Goleta City Council
March 17, 2026

Agenda Item B.1

PUBLIC HEARING
Meeting Date: March 17, 2026
TO: Mayor and Councilmembers
SUBMITTED BY: Peter Imhof, Planning and Environmental Review Director PREPARED BY: Lisa Prasse, Current Planning Manager
Darryl Mimick, Supervising Planner
SUBJECT: Shelby Single Family Residential project for 56 Single Family units and 3 open space lots with a Final Environmental Impact Report at 7400 Cathedral Oaks Road. APN: 07 7-530-019; Case No. 05 -154-

VTM-DP-DRB
RECOMMENDATION:

It is recommended that the City Council:

A. Conduct a public hearing;
B. Adopt City Council Resolution No. 26-___, entitled “A Resolution of the City Council:
1) adopting environmental findings pursuant to the California Environmental Quality Act, 2) certify ing the Shelby Residential Project Final Environmental Impact Report (SCH #2012081019), 3) adopting the mitigation monitoring and reporting program, 4) adopting a statement of overriding considerations, and 5) approving the project”; C. Adopt City Council Resolution No. 26-___, entitled “A Resolution of the City Council of the City of Goleta, California approv ing the Vesting Tentative Map to create 56 residential lots and 3 open space lots For the Shelby Residential Project located at 7400 Cathedral Oaks Road; APN 077-530-019; Case No. 05-154- VTM”; and D. Adopt City Council Resolution No. 26-___, entitled “A Resolution of the City Council of the City of Goleta, California approving the Development Plan for 56 residential lots and 3 open space lots and associated improvements for the Shelby Residential Project located at 7400 Cathedral Oaks Road; APN 077 -530-019; Case No. 05-154- DP-DRB”.
1 Meeting Date: March 17, 2026

APPLICANTS/OWNERS:

Applicant: Property Owner
L & P Consultants Springville 3, LP
Mark Lloyd Glynne Couvillion
3 West Carrillo Street, Suite 205 690 Lilac Drive
Santa Barbara CA 93101 Santa Barbara CA 93108

JURISDICTION

The City is the lead agency for the Project un der CEQA and the City Council will be the final decision-maker for the Project regarding the adequacy of the Final Environmental Impact Report ( EIR), Mitigation Monitoring and Reporting Program, the proposed Statement of Overriding Considerations, as well as the merits of the various Project components (i.e., the Vesting Tentative Map and the Development Plan).

BACKGROUND

Project History

On October 11, 2005, Shelby Family Partnership, L.P. (“Applicant”) applied for a General Plan amendment and rezone from Agricultural to Design Residential at a density 20 units/acre to develop 248 units on a 14.38 -acre parcel located at 7400 Cathedral Oaks Road, APN 077 -530-019 (“Property”). B etween 2005 and 2011, the original submittal was revised multiple times by the Applicant and, on March 3, 2011, the City deemed the 60-residential unit and 4-open space lot project ( hereinafter called the “ original” project) complete.1

At the time the original project was deemed complete, the application included: 1) General Plan Amendments from Agricultural to Single Family Residential and to remove the site from General Plan Figure OS 3 -5; 2) rezoning the site from AG -II-40 (Agriculture II, 40 - acre minimum parcel size) to R -1-7000 (Single Family Residential, 7000 -square foot minimum lot size); 3) a Zoning Code Text Amendment to change the minimum lot width from 65 feet to 60 feet, applicable to all RS 7000 zoned lots citywide; 4) a Vesting Tentative Map to create 60 single family lots with 4 open spaces;25) a Development Plan to allow the construction of 60 single family homes; and 6) a Development Agreement.

On July 23, 2012, a Notice of Preparation was issued, and a scoping hearing was held on August 8, 2012. Various Draft/Revised Draft EIRs were released for public revi ew in 2013, 2014, and 2015. In approximately 2016, the original project was put on hold due to the water shortage emergency/ water moratorium imposed by Goleta Water District (GWD) and not being able to convert agricultural water into residential water allocation.

1 Because the original project was deemed complete in 2011, it vested prior to the subsequent voter - approved November 2012 Goleta Agricultural Land Protection Initiative (“Measure G”).

2 Meeting Date: March 17, 2026

In 2023, after the GWD lifted its water moratorium, the Applicant submitted a Senate Bill 330 (“SB 330”) preliminary application , to revise the original project by reducing the number of residential units from 60 to 56 and designating 20% of th e units as deed - restricted affordable, based on specified household income categories (the revised , currently pending project, hereafter, the “Project”). The Applicant submitted the SB 330 preliminary application when the City did not yet have a certified Housing Element, which the Applicant maintained made the Project subject to the Builder’s Remedy and the protections of the Housing Accountability Act (“HAA”). The Applicant’s use of an SB 330 preliminary application to amend and/or revise the pending development application from 2011 raised novel legal issues. The City disagreed with the Applicant’s position regarding the applicability of certain State housing laws and returned the preliminary application.

The disagreement between the Applicant and the C ity resulted in a lawsuit against the City (Shelby Family Partnership LP v. City of Goleta, Case No. 24CV00548). On February 26, 2025, after briefing and hearing on most of the Applicant’s claims, the Santa Barbara Superior Court ruled in the Applicant’s f avor. Among other things, the Court ordered the City to accept the SB 330 preliminary application and process the Project, and found that the Project is subject to the Builder’s Remedy and the protections of the HAA.

Following the Court’s decision, the City and the Applicant settled the litigation. Under the settlement agreement, the City agreed to review and process a permit application for the Project, which included a guarantee on the percentage of affordable housing the City could utilize toward its Regional Housing Needs Allocation (“RHNA”) requirements and comprehensive environmental review (including preparation of a revised and recirculated EIR for the proposed Project). As required by state law, the Project no longer requires a General Plan amendment or rezon e to allow single -family residential use. (Gov. Code, § 65589.5(f)(6)(D)(i).)

Builders Remedy

As profiled above, the Project is subject to the “Builder’s Remedy” and the protections of the HAA. Prior to January 1, 2025, the HAA prohibi ted a jurisdiction from denying a qualifying affordable housing project due to inconsistencies with the local zoning and/or General Plan if an applicant submitted a preliminary application while the jurisdiction’s Housing Element was out of substantial compliance with state Housing Element law (i.e., uncertified). (Gov. Code, § 65589.5(d)(5), (o)(1).) This provision was commonly referred to, and is now officially known as, the “Builder’s Remedy.” In September 2024, the Governor signed Assembly Bill (AB) 189 3, which amended the HAA to, among other things, further specify when the Builder’s Remedy applies and how such applications are processed.3 As discussed in California Government Code section 65589.5(f)(6)(D)(iii), “[a]ny [Builder’s Remedy] project that co mplies with this paragraph shall be deemed consistent, compliant, and in conformity with an applicable plan, program, policy, ordinance, standard, requirement, redevelopment plan and implementing instruments, or other similar provision for all purposes, an d shall not be considered or treated as a

3 If an application was deemed complete before January 1, 2025, the HAA (as amended by AB 1893) allows the applicant to “choose to be subject to the provisions of [the HAA] that were in place on the date the preliminary application was submitted, or any or all of the provisions of [the HAA] applicable as of January 1, 2025.” (Gov. Code, § 65589.5(f)(7)(A).)
3 Meeting Date: March 17, 2026

nonconforming lot, use, or structure for any purpose.” As noted above, the Builder’s Remedy allows the Project to be developed on the project site without requiring a General Plan amendment or rezoning and permits the applicant to identify a local zoning district to be used as a basis for design consistency (hence the Project being evaluated for consistency with the RS-7 zoning standards).

California Density Bonus Law

State Density Bonus law offers significant b enefits to housing projects that include a qualifying number of affordable units. AB 1893 clarified that the Builder’s Remedy and Density Bonus law can operate in tandem, provided that a project provides a sufficient quantity of affordable units to qualify under Density Bonus law. For the reasons noted below, the Project qualifies for the Builder’s Remedy and Density Bonus law — and under the latter the applicant is requesting one concession and four waivers from specified RS- 7 zoning requirements, described below.

Location and Existing Setting

The proposed Project would be developed on a 14.38-acre site located at 7400 Cathedral Oaks Road (Assessor’s Parcel Number 077 -530-019) in the City of Goleta as shown in Graphic 1 below (i.e., the Property). The Pr operty is currently fallow, used for woodchip and firewood storage, and contains three vacant structures, including a single -family residence. The Property is bordered by the Glen Annie Golf Course to the north and east, El Encanto Creek, Northgate Road, and multi-family residential development to the west, and Cathedral Oaks Road and single-family residences to the south.

Although designated for Agriculture in the City of Goleta General Plan/Coastal Land Use Plan and zoned AG -40 (Agriculture, 40 -acre min imum lot size), the Property has not supported agricultural activity since the mid-1990s. The Property includes areas mapped as Environmentally Sensitive Habitat Area and portions within the Streamside Protection Area (SPA) buffer of El Encanto Creek. The Property is also located within a Local Very High and High Fire Hazard Severity Zone, as designated by the California Department of Forestry and Fire Protection. Graphic 2 shows the Fire Severity zones affecting the Property along with the ESHA adjacent ESHA boundary.

4 Meeting Date: March 17, 2026

Graphic 1

Graphic 2 -

Project’s Primary Objectives

The primary objectives for the proposed Project are as follows:

1. Develop up to 56 residential units on underutilized land located within Goleta.

2. Provide residential development in Goleta to bolster the City’s housing stock, as contemplated by the City’s adopted 2023-2031 Housing Element. 5 Meeting Date: March 17, 2026

3. Provide housing opportunities for extremely low income, lower income, and moderate income-level households to support the City in complying with its RHNA requirements.

4. Improve accessibility and encourage active transportation for bicycles and pedestrians in Goleta.

5. Design residences to incorporate green building measures to encourage the use of energy and water efficient technology.

Native American Consultation

Separate from the original Senate Bill 18 consultation for the original project in 2011, on August 9, 2013, the City submitted a request to the Native American Heritage Commission (“NAHC”) for a Sacred La nds File search and a Native American Contact list. On August 29, 2013, the City contacted by mail the list of Native American groups and individuals provided by NAHC, asking if they had any cultural information about the Property or concerns about the original project. Comments were requested by September 30, 2013; no responses were received.

In a letter dated July 25, 2014, the City invited the local Native American community to a meeting on August 12, 2014, to discuss the original project. No one from the tribes attended the meeting. Kathleen Pappo of the Barbareño/Ventureño Band of Mission Indians provided a letter in response to the request on August 6, 2014 (Pappo 2014), noting that she would like to see some of the land that was formerly occupied by the Chumash Native Americans to remain undeveloped.

Additionally, although not required pursuant to Assembly Bill (AB) 52, the City engaged in informal consultation in August 2025 with tribes listed in the NAHC Native American Contact list to provide these tribes with updates to the proposed Project and to receive comments. No new comments were received.

Design Review Board (DRB)

A description of the design elements (architectural style, landscaping, lighting) is provided in the Project Description section below. On February 10, 2026, the Design Review Board (DRB) reviewed photo -simulations, site plans, elevations, landscaping, and lighting for the Project. The DRB recommended Preliminary review approval to the City Council.

The architectural plans, the landscaping and lighting plans are provided as Exhibit A to Attachment 3 to this report. Graphic 3 below is an excerpt from the plans to provide an example of the architectural style of the one -story plan and one of the two -story house types.

Graphic 3
6 Meeting Date: March 17, 2026

Planning Commission

On March 2, 2026, the Planning Commission reviewed the project at a noticed public hearing. After considering the administrative record, the Planning Commission, on a 4-1 vote, recommended that the Council certify the Final EIR, adopt the Findings, adopt the Mitigation Monitoring and Reporting Project, adopt the Statement of Overriding Consideration, and approve the VTM and Development Plan. The topics of discussion at Planning Commission involved concerns about the impacts of this project on the traffic in the area, SPA buffer reduction, fire safety, and the public benefit of the multim odal pathway to be built by Shelby along Cathedral Oaks. Greater explanation of these topics can be found in the staff report below and the Final EIR.

PROJECT DESCRIPTION

The proposed Project involves the demolition of the existing on -site residence, garage, and barn; subdivision of the existing 14.38-acre parcel into 59 separate lots via a Vesting Tentative Map; construction and occupancy of 56 single -family residences on Lots 1 through Lot 56. Eleven of the lots would be income-restricted for a minimum of 55 years, with the restriction re-setting upon resale, as described below. Use of Lot 57, Lot 58, and 7 Meeting Date: March 17, 2026

Lot 59 would be for open space containing landscape and stormwater facilities. The layout of the proposed subdivision is shown in Graphic 4, and the location of the affordable units are shown in Graphic 5 below. The VTM is provided as Exhibit A to Attachment 2 of this report.

Graphic 4

8 Meeting Date: March 17, 2026

Graphic 5

The proposed Project includes the following primary components:

 Demolition of the existing on-site residence, garage, and barn.  Subdivision of the existing 14.38-net acre parcel into 59 separate lots via a Vesting Tentative Tract Map. As designed the property lines of each lot go the centerline of the private of the roads. The individual lot sizes would range from approximately 7,000 gross square feet to approximately 19,500 gross square feet, inclusive of the roadway, as the property lines extend to the center line of the private streets. 9 Meeting Date: March 17, 2026

The net lot sizes would range from 5,910 square feet to 13,150 square feet (developable area behind the sidewalk).
 Construction and occupancy of 56 single-family dwellings on Lots 1 through Lot 56 inclusive of landscaping and lighting. As indicated above, 11 dwellings will be deed-restricted as affordable units for at least 55 years. Of the 11 af fordable dwellings, four will be designated for extremely low -income households, one will be designated for lower income households, three will be designated for moderate income households, and three will be designated for above -moderate income households. All residential units, including the 11 affordable units, will be counted towards the City’s Regional Housing Needs Allocation (RHNA).  Use of Lots 57 through Lot 59 would be for open space containing landscape and/or stormwater facilities.

The Applicant is proposing private streets to serve the Project. The streets, the lighting, landscaping, and the common area improvements will be the responsibility of the future homeowner’s association (HOA).

As noted above, the Project is being evaluated for consi stency with the RS -7 zoning district’s standards. Features of the Project that deviate from the RS -7 zone’s requirements are justified pursuant to relief provided under State Density Bonus law (Gov.

Code, § 65915). As a Builder’s Remedy project with at least seven (7) percent of units for extremely low-income households, the Project is entitled to, among other things, four concessions4 and an unlimited number of waivers or reductions of development standards that physically preclude the Project from being c onstructed by the applicant. (Gov. Code, § 65589.5(f)(6)(B)(i)(II), (C)(i), (iv).)5

The Applicant is requesting one concession and four waivers to deviate from the City standards listed below. State law prohibits the City from finding the Project inconsis tent with the City’s standards as a result of Density Bonus law. (Gov. Code, § 65589.5(j)(3).) The one concession and four waivers are as follows:

Concession

1. Encroachment into the required 100 -foot streamside protection area (SPA) buffer of approximately 7,786 square feet (0.18 acres) in the rear yards of Lots 1 through 8, portions of the houses on Lots 1 and 2, and for portions of sidewalk in Lot 38. To compensate for SPA buffer encroachment, the proposed Project design includes 0.21 acres of additi onal open space provided outside of and adjacent to the edge of the 100-foot SPA buffer on proposed Lot 58.

4 The terms “concession” and “incentive” are synonym ous under Density Bonus law and, among other things, mean reduced site development standards or modified Zoning Code requirements that result in cost savings for the project. (See Gov. Code, § 65915(k).)
5 A Builder’s Remedy project automatically receive s two concessions in addition to those granted under Density Bonus law. (Gov. Code, § 65589.5(f)(6)(C)(i).) When a Builder’s Remedy project qualifies by providing at least 7 percent extremely low-income units, it is treated as if it were providing 10 perce nt very low-income units under Density Bonus law (which qualifies the project for two concessions). (Gov. Code, §§ 65589.5(f)(6)(C)(iv), 65915(d)(2)(B).)
10 Meeting Date: March 17, 2026

Waivers

Four waivers from the RS-7 zone district standards:

1. Proposed lot widths of 60 feet (which is less than the 65 feet otherwise required in the RS-7 zone district) on 31 of the 56 proposed residential lots. This occurs on Lots 1-9, 20-30, 32-36, 39-40, 47-48, 51, and 55.

2. Proposed rear yard setbacks of 15 feet (which is less than the 25 feet otherwise required in the RS -7 zone district) on 51 of the 56 proposed residential lots. This occurs on Lots 1-12, 14, 17-19, 21-29, and 31-56.

3. Reduced side yard setbacks (of less than the otherwise required 6.5 feet in the RS -7 zone district) on 32 of the 56 proposed residential lots. The reduction allows for a second story to extend closer to the edge of the property line. This occurs on Lots 5 - 9, 20, 22-28, 30, 31, 33-37, 40, 43, and 47-56.

4. The allowed maximum floor area of 35 houses would exceed the maximum allowed floor area. The exceedances range bet ween 208 to 1,539 additional square feet, depending on the lot. These floor area exceedances would occur on Lots 1 through 14, 20 through 23, 25 through 29, 32, 34, 36, 40, 41, 45, 46, 48, 50, 52, and 55.

Design

The residential units to be developed would consist of five dwelling types ranging in size from a single -story, 1,723-square-foot floor plan to a two -story, 3,882-square-foot floor plan. The typical roof height would range from approximately 17 feet 9 inches to 23 feet 10 inches.

The design of the five residential dwelling types includes wood panels, smooth stucco finish, metal siding, glass door and window systems, and cantilevered sloped and flat roof systems. The proposed development is similar and compatible with the existing developments surrounding the site due to the choice of colors and materials. However, since the proposed development is not identical in architectural style to the multi -family and single -family development to the west and south, the architectural style of the proposed development avoids monotonous repetition.

Preliminary raw earthwork volumes are estimated at 27,500 cubic yards of cut and 23,500 cubic yards of fill.

Lighting

Proposed lighting conforms to the City’s dark sky lighting standards by all being downward angled. The lighting proposal includes streetlights at all intersections that are 16 feet tall, bollard lights 2 feet in height on each street, and lights at the fro nt and back entrances/exits at the houses. The lights are LEDs and range in wattage from 7.5W to 120W. The photometric plan provided for the Project indicates that the foot -candle readings on 10-foot intervals do not exceed 0.1 foot-candles adjacent to residences.

11 Meeting Date: March 17, 2026

Landscape and Stormwater Control

The landscape plant palette includes various 15 -gallon screen shrubs adjacent to residential streets, such as Bush Anemone, Toyon, Kohuhu, and Lemonade Be rry.

Various proposed canopy trees include protecting i n place the existing live oaks and adding new marina strawberries (24” Box), meyer lemons (24” Box), chinese flames (36” Box), apple (24” Box), avocado (24” Box), red push pistache (36” Box), as well as others.

New trees to assist in the restoration with t he proposed restoration of areas within the riparian corridor include California sycamore (36” Box), and Western cottonwood (24” Box).

Further, the landscape plan for the Project incorporates various features for management of stormwater and water quality. Stormwater curb extensions and permeable paver parking areas and driveways are proposed to capture street stormwater runoff for treatment, filtration, and sediment dropout. Above -ground rain barrels would be located at each residence to collect precipitation and roof drainage for use as supplemental irrigation. A bioswale and vegetated swale located in the open space area along Cathedral Oaks Road and in various biofiltration/collection areas on site would capture additional stormwater for filtration, infiltration, and sediment dropout.

Additional Improvements

The proposed Project would include improvements to the open space lots, such as a community picnic area on Lot 57 and frontage landscaping an d screening on Lot 59.

Infrastructure improvements would include a looped internal road system with one cul - de-sac, two intersections with Cathedral Oaks Road, and a five-foot-wide interior sidewalk throughout the Project site. Additionally, the proposed P roject would include frontage improvements along approximately 890 linear feet of Cathedral Oaks Road between Northgate Drive to the west and the Glenn Annie golf course property to the east.

Frontage improvements would consist of two driveway entrances to the Project site, curb and gutter improvements, and continuation of an existing Class I trail that extends east of the Project site and runs parallel to Cathedral Oaks Road.

Utilities

The proposed Project would include underground connections for sewer , water, cable television, and electricity. The proposed Project would be all -electric and would not require natural gas connections. Water service would be provided by the GWD as the first choice. If GWD does not have the water capacity to serve the site , the Applicant is planning on wheeling water through GWD system if the appropriate measures are taken.

Sewer service would be provided by Goleta West Sanitary District. Electricity would be provided by Southern California Edison or Central Coast Community Energy.

Telecommunications services would be provided by a variety of companies, including Verizon and AT&T. Solid waste services would be provided by Marborg Industries. 12 Meeting Date: March 17, 2026

Demolition and Grading

The Project would involve the demolition of the existing on -site residence, garage, and barn, totaling 3,893 square feet. Preliminary raw earthwork volumes are estimated at 27,500 cubic yards of cut and 23,500 cubic yards of fill. The 4,000 cubic yards of excess cut would be hauled to the Tajiguas Landfill, located at 14470 Calle Real in unincorporated Santa Barbara County. Existing Project site elevations range from 145 to 252 feet above mean sea level, with an average slope of 7.8 percent. The finished grade would range from approximately 150 to 245 feet. Grading for the 56 new homes would include site -wide earthwork and installation of two 18 -inch storm drains beneath the western internal roadway, which would direct stormwater to a detention basin in the southwest corner of the Project site. The basin would be directed to an existing storm drainpipe that outlets to El Encanto Creek.

Streamside Protection Area Buffer Encroachment

The City’s SPA policy (General Plan/Coastal Land Use Plan Policy CE 2.2) requires a 100-foot buffer between development and the edge of the El Encanto Creek riparian corridor, which may be reduced to no less than 25 feet under certain conditions. The Project site includes approximately 1.12 acres (49,148 square feet) of SPA buffer.

Approximately 7,786 square feet of proposed residential development would encroach into the SPA buffer, including portions of homes on Lots 1 and 2 and rear yards on Lots 1 through 8. Approximately 11,283 square feet of proposed stormwater detention would be located in the SPA buffer on Lot 58. Additional improvements within the SPA buffer include a meandering walking path, landscaping, and roughly 65 linear feet of sidewalk.

A co ncession pursuant to State Density Bonus law is being utilized to allow the encroachment of these proposed Project features in the SPA buffer , which Staff finds consistent with State law . The landscaping proposed in the SPA buffer on Lot 58 is intended to protect the biologic value and function of the stream.

DISCUSSION:

As profiled above, the Project qualifies as a Builder’s Remedy project under the HAA and relief from City development standards under State Density Bonus law. Because this is a Builder’s Remedy and State Density Bonus law project, State law overrides certain Goleta Municipal Code standards and otherwise limits the City’s discretion over the Project.

Map Design

The proposed subdivision design provides access to the proposed lots in a un iform and rational manner. The site is physically suitable for the type of development, given the topography, its lot size, and access to existing infrastructure. The type of development includes 56 single family residential units on a 14.38 -acre site, and the site can accommodate the development including its density of 3.89 units per acre as well as the infrastructure proposed by the Project. The site is located adjacent to existing infrastructure located within the Cathedral Oaks right -of-way. The Projec t provides a public sidewalk and bike path along the north side of Cathedral Oaks. 13 Meeting Date: March 17, 2026

Moreover, the site is located close to existing public infrastructure that is anticipated to be appropriately sized to accommodate the additional demands of the single -family units, including, without limitation, existing public streets, U.S. Highway 101, utility lines (e.g., water, sewer, gas electricity and communications ), and bus service routes. The project will be required to connect to existing utility services and preliminary services determinations/ preliminary condition letters have been provided by Goleta West Sanitary District and Goleta Water District. The Applic ant will be required to satisfy the requirements of these agencies prior to issuance of building permits. Elementary and secondary public education facilities are available in the City to serve students from the Project.

Architectural and Landscaping Design

The proposed development will create its own unique neighborhood. Further, the proposed development’s site layout is designed to be consistent with adjacent single - family residential neighborhoods south of Cathedral Oaks Drive with the two access points aligning with the roads that serve the Crown Collection neighborhood. The proposed interior residential streets serve the residences and utilize pavers and curvilinear streets for traffic calming measures. The design of the homes is harmonious with each other based on the design features and the proposed colors and materials.

Further, the landscaping and lighting features complement the architectural design and site layout thereby creating a balanced neighborhood design.

Further, the home sizes range from 1,723 square feet to 3,882 square feet and height of the one and two story proposed homes range between 17 feet and 9 inches to 23 feet and 10 inches, which is in keeping with the height of the nearby developments, such as the Crown Collection located across the street. The proposed project is located along a Local Scenic Corridor on Figure 6 -1 of the General Plan and the proposed photo simulations which are on file with the Planning Department and are incorporated by reference demonstrate that the public view to the mountains will alter minimally. It is likely that private views from the Crown Collection will be affected by the development of the Project. While General Plan Policy VH 1.8 does state “Project development and architecture shall be considerate of private views,” the City notes the protections provided to Project under Builder’s Remedy, described in additional detail throughout this report.

Development on the Project site is challenging from a view perspective based on the height difference between the properties. The rear of the new homes on Lots 31 -37 will be approximately 140’ away from the rear property lines of the homes on the south side of Cathedral Oaks.

Furthermore, each of the floor plans and design elements work well toge ther due to the similarity of the colors and materials of each home type. Further, the proposed development is compatible with the existing developments surrounding the site because of the choice of colors and materials to be utilized, such as wood panels, smooth stucco finish, metal siding, glass door and window systems, and cantilevered sloped and flat roof systems. Although not identical to the residences to the west and south, the development has harmonious single -family residential characteristics but at the same time avoids monotonous repetition.
14 Meeting Date: March 17, 2026

There are no native or specimen trees present on the site given the site’s past use for agricultural and wood chipping. The project includes 4 acres of landscaping around the perimeter of the development as well as within each new lot. The proposed landscaping improves the appearance of the community by providing a cohesive plant palette placed in a manner to provide screening along Cathedral Oaks and between the lots, which will be permanently maintained for the life of the project by the Homeowners Association.

The palette comprises plant material and trees known to thrive in the local climate and soil conditions. Twenty percent or less of the plant material will require moderate water, and the remainder will require low to very low water once established. Exterior lighting has been designed to meet the City’s dark sky lighting standards by all being downward angled. The photometric plan provided for the Project indicates that the foot -candle readings on 10-foot intervals do not exceed 0.1 foot-candles adjacent to residences.

Builders Remedy/SB 330/State Density Bonus Law

State law significantly restricts the Design Review Board’s (DRB), Planning Commission’s (PC), and City Council’s (CC) discretion over the Project. As a Builder’s Remedy project, the HAA deems the Project (inclusive of the Density Bonus concession and waivers) “consistent, compliant, and in conformity with” the City’s applicable z oning and General Plan standards. (Gov. Code, § 65589.5(f)(6)(D)(iii).).

Notwithstanding these state law restrictions, staff has reviewed the Project for consistency with the City’s standards and determined that the finding for Preliminary Design Review, Vesting Tentative Map, and the Development Plan can be made for the Project. These findings, and staff’s rationale for why each finding can be made (including the recognition of the concession and waivers), are provided in Attachments 2 and 3 to this report and the General Plan and Zoning Consistency analyses provided as Exhibits B and C to Attachments 2 and 3.

Affordable Housing

A component of this Project is the dedication of 11 income -restricted units as described above. These units will be deed -restricted for a minimum period of 55 years , with the covenant resetting upon sale. Conditions have been incorporated that outline how these units will be sold and how the affordability will be maintained for 55 years. The City will be able to include these units in the affordable housing stock inventory. With the payment of an inclusionary housing in-lieu fee, which supplements the 11 income-restricted units to be built on site, the Project will meet the requirements of GMC Section 17.28.040 (A) and provide the requisite 20% inclusionary units.

General Plan/Coastal Land Use Plan (GP/CLUP) Consistency

Staff has prepared both a General Plan and Zoning Consistency analysis for the proposed Project, which are provided as Exhibits B and C to Attachments 2 and 3. As outlined in those documents, the Project can be found consistent with the applicable policy and zoning regulations given its status as a Builder’s Remedy project and with the use of the 15 Meeting Date: March 17, 2026

concession (SPA buffer reduction) and four waivers from development regulations (i.e., rear yard setback, second story setback, maximum floor area, and lot widths) afforded by State Density Bonus law.

As previously noted, state law prohibits the City from requiring the project to apply for, or receive approval of, a General Plan amendment, Specific Plan amendment, rezoning, or other legislative approval. (Gov. Code, § 65589.5 (f)(6)(D)(i).) Additionally, as a Builder’s Remedy project, the applicant identified a local zoning district that is used as a basis for design consistency. The Applicant identified the RS -7 zoning district as the most analogous zone. Per Section 17.070.030, the maximum density in the RS zone districts is 5 dwellings/acre. The Project has a density of 3.89 dwellings/acre. Therefore, the design of the Project is consistent with the density allowed with the RS-7 zone district.

ENVIRONMENTAL REVIEW

Revised Draft Environmental Impact Report (EIR)

As the lead agency for the original project, the City determined that an environmental impact report (“EIR”) would be necessary to study the potential impacts of the project. On August 7, 2012, th e City issued a Notice of Preparation and held a scoping hearing on August 8, 2012. In 2014, the City released two Draft EIRs for public review for the original project. The first was a Supplemental Draft EIR to the Certified EIR for the General Plan/Coastal Land Use Plan (State Clearinghouse No. 2012071071) that analyzed the impacts of a General Plan Amendment required for the original project. The second was a Draft EIR (State Clearinghouse No. 2012081019) that analyzed the project -level impacts of the d evelopment of the project. Based on public comments received on the EIRs, the City revised and recirculated both EIRs from October 26, 2015 through December 14, 2015.

As discussed above, after the Applicant submitted an SB 330 preliminary application, revising the project, and the City and Applicant entered into a settlement agreement to resolve litigation, a General Plan Amendment was no longer required for the Project .

Thus, the City determined that a revised EIR replacing the prior two EIRs in their entirety was required for this Project.

The Revised Draft EIR analyzed the impacts of the Project on the topics of Aesthetics, Air Quality, Biological Resources, Cultura l Resources, Geology and Soils, Greenhouse Gas Emissions, Hazards and Hazardous Materials, Hydrology and Water Quality, Land Use and Planning, Noise, Transportation and Circulation, Tribal Cultural Resources, Utilities and Service Systems, and Wildfire.

The Revised Draft EIR concluded that the Project would have significant and unavoidable project specific and cumulative impacts (Class I) in the area of Transportation and Traffic – Vehicle Miles Traveled. Further, the Revised Draft EIR concluded that the Project would have potentially significant, but mitigable, impacts on the environment (Class II) in the areas of Biological Resources, Tribal Cultural Resources, Geology and Soils, Hazards and Hazardous Materials, Hydrology and Water Quality, Land Use and Planning, Noise, Wildfire, and Cultural Resources.
16 Meeting Date: March 17, 2026

Biological Resources

The proposed encroachment of residential structures and grading into the 100 -foot SPA upland buffer are allowed pursuant to State Density Bonus Law and meet the criteria for buffer reduction under General Plan/Coastal Land Use Plan Policy CE 2.2 and Goleta Municipal Code Section 17.30.070. While the proposed project would be inconsistent with Policy CE 2.3, such conflict does not inherently result in a significant environmental impact under CEQA. CEQA significance is determined by whether a conflict with a plan would lead to a substantial adverse physical change in the environment. In this case, the inconsistency is limited to the type of development (i.e., residential use) rather than the extent or severity of physical impacts, which are addressed through mitigation measures and site design. The proposed residential development within the SPA buffer has been sited and designed to minimize impacts to riparian vegetation, would not involve protected tree removal, and would not result in significant degradation of streamside habitat or hydrology. Therefore, the proposed project’s impact involving conflicts with policies related to SPAs (Policies CE 2.2 and CE 2.3) would be less than significant.

Transportation and Traffic – Vehicle Miles Traveled and Level of Service

Senate Bill (SB) 743 was signed into law in 2013, shifting the way transportation impacts are evaluated. Specifically, the analysis moved away from level of service (LOS) and toward vehicle miles traveled (VMT) to support lower greenhouse gas emissions, development of multimodal transportation, and a diversity of land uses. With the passage of SB 743, traffic congestion (LOS), by itself, is not an environmental impact under CEQA.

As such, LOS was not an alyzed in the EIR, including the cumulative impact analysis , since LOS is not a determination of significance under CEQA. As such, Section 4.11 Transportation and Circulation of the Revised Draft EIR analyzes VMT, and not LOS. To implement SB 743, the City of Goleta and County of Santa Barbara have both developed project-level VMT calculators to evaluate VMT generated by land use projects in the area.

Given that vehicle miles are distributed regionally and based on the project site’s proximity to unincorporated Santa Barbara County, both City and County VMT calculators were used to analyze the project. Based on the ATE’s Phase I Traffic and VMT Assessme nt (Appendix J of the Revised Draft EIR), and the City’s VMT analysis tool the project is expected to generate 21.24 VMT per resident, which exceeds the City’s 16.79 VMT per resident threshold. Based on the County’s VMT tool, the project is estimated to generate

15.9 VMT per resident, which exceeds the County threshold of 14.9 VMT per resident.

The project would therefore have a potentially significant VMT impact. Mitigation Measure TRA-1 requires the applicant to prepare a VMT Reduction Plan that will include reduction measures to be implemented during project design and development. However, even with implementation of Mitigation Measure TRA -1, VMT impacts (project -specific and cumulative) would remain significant and unavoidable.

Although LOS is no long er treated as a transportation impact or a determination of significance under CEQA , it is addressed in Section 4.9 Land Use and Planning of the Revised Draft EIR when analyzing the Project’s consistency with the City’s General Plan/Coastal Land Use Plan policies. As discussed on page 4.9-36 of the Revised Draft EIR, the General Plan/Coastal Land Use Plan Policy TE 4.1: General Level of Service 17 Meeting Date: March 17, 2026

Standard provides that a traffic LOS standard C shall apply citywide to major arterials, minor arterials, and collector roadways and signalized and unsignalized intersections. As studied in ATE’s Phase I Traffic and VMT Assessment (Appendix J of the Revise d Draft EIR), the Project is forecasted to generate 477 average daily traffic ( ADT), 37 AM peak hour trips, and 47 PM peak hour trips, and therefore unlikely to exceed LOS C at the study-area roadways identified in the Phase I Traffic and VMT Assessment. T hus, the project is consistent with Policy TE 4.1. Overall, the Project would be consistent with the applicable policies from the General Plan/Coastal Land Use Plan with implementation of mitigation measures, and as such, impacts related to conflict with land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental impact would be less than significant with mitigation.

Alternatives
Three alternatives to the Project were considered and are described in detail in the Revised Draft EIR and in the CEQA Resolution (Attachment 1). The alternatives selected for detailed analysis within the Revised Draft EIR focus on alternatives that could reduce the Project’s significant environmental impacts, while still meeting mo st of the basic Project objectives. In general, the three alternatives were:
 Alternative 1: No Project Alternative (No Build). This alternative assumes that the proposed Project is not approved and the site remains in its existing condition.
 Alternative 2: No Project Alternative (By-Right Development). This alternative assumes the Project site would be developed with land uses that are allowed by right pursuant to the Agricultural designations. The anticipated activities would be establishment of an agr icultural operation with a complex of greenhouses, provision of farmworker housing, and expansion of the existing single-family unit on the property.
 Alternative 3: Mixed Use Alternative. This alternative would include 56 residential units, including multifamily (such as duplexes, triplexes, or other medium-density residential buildings), as well as commercial space, and daycare space within the same development footprint as the proposed Project.

For the purposes of this analysis, it is assumed that the lot coverage would be similar to that of the proposed Project, with the same scope of development activities within the same Project footprint as the proposed Project.

Despite the incorporation of all feasible mitigation measures, the Project would still result in a significant unavoidable impact (project specific and cumulative) related to traffic and circulation based on Vehicle Miles Traveled. Accordingly, the City Council will need to adopt a Statement of Overriding Considerations, which is discussed further below.

DEIR Public Review Period and Final EIR
A Notice of Availability (NOA) and the Revised Draft EIR were released for a 45-day public review period from November 26, 2025 through January 12, 2026. During this period, an Environmental Hearing Officer hearing was conducted on January 6, 2026. No comments 18 Meeting Date: March 17, 2026

were received at the January 6, 2026 hearing. The City received six written comment letters on the Revised Draft EIR during the public comment period. The topics of the comments included:

1. Concerns about the volume of traffic to be generated by the Project

2. Concerns about the number of students generated by the Project

3. Water availability

4. Habitat and ESHA setbacks

5. Development of the Glen Annie Golf Course

6. Soil stability of the property. wildfire and emergency response

7. Pedestrian, bicycle, and transit circulation

Following the closure of the public review period, the City has prepared a Final EIR. The Final EIR includes Responses to the Comments received and minor revisions to the text of the Draft EIR where appropriate based on the comments received. None of these revisions in the Final EIR rise to the level requiring recirculation of the Revised Draft EIR under Section 15088.5 of the State CEQA Guidelines (California Code of Regulations Title 14). The comments and the Responses to the Comments are provided in Section 7 of the Final EIR. The Revised Draft EIR and the Final EIR can be accessed at:
https://www.cityofgoleta.org/your-city/planning-and-environmental-review/ceqa- review/shelby-residential-development-project.

CEQA Resolution

Attachment 1 to this staff report is a Resolution recommending City Council’s certification of the Final EIR, adoption of CEQA findings, adoption of the Mitigation Monitoring and Reporting Program (MMRP), and adoption of the Statement of Overriding Considerations (SOC). The Final EIR has been completed in compliance with CEQA. The City Council is being asked to certify the Final EIR consistent with State CEQA Guidelines section 15090.

Findings Requir ed for Significant Impacts . State CEQA Guidelines section 15091 provides that no public agency shall approve or carry out a project for which an EIR has been certified that identifies one or more significant environmental effects of the project unless the public agency makes one or more of the following findings for each of the project’s significant effects:

1) Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the final EIR.
2) Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency. 3) Specific economic, legal, social, technological, or other considerations, including the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR.

Exhibit A to Attachment 1 is the Findings of Facts and contains the following Sections:

 Section I – Introduction of the Findings of Fact
19 Meeting Date: March 17, 2026

 Section II – Findings for Impacts that do not require mitigation measures  Section III – Findings for Impacts that are less than significant with inclusion of mitigation measures
 Section IV – Findings for Impacts that cannot be fully mitigated to less than significant level
 Section V – Findings regarding Cumulative Impacts
 Section VI – Findings regarding Irreversible Environmental Changes  Section VII – Findings regarding Growth Inducing
 Section VIII – Findings regarding Alternatives
 Section IX – Adoption of SOC

Further, when making CEQA Findings of Fact, CEQA requires the lead agency to also adopt a program for reporting on or monitoring the changes that it has either required in the project or made a condition of approval to avoid or substantially lessen significant environmental effects. (State CEQA Guidelines, § 15091(d).) A Mitigation and Monitoring and Reporting Program (MMRP) has been prepared for the Project and is included as Exhibit B to Attachment 1.

Statement of Overriding Considerations. Pursuant to State CEQA Guidelines Section 15093(a), the City must balance, as applicable, the economic, legal, social, technological, or other benefits of the project against its unavoidable environmental risks in determining whether to approve the project. If the specific benefits of the project outweigh the unavoidable adverse environmental effects, those e nvironmental effects may be considered acceptable. While recognizing that the unavoidable adverse impacts regarding Vehicle Miles Traveled (project -specific and cumulative) are significant under CEQA thresholds, the City nonetheless finds that these unavoidable adverse impacts are acceptable and outweighed by specific social, economic and other benefits of the Project.

In making this determination, the factors and public benefits specified below were considered. The substantial evidence supporting the various benefits can be found in the findings outlined in Attachment 1, which are incorporated by reference into this staff report. The following social, economic, and environmental benefits, independent of the other benefits, outweigh the potential significant unavoidable adverse impacts and render acceptable each and every one of these unavoidable adverse environmental impacts:

1. Develop up to 56 residential units on underutilized land located within Goleta.

2. Provide residential development in Goleta to fulfill the housing stock envisioned in the City’s adopted 2023-2031 Housing Element.

3. Provide housing opportunities for extremely low income, lower income, and moderate income -level persons to support the City in complying with its Regional Housing Needs Allocation requirements.

4. Improve accessibility and encourage active transportation for bicycles and pedestrians in Goleta.

5. Design residences to incorporate green building measures to encourage the use of energy and water efficient technology.

With respect to the first benefit listed above, the Project site is currently a large fallow field with three small, vacant buildings, for which there is no agricultural activity and has been 20 Meeting Date: March 17, 2026

fallow since approximately 1995 and is therefore underutilized. Development of this Project would transform this underutilized site into much-needed housing, a much needed public benefit.

Further, the second and third benefits listed above would be achieved by this Project, with the addition of 56 residential units, 11 of which will be income -restricted. Project would result in the second and third benefits listed above, by adding 56 residential uni ts – four designated for extremely low income, one designated for lower income, three designated for moderate income, and three for above -moderate income levels. This Project would thus provide for residential development within the City as envisioned in its adopted 2023- 2031 Housing Element and further the City’s compliance with its Regional Housing Needs Allocation requirements.

The fourth benefit would be achieved because the Project would provide pedestrian linkages and maintain connectivity to the Ci ty’s planned bikeway system by including frontage improvements along approximately 890 linear feet of Cathedral Oaks Road between Northgate Drive to the west and the Glen Annie Golf Course property to the east.

These frontage improvements include two driveway entrances to the site, curb and gutter installation, and conversion of the existing Class II bike path to a Class I bike path in compliance with the City’s Bicycle and Pedestrian Master Plan. The Class I bike path along the frontage of the Shelby prope rty will connect with an existing Class I trail that extends east of the project site and runs parallel to Cathedral Oaks Road. The Class I trail would provide an exclusive right-of-way for bicycle and pedestrian use and minimize vehicle cross flows (i.e., the locations which a vehicle can cross the pathway). The Project would also provide internal streets that connect to existing bicycle and pedestrian facilities, and internal sidewalks and pedestrian connections to the Class I multi-use path for bicycle a nd pedestrian use. These features would allow for integration with the surrounding circulation network and encourage walking and bicycle. It would also incorporate active transportation reduction strategies , which include affordable housing integration and bicycle facilities and pedestrian improvements as part of the project.

The fifth benefit would be achieved because the Project would implement energy-efficient light fixtures, building materials, and heating, ventilation, and air conditioning equipment.

The proposed design of the residences would include solar photovoltaic systems pursuant to the requirements of the California Building Code ti tle 24, part 6. Further, the Project aligns with the City’s Strategic Energy Plan by sourcing electricity from Southern California Edison, which is required under Senate Bill 100 to procure 60% renewable energy by 2030 and 100% by 2045. In addition, residents would have the opportunity to opt-in to the Central Coast Community Energy electric procurement system, which procures electricity from renewable sources for delivery. The Project would continue the existing Class 1 trail that extends east of the project site and runs parallel to Cathedral Oaks Road, which would promote alternative modes of transportation for residents and encourage less vehicle use, therefore reducing energy use associated with vehicle trips.

Conclusion

The Final EIR prepared in conne ction with the Project sufficiently analyzes the Project’s potentially significant environmental impacts, as well as the three alternatives to the 21 Meeting Date: March 17, 2026

Project, examining the environmental impacts of each alternative as well as the ability of the alternatives to meet Project objectives.

The City Council is asked to consider the above information and, if it concurs, to adopt Attachment 1 to the staff report, thereby certif ying the Final EIR, adopting of the CEQA findings, adopting the SOC, and adopt ing the MMRP, adopting Attachment 2 approving the Vesting Tract Map, and adopting Attachment 3 approving the Development Plan and grant Preliminary Design approval based on the findings provided.

PUBLIC NOTICE

Notice has been provided in the following manner:

 Story poles representing each floor plan with elements over 20’ tall were installed on the site on January 12, 2026.
 Two eight-sq. ft. signs were installed on the site on January 14, 2026, for the DRB hearing. The signs have been updated with information on February 12, 2026, for the Planning Commission hearing. The signs were late updated on March 2, 2026, for the City Council hearing.
 Advertisement was published in the Santa Barbara Independent on February 19, 2026, a minimum of 10 days before the Pla nning Commission hearing. An additional advertisement was published in the Santa Barbara Independent on March 5, 2026, for the City Council hearing; and
 Notices were mailed to property owners and tenants within 500’ feet on February 18, 2026, a minimum of 10 days before the Planning Commission hearing. On March 4, 2026, notices were mailed to property owners and tenants within 500, a minimum of 10 days before the City Council hearing.

FISCAL IMPACTS:

As part of the resolution of the litigation involving the Project, the City agreed to provide Applicant an Attorney Fee Credit of $1.1 million, and in exchange, Applicant agreed not to seek attorneys’ fees in the underlying lawsuit and would not seek to li tigate the remaining causes of action in the case. The Attorney Fee Credit amount is a negotiated resolution of the lawsuit, and the City did not agree that Shelby had incurred that amount in attorney s’ fees and costs in the lawsuit. Because Applicant has to pay certain development costs to the City, the City agreed to allow some of those costs to be credited against the Attorney Fee Credit. The agreement provides that the City will receive a 20% percent reduction of the credit ($220,000), if the project r eceives Final Administrative Approval, defined as approval by the final City decision-makers, by March 31, 2026.

In addition, the settlement agreement provided that the City would bear the cost of the EIR for the Project. On August 19, 2025, the City Council approved a contract with Rincon Consultants in the amount of $330,000 associated with preparation of the EIR.

The Project has been conditioned to pay the applicable Development Impact Fees at the appropriate rates as outlined in Vesting Tentative Map Condition No. 20 (see Exhibit D of 22 Meeting Date: March 17, 2026

Attachment 2) and in Development Plan Condition No. 55 (see Exhibit D of Attachment 3).

ALTERNATIVES:

Request additional information or additional discussion.

LEGAL REVIEW BY: Isaac Rosen, City Attorney

APPROVED BY: Robert Nisbet, City Manager

ATTACHMENTS:

1. A Resolution of the City Council: 1) adopt ing environmental findings pursuant to the California Environmental Quality Act, 2) certifying the Shelby Residential Project Final Environmental Impact Re port (SCH #2012081019), 3) adopt ing the mitigation monitoring and reporting program, 4) adopt ing a statement of overriding considerations, and 5) approving the project

Exhibit A – Findings of Fact
Exhibit B- Shelby Final EIR link:
https://www.cityofgoleta.org/your-city/planning-and-environmental-review/ceqa- review/shelby-residential-development-project
Exhibit C – MMRP
Exhibit D – Notice of Determination

2. A Resolution of the City Council of the City of Goleta, California approving the Vesting Tentative Map to create 56 residential lots and 3 open space lots for the Shelby Residential Project located at 7400 Cathedral Oaks Road; APN 077-530-019; Case No. 05-154- VTM
Exhibit A – Vesting Tentative Map
Exhibit B – General Plan Consistency
Exhibit C – Zoning Consistency
Exhibit D – Conditions

3. A Resolution of t he City Council of the City of Goleta, California approv ing of the Development Plan for 56 residential lots and 3 open space lots and associated improvements for the Shelby Residential Project located at 7400 Cathedral Oaks Road; APN 077-530-019; Case No. 05-154-DP-DRB
Exhibit A – Development Plans
Exhibit B – General Plan Consistency
Exhibit C – Zoning Consistency
Exhibit D – Conditions

4. Staff Presentation
23 Meeting Date: March 17, 2026

24 ATTACHMENT 1
A Resolution of the City Council of the City of Goleta: 1) adopt ing environmental findings pursuant to the California Environmental Quality Act, 2) certify ing the Shelby Residential Project Final Environmental Impact Report (SCH #2012081019), 3) adopt ing the mitigation monitoring and reporting program, 4) adopting a statement of overriding considerations, and 5) approving the project

25 City Council Resolution No. 26 -_____
Attachment 1
Shelby Project
1 | P a g e

RESOLUTION NO. 26-_____
A RESOLUTION OF THE CITY COUNCILOF THE CITY OF GOLETA,: 1)

ADOPTING ENVIRONMENTAL FINDINGS PURSUANT TO THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT, 2) CERTIFY ING THE

SHELBY RESIDENTIAL PROJECT FINAL ENVIRONMENTAL IMPACT
REPORT (SCH #2012081019), 3) ADOPT ING THE MITIGATION
MONITORING AND REPORTING PROGRAM, 4) ADOPT A STATEMENT
OF OVERRIDING CONSIDERATIONS, AND 5) APPROV ING THE

PROJECT
WHEREAS, on October 11, 2005, Shelby Family Partnership, L.P. (known as Springville 3 LP as of December 31, 2025), (“Applicant”) applied for a General Plan amendment and rezone from Agricultural to Design Residential at a density 20 units/acre to develop 248 units (“original project”) on a 14.38-acre parcel located at 7400 Cathedral Oaks Road, APN 077-530-019 (“property”); and

WHEREAS, between 2005 and 2011, the original project was revised multiple times (including the reduction of units and density) by the applicant and, on March 3, 2011, the original project’s application for 60 residential units and 4 open space lots was deemed complete; and

WHEREAS, pursuant to section 21067 of the Public Resources Code, and section 15367 of the State CEQA Guidelines (Cal. Code Regs., tit. 14, § 15000 et seq.), the City of Goleta (“City”) is the lead agency for the proposed project; and WHEREAS, in accordance with State CEQA Guidelines section 15082, on July 23, 2012, the City sent to the Office of Planning and Research and each responsible an d trustee agency a Notice of Preparation (“NOP”) stating that an Environmental Impact Report (State Clearinghouse Number #2012081019 would be prepared; and WHEREAS 11 comment letters were received in response to the NOP; and WHEREAS, pursuant to Public Resources Code section 21083.9 and State CEQA Guidelines sections 15082(c) and 15083, the City held a duly noticed Scoping Meeting on August 8, 2012, to solicit comments on the scope of the environmental review of the proposed project and, 5 verbal comments were received; and WHEREAS two Draft Environmental Impact Reports (“Draft EIR”) were prepared and released for public review in 2014: (1) the first Draft EIR was a Supplemental Draft EIR to the Certified EIR for the General Plan/Coastal Land Use Plan (SCH No. 2012071071) that analyzed the impacts of a General Plan amendment required for the proposed project, and (2) the second was a Draft EIR (SCH No. 2012081019) that 26 City Council Resolution No. 26 -_____
Attachment 1
Shelby Project
2 | P a g e

analyzed the project-level impacts of development of the proposed project, incorporating comments received in response to the NOP; and
WHEREAS, based on public comments provided on both Draft EIRs, the City revised the two EIRs and released the Revised Draft Supplemental EIR for the General Plan Amendment (SCH No. 2012071071) and the 2015 Revised Draft EIR (SCH No. 2012081019) for public review between October 26, 2015 and December 14, 2015; and WHEREAS the project was delayed in part due to a Stage II Water Shortage Emergency and water moratorium imposed by the Goleta Water District in September 2014; and
WHEREAS, in March 2023, the applicant submitted a Senate Bill (SB) 130 application to revise the project, reducing the number of residential units from 60 to 56 and designating 20 percent of the proposed residential units as deed -restricted units for specific household incomes for 55 years, during a time the City did not yet have a certified Housing Element; and
WHEREAS the updated project (“Project”) involves the demolition of the existing on-site residence, garage, and barn; subdivision of the existing 14.38-acre parcel into 59 separate lots via a Vesting Tentative Map; construction and occupancy of 56 single-family residences on Lot 1 through Lot 56 that would range from extremely low income to above- moderate income levels; and use of Lot 57, Lot 58, and Lot 59 for open space containing landscape and stormwater facilities; and
WHEREAS the 14.38 acre Project site is located at 7400 Cathedral Oaks Road (Assessor’s Parcel Number 077-530-019) in Goleta, California; and WHEREAS the Project is a qualified housing development project that utilizes the “Builder’s Remedy” protections of the California Housing Accountability Act and seeks approval for a demolition permit for existing structures, Vesting Tentative Map (05 -154- VTM), Development Plan (05-154-DP), approval of concessions/incentives or waivers for lot width, rear yard setback, side yard setback reductions, and FAR exceedance, and reduction of the El Encanto Creek 100 -foot Streamside Protection Area (“SPA”) buffer pursuant to State Density Bonus Law, and ministerial approval of the issuance of a permit for the construction of the proposed residences; and
WHEREAS, because a General Plan amendment is no longer required for the Project, the City prepared a Revised Draft EIR which replaces the prior two EIRs in their entirety, reflecting changes to the Project design, updated CEQA Guidelines and thresholds, updates to the Santa Barbara County Environmental Thresholds and Guidelines Manual, as well as changes to the project-level environmental and cumulative setting in the vicinity of the Project site; and
27 City Council Resolution No. 26 -_____
Attachment 1
Shelby Project
3 | P a g e

WHEREAS the Revised Draft EIR determined that mitigation measures were required to mitigate impacts to a less than significant level for the following resource areas: Biological Resources, Cultural Resources, G eology and Soils, Hazards and Hazardous Materials, Hydrology and Water Quality, Land Use and Planning, Noise, Tribal Cultural Resources, and Wildfire; and
WHEREAS the Revised Draft EIR further concluded that despite the incorporation of all feasible miti gation measures, the proposed Project would nonetheless result in significant and unavoidable impacts relating to Transportation and Traffic (Vehicle Miles Traveled – project specific and cumulative); and
WHEREAS, in accordance with State CEQA Guidelines section 15085, a Notice of Completion was prepared and filed with the Office of Planning and Research on November 21, 2025; and
WHEREAS, as required by State CEQA Guidelines section 15087(a), the City sent Notice of Completion of the Revised Draft EIR to the Office of Land Use and Climate Innovation on November 21, 2026, and the City provided Notice of Availability of the Revised Draft EIR to the public on November 26, 2025, the date when the public review period commenced; and

WHEREAS, during the public comment period, copies of the Revised Draft EIR and technical appendices were available for review and inspection at City Hall, on the City’s website, at the Goleta Valley Library Express;, and the Goleta Community Center and
WHEREAS, pursuant to State CEQA Guidelines section 15087(e), the Revised Draft EIR was circulated for at least a 45 -day public review and comment period from November 26, 2025 to January 12, 2026; and
WHEREAS, during the public review and comment period, the City consulted with and requested comments from all responsible and trustee agencies, other regulatory agencies, and others pursuant to State CEQA Guidelines section 15086; and WHEREAS the City received six written comment letters from private citizens on the Revised Draft EIR; and
WHERAES, on February 18, 2026, City released the Final EIR (“Final EIR”), which consists of the Revised Draft EIR, all tech nical appendices prepared in support of the Revised Draft EIR, all written comment letters received on the Revised Draft EIR, and written responses to all written comment letters received on the Revised Draft EIR; and WHEREAS the “EIR” consists of the Fin al EIR and its attachments and appendices, as well as the Revised Draft EIR and its attachments and appendices (as modified by the Final EIR); and
28 City Council Resolution No. 26 -_____
Attachment 1
Shelby Project
4 | P a g e

WHEREAS all potentially significant adverse environmental impacts were sufficiently analyzed in the EIR; and
WHEREAS, as contained herein, the City has endeavored in good faith to set forth the basis for its decision on the Project; and
WHEREAS all of the requi rements of the Public Resources Code and the State CEQA Guidelines have been satisfied by the City in connection with the preparation of the EIR, which is sufficiently detailed so that all of the potentially significant environmental effects of the Project have been adequately evaluated; and WHEREAS the EIR prepared in connection with the Project sufficiently analyzes the Project’s potentially significant environmental impacts and the EIR analyzes a range of feasible alternatives capable of reducing these effects to an even lesser level of significance; and
WHEREAS the City has made certain findings of fact, as set forth in Exhibit A to this Resolution, attached hereto and incorporated herein, based upon the oral and written evidence presented to it as a w hole and the entirety of the administrative record for the Project, which are incorporated herein by this reference; and WHEREAS the City finds that environmental impacts that are identified in the EIR as less than significant and do not require mitigation are described in Section II of Exhibit A; and
WHEREAS the City finds that environmental impacts that are identified in the EIR that are less than significant with incorporation of mitigation measures are described in Section III of Exhibit A; and
WHEREAS the City finds that even with the incorporation of all feasible mitigation measures, the environmental impacts that are identified in the EIR that are significant and unavoidable are described in Section IV of Exhibit A; and WHEREAS the cumulative impacts of the Project identified in the EIR and set forth herein, are described in Section V of Exhibit A; and
WHEREAS the potential significant irreversible environmental changes that would result from the proposed Project identified in the EIR and set forth herein, are described in Section VI of Exhibit A; and
WHEREAS the existence of any growth -inducing impacts resulting from the proposed Project identified in the EIR and set forth herein, are described in Section VII of Exhibit A; and
29 City Council Resolution No. 26 -_____
Attachment 1
Shelby Project
5 | P a g e

WHEREAS alternatives to the proposed Project that might further reduce the already less than significant environmental impacts are described in Section VIII of Exhibit A; and
WHEREAS the Statement of Overriding Considerations that indicates the benefits of the proposed Proj ect outweigh the unavoidable significant environmental effect is described in Section IX of Exhibit A; and
WHEREAS all the mitigation measures identified in the EIR and necessary to reduce the potentially significant impacts of the proposed Project to a l evel of less than significant are set forth in the Mitigation Monitoring and Reporting Program (MMRP) in Exhibit C to this Resolution, attached hereto and incorporated herein; and WHEREAS, prior to taking action, the City has heard, been presented with, reviewed and considered all of the information and data in the administrative record, including but not limited to the EIR, and all oral and written evidence presented to it during all meetings and hearings; and
WHEREAS the EIR reflects the independent judgment of the City and is deemed adequate for purposes of making decisions on the merits of the Project; and WHEREAS no comments made in the public hearings conducted by the City and no additional information submitted to the City have produced substantial new information requiring recirculation of the EIR or additional environmental review of the Project under Public Resources Code section 21092.1 and State CEQA Guidelines section 15088.5; and
WHEREAS, on March 2, 2026 , the Planning Commission conducted the public hearing to consider the Revised Draft EIR and approval of the demolition permit for existing structures, approval for the Vesting Tentative Map (05 -154-VTM), approval for the Development Plan (05 -154-DP), approval for the requested concessions/incentives or waivers, reduction of the El Encanto Creek 100 -foot SPA buffer pursuant to State Density Bonus Law, and approval for the building permits for new residences for the Project and solicited comments on the docu ment. After hearing all relevant testimony from staff, the public and the City’s consultant team, the Planning Commission voted 4-1 to recommend that the City Council certify the EIR for the Project; and WHEREAS, on March 17, 2026, the City Council considered the entire administrative record, Final EIR, Mitigation Monitoring and Reporting Program (“MMRP”), Statement of Overriding Considerations, including staff reports and oral and written testimony from interested persons at a noticed public hearing; and

WHEREAS all other legal prerequisites to the adoption of this Resolution have occurred;
30 City Council Resolution No. 26 -_____
Attachment 1
Shelby Project
6 | P a g e

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

SECTION 1. The above recitals are true and correct and incorporated herein by reference.

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

SECTION 3. The City Council hereby adopts the “CEQA Findings of Fact” which were prepared in accordance with State CEQA Guidelines sections 15091 and which are attached hereto as Exhibit A and incorporated herein by this reference.

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

SECTION 5. Based upon the entire record before it, including the EIR, Findings of Fact, and all written and oral evidence presented, the City Council hereby approves the proposed Project.

SECTION 6. The documents and materials that constitute the record of proceedings on which this Resolution has been based are located at Goleta City Hall, located at 130 Cremona Drive, Suite B, Goleta, California 93117. The custodian for these records is the City Clerk. This information is provided pursuant to Public Resources Code section 21081.6.

SECTION 7. City Council to direct City staff to cause a Notice of Determination to be filed and posted with the County Clerk and the State Clearinghouse within five working days of the adoption of the City Council Resolution.
31 City Council Resolution No. 26 -_____
Attachment 1
Shelby Project
7 | P a g e

APPROVED AND ADOPTED this 17 day of March, 2026.
__________________________

PAULA PEROTTE
MAYOR

ATTEST: APPROVED AS TO FORM:

_________________________ __________________________

DEBORAH LOPEZ ISAAC ROSEN

CITY CLERK CITY ATTORNEY

32 City Council Resolution No. 26 -_____
Attachment 1
Shelby Project
8 | P a g e

STATE OF CALIFORNIA )
COUNTY OF SANTA BARBARA ) ss.

CITY OF GOLETA )

I, DEBORAH LOPEZ, City Clerk of the City of Goleta, California, DO HEREBY CERTIFY that the foregoing Resolution No. 26- __ was duly adopted by the City Council of the City of Goleta at a regular meeting held on th e __ day of _______, 20 26 by the following vote of the City Council:

AYES:

NOES:

ABSENT:

(SEAL)

_________________________

DEBORAH LOPEZ

CITY CLERK

Attachments:

Exhibit A – Findings of Fact
Exhibit B – EIR - link to document due to size
Exhibit C – Mitigation Monitoring and Reporting Program

33 EXHIBIT A to ATTACHMENT 1
Findings of Fact
34 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
1 | P a g e

EXHIBIT A

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

SECTION I.

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

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

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

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

As indicated above, section 21002 requires an agency to “avoid or substantially lessen” significant adverse environmental impacts. Thus, mitigation measures that 35 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
2 | P a g e

“substantially lessen” significant environmental impacts, even if not completely avoided, satisfy section 21002’s mandate. (Laurel Hills Homeowners Assn. v. City Council (1978) 83 Cal.App.3d 515, 521 [“CEQA does not mandate the choice of the environmentally best feasible project if through the imposition of feasible mitigation measures alone the appropriate public agency has reduced environmental damage from a project to an acceptable level”]; Las Virgenes Homeowners Fed., Inc. v. County of Los Angeles (1986) 177 Cal. App. 3d 300, 309 [“[t]here is no requirement that adverse impacts of a project be avoided completely or reduced to a level of insignificance . . . if such would render the project unfeasible”].)
While CEQA requires that lead agencies adopt feasible mitigation measures or alternatives to substantially lessen or avoid significant environmental impacts, an agency need not adopt infeasible mitigation measures or alternatives. (Pub. Resources Code, § 21002.1(c) [if “economic, social, or other conditions make it infeasible to mitigate one or more significant effects on the environment of a project, the project may nonetheless be carried out or approved at the discretion of a public agenc y”]; see also State CEQA Guidelines, § 15126.6(a) [an “EIR is not required to consider alternatives which are infeasible”].) CEQA defines “feasible” to mean “capable of being accomplished in a successful manner within a reasonable period of time, taking i nto account economic, environmental, social, and technological factors.” (Pub. Resources Code, § 21061.1.) The State CEQA Guidelines add “legal” considerations as another indicia of feasibility. (State CEQA Guidelines, § 15364.) Project objectives also inform the determination of “feasibility.” ( Jones v. U.C. Regents (2010) 183 Cal. App. 4th 818, 828 -829.) “‘[F]easibility’ under CEQA encompasses ‘desirability’ to the extent that desirability is based on a reasonable balancing of the relevant economic, environmental, social, and technological factors.” (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 401, 417; see also Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715.) “Broader considerations of policy thus come into play when the decision making body is considering actual feasibility[.]” ( Cal. Native Plant Soc’y v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 1000 (“ Native Plant ”); see also Pub.

Resources Code, § 21081(a)(3) [“economic, legal, social, technological, or other considerations” may justify rejecting mitigation and alternatives as infeasible] (emphasis added).)
Environmental impacts that are less than significant do not r equire the imposition of mitigation measures. ( Leonoff v. Monterey County Board of Supervisors (1990) 222 Cal.App.3d 1337, 1347.)
The California Supreme Court has stated, “[t]he wisdom of approving . . . any development project, a delicate task which requires a balancing of interests, is necessarily left to the sound discretion of the local officials and their constituents who are responsible for such decisions. The law as we interpret and apply it simply requires that those decisions be informed, and the refore balanced.” ( Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 576.) In addition, perfection in a project or a project’s environmental alternatives is not required; rather, the requirement is that sufficient 36 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
3 | P a g e

information be pro duced “to permit a reasonable choice of alternatives so far as environmental aspects are concerned.” Outside agencies (including courts) are not to “impose unreasonable extremes or to interject [themselves] within the area of discretion as to the choice of the action to be taken.” (Residents Ad Hoc Stadium Com. v. Board of Trustees (1979) 89 Cal.App.3d 274, 287.)
37 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
4 | P a g e

SECTION II.

FINDINGS REGARDING ENVIRONMENTAL

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

A. AESTHETICS

1. Scenic Vistas
Threshold: Would the Project have a substantial adverse effect on a scenic vista?
Finding: Less than significant. (Revised Draft EIR, pp. 4.1-15 -- 4.1-17.) Explanation: The project site is primarily visible from Cathedral Oaks Road, Royal Linda Drive, and King Daniel Lane, as well as from residences in the neighborhood south of Cathedral Oaks Road. Limited views of t he site are also available from the Glen Annie Golf Course, which is partially screened by intervening topography and vegetation.

Cathedral Oaks Road is identified as a Scenic Corridor in the City of Goleta General Plan/Coastal Land Use Plan, which identif ies the project area of the corridor as having views in all directions.

As such, foothill and mountain views from the Cathedral Oaks Road Scenic Corridor are considered a significant visual resource. Scenic views of the Santa Ynez Mountains are limited at points to the east and west of the project site due to intervening development, topography, and vegetation. Views of the foothills and mountains are available from Cathedral Oaks Road directly adjacent to the project site because there is limited vegetati on and development on the majority of the site and topography slopes up gradually from the roadway. Project construction would involve grading to prepare the site for residential lots, open space areas, internal roadways, and other infrastructure. Once ope rational, the project would include residential units consisting of five dwelling types ranging in size from a single -story, 1,765 -square-foot floor plan to a two -story, 3,870 - square-foot floor plan. The typical roof height would range from 17 feet 9 inches for single-story residences to 23 feet 10 inches for two- story residences.

The individual lot size would range from approximately 7,000 gross square feet to approximately 19,500 gross square feet. The net area 38 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
5 | P a g e

of the individual lots, as measured behind the sidewalks, ranges from 5,905 square feet to 13,076 square feet. Landscaping would be comprised of an assortment of native and non -invasive screen shrubs, accent trees, and canopy trees, with a plant palette su itable for the climate in Goleta. The landscape buffer along Cathedral Oaks Road would be approximately 50 feet wide. Interior block walls between individual lots and a perimeter block wall surrounding the development would be 6 feet in height. The proposed residences are designed with architectural styles and building colors consistent with surrounding residences and the natural environment. The discussion below evaluates the potential for the proposed project to substantially obstruct or adversely alter e xisting views from public viewpoints (adjacent roadways).

View from Eastbound Cathedral Oaks Road
Figure 4.1 -1 of the Revised Draft EIR illustrates views toward the project site from eastbound Cathedral Oaks Road with the project.

When traveling east on Cathedral Oaks Road toward and along the project site, under existing conditions, the Santa Ynez Mountains are only partially and distantly visible from the roadway, but mostly blocked by intervening topography and vegetation. Project construction may tempo rarily introduce materials and equipment to the site that are visible in views of and through the site. However, construction equipment used on the project site would not be of substantial size or massing such that substantial interference of views of the foothills and mountains would occur. Changes in views during project construction would fluctuate, depending on the portion of the site being developed at any given time, and would be temporary during the construction phase. Once the site is developed with the project, the visual simulation (CO1 of the Revised Draft EIR) shows that the limited views of the mountains would be screened by new rooflines and vegetation and no longer distantly visible from this perspective.

View from Westbound Cathedral Oaks Road
Figure 4.1 -2 of the Revised Draft EIR illustrates views toward the project site from westbound Cathedral Oaks Road with the project.

When traveling west on Cathedral Oaks Road toward and along the project site, under existing conditions, there are no views of the Santa Ynez Mountains due to intervening topography and vegetation and because the mountains curve to the north. Project construction may temporarily introduce materials and equipment to the site that are visible in views of and through the sit e. However, construction 39 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
6 | P a g e

equipment used on the project site would not be of substantial size or massing such that substantial interference of views of the foothills and mountains would occur. Changes in views during project construction would fluctuate, de pending on the portion of the site being developed at any given time, and would be temporary to the construction phase. Once the site is developed with the project, the visual simulation shows (CO2 of the Revised Draft EIR) that rooflines and taller vegetation would be visible on-site. The project would not change views of the mountains or foothills from this perspective.

Views from King Daniel Lane and Royal Linda Drive
Figure 4.1 -3 and Figure 4.1 -8 of the Revised Draft EIR illustrate views from the intersecting King Daniel Lane and Royal Linda Drive, respectively, across Cathedral Oaks Road toward the project site.

From this perspective, views of the Santa Ynez foothills and mountains are limited and largely blocked by landscaping and overgrown vegetation along Cathedral Oaks Road. With the project, views through the site would be altered to include the paved site entrance and new fencing, single -family residences, and additional vegetative screening, once matured. Project construction may temporarily introduce materials and equipment to the site that are visible in views of and through the site. However, construction equipment used on the project site would not be of substantial size or massing such that substantial interference of views of the foothills and mountains would occur. Changes in views during project construction would fluctuate, depending on the portion of the site being developed at any given time, and would be temporary during the construction phase. During construction, the project applican t would be required to demonstrate that the project complies with the grading limitations.

Once developed and prior to occupancy, the project would be required to comply with height limitations established with the approved entitlement plans and finished floor elevations of each lot are consistent with the finished floor elevation shown on the Vesting Tentative Tract Map #32,046 and Final Development Plan dated July 31, 2025. Landscaping and rooflines would screen the existing, limited views of the foothil ls and mountains from King Daniel Lane.

Partial, limited views of the mountains would be retained from Royal Linda Drive with the project. Thus, while the project would result in some obstruction of existing views, these views are already very limited, only experienced for brief periods while vehicles brake before turning onto Cathedral Oaks Road, and are not identified by the City as designated scenic corridors or scenic resources.
40 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
7 | P a g e

Although the proposed project design would result in changes to views from King Daniel Lane, views of and through the site would consist primarily of on -site landscaping/vegetation, once matured.

Therefore, the project would not result in substantial, adverse changes to views of the mountains or foothills from the perspective of intervening roadways south of the site.

Conclusion
While the proposed project would result in some changes to existing views, the design of the proposed project would not result in substantial, adverse changes to identified scenic corridors or resources from public viewpoints in the project vicinity. The overall aesthetic nature of the site with the project would be dominated by landscaping and vegetation on the site, once matured, and would be cohesive with the size and design features (i.e., architectu ral styles and building colors) of other residential development in the vicinity.

Views of the site would remain dominated by landscaping and vegetation and views of the surrounding foothills and mountains would continue to be available to the public in a limited manner from intersecting public roadways. Therefore, the proposed project would have a less than significant impact related to adverse effects on scenic vistas and the aesthetic nature thereof. (Revised Draft EIR, pp. 4.1-15 -- 4.1-17.)

2. Scenic Resources
Threshold: Would the Project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?
Finding: No impact. (Revised Draft EIR, p. 4.1-22.)
Explanation: The project would not be within, nor would it affect any views from, a State Scenic Highway as designated by the State of California. As such, the project would not damage scenic resources within a state scenic highway. No impact would occur . (Revised Draft EIR, p. 4.1-

22.)

3. Visual Character
Threshold: In non-urbanized areas, would the project substantially degrade the existing visual character or quality of public view of the site and its surroundings?
41 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
8 | P a g e

Finding: Less than significant. (Revised Draft EIR, pp. 4.1-22 – 4.1-23.) Explanation: The City of Goleta is in an urbanized area because Goleta and the contiguous city of Santa Barbara have a combined population of at least 100,000 people. Given that the proposed project would facilitate redevelopment in an urbanized area, the impact discussion of visual character and views is focused on consistency with applicable zoning and other regulations governing scenic quality. An expanded discussion of the proposed project’s consistency with City of Goleta General Pl an/Coastal Land Use Plan policies is provided in Section 4.9, Land Use and Planning of the Revised Draft EIR. The project would involve demolition of an existing residence, garage, and barn; subdivision of the project site into residential and open space l ots; development of single -family residential units on each residential lot; and open space containing landscaping with native vegetation throughout the project site.

The following subsections describe the project’s consistency with applicable zoning and other regulations that govern scenic quality:.

City of Goleta General Plan/Coastal Land Use Plan . The project would be consistent with the City of Goleta General Plan/Coastal Land Use Plan policies related to scenic quality and character including Policies VH 3.3, Site Design; VH 3.4, Building Design; VH

3.5, Pedestrian -Oriented Design; VH 4.9, Landscape Design; VH

4.10, Streetscape and Frontage Design; VH 4.11, Parking Lots; VH

4.12, Lighting; VH 4.14, Utilities; and VH 4.16, Green Building; as the proposed project would implement green building practices and appropriate landscaping in all proposed development, including the residences, associated parking lots, internal roadways, and open space areas. The finished grade elevation of the project site would range from approximately 150 feet above mean sea level to approximately 245 feet above mean sea level, in conformance with the natural varying topography of the surrounding area. Existing vegetation would be maintained, as feasible, and no tree removal would occur. Landscaping would be comprised of an assortment of native and non -invasive screen shrubs, accent trees, and canopy trees to promote the natural landscape of the project area. The proposed project’s internal circulation design would provide sidewalks for pedestrian travel and include extension of an existing Class I trail adjacent to Cathedral Oaks Road that would expand pedestrian circulation infrastructure.

The proposed design of the residences would include solar photovoltaic systems pursuant t o the requirements of California 42 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
9 | P a g e

Building Code Title 24, Part 6. The proposed project’s exterior lighting would consist of downward directed fixtures. Proposed project lighting would be designed and shielded in accordance with City standards. Exterior lighting used at night (i.e. roadway lighting) would be dimmed after 11:00 p.m. to the maximum extent practical without compromising public safety. All exterior lighting in common areas and on individual parcels would be designed to meet the City’s “dark sky” and low energy use requirements and would conform to the architectural scale of the residential neighborhood. The proposed project would underground all utilities, and no above -ground utilities are proposed. Goleta Zoning Code.

Goleta Zoning Code . The project site is zoned Agriculture, with an RS-7 (Single Family Residential, 7,000 square foot lot minimum) zoning utilized for consistency evaluation herein.

As the proposed development of the project site would consist of residential uses on lots 7,000 squa re feet or greater, the proposed project would be permitted under the RS -7 zoning. The proposed project would be required to comply with development regulations pursuant to Section 17.07.040 of the City’s Zoning Code. The proposed project would meet the de velopment standards, including maximum lot coverage, maximum building height, minimum
setbacks, and parking, of the RS -7 zone. The proposed maximum height of 24 feet would be similar to adjacent residential uses and visual impacts would be minimized due to the presence of open space and vegetation surrounding and within the site. In summary, the proposed project would be consistent with applicable zoning and other regulations that govern scenic quality. Impacts would be less than significant. (Revised Draft EIR, pp. 4.1-22 – 4.1-23.)

4. Light and Glare
Threshold: Would the Project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? Finding: Less than significant. (FEIR, pp. 4.1-23 – 4.1-24.) Explanation: Project operation would involve residential use of the project site, which is typically minimal during nighttime hours when humans are typically indoors resulting in minimal new sources of nighttime illumination on the project site, limited to exterior lights on residences and streetlights. Existing offsite sources of illumination include streetlights along Cathedral Oaks Road, residential properties bordering Cathedral Oaks Road to the west and south, and facility 43 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
10 | P a g e

lighting from the Glen Annie Golf Course to east. Headlights from vehicles on Cathedrals Oaks Road are also sources of light in the project vicinity. Proposed project construction is not anticipated to occur during evening or nighttime hours in accordance with Section

17.39.070 of the City’s Zoning Code and due to surrounding residential uses within 1,600 feet of the site, which limits construction activities from Monday to Friday, 8:00 a.m. to 5:00 p.m. Thus, the proposed project would not introduce new light sources to the project site during construction. Any new light sources would be related to the new residences, roadways, and parking areas (e.g., driveways) as needed. Consequently, the following discussion focuses on the proposed project’s operational impact involving light and glare.

The project would introduce new stationary sources of light and glare on the project site through development of residential uses with driveways and internal roadways with streetlights. Exterior night lighting, including street lighting, could resul t in the exposure of adjoining areas to excessive light and glare if such lighting is not properly shielded and directed away from neighboring land uses, or if the light fixtures are excessively tall, creating a situation where appropriate light shielding is not possible. In addition, if appropriate dark-sky lighting fixtures are not incorporated and properly installed, project lighting could increase lighting of the night sky, which could result in a substantial adverse effect to nighttime views in the are a.

The primary method by which the City ensures appropriate reduction of light and glare impacts is the City of Goleta General Plan/Coastal Land Use Plan Policy VH 4.12 requirement for dark sky compliant lighting fixtures for exterior lighting. The City re quires that exterior night lighting is of low intensity, low -glare design, and hooded to direct light downward onto the subject parcel and prevent spill -over onto adjacent parcels.

All exterior lighting would be required to meet the City’s Title 17 Chapter 17.35 Zoning Ordinance, which provides exterior night lighting and dark sky requirements designed to reduce impacts to wildlife. Exterior lighting fixtures also must be kept to the minimum number and intensity needed to ensure public safety. Lights must be dimmed after 11:00 p.m. to the maximum extent practical without compromising public safety. Upward -directed exterior lighting is prohibited. All exterior lighting fixtures must be appropriate for the architectural style of the structure and surrounding area. All night/ambient lighting on streets and homes along the western boundary of the project site (adjacent to El Encanto Creek) must be 44 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
11 | P a g e

directed away from the creek in accordance with City of Goleta General Plan/Coastal Land Use Plan Policy VH 4.12(a).

Compliance with City lighting requirements and specifications, including the submittal of a photometric plan prepared by a licensed engineer as well as lighting cut sheets, would ensure that potential light spillover impacts are less than significant. Mo ving sources of light would include headlights of vehicles driving on roadways near the project site, such as Cathedral Oaks Road, and entering or exiting the project site at night. While operation of the project would involve vehicle travel, and thus pote ntial light from vehicles, these lighting sources would be similar to existing conditions surrounding the project site, as residential and recreational vehicles are frequent in the area, given the site’s proximity to Cathedral Oaks Road and the Glen Annie Golf Course. The project would introduce new sources of glare in the form of focused, intense light from sunlight reflecting on the glass surfaces of the residences and amenities, as well as from parked car windows within the new parking areas and internal roadways. However, vegetative screening in the open space areas and perimeter walls around the development would reduce off- site impacts of glare from both the proposed structures and parked cars. Thus, the potential for glare -related impacts would be lim ited and less than significant. (FEIR, pp. 4.1-23 -- 4.1-24.) B. AGRICULTURE AND FOREST RESOURCES

1. Farmland Conversion
Threshold: Would the Project convert Prime Farmland, Unique Farmland, or Farmland of Statewide significance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?
Finding: No impact. (Revised Draft EIR, p. 4-4.)
Explanation: Agriculture on the project site consists of an approximate 14.38 net- acre fallow field, which has not been in agricultural use since 1995, and three associated structures. According to the California Important Farmland Finder (California Department of Conservation [DOC] 2022), the project site is not designated as Prime F armland, Unique Farmland, or Farmland of Statewide Impor tance. Therefore, the proposed project would not convert Farmland to non-agricultural use and there would be no impact. (Revised Draft EIR, p. 4-4.)

45 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
12 | P a g e

2. Agricultural Zoning
Threshold: Would the Project conflict with existing zoning for agricultural use, or a Williamson Act contract?
Finding: No impact. (Revised Draft EIR, p. 4-4.)
Explanation: The proposed project is a qualified housing development project that utilizes the “Builder’s Remedy” protections of the California Housing Accountability Act. Accordingly, pursuant to California Government Code section 65589.5(f)(6)(A), because there are no general plan designation or zoning classification that allow the density and unit type proposed by the applicant, the project applicant has identified the RS-7 zone district as the most analogous zone to the proposed project. The Builder’s Remedy would allow the proposed residential development to be developed in accordance with the development standards of the RS -7 zone within an area zoned for Agriculture without requiring a zoning change. Accordingly, the proposed project would not conflict with current Agricultural zoning, as such development would be permitted in accordance with the provisions of Bu ilder’s Remedy. Additionally, based on the California Department of Conservation’s Williamson Act map (DOC 2025), the site is not under a Williamson Act contract. As such, the proposed project would not conflict with any existing agricultural zoning or any Williamson Act contract. Based on the above, the proposed project would have no impact on agricultural resources. (Revised Draft EIR, p. 4-4.)

3. Forestland Zoning
Threshold: Would the Project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)?
Finding: No impact. (Revised Draft EIR, p. 4-4.)
Explanation: The project site is not zoned for forest land, timberland, or timberland production, as defined by Public Resources Code sections 12220(g), 4526, or Government Code section 51104(g). There are no forest resources present on the site, and the surrounding area is developed for recreational and residential uses. Therefore, the proposed project would not conflict with forest or timberland zoning , and there would be no impact. (Revised Draft EIR, pp. 4-4.)
46 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
13 | P a g e

4. Loss of Forest Land
Threshold: Would the Project result in the loss of forest land or conversion of forest land to non-forest use?
Finding: No impact. (Revised Draft EIR, p. 4-4.)
Explanation: The project site is not zoned for forest land, timberland, or timberland production, as defined by Public Resources Code sections 12220(g), 4526, or Government Code section 51104(g). There are no forest resources present on the site, and the surrounding area is developed for recreational and residential uses. Therefore, the proposed project would not result in the loss or conversion of forest land to non-forest uses, and there would be no impact. (Revised Draft EIR, p. 4-4.)

5. Conversion of Farmland or Forestland
Threshold: Would the Project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non- forest use?
Finding: No impact. (Revised Draft EIR, p. 4-4.)
Explanation: The proposed project would not involve other changes in the existing environment that could indirectly lead to the conversion of farmland or forest land. The project site is fallow and is surrounded by residential and recreational uses. Given the absence of agricultural uses on-site or in the vicinity of the project site, the proposed project would not result in the conversion of farmland to nonagricultural or uses. Similarly, neither forest nor timberland resources would be lost or converted to non -forest uses because no forest or tim berland exists on-site or in the vicinity of the project site. Based on the above, the proposed project would have no impact on forestry resources. (Revised Draft EIR, p. 4-4.)
C. AIR QUALITY

1. Air Quality Plans and Air Quality Standards
Threshold: Would th e Project conflict with or obstruct implementation of the applicable air quality plan; violate any air quality standard or contribute substantially to an existing or projected air quality violation?
Finding: Less than significant. (Revised Draft EIR, pp. 4.2-9 – 4.2-10.) 47 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
14 | P a g e

Explanation:

According to the DOF’s population estimates for Goleta, Goleta has a current population of approximately 32,747 people (DOF 2025).

Based on the City’s average 2.59 persons per household (DOF 2025), the proposed project would result in an increase in population of 145 people, bringing the City’s population to 32,892. SBCAG’s growth forecast estimates that the population in Goleta would increase from 32,892 residents to 34,700 residents by 2050, an increase of 1,808 residents. Therefore, the addition of 145 residents to Goleta would be within the SBCAG growth projections utilized within the 2022 Ozone Plan to forecast emissions (SBCAG 2019).

The proposed project’s construction emissions would not result in substantial contributions to regional air pollutant em issions. In accordance with standard practices in the City, the following standard SBCAPCD fugitive dust control measures required by SBAPCD Rule 345 and enforced as Conditions of Approval would be required for project construction:
 During construction, use water trucks, sprinkler systems, or dust suppressants in all areas of vehicle movement to prevent dust from leaving the site and from exceeding the SBAPCD’s limit of 20 percent opacity for greater than 3 minutes in any 60 minute period. When using water , this includes wetting down areas as - needed but at least once in the late morning and after work is completed for the day. Increased watering frequency should be required when sustained wind speed exceeds 15 mph.

Reclaimed water should be used whenever po ssible. However, reclaimed water should not be used in or around crops for human consumption. On-site vehicle speeds shall be no greater than 15 miles per hour when traveling on unpaved surfaces.
 Install and operate a track-out prevention device where vehicles enter and exit unpaved roads onto paved streets. The track -out prevention device can include any device or combination of devices that are effective at preventing track out of dirt such as gravel pads, pipe-grid track-out control devices, rumble strips, or wheel-washing systems.
 If importation, exportation, and stockpiling of fill material is involved, soil stockpiled for more than one day shall be covered, kept moist, or treated with soil binders to prevent dust generation.

Trucks transporting fill material to and from the site shall be tarped from the point of origin.
48 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
15 | P a g e

 Minimize the amount of disturbed area. After clearing, grading, earthmoving, or excavation is completed, treat the disturbed area by watering, OR using roll -compaction, OR revegetating, OR by spreading soil binders until the area is paved or otherwise developed so that dust generation will not occur. All roadways, driveways, sidewalks etc. to be paved should be completed as soon as possible.
 Schedule clearing, grading, earthmoving, and excavation activities during periods of low wind speed to the extent feasible.

During periods of high winds (>25 mph) clearing, grading, earthmoving, and excavation operations shall be minimized to prevent fugitive dust created by on-site operations from becoming a nuisance or hazard.
 The contractor or builder shall designat e a person or persons to monitor and document the dust control program requirements to ensure any fugitive dust emissions do not result in a nuisance and to enhance the implementation of the mitigation measures as necessary to prevent transport of dust off -site. Their duties shall include holiday and weekend periods when work may not be in progress. The name and telephone number of such persons shall be provided to the Air Pollution Control District prior to grading/building permit issuance and/or map clearance.

As a Condition of Approval, the City would require the use of construction equipment that meets the Tier 4 emissions standards set by USEPA for non -road diesel engines, which would further reduce in particulate matter and NO2 emissions during construction. As the proposed project would be consistent with the 2022 Ozone Plan’s emissions forecast assumptions and would incorporate the standard fugitive dust control measures recommended by SBCAPCD during construction activities, the proposed project would be consistent with the 2022 Ozone Plan. Therefore, the proposed project would have a less than significant impact related to conflicts with or obstruction of implementation of the applicable air quality plan. (Revised Draft EIR, pp. 4.2-9 – 4.2-10.)

2. Cumulatively Considerable Pollutant Emissions
Threshold: Would the Project result in cumulatively considerable net increase of any criteria pollutant for which the project region is non -attainment under an applicable federal or state ambient air quality standard? Finding: Less than significant. (Revised Draft EIR, pp. 4.2-11 – 4.2-12.) Explanation: Construction Emissions . Short-term impacts include those associated with grading and construction of the proposed project. 49 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
16 | P a g e

Dust would be generated by construct ion equipment during grading (23,500 cubic yards of fill and 27,500 cubic yards of cut), implementation of infrastructure, and construction of the new building. In addition, use of heavy equipment/trucks, hauling of soil and construction materials, and oth er construction-related vehicles would result in on -site and off -site exhaust emissions. The grading and construction period would last 18 months. The proposed project’s emissions resulting from grading and construction activities are summarized in Table 4 .2-5 of the Revised Draft EIR. The proposed project’s construction emissions of ROG and NOX would not exceed the SBCAPCD threshold of 25 tons per year used by the City for this analysis. Therefore, as the project does not exceed SBCAPCD construction thresh olds of significance for the criteria pollutants in nonattainment, project construction would not contribute substantially to an existing or projected air quality violation, and this impact would be less than significant.

Operational Emissions. Operation of the proposed project would generate long-term criteria air pollutant emissions from area sources (e.g., architectural coating, consumer products, and landscaping equipment), energy sources (i.e., electricity use), and mobile sources (i.e., vehicle trips to and from the project site). These estimated emissions are shown in Table 4.2 -6 of the Revised Draft EIR . The proposed project’s operational emissions would not exceed significance threshold levels. Therefore, as the project does not exceed SBCAPCD oper ational thresholds of significance for the criteria pollutants in nonattainment, project operation would not contribute substantially to an existing or projected air quality violation, and this impact would be less than significant. (Revised Draft EIR, pp. 4.2-11 – 4.2-12.)

3. Sensitive Receptors
Threshold: Would the Project expose sensitive receptors to substantial pollutant concentrations?
Finding: Less than significant. (Revised Draft EIR, pp. 4.2-12 – 4.2-13.) Explanation: The nearest sensitive receptors to the project site are residences located approximately 200 feet to the west and 65 feet to the south.

Construction-related activities would result in temporary project - generated diesel particulate matter exhaust emissions from off-road, heavy-duty diesel equipment for site preparation, grading, building construction, and other construction activities. In addition, 50 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
17 | P a g e

construction would involve volatile organic compound emission from paints vehicles, and NOx emissions from construction equipment.

While construction activities would occur within 65 feet of residential receptors, emissions associated with construction equipment would be short term, temporary, and cease following the completion of construction, which would last 18 months. Furthermore, as a Condition of Approval, the City would require the use of construction equipment that meets the USEPA Tier 4 emissions standards for non-road diesel engines, which would substantially reduce localized air pollutant emissions, incl uding particulate matter and NOx from construction activities because Tier 4 emissions standards require the use of advanced emission control technologies in construction equipment engines. Through the implementation of Tier 4 standards, exhaust emissions from non -road diesel engines decrease by approximately 90 percent (USEPA 2004). In addition, architectural coatings would be applied by construction personnel in compliance with SBCAPCD Rule 323.1, which limits the use of volatile organic compounds in paints. The use of asphalt would occur in accordance with SBCAPCD Rule 329 which limits the use of asphalt with high levels of reactive organic compound emissions.

Compliance with SBCAPCD Rule 323.1 and 329 would minimize the amount of volatile organic compou nd and reactive organic compound emissions on -site during construction, respectively.

Consequently, people would not be exposed to toxic substances long enough to create a significant health risk. In addition, the dust control measures of SBCAPCD’s Rule 34 5 would be implemented by construction personnel to minimize fugitive dust emissions.

Therefore, construction of the proposed project would have a less than significant impact related to exposing sensitive receptors to substantial pollutant concentrations. Project operation would consist of single-family residences which themselves would not include the use of equipment that would increase toxic air emissions at the project site. Landscaping equipment such as lawnmowers could be used at individual residences; however, the sporadic and infrequent use of such equipment would not generate substantial pollutant concentrations at nearby sensitive receptors.

This type of equipment does not have large engines, such as construction equipment engines, that can resul t in substantial pollutant emissions. Project operation would not result in substantial increases in vehicle trips and therefore would not result in substantial adverse air quality impacts related to carbon monoxide. Therefore, the proposed project would n ot expose sensitive receptors to 51 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
18 | P a g e

substantial pollutant concentrations, and this impact would be less than significant. (Revised Draft EIR, pp. 4.212 – 4.2-13.)

4. Other Adverse Emissions
Threshold: Would the Project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people? Finding: Less than significant. (Revised Draft EIR, p. 4.2-14.) Explanation: The project would generate oil and diesel fuel odors during construction from equipment use. Construction of new roadways on- site would require application of aggregate concrete (asphalt) that could create objectionable odors during construction. The odors would be limited to the construction period and would be intermittent and temporary. Furthermore, these odor s would dissipate rapidly with distance from in -use construction equipment. Accordingly, project construction would not result in other emissions, such as those leading to odors, that would adversely affect a substantial number of people. SBCAPCD’s Scope a nd Content of Air Quality Sections in Environmental Documents (2022) states that certain projects have the potential to cause substantial odor impacts because of the nature of their operation and their location. Examples include fast food restaurants, bake ries, coffee roasting facilities, agricultural uses, wastewater treatment plants, food -processing plants, chemical plants, composting operations, refineries, landfills, dairies, and fiberglass molding facilities. The proposed project does not include any f acilities considered to have the potential to cause odor impacts. Therefore, the proposed project would have a less than significant impact related to emissions leading to odors that would adversely affect a substantial number of people. ( Revised Draft EIR, p. 4.2-14.)
D. BIOLOGICAL RESOURCES

1. Sensitive Species
Threshold: Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
Finding: Less than significant. (Revised Draft EIR, pp. 4.3-22 – 4.3-29.) 52 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
19 | P a g e

Explanation: Operation.

Special-Status Plant Species
Project operation would involve residential use of the project site.

While the proposed project would increase human presence on the project site, such presence would be associated with residential and recreational uses (such as biking or walking along established paths, as well as recreational use of Lot 57), which would not have the potential to result in significant impacts to special -status plants.

Operational impacts to vegetation would be limited to performance of routine landscape main tenance activities and fuel management activities, which would not involve the removal of special -status plants. Therefore, operation and maintenance impacts on special - status plants would be less than significant. (Draft EIR, pp. 4.3-23).

Special-Status Wildlife Species
One special-status wildlife species, western red bat, has a moderate potential to roost and forage on -site. No special -status wildlife species have been observed on the project site, or have a high potential to occur on-site.

Project ope ration would involve residential use of the project site, which is typically minimal during nighttime hours when humans are typically indoors and bats are active. Following the completion of construction activities, western red bat could roost in newly pla nted trees installed as landscaping allowing for foraging for insects on the project site. Raised and/or unshielded lighting on the exterior of new residential structures and new streetlights have potential to disrupt the bats’ nocturnal behavior. However, all exterior lighting would be required to meet the City’s Title 17 Chapter 17.35 Zoning Ordinance, which provides exterior night lighting and dark sky requirements designed to reduce impacts to wildlife. Compliance with these requirements would ensure th at project -related lighting would not disrupt western red bat behavior. Operational impacts on western red bat would therefore be less than significant.

Nesting Birds
Project operation would involve residential use of the project site, including routine landscaping and tree maintenance. These activities are expected to be limited to standard residential upkeep such as irrigation and pruning of vegetation, but would not involve tree removal or substantial disturbance to mature vegetation. Although 53 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
20 | P a g e

newly planted trees may eventually provide roosting or nesting habitat for migratory birds and raptors, maintenance activities would be conducted in accordance with existing fed eral and state regulations, including the Migratory Bird Treaty Act and California Fish and Game Code, which prohibit the disturbance of active nests.

Therefore, operational impacts on nesting birds would be less than significant. (Revised Draft EIR, pp. 4.3-22 – 4.3-29.)

2. Riparian Habitat
Threshold: Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Finding: Less than significant. (Revised Draft EIR, pp. 4.3-32 – 4.3-33.) Explanation: Indirect Construction Impacts on ESHA and ESHA Buffers Indirect construction impacts to riparian habitat types and sensitive natural communities designated as ESHA would include adverse water quality effects, chemical spills or vehicle leaks near and within ESHA, and dust generation. These impacts are associat ed with trenching for the new 90-foot-long section of storm drain pipe in the southwestern portion of the project site , grading for the detention basin in the southwestern portion of the project site, vegetation trimming for the bike path along Cathedral Oaks Road, and building construction near the eucalyptus grove ESHA. These activities involve heavy equipment operation, soil disturbance, and potential use of hazardous materials in close proximity to sensitive habitats.

Impacts related to dust would be m inimized with implementation of standard fugitive dust control measures recommended by the Santa Barbara County Air Pollution Control District (such as vehicle speed limits, covering stockpiles, watering of disturbed soil, and minimizing construction activ ities during high winds). Risk of spills and water quality impacts would be reduced through implementation of standard construction BMPs specified in the SWPPP (such as erosion and sediment control BMPs designed to minimize erosion and retain sediment on -site, and good housekeeping BMPs to reduce the risk of spills, leaks, and off-site discharge of construction debris and waste). Additionally, as a Condition of Approval, the City would require that chemical storage, portable toilet placement, vehicle and/or equipment maintenance, and equipment refueling only occurs in designated staging areas located at least 100 feet from El Encanto Creek, which would minimize the risk of leaks or spills 54 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
21 | P a g e

reaching surface waters. Therefore, indirect construction impacts would be less than significant. (Revised Draft EIR, p. 4.3-30.) Direct Construction Impacts on ESHA and ESHA Buffers
Direct impacts to arroyo willow thicket, black sage – California sagebrush scrub, and eucalyptus grove that serves as raptor roosting habitat E SHA, as well as the respective ESHA buffers, would include the construction of new structures or facilities within ESHA or ESHA buffers. The proposed project would directly impact native vegetation, including ESHA, in four areas: installation of a new storm drain pipe that would tie into an existing storm drain pipe in the southwestern portion of the project site; construction of a new bike path along Cathedral Oaks Road; grading in the southwestern corner of the project site to construct the detention basi n; and grading and building construction within eucalyptus grove along El Encanto Creek. Impacts to these areas are discussed further below.

Storm Drain Pipe
The proposed storm drain pipe in the southwestern portion of the project site would be installed u nderground and would result in impacts to black sage – California sagebrush scrub ESHA during trenching activities. These impacts would include vegetation removal and soil disturbance within sensitive natural communities. According to the City of Goleta General Plan/Coastal Land Use Plan Policy CE

1.6 and Goleta Municipal Code Section 17.30.040, development within ESHA and ESHA buffers is generally prohibited unless the use is considered resource-dependent and is sited and designed to avoid or minimize impa cts to the maximum extent feasible. As stipulated by City of Goleta General Plan/Coastal Land Use Plan Policy CE

1.6(d), utility structures, such as stormwater management systems, may be allowed within ESHA or buffers if they are necessary to protect public health and safety and if no feasible alternative exists outside of the ESHA. The storm drain pipe is a resource -dependent utility designed to manage stormwater runoff generated by impervious surfaces within the proposed development and to reduce downstream erosion and flooding. El Encanto Creek is the natural receiving water for stormwater in the vicinity of the project site, and the project site currently drains toward the creek under existing conditions. The proposed storm drain pipe would tie into an e xisting storm drain pipe that already discharges to El Encanto Creek. Due to topographic constraints and the location of the creek adjacent to the western boundary of the project site, there is no feasible alternative discharge location. Additionally, City of Goleta General Plan/Coastal Land Use Plan Policy CE 2.5 (Maintenance of Creeks 55 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
22 | P a g e

as Natural Drainage Systems) emphasizes discharge to natural waterbodies, such as El Encanto Creek. The storm drain pipe has been sited and designed to minimize significant adverse impacts to riparian vegetation and the biological integrity of El Encanto Creek.

Bike Path
The proposed bike path would serve as a continuation of an existing Class I trail that extends east of the project site and runs parallel to Cathedral Oaks Road, and would be constructed immediately north of Cathedral Oaks Road in the southern and southwestern portion of the project site, within arroyo willow thicket and black sage – California sagebrush scrub ESHA. The proposed bike path has been designed to follow an existing disturbed corridor to the extent possible. Construction of the proposed bike path would require continuous pruning of adjacent vegetation to prevent overgrowth onto the path, which would result in permanent impacts to ESHA.

However, the City of Goleta General Plan/Coastal Land Use Plan Policy CE 1.6 and Goleta Municipal Code Section 17.30.040, which provide protection for ESHA and ESHA buffers against development, allow for resource-dependent uses (including public accessways and trails) that are sited to avoid or minimize impacts on the resource to the maximum extent feasible. As designed, the proposed bike path would minimize impacts to habitat value or sensitive species to the maximum extent feasible from the existing configuration.

Detention Basin
Construction of the detention basin would result in impacts (vegetation removal and soil disturbance from grading) to arroyo willow thicket ESHA and black sage – California sagebrush scrub ESHA in the southwestern portion of the project sit e. This location was selected for the detention basin because it is the lowest elevation point on the project site, which allows gravity-fed drainage from the surrounding development without the need for pumps or extensive underground infrastructure. The b asin is designed to manage stormwater runoff and improve water quality, and is a resource-dependent utility that may be permitted within ESHA or buffers when no feasible alternative exists and when designed to minimize impacts. The basin would be located outside of the riparian corridor to the extent feasible. Locating the basin elsewhere on the project site would require substantial regrading, increased disturbance to ESHA, or conflict with proposed residential lots and traffic circulation. Additionally, the southwestern corner of the project site is adjacent to El Encanto Creek, which is the natural receiving water for stormwater in the area.
56 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
23 | P a g e

Grading and Building Construction
Grading on Lots 1, 2, and 58 would disturb the eucalyptus grove that serves as ra ptor roosting habitat ESHA. However, all of the eucalyptus trees in the study area are rooted on the adjacent golf course property, and the proposed project is not expected to require removal of any eucalyptus trees unless they are determined to be structurally unsound and pose a safety hazard to construction workers and future residents and their guests. Impacts would be limited to removal of ornamental trees and shrubs and ruderal vegetation beneath the eucalyptus tree canopy.

Impacts would include disturbances, such as vegetation removal and soil disruption during construction, to this sensitive natural community. Grading is not anticipated to result in removal or major impacts to protected trees within the ESHA or alter the surface hydrology or remove native vegetation within the ESHA buffer, as it would be limited to surface -level modifications that avoid tree root zones and alterations to drainage patterns. Grading on Lots 1, 2, and 58 would impact 7,811 square feet of eucalyptus grove due to grading and vegetation removal. Additionally, the proposed project would impact 685 square feet of eucalyptus grove through habitat loss associated with permanent removal of understory vegetation associated with this ESHA.

Summary of Construction Impacts on ESHA
The proposed project would result in both indirect and direct impacts to riparian habitat types and sensitive natural communities designated as ESHA. Indirect impacts would include adverse water quality effects, chemical spills or vehicle leaks near and within ESHA, and habitat destruction during construction. Direct impacts would include the following permanent impacts:
 Impacts to 378 square feet of black sage – California sagebrush scrub ESHA due to trenching for the new storm drain pipe;
 Impacts to 8,496 square feet of eucalyptus grove that serves as raptor roosting habitat ESHA due to development on Lots 1, 2, and 58 for the proposed detention basin and residential development; and
 Impacts to 125 square feet of arroyo willow thicket ESHA and 82 square fee t of black sage – California sagebrush scrub ESHA due to construction of the new bike path.

In total, the proposed project would permanently impact 57 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
24 | P a g e

approximately 9,081 square feet (0.21 acre) of ESHA. The overall project-related impact on riparian habitat and sensitive natural communities would be potentially significant.

Mitigation Measure BIO-3 would reduce potential impacts to riparian habitat and sensitive vegetation communities by requiring compensatory mitigation for habitat loss due to project development.

Mitigation Measures BIO-4 and BIO-7 would reduce potential indirect impacts to riparian habitat and sensitive vegetation communities during project construction by requiring biological monitoring during construction and construction worker environm ental awareness training (BIO -4) and fencing around ESHA (BIO -7). Following the implementation of Mitigation Measures BIO-3, BIO-4, and BIO-7, the proposed project’s impact involving a substantial adverse effect on riparian habitat and sensitive vegetation communities would be less than significant with mitigation incorporated. (Revised Draft EIR, pp.

4.3-30 -- 4.3-33.)
Operational Impacts on ESHA and ESHA Buffers
Operation and maintenance of the proposed project would involve residential use of the project site and maintenance of landscape vegetation. These activities include the use of landscaping chemicals, such as fertilizers and pesticides, which have the potential to affect adjacent ESHA through runoff. Operational activities would be conducted in accordance with Goleta Municipal Code Section 17.030.060 (Management of ESHAs), which prohibits the use of insecticides, herbicides, artificial fertilizers, or other toxic chemical substances within and adjacent to ESHA. Additionally, the proposed detention basin is designed to capture and treat runoff before it reaches ESHA. Therefore, operational activities would have a less than significant impact on riparian habitat types and sensitive natural communities. (Revised Draft EIR, pp. 4.3-32 – 4.3-33.)

3. Wetlands
Threshold: Would the Project have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but n ot limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Finding: Less than significant. (Revised Draft EIR, pp. 4.3-34 – 4.3-35.) 58 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
25 | P a g e

Explanation: Operation. Operation and maintenance of the proposed project would involve residential use of the project site and maintenance of landscape vegetation. These activities include the use of landscaping chemicals, such as fertilizers and pesticides, which have the pot ential to affect adjacent surface waters through runoff.

Operational activities would be conducted in accordance with Goleta Municipal Code Section 17.030.060 (Management of ESHAs), which prohibits the use of insecticides, herbicides, artificial fertilizer s, or other toxic chemical substances within and adjacent to ESHA, which surrounds El Encanto Creek. Additionally, the proposed detention basin is designed to capture and treat runoff before it reaches El Encanto Creek. Therefore, operational activities wo uld have a less than significant impact on aquatic resources. (Revised Draft EIR, pp.

4.3-34 – 4.3-35.)

4. Wildlife Movement
Threshold: Would the Project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Finding: Less than significant. (FEIR, pp. 4.3-35 -- 4.3-37.) Explanation: The project site is surrounded by residential development an d the Glen Annie Golf Course, and fenced with a six -foot-tall chain -link fence with one opening along Cathedral Oaks Road. The perimeter fence around the project site effectively prevents large mammals from entering the project site. Given the habitat and vegetation types present on the project site, and lack of essential wildlife resources such as food, water, and shelter, wildlife utilization of the project site is very low and likely limited to a few common resident species of amphibians, small mammals, reptiles, and common migratory and resident birds. El Encanto Creek, to the west of the project site, has the potential to serve as a wildlife corridor between open space to the north and the Pacific Ocean to the south, but such potential has been greatly reduced over time due to urban development south of the project site. Project construction could indirectly affect wildlife movement through the introduction of noise, light, and increased human presence, all of which could affect essential behavioral activities and physiology of wildlife.

Noise (Operation)
Operational noise levels would not exceed the City’s 65 -decibel 59 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
26 | P a g e

noise standard and would be limited to residential sources, such as heating, ventilating, and air conditioning units. Impacts on wildlife movement from operational noise would be less than significant.

Light
Proposed project construction would not occur during evening or nighttime hours in accordance with Section 17.39.070 of the Goleta Municipal Code, which limits construction activities from Monday to Friday, 8:00 a.m. to 5:00 p.m. Thus, the proposed project would not introduce new light sources to the project site during the construction time period. Impacts on wildlife movement as a result of construction lighting would be less than significant.

The proposed project would introduce new sources of light from the new residences, roadways, and parking ar eas (e.g., driveways).

Proposed project lighting would be designed in accordance with City standards, including the City of Goleta’s General Plan/Coastal Land Use Plan Policy 4.12 (Lighting), which requires outdoor lighting fixtures to be designed, located , aimed downward or toward structures (if properly shielded), retrofitted if feasible, and maintained in order to prevent overlighting, energy waste, glare, light trespass, and sky glow (City of Goleta 2006). All night/ambient lighting on streets and homes along the western boundary of the project site (adjacent to El Encanto Creek) would be directed away from the creek in accordance with City of Goleta General Plan/Coastal Land Use Plan Policy VH 4.12(a). Moving sources of light would include headlights of vehicles driving on roadways near the project site, such as Cathedral Oaks Road, and entering or exiting the project site at night. While project operation would involve vehicle travel, and thus potential light from vehicles, these lighting sources would be similar to existing conditions surrounding the project site, as residential and recreational vehicles are frequent in the area, given the site’s proximity to Cathedral Oaks Road and the Glen Annie Golf Course.

Therefore, impacts on wildlife movement as a result of operational project lighting would be less than significant.

Human Presence
Project construction would result in increased human presence, including construction workers, at the project site. However, project construction would not occur duri ng evening or nighttime hours in accordance with Section 17.39.070 of the Goleta Municipal Code, which limits construction activities from Monday to Friday, 8:00 a.m. to 5 p.m. Many wildlife species are nocturnal or crepuscular3 , and 60 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
27 | P a g e

are typically resting or hiding during the day when construction activities occur. Therefore, increased human presence during construction would be unlikely to substantially interfere with wildlife movement, and construction impacts would be less than significant.

Project ope ration would introduce residential uses and increase human activity. However, the project site is not a designated wildlife corridor. Although a portion of El Encanto Creek extends onto the western edge of the project site, its potential to serve as a wild life movement corridor has been greatly reduced over time due to urban development south of the project site, and the creek itself is not proposed for development or alteration beyond the installation of a storm drain outlet. Construction of the storm drai n outlet would not involve channelization, culverting, or other modifications that would impede wildlife movement. No fencing or structures would block access to the creek. Furthermore, the creek corridor would remain vegetated and connected to upstream and downstream open space areas, preserving its function as a movement corridor for small mammals, amphibians, reptiles, and birds. Therefore, operational impacts to wildlife movement would be less than significant. ( FEIR, pp. 4.3-35 -- 4.3-37.)

5. Habitat Conservation Plans
Threshold: Would the Project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? Finding: No impact. (Revised Draft EIR, p. 4.3-43.)
Explanation: The proposed P roject is not within the jurisdiction of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan.

No impact would occur. (Revised Draft EIR, p. 4.3-43.)
E. CULTURAL RESOURCES

1. Historical Resources
Threshold: Would the Project cause a substantial adverse change in the significance of a historical resource pursuant to State CEQA Guidelines, section 15064.5?
Finding: No impact. (Revised Draft EIR, p. 4.4-12.)
61 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
28 | P a g e

Explanation: The project site does not contain any historic resources; therefore, the project would not create a substantial adverse change in the significance of a historical resource. No impact would occur. (Revised Draft EIR, p. 4.4-12.)

2. Human Remains
Threshold: Would the Project disturb any human remains, including those interred outside of dedicated cemeteries?
Finding: Less than significant. (Revised Draft EIR, pp. 4.4-16 – 4.4-17.) Explanation: The Phase I Cultural Resources Investigation (Rasmussen 1999) and Extended Phase I Archaeological Investigation (Dudek 2011) for the proposed project did not identify human remains or prehistoric villages where human remains and/or cemeteries are known to exist within the project site. However, the potential cannot be ruled out that human remains could be discovered during ground disturbing activities. In the event of an unanticipated discovery of human remains during construction, the State of California Health and Safety Code Section 7050.5 requires that all construction activities halt in the vicinity of the discovery and the County Coroner be contacted immediately. The County Coroner would make a
determination of origin and disposition of the human remains pursuant to Public Resources Code Section 5097.98. If the human remains are determined to be prehistoric, the coroner would notify the NAHC, which would determine and notify a most likely descendant (MLD). The MLD would complete an inspection of the site within 48 hours of being granted access to the site. The MLD would be responsible for the ultimate disposition of the remains, as required by Section 5097.98 of the Public Resources Code.

Recommendations by the MLD may include: (1) the nondestructive removal and ana lysis of human remains and items associated with Native American human remains; (2) preservation of Native American human remains and associated items in place; (3) relinquishment of Native American human remains and associated items to the descendants for treatment; or (4) other culturally appropriate treatment. With compliance with existing regulations prescribed in the State of California Health and Safety Code Section 7050.5 and Public Resources Code Section 5097.98, impacts to human remains would be le ss than significant. (Revised Draft EIR, pp. 4.4-16 – 4.4-17.)

62 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
29 | P a g e

F. ENERGY

1. Wasteful Use of Energy
Threshold: Would the Project result in potentially significant impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Finding: Less than significant. (Revised Draft EIR, p. 4-5.) Explanation: Construction activities would involve temporary energy including fuel for equipment and vehicles and electricity for site operations. These activities would be short -term and not considered excessive given the project’s scale and duration. Energy use would not be considered excessive as project contractors would be required to comply with the provisions of the California Code of Regulations Title 13 Sections 2449 and 2485, which prohibit diesel -fueled commercial motor vehicles and off -road diesel vehicles from idling for more than five minutes and would minimize unnecessary fuel consumption.2 Furthermore, as a Condition of Approval, the City would requ ire the use of construction equipment that meets the USEPA Tier 4 emissions standards for non -road diesel engines, which result in improved fuel efficient compared to other tiers of diesel engines (Mico Equipment 2024).

In addition, heavy -duty equipment w ould be subject to the United States Environmental Protection Agency Construction Equipment Fuel Efficiency Standard, which would also minimize inefficient, wasteful, or unnecessary fuel consumption. These practices would result in efficient use of energy necessary to perform construction of the proposed project. California Energy Code (Title 24, Part 6) and CALGreen (Title 24, Part 11) sets minimum energy efficiency standards for building systems such as insulation; heating, ventilation, and air conditioni ng; lighting; and water heating.

CALGreen mandates sustainable building practices including water conservation, indoor air quality, and construction waste reduction (California Energy Commission 2025a; 2025b).

The residences would incorporate energy effic ient design features consistent with Title 24. For example, the proposed project’s inclusion of Energy Star appliances and low-flow plumbing fixtures is consistent with these codes and requirements. Exterior lighting would also comply with the City of Gole ta’s “dark sky” ordinance (Municipal Code Chapter 17.35), further minimizing unnecessary energy use associated with lighting. Furthermore, during operation 63 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
30 | P a g e

the proposed project would not require the use of natural gas as the proposed residences would be al l-electric. Adherence to regulatory requirements designed to reduce energy consumption would ensure the construction and operation of the proposed project would not involve the wasteful, inefficient, or unnecessary use of energy. This impact would be less than significant. (Revised Draft EIR, p. 4-5.)

2. Energy Efficiency Plans
Threshold: Would the Project conflict with or obstruct a state of local plan for renewable energy or energy efficiency?
Finding: Less than significant. (Revised Draft EIR, pp. 4-5 – 4.6.) Explanation: The proposed project would be consistent with City of Goleta Conservation Element Policy CE 13.1 and Policy CE 13.3, which encourages energy conservation through efficient building design and the use of renewable energy technologies beca use proposed project design and construction would comply with standards set in California Building Code Title 24, which require implementation of energy-efficient light fixtures, building materials, and heating, ventilation, and air conditioning equipment. The proposed design of the residences would include solar photovoltaic systems pursuant to the requirements of California Building Code Title 24, Part 6.

Adherence to these standards would ensure the proposed project would minimize energy consumption in the new residences (City of Goleta 2025a). In addition, the proposed project aligns with the City’s Strategic Energy Plan by sourcing electricity from Southern California Edison, which is required under Senate Bill 100 to procure 60 percent renewable energy by 2030 and 100 percent by 2045.

In addition, residents would have the opportunity to opt -in to the Central Coast Community Energy electric procurement system, which procures electricity from renewable sources for delivery.

Central Coast Community Energ y has an overarching goal of sourcing 100 percent clean energy by 2030 (Central Coast Community Energy 2025). Accordingly, the proposed project would be supplied with renewable electricity in accordance with the requirements of Senate Bill 100 either by SCE in 2045 or by Central Coast Community Energy in 2030. The proposed project would result in localized increases in fuel use from vehicles as residents travel to and from the project site. However, this energy expenditure would not be considered wasteful, inefficient, or unnecessary as vehicles are generally motor vehicles are designed to be fuel efficient. In addition, the proposed project includes the continuation of an 64 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
31 | P a g e

existing Class I trail that extends east of the project site and runs parallel to Cath edral Oaks Road, which would promote alternative modes of transportation for residents and encourage less vehicle use, thereby reducing energy use associated with vehicle trips.

Therefore, the proposed project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. This impact would be less than significant. (Revised Draft EIR, pp. 4-5 –

4.6.)
G. GEOLOGY AND SOILS

1. Fault Rupture
Threshold: Would the Project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist -Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial eviden ce of a known fault?
Finding: Less than significant impact. (Revised Draft EIR, p. 4.5-9 – 4.5-10.) Explanation: Known Fault. The project site is not located within an Alquist-Priolo Earthquake Fault Zone, and no active faults are mapped across the project site. The nearest mapped fault is the More Ranch Fault, located approximately 1.2 miles southeast of the project site. As the project site does not overlie a known fault the proposed project would not directly or indirectly cause the risk of loss, injury, or death involving rupture of a known earthquake fault. No impact would occur.

Liquefaction. The project site is underlain b y stiff to very hard clay and silt with localized weathered Rincon shale. Subsurface exploration did not encounter groundwater to the maximum depth explored (approximately 51 feet), and no loose granular layers were observed. These conditions are not condu cive to liquefaction or lateral spreading, which typically require loose, saturated granular soils. The potential for liquefaction and associated lateral spreading at the project site is negligible. The proposed project’s design would include implementation of standard engineering practices consistent with CBC requirements, such as foundation design and soil compaction techniques, which would reduce the potential for substantial adverse effects due to liquefaction.

Therefore, the proposed project’s impact r elated to directly or 65 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
32 | P a g e

indirectly cause substantial adverse effects related to seismic - induced ground failure, including liquefaction, would be less than significant. (Revised Draft EIR, p. 4.5-9 – 4.5-10.)

2. Soil Erosion
Threshold: Would the Project result in substantial soil erosion or the loss of topsoil?
Finding: Less than significant. (Revised Draft EIR, pp. 4.5-11 – 4.5-12.) Explanation: Construction: The proposed project would involve over one acre of site disturbance during grading and the construction of residences, sidewalks, roadways, patios, landscaping, and associated facilities.

Construction would involve grading of approximately 27,500 cubic yards of cut and 23,500 cubic yards of fill. This grading activity would involve vegetation removal and expose soil to erosion. Construction projects of one or more acres are subject to the requirements of the Construction Stormwater General Permit, which requires preparation and implementation of a SWPPP to contr ol the discharges of pollutants, including sediment, into local surface water drainages.

The SWPPP would specify the storm water monitoring and
construction BMPs required to be implemented to minimize water quality degradation. Construction BMPs would incl ude, but are not limited to, erosion and sediment control BMPs designed to minimize erosion. In addition to NPDES permit requirements, construction activities would be subject to the requirements of Chapter 15.09 of the City’s Municipal Code which requires preparation of an erosion and sediment control plan in order to obtain a grading permit. The City accepts a SWPPP in lieu of an erosion control and sediment plan, if the SWPPP contains the requirements of the City’s required elements of an erosion and sed iment control plan. As stated in Municipal Code Section 15.09.110, the City’s Planning and Environmental Review Director or designee would review the SWPPP as part of the grading permit application to ensure the City’s required elements of an erosion and s ediment control plan are implemented within the SWPPP. Accordingly, the SWPPP prepared for the proposed project would include information on proposed BMPs that would be used during construction to retain sediment on- site, minimize surface runoff and erosio n, utilize vegetation for erosion control, and control pollution from on -site stormwater discharges, as well as a summary of precautionary measures to be taken to ensure vehicle use does not result in erosion These requirements would minimize the potential for construction activities 66 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
33 | P a g e

to result in substantial soil erosion or the loss of topsoil. As such, construction phase impacts would be less than significant.

Operation: During operation, the primary sources of erosion would be stormwater runoff from impe rvious surfaces and landscaped areas. However, the proposed project includes stormwater infrastructure designed to maintain pre -project runoff rates and minimize erosion. The proposed project would include a detention basin located in the western portion o f the project site and an underground detention system located at the southern portion of the project site. The proposed detention basin and underground detention system have been sized to ensure the post -project peak runoff outflows would be the same as t he pre -project peak runoff outflows for a 100 -year flood event; thereby ensuring that erosion discharge from runoff into El Encanto Creek and the City’s storm drain system would not be increased as a result of the proposed project. In addition, landscaping would include drought -tolerant native plants and smart irrigation systems to minimize overwatering and reduce erosion potential. Proposed project design would ensure that operation of the proposed project would minimize the potential to result in substantial soil erosion or the loss of topsoil. This impact would be less than significant. (Revised Draft EIR, pp. 4.5-11 – 4.5-

12.)

3. Septic Tanks
Threshold: Would the Project have soils incapable of adequately supporting the use of septic tanks or alternative w aste water disposal systems where sewers are not available for the disposal of waste water? Finding: No impact. (Revised Draft EIR, p. 4.5-14.)
Explanation: The proposed project would include underground utility connections for sewer service provided by Goleta West Sanitary District and would not rely on septic tanks or alternative wastewater disposal systems. As the project would be connected to a public sewe r system, the suitability of site soils for septic systems is not relevant to the proposed development. As such, the project would not result in impacts related to soils incapable of supporting septic tanks or alternative wastewater disposal systems. The p roposed project would connect to the existing sewer service provided by Goleta West Sanitary District and would not require the use of septic tanks or alternative wastewater disposal systems. No impact would occur. (Revised Draft EIR, p. 4.5-14.)
67 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
34 | P a g e

H. GREENHOUSE GAS EMISSIONS

1. Emissions Generation
Threshold: Would the Project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Finding: Less than significant. (Revised Draft EIR, p. 4.6-11.) Explanation: Construction and operation of the project would generate GHG emissions. This analysis considers the combined impact of GHG emissions from both construction and operation. As the project site is used for storage, which is not a GHG -intensive use, the impacts are assessed relative to the baseline, which assumes negligible GHG emissions currently occurring at the project site. Construction- related GHG emissions associated with heavy -duty construction equipment, material delivery trucks, and constr uction worker trips would occur intermittently during construction of the proposed project. Following completion of the proposed project, construction - related GHG emissions would cease. Therefore, these emissions are considered temporary and short -term in nature. Table 4.6 -1 of the Revised Draft EIR presents the GHG emissions generated during proposed project construction activities. The construction is assumed to occur over the course of a period of 18 months, and thus the estimated emissions reflect a pea k annual emission rate from construction activities.

The proposed project’s construction activities would generate approximately 565 MT of CO2e. Amortized over 30 years,
construction GHG emissions would total 18.8 MT of CO2e. Per guidance in the County’s 2024 Environmental Thresholds and Guidelines Manual, as construction GHG emissions are temporary and short -term in nature, the proposed project’s impact related to GHG emissions are evaluated based on the proposed project’s annual amortized construction em issions over the lifetime of the project (a default lifetime of 30 years) combined with annual operational emissions.

Operation of the project would generate GHG emissions associated with area sources (e.g., landscape maintenance), energy and water usage, refrigerant usage, vehicle usage (employee trips), and wastewater and solid waste generation. Table 4.6 -2 shows the 68 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
35 | P a g e

combined estimated annual construction and operational emissions associated with the proposed project based on GHG emissions per resident, consistent with the County’s GHG threshold. As shown therein, the proposed project’s combined construction and operational emissions would not exceed the County’s 2.68 MT CO2e per resident per year threshold. Therefore, the proposed project would not generate substantial GHG emissions directly or indirectly that may have a significant impact on the environment. This impact would be less than significant. (Revised Draft EIR, pp. 4.6-11 – 4.6-

12.)

2. Emission Reduction Plans
Threshold: Would the Project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emission of greenhouse gases?
Finding: Less than significant. (Revised Draft EIR, pp. 4.6-14 – 4.6-15.) Explanation: 2022 Scoping Plan
The proposed project would be consistent with all local actions, save for the provision of at least 20 percent of units affordable to lower income levels. The proposed project includes 20 percent deed - restricted units, four of which would be designated for extremely low income an d one of which would be designated for low income, resulting in 9 percent of units deed -restricted for low income.

Although the proposed project would not fully meet 20 percent affordable housing, the proposed project would be consistent with the other app licable measures of Appendix D of the Revised Draft EIR. The proposed project would be overall consistent with the 2022 Scoping Plan because the proposed project would incorporate several key attributes to minimize GHG emissions specified in the 2022 Scoping Plan, including the no net loss of affordable housing, installation of electric vehicle charging receptacles, building electrification, and installation of a Class I bike trail to facilitate increased bicycle travel. A project that incorporates some but not all of the key project attributes may still be consistent with the state’s climate goals. Because the proposed project would be consistent with all other Appendix D local actions and would still include the provision of some affordable housing, the pr oposed project would overall be consistent with the 2022 Scoping Plan.

69 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
36 | P a g e

SBCAG 2050 RTP/SCS
Policy 1.1 of the 2050 RTP/SCS aims to promote a “better balance of jobs and housing to reduce long-distance commuting by means of traditional land use zoning” (SB CAG 2025). The proposed project would utilize the “Builder’s Remedy” protections of the California Housing Accountability Act, which would allow for the development of housing within the Agriculture II zone. The addition of housing in the Agriculture II zone would provide additional flexibility to traditional land use zoning to increase the local housing supply in Goleta, thereby providing employees who work in Goleta with additional opportunities to relocate closer to their place of work and reduce long-distance commuting. Therefore, the proposed project would be consistent with Policy 1.1. In addition, Policy 3.2 2050 RTP/SCS aims to “plan for adequate affordable and workforce housing within existing urbanized areas near jobs and public transit” (SBCAG 2025). The proposed project includes the provision of affordable housing within 0.2 -mile of existing transit facilities. Therefore, the proposed project would be consistent with Policy 3.2.

City of Goleta General Plan/Coastal Land Use Plan
The proposed project would be consistent with Policy CE 15.3 of the Conservation Element by incorporating water efficient fixtures to reduce water consumption for landscaping, plumbing, and irrigation consistent with the latest Title 24 Green Building Code and Building Energy Efficiency Standards. The project would be consistent with Transportation Element Policy TE 1.1 by placing residential development within proximity to existing transit and bicycle facilities on Cathedral Oaks Road. The proposed project would also be consistent with Transportation Element Policy TE 11.1 by including the continuation of an existing Class I trail that extends east of the project site and runs parallel to Cathedral Oaks Road, consistent with the City’s bikeways plan map. Th e proposed residences would not utilize natural gas and would be constructed in accordance with the energy reduction standards set forth in CALGreen and the Building Energy Efficiency Standards, including the CALGreen requirements for the installation of s olar photovoltaic panels which would be consistent with Conservation Element Policy CE 13.1 and Policy CE

13.3. Based on the above, the proposed project would be consistent with policies in the City of Goleta General Plan/Coastal Land Use Plan which assist in reducing GHG emissions.

70 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
37 | P a g e

City of Goleta Climate Action Plan
The proposed residences include solar in accordance with the Title 24 Building Energy Efficiency Standards for solar on residential land uses. This would align with align with Policy RE -1 of the City of Goleta’s CAP, which requires the City to continue implementation of a solar-ready ordinance requiring buildings to be constructed such that solar installation is possible, and Policy RE -4 of the City of Goleta’s CAP, which requires the City to encourage solar installation in new residential development. The proposed project includes the continuation of an existing Class I trail that extends east of the project site and runs parallel to Cathedral Oaks Road which would promote alternative modes o f transportation for residents and be consistent with Policy T -7 of the City of Goleta’s CAP, which requires implementation of the City of Goleta General Plan/Coastal Land Use Plan Policy TE 11.

The proposed project’s landscaping would include low-volume spray heads, bubblers, and drip systems, which would be controlled by an automatic timer with a seasonal adjustment to apply less water during the rainy season and minimize water use. In addition, the proposed residences would incorporate energy -efficient design features consistent with Title 24 of the California Building Code, including the use of low -flow plumbing fixtures. These water efficiency design features would assist to minimize water use consistent with Policy WR -1, which encourages residents to implement water retrofits and utilize water -efficient landscaping to reduce per capita water consumption. The proposed project would be consistent with the policies outlined in the City of Goleta’s CAP.

Conclusion
The consistency analysis demonstrates th at overall the proposed project complies with the plans, policies, regulations and GHG reduction actions/strategies outlined in 2022 Scoping Plan, SBCAG’s 2050 RTP/SCS, City of Goleta General Plan/Coastal Land Use Plan, and City of Goleta’s CAP. Overall consistency with the above plans, policies, and GHG reduction measures would ensure that the proposed project’s incremental contribution of GHG emissions would not inhibit the ability of the state to meet its GHG reduction goals.

Therefore, the proposed project’s impact related to conflicts with any applicable plans, policies, and measures an agency adopted for the purpose of reducing emissions of GHG emissions would be less than significant. (Revised Draft EIR, pp. 4.6-14 – 4.6-15.)
71 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
38 | P a g e

I. HAZARDS AND HAZARDOUS MATERIALS

1. Hazardous Materials
Threshold: Would the Project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Finding: Less than significant. (Revised Draft EIR, pp. 4.7-13 – 4.7-14.) Explanation: Construction. Project demolition and construction would temporarily increase the regional transport, use, and disposal of construction-related hazardous materials and petroleum products (e.g., diesel fuel, lubricants, paints and sol vents, and cement products containing strong basic or acidic chemicals). The increased use of these hazardous materials has the potential to result in adverse effects in the event construction workers, the public, or the surrounding environment become expo sed to these hazardous materials and associated health risks. Potential exposure could result from accidental spills or leaks during fueling or equipment maintenance, improper storage or handling of chemicals, or inadequate disposal of hazardous waste. Air borne exposure may also occur through dust inhalation or the release of fumes and vapors from volatile compounds. Soil and groundwater contamination could result from leaching or runoff, particularly during storm events.

Additionally, risks to workers may be elevated if personal protective equipment is not used or if safety protocols are not followed, while public exposure could occur through unauthorized site access or the migration of contaminants beyond the construction zone. Hazardous materials are com monly used at construction sites, and project construction activities would be required to comply with applicable federal and state regulations established by USEPA and the State of California. These include the Hazardous Material Transportation Act, Resource Conservation and Recovery Act, the California Hazardous Materials Management Act, and CCR Title 22. Oversight by the appropriate federal, state, and local agencies and compliance by new development with applicable regulations related to the handling and storage of hazardous materials would minimize the risk associated with potential exposure of the public to these substances.

These regulations require that only trained and certified individuals handle hazardous materials; enforce safety regulations for the transportation of hazardous materials via vehicle, aircraft, and rail; and set forth containment protocols and incident reporting 72 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
39 | P a g e

procedures, among other requirements. Additionally, compliance with the Construction Stormwater General Permit requires implementation of Good Housekeeping Best Management Practices to reduce risk of spills or runoff from hazardous materials used during construction. During the Phase I ESA site reconnaissance, various containers of hazardous substances and petroleum products , including paint, gasoline, motor oil, and propane, were observed outside of the southernmost structure on the project site. Project construction would include removal of these existing hazardous materials and waste from the project site; such removal and disposal of on -site hazardous materials would be required to comply with applicable federal and state regulations noted above, which would minimize potential impacts associated with the transport and disposal of these substances. With compliance with exis ting regulations governing transport, use, and disposal of hazardous materials, the project would not create a significant hazard to the public or the environment during construction. This impact would be less than significant.

Operation
Residential land use is not typically associated with the use, transportation, storage, or generation of substantial quantities of hazardous materials. Project operation would result in an incremental increase in the use of household hazardous materials, such as cleaning products. In addition, landscaping would include the use of fertilizers and pesticides on -site. The use of these materials could result in exposure of residents, visitors, and the public to hazardous materials and associated health risks. However, all hazardous material transport, use, or disposal associated with the proposed residences would be required to comply with existing hazardous materials regulations established by USEPA and the State of California. These regulations prescribe measures for the safe transport, use, storage, and disposal of hazardous materials to reduce the risk of spills. With compliance with existing regulations governing transport, use, and disposal of hazardous materials, the proposed project would not create a significant hazard to the public or the environment during operation. This impact would be less than significant. (Revised Draft EIR, pp. 4.7-13 – 4.7-14.)

2. Accident or Upset
Threshold: Would the Project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident 73 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
40 | P a g e

conditions involving the release of hazardous materials into the environment?
Finding: Less than significant. (Revised Draft EIR, pp. 4.7-16 – 4.7-17.) Explanation: Construction
Hazardous Materials in Soil, Soil Vapor, or Groundwater Project construction would include grading and earth -moving activities that could potentially disturb hazardous materials in soils throughout the project site. Ground -disturbing activities generating fugitive dust would have the potential to result in the release of hazardous materials into the environment if not handled properly, Based on the depth to groundwater, groundwater would not be encountered during grading activities; therefore, there is no potential for the release of contaminated groundwater. The project site was not identified as having existing soil vapor contamination, based on vapor encroachment evaluations completed as part of the P hase I.

In addition, based on the results of the soil sampling completed as part of the Phase I ESA, ground -disturbing activities on the project site would not have the potential to expose construction workers or residents to risks associated with the rele ase of organochlorine pesticides or arsenic. Impacts related to the release of hazardous materials in soil, soil vapor, and groundwater would be less than significant. (Revised Draft EIR, p. 4.7-16.)
Operation
Radon The Radon Zone Map for Santa Barbara County produced by the Bureau of Mines and Geology indicates that the project site is in an area with high potential for indoor radon levels exceeding USEPA recommended level of 4.0 pCi/L (California Department of Conservation 2000). Accordingly, the release of radon could be a risk to residents. However, in accordance with City of Goleta General Plan/Coastal Land Use Plan Policy SE 1.9, the City requires testing of radon levels on the project site and implementation of radon - resistant design if radon level s on-site are in excess of the USEPA recommended level of 4.0 pCi/L. If on -site radon levels exceed the USEPA recommended threshold, as a Condition of Approval, the City would require the design of homes to comply with the standards for reducing radon in s ingle-family residences implemented by the American Association of Radon Scientists and Technologists and American National Standards Institute.
74 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
41 | P a g e

These standards include, but are not limited to, use of vents to remove radon from residences, use of gravel u nder the foundations of residences to minimize radon intrusion into residences, and mandated radon testing after implementation of radon -reducing design features but prior to occupancy. With adherence to these standards, the proposed project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving radon release. This impact would be less than significant.

Hazardous Material Use Project operational activities would involve minimal transport, use, and disposal of hazardous materials used for routine maintenance. Small quantities of household hazardous materials and landscaping materials may be used on-site.

However, the project’s operational activities would be required to comply with applicable federal, state, and local regulations, which prescribe measures to reduce the risk of accidental spills. In addition, the Phase I ESA did not identify hazards on -site that could pose a risk to residents during operation of the proposed project. Therefore, project operation would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the likely release of hazardous materials into the environment, and this i mpact would be less than significant. (Revised Draft EIR, pp. 4.7-16 -- 4.7-17.)

3. Waste Sites
Threshold: Would the Project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
Finding: No impact. (Revised Draft EIR, p. 4.7-20.)
Explanation: Government Code Section 65962.5 requires CalEPA to maintain an updated Hazardous Waste and Substance s Sites List, also known as the Cortese List. DTSC is responsible for a portion of the information contained in the Cortese List; other state and local government agencies are also required to provide additional hazardous material release information for t he Cortese List. Based on review of these databases, there are no hazardous material sites mapped within the project site. As such, the proposed project would not create a significant hazard to the public or the environment due 75 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
42 | P a g e

to listed hazardous material s sites. Therefore, no impact would occur. (Revised Draft EIR, p. 4.7-20.)

4. Hazards Near Schools
Threshold: Would the Project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one - quarter mile of an existing or proposed school?
Finding: Less than significant. (Revised Draft EIR, pp. 4.7-19 – 4.7-20.) Explanation: Operation. Residential land use is not typically associated with the use, transportation, storage, or generation of substantial quantities of hazardous materials. Project operation would result in an incremental increase in the use of household hazardous materials, such as cleaning products. In addition, landscaping would include the use of fertilizers and pesticides onsite. Pesticide use would occur in accordance with existing hazardous materials regulations established by USEPA, the State of California, the County of Santa Barbara, and the City of Goleta. These regulations prescribe measures for the safe transport, use, storage, and disposal of hazardous materials to reduce the risk of spills. With adherence to existing regulatory requirements, proposed project ope ration would not pose a significant hazard to existing or proposed schools within

0.25-mile of the project site due to the handling of hazardous or acutely hazardous materials, substances, or waste. As such, operational impact would be less than significan t. (Revised Draft EIR, pp. 4.7-19 -- 4.7-20.)

5. Public Airports
Threshold: For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project res ult in a safety hazard for people residing or working in the project area?
Finding: No impact. (Revised Draft EIR, p. 4.7-21.)
Explanation: The project site is not located within the vicinity of a private airstrip.

The airport nearest to the project site, the Santa Barbara Airport, is located approximately 1.8 miles southeast of the project site. The project site is located outside of the safety and noise contours established within the Santa Barbara Airport Land Use Plan (Santa Barbara County Association of Governments 2023). Accordingly, the proposed project would not result in a safety hazard or excessive 76 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
43 | P a g e

noise related to airport operations for people residing or working in the project area. No impact would occur. (Revised Draft EIR, p. 4.7-

21.)

6. Emergency Plans
Threshold: Would the Project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Finding: Less than significant. (Revised Draft EIR, pp. 4.7-21 – 4.7-22.) Explanation: The City of Goleta, in cooperation with Federal Emergency Management Agency, the County of Santa Barbara, and State Offices of Emergency Services, is responsible for emergency preparedness and response. Components of emergency
preparedness and response include identification of evacuation routes and secondary emergency accesses, as well as provision of information to the community regarding appropriate individual actions in the event of various types of emergencies. The Santa Barbara County Multi-Jurisdictional Hazard Mitigation Plan identifies Cathedral Oaks Road as an evacuation route (County of Santa Barbara 2023). Construction staging and parking would occur on the project site and therefore would not impair implementation of the Santa Barbara County Multi -Jurisdictional Hazard Mitigation Plan.

The proposed utility installation underlying Cathedral Oaks Road would require encroachment into the right -of-way and temporary lane closures on Cathedral Oaks Road during this phase of construction.

However, in accor dance with Chapter 12.02 of the City’s Municipal Code, the project applicant would be required to maintain at least one safe crossing for vehicles and must implement measures to minimize disruption to existing traffic conditions. For the proposed project, implementation would involve preparation and City approval of a Traffic Control Plan that ensures at least one travel lane remains open at all times, with flaggers or temporary signals used to alternate traffic flow as needed. The Traffic Control Plan woul d also include advance signage, detour routes, and work-hour restrictions to reduce peak-hour congestion. Coordination with emergency service providers would be required to ensure continuous access for fire, police, and medical responders. The City’s stand ard requirement to maintain at least one open lane and coordinate with emergency responders ensures that fire trucks, ambulances, and law enforcement vehicles could still travel along Cathedral Oaks Road 77 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
44 | P a g e

during project construction. In addition, the projec t applicant’s construction contractor would be required to implement a Construction Traffic Management Plan during construction within Cathedral Oaks Road.

The Construction Traffic Management Plan would require
implementation of traffic control measures a nd minimization of disruptions to access points at the project site for emergency service vehicles during construction on Cathedral Oaks Road, which would be reviewed for potential safety concerns and approved by the Santa Barbara County Fire Department. Examples of measures that would be implemented include scheduling lane closures during off -peak hours and coordinating with emergency service providers to maintain access; stationing trained flaggers at both ends of the construction zone to direct traffic a nd prioritize emergency vehicles; including a 24-hour emergency contact list and protocols for immediate coordination with emergency responders; and using high -visibility signage and advance public notifications to alert drivers and emergency services to construction activities.

With implementation of the Construction Traffic Management Plan, proposed construction within Cathedral Oaks Road would not result in interference with emergency response or evacuation. Proposed project operations would not involve closures on Cathedral Oaks Road nor introduce activities that could impede or interfere with the Santa Barbara County Multi-Jurisdictional Hazard Mitigation Plan or emergency evacuations on Cathedral Oaks Road. Furthermore, the proposed project would not generate substantial additional vehicles utilizing Cathedral Oaks Road and therefore would not result in substantial interference with emergency evacuation procedures on Cathedral Oaks Road. Therefore, proposed project operation would not result in impaired implementation or physical interference with an adopted emergency response plan or emergency evacuation plan, and impacts would be less than significant . (Revised Draft EIR, pp.4.7-21 – 4.7-22.)

7. Wildland Fires
Threshold: Would the Project expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands?
Finding: Less than significant. (Revised Draft EIR, pp. 4.7-22 – 4.7-24.) 78 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
45 | P a g e

Explanation: CAL FIRE designated the project site in the Local Responsibility Area primarily as a Very High Fire Hazard Severity Zone, with the southeastern portion of the project site designated as a High Fire Hazard Severity Zone (CAL FIRE 2025; Appendix G). The project site (along with most of the city of Goleta) is also subject to strong downslope winds, including Sundowner winds, which are known to intensify and rapidly spread wildfires. Additionally, the project site lies within the wil dland-urban interface, where development meets natural vegetation, increasing the risk of structure ignition.

During construction, there would be a temporary increase in human activity and potential ignition sources, including equipment that could create sparks, be a source of heat, or leak flammable materials on the project site. Ignition sources include internal combustion engines, welding or cutting tools, generators, and fuel storage areas. In a Very High Fire Hazard Severity Zone, such activities elevate the risk of wildfire ignition, particularly during hot, dry, and windy conditions. If not properly managed, a small spark or fuel spill could ignite surrounding vegetation, leading to rapid fire spread due to the project site’s flammable vegetation, sloped terrain, and exposure to Sundowner winds. This risk is compounded by the proximity of the project site to the wildland-urban interface, where fire could threaten nearby structures and infrastructure.

In accordance with PRC Section 4442, equipment including earth - moving and portable construction equipment with internal combustion engines would be equipped with spark arrestors to prevent the emission of flammable debris from exhaust, when operating on any forest -covered, brush -covered, or grass -covered land. In addition, PRC Sections 4427 and 4431 specify standards for conducting construction activities on days when a burning permit is required, and PRC Section 4428 requires construction contractors to maintain fire suppression equipment during the highest fire danger period (April 1 to December 1) when operating on or near any forest- covered, brush -covered, or g rasscovered land. In addition, compliance with CFC Section 3312 would require use of a water supply system for fire protection prior to combustible materials arriving at the project site. These measures are designed to prevent accidental ignition and facilitate rapid response in the event of a fire.

Adherence to these regulatory requirements would minimize the risk of potential wildland fire during construction.

Proposed project design would be subject to the following fire safety standards:
79 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
46 | P a g e

 The CFC, whic h include safety measures to minimize the threat of fire, including ignition -resistant construction with exterior walls of noncombustible or ignition resistant material from the surface of the ground to the roof system and sealing any gaps around doors, windows, eaves and vents to prevent intrusion by flame or embers, automatic interior and exterior fire sprinklers, a robust water delivery system, fire apparatus access, and defensible space.
 Chapter 9, Fire Protection Systems, of the California Building Code, which addresses fire suppression and detection
systems and is applicable to all development.
 Chapter 7A, Materials and Construction Methods for Exterior Wildfire Exposure, of the California Building Code, which governs materials and construction metho ds for exterior wildfire exposure and is applicable to structures within Very High Fire Hazard Severity Zones.
 CCR Title 14, which sets forth the minimum development standards for emergency access, fuel modification, setback, signage, and water supply, wh ich help prevent loss of
structures or life by reducing wildfire hazards. CCR Title 14 is applicable to development in State Responsibility Areas and Very High Fire Hazard Severity Zones.

Undergrounding of the proposed utility lines on -site would minimize the risk of fire from utilities. Furthermore, project operation would not introduce new activities that could substantially increase the risk of wildfires, as operation of the proposed project involves residential uses which do not pose a substantial fire risk.

Residences would be designed in accordance with California Building Code standards for roof coverings, vents, residential sprinklers, ignition -resistant construction materials, decking, and exterior windows, skylights, and doors which would minimize fire risk.

Landscaping onsite would include fire -resistant plants strategically placed to resist spread of fire to nearby homes and hardscaping on- site would use limited combustible materials, including non - combustible fencing, in or near structures. These design features are consistent with the requirements of Chapter 7A of the California Building Code and CCR Title 14, which are specifically intended to reduce wildfire ignition and structure loss in VHFHSZs. For example, ignition-resistant construction materials and ember -resistant vents reduce the likelihood of structure ignition from wind -driven embers, 80 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
47 | P a g e

which are a primary cause of home loss in wildfires. Residential sprinkler systems provide immediate suppression capability in the event of ember intru sion or radiant heat exposure. Fire -resistant landscaping and non -combustible fencing reduce the potential for fire to spread from vegetation to structures. By incorporating these features into the proposed project’s design, the risk of wildfire ignition and structure loss is substantially reduced even under VHFHSZ conditions.

Construction activities may require temporary lane closures on Cathedral Oaks Road to complete frontage improvements and utility work, resulting in temporary disruptions to vehicular and multimodal circulation in the area. However, the project applicant would be required to maintain at least one safe crossing for vehicles and must implement measures to minimize disruption to existing traffic conditions. To ensure compliance with the City’s Municipal Code, as a Condition of Approval, the project applicant’s construction contractor would be required to prepare and implement a Construction Traffic Management Plan, which must specify transportation measures to be implemented during constru ction on Cathedral Oaks Road to ensure disruptions to circulation and minimized, including in the event of emergency evacuation.

Examples of transportation measures that would be implemented include scheduling lane closures during off -peak hours and coordinating with emergency service providers to maintain access; stationing trained flaggers at both ends of the construction zone to direct traffic and prioritize emergency vehicles; including a 24 -hour emergency contact list and protocols for immediate coordination with emergency responders; and using high -visibility signage and advance public notifications to alert drivers and emergency services to construction activities. With implementation of these transportation measures, the proposed project would mainta in adequate emergency access in accordance with City standards. As discussed in detail in Section 4.14, Wildfire, the proposed project would not generate substantial additional vehicles utilizing Cathedral Oaks Road and therefore would not result in substa ntial interference with emergency evacuation procedures on Cathedral Oaks Road. With adherence to regulatory requirements, the proposed project’s potential to expose people or structures to significant risk of loss, injury, or death involving wildland fires would be less than significant. (Revised Draft EIR, pp. 4.7-22 – 4.7-24.)
J. HYDROLOGY AND WATER QUALITY

1. Water Quality Standards
81 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
48 | P a g e

Threshold: Would the Project violate any water quality standards or waste discharge requirements?
Finding: Less than significant. (Revised Draft EIR, pp. 4.8-12 – 4.8-13.) Explanation: Operation. For post-construction impacts, the primary source of pollutants would be oil, grease, and other materials deposited on the paved surfaces of internal roads, driveways, and parking areas from vehicles traveling to and from the project site. In addition, runoff from landscaped areas may contain pesticides, herbicides, fertilizers, and other chemical compounds. Pet waste could also be introduced into stormwater which could add E . coli and nitrates to stormwater. If unaddressed, pollutants from residential users could be discharged into receiving waters. The Stormwater Control Plan prepared for the proposed project serves as the required SWQMP and specifies the Source Control and LID BMPs proposed for the project. Source Control BMPs are preventative measures that are implemented to reduce the introduction of pollutants into stormwater. Proposed permanent Source Control BMPs include design of landscaping to minimize irrigation and runoff, implementation of trash storage areas, regular sweeping of the parking lot and access roads, and regular drainage facility inspection and maintenance. LID BMPs mimic a project site’s natural hydrology by using design measures that capture, filter, store, evaporate, detain, treat, and discharge runoff rather than allowing runoff to flow directly the discharge point.

Proposed LID BMPs include the installation of a detention basin located in the western portion of the project site and an underground detention system located at the southern portion of the project site adjacent to Cathedral Oaks Road.

Additional LID BMPs include the use of above-ground rain barrels at each residence, and implementation of a bioswale and vegetated swale located in the ope n space area along Cathedral Oaks Road.

Stormwater infrastructure would include media filters and biofiltration to filter pollutants out of stormwater prior to discharge to either El Encanto Creek or to storm drain outlets within Cathedral Oaks Road.

This stormwater infrastructure would minimize the amount of sediments and wastes discharged in stormwater during operation, thereby minimizing the potential to contribute to the turbidity, E. Coli, dissolved oxygen, nitrate, and imbalanced pH impairments of El Encanto Creek. The proposed project would increase the total impervious surfaces on -site by approximately 5.59 acres, which would exceed a 25 percent increase in impervious surfaces and could increase on -site stormwater runoff rates and subsequent pollutant discharge. The proposed project would include a detention 82 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
49 | P a g e

basin located in the western portion of the project site and an underground detention system located at the southern portion of the project site.

The proposed detention basin and underground dete ntion system have been sized to capture, detain, and release stormwater at a controlled rate to ensure the post-project peak runoff outflows would be the same as the pre -project peak runoff outflows for a 100 -year flood event. Detention systems reduce poll utants in stormwater by detaining stormwater runoff, allowing pollutants to settle out through sedimentation, and removing them through filtration as the water slowly passes through and drains out of the system, to ensure that pollutant discharge into El Encanto Creek and the City’s storm drain system would not be increased as a result of the proposed project.

With implementation of design measures, and compliance with federal, state, and local regulatory requirements as described above, potential impacts for the release of pollutants into El Encanto Creek would be minimized. Runoff generated by the proposed project would be adequately treated and long -term impacts related to surface water and groundwater quality would be less than significant with compliance with state and local regulations. (Revised Draft EIR, pp. 4.8-12 – 4.8-13.)

2. Groundwater Supplies
Threshold: Would the Project substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin?
Finding: Less than significant. (Revised Draft EIR, 4.8-14.) Explanation: Subsurface investigations were conducted for soils up to 51 feet in depth at the project site. Subsurface investigations did not reveal any static or perched groundwater underlying the project site.

Accordingly, encountering groundwater during excavation or other ground disturbing activities during construction is not anticipated, and construction would not substantially decrease groundwater supplies. The project site does not currently contain impervious surfaces aside from the existing on -site structures. The proposed project would increase the total impervious surfaces on -site by approximately 5.59 acres, which would exceed a 25 percent increase in impervious surfaces. However, on -site soils are classified as Group D, which have high runoff potential. Due to the high runoff potential of on -site soils, there is a low potential for groundwater 83 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
50 | P a g e

infiltration on the project site under existing conditions. Given the limited infiltration potential of on -site soils (under both existing and post-project conditions), the proposed project would not substantially decrease groundwater infiltration rates on-site or result in substantial interference to groundwater recharge.

Operation of the proposed project would not require groundwater extraction on the project site. Ho wever, water demand for the proposed project would be met by GWD which sources its water, in part, from the Goleta Groundwater Basin. GWD is subject to the adjudication requirements of the Wright Judgement, which established extraction, storage requirements, and allowable uses of groundwater to achieve and maintain hydrologic balance (which was achieved in 1998), and the proposed project would not interfere with the management of the Basin in accordance with the Wright Judgement due to its water demands bec ause GWD is only permitted to extract water in accordance with the allocations determined by the Wright Judgement. The basin is not designated as critically overdraft and is required to be managed to maintain hydrologic balance.

GWD has anticipated adequate water supplies available to meet its projected demands through the year 2040 (GWD 2021). The proposed project would be required to undergo GWD review prior to issuance of a Can and Will Serve Letter, stating that GWD has sufficient water available to su pport the proposed project. Finally, existing regulatory measures requiring water conservation during times of drought prevent the overdraft of the Basin that GWD would use to supply water demand of the proposed project. Therefore, the proposed project would not substantially decrease water supplies or conflict with or obstruct a sustainable groundwater management plan. This impact would be less than significant. (Revised Draft EIR,

4.8-14.)

3. Runoff
Threshold: Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems o r provide substantially additional sources of polluted runoff or impede or redirect flood flows? Finding: Less than significant. (Revised Draft EIR, pp. 4.8-17 – 4.8-18.) 84 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
51 | P a g e

Explanation: Runoff.

Operation. The proposed project would increase impervious surface area on the site, which could increase on-site stormwater runoff rates and subsequent pollutant discharge. The project would include the installation of a detention basin located in the western portion of the project site and an underground detention system located at the southern portion of the project site adjacent to Cathedral Oaks Road.

These facilities would ensure existing runoff discharge rates would not increase compared to existing conditions for t he 100-year flood event) by capturing stormwater runoff and releasing it at a controlled rate. Because stormwater runoff from the project site would not be increased compared to existing conditions, the proposed project would not result in an exceedance of the capacity of existing or planned stormwater drainage systems. Furthermore, proposed stormwater infrastructure would treat stormwater to reduce pollutants prior to discharge, ensuring operation of the proposed project would not provide substantial addit ional sources of polluted runoff.

Therefore, project operation would not create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff. This impact would be less than significant. (Revised Draft EIR, pp. 4.8-17 – 4.8-18.)
Flood Flows.

The project site is not located within a flood hazard zone. Rather, the project site is located within Zone X, defined as an area of minimal flood hazard. While the proposed project would alter on-site drainage patterns, proposed development would not impede or redirect flood flows on-site because the project site is not located within a flood hazard zone. Furthermore, because the proposed detention systems would discharge stormwater flows from the site at a controlled rate such that stormwater flow rates would not increase compared existing conditions, the proposed project would not alter off -site flooding or drainage. No impact would occur. (Revised Draft EIR, p.

4.8-18.)

4. Erosion or Siltation
Threshold: Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off-site?
85 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
52 | P a g e

Finding: Less than significant. (Revised Draft EIR, p. 4.8-15.) Explanation: Construction. Construction activities would increase the potential for erosion and sedimentation. However, such activities would be required to comply with the Construction Stormwater General Permit, the City Municipal Code, as well as implementation of the required SWPPP and construction BMPs would minimize sediment discharge in stormwater runoff. With implementation of the SWPPP and construction BMPs(including erosion control and sediment control BMPs), visual inspections, and water quality (turbidity) monitoring required in compliance with the Construction General Permit, construction phase erosion and siltation would be minimized and would not substantially alter the existing drainage pattern of the site or area in a manner which would result in a substantial erosion or siltation on - or off -site. Construction impacts would be less than significant.

Operation. The project site does not curre ntly contain impervious surfaces aside from the three existing on -site structures. The proposed project would increase the total impervious surfaces on - site by approximately 5.59 acres, which would exceed a 25 percent increase in impervious surfaces. The i ncrease in impervious area would increase stormwater runoff compared to existing conditions.

The remainder of the project site would consist of landscaping, which would include installation of native, drought -tolerant plants. The drought-tolerant native plants would require less water compared to existing conditions. In addition, the proposed project’s landscaping irrigation equipment would be controlled by an automatic timer with a seasonal adjustment to apply less water during the rainy season, which would minimize the potential for soil erosion to occur due to overwatering. The proposed project would include a detention basin located in the western portion of the project site and an underground detention system located at the southern portion of the proje ct site.

The proposed detention basin and underground detention system have been sized to ensure the postproject peak runoff outflows would be the same as the pre -project peak runoff outflows for a 100 - year flood event.

Accordingly, stormwater discharge rates with implementation of the detention systems would be the same as existing conditions, which would therefore not increase erosion off -site (downstream). The impervious surfaces introduced as part of the proposed project would not be subject to erosion. In addition, on-site landscaped areas would help maintain soil structure and minimize the potential for on -site erosion to occur. Therefore, project operation would not substantially 86 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
53 | P a g e

increase the rate or amount of surface runoff in a manner that would result in substantial erosion or siltation on -or off -site. Operational impacts would be less than significant. ( Revised Draft EIR, p. 4.8 -

15.)

5. Flooding
Threshold: Would the Project substantially alter the existing drainage pattern of the site or area, i ncluding through the alteration of the course of a stream or river, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site?
Finding: Less than significant. (Revised Draft EIR, p. 4.8-15.) Explanation: Construction. Construction activities would increase the potential for erosion and sedimentation. However, such activities would be required to comply with the Construction Stormwater General Permit, the City Municipal Code, as well as implementation of the required SWPPP and construction BMPs would minimize sediment discharge in stormwater runoff. With implementation of the SWPPP and construction BMPs (including erosion control and sediment control BMPs), visual inspect ions, and water quality (turbidity) monitoring required in compliance with the Construction General Permit, construction phase erosion and siltation would be minimized and would not substantially alter the existing drainage pattern of the site or area in a manner which would result in a substantial erosion or siltation on - or off -site. Construction impacts would be less than significant.

Operation. The project site does not currently contain impervious surfaces aside from the three existing on -site structures. The proposed project would increase the total impervious surfaces on - site by approximately 5.59 acres, which would exceed a 25 percent increase in impervious surfaces. The increase in impervious area would increase stormwater runoff compared to existing conditions.

The remainder of the project site would consist of landscaping, which would include installation of native, drought -tolerant plants. The drought-tolerant native plants would require less water compared to existing conditions. In addition, the proposed project’s landscaping irrigation equipment would be controlled by an automatic timer with a seasonal adjustment to apply less water duri ng the rainy season, which would minimize the potential for soil erosion to occur due to overwatering. The proposed project would include a detention basin located in the western portion of the project site and an underground 87 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
54 | P a g e

detention system located at th e southern portion of the project site.

The proposed detention basin and underground detention system have been sized to ensure the postproject peak runoff outflows would be the same as the pre -project peak runoff outflows for a 100 - year flood event. Acco rdingly, stormwater discharge rates with implementation of the detention systems would be the same as existing conditions, which would therefore not increase erosion off - site (downstream). The impervious surfaces introduced as part of the proposed project would not be subject to erosion. In addition, on-site landscaped areas would help maintain soil structure and minimize the potential for on-site erosion to occur. Therefore, project operation would not substantially increase the rate or amount of surface runoff in a manner that would result in substantial erosion or siltation on-or off-site. Operational impacts would be less than significant. (Revised Draft EIR, p. 4.8-15.)

6. Flood Hazard
Threshold: In flood hazard, tsunami, or seiche zones, would the Pr oject risk release of pollutants due to project inundation?
Finding: No impact. (Revised Draft EIR, pp. 4.8-18 – 4.8-19.) Explanation: The project site is located outside of a flood hazard zone. There are no levees or dams upstream of the project site that would inundate the proposed project in the event of a dam or levee failure. Due to the absence of a large body of water, such as a reservoir, in proximity to the project site, the project site is not subject to inundation from seiche. The entirety of the project site lies outside of a tsunami inundation zone. Therefore, the proposed project would not risk the release of pollutants from proj ect structures due to inundation. No impact would occur. (Revised Draft EIR, pp. 4.8-18 – 4.8-19.)

7. Water Quality Control Plan
Threshold: Would the Project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? Finding: Less than significant. (Revised Draft EIR, p. 4.8-19.) Explanation: Operation. Project operation would include use of a detention basin, underground detention system, bioswale, vegetated swale, and media filters. These stormwater infrastructure features would capture and treat stormwater runoff by filtering pollutants out of stormwat er prior to discharge, thereby minimizing the potential to result in 88 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
55 | P a g e

pollutants in excess of water quality objective quantities identified in the Basin Plan. Therefore, impacts during operation would be less than significant. (Revised Draft EIR, p. 4.8-19.)
K. LAND USE AND PLANNING

1. Established Communities
Threshold: Would the Project physically divide an established community? Finding: Less than significant. (FEIR, p. 4.9-6.)
Explanation: The project site is situated at the northern edge of Goleta. The project site is primarily bordered by recreational and natural lands, with the Glen Annie Golf Course to the north and east and El Encanto Creek to the west. Residential land uses are located across El Encanto Creek and Northgate Road on the west and across Cathedral Oaks Road to the South. No residential or other urban uses are located directly adjacent to the project site. The proposed project includes subdivision of the project site for dev elopment of single -family residences and adjoining open space areas. The project provides two new access points on Cathedral Oaks Road; internal streets that connect to existing bicycle and pedestrian facilities; and internal sidewalks and pedestrian conne ctions to the Class I multi -use path for bicycle and pedestrian use. These features would allow for integration with the surrounding circulation network.

The project also includes frontage improvements along Cathedral Oaks Road between Northgate Drive to the west and the Glen Annie Golf Course property to the east. These frontage improvements include two driveway entrances to the project site, and curb and gutter installation. The proposed project would improve connectivity within the local vicinity by expanding access through and around the project site, and serve to extend a similar type of development to the existing residential development in the area. The project does not include any new components that could divide an established community. Development of the project site would not result in the physical division of an established community, and impacts would be less than significant. (FEIR, p. 4.9-6.)
L. MINERAL RESOURCES

1. Regional and Statewide Mineral Resources
89 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
56 | P a g e

Threshold: Would the Project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
Finding: No impact. (Revised Draft EIR, p. 4-6.)
Explanation: The California Geological Survey’s Updated Mineral Land Classification Map for Concrete Grade Aggregates in the San Luis Obispo-Santa Barbara Production-Consumption Region, California – South Half indicates the project site is within Mineral Resources Zones 1 (MRZ) and MRZ -3 (California Geological Survey 2011).

MRZ-1 designati ons indicate areas containing little or no mineral deposits and MRZ -3 designations indicate deposits identified but require further evaluation. Accordingly, there are no known mineral resources of regional or statewide value identified on the project site.

Furthermore, in accordance with Section 17.37.050 of the City’s Municipal Code, surface mining is prohibited within Goleta; therefore, the development of the proposed project would not result in any loss of mineral resources as under existing conditions mineral resources could not be extracted within Goleta. Therefore, no impact related to the loss of availability of a known mineral resource that would be of value to the region and the residents of the state would occur. (Revised Draft EIR, p. 4-6.)

2. Locally-Important Mineral Resource
Threshold: Would the Project result in the loss of availability of a local ly- important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan?
Finding: No impact. (Revised Draft EIR, p. 4-6.)
Explanation: The project site does not contain any existing mineral extraction activities, and no such activities are planned within the City of Goleta.

The project site is not delineated on the City’s General Plan/Coastal Land Use Plan, specific plan, or any other land use plan as a mineral resource recovery site. The nearest known extractive industry is the historic Ellwood Oil Field which is located approximately 2.3 miles southwest of the project site, which ceased operations in 201 7 (California State Lands Commission 2025). Therefore, the proposed project would not result in the loss of availability of a locally important mineral recovery site delineated on a local general plan, specific plan, or other land use plan. No impact would occur. (Revised Draft EIR, p. 4-6.)
90 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
57 | P a g e

M. NOISE

1. Noise Standards
Threshold: Would the Project result in the generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Finding: Less than significant. (Revised Draft EIR, pp. 4.10-8 – 4.10-9.) Explanation: Operation
Stationary Noise
The primary stationary noise source associated with operation of the proposed project would be HVAC units at the proposed residences.

A typical HVAC unit generates a noise level of 68 dBA at 3.28 feet (Carrier 2007). This noise level would attenuate to 38 dBA at a distance of 100 feet, which is the distance to the nearest residences, with no obstructions or barriers to the noise. The noise levels would be well below the City’s 65 dBA CNEL standard, and would be reduced further with the proposed perimeter wa lls. Therefore, operational noise impacts from the proposed project’s stationary noise sources would be less than significant.

Traffic Noise
The proposed project would generate a total of 477 average daily vehicle trips (ADT) that would be added to the existing traffic volumes on the local roadway system. At each turning opportunity, the proposed project contribution to the total traffic volume would be progressively diluted, along with the potential to contribute to noise levels. Future ADT along Cathedral Oaks Road in the vicinity of the proposed project would be 8,900 ADT . Quiet suburban areas typically have noise levels in the range of 40 to 50 dBA, while those along arterial streets are in the 50 to 60+ dBA range. Near the project site, both noise sources are present due to the residential nature of the area and Cathedral Oaks Road operating as a two -lane arterial.

In general, a 3 dB change in community noise levels is noticeable, while 1 -2 dB changes generally are not perceived. The proposed project wo uld increase traffic noise levels by 0.2 dBA CNEL, well below a 3 dB increase in noise levels. As such, project-related traffic noise impacts on adjacent sensitive receivers are not expected to be detectable. Therefore, this impact would be less than signi ficant. 91 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
58 | P a g e

(Revised Draft EIR, pp. 4.10-8 -- 4.10-9.)

2. Vibration
Threshold: Would the Project result in the exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels? Finding: Less than significant. (Revised Draft EIR, p. 4.10-11.) Explanation: Construction. Construction activities that would occur at the project site have the potential to generate low levels of groundborne vibration. Vibration levels could reach approximately78 VdB at 50 feet. This would not exceed the FTA’s threshold of 83 VdB for buildings with primarily daytime uses. The nearest residence is located approximately 65 feet away; therefore, vibration levels at the nearest residence would not exceed the FTA’s threshold. In addition, it is anti cipated that construction of the proposed project would not involve the use of ramming or drilling equipment, which tend to result in higher vibration levels. As construction progresses north into the project site, potential vibration affecting adjacent re sidences would be further reduced. Therefore, vibration levels as a result of construction would be below the level needed to perceive vibration for most people. The potential vibration impacts as a result of construction would be less than significant.

Operation. Operational activities known to generate excessive groundborne vibration include projects involving railroads and subways. The proposed project would not involve substantial vibration sources associated with operation such as this because operation of residences does not include these uses. Therefore, the proposed project’s operational groundborne vibration and noise impacts would be less than significant . (Revised Draft EIR, p. 4.10-

11.)

3. Airport Noise
Threshold: For a project located w ithin the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
Finding: No impact. (Revised Draft EIR, p. 4.10-11.)
92 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
59 | P a g e

Explanation: The airport nearest to the project site, the Santa Barbara Airport, is located approximately 1.8 miles southeast of the project site. The project site is located outside of noise contours for the Santa Barbara Airport. The project site is also not located within the vicinity of a private airstrip. Therefore, the project would not expose people residing or working in the project area to excessive noise levels. No impact would occur. (Revised Draft EIR, p. 4.10-11.)
N. POPULATION AND HOUSING

1. Population Growth
Threshold: Would the Project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of road or other infrastructure?
Finding: Less than significant. (Revised Draft EIR, p. 4-7.) Explanation: The proposed project would result in the development of new residential units, which would directly contribute to population growth in Goleta. According to the California Department of Finance (2025), the current population of Goleta is approximately 32,747 people.

Based on the City’s average household size of 2.59 persons per household (California Department of Finance 2025), the proposed project would result in an estimated population increase of 145 people, bringing the total to approximately 32,892 residents. This increase is within the growth projections developed by the Santa Barbara County Association o f Governments, which estimate that Goleta’s population will reach 34,700 by 2050 (Santa Barbara County Association of Governments 2019). Therefore, the proposed project’s impact related to substantial unplanned population growth would be less than significant. (Revised Draft EIR, p. 4-7.)

2. Displacement of Housing
Threshold: Would the Project displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere; and displace substantial numbers of people, nece ssitating the construction of replacement housing elsewhere?
Finding: Less than significant. (Revised Draft EIR, p. 4-7.) Explanation: The project site currently contains a vacant single -family residence and two vacant accessory structures. The proposed project would 93 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
60 | P a g e

not displace people because the on -site residence is vacant. The project would also not necessitate the construction of replacement housing elsewhere. While the project would require demolition of one on-site residence, the project would inc rease housing in the City by developing 56 residences. Therefore, the proposed project’s impact related to the displacement of substantial people or housing would be less than significant. (Revised Draft EIR, p. 4-7.)
O. PUBLIC SERVICES

1. Fire Protection
Threshold: Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cau se significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection?
Finding: Less than significant. (Revised Draft EIR, p. 4-8.) Explanation: The proposed project would introduce approximately 145 new residents to the City of Goleta. This additional population could place some pressure on existing public facilities and services, potentially affecting service ratios and response times. However, public safety services, incl uding fire and police protection, would be supported through the payment of development impact fees required for new residential subdivisions. These fees help fund capital improvements and ensure that new development contributes its fair share toward maintaining acceptable service ratios and response times (City of Goleta 2025a). The City’s General Plan/Coastal Land Use Plan includes policies (PF 3 Public Safety Services and Facilities, PF 3.2 New Fire Station in Western Goleta, PF 3.3 Impact Fees for Fire Protection Facilities/Equipment, and PF 3.8 Impact Fee for Police Facilities) to accommodate projected growth in public safety services, including the planned addition of a new fire station within Goleta. As population increases, so does the demand for fir e and police protection services, which may require additional facilities to maintain adequate service levels. The proposed project itself does not necessitate construction of Fire Station 10; rather, the planned Fire Station 10, which has already undergone environmental review, would address existing service levels for fire protection facilities in Goleta and would help the SBCFD achieve adequate service in Goleta. The proposed project would contribute incrementally to 94 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
61 | P a g e

population growth, but given the rela tively small increase in population and the availability of existing services supplemented by impact fees, the proposed project itself would not necessitate new or physically altered fire or police facilities. Therefore, the proposed project’s impact relat ed to new or physically altered fire or police facilities would be less than significant. (Revised Draft EIR, p. 4-8.)

2. Police Protection
Threshold: Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other perf ormance objectives for Sheriff Law Enforcement Services?
Finding: Less than significant. (Revised Draft EIR, p. 4-8.) Explanation: The proposed project would introduce approximately 145 new residents to the City of Goleta. This additional population could place some pressure on existing public facilities and services, potentially affecting service ratios and response times. However, public safety services, including fire and police protection, would b e supported through the payment of development impact fees required for new residential subdivisions. These fees help fund capital improvements and ensure that new development contributes its fair share toward maintaining acceptable service ratios and resp onse times (City of Goleta 2025a). The City’s General Plan/Coastal Land Use Plan includes policies (PF 3 Public Safety Services and Facilities, PF 3.2 New Fire Station in Western Goleta, PF 3.3 Impact Fees for Fire Protection Facilities/Equipment, and PF 3 .8 Impact Fee for Police Facilities) to accommodate projected growth in public safety services, including the planned addition of a new fire station within Goleta.

As population increases, so does the demand for fire and police protection services, which may require additional facilities to maintain adequate service levels. The proposed project itself does not necessitate construction of Fire Station 10; rather, the planned Fire Station 10, which has already undergone environmental review, would address ex isting service levels for fire protection facilities in Goleta and would help the SBCFD achieve adequate service in Goleta. The proposed project would contribute incrementally to population growth, but given the relatively small increase in 95 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
62 | P a g e

population and the availability of existing services supplemented by impact fees, the proposed project itself would not necessitate new or physically altered fire or police facilities. Therefore, the proposed project’s impact related to new or physically altered fire or police facilities would be less than significant. (Revised Draft EIR, p. 4-8.)

3. Schools
Threshold: Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the co nstruction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for schools?
Finding: Less than significant. (Revised Draft EIR, pp. 4-8 – 4.9.) Explanation: The proposed project would include 56 residential units. Using a student generation factor of 0.2 students per residential unit per school district, consistent with the student generation factor utilized in the City of Goleta General Plan/Coastal Land Us e Plan Final EIR (City of Goleta 2006), the proposed project could generate approximately 11 students. Local public schools in Goleta are within the Goleta Union School District and Santa Barbara Unified School District. Goleta Union School District has an enrollment of approximately 1,613 students and a capacity of approximately 2,178 students, while Santa Barbara Unified School District has an enrollment of approximately 2,772 students and a capacity of approximately 3,861 students (City of Goleta 2024). The proposed project’s addition of approximately 11 students would not exceed the capacities of these school districts. As the school district is not approaching or currently exceeding its student capacity, the proposed project’s impact related to new or e xpanded school facilities would be less than significant. (Revised Draft EIR, pp. 4-8 –

4.9.)

4. Parks
Threshold: Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental faci lities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for parks?
96 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
63 | P a g e

Finding: Less than significant. (Revised Draft EIR, pp. 4-9 – 4.10.) Explanation: Goleta operates 31 parks and recreational facilities totaling approximately 550 acres (City of Goleta 2025b). Goleta has established a goal of maintaining 10 acres of parkland per 1,000 residents, and currently exceeds that goal with a rat io is 16.8 acres per 1,000 residents (City of Goleta 2025b). The proposed project would add approximately 145 new residents to the City of Goleta, which would incrementally increase demand for neighborhood and regional parks and slightly reduce the City’s parkland ratio to 16.7 acres per 1,000 residents. 4 This represents a minimal change and would not cause substantial physical deterioration of existing facilities. In addition, the project includes on -site open space amenities, such as a community picnic a rea and landscaped lots, which would provide passive recreation opportunities for residents and reduce reliance on off-site facilities. The project applicant would also be required to pay Quimby Act parkland dedication or in -lieu fees, which fund the devel opment and maintenance of parks and recreational facilities. Accordingly, the proposed project’s impact related to the substantial physical deterioration of parks and recreational facilities would be less than significant. (Revised Draft EIR, pp. 4-9 – 4.10.)

5. Other Public Facilities
Threshold: Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for other public facilities?
Finding: Less than significant. (Revised Draft EIR, p. 4-10.) Explanation: The proposed project would introduce approximately 145 new residents to the City of Goleta. This additional population could place some pressure on existing public facilities and services, potentially affecting service ratios and response times. However, public safety services, including fire and police protection, would b e supported through the payment of development impact fees required for new residential subdivisions. These fees help fund capital improvements and ensure that new development contributes its fair share toward maintaining acceptable service ratios and resp onse times (City of Goleta 2025a). The City’s General Plan/Coastal Land Use Plan includes policies (PF 3 Public Safety Services and Facilities, PF 3.2 97 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
64 | P a g e

New Fire Station in Western Goleta, PF 3.3 Impact Fees for Fire Protection Facilities/Equipment, and PF 3 .8 Impact Fee for Police Facilities) to accommodate projected growth in public safety services, including the planned addition of a new fire station within Goleta. As population increases, so does the demand for fire and police protection services, which m ay require additional facilities to maintain adequate service levels. The proposed project itself does not necessitate construction of Fire Station 10; rather, the planned Fire Station 10, which has already undergone environmental review, would address exi sting service levels for fire protection facilities in Goleta and would help the SBCFD achieve adequate service in Goleta. The proposed project would contribute incrementally to population growth, but given the relatively small increase in population and the availability of existing services supplemented by impact fees, the proposed project itself would not necessitate new or physically altered fire or police facilities. Therefore, the proposed project’s impact related to new or physically altered fire or p olice facilities would be less than significant. (Revised Draft EIR, p. 4-10.) P. RECREATION

1. Increased Use
Threshold: Would the Project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? Finding: Less than significant. (Revised Draft EIR, p. 4-10.) Explanation: The proposed project would add approximately 145 new residents to the City of Goleta, which would incrementally in crease demand for neighborhood and regional parks and slightly reduce the City’s parkland ratio to 16.7 acres per 1,000 residents. 4 This represents a minimal change and would not cause substantial physical deterioration of existing facilities. In addition, the project includes on- site open space amenities, such as a community picnic area and landscaped lots, which would provide passive recreation opportunities for residents and reduce reliance on off -site facilities.

The project applicant would also be req uired to pay Quimby Act parkland dedication or in-lieu fees, which fund the development and maintenance of parks and recreational facilities. Accordingly, the proposed project’s impact related to the substantial physical deterioration of parks and recreati onal facilities would be less than significant. (Revised Draft EIR, p. 4-10.)
98 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
65 | P a g e

2. Construction and Expansion
Threshold: Does the Project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?
Finding: Less than significant. (Revised Draft EIR, p. 4-10.) Explanation: The project would include limited on-site recreational improvements, including a community picnic area and continuation of an existing Class I trail along Cathedral Oaks Road. These improvements would occur within the project site and have been evaluated as part of the overall grading, landscaping, and infrastructure improvements analyzed in this EIR. No off-site recreational facilities or expansions are proposed or required to serve the project. Therefore, the proposed project would not require the construction or expansion of recreational facilities beyond the recreational components of the proposed project. This impact would be less th an significant. (Revised Draft EIR, p. 4-10.)
Q. TRANSPORTATION / TRAFFIC

1. Plans, Policies, and Ordinances
Threshold: Would the Project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities?
Finding: Less than significant. (FEIR, pp. 4.11-7 – 4.11-8.) Explanation: The City of Goleta’s Transportation Element promotes a safe, efficient, and multimodal transportation system (City of Goleta 2006).

Consistent with Poli cy TE 1.1 proposed project provides two new access points on Cathedral Oaks Road; internal streets that connect to existing bicycle and pedestrian facilities; and internal sidewalks and pedestrian connections to the Class I multi -use path for bicycle and pedestrian use. These features would allow for integration with the surrounding circulation network and encourage walking and bicycling. The project would also advance Policy TE 2 by incorporating active transportation reduction strategies such as affordable housing integration and incorporation of bicycle facilities and pedestrian improvements. The proposed project also supports Policy TE 10 and Policy TE 11 by providing pedestrian linkages and maintaining connectivity to the City’s planned bikeway system ( City of Goleta 2006). This would be achieved with the project by the 99 Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
66 | P a g e

inclusion of frontage improvements along Cathedral Oaks Road between Northgate Drive to the west and the Glen Annie Golf Course property to the east. These frontage improvements include t wo driveway entrances to the site, curb and gutter installation, and continuation of an existing Class I trail that extends east of the project site and runs parallel to Cathedral Oaks Road. The Class I trail would provide an exclusive right-of-way for bicycle and pedestrian use and minimize vehicle cross flows (i.e., the locations which a vehicle can cross the pathway). Construction activities may require temporary lane closures within the public right -of-way (e.g., along Cathedral Oaks Road) to complete f rontage improvements and utility work, resulting in temporary disruptions to vehicular and multi -modal circulation in the area. In accordance with Chapter 12.02 of the City’s Municipal Code, the project applicant would be required to maintain at least one safe crossing for vehicles and must implement measures to minimize disruption to existing traffic conditions.

To ensure compliance with the City’s Municipal Code, as a Condition of Approval, the project applicant’s construction contractor would be required to prepare and implement a Construction Traffic Management Plan, which must specify transportation measures to be implemented during construction on Cathedral Oaks Road to ensure disruptions to transit, roadway, bicycle, and pedestrian facilities are min imized. These measures include the use of traffic control measures for traffic safety; coordination with SBCFD and MTD; and coordination with concurrent construction projects within

0.25-mile of planned improvements on Cathedral Oaks Road to ensure temporary lane and/or roadway closures on Hollister Avenue are coordinated to limit overlap. These requirements would be imposed as conditions of approval to minimize disruption and ensure safety during construction, consistent with Policy TE 12 (City of Goleta 2 006). The proposed project would be consistent with the City’s General Plan/Coastal Land Use Plan Transportation Element multimodal and performance policies and would not introduce conflicts with transit, roadway, bicycle, or pedestrian facilities.

Temporary construction-related effects would be addressed through the City’s encroachment permitting and Construction Traffic Management Plan implementation and requirements. Therefore, the proposed project would not include elements or features that would conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities. This impact would be less than significant. (FEIR, pp. 4.11- 7 – 4.11-8.)
100
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
67 | P a g e

2. Design Hazards
Threshold: Would the Project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
Finding: Less than significant. (Revised Draft EIR, p. 4.11-10.) Explanation: The proposed project would not substantially increase hazards due to a geometric design feature or incompatible use. The project includes two new access points on Cathedral Oaks Road that are aligned with Royal Linda Drive and King Daniel Lane across Cathedral Oaks R oad. These intersections would be controlled by two-way stop signs for the new roadways. The geometry of these intersections would provide clear visibility and minimize potential offset intersection conflicts and ensuring compliance with City design standards for safe access and circulation (City of Goleta 2006). The internal circulation system consists of a looped roadway with one cul- de-sac, which is typical for residential subdivisions and does not introduce sharp curves or unusual alignments. Surroundin g uses include residential neighborhoods, a golf course, and schools. The proposed residential development of the site would not present new conflicts with farm equipment or other incompatible uses.

Furthermore, the proposed project would incorporate sidewalks and frontage improvements, including the continuation of an existing Class I multi -use trail along Cathedral Oaks Road, which would enhance pedestrian and bicycle safety in accordance with the City’s Transportation Element goals for multimodal connectivity. Based on these considerations, the proposed project would not create or exacerbate hazards related to roadway geometry or incompatible uses, and impacts would be less than significant. (Revised Draft EIR, p. 4.11-10.)

3. Emergency Access
Threshold: Would the Project result in inadequate emergency access? Finding: Less than significant. (Revised Draft EIR, pp. 4.11-10 – 4.11-11.) Explanation: During construction, equipment staging and worker parking would occur entirely on -site, which would minimize the potential for construction-related vehicles to block travel lanes or impede emergency access in the immediate area. The proposed frontage improvements along Cathedral Oaks Road, including curb, gutter, and Class I trail continuation, may require temporary encroachment 101
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
68 | P a g e

into the public right-of-way and lane closures. These temporary lane closures could result in short -term disruptions to traffic fl ow on Cathedral Oaks Road, which serves as a primary access route for the project site and surrounding neighborhoods. In accordance with Chapter 12.02 of the City’s Municipal Code, the project applicant would be required to maintain at least one safe crossing for vehicles and must implement measures to minimize disruption to existing traffic conditions. The project would require implementation of a Construction Traffic Management Plan.

This plan would provide for traffic control measures and minimization of disruptions to critical access points for emergency service vehicles during construction and would be reviewed and approved by SBCFD. Accordingly, construction would not result in inadequate emergency access and impacts would be less than significant.

Project operations would not result in inadequate emergency access.

The proposed project includes two new access points on Cathedral Oaks Road, which are aligned with existing local roads and designed to meet City of Goleta standards for safe ingress and egress (City of Goleta 2006). The internal circulation system would also provide multiple routes for emergency vehicles to access all lots. The proposed project would comply with SBCFD requirements for roadway width, turning radii, and fire apparatus access. Additionally, the project frontage improvements along Cathedral Oaks Road would maintain unobstructed travel lanes and do not include any features that would impede emergency response. No gated entries or other barriers that could restrict emergency access are proposed.

Based on these design features and compliance with applicable fire and transportation standards, the proposed project would provide adequate emergency access, and impacts would be less than significant. (Revised Draft EIR, pp. 4.11-10 – 4.11-11.)

4. VMT
Threshold: Would the Project conflict or be inconsistent with CEQA Guidelines sections 15064.3, subdivision (b)?
Finding: Less than significant. (Revised Draft EIR, p. 4.11-8.) Explanation: Construction. Construction of the project would result in short-term, temporary vehicle trips to and from the project site during the construction phase. According to CEQA Guidelines Section 15064.3(b), the significance of transportation impacts is primarily determined by the amount and distance of vehicle travel attributable to a project. Project construction-related vehicle trips 102
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
69 | P a g e

would be temporary and limited to the duration of construction activities. As a result, temporary construction-related VMT would not have a lasting effect on the overall transportation network or traffic patterns in the area. Therefore, VMT for project construction would not conflict with or be inconsistent with CEQA Guidelines Section 15064.3(b). (Revised Draft EIR, p. 4.11-8.)

R. UTILITIES AND SERVICE SYSTEMS

1. Wastewater Treatment Requirements
Threshold: Would the Project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Finding: Less than significant. (Revised Draft EIR, pp. 4.13-11 – 4.13-12.) Explanation: Water
The proposed project includes a system of underground water lines beneath internal roadways, connecting residences to the City’s water main at Cathedral Oaks Road and Royal Linda Drive, and at Cathedral Oaks Road and King Daniel Lane. The environmental impacts of these water infrastructure improvements are evaluated throughout this EIR. The proposed project would not generate substantial water demand nor necessitate new or expanded water facilities to meet anticipated project demand. Therefore, the proposed project would not require new or expanded water facilities, beyond the improvements evaluated throughout this EIR, the construction of which could cause significant environmental effects.

This impact would be less than significant.

Wastewater
The proposed project includes a system of underground sewer lines beneath internal roadways connecting residences to the City’s sewer main underneath Cathedral Oaks Road adjacent to Royal Linda Drive and underneath King Daniel Lane adjacent to Cathedral Oaks Road. The GWSD WWTP has sufficient available capacity to treat the anticipated projectgenerated wastewater. In addition, GWSD has indicated it has the capability to provide wastewater treatment services for the proposed project. Accordingly, new wastewater 103
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
70 | P a g e

treatment facilities would not be required to accommodate the proposed project’s anticipated wastewater demand. The proposed project would not require new or expanded wastewater treatment facilities, beyond the wastewater infrastructure improvements evaluated th roughout the Revised Draft EIR, the construction of which could cause significant environmental effects. Therefore, this impact would be less than significant.

Stormwater
The proposed project would include a detention basin located in the western portion of the project site and an underground detention system located at the southern portion of the project site. The proposed detention basin and underground detention system have been sized to ensure the postproject peak runoff outflows would be maintained the same as the pre -project peak runoff outflows for a 100-year flood event, and that outflows from this infrastructure would not exceed the existing capacities of El Encanto Creek or the storm drains on Cathedral Oaks Road. Because the proposed stormwater drainage facilities would allow for stormwater filtration and would adequately capture stormwater runoff, no additional stormwater infrastructure would be needed beyond the stormwater infrastructure included as part of the proposed project. As a result, the proposed project would not require upgrades to stormwater infrastructure beyond what is evaluated within this EIR. Therefore, this impact would be less than significant.

Electric, Natural Gas, and Telecommunications Facilities The proposed project would include underground connections for cable television and electricity at the intersection of the proposed project’s driveways and Cathedral Oaks Road. The proposed project would be all-electric and would not utilize natural gas infrastructure.

The environmental impacts of these utility connections are evaluated throughout the Revised Draft EIR. SCE and 3CE would have sufficient electricity supplies for the proposed project and the proposed project would not place a substantial demand on electricity due to wasteful energy consumption such that new or expanded off- site electrical infrastructure would be needed. Similarly, the proposed project would use existing telecommunications facilities during operation and would not require upgrades to existing facilities or create a demand for service unable to be met by existing providers.

Therefore, this impact would be less than significant. (Revised Draft EIR, pp. 4.13-11 – 4.13-12.)
104
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
71 | P a g e

2. Water Supplies
Threshold: Would the Project have sufficient water supplies availabl e to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
Finding: Less than significant. (FEIR, pp. 4.13-12 – 4.13-13.) Explanation: Water demand of the proposed project is based on the Average Water Demand Report prepared for the proposed project in February 2026 (MQ Design Tech, Inc. 2026). As described in the report , the proposed project would result in an annual water demand of approximately 39.81 AFY.1 This demand represents approximately

25.7 percent of GWD’s SAFE Water Supply allocation of 154.7 acre- feet. GWD’s projected water surplus in a normal year 2040 is 4,507 acre-feet. In a single dry -year scenario, GWD’s projected water surplus in 2040 is 2,909 acre -feet. The proposed project’s water demand represents approximately 0. 9 percent of the anticipated 2040 surplus. During multiple dry years, GWD anticipates a water surplus of 2,909 AF in year one and 2,409 AF in year two, with demand and supply totals being equal in years three through five.

The proposed project’s water demand represents approximately 1.4 percent and 1.7 percent of GWD’s dry year one and dry year two surpluses, respectively. GWD’s UWMP identifies that, during years three through five of a drought, water supply and demand would b e balanced with the implementation of water conservation measures.

The GWD UWMP estimates a population of 34,300 for Goleta by 2040 (GWD 2021).

The current population of Goleta is approximately 32,747 people.

The proposed project would result in an estima ted population increase of 145 people, bringing the total population of Goleta to approximately 32,892 residents. This amount is within the population projections of GWD’s UWMP. In addition, GWD accounts for projected growth in the water projections in the ir UWMP. The 2025 UWMP is currently being developed and would account for project growth in the City of Goleta, including projected growth from the proposed project. Pursuant to the Goleta Water District Code, new projects can only secure new water entitle ment after final project approval by the applicable land use agency (in this case, the City of Goleta). Project applicants are required to obtain a Can and Will Serve letter from GWD, which specifies the water allocation to be provided to the proposed project. GWD will not issue a Can and Will Serve letter if sufficient water supplies are not available for a project. 105
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
72 | P a g e

A Conditional Can and Will Serve letter would be issued prior to issuance of final building permits, and the final Can and Will Serve letter would be issued after the final building permit is issued by the City of Goleta , all fees are paid, and all requirements of the Conditional Can and Will Serve Letter are met . Under the SAFE Water Supplies Ordinance, GWD is authorized to issue one percent of its total available water supply for new water connections each year that sufficient water is available, Goleta Water District SAFE Water Supplies Ordinance, being met. The proposed project demand would be less than one percent of GWD’s total available w ater supplies. However, water allocations are made on a first-come, first- served basis to projects that have received approval from the applicable land use agency (GWD 2025b). If sufficient water allocations are not available at the time a water supply all ocation application for the proposed project is submitted to GWD, the project applicant could pursue purchasing additional supplies via water wheeling from another water agency or acceptable third party with excess supplies for sale, and enter into an agr eement with GWD to wheel the water to the project site using GWD facilities. Water wheeling would involve the transfer of water supplies from another water agency or third party provided that existing water infrastructure is in place for the water supply transfer and environmental clearance has been previously completed for use of the water supply. When required by the GWD Board of Directors or District General Manager, the project applicant would be required to adhere to the water shortage restrictions during stages of drought, as set forth in Goleta Water District Code Chapter 6.21. Water shortage restrictions include prohibitions on manually irrigating landscaping with a hose not equipped with a shutoff nozzle, washing buildings or impervious areas such a s driveways and walkways, and use of outdoor water features. Restrictions are also imposed to prohibit hours for landscape watering. As detailed above, GWD will review the proposed project and issue a Can and Will Serve letter, stating that GWD has sufficient water available to support the proposed project.

In addition, because the proposed project’s water demand is adequately captured within GWD’s UWMP growth projections, the proposed project would not result in substantial water demand during drought years. The proposed project would not result in substantial water supply reductions; therefore, this impact would be less than significant. (FEIR, pp. 4.13-12 – 4.13-13.)

3. Wastewater Capacity
106
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
73 | P a g e

Threshold: Would the Project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
Finding: Less than significant. (Revised Draft EIR, p. 4.13-14.) Explanation: Residents would generate wastewater that would flow into GWSD’s conveyance system and be treated at the WWTP. Currently, the wastewater inflow to the WWTP is 5.01 MGD, leaving approximately

2.63 MGD of capacity available. GWSD is entitled to receive approximately 0.93 MGD more wastewater flows than what GWSD customers currently produce (McCarthy 2025). The proposed project’s anticipated wastewater generation is calculated consistent with the wastewater generation factor of 220 gallons per day per residential unit used in the City of Goleta General Plan/Coastal Land Use Plan Final EIR (City of Goleta 2006). Accordingly, the proposed project is anticipated to result in approximately 12,320 gallons of wastewater per day, or 0.01 MGD. A 0.01 MGD in crease in wastewater flows represents approximately one percent of the 0.93 MGD capacity available for GWSD customers. The existing WWTP capacity would be sufficient to accept wastewater generated by the proposed project. In addition, GWSD has indicated it has the capability to provide wastewater treatment services for the proposed project. Therefore, the proposed project is anticipated to result in a determination by GWSD that GWSD has adequate capacity to serve the proposed project in addition to existing demands. This impact would be less than significant. (Revised Draft EIR, p. 4.13-14.)

4. Solid Waste
Threshold: Would the Project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? Finding: Less than significant. (Revised Draft EIR, pp. 4.13-14 -- 4.13-15.) Explanation: Demolition and Construction
The proposed project would generate solid waste from the demolition of exist ing on -site structures and construction of the proposed residential development. The structures that would be demolished total 3,893 square feet. In addition, the proposed project would result in the construction of approximately 163,920 square feet of residential development. Based on a solid waste generation factor of 107
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
74 | P a g e

100 pounds per square foot for demolition, the demolition of existing structures would result in approximately 194 tons of debris. Based on a solid waste generation factor of 4.38 pounds per square foot for construction (USEPA 1998), the construction of the proposed project would generate approximately 358 tons of debris. In total, demolition and construction activities together would generate approximately 552 tons of solid waste. With the 6 5 percent demolition and construction waste recycling required by CalGreen Title 21 Part 11 Section 4.408.1 and Chapter 8.10 of the Goleta Municipal Code, demolition and construction would result in approximately 193 tons of solid waste that would require use of a landfill. This amount of nonrecyclable waste would not exceed the City’s project specific demolition and construction threshold of 350 tons. Therefore, the proposed project’s demolition and construction activities would have a less than significan t impact related to generating excessive solid waste and compliance with state and local solid waste management and reduction statutes.

Operation
Solid waste generation from project operation is calculated based on a waste generation factor of 0.95 tons per year per residence multiplied by the average number of people per unit, consistent with the County’s 2024 Environmental Thresholds and Guidelines Manual. The City has an average of 2.59 persons per household (California Department of Finance 2025). Bas ed on this factor, the proposed project would result in a gross solid waste generation rate of 138 tons per year.3 With a 50 percent solid waste diversion rate required by AB 939, this solid waste generation would be reduced to 69 tons per year. This amoun t of solid waste does not exceed the City’s project -specific threshold of 196 tons per year. As a result, project operation would not result in excessive solid waste generation and would comply with solid waste management and reduction statutes. Therefore, the proposed project’s operation would have a less than significant impact related to generating excessive solid waste and compliance with state solid waste management and reduction statutes. ( Revised Draft EIR, pp. 4.13 - 14 -- 4.13-15.)

5. Solid Waste Laws
Threshold: Will the Project comply with federal, state, and local statutes and regulations related to solid waste?
Finding: Less than significant. (Revised Draft EIR, pp. 4.13-14 -- 4.13-15.) 108
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
75 | P a g e

Explanation: Demolition and Construction
The proposed project would generate solid waste from the demolition of existing on -site structures and construction of the proposed residential development. The structures that would be demolished total 3,893 square feet. In addition, the proposed project would result in the construction of approximately 163,920 square feet of residential development. Based on a solid waste generation factor of 100 pounds per square foot for demolition, the demolition of existing structures would result in approximately 194 tons of debris. Ba sed on a solid waste generation factor of 4.38 pounds per square foot for construction (USEPA 1998), the construction of the proposed project would generate approximately 358 tons of debris. In total, demolition and construction activities together would generate approximately 552 tons of solid waste.2 With the 65 percent demolition and construction waste recycling required by CalGreen Title 21 Part 11 Section 4.408.1 and Chapter 8.10 of the Goleta Municipal Code, demolition and construction would result in approximately 193 tons of solid waste that would require use of a landfill. This amount of nonrecyclable waste would not exceed the City’s project specific demolition and construction threshold of 350 tons. Therefore, the proposed project’s demolition and construction activities would have a less than significant impact related to generating excessive solid waste and compliance with state and local solid waste management and reduction statutes.

Operation
Solid waste generation from project operation is calculated based on a waste generation factor of 0.95 tons per year per residence multiplied by the average number of people per unit, consistent with the County’s 2024 Environmental Thresholds and Guidelines Manual. The City has an average of 2.59 persons per household (California Department of Finance 2025). Based on this factor, the proposed project would result in a gross solid waste generation rate of 138 tons per year.3 With a 50 percent solid waste diversion rate required by AB 939, this solid waste generation would be reduced to 69 tons per year. This amount of solid waste does not exceed the City’s project -specific threshold of 196 tons per year. As a result, project operation would not result in excessive solid waste generation and would comply with solid waste management and reduction statutes. Therefore, the proposed project’s operation would have a less than significant impact related to generating excessive solid waste and compliance with state solid waste 109
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
76 | P a g e

management and reduction statutes. (Revised Draft EIR, pp. 4.13 - 14 -- 4.13-15.)
S. WILDFIRE

1. Response Plans
Threshold: If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the Project substantially impair an adopted emergency res ponse plan or emergency evacuation plan?
Finding: Less than significant. (Revised Draft EIR, pp. 4.14-18 -- 4.14-20.) Explanation: Construction. C onstruction activities may require temporary lane closures within the public right-of-way along Cathedral Oaks Road to complete frontage improvements and utility work. Cathedral Oaks Road serves as a primary east-west arterial in the city of Goleta and is designated as a critical transportation facility due to its role in facilitating emergency access and evacuat ion. Temporary lane closures during construction could result in reduced roadway capacity, localized congestion, and slower travel speeds, particularly at intersections or segments with limited alternative routing. These disruptions may also affect signal timing, turning movements, and access for large emergency vehicles, depending on the configuration of the work zone. These disruptions may delay emergency response times and impede evacuation flow, especially if closures coincide with high-risk periods or if detour routes are themselves constrained.

While these disruptions would be temporary during utility installation, in accordance with Chapter 12.02 of the City’s Municipal Code, the project applicant would be required to maintain at least one safe crossing for vehicles and must implement measures to minimize disruption to existing traffic conditions. To ensure compliance with the City’s Municipal Code, as a Condition of Approval, the project applicant’s construction contractor would be required to prepare and implement a Construction Traffic Management Plan, which must specify transportation measures to be implemented during construction on Cathedral Oaks Road to ensure disruptions to transit, roadway, bicycle, and pedestrian facilities are minimized.

These measures include the use of traffic control measures for traffic safety; coordination with SBCFD; and coordination with concurrent construction projects within 0.25 -mile of planned improvements on Cathedral Oaks Road to ensure temporary lane and/or road way closures on Hollister Avenue are coordinated to limit overlap. The 110
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
77 | P a g e

requirement for a Construction Traffic Management Plan as a Condition of Approval introduces project -specific controls that directly address the types of disruptions anticipated. These include traffic control measures to preserve safety and flow, coordination with SBCFD to ensure emergency access is maintained, and coordination with other nearby construction projects to avoid overlapping closures. These measures are designed to preserve the functional capacity of Cathedral Oaks Road during construction, thereby minimizing the potential for substantial delays to emergency response or evacuation. Given the presence of multiple access points in the surrounding developed area, and the implementation of targeted traffic management strategies, construction of the proposed project is not expected to substantially impair emergency evacuation routes.

With adherence to the City’s existing municipal code regulations requiring the implementation of a Construction Traffic Management Plan, construction of the proposed project would have a less than significant impact related to impairing emergency evacuation.

Operation. The proposed project includes two ingress/egress points at the southwest and southeast edges of the project site which provide connection to Cathedral Oaks Road. It is estimated that the proposed project would result in up to 84 additional vehicles utilizing Cathedral Oaks Road as an evacuation route. This addition would not exceed the road’s current capacity of 1,600 vehicles per hour.

Furthermore, if Cathedral Oaks Road became impassable or reached capacity during an evacuation, vehicles from the project site could evacuate via Brandon Drive to Calle Real or Placer Drive and Ellwood Station to Calle Real. Additionally, the proposed project design includes internal roads that comply with fire department standards for widths and maneuvering for vehicles inc luding fire trucks. This ensures that internal roadways constructed as part of the proposed project are adequate for evacuees, which further reduces the potential for the project to result in inadequate evacuation routes for future residents.

Overall, project operation would have a less than significant impact related to impairing emergency evacuation. While the proposed project would not impair emergency evacuation, SBCFD maintains a response time goal of eight minutes for suburban areas. This goal is a performance benchmark rather than a regulatory requirement, and slight deviations from it do not necessarily indicate a deficiency in emergency response service. The travel time from the closest fire station to the project site, Fire Station 11, is nine min utes (including 111
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
78 | P a g e

a three-minute dispatch time), which is over the response time goal by one minute for suburban areas. However, the proposed project would not include any components that would result in further delays of SBCFD response times. As described above, the proposed project would result in up to 84 additional vehicles utilizing Cathedral Oaks Road, which would not result in substantial barriers to SBCFD response to the project site. Additionally, the project applicant would be required to pay impact fees in accordance with the General Plan/Costal Land Use Plan Policy PF 3.3 and Municipal Code Chapter 17.70. These fees would support the construction of a proposed fire station located at 7952 Hollister Avenue, which would be closer to the project site. The total response time from this proposed fire station to the project site would be seven minutes, which is within the SBCFD response time goal for suburban areas.

The proposed project itself does not necessitate construction of Fire Station 10; rather, the planned Fire Station 10, which has already undergone environmental review, would address existing service levels for fire protection facilities in Goleta and would help the SBCFD achieve adequate service in Goleta. Given that the eight - minute response time is a goal rather than a mandated threshold, the proposed project would not include features that would substantially delay SBCFD response times, and the project applicant would contribute to ensuring adequate fire services are available in Goleta through the payment of development impact fees, the proposed project would not result in substantial delays to fire protection services. Therefore, operational impacts on emergency response and fire protection services would be considered less than significant. (Revised Draft EIR, pp. 4.14-18 -- 4.14-20.)

2. Pollutant Concentrations
Threshold: Due to slope, prevailing winds, and other factors, would the Project exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of wildfire?
Finding: Less than significant. (Revised Draft EIR, pp. 4.14-20 -- 4.14-22.) Explanation: Construction. The project site contains combustible materials on site including vegetation, woodchips, and firewood, as well as several vacant structures. The project would include the construction of 56 single family dwellings on the site. During construction, there would be a temporary increase in human activity and potential ignition sources, including equipment that could create sparks, be a source of heat, or leak flammable materials. Heat or sparks from 112
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
79 | P a g e

construction equipment, vehicles, and the use of flammable hazardous materials have potential to ignite adjacent vegetation and start a fire, especially during weather events that include low humidity and high wind speeds. However, construction of the proposed project would not include unique activities that could exacerbate fire risk, such as storage of high quantities of flammable liquids and fuels or use of tempor ary heating equipment. In accordance with CFC Chapter 9, Section 3312, installation of an on -site water supply system would occur prior to the commencement of construction to provide water supply for firefighting in the event of a fire. Additionally, construction activities would include the use of safety equipment and procedures such as spark arresters, clearance around welding or other hot work, smoking restrictions, extinguishers, and charged water hoses and shovels nearby. These measures would interrupt ignition pathways and limit fire propagation. Furthermore, in accordance with Chapter 35 of the CFC, fire watch must be provided during hot work activities and continue at least 30 minutes beyond the conclusion of hot work activities. As part of the fire watch, the work are must be reviewed prior to authorizing hot work operations to ensure the hot work would be conducted in a fire -safe area, thereby further reducing wildfire risk during construction. The combination of site-specific fire safety measures, timing controls, and regulatory compliance ensures that construction activities would not materially increase wildfire risk beyond baseline conditions. With implementation of these measures, construction impacts would be less than significant.

Operation. Project operation would involve 56 new single -family dwelling units on the project site. This could result in the introduction of new potential ignition sources in the form of flammable building materials, vegetation for landscaping, vehicles, and small machinery for building and landscape maintenance. Additionally, the proposed project would be constructed with materials consistent with CBC Chapter 7A and California Residential Code Section R337.

Specifically, the proposed project would comply with require ments set forth for roof coverings, vents, residential sprinklers, ignition - resistant construction materials, decking, and exterior windows, skylights, and doors. Compliance with these requirements would reduce the likelihood that structures would ignite f rom embers, radiant heat, or direct flame contact during a wildfire, as these requirements are designed to interrupt common ignition pathways and limit fire spread. Additionally, the proposed project design would be subject to review by SBCFD to ensure the proposed project design adheres to SBCFD development standards for adequate 113
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
80 | P a g e

ingress and egress, fire hydrant spacing and water flow to the site, installation of a stored water protection system on site, adequate fire sprinkler systems, and defensible space.

The proposed project would include installation of a new water main on site and a domestic and fire storage and delivery system that would exceed the minimum fire flow requirements included in the CFC. The fire hydrant system installed on site would be in compliance with SBCFD development standards. In accordance with General Plan/Costal Land Use Plan Policy SE 7.4 and Municipal Code Section 17.32.060, a landscape plan which meets the requirements of a Fire Fuel Modification Plan was prepared for the proposed project. The plan was developed to meet SBCFD
development standards and demonstrates compliance with
defensible space requirements outlined in Chapter 49 of the CFC and Section 51182 of the California Government Code. The plan prohibits the use of h ighly flammable plant species identified in SBCFD development standards and instead incorporates irrigated, fire-resistant landscaping around dwelling units and common areas.

Plantings would be strategically placed to create fuel breaks, reduce flame lengths, and minimize the potential for fire to spread toward nearby homes. Hardscaping with limited combustible materials in or near structures and the use of non -combustible fencing would be utilized on the project site to minimize the ability of a fire to sp read on-site. Hardscaping would include interior block walls between individual lots and a perimeter block wall surrounding the development which would serve to contain potential on -site fires. In addition, the proposed project would include a 50 -foot-wide landscape buffer along Cathedral Oaks Road which would ensure flammable vegetation is adequately set back from Cathedral Oaks Road such that potential ignition sources near the roadway are limited.

Collectively, these hardscape and landscape features wou ld minimize the likelihood of wildfire ignition or spread within the project site. Project roadways would meet SBCFD development standards, which would ensure that fire response vehicles would be able to readily access the site in the event of a fire, reducing the potential for the fire to spread uncontrollably. Additionally, there are no gates on the project site, ensuring access to the project site would not be blocked by any closed gates in the event of an emergency. The project site is mostly surrounded by a golf course and urban development, both of which provide effective defensible space and would not readily contribute to the spread of wildfire. Specifically, the 114
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
81 | P a g e

existing golf course is maintained as a greenbelt that is regularly irrigated and managed to remain non-combustible, thereby reducing potential fire exposure along much of the project boundary. However, there is a small portion of the site along the southwestern border that includes a riparian area which has combustible vegetation. To minimize potential wildfire risk in this area, the proposed project would incorporate a maximum 100 -foot buffer zone4 between any development associated with the proposed project and the riparian zone onsite. This buffer area would include a walking path, turf areas, trees selected for low flammability, and irrigated landscaping intended to not support the spread of wildfire.

The proposed project would also construct a perimeter road which would further separate dwelling units from the riparian area along the southwest border of the site. This buffer area would provide an additional fuel break and access route for emergency responders which would reduce the risk of the spread of wildfire onto the project site. Overall, the design of the proposed project would mini mize the amount of ignition sources for a fire and would include features to assist with the containment of wildfire in compliance with existing regulations including those in the CFC, CBC, California Residential Code, the City of Goleta General Plan/Coast al Land Use Plan, Municipal Code, and SBCFD Development standards. The proposed project’s impact related to the uncontrolled spread of a wildfire would be less than significant. (Revised Draft EIR, pp. 4.14-20 -- 4.14-22.)

3. Infrastructure Risks
Threshold: Would the Project require the installation or maintenance of associated infrastructure (such a roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts t o the environment?
Finding: Less than significant. (Revised Draft EIR, pp. 4.14-22 -- 4.14-23.) Explanation: The project would be served by extensions of existing power lines, water sources, and other utility services. Specifically, the proposed project w ould require the extension of underground power lines beneath Cathedral Oaks Road and installation of new underground water lines connecting to the existing water main at Cathedral Oaks Road and Royal Linda Drive, and at Cathedral Oaks Road and King Daniel Lane. Additionally, the proposed project would involve construction of internal roadways within the project site to provide site access.
115
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
82 | P a g e

These new roadways would enhance emergency response
capability by improving ingress and egress for both residents and emergency vehicles. The new on -site water lines would serve the proposed residences and supply several new fire hydrants throughout the development, thereby improving firefighting capacity.

Undergrounding the power lines would further reduce wildfire ignition potential associated with overhead utility infrastructure. Furthermore, the proposed project would maintain a maximum 100 - foot buffer zone near the riparian area on the southwestern border of the project site to further reduce spread of wildfire to a djacent land. This buffer area and implementation of the project landscape plan would reduce wildfire risk by reducing fuel load on site. The proposed project would also comply with the defensible space requirement set forth in the SBCFD development standards, Chapter 49 of the CFC, and Section 51182 of the Government Code by maintaining irrigated fire resistive landscaping around the dwelling units and common areas on the project site which would reduce the risk of wildfire on site. Installation of the proposed infrastructure would occur entirely within the project site, and the environmental effects of such improvements are evaluated throughout the Revised Draft EIR. None of the potential infrastructure improvements would exacerbate fire risk or result in additional temporary or ongoing impacts to the environment beyond those already identified and disclosed throughout this EIR.

Therefore, this impact would be less than significant. (Revised Draft EIR, pp. 4.14-22 -- 4.14-23.)

4. Runoff Risks
Threshold: Would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? Finding: Less than significant. (Revised Draft EIR, pp. 4.14-23 -- 4.14-24.) Explanation: Construction. The proposed project would involve over one acre of site disturbance during grading and the construction of residences, sidewalks, roadways, patios, landscaping, and associated facilities. Construction would involve grading of approximately 27,500 cubic yards of cut and 23,500 cubic yards of fill. This grading activity would involve vegetation removal and expose soil to erosion. Project site disturbance would eliminate existing vegetative cover, including grasses, shrubs, and ornamental landscaping, which currently stabilize soil and reduce surface runoff.

The removal of vegetation and modification of site topography would increase the susceptibility of exposed soils to erosion from wind and 116
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
83 | P a g e

stormwater, particu larly during construction activities. Although wildfires can exacerbate erosion and slope instability, the project site does not contain steep terrain, ravines, or other unique topographic features that would intensify post -fire runoff or landslide risk. The proposed project would comply with the Construction Stormwater General Permit and the City Municipal Code, as well as
implementation of the required Stormwater Pollution Prevention Plan and construction best management practices to minimize erosion and sediment discharge on site.

By minimizing on-site erosion and controlling sediment-laden runoff, these standards help prevent downstream sedimentation that could reduce channel capacity and increase flood risk. Proper stormwater management also reduces th e likelihood of concentrated flows that could destabilize slopes or contribute to shallow landslides, particularly in areas with steep terrain or erodible soils. The Stormwater Pollution Prevention Plan and best management practices are designed to maintai n pre -construction hydrologic conditions to the extent feasible, thereby reducing the potential for off-site impacts such as flooding or slope failure. With implementation of these standards, construction activities would not substantially alter the draina ge pattern of the site or result in substantial erosion. Additionally, the proposed project would implement measures such as the use of spark arresters on equipment and the suspension of hot work during periods of elevated fire risk. These measures directl y address the potential for fire ignition from construction activities Through implementation of site - specific erosion control measures and fire prevention protocols, the proposed project would have low potential to expose people or structures to significa nt risks associated with runoff, post -fire slope instability, or drainage changes. Construction impacts would be less than significant. (Revised Draft EIR, pp. 4.14-23 -- 4.14-24.) SECTION III.

IMPACTS THAT ARE LESS THAN SIGNIFICANT WITH MITIGATION

INCORPORATED
The City Council hereby finds that Mitigation Measures have been identified in the EIR and these Findings that will avoid or substantially lessen the following potentially significant environmental impacts to a less than significant level. The potentially significant impacts, and the Mitigation Measures that will reduce them to a less than significant level, are as follows:
117
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
84 | P a g e

A. BIOLOGICAL RESOURCES

1. Sensitive Species
Threshold: Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
Finding: Less than significant with mitigation incorporated . (Revised Draft EIR, pp. 4.3-22 – 4.3-29.)
Explanation: Construction.

Special-Status Plant Species
The only special-status plant species observed on the project site is Santa Barbara honeysuckle. Approximately 59 Santa Barbara honeysuckle shrubs were observed on the western edge of the project site, with a cluster of Santa Barbara honeysuckle shrubs occurring in the southwestern portion of the projectsite, where the new 90-foot long section of storm drain pipe would tie into an existing buried storm drain pipe that discharges into El Encanto Creek. Two other special-status plant species, ocellated Humboldt lily and black- flowered figwort, have a moderate potential to occur on the project site. Construction Approximately 10 Santa Barbara honeysuckle plants would be removed during grading activities for project construction. Additionally, project construction would require the removal or disturbance of habitat for Santa Barbara honeysuckle, and may require the removal or disturbance of habitat for ocellated Humboldt lily and black-flowered figwort. Thus, the proposed project would potentially result in direct i mpacts to Santa Barbara honeysuckle, ocellated Humboldt lily, and black -flowered figwort, and such impacts would be potentially significant. Indirect impacts to Santa Barbara honeysuckle, ocellated Humboldt lily, and black - flowered figwort may occur during project construction from adverse water quality effects, chemical spills or vehicle leaks near the special- status plants (if present), or dust generation. These impacts would be less than significant through implementation of standard construction BMPs sp ecified in the SWPPP (such as erosion and sediment control BMPs designed to minimize erosion and retain sediment on-site, and good housekeeping BMPs to reduce the risk of spills, leaks, and off -site discharge of construction debris and waste), as well as s tandard fugitive dust control measures 118
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
85 | P a g e

recommended by the Santa Barbara County Air Pollution Control District (such as vehicle speed limits, coverin g stockpiles, watering of disturbed soil, and minimizing construction activities during high winds).

Special-Status Wildlife Species
One special-status wildlife species, western red bat, has a moderate potential to roost and forage on -site. No special -status wildlife species have been observed on the project site, or have a high potential to occur on-site.

The proposed project would remove nonnative ornamental trees on the project site. If western red bats are roosting in these trees at the time of removal, this disturbance could result in displacement or temporary loss of roosting sites, resulting in a direct impact to the species. However, western red bat, if present on the project site, would likely roost in adjacent areas to the project site and continue foraging in these areas, particularly over the adjacent golf course and open spaces, which offer insect prey. The continued availability of foraging habitat would reduce the likelihood of long-term population- level effects associated with roost removal. Nevertheless, the potential removal of available roosting habitat would result in a potentially significant impact on western red bat.

Nesting Birds
Migratory birds and raptor species may utilize the project site for roosting habitat. Nests of common raptor species are considered ESHA pursuant to the City of Goleta General Plan/Coastal Land Use Plan Policy CE 8.1 (City of Goleta 2006).

Direct impacts to migratory bird or raptor nests could occur during demolition of existing structures, removal of vegetation, and ground disturbing activities if nests are present at the time of project construction. Indirect i mpacts, such as increased noise, vibration, and human presence during construction (if it occurs within the nesting bird season) could result in nest disturbance, including nest abandonment and mortality of fledglings, at the project site or adjacent areas . Therefore, construction -related impacts would be potentially significant.

Mitigation Measure NOI-1 would reduce potential indirect impacts to nesting birds during project construction by minimizing construction noise in compliance with existing City noise standards. 119
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
86 | P a g e

Mitigation Measures BIO-1, BIO-2, and BIO-3 would reduce potential impacts to special-status plant species by requiring pre-construction special-status plant surveys and fencing around special-status plant habitat that would ensure avoidance o f such habitat during construction activities (BIO-1), preparation and implementation of a Rare Plant Protection Plan (BIO -2), and preparation of implementation of a Habitat Restoration Plan that specifies mitigation for removal of rare plant species (BIO -3). Mitigation Measure BIO-4 would reduce potential impacts to special-status species, both plant and wildlife, by requiring biological monitoring during construction and construction worker environmental awareness training.

Mitigation Measure BIO -4 would reduce potential impacts to all special-status species included in the above analysis. Mitigation Measure BIO-5 would reduce potential impacts to western red bat by requiring pre-construction surveys and roost avoidance, if detected.

Mitigation Measure BIO-6 would reduce potential impacts to nesting birds and raptors by requiring pre -construction surveys and avoidance measures. Following the implementation of Mitigation Measures NOI-1 and BIO -1 through BIO -6, the proposed project’s construction impact involving a substantial adverse effect on special- status species or their habitat would be less than significant with mitigation incorporated. (Revised Draft EIR, pp. 4.3-29 – 4.3-30.)

MM BIO-1 Special-Status Plant Surveys and Avoidance
Prior to the start of construction activities, including vegetation removal, a City-approved, qualified biologist (retained by the project applicant) shall conduct a spring special -status plant survey within the areas of proposed ground disturbance. The su rvey shall be conducted during the appropriate season (March –April) and in suitable habitat to detect rare annual plant species (ocellated Humboldt lily [Lilium humboldtiissp. ocellatum] and black -flowered figwort [Scrophularia atrata]) and additional indi viduals of Santa Barbara honeysuckle (Lonicera subspicata var. subspicata) that may not have been observed during previous surveys conducted on June 20, July 11, July 21, August 22, November 3, and November 5, 2025 as part of the Biological Assessment Repo rt for the Shelby Residential Development Project (Watershed Environmental, Inc. 2025). The survey shall be conducted in accordance with the CNPS Botanical Survey Guidelines (2001), CDFW Protocols for Surveying and Evaluating Impacts to Special Status Nati ve Plant Populations and Sensitive Natural Communities (2018), and the USFWS General Rare Plant Survey Guidelines (Cypher 2002). Reference sites shall 120
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
87 | P a g e

be visited to confirm detectability of target species prior to initiating the survey. Within 24 hours of completing the spring survey, the qualified biologist shall prepare and submit a brief letter report documenting the survey methods and results to the City of Goleta’s Planning and Environmental Review Director, or designee, for review and approval. A second pre-construction special-status plant survey shall be conducted by the qualified biologist no more than two weeks prior to the initiation of vegetation removal and construction activities.

The biologist shall prepare a brief letter report summarizing th e survey results within 24 hours of completing the survey and submit it to the City of Goleta’s Planning and Environmental Review Director, or designee, for review and approval. If construction has not commenced within two years of the most recent survey, the special- status plant survey shall be repeated prior to the start of construction.

If special status plant species are detected during the spring and/or pre-construction special status plant surveys, the project applicant shall implement Mitigation Measure BIO-2.

Plan Requirements and Timing . The spring and pre -construction special-status plant surveys shall be conducted by the qualified biologist prior to issuance of Zoning Clearance for the grading permit.

The qualified biologist shall prepare and sub mit a brief letter report summarizing the results of each survey to the City of Goleta’s Planning and Environmental Review Director within 24 hours of completing the survey. If construction has not commenced within two years of the most recent survey, the special-status plant survey shall be repeated prior to the start of construction.

Monitoring. The City of Goleta’s Planning and Environmental Review Director, or designee, shall review and approve the survey results and maintain documentation on file.

MM BIO-2 Rare Plant Protection Plan
Prior to issuance of Zoning Clearance for the grading permit, the project applicant shall retain a City approved, qualified biologist to prepare a Rare Plant Protection Plan for review and approval by the City of Golet a’s Planning and Environmental Review Director, or designee. The Rare Plant Protection Plan shall focus on special - status species with potential to occur on -site (Santa Barbara honeysuckle, ocellated Humboldt lily, and black -flowered figwort) and shall include:
 Establishment of avoidance buffers for special -status plant species and habitat that supports special-status plants outside of 121
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
88 | P a g e

the project’s disturbance area.
 Specifications for temporary rare plant protection fencing (minimum 4 feet tall, metal po sts spaced no more than 8 feet apart).
 Locations of fencing depicted on grading plans.
 “Rare Plant Protection Zone – Keep Out” signage posted at 20 - foot intervals.
 Maintenance requirements to ensure fencing remains upright and effective throughout construction.

The qualified biologist shall inspect the fencing and signage and establish avoidance buffers prior to the start of construction and shall submit written confirmation to the City of Goleta’s Planning and Environmental Review Director, or designee , that the fencing has been installed in accordance with the approved plan.

Plan Requirements and Timing . The Rare Plant Protection Plan shall be finalized by the qualified biologist and approved by the City of Goleta’s Planning and Environmental Review D irector, or designee, prior to issuance of Zoning Clearance for the grading permit. Fencing, signage, and avoidance buffers shall be installed by the qualified biologist prior to the start of construction and maintained throughout the duration of construction activities.

Monitoring. The City of Goleta’s Planning and Environmental Review Director, or designee, shall review and approve the Rare Plant Protection Plan and restoration plan, maintain documentation on file, and conduct periodic inspections to ens ure compliance with fencing, signage, and restoration requirements.

MM BIO-3 Habitat Restoration and Rare Plant Mitigation Prior to issuance of Zoning Clearance for the grading permit, the project applicant shall retain a City approved, qualified biologist to prepare a Habitat Restoration Plan consistent with the provisions of Goleta Municipal Code Section 17.30.030(D) to restore and mitigate impacts to native vegetation communities and special -status plant species. Restoration and mitigation shall occur on the project site if feasible. The plan shall provide for:
 Restoration of temporarily disturbed native vegetation (includi ng black sage – California sagebrush scrub, arroyo willow thicket, 122
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
89 | P a g e

and eucalyptus grove) at a minimum 1:1 ratio.
 Mitigation for permanent impacts to black sage – California sagebrush scrub, arroyo willow thicket, and eucalyptus grove at a minimum 3:1 ratio.
 Mitigation for removal of rare plant species, including Santa Barbara honeysuckle (Lonicera subspicata var. subspicata), ocellated Humboldt lily (Lilium humboldtii ssp. ocellatum) and blackflowered figwort (Scrophularia atrata) at a minimum 10:1 ratio. All plant materials used for restoration and mitigation shall be locally sourced from the Goleta or Devereux Slough
watersheds or adjacent watersheds. The plan shall specify:
 Quantity, species, and container size of plant materials to be installed.
 Annual performance standards for vegetation growth, cover, and survival.
 Success criteria requiring a minimum of 85 percent native vegetation cover and/or rare plant survival after five years.  Maintenance activities to support plant establishment and long - term viability.
 Frequency of biological monitoring (by the qualified biologist) and reporting requirements (to the City of Goleta’s Planning and Environmental Review Director).

Plan Requirements and Timing . The Habitat Restoration Plan shall be submitted to the City of Goleta’s Planning and Environmental Review Director, or designee, for review and approval prior to issuance of Zoning Clearance for the grading permit. Restoration and mitigation planting shall occur during the first planting season following completion of construction in impacted areas. Rare plant mitigation shall be implemented concurrently with native vegetation restoration.

Monitoring. The City of Goleta’s Planning and Environmental Review Director, or designee, shall review and approve the Habitat Restoration Plan and maintain documentation on file. The qualified biologist shall conduct biological monitoring in accordance with the approved plan and submit status reports to the City of Goleta’s Planning and Environmental Review Director for five years following installation. The City of Goleta’s Planning and Environmental Review Director, or designee, shall conduct 123
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
90 | P a g e

periodic inspections to verify compliance with restoration goals, including vegetation cover, species composition, and rare plant survival.

MM BIO-4 Biological Monitoring and Worker Education Prior to initiation of construction activities, the project applicant shall retain a City -approved, qualified biologist familiar wit h special-status plant and wildlife species with the potential to occur in the project work area. The qualified biologist shall be present on-site daily during grading and vegetation removal. The monitor shall be responsible for the following:
 Ensure that procedures for verifying compliance with biological resource mitigation measures are followed.
 Lines of communication and reporting methods.
 Guiding the construction contractor in marking/flagging construction area limits.
 Conducting construction crew W orker Environmental
Awareness Program (WEAP) training.
 Authority to stop non-emergency work.
 Action to be taken in the event of non-compliance.
 Conducting daily wildlife clearance surveys prior to any grading, turf removal, other vegetation removal.
 Inspecting ESHA fencing around sensitive habitats.
 Preparing monitoring summaries of special-status species’ presence, or the lack thereof, on the project site during grading or vegetation removal. All construction personnel shall attend a WEAP training cond ucted by the qualified biologist prior to commencement of construction activities.

The construction contractor(s) shall be responsible for ensuring that all new personnel receive the training after construction is initiated. The WEAP 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 shall be implemented to protect special -status spe cies. Special -status plant species addressed in the WEAP training shall include, at a minimum, Santa Barbara honeysuckle, ocellated
Humboldt lily, and black -flowered figwort. Species -status 124
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
91 | P a g e

wildlife species addressed in the WEAP, at a minimum,
shall include western red bat.

Plan Requirements and Timing. The qualified biologist shall be present on-site daily during grading and vegetation removal. This measure shall be incorporated into the grading plans and the WEAP shall be available on -site during constru ction. The qualified biologist shall submit a monitoring summary to the City of Goleta’s Planning and Environmental Review Director within 30 days after completing each phase of construction.

Monitoring. Records of construction worker WEAP participation shall be kept on file with the City of Goleta’s Planning and Environmental Review Director for the duration of construction.

Monitoring summaries shall be kept on file with the City for the duration of construction.

MM BIO-5 Bat Roost Avoidance and Protection
To avoid disturbance to western red bats (Lasiurus blossevillii), ground disturbance and tree removal shall occur outside of the bat maternity season (April 1 to August 31). If ground disturbance or tree removal mus t occur during this period, the project applicant shall retain a City -approved, qualified biologist to conduct two nighttime acoustic bat surveys no more than two weeks prior to tree removal within the disturbance footprint, plus a 300 -foot buffer. Surveys shall be conducted using ultrasonic microphones capable of detecting bat echolocation calls and shall last a minimum of one hour each. Survey conclusions shall be reviewed and approved by the City of Goleta’s Planning and Environmental Review Director, or designee, prior to initiation of construction.

If bat activity is detected, the qualified biologist shall conduct a daytime visual inspection of trees for signs of active roosts, including guano, insect carcasses, or direct observation of bats.

If any active roosts are found, the City -approved biologist shall establish a 100 -foot buffer. The construction contractor shall ensure that no ground disturbance or tree removal occurs within the buffer until the City-approved biologist confirms the breeding season has concluded or the roost is no longer active and removes the buffer. If work within the buffer is necessary, a City- contracted biological monitor (funded by the project applicant) shall monitor the active roost full -time during construction activities within the buffer to ensure project activities are not 125
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
92 | P a g e

indirectly impacting roosting bats.

Plan Requirements and Timing. Within 24 hours of completing the surveys (and prior to initiation of tree removal activities), the qualified biologist shall prepare a brief report summarizing the methods and results of the acoustic and visual bat surveys and submit it to the City of Goleta’s Planning and Environmental Review Director.

Monitoring. The City of Goleta’s Planning and Environmental Review Director, or des ignee, shall review and approve the bat survey results prior to commencement of tree removal activities and maintain documentation on file. The City of Goleta’s Planning and Environmental Review Director shall conduct periodic inspections to ensure that tr ee removal activities comply with seasonal restrictions and avoidance measures for active bat roosts.

MM BIO-6 Pre-construction Nesting Bird Surveys and Avoidance To avoid construction impacts to nesting birds and raptors, the construction contracto r shall conduct vegetation removal and initial ground disturbance outside the bird and raptor breeding season, which is typically February 1 through September 1 but can vary based on local and annual climatic conditions. If construction begins within the b reeding season, then not more than seven days before demolition, ground disturbance, and/or vegetation removal commences, a bird and raptor
preconstruction survey shall be conducted by a City -approved, qualified biologist (retained by the project applicant ) within the disturbance footprint, plus a 300-foot buffer. The survey shall be conducted by a biologist familiar with the identification of bird species known to occur in southern California.

The City -approved biologist shall conduct the preconstruction nesting bird and raptor surveys during the time of day when bird species are active and for a sufficient duration to reliably conclude presence/absence of nesting birds and raptors within the 300-foot buffer. The City-approved biologist shall submit a summary of the nesting bird and raptor survey results to the City of Goleta’s Planning and Environmental Review Director, or designee.

Survey conclusions shall be reviewed and approved by the City of Goleta’s Planning and Environmental Review Director, or designee, prior to initiation of construction. If no bird nests are observed no further mitigation is required.
126
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
93 | P a g e

If an active nest of species protected by the California Fish and Game Code (§ 3503) or Migratory Bird Treaty Act are found within 300 feet of the di sturbance footprint, the City -approved biologist shall flag their locations and map their locations on an aerial photograph of the disturbance footprint at a scale no less than 1”=200’ and/or recorded with the use of a Global Positioning System unit. If ac tive raptor nests are detected, the map shall include topographic lines, parcel boundaries, adjacent roads, known historical nests for protected nesting species, and known roosting or foraging areas, as required by the City of Goleta’s General Plan/Coastal Land Use Plan Policy CE 8.3. The buffer shall be 300 feet in compliance with the City of Goleta’s General Plan/Coastal Land Use Plan Policy CE 8.4. If the 300 -foot buffer is infeasible, the City -approved biologist may reduce the buffer distance as appropr iate, depending upon the species and the proposed work activities. If any active non -raptor bird nests are found, the City-approved biologist shall establish a suitable buffer area (varying from 25 to 300 feet), depending on the species. The construction contractor shall ensure that no ground disturbance occurs within the buffer until the City-approved biologist confirms that the breeding/nesting is completed and all the young have fledged, and removes the buffer. If work within the buffer is necessary, a C ity-contracted biological monitor (funded by the project applicant) shall monitor the active nest full -time during construction activities within the buffer to ensure project activities are not indirectly impacting protected nesting birds and raptors. If work ceases for more than 30 days, a new nesting bird survey shall be conducted in accordance with this measure.

Plan Requirements and Timing: The survey shall be conducted no more than seven days prior to commencement of any
demolition, grading, and/or vegetation removal activities. Survey conclusions shall be reviewed and approved by the City of Goleta’s Planning and Environmental Review Director, or designee, prior to the commencement of construction activities that could disturb suitable nesting habitat, such as demolition, grading, and/or vegetation removal. This measure, and any buffer requirements, shall be incorporated into the grading plans.

Monitoring: The City of Goleta’s Planning and Environmental Review Director, or designee, shall review any bio logical survey reports and conduct periodic site inspections to verify compliance with survey recommendations in the field. The City of Goleta’s Planning and Environmental Review Director, or designee, shall 127
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
94 | P a g e

conduct periodic spot checks to ensure that construction does not occur within the buffer during construction.

2. Riparian Habitat
Threshold: Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Finding: Less than significant with mitigation incorporated. (Revised Draft EIR, pp. 4.3-32 – 4.3-33.)
Explanation: Direct Construction Impacts on ESHA and ESHA Buffers Direct impacts to arroyo willow thicket, black sage – California sagebrush scrub, and eucalyptus grove that serves as raptor roosting habitat ESHA, as well as the respective ESHA buffers, would include the construction of new structures or fa cilities within ESHA or ESHA buffers. The proposed project would directly impact native vegetation, including ESHA, in four areas: installation of a new storm drain pipe that would tie into an existing storm drain pipe in the southwestern portion of the pr oject site; construction of a new bike path along Cathedral Oaks Road; grading in the southwestern corner of the project site to construct the detention basin; and grading and building construction within eucalyptus grove along El Encanto Creek. Impacts to these areas are discussed further below.

Storm Drain Pipe
The proposed storm drain pipe in the southwestern portion of the project site would be installed underground and would result in impacts to black sage – California sagebrush scrub ESHA during trenching activities. These impacts would include vegetation removal and soil disturbance within sensitive natural communities. According to the City of Goleta General Plan/Coastal Land Use Plan Policy CE

1.6 and Goleta Municipal Code Section 17.30.040, develop ment within ESHA and ESHA buffers is generally prohibited unless the use is considered resource-dependent and is sited and designed to avoid or minimize impacts to the maximum extent feasible. As stipulated by City of Goleta General Plan/Coastal Land Use P lan Policy CE

1.6(d), utility structures, such as stormwater management systems, may be allowed within ESHA or buffers if they are necessary to protect public health and safety and if no feasible alternative exists outside of the ESHA. The storm drain pipe is a resource-dependent 128
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
95 | P a g e

utility designed to manage stormwater runoff generated by impervious surfaces within the proposed development and to reduce downstream erosion and flooding. El Encanto Creek is the natural receiving water for stormwater in the vici nity of the project site, and the project site currently drains toward the creek under existing conditions. The proposed storm drain pipe would tie into an existing storm drain pipe that already discharges to El Encanto Creek. Due to topographic constraints and the location of the creek adjacent to the western boundary of the project site, there is no feasible alternative discharge location. Additionally, City of Goleta General Plan/Coastal Land Use Plan Policy CE 2.5 (Maintenance of Creeks as Natural Drain age Systems) emphasizes discharge to natural waterbodies, such as El Encanto Creek. The storm drain pipe has been sited and designed to minimize significant adverse impacts to riparian vegetation and the biological integrity of El Encanto Creek.

Bike Path
The proposed bike path would serve as a continuation of an existing Class I trail that extends east of the project site and runs parallel to Cathedral Oaks Road, and would be constructed immediately north of Cathedral Oaks Road in the southern and southwestern portion of the project site, within arroyo willow thicket and black sage – California sagebrush scrub ESHA. The proposed bike path has been designed to follow an existing disturbed corridor to the extent possible. Construction of the proposed bike pat h would require continuous pruning of adjacent vegetation to prevent overgrowth onto the path, which would result in permanent impacts to ESHA.

However, the City of Goleta General Plan/Coastal Land Use Plan Policy CE 1.6 and Goleta Municipal Code Section 1 7.30.040, which provide protection for ESHA and ESHA buffers against development, allow for resource-dependent uses (including public accessways and trails) that are sited to avoid or minimize impacts on the resource to the maximum extent feasible. As desi gned, the proposed bike path would minimize impacts to habitat value or sensitive species to the maximum extent feasible from the existing configuration.

Detention Basin
Construction of the detention basin would result in impacts (vegetation removal and so il disturbance from grading) to arroyo willow thicket ESHA and black sage – California sagebrush scrub ESHA in the southwestern portion of the project site. This location was selected for the detention basin because it is the lowest elevation point on the project site, which allows gravity-fed drainage from the surrounding development without the need for pumps or 129
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
96 | P a g e

extensive underground infrastructure. The basin is designed to manage stormwater runoff and improve water quality, and is a resource-dependent ut ility that may be permitted within ESHA or buffers when no feasible alternative exists and when designed to minimize impacts. The basin would be located outside of the riparian corridor to the extent feasible. Locating the basin elsewhere on the project si te would require substantial regrading, increased disturbance to ESHA, or conflict with proposed residential lots and traffic circulation. Additionally, the southwestern corner of the project site is adjacent to El Encanto Creek, which is the natural recei ving water for stormwater in the area.

Grading and Building Construction
Grading on Lots 1, 2, and 58 would disturb the eucalyptus grove that serves as raptor roosting habitat ESHA. However, all of the eucalyptus trees in the study area are rooted on the a djacent golf course property, and the proposed project is not expected to require removal of any eucalyptus trees unless they are determined to be structurally unsound and pose a safety hazard to construction workers and future residents and their guests. Impacts would be limited to removal of ornamental trees and shrubs and ruderal vegetation beneath the eucalyptus tree canopy.

Impacts would include disturbances, such as vegetation removal and soil disruption during construction, to this sensitive natural community. Grading is not anticipated to result in removal or major impacts to protected trees within the ESHA or alter the surface hydrology or remove native vegetation within the ESHA buffer, as it would be limited to surface -level modifications that av oid tree root zones and alterations to drainage patterns. Grading on Lots 1, 2, and 58 would impact 7,811 square feet of eucalyptus grove due to grading and vegetation removal. Additionally, the proposed project would impact 685 square feet of eucalyptus g rove through habitat loss associated with permanent removal of understory vegetation associated with this ESHA.

Summary of Construction Impacts on ESHA
The proposed project would result in both indirect and direct impacts to riparian habitat types and sen sitive natural communities designated as ESHA. Indirect impacts would include adverse water quality effects, chemical spills or vehicle leaks near and within ESHA, and habitat destruction during construction. Direct impacts would include the following permanent impacts:

130
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
97 | P a g e

 Impacts to 378 square feet of black sage – California sagebrush scrub ESHA due to trenching for the new storm drain pipe;
 Impacts to 8,496 square feet of eucalyptus grove that serves as raptor roosting habitat ESHA due to development on Lots 1, 2, and 58 for the proposed detention basin and residential development; and
 Impacts to 125 square feet of arroyo willow thicket ESHA and 82 square feet of black sage – California sagebrush scrub ESHA due to construction of the new bike path.

In total, the proposed project would permanently impact approximately 9,081 square feet (0.21 acre) of ESHA. The overall project-related impact on riparian habitat and sensitive natural communities would be potentially significant.

Mitigation Measure BIO-3 would reduce potential impacts to riparian habitat and sensitive vegetation communities by requiring compensatory mitigation for habitat loss due to project development.

Mitigation Measures BIO-4 and BIO-7 would reduce potential indirect impacts to riparian habita t and sensitive vegetation communities during project construction by requiring biological monitoring during construction and construction worker environmental awareness training (BIO -4) and fencing around ESHA (BIO -7). Following the implementation of Mitigation Measures BIO-3, BIO-4, and BIO-7, the proposed project’s impact involving a substantial adverse effect on riparian habitat and sensitive vegetation communities would be less than significant with mitigation incorporated. (Revised Draft EIR, pp.

4.3-30 -- 4.3-33.)
MM BIO-7 Protection of Environmentally Sensitive Habitat Areas Construction methods shall include hand -trimming of vegetation rather than removal where feasible. The project applicant shall retain a City -approved, qualified biologist who sh all install temporary construction fencing between the ESHA area that would be disturbed (during installation of the new storm drain pipe, construction of the new bike path along Cathedral Oaks Road, grading in the southwestern corner of the project site t o construct the detention basin, and grading and building construction within eucalyptus grove along El Encanto Creek) and the adjacent ESHA to be protected.

The fencing shall be a minimum of 4 feet tall, attached to metal fence posts spaced no more than 8 feet apart, and shall include “Environmentally Sensitive Habitat Area – Keep Out” signage posted 131
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
98 | P a g e

at 20-foot intervals. The fencing and signage shall be installed prior to the start of construction activities and shall be maintained in an upright and funct ional condition for the duration of construction in these areas. No construction activities shall occur in the fenced ESHA designated to be protected.

Plan Requirements and Timing. Specification for hand-trimming of vegetation, as well as the location and specifications of the temporary construction fencing, shall be included in the final construction plans and reviewed by the City of Goleta’s Planning and Environmental Review Director, or designee, prior to issuance of Zoning Clearance for the grading permit. Fencing and signage shall be installed prior to any ground disturbance and maintained throughout the duration of construction activities in proximity to Environmentally Sensitive Habitat Area.

Monitoring. The qualified biologist shall install the fencing and signage prior to the start of construction and confirm proper installation by writing to the City of Goleta’s Planning and Environmental Review Director. The City of Goleta’s Planning and Environmental Review Director shall conduct periodic inspections to ensure vegetation is hand -trimmed where feasible and fencing remains in place and in good condition throughout construction.

3. Wetlands
Threshold: Would the Project have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Finding: Less than significant with mitigation incorporated . ( Revised Draft EIR, pp. 4.3-34 – 4.3-35.)
Explanation: Construction. No wetland resources occur on the project site, and no features on the project site meet the State or City wetland definition (i.e., do not support wetland soil, hydrology, or plants). El Encanto Creek, which is part of the Devereux Slough watershed, flows through the southwestern portion of the project site. The United States Geological Survey has mapped El Encanto Creek as having intermittent flow, although portions of the creek within the Glen Annie Golf Course and adjacent to the project site may have perennial flow 132
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
99 | P a g e

in normal to wet years due in part to surface or subsurface irrigation runoff from the Glen Annie Golf Course. No work would occur within El Encanto Creek, and no resources under the jurisdiction of USACE would be impacted by the proposed project. However, the proposed project would include the construction of a new bike path that would entail the permanent removal of arroyo willow thicket ESHA, which is identified as riparian habitat and a sensitive natural community potentially under the jurisdiction of CDFW and the Central Coast RWQCB. As a Condition of Approval, the City of Goleta would require the project applicant to coordinate with CDFW and the Central Coast RWQCB and obtain applicable permits (e.g., Lake and Streambed Alteration Agreement, Clean Water Act Section 401 Water Quality Certification) as determined appropriate by the resource agencies.

These permits would require the applicant to implement avoidance and minimization measure s, provide compensatory mitigation for permanent impacts to riparian habitat, and comply with all applicable water quality protection standards and habitat restoration requirements as specified by the permitting agencies. Although these permits would minim ize impacts by requiring avoidance and minimization measures, compensatory mitigation, and compliance with water quality and habitat restoration standards, impacts to this riparian habitat and potentially jurisdictional resource would nevertheless remain p otentially significant due to the direct, permanent removal of the riparian habitat. The proposed project would potentially result in indirect impacts to El Encanto Creek due to the potential to introduce sediment, construction debris, or pollutants (e.g., fuels, lubricants) into the creek during adjacent ground disturbance and equipment operation. Such contaminants could degrade water quality, harm aquatic habitat, and affect downstream resources within the Devereux Slough watershed. Risk of spills and wat er quality impacts would be reduced through implementation of standard construction BMPs specified in the SWPPP, such as erosion and sediment control BMPs designed to minimize erosion and retain sediment on -site, and good housekeeping BMPs to reduce the ri sk of spills, leaks, and off -site discharge of construction debris and waste. Therefore, indirect impacts to El Encanto Creek would be less than significant.

Mitigation Measure BIO -3 would reduce potential impacts to jurisdictional resources by requiring compensatory mitigation for habitat loss due to project development. Mitigation Measure BIO -4 would reduce potential indirect impacts to jurisdictional resources 133
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
100 | P a g e

during project construction by requiring biological monitoring during construction and constr uction worker environmental awareness training (BIO -4). Following the implementation of Mitigation Measures BIO-3 and BIO-4, the proposed project’s impact involving a substantial adverse effect on jurisdictional resources would be less than significant with mitigation incorporated. (Revised Draft EIR, pp.

4.3-34 – 4.3-35.)

4. Wildlife Movement
Threshold: Would the Project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Finding: Less than significant with mitigation incorporated . ( Revised Draft EIR, pp. 4.3-35 -- 4.3-37.)
Explanation: Noise (Construction)
Construction noise may affect es sential behavioral activities of wildlife, including through nest/roost abandonment, interference with behavior, permanent injury to the auditory system, or masking of important sounds or sound components. Short-term construction and long-term operational noise could affect western red bat, along with common migratory and resident wildlife. Animal species differ greatly in their response to noise of various characteristics and duration. An individual animal’s response to a given noise event or series of events also can fluctuate due to a variety of factors, including the time of day and year, the physical condition of the animal, the physical environment (such as whether the animal is restrained or unrestrained), the experience of the individual animal, and whether or not other physical stressors (e.g., drought) are present (Manci et al. 1988). Generally, sound levels above approximately 90 decibels are likely to be adverse to mammals and are associated with a number of behaviors such as retreat from the sound source, freezing, or a strong startle response (Manci et al. 1988). Noise levels above 75 decibels are known to be capable of producing adverse physiological effects in wildlife (Fletcher 1971). As discussed in Section 4.10, Noise, construction noise lev els may exceed Goleta’s 65 decibel construction noise standard, which could result in a potentially significant impact to wildlife movement. However, terrestrial wildlife migration is most pronounced during dusk, nighttime, and dawn. Construction activities would adhere to typical working hours in accordance with Section 17.39.070 of the City’s 134
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
101 | P a g e

Zoning Code, which limits construction activities from Monday to Friday, 7:00 a.m. to 4:00 p.m., and construction noise would not affect nocturnal terrestrial wildlife movement. Nevertheless, potential impacts on diurnal wildlife movement from construction-related noise would be potentially significant.

Following the implementation of Mitigation Measure NOI -1, the proposed project’s impact to wildlife movement would b e less than significant. (Revised Draft EIR, pp. 4.3-35 -- 4.3-37.)

5. Local Policies and Ordinances
Threshold: Would the Project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Finding: Less than significant with mitigation incorporated . ( Revised Draft EIR, pp. 4.3-41 -- 4.3-43.)
Explanation: The project would result in potentially significant impacts to special - status plants and special -status wildlife (Impact BIO -1), ESHA and other sensitive natural communities (Impact BIO -2), and aquatic resources (Impact BIO -3). Local policies or ordinances that protect biological resources that would pertain to the project include policies within the City of Goleta General Plan/Co astal Land Use Plan and Goleta Municipal Code. The proposed project would be consistent with the City of Goleta’s General Plan/Coastal Land Use Plan Policy CE 1.3, Site-Specific Studies and Unmapped ESHAs; Policy CE 1.8, ESHA Buffers; Policy CE 2.1, Design ation of Protected Creeks; Policy CE 2.5, Maintenance of Creeks as Natural Drainage Systems; Policy CE 8.1, ESHA Designation; Policy CE 8.2, Protection of Habitat Areas; Policy CE 8.3, Site -Specific Biological Resources Study; Policy CE 8.4, Buffer Areas f or Raptor Species; and Policy CE 9.1, Definition of Protection Trees.

Policy Inconsistency Related to ESHA Impacts
The proposed project would potentially be inconsistent with the City of Goleta General Plan/Coastal Land Use Plan Policy CE 1.6 (Protection of ESHAs) and Policy CE 5.3 (Protection of Coastal Bluff Scrub, Coastal Sage Scrub, and Chaparral ESHA), as well as Section 17.30.040 (Development and Mitigation of Impacts) of the Goleta Municipal Code. These policies and code section collectively prohibit development within ESHAs and their buffers unless the use is resource-dependent and no feasible alternative exists, and require 135
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
102 | P a g e

that any permitted encroachments be sited and designed to avoid or minimize impacts to the maximum extent feasible. The prop osed project would permanently impact 9,081 square feet (0.21 acre) of ESHA due to trenching, grading, and residential development on the project site. Policy CE 1.6 prohibits development within ESHAs and buffers unless the use is compatible with maintaining habitat values.

The proposed residential development and grading within the SPA buffer are not resource -dependent uses and therefore conflict with this policy. Policy CE 5.3 requires a minimum 25 -foot buffer around coastal sage scrub ESHA, which would b e encroached upon by the detention basin and bike path. The permanent loss of ESHA would result in a potential inconsistency with Policies CE 1.6 and CE 5.3 and Section 17.30.040 (Development and Mitigation of Impacts) of the Goleta Municipal Code. This im pact would be potentially significant.

Policy Inconsistency Related to SPA Impacts
The proposed project would potentially be inconsistent with the City of Goleta General Plan/Coastal Land Use Plan Policy CE 2.2 (Streamside Protection Areas) and Policy 2.3 (Allowable Uses and Activities in Streamside Protection Areas), as well as Section

17.30.070 (Streamside Protection Areas) of the Goleta Municipal Code. Pursuant to City of Goleta General Plan/Coastal Land Use Plan Policy CE 2.2, an SPA upland buffer associated with El Encanto Creek extends 100 feet on either side of the creek. Approxima tely

1.12 acres (49,148 square feet) of the El Encanto Creek SPA buffer occur on the project site. The project applicant would utilize a waiver under State Density Bonus Law (Government Code Section 65915) to encroach within the required 100 -foot-wide SPA upland buffer, which is established by General Plan/Coastal Land Use Plan Policy CE 2.2 and Goleta Municipal Code Section 17.30.070. The encroachment would allow the following activities within the SPA buffer on the western side of the project site:
 7,786 square feet of proposed residential development, which includes portions of the houses on proposed Lots 1 and 2, along with some or all the private rear yards of Lots 1 through 8;
 Trenching for a new, 90-foot-long storm drain pipe;
 11,283 square feet of proposed stormwater detention; and 136
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
103 | P a g e

 A meandering path, landscaping, and 65 linear feet of sidewalk.

General Plan/Coastal Land Use Plan Policy CE 2.2 and Goleta Municipal Code Section 17.30.070 allow for site -specific reductions to the 100-foot buffer under limited circumstances. A reduction may be granted only if the following two criteria are met: No feasible alternative siting for development exists that would avoid encroachment into the SPA upland buffer; and The proposed development would not resul t in significant adverse effects on streamside vegetation or the biotic quality of the stream.

The minimum allowable buffer width under a reduced SPA is 25 feet, and any reduction must be supported by substantial evidence demonstrating compliance with the above criteria. The proposed encroachments include resource -dependent utility use, public access improvements, and residential development. The storm drain pipe and stormwater detention basin are utility features designed to manage runoff and improve downs tream water quality. When sited and designed to avoid significant impacts to streamside vegetation and hydrology, such facilities may be considered consistent with SPA policies. The meandering path and public sidewalk are public access features that suppor t alternative transportation and recreational use. These are considered resource -dependent uses under General Plan/Coastal Land Use Plan Policy CE 1.6 and are conditionally allowed within SPA buffers when designed to minimize impacts on sensitive resources . The residential development and associated grading within the SPA buffer, including portions of Lots 1 through 8, are not resource -dependent uses. However, the proposed encroachment of residential structures and grading into the 100-foot SPA upland buffe r meets the two -part test for buffer reduction under General Plan/Coastal Land Use Plan Policy CE 2.2 and Goleta Municipal Code Section 17.30.070, as follows:

No Feasible Alternative Siting.

The proposed project would include affordable housing, and as such qualifies for a waiver under State Density Bonus Law (Government Code Section 65915) , including reducing SPA buffer requirements.

The waiver is necessary to accommodate the density and
configuration of the project. Site constraints, including the location of El Encanto Creek and other environmental setbacks, limit the developable area. Relocating the affected residential structures outside the SPA buffer would reduce the number of units or compromise site functionality, thereby conflicting with the pro ject’s 137
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
104 | P a g e

objectives to develop up to 56 residential units, expand the City’s housing stock consistent with the adopted 2023 –2031 Housing Element, and provide housing opportunities for extremely low, lower, and moderate income households to support compliance with Regional Housing Needs Allocation requirements. Therefore, no feasible alternative siting exists that would avoid buffer encroachment while meeting the project’s land use and housing objectives.

No Significant Adverse Effects on Streamside Resources
The encroachments would be limited in scale and would primarily occur outside the creek channel and riparian vegetation. The project would include stormwater management features (e.g., detention basin) that reduce runoff and protect water quality. Constru ction would include the implementation of BMPs to minimize erosion and sedimentation in accordance with the National Pollutant Discharge Elimination System Construction General Permit. As designed, the proposed project would not significantly degrade strea mside vegetation, hydrology, or habitat quality.

Therefore, the proposed encroachments are consistent with General Plan/Coastal Land Use Plan Policy CE 2.2 and Goleta Municipal Code Section 17.30.070. The proposed project would be
inconsistent with City of Goleta General Plan/Coastal Land Use Plan Policy CE 2.3, which specifically limits allowable uses in SPAs to resource-dependent activities. Residential development is not listed among the permitted uses, and is therefore considered inconsistent with this policy. While the proposed project would be inconsistent with Policy CE 2.3, such conflict does not inherently result in a significant environmental impact under CEQA. CEQA significance is determined by whether a conflict with a plan would lead to a substantial adverse physical change in the environment. In this case, the inconsistency is limited to the type of development (i.e., residential use) rather than the extent or severity of physical impacts, which are addressed through mitigation measures and site design.

The proposed residential development within the SPA buffer has been sited and designed to minimize impacts to riparian vegetation, would not involve protected tree removal, and would not result in significant degradation of streamside habitat or h ydrology.

Therefore, the proposed project’s impact involving conflicts with policies related to SPAs (Policies CE 2.2 and CE 2.3) would be less than significant.

Policy Inconsistency Related to Land Divisions
138
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
105 | P a g e

The proposed project would involve land divis ions for parcels within and adjacent to ESHA and would require development within ESHA or ESHA buffers, and would thus conflict with City of Goleta General Plan/Coastal Land Use Plan Policy CE 1.9 (Standards Applicable to Development Projects). Policy CE 1.9 establishes specific standards for development projects that may affect ESHA, including requirements to avoid ESHA impacts wherever feasible, maintain adequate buffers, and implement mitigation measures when avoidance is not possible. Policy CE 1.9(b) e xplicitly prohibits land divisions that would result in future development within ESHA or ESHA buffers unless the use is resourcedependent and sited to minimize impacts. The proposed project would include the subdivision of land and siting of residential l ots that would result in grading, landscaping, and construction within mapped ESHA and SPA buffer areas. These uses are not considered resource - dependent, and the resulting parcel configuration would permanently alter ESHA and reduce buffer integrity. Ther efore, the proposed project would conflict with the intent and requirements of Policy CE

1.9, which is designed to prevent incremental loss of sensitive habitat through subdivision and development. This impact would be potentially significant.

Policy Inconsistency Related to Protected Trees
The proposed project would potentially be inconsistent with the City of Goleta General Plan/Coastal Land Use Plan Policy CE 9.5, Mitigation of Impacts to Native Trees, as well as the City’s Urban Forest Management Plan and Goleta Municipal Code Chapter 15.09 (Grading, Erosion and Sediment Control) and its Appendix A (Grading Ordinance Guidelines for Native Oak Tree Removal). The City’s Urban Forest Management Plan emphasizes the preservation of native trees and outlines best practices for their protection during development. Goleta Municipal Code Chapter 15.09 (Grading, Erosion and Sediment Control) and its Appendix A (Grading Ordinance Guidelines for Native Oak Tree Removal) require that grading near native oaks be minimized and that protective measures, such as fencing, arborist oversight, and root zone preservation, be implemented during construction. While no native trees are located directly on the project site, three protected coast live oak trees have canopies and/or critical root zones that extend onto the project site.

Although the project would avoid direct removal or substantial disturbance of these trees, construction activities within their critical root zones could result in indirect impacts, such as soil com paction or root damage, if appropriate protection measures are not 139
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
106 | P a g e

implemented. Therefore, the proposed project would potentially conflict with City of Goleta’s General Plan/Coastal Land Use Plan Policy CE 9.5, the City’s Urban Forest Management Plan, and Goleta Municipal Code Chapter 15.09 (Grading, Erosion and Sediment Control), and the proposed project’s impact involving conflict with this policy would be potentially significant. (Revised Draft EIR, pp. 4.3-37 – 4.3-41.)
Mitigation Measures BIO -3, BIO-4, BIO-7 and BIO-8 are required.

Mitigation Measure BIO-3 would reduce potential permanent impacts to ESHA by requiring compensatory mitigation for habitat loss due to project development. Mitigation Measures BIO -4 and BIO -7 would reduce potential indirect impacts to riparian ESHA during project construction by requiring biological monitoring during construction and construction worker environmental awareness training (BIO -4) and fencing around ESHA (BIO-7). Mitigation Measure BIO-8 would reduce potential im pacts to protected trees by requiring implementation of tree protection measures during project construction activities. Following the implementation of Mitigation Measures BIO -3, BIO -4, BIO -7, and BIO -8, the proposed project would be consistent with the C ity of Goleta’s General Plan/Coastal Land Use Plan Policies CE 1.6, CE 5.3, and CE 9.5, as well as the City’s Urban Forest Management Plan, and Goleta Municipal Code Chapter 15.09 (Grading, Erosion and Sediment Control). The proposed project’s impact involving conflict with any local policies or ordinances protecting biological resources would be less than significant with mitigation incorporated. The proposed project would remain inconsistent with Policies CE 1.9 and 2.3; however, these inconsistencies are related to policy -level misalignments and the environmental impacts of development within ESHA and SPA buffers would be reduced to a less than significant level with implementation of the abovementioned mitigation measures, and thus would not result in a significant impact on the environment.

Mitigation Measure BIO-3 would reduce potential permanent impacts to ESHA by requiring compensatory mitigation for habitat loss due to project development. Mitigation Measures BIO -4 and BIO -7 would reduce potential i ndirect impacts to riparian ESHA during project construction by requiring biological monitoring during construction and construction worker environmental awareness training (BIO -4) and fencing around ESHA (BIO-7). Mitigation Measure BIO-8 would reduce pote ntial impacts to protected trees by requiring implementation of tree protection measures during project construction activities. Following the implementation of Mitigation 140
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
107 | P a g e

Measures BIO -3, BIO -4, BIO-7, and BIO -8, the proposed project would be consistent wi th the City of Goleta’s General Plan/Coastal Land Use Plan Policies CE 1.6, CE 5.3, and CE 9.5, as well as the City’s Urban Forest Management Plan, and Goleta Municipal Code Chapter 15.09 (Grading, Erosion and Sediment Control). The proposed project’s impact involving conflict with any local policies or ordinances protecting biological resources would be less than significant with mitigation incorporated. The proposed project would remain inconsistent with Policies CE 1.9 and 2.3; however, these inconsistencies are related to policy -level misalignments and the environmental impacts of development within ESHA and SPA buffers would be reduced to a less than significant level with implementation of the abovementioned mitigation measures, and thus would not result in a significant impact on the environment. (Revised Draft EIR, pp. 4.3-41 -- 4.3-43.)
MM BIO-8 Tree Protection Measures
The construction contractor shall implement the following tree protection measures to ensure that impacts to protected trees, including native coast live oak trees outside of the project site, are minimized to the extent feasible or avoided, consistent with the City of Goleta’s General Plan/Coastal Land Use Plan Policy CE 9.5, the City’s Urban Forest Management Plan, and Goleta Muni cipal Code Chapter 15.09 (Grading, Erosion and Sediment Control), prior to the start of project construction. The following tree protection measures shall be included within the project construction plans, including the grading and landscaping plans. All m easures below shall be conducted by or under the direct supervision of an International Society of Arboriculture (ISA) certified arborist retained by the project applicant:

Prior to Construction
 A certified arborist or qualified biologist under the supervision of the certified arborist shall monitor any ground disturbance, vegetation removal, and fencing installation activities that have a potential to impact the protected trees.
 Temporary fencing such as snow fencing, not less than 3 feet high with tree protection signs shall be erected around the three protected trees to be preserved that have a potential to be impacted during construction. The protective fence shall be installed at the protecte d zone boundary of each tree, which is defined as the critical root zone. The contractor shall 141
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
108 | P a g e

maintain the fence to keep it upright, taut and aligned during active construction. Fencing shall be in place and inspected by a City approved biologist prior to the start of activities with the potential to impact protected trees. Fencing shall be removed only after all construction activities with the potential to impact the protected trees are complete.
 A pre -construction meeting shall be held between all contractors (including grading, tree removal/pruning, builders, etc.) and the project arborist. The meeting shall focus on instructing the contractors on tree protection practices. All equipment operator s and spotters, assistants, or those directing operators from the ground shall provide written acknowledgement of their receiving tree protection training.

This training shall include information on the location and marking of the protected trees, the nece ssity of preventing damage, and the discussion of work practices that will
accomplish such.

Protection and Maintenance During Construction
 Contractors shall avoid heavy equipment operations, grade changes, ponding water, and fill or compaction within the protected tree zone unless where specifically approved and under the supervision of a certified arborist or qualified biologist in direct communication with the certified arborist.  Contractors shall ensure that damage to the tree be avoided to the extent f easible when transporting or moving
construction materials and working within or adjacent to the protected zone). If contact with the tree crown is unavoidable, affected branches may be pruned by a qualified arborist under supervision of a certified arbori st and shall adhere to industry standards.
 Except where specifically approved in writing beforehand, all trenching shall be done outside of the fenced protected zone.

Where trenching is necessary in areas that contain roots from retained trees, contractors should use trenching techniques that include the use of either a root pruner or an Air-Spade to limit root impacts. A certified arborist or qualified biologist in direct communication with the certified arborist shall ensure that all pruning cuts be clean and sharp to minimize ripping, tearing, and fracturing of the root system. Use of both root - pruning and AirSpade equipment shall be accompanied only 142
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
109 | P a g e

by hand tools to remove soil from trench locations. The trench should be made no deeper than necessary, an d when
possible, alternatives to trenching should be utilized.  The contractor shall be responsible for irrigating (deep watering) the trees in the summer and fall irrigation as necessary and determined by a certified arborist. One
irrigation cycle shall t horoughly soak the root zones of the trees to a depth of two feet. The soil shall be allowed to dry out between watering to avoid keeping consistently wet soil.

Soil moisture shall be checked with a soil probe before irrigating. The area within three feet of the trunk shall never be soaked, especially in summer months.
 If any protected trees are damaged to the point where continued viability is threatened, as determined by a certified arborist, the tree shall be replaced at a 3:1 ratio with like species grown from locally obtained seed. Replacement shall occur on site as feasible, or off site (within the same watershed) if on site replacement is not feasible.

Replacement trees shall be monitored for a period of five years.

Maintenance After Construction
 The contractors shall ensure that the mulch is kept a minimum one foot away from the trunk base and no more
than 8 inches deep to avoid creating conditions favorable to the establishment and growth of decay -causing fungal
pathogens.

Plan Requirements and Timing.

The project applicant shall submit the construction plans that include the tree protection measures to the City of Goleta’s Planning and Environmental Review Director for review and approval prior to issuance of Zoning Clearance for the grading permit.

Monitoring.

The City of Goleta’s Planning and Environmental Review Director, or designee, shall review and approve the construction plans to ensure this measure is included. The City of Goleta’s Planning and Environmental Review Director, or designee , shall approve the arborist prior to Zoning Clearance for the grading permit. 143
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
110 | P a g e

B. CULTURAL RESOURCES

1. Archaeological Resources
Threshold: Would the Project cause a substantial adverse change in the significance of an archaeological resource pursuant to S tate CEQA Guidelines, section 15064.5?
Finding: Less than significant with mitigation incorporated . ( Revised Draft EIR, pp. 4.4-13 -- 4.4-16.)
Explanation: No prehistoric archaeological materials were recovered during the excavation of three shovel probes within the mapped CA-SBA-1735 boundary. The results of the previous Phase 1 survey of the project site, the supplemental survey of the northern third of the project site with systematic shovel scrapes, and the three shovel probes, revealed no archaeological resources located within the project site (Dudek 2011).

Project-related ground disturbance would occur throughout the

14.38-acre site during demolition of existing structures, grading for 56 new residential lots, and installation of utilities and other infrastructure. Grading would involve approximately 27,500 cubic yards of cut and 23,500 cubic yards of fill. Excavation for utilities and stormwater facil ities would extend several feet below the current ground surface, including installation of two 18-inch storm drains, an underground detention system, and a detention basin in the western portion of the site. Portions of the proposed project would also encroach into the 100-foot Streamside Protection Area buffer along El Encanto Creek, where native soils are most likely to remain intact.

Although the project site has been subject to previous disturbance from orchard removal and residential development, the proposed depths and area of excavation for utilities, stormwater systems, and grading would likely extend into previously undisturbed native soils.

While there are no known archaeological resources present on the project site, the potential remains for un known resources to be present. Should currently unknown archaeological resources be present onsite, they are most likely to occur in the intact and undisturbed soil rather than in previously disturbed fill. The combination of the proposed ground disturbanc e and the project site’s location in a culturally sensitive area increases the potential for encountering unknown archaeological materials.
144
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
111 | P a g e

While prior testing and surveys revealed no archaeological deposits, the possibility of unanticipated discoveries c annot be ruled out. If such materials qualify as unique archaeological resources under CEQA, their disturbance would constitute a substantial adverse change in significance. Therefore, impacts to archaeological resources would be potentially significant.

Mitigation Measures CUL-1 through CUL-3 would minimize potential impacts to unanticipated discoveries of archaeological resources by requiring archaeological monitoring, a cultural resources sensitivity training for construction personnel, and implementat ion of appropriate procedures for evaluation and treatment of any discoveries made during construction. Therefore, implementation of Mitigation Measures CUL -1 through CUL -3 would reduce potential impacts to archaeological resources to a less than significa nt level. (Revised Draft EIR, pp. 4.4-13 -- 4.4-16.)
MM CUL-1 Archaeological Monitoring
Prior to ground disturbance activities, the project applicant shall retain an archaeologist who meets the Secretary of the Interior’s Professional Qualification Stan dards (qualified archaeologist) and has experience in California prehistoric and historic resources (experience within City of Goleta or Santa Barbara County preferred). The project applicant shall provide proof of retainment of the qualified archaeologist to the City of Goleta’s Planning and Environmental Review Director, or designee, prior to the issuance of Zoning Clearance for the grading permit. The qualified archaeologist shall prepare a Cultural Resource Monitoring and Inadvertent Discovery Plan, conduct archaeological monitoring, and address any inadvertent discoveries identified during project implementation (refer to Mitigation Measure CUL -4). The City of Goleta’s Planning and Environmental Review Director, or designee, shall review and approve the Plan prior to the issuance of Zoning Clearance for the grading permit. The Plan shall outline archaeological and Native American resource monitoring protocols, as well as a program for treatment and mitigation in the case of an inadvertent discovery of cultural resources during project -related ground -disturbance. The Plan shall also provide for the proper identification, evaluation, treatment, and protection of any cultural resources in accordance with CEQA throughout the duration of the project. The Plan shall be incorporated and referenced in all grading and construction plans intended for use by the construction contractor(s). The qualified archaeologist shall manage archaeological monitoring during initial ground disturbance activities, defined as const ruction-related earth 145
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
112 | P a g e

moving of sediments from their place of deposition. This definition excludes movement of sediments after they have been initially disturbed or displaced by project -related construction. The qualified archaeologist shall oversee and es tablish monitoring efforts as needed (increase, decrease, or discontinue monitoring frequency) based on the observed potential for construction activities to encounter cultural deposits or material. The qualified archaeologist shall ensure all daily monito ring logs are maintained. The requirement for archaeological monitoring shall be noted on all demolition and grading plans. The qualified archaeologist shall prepare an archaeological monitoring report within 60 days following completion of ground disturba nce, and shall submit the archaeological monitoring report to the City of Goleta’s Planning and Environmental Review Director, or designee, for review. The archaeological monitoring report shall document compliance with approved cultural resource mitigatio n measures, include all monitoring efforts, and include an appendix with the daily monitoring logs. The qualified archaeological shall submit the final archaeological monitoring report to the City of Goleta’s Planning and Environmental Review Director and the Central Coast Information Center.

Plan Requirements and Timing. Prior to ground disturbance, the project applicant shall retain a qualified archaeologist. The qualified archaeologist shall create a Plan, conduct monitoring, and address any discoveries during project construction. Proof of retainment shall be provided to the City of Goleta’s Planning and Environmental Review Director prior to the issuance of Zoning Clearance for the grading permit. The Plan shall outline monitoring protocols and treatment for any discovered cultural resources, ensuring compliance with CEQA. The Plan shall be referenced in all grading and construction plans. The City of Goleta’s Planning and Environmental Review Director, or designee, shall review and approve the Plan pri or to the issuance of Zoning Clearance for the grading permit.

Monitoring. The qualified archaeologist shall manage monitoring during initial ground disturbance, adjusting efforts (decrease, increase, or terminate) based on the potential to encounter cultu ral deposits. Daily monitoring logs shall be maintained. The qualified archaeologist shall prepare an archaeological monitoring report, documenting compliance and monitoring efforts, and shall submit the archaeological monitoring report to the City of Goleta’s Planning and Environmental Review Director, or designee, for review, within 60 146
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
113 | P a g e

days following completion of ground disturbance. The qualified archaeological shall submit the final archaeological monitoring report to the City of Goleta’s Planning and E nvironmental Review Director and the Central Coast Information Center.

MM CUL-2 Worker Environmental Awareness Program Training All construction personnel and monitors who are not trained archaeologists shall be briefed regarding unanticipated discoveries of archaeological resources prior to the start of construction activities as part of a Worker Environmental Awareness Program (W EAP) training. A basic presentation shall be prepared and presented by the qualified archaeologist, or their designee, to inform all construction personnel working on the project about the archaeological sensitivity of the area. The purpose of the WEAP tra ining is to provide specific details on the kinds of archaeological materials that may be identified during construction and explain the importance of and legal basis for the protection of the event archaeological resources or human remains are uncovered during ground-disturbing activities.

These procedures include work curtailment or redirection, and the immediate contact of the qualified archaeologist and if appropriate, Native American representative. If new construction personnel are added to the proje ct, the crew foreman shall ensure the new personnel receive the WEAP training before starting work. The necessity of training attendance shall be stated on all demolition, grading, or construction plans and the project applicant shall maintain records demo nstrating construction worker WEAP participation. The project applicant shall submit the records of construction worker WEAP participation to the City of Goleta’s Planning and Environmental Review Director prior to construction activities and as needed aft er the addition of new personnel. Plan Requirements and Timing. This measure shall be incorporated into the grading, demolition, and construction plans and the WEAP shall be available on -site during construction. Monitoring. Records of construction worker WEAP participation shall be kept on file with the City of Goleta’s Planning and Environmental Review Director for the duration of construction.

MM CUL-3 Unanticipated Discovery of Cultural Resources If unanticipated cultural resources are discovered du ring project - related ground disturbance, the following procedures shall be implemented:
147
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
114 | P a g e

 The construction contractor(s) shall halt work within 50 feet of the find and notify the qualified archaeologist. Temporary fencing must be erected (e.g., orange tempor ary fence) to prevent damage to the resource along the 50-foot buffer. The qualified archaeologist retained pursuant to Mitigation Measure CUL-2 shall immediately evaluate the resource.
 If the resource is determined to be potentially significant, then the qualified archaeologist, project applicant, Native
American monitor (if resources are Native American in
origin), and City of Goleta’s Planning and Environmental Review Director, or designee, shall meet to discuss the significance of the find. At the meet ing, a decision shall be made, with the concurrence by the City of Goleta’s Planning and Environmental Review Director, or designee, as to the appropriate mitigation (documentation, recovery, avoidance, etc.) for the cultural resource.
 Treatment and avoid ance of the newly discovered
resource(s) shall be consistent with the Plan prepared
pursuant to Mitigation Measure CUL -1. This may include avoidance of the cultural resources through project design, in-place preservation of cultural resources located in na tive soils, and/or re-burial within the immediate vicinity so they are not subject to further disturbance in perpetuity. If avoidance is infeasible, then treatment shall be implemented pursuant to the Plan. The City of Goleta’s Planning and Environmental Review Director, or designee, shall make the final
determination based on the provisions of CEQA with respect to archaeological resources and recommendations of the
qualified archaeologist.
 Further ground disturbance, including but not limited to grading and trenching, shall not resume within the area of the discovery until the City of Goleta’s Planning and
Environmental Review Director, or designee, has determined the appropriate mitigation has been implemented pursuant to the Plan and the qualified archae ologist has notified the construction contractor(s) to resume work. Work shall be allowed to continue outside of the 50 -foot buffer area and shall be monitored by additional archaeological monitors, if necessary.
148
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
115 | P a g e

 If the resource proves to be eligible for the CRHR and significant impacts to the resource cannot be avoided via project redesign, the qualified archaeologist shall prepare a data recovery plan tailored to the physical nature and
characteristics of the resource, pursuant to the requirements of the CEQA Guidelines Section 15126.4(b)(3)(C). The data recovery plan shall identify data recovery excavation
methods, measurable objectives, and data thresholds to
reduce any significant impacts to cultural resources related to the resource. The City of Golet a’s Planning and
Environmental Review Director, or designee, shall review and approve the treatment plan and archaeological testing as appropriate. The qualified archaeologist shall submit the resulting documentation to the regional repository of the California Historical Resources Information System pursuant to CEQA Guidelines Section 15126.4(b)(3)(C).
 The qualified archaeologist shall provide evidence of compliance with this mitigation measure, if a significant archaeological resource is found, to the Ci ty of Goleta’s Planning and Environmental Review Director and the
appropriate California Historical Resources Information System Information Center upon completion of the data
recovery plan detailing the significance of the resource and treatment findings.

Plan Requirements and Timing . If unanticipated cultural resources are discovered during ground disturbance, the construction contractor(s) shall halt work within 50 feet of the find and contact the qualified archaeologist. The qualified archaeologist shall evaluate the resource immediately. If the resource is potentially significant, the qualified archaeologist, project applicant, Native American monitor (if applicable), and City of Goleta’s Planning and Environmental Review Director, or designee, shall m eet to decide on appropriate mitigation.

Treatment and avoidance shall follow the Plan from Mitigation Measure CUL -2. The City of Goleta’s Planning and
Environmental Review Director, or designee, shall make the final determination based on CEQA provisions. Ground
disturbance shall not resume in the area until the City of Goleta’s Planning and Environmental Review Director, or designee, has verified that mitigation is implemented. Work outside the 50 -foot buffer shall continue with additional monitoring if n ecessary. Monitoring. The City of Goleta’s 149
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
116 | P a g e

Planning and Environmental Review Director, or designee, shall review and approve the data recovery plan (if
applicable). The qualified archaeologist shall submit
documentation to the California Historical Resourc es
Information System. The qualified archaeologist shall provide evidence of compliance to the City of Goleta’s Planning and Environmental Review Director and the California Historical Resources Information System upon completion.

C. GEOLOGY AND SOILS

1. Fault Rupture
Threshold: Would the Project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic shaking?
Finding: Less than significant impact with mitigation incorporated . (Revised Draft EIR, p. 4.5-9.)
Explanation: Seismic Shaking . The project site is located within a seismically active region of southern California and is subject to strong ground shaking during a major earthquake. Although no active faults cross the property, several regional faults are capable of producing large seismic events that could affect the site. The proposed project would be required to comply with the CBC seismic design provisions, which establish minimum structural standards to reduce the risk of damage or collapse during an earthquake. Nevertheless, the project site may experience strong ground shaking during a major earthquake, which could result potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking. This impact would be potentially significant. Implementation of Mitigation Measure GEO -1 would reduce potential impacts due to
groundshaking on the project site to a less than significant level through incorporation of structur al integrity recommendations into the project, which would ultimately minimize the potential for the risk of loss, injury, or death involving strong seismic ground shaking.

Landslides. The northern portion of the project site is mapped within an area of h igh landslide potential, and the Rincon Formation underlying this area is susceptible to slope instability. The proposed project includes grading to create level building pads, with cut slopes up to approximately 14 feet high and combined cut slopes up to 18 feet high in the northern portion of the site. The proposed project includes development in an area identified as having a high landslide 150
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
117 | P a g e

risk, includes development on slopes exceeding 20 percent.

Proposed project construction would include cut slopes exceeding a grade of 1.5 horizontal to 1 vertical and a cut slope over 15 feet in height as measured from the lowest finished grade. These construction techniques would result in steep slopes that could increase the risk of a landslide occurring. Therefore, the proposed project’s impact related to the risk of loss, injury, or death involving landslides would be potentially significant. Implementation of Mitigation Measure GEO -1 would reduce potential impacts due to landslides on the project site to a less th an significant level through incorporation of slope stability recommendations into the project, which would ultimately minimize the potential for the risk of loss, injury, or death involving landslides. (Revised Draft EIR, p. 4.5-9.)

MM GEO-1 Geotechnical Design
The applicant’s project design engineer shall incorporate the recommendations within of the Geotechnical Investigation prepared for the project into the project’s grading and building plans. These include, but are not limited to, requiring existing fill and soft material to be excavated to firm native soil, the use of cut pads for compaction control, and the use of piers for stability of the residences. The applicant shall submit the grading and building plans to the Planning and Environmental Rev iew Director or designee for review and approval prior to issuance of a Zoning Clearance for the grading and building permits for the project. The applicant shall also retain a licensed geotechnical professional approved by the Planning and Environmental R eview Director or designee prior to the start of construction. The licensed geotechnical professional shall be responsible for ensuring proper implementation of the
recommendations within the final Geotechnical Investigation prepared for the project and pr oviding a report to the Planning and Environmental Review Director or designee certifying the recommendations below have been incorporated into project design and throughout construction prior to the issuance of a certification of occupancy.

Plan Requirements and Timing. Grading and building plans shall be submitted for review and approval by the Planning and Environmental Review Director or designee before the City issues a Zoning Clearance for the grading and building permits. The Planning and Environmental Review Director or designee shall approve the licensed geotechnical professional prior to the start of construction.

The licensed geotechnical professional shall submit the report to the 151
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
118 | P a g e

Planning and Environmental Review Director or designee certifying the recommendations have been incorporated prior to the issuance of a certification of occupancy.

Monitoring. Once during the grading phase of construction, the Planning and Environmental Review Director or designee shall visit the project site to confirm with the licensed geotechnical professional that the construction contractor is implementing the applicable geotechnical recommendations.

2. Unstable Soils
Threshold: Would the Project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on - or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
Finding: Less than significant with mitigation incorporated . ( Revised Draft EIR, pp. 4.5-12 – 4.5-13.)
Explanation: Subsurface investigations of the project site did not identify groundwater underneath the project site to a depth of 51 feet.

Accordingly, construction activities would not require groundwater dewatering, and the proposed project construction would not induce subsidence. Project operation would not involve groundwater pumping on -site and therefore would not result in subsidence.

Testing of on -site soils indicate that the site soils are dense and cohesive; therefore, the potential for collapse or subsidence is considered negligible and the proposed project would not risk collapse. However, the project site is subject to landslide risk, and project construction would involve the creation of steep slopes that could increase the potential for a landslide to occur. Accordingly, this impact would be potentially significant.

Implementation of Mitigation Measure GEO-1 would reduce potential impacts due to landslides on the project site to a less than significant level through incorporation of slope st ability recommendations into the project, which would ultimately minimize the potential for on - or off-site landslides to occur. (Revised Draft EIR, pp. 4.5-12 – 4.5-13.)

3. Expansive Soils
Threshold: Would the Project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code, creating substantial risks to life or property?
152
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
119 | P a g e

Finding: Less than significant with mitigation. (Revised Draft EIR, p. 4.5-13.) Explanation: Expansive soils are present across the project site, particu larly in near-surface deposits. Laboratory testing of representative samples yielded Plasticity Index values of 50 and 53, and an Expansion Index of 90, which indicate high to critical expansion potential consistent with expansive clay soils as defined in Table 18-1-B of the Uniform Building Code (Appendix E). The proposed project would be subject to the requirements of the CBC, which includes design standards for construction on expansive soils; however, given the high expansion potential of soils underlyi ng the project site, the proposed project could still create a risk to life or property related to expansive soils.

This impact would be potentially significant.

Mitigation Measure GEO -1 would reduce potential impacts due to expansive soils on the project site to a less than significant level through incorporation of structural integrity recommendations into the project, which would ultimately minimize the potential for expansive soils to result in risks to life or property. (Revised Draft EIR, p. 4.5-13.)

4. Paleontological Resources
Threshold: Would the Project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? Finding: Less than significant with mitigation incorporated . ( Revised Draft EIR, pp. 4.5-14 -- 4.5-16.)
Explanation: The paleontological sensitivity of the artificial fill and Pleistocene - aged alluvium is undetermined greater than two feet below the ground surface. The paleontological sensitivity of the Rincon Formation is high greater than two fe et below ground surface. The proposed project’s construction activities include ground -disturbing activities (i.e., grading, excavating, trenching) which would require grading to a depth of up to eight feet. Such activities would occur greater than two feet below ground surface of the Pleistocene -aged alluvium and Rincon Formation, which could directly or indirectly destroy a unique paleontological resource or site or unique geologic feature. This impact would be potentially significant.

Mitigation Measure GEO-2 would reduce potentially significant impacts to paleontological resources to a less than significant level through construction monitoring and construction personnel training to ensure that paleontological resources that may be encountered 153
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
120 | P a g e

during construction are collected and curated in a designated fossil repository. (Revised Draft EIR, pp. 4.5-14 -- 4.5-16.)
MM GEO-2 Paleontological Resources Mitigation
Qualified Professional Paleontologist. Prior to excavation, the project applicant shall re tain a Qualified Professional Paleontologist, as defined by the Society of Vertebrate Paleontology (SVP 2010), who shall direct all mitigation measures related to paleontological resources. Selection of the Qualified Professional Paleontologist shall be subject to review and approval by the City.

Worker Environmental Awareness Program . Prior to the start of construction, the Qualified Professional Paleontologist or their designee shall conduct a paleontological Worker Environmental Awareness Program (WEAP) training for construction personnel regarding the appearance of fossils and the procedures for notifying paleontological staff should fossils be discovered. The names of all onstruction personnel who have received this training shall be recorded and provided to the City upon request.

Paleontological Monitoring and Salvage. Paleontological monitoring shall be conducted by a paleontological monitor with experience with collection and salvage of paleontological resources and who meets the minimum standards of the SVP (2010) for a Paleontological Resources Monitor. Paleontological monitor ing shall occur during ground-disturbing activities that would disturb previously undisturbed sediments greater than two feet deep (e.g., grading, excavation, drilling of greater than two feet in diameter) throughout the entire project site. Monitoring sha ll consist of twice -per-week monitoring visits.

Based on geological observations or the construction schedule, the Qualified Professional Paleontologist may recommend that monitoring be increased or reduced in frequency or ceased entirely, and such decisi ons shall be subject to review and approval by the City.

In the event of a fossil discovery by the paleontological monitor or construction personnel, all construction activity within 50 feet of the find shall cease, and the Qualified Professional Paleonto logist shall evaluate the find. If the fossil(s) is (are) not scientifically significant, then construction activity may resume. If it is determined that the fossils may be scientifically significant, the following shall occur:
154
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
121 | P a g e

 Fossil Salvage. The fossil shall be salvaged (excavated and collected) to protect it from damage/destruction. Typically, fossils can be safely salvaged quickly by a single paleontological monitor with minimal disruption to construction. Larger fossils may require more extensive salv age operations. After fossil salvage is complete, construction activity within the area may resume.
 Fossil Preparation and Curation. Fossils shall be identified to the lowest (most -specific) possible taxonomic level, prepared to a curation-ready condition , and curated in a fossil repository per SVP (2010) standards, such as the Santa Barbara Museum of Natural History, along with all pertinent data, photos, and/or maps required by the repository.
 Final Paleontological Mitigation Report. Upon completion of ground-disturbing activities (or preparation and curation of fossils, if necessary), the Qualified Professional Paleontologist shall prepare a final report describing the paleontological mitigation program’s results. The report shall include a summary of the field and laboratory methods employed; an overview of project geology; and, if applicabl, an analysis of the recovered fossils, including physical description, taxonomic identification, and scientific significance. The report shall be submitted to the C ity and, if fossil curation occurred, the designated fossil repository.

Plan Requirements and Timing . The Planning and
Environmental Review Director or designee shall approve the Qualified Professional Paleontologist prior to the issuance of a Zoning Clearance for a grading permit. The qualified professional paleontologist shall conduct WEAP training pri or to the start of ground-disturbing activities and submit a signed form to the Planning and Environmental Review Director within 24 hours following the completion of WEAP training. The Qualified Professional Paleontologist or designated paleontological resource monitor shall observe grading and drilling activities throughout undistributed construction areas on -site on a twice - per-week monitoring schedule. If a fossil is discovered, the qualified professional paleontologist shall submit the Final Paleontological Mitigation Report to the Planning and
Environmental Review Director or designee within 90 days of completion of salvage and preparation. If curation occurred, the qualified professional paleontologist shall also submit the Final Paleontological Mitigation Report to the Santa Barbara Museum 155
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
122 | P a g e

of Natural History.

Monitoring. The Planning and Environmental Review Director or designee shall review and approve the form provided by the qualified professional paleontologist certifying WEAP training was complet ed. The Planning and Environmental Review
Director or designee shall confirm the Qualified Professional Paleontologist or designated paleontological resource monitor observed grading and drilling activities. The Planning and Environmental Review Director o r designee shall review and approve the Final Paleontological Mitigation Report, if applicable.

D. HAZARDS AND HAZARDOUS MATERIALS

1. Accident or Upset
Threshold: Would the Project create a significant hazard to the public or the environment through reasonabl y foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Finding: Less than significant with mitigation incorporated . ( Revised Draft EIR, pp. 4.7-15 -- 4.7-19.)
Explanation: Construction
Hazardous Materials in Existing Structures
There is no evidence that PCB contamination exists on -site, and based on the age of the residence, garage, and barn on -site, there is limited potential for mercury to be located within these structures.

Any poten tial sources of mercury (i.e., thermostats, gas pressure regulators, etc.) would be identified and removed prior to demolition in accordance with California Code of Regulations Title 8, Section 1735. Accordingly, the potential for hazards involving the rel ease of mercury during demolition would be less than significant. However, based on the age of the residence, garage, and barn on -site, there is potential for the structures to contain ACM and LBP. Considering the proposed project would involve the demolit ion of the residence, garage, and barn, proposed demolition activities have the potential to result in accidental release of ACM or LBP, which would create a potentially significant hazard to both construction workers and the environment. In California, an y facility known to contain ACMs is 156
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
123 | P a g e

required to have a written asbestos management plan (also known as an Operations and Maintenance Program).

SBCAPCD enforces the Asbestos National Emission Standards for Hazardous Air Pollutants, which regulates the cont rol of asbestos during the renovation and demolition of buildings under the federal Clean Air Act. Additionally, Cal/OSHA Title 8, Section 1529 sets requirements for asbestos exposure assessments and monitoring, methods of complying with exposure requireme nts, safety wear, communication of hazards, and medical examination of workers.

Similarly, the removal of LBP-containing materials would be subject to specific and detailed Cal/OSHA requirements to ensure proper containment, handling, notification, and mon itoring, and removal would be performed by a licensed LBP abatement contractor.

Cal/OSHA Title 8, Section 1532.1 requires testing, monitoring, containment, and disposal of lead -based materials such that exposure levels do not exceed Cal/OSHA standards. Under this rule, construction workers may not be exposed to lead at concentrations greater than 50 micrograms per cubic meter of air averaged over an eighthour period, and exposure must be reduced to lower concentrations if the workday exceeds eight hours. Fu rthermore, as required by CCR Title 17, Section 36100, the project applicant would be required to submit Form 8551 to CDPH prior to performing lead hazard abatement, which would require information related to the structure, construction activities, and construction restrictions. While the potential removal of ACMs and LBP from the residence, garage, and barn would be subject to applicable laws and regulations enforced by SBCAPCD, Cal/OSHA, and CDPH, construction
activities would nevertheless have the potential to create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of ACMs or LBP into the environment if these materials are mishandled during demolition without proper monitoring from local agencies. This impact would be potentially significant.

Implementation of Mitigation Measures HAZ -1 and HAZ -2 would reduce potential hazardous material impacts associated with accidental releases of hazardous materials during demolitio n of the existing residence, garage, and barn to a less-than-significant level. (Revised Draft EIR, pp. 4.7-15 -- 4.7-19.)
MM HAZ-1 Asbestos-Containing Materials Abatement
Prior to the issuance of Zoning Clearance associated with the demolition perm it, the project applicant shall prepare an asbestos 157
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
124 | P a g e

abatement plan addressing the items/topics listed below. The asbestos abatement plan shall be reviewed and approved by SBCAPCD. Proof of SBCAPCD approval shall be provided to the City of Goleta’s Planning and Environmental Review Director, or designee. During project construction and demolition activities, the project applicant shall follow the measures outlined in the asbestos abatement plan, which shall be undertaken by properly trained and licensed asbe stos contractors currently registered with Cal/OSHA and/or OSHA (herein referred to as “abatement contractors”).

Abatement contractors shall be selected and vetted by the project applicant and reviewed by SBCAPCD ten working days prior to starting demoliti on as part of the Notification for Renovation and Demolition Form ENF-28 submittal. Project-specific requirements to be addressed in the asbestos abatement plan include the following:
 Disturbance activities shall be performed only by abatement contractors using appropriate controls to prevent fiber emissions during the removal process. This may include, but is not limited to, the use of wet methods (water mist), negative pressure containment, high efficiency particulate air filtration, and other engineering controls, as deemed appropriate, to keep fibers from being dispersed in accordance with current federal, state, and local regulations. Presumed asbestos containing roofing materials s hall be sampled by abatement contractors prior to demolition to determine proper handling and disposal requirements.
 Windows with trace (defined as less than 1 percent) asbestos in putty shall be removed intact to avoid disturbance of the putty, if possible. Other materials with trace asbestos shall be point counted to determine the asbestos concentrations; if asbestos concentrations are not determined, these materials shall be managed as ACMs.
 Workers performing removal shall be properly protected to prevent exposure, including the use of respiratory protection with high efficiency particulate air filtration, protective suits, or other protective equipment deemed necessary by abatement contractors. Disturbance of greater than 100 square feet of any ACMs or asbestos-containing construction materials must be performed by trained and licensed abatement contractors.  Asbestos containing waste materials must be properly
contained and transported for off -site disposal at a permitted 158
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
125 | P a g e

landfill or disposal facility. Friable asbestos with greater than 1 percent asbestos content is considered hazardous waste per current federal and state regulations and must be
transported and disposed of using proper manifest
documentation. Non-friable asbestos is categorized as non - hazardous, asbestos containing waste and can typically be disposed to the local Class III landfill with prior approval from landfill operators. As noted, materials with less than 1 percent total asbestos can be disposed of as construction debris if proper lab analysis is provided.
 Proper removal techniques must be followed to prevent the dissemination of asbestos fibers. All required notification and permitting shall be administered by the abatement contractor, and proper completion shall be verified by th e City’s Director of Planning and Environmental Review.
 If suspect materials are found during site work, the area shall be isolated, and any suspect materials tested to confirm or deny the presence of asbestos, lead, or other hazards, as determined appropriate by the abatement contractor.

MM HAZ-2 Lead-Based Paint Abatement
Prior to the issuance of Zoning Clearance associated with the demolition permit, the project applicant shall prepare an LBP abatement plan. This plan can be combined with the plan required in Mitigation Measure HAZ -1. The LBP abatement plan shall be reviewed and approved by the City of Goleta’s Planning and Environmental Review Director, or designee. Approval of the LBP abatement plan by the City of Goleta’s Planning and Environmental Review Director, or designee, shall be based on the plan’s demonstrated c ompliance with applicable federal, state, and local regulations, including California Department of Public Health and California Division of Occupational Safety and Health requirements.

The plan shall clearly identify the use of certified abatement contractors, describe lead -safe work practices (e.g., containment, wet methods, dust suppression), and outline procedures for waste segregation, characterization, and disposal in accordance with hazardous waste thresholds. The plan shall also include site-specific measures to prevent off -site migration of lead dust or debris, and provide documentation of California Department of Public Health notification and contractor qualifications
159
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
126 | P a g e

During proposed project construction and demolition activities, the project app licant shall follow the measures outlined in the LBP abatement plan. These requirements shall be undertaken by properly trained contractors that utilize lead -safe work practices (or “abatement contractors”). Abatement contractors shall be selected and vett ed by the project applicant and reviewed by the City of Goleta’s Planning and Environmental Review Director. Prior to abatement, the applicant shall notify California Department of Public Health of lead -based abatement activities through submittal of California Department of Public Health Form 8551, and provide evidence of the notification to the City of Goleta’s Planning and Environmental Review Director or designee. Project -specific requirements of the LBP abatement plan include the following:
 Any disturbance by abatement contractors that might generate dust or create a lead exposure hazard shall be performed by lead- trained workers using lead -safe work practices. Lead safe work practices include appropriate containment, wet methods, and use of hand tools or similar methods that will minimize the generation of airborne dust emissions and potential lead hazards.
 To prevent lead exposure hazard due to the generation of lead dust and debris, lead-painted components (e.g., windows, doors, baseboards) or simil ar lead -containing items shall be removed intact and segregated from the overall waste stream by
abatement contractors.
 Pursuant to California Code of Regulations Title 22, Section 66261.24(a)(2)(A), lead -containing waste is classified as hazardous waste if total lead concentration exceeds 1,000 milligrams per kilogram (or parts per million) or if soluble lead concentration exceeds 5.0 milligrams per liter.

Proper waste characterization testing or waste profiling shall be conducted prior to disposal of le ad containing waste. If practicable, lead wastes shall be segregated to minimize the volume of possible hazardous waste. If lead -containing and non -lead waste materials are comingled during demolition, composite samples of
representative waste shall be analyzed by a certified lab to determine proper disposal requirements.

2. Hazards Near Schools
160
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
127 | P a g e

Threshold: Would the Project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one - quarter mile of an existing or proposed school?
Finding: Less than significant with mitigation incorporated . ( Revised Draft EIR, pp. 4.7-19 -- 4.7-20.)
Explanation: Construction. The nearest school to the project site is South Coast Montessori, which is located approximately 0.2 mile south of the project site. During construction, equipment would require the use of diesel fuel, gasoline, motor oil, and similar materials. The amount of fuel and oil to power construction equipment would be typical of similar construction projects (e .g., 10,000 to 25,000 gallons of fuel4 ). Such materials would be handled and disposed of in accordance with applicable regulations including OSHA Standard 1917.156, which designates fueling locations, regulates liquid fuel, and specifies standards for fue ling operation and storage. Construction personnel would be required to have the necessary training and/or certifications to operate construction equipment, minimizing the risk of accidental release of hazardous materials due to equipment failure. However, construction activities would have the potential to create a significant hazard involving the release of ACMs or LBP into the environment. Therefore, proposed project construction would potentially involve the handling of hazardous materials within 0.25-mile of South Coast Montessori. As such, construction related impacts would be potentially significant , and Mitigation Measures HAZ -1 and HAZ -2 would be required .

Implementation of Mitigation Measures HAZ -1 and HAZ -2 would reduce potential hazardous materia l impacts associated with the handling of hazardous materials within 0.25 -mile of an existing or proposed school during construction to a less -than-significant level. (Revised Draft EIR, pp. 4.7-19 -- 4.7-20.)
E. HYDROLOGY AND WATER QUALITY

1. Water Quality Standards
Threshold: Would the Project violate any water quality standards or waste discharge requirements?
Finding: Less than significant with mitigation incorporated. (Revised Draft EIR, pp. 4.8-10 -- 4.8-12.)
Explanation: Construction. Potential impacts on water quality from construction- related activities would occur due to demolition, vegetation removal, 161
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
128 | P a g e

grading, and use of construction materials on the site. While the project does not require construction activities within El Encanto Creek, there is a potential for pollutants to be transported from the project site to downstream receiving waters, including El Encanto Creek, during construction. The Phase I Environmental Site Assessment prepared for the proposed project (Appendix F) states that, due to the age of the on-site structures, there is potential for on- site structures to contain asbestos and lead-based paint. Demolition activities would occ ur in the vicinity of El Encanto Creek and have the potential to release these pollutants into on-site soils, where they could then be transported downstream in stormwater runoff during storm events. SWRCB’s Construction Stormwater General Permit includes requirements for projects to address demolition -related pollutants. In compliance with these requirements, the SWPPP would specify BMPs to control the discharge of pollutants associated with demolition, including asbestos and lead. In addition, demolition and construction activities would be required to adhere to the Santa Barbara County Air Pollution Control District regulations regarding asbestos and California Department of Public Health regulations regarding lead-based paint materials. However, the release of lead- based materials or asbestos is possible if improperly handled, which could result in pollutant discharge during demolition. Therefore, this impact would be potentially significant.

Mitigation Measures HAZ -1 and HAZ -2 require implementation of asbestos and lead -based paint abatement plans which require asbestos and leadbased components to be removed intact, proper transportation and disposal of asbestos and leadbased components, and the testing and monitoring of unidentified suspect materials prior to removal to confirm if asbestos and lead -based components are present in such materials. With implementation of Mitigation Measures HAZ -1 and HAZ -2, potential impacts for asbestos and leadbased materials to adversely contribute to water quality impairments in El Encanto Creek or substantially degrade water quality would be reduced to a less than significant level.

Subsurface investigations were conducted for soils up to 51 feet in depth at the project site. Subsurface investigations did not reveal any static or perched groundwater underlying the project site.

Accordingly, encountering groundwater during excavation or other ground disturbing activities during construction is not anticipated.

Therefore, discharge of dewatered groundwater to surface waters is not anticipated. E. coli is primarily a result of bacteria loads in water, and construction would not introduce substantial wastes (i.e., 162
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
129 | P a g e

wastewater, pet wastes, wildlife wastes) or introduce livestock or other animals which could substantially increa se E. coli concentrations in El Encanto Creek.

In addition, on-site portable toilets would be provided for construction workers, which would be handled by a licensed waste contractor to minimize the potential of waste release, and limit the potential for release of E. coli. In addition, as a Condition of Approval, the City would require that portable toilet placement only occur in designated staging areas located at least 100 feet from El Encanto Creek.

Therefore, construction would not have the potential to introduce E. coli into El Encanto Creek. The proposed project would involve over one acre of site disturbance during grading and the construction of residences, sidewalks, roadways, patios, landscaping, and associated facilities. Construction would invo lve grading of approximately 27,500 cubic yards of cut and 23,500 cubic yards of fill. This grading activity would involve vegetation removal and expose soil to erosion and potentially could cause sedimentation of El Encanto Creek which could further reduc e dissolved oxygen levels, further imbalance of pH levels, increase turbidity, and result in the release of nitrates. Eroded soils can also transport other pollutants, if present in on-site soils. However, there is no known soil contamination on the projec t site. Soil sampling was conducted at the project site to determine the extent of residual organochlorine pesticides and arsenic potentially present in soil at the project site from past agricultural use. Organochlorine pesticides were not detected above the laboratory reporting limits and on -site arsenic levels were consistent with background concentrations and not indicative of elevated arsenic from past contamination. During onsite grading and building construction, hazardous materials such as fuels, paints, solvents, and concrete additives could be used which could be spilled or leaked and subsequently transported downstream during a storm event. However, these hazardous materials require proper management and disposal. Improper management of any resultant hazardous wastes could increase the opportunity for hazardous materials to release into surface water runoff and potentially infiltrate the underlying groundwater. As a Condition of Approval, the City would require that chemical storage, portable toilet placement, vehicle and/or equipment maintenance, and equipment refueling only occurs in designated staging areas located at least 100 feet from El Encanto Creek, which would minimize the risk of leaks or spills reaching surface waters.
163
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
130 | P a g e

In addition, construction projects of one or more acres are subject to the requirements of the Construction Stormwater General Permit, which requires preparation and implementation of a SWPPP to control the discharges of pollutants, including sediment, into local surface water drainages. The SWPPP would specify the storm water monitoring and construction BMPs required to be implemented to minimize water quality degradation. Construction BMPs would include, but are not limited to, erosion and sediment control BMPs designed to minimize erosion and retain sediment onsite, and good housekeeping BMPs to reduce the risk of spills, leaks, and off -site discharge of construction debris and waste. In addition to NPDES permit requirements, construction activities would be subject to the requirements of Chapter 15.09 of the City’s Municipal Code which requires preparation of an erosion and sediment control plan in order to obtain a grading permit. The City accepts a SWPPP in lieu of an erosion control and sediment plan, if the SWPPP conta ins the requirements of the City’s required elements of an erosion and sediment control plan. As stated in Municipal Code Section

15.09.110, the City’s Planning and Environmental Review Director or designee would review the SWPPP as part of the grading per mit application to ensure the City’s required elements of an erosion and sediment control plan are implemented within the SWPPP.

Accordingly, the SWPPP prepared for the proposed project would include information on proposed BMPs that would be used during construction to retain sediment on -site, minimize surface runoff and erosion, utilize vegetation for erosion control, and control pollution from on -site stormwater discharges to reduce risk of erosion, sedimentation, and leaks or spills during construction. The SWPPP would include identification of all potential construction -related pollutants and their sources, and implementation of BMPs to address and reduce each potential pollutant in stormwater runoff. Visual inspections are required weekly and before, d uring, and after storm events to ensure the BMPs remain in proper working order.

In addition, the Construction Stormwater General Permit requires determination of a construction project’s risk to receiving waters, based on the potential for sediment transport to receiving waters and the receiving water’s sediment -sensitivity. Based on a construction project’s risk, water quality monitoring (pH and turbidity) of stormwater runoff from the construction site may be required to ensure discharge limitation specified in the Construction Stormwater General Permit are not exceeded. The Construction Stormwater General Permit also requires reporting and corrective actions for any detected exceedances. The BMP, inspection, and monitoring 164
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
131 | P a g e

requirements of the Constructi on Stormwater General Permit intended to reduce pollutants in stormwater runoff and ensure that water quality in receiving waters is not degraded. These requirements of the Construction Stormwater would minimize the potential for adverse water quality impa cts, such as reductions in dissolved oxygen levels, further imbalance of pH levels, increased turbidity, and nitrate release, to further impair El Encanto Creek.

Therefore, this impact would be less than significant. (Revised Draft EIR, pp. 4.8-10 -- 4.8-12).

2. Water Quality Control Plan
Threshold: Would the Project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? Finding: Less than significant with mitigation incorporated. ( Revised Draft EIR, pp. 4.8-19 -- 4.8-20.)
Explanation: Construction. Construction would be conducted in compliance with applicable regulatory requirements related to stormwater runoff to minimize the potential for pollutants to degrade water quality. These include the Construction Stormwater General Permit, the Central Coast RWQCB’s Post -Construction Requirements, the County’s Stormwater Technical Guide for Low Impact Development, and Chapter 13.04 and Chapter 15.09 of the City’s Municipal Code. In accordance with these existing requirements, the proposed project would be required to implement a SWPPP, construction BMPs, SWQMP, Source Control BMPs, and LID BMPs to reduce the
potential for the proposed project to degrade water quality. However, the proposed project still has the potential to result in water quality impacts in El Encanto Creek during construction related to asbestos and lead -based materials. These construction activities could introduce pollutants exceeding water quality objectives, which could conflict with the Basin Plan. Construction impacts related to Basin Plan conflicts would be potentially significant.

Mitigation Measures HAZ -1 and HAZ -2 would reduce potential surface water quality impacts related to the introduction of pollutants associated wi th the improper handling of asbestos or lead -based materials during demolition. With implementation of Mitigation Measures HAZ-1 and HAZ-2, the proposed project would reduce the potential to conflict with or obstruct implementation of a water quality control plan to a less than significant level. (Revised Draft EIR, pp.

4.8-19 -- 4.8-20.)
165
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
132 | P a g e

3. Runoff
Threshold: Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantially additional sources of polluted runoff or impede or redirect flood flows? Finding: Less than significant with mitigation incorporated . ( Revised Draft EIR, pp. 4.8-17 -- 4.8-18.)
Explanation: Construction. Construction activities would alter the existing drainage patterns on the project site, which could alter stormwater flows o n the project site compared to existing conditions.

Construction activities have the potential to increase discharge of pollutants in stormwater runoff from the project site compared to existing conditions. Construction would comply with several regulations such as the Construction Stormwater General Permit and the City Municipal Code intended to control stormwater runoff and reduce pollutants and ensure construction activities would not result in substantial runoff water which would exceed the capacities o f El Encanto Creek. However, even with adherence to regulatory requirements, construction activities could result in additional sources of polluted runoff related to asbestos and lead-based paints if these materials are improperly handled, which could resu lt in pollutant discharge during demolition. This impact would be potentially significant.

Implementation of Mitigation Measures HAZ -1 and HAZ -2 require implementation of asbestos and lead -based paint abatement plans which require asbestos and lead-based components to be removed intact, proper transportation and disposal of asbestos and lead - based components, and the testing and monitoring of unidentified suspect materials prior to removal to confirm if asbestos and lead - based components are present in su ch materials. With
implementation of Mitigation Measures HAZ -1 and HAZ-2, potential impacts for asbestos and lead-based materials to provide substantial sources of polluted runoff would be reduced to a less than significant level. (Revised Draft EIR, pp. 4.8-17 -- 4.8-18.)
F. LAND USE AND PLANNING

1. Conflicts With Plans
166
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
133 | P a g e

Threshold: Would the Project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? Finding: Less than significant with mitigation incorporated. (FEIR, pp.4.9-6 --

4.9-11.)
Explanation: The project site has a General Plan/Coastal Land Use Plan land use designation of Agriculture, which does not permit the residentia l development that would occur with the proposed project. The proposed project is subject to the Builder’s Remedy and protections of the Housing Accountability Act, and as such, does not require a General Plan Amendment to change the project site land use designation from Agriculture to Single Family Residential or a zoning change. Consistent with California Government Code section 65589.5(f)(6)(A), the proposed project will be evaluated for consistency with the regulations of the RS -7 zone district.

Components of the proposed project which are not consistent with the RS-7 zone will be evaluated consistent with California Density Bonus Law which allows waivers for deviations from the standards identified within the RS-7 zone. As part of the proposed project, the project applicant is requesting the following concessions/incentives or waivers pursuant to Government Code Section 65915(a) for the following deviations from City standards:
 Four waivers from the RS-7 zone district standards:
o Proposed lot widths of less than the 65 feet required in the RS-7 zone on 31 of the 56 proposed residential lots.
o Proposed rear yard setbacks of less than the 25 feet
required on 51 of the 56 proposed residential lots.
o Proposed side yard setbacks of less than the 6.5’ required on 32 of the 56 proposed lots. The reduction
accommodates eaves on no less than 5 feet to the
property line.
o Allowed maximum floor area of 35 houses exceeding the maximum permitted floor area from 208 to 1,539 additional square feet. These floor area exc eedances would occur
on Lots 1 through 14, 20 through 23, 25 through 29, 32, 34, 36, 40, 41, 45, 46, 48, 50, 52, and 55.
167
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
134 | P a g e

o Encroachment into the required 100 -foot SPA buffer10 of approximately 7,786 square feet (0.18 acres) in the rear yards of Lots 1 throu gh 8. portions of the houses on Lots 1 and 2, and for portions of sidewalk in Lot 38. To
compensate for SPA buffer encroachment, the proposed
project design includes 0.21 acre of additional open space provided outside of and adjacent to the edge of the 100 - foot SPA buffer on proposed Lot 58.

Table 4.9 -1 of the Revised Draft EIR summarizes the proposed project’s consistency with the RS-7 zone requirements, including lot area, lot width, floor area, density, building height, and setback requirements, as stip ulated by Section 17.07.030 of the Goleta Municipal Code. The proposed project would meet the development standards of the RS -7 zone, following the approval of requested waivers pursuant to California Density Bonus Law. The project would require approval of a vesting tentative map, Development Plan, and waivers from the City to authorize the proposed development. Upon approval of these items as well as associated demolition and construction permits, the residential development would no longer be considered non-conforming and would instead be conforming uses under the Goleta Municipal Code, California Housing Accountability Act “Builder’s Remedy,” and California Density Bonus Law. This framework for approval would resolve any non -conformance issues based on land use and zoning, and align the project site’s use with the City’s Single Family Residential land use designation and RS -7 zone district.

These actions would not result in physical environmental impacts beyond those already analyzed in this EIR but are subject to review by the City of Goleta. The project would be consistent with applicable Goleta General Plan/Coastal Land Use Plan land use policies adopted for the purpose of avoiding or mitigating an environmental effect, following the implementation of project-specific mitigation measures. The proposed project includes several elements that support bicycle and pedestrian travel. The proposed project includes two new access points on Cathedral Oaks Road; internal streets that connect to existing bicycle a nd pedestrian facilities; and internal sidewalks and pedestrian connections to the Class I multi -use path for bicycle and pedestrian use. The Class I trail would provide an exclusive right-of-way for bicycle and pedestrian use and minimize vehicle cross flows (i.e., the locations which a vehicle can cross the pathway).
168
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
135 | P a g e

The Class I trail would be consistent with the locations of bicycle infrastructure shown in Figure 4 -19, Future Active Transportation Network Map, of the BPMP. The proposed project supports BPMP Policy TE 10 and Policy TE 11 by providing pedestrian linkages and maintaining connectivity to the City’s planned bikeway system (City of Goleta 2006). This would be achieved with the proposed project by the inclusion of frontage improvements along Ca thedral Oaks Road between Northgate Drive to the west and the Glen Annie Golf Course property to the east. The proposed project would not remove existing pedestrian or bicycle infrastructure, create physical barriers to non-motorized travel, or degrade saf ety or connectivity in a way that causes a measurable impact on the physical environment.

Accordingly, the proposed project would be consistent with the policies and vision for active transportation infrastructure in Goleta set forth within the City’s BPMP . The proposed project would result in development within the SPA. Specifically, encroachment into the SPA buffer would be required for approximately 7,786 square feet (0.18 acre) of residential development on Lots 1 through 8; portions of the houses on Lots 1 and 2; a new, 90 -foot storm drain pipe and approximately 11,283 square feet of stormwater infrastructure, a meandering path, landscaping, and 65 feet of sidewalk. General Plan/Coastal Land Use Plan Policy CE 2.2 and Goleta Municipal Code Section 17.30.070 allow for site-specific reductions to the 100- foot buffer under limited circumstances. The proposed
encroachments into the 100-foot buffer are consistent with Policy CE

2.2. Policy CE 2.3, listed fully in Table 4.9-2 of the Revised Draft EIR, describes allowable uses and activities in the SPA buffer.

While the stormwater infrastructure, meandering path, and sidewalk are considered allowable uses pursuant to Policy CE 2.3, the residential development is not an allowable use pursuant to Policy CE 2.3. As such, the proposed project would be potentially inconsistent with this policy, which specifically limits allowable uses in SPAs to resource-dependent activities. While the proposed project would be inconsistent with Policy CE 2.3, such conflict does no t inherently result in a significant environmental impact under CEQA.

CEQA significance is determined by whether a conflict with a plan would lead to a substantial adverse physical change in the environment. In this case, the inconsistency is limited to th e type of development (i.e., residential use) rather than the extent or severity of physical impacts, which are addressed through mitigation measures and site design. The proposed development within the SPA buffer has been sited and designed to avoid riparian vegetation and minimize grading, and would not result in significant degradation 169
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
136 | P a g e

of streamside habitat or hydrology. Therefore, the proposed project’s impact involving conflicts with Policy CE 2.3 would be less than significant.

The proposed project would involve land divisions for parcels within and adjacent to ESHA and would require development within ESHA or ESHA buffers, and would thus conflict with City of Goleta General Plan/Coastal Land Use Plan Policy CE 1.6 (Protection of ESHAs), Policy CE 1.9 (Standards Applicable to Development Projects), and Policy CE 5.3 (Protection of Coastal Bluff Scrub, Coastal Sage Scrub, and Chaparral ESHA). Policy CE 1.6 requires the protection of ESHA and prohibits development in ESHA and ESHA buffers, exempting cert ain development (e.g., public road crossings, utility lines, etc.) only when there are no feasible less environmentally damaging alternatives. Policy CE 1.9 establishes specific standards for development projects that may affect ESHA, including requirements to avoid ESHA impacts wherever feasible, maintain adequate buffers, and implement mitigation measures when avoidance is not possible. Policy CE 1.9(b) explicitly prohibits land divisions that would result in future development within ESHA or ESHA buffers unless the use is resource -dependent and sited to minimize impacts. Policy CE 5.3 requires a minimum 25 -foot buffer around coastal sage scrub ESHA.

The proposed project would include the subdivision of land and siting of residential lots that would resul t in grading, landscaping, and construction within mapped ESHA and SPA buffer areas. These uses are not considered resource -dependent, and the resulting parcel configuration would permanently alter ESHA and reduce buffer integrity. Therefore, the proposed project would conflict with the intent and requirements of Policy CE 1.9, which is designed to prevent incremental loss of sensitive habitat through subdivision and development. The permanent loss of ESHA and ESHA buffer would result in a potential inconsi stency with Policies CE 1.6 and CE 5.3 and Section 17.30.040 (Development and Mitigation of Impacts) of the Goleta Municipal Code. In addition, the proposed storm drain pipe, detention basin, and bike path would encroach on the 25 -foot buffer required by Policy CE 5.3. While this development would make the proposed project potentially inconsistent with Policy CE 1.6, Policy CE 1.9(b), and CE 5.3, as described in Section 4.3, Biological Resources, the environmental impacts of development within ESHA buffers these impacts would be reduced to a less than significant level by requiring fencing around ESHA (BIO -7) and biological monitoring during construction and construction worker
170
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
137 | P a g e

environmental awareness training (BIO-4). Mitigation Measure BIO- 3 would reduce p otential permanent impacts to ESHA by requiring compensatory mitigation for habitat loss due to project development.

Accordingly, although the proposed project would be potentially inconsistent with Policy CE 1.9(b), such an inconsistency would not cause a significant environmental impact. As discussed in Section

4.3, Biological Resources, the proposed project would potentially be inconsistent with the City of Goleta General Plan/Coastal Land Use Plan Policy CE 9.5, as well as the City’s Urban Forest Manag ement Plan and Goleta Municipal Code Chapter 15.09. While no native trees are located directly on the project site, three protected coast live oak trees have canopies and/or critical root zones that extend onto the project site. Although the project would avoid direct removal or substantial disturbance of these trees, construction activities within their critical root zones could result in indirect impacts, such as soil compaction or root damage, if appropriate protection measures are not implemented. Howev er, the proposed project would include implementation of BIO -8 which would require implementation of tree protection measures during project construction activities. A detailed evaluation of the proposed project’s consistency with applicable policies from the General Plan/Coastal Land Use Plan is provided in Table 4.9-2 of the Revised Draft EIR. In summary, the proposed project would be consistent with development standards of the Goleta Municipal Code, and would be consistent with applicable policies from the Goleta General Plan/Coastal Land Use Plan with the implementation of mitigation measures. Therefore, impacts related to conflict with land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect would be less than significant with mitigation.

With the approval of waivers provided to the project applicant for deviations from City standards pursuant to Government Code Section 65915(a), project design would be consistent with City zoning requirements. Mitigation Measures BIO -1 through BIO -8; CUL-1 through CUL-3; GEO-1 and GEO-2; HAZ-1 and HAZ-2; and NOI-1 would reduce impacts involving conflicts with land use plans, policies, or regulations that were adopted for purposes of reducing environmental impact s. These mitigation measures would reduce impacts involving conflict with the Goleta General Plan/Coastal Land Use Plan as they would minimize potential impacts to protected environmental resources within the Goleta General Plan. 171
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
138 | P a g e

With implementation of Mi tigation Measures BIO -3, BIO -4, BIO -7, and BIO-8, the proposed project would be consistent with Policies CE 1.6 and CE 5.3. With implementation of Mitigation Measure BIO- 8, the proposed project would be consistent with Policy CE 9.5. The proposed project would remain inconsistent with Policies CE 1.9 and

2.3; however, these inconsistencies are related to policy -level distinctions and would not result in a significant impact to the environment. (FEIR, pp.4.9-6 -- 4.9-11.)
G. NOISE

1. Noise Standards
Threshold: Would the Project result in the generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Finding: Less than significant with mitigation incorporated . ( Revised Draft EIR, pp. 4.10-8 -- 4.10-10.)
Explanation: Construction. Residential construction projects produce readily apparent noise. The sensitivity to noise from such con struction is increased when it occurs in or near residential areas or other sensitive receivers. The nearest sensitive receivers are the residences adjacent to Cathedral Oaks Road, located as close as 65 feet from the southern edge of the project site, and residences to the west approximately 200 feet from the project site. In addition, the Glen Annie Golf Course is within 100 feet of the project site. The proposed project would be constructed in approximately 18 months.

The grading/excavation phase of project construction tends to create the highest construction noise levels because of the operation of heavy equipment, although only a limited amount of equipment can operate near a given location at a particular time. For general construction activities, pre dicted average -daily construction noise levels were calculated assuming three louder pieces of equipment operating simultaneously.

Default equipment assumptions from CalEEMod were included in the air quality analysis; from this list, a grader, scraper, an d dozer were used as the three louder pieces of equipment for the analysis. The closest residences to the south could experience construction noise levels of 78 dBA from the source. Residences to the west and golfers at the Glen Annie Golf Course would experience noise levels ranging from 68 and 72 dBA, respectively. Overall, construction noise within 172
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
139 | P a g e

450 feet of sensitive receptors would exceed Goleta’s 65 dBA standard. As a Condition of Approval, standard measures from the City of Goleta General Plan/Coas tal Land Use Plan Noise Element would be implemented to address short -term construction noise.

These include complying with Policy NE 6.4 which restricts construction activities near or adjacent to residential buildings and other sensitive receptors to the hours of 8:00 a.m. to 5:00 p.m. and using properly maintained equipment with a muffled exhaust system, shutting off idling equipment, and maintaining adequate buffers between construction activities and sensitive receptors.

However, with implementation of standard measures that are required by regulations, construction noise levels may still exceed Goleta’s 65 dBA construction noise standard at nearby noise - sensitive receivers. Therefore, construction noise impacts would be potentially significant.

Implementation of Mitigation Measure NOI -1 would ensure that construction noise levels do not exceed the City’s 65 dBA construction noise standard. Measures may include a temporary noise barrier to break the line of sight between c onstruction equipment and residences within 450 feet of heavy -duty equipment operation. To estimate the sound level reduction from a temporary noise barrier, the barrier was assumed to be constructed with a solid material that has a density of at least 1.5 pounds per square foot with no gaps from the ground to the top of the barrier. With these assumptions, the estimated noise reduction from a temporary noise barrier which would block the line -of-sight between the equipment exhaust stacks and nearest receiv ers would be 15 dBA. With this reduction, noise levels at the closest residences 100 feet south would be 63 dBA or lower. In lieu of barriers, measures listed in Mitigation Measure NOI-1 may also be combined if it can be demonstrated that such measures would reduce construction noise below the City’s 65 dBA construction noise standard. Therefore, with implementation of a Construction Noise Control Plan, construction noise levels would not exceed Goleta’s 65 dBA construction noise standard, and impacts would be less than significant with mitigation. (Revised Draft EIR, pp. 4.10-8 -- 4.10-10.)
MM NOI-1 Construction Noise Reduction
The construction contractor shall prepare and submit a Construction Noise Control Plan to the City of Goleta Planning and Environmental Review Director or designee for review and approval prior to issuance of a Zoning Clearance for a grading permit/demolit ion 173
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
140 | P a g e

permit. The Construction Noise Control Plan shall specify the noise reduction measures to be implemented during project construction that uses heavy -duty equipment within 450 feet of residences and the golf course (measured from the center of the site) to ensure noise levels do not exceed 65 dBA at nearby sensitive receivers. The measures specified in the Construction Noise Control Plan shall be included on the building and grading plans and shall be implemented by the construction contractor during construction. The Construction Noise Control Plan may include, but would not be limited to, the following to reduce construction noise below the City’s 65 dBA construction noise standard. Construction noise control measures may be combined as necessary to demonstrate that such measures would reduce construction noise below the City’s noise standard.

The construction contractor shall provide proof in the Construction Noise Control Plan that the chosen measures would reduce construction noise below the City’s 65 dBA construction noise standard:
 Prior to use of any construction equipment, the contractor shall fit all equipment with properly operating mufflers, air intake silencers, and engine shrouds no less effective than as originally equipped by the manufacturer.
 Installation of temporary sound barriers/blankets to break the line of sight between construction equipment and sensitive receivers within 450 feet of the project site. The barriers shall be constructed with a solid material that has a density of at least 1.5 pounds per square foot with no gaps from the ground to the top of the barrier.
 Staging and delivery areas shall be located as far as feasible from existing residences and the golf course. To the extent consistent with applicable safety regulations , trucks operating with reverse motions alarms shall be outfitted with SAE J994 Class D or equivalent alarms (ambient -adjusting, or “smart alarms” that automatically adjust the alarm to 5 dBA above the ambient near the operating equipment), or switch off b ack-up alarms and replace with human spotters in compliance with all safety requirements and laws.
 A construction notification sign shall be posted at the job site, clearly visible to the public, that includes permitted construction days and hours, as well as the telephone numbers of the City of Goleta’s and the contractor’s authorized representatives that are 174
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
141 | P a g e

assigned to respond in the event of a noise complaint.
 If the authorized contractor’s representative receives a complaint, either City code enforcement or a contractor-retained and Goleta- approved noise consultant shall conduct noise measurements at the properties that registered the complaint. The noise measurements shall be conducted for a minimum of one hour to determine if noise levels are compli ant with City’s 65 dBA standard. The consultant shall prepare a letter report for code enforcement summarizing the measurements, calculation data used in determining impacts, and potential measures to reduce noise levels to the maximum extent feasible.

Plan Requirements and Timing: The Planning and
Environmental Review Director or designee shall approve the Construction Noise Control Plan prior to issuance of the zoning clearance for the grading permit/demolition permit. The measures specified in the Construction Noise Control Plan shall be included on the building and grading plans. Monitoring: The City shall monitor compliance with the requirements of the Construction Noise Control Plan periodically during construction and shall promptly investigate and respond to all noise complaints.

Monitoring: The City shall monitor compliance with the
requirements of the Construction Noise Control Plan periodically during construction and shall promptly investigate and respond to all noise complaints
H. TRIBAL CULTURAL RESOURCES

1. Tribal Cultural Resources
Threshold: Would the Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is: (i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k); or (ii) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in Public Resources Code section 5024.1?
175
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
142 | P a g e

Finding: Less than significant with mitigation incorporated . ( Revised Draft EIR, pp. 4.12-6 -- 4.12-6.)
Explanation: Although the project is not required to comply with the tribal consultation requirement s of AB 52, the City of Goleta conducted outreach to the local Native American community in 2013 and 2014.

The only response received was a written response
Barbareño/Ventureño Band of Mission Indians expressing general interest in preserving land historic ally occupied by Chumash peoples. No projector site-specific comments, concerns or requests were received from the local tribes. Additionally, on September 23, 2025, the City held a consultation with Amanda Dobrov from Santa Ynez Band of Chumash Indians. M s. Dobrov was provided all background documentation and would decide if she wanted to provide comments or not. To date, no comments have been received. Additionally, the City notified Eleanor Fishburn from Barbareno Band of Chumash Indians and the Cultural Resource Committee from the Barbareno/Ventureno Band of Mission Indians regarding consultations and comments but no comments have been submitted as of date. Based on previous project site testing, there is a high degree of confidence in the absence of tri bal cultural resources on the project site (Dudek 2011). No tribal cultural resources were identified during consultation with the local tribes, and no additional tribal concerns were raised. Therefore, based on the absence of identified tribal cultural re sources and the results of prior field investigations, the proposed project would not result in a substantial adverse change to any known tribal cultural resources.

Although impacts to known tribal resources would not occur, there is a potential for unknown tribal resources not identified during project site testing to be encountered during ground disturbing activities.

Moreover, ground disturbance during proposed project construction could inadvertently encounter and consequently damage or destroy unanticipated tribal cultural resources. Such impacts to tribal cultural resources would be potentially significant.

Mitigation Measures CUL-1 through CUL-3 would minimize potential impacts to tribal cultural resources of Native American origin by requiring cons truction monitoring and procedures and final disposition of any unanticipated discoveries of such resources.

Therefore, with implementation of these measures, impacts to tribal cultural resources would be reduced to less than significant. (Revised Draft EIR, pp. 4.12-6 -- 4.12-6.)
I. WILDFIRE
176
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
143 | P a g e

1. Runoff Risks
Threshold: Would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? Finding: Less than significant with mitigation incorporated. ( Revised Draft EIR, pp. 4.14-23 -- 4.14-24.)
Explanation: Operation. During operation, there would be stormwater runoff from impervious surfaces on site, as occurs under existing conditi ons.

However, stormwater infrastructure installed as part of the proposed project would be implemented to maintain pre -project runoff rates and minimize erosion. While operational erosion impacts would be minimized on site, the northern portion of the proj ect site is mapped within an area of high landslide potential. This area is underlain by the Rincon Formation, which is known for its susceptibility to slope instability. The site includes sloping terrain, particularly in the northern section, where landslide risk is greatest.

In the event of a wildfire, fire can damage vegetation roots and burn vegetation. Vegetation itself acts as a barrier to rockfall or soil movement, and the roots of vegetation help maintain soil stability.

The damage or removal of vegetation would result in the removal of natural barriers to deflect or stop landslide movement and would decrease the relative stability of soils underlying the project site, which would increase the risk of landslide potential on the project site. Accordingly, wildfire on the project site could exacerbate the risk of slope instability or risk of landslide. Risk of landslide on the project site would be reduced through the implementation of Mitigation Measure GEO -1, which would require the project design to incorporate recommendations made in the Preliminary Geotechnical Investigation. These include the recommendation that existing fill and soft material be excavated to firm native soil, that cut pads be used for compaction control, and that piers be used for stability of the residences on site. These recommendations are based on site - specific geotechnical conditions and are intended to directly address the potential for soil instability and slope movement. Excavation to firm native soil would eliminate the pr esence of unconsolidated or expansive materials that could shift under load or during seismic or post-fire conditions. Cut pads would ensure uniform compaction and slope integrity, reducing the likelihood of differential settlement or surface sloughing. Th e use of piers would provide foundational support, anchoring buildings into stable subsurface layers and reducing the risk of structural movement or collapse in the event of 177
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
144 | P a g e

soil instability. Together, these recommendations are designed not only to reduce the risk of landslide but also to meet established engineering safety factors for slope stability and structural integrity.

The Preliminary Geotechnical Investigation concluded that, with implementation of these recommendations, the project site would be suitable for the proposed development and would not pose a significant geologic hazard. Therefore, adherence to Mitigation Measure GEO-1 would reduce the potential for landslide or post-fire slope instability to a level where no substantial risk to people or structures would occur. Impacts would be less than significant with mitigation.

Implementation of Mitigation Measure GEO-1 would reduce the risk of landslide on the project site by ensuring the proposed project incorporates recommendations included in the Preliminary Geotechnical Investigation. This would reduce impacts associated with post-fire instability and landslide risk as a result of wildfire to less than significant. (Revised Draft EIR, pp. 4.14-23 -- 4.14-24.)

SECTION IV.

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

J. TRANSPORTATION

1. VMT
Threshold: Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Finding: Significant and unavoidable. (FEIR, pp. 4.11-8 -- 4.11-10.) Explanation: Operation. The proposed project would develop 56 single -family residential units (45 market -rate and 11 deed -restricted affordable units) on a vacant site along Cathedral Oaks Road. Based on the ATE Phase I Traffic and VMT Assessment and City of Goleta VMT analysis to ol, the project is estimated to generate 21.24 VMT per 178
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
145 | P a g e

resident, which exceeds the City’s threshold of 16.79 VMT per resident. Given that vehicle miles are distributed regionally and based on the project site’s proximity to unincorporated Santa Barbara Cou nty, the County of Santa Barbara VMT tool was also used to estimate project VMT in relation to County thresholds. Using the County’s VMT calculator, the project is estimated to generate

15.9 VMT per resident, which exceeds the County threshold of 14.9 VMT per resident. Therefore, the proposed project would potentially be inconsistent with CEQA Guidelines Section 15064.3(b). This impact would be potentially significant.

Based on the assumed VMT reductions in the ATE Phase I Traffic and VMT Assessment for the potential reduction measures included in Mitigation Measure TRA -1, VMT could potentially be reduced to

12.75 VMT per resident, which would be below the County’s threshold of 14.9 VMT per resident. With Mitigation Measure TRA-1, VMT could potentially be reduced to 17.03 VMT per resident for the City of Goleta. As such, the project would still exceed the City VMT threshold of 16.79 VMT per resident. Furthermore, the
implementation of some VMT reduction programs (i.e., improve design of development, extend transit network coverage or hours) could result in additional ground -disturbing activities which would result in additional environmental impacts associated with increased ground disturbance. Despite implementation of all feasible mitigation for VMT reduc tion, the project would still conflict with CEQA Guidelines Section 15064.3(b), and the impact would remain significant and unavoidable. (Revised Draft EIR, pp. 4.11 -8 -- 4.11-

10.)
MM TRA-1 Vehicle Miles Traveled Reduction Plan
The applicant shall prepa re and submit a Vehicle Miles Traveled (VMT) Reduction Plan to the City of Goleta Planning and Environmental Review Director or designee for review and approval prior to issuance of a Zoning Clearance for a grading
permit/demolition permit. The VMT Reduction Plan shall specify the VMT reduction measures to be implemented during project design and development. The measures specified in the VMT Reduction Plan shall be included in development plans and implemented during project development. The VMT Reduction Plan may include, but would not be limited to, the following:
 Integrate Affordable and Below Market Rate Housing: Provide 9 percent low -income units (five units), 5 percent moderate - income units, and 5 percent above -moderate (workforce) 179
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
146 | P a g e

units for a total of 20 percent income-restricted units.  Provide Pedestrian Network Improvements: Provide a safe path from the project to transit stop, connect pedestrian walkways to existing pedestrian facilities along Glen Annie Road and Cathedral Oaks Road.
 Improve Des ign of Development: Implement or provide
funding for improvements to corridors and crossings for bike networks identified within a 0.5 -mile buffer of the project boundary, particularly along Cathedral Oaks Road.
 Extend Transit Network Coverage or Hours: P rovide a bus stop adjacent to the project site on Cathedral Oaks Road.  Implement School Pool Program: Work with school district(s) to create ridesharing program for school children.

Plan Requirements and Timing: The Planning and Environmental Review Director or designee shall approve the VMT Reduction Plan demonstrating incorporation of all feasible VMT reduction strategies/measures into project design prior to issuance of the zoning clearance for the grading permit/demolition permit. The measures specified in the VMT Reduction Plan shall be included in the building and grading plans.

Monitoring: The City shall monitor compliance with the
requirements of the VMT Reduction Plan periodically during construction and following project occupancy and shall promp tly investigate and respond to any non-compliance issues.

SECTION V.

CUMULATIVE IMPACTS
Regarding the Project’s potential to result in cumulative impacts, the City hereby finds as follows:

A. AESTHETICS
There are no officially designated State Scenic Highways in Goleta; therefore, a discussion of cumulative impacts related to State Scenic Highways is not provided herein.

The Annual Pavement Rehabilitation Project and Pavement Management Program on Cathed ral Oaks Road would consist of temporary construction activities associated with roadway rehabilitation. The Annual Pavement Rehabilitation Project and 180
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
147 | P a g e

Pavement Management Program does not include the construction of buildings or other structures that coul d further obstruct already limited views of the scenic Santa Ynez mountains and foothills. The redevelopment of the Glen Annie Golf Course property into a residential development would serve as an extension of the existing residential development in the vi cinity. This would increase the overall developed condition of the area, adding structural development at the base of the Santa Ynez foothills and mountains, potentially decreasing scenic views in the Cathedral Oaks Scenic Corridor.

As a result, cumulative development could result in a significant cumulative impact on scenic vistas. As discussed in the project -specific analysis above, project construction would be fluctuating and temporary as it relates to visual impacts. Construction equipment used on the project site would not be of substantial size or massing such that substantial interference of views of the foothills and mountains would occur. Accordingly, proposed project construction would result in less than significant impacts to aesthetics and scenic resources.

Once operational, the project would alter the aesthetic nature and views of/through the project site. However, as designed, aesthetic impacts and impacts to scenic views would be similar to surrounding development, continue to offer limited public views to the Santa Ynez foothills and mountains, and not substantially different than the existing condition. As such, the project would not result in a considerable contribution to cumulative impacts. Cumulative development in Goleta, including the project, would be required to comply with the applicable policies and regulations relating to scenic views/resources and aesthetics in the City of Goleta General Plan/Coastal Land Use Plan and Goleta Zoning Code. County projects would similarly be subject to County of Santa Barbara policies and regulations governing aesthetics and visual resources. As such, cumulative impacts related to compliance with applicable zoning and other regulations governing scenic quality would be less than significant.

Cumulative development would contribute to an increase in light and glare throughout Goleta. However, future projects, including the project, would be required to implement City lighting regulations, which would minimize the potential for skyglow or light trespass by requiring lighting fixtures to be designed, located, aimed downward or toward structures (if properly shielded). Implementation of City lighting regulations would ensure that cumulative impacts involving light and glare would be less than significant. (Revised Draft EIR, pp. 4.1-25 -- 4.1-26.)
B. AGRICULTURE AND FORESTRY RESOURCES
The project site does not contain any soils classified as “Prime Farmland,” “Unique Farmland,” or “Farmland of Statewide Importance,” and therefore would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to a non -agricultural use and no impact would occur. (Revised Draft EIR, p . 4-4.) The project would not have significant cumulative agriculture and forestry resource impacts.

C. AIR QUALITY
181
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
148 | P a g e

Conflicts with an Air Quality Management Plan and Criteria Air Pollutant Emissions
The geographic scope for evaluating cumulative impacts pertaining to conflicts with an air quality management plan and cumulatively considerable criteria air pollutant emissions is the SCCAB. This geographic scope is appropriate as the SCCAB is managed by SBCAPCD, and the 2022 Ozone Plan and SBCAPCD emissions thresholds are implemented in order to manage air quality within the SCCAB. Regional air pollution is largely a cumulative issue, and SBCAPCD’s Environmental Review Guidelines and Scope and Content of Air Quality Sections in Environmental Documents includes recommendations for the analysis of cumulative impacts pertaining to ozone and localized pollutants. Inconsistency with the Ozone Plan is considered a cumulatively adverse air quality impact. The planned, pending, and reasonably foreseeable projec t is within Goleta, at the time of this project would include the construction of a total of 534 residential units in addition to the proposed project’s 56 residential units. Based on the City’s average

2.59 persons per household estimated by the DOF, cumu lative growth in Goleta would be approximately 1,528 residents.3 SBCAG forecasts a population of 34,700 in Goleta in 2050 (SBCAG 2019), which functions as a basis for the 2022 Ozone Plan’s emissions forecast. The addition of 1,528 residents to Goleta would result in a population of 34,275, which would be below SBCAG population forecasts. Thus, cumulative development would be accommodated within SBCAG growth projections. Cumulative development would not exceed the SBCAG growth assumptions, which function as a basis for the 2022 Ozone Plan’s emissions forecast, and would not result in cumulatively considerable project emissions. Cumulative impacts related to conflicts with the 2022 Ozone Plan and the release of cumulative considerable criteria air pollutant emissions would therefore be less than significant.

Exposure of Sensitive Receptors to Substantial Pollutant Concentrations The geographic scope for evaluating cumulative impacts pertaining to exposure of sensitive receptors to substantial pollutant concentr ations includes projects adjacent to the project site, which is appropriate as such projects could result in air pollutant emissions which could combine with the proposed project’s air pollutant emissions at the same sensitive receptors. Cumulative impacts in proximity to the project site such as the Annual Pavement Rehabilitation Project and Pavement Management Program adjacent to the south of the project site and the Glen Annie Golf Course Residential Development adjacent to the north and east of the proj ect site could expose sensitive receptors to substantial pollutant concentrations if construction schedules overlapped. As stated in SBCAPCD’s Environmental Review Guidelines and Scope and Content of Air Quality Sections in Environmental Documents, significance criteria for cumulative impacts are the same as project-level impacts. However, projects may still be approved even if they do not meet SBCAPCD significance criteria, which could lead to substantial pollutant concentrations at sensitive receptors. Therefore, cumulative impacts related to exposing sensitive receptors to substantial pollutant concentration could be significant.

182
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
149 | P a g e

The proposed project’s construction emissions would be short -term, temporary, and cease following the completion of construction. Construction equipment utilized for the proposed project would be equipped with Tier 4 engines which would substantially reduce air pollutant emissions from construction activities. Compliance with SBCAPCD Rules 323.1, 329 and 345 would ensure construction would minimize potential pollutant concentrations emitted from the use of paints and from fugitive dust generation. Project operation would not result in substantial pollutant concentrations. Therefore, the proposed project’s contribution to cumulative impacts related to exposing receptors to substantial pollutant concentrations would not be considerable.

Odors
The geographic scope for evaluating cumulative impacts pertaining to odors includes areas adjacent to the project site, which is appropriate because odors dissipate with distance. Cumulative projects would adversely affect sensitive receptors from odor emissions if cumulative projects were typical odor-producing land uses. Construction of cumulative projects would result in constructio n equipment-related odors; however, the temporary nature of construction would ensure less than significant cumulative odor impacts. Cumulative projects in proximity to the project site such as the Annual Pavement Rehabilitation Project and Pavement Manage ment Program and the Glen Annie Golf Course Residential Development adjacent to the north and east of the project site do not include odor producing facilities that could result in substantial operational odors.

Therefore, cumulative odors from the surrounding area from construction and operations would not be combined at the same receptors, and cumulative impacts related to odors would be less than significant. (Revised Draft EIR, pp. 4.2-14 -- 4.2-16.)

D. BIOLOGICAL RESOURCES
The cumulative projects would consist of construction of a total of 534 residential units, 440,599 square feet of industrial space (automotive service facilities, industrial buildings, distribution/delivery facilities, indoor/outdoor storage, and a repurposed hangar building), and 163,930 square feet of commercial space (shopping center improvements, automotive dealerships, a golf pro shop, a coffee shop, and office facilities). Cumulative projects also include oil and gas infrastructure removal, animal shelter renovations, construction and renovation of medical facilities, parkland improvements, one synagogue, one church, hotel renovations, battery energy storage infrastructure, restoration and habitat management activities, and various roadway improvements. In addition, while not within the City of Goleta, the Santa Barbara County Board of Supervisors approved a rezone of the Glen Annie Golf Course for the development of 800 to 1,000 residential units as part of the County’s 2023 -2031 Housing Element Update. Cumulative development in the City of Goleta would have the potential to disturb special -status species, riparian habitats, sensitive natural communities, wetlands, and wildlife movement. Existing City policies as well as federal and State regulations would protect special-status spec ies, riparian habitats, sensitive natural communities, wetlands, and wildlife movement during the course of cumulative project development. Individual 183
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
150 | P a g e

development proposals are reviewed separately by the City and must undergo environmental review when it i s determined that the potential for significant impacts exists. Cumulative projects would be required to implement mitigation measures, similar to the proposed project, if it is determined that significant impacts for individual cumulative projects would o ccur. Nevertheless, cumulative development may have a potentially significant cumulative impact on biological resources, given the scope of anticipated development.

The proposed project includes specific mitigation measures to avoid and minimize impacts to biological resources, including pre-construction surveys for nesting birds and special-status species and mitigation for impacts to ESHA. The proposed project would not result in degradation or fragmentation of habitat that could substantially impact special-status species or wildlife movement; would maintain ecological connectivity and avoid direct impacts to ESHA and the SPA buffer to the maximum extent feasible; and would comply with applicable biological resource protection policies to the extent feasible.

Therefore, the proposed project would not have a considerable contribution to potential cumulative impacts. Cumulative development has potential to conflict with biological resource plans and policies. However, individual cumulative projects would be required to implement mitigation measures, similar to the proposed project, if it is determined that significant impacts involving conflict with biological resource plans and policies for individual cumulative projects would occur. The proposed project’s potential inconsistencies with policies designed to protect ESHA and the SPA buffer associated with El Encanto Creek would be resolved with implementation of mitigation measures and would not result in a significant environmental impact; furthermore, no c umulative development projects are located along El Encanto Creek. Therefore, cumulative development would have a less than significant cumulative impact involving conflict with biological resource plans and policies. There would be no cumulative impact re garding conflict with adopted Habitat Conservation Plans or Natural Community Conservation Plans, as no such plans are implemented within the geographic scope of cumulative impacts to biological resources. (Revised Draft EIR, pp. 4.3-44 -- 4.3-43.) E. CULTURAL RESOURCES
The proposed project would result in no impact to built environment (historic) resources. As such, it would not contribute to cumulative impacts on such resources.

Therefore, cumulative impacts related to built environment resources are not ad dressed further in this analysis. Cumulative projects would have the potential to adversely impact buried archaeological resources through ground -disturbing construction activities.

However, existing City policies and regulations would protect any unknown resources that might be uncovered in the course of project development. Individual development proposals are reviewed separately by the City and undergo environmental review when it is determined that the potential for significant impacts exists, which is occurring for the proposed project. In the event that future cumulative development would result in impacts to known or unknown cultural resources, impacts to such resources would be addressed 184
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
151 | P a g e

on a case-by-case basis. Nevertheless, there is potential for c umulative development to uncover archaeological resources in the City of Goleta given the breadth of cumulative development and the area’s sensitivity for archaeological resources. Cumulative impacts to archaeological resources would therefore be potential ly significant. The proposed project would be required to implement Mitigation Measures CUL 1 through CUL 3, which require archaeological monitoring during ground disturbing activities, a preconstruction cultural resources training for construction personnel, and implementation of appropriate procedures for the evaluation and treatment of any cultural resources that may be encountered, consistent with CEQA Guidelines Section 15064.5 and PRC Section 21083.2. With implementation of Mitigation Measures CUL 1 t hrough CUL 3, the proposed project’s contribution to cumulative impacts to archaeological resources would not be considerable.

Cumulative development would have the potential to adversely impact buried human remains through ground -disturbing construction activities. The magnitude of impacts for individual projects would depend upon the location, size of development, and depth of ground disturbance. State of California Health and Safety Code Section 7050.5 would apply to all future development, and compliance with this regulation would address impacts related to buried human remains associated with cumulative development.

Therefore, cumulative development impacts involving the disturbance of human remains would be less than significant. (Revised Draft EIR, pp. 4.4-17 -- 4.4-18.) F. ENERGY
The California Building Energy Efficiency Standards and CALGreen require energy efficient appliances and building materials that reduce energy consumption in new development. Furthermore, vehicle fuel efficiency is anticipated to continue improving through implementation of the existing Pavley regulations in accordance with Assembly Bill 1493. The City’s General Plan/Coastal Land Use Plan includes Policies TE 1.6, TE

7.2, and TE 7.12 which allows the City to require developers to provide improvements that reduce the use of single-occupancy vehicles, requires the City to collaborate with the Santa Barbara Metropolitan Transit District to ensure bus transit is reliable throughout Goleta, and allows the City to require new or substantially renovated development to incorporate design measures to facilitate transit use. The City’s CAP includes measures such as requiring projects to dedicate land for bicycle trails, requiring projects along transit corridors to provide for transit access, and requiring preferential parking to commuters who carpool, vanpool, ride -share, or use alternatively fueled vehicles. Continual implementation of these policies in the City’s General Plan/Coastal Land Use Plan and measures included in the City’s CAP would ensure new development w ould promote alternative transportation and reduce vehicle travel.

As a result of increasing energy efficiency standards associated with electricity and natural gas consumption, water use, and transportation, the combined increase in energy consumption in Goleta would not be expected to result in wasteful, inefficient, and unnecessary consumption of energy resources. Therefore, cumulative energy impacts 185
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
152 | P a g e

would be less than significant. The project would adhere to California Building Energy Efficiency Standards and CALGreen energy -efficiency requirements. Thus, the project would not have a cumulatively considerable contribution to cumulative energy consumption impacts. Cumulative development would be constructed in accordance with the California Building Ener gy Efficiency Standards, CALGreen requirements, and the City’s CAP. Cumulative development would receive electricity that is procured in compliance with SB 100 which would promote the use of renewable energy. As a result, cumulative impacts related to conf licts with renewable energy plans would be less than significant, and the project would not have a cumulatively considerable contribution to cumulative impacts to conflicts with renewable energy plans.

G. GEOLOGY AND SOILS
Cumulative projects proposed in an d around Goleta would expose additional people and property to seismic and geologic hazards that are present in the region. The magnitude of geologic hazards for individual projects would depend upon the location, type, and size of development and the spec ific hazards associated with individual sites.

Any specific geologic hazards associated with each individual site would be limited to that site without affecting other areas. In addition, existing regulations, including compliance with CBC requirements, would reduce seismic and geologic hazards to acceptable levels.

Seismic and geologic hazards would be addressed on a case -by-case basis and would not result in considerable impacts. Cumulative geology and soils impacts would be less than significant. Areas t hroughout Goleta would continue to be developed and redeveloped and involve grading and excavation activities that would potentially encounter paleontological resources. Given the high sensitivities of geologic units underlying Goleta, cumulative projects could potentially damage paleontological resources or unique geologic features. Therefore, cumulative impacts would be potentially significant. Ground -disturbing activities associated with the proposed project have the potential to result in the destructio n, damage, or loss of undiscovered scientifically important paleontological resources due to the high paleontological sensitivity of the underlying geologic units. However, implementation of Mitigation Measure GEO -2 would minimize the potential for the pro posed project to cause a substantial adverse change in known or unknown paleontological resources by requiring WEAP training, monitoring, and setting forth procedures for the recovery, identification, and curation of fossils discovered during construction. Therefore, with mitigation, the proposed project’s contribution to cumulative impacts related to paleontological resources or unique geologic features would not be considerable. (Revised Draft EIR, p. 4.5-16.) H. GREENHOUSE GAS EMISSIONS
The construction an d operation of development statewide would emit GHG emissions which have the potential to exceed applicable GHG emissions thresholds established by cities, counties, air pollution control districts, or other relevant agencies. 186
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
153 | P a g e

Such projects that would resu lt in GHG emissions above a threshold level could still be developed through as Statement of Overriding Considerations which permits a project even if it would have significant and unavoidable impacts. These GHG emissions thresholds enforced by local agenc ies are designed to assist the local agency in contributing to statewide emissions reductions targets. Given that development could occur even if it would exceed local GHG emissions thresholds, cumulative impacts related to GHG emissions would be significant.

GHG impacts are assessed in a cumulative context since no single project can cause a discernible change to the climate. Therefore, the proposed project’s potential to contribute to significant cumulative GHG impacts is evaluated based on the same thresholds as used for project-level evaluation. In the absence of a City-adopted numeric threshold, the significance of the proposed project’s GHG emissions is evaluated on the County’s threshold of 2.68 MT CO2e per resident per year. In addition, consistency with applicable plans, policies, regulations, and requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions. For this project, the most directly applicable adopted regulatory plans to reduce GHG emissions are the 2022 Scoping Plan, the 2050 RTP/SCS, the City of Goleta General Plan/Coastal Land Use Plan, and the City of Goleta’s CAP. The proposed project would not exceed the County’s 2.68 MT CO2e per resident per year threshold. The proposed project would be consistent with the statewide, regional, and local plans by including energy and water conservation measures, and solar readiness consistent with the latest iteration of CALGreen and the Building Energy Efficiency Standards. Furthermore, the proposed project would not convert natural lands and would contribute to the job and housing balance by increasing the local housing supply in Goleta, thereby providing employees who work in Goleta with additional opportunities to relocate closer to their place of work and reduce long -distance commuting. Thus, the proposed project’s contribution to cumulative GHG impacts would not be considerable. (Revised Draft EIR, pp. 4.6-15 -- 4.6-16.)
I. HAZARDOUS AND HAZARDOUS MATERIALS
Cumulative projects proposed in the geographic scope would have the potential to expose future area residents, employees, and visitors to hazards by developing areas that may have previously been contaminated. The magnitude of hazards for individual projects would depend upon the location, type, and size of development and the specific hazards associated with individual sites. If soil and/or groundwater contamination are found to be present on sites of planned and future development, these conditions would be required to comply with existing applicable local, State, and federal regulations.

Hazard evaluations would be completed on a case-by-case basis for future development.

Compliance with applicable regulations and implementation of appropriate mitigation measures, including remedial action on contaminated sites, would address impacts related to these hazards and hazardous materials associated with future development in the City. Hazardous materials regulations are designed to prevent, contain, and remediate hazardous materials incidents at b oth the project and regional scale. These 187
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
154 | P a g e

regulations require site -specific hazardous materials business plans, emergency response protocols, and proper training and certification for handlers and transporters.

When applied cumulatively across multiple dev elopments, these regulatory frameworks create a consistent and enforceable system that minimizes the potential for overlapping or compounding hazardous materials risks.

Cumulative impacts related to the creation of a significant hazard to the public or the environment through the routine transport, use or disposal of hazardous materials; accidental release of hazardous materials; handling of hazardous materials within 0.25 mile of a school; or location of an existing hazardous material site would therefore be less than significant.

All cumulative projects would be required to adhere to the Santa Barbara County Multi-Jurisdictional Hazard Mitigation Plan, which includes comprehensive actions for emergency response and evacuation, ensuring that all projects within Santa Barbara County adhere to established protocols. The Multi -Jurisdictional Hazard Mitigation Plan includes coordinated emergency response strategies, evacuation route planning, and interagency communication protocols that are implemented at the project level through conditions of approval, construction traffic management plans, and fire department oversight. Each cumulative project must demonstrate that emergency vehicle access is maintained during construction and that evacuation routes remain u nobstructed, even under temporary traffic control. These requirements are enforced through project-specific review by the Santa Barbara County Fire Department and other emergency service providers. Past, present, and reasonably foreseeable future projects, including the projects listed in Table 3-1, would not impair implementation of or physically interfere with evacuation plans, as projects would be required to maintain clear access routes and ensure that construction activities do not obstruct evacuation routes. Therefore, cumulative impacts related to emergency response would be less than significant.

Cumulative projects would involve construction over various periods of time and would therefore have the potential to cause wildfires through equipment that could create sparks, be a source of heat, or leak flammable materials on cumulative projects’ sites.

Accordingly, cumulative impacts related to wildland fire would be potentially significant.

Construction and operation of the proposed project would occur in compliance with applicable regulations, such as the California Public Resources Code, which would reduce the risk of wildfire during construction and operation. These regulations include, but are not limited to, PRC Sections 4290 and 4291, which establ ish defensible space requirements, emergency access standards, and vegetation management protocols.

When applied cumulatively to individual project sites, these regulations ensure that ignition sources are minimized, emergency response access is maintained , and vegetation is managed to reduce fuel loads. The proposed project would underground utility lines on -site to minimize the risk of fire from utilities. Operation of the proposed project would not introduce new activities that could substantially increa se the risk of wildland fire. In addition, operation of the proposed project would not induce substantial vehicle use such that emergency evacuation on Cathedral Oaks could be impeded in the 188
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
155 | P a g e

event of a wildland fire. Therefore, the proposed project’s contr ibution to cumulative impacts related to the risk of loss, injury, or death involving wildland fire would not be considerable. (Revised Draft EIR, pp. 4.7-24 -- 4.7-26.) J. HYDROLOGY AND WATER QUALITY
The geographic scope for cumulative impacts related to wat er quality, drainage, and sedimentation is the El Encanto Creek watershed. This geographic scope is appropriate as stormwater from development in this area would discharge to El Encanto Creek and could contribute to existing impairments in El Encanto Creek. The geographic scope for cumulative impacts related to groundwater are projects within the GWD service area. This geographic scope is appropriate as GWD would provide water to cumulative development which, in part, is sourced from the Basin. As the propo sed project would result in no impact related to flooding, the proposed project has no potential to contribute to cumulative impacts related to flooding. As such, cumulative impacts related to flooding are not discussed herein.

Water Quality, Drainage, and Sedimentation
Cumulative development in Goleta would increase impervious surfaces, redirect the drainage of surface flow during storm events, and increase pollutant loading, peak flows, erosion, sedimentation, and flooding. For the cumulative analysis related to hydrology and water quality, cumulative projects being considered include the projects discharging to the same waters as the proposed project (i.e., El Encanto Creek). El Encanto Creek is impaired by a variety of pollutants, including turbidity, E. coli, nitrate, dissolved oxygen, and imbalanced pH levels (SWRCB 2025). The Annual Pavement Rehabilitation Project and Pavement Management Program and Glen Annie Golf Course Residential Development are examples of cumulative projects that would also potentially discharge stormwater runoff to El Encanto Creek and contribute to pollutant loading in stormwater runoff discharged to these waterways. Cumulative projects would be required to comply with federal, state, and City water quality requirements, such as the Construction Stormwater General Permit, Post-Construction Requirements, the Phase II MS4 Permit, and Chapter 13.04 of the City’s Municipal Code. Further, cumulative projects would be required to implement mitigation if, due to project -specific circumstances, a potential impact to water quality could occur.

However, the proximity of cumulative development to El Encanto Creek could continue to result in continued impairment of the waterway. Due to the existing impairment of El Encanto Creek and the potential for cumulative development to discharge pollutants to El Encanto Creek, cumulative impacts to water quality, drainage, and sedimentation would be significant. The proposed project’s demolition activities would be required to obtain coverage from SWRCB’s Construction Stormwater General Permit, which includes requirements for projects to address demolition -related pollutants. The construction contractor would also be required to comply with Mitigation Measures HAZ-1 and HAZ-2 to minimize the potential for pollutants associated with asbestos and lead-based materials 189
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
156 | P a g e

would enter runoff and degrade water quality. Construction would also be required to obtain coverage from the Construction Stormwater General Permit, which requires preparation and implementation of a SWPPP to control the discharges of pollutants, including sediment, into local surface water drainages through implementation of erosion and sediment control BMPs and good housekeeping BMPs. During operation, the proposed project would comply with Chapter 13.04 o f the City’s Municipal Code by utilizing Source Control and LID BMPs to detain, retain, and treat runoff consistent with the requirements of the Central Coast RWQCB’s Post Construction Requirements and the County’s Stormwater Technical Guide for Low Impact Development. The proposed project would implement a detention basin and underground detention system in accordance with the Stormwater Control Plan (Appendix I) prepared for the proposed project, which serves as the SWQMP for the proposed project. Complia nce with these existing regulations to protect water quality, installation of stormwater control and treatment infrastructure proposed as part of project design, and implementation of Mitigation Measures HAZ-1 and HAZ-2, would ensure the proposed project’s contribution to significant cumulative water quality impacts would not be considerable.

Groundwater
Development of the cumulative projects in Goleta would add a total of 534 residential units, 440,599 square feet of industrial space, and 163,930 square feet of commercial space in Goleta, in addition to the potential construction of up to 1,000 residential units on the Glen Annie Golf Course site, which would increase water demand in the GWD service area. Cumulative projects that are provided water by GWD would increase water demand from GWD which may, in part, be met by groundwater sourced from the Goleta Basin. However, GWD is subject to the adjudication requirements of the Wright Judgement and is only permitted to extract water in accordance with the allocations determined by the Wright Judgement. Accordingly, although cumulative development served by GWD would increase water demand, GWD is not permitted to increase groundwater extraction such that GWD would exceed their allocation of up to 2,000 acre-feet per year. Cumulative projects served by GWD would be subject to GWD’s adjudication requirements of the Wright Judgement and therefore would not receive a water allocation if project’s water demand would cause GWD to exceed their allocation of 2,000 acre-feet per year from the Goleta Basin in order to serve the cumulative project.

As a result, cumulative impacts related to sustainable groundwater management would be less than significant. (Revised Draft EIR, pp. 4.8-20 -- 4.8-21.) K. LAND USE AND PLANNING
Cumulative projects within the geographic scope would consist of construction of a total of 534 residential units, 440,599 square feet of industrial space, and 163,930 square feet of commercial space. Cumulative projects also include oil and gas infrastructure removal, animal shelter renovations, construction and renovation of medical facilities, parkland improvements, one synagogue, one church, hotel renovations, battery energy storage infrastructure, restoration and habitat management activities, and various 190
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
157 | P a g e

roadway improvements. Past, present, and reasonably foreseeable future projects would not physically divide an established community. Most cumulative projects would not include the construction of new linear features that could prevent mobility of a community.

Cumulative projects that include new linear features, such as the planned construction of a new overcrossing over U.S. Highway 101, would improve connectivity within the city of Goleta. Conflicts regarding compatibility between past, present, and re asonably foreseeable future projects and applicable land use plans, policies, or regulations would be localized and addressed on a case-by-case basis. The City General Plan/Coastal Land Use Plan, Municipal Code, and other relevant land use or planning documents are legally binding documents guiding land use and development decisions within the city. All cumulative projects must be reviewed for consistency, and if determined to have conflicts with these plans, they would not be approved. Therefore, cumulative development would not result in a significant cumulative impact to land use and planning. (Revised Draft EIR, p. 4.9-44.)
L. NOISE
Some construction activities from the Annual Pavement Rehabilitation Project and Pavement Management Program and Glen Annie Golf Course Residential Development may occur within several hundred feet of the nearest sensitive receivers and therefore may expose these receivers to construction noise simultaneously with construction noise generated by the proposed project, which could result in increased noise exposure to the sensitive receivers from combined noise levels. Although real world conditions would likely minimize the cumulative effect via noise direction, angles, attenuation, and dispersion, cumulative construction noise impacts could still occur and this impact would be potentially significant.

The proposed project would include implementation of Mit igation Measure NOI-1 to reduce project construction noise levels to comply with Goleta’s construction noise thresholds. As project construction would not generate a substantial increase in ambient noise levels with mitigation, the proposed project’s contribution to cumulative construction noise impacts would not be considerable. Similar to construction noise, construction vibration is localized and rapidly attenuates within a developed area. Potential vibration from the Annual Pavement Rehabilitation Proje ct and Pavement Management Program and Glen Annie Golf Course Residential Development would occur from a different direction from the nearest sensitive receiver than the proposed project and thus approach different angles of the nearest vibration sensitive receivers, ensuring the vibration travels further distances before it could theoretically combine with the proposed project’s vibration. As the Annual Pavement Rehabilitation Project and Pavement Management Program and Glen Annie Golf Course Residential Development would be constructed at a similar or further distance from the nearest sensitive receiver, associated vibration levels would be anticipated to be well below vibration limits as well. While higher vibration levels can occur from activities such a s blasting or pile driving, construction that occurs in bedrock areas or involves substantial underground excavation requiring building piles would not be anticipated for the Annual Pavement Rehabilitation Project and Pavement 191
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
158 | P a g e

Management Program or Glen An nie Golf Course Residential Development. Therefore, the combined vibration level from cumulative projects would still be well below vibration limits, and no cumulative construction vibration impact would occur.

The Annual Pavement Rehabilitation Project an d Pavement Management Program would not have an operational component. The Glen Annie Golf Course Residential Development would have an operational component which would include similar residential operations as the proposed project. Operational noise woul d be localized and rapidly attenuate due to the effects of distance, intervening structures, and topography that block the line of sight. Therefore, the ability of on -site project noise to combine with noise from off -site sources to create a substantial in crease in noise levels would not occur. However, cumulative projects could create a cumulative increase in off- site traffic noise if the cumulative increase in vehicle trips resulting from cumulative development would result in a 3 dBA or greater increase in traffic noise on Cathedral Oaks Road. As such, cumulative operational traffic noise impacts would be potentially significant. The proposed project’s addition to traffic would not result in a noticeable off - site traffic noise increase; thus, the proposed project’s traffic noise increase would not result in considerable contribution to significant cumulative traffic noise impacts. (Revised Draft EIR, pp. 4.10-12 -- 4.10-13.)
M. TRANSPORTATION
Cumulative development in Goleta would be subject to the same trans portation- related programs, plans, ordinances, and policies as the proposed project. Specifically, cumulative development would be required to demonstrate consistency with the City’s Transportation Element, which guides the continued development and improv ement of the transportation system in Goleta. The Annual Pavement Rehabilitation Project and Pavement Management Program is currently under construction and may require closure of Cathedral Oaks Road and other roads near the project site. Road closures for this project in combination with changes to transportation and circulation as a result of other future development projects in the vicinity that may require road closures, new design features, or rerouting of traffic could result in a potentially signific ant cumulative impact related to existing roadway, pedestrian, bicycle, or transit facilities. The proposed project would require temporary lane closures along Cathedral Oaks Road during frontage improvements. These closures could result in short -term disr uptions of multi -modal transportation on Cathedral Oaks Road. As a Condition of Approval, the project applicant’s construction contractor would be required to implement a Construction Traffic Management Plan. This plan would include coordination with the C ity and emergency service providers to avoid overlapping closures, which would minimize the potential for the proposed project to contribute to cumulative roadway, bicycle, pedestrian, or transit route closures or detours. The proposed project would includ e features such as the extension of the Class I multi -use path on Cathedral Oaks Road and incorporation of bicycle and pedestrian facilities on -site that would provide increased opportunities for multi-modal transportation. Accordingly, the proposed project’s contribution to cumulative impacts on roadway, bicycle, and pedestrian facilities would not be considerable. 192
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
159 | P a g e

Significant cumulative VMT impacts could occur if cumulative development increases VMT in the City beyond established thresholds. Cumulative pr ojects include 470 residential units, 379,568 square feet of industrial space, and 203,113 square feet of commercial space, each of which could induce additional vehicle travel above City - established thresholds. Accordingly, cumulative impacts would be pot entially significant.

The proposed project would generate 21.24 VMT per resident, which exceeds the City’s threshold of 16.79 VMT per resident. Although the proposed project includes design features and Mitigation Measure TRA-1 that would reduce VMT, cumulative VMT impacts would remain significant and unavoidable because the reduction would not reduce VTM below the City’s threshold. Therefore, the proposed project’s contribution to cumulative VMT impacts would be considerable.

The Annual Pavement Rehabilit ation Project and Pavement Management Program is currently under construction and may require closure of Cathedral Oaks Road and other roads near the project site. Road closures for this project in combination with changes to transportation and circulation as a result of other future development projects in the vicinity that may require road closures, new design features, or rerouting of traffic could result in the creation of transportation hazards or substantial delays in emergency access. Therefore, cumulative impacts related to transportation hazards and emergency access would be potentially significant. The proposed project would require temporary lane closures along Cathedral Oaks Road during frontage improvements. These closures could result in short -term disruptions to traffic flow and emergency access in the immediate area. As a Condition of Approval, the project applicant’s construction contractor would be required to implement a Construction Traffic Management Plan. This plan would include coordina tion with the City and emergency service providers to avoid overlapping closures and maintain emergency access. In addition, this plan would minimize potential transportation hazards on Cathedral Oaks Road. With implementation of this plan, the proposed pr oject’s contribution to cumulative impacts related to transportation hazards and emergency access would not be considerable. (Revised Draft EIR, pp. 4.11-11 -- 4.11-12.)
N. TRIBAL CULTURAL RESOURCES
The geographic scope for considering cumulative impacts to tribal cultural resources is based on the ethnographic use patterns of the project site and surrounding region. For the ethnographic period, the geographic extent includes the entire traditional Chumash territory. Development of past, present, and reasonab ly foreseeable future developments could cumulatively contribute to the erasure of tribal cultural resources from the landscape. However, compliance with existing regulations protecting tribal cultural resources, including the provisions of AB 52, would en sure that any known or potential tribal cultural resources are treated in consultation with local Native American groups. Compliance with AB 52, implementation of project -specific measures to protect tribal cultural resources on a case -by-case basis, and c ontinued involvement by local Native American groups in regional planning would generally limit the destruction of tribal cultural resources such that cumulative impacts would be less than significant. ( Revised 193
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
160 | P a g e

Draft EIR, p. 4.12-7.)
O. UTILITIES AND SERVICE SYSTEMS
Development of the cumulative projects in Goleta, and the residential development at the Glen Annie Golf Course would add a total of approximately 1,534 residential units, 440,599 square feet of industrial space, and 163,930 square feet of commerci al space which would increase water demand in the GWD service area. Using water demand rates for the County’s 2024 Environmental Thresholds and Guidelines Manual for multifamily development (0.22 AFY/unit), light industry (0.28 AFY/1,000 square feet), and general commercial development (0.30 AFY/1,000 square feet), the additional water demand from cumulative development, assuming all projects are approved and constructed, is estimated at approximately 510 AFY. The estimated cumulative water demand of 510 AFY represents approximately 11.3 percent of the 2040 normal year water supply surplus, and approximately 17.5 percent and 21.2 percent of GWD’s dry year one and dry year two water supply surpluses, respectively. GWD’s UWMP identifies that, during years three through five of a drought, water supply and demand would be balanced with the implementation of water conservation measures.

The GWD UWMP estimates a population project of 34,300 for Goleta by 2040 (GWD 2021). The City has an average of 2.59 persons per household (California Department of Finance 2025). Based on the addition of 534 residential units in addition to the proposed project’s 56 residential units, cumulative growth in Goleta would increase Goleta’s population to 34,173 residents, which would b e within the growth projections of the GWD UWMP. Cumulative projects would adhere to the Goleta Water District Code, including water shortage restrictions during drought which would allow GWD to meet water demands during a five -year drought. Pursuant to th e SAFE Water Supplies Ordinance, GWD is permitted to allocate a maximum 154.7 acre -feet of water to new or additional development in 2025 (GWD 2024b). The water demand associated with cumulative development is anticipated to exceed the 154.7 acre-feet allocation; however, all cumulative development would not request water allocations in 2025. GWD determines the available supply for the next year annually each December. Pursuant to the Goleta Water District Code, cumulative development may utilize GWD’s perm itted allocation on a first-come-first-serve basis each year that water supply is available. Each cumulative project would be required to obtain a Can and Will Serve letter from GWD, which would confirm that water supply available for that project. GWD is required to reevaluate its supplies annually to determine if it can continue to issue new water allocations. In the event GWD determines inadequate supplies are available to serve new projects in the future, GWD cannot release potable service water to new or additional service connections unless certain specific conditions are met. Beyond 2025, if GWD determines it cannot allocate water supply to new connections, only the cumulative development projects that receive a water supply allocation would be able t o be constructed until additional water supplies become available, including through transfer of water supply from other water agencies or third parties via water wheeling.. Therefore, because development can only occur if water supplies to serve that development are available and 194
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
161 | P a g e

allocated by GWD, cumulative development would not deplete GWD’s projected water surpluses such that a substantial reduction in water supplies would occur. Therefore, cumulative development would have a less than significant impac t related to having sufficient water supplies available during normal, dry, and multiple dry years. Cumulative development in Goleta would also increase wastewater generation.

Consistent with the wastewater generation factors used in the City of Goleta General Plan/Coastal Land Use Plan Final EIR (184 to 220 gallons per day per residential unit, and 100 gallons per day per 1,000 square feet of habitable space for commercial and industrial development), cumulative development would generate approximately 161,668 gallons per day of wastewater, or approximately 0.16 MGD. This calculation assumes all residential units would generate 220 gallons of wastewater per unit per day.

This wastewater generation represents approximately 6.1 percent of the remaining 2.63 MGD capacity available at GSD’s WWTP. Therefore, cumulative development would have a less than significant impact related to exceeding a wastewater treatment provider’s treatment capacity. Cumulative development would introduce new structures which would require installation of stormwater infrastructure, the construction of which could cause potential environmental impacts such as habitat disruption, erosion, or water quality degradation. The construction of stormwater infrastructure must occur in compliance with applicable federal, state, and City water quality requirements, such as the Construction Stormwater General Permit and Chapter 13.04 of the City’s Municipal Code. As described in Section 4.8, Hydrology and Water Quality, requirements include implementation of best management practices designed to minimize erosion and retain sediment onsite, and reduce the risk of spills, leaks, and off -site discharge of construction debris and waste.

Nevertheless, construction of stormwater infrastructure near waterw ays could result in impairment of water quality within the waterways resulting in significant cumulative impacts related to stormwater infrastructure installation.

The proposed project would include stormwater infrastructure, the environmental impacts of which are evaluated throughout this EIR. Installation of the proposed project’s stormwater infrastructure would occur in compliance with the Construction Stormwater General Permit, Chapter 13.04 of the City’s Municipal Code, and with implementation of Mitigation Measure BIO -5 to minimize the potential for pollutants associated with construction equipment used for stormwater infrastructure installation to leak or spill and degrade water quality in El Encanto Creek. Compliance with existing regulations, and implementation of Mitigation Measure BIO -5 would ensure the proposed project’s contribution to significant cumulative impacts related to stormwater infrastructure installation would not be considerable. Cumulative development would raise the demand for electricity and natural gas in the SCE, Central Coast Community Energy, and Southern California Gas (SCG) service areas. However, SCE and the Southern California Gas Company service a majority of southern California, while Central Coast Community Energy is ava ilable across the central coast of California. Cumulative development in Goleta represents approximately 0.05 percent of Central Coast Community Energy’s service population, 0.004 percent of SCE’s service population, and approximately 0.003 195
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
162 | P a g e

percent of the Southern California Gas Company’s service population (Central Coast Community Energy 2025; SCE 2025; Southern California Gas Company 2025).

Accordingly, the demand placed by cumulative development in Goleta compared to the respective service populations of SCE, Central Coast Community Energy, and/or Southern California Gas Company is not anticipated to result in substantial energy demand such that new SCE, Central Coast Community Energy, and/or Southern California Gas Company facilities would be required. T herefore, cumulative impacts related to requiring the relocation or reconstruction of new electricity and natural gas infrastructure would be less than significant.

Similar to electricity and natural gas demand, cumulative development would increase the demand for telecommunications infrastructure. However, Verizon and AT&T provide extensive telecommunications infrastructure in Goleta which ensures telecommunications coverage is provided citywide to serve cumulative development (Doggett 2025). Therefore, c umulative impacts related to requiring the relocation or reconstruction of new telecommunications facilities would be less than significant.

Cumulative development would increase solid waste generation, thereby reducing the capacity of the Tajiguas Landfil l and potentially the Kettleman Hills Facility, if contaminated soil disposal is required. This is a potentially significant cumulative impact on solid waste.

According to the County’s 2024 Environmental Thresholds and Guidelines Manual, if solid waste ge neration exceeds 196 tons/year, it is considered to be cumulatively significant. If solid waste generation exceeds 40 tons per year, but is less than 196 tons/year, it is considered an adverse, yet less than significant, contribution to cumulative impacts to solid waste facilities. Solid waste generation from demolition and construction of the proposed project is estimated to be 193 tons, and the proposed project’s operational solid waste is estimated to be 69 tons per year. Therefore, project construction and operation would have an adverse, but not considerable contribution to cumulative impacts related to generating excessive solid waste and compliance with federal, state, and local solid waste management and reduction statutes. ( Revised Draft EIR, pp. 4.13-15 -- 4.13-17.)
P. WILDFIRE
The proposed project would result in no impact related to flooding; therefore, the proposed project has no potential to contribute to cumulative impacts related to risks of downslope or downstream flooding. As such, cumulative i mpacts related to risks of downslope or downstream flooding are not discussed herein. Tthe Annual Pavement Rehabilitation Project and Pavement Management Program is currently under construction and the Glen Annie Golf Course Residential Development is loca ted adjacent to the project site and would involve the construction of up to 1,000 residential units. These projects may require closure of Cathedral Oaks Road and other roads near the project site. Road closures for these project in combination with chang es as a result of other future development projects in the vicinity that may require road closures, new 196
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
163 | P a g e

design features, or rerouting of traffic could result in delays in emergency evacuation.

Therefore, cumulative impacts related to emergency evacuation w ould be potentially significant. The proposed project would require temporary lane closures along Cathedral Oaks Road during frontage improvements. These closures could result in short -term disruptions to traffic flow and emergency access in the immediate area. As a Condition of Approval, the project applicant’s construction contractor would be required to implement a Construction Traffic Management Plan. This plan would include coordination with the City and emergency service providers to avoid overlapping closures and maintain Cathedral Oaks Road for emergency evacuation. With implementation of this plan, the proposed project would not result in a considerable contribution to potential cumulative impacts related to emergency evacuation.

The City of Goleta is within an LRA, but is surrounded by land classified as an SRA. The majority of land north of the project site is classified as a very high FHSZ. There are also areas of moderate FHSZs in SRAs along the western edge of the city and just southeast of Goleta (CALFIRE 2024b). Within the city, there are areas of moderate, high, and very high FHSZs along the northern border of the city within the LRA. There is also an area of moderate FHSZ along the southwestern portion of the city within an LRA (CAL FIRE 202 5). Cumulative wildfire -related impacts could be significant if cumulative development would occur in rural or high fire hazard areas that could exacerbate risks due to location on steep slopes, in high -wind areas, or areas of historical wildfire burn areas. Cumulative development and infrastructure would be subject to Statewide standards for fire safety in the California Fire Code and local regulations. However, existing codes and regulations cannot fully prevent wildfires from damaging structures or populations, and cumulative impacts related to exposing occupants to pollutant concentrations for wildfire, the uncontrolled spread of a fire, and fire risk associated with the installation of infrastructure would be potentially significant. The proposed projec t would be located within a very high FHSZ. The project itself is designed to increase fire breaks and access for emergency response crews and adheres to defensible space requirements.

While the proposed project would require the extension of power, water, and other utilities to the site, no overhead power lines would be required, and all infrastructure would be designed and installed compliant with local and State regulations, including the CBC, CFC, and SBCFD development requirements. These standards req uire fire -resistant construction, defensible space, and adequate emergency access, all of which would reduce structure ignition and fire spread. The project’s underground utilities and enhanced emergency access further reduce ignition risk and improve response capability.

Because the proposed project would comply with existing regulations intended to reduce the risk and spread of wildfire, the project would not result in a considerable contribution to cumulative wildfire impacts related to exposing occupant s to pollutant concentrations for wildfire, the uncontrolled spread of a fire, and fire risk associated with the installation of infrastructure.

Wildfire within Goleta could expose additional people or structures to risks 197
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
164 | P a g e

including landslides as a result of post-fire instability. The magnitude of such hazards depends on site -specific conditions, such as slope, soil type, and vegetation cover.

Cumulative projects within the region are subject to mandatory compliance with the CBC, which requires geotechnical investigations and site -specific engineering solutions to address slope stability. Because each cumulative project must evaluate and mitigate its own geologic hazards through site-specific design and regulatory compliance, the risk of post-fire landslides is localized and not expected to compound across projects.

Accordingly, cumulative impacts related to risks associated with post-fire slope instability would be less than significant. (Revised Draft EIR, pp. 4.14-22 -- 4.14-26.)

198
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
165 | P a g e

SECTION VI.

FINDINGS REGARDING SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL

CHANGES
Sections 15126(c) and 15126.2(c) of the CEQA Guidelines, require that an EIR address any significant irreversible environmental changes that would occur should the project be implemented. Generally, a project would result in significant irreversible environmental changes if any of the following would occur:
 The project would involve a large commitment of non-renewable resources;  The primary and secondary impacts of the project would generally commit future generations to similar uses;
 The project involves uses in which irreversible damage could result from any potential environmental accidents; or
 The proposed consumption of resources is not justified.

CEQA Guidelines Section 15126.2(b) requires that an EIR identify significant impacts that a project would cause which cannot be reduced to less than significant with the application of mitigation measures.

Most potentially significant impacts of the proposed project would be reduced to less th an significant through implementation of mitigation measures. However, implementation of the proposed project would result in one significant and unavoidable impact. The proposed project would generate 21.24 vehicle miles traveled (VMT) per resident, which exceeds the City of Goleta’s threshold of 16.79 VMT per resident. Given that vehicle miles are distributed regionally and based on the project site’s proximity to unincorporated Santa Barbara County, the County of Santa Barbara VMT tool was also used to estimate project VMT in relation to County thresholds. Using the County’s VMT calculator, the project is estimated to generate 15.9 VMT per resident, which exceeds the County threshold of 14.9 VMT per resident. Mitigation Measure TRA -1, requiring a Vehicle Miles Traveled Reduction Plan, could potentially reduce VMT to 12.75 VMT per resident for the County, which would be below the County’s threshold of 14.9 VMT per resident.

However, with Mitigation Measure TRA -1, VMT could potentially be reduced to

17.03 VMT per resident for the City of Goleta and the project would still exceed the City VMT threshold of 16.79 VMT per resident. Furthermore, the implementation of some VMT reduction programs (i.e., improve design of development, extend transit network coverage or hours) could result in additional ground -disturbing activities which would result in additional environmental impacts associated with increased ground disturbance.

Therefore, the impact would remain significant and unavoidable. No other significant unavoidable impacts have been identified. All other potentially significant impacts, 199
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
166 | P a g e

including those related to air quality, noise, biological resources, water supply, and utilities, would be reduced to less than significant levels through mitigation or compliance with existing regulations. (Revised Draft EIR, p. 5-2.) Irreversible Environmental Effects
CEQA Guidelines Section 15126.2(d) requires a discussion of any significant irreversible environmental changes which would be caused by implementation of the proposed project. Such significant irreversible environmental changes may include the following:
 Use of non-renewable resources during the initial and continued phases of the project which would be irreversible because a large commitment of such resources makes removal or non-use unlikely.
 Primary impacts and, particularly secondary impacts (such as highway improvement which provides access to a previously inaccessible area) which generally commit future generations to similar uses.  Irreversible damage, which may result from environmental accidents associated with the project.

Development of the proposed project would result in a long -term commitment of the project site to residential use. The site is currently a large fallow field with three small buildings including a single family residence and historically used for agriculture. It would be permanently altered through the removal of existing on-site structures and construction of 56 single -family homes, internal roadways, stormwater infrastructure, and ut ility connections. This change in land use would be irreversible and would commit the site to urban development, precluding future agricultural or open space uses. Construction of the proposed project would require the consumption of non -renewable resource s, including fossil fuels (e.g., gasoline and diesel), building materials (e.g., concrete, steel, and lumber), and energy. These resources would be used for site preparation, grading, infrastructure installation, and construction. Although the project incorporates sustainable design features, such as all -electric buildings, solar readiness, efficient HVAC systems, and water -conserving fixtures, operation of the project would still require ongoing consumption of electricity, potable water, and other resource s. Utilization and consumption of these resources would occur with any development in Goleta and are not unique to the proposed project.

The proposed project would result in a permanent increase in demand for water supply, wastewater treatment services, and solid waste disposal services. These service demands represent a long-term commitment of public resources. However, the proposed project’s water demand (approximately 39.81 acre-feet per year) is consistent with long- range planning forecasts (Goleta Wat er District 2021). Wastewater and solid waste impacts would also be less than significant because the project would not exceed the 200
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
167 | P a g e

capacity of existing infrastructure or violate applicable reduction and diversion standards.

The proposed project would also result in a permanent increase in vehicle trips, contributing incrementally to regional air pollutant and greenhouse gas emissions.

However, these impacts would be less than significant. No irreversible environmental damage due to environmental accidents ( e.g., hazardous materials spills) is anticipated because the project does not involve industrial uses nor hazardous operations and would comply with applicable safety and construction standards.

Development accommodated by the proposed project would resul t in an irreversible commitment of land to residential use and long -term consumption of natural and non-renewable resources, including electricity, potable water, and building materials.

These impacts would be less than significant. (FEIR, pp. 5-2 – 5-3.) SECTION VII.

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

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

Population Growth
According to the California Department of Finance (2025), the current population of Goleta is approximately 32,747 people. The proposed project would facilitate construction of 56 single -family residential units. Based on the City of Goleta’s average household size of 2.59 persons per household (California Department of Finance 2025), the proposed project would result in an estimated population increase of approximately 145 residents, bringing the total city population to approximately 32,892 residents. This increase is within the growth projections developed by the Santa Barbara County 201
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
168 | P a g e

Association of Governments, which estimate that Goleta’s population will reach 34,700 by 2050 (Santa Barbara County Association of Governments 2019). The proposed project would not exceed regional growth projections or induce growth beyond what is planned in the City’s General Plan or regional planning documents. Therefore, the proposed project would not induce substantial population growth that could lead to substantial adverse environmental effects. (Revised Draft EIR, p. 5-1.) Economic Growth
The proposed project would generate temporary employment opportunities during construction. Based on the size of the project and scale of construction, construction workers would be exp ected to be drawn from the existing regional workforce. As such, construction of the project would not be growth -inducing from a temporary employment standpoint. The proposed project would not include commercial, industrial, or other employment-generating uses and would not result in long -term job creation. Therefore, the proposed project would not induce economic expansion to the extent that substantial environmental impacts would occur. (Revised Draft EIR, p. 5-1.) Removal of Obstacles to Growth
The proposed project would develop residential uses within the City of Goleta on a site surrounded by residential, recreational, and open space uses. Access to the project site would be provided from existing roadways such as Cathedral Oaks Road, Storke Road, and United States Route 101. Aside from the internal on -site roadways which provide circulation within the project site, no new roadways would be required for the proposed project.

The project would utilize existing water, wastewater, stormwater, elec tric, and telecommunications infrastructure. Utility extensions would be limited to connections within the project site and to existing service lines beneath Cathedral Oaks Road. No additional infrastructure or facilities beyond those necessary to accommod ate the proposed project would be required. In addition, no undeveloped land in the vicinity of the project site would have new potential for development through the extension of utility services to the project site. For these reasons, implementation of th e proposed project would not extend infrastructure in a manner that would remove obstacles to growth in the project vicinity. (Revised Draft EIR, p. 5-1.)

SECTION VIII.

ALTERNATIVES
A. BACKGROUND
The Revised Draft EIR analyzed three alternatives to the Project as proposed and 202
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
169 | P a g e

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

Where significant impacts are identified, section 15126.6 of the State CEQA Guidelines requires EIRs to consider and discuss alternatives to the proposed actions.

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

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

In subsection 15126.6(c), the State CEQA Guidelines describe the selection process for a range of reasonable alternatives:
(c) The range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic objectives of the Project and could avoid or substantially lessen one or more of the significant effects. The EIR should briefly describe the rationale for selecting the alternatives to be discussed. The EIR should also identify any alternatives that were considered by the lead agency but were rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency’s determination. Additional information explaining the choice 203
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
170 | P a g e

of alternatives may be included in the administrative record. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts.

The range of alternatives required is governed by a “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The EIR shall include suf ficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed Project. Alternatives are limited to ones that would avoid or substantially lessen any of the significant effects of the Project.

Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the Project.

B. PROJECT OBJECTIVES
The following objectives have been established for the Project :
 Develop up to 56 residential units on underutilized land located within Goleta.
 Provide residential development in Goleta to fulfill the housing stock envisioned in the City’s adopted 2023-2031 Housing Element.  Provide housing opportunities for extremely low income, lower income, and moderate income level persons to support the City in complying with its Regional Housing Needs Allocation requirements.
 Improve accessibility and encourage active transportation for bicycles and pedestrians in Goleta.
 Design residenc es to incorporate green building measures to encourage the use of energy and water efficient technology.
(Revised Draft EIR, p. ES-5.)
C. ALTERNATIVES CONSIDERED BUT REJECTED FROM DETAILED

ANALYSIS
Section 15126.6(c) of the State CEQA Guidelines specifies that an EIR should (1) identify alternatives that were considered by the lead agency but were eliminated from detailed consideration because they were determined to be infeasible during the scoping process; and (2) briefly explain the reasons underlying the lead agency’s determination.

Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives; (ii) infeasibility; and/or 204
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
171 | P a g e

(iii) inability to avoid significant environmental impacts.

The following alternatives were considered but rejected as part of the environmental analysis for the Project:
 Alternative Location
 Reduced Scale
 Alternative Use
Finding: The City Council rejects the above alternatives, on the following grounds, each of which individually provides sufficient justification for rejection of this alternative:
(1) the alternatives do not avoid any significant and unavoidable impacts, ( 2) the alternatives would likely not further reduce any of the proposed project’s significant impacts; and (3) the alternatives are technically, financially, and legally infeasible given the reasons stated above. Therefore, these alternatives are eliminate d from further consideration. (Revised Draft EIR, pp. 6-2 – 6-4.)
D. EVALUATION OF ALTERNATIVES SELECTED FOR ANALYSIS
The alternatives selected for further detailed review within the EIR focus on alternatives that could the Project’s significant environmental impacts, while still meeting most of the basic Project objectives. Those alternatives include:
 Alternative 1: No Project/No Build Alternative (Revised Draft EIR, pp. 6-6 -- 6-14.)
 Alternative 2: By-Right Development (Revised Draft EIR, pp. 6-14 -- 6-

32.)
 Alternative 3: Mixed-Use Alternative (Revised Draft EIR, pp. 6-32 -- 6-

48.)

1. Alternative 1: No Project/No Build Alternative
Description: Alternative 1 assumes that if the proposed project is not approved, the site would remain in its existing condition. The existing condition includes a 2,015- square-foot residence, 726-square-foot garage, and 1,152- square-foot barn, all of which are vacant and would remain vacant under this alternative. The project site had an avocado orchard until the mid-1990s, a remnant of which is evident on the northern third of the lot. The project site is currently used in part for the splitting and storage of woodc hips and firewood, which would continue under Alternative

1. Alternative 1 would not result in any development on the project site. (Revised Draft EIR, p. 6-6.)
205
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
172 | P a g e

Impacts:
a. Aesthetics and Visual Resources
Under Alternative 1, the project site would remain in its existing condition and no alterations to existing views on the site would occur. Alternative 1 would have no impact on scenic vistas, which would be a reduced level of impact compared to the proposed project. The project site is not visible from a scenic highway. Like the proposed project, Alternative 1 would have no impact on scenic resources within a State scenic highway. Alternative 1 would not result in new development that would conflict with ap plicable zoning or other regulations that govern scenic quality. Alternative 1 would result in no impact, which would be a reduced level of impact compared to the proposed project.

Alternative 1 would not result in new sources of light and glare, as no ne w development would occur and on -site structures would remain the same as existing conditions. Therefore, Alternative 1 would result in no impact involving the creation of a new source of light and glare that could adversely affect daytime or nighttime vie ws, which would be a reduced level of impact compared to the proposed project. Overall, based on the above, Alternative 1 would have no impact related to aesthetics and visual resources, which would be a reduced level of impact compared to the proposed project. (Revised Draft EIR, pp. 6-7 -- 6-8.) b. Air Quality
Alternative 1 would not result in new development on the project site, which would remain the same as existing conditions. Alternative 1 would not result in any new growth and therefore would not conflict with the growth projections utilized within the 2022 Ozone Plan. Alternative 1 would result in no impact involving conflict with an applicable air quality management plan, which would be a reduced level of impact compared to the proposed project. Alternative 1 would not result in any demolition, construction, or additional on -site operational activities and therefore would not generate air pollutant emissions beyond existing conditions nor result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non -attainment under an applicable federal or state ambient air quality standard. No impact related to criteria air pollutants would occur, which would be a reduced level of impact compared to the proposed project. Alternative 1 would not result in any demolition, construction, or additional on-site operational activities and therefore would not generate air pollutant emissions beyond existing conditions that could expose sensitive receptors to substantial pollutant concentrations. No impact related to pollutant conc entrations would occur, which would be a reduced level of impact compared to the proposed project. Alternative 1 would not result in any demolition, construction, or additional on-site operational activities and therefore would not generate odors beyond ex isting conditions. No impact related to odors would occur, which would be a reduced level of impact 206
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
173 | P a g e

compared to the proposed project. Overall, based on the above, Alternative 1 would have no impact related to air quality, which would be a reduced level of impact compared to the proposed project. (Revised Draft EIR, p. 6-8.) c. Biological Resources
Alternative 1 would maintain existing conditions at the project site and would not result in new development that would have a substantial adverse effect, eithe r directly or indirectly, on special -status species. Alternative 1 would result in no impact to special -status species, which would be a reduced level of impact compared to the proposed project. Alternative 1 would maintain existing conditions at the project site and would not result in new development that would adversely impact riparian habitat or sensitive natural communities, either directly or indirectly.

Alternative 1 would result in no impact to riparian habitat or sensitive natural communities, which would be a reduced level of impact compared to the proposed project. Alternative 1 would not involve construction activities that could result in impacts to jurisdictional wetland features, as no new development would occur for Alternative 1. Alternative 1 would have no impact to wetlands, which would be a reduced level of impact compared to the proposed project.

Alternative 1 would maintain existing conditions at the project site and would not involve new development that could substantially interfere with the movement of fish or wildlife species. Alternative 1 would have no impact on wildlife movement, which woul d be a reduced level of impact compared to the proposed project.

Alternative 1 would not involve new development that would conflict with a local policy or ordinance that protects biological resources. Therefore, Alternative 1 would have no impact, which would be a reduced level of impact compared to the proposed project. Alternative 1 would be located on the same site as the proposed project. The project site is not subject to an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state Habitat Conservation Plan. Therefore, Alternative 1 would have no impact related to conflicts with these plans, which is the same level of impact as the proposed project. Overall, based on the above, Alternative 1 wou ld have no impact related to biological resources, which would be a reduced level of impact compared to the proposed project. (Revised Draft EIR, pp. 6-7 -- 6-9.)
d. Cultural Resources
Alternative 1 would be located on the same site as the proposed proje ct, which does not contain structures eligible as historical resources. Alternative 1 would result in no impact on historical resources, which would be the same level of impact as the proposed project. Alternative 1 would not include any new development or ground-disturbing activities on -site and therefore would have no potential to damage or disturb subsurface archaeological resources. Therefore, Alternative 1 would have no impact on archaeological resources, which would be a reduced 207
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
174 | P a g e

level of impact compared to the proposed project. Alternative 1 would not include any new development or ground -disturbing activities on-site and therefore would have no potential to damage or disturb human remains. Therefore, Alternative 1 would have no impact on human remains , which would be a reduced level of impact compared to the proposed project. Overall, based on the above, Alternative 1 would have no impact to cultural resources, which would be a reduced level of impact compared to the proposed project. (Revised Draft EIR, p. 6-9.) e. Geology and Soils
Alternative 1 would be located on the same site as the proposed project. There is no Alquist-Priolo Fault Zone located on the project site. Therefore, Alternative 1 would have no impact involving fault rupture, which woul d be the same level of impact as the proposed project. The project site is located in a region of high seismic activity, with the potential for large seismic events that could generate strong ground shaking; however, Alternative 1 would not include new development on the site that could increase the risk of loss, injury, or death due to seismic ground shaking compared to existing conditions. Therefore, Alternative 1 would have no impact involving seismic ground shaking, which would be a reduced level of impact compared to the proposed project. Alternative 1 would be subject to the same negligible liquefaction, lateral spreading, subsidence, and collapse risks as the proposed project; however, Alternative 1 would not include new development on the site that could increase the risk of loss, injury, or death due to these geologic hazards compared to existing conditions. Therefore, Alternative 1 would have no impact involving liquefaction, lateral spreading, subsidence, and collapse, which would be a reduced level of impact compared to the proposed project.

Alternative 1 would be subject to the same high landslide risk as the proposed project; Alternative 1 would not include new development on the project site that could increase the risk of loss, injury, or deat h due to landslides compared to existing conditions. Therefore, Alternative 1 would have no impact involving landslides, which would be a reduced level of impact compared to the proposed project. Alternative 1 would not involve any ground -disturbing activities such as grading that would increase the potential for erosion and sedimentation.

Alternative 1 would maintain existing drainage patterns on the project site and would not result in new sources of runoff that could contribute to erosion and the loss of topsoil. Alternative 1 would have no impact involving substantial soil erosion or the loss of topsoil, which would be a reduced level of impact compared to the proposed project. Alternative 1 would be subject to the same high to critical expansion potential of soils underlying the project site as the proposed project; however, Alternative 1 would not include new development on the project site that could increase risks to life or property due to expansive soils compared to existing conditions. Therefore, Alternative 1 would have no impact involving expansive soils, which would be a reduced level of impact compared to the proposed project. 208
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
175 | P a g e

Alternative 1 would not involve the use of septic tanks or alternative wastewater disposal systems. Alternative 1 would result in no impact, which would be the same level of impact as the proposed project. Alternative 1 would not include new development on the project site that could increase the potential to damage or disturb unanticipated paleontological resources. Ther efore, Alternative 1 would have no impact on paleontological resources, which would be a reduced level of impact compared to the proposed project. Overall, based on the above, Alternative 1 would have no impact related to geology and soils, which would be a reduced level of impact compared to the proposed project. (Revised Draft EIR, pp. 6-7 -- 6-

9.)
f. Greenhouse Gas Emissions
Alternative 1 would maintain existing conditions on the project site. Consequently, Alternative 1 would not generate GHG emission s beyond existing conditions and would not result in an increase in GHG emissions. Therefore, Alternative 1 would not have a significant impact on the environment regarding the generation of GHG emissions, and would not conflict with an applicable plan, po licy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases. No impact related to greenhouse gas emissions would occur, which would be a reduced level of impact compared to the proposed project. (Revised Draft EIR, p. 6-10.)
g. Hazards and Hazardous Materials
Alternative 1 would not involve new development on the project site or involve the routine transport, use, or disposal of hazardous materials beyond existing conditions (i.e., the current minimal use of fuels occurring o n-site for splitting and storage of woodchips and firewood). Alternative 1 would result in no impact related to the transport, use, or disposal of hazardous materials, which would be a reduced level of impact compared to the proposed project. Alternative 1 would not result in the demolition of existing structures on the project site and therefore would not risk the release of asbestos -containing materials (ACM) or lead -based paints (LBP) which may be present in on-site structures. Alternative 1 would result in no impact involving the accidental release of hazardous materials, which would be a reduced level of impact compared to the proposed project. Alternative 1 would be located the same distance from nearby schools as the proposed project; however, Alternative 1 would not involve additional routine transport, use, or disposal of hazardous materials beyond existing conditions and therefore would not result in any increased risks of hazardous material use within 0.25 -mile of a school.

Alternative 1 would have no impact, which would be a reduced level of impact compared to the proposed project.

Alternative 1 would be located on the same site as the proposed project, which is not located on a site listed pursuant to Government Code Section 65962.5. No 209
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
176 | P a g e

impact would occur related to listed hazardous materials sites, which would be the same level of impact as the proposed project. Alternative 1 would be located on the same site as the proposed project, which is not within the noise or safety contours of the Santa B arbara Airport. No impact related to excessive noise or safety hazards due to proximity to an airport would occur, which would be the same level of impact as the proposed project. Alternative 1 would not result in any development and therefore would not re quire any closures of Cathedral Oaks Road for construction-related activities.

Alternative 1 would not result in any increased vehicle trips to the project site beyond existing conditions. Therefore, Alternative 1 would have no impact related to interfere nce with an adopted emergency response plan or emergency evacuation plan, which would be a reduced level of impact compared to the proposed project. Alternative 1 would not include new development and would maintain existing conditions on -site, which invol ves the storage of firewood.

Therefore, while Alternative 1 would not result in any development on the project site, under existing conditions Alternative 1 would pose fire risk due to the storage of firewood. Compared to the proposed project, Alternative 1 would consistently keep materials on-site with a higher risk of flammability compared to the proposed project.

However, Alternative 1 would not involve construction activities with the potential to result in wildfire ignition or increase impacts related to wildfire compared to existing conditions. Alternative 1 would have no impact related to wildfire, and would be reduced when compared to the proposed project. Overall, based on the above, Alternative 1 would have a no impact involving hazards and hazard ous materials, which would be a reduce d level of impact when compared to the proposed project. (Revised Draft EIR, pp. 6-10 -- 6-11.) h. Hydrology and Water Quality
Alternative 1 would not result in demolition or new construction that could violate water quality standards or waste discharge requirements. No new sources of pollutants would be introduced to the project site, and existing drainage patterns would be maintained. Therefore, Alternative 1 would result in no impact related to water quality degradation, which would be a reduced level of impact compared to the proposed project. Alternative 1 would not include any new development on - site and therefore would not require additional water use, including groundwater, beyond existing conditions. In additi on, Alternative 1 would not include the introduction of impervious surfaces on-site. Therefore, Alternative 1 would have no impact involving the substantial decrease of groundwater supplies or interference with groundwater recharge, which would be a reduce d level of impact compared to the proposed project.
210
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
177 | P a g e

Alternative 1 would not involve new development and would maintain existing conditions at the project site. Therefore, Alternative 1 would not substantially alter the drainage pattern of the project site, including through the alteration of a course of a stream or river or through the addition of impervious surfaces. Alternative 1 would not result in substantial erosion or siltation, increased runoff, or additional sources of polluted runoff. Alternative 1 would have no impact involving alteration of drainage patterns that result in substantial erosion or siltation, surface runoff, or polluted runoff, which would be a reduced level of impact compared to the proposed project. As with the proposed project, A lternative 1 would be located outside of a flood hazard zone, tsunami inundation area, and seiche zone. No impact related to impeded or redirected flood flows would occur, which would be the same level of impact as the proposed project. Alternative 1 would not result in any development and therefore would not result in water quality impacts, water consumption, or impacts to groundwater supplies beyond existing conditions.

Therefore, Alternative 1 would not conflict with the Water Quality Control Plan for the Central Coast Basin (Basin Plan) or the Groundwater Management Plan Goleta Groundwater Basin (Groundwater Management Plan) and no impact would occur, which would be a reduced level of impact compared to the proposed project.

Based on the above, Alternative 1 would have no impact related to hydrology and water quality, which would be a reduced level of impact compared to the proposed project. (Revised Draft EIR, pp. 6-11 -- 6-12.)
i. Land Use and Planning
Alternative 1 would not include new construction that could physically divide an established community and would result in no impact, which would be a reduced level of impact compared to the proposed project. Alternative 1 would maintain existing conditions at the project site and would not result in new development. In contrast to the proposed project, Alternative 1 would not conflict with Goleta General Plan/Coastal Land Use Plan Policies CE 1.9 and CE 2.3 because under Alternative 1, no development would occur within or proximate to Environmentally Sensitive Habitat Areas (ESHA) or within the Streamside Protection Area of El Encanto Creek.

Alternative 1 would not conflict with the Goleta General Plan/Coastal Land Use Plan and would have no impact involving conflict with existing plans adopted for the purpose of avoiding or mitigating an environmental effect, which would be a reduced level of impact compared to the proposed project. However, Alternative 1 would not assist in fulfilling the City’s Regional Housing Needs Allocation requirements identified within the City’s 2023 -2031 Housing Element as Alternative 1 would not include new residential development. Nevertheless, Alternative 1 would have no impact involving land use and planning, which would be a reduced level of impact compared to the proposed project. (Revised Draft EIR, p. 6-12.)
211
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
178 | P a g e

j. Noise
Alternative 1 would not generate construction noise which could exceed City of Goleta standards. Under Alternative 1, the site would remain under existing conditions, and no additional operational noise would occur. Alternative 1 would have no impacts rela ted to noise, which would be a reduced level of impact compared to the proposed project. Alternative 1 would not involve construction activities that would generate groundborne vibration. No impact would occur, which would be a reduced level of impact compared to the proposed project.

As with the proposed project, Alternative 1 would be located outside of the noise contours of the Santa Barbara Airport. As with the proposed project, Alternative 1 would have no impact related to excessive airport noise. Bas ed on the above, Alternative 1 would have no impact related to noise and vibration, which would be a reduced level of impact compared to the proposed project. (Revised Draft EIR, p. 6-13.)
k. Transportation and Circulation
Alternative 1 would not result in new development or uses at the project site and would not introduce features that would conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. No impact would occur, which would be a reduced level of impact compared to the proposed project. However, Alternative 1 would not include the extension of the Class I trail parallel to Cathedral Oaks Road and therefore, unlike the propose d project, would not support the City’s policies for alternate modes of transportation. Alternative 1 would maintain existing conditions on-site and would not increase vehicle trips to and from the project site or VMT beyond existing conditions. Alternative 1 would result in no impact related to VMT, which would be a reduced level of impact compared to the proposed project.

Alternative 1 would not result in new development that could increase roadway hazards due to geometric design features or incompatible uses. Alternative 1 would result in no impact, which would be a reduced level of impact compared to the proposed project. Alternative 1 would not result in new development, and consequently, would not require construction vehicles or temporary closure of lanes on Cathedral Oaks Road during the construction phase that could affect emergency access. Alternative 1 would result in no impact involving inadequate emergency access, which would be a reduced level of impact compared to the proposed project. Based on the above, Alternative 1 would result in no impacts related to transportation and circulation, which would be a reduced level of impact compared to the proposed project. (Revised Draft EIR, p. 6-13.) l. Tribal Cultural Resources
212
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
179 | P a g e

Alternative 1 would be located on the same site as the proposed project. Based on Native American consultation conducted for the proposed project, no tribal cultural resources have been identified on the site. In addition, Alternative 1 would not include ground-disturbing activities on-site that could potentially damage or disturb unanticipated tribal cultural resources. Alternative 1 would not potentially damage or disturb unknown tribal cultural resources; therefore, Alternative 1 would not cause a substantial adverse change in the significance of a tribal cultural resource, as defined in Public Resources Code Section 21074. Therefore, Alternative 1 would have no impact on tribal cultural resources, which would be a reduced level of impact compared to the proposed project. (Revised Draft EIR, p. 6-13.) m. Utilities and Service Systems
Alternative 1 would not include new development and would maintain existing conditions on-site. Therefore, Alternative 1 would not result in new demand for water, wastewater, stormwater, electric, natural gas, or telecommunications facilities. Because no new or expanded utility infrastructure would be required, Alternative 1 would not result in the construction of new or expanded utility systems, and would therefore not cause significant environmental impacts related to such construction. No impact would occur, which would be a reduced level of impact compared to the proposed project.

Alternative 1 would not increase water demand or wastewater generation compared to existing conditions. As such, it would not exceed the capacity of existing water or wastewater treatment providers or infrastructure. No upgrades to water or wastewater systems would be necessary, and no impacts to water supply or wastewater treatment would occur. This would be a reduced level of impact compared to the proposed project. Alternative 1 would not increase solid waste generation on-site compared to existing conditions. Consequently, Alternative 1 would not exceed the capacity of local landfills or conflict with applicable soli d waste regulations. No impact would occur, which would be a reduced level of impact compared to the proposed project. Therefore, Alternative 1 would have no impact on utilities and service systems, which would represent a reduced level of impact compared to the proposed project. (Revised Draft EIR, pp. 6-13 – 6-14.) n. Wildfire
Alternative 1 would not include new development and would maintain existing conditions on -site, which involves the storage of firewood. Because no new structures or infrastructure would be introduced, Alternative 1 would not impair an adopted emergency response plan or emergency evacuation plan. No impact would occur, which would be a reduced level of impact compared to the proposed project. Alternative 1 would not involve new cons truction or grading that could exacerbate wildfire risks due to slope, prevailing winds, or other site -specific conditions.
213
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
180 | P a g e

However, the continued storage of firewood on -site would maintain the presence of flammable materials, which could contribute to th e uncontrolled spread of wildfire or increase pollutant concentrations in the event of a fire. Nonetheless, Alternative 1 would not involve construction activities with the potential to result in wildfire ignition. No impact would occur, which would be a reduced level of impact when compared to the proposed project.

Alternative 1 would not require the installation or maintenance of infrastructure such as roads, fuel breaks, emergency water sources, or utilities. Because no new development would occur, there would be no temporary or ongoing environmental impacts associated with fire -related infrastructure. No impact would occur, which would be a reduced level of impact compared to the proposed project. Alternative 1 would not introduce new structures or grad ing that could alter site drainage or slope stability. As such, it would not expose people or structures to significant risks related to post-fire flooding, landslides, or other geologic hazards. No impact would occur, which would be a reduced level of impact compared to the proposed project.

Overall, Alternative 1 would have no impact involving wildfire, which would represent a reduced impact compared to the proposed project. (Revised Draft EIR, p. 6-14.)
Finding: The City Council rejects Alternative 1: No Project/No Build Alternative, on the following ground, which individually provides sufficient justification for rejection of this alternative: (1) the alternative fails to meet any of the Project objectives.

2. Alternative 2: By-Right Development (Revised Draft EIR, pp. 6-6 -- 6-7.) Description: In another version of a no project alternative, if the project is not approved, Alternative 2 assumes the site would be developed with land uses that are allowed by -right pursuant to the Goleta Municipal Code. In accordance with the AG -II zoning district, the re -establishment of the avocado orchard or the establishment of other agricultural operations could occur without requiring discretionary approvals. Other land uses allowed by right under the existing AG-II zoning are provided in Goleta Municipal Code Section 35 -217.3, and include the following:
o All types of agriculture, including the commercial raising of animals o Sale of agricultural products produced on the premises o Greenhouses not exceeding a total of 20,000 square feet o One single-family dwelling unit per legal lot
214
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
181 | P a g e

o One guest house or artist studio per legal lot
o Home occupations
o Animal hospitals
o Commercial boarding of animals and riding stables
For the purposes of this analysis, Alternative 2 would include the largest amount of structural development allowable on the project site by right, which would be a complex of greenhouses totaling 20,000 square feet in floor area (e.g., 10 greenhouses at 2,000 square feet each), and 12 units provided fo r farmworker housing. The greenhouses would be powered with solar panels, with backup generators on-site in the event of solar panel failure. The residence also could be enlarged, or the residence could be demolished and a new, larger residence could be co nstructed at a size of up to 4,900 square feet, as long as the new development complied with the 35 -foot height limitation and minimum setback of 10 feet from Cathedral Oaks Road. Row crops, orchards, or animal grazing would also be allowed over most of the project site.

Based on allowable uses and the above assumptions, Alternative 2 would include expansion of the existing single -family residence to 4,900 square feet, 12 residential units provided as farmworker housing assumed to each be up to 1,500 square feet, up to 20,000 square feet of a greenhouse complex, and agricultural uses such as row crop cultivation, orchards, or animal grazing on the undeveloped portions of the project site. The residence and farmworker housing would not use natural gas. The 2 0,000 square foot greenhouse complex would result in approximately 40 additional employees, some of which would be housed in the proposed farmworker housing. In addition, Alternative 2 would not include the extension of the Class I trail parallel to Cathed ral Oaks Road. Alternative 2’s construction equipment staging and worker parking would occur entirely on-site.

Based on Alternative 2’s reduction in people on -site compared to the proposed project (3 residents and 40 employees compared to the proposed project’s 145 residents), Alternative 2 would result in fewer daily vehicle trips to and from the project site comp ared to the proposed project. Utility infrastructure required for Alternative 2 would be installed underground. (Revised Draft EIR, pp. 6-6 -- 6-7.) Impacts:
a. Aesthetics and Visual Resources
Under Alternative 2, a complex of greenhouses totaling 20,000 square feet could be developed, and the existing residence could be enlarged or replaced with a larger residence. In addition, Alternative 2 would include 12 farmworker housing 215
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
182 | P a g e

units and agricultural uses (e.g., row crop cultivation, orchards, animal grazing) on the remaining portions of the project site. Although Alternative 2 would introduce new structures, it would include fewer structures than the proposed project, and the proposed agricultural uses (e.g., row crop cultivation, orchards, animal grazing) on undeveloped portions of the project site would not require additional structures that could impede views of scenic vistas. Accordingly, Alternative 2 would have less potential to impact scen ic vistas compared to the proposed project. The greenhouse complex, residence, and farmworker housing would be designed in compliance with the 35 -foot height limitation enforced within Table 17.12.030 of the City’s Municipal Code, which is 10 feet higher than the 25-foot height limitation the proposed project is subject to. Although Alternative 2 would be taller than the proposed project, because fewer structures would be included, this alternative would result in less overall visual obstruction or blockage of views compared to the proposed project. Overall, Alternative 2’s impacts related to scenic vistas would be reduced compared to the proposed project but would remain less than significant.

The project site is not visible from a scenic highway. Like the proposed project, Alternative 2 would have no impact on scenic resources within a State scenic highway.

Although the proposed project would be visually consistent with the RS -7 zone utilized for consistency evaluation pursuant to the Builder’s Remedy, th e RS -7 zone is not the site's existing zoning designation. Rather, it was used solely for the purpose of evaluating consistency of the proposed project pursuant to the Builder’s Remedy, which allows certain projects to proceed despite zoning inconsistencies.

In contrast, Alternative 2 would be consistent with the site's existing AG -II zoning designation, which permits low -density agricultural and rural residential uses. As such, Alternative 2 would result in development that is visually compatible with the type, scale, and character of development allowed under the AG -II zone. In addition, Alternative 2 would not require the use of waivers to meet applicable development standards. Therefore, Alternative 2 would have a reduced impact related to conflicts with applicable zoning governing scenic quality but impacts would remain less than significant.

As with the proposed project, Alternative 2 would include construction of new development on-site and therefore would introduce new sources of light. As with the proposed project, construction of Alternative 2 would not occur during evening or nighttime hours in accordance with Section 17.39.070 of the City’s Zoning Code and would not require nighttime lighting. Given Alternative 2’s reduced number of structures com pared to the proposed project, it would require less operational lighting than the proposed project. Operational lighting installed as part of Alternative 2 would be designed in compliance with City of Goleta General Plan/Coastal Land Use Plan Policy VH 4. 12 requirement for dark sky compliant lighting fixtures for exterior lighting. Alternative 2 would introduce similar sources of potential glare compared to the proposed project in the form of glass surfaces 216
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
183 | P a g e

at the greenhouse complex and on windows of resid ences; however, glass surfaces in a greenhouse are typically antireflective in order to effectively manage sunlight exposure for plants within a greenhouse. In addition, on -site vegetation and structures would screen glare caused from the windows of reside nces.

Overall, Alternative 2’s impacts related to light and glare would be reduced compared to the proposed project but would remain less than significant.

Based on the above, Alternative 2’s impacts related to scenic vistas, conflicts with applicable zoning governing scenic quality, and light and glare. would be reduced compared to the proposed project due to Alternative 2’s reduced development footprint. Like the proposed project, Alternative 2 would result in no impacts related to a State scenic highway and impacts on scenic vistas, conflicts with applicable zoning governing scenic quality, and light and glare would be less than significant. (Revised Draft EIR, pp. 6-14 -- 6-15.)
b. Air Quality
Based on the City’s average 2.59 persons per household (Ca lifornia Department of Finance [DOF] 2025), Alternative 2 would result in direct population growth of three people from the renovations or construction of an on-site residence. The City of Goleta General Plan/Coastal Land Use Plan Final EIR utilizes a grow th rate of one job per 500 square feet of commercial floor area to estimate growth from employment (City of Goleta 2006a). Accordingly, the 20,000 square foot greenhouse complex could result in approximately 40 additional employees to Goleta. In a conservative scenario where all projected employees and their families were to relocate to Goleta, based on the City’s average 2.59 persons per household (DOF 2025), there would be an indirect population growth of 104 residents from the greenhouse complex. In tota l, Alternative 2 could result in a population growth of 107 residents to Goleta, which is 38 fewer residents than the proposed project.

Given that the proposed project’s growth would be within Santa Barbara County Association of Governments (SBCAG) growth projections utilized within the 2022 Ozone Plan, Alternative 2 would also be within SBCAG growth projections and therefore would not conflict with the 2022 Ozone Plan. Alternative 2’s impacts related to conflicts with an air quality management plan would be reduced compared to the proposed project, but would remain less than significant.

Alternative 2 would construct fewer structures than the proposed project. As such, Alternative 2 would result in less criteria air pollutant emissions during construction compared to the proposed project. Given that construction of the proposed project would not exceed Santa Barbara Air Pollution Control District (SBCAPCD) emissions thresholds, Alternative 2’s construction would also not exceed SBCAPCD thresholds. Compared to the proposed project, Alternative 2 would reduce vehicle trips, include use of solar panels for the greenhouse complex, and reduce the number of residences, which would reduce air pollutant emissions. 217
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
184 | P a g e

However, the use of farming equipment for agricultur e during operation would generate increased particulate matter emissions compared to the proposed project. Given the potential for the regular use of farming equipment, Alternative 2’s impacts related to release of criteria air pollutants would be greater compared to the proposed project but would remain less than significant.

As with the proposed project, construction of Alternative 2 would include the use of Tier 4 emissions standards for construction equipment required as a Condition of Approval which would minimize exhaust emissions from nonroad diesel engines and would occur in compliance with SBCAPCD Rule 323.1, Rule 329, and Rule 345 to minimize the amount of volatile organic compound, reactive organic compound, and fugitive dust emissions on -site du ring construction. During operation, Alternative 2 would involve the use of a single -family residence, farmworker housing, a greenhouse complex, and agricultural uses. The single - family residence and farmworker housing would not include the use of equipmen t that would increase toxic air emissions at the project site. The greenhouse gas complex may require the use of generators to provide backup power in the event of solar panel failure; however, given that these generators would be used in emergency cases which would be infrequent and temporary, the use of generators would not result in a substantial generation of air pollutants. Use of farming equipment for agricultural uses during operation would generate increased emissions compared to the proposed projec t. Given the potential for the regular use of farming equipment proximate to on - and off -site residential receptors, Alternative 2 would expose residential receptors to higher amounts of pollutants compared to the proposed project, which could lead to adve rse health risks.

Overall, Alternative 2’s impacts related to the release of toxic air contaminants would be greater compared to the proposed project but would remain less than significant.

Alternative 2 would construct fewer structures than the proposed project and therefore would result in a fewer amount of construction odors generated from the use of construction equipment compared to the proposed project. Alternative 2’s construction odors would be intermittent, temporary, and would dissipate rapidly with distance from in -use construction equipment. Unlike the proposed project, Alternative 2 would include agricultural uses on site, which could include row crop cultivation, orchards, or animal grazing. The use of farm equipment would result in similar odors as construction equipment, which would be intermittent, temporary, and would dissipate rapidly with distance from the farm equipment itself. However, the use of the project site for grazing could result in odors associated with grazing animals on-site. Therefore, Alternative 2’s impact related to odors would be greater than the proposed project, but would remain less than significant. Overall, based on the above, Alternative 2’s impact related to conflicts with an air quality management plan would be reduced compared to the proposed project, but would remain less than significant. Alternative 2’s impact related to criteria air pollutants, 218
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
185 | P a g e

toxic air contaminants, and odors would be greater than the proposed project but remain less than significant. (Revised Draft EIR, pp. 6-16 -- 6-17.) c. Biological Resources
Alternative 2 would have a reduced development footprint compared to the proposed project because it would include fewer structures. Although ground disturbance would occur for agricultural uses (e.g., tilling, etc.), this would be less intensive than the ground disturbance required for development of the proposed project. Therefore, Alternative 2 would have less potential to directly and indirectly affect special-status plant and wildlife species on-site as the proposed project. As with the proposed project, Alternative 2 would require implementation of Mitigation Measures NOI-1 and BIO-1 through BIO-6 to reduce potential impacts to special- status plant and wildlife species to a less than significant level. Alternative 2’s impacts related to special -status plant and wildlife species would be reduced compared to the proposed project but would remain less than significant with mitigation incorporated.

Given Alternative 2’s development footprint, it would have less potential than the proposed project to result in direct impacts to arroyo willow thicket, black sage – California sagebrush scrub, and eucalyptus grove that serves as raptor roosting habitat ESHA. Alternative 2 would require implementation of Mitigation Measures BIO-3, BIO-4, and BIO-7 to reduce potential impacts to arroyo willow thicket, black sage – California sagebrush scrub, and eucalyptus grove that serves as raptor roosting habitat ESHA. Alternative 2’s impacts related to ESHA would be reduced compared to the proposed project but would remain le ss than significant with mitigation incorporated.

Alternative 2 includes fewer structures compared to the proposed project and would have less potential than the proposed project to remove riparian habitat during construction which may be a jurisdictional resource. Alternative 2 would require implementation of Mitigation Measures BIO -3 and BIO -4 to reduce potential construction impacts to jurisdictional resources. Alternative 2’s operation would include greater use of outdoor pesticides compared to the proposed project for the agricultural uses on -site; however, operational activities would be conducted in accordance with Goleta Municipal Code Section 17.030.060 which prohibits the use of insecticides, herbicides, artificial fertilizers, or other toxic chemical substances within and adjacent to ESHA. Alternative 2 would have a reduced potential to disturb jurisdictional resources compared to the proposed project and impacts would remain less than significant with mitigation incorporated.

Alternative 2 inclu des fewer structures compared to the proposed project, but construction noise could still result in temporary disruption of wildlife movement.

Accordingly, Alternative 2 would require implementation of Mitigation Measure NOI-1 to reduce potential impacts t o wildlife movement related to construction 219
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
186 | P a g e

noise to a less than significant level. During operation, the use of farming equipment such as tractors would increase on-site operational noise compared to the proposed project which could disturb wildlife movement. The City would require the use of noise -reducing equipment on farm equipment in order to reduce operation noise below the City’s noise threshold. Alternative 2 would introduce fewer new sources of light and glare as the proposed project, which would r esult in less potential to adversely impact wildlife movement due to light and glare.

Alternative 2 would result in decreased human presence at the project site compared to the proposed project because Alternative 2 would include fewer residences and less potential for direct and indirect population growth compared to the proposed project. This human presence would not substantially impede wildlife movement as the project site is not designated as a wildlife corridor, and no fencing or structures would bloc k access to the creek. Due to the increase in operational noise compared to the proposed project, Alternative 2’s impact on wildlife corridors and wildlife movement would be greater compared to the proposed project but would remain less than significant wi th mitigation incorporated.

Alternative 2 would have a reduced potential to conflict with City of Goleta General Plan/Coastal Land Use Plan Policies CE 1.6, CE 1.9, CE 2.3, CE 5.3, and CE 9.5, and the City’s Urban Forest Management Plan, compared to the proposed project due to the reduced development footprint and ground disturbance. Alternative 2 would require implementation of Mitigation Measures BIO -3, BIO -4, BIO7, and BIO-8. As with the proposed project, Alternative 2 would remain inconsistent with Policies CE 1.9 and 2.3; however, these inconsistencies are related to policy-level distinctions and the environmental impacts of development within ESHA and Streamside Protection Area buffers would be reduced to a less than significant level with implementat ion of the abovementioned mitigation measures, and thus would not result in a significant impact on the environment. Alternative 2’s impact related to conflicts with local policies and ordinances protecting biological resources would be reduced compared to the proposed project and would remain less than significant with mitigation incorporated.

As with the proposed project, Alternative 2 would not be located in an area subject to an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. Alternative 2 would have no impact related to conflicts with these plans, which would be the same level of impact compared to the proposed project. Based on the above, Alternative 2’s impact related to special-status plant and wildlife species, riparian habitat and ESHA, jurisdictional features, and conflicts with local policies or ordinances protecting biological resources would be reduced compared to the proposed project and would remain less than significant with mitigation incorporated. Alternative 2’s impact related to wildlife corridors and wildlife movement would be greater compared to the proposed project but would remain 220
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
187 | P a g e

less than significant with mitigation incorporated. As with t he proposed project, Alternative 2 would have no impact related to conflicts with an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. (Revised Draft EIR, pp. 6 -17 -- 6-18.)
d. Cultural Resources
Alternative 2 would be located on the same site as the proposed project, which does not contain structures eligible as historical resources. As with the proposed project, Alternative 2 would have no impact on historical r esources. Alternative 2 would have a reduced development footprint compared to the proposed project because it would include fewer structures. Although ground disturbance would occur for agricultural uses (e.g., tilling, etc.), this would be less intensive than the ground disturbance required for development of the proposed project.

Therefore, Alternative 2 would reduce the potential to encounter unknown archaeological resources. Mitigation Measures CUL -1 through CUL -3 would continue to be required, which would minimize potential impacts to unanticipated discoveries of archaeological resources by requiring archaeological monitoring, a cultural resources sensitivity meeting for construction personnel, and implementation of appropriate procedures for evaluati on and treatment of any discoveries made during construction. Alternative 2’s impacts would be reduced compared to the proposed project but would remain less than significant with mitigation incorporated. Alternative 2 would reduce the potential to encount er unknown human remains compared to the proposed project due to its reduced development footprint and less intensive ground disturbance.

As with the proposed project, in the event of unanticipated discovery of human remains, the construction contractor w ould be required to comply with State of California Health and Safety Code Section 7050.5 and human remains would be preserved in accordance with the requirements of Public Resources Code Section 5097.98. Alternative 2’s impacts related to human remains wo uld be reduced compared to the proposed project and would remain less than significant. Based on the above, Alternative 2 would have a reduced impact compared to the proposed project due to Alternative 2’s reduced ground disturbing activities and development footprint. As with the proposed project, Alternative 2 would have no impact on historical resources. Alternative 2’s impacts related to archaeological resources would remain less than significant with mitigation incorporated.

Alternative 2’s impacts rel ated to human remains would remain less than significant. (Revised Draft EIR, pp. 6-18 -- 6-19.)
e. Geology and Soils
221
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
188 | P a g e

Alternative 2 would be located on the same site as the proposed project. There is no Alquist-Priolo Fault Zone located on the site. Ther efore, Alternative 2 would have no impact involving fault rupture, which would be the same level of impact as the proposed project. The project site is located in a region of high seismic activity, with the potential for large seismic events that could gen erate strong ground shaking.

As with the proposed project, Alternative 2 would implement Mitigation Measure GEO-1, which requires incorporation of geotechnical recommendations into grading and building plans. Implementation of Mitigation Measure GEO -1 would reduce potential impacts due to groundshaking to a less than significant level through incorporation of structural integrity recommendations. Because Alternative 2 would reduce the amount of development and people that would be introduced on-site compar ed to the proposed project, Alternative 2’s impacts related to seismic ground shaking would be reduced compared to the proposed project, but would remain less than significant with mitigation incorporated.

Alternative 2 would be subject to the same neglig ible liquefaction, lateral spreading, subsidence, and collapse risks as the proposed project. As with the proposed project, Alternative 2 would require implementation of Mitigation Measure GEO-1 requiring recommendations from the project-specific geotechnical reports to be put into grading and building plans. Implementation of Mitigation Measure GEO-1 would reduce potential impacts due to landslides on the project site to a less than significant level through incorporation of slope stability recommendations. Because Alternative 2 would reduce the amount of development and people that would be introduced on -site compared to the proposed project, Alternative 2’s impacts related to liquefaction, lateral spreading, subsidence, and collapse risks would be reduced compared to the proposed project, but would remain less than significant with mitigation incorporated.

Alternative 2 would be subject to the same landslide risks as the proposed project.

As with the proposed project, Alternative 2 would require implement ation of Mitigation Measure GEO -1 to incorporate slope stability recommendations into grading and building plans. Because Alternative 2 would reduce the amount of development and people that would be introduced on -site compared to the proposed project, Alt ernative 2’s impacts related to landslide risks would be reduced compared to the proposed project, but would remain less than significant with mitigation incorporated. Alternative 2 would have a reduced development footprint compared to the proposed projec t because it would include fewer structures than the proposed project. Although ground disturbance would occur for agricultural uses (e.g., tilling, etc.), this would be less intensive than the ground disturbance required for development of the proposed project. Alternative 2 would therefore have less potential for erosion of on -site soils during construction compared to the proposed project. As with the proposed project, Alternative 2’s construction activities must obtain coverage from the Construction Sto rmwater 222
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
189 | P a g e

General Permit which would require implementation of a Stormwater Pollution Prevention Plan and BMPs for erosion control.

As with the proposed project, Alternative 2 would not substantially increase the rate of runoff on the site compared to exist ing conditions with installation of stormwater control infrastructure. Alternative 2 could result in erosion during operation due to on-site agricultural uses which would not occur with the proposed project. Such grading would be required to comply with Se ction 15.09.080 of the City’s Municipal Code which sets standards specific for grading for agricultural practices, including obtaining erosion control permits, implementation of long-term erosion control BMPs, and required inspections. In addition, agricul tural practices on-site would be subject to the Central Coast Region Water Quality Control Board’s General Waste Discharge Requirements for Discharges from Irrigated Lands (Order No. R3 -2021-0040) which requires that land managers for agricultural lands im plement BMPs to ensure surface water discharges from irrigation do not contribute to substantial erosion on-site.

Therefore, Alternative 2’s impact related to erosion would be greater than the proposed project but would remain less than significant. As with the proposed project, Alternative 2 would locate development on soil with high to critical expansion potential o f soils. The construction contractor would be required to comply with the California Building Code, including the use of non -expansive fill material, to minimize the potential for structural hazards associated with soil expansion. As with the proposed proj ect, Alternative 2 would require implementation of Mitigation Measure GEO-1 requiring recommendations from the projectspecific geotechnical reports to be put into grading and building plans.

Implementation of Mitigation Measure GEO-1 would reduce potential impacts due to expansive soils on the project site to a less than significant level through incorporation of structural integrity recommendations into the project, which would ultimately minimize the potential for expansive soils to result in risks to lif e or property.

Because Alternative 2 would reduce the amount of development and people that would be introduced on -site compared to the proposed project, Alternative 2’s impacts related to expansive soils would be reduced compared to the proposed project, but would remain less than significant with mitigation incorporated.

Alternative 2 would not involve the use of septic tanks or alternative wastewater disposal systems. Alternative 2 would result in no impact, which would be the same level of impact as th e proposed project. Alternative 2 would have a reduced potential to encounter unknown paleontological resources compared to the proposed project due to a reduced development footprint and less intensive ground disturbing activities. Alternative 2 would req uire the implementation of Mitigation Measure GEO -2 to reduce potential construction impacts to paleontological resources and unique geologic features to a less than significant level by requiring a Worker Environmental Awareness Program training, monitoring, and setting forth 223
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
190 | P a g e

procedures for the recovery, identification, and curation of fossils discovered during construction. Alternative 2’s impacts related to paleontological resources and unique geologic features would be reduced compared to the proposed project but would remain less than significant with mitigation incorporated. Based on the above, Alternative 2’s would have no impact related to earthquake faults and septic tanks, the same as the proposed project. Alternative 2’s impacts related to groundshaking, landslides, and expansive soils, would be reduced compared to the proposed project but would remain less than significant with mitigation incorporated. Alternative 2’s impacts related to liquefaction, lateral spreading, subsidence, and collapse, wo uld be reduced compared to the proposed project and would remain less than significant. Alternative 2’s would have no impact related to septic tanks, the same as the proposed project. Alternative 2’s impacts related to erosion would be greater compared to the proposed project but would remain less than significant. Alternative 2’s impacts related to paleontological resources would be reduced compared to the proposed project but would remain less than significant with mitigation incorporated. (Revised Draft EIR, pp. 6-19 -- 6-

21.)
f. Greenhouse Gas Emissions
Alternative 2 would include fewer structures than the proposed project, leading to a shorter construction schedule and lower construction -related GHG emissions than the proposed project. Alternative 2 would include greenhouse facilities which would be energy-intensive uses due to the consistent monitoring and temperature adjustment requirements for vegetation growth within the greenhouses. In addition, Alternative 2 would include single -family residence and farmworker housing which would utilize energy for heating and cooling purposes. However, Alternative 2’s greenhouse facilities would be powered with solar panels and Alternative 2’s single -family residence and farmworker housing would be all - electric and, therefore, the electricity used at the project site would not result in GHG emissions associated with procurement of electricity. Alternative 2 would result in fewer daily vehicle trips to and from the project site compared to the proposed project bec ause Alternative 2 would result in less people on -site compared to the proposed project. Due to a reduction in vehicle trips to and from the project site, Alternative 2 would reduce GHG emissions from vehicle travel compared to the proposed project. Howeve r, Alternative 2’s agricultural uses would include the use of farming equipment that would utilize natural gas and diesel fuel. Unlike the proposed project, which would be all -electric during operation, this use of natural gas and diesel fuel would generat e increased operational GHG emissions on the project site. Given Alternative 2’s increase in operational GHG emissions compared to the proposed project, Alternative 2 would result in greater impacts related to GHG emissions compared to the proposed project, but impacts would remain less than significant. 224
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
191 | P a g e

As with the proposed project, Alternative 2 would include design features to promote renewable energy use and energy efficiency which contribute to the creation of minimal GHG emissions. Alternative 2 woul d include the use of renewable energy from solar panels in compliance with SBCAG 2050 Regional Transportation Plan/Sustainable Community Strategy policies. Alternative 2 would incorporate water efficient fixtures within the residence, farmworker housing, greenhouse facilities, and for on -site irrigation for agricultural practices to reduce water consumption for landscaping, plumbing, and irrigation. Alternative 2’s greenhouse solar panels would not generate GHG emissions due to electricity use.

Alternative 2’s residence and farmworker housing would not utilize natural gas and would be constructed in accordance with the energy reduction standards set forth in CALGreen and the Building Energy Efficiency Standards, including the CALGreen requirements for the in stallation of solar photovoltaic panels. As a result, Alternative 2 would minimize GHG emissions from stationary sources. As with the proposed project, Alternative 2 would place the on -site residential development within proximity to existing transit and b icycle facilities on Cathedral Oaks Road which would encourage alternative transportation and minimize GHG emissions associated with mobile use (i.e., vehicle trips). Accordingly, Alternative 2 would be consistent with applicable GHG reduction plans. Therefore, Alternative 2’s impact related to conflicts with GHG reduction plans would be similar to the proposed project and impacts would remain less than significant.

Based on the above, Alternative 2’s GHG emissions impacts would be increased compared to th e proposed project due to increased operational GHG emissions associated with farming on the project site, but impacts would remain less than significant. Alternative 2’s impacts related to conflicts with GHG reduction plans would be similar to the propose d project and would remain less than significant. (Revised Draft EIR, pp. 6-21 -- 6-22.)
g. Hazards and Hazardous Materials
Alternative 2 would construct fewer structures than the proposed project, leading to a shorter construction schedule and associated reduction in the use of hazardous materials during construction. Hazardous materials used during construction of Alternative 2 would be handled in accordance with the same regulations as the proposed project, such as the Hazardous Materials Transportation Act, Resource Conservation and Recovery Act, the California Hazardous Waste Control Law, and California Code of Regulations Title 22. These regulations prescribe measures for the safe transport, use, storage, and disposal of hazardous materials to reduce risk of spills. Construction of Alternative 2 would also occur in compliance with Chapter 15.09 of the City’s Municipal Code to reduce potential spills. During operation, transport, use, and disposal of pesticides for the greenhouse complex and agricultural uses on -site would be increased compared to the proposed project due to an increase in pesticide use at the greenhouse complex and potentially for on-site crop growth or orchards. However, any use of 225
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
192 | P a g e

household hazardous materials or other hazardous materials such as pesticides during operation would occur in compliance with existing hazardous materials regulations established by United States Environmental Protection Agency and the State of California. Accordingly, Alternative 2’s impact related to the routine transport, use, and disposal of hazardous materials would be greater compared to the proposed project but would remain less than significant.

As with the proposed project, Alternative 2 would include demolition of the existing on-site residence, garage, and barn, which have the potential to contain ACM and LBP. Alternative 2 would result in the same potential impact regarding the release of ACM and LBP from demolition of existing buildings. Mitigation Measures HAZ - 1 and HAZ -2 would continue to be required, which would reduce potential hazardous material impacts associated with accidental releases of hazardous materials dur ing demolition to a lessthan significant level. Alternative 2 would develop fewer residences and therefore less potential for radon exposure in residences; however, as with the proposed project, in accordance with Goleta General Plan/Coastal Land Use Plan Policy SE 1.9, radon testing would be required and, if on -site radon levels exceed the United States Environmental Protection Agency recommended threshold, as a Condition of Approval, the City would require the design of homes to comply with the standards for reducing radon in single-family residences implemented by the American Association of Radon Scientists and Technologists and American National Standards Institute.

Operation of Alternative 2’s residences would involve minimal transport, use, and disposal of hazardous materials for landscaping; however, use of the greenhouse complex and agricultural uses on -site (i.e., pesticide use) would be increased compared to the proposed project’s landscaping. Alternative 2’s operational activities would be require d to comply with applicable federal, state, and local regulations, which prescribe measures to reduce the risk of accidental spills.

Accordingly, Alternative 2’s impact related to the accidental release of hazardous materials would be greater than the prop osed project but would remain less than significant with mitigation incorporated.

Construction of Alternative 2 would occur the same distance from South Coast Montessori as the proposed project. Alternative 2’s construction activities would have reduced p otential compared to the proposed project to create a significant hazard involving the release of hazardous materials into the environment due to reduced construction activities, which would be minimized with implementation of Mitigation Measures HAZ -1 and HAZ-2. However, Alternative 2 would have a greater operational risk of hazardous material release due to increased pesticide use on-site. Alternative 2’s impact related to handling hazardous materials within

0.25-mile of a school would be increased compar ed to the proposed project but would remain less than significant with mitigation incorporated.

Alternative 2 would be located on the same site as the proposed project which is not located on a site listed pursuant to Government Code Section 65962.5. No 226
Exhibit A to Attachment 1
CEQA Findings and SOC
Shelby Residential Project
193 | P a g e

impact would occur related to listed hazardous materials sites, which would be the same level of impact as the proposed project.

Alternative 2 would be located on the same site as the proposed project which is not located within the noise or safety contour s of the Santa Barbara Airport. No impact related to excessive noise or safety hazards due to proximity to an airport would occur, which would be the same level of impact as the proposed project.