Goleta City Council
June 2, 2026

City Council Resolution 26 - _____
dust, and noise and vibration. Therefore, construction -related direct impacts and indirect impacts (including water quality effects, chemical spills, dust, and noise or vibration) w ould be potentially significant. (Draft EIR, pp. 4.3-39 through 4.3-40, 6-51 through 6-52) Cooper’s Hawk, White -Tailed Kite, and Other Raptor Species .

Cooper’s hawk and white -tailed kite have been observed on the project site, and American peregrine falcon has been observed from the project site. Nests of these species, as well as nests of common raptor species such as red -tailed hawk, are considered ESHA pursuant to the City of Goleta’s General Plan/Coastal Land Use Plan Policy CE 8.1 (City of Goleta 2006) . Alternative 4 would not include activities within 200 feet of historic nests for either Cooper’s hawk and white -tailed kite, and would avoid impacts involving ESHA or ESHA buffers for special -status raptor nest sites. The proposed replacement cart path would occur near recent nesting locations for red-tailed hawk, and construction associated with the replacement cart path could result in red -tailed hawk nest disturbance due to noise, vibration, and human presence during construction if it occurs within the nesting bird season. If raptor species are nesting on the project site at the time of grading or other project-related construction activities, disturbance to nesting, including nest abandonment and mortality of fledglings, could occur due to noise, vibration, and human presence during construction. Therefore, construction -related impacts would be potentially significant. (Draft EIR, pp. 4.3-40, 6-51 through 6-52.)
Yellow Warbler and Other Special -Status Bird Species . Yellow warbler has been detected on the project site and suitable habitat for this special -status species occurs along Bell Canyon Creek and Devereux Creek. However, the suitable habitat along Bell Canyon Creek does not occur within 400 feet of grading, construction activities, or other project activities that could result in disturbance to yellow warblers, and no direct impacts would occur. Grading would occur within approximately 50 feet of suitable habitat at Devereux Creek; if grading occurs during the nesting season when yellow warblers are present, it could result in disturbance to nesting yellow warblers due to noise, vibration, and human presence during construction. Other special-status bird species with potential to occur on the project site, including American white pelican, Californ ia brown pelican, redhead, and yellow -headed blackbird, could also undergo nest disturbance should construction activities occur near active nests for these species. Therefore, construction -related indirect impacts would be potentially significant. (Draft EIR, pp. 4.3- 49, 6-51 through 6-52)
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MM BIO-1 Pre-Construction Special-Status Plant Survey and Avoidance Prior to the start of construction activities, a City-approved, qualified biologist (retained by the project applicant) shall conduct a pre- construction special-status plant survey within 50-feet of the areas of proposed ground disturbance (including landscaping activities). The survey shall be conducted at the appropriate season, and in appropriate habitat, for identifying potentially occurring special-status plant species, including cliff malacothrix, woolly seablite, and Santa Barbara honeysuckle. The special -status plant survey shall be conducted in conformance with the California Native Plant Society Botanical Survey Guidelines (CNPS 2 001), Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities (CDFW 2018), and the
USFWS’s General Rare Plant Survey Guidelines (Cypher 2002).

Reference sites shall be visited to document if target species are detectable prior to the special -status plant survey. If special -status plant species are encountered within 50 feet of project activities, the qualified biologist shall flag a minimum 50 -foot buffer around all known locations to avoid potential impacts to seed banks and microhabitats that support the species. The buffers shall be flagged for avoidance prior to the start of construction activities. Any habitat area supporting special-status plants shall be considered ESHA, and appropriate setbacks shall be established within which no construction activities may occur and no landscaping may occur that will result in removal of or harm to rare plants. If construction has not commenced within two years of the most recent plant survey, the special-status plant survey shall be repeated prior to the start of construction. The qualified biologist shall submit a summary of the survey results to the City of Goleta’s Planning and Environmental Review Director, or designee, for review and approval p rior to initiation of construction activities, including landscaping activities.

If ground disturbing activities must occur within the established buffer, the topsoil (top 6 inches) in the disturbance areas shall be salvaged for any plant species with a Ca lifornia Rare Plant Rank of 1A to 2B. Salvaged topsoil shall be stored in temporary stockpiles and replaced in the same location following ground disturbance completion. If replacement in the same location is not feasible, the stockpiles shall be placed in the same vegetation community that currently supports the special-status plant species.

Plan Requirements and Timing . The qualified biologist shall conduct a pre-construction special-status plant survey and submit a 115
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summary of the pre -construction special-status plant survey results to the City of Goleta’s Planning and Environmental Review Director, or designee, within two years prior to the start of construction activities, including landscaping activities. If special -status plant species are detected, the qualified biologist shall flag an appropriate avoidance buffer prior to Zoning Clearance for the grading permit.

Monitoring: The City of Goleta’s Planning and Environmental Review Director, or designee, shall review and approve the survey results and keep the results on file with the City. The City of Goleta’s Planning and Environmental Review Director, or designee, shall conduct periodic spot checks to ensure that construction does not occur within the buffer during construction.

MM BIO-2 Environmentally Sensitive Habitat Fencing and Protection Prior to initiation of construction activities, the project applicant shall retain a qualified biologist to delineate all ESHA, aquatic resources, and required setbacks with temporary construction fencing and/o r flagging and signage. The fencing shall serve as a visual boundary for construction personnel and be maintained throughout the duration of construction. The construction contractor shall ensure that construction personnel and equipment do not enter the setback areas during the duration of construction activities. No non-native or invasive plant species that have a potential to displace or alter sensitive vegetation communities or vegetation communities supporting sensitive species shall be planted within ESHA or ESHA buffers. Areas protected under this measure shall include sensitive coastal sage scrub and coastal bluff scrub communities, riparian habitats associated with Devereux Creek, coastal wetlands, native grasslands, open water associated with the golf course pond, areas supporting special -status plant species, and aquatic resources.

Unless otherwise authorized, the setbacks shall be as follows:
 Sensitive scrub communities: 25 feet
 Riparian vegetation: 100 feet unless otherwise authorized  Coastal wetlands: 100 feet
 Native grasslands: 10 feet
 Monarch roost: 100 feet
 Aquatic resources and open water: 100 feet unless otherwise authorized
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No grading, vehicles or heavy machinery, or construction shall be permitted with the setbacks, unless reduced
setbacks are approved by the City for specific activities and locations. No grading, sand capping, vehicles, heavy
machinery, or construction activities shall be permitted within any ESHA at any time, unless these activities are covered under compensatory mitigation described in Mitigation
Measure BIO-11.

Plan Requirements and Timing. The project applicant shall retain a qualified biologist to delineate all ESHA and required setbacks with temporary construction fencing and/or flagging and signage prior to the start of construction activities.

Monitoring: The qualified biologist and construction
contractor shall provide evidence of ESHA delineation and BMP installation to the City of Goleta’s Planning and
Environmental Review Director, or designee, prior to the start of construction. The City of Goleta’s Planning and
Environmental Review Director, or designee, shall conduct periodic spot checks to ensure that construction does not occur within the buffer during construction.

MM BIO-3 Biological Monitoring and Worker Education
Prior to initiation of construction activities, the project applicant shall retain a qualified biologist familiar with 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 Worker Environmental
Awareness Program (WEAP) training.
 Authority to stop non-emergency work.
 Action to be taken in the event of non-compliance.
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 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 conducted by the qualified biologist prior to commencement of construction activities. The construct ion 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 species. Special -status plant species
addressed in the WEAP training shall include, at a minimum, cliff malacothrix, red sand verbena, Santa Barbara
honeysuckle, Southern California black walnut, and woolly seablite. Species -status wildlife species addressed in the WEAP, at a minimum, shall include California red-legged frog, tidewater goby, monarch but terfly, Crotch’s bumble bee, Cooper’s hawk, southwestern pond turtle, yellow warbler, and white-tailed kite.

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
construction. The qualified biologist shall submit a monitoring summary to the City of Goleta’s Planning and Environmental Review Director within 30 days after completing eac h 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-4 General Best Management Practices
The construction contractor shall ensure that all construction 118
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personnel are informed of and adhere to the general
requirements listed below prior to the start of construction activities. This measure shall be incorporated into the construction plans, including demolition, grading, building, and landscaping plans. The project applicant shall submit the construction plans to the City of Goleta’s Planning and Environmental Review Director prior to issuance of Zoning Clearance for the grading permit. The City of Goleta’s
Planning and Environmental Review Director, or designee, shall review and approve the construction plans to ensure the below measures are included.
 Best management practices, such as silt fending or
straw wattles, shall be installed prior to conducting any project activity within 100 feet of any aquatic resource, including sand capping, grading, cart path
construction, or bridge construction. Implementation of BMPs shall be consistent with any requirements from
the approved Stormwater Pollution Prevention Plan
(SWPPP) for the Project.
 Project-related vehicles shall observe a 5 -mile-per- hour speed limit within the unpaved limits of
construction.
 All open trenches shall be fenced and sloped to
prevent entrapment of wildlife species.
 All hollow posts and pipes shall be capped, and metal fence stakes shall be plugged with bolts or other
plugging materials to prevent wildlife entrapment and
mortality.
 All food-related trash items such as wrappers, cans,
bottles, and food scraps generated during proposed
project construction shall be disposed of in closed
containers and removed daily from the project site.
 No deliberate feeding of wildlife shall be allowed.
 No pets shall be allowed on the project site.
 No firearms shall be allowed on the project site.
 If vehicle or equipment maintenance is necessary, it
shall be performed in the designated staging areas.
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 During construction, heavy equipment shall be
operated in accordance with standard BMPs. All
equipment used on-site shall be properly maintained to
avoid leaks of oil, fuel, or residues. The construction contractor shall prevent oil, petroleum products, or any other pollutants from contaminating the soil or entering a watercourse (dry or otherwise). When vehicles or
equipment are stationary, mats or drip pans shall be
placed below vehicles to contain fluid leaks. Provisions shall be in place to remediate any accidental spills.
 Refueling of any equipment shall only occur in
designated staging areas. Designated areas shall not
be located near any storm drain inlets, drainage
swales, or surface waterways. When refueling gas
powered equipment or mixing herbicide, workers shall
refuel or mix over drip pan which is appropriately sized to catch any spillage. The designated refueling area
shall be inspected frequently to ensure no spill of
hazardous materials have occurred and could
contaminate the ground or water. The construction
contractor shall advise workers to cle an and report
spills immediately.
 Standard dust control measures shall be implemented
to reduce impacts on nearby plants and wildlife. This
includes a variety of options to reduce dust including
replacing ground cover in disturbed areas as quickly as possible, watering active sites regularly, and
suspending all excavating and grading operations
during periods of high winds.

Plan Requirements and Timing . This measure shall be
incorporated into the construction plans, including demolition, grading, building, and landscaping plans. The project
applicant shall submit the construction plans 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. The construction contractor shall ensure that all construction personnel are informed of and adhere to the general requirements listed above prior to the start of construction activities.

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.
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MM BIO-5 Crotch’s Bumble Bee Pre -construction Survey and Avoidance
Should ground -disturbing activities, including grading, trenching, and vegetation remov al such as grubbing, be scheduled to occur during the Crotch’s bumble bee colony active period (typically spring to late summer), a qualified biologist shall conduct a habitat assessment prior to ground - disturbing activities to identify areas containing su itable habitat for Crotch’s bumble bee. The habitat assessment shall be conducted in areas supporting suitable vegetation
communities and land covers and shall focus on presence of suitable floral resources and potential nest sites, and shall be conducted within areas of proposed ground disturbance that meet the preceding criteria. The qualified biologist shall submit the habitat assessment results to the City of Goleta’s Planning and Environmental Review Director for review and approval within five days of completing the habitat
assessment.

Following completion of the habitat assessment, if suitable habitat is present, the qualified biologist shall conduct pre - construction surveys for Crotch’s bumble bee in the areas identified as suitable, using a methodology (including number of surveys, timing of surveys, suitable survey conditions, and time of day) accepted by CDFW. The pre -construction
surveys shall be conducted prior to grounddisturbing
activities. The qualified biologist shall submit the pre - construction survey resultsto the City of Goleta’s Planning and Environmental Review Director for review and approval within five days of completing the pre-construction surveys.

If Crotch’s bumble bees are not detected during the pre - construction surveys but suitable habitat is present, a qualified biologist shall be present during ground -disturbing project activities that occur during the Crotch’s bumble bee colony active period, to ensure that no impacts occur to a previously unidentified Crotch’s bumble bee nest . No additional work restrictions with regard to Crotch’s bumble bee shall be implemented for the remainder of the colony active period. If Crotch’s bumble bees are detected, ground -disturbing
activities shall be prohibited within 100 feet of any known, occupied Crotch’s bumble bee nest, or as determined by the qualified biologist, who shall demarcate the 100 - foot buffer via flagging. Work shall not resume in this area for the duration of the Crotch’s bumble bee colony active period, unless the 121
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qualified b iologist determines the nest is inactive, with concurrence from CDFW.

If Crotch’s bumble bee remains a State candidate species or is listed as endangered or threatened under the California Endangered Species Act, and should ground -disturbing
activities in areas potentially supporting habitat extend into one or more subsequent years, the habitat assessment and, if necessary, the surveys, shall be repeated in areas where ground disturbance may occur that year. Prior to initiation of ground-disturbing activiti es, should the California Fish and Game Commission remove the candidate status of Crotch’s bumble bee and determine the species shall not be listed, then no measures protecting Crotch’s bumble bee shall be required.

Plan Requirements and Timing. The qualified biologist shall conduct a habitat assessment prior to any ground -disturbing activities during the Crotch’s bumble bee colony active period.

Following the habitat assessment, the qualified biologist shall conduct pre -construction surveys in the identifi ed suitable areas. If Crotch’s bumble bees are detected, prior to ground - disturbing activities, the qualified biologist shall demarcate a 100-foot buffer for any known, occupied nest via flagging. If Crotch’s bumble bees are not detected, a qualified biolo gist shall be present during ground -disturbing activities. The qualified biologist shall submit the habitat assessment results and pre -construction survey results to the City of Goleta’s Planning and Environmental Review Director, or designee, prior to gro und-disturbing activities. The qualified biologist shall submit monitoring results to the City of Goleta’s Planning and Environmental Review Director, or designee, following the completion of ground-disturbing activities.

Monitoring: The City of Goleta’s Planning and Environmental Review Director, or designee, shall review and approve the habitat assessment results, pre -construction survey results, and monitoring results. The City of Goleta’s Planning and Environmental Review Director, or designee, shall c onduct periodic spot checks to ensure that construction does not occur within the buffer during construction.

MM BIO-6 Monarch Butterfly Roost Protection
Construction activities (including grading and sand capping) within 200 feet of monarch butterfly ESHA shall be scheduled 122
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by the construction contractor to occur between April 1 and September 30 where feasible, to avoid overwintering monarch butterflies. Monarch butterfly ESHA designation shall be based on the City of Goleta’s General Plan/Coastal Land Use Plan Policy CE 4.1 and the most current site boundaries from the Xerces Map of Overwintering Sites, as confirmed by a monarch specialist or qualified biologist.

If construction activities within 200 feet of monarch butterfly ESHA cannot feasibly be sche duled to avoid the
overwintering season, the project applicant shall ensure the following measures are implemented prior to construction activities:
 A monarch specialist or qualified biologist shall conduct a survey for roosting monarchs prior to the start of
ground-disturbing activities, including vegetation
removal, and confirm the absence of roosting
monarchs before the work can commence. Roosting
monarch surveys must follow the Xerces Society
Protocol (2022). Surveys shall be conducted in the
early morning while temperatures are low enough that
monarch butterflies remain clustered from the evening
before (usually when temperatures are below 13 °C or
55 °F).
 Surveys shall be spaced sufficiently apart to capture roosting individuals during this timeframe a nd
conducted during a time when monarchs are present
at a local reference site as feasible. Depending on the observed monarch behavior, more than two site visits
may be necessary to conclude the presence/absence
of roosting monarchs throughout the season.
 During the overwintering season and during
construction activities, roosting monarch surveys shall be conducted routinely to confirm continued absence
or to identify, map, and describe roost locations if
presence of roosting monarchs is confirmed. Mapped
roosting locations may be adjusted as needed under
the guidance of a monarch specialist or qualified
biologist.
 Any construction activities within 200 ft of roosting monarchs within the monarch butterfly ESHA shall be
prohibited (consistent with CE 4.5 and CE 4.6d).
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 A monarch specialist or qualified biologist shall be
present during ground -disturbing activities, including vegetation removal, to document monarch butterfly
protection. The monarch monitor shall document that
roosting monarchs are not disturbed by ground -
disturbing activities. The monarch monitor shall have
authority to stop ground -disturbing activities if
monarchs show signs of unnatural disturbance.

Plan Requirements and Timing : If construction activities within 200 feet of monarch butterfly ESHA cannot feasibly be scheduled to avoid the overwintering season, the project applicant shall retain a monarch specialist or qualified biologist to conduct surveys for roosting monarchs prior to the start of construction activities. The monarch speciali st or qualified biologist shall submit survey results to the City of Goleta’s Planning and Environmental Review Director, or designee, within five days of completing the pre -construction survey. The monarch specialist or qualified biologist shall monitor g round-disturbing activities, including vegetation removal, during construction. The monarch specialist or qualified biologist shall submit monitoring results to the City of Goleta’s Planning and Environmental Review Director
following the completion of con struction activities within 200 feet of monarch butterfly ESHA.

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

MM BIO-7 Implementation of Monarch Roost Protection Plan The project applicant shall retain a qualified biologist to prepare a Monarch Roost Protection Plan prior to the start of construction activities. The Monarch Roost Protection Plan shall include the following.
 Trees majorly impacted by co nstruction, grading, and trenching of the project improvement elements within
the monarch butterfly ESHA shall be replaced at a 3:1
ratio within the ESHA and as close to the removed tree
as is reasonably feasible.
 If understory vegetation that supports ov erwintering habitat is removed within monarch butterfly ESHA, as
determined by a monarch specialist, the vegetation
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shall be replaced at a 1:1 ratio as close to the removed vegetation as is feasible.
 Grading or other activities that could alter the surface hydrology that sustains the groves of trees within
monarch butterfly ESHA are prohibited within the
ESHA buffer (50 - or 100- feet depending on whether
the site is transitory or overwintering habitat).
 The qualified biologist shall submit the Monarch Roost Protection Plan to the City of Goleta’s Planning and
Environmental Review Director, or designee, for review
and approval prior to the start of construction activities.

The construction contractor shall implement the
Monarch Roost Protection Plan for the duration of
construction.

Plan Requirements: The qualified biologistshall prepare a Monarch Roost Protection Plan, which shall be
submitted to the City of Goleta’s Planning and
Environmental Review Director, or designee, for review
and approval prior to Zoning Clearance for the grading
permit.

Monitoring and Reporting: The City of Goleta’s Planning and Environmental Review Director, or designee, shall
review and approve the Monarch Roost Protection Plan
prior to Zoning Clearance for the grading permit.

MM BIO-8 Tree Protection Measures
The construction contractor shall implem ent the following tree protection measures to ensure that impacts to
protected trees are minimized to the extent feasible or avoided, consistent with the City of Goleta’s General
Plan/Coastal Land Use Plan Policy CE 4 and CE 9, prior
to the start of projec t construction. The following tree protection measures shall be included within the project construction plans, including the grading and landscaping plans. All measures below shall be conducted by or under the direct supervision of an International Societ y of
Arboriculture (ISA) certified arborist retained by the project applicant
Prior to Construction
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 A certified arborist or qualified biologist under the supervision of the certified arborist shall monitor
any ground disturbance or vegetation removal
activities that have a potential to impact protected
trees.
 Temporary fencing such as snow fencing, not less
than 3 feet high with tree protection signs shall be
erected around all protected trees (or tree groups)
to be preserved that have a potential to be impacted
during construction. The protective fence shall be
installed at the protected zone boundary of each
tree (or tree group), which is defined as the critical
root zone. The contractor shall 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 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 protect ion practices. All
equipment operators 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 mar king of
protected trees, the necessity 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, an d 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.
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 Contractors shall ensure that damage to the tree be
avoided to the extent feasible 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 Arborist 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 by hand tools to remove soil
from trench locations. The trench should be made
no deeper than necessary, and 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
thoroughly soak the root zones of the trees t o a
depth of two feet. The soil shall be allowed to dry
out between watering to avoid keeping a
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. Replacemen t 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
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of 5 years.

Maintenance After Construction
 The contractors shall ensure that the mulch is k ept
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 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.

MM BIO-9 Preconstruction Semi -Aquatic Species Survey, Avoidance, and Relocation
Prior to the start of construction activities, a qualified biologist (retained by the project applicant) shall conduct a pre - construction survey for semi -aquatic species (e.g., California red-legged frog, southwestern pond turtle) within areas of proposed ground disturbance. The survey shall be completed seven days prior to ground disturbance in dry conditions or 48 hours prior to ground disturbance in favor able conditions for upland amphibian migration (e.g., during or immediately after heavy rain events, heavy fog, or high humidity). The qualified biologist shall survey for California red -legged frog adhering to survey techniques described in Revised Guidance on Site Assessment and Field Surveys for the California Red -legged Frog (USFWS 2005). Additionally, the qualified biologist shall survey for southwestern pond turtle adhering to the survey techniques described in USGS Western Pond Turtle (Emys
marmorata) Visual Encounter Survey Protocol for Western Pond Turtles (Oregon Department of Fish and Wildlife 2020).

The qualified biologist shall submit a summary of the survey results to the City of Goleta’s Planning and Environmental Review Director, or designee, for review and approval prior to 128
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initiation of ground disturbance.

If a special status species is identified during construction, the construction contractor shall halt construction activities within 100 feet of the location and contact the qualified bio logist. If identified during pre -construction surveys or during
construction, individual special -status species in the work area shall be allowed to move out of the work area of their own volition. If special-status species are detected and do not move out of the work area, a Species Relocation and
Exclusion Plan shall be prepared by the qualified biologist and submitted to the City of Goleta’s Planning and Environmental Review Director, or designee, for approval prior to relocation.

The Species Relocation and Exclusion Plan shall specify that if relocation by humans is required, the animal shall be captured by a qualified biologist and relocated out of harm’s way to the nearest suitable habitat, a minimum of 100 feet from the project work area where it was found. Species listed as threatened or endangered (e.g., California red-legged frog) shall only be handled as authorized by United States Fish and Wildlife Service. The qualified biologist shall document observations of special -status species on California Natural Diversity Database forms and submit the documentation to the California Department of Fish and Wildlife upon project completion. If one or more special status semi -aquatic species are detected, surveys are required each day prior to construction activities until the species has moved out of the work area or the qualified biologist has determined that construction may resume. Construction can commence when the semi-aquatic species moves or is relocated out of the work area and when approved by the q ualified biologist. If
construction ceases for more than 30 days, a new special status survey is required.

Plan Requirements and Timing: Prior to issuance of Zoning Clearance for the grading permit, the qualified biologist shall submit a summary of the survey results to the City of Goleta’s Planning and Environmental Review Director. If no special - status species are found, grading activit ies can commence and no further reporting is required.

If species are detected and do not move out of the work area, a Species Relocation and Exclusion Plan shall be prepared by the qualified biologist and submitted to the City of Goleta’s Planning and Environmental Review Director, or designee, for approval prior to relocation and commencing construction. If 129
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construction ceases for more than 30 days, a new special status survey is required.

Monitoring: The City of Goleta’s Planning and Environmental Review Director, or designee, shall review any biological survey, relocation, or exclusion reports in consultation with CDFW or USFWS. The City of Goleta’s Planning and
Environmental Review Director, or designee, shall conduct periodic site inspections to verif y compliance with survey recommendations in the field. The City of Goleta’s Planning and Environmental Review Director, or designee, shall
conduct periodic spot checks to ensure that construction does not occur within the buffer during construction.

MM BIO-10 Pre-construction Nesting Bird Surveys and Avoidance To avoid construction impacts to nesting birds and raptors, the construction contractor 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 breeding 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 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 reliab ly 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 de signee. 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.

If an active ne st of species protected by the California Fish and Game Code (§ 3503) or Migratory Bird Treaty Act are found within 300 feet of the disturbance footprint, the City - 130
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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 (GPS) unit. If active 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 appropriate, depending upon the
species and the proposed work activities. If any active non - raptor bird nests are found, th e 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 confirm s that the
breeding/nesting is completed and all the young have fledged, 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 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 (7) 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 biological 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 conduct periodic spot checks to ensure that 131
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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. (Draft EIR, pp. 4.3-51 through

4.3-55, p. 6-52.)
Explanation: Construction of Alternative 4 has the potential to result in direct and indirect impacts to arroyo willow thickets, Devereux Creek and associated riparian habitat, coastal bluff scrub/coastal sage scrub, and Monarch Butterfly Roosting Habitat. Following implementation of Mitigation Me asures HYD -1, BIO -2, BIO -3, BIO -4, BIO -6, BIO -7, BIO-8, and BIO -11, Alternative 4 ’s construction impact would be Class II, less than significant with mitigation.

Indirect Impacts on ESHA and ESHA Buffers . Indirect impacts to riparian habitat types or sensitive natural communities designated as ESHA would include water quality effects, chemical spills or vehicle leaks near and within ESHA, and dust. These impacts would be potentially significant. (Draft EIR, pp. 4.3-51, 6-51 through 6-52) Direct Impacts on ESHA and ESHA Buffers . Direct impacts to riparian habitat types or sensitive natural communities designated as ESHA and ESHA buffers would include the construction and operation of new structures or facilities within ESHA or ESHA buffers.

However, the prop osed clubhouse, comfort station, maintenance facility, and Rio Grande Coffee Shop would be located within currently developed areas. Construction of new features that could result in direct impacts to ESHA or ESHA buffers include the installation of the de composed granite path and underground utility trenching on Hollister Avenue, storm drain outlet, cart path, and a sewer line, as well as proposed grading, sandcapping, and landscaping activities, as discussed in the following subsections.

Extended Bicycle Path. Alternative 4 would include construction activities within and adjacent to monarch butterfly/raptor roosting habitat ESHA and riparian/marsh/vernal pool ESHA (as well as their associated 100 -foot buffers) along the southern edge of Hollister Avenue. These activities would include grading, paving, and installation of landscaping adjacent to eucalyptus groves designated 132
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as ESHA. Although Alternative 4 would not introduce new development into undisturbed habitat, it would result in minor encroachments into ESHA buffers and potential root zone disturbance. Alternative 4’s impacts to ESHA are not anticipated to be greater than those of Alternative 4 , because the bike path alignment is confined to previously disturbed areas and involves a low-impact use. While minor encroachment and temporary
construction-related effects may occur, they are limited in scale and duration and do not introduce substantial new development into undisturbed habitat. Additionally, Alternative 4 would avoid removal of protected trees and significant impacts to Monarch Butterfly Roosting ESHA where feasible through project design. Furthermore, as with Alternative 4, Alternative 4 would require Mitigation Measures HYD-1, BIO -2, BIO -3, BIO-4, BIO -6, BIO-7, BIO-8, and BIO -11 to reduce potential impacts related to riparian habitat, ESHA, and wetlands to a less than significant level. Alternative 4’s impact related to riparian habitat, ESHA, and aquatic resources would be similar to Alternative 4 and would remain less than si gnificant with mitigation. (Draft EIR, 6-51 through 6-52.)
Storm Drains . The proposed installation of a storm drain and associated outlet within arroyo willow thickets along Devereux Creek in the eastern portion of the project site would temporarily impact, via trenching, 0.005 acre of arroyo willow thickets; and of the 0.005 acre, approximately 0.002 acre consists of non -wetland waters under the jurisdiction of USACE. Temporary impacts would constitute disturbances, such as vegetation removal and soil disr uption during construction, to this sensitive natural community. The proposed storm drain installation would also permanently impact 0.002 acre of arroyo willow thickets through habitat loss. This impact would be a significant impact. (Draft EIR, pp. 4.3-52, 6-51 through 6-52) Cart Paths . A proposed replacement cart path extends from just south of the maintenance facility, crosses Devereux Creek at a proposed free-span bridge, and terminates south of Devereux Creek.

A portion of the path and the bridge loca ted southwest of proposed Hole 4 and Hole 5, would occur within the ESHA buffer for arroyo willow thickets. The northern portion of the path would occur within Monarch Butterfly Roosting Habitat ESHA and ESHA buffer.

However, the City of Goleta’s General P lan/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 cart path and free -span bridge would minimize impacts to habitat values or 133
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sensitive species to the maximum extent feasible from the existing configuration throug h site design. Furthermore, the new cart path and free -span bridge would replace an existing cart path and Arizona-style concrete crossing that are currently within Devereux Creek riparian ESHA and Monarch Butterfly Roosting Habitat ESHA, along the eastern boundary of the project site. Alternative 4 would remove 5,134 square feet of cart path within the Devereux Creek ESHA (which would decrease impervious hardscape by nearly 50 percent [for a total of 2,607 square feet of hardscape]), remove the existing 10- to 12-inch concrete culvert, and restore approximately 2,831 square feet of Devereux Creek riparian ESHA and Monarch Butterfly Roosting Habitat ESHA. The portion of the path within Monarch Butterfly Roosting Habitat ESHA and ESHA buffer would replace the existing cart path and would not result in additional impacts as the location would remain consistent.

Construction of the free -span bridge would occur within Devereux Creek, which could temporarily affect water quality and consequently riparian ESHA associated with the creek. The construction contractor would implement construction BMPs and stormwater monitoring to reduce the potential to introduce sediment and pollutants and degrade water quality in Devereux Creek. However, construction work inside Devereux Creek during periods of high flows could result in the degradation of water quality from increased erosion.

Therefore, impacts to ESHA from construction of the free -span bridge would be potentially significant. (Draft EIR, pp. 4.3 -51, 6-52 through 6-53, 6-51 through 6-52)
Utility Trenches. The proposed utility trench (for undergrounding of existing utilities) crosses over a culvert south of Hollister Avenue and above Devereux Creek, and is located within the minimum ESHA and SPA buffers for Devereux Creek. Trenching activities may require removal of unhealthy eucalyptus trees that may contribute to habitat based on jurisdictional water agency (e.g., CDFW, RWQCB, USACE) determination, but impacts would not extend further than the proposed decomposed gr anite path. Trenching may also have the potential to result in degradation of riparian ESHA associated with Devereux Creek through chemical spills or sedimentation from construction activities. Trenching would be a potentially significant impact to ESHA.

Alternative 4 would involve the installation of a sewer line within the eastern portion of the project site that connects to the comfort station.

Construction of the proposed sewer line would temporarily, directly impact 0.04 acre of riparian habitat under the jurisdiction of CDFW, the Central Coast RWQCB, and CCC. Temporary impacts would 134
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constitute disturbances, such as vegetation removal and soil disruption during construction. This impact would be potentially significant. The proposed sewer line trench is not anticipated to require removal of or major impacts to trees within the Monarch Butterfly Roosting Habitat ESHA, however accidental damage to trees through construction accidents could occur that would be a potentially significant impact to ESHA. (Draft EIR, pp. 4.3 -53, 6-51 through 6-52)
Grading, Landscaping and Sandcapping . Alternative 4 would involve grading for recontouring and sand capping within the 100 - foot ESHA and SPA buffers for Devereux Creek, where nonnative grasses (wild oats and annual bro me grassland) would be replaced with the recontoured golf course. However, the existing nonnative grasses within the buffer are currently part of the golf course.

Furthermore, the proposed daylighting of downstream portions of Devereux Creek, via removal o f an underground culvert, would improve the overall biotic quality of Devereux Creek.

Grading and sand -capping would occur within Monarch Butterfly Roosting Habitat ESHA and ESHA buffer along the eastern boundary of the site. These activities are not anti cipated to result in removal or major impacts to trees within the ESHA or alter the surface hydrology or remove native vegetation within the ESHA buffer, as the proposed activities would be limited to surface -level modifications that avoid tree root zones and alterations to drainage patterns.

Grading and sand-capping would also occur near the coastal bluffs and within the ESHA buffers for quailbush scrub and California brittle bush – ashy buckwheat scrub alliance, both of which are considered coastal bluff scrub/coastal sage scrub ESHA under the City of Goleta’s General Plan/Coastal Land Use Plan. However, the grading (recontouring) and sand-capping would promote infiltration of water, reduced waterlogging, and better root growth. Proposed activities would be consistent with the City of Goleta’s General Plan/Coastal Land Use Plan Policy CE 5.3 and would avoid ESHA and occur within the ESHA buffer only in areas that are already existing golf course, and would remain turf or playable areas of the golf course.

Alternative 4 would involve the installation of native plants in all graded and sand capped areas that are not playable, pursuant to the City of Goleta’s General Plan/Coastal Land Use Plan Policy CE 5.3.

Therefore, proposed grading, landscaping and sand -capping activities would have a less than significant impact on ESHA. (Draft EIR, pp. 4.3-53 through 54, 6-52 through 6-53, 6-51 through 6-52) 135
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Summary of Impacts on ESHA
Alternative 4 would result in both indirect and direct impacts to riparian habitat types or sensitive natural communities designated as ESHA. Indirect impacts would include water quality effects, chemical spills or vehicle leaks near and within ESHA, dust, and inadvertent habitat destruction during construction. Direct impacts would include permanent impacts to 0.002 acre and temporary impacts to 0.005 acre of arroyo willow thickets and additional impacts to eucalyptus vegetation associated with riparian ESHA in Devereux Creek. The overall project-related impact on riparian habitat or sensiti ve natural communities would be potentially significant.

Mitigation Measure HYD -1 and Mitigation Measures BIO -2, BIO-3, BIO-4, BIO-6, BIO-7, BIO-8, and BIO-11 are required.

Mitigation Measure HYD-1 would require culvert removal and bridge installation at Devereux Creek to occur within the dry season to minimize the potential for construction pollutants to enter water within Devereux Creek. Mitigation Measures BIO -2, BIO -3, and BIO -4 would reduce potential indirect impacts to riparian habitat or sensitive vegetation communities during project construction by requiring fencing around ESHA, biological monitoring during construction, construction worker environmental awareness training, and implementation of best management practices that would minimize potential impacts to biological resources during construction.

Mitigation Measure BIO -11 would reduce potential permanent impacts to riparian habitat or sensitive vegetation communities by requiring compensatory mitigation for habitat loss due to project development. Following the implementation of Mitigation Measures HYD-1, BIO -2, BIO -3, BIO -4, and BIO -11, Alternative 4 ’s impact involving a substantial adverse effect on riparian habitat or sensitive vegetation communities would be less than significant with mitigation incorporated. (Draft EIR, pp. 4.3-51 through 4.3-55, p. 6-52.)

MM BIO-11 Compensatory Mitigation for Impacts on Sensitive Communities and Riparian Habitat
Onsite mitigation shall be provided to compensate for the permanent loss of arroyo willow thickets/riparian habitat (0.002 acre) at a ratio of 5:1. Temporary impacts to arroyo willow thickets/riparian habitat (0.005 acre), eucalyptus woodland/riparian habi tat (0.04 acre), and nonwetland waters of the United States and State (0.002 acre) shall be restored at a 1:1 ratio. Details of the mitigation program 136
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requirements shall be described in a Habitat Mitigation and Monitoring Program (HMMP). A qualified biolog ist, retained by the project applicant, shall prepare the HMMP.

Final landscape plans for the project shall not include removal of sensitive vegetation or aquatic resources in areas for landscaping purposes only (where no construction ground disturbances, including grading, trenching, excavation for bioretention basins or other drainage or utility features, is proposed).

Requirements described in the HMMP shall include:
 Specification that mitigation shall be on -site and shall occur adjacent, or as near as possible, to any removed
habitat area. Mitigation for loss of arroyo willow/riparian habitat associated with Devereux Creek shall occur only along Devereux Creek, and near the area of impacts to the extent possible.
 Mitigation for the loss of riparian habi tat and non-wetland waters of the United States and State shall conform with any requirements included within a Lake and Streambed
Alteration Agreement provided by the California
Department of Fish and Wildlife, a Clean Water Act 401
Certification issued b y the Central Coast Regional Water Quality Control Board, or USACE Clean Water Act Section 404 permit.
 The mitigation program shall conform with all requirements of the City of Goleta’s General Plan/Coastal Land Use
Plan and the City of Goleta Creeks and W atershed
Management Plan.
 Specification of a 5 -year monitoring period for all
restoration areas.
 Development of a plant palate for each restoration area (arroyo willow thicket/riparian, eucalyptus woodland, non - wetland waters of the United States and State) in keeping with the character and plant composition of the native
community being restored.
 Restoration for temporary impacts within monarch butterfly winter roosting habitat shall conform with requirements of the City of Goleta’s General Plan/Coastal Land Use Plan. 137
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 Defined attainable and measurable goals and objectives to be achieved through implementation of the HMMP.
 A restoration work plan that details methodologies, a restoration schedule, plant materials(seed), and
implementation strategies. Performance standards for the restoration work plan shall include achievement of
vegetation cover, species diversity, and soil stability standards.
 A detailed maintenance plan to include removal of invasive non-native species.
 A monitoring plan that includes meth ods and analysis of results, goals for success or failure, and an adaptive
management plan and suggestions for failed restoration
efforts.
 Restoration activities using native species from locally collected stock.

The qualified biologist shall submit the HMPP to the City of Goleta’s Planning and Environmental Review Director, or designee, for review and approval prior to initiation of construction activities. Plan Requirements and Timing: The project applicant shall retain a qualified biologist to prepare an HMMP prior to Zoning Clearance for the grading permit. The qualified biologist shall submit the HMMP to the City of Goleta’s Planning and Environmental Review Director, or designee, for review and approval prior to Zoning Clearance for the grading permit. Monitoring: The City of Goleta’s Planning and Environmental Review Director, or designee, shall review and approve the HMMP prior to the start of construction activities. The City of Goleta’s Planning and Environmental Review Director, or designee, shall ensure compliance with the onsite mitigation requirements and monitor the restoration efforts throughout the 5 - year monitoring period.

3. Wetlands
Threshold: Would the Project have a substantial adverse effect on federally protected wetlands (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. (Draft EIR, pp.4.3-56 through

4.3-57)
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Explanation: Project construction has t he potential to result in direct and indirect substantial adverse effects to aquatic resources, including Devereux Creek and the Golf Course Pond. Operation of Alternative 4 would be similar to existing conditions and would have a less than significant impact to aquatic resources. Following implementation of Mitigation Measures HYD -1, BIO-2, BIO-3, BIO-4, and BIO -11, the project’s construction impact would be Class II, less than significant with mitigation.

Alternative 4 would involve the installation of a storm drain and associated outlet, which would include permanent removal of 0.002 acre of riparian and streambed habitat associated with Devereux Creek (Aquatic Resource B), which is under the jurisdiction of CDFW, the Central Coast RWQCB, and the CCC; and of the 0.002 acre, approximately 0.001 acre consists of non-wetland waters of the United States under the jurisdiction of USACE. Additionally, trenching for construction of the storm drain would result in temporary impacts to 0.005 acre of riparian and st reambed habitat under the jurisdiction of CDFW, the Central Coast RWQCB, and the CCC; and of the 0.005 acre, approximately 0.002 acre consists of non-wetland waters under the jurisdiction of USACE. The proposed installation of the storm drain and associated outlet would not impact wetlands.

Alternative 4 would involve the installation of a water line within the eastern portion of the project site. Trenching for the water line would occur within the minimum 100 -foot SPA buffer for non -wetland waters of the State and United States associated with Devereux Creek (Aquatic Resource B). Construction of the proposed water line would temporarily impact 0.04 acre of riparian habitat under the jurisdiction of CDFW, the Central Coast RWQCB, and CCC; and of the 0.04 ac re, approximately 0.003 acre consists of non -wetland waters under the jurisdiction of USACE. Trenching would occur at a depth of 4 feet, which could potentially result in damage to existing eucalyptus trees within the riparian habitat. The proposed installation of the water main would not result in the direct, permanent removal of riparian habitat and would not impact wetlands.

Alternative 4 would involve utility trenching and the installation of a decomposed granite path along Hollister Avenue within the minimum 100-foot SPA buffer of Devereux Creek (Aquatic Resource B). This may result in temporary and permanent impacts to CDFW, RWQCB, CCC, and USACE jurisdiction, particularly to eucalyptus trees within the riparian habitat. The proposed activities along H ollister Avenue would not result in impacts to wetlands.
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Alternative 4 would involve the filling and grading of Aquatic Resource E, which is an anthropogenic stormwater drainage feature within the northwestern portion of the project site. Alternative 4 would replace this feature with an on -site stormwater treatment basin, which would result in the removal of 0.01 acre of potential CDFW streambed and potential non -wetland waters of the State under the jurisdiction of the Central Coast RWQCB.

Alternative 4 would involve grading, for recontouring of the golf course, within the 100 -foot SPA buffer for the Golf Course Pond (Aquatic Resource C) and for Devereux Creek (Aquatic Resource B).

The proposed grading activities would not have a direct effect on streamside vegetation, as grading activities would occur more than 25 feet from riparian habitat, and would not result in permanent development that could directly or indirectly affect the biotic quality of the Golf Course Pond or Devereux Creek.

Indirect impacts to aquatic resources, including Devereux Creek and the Golf Course Pond, could occur during construction and operation of Alternative 4 . Indirect construction impacts could include increased erosion, sedimentation, or the leakage of chemicals, liquid products, petroleum products, and concrete-related waste to aquatic resources within the project site. These indirect construction impacts would be potentially significant.

Operation and maintenance of Alternative 4 would be similar to existing conditions at the project site. Indirect operational impacts could include oil leaks from vehicles traveling to and from the project site, oil leaks from on -site vehicles, pesticide or fertilizer spillage, leaching of metals from roof and drains, or transport of litter during storm events to aquatic resources within the project site. With the implementation of Source Control and Low Impact Development BMPs, operation of Alternative 4 would have a less than significant impact to aquatic resources.

Mitigation Measure HYD-1, and Mitigation Measures BIO -2, BIO-3, BIO-4, and BIO -11, are required. Mitigation Measure HYD -1 would require culvert removal and bridge installation at Devereux Creek to occur within the dry season to minimize the potential for construction pollutants to enter water within Devereux Creek. Mitigation Measures BIO-2, BIO-3, and BIO-4 would reduce potential indirect impacts to wetlands during project construction by requiring fencing around aquatic resources, biological monitoring du ring construction, construction worker environmental awareness training, and implementation of best management practices that would minimize potential impacts to biological resources during construction. 140
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Mitigation Measure BIO -11 would reduce potential per manent impacts to wetlands by requiring compensatory mitigation for habitat loss due to project development. Following the implementation of Mitigation Measures HYD -1, BIO -2, BIO -3, BIO -4, and BIO -11, Alternative 4 ’s impact involving a substantial adverse effect on wetlands would be less than significant with mitigation incorporated. (Draft EIR, pp. 4.3-56 through 57, 6-52 through 6-53)

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.

Explanation: Construction of Alternative 4 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. Construction activities would adhere to typical working hours, and construction noise would not affect nocturnal terrestrial wildlife movement. Impacts on wildlife movement from construction -related noise would be potentially significant, and mitigation would be required.

Mitigation Measure NOI-1 would reduce potential indirect impacts to wildlife movement during project construction by minimizing construction noise in compliance with existing City noise standards, which are set to a threshold below noise levels known to produce adverse physiological effects in wildlife (Fletcher 1971). Following the implementation of Mitigation Measure NOI -1, Alternative 4 ’s impact to wildlife movement would be less than significant. (Draft EIR, pp. 4.3-57 through 4.3-59, p. 6-52.)

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. (Draft EIR, pp. 4.3 -59 through

4.3-61, 6-52.)
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Explanation: Alternative 4 would include installation of a storm drain and associated outlet within arroyo willow thickets ESHA along Devereux Creek, sand capping and grading within the 100 -foot Streamside Protection Area, and trenching for underground utili ties within riparian ESHA along Devereux Creek and along the eastern project site boundary within riparian and monarch butterfly roosting habitat ESHA. Additionally, Alternative 4 would include construction activities within and adjacent to monarch butterf ly/raptor roosting habitat ESHA and riparian/marsh/vernal pool ESHA (as well as their associated 100 -foot buffers) along the southern edge of Hollister Avenue, due to the extension of the bicycle path.

Alternative 4 would be potentially inconsistent with the City of Goleta’s General Plan/Coastal Land Use Plan Policies CE 1 .6, CE

2.2, CE 4.4, and CE 9.5. Alternative 4 may result in direct impacts, such as root and/or canopy pruning or compaction or accidental damage during excavation and grading, to 27 tree s due to the extension of the bicycle path. However, removal of and major impacts to protected trees are anticipated to be avoided (and reduced to less than significant) through implementation of project design measures such as root bridging or shaving, sh ifting the alignment, or eliminating sections of curb/gutter. The extended bicycle path under Alternative 4 is an allowed use (public accessway/trail) pursuant to General Plan/Coastal Land Use Plan Policy CE 1.6.

Alternative 4 would require implementation of Mitigation Measures BIO-2, BIO-3, BIO-4, BIO-6, BIO-7, BIO-8, and BIO-11, which would result in consistency with General Plan/Coastal Land Use Plan Policies CE 1.6, CE 2.2, CE 4.4, and CE 9.5, and reduce this impact to a less than significant level, whi ch would be the same as the proposed project.

Mitigation Measure BIO -2 would reduce potential impacts to ESHA by requiring fencing around special -status plant habitat that would ensure avoidance of such habitat during construction activities.

Mitigation M easures BIO -3 and BIO -4 would reduce potential impacts to ESHA by requiring biological monitoring during construction, construction worker environmental awareness training, and implementation of best management practices that would minimize potential impac ts to biological resources during construction. Mitigation Measure BIO -6 would reduce potential impacts to Monarch Butterfly Roosting Habitat ESHA. Mitigation Measures BIO -7 and BIO -8 would reduce potential impacts to protected trees by requiring preparati on of a Monarch Roost Protection Plan, as well as implementation of tree protection 142
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measures during project construction activities. Specifically, Mitigation Measure BIO -8 would require replacement of protected trees at a 3:1 ratio. Mitigation Measure BIO -11 would reduce potential permanent impacts to ESHA by requiring compensatory mitigation for habitat loss due to project development. Following the implementation of Mitigation Measures BIO-2, BIO-3, BIO-4, BIO-6, BIO-7, BIO-8, and BIO-11, Alternative 4 would be consistent with the City of Goleta’s General Plan/Coastal Land Use Plan Policies CE

1.6, 2.2, 4.4 and CE 9.5, and Alternative 4’s impact involving conflict with any local policies or ordinances protecting biological resources would be less than s ignificant with mitigation incorporated. (Draft EIR, pp. 4.3-59 through 4.3-61, 6-52.)
B. 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: Less than significant with mitigation. (Draft EIR, pp. 4.4 -14 through

4.4-18, p. 6-53.)
Explanation: The Barnsdall Rio Grande Gas Station, located at 7825 Hollister Avenue (Assessor’s Parcel Number 079 - 210-059), is a designated City of Goleta Landmark pursuant to Goleta City Council Resolution 22-10 and is designated County of Santa Barbara Landmark #29.

Therefore, it is a historical resource as defined by CEQA 15064.5(a)(2) because it is “included in a local reg ister of historical resources, as defined in section 5020.1(k) of the Public Resources Code”.

Alternative 4 would include the restoration and adaptive reuse of the Barnsdall Rio Grande Gas Station as a new quick stop café, renamed the Rio Grande Coffee Shop. The Rio Grande Coffee Shop would consist of two parts: the restored existing 349 square foot Barnsdall Rio Grande Gas Station to serve as seating for the café and a new 695 square foot café building designed to resemble a 1920s gas station service bay, located to the east of the existing gas station building. New wooden trellises would be located to the west of the existing gas station building, and on the eastern and western sides of the Rio Grande Coffee Shop.

Proposed renovations to the existing gas station building include remodeling the interior to function as an extension of seating for the 143
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new coffee shop. The proposed improvements to the Barnsdall Rio Grande Gas Station would be consistent with all of the applicable Secretary of the Interior’s S tandards for Rehabilitation and thus the City of Goleta Historic Preservation Ordinance. However, construction activities associated with the Rio Grande Coffee Shop would result in vibration near the Barnsdall Rio Grande Gas Station.

Vibration damage, such as through structural damage or material fatigue, to the Barnsdall Rio Grande Gas Station as a result of construction activities would result in a potentially significant impact on the historic building.

While Alternative 4 plans comply with the Standard s for Rehabilitation, it is possible during project implementation that repairs, replacements, materials, finishes, designs, colors, textures, and other visual qualities may not be implemented with the intent of the Standards for Rehabilitation. If the wro ng materials are used during project construction, a potentially significant impact to the Barnsdall Rio Grande Gas Station’s historical integrity would occur.

To reduce the possibility of inappropriate treatments and protect the historic integrity of the Barnsdall Rio Grande Gas Station Alternative 4 would comply with Mitigation Measure CUL -1, which requires coordination and monitoring by the City and/or architectural historian.

Implementation of Mitigation Measure NOI -2 would ensure project - related ground borne vibration during construction activities at the Barnsdall Rio Grande Gas Station would be less than the significance threshold of 0.08 inches per second peak particle velocity. With implementation of Mitigation Measure NOI -2, project impacts involving a substantial adverse change in the significance of a historical building due to vibration -related impacts would be less than significant. Implementation of Mitigation Measure CUL-1 would ensure that repairs, replacements, materials, finishes, designs, colors, textures, and other visual qualities inconsistent with the Standards for Rehabilitation would be avoided during project implementation and the historic integrity of the Barnsdall Rio Grande Gas Station is retained. With the implementation of Mitigat ion Measure CUL-1 project impacts would be less than significant. (Draft EIR, pp. 4.4-14 through 4.4-18, p. 6-53.)

MM CUL-1 Architectural Monitoring for Barnsdall Rio Grande Gas Station The project applicant shall retain a Secretary of Interior’s Professionally Qualified architectural historian and/or the City’s Urban Historian (qualified historian) to ensure the project implementation utilizes the Secretary of Interior’s Standards for Rehabilitation and guidelines from the National Park Service 144
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including:
 Preservation Brief #9, The Repair of Historic Wood Windows  Preservation Brief #10, Exterior Paint Problems on Historic Woodwork
 Preservation Brief #32, The Preservation and Repair of Historic Stuccowork
 Preservation Brief #45, Preserving Historic Wood Porches

The project applicant shall provide proof of retainment of the qualified historian to the City of Goleta’s Planning and Environmental Review Director prior to the issuance of Zoning Clearance for the building permit for the renovation of the Barn sdall Rio Grande Gas Station.

The requirement shall be referenced in the construction plans for the Rio Grande Coffee Shop intended for use by the construction contractor(s).

Prior to the start of renovation of the Barnsdall Rio Grande Gas Station, the qu alified historian shall review the replacements, materials, finishes, designs, colors, textures, and other visual qualities for consistency with the Secretary of Interior’s Standards for Rehabilitation. During renovation of the Barnsdall Grande Gas Station, the qualified historian shall conduct weekly spot checks to monitor construction progress for consistency with the Standards for Rehabilitation. Monitoring may be increased or reduced as deemed necessary by the qualified historian with approval by the Ci ty of Goleta’s Planning and Environmental Review Director, or designee.

The qualified historian shall have the authority to halt work if inconsistent with the Standards for Rehabilitation and develop a plan to revise the work for consistency with the Stand ards for Rehabilitation in consultation with the City and contractor(s).

Throughout the renovation of the Barnsdall Rio Grande Gas Station, the qualified historian shall submit a weekly update to the City of Goleta’s Planning and Environmental Review Dir ector to document compliance. The update shall include date of monitoring, project progress, compliance or non -compliance with the Standards for Rehabilitation, and necessary actions to ensure compliance with the Standards for Rehabilitation.

Plan Requirements and Timing. Prior to renovation of the Barnsdall Rio Grande Gas Station, the project applicant shall retain a qualified historian. The qualified historian shall review project plans for replacements, materials, finishes, designs, colors, textures, a nd other visual qualities for consistency with the Secretary of Interior’s 145
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Standards for Rehabilitation prior to and during renovation of the Barnsdall Rio Grande Gas Station.

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 building permit for the renovation of the Barnsdall Rio Grande Gas Station.

Monitoring. Throughout the renovation of the Barnsdall Rio Grande Gas Station, the qualified historian shall submit a weekly update to the City of Goleta’s Planning and Environmental Review Director to document compliance. The update shall include date of monitoring, project pro gress, and compliance or non -compliance with the Standards for Rehabilitation, and necessary actions to ensure compliance with the Standards for Rehabilitation. The City of Goleta’s Planning and Environmental Review Director, or designee, shall review the weekly updates.

2. Archaeological Resources
Threshold: Would the Project cause a substantial adverse change in the significance of an archaeological resource pursuant to State CEQA Guidelines, section 15064.5?
Finding: Less than significant with mitigation. (Draft EIR, pp. 4.4 -18 through

4.4-22, p. 6-53.)
Explanation: Construction. Project-related ground disturbance would extend up to 6 feet below the current ground surface for installation of landscaping and paving; up to 4 feet below the current ground surface within the golf course for utility installation; and up to 25 feet below the current ground surface for construction of the new clubhouse. Although the project site has been subject to previous ground disturbance, the proposed depths of dis turbance necessary for utility and clubhouse construction would likely extend deeper than previously disturbed soils. Given the cultural sensitivity of the area (as inferred by archival documents and existing cultural resources located within and surrounding the project site), and the presence of potentially intact native soils, unknown or previously unrecorded archaeological materials may exist within the project site. If these materials constitute unique archaeological resources under CEQA, disturbance of these resources could result in a substantial adverse change in the significance of an archaeological resource and impacts would be potentially significant.

Construction of Alternative 4 would slightly increase the amount of ground disturbance compared t o the proposed project 4 as 146
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Alternative 4 would extend the bicycle path to Pebble Beach Drive.

However, this increase would be nominal given the overall scale of ground disturbance. Under Alternative 4, approximately 0.49 acre of additional ground disturba nce would occur, which is approximately

0.28 percent of the total anticipated ground disturbance of 174.43 acres under the proposed project . No known archaeological resources are located within the extended bicycle path area. The increase in ground disturb ance would be nominal given the overall scale of ground disturbance that would occur. In addition, the extended bicycle path area is located within the disturbed right -of- way of Hollister Avenue, which would have a reduced potential to contain unknown arch aeological resources due to the amount of previous disturbance. However, because ground disturbance would occur, Alternative 4 has potential to encounter unknown cultural resources and Mitigation Measures CUL -2 through CUL -4 would continue to be required.

Mitigation Measures CUL-2 through CUL-4 would minimize potential impacts to unanticipated discoveries of archaeological resources by requiring archaeological monitoring, a cultural resources sensitivity meeting for construction personnel, and implementatio n of appropriate procedures for evaluation and treatment of any discoveries made during construction. Therefore, implementation of Mitigation Measures CUL-2 through CUL-4 would reduce impacts to archaeological resources to a less than significant level. (Draft EIR, pp. 4.4-18 through 4.4-22, p. 6-53.)
MM CUL-2 Archaeological Monitoring
Prior to ground disturbance activities, the project applicant shall retain an archaeologist who meets the Secretary of the Interior’s Professional Qualification Standards (qualified archaeologist) and has experience in California prehistoric and historic r esources (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 (Plan), conduct archaeological monitoring, and address any inadvertent discoveries identified d uring 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 sha ll outline archaeological and Native American resource monitoring protocols, 147
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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 prov ide 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 construction - related earth 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 establish 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 monitoring logs are maintained. The requirement for archaeological monitoring shall be not ed on all demolition and grading plans. The qualified archaeologist shall prepare an archaeological monitoring report within 60 days following completion of ground disturbance, 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 mitigation 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 G oleta’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 sh all 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 prior to the issuance of Zoning Clearance for the grading permit.
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Monitoring. The quali fied archaeologist shall manage monitoring during initial ground disturbance, adjusting efforts based on the potential to encounter cultural deposits. Daily monitoring logs shall be maintained. The qualified archaeologist shall prepare an archaeological mo nitoring 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 days following completion of ground disturbance. 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.

MM CUL-3 Workers Environmental Awareness Program (WEAP) 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. A basic presentation shall be prep ared 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 training 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 significant archaeological resources. Each worker shall also learn the proper procedures to follow in 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 project, 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 a nd the project applicant shall maintain records demonstrating 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 Directo r prior to construction activities and as-needed after 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 149
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shall be kept on file with the City of Goleta’s Planning and Environmental Review Director for the duration of construction.

MM CUL-4 Unanticipated Discovery of Cultural Resources If unanticipated cultural resources are discovered during project - related ground disturbance activities, the following procedures shall be implemented:
 In the event that archaeological resources are unexpectedly encountered during ground disturbing activitie s, the
construction contractor(s) shall halt work within 50 feet of the find and contact the qualified archaeologist. 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 meeting, 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 avoidance of the newly discovered resource(s) shall be consistent with the Plan prepared pursuant to
Mitigation Measure CUL-2. This may include avoidance of the cultural resources through project design, in -place
preservation of cultural resources located in native 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. Th e 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 dist urbance, 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 150
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the Plan and the qualified archaeologist 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.
 If the resource proves to be eligible for the California Register of Historical Resources and significant impacts to the
resource cannot be avoided via project redesign, the qualified archaeologist shall prepare a data recovery plan tailored to the ph ysical 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 an y significant impacts to cultural resources related to the resource. The City of Goleta’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 City 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 meet 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 151
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Review Director, or designee, has verified that mitigation is implemented. Work outside the 50 -foot buffer shall continue with additional monitoring if necessary.

Monitoring. The City of Goleta’s 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 Resources 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: 1(b) Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking?
Finding: Less than significant with mitigation incorporated. (Draft EIR, pp. 4.6- 10 through 4.6-19, 6-56.)
Explanation: The project site is located in a seismically active area and seismic activity could affect structures on the project site. Mitigation Measure GEO-1 would require incorporation of seismic design
recommendations from geotechnical reports prepared for project structures into the project’s structural design, which would reduce impacts involving seismic ground shaking. Construction and operational impacts would be Class II, less than significant with mitigation incorporated.

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. Primary seismic risks at the project site would be earthquakes generated by local faults, as well as larger regional faults, such as the San Andreas Fault. The design of Alternative 4’s structural elements (i.e., the proposed clubhouse, Rio Grande Coffee Shop, and comfort station) would be designed to withstand seismic loads, as required by the CBC; however, in the event of an earthquake the se proposed structures could result in substantial adverse effects involving strong seismic ground shaking. Therefore, this impact would be potentially significant, and mitigation is required.

Implementation of Mitigation Measure GEO-1 would reduce potential 152
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impacts due to ground -shaking 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 the risk of loss, injury, or death invol ving strong seismic ground shaking. (Draft EIR, pp. 4.6 -10 through 4.6 -19, 6-

56.)
MM GEO-1 Geotechnical Design
The applicant’s project design engineer shall incorporate the recommendations listed below from the Site-Specific Hazards Study and Preliminary Foundation Investigation (Appendix F -1), Preliminary Geotechnical Investigation for Proposed Club House (Appendix F-2), and the Preliminary Geotechnical Investigation for Proposed Comfort Station (Appendix F -3) into the project’s grading and building plans. The applicant shall submit the grading and building plans to the Planning and Environmental Review 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 Review Director or designee prior to the start of construction. The licensed geotechnical professional shall be responsible for ensuring proper implementation of the recommendations below and providing 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.

GRADING (GENERAL)

1. The area to be graded shall be cleared of surface vegetation, including roots and root structures.

2. If, during the removal and scarification process, excessive root structures are encountered, these areas shall be deep ripped in two directions to the depth of the root structure, after which the disturbed soils and the roo ts shall be completely removed, and the resulting cavities shall be scarified and processed to receive fill in accordance with recommendations contained in this section.

3. If, during the grading operations, previously placed undocumented fill material is encountered, this fill material shall be removed under the direction of the project design engineer prior to commencement of the filling operations.
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4. Removed surface soils and/or imported approved fill will be placed in loose lifts of approximately 6 inches, thoroughly mixed, moistened or dried to near optimum moisture content, and compacted to a minimum of 90 percent relative compaction.

5. Rocks greater than 6 inches in size shall be removed from the soil being spread for compaction.

6. Import soils, if required for compacted fill, shall be granular, non - expansive soils which are equal to, or superior in quality to, the on - site soils as determined by the project design engineer prior to importation of the fill material to the site.

7. The compaction standard shall be the latest adoption of the ASTM D-1557 method of compaction.

8. Positive surface drainage shall direct water away from all slopes and away from the foundation system of the proposed structure

GRADING (CLUBHOUSE)

1. In areas where compac ted fill soil is to be placed, the area to receive the fill soil shall be prepared. In the area to be prepared, the loose topsoil and compressible surface soils shall be removed and observed by the project design engineer. Upon approval of excavation, the exposed ground surface shall be scarified an additional 6 to 8 inches, moistened or dried to near the optimum moisture content, and compacted to 90 percent of the relative compaction.

2. The footings of the proposed structures shall be supported completely on firm undisturbed original ground. The structures shall not be supported over a cut/fill transition unless the foundation is engineered to account for the transition.

3. All fill slopes which are created during the grading operation shall be properly shaped to a maximum slope angle of 2 horizontal to 1 vertical, and compacted by rolling the sheepsfoot roller or similar compaction equipment over the slope face at vertical lift intervals of 30 inches or less.

GRADING (COMFORT STATION)

1. The footings of the proposed structures shall be supported completely by a uniform thickness of non-expansive compacted soil.

The structures shall not be supported over a cut/fill transition. 154
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2. Beneath the proposed structures and for a minimum distance of 5 feet beyond the exterior perimeters, the loose topsoil and compressible surface soils shall be removed and observed by a representative of our firm. Upon approval of excavation, the exposed ground surface shall be scarified an additional 6 to 8 inches, moistened or dr ied to near the optimum moisture content, and compacted to 90 percent of the relative compaction. The minimum depth of removal shall be at least 12 inches below the bottom of the proposed footings.

GRADING (RIO GRANDE COFFEE SHOP)

1. It should be noted gas tanks that were buried on the property have been removed and the resulting void was backfilled with an imported yellow sand. If these backfilled areas are located below the proposed structures, backfill soil shall be removed and replaced at 95 percent compaction.

2. The footings of the proposed structures shall either be supported completely by a uniform thickness of non -expansive compacted fill or the foundations shall be designed to penetrate the fill and compressible topsoil such that the structure is supported either completely over fill or completely on firm original ground. The structures shall not be supported over a cut/fill transition unless the foundation is engineered to account for the transition.

3. Beneath the proposed structures and for a minimum distance of 5 feet beyond the exterior perimeters, the loose topsoil and compressible surface soils shall be removed and observed by the project design engineer. Upon approval of excavation, the exposed ground surface shall be scarified an additiona l 6 to 8 inches, moistened or dried to near the optimum moisture content, and compacted to 90 percent of the relative compaction. The minimum depth of removal shall be at least 12 inches below the bottom of the proposed footings.

FOUNDATIONS (GENERAL)

1. All footings shall contain a minimum of two No. 4 horizontal rebar; one placed in the base and one in the stem of the footing. The project design engineer shall specify the foundation steel reinforcement.

2. Concrete slab-on-grade floors shall be placed over a subgrade soil conforming to the Grading recommendations of this mitigation measure.
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3. As a minimum, concrete slabs on grade shall be a full 4 inches thick and shall contain No. 3 rebar spaced 24 inches on center each way. The steel reinforcement sha ll be placed near the center of the slab. Concrete slabs on grade shall be doweled into all adjacent footings using No. 3 rebar spaced 24 inches on center. The traditional or conventional subgrade preparation below a concrete slab-on-grade floor is some variation of the following: A minimum 4- inch coarse, washed concrete sand layer is placed over the soil subgrade. A 10- mil or heavier impervious membrane is placed over the sand layer. These concrete slab -on-grade and sand layer recommendations shall be modified and/or eliminated as needed by the designers for surcharge loads, wheel loads, concentrated loads, or for moisture control. The floor covering supplier or manufacturer will be contacted for their specifications for design features, which will result in a successful bond between the concrete slab and floor covering. Floor flatness and shrinkage crack control must be addressed by a competent contractor experienced in the skill of concrete placement. The owners or their agents shall inform those designing, building, and installing the concrete slab on grade and flooring of the performance and aesthetics expected.

4. The licensed geotechnical engineer shall be requested to inspect the footing excavation prior to placement of reinforcing steel and timber form boards.

5. Floor elevations located lower than the surrounding exterior grades are recommended to be protect ed from moisture intrusion.

The project design engineer shall consider installation of features, such as waterproofing and French drains.

FOUNDATIONS (CLUBHOUSE)

1. These recommendations assume the undisturbed native soil will support the proposed footings. If the final graded conditions positions part of the building over the compacted fill soil, extended footings and/or a pile and grade beam foundation may be required over the fill sections. The footing depth below the lowest adjacent grade shall be minimum of 24 inches. The soil encountered at this depth must be firm, non -porous, undisturbed native soil and the footing excavation must penetrate at least 12 inches into the firm soil. An allowable soil bearing value of 2,000 pounds per square foot may be assumed for the 24 inch deep footing described above with a one - third increase for wind or seismic forces.

2. Specification No. 1 shall apply at the basement foundation elevation and at the basement level a 20% increase in allowable soil 156
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bearing is allowed for each additional 6 inches of depth below the lowest adjacent grade, up to maximum allowable soil bearing value of 3,000 pounds per square foot.

3. Isolated piers may be utilized and shall extend a minimum of 24 inches below the lowest adjacent ground surface.

4. If footings are to be located on, adjacent to, or within 10 feet of the top of a slope, these footings shall extend to such a depth so that the horizontal distance between the bottom outside edge of the footing and the face of the adjacent slop e is a minimum distance of 10 feet The slope setback required by the CBC, Figure 1808.7.1, shall also apply.

FOUNDATIONS (COMFORT STATION)

1. These recommendations assume a uniform thickness of
compacted soil will support the proposed footings.

2. Isolated piers may be utilized and shall extend a minimum of 18 inches below compacted ground surface.

3. Based upon compliance with these recommendations, an allowable soil bearing value for compacted soil of 1,500 pounds per square foot for 12-inch-deep footings and 2,000 pounds per square foot for 18 -inch-deep footings, with a one -third increase when considering wind or seismic forces, may be assumed.

FOUNDATIONS (RIO GRANDE COFFEE SHOP)

1. These recommendations assume a uniform thickness of
compacted soil will support the proposed footings.

2. Footings below two-story portions of the structure shall extend 18 inches below compacted ground surface.

3. Isolated piers may be utilized and shall extend a minimum of 18 inches below compacted ground surface.

4. Ba sed upon compliance with the above recommendations, an allowable soil bearing value for compacted soil of 1,300 pounds per square foot for 12-inch-deep footings and 1,500 pounds per square foot for 18 -inch-deep footings, with a one -third increase when considering wind or seismic forces, may be assumed.

PAVEMENT (CLUBHOUSE)
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1. In the areas to be paved, the top loose surface soils shall be removed from below the proposed final soil subgrade elevation, moistened or dried to at or near the optimum moisture con tent, and compacted to 90 percent relative compaction with the top 9 inches being compacted to 95 percent relative compaction where pavement will be subject to vehicle travel or parking. The subgrade area shall be check rolled in order to detect isolated soft spots. Any areas found to be yielding under the wheel loads of the equipment shall be stabilized by removal and compaction.

2. The Class 2 aggregate base shall be recompacted to a minimum of 95 percent relative compaction in accordance with the ASTM D - 1557 test method. Asphalt concrete shall be placed only after the Class 2 aggregate base has been demonstrated to be firm and unyielding.

3. If asphalt pavement is selected for the finished pavement surface, an R-Value of the subgrade soil shall be perfo rmed by a licensed geotechnical professional in order to provide appropriate thickness of Class 2 aggregate base and asphalt concrete.

4. Maintenance to assist in reducing the potential for rapid deterioration of the asphalt paved areas shall include surf ace treatment approximately six months to one year after construction and approximately three years from the first treatment. Pavement conditions shall be reviewed at least once a year for cracks, puddling of surface water, and overall appearance. This rev iew should be done in the fall such that cracks may be repaired which may otherwise allow moisture to pass through the pavement and weaken the subgrade.

5. For concrete slab on grade pavements the slab shall be a minimum of 5.5 inches thick and be placed over a 4 inch thick layer of compacted Class 2 base (at 95 percent relative compaction) and shall be reinforced with No. 3 rebar at 24 inches on center each way and placed at the mid-height of the slab thickness.

PAVEMENT (RIO GRANDE COFFEE SHOP)

1. In t he areas to be paved, the top loose surface soils shall be removed from below the proposed final soil subgrade elevation, moistened or dried to at or near the optimum moisture content, and compacted to 90 percent relative compaction with the top 9 inches being compacted to 95 percent relative compaction where pavement will be subject to vehicle travel or parking. The subgrade area shall be check rolled in order to detect isolated soft spots. Any areas found 158
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to be yielding under the wheel loads of the equipm ent shall be stabilized by removal and compaction.

2. The Class 2 aggregate base shall be recompacted to a minimum of 95 percent relative compaction in accordance with the ASTM D - 1557 test method. Asphalt concrete shall be placed only after the Class 2 a ggregate base has been demonstrated to be firm and unyielding.

3. If asphalt pavement is selected for the finished pavement surface, an R-Value of the subgrade soil shall be performed by a licensed geotechnical professional in order to provide appropriate thickness of Class 2 aggregate base and asphalt concrete.

4. M aintenance to assist in reducing the potential for rapid deterioration of the asphalt paved areas shall include surface treatment approximately six months to one year after construction and approximately three years from the first treatment. Pavement conditions shall be reviewed at least once a year for cracks, puddling of surface water, and overall appearance. This review should be done in the fall such that cracks may be repaired which may otherwise allow moisture to pass through the pavement and weaken the subgrade.

RETAINING WALLS (CLUBHOUSE)
The following retaining wall recommendations assume a single wall on level ground or a slope of less than 25 degrees. If there is more than one retaining wall, creating a multilevel terraced condition, the upper footing must be at a depth that passes below a 50 percent sloping line projected up from the top of the footing of the retaining wall below.

Cantilevered: For cantilevered retaining walls, such as site walls and garden walls, which do not form part of the s tructure, the following shall apply:

1. The cantilevered retaining wall shall be designed assuming an active soil pressure equivalent to a fluid (EFP) whose weight is 35 pounds per cubic foot for level backfill conditions and 52 pounds per cubic foot for backfill slopes, which are constructed at an angle of up to 27 degrees. These values are based on Coulomb’s Equation and the following assumed backfill soil values: internal angle of friction equal to 34 degrees, cohesion equal to 0, and a total unit weight of soil equal to 125 pounds per cubic foot. The EFP value does not include surcharge loads and is based on a free -draining condition. 159
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The free-draining condition must be created by placing the backfill specified in the Preliminary Geotechnical Investigation for Proposed Club House.

2. Retaining walls may be designed using pseudostatic analyses based on a modified Seed Whitman (1970) approach. The need to apply the lateral seismic load is to be determined by the project design engineer or by the building code. The seismic earth force was estimated using the modified Seed Whitman (1970) method, assuming a horizontal peak ground acceleration of 1.142g, and assuming drained backfill conditions. The peak horizontal ground acceleration (PGAm) was determined in a ccordance with Section 1803.5.12 of the 2019 CBC, Paragraph 2.2. The seismic earth resultant force (ΔPae), acting on the stem of the retaining wall, may be estimated as ΔPae = 34.4H2. The resultant force (ΔPae) may be assumed to act at 0.33H above the base of the wall2. Kh = 0.765.

3. The bottom of the retaining wall footing shall extend a minimum distance of 24 inches below the lowest adjacent undisturbed natural grade or 12 inches into firm, undisturbed original ground (whichever is deeper) and shall be designed assuming an allowable soil bearing value of 2,000 pounds per square foot. For footings placed on slopes, the base of the toe or keyway placed at the toe shall extend to such a depth that there exists 10 horizontal feet between the bottom of the footing and the daylight line of the adjacent slope. The key may be placed adjacent to the downhill edge of the retaining wall footing in order to attain the recommended downhill grade footing embedment.

The slope setback required by the CBC, Figure 1808.7.1 , shall also apply.

4. A passive soil pressure equivalent to a fluid whose weight is 350 pounds per cubic foot and a coefficient of friction against sliding of

0.35 may be assumed for the footing excavation described in the recommendation above.

5. The use of equipment to compact soil within the wedge of backfill defined by a 1:1 line projected up from behind the retaining wall to the surface shall be limited to handheld rammer plate compactors, such as a Wacker BS 45Y. A string line shall be placed along the top of the wall to monitor possible rotation of the wall due to the compaction surcharge. If the wall begins to bow or lean away from the backfilling operations, the compaction process shall stop and the licensed geotechnical professional shall be notified immediately such that modified compaction recommendations can be given at that time.
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6. The finish covering on the face of the wall, such as stucco or paint, may be adversely affected by moisture intrusion from the backfill through the back of the wall. To prevent this, the back of the wall and footing shall be waterproofed. All waterproofing and application of waterproofing shall be in accordance with the specifications of the product supplier.

7. Retaining wall backfill shall be a clean, coarse sa nd or gravel wrapped in a filter fabric. The gravel shall be separated from adjacent native soil by a filter fabric. The retaining wall shall be serviced by appropriately placed weep holes or a perforated drain. This drainage feature must include at least 2 cubic feet of gravel wrapped in filter fabric. Lower quality native backfill material may be utilized outside the triangular wedge, which extends upwards from the inside edge of the retaining wall and is a minimum width of 60 percent of the wall height at ground surface. The sand between the wall and native soil shall have a Sand Equivalent of 20 or greater and an Expansion Index equal to 0. To avoid excessive amounts of sand and gravel backfill, the construction contractor is prohibited to cut a vertical excavation 2 to 4 feet beyond the back of the retaining wall footing or stem. Cuts shall only occur to the point needed to install the drainpipe and slope the excavation back as specified.

8. It is assumed that the rough grade excavation behind the retaining wall is to be cut at a temporary slope angle of 1 horizontal to 1 vertical in order to comply with Cal-OSHA safety requirements.

9. All soil backfill shall be compacted to a minimum of 90 percent relative compaction. It should be noted, retaining wal ls designed assuming active soil conditions are anticipated to deflect seasonally.

In addition, surface features which obtain their support from retaining wall backfill materials are anticipated to express differential movement with respect to the retainin g wall as the wall may be resting upon a thinner depth of fill or undisturbed original ground, and the surface features may be resting upon a considerable thickness of compacted fill, which has settlement characteristics differing from that of original gro und. The differential movement between the wall and slab patio may be undesirable. In order to hide or prevent such differential movement, an alternate design may be required, such as, but not limited to, placing a planter between the wall and slab, or connecting the slab to the wall, creating a retaining wall which is pinned at the top, not cantilevered.

Partially Restrained: For restrained or partially restrained retaining walls or cantilevered retaining walls which form a portion of the foundation system of the structure, the wall shall be designed as a 161
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braced wall utilizing at -rest pressures in accordance with the following recommendations:

1. The retaining wall shall be designed assuming an at -rest soil pressure equivalent to a fluid (EFP) whose weigh t is 60 pounds per cubic foot for level backfill conditions and 73 pounds per cubic foot for backfill slopes, which are constructed at an angle of up to 27 degrees. These values are based on the same assumed conditions stated in Recommendation No. 1 under the Cantilevered section.

The at -rest condition for a level backfill is based on the following equation: EFP=Koy where Ko=1 -sin ɸ, y is the total unit weight of soil, and ɸ is the internal angle of friction.

2. The retaining wall footing shall conform to the Foundations recommendations and may be designed assuming an allowable soil bearing value of 2,000 pounds per square foot. For footings placed on or adjacent to slopes, the base of the toe or keyway placed at the toe shall extend to such a depth that th ere exists 10 horizontal feet between the bottom of the footing and the daylight line of the adjacent slope.

3. A passive soil pressure equivalent to a fluid whose weight is 350 pounds per cubic foot and a coefficient of friction against sliding of

0.35 m ay be assumed for the footing excavation described in the recommendation above.

4. The retaining wall shall be serviced by a perforated drain which is located a minimum of 12 inches below top of the adjacent interior concrete slab-on-grade floor.

5. Wall s, foundations, and connections between walls and foundations forming interior finished rooms of the structure shall be waterproofed by the proper application of a moisture barrier. All waterproofing products shall be applied in strict conformance with the manufacturer's recommendations.

6. It is assumed that the rough grade excavation behind the retaining wall is to be cut at a temporary slope angle of 1 horizontal to 1 vertical in order to comply with Cal-OSHA safety requirements.

7. Footings located ne ar the retaining wall stem and in the zone of the granular backfill material shall extend through the retaining wall backfill, shall be supported on the firm underlying undisturbed ground, and below a 1 horizontal to 1 vertical line projected upward from the base of the wall; whichever is deeper. As an alternative, the footing can be designed to span across the backfill area and be 162
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supported by footings able to receive the reaction load of the spanning member. This may include tying into the retaining wall for support, if that portion of the retaining wall has been designed to receive the additional load.

8. Retaining wall backfill shall include 2 cubic feet per linear foot of wall of 3/8- to 1- inch gravel placed around a 4-inch perforated rigid PVC drainpipe. The perforations of the pipe shall be placed down at the positions of 5 and 7 o'clock. A filter fabric shall separate the gravel from the other backfill soils.

9. Retaining wall backfill above the drainpipe shall be a clean, coarse sand or gravel, creating an inverted triangular wedge. Lower quality native backfill material may be utilized outside the triangular wedge which extends upwards from the outside edge of the pipe/gravel at the base of the retaining wall and is a minimum width of 60 percent of the wall height at ground surface. Clean, coarse sand is acceptable when the Sand Equivalent is greater than 20 and the Expansion Index equals 0. To avoid excessive amounts of sand and gravel backfill, do not allow the excavation contractor to cut a vertical excavation 2 to 4 feet beyond the back of the retaining wall footing or stem. Cut only to the point needed to install the drainpipe and slope the excavation back as specified.

10. The use of equipment to compact soil within the wedge of backfill defined by a 1:1 line projected up from behind the retaining wall to the surface shall be limited to handheld rammer plate compactors, such as a Wacker BS 45Y. A string line shall be placed along the top of the wall to monitor possible rotation of the wall due to the compaction surcharge. If the wall begins to bow or lean away from the backfilling operations, the compaction process shall stop and the licensed geotechnical professional shall be notified immediately such that modified compaction recommendations c an be given at that time.

11. The project design engineer designing the retaining wall shall address the following conditions:
a. When a retaining wall is backfilled without a top restraint, such as a wood floor diaphragm, the stem of the retaining wall acts as a cantilever.
b. Depending on the rigidity of the top restraint, the wall may act as a beam spanning between the top and bottom points, reversing the tension side of the stem to the front of the wall 163
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as opposed to the back as in the case of a cantilever
condition.
c. Structure members deflect when loaded. The users guide to the widely used computer program RetainPro recommends the deflection of the wall be checked because the program does not calculate deflection. Refer to Section 9 titled “Related Design Considerations” in the manual titled “Basics of Retaining Wall Design”, Page 50. As an estimate, the Concrete Reinforcing Steel Institute (CRSI) manual estimates concrete reinforced stems of cantilevered retaining walls will deflect a horizontal distance at the top of the wall equal to the height of the wall divided by 240. The appropriate deflection equation and values cor responding to load, condition, and material shall be employed to determine the deflection
corresponding to the lateral loads recommended herein such that appropriate connections, tiebacks, bracing, or
construction joints can be placed within the structural design to properly account for the deflection. The total deflection may not occur during the backfilling operation, but rather sometime after the frame structure is built over and adjacent to the retaining wall.

ADJACENT LOADS (GENERAL)

1. Where footin gs are placed at varying elevations, the effect of adjacent loads will be calculated using the widely published Formulas for Stresses in Semi -infinite Elastic Foundations or the Boussinesq figures and equations for both vertical and horizontal surcharge loads.

SETTLEMENT (GENERAL)

1. It is the intent of the recommendations contained in this report to achieve angular distortions of approximately 1/480. A total settlement of approximately 1 inch or less is anticipated for foundations supported on the undistu rbed native soil and approximately 1 percent to 1.5 percent of the fill height is the anticipated total settlement at areas where compacted fill soil is placed in accordance with the Grading measures provided in this mitigation measure. The soil bearing va lues and estimated settlements contained in this report are preliminary and can be modified after the foundation and grading plans are substantially complete.
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Plan Requirements and Timing . Grading and building plans shall be submitted for review and appro val 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 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 i mplementing the applicable geotechnical recommendations.

2. 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. (Draft EIR, pp. 4.6 -23 through

4.6-25, 6-56.)
Explanation: There are no documented paleontological resources on the project site; however, there have been eight recorded paleontological resources within 1.5 miles of the project site, and seven of these paleontological resources were discovered in the same geologic units as those underlying the project site. Based on the high sensitivities of geologic units underlying the project site and the presence of paleontological resources in proximity to the project site, paleontological resources have a high potential to be present within the project site.

Project-related ground disturbance would extend up to 6 feet below the current ground surface for installation of landscaping and paving; up to 4 feet below the current ground surface within the golf course for utility installation; and up to 25 feet below the current ground surface for construction of the new clubhouse. Although the project site has been subject to previous ground disturbance, the prop osed depths of disturbance necessary for utility and clubhouse construction would likely extend deeper than previously disturbed soils. If intact paleontological resources are discovered on the project site during ground -disturbing activities, such activit ies could potentially destroy such paleontological resources, resulting in a 165
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potentially significant impact. Therefore, mitigation is required.

Implementation of Mitigation Measure GEO-2 would reduce potential impacts to paleontological resources and uniq ue geologic features to a less than significant level by requiring WEAP training, monitoring, and setting forth procedures for the recovery, identification, and curation of fossils discovered during construction. (Draft EIR, pp. 4.6-23 through 4.6-25, 6-56.)
MM GEO-2 Paleontological Resources Impact Plan and Monitoring Prior to the commencement of any grading activities, the project applicant shall retain a qualified professional paleontologist as defined in the Society of Vertebrate Paleontology’s Stan dard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources (2010). The qualified professional paleontologist shall prepare a Paleontological Resources Impact Mitigation Program consistent with the guidance provided in the Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources. The Paleontological Resources Impact Mitigation Program shall be reviewed and approved by the City’s Planning and Environmental Review Director or designee prior to the issuance of a Zoning Clearance for a grading permit. The Paleontological Resources Impact Mitigation Program shall include, but not be limited to, the following:
 Worker Environmental Awareness Program Training. The
qualified professio nal paleontologist shall conduct WEAP training for construction personnel regarding the appearance of fossils and the procedures for notifying paleontological staff should fossils be discovered by construction staff. A basic presentation shall be prepared and presented by the qualified professional paleontologist to inform all construction
personnel working on the project about the paleontological sensitivity of the area. Each worker shall also learn the proper procedures to follow in the event paleontological resources or unique geologic features are uncovered during ground -
disturbing activities. These procedures include halting construction and resource assessment. If new construction personnel are added to the project, the construction
contractor shall ensure the new personnel receive the training before starting work. The qualified professional paleontologist shall ensure construction personnel sign a form affirming they received WEAP training. The qualified professional
paleontologist shall submit this f orm to the Planning and Environmental Review Director or designee.
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 Monitoring. The qualified professional paleontologist shall identify the locations on the project site where paleontological monitoring is required. The qualified professional
paleontologist, or a paleontological resource monitor
designated by the qualifie d professional paleontologist, shall observe initial grading and drilling activities on -site in areas underlain by late Pleistocene marine terrace deposits, the Sisquoc Formation, and the Monterey Formation. No
monitoring is required for ground disturbing activities in areas of artificial fill, subject to the discretion of the qualified professional paleontologist.
 Discovery of Paleontological Resources. In the event that fossils are unearthed during grading, the qualified
professional paleontologist or de signated paleontological resource monitor will temporarily halt and/or divert grading activity within a 50-foot radius of the find to allow for recovery of the resource.
o Fossil Salvage. The qualified professional
paleontologist shall salvage (i.e., excavat e and
recover) the fossil to protect it from
damage/destruction. Bulk matrix sampling may be
necessary to recover small invertebrates or micro
vertebrates from paleontologically sensitive deposits.

After the fossil(s) is (are) salvaged, construction activity may resume.
o Fossil Preparation and Curation. Fossils shall be
identified to the lowest (i.e., most -specific) possible taxonomic level, prepared to a curation -ready
condition, and curated in a scientific institution with a permanent paleontological coll ection along with all
pertinent field notes, photos, maps, and data required
by the curating institution. Fossils of undetermined
significance at the time of collection may also warrant curation at the discretion of the qualified professional paleontologist.
o Final Paleontological Mitigation Report. Upon
completion of ground-disturbing activities (or laboratory preparation and curation of fossils, if necessary), the qualified professional paleontologist shall prepare a
final report describing the results of the paleontological monitoring efforts. The report shall include a summary
of the field and laboratory methods employed; an
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overview of project geology; and, if fossils were
discovered, an analysis of the fossils, including
physical description, taxonomic identification, and
scientific significance. The report shall be submitted to the City’s Planning and Environmental Review Director
or designee and, if fossil curation occurred, the Santa Barbara Museum of Natural History.

Plan Requirements and Timing. The Planning and Environmental Review Director or designee shall approve the Paleontological Resources Impact Mitigation Program prior to the issuance of a Zoning Clearance for a grading permit. The qualified professional paleontologist shall conduct WEAP t raining prior to the start of ground-disturbing activities and submit the signed form to the Planning and Environmental Review Director within 24 hours following the completion of WEAP training. The qualified professional paleontologist or designated paleo ntological resource monitor shall observe initial grading and drilling activities throughout construction on-site in areas underlain by late Pleistocene marine terrace deposits, the Sisquoc Formation, and the Monterey Formation. 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 pr ofessional paleontologist shall also submit the Final Paleontological Mitigation Report to the Santa Barbara Museum 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 completed.

The Planning and Environmental Review Director or designee shall confirm the qualified professional paleontologist or designated paleontological resource monitor observed gradi ng and drilling activities. The Planning and Environmental Review Director or designee shall review and approve the Final Paleontological Mitigation Report, if applicable.

D. HAZARDOUS AND HAZARDOUS MATERIALS

1. Accident or Upset
Threshold: Would the Proje ct create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
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Finding: Less than significant with mitigation incorporated . (Draft EIR, pp. 6- 57 through 6-58.)
Explanation: Alternative 4 would include demolition of the existing clubhouse, portions of the existing maintenance facility, and comfort station, and restoration of the Barnsdall Rio Gas Station, which have the potential to contain ACM, LBP, mercury, and PCB. Alternat ive 4 would result in the same potential impact regarding the release of ACM, LBP, mercury, and PCB from demolition of existing buildings. Alternative 4 would require slightly more ground disturbance than the proposed project and therefore would a small in crease in potential to result in release of hazardous materials. However, the increase would be nominal given the overall scale of construction activities. Grading could potentially disturb hazardous materials in soil, leading to an accidental release of h azardous materials. Construction of Alternative 4 could also encounter perched groundwater which, if contaminated, could result in the accidental release of hazardous materials. In addition, operation of Alternative 4 could result in exposure to volatile o rganic compounds in the soil similar to the proposed project. Mitigation Measures HAZ-1 through HAZ-6 would continue to be required, which would reduce potential hazardous material impacts associated with accidental releases of hazardous materials during demolition of the existing clubhouse, and grading of potentially contaminated soil, soil vapor, or groundwater to a less than significant level. Operation of Alternative 4 would result in the same reduction in fertilizer and pesticide use on the golf course as the proposed project due to the same reduction of irrigated turf.

Accordingly, Alternative 4’s impact related to the accidental release of hazardous materials would be similar compared to the proposed project and would remain less than significant with mitigation incorporated. (Draft EIR, pp. 6-57 through 6-58.)
MM HAZ-1 Asbestos-Containing Materials Abatement
Prior to the issuance of Zoning Clearance associated with the demolition permit, the project applicant shall prepare an asbestos abatement pla n 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 c onstruction 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 asbestos 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 169
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applicant and reviewed by SBCAPCD ten working days prior to starting demolition 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 dispe rsed in accordance with current federal, State, and local regulations. Presumed asbestos containing roofing materials shall 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 mat erials must be properly contained and transported for off -site disposal at a permitted 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 170
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dissemination of asbestos fibers. All required notificat ion and permitting shall be administered by the abatement contractor, and proper completion shall be verified by the 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.

Plan Requirements and Timing . The project applicant shall prepare the asbestos abatement plan, obtain SBCAPCD’s approval, and contract with an abatement contractor prior to the issuance of Zoning Clearance associated with the demolition permit.

Monitoring. The City of Goleta’s Direc tor of Planning and Environmental Review, or designee, shall verify SBCAPCD has approved the asbestos abatement plan prior to the issuance of Zoning Clearance. The City of Goleta’s Director of Planning and Environmental Review, or designee, shall spot -check compliance with the asbestos abatement plan during demolition activities and verify compliance documentation following Alternative 4’s demolition activities.

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. During proposed project construction and demolition activities, the project applicant shall follow the measures outlined in the LBP abatement plan. These requirements shall be undertaken by properly trained contracto rs that utilize lead -safe work practices (or “abatement contractors”).

Abatement contractors shall be selected and vetted by the project applicant and reviewed by the City of Goleta’s Planning and Environmental Review Director. Prior to abatement, the appl icant shall notify CDPH of lead -based abatement activities through submittal of CDPH 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
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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 appropria te 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 compo nents (e.g., windows, doors, baseboards) or similar lead -containing items shall be removed intact and segregated from the overall waste stream by abatement contractors.
 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 lead containing waste. If practica ble, 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.

Plan Requirements and Timing . The project applicant shall prepare the LBP abatement plan, notify CDPH, and contract with an abatement contractor prior to the issuance of Zoning Clearance associated with the demolition permit.

Monitoring. The City of Goleta’s Director of Planning and Environmental Review, or designee, shall approve the LBP abatement plan and verify CDPH has been notified prior to the issuance of Zoning Clearance. The City of Goleta’s Director of Planning and Environmental Review, or designee, shall check the abatement contractor’s monitoring log to ensure project -specific recommendations are enacted during proposed project demolition activities.

MM HAZ-3 Corrective Action Plan/Soil and Groundwater Management Plan Revision
Prior to commencement of grading activities a t the project site, the project applicant shall retain a qualified environmental consultant approved by Santa Barbara County EHS to revise the existing CAP/SGMP prepared for the project site such that the CAP/SGMP 172
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addresses potential contamination in the m aintenance yard, and addresses Santa Barbara County EHS’s comments on the
CAP/SGMP. The revised CAP/SGMP shall address:

1. On-site handling and management of impacted soils or other impacted wastes (e.g., stained soil, and soil or groundwater with solvent or chemical odors) if such soils or impacted materials are encountered;

2. The notification process if an unknown well or leaking well is discovered (e.g., notification of the Santa Barbara County Petroleum Unit, as well as the California Department of Conservation Geologic Energy Management Division); and,

3. Specific actions to reduce hazards to construction workers and off-site receptors during the construction phase.

The CAP/SGMP must establish engineering controls and soil management practices to ensure construction worker safety, ensure the health of future workers and visitors, and prevent the off -site migration of contaminants from Alternative 4. These measures and practices shall include, but are not limited to:
 Stockpile management, including stormwater pol lution prevention and the installation of best management practices.  Proper disposal procedures of contaminated materials.  Investigation procedures for encountering known and
unexpected odorous or visually stained soils, other indications of hydrocarbon pi ping or equipment, and/or debris during ground disturbing activities.
 Monitoring and reporting
 An environmental health and safety plan for contractors working at the project site that addresses the safety and health hazards of each phase of site constructi on activities with the requirements and procedures for employee
protection.
 The environmental health and safety plan shall outline proper soil handling procedures and health and safety requirements to minimize worker and public exposure to hazardous
materials during construction.
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The City of Goleta’s Planning and Environmental Review Director, or designee, shall review the CAP/SGMP and have the authority to propose and include modifications prior to submittal to Santa Barbara County EHS. Santa Barbara County EHS shall review and approve the CAP/SGMP prior to construction (demolition and grading) activities at the project site. The project applicant shall submit proof of Santa Barbara County EHS’s approval of the CAP/SGMP to the City of Goleta’s Planning and Environmental Review Director prior to construction activities. The City of Goleta’s Planning and Environmental Review Director, or designee, shall verify Santa Barbara County EHS’s approval of the CAP/SGMP and shall review the final CAP/SGMP prior to issuance of Zoning Clearance for the grading permit. The project applicant shall implement the CAP/SGMP during demolition, grading, and
construction at the project site.

Plan Requirements and Timing . Prior to commencement of construction and grading activities at the project site, th e project applicant shall retain a qualified environmental consultant approved by Santa Barbara County EHS to revise the existing CAP/SGMP prepared for Alternative 4. The project applicant shall submit proof of Santa Barbara County EHS’ approval of the CAP /SGMP to the City of Goleta’s Planning and Environmental Review Director prior to construction activities. The project applicant shall implement the CAP/SGMP during demolition, grading, and construction at the project site.

Monitoring. The City of Goleta’s Planning and Environmental Review Director, or designee, shall review the CAP/SGMP and have the authority to propose and include modifications prior to submittal to Santa Barbara County EHS. Once Santa Barbara County EHS has reviewed the CAP/SGMP, the Cit y of Goleta’s Planning and Environmental Review Director or designee shall verify Santa Barbara County EHS’ approval of the CAP/SGMP and that Santa Barbara County EHS’s comments on the CAP/SGMP have been appropriately addressed by the qualified environment al consultant.

The City of Goleta’s Planning and Environmental Review Director, or designee, shall review the final CAP/SGMP prior to issuance of Zoning Clearance of construction or grading permits, and shall review project construction plans to ensure app licable recommendations from the CAP/SGMP are integrated into
construction plans.

MM HAZ-4 Sub-slab Vapor Mitigation System
Where soil vapor is known and is identified to be present at chemical 174
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concentrations exceeding regulatory screening thresholds for sub- slab/soil vapor intrusion, the project applicant shall retain a qualified environmental consultant (PG or PE) or other qualified person to prepare a Sub -slab Vapor Mitigation System Design for Alternative

4. The plan shall include, but is not limited to, design specifications, material specifications, installation requirements, and monitoring requirements.

Santa Barbara County EHS shall review and approve the Sub -slab Vapor Mitigation System Design prior to issuance of Zoning Clearance for building pe rmits. The project applicant shall incorporate a sub-slab vapor barrier into the project’s building plans, the implementation of which shall prevent the potential for soil vapor VOCs from migrating to indoor air. The project’s building plans, which shall include engineering measures or institutional controls, shall be submitted by the qualified environmental consultant to the City of Goleta’s Planning and Environmental Review Director, or designee, prior to the issuance of Zoning Clearance for building permits.

Plan Requirements and Timing . The project applicant shall retain a qualified environmental consultant (PG or PE) or other qualified person to prepare a Sub -slab Vapor Mitigation System Design for Alternative 4 prior to construction. The project applicant shall incorporate a sub-slab vapor barrier during construction.

Monitoring. Santa Barbara County EHS shall review and approve the Sub -slab Vapor Mitigation System Design prior to issuance of Zoning Clearance fo r building permits. The qualified environmental consultant shall submit the project’s building plans, which shall include engineering measures or institutional controls, to the City of Goleta’s Planning and Environmental Review Director, or designee, prior to the issuance of Zoning Clearance for building permits.

MM HAZ-5 Groundwater Disposal
If disposal of contaminated groundwater is required during construction of Alternative 4, Santa Barbara County EHS shall be consulted to determine if the treated gr oundwater can be disposed of through one of their waste discharge permit options. Based on the concentrations of chemical constituents of contaminated groundwater, an individual NPDES permit and/or waste discharge requirements may be required to be obtaine d for dewatering activities. If disposal of contaminated groundwater is required, proof of consultation with Santa Barbara County EHS and compliance with Santa Barbara County EHS’s disposal requirements shall be submitted to the City of Goleta’s Planning and Environmental Review 175
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Director.

Plan Requirements and Timing . If dewatering is required, the project applicant shall consult with Santa Barbara County EHS and provide proof of consultation and compliance with EHS’s disposal requirements to the City of Go leta’s Planning and Environmental Review Director prior to the issuance of Zoning Clearance.

Monitoring. If disposal of contaminated groundwater is required, the City of Goleta’s Planning and Environmental Review Director, or designee, shall verify consult ation with Santa Barbara County EHS and compliance with Santa Barbara County EHS’s disposal requirements has occurred prior to the issuance of Zoning Clearance.

MM HAZ-6 Oil Well Access
The property owner shall grant access to all wells located on the project site to any public agency or legal inheritor of the wells for the purposes of inspection, maintenance, service, or re -abandonment such that future remediation or abandonment of existing wells is not impeded by project -related redevelopment. This acc ess shall be maintained in perpetuity and shall not be restricted by any physical or legal barriers resulting from project construction or operation.

Plan Requirements and Timing . Prior to issuance of Zoning Clearance for the grading permit, the project ap plicant shall provide documentation to the City of Goleta’s Planning and Environmental Review Director demonstrating that the property owner has agreed to grant access to all wells on the project site to any public agency or legal inheritor of the wells fo r the purposes of inspection, maintenance, service, or re- abandonment. This documentation shall also reference the indemnification provisions outlined in the Condition of Approval.

Monitoring. The City of Goleta’s Planning and Environmental Review Direct or, or designee, shall verify that the required documentation has been submitted and that it includes provisions for both access and indemnification prior to issuance of Zoning Clearance for the grading permit.

2. 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?
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Finding: Less than significant with mitigation. (Draft EIR, pp. 4.8 -24 through

4.8-25, 6-58.)
Explanation: Construction. Construction of Alternative 4 would occur approximately 80 feet from the Ellwood School due to the extension of the bicycle path beyond the project site’s eastern boundary, which is closer to the school than Alternative 4 . 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. 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 fueling operation and storage.

Construction personnel would be required to h ave the necessary training and/or certifications to operate construction equipment, minimizing the risk of accidental release of hazardous materials due to equipment failure. construction activities would have the potential to create a significant hazard i nvolving the release of ACMs, LBP, mercury, or PCBs into the environment, or through exposure and transport of on-site contaminated soil or groundwater.

Alternative 4’s construction activities would have the potential to create a significant hazard involv ing the release of hazardous materials into the environment, or through exposure and transport of on-site contaminated soil or groundwater, which would be reduced with implementation of Mitigation Measures HAZ -1 through HAZ -6.

Therefore, Alternative 4’s im pact related to handling hazardous materials within 0.25-mile of a school would be less than significant with mitigation incorporated.

Implementation of Mitigation Measures HAZ-1 through HAZ-6 would reduce potential hazardous material impacts associated wi th the handling of hazardous materials within 0.25 -mile of an existing or proposed school during construction to a less -than-significant level. (Draft EIR, pp. 4.8-24 through 4.8-25, 6-58.)

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: Less than significant with mitigation incorporated. (Draft EIR, pp. 4.8- 25 through 4.8-28, 6-59.)
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Explanation: Based on review of the databases maintained pursuant to Government Code Section 65962.5, there are two hazardous materials sites located within the project site: a Santa Barbara County EHS Cle anup Program Site case (#375) for the Sandpiper Golf Club with an “Open – Inactive” status as of June 2, 2023 and a LUST Cleanup Site case (EHS case #51238, Central Coast RWQCB case #213) for the Barnsdall Rio Grande Gas Station with a “Completed – Case Closed” status as of April 24, 1997 (SWRCB 2025a).

According to the 1997 Case Closure Summary available on GeoTracker for the Barnsdall Rio Grande Gas Station LUST Cleanup Site case, soil impacted with TPH -g and VOCs was left in place at the time of case closure (SWRCB 2025a). Based on a review of the applicant-provided documents and documents available on GeoTracker for the Sandpiper Golf Club Cleanup Program Site case, site assessments conducted at the Sandpiper Golf Club since 2002 have identified contamin ants of concern as TPH -g, TPH-d, TPH-o, VOCs, PAHs, and metals in soil and groundwater at the clubhouse and golf course areas of the project site, and VOCs in soil vapor at the clubhouse area of project site (SWRCB 2025a, CGI 2025b).

Construction. Groundwater at the project site is known to be impacted with TPH -g, TPH -d, TPH -o, VOCs, PAHs, and metals.

Although groundwater at the project site has reportedly not been encountered in soil borings advanced as deep as 50 feet (CGI 2025b), there is the pot ential for seasonal perched groundwater to be encountered at shallower depths. Based on the depth of excavation for Alternative 4 (anticipated to be up to 25 feet below ground surface), groundwater may be encountered during
construction activities at the p roject site and would require special handing and/or dewatering.

Additionally, soil at the project site is known to be impacted with TPH- g, TPH-d, TPH-o, VOCs, PAHs, and metals, and soil vapor at the project site is known to be impacted with VOCs. Impacted soil that is planned for export would be hauled off -site for disposal during proposed project construction, which would require special handling or disposal as a waste. Notably, the maintenance yard has not been assessed for hazardous materials contamina tion to date. With the known impacted soil, soil vapor, and groundwater at the project site and the unknown soil, soil vapor, and groundwater conditions in the existing maintenance yard, there is a potential for grading and construction workers to be expos ed to contaminants (e.g., TPH, VOCs, PAHs, and metals) via dust and/or soil, air, and groundwater.

Ground-disturbing activities during proposed project construction 178
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would result in a potentially significant hazard to the public (construction workers on-site) or the environment through exposure to contaminated soil, soil vapor, or groundwater. Therefore, construction impacts would be potentially significant.

A Revised CAP/SGMP was prepared for the project site in 2025 (CGI 2025a). The CAP/SGMP establishes pr otocols and procedures for on-site handling and management of impacted soils and
groundwater, if encountered during proposed project construction activities, and includes a site specific health and safety plan.

However, the CAP/SGMP does not address potential contamination in the maintenance yard, and the exposure to such contamination may cause potentially significant impacts to the public or the environment. Santa Barbara County EHS, which regulates the project site under its Site Mitigation Unit program based on previously reported petroleum-impacted soil, would require a formal CAP for Alternative 4. Once the CAP has been completed, Santa Barbara County EHS would review the CAP/SGMP to ensure it includes all historical and post-remediation assessment data.

Operation. The risk of hazardous materials creating a significant hazard to the public or the environment would primarily occur during construction of Alternative 4 as on-site contamination is disturbed.

However, contamination may remain in place at th e project site during operation. Given that soil vapor at the project site is known to be impacted with VOCs, which could migrate from contaminated soil into indoor air, there is a risk of public exposure to VOCs. Therefore, Alternative 4 would have a potentially significant operational impact involving the creation of a significant hazard to the public or the environment, and engineering controls, such as a vapor barrier, would be necessary.

Implementation of Mitigation Measures HAZ -3 through HAZ -7 prior to and during construction would reduce Alternative 4 ’s impact associated with creation of a significant hazard to the public or the environment to a less -than-significant level. Implementation of Mitigation Measures HAZ -4 and HAZ -7 would reduce potential impacts associated with vapor intrusion during project operation such that impacts involving the creation of a significant hazard to the public or the environment would be less than significant. (Draft EIR, pp. 4.8-25 through 4.8-28, 6-59.)
MM HAZ-7 Regulatory Agency Notification and Oversight Given the project site is listed as an open Santa Barbara County EHS Cleanup Program Site (EHS case #375) and a closed LUST Cleanup 179
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Site (EHS case #51238, Central Coast RWQCB case #213), the EHS case #375, EHS cas e #51238, and Central Coast RWQCB case #213 shall continue to be utilized for agency oversight of assessment and remediation of the project site.

The project applicant shall submit the following documents to the Santa Barbara County EHS project manager of the open Cleanup Program Site case, and the Santa Barbara County EHS and Central Coast RWQCB project managers of the closed LUST Cleanup Site case. The Santa Barbara County EHS project manager and Central Coast RWQCB project manager shall review and appro ve the following documents prior to issuance of Zoning Clearance for the grading permit at the project site:
 Current development plan (e.g., architectural drawings and project description) and any modifications to the development plan
 All environmental a ssessment documents completed for the project site, including the Environmental Impact Report for the Sandpiper Golf Course Renovation and New Clubhouse
Project (this EIR)
 All future hazardous material reports completed for the project site
Upon submittal of the listed information, and in accordance with the regulatory agency’s voluntary oversight agreement, the regulatory agency may require additional actions such as: development of subsurface investigation workplans; completion of additional soil, soil vapor, and/or groundwater subsurface investigations; installation of soil vapor or groundwater monitoring wells; soil excavation and off - site disposal; completion of human health risk assessments; and/or completion of remediation reports or case closure documents.

The project applicant shall retain a qualified environmental consultant (PG or PE) to conduct any required subsurface soil, soil vapor, groundwater investigations, or human health risk assessments in accordance with a sampling plan that shall be reviewed and approved by the regulatory agency. In the event the regulatory agency identifies the need for installation of soil vapor or groundwater monitoring wells to reduce potential hazards to the public or the environment, the project applicant shall ide ntify soil vapor or groundwater monitoring wells on the final project plans for review and approval by the regulatory agency. In the event the regulatory agency identifies the need for soil excavation and off -site 180
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disposal to reduce potential hazards to the public or the environment, the City of Goleta’s Planning and Environmental Review Director, or designee, shall review the final grading plans to ensure soil excavation and off-site disposal are included, and shall approve the final grading plans prior to issuance of Zoning Clearance for the grading permit. If required workplans, investigations, or other mitigation actions require regulatory agency remediation reports or case closure documents, the qualified environmental consultant shall submit these docu ments 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. The project applicant shall also provide proof of Santa Barbara County EHS’s and Ce ntral Coast RWQCB’s approval of the current development plan, environmental assessment documents,
hazardous material reports, and additional workplans, investigations, human health risk assessments, remediation reports, or case closure documents (as applic able) to the City of Goleta’s Planning and Environmental Review Director prior to issuance of Zoning Clearance for the grading permit.

Plan Requirements and Timing . Prior to issuance of Zoning Clearance for the grading permit at the project site, the proj ect applicant shall submit the abovementioned documents to the Santa Barbara County EHS project manager of the open Cleanup Program Site case, and the Santa Barbara County EHS and Central Coast RWQCB project managers of the closed LUST Cleanup Site case.

Prior to issuance of Zoning Clearance for the grading permit, the project applicant shall also retain a qualified environmental consultant to conduct any required subsurface soil, soil vapor, groundwater investigations, or human health risk assessments in accordance with a sampling plan that shall be reviewed and approved by Santa Barbara County EHS or the Central Coast RWQCB.

Monitoring. If required workplans, investigations, or other mitigation actions require regulatory agency remediation reports or case closure documents, the qualified environmental consultant shall submit these documents 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.

E. HYDROLOGY AND WATER QUALITY

1. Water Quality Standards
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Threshold: Would the Project violate any water quality standards or waste discharge requirements?
Finding: Less than significant with mitigation. (Draft EIR, pp. 4.9 -14 through

4.9-19, 6-59.)
Explanation: Construction. Alternative 4 would involve the demolition of the existing clubhouse, portions of the existing maintenance facility, and comfort station. The existing clubhouse and comfort station were constructed in 1971 and have the potential to contain asbestos and lead-based paint. Demolition activities have the potential to release these pollutants into on -site soils, where they could then be transported off -site in stormwater runoff during storm events.

SWRCB’s Construction Stormwater Gener al 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 ad dition, demolition activities would be required to be scheduled when there is a low probability of precipitation. In addition, demolition and construction activities would be required to adhere to the Santa Barbara County Air Pollution Control District reg ulations 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 d uring demolition and exacerbate the existing toxicity impairment in Bell Canyon Creek. Therefore, this impact would be potentially significant, and mitigation is required.

Subsurface investigations were conducted for soils up to the anticipated depths of construction for the comfort station, the clubhouse, and the Barnsdall Rio Grande Gas Station. Subsurface investigations did not encounter groundwater underlying the existing clubhouse, Barnsdall Rio Grande Gas Station, or comfort station.

Although subsurface investigations did not encounter groundwater, water table levels can fluctuate and seasonal perched groundwater8 can exist subsurface. If groundwater or seasonal perched groundwater is encountered during excavation activities, temporary groundwater dew atering during construction may be required.

Depending on the quality of the water, groundwater could be discharged into Devereaux Creek or Bell Canyon Creek.

Groundwater dewatering would be conducted in accordance with Central Coast RWQCB regulations whic h require testing and treatment, as necessary, of groundwater prior to its release into surface waters to prevent exceedances of effluent limitations and discharge flow rates. However, the potential exists that dewatered 182
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groundwater could be contaminated with pollutants such as gasoline, diesel, and motor oil from past oil extraction activities on the project site The extraction of contaminated groundwater could result in an accidental release of hazardous materials into Devereaux Creek or Bell Canyon Creek . The environmental effects of potential contaminated groundwater release would not be adequately minimized through Central Coast RWQCB regulations alone.

Therefore, groundwater dewatering would have the potential to substantially degrade surface water qua lity. This impact would be potentially significant, and mitigation would be required.

Construction would not introduce substantial wastes (i.e., wastewater, pet wastes, wildlife wastes) or introduce livestock or other animals which could substantially incr ease E. coli concentrations in Bell Canyon Creek. In addition, on -site portable toilets would be provided for construction workers, which would also limit the potential for release of E. coli. Therefore, construction would not have the potential to introduce E. coli into Bell Canyon Creek.

Construction activities would require approximately 86,500 cubic yards of soil cut and 56,000 cubic yards of soil fill, with the remaining 30,500 cubic yards used at graded areas of the project site which would occur across the 193-acre project site. Selenium is a naturally occurring element; however, soils on the project site contain minimal amounts of selenium and construction activities would not contribute to the existing selenium impairment in Bell Canyon Creek. Gradi ng operations would increase the potential for erosion and sedimentation and the release of nitrates within the soil. If grading activities occur during the rainy season, or in the event of heavy storms, soils from the site could be entrained, eroded, and transported to Devereaux Creek or Bell Canyon Creek. Construction could correspondingly contribute to existing impairments by reducing dissolved oxygen and increase turbidity in Devereaux Creek or increase nitrate levels in Bell Canyon Creek. In addition, chemicals, liquid products, petroleum products, and concrete-related waste may be spilled or leaked and have the potential to be transported off -site via stormwater runoff.

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 construc tion 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 183
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minimize erosion and retain sediment on -site, and good housekeeping BMPs to r educe 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 pr eparation 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 sedime nt 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 sedi ment control plan are implemented within the SWPPP. Accordingly, the SWPPP prepared for Alternative 4 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, 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 pollutants such as nitrates and toxicity from entering Bell Canyon Creek and contributing to the existing impairments.

Construction of Alternative 4 includes a new golf cart path bridge crossing Devereaux Creek, maintenance of an existing bridge crossing Devereaux Creek, and the removal of an existing culvert, which could temporarily affect water quality, including by increasing turbidity, in Devereaux Creek. The construction contractor would implement construction BMPs and stormwater monitoring consistent with the SWPPP and Chapter 15.09 of the City’s Municipal Code to reduce the potential to introduce sediment and pollutants and degrade water quality in Devereaux Creek. However, construction work inside Devereaux Creek during periods of high flows could result in the degradation of water quality from increased erosion.

Therefore, this impact would be potentially significant, and mitigation is required.

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 le ad-based components are 184
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present in such materials. With implementation of Mitigation Measures HAZ-1 and HAZ-2, potential impacts for asbestos and lead based materials to worsen toxicity in Bell Canyon Creek, introduce toxicity to Devereaux Creek, or substa ntially degrade water quality would be reduced to a less than significant level.

Mitigation Measure HAZ-5 requires proper handling and disposal of any contaminated groundwater encountered during potential groundwater dewatering activities. If contaminated groundwater is generated during construction, the Central Coast RWQCB or the City shall be consulted to determine if the treated groundwater can be disposed of through one of their waste discharge permit options, or if an individual NPDES and/or waste disc harge requirement would be required. The groundwater discharge and disposal requirements vary by agency, location, concentration, and contaminants of concern and would therefore be developed in consultation with the City and/or the Central Coast RWQCB. Wit h implementation of Mitigation Measure HAZ -5, contaminated groundwater would be remediated and disposed of in compliance with Central Coast RWQCB or the City requirements, thereby reducing potential toxicity associated with groundwater dewatering impacts t o a less than significant level.

Mitigation Measure BIO -4 requires construction vehicle equipment maintenance to take place in designated staging areas which are not permitted to be located near any storm drain inlets, drainage swales, or surface waterways , including Devereaux Creek. Implementation of Mitigation Measure HYD -1 above requires culvert removal and bridge installation at Devereaux Creek to occur within the dry season to minimize the potential for construction pollutants to enter water within Dev ereaux Creek and result in increased turbidity or decreased dissolved oxygen. Combined implementation of
Mitigation Measures BIO -4 and HYD -1 would ensure that potential impacts related to degrading water quality due to culvert removal and bridge installation would be reduced to a less than significant level.

Overall, implementation of Mitigation Measures HAZ-1, HAZ-2, HAZ- 5, BIO -4, and HYD -1 would reduce Alternative 4 ’s potential to substantially degrade water quality to a less than significant level. (Draft EIR, pp. 4.9-14 through 4.9-19, 6-59.)
MM HYD-1 Dry Season Construction in Devereaux Creek
Prior to the issuance of Zoning Clearance for the grading permit, the project applicant shall include within the construction contract the requirement that wo rk related to culvert removal, and bridge 185
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installation and maintenance at Devereaux Creek must occur during the dry season (June 1 to October 15) when water flows are low. The construction contractor shall only conduct work related to culvert removal and b ridge installation/maintenance at Devereaux Creek during the dry season.

Plan Requirements and Timing. The construction contract shall be reviewed and approved by the Planning and Environmental Review Director or designee prior to the issuance of Zoning C learance for the grading permit. During construction, the construction contractor shall schedule culvert removal and bridge installation to occur during the dry season. The construction contractor shall provide the Planning and Environmental Review Director with a minimum of a 7- day notice for when culvert removal and bridge installation are scheduled to occur.

Monitoring. The Planning and Environmental Review Director or designee shall visit the site during scheduled culvert removal and bridge installation to confirm such activities are taking place during the dry season.

2. 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 or through the addition of impervious surfaces, in a manner that would 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? Finding: Less than significant with mitigation incorporated. (Draft EIR, pp. 4.9- 22 through 4.9-23, 6-60.)
Explanation: Construction. 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 of Devereaux Creek or Bell Canyon Creek. However, even with adherence to regulator y requirements, construction activities could result in additional sources of polluted runoff related to asbestos, lead-based paints, groundwater dewatering, culvert removal, and bridge installation. This impact would be potentially significant, and mitigation is required.

Implementation of Mitigation Measures HAZ -1 and HAZ -2 require 186
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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 such 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.

Implementation of Mitigation Measure HAZ -5 requires proper handling and disposal of any contaminated groundwater
encountered during potential groundwater dewatering activities. If contaminated groundwater is generated during construction, the Central Coast RWQCB or the City shall be consulted to determine if the treated groundwater can be disposed of through one of their waste discharge permit options, or if an individual NPDES and /or waste discharge requirement would be required. The groundwater discharge and disposal requirements vary by agency, location, concentration, and contaminants of concern and would therefore be developed in consultation with the City and/or the Central Co ast RWQCB. With implementation of Mitigation Measure HAZ -5, contaminated groundwater would be remediated and disposed of in compliance with Central Coast RWQCB or the City requirements, thereby reducing the potential for groundwater to provide substantial sources of polluted runoff to a less than significant level.

Implementation of Mitigation Measure BIO -4 requires construction vehicle equipment and maintenance to occur in designated staging areas which are not permitted to be located near any storm drain inlets, drainage swales, or surface waterways, including Devereaux Creek. Implementation of Mitigation Measure HYD-1 requires culvert removal and bridge installation at Devereaux Creek to occur within the dry season to minimize the potential for construct ion pollutants to enter water within Devereaux Creek. Combined implementation of Mitigation Measures BIO -4 and HYD -1 would ensure that potential impacts related to providing substantial sources of polluted runoff due to culvert removal and bridge installation would be reduced to a less than significant level.

Overall, implementation of Mitigation Measures HAZ-1, HAZ-2, HAZ- 5, BIO -4, and HYD -1 would reduce Alternative 4 ’s potential to introduce substantial additional sources of polluted runoff to a less than significant level. (Draft EIR, pp. 4.9-22 through 4.9-23, 6-60.) 187
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3. 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. (Draft EIR, pp. 4.9 -26 through

4.9-27, 6-60.)
Explanation: Construction and operation of Alternative 4 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 13.0 4 and Chapter 15.09 of the City’s Municipal Code. In accordance with these permits Alternative 4 would be required to implement a SWPPP, construction BMPs, SWQMP, Source Control BMPs, and LID BMPs to reduce the
potential for Alternative 4 to degrade water quality. However, Alternative 4 still has the potential to result in water quality impacts in Devereaux Creek or Bell Canyon Creek during construction related to asbestos, lead-based materials, groundwater dewatering, culvert removal, and bridge installation. These construction activities could result in the introduction of pollutants which could increase the severity of existing impairments in Devereaux Creek and Bell Canyon Creek. Worsening existing impairments could result in pollutants in excess of water quality objective quantities identified in the Basin Plan and/or cause the beneficial uses of Devereaux Creek identified in the Basin Plan to be reduced which would conflict with the Basin Plan. Therefore, construction impacts would be potentially significant, and mitigation is required.

Alternative 4 would include implementation of Mitigation Measures BIO-4, and HYD-1, to reduce potential surface water quality impacts related to culvert removal and bridge installation in Devereaux Creek. Alternative 4 would include implementation of Mitigation Measures HAZ -1 and HAZ -2 in order to reduce potential surface water quality impacts related to the introduction of pollutants associated with the improper handling of asbestos or lead -based materials during demoliti on. Alternative 4 would include implementation of Mitigation Measure HAZ -5, to reduce potential surface water quality impacts related to groundwater dewatering.

With the combined implementation of Mitigation Measures HAZ -1, HAZ-2, HAZ-5, BIO-4, and HYD -1, Alternative 4 would reduce the potential to conflict with or obstruct implementation of a water quality 188
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control plan to a less than significant level. (Draft EIR, pp. 4.9 -26 through 4.9-27, 6-60.)
F. LAND USE AND PLANNING

1. Conflicts With Plans
Threshold: Would the Project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? Finding: Less than significant with mitigation. (Draft EIR, pp. 4.10-6 through

4.10-47, 6-61 through 6-62.)
Explanation: The project site is zoned as Open Space/Active Recreation (City of Goleta 2025). Pursuant to Section 17.12.010(C) of the Goleta Municipal Code, the specific intent of the Open Space/Active Recreation zone is “for existing or planned areas for public parks and active recreational activities and facilities through implementation of the Open Space/Active Recreation land use designation in the General Plan. Individual recreational areas may include a mix of passive and active recreational features or improvemen ts.” As identified in Section 12.12.020 of the Goleta Municipal Code, allowed uses within this zone include community gardens, government buildings, park and recreation facilities, passive open space, and outdoor recreation (with a Conditional Use Permit). As the proposed renovation of the project site would consist of outdoor recreational facilities with associated recreational and support structures, and the project applicant would obtain a Conditional Use Permit, Alternative 4 would thus be permitted in the Open Space/Active Recreation zone.

The golf course’s initial construction was approved by the County of Santa Barbara with building and grading permits. The project site was incorporated as part of the City of Goleta in 2002, which brought the project site under the jurisdiction of City regulations and planning.

Some aspects of the Sandpiper Golf Club are considered legal non- conforming, as they were approved and operated under the previous County’s approval; consequently, while the existing developme nts do not conform to current City codes, they are allowed to continue operating because they were legally established under the regulations in place at the time of their approval. Alternative 4 would require approval of a Development Plan from the City and a Coastal Development Permit from the California Coastal Commission to authorize the proposed improvements and continued use of the golf course and associated facilities. Upon approval of these permits, the 189
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golf course use and related structures would no longer be considered legal non-conforming and would instead be conforming uses under the Goleta Municipal Code. This change would resolve the current non-conforming status and align the project site’s use with the Open Space/Active Recreation zoning designation.

Alternative 4 would meet the development standards of the Open Space/Active Recreation zone, following the approval of a front yard setback Adjustment request. The requested Adjustment would allow eight parking spaces to be located within the front yard setback from the property line along Hollister Avenue.

Alternative 4 would be consistent with applicable Goleta General Plan land use policies adopted for the purpose of avoiding or mitigating an environmental effect, following the implementation o f project-specific mitigation measures.

The entire project site is located within Review Area 2 of the Santa Barbara Airport’s Airport Influence Area, as well as within the FAR Part 77 airspace surface (SBCAG 2023). Height restrictions for development on the project site, as identified by FAR Part 77, range from 361 feet to 411 feet. The maximum height of proposed renovation on the project site is anticipated to be 33 feet from grade.

Accordingly, Alternative 4 would not conflict with the 2023 Santa Barbara County ALUP height restrictions.

The pr oject would require an amendment to GWSD’s Sphere of Influence and approval of an Out of Area Service Agreement to allow sewer service to the clubhouse, Rio Grande Coffee Shop, maintenance facilities, and comfort station. In addition, Alternative 4 includes a request for relinquishment or abandonment of a portion of the public right -of-way along Hollister Avenue. These discretionary actions would not result in physical environmental impacts beyond those already analyzed in this EIR but are subject to review by the Santa Barbara County LAFCO (which would approve the requested changes to GWSD’s Sphere of Influence) and the City of Goleta (which would approve the public right-of-way relinquishment).

Alternative 4 would further Policies OS 2.2 (Planned Vertical Accessways) and OS 2.4 (Mitigation of Impa cts to Vertical Coastal Access) by facilitating lateral pedestrian connectivity along Hollister Avenue that improves public access for all Goleta residents to vertical access points toward the shoreline. The extent of the Class I bike path proposed under Alternative 4 would compensate for the lack of a bluff top lateral access and vertical access by (1) increasing the lateral access along Hollister Avenue that would connect to 190
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multiple vertical access points that allow visitors of the Ellwood Mesa to access the beach and lateral bluff access points located offsite and (2) providing a safe and smooth surface that is wide enough to accommodate two directional flow of walking and alternative modes of transportation to multiple lateral and vertical access points off the project site.

Additionally, Alternative 4 would further Policies VH 3.5 (Pedestrian- Oriented Design), TE 1.1 (Alternative Modes), TE 2.3 (Diversion of Automobile Trips to Alternative Modes), and TE 10.4 (Pedestrian Facilities in New Development) by providing an extended bike path that connects existing pedestrian and bicycle infrastructure instead of a Type 4 path that would only occur along the project site’s northern boundary and would not accommodate alternative modes of transportation, including bicycles. The Type 4 path would only accommodate pedestrian walking. By encouraging greater
alternative modes of transportation, Alternative 4 would better reduce consumption of non-renewable energy sources. Alternative 4 would directly further the City’s Bicycle and Pedestrian Master Plan, which implements the City’s General Plan/Coastal Land Use Plan Transportation Element Policies. One of the goals and objectives of the Bicycle and Pedestrian Master Plan is to provide more active means of transportation (bicycle and walking) in order to reduce greenhouse gas emissions through less vehicle miles traveled as alternative methods are used. In order to meet this objective, the Bicycle and Pedestrian Master Plan id entifies a need for a Class I multi-use pathway along Hollister Avenue from Cathedral Oaks Road to Elderberry Drive, which would directly support Policies TE 10 and TE 11 from the Bicycle and Pedestrian Master Plan, which require pedestrian or bicycle link ages that are safe and convenient for all Goleta residents. Alternative 4 would complete this multi -use pathway and would thus result in consistency with the Bicycle and Pedestrian Master Plan’s goals and policies, whereas the Type 4 path under Alternative 4 does not meet the Bicycle and Pedestrian Master Plan.

Overall, while Alternative 4 would support the City’s policies for active transportation as well as comply with the Bicycle and Pedestrian Master Plan, Alternative 4’s impact would be less th an sign ificant with mitigation.

Mitigation Measures BIO -1 through BIO -11; CUL-1 through CUL -4; HYD-1; NOI -1; TCR -1 and TCR -2; and UTIL -1, would reduce impacts involving conflicts with land use plans, policies, or regulations that were adopted for purposes of redu cing environmental impacts. These mitigation measures would reduce 191
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impacts involving conflict with the Goleta General Plan as they would minimize potential impacts to protected environmental resources within the Goleta General Plan. (Draft EIR, pp. 4.10 -6 through 4.10- 47, 6-61 through 6-62.)
G. NOISE

1. Noise Standards
Threshold: Would the Project result in generation of a substantial temporary 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? (Construction) Finding: Less than significant with mitigation. (Draft EIR, pp. 4.11-11 through

4.11-13, 6-62 through 6-63.)
Explanation: Noise from construction activities at the clubhouse and comfort station would not exceed 65 dBA at the nearest sensitive receptors, and no noise control is needed during construction to reduce noise levels for these receptors. However, noise levels from all oth er improvements (construction activities for golf course improvements, maintenance yard, Rio Grande Coffee Shop/Barnsdall Rio Grande Gas Station, and Hollister Avenue improvements) may exceed Goleta’s 65 dBA standard at the nearest residences to those activities.

Specifically, the extended bike path’s approximate center of each construction area would be within 50 feet of residences on Elderberry Drive and Pebble Beach Drive, compared to 100 feet with the proposed project for Elderberry Drive and 1,600 fee t for Pebble Beach Drive. Additionally, the extended bike path would be within 80 feet of the Ellwood School.

Because construction would occur close to sensitive receptors, short-term noise impacts associated with construction activities for Alternative 4 were analyzed based on typical construction equipment noise levels derived from the Federal Highway Administration’s Roadway Construction Noise Model, and predicted average -daily construction noise levels (in dBA [A -weighted decibel] Leq) were calculated assuming three louder pieces of equipment operating simultaneously with the equipment operating in approximately the center of each construction area to the nearest sensitive receptors (a distance of 50 feet). Heavy-duty construction equipment used for construction of the bike path may require excavators, concrete trucks, dump trucks, pavers, loaders, and rollers. The three loudest 192
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pieces of equipment from this list would be an excavator, loader, and roller. At a distance of 50 feet, these pieces of equipme nt would generate a noise level of 80 dBA. Construction for Alternative 4 would exceed Goleta’s 65 dBA construction noise standards.

Alternative 4 would require implementation of Mitigation Measure NOI-1 to ensure construction noise levels do not exceed Goleta’s 65 dBA construction noise standards. With similar assumptions to Alternative 4 , the use of a temporary noise barrier would reduce construction noise levels by 15 dBA to 65 dBA, which would not exceed Goleta’s 65 dBA standard. Accordingly, Alternativ e 4’s construction noise impact would remain less than significant with mitigation. (Draft EIR, pp. 4.11-11 through 4.11-13, 6-62 through 6-

63.)

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/demolition permit. The Construction Noise Control Plan shall specify the no ise reduction measures to be implemented during project construction that uses heavy-duty equipment within 400 feet of residences, which may include improvements to the golf course (e.g., grading of the course), maintenance yard, Barnsdall area, and Hollis ter Avenue to ensure noise levels do not exceed 65 dBA at nearby sensitive receptors at the nearest residences. The measures specified in the Construction Noise Control Plan shall be included on the building and grading plans and shall be implemented by th e construction contractor during construction. Measures in the Construction Noise Control Plan may include, but would not be limited to, the following:
 Prior to the start of and for the duration of construction, the contractor shall properly maintain and tune all construction equipment in accordance with the manufacturer’s
recommendations to minimize noise emissions.
 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.
 Staging and delivery areas shall be located as far as feasible from existing residences.
 Installation of temporary sound barriers/blankets to break the line of sight between construction equipment and
residences within 400 feet of heavy -duty equipment
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operation. 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.
 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 a bove the ambient near the
operating equipment), or switch off back -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 publi c, 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 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 compliant 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 periodi cally during construction and shall promptly investigate and respond to all noise complaints.

2. Vibration
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Threshold: Would the project generate excessive groundborne vibration or groundborne noise levels?
Finding: Less than significant with mitigation. (Draft EIR, pp. 4.11-17 through

4.11-18, 6-63.)
Explanation: Construction. Construction vibration would also occur on -site near the Barnsdall Rio Grande Gas Station, a historical structure.

Equipment may be used within 15 feet of the building when accounting for equipment setbacks; at a distance of 15 feet, a vibratory roller would generate a vibration level of 0.37 in/sec PPV and a large bulldozer would generate a vibration level of 0.16 in/sec PPV. The equipment would exceed the Caltrans vibration damag e potential threshold for historical structures of 0.12 PPV in/sec for transient sources within a distance of 42 feet and 20 feet, respectively. Therefore, if a vibratory roller, large bulldozer, or similar heavy-duty construction equipment is used within these distances to the Barnsdall Rio Grande Gas Station, building damage could occur from vibration and impacts would be potentially significant from construction vibration.

Alternative equipment near the Barnsdall Rio Grande Gas Station would be used to reduce construction related vibration. Specifically, use of a static roller would generate vibration levels of approximately

0.09 in/sec PPV at a distance of 15 feet (McIver 2012). Grading and earthwork equipment that is limited to 100 horsepower or less would generate 0.006 in/sec PPV within 15 feet of Barnsdall Rio Grande Gas Station. With implementation of Mitigation Measure NOI -2, project groundborne vibration would be less than the significance threshold of 0.08 in/sec PPV at the Barnsdall Rio Grande Gas Station. Therefore, with mitigation, project construction vibration impacts would be less than significant.

Construction of the extended bike path under Alternative 4 woul d move construction equipment closer to residences, with a vibratory roller being potentially used within 30 feet of the residential structures on Elderberry Drive and Pebble Beach Drive. This would equal a vibration level of approximately 0.17 PPV in/sec. at a distance of 30 feet. This vibration level would be well below the Caltrans vibration damage potential threshold for older structures of 0.5 PPV in/sec for transient sources. Therefore, temporary impacts associated with the vibratory roller (and other potential equipment) to off-site residential structures would be less than significant. (Draft EIR, pp. 4.11 -17 through 4.11-18, 6-63.)
MM NOI-2 Construction Vibration Reduction Measures
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Prior to the issuance of Zoning Clearance for grading and buildi ng permit, the City of Goleta Planning and Environmental Review Director or designee shall verify that the construction plans include the following requirements:
 For paving activities within 42 feet of the Barnsdall Rio Grande Gas Station, a static roller shall be used in lieu of a vibratory roller.
 For grading and earthwork activities within 20 feet of the Barnsdall Rio Grande Gas Station, offroad equipment shall be limited to 100 horsepower or less.

Plan Requirements and Timing: The Planning and Environme ntal Review Director or designee shall confirm the requirements are included on the grading and building permits prior to the issuance of Zoning Clearance for grading and building permits.

Monitoring: The City shall monitor compliance with the
requirements of the vibration reduction measure periodically during grading and construction activities within 50 feet of Barnsdall Rio Grande Gas Station.

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: a) 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 b) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Finding: Less than significant with mitigation. (Draft EIR, pp. 4.15 -7 through

4.15-10, 6-65.)
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Explanation: Construction. Although the Tribes did not identify tribal cultural resources within the project site, the presence of the
abovementioned resources indicates a high sensitivity for cultural resources in the area. Moreover, ground d isturbance during project construction could inadvertently encounter and consequently damage or destroy unanticipated cultural resources that may qualify as tribal cultural resources upon evaluation. Such impacts to tribal cultural resources would be poten tially significant. However, implementation of Mitigation Measures TCR-1 and TCR-2, as well as CUL-2 through CUL-4, would reduce potential impacts to a less than significant level. Project impacts involving a substantial adverse change to tribal cultural r esources would be Class II, less than significant with mitigation incorporated.

Mitigation Measures TCR -1 and TCR -2, in conjunction with Mitigation Measures CUL-2 through CUL4, would minimize potential impacts to cultural resources of Native American orig in by requiring Native American monitoring and procedures for 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 signifi cant. (Draft EIR, pp.

4.15-7 through 4.15-10, 6-65.)
MM TCR-1 Native American Monitoring
At least 30 days prior to the commencement of project -related ground-disturbing activities, including, but not limited to, site clearing, grubbing, trenching, and e xcavation, the project applicant shall secure a tribal monitoring agreement with Native American Tribes.

Should more than one of the Tribes wish to provide monitoring for the project, they may do so on a rotating basis to provide equal representation onsite during ground -disturbing activities. The tribal monitoring agreement shall be consistent with the processes and procedures outlined in the Cultural Resource Monitoring and Inadvertent Discovery Plan (Plan) prepared under Mitigation Measure CUL -2, and the project applicant shall submit the tribal monitoring agreement to the City of Goleta’s Planning and Environmental Review Director prior to the commencement of project-related ground -disturbing activities. The Native American monitor(s) shall have the auth ority to temporarily divert, redirect, or halt ground -disturbing activities to allow recovery of cultural resources, in coordination with the qualified archaeologist retained under Mitigation Measure CUL -2. The project applicant shall notify the retained N ative American monitor(s) of scheduled ground disturbance at least five business days in advance. Work may proceed if the retained Native American monitor(s) are unavailable 197
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at the time of ground disturbance. Native American monitoring may be reduced or te rminated in consultation with the project applicant and the City of Goleta’s Planning and Environmental Review Director, or designee, as warranted by conditions such as encountering bedrock, the presence of fill soil, or negative findings during initial gr ound disturbance. The Native American monitor(s) shall maintain monitoring logs throughout project -related ground - disturbing activities and submit the monitoring logs to the City of Goleta’s Planning and Environmental Review Director after each phase of co nstruction (e.g., site clearing, grubbing, trenching) has concluded.

Plan Requirements and Timing . At least 30 days before ground - disturbing activities begin, the project applicant shall secure a tribal monitoring agreement with Native American Tribes. The agreement shall align with the Cultural Resource Monitoring and Inadvertent Discovery Plan from Mitigation Measure CUL-2 and shall be provided to the City of Goleta’s Planning and Environmental Review Director prior to the commencement of project -related ground-disturbing activities. The project applicant shall notify the Native American monitor(s) at least five business days before ground disturbance.

Work can proceed if the Native American monitor(s) are unavailable.

Monitoring. The Native American monit or(s) shall maintain monitoring logs throughout project related ground -disturbing activities and submit the monitoring logs to the City of Goleta’s Planning and Environmental Review Director after each phase of construction has concluded. Monitoring logs shall be kept on file with the City of Goleta’s Planning and Environmental Review Director for the duration of construction.

MM TCR-2 Final Disposition of Unanticipated Tribal Cultural Resources Inadvertent discoveries of archaeological resources found during construction shall be immediately evaluated by the qualified archaeologist (retained under Mitigation Measure CUL -2) for their potential to qualify as tribal cultural resources, and shall be treated in accordance with the Cultural Resource Monitoring and Inadvertent Discovery Plan (Plan) prepared under Mitigation Measure CUL2.

The appropriate treatment method, which may include one or more of the following treatments, shall be determined by th e qualified archaeologist in consultation with the City of Goleta’s Planning and Environmental Review Director, or designee, and the Native American monitor(s). The qualified archaeologist shall provide the data recovery plan prepared pursuant to Mitigatio n Measure CUL-4 to the City of Goleta’s Planning and Environmental Review Director, 198
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or designee, for review and approval prior to initiation of the appropriate treatment.
 Preservation-in-place of the cultural resources, if feasible.

Preservation in place m eans avoiding the resources, leaving them in the place where they were found with no development affecting the integrity of the resources.
 Reburial of the resources in the immediate vicinity of the project site. The measures for reburial may include the following in accordance with the Plan: a) measures and
provisions to protect the future reburial area from any future impacts in perpetuity; b) reburial shall not occur until all legally required cataloging and basic recordation have been
completed, with an exception that sacred items, burial goods, and Native American human remains are excluded; c) any
reburial process shall be culturally appropriate; and d) listing of contents and location of the reburial shall be included in the data recovery plan prepare d pursuant to Mitigation Measure CUL-4.
 If preservation in place or reburial is not feasible, then the resource(s) may be curated in a culturally appropriate manner as described in the Plan prepared pursuant to Mitigation Measure CUL-2 at a Santa Barbara County curation facility that meets the California Office of Historic Preservation Guidelines for the Curation of Archaeological Resources, ensuring access and use pursuant to these guidelines. The collection and associated records shall be transferred, including title, and are to be accompanied by payment of the fees necessary for permanent curation. Evidence of curation in the form of a letter from the curation facility stating that subject archaeological materials have been received and that all fees hav e been paid, shall be provided to the City of Goleta’s Planning and Environmental Review Director by the project applicant. No destructive or invasive testing on sacred items, burial goods, and Native American human remains
shall be permitted. Results conc erning finds of any
inadvertent discoveries shall be included in the data recovery plan prepared pursuant to Mitigation Measure CUL-4.

Plan Requirements and Timing . Inadvertent discoveries of archaeological resources during construction shall be immediatel y evaluated by the qualified archaeologist for their potential to qualify as tribal cultural resources and treated according to the Cultural Resource Monitoring and Inadvertent Discovery Plan from Mitigation 199
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Measure CUL-2. The qualified archaeologist shall provide the data recovery plan prepared pursuant to Mitigation Measure CUL-4 to the City of Goleta’s Planning and Environmental Review Director, or designee, for review and approval prior to initiation of the appropriate treatment.

Monitoring. The City of Goleta’s Planning and Environmental Review Director, or designee, shall consult with the qualified archaeologist and Native American monitor(s)to determine the appropriate treatment process. The City of Goleta’s Planning and Environmental Review Director, or designee, shall also review and approve the data recovery plan prior to initiation of the appropriate treatment. The qualified archaeologist shall submit evidence of completion of the appropriate treatment method, to the City of Goleta’s Planning and Environmental Review Director within 30 days of completion.

I. UTILITIES AND SERVICE SYSTEMS

1. Solid Waste and Solid Waste Laws
Threshold: (i) 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? (ii) Will the Project comply with federal, state, and local statutes and regulations related to solid waste?
Finding: Less than significant with mitigation incorporated. (D raft EIR, pp.

4.16-15 through 4.16-18, 6-66.)
Explanation: Demolition and Construction . Alternative 4 would generate solid waste resulting from the demolition of existing structures and construction of the proposed golf clubhouse, maintenance facility, comfort station, and Rio Grande Coffee Shop. Alternative 4 would involve the demolition of the existing clubhouse (9,305 square feet), maintenance facility structures (5,025 square feet to be demolished), comfort station (290 square feet), and removal of 62,483 square feet of concrete golf cart paths. In addition, Alternative 4 would construct a 37,179 square foot golf clubhouse, 7,106 square foot maintenance facility, 329 square foot comfort station, and 1,044 square foot Rio Grande Coffee Shop, all of which would generate solid waste during construction.

Alternative 4 would result in slightly more solid waste generation than the proposed project due to increased construction activities. 200
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However, the increase would be nominal given the overall demolition and construction activities. Mitigation Measure UTIL -1 would be required to reduce solid waste generated during construction below the City’s project specific threshold of 350 tons of nonrecyclable construction and demolition debris. Once operational, Alternative 4 would result in the same solid waste generation as the proposed project which does not exceed the City’s project-specific threshold of 196 tons per year. Therefore, solid waste impacts related to the operation of Alternative 4 would be similar compared to the proposed project and would remain less than significant with mitigation incorporated. (Draft EIR, pp. 4.16-15 through 4.16-18, 6-66.) MM UTIL-1 Additional Diversion Requirements
Demolition debris generated by removal of the existing concrete golf cart paths shall be recycled at a minimum 98 percent diversion rate.

All other materials (non -concrete materials) shall be recycled at a minimum 65 percent diversion rate. The project applicant’s Waste Management Plan, required in accordance with Chapter 8.10, Article IV of the City’s Municipal Code, shall include a measure that requires the construct ion contractor to recycle all concrete debris from the existing concrete golf cart path removal. The Waste Management Plan shall be submitted to the City Director of Public Works or designee for review and approval prior to the start of construction.

During construction, the City Director of Public Works or designee shall assign a monitor to inspect the project site on a quarterly basis to ensure the requirements of the Waste Management Plan are being implemented. In addition, the project applicant shall re tain proof of 98 percent diversion rate of the demolition waste generated from the concrete golf cart paths via waste tonnage data, supported by original or certified photocopies of receipts and weight tickets on other records of measurement from recycling companies, deconstruction contractors, and/or landfill and disposal companies, and submit these to the City Director of Public Works or designee for review and approval prior to the issuance of a certificate of occupancy.

Plan Requirements and Timing . The project applicant shall prepare and submit the Waste Management Plan to the City Director of Public Works or designee prior to the start of construction. The project applicant shall submit proof of achieving a 98 percent diversion rate of the demolit ion waste generated from the concrete golf cart paths to the City Director of Public Works or designee following the completion of construction. The City Director of Public Works or designee shall review and approve the applicant -provided proof prior to the issuance of a certificate of occupancy. 201
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Monitoring: A monitor chosen by the Director of Public Works Department, or designee, shall inspect the project site on a quarterly basis from the start of construction activities.

SECTION IV.

FINDINGS IMPACTS THAN CANNOT BE FULLY MITIGATED TO A LESS THAN

SIGNIFICANT LEVEL
The City Council hereby finds that there are no significant and unavoidable environmental impacts that cannot be fully mitigated to a less than significant level. As a result, no Statement of Overriding Considerations is warranted.

SECTION V.

CUMULATIVE IMPACTS
Regarding Alternative 4’s potential to result in cumulative impacts, the City hereby finds as follows:

A. AESTHETICS
Cumulative development in the vicinity of the project site could obstruct scenic views or vistas experienced from public viewing areas, as well as result in the overall degradation of visual character. Cumulative development would mostly consist of ground- level improvements or infrastructure removal. However, the City of Goleta Fire Station 10 would occupy 11,600 square feet with a maximum roof height of 32 feet, and would be located directly across Hollister Avenue from the project site. As discussed in the Final Environmental Impact Report for City of Goleta Fir e Station 10, development of the fire station would require tree removal and would alter views along Hollister Avenue (City of Goleta 2018). Cumulative projects, including the fire station, could change views along Hollister Avenue and potentially result in a significant cumulative impact on scenic views experienced from the Hollister Avenue scenic corridor. However, the 4 would improve the quality of views experienced from Hollister Avenue and the overall visual character of the project site, as the Alternative 4 would add vegetative screening by the maintenance yard, restore the aging Barnsdall Rio Grande Gas Station and add visually appealing landscaping, underground the existing power lines, and add native vegetation throughout the golf course. Therefore, Alternative 4 would not result in a considerable contribution to significant cumulative impacts to scenic vistas and visual character.

There are no officially designated State Scenic Highways in Goleta. Thus, there would be no cumulative impacts to sceni c resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway.

Cumulative development would contribute to an increase in light and glare throughout Goleta. However, future projects, including Alternative 4, would be required to implement City lighting regulations, which would minimize the potential for skyglow or light 202
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trespass by requiring lighting fixtures to be designed, located, aimed downward or toward structures (if properly shielded), and retrofitted if feasible. There fore, although several projects listed in Table 3 -1 in Section 3, Environmental Setting of the Draft EIR, would occur in the near vicinity of the project site, implementation of City lighting regulations would ensure that cumu lative impacts involving light and glare would be less than significant. (Draft EIR, pp. 4.1-30 through 4.1-31.)
B. AIR QUALITY
Conflicts with an Air Quality Management Plan and Criteria Air Pollutant Emissions. The planned, pending, and reasonably foreseeable projects within Goleta, at the time of this project, would include the construction of a total of 467 residential units.

Based on the Department of Finance’s 2.59 persons per household in Goleta, the cumulative growth in Goleta would be approximately 1,209 residents. 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 1,209 residents to Goleta would result in a population of 33,800, 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 be less than significant.

Exposure of Sensitive Receptors to Substantial Pollutant Concentrations .

Cumulative impacts in proximity to the project site such as the Annual Pavement Rehabilitation Project and Pavement Management Program adjacent to th e northeast of the project site and Fire Station 10 located north of the project site could expose sensitive receptors to substantial TAC emissions if construction schedules overlapped. Alternative 4’s construction emissions would be short -term, temporary, and cease following the completion of construction. In addition, based on the existing wind patterns at the project site emissions would be carried away from sensitive receptors. Because the winds at the project site would push pollutant concentrations aw ay from sensitive receptors, Alternative 4 ’s emissions would not substantially overlap at the same receptors as cumulative projects. Operation of Alternative 4 would not result in substantial pollutant concentrations. Therefore, Alternative 4’s contribution to cumulative impacts related to exposing receptors to substantial pollutant concentrations would not be considerable.

Odors. 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 construction equipment -related odors; however, the temporary nature of construction would ensure less than significant cumulative odor impacts. In addition, it is likely project odors wo uld not be distinguishable due to vehicle exhaust on Hollister Avenue or United States Route 101. Cumulative projects in proximity to the project site such as the Annual Pavement Rehabilitation Project and Pavement Management Program and Fire Station 10 do not include odor producing facilities that 203
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could result in substantial 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. (Draft EIR, pp. 4.2-16 through 4.2-18.)
C. BIOLOGICAL RESOURCES
The cumulative projects would consist of construction of a total of 467 residential units, 378,670 square feet of industrial space (storage facilities, warehouses, distribution and delivery facilities, and a repurposed hangar building), and 58,690 square feet of commercial space (office space, car dealership facilities, and shopping center improvements). Cumulative projects also include healthcare facility remodeling and expansion, a synagogue and storage building, a church, a fire station, habitat restoration projects within Ellwood Mesa Open Space and Sperling Preserve, three oil and gas infrastructure removal projects, two battery energy storage system projects, and se veral infrastructure improvements.

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 species, riparian habitats, sensitive natural communities, wetlands, and wildlife movement during the course of cumulative project development. Individual development proposals are reviewed separa tely by the City and must undergo environmental review when it is determined that the potential for significant impa cts exists. Cumulative projects would be required to implement mitigation measures, similar to Alternative 4 , if it is determined that signi ficant impacts for individual cumulative projects would occur. Nevertheless, cumulative development may have a potentially significant cumulative impact on biological resources, given the scope of anticipated development. Alternative 4 would include the implementation of mitigation measures that would minimize impacts on biological resources such that Alternative 4’s impacts would be less than significant. Therefore, Alternative 4 would not have a considerable contribution to potential cumulative impacts.

Cumulative development have a potential to conflict with biological resource plans and policies. However, individual cumulative projects would be required to implement mitigation measures, similar to Alternative 4, if it is determined that significant impac ts involving conflict with biological resource plans and policies for individual cumulative projects would occur. 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 regarding 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. (Draft EIR, pp. 4.3-61 through 4.3-62.)
D. CULTURAL RESOURCES
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Cumulative projects would have the potential to adversely impact historical built environment resources. However, the magnitude of impacts for individual projects would depend upon the location, size of development, and proximity to historical built environment resources. Historic resource evaluations would be completed on a case-by- case basis for all future development. Compliance with applicable regulations and implementation of appropriate mitigatio n measures, including resource avoidance measures and noise and vibration reduction measures, would address impacts related to built environment resources associated with cumulative development. Therefore, cumulative development would have a less -than-significant cumulative impact involving substantial adverse changes in the significance of built environment resources.

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 this 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 on a case -by-case basis. Nevertheless, there is potential for significant cumulative impacts to archaeological resources in the City of Goleta given the breadth of cumulative development and the area’s sensitivity for archaeological resources. Alternative 4 has the potential to impact unknown archaeological resources; however, Alternative 4 would be required to implement Mitigation Measures CUL2 through CUL -4, which would require archaeological monitoring, a cultural resources sensitivity meeting for construction personnel, and implementation of appropriate procedures for evaluation and treatment of any discoveries made during construction. With implementation of Mitigation Measures CUL-2 through CUL -4, the project would not have a considerable contribution to significant cumulative impacts to archaeological resources.

Cumulative development projects 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 disturba nce. 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 de velopment would have a less than significant cumulative impact involving the disturbance of human remains. (Draft EIR pp. 4.4 -23 through 4.4-24.)
E. ENERGY
Cumulative development in Goleta would increase demand for energy resources.

However, the California Bui lding 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 205
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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 allow 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 commu ters 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 would promote alte rnative 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 would be less than significant.

Cumulative development, like Alternative 4, would be constructed in accordance with the California Building Energy Efficiency Standards, CALGreen requirements, the City’s EV Reach Code, and the City’s CAP. Cumulative development would receive electricity that is produced in compliance with SB 100, which would promote the use of renewable energy. As a result, cumulative impacts related to conflicts with renewable energy plans would be less than significant. (Draft EIR, pp. 4.5-11 through 4.5-12).

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

Any specific geologic hazards associated with each individual site would be limited to that site without affecting other areas. In 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 throughout 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 a paleontological 206
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resource or unique geologic feature. Therefore, cumulative impacts would be potentially significant. Ground-disturbing activities associated with Alternative 4 have the potential to result in the destruction, damage, or loss of undiscovered scientifically impo rtant 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 Alternative 4 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, Alternative 4 ’s contribution to cumulative impact s related to paleontological resources or unique geologic features would not be considerable with implementation of mitigation. (Draft EIR, pp. 4.6-25 through 4.6-26.) G. GREENHOUSE GAS EMISSIONS
GHG impacts are assessed in a cumulative context since no single project can cause a discernible change to the climate. Therefore, cumulative significance is based on the same thresholds as used for project -level evaluation. In the absence of a City -adopted numeric threshold, the significance of Alternative 4’s GHG emissions is evaluated on the County’s 2.63 MT CO2e per employee 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 GH G 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’s General Plan/Coastal Land Use Plan, and the City of Goleta’s CAP.

Alternative 4 would not exceed the County’s 2.63 MT CO2e per employee per year threshold. Alternative 4 would be consistent with the statewide, regional, and local plans by including energy and water conservation measures, and solar readiness consistent with the latest i teration of CALGreen and the Building Energy Efficiency Standards.

Furthermore, Alternative 4 would not convert natural lands and would contribute to the job and housing balance. Alternative 4 includes 52 bicycle parking spaces to the project site and extension of a Class I bicycle path to promote alternative modes of transportation that would promote GHG emissions reductions from vehicles. Therefore, Alternative 4 would be consistent with the State, regional, and local plans. Thus, based on the CEQA Guidelines for determining the significance of GHG emissions, Alternative 4’s contribution to cumulative GHG impacts would not be considerable. (Draft EIR, pp. 4.7 -16 through

4.7-17.)
H. HAZARDOUS AND HAZARDOUS MATERIALS
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 207
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implementation of appropriate mitig ation measures, including remedial action on contaminated sites, would address impacts related to these hazards and hazardous materials associated with future development in the City. Cumulative impacts related to the creation of a significant hazard to th e 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.

Several cumulative projects are within the Santa Barbara Municipal Airport Influence Area, thereby potentially exposing persons to risk of airport safety hazards.

However, these projects are subject to review of ai rport-related hazards during the environmental review process and by the FAA and ALUC, which would ensure that development does not impose an aviation -related hazard on structures or people.

Therefore, cumulative airport safety impacts would 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 Bar bara County adhere to established protocols. Past, present, and reasonably foreseeable future projects would not impair implementation of or physically interfere with evacuation plans, as projects would be required to maintain clear access routes and ensur e 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.

However, cumulative projects would be required to comply with applicable regulations, such as t he California Public Resources Code, which would reduce the risk of wildfire.

Therefore, cumulative impacts related to wildfire would be less than significant. (Draft EIR, pp. 4.8-31 through 4.8-32.)
I. HYDROLOGY AND WATER QUALITY
The geographic scope for cum ulative impacts related to water quality, drainage, and sedimentation are areas where runoff discharges to Bell Canyon Creek and Devereaux Creek. This geographic scope is appropriate as development in this area could contribute to existing impairments in Bell Canyon Creek and Devereaux 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. The geographic scope for cumulative impacts related to flooding is the Bell Canyon Creek and Devereaux Creek floodplains. This geographic scope is appropriate as cumulative development within these floodplains and floodways can resu lt in increased flooding, including redirection of flood flows, increases in flood boundaries, and increases in flood elevations. 208
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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 d ischarging to the same waters as Alternative 4 (i.e., Bell Canyon Creek and Devereaux Creek). Bell Canyon Creek is impaired by a variety of pollutants, including selenium, nitrate, E. coli, and toxicity.

Devereaux Creek is impaired by dissolved oxygen and turbidity. The Annual Pavement Rehabilitation Project and Pavement Management Program, Viajero Battery Storag e Project, and Fire Station 10 , are examples of cumulative projects that would also potentially discharge stormwater runoff to Bell Canyon Creek and Devereaux Creek and could potentially increase the volume of stormwater runoff 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 q uality 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 Bell Canyon Creek and Devereaux Creek could continue to result in continued impairment of these waterways. Due to the e xisting impairments of Bell Canyon Creek and Devereaux Creek and the potential for cumulative development to discharge pollutants to these waterways, cumulative impacts to water quality, drainage, and sedimentation are significant.

Alternative 4 ’s demoliti on 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 comply with Mitigation Measures HAZ-1 and HAZ-2 to minimize the potential for pollutants associated with asbestos and lead-based materials would enter runoff and degrade water quality. Construction of Alternative 4 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. Water quality impacts associated with culvert removal and bridge installation in Devereaux Creek would be reduced with implementation of Mitigation Measures BIO -4 and HYD -1 which require construction vehicle equipment and maintenance to occur in designated staging areas which are not permitted to be located near any storm drain inlets, drainage swales, or surface waterways and require culvert removal and bridge installation/maintenance in Devereaux Creek to occur during the dry season In addition, if groundwater dewatering is required, groundwater dewatering would occur in compliance with Mitigation Measure HAZ -5 which requires proper handling and disposal of any contaminated groundwater encountered during potential groundwater dewatering activities. During operation, Alternative 4 would comply with Chapter 13.04 of 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 209
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Development. Alternative 4 would implement bioretention basins in accordance with the Preliminary Stormwater Control Plan prepared for Alternative 4 , which serves as the SWQMP for Alternative 4. Compliance with these existing regulations to protect water quality, implementation of Mitigation Measures HAZ -1, HAZ -2, and HAZ -5, and implementation of stormwater control and treatment infrastructure would ensure Alternative 4’s contribution to significant cumulative water quality impacts would not be considerable.

Groundwater. 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 there fore 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 sustainabl e groundwater management would be less than significant.

Flooding. The cumulative study area for flooding and inundation are the Bell Canyon Creek and Devereaux Creek floodplains and floodways. Cumulative development within these floodplains and floodways can result in increased flooding, including redirection of flood flows, increases in flood boundaries, and increases in flood elevations. Cumulative projects listed in Table 3-1 in Section 3, Environmental Setting of the Draft EIR, such as the Ellwood Butterfly Habitat Management Plan Implementation or Annual Pavement Rehabilitation Project and Pavement Management Program may encroach upon these floodplains or floodways but must be designed in accordance with Chapter 15.10 of the City’s Municipal Code which requires the use of flood resistant materials, elevating new construction two feet above base flood elevations, and prohibition of construction within floodways unless a registered professional engineer certifies that construction would not result in any increase in flood levels during the occurrence of the base flood discharged, among other requirements. Cumulative development would be reviewed by the City to verify compliance with all applicable regulations governing development within floodplain. Existi ng City design requirements for development within a floodplain would ensure cumulative development is designed to prevent substantial changes to the floodplain. As a result, cumulative impacts related to flooding would be less than significant. (Draft EIR, pp. 4.9-28 through 4.9-29.) J. LAND USE AND PLANNING
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 210
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projects that include new linear features, such as the planned construction of a new overcrossing over United States Highway 101, would improve connectivity within the city of Goleta. Conflicts regarding compat ibility between past, present, and reasonably 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, 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. There fore, cumulative development would not result in a significant cumulative impact to land use and planning. (Draft EIR, p. 4.10-48.) K. NOISE
Construction noise is localized and rapidly attenuates within an urban environment.

Accordingly, the cumulative impact analysis for noise considers impacts that would occur from the construction and op eration of cumulative projects would occur within 0.1 -mile from the project site. These projects include the following:
 Beach Hazards Removal
 Ellwood Butterfly Habitat Management Plan Implementation  Ellwood Tree Safety Emergency Permit and Ellwood North Restoration  Annual Pavement Rehabilitation Project and Pavement Management Program  Hazardous Fuel Reduction at Ellwood Mesa/Sperling Preserve Open Space  Viajero Battery Storage Project
 Greenbark Battery Energy Storage Project
 City of Goleta Fire Station 10
Some construction activities from the cumulative projects listed above may occur within several hundred feet of the nearest sensitive receptors and therefore may expose these receivers to construction noise simultaneously with construction noise generated from the project site. Theoretically this could result in increased noise exposure to the sensitive receivers from combined noise levels; however, real world conditions wo uld result in less of a cumulative effect through noise direction, angles, attenuation, and dispersion. In addition, cumulative projects would also be required to comply with City of Goleta standards (e.g., restricting construction noise levels to 65 dBA or less). The project would implement Mitigation Measure NOI-1 to reduce project construction noise levels to comply with Goleta’s construction noise thresholds. Therefore, while cumulative construction noise may occur from the project and simultaneous cons truction of another project within several hundred feet, a substantial cumulative construction noise impact 211
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would not occur as in practice this effect would be minimal as previously explained.

Similar to construction noise, construction vibration is localized and rapidly attenuates within an urban environment. Potential vibration from the cumulative projects listed above would occur from a different direction from the nearest sensitive receptor than Alternative 4 and thus approach different angles of the n earest vibration sensitive receivers, thus ensuring the vibration travels further distances before it could theoretically combine with the project’s vibration. As those projects would be constructed at a similar or further distance from the nearest sensitive receiver, their vibration levels would be anticipated to be well below vibration limits as well. While higher vibration levels can occur from activities such as blasting or pile driving, construction that occurs in bedrock areas or involves substantial underground excavation requiring building piles would not be anticipated for the types of cumulative projects proposed nearby. Therefore, the combined vibration level from cumulative projects would still be well below vibration limits, and no cumulative construction vibration impact would occur.

Some cumulative projects listed above would include similar operational noise sources as Alternative 4 (e.g., mechanical equipment noise). Operational noise from these sources is localized and rapidly attenuates due to the effects of distance, intervening structures, and topography that block the line of sight. In addition, other ambient noise sources in c loser proximity to the receptors would dominate the soundscape, effectively masking project -related noise leading to a cumulative increase.

Therefore, the ability of on -site project noise to combine with noise from offsite sources to create a substantial i ncrease 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 Hollister Avenue or Cathedral Oaks Road. The project’s addition to traffic would not result in a noticeable off -site traffic noise increase; thus, the project’s traffic noise increase would not be considerable. (Draft EIR, pp. 4.11- 19 through 4.11-20.)
L. PUBLIC SERVICES
Goleta has a population of approximately 32,515 people. Development of the cumulative projects would add a total of 467 residential units, which would result in an additional 1,209 people based on the city’s average persons per household of 2.59 (DOF 2024). This increase would raise the population of the SBCFD service area to approximately 175,477 people (SBCFD 2025a). With approximately 214 firefighters, SBCFD would provide a ratio of approximately 2.44 firefighters per 2,000 persons within its service population which is above the City goal of one firefighter on duty 24 hours a day for every 2,000 persons. The City has accounted for cumulative growth within the City of Goleta’s General Plan/Coastal Land Use Plan, which inf orms the potential need for expansion of fire services within the City. Pursuant to Chapter 17.70 of the Municipal Code, cumulative development would be required to pay development impact fees which would provide funding for expanded fire protection facili ties to accommodate new residents. In addition, once constructed, Fire Station 10 would reduce potential 212
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constraints associated with increased demands for fire protection service that could be experienced by existing fire stations in Goleta. A Final Enviro nmental Impact Report for Fire Station 10 was prepared and certified by the City Council in December 2018. 1 Fire Station 10 would sufficiently accommodate demand for fire services generated by cumulative growth. Accordingly, cumulative development would not generate demand for fire protection services such that additional facilities would be required. As such, cumulative impacts related to fire protection services and facilities would be less than significant.

Cumulative development would result in additi onal residents, commercial, and industrial development which would increase the demand for police services in Goleta.

Although not required at this time, increased demands may eventually require additional Deputy Service Units, which eventually may result in the need for new or expanded police stations in Goleta. Cumulative development would be required pay development impact fees, which would provide funding for expanded police stations. If the City determines a new or expanded police station would be needed in the future, the potential environmental impacts of developing a police station would be evaluated and mitigated as necessary as part of project-specific environmental review. Because the location, timing, and features of a new police station are not currently known, any environmental impact analysis of a new station would be speculative at this time. However, the required project -specific environmental review would ensure potential environmental impacts of a new or expanded police station are evaluated and mitigated, if necessary. Therefore, cumulative impacts related to police facilities would be less than significant.

The need for school services in Goleta would increase in association with the anticipated population increase from cumulative deve lopment. Cumulative development identified in Table 3 -1 of Section 3, Environmental Setting of the Draft EIR would add a total of 467 residential units, which could result in approximately 93 additional students in GUSD and 93 additional students in SBUSD. GUS D has capacity available for 194 students in Goleta and SBUSD has capacity available for 1,050 students in Goleta.

Therefore, cumulative development would not generate enough students to necessitate the development of new or expanded school facilities. In addition, cumulative development would be required to pay state -mandated developer fees to fund the construction of school facilities to accommodate students generated from new development projects which, pursuant to Section 65995(3)(h) of the California Government Code, is considered full and complete mitigation of potential impacts related to school capacity. Therefore, cumulative impacts to schools would be less than significant.

The demand for library services in Goleta would increase in association wi th the anticipated population increase of 1,209 people from cumulative development. There are currently no specific plans for a new library in the City, and renovations associated with the existing Goleta Valley Library are underway. Development impact mit igation fees assessed on cumulative development would be used to develop additional libraries as needed, subject to City discretion. At the time additional new or expanded library facilities are proposed, these facilities would be subject to project -specific environmental review 213
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and all applicable federal, State, and local regulations that would reduce environmental impacts associated with facility development or expansion. Therefore, required project - specific environmental review for a new or expanded libr ary facility would ensure cumulative impacts related to library facilities would be less than significant. (Draft EIR, pp. 4.13-11 through 4.13-12.)
M. RECREATION
Cumulative development would add a total of 467 residential units, which would increase the demand for parks and recreation in the City. As required by Chapter 16.14 of the Goleta Municipal Code, new residential developments within the City must dedicate

0.0128 acre per dwelling unit to parks and recreation, or pay in-lieu fees toward the future development of such facilities. Thus, cumulative development in the City would generate demand for approximately 6.0 acres of recreational facilities. If parks and recreation facilities are not developed in Goleta, cumulative growth could result in the increased use and deterioration of existing park and recreation facilities. Therefore, cumulative impacts related to parks and recreational facilities would be potentially significant.

Alternative 4 would not directly or indirectly generate population growth bec ause Alternative 4 does not include residential development and proposed utility extensions would serve only the Sandpiper Golf Club. Although Alternative 4 could, in a conservative scenario, result in approximately 55 additional residents in Goleta due to increased employment at Sandpiper Golf Club, Alternative 4 includes development of recreational facilities that would result in increased access to recreational opportunities for residents of Goleta. These include the construction of sidewalks to improve access to Ellwood Mesa Open Space and Sperling Preserve, construction of a Class I bicycle path within Hollister Avenue’s right -of-way, and dedication of lateral access along beach frontage. While Alternative 4’s inclusion of restaurant and coffee shop fac ilities proximate to the project site may result in increased use of nearby parks and trails due to increased access, ultimately these improvements would expand recreational opportunities in Goleta.

Because Alternative 4 would ultimately expand recreation opportunities in Goleta through the inclusion of a Class I bicycle path and dedication of lateral access along beach frontage, Alternative 4’s overall contribution to cumulative impacts related to parks and recreational facilities would not be considerable. (Draft EIR, p. 4.12-7.) N. TRANSPORTATION
Cumulative development in Goleta would be subject to the same circulation-related programs, plans, ordinances, and policies as Alternative 4 . Specifically, cumulative development would be required to demonstrate consistency with the City’s Transportation Element and BPMP, which guide the continued development and improvement of the transportation system in Goleta. In addition, cumulative development would be reviewed by the City and SBCFD to ensure adequate emergency access. However, there are several cumulative projects (i.e., Fire Station 10, Hollister Avenue Complete Streets Corridor Plan, Hollister Avenue Old Town Interim Striping, Holliste r Avenue Class I Bike Path Lighting), that could result in cumulative temporary closures of lanes on Hollister 214
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Avenue during construction. As a result, cumulative development could result in a significant impact to conflicts with transit, roadway, bicycle, and pedestrian facilities, transportation hazards, and delays in emergency access on Hollister Avenue. As a Condition of Approval, the project applicant’s construction contractor would be required to implement a Construction Traffic Management Plan, which requires the project applicant to coordinate with the City to ensure construction activities on Hollister Avenue would not substantially overlap with nearby construction activities, thereby limiting the potential for multiple closures on Hollister Avenue. Accordingly, Alternative 4 would limit the potential for multiple closures on Hollister Avenue due to cumulative development.

Therefore, with implementation of the Construction Traffic Management Plan, Alternative 4’s contributions to cumulative conflicts with transit, roadway, bicycle, and pedestrian facilities, as well as any potential to result in transportation hazards or delays in emergency access on Hollister Avenue, would not be considerable.

Significant cumulative VMT impacts could occur from cumul ative development if cumulative development would raise VMT in the City beyond established thresholds.

Based on technical guidance from the LCI, if a project has a less than significant impact on VMT using an efficiency -based threshold (e.g., VMT per resid ent), the project would not contribute to a cumulative VMT impact (LCI 2018). The City’s screening criteria is analogous to an efficiency -based threshold, and therefore applicable to evaluate cumulative VMT impacts. Alternative 4’s VMT impact would be less than significant based on the City’s screening criteria because the project’s proposed retail development is locally serving, and the reduction in annual rounds of golf would decrease VMT associated with golfers compared to existing conditions. Therefore, Alternative 4 ’s contribution to cumulative VMT impacts would not be considerable. (Draft EIR, pp. 4.14- 14 through 4.14-15.)
O. 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 reasonably foreseeable future developments could cumul atively contribute to the erasure of Chumash tribal cultural resources from the landscape. However, compliance with the provisions of AB 52 would ensure that any known or potential tribal cultural resources are treated in consultation with local Native Ame rican groups. Compliance with AB 52, implementation of project specific measures to protect tribal cultural resources on a case -by-case basis, and continued involvement by local Native American groups in regional planning would generally limit the destruct ion of tribal cultural resources such that cumulative impacts would be less than significant. (Draft EIR, p. 4.15-10.) P. UTILITIES AND SERVICE SYSTEMS
Development of the cumulative projects in Goleta would add a total of 467 residential units, 378,670 square feet of industrial space, and 58,690 square feet of 215
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commercial space, which would increase water demand in Goleta. Using water demand rates for the County’s 2024 Environmental Thresholds and Guidel ines 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 approv ed and constructed, is estimated at approximately 226 AFY. The estimated cumulative water demand of 208 AFY represents approximately 5.0 percent of the 2040 normal year water supply surplus, and approximately 7.8 percent and 9.3 percent of GWD’s dry year o ne and dry year two water supply surpluses, respectively.

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. Pursu ant to the SAFE Water Supplies Ordinance, GWD is permitted allocate a maximum 154.7 acre-feet of water supply allocation to new or additional development in 2025 (GWD 2024b). Cumulative development would be able to utilize GWD’s permitted allocation on a f irst-come-first-serve basis in order to meet water demands associated with cumulative projects. Accordingly, water demand from cumulative development is not anticipated to exceed the GWD’s 2025 maximum permitted allocation of 154.7 AFY to new or additional water services. 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 potab le 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, cumulative development projects must meet one of the requirements to obtain water services which would ensure water supplies would be distributed to cumulative development in a manner which preserves water supply. Therefore, 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 impact on water supply.

Cumulative development in Goleta would also increase wastewater generation.

Consistent with the wastewater generation factors used in the City of Goleta’s 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 146,476 gallons per day of wastewater, or approximately 0.15 MGD. This is a conservative estimate as it assumes residential units would generate 220 gallons of wastewater per unit per day. This wastewater generation represents approximately 5.7 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 wastewater.

Cumulative development would introduce new structures which would requi re installation of stormwater infrastructure. Cumulative projects would be required to comply with the drainage requirements of Chapter 13.04 of the City’s Municipal Code to control and reduce stormwater flows. These requirements would ensure cumulative pr ojects 216
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would not substantially affect existing stormwater drainage system or result in inadequate facilities for the control of stormwater runoff. Therefore, cumulative impacts related to stormwater infrastructure would be less than significant.

Cumulative development would raise the demand for electricity and natural gas in the SCE and SCG service areas. However, SCE and SCG service a majority of southern California, and cumulative development in Goleta is not anticipated to result in substantial energy demand such that new SCE and/or SCG facilities would be required. Therefore, cumulative impacts to 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, there is extensive telecommunications infrastructure available in Goleta to serve cumulative development provided by Verizon, Qwest, AT&T, and Level 3. Therefore, cumulative impacts to telecommunications facilities would be less than significant.

Cumulative development would increase solid waste generation, thereby reducing the capacity of the Tajiguas Landfill and potentially the Kettleman Hills Facility, if contaminated soil disposal is required . According to the County’s 2024 Environmental Thresholds and Guidelines Manual, if solid waste generation exceeds 40 tons per 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 Alternative 4 is estimated to be 349 tons with implementation of Mitigation Measure UTIL- 1, and Alternative 4 ’s operational solid waste is estimated to be 105.5 tons per year.

Therefore, project constru ction and operation would have an adverse, but not considerable contribution to cumulative impacts related to solid waste. (Draft EIR, pp.

4.16-18 through 4.16-20.)

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SECTION VI.

FINDINGS REGARDING SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL

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

Construction of Alternative 4 would require building materials and energy, including non-renewable resources. Consumption of these resources would occur with any development in Goleta and are not unique to Alternative 4. Operation of Alternative 4 would irreversibly increase local dem and for non -renewable energy resources such as natural gas and electricity. Any additional vehicle trips associated with Alternative 4 would incrementally increase local traffic and regional air pollutant and greenhouse gas emissions. However, these impacts would be less than significant.

Development accommodated by Alternative 4 would require an irreversible commitment of fire protection services, law enforcement, water supply, wastewater treatment, and solid waste disposal services; however, these impacts would be less than significant. (Draft EIR, p. 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); 218
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 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 G uidelines provide that growth inducement must not be assumed.

Population Growth. Alternative 4 would not construct new housing or extend roads.

While Alternative 4 would extend utility infrastructure to the new clubhouse, new comfort station, and Rio Grande Coffee Shop, these extensions would serve only Alternative 4.

Accordingly, Alternative 4 would not lead to direct growth due to residential development or indirect growth due to road or infrastructure extensions into undeveloped portions of Goleta. Alternative 4 would result in approximately 21 additional employees, which could cause indirect growth; however, given the size of the city workforce and the relatively small number of jobs being created, these jobs would likely come from the local workforce.

As such, it is not expected that people would relocate to Goleta because of the project.

However, in a conservative scenario where all projected employees and their families were assumed to relocate to Goleta, there would be a population growth of 55 people,1 which would raise Goleta’s population to approximately 32,570 people.2 This population growth would account for approximately 2.5 percent of the total anticipat ed growth in Goleta by 2050. This growth would not exceed the Santa Barbara County Association of Government’s 2050 population forecast of 34,700 (Santa Barbara County Association of Government 2019). Therefore, Alternative 4 would not induce substantial p opulation growth that could lead to substantial adverse environmental effects. (Draft EIR, p. 5.-1.) Economic Growth. Alternative 4 would generate temporary employment opportunities during construction. Based on the size of the project and scale of constru ction, construction workers would be expected to be drawn from the existing regional work force. As such, construction of the project would not be growth-inducing from a temporary employment standpoint. However, Alternative 4 would also provide long -term employment opportunities and generate approximately 21 additional employees in Goleta.

Employment in Goleta is forecasted to increase by 3,860 jobs between 2025 and 2050 (Santa Barbara County Association of Government 2019). The 21 permanent jobs anticipated to be generated by Alternative 4 would be approximately 0.5 percent of the projected job growth between 2025 and 2050, and therefore would be within employment forecasts. These employees would be expected to primarily use existing commercial services in Goleta, creating only a minor need for expanded commercial services. As a result, Alternative 4 would not be expected to induce economic expansion to the extent that substantial environmental impacts associated with Alternative 4 would occur. (Draft EIR, p. 5-2.)
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Removal of Obstacles. Alternative 4 would provide improved recreational facilities and associated amenities on a site that is currently developed with existing recreational uses.

The project site is adjacent to industrial and recreational/open spac e uses to the west; residential uses to the north; and residential and recreational/open space uses to the east.

Alternative 4 would rely on Hollister Avenue and existing connecting roadways (such as United States Highway 101 and Cathedral Oaks Road) for s ite access. No new roads would be required for Alternative 4. The project would utilize existing water, wastewater, and solid waste facilities that serve Goleta. Utility expansion to serve the new clubhouse, comfort station, and Rio Grande Coffee Shop would be limited to just those uses. No additional infrastructure or facilities beyond those necessary to accommodate Alternative 4 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. F or these reasons, implementation of Alternative 4 would not extend infrastructure in a manner that would remove any obstacle to growth. (Draft EIR, p. 5-2.) SECTION VIII.

ALTERNATIVES
A. BACKGROUND
The Draft EIR analyzed four alternatives to the Project as proposed and evaluated these alternatives for their ability to avoid or reduce the Project’s significant environmental effects while also meeting the majority of the Project’s objectives. The City finds that it has 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, which 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 alternat ive to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision -making and public participation. An EIR is not required to consider alternatives which are infeasible. The lead agency is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason.

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

In subsection 15126.6(c), the State CEQA Guidelines describe the selection process for a range of reasonable alternatives:
(c) The range of potential alternatives to Alternative 4 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 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 sufficient informa tion about each alternative to allow meaningful evaluation, analysis, and comparison with Alternative 4. Alternatives are limited to ones that would avoid or substantially lessen any of the significant effects of the Project. Of those alternatives, the EI R 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 (Draft EIR, ES-9) :
 Maintain and improve golf course playability and establish a new golf course routing plan that more closely follows the natural topography of the project site.
 Reduce golf course turf area and replace with native and coastal appropriate landscaping to restore the golf course to a more natural state, thereby reducing water usage and agrichemical application. 221
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 Provide improved recreational and dining facilities for golfers, diners, and special event attendees at the Sandpiper Golf Club.
 Provide enhanced mai ntenance facilities to support Sandpiper Golf Club operations.
 Rehabilitate, preserve, and adaptively reuse the historic Barnsdall Rio Grande Gas Station.
 Protect water quality and bluff stability by converting existing private septic systems to public sewers and utilizing sand-capping to filter stormwater.  Improve public views across the property from Hollister Avenue by undergrounding overhead utility lines and implementing other improvements.
 Improve coastal access for the public in the vicinity of the project site.

C. ALTERNATIVES CONSIDERED BUT REJECTED FROM DETAILED

ANALYSIS
Section 15126.6(c) of the State CEQA Guidelines specifies that an EIR should (1) identify alternatives that were considered by the lead agency but were eliminated from detailed consideration because they were determined to be infeasible during the scoping process; and (2) briefly explain the reasons underlying the lead agency’s determination.

Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives; (ii) infeasibility; and/or (iii) inability to avoid significant environmental impacts.

The following alternatives were considered but rejected as part of the environmental analysis for the Project:
 Alternative location (Draft EIR, pp. 6-2 through 6-3.)  Alternative use (Draft EIR, p. 6-3.)
Finding: The City Council rejects the above alternatives, on the following grounds, each of which individually provides sufficient justificat ion for rejection of this alternative:
(1) the alternatives would likely not further reduce any of Alternative 4 ’s significant impacts; and (2) the alternatives are technically, financially, and legally infeasible given that there are no other properties i n the City or surrounding area that could support renovation similar to Alternative 4, and the project applicant does not own or control any other property within the City that would be suitable for renovation . Additionally, development of the site with more intensive recreational uses could generate greater environmental impacts than Alternative 4 , including those related to an increase in population, vehicle trips and associated emissions, or impervious surface areas. 222
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Therefore, these alternatives are eliminated from further consideration.

D. EVALUATION OF ALTERNATIVES SELECTED FOR ANALYSIS
The alternatives selected for further detailed review within the EIR focus on alternatives that could reduce the Project’s significant environmental impacts, while still meeting most of the basic Project objectives. Those alternatives include:
 Alternative 1: No Project/No Build Alternative (Draft EIR, pp. 6-7 through 6-16)
 Alternative 2: Clubhouse Renovation (Draft EIR, pp. 6-16 through 6-33)  Alternative 3: Revised Site Plan (Draft EIR, pp. 6-33 through 6-49)  Alternative D4: Proposed Project (Draft EIR, pp. 4.1-16 through 4.17-5)

1. Alternative 1: No Project/No Build Alternative
Description: The No Project Alternative assumes that Alternative 4 is not approved and the Sandpiper Golf Club and course is not renovated. The existing project site would be maintained, and golf course operations would continue under existing conditions. The No Project Alternative would not upgrade the existing clubhouse, comfort station, or maintenance yard; would not rehabilitate/adaptively reuse the aging Barnsdall Rio Grande Gas Station; would not reduce the irrigated turf area of the golf course; would not provide lateral access or open space easements; and would not eliminate septic system use. Under the No Project Alternative, the Sphere of Influence request would not be included. (Draft EIR, p. 6-5.) Impacts:
a. Aesthetics
Under the No Project Alternative, the Sandpiper Golf Club would be operated and maintained in the existing condition and would not be renovated. The No Project Alternative would not involve new construction or the addition of structures on the project site that could impact scenic vistas, which would reduce construction impacts when compared to Alternative 4 . However, the No Project Alternative would not include undergrounding of the existing power lines or restoration of the existing Barnsdall Rio Gas Station and therefore would not result in the aesthetic improvements to the project site that would occur as part of Alternative 4 .

Therefore, the No Project Alternative would have no construction impacts on scenic vistas, bu t would not improve the visual quality of the site or community.

Overall, the No Project Alternative would have no impact when compared to existing conditions, but a greater visual impact when compared to Alternative 4, because it would not include the sit e renovation and undergrounding on utilities lines along Hollister Avenue that would be implemented as part of Alternative 4. 223
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