................... 59 Figure 21. Ellwood Main Core Hemiphoto Examples .................................................... 61 Figure 22. Insolation at Hemiphoto Sites ....................................................................... 62 Figure 23. Oblique LiDAR View from South with Example Hemiphoto .......................... 63 Figure 24. Oblique LiDAR view from southwest with Example Hemiphoto .................... 64 Figure 25. Oblique LiDAR View from N, with Two Hemiphotos along Gully .................. 65 Figure 26. Ellwood Main Vulnerabilities and Recommendations for Restoration .......... 66 Figure 27. Monarch Observations - Ellwood West ........................................................ 67 Figure 28A. Hemiphoto Transect Locations at Ellwood West ........................................ 70 Figure 28B. Example Hemiphotos at Ellwood West ...................................................... 70 Figure 29. Point maps of hemiphoto results at Ellwood West ....................................... 71 Figure 30. Oblique View Ellwood West Vulnerabilities .................................................. 72 Figure 31. Ellwood West Vulnerabilities and Recommendations for restoration ........... 73 Figure 32. Monarch Observations - Ellwood East ......................................................... 74 Althouse and Meade, Inc.

Habitat Analysis and Recommendations for Ellwood Mesa, City of Goleta vi April 2023
Figure 33A. Hemiphotos Transect Locations at Ellwood East ....................................... 78 Figure 33B. Example Hemiphotos for Ellwood East ...................................................... 79 Figure 34. Point maps of hemiphoto results at Ellwood East ........................................ 80 Figure 35. Ellwood East Vulnerabilities and Recommendations for Restoration ........... 81 Figure 36. Monarch Observations - Ellwood North ........................................................ 82 Figure 37A. Hemiphoto Transect Locations at Ellwood North Central ........................... 85 Figure 37B. Example Hemiphotos at Ellwood North Central ......................................... 85 Figure 38. Point maps of Hemiphoto results at Ellwood North-Central .......................... 86 Figure 39. Ellwood North- Central Vulnerabilities and recommendations for Restoration ...................................................................................................................................... 87 Figure 40A. Hemiphoto Transect Locations at Ellwood North-North ............................. 89 Figure 40B. Example Hemiphotos at Ellwood North-North ............................................ 90 Figure 41. Point Maps of Hemiphoto Results at Ellwood North-North ........................... 91 Figure 42. Monarch Observations - Ellwood Ironbark ................................................... 92 Figure 43A. Hemiphoto Transect Locations at Ellwood Ironbark ................................... 95 Figure 43B. Example Hemiphotos at Ellwood Ironbark ................................................. 95 Figure 44. Point Maps of Hemiphoto Results at Ellwood Ironbark ................................ 96 Figure 45. Ellwood Ironbark Recommendations ............................................................ 97 Figure 46. Ideal Double Wind Row Simulation ............................................................ 106 Figure 47. Double Row Layout .................................................................................... 107 Figure 48. Double Row Species Models ..................................................................... 108 Figure 49. Wind Modeling Scenarios........................................................................... 110 Figure 50. Existing Conditions Classified Stems ......................................................... 111 Figure 51. Above Ground Wind Conditions (30 ft) ....................................................... 112 Figure 52. Wind Conditions within Clustering Area ..................................................... 113 Figure 53. Vertical Profile of Wind Conditions at Viewing Area ................................... 114 Figure 54. Prescribed Tree Planting Areas - Ellwood Main ......................................... 116 Figure 55. Prescribed Tree Planting Areas - Ellwood West ......................................... 118 Figure 56. Prescribed Tree Planting Areas - Ellwood North ........................................ 120 Figure 57. Prescribed Tree Planting Areas - Ellwood East .......................................... 122 Figure 58. Prescribed Tree Planting Areas - Ellwood Ironbark .................................... 123 Figure 59. Prescribed Tree Planting Areas – Sandpiper ............................................. 124 Figure 60. Prescribed Tree Planting Areas - Ocean Meadows ................................... 126

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Habitat Analysis and Recommendations for Ellwood Mesa, City of Goleta vii April 2023
List of Appendices
Appendix A. Hemispherical Photography Methods
Appendix B. Wind Modelling Methods
Appendix C. Ellwood Mesa Monarch Counts 2015-2023
Appendix D. Monarch Butterfly Habitat on the Razor’s Edge Appendix E. Ellwood Wind Data
Appendix F. Dead Wood Removal and Monarch Butterfly Habitat Effects Appendix G. Ellwood Monarch Butterfly Habitat Characterization Report

Cover Page: Samples of the wind modeling scenarios, hemispherical photography, LiDAR tree classification, and monarch photo by Charis van der Heide.

Althouse and Meade, Inc.

Habitat Analysis and Recommendations for Ellwood Mesa, City of Goleta 1 April 2023
1 EXECUTIVE SUMMARY
The City of Goleta’s Ellwood Mesa /Sperling Preserve Open Space (Ellwood Mesa) is an important and widely recognized overwintering site for monarch butterflies (Danaus plexippus ).

Historically, tens and hundreds of thousands of monarch butterflies utilized the forest in the winter months for the overwintering phase of their migration. Recently, tree health and the condition of the overwintering habitat dramatically declined, and monarch roosting sites are threatened. The City of Goleta is committed to restoration and management of the Ellwood Mesa forest for the benefit of monarch butterflies and other sensitive wildlife.

Restoration of monarch overwintering habitat is challenging because of the time it takes for trees to establish and mature. Our common goal for the Ellwood Mesa /Sperling Preserve Open Space is to maximize the probability that monarchs will continue to use the forest of Ellwood Mesa as overwintering grounds for many decades into the future.

Our technical studies provide the basis for implementation of the Monarch Butterfly Habitat Management Plan (MBHMP) relative to monarch overwintering biology and habitat needs. We report on five years of studies. Our work is extensive and rigorous to ensure the best restoration effort can be implemented and to address concerns of community members.

In this report, we present the information about the history of the Ellwood Mesa and the influence of Ellwood Cooper in the original establishment of the eucal yptus tree forest, in Section 2. We summarize the historic land swap that preserved the land of Ellwood Mesa in perpetuity in Section 2.1.

In Section 3 , we explore the features of monarch butterfly overwintering habitat and biology.

Monarchs roost at overwintering sites along the California coast between October and March.

They seek wind-sheltered areas with a precise microclimate to support their survival through the winter and protect them from inclement weather. This habitat often has a dense wall of foliage from ground to canopy top with an open interior that receives a combination of full direct and dappled insolation (sunlight) and full shade . We discuss the importance of eucalyptus trees for the creation of this habitat in Section 3.2.

To select the best trees for our restoration efforts at Ellwood Mesa, w e examine and evaluate the characteristics of 29 species of native trees, eucalyptus trees and other non-native trees for their usefulness in monarch overwintering habitat and their usefulness i n restoration efforts in Section 3.3. Of the species considered for restoration at Ellwood Mesa, the following species are selected for their individual characteris tics to improve the forest for overwintering monarchs:
blue gum eucalyptus ( Eucalyptus globulus), karri (Eucalyptus diversicolor), toyon (Heteromeles arbutifolia), red ironbark ( Eucalyptus sideroxylon), coast live oak ( Quercus agrifolia), western sycamore ( Platanus racemosa), California bay laurel (Umbellularia californica ), and Fremont cottonwood (Populus fremontii).

The Ellwood Mesa is an urban forest dominated by a mix of eucalyptus species and native trees that holds six monarch overwintering sites . Monarch butterfly surveys and counts have been conducted at the Ellwood Mesa for many years. Peak population counts were recorded for Ellwood Main (Goleta Butterfly Grove) since 1989 and counts for the Western Monarch Thanksgiving Count began in 1997. We present this data in Section 4.1. A graph of total population of western monarchs and the total population in Santa Barbara County alongside the yearly Than ksgiving Counts at Ellwood Main in Section 4.2 shows how monarch numbers at Ellwood Main continue to decline relative to California’s population.

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Habitat Analysis and Recommendations for Ellwood Mesa, City of Goleta 2 April 2023
In Section 4.4 , we discuss the unprecedented drought in California during 2012- 2016 and the impact this had on the forest conditions at Ellwood Mesa. Forests exist in a dynamic equilibrium with available si te water by growing more in wetter years and dying back in dry periods. A sustainable density of trees at a site result from a dynamic process. During wet periods, Ellwood Mesa experiences high growth and high tree mortality during and after the drought. Loss of trees and canopy cover during the past decade opened Ellwood’s overwintering sites to increased wind exposure. At Ellwood Main, the depth of wind shelter diminished with mass mortality, leaving “thin green lines” of remaining live trees that provide very limited wind shelter. The forest’s critical redundancy in wind shelter disappeared. We illustrate the dramatic extent of tree mortality in a series of figures with LiDAR (laser imaging, detection, and ranging) data.

In Section 5, we examine the s tatus of monarch butterfly overwintering habitat at Ellwood Mesa and describe the myriad studies and research we conducted to better understand the habitat. We gathered data using direct observations, hemispherical photography, LiDAR, arboriculture and wind modeling. We examine d these data for each monarch overwintering location : Ellwood Mesa: Ellwood Main, Ellwood West, Ellwood East, Ellwood Nort h (North and Central), and Ellwood Ironbark. ( Detailed analysis for monarch locations at Sandpiper and Ocean Meadows will be included in a later update.) Our site -specific detailed analys es include descriptions of current conditions using observations from hemispherical photographs for the Visible Sky, proportion of potential annual insolation, and monthly potential direct insolation. Each site analysis includes a detailed map of vulnerabilities and a list of our site-specific recommendations for habitat restoration that would reduce identified vulnerabilities and improve habitat conditions.

In Section 6, we present our recommendations for restoration of Ellwood Mesa as a whole. The first step is to perform deferred maintenance of the trees with strategic fuel management , surgically remove dead standing and downed trees, and clear debris to prepare planting areas.

The second step is to restore wind protection around monarch roosting locations: protect existing trees (Section 6.2.1), instal l our recommended double wind row design (Section 6.2.3), and implement planting areas in prescribed areas (Section 6.2.1 to 6.2.10). Section 6.2.4, present s results of the wind modeling on our planting designs at Ellwood Main t hat illustrate expected success of improved habitat for roosting monarchs.

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Habitat Analysis and Recommendations for Ellwood Mesa, City of Goleta 3 April 2023
2 INTRODUCTION
Monarch butterfly migration is an amazing natural phenomenon worthy of conservation. Every year, monarchs migrate in massive numbers to overwintering sites in California to wait out the winter months. Overwintering habitat in coastal California is critical to this migration, providing the genetic source for the following year’s migratory population. The Ci ty of Goleta’s Ellwood Mesa/Sperling Preserve Open Space (Ellwood Mesa) is an important and widely recognized overwintering site where visitors delight at the sight of monarchs aggregating in the eucalyptus groves. Until recently, Ellwood Mesa supported many thousand monarchs that enveloped and draped over eucalyptus branches through winter months. Relatively rapid loss of eucalyptus trees reduced wind buffers and live branches necessary to protect overwintering monarch butterflies.

Overwintering sites are under thre at from a variety of sources including ur banization, fire, drought and pests . Historically, Santa Barbara County provides an important area for overwintering monarchs with approximately 25 % of the overwintering sites in California. The Ellwood Main (Monarch Butterfly Grove) has attracted some of the highest monarch counts in the state. Unfortunately, the quality of the habitat at Ellwood Main is declining. Before 2012, the monarch population at Ellwood Main fluctuated between 2 – 25% of the western population during the Thanksgiving Count with an average of 11%. Starting in 2013, the Ellwood Main portion of the western monarch population fell to 1% and has fluctuated between 0 – 2.3% with an average of 1% (Xerces Society 2023).

Blue gum ( Eucalyptus globulus) trees comprise the dominant tree taxon for Ellwood Mesa ’s monarch butterfly habitat with s ix historic monarch overwintering locations—Ellwood Main being the largest and most well -known (Figure 1 and Figure 2). By 2016, the b lue gums on Ellwood Mesa began dying off in massive numbers . This die -off creates a substantial risk for fire, injury to park goers, and degrad ed monarch clustering habitat. As roosting and wind buffer trees died, monarchs changed their roosting behavior , and in 2016 monarchs aggregated in higher numbers at sites adjacent to Ellwood Main (see monarch numbers Section 4).

The 2019 Monarch Butterfly Habitat Management Plan for Ellwood Mesa (MBHMP ; Rincon) outlines 22 Programs to guide the maintenance and management of th e monarch butterfly overwintering habitat on Ellwood Mesa. Recommended actions in the MBHMP include wildfire fuels reduction, tree maintenance, tree and nectar plant installation, and continued monitoring of monarch numbers and habitat health.

In response to public concerns about how the plan would be implemented, we conducted a series of technical and scientific studies of Ellwood Mesa eucalyptus groves . The purpose of the studies is to better understand monarch and wildlife habitat, inform forest management, and address habitat risks associated with proposed actions. Results of these studies detail conditions, past and present, in the Ellwood eucalyptus grove to guide restoration and habitat enhancement for monarch butterflies now and for decades to come.

Monarch restoration is particularly challenging because of the long -time horizons involved with tree growth . This technical report summarizes our investigations and recommendations. Our work is extensive and rigorous to ensure the best restoration effort can be implemented and to address concerns of community members and to facilitate timely recovery of monarch aggregation sites.

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Habitat Analysis and Recommendations for Ellwood Mesa, City of Goleta 4 April 2023
Our common goal with advocates of Ellwood Mesa /Sperling Preserve Open Space is to maximize the probability that monarchs will continue to use t he forest of Ellwood Mesa as overwintering grounds for many decades into the future. We recognize that this goal is challenging due to tree growth rates, and the time required to provide optimal habitat benefits.

2.1 History of Ellwood Mesa – 1800s to Present
Ellwood Mesa was first planted with 150,000 blue gum eucalyptus trees in 1876 by Ellwood Cooper (Farmer 2013). Since World War II, Ellwood Mesa has been managed as a wood lot by Mr. Cooper, hi s horticultural successors, and by Goleta residents. Our earliest records of monarch butterflies using Ellwood Mesa as aggregation habitat is from the 1960’s. Residents shared stories of riding horses during aggregation season and their horses would be covered by monarch butterflies seeking the nutrient-rich sweat of the horses.

The Ellwood Mesa is now managed by the City of Goleta after an innovative land swap and fund-raising effort in 2005 that preserved the land in perpetuity. The City of Goleta was incorporated in February 2002 and fundraising for the land swap began in January 2003 by the Trust for Public Lands and Friends of Ellwood Coast. T he Ellwood-Devereux Coast Open Space and Habitat Management Plan was drafted by August 2003. The Trust for Public Lands achieved the fund-raising goal of $20.4 million in December 2004. Meanwhile, the Comstock Homes and City coastal access parking lot submitted their application to the California Coastal Commission in August 2004 and their appl ication was approved in January 2005, providing opportunity to conserve most of the mesa’s monarch butterfly habitat . In February 2005, the City of Goleta closed escrow on the ownership of Ellwood Mesa.

After acquisition, the City of Goleta implemented a hands-off approach to forest management of the eucalyptus grove at Ellwood Mesa. The City adopted the Ellwood- Devereux Coast Open Space and Habitat Management Plan (OSHMP) in 2004 that focused on broad management goals for maintaining the habitat for the monarch butterflies. For years, the City’s opinion was that the forest is a natural and self-sustaining habitat that should be left alone.

The City hired Daniel E. Meade, Ph.D. with Althouse & Meade, Inc in 2010 to develop a Monarch Butterfly Habitat Man agement Plan for Ellwood Mesa (MBHMP) . Several revisions were drafted while t he needs of the habitat and the status of the trees continued to change and require additional sections in the MBHMP to address the growing list of issues.

Unfortunately, while the MBHMP was still under development, the region and state of California experienced an extreme 5 -year drought (2012- 2016). The drought led to widespread forest dieback that degraded monarch butterfly habitat throughout the grove, a condition emphasized by a dramatic decline of monarch population numbers across the six aggregation sites on the mesa.

In response to the declining tree health, a tree health survey was conducted in 2017 which identified over 1,400 standing dead and dying trees in the eucalyptu s forest at Ellwood Mesa.

The Public Works Director suggested removing these trees immediately with an emergency permit. This proposal was met with harsh public backlash based on concerns about large -scale tree removal in and around the aggregation sites without the MBHMP in place to protect and restore monarch habitat. The City Council responded to community concerns by approving the removal of only those trees that pose d a threat to public safety and directing the completion of the MBHMP. The City then prepared several in -depth scientific studies to understand the forest Althouse and Meade, Inc.

Habitat Analysis and Recommendations for Ellwood Mesa, City of Goleta 5 April 2023
habitat. The goal of the technical investigations was to understand grove complexity and recommend management actions that would protect and restore forest elements important to monarch butterflies.

The City received a state grant for $3.9 million for the implementation of the MBHMP in 2018.

The MBHMP was adopted by the City of Goleta in March 2019. From 2019 until the present, the City is in the process of preparing permits and design plans for the approval from the many agencies with jurisdiction over the Ellwood Mesa land and habitat.

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Habitat Analysis and Recommendations for Ellwood Mesa, City of Goleta 8 April 2023
3 MONARCH BUTTERFLY OVERWINTERING HABITAT AND

BIOLOGY
Overwintering monarchs are butterflies that migrate from inland summer breeding sites in Western North America in search of groves of trees in mild coastal climates where freezes rarely occur for the winter (Pelton et al. 2016, Xerces Society 2017a ). Within those groves, they seek wind-sheltered areas which require a dense wall of foliage from ground to canopy top in the windward direction or sheltering hillslopes. Overwintering monarchs prefer microsites that receive a combination of full direct and dappled insolation (sunlight) for basking, but also have shaded areas for resting at cool temperatures. Large areas of deep shade are rarely occupied for long. Forests can be either too open, or too dense for cluster sites (Weiss et al. 1991).

Monarchs adjust their micro-distribution among trees and branches as winds and insolation shift, and will completely abandon sites if the microclimate, primarily wind, exceeds their tolerance.

Winds greater than 2 m/s (5.2 mph) at ground level appear to be a limit for cluster sites (Leong 1990, Leong et al. 1991, Leong 2016). When weather is mild, monarchs will use a wide variety of sites and have an expansive micro -distribution. When storms approach, with the strongest winds from the SE, monarchs concentrate in the most SE -wind-sheltered spots. As the front passes, winds shift though S, SW, W, and NW and monarchs may readjust their cluster sites when they can fly again. But strong winds are possible from all directions, including dry N, NE, and E winds, so wind shelter over the entire 360° circle needs to be available somewhere in a site. It takes a delicate balance b etween dense canopy cover and more open areas to attract and retain monarchs, as they dynamically “crowd source the microclimate.” Dense perimeter trees and/or sheltering topography for wind protection in all directions, with an interior canopy gap for a varied insolation environment, is an ideal habitat configuration. Some viewers fondly consider this a “cathedral” arrangement of forest canopy surrounding a central opening.

3.1 Features of Overwintering Monarch Habitat
Across the monarchs’ overwintering range there are similari ties in their preferred habitat. K ey elements of overwintering monarch habitat include:
1) Location within a mild coastal climate, where freezing is unlikely, and high temperatures are moderate so that monarchs can conserve their fat reserves and remain in reproductive diapause. These conditions are found along the immediate coast from Mendocino to Baja and near San Francisco Bay.
2) Trees on which to form clusters. Monarchs cluster on many tree species ranging from sparse Torrey pines, various eucalyptus species, dense live oaks, to broadleaf sycamores. 3) Most importantly, wind shelter from many, if not all directions. Monarchs will leave sites when the wind at ground level exceeds <2 m/s (5.2 mph, Leong 1990, Leong et al. 1991, Leong 2016). Topography can contribute to wind shelter, in addition to the key role of trees.
4) Canopy gaps that allow sunlight (insolation) into the grove. A mix of full sun for several hours, dappled light, and deeper shade within a small area is ideal. 5) Many sites, but not all, have a “cathedral” structure, with a large empty space above a clearing, often created by a stream or gully surrounded by tall trees. Monarchs can fly Althouse and Meade, Inc.

Habitat Analysis and Recommendations for Ellwood Mesa, City of Goleta 9 April 2023
freely in the open interior space and the surrounding trees provide a varied insolation environment within short distances.

A permanent overwintering site supports monarchs through the entire October -March overwintering season and must have all these elements within a compact area to do so. A transitory or autumnal site supports monarchs for a short time at the start of the season (October, November, December). Transitory sites often have several of these elements but are lacking key elements to offer the full spectrum of protection for monarchs through the entire overwintering season.

Monarchs are opportunistic creatures. The migrating population finds overwintering sites by exploring almost every grove of trees along the coast at some point during the migration. Early in the season when weather is mild, butterflies are widely scattered. As storms blow into California, the monarchs remain at sites that provide suitable wind shelter and insolation and leave sites that do not. As they fly from grove to grove, they use the presence of other monarch s as a cue that a site is suitable – they are very skilled at finding each other. The net result is that they dynamically accumulate at the suitable sites and abandon unsuitable sites as seasonal weather proceeds.

The same basic mechanism works within a grove as monarchs choose microsites for clustering.

Every cluster is in a dynamic equilibrium between monarchs staying, leaving, and arriving.

Monarchs will stay in place if conditions are suitable for their immediate physiological state.

Sometimes clusters break up almost instantaneously if a burst of wind occurs during good flight conditions. Other times, a wind shift will cause butterflies to move. High winds can drive monarchs completely from overwintering groves. At night, or if it is too cool and/or cloudy for flight, then high winds can dislodge monarchs, who fall to the ground where they are vulnerable to predation and perhaps freezing. “Sunburst” behavior occurs when sunlight strikes a cluster and many monarchs warm and take flight. M onarchs also take flight to find nectar, water, or mates depending on their physiological needs affected by warm temperatures and the time of the season.

When a monarch decides where to land, the presence of other clustering monarchs is the best cue that it is a good s ite. The individual decisions of hundreds or thousands of butterflies in an overwintering aggregation create a dynamic micro -distribution as they “crowdsource the microclimate.”
The forest canopy filters outside weather according to its fine scale structur e. Trees attenuate wind according to foliage density, and multiple layers of branches and leaves can create calm conditions even during storm winds. But small gaps and wind tunnels can allow wind to exceed critical thresholds in the interior of the grove . The cumulative loss of trees and branches - whether from drought, windfall, pests, disease or human cutting - can open a formerly wind sheltered stand or weaken multiple lines of shelter and increase vulnerability to further loss.

3.2 The Importance of Eucalyptus Trees
Eucalyptus trees are important to monarch overwintering sites because they grow taller than most native trees and provide suitable branching and canopy structure to sustain overwintering monarch aggregations (Meade et al . 2018, Meade et al . 2019, Meade et al. 2023, Griffiths and Villablanca 2015, Longcore, Rich, and Weiss 2020). Thi s technical report supports and Althouse and Meade, Inc.

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encourages the presence and growth of eucalyptus trees for the benefit of overwintering monarchs.

Blue gum eucalyptus trees were introduced to California in the late 1800’s from Tasmania and have since naturalized throughout the state. The intensity of the invasiveness of this species is under much debate. Blue gums can exhibit invasiveness and negative environmental impacts in some areas, but these are poorly represented in scientific journals. Thus, in 2015, California Invasive Plant Council (Cal-IPC) conducted a review of the literature and concluded that the data warranted the blue gum be resigned as “limited” invasive status from the previous “moderate” status (Wolf and Johnson 2014, Wolf and DiTomaso 2016, Cal-IPC 2023). Spread of blue gums is typically limited to expansion along the periphery of an existing population, especially in coastal areas in riparian habitat (Lopez 2015). In this case, limited status represents the widespread distribution of blue gums throughout the state and identifies that significant ecological impacts are limited to specific regions and there is minimal or no impact in other areas (Cal-IPC 2023). Wolf and DiTomaso note that blue gums alter fire regime by accumulation o f significantly higher fuel loads than native woodlands (Wolf and DiTomaso 2016, CAL -IPC 2015).

Blue gum r esprouts readily when cut, grazed, or burned. It coppices readily from stumps of all sizes and ages when the tree is damaged. If the tree is cut dow n, lignotubers become active and each bud produces a shoot bearing foliage. Such shoots are commonly known as "sucker growth" or coppice shoots, and a large number are usually formed (Skolmen and Ledig 1990, Bean and Russo 2014).

Contrary to popular opinion, there is no scientific evidence that blue gum eucalyptus trees produce an allelopathic effect to inhibit the growth of understory vegetation (Nelson et al. 2016).

Nelson’s study conducted at California Polytechnic State University, showed that germinati on and early seedling growth of five California native plants were not inhibited by blue gum eucalyptus chemical extracts. It is likely that any noticeable decrease of understory vegetation under eucalyptus trees is caused by the accumulation of fallen leaves, bark, and branches , and low rate of decomposition. Many native plants are regularly observed growing and thriving in gaps under eucalyptus tree canopies at monarch overwintering sites throughout the state.

Additionally, eucalyptus trees support a diversity of fauna. A 2015 study of eucalyptus woodlands in central California found that non-native eucalyptus and native oak groves had very similar bird community composition, species richness, and abundance (Fork et al., 2015). The study also reported s imilar abundance and richness of non- natives in eucalyptus versus oak woodlands and thus no evidence of ‘‘invasional meltdown.” Invasional meltdown was initially described in 1999 as that case where invasive species foster the spread and establishment of other non-native and/or invasive species (Simberloff and Von Holle 1999).

3.3 Tree Species Consideration and Selection
Overwintering monarchs have been observed roosting in many different species of trees and shrubs and the species of tree vary across their overwintering range in California (Xerces Society 2023). The paper Monarch Butterfly Habitat on the Razor’s Edge - Native and Non- native Vegetation in California and Occam’s Razor (2023) examined the characteristics of 29 species and their usefulness in monarch overwintering restoration efforts in Santa Barbara County (included in Appendix D).

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Of the 130 overwintering sites in Santa Barbara County , 96 are dominated by eucalyptus (2 of which are eucalyptus and non- natives), 10 are mixed eucalyptus and California native trees, 9 sites are eucalyptus with local California native trees, 9 sites are California native trees, and 6 sites are local Santa Barbara County native trees (Meade et al. 2023). Eucalyptus trees are either the primary vegetation, or a significant contributor to the creation of monarch butterfly aggregation sites in Santa Barbara County in 88% percent of known or potential aggregation sites.

The Meade et al. 2023 paper evaluates native trees, eucalyptus species, and several other non- native trees that all have at least one record of monarchs using them a s an aggregation tree (Xerces Society 2023) . The paper concludes that several species of eucalyptus trees are the reliable choice for restoration when the goal is creating protective monarch butterfly aggregation habitat. Choices for native trees in Santa Barbara County are limited and are not sufficient for forming the typical structure of a monarch butterfly aggregation site with a flight area encircled by substantial, tall trees that filter light, buffer wind and ameliorate temperatures and humidity (Wenner 1987, Leong 1990, Weiss et al. 1991, Calvert 1991, Meade 1999, Leong 2016). The structures of a eucalyptus grove generally provide better protection from wind and rain for a longer period through the overwintering season than sycamore, oak, cottonwood, and willow habitats.

We’ve given these 29 tree species a rank based on the tree rating analysis that was conducted in the Meade et al. 2023 paper. This ranking system assigns Very High, High and Moderate labels to the tree species in order of their rating. This ranking relates to their usefulness in the restoration efforts of monarch butterfly overwintering habitat, all things considered.

The three highest ranked trees from the evaluation are three eucalyptus tree species and are given a Very High ranking label. These three trees are commonly found at aggregation sites and are naturalized in California: red iron bark gum (Eucalyptus sideroxylon), blue gum (E. globulus), and r iver red gum (E. camaldulensis). The next grouping of ranked trees are given a High ranking label and are six species that create suitable aggregation habitat for the duration of the overwintering season: lemon scented gum (Corymbia citriodora), red flowering gum (Corymbia ficifolia), t oyon (Heteromeles arbutifolia) , karri (E. diversicolor) , Monterey cypress (Hesperocyparis macrocarpa), and sugar gum (Eucalyptus cladocalyx). All the trees with lower ratings are given the ranking label of Moderate and would provide additional habitat benefits by increasing diversity and wind shelter to an aggregation grove in associat ion with the nine higher ranked species: B ishop pine (Pinus muricata), silver wattle (Acacia dealbata), Canary Island pine (Pinus canariensi s), holly-leaf cherry (Prunus ilicifolia ssp. ilicifolia), Monterey pine (Pinus radiata) , Torrey pine (Pinus torreyana ssp. torreyana) , coast redwood (Sequoia sempervirens), evergreen ash (Fraxinus uhdei) , cork oak (Quercus suber) , blackwood (Acacia melanoxylon), California bay laurel (Umbellularia californica) , western sycamore (Platanus racemosa), Fremont cottonwood (Populus fremontii), coast live oak (Quercus agrifolia), grand fir (Abies grandis) , arroyo willow (Salix lasiolepis), Douglas fir (Pseudotsuga menziesii ), monkey-puzzle (Araucaria Araucana) , dawn redwood (Metasequoia glyptostroboides) , and black cottonwood (Populus trichocarpa).

We explore the characteristics of f ive Eucalyptus species in Table 1 and list their rank (from Section 3.3), propensity to spread into wildlands ( Invasiveness), distribution in Australia from tropical to Mediterranean (Natural Habitat), and on their height . The species include red river gum ( E. camaldulensis ), sugar gum ( E. cladocalyx), karri (E. diversicolor ), blue gum (E.

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globulus), and red ironbark gum ( E. sideroxylon). In Table 2, we list the leaf characteristics of these same five eucalyptus species.

TABLE 1. RANKING OF FIVE EUCALYPTUS SPECIES
Eucalyptus Species Rank Invasive/ Naturalized
Lignotuber1 Natural Habitat Height &
Leaves
Red River Gum
(E. camaldulensis)

(Photo UFEI 2023)
Very High Invasive.

Lignotuber sometimes present
Near seasonal
water <25 m
Sugar Gum (E. cladocalyx)

(photo EUCID 2020)
High
Naturalized.

No lignotuber—has epicormic
buds2 on stem
Mediterranean
(S. Australia) 10 – 20 m

1 Lignotuber is a basal woody swelling that holds a large number of dormant buds in a protected position along with carbohydrates and other nutrients (Bortoloto et al. 2020). 2 Epicormic bud will form shoots arising spontaneously from adventitious or dormant buds on stems or branches of woody plants, often following exposure to increased light levels or fire (Helms 1998).

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Eucalyptus Species Rank Invasive/ Naturalized
Lignotuber1 Natural Habitat Height &
Leaves
Karri (E. diversicolor)

(Photo UFEI 2023)
High
Not Naturalized.

No lignotuber—has epicormic
buds on stem
Mediterranean
(SW of
Western
Australia)
90 m
Blue Gum (E. globulus)

(Photo UFEI 2023)
Very high Very naturalized.

Forms lignotuber.

Southeastern
Australia with
uniform
climate/rainfall
<60 m
Red Ironbark Gum
(E. sideroxylon)

(Photo UFEI 2023)
Very high
Reproduces occasionally
(uncommon naturalized).

Forms lignotuber.

Eastern
Australia (wet
summer)
7 – 25 m

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TABLE 2. LEAF CHARACTERISTICS OF FIVE EUCALYPTUS SPECIES Eucalyptus Species Leaf Characteristics (EUCLID 2020)
Red River Gum
(E. camaldulensis)

© N Parks Flora&FaunaWeb
alternate, petiole 0.7-3 cm long; blade lanceolate or broadly so or falcate, 8-23 cm long, 1-4.2 cm wide, base tapering to petiole, concolorous, dull, bluish or blue-green, rarely green, or slightly glaucous, side-veins about 45° or more to midrib, venation usually sparsely to moderately reticulate, intramarginal vein parallel to and well removed from margin, oil glands numerous, island3, rarely obscure. [leaf description for ssp. arida]
Sugar Gum
(E. cladocalyx)

(Photo by John Rawlings)
alternate, petiole 0.9–2.7 cm long; blade slightly falcate to lanceolate, 6.5–17 cm long, 1.2–4 cm wide, base usually tapering to petiole, strongly discolorous, glossy, darker green on upper side, paler below, side-veins at an acute or wider angle, densely to very densely reticulate, intramarginal vein parallel to and well removed from margin, oil glands small, obscure.

Karri (E. diversicolor)

alternate, petioles 1–2 cm long; blade lanceolate, 7–13.5 cm long,

1.5–3.7 cm wide, base tapering or oblique, margin entire or subcrenulate, apex a drip-tip, discolorous, dark green and glossy above, paler below, penniveined, reticulation dense, intramarginal vein close to margin, oil glands mostly island, yellow.

3 “island” in this context means the leaf oil glands occur in the cent er of the smallest unreticulated areas (areole) of the leaf, as opposed to intersectional oil glands that occur at the intersections of the veinlets.

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Eucalyptus Species Leaf Characteristics (EUCLID 2020)
(Photo from lucidcentral.org)
Blue Gum (E. globulus)

From Trees of Stanford and
Environs,
Ronald Bracewell
alternate, petiole 2–3.5 cm long; blade lanceolate to falcate, 12–30 cm long, 1.7–3 cm wide, glossy, green, side-veins greater than 45° to midrib, densely reticulate, intramarginal vein parallel to and well removed from margin, oil glands island and intersectional.

Red Iron Bark Gum
(E. sideroxylon)

© Ron Vanderhoff
alternate, petiole 0.5–2.5 cm long; blade lanceolate, 5–14 cm long, 1–4 cm wide, base tapering to petiole, concolorous, dull, green to blue-green, grey-green, grey or glaucous, side-veins at an acute or wider angle to midrib, moderately to densely reticulate, intramarginal vein parallel to and just within margin or well removed from it, oil glands island and intersectional.

3.4 Tree Species for Restoration of Ellwood Mesa
Of the species considered for restoration at Ellwood Mesa, the following species have risen to the top of the list and are selected for their ind ividual characteristics to improve the forest for overwintering monarchs:

Blue gum (Eucalyptus globulus)
The blue gum eucalyptus (Eucalyptus globulus) is an evergreen tree with a m ax height of 50 m (165 ft). This species is well documented to pro vide suitable overwintering habitat for monarch butterflies in California (Meade et al . 2018, 2023). This species is native to the wet regions of Tasmania, and it has a medium water use rating ( UFEI 2023). The blue gum has week branch strength and sheds bark and branches generously. Therefore, a healthy and sustainable blue gum forests require regular maintenance and management.

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The blue gum eucalyptus tree is well established in the forest on Ellwood Mesa and functions as the dominant tree in the structure of the monarch aggregation habitat. Although the blue gum trees have experienced die-off from the extreme drought in the forest at higher rates compared to other eucalyptus species on the mesa, the species remains an extremely valuable element of the forest for monarch butterflies.

We recommend protecting and supporting the live blue gum trees, encouraging blue gum saplings and resprouts to flourish in the forest , and adding additional plantings of this species as the need arises to improve coverage in the monarch roost sites. In Phase 1 of t he implementation of the MBHMP, blue gum trees will be planted to replaced dead and dying monarch roost trees in the monarch aggregation sites on Ellwood Mesa. See Section 6.2 for planting details.

Karri (Eucalyptus diversicolor)
The karri (Eucalyptus diversicolor) tree is native to Southwestern Western Australia and is often used as a windbreak and shade tree (Photo 1). It is the tallest tree in Western Australia with a max height of 64 m (210 ft). Its leaves are spear -shaped and similar to the sickle shape of the blue gum. The karri tree has medium branch strength and smooth bark that sheds less than blue gum trees. The karri tree has a low water use rating , compared with the medium of the blue gum, meaning that it is more tolerant to drought stress (UFEI 2023).

Photo 1. Karri. EUCLID 2020.

The karri tree is known to occur in the Goleta/Santa Barbara area. The book Trees of Santa Barbara" documents the occurrence of karri trees “ along the west side of Sheffield Drive north of the intersection with San Leandro Lane." (p. 282 in Muller et al. 2005). This location is at the base of Ortega Hill which is a known monarch overwintering site. Karri trees in this location are part of the canopy of eucalyptus trees that may influence the wind protection to the Ortega Hill site, this is also known as the shelter zone for the site.

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Of the Eucalyptus taxa found in aggregation sites, the karri tree is the only one considered not naturalized or is not found as a garden escape in California. The other four species in Table 1 are known to reseed into natural lands. The Australian Native Plants Society does not consider Karri to be an invasive r isk in the wild in Australia (ANPSA 2023). Dr. Matt Ritter did not even consider it for inclusion in the Manual of California Vegetation because it is not found as a garden escape in California (Jepson Flora Project 2023; Ritter and Yost 2009; personal communication 2/10/2023 with LynneDee Althouse ). It is Southwestern Australia’s tallest tree with smooth, deciduous bark that changes color as it ages (EUCLID 2020).

Based on its characteristics and expert opinion, we are including the karri tree in the planting plans and restoration actions at Ellw ood Mesa. While the blue gum is intended to remain the dominant tree at the monarch roost sites, the karri tree will strengthen the forest by adding diversity and structure. Our intention is to build a more drought resilient forest with the addition of the karri tree. See Section 6.2 for planting details.

Toyon (Heteromeles arbutifolia)
Toyon (Heteromeles arbutifolia) is an evergreen shrub and native the western part of California and the Sierra foothills. This perennial shrub is drought-tolerant and common in coastal sage scrub and chaparral plant communit ies (CNPS 2023). Toyon grows well in the understory of eucalyptus forests and is present on the Ellwood Mesa, see Photo 2.

Toyon shrubs grow to a mature height of 1.8 to 9 m ( 6 to 30 ft) (UFEI 2023). The evergreen and perennial characteristics of this species make it well suited to provide wind shelter to the monarch aggregation habitats. Monarchs are known to roost on this species in Santa Barbara County (Xerces Society 2023, Meade et al. 2023).

We are proposing to plant toyon around the existing monarch overwintering sites to strengthen the wind shelter zones and build a more drought res ilient forest. See Section 6.2 for planting details.

Photo 2. Toyon shrub well established outside of eucalyptus grove at Ellwood Mesa.

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Red ironbark (Eucalyptus sideroxylon)
Red ironbark ( Eucalyptus sideroxylon) trees are the dominant species in the southern section of the Ellwood North area and some are growing on the eastern edge of Ellwood West along Santa Barbara Shores access road, see on Figure 2.

Red ironbark is native to Eastern Australia and has max tree height of 27 m (90 ft). Its leaves are spear-shaped and si milar to the sickle shape of the blue gum. The red ironba rk has medium branch strength and furrowed black or red bark that does not shed like blue gum trees. This tree has a low water use rating, compared with the medium of the blue gum, meaning that it is more tolerant to drought stress (UFEI 2023). Evidence of its higher drought tolerance was apparent during the 2012- 2016 drought; no red ironbark trees succumbed to the drought conditions at Ellwood Mesa while many blue gum trees are drought stressed, as shown in Photo 3.

Monarchs are known to roost on this species in Santa Barbara County (Xerces Society 2023, Meade et al. 2018 and 2023). The red ironbark tree has pink to red flowers which bloom in fall, winter, spring and offers a nectar source for the overwintering monarchs (UFEI 2023).

We are proposing to plant red ironbark around the existing monarch overwintering sites to strengthen the wind shelter zones and build a more drought resilient forest. See Section 6.2 for planting details.

Photo 3. Red ironbark trees in the southern section of Ellwood North are green and healthy (on the right) while the blue gum trees (on the left) are drought stressed.

Coast live oak (Quercus agrifolia)
The coast live oak is native to central and southern California and is present in the Ellwood Mesa forest in the under and middle story among the eucalyptus trees. This evergreen tree has high wildlife value and is important to the California landscape. This oak has a max tree height of 21

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m (70 ft) and given enough time this tree can develop a large spreading canopy often wider that its height ( UFEI 2023). Coast live oak has a low water use rating and strong branch strength (UFEI 2023).

Monarchs are known to roost on this species in Santa Barbara County (Xerces Society 2023, Meade et al. 2018 and 2023). We are proposing planting this tree in the wind shelter zone on the Ellwood Mesa to improve the monarch habitat and add wildlife value.

Western sycamore (Platanus racemosa)
The western sycamore is a deciduous, California native riparian tree (UFEI 2023). This species is common along creeks and drainages in California and is present along Devereux Creek and other drainages on the Ellwood Mesa. This tree has a maximum height of 24 m (80 ft) and can have a canopy width between 6-15 m (20-50 ft). The western sycamore has a high water use rating and is tolerant of extreme heat and wind with medium branch strength (UFEI 2023).

Monarchs are known to roost on this species in Santa Barbara County (Xerces Society 2023, Meade et al. 2018 and 2023). Its deciduous nature causes this tree to offer decreased wind protection for monarchs by December or January as its leaves fall . This species is proposed for planting near Ellwood Main along Dever eux Creek to close the wind vulnerability from the north.

California bay laurel (Umbellularia californica)
California bay laurel (Umbellularia californica) has a native range from southwestern Oregon to Baja California (UFEI 2023). It is an evergreen tree and is commonly associated riparian habitats, oak woodlands , and mixed -evergreen forests. This species has a maximum height of

22.8 m (75 ft) and can be as wide as it is tall (UFEI 2023).

Monarchs are known to roost on this species in Santa Barbara County (Xerces Society 2023, Meade et al. 2018 and 2023). This species is proposed for planting near Ellwood Main along Devereux Creek to close the wind vulnerability from the north.

Fremont Cottonwood (Populus fremontii)
Fremont Cottonwood ( Populus fremontii) is a deciduous, California native riparian tree (UFEI 2023). This tree has a maximum height of 24 m (80 ft) and can have a canopy width between 9- 15 m (30-50 ft). This species has a high water use rating and weak branch strength (UFEI 2023).

Monarchs are known to roost on this species in Santa Barbara County (Xerces Society 2023, Meade et al. 2018 and 2023) . This species is proposed for planting near Ellwood Main along Devereux Creek to close the wind vulnerability from the north.

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4 ELLWOOD MESA BACKGROUND
The Ellwood Mesa is an urban forest dominated by a mix of eucalyptus species and native trees.

The eucalyptus forest on the Ellwood Mesa holds six monarch overwintering sites (Calvert 1991, Nagano and Sakai 1987, Meade 1999). These overwintering sites are scattered through the forest, as shown on Figure 2.

4.1 Monarchs at Ellwood Mesa
Monarch butterfly surveys and counts have been conducted at the Ellwood Mesa for many ye ars.

Peak population counts were recorded for Ellwood Main (Goleta Butterfly Grove) since 1989 and counts for the Western Monarch Thanksgiving Count began in 1997. Monarch aggregation locations are shown on Figure 2. The counts follow the Xerces Society’s protocol for estimating number of monarch butterflies, the Step -by-Step Western Monarch Thanksgiving Count Monitoring Guide (The Xerces Society 2017b).

The monarch population at Ellwood Main (Goleta Butterfly Grove) fluctuates greatly from year to year, as shown in Graph 1. The highest monarch population at Ellwood Main was recorded at 47,510 in 2011 and the lowest was 5 in 2020. These fluctuations are natural and expected for insect populations (Xerces Society 2021).

We assume that monarch butterflies vote on suitable overwintering habitat with their presence.

Monarch butterflies select preferable and suitable habitat and show us these locations with their numbers. There is a direct relationship between suitable habitat and monarch counts. In a year with a decent population abundance to span the entire distribution of overwi ntering sites, we can assume that the sites with suitable and protective habitat will have higher monarch butterfly counts relative to those sites with less suitable and poorly protective habitat. Thusly, the decline of habitat quality can be shown in the relative decline of monarch numbers at a site over time.

4.2 Ellwood Mesa Monarchs Relative to the Western Population When we graph the total population of western monarchs and the total population in Santa Barbara County alongside the yearly Thanksgiving Counts at Ellwood Main, we begin to see how the monarch numbers at Ellwood Main are declining relative to the larger populations, and thusly we can see the decline of the habitat at Ellwood Main. Graph 2 shows these population numbers on the logarithmic base 10 scale. Logarithmic scale is helpful for visualizing the growth and decline in populations and natural systems. In Graph 2, we can see how the total populations of western monarchs in California and Santa Barbara County are closely linked with the monarch numbers at Ellwood Main and the fluctuations are parallel from 1997 until 2010. In 2011, the monarch numbers at Ellwood Main start to decline while the western and Santa Barbara County populations follow a similar upwards and fluctuating trend. The monarch numbers at Ellwood decline drastically in the years 2013 and 2016 which t he populations of western monarchs and the Santa Barbara County showed an increase. One explanation for this incongruity is the decline of the habitat quality because of the drought discussed in Section 4.4.

In addition to the Western Monarch Thanksgiving Counts, the City of Goleta conducts monarch counts at the six known aggregation sites every two weeks during the overwintering period, October 1st through March 15th. In 2019, the city included habitat -wide surveys for monarch s potentially roosting outside of the six known sites and two sites were added in 2019 after this Althouse and Meade, Inc.

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effort. These data show us how the monarchs are utilizing the sites every two weeks and we can infer habitat value from this numbers. In the 2015 -2016 season ( Graph 3), the monarchs maintained a consistent presence at Ellwood Main thr ough the season and remained at Ellwood Main until mid -February. In the 2021- 2022 season ( Graph 4), the monarchs were present at Ellwood East in greater numbers than at Ellwood Main and my mid-January they had abandoned Ellwood Main in favor of Ellwood East. In the 2022- 2023 season ( Graph 5), we see that the monarchs were present at Ellwood Main and Ellwood East, and they had abandoned both sites by mid-January, likely because of the severe storms that occurred along the central coast in late December 2022 and early January 2023. This shows that the Ellwood Main habitat has declined to the point where it is no longer suitable habitat to protect monarchs from severe storms through January.

GRAPH 1. PEAK MONARCH POPULATION AT ELLWOOD MAIN FROM 1989 TO 2022 Data from Althouse and Meade Inc and Rincon Consultants Inc.

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GRAPH 2. TOTALS OF WESTERN MONARCH POPULATION, SANTA BARBARA COUNTY

MONARCH POPULATION, AND MONARCHS AT ELLWOOD MAIN IN LOGARITHMIC SCALE Data source: Xerces Society for Invertebrate Conservation 2023.

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GRAPH 3. MONARCH COUNTS AT ELLWOOD MESA, 2015-2016 SEASON Data from Althouse and Meade Inc and Rincon Consultants Inc.

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GRAPH 4. MONARCH COUNTS AT ELLWOOD MESA, 2021-2022 SEASON Data from Rincon Consultants Inc.

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GRAPH 5. MONARCH COUNTS AT ELLWOOD MESA, 2022-2023 SEASON Data from Rincon Consultants Inc.

4.3 Climate and topography at Ellwood Mesa
Ellwood Mesa has a Mediterranean climate, characterized by mild temperatures year-round.

During the winter months when monarchs roost at Ellwood Mesa, temperature lows range from low to high 40 degrees Fahrenheit, highs from mid to high 60’s, and mean temperature range s from low to high 50’s ( Graph 6). Events outside this range are possible any time during the overwintering period, however, with a handful of uncharacteristically warm or cold days.

November has the bulk of war mer than average days, occasionally exceeding 80 degrees. Only two days in the last thirty yea rs were daytime highs above 90 degrees. Conversely, temperature lows can often go below 40 degrees, with a handful of incidents below 30 degrees (Graph 6).

Wind condi tions at Ellwood Mesa are generally suitable for monarch butterflies, with the majority of wind observations under 10 mph (blue, teal, and green areas in Graph 7). However, winter storms periodically bring strong winds throughout the overwintering period. These storms most frequently come from the southwest which bring win d speeds up to 30mph and heavy rain.

While less common, all directions have records of strong storm events, particularly from the northeast and southeast (Graph 7).

The Ellwood Mesa contains topographic features that provide conditions supportive of the microclimate needs of migratory monarch butterflies. Overwintering monarch butterflies tend to cluster in specific areas where cold air is allowed to sink and drain away from the aggregation area. This mechanism allows for a warmer and better regulated microclimate to persist within the aggregation site. The low -lying channels formed by Deveraux creek allow for this removal of cold air at each of the show aggregation sites (Figure 3).

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GRAPH 6. HISTORICAL TEMPERATURE OBSERVATIONS FROM 1993 – 2023 Data is d uring the monarch overwintering period. Temperature extremes and mean are plotted by date for each year. Averages for each temperature category are plotted across the time range.

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GRAPH 7. WIND OBSERVATIONS FROM 1993 – 2023
Data is during the monarch overwintering period.

10 5
65 50
85 80
65 60
70 55 50
40 70
65 60
90 80
95 85
80 75
75 70
90 85
55 50
75 15
45 35
20 25
60 30
45 30
25 35
20 80 75
40 35
80 75
60 50
30 95
95 95
90 90
80 8080
80 75
70 60
65 55
60 55
55 4545
40 45
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Goleta Monarch Butterfly Grove at Ellwood Mesa
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Figure 3. Ellwood Mesa Topography
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4.4 The 2012 – 2016 Drought: Unprecedented Event

4.4.1 Impacts of Drought on the Ellwood Forests
Forests exist in a dynamic equilibrium with available site water – growing more in wetter years and dying back in dry periods. The sustainable density of trees at a site results from dynamic processes. The first response to drought conditions is reduced annual growth, followed by loss of leaves and branches, and eventually death of entire trees as competition below ground for limited water pushes trees over their tolerances (Metcalfe et al. 1990, McJannet and Vertessy 2001 ).

Insects and disease also can thr ive under water stressed conditions, hastening tree mortality. For example, the eucalyptus long- horned borer ( Phoracantha spp.) can more readily spread when trees do not have sufficient water to produce sap to repel the growing beetle grubs below the bark layer.

The Ellwood forests were established in the late 19 th Century, during a relatively wet period.

The tree spacing was typically around 2 meters (6’). The trees grew well in the mild climate and developed into the dense forests we associate with Ellwood. The monarchs occupied the suitable microclimatic niches – wind-sheltered gaps in the canopy ( see Section 3.1) – as they developed across topography and by the recruitment and mortality of trees. For many decades, the forest was managed as a woodlot, where a certain amount of live and dead wood was removed, which maintained a sustainable forest density.

A historical reconstruction of the climate and water balance at Ellwood allows the current crisis to be put in perspective. The long- term (1895-present) precipitation (PPT) records by water year (October 1 - September 30) for Ellwood shows high interannual variability, typical of the California climate (Graph 8). Mean PPT was close to 600 mm (23”). Maximum PPT was >1200 mm (47”) in 1941 and 1998, and minimum PPT was <250 mm (7.9”) in 1990 and 2007. Notable multi-year periods of low precipitation included the late -1920s and early- 1930s, the late -1940s and early-1950s, the late 1980s-early 1990s, and 2012-2016.

GRAPH 8. ANNUAL PRECIPITATION AT ELLWOOD MESA (OCT. 1 – SEPT. 30) Long-Term Average=576 mm (22.7”, Horizontal Line)

Annual precipitation (PPT) is not the only driver of drought – evaporative demand over the dry season, driven largely by temperature and the last date of soaking rains, depletes soil moisture until the rains return in fall. A water balance model, the Basin Characterization Model (Flint et al. 2021), keeps tr ack of PPT, soil storage, and outputs including evapotranspiration, recharge, and runoff. Drought intensity is characterized by “Climatic Water Deficit” (CWD), which

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integrates precipitation, evaporative demand (PET), and soil moisture storage monthly into a single number for the water year. The calculation is for a standardized site with available soil water capacity of 451 mm (17”), the Ellwood monthly climate, and occupied by a blue gum forest. This is a consistent measure of annual and multi -year CWD that characterizes the overall intensity of drought on the soil type mapped at Ellwood. It does not account for microsite differences in soil depth and topography (to be discussed later).

A single year of drought stress rarely has strong lasting effects. Som e leaf fall in evergreen trees may be observed. Cumulative stress over several years leads to widespread forest decline with loss of entire branches and trees (Metcalfe et al. 1990, McJannet and Vertessy 2001).

Annual CWD values are shown in Graph 9 as the thin grey line. Mean CWD was approx. 900 mm (35”) – Mediterranean climates have relatively high CWD because of the summer dry season, but the vegetation is adapted to these average levels. Maximum annual CWD was >1100 mm (43”) in 1990 and 2014, and minimum CWD was <800 mm (31”) in 1963, 1983, and 1998.

The 4 -year running average is shown as the thicker blue line. The multi -year droughts in the 1920s and 1930s, 1940s, and from 1987- 1990 peaked at 1000 mm (39”). There was some observable canopy die off by the early 1990s, but was largely restricted to high branches (S.B.

Weiss and D. E. Meade, pers. observ.). But these branches resprouted during the relative wet period in the 1990s and 2000s.

GRAPH 9. ANNUAL CLIMATIC WATER DEFICIT AND 4-YEAR RUNNING AVERAGE A measure of annual Climatic Water Deficit (CWD) (grey line) and 4 -year running average (thick blue line) at Ellwood Mesa. Long-term average = 907 mm (35.7”, Horizontal Line).

The other side of the equation is high productivity periods , characterized by low CWD and high PET. Notable periods of high forest productivity include 1905-1918, 1954-1959, and 1993-2005.

The last high productivity period set up the catastrophic response to the recent drought , as trees grew according to site water availability with no removal of live biomass.

At the end of the latest drought from 2012- 2016, CWD peaked at a 4 -year average of 1081 mm (43”), nearly 100 mm greater than the historical highs in 1931 and 1990. The 2012- 2015 California drought was not only the most severe in 1,200 years, but it also “has an almost incalculable return period and is completely without precedent” (Robeson 2015). Unlike much of California, Santa Barbara County received relatively little rain in 2016, extending the drought one more year.

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The most important long-term climate trend at Ellwood Mesa has been an increase in evaporative demand – annual potential evapotranspiration (Graph 10). PET is a multiplicative function of air temperature and solar radiation, and accounts for summer fog. The long-term trend is driven by increasing air temperature , especially during the dry season. PET has increased by 50 mm (2”) since 1900, with the sharpest increase since 2013. In 2020, PET hit an unprecedented 1412 mm (56”); however, the resultant CWD was not excessive because Mar -Apr rainfall was 285 mm (11”) which saturated the soils at the beginning of the dry season. In contrast, in 2013 and 2015, the rains stopped early (January) so the CWD accumulated over an extended dry season . These examples highlight how the timing of precipitation is an important component of annual CWD.

GRAPH 10. ANNUAL POTENTIAL EVAPOTRANSPIRATION
A measure of evaporative demand (grey line) and 4 -year running average (thick blue line) at Ellwood Mesa. Long-term average = 1344 mm (53-inch, horizontal line).

4.4.2 Tree Mortality
The impact of this unprecedented drought on Ellwood has been mass mortality of blue gums across much of the site ( Photo 4 and Photo 5). As discussed elsewhere, Ellwood is too arid for blue gums to thrive over the long term – the tree comes from Tasmania and southeast Australia where there is regular summer rainfall. The whole tree mort ality was exacerbated by the uncontrolled growth of dense stands during the wet periods in the 1990s and 2000s, after woodlot management ceased. The blue gums have “self -thinned” to restore some balance between forest density and water availability. The ot her eucalyptus species present at Ellwood, especially red ironbark, have not suffered drought mortality.

The extent of the tree mortality is captured in the LiDAR map of dead standing and downed wood (Figure 5 - Figure 12) (LiDAR is explained in Section 5.1.3). The figures show l arge swaths of the forest died off. We estimate that there was approximately 360,797cubic feet of dead standing and downed wood across the entire forest as of 2021 with major mortality hotspots in Ellwood North, Ellwood West, and parts of Ellwood Main (maps). Total volumes of dead standing and downed wood by monarch site area (Figure 4) is presented in Table 3.

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TABLE 3. VOLUME OF DEAD STANDING AND DOWNED WOOD BY MONARCH SITE AREAS Name of Monarch Site
Area
Monarch Site Area
Size (ac)
Volume of Dead standing
and Dead downed Wood
(cubic feet)
Number of Dump
Trucks
Ellwood Main 13.86 95,377 252
Ellwood West 6.74 58,079 154
Ellwood East 8.33 32,802 87
Ellwood North 10.81 95,280 252
Ellwood Ironbark 8.14 66,652 176
Sandpiper 3.04 6,699 18
Ocean Meadows 2.09 5,908 16
Totals 53.01 360,797 954

4.4.3 Effects of Tree Mortality on Monarch Habitat
The loss of trees and canopy cover has opened the overwintering sites to increased wind exposure. At Ellwood Main, the depth of wind shelter has diminished with the mass mortality, so that there are “thin green lines” of remaining live trees to provide wind shelter from various directions. Critical redundancy in wind shelter is gone. The west-southwest exposure has opened into a wind gap. The dead trees tend to be on the c onvex shoulder of the drainage, where the soils are thin, and water drains away. Downslope, where soils are thicker and some water drains in from the slopes above, fewer trees have died, and the remaining row of live trees provide the last line of wind shelter for the cluster zone. On the southeast side, the outer edge row of trees is still intact, but the interior trees have died. The loss of trees north of the cluster zone, some still standing as of 2023, has opened that direction to more wind, and the cl uster trees themselves provide the remaining shelter from the northwest, north, and northeast winds.

At Ellwood West and Ellwood East, the topography – the rise from Deveraux Creek to the mesa – has ameliorated the loss of tree canopy to the south. The cluster sites close to the riparian zone, in the flat or just up the slope, and the mesa, with an elevation difference of approximately 12 m (40’), provides additional shelter from SE, S, and SW winds. Shelter from E and W winds are provided by the gr eat depth of forest cover along the riparian corridor, and these trees are relatively well watered and less susceptible to drought (although there have been individual trees that have died or uprooted).

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Photo 4. Mass mortality of blue gums at Ellwood North, view towards the east.

Photo 5. Mass mortality of blue gums at Ellwood Main, at viewing area looking southwest.

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5 STATUS OF THE HABITAT AT ELLWOOD MESA
Professional experience integrates the technical analyses into a coherent assessment and plan that maximizes chance of success, if adopted and executed. Since 1989, the core scientists on this team have worked on dozens of formal and informal monarch habitat assessments/plans and have seen a full gamut of site characteristics, monarch behavior, and management successes and failures.

5.1 Overview of Methods
We are applying this best available science to diagnosing and restoring the monarch habitat at Ellwood Mesa. The tools we use to assess and manage overwintering sites include:
1) Direct observations
2) Hemispherical photography
3) LiDAR
4) Forestry
5) Wind modeling
These are methods that are used to quantify the amount of canopy and openness in the canopy in order to then infer the prevalence of wind and intensity of lig ht. These techniques encompass the best available science, bolstered by collective decades of monarch experience at Ellwood Mesa and dozens of sites from Sonoma to San Diego.

5.1.1 Direct Observation
The direct observations of monarch distribution and abundance allows the butterflies to tell us what they like and do not like. The Western Monarch Thanksgiving Counts document numbers in late -November and early -December, and the New Year’s Counts document numbers at a subset of sites in early -January. The difference between the two counts reflects site suitability in the face of whatever weather occurred between the counts. With strong storms, monarchs leave some sites completely, do a partial exodus, and many sites decline with ongoing mortality.

Often, a large storm will reshuffle monarch distributions among close sites, or sites tens of kilometers away. In other years conditions are mild and little change in distribution occurs, only some mortality. In California as a whole, the change from Thanksgiving to New Year’s ranged from –35 to –49 % but varied greatly from site to site and region to region.

Finer temporal resolution of monitoring (1 -2 weeks, or even close to daily) reveals responses to individual weather events especially when the cluster locations are closely tracked by tree, branch, and height. Wind vulnerabilities become apparent when movements are linked to individual storms or storm sequences, and we can often observe the fine -scale shelter provided by individual branches. Also, monarchs prefer different insolation regimes at different times of the year conditional to wind, seeking afternoon sun after a day flying, or morning sun when early activity.

Direct observation of wind, temperature , and insolation can be valuable, but have limits. Spot observations can map instantaneous conditions across an entire site and have proven invaluable (Leong 1990, Leong et al. 1991). Continuous observations by automated equipment are limited to a few sites in any given grove.

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5.1.2 Hemispherical Photography
Hemispherical photography (hemiphotos ) is a well- developed technique for analyzing canopy structure at overwintering sites (Weiss et al. 1991). A 180 degree “fisheye” image pointed upward allows precise determination of canopy gaps, and their directional impacts on light and wind is determined by specialized image analysis software, such as Hemiview. The methodology for the hemispherical photography is included in Appendix A.

Canopy gaps along sunpaths allow for fine -scale estimation of monthly and half -hourly insolation, and gaps in different wind directions that are produce d. These “site factors” can be mapped as points or as interpolated surfaces. The point data are presented as color -coded circles for ISFU (Visible Sky), DSFU (proportion of potential annual insolation), and monthly potential direct insolation.

The first- order approximation of wind penetration from hemiphotos is “directional exposure:” the proportion of open sky in 8 different directions. “Wind roses” for hemiphotos are created from different sized wedges in 8 directions that correspond to the proportion of open sky in that 45° sky sector. Low elevation angles are more highly weighted than overhead the hemispherical view (greater proportion of the hemisphere at low elevation angles). H emiphotos are labeled for directional exposure with the wind rose below the photo number. The wind rose wedges are color coded: red is > 0.30 and indicates too much exposure, yellow is between 0.20 - 0.30 which is marginal, and blue is < 0.20 which is generally well-sheltered.

At Ellwood Main, a dense enough array was taken so that interpolated surfaces could be generated in ArcGIS using the Geostatistical Analyst. The chosen technique (Thin Plate Spline) that is an exact interpolator – the surface goes through each observation, and directional bias (i.e., upwind/downwind) can also be considered.

More detailed methodology is included in Appendix A.

5.1.3 LiDAR
LiDAR is the newest tool for evaluating monarch sites, developed since 2019. A laser scanner, from drone or airplane, is flo wn over a site and the 3- D “point cloud” of reflections captures the fine-scale canopy structures across entire sites and adjacent areas. Lidar is an acronym of "light detection and ranging" , a method for determining ranges by targeting a surface with a laser and measuring the time for the reflected light to return to the receiver. The full analysis report with methodology is included in Appendix G.

5.1.4 Arboriculture
Professional ar borists were employed to assess current conditions and tree health and make recommendations for future maintenance. The foundational knowledge arborists provide is important to our understanding of forest dynamics and our ability to manage them into the future.

In 2017 and 2018, an ISA Certified Arborist (Cory Meyer) assessed trees throughout Ellwood Mesa by documenting tree genus and species, diameter at breast height ( DBH), tree height, canopy spread, health, and environmental conditions. Diameter was measured in Standard American English (SAE) units by running a Starrett 530JT-50 diameter tape measure around the trunk at breast height. Visual inspections were used to estimate canopy height and spread, health, structure (e.g., direction of lean) , and defects . Notes were taken for environmental or site conditions, tree structural problems, or possible diseases and pests.

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5.1.5 Wind Model
Recent software advances allow computationa l fluid dynamics to be applied to LiDAR point clouds to model wind within forest canopies. We applied Rhinoceros 3D 7 (McNeel et. al. 2010) with Eddy3D (a plugin for Rhino 7 that uses OpenFOAM ), Volvox (Zwierzycki 2016), Lands Design (Asuni 2022). We created a 3-D map of wind speeds at fine scales, allowing for more detailed assessments than those based on inferred wind from canopy gaps. Detailed wind modeling methods are provided in Appendix B.

The effects of both proposed and existing forest manageme nt, such as planting shelterbelts, or the loss of trees, as well as the effects of nearby buildings were simulated to understand how wind dynamics are affected by various structure types and heights.

More detailed methodology is included in Appendix B.

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5.2 Ellwood Main
Ellwood Main is a stand of primarily blue gums surrounding a north -south running side gully of Deveraux Creek. The core stand extends approximately 140 m (460 ft) north-south from Deveraux Creek to the end of the gully, and approximately 125 m (410 ft) east-west. Some outlying stands north across Deveraux Creek and east and west of the core stand provide outer wind shelter. The main cluster sites occupy approximately 30 m (100 ft) over the gully, starting approximately 30 m (100 ft) from the creek channel. Tree heights are up to 40 m (130 ft).

The stand of trees has a cathedral structure and the elongated north- south gap over the gully allows substantial insolation into the cluster sites. The trees on the shoulders of the gully and extending onto the mesa top provided multiple layers of shelter from southerly, easterly, and westerly winds. The south, west, and east edges of the stand are characterized by dense stands of saplings and pole -sized trees. Trees between the cluster site and Deveraux Creek and the trees north of the creek provided shelter from northerly winds. The gully itself provides a cold moist air pool at night and in the morning.

The combination of these features made Ellwood Main a premiere overwintering site that has attracted and maintained large numbers of monarchs thorough entire overwintering season for decades. In recent years, monarchs have uti lized the trees along the gully for roosting and their cluster locations span the 100 m area, as shown on Figure 13.

The recent mass mortality of blue gums has greatly weakened the wind shelter for the monarch roosting areas. To visualize the canopy of Ellwood Main, we created a dissection of the profile of Ellwood Main in 25 m slices, shown in Figure 14. The profile starts on the north bank of Deveraux Creek and progresses due south through the cluster zones to the south end of the stand of trees. The V-shape is the north-south gully through Ellwood Main. Table 4 gives a description of each slice of the profile.

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FIGURE 14. A PROFILE THROUGH ELLWOOD MAIN: ANATOMY OF A MAJOR AGGREGATION SITE

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TABLE 4. DESCRIPTION OF ELLWOOD MESA CANOPY SLICES
Images of this Slices are shown in Figure 14.

Location Description
0 North bank of Deveraux Creek, scattered trees
25 Creek Channel
50 South bank
75 Opening above gully [a], south-edge of riparian zone with tall dense trees 100 Openings east and west away from gully [b]
125 First small clusters on west bank (purple dots), substantial north wind shelter across gully [c]
150 Small clusters on east bank, immediate north wind shelter major cluster zone [d] 175 Major cluster zone. Mainly on east bank or bottom of gully. Viewing area on east bank [e].

West opening [f] is a major tree mortality zone (Photo) that opened a west -southwest wind vulnerability.
200 Cathedral structure apparent over gully [g], clusters are low. Large west -opening continues south [h]
225 Most southerly stack of clusters, on west bank. Large west opening continues [i] 250 Short south-wind shelter across gully [j], interior gaps to west of gully [k] 275 Tall canopy on east and west banks of gully [l]
300 Taller south-wind shelter across entire gully [m]
325-340 The stand narrows and densifies and the gully emerges east of the stand Note: 25 ft slices were created in ARCGIS Scene, starting on the north bank of Deveraux Creek, and progressing due south through the cluster zones and to the south end of the stand.

The V-shape is the north-south gully.

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5.2.1 Historical Conditions at Ellwood Main: Hemiphotos 1990, 1998, and 2021 In January 1990, a 100 m transect was set up along the Ellwood Main gully, with hemiphotos taken every 10 m (Weiss et al. 1991). The transect was resampled in 1998 and in 2021, allowing for a quantitative comparison o f site factors over time that document change in the canopy structure and habitat suitability for the monarchs.

The array of hemiphotos ( Figure 15) shows the main cluster zone at Ellwood Main, at 60 m and 70 m along the gully, with hemiphotos taken in 1990, 1998, and 2021. In 1990, the forest had experienced 4 intense drought years so was relatively open with loss of tall branches and foliage.

During the wet 1990s, the forest grew vigorously. By 2021, further drought had thinned the forest, and large numbers of whole trees died.

At 70 m, the canopy filled in from south through north-west between 1990 and 1998, primarily from south through north-west, while it opened to the north. By 2021, more openings appeared to the south, southwest, west, and northwest , and an overhead tree to the southeast died. But the tree almost due east filled in over that time. A similar pattern is seen at 60 m.

The major s ite factors ( Table 5) show trends of key “site factors” across all three dates. ISFU 4 (fraction of visible sky in all directions) varies from 0.11- 0.16 in the photos, and ranges by 0.03 through time at each site. ISFU increased from 1998 to 2021 at 60 m but decreased from 0.13 to

0.11 at 70 m over that period. ISFC 5 (visible sky corrected to a horizontal surface) is higher than ISFU and ISFU/ISFC ratio has a narrow range from 1.5 -1.6, indicating that the canopy is relatively more open overhead than around the edges, i.e., the sites are in a substantial overhead gap. The Direct Site Factor Uncorrected (DSFU) is the fraction of potential annual insolation uncorrected for receiving surface – basically how open the canopy is along all of the yearly sunpaths. The DSFU values, and visual inspection, indicate that the sites are open enough toward the S that full or dappled sunlight is received several hours each day.

TABLE 5. MAJOR SITE FACTORS AT TWO HEMIPHOTO SITES IN CLUSTER ZONE FOR 1990, 1998, AND 2021
Site Factor 60m 70m
1990 1998 2021 1990 1998 2021
ISFU 0.15 0.13 0.16 0.14 0.13 0.11
ISFC 0.23 0.20 0.25 0.22 0.20 0.17
ISFU/ISFC 1.50 1.60 1.60 1.50 1.50 1.50
DSFU 0.23 0.15 0.28 0.20 0.15 0.17

The graphic assessment of canopy gaps is shown as polar plots in Figure 16 and Figure 17. The figures show directional exposure in 8 directions and show some complex behavior of t he canopy gaps over time and space . For example, at 60 m north -exposure decreased from 1990/1998 to 2021; i.e., the canopy filled in in that direction. In contrast, at 70 m north-exposure remained relatively constant. At 60 m, south- and southwest-exposure decreased from 1990 to

4 ISFU = Indirect Site Factor Uncorrected: the overall proportion of sky visible. 5 ISFC = Indirect Site Factor Cosign corrected to a horizontal surface.

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1998, then increased by 2021, reflecting the many trees that died from 1998 to 2021 in that sector. At 70 m, south- exposure decreased from 1990 to 1998, and slightly increased by 2021.

And southwest-exposure decreased from 1991 to 1998 and increased back in 2021. Many more changes can be observed.

The differences between sites only 10 meters apart show that monarchs can move short distances to reduce wind exposure. For example, moving from 60 m to 70 m reduces south- exposure from

0.28 to 0.13, but moving to 80 m increases south -exposure to 0.25. The same move reduces southeast-exposure from 0.26 to 0.18 and to 0.11.

The main conclus ion from this historical comparison is that the patterns of sky exposure in the cluster zone have shifted through time, to be expected in a complex dynamic forest. Throughout the 1990s and 2000s, Ellwood Main supported permanent season- long monarch aggrega tions, indicating that the site factors observed in 1991 and 1998 were well within the tolerance range and could protect monarchs from the most intense winter storms. The degradation of the forest starting in the mid -2010s has reduced the multiple layers of wind shelter, thereby increasing wind vulnerabilities, leaving “thin, green lines” as the remaining wind shelter.

As of 2021, the cluster zone remains relatively well -sheltered from most directions, but significant gaps have formed especially to the west and southwest. By 2021, the site factors in the cluster zone were suitable when monarchs arrived, and they remained at the site until strong windstorms exceed a threshold between 25 and 30 mph, as occurred in December 2021 and December 2022. As such, Ellwood Main may be acting as an “ecological trap,” attracting monarchs early in the season but leaving them vulnerable to strong storms that can be expected each year (as shown on the wind rose in Graph 7 in Section 4.3).

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FIGURE 15. HEMIPHOTOS FROM THREE YEARS BETWEEN 1990 AND 2021 AT 60 AND 70

METERS INTO THE ELLWOOD MAIN GROVE

1990 1998 2021
70 60

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FIGURE 16. GRAPHIC ASSESSMENT OF CANOPY GAPS OBSERVED IN THE HEMIPHOTOS EACH

OF THREE YEARS

FIGURE 17. GRAPHIC ASSESSMENT OF 2021 DIRECTIONAL EXPOSURE AT THREE LOCATIONS 10 METERS APART IN THE CLUSTER ZONE

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5.2.2 Current Conditions at Ellwood Main
At Elwood Main, hemiphotos were taken at 10 m (33 ft) increments along the gully bottom (recreating the 1990 and 1998 transects, see historical conditions in Section 5.2.1), and at 10 m increments along the trails on the east -side and west-side, and a few at the canopy edges. Photo locations are shown in Figure 18, overlaid onto the maps of standing and downed dead wood, and a color infrared (CIR) image with live canopy as bright red. The cluster zone of 2021 and 2022 is in the white oval.

5.2.2.1 Visible sky
The point map of Visible Sky (ISFU) at Ellwood Main (Figure 19) shows that the cluster zone is in the range of 0.125- 0.20. The northern part is slightly more closed. Areas 20+ meters south of the cluster zone are less open, < 0.125. The range s reported in Table 6 are from the four hemiphotos that overlap within the cluster zone oval.

5.2.2.2 Directional exposure
The maximum directional exposure and wind roses ( Figure 19) show how exposure decreases from the edge (red) into the interior (yellow through blue ), and there are “wind tunnels” where a bulge or streak of red or yellow extend into the interior. The individual wind roses show which and how many directions are vulnerable. Maximum directional exposure shows that much of the northern half of Ellwood main has marginal (yellow) exposure from one or more directions. The only 360° sheltered areas in the grove are in the southern half, but those areas have too much canopy cover and lack sufficient insolation.

Directional exposure (Figure 20) shows an array of 8 directions. The penetration of wind into the grove is illustrated as the gradient from red (>0.30) at the edge, through yellow ( 0.20-0.30), and into blue (<0.20). Descriptions of key features from each direction are in Table 6. Note some extremely sharp gradients near the gully transect; these are the “thin green lines” of remaining live foliage that are the last live shelter for the cluster zone.

The most vulnerable directions in the cluster zone are W, SW, S, SE. The depth of wind shelter in these directions has been compromised by the tree mortality in the interior, extendin g all the way to the edge in the southwest gap (see Figure 18 for dead trees) – prior to the mortality, many more trees provided redundant wind shelter in these areas. The thin green lines of live trees that provides the critical wind shelter are just below the E -trail and along the SE edge. The high S - exposure is a natural consequence of the cathedral structure over the gully and is also what allow insolation into the cluster zone (see below). Monarchs could move about 10 m north along the gully axis, cluster behind some branches, and reduce their S -exposure. But then they will increase their N exposure. The N-exposure in the cluster zone is attenuated by the remaining thin green line running E -W across the gully just N of the cluster zone. N -exposure has increased from tree mortality and canopy thinning.

The array of photos around the primary cluster zone ( Figure 21) shows these structures from the ground. Each photo is discussed in Table 7.

5.2.2.3 Insolation
Maps of ground-level DSFU (Figure 22) show that the cluster zone is in a higher insolation belt (white. 0.23-0.29) running E -W across the gully. Other parts of the grove (the gully floor N of the cluster zone) are deeply shaded all year long (darker blue, < 0.13). Note that DSFU assess all Althouse and Meade, Inc.

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sunpaths through the year and includes the high sun angles of summer (see Methods). But DSFU is relevant as an approximate measure of southern su npath exposure higher in the canopy, i.e., the values for summer from ground level are relevant for winter values higher in the canopy.

The point maps of monthly insolation at ground level show that the cluster zone is in a higher Oct- Feb insolation area compared with areas further south, the result of the elongated gap over the gully that creates the cathedral structure. The gap can be clearly seen in Photos 314 and 315 (Figure 21). Insolation in the cluster zone decreases from October to December and increases again through February (a natural consequence of seasonal sun angles). In October. most of the forest floor is not in deep shade, but the deepest shade (darkes t blue) increases in November and December, especially in the southern interior of the grove. By December, the ground- level shade extends to the S end of the cluster zone. The S-edges receive nearly all potential radiation (reds).

An array of hemiphotos ar ound the primary cluster zone show some of the canopy structures described above (Figure 21). The descriptions (Table 7) include presence of gaps and thin green lines in various directions.

5.2.2.4 Ellwood Main Summary of Findings
Between the LiDAR, current and historical hemiphotos, and experience, we have a comprehensive view of current conditions at Ellwood Main. The key southwest , south-southeast and north vulnerabilities are presented as oblique LiDAR views with hemiphotos from below (Figure 23 - Figure 25). If the darker blues (ground) are visible, it means that a deep canopy gap exists in that view. Accompanying hemiphotos give the view from the ground inside the grove.

Key conclusions and observations include:

1. The primary cluster zone has relatively higher insolation than surrounding areas, created by the cathedral structure and elongated gap over the gully.

2. The primary cluster zone has low directional exposure from most sides, but with moderate wind vulnerabilities from SW, S, SE, and N.

3. Mass tree mortality has opened the canopy, leaving only thin green lines of live trees in key directions as the remaining wind shelter. Gaps in those lines create specific vulnerabilities shown in Figure 23 - Figure 25.

4. Even where some wind shelter remains, redundancy in wind shelter has been lost.

5. Monarchs were attracted to Ellwood Main in October and November 2021 and 2022, but then abandoned the site following strong storms, confirming substantial loss of wind shelter.

6. Further tree mortality and treefall will reduce remaining wind shelter.

7. Some vulnerabilities are compensated by short movements (10-20 meters) to other trees/branches, but then wind shifts can drive monarchs back to original cluster sites.

8. Many standing dead trees threaten nearby cluster and windbreak trees.

The restoration recommendations ( Figure 26) show the primary cluster zone, the main dieback zones, and the vulnerabilities described above.

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5.2.3 Recommendations for Ellwood Main Restoration Actions The following are our recommendations f or the restoration of Ellwood Main and correspond with Figure 26:
• Replace/replant dead monarch aggregation trees with blue gum eucalyptus. • Encourage the recruitment and establishment of blue gum saplings and existing trees. • Retain tall trees north of creek for north-northwest shelter. • Be very surgical with fuels reduction in areas 18A-B-C-D. • Fuel reduction areas 21B-C and 22A are important northeast shelter trees. • Remove standing dead trees (shown in black on Figure 26). • Remove high fraction of downed wood, especially finer fuels <10 inches diameter that prevent new growth.
• Separate large logs on the forest floor as practical. • Plant shelterbelts of red ironbark on open edges, or inside behind the first row of blue gums.
• Fill the west gap with red ironbark (white oval on Figure 26). • Plant karri ( E. diversicolor) within interior of grove around the aggregation area for tall canopy and wind shelter trees.
• Plant California bay trees along the south side of Devereaux Creek.

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FIGURE 18. HEMIPHOTOS TRANSECT LOCATIONS AT ELLWOOD MAIN

Photo locations on left, on top of a CIR image and dead standing (blue) and dead downed (white) wood. Example photograph (473) in high mortality zone with directional exposure in each octant, as a reference. Maximun expoure to S, SW, and W, lowest NE. Mont hly sunpaths are in yellow, from December (most southerly) through June (nearly overhead at noon). The most southern 3 bands are the overwintgering season (Oct -Dec-Feb). Many dead standing trees in photo. Gap to W is same as in Photo 6 taken from outside forest.

Photo 6. Dead snag in west gap at Ellwood Main taken from the outside of the canopy (Photo by Stu Weiss).

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FIGURE 19. VISIBLE SKY
Green is in the most frequent zone (0.15-0.30) of overwintering microsites, blue is too closed (<0.15), and white-red is too open (>0.30). For Directional Exposure blue is low exposure (<0.20), yellows are marginal (0.20-0.30, and red is high (>0.30).

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FIGURE 20. DIRECTIONAL EXPOSURE FROM 8 DIRECTIONS

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TABLE 6. DETAILS OF 4 HEMIPHOTOS WITHIN PRIMARY CLUSTER ZONE Direction Cluster Zone Comments on pattern
NW 0.06-0.15 Penetration into the southern section of the grove through tree mortality zone on W side.

N 0.13-0.21 Small patch >0.20, high penetration into zone from gap to north (red), attenuated 10 m N of cluster zone by a thin green line E -W across gully (drawn in)
NE 0.13-0.19 Moderate penetration (yellow) on N-border, and high (red) in NW corner E 0.08-0.16 Patch of moderate (yellow) exposure in interior on E -side, SE of cluster zone. Thin green line of live trees along SE and E border, SE 0.13-0.28 Much of cluster zone is > 0.20, storm wind direction. The SE edge is a thin green line with high mortality in the interior, gaps in this dense edge would have disproportionate effects.

S 0.15-0.28 Highest interpolated exposure (0.32) in center of cluster zone, reduced to

0.05 past N-end of zone behind live trees. 0.2- 0.25 within the W tree mortality patch. This is a natural consequence of the position of the clusters at the N- end of an elongated gap over the gully (cathedral structure).

SW 0.07-0.30 Penetration into high mortality zone (red), rapid attenuation at W -side of cluster zone, thin green line below trail (drawn in). Highest exposure at E end of cluster zone on E shoulder of gully
W 0.07-0.24 Penetration into high mortality zone(red), thin green line below trail (drawn in), higher exposure (yellow) on far E side of cluster zone on E shoulder of gully

TABLE 7. DESCRIPTIONS OF HEMIPHOTOS IN FIGURE 21
Photo Comments
318 End of gully at Deveraux creek. Large opening to N, dense canopy to S blocks insolation.
317 10 m S of 317, opening appears smaller, some dappled insolation from S 316 N-end of main cluster zone, small gap N, some gaps SW and W, dappled insolation. Dead tree to SE.
315 Main cluster area, thin green line between here and 424/425, blocking W and SW.

S gap for direct insolation mid-day. Dead tree to NE.
314 Large gap S, some gaps SW. Thin green line W to 425 427, full mid -day, dappled afternoon insolation
423 W-shoulder of gully, gap to NE and SW. insolation in afternoon, Thin green line to E toward 317
424 Large gap SW (mortality zone w/ dead trees). Thin green line E to 316 425 Large gap SW w/ dead trees, low exposure elsewhere Thin green line to 315 and 314
427 Large gap S and SW w/ dead trees, direct insolation late -morning to mid - afternoon.
460 Dappled insolation late morning
459 Gap to NE, direct insolation mid-day.
455 Viewing area, few large gaps dappled light early afternoon 454 Viewing area, large gap SSW, direct insolation for 2 hrs. 453 Gap to SW across gully to high mortality zone
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FIGURE 21. ELLWOOD MAIN CORE HEMIPHOTO EXAMPLES
Photo locations above, note that east and west are reversed in upward looking hemiphotos.

Discussion of photos in Table 7.

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FIGURE 22. INSOLATION AT HEMIPHOTO SITES
Upper legend only applies to DSFU

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FIGURE 23. OBLIQUE LIDAR VIEW FROM SOUTH WITH EXAMPLE HEMIPHOTO Dead standing trees in northeast sector and protruding into south gap.

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FIGURE 24. OBLIQUE LIDAR VIEW FROM SOUTHWEST WITH EXAMPLE HEMIPHOTO Thin green line is at top of photo between the photo and the cluster zone.

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FIGURE 25. OBLIQUE LIDAR VIEW FROM N, WITH TWO HEMIPHOTOS ALONG GULLY 90m and 70m with thin green line of remaining wind shelter in between the photos.

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FIGURE 26. ELLWOOD MAIN VULNERABILITIES AND RECOMMENDATIONS FOR RESTORATION

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5.3 Ellwood West

5.3.1 Current Conditions at Ellwood West
A similar set of hemiphoto and LiDAR analyses were applied to Ellwood West. Ellwood West has been a subsidiary overwintering site, sometime supporting a large fraction of butterflies at Ellwood Mesa as a whole, but in recent years has been occupied early in the overwintering season, and then largely abandoned.

The monarchs roost at Ellwood West in a cathedral opening along Deveraux Creek, shown in Figure 27. From the c enter of the Ellwood West site, the Mesa rises approx. 12 m ( 40 ft ) in elevation to the south, with forest edges approx. 65 m (213 ft) south and approx. 65 m (213 ft) north, and the neighborhood border approx. 90 m ( 295 ft) north. There has been massive tree mortality in this area (Figure 28). Many trees south of the creek on the slope have recently died and are still standing, and much dead wood lies on the forest floor. In recent seasons, the monarchs began roosting in small open areas on the slope south of the creek , however these roosts are temporary given the loss of protective canopy.

A transect of hemiphotos at 10 m spacing was taken through the historical cluster zone extending along the creek (Figure 28A). Four example hemiphotos ( Figure 28B) illustrate key features of the cluster zone. Photos 217 and 218 are in the most recent cluster zone and are at the east end of the transect. Photo 214 is in the center, and 212 is at the west end. These sites have maximum directional exposure to the east. The hemiphotos in Figure 28B show how most of the sunpaths are covered by foliage, leading to low insolation.

In general, the canopy is closed at Ellwood West , with ISFU < 0.15 across the transect (range

0.10 to 0.14) , see Table 8. DSFU is low (0.11- 0.19) as well – the rise of the Mesa adds to the effective height of trees along the sunpaths. While some sites receive substantial insolation in October, by December much of the transect is in deep shade (darker blues in Figure 29). The maximum directional exposure in the two cluster sites is east (0.24 to 0.29) (yellow wedges, also see Table 8). In the middle of the transect, there is a site with high E -exposure (0.31), and one site with moderate NE exposure (0.22).

TABLE 8. EXAMPLE HEMIPHOTO DATA AND COMMENTS AT ELLWOOD WEST Photo Cluster ISFU DSFU Max Exposure Comments
418 Current 0.14 0.17 0.24 E East end of transect
417 Current 0.12 0.16 0.29 E Dead canopy visible ENE
412 Historic 0.13 0.19 0.26 W West end of transect
414 Historic 0.14 0.19 0.22 NE Dead standing visible SE

Ellwood West tends to be abandoned mid -season. Early in the 2022 season (Oct 31), Ellwood West attracted 924 monarchs (out of 1431 at Ellwood, 65%), but numbers fell to 120 -130 (1-2%) through November, and the site was largely abandoned by Dec 15. In 2021, Ellwood West supported 2,564 butterflies (29% of the overall Ellwood Mesa aggregation) on Dec 1, but only 3 were observed by Jan 4, 2022.

The low insolation and east exposure may be factors in the relative low use of Ellwood West by December, and the aba ndonment by mid- season. The east exposure may be a problem during Althouse and Meade, Inc.

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storms, east is a common wind direction with occasionally strong winds (see Section 4.3). By December, all the hemiphoto sites are quite dark at ground level, so the site may just be unattractive for monarchs in mid -winter. Some thought should be given to opening the overhead canopy, once the dead standing wood is cleared, but a detailed study is desi rable for removing more than the standing dead trees.

Prior to the mortality of so many trees on the slope, the site was undoubtedly even more shaded.

Sealing up the southern edge with a double ironbark row would ensure wind shelter along the Mesa edge ( Figure 31), but minimally affecting insolation . Sealing up the northern exposure would reinforce the thin green line between the trail and the edge. And, selectively p lanting tall growing eucalyptus east of the cluster site would address the east-wind vulnerability.

5.3.2 Recommendations for Ellwood West Restoration Actions The following are our recommendations for the restoration of Ellwood West:
• Replace/replant dead monarch aggregation trees with blue gum eucalyptus. • Encourage the recruitment and establishment of blue gum saplings and existing trees. • Removal dead standing trees (black in Figure 31)
• Remove high fraction of downed wood, especially finer fuels <10 inches diameter that prevent new growth.
• Separate large logs on the forest floor as practical. • Plant red ironbark trees in the openings on south-edge. • Plant ironbark/karri (E. diversicolor) between Santa Barbara Shore Drive and cluster zone to address east wind vulnerability.
• Plant double ironbark row on north-side.
• Plant low density karri (E. diversicolor) within tree mortality zones to diversify canopy and add to the wind shelter zone.
• Plant native trees in riparian zone along Devereux Creek, do not fill in the open interior under monarch roost trees to maintain cathedral structure. • Plant understory native shrubs and oaks
• Once dead wood removed, consider opening the overhead canopy after additional study.

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FIGURE 28A. HEMIPHOTO TRANSECT LOCATIONS AT ELLWOOD WEST In map with 50 m grid, CIR and dead trees , trails (green lin e), Devereux Creek (blue line) , grey polygons (fuel management treatment areas).

FIGURE 28B. EXAMPLE HEMIPHOTOS AT

ELLWOOD WEST
Photos 418 and 417 are the cluster site.

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FIGURE 29. POINT MAPS OF HEMIPHOTO RESULTS AT ELLWOOD WEST

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FIGURE 30. OBLIQUE VIEW ELLWOOD WEST VULNERABILITIES

Descriptive comments about Figure 30 of Ellwood West:
• Black dots are historical cluster sites, E end of transect occupied in 2021 and 2022. • Cathedral structure along creek.
• The hillslope to the Mesa provides intrinsic wind shelter. Reduces impact of tree mortality.
• E and N wind vulnerabilities, thin green line N of trail • Fuels management – only 17A, B, and C (shown on Figure 31) have potential impacts, but far from cluster zone, stand of red ironbark. Other fuel grid cells along N-edge do not have tall trees.

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FIGURE 31. ELLWOOD WEST VULNERABILITIES AND RECOMMENDATIONS FOR RESTORATION

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5.4 Ellwood East

5.4.1 Current Conditions at Ellwood East
Ellwood East is in the east ern portion of the eucalyptus stand on Ellwood Mesa , south of Deveraux Creek in a topographic bowl at the base of the Mesa slope. The bowl wraps around from east to south and southwest and rises approximately 12 m (40 ft). The bowl itself provides some intrinsic wind shelter from east through southwest. Monarchs historically clustered along a 80 m (260 ft.) stretch in the bottomland flat, shown in Figure 32. In 2021, monarchs clustered 10-15 m south of the previous cluster zone at the very base of the Mesa slope. The Ellwood East stand has several species of eucalyptus in addition to blue gums – red river gums (E. camaldulensis), and a small stand of red ironbark at the Mesa rim.

The bottomland flat is occupied by numerous non- native, evergreen ash (Fraxinus uhdei) trees, some of which are >30 m (100 ft.) tall. A stand of evergreen ash is present in the western side of the bottomland flat, west of the historical cluster zone, and monarchs also roosted in these trees in 2021- 2022 season. The edge of the forest at the Mesa rim consists of small dense trees on highly compacted soils, with many smal l gaps that lead to the larger trees on the slope.

Substantial mortality of blue gum on the Mesa slope and in the flat opened the forest and dead downed wood (especially large trunks) is strewn across the forest floor.

Ellwood East has been heavily used i n recent years (see Section 4.1 and Appendix C). In 2021- 2022, monarchs abruptly abandoned Ellwood Main in late December, and many moved to Ellwood East for the re mainder of the season. A similar, less abrupt movement from Ellwood Main to Ellwood East occurred in 2022- 2023. But unlike 2022, Ellwood East was abandoned as monarch numbers at Ellwood crashed following a series of intense winter storms in late - December and early-January (see Section 4.1 and Appendix C).

A transect of hemiphotos spaced ~10 m (33 ft.) apart was taken northwest to southeast through the historical cluster zone (Figure 33A). Another set of hemiphotos was taken in a 2021 cluster area, slightly up the Mesa slope. Some photo data are presente d in Table 9. Photos 702, 709, and 708 are in the slope cluster zone ( Figure 33B). The Mesa slope rises to the S. Photo 702 is well sheltered from all directions, Photos 708 and 709 have gaps to the NE and SW. All three photos receive some dappled light at ground level for a few hours during the overwintering season.

Photo 707 is upslope from the cluster zone, and a substantial gap appears to the SSW – note that there is only one clump of trees in the SE octant. This is the area of substantial tree mortality.

Photos 468 and 462 are along the historical cluster zone; 468 has a large overhead gap and moderate N and NW exposure.

The point maps of hemiphoto data (Ellwood East has relatively high overall canopy cover. ISFU ranges from 0.075 to 0.15. The DSFU map shows a higher insolation (0.16- 0.25) zone on the slope, and the monthly insolation is higher in the slope area. S, SW, and W exposure increase on the slope (Figure 34). One slope site (Photo 708) has high NE exposure. The E end of the lower transect has moderate NW and N exposure, and one site in the middle of the transect has high E exposure. The outlying hemiphoto site to the SW is in the ironbark stand and has all around low directional exposure.

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TABLE 9. EXAMPLE HEMIPHOTO DATA AND COMMENTS AT ELLWOOD EAST Photo Cluster ISFU DSFU Max Exposure Comments
702 Cluster 0.10 0.14 0.14 E 2021 slope location
708 Cluster 0.12 0.14 0.34 NE 2021 slope location
709 Cluster 0.11 0.12 0.25 N 2021 slope location
707 Upslope 0.12 0.25 0.24 S Upslope above cluster zone 468 Cluster 0.14 0.13 0.28 NW East-end of zone
462 Cluster 0.12 0.16 0.27 N West-end of zone

Overall Ellwood East has an array of microsites that provide moderate insolation and low directional exposure within short distances within the site. The shift to the 2021 cluster sites appears to be driven by insolation, but moving farther up the slope would increase wind exposure.

Ellwood East combines generally low directional exposure with higher insolation on the slope.

The extensive drought mortality of blue gums (dieback zones) on the slope has opened the forest, allowing insolation to penetrate at the cost of increasing SE -S-SW wind vulnerabilities. Planting a red ironbark shelterbelt a long the rim, where soils become deep enough to support larger trees (north of the stunted stands that occupy the compacted soils), will address this vulnerability. The sheltering effect of the windbreak at the Mesa rim will extend across the entire cluste r zone. A healthy stand of ironbark already occupies part of the Mesa rim.

The forest on the slope has self -thinned to a more sustainable density of blue gums. Removing fine fuels and dispersing large fallen trunks will prepare the slope for new planting s of native understory shrubs and oaks, as well as a few karri ( E. diversicolor), near the top of the slope to diversify the canopy. But planting tall trees on the mid- and lower slope would reduce insolation at the base of the slope so should be mostly avoided.

On the northern edge, the fuels management grid cells 23A, 24A, and 24B are sensitive areas and maintaining the taller vertical structure is imperative. Closer to the cluster zone, canopy gaps that create N and NW vulnerabilities can be closed by l arge trees. Riparian restoration along Deveraux Creek can establish sycamores, cottonwoods, and willows on that stretch, once the ash trees are selectively removed. Adding California bay to the mix would provide an evergreen species. Between the riparian zone and the cluster zone, planting well -spaced tall eucalyptus, especially karri (E. diversicolor), will eventually fill these gaps – the trees should grow well on the bottomland soils.

These recommendations consider the whole site with regard to monarch habitat. However, the cluster site is bisected by a property line – City of Goleta owns the western section, and the Rancho Estates owns the eastern section. We recommend that actions – primarily the rim ironbark shelterbelt - be taken on the Goleta prope rty now and that the other actions in the bottomland be taken with permission from property owner.

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5.4.2 Recommendations for Ellwood East Restoration Actions The following are our recommendations for the restoration of Ellwood East and corresponds with Figure 39:
• Replace/replant dead monarch aggregation trees with blue gum eucalyptus. • Encourage the recruitment and establishment of blue gum saplings and existing trees. • Fuel treatment grids 23B, 24A, 24B are most sensitive and include riparian corridor (blue line in Figure 35)
• Remove most dead standing trees (shown in black in Figure 35) • Remove high fraction of downed wood, e specially finer fuels <10 inches diameter that prevent new growth.
• Remove accumulated small (<10 i n.) branches for fuel reduction. Raking out the accumulated debris.
• Separate large logs on the forest floor as practical. • Plant an ironbark shelterbelt along the crest of the Mesa slope (thick blue line in Figure 35) in an arc from southwest to south to southeast. The western part on Goleta property can be planting now, the south and southeast sections depend on agreement with the adjacent property.
• Plant red ironbark and karri (E. diversicolor) within orange oval north of cluster zone to address north-northwest vulnerability.
• Manage blue gums at current drought-thinned density on slope above cluster zone. • Fill in understory on slope with coast live oaks, toyons and other native shrubs.

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FIGURE 33A. HEMIPHOTOS TRANSECT LOCATIONS AT ELLWOOD EAST Dead standing (blue) and downed (yellow) shown over a color infrared photo. White oval is the cluster zone over the last decade.

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FIGURE 33B. EXAMPLE HEMIPHOTOS FOR ELLWOOD EAST
Hemiphotos 702,708,709, and 468 are in the cluster zone.

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FIGURE 34. POINT MAPS OF HEMIPHOTO RESULTS AT ELLWOOD EAST

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FIGURE 35. ELLWOOD EAST VULNERABILITIES AND RECOMMENDATIONS FOR RESTORATION Cluster sites are small white circles within the larger ellipse.

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5.5 Ellwood North
Ellwood North is a large rectangle of eucalyptus forest. Monarchs have aggregated historically in the northern portion of this area and more recently closer to the center of the a rea, as shown on Figure 36. We have examined both locations and refer to them as Ellwood North -North (the northern location) and Ellwood North-Central (the central location).

5.5.1 Current Conditions at Ellwood North-Central
Ellwood North- Central (NC) is the area south of the cross trail in Ellwood North and has the most current potential for cluster sites within Ellwood North area. Monarch clusters greater than 20 individuals were last observed during the 2017- 2018 season. Since then, only single butterflies or groups of a few individuals have utilized the Ellwood NC site , see Figure 36 and Appendix C for monarch count data . The entire Ellwood North has experienced the most tree mortality, especially north of the cross trail in Ellwood North -North (NN). There are substantial areas of tree mortality within Ellwood NC, especially along the cross trail, but also scattered within the forest.

Photo 481 is located closest to the last historical cluster site and is approx. 33 m (108 ft.) south of the cross trail in an area that has not suffered as much tree mortality as further north, shown in Figure 37 A and B. This site is more exposed to the northwest (0.27 DSFU) than is optimal, see the data from the hemiphotos in Table 10. Photo 345 is located along the cross trail and clearly shows the extensive tree mortality to the north. Photo 342 is located along the inner edge of the eastern 100 ft fuels management buffer and is an example of the type of gaps along that edge that create wind vulnerabilities – in this case the key direction is southeast (0.36 DSFU).

TABLE 10. EXAMPLE HEMIPHOTO DATA AND COMMENTS AT ELLWOOD NORTH-CENTRAL Photo Cluster ISFU DSFU Max Exposure Comments
481 Historic 0.18 0.27 0.27 NW Near center of cluster zone 345 Historic 0.22 0.25 0.33 NW North-edge along trail, dead trees N
342 Shelter zone 0.21 0.32 0.36 SE West-edge at 100’ fuels border 350 Shelter zone 25 0.21 0.49 W West-edge
Unlike the other sites (Ellwood Main, West, and East) Ellwood North -Central does not have an obvious cathedral structure over a creek or gully. The historical cluster sites have been in small gaps in the forest. Overall ISFU within the cluster zone ranges from 0.13 to 0.23 ( Figure 38).

DSFU ranges from 0.19 to 0.30, indicating good exposure to insolation on an annual basis. In October and November, strong insolation (white/red) penetrates to the forest floor at several sites within the cluster zone. Directional exposure is varied, but most sites have one or more directions with excessive exposure; a few sites have low or moderate exposure in all directions.

Sites like Photo 481 appear suitable for clustering. But few monarchs appear or stay in Ellwood North (any part of it) and it has always been a secondary site among the Ellwood complex.

The main vulnerabilities at Ellwood North -Central are northeast, north, and nort hwest wind penetrating through the mortality zone north of the cross trail. The trail itself creates east and west vulnerability at either end. Mismanagement of the fuels buffer zone to the east could open the forest to northeast, east, and southeast winds.

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Removal of the dead standing trees is a high priority. Management of the downed fuels – removal of finer fuels (less than approx. 10- inch diameter) and spreading out of the large , downed trunks will prepare the ground for plantings. The main plantings to address the wind vulnerabilities are to seal up the edge just south of the cross trail with a red ironbark shelterbelt (double row), establish an inner red ironbark shelterbelt on the east side at the 100 ft fuel management line, and establish an inner red ironbark shelterbelt along the west side. In the interior of the forest, it will be important to maintain the existing blue gum trees, encourage blue gum saplings , and plant some well -spaced karri ( E. diversicolor) to add diversity. There is sufficient depth of forest south of the cluster zone for wind shelter. Maintenance of some gaps within the sheltered area may be necessary in the long term.

The vulnerability of the blue gum forest in Ellwood North in general to drought resulted from tight spacing (approx. 6 ft.) of trees, and exuberant growth of coppiced (multi trunk) trees during wet periods. When the 2012- 2016 drought intensified, these areas were primed for mass mortality because of the dense growth, thinner soils, and upland topographic position. The forest has thinned to a density commensurate with the drought intensity, so future management should aim to avoid densification of the blue gums. There is plenty of room in the understory for native shrubs (toyon grows well in this area) and live oak trees.

5.5.2 Recommendations for Ellwood North-Central Restoration Actions The following are our recommendations for the restoration of Ellwood North- Central and corresponds with Figure 39:
• Replace/replant dead monarch aggregation trees with blue gum eucalyptus. • Encourage the recruitment and establishment of blue gum saplings and existing trees. • Fuels management (10 A, B, C, 11A, B) is very sensitive area. • Removal of most dead standing trees (shown in black in Figure 39) • Remove high fraction of downed wood, especially finer fuels <10 inches diameter that prevent new growth.
• Separate large logs on the forest floor as practical. • Plant shelterbelts at 100’ limit of fuels management grid. Multistoried with red ironbark as canopy and understory native shrubs and oaks
• Reinforce western edge shelterbelt as needed.
• Reinforce northern edge (just south of cross trail) with double ironbark row. • Plant karri (E. diversicolor) within interior to diversify the overstory. • Maintain lower density of blue gums established after drought.

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FIGURE 37A. HEMIPHOTO

TRANSECT LOCATIONS AT

ELLWOOD NORTH CENTRAL
Map with 50 m Grid. Dead
standing (blue) and Downed
(yellow) shown over a c olor
infrared photo. Lighter shaded
grids are fuel management areas.

FIGURE 37B. EXAMPLE

HEMIPHOTOS AT ELLWOOD NORTH

CENTRAL

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FIGURE 38. POINT MAPS OF HEMIPHOTO RESULTS AT ELLWOOD NORTH-CENTRAL

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FIGURE 39. ELLWOOD NORTH-CENTRAL VULNERABILITIES AND RECOMMENDATIONS FOR

RESTORATION

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5.5.3 Current Conditions at Ellwood North-North
Ellwood North-North (NN) is the area north of the cross trail in Ellwood North and is one of the epicenters of tree mortality (Figure 40A). Monarchs were last observed roosting north of the cross trail over 10 years ago , see Figure 36 and Appendix C for monarch count data . Ellwood North-North has lost virtually all habitat value for overwintering monarchs that once clustered in the southern part of this zone because the forest has opened to the point where wind vulnerabilities from most directions are widespread. Because of this, Ellwood North-North has a lower potential to become overwintering habitat and is therefore a lower priority for restoration ; the adjacent area at Ellwood North -Central has much higher restoration potential. The Ellwood North-North area has better nectar habitat potential and can be managed with an open eucalyptus overstory with a diverse native understory, including nectar plants in open areas.

Hemiphotos were taken primarily along the east and west edges, and along the cross trail at the south end of this area. Four examples are shown in Figure 40B with dead standing trees (blue) and downed trees (yellow) shown over a color infrared (CIR) photo; note the dead standing trees in Photos 3 56 and 362. Photo 332 is in the middle of a large clearing. There are wind vulnerabilities in many directions in these photos.

The point maps of the hemiphoto results show the openness of the canopy at site, see Figure 40B and Figure 41. The majority of the ISFU values are above 0.30 ( shown in white -red), except at the southern boundary along the cross -trail (which is considered more deeply in Ellwood North- Central account). There is h igh annual insolation (DSFU), again except for the denser forest along the cross trail and very high insola tion at ground level October -February throughout the site, with a few exceptions. All of these results point to a very open site with very little habitat suitability for overwintering monarchs. Directional Exposure is high in most direction at most sites ( red wedges predominate), again only at the cross trail are there less exposed sites, see values in Table 11.

TABLE 11. EXAMPLE HEMIPHOTO DATA AND COMMENTS AT ELLWOOD NORTH-NORTH Photo Site ISFU DSFU Max Exposure Comments
332 Shelter zone 0.46 0.64 0.58 N Near center of stand
333 Shelter zone 0.41 0.70 0.60 W On east-end, at 100’ fuels border 356 Shelter zone 0.32 0.41 0.52 N Near west-edge
362 Shelter zone 0.25 0.19 0.42 NE Northwest section
No detailed vulnerability map was produced because there are so many vulnerabilities that can be seen in the point maps in Figure 41. Widespread tree plantings for monarchs at this site should be dela yed until the other higher priority sites are planted. The recommended plantings of an ironbark shelterbelt south of the cross trail are primarily for Ellwood North -Central. Nectar plants in the understory at Ellwood North-North could help attract butterflies to Ellwood North- Central.

A limited area within this site could be designed with a circular shelterbelt to create a wind - protected gap, but that detailed design should wait until Phase 2.

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5.5.4 Recommendations for Ellwood North-North Restoration Actions The following are our recommendations for the restoration of Ellwood North-North:
• Replace/replant dead monarch aggregation trees with blue gum eucalyptus. • Encourage the recruitment and establishment of blue gum saplings and existing trees. • Fuels management (9A, B, C, D, 10A on Figure 40A) are less sensitive than in other fuel management areas.
• Removal of most dead standing trees
• Remove high fraction of downed wood, especially finer fuels less than 10 -inches diameter that prevent openings for plantings and new growth. • Separate large logs on the forest floor as practical. • Ellwood North-North is an excellent place to practice wood removal because it is not a high sensitivity area.
• Plant native shrubs and forbs, with nectar plants in sunny interior areas. Take advantage of some swales where goldenrods (Solidago sp.) are already established as a native fall - blooming nectar source.
• Nectar plants at Ellwood North -North would help attract butterflies that might cluster at Ellwood North-Central.

FIGURE 40A. HEMIPHOTO TRANSECT

LOCATIONS AT ELLWOOD NORTH-
NORTH
Hemiphoto is shown over a color
infrared photo. Map with 50 m Grid.

Dead standing trees are indicated in
blue and downed trees are indicated in
yellow.

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FIGURE 40B. EXAMPLE HEMIPHOTOS

AT ELLWOOD NORTH-NORTH

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FIGURE 41. POINT MAPS OF HEMIPHOTO RESULTS AT ELLWOOD NORTH-NORTH

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5.6 Ellwood Ironbark

5.6.1 Current Conditions at Ellwood Ironbark
The Ellwood Ironbark area is at the south west corner of Ellwood North. A stand of red ironbark (Eucalyptus sider oxylon) is between a grove of blue gums along the drainage channel to the west, and a stand of blue gums to the east (Figure 43A). A few monarch observations were recorded in 2019, see Figure 42 and Appendix C for monarch count da ta. The area east of the major trail suffered massive tree mortality. All the dead standing trees (shown in blue) and downed trees (shown in yellow) in the map are blue gums; no whole -tree ironbark mortality was noted. The red ironbark trees are planted close together (3 -6 ft), and many stumps have multiple stems and form very dense stands that are highly effective at blocking the wind. But the dense canopy blocks insolation, except in narrow gaps along trails (Photos 393 and 394, Figure 43B).

There is a double row of ironbarks running east -west at the south end of the stand, with a narrow trail on the north-side. Photo 387 shows how effective this double row is for re ducing south exposure, as well as the narrow east -west gap along the trail. The interior is very dark (Photos 393 and 394), and Photo 394 shows an elongated gap along the narrow north- south trail through this area. Along the drainage in the blue gums, dead standing trees are visible to the southwest (Photo 400) and the elongated gap along the creek runs southwest to northeast. Table 12 shows the ISFU and DSFU values and comments for the four example hemispherical photos.

Hemiphotos were taken in 3 transects, shown in Figure 44. One transect ran east-west along a narrow trail behind a double row. A second transect ran north-south through the ironbark stand along a narrow trail. The third transect ran along the drainage bottom toward the west end. The hemiphoto point maps show that the interior is very dark. ISFU values are all less than 0.125, and some less than 0.10 (Figure 44). There is a relatively higher insolation site just south of the proposed gap, a result of the narrow north- south trail. The south- edge transect shows higher ISFU and insolati on at the west and east ends, where the trail opens. The interior has low directional exposure in nearly all directions (note the preponderance of blue wedges along the north-south trail). The low south exposure along the east -west trail is the basis for proposing a double row of red ironbarks as the basic shelterbelt design. Note that exposure is high (red) at the ends of this trail where it opens, and moderate (yellow) at 20 m (70 ft) into the stand along the trail. T his pattern emphasizes that trail openings need to be carefully designed to avoid wind tunnel effects. The transect along the drainage channel has one site in the optimal ISFU range (shown in green) but that site has moderate to high southwest, south, and west exposur e. The sites farther south have lower ISFU, as well as moderate south exposure. This drainage channel site has only a thin green line west of the channel to provide shelter.

TABLE 12. EXAMPLE HEMIPHOTO DATA AND COMMENTS AT ELLWOOD IRONBARK Photo Cluster ISFU DSFU Max Exposure Comments
393 Shelter zone 0.10 0.16 0.20 S W side of proposed opening 394 Shelter zone 0.08 0.14 0.60 W S of proposed opening 387 Shelter zone 0.12 0.19 0.20 W S-edge interior
400 Shelter zone 0.12 0.23 0.23 W Along drainage channel

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5.6.2 Recommendations for the Creation of a New Site at Ellwood Ironbark The major recommendation for Ellwood Ironbark is the creation of a new gap in the well - protected interior of the ironbark stand where insolation is currently too low to be suitable for roosting monarchs . In 2022, Weiss and a crew from Rincon Consultants tagged 17 trees for potential removal to initialize a gap that is approximately 10 x 15 m (33 by 50 ft). This is viewed as an experiment – the effects on canopy cover and insolation will be evaluated and further removal considered. Such gap creation has been executed at 3 other sites – Monarch Lane (Los Osos, SLO County) in the 1990s, Point Pinole (Richmond, Contra Costa County) and Andrew Molera State Park (Big Sur, Monterey County), both in 2022. At Monarch Lane, the monarchs use the gap, and it has been successful over time in providing a w ind-sheltered, high insolation site.

As part of the gap creation, another recommendation is to fill in the forest just to the east with red ironbark and karri, as replacements for the dead trees and to bolster wind shelter from that direction. This is consistent with some previous mitigation requirements that are described in the planting plan.

The following are our recommendations for the restoration of Ellwood Ironbark:
• Remove most dead standing trees (shown in black in Figure 45) • Remove high fraction of downed wood, especially finer fuels <10 inches diameter that prevent new growth.
• Remove some accumulated litter within ironbark stand for fuel reduction. • Separate large logs on the forest floor as practical. • Create a small gap as indicated, removal of ~17 trees initially. • Maintain the double wind row of ironbark trees for a wind shelter zone. • Plant ironbark and karri (E. diversicolor) within blue circle for wind shelter. • Maintain lower density of blue gums established after drought. • Manage massive dieback zone for native understory, live oaks.

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FIGURE 43A.

HEMIPHOTO

TRANSECT

LOCATIONS AT

ELLWOOD IRONBARK
Dead standing
(blue) and downed
(yellow) shown
over a color infrared
photo. The bright
white dots are the
locations of trees
marked for potential
removal to create a
hospitable gap for
monarchs.

FIGURE 43B. EXAMPLE

HEMIPHOTOS AT ELLWOOD

IRONBARK

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FIGURE 44. POINT MAPS OF HEMIPHOTO RESULTS AT ELLWOOD IRONBARK

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FIGURE 45. ELLWOOD IRONBARK RECOMMENDATIONS

5.7 Sandpiper
Restoration of the Sandpiper monarch site will be includ ed in MBHMP Implementation Phase 2.

We will discuss analysis and rest oration recommendations in a future update for future reference and planning.

5.8 Ocean Meadows
Restoration of the Ocean Meadows monarch site will be included in MBHMP Implementation Phase 2. We will discuss analysis and restoration recommendations in a future update for future reference and planning.

5.9 Extent of Forest Death
Comparative photographs from 2011 and 2017 illustrate the significant canopy loss throughout the eucalyptus forest at Ellwood Mesa (Photos 7-16) (Meade et al. 2017). The 2011 photos show the tree canopy during conditions with plentiful rainfall and extensive growth. The 2017 photos show the same location after several years of extended drought. Thick canopies are present in the 2011 photos, while dead trees and/or sparce trees with epicormic growth are visible i n the 2017 photos.

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A health assessment was conducted in 2017 on the trees in the five monarch aggregation sites (Meade et al. 2017). The assessment assigned a health rating to each tree: 0 - dead, 1 - dying or hazard tree (should be removed), 2 - distressed trees, poor structure and health (some may need to be removed depending on their importance to aggregation site) , 3 - tree with decent structure and health (should remain), 4 - tree with good structure and overall health (should remain ; Table 13).

TABLE 13. RESULTS OF 2017 TREE HEALTH ASSESSMENT AT ELLWOOD MESA North West Main East Sandpiper
Total trees assessed 94 54 184 33 47
Health rating (Average) 1.6 1.75 1.6 1.75 2.55
Dead (0) 22 (23%) 5 (9%) 32 (17%) 3 (9%) 0
Remove (0-1) 34 (36%) 10 (19%) 63 (34%) 8 (24%) 0
Dead or distressed (0-2) 73 (78%) 49 (91%) 165 (90%) 28 (84%) 23 (49%) Height of dead trees
(Average) 65 ft. 70 ft. 67 ft. 67 ft. n/a
Data source: Meade et al. 2017

Photo 7. Ellwood North monarch roost location,
2011 (photo by Daniel E. Meade).

Photo 8. Ellwood North monarch roost location,
2017 (photo by Daniel E. Meade).

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Photo 9. Viewing area at Ellwood Main, 2011
(photo by Daniel E. Meade).

Photo 10. Viewing area at Ellwood Main, 2017
(photo by Daniel E. Meade).

Photo 11. Monarch clusters at Ellwood Main,
2011 (photo by Daniel E. Meade).

Photo 12. Monarch clusters at Ellwood Main, 2017
(photo by Daniel E. Meade).

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Photo 13. Trail to bluffs east of Ellwood Main,
2011 (photos by Daniel E. Meade).

Photo 14. Trail to bluffs east of Ellwood Main,
2017 (right) (photos by Daniel E. Meade).

Photo 15. Trail to bluffs west of Ellwood Main,
2011 (photo by Daniel E. Meade).

Photo 16. Trail to bluffs west of Ellwood Main,
2017 (photo by Daniel E. Meade).

5.10 Wind and Monarch Movement between Ellwood Aggregation Sites Overwintering monarch butterflies require specific habitat conditions that offer them buffering potential from negative wind and temperature effects. Cool moist air that is sheltered from strong winds offer ideal habitat. Such conditions have historically been met in Ellwood Mesa, however, widespread forest dieback has jeopardized ideal habitat conditions and now pose a threat to overwintering monarch populations.

In Santa Barbara California, monarchs can typically be found in overwintering mode from October-February. In these months, warmed air escaping from the land interior means that the prevailing winds tend to blow from the north and/or east. Winds coming off the ocean, that blow from the south and/or west, tend to be cooler.

In the 2021/2022 season, overwintering sites were subject to strong and prolonged wind events from the east/southeast between December 13-14 in 2021. This event lasted for around 36 hours, and although average wind speed was only around 15 mph, wind gusts averaged 27 mph for up to 16 hours. These winds did not however, result in notable alterations to temperature and

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humidity. In the same season, at midnight on January 21, an unusual wind blew in from the northeast at 18 mph. This relatively isolated event increased the temperature by 15 degrees and decreased humidity by over 50%.

In the 2022/2023 season, overwintering sites were subject to strong and prolonged wind events from east/southeast between January 4-5. This event lasted for up to 40 hours but was especially severe between 8pm (Jan 4) – 5am (Jan 5). In these 9 hours, the average wind speed was around 16 mph, and gusts averaged 30 mph, with some gusting up to 38 mph. Temperature and humidity did not appear to be affected by this wind event. However, on January 22- 23, unusual north/northeast winds blew throughout the night with gusts up to 29 mph. The winds appeared to keep the temperature elevated and humidity low throughout the night. Upon cessation of the winds around 4am (Jan 23), the temperature quickly dropped, and humidity increased.

The winter months in Ellwood generally have tame winds, and although events of extended duration and gust strength, or of unusually warmth and dryness are infrequent, they appear to occur with some regularity from season -to-season. Historically, the topography of Ellwood, and habitat structure provided by eucalyptus and other trees have allowed some buffering capacity for the monarch butterflies.

Monarchs are sensitiv e to dehydration and seek areas of high humidity where available. They will avoid warm temperatures and seek the protection of cool moist post of air pools in the forest interior, where microsite conditions buffer them from warm dry air blowing from inland .

Monarchs are also sensitive to the cold and may freeze under certain conditions. If situations allow, monarchs may move around their roosting trees to find areas most suited to their needs.

However, the level of forest degradation that we currently see h as little buffering capacity and now may be incapable of protecting monarch populations from large weather fluctuations.

Wind data is included in Appendix E.

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6 RECOMMENDATIONS

6.1 Perform Deferred Maintenance

6.1.1 Strategic Fuel Reduction
The City of Goleta prep ared the Community Wildfire Protection Plan (CWPP) in 2012 and acquired a Cal Fire grant to fund the implementation of the fuel reduction strategy in 2022. The goal of the CWPP is to minimize the risk of wildland fire to life, homes and infrastructure, and natural resources. Our habitat analysis supports the recommendation to remove dead wood and downed debris outlined in the CWPP. The removal of dead wood and downed debris will reduce the fire risk to the forest, and this is crucial for the protection and longevity of the monarch habitat at Ellwood Mesa.

Dr Daniel E. Meade and Dr. Stu Weiss prepared a letter report titled “Dead wood removal and monarch butterfly habitat effects” dated March 9, 2022, which is included in Appendix F. This letter emphasizes the importance for the management of monarch overwintering habitat an d the removal of dead standing and downed wood. The Xerces Society guidelines for managing monarch groves stress the importance of removing hazard trees and felled debris (The Xerces Society 2017a). The 1993 Monarch conservation and management guidelines similarly state the importance of removing hazardous trees and the forest floor should be maintained to prevent the accumulation of dead plant materials (Bell et al. 1993).

The Meade and Weiss 2022 letter continues to explain that historically, Ellwood forests were managed to remove dead wood and maintain healthy stands of trees through normal forestry practices (Santos 1997, Meade personal observation). Failure to manage a grove results i n over recruitment of trees during periods of higher rainfall and then death of trees during times of water stress (droughts). Appropriately managing tree density based on water demand creates a more stable grove and is a fundamental tenet of forestry mana gement, even for groves managed for wildlife (Grebner et al. 2021, Taylor 2018).

The accumulation of bark and dead wood on the ground and leaning into the tree canopy creates a major fire hazard to monarch habitats (Xerces Society 2017a). Ignition from campfires and other human sources can feed on ground debris and quickly escalate int o a catastrophic fire event. This risk can be managed by reducing fuel load through removal of dead branches, trunks and highly flammable vegetation that can create fire ladders into the forest crown. The Ellwood groves, once managed for wood production, now present a tangle of downed wood, dead leaning trunks, and over abundant understory shrubs. The City of Goleta Community Wildfire Protection Plan (2012) provides management recommendations to reduce, “potential fire intensity, rate of spread, and severit y of effects” (pg . 58). Management prescriptions in the CWPP when implemented will help to protect life, property, and natural resources including monarch butterfly habitat.

The presence of large quantity of dead wood at Ellwood results in:
• Increased wind penetration and speed at aggregation locations due to downed trees, • Higher tree-fall risk to remaining live trees,
• Reduction in shade at aggregation sites,
• Loss of cover for butterflies from predators,
• Poor recruitment and growth of replacement trees,
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• Increased wildfire risk - intensification of fires and a fire ladder to canopy, and • Public safety hazard from dead standing and leaning trees and ground debris.

Removal of dead wood from the Ellwood forests and monarch groves will have positive effects for monarch butterflies. The benefits include:
• Removal and replacement of dead trees will increase humidity and shade and boost protection of monarchs as they grow to maturity in the next decade. • Removal of downed trees and branches eliminates debris tangles that interfere with recruitment of saplings and growth of trees with good form. • Space for planting trees and shrubs will be opened by removing dead wood. • Removal of leaning dead trees and branch and debris tangles will improve patrolling and clustering habitat for monarch butterflies.
• Reduction of hazards for visitors to the grove
• Preservation of habitat by reducing intensity and rate of spread of fires.

Maps showing the abundance of dead wood is shown in Figure 5 - Figure 12 in Section 4.4.2.

6.1.2 Prepare Restoration Areas
Removing the standing dead trees and downed wood, disc ussed in Section 6.1.1, will open up space for new plantings . Downed wood on the forest floor takes up a large area and we would have difficulty finding available open ground for new plantings. Photo 17 shows the grandeur of the downed wood in the Ellwood Mesa forest. After the removal is conducted, care may be necessary to prepare the recommended areas for plantings. These actions may include removing litter, removing non-native and invasive weeds, and smoothing out disturbed soil surface.

Eucalyptus debris does not break down as quickly as native vegetation and bark debris that accumulates on the ground retains nutrients and can inhibit new growth. Fallen blue gum eucalyptus trees decompose very slowly (DiTomaso et al. 2013), especially in dry climates. The high level of phenolics in eucalyptus inhibits fungi from breaking down the wood and allows accumulation of fire fuel (Reid et al. 2005). Chipping will aid the release of nutrients from woody debris by converting coarse wood to fine pieces (Russell et al. 2015). Mulching around new forest plantings can increase planting survival and growth rate (Cahill et al. 2005, Chalker - Scott 2007).

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Photo 17. Extensive area with mass of dead, downed trees (Photo by Kyle Nessen).

6.2 Restore Aggregation Trees and Wind Protection
After the dead standing trees are removed, the restoration of the monarch aggregation locations and the surrounding wind protection zones is crucial for the longevity of the monarch habitat.

6.2.1 Restore Aggregation Trees
The monarchs have chosen specific recurring locations in Ellwood Mesa and the trees they return to year after year are v ery important for their overwintering roosting success. In areas where the monarch aggregation trees have died and have been removed, we recommend replacing these trees with blue gum eucalyptus plantings. Specific locations of these aggregation tree replacement plantings should be identified by a monarch butterfly biologist on the ground. C are should be taken to retain and protect the integrity of the open interior within the monarch aggregation sites.

6.2.2 Protect and Support Existing Live Trees
The existing tree canopy is vital to the continued health of the Ellwood Mesa forest for overwintering monarchs. We recommend encouraging seedlings and saplings, especially of blue gum eucalyptus trees, within the monarch aggregation sites. This will requi re the removal of dead and downed wood for fuel management to be conducted carefully to avoid unintentional impacts to existing young trees and clearing away the debris around seedlings and saplings. We recommend consultation with an arborist to explore me thods of irrigation and fertilization to maximum the survival of existing trees.

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6.2.3 Double Wind Row Design
The wind vulnerabilities throughout the Ellwood Mesa require reinforcement in order to provide adequate wind protection and maintain suitable wind spe eds in m onarch butterfly aggregation areas. Reinforcement of these areas is determined by the distribution and density of the existing foliage and the terrain around the aggregation sites, and the characteristics of species included in the reinforcement.

We designed a layout of tree planting that includes two rows of red ironbark with a row of toyon in front of it. This layout is referred to as the ‘double row’. The intention of the design is that the red ironbark will provide most of the wind protection while the toyon plugs any gaps in the lower canopy. This will create a continuous wall of canopy from the ground to the top of the canopy and thus a solid wall of wind protection. The red ironbark is spaced out with 20 feet between each tree’s center, one ro w staggered from the other, with toyon also spaced 20 f eet from one another in a row 40 feet in front of the back row of red ironbark ( Figure 47). The 20- foot spacing is intended to limit competition amongst trees in the double row, allowing for sufficient resources to grow to the desired mature size. This design can be used in areas where existing foliage and terrain are the thinnest, requiring substantial reinforcement to maintain suitable aggregation site conditions.

Red ironbark is favorable for the design because of its observed success on Ellwood Mesa, drought tolerance, fast growth rate, dense canopy, and mature canopy height of approximately 80 ft (approx. 24 m). Toyon is a favorable compliment to red ironbark because it is also established on Ellwood Mesa and grows to a mature height of 20 ft (6 m), which covers areas in red ironbark’s lower canopy that naturally thin in maturity.

To quantify the wind protection provided by this design we simulated an ideal version of the layout in an isolated environment. We simulated the effects of winds encountering the double row head on and the resulting wind shadow on the leeward side of the double row ( Figure 46).

We ran iterations of this test with the double row plants at three different ages and thus heights:
early establishment, intermediate, and mature (Table 14).

TABLE 14. DOUBLE ROW GROWTH CHART
Species Height Early Establishment Intermediate Maturity Red ironbark 10 ft (3.05 m) 40 ft (12.2 m) 82 ft (25 m) Toyon 3.3 ft (1 m) 6.6 ft (2 m) 20 ft (6 m)

SuitableMarginal059 mph
Figure 46. Ideal Double Wind Row Simulation
Early Establishment
Intermediate
Mature Conditions
Observed Monarch aggregation zone relative to canopy edge

Figure 47. Double Row Layout
Figure 48. Double Row Species Models
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6.2.4 Wind Modeling at Ellwood Main
We conducted simulations of microclimate wind conditions at Ellwood Main during a southwest storm event in order to assess the efficacy of our restoration plans. We evaluated four scenarios:

Existing Conditions, Early Establishment, Intermediate Conditions, and Mature Conditions (see Figure 49). Existing scenarios included three stem categories (living, standing dead, and dead downed), as well as ve getation not classified as stems (See Figure 50). All other scenarios included only living stems (See Appendix B for more details). The Early Establishment scenario represented 0-5 years after planting, when trees are allowed to grow to 10 ft in height and dead wood has been removed to make space for new plantings. Intermediate Conditions scenario is when trees reach 40 ft in height, approximately 10- 15 years after planting. Finally, Mature Conditions are when tree heights have reached existing conditions and replaced lost forest canopy.

Figure 51, Figure 52, and Figure 53 shows wind conditions within the m onarch clustering area for the four simulated scenarios. Existing conditions show mostly marginal conditions with some pockets of favorable wind speeds. Early Establishment, however, reveals a decrease in habi tat quality primarily due to the removal of standing dead wood. While this result is not ideal in the near term, any protection from dead standing wood is temporary and poses a safety risk to hikers and remaining living trees. Any restoration plantings wil l also be inhibited by existing dead wood, and inevitable felling could damage newly planted trees. Thus, we recommend removing the dead wood now so that we can address the issues previously mentioned and begin restoring Ellwood Main for the long-term management of monarch butterfly habitat. See Section 5.10 for a discussion on the adaptability of monarch butterflies and how they have historically used other parts of the forest when conditions have turned unfavorable at Ellwood Main.

Intermediate Conditions show when wind favorability meets or exceeds Current Conditions within the clustering area, as well as an improvement in habitat quality along the eastern edge of Ellwood Main. Finally, at Mature Conditions, the clustering area is almost entirely in suitable wind conditions , suggesting that when fully implemented, restoration activities will imp rove habitat conditions for monarch butterflies for many decades to come.

Existing ConditionsEarly Establishment
Intermediate Mature
Figure 49. Wind Modeling Scenarios
Monarch viewing area

Living Stems Standing Dead Stems
Dead Downed StemsAll Classified Stems
Figure 50. Existing Conditions Classified Stems
Monarch viewing area

Existing ConditionsEarly Establishment
Intermediate Mature Conditions
Figure 51. Above Ground Wind Conditions (30 ft)
SuitableMarginalExcessive05930+ mphExtent of clustering monarch butterflies Extent of existingtree canopy
Existing ConditionsEarly Establishment
Intermediate Mature Conditions
Figure 52. Wind Conditions within Clustering Area
SuitableMarginalExcessive05930+ mph
Extent of clustering Monarch butterflies

Existing ConditionsEarly Establishment
Intermediate Mature Conditions
Figure 53. Vertical Profile of Wind Conditions at Viewing Area SuitableMarginalExcessive05930+ mph
Monarch viewing area

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6.2.5 Ellwood Main Prescriptions
To address the vulnerabilities identified in this report (See section 5.2), additional tree planting is recommended around Ellwood Main. Figure 54 shows specific planting areas and outlines the recommended species and spacing of these trees.

Along the southern edge of Ellwood Main, a double row planting of red ironbark (Eucalyptus sideroxylon) should be implemented within the boundaries of the existing canopy. Tree planting should generally follow the design outlined in Section 6.2.3; however, conditions on the ground will determine final planting locations and deviations from the idealized plan. Outside the southern existing canopy, toyons (Heteromeles arbutifolia) should be planted roughly 20 ft apart to act as an understory buffer as the red iron bark grow out. Inside the double wind row and edge of canopy, karri (Eucalyptus diversicolor ) should be planted to replace blue gum loss. This species has been identified as having several advantages in this environment (See section 3.4 for additional details).

The monarch aggregation trees are b lue gum (Eucalyptus globulus) trees along the west and east slopes of the gully at Ellwood M ain. Several of the recurring aggregation blue gum trees have died and the loss of roosting substrate is substantial. These aggregation trees should be replaced with blue gum eucalyptus trees in similar locations along the west and east slopes and the blue gums should be planted at 20 ft spacing. Along the higher slopes of Ellwood Main that occur outside of the recurring aggregation trees , karri should be planted at 50 ft spacing. Wherever possible, blue gum regrowth should be encouraged, and planting should consider this potential.

This is shown in the Sparse Planting polygon on Figure 54.

North of the Ellwood Main and adjacent to Devereux Creek, several native species should be planted, specifically sycamore (Platanus racemosa) , California bay laurel (Umbellularia californica), and cottonwood (Populus fremontii), to seal the north gap vulnerability. In areas of fuel removal along the neighborhood boundary, special care should be taken around existing large trees that provide critical protection. Across the creek , karri should be planted at 40 ft spacing.

Finally, in the grove west of Ellwood Main, blue gum regrowth should be encouraged where possible and karri and blue gum should be planted to fill in gaps. Planting should be no closer than 50 ft apart. Separate fallen logs where applicable, a nd remove high fraction of downed wood, especially finer fuels that are less than 10 inches in diameter.

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6.2.6 Ellwood West Prescriptions
The Ellwood West aggregation site sit s above Devereux Creek and is composed of blue gum trees to the north and south of the creek . Due to extensive die -off, particularly on the south side of Devereux Creek, there are now vulnerabilities in wind protection. To remedy this, we recommend removing the existing dead wood, replacing dead aggregation trees with blue gum , and planting karri sparsely to fill in the area surrounding the aggregation trees. Tree planting should be 50 ft spacing where large gaps in the canopy exist. Finer fuels, less than 1 0 inches in diameter, should be removed to promote new growth. Existing blue gum eucalyptus regeneration should also be encouraged wherever possible.

At the edge of canopy, double wind rows are recommended for the north and south face of Ellwood West. On the north face, coast live oaks (Quercus agrifolia) and toyons are encouraged outside of existing canopy at approximately 20 ft spacing. On the south face, only toyons are recommended outside of existing canopy, also at 20 ft spacing. East of Santa Barbara Shores trailhead, we recommend maintaining the density of existing red iron bark stand with karri.

Along Devereux Creek, native trees should be planted but not within 50ft of monarch aggregation trees. Care should be take to protect and maintain the open interior along the creek near the monarch aggregation trees. All plantings shall stay out of jurisdictional wetland delineations. Specific planting areas and recommendations are detailed in Figure 55.

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6.2.7 Ellwood North Prescriptions
Based on our analysis of Ellwood North, we recommend a significant restoration effort to restore Ellwood North to its historic overwintering conditions. Fuel management in the area is less sensitive, and removal of dead standing, dead downed, especially finer fuels, is recommended wherever practical. Separate large logs and remove fine fuels as needed. Ellwo od North is an excellent opportunity to refine fuel management within the groves as it currently offers the least habitat quality for overwintering monarchs.

Along the western face, we recommend a double row windbreak spanning approximately 1,200 ft. Plantings should include red iron bark within existing e ucalyptus canopy where space exists, and oaks and toyon outside of eucalyptus canopy.

Along the eastern face, a double wind row as described above is recommended for the northern half, beginning at the trail that bisects the habitat from west to east. South of the trail on the eastern side, we recommend planting karri and red iron bark to close the wind vulnerabilities .

Toyons and oaks are recommended outside of existing canopy as described in the double row design. All plantings on the eastern side of Ellwood North shall occur outside the 100ft fire safety perimeter.

Along the bisecting trail mentioned previously and the similar trail further south, we recommend planting red iron bark carefully placed at the direction of restoration experts to fill gaps.

In the interior spaces created by the windbreaks , replace dead monarch aggregation trees with blue gum eucalyptus a nd create or retain open interior s. Sparsely planted karri trees are recommended where canopy is thin. Plantings should be no closer than 50ft. Wherever possible, existing blue gum eucalyptus regeneration should be encouraged, as well as natives such as coast live oak and toyon. Interior open spaces should encourage native forbs and nectaring plants .

Encourage existing plants where available, such as (Solidago sp.).

See Figure 56 for specific planting area recommendations.

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6.2.8 Ellwood East Prescriptions
We recommend replacement of dead monarch aggregation trees with blue gum eucalyptus .

Existing live trees should be supported, and regeneration should be encouraged. We suggest planting karri sparsely around the monarch aggregation trees , no closer than 50ft apart in these areas. Additionally, we recommend planting a double wind row of red ironbark on the south side of the eucalyptus canopy to close the south wind vulnerabilit y and planting red ironbark and karri north of Devereux Creek to address the north-northwest wind vulnerability. Coast live oaks, toyons and other native shrubs can be used to fill in the understory.

All fuel treatment should take careful consideration on the north side of Devereux Creek and along neighborhood boundary. Remove dea d standing wood and reduce fuels on the ground wherever practical. Because Ellwood East aggregation sites only partially occur on city property, restoration activities are limited to the western extent.

See Figure 57 for specific areas where planting is recommended.

See Section 5.4 for a full description of the current status of Ellwood East and identified vulnerabilities.

6.2.9 Ellwood Ironbark Prescriptions
See Section 5.6 for a full description of the current status of Ellwood Ironbark Site.

6.2.10 Sandpiper Prescriptions
The restoration of the Sandpiper site will be addressed further in Phase 2 of the Implementation.

To inform restoration efforts, a double wind row with red ironbark should be planted along the trail on the north side of Devereux Creek. Native trees, such as oak and toyons can be planted to reinforce the boundary. On the south side of the creek where the two trails converge, additional red ironbark planting is recommended, along with native trees and shrubs.

The most important area of restoration is along the western boundary of Ellwood Mesa and Sandpiper Golf Course. Loss of trees has resulted in significant vulnerabilities to wind protection. We recommend planting red ironbark along the western boundary of Ellwood Mesa and work with Sand Piper Golf Course to plant additional trees for greater resiliency. We recommend that dead monarch aggregation trees be replaced with blue gum eucalyptus and the existing blue gum should be supported and regeneration encouraged.

Fuel management should focus on removing dead downed wood and reducing fuel loads. Large logs can be left on site but moved as practical to allow for tree planting. Fine fuels (less than 10 inches in diameter) shall be either mulched or removed from site.

See Figure 59 for recommended planting areas.

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6.2.11 Ocean Meadows Prescriptions
The restoration of the Sandpiper site will be addressed further in Phase 2 of the Implementation.

To inform restoration efforts, tree planting shall focus on the western side of the aggregation site that occurs on Ellwood Mesa. We recommend filling holes on outer edge of canopy with red ironbark where necessary. Encourage regeneration of existing blue gums where possible and use native trees and shrubs within and outside the existing canopy to reinforce wind protection.

Planting shall not occur in jurisdictional wetlands.

See Figure 60 for tree planting locations.

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7 DISCUSSION
The multi -generational journey of monarch butterflies is one of the most famous examples of migration in the animal kingdom (National Geographic Society 2022) . Every year, monarch butterflies in western North America travel up to thousands of miles from their summer breeding grounds to gather in dense clusters along the California coast. One of the best places to view this natural phenomenon was Goleta Monarch Butterfly Grove at Ellwood Mesa, a widely recognized site of importance for overwintering butterflies. For decades, residents and visitors enjoyed the opportunity of observing the butterflies up close and in tremendous numbers, evoking feelings of appreciation and fostering calls for conservation.

Historically, the eucalyptus groves at Ellwood Mesa created ideal habitat conditions for monarchs. Large trees with varied canopies allow for "dappl ed light," where monarch butterflies can seek either shade or sun to moderate their body temperature throughout the day. Dense foliage acts to increase humidity within the grove, slowing the rate of desiccation of the butterflies and reducing the need for them to seek out water. D uring strong storm events, the trees provide critical wind protection that would otherwise cause butterfly mortality. This extensive forest was, at one time, the largest plantation in California (Farmer 2013), leading to numerous named overwintering sites both presently and historically.

Until the 1990s, Ellwood Mesa was actively managed through forestry practices, such as felling dead trees, harvesting firewood, and thinning live branches (Santos 1997). However, when the City of Goleta acquired the property in 2005, forestry activities ceased, leaving the grove largely unmanaged. Since then, periods of wet and dry seasons have caused stretches of growth and dieback of the forest canopy. The most significant of these periods was between 2012 and 2016, when unprecedented drought conditions led to a dramatic loss of trees throughout the Mesa.

Thousands of trees died and remain on site today. Deferred maintenance of dead and downed wood at Ellwood Mesa create imminent danger to human safety, neighboring homes, and monarch overwintering habitat. High fuel loads present an extreme fire hazard while standing dead trees pose a risk to the thousands of hikers who visit this area each year. Additionally, fallen wood inhibits restorati on activities, and risk of tree fall from standing dead trees threaten live trees and future planting efforts.

Our findings document that the loss eucalyptus trees at Ellwood Mesa caused a marked decline in the quality of overwintering monarch habitat. At all aggregation sites, reduced canopy cover corresponded with fewer overwintering monarchs, as well as increased instability in movement between sites - indicating a heightened vulnerability to adverse weather conditions.

To restore habitat quality, we r ecommend first strategic removal of existing fuel loads around identified aggregation sites. Second, we recommend planting additional trees and encourage regeneration of existing blue gums (Eucalyptus globulus ) wherever possible. We recommend strategic re moval of dead wood, removal of ground fuels, and planting of specific species in designed and tested configurations. Chipping and mulching downed wood and planting new trees will all aid in the process of restoring a healthy forest and ensuring resilient w ind protection zones.

For an effective wind break along the periphery of the existing canopy, we propose a new tree planting design—the double wind row —with drought-resistant red ironbark (Eucalyptus sideroxylon). Within the interior of the groves and where blue gum regeneration is not present , we recommend planting karri ( Eucalyptus diversicolor). This species of eucalyptus is Althouse and Meade, Inc.

Habitat Analysis and Recommendations for Ellwood Mesa, City of Goleta 128 April 2023
comparable in size and structure to blue gum and has two distinct advantages: it is ad apted to Mediterranean climates, and does not reproduce spontaneously in California, mitigating invasive potential that blue gums bring. While we recognize blue gums characterize much of Ellwood Mesa, they were overwhelmingly impacted by the 2012- 2016 drought. A diversity of tree species will minimize the potential of a future mass die-off.

Trees are our best tool for restoring monarch overwintering habitat. In arid southern California, eucalyptus species are especially useful for their ability to grow large quickly. Unfortunately, given the imperiled state of monarch populations, the time window for restoration through trial and error is gone and the time for iteration is minimal. time to act is now to address this challenge, our wind simulations informed our planting designs for Ellwood Mesa to ensure new trees and shrubs , when mature, will offer sufficient wind protection. Although our simulations are specific to Ellwood Mesa, our planting principles can be applied to other overwintering sites in California. Ultimately, we hope this report serves as a starting point for land managers seeking to restore damaged overwintering monarch habitat.

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EUCLID. 2020. Eucalyptus diversicolor. In Eucalypts of Australia Fourth Edition. Center for Australian National Biodiversity Research (CANBR). Available at https://apps.lucidcentral.org/euclid/text/entities/eucalyptus_diversicolor.htm.

Farmer, Jared. 2013. Trees in Paradise: A California History. W. W. Norton & Company Inc., New York.

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Grebner, Donald, Pete Bettinger, Jacek Siry, and Kevin Boston. 2021. Introduction to Forestry and Natural Resources. 2nd Edition, Academic Press.

Green PT, O'Dowd DJ, Abbott KL, Jeffery M, Retallick K, Mac Nally R. 2011. Invasional meltdown: invader-invader mutualism facilitates a secondary invasion. Ecology. 2011 Sep;92(9):1758-68. doi: 10.1890/11-0050.1. PMID: 21939072.

Griffiths, J., and F. Villablanca. 2015. Managing monarch butterfly overwintering groves:
making room among the eucalyptus. California Fish and Game 101:40-50.

Helms, J.A. 1998. The dictionary of forestry. Bethesda, MD, USA: The Society of American Foresters.

Hennessy, P.R., 2012, May. The history of social perceptions of Eucalyptus Globulus in the East San Francisco Bay area. In Senior Research Seminar (Vol. 6).

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Leong, Kingston L.H. 1990. Microenvironmental factors associated with the winter habitat of the Monarch Butterfly (Lepidoptera: Danaidae) in central California. Annals Entomological Society of America 83:906–910.

Leong Kingston L.H., Frey D, Brenner G, Baker S, Fox D. 1991. Use of multivariate analyses to characterize the monarch butterfly (Lepidoptera, Danaidae) winter habitat. Annals of the Entomological Society of America 84: 263-267.

Longcore, Rich, and Weiss 2020. Nearly all California monarch overwintering groves require non-native trees. California Fish and Wildlife 106(3):220-225 Lopez, A. J. 2015. Predicting Invasive Range of Eucalyptus globulus in California. A Thesis presented to California Polytechnic State University, San Luis Obispo. December.

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McJannet, David, and Rob Vertessy. 2001. Effects of thinning on wood production, leaf area index, transpiration, and canopy interception of a plantation subject to drought. Tree Physiology 21, 1001–1008.

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Meade, Daniel E. 1999. Monarch Butterfly Overwintering Sites in Santa Barbara County, California. Althouse and Meade, Inc., Paso Robles, California.

Meade, Daniel E., Cory Meyer, and Jessica Griffiths. 2017. Status of Monarch Butterfly Habitat in Ellwood. Presentation to Goleta City Council on July 18, 2017.

Meade, Daniel E., Charis van der Heide, and Jessica Griffiths. 2019. Monarch Butterfly Habitat on the Razor’s Edge - Native and Non-native Vegetation in California and Occam’s Razor.

Non-published letter. Althouse and Meade, Inc.

Meade, Daniel E., Charis van der Heide, and Jessica Griffiths. 2023. Monarch Butterfly Habitat on the Razor’s Edge - Native and Non-native Vegetation in California and Occam’s Razor.

Updated from 2019 original version prepared for the City of Goleta.

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9 APPENDICES
Appendix A. Hemispherical Photography Methods
Appendix B. Wind Modelling Methods
Appendix C. Ellwood Mesa Monarch Counts 2015-2023
Appendix D. Monarch Butterfly Habitat on the Razor’s Edge Appendix E. Ellwood Wind Data
Appendix F. Dead Wood Removal and Monarch Butterfly Habitat Effects Appendix G. Ellwood Monarch Butterfly Habitat Characterization Report

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Habitat Analysis and Recommendations for Ellwood Mesa, City of Goleta A-1 April 2023
APPENDIX A. HEMISPHERICAL PHOTOGRAPHY METHODS

Hemispherical photographs were collected at Ellwood Main/ Goleta Butterfly Grove in the 1990, 1998, and 2021 by Dr. Stu Weiss.

Hemispherical photography has been a standard method for assessing forest canopy structure at monarch overwintering sites (Weiss et al. 1991, Weiss and Murphy 1992, Weiss 1998, Weiss 2011, Weiss 2016). Photographs are taken using a Nikkor 8mm lens on a Nixon D610 camera body, mounted on self -leveling gimbals so that the photograph is pointed straight up at the zenith. A compass is used to orient to north. The hemispherical photo point locations cover the habitat contributing to protection of monarch cluster ing locations. Photos taken at these points were used to produce a hemiphoto that shows the interpolated exposure from 8 different directions and the maximum exposure from all directions.

Photographs are analyzed with Hemiview 2.0 software (Delta -T Devices). The photographs are aligned, and a gray-scale threshold is interactively selected to differentiate sky from obstructions.

Photographs are best taken under uniform overcast conditions, or at sunrise or sunset, when there is no direct illumination of the canopy (which can be brighter than the sky).

Hemiview overlays a “sky grid” (gray) that divides the upward hemisphere into 5° zenith angle increments (18 total = 90°) and 45° azimuth wedges centered on the eight cardinal directions.

The fraction of open s ky in each segment is calculated and weighted by the geometry of the segment depending on the analysis. Hemiview also overlays a “sun grid” (yellow) based on site latitude, with monthly increments through the year, and half-hourly increments over the day. The December 21 sunpath (winter solstice) is the lowest path, the middle path is March 21, and the highest path is June 21. The fraction of open sky in each of the segments is calculated, and the specified solar model is used to calculate insolation. Here, the units are MJ m -1 month-1, which is directly proportional to the LiDAR derived watt-hours m-2 d-1.

An example photograph, taken in the cluster site, shows both grids. The following “site factors” are extracted:
(1) ISFU – Indirect Site Factor Uncorrected, the fraction of visible sky in all directions. (2) DSFU – Direct Site Factor Uncorrected, the fraction of potential radiation across all months. (3) October, Nov/Feb and Dec/Jan potential direct insolation – calculated from fraction of unobstructed monthly sunpaths assuming clear skies.
(4) Wind Site Factors (WSF) – the fraction of sky visible in eight compass directions, a measure of relative wind exposure.

Reading a Hemispherical Photograph
The important thing to look at in the photographs is the amount of open sky in various sectors – in the 8 cardinal 45° compass directions (azimuth) and in the various elevation angle bands. Note how much larger the area of each sector is near the horizon. For wind at ground level, the most important sectors are the first 10° above the horizon. However, as one ascends in height, the higher elevation angle sectors become more important. WSF uses visible sky in the entire 45° sector as an approximation, one that provides a good measure of relative wind exposure. The basic relationship is monotonic – more open sky equals more wind exposure.

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The sun paths are divided into monthly bands going east to west (left to right) across the photo, divided into half-hour time slices. Fully shaded is when a sector is totally blo cked, dappled light of varying intensities is where many small holes in the canopy are visible, and full sun when the sky is open. Apparent sunpaths are quite sensitive to the height of observation – sites that are completely shaded at ground level may be in bright sun 20 ft up in the canopy, depending on the exact configuration of branches and canopy gaps.

References:

Weiss, Stuart B., Paul M. Rich, Dennis D. Murphy, William H. Calvert, and Paul R. Ehrlich. 1991. Forest Canopy Structure at Overwintering Monarch Butterfly Sites: Measurements with Hemispherical Photography. Conservation biology. Volume 5, No. 2. June 1991.

Weiss, S.B., and Murphy, D.D. 1992. Scientific investigations of overwintering monarch butterfly habitat at Ardenwood and Point Pinole. Report to the East Bay Regional Park District, Oakland, CA.

Weiss, S.B. 1998. Habitat Suitability, Restoration, and Vegetation Management at Monarch Grove Sanctuary, Pacific Grove California. Revised final report to the City of Pacific Grove.

Weiss, S.B. 2011. Management Plan for Monarch Grove Sanctuary: Site Assessment and Initial Recommendations Revised final report to the City of Pacific Grove.

Weiss, S.B. 2016. Assessment of Overwintering Monarch Butterfly Habitat at Ardenwood Regional Preserve, East Bay Regional Park District. Final report to East Bay Regional Park District

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APPENDIX B. WIND MODELLING METHODS
To assess changes in sheltering dynamics around monarch aggregation site s, we modeled existing and proposed wind conditions using microclimate airflow simulations.

A three-dimensional model of Ellwood Main was created in Rhinoceros 3D 7 (McNeel et. al. 2010) using LiDAR data collected by NV5 on September 27, 2021. Three catego ries of tree stems were classified and used in the model: living stems, standing dead stems, and dead downed stems (See Appendix G for additional details). All additional points were classified as vegetation. Point clouds were converted to a voxel volume by using the plugin, Volvox (Zwierzycki 2016) . All stem categories were 0.25 m sized voxels, while vegetation was 1 m.

Vegetation voxels were modeled as a momentum sink, using the default "dense" settings. Stems were also modeled as momentum sinks, but used high values (LAI = 50) to approximate a solid object. Terrain within the model was derived from classified ground points and converted to a 3D solid object.

Proposed restoration tree plantings were added using the landscape architecture plugin, Lands Design (Asuni 2022). The location of trees was directed from our proposed double row planting scheme and input from monarch restoration experts. Three scenarios were simulated: early establishment, minimum viable tree height, and maturity. Early establishment represents the first five years of planting where trees reach a height of 3.05 m (10 ft). Minimum viable tree height represents the first ten to fifteen years after planting where trees reach a height of 12.2 m (40 ft).

This threshold was determined iteratively though multiple simulation runs at various heights.

Maturity represents after thirty years or more of growth where trees reach a height of 24.4 - 30 m (80 - 100 ft). Tree object geometry was simplified for simulation runs and treated as momentum sinks, using the default "dense" set ting. Only living stem and vegetation voxels were included in proposed simulations, as dead wood is proposed to be removed.

An additional simulation was conducted to test the effect of our double -wind row design in isolation. Using the same set of tree species and modeling specifications as used at Ellwood Main, a 274 m (900 ft) idealized double wind row was simulated in perfectly flat terrain . Model geometry was simplified identically as performed in Ellwood Main simulations.

All simulated conditions were modeled using Eddy3D, a plugin for Rhino 7 that uses OpenFOAM, a comput ational fluid dynamic simulator, to model microclimate conditions (Weller et. al. 1998). An atmospheric flow boundary condition, informed by weather data collected at Santa Barbara Municipal Airport, was used for all models . Turbulence parameters used the kOmegaSST model. Relaxation factors and solution and control algorithms were both set to robust. The model treated trees as momentum sinks, using the default "dense tree" Darcy - Forcheimer coefficients. Models were allowed to run for 3,000 iterations. All residuals (Ux, Uy, Uz, omega, k) did not exceed 10-4, except for p, which approached this value.

All scenarios used storm conditions of 12 m/s (27 mph) as the model input, which have been observed in all directions (Exhibit 1). We chose a southwest wind at Ellwood Main because those are the most frequent storms and also subject to some of the most severe dieback in existing canopy.

Modeling dynamic systems is challenging, even in tightly controlled environments. A large natural system, such as a grove of eucalyptus trees found within Ellwood Mesa , is subject to Althouse and Meade, Inc.

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some inaccuracy. However, modeling all conditions using identical paramet ers allows us to explore how proposed restoration efforts will vary from existing conditions.

Exhibit 1. Santa Barbara Airport Wind Rose December 1972- 2020 shows strong winds from all directions.

Reference:

Asuni CAD. 2022. Lands Design, Version 5.6.2.7780. Barcelona, Spain.

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APPENDIX C. ELLWOOD MESA MONARCH COUNTS 2015-2023

Ellwood Mesa Biweekly Monarch Population Data by Season Data sources: Althouse and Meade Inc. and Rincon Consultants Inc. 2015-2016 10/23/15 11/11/15 12/3/15 12/16/15 12/31/15 1/8/16 1/22/16 2/3/16 2/19/16 Ellwood Main 72 2,852 6,610 7,505 7,617 5,680 4,654 3,335 0 Ellwood East 8 1,763 3,065 1,991 2,134 1,900 2,246 910 8 Ellwood West 37 840 1,525 322 75 7 0 0 0
Ellwood North 4 41 379 225 148 45 0 4 3
Sandpiper 795 2,626 7,823 4,932 1,770 306 2 2 4
Total 916 8,122 19,402 14,975 11,744 7,938 6,902 4,251 15

2016-2017 10/5/16 11/14/16 12/2/16 1/7/17 2/1/17 3/1/17 Ellwood Main 13 1,365 2,120 123 0 11
Ellwood East 5 1,175 1,200 2,670 20 8
Ellwood West 4 1,920 1,730 1,145 527 5
Ellwood North 10 25 1,580 1,490 453 15
Sandpiper 90 3,051 4,495 2,860 858 2
Total 122 7,536 11,125 8,288 1,858 41

2017-2018 10/24/17 11/9/17 11/30/17 1/8/18 1/13/18 1/23/18 2/8/18 Ellwood Main 120 829 1,390 2,185 1,510 1,680 192
Ellwood East 39 479 610 0 3 7 3
Ellwood West 117 825 2,537 120 2 3 0
Ellwood North 4 0 100 1 21 1,534 376
Sandpiper 156 771 2,407 0 0 0 0
Total 436 2,904 7,044 2,306 1,536 3,224 571

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2018-2019 10/13/18 10/25/18 11/8/18 11/25/18 12/13/18 1/4/19 1/17/19 Ellwood Main 0 11 11 205 230 170 0
Ellwood East 0 0 1 0 0 0 0
Ellwood West 0 5 7 1 0 0 0
Ellwood North 0 3 0 0 1 0 2
Sandpiper 2 3 8 1 0 0 0
Total 2 22 27 207 231 170 2

2019-2020 10/10/19 10/24/19 11/7/19 11/19/19 12/5/19 12/19/19 1/2/20 1/16/20 1/30/20 2/14/20 2/28/20 3/12/20 Ellwood Main 0 8 66 52 2 1 1 0 2 0 1 0
Ellwood East 1 2 4 55 52 13 7 0 0 0 0 0
Ellwood West 0 5 2 44 15 2 1 0 0 0 4 0
Ellwood North 3 2 2 8 1 0 3 0 2 0 0 0
Sandpiper 9 22 18 89 40 0 2 0 3 2 5 0
Ellwood Ironbark 0 0 0 4 0 0 0 0 1 0 3 0
Ellwood Main
Annex 0 0 0 19 1 0 0 0 0 0 5 0
Ocean Meadows 0 0 0 0 0 0 0 0 0 0 0 0
Total 13 39 92 271 111 16 14 0 8 2 18 0

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2020-2021 10/15/20 10/29/20 11/12/20 11/25/20 12/15/20 12/27/20 1/13/21 1/26/21 2/15/21 2/25/21 3/17/21 3/31/21 Ellwood Main 0 3 5 0 0 0 0 0 0 0 0 0
Ellwood East 0 2 3 0 0 0 0 0 0 0 0 0
Ellwood West 0 0 0 0 0 0 0 0 0 0 0 0
Ellwood North 0 1 2 0 0 0 0 0 0 0 0 0
Sandpiper 0 0 0 0 0 0 0 0 0 0 0 0
Ellwood Ironbark 0 0 0 0 0 0 0 0 0 0 0 0
Ellwood Main Annex 0 0 0 0 0 0 0 0 0 0 0 0
Ocean Meadows 0 0 0 0 0 0 0 0 0 0 0 0
Total 0 6 10 0 0 0 0 0 0 0 0 0

2021-2022 10/15/21 10/18/21 11/1/21 11/2/21 11/15/21 12/1/21 12/15/21 1/4/22 1/17/22 2/1/22 Ellwood Main 0 0 6 295 3,874 2,719 4,719 3,378 250 0
Ellwood East 0 0 18 0 4,292 3,645 8,900 10,714 11,840 9,555 Ellwood West 1 0 0 36 1,551 2,564 1,435 50 3 0
Ellwood North 6 0 0 14 6 3 0 0 0 0
Sandpiper 18 0 0 129 346 5 0 0 0 0
Ellwood Ironbark 3 0 0 0 0 0 0 0 0 0
Ellwood Main Annex 0 0 0 0 0 0 0 0 0 0
Ocean Meadows 0 1 0 0 1 0 1 0 0 0
Total 28 1 24 474 10,070 8,936 15,055 14,142 12,093 9,555

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2022-2023 10/17/22 10/31/22 11/15/22 11/30/22 12/15/22 12/30/22 1/13/23 Ellwood Main 11 73 4,188 9,311 5,394 1,833 6
Ellwood East 3 202 1,756 2,946 1,443 78 12
Ellwood West 0 924 120 130 7 0 0
Ellwood North 0 3 0 0 0 0 0
Sandpiper 9 228 0 0 0 0 0
Ellwood Ironbark 0 1 0 0 0 0 0
Ellwood Main Annex 0 0 0 0 0 0 0
Ocean Meadows 0 0 0 0 0 0 0
Total 23 1,431 6,064 12,387 6,844 1,911 18

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Western Monarch Population Data
Data source: Xerces Society 2023
Year 1997 1998 1999 2000 2001 2002 2003 2004 2005
Total Western Monarchs (WMTC) 1,235,490 564,349 267,574 390,057 209,570 99,353 254,378 205,085 218,679 SB Co. Total 354,300 84,309 87,138 131,266 67,078 13,922 35,324 33,598 78,319 Ellwood Main, Goleta 25,000 20,000 25,000 58,000 35,000 4,500 18,400 16,680 54,700

Year 2006 2007 2008 2009 2010 2011 2012 2013 2014
Total Western Monarchs (WMTC) 221,058 86,437 131,889 58,468 143,204 222,525 144,812 211,275 234,731 SB Co. Total 50,853 14,430 29,230 8,000 40,518 54,260 33,621 54,980 46,916 Ellwood Main, Goleta 19,000 11,000 12,000 6,500 27,600 21,800 17,150 2,355 3,543

Year 2015 2016 2017 2018 2019 2020 2021
Total Western Monarchs (WMTC) 292,888 298,464 192,624 27,721 29,436 1,899 247,246 SB Co. Total 57,782 74,060 45,868 6,287 7,665 208 97,025 Ellwood Main, Goleta 6,610 2,120 1,390 205 55 0 3,874

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APPENDIX D. MONARCH BUTTERFLY HABITAT ON THE RAZOR’S EDGE Native and Non-native Vegetation in California and Occam’s Razor, 2023

Monarch Butterfly Habitat on the Razor’s Edge:

Native and Non-native Vegetation in California and
Occam’s Razor

Daniel E. Meade, Jessica Griffiths, Charis van der Heide for
City of Goleta, Santa Barbara County, California

Prepared for

George Thomson, Parks & Open Space Manager
City of Goleta – Public Works Department
130 Cremona Drive
Goleta, CA 93117

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February 2023

Monarch Butterfly Habitat on the Razor’s Edge:

Native and Non-native Vegetation in California and Occam’s Razor; February 2023 ii

TABLE OF CONTENTS
1 INTRODUCTION ........................................................................................................ 3

1.1 Purpose ............................................................................................................... 3 2 SANTA BARBARA COUNTY HABITATS ................................................................... 4

2.1 Background ......................................................................................................... 4

2.2 Data Analysis ...................................................................................................... 5

2.3 Tree and Habitat Choices .................................................................................... 7

2.4 Tree Characteristics ............................................................................................ 9 3 CONCLUSION .......................................................................................................... 11 4 REFERENCES ......................................................................................................... 12 ATTACHMENT A. TREE COMPARISON FOR CHARACTERISTICS IMPORTANT TO MONARCH BUTTERFLY AGGREGATION SITES .................................................. 14

Production Note: This is updated from the original version completed in April 2019 with Daniel E. Meade, Jessica Griffiths, and Charis van der Heide as the original authors. Charis van der Heide completed this revision following the passing of Dr. Daniel E.

Meade on November 26, 2022.

Charis van der Heide may be reached at: [email protected]

Jessica Griffiths may be reached at: [email protected]

Cover Page: Clustering Monarchs taken by Charis van der Heide on November 19, 2022.

Meade, Griffiths, and van der Heide
Monarch Butterfly Habitat on the Razor’s Edge:

Native and Non-native Vegetation in California and Occam’s Razor; February 2023 3 1 INTRODUCTION
Conservation biologists and land managers face a dilemma prescribing effective, proven, conservative recommendations to restore western monarch butterfly aggregation sites (Lane 1993).

In sites where monarchs aggregate in trees native to their location, such as Monterey pines (Pinus radiata) in Monterey, this question is beginning to be answered in favor of native trees when both native trees and eucalyptus are present (Griffiths and Villablanca 2015). But, in areas where native trees are absent from most monarch butterfly aggregation sites, such as Santa Barbara County, the question of what to plant in aggregation sites in need of restoration is more complicated. This pertains specifically to eucalyptus trees that are the subject of a long and sometimes bitter controversy in California regarding whether to keep or replace eucalyptus trees with native vegetation (Bell et al. 1993, Santos 1997, Farmer 2013, Marris 2016, St. George 2016, Longcore et al. 2020).

There are only four tree species native to Santa Barbara County’s coastal habitats with suitable size and structure to be considered for protecting monarch aggregations from inclement weather:
western sycamore (Platanus racemosa), Fremont cottonwood (Populus fremontii), arroyo willow (Salix lasiolepsis), and coast live oak (Quercus agrifolia). Black cottonwood (Populus balsamifera subsp. trichocarpa) occur in some south coast riparian corridors. White alder trees ( Alnus rhombifolia) are confined to higher elevations on the south coast in or near streams with abundant water. All except one of these trees, coast live oak, are deciduous and provide reduced protection from wind and storms once their leaves fall. Coast live oak does not have a columnar growth form that creates usable aggregation spaces. No aggregation sites are known in oak woodlands. A few native shrubs such as toyon (Heteromeles arbutifolia), California bay (Umbellularia californica), and holly -leafed cherry ( Prunus illicifolia ), expand the possible plant palette for roosting monarchs, but do not provide the tall canopy cover necessary at sites where mon archs aggregate.

Therefore, choices for native trees are limited and are not sufficient for forming the typical structure of a monarch butterfly aggregation site with a flight area encircled by substantial, tall trees that filter light, buffer wind and ameliorate temperatures and humidity (Wenner 1987, Leong 1990, Weiss et al. 1991, Calvert 1991, Meade 1999, Leong 2016).

1.1 Purpose
Scientific problem -solving employs the principle of Occam’s razor, or parsimony. This fundamental heuristic, or way of discovering something, is summarized as, “simpler solutions are more likely to be correct than complex ones” (attributed to William of Occam). When attempting to determine what causes monarchs to aggregate at a site, the simplest approach would be to examine the ag gregation sites as a whole. The most easily observable feature of overwintering sites is the tree species they are comprised of. The structure of an overwintering site (i.e. the trees) directly influences the myriad other factors that cause monarchs to sel ect a site, e.g. temperature, wind speed, humidity, and light. Thus, we can look at overall habitat preference using the composition of tree species and not all the other factors that may generate that preference.

Goleta City CouncilOctober 17, 2023

Goleta City Council
October 17, 2023