Goleta City Council
April 16, 2024

Agenda Item C.1

PUBLIC HEARING
Meeting Date: April 16, 2024
TO: Mayor and Councilmembers
SUBMITTED BY: Peter Imhof, Planning and Environmental Review Director CONTACT: Darryl Mimick, Senior Planner
Kathy Allen, Supervising Senior Planner
SUBJECT: Consideration of Initiation of a General Plan Amendment 7925 Hollister Avenue (APN 079-210-059)
Case No. 22-0009-GPA
RECOMMENDATION:

Adopt Resolution No. 24-___, entitled “ A Resolution of the City Council of the City of Goleta, Califor nia, Initiating the Processing of An Applicant -Requested General Plan Amendment to update Figure CE 4 -1 and Figure OS 3.5 w ithin the General Plan/Coastal Land Use Plan related to the resources located at 7925 Hollister Avenue (APN 07 9-210-059) and finding that the initiation of a General Plan Amendment is exempt from the California Environmental Quality Act.”
BACKGROUND:

Goleta’s General Plan/Coastal Land Use Plan
The City of Goleta adopted the Goleta General Plan/Coastal Land Use Plan (General Plan) on October 2, 2006. The General Plan contains the following seven state-required elements, and two optional elements as follo ws: Land Use Element, Open Space Element, Conservation Element, Safety Element, Visual and Historic Resources Element, Transportation Element, Public Facilities Element, Noise Element, and Housing Element. The Conservation Element includes a Special-Status Species and Environmental Sensitive Habitat Area (E SHA) Map (Figure 4-1), which identifies the ESHA and special-status species in th e City. The Open Space Element includes an Open Space Plan Map, which identifies all Open Space uses within the City. The subject ESHA is also replicated/identified on the Open Space Plan Map. The most recent amendment occurred on December 5, 2023, regarding the adoption of the 6th Cycle Housing Element 2023-2031.

General Plan Amendment Initiation Process
The General Plan Amendment (GPA) process is governed by Article 6 of State Planning and Zoning Law (Government Code Section 65 350 et seq.). Pursuant to s tate law, General Plan amendments require the Planning Commission ’s consideration and 1 Meeting Date: April 16, 2024

recommendation. The City Council is t he City’s final decision-making body on a legislative action. The subject parcel is within the California Coastal Zone . As the City currently does not have an adopted Local Coastal Program (LCP) , the California Coastal Commission would have approval authority on the proposed GPA.

Before a GPA can be considered, Section 17.67. 030 outlines the procedures for the initiation process. These procedures require that all requests for GPAs be initiated by the City Council at a public hearing prior to processing. Section 17.67.030 provides five factors the City Council must consider by the applicant for the initiation of a GPA. These five factors are:

1. The amendment proposed appears to be consistent with the Guiding Principles and Goals of the General Plan;

2. The amendment proposed appears to have no material effect on the community or the General Plan;

3. The amendment proposed provides additional public benefit to the community as compared to the existing land use designation or policy;

4. Public facilities appear to be available to serve the affected site, or their provision will be addressed as a component of the amendment process; or

5. The amendment proposed is required under other rules or regulations.

Applicant’s Request

On January 24, 2024 , Steve Welton of Suzanne Elledge Planning and Permitting Services (Agent) submitted a request for the initiation of a General Plan Amendment on behalf of Sand piper-Golf Trust (property owner) . The GPA initiation request is to study the proposed removal of the following ESHA design ations from Figure CE 4 -1 and Figure OS 3.5, consisting of the following:

 Removal of ESHA designations adjacent to Devereux Creek in areas where the creek is contained within a pipe.
 Removal of the golf course pond as designated ESHA.
 Removal of the special-status species designation (California Red-Legged Frog) adjacent to the golf course pond.

Additionally, the GPA initiation request is to study proposed additions of ESHA to Figure 4-1 and Figure OS 3.5, consisting of the following:

 Adding purple needle grass to the southeast corner of the parcel as ESHA.  Adding Santa Barbara honeysuckle at the southeast property line as ESHA.  Adding sage scrub adjacent to Devereux creek as ESHA.  Adding three special-status species designations (raptor nests) adjacent to Devereux creek.
 Adding wooly seablite and cliff malacthrix within sage scrub in various locations as ESHA.
2 Meeting Date: April 16, 2024

 Adding black walnut to ESHA within Bell’s Canyon.
 Adding a coastal wetland in the middle of site adjacent to the ocean as ESHA.

Please see Attac hment 2, Figure 4 -1 Special -Status Species and Environmental Sensitive Habitat Areas Map, and Attachment 4 and 5, the ESHA/Special -Status Species comparison of Figure 4-1 to the applicant’s request for vacations/additions, and the revised ESHA/Special-status species map proposed by the applicant. Attachment 3, Figure 3-5, the Open Space Map, mirror s the proposed ESHA changes as establis hed in Figure 4-1. Additionally, Attachment 6 provides the applicant’s biological assessment of the site which has led to t he requested GPA , and Attachment 7 provides the applicant’s submitted Initiation Factors.

Site Information

The golf course has been located at this location since 197 2. The property includes an existing 18-hole golf course, with a 9,305-square foot, 28 -foot six -inch high golf clubhouse, 124 parking spaces, a maintenance yard, a historic vacant gas station, golf course landscaping, ame nities, and infrastructure on a 192.93 -acre parcel. The site is located in the Open Space Active Recreation zone district and the Open Space/Active Recreation General Plan Land Use designation. The property is outlined in blue below.

Figure 1. Vicinity Map

Applicable Policies
The following General Plan Policies define the purpose of Environmentally Sensitive Habitat Areas, as well as explain the process and reasoning to explore revisions to 3 Meeting Date: April 16, 2024

Environmentally Sensitive Habitat Areas within CE Figure 4 -1, and the associated OS Figure 3-5 Map.

General Plan Policy CE 1.1 defines Environmentally Sensitive Habitat Areas as any areas that through professional biological evaluation are determined to meet the following criteria:

A. Any area in which plant or animal life or their habitats are either rare or especially valuable because of their special nature or role in an ecosystem and that could be easily disturbed or degraded by human activities and developments.

B. Any area that includes habitat for species and plant communities recognized as threatened or endangered by the state or federal governments; plant communities recognized by the State of California (in the Terrestrial Natural Communities Inventory) as restricted in distribution and very threatened; and those habitat types of limited distribution recognized to be of particular habitat value, including wetlands, riparian vegetation, eucalyptus groves associated with monarch butterfly roosts, oak woodlands, and savannas.

C. Any area that has been previously designat ed as an ESHA by the California Coastal Commission, the California Department of Fish and Game, City of Goleta, or other agency with jurisdiction over the designated area.

Additionally, as stated in General Plan Policy CE 1.3, Site -Specific Studies and Unmapped ESHAs, any area not designated on the ESHA map in Figure 4 -1 that meets the ESHA criteria for the resources specified in CE 1.1 shall be granted the same protections as if the area was shown on the map. Proposals for development on sites where ESHAs are shown on the map or where there is probable cause to believe that ESHAs may exist shall be required to provide the Cit y with a site -specific biological study that includes the following information:

A. A base map that delineates topographic lines, parce l boundaries, and adjacent roads.

B. A vegetation map that identifies species that may be indicators of ESHAs.

C. A soils map that delineates hydric and nonhydric soils, if applicable. Goleta General Plan/Coastal Land Use Plan 4.0 Conservation Element September 2006 4-10.

D. A census of animal species that indicates the potential existence of ESHAs.

E. A detailed map that shows the conclu sions regarding the boundary, precise location and extent, or current status of the ESHA based on substantial evidence provided in biological studies.

Lastly, General Plan Policy CE 1.5 provides the process by which corrections to the General Plan’s map of ESHAs can be made . First, the applicant must submit a a site- specific biological study that contains substantial evidence that an area previously shown as an ESHA on Figure 4 -1 does not contain habitat that meets the definition of an ESHA for reasons ot her than that set forth in CE 1.4 . This study would then be reviewed by the City biologist. Then the Planning Commission shall review all available information and determine if the area in question should no longer be considered an 4 Meeting Date: April 16, 2024

ESHA and therefore not be subject to the ESHA protection policies of this plan. This decision is subject to appeal to the City Council. If the final decision -making body determines that the area is not an ESHA, a map modification would be included in the next General Plan/Coastal Land Use Plan amendment.

DISCUSSION:

As previously noted , the Council must consider a specific set of five factors when determining whether to initiate a General Plan Amendment. Pursuant to Goleta Municipal Code Section 17.67.030(B) , staff has provided the below General Plan Amendment Initiation factor justifications for the City Council ’s consideration. The applicant’s justification for the initiation is also provided in Attachment 7. Determining to initiate the General Plan Amendment does not bind the Council to any one outcome and allows for further study prior to a formal decision on the merits of the request.

The following is provided for the Council’s consideration:

1. The amendment proposed appears to be consistent with the Guiding Principles and Goals of the General Plan.

Consistent with CE 1.5, site-specific biological stud ies (See Attachment 7) have been prepared by professi onal biologists from Dudek & Associates , which contains evidence that some of the areas shown as ESHA and special-status species designations on the Sandpiper property do no t contain ESHA or do not exist. Alternatively, biological studies also identify areas where ESHA and special-status species do exist.

In keeping with General Plan Policy CE 1.5, allowing the General Plan Amendment request to proceed at this time for further study would be consistent with the guiding principles and goals of the General Plan. The submitted biological studies would be peer -reviewed during the environmental review process and the community and decision-makers would be afforded an opportunity to weigh in on the merits of the proposal with more robust information before making a decision . The proposed request appears to be consistent with the guiding principles of the General Plan , which includes a desire to accurately represent ESHA and special-status species that exist on-site, and those that are not mapped.

2. The amendment proposed appears to have no material effect on the community or the General Plan or Specific Plan.

The Amendment appears t o not have a material effect on the community or General Plan based on policy CE 1.5 . If initiated, the request would allow for the further study to determine the scope and sensitivity of biological resources present on the Sandpiper Golf Course and whether Figure s 4-1 and 3 -5 of the 5 Meeting Date: April 16, 2024

General Plan/Coastal Land Use Plan should be amended to reflect site -specific biological studies.

3. The amendment proposed provides additional public benefit to the community as compared to the existing land use designation or policy.

The Amendment could be beneficial in that two figures ( Figures 4-1 and 3-5) of the General Plan/Coastal Land Use Plan would be amended to reflect site - specific biological studies. As indicated above, the initiation would allow for further study during the environmental review process and the community and decision-makers would be afforded an opportunity to weigh in on the meri ts of the proposal with more robust information before making a decision.

4. Public facilities appear to be available to se rve the affected site, or their provisions will be addressed as a component of the amendment process.

The availability of public fac ilities is not germane to this particular request.

However, the property is served by Goleta Water District . As part of the Sandpiper Golf Course renovation project, the applicant is proposing a Goleta West Sanitary District Sphere of Influence change in order to change from septic systems to sanitary sewer through a service agreement.

5. The amendment proposed is required under other rules or regulations.

As mentioned in Factor #1, Policy CE 1-5 requires that the City must modify Figure 4-1 through its next General Plan/Coastal Plan Amendment , when it is in possession of substantial evidence that Figure 4-1 does not contain habitat that meets the definition of an ESHA for reasons other than that set forth in CE 1.4. If initiated, the submitted biological st udies would be peer-reviewed during the environmental review process and the community and decision-makers would be afforded an opportunity to weigh in on the merits of the proposal with more robust information before making a decision.

If the Council f inds that the initiation factors can be made, then adopt the Resolution provided as Attachment 1 to this report . If initiated, then the General Plan Amendment would be processed as part of the larger Sandpiper Golf course renovation project. The Sandpiper Golf Course Project will include review by the Historic Resource Commission, Design Review Board , Planning Commission, and the City Council. The City Council would be the ultimate City decision-maker on all the project components at a public hearing. Initiation of the GPA would not commit the City to any particular action on the GPA ultimately.

ENVIRONMENTAL REVIEW:
6 Meeting Date: April 16, 2024

The initiation of a General Plan Amendment is not subject to the California Environmental Quality Act (CEQA) pursuant to Section 15060(c)( 3) of the CEQA Guidelines (Title 14, Chapter 3 of the California Code of Regulations) because the activity is not a “projec t” as defined in Section 15378(b)(5) as an organizational or administrative activity by government that will not result in direct or indirect physical changes in the environment. The initiation is also exempt from CEQA pursuant to Section 15061(b)(3) of the CEQA Guidelines because the activity is covered by the general rule which exempts activities that can be seen with certainty to hav e no possibility for causing a significant effect on the environment.

If the GPA is initiated, then the GPA environmental impacts will be assessed as part of the environmental document prepared for the affiliated Sandpiper Golf course renovation project. (Attachment 8).

FISCAL IMPACTS:

The case processing costs associated with the initiation of the proposed General Plan Amendment at 7925 Hollister Avenue are being are being borne by the Applicant.

ALTERNATIVES:

The City Council could choose to:

1. Decline to initiate the requested General Plan amendment. If not initiated, the ESHA and special-status species designations will remain unchanged.

2. Initiate a portion of the request.

3. Continue this item for additional information/discussion.

LEGAL REVIEW BY: Megan Garibaldi, City Attorney
APPROVED BY: Robert Nisbet, City Manager
ATTACHMENTS:

1. Adopt Resolution No. 24 -___, entitled “A Resolution of the City Council of the City of Goleta, California, Initiating the Processing of An Applicant -Requested General Plan Amendment to update Figure CE 4 -1 and Figure OS 3.5 with the General Plan/Coastal Land Use Plan relate d to the resources located at 7925 Hollister Avenue (APN 079 -210-059) and finding that the initiation of a General Plan Amendment is exempt from the California Environmental Quality Act”.

2. Goleta General Plan/Coastal Land Use Plan CE Figure 4-1

3. Goleta General Plan/Coastal Land Use Plan OS Figure 3-5

4. Applicant Proposed Overlay to CE Figure 4-1

5. Applicant Proposed CE Figure 4-1

6. Applicant Submitted Biological Studies

7. Applicant Submitted Initiation Factors
7 Meeting Date: April 16, 2024

8. CEQA Notice of Exemption

9. Staff PowerPoint Presentation
8 Attachment 1:

Resolution No. 24-___, entitled “A Resolution of the City Council of the City of Goleta, California, Initiating the Processing of An Applicant-Requested General Plan Amendment to update Figure CE 4-1 and Figure OS 3.5 with the General Plan/Coastal Land Use Plan related to the resources located at 7925 Hollister Avenue (APN 079-210- 059)”

9 Resolution No.24-_ Initiation of Specific Plan Amendment for APN 079-210-059 Page 1 RESOLUTION NO. 24- _

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF GOLETA,

CALIFORNIA, INITIATING THE PROCESSING OF AN APPLICANT - REQUESTED GENERAL PLAN AMENDMENT TO UPDATE FIGURE CE 4-1 AND FIGURE OS 3.5 WITH THE GENERAL PLAN/COASTAL LAND USE PLAN RELATED TO THE RESOURCES LOCATED AT 7925 HOLLISTER AVENUE (APN 079 -210-059 AND FINDING THAT THE INITIATION OF A

GENERAL PLAN AMENDMENT IS EXEMPT FROM THE CALIFORNIA
ENVIRONMENTAL QUALITY ACT (APN 079-210-059, CASE NO. 22-0009- GPA)

WHEREAS, the Goleta General Plan/Coastal Land Use Plan (General Plan) is the City’s official policy that guides land use and physical development of the geographic area of the incorporated City limits; and

WHEREAS, California Government Code Sections 65350 et seq. authorize cities and counties to prepare, adopt and amend General Plans and their elements; and

WHEREAS, California Government Code Section 65358(a) reads, “If it deems it to be in the public interest, the legislative body may amend all or part of an adopted General Plan. An amendment to the General Plan shall be initiated in the manner specified by the legislative body. Notwithstanding Section 66016, a legislative body that permits persons to request an amendment of the General Plan may re quire that an amount equal to the estimated cost of preparing the amendment be deposited with the planning agency prior to the preparation of the amendment”; and

WHEREAS, City Council Resolution No. 12 -13 and Goleta Municipal Code Chapter 17. 67 establish a procedure for the initiation of processing of requests for a General Plan Amendment; and

WHEREAS, City Council Resolution No. 12 -13 and Goleta Municipal Code subsection 17.67.030(B) require the City Council to consider certain factors for the initiation of General Plan amendments, including consistency with the Guiding Principles and Goals of the General Plan, no material effect on the community or the General Plan, providing additional public benefit to the community as compared to the existing land use designation or policy, availability of or the future study of the availability of public services, or rules or regulations that may drive the need to amend the General Plan; and

WHEREAS, on January 24, 2024, Steve Welton of Suzzane Elledge Planning and Permitting Services (Agent) submitted a request for the initiation of a General Plan Amendment for the removal and addition of Environmental Sensitive Habitat Areas (ESHA) and Special Status Species; and

WHEREAS, the applicant is seeking an initiation of a General Plan Amendment to add and remove the designation of certain Environmental Sensitive Habitat Areas (ESHA) and Special Status Species from Figure CE 4-1 and Figure OS 3.5; and 10 Resolution No.24-_ Initiation of Specific Plan Amendment for APN 079-210-059 Page 2

WHEREAS, the City Council conducted a duly noticed public hearing on April 16, 2024, at which time all interested persons were given an opportunity to be heard; and

WHEREAS, the City Council considered the entire administrative record, including staff reports, the General Plan, and oral and written testimony from interested persons.

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

SECTION 1. General Plan Initiation Factors

The City Council makes the following statements regarding the initiation factors outlined in City Council Resolution No. 12-13 and Goleta Municipal Code Section 17.67.030:

a) The amendment proposed appears to be consistent with the Guiding Principles and Goals of the General Plan.

Consistent with CE 1.5, site-specific biological studies (See Attachment 7) have been prepared by professional biologists from Dudek & Associates, which contains evidence that some of the areas shown as ESHA and special-status species designations on the Sandpiper property do not contain ESHA or do not exist.

Alternatively, biological studies also identify areas where ESHA and special-status species do exist.

In keeping with General Plan Policy CE 1.5, allowing the General Plan Amendment request to proceed at this time for further study would be consistent with the guiding principles and goals of the General Plan. The submitted biological studies would be peer reviewed during the environmental review process and the community and decisionmakers would be afforded an opportunity to weigh in on the merits of the proposal with more robust information before making a decision.

The proposed request appears to be consistent with the guiding principles of the General Plan, which includes a desire to accurately represent ESHA and special- status species that exist on-site, and those that are not mapped.

b) The amendment proposed appears to have no material effect on the community or the General Plan or Specific Plan.

The Amendment appears to not have a material effect on the community or General Plan based on policy CE 1.5. If initiated, the request would allow for the further study to determine the scope and sensitivity of biological resources present on the Sandpiper Golf Course and whether Figure s 4-1 and 3 -5 of the General Plan/Coastal Land Use Plan should be amended to reflect site -specific biological studies.

11 Resolution No.24-_ Initiation of Specific Plan Amendment for APN 079-210-059 Page 3

c) The amendment proposed provides additional public benefit to the community as compared to the existing land use designation or policy.

The Amendment could be beneficial in that two figures (Figures 4-1 and 3-5) of the General Plan/Coastal Land Use Plan would be amended to reflect site -specific biological studies. As indicated above, the initiation would allow for further study during the environmental review process and the community and decisionmakers would be afforded an opportunity to weigh in on the merits of the proposal with more robust information before making a decision.

d) Public facilities appear to be available to serve the affected site, or their provisions will be addressed as a component of the amendment process.

The availability of public facilities is not germane to this particular request.

However, the property is served by Goleta Water District. As part of the Sandpiper Golf Course renovation project, the applicant is proposing a Goleta West Sanitary District Sphere of Influence change in order to change from septic sys tems to sanitary sewer through a service agreement.

e) The amendment proposed is required under other rules or regulations.

As mentioned in Factor #1, Policy CE 1-5 requires that the City must modify Figure 4-1 at their next General Plan/Coastal Plan Amendment when it is in possession of substantial evidence that the site referenced in Figure 4 -1 does not contain habitat that meets the definition of an ESHA for reasons other than that set forth in CE 1.4... If initiated, the submitted biological studies would be peer reviewed during the environmental review process and the community and decisionmakers would be afforded an opportunity to weigh in on the merits of the proposal with more robust information before making a decision.

SECTION 2. Environmental Assessment
The initiation of a General Plan Amendment is not subject to the California Environmental Quality Act (CEQA) pursuant to Section 15060(c)(3) of the CEQA Guidelines (Title 14, Chapter 3 of the California Code of Regulations) because the activity is not a “project” as defined in Section 15378(b)(5) as an organizational or administrative activity by government that will not result in direct or indirect physical changes in the environment.

The initiation is also e xempt from CEQA pursuant to Section 15061(b)(3) of the CEQA Guidelines because the activity is covered by the general rule which exempts activities that can be seen with certainty to have no possibility for causing a significant effect on the environment.

SECTION 3. Action
The City Council hereby authorizes staff to initiate processing of a proposed General Plan Amendment to update Figure CE 4-1 and Figure OS 3.5 within the General Plan/Coastal 12 Resolution No.24-_ Initiation of Specific Plan Amendment for APN 079-210-059 Page 4 Land Use Plan related to the resources located at 7925 Hollister Avenue (APN 079-210- 059). The initiation of the General Plan Amendment does not suggest how the City Council may ultimately act on the General Plan Amendment when it is brought forward for City Council consideration. The initiation of the General Plan Amendment shall not influence the City Council’s consideration of the General Plan Amendment.

SECTION 4. Effective Date
This Resolution becomes effective upon adoption.

SECTION 5. Time Limit
The initiation of this General Plan Amendment will automatically expire after two (2) years from the date of this Resolution if an application for the General Plan Amendment is not submitted to the PER Department during this timeframe.

SECTION 6. Certification
The City Clerk shall certify to the passage and adoption of this resolution and enter it into the book of original resolutions.

SECTION 7. Records
The documents and materials associated with this Resolution that constitute the record of proceedings on which the City Council’s findings and determinations are based are located at 130 Cremona Drive, Suite B, Goleta CA 93117.

PASSED, APPROVED, AND ADOPTED this 16th day of April 2024.

_____________________________

PAULA PEROTTE, MAYOR

ATTEST: APPROVED AS TO FORM:

_________________________ ___________________________
DEBORAH S. LOPEZ MEGAN GARIBALDI

CITY CLERK CITY ATTORNEY
13 Resolution No.24-_ Initiation of Specific Plan Amendment for APN 079-210-059 Page 5

STATE OF CALIFORNIA )
COUNTY OF SANTA BARBARA ) ss.

CITY OF GOLETA )

I, DEBORAH S. LOPEZ, City Clerk of the City of Goleta, California, DO HEREBY CERTIFY that the foregoing Resolution No. 24-__ was duly adopted by the City Council of the City of Goleta at a regular meeting held on the 16th day of April 2024 by the following vote of the Council:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

(SEAL)

__________________________
DEBORAH S. LOPEZ

CITY CLERK

14 Attachment 2:

Goleta General Plan/Coastal Land Use Plan CE Figure 4-1

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UCSB
Isla Vista
Union Pacific RR
Cathedral Oaks Rd
Old San Jose Creek
Santa Barbara Airport

Hollister Ave
Glen Annie Rd
Cathedral Oaks Rd
Storke Rd
Calle Real
Fairview Ave
Phelps Rd
Hollister Ave
Hollister Ave
Calle Real
Mesa Rd
Patterson Ave
La Patera Ln
El Colegio Rd
Los Carneros Rd
Kellogg Ave
Fairview Ave
Goleta Slough
Devereux Slough

Campus Lagoon
Los Carneros
Lake
Rancho Goleta
Lake

San Jose Creek
San Pedro Creek
Tecolote Creek Glen Annie Creek
Las Vegas Creek
Los Carneros Creek
Maria Ignacio Creek
Ellwood Canyon Creek
Winchester Canyon Creek El Encanto Creek
Bell Canyon Creek

Atascadero Creek
Devereux Creek
San Antonio Creek
Goleta Pt
Goleta Pier
Coal Oil Pt
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Pacific Ocean
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Figure 4-1

SPECIAL-STATUS SPECIES AND

ENVIRONMENTALLY SENSITIVE HABITAT AREAS

GENERAL PLAN/COASTAL LAND USE PLAN
March 2023
±
0 1,200 2,400
Feet
Legend
Environmentally Sensitive Habitats Other Features
Goleta City
Boundary
Coastal Zone
n Schools
Creeks
Native Grassland
Special-Status Species
Cooper's Hawk Nest[Ç
[b Kite Nest
[Ç Red-Tailed Hawk Nest
[à Globose Dune Beetle
[b Vulture Roost
[« Western Snowy Plover
[¡ Tidewater Goby
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Red-Shouldered
Hawk Nest
[¨ Santa Barbara Honeysuckle
[¨ Black-Flowered Figwort
Southern Tarplant[(
^_ Ellwood Main Monarch Grove
Critical Habitat for the
Western Snowy Plover
Beach and Shoreline
Unvegetated Open
Creek Channel
Open Water
Riparian/Marsh/Vernal Pool
Sage Scrub/Dune/
Bluff Scrub
Native Upland Woodlands
/Savannahs
Monarch Butterfly and/or
Raptor Roosting Habitat
^_ Monarch Butterfly Aggregation
Sources:Habitat mapping conducted by Jones & Stokes in April-May 2006 based on aerial imagery (1-foot resolution) and field observation, merged with 1) information on the occurrence of special status habitats and species collected by City from recent information from local environmental review ; 2) mapping of creeks, ponds, lakes and reservoir location based on USGS topographic map review and habitat management plan documents, air photo interpretation, and field survey; and 3) review of California Natural Diversity Database (CNDDB) records by Jones & Stokes for occurrence of special status species in the Goleta and Dos Pueblos quadrangles and vicinities (2006 databases).

Habitats reflect those comprising an ESHA.

ESHA locations are approximate. Any area not designated on the ESHA map that meets the ESHA criteria shall be accorded the same protections as if the area was shown on the map. ESHA buffers are not shown on this map. Refer to the applicable policy in the General Plan for the specific buffer widths.

Note:

Amended by Reso. 09-59, 11/17/09
Amended by Reso. 12-46, 7/17/12
Amended by Reso. 15-03, 1/20/15
Amended by Reso. 23-12, 3/7/23
16 Attachment 3:

Goleta General Plan/Coastal Land Use Plan OS Figure 3-5

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UCSB
Isla Vista
Union Pacific RR
Cathedral Oaks Rd
Old San Jose Creek
Santa Barbara Airport

Hollister Ave
Glen Annie Rd
Cathedral Oaks Rd
Storke Rd
Calle Real
Fairview Ave
Phelps Rd
Hollister Ave
Hollister Ave
Calle Real
Mesa Rd
Patterson Ave
La Patera Ln
El Colegio Rd
Los Carneros Rd
Kellogg Ave
Fairview Ave
Goleta Slough
Devereux Slough

Campus Lagoon
Los Carneros
Lake
Rancho Goleta
Lake

San Jose Creek
San Pedro Creek
Tecolote Creek Glen Annie Creek
Las Vegas Creek
Los Carneros Creek
Maria Ignacio Creek
Ellwood Canyon Creek
Winchester Canyon Creek El Encanto Creek
Bell Canyon Creek

Atascadero Creek
Devereux Creek
San Antonio Creek
Goleta Pt
Goleta Pier
Coal Oil Pt
Ellwood
Pier
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Pacific Ocean
Figure 3-5

OPEN SPACE PLAN MAP

GENERAL PLAN/COASTAL LAND USE PLAN
December 2023
±
0 1,200 2,400
Feet
Open Space for Managed
Production of Resources
Open Space for Public
Health and Safety
Flood Plain(See Note)
Tsunami Run-up Areas(See Note)
Agriculture
Other Features
Schoolsn
Creeks
Coastal Zone
Goleta City Boundary
Tsunami run-up areas and flood plain information are shown in Safety Element Figure 5-2.Note:Legend Open Space for Outdoor Recreation
Open Space for Preservation
of Natural Resources
Active Park Sites
Passive Parks /Open Space Areas
Private Recreational Areas
Environmentally Sensitive Habitat Areas
Amended by Reso. 09-59, 11/17/09
Amended by Reso. 12-46, 7/17/12
Amended by Reso. 15-03, 1/20/15
Amended by Reso. 17-46, 10/17/17
Amended by Reso. 23-12, 3/7/23
Amended by Reso. 23-65, 12/5/23
18 Attachment 4:

Applicant Proposed Overlay to CE Figure 4-1

19 Date: 10/27/2023 - Last saved by: slucarelli - Path: \\dudek.int\data\GISData\Projects\j1276000\MAPDOC\ESHA Memo\Figure4_ESHAComparison.mxd Island
Las Armas Rd
20 Attachment 5:

Applicant Proposed CE Figure 4-1

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Proposed Revisions to General Plan (Figure 4-1) Special-Status Species and ESHA ESHA Memo for the Sandpiper Golf Club Project
SOURCE: Aerial: Sanborn 2020
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EXHIBIT 1
Project Boundary
Environmentally Sensitive Habitat Areas
Beach and Shoreline
Sage Scrub/Dune/Bluff Scrub
Native grassland
Riparian/Marsh/Vernal Pool
Open Water
Coastal Wetland
Unvegetated Open Creek Channel
Monarch butterfly and/or Raptor Roosting
Southern California black
Cliff malacothrix
Red sand-verbena
Santa Barbara honeysuckle
Woolly seablite
Wildlife Special-Status Species
GF Cooper’s Hawk Nest
GF White-tailed Kite Nest
GF Red-tailed Hawk Nest
!!H California Red-Legged Frog
##0 Tidewater Goby
_^_ Monarch Butterfly Aggregation
22 Attachment 6:

Applicant Submitted Biological Studies

23 Biological Resources Assessment Report
For the Sandpiper Golf
Club Project
NOVEMBER 2022
REVISED AUGUST 2023
Prepared for:

SANDPIPER GOLF TRUST LLC
280 Chestnut Avenue
Westmont, Illinois 60559
Contact: Cathy Hwang
Prepared by:

621 Chapala Street
Santa Barbara, California 93101
Contact: John Davis IV
805-252-7996

24 Printed on 30% post-consumer recycled material.

25 12760 i AUGUST 2023
Table of Contents
SECTION PAGE NO.

Acronyms and Abbreviations ............................................................................................................................................. v 1 Introduction .......................................................................................................................................................... 1

1.1 Site Location and Surrounding Area ..................................................................................................... 1

1.2 Project Description ................................................................................................................................. 1

1.2.1 Golf Course Redesign ............................................................................................................... 1

1.2.2 Clubhouse ................................................................................................................................. 2

1.2.3 Barnsdall Gas Station ............................................................................................................... 2

1.2.4 Comfort and Maintenance ....................................................................................................... 3 2 Regulatory Setting ................................................................................................................................................ 4

2.1 Sensitive Vegetation Communities ........................................................................................................ 4

2.2 Special-Status Plant and Wildlife Species Defined .............................................................................. 4

2.3 Endangered Species Acts ...................................................................................................................... 5

2.3.1 Federal Endangered Species Act ............................................................................................. 5

2.3.2 California Endangered Species Act .......................................................................................... 5

2.4 Migratory Bird Protections ..................................................................................................................... 6

2.5 Jurisdictional Aquatic Resources ........................................................................................................... 6

2.5.1 U.S. Army Corps of Engineers ................................................................................................... 6

2.5.2 California Department of Fish and Wildlife ............................................................................. 7

2.5.3 Regional Water Quality Control Boards ................................................................................... 8

2.5.4 California Coastal Commission ................................................................................................ 8

2.5.5 City of Goleta ............................................................................................................................. 8

2.6 California Environmental Quality Act ..................................................................................................... 9

2.7 Local Laws, Ordinances, Regulations, and Standards ......................................................................... 9

2.7.1 City of Goleta General Plan/Coastal Land Use Plan ............................................................... 9 3 Methods ............................................................................................................................................................. 12

3.1 Literature Review ................................................................................................................................. 12

3.2 Field Surveys in 2021 and 2022 ........................................................................................................ 13

3.2.1 Reconnaissance Survey ........................................................................................................ 14

3.2.2 Vegetation Mapping ............................................................................................................... 15

3.2.3 Aquatic Resources Delineation ............................................................................................. 15

3.2.4 Special-Status Plant Survey .................................................................................................. 17

3.2.5 Native Grassland Assessment .............................................................................................. 17

3.2.6 Roosting Monarch Butterfly Survey ...................................................................................... 18

3.2.7 Protocol California Red-legged Frog Surveys ....................................................................... 19 26 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT 12760 ii AUGUST 2023

3.2.8 Nesting Raptor Surveys ......................................................................................................... 20

3.3 Previous Surveys ................................................................................................................................. 21 4 Results ............................................................................................................................................................... 22

4.1 Biological Setting ................................................................................................................................. 22

4.2 Vegetation Communities and Land Covers ........................................................................................ 22

4.2.1 Coast live Oak Woodland Alliance ........................................................................................ 24

4.2.2 Monterey Cypress – Monterey Pine Semi-Natural Alliance ................................................. 24

4.2.3 Pepper Tree or Myoporum Groves Semi-Natural Alliance ................................................... 25

4.2.4 Eucalyptus (globulus, camaldulensis) Provisional Semi-Natural Association ................... 25

4.2.5 Baccharis pilularis – Toxicodendron diversilobum Association .......................................... 26

4.2.6 Coyote Brush Scrub Alliance ................................................................................................. 26

4.2.7 Quailbush Scrub Alliance....................................................................................................... 26

4.2.8 California Brittle Bush – Ashy Buckwheat Scrub Alliance ................................................... 27

4.2.9 Coastal Sage Scrub ............................................................................................................... 27

4.2.10 Arroyo Willow Thickets Alliance ............................................................................................. 27

4.2.11 Needle Grass - Melic Grass Grassland Alliance ................................................................... 28

4.2.12 Wild Oats and Annual Brome Grasslands Semi-Natural Alliance ...................................... 29

4.2.13 Upland Mustards or Star-Thistle Fields Semi-Natural Alliance .......................................... 29

4.2.14 Cattail Marshes Alliance ........................................................................................................ 29

4.2.15 Emergent Wetland ................................................................................................................. 30

4.2.16 Beach ...................................................................................................................................... 30

4.2.17 Ice Plant Mats Semi-Natural Alliance ................................................................................... 30

4.2.18 Disturbed Habitat ................................................................................................................... 30

4.2.19 Golf Course – Developed....................................................................................................... 31

4.2.20 Open Water ............................................................................................................................ 31

4.2.21 Parks and Ornamental Plantings .......................................................................................... 31

4.2.22 Urban/Developed .................................................................................................................. 31

4.3 General Wildlife ................................................................................................................................... 31

4.3.1 Invertebrates .......................................................................................................................... 32

4.3.2 Fish ......................................................................................................................................... 32

4.3.3 Amphibians ............................................................................................................................ 32

4.3.4 Reptiles ................................................................................................................................... 32

4.3.5 Birds ........................................................................................................................................ 32

4.3.6 Mammals ............................................................................................................................... 37

4.4 Special-Status/Regulated Resources ................................................................................................ 37

4.4.1 Sensitive Vegetation Communities ....................................................................................... 37 27 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT 12760 iii AUGUST 2023

4.4.2 Special-Status Plant Species ................................................................................................ 41

4.4.3 Special-Status Wildlife Species ............................................................................................. 42

4.4.4 Jurisdictional Aquatic Resources .......................................................................................... 51

4.4.5 Wildlife Corridors and Habitat Linkages ............................................................................... 59 5 Impacts and Recommendations ...................................................................................................................... 62

5.1 Impacts to Vegetation Communities and Land Covers, Including Native Grassland ...................... 63

5.2 Impacts to Special-Status Plants ........................................................................................................ 69

5.3 Impacts to Special-Status Wildlife Species ........................................................................................ 69

5.3.1 Invertebrates .......................................................................................................................... 70

5.3.2 California Red-Legged Frog ................................................................................................... 71

5.3.3 Western Pond Turtle .............................................................................................................. 73

5.3.4 Special-Status and Common Raptor Species ...................................................................... 73

5.3.5 Yellow Warbler and Other Special-Status Bird Species ....................................................... 74

5.4 Impacts to Jurisdictional Waters ........................................................................................................ 75

5.5 Impacts to Wildlife Corridors and Habitat Connectivity ..................................................................... 76 6 References ........................................................................................................................................................ 78 TABLES
1 Surveys, Dates, Personnel, and Conditions ..................................................................................................... 13 2 National Indicator Status Ratings and Their Rating Categories ..................................................................... 16 3 Summary of Vegetation Communities and Land Cover Types ....................................................................... 23 4 Raptor Survey Results ...................................................................................................................................... 35 5 Native Grassland Results by Polygon .............................................................................................................. 39 6 California Red-Legged Frog Surveys (2022) .................................................................................................... 47 7 Summary of Potential Jurisdictional Aquatic Resources ................................................................................ 54 8 Impacts to Sensitive Vegetation Communities and Land Cover Types .......................................................... 66

FIGURES
1 Project Location ................................................................................................................................................ 84 2 Project Site ........................................................................................................................................................ 86 3 Survey Areas ...................................................................................................................................................... 88 4 Monarch Butterfly Survey Area ......................................................................................................................... 90 5 Vegetation Communities and Land Covers ..................................................................................................... 92 6 Raptor Survey Results ...................................................................................................................................... 94 7A Native Grassland Assessment ......................................................................................................................... 96 7B Native Grassland Assessment ......................................................................................................................... 98 8 Rare Plant Results .......................................................................................................................................... 100 28 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT 12760 iv AUGUST 2023
9 Monarch Butterfly Survey Results .................................................................................................................. 102 10 California Red-Legged Frog Survey Results ................................................................................................... 104 11 Other Special-Status Wildlife Species Observations ..................................................................................... 106 12 Aquatic Resources Delineation ...................................................................................................................... 108 12a Aquatic Resources A, C, D, and E ................................................................................................................... 110 12b Aquatic Resource B (north) ............................................................................................................................ 112 12c Aquatic Resource B (south) ............................................................................................................................ 114 12d Aquatic Resource D ......................................................................................................................................... 116 12e Aquatic Resource E ......................................................................................................................................... 118 12f Aquatic Resource F ......................................................................................................................................... 120 13 ESHA, Sensitive Resources, and Setbacks .................................................................................................... 122 14 Impacts to Sensitive Biological Resources .................................................................................................... 124

APPENDICES
A Local Policies
B Photo Log
C Wildlife Compendium
D Native Grassland Data Sheets
E Plant Compendium
F Plant and Wildlife Potential to Occur Tables
G Wetland Determination Data Forms
29 12760 v AUGUST 2023

Acronyms and Abbreviations
Acronym/Abbreviation Definition
CCA California Coastal Act
CCC California Coastal Commission
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
CESA California Endangered Species Act
CFR Code of Federal Regulations
CLUP Coastal Land Use Plan
CNDDB California Natural Diversity Database
CNPS California Native Plant Society
CRPR California Rare Plant Rank
CWA Clean Water Act
EPA U.S. Environmental Protection Agency
ESA Endangered Species Act
ESHA Environmentally Sensitive Habitat Area
FP Fully Protected
MBTA Migratory Bird Treaty Act
MCV Manual of California Vegetation
NCL Natural Community List
NMFS National Marine Fisheries Service
OHWM Ordinary High Water Mark
RWQCB Regional Water Quality Control Board
SSC Species of Special Concern
TNW Traditional Navigable Water
UPRR Union Pacific Railroad
USACE U.S. Army Corps of Engineers
USFWS U.S. Fish and Wildlife Service
USDA U.S. Department of Agriculture
USGS U.S. Geological Survey

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1 Introduction
Dudek has prepared this Biological Resources Assessment Report (Report) for Sandpiper Golf Trust LLC and Ty Warner Hotels & Resorts in support of the Sandpiper Golf Club Project (Project). The purposes of the report are to provide methods and results of biological surveys , describe the biological resources o n the Project site, address potential impacts from development of the Project, and provide recommendations to avoid, minimize, or mitigate any potential impacts . The impact analysis and recommended measures are based on potentially occurring resources and applicable federal, state, and local regulations . In addition to describing methods and results of surveys Dudek has conducted, the Report incorporates findings of previous surveys conducted on the Project site.

Due to discrepancies in the delineation of Environmentally Sensitive Habitat Areas (ESHA) between the City of Goleta and Dudek’s on the ground mapping and assessment of ESHA, Dudek has also prepared an ESHA memorandum (memo) that provides substantial evidence pursuant to City of Goleta Conservation Element Policies CE 1.3 and CE 1.5 to support the Project requested map modifications to the City General Plan/Coastal Land Use Plan (CLUP) Figure 4-1, Special-Status Species and Environmentally Sensitive Habitat Areas (Dudek 2023).

1.1 Site Location and Surrounding Area
The Sandpiper Golf Club, Assessor’s Parcel Number 079-210-059, is situated within the far western portion of the City of Goleta in Santa Barbara County , California, along the bluffs adjacent to the Pacific Ocean and 2.5 miles south of the Los Padres National Forest and Santa Ynez Mountains (Figure 1, Project Location). It is located at 7925 Hollister Avenue (Figure 2, Project Site); the site entrance and existing parking lot are in the northern portion of the site, immediately west of the intersection of Hollister Avenue and Cathedral Oaks Road. Residential development and open space associated with Ellwood Mesa are to the east , and Ellwood Mesa and University of California, Santa Barbara open spaces and Coal Oil Point Reserve together form a corridor of undeveloped land extending eastward more than 1.5 miles to the boundary of Isla Vista. Immediately north of Hollister Avenue are residential development, some open space associated with Devereux Creek, and a narrow strip of eucalyptus woodland within and adjacent to the Union Pacific Railroad (UPRR) corridor. U.S. Highway 101 parallels the UPRR immediately to the north, between 0.05 and 0.2 miles from the Project site. A mixture of residential development and agricultural lands (rangeland and cultivated lands) extend approximately 0.7 mile north from the highway, and undeveloped ranchland dominates the landscape farther northward, to the boundary of Los Padres National Forest, approximately 32.5 miles north of the site. To the west of the Project site, on the south side of U.S. Highway 101, is an existing Beacon West Energy Group facility, Bell Canyon Creek, then the Ritz-Carlton, Bacara, Santa Barbara Resort, 0.4 mile west of the Project site. Lands farther to the west are mostly undeveloped . The Pacific Ocean is immediately west and south of the Project site.

1.2 Project Description
The Project involves a redesign and rerouting of the existing 18 -hole golf course including a new comfort station, demolition and replacement of the existing clubhouse with a new clubhouse and restaurant building, and renovations and enhancements to the existing historic Barnsdall Gas Station. The new clubhouse would replace the existing 9,305-square-foot, 27-foot-high clubhouse and golf cart storage facility, which were built in the 1970s and have not been significantly updated since construction. The redevelopment Project would bring the golf course up to date to continue serving the community.
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1.2.1 Golf Course Redesign
This Project proposes renovations to the existing golf course. During construction of the original course, almost the entire site was graded and scarified as evidenced by photographic aerials taken during construction. Portions of Devereaux creek were filled and the creek directed into culverts at strategic locations, in order to facilitate golf play.

For the proposed renovations. the applicant hired a renowned golf course architect, Tom Doak, specifically for his skill at working with the existing contours when approaching a redesign. The proposed course layout is largely similar to the grading plan approved by Santa Barbara County in 1971. The redesign proposes minimal cut into native soils in order to minimize ground disturbance. Of the 48 acres of grading, only 7 acres would take place in areas not already subject to regular golf course maintenance. Existing hardscape cart paths would largely be removed except for tee boxes and returns and certain crossings.

The design intention is to naturalize the golf course with the result being a significant increase in habitat and foraging opportunities. Correspondingly, the project reduces turfed areas on the course by 53 acres, and proposes to landscape these areas with native materials. Importantly, this will also result in a significant reduction water use and in the need for nutrients and biochemicals to maintain the grass. Another beneficial aspect of the design is to introduce sand-capping, a form of mulch. The purpose for the sand -capping is to substantially improve drainage and water quality by providing what would essentially be a giant natural filter on the course. Only 2 of the 36 acres of sand-capping would occur to areas not currently subject to regular maintenance. In these (non-ESHA) areas, the process for introducing the sand cap is allow the plant material to dry out and then to remove plant material and place sand and topsoil directly on the underlying soils. After replacing irrigation, hydroseeding or sod will be introduced along with shrubs, and other landscaping.

As discussed in the following report, the applicant also proposes to replace an existing concrete “Arizona” style cart path and 10-12” culvert that are currently located within Deveraux Creek. These elements will be replaced with a free span bridge with abutments at each end of the creek and the waterway will be restored to a natural habitat without restricted flows. The existing hardscape cart path in the ESHA will be removed and replaced with a path that reduce hardscape by almost 50%.

1.2.2 Clubhouse
The club house design is inspired by the natural landscape and site condition of the grassy rolling hills of the course, the bluff, and the ocean. The intent is to create a building that is directly related to its spectacular setting, honoring the contours of the land and blending the architecture, landscape, and transparency of the sky in the composition.

The Project includes improvements to area roadways and Project entrances, such as relocation of the main entrance to align it with Cathedral Oaks Road, as well as landscape enhancements on Hollister Avenue. The parking lot would be updated and restriped to provide ample parking and access for the Golf Course.

1.2.3 Barnsdall Gas Station
The Project would include repairing the historic Barnsdall Gas Station and reinvigorating it into a quick stop cafe for golfers and community members. It would include ample bicycle parking to attract those cycling along Hollister Avenue, a new structure for food prep, remodel of the interior of the existing building , and any necessary repairs, painting, and finishing to the exterior of the existing building. 33 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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1.2.4 Comfort and Maintenance
A new comfort station is proposed on the golf course adjacent to the sixth green. The comfort station would have men’s and women’s restroom facilities and would include a small kitchenette for grab and go snacks and for use during events. The main existing maintenance building will be removed and reconstructed. An existing equipment storage building will be expanded.
34 12760 4 AUGUST 2023

2 Regulatory Setting
This section outlines the federal, state, and local regulations pertinent to the biological resources of the Project site and immediate vicinity. Some of the biological resources that could be affected by the proposed Project are regulated by resource agencies, which often overlap in jurisdiction. This section identifies and discusses the various programs regulating sensitive habitats, state- and/or federally listed threatened or endangered plants and wildlife, and jurisdictional aquatic/hydrological features, such as drainages, streambeds, riparian habitat, and wetlands.

2.1 Sensitive Vegetation Communities
For the purpose of this Report, sensitive vegetation communities and habitats include:
 Alliances on the California Department of Fish and Wildlife ( CDFW) California Natural Community List with a state rarity rank of S1, S2, or S3 (CDFW 2022a);
o S1: Critically Imperiled – At very high risk of extirpation in the jurisdiction due to very restricted range, very few populations or occurrences, very steep declines, severe threats, or other factors. o S2: Imperiled – At high risk of extirpation in the jurisdiction due to restricted range, few populations or occurrences, steep declines, severe threats, or other factors. o S3: Vulnerable – At moderate risk of exti rpation in the jurisdiction due to a fairly restricted range, relatively few populations or occurrences, recent and widespread declines, threats, or other factors.  Vegetation communities or habitats listed in the California Natural Diversity Database (CNDDB) ( CDFW 2022b); or
 Habitats considered locally sensitive under policies of the City of Goleta General Plan/Local Coastal Land Use Plan (CLUP) (City of Goleta 2006).

2.2 Special-Status Plant and Wildlife Species Defined
For the purpose of this Report, special-status plant species and wildlife species are those:
 Designated as either rare, threatened, or endangered by U.S. Fish and Wildlife Service ( USFWS), National Marine Fisheries Service (NMFS), or CDFW, and protected under either the federal Endangered Species Act (ESA) (16 USC 1531 et seq.) or the California Endangered Species Act (CESA) (California Fish and Game Code, Section 2050 et seq.) , or meet the CEQA definition for endangered, rare, or threatened (14 CCR 15380[b],[d]);
Additional special-status wildlife species in this Report include those that are:
 California Species of Special Concern (SSC), as designated by CDFW (2022c);  Vertebrate species that are fully protected (FP) species, as described in Fish and Game Code; or  Those considered special-status species under the General Plan/CLUP. 35 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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Additional special-status plant species include those that are:
 Candidate species being considered or proposed for listing under the federal ESA or CESA; or  Of expressed concern to resource/regulatory agencies or local jurisdictions. This includes plants included on the CDFW Special Vascular Plants, Bryophytes, and Lichens List (CDFW 2022d) as well as species with a California Rare Plant Rank (CRPR) of 1, 2, 3, or 4 in the California Nati ve Plant Society (CNPS) Inventory of Rare and Endangered Plants of California (CNPS 202 2a). Plants included on the CNPS Inventory are classified as follows:
o CRPR 1A: plants presumed extirpated in California and either rare or extinct elsewhere; o CRPR 1B: plants rare, threatened, or endangered in California and elsewhere; o CRPR 2A: plants presumed extirpated in California but common elsewhere; o CRPR 2B: plants rare, threatened, or endangered in California but more common elsewhere o CRPR 3: plants about which we need more information – a review list; and o CRPR 4: plants of limited distribution – a watch list.

2.3 Endangered Species Acts
Various plant and wildlife species receive protections due to being listed as threatened or endangered under federal and state statutes.

2.3.1 Federal Endangered Species Act
The federal Endangered Species Act (ESA) of 1973 (16 USC 1531 et seq.), as amended, is administered by the USFWS and the National Oceanic and Atmosph eric Administration NMFS. This legislation is intended to provide a means to conserve the ecosystems upon which endangered and threatened species depend and provide programs for the conservation of those species, thus preventing extinction of plants and wi ldlife. Under the provisions of Section 9(a)(1)(B) of the ESA (16 USC 1531 et seq.), it is unlawful to “take” any listed species.

In a case where a property owner seeks permission from a federal agency for an action that could affect a federally listed plant or wildlife species, the property owner and agency are required to consult with USFWS or NMFS. Take permits are obtained either through a Biological Opinion, when the action being permitted involves another federal agency as described in Section 7 of the ESA, or a Habitat Conservation Plan, under Section 10 of the ESA.

2.3.2 California Endangered Species Act
CDFW administers the CESA (California Fish and Game Code), which prohibits the “take” of plant and animal species designated by the Fish and Game Commission as endangered or threatened in the State of California. Protections are also accorded “candidate” species, which include plant and animal species that are formally being considered for listing as endangered or threatened. Section 2081 of the California Fish and Game Code provides for the application of an incidental take permit for take of species protected under CESA that occurs incidentally during otherwise lawful activities.

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2.4 Migratory Bird Protections
The Migratory Bird Treaty Act (MBTA) was originally passed in 1918 as four bilateral treaties, or conventions, for the protection of a shared migratory bird resource (16 USC 703 –712). The primary motivation for the international negotiations was to stop the “indiscriminate slaughter” of migratory birds by market hunters and others. Each of the treaties protects selected species of birds and provides for closed and open seasons for hunting game birds.

The MBTA protects over 800 species of birds, which are listed in the Code of Federal Regulations (50 CFR 10.13).

The MBTA prohibits the “take” of any migratory bird or any part, nest, or eggs of any such bird. Under the MBTA, take is defined as pursuing, hunting, shooting, capturing, collecting, or killing, or attempting to do so.

Pursuant to Section 3503.5 of the California Fish and Game Code, it is unlawful to take, possess, or destroy any birds of prey; or to take, possess, or destroy any nest or eggs of such birds. “Birds of prey” refer to species in the orders Falconiformes and Strigiformes [now also including the order Accipitriformes]. Active nests of all other native birds are similarly protected under Sections 3503 and 3513 of the California Fish and Game Code. Disturbance that causes nest abandonment and/or loss of reproductive effort is considered “take” by the CDFW. This statute does not provide for the issuance of an incidental take permit.

2.5 Jurisdictional Aquatic Resources
Three primary agencies regulate activities within streams, wetlands, and ri parian areas throughout California:
the U.S. Army Corps of Engineers (USACE) Regulatory Program regulates activities pursuant to Section 404 of the federal Clean Water Act (CWA) , the CDFW regulates activities under Sections 1600 –1616 of the California Fish and Game Code , and the Regional Water Quality Control Board s (RWQCBs) regulates activities under the Porter-Cologne Water Quality Control Act and Section 401 of the CWA. In addition, the California Coastal Commission (CCC) regulates wetlands and riparian habitat in the c oastal zone. The City of Goleta General Plan/CLUP includes protection policies for creeks, riparian areas, and wetlands ( City of Goleta 2006 ). The following discussion provides information on each agency’s regulatory program. In addition, Section IV, Appendix G (Environmental Checklist Form), of the Californ ia Environmental Quality Act (CEQA) Statutes and Guidelines requires an evaluation of impacts to “federally protected wetlands as defined by Section 404 of the Clean Water Act (including but not limited to marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.”

2.5.1 U.S. Army Corps of Engineers
The definition of waters of the United States establishes the geographic scope for authority under Section 404 of the CWA; however, the CWA does not specifically define waters of the United States, leaving the definition open to statutory interpretation and agency rulemaking. The definition of what constitutes “waters of the United States” (provided in 33 CFR Section 328.3(a)) has changed multiple times over the past few decades starting with the United States v. Riverside Bayview Homes, Inc. court ruling in 1985. Subsequent court proceedings, rule makings, and congressional acts in 2001 (Solid Waste Agency of Northern Cook County v. United States Army Corps of Engineers), 2006 (Rapanos v. United States), 2015 (Clean Water Rule), 2018 (suspension of the Clean Water Rule), 2019 (formal repeal of the Clean Water Rule), 2020 (Navigable Waters Protection Rule, NWPR), and 2021 (Pasqua Tribe et al v. United States Environmental Protection Agency resulting in remand and vacatur of the NWPR and a return to “the pre-2015 regulatory regime”) have 37 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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attempted to provide greater clarity to the term and its regulatory implementation. On December 30, 2022, the agencies announced the final Revised Definition of “Waters of the United States” rule (Rule) (88 CFR 3004–3144). The Rule was published in the Federal Register on January 18, 2023, and became effective on March 20, 2023, restoring federal jurisdiction over waters that were protected prior to 2015 under the Clean Water Act for traditional navigable waters, the territorial seas, interstate waters, and upstream water resources that significantly affect those waters. The Rule represents a re-expansion of federal jurisdiction over certain water bodies and wetlands previously exempt pursuant to the 2020 Navigable Waters Protection Rule. The Rule also considers various subsequent court decisions including two notable Supreme Court decisions.

There are two key changes that the Rule incorporates. Firstly, the Rule reinstates the “Significant Nexus” test. The “Significant Nexus” test refers to waters that either alone, or in combination with similarly situated waters in the region, significantly affect the chemical, physical, or biological integrity of traditional navigable waters, interstate waters, or the territorial seas (86 FR 69372-69450). The “Significant Nexus” test attempts to establish a scientific connection between smaller water bodies, such as ephemeral or intermittent tributaries, and larger, more traditional navigable waters such as rivers. Significant nexus evaluations take into consideration hydrologic and ecologic factors including, but not limited to, volume, duration, and the frequency of surface water flow in the resource and its proximity to a traditional navigable water, and the functions performed by the resource on adjacent wetlands. Second, the Rule adopts the “Relatively Permanent Standard” test. To meet the “Relatively Per manent Standard” water bodies must be relatively permanent, standing, or continuously flowing and have a continuous surface connection to such waters.

On May 25, 2023, the Supreme Court issued its long-anticipated decision in Sackett v. EPA., in which it rejected the EPA's claim that "waters of the United States," as defined in the CWA , includes wetlands with an ecologically significant nexus to traditional navigable waters. The Supreme Court held that only those w etlands with a continuous surface water connection to traditional navigable waterways would be afforded federal protection under the CWA. Specifically, to assert jurisdiction over an adjacent wetland under the CWA, a party must establish that (1) the adjacent body of water constitutes water[s] of the United States’ (i.e., a relatively permanent body of water connected to traditional interstate navigable waters) and (2) the wetland has a continuous surface connection with that water, making it difficult to determine where the water ends and the wetland begins. The Rule will need to be modified by the Biden administration in light of this decision.

The term “wetlands” (a subset of waters of the United States) is defined in 33 CFR, Section 328.3(c)(16), as “areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas.” In the absence of wetlands, the limits of USACE jurisdiction in non-tidal waters, such as intermittent streams, extend to the “ordinary high water mark,” which is defined in 33 CFR 328.3(c)(7) as “that line on the shore established by the fluctuations of water and indicated by physical characteristics such as a clear, natural line impressed on the bank, shelving, changes in the character of soil, destruction of terrestrial vegetation, the presence of litter and debris, or other appropriate means that consider the characteristics of the surrounding areas.”

2.5.2 California Department of Fish and Wildlife
Under California Fish and Game Code Sections 1600 –1616, CDFW has authority to regulate work that will substantially divert or obstruct the natural flow, or substantially change or use any material from the bed, channel, or bank of any river, stream, or lake. CDFW also has authority to regulate work that will deposit or dispose of debris, 38 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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waste, or other material containing crumbled, flaked, or ground pavement where it may pass into any river, stream, or lake. This regulation takes the form of a requirement for a Lake or Streambed Alteration Agreement (LSAA) and is applicable to all federal and nonfederal projects.

2.5.3 Regional Water Quality Control Boards
Pursuant to Section 401 of the federal CWA, the RWQCB s regulate discharging waste, or proposing to discharge waste, within any region that could affect a water of the state (California Water Code, Section 13260[a]), pursuant to provisions of the Porter-Cologne Water Quality Control Act. Waters of the state are defined as “any surface water or groundwater, including saline waters, within the boundaries of the state” ( California Water Code, Section 13050[e]). Before USACE will issue a CWA Section 404 permit, applicants must receive a CWA Section 401 Water Quality Certification from the local RWQCB. If a CWA Section 404 permit is not required for a project, the RWQCB may still require a permit (i.e., Waste Discharge Requirement) under the Porter-Cologne Water Quality Control Act.

2.5.4 California Coastal Commission
Under the California Coastal Act (CCA), the CCC, in partnership with local governments, regulates impacts to wetlands and other sensitive habitat in the “coastal zone” and requires a coastal development permit for almost all development within this zone. The coastal zone generally extends approximately 1,000 yards inland from the mean high tide line. In less developed areas, it can extend up to 5 miles inland from the mean high tide line, but can also be considerably less than 1,000 yards inland in developed areas.

Section 30121 of the CCA defines wetlands as “lands within the coastal zone which may be covered periodically or permanently with shallow water and include saltwater marshes, swamps, mudflats, and fens.” In contrast to USACE, which uses a three -parameter definition to delineate wetlands, CC C essentially uses the Cowardin et al. (1979) method of wetlands classification, which defines wetland boundaries by a single parameter (i.e., hydric soils, hydrophytic vegetation, or hydrology).

2.5.5 City of Goleta
The CCA directs each city or county wit hin the coastal zone to prepare a Local Coastal Program (LCP) for CCC certification. Once the LCP is certified by CCC, the local government assumes coastal development permit authority for most development within the coastal zone.

The City of Goleta (City) General Plan/CLUP includes a coastal land use plan but not a certified LCP (City of Goleta 2006). Therefore, the CCC has jurisdictional authority in the plan area. The General Plan/CLUP defines wetland boundaries by a single parameter (i.e., hydric soils, hydrophytic vegetation, or hydrology) (City of Goleta 2006 ), consistent with the CCC. Appendix A, Local Policies, includes aquatic resource related policies relevant to the Project including:
 Policy CE 1: Environmentally Sensitive Habitat Area Designations and Policy [GP/CP] o Policy CE 1.2: Designation of Environmentally Sensitive Habitat Areas  Policy CE 2: Protection of Creeks and Riparian Areas [GP/CP] o Policy CE 2.1: Designation of Protected Creeks
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o Policy CE 2.2: Streamside Protection Areas
o Policy CE 2.3: Allowable Uses and Activities in Streamside Protection Areas o Policy CE 2.5: Maintenance of Creeks as Natural Drainage Systems o Policy CE 2.6: Restoration of Degraded Creeks
 Policy CE 3: Protection of Wetlands [GP/CP]
o Policy CE 3.1: Definition of Wetlands
o Policy CE 3.2: Designation of Wetland ESHAs
o Policy CE 3.3: Site-Specific Wetland Delineations
o Policy CE 3.4: Protection of Wetlands in the Coastal Zone o Policy CE 3.6: Mitigation of Wetland Fill
o Policy CD 3.7: Lagoon Protection

2.6 California Environmental Quality Act
CEQA requires identification of a project’s potentially significant impacts on biological resources and ways that such impacts can be avoided, minimized, or mitigated. The act also provides guidelines and thresholds for use by lead agencies for evaluating the significance of proposed impacts.

2.7 Local Laws, Ordinances, Regulations, and Standards
In addition to the regulations identified above, the following local laws, ordinances, regulations, and standards apply to the environmental review of potential impacts on biological resources as a result of the Project.

2.7.1 City of Goleta General Plan/Coastal Land Use Plan The City of Goleta adopted the Goleta General Plan/ CLUP in 2006 (City of Goleta 2006). The General Plan/ CLUP aims to create a coherent vision of the City’s future that forms the foundation for the General Plan’s goals, objectives, and policies. The General Plan/CLUP Conservation Element includes a focus on preserving, protecting, and enhancing the City’s natural resources. Policies relevant to the biological resources at the Project site are provided in Appendix A and include:

 Policy CE 1: Environmentally Sensitive Habitat Area Designations and Policy [GP/CP] o Policy CE 1.1: Definition of Environmentally Sensitive Habitat Areas o Policy CE 1.2: Designation of Environmentally Sensitive Habitat Areas o Policy CE 1.3: Site-Specific Studies and Unmapped ESHAs o Policy CE 1.4: Illegal Destruction of ESHAs
o Policy CE 1.5: Corrections to Mapping of ESHAs
o Policy CE 1.6: Protection of ESHAs
o Policy CE 1.7: Mitigation of Impacts to ESHAs
o Policy CE 1.8: ESHA Buffers
o Policy CE 1.9: Standards Applicable to Development Projects 40 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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o Policy CE 1.10: Management of ESHAs
 Policy CE 2: Protection of Creeks and Riparian Areas [GP/CP] o Policy CE 2.1: Designation of Protected Creeks
o Policy CE 2.2: Streamside Protection Areas
o Policy CE 2.3: Allowable Uses and Activities in Streamside Protection Areas o Policy CD 2.4: Dedication of Easements or Other Property Interests o Policy CE 2.5: Maintenance of Creeks as Natural Drainage Systems o Policy CE 2.6: Restoration of Degraded Creeks
 Policy CE 3: Protection of Wetlands [GP/CP]
o Policy CE 3.1: Definition of Wetlands
o Policy CE 3.2: Designation of Wetland ESHAs
o Policy CE 3.3: Site-Specific Wetland Delineations
o Policy CE 3.4: Protection of Wetlands in the Coastal Zone o Policy CE 3.6: Mitigation of Wetland Fill
o Policy CE 3.7: Lagoon Protection
 Policy CE 4: Protection of Monarch Butterfly Habitat Areas [GP/CP] o Policy CE 4.1: Definition of Habitat Area
o Policy CE 4.2: Designation of Monarch Butterfly ESHAs o Policy CE 4.3: Site-Specific Studies and Unmapped Monarch ESHAs o Policy CE 4.4: Protection of Monarch Butterfly ESHA
o Policy CE 4.5: Buffers Adjacent to Monarch Butterfly ESHAs o Policy CE 4.6: Standards Applicable to New Development Adjacent to Monarch ESHAs  Policy CE 5: Protection of Other Terrestrial Habitat Areas [GP/CP] o Policy CE 5.1: Designation of Other Terrestrial ESHA
o Policy CE 5.2: Protection of Native Grasslands
o Policy CE 5.3: Protection of Coastal Bluff Scrub, Coastal Sage Scrub, and Chaparral ESHA  Policy CE 6: Protection of Marine Habitat Areas [GP/CP] o Policy CE 6.1: Definition of Marine ESHAs
o Policy CE 6.2: Protection of Marine ESHAs
 Policy CE 7: Protection of Beach and Shoreline Habitats [GP/CP] o Policy CE 7.1: Designation of Beach and Shoreline ESHAs o Policy CE 7.2: Protection of Dunes
o Policy CE 7.3: Protection of Beach Areas
o Policy CE 7.4: Permitted Uses of Beach and Shoreline Areas o Policy CE 7.5: Shoreline Protective Structures
o Policy CE 7.6: Restoration of Degraded Shoreline Areas o Policy CE 7.7: Recreation Facilities on Beach Areas
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o Policy CE 7.8: Protection of Seabird Nest Areas
 Policy CE 8: Protection of Special-Status Species [GP/CP] o Policy CE 8.1: ESHA Designation
o Policy CE 8.2: Protection of Habitat Areas
o Policy CE 8.3: Site-Specific Biological Resources Study o Policy CE 8.4: Buffer Area for Raptor Species
 Policy CE 9: Protection of Native Woodlands [GP/CP]
o Policy CE 9.1: Definition of Protected Trees
o Policy CE 9.2: Tree Protection Plan
o Policy CE 9.3: Native Oak Woodlands and Savannas
o Policy CE 9.4: Tree Protection Standards
o Policy CE 9.5: Mitigation of Impacts to Native Trees

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3 Methods
Dudek conducted a literature review and field surveys in preparation of this Report . In addition to surveys Dudek conducted in 2021 and 2022 in support of the Project, biological surveys were conducted on the Project site for previously proposed projects. In general, surveys were conducted within the Project site boundary, including the undeveloped areas, such as in Bell Creek Canyon, west of the golf course. But several survey areas extended beyond the Project boundaries (Figure 3, Survey Areas).

3.1 Literature Review
Prior to conducting field surveys, Dudek initiated a review of available information on biological resources occurring or potentially occurring on the Project site. Several previous biological surveys have been conducted at the Sandpiper Golf Club, and various standard sources include information relevant to the occurrence or potential occurrence of sensitive biological resources on the Project site. T he literature review first involved a searc h of standard databases for sensitive biological resources. Dudek queried the CNDDB (CDFW 2022b) to determine what special-status plant species and special-status wildlife species could occur in the region. Typical CNDDB queries include nine U.S. Geological Survey (USGS) quadrangles (quads): the Project quad and the eight surrounding quads.

However, because of the coastal location of the Project site, only five quads border the Project quad. Therefore, the query focused on the following six q uads: Dos Pueblos Canyon (the Project quad), Goleta, Tajiguas, Santa Ynez, Lake Cachuma, and San Marcos Pass. Dudek also queried the CNPS Inventory of Rare and Endangered Plants (CNPS 2022a) for special-status plant species observed in the region and the USFWS’s Information for Planning and Consultation (IPaC) Trust Resources website (USFWS 2022a) for a list of potentially occurring federally listed species. Other sources consulted included:
 California Natural Community List (CDFW 2020a)
 CNPS A Manual of California Vegetation Online (CNPS 2022b)  Google aerial imagery (Google 2022)
 USFWS National Wetlands Inventory (USFWS 2022b)
 U.S. Geological Survey’s National Hydrography Dataset (USGS 2022) Local sources include the City’s General Plan/ CLUP ( City of Gole ta 2006 ), which in addition to its biological resources policies, includes occurrences of special -status plant and wildlife species. Other local sources that provide information on biological resources occurring in the area include:
 City of Goleta Creek & Watershed Management Plan (City of Goleta 2020)  Final Ellwood Mesa/Sperling Preserve Open Space Monarch Butterfly Habitat Management Plan (City of Goleta 2019)
 Goleta Urban Forest Management Plan (City of Goleta 2017)  Monarch Butterfly Overwintering Sites (Xerces Society 2022a)  Monarch Butterfly Overwintering Sites in Santa Barbara County California (Meade 1999)  The Birds of Santa Barbara County, California (Lehman 2022) 43 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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Finally, reports on previous biological surveys, which pertain mostly to the presence of California red -legged frog (Rana draytonii) and birds, included:
 Biological Assessment for the Sandpiper Golf Course Renovation Project, Goleta, California (Dana Bland & Associates 2004)
 California Red-legged Frog Status, Sandpiper Golf Course, Goleta, California (Rathbun 2004)  Sandpiper Golf Course: Conceptual Plan for Riparian and Red-Legged Frog Habitat Restoration (Tierney 2004)  Sandpiper Golf Course Renovation Project: Winter Bird Surveys (TOBC 2004a)  Sandpiper Golf Course Renovation Project: Spring Bird Surveys (TOBC 2004b)  Sandpiper Golf Course Renovation Project: Bird Surveys (TOBC 2006)  Sandpiper Golf Course: Monarch Butterfly Survey (Althouse and Meade Inc. 2004)

3.2 Field Surveys in 2021 and 2022
Dudek conducted a reconnaissance survey and vegetation mapping in 2021. Based on results of the reconnaissance survey and biological resources issues identified during the literature review, Dudek conducted additional, focused surveys in 2022, as described below. Survey types, dates, times, personnel, and conditions are included in Table 1.

Table 1. Surveys, Dates, Personnel, and Conditions
Date Time Personnel Conditions Survey Type
4/2/2021 0800–1415 HM 53°F–63°F; 0%–
100% cc; 1–3 mph
winds
Reconnaissance/
Vegetation Mapping
11/24/2021 0630–0900 (P)
0915–1200 (R)
AD 51°F–60°F; 0% cc;
0–2 mph winds
Monarch butterfly
01/06/2022 0700-1020 (P)
1030-1200 (R)
AD 54°F–63°F; 5%–
10% cc; 0–2 mph
winds
Monarch butterfly
3/22/2022 0735–1121 DC 61°F–83°F; 0%–
10% cc; 1–6 mph
winds
Coastal raptor
4/13/2022 0720–1118 DC 51°F–61°F; 0% cc;
1–4 mph wind
Coastal raptor
4/25/2022 1529–1730 AD 73°F; 0% cc; 1–
2mph wind
CRLF (daytime)
4/25/2022 2031-2355 AD, DC 72°F; 50% cc; 0–
1mph wind
CRLF (nighttime)
4/27/2022 0737–1121 DC 55°F–64°F; 0%–
10% cc; 3–8 mph
wind
Coastal raptor
5/4/2022 1126–1800 HM 64°F–66°F; 0% cc;
1–7 mph wind
Special-status plants
5/10/2022 0801–1601 HM, RS 56°F–64°F; 10% cc;
1–15 mph wind
Aquatic resources
delineation
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Table 1. Surveys, Dates, Personnel, and Conditions
Date Time Personnel Conditions Survey Type
5/11/2022 0754–1727 HM, RS 56°F–67°F; 0% cc;
2–15 mph wind
Aquatic resources
delineation
5/11/2022 1955-2133 AD, RS 59°F; 0% cc; 0–1
mph wind
CRLF (nighttime)
5/13/2022 1120-1630 AD 72°F–77°F; 0% cc;
1–3 mph wind
CRLF (daytime)
5/24/2022 2107-2323 AD, HM 55°F; 100% cc; 0–1
mph wind
CRLF (nighttime)
5/26/2022 0758–1724 HM 59°F–60°F; 100%
cc; 2–5 mph wind
Native grassland
assessment
5/27/2022 0740–1132 HM 59°F–60°F; 100%
cc; 1–5 mph wind
Native grassland
assessment
5/18/2022 0711–1111 DC 55°F–60°F; 0%–
50% cc; 1–5 mph
wind
Coastal raptor
6/20–21/2022 2103-0007 AD, DC 71°F–77°F; 0% cc;
0–2 mph wind
CRLF (nighttime)
7/21/2022 2058-2345 AD, RS 61°F–62°F; 0%–
10% cc; 0–3 mph
wind
CRLF (nighttime)
6/10/2022 0741–1104 DC 61°F–63°F; 100%
cc; 0–4 mph wind
Coastal raptor
7/27/2022 1430-1730 AD 61°F–71°F; 0% cc;
1–3 mph wind
CRLF (daytime)
7/7/2022 0745–1549 HM 65°F–71°F; 0% cc;
0–7 mph wind
Special-status plants
8/12/2022 0950–1126 HM 69°F–71°F; 0% cc;
1–6 mph wind
Aquatic resources
delineation
Notes: CRLF = California red -legged frog; P = Project Site ; R = Reference Site (for monarch butterflies); F = Fahrenhe it; cc = cloud cover; mph = miles per hour.

Biologists’ initials: AD = Andrea Dransfield; DC = Dave Compton; HM = Heather Moine; RS = Rachel Swick.

3.2.1 Reconnaissance Survey
On April 2, 2021, Dudek performed a reconnaissance -level field survey within the Project site (Table 1) . The reconnaissance-level field survey was conducted to identify existing biological resources and potential biological constraints. Dudek mapped vegetation within the Project site, including the golf course and areas outside the golf course, which occur along Bell Canyon Creek, the Pacific Ocean bluffs, and the eastern boundary of the site, as well as club house area, maintenance yard, and the historic Barnsdall Gas Station. The reconnaissance survey also included a habitat assessment for special-status plant and wildlife species and an assessment of aquatic resources that could occur on the Project site, including the golf course, other golf course facilities, and the area around Bell Canyon Creek and Bell Canyon Creek Lagoon, west of the golf course. During the survey, the biologist recorded all plant species observed and all wildlife species detected by sight, calls, tracks, scat, or other sign . Methods for vegetation mapping are described below.
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3.2.2 Vegetation Mapping
A Dudek biologist performed vegetation mapping on the Project site consistent with the Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities ( CDFW 2018), and vegetation communities were identified using the Manual of California Vegetation Online (MCV) (CNPS 2022b).

Vegetation communities were classified based on site factors, descriptions, membership rules, distribution, and characteristic species present in the area. Information such as dominant species and associated cover classes were recorded. In some areas, the vegetation communities observed in the field did not match those described in MCV (CNPS 2022b) or included on the California Natural Community List (CDFW 2022a). In these instances, Dudek generated additional site- specific vegetation community or land cover classifications. Additionally, Bell Canyon vegetation had been mapped as part of the City of Goleta Creek & Watershed Management Plan (City of Goleta 2020); therefore, the vegetation mapping included in this plan was incorporated into the vegetation map.

Vegetation communities were generally mapped to the alliance level , except where mapping to the finer -scale association level was necessary to determine sensitivity in accordance with the California Natural Community List (CDFW 2022a). Since the Project site is in the coastal zone, no minimum mapping units apply to sensitive vegetation communities and riparian and wetland vegetation communities; therefore, all sensitive vegetation communities observed were mapped.

Dudek biologists mapped vegetation communities on the Project site while in the field using an Esri ArcGIS mobile application. A Dudek geographic information system (GIS) technician transferred the vegetation boundaries into an ArcGIS file and created a GIS coverage for vegetation communities. Once major line work and community designations were completed, a geodatabase was created to verify that these data were topologically correct and met final quality control and assurance procedures.

3.2.3 Aquatic Resources Delineation
Dudek conducted a field delineation of aquatic resources of the Project site in accordance with the procedures of the Corps of Engineers Wetlands Delineation Manual (USACE 1987) and the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (Version 2) (USACE 2008a). The instruction guidelines for jurisdictional determinations (USACE 2007) present regulation responsibilities of USACE under the CWA: USACE regulates traditional, navigable waters of the United States, adjacent wetlands, and relatively permanent waters tributary to TNW and adjacent wetlands. Wetland vegetation was classified using CNPS (2022b). Wetland areas under the jurisdiction of USACE were delineated based on the presence of hydric soils, hydrophytic vegetation, and wetland hydrology. Non-wetland waters of the United States under the jurisdiction of USACE were delineated based on the presence of an ordinary high water mark (OHWM) and nexus to a TNW of the United States. Identification of the OHWM followed the A Field Guide to the Identification of the Ordinary High Water Mark (OHWM) in the Arid West Region of the Western United States (USACE 2008b), where present. The aquatic resources delineation also included the collection of CDFW jurisdictional boundaries subject to Section 1600 -1616 of the California Fish and Game Code, which extend to the top of bank or the outermost edge of riparian vegetation, whichever is greater, associated with a stream channel or waterway. Additionally , the aquatic resources delineation included wat ers of the state under the jurisdiction of the RWQCB, pursuant to Section 401 of the federal CWA and the Porter- Cologne Act as wetlands or drainages. T he aquatic resources delineation included an evaluation of the survey area for features meeting the defin ition of a coastal wetland under Section 30121 of the CCA.

City of Goleta defines wetlands as the most protective of USFWS, CDF W (formerly California Department of 46 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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Fish and Game), and CCC wetland definitions using indicators of a single parameter (plants, soil, or hydrology) to determine the boundary of a wetland. Lastly, City of Goleta identifies watercourses and their associated riparian areas as Environmentally Sensitive Habitat Area s (ESHAs ) and have associated protection policies.

Hydrophytic Vegetation
During the aquatic resources delineation, a “sampling point” was considered positive for hydrophytic vegetation if it passed the basic dominance test (Indicator 1), meaning that more than 50 % of the dominant species sampled were characterized as either obligate, facultative wetland, and/or facultative per the National Wetland Plant List (USACE 2020). A description of the hydrophytic vegetation categories is provided in Table 2 (Lichvar et al. 2012).

In those cases where the dominance test failed but there were positive indicators of hydric soils and/or hydrology, the vegetation parameter was re -evaluated using the prevalence index (Indicator 2), which takes into account all plant species in the community, not just dominants. All plant species observed during the surveys were identified and recorded.

Table 2. National Indicator Status Ratings and Their Rating Categories Indicator Status (abbreviation)
Percent Occurrence
in Wetlands
Obligate (OBL). Occur almost always under natural conditions in wetlands. 99 Facultative Wetland (FACW). Usually occur in wetlands but occasionally found in non- wetlands. 67–99
Facultative (FAC). Equally likely to occur in wetlands and non-wetlands. 34–66 Facultative Upland (FACU). Usually occur in non-wetlands but occasionally found in wetlands. 1–33
Upland (UPL). Occur in wetlands in another region, but occur almost always under natural conditions in non-wetlands in the region specified. 1 Source: Lichvar et al. 2012
Note: The three facultative categories are subdivided by (+) and (−) modifiers.

Soils
According to the National Technical Committee for Hydric Soils, hydric soils are “soils that are formed under conditions of saturation, flooding, or ponding long enough during the growing season to develop anaerobic conditions in the upper part” (USDA 1994). Soil pits were prepared using a shovel to determine if hydric soils were present. The presence of hydric soils was determined through consultations with the 1987 Manual, as well as Field Indicators of Hydric Soils in the United States v. 7.0 (USDA- NRCS 2010) and the USACE’s Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (Version 2.0) (USACE 2008 a). Munsell Soil Color Charts were used to determine soil chroma and value. Where feasible, soil pits were prepared to depths as deep as 16 inches. Dry soils were moistened to obtain the most accurate color.

Hydrology
Per the guidelines prescribed in the Arid West Supplement (USACE 2008 a), wetland hydrology indicators are separated into four major groups: A, B, C, and D. Group A indicators are based on direct observations of surface flow, ponding, and soil saturation/groundwater. Group B indicators consist of evidence that the site has been or is currently subjected to ponding including, but not limited to, water marks, drift deposits, and sediment deposits. 47 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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Group C indicators include signs of previous and/or current saturation including oxidized rhizospheres surrounding living roots and the presence of reduced iron or sulfur, b oth of which are indicative of extended periods of soil saturation. Group D indicators consist of “vegetation and soil features that are indicative of current rather than historic wet conditions and include a shallow aquitard and results of the FAC -Neutral test” (USACE 2008a). Each group is subdivided into primary and secondary categories based on their frequency and reliability to occur in the Arid West region. Signs of hydrology were investigated on site by intensive field review.

3.2.4 Special-Status Plant Survey
A Dudek botanist familiar with the target special- status plant species and general flora of Santa Barbara County conducted floristic surveys (spring and early summer passes) ( Table 1) in accordance with USFWS, CDFW, and CNPS guidelines (Cypher 2002; CDFW 2018 ; CNPS 2001 ). The botanist surveyed all undeveloped areas of the Project site for special-status plant speci es by walking the site for 100 % visual survey coverage, depending on topography and vegetative cover. The botanist did not survey hard scape areas or golf course fairways or greens.

The botanist meandered to ensure the entire Project site was completely surveyed. During the surveys, when a special-status plant species was observed, the location was mapped using Environmental Systems Resea rch Institute (ESRI) Field Maps application on a handheld iOS device boosted with a Trimble R1, for sub-meter accuracy.

Native and naturalized plant species encountered during the surveys were identified and recorded. Scientific and common names for plant species with a California Rare Plant Rank ( CRPR) follow the CNPS Online Inventory of Rare, Threatened, and Endangered Plants of California (CNPS 2022a). For plant species without a CRPR, scientific names follow the Jepson Interchange List of Currently Accepted Names of Native and Naturalized Plants of California (Jepson Flora Project 202 2) and common names follow the California Natural Community list (CDFW 2022a) or the U.S. Department of Agriculture (USDA) Natural Resources Conservation Service Plants Database (USDA 2022a).

3.2.5 Native Grassland Assessment
During initial vegetation mapping and identification of biological constraints, the Dudek botanist noted the presence of native grasses. As a result, during the April 2022 special-status plant species survey pass, prior to conducting an assessment of potential native grasslands, the Dudek botanist recorded the general locations of native grasses on the Project site using an ESRI ArcGIS Field Maps application on a handheld iO S device. In May 2022, the Dudek botanist conducted the native grassland assessment by walking areas with native grasses providing 100 % visual survey coverage. When native grasses were observed, pin flags were placed adjacent to native grass individuals to the outside of the polygon, ensuring the whole native grass plant was included in the polygon. Once an entire polygon was delineated with pin flags, the polygon was assigned a unique identifier and mapped using ESRI ArcGIS Field Maps application on a handheld iOS device boosted with a Trimble R1 by following the pin flag boundary. After GPSing the polygon, the botanist decided which assessment method of the t wo described below was most appropriate based on the polygon size.

Quantitative Method
For polygons of native grasses where it was feasible to establish a transect and 1-meter- square quadrats, the quantitative method was applied. Transect locations were chosen using a non-random design that allowed for the greatest coverage of the polygon and varied in length, depending on the size of the polygon being assessed. For 48 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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larger, more irregularly shaped polygons , multiple transects were established. Transect start and end points were recorded when the transect was established. Starting at the zero end of the transect tape, the botanist placed a 1- meter-square quadrat on alternating sides of the transect at 2-meter intervals. Within each 1-meter-square quadrat, the botanist estimated the percent cover of native grasses relative to plant cover and counted the number of native grass individuals. For grass species that were difficult to count, such as salt grass (Distichlis spicata), the total number of individuals was not recorded.

Qualitative Method
For polygons of native grasses where it was infeasible to establish a transect and 1-meter- square quadrats (polygons that were too small), the percent cover of native grasses relative to plant cover was visually estimated and the number of native grass individuals was recorded. For grass species that were difficult to count, such as salt grass, the total number of individuals was not recorded.

Upon completing the native grassland field survey, Dudek performed a desktop assessment of the native grass relative plant cover percent and size of each polygon to determine whether polygons met the City defined thresholds for a native grassland (see Goleta General Plan/Coastal Land Use Plan – Policy CE 5: Protection of Other Terrestrial Habitat Areas [GP/CP] ). Under the Goleta General Plan/ CLUP (City of Goleta 2006), native grasslands are areas were where native grassland species comprise 10% or more of the total relative plant cover. Additionally, the Goleta General Plan/CLUP (City of Goleta 2006 ) further defines native grasslands by size and includes that removal or disturbance to native grass patches less than 0.25 acres that are clearly isolated and not part of a significant native grassland or an integral component of a larger ecosystem may be allowed.

Dudek biologists calculated the mean native grassland species relative plant cover for the 1-meter-square quadrats for each polygon to determine the coverage of native grassland species for each polygon containing native grasses.

For polygons assessed using the qualitative method, the visually estimated relative percent cover of native grassland species was noted for each polygon. Dudek biologists then assessed the size of individual polygons containing native grasses and clusters of polygo ns containing native grasses to determine if the City defined thresholds for native grasslands was met. Areas identified as native grasslands wer e then incorporated into the vegetation map.

3.2.6 Roosting Monarch Butterfly Survey
Dudek Biologist Andrea Dransfield conducted two monarch butterfly surveys in November 2021 and January 2022 (Table 1). The survey methodology generally followed Xerces Society monitoring guidelines for statewide monarch counts (Xerces Society 2022b). Surveys were conducted in the early morning starting when temperatures were low (below 55°F) and monarchs were still clustered. Surveys were not conducted during heavy precipitation or strong winds.

Monarch butterfly surveys were conducted both at the Project site and at several reference locations ( Figure 4, Monarch Butterfly Survey Area ) to understand the Project survey results within the larger regional context of monarch activity. The Santa Barbara Shores/Ellwood Butterfly Grove, adjacent to and directly east of the Project site, served as the primary reference site (Figure 4). Ellwood contains a large complex of eucalyptus groves and is a well-documented monarch aggregation site (Meade 1999). The Dudek biologist generally surveyed Xerces Society Site Nos. 2744, 2745, 3178, 2747, 2749, 2750, and 2751 as reference locations (Figure 4 ). For each visit, the biologist walked all habitat on the Project site and adjacent reference areas, and used binoculars to examine all potentially suitable overwintering trees. Areas difficult to access were surveyed using binoculars (10×42) to record 49 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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all occurrences of monarch individuals and/or clusters. The locations and numbers of individuals were counted and recorded on an aerial map.

In addition to the surveys , Dudek conducted a brief habitat assessment of the Project site. This assessment included noting tree clusters, freshwater locations, and plants potentially providing nectar sources.

3.2.7 Protocol California Red-legged Frog Surveys
Previous surveys, in October 2001 and June 2004 , detected California red-legged frog on the Project site in the Golf Course Pond, in Bell Canyon Creek, and in an unnamed wetland feature near the bluff (which Rathbun referred to as the “clubhouse gully”) (Rathbun 2004) . Therefore, Dudek conducted an initial habitat assessment and California red-legged frog surveys in areas supporting aquatic habitat on the Project site and within 500 feet (Figure 3) from April 25, 2022, to July 27, 2022, in accordance with the Revised Guidance on Site Assessments and Field Surveys for the California Red -legged Frog (USFWS 2005 a). The protocol states that , for each suitable aquatic habitat, these surveys shall:
 Consist of up to eight surveys conducted over a minimum period of 6 weeks  Include two day surveys and four night surveys during the breeding season  Include one day and one night survey during the non-breeding season (July 1 through September 30)  Be spaced at least 7 days apart
 Have daytime surveys conducted between 1 hour after sunrise and 1 hour before sunset  Have night surveys commence no less than 1 hour after sunset  Cease if a California red-legged frog is identified at any time during the course of a survey Dudek Biologist Andrea Dransfield conducted all surveys, with assistance during night surveys from Dudek Biologists Rachel Swick, Dave Compton, and Heather Moine. Upon arrival at each aquatic habitat, biologists listened for approximately 10 minutes for calling frogs prior to disturbing the site. If calls were identified, the detection and the approximate location of the call was recorded. For both daytime and night surveys, visual encounter was the main method of survey. Dudek generally walked along the edges of suitable habitat and avoided walking within the habitat itself whenever possible.

During daytime surveys during the breeding season , Dudek biologists searched primarily for egg masses, larvae, and metamorphosing sub-adults (metamorphs). Biologists searched for both metamorphs and adults during the non-breeding season daytime.

During night surveys, biologists searched primarily for adults and metamorphosing sub-adults. Night surveys were not conducted during periods of heavy rains, fog, or other conditions that may impair the surveyor’s ability to visually detect frogs. Nigh t surveys were conducted using lights that met standards specified in USFWS (2005) and permitted detection from eye shine. Binoculars were used to facilitate detection of eye s hine. Dudek biologists recorded species and population numbers for all amphibians encountered during the surveys. 50 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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3.2.8 Nesting Raptor Surveys
Dudek conducted raptor surveys in accordance with the CCC (2004) protocol for breeding raptors . The protocol states that these surveys shall:
 Be conducted between March 1 and June 15
 Consist of at least five visits
 Be spaced at least 1 week apart
 Consist of at least 2 hours on site between dawn and 10:00 a.m.  Include three visits immediately before nightfall, if habitat for ground-nesting owls is present  Specifically involve searches for nests, foraging birds, and birds using trees for nesting, perching, or roosting No habitat for ground-nesting owls are known to be present in the region during the breeding season (CDFW 2022b; Lehman 2022), so Dudek did not conduct evening surveys. The survey covered the entire Project site and a 500- foot buffer (Figure 3). Dudek Senior Ornithologist Dave Compton conducted all surveys. Mr. Compton walked or drove a golf cart around the entire golf course and covered the Project buffer entirely on foot and by scanning from key locations. Mr. Compton typically stopped in several locations during the course of the survey for 10 to 2 0 minutes to scan for raptors and observe raptor behavior. Each of the five morning surveys took between 3.5 and

4.0 hours , during which Mr. Compton searched for and observ ed raptors, raptor nests, other raptor breeding evidence, and raptor foraging. At least 2 hours prior to 10:00 a.m., per CCC (2004) protocol, were spent observing within each survey area during each survey pass. Survey routes permitted inspection of all suitable trees for raptor nests, through either close-up examination or scanning a group of trees at a distance.

Nesting, Perching, and Roosting
Mr. Compton searched for raptor nests in mature trees within each of the survey areas (including the 500 -foot buffer), especially if a raptor in the area displayed behavior indicati ng potential breeding or nest building. Trees of interest included eucalyptus (Eucalyptus spp.), ornamental pines ( Pinus spp.), Monterey cypress (Hesperocyparis macrocarpa), other large ornamentals, and mature oaks (Quercus spp.), western sycamores (Platanus racemosa), and willows (Salix spp.). The ornithologist also examined all suitable raptor perching areas and listened for raptor calls. Locations of any raptor perches or nests were noted on an aerial image displayed in the Field Maps mobile app on an iO S device. In addition, the locations of other breeding -related behaviors or of raptor fledglings were noted on the aerial field map. Locations recorded in the field were later digitized by a GIS technician.

Although the term “roosting” may be applied to multiple behaviors, and the meaning of this term overlaps with “perching,” roosting may refer specifically to occupying a location during the nighttime hours, often referred to as “night roosting.” Some species, such as white- tailed kite ( Elanus leucurus), a state fully protected species, may roost communally at night, especially during winter. White- tailed kite roosts typically occur in dense vegetation in riparian habitat, orchards, oaks ( Quercus spp.), and other trees. Dudek noted the suitability of on- site habitat for such roosting. However, the timing of the surveys as dictated by the protocol (CCC 2004), which is during the spring and during daytime hours, does not permit direct observations of communal night roosting for most species. 51 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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Foraging
As the Project would result in very limited permanent impacts from development, surveys focused on nesting and perching rather than foraging, which for most raptors in the region occurs mostly in more open habitats. However, the presence of adjacent foraging habitat is an important component of nesting habitat. Red -tailed hawks, for example, tend to establish nests in locations where they have views over adjacent foraging habitat. In general, raptors will nest in locations where they have ready access to foraging habitat. Therefore, Dudek noted any foraging activities observed and the presence of nearby foraging habitat during surveys.

3.3 Previous Surveys
Several previous surveys were conducted for biological resources. Most surveys were conducted in the period from 2004 to 2006. California red -legged frog surveys were conducted in 2002, 2003, and 2004 (Rathbun 2004) .

Research zoologist Galen Rathbun conducted t he frog surveys. Although he conducted the surveys prior to the issuing of the USFWS survey guidance for the species (USFWS 2005a), he employed similar field methods, including daytime surveys for egg masses and tadpoles and night-time surveys for adults. Surveys focused on the golf course pond, Bell Canyon Creek (including Bell Canyon Creek lagoon), Devereux Creek, and the unnamed wetland feature (“Clubhouse Gully” per Rathbun) along the bluff near the center of the site. In addition to the surveys described above, Dr. Rathbun also conducted dip -netting for tadpoles at the golf course pond in 2002 only, and also conducted dip-netting at the unnamed wetland feature in 2004.

Tom Olson Biological Consulting conducted winter and spring bird surveys on the site in 2004 (TOBC 2004a, 2004b, 2006). These surveys were conducted on foot and through use of golf cart, and they focused on locations of particular interest to birds, such as the golf course pond, Devereux Creek, the eucaly ptus grove along the eastern boundary of the property, scattered trees around the course, and Bell Canyon Creek. Althouse and Meade Inc. (2004) conducted monarch butterfly (Danaus plexippus) surveys in 2003 and 2004, including surveys of the known aggregation site at the eastern boundary of the golf course in fall and winter and a habitat assessment of the entire course in January 2004.

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4 Results

4.1 Biological Setting
The Project site includes the Sandpiper Golf Club and an undeveloped area along Bell Canyon Creek west of the golf course, which are both part of Assessor’s Parcel Number 079- 210-059. The Project site is located near the western limit of the City of Goleta, in southern Santa Barbara County. In general, most development associated with the City of Goleta occurs to the east and northeast, and lan ds to the north and west are largely undeveloped or sparsely developed. The Project site is situation along a coastal bluff above the Pacific Ocean, which lies to the south, and adjacent to a large complex of coastal open space to the east that includes the Ellwood Mesa/Sperling Preserve and, farther east, the University of California , Santa Barbara ’s North Campus Open Space and Coal Oil Point Reserve. The Ellwood Onshore Beacon West Energy Group facility is situated between the Bell Canyon and Sandpiper Golf Club portions of the Project site , and t he Ritz -Carlton Bacara property is west of Bell C anyon.

Residential properties, the Union Pacific Railroad, and U.S. 101 are north of the golf club and Hollister Avenue .

Additional residential areas are to the east, between Ellwood Mesa and Hollister Avenue. Photos of the Project site are included in Appendix B.

4.2 Vegetation Communities and Land Covers
This section describes the vegetation communities and land covers identified on the Project site (Figure 5 , Vegetation Communities and Land Covers). As shown on Table 3, a total of 16 vegetation communities and six additional land cover types were mapped during field surveys. Of the 16 vegetation communities, 14 are described in the Manual of California Vegetation Online (MCV; CNPS 2022b) and the California Natural Community List (NCL; CDFW 2022a). Two are general vegetation community types occurring in portions of Bell Canyon Creek far from any Project impacts and were not investigated closely enough to assign to the alliance level. The six additional land cover types are not described in MCV or NCL and are characterized as beach , disturbed habitat, golf course – developed, open water, parks and ornamental plantings, and urban/developed. Vegetation communities and land cover types observed are summarized in Table 3 and described below. Despite the variety of land cover types, many of which occur in the undeveloped parts of the Project site, 61% of the entire Project site is occupied by maintained areas of the developed golf course (fairways, tees, greens, sand traps, surrounds) and or structures and hardscape associated mostly with the clubhouse and maintenance yard. P atches of less-maintained areas occur around the golf course, mostly consisting or non-native grasses and planted trees, and much of the remaining areas, and nearly all of the sensitive biological resources occurring on the Project site, occur in areas outside or at the fringes of the existing golf course: along Bell Canyon Creek, al ong the beach and bluffs, and along the eastern boundary, which is dominated by eucalyptus trees (Eucalyptus spp.).

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Table 3. Summary of Vegetation Communities and Land Cover Types Category Vegetation Community/Land Cover Type
State
Rarity
Rank ESHA
Sum
of
Acres
Woodland
Riparian
Woodland
Coast live oak woodland alliance S4 Yes 0.7
Woodland Monterey cypress - Monterey pine stands semi-natural alliance
SNA Potentially
Yes

2.9 Pepper tree or Myoporum groves semi-natural alliance SNR No 1.3 Woodland or
Riparian
Woodland
Eucalyptus (globulus, camaldulensis) provisional
semi-natural association
SNA Potentially
Yes

11.2 Woodland Total 16.1
Scrub
Coastal Bluff
Scrub
Baccharis pilularis - Toxicodendron diversilobum
association
S5? Yes 0.4
Coyote brush scrub alliance S5 Yes 2.7
Quailbush scrub alliance S4 Yes 8.3
Coastal Sage
Scrub
California brittle bush - Ashy buckwheat scrub alliance S3 Yes 0.1 Coastal sage scrub NA Yes 0.1
Riparian Scrub Arroyo willow thickets alliance S4 Yes 5.5 Scrub Total 17.0
Grass and Herb Dominated
Native
Grassland
Needle grass - Melic grass grassland alliance S3S4 Yes 0.4 Non-native
Grass
Wild oats and annual brome grasslands semi-natural
alliance
SNA No 28.2
Non-native Herb Upland mustards or star-thistle fields semi-natural alliance
SNA No 0.1
Grass and Herb Dominated Total 28.7
Bog and Marsh
Wetland Cattail marshes alliance S5 Yes 1.2
Emergent wetland NA Yes 0.2
Bog and Marsh Total 1.4
Dune
Dune Beach NA Yes 8.4
Ice plant mats semi-natural alliance SNA No 0.1
Dune Total 8.6
Other
Other Disturbed habitat NA No 0.6
Golf course – Developed NA No 115.2
Open water NA Yes 2.0
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Table 3. Summary of Vegetation Communities and Land Cover Types Category Vegetation Community/Land Cover Type
State
Rarity
Rank ESHA
Sum
of
Acres
Parks and ornamental plantings NA No 0.7
Urban/Developed NA No 3.4
Other Total 121.9
Grand Total 193.7
Notes:
? = denotes inexact numeric rank . Indicates best estimate of the rank, insufficient samples over the full expected range of the type, but existing information points to this rank.

NA = not applicable. Not identified in A Manual of California Vegetation ( CNPS 2022a) or California Natural Community List (CDFW 2022a); therefore, there is no sensitivity status.

S3 = Vulnerable, sensitive. At moderate risk of extirpation in the jurisdiction due to a fairly restricted range, relatively few populations or occurrences, recent widespread declines, threats, or other factors.

S4 = Apparently secure, not sensitive. At a fairly low risk of extirpation in the jurisdiction due to an extensive range and/or many population occurrences, but with possible cause for some concern as a result of local recent declines, threats, or other factors.

S5 = secure, not sensitive. At a very low risk of extirpation in the jurisdiction due to a very extensive range, abundant populati ons or occurrences, with little to no concern from declines or threats.

SNA = Semi-natural alliance or association. Associated with a non-native plant; therefore, there is no sensitivity status.

SNR = State not ranked.

4.2.1 Coast live Oak Woodland Alliance
The coast live oak woodland alliance (CLO) is recognized by NCL and MCV, and has a state rarity rank of S4. Although this indicates it is not sensitive, it is considered ESH A under the City of Goleta General Plan/C LUP (City of Goleta 2006). Coast live oak woodland alliance includes coast live oak as the dominant or codominant tree in the canopy.

Coast live oak woodland has a continuous to open canopy less than 30 meters (98 feet) in height with a sparse to intermittent shrub canopy, and sparse or grassy ground layer (CNPS 2022b). Species associated with the coast live oak woodland alliance include bigleaf maple ( Acer macrophyllum), blue oak ( Quercus douglasii), box -elder (Acer negundo), California bay ( Umbellularia californica), Engelmann oak ( Quercus engelmannii), California sycamore (Platanus racemosa), Southern California black walnut ( Juglans californica), valley oak ( Quercus lobata), arroyo willow (Salix lasiolepis), California black oak (Quercus kelloggii), and madrone (Arbutus menziesii) (CNPS 2022b).

Coast live oak woodland is limited on the Project site to a single stand between Bell Canyon Creek and the Beacon West Group facility (Figure 5) . A portion of the oak woodland occurs within an area the City has mapped as Riparian/Marsh/Vernal Pool ESHA (City of Goleta 2016). Other species occurring within coast live oak woodland on the Project site include California blackberry (Rubus Ursinus), poison oak (Toxicodendron diversilobum), coyote brush (Baccharis pilularis), arroyo willow (Salix lasiolepis ), western white clematis (Clematis ligusticifolia), and fennel (Foeniculum vulgare). Approximately 0.7 acres of coast live oak woodland occurs on the Project site, but all of this occurs well outside the existing golf course. See also Section 4.3.1, Sensitive Vegetation Communities (Table 3).

4.2.2 Monterey Cypress – Monterey Pine Semi-Natural Alliance Monterey cypress – Monterey pine semi-natural alliance (MC-MPS) is recognized in MCV and NCL but possesses no state rarity rank. It includes Monterey cypress (Hesperocyparis macrocarpa) and/or Monterey pine (Pinus radiata) as the dominant species in the canopy . Although both species are native to parts of California, neither Monterey 55 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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cypress nor Monterey pine is native to the Project region. However, where this community supports habitat for nesting raptors, it may be considered ESHA.

Clusters of Monterey cypress and Monterey pines occur widely in relatively small and open stands across the southern and eastern parts of the golf course, with Monterey cypress stands predominating (Figure 5) . Other species occurring within Monterey cypress – Monterey pine include non- native grasses , prickly Russian thistle (Salsola tragus), and Australian saltbush ( Atriplex semibaccata). Approximately 2.9 acres of Monterey cypress – Monterey pine semi-natural alliance occurs on the Project site (Table 3).

4.2.3 Pepper Tree or Myoporum Groves Semi-Natural Alliance Pepper tree or myoporum groves semi-natural alliance (PTMG) is recognized in both MCV and NCL and has no state rarity rank. Pepper tree or myoporum groves consist of myoporum ( Myoporum laetum) or pepper trees (Schinus spp.) as the dominant species in the tree canopy. These groves have an open to continuous tree canopy less than 18 meters (59 feet) in height. Understory shrubs are infrequent or common and the herbaceous layer is simple to diverse. Throughout Central and Southern California, the pepper trees or myoporum groves semi- natural alliance occurs in coastal canyons, washes, slopes, riparian areas, and roadsides (CNPS 2022b).

Stands of both Brazilian pepper trees (Schinus terebinthifolius) and myoporum occur on the Project site, both in limited areas, in the northwest near Hollister Avenue and near the bluffs (Figure 5). Other species occurring within this community include shortpod mustard ( Hirschfeldia incana), non-native grasses, white bladderflower ( Araujia sericifera), castorbean (Ricinus communis), and Sydney golden wattle (Acacia longifolia). The Project site supports approximately 1.3 acres of pepper tree or myoporum groves semi-natural alliance (Table 3).

4.2.4 Eucalyptus (globulus , camaldulensis) Provisional Semi-Natural Association
Eucalyptus (globulus, camaldulensis) semi-natural association (EUC) is an association of Eucalyptus - tree of heaven - black locust groves semi-natural alliance that contains eucalyptus trees (Eucalyptus spp.) as the dominant species.

It is recognized in MCV and NCL, but has no state rarity rank. However, eucalyptus may be ESHA where they support monarch butterfly roosts or nesting raptors, especially special -status species such as white -tailed kite ( Elanus leucurus). Eucalyptus have an intermittent to continuous canopy l ess than 50 meters (164 feet) in height with a sparse to intermittent shrub and herbaceous layer. Throughout California, eucalyptus were planted as trees, groves, and windbreaks and have naturalized on uplands and stream courses (CNPS 2022b). Understories of eucalyptus are usually depauperate, due to a buildup of allelopathic chemicals in the soil and buildup of debris (CNPS 2022b).

The largest eucalyptus stand on the Project site is along the eastern border, overlapping Ellwood Mesa (Figure 5).

Several isolated areas of Eucalyptus (globulus, camaldulensis) semi-natural association occur elsewhere in the eastern part of the golf course and at several locations along Hollister Avenue, including within the parking lot where the canopy of red ironbark ( Eucalyptus sideroxylon) shades the pavement . A large eucalyptus stand west of Bell Canyon Creek also overlaps the far western part of the Project site, well away from the golf course. Eucalyptus trees occurring on site include Tasmanian blue gum ( Eucalyptus globulus), river redgum ( Eucalyptus camaldulensis), lemonscented gum ( Eucalyptus citriodora ), and red ironbark. Some non- native grasses and cape ivy ( Delairea odorata) occur in the understory where vegetation is not completely suppressed by buildup of allelopathic chemicals 56 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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and leaf litter and other debris. Approximately 11.2 acres of Eucalyptus (globulus, camaldulensis) provisional semi- natural association occurs on the Project site (Table 3).

4.2.5 Baccharis pilularis – Toxicodendron
diversilobum Association
Baccharis pilularis - Toxicodendron diversilobum association (BP-TD) is an association of coyote brush scrub alliance that is recognized by MCV and NCL and has a state rarity rank of S5?. Although this rank indicates that this association is not rare, it may be considered ESHA under the General Plan/CLU P (City of Goleta 2006), as coastal bluff scrub or coastal sage scrub. This community includes a mixed shrub canopy of coyote brush ( Baccharis pilularis) and poison oak (Toxicodendron diversilobum). It includes a canopy less than 3 meters (approximately 10 feet) and variable herbaceous layer.

One patch of Baccharis pilularis – Toxicodendron diversilobum occurs on the Project site, adjacent to the Beacon West Energy Group facility, in the northwestern part of the site (Figure 5). Other species this area supports includes coast live oak and blue elderberry ( Sambucus mexicana). The Project site supports approximately 0.4 acres of Baccharis pilularis - Toxicodendron diversilobum association (Table 3).

4.2.6 Coyote Brush Scrub Alliance
Coyote brush scrub alliance (CYS) is recognized by MCV and NCL and has a state rarity rank of S5. Although this rank indicates that this alliance is not rare, it may be considered ESHA under the General Plan/CLUP (City of Goleta 2006), as coastal bluff scrub or coastal sage scrub. Coyote brush scrub includes coyote brush as the dominant or co-dominant shrub (50% relative cover in the shrub canopy) in the canopy. It has a variable shrub canopy less than 3 meters (10 feet) in height with a variable ground layer. Associated species include field mustard (Brassica rapa), California brittle bush (Encelia californica), quailbush (Atriplex lentiformis), hottentot fig (Carpobrotus edulis), and blue elderberry. Throughout California, the coyote brush scrub alliance occurs on stream sides, stabilized dunes of coastal bars, river mouths, spits along the coastline, coastal bluffs, open slopes, ridges, and terraces.

Several stands of coyote brush scrub occur on the Project site, with most near the bluffs and one along Devereux Creek in the eastern part of the site (Figure 5). Other species associated with this community on the Project site include California sagebrush ( Artemisia californica), fennel, shortpod mustard, myoporum, sea fig ( Carpobrotus chilensis), and hottentot fig (Carpobrotus edulis). The Project site supports approximately 2.7 acres of coyote brush scrub (Table 3).

4.2.7 Quailbush Scrub Alliance
Quailbush scrub alliance (QS) is recognized by MCV and NCL and has a state rarity rank of S4 . Although these designations indicate this community is not sensitive, it may be considered ESHA under the General Plan/C LUP (City of Goleta 2006), as coastal bluff scrub, when it occurs on bluffs along the immediate coast. In addition, this community may be considered ESHA where it supports special-status species. This vegetation community includes quailbush as a dominant species. Quailbush scrub has an open to intermittent scrub canopy less than five meters (16 feet) in height with a variable herbaceous layer (CNPS 2022b). 57 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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Quailbush scrub occurs on the Project site in a large, long stand that extends almost the length of the golf course, along the bluffs (Figure 5). On the Project site, this community supports several small populations of cliff malacothrix (Malacothrix saxatilis var. saxatilis), which possesses a California Rare Plant Rank (CRPR) of 4.2, and a single population of woolly seablite (Suaeda taxifolia), also a CRPR 4.2 species. Other species occurring within quailbush scrub on the Project site include coyote brush, fennel, Hottentot fig, and sea fig. The Project site supports approximately 8.3 acres of quailbush scrub (Table 3).

4.2.8 California Brittle Bush – Ashy Buckwheat Scrub Alliance California brittle bush – ashy buckwheat scrub alliance (CBB – ABS) is recognized by MCV2 and NCL and has a state rarity rank of S3, and therefore is a sensitive vegetation community. In addition, the General Plan/C LUP designates this community as ESHA, as a coastal sage scrub community. This alliance includes California brittle bush (Encelia californica) and or ashy buckwheat (Eriogonum cinereum) as dominant or co-dominant in the shrub canopy. At the Project site, thi s alliance is dominated by California brittle bush. This alliance includes California brittle bush with greater than 30% relative cover in the shrub canopy. Some species associated with this community include California sagebrush (Artemisia californica ), coyote brush ( Baccharis pilularis ), bush monkeyflower (Diplacus aurantiacus), ashy buckwheat (Eriogonum cinereum), Menzies’s golden bush ( Isocoma menziesii), deer weed (Acmispon glaber), chaparral yucca (Hesperoyucca whipplei), desert wishbone-bush ( Mirabilis laevis), coast prickly pear (Opuntia littoralis), purple sage (Salvia leucophylla), and black sage (CNPS 2022b).

One small patch of California brittle bush scrub occurs on the Project site, along the bluff in the far southwestern part of the golf cour se (Figure 5). Other species occurring within this community on the Project site include giant wild rye ( Elymus condensatus ) and New Zealand spinach ( Tetragonia tetragonoides). The Project site supports approximately 0.1 acre of this vegetation alliance (Table 3).

4.2.9 Coastal Sage Scrub
Coastal sage scrub (CSS) is a general vegetation type that most closely corresponds to Venturan coastal sage scrub in Holland (1986). It is not recognized by MCV or NCL, but encompasses several communities described in those sources. Although this community does not possess a state rarity rank, it is considered ESHA where it occurs, under the General Plan/CLUP (City of Goleta 2006). It is typically dominated by California sagebrush, but other dominant plants occur, including brittle bush ( Encelia californica ), black sage ( Salvia mellifera ), Menzies’ goldenbush (Isocoma menziesii), and coyote brush.

One stand of coastal sage scrub occurs on the Project site, west of Bell Canyon Creek, well away from any proposed Project activities (Figure 5). This stand supports a mixture of California sagebrush and coyote brush. The Project site supports approximately 0.1 acres of coastal sage scrub (Table 3).

4.2.10 Arroyo Willow Thickets Alliance
Arroyo willow thickets alliance (AWT) is an alliance recognized by MCV and NCL as a state rarity rank of S4. While these designations do not indicate this community is rare, a rroyo willow thickets are considered riparian habitat and designated as ESHA in the City of Goleta General Plan/CLUP (City of Goleta 2006). This alliance includes arroyo willows (Salix lasiolepis) with greater than 60% relative cover in the shrub canopy with poison oak ( Toxicodendron diversilobum), co yote brush ( Baccharis pilularis ), California rose (Rosa californica ), and quailbush (Atriplex 58 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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lentiformis). Throughout California, the arroyo willow thickets alliance occurs along stream banks and benches, slope seeps, and stringers along drainages (CNPS 2022b).

Arroyo willow thickets occur in two parts of the site, in two patches along Devereux Creek in the eastern part of the golf course and along Bell Canyon Creek, west of the golf course and away from proposed Project activities (Figure 5). Other species occurring within arroyo willow thickets on the Project site include California rose (Rosa californica), California blackberry, and western white clematis. The Project site supports approximately 5.5 acres of arroyo willow thickets (Table 3).

4.2.11 Needle Grass - Melic Grass Grassland Alliance
Needle grass – melic grass grassland alliance (NG – MGG) is recognized by MCV and NCL with a S3S4 state rarity rank (CDFW 2022a). Locally, it is considered an environmentally sensitive habitat area (ESHA) under the General Plan/CLUP (City of Goleta 2006) . Needle grass – melic grass grassland includes California melicgrass ( Melica californica), Torrey’s melicgrass (Melica torreyana), nodding needlegrass (Stipa cernua), foothill needlegrass (Stipa lepida), and/or purple needlegrass (Stipa pulchra) as dominant or characteristically present in the herbaceous layer with other perennial grasses and herbs. At the Project site, this alliance is dominated by purple needlegrass. Some species associated with this community include Astragalus spp., Avena spp., Bromus spp., San Diego reed grass (Calamagrostis koelerioides), Calochortus spp., Calystegia spp., wavyleaf soap plant (Chlorogalum pomeridianum), Clarkia spp., sand-aster (Corethrogyne filaginifolia), dove weed (Croton setiger), Cryptantha spp., American wild carrot ( Daucus pusillus ), bluedicks ( Dipterostemon capitatus ), blue wildrye ( Elymus glaucus ), Eriogonum spp., Erodium spp., California poppy ( Eschscholzia californica ), California f escue ( Festuca californica ), perennial rye grass ( Festuca per ennis), shortpod mustard ( Hirschfeldia incana ), yellowflower tarweed ( Holocarpha virgata), meadow barley (Hordeum brachyantherum), prairie Junegrass (Koeleria macrantha), Lasthenia spp., Plantago spp. onesided bluegrass ( Poa secunda), Sanicula spp., western blue-eyed grass ( Sisyrinchium bellum), and Trifolium spp. (CNPS 2022).

This vegetation community includes the perennial bunchgrass purple needlegrass (Stipa pulchra) as a dominant or co-dominant grass. These communities are mid -height grasslands, typically up to 2 feet tall. According to Holland (1986), native and introduced annuals grow between bunches of purple needlegrass and often exceed it in cover.

Trees or shrubs may also be prese nt within the grassland. Needle grass grassland occurs on deep soils that have a high clay content. Sites that are moist or waterlogged during winter and very dry during summer are favorable (Holland 1986). Under the Goleta General Plan/ CLUP (City of Goleta 2006) , native grasslands, including needle grass grassland, are areas were where native grassland species comprise 10% or more of the total relative plant cover. Additionally, the Goleta General Plan/ CLUP (City of Goleta 2006) further defines native grasslands by size and includes that removal or disturbance to native grass patches less than 0.25 acre that is clearly isolated and not part of a significant native grassland or an integral component of a larger ecosystem may be allowed. Needle grass – melic grass grassland alliance occurs in one location within the Project site, in a less maintained area of the southwestern part of the Project site (Figure 5). Approximately 0.4 acres of needle grass – melic grass grassland occurs within the Project site (Table 3).
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4.2.12 Wild Oats and Annual Brome Grasslands
Semi-Natural Alliance
The wild oa ts and annual brome grassland s semi-natural alliance (WOABG) is a non -native grassland community recognized by MCV and NCL that does not have a state rarity rank. It is dominated by wild oats (Avena spp.) and several brome species including ripgut brome (Bromus diandrus), soft brome (B. hordeaceus), or false brome (Brachypodium distachyon). The herbaceous layer is less than 1.2 meters (approximately 4 feet) in height, and cover is open to continuous (CNPS 2022b). This community is found between 0 and 2,200 meters (7,216 feet) amsl.

Wild oats and annual brome grasslands semi-natural alliance are the dominant vegetation community on site, and the dominant land cover outside the golf course manifestation of urban/developed (Figure 5). Stands are widely distributed around the golf course. Ripgut brome ( Bromus diandrus) and slender wild oats (Avena barbata) are dominant species within this community on site. Other species occurring here include mouse barley ( Hordeum murinum), shortpod mustard, cheeseweed mallow ( Malva parviflora), and perennial ryegrass ( Festuca perennis).

The Project site supports approximately 28.2 acres of wild oats and annual brome grasslands semi-natural alliance (Table 3).

4.2.13 Upland Mustards or Star-Thistle Fields
Semi-Natural Alliance
Upland mustards is an association of upland mustards or star-thistle fields semi-natural alliance (UM) is a natural community recognized by MCV and NCL but that does not have a state rarity rank. Within this community, black mustard (Brassica nigra), shortpod mustard, or other mustards occur at greater than 80% relative cover in the herbaceous layer. Emergent trees and shrubs may be present at low levels.

A single patch of upland mustards or star-thistle fields semi-natural alliance occurs on the Project site near Hollister Avenue, west of the clubhouse (Figure 5). Other species occurring with upland mustards on the Project site include non-native grasses, cast orbean, fennel, Maltese star -thistle (Centaurea melitensis), and prickly lettuce ( Lactuca serriola). The Project site supports 0.1 acre of this vegetation community (Table 3).

4.2.14 Cattail Marshes Alliance
Cattail marshes alliance (CTM) is recognized by MCV and NCL with a state rarity rank of S5 . Although this rank indicates this community is not sensitive, as a wetland community, cattail marshes is considered ESHA under the General Plan/ CLUP (City of Goleta 2006) . Cattail marshes is dominated by broadleaf cattail ( Typha latifolia ), southern cattail (Typha domingensis), or narrowleaf cattail (Typha angustifolia). Throughout California, the cattail marsh alliance occurs in brackish or semi -permanently flooded freshwater marshes. Cattail marshes have a continuous or intermittent herbaceous canopy of less than 1.5 meters (4.9 feet) in height. This alliance occurs from sea level to 350 meters (1,148 feet) amsl (CNPS 2022b).

Cattail marsh on the Project site is limited to Bell Canyon Creek, away from existing development associated with the golf course, and a wetland feature near the bluffs (Figure 5). This community consists almost entirely of southern cattail on the Project site. The City has mapped cattail marshes along Bell Canyon Creek as ESHA (City of Goleta 60 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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2016). The Project site supports 1.2 acres of cattail marshes (Table 3), all of which occur well outside the area of proposed Project activities.

4.2.15 Emergent Wetland
Emergent wetland (EM) is a general vegetation type that is not described in MCV or NCL. It is considered “emergent” because it consists of erect, rooted, herbaceous plants growing in water or on a substrate. It is dominated by perennial plants that are present for most of the growing season in most years. As a wetland community, it is considered ESHA under the General Plan/CLUP (City of Goleta 2006).

Emergent wetland on the Project site is limited to Bell Canyon Creek, away from existing development associated with the golf course (Figure 5). The City mapped this stand of emergent vegetation as ESHA ( City of Goleta 2016).

This stand is dominated by California bulrush (Schoenoplectus californicus) and also supports southern cattail and saltmarsh bulrush ( Bolboschoenus maritimus ). The Project site supports approximately 0.2 acres of emergent wetland (Table 3), all of which is well outside the area of proposed Project activities.

4.2.16 Beach
Beach (B) is an unvegetated land cover that is not included in MCV or NCL. Beaches are characterized as narrow, sandy, and stony areas along the ocean that are partly or completely covered by water during high tide and exposed during low tide. Beach and shoreline resources are considered ESHA under the General Plan/CLUP.

The beach area occurs below the bluff on the south edge of the Project site (Figure 5). For the most part, this land cover supports no plant species. The Project site supports 8.4 acres of beaches (Table 3).

4.2.17 Ice Plant Mats Semi-Natural Alliance
Ice plant mats semi-natural alliance (IPM) is recognized by MCV and NCL, but that does not have a state rarity rank.

Ice plant mats contains hottentot fig (Carpobrotus edulis), sea fig (Carpobrotus chilensis), or other ice plant taxa as the dominant or co-dominant species in the herbaceous layer. These non-native species invade coastal bluff scrub, dune mat, dune scrub, and coastal prairies and compete with native plants ( CNPS 2022b). Ice plant mats areas have an intermittent to continuous canopy within the herbaceous layer less than 0.5 meters (1.6 feet) in height.

On the Project site, ice plant mats semi -natural alliance occurs in two small patches in the southwest, along the bluffs (Figure 5) . Both sea fig and Hottentot fig occur within ice plant mats on the Project site. Other species occurring here include non-native grasses and New Zealand spinach. The Project site supports 0.1 acres of ice plant mats semi-natural alliance (Table 3).

4.2.18 Disturbed Habitat
Disturbed habitat (DH) is an anthropogenic land cover that is not described in NCL or MCV2. Disturbed areas include natural, impervious ground with scattered non- native plants specie s, and they display evidence of physical disturbance, such as from active maintenance or occasional ground disturbance. Areas mapped as this land cover on the Project site are bare and support little weedy herbaceous vegetation. Disturbed habitat on the Project site is limited 61 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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to the access road leading from the Beacon West Energy Group facility and below the bluffs to the oil piers (Figure 5).

This area is nearly entirely unvegetated. The Project site supports 0.6 acre of disturbed habitat (Table 3).

4.2.19 Golf Course – Developed
Golf course – developed (Golf Course) is a land cover that is not recognized by MCV or NCL. Golf course areas include an abundance of open space largely made up of turf grass and row tree s. Although these areas are considered to be developed, wildlife may still utilize the trees as nesting and cover habitat and the turf grass as foraging and movement habitat. These areas are generally irrigated and highly maintained. Golf course –developed occurs throughout the golf course and account for the largest portion of the Project site (Figure 5). The Project site supports approximately 115.2 acres of the golf course – urban developed land cover (Table 3).

4.2.20 Open Water
Open water (OW) is not recognized in MCV or NCL. It consists of standing water with no emergent vegetation and can occur in marine, estuarine, riverine, lacustrine, and palustrine systems. On the Project site, open water occurs at the golf course pond and within Bell Canyon Creek (Figure 5). The Project site supports 2.0 acres of open water (Table 3).

4.2.21 Parks and Ornamental Plantings
Parks and o rnamental plantings (ORN) are not described MCV2 or NCL because this is not a naturally occurring community in California. Areas mapped as ornamental include planted areas where ornamental landscaping has been installed. Ornamental plantings on the Project site are limited to several small areas near the clubhouse and around and near the maintenance yard, in the northeast part of the site (Figure 5). The Project site supports 0.7 acre of parks and ornamental plantings (Table 3).

4.2.22 Urban/Developed
Urban/developed areas (DEV) are not described in MCV2 or NCL because they are not naturally occurring communities in California. Areas designated as developed have been altered from their natural states for human uses and provide no habitat and foraging potential for wildlife due to the lack of cover by native vegetation. On the Project site, the urban/developed land cover is limited to the clubhouse and parking lot (Figure 5) . There are approximately 3.3 acres of urban/developed lands (Table 3).

4.3 General Wildlife
During surveys since 2002, 116 species have been detected on the Project site. Common species known and expected to occur are described below. All wildlife species observed during surveys, including 2021-2022 surveys and those conducted previously, are included in Appendix C, Wildlife Compendium. 62 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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4.3.1 Invertebrates
The Project site aquatic habitats, wetland vegetation, riparian vegetation, coastal sage scrub, coastal bluff scrub, and maintained irrigated vegetation that likely support a variety of invertebrates. Only two invertebrate species have been confirmed to occur during surveys, both of which were butterfly species: monarch butterfly (discussed in Section 4.3.3) and cabbage white (Pieris rapae).

4.3.2 Fish
No fish surveys were conducted in 2022, and available data from past fish surveys was limited to results of surveys of Bell Canyon Creek for the federally endangered tidewater goby (Eucyclogobius newberryi). The only other species confirmed during surveys was mosquitofish ( Gambusia affinis), in the golf course pond, where it presumably has been introduced for vector control purposes . Bell Canyon Creek, including the la goon, likely support a variety of species, including those occurring in fresh and brackish water.

4.3.3 Amphibians
The life cycles of amphibians typically have aquatic and upland phases. Despite the presence of suitable aquatic habitats for amphibians, only three species, from two families, have been observed on the Project site. In addition to the federally listed threatened California red-legged frog (Rana draytonii), discussed in Section 4.3.3, two common species of frog have been detected: the native Baja California treefrog (Pseudacris hypochondriaca) and the non -native American bullfrog (Lithobates catesbeianus). Other common species that potentially occur, based on the habitat present, are western toad (Anaxyrus boreas) and black-bellied slender salamander (Batrachoseps nigriventris).

4.3.4 Reptiles
Reptiles occur in a variety of habitats. Many species shelter in small burrows, which they use as refuge from extreme temperatures and to avoid predators. Biologists observed one common reptile species, western fence lizard (Sceloporus occidentalis), on the Project site during surveys. Other common reptiles likely to occur on site based on the habitat present include but are not limited southern alligator lizard (Elgaria multicarinata) and gopher snake (Pituophis catenifer).

4.3.5 Birds
A total of 102 bird species representing 38 families were observed on site, or flying over the site. Some species are those that are tolerant of human presence, while many are species attracted to the irrigated plantings and to the permanent water in the golf course pond, where several species winter or stop in during migration. Breeding species include those that may use some of the ornamental trees and the narrow, wooded patches along the golf course fringes, the taller and denser stands of herbaceous habitats in the less well-maintained parts of the golf course, and the limited riparian area along a portion of Devereux Creek. Several species of blackbirds, such as Brewer’s blackbird (Euphagus cyanocephalus) and brown-headed cowbird (Molothrus ater), are attracted to irrigated parts of the golf course, where they forage for insects. Wintering species such as American pipit (Anthus rubescens) use these areas as well, and swallow species such as cliff swallow (Petrochelidon pyrrhonota) and northern rough-winged swallow (Stelgidopteryx serripennis) forage over these areas in spring and summer. Water birds that use the pond for resting and foraging during winter and migration include American coot (Fulica americana), pied-billed grebe (Podilymbus podiceps), and several species of waterfowl. 63 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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Heron and egret species that may forage along the edges of the pond at any season include great blue heron (Ardea herodias), great egret (Ardea alba), and black-crowned night-heron (Nycticorax nycticorax). Common songbirds that may breed on the property include song sparrow (Melospiza melodia), black phoebe (Sayornis nigricans), Cassin’s kingbird (Tyrannus vociferans), house finch ( Haemorhous mexicanus), lesser goldfinch ( Spinus psaltria), California towhee (Melozone crissalis), and hooded oriole (Icterus cucullatus). Grassland species occurring on the site include western meadowlark (Sternula neglecta; winter) and lark sparrow (Chondestes grammacus) Common Raptors
Raptor Habitat: Raptor habitat is influenced by a number of factors, and habitat varies by raptor species. Those species potentially nesting in the Sandpiper Golf Club vicinity include red -tailed hawk, red -shouldered hawk, white-tailed kite (see Section 4.3.3), Cooper’s hawk (See Section 4.3.3), American kestrel (Falco sparverius), great horned owl (Bubo virginianus), and barn owl ( Tyto alba). Other species have the potential to perch and hunt over portions of campus. Some of these are species that winter in the area, such as northern harrier (Circus hudsonius), or that may forage over campus at any time of year, such as peregrine falcon, but are very unlikely in the immediate vicinity of the golf club. Species such as bald eagle a nd Osprey (Pandion haliaetus) may be attracted on occasion to fish resources associated with the pond, but have little attraction to other parts of the Project site and immediate vicinity. In addition, these latter species are not known to nest along the coast of southern Santa Barbara County.

Therefore, the assessment of trees as raptor habitat focused on the nesting potential for the above known nesting species, and the potential for perching and roosting by a greater variety of species. Additional factors that influence raptor habitat are the level of human disturbance, such as from pedestrian and vehicular traffic; the ability of a tree’s branches to support the nests of larger species such as red-tailed hawk; the visual cover provided by a tree’s branches and foliage (especially important for a species such as white-tailed kite); whether foraging habitat occurs adjacent to the trees; and whether the trees provide prominent perches with views of foraging habitat.

The Project site and parts of the 500-foot buffer are characterized by suitable nesting habitat in larger trees at the eastern and western Project boundaries, in some of the larger trees on the golf course, and in various large trees nearby, especially eucalyptus trees near Bell Canyon Creek, in the Ellwood Mesa area east of the site, and between U.S. 101 and Hollister Avenue within the 500 -foot buffer. Foraging habitat occurs in open spaces throughout, although foraging habitat on the golf course, is somewhat limited due to the prevalence of highly maintained greens, tees, fairways, and surrounds.

Two common raptor species common in the region were detected during raptor surveys in 2022: red-shouldered hawk ( Buteo lineatus ) and red -tailed hawk ( Buteo jamaicensis ) (Figure 6 , Raptor Survey Results; Table 4) .

Occurrence and potential occurrence of Cooper’s hawk, which was also detected during 2022 surveys, and white- tailed kite are discussed in Section 4.3.3. In addition, one owl species, great horned owl ( Bubo virginianus), was detected during previous surveys. Observations from 2022 are summarized in Table 1 , and observations of all raptor species detected during surveys are described below.

Cooper’s hawk. This species was detected on one occasion during surveys in 2022 (Figure 6; Table 4), It was not detected during earlier surveys. The lone individual detected during 2022 raptor surveys was observed perching in a eucalyptus tree on the north side of Hollister Avenue, within the survey buffer, on March 22, 2022. The species was not detected during bird surveys in 2004 and 2006, but the eBird database includes several reports of the species in winter (CLO 2022). Suitable nesting habitat occurs widely in the area, including in the eucalyptus groves at the eastern edge of the golf course and at the western edge of the golf course . Although nesting has not been 64 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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recorded during surveys of the Project site, data included on the Goleta General Plan/CLUP species map (City of Goleta 2016) includes a nesting location immediately east of the Project site (Figure 6).

Red-shouldered Hawk. This species was detected on four of five surveys in 2022 (Table 4), and it was also detected during both winter and spring surveys in 2004 (TOBC 2004a, 2004b). A pair was detected copulating over a suitable nest structure in a eucalyptus tree on March 22, 2022 (Figure 6), and an independent observer reported copulation at the same location seven days later (SBAS 2022). However, no additional evidence of nesting was detected during surveys. Adults were observed in the vicinity of the nest structure on the t hree subsequent surveys, on April 13 , April 27, and May 18, 2022, but the species was never detected in the nest, and no other suitable nest was found.

The species has been detected nesting in the vicinity , including as recently as 2005 (City of Goleta 2016 ; TOBC 2006; SBAS 2022), but it has not been detected nesting on the site. It has potential to nest at the location where the unused nest was observed in 2022, as well as at various other locations on the Project site, especially in trees at the eastern, western, and northern fringes of the site.

Red-tailed Hawk. This species nested on the Project site in 2021 near the eastern boundary, and during 2022 focused raptor surveys (Figure 6; Table 4). During focused surveys in 2022, adults were observed perching and flying in the nest vicinity during each survey. Two nestlings were observed in the nest on April 13, 2022, and a fledgling was in the area, accompanies by an adult, on June 10, 2022. An adult and fledgling were recorded on the site during bird surveys in 2004, south of the clubhouse, but no nest was found (TOBS 2004b). This species has established territories around Goleta, and it was also known to have nested north of the Project site, in a development just south of U.S. 101, in 2020 and 2021 (SBAS 2022). In addition, regular sightings of individuals in the western part of the golf course indicate the potential presence of a third nesting territory west of the golf course. A red-tailed hawk perched in eucalyptus west of Bell Canyon Creek on May 18, 2022, may have been one of these individuals. During surveys in 2022, perching and flying behaviors were most associated with the 2022 nest vicinity and the western edge of the golf course. Multiple individuals were detected during all surveys. This species has the potential to forage in most parts of the golf course, especially away from the well maintained fairways, greens, and tees Great Horned Owl. Although this species was not detected during raptor surveys in 2022, a recent fledgling was detected incidentally on the ground along Bell Canyon Creek in April 2022 during reconnaissance for California red- legged frog surveys. Given the condition of fledgling, which was barely able to fly, it is likely it hatched in a nest very nearby, possible within the site boundaries, although likely not in a tree on the golf course. The species was detected nesting in March 200 6 immediately east of the Project site, in the large eucalyptus grove that occurs along the eastern boundary on both sides of the property line. A fledgling detected in May 2006 indicated the nesting h ad been successful.
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Table 4. Raptor Survey Results
Survey
No. Date / Time Site Conditions Biologists Observations 1 1 March 22, 2022
0735–1121
Sunny with light (1-6 mph)
winds. Temperatures
ranged from 61ºF to 83ºF.

Dave Compton RSHA – 2 total: pair copulating above suitable nest in Tasmanian blue gum at N edge of golf course, near
maintenance yard and abandoned gas station. P in trees
nearby and F around area.

RTHA – 2 total: 1 adult P on Monterey cypress trees near center of golf course and near ocean. 1 adult P in Monterey cypress and Eucalyptus sp. and F in western part of golf course.

COHA – 1 adult P in eucalyptus tree in survey buffer N of the club house and Hollister Ave.
2 April 13, 2022
0620–1018
Clear with light (1-4 mph)
winds. Temperatures
ranged from 51ºF to 61ºF.

Dave Compton RTHA – 3 total adults (2 nestlings): 1 adult on nest in Eucalyptus sp. just east of Devereux Creek, tending 2 downy nestlings; 1 P in Monterey cypress trees near the bluffs in the center of the golf course; 1 F between P in Monterey cypress and Tasmanian blue gum (Eucalyptus globulus) at the
western edge of the golf course.

RSHA – 1 calling near previously noted nest site near Hollister Ave., but no activity detected visually around nest during visit. 3 April 27, 2022
0737–1121
Sunny (0-10% cloud cover),
with light to moderate (3-8
mph) winds. Temperatures
ranged from 55ºF to 64ºF.

Dave Compton RTHA – 4 total adults, 2 nestlings: Pair nr known nest in E part of golf course, ranging around nest vicinity; 2 nestlings with juvenile feathers coming in. 1 ad P at W edge of golf course, the F to Bell Canyon Creek area. 1 ad soaring N of Hollister.

RSHA – 2 total adults: both adults near previously identified nest nr N edge of golf course, but no activity in nest. 1 RSHA P on wire W of nest; later both adults heard calling.
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Table 4. Raptor Survey Results
Survey
No. Date / Time Site Conditions Biologists Observations 1 4 May 18, 2022
0711–1111
Sunny, becoming partly
cloudy with light (1-5 mph)
winds. Temperatures
ranged from 55ºF to 60ºF.

Dave Compton RTHA – 4 total adults: Pair nr known nest in E part of golf course, F, P, and calling in vicinity and to SW. No nestlings in nest, and no fledglings detected. Second pair presumed at W edge of golf course and across Bell Canyon Creek. One adult P around east side of the Beacon West Energy Group facility, while second P more than one hour in eucalyptus on W side of Bell Canyon Creek.

RSHA – 1 adult minimum: F nr nest at N edge of golf course.

Calling later heard in vicinity, but only one confirmed. No activity in nest. Close inspection of nest area revealed no unknown nests
5 June 10, 2022
0738–1104
Overcast with light (0-5
mph) winds. Temperatures
ranged from 61ºF to 63ºF.

Dave Compton RTHA – 2 minimum. Minimum 1 adult P in eucalyptus and Monterey cypress in southeastern part of golf course, near nest. Minimum 1 fledgling P with ad and calling in Monterey cypress west of nest, and P and F near bluff. RTHA nest and RSHA nest both empty.

Note:
1 F = flew, flying
P = perch, perching
COHA = Cooper’s hawk
RSHA = red-shouldered hawk
RTHA = red-tailed hawk

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4.3.6 Mammals
Golf course maintenance likely limits the presence of some mammal species, especially burrowing small mammals, although some species survive in the less maintained areas on the Project site. Some medium-size mammals also persist in the area, likely favoring habitats along the fringes, but also moving around the golf course at nighttime to forage, such as for insects and rodents. California ground -squirrels (Otospermophilus beecheyi) are encountered regularly during the day. Other common species observed during the nighttime include striped skunk ( Mephitis mephitis), northern raccoon ( Procyon lotor), red fox (Vulpes vulpes ), Virginia opossum (Didelphis virginiana ), and long-tailed weasel ( Neogale frenata ). Although bats have been observed foraging over the Project site in the evening, the species observed have not been identified. Wooded areas in the immediate vicinity of the golf course may provide roosting habitat for some bats, alth ough habitat on the golf course itself is limited . The historic gas station potentially supports roosting bats, and eucalyptus woodland around the fringes of the site may as well. The golf course is likelier much more important as foraging habitat, due to the presence of insects attracted by water associated with the pond and because of irrigation of the site.

4.4 Special-Status/Regulated Resources
The following resources are discussed in this section: (1) vegetation communities that are unique, of relative ly limited distribution, or of particular value to wildlife; (2) plant and animal species present or potentially present on the Project site that are given special recognition by federal, state, or local resource agencies and environmental organizations owing to declining, limited, or threatened populations, that are the result, in most cases, of habitat reduction; (4) aquatic resources under the jurisdiction of state, federal, and local agencies; and (3) habitat areas that may support wildlife movement or wildlife nurseries.

4.4.1 Sensitive Vegetation Communities
Sensitive vegetation communities include wetlands and riparian communities, as well as those communities that CDFW has identified as a high priority for inventory due to rarity or threat in California. In addition, within the City of Goleta, several communities are identified as sensitive under the Conservation Element of the General Plan/CLUP (City of Goleta 2006) . The latter includes oak woodlands, coastal bluff scrub, any coastal sage scrub community, and any native grasslands meeting the criteria describe in Policy CE 5.2 (Appendix D, Native Grassland Data Forms), which applies to both the coastal and non-coastal portion of the plan area. Therefore, for the purposes of this report, sensitive vegetation communities or habitats are:
 Alliances on CDFW’s California Natural Communities List with a state rarity rank of S1, S2, or S3 (CDFW 2022a);  Riparian and wetland communities; or
 Communities considered sensitive in City (2006).

Other communities may be protected (identified as ESHA) if they provide habitat for protected species, such as roosting monarch butterflies or nesting raptors , but are not themselves considered sensitive. Ten vegetation communities considered sensitive either because of their state rarity rank because they are considered ESHA under the General Plan/CLUP (City of Goleta 2006), occur on the Project site:
 Coast live oak woodland alliance has a state rarity rank of S4. Although this rank indicates this community is not sensitive, oak woodlands are considered ESHA under the General Plan/CLUP (City of Goleta 2006). Because of 68 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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this, any area designated as coast live oak woodland is considered sensitive. This community occurs along Bell Canyon Creek, well west of the golf course and west of the Beacon West Energy Group facility.  Arroyo willow thickets alliance has a state rarity rank of S4. Although this rank indicates this community is not sensitive, as a riparian community, arroyo willow thickets is considered ESHA under the General Plan/CLUP (City of Goleta 200 6). Because of this, any area designated as arroyo willow thickets is considered sensitive. This community occurs along Bell Canyon Creek (well west of the golf course) and along Devereux Creek.
 Baccharis pilularis – Toxicodendron diversilobum association has a state rarity rank of S5. Although this rank indicates this community is not sensitive, as a coastal sage scrub community, Baccharis pilularis – Toxicodendron diversilobum association is considered ESHA under the General Plan/CLUP (City of Goleta 2006). Because of this, any area designated as Baccharis pilularis – Toxicodendron diversilobum association is considered sensitive. This community occurs in a small area near Hollister Avenue, near the northwestern part of the golf course.
 Coyote brush scrub alliance has a state rarity rank of S5. Although this rank indicates this community is not sensitive, as a coastal sage scrub community, coyote brush scrub is considered ESHA u nder the General Plan/CLUP (City of Goleta 2006). Because of this, any area designated as coyote brush scrub is considered sensitive. This community occurs near the bluff in the southwestern part of the Project site and along Devereux Creek near the eastern boundary.
 Quailbush scrub alliance has a state rarity rank of S4. Although this rank indicates this community is not sensitive, as a coastal bluff scrub community, quailbush scrub is considered ESHA under the General Plan/CLUP (City of Goleta 2006) . Because of this, any area designated as quailbush scrub is considered sensitive. This community occurs extensively along the bluff, just south of the golf course.  Coastal sage scrub is a general vegetation type that is not described in MCV or NCL, therefore it does not possess a state rarity rank. However, coastal sage scrub is considered ESHA under the General Plan/CLUP (City of Goleta 2006). Because of this, any area designated as emergent wetland is considered sensitive.

On the Project site, areas mapped as coastal sage scrub occur only west of Bell Canyon Creek lagoon, well away from the golf course.
 California brittle bush scrub alliance has a state rarity rank of S3 and therefore considered sensitive. As a type of coastal sage scrub vegetation, is also considered ESHA under the General Plan/ CLUP. One small patch of this community occurs along the bluff, adjacent to the southwestern part of the golf course.  Cattail marshes alliance has a state rarity rank of S5. Although this rank indicates this community is not sensitive, as a wetland community, cattail marshes is considered ESHA under the General Plan/CLUP (City of Goleta 2006) . Because of this, any area designated as cattail marshes is considered sensitive. This community occurs in Bell Canyon Creek (west of the golf course) and in a wetland along the bluff.  Emergent wetland is a general vegetation type that is not described in MCV or NCL, therefore it does not possess a state rarity rank. However, as a wetland community, cattail marshes is consid ered ESHA under the General Plan/CLUP (City of Goleta 2006). Because of this, any area designated as emergent wetland is considered sensitive. On the Project site, this community occurs within Bell Canyon Creek, west of the golf course.
 Needle grass grassland alliance has a state rarity rank of S4. Although this rank indicates this community is not sensitive, as a wetland community, a s a native grassland community, this community is considered sensitive under the General Plan/CLUP (City of Goleta 2006). A patch of approximately 0.25 acres occurs in the southeastern portion of the Project site (Figures 7A and 7B, Native Grassland Assessment). Other small 69 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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patches of native grasses occur in the v icinity that do not meet all the criteria to qualify as needle grass grassland, but occur in other, non-native grass communities.

In addition to the above, the General Plan/CLUP (City of Goleta 2006) provides protection for the beach land cover as “beach and shoreline habitat” and for open water areas.

4.4.1.1 Native Grassland Assessment
Botanical surveys resulted in the identification of five species of native grasses: meadow barley ( Hordeum brachyantherum), purple needlegrass ( Stipa pulchra) , salt grass, creeping ryegrass ( Elymus triticoides), and smallflower melicgrass (Melica imperfecta). Within the native grassland assessment polygons, native plant species clustered tarweed (Deinandra fasciculata), western vervain (Verbena lasiostachys), and western blue- eyed grass (Sisyrinchium bellum), often associated with native grasslands, were observed but not within the one-meter square quadrats. During the native grassland assessment field surveys, a total of 32 polygons containing native grasses were recorded ranging in size from 4 square feet (NG-7) to 9,663 square feet (0.22 acres; NG-20) (Figures 7A and 7B). These polygons containing native grass species generally occur in clusters in the less maintained parts of the golf course, outside the fairways, greens, tees, and surrounds. In general, these polygons containing native grass species occur within areas mapped as the wild oats and annual brome grasslands vegetation community. Table 5 includes the polygons containing native grasses, the associated polygon ID, the assessment method (qualitative or quantitative), the native grassland species observed, and native grassland percent cover.

Table 5. Native Grassland Results by Polygon
Polygon ID
Qualitative
or
Quantitative
Area (square
feet /acres ) Native Grass land Species
Native
Grassland
Percent Cover a
NG-1 Qualitative 55/0.00b Hordeum brachyantherum
Stipa pulchra
5 NG-2 Qualitative 92/0.00b Hordeum brachyantherum
Stipa pulchra
10 NG-3 Qualitative 86/0.00b Hordeum brachyantherum
Stipa pulchra
5 NG-4 Qualitative 108/0.00b Hordeum brachyantherum
Stipa pulchra
35 NG-5 Qualitative 21/0.00b Stipa pulchra 25
NG-6 Qualitative 461/0.01 Hordeum brachyantherum
Stipa pulchra
30 NG-7 Qualitative 4/0.00b Stipa pulchra 10
NG-8 Quantitative 346/0.01 Hordeum brachyantherum
Stipa pulchra
15 NG-9 Quantitative 597/0.01 Hordeum brachyantherum
Stipa pulchra
23 NG-10 Quantitative 172/0.00b Stipa pulchra 25
NG-11 Quantitative 345/0.01 Hordeum brachyantherum
Stipa pulchra
14 NG-12 Quantitative 647/0.01 Distichlis spicata 40
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Table 5. Native Grassland Results by Polygon
Polygon ID
Qualitative
or
Quantitative
Area (square
feet /acres ) Native Grass land Species
Native
Grassland
Percent Cover a
NG-13 Quantitative 6,182/0.14 Stipa pulchra 15
NG-14 Quantitative 5,042/0.12 Stipa pulchra 24
NG-15 Quantitative 756/0.02 Stipa pulchra 6
NG-16 Quantitative 1,081/0.02 Stipa pulchra 9
NG-17 Quantitative 1,126/0.03 Hordeum brachyantherum
Stipa pulchra
9 NG-18 Qualitative 53/0.00b Hordeum brachyantherum 10
NG-19 Qualitative 481/0.01 Elymus triticoides 10
NG-20 Quantitative 9,663/0.22 Melica imperfecta
Stipa pulchra
12 NG-21 Quantitative 649/0.01 Stipa pulchra 8
NG-22 Quantitative 2,149/0.05 Stipa pulchra 3
NG-23 Qualitative 194/0.00b Hordeum brachyantherum 5
NG-24 Qualitative 113/0.00b Hordeum brachyantherum 2
NG-25 Qualitative 125/0.00b Hordeum brachyantherum
Stipa pulchra
10 NG-26 Qualitative 27/0.00b Hordeum brachyantherum 10 NG-27 Quantitative 2,692/0.06 Hordeum brachyantherum 10 NG-28 Quantitative 6,196/0.14 Hordeum brachyantherum
Melica imperfecta
Stipa pulchra
8 NG-29 Quantitative 3,529/0.08 Hordeum brachyantherum 14 NG-30 Qualitative 27/0.00b Hordeum brachyantherum 5
NG-31 Qualitative 299/0.01 Hordeum brachyantherum
Stipa pulchra
5 NG-32 Qualitative 740/0.02 Hordeum brachyantherum
Melica imperfecta
Stipa pulchra
15 Notes:
a Native grassland species percent cover of the total relative plant cover. b Less than 0.00 acres when rounded.

Of the 32 polygons with native grasses, a total of 20 met or exceeded the native grassland Conservation Element of the General Plan/CLUP (City of Goleta 2006) threshold of supporting at least 10 % or more of native grassland species of the total relative plant cover; however , each polygon was less than 0.25 acre in size (Table 5). Since native grasslands dominated by perennial bunch grasses tend to be patchy, groupings of polygons were assessed based on the percent cover, size of each polygon, and proximity of polygons resulting in one native grassland area containing NG -20, NG -21, and NG- 22 (Figure 7B). These polygons were combined to delineate the whole area needle grass grassland and incorporated into the vegetation map (Figure 5). 71 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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4.4.2 Special-Status Plant Species
Focused special-status plant species surveys were conducted in May and July 2022 (Figure 8, Rare Plant Results; Table 1). Surveys resulted in identification of 134 species of plants on the P roject site. Appendix E, Plant Compendium, lists all species obser ved during surveys. The literature review identified 28 special-status species that occur in the region. Species are considered to have low to no potential to occur prima rily due to the lack of suitable habitat and/or lack of observations within the Project site during the focused surveys. The se species are not further analyzed in this Report because no direct, indirect, or cumulative impacts are expected. The following sections address special-status species observed on the Project site during surveys.

Monterey cypress and Monterey pines were observed throughout the southern and eastern parts of the golf course in relatively small and open stands. Monterey cypress trees are not naturally occurring within the Goleta area and instead are documented as native in occurrences located in the Monterey, California area (CNPS 202 2a); therefore, Monterey cypress trees are not considered special -status plants species at the Project site.

Additionally, Monterey pine trees are not naturally occurring within the Goleta area ; only three native stands occur in California, at Ano Nuevo, Cambria, and the Monterey Peninsula (CNPS 2022a). T herefore, Monterey pine trees are not considered special -status plant species at the Project site. However , Monterey cypress trees and Monterey pine trees could be considered ESHA if used by nesting raptors.

4.4.2.1 Cliff Malacothrix
Cliff malacothrix (Malacothrix saxatilis var. saxatilis) is a perennial herb with a CRPR of 4.2 that occurs in coastal bluff scrub and coastal scrub at approximately 3 to 65 meters (10 to 220 feet) in elevation. It occurs along the coast from Orange County north to Santa Barbara County, and inland in Kern and San Bernardino Counties.

During surveys in 2022, cliff desert malacothrix was documented in clusters distributed along the bluffs the length of the Project site (Figure 8).

4.4.2.2 Red Sand Verbena
Red sand verbena (Abronia maritima) is a perennial herb with a CRPR of 4.2 species that occurs in coastal dunes and coastal strand habitats at approximately 0 to 100 meters (0 to 330 feet) elevation. It occurs along the California coast from San Luis Obispo County southward, and on the Channel Islands. Within the Project site, it occurs along the upper beach just west of the Bell Canyon Creek lagoon, at the far western portion of the site (Figure 8).

4.4.2.3 Santa Barbara Honeysuckle
Santa Barbara honeysuckle ( Lonicera subspicata var. subspicata) is a perennial evergreen shrub with a CRPR of 1B.2 species that occur s in chaparral, cismontane woodland, and coastal scrub habitats at approximately 10 to 1,000 meters (35 to 3,280 feet) elevation. Within the Project site, it occurs in the eastern part of the Project site, within the on-site monarch butterfly grove and in coyote brush scrub associated with Devereux Creek (Figure 8).

4.4.2.4 Southern California Black Walnut
Southern California black walnut (Juglans californica) is a perennial deciduous tree with a CRPR of 4.2 that occurs in chaparral, cismontane woodland, coastal scrub, and riparian woodland at approximately 50 to 90 meters (165 72 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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to 2,966 feet) elevation. Within the Project site, six of theses tree occur just west of the golf course, at the southern end of the Beacon West Energy Group facility (Figure 8).

4.4.2.5 Woolly Seablite
Woolly seablite (Suaeda taxifolia) is a perennial evergreen shrub species with a CRPR of 4.2 that occurs in coastal bluff scrub, coastal dune, and marsh and swamp habitats at approximately 0 to 50 meters (0 to 165 feet) elevation.

It occurs along the coast from Orange County north to San Luis Obispo County, as well as on the Channel Islands.

On the Project site, this species occurs along the bluff in a patch by approximately 6 meters (20 feet) wide by 40 meters (130 feet) long (Figure 8).

4.4.3 Special-Status Wildlife Species
The literature review identified 35 special-status wildlife species with potential to o ccur in the Project region (Appendix F). Of these, 13 either were identified on the Project site during 2021 -2022 surveys, were identified as occurring on site during previous surveys or through the literature review or have at least a moderate potential to occur due to the species’ range and the occurrence of suitable habitat on the Project site. Note that several of these species are those identified on the Project site, but only occur during phases of their life cycles for which they are not designated as having special status—particularly birds that occur in migration or winter. Species with at least a moderate potential to occur are discussed in greater detail below.

4.4.3.1 Invertebrates
Crotch Bumble Bee
Crotch bumble bee (Bombus crotchii) is not a special-status species under the general definition used in this Report, but is included here because it was recently considered a candidate species under CESA, and recent resolution of litigation may result in the revival of candidate status. The crotch bumble bee formerly ranged throughout much of Central and Southern California, along the Central and Southern California coasts, through the Central Valley, and in the surrounding foothills. However, it now appears to be absent from much of its former range, and its population appears to have declined drastically, especially in its former stronghold in the Central Valley (Xerces Society et al. 2018; CDFW 2019). Crotch bumble bee occurs in open grassland and scrub communities supporting suitable floral resources. Queens emerge first from hibernation and are active from late February to early October, with a peak in activity in early April. Workers begin to emerge in late March, peak in abundance in early July, and may remain active until September (Thorp et al. 1983). Because of its short tongue, the Crotch bumble bee is best suited to foraging at open flowers with short corollas. Data from a variety of resources included observations most commonly associating the species with plants, in descending order based on number of observations, from the families Fabaceae, Apocynaceae, Asteraceae, Lamiaceae, and Boraginaceae (Richardson et al., as cited in Xerces Society et al. 2018). Williams et al. (2014) cited the genera Asclepias, Chaenactis, Lupinus, Medicago, Phacelia, and Salvia as example food plants. The species nests primarily underground and may be reliant on small mammal burrows.

Little is known about winter hibernacula, but the species is presumed to rely on microhabitats for overwintering similar to those of other bumble bees, including loose, disturbed soil, leaf litter, and other debris (Xerces Society et al. 2018; CDFW 2019). An “adult female” Crotch bumble bee was collected at Santa Barbara Shores, less than 0.2 mile east of the Project site, in 2017 (CDFW 2022b). Crotch bumblebee has not been recorded on the Project site.

No focused surveys have been conducted, but no bumble bee species of any type was observed on the site during 73 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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other biological surveys in 2021 or 2022 . Suitable habitat likely occurs at the eastern extreme of the Project site, immediately adjacent to Santa Barbara Shores, within and immediately adjacent to the eucalyptus woodland, where suitable debris and lack of maintenance permit conditions that could support overwintering and nesting by the species. The existing maintained golf course is not suitable, due to the high level of maintenance, and even less maintained areas outside fairways, greens, tees, and surrounds are relatively unlikely to supporting nesting and wintering by this species. Although a variety of species occur in families cited as potential floral resources in Xerces Society et al. (2018) occur on the Project site, particularly species in the large Asteraceae family, only one species in the genera cited in William s et al. (2014) occurs. In general, due to the maintained nature of the Project site, suitable floral resources there are limited . Given the close proximity of occurrences of this species, it may occur there on occasion, including flying over the site in transit between habitats.

Globose Dune Beetle
The globose dune beetle is included on the CDFW Special Animals list, but often is not considered special -status species. It is included here because the City of Goleta General Plan/CLUP species map (City of Goleta 2016) includes occurrences of the species. The globose dune beetle inhabits coastal sand dune habitat from Sonoma County south to Ensenada, Mexico. It burrows beneath the sand and is most common underneath dune vegetation. The nearest occurrences are from the mouth of Tecolote Creek, only 0-.3 miles west of the Project site and 0.4 miles west of the golf course. Potential habitat on the Project site is limited to areas well away from the golf course, on the west side of Bell Canyon Creek lagoon. The Project site lacks the dune habitat suitable for this species, with the possible exception of a small area west of Bell Canyon Creek lagoon and more than 200 feet from the golf course.

Monarch Butterfly
The monarch butterfly is protected in its roosting habitats under the City’s General Plan/CLUP (City of Goleta 2006) and is a candidate for listing under the federal Endangered Species Act. This invertebrate species follows a pattern of seasonal migration. The summer grounds of the species extend as far north as Canada . Eastern monarchs migrate southwest to wintering grounds in the Sierra Madre range of Mexico. Some western monarchs remain in the wintering grounds to breed. Those summering in the Pacific Northwest and the Rocky Mountains migrates to wintering grounds along the California coast (USFWS 2020).

Distribution of monarch butterflies in the breeding season is determined by availability of its host plant, milkweed (Asclepias spp.). Adults lay their eggs on the host plant, and larvae emerge two to five days later. Upon hatching, the larvae feed on the leaves of the plant and stay on the same plant throughout their molting stages. The larva then pupates into its chrysalis before closing as an adult monarch butterfly six to fourteen days later (USFWS 2020).

Multiple generations are produced during spring and summer. During the fall, the last generation of monarchs migrate to overwintering sites and live for 6 to 9 months (Xerces Society 2016). Overwintering sites in California are associated with wind-protected groves of large trees (primarily eucalyptus or pine) with nectar and water sources nearby, generally near the coast . Numerous overwintering sites have been recorded in Santa Barbara County, including the Goleta area (Meade 1999; Xerces Society 2021 , 2022a, 2022b). Several roosting locations in the Project vicinity occur to the west and (especially) the east of the Project site (Figure 9, Monarch Butterfly Survey Results). Poor to unsuitable habitat occurs in the interior part of the golf course. Multiple single cypress (Cupressus sp.) and eucalyptus trees scattered throughout the site do not offer the protected habitat and important microhabitat conditions that monarchs require , including appropriate levels of sunlight, canopy cover, wind protection, humidity, and temperature. The majority of the Project site is also highly landscaped and lacks areas composed of abundant floral/nectar resources. Although some nectar resources, such as coyote brush (Baccharis 74 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

12760 44 AUGUST 2023

pilularis) occur on site, monarchs would be more likely to gravitate toward the abundant nectar resources in the adjacent properties containing coastal sage scrub that surround the site. The scrub habitats in the surrounding area provide a variety of nectar plants for monarchs such as California brittlebush ( Encelia californica), coyote brush, California sagebrush ( Artemisia californica), and black sage ( salvia mellifera). Fresh water resources may include water within Tecolote Canyon and Bell Canyon creeks, coastal fog/precipitation, and possibly within the treated pond within the golf course. In addition, suitable roosting habitat occurs on the eastern boundary and within the Project site boundary along Bell Canyon Creek, which are closer to these areas supporting better foraging habitat. Although roosting habitat on the eastern boundary of the site is adjacent to g olf course, the habitat along Bell Canyon Creek is more than 500 feet west of the golf course and far from proposed Project activities.

Althouse and Meade Inc. (2004) conducted surveys on the Project site in the fall-winter 2003 –2004, recording a high of 1 ,254 monarch butterflies on November 18, 2003, at “Site #60” (Xerces Site No. 2747) a roost at the eastern boundary of the Project site at Devereux Creek. Of these, 98 were in a cluster on the Project site and the rest were in clusters on the property to the east. The high total recorded on the Project site was 123, recorded in a different cluster on the south side of Devereux Creek on December 4, 2003. Numbers decreased at Xerces Site No.2747 and on the Project site as winter progressed, and only 2 roosting butterflies were recorded on site in the final four surveys, through February 29, 2004 (Althouse and Meade Inc. 2004). During surveys in 2021–2022, no clustering or overwintering individuals were detected during monarch surveys within the boundaries of the Project site. Individual fliers (i.e., monarchs in flight) were observed on both surveys along the eastern and western boundaries. Along the eastern boundary (Xerces Site No. 2747), approximately nine individual fliers were observed on the first visit and seven individual fliers along with two dead individuals were observed on the second visit. Along the western boundary, on the west side of Bell Canyon Creek and more than 500 feet from the golf course (Xerces Site No. 2745), only one individual flier was observed during the first visit. In addition, one individual was detected flying within the west central portion of the property. Multiple individual fliers were also observed within the reference sites north and west of the Project site. No additional transitory or overwintering clusters were observed within any areas of the Project site. Clustering individuals were only detected in Ellwood Butterfly Grove. On the first visit to the Ellwood reference sites, single monarch individuals were observed flying at the four westernmost observation points in Site No. 2749 (0.2 mile east of the Project site), single monarch individuals were observed flying in Site No. 2750, and approximately 1,000 indiv iduals were observed clustering, flying and sunning at the easternmost observation point in Site No. 2751 (Figure 9). The second site visit to Ellwood Butterfly Grove returned similar results. Although low numbers were recorded during Dudek’s surveys, in December 2021, over 15,000 monarchs were documented overwintering at the Ellwood Butterfly Grove (City of Goleta 2021).

4.4.3.2 Fish
Tidewater Goby
The tidewater goby is federally listed as enda ngered and an SSC. It is found in brackish or freshwater in bays, sounds, and lagoons, and creeks along the coast from Del Norte County south to San Diego County. Half-grown and adult tidewater gobies move upstream in summer and fall, usually up to 1 kilom eter (0.62 mile) from the estuary, but in some areas from 5 to 8 kilometers (3.1 to 5.0 miles). Reproduction occurs at all times of year, but peak spawning occurs during spring and late summer (USFWS 2005 b). The species is subject to periodic extirpations, but is adapted to recolonization of previously occupied sites from nearby occupied locations (USFWS 2005b). This species inhabits creeks along the entire coast of Santa Barbara County (Swift et al. 1989). It is known to be present in the Bell Canyon Creek, on the Project site but west of the golf course, and the creek has been designated as critical habitat for the species ( 73 FR 5920-6006). Although the species was not observed here during surveys in 75 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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2008, it was detected on at least four oc casions between 1984 and 1999 , and a minimum of 100 were present on the latter date (CDFW 2022b). The species is presumed present in Bell Canyon Creek, but habitat is absent on the golf course or elsewhere within the Project site.

4.4.3.3 Amphibians
California Red -legged Frog
The California red-legged frog (Rana draytonii) is federally listed as threatened (FT) and a California SSC. It occurs on the coastal slope of Southern California, in the coast ranges and immediate coast from central California north to Mendocino County, and in the foothills of the Sierra Nevada and the Cascade Range bordering the Central Valley.

California red-legged frog can survive in a variety of habitat types, including various aquatic, riparian, and upland habitats. Preferred aquatic habitat of the California red-legged frog is characterized by dense shrubby, or emergent riparian vegetation, such as arroyo willow (Salix lasiolepis ), cattails (Typha spp.), and bulrushes ( Schoenoplectus spp.), associated with deep (greater than two feet), still or slow- moving water. The California red -legged frog will also utilize ephemeral ponds, intermittent streams, seasonal wetlands, springs, seeps, permanent ponds, perennial creeks, manmade aquatic features, marshes, dune ponds, lagoons, riparian corridors, blackberry thickets, non- native annual grasslands, and oak savannas. California red- legged frog have been known to breed successfully in artificial ponds with little or no emergent vegetation, although they generally use emergent aquatic vegetation to act as braces to anchor egg masses (USFWS 2002).

Galen Rathbun (2004) conducted surveys on the Project site and in suitable aquatic habitat on the surrounding area between 2002 and 2004. Rathbun conducted six day and night surveys from January 2003 to March 2004 at Bell Canyon Creek. At least one adult California red-legged frog was observed during each survey, with the highest number of 13 observed during the January 2003 survey (Rathbun 2004). Rathbun observed a single egg mass in Bell Canyon Creek during the March 2004 survey. Seven surveys ( day, night, dip -net, and minnow trap) were conducted at the Golf Course Pond from August 2002 to March 2004 (Rathbun 2004). Rathbun observed at least one adult during four of those surveys . Four adults were observed at the Golf Course Pond in both August 2022 and March 2003 (Rathbun 2004). Rathbun conducted four surveys (day, night, and dip -net) in the “Clubhouse Gully” (the unnamed wetland feature near the bluff) from January to June 2004. Two adults were observed during the February 2004 survey, and one adult was observed during the March 2004 survey (Rathbun 2004). Rathbun conducted seven surveys (day, night, and dip-net) in Devereux Creek and its related features from January 2003 to June 2004. No California red-legged frog were observed during any survey conducted in Devereux Creek or its related features (Rathbun 2004).

Ted Mullen and Rosemary Thompson of Science Applications International Corporation (SAIC) observed two California red-legged frog in the Golf Course Pond during surveys conducted in October 2001 (Rathbun 2004 ). In September 2001, Mullen and Thompson also observed a single subadult in Devereux Creek approximately 0.1 mile north of the Project site in a plunge pool between U.S. Highway 101 and the UPRR (Rathbun 2004). Mullen and Thompson identified Bell Canyon Creek as suitable for breeding.

In addition, the CNDDB includes three occurrences within one mile of the Project site. The nearest of these occurrences is at Tecolote Creek, approximately 0.3 mile west of Bell Canyon Creek and the western edge of the Project site, where California red-legged frog have been observed in 1997, 2009, and 2010. One California red- legged frog specimen was collected in June 1997 at an undisclosed location in Tecolote Creek. In 2009, Tecolote Creek was surveyed from the mouth of the creek to the railroad tracks and an undisclosed number of frogs were observed over an approximately 500 -foot stretch of creek. In April 2010 , three females, four males, and five 76 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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juveniles were observed at a n undisclosed location in Tecolote Creek. Another CNDDB occurrence is located approximately 0.5 miles north of the Project site in Bell Canyon, adjacent to Bell Canyon Creek. During emergency road and culvert repair in October and November 2008, over the course of three surveys, a total of ten adults, four juveniles, and 1 tadpole were observed. Three of these adults and one juvenile were relocated downstream in Bell Canyon Creek, in closer proximity to the Project site. An additional CNDDB occurrence from 2008 is located approximately 1.0 mile west of the Project site.

Dudek identified aquatic habitat at three locations on the Project site and within 500 feet and focused on these areas during surveys. the locations were Bell Canyon Creek south of U.S. 101, several shallow pools within the on- site wetland feature near the bluff, and the Golf Course Pond (Table 6; Figure 10, California Red-Legged Frog Survey Results). Although a single subadult was observed in Devereux Creek on the Project site in 2001 (R athbun 2004), Dudek observed no pooling within Devereux Creek anywhere on the Project site or within 500 feet. Water was observed in the plunge pool between U.S. 101 and the UPRR, but this location was outside the designated survey area. The one day-time and four night -time breeding season surveys were conducted from April 25 to June 20 , 2022. The nigh-time and daytime non-breeding season California red-legged frog surveys were conducted on July 21 and July 27, 2022 , respectively (Table 6) . The ha bitat assessment was conducted as part of the daytime breeding-season survey.

Aquatic habitat was not initially identified in the wetland feature near the bluff, but additional investigations following the initial survey identified habitat here prior to t he second night -time survey. Although this area was surveyed during each subsequent visit, pooling here was considered too shallow to support breeding by California red-legged frog, although it may still be used on occasion for dispersal. Aquatic habitat at this location consisted of two pools approximately one foot deep, two feet wide and three feet long, containing gently flowing water were present during the remaining surveys. Water was clear and lacked debris. The pools were well shaded by surrounding cattails but had no overhanging vegetation.

The Golf Course Pond is up to fifteen feet deep and has no overhanging or emergent wetland vegetation. Despite the suitable depth, g iven the lac k of overhanging vegetation and any adjacent vegetation other than maintained turf grass, habitat is not optimal as a breeding site, although the site may still be used as a dispersal site.

Bell Canyon Creek has optimal habitat for California red-legged frog and was surveyed from Hollister Avenue to the Bell Canyon Creek Lagoon. At Hollister Avenue, the Creek was four to six inches deep and did not support pooling.

Shortly downstream, the creek quickly deepens, and ranges between one and four feet deep down to Bell Canyon Creek Lagoon. Dense riparian vegetation covering the banks of the creek is dominated by arroyo willows and cattails.

Water was turbid throughout Bell Canyon Creek and contained substantial woody debris and overhanging vegetation.

Bell Canyon Creek Lagoon likely reaches depths of up to six feet but does not support any overhanging vegetation.

Emergent cattails dominated the fringes of much of the lagoon, with beach sand occurring near the mouth.

No California red-legged frog were observed or heard during any of the focused surveys. At Bell Canyon Creek, dense vegetation and limited visibility may have inhibited detection of California red-legged frog. However, California red- legged frog are unlikely to have avoided detection at the Golf Course Pond and the unnamed wetland feature. Baja California treefrogs ( Pseudacris hypochondriaca ) were detected during every survey, at every aquatic habitat feature surveyed, and they were particularly abundant at the Golf Course Pond and Bell Canyon Creek. Adults and tadpoles were present at all aquatic habitat areas surveyed. Egg masses were observed only at the Golf Course Pond, where they were detected during both the daytime and nighttime surveys on April 25, 2022 . One calling American bullfrog (Lithobates catesbeianus) was detected at the Golf Course Pond during nighttime surveys on April 25, May 11, and May 24, 2022.
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Table 6. California Red-Legged Frog Surveys (2022)
Survey
Type,
No.

Aquatic Habitat
Area Surveyed Date
Start/End
Time
Breeding/
Non-Breeding
Season
Water Temp (º C)
(Start/End)
Moon
Phase
CRLF
Found
Other
amphibians
Day 1 Gold Course Pond April 25, 2022 1630-1700 Breeding 24.0 / 24.0 last quarter None Baja California treefrog
Day 1 Bell Canyon Creek April 25, 2022 1700-1730 Breeding 14.0 / 25.0 last quarter None Baja California treefrog
Night 1 Golf Course Pond April 25, 2022 2039-2151 Breeding 23.0 / 23.0 last quarter None Baja California treefrog,
American bullfrog
Night 1 Bell Canyon Creek April 25, 2022 2230-2355 Breeding 13.2 / 13.2 last quarter None Baja California treefrog
Night 1 Unnamed wetland May 11, 2022 1955-2005 Breeding 16.0 / 16.0 first quarter None Baja California treefrog
Night 2 Golf Course Pond May 11, 2022 2005-2030 Breeding 23.0 / 23.0 first quarter None Baja California treefrog,
American bullfrog
Night 2 Bell Canyon Creek May 11, 2022 2030-2133 Breeding 16.0 / 16.0 first quarter None Baja California treefrog
Day 1 Unnamed wetland May 13, 2022 1120-1138 Breeding 19.1 / 19.1 waxing gibbous
None Baja California
treefrog
Day 2 Golf Course Pond May 13, 2022 1140-1201 Breeding 26.1 / 26.1 waxing gibbous
None Baja California
treefrog
Day 2 Bell Canyon Creek May 13, 2022 1523-1604 Breeding 16.1 / 16.1 waxing gibbous
None Baja California
treefrog
Night 2 Unnamed wetland May 24, 2022 2107-2123 Breeding 16.6 / 16.6 last quarter None Baja California treefrog
Night 3 Gold Course Pond May 24, 2022 2130-2157 Breeding 22.1 / 22.1 last quarter None Baja California treefrog
Night 3 Bell Canyon Creek May 24, 2022 2226-2323 Breeding 14.1 / 21.7 last quarter None Baja California treefrog
Night 3 Unnamed wetland June 20, 2022 2115-2135 Breeding 17.7 / 22.2 last quarter None Baja California treefrog
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Table 6. California Red-Legged Frog Surveys (2022)
Survey
Type,
No.

Aquatic Habitat
Area Surveyed Date
Start/End
Time
Breeding/
Non-Breeding
Season
Water Temp (º C)
(Start/End)
Moon
Phase
CRLF
Found
Other
amphibians
Night 4 Golf Course Pond June 20, 2022 2135-2219 Breeding 22.2 / 24.2 last quarter None Baja California treefrog
Night 4 Bell Canyon Creek June 20, 2022 2254-0007 Breeding 25.0 / 16.7 last quarter None Baja California treefrog
Night 1 Unnamed wetland July 21, 2022 2058-2120 Non-Breeding 16.0 / 16.0 last quarter None Baja California treefrog
Night 1 Golf Course Pond July 21, 2022 2135-2229 Non-Breeding 24.1 / 23.1 last quarter None Baja California treefrog
Night 1 Bell Canyon Creek July 21, 2022 2259-2345 Non-Breeding 16.9 / 24.2 last quarter None Baja California treefrog
Day 1 Unnamed wetland July 27, 2022 1430-1458 Non-Breeding 16.6 / 16.6 new moon None Baja California treefrog
Day 1 Golf Course Pond July 27, 2022 1500-1545 Non-Breeding 25.0 / 25.0 new moon None Baja California treefrog
Day 1 Bell Canyon Creek July 27, 2022 1556-1730 Non-Breeding 16.1 / 25.0 new moon None Baja California treefrog
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4.4.3.4 Reptiles
Western Pond Turtle
The western pond turtle is an SSC that is found throughout the Pacific slope of California. It is highly associated with water, occurring in permanent ponds, lakes, streams, and irrigation ditches in forest, open woodlands, and grassland. Western pond turtles require basking sites such as partially submerged logs, rocks, mats of floating vegetation, or mud banks. Females lay eggs in nests constructed on dry land as far as 100 meters (328 feet) from water. The western pond turtle feeds on aquatic plant material, beetles, aquatic invertebrates, fishes, and frogs.

The nearest CNDDB occurrence is from approximately 1.3 miles east of the Project site. However, Dudek observed this species in May 2022, approximately 0.75 mile west of the Project site, in Tecolote Creek. Bell Canyon Creek, within the Project site boundary but west of and outside the golf course, provides suitable aquatic habitat to support this species, and it may here on occasion, although no pond turtles were observed during surveys of aquatic habitats for California red-legged frog. If this species does occur in Bell Canyon Creek, the bluff and dense vegetation at the western edge of the golf course may present an obstacle to movement onto the golf course, although may have a low potential to reach this area.

4.4.3.5 Birds
American Peregrine Falcon
The peregrine falcon (Falco peregrinu s) is a fully protected species that was formerly listed under both CESA and ESA. It occurs widely across California. In addition, the American peregrine falcon ( F. p. anatum), the subspecies that nests in California, is absent as a nester in the Central Valley and parts of the coast. It typically nests on ledges, and may sometimes nest on human- made structures, such as tall buildings or transmission towers, or in trees.

Nests are usually near water and available prey, although this species may travel long distances from the nest to forage. They feed in open habitat, such as marshes, where they hunt mostly birds, ranging in size from songbirds to small geese ( White et al. 20 20). Several nesting locations are known from south slopes of the Santa Ynez Mountains, including in the Goleta area. But the species is not known to nest near the coast in the Goleta area (Lehman 2022). The eBird citizen-science database (CLO 2022) includes several reports of peregrine falcon from Sandpiper Golf Course. However, nesting habitat is absent from the Project site and immediate area, and any observations of this species likely involve wintering individuals or breeding falcons foraging far from nest sites.

American White Pelican
The American white pelican (Pelecanus erythrorhynchos) is an SSC. It occurs throughout California in winter, during migration, and as a non- breeding summer resident. Historically, it nested in the San Joaquin Valley, the Colorado River Valley, and the Salton Sink, but its breeding range in the state is now limited to n ortheastern California (Shuford 2008). American white pelicans nest I colonies on remote islands where abundant suitable habitat (lakes, marshes, canals, reservoirs) supporting suitable fish prey occurs. Breeding birds may fly many miles to foraging habitat. Away from the breeding grounds, American white pelicans will also forage in estuarine habitats. This species occurs at almost any season in Santa Barbara County, especially from late summer through winter. Reports from the south coast are mostly from la te fall and winter. This species was not recorded during formal surveys of the Project site, but eBird (CLO 2022) includes multiple reports in winter for this easily identified species. However, the Project site does not support breeding habitat for this species, which does not breed in the region, and these reports likely involved individuals moving about the region.
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California Brown Pelican
California brown pelican ( Pelecanus occidentalis californicus ) is a California fully protected species that was formerly listed as endangered under the ESA. It nests in California only on the Channel Islands, at Anacapa Island and Santa Barbara Island, but occurs widely along the California coast at all seasons . It often roosts communally on beaches, sandspits, nearshore islands, and other isolated or protected areas along the immediate coast. It forages in marine environments, mostly along and near the coast, and occasionally occurs in deep water far from shore. California brown pelicans are common year -round in southern Santa Barbara County. Dozens to hundreds may occur in feeding flocks on occasion, in nearshore waters. The species roosts in high numbers very locally along the coast, such as at the Santa Barbara Harbor, where hundreds may be observed roosting on the sandspit. Smaller numbers roost on occasion on the Bird Island structures 0.25 mile offshore of the Project site. At the Project site, this species is generally unexpected, because of its habitat of rarely wandering inland of the immediate cost.

However, during an unusual incursion of this species to inland areas in the spring of 2022, Dudek observed one roosting along the edge of the golf course pond in May 2022.

Cooper’s Hawk
The Cooper’s hawk ( Accipiter cooperii; nesting) is a CDF W Watch List species. It is found throughout California in wooded areas. It inhabits live oak, riparian, deciduous, or other forest habitats (Rosenfeld et al. 2020). This species nests in many species of trees in both extensive forests or isolated trees in natural and urbanized landscapes, often within 1 kilometer of water ( Rosenfeld et al. 2020). Cooper’s hawks use patchy woodlands and edges with snags for perching while they are hunting for medium-sized birds and small mammals (Rosenfeld et al. 2020). Along the south coast of Santa Barbara County, this species is a common transient and winter visitor, and its breeds locally along several rivers and creeks (Lehman 2022). An active nest of this species was observed just east of the Project site in 2006, although the success of the nest was not confirmed (TOBC 2006). Several other occurrences in the site vicinity include one approximately 0.5 mile east of the site in 2017, in the Ellwood Butterfly Preserve ( SBAS 2022). Cooper’s hawk was not recorded on the P roject site during surveys in 2022, but was recorded once in the survey buffer, on March 22, 2022, perched in a eucalyptus tree on the north side of Hollister Avenue and north of the clubhouse (Figure 6).

Redhead
The redhead ( Aythya americana) is a duck species that is considered an SSC in California . It winters throughout California and breeds locally in wetlands in the Central Valley, north eastern California, the eastern deserts, and several locations in the southern coast north to northern Santa Barbara County (Beedy and Deuel 2008; Lehman 2022). Redheads nest in emergent vegetation in relatively deep wetlands with extensive open water , and they winter in relatively large, deep bodies of water. Redheads are not known to nest in southern Santa Barbara County, but in recent years they have nested on the northern coast of the county, with several records from the Santa Ynez River estuary and one from the Santa Maria River estuary (Lehman 2022). Redheads were not observed during any formal biological surveys of the Project site, but eBird includes a reports of a bird that was present in January 2022 (CLO 2022). This individual was presumably wintering in the area. Suitable nesting habitat is absent from the Project site, and the species is not known to nest in southern Santa Barbara County. 81 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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White -tailed Kite
The white-tailed kite (Elanus leucurus) is a state FP species that is a common to uncommon, yearlong resident in coastal and valley lowlands throughout the Pacific slope of California. It nests in treetops with dense foliage, including orchards, and hunts in undisturbed, open grasslands, meadows, farmlands, and emergent wetlands. It prefers to prey on voles and o ther small mammals, and occasionally feeds on birds, insects, reptiles, and amphibians. White-tailed kites roost communally in the non -nesting season. This species is a local breeder along the southern coast of Santa Barbara County (Lehman 20 22). The white-tailed kite population has been known to rise and fall dramatically over the years, and the local population in Goleta appears to be at low levels currently (Lehman 2022; D. Compton, personal observation). A white-tailed kite pair was observed on the Project site in 2004, when they were recorded vocalizing from several trees on the golf course, but no evidence of nesting of nesting was detected , including during subsequent breeding bird surveys (TOBC 2004a, 2004b, 2006). Nesting was recorded in eucalyptus just east of the site in March 2006, the species reportedly was seen over the golf course on occasions prior to 2000 (TOBC 2006). The species is well-known to nest and forage in the Ellwood Mesa area to the east of the site and has been recorded to nest as near as approximately 0.3 miles, in 2010 (SBAS 2022). The species was not observed on the Project site or within the site buffer during surveys in 2022.

Yellow Warbler
The yellow warbler (Setophaga petechia) is an SSC during its nesting period. It breeds widely across California, but is absent from the high Sierras, most of the southern deserts, and most of the Central Valley. The species is largely absent from the state in winter. Spring migrants pass through from April through early June, and fall migrants occur from late July to mid -October. At these seasons, this species occurs in a wide variety of habitats. Yellow warblers breed primarily in deciduous riparian woodlands, including those dominated by cottonwoods, willows, and alders, up to 8000 feet; they also breed in montane chaparral and open conifer forests. In the Santa Barbara and Goleta area, it breeds at several locations characterized by ornamental plantings and irrigation, as well as at several locations supporting riparian habitats typically associated with the species (Lehman 2022; D. Compton, personal observation). This species was detected during April raptors surveys, but not subsequently, and the individuals detected were assumed to be migrants. It has a moderate to low potential to nest on the Project site, especially in riparian at Bell Canyon Creek or in the vicinity of Devereux Creek.

Yellow -headed Blackbird
The yellow-headed blackbird is an SSC for nesting. In California, it breeds locally in the Great Basin, Colorado Valley, Imperial Valley, western Mojave Desert, Central Valley, and select areas nearer the coast (Jaramillo 2008). It formerly bred more widely. This species nests in colonies in emergent wetlands. It occurs regularly in Santa Barbara County, including the Goleta area, in spring and fall (Lehman 2022, D. Compton, personal observations). However, it has not bred in Goleta since the early 20th century (Lehman 2022). A female of this species was observed at the golf course pond during raptor surveys on May 18, 2022, and eBird (CLO 2022) includes observations of up to two during May 2022 (Figure 11, Other Special-Status Wildlife Species Observations).

4.4.4 Jurisdictional Aquatic Resources
Dudek conducted a formal aquatic resources delineation within the Project site of waters of the United States (including wetlands and non-wetlands) regulated by the USACE, waters of the state regulated by the Central Coast RWQCB, jurisdictional streambed a nd riparian vegetation regulated by CDFW, and coastal wetlands and riparian 82 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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regulated by the CCC and the City (Figure 12, Aquatic Resources Delineation). In addition to the aquatic resources described below, the aquatic resources delineation investigated non-jurisdictional features associated with WSP- 01, WSP-03, WSP-04, WSP-05, WSP-06, WSP-07, WSP-08, and WSP-09. Investigations at wetland sample points WSP-01, WSP-04, WSP-05, and WSP-09 did not result in identification of hydrophytic vegetation, hydric soils, or wetland hydrology. The aquatic resource delineation at wetland sample points WSP-03, WSP-06, WSP-07, and WSP- 08 identified hydrophytic vegetation; however, each wetland sample point was dominated by facultative (FAC) plant species: Australian saltbush (Atriplex semibaccata), bristly oxtongue (Helminthotheca echioides), and perennial rye grass (Festuca perennis, previously named Lolium multiflorum and Lolium perenne). “Facultative” is defined as “equally likely to occur in wetlands and non- wetlands.” Since these plant species are widespread throughout the Project site, including slopes and non-jurisdictional areas, it was determined that WSP- 03, WSP-06, WSP-07, and WSP-08 are in upland areas and not jurisdictional. EF-HLM-01 was documented as an erosional feature, thus non- jurisdictional and USW-HLM-04 was an upland swale with lower topography from surrounding areas but was not hydrologically connected to other features and lacked hydrophytic vegetation, thus was non-jurisdictional. Photo documentation is provided in Appendix B, wetland determination data forms and OHWM data sheets are provided in Appendix G.

4.4.4.1 Aquatic Resource A – Bell Canyon Creek
Aquatic Resource A – Bell Canyon Creek is an intermittent stream that forms the western Project boundary (Figure 12A, Aquatic Resource A - Bell Canyon Creek). In the northwestern corner of the City above Cathedral Oaks Road, Ellwood Canyon Creek and Winchester Canyon Creek converge to become Bell Canyon Creek which continues to the coast and discharges into a lagoon at the Pacific Ocean, a traditional navigable water (TNW). The lagoon within the lowermost portion of Bell Canyon Creek is influenced by tides and back -water effects of the lagoon and the seasonally present beach sand bar barrier at the mouth of the stream. Bell Canyon Creek is intermittent and regularly inundated , which makes it a relatively permanent water. Within the Project site, the creek supports extensive riparian habitat, wetland waters, and non- wetland waters. The riparian habitat is dominated by arroyo willow thickets, pepper tree or myoporum groves, eucalyptus groves, and coast live oak woodland. Cattail marsh, emergent wetland, and open water habitats comprise the wetland waters and non-wetland waters.

Bell Canyon Creek was characterized as part of the City of Goleta Creek & Watershed Management Plan (City of Goleta 2020); therefore, the vegetation mapping included in this plan was incorporated into the vegetation map and aquatic resources delineation. Additionally, the City of Goleta Creek & Watershed Management Plan (City of Goleta 2020) includes information on the watershed area, creek length, creek elevation, land use ad jacent to the creek, channel alignment, hydrology, beneficial uses, water quality, channel geomorphology, channel sediments, flooding, and biological resources.

The areas containing hydrophytic wetland vegetation and riparian habitats delineated to the ext ent of riparian vegetation associated with Bell Canyon Creek are potentially jurisdictional. In summary, Aquatic Resource A – Bell Canyon Creek is potential jurisdiction of the following: 1.20 acres USACE wetland waters of the United States, 0.86 acre USACE non-wetland waters of the United States, 1.20 acres RWQCB wetland waters of the state – stream channel, 6.85 acres RWQCB non-wetland waters of the state – stream channel, 5.99 acres CDFW riparian, 2.06 acres CDFW streambed, 2.06 acres CCC and City wetland, and 5.99 acres CCC and City riparian (Table 7). In total Aquatic Resource A – Bell Canyon Creek is 1,076 linear feet.

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Table 7. Summary of Potential Jurisdictional Aquatic Resources Feature ID
USACE
Wetland Waters of the
United States (acres)
USACE
Non -Wetland Waters of the
United States
(acres)
RWQCB
Wetland Waters of the
State - Stream Channel
(acres)
RWQCB
Wetland Waters of the
State – Wetland
(acres)
RWQCB
Non -Wetland Waters of the
State - Stream Channel
(acres)
CDFW
Lake
(acres)
CDFW
Riparian
(acres)
CDFW
Streambed
(acres)
CCC/City
Wetland
(acres)
CCC/City
Riparian
(acres)
Linear
feet
Aquatic Resource A - Bell Canyon Creek
NWW-HLM-08 — 0.74 — — 0.74 — — 0.74 0.74 — 625
NWW-HLM-09 — 0.12 — — 0.12 — — 0.12 0.12 — 451
RIP-RFS-05 — — — — 5.99 — 5.99 — — 5.99 —
WET-HLM-05 1.03 — 1.03 — — — — 1.03 1.03 — —
WET-HLM-06 0.17 — 0.17 — — — — 0.17 0.17 — —
Subtotal 1.20 0.86 1.20 — 6.85 — 5.99 2.06 2.06 5.99 1,076 Aquatic Resource B - Devereux Creek
NWW-HLM-03 — 0.08 — — 0.08 — — 0.08 0.08 — 258
NWW-HLM-05 — 0.02 — — 0.02 — — 0.02 0.02 — 161
NWW-HLM-06 — 0.49 — — 0.49 — — 0.49 0.49 — 706
RIP-RFS-01 — — — — 0.68 — 0.68 — — 0.68 —
RIP-RFS-02 — — — — 0.44 — 0.44 — — 0.44 —
RIP-RFS-03 — — — — 1.72 — 1.72 — — 1.72 —
RIP-RFS-04 — — — — 0.74 — 0.74 — — 0.74 —
Subtotal — 0.59 — — 4.17 — 3.58 0.59 0.59 3.58 1,125
Aquatic Resource C - Golf Course Pond
WET-HLM-07 — — — 1.26 — 1.26 — — 1.26 — —
Subtotal — — — 1.26 — 1.26 — — 1.26 — —
Aquatic Resource D
NWW-HLM-02 — 0.01 — — 0.01 — — 0.01 0.01 — 46
Subtotal — 0.01 — — 0.01 — — 0.01 0.01 — 46
Aquatic Resource E
NWW-HLM-01 — — — — 0.01 — — 0.01 — — 40
Subtotal — — — — 0.01 — — 0.01 — — 40
Aquatic Resource F
NWW-HLM-04 — 0.03 — — 0.03 — — 0.03 0.03 — 237
WET-HLM-01 0.14 — 0.14 — — — — 0.14 0.14 — —
Subtotal 0.14 0.03 0.14 — 0.03 — — 0.17 0.17 — 237
Total 1.34 1.49 1.34 1.26 11.06 1.26 9.57 2.84 4.09 9.57 2,524

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4.4.4.2 Aquatic Resource B – Devereux Creek
Aquatic Resource B – Devereux Creek within the Project site is the western most tributary to the Devereux Creek watershed (Figures 12 B, Aquatic Resource B – Devereux Creek ). Aerial imagery from 1947 to 1967 depicts Devereux Creek as continuously vegetated within the Project site and the next most recent aerial image , 1972, shows the golf course development and discontinuous vegetated areas associated with Devereux Creek (Historic Aerials 2022) pursuant to the original golf course grading plans approved by the County of Santa Barbara on September 24, 1971.

Within the Project site, Devereux Creek is an intermittent stream (although most portions of the creek were observed as dry during Dudek surveys) that enters the site south of Hollister Avenue near the northeast corner of the Project site, with flows directing south and southeast to the eastern boundary of the Project site. Devereux Creek enters the Project site via an approximately 4-foot by 4-foot culvert. and flow is conveyed through a channel with an OHWM of 3 feet, a top of bank width of 6 feet, and an overstory of riparian habitat dominated by eucalyptus with Australian cheesewood (Pittosporum undulatum), Douglas’ sagewort (Artemisia douglasiana), and poison oak (Toxicodendron diversilobum) (NWW-HLM-05). Observed OHWM indicators included vegetation matted down, bent, absent, scour , bed and banks, and change in plant community and/or cover. The creek then enters an approximately 1.5 diameter culvert and pipe under the fairway of golf course hole number one. Devereux Creek daylights again on the south side of the fairway of golf course hole number 1 into a wide channel with an OHWM of 25 feet, a top of bank width of 30 feet, and an overstory of riparian habitat dominated by arroyo willows with Australian cheesewood (Pittosporum undulatum), Cape-ivy (Delairea odorata), petty spurge (Euphorbia peplus), poison oak (Toxicodendron diversilobum), smilograss ( Stipa miliacea var. miliacea), tall flatsedge ( Cyperus eragrostis), and western vervain (Verbena lasiostachys) (NWW-HLM-06). Observed OHWM indicators included wracking, break in slope at OHWM, scour, deposition, and bed and banks. As Devereux Creek extends southeast of the arroyo willows, it is assumed that approximately 450 feet of surface flows would occur across the fairway of golf course hole number 2, under a bridge vegetated, and into an arroyo willow habitat. A culvert was observed within this area to suggest that flows are conveyed through a subsurface pipe (please refer to ph otos 21 and 22 in Appendix B - Photos). Additionally, there is no evidence of flow or standing water within this surface flow area which is likely due to golf course maintenance of fairways and adjacent areas. The topography within this downstream arroyo willow habitat is slightly lower than adjacent areas; however, there was no observed OHWM or top of bank within the riparian canopy. Similar to the upstream area, it is assumed that approximately 310 feet of surface flows would occur across the fairway of golf course hole number 5 into a channel with a OWHM varying between 3 feet to 16 feet and top of bank widths between 6 feet and 22 feet with OHWM indicators from presence of litter and debris; wracking; vegetation matted down, bent, or absent; sediment sorting; leaf litter disturbed or washed away; bed and banks; and change in plant community and/or cover. The riparian habitat was dominated by eucalyptus, with nasturtium (Tropaeolum majus) and poison hemlock (Conium maculatum) (NWW- HLM-03). Additionally, two upland swales convey water into this downstream portion of Devereux Creek. Note that, while eucalyptus woodland is not typically considered riparian habitat, it may be regarded as riparian vegetation where it is associated with a stream course and provides important habitat for other species. Despite assumptions that communities dominated by non-native eucalyptus is poor habitat for wildlife compared to native woodlands, evidence suggests th at native and eucalyptus woodlands in California support a similar species richness (Sax 2002). Eucalyptus woodland along Devereux Creek is especially valuable as is supports habitat for special-status species including Santa Barbara honeysuckle (see Section 4.4.2) and monarch butterfly (see Section 4.4.3).
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Riparian habitats were delineated along Devereux Creek , and these and areas extending to the OHWM are potentially jurisdictional. Additionally, two non-jurisdictional swales convey water into the downstream portion of Devereux Creek along the eastern boundary of the Project site. In summary, Aquatic Resource B – Devereux Creek is potential jurisdiction of the following: 0. 59 acre USACE non- wetland waters of the United States , 4.17 acres RWQCB non-wetland waters of the state – stream channel, 3.58 acres CDFW riparian, 0.59 acre CDFW streambed,

0.59 acre CCC and City wetland, and 3.58 acres CCC and City riparian (Table 7). In total Aquatic Resource B – Devereux Creek is 1,125 linear feet.

4.4.4.3 Aquatic Resource C – Golf Course Pond
Aquatic Resource C – golf course pond is within the northwestern portion of the Project site (Figure 12C, Aquatic Resource C – Golf Course Pond ). Aerial imagery from 1947 to 1967 depicts this area as upl and habitat with scattered vegetation; the next most recent aerial image, from 1984, shows the pond, which was developed during construction of the golf course (Historic Aerials 2022) . The golf course pond is a man- made (anthropogenic) perennial aquatic feature surrounded by maintained mowed turf with no emergent wetland vegetation. The tee for golf course hole number 18 is on a peninsula extending from the adjacent golf cart path into the pond. The pond is not hydrologically connected to downstream features and is approximately 780 feet from Bell Canyon Creek riparian habitat and approximately 900 feet from the Pacific Ocean.

Since Aquatic Resource C – golf course pond is isolated, it is not expected to be jurisdiction of USACE. The limits of the pond are potential jurisdiction of the following: 1.26 acres RWQCB wetland waters of the state – wetland, 1.26 acres CDFW lake, and 1.26 acres CCC and City wetland (Table 7).

4.4.4.4 Aquatic Resource D
Aquatic Resource D is an unnamed feature within the southwestern portion of the Project site (Figure 12D, Aquatic Resource D). This aquatic resource was inundated during the May 2022 aquatic resources survey and is likely fed by golf course irrigation, resulting in an intermittent to perennial feature. The aquatic resource has an OHWM of 2 feet and a top of bank width of 6 feet with observed natural line impressed on the bank, scour, bed and banks, and change in plant community and/or cover (NWW-HLM-02). Plant species observed included annual rabbitsfoot grass (Polypogon monspeli ensis), brass buttons ( Cotula coronopifolia ), bristly oxtongue ( Helminthotheca echioides), castorbean (Ricinus communis), fat hen ( Atriplex prostrata), fiddle dock (Rumex pulcher), field mustard (Brassica rapa), and shortpod mustard (Hirschfeldia incana), Downstream of the channel the flow is conveyed by a pipe onto the beach and via an undefined swale through iceplant. A wetland sampling point (WSP-02) was recorded within the channel. Vegetation was dominated by annual rabbitsfoot grass (Polypogon monspeliensis; FACW), bristly oxtongue (Helminthotheca echioides; FAC), castorbean (Ricinus communis; FACU), fat hen (Atriplex prostrata; FACW), and field mustard (Brassica rapa; FACU), which passed the dominance test resulting in hydrophytic vegetation. A soil pit was excavated to a depth of 16 inches and hydric soil indicators hydrogen sulfide and redox dark surface were observed resulting in hydric soils. Wetland hydrology indicators surface water, high water table, saturation, aquatic invertebrates, hydrogen sulfide, and drainage patterns were observed resulting wetland hydrology.

Areas extending to top of bank and extending to the OHWM are potentially jurisdictional. Additionally, there is one swale, non -jurisdictional, that conveys water onto the beach downstream of Aquatic Resource D. In summary, Aquatic Resource D is potential jurisdiction of the following: 0.01 acre USACE non -wetland waters of the United States, RWQCB non- wetland waters of the state – stream channel, CDFW streambed, and CCC and City wetland (Table 7). In total Aquatic Resource D is 46 linear feet. 88 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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4.4.4.5 Aquatic Resource E
Aquatic Resource E is an unnamed, anthropogenic feature along the northern Project boundary within the northwestern portion of the Project site (Figure 12E, Aquatic Resource E). This aquatic resource was dry during the May 2022 aquatic resources survey and is likely an ephemeral feature constructed to convey storm flows from the area immediately west of the clubhouse. Upstream of the aquatic resource is an undefined swale through upland mustard and wild oats and annual brome grassland. The aquatic resource has an OHWM of 5-feet and a top of bank width of 8-feet (NWW-HLM-01). Dominant plant species observed included castorbean (Ricinus communis), coyote brush ( Baccharis pilularis ), petty spurge ( Euphorbia peplus ), poison hemlock ( Conium maculatum), and shortpod mustard (Hirschfeldia incana). No associated riparian vegetation was observed. At the downstream end of the channel a 3-foot wide by 2-foot tall culvert conveys water downstream likely into the storm drain which flows to the Pacific Ocean. This anthropogenic feature shows no signs of recent maintenance.

Areas extending to top of bank are potentially jurisdictional. Additionally, there is one swale, non-jurisdictional, that conveys water into Aquatic Resource E. In summary, Aquatic Resource E is potential jurisdiction of the following:

RWQCB non-wetland waters of the state – stream channel and CDFW streambed (Table 7). In total Aquatic Resource D is 40 linear feet.

4.4.4.6 Aquatic Resource F
Aquatic Resource F is an unnamed feature along the southern boundary of the Project site within the central portion of the Project site (Figure 12F, Aquatic Resource F). The general area extending upslope of the aquatic resource to the north through the topographic low area is sometimes referred to as the “Clubhouse Gully” per Rathbun (2004).

Aerial imagery from 1947 to 1967 depicts this Aquatic Resource F area with darker likely riparian or hydrophytic vegetation (Historic Aerials 2022) . However, th e next most recent aerial image, from 1984, shows darker, likely riparian or hydrophytic vegeta tion extending upslope of the aquatic resource to the north through the topographically lower area, which was likely disturbed/removed during construction of the golf course.

Aquatic Resource F begins with an undefined swale that conveys water south to a channel with OHWM varying between 1 foot and 5 feet and a top of bank width varying between 5 feet and 10 feet (NWW-HLM-04). OHWM indicators included break in slope at OHWM, scour, and bed and banks. Plant species observed included annual rabbitsfoot grass ( Polypogon monspeliensis), coyote brush ( Baccharis pilularis ), field mustard (Brassica rapa), poison hemlock (Conium maculatum), and southern cattail ( Typha domingensis). No surface water was observed within the swale; however, a 3-inch white PVC pipe and 4- inch black corrugated HDPE pipe were observed within the inundated channel which are likely fed by golf course irrigation water . Downstream of the channel is a large wetland area dominated by cattails. Water was observed flowing from the limits of the cattail wetland through the seawall to the beach.

Areas extending to top of bank and extending to the OHWM are potentially jurisdiction. Additionally, there is one swale, non-jurisdictional, that conveys water into Aquatic Resource F. In summary, Aquatic Resource F is potential jurisdiction of the following: 0.14 acre USACE wetland waters of the United States, 0.03 acre USACE non -wetland waters of the United States , 0.14 acre RWQCB wetland waters of the st ate – stream channel, 0.03 acre RWQCB non-wetland waters of the state – stream channel, 0.17 acre CDFW streambed, and 0.17 acre CCC and City wetland (Table 7). In total Aquatic Resource F is 237 linear feet. 89 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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4.4.4.7 Jurisdiction
Aquatic Resources A , B, D, and F may be regulated by USACE given their duration of flow and downstream connection to a traditional navigable water (the Pacific Ocean). These features may also be regulated by the RWQCB, CDFW, CCC, and the City. In addition, RWQCB, CDFW, CCC, and the City may regulate streambeds beyond the OHWM (to top of bank) and associated riparian habitat. Based on the aquatic resources delineation the following potential jurisdictions are on the Project site: 1.34 acres of USACE wetland waters of the United States, 1.49 acres of USACE non-wetland waters of the United States, 1.34 RWQCB wetland waters of the state – stream channel, 1.26 RWQCB wetland waters of the state – wetland, 11.06 RWQCB non-wetland waters of the state – stream channel, 1.26 acres of CDFW lake, 9.57 acres of CDFW riparian, 2.84 acres of CDFW streambed, 4.09 acres of CCC and City wetland, and 9.57 acres of CCC and City riparian (Table 7).

4.4.5 Wildlife Corridors and Habitat Linkages
Wildlife corridors are linear features that connect large patches of natural open space and provide avenues for dispersal or migration of animals and dispersal of plants (e.g., via wildlife vectors). Wildlife corridors contribute to population viability by assuring continual exchange of genes between populations, which helps maintain genetic diversity.

Habitat linkages are small patches that join larger blocks of habitat and help reduce the adverse effects of habitat fragmentation. They serve as connections between habitat patches and help reduce the adverse effects of habitat fragmentation. Although individual animals may not move through a habitat linkage, the linkage is a potential route for gene flow and long -term dispersal. Habitat linkages may serve b oth as habitat and avenues of gene flow for small animals such as reptiles, amphibians, and rodents. Habitat linkages may be represented by continuous patches of habitat or by nearby habitat “islands” that function as stepping stones for dispersal and move ment (especially for birds and flying insects). Wildlife corridors and habitat linkages provide avenues for dispersal or migration of animals that also contribute to population viability in several ways, including (1) ensuring continual exchange of genes between populations to aid in maintaining genetic diversity, (2) providing habitat for some species, (3) providing access to adjacent habitat areas representing additional territory for foraging and mating, (4) allowing for a greater carrying capacity, and (5) providing routes for colonization of habitat lands following local population extinctions or habitat recovery from ecological catastrophes.

The Project site is situated adjacent to a large area of open Space within the City of Goleta at Ellwood Mesa, extending eastward to the University of California, Santa Barbara’s Coal Oil Point Reserve , North Campus Open Space, and Devereux Slough . This complex of open spaces includes grassland, coastal scrub, coastal salt marsh and flood plain, and an extensive area of eucalyptus supporting monarch butterflies. Bell Canyon Creek, occupying the western section of the Project site, provides various wildlife species with access to the coast from extensive undeveloped lands in the Santa Ynez Mountain foothills and beyond. Although the Project site is mostly developed as a golf course, and daytime human activity likely deters movement by larger and medium -size terrestrial mammals. It serves several connectivity functions, including opportunities for gene flow for plant and smaller animal species, therefore providing a genetic connection between the Santa Ynez Mountain foothills and coastal open space, as well as night-time movement opportunities for larger and medium-size wildlife travelling between these areas and foraging opportunities for a variety of species. Scrub habitats along the bluff and riparian habitats along Devereux Creek provide potential for gene flow along the coast and between inland and coastal areas, respectively.

The golf course itself is almost entirely free of structures and human activity during nighttime, and the more mobile wildlife species occurring the area, such as coyotes ( Canis latrans) and bobcat ( Lynx rufus ), potentially move 90 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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through this area on occasional to access foraging habitat at Ellwood Mesa and other open space, as well as along Bell Canyon Creek. Some medium-sized to smaller mammals, such as red fox (Vulpes vulpes ) and striped skunk (Mephitis mephitis) may occupy areas along the bluff or in Bell Canyon Creek and access the golf course at night to forage. Although some larger mammals, such as mule deer (Odocoileus hemionus) or American black bear (Ursus americanus), also have the potential to use these areas for movement on occasion, available foraging habitat along the coast is limited for these species.

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5 Impacts and Recommendations
This section describes the potential Project’s impacts and consistency with City policy . It also recommends measures to avoid, minimize, and mitigat e potential impacts. General Plan/CLUP Conservation Element p olicies relevant to biological resources in the Coastal Zone are provided in Appendix A. As described below, development of the proposed Project contains the possibility for several potential impacts, however, the in- depth analysis concludes that only minimum impacts occur to sensitive biological resources or ESHA and these impacts and uses are consistent with several General Plan/CLUP policies, including, but not limited to CE 1.6, 1.7, and CE 2.5 related to protection of ESHA, appropriate restoration opportunities for degraded creeks, and mitigation for public uses that encroach into ESHA and ESHA buffers . Dudek has also prepared an ESHA memorandum (memo) that discusses the ESHA and ESHA buffers on the Project site (Dudek 2023).

Impacts from development projects typically include permanent impacts from development and temporary impacts to areas affected by Project activities but where no permanent development occurs. Most of the existing golf course is already developed as golf course or supports structures and other golf course support facilities (parking areas, maintenance yard, restrooms). In addition, a small area is occupied by the historic Barnsdall Gas Station, where improvements are proposed. Therefore, most areas subject to Project impacts are already developed, although they may not support structures or hardscape typically associated with development. Even those areas that are more natural are islands of vegetation interspersed among the more extensive, maintained parts of the golf course.

However, sensitive resources occur in several locations, especially around the fringes of the golf course, and many of these resources are ESHA, and their designation as such entails development setbacks (Figure 13 , ESHA, Sensitive Resources, and Setbacks).

Project activities could result in a variety of potential impacts to these resources and setbacks. Most grading would occur in areas already considered developed as maintained golf course (tees, greens, fairways, sand traps, surrounds) or more traditional development, but some grading will occur in areas that are not maintained and do not support h ardscape or structures. Grading may also be proposed in ESHA setbacks, and therefore may have potential to result in impacts to ESHA resources , especially where the impacts occur in more natural parts of the existing golf course. New golf car t paths may al so occur in areas supporting sensitive resources or within ESHA setbacks. And sand-capping may overlap some natural areas, and thus could result in impacts to sensitive biological resources, although it would not constitute an impact to regularly maintained portions of the golf course, including those within ESHA setbacks. Finally, if Project activities occur outside any of these areas, unknown impacts could occur, if ESHA boundaries and setbacks are disregarded. The following analysis considers all potenti al types of impacts, current land use (including whether a location is already subject to regular maintenance), and the nature of the resource potentially subject to impacts , such as whether it is present seasonally versus year -round of temporarily versus permanently.

General Plan/CLUP Policies pertaining to ESHA are included in Appendix A. Policy CE 1.6, regarding protection of ESHA, states that “No development, except as otherwise allowed by this element, shall be allowed within ESHA.” Allowable uses, which include public road crossings, utility lines, restoration and enhancement, nature education, biological resource, and Public Works projects, are not part of the Project. CE 1.7 states that “New development shall be cited and designed to avoid impacts t o ESHA,” but does allow for project design with the “fewest or least significant impacts,” if no feasible alternative exists to avoid impacts completely. As the Project generally occurs on maintained portions of an existing golf course, in many cases, the activities being conducted are not new 93 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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development. However, elements of the Project are new, and could result in impacts if they occur within ESHA or ESHA setbacks.

5.1 Impacts to Vegetation Communities and
Land Covers, Including Native Grassland
The Project site supports 12 sensitive vegetation communities designated as an Environmentally Sensitive Habitat Area (ESHA) and that receive protection , guidance, and mitigation under the General Plan/CLUP policies (City of Goleta 2006) (Table 8). Several General Plan/CLUP policies specifically address protection and mitigation for ESHA that are applicable to the proposed Project:

CE 1.6 Protection of ESHAs. [GP/CP] ESHAs shall be protected against significant disruption of habitat values, and only uses or development dependent on and compatible with maintaining such resources shall be allowed within ESHAs or their buffers. The following shall apply:
a. No development, except as otherwise allowed by this element, shall be allowed within ESHAs and/or ESHA buffers.
b. A setback or buffer separating all permitted development from an adjacent ESHA shall be required and shall have a minimum width as set forth in subsequent policies of this element.

The purpose of such setbacks shall be to prevent any degradation of the eco logical functions provided by the habitat area.
c. Public accessways and trails are considered resource-dependent uses and may be located within or adjacent to ESHAs. These uses shall be sited to avoid or minimize impacts on the resource to the maximum extent feasible. Measures— such as signage, placement of boardwalks, and limited fencing or other barriers— shall be implemented as necessary to protect ESHAs.
d. The following uses and development may be allowed in ESHAs or ESHA buffers only where there are no fe asible, less environmentally damaging alternatives and will be subject to requirements for mitigation measures to avoid or lessen impacts to the maximum extent feasible: 1) public road crossings, 2) utility lines, 3) resource restoration and enhancement projects, 4) nature education, 5) biological research, and 6) Public Works projects as identified in the Capital Improvement Plan, only where there are no feasible, less environmentally damaging alternatives.
e. If the provisions herein would result in any legal parcel created prior to the date of this plan being made unusable in its entirety for any purpose allowed by the land use plan, exceptions to the foregoing may be made to allow a reasonable economic use of the parcel. Alternatively, the City may establish a program to allow transfer of development rights for such parcels to receiving parcels that have areas suitable for and are designated on the Land Use Plan map for the appropriate type of use and development.
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CE 1.7 Mitigation of Impacts to EHSAs. [GP/C P] New development shall be sited and designed to avoid impacts to ESHAs. If there is no feasible alternative that can eliminate all impacts, then the alternative that would result in the fewest or least significant impacts shall be selected. Any impacts that cannot be avoided shall be fully mitigated, with priority given to onsite mitigation. Offsite mitigation measures shall only be approved when it is not feasible to fully mitigate impacts on site.

If impacts to onsite ESHAs occur in the Coastal Zone, an y offsite mitigation area shall also be located within the Coastal Zone. All mitigation sites shall be monitored for a minimum period of 5 years following completion, with changes made as necessary based on annual monitoring reports.

Where appropriate, mitigation sites shall be subject to deed restrictions. Mitigation sites shall be subject to the protections set forth in this plan for the habitat type unless the City has made a specific determination that the mitigation is unsuccessful and is to be discontinued.

CE 2.5 Maintenance of Creeks as Natural Drainage Systems. [GP/CP] Creek banks, creek channels, and associated riparian areas shall be maintained or restored to their natural condition wherever such conditions or opportunities exist. Creeks carry a significant amount of Goleta’s stormwater flows.

The following standards shall apply:
a. The capacity of natural drainage courses shall not be diminished by development or other activities.
b. Drainage controls and improvements shall be accomplished with the minimum vegetation removal and disruption of the creek and riparian ecosystem that is necessary to accomplish the drainage objective.
c. Measures to stabilize creek banks, improve flow capacity, and reduce flooding are allowed but shall not include installation of new concrete channels, culverts, or pipes except at street crossings, unless it is demonstrated that there is no feasible alternative for improving capacity. d. Drainage controls in new development shall be required to minimize erosion, sedimentation, and flood impacts to creeks. Onsite treatment of stormwater through retention basins, infiltration, vegetated swales, and other best management practices (BMPs) shall be required in order to protect water quality and the biological functions of creek ecosystems. e. Alteration of creeks for the purpose of road or driveway crossings shall be prohibited except where the alteration is not substantial and there is no other feasible alternative to provide access to new development on an existing legal parcel. Creek crossings shall be accomplished by bridging and shall be designed to allow the passage of fish and wildlife. Bridge abutments or piers shall be located outside creek beds and banks, unless an environmentally superior alternative exists. (Amended by Reso. 09-59, 11/17/09)
Several Project activities have potential to result in impacts to these communities, although the impacts from these activities vary. However, all impacts shown in Table 8, if occurring directly within a sensitive community or land cover, would result in removal or alteration of existing habitat and would therefore be a direct impact. Impacts from grading generally involve recontouring and sand-capping within the existing golf course, followed by installation of turf or native revegetation, and are, therefore, not considered new development. The impact from establishment of a cart path or bridge within the designated setback of a sensitive community depends on the type of bridge 95 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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proposed and the location of the golf cartpath (whether or not it is within a currently maintained part of the golf course) and whether the re-routing of the path will result in an increase or decrease in the area within ESHA or an ESHA buffer. Impacts to ESHA may also include encroachment of the project within ESHA buffers , potential for inadvertent impacts to sensitive vegetation, and potential impacts from dust or chemical pollutants. Specifics of Project impacts to the sensitive vegetation, considered ESHA, are described further below.

Table 8 shows all direct impacts to sensitive vegetation communities. The Project would result in the loss of 0.02 acre of arroyo willows and 0.01 acre of coyote brush scrub (considered coastal bluff scrub/coastal sage scrub) due to bridge and replacement golf cart path construction at Devereux Creek (Figure 14, Impacts). As shown in Figure 14, Project activities would also occur within the designated setbacks of several communities. Sand -capping is proposed within the setbacks for coyote brush scrub, quailbush scrub, and California brittle bush – ashy buckwheat scrub alliance (all considered coastal bluff scrub/coastal sage scrub) near the bluffs (Figure 14). These activities would support replanting of turf grass in areas that are already maintained golf course and , therefore, would not constitute a new impact. Sand -capping would also occur within the setback of cattail marshes habitat associated with Bell Canyon Creek and beach habitat just east of Bell Canyon Creek, but also would be in support of modifications to the existing golf course. A new golf cart path within the existing, maintained golf course would not unto itself constitute a new development or impact within an ESHA setback. Impacts to ESHA buffers become significant when natural vegetation or wildlife habitats are altered and/or new indirect impacts are introduced (i.e., noise, light, etc.). The proposed Project was careful in its design to avoid encroaching into ESHA and ESHA buffers that did not already contain playable areas of the golf course with managed turf or degraded habitat, such as Devereaux Creek, where the replacement cart bridge and culvert will be installed in compliance with Policies CE 1.7 and CE 2.5. Note that new development adjacent to ESHA setbacks typically requires restoration of these setbacks with native vegetation. Where no new development occurs, restoration of ESHA setbacks shall not be required.

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Table 8. Impacts to Sensitive Vegetation Communities and Land Cover Types Category
Setback
(ft)
Total
acreage
Impacts (acres)
Grading
Sand -
Capping
Cart
Path Bridge
Arroyo willow thickets (riparian) 100
(maximum)

5.50 ― ― 0.002 0.02
Baccharis pilularis -
Toxicodendron diversilobum
(coastal sage scrub)
25 0.41 ― ― ― ―
Beach N.A. 8.45 ― ― ― ―
California brittle bush - Ashy
buckwheat scrub (coastal sage
scrub)
25 0.07 ― ― ― ―
Cattail marshes (wetland) 100 1.19 ― ― ― ―
Coast live oak woodland (oak
woodland)
N.A. 0.73 ― ― ― ―
Coastal sage scrub (coastal
sage scrub)
25 0.11 ― ― ― ―
Coyote brush scrub (coastal
bluff scrub)
25 2.67 ― ― 0.001 0.01
Emergent wetland (wetland) 100 0.17 ― ― ― ―
Needle grass grassland (native
grassland
10 0.36 ― ― ― ―
Quailbush scrub (coastal bluff
scrub)
25 8.32 ― ― ― ―

The replacement cart path and free-span bridge are proposed between H oles 4 and 5 within ESHA (i.e., arroyo willow thickets and coyote brush scrub vegetation communities) associated with Devereux Creek (Figure 14, Table 8). A portion of the path also occurs within the buffer of these ESHAs. General Plan/CLUP Policy CE 1.6 provides protections for ESHA and ESHA buffers against development. However, this policy allows for public accessways and trails. In addition, this replacement cart path and bridge will replace an existing cart path and Arizona crossing that also crosses through ESHA that is both Devereux Creek riparian and Monarch Butterfly Roosting ESHA at the eastern edge of the property. Also, a long stretch of the same existing path is within the ESHA buffer for Monarch Butterfly Roosting ESHA. The replacement path would significantly reduce the area of the cart path within ESHA and the ESHA buffer, from 5,134 square feet to 2,607 square feet , a reduction of 2,527 square feet, or 0.06 acre .

Therefore, the replacement cart path will reduce the encroachment of ESHA and ESHA buffer from this path to slightly more than half its current extent. The current cart path, culvert, and Arizona crossing that will be removed from the golf course will be revegetated with native vegetation. The proposed Project reduces the area of the cart path within ESHA and the ESHA buffer . Implementing mitigation consistent with Policy CE 1.7 and CE 2.5 would further lessen project impacts to arr oyo willow thickets and coyote brush scrub. The Project design includes 1) replacement of the cart path/culvert/Arizona crossing under Devereux Creek that connects Holes 4 and 5 ; 2) , installation of a new free-span bridge; 3) and re-establishment of a natural creek channel with sandstone boulders and riparian vegetation on the banks. The result is the configuration of a free- flowing natural stream channel in conjunction with an environmentally superior Project design consistent with Policy CE 1.7 and CE 2.5 with the inclusion of recommended Mitigation Measures:
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MM- BIO-1, MM BIO -2, MM BIO -3, MM BIO -4, MM BIO-5, and MM BIO -6 are recommended for further reducing impacts to ESHA, including proposed removal of 0.03 acre of sensitive vegetation from installation of a free-span bridge and grading of 0.003 acre or sensitive vegetation for the realignment of the cart path . Re-establishment of the creek and replacement of the culvert should be conducted in accordance with Policy CE 1. 7 and to satisfy requirements in MM BIO-1, below.

MM BIO-1 Compensatory Mitigation for Impacts to Sensitive Communities and Riparian Habitat . On- site mitigation shall be provided to compensate for the permanent loss of arroyo willow thickets/riparian habitat (0.02 acre) and coyote brush scrub (0.01 acre) at a ratio of 5:1 . Details of the mitigation program requirements shall be described in a Habitat Mitigation and Monitoring Program (HMMP). Requirements described in the HMMP shall include:

1. Specification that mitigation shall be on-site and shall occur adjacent, or as near as possible, to any removed habitat area. Mitigation for loss of arroyo willow/riparian habitat and coyote brush scrub associated with Devereux Creek shall occur only along Devereux Creek, and near the area of impacts to the extent possible.

2. Mitigation for the loss of arroyo willow thicket/riparian habitat shall conform with any requirements included within a Lake and Streambed Alteration Agreement provided by the California Department of Fish and Wildlife.

3. The mitigation program shall conform with all requirements of the City of Goleta General Plan/Coastal Land Use Plan and the City of Goleta Creeks and Watershed Management Plan.

4. Specification of a 5-year monitoring period for all restoration areas.

5. Development of a plant palate for each restoration area (arroyo willow thicket/riparian, coyote brush scrub) in keeping with the character and plant composition of the native community being restored.

6. Defined attainable and measurable goals and objectives to be achieved through implementation of the HMMP.

7. A restoration work plan that details methodologies, a restoration schedule, plant materials (seed), and implementation strategies.

8. A detailed maintenance plan to include removal of invasive non-native species.

9. Defined performance standards for restoration.

10. A monitoring plan that includes methods and analysis of results, goals for success or failure, and an adaptive management plan and suggestions for failed restoration efforts.

11. Restoration activities using native species from locally collected stock.

MM BIO-2 Delimiting and Avoidance of ESHA and ESHA Setbacks . Prior to initiation of Project-related activities, including grading, establishment of replacement cart paths, sand -capping, re-sodding, 98 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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landscaping, or construction of the new clubhouse or other structures, all sensitive habitats and required setback shall be delineated with construction fencing and protected with BMPS, such as silt fencing or straw wattles . Areas protected under this measure shall include sensitive coastal sage scrub and coastal bluff scrub communities, riparian habitats associated with Devereux Creek, coastal wetlands, native grasslands, and areas supporting special -status plant species. Unless otherwise authorized, setbacks shall be as follows:
 Sensitive scrub communities: 25 feet
 Riparian vegetation: 100 feet unless otherwise authorized  Coastal wetlands: 100 feet
 Native grasslands: 10 feet
No grading, no vehicles or heavy machinery, and no construction shall be permitted with the setbacks, unless setbacks are reduced for specific activities and locations. No grading, sand-capping, vehicles, heavy machinery, or construction activities shall be permitted within any ESHA at any time, unless these activities are covered under compensatory mitigation described in MM BIO-1.

MM BIO-3 W orker Environmental Awareness Program (WEAP). All construction personnel shall attend a WEAP training by a qualified biologist prior to commencement of Project activities. The training shall include a description of a special- status species potentially present in the area, jurisdictional habitats present proximate to the Project site, information on sensitive habitats to be avoided, and specific measures that are being implemented to protect special- status species and the boundaries within which the Project may be accomplished. Special-status plant species addressed in the WEAP traini ng shall include, at a minimum, cliff malacothrix , red sand verbena, Santa Barbara honeysuckle, Southern California black walnut, southern tarplant, and woolly seablite.

Species-status wildlife species addressed in the WEAP, at a minimum, California red -legged frog, tidewater goby, western pond turtle, and white-tailed kite.

MM BIO-4 Biological Monitoring during Constructio n. The Project shall retain a qualified biologist to monitor construction and compliance of all recommended mitigation measures. The monitor shall perform daily clearance surveys prior to any grading, turf removal, other vegetation removal, to search for California red-legged frog, western pond turtle, and other special-status wildlife species.

The monitor shall also perform regular inspec tions of construction fencing and BMPS around sensitive habitats and setbacks. Monitoring shall be daily during grading and vegetation removal, and weekly for the remainder of the Project. Reporting shall be on weekly basis. A final monitoring report shall be prepared after all Project activities have been completed by the contractor.

MM BIO-5 Best Management Practices. Best management practices, such as silt fending or straw wattles, shall be installed prior to conducting any Project activity within 100 feet of any aquatic resource, including sand-capping, grading, cart path construction, or bridge construction. Implementation of BMPs shall be consistent with any requirements for preparation of a Stormwater Pollution Prevention Plan (SWPPP) for the Project.

MM BIO-6 Equipment Maintenance Conducted Away from Environmentally Sensitive Habitat . In addition to any standard requirements for preventing pollutants entering waters or wetlands, 99 SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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vehicle or equipment maintenance shall not be conducted within 100 feet of any environmentally sensitive habitat.

5.2 Impacts to Special -Status Plants
Surveys identified the following special-status plant species as occurring on the Project site:
 Cliff malacothrix
 Red sand verbena
 Santa Barbara honeysuckle
 Southern California black walnut
 Woolly seablite
Of these, Southern California black walnut occurs within riparian vegetation associated with Bell Canyon, red sand verbena is associated with dunes near the mouth of Bell Canyon Creek, and cliff malacothrix and woolly seablite occur on the bluffs within scrub communities located away from Project activities. Santa Barbara honeysuckle has been identified only within and adjacent to riparian habitat and monarch butterfly roosting habitat, which Project activities will avoid. Therefore, no impacts are expected to known populations or individuals of special-status plants.

However, if any Project activities occur outside of identified impact areas, impacts could result to known individuals and populations. Also, depending on the interval between special-status plant surveys conducted in 2022 and the initiation of construction, potentially occurring special-status plants could occur outside areas where they have been identified previously.

MM BIO-2, MM BIO-3, and MM BIO-4, MM BIO-5, MM BIO-6, and MM BIO-7 are recommended to avoid impacts to special-status plants.

MM BIO-7 Updated Surveys for Special-Status Plants. If, at the time construction is initiated, special-status plant surveys have not been conducted on the Project site for more than a period of two years, conduct up dated special -status plant surveys, to determine current locations of special -status plants and special-status plant populations. Special-status plant surveys shall be conducted at the appropriate season, and in appropriate habitat, for identifying potentially occurring species, at least including cliff malacothrix, red sand verbena, woolly seablite, and Santa Barbara honeysuckle. The special-status plant species survey shall be conducted in conformance with the C alifornia Native Plant Society Botanical Survey Guidelines (CNPS 2001) , Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities (CDFW 2018), and the U.S. Fish and Wildlife Service’ s General Rare Plant Survey Guidelines (Cypher 2002). If special-status plant species are encountered, field personnel will demarcate the edge of the area occupied by the plants . Any habitat area supporting special -status plants shall be considered ESHA, and appropriate setbacks shall be established.

5.3 Impacts to Special-Status Wildlife Species
Dudek identified 13 species of wildlife that have been observed on the Project site or have the potential to occur that are considered special-status species, including three invertebrate species, one fish species, one amphibian 100

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species, one reptile species, and seven bird species (Appendix E). One invertebrate species, globose dune beetle, has potential to occur only on the beach, and would not be subject to impacts from Project implementation. Another.

Crotch bumble bee, may fly over the site, but has a low potential to nest or hibernate on the site . Also, the Project would not substantially alter habitat for this species.

5.3.1 Invertebrates
One special-status invertebrate species, monarch butterfly, has been observed on the Project site. Two additional species, Crotch bumble bee and globose dune beetle , have some potential to occur. Globose d une beetle has potential to occur only on the beach, and is most likely to occur near the mouth of Bell Canyon Creek, far from any proposed impacts. Therefore, the Project would not result in impacts to globose dune beetle. Although CNDDB (CDFW 2022b) includes an occurrence of Crotch bumble bee only 0.2 mile from the Project site, the maintained nature of most of the Project site likely limits available floral resources for foraging and available burrows and microhabitats such as leaf litter and woody debris that could provide opportunities for nesting and hibernation. In addition, these microhabitats would be mostly limited to areas near protect ed eucalyptus woodland along the eastern boundary of the site and scrub and riparian habitats associated with the bluffs, Devereux Creek, and Bel l Canyon Creek, where the no impacts are proposed. Also, as the Project proposes minimal new develop, from the expansion of parking eastward and creation of a new comfort station, and the biological setting would remain essentially unchanged, little to no impacts are expected to floral resources that would negatively affect Crotch bumble bee. Therefore, it is expected that the Project would not result in significant impacts to Crotch bumble bee.

Although monarch butterfly overwintering sites were not observed directly within the main areas of the Project site during surveys in 2021-2022, monarchs continue to be present within the western and eastern historic and known overwintering sites along the western and eastern boundaries of the property, which are mapped as ESHA (City of Goleta 2006; Figure 13). As described in Section 4.3.3.1, no additional potential roosting habitat occurs on the site, and therefore ESHA is limited to that shown in the General Plan/CLUP. No Project activities are proposed within 200 feet of the monarch butterfly roost in Bell Canyon to the west. The grove along the eastern boundary is adjacent to the golf course. The Conservation Element of the City’s General Plan/CLUP includes several policies for the protection of monarch butterfly roosting habitat and its designation as E SHA (Appendix A). Policies CE 4. 4, Protection of Monarch Butterfly ESHAs; C.E. 4.5, Buffers Adjacent to Monarch B utterfly ESHAs; and C.E. 4.6 Standards Applicable to New Development Adjacent to Monarch ESHAs (Appendix A) describe required protections of monarch butterfly roosting habitat. The Project avoids new development within monarch butterfly ESHA. Grading, construction of a replacement cart path, and sand -capping are proposed within the 100 -foot setback. Grading within this buffer occurs in two areas. The more northerly area, near the Hole 4 green, is in a portion of monarch butterfly ESHA where monarch butterflies have not been documented roosting. The historic monarch butterfly roosting location is farther south within this grove of trees, but not within several hundred feet of grading that will occur near the Hole 4 green. Although the second area of encroachment ( along the Hole 5 fairway) is nearer the historic roost site, no butterflies were detected roosting here during surveys. In addition, none of the activities proposed in these areas would introduce new development within the setback, and instead would result in recontouring of a portion of the existing golf course facility, new plantings within existing maintained areas, and a replacement paved cart path within existing developed golf course. No new structures are proposed. However, to ensure that project activities do not disturb roosting butterflies , MM BIO-2, MM BIO-3, MM BIO-4, MM BIO-5, MM BIO-8, MM BIO-9, and MM BIO-10 are recommended.
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MM BIO-8 Monarch Butterfly Roost Buffers. A buffer of 100- feet from the outer extent of the entire grove/tree canopy of existing and historic overwintering sites shall be established. No development or construction work activities is allowed within this buffer, unless it otherwise is allowed by the City’s General Plan/Coastal Land Use Plan (e.g., public accessways sited to avoid or minimize impacts to aggregation sites, interpretive signs which are visually unobtrusive) and authorized by the City of Goleta. Grading and other activities which alter the surface hydrology which sustains the tree groves are prohibited within the buffer , unless authorized by the City of Goleta. Fencing shall be installed along the outer boundary of the buffer zone prior to and during any grading and construction activities on site.

If an active roost or aggregation is present on the Project site, any construction grading, or other development within 200 feet of the active roost, shall be prohibited between October 1 and March 1.

MM BIO-9 Tree Removal Prohibition. Removal of vegetation within monarch ESHA is prohibited, except for minor pruning of trees or removal of dead trees and debris which pose a threat to public safety as determined by the City of Goleta.

MM BIO-10 Fall and Winter Pre-Construction Surveys. Surveys for roosting monarchs shall be conducted if work is proposed between October 1 and March 1. Between October to March a qualified biologist shall perform two site visits to docu ment the presence/absence of active roost or aggregations within the eastern and western historic monarch groves. The site visits shall be spaced sufficiently apart to capture roosting individuals during this timeframe (e.g., November and January). The sit e visits shall be conducted during a time when monarchs are present at a local reference site.

Depending on the observed monarch behavior, more than two site visits may be necessary to conclude the presence/absence of roosting monarchs throughout the season.

The surveys shall generally follow Xerces monitoring guidelines used for statewide monarch counts.

Surveys shall be conducted in the early morning starting when temperatures are low (below 55°F) and monarchs are still clustered. Surveys shall not be co nducted during heavy precipitation or strong winds. A survey report documenting the following shall be provided to the City within 24 hours of survey completion: date, weather conditions, survey times, surveying biologist, general survey methods, location of any monarchs, number of monarchs, behaviors (flying, clustering, sunning, etc.), and any recommendations.

5.3.2 California Red-Legged Frog
Protocol surveys for California red- legged frog of aquatic habitats on the Project site and within 500 feet in 2022 resulted in no observations of California red-legged frogs. However, suitable breeding habitat still occurs within the Project site in Bell Canyon Creek, approximately 550 feet from any ground disturbances associated with the Project, and less than 100 feet from sand-capping and related activities. In addition, although the golf course pond and aquatic habitat in the unnamed wetland feature near the bluff are not considered suitable breeding h abitat for California red-legged frog breeding, the species has been observed in these locations during the period when frogs are dispersing through habitats surrounding breeding ponds (Rathbun 2004). Despite recent negative surveys, California red -legged frogs may still occur in the Project vicinity , and may still breed in Bell Canyon Creek on occasion, as well as in Tecolote Creek , approximately 1,200 feet west of the Project site. Although no Project activities are proposed that would directly or indirec tly affect aquatic habitat within Bell Canyon Creek, the Project 102

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has potential to result in impacts to California red -legged frog individuals dispersing across the golf course during Project activities. Therefore, grading has potential to result in injury or mortality to California red -legged frogs, resulting in take of a federally listed species.

MM BIO-2, MM BIO-3, MM BIO-4, MM BIO-5, MM BIO-6. MM BIO-11, and MM BIO-12 are recommended to avoid impacts of California red-legged frogs, and thus avoid take of a federally listed species.

MM BIO-11 California Red-legged Frog Avoidance. To avoid the potential for take of California red -legged frog that may disperse through the Project site, all initial ground disturbing activities shall be completed in th e dry season (between June 1 and September 30), unless California red -legged frogs are determined not to be present in aquatic habitats within 300 feet of ground disturbance activities. To determine presence/absence, the qualified biologist shall conduct a survey meeting the requirements of the U.S. Fish and Wildlife Service protocol for California red-legged frog (USFWS 2005), with the final survey effort completed not sooner than 48 hours prior to the commencement of ground-disturbing activities. Initial grading activities also shall not occur after the first fall rains and before May of any year, unless it is determined through the above- described survey that California red-legged frogs are absent in aquatic habitats within 300 feet of Project activities.

If ground-disturbing activities occur during the rainy season (between October 1 and May 31) and if the National Weather Service (www.weather.gov) forecast predicts a rain event of 1⁄2 inch or more over a 48 -hour or less period for the worksite area, these activities will be halted 24 hours before the rain event is anticipated. Ground-disturbing activities, for the purposes of this protective measure, consist of grading, excavating, trenching, modifying drainages, any other mechanical disturbance of the soil, or any Project activities that include driving vehicles or equipment. Ground- disturbing activities may resume only after the site has sufficiently dried and amphibians are unlikely to be dispersing through the Project site.

After each rain event and prior to resumption of suspended Project activities, a qualified biological monitor shall inspect the entire disturbance area for California red-legged frogs. The monitor shall conduct a clearance survey involving the inspection of excavations, trenches or other topographically depressed areas that may temporarily hold rainwater, pipes, logs, debris, and any other equipment that may provide refugia for this species. If no California red -legged frogs are observed within the Project site, construction may proc eed. If a California red -legged frog is observed directly adjacent to the site, the monitor will remain on- site to monitor the individual’s movements. If a California red -legged frog is found within the Project site, the monitor will direct the construction crews away from the individual so the frog(s) may move offsite on their own accord.

No personnel or biologist will be allowed to touch the frog(s) without prior consultation with the USFWS.

In addition to the above, the following measures shall be taken:
• During evening hours and any periods when no construction activities are occurring, cover any excavations, including trenches, that could entrap California red-legged frogs. • During Project activities, regularly remove all trash from work sites, to avoid attracting predators.
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Once construction is complete, remove all trash and construction debris from work areas.

MM BIO-12 Sensitive Wildlife Survey Prior to Ground Disturbance. Prior to initiation of ground disturbances, a qualified biologist shall conduct a survey for special -status wildlife species within all areas where ground-disturbance is proposed. The survey shall focus on detecting any California red-legged frogs or western pond turtles inhabiting upland habitats, and any other terrestrial special-status wildlife than may be present. If any special-status wildlife species are detected, the qualified biologist shall implement avoidance measures, including establishing setbacks of at least 50 feet around the animal. The qualified biologist shall monitor the animal, and no Project activities may occur within the setback until the animal has left the area on its own.

5.3.3 Western Pond Turtle
Despite multiple surveys of aquatic habitats on the Project site, no western pond turtles were detected during surveys in 2021 and 2022 . However, the species has been observed recently at Tecolote Creek , approximately 1,200 feet west of the Project site, and may potentially occur in Bell Canyon Creek and occasionally occur in surrounding upland habitats, including the golf course , while dispersing to nest or take temporary shelter during winter. Generally, the relatively steep slope at the edge of the golf course and impenetrable emergent vegetation near the mouth of Bell Canyon Creek would deter western pond turtle from entering the golf course from Bell Canyon Creek. However, some possibility exists that the occasional western pond turtle could reach the golf course from near the beach. If this occurs, a western pond turtle could be injured or killed during grading on the golf course, or the nest of a western pond turtle in more natural portions of the golf course subject to grading could be destroyed.

Given the relatively low potential for this species to occur in impacts areas, the likelihood of this occurring is low.

But this impact could be considered significant.

MM BIO-2, MM BIO -3, MM BIO-4, MM BIO -5, MM BIO-6, and MM BIO-12 are recommended to avoid impacts to western pond turtle.

5.3.4 Special-Status and Common Raptor Species
Two special-status raptor species have been observed on the Project site: Cooper’s hawk and white-tailed kite. Nest of these species, including historic nests are considered ESHA under Policy CE 8.1 of the General Plan/CLUP ( City of Goleta 2006). In addition, nests of common raptor species such as red -tailed hawk are considered ESHA. Each of the species has been recorded on the Project site. Each species also has been recorded nesting on the site or in the vicinity. Historic nests of Cooper’s hawk and white- tailed kite were recorded adjacent to the site to the east (Figure 6). Red-tailed hawk nested at different locations in 2021 and 2022 (Figure 6). Project activities and new development may be prohibited within approximately 100 feet of these nest sites. In addition to potential impacts to ESHA, if any of these species is nesting at the time of grading or other Project activities, disturbance to nesting could result. Because the Project would result in little loss of natural habitat, and because conditions after Project implementation would remain similar to conditions prior to implementation, and the Project would even result in planting of additional native vegetation on the golf course, the Project would not result in significant impac ts to Cooper’s hawk or white -tailed kite foraging habitat. The Project would avoid impacts to areas within 200 feet of either of the historic nests of the species and thus would not result in impacts to ESHA or ESHA setbacks from special-status raptor nest sites. Therefore, the only potentially significant impact to these species would be impacts to nesting Cooper’s hawks and white-tailed kites. The Project proposes replacement golf cart paths near both recent 104

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nesting locations for red -tailed hawk. Project activities to establish these paths could result in impacts to nesting red-tailed hawks, if these Project activities occur during the nest season when these nest sites are active. However, the new cart path near these nests site would not result in new imp acts, if the paths are established outside the nesting period. The new paths would not establish new human disturbance in these areas, which already occur along fairways subject to regular human presence.

MM BIO-3, MM BIO-4, MM BIO-13, and MM BIO-14 are recommended to avoid impacts to nesting special-status raptors.

MM BIO-13 Pre-Project Nesting Bird Survey. Avoid initiating construction during the nesting bird season for native birds (February 1 to August 31). If construction must begin within the nesting bird season, a qualified biologist shall conduct a pre-construction survey to determine if active nests of special - status birds, or common bird species protected by the Migratory Bird Treaty Act and the California Fish and Game Code, are present in the construction zone or within 100 feet (300 feet for raptors) of the construction zone for the P roject site. The survey should occur no less than one week prior to construction or site preparation activities.

MM BIO-14 Nesting Bird Buffers and Avoidance. If active nests are found, a no-construction buffer of 100- feet (300 feet for raptors) shall be established around the nest site where it overlaps with work areas. The buffer distance may be greater or less, depending on the bird species and Project activity, as determined by the biologist. Grading, construction, or other Project activities within no- construction buffers shall be postponed or halted, at the discretion of the biologist, until the nest is vacated, young have fledged and are no longer dependent on the nest site , and there is no evidence of a second attempt at nesting. In addition, the qualified biologist shall map all active nests with geographic positioning system technology and provide the nest locations and buffers on aerial-based maps of the Project vicinity. The biologist shall regularly update maps to inform the Contractor of areas to avoid. A City-appointed biologist should also serve as a construction monitor during the breeding season to ensure that no inadvertent impacts occur to nesting birds.

5.3.5 Yellow Warbler and Other Special-Status Bird Species Yellow warbler was detected during surveys. Nesting habitat for this species is considered ESHA, according to General Plan/CLUP Policy CE 8.1. However, this species was detected on the Project site only during the migratory season for this species. This species was not detected nesting, was not detected in suitable nesting habitat, and was not present through the nesting season. Therefore, no ESHA should be established on the Project site due to presence of this species. Although suitable habitat occurs along Bell Canyon Creek and Devereux Creek, the suitable habitat does not occur in the former location within 400 feet of grading, construction activities, or any other Project activity that would result in disturbance to yellow warblers. Grading would occur within approximately 50 feet of suitable habitat at Devereux Creek. But it would not result in permanent impacts that would alter yellow warbler habitat or change the character of the area surrounding the suitable habitat. However, if grading occurs here during the nesting season when yellow warblers are present, it could result in disturbance to nesting yellow warblers, which could be considered a significant impact. Other special-status bird species may have potential to occur, and impacts to these species would be similar to those for yellow warbler.

MM BIO-3, MM BIO-4, MM BIO-13, and MM BIO-14 are recommended to avoid impacts to nesting yellow warblers and other special-status bird species.
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5.4 Impacts to Jurisdictional Waters
Table 7 provides a summary of potentially jurisdiction features. Direct impacts to aquatic resources would occur only within Devereux Creek, where the Project proposes removal of 0.02 acre of riparian vegetation due to installation of a cart path and associated bridge. Although grading does not occur within any other potentially jurisdictional resource, it occurs within the setback associated with the Golf Course Pond (Aquatic Resource C) and within 100 feet of riparian vegetation associated with Devereux Creek (Aquatic Resource B). Under Policy CE 2.2, a 100-foot setback may be reduced if there is no feasible alternative for siting and Project impacts “will not have a significant adverse effect on streamside vegetation or the biotic quality of the stream.” Therefore, areas where grading occurs less than 100 feet but more than 25 feet from riparian habitat may not be inconsistent with Policy CE 2.2. Grading occurs within 25 feet of riparian eucalyptus near the eastern boundary of the Project site (Figure 14). However, this grading occurs in an area of existing golf course development, where re -contouring and revegetation are proposed.

The Project would result in filling and grading of Aquatic Resource E, an anthropogenic stormwater drainage feature, and replacement of this feature with stormwater drainage into an onsite stormwater treatment basin. This activity would result in elimination of 0.01 acre of non-wetland waters of the State.

In addition to grading, the Project proposes sand -capping within several wetland and riparian buffers. This activity in itself would not constitute a significant impact. However, impacts could occur to wetlands or riparian habitats i f sand or chemicals from vehicles or machinery enter the sensitive aquatic resources, including Bell Canyon Creek, which is habitat for California red -legged frog and occupied critical habitat for tidewater goby, both of which are federally listed species.

To confirm whether USACE/ RWQCB and CDFW would take jurisdiction of Aquatic Resource E, an anthropogenic feature near Hollister Avenue, and impacts to 0.01 acre of potential non-wetland waters of the State would require mitigation of 5:1 (creation:impact), Dudek recommends consultation with these agencies.

Impacts to 0.02 acre of riparian vegetation subject to CCC and CDFW jurisdictions within Devereux Creek are also discussed as impacts to sensitive vegetation in Section 5.1, above. Mitigation consistent with Policy CE 1.7 should be implemented to compensate for impacts to CDFW and Coastal riparian.

MM BIO-1, MM BIO-2, MM BIO -3, MM BIO -4, MM BIO -5, MM BIO -6, and MM BIO-15 are recommended to avoid impacts to jurisdictional aquatic resources.

MM BIO-15 Avoidance of Aquatic Resources and Designated Setbacks. Avoid incidental grading or construction activities within aquatic resources and within the designated 100-foot setback for riparian or wetland habitats. All aquatic habitats and all 100 -foot riparian and wetland setbacks shall be delineated in the field, and no unplanned construction activities shall take place within these areas. 106

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5.5 Impacts to Wildlife Corridors and
Habitat Connectivity
The Project would result in redevelopment of areas already occupied by structures and other development, and current land uses would remain the same after implementation. It would therefore result in no permanent impacts to wildlife movement and habitat connectivity. Project implementation would result in some temporary disruptions to wildlife movement, but animals would continue to be able to pass through the site, even during Project implementation, during nighttime, as under current conditions . Important habitats such as Bell Canyon Creek, Devereux Creek, coastal bluff scrub and coastal sage scrub that receives protections as ESHA, and the golf course pond, would not be directly disturbed during construction, and populations of plants and animals that provide a genetic connection between undeveloped habitats to the north, east, and west, would persist. Because of the minimal impacts to wildlife movement and habitat connectivity, no measures are recommended.

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Xerces Society, Defenders of Wildlife, and the Center for Food Safety. 2018. A Petition to the State of California Fish and Game Commission to List the Crotch Bumble Bee (Bombus crotchii), Franklin’s Bumble Bee (Bombus franklini), Suckley Cuckoo Bumble Bee (Bombus suckleyi), and Western Bumble Bee (Bombus occidentalis occidentalis) as Endangered under the California Endangered Species Act. Submitted by the Xerces Society for Invertebrate Conservation, Defenders of Wildlife, and Center for Food Safety.

October 2018.

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Project Location
Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: USGS National Map
Date: 9/30/2022 - Last saved by: kzecher - Path: Z:\Projects\j1276000\MAPDOC\Biological\Figure1_ProjectLocation.mxd 02 ,0001,000
Feet
Project Boundary
FIGURE 1
Arroyo
Grande
Buellton
Carpinteria
Goleta
Grover Beach
Guadalupe
Lompoc
Maricopa
Ojai
Oxnard
Pismo Beach
Santa Barbara
Santa Maria
Solvang
Taf t
Ventura
Kern CountySan Luis
Obispo
County
Ventura
County
SANTA

BARBARA
COUNTY
Project Site
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Island
Oak L n
Las Armas Rd
Kestrel
Ln
Elderberry
Dr
Maintenance
Ya rd
Golf
Course
Pond
Clubhouse
Cathedral
O
Hollister Ave
Devereux
Creek
Bell
Canyon
Project Site
Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Sanborn 2020
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Feet
FIGURE 2
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SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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W i n c h e s te r Cir
Wajero Dr
Toura n Ln
Ca l l e R e a l
Kestrel
Ln
Pebble Beach Dr
E
lde
rberry
Dr
Maintenance
Yard
Golf
Course
Pond
Clubhouse
Hollister Ave
C
athedral
Oa
ks
R
Devereux
Creek
B
ell
C
anyo
n
Survey Areas
Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Aerial: Sanborn 2020
0 800400
Feet
Project Boundary
Raptor Survey Area and
California Red-legged Frog
Survey Area
FIGURE 3
119

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D a ytona Dr
S
anta
B
a
rb
a
r aS h ores Dr
V
e
reda
L
e
yenda
S
a
n
R
ossano
D
r
C
o ronado Dr
W
inchester
C
a
nyon
R
d
W i n c h e ster
Cir
Day Rd
S e a G u l l D r
Palo Alto Dr
B
randon
D
r
J e n n a Dr
Dartmoor Ave
Bristol Pl Surrey Pl
To u r a n L n
So m m
er
L
n
C a l l e R e a l
Kestrel
Ln
Dee
rhurst
D
r
Car l i sl e W
a
y
Saratog a C t
B
ig
S
ur
Dr
Pebble Beach Dr
E
lderberry
Dr
N e w p o r t D r
2747
3178
2745
2749
2750 2751
2744
Maintenance
Yard
Golf
Course
Pond
Clubhouse
Hollister Ave
Cathedral Oaks Rd
D
evereux
Creek
Bel l Ca n y o n
Monarch Butterfly Survey Area
Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Aerial: Sanborn 2020
01 ,000500
Feet
Project Boundary
Survey Areas
Althouse and Meade 1999 Survey Area,
with Site Number
Xerces Society Survey Area,
with Site Number
FIGURE 4
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S o r a C t
Heron Ct
Wajero Dr
Island
Oa k L n
Las Armas Rd
Kestrel Ln
Elderberry
Dr
Cathedral Oa
Hollister Ave
BP-TD
CLO
CSS
DH
EM

CBB-ABS
UM
CTM
CTM
DEV
DEV
DEVDEV
MC-MPS
MC-MPS
MC-MPS
MC-MPS
MC-MPS
MC-MPS
MC-MPS
MC-MPS
MC-MPS
ORN
ORNORN
OW
OW
WOABG
WOABG
WOABG
WOABG
WOABG
WOABG
WOABG
WOABG
WOABG
WOABG
WOABG
WOABG
WOABG
WOABG

WOABG WOABG
WOABG
IPM
IPM
QS
QS
CYS
CYS
B
B
B
DEV
EUC
EUC
EUC
EUC
EUC
EUC
EUC
EUC
EUC
EUC
EUC
EUC
PTMG
PTMG
PTMG
PTMG
QS
QS
CTM
CTM
WOABG
AWT
AWT
AWT
CYS
CYS
EUC
EUC
WOABG
WOABG
EUC
EUC
WOABG
WOABG
EUC
WOABG
EUC
WOABG
MC-MPS
MC-MPS
MC-MPS
Golf Course
NG-MGG
ORN
ORN
ORN
Vegetation Communities and Land Covers
Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Aerial: Sanborn 2020
0 440220
Feet
FIGURE 5
Project Boundary
Vegetation Communities
AWT : Arroyo willow thickets Alliance
UM : Upland mustards or star-thistle fields Semi-
Natural Alliance
BP-TD : Baccharis pilularis - T oxicodendron
diversilobum Association
CBB-ABS : California brittle bush - Ashy buckwheat
scrub Alliance
CLO : Coast live oak woodland Alliance
CSS : Coastal sage scrub
CTM : Cattail marshes Alliance
CYS : Coyote brush scrub Alliance
EM : Emergent Wetland
EUC : Eucalyptus ( globulus, camaldulensis )
Provisional Semi-natural Association
IPM : Ice plant mats Semi-Natural Alliance
MC-MPS : Monterey cypress - Monterey pine stands
Semi-Natural Alliance
NG-MGG : Needle grass - Melic grass grassland
Alliance
PTMG : Pepper tree or Myoporum groves Semi-
Natural Alliance
QS : Quailbush scrub Alliance
WOABG : Wild oats and annual brome grasslands
Semi-Natural Alliance
Land Covers
B : Beach
DEV : Urban/Developed
DH : Disturbed Habitat
Golf Course : Golf Course - Developed
ORN : Parks and ornamental plantings
OW : Open water
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C
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B
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ll
C
a
n
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o
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W i n c h e st e r Ci r
Wajero Dr
Toura n L n
Island
Oak L n
Las Armas Rd
C a l l e Re a l
Ke strel
Ln
Elderberry
Dr
(2021)
(2020)
(2022)
C
athedral
O
aks
R
d
Hollister Ave
Raptor Survey Results
Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Aerial: Sanborn 2020
0 540270
Feet
FIGURE 6
Project Boundary
Raptor Survey Area
RaptorSurveyResults
Red-tailed hawk
Perching
Nest
Red-shouldered hawk
Calling
Perching
Nest (unsuccessful)
Cooper’s hawk
Perching
Nest (historic)
Great horned owl
Fledgling
White-tailed kite
Nest (historic)
125

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NG_13
NG_02 NG_05
NG_06
NG_16
NG_12
NG_11
NG_01
NG_10
NG_04
NG_15
NG_03
NG_14
NG_08
NG_09
NG_32
Native Grassland Assessment
Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Aerial: Sanborn 2020
0 12562.5
Feet
FIGURE 7A
7 B
7A
Project Boundary
Native Grassland Transects
Transect
Transect Start
Transect End
Native Grassland Assessment Results
Needle Grass Grassland
(native grassland)
Native Grass Area (Does not meet
native grassland criteria)
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NG_21
NG_29
NG_31
NG_24
NG_17
NG_26
NG_27
NG_20
NG_30
NG_22
NG_18
NG_23
NG_28
NG_25
Native Grassland Assessment
Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Aerial: Sanborn 2020
0 12562.5
Feet
FIGURE 7 B
7 B
7A
Project Boundary
Native Grassland Transects
Transect
Transect Start
Transect End
Native Grassland Assessment Results
Needle Grass Grassland
(native grassland)
Native Grass Area (Does not meet
native grassland criteria)
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B
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C
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S o r a C t
Heron Ct
Wajero Dr
Island
Oa k L n
Las Armas Rd
Kestrel
Ln
Elderberry
Dr
Cathedral Oa
Hollister Ave
Special-Status Plant Survey Results
Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Aerial: Sanborn 2020
0 430215
Feet
FIGURE 8
Project Boundary
Special-Status Plant Results
Cliff malacothrix (Malacothrix saxatilis
var.saxatilis)
Red sand-verbena (Abronia maritima)
Santa Barbara honeysuckle (Lonicera
subspicata var.subspicata)
Southern California black walnut
(Juglans californica)
Woolly seablite (Suaeda taxifolia)
130

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101
S
anta
B
a
rb
a
ra Shores Dr
Anchor Dr
Lancaster Pl
San
R
ossa
no
D
r
C
oro nado Dr
S e a G u l l D r
Winchester Canyon Rd
W i n c h e st e r Cir
Day Rd
Palo Alto Dr
S
a
n
Ferm
o
D
r
Brandon
D
r
Wajero Dr
Dartmoor Ave
Bristol Pl Surrey Pl
T o u r a n L n
Island
O
ak L n
Deerh
urst
D
r Ca r li sl e W a y
So m m e r
L
n
Las Armas Rd
Ca l l e R e a l
Hempst e a d A v e
Kestrel
Ln
Vereda
L
ey e
nda
S
arat o g a C t
B
igS u r D r
Pebble Beach Dr
Elderberry
Dr
Ne w p o r t D r
2747
31782745
2749
2750 2751
2744
Maintenance
Yard
Golf
Course
Pond
Clubhouse
Hollister Ave
Cathedr al Oaks Rd
Devereux
Creek
Bel l Canyon
Monarch Butterfly Survey Results
Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Aerial: Sanborn 2020
0 690345
Feet
FIGURE 9
Project Boundary
Survey Areas
Althouse and Meade 1999 Survey
Area, with Site Number
Xerces Society Survey Area,
with Site Number
Survey Results
Monarch Butterfly (in flight)
Monarch Butterfly (clusters)
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W i n c h e st e r Ci r
Heron Ct
Wajero Dr
Tou r a n Ln
Island
Oa k L n
Las Armas Rd
C a l l e Re a l
Kestrel Ln
Elderberry
Dr
Golf
Course
Pond
Bell Creek
Unnamed
Wetland
Hollister Ave
C
athedral
Oa
ks
R
d
Devereux
Creek
Tecolote
C
anyo
n
B
ell
C
a n
yon
California Red-Legged Frog Survey Results
Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Aerial: Sanborn 2020
0 480240
Feet
FIGURE 10
Project Boundary
California Red-legged Frog Survey
Area (500-foot Radius of Project Site)
Survey Locations
California Red-Legged Frog
(historical occurrence)
Breeding
Non-breeding
134

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C
r eek
B
ell
C
a
n
y
o
n
T
e
c
o
lo
te
C
a
n
y
o
n
W i n c h e st e r Ci r
Wajero Dr
Island
Oak L n
Las Armas Rd
Toura n L nCa l l e Re a l
Ke strel
Ln
Elderberry
Dr
Hollister Ave
C
athedral
Oa
ks
R
d
Other Special-Status Wildlife Species Observations
Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Aerial: Sanborn 2020
0 500250
Feet
FIGURE 11
Project Boundary
Other Special-Status Wildlife Species
Observations
California brown pelican
Yellow-headed blackbird
Globose dune beetle
Tidewater goby
136

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Date: 10/1/2022 - Last saved by: kzecher - Path: Z:\Projects\j1276000\MAPDOC\Biological\Figure12_AquaticResourcesDelineatio n2.mxd Aquatic Resource E
Figure 12E
Aquatic Resource D
Figure 12D
Aquatic Resource F
Figure 12F
Aquatic Resource A
Bell Canyon Creek
Figure 12A
Aquatic Resource B
Devereux Creek
Figure 12B
Aquatic Resource C
Golf Course Pond
Figure 12C
D
e
v
e
re
u
x
C
re
e
k
B
e
ll
C
a
n
y
o
n
S o r a C t
Heron Ct
Wajero Dr
Island
Oa k L n
Las Armas Rd
Kestrel
Ln
Elderberry
Dr
WSP-01
WSP-03
WSP-02
WSP-08
WSP-09
WSP-06
WSP-04
WSP-05
WSP-07
WET-HLM-01
RIP-RFS-01
RIP-RFS-03
RIP-RFS-02
RIP-RFS-04
NWW-HLM-06
PIPE-RFS-01
UPS-RFS-02
USW-HLM-01
USW-HLM-03
USW-HLM-05
NWW-HLM-03
NWW-HLM-04
NWW-HLM-01
NWW-HLM-02
NWW-HLM-05
RIP-RFS-05
NWW-HLM-08
NWW-HLM-09
WET-HLM-06
WET-HLM-05
USW-HLM-02
WET-HLM-07
Cathedral Oaks
Hollister Ave
Aquatic Resources Delineation
Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Aerial: Sanborn 2020
0 460230
Feet
FIGURE 12
Project Boundary
Aquatic Resource Area Inset Map Index
Aquatic Resource
Wetland Sampling Point
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C a
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o
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WSP-01
RIP-RFS-05
NWW-HLM-08
NWW-HLM-09
WET-HLM-06
WET-HLM-05
Aquatic Resource A - Bell Canyon Creek
Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Aerial: Sanborn 2020
0 14070
Feet
FIGURE 12A
Project Boundary
Potential Jurisdictional Aquatic
Resources
U.S. Army Corps of Engineers
Wetland Waters of the U.S.

Non-Wetland Waters of the U.S.

Regional Water Quality Control Board
Wetland Waters of the State -
Stream Channel
Non-Wetland Waters of the State -
Stream Channel
California Department of Fish and
Wildlife
Riparian Area
Streambed
California Coastal Commission/
City of Goleta
Wetland
Riparian
Other Features
Wetland Sampling Point
101
E
D
F
A
B
C
139
/68/97/116/101/58/32/49/48/47/49/47/50/48/50/50/32/32/45/32/32/76/97/115/116/32/115/97/118/101/100/32/98/121/58/32/107/122/101/99/104/101/114/32/32/45/32/32/80/97/116/104/58/32/90/58/92/80/114/111/106/101/99/116/115/92/106/49/50/55/54/48/48/48/92/77/65/80/68/79/67/92/66/105/111/108/111/103/105/99/97/108/92/70/105/103/117/114/101/49/50/65/45/70/95/65/82/68/73/110/115/101/116/115/50/46/109/120/100 D
e
v
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re
u
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C
re
e
k
S o r a C t
Wajero Dr
Heron Ct
Isla
n
d
Oa k L n
Ke strel Ln
Elderberry
Dr
WSP-08
WSP-09
WSP-06
WSP-04
WSP-05
WSP-07
CUL-RFS-02
CUL-RFS-03
CUL-RFS-06
CUL-RFS-08
CUL-RFS-07
RIP-RFS-01
RIP-RFS-03
RIP-RFS-02
RIP-RFS-04
NWW-HLM-05
NWW-HLM-06
USW-HLM-05
NWW-HLM-03
USW-HLM-02
T-NWW-HLM-03
T-NWW-HLM-05
T-NWW-HLM-06
Hollister Ave
/65/113/117/97/116/105/99/32/82/101/115/111/117/114/99/101/32/66/32/8211/32/68/101/118/101/114/101/117/120/32/67/114/101/101/107/32 /66/105/111/108/111/103/105/99/97/108/32/82/101/115/111/117/114/99/101/115/32/65/115/115/101/115/115/109/101/110/116/32/82/101/112/111/114/116/32/102/111/114/32/116/104/101/32/83/97/110/100/112/105/112/101/114/32/71/111/108/102/32/67/108/117/98/32/80/114/111/106/101/99/116 /83/79/85/82/67/69/58/32/65/101/114/105/97/108/58/32/83/97/110/98/111/114/110/32/50/48/50/48 /48 /50/57/48/49/52/53
/70/101/101/116
FIGURE 12B
Project Boundary
Potential Jurisdictional Aquatic
Resources
U.S. Army Corps of Engineers
Non-Wetland Waters of the U.S.

Regional Water Quality Control Board
Non-Wetland Waters of the State -
Stream Channel
California Department of Fish and
Wildlife
Riparian Area
Streambed
California Coastal Commission/
City of Goleta
Wetland
Riparian
Other Features
Culvert
Wetland Sampling Point
OHWM Transects
Swale
101
E
D
F
A
B
C
140
/68/97/116/101/58/32/49/48/47/49/47/50/48/50/50/32/32/45/32/32/76/97/115/116/32/115/97/118/101/100/32/98/121/58/32/107/122/101/99/104/101/114/32/32/45/32/32/80/97/116/104/58/32/90/58/92/80/114/111/106/101/99/116/115/92/106/49/50/55/54/48/48/48/92/77/65/80/68/79/67/92/66/105/111/108/111/103/105/99/97/108/92/70/105/103/117/114/101/49/50/65/45/70/95/65/82/68/73/110/115/101/116/115/50/46/109/120/100 WET-HLM-07
/65/113/117/97/116/105/99/32/82/101/115/111/117/114/99/101/32/67/32/8211/32/71/111/108/102/32/67/111/117/114/115/101/32/80/111/110/100 /66/105/111/108/111/103/105/99/97/108/32/82/101/115/111/117/114/99/101/115/32/65/115/115/101/115/115/109/101/110/116/32/82/101/112/111/114/116/32/102/111/114/32/116/104/101/32/83/97/110/100/112/105/112/101/114/32/71/111/108/102/32/67/108/117/98/32/80/114/111/106/101/99/116 /83/79/85/82/67/69/58/32/65/101/114/105/97/108/58/32/83/97/110/98/111/114/110/32/50/48/50/48 /48 /53/48/50/53
/70/101/101/116
FIGURE 12C
Project Boundary
Regional Water Quality Control Board
Wetland Waters of the State - Wetland
California Department of Fish and
Wildlife
Lake
California Coastal Commission/
City of Goleta
Wetland
101
E
D
F
A
B
C
141
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NWW-HLM-02
T-NWW-HLM-02
Aquatic Resource D
Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Aerial: Sanborn 2020
0 2010
Feet
FIGURE 12D
Project Boundary
Potential Jurisdictional Aquatic
Resources
U.S. Army Corps of Engineers
Non-Wetland Waters of the U.S.

Regional Water Quality Control Board
Non-Wetland Waters of the State -
Stream Channel
California Department of Fish and
Wildlife
Streambed
California Coastal Commission/
City of Goleta
Wetland
Other Features
Wetland Sampling Point
OHWM Transects
Swale
Pipe
101
E
D
F
A
B
C
142
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NWW-HLM-01
USW-HLM-01
T-NWW-HLM-01
Aquatic Resource E
Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Aerial: Sanborn 2020
0 2010
Feet
FIGURE 12E
Project Boundary
Potential Jurisdictional Aquatic Resources
Regional Water Quality Control Board
Non-Wetland Waters of the State -
Stream Channel
California Department of Fish and
Wildlife
Streambed
Other Features
Culvert
OHWM Transects
Swale
101
E
D
F
A
B
C
143
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WET-HLM-01
USW-HLM-03
NWW-HLM-04
T-NWW-HLM-04
Aquatic Resource F
Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Aerial: Sanborn 2020
0 4020
Feet
FIGURE 12F
Project Boundary
Potential Jurisdictional Aquatic
Resources
U.S. Army Corps of Engineers
Wetland Waters of the U.S.

Non-Wetland Waters of the U.S.

Regional Water Quality Control Board
Wetland Waters of the State -
Stream Channel
Non-Wetland Waters of the State -
Stream Channel
California Department of Fish and
Wildlife
Streambed
California Coastal Commission/
City of Goleta
Wetland
Other Features
Culvert
OHWM Transects
Swale
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SANDPIPER GOLF CLUB PROJECT / BIOLOGICAL RESOURCES ASSESSMENT REPORT

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Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Aerial: Sanborn 2020
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FIGURE 13
Project Boundary
Sensitive Biological Resources
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Purple Needle Grass Grassland
Coastal Bluff Scrub/Coastal Sage Scrub
Riparian
Monarch Butterfly Roosting Habitat
Cliff malacothrix
Red sand-verbena
Santa Barbara honeysuckle
Southern California black walnut
Woolly seablite
White-tailed kite Nest (historic)
Coastal Wetland
Open Water
Sensitive Biological Resources
(Non-ESHA)
Golf Course Water Feature
Coastal Wetland
Open Water
City of Goleta
Red-tailed hawk Nest (date)
Cooper’s hawk Nest (historic)
CNDDB
CNDDB Red-Legged Frog (historic)
Setbacks
Purple Needle Grass Grassland 10-foot
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Sensitive Scrub 25-foot Setback
Riparian 100-foot Setback
Riparian 25-foot Minimum Setback
Monarch Butterfly Roosting Habitat 100-foot
Setback
Monarch Butterfly Roosting Habitat 50-foot
Minimum Setback
Coastal Wetland/Open Water 100-foot
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Coastal Wetland 50-foot Minimum Setback
Raptor Nest 100-foot Setback
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Biological Resources Assessment Report for the Sandpiper Golf Club Project SOURCE: Aerial: Sanborn 2020
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Project Boundary
Proposed Project Impacts
Grading
Structures
Sand-capping
Cart Path
Cart Bridge
Sensitive Biological Resources
(ESHA)
Purple Needle Grass Grassland
Coastal Bluff Scrub/Coastal Sage Scrub
Riparian
Monarch Butterfly Roosting Habitat
Cliff malacothrix
Red sand-verbena
Santa Barbara honeysuckle
Southern California black walnut
Woolly seablite
White-tailed kite Nest (historic)
Coastal Wetland
Open Water
Sensitive Biological Resources
(Non-ESHA)
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Coastal Wetland
Open Water
City of Goleta
Red-tailed hawk Nest (date)
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CNDDB
CNDDB Red-Legged Frog (historic)
Setbacks
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Riparian 100-foot Setback
Riparian 25-foot Minimum Setback
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Monarch Butterfly Roosting Habitat 50-foot
Minimum Setback
Coastal Wetland/Open Water 100-foot
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Coastal Wetland 50-foot Minimum Setback
Raptor Nest 100-foot Setback
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Appendix A
Local Policies
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ATTACHMENT A

LOCAL POLICIES
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A-1 August 2023
The City of Goleta adopted the Goleta General Plan/Coastal Land Use Plan in 2006 (City of Goleta 2006). The General Plan/Coastal Land Use Plan aims to create a coherent vision of the City’s future that forms the foundation for the General Plan’s goals, objectives, and policies. The General Plan/Coastal Land Use Plan Conservation Element includes a focus on preserving, protecting, and enhancing the City’s natural resources. Policies relevant Sandpiper Golf Club are described below.

Policy CE 1: Environmentally Sensitive Habitat Area Designations and Policy [GP/CP] CE 1.1 Definition of Environmentally Sensitive Habitat Areas. [GP/CP] ESHAs shall include, but are not limited to, any areas that through professional biological evaluation are determined to meet the following criteria:
a. Any area in which plant or animal life or their habitats are either rare or especially valuable because of their special nature or role in an ecosystem and that could be easily disturbed or degraded by human activities and developments.
b. Any area that includes habitat for species and plant communities recognized as threatened or endangered by the state or federal governments; plant communities recognized by the State of California (in the Terrestrial Natural Communities Inventory) as restricted in distribution and very threatened; and those habitat types of limited distribution recognized to be of particular habitat value, including wetlands, riparian vegetation, eucalyptus groves associated with monarch butterfly roosts, oak woodlands, and savannas.
c. Any area that has been previously designated as an ESHA by the California Coastal Commission, the California Department of Fish and Game, City of Goleta, or other agency with jurisdiction over the designated area.

CE 1.2 Designation of Environmentally Sensitive Habitat Areas. [GP/CP] ESHAs in Goleta are generally shown in Figure 4-1, and Table 4-2 provides examples of the ESHAs and some locations of each.

The provisions of this policy shall apply to all designated ESHAs. ESHAs generally include but are not limited to the following:
a. Creek and riparian areas.
b. Wetlands, such as vernal pools.
c. Coastal dunes, lagoons or estuaries, and coastal bluffs/coastal bluff scrub. d. Beach and shoreline habitats.
e. Marine habitats.
f. Coastal sage scrub and chaparral.
g. Native woodlands and savannahs, including oak woodlands. h. Native grassland.
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i. Monarch butterfly aggregation sites, including autumnal and winter roost sites, and related habitat areas.
j. Beach and dune areas that are nesting and foraging locations for the western snowy plover. k. Nesting and roosting sites and related habitat areas for various species of raptors. l. Other habitat areas for species of wildlife or plants designated as rare, threatened, or endangered under state or federal law.
m. Any other habitat areas that are rare or especially valuable from a local, regional, or statewide perspective.

CE 1.6 Protection of ESHAs. [GP/CP] ESHAs shall be protected against significant disruption of habitat values, and only uses or developm ent dependent on and compatible with maintaining such resources shall be allowed within ESHAs or their buffers. The following shall apply:
a. No development, except as otherwise allowed by this element, shall be allowed within ESHAs and/or ESHA buffers.
b. A setback or buffer separating all permitted development from an adjacent ESHA shall be required and shall have a minimum width as set forth in subsequent policies of this element.

The purpose of such setbacks shall be to prevent any degradation of the ecologi cal functions provided by the habitat area.
c. Public accessways and trails are considered resource-dependent uses and may be located within or adjacent to ESHAs. These uses shall be sited to avoid or minimize impacts on the resource to the maximum extent fe asible. Measures — such as signage, placement of boardwalks, and limited fencing or other barriers— shall be implemented as necessary to protect ESHAs.
d. The following uses and development may be allowed in ESHAs or ESHA buffers only where there are no feasible, less environmentally damaging alternatives and will be subject to requirements for mitigation measures to avoid or lessen impacts to the maximum extent feasible: 1) public road crossings, 2) utility lines, 3) resource restoration and enhancement projects, 4) nature education, 5) biological research, and 6) Public Works projects as identified in the Capital Improvement Plan, only where there are no feasible, less environmentally damaging alternatives.
e. If the provisions herein would result in any legal pa rcel created prior to the date of this plan being made unusable in its entirety for any purpose allowed by the land use plan, exceptions to the foregoing may be made to allow a reasonable economic use of the parcel. Alternatively, the City may establish a program to allow transfer of development rights for such parcels to receiving parcels that have areas suitable for and are designated on the Land Use Plan map for the appropriate type of use and development.
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CE 1.7 Mitigation of Impacts to EHSAs. [GP/CP] New development shall be sited and designed to avoid impacts to ESHAs. If there is no feasible alternative that can eliminate all impacts, then the alternative that would result in the fewest or least significant impacts shall be selected. Any impacts that cannot be avoided shall be fully mitigated, with priority given to onsite mitigation. Offsite mitigation measures shall only be approved when it is not feasible to fully mitigate impacts on site.

If impacts to onsite ESHAs occur in the Coastal Zone, any offsite mitigation area shall also be located within the Coastal Zone. All mitigation sites shall be monitored for a minimum period of 5 years following completion, with changes made as necessary based on annual monitoring reports.

Where appropriate, mitigation sites shall be subject to deed restrictions. Mitigation sites shall be subject to the protections set forth in this plan for the habitat type unless the City has made a specific determination that the mitigation is unsuccessful and is to be discontinued.

CE 1.8 ESHA Buffers. [GP/CP] Development adjacent to an ESHA shall minimize impacts to habitat values or sensitive species to the maximum extent feasible. Native vegetation shall be provided in buffer areas to serve as transitional habitat. All buffers shall be of a sufficient size to ensure the biological integrity and preservation of the ESHA they are designed to protect.

CE 1.9 Standards Applicable to Development Projects. [GP/CP] The following standards shall apply to consideration of developments within or adjacent to ESHAs:
a. Site designs shall preserve wildlife corridors or habitat networks. Corridors shall be of sufficient width to protect habitat and dispersal zones for small mammals, amphibians, reptiles, and birds.
b. Land divisions for parcels within or adjacent to an ESHA shall only be allowed if each new lot being created, except for open space lots, is capable of being developed without building in any ESHA or ESHA buffer and without any need for impacts to ESHAs related to fuel modification for fire safety purposes.
c. Site plans and landscaping shall be designed to protect ESHAs. Landscaping, screening, or vegetated buffers shall retain, salvage, and/or reestablish vegetation that supports wildlife habitat whenever feasible. Development within or adjacent to wildlife habitat networks shall incorporate design techniques that protect, support, and enhance wildlife habitat values.

Planting of nonnative, invasive species shall not be allowed in ESHAs and buffer areas adjacent to ESHAs.
d. All new development shall be sited and designed so as to minimize grading, alteration of natural landforms and physical features, and vegetation clearance in order to reduce or avoid soil erosion, creek siltation, increased runoff, and reduced infiltration of stormwater and to prevent net increases in baseline flows for any receiving water body. e. Light and glare from new development shall be controlled and directed away from wildlife habitats. Exterior night lighting shall be minimized, restricted to low intensity fixtures, shielded, and directed away from ESHAs.
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f. All new development should minimize potentially significant noise impacts on special- status species in adjacent ESHAs.
g. All new development shall be sited and designed to minimize the need for fuel modification, or weed abatement, for fire safety in order to preserve native and/or nonnative supporting habitats. Development shall use fire resistant materials and incorporate alternative measures, such as firewalls and landscaping techniques, that will reduce or avoid fuel modification activities.
h. The timing of grading and construction activities shall be controlled to minimize potential disruption of wildlife during critical time periods such as nesting or breeding seasons. i. Grading, earthmoving, and vegetation clearance adjacent to an ESHA shall be prohibited during the rainy season, generally from November 1 to March 31, except as follows: 1) where erosion control measures such as sediment basins, silt fencing, sandbagging, or installation of geofabrics have been incorpor ated into the project and approved in advance by the City; 2) where necessary to protect or enhance the ESHA itself; or 3) where necessary to remediate hazardous flooding or geologic conditions that endanger public health and safety. j. In areas that are not adjacent to ESHAs, where grading may be allowed during the rainy season, erosion control measures such as sediment basins, silt fencing, sandbagging, and installation of geofabrics shall be implemented prior to and concurrent with all grading operations.

Policy CE 2: Protection of Creeks and Riparian Areas [GP/CP] CE 2.1 Designation of Protected Creeks. [GP/CP] The provisions of this policy shall apply to creeks shown in Figure 4-1. These watercourses and their associated riparian areas are defined as ESHAs. They serve as habitat for fish and wildlife, provide wildlife movement corridors, provide for the flow of stormwater runoff and floodwaters, and furnish open space and passive recreational areas for city residents.

CE 2.2 Streamside Protection Areas. [GP/CP] A streamside protection area (SPA) is hereby established along both sides of the creeks identified in Figure 4 -1. The purpose of the designation shall be to preserve the SPA in a natural state in order to protect the as sociated riparian habitats and ecosystems. The SPA shall include the creek channel, wetlands and/or riparian vegetation related to the creek hydrology, and an adjacent upland buffer area. The width of the SPA upland buffer shall be as follows:
a. The SPA upland buffer shall be 100 feet outward on both sides of the creek, measured from the top of the bank or the outer limit of wetlands and/or riparian vegetation, whichever is greater. The City may consider increasing or decreasing the width of the SPA upland buffer on a case-by-case basis at the time of environmental review. The City may allow portions of a SPA upland buffer to be less than 100 feet wide, but not less than 25 feet wide, based on a site specific assessment if (1) there is no feasible alternative siting for development that will avoid the SPA upland buffer; and (2) the project’s impacts will not have significant adverse effects on streamside vegetation or the biotic quality of the stream. 152

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b. If the provisions above would result in any legal parcel created prior to the date of this plan being made unusable in its entirety for any purpose allowed by the land use plan, exceptions to the foregoing may be made to allow a reasonable Goleta General Plan/Coastal Land Use Plan 4.0 Conservation Element September 2006 4-14 economic use of the parcel, subject to approval of a conditional use permit.

CE 2.3 Allowable Uses and Activities in Streamside Protection Areas. [GP/CP] The following compatible land uses and activities may be allowed in SPAs, subject to all other policies of this plan, including those requiring avoidance or mitigation of impacts:

a. Agricultural operations, provided they are compatible with preservation of riparian resources. b. Fencing and other access barriers along property boundaries and along SPA boundaries. c. Maintenance of existing roads, driveways, utilities, structures, and drainage improvements. d. Construction of public road crossings and utilities, provided that there is no feasible, less environmentally damaging alternative.
e. Construction and maintenance of foot trails, bicycle paths, and similar low-impact facilities for public access.
f. Resource restoration or enhancement projects.
g. Nature education and research activities.
h. Low-impact interpretive and public access signage.
i. Other such Public Works projects as identified in the Capital Improvement Plan, only where there are no feasible, less environmentally damaging alternatives.

CE 2.5 Maintenance of Creeks as Natural Drainage Systems. [GP/CP] Creek banks, creek channels, and associated riparian areas shall be maintained or restored to their natural condition wherever such conditions or opportunities exist. Creeks carry a significant amount of Goleta’s stormwater flows.

The following standards shall apply:
j. a. The capacity of natural drainage cou rses shall not be diminished by development or other activities.
k. b. Drainage controls and improvements shall be accomplished with the minimum vegetation removal and disruption of the creek and riparian ecosystem that is necessary to accomplish the drainage objective.
l. c. Measures to stabilize creek banks, improve flow capacity, and reduce flooding are allowed but shall not include installation of new concrete channels, culverts, or pipes except at street crossings, unless it is demonstrated that there is no feasible alternative for improving capacity. 153

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m. d. Drainage controls in new development shall be required to minimize erosion, sedimentation, and flood impacts to creeks. Onsite treatment of stormwater through retention basins, infiltration, vegetated swales, and other best management practices (BMPs) shall be required in order to protect water quality and the biological functions of creek ecosystems. n. e. Alteration of creeks for the purpose of road or driveway crossings shall be prohibited except where the alteration is not substantial and there is no other feasible alternative to provide access to new development on an existing legal parcel. Creek crossings shall be accomplished by bridging and shall be designed to allow the passage of fish and wildlife. Br idge abutments or piers shall be located outside creek beds and banks, unless an environmentally superior alternative exists. (Amended by Reso. 09-59, 11/17/09)
Policy CE 3: Protection of Wetlands [GP/CP]
CE 3.1 Definition of Wetlands. [GP/CP] Wetlands are defined as any area that meets the definition of a wetland as defined by the California Coastal Commission, California Department of Fish and Game, and U.S. Fish and Wildlife Service. The most protective of definitions shall be applied and used to determine the boundary of a wetland. The City of Goleta uses the identification of a single indicator (soil, hydrology, or plants) to determine the boundary of a wetland.

CE 3.2 Designation of Wetland ESHAs. [GP/CP] Wetland ESHAs are included on Figure 4-1. In the Coastal Zone, wetlands are lands that may be covered periodically or permanently with shallow water and include saltwater marshes, freshwater marshes, open or closed brackish water marshes, swamps, mudflats, and fens. Goleta’s wetlands are associated with small lagoons at the mouths of Bell Canyon and Tecolote Creeks, vernal pools, and freshwater marshes and ponds or impoundments, such as Lake Los Carneros. All wetlands are defined as ESHAs. Any unmapped areas that meet the criteria identified in CE 3.1 are wetlands and shall be granted all of the protections for wetlands set forth in this plan.

CE 3.4 Protection of Wetlands in the Coastal Zone. [CP] The biological productivity and the quality of wetlands shall be protected and, where feasible, restored in accordance with the federal and state regulations and policies that apply to wetlands within the Coastal Zone. Only uses permitted by the regulating agencies shall be allowed within wetlands. The filling, diking, or dredging of open coastal waters, wetlands, estuaries, and lakes is prohibited unless it can be demonstrated that:
a. There is no feasible, environmentally less damaging alternative to wetland fill. b. The extent of the fill is the least amount necessary to allow development of the permitted use. c. Mitigation measures have been provided to minimize adverse environmental effects. d. The purposes of the fill are limited to: incidental public services, such as burying cables or pipes; restoration of wetlands; and nature study, education, or similar resource-dependent activities.

A wetland buffer of a sufficient size to ensure the biological integrity and preservation of the wetland shall be required. Generally the required buffer shall be 100 feet, but in no case sha ll 154

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wetland buffers be less than 50 feet. The buffer size should take into consideration the type and size of the development, the sensitivity of the wetland resources to detrimental edge effects of the development to the resources, natural features such as topography, the functions and values of the wetland, and the need for upland transitional habitat. A 100 -foot minimum buffer area shall not be reduced when it serves the functions and values of slowing and absorbing flood waters for flood and erosion control, sediment filtration, water purification, and ground water recharge. The buffer area shall serve as transitional habitat with native vegetation and shall provide physical barriers to human intrusion.

CE 3.7 Lagoon Protection. [GP/CP] The lagoons at the mouths of Bell Canyon and Tecolote Creeks shall be protected. Lagoon breaching or water level modification shall not be allowed.

Policy CE 4: Protection of Monarch Butterfly Habitat Areas [GP/CP] CE 4.1 Definition of Habitat Area. [GP/CP] The monarch butterfly is recognized as a California and Goleta special resource. Although the species is not threatened with extinction, its autumnal and winter aggregation sites, or roosts, are especially vulnerable to disturbance. Sites that provide the key elements essential for successful monarch butterfly aggregation areas and are locations where monarchs have been historically present shall be considered ESHAs. These elements include stands of eucalyptus or other suitable trees that offer shelter from strong winds and storms, provide a microclimate with adequate sunlight, are situated near a source of water or moisture, and that provide a source of nectar to nourish the butterflies.

CE 4.2 Designation of Monarch Butterfly ESHAs. [GP/CP] Existing and known historical monarch roost sites, as shown on Figure 4 -1, are hereby designated as ESHAs. These include about 20 known roosts, eight of which comprise the Ellwood Complex, a series of sites within a network consisting of eucalyptus groves and windrows interspersed by open fields and crossed by small creeks. This network includes several separate but interconnected autumnal and winter roost sites. The Ellwood Main site, the largest roost in Santa Barbara County and one of the largest in the state, occupies a site along Devereux Creek in the Sperling Preserve, a City -owned tract situated near the coastal bluffs in western Goleta.

CE 4.4 Protection of Monarch Butterfly ESHAs. [GP/CP] Monarch butte rfly ESHAs shall be protected against significant disruption of habitat values, and only uses or development dependent on and compatible with maintaining such resources shall be allowed within these ESHAs or their buffer areas. The following standards shall apply:
a. No development, except as otherwise allowed by this policy, shall be allowed within monarch butterfly ESHAs or ESHA buffers.
b. Since the specific locations of aggregation sites may vary from one year to the next, the focus of protection shall be the entire grove of trees rather than individual trees that are the location of the roost.
c. Removal of vegetation within monarch ESHAs shall be prohibited, except for minor pruning of trees or removal of dead trees and debris that are a threat to public safety. 155

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d. Public accessways are considered resource- dependent uses and may be located within a monarch ESHA or its buffer; however, such accessways shall be sited to avoid or minimize impacts to aggregation sites.
e. Interpretative signage is allowed within a monarch ESHA or its buffer, but shall be designed to be visually unobtrusive.
f. Butterfly research, including tree disturbance or other invasive methods, may be allowed subject to City approval of a permit.

CE 4.5 Buffers Adjacent to Monarch Butterfly ESHAs. [GP/CP ] A buffer of a sufficient size to ensure the biological integrity and preservation of the monarch butterfly habitat, including aggregation sites and the surrounding grove of trees, shall be required. Buffers shall not be less than 100 feet around existing and historic roost sites as measured from the outer extent of the tree canopy. The buffer area shall serve as transitional habitat with native vegetation and shall provide physical barriers to human intrusion. The buffer may be reduced to 50 feet in circumstances where the trees contribute to the habitat but are not considered likely to function as an aggregation site, such as along narrow windrows. Grading and other activities that could alter the surface hydrology that sustains the groves of trees are prohibited within or adjacent to the buffer area.

CE 4.6 Standards Applicable to New Development Adjacent to Monarch ESHAs. [GP/CP] The following standards shall apply to consideration of proposals for new development adjacent to monarch ESHAs or ESHA buffers:
a. A site-specific biological study, prepared by an expert approved by the City who is qualified by virtue of education and experience in the study of monarch butterflies, shall be required to be submitted by the project proponent.
b. The study shall include preparation of a Monarch Butterfly Habitat Protection Plan, which at a minimum shall include: 1) the mapped location of the cluster of trees where monarchs are known, or have been known, to roost in both autumnal and over-wintering aggregations; 2) an estimate of the size of the population within the colony; 3) the mapped extent of the entire habitat area; and 4) the boundaries of the buffer zone around the habitat area. c. A temporary fence shall be installed along the outer boundary of the buffer zone prior to and during any grading and construction activities on the site. d. If an active roost or aggregation is present on the project site, any construction grading, or other development within 200 feet of the active roost, shall be prohibited between Oct ober 1 and March 1.

Policy CE 5: Protection of Other Terrestrial Habitat Areas [GP/CP] CE 5.1 Designation of Other Terrestrial ESHAs. [GP/CP] The following habitats, which are not specifically included in other policies, are hereby designated ESHAs:
a. Native grasslands.
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b. Coastal bluff scrub, coastal sage-scrub, and chaparral.

CE 5.2 Protection of Native Grasslands. [GP/CP] In addition to the provisions of Policy CE 1, the following standards shall apply:
a. For purposes of this policy, existing native grasslands are defined as an area where native grassland species comprise 10 percent or more of the total relative plant cover. Native grasslands that are dominated by perennial bunch grasses tend to be patchy. Where a high density of separate small patches occurs i n an area, the whole area shall be delineated as native grasslands.
b. To the maximum extent feasible, development shall avoid impacts to native grasslands that would destroy, isolate, interrupt, or cause a break in continuous habitat that would (1) disrupt associated animal movement patterns and seed dispersal, or (2) increase vulnerability to weed invasions.
c. Removal or disturbance to a patch of native grasses less than 0.25 acre that is clearly isolated and is not part of a significant native grassland or an integral component of a larger ecosystem may be allowed. Removal or disturbance to restoration areas shall not be allowed. d. Impacts to protected native grasslands shall be minimized by providing at least a 10-foot buffer that is restored with native species around the perimeter of the delineated native grassland area.
e. Removal of nonnative and invasive exotic species shall be allowed; revegetation shall be with plants or seeds collected within the same watershed whenever feasible.

CE 5.3 Protection of Costal Bluff Scrub, Coastal Sage Scrub, and Chaparral ESHA. [GP/CP] In addition to the provisions of Policy CE 1, the following standards shall apply:
a. For purposes of this policy, coastal bluff scrub is defined as scrub habitat occurring on exposed coastal bluffs. Example species in bluff scrub habitat include Brewer’s saltbush ( Atriplex lentiformis), lemonade berry ( Rhus integrifolia), seashore blight ( Suaeda californica), seacliff buckwheat (Eriogonum parvifolium), California sagebrush (Artemisia californica ), and coyote bush (Baccharis pilularis). Coastal sage scrub is defined as a drought-tolerant, Mediterranean habitat characterized by soft -leaved, shallow-rooted subshrubs such as California sagebrush (Artemisia californica ), coyote bush ( Baccharis pilularis ), and California encelia ( Encelia californica). It is found at lower elevations in both coastal and interior areas where moist maritime air penetrates inland. Chaparral is defined as fire- and drought -adapted woody, evergreen shrubs generally occurring on hills and lower mountain slopes. The area must have both the compositional and structural characteristics of coastal bluff scrub, coastal sage scrub, or chaparral habitat as described in Preliminary Descriptions of Terrestrial Natural Communities of Calif ornia (Holland 1986) or other classification system recognized by the California Department of Fish and Game.
b. To the maximum extent feasible, development shall avoid impacts to coastal bluff scrub, coastal sage scrub, or chaparral habitat that is part of a wildlife movement corridor and the 157

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impact would preclude animal movement or isolate ESHAs previously connected by the corridor such as (1) disrupting associated bird and animal movement patterns and seed dispersal, and/or (2) increasing erosion and sedimentation impacts to nearby creeks or drainages. c. Impacts to coastal bluff scrub, coastal sage scrub, and chaparral ESHAs shall be minimized by providing at least a 25 -foot buffer restored with native species around the perimeter of the ESHA, unless the activity is allowed under other CE subpolicies and mitigation is applied per CE 1.7
d. Removal of nonnative and invasive exotic species shall be allowed; revegetation shall be with plants or seeds collected within the same watershed whenever feasible.

Policy CE 6: Protection of Marine Habitat Areas [GP/CP] CE 6.1 Designation of Marine ESHAs. [GP/CP] All marine areas offshore from Goleta extending from the mean high tide line seaward to the outer limit of state waters are hereby designated ESHAs. These areas include Areas of Special Biological Significance and Marine Protected Areas (as designated by the California Department of Fish and Game), and shall be granted the protections provided for ESHAs in this plan.

CE 6.2 Protection of Marine ESHAs. [GP/CP] The following protections shall apply to marine ESHAs:
a. Marine ESHAs shall be protected against significant disruption of habitat values, and only uses dependent on such resources, such as fishing, whale watching, ocean kayaking, and similar recreational activities, should be allowed within the offshore area. b. All existing oil and gas production facilities, including platform Holly and the piers at State Lease 421, shall be decommissioned immediately upon termination of production activities.

All facilities and debris shall be completely removed and the sites restored to their prior natural condition as part of the decommissioning activities. No new oil and gas leases or facilities shall be allowed within state waters offshore from Goleta.
c. Permitted uses or developments shall be compatible with marine and beach ESHAs. d. Any development on beach or ocean bluff areas adjacent to marine and beach habitats shall be sited and designed to prevent impacts that could significantly degrade the marine ESHAs.

All uses shall be compatible with the maintenance of the biological productivity of such areas.

Grading and landform alteration shall be limited to minimize impacts from erosion and sedimentation on marine resources.
e. Marine mammal habitats, including haul- out areas, shall not be altered or disturbed by development of recreational facilities or activities, or any other new land uses and development.
f. Near-shore shallow fish habitats and shore fishing areas shall be preserved and, where appropriate and feasible, enhanced.
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g. Activities by the California Department of Fish and Game; Central Coast Regional Water Quality Control Board; State Lands Commission; and Division of Oil, Gas and Geothermal Resources to increase monitoring to assess the conditions of near-shore species, water quality, and kelp beds, and/or to rehabilitate areas that have been degraded by human activities, such as oil and gas production facilities, shall be encouraged and allowed.

Policy CE 7: Protection of Beach and Shoreline Habitats [GP/CP] CE 7.1 Designation of Beach and Shoreline ESHAs. [GP/CP] All areas extending from the mean high tide line landward to the top of the ocean bluffs are hereby designated as ESHAs.

CE 7.2 Protection of Dunes. [GP/CP] Dune ESHAs shall be protected and, where feasible, enhanced.

Vehicle traffic through dunes shall be prohibited. Where pedestrian access through dunes is allowed, well-defined footpaths or other means of directing use and minimizing adverse impacts shall be used. Active nesting areas for sensitive birds, such as the western snowy plovers and least terns, shall be protected by fencing, signing, and other means.

CE 7.3 Protection of Beach Areas. [GP/CP] Access to beach areas by motorized vehicles, including offroad vehicles, shall be prohibited, except for beach maintenance and emergency response vehicles of public agencies. Emergency services shall not include routine vehicular patrolling by private security forces. Any beach grooming activities shall employ hand -grooming methods, and mechanical beach grooming equipm ent and methods shall be prohibited. All vehicular uses on beach areas shall avoid ESHAs to the maximum extent feasible.

CE 7.4 Permitted Uses of Beaches and Shoreline Areas. [GP/CP] Uses on beaches and shoreline areas shall be limited to coastal-dependent activities that are compatible with preservation of the quality of the resource, including coastal -dependent recreation activities such as swimming, surfing, boating and kayaking, and fishing. Any commercial coastal -dependent recreation activities that would limit use of beach and shoreline areas to customers and exclude the general public shall be subject to approval of a permit by the City. Any such permitted uses shall not degrade the quality or the habitat or cause impacts to birds and other wildlife.

CE 7.5 Shoreline Protective Structures. [GP/CP] New shoreline protective structures such as seawalls, revetments, and riprap shall be prohibited, except as provided in Policies SE 2 and SE 3.

CE 7.7 Recreation Facilities on Beach Areas. [GP/CP] When permitted, new public access and recreational facilities or structures on beaches shall be designed and located to minimize impacts to ESHAs and marine resources.

CE 7.8 Protection of Seabird Nest Areas. [GP/CP] To protect seabird nesting areas, no pedestrian access shall be provided on bluff faces except along existing and planned formal trails or stairways shown in this plan. New structures shall be prohibited on bluff faces except for stairs, ramps, or trails to provide for public beach access.

Policy CE 8: Protection of Special-Status Species [GP/CP] 159

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CE 8.1 ESHA Designation. [GP/CP] Requisite habitats for individual occurrences of special- status plants and animals, including candidate species for listing under the state and federal endangered species acts, California species of special concern, California Native Plant Society List 1B plants, and other species protected under provisions of the California Fish and Game Code shall be preserved and protected, and their occurrences, including habitat requirements, s hall be designated as ESHAs. These habitats include, but are not limited to, the following:

a. Special-status plant species such as Santa Barbara honeysuckle ( Lonicera subspicata var. subspicata), southern tarplant ( Centromadia parryi ssp. australis) and bla ck-flowered figwort (Scrophularia atrata).
b. Habitat capable of supporting special -status invertebrate species, such as the globose dune beetle (Coelus globosus), and roosting habitat for the monarch butterfly. c. Aquatic habitat capable of supporting special-status fish species such as the steelhead trout (Oncorhynchus mykiss) and tidewater goby (Eucyclogobius newberryi). d. Habitat capable of supporting special -status amphibians and reptiles such as the red -legged frog (Rana aurora draytonii) and western pond turtle (Clemmys marmorata pallida). e. Nesting and roosting areas for various species of raptors such as Cooper’s hawks ( Accipiter cooperii), red-tailed hawks (Buteo jamaicensis), white-tailed kites (Elanus leucurus), and turkey vultures (Cathartes aura).
f. Nesting habitat for other special -status bird species such as western snowy plover, southwestern willow flycatcher ( Empidonax traillii extimus ), loggerhead shrike ( Lanius ludovicianus), yellow warbler (Dendroica petechia), or tri-colored blackbird (Agelaius tricolor). g. Nesting and foraging habitat for special -status mammals such as pallid bat (Antrozous pallidus), western red bat ( Lasiurus blossevillii), Yuma myotis ( Myotis yumanensis ), and American badger (Taxidea taxus).

CE 8.2 Protection of Habitat Areas. [GP/CP] All development shall be located, designed, constructed, and managed to avoid disturbance of adverse impacts to special -status species and their habitats, including spawning, nesting, rearing, roosting, foraging, and other elements of the required habitats.

CE 8.3 Site-Specific Biological Resources Study. [GP/CP] Any areas not designated on Figure 4-1 that meet the ESHA criteria for the resources specified in CE 8.1 shall be accorded the same protections as if the area were shown on the figure. Proposals for development on sites where ESHAs are shown on the figure, or where there is probable cause to believe that an ESHA may exist, shall be required to provide the City with a site-specific biological study that includes the following information:

a. A base map that delineates topographic lines, parcel boundaries, and adjacent roads. 160

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b. A vegetation map that 1) identifies trees or other sites that are existing or historical nests for the species of concern and 2) delineates other elements of the habitat such as roosting sites and foraging areas.
c. A detailed map that shows the conclusions regarding the boundary, precise location and extent, or current status of the ESHA based on substantial evidence provided in the biological studies. d. A written report that summarizes the survey methods, data, observations, findings, and recommendations.

CE 8.4 Buffer Areas for Raptor Species. [GP/CP] Development shall be designed to provide a 100 -foot buffer around active and historical nest sites for protected spec ies of raptors when feasible. In existing developed areas, the width of the buffer may be reduced to correspond to the actual width of the buffer for adjacent development. If the biological study described in CE 8.3 determines that an active raptor nest site exists on the subject property, whenever feasible no vegetation clearing, grading, construction, or other development activity shall be allowed within a 300-foot radius of the nest site during the nesting and fledging season.

Policy CE 9: Protection of Native Woodlands [GP/CP]
CE 9.1 Definition of Protected Trees. [GP/CP] New development shall be sited and designed to preserve the following species of native trees: oaks ( Quercus spp.), walnut (Juglans californica), sycamore (Platanus racemosa), cottonwood (Populus spp.), willows (Salix spp.), or other native trees that are not otherwise protected in ESHAs, unless as otherwise allowed in CE 9.

CE 9.2 Tree Protection Plan. [GP/CP] Applications for new development on sites containing protected native trees shall include a report by a certified arborist or other qualified expert. The report shall include an inventory of native trees and a Tree Protection Plan.

CE 9.3 Native Oak Woodlands or Savannas. [GP/CP] Native oak woodlands and savannas are designated as ESHAs and shall be preserved and protected. A minimum buffer area shall be established via the implementation of CE-IA-4, Preparation of a Tree Protection Ordinance.

CE 9.4 Tree Protection Standards. [GP/CP] The following impacts to native trees a nd woodlands should be avoided in the design of projects: 1) removal of native trees; 2) fragmentation of habitat; 3) removal of understory; 4) disruption of the canopy, and 5) alteration of drainage patterns.

Structures, including roads and driveways, sho uld be sited to prevent any encroachment into the protection zone of any protected tree and to provide an adequate buffer outside of the protection zone of individual native trees in order to allow for future growth. Tree protection standards shall be detailed in the Tree Protection Ordinance called for in CE-IA-4.

CE 9.5 Mitigation of Impacts to Native Trees. [GP/CP] Where the removal of mature native trees cannot be avoided through the implementation of project alternatives or where development encroaches into the protected zone and could threaten the continued viability of the tree(s), mitigation measures shall include, at a minimum, the planting of replacement trees on site, if suitable area exists on the subject site, or offsite if suitable onsite area is unavailable, consistent with the Tree Protection Ordinance (see also CE- IA-4). The Tree Protection Ordinance shall establish the 161

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mitigation ratios for replacement trees for every tree removed. Where onsite mitigation is not feasible, offsite mitigation shall be provided by planting of replacement trees at a site within the same watershed. If the tree removal occurs at a site within the Coastal Zone, any offsite mitigation area shall also be located within the Coastal Zone. Minimum sizes for various species of replacement trees shall be established in the Tree Protection Ordinance. Mitigation sites shall be monitored for a period of 5 years. The City may require replanting of trees that do not survive.

Policy CE 10: Watershed Management and Water Quality [GP/CP] CE 10.1 New Development and Water Quality. [GP/CP] New development shall not result in the degradation of the water quality of groundwater basins or surface waters; surface waters include the ocean, lagoons, creeks, ponds, and wetlands. Urban runoff pollutants shall not be discharged or deposited such that they adversely affect these resources.

CE 10.2 Siting and Design of New Development. [GP/CP] New development shall be sited and designed to protect water quality and minimize impacts to coastal waters by incorporating measures designed to ensure the following: a. Protection of areas that provide important water quality benefits, areas necessary to maintain riparian and aquatic biota, and areas susceptible to erosion and sediment loss. b. Limiting increases in areas covered by impervious surfaces. c. Limiting the area where land disturbances occur, such as clearing of vegetation, cut-and-fill, and grading, to reduce erosion and sediment loss. d. Limiting disturbance of natural drainage features and vegetation.

CE 10.3 Incorporation of Best Management Practices for Stormwater Management. [GP/CP] New development shall be designed to minimize impacts to water quality from increased runoff volumes and discharges of pollutants from nonpoint sources to the maximum extent feasible, consistent with the City’s Storm Water Management Plan or a subsequent Storm Water Management Plan approved by the City and the Central Coast Regional Water Quality Control Board. Post construction structural BMPs shall be designed to treat, infiltrate, or filter stormwater runoff in accordance with applicable standards as required by law. Examples of BMPs include, but are not limited to, the following:

a. Retention and detention basins.
b. Vegetated swales.
c. Infiltration galleries or injection wells.
d. Use of permeable paving materials.
e. Mechanical devices such as oil-water separators and filters. f. Revegetation of graded or disturbed areas.
g. Other measures as identified in the City’s adopted Storm Water Management Plan and other City-approved regulations.
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CE 10.4 New Facilities. [GP/CP] New bridges, roads, culverts, and outfalls shall not cause or contribute to creek bank erosion or creek or wetland siltation and shall include BMPs to minimize impacts to water quality. BMPs shall include construction phase erosion control, polluted runoff control plans, and soil stabilization techniques. Where space is available, dispersal of sheet flow from roads into vegetated areas, or other onsite infiltration practices, shall be incorporated into the project design.

CE 10.5 Beachfront and Blufftop Development. [GP/CP] Development adjacent to the beach or blufftop shall incorporate BMPs designed to prevent or minimize polluted runoff to the beach and ocean waters.

CE 10.6 Stormwater Management Requireme nts. [GP/CP] The following requirements shall apply to specific types of development:
h. Commercial and multiple- family development shall use BMPs to control polluted runoff from structures, parking, and loading areas.
i. Restaurants shall incorporate BMPs designed to minimize runoff of oil and grease, solvents, phosphates, and suspended solids to the storm drain system. j. Gasoline stations, car washes, and automobile repair facilities shall incorporate BMPs designed to minimize runoff of oil and grease, solvents, car battery acid, engine coolants, and gasoline to the stormwater system.
k. Outdoor materials storage areas shall be designed to incorporate BMPs to prevent stormwater contamination from stored materials.
l. Trash storage areas shall be designed using BMPs to prevent stormwater contamination by loose trash and debris.

CE 10.7 Drainage and Stormwater Management Plans. [GP/CP] New development shall protect the absorption, purifying, and retentive functions of natural systems that exist on the site. Drainage Plans shall be designed to complement and use existing drainage patterns and systems, where feasible, conveying drainage from the site in a nonerosive manner. Disturbed or degraded natural drainage systems shall be restored where feasible, except where there are geologic or public safety concerns. Proposals for new development shall include the following:
m. A Construction-Phase Erosion Control and Stormwater Management Plan that specifies the BMPs that will be implemented to minimize erosion and sedimentation; provide adequate sanitary and waste disposal facilities; and prevent contamination of runoff by construction practices, materials, and chemicals.
n. A Post-Development- Phase Drainage and Stormwater Management Plan that specifies the BMPs—including site design methods, source controls, and treatment controls —that will be implemented to minimize polluted runoff after construction. This plan shall include monitoring and maintenance plans for the BMP measures.
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CE 10.9 Landscaping to Control Erosion. [GP/CP] Any landscaping that is required to control erosion shall use native or drought -tolerant noninvasive plants to minimize the need for fertilizer, pesticides, herbicides, and excessive irrigation.

164

Appendix B
Photo Log
165

APPENDIX B / PHOTOS

12760 B-1 AUGUST 2023

Photo 1. Bell Creek Lagoon (Aquatic Resource A,
California red-legged frog survey area, tidewater goby
critical habitat), facing north. July 7, 2022.

Photo 2. Bell Creek, facing south. May 13, 2022.

Photo 3. Devereux Creek. Culvert leading from
northern portion of creek under fairway of Hole 1. May
11, 2022.

Photo 4. Devereux Creek, looking south from fairway
of Hole 1. May 11, 2022.

166

APPENDIX B / PHOTOS

12760 B-2 AUGUST 2023

Photo 5. Golf Course Pond, with surrounding
maintained turf and golf cart path, facing south. July
7, 2022.

Photo 6. Aquatic Resource D. NWW-HLM-02 and WSP-
02 facing south. May 10, 2022.

Photo 7. Aquatic Resource D. WSP-02, hydric soil
indicator F6: redox dark surface. May 10, 2022.

Photo 8. Aquatic Resource F. NWW-HLM-04 and WET-
HLM-01, facing southwest. California red-legged frog
survey area. May 11, 2022.

167

APPENDIX B / PHOTOS

12760 B-3 AUGUST 2023

Photo 9. NG_21. Native grassland assessment
polygon 21 containing native grass species purple
needlegrass. May 26, 2022.

Photo 10. NG_22. Native grassland assessment
polygon 22 containing native grass species purple
needlegrass. May 26, 2022.

Photo 11. NG_20A. Native grassland assessment
polygon 20 containing native grass species
smallflower melicgrass (Melica imperfecta) and
purple needlegrass (Stipa pulchra). Combined with
NG-21 and NG-22, these polygons result in the one
native grassland area on the Project site. May 26,
2022.

Photo 12. NG_20B. Native grassland assessment
polygon 20 containing native grass species
smallflower melicgrass and purple needlegrass. May
26, 2022.

168

APPENDIX B / PHOTOS

12760 B-4 AUGUST 2023

Photo 13. Santa Barbara honeysuckle (Lonicera
subspicata var. subspicata) CRPR 1B.2. Facing north.

July 7, 2022.

Photo 14. Southern California Black Walnut (Juglans
californica) CRPR 4.2. Facing west. April 2, 2022.

Photo 15. Red sand verbena (Abronia maritima) CRPR

4.2. Facing north. May 4, 2022.

Photo 16. Cliff malacothrix (Malacothrix saxatilis var. saxatilis) CRPR 4.2. Facing south. May 4, 2022.

169

APPENDIX B / PHOTOS

12760 B-5 AUGUST 2023

Photo 17. Baja California tree frog (Pesudacris
hypochondriaca) observed during nighttime California
red-legged frog surveys in the Golf Course Pond. May
11, 2022.

Photo 18. Baja California tree frog egg mass observed
during nighttime California red-legged frog surveys in
the Golf Course Pond. April 25, 2022.

Photo 19. American bullfrog (Lithobates
catesbeianus) observed during nighttime California
red-legged frog surveys in the Golf Course Pond. April
25, 2022.

Photo 20. Red-tailed hawk (Buteo jamaicensis) nest
with nestlings, in a eucalyptus tree in eastern portion of the Project site. April 27, 2022.

170

APPENDIX B / PHOTOS

12760 B-6 AUGUST 2023

Photo 21. Culvert inlet between Holes 4 and 5. An
Arizona Crossing currently occurs in Devereaux Creek.

Photo provided by SEPPS.

Photo 22. Culvert outlet in Devereaux Creek between
Holes 4 and 5 where the Arizona crossing is located.

Photo provided by SEPPS.

171

Appendix C
Wildlife Compendium
172

APPENDIX C / WILDLIFE COMPENDIUM

12760 C-1 AUGUST 2023

Wildlife Species
Amphibians
Frogs

HYLIDAE - TREEFROGS
Pseudacris hypochondriaca—Baja California treefrog
RANIDAE – TRUE FROGS
Rana draytonii—California red-legged frog
Lithobates catesbeianus—American bullfrog*
Birds
ACCIPITRIDAE – HAWKS, KITES, EAGLES, AND ALLIES
Accipiter cooperii—Cooper's hawk
Buteo jamaicensis—red-tailed hawk
Buteo lineatus—red-shouldered hawk
Elanus leucurus—white-tailed kite
AEGITHALIDAE – LONG -TAILED TITS AND BUSHTITS
Psaltriparus minimus—bushtit
ANATIDAE – DUCKS, GEESE, AND SWANS
Anas platyrhynchos—mallard
Anser albifrons—greater white-fronted goose
Aythya affinis—lesser scaup
Aythya collaris—ring-necked duck
Branta canadensis—Canada goose
Bucephala albeola—bufflehead
Chen caerulescens – snow goose
Lophodytes cucullatus—hooded merganser
Oxyura jamaicensis—ruddy duck
Mareca strepera—gadwall
Mareca americana—American wigeon
AREIDAE – HERONS, BITTERNS, AND ALLIES
Ardea alba—great egret
Ardea herodias—great blue heron
Egretta thula—snowy egret
Nycticorax nycticorax—black-crowned night-heron

APODIDAE - SWIFTS
Chaetura vauxi—Vaux's swift
173

APPENDIX C / WILDLIFE COMPENDIUM

12760 C-2 AUGUST 2023

CARDINALIDAE – CARDINALS AND ALLIES
Pheucticus melanocephalus—black-headed grosbeak
CATHARTIDAE – NEW WORLD VULTURES
Cathartes aura—turkey vulture
CHARADRIIDAE – LAPWINGS AND PLOVERS
Charadrius vociferus—killdeer
COLUMBIDAE – PIGEONS AND DOVES
Zenaida macroura—mourning dove
Columba livia—rock pigeon (rock dove)*
Streptopelia decaocto—Eurasian collared-dove*
CORVIDAE – CROWS AND JAYS
Aphelocoma californica—California scrub-jay
Corvus brachyrhynchos—American crow

ESTRILDIDAE - WAXBILLS
Lonchura punctulata—scaly-breasted munia*
FRINGILLIDAE –FINCHES AND ALLIES
Haemorhous mexicanus—house finch
Haemorhous purpureus—purple finch
Spinus psaltria—lesser goldfinch

HIRUNDINIDAE - SWALLOWS
Hirundo rustica—barn swallow
Petrochelidon pyrrhonota—cliff swallow
Stelgidopteryx serripennis—northern rough-winged swallow Tachycineta bicolor—tree swallow
Tachycineta thalassina—violet-green swallow
LARIDAE – GULLS, TERNS, AND SKIMMERS
Larus californicus—California gull
Larus delawarensis—ring-billed gull
Larus heermanni—Heermann's gull
Larus occidentalis—western gull

ICTERIDAE - BLACKBIRDS
Agelaius phoeniceus—red-winged blackbird
Euphagus cyanocephalus—Brewer's blackbird
Icterus bullockii—Bullock's oriole
Icterus cucullatus—hooded oriole
Sturnella neglecta—western meadowlark
Xanthocephalus xanthocephalus—yellow-headed blackbird
Molothrus ater—brown-headed cowbird*
174

APPENDIX C / WILDLIFE COMPENDIUM

12760 C-3 AUGUST 2023

MIMIDAE – MOCKINGBIRDS AND THRASHERS
Mimus polyglottos—northern mockingbird
MOTACILLIDAE – WAGTAILS AND PIPITS
Anthus rubescens—American pipit
ODONTOPHORIDAE – NEW WORLD QUAIL
Callipepla californica—California quail
PARIDAE – CHICKADEES AND TITMICE
Baeolophus inornatus—oak titmouse
PARULIDAE – WOOD WARBLERS
Cardellina pusilla—Wilson's warbler
Geothlypis trichas—common yellowthroat
Setophaga coronata—yellow-rumped warbler
Setophaga petechia—yellow warbler
Setophaga townsendi—Townsend's warbler
Leiothlypis celata—orange-crowned warbler
PASSERELLIDAE – NEW WORLD SPARROWS
Chondestes grammacus—lark sparrow
Junco hyemalis—dark-eyed junco
Melospiza lincolnii—Lincoln's sparrow
Melospiza melodia—song sparrow
Melozone crissalis—California towhee
Pipilo maculatus—spotted towhee
Zonotrichia leucophrys—white-crowned sparrow

PELECANIDAE - PELICANS
Pelecanus occidentalis—brown pelican

PHALACROCORACIDAE - CORMORANTS
Nannopterum auritus—double-crested cormorant
PICIDAE – WOODPECKERS AND ALLIES
Melanerpes formicivorus—acorn woodpecker
Dryobates nuttallii—Nuttall's woodpecker
Dryobates pubescens—downy woodpecker

PODICIPEDIDAE - GREBES
Podilymbus podiceps—pied-billed grebe

POLIOPTILIDAE - GNATCATCHERS
Polioptila caerulea—blue-gray gnatcatcher
175

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12760 C-4 AUGUST 2023

PTILOGONATIDAE – SILKY -FLYCATCHERS
Phainopepla nitens—phainopepla
RALLIDAE – RAILS, GALLINULES, AND COOTS
Fulica americana—American coot
RECURVIROSTRIDAE – STILTS AND AVOCETS
Himantopus mexicanus—black-necked stilt

REGULIDAE - KINGLETS
Regulus satrapa—golden-crowned kinglet
Corthylio calendula—ruby-crowned kinglet
SCOLOPACIDAE – SANDPIPERS, PHALAROPES, AND ALLIES
Calidris alba—sanderling
Calidris minutilla—least sandpiper
Limnodromus griseus—short-billed dowitcher
Limosa fedoa—marbled godwit
Numenius phaeopus—whimbrel
Tringa melanoleuca—greater yellowlegs
Tringa semipalmata—willet
STRIGIDAE – TYPICAL OWLS
Bubo virginianus—great horned owl

STURNIDAE - STARLINGS
Sturnus vulgaris—European starling*
THRESKIORNITHIDAE – IBISES AND SPOONBILLS
Plegadis chihi—white-faced ibis

TROCHILIDAE - HUMMINGBIRDS
Calypte anna—Anna's hummingbird
Selasphorus sasin—Allen's hummingbird

TROGLODYTIDAE - WRENS
Cistothorus palustris—marsh wren
Troglodytes aedon—house wren
Thryomanes bewickii—Bewick's wren

TURDIDAE - THRUSHES
Sialia mexicana—western bluebird
Turdus migratorius—American robin
TYRANNIDAE – TYRANT FLYCATCHERS
Empidonax difficilis—Pacific-slope flycatcher
Sayornis nigricans—black phoebe
176

APPENDIX C / WILDLIFE COMPENDIUM

12760 C-5 AUGUST 2023

Sayornis saya—Say's phoebe
Tyrannus verticalis—western kingbird
Tyrannus vociferans—Cassin's kingbird

VIREONIDAE - VIREOS
Vireo gilvus—warbling vireo
Vireo huttoni—Hutton's vireo
Fishes

POECILIIDAE - POECILIIDS
Gambusia affinis—mosquitofish*

GOBIDAE - GOBIES
Eucyclogobius newberryi—tidewater goby
Invertebrates
Butterflies
NYMPHALIDAE – BRUSH -FOOTED BUTTERFLIES
Danaus plexippus—monarch
PIERIDAE – WHITES AND SULFURS
Pieris rapae—cabbage white
Mammals
CANIDAE – WOLVES AND FOXES
Vulpes vulpes—red fox*
DIDELPHIDAE – NEW WORLD OPOSSUMS
Didelphis virginiana—Virginia opossum*
LEPORIDAE – HARES AND RABBITS
Sylvilagus bachmani—brush rabbit
MUSTELIDAE – WEASELS, SKUNKS, AND OTTERS
Neogale frenata—long-tailed weasel
PROCYONIDAE – RACCOONS AND RELATIVES
Procyon lotor—northern raccoon

SCIURIDAE - SQUIRRELS
Otospermophilus beecheyi—California ground squirrel
177

APPENDIX C / WILDLIFE COMPENDIUM

12760 C-6 AUGUST 2023

Reptiles
Lizards
PHRYNOSOMATIDAE – IGUANID LIZARDS
Sceloporus occidentalis—western fence lizard
∗ signifies introduced (non-native) species
178

Appendix D
Native Grassland Data Sheets
179
180
181
182
183
184
185
186
187
188
189
190
191
192
193
194
195
196
197

Appendix E
Plant Compendium
198

APPENDIX E / PLANT COMPENDIUM

12760 E-1 AUGUST 2023

Dicots
ADOXACEAE —MUSKROOT FAMILY
Sambucus mexicana—blue elderberry
AIZOACEAE —FIG -MARIGOLD FAMILY
* Carpobrotus chilensis—sea fig
* Carpobrotus edulis—hottentot fig
* Tetragonia tetragonoides—New Zealand spinach
AMARANTHACEAE —AMARANTH FAMILY
Amaranthus blitoides—mat amaranth
ANACARDIACEAE —SUMAC OR CASHEW FAMILY
Rhus integrifolia—lemonade berry
* Schinus molle—Peruvian peppertree
* Schinus terebinthifolius—Brazilian peppertree
Toxicodendron diversilobum—poison oak
APIACEAE —CARROT FAMILY
* Conium maculatum—poison hemlock
* Foeniculum vulgare—fennel
APOCYNACEAE —DOGBANE FAMILY
* Araujia sericifera—white bladderflower
* Nerium oleander—oleander
ASTERACEAE —SUNFLOWER FAMILY
Ambrosia chamissonis—silver bur ragweed
Ambrosia psilostachya—western ragweed
Artemisia californica—California sagebrush
Artemisia douglasiana—Douglas' sagewort
Baccharis glutinosa—saltmarsh baccharis
Baccharis pilularis—coyote brush
* Carduus pycnocephalus—Italian plumeless thistle
* Centaurea melitensis—Maltese star-thistle
* Cotula coronopifolia—brass buttons
Deinandra fasciculata—clustered tarweed
* Delairea odorata—Cape-ivy
Encelia californica—California brittle bush
* Erigeron bonariensis—asthmaweed
199

APPENDIX E / PLANT COMPENDIUM

12760 E-2 AUGUST 2023

* Helminthotheca echioides—bristly oxtongue
Isocoma menziesii var. vernonioides—Menzies' goldenbush Jaumea carnosa—marsh jaumea
* Lactuca serriola—prickly lettuce
Malacothrix saxatilis var. saxatilis—cliff malacothrix
Pseudognaphalium californicum—ladies' tobacco
* Pseudognaphalium luteoalbum—Jersey cudweed
* Silybum marianum—blessed milkthistle
* Sonchus asper—spiny sowthistle
* Sonchus oleraceus—common sowthistle
* Taraxacum officinale—common dandelion
Xanthium strumarium—cocklebur
BORAGINACEAE —BORAGE FAMILY
Heliotropium curassavicum—salt heliotrope
BRASSICACEAE —MUSTARD FAMILY
* Brassica nigra—black mustard
* Brassica rapa—field mustard
* Cakile maritima—European searocket
* Hirschfeldia incana—shortpod mustard
* Lepidium didymum—lesser swinecress
* Raphanus sativus—cultivated radish
CACTACEAE —CACTUS FAMILY
* Opuntia ficus-indica—Barbary fig
Opuntia littoralis—coast prickly pear
CAPRIFOLIACEAE —HONEYSUCKLE FAMILY
Lonicera subspicata var. subspicata—Santa Barbara honeysuckle CARYOPHYLLACEAE —PINK FAMILY
* Spergularia rubra—red sandspurry
CHENOPODIACEAE —GOOSEFOOT FAMILY
Atriplex lentiformis—quailbush
Atriplex leucophylla—beach saltbush
* Atriplex prostrata—fat hen
* Atriplex semibaccata—Australian saltbush
* Chenopodium album—lambsquarters
* Chenopodium murale—nettleleaf goosefoot
Salicornia pacifica—Pacific swampfire
200

APPENDIX E / PLANT COMPENDIUM

12760 E-3 AUGUST 2023

* Salsola tragus—prickly Russian thistle
Suaeda taxifolia—woolly seablite
CONVOLVULACEAE —MORNING -GLORY FAMILY
Calystegia macrostegia ssp. cyclostegia—island false bindweed * Convolvulus arvensis—field bindweed
EUPHORBIACEAE —SPURGE FAMILY
* Euphorbia peplus—petty spurge
* Euphorbia terracina—Geraldton carnation weed
* Ricinus communis—castorbean
FABACEAE —LEGUME FAMILY
* Acacia longifolia—Sydney golden wattle
* Medicago polymorpha—burclover
* Melilotus albus—yellow sweetclover
* Melilotus indicus—annual yellow sweetclover
* Vicia villosa—winter vetch
FAGACEAE —OAK FAMILY
Quercus agrifolia—coast live oak
FRANKENIACEAE —FRANKENIA FAMILY
Frankenia salina—alkali heath
GERANIACEAE —GERANIUM FAMILY
* Erodium botrys—longbeak stork's bill
* Erodium cicutarium—redstem stork's bill
* Erodium moschatum—musky stork's bill
JUGLANDACEAE —WALNUT FAMILY
Juglans californica—Southern California black walnut
MALVACEAE —MALLOW FAMILY
* Malva parviflora—cheeseweed mallow
Malvella leprosa—alkali mallow
MYRSINACEAE —MYRSINE FAMILY
* Lysimachia arvensis—scarlet pimpernel
MYRTACEAE —MYRTLE FAMILY
* Corymbia ficifolia—red flowering gum
* Eucalyptus camaldulensis—river redgum
201

APPENDIX E / PLANT COMPENDIUM

12760 E-4 AUGUST 2023

* Eucalyptus citriodora—lemonscented gum
* Eucalyptus globulus—Tasmanian bluegum
* Eucalyptus sideroxylon—red ironbark
NYCTAGINACEAE —FOUR O'CLOCK FAMILY
Abronia maritima—red sand-verbena
Abronia umbellata—pink sand verbena
OLEACEAE —OLIVE FAMILY
Fraxinus dipetala—California ash
ONAGRACEAE —EVEN ING PRIMROSE FAMILY
* Ludwigia peploides—floating primrose-willow
OXALIDACEAE —OXALIS FAMILY
* Oxalis pes-caprae—Bermuda buttercup
PAPAVERACEAE —POPPY FAMILY
Eschscholzia californica—California poppy
PITTOSPORACEAE —PITTOSPORUM FAMILY
* Pittosporum undulatum—Australian cheesewood
PLANTAGINACEAE —PLANTAIN FAMILY
* Plantago coronopus—buckhorn plantain
* Plantago lanceolata—narrowleaf plantain
* Plantago major—common plantain
PLATANACEAE —PLANE TREE, SYCAMORE FAMILY
Platanus racemosa—California sycamore
PLUMBAGINACEAE —LEADWORT FAMILY
* Plumbago auriculata—Cape leadwort
POLYGONACEAE —BUCKWHEAT FAMILY
Eriogonum cinereum—ashy buckwheat
* Polygonum aviculare—prostrate knotweed
* Rumex crispus—curly dock
* Rumex pulcher—fiddle dock
PORTULACACEAE —PURSLANE FAMILY
* Portulaca oleracea—little hogweed
202

APPENDIX E / PLANT COMPENDIUM

12760 E-5 AUGUST 2023

RANUNCULACEAE —BUTTERCUP FAMILY
Clematis ligusticifolia—western white clematis
ROSACEAE —ROSE FAMILY
Heteromeles arbutifolia—toyon
* Rhaphiolepis indica—Indian hawthorn
Rosa californica—California rose
Rubus ursinus—California blackberry
SALICACEAE —WILLOW FAMILY
* Salix babylonica—Weeping willow
Salix lasiolepis—arroyo willow
SCROPHULARIACEAE —FIGWORT FAMILY
* Myoporum laetum—myoporum
Scrophularia californica—California figwort
SOLANACEAE —NIGHTSHADE FAMILY
* Nicotiana glauca—tree tobacco
Solanum americanum—American black nightshade
Solanum douglasii—greenspot nightshade
TAMARICACEAE —TAMARISK FAMILY
* Tamarix ramosissima—tamarisk
TROPAEOLACEAE —NASTURTIUM FAMILY
Tropaeolum majus—nasturtium*
URTICACEAE —NETTLE FAMILY
Urtica dioica—stinging nettle
VERBENACEAE —VERVAIN FAMILY
* Lantana montevidensis—trailing shrubverbena
Verbena lasiostachys—western vervain
Gymnosperms and Gnetophytes
CUPRESSACEAE —CYPRESS FAMILY
Hesperocyparis macrocarpa—Monterey cypress
PINACEAE —PINE FAMILY
* Pinus canariensis—Canary Island pine
* Pinus halepensis—aleppo pine
203

APPENDIX E / PLANT COMPENDIUM

12760 E-6 AUGUST 2023

Monocots
ARECACEAE —PALM FAMILY
* Phoenix canariensis—Canary Island date palm
* Washingtonia robusta—Washington fan palm
ASPARAGACEAE —ASPARAGUS FAMILY
* Asparagus asparagoides—African asparagus fern
CYPERACEAE —SEDGE FAMILY
Bolboschoenus maritimus—salt marsh bulrush
Cyperus eragrostis—tall flatsedge
Schoenoplectus californicus—California bulrush
IRIDACEAE —IRIS FAMILY
Sisyrinchium bellum—western blue-eyed grass
JUNCACEAE —RUSH FAMILY
Juncus patens—western rush
POACEAE —GRASS FAMILY
* Arundo donax—giant reed
* Avena barbata—slender oat
* Avena fatua—wild oat
* Brachypodium distachyon—purple false brome
* Bromus diandrus—ripgut brome
* Bromus hordeaceus—soft brome
* Bromus madritensis—compact brome
* Bromus rubens—red brome
* Cortaderia jubata—purple pampas grass
* Cynodon dactylon—Bermudagrass
Distichlis spicata—salt grass
Elymus condensatus—giant wild rye
Elymus triticoides—creeping ryegrass
* Festuca myuros—rat-tail fescue
* Festuca perennis—perennial rye grass
* Holcus lanatus—common velvet grass
Hordeum brachyantherum—meadow barley
* Hordeum marinum—seaside barley
* Hordeum murinum—mouse barley
Melica imperfecta—smallflower melicgrass
204

APPENDIX E / PLANT COMPENDIUM

12760 E-7 AUGUST 2023

* Paspalum dilatatum—dallisgrass
* Poa annua—annual bluegrass
* Polypogon monspeliensis—annual rabbitsfoot grass
* Polypogon viridis—beardless rabbitsfoot grass
* Stipa miliacea var. miliacea—smilograss
Stipa pulchra—purple needlegrass
* Stipa tenuissima—no common name
TYPHACEAE —CATTAIL FAMILY
Typha domingensis—southern cattail
∗ signifies introduced (non-native) species
205

Appendix F
Plant and Wildlife Potential to Occur Tables
206

ATTACHMENT F / SPECIAL-STATUS PLANT AND WILDLIFE SPECIES WITH POTENTIAL TO OCCUR ON THE PROJECT SITE 12760 F-1
JULY 2023

Special -Status Plant Species Potential to Occur on the Project Site Scientific
Name
Common
Name
Status
(Federal/State/CR
PR)
Primary Habitat Associations/ Life Form/
Blooming Period/ Elevation Range (feet) Potential to Occur Abronia maritima red sand-verbena None/None/4.2 Coastal dunes/perennial herb/Feb–Nov/0–330 Occurs within the Project site. This species was observed in sand dunes adjacent to the beach
during 2022 botanical surveys.

Amsinckia
douglasiana
Douglas'
fiddleneck
None/None/4.2 Cismontane woodland, Valley and foothill grassland; Dry/annual herb/Mar–May/0–6,395
Not expected to occur. While some suitable
grassland habitat is present within the Project site,
this species has not been observed south of the
Santa Ynez Mountains since 1935 (Calflora 2022),
and it was not detected during surveys in 2022
during botanical surveys.

Arctostaphylos
refugioensis
Refugio manzanita None/None/1B.2 Chaparral/perennial evergreen shrub/(May)Dec– Mar/900–2,690
Not expected to occur. The site is outside of the
species’ known elevation range and there is no
suitable vegetation present.

Atriplex coulteri Coulter's saltbush None/None/1B.2 Coastal bluff scrub, Coastal dunes, Coastal scrub, Valley and foothill grassland; Alkaline (sometimes), Clay
(sometimes)/perennial herb/Mar–Oct/10–1,505
Not expected to occur. This perennial species was
not observed during botanical surveys conducted in
May and July 2022. Suitable coastal bluff scrub,
and coastal dune habitat present is within the
Project site to support this species. In addition,
there are clay soils present within the Project site.

The nearest occurrence is from 2003 approximately

3.3 miles east of the Project site (CDFW 2022b).

Atriplex serenana
var. davidsonii
Davidson's
saltscale
None/None/1B.2 Coastal bluff scrub, Coastal scrub; Alkaline/annual herb/Apr–Oct/35–655
Low potential to occur. While this species was not
observed during botanical surveys conducted in
May and July 2022, there is suitable coastal bluff
scrub, and coastal dune habitat present within the
Project site to support this species. The nearest
occurrence is from 1948 aproximately 3.5 miles
east of the Project site (CDFW 2022b).

Baccharis
plummerae ssp.
plummerae
Plummer's
baccharis
None/None/4.3 Broadleafed upland forest, Chaparral, Cismontane woodland, Coastal scrub; Rocky/perennial deciduous
shrub/May–Oct/15–1,390
Not expected to occur. No suitable vegetation is
present to support this species within the Project
site. The nearest recent occurrence is from 2021
approximately 8.1 miles west of the Project site
(Calflora 2022).
207

ATTACHMENT F / SPECIAL-STATUS PLANT AND WILDLIFE SPECIES WITH POTENTIAL TO OCCUR ON THE PROJECT SITE 12760 F-2
JULY 2023

Special -Status Plant Species Potential to Occur on the Project Site Scientific
Name
Common
Name
Status
(Federal/State/CR
PR)
Primary Habitat Associations/ Life Form/
Blooming Period/ Elevation Range (feet) Potential to Occur Calandrinia breweri Brewer's
calandrinia
None/None/4.2 Chaparral, Coastal scrub; Burned areas, Disturbed areas, Loam (sometimes), Sandy (sometimes)/annual
herb/(Jan)Mar–June/35–4,000
Not expected to occur. While some disturbed
habitat is present within the Project site, it is not
expected to support this species. The nearest
occurrence is from 1956 approximately 7.2 miles
northeast of the Project site (Calflora 2022). In
addition, the only occurrences of this species south
of the Santa Ynez Mountains are from the foothills
in Santa Barbara and Montecito.

Calochortus
catalinae
Catalina mariposa
lily
None/None/4.2 Chaparral, Cismontane woodland, Coastal scrub, Valley and foothill grassland/perennial bulbiferous
herb/(Feb)Mar–June/50–2,295
Low potential to occur. While this species was not
observed during botanical surveys conducted in
May and July 2022, some suitable grassland habitat
is present within the Project site to support this
species. The nearest occurrence is from 1982,
approximately 1.8 miles northwest of the Project
site (Calflora 2022).

Calochortus
fimbriatus
late-flowered
mariposa-lily
None/None/1B.3 Chaparral, Cismontane woodland, Riparian woodland; Serpentinite (sometimes)/perennial bulbiferous
herb/June–Aug/900–6,250
Not expected to occur. The site is outside of the
species’ known elevation range.

Centromadia parryi
ssp. australis
southern tarplant None/None/1B.1 Marshes and swamps, Valley and foothill grassland, Vernal pools/annual herb/May–Nov/0–1,570
Low potential to occur. While this species was not
observed during the botanical surveys conducted in
May and July 2022, there is some suitable
grassland habitat (consisting of wild oat and annual
brome) present to support this species within the
Project site. The nearest occurrence was observed
in 1997, approximately 1.4 miles east of the Project
site (CDFW 2022b).

Chorizanthe
palmeri
Palmer's
spineflower
None/None/4.2 Chaparral, Cismontane woodland, Valley and foothill grassland; Rocky, Serpentinite/annual herb/Apr–
Aug/180–3,100
Not expected to occur. This species was not
observed during the botanical surveys conducted in
May and June 2022. While some suitable habitat
occurs within the Project site that could support this
species, it has not been observed south of the
Santa Ynez Mountains since 1876 (Calflora 2022).
208

ATTACHMENT F / SPECIAL-STATUS PLANT AND WILDLIFE SPECIES WITH POTENTIAL TO OCCUR ON THE PROJECT SITE 12760 F-3
JULY 2023

Special -Status Plant Species Potential to Occur on the Project Site Scientific
Name
Common
Name
Status
(Federal/State/CR
PR)
Primary Habitat Associations/ Life Form/
Blooming Period/ Elevation Range (feet) Potential to Occur Eriogonum elegans elegant wild
buckwheat
None/None/4.3 Cismontane woodland, Valley and foothill grassland; Gravelly (usually), Roadsides (sometimes), Sandy
(usually), Washes (often)/annual herb/May–Nov/655–
5,000
Not expected to occur. The site is outside of the
species’ known elevation range.

Fritillaria ojaiensis Ojai fritillary None/None/1B.2 Broadleafed upland forest, Chaparral, Cismontane woodland, Lower montane coniferous forest;
Rocky/perennial bulbiferous herb/Feb–May/740–3,270
Not expected to occur. The site is outside of the
species’ known elevation range and no suitable
vegetation occurs.

Galium
cliftonsmithii
Santa Barbara
bedstraw
None/None/4.3 Cismontane woodland/perennial herb/May–July/655– 4,000
Not expected to occur. The site is outside of the
species’ known elevation range and no suitable
vegetation occurs.

Horkelia cuneata
var. puberula
mesa horkelia None/None/1B.1 Chaparral, Cismontane woodland, Coastal scrub; Gravelly (sometimes), Sandy (sometimes)/perennial
herb/Feb–July(Sep)/230–2,655
Not expected to occur. The site is outside of the
species’ known elevation range and no suitable
vegetation occurs. In addition, this species was not
observed during either the May or July 2022
botanical surveys. The nearest occurrence is from
1981, approximately 1.6 miles northeast of the
Project site (CDFW 2022b).

Juglans californica Southern
California black
walnut
None/None/4.2 Chaparral, Cismontane woodland, Coastal scrub, Riparian woodland/perennial deciduous tree/Mar–
Aug/165–2,950
Occurs within the Project site. This species was
observed within the upper banks of Bell Creek in
riparian woodland vegetation during May and July
2022 botanical surveys.

Juncus acutus ssp.
leopoldii
southwestern
spiny rush
None/None/4.2 Coastal dunes, Marshes and swamps, Meadows and seeps/perennial rhizomatous herb/(Mar)May–June/10–
2,950
Not expected to occur. This perennial species was
not observed during the botanical surveys
conducted in May and July 2022. Suitable coastal
dune habitat occurring within the Project site could
support this species. The nearest occurrence is
from 1991, approximately 3.6 miles southeast of the
Project site (Calflora 2022).

Juncus luciensis Santa Lucia dwarf
rush
None/None/1B.2 Chaparral, Great Basin scrub, Lower montane coniferous forest, Meadows and seeps, Vernal
pools/annual herb/Apr–July/985–6,690
Not expected to occur. The site is outside of the
species’ known elevation range.
209

ATTACHMENT F / SPECIAL-STATUS PLANT AND WILDLIFE SPECIES WITH POTENTIAL TO OCCUR ON THE PROJECT SITE 12760 F-4
JULY 2023

Special -Status Plant Species Potential to Occur on the Project Site Scientific
Name
Common
Name
Status
(Federal/State/CR
PR)
Primary Habitat Associations/ Life Form/
Blooming Period/ Elevation Range (feet) Potential to Occur Lasthenia
conjugens
Contra Costa
goldfields
FE/None/1B.1 Cismontane woodland, Playas, Valley and foothill grassland, Vernal pools; Mesic/annual herb/Mar–
June/0–1,540
Not expected to occur. This species was not
observed during botanical surveys conducted in
May and July 2022. In addition, no suitable vernal
pool habitat is present within the Project site to
support this species. This species is typically
observed farther north in California, around the San
Francisco Bay area. The nearest occurrence was
last observed in 1950, approximately 2.6 miles
southeast of the Project site (CDFW 2022b).

Lasthenia glabrata
ssp. coulteri
Coulter's goldfields None/None/1B.1 Marshes and swamps, Playas, Vernal pools/annual herb/Feb–June/5–4,000
Not expected to occur. This species was not
observed during botanical surveys conducted in
May and July 2022. In addition, no suitable vernal
pool or marsh and swamp habitat is present within
the Project site to support this species. A known
population occurs approximately 2.9 miles east of
the Project site (CDFW 2022b).

Layia heterotricha pale-yellow layia None/None/1B.1 Cismontane woodland, Coastal scrub, Pinyon and juniper woodland, Valley and foothill grassland; Alkaline (sometimes), Clay (sometimes)/annual herb/Mar–
June/985–5,590
Not expected to occur. The site is outside of the
species’ known elevation range.

Lepechinia
fragrans
fragrant pitcher
sage
None/None/4.2 Chaparral/perennial shrub/Mar–Oct/65–4,295 Not expected to occur. This species was not observed during botanical surveys conducted in
May and July 2022. In addition, no suitable
chaparral habitat is present within the Project site to support this species. The nearest occurrence is
from 2020, approximately 6.9 miles northeast of the
Project site (Caflora 2022).

Lonicera
subspicata var.
subspicata
Santa Barbara
honeysuckle
None/None/1B.2 Chaparral, Cismontane woodland, Coastal
scrub/perennial evergreen shrub/(Feb)May–
Aug(Dec)/35–3,280
Occurs within the Project site. This species was
observed within several channelized areas mapped
as non-wetland waters during botanical surveys
conducted in May and July 2022.
210

ATTACHMENT F / SPECIAL-STATUS PLANT AND WILDLIFE SPECIES WITH POTENTIAL TO OCCUR ON THE PROJECT SITE 12760 F-5
JULY 2023

Special -Status Plant Species Potential to Occur on the Project Site Scientific
Name
Common
Name
Status
(Federal/State/CR
PR)
Primary Habitat Associations/ Life Form/
Blooming Period/ Elevation Range (feet) Potential to Occur Malacothrix
saxatilis var.
saxatilis
cliff malacothrix None/None/4.2 Coastal bluff scrub, Coastal scrub/perennial rhizomatous herb/Mar–Sep/10–655
Occurs within the Project site. This species was
observed within coastal bluff scrub on the cliffs
above the beach during botanical surveys
conducted in May and July 2022.

Monardella
hypoleuca ssp.
hypoleuca
white-veined
monardella
None/None/1B.3 Chaparral, Cismontane woodland/perennial herb/(Apr)May–Aug(Sep–Dec)/165–5,000
Not expected to occur. This species was not
observed during botanical surveys conducted in
May and July 2022. In addition, no suitable
chaparral or cismontane woodland habitat is
present within the Project site to support this
species. The Project site is outside of the species'
known elevation range.

Pelazoneuron
puberulum var.
sonorensis
Sonoran maiden
fern
None/None/2B.2 Meadows and seeps/perennial rhizomatous herb/Jan– Sep/165–2,000
Not expected to occur. The Project site is outside of
the species' known elevation range. In addition, this
species was not observed during botanical surveys
conducted in May and July 2022.

Scrophularia atrata black-flowered
figwort
None/None/1B.2 Chaparral, Closed-cone coniferous forest, Coastal dunes, Coastal scrub, Riparian scrub/perennial
herb/Mar–July/35–1,640
Not expected to occur. This perennial species was
not observed during botanical surveys conducted in
May and July 2022. Limited suitable coastal dune
habitat is present within the Project site that could
support this species. The nearest occurrence is
from 1958, approximately 2.6 miles southeast of the
Project site (CDFW 2022b).

Suaeda esteroa estuary seablite None/None/1B.2 Marshes and swamps/perennial herb/(Jan–May)July– Oct/0–15
Not expected to occur. This species was not
observed during botanical surveys conducted in
May and July 2022. In addition, no suitable marsh
or swamp habitat is present within the Project site
to support this species. The nearest occurrence is
from 1979, approximately 3.3 miles east of the
Project site (CDFW 2022b).
1 The federal and state status of species is based on the Special Animals List (CDFW 2022c).

Status Abbreviations
FE: Federally listed as endangered
FT: Federally listed as threatened
211

ATTACHMENT F / SPECIAL-STATUS PLANT AND WILDLIFE SPECIES WITH POTENTIAL TO OCCUR ON THE PROJECT SITE 12760 F-6
JULY 2023

FC: Federal candidate species (former Category 1 candidates) FPD: Federally proposed for delisting
BCC: U.S. Fish and Wildlife Service Bird of Conservation Concern SSC: California Species of Special Concern
FP: California Fully Protected Species
WL: California Watch List Species
SE: State listed as endangered
ST: State listed as threatened
SCD: State candidate for delisting

Special -Status Wildlife Species with Potential to Occur on the Project Site Scientific
Name
Common
Name
Status
(Federal/State) Habitat Potential to Occur
Amphibians
Rana boylii
pop. 6
foothill yellow-
legged frog -
south coast

DPS FPE/SE
Rocky streams and rivers with open banks in
forest, chaparral, and woodland
Not expected to occur. No suitable rocky
streams or open banks are present within
the BSA to support this species. In
addition, Bell Creek's close proximity to
the coast makes it unsuitable for this
species. The nearest occurrence was
observed in 1933 approximately 7.6 miles
north of the BSA (CDFW 2022b).

Rana draytonii
California red-
legged frog FT/SSC
Lowland streams, wetlands, riparian
woodlands, livestock ponds; dense, shrubby or
emergent vegetation associated with deep,
still or slow-moving water; uses adjacent
uplands
High potential to occur. While this species
was not observed during protocol-level,
focused California red-legged frog surveys
conducted between April and July 2022,
this species has been known to breed in
Bell Creek and has a high potential to still
do so. In addition, there is potential for the
species to disperse across the golf course
and use the golf course pond and other
aquatic features while dispersing. The
nearest occurrence was last observed in
2010 in Bell Creek approximately 0.5
212

ATTACHMENT F / SPECIAL-STATUS PLANT AND WILDLIFE SPECIES WITH POTENTIAL TO OCCUR ON THE PROJECT SITE 12760 F-7
JULY 2023

Special -Status Wildlife Species with Potential to Occur on the Project Site Scientific
Name
Common
Name
Status
(Federal/State) Habitat Potential to Occur
miles north of the Project site (CDFW
2022b).

Taricha torosa California newt None/SSC
Wet forests, oak forests, chaparral, and rolling
grassland
Not expected to occur. Occurrences of this
species in the vicinity are limited to the
Santa Ynez Mountains and foothills, and it
is not known to be along the immediate
coast. The nearest occurrence is from
2011, approximately 1.5 miles north of
the Project site in Ellwood Canyon (CDFW
2022b).

Birds
Accipiter
cooperii
(nesting) Cooper's hawk None/WL
Nests and forages in dense stands of live oak,
riparian woodlands, or other woodland
habitats often near water
High potential to nest. Stands of
eucalyptus trees are present within
several areas of the Project site that
provide suitable nesting habitat. In
addition, the riparian woodland habitat
found adjacent to Bell Creek provides
suitable nesting habitat for this species.

The nearest nesting occurrence, from
2019, is from approximately 0.25 miles
east of the BSA (SBAS 2022). One
individual was observed perching offsite,
north of Hollister, during raptor surveys in
2022.

Agelaius
tricolor (nesting
colony)
tricolored
blackbird BCC/SSC, ST
Nests near freshwater, emergent wetland with
cattails or tules, but also in Himalayan
blackberrry; forages in grasslands, woodland,
and agriculture
Not expected to nest. Some emergent
vegetation occurring on the Project site
may provide limited areas of suitable
habitat. But this species is considered
extirpated as a breeder in southern Santa
Barbara County (Lehman 2022). Nesting
has not been recorded in the area in
approximately 40 years. The nearest
occurrence were from Goleta in the 1970s
213

ATTACHMENT F / SPECIAL-STATUS PLANT AND WILDLIFE SPECIES WITH POTENTIAL TO OCCUR ON THE PROJECT SITE 12760 F-8
JULY 2023

Special -Status Wildlife Species with Potential to Occur on the Project Site Scientific
Name
Common
Name
Status
(Federal/State) Habitat Potential to Occur
to early 1980s, more than 3.0 miles to the
east (CDFW 2022b).

Ammodramus
savannarum
(nesting)
grasshopper
sparrow None/SSC
Nests and forages in moderately open
grassland with tall forbs or scattered shrubs
used for perches
Low potential to occur. Although the
species occurs at nearby Ellwood Mesa
(SBAS 2022; Lehman 2022), the Project
site supports only fragmented suitable
open grassland habitat and generally
lacks suitable scattered shrubs this
species uses for perching.

Athene
cunicularia
(burrow sites &
some wintering
sites) burrowing owl BCC/SSC
Nests and forages in grassland, open scrub,
and agriculture, particularly with ground
squirrel burrows
Low potential to occur. While this species
has been observed on golf courses, it is
considered extirpated as a nesting species
in southern Santa Barbara County (2022).

California ground squirrel presence on the
Project site suggests some potential for
this species to occur in fall or winter, when
it is a rare visitor to the area, such as at
the North Campus Open Space, University
of California, Santa Barbara,
approximately 1.0 mile east of the Project
site (CLO 2022). However, most open
areas are well maintained, and consistent
human presence on the golf course is
likely to deter overwintering.

Aythya
americana redhead None/SSC
Nests in freshwater emergent vegetation in
areas with deep open water, as well as in
some more alkaline areas.

Not expected to nest. This species was
observed within the golf course pond in
January 2022 (CLO 2022), during its
wintering period. Suitable habitat is
absent on the Project site. The nearest
known nesting locations are along the
northern coast of Santa Barbara County
(Lehman 2022).
214

ATTACHMENT F / SPECIAL-STATUS PLANT AND WILDLIFE SPECIES WITH POTENTIAL TO OCCUR ON THE PROJECT SITE 12760 F-9
JULY 2023

Special -Status Wildlife Species with Potential to Occur on the Project Site Scientific
Name
Common
Name
Status
(Federal/State) Habitat Potential to Occur
Charadrius
nivosus nivosus
(nesting)
western snowy
plover FT, BCC/SSC
On coasts nests on sandy marine and
estuarine shores; in the interior nests on
sandy, barren or sparsely vegetated flats near
saline or alkaline lakes, reservoirs, and ponds
Low potential to occur. Not expected to
nest. Any potential for this species to
occur is likely limited to the small dune
area just west of Bell Creek, away from the
golf course. Although this species is
known to nest approximately 1.0 mile to
the southeast, at Coal Oil Point Reserve
(CDFW 2022b, SBAS 2022), it has never
been observed nesting within or adjacent
to the Project site, and the beach below
the bluffs is too narrow and subject to
inundation during high tides to support
nesting by this species. If the species
forages here on occasion, this would occur
only on the beaches, away from the golf
course.

Elanus
leucurus
(nesting)
white-tailed
kite None/FP
Nests in woodland, riparian, and individual
trees near open lands; forages
opportunistically in grassland, meadows,
scrubs, agriculture, emergent wetland,
savanna, and disturbed lands
Moderate potential to nest. Suitable trees
are present to support nesting, especially
along the eastern boundary of the Project
site. Willows and other trees along Bell
Creek and some trees elsewhere on the
golf course may also provide suitable
nesting habitat, although relatively
continual human presence may limit the
potential for nesting. Although a pair was
observed on the Project site in 2004
(TOBC 2004a), no evidence of nesting was
observed, and the species was not
subsequently detected. No white-tailed
kites were observed on the site during
surveys in 2022. The General Plan/CLUP
species map (City 2016) includes a
nesting occurrence immediately adjacent
215

ATTACHMENT F / SPECIAL-STATUS PLANT AND WILDLIFE SPECIES WITH POTENTIAL TO OCCUR ON THE PROJECT SITE 12760 F-10
JULY 2023

Special -Status Wildlife Species with Potential to Occur on the Project Site Scientific
Name
Common
Name
Status
(Federal/State) Habitat Potential to Occur
to the eastern boundary of the Project site.

Additional nesting occurrences are from
as near as 0.3 miles to the east, in 2010
(SBAS 2022).

Falco
mexicanus
(nesting) prairie falcon None/WL
Forages in grassland, savanna, rangeland,
agriculture, desert scrub, alpine meadows;
nest on cliffs or bluffs
Not expected to occur. No suitable nesting
cliffs or bluffs are present on the Project
site, and any occurrence of this species is
very rare in southern Santa Barbara
County (Lehman 2022). CNDDB includes
several historical occurrences from
unspecified locations well north of the
site, but there are no recent records of
this species nesting anywhere on the
south coast (Lehman 2022, CDFW
2022b).

Falcon
peregrinus
anatum
American
peregrine
falcon FD/SD, FP
Near wetlands, lakes, rivers, or other water; on
cliffs, banks, dunes, mounds; also, human-
made structures.

Not expected to nest. This species has
been reported on several occasions since
2017 through the eBird database (CLO
2022) and likely occurs here while
foraging at different times of year.

Waterfowl and other birds attracted to the
golf course pond probably provide an
attractant to foraging peregrine falcons,
but nesting habitat is absent.

Passerculus
sandwichensis
beldingi
Belding's
savannah
sparrow BCC/SE
Nests and forages in coastal saltmarsh
dominated by pickleweed (Salicornia spp.)
Not expected to occur. No suitable coastal
saltmarsh habitat is present on the Project
site, which is just north of the known
range of this subspecies, which occurs
north to Devereux Slough, approximately

1.4 miles to the southeast (Lehman
2022).
216

ATTACHMENT F / SPECIAL-STATUS PLANT AND WILDLIFE SPECIES WITH POTENTIAL TO OCCUR ON THE PROJECT SITE 12760 F-11
JULY 2023

Special -Status Wildlife Species with Potential to Occur on the Project Site Scientific
Name
Common
Name
Status
(Federal/State) Habitat Potential to Occur
Pelecanus
occidentalis
californicus
(nesting
colonies &
communal
roosts)
California
brown pelican FPD/FP, SCD
Forages in warm coastal marine and estuarine
environments; in California, nests on dry,
rocky offshore islands
Observed on the Project Site. Not
expected to nest. The nearest breeding
locations are on the Channel Islands, at
Anacapa Island and Santa Barbara Island.

Regular roosting locations are along the
immediate shore. One was observed
during surveys in May 2022, resting at the
golf course pond. But this species
generally stays along the beach and in
nearshore waters.

Plegadis chihi white-faced ibis None/None
Observed on the Project Site. Not
expected to nest and expected to occur
only as a rare visitor. This species is not
known to nest in Santa Barbara County
(Lehman 2022). The only observations on
the Project site during surveys were of
single foraging birds in the spring and
early summer 2022. Individuals and small
flocks have been reported in the eBird
database (CLO 2022).

Rallus
obsoletus
levipes
Light-footed
Ridgway’s rail FE/FP, SE
Coastal wetlands, brackish areas, coastal
saline emergent wetlands
Not expected to occur. No suitable coastal
wetlands, brackish areas, or coastal saline
emergent wetlands are present within the
Project site. The nearest occurrence was
in 1974 approximately 3.2 miles east of
the Project in the Goleta Slough, where
believed to be extirpated (CDFW 2022b;
Lehman 2022).

Riparia riparia
(nesting) bank swallow None/ST
Nests in riparian, lacustrine, and coastal areas
with vertical banks, bluffs, and cliffs with
sandy soils; open country and water during
migration
Not expected to occur. This species is no
longer known to nest in Santa Barbara
County (Lehman 2022) and may be
extirpated as a breeding species in
southern California. The nearest CNDDB
217

ATTACHMENT F / SPECIAL-STATUS PLANT AND WILDLIFE SPECIES WITH POTENTIAL TO OCCUR ON THE PROJECT SITE 12760 F-12
JULY 2023

Special -Status Wildlife Species with Potential to Occur on the Project Site Scientific
Name
Common
Name
Status
(Federal/State) Habitat Potential to Occur
occurrence was in 1913 approximately

7.3 miles east of the Project site (CDFW
2022b). The species may pass over the
Project site occasionally during migration.

Setophaga
petechia yellow warbler None/SSC
Riparian plant associations in close proximity
to water. Also nests in montane shrubbery in
open conifer forests in the Cascades and
Sierra Nevada.

Low potential to nest. This species was
detected during raptor surveys in April
2022 and likely occurs regularly as a
migrant on the Project site, in spring and
fall. No evidence of nesting has been
detected, but marginally suitable nesting
habitat occurs along Devereux Creek.

Sternula
antillarum
browni (nesting
colony)
California least
tern FE/FP, SE
Forages in shallow estuaries and lagoons;
nests on sandy beaches or exposed tidal flats
Not expected to occur. No suitable nesting
habitat occurs on the Project site. The
species likely occurs along the shore
during migration and post-breeding
dispersal. Nesting formerly occurred
approximately 1.2 miles southeast of the
Project site, at the mouth of Devereux
Slough (now Coal Oil Point Reserve), and
several pairs nested here again in 2004 to
2007 (Lehman 2022).

Xanthocephalu
s
xanthocephalus
yellow-headed
blackbird None/None
Observed on the Project site. A single
individual was observed in May 2022 in
the vicinity of the golf course pond.

However, this observation was consistent
with migration, and the species is not
known to nest anywhere in Santa Barbara
County.

Fishes
Eucyclogobius
newberryi tidewater goby FE/None
Brackish water habitats along the California
coast from Agua Hedionda Lagoon, San Diego
County, to the mouth of the Smith River
Observed. While this species was not
observed incidentally in Bell Creek during
other biological surveys, this species has
been observed previously in Bell Creek, on
218

ATTACHMENT F / SPECIAL-STATUS PLANT AND WILDLIFE SPECIES WITH POTENTIAL TO OCCUR ON THE PROJECT SITE 12760 F-13
JULY 2023

Special -Status Wildlife Species with Potential to Occur on the Project Site Scientific
Name
Common
Name
Status
(Federal/State) Habitat Potential to Occur
the Project site (Goleta 2006). USFWS has
designated this area as critical habitat.

Invertebrates
Bombus
crotchii
Crotch bumble
bee None/None
Open grassland and scrub communities
supporting suitable floral resources.

Low potential to occur. While suitable
open grassland habitat is present within
the Project site, the generally maintained
nature of the site limits the availability of
both suitable floral resources and nesting
and wintering habitat. As CNDDB includes
an occurrence from 2017 approximately

0.2 miles east of the Project site, the
species may fly over the site on occasion
(CDFW 2022b).

Coelus
globosus
globose dune
beetle None/None
Inhabitant of coastal sand dune habitat;
erratically distributed from Ten Mile Creek in
Mendocino County south to Ensenada, Mexico
Low potential to occur. Suitable habitat
may occur along the beach, well away
from the golf course. And suitable habitat
may be limited to areas west of Bell Creek
lagoon. The nearest occurrences are from
less than 0.5 miles southeast and west of
the Project site (CDFW 2022b).

Danaus
plexippus pop.
1 monarch FC/None
Wind-protected tree groves with nectar
sources and nearby water sources
Observed on the Project site. A known
monarch roost at the eastern boundary
overlaps the Project site. A cluster of 98
individuals were observed on the Project
site in 2003, and more were observed in
the roosting grove just offsite. No
clustering butterflies were observed here
during surveys in 2021-2022, but
butterflies were observed in flight in
several locations on the Project site.

Several additional known roosting sites
are near the Project site.
219

ATTACHMENT F / SPECIAL-STATUS PLANT AND WILDLIFE SPECIES WITH POTENTIAL TO OCCUR ON THE PROJECT SITE 12760 F-14
JULY 2023

Special -Status Wildlife Species with Potential to Occur on the Project Site Scientific
Name
Common
Name
Status
(Federal/State) Habitat Potential to Occur
Mammals
Antrozous
pallidus pallid bat None/SSC
Grasslands, shrublands, woodlands, forests;
most common in open, dry habitats with rocky
outcrops for roosting, but also roosts in man-
made structures and trees.

Not expected to roost. Moderate potential
to forage. No suitable rocky outcrops or
manmade structures present to support
the roosting habits of this species. This
species may forage on occasion over the
Project site. The nearest occurrence is an
acoustic detection from 2017
approximately 1.8 miles east of the
Project site (CDFW 2022b).

Corynorhinus
townsendii
Townsend's
big-eared bat None/SSC
Mesic habitats characterized by coniferous
and deciduous forests and riparian habitat,
but also xeric areas; roosts in limestone caves
and lava tubes, man-made structures, and
tunnels
Not expected to roost. Low potential to
forage. No suitable roosting habitat is
present in the survey area. The nearest
occurrence is from 2005, approximately

4.3 miles northwest of Project site (CDFW
2022b).

Eumops perotis
californicus
western mastiff
bat None/SSC
Chaparral, coastal and desert scrub,
coniferous and deciduous forest and
woodland; roosts in crevices in rocky canyons
and cliffs where the canyon or cliff is vertical
or nearly vertical, trees, and tunnels
Not expected to occur. Suitable roosting
habitat is absent from the vicinity. The
nearest occurrence is an acoustic
detection from 2008, approximately 5.9
miles east of the Project site (CDFW
2022b).

Lasiurus
blossevillii western red bat None/SSC
Forest, woodland, riparian, mesquite bosque,
and orchards, including fig, apricot, peach,
pear, almond, walnut, and orange; roosts in
tree canopy
Low potential to roost. Moderate potential
to forage. While riparian habitat occurs on
the Project site, the species prefers more
well-developed riparian habitats. Much of
the site is suitable foraging habitat. The
nearest occurrence is an acoustic
detection from 2017, approximately 1.8
miles east of the Project site (CDFW
2022b).
220

ATTACHMENT F / SPECIAL-STATUS PLANT AND WILDLIFE SPECIES WITH POTENTIAL TO OCCUR ON THE PROJECT SITE 12760 F-15
JULY 2023

Special -Status Wildlife Species with Potential to Occur on the Project Site Scientific
Name
Common
Name
Status
(Federal/State) Habitat Potential to Occur
Myotis
yumanensis Yuma myotis None/None
Riparian, arid scrublands and deserts, and
forests associated with water (streams, rivers,
tinajas); roosts in bridges, buildings, cliff
crevices, caves, mines, and trees
Moderate potential to roost. Moderate
potential to forage. The primary roosting
habitat types are absent from the Project
site, but this species may roost
occasionally, such as for night roosts, in
trees on the Project site. Suitable riparian
and aquatic foraging habitat is present
within the Project site, along Devereux and
Bell Creeks. The nearest occurrence is an
acoustic detection from 2008,
approximately 5.9 miles east of the
Project site (CDFW 2022b).

Neotoma lepida
intermedia
San Diego
desert woodrat None/SSC
Coastal scrub, desert scrub, chaparral, cacti,
rocky areas
Not expected to occur. Some coastal
scrub and coastal bluff scrub on the
Project site may be suitable, but this
species is not known to occur along the
immediate coast locally. No woodrat
middens were observed during surveys in
2021-2022. The nearest occurrence is
from 2015, approximately 5.7 miles
northeast of the Project site, in the
foothills of the Santa Ynez Mountains
(CDFW 2022b).

Taxidea taxus
American
badger None/SSC
Dry, open, treeless areas; grasslands, coastal
scrub, agriculture, and pastures, especially
with friable soils
Low potential to occur. The supports open
areas superficially suitable for this
species, but it lacks the prey base
required by this species and is too subject
to disturbance from human present to
support residence by the species. It is
possible this species passes through on
occasion, while moving between more
suitable habitats, during night hours. The
nearest CNDDB occurrence is from 1922,
221

ATTACHMENT F / SPECIAL-STATUS PLANT AND WILDLIFE SPECIES WITH POTENTIAL TO OCCUR ON THE PROJECT SITE 12760 F-16
JULY 2023

Special -Status Wildlife Species with Potential to Occur on the Project Site Scientific
Name
Common
Name
Status
(Federal/State) Habitat Potential to Occur
approximately 9.9 miles west of the survey
area (CDFW 2022b).

Reptiles
Anniella
pulchra
northern
California
legless lizard None/SSC
Coastal dunes, stabilized dunes, beaches, dry
washes, valley–foothill, chaparral, and scrubs;
pine, oak, and riparian woodlands; associated
with sparse vegetation and sandy or loose,
loamy soils
Low potential to occur. Riparian woodland
or coastal scrub habitats in the survey
area have a small potential to support this
species. But unmaintained areas are very
limited on the Project site and are mostly
isolated from populations elsewhere. The
nearest, recent CNDDB occurrence is from
2018, approximately 6.4 miles northwest
of the Project site, in the leaf litter of a
coast live oak woodland (CDFW 2022b).

Emys
marmorata
western pond
turtle None/SSC
Slow-moving permanent or intermittent
streams, ponds, small lakes, and reservoirs
with emergent basking sites; adjacent uplands
used for nesting and during winter
Moderate potential to occur. Bell Creek
provides suitable aquatic habitat to
support this species. Dudek observed this
species in May 2022, approximately 0.75
miles west of the Project site in Tecolote
Creek, and it may also occur in Bell Creek,
on the Project site. Although the bluff and
dense vegetation at the eastern edge of
the golf course may present an obstacle to
movement onto the golf course, it may
have a low potential to reach this area.

Phrynosoma
blainvillii
Blainville's
horned lizard None/SSC
Open areas of sandy soil in valleys, foothills,
and semi-arid mountains including coastal
scrub, chaparral, valley–foothill hardwood,
conifer, riparian, pine–cypress, juniper, and
annual grassland habitats
Low potential to occur. Coastal scrub and
coastal bluff scrub along the bluffs provide
suitable habitat for this species, but it is
not known from the coast in the
immediate vicinity. The nearest
occurrence is from 2010, approximately

6.7 miles northeast of the Project site
(CDFW 2022b).
222

ATTACHMENT F / SPECIAL-STATUS PLANT AND WILDLIFE SPECIES WITH POTENTIAL TO OCCUR ON THE PROJECT SITE 12760 F-17
JULY 2023

1 The federal and state status of species is based on the Special Animals List (CDFW 2022c).

Status Abbreviations
FE: Federally listed as endangered
FT: Federally listed as threatened
FC: Federal candidate species (former Category 1 candidates) FPD: Federally proposed for delisting
BCC: U.S. Fish and Wildlife Service Bird of Conservation Concern SSC: California Species of Special Concern
FP: California Fully Protected Species
WL: California Watch List Species
SE: State listed as endangered
ST: State listed as threatened
SCD: State candidate for delisting

Special -Status Wildlife Species with Potential to Occur on the Project Site Scientific
Name
Common
Name
Status
(Federal/State) Habitat Potential to Occur
Salvadora
hexalepis
virgultea
coast patch-
nosed snake None/SSC
Brushy or shrubby vegetation; requires small
mammal burrows for refuge and overwintering
sites
Not expected to occur. This species is
known in the vicinity from chaparral
habitats in the Santa Ynez Mountains but
is not known to occur in the lowlands of
the south coast of Santa Barbara County.

The nearest CNDDB occurrence is from
1978, approximately 7.4 miles northwest
of the Project site (CDFW 2022b).
223

Appendix G
Wetland Determination Data Forms
224
225
226
227
228
229
230
231
232
233
234
235
236
237
238
239
240
241
242
243
244
245
246
247
248
249
250
251
252
253
254
255
256

MEMORANDUM
To: City of Goleta, Planning and Environmental Review Department From: Dave Compton, Senior Wildlife Biologist, Dudek
John Davis IV, Principal/Senior Coastal Ecologist, Dudek Subject: Memorandum Describing Environmentally Sensitive Habitat Areas (ESHAs) for the Sandpiper Golf Club Project
Date: August 7, 2023
Revised October 26, 2023
cc: Steve Welton, SEPPS
Chip Wullbrandt, Price, Postel, and Parma, LLP
Bill Medel
Attachment(s): A: Figures 1. Project Location
Figure 2. General Plan (Figure 4-1) Special-Status Species and ESHA Figure 3. Sensitive Resources Identified during Surveys, 2021-2022 Figure 4. ESHA Comparison
B: Photographic Documentation
This revised memorandum reviews existing and new Environmentally Sensitive Habitat Areas (ESHAs) that Dudek identified in Biological Resources Assessment Report for the Sandpiper Golf Club Project ( BRAR; Dudek 2023). In addition, Dudek has expanded the ESHA discussion to incorporate responses to comments raised in the Notice of Application Incompleteness (2 nd Submittal) dated September 6, 2023 , and a follow up meeting with the City of Goleta (City) regarding the letter on October 3, 2023. The responses are generally found in Section 3 of the memo.

The Project site occurs in the western portion of the City of Goleta, within the Coastal Zone (Attachment A: Figure 1, Project Location). The City’s General Plan/Coastal Land Use Plan (CLUP; City of Goleta 2006) includes Figure 4 -1 Special-Status Species and Environmentally Sensitive Habitat Areas, updated through 2016 (City of Goleta 2016 ; Attachment A; Figure 2, General Plan (Figure 4 -1) Special-Status Species and ESHA ). As part of the Project, the Sandpiper Golf Club Trust is seeking an amendment to the General Plan/CLUP that would result in revisions to ESHA as depicted on Figure 4-1.
1 ESHA in the City of Goleta
Figure 4.1 of the in the General Plan/CLUP depicts sensitive biological resources throughout the City of Goleta (Attachment A: Figure 2) . These resources include occurrences of special -status plants and wildlife and various ESHAs that have previously been identified. Figure 4-1 is not considered a comprehensive map of ESHAs occurring in the City of Goleta. In addition to the map provided in Figure 4-1, Policy CE 1.2 provides a list of habitat types that are considered ESHA, including:
a. Creek and riparian areas.
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b. Wetlands, such as vernal pools.
c. Coastal dunes, lagoons, or estuaries, and coastal bluffs/coastal bluff scrub. d. Beach and shoreline habitats.
e. Marine habitats.
f. Coastal sage scrub and chaparral.
g. Native woodlands and savannahs, including oak woodlands. h. Native grassland.
i. Monarch butterfly aggregation sites, including autumnal and winter roost sites, and related habitats. j. Beach and dune areas that are nesting and foraging locations for the western snowy plover. k. Nesting and roosting sites and related habitat areas for various species of raptors. l. Other habitat areas for species of wildlife or plants designated as rare, threatened, or endangered under state or federal law.
m. Any other habitat areas that are rare or especially valuable from a local, regional, or statewide perspective.

The Conservation Element of the General Plan/CLUP includes Policy CE 1.3 with regard to site-specific studies and unmapped ESHAs. In addition, the General Plan/CLUP includes a policy (CE 1.5) requiring corrections to ESHA as depicted in Figure 4-1, and the amendment of Figure 4-1 based on these changes. These policies are as follows:

CE 1.3 Site-Specific Studies and Unmapped ESHAs. [GP/CP] Any area not designated on the ESHA map in Figure 4-1 that meets the ESHA criteria for the resources specified in CE 1.1 shall be granted the same protections as if the area was shown on the map. Proposals for development on sites where ESHAs are shown on the map or where there is probable cause to believe that ESHAs may exist shall be required to provide the City with a site-specific biological study that includes the following information:
a. A base map that delineates topographic lines, parcel boundaries, and adjacent roads. b. A vegetation map that identifies species that may be indicators of ESHAs. c. A soils map that delineates hydric and nonhydric soils, if applicable. d. A census of animal species that indicates the potential existence of ESHAs. e. A detailed map that shows the conclusions regarding the boundary, precise location and extent, or current status of the ESHA based on substantial evidence provided in the biological studies. 258

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CE 1.5 Corrections to Map of ESHAs. [GP/CP] If a site-specific biological study contains substantial evidence that an area previously shown as an ESHA on Figure 4 -1 does not contain habitat that meets the definition of an ESHA for reasons other than that set forth in CE 1.4, the City biolog ist and the Planning Commission shall review all available information and determine if the area in question should no longer be considered an ESHA and therefore not be subject to the ESHA protection policies of this plan . If the final decision - making body determines that the area is not an ESHA, a map modification shall be included in the next General Plan/Coastal Land Use Plan amendment; however, Local Coastal Program policies and standards for protection of ESHAs shall not apply, and approval of development consistent with all other requirements of this plan may be considered prior to the map revision.

In addition, the General Plan/LCP includes policies applying to creeks as ESHA, and to Streamside Protection Areas, including Policy CE 2.1 Policy, Designation of Protected Creeks; Policy CE 2.2, Streamside Protection Areas; Policy CD 2.3, Allowable Uses and Activities in Streamside Protection Areas; and Policy CE 2.6, Restoration of Degraded Creeks. These policies specifically refer to creeks depicted on Figure 4-1, as follows:

CE 2.1 Designation of Protected Creeks. [GP/CP] The provisions of this policy shall apply to creeks shown in Figure 4-1. These watercourses and their associated riparian areas are defined as ESHAs. They serve as habitat for fish and wildlife, provide wildlife movement corridors, provide for the flow of stormwater runoff and floodwaters, and furnish open space and passive recreational areas for city residents.

CE 2.2 Streamside Protection Areas. [GP/CP] A Streamside Protection Area (SPA) is hereby established along both sides of the creeks identified in Figure 4-1. The purpose of the designation shall be to preserve the SPA in a natural state in order to protect the associated riparian habitats and ecosystems. The SPA shall include the creek channel, wetlands and/or riparian vegetation related to the creek hydrology, and an adjacent upland buffer area. The width of the SPA upland buffer shall be as follows:
a. The SPA upland buffer shall be 100 feet outward on both sides of the creek, measured from the top of the bank or the outer limit of wetlands and/or riparian vegetation, whichever is greater. The City may consider increasing or decreasing the width of the SPA upland buffer on a case-by-case basis at the time of environmental review. The City may allow portions of a SPA upland buffer to be less than 100 feet wide, but not less than 25 feet wide, based on a site specific assessment if (1) there is no feasib le alternative siting for development that will avoid the SPA upland buffer; and (2) the project’s impacts will not have significant adverse effects on streamside vegetation or the biotic quality of the stream. b. If the provisions above would result in any legal parcel created prior to the date of this plan being made unusable in its entirety for any purpose allowed by the landuse plan, exceptions to the foregoing may be made to allow a reasonable economic use of the parcel, subject to approval of a conditional use permit.

CE 2.3 Allowable Uses and Activities in Streamside Protection Areas. [GP/CP] The following compatible land uses and activities may be allowed in SPAs, subject to all other policies of this plan, including those requiring avoidance or mitigation of impacts:
a. Agricultural operations, provided they are compatible with preservation of riparian resources. b. Fencing and other access barriers along property boundaries and along SPA boundaries. 259

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c. Maintenance of existing roads, driveways, utilities, structures, and drainage improvements. d. Construction of public road crossings and utilities, provided that there is no feasible, less environmentally damaging alternative.
e. Construction and maintenance of foot trails, bicycle paths, and similar low -impact facilities for public access.
f. Resource restoration or enhancement projects.
g. Nature education and research activities.
h. Low-impact interpretive and public access signage.
i. Other such Public Works projects as identified in the Capital Improvement Plan, only where there are no feasible, less environmentally damaging alternatives
CE 2.5 Maintenance of Creeks as Natural Drainage Systems . [GP/CP] Creek banks, creek channels, and associated riparian areas shall be maintained or restored to their natural condition wherever such conditions or opportunities exist. Creeks carry a significant amount of Goleta’s stormwater flows. The following standards shall apply:
a. The capacity of natural drainage courses shall not be diminished by development or other activities. b. Drainage controls and improvements shall be accomplished with the minimum vegetation removal and disruption of the creek and riparian ecosystem that is necessary to accomplish the drainage objective. c. Measures to stabilize creek banks, improve flow capacity, and reduce flooding are allowed but shall not include installation of new concrete channels, culverts, or pipes except at street crossings, unless it is demonstrated that there is no feasible alternative for improving capacity. d. Drainage controls in new development shall be required to minimize erosion, sedimentation, and flood impacts to creeks. Onsite treatment of stormwater through retention basins, infiltration, vegetated swales, and other best management practices (BMPs) shall be required in order to protect water quality and the biological functions of creek ecosystems.
e. Alteration of creeks for the purpose of road or driveway crossings shall be prohibited except where the alteration is not substantial and there is no other feasible alternative to provide access to new development on an existing legal parcel. Creek crossin gs shall be accomplished by bridging and shall be designed to allow the passage of fish and wildlife. Bridge abutments or piers shall be located outside creek beds and banks, unless an environmentally superior alternative exists.

CE 2.6 Restoration of Degraded Creeks . [GP/CP] Segments of several creeks in Goleta have been covered or channelized by concrete culverts, causing degradation of the creek ecosystem. Restoration activities for improving degraded creek resources shall include the following:
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f. Channelized creek segments and culverts shall be evaluated and removed to restore natural channel bed and bank, where feasible.
g. Creek courses in public rights-of-way shall be uncovered as part of public works improvement projects. h. Barriers that prevent migration of fish such as anadromous salmonids from reaching their critical habitat shall be removed or modified.
i. Restoration of native riparian vegetation and removal of exotic plant species shall be implemented, unless such plants provide critical habitat for monarch butterflies, raptors, or other protected animals. j. Creek rehabilitation projects shall be designed to maintain or improve flow capacity, trap sediments and other pollutants that decrease water quality, minimize channel erosion, prevent new sources of pollutants from entering the creek, and enhance in-creek and riparian habitat. k. The use of closed-pipe drainage systems for fish-bearing creeks shall be prohibited unless there is no feasible, less environmentally damaging alternative. When the use of culverts is necessary, the culverts shall be oversized and have gravel bottoms that maintain the channel's width and grade.

One additional policy in the Land Use Element of the General Plan, LCP, Policy US 9.3, pertains specifically to Sandpiper Golf Club, and includes a requirement pertaining to ESHA:
l. Any rerouting or alteration of the golf course shall be designed in a manner that protects and enhances environmental resources, including adjacent monarch butterfly habitat areas, Devereux Creek, and other drainages, and that protects safety on the beach.

Dudek conducted site-specific studies for the Sandpiper Golf Club Project in 2021 and 2022 and presented results of its ESHA determination s in the BRAR (Attachment A: Figure 3, Sensitive Resources Identified during Surveys, 2021-2022). The BRAR refined mapping of several ESHAs depicted in Figure 4-1 of the General Plan/CLUP, mapped several new ESHAs, and determined one area depicted as ESHA on Figure 4-1 did not qualify as ESHA. 2 Survey Methods
Several surveys described in the BRAR identified ESHA on the Sandpiper Golf Club Project Site (Attachment A: Figure 1). These included surveys that confirmed the presence of previously known ESHA, identified previously unidentified ESHA, or resulted in refinement of ESHA boundaries. Special-status plant surveys and several focused surveys for special-status wildlife species (monarch butterfly surveys, raptor surveys, California red -legged frog surveys) provided information pertinent to ESHA determinations, but focused on known habitat areas (monarch butterfly, California red-legged frog) and did not affect determination of boundaries of these areas. Identification of potential ESHA raptor habitat was based on the location of raptor nests observed during surveys. Methods of other surveys that identified ESHA require more explanation to clarify how ESHA was determined. 261

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2.1 Vegetation Mapping
Many ESHAs are based on sensitive vegetation communities or sensitive vegetation types, such as riparian vegetation and coastal sage scrub. A Dudek biologist performed vegetation mapping on the Project Site consistent with the Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities (CDFW 2018), and vegetation communities were identified using the Manual of California Vegetation Online (MCV) (CNPS 2023). Vegetation communities were classified based on site factors, descriptions, membership rules, distribution, and characteristic species present in the area. Information such as dominant species and associated cover classes were recorded. In some areas, the vegetation communities observed in th e field did not match those described in MCV (CNPS 2023) or included on the California Natural Community List (NCL; CDFW 2022). In these instances, Dudek generated additional site -specific vegetation community or land cover classifications. Additionally, B ell Canyon vegetation had been mapped as part of the City of Goleta Creek & Watershed Management Plan (City of Goleta 2020); therefore, the vegetation mapping included in this plan was incorporated into the vegetation map.

Vegetation communities were generally mapped to the alliance level, except where mapping to the finer -scale association level was necessary to determine sensitivity in accordance with the NCL (CDFW 2022). Since the Project Site is in the coastal zone, no minimum mapping units apply to sensitive vegetation communities and riparian and wetland vegetation communities; therefore, all sensitive vegetation communities observed were mapped.

Dudek biologists mapped vegetation communities on the Project Site while in the field using an Esri ArcGIS mobile application. A Dudek geographic information system (GIS) technician transferred the vegetation boundaries into an ArcGIS file and created a GIS coverage for vegetation communities. Once major line work and community designations were completed, a geodatabase was created to verify that these data were topologically correct and met final quality control and assurance procedures.

2.2 Native Grassland Mapping
In accordance with Policy CE 5.1 and CE 5.2, native grasslands in Goleta are ESHA. During initial vegetation mapping and identification of biological constraints, the Dudek botanist noted the presence of native grasses. As a result, during the April 2022 special -status plant species survey pass, prior to conducting an assessment of potential native grasslands, the Dudek botanist recorded the general locations of native grasses on the Project Site using an ESRI ArcGIS Field Maps application on a handheld iOS device. In May 2022, the Dudek botanist conducted the native grassland assessment by walking areas with native grasses providing 100% visual survey coverage. When native grasses were observe d, pin flags were placed adja cent to native grass individuals to the outside of the polygon, ensuring the whole native grass plant was included in the polygon. Once an entire polygon was delineated with pin flags, the polygon was assigned a unique identifier and mapped using ESRI ArcGIS Field Maps application on a handheld iOS device boosted with a Trimble R1 by following the pin flag boundary. After mapping the polygon boundaries in the field using global positioning system (GPS) technology , the botanist determined which assessment method of the two described below was most appropriate based on the polygon size.

Quantitative Method
For polygons of native grasses where it was feasible to establish a transect and 1 -meter-square quadrats, the quantitative method was applied. Transect locations were chosen using a non-random design that allowed for the 262

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greatest coverage of the polygon and varied in length, depending on the size of the polygon being assessed. For larger, more irregularly shaped polygons, multiple transects were established. Transect start and end points were recorded when the transect was established. Starting at the zero end of the transect tape, the botanist placed a 1- meter-square quadrat on alternating sides of the transect at 2-meter intervals. Within each 1-meter-square quadrat, the botanist estimated the percent cover of native grasses relative to plant cover and counted the number of native grass individuals. For grass species that were difficult to count, such as salt grass ( Distichlis spicata), the total number of individuals was not recorded.

Qualitative Method
For polygons of native grasses where it was infeasible to establish a transect and 1 -meter-square quadrats (polygons that were too small), the percent cover of native grasses relative to plant cover was visually estimated and the number of native grass individuals was recorded. For grass species that were difficult to count, such as salt grass, the total number of individuals was not recorded.

Upon completing the native grassland field survey, Dudek performed a desktop assessment of the native grass relative plant cover percent and size of each polygon to determine whether polygons met the City defined thresholds for a native grassland (see Goleta General Plan/Coastal Land Use Plan – Policy CE 5: Protection of Other Terrestrial Habitat Areas [GP/CP]). Under the Goleta General Plan/CLUP (City of Goleta 2006), native grasslands are areas were where native grassland species comprise 10% or more of the total relative plant cover. Additionally, the Goleta General Plan/CLUP (City of Goleta 2006) further defines native grasslands by size and includes that removal or disturbance to native grass patches less than 0.25 acres that are clearly isolated and not part of a significant native grassland or an integral component of a larger ecosystem may be allowed.

Dudek biologists calculated the mean native grassland species relative plant cover for the 1-meter-square quadrats for each polygon to determine the coverage of native grassland species for each polygon containing native grasses.

For polygons assessed usin g the qualitative method, the visually estimated relative percent cover of native grassland species was noted for each polygon. Dudek biologists then assessed the size of individual polygons containing native grasses and clusters of polygons containing nat ive grasses to determine if the City defined thresholds for native grasslands was met. Areas identified as native grasslands were then incorporated into the vegetation map.

2.3 Aquatic Resources Delineation
Riparian habitats, creeks, and wetlands are considered ESHA under the General Plan/CLUP. Dudek conducted a field delineation of aquatic resources of the Project Site in accordance with the procedures of the Corps of Engineers Wetlands Delineation Manual (USACE 1987) and the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (Version 2) (USACE 2008a). The instruction guidelines for jurisdictional determinations (USACE 2007) present regulation responsibilities of USACE under the CWA: USACE regulates traditional, navigable waters of the United States, adjacent wetlands, and relatively permanent waters tributary to TNW and adjacent wetlands. Wetland vegetation was classified using CNPS (202 3). Wetland areas under the jurisdiction of USACE were delineated based on the presence of hydric soils, hydrophytic vegetation, and wetland hydrology. Non-wetland waters of the United States under the jurisdiction of USACE were delineated based on the presence of an ordinary high water m ark (OHWM) and nexus to a TNW of the United States. Identification of the OHWM followed the A Field Guide to the Identification of the Ordinary High Water Mark (OHWM) in the Arid West 263

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Region of the Western United States (USACE 2008b), where present. The aquatic resources delineation also included the collection of CDFW jurisdictional boundaries subject to Section 1600 -1616 of the California Fish and Game Code, which extend to the top of bank or the outermost edge of riparian vegetation, whichever is greater, associated with a stream channel or waterway. Additionally , the aquatic resources delineation included waters of the state under the jurisdiction of the RWQCB, pursuant to Section 401 of the federal CWA and the Porter -Cologne Act as wetlands or drainages. T he aquatic resources delineation included an evaluation of the survey area for features meeting the definition of a coastal wetland und er Section 30121 of the CCA.

City of Goleta defines wetlands as the most protective of USFWS, CDFW (formerly California Department of Fish and Game), and CCC wetland definitions using indicators of a single parameter (plants, soil, or hydrology) to determine the boundary of a wetland . Lastly, City of Goleta identifies watercourses and their associated riparian areas as Environmentally Sensitive Habitat Area s (ESHAs) and have associated protection policies .

Hydrophytic Vegetation
During the aquatic resources delineation, a “sampling point” was considered positive for hydrophytic vegetation if it passed the basic dominance test (Indicator 1), meaning that more than 50% of the dominant species sampled were characterized as either obligate, facultative wetland, and/or facultative per the National Wetland Plant List (USACE 2020). A description of the hydrophytic vegetation categories is provided i n Table 1 (Lichvar et al. 2012).

In those cases where the dominance test failed but there were positive indicators of hydric soils and/or hydrology, the vegetation parameter was re-evaluated using the prevalence index (Indicator 2), which takes into account all plant species in the community, not just dominants. All plant species observed during the surveys were identified and recorded.

Table 1. National Indicator Status Ratings and Their Rating Categories Indicator Status (abbreviation)
Percent Occurrence
in Wetlands
Obligate (OBL). Occur almost always under natural conditions in wetlands. 99 Facultative Wetland (FACW). Usually occur in wetlands but occasionally found in non- wetlands. 67–99
Facultative (FAC). Equally likely to occur in wetlands and non-wetlands. 34–66 Facultative Upland (FACU). Usually occur in non-wetlands but occasionally found in wetlands. 1–33
Upland (UPL). Occur in wetlands in another region, but occur almost always under natural conditions in non-wetlands in the region specified. 1 Source: Lichvar et al. 2012
Note: The three facultative categories are subdivided by (+) and (−) modifiers.

Soils
According to the National Technical Committee for Hydric Soils, hydric soils are “soils that are formed under conditions of saturation, flooding, or ponding long enough during the growing season to develop anaerobic conditions in the upper part” (USDA 1994). Soil pits were prepared using a shovel to determine if hydric soils were present. The presence of hydric soils was determined through consultations with the 1987 Manual, as well as Field Indicators of Hydric Soils in the United States v. 7.0 (USDA-NRCS 2010) and the USACE’s Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (Version 2.0) (USACE 2008a). Munsell Soil 264

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Color Charts were used to determine soil chroma and value. Where feasible, soil pits were prepared to depths as deep as 16 inches. Dry soils were moistened to obtain the most accurate color.

Hydrology
Per the guidelines prescribed in the Arid West Supplement (USACE 2008a), wetland hydrology indicators are separated into four major groups: A, B, C, and D. Group A indicators are based on direct observations of surface flow, ponding, and soil saturation/groundwater. Group B indicators consist of evidence that the site has been or is currently subjected to ponding including, but not limited to, water marks, drift deposits, and sediment deposits.

Group C indicators include signs of previous and/or current saturation including oxidized rhizospheres surrounding living roots and the presence of reduced iron or sulfur, both of which are indicative of extended periods of soil saturation. Group D indicators consist of “vegetation and soil features that are indicative of current rather than historic wet conditions and include a shallow aquitard and results of the FAC-Neutral test” (USACE 2008a). Each group is subdivided into primary and secondary categories based on their frequency and reliability to occur in the Arid West region. Signs of hydrology were investigated on site by intensive field review. 3 ESHAs Present on the Project Site
Figure 4 -1 of the General Plan/CLUP (City of Goleta 2016) identified several ESHAs on and adjacent to the Sandpiper Golf Club Project Site. Dudek’s field investigations resulted in confirmation of several of these ESHAs, revisions of boundaries elsewhere, and identification of previously unrecorded ESHAs. In addition, streams occurring on or adjacent to the Project Site would serve as the basis for streamside protection areas, in accordance with Policy CE 2.2.

3.1 City-Mapped ESHA
ESHA depicted on the Project Site in Figure 4-1 of the General Plan/CLUP includes Open Water (the golf course pond), Riparian/Marsh/Vernal Pool (along Devereux Creek and Bell Canyon Creek), Sage Scrub/Dune/Bluff Scrub (along the bluffs), and Monarch Butterfly and/or Raptor Roosting Habitat (along the eastern boundary and in Bell Creek Canyon in the west) ( Attachment A: Figure 2, General Plan (Figure 4 -1) Special-Status Species and ESHA ).

The City requested that, “the ESHA mapping needs to include Devereaux Creek (in Figures 2 and 3) for purposes of analyzing Streamside Protection Areas .” Please see Section 3.2.6 . Additionally, the City requested that ESHA mapping include special-status species location on site (such as [California] red-legged frog) and ESHA and special- status species adjacent to the project site. Please see Attachment A: Figures 2 and 5 and an explanation for the California red-legged frog habitat in Section 3.2.5. Lastly, the City requested that, “…the General Plan consistency analysis should include how the project is consistent with CE 2.6(a).” Habitat restoration is addressed in Section

3.2.6.1. 3.2 Dudek-Identified ESHA
Dudek identified the above features, but revised the mapping of several and determined that the open water associated with the golf course pond may not meet the City’s definition of ESHA (Attachment A: Figure 3, Table 2).

Dudek also identified previously undocumented ESHA in several locations on the Project Site. This section describes areas Dudek identified as ESHA, including newly identified ESHAs, describes differences between Dudek’s ESHA 265

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mapping and the City’s, and provides Dudek’s rationale for ESHA boundaries th at differ from the City’s. Table 2 provides a list of all ESHA types identified on the Project Site, whether Dudek’s mapping or ESHA determination differed from the City’s, buffers suggested in the General Plan/CLUP, and potential buffer reductions, based on General Plan/CLUP policies. All ESHAs and special-status species discussed below are included on the Preliminary Landscape Layout Plan (Earthform 2023).

Table 2. ESHAs Occurring on the Sandpiper Golf Course Project Site ESHA Type Dudek Revisions
General Plan/CLUP
Buffer (ft)
Potential Buffer
Reduction (minimum
ft)
Vegetation Communities and Land Covers
Coast live oak woodland
(riparian)
Newly identified along
Bell Canyon Creek,
outside riparian
100 25
Coastal sage
scrub/coastal bluff
scrub*
Minor boundary revisions 25 N.A.

Needlegrass-melic grass
grassland (native
grassland)
Newly identified 10 N.A.

Beach Dudek assumed all beach
could be ESHA
N.A. N.A.

Open Water Determined not ESHA 100 N.A.

Riparian and Wetland Habitats
Riparian** Boundary revisions
(additions and
subtractions)
100 25
Coastal wetlands Confirmed and newly
identified
100 50
Rare Plant Habitat
Habitats supporting cliff
malacothrix, red sand-
verbena, Santa Barbara
honeysuckle, Southern
California black walnut,
and woolly seablite
Newly identified (all
within ESHA vegetation
communities or wildlife
habitats, or within
buffers)
N.A. N.A.

Wildlife Habitat
Monarch roost Confirmed 100 50
Raptor nest Newly identified 100
300 ft for disturbance
when occupied
N.A.

Note: Table note example.
* Coastal sage scrub/coastal bluff scrub identified on the Project Site includes several distinct vegetation communities included in the CDFW Natural Communities List (CDFW 2022) and the Manual of California Vegetation Online (CNPS 2023): coyote brush scrub, Baccharis pilularis – Toxicodendron diversilobum association, quailbush scrub alliance, California brittle bush scrub alliance, and coastal sage scrub.
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** Riparian habitats identified as ESHA included arroyo willow thickets and a riparian form of eucalyptus woodland along Devereux Creek.
† Includes both areas depicted in Figure 4-1 of the General Plan/CLUP as “emergent wetland” and previously unmapped ESHAs near the ocean bluff.

3.2.1 Coast Live Oak Woodland
Dudek mapped coast live oak woodland on the east side of Bell Canyon Creek ( Attachment A, Figure 32). The General Plan/CLUP Figure 4-1 includes ESHAs designated as Native Upland Woodlands/Savannahs, but it shows no such areas occurring on the Project Site. However, a portion of the coast live oak woodland Dudek mapped was within Riparian/Marsh/Vernal Pool along Bell Canyon Creek in Figure 4 -1 ( Attachment A ; Figure 34, ESHA Comparison). Dudek identified coast live oak woodland extending farther eastward, based on field observations.

The entire coast live oak woodland should be considered riparian oak woodland associated with Bell Canyon Creek, and both the ESHA and buffer should be considered part of the streamside protection area (SPA) for this area.

The General Plan specifies a buffer of 100 feet for riparian habitat, and a potential buffer reduction to 25 feet (Table 2). The Preliminary Landscape Layout Plan (Earthform 2023) depicts riparian ESHA and the setback that would provide the limits of the upland buffer for the Bell Creek SPA.

3.2.3 Coastal Sage Scrub/Coastal Bluff Scrub
Coastal sage scrub and coastal bluff scrub vegetation communities along the ocean bluff at the south edge of the Project Site include Baccharis pilularis – Toxicodendron diversilobum association, coyote brush scrub alliance, and quailbush scrub alliance. Differences from City-mapped vegetation along the bluff were minor, and based on field observations made according to methods described in Section 2.1 above. Dudek also mapped a small area of coyote brush scrub alliance on the south side of Devereux Creek near the western edge of the site that had previously been identified (Attachment A: Figure 43).

The General Plan (Policy CE 5.3) and the City of Goleta Municipal Code (17.30.140) specifyies a buffer of 25 feet for coastal sage scrub and coastal bluff scrub habitat (Table 2). It includes no provision for reducing this buffer. The Preliminary Landscape Layout Plan (Earthform 2023) depicts both coastal sage scrub and coastal bluff scrub ESHA and the setback for sensitive scrub.

3.2.3 Native Grassland
Although the City mapping includes native grassland east of the Project Site, on the Ellwood Bluffs, it includes none on the Project Site itself. Dudek observed several species of native grasses in unmaintained parts of the golf course, including purple needlegrass (Stipa pulchra), which was recorded in sufficient density and over a sufficient area in the southeastern part of the Project Site to be considered a native grassland (Attachment A: Figure 32).

The General Plan (Policy CE 5.2) and City of Goleta Municipal Code (17.30.160) specifyies a buffer of 10 feet for native grassland (Table 2). It includes no provision for reducing this buffer. The Preliminary Landscape Layout Plan (Earthform 2023) depicts native grassland ESHA and the 10-foot setback. 267

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3.2.4 Beach
The General Plan/CLUP Figure 4-1 identifies ESHA for “Beach and Shoreline” in the southwestern extreme of the Project Site (near the mouth of Bell Canyon Creek) and in a stretch of beach in the south -central part of the site .

Dudek mapped “beach” as a land cover all along the southern edge of the Project Site. But, since no Project activities would occur on or near the beach, Dudek did not distinguish between beach ESHA and beach that may not be ESHA. Dudek assumes the entire beach within the Project Site could be ESHA, but only City-mapped Beach and Shoreline ESHA is shown on Figure 23. The General Plan and the City of Goleta Municipal Code (17.30.170) does not specify a buffer distance for Beach and Shoreline. The Preliminary Landscape Layout Plan (Earthform 2023) depicts City-mapped Beach and Shoreline ESHA.

3.2.5 Open Water and California Red-legged Frog Habitat Although Figure 4-1 of the General Plan/CLUP displays an area of Open Water, the golf course pond, just southwest of the clubhouse, as ESHA, Dudek observations and historical information related to the seasonally maintained pond indicate this location should not be considered ESHA. Bell Canyon Lagoon, Tecolote Creek Lagoon, and Lake Los Carneros are provided as examples of lagoons and open water habitats that are considered ESHA in Table 4-2 of the General Plan/CLUP. The Sandpiper Golf Course pond or more correctly termed “water hazard,” however, is a water feature that is regularly managed and treated and drained annually for maintenance (Sandpiper Golf Course, pers. comm. and Rathburn 2004). It is void of emergent or other suitable vegetation thereby reducing its habitat quality for breeding, refugia/shelter, prey, and other essential habitat characteristics of the California red-legged frog (Rana draytonii), Contaminants such as m ineral fertilizers used throughout the range of the California red - legged frog on crops, household lawns, and golf courses negatively affect CRLF habitat (USFWS 2006). Marco et al. (1999) found increased mortality of northern red-legged frog larvae when exposed to nitrite below the levels allowed for drinking water. During aquatic resources surveys, Dudek confirmed and mapped the extent of open water associated with Bell Canyon Lagoon. However, the Sandpiper Golf Course pond is listed as an example of special- status species habitat, not as an open water habitat as listed in Table 4-2 and displayed on Figure 4-1 in the City’s General Plan. In the General Plan, ESHA is defined under CE 8.1 ESHA Designation for the CRLF under d. Habitat capable of supporting special-status amphibians and reptiles such as the red -legged frog (Rana aurora draytonii) and western pond turtle (Clemmys marmorata pallida). Under the optimal conditions, the Sandpiper Golf Course Pond is only suitable as a temporary summer aquatic refuge but is not able to support a CRLF population. Currently, the pond is unoccupied by the CRLF, and, therefore, doesn’t meet the definition of ESHA.

California red-legged frog (Rana draytonii) was originally observed in the golf course pond in 2001, 2002, and 2003, however, Rathbun (2004), in an assessment of the frog population of the golf course area, believed that the pond was not a breeding location, and that instead it provided stopover habitat for frogs that “move seasonally and intermittently between water bodies in order to find favorable habitat during adverse conditions.” Dudek conducted eight focused CRLF surveys according to USFWS (2005) pro tocol between April and July 2022 and observed no California red-legged frogs in the golf course pond or in any of the other aquatic habitats in the vicinity (Dudek 2023). The golf course pond is an artificial pond surrounded my well -maintained “golf course” grasses. It is up to fifteen feet deep and has no overhanging or emergent wetland vegetation. Despite the suitable depth, given the lack of overhanging vegetation and any adjacent vegetation other than maintained turf grass, habitat is not optimal as a breeding site, although the site may still be used as a dispersal site. In addition, th is pond is periodically drained. Also, Rathbun (2004) noted that “…given the relatively small number of [CRLF] frogs in limited wetland 268

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habitats in the vicinity of the Sandpiper Golf Course, the [CRLF] frogs are probably susceptible to local extinction.” In addition to poor quality habitat, the California’s most recent drought (2011 to 2021, interrupted by 2017) may have contributed to the absence of CRLF on the property during the 2022 surveys. As mentioned above, the Sandpiper Golf Course Pond is currently considered unoccupied by the CRLF and, therefore, is not deserving of an ESHA designation . The General Plan specifies a buffer of 100 feet for open water (Table 2) . The Preliminary Landscape Layout Plan (Earthform 2023) depicts open water habitats and the 100-foot setback.

Opportunities for habitat restoration related to Devereux Creek are introduced in 3.2.6.1.

3.2.6 Streamside Protection Areas and Riparian Habitat
Dudek largely confirmed mapping of riparian habitat and wetland vegetation along Bell Canyon Creek . In accordance with Policy CE 2. 2, the outer edge of the riparian and wetland vegetation associated with the creek would serve as the outer extent of ESHA and as basis for the 100-foot setback that would define the extent of the streamside protection area (SPA). Elsewhere on the Project site, Dudek made substantial changes to the mapping of riparian ESHA along Devereux Creek. The City-mapped ESHA along this creek is of relatively even width, the length of the creek where it occurs on the golf course. However, the creek course is underground in two three locations, crossing two different the Hole 1, 2, 3, and 5 fairways, so that these areas are completely devoid of riparian vegetation, indications of surface flows, or defined banks. A swale that follows the course of the historic creek likely conducts local surface local flows across the Hole 2, 3, and 5 during storms (Stantec 2023), but Dudek observed no indications of surface hydrology here , and this swale is generally poorly defined throughout (Attachment B:

Photographic Documentation). The hole 1 fairway, where Dudek (2023) identified culverts at either side, is level through this area, and no evidence is present of above ground flows. East of the Hole 5 fairway, on the east side of an Arizona crossing paralleling the fairway, signs of hydrology and of a bed and bank resume as the creek flows offsite to Santa Barbara Shores Park.

Elsewhere along Devereux Creek, Dudek mapped riparian vegetation based on conditions observed in the field.

Two areas of arroyo willow scrub, which occurs in a well -defined community amid maintained areas of the golf course, were identified as riparian vegetation. In addition, Dudek identified two areas of eucalyptus woodland as riparian, due to the association of trees in these two locations with Devereux Creek. Trees considered shading the creek in these two areas, one of which is just south of Hollister Avenue and one of which is on the western edge of the Project Site, were mapped as riparian ( Attachment A: Figure 43). Dudek’s mapping resulted in an increase in the area of riparian vegetation in these two areas. elimination of riparian ESHA in the two fairways where the creek runs underground, and mapping of riparian ESHA where arroyo willow scrub occurs that is similar to the City’s mapping. Because no riparian vegetation, defined bed and bank, or indicators of surface flows occur in the vicinity of the Hole 1, 2, 3, and 5 fairways, these areas do not meet the definition of ESHA.

Because no riparian vegetation or defined banks occur in areas where the creek is underground or otherwise absent, there is also no basis for establishing an upland buffer, in accordance with General Plan policy. Policy CE

2.2 (see Section 1 above) states that the streamside protection area (SPA) “upland buffer shall be 100 feet outward on both sides of the creek, measured from the top of the bank or the outer limit of wetlands and/or riparian vegetation, whichever is greater.” It further provides that the upland buffer may be as little as 25 feet on either side of the creek, based on a site -specific assessment. The purpose of the upland buffer and the SPA “shall be to preserve the SPA in a natural state in order to protect the associated riparian habitats and ecosystems.” However, under existing conditions, the portions of the historic Devereux Creek that do not support riparian vegetation also 269

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do not support stream banks, observable signs of surface flows, or any other resource to protect (Attachment B:

Photographic Documentation; Dudek 2023). Therefore, Figure 4 (Attachment A) shows the SPA as including only the areas supporting surface flows and riparian vegetation, plus the upland buffer for these areas.

As noted above, the General Plan specifies a buffer of 100 feet for stream resources, including riparian habitat, and a potential buffer reduction to 25 feet (Table 2). The Preliminary Landscape Layout Plan (Earthform 2023) depicts riparian ESHA and the setback that would provide the limits of the upland buffer for the Devereux Creek SPA, as mapped by Dudek.

3.2.6.1 Devereux Creek Restoration
Although, in their altered conditions, these segments of the historic Devereux Creek do not support surface flows, a defined bank, or riparian vegetation, several General Plan policies, including Policy LU 9.3 (h) and Policy CE 2.6 refer to the protection, enhancement, and restoration of creeks, and of Devereux Creek specifically (Section 1, above). Policy LU 9.3(h) states that design for rerouting or alteration of the golf course “shall be . . . in a manner that protects and enhances environmental resource s,” including Devereux Creek. Policy CE 2.6 states that “channelized sections of creek and culverts shall be evaluated and removed to restore natural channel bed and bank, where feasible” and further states that “rehabilitation project shall be designed to maintain or improve flow capacity.”
The Project, as currently proposed, provides enhancement to Devereux Creek that addresses these requirements.

An Arizona crossing along the east edge of the Hole 5 fairway (Attachment B: Photo Documentation) would be removed along with the culvert that crosses under it. Surface flows would be restored to this area, and the cart path would be moved farther west, where a bridge would span the swale marking the historic course of Devereux Creek, rather than disturbing the surface of the historic creek course. Additional improvements are in development in the vicinity of the Holes 2, 3, and 5 fairways. The current landscape plan proposes a more natural, dry creek design in these areas (Earthform Design 2023). Specifics of this design are forthcoming, after project approval.

3.2.7 Emergent Wetlands
Dudek confirmed mapping of emergent wetland in Bell Canyon Creek, and mapped additional emergent wetland at a location not identified as ESHA in the City’s map, along the ocean bluff (Attachment A: Figure 43). This location is one that had previously been identified as supporting aquatic habitat, and where Dudek and previous consultants conducted surveys for California red-legged frog. No other emergent wetlands were identified.

The General Plan (Policy CE 3.4) and the City of Goleta Municipal Code (17.30.090) specifyies a buffer of 100 feet for coastal wetlands, and a potential buffer reduction to 50 feet (Table 2). The Preliminary Landscape Layout Plan (Earthform 2023) depicts the coastal wetland ESHA and the 100-foot setback.

3.2.8 Rare Plant Habitats
Dudek identified five rare plant species during surveys, none of which had been identified in City data, including:
cliff malacothrix (Malacothrix saxatilis var. saxatilis), which possesses a California Rare Plant Rank (CRPR) of 4.2; red sand-verbena (Abronia maritima), a perennial herb with a CRPR of 4.2; Santa Barbara honeysuckle (Lonicera subspicata var. subspicata), a perennial evergreen shrub with a CRPR of 1B.2; Southern California black walnut 270

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(Juglans californica), a tree with a CRPR of 4.2; and woolly seablite (Suaeda taxifolia), also a CRPR 4.2 species. Of these, cliff malacothrix, Southern California black walnut, and woolly seablite all occur within areas considered ESHA based on vegetation community. Red sand -verbena occurs in an area of beach mapped as ESHA in the General Plan/CLUP and far from golf course and any proposed re-design. Santa Barbara honeysuckle occurs partly within an area protected as monarch butterfly roosting habitat and as riparian habitat associated with Devereux Creek. A portion of the area where Santa Barbara honeysuckle occurs is outside the se ESHAs but well within the 100-foot buffer. No additional buffers are required to protect any of these species.

The General Plan (Policies CE 8.1 and CE 8.2) and the City of Goleta Municipal Code (17.30.090) does not specify a buffer for habitats supporting rare plants. As all rare plants on the Project Site occur within ESHA vegetation communities or wildlife habitat with designated buffers, or within the buffers for such habitats, these species will be protected under policies protecting these habitats. The Preliminary Landscape Layout Plan (Earthform 2023) includes the location of all rare plants.

3.2.9 Monarch Butterfly Roosting Habitat
Dudek generally confirmed the location and boundary of monarch butterfly roosting habitat . It also confirmed eucalyptus woodland along the western boundary as potential raptor habitat. Figure 3 shows the location of two historic raptor nest sites within eucalyptus in this area.

The General Plan (Policy CE 4.5) and the City of Goleta Municipal Code (17.30.180) specifyies a buffer of 100 feet for monarch butterfly roosting habitat, and a potential buffer reduction to 50 feet (Table 2). The Preliminary Landscape Layout Plan (Earthform 2023) depicts monarch butterfly roost ESHA and the 100-foot setback.

3.2.10 Raptor Nests
In addition to historic nests of Cooper’s hawk ( Accipiter cooperii) and white-tailed kite (Elanus leucurus) included in City data in Figure 4-1 of the General Plan/CLUP, Dudek identified two locations where red-tailed hawks (Buteo jamaicensis) nested, one in 2021 and one in 2022, and a location of an unsuccessful nesting attempt by red - shouldered hawks (Buteo lineatus) in 2022 (Figure 32).

The General Plan (Policy CE 8.4) specifies a buffer of 100 feet for raptor nests of sensitive raptor species , when feasible. This would include any nest of white -tailed kite or Cooper’s hawk. This buffer increases to 300 feet for disturbance conducted near a nest that is occupied (Table 2). The Preliminary Landscape Layout Plan (Earthform 2023) depicts all raptor nests identified during surveys in 2021-2022 and previously. 4 References
CDFW (California Department of Fish and Wildlife). 2018. “Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities.” March 20, 2018. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18959.

CDFW. 2022. “California Natural Community List.” Sacramento, California: CDFW. July 5, 2022. Accessed July 2022 at https://wildlife.ca.gov/Data/VegCAMP/Natural-Communities#natural%20communities%20lists. 271

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City of Goleta. 2006. General Plan/Coastal Land Use Plan.

City of Goleta. 2016. Special-Status Species and Environmentally Sensitive Habitat Areas. General Plan/Coastal Land Use Plan. June 2016.

CNPS. 2023. A Manual of California Vegetation Online. Accessed August 2022. www.vegetation.cnps.org Dudek. 2023. Biological Resources Assessment Report for the Sandpiper Golf Club Project. November 2022; Revised August 2023.

Earthform Design. 2023. Sandpiper Golf Club, 7925 Hollister Ave., Santa Barbara, CA 93117. Preliminary Landscape Layout Plan. July 25, 2023.

Lichvar, Robert W., Norman C. Melvin, Mary L. Butterwick, and William N. Kirchner. 2012. National Wetland Plant List Indicator Rating Definitions. ERDC/CRREL TN-12-1.

Rathbun, G.B. 2004. California Red-legged Frog Status, Sandpiper Golf Course, Goleta, California. Prepared for Sandpiper BB Property LLC, 7925 Hollister Avenue, Goleta, California. June 17.

Stantec. 2023. Preliminary Drainage Study for the Sandpiper Golf Club, City of Goleta, CA. July 11, 2023.

USACE (U.S. Army Corps of Engineers). 1987. Corps of Engineers Wetlands Delineation Manual. Online ed.

Environmental Laboratory, Wetlands Research Program Technical Report Y-87-1. Vicksburg, Mississippi:

U.S. Army Engineer Waterways Experiment Station. January 1987. http://www.cpe.rutgers.edu/Wetlands /1987-Army-Corps-Wetlands-Delineation-Manual.pdf.

USACE. 2007. Jurisdictional Determination Form Instructional Guidebook. May 30.

USACE. 2008a. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (Version 2.0). Environmental Laboratory, ERDC/EL TR-08-28. Vicksburg, Mississippi: U.S. Army Engineer Research and Development Center. September 2008. https://www.nrcs.usda.gov/Internet /FSE_DOCUMENTS/stelprdb1046489.pdf.

USACE. 2008b. A Field Guide to the Identification of the Ordinary High Water Mark (OHWM) in the Arid West Region of the Western United States: A Delineation Manual. ERDC/CRREL TR-08-12. Prepared by R.W.

Lichvar and S.M. McColley. Hanover, New Hampshire: U.S. Army Engineer Research and Development Center, Cold Regions Research and Engineering Laboratory. August 2008. https://apps.dtic.mil/dtic /tr/fulltext/u2/a486603.pdf.

USACE. 2020. National Wetland Plant List, version 3.5. U.S. Army Corps of Engineers. Engineer Research and Development Center. Cold Regions Research and Engineering Laboratory, Hanover, NH. Accessed May 2022. http://wetland-plants.usace.army.mil/.

USDA (U.S. Department of Agriculture). 1994. Changes in hydric soils of the United States. Federal Register 59(133): 35680–35681, July 13.
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USDA-NRCS (U.S. Department of Agriculture, Natural Resources Conservation Service). 2010. Field Indicators of Hydric Soils in the United States: A Guide for Identifying and Delineating Hydric Soils, Version 7.0, 2010.

Prepared in cooperation with the National Technical Committee for Hydric Soils. Edited by L.M. Vasilas, G.W. Hurt, and C.V. Noble.

USFWS. 2005. Revised Guidance on Site Assessments and Field Surveys for the California Red-legged Frog. August.

USFWS. 2002. Recovery Plan for the California Red-Legged Frog (Rana aurora draytonii)

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Attachment A
Figures 1–4
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275
Project Location
ESHA Memo for the Sandpiper Golf Club Project
SOURCE: USGS National Map
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Feet
Project Boundary
FIGURE 1
Arroyo
Grande
Buellton
Carpinteria
Goleta
Grover Beach
Guadalupe
Lompoc
Maricopa
Ojai
Oxnard
Pismo Beach
Santa Barbara
Santa Maria
Solvang
Taf t
Ventura
Kern CountySan Luis
Obispo
County
Ventura
County
SANTA

BARBARA
COUNTY
Project Site
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W a j e r o D r
Island
O a k L n
L a s A r m a s R d
Kestrel
Ln
Elderberry
Dr
C a t h e d r a l O a k s R d
H o l l i s t e r A v e
General Plan (Figure 4-1) Special-Status Species and ESHA ESHA Memo for the Sandpiper Golf Club Project
SOURCE: Aerial: Sanborn 2020
0 400200
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FIGURE 2
Project Boundary
Environmentally Sensitive Habitat Areas
Beach and Shoreline
Monarch butterfly and/or Raptor Roosting
Open Water
Riparian/Marsh/Vernal Pool
Sage Scrub/Dune/Bluff Scrub
Unvegetated Open Creek Channel
Special-Status Species
GF Cooper's Hawk Nest
GF White-tailed Kite Nest
!!H California Red-Legged Frog
##0 Tidewater Goby
_^_ Monarch Butterfly Aggregation
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(2022)
S o r a C t
H e r o n C t
Kestrel Ln
W a j e r o D r
Island
O a k L n
L a s A r m a s R d
Elderberry
Dr
C a t h e d r a l O a k s R d
H o l l i s t e r A v e
Sensitive Resources Identified during Surveys, 2021-2022 ESHA Memo for the Sandpiper Golf Club Project
SOURCE: Aerial: Sanborn 2020
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FIGURE 3
Project Boundary
Historic Devereux Creek
Non-Wetland Waters/Streambed
Sensitive Communities
Coastal Bluff Scrub/Coastal Sage Scrub
Purple Needle Grass Grassland
Monarch Butterfly Roosting Habitat
Riparian
Coastal Wetland
Open Water
Special-Status Plants
Cliff malacothrix (Malacothrix saxatilis var.
saxatilis)
Red sand-verbena (Abronia maritima)
Santa Barbara honeysuckle (Lonicera subspicata
var.subspicata)
Southern California black walnut (Juglans
californica)
Woolly seablite (Suaeda taxifolia)
Special-Status Wildlife
"" California brown pelican
$1 Yellow-headed blackbird
Raptor Nests
GF Red-tailed Hawk Nest (2021, 2022)
GF Red-shouldered Hawk Nest (unsuccessful)
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H e r o n C t
Kestrel Ln
W a j e r o D r
Island
O a k L n
L a s A r m a s R d
Elderberry
Dr
(2021)
(2022)
C a t h e d r a l O a k s R d
H o l l i s t e r A v e
ESHA Comparison
ESHA Memo for the Sandpiper Golf Club Project
SOURCE: Aerial: Sanborn 2020
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FIGURE 4
Project Boundary
U.S. Army Corps of Engineers
Non-Wetland Waters/Streambed
Dudek Mapped ESHA
Sensitive Communities
Coastal Bluff Scrub/Coastal Sage Scrub
Purple Needle Grass Grassland
Riparian and Wetland ESHA
Riparian
Coastal Wetland
Open Water
Raptor Nests
GF Red-tailed hawk Nest (2021, 2022)
GF Red-shouldered hawk Nest (2022)
City of Goleta ESHA
Habitat Type
Beach and Shoreline
Monarch butterfly and/or Raptor
Roosting Habitat
Open Water
Riparian/Marsh/Vernal Pool
Sage Scrub/Dune/Bluff Scrub
Unvegetated Open Creek Channel
Monarch Butterfly
Monarch Butterfly Roosting Habitat
Special-Status Species
!!H California Red-Legged Frog
##0 Tidewater Goby
_^_ Monarch Butterfly Aggregation Site
Raptor Nests
GF Cooper's hawk Nest (City, historic)
GF White-tailed kite Nest (City, historic)
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Attachment B
Photos
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Ke st rel Ln
Elderberry
Dr
1 2
3 4
5 6 H o l l i s t e r A v e
Photo Locations and Directions
ESHA Memo for the Sandpiper Golf Club Project
SOURCE: Aerial: Sanborn 2020
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Project Boundary
F Photo Location
Proposed Riparian ESHA
Riparian
Monarch Butterfly Habitat
Monarch Butterfly and/or Raptor Habitat
(City of Goleta, confirmed in field)
^_ Monarch Butterfly Aggregation Site
Special-Status Species
GF Cooper's Hawk Nest (historic)
GF White-tailed Kite Nest (historic)
282

APPENDIX B / PHOTOS

12760 B-1 OCTOBER 2023

Photo 1. Grill above culvert opening adjacent to Arizona crossing of historic Devereux Creek at Hole 5 fairway, looking southwest. May 10, 2022.

Photo 2. Looking northwest along historic Devereux Creek course and Hole 5 fairway. May 10, 2022. 283

APPENDIX B / PHOTOS

12760 B-2 OCTOBER 2023

Photo 3. Looking northwest along historic Devereux Creek course, across Hole 3 fairway. May 10, 2022.

Photo 4. Looking northwest from near existing bridge over historic Devereux Creek, across Hole 2 fairway. May 10, 2022.

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APPENDIX B / PHOTOS
12760 B-3 OCTOBER 2023
Photo 5. Looking north to proposed riparian ESHA along Devereux Creek, immediately west of Hole 2 fairway.

April 2, 2021.

Photo 6. Looking south over Hole 1 Fairway toward proposed Devereux Creek riparian and along approximate route of existing creek culvert under the fairway. May 10, 2022. 285

Attachment 7:

Applicant Submitted Initiation Factors

286

11 December 2023

City of Goleta
Planning & Environmental Services
130 Cremona Drive, Suite B
Goleta, CA 93117
c/o Darryl Mimick
Email: [email protected]

Subject: Project Description and Initiation of Amendment Factors Sandpiper Golf Course: 7925 Hollister Avenue; APN 079-210-059

Dear Darryl,

This letter provides the applicants response to the Initiation Factors that the City Council must consider in initiating a General Plan Amendment. The applicant is requesting a revision to figure 4 -1 of the Conservation Element to accurately reflect the ESHA boundaries as mapped by the professional biologist from Dudek & Associates at the Sandpiper Golf Club.

1. The amendment proposed appears to be consistent with the Guiding Principles and Goals of the General Plan;
CE 1.5 of the General Plan states “if a site-specific biological study contains substantial evidence that an area previously shown as an ESHA on Figure 4-1 does not contain habitat that meets the definition of an ESHA for reasons other than that set forth in CE 1.4, the City biologist and the Planning Commission shall review all available information and determine if the area in question should no longer be considered an ESHA and therefore not be subject to the ESHA protection policies of this plan. If the final decision-making body determines that the area is not an ESHA, a map modification shall be included in the next General Plan/Coastal Land Use Plan amendment; however, Local Coastal Program policies and standards for protection of ESHAs shall not apply, and approval of development consistent with all other requirements of this plan may be considered prior to the map revision.”
A site-specific biological study was prepared by professional biologists from Dudek & Associates which contains substantial evidence that some of the areas shown as ESHA on the Sandpiper property do no contain ESHA and also some areas that do contain ESHA. The General Plan thus requires the City to review this information. This request is thus consistent with the guiding principles and goals of the General Plan which include a desire to accurately represent Environmentally Sensitive Habitat Areas. Approving the request will have no impact on ESHA in the City and will only serve to advance the project, which will have numerous positive environmental benefits.
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Sandpiper Golf Club
11 December 2023