Santa Barbara City Council
July 2, 2024

Actions for reducing organic waste are underpinned by SB 1383 requirements, which lay out specific programs, policies, and objectives for the City to support the state’s goal of a 75% reduction from 2014 levels in organics waste by 2025. While not explicitly modeled, many of these actions support the achievement of SB 1383 goals. Actions that address inorganic waste are not quantified in this analysis due to their very minimal impact on communitywide greenhouse gas emission reduction goals.

Emission reductions in the waste sector are already being implemented due to the new ReSource Center and driven by the City surpassing compliance with SB 1383, which sets a statewide target to reduce organic waste disposal 75 percent relative to 2014 levels and recover 20 percent of edible food by 2025. CalRecycle has provided a suite of activities that jurisdictions are required to complete to achieve this target, including the following:
 Provide organic waste collection services for all residents and businesses and monitor contamination.
 Implement an edible food recovery program for commercial edible food generators, with compliance beginning between 2022 and 2024.
 Procure organic waste to meet organic waste product procurement targets as notified by CalRecycle by 2022.
 Conduct education and outreach to businesses, residents, and commercial ediblefood generators by 2022 and annually thereafter.
 Ensure there is adequate capacity and collection services to comply with SB 1383requirements.  Adopt enforceable ordinances prior to 2022 encompassing requirements for organics and edible food generators in the City.
 Monitor compliance beginning in 2022, conduct enforcement beginning in 2024, and maintain records ofimplementation.

The City is expected to provide the level of composting and food donation that will exceed SB 1383 requirement of organic waste disposal by 75% by 2025. Landfilled organics are a large source of methane emissions and the majority of anerobic waste emissions, as such it is assumed that an 80% reduction in organic waste equates to an 80% reduction in emissions.88 Educational actions such as W-4.2, W-4.3, W-4.4 will not lead to direct GHG emission reductions but they are critical components of the strategy behind SB 1383 implementation. For example, education around composting and food waste reduction can provide the information needed by residents to start a home compost pile and reduce their overall waste. Providing these materials in multiple languages in a culturally appropriate manner will further the impacts of this action.

Action W-4.5 and W-4.17 encompass studies and plans that will not directly impact GHG emissions but will support the City’s goal to reduce all waste generation. Action W-4.6 will directly support implementation of SB 1383, as providing farmers with compost to meet organic procurement target falls within SB 1383’s scope.
88 See:
https://calrecycle.ca.gov/climate/organics/#:~:text=Anaerobic%20decomposition%20of%20organic%20materials,a%2020%2Dyear%20tim e%20period.

Water, Solid Waste, and Wastewater Measures
GHG Emissions Reductions Technical Evidence 55
Action W-4.3 will support SB 1383’s targets by enacting a local ordinance to reduce single use items across the City. Adoption is further encouraged through partnerships with local businesses in Action W-4.2 and W-4.14 promoting reusable items to reduce general waste production.

Additionally, these actions complement Measure CS-2 which is to increase carbon sequestration by applying 0.08 tons of compost per capita annually in the community through 2030 and 2045. See Section 5 Carbon Sequestration.

The methods and assumptions used to calculate the GHG emissions reductions associated with metrics in Measure W-4 are shown in Table 18 below. As mentioned previously, the ReSource Center already began meeting the SB 1383 organic waste diversion obligation in 2021 and Measure W-4 is intended to exceed the compliance obligation. Therefore, the table below presents the amount of GHG reductions achieved with the ReSource Center meeting the compliance obligation and exceedance of the obligation to be achieved with implementation of Measure W-4. The GHG emissions reduction benefits associated with organic diversion were quantified by multiplying the forecasted waste emissions by the target organics diversion rate. This is because organic materials are anaerobically converted into methane and make up 100% of landfill related methane emissions.89 The actual diversion rate will be tracked on an annual basis and if there is a circumstance in which the City doesn’t achieve the incremental targets the CAP will be updated accordingly.

Table 18 GHG Emissions Reductions from Measure W-4
Calculations 2030 2035
Waste Emissions 57,216 59,142
ReSource Center Organic Waste Diversion Compliance
Obligation (%)
75% 75%
Emissions Reduction from continued ReSource Center SB
1383 Compliance
42,912 44,357
Measure W-4 Organic Waste Target Achievement (%) 80% 85% Exceedance of SB 1383 Compliance Obligation (%) 5% 10%
Emissions Reduction from exceedance of SB 1383
Compliance Obligation
2,861 5,914
Total Reductions (MT CO2e) 45,773 50,271
89 US Community Protocol Appendix E – Solid Waste https://icleiusa.org/ghg-protocols/ City of Santa Barbara
Climate Action Plan Update
56 5 Carbon Sequestration
Carbon sequestration describes the process in which plants and water-based algae take carbon from the atmosphere and store it in their biomass via photosynthesis. Plants also release carbon, in the form of carbohydrates and other molecules (collectively called exudates), into the soil through their roots, where they increase soil organic carbon and support a diversity of soil microbes and fungi, which facilitate soil carbon sequestration. Natural lands act as carbon sinks by sequestering carbon from the atmosphere and storing it in vegetation and soils, playing an increasingly important role in pursuing state carbon neutrality goals. Maintaining healthy natural lands is key to human well-being as they are responsible for our water supply and quality, air quality, and biodiversity, which in turn influences socioeconomics and social equity.

Carbon capture involves the capture of GHG emissions from industrial processes, such as steel and cement production, or from the burning of fossil fuels in power generation. This carbon is then transported from where it was produced, via ship or in a pipeline, and stored deep underground in geological formations. The CAP’s carbon sequestration and carbon capture measures are as shown below.

Table 19 Carbon Sequestration Measures
Measure
Number GHG Emissions Reduction Measures
Anticipated Reduction/
Sequestration (MT CO2e)
CS-1 Increase carbon sequestration by maintaining existing trees and natural lands and by planting 4,500 new trees throughout the community by 2030. 2030: 159
2035: 159
CS-2 Explore new carbon sequestration and carbon capture opportunities. Supportive CS-3 Maintain and expand existing restoration projects to sequester carbon through a 25-acre net increase in restored land areas by 2030.

Supportive
CS-4 Increase carbon sequestration by applying 0.08 tons of compost per capita annually in the community through 2030 and 2035.
2030: 1,778
2035: 1,853
CS-5 Reduce GHG emissions of residential and commercial building materials 20% by 2030 and 40% by 2035 in line with AB 2446.

Supportive
Santa Barbara's Parks and Recreation system includes over 1,800 acres of parkland including developed parks, open space, beaches, trails, and sports facilities. The Santa Barbara Parks and Recreation Department has a Creeks Restoration and Water Quality Improvement Division (Creeks Division) which has a mission to improve creek and ocean water quality and restore natural creek systems through storm water and urban runoff pollution reduction, creek restoration, and community education programs. To accomplish this mission, the Creeks Division executes large capital projects to reconstruct creeks and wetlands, returning them to more natural conditions by reshaping the creek channels, removing of aging infrastructure, manage invasive species, and install native plants and trees. These projects have many benefits, including increasing carbon sequestration. The measures and actions in this CAP build off of existing City programs to expand their impact and quantify the carbon sequestration associated with them. Carbon sequestration quantification and tracking is a relatively newer field. However, with the large role carbon sequestration will play in meeting state and the City’s carbon neutrality goals, communities are beginning to take a conservative approach to carbon sequestration quantification as a starting point while the state develops more specific goals and guidance. Passed in 2022, AB 1757 directs the Carbon Sequestration
GHG Emissions Reductions Technical Evidence 57
California Natural Resource Agency to determine carbon sequestration reduction targets by 2024 and develop a methodology to track them by 2025. Once that is completed, the City will integrate those goals and tracking methods within these measures and actions and update them as needed.

Measure CS-1 Increase Carbon Sequestration by Maintaining Existing Trees and Natural Lands and by Planting 4,500 New Trees throughout the Community by 2030 Action
Number
Strategic
Theme Action
Anticipated
Reduction
(MT CO2e)
CS-1.1 Education,
Structural
Change,
Partnerships
Continue to implement and expand the City's Urban Forest Management Plan to include goals for promoting street tree health, enhancing resiliency, increasing the environmentalbenefits and co-benefits resulting from street trees and shading, community engagement around the urban forest. Include activity to promote street tree health and maintaining existing trees through partnerships with the community and localnon-profits.
2030: 159
2035: 159
CS-1.2 Structural
Change,
Feasibility
Studies
Continue to look for opportunities to increase carbon sequestration via land acquisitions and tree protections in alignment with the City's Open Space, Parks and Recreation Element.

Supportive
CS-1.3 Structural
Change,
Foundational
Implement the City’s Community Wildfire Protection Plan to reduce fire risk and carbon loss due to wildfires by conducting vegetation management throughout the City. Ensure that vegetation management projects minimize full removal of vegetation or conversion of land cover type from a higher carbon sequestration land cover (shrubs and trees) to a lower carbon sequestration land cover type (annual grasses).

Supportive
CS-1.4 Feasibility
Study
Develop a City-wide, or participate in a regional, carbon sequestration analysis and plan to explore opportunities to increase sequestration in the City.

Supportive
CS-1.5 Structural
Change,
Equity,
Education
Implement the City of Santa Barbara’s Creek Tree Program to assist private creekside landowners with improving wildlife habitat along creeks in Santa Barbara through the protection and planting of native trees. Develop a wildlife habitat installation program where the City provides carbon sequestering plants and creek trees and removes non-natives as feasible for appropriate creekside properties. Prioritize low-income areas for implementation of the Creek Tree Program and keep an updated publicly accessible page on the City website with important information about the program.

Supportive
CS-1.6 Feasibility
Studies
Update tree canopy coverage data within the City to measure the change in coverage over time as it relates to sequestration as part of the next Urban Forest Management Plan update.

Supportive
CS-1.7 Partnerships Invest and participate in regional development of local carbon off-set program in partnership with the County and/or Central Coast Regional Collaborative.

Supportive
CS-1.8 Equity Prioritize low-income areas of the City with less existing tree canopy for tree plantings and increase shading in gathering spaces.

Supportive
Action CS-1.1 is to continue to implement the City’s Urban Forest Management Plan and expand the goals to capture more co-benefits. The City has a robust urban forest management program that involves a number of City departments including Parks and Recreation, Public Works, Community Development, and Fire. Planting and maintenance of City trees is primarily the responsibility of the Parks and Recreation Department. Other departments such as Fire, Community Development, and Public Works are involved as part of public safety, public capital improvement projects, and land use planning and development. Public review and policymaking related to tree planting, maintenance, and preservation is provided by the Street Tree Advisory Committee, Parks and Recreation City of Santa Barbara
Climate Action Plan Update
58 Commission, Single Family Design Board, Historic Landmarks Commission, Architectural Board of Review, Planning Commission, and City Council. There are also additional planning efforts that support the urban forest management program including the Street Tree Master Plan, Santa Barbara Municipal Code (e.g., Chapter 15 and Chapter 22), the Local Coastal Plan, and the General Plan. Additionally, Action CS-1.2 looks to update the Open Space, Parks and Recreation Element to include policy guidance and support for activities to increase carbon sequestration.

Continued expansion and implementation of the urban forest management program, especially to focus on under-resourced communities, will need strong community partnerships and education.

Action CS-1.5 and CS 1.6, and CS-1.8 look to Identify and partner with local community-based organizations with connections to under-resourced communities to assist with identification of priority planting areas, provide education, and support community tree planting events.

Due to the success of the City’s programs and the additional actions in this measure, City could set a goal of planting and maintaining an additional 4,500 trees by 2030. The City does not currently have a confirmed goal for tree planting past 2030. However, the 4,500 trees planted by 2030 will continue to sequester carbon on an annual basis throughout their lifespan. GHG emission reductions were estimated based on the number of trees to be added to the inventory and the average CO2e accumulation factor per tree (0.0354 MT CO2e/tree/year).90 The calculations and assumptions used to estimate emission reductions from Measure CS-1 are provided in Table 20.

Although there many actions under CS-1 that collectively support substantial increases in carbon sequestration, this analysis conservatively only quantifies carbon sequestration associated with planting trees. As more feasibility studies are done (Actions CS-1.4 and CS-1.6) and more tracking and monitoring are put in place, then the City will have additional substantial evidence to better quantify carbon sequestration reduction potential. Although not quantified here, urban greening can further reduce building carbon emissions by reducing the heat island effect in cities which reduces the need to rely on air conditioning in homes.91 Table 20 Measure CS-1 GHG Emission Reduction Calculations Calculation Factor 2030 2035
Newly Planted Trees (compared to 2019) 4,500 4,500
Tree Sequestration Factor (MT CO2e/tree/year)1 0.0354 0.0354 Total GHG Emissions Reductions (MT CO2e) 159 159
Notes: MT CO2e = metric tons of carbon dioxide; kWh =-kilowatt-hour Values may not add up due to rounding 1 Default annual CO2e sequestration per tree per year with a maximum lifespan of 20 years per tree is 0.0354 MT CO2e/tree/year was obtained from CAPCOA. 2010. Quantifying Greenhouse Gas Mitigation Measures.

Measure CS-2 Explore New Carbon Sequestration and Carbon Capture Opportunities Action
Number
Strategic
Theme Action
Anticipated
Reduction
(MT CO2e)
CS-2.1 Partnerships,
Feasibility
Studies
Create an organizational body (internally within the City or through a partnership like with UCSB or the Santa Barbara Botanical Garden) to lead program development and research for facilitating emergent carbon sequestration and carbon capture plans relevant to the City.

Supportive
90CAPCOA. 2011. Quantifying Greenhouse Gas Mitigation Measures. http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOAQuantification-Report-9-14-Final.pdf 91 The Trust for Public Land (TPL). Quantifying the greenhouse gas benefits of urban parks. August 2008.

Carbon Sequestration
GHG Emissions Reductions Technical Evidence 59
CS-2.2 Education Pilot and promote carbon sequestering construction materials like low-carbon concrete and mass timber.

Supportive
CS-2.3 Education,
Partnerships
Work with local architects, construction trades, and workforce development organizations to expand industry knowledge and adoption of carbon sequestering building materials and techniques.

Supportive
CS-2.4 Feasibility
Studies
Conduct a feasibility study to explore carbon capture and storage opportunities for the community.

Supportive
CS-2.5 Feasibility
Studies,
Partnerships
Initiate a study partnering with local academic institutions and the ReSource Center to identify and research ways to create a circular economy around organic waste and increasing edible food rescue.

Supportive
CS-2.6 Feasibility
Studies
Conduct a feasibility study to explore repurposing biosolids into biochar locally and replacing conventional fertilizer through Public Works.

Supportive
CS-2.7 Partnerships,
Feasibility
Studies
Invest in the existing kelp farming efforts by studying regional environmental impacts and sequestration potential through a partnership with UCSB. .

Supportive
CS-2.8 Partnerships Partner with furniture, home renovation, and construction companies to promote sustainable and locally harvested timber to reduce embodied carbon from transit of construction materials and reduce the price premium of emerging timber uses.

Supportive
CS-2.9 Funding Leverage the grant writer position(s) in strategy A-2.2 to expand funding for the carbon sequestration program.

Supportive
CS-2.10 Equity If there are localized co-benefits to any sequestration projects focus development, when possible, to benefit historically adversely impacted underresourced communities.

Supportive
Measure CS-2 focuses on exploring new carbon sequestration and carbon capture opportunities in the City of Santa Barbara. Over time as GHG emissions are reduced from more and more sectors, carbon sequestration and carbon removal will play an increasingly important role in California’s and the City’s ability to achieve carbon neutrality. The measure includes several actions aimed at facilitating research, partnerships, education, feasibility studies, and funding to identify and develop potential carbon sequestration projects. Actions CS-2.1, CS-2.2, CS-2.3, CS-2.4, and CS-2.6 focus on establishing partnerships with various entities, such as UCSB, the Santa Barbara Botanical Garden, and local academic institutions, to conduct research and development in the field of carbon capture and sequestration. This approach acknowledges that the technology for high levels of carbon capture and sequestration may not be readily available or cost-effective for the City to pursue independently at this time. Actions CS-2.5 and CS-2.7 propose investing in existing local efforts, such as the ReSource center and kelp farms, to expand carbon sequestration opportunities and promote the development of a circular economy. This highlights the City's commitment to utilizing available resources and infrastructure to advance carbon sequestration goals. Action CS-2.9 supports the measure through focusing on funding opportunities specific to carbon capture and sequestration such as through CARB. This demonstrates a proactive approach to seeking financial support for the implementation of carbon capture and sequestration projects. Action CS-2.10 will promote how identified carbon capture and sequestration opportunities bring benefits to the underserved communities. The potential for GHG reduction via carbon capture and carbon sequestration varies drastically depending on the technology and methods used for carbon capture and sequestration.

Therefore, until the technology or means for carbon capture is identified, the measure remains supportive and will not be quantified until adequate data is available from an implementable project.

City of Santa Barbara
Climate Action Plan Update
60 Measure CS-3 Maintain and Expand Existing Restoration Projects to Sequester Carbon through a 25-acre Net Increase in Restored Land Areas by 2030 Action
Number
Strategic
Theme Action
Anticipated
Reduction
(MT CO2e)
CS-3.1 Structural
Change,
Partnerships,
Equity,
Education
Develop a Citywide restoration plan in partnership with the Creeks Division, Parks and Recreation, and Public Works to achieve target net increases in restored land area and waterways. Prioritize implementation of restoration projects in disadvantaged communities. Facilitate community outreach through surveys and public meetings on ways to best restore lands and waterways within the City as well as identify additional priority areas.

Supportive
CS-3.2 Structural
Change,
Equity
Should parcels be identified for potential rezoning from their existing state to a park or open space, consider the following:
1) Provide flexible solutions for developing urban parks in infill areas where traditional neighborhood and community parks are not feasible; 2) Aim to achieve the greatest carbon sequestration possible, given constraints around use and amenities to be included. Use and amenities are determined by Parks and Recreation staff through a community process; and 3) Selection of parcels be made with an aim to serve underserved communities.

Supportive
CS-3.3 Partnerships Expand Creeks Division volunteering programs to help maintain creek restoration projects. Coordinate projects with Parks and Recreation and Sustainability and Resilience Departments.

Supportive
CS-3.4 Structural
Change,
Feasibility
Studies,
Education
Facilitate annual reporting as part of the urban forestry, wildfire prevention, and City-wide restoration efforts by developing and maintaining existing projects to gauge progress over time and identify any gaps related to ongoing projects.

Incorporate GHG reduction calculations into this monitoring plan.

Supportive
CS-3.5 Funding,
Foundational
Leverage the grant writer position(s) in strategy A-2.2 to pursue funding for restoration activities with a focus on projects that have not reached completion due to funding constraints.

Supportive
CS-3.6 Structural
Change,
Foundational
Include long term maintenance in restoration planning and implementation by partnering with the community and local organizations to assist in maintenance activities. Include continued maintenance and expansion of Creeks Division projects of the Upper Las Positas Creek, Mission Creek, Palermo Open Space, Arroyo Burro, and the Andree Clark Bird Refuge.

Supportive
Measure CS-3 includes actions to facilitate and track City-led restoration efforts that will help to increase carbon sequestration. Implementing and tracking restoration efforts that increase carbon sequestration will be critical for the City to meet its 2035 carbon neutrality goal. Action CS-3.1 includes a restoration plan that will provide goals, targets, and actions to facilitate restoration throughout the city. Actions CS-3.3, CS-3.5, and CS-3.6 develop volunteer programs, partnerships, and grant funding positions(s) to help implement CS-3.1. CS-3.4 will create a reporting program to showcase the City’s progress and monitor GHG sequestration. As the goals and targets for carbon sequestration associated with restorations have yet to be developed, the measure is not yet quantified.

Carbon Sequestration
GHG Emissions Reductions Technical Evidence 61
Measure CS-4 Increase Carbon Sequestration by Applying 0.08 tons of Compost per Capita Annually in the Community through 2030 and 2035
Action
Number
Strategic
Theme Action
Anticipated
Reduction
(MT CO2e)
CS-4.1 Structural
Change
Enforce compliance with SB 1383 and aim to exceed the baseline requirement by establishing a minimum level of compost application per year on applicable/appropriate land throughout the City including City-owned land twice that of SB 1383 requirements.
2030: 1,778
2035: 1,853
CS-4.2 Feasibility
Studies
Identify additional locations within the City to apply compost and provide household incentives for small-scale implementation.

Supportive
CS-4.3 Structural
Change
Maintain procurement policies to comply with SB 1383 requirements for jurisdictions to purchase recovered organic waste products.

Supportive
CS-4.4 Partnerships,
Education
Work with the ReSource Center to provide residents, businesses, and developers with educational material on where compost can be acquired and how it can be used (i.e., landscaping).

Supportive
CS-4.5 Partnerships Collaborate with Santa Barbara Community College, UC Santa Barbara, local schools, and Public Works to identify opportunities to apply compost to landscaping.

Supportive
Compost is also discussed under Measure W-4 because compost application is part of the overall waste management process and is a requirement under SB 1383. The City surpassed compliance with SB 1383, which sets a statewide target to reduce organic waste disposal 75 percent relative to 2014 levels and recover 20 percent of edible food by 2025. CalRecycle has provided a suite of activities that jurisdictions are required to complete to achieve this target, which includes waste product procurement targets.

The ReSource Center began meeting the SB 1383 procurement obligation in 2021. Measure CS-4 is intended to ensure the City continues to meet the procurement obligation in the future. Actions CS4.1 through CS-4.5 build upon existing City programs but provide additional support to identify application gaps (Action CS-4.2), improve processes (CS-4.3), provide education (Action CS-4.4) and develop additional partnerships (Action CS-4.5). Emission reductions associated with procurement of 0.08 tons of recovered organic waste products, such as compost, per person are demonstrated in Table 21 below.

Table 21 GHG Emissions Reductions from Measure CS-4
Inputs and Assumptions
City procurement requirement in 2021 (tons)1 7,444
City population that procurement is requirement based on1 93,055 Procurement requirement per capita 0.0800
Emission reduction factor associated with mixed organics compost application due to avoided landfill emissions, decreased soil erosion, decreased fertilizer use (MT CO2e/ton)2

0.23 Calculations 2030 2035
Population 96,637 100,713
Estimated procurement requirement (tons) 7,731 8,057
City Recovered Organic Waste Product Procurement Obligation (%) 100% 100% Measure CS-4 Procurement Target (%) 100% 100%
City of Santa Barbara
Climate Action Plan Update
62 Emissions Reduction from Continued ReSource Center SB 1383 Compliance of Procurement Requirements (MT CO2e)3
1,778 1,853
1 https://calrecycle.ca.gov/organics/slcp/procurement/recoveredorganicwasteproducts/ 2 https://ww2.arb.ca.gov/sites/default/files/classic/cc/waste/cerffinal.pdf .3These emissions are also associated with the implementation of Measure CS-2. To review the actions that will implement Measure CS-2 are discussed in Section 5 Carbon Sequestration.

Measure CS-5 Reduce GHG Emissions of Residential and Commercial Building Materials 20% by 2030 and 40% by 2035 in Line with AB 2446 Action
Number
Strategic
Theme Action
Anticipated
Reduction
(MT CO2e)
CS-5.1 Feasibility
Studies
Conduct a feasibility study on carbon capture technologies to locally produce calcium carbonate (low carbon concrete) creating sequestration via construction materials. Determine viability within the City and project demand.

Supportive
CS-5.2 Partnerships,
Feasibility
Studies
Partner with UCSB to pilot a building specific embodied carbon reduction project for planned construction.

Supportive
CS-5.3 Moonshot Develop a strategic construction and procurement plan to promote construction projects that use alternative materials to reduce embodied carbon. Include scoring criteria in City request for proposals for construction projects that identify resilience features such as water and energy efficiency, reduced urban heat, and decrease the embodied carbon in line with AB 2446.

Supportive
AB 2446, adopted in 2022, requires CARB to develop a strategy for achieving a 40 percent net reduction in the embodied carbon in building materials by end of 2035.92 As part of this bill, CARB is also tasked with developing a framework for measuring and tracking the reduction in building material carbon intensity by 2025. Measure CS-5 supports the state’s efforts to reduce embodied carbon emissions in construction materials and prepares the City for legislation related to building materials that may be passed in the coming years. Under Action CS-5.1 the City will conduct a feasibility study to evaluate the viability of products like low carbon concrete and carbon sequestering concrete. Concrete is one of the most extensively used materials in buildings and traditional manufacturing of concrete is a carbon intense process.93 There are a number of emerging technologies that reduce the emissions from concrete production as well as technologies for using concrete as a means to sequester carbon emissions.94 Understanding the feasibility of other building materials is the first step to development a strategy to reduce embodied emissions in building materials. Through Action CS-5.2 the City will develop a partnership with UCSB to pilot a project focused on reducing embodied carbon in building construction. This collaborative effort aims to explore and implement strategies to minimize the carbon footprint associated with planned construction projects. By leveraging the expertise of UCSB, the City, can benefit from cutting-edge research and innovative approaches to reduce GHG emissions in the building environment. Action CS-5.3 is a moonshot effort by the City that would involve the development of a strategic construction and procurement plan to promote of alternative materials with lower embodied 92 2022 - Assembly Bill 2446 (Holden, Chris), Embodied Carbon Emissions: Construction Materials (Chaptered) | California Air Resources Board
93 Jeremy Gregory, Hessam Azarijafaris, Ehsan Vahidi, and Randolph Kirchain. September 2021. The role of concrete in life cycle greenhouse gas emissions of US buildings and pavements. PNAS Vol. 118 No. 37. Accessed Here:
https://www.pnas.org/doi/full/10.1073/pnas.2021936118 94 CarbonCure's Sustainable Concrete Solution - Concrete Technology Reducing Carbon Impact Carbon Sequestration
GHG Emissions Reductions Technical Evidence 63
carbon and construction designs that increases climate resiliency. At this time the Measure is supportive to the overall efforts of the City but is not quantifiable since lifecycle emissions are not quantified in the overall GHG inventory.

City of Santa Barbara
Climate Action Plan Update
64 6 Community Climate Potential
Any increase in government and private sector spending related to the CAP and associated greenhouse gas reduction measures will generate economic activity, resulting in changes to employment. To meet the City’s goals in the CAP, the City will need to help transform its economy into one that supports a zero-carbon future and moves toward energy efficiency. This greener economy will involve an increasing number of sectors with lower carbon outputs and decreased environmental impacts. Early studies show that there will be some economic decline in certain industries and limited job losses; however, the overall economic impact is expected to be net positive. For this reason, it is important that the City needs to address equity explicitly in the green transition. Ensuring equitable outcomes result from transformative climate investments is critical.

Measure CP-1 outlines the City’s plan to integrate innovation and equity into the green economy.

Measure CP-1 Encourage Community Innovation and Empower the Local Green Economy through Investment in a Green Technology Workforce Action
Number
Strategic
Theme Action
Anticipated
Reduction
(MT CO2e)
CP-1.1 Structural
Change
Create a Green Technology incubator in partnership with UCSB to determine technological advancement research into clean power, built environment advancement, and carbon sequestration.

Supportive
CP-1.2 Funding Leverage the grant writer position(s) in strategy A-2.2 to source funding for the Green Technology incubator through involvement of venture capitalist and private equity firms.

Supportive
CP-1.3 Education Facilitate workforce training by partnering with local academic institutions to offer scholarships for students pursuing climate trades.

Supportive
CP-1.4 Education Partner with Santa Barbara Community College and/or UCSB to develop a clean energy technology certificate program.

Supportive
CP-1.5 Moonshot Leverage the grant writer position(s) in strategy A-2.2 to establish an Innovation Bootcamp with funding from SBCE to encourage forward thinking sustainability and resilience ideas and pilots. The Innovation Bootcamp will be tiered based on stages.

Supportive
CP-1.6 Moonshot Create a climate innovation competition for local area students where the prize is a scholarship or grant.

Supportive
Green jobs are broadly defined as occupations that include tasks associated with meeting green economic goals and improving the environment. This could be jobs in businesses that produce goods or provide services that conserve natural resources or reduce the environmental impact of production processes. Green goods, services, and production processes typically fall into the following categories of economic activity: renewable energy; energy efficiency; greenhouse gas reduction; pollution reduction and cleanup; recycling and waste reduction; natural resources conservation; and education, compliance, public awareness and training.

Green jobs may include, but are not limited to, the following:
 Clean renewable energy
 Public transportation
 Waste management/recycling
Community Climate Potential
GHG Emissions Reductions Technical Evidence 65
 Eco-tourism
 Sustainable agriculture
 Land conservation/remediation
 Construction/Building remediation
These measures and actions in the CAP will increase spending on projects that are expected to increase employment in these jobs. While increased jobs are generally viewed as a positive impact, Measure CP-1 contains actions to ensure equitable outcomes of this job creation, such as implementing retraining programs and outreach for underrepresented communities. Actions CP-1.1 and CP-1.2 will create a Green Technology incubator to understand how anticipated growth— particularly ones spurred by transformative climate investments—can create employment opportunities that connect with historically underrepresented, under-served and under-resourced members of the community.

Actions CP-1.3, CP-1.4, CP-1.5, and CP-1.6 work together to facilitate the training and help the development of a local green workforce. Workforce development ensures and expands employability by aligning skills of employees with business needs and labor market trends. These workforce development initiatives need to be holistic and take form multiple ways which is why the City has actions to include apprenticeship programs, targeted development programs, and funding incentives. Coordination among business and education communities, labor and trade groups as well as the local and regional governments will ensure sound delivery of workforce development initiatives. Being proactive in developing a green workforce is particularly important in Santa Barbara where it is difficult to attract and retain talent due to the region’s high costs for housing.

Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

City of Santa Barbara CAP
Analysis of Costs and Benefits
The City of Santa Barbara (City) is setting an aggressive goal to achieve carbon neutrality by 2035, more aggressive than the State of California’s goals to reduce greenhouse gas (GHG) emissions 40% below 1990 levels by 2030 (SB 32) and 85% below 1990 levels or net zero by 2045. The City is developing a Climate Action Plan (CAP) to serve as a roadmap to achieve these GHG emissions reduction targets and to promote a higher quality of life for its residents. Achieving GHG emissions reduction requires strategic investments related to the measures and actions contemplated within the CAP including policies, infrastructure, technology, and programs that support behavioral change.

To provide transparency around the City’s investment priorities, Hatch and Rincon evaluated the potential benefits and costs of implementing a subset of the City’s CAP measures and actions. This memo also identifies funding and financing strategies that can support the implementation of the select measures and actions.

Benefit and Cost Considerations
The goal for this benefit and cost evaluation is to provide the City with insights into the variability of the impact of key measures and actions to the City, its residents, local property and business owners, and other stakeholders.

Some of the key variables that may affect cost effectiveness of measures and actions in the CAP include upfront costs, lifecycle costs, incremental or marginal costs, the time value of money, and the cost of inaction.
• Upfront vs. Lifetime Costs
It is important to differentiate between upfront costs and lifetime costs of implementing a measure. Upfront costs include the labor and material costs of an intervention (e.g., the purchase of an electric vehicle and the installation of an at-home electric vehicle charger).

Lifetime costs include the upfront costs as well as the costs of operating, maintaining, renewal and disposing of the intervention upon renewal (e.g., annual service or unplanned repair of both the electric vehicle and its charger). Lifetime costs are estimated over a finite period and are discounted to reflect net present value. While electric vehicles may be more expensive at the time of purchase than an internal-combustion engine, its lifecycle costs (e.g., its maintenance over the lifetime of ownership) are significantly lower than traditional vehicles, providing a significant return on investment.
• Incremental or Marginal Costs
An incremental or marginal cost is the difference in cost between a new intervention versus the old or typical approach. For example, purchasing an average sale price of a new electric vehicle in 2023 is $60,000, roughly 20 percent more than the sales price of a traditional car.

While the marginal or incremental cost in the short-term is significant in this example, it may be zero or near zero in the long-term because of reduced fuel costs and maintenance costs (e.g., fluid replacement, transmission repair, etc.) throughout the lifetime of the electric ATTACHMENT 4
Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

vehicle. In many cases the difference between choosing an emission reducing intervention versus the traditional alternative is negligible especially when considering the ongoing costs of the intervention.
• Financing: Time Value of Money and Savings or Avoided Costs Financing includes mechanisms (e.g., loans, bonds, etc.) that cover costs of a large investment such as upfront capital for infrastructure, equipment, or building re/development that must eventually be repaid over time. Financing leverages the time value of money and utilizes future revenues to back large investments today. In the case of revenue bonds, the repayment dollars may be from the large investment’s revenue stream. This return on investment (ROI) allows high-cost investments to be low, or no-cost over time given the potential savings and avoided costs gained over the useful life of an investment. Partnerships with third parties such as financial institutions and/or utilities can be structured against a capital investment’s cost savings or revenue streams. For example:
o Energy efficiency retrofits can generate cost savings of more than 30 percent for 15 to 20 years. If external partners are involved, such as with an energy savings performance contract (ESPC), cities may not need to provide any upfront capital, but the project’s cost savings would accrue with a private third party and be ceded by the city. o An anaerobic digester may need $5 million to $10 million in upfront capital but could also generate $1 million to $2 million annually in natural gas delivery revenue. Scaled over a 20-year period, the annual revenue can be an attractive financial investment for a city.

In addition to identifying the measures prioritized for this memo, the following table outlines approximate upfront cost estimates to assist in measure implementation. For each measure, both internal upfront (municipal-focus) and external costs (community-focus) are considered. The upfront costs presented in the tables do not consider the exact scale of the measures and do not represent the precise calculations of exact measure costs. Rather, these approximate upfront costs are presented to illustrate the order of magnitude of cost impacts to parties affected. Given the unpredictability of maintenance required and variables that affect operations, lifecycle costs are excluded in this analysis. Sunk costs or expenses already incurred and committed--such as salaries, lease payments, deposits, or cost of any investments made upfront—are also excluded from this analysis. The approximate upfront costs are sourced from various municipalities in California and are presented in today’s value (as of the time of writing, 2023). Additionally, upfront costs presented in this memo do not consider inflation, any potential for cost changes beyond inflation, or any future unforeseen fluctuations in cost (e.g., escalation of construction material costs due to supply shortages).

The findings from this memo may be utilized for prioritizing actions for implementation, for identifying more detailed scopes of work for an action, and as a discussion document when engaging with internal City departments and divisions for planning and implementation of measures and actions.

Funding and Financing Strategies
Local governments already face challenges in meeting their constituents’ needs for investment in many types of critical infrastructure and programs. This memo examines approaches that go beyond Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

the use of general fund monies to pay for climate-related infrastructure; funding and financing sourced outside municipal sources is central to unlocking investments that generate benefits for a wider group of constituencies in Santa Barbara and beyond. Funding and financing strategies that go beyond publicly-led approaches may also reduce the burden on low-income residents to fund investments that broadly support all residents and businesses in the City of Santa Barbara. This analysis identifies funding and financing approaches and relevant case studies in building electrification, building performance standards, and zero-emissions off-road equipment that result in emissions reductions.

Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Analyzed CAP Measures/Actions
To facilitate the City’s CAP implementation, this memo seeks to identify benefits and costs variables and to refine funding and financing approaches for a subset of measures and actions in the City of Santa Barbara CAP. The four subsets of measures and actions selected by the City for analysis are below.1
# Measure Actions
1 Electrification Programs and Policies for Multifamily Residential Properties BE-5:

Reduce Existing
Residential Natural Gas
Consumption by 10%
Below 2019 Levels by
2030 and 17% Below 2019
by 2035

5.13: Establish a program that provides targeted direct install services and cost share for specific electrification measures with multi-unit residential development owners. City to cover incremental cost in addition to an incremental electricity rate from SBCE.

5.14: Develop and implement a multi-family residential property regulation by 2028 to promote phased building energy efficiency and decarbonization. The regulation would require periodic energy inspections and prescriptive energy efficiency and decarbonization points requirements from a standardized checklist, with required performance increasing over time. 2 Residential Electrification at Time of Renovation and Time of Sale BE-5:

Reduce Existing
Residential Natural Gas
Consumption by 10%
Below 2019 Levels by
2030 and 17% by 2035

5.1: Adopt a time of renovation energy efficiency and electrification requirement by 2025, effective 2026. This ordinance could require replacement of HVAC systems, hot water heaters, and other appliances to be all electric and low hydrofluorocarbons (HFC) gas emitters or provide a checklist of costeffective efficiency and electrification options for renovations to complete based on the scope of the project. Adopt an electrification ordinance for existing residential buildings by 2028, effective 2029, to be implemented through the building permit process, which bans expansion or reconnection of natural gas infrastructure.
3 Commercial and Mixed-Use Energy Benchmarking Programs and Building Performance Standards BE-6:

Reduce Commercial
Natural Gas Consumption
10% Below 2019 Levels
by 2030 and 18% by 2035
BE-6.2: Develop and implement a commercial and mixed-use building benchmarking program for commercial and multifamily buildings over 20,000 square feet by 2025, effective 2026. The program would include reporting electricity and natural gas usage (and any other energy source) data through energy star portfolio manager. It would establish monetary penalties for noncompliance. Residential portions of buildings that are part of a mixed-use development would be exempt. Create incentives for buildings not covered to encourage voluntary compliance.
1 Example funding tools and financing mechanisms are not exhaustive, rather provides recent examples and prioritizes approaches applicable to California or have local precedence. Additional funding sources and financing opportunities can also be found in the Better Building Financing Navigator managed by the U.S. Department of Energy.

Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

4 Off-road Equipment Electrification and Decarbonization T-8:

Electrify or otherwise
decarbonize 6% of offroad equipment by 2030
and 20% by 2035
All actions including alignment with or exceeding AB 1346 (ban on gas powered small offroad engines by 2024)
Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Measure/Action 1: Electrification Programs and Policies for Multifamily Residential Properties
This set of measures and actions is associated with residential multi-unit electrification programs and policies.

BE-5: Reduce Existing Residential Natural Gas Consumption by 10% Below 2019 Levels by 2030 and 17% by 2035
BE-5.13: Establish a program that provides targeted direct install services and cost share for specific electrification measures with multi-unit residential development owners. City to cover incremental cost in addition to an incremental electricity rate from SBCE.

BE-5.14: Develop and implement a multi-family residential property regulation by 2027 to promote phased building energy efficiency and decarbonization. The regulation would require periodic energy inspections and prescriptive energy efficiency and decarbonization points requirements from a standardized checklist, with required performance increasing over time.

Enacting BE-5.13 and 5.14 would allow the City to meet the targets set in the CAP, reduce existing residential natural gas consumption by 10% below 2019 levels by 2030 and 17% by 2035. Currently, the City does not have programs or policies that prohibits natural gas use in existing residential properties; however, it adopted a natural gas prohibition in newly constructed buildings in 2022.2 The City is considering equity and funding of electrification in multi-unit properties by incorporating targeted direct install services and cost sharing. Cost sharing for multi-unit electrification would typically be partially funded by customers rather than fully incurred by the utilities. A phased approach to adopting multi-unit electrification would also grant the City the time to develop financing strategies on incremental costs and further its partnership with Santa Barbara Clean Energy (SBCE) and Southern California Edison (SCE) to negotiate an incremental electricity rate. It will also lessen the cost burden for many building owners.

Benefits and Cost Considerations
Benefits
Direct install rebates and cost-sharing of incremental costs for the electrification of multi-unit residential buildings have a variety of benefits to help meet zero-emission goals, although electrification requirements for multi-unit residential properties may vary. Some state and/or local governments provide financial support to audit the capacity for electrification at such properties. In New York, the Multifamily Buildings Low-Carbon Capital Planning Support program offers cost-share incentives through New York State Energy Research and Development’s (NYSERDA) Flexible Technical Assistance (FlexTech) program to help pay for an energy study for a multifamily portfolio.3 Services cost-shared by the FlexTech program includes general energy feasibility studies, peak-load reduction and load management, and long-term energy master planning. These services are designed to 2 City of Santa Barbara Natural Gas Prohibition, FAQ 2022 3 Multifamily Buildings Low-Carbon Capital Planning Support - NYSERDA Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

support commercial, industrial, institutional, government, and not-for-profit sectors with objective and customized information to help inform energy decisions.

Other municipalities, such as Piedmont in California, also have lending programs that provide residents—renters or homeowners—with loaner electric appliances. This includes programs that provide induction cooktops, an electric alternative appliance, that can replace natural gas stoves and reduce emissions.
4 The replacement of gas stove tops with induction stove tops would help decrease the negative effects of harmful pollutants to residents, which often can cause headaches and fatigue, and at very high levels, brain and heart damage.
5,6 Santa Barbara Clean Energy also has a similar
program where induction cooktop kits are available for loan through the Santa Barbara Public Library.7
Though the specific budget of these programs is not publicly available, existing program information from the City of Piedmont indicates that the main costs of these initiatives are staff time, which is used to set up and monitor partnerships (e.g. with the library), and funding to procure induction cooktops.

These cooktops are $100 or less.8 In the case of Piedmont’s induction cooktop lending program, induction cooktops were procured through partnerships with AVA (previously East Bay Community Energy). Replicating these successful partnerships and expanding existing programming through Santa Barbara Clean Energy could be helpful for the City of Santa Barbara in reducing programmatic costs associated with material procurement and staff time.

Another successful program for multifamily building electrification and energy efficiency is the Bay Area Multifamily Enhancements Program (BAMBE). BAMBE offers rebates starting at $500 per unit to help multifamily property owners (5+ units) lower the cost of energy efficiency upgrades while providing technical assistance. It also includes an ‘adder’ for building electrification, with total potential incentives coming in at $5,000 or more per unit. Since BAMBE began programmatic work in 2013, the program has upgraded over 45,000 units across the Bay Area and has provided over $34 million in direct rebates to multifamily property owners.

BAMBE’s climate impact through energy savings of these initiatives is significant, totaling 0.85 gross GWh and 87,000 gross therms saved as the direct result of programmatic work. According to the BayREN 2022 annual report, BAMBE program expenditures for the calendar year added up to a total of $2,951,888. It should be noted that these program expenditures encompass multiple programmatic areas beyond just building electrification (e.g. energy efficiency). In 2022, BayREN spent $477,650 on administration, $224,119 on marketing, $1,933,520 on direct implementation no incentive costs (DINI), and $316,600 on incentives.9,10
Another successful program for multifamily building electrification is a 2018 Pacific Gas and Electric (PG&E) multifamily rebate program that covered a range of energy-efficient upgrades and measures 4 Induction Cooktop Lending Program | City of Piedmont
5 Indoor Air Pollution from Cooking | California Air Resources Board 6 Combustion Pollutants & Indoor Air Quality | California Air Resources Board 7 Induction Cooktop Kits, Santa Barbara Clean Energy
8 https://www.nytimes.com/wirecutter/reviews/best-portable-induction-cooktop/ 9 Bay Area Regional Energy Network (BayREN 2022 Annual Report) | BayREN https://www.bayren.org/multifamily-property-owners/buildingimprovements. 10 BayREN Increases Rebates for Multifamily Rebates, Yemi Reyes for CivicWell.org. https://www.bayren.org/sites/default/files/2023- 05/BayREN%20AR%2011x17.pdf
Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

such as lighting upgrades, heating and cooking systems, water heating, building envelope improvements, appliances, and energy audits.11 These incentives were recommended based on assessment results in order to provide comprehensive, whole-building energy savings.12 The program aimed to promote long-term energy benefits through energy efficient solutions including those that would incentivize customers to eliminate unnecessary energy use, reduce carbon footprints, and save money.13
To be able to pay for the incremental costs of electrification, cost-sharing between utilities (and community choice aggregators) and residents would help with upfront costs that would otherwise be infeasible if solely paid for by one party. The City would achieve its decarbonization goals, while residents get support transitioning to all-electric buildings. Additionally, some states, like New York, have implemented bill relief programs that help support low-income customers or even exempt lowincome customers from cost-sharing to allow for more equitable access to the electrification transition.14 Other states like California have programs for income-qualified residents and owners to receive energy-efficient appliances at no or minimal charge.15 These cost sharing programs help reduce the marginal cost to upgrade appliances from gas to allelectric. The increase in the marginal cost of appliance replacement is seen as the main cost hurdle for procuring and installing electric appliances, and thus, building electrification. In some cases, the incentives and cost sharing structures described above can even bring the cost of multifamily building electrification to be equal to the cost of gas upgrades that would have happened anyway in a ‘business as usual’ scenario.

Benefits to Community
Direct install rebates allow residents and property owners to move toward electrification of multifamily residential buildings with financial incentives to invest in electric alternatives.

Ultimately, cost-sharing allows building owners to share the upfront costs of energy efficiency upgrades with the utilities and residents. As stated above, utilities benefit through more efficient appliances (heat pumps) and strategies such as storing thermal energy with hot water heaters equipped with mixing valves or demand response programs.16 This cost-sharing allows for multiple parties to be invested in supporting zero-emission goals and will reduce electricity bills for both residents and property owners in the long-term. In this way, the community has a direct contribution to lowering emissions in multifamily buildings. For the building owners, cost-sharing with residents would also allow for a faster return on investment as well as improved building value, as compared to other less energy efficient buildings. As federal policy towards electrification continues to advance, building owners that participate in costsharing will meet the requirements for energy saving earlier rather than later. 11 Multifamily Property Program Energy-Efficiency Rebates Catalog | PG&E 12 High-Impact Programs Targeting Regional Multifamily Energy Savings Opportunities, July 2021 | ACEEE 13 PG&E Energy Efficiency Annual Report, 2018
14 Electric and Gas Bill Relief Program | New York State 15 Energy Savings Assistance | California Public Utilities Commission 16 Water Heaters Have Battery Potential | IEEE
Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Benefits to City
The main benefit to the City of electrification is the achievement of decarbonization goals associated with electrification. Incentivizing electrification at the most cost-effective time and preparing the community for this transition is a primary goal of the City.

Across the City of Santa Barbara, multi-unit residential properties use a total of 4,027,341 therms of natural gas every year. It is important to break out this natural gas use by appliance type, as building electrification will ultimately depend on the replacement of natural-gas burning appliances as they fail (‘burnout’) replaced with electric alternatives. These appliances will function anywhere from 10-22 years. When all multi-family housing units in Santa Barbara are accounted for, the appliance units used for a multifamily household are collectively expected to emit 421,284 MT CO2e across their functional lifespan. As shown in Error! Reference source not found., the City would reduce 86 therms of natural gas per year for each water heater that is electrified, 88 therms for each furnace, and 20 therms for each stove on average. Other includes all other gas uses, likely clothes dryers, pool heaters, and other less common uses.

Table 1: Multifamily Building Electrification (GHG Savings & Marginal Cost) Household Appliance Type Water
heating
Spacing
heating/cooling
Cooking Other Total
Appliance Lifespan (Years) 13 22 12 10 N/A
Total annual natural gas use
(therms/year) 86 88 20 32226
Total therms (lifespan) 1,119 1,899 245 317 3,580
Appliance Lifespan GHG
Emissions
(MT/CO2e/Source/Unit)
7 13 2 2
24 *Total emissions includes both combustion and associated leakage Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Although the City is expected to cover the incremental costs of some rebate programs which adds to the City’s upfront costs, the cost-sharing approach will alleviate and reduce some of the upfront cost to the City. Long-term energy reduction will ultimately benefit the management of the City’s grid and utilities. The reduction of overall energy demand in the City will help conserve natural resources and encourage a more sustainable energy ecosystem. While electrification of buildings and vehicles will ultimately require grid upgrades to handle additional electricity use, it is important to identify the nuances of how building and transportation electrification will impact future electrical load. Heat pumps, when combined with weatherization upgrades can reduce summer peak electrical demands, and reduce electricity use by 50 percent in comparison to traditional HVAC systems.17 Heating and cooling buildings take up the largest percentage of total building electrical loads, with HVAC electrical loads ranging from 25-33 percent of total household energy load.18 Most relevant to Santa Barbara’s climate, a Natural Resources Defense Council (NRDC) analysis on air conditioning replacement with heat pumps came to the conclusion that California’s electric grid, which is “summer-peaking” would experience reduced risk of heatinduced blackouts through the installation of heat pumps in place of older air conditioning units.19 It is also important to consider future projections for vehicle electrification when thinking about future electrical loads related to building electrification. New State targets for vehicle electrification, target 12.5 million electric cars on California’s roads by 2035, is expected to increase electric loads across the State. As an example State grid planners are projecting a more modest estimate of 3.7 million electric vehicles by 2035 an increase of 35,000 GWH by Though these grid planning efforts are factoring in rates of new renewable energy procurement to shape this demand, designing in future flexibility and incentives for strategic vehicle charging will be critical in allowing for continued grid reliability.20,21 Though building electrification offers significant opportunities to reduce peak summer loads, increases in EV adoption may need to be met with incentives for flexible charging, and more aggressive energy efficiency moves. These energy efficiency initiatives could be partially achieved through reductions in commercial building energy usage through BE-6, which aims to establish efficiency standards in the often oversized and energy-intensive commercial building sector.
17 Pump Up Your Savings with Heat Pumps, May 30, 2023 | Energy.gov [U.S. Department of Energy] 18 Duty-cycling buildings aggressively: The next frontier in HVAC control, Agarwal et al. 2021; Proceedings of the 10th ACM/IEEE International Conference on Information Processing in Sensor Networks 19 Want to Cut Heating Costs? Replace Your AC! Kiki Velez, October 2022 | Natural Resources Defense Council 20 Race to Zero: California’s bumpy road to electrify cars and trucks, Jan 2023, Nadia Lopez | CalMatters 21 2021 IEPR California Energy Demand Forecast Summary
Jobs Impacts
It is hard to challenge the fact that electrification is on the rise and the increasing need for skilled labor workers to keep up with the demand of end-use technology transformations for stove-tops, hot water heaters, furnaces, and the necessary home and commercial electrical upgrades (breaker boxes) to electrify buildings, as well as grid infrastructure updates. A 2020 study shows that decarbonization can create millions of well-paying American jobs with opportunity to become an exporter of clean energy technologies also increasing job growth.

A Hatch-led study for the City of Santa Cruz shows that capital expenditures ranging from $80 million to $100 million for electrification of existing commercial and residential buildings in the city may result to 50 to 55 California jobs annually.

Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Additionally, energy efficiency programs have potential to create jobs in various sectors and can stimulate local economic growth and provide employment opportunities.22 The initiatives supported by the City may also resonate with the larger public and rally more environmentally conscious residents and businesses towards the effort.

Costs
Although there are many benefits to direct install rebates and cost-sharing, there are regulatory uncertainties, potentially substantial upfront financial costs, and technological information gaps that may become challenges for both the community and local governments.

Costs to Community
Multi-family housing utilizes a wide variety of equipment and electrical infrastructure depending on the age and design of the building and the number of units. Some multi-family buildings utilize the same equipment as those found in single-family residential units (the costs for which can be found in Error! Reference source not found. under Action 2). In some cases, equipment such as water heaters may even serve multiple units resulting in lower per unit costs. However, other larger buildings could utilize rooftop package units, hot and chilled water loops, boilers, or other technologies. Each of these equipment types as well as other physical attributes of the specific building will have significant impacts on costing. While it is possible to identify costs associated with specific appliances, it is difficult to identify general costs for electrical infrastructure upgrades associated with multifamily buildings, such as panel and service upgrades due to the nuances associated with age, scale and design of multifamily buildings. The cost of infrastructure up-grades requires a significant study that falls outside of the scope of this analysis.

One potential area for the City to focus on is rooftop heat pump package units which have been shown to be cost competitive and have similar footprints to gas package units. Data provided by Peninsula Clean Energy in San Mateo County details different sized heat pump package units only slightly increasing costs compared to gas package units, as shown in 22 Mobilizing for a Zero Carbon America | Laskey and Rewiring America Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Figure 1. This near-cost parity between existing gas and electric technologies means that transitioning rooftop heat pump package units offers an opportunity to electrify buildings with no, or minimal upfront costs.

Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Figure 1 Median Rooftop Packaged Heat Pump Installation Costs (PCE Decarbonization Plan) Larger buildings also tend to have systems that are oversized which can lead to inefficiencies. As documented in the 2023 City of Sacramento Existing Building Electrification Strategy, interviews with local contractors and facility managers concluded that commercial building infrastructure is mostly oversized. From the vantage point of commercial building/facility managers, oversizing building heating and cooling systems was considered easier in guaranteeing heat and hot water performance rather than fine-tuning the needs of a smaller system to match the timed demand for heating and cooling.23
When electrifying, it will be important to understand the buildings existing electrical infrastructure and actual heating and cooling needs and to identify any cost-effective efficiency actions to allow for downsizing of new electric equipment. Balancing the heating and cooling needs with the electrical service and infrastructure of each building is critical to limiting added infrastructure costs related to building electrification. To fully understand the costs associated with multi-family housing electrification in Santa Barbara, additional research should be conducted on the most common building electrical infrastructure and heating and cooling systems and their electric alternatives. In addition, depending on the on-bill savings (which are heavily dependent on the difference in cost between gas and electric), some investments in electrification may also have lengthy payback periods where the long-term benefits are not seen by the residents nor the property owners until many years later. Both property owners and residents may be reluctant to commit to improvements that they will not see in their time living in the complex or owning the property.
23 City of Sacramento Existing Building Strategy, 2023 | City of Sacramento Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Some studies have estimated average retrofit costs for the full electrification of multifamily buildings. Detail from a study completed in New York State is shown in Figure 2. 24 This is the total
upfront cost to install all new electric appliances and infrastructure. To understand the marginal cost, the single-family gas installation cost could be used as an estimate. Smaller multifamily buildings are likely to use similar appliances as single family units but may even share a single appliance between two units, decreasing the per unit cost to upgrade. 25 Based on data from the
San Francisco Bay Area the marginal cost to install all new gas appliances is between $11,000 and $18,000 depending on whether an air conditioning is in place. This results in an average marginal cost of $8,000 to $25,000 per unit.

Figure 2 Retrofit Costs of Multifamily Buildings Per Unit (NY State; all-appliance replacement) Costs to City
For Action 5.13 the City’s costs would be based on the number of direct install projects completed and the per unit costs described in Error! Reference source not found.. If the City’s project covered larger systems, like boilers, those costs could be significantly higher. In addition, the City would likely need dedicated staff to support this program as well as for potential technical consulting support, the cost of which would be dependent on the size of the program and the program needs.
24 https://www.nyserda.ny.gov/-/media/Project/Climate/Files/2022-Comments/NY-Building-Electrification-Cost-Full-Report-June2022 25 U.S. Households are Using Less Energy, 2018 | Joint Center for Housing Studies of Harvard University Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

For Action 5.14 the City would need to develop an ordinance and checklist, which could be completed by a consultant or City Staff for an estimate of approximately $100,000. However, the City would also likely need additional staff to support the program and to conduct inspections.

Likely between 1 and 2 full time staff at a minimum would be needed to actively manage the program and complete the inspections.

Current Rebates and Incentives
Figure 3 includes a list of rebates and incentives that are currently available for multifamily buildings in Santa Barbara based on information from The Switch Is On which compiles rebates for each geographic area. These rebates were accessed on September 15, 2023 and are subject to change.

Additional low-medium income upfront incentives are expected to be made available by the Inflation Reduction Act in early 2024.

Figure 3 Multifamily Electrification Rebates For City of Santa Barbara Multi-Family Electrification Rebates
Appliance Funder Incentive
Amount
Source
Heat Pump Hot
Water Heater
(HPHWH)
3C-REN: Lowrange $500
https://incentives.switchison.org/rebate-profile/3cren-500-750-heat-pump-water-heater-multifamilybuilding-project-s?view=residents&origin=directory 3C-REN: HighRange $750
https://incentives.switchison.org/rebate-profile/3cren-500-750-heat-pump-water-heater-multifamilybuilding-project-s?view=residents&origin=directory IRA* $2,000
CityofSanMateo_CostData_Clean_V2.xlsx; backed up
by :
https://incentives.switchison.org/residents/incentives
?field_zipcode=93101&field_zipcodes1=93101&field_f
unctional_category=All&f%5B0%5D=incentive_type%
3A2794
Total HPWH Incentives- Low-Range $2,500
Total HPWH Incentives- High-Range $2,750
Heat Pump HVAC 3C-REN: Ductless
(Mini-Split) lowend $500
https://incentives.switchison.org/residents/incentives
?field_zipcode=93101&field_zipcodes1=93101&field_f
unctional_category=6
3C-REN Ductless
(Mini-Split) highend $750
https://incentives.switchison.org/residents/incentives
?field_zipcode=93101&field_zipcodes1=93101&field_f
unctional_category=7
IRA* $2,000
CityofSanMateo_CostData_Clean_V2.xlsx; backed up
by :
https://incentives.switchison.org/residents/incentives
?field_zipcode=93101&field_zipcodes1=93101&field_f
unctional_category=All&f%5B0%5D=incentive_type%
3A2794
Total Heat Pump HVAC Incentives;
Low-End $2,500
Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Multi-Family Electrification Rebates
Appliance Funder Incentive
Amount
Source
Total Heat Pump HVAC Incentives;
High-End $2,750
Panel Upgrade IRA* $600 CityofSanMateo_CostData_Clean_V2.xlsx; backed up by :
https://incentives.switchison.org/residents/incentives
?field_zipcode=93101&field_zipcodes1=93101&field_f
unctional_category=All&f%5B0%5D=incentive_type%
3A2794
Total incentives for Panel $600
Whole-Home
Electrification
Credit (AllSystems)
CA Energy Smart
Homes $3,550
https://incentives.switchison.org/rebateprofile/energy-smart-homes-whole-houserebate-multifamily?view=residents&origin=directory *Incentive values reflect available rebates and incentives written upon the writing of this memorandum during late summer of 2023.

IRA rebates may vary in timing and applicability of availability of funding. TECH and 3C-REN incentives should be continually monitored by City staff as funding availability and deadlines change often.

Additional Funding and Financing Strategies
Strategies to fund or finance projects resulting from the implementation of BE-5.13 and 5.14 include the use of state and federal grants as well as co-funding; ratepayer energy efficiency programs for multifamily properties; low or no interest loans from utilities and other state-run organizations; and on-bill financed programs. Rebates and assistance programs are widely available particularly for affordable multifamily housing units; however, these are competitive.

Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

To undertake BE-5.13 and 5.14, a coordinated approach with multi-unit properties and property owners in the City will be needed. Before implementation, the City should consider an electrification readiness of multi-unit properties in the City through BE-5.2.26 The City may use existing rate studies from Southern California Edison and SBCE to understand current rates and other associated electrical costs today. Funding and financing strategies will be based on these studies. Additional example funding and financing case studies follow below.

Bay Regional Energy Network (BayREN)
27 Bay Area Multifamily Building Enhancements (BAMBE)
Agency/Implementer: Regional Association | Program Type: Rebate | Beneficiary: Property Owners BayREN assists eligible multifamily properties28 and their owners seeking to replace old equipment and upgrade building’s energy and water efficiency. BayREN provides technical assistance and cash rebates for qualifying upgrades including gas-to-electric conversions. The rebate program includes a base rebate—$500 per apartment unit—for the installation of two or more energy efficiency upgrades that save 10% or more of a property’s energy use.

Additional rebates for in-unit electrification upgrades, such as electric laundry dryers or electric cooking range from $250 to $1,500 per apartment unit. The rebates for system upgrades such as those for central systems, common areas, and electrical panels vary by equipment, by the number of apartments served or by property.

Properties located in high-priority zones—areas most affected by air pollution, extreme heat, and high housing costs—qualify for additional rebates. In these zones, upgrades that mitigate extreme heat and improve indoor air quality may earn $500 per apartment served. Properties that are 26 The completion of an existing building electrification feasibility analysis in collaboration with UC Santa Barbara and other research institutions by 2025.
27 A regional organization managed by the Association of Bay Area Governments. BayREN is funded by California utility ratepayers under the California Public Utilities Commission (CPUC) and the public purpose surcharge, as well as through grants and funding from member agencies, other state and federal agencies, and foundations. 28 Eligible properties must meet target criteria, see page 8 of the BayREN Annual Report 2022. Any other properties that do not meet at least one of the target criteria are put on a waitlist or admitted into the queue periodically given availability.

Cost-sharing Among Distributed Energy Resource Customers in Minnesota Minnesota is the first state to adopt an approach to interconnection upgrades that spreads costs among certain distributed energy resource (DER) customers, rather than asking all utility ratepayers or individual DER customers to foot the bill. The local utility provider is Xcel Energy, a major utility that serves approximately 3.7 million electricity customers across parts of the Midwest and Western states.

Under the cost-sharing program, all Xcel Energy customers applying to interconnect a project up to 40 kilowatts will be asked to pay a cost-share fee of $200, which will then make them eligible to have grid upgrade costs covered, up to a cap of $15,000 per project.

The program also includes two key equity considerations. First, the program will exempt under-resourced or “low-income” customers qualifying for Xcel’s income qualified Solar Rewards program from paying the cost share fee. Additionally, Xcel is required to create a waitlist for customers participating in the program— ensuring that, even in the case of temporary insufficient funding, all customers who pay the cost share fee will be able to have up to $15,000 of upgrades covered by the fund.

Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

affordable (properties built before 2010 with less than 50 units or deed-restricted affordable properties) seeking any upgrades earn 1.5x to 2x more above all other program rebates. 29 California Energy Design Assistance Program (CEDA; run by Willdan) Agency/Implementer: Third-party Program Administrator; Utility Provider | Program Type: Technical Services, Rebate | Beneficiary: Property Owners
SCE commissioned the California Energy Design Assistance (CEDA) program as part of the California Public Utilities Commission’s Energy Efficiency program. The program provides complimentary custom energy modeling to analyze energy efficiency options and potential energy savings from common areas and in-unit upgrades or building controls and energy recovery systems in new construction and major alteration multifamily projects. A property’s incentive is provided and based on estimated energy savings across the building’s lifetime and paid after installation and savings are verified. Incentives are capped at $1 million per project and lesser of 100% incremental measure cost or 50% full measure cost.30 Bay Area Air Quality Management District (BAAQMD) Climate Tech Finance Agency/Implementer: Local Air District; Bank | Program Type: Loans | Beneficiary: Local Governments; Small Businesses
Climate Tech Finance, through the California Infrastructure and Economic Development Bank (iBank), offers government-back loan guarantees to municipalities, universities, schools, hospitals, as well as small businesses and eligible nonprofits or public-private partnerships within the BAAQMD jurisdiction for climate tech financing. Direct loans are available to public-sector facilities.

Loan guarantees of up to $5 million are offered on loans of up to $20 million, with up to a sevenyear term. iBank provides loans for public entities ranging from $500,000 to $30 million, with up to 30-year terms. Interest rates vary and are based on public entities’ ratings. Eligible projects include any that has direct greenhouse gas reductions, such as electrification, on-site or indirect reductions.

Southern California Edison (SCE) On-Bill Financing (OBF) Program for Non-Residential Customers Agency/Implementer: Utility Provider | Program Type: OBF, No/Low Interest Loan | Beneficiary: Utility Customers
Eligible31 SCE non-residential customers may participate in on-bill financing (OBF) for qualifying energy efficiency projects. OBF through the SCE includes no interest, no fees or loan costs, and repayment through the SCE utility bill. Loans are at a minimum of $5,000 and a maximum of $250,000 for projects by multifamily customers with loan terms of up to 10 years. Loans may be bundled or consolidated but all loans are capped at a maximum of $4,000,000 per service account, though exceptions apply on a case-by-case basis.
29 More details on additional rebates by in-unit or system upgrades and geographic locations are found at BayREN.org/multifamilyproperty-owners/building-improvements. 30 CEDA Factsheet
31 Eligible SCE customers are those who participate in the capital projects under the Strategic Energy Management Program or those who participate in statewide Energy Efficiency program such as CEDA for multifamily and are in good credit standing.

Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

US Department of Health and Human Services, Low Income Home Energy Assistance Program (LIHEAP)
Agency/Implementer: Federal; State Government | Program Type: Funding Assistance | Beneficiary:

Local Governments; Residents
The State of California received $179 million in LIHEAP funding in 2022 to assist households with low income, particularly those with the lowest incomes that pay a high proportion of household income for home energy. The resulting programs implemented by municipalities within the state can support the City in providing free energy efficiency upgrades to low-income households, including those in low-income multifamily housing, to lower their monthly utility bills while also improving the health and safety of the household's occupants. Eligibility is based on income requirements. Funds for the state in 2023 are not yet available at the time of this writing.

Retrofit Electrification Pilot in New York City
Building owners receiving Housing Preservation and Development (HPD) financing for rehabilitations of multifamily buildings up to seven stories that are interested in electrification of hot water heating and/or space heating and cooking may be eligible for funding and technical support through the HPD-New York State Research and Development Authority (NYSERDA) Electrification Retrofit Pilot. Projects must meet the criteria to be considered. Funding will cover incremental costs for electrification and will be granted on a first-come, first-served basis. Funding may be capped on a per-project basis and will be limited to $1 million per project.

Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Measure/Action 2: Time of Renovation/Sale Electrification Requirements
This measure and action involves two actions associated with time of renovation and time of sale electrification policies under the City’s Measure BE-5: BE-5.5 and BE-5.6.

BE-5: Reduce Existing Residential Natural Gas Consumption by 10% Below 2019 Levels by 2030 and 17% by 2035
BE-5.5: Adopt a time of renovation energy efficiency and electrification requirement by 2025.

This ordinance could require replacement of HVAC systems, hot water heaters, and other appliances to be all electric and low hydrofluorocarbons (HFC) gas emitters or provide a checklist of cost-effective efficiency and electrification options for renovations to complete based on the scope of the project.

BE-5.6: Provide a rebate at time of sale for qualifying building electrification upgrades including panels, wiring, and heat pump appliances. Implement the rebate program by 2025.

Benefits and Cost Considerations
Benefits
The adoption of a time of renovation and time of sale electrification requirements will benefit both the community and the City in several ways. Overall, building energy efficiency measures can benefit the broader society by reducing GHG emissions and help meet carbon reduction goals. Increasing energy efficiency helps lower utility bills for residents and can increase comfort levels during high summers and cold winter months. This can lead to a better quality of life for residents and higher resident retention rates.32 Utility programs are incentivized to encourage customers to upgrade their systems since electrification alternatives to on-site fossil-fueled heating can be as much as three times more energy efficient.
33 The addition of adopting these requirements at the time of renovation and time of sale will further accelerate electrification especially in the case of multifamily buildings. To support, the federal government has dedicated $4.5 billion towards the Home Electrification and Appliances Rebates to advance a high-efficiency electric home rebate program. 34 These types of programs help households
reduce energy bills and allows for easier access to residential energy improvements. Due to the demand, these programs also attract qualified workforces to serve both single and multifamily markets and increase market demand for residential efficiency and electrification.35 Benefits to Community
Time of renovation and time of sale requirements will incentivize property owners to focus on electrification through a rebate. These energy efficiency adjustments can produce benefits for both building owners and occupants, such as lower energy costs and improved comfort, increase 32 Standard Rebates for Multifamily Properties | Austin Energy 33 Renovating Regulation to Electrify Buildings | Shipley, Hopkins, Takahashi, Farnsworth, 2021 https://www.raponline.org/wpcontent/uploads/2021/01/rap-shipley-hopkins-takahashi-farnsworth-renovating-regulation-electrify-buildings-2021-january.pdf 34 Home Electrification and Appliance Rebates | Department of Energy 35 IRA Home Energy Rebate Program Informational Webinar Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

property values, reduce work orders, and decrease maintenance costs for properties.36 For example a Rocky Mountain Institute 2018 Report ‘The Economics of Existing Buildings’ shows a lower 15-year net present cost for Oakland homes with a retrofit using a flexible heat pump in any electrical rate scenario ($20.8-22.9) instead of a natural gas with new air conditioning scenario ($24.2).37
Benefits to City
As stated above, the major benefit to the City of electrification is meeting the aggressive GHG reduction goals adopted in the CAP. Across the City of Santa Barbara, single-family properties use a total of 8,105,606 therms of natural gas every year. Similar to the multifamily GHG and marginal cost description described above, the gas appliances that will ultimately need to be replaced with electric technologies to effectively electrify buildings will function anywhere from 10-22 years.

When all single-family housing units in Santa Barbara are accounted for, the appliance units used for a single-family household are collectively expected to emit 871,756 MT CO2e across their functional lifespan. At the single-family household level, each household can reduce 40 MT CO2e GHG through whole home electrification by electrifying gas appliances as they fail.

As the appliances being replaced are the same as for multifamily properties, the total cost of whole-home appliance replacement is projected to be $17,200 before incentives. This cost is the marginal cost (electric-gas replacement) without factoring any incentives for electrification, so can be considered a conservative cost estimate to electrify. When broken out by appliance type, this means that the building owner would be paying $256-$556 for each MT of CO2e when they electrify before any incentives, as displayed below in Table 2.

Table 2: Single-family Building Electrification (GHG Savings & Marginal Cost) Household Appliance
Type
Water heating Spacing
heating/cooling
Cooking Other TOTAL
(WholeHome- as
applicable)
Appliance Lifespan (Years) 13 22 12 10
Total annual natural gas
use (therms/ lifespan of
appliance) 1,886 3,201 412 535 6,034
Appliance Lifespan GHG
Emissions
(MT/CO2e/Source/Unit) 12 21 3 4 40
Electric Replacement Cost
$ 6,000

$ 17,900 $ 2,400 $ 2,000 $ 28,300
Gas Replacement Cost
$ 2,800 $ 6,100 $ 1,200 $ 1,000 $ 11,100
Marginal Cost
$ 3,200 $ 11,800 $ 1,200 $ 1,000 $ 17,200
Marginal Cost/Lifespan
MT CO2e $ 256 $ 557 $ 440 $ 283 $ 431
36 Renovating Regulation to Electrify Buildings | Shipley, Hopkins, Takahashi, Farnsworth, 2021 37 Rocky Mountain Institute, the Economics of Electrifying Existing Buildings, 2018 The Economics of Electrifying Buildings - RMI Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

These electrification measures could also offer economic and workforce development opportunities. A UCLA Luskin Center for Innovation 2019 Report analysis revealed that electrification of building stock across the state would create over 100,000 full time equivalent jobs, even after accounting for job losses in the fossil fuel industry. This new demand for skilled workers is expected to grow in sectors including construction jobs for energy-efficient improvements, building upgrades and modifications, and electric equipment installation.

Planning for this workforce transition will be critical to ensure a just transition, as an estimated 55% of gas workers are expected to reach retirement age over the next 25 years. This growth in electrification-related jobs could be a major opportunity for job growth in the City, as well as an opportunity to aid a just transition of fossil-fuel workers to clean-energy jobs38 Costs
Time of renovation and time of sales requirements encourage the electrification of buildings.

However, there are several challenges that the community and City could face in doing so. Upfront costs pose a challenge and can be a financial burden for building owners, especially for owners with limited budgets or resources. The time at which electrification takes place is very important for determining costs. As shown in Figure 4, the total upfront cost to electrify a single-family building is approximately $32,000 and assumes a shift from natural gas to electric for the stove, HVAC, dryer, and water heater, as well as a panel upgrade and new wiring for 220v appliances. However, the marginal cost of upgrading (compared to replacing it with another natural gas appliance) is only $13,400 before rebates. By stacking rebates, the marginal cost could potentially be lower to electrify than to replace with gas.

Costs to Community
Single family residential electrification costs are becoming more readily understood. Error! Reference source not found. summarizes average installation costs in San Mateo County. While these costs are likely similar in Santa Barbara, some cost variables can significantly change the costs for a particular building or region. The major cost variables include:
• Need for a panel upgrade (as shown in the figure panel upgrades can add nearly $4,000) • Existing or desired air conditioning (a single heat pump provides both heating and cooling, saving money compared to a separate furnace and AC unit installation) • Labor costs in the region (higher labor costs increase installation costs) • Existing electrical infrastructure (knob and tube is a safety hazard and difficult to work with) • Space constraints (heat pumps are larger)
Consistent with the major cost variables described above, Error! Reference source not found. below includes specific rows for air conditioning because the installation of a heat pump HVAC functions as both an air conditioning and space heating unit, displacing the need for two separate appliances. This means that the entire cost of an air conditioner ($7,500) is functionally displaced by one appliance: a heat pump HVAC, leading to cost savings equivalent to the cost of a new air conditioner. The City is expected to experience future effects of extreme heat, like the heat advisory experienced throughout the region in August of 2023. In response, more City of Santa Barbara residents are expected to install AC to adapt to these changing temperature conditions.39 38 California Building Decarbonization: Workforce Needs and Recommendations, Nov 2019, UCLA Luskin Center for Innovation 39 County of Santa Barbara, Heat Expected in Santa Barbara County, August 2023 Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Similarly, the need for an electric panel upgrade, triggered by a greater electrical load through new electric appliances is a critical cost variable to consider, as it is estimated to cost $3,700 upfront. The addition of an electric panel upgrade depends on the existing panel size of the house, which is closely correlated to building vintage (age). An analysis by Redwood Energy estimates that housing with a 100-amp panel can accommodate whole-home electrification, if there is incorporation of a “watt diet” strategy. Watt diets allow for maximization of the existing panel, avoiding the cost of a panel upgrade through selection of highly efficient appliances, and if necessary, prioritized circuit sharing devices.40 Accordingly, the last four rows of Error! Reference source not found. describe different scenarios for electric, gas, and marginal cost replacement when factoring potential cost savings from avoided AC installation, or cost increases from electrical panel upgrades.

Figure 4 Residential Electric and Gas Replacement Upfront Appliance Installation Costs* Residential Appliance Electric
Replacement Cost
Gas Replacement
Cost
Marginal Cost
Gas HVAC to Heat Pump HVAC $17,900 $6,100 $11,800
Gas water heater to Heat Pump
water heater $6,000 $2,800 $3,200
Air Conditioning (Gas case only) Included with heat
pump $7,500 ($7,500)
Gas stove to electric stove $2,400 $1,200 $1,200
Gas dryer to electric dryer $2,000 $1,000 $1,000
Electric Panel Upgrade $3,700 N/A $3,700
Total with AC + Panel
$32,000 $18,600 $13,400
Total Without AC + Panel
N/A $11,100 $20,900
Total with AC no Panel
$28,300 N/A $9,700
Total without AC no Panel
N/A N/A $17,200
*Based on 2023 appliance costs and labor costs for the San Francisco Bay Area A slow payback rate of lower energy bills may make it difficult for some households to justify a higher upfront cost for electrification, especially those without extra cash on hand.41 For multifamily residential homes, rebates to a building owner who does not pay the utility bill may 40 Redwood Energy, Watt Diet Calculator. 41 To Decarbonize Households, America Needs Incentives for Electric Appliances | American Progress, 2021 Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

not be a strong enough incentive. Similarly, a resident living in an older apartment building may not want to invest in a home they do not own. Actions BE-5.5 and BE-5.6 will need additional public outreach and education for both property owners and residents. Any incentive program that the City may develop should be coupled with extensive and targeted outreach efforts to reach property owners and residents that may not have the resources for a full-electrification transition.

While on-bill costs could not be calculated specifically for Santa Barbara in this report (due to the complexity of time of use rates, variability of gas rates over time, and other factors) studies in other locations have shown that electrification of single-family buildings can be cost effective within the correct rate structure. For example, a recent analysis conducted by Peninsula Clean Energy and Silicon Valley Clean Energy showed that after electrification an average single-family home which stayed on basic electricity rates saw an on-bill increase of approximately $300 per year. However, if the all-electric rate was used (which has electrification friendly time of use rates) the same home would save about $200 per year or $32 per month as shown in Figure 5. 42 These
savings may or may not represent conditions in Santa Barbara due to differences in rate structure and climate zone. However, a significant departure from these results (a small increase or small decrease in energy bills) is not likely.

Figure 5 On-bill savings after electrification on the E-Elec Rate (PCE/SVCE Single Family On-Bill Impacts Results) Costs to City
The City may face similar high upfront cost issues as having to support the payment of incremental costs for electrification. Although some larger cities like New York City fund programs that will support residents and building owners in their transition, not many other cities have as ample services. The City would need to work with the local utility companies to determine upgrades that may be needed to support additional energy use. Collaboration would include planning, coordination, permitting approvals, infrastructure investment, and oversight with utility companies.
43 42 SVCE-PCE-Single-Family-On-Bill-Impacts-Results-2023.pdf (svcleanenergy.org) 43 Building the Electricity Grid of the Future | Governor Gavin Newsom, 2023 Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Current Rebates and Incentives
Figure 6 provides some examples of single-family residential rebates available for heat pump hot water heaters (HPWH), heat pump HVAC, panel upgrades, and whole-home electrification credits.

Rebates are currently available from 3C-REN, TECH Clean California, and the Inflation Reduction Act.

Many of these incentives can “stack”, meaning a single project can take advantage of multiple incentive streams.

Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Figure 6 Single-Family Electrification Rebates For Santa Barbara Single-Family Electrification Rebates
Appliance Funder Incentive
Amount
Source
Heat Pump
Water Heater
(HPWH)
3C-REN: Low-range $2,420
https://www.3c-ren.org/for-residents#!directory;
https://incentives.switchison.org/rebate-profile/3cren-500-750-heat-pump-water-heater-multifamilybuilding-project-s?view=residents&origin=directory 3C-REN: High-Range $8,450
https://www.3c-ren.org/for-residents#!directory;
https://incentives.switchison.org/rebate-profile/3cren-500-750-heat-pump-water-heater-multifamilybuilding-project-s?view=residents&origin=directory IRA* $2,000
CityofSanMateo_CostData_Clean_V2.xlsx; backed up
by :
https://incentives.switchison.org/residents/incentives
?field_zipcode=93101&field_zipcodes1=93101&field_f
unctional_category=All&f%5B0%5D=incentive_type%
3A2794
Total incentives for HPWH - Low; Range:
$4,420
Total Incentives for HPWH- High-Range:
$10,450
Heat Pump
HVAC
TECH $1,000
CityofSanMateo_CostData_Clean_V2.xlsx; backed up
by :
https://incentives.switchison.org/residents/incentives
?field_zipcode=93101&field_zipcodes1=93101&field_f
unctional_category=All&f%5B0%5D=incentive_type%
3A2794
3C-REN low-end $3,896
https://incentives.switchison.org/rebate-profile/3cren-single-family-hvac-heatpump?view=residents&origin=directory 3C-REN high-end $14,535
https://incentives.switchison.org/rebate-profile/3cren-single-family-hvac-heatpump?view=residents&origin=directory IRA* $2,000
CityofSanMateo_CostData_Clean_V2.xlsx; backed up
by :
https://incentives.switchison.org/residents/incentives
?field_zipcode=93101&field_zipcodes1=93101&field_f
unctional_category=All&f%5B0%5D=incentive_type%
3A2794
Total incentives for HP HVAC -low-end $6,896
Total incentives for HP HVAC -high-end $17,535
Panel Rebates
IRA* $600
CityofSanMateo_CostData_Clean_V2.xlsx; backed up
by :
https://incentives.switchison.org/residents/incentives
?field_zipcode=93101&field_zipcodes1=93101&field_f
unctional_category=All&f%5B0%5D=incentive_type%
3A2794
Total incentives for Panel $600
Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Single-Family Electrification Rebates
Appliance Funder Incentive
Amount
Source
Whole-Home
Electrification
Credit (AllSystems)
CA Energy Smart Homes $5,500 https://incentives.switchison.org/rebateprofile/energy-smart-homes-whole-house-rebatesingle-family?view=residents&origin=directory Total Available for Whole-Home Electrification (No
Panel Electrification- Low Range) $17,416
Total Available for Whole-Home Electrification (No
Panel Electrification- High Range) $34,085
Total Available for Whole-Home Electrification (+
Panel Upgrade); low-range $16,816
Total Available for Whole-Home Electrification (+
Panel Upgrade); high-range $33,485
*Note that IRA; 3C-REN rebates may vary in timing and applicability of availability of funding. Costs displayed in this memo reflect incentives and rebates available in fall of 2023.

Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Additional Funding and Financing Strategies
In addition to the incentives listed above, some cities have begun developing additional incentives and programs to support adoption of electric appliances. Property-based pilot programs or incentives for individual appliances educate property owners on the benefits and drawbacks of electrification before major alterations or property sales occur.

Some of the residential electrification funding and financing strategies referenced in BE-5.13 and 5.14 may also apply to BE-5.5 and 5.6, and vice versa.

Rebates for Electrifying Gas Appliances in the City of Berkeley, CA Agency/Implementer: Local Government | Program Type: Rebates | Beneficiary: Homeowners The City of Berkeley adopted an ordinance in 2019 requiring new buildings and major renovations must be equipped with fully electric home appliances. The Berkeley legislation allowed residents with existing gas-powered appliances to keep them and helped connect those who wanted to make the switch of their own accord with rebates and resources to ease the process.44To reach lower-income residents, the City Council approved $600,000 out of the City’s general fund’s discretionary budget in 2022 to establish a Climate Equity Fund Pilot Program, which consists of several sustainability programs.45 Within that fund $100,000 is to cover necessary City staff hours.

Additionally, $250,000 is set aside for three contracts not to exceed $83,334 each with the Association for Energy Affordability, BlocPower, and Northern California Land Trust to run programs that identify and support low-income Berkeley residents in electrifying their homes and businesses.46,47
Property-Assessed Clean Energy (PACE) Financing
Agency/Implementer: Local Governments | Program Type: Assessment Districts | Beneficiary: Property Owners; Taxpayers
Property Assessed Clean Energy (PACE) is a financing mechanism that enables low-cost, long-term funding for energy efficiency, renewable energy, and water conservation projects. PACE financing is repaid as an assessment on the property’s regular tax bill and is processed the same way as other local public benefit assessments (sidewalks, sewers) have been for decades. Depending on local legislation, PACE can be used for commercial, non-profit, and residential properties. It is currently available for residents in the City of Santa Barbara.48,49 Block-level Residential Retrofits in Oakland’s EcoDistrict Agency/Implementer: Local Governments | Program Type: Assessment Districts; Neighborhood Trusts | Beneficiary: Property owners; Taxpayers
44 Berkeley first city in California to ban natural gas in new buildings 45 City of Berkeley Adopted Budget FY 2023 & 2024 46 City of Berkeley Council Report April 26,2022 47 Berkeley Climate Equity Action Fund 48 PACE FAQ
49 Strategic Energy Plan for the County of Santa Barbara Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Lowering GHG emissions at the community wide level is often left in the hands of individuals, which has been a major contributing factor to the relatively slow pace of the adoption of climatefriendly measures. EcoBlock aims to develop a framework under which the process of retrofitting residential blocks to be more sustainable and resilient is more cost effective, equitable, and efficient. In partnership with the City of Oakland, EcoBlock is developing a prototype of an energy efficient and resilient city block in lower-income neighborhoods in the city where residents are historically less empowered to make energy and water efficient upgrades to their homes. This pilot program combines sustainability actions like solar panels and energy efficient appliances with infrastructure like electric vehicle (EV) chargers, bike sharing systems, and street trees and aims to have six fully complete eco-districts by 2030.50
Approaches like EcoBlock are a great example of what can be accomplished when sustainability measures are leveraged with economies of scale, which can be accomplished and funded through established mechanisms like assessment districts and neighborhood level trusts. Assessment Districts are funded by a charge paid by property owners within the district to fund projects or services that provide direct benefits to properties in that district. A neighborhood trust is a nonprofit community-based fund that manages capital, operations, and maintenance related to energy efficiency projects. Funds for the trust are raised by the same community members that receive the benefits. Both approaches function in a similar way and are an effective way to leverage unique community priorities, expand access to potential grants, and save on implementation costs that are spread across an entire neighborhood rather than individuals.

As of October 2023, the initial goal of capping the neighborhood’s gas line was delayed by the opposition of ten of the 25-neighbors residing on the Fruitvale EcoBlock project site. However, voluntary home electrification, community EV car-sharing and curbside charging, and fast-tracked rooftop solar plus battery storage for the neighborhood has been a success, with construction being six months away from implementation by PG&E. There have also been a couple of pandemic-related supply chain shortages that slowed construction, and the initial vision for a microgrid was scaled back due to inflation. However, residents note that a major success of the program is relatively wide-spread support among the neighborhood for the program, which has been integral to the success so far.51, 52
Golden State Rebates
Agency/Implementer: CleaResult under contract by Investor Owned Utilities (SCE, PG&E SDG&E, SoCalGAS)| Program Type: Rebates | Beneficiary: Homeowners, Renters within Utility Service Territories
Funded by ratepayers, the program offers instant rebates through coupons for measures that increase the energy efficiency of single-family homes including replacement of gas heating or cooling pumps into electric. Coupons are provided to eligible buyers (SCE customers) who can then apply the coupons to their purchases at participating retailers.53 50 EcoBlock, University of California Berkeley
51 Electric Avenue: One Oakland Block’s Improbably Journey to Ditch Gas; Oct 30| KQED 52 Oakland Fund for Innovation, Ecoblock 53 Golden State Rebates Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

State of California GoGreen Home Energy Financing
Agency/Implementer: State Agencies | Program Type: Loans | Beneficiary: Homeowners; Renters within Utility Service Territories
The California Alternative Energy and Advanced Transportation Financing Authority (CAEATFA) partners with California Public Utilities Commission (CPUC) and California Hub for Energy Efficiency Financing (CHEEF) provide financing for eligible residential electrification and efficiency renovations. Eligible properties are those that receive service from SCE and include both singlefamily and multifamily housing (making this loan applicable for BE-5.13 and 5.14). Eligible projects include upgrades to ENERGY STAR accredited electric appliances.54 Interest rates are reduced in exchange to energy efficiency benefits and is capped using 10-year Treasury bonds plus 750 basis points. Maximum loan terms per unit is $50,000 for up to four units with a minimum of $2,500 (though this varies). GoGreen Home Energy Financing is available for affordable55 multifamily properties with five or more properties and businesses.

U.S. Department of Energy Clean Energy Tax Credits for Consumers Agency/Implementer: Federal Government | Program Type: Tax Credits | Beneficiary: Taxpayers The federal Inflation Reduction Act allocated $4.5 billion to tax credit programs for appliance electrification and other energy savings. The program is available to taxpayers—both homeowners and renters—from 2023 to 2032. Credit amounts are typically 30% of equipment costs with a cap depending on equipment type or energy efficiency upgrades including credits for home energy audits.56
U.S. Department of Energy Home Energy Rebate Program
Agency/Implementer: Federal and State Governments | Program Type: Rebates | Beneficiary:

Homeowners; Renters
As part of the Inflation Reduction Act, the US DOE allocated $582 million to the state of California to develop programs and accelerate deployment of clean energy technology. Half of the allocation is dedicated to help states develop home energy performance-based, whole-house rebates, called the Homeowner Managing Energy Savings (HOMES) rebate program. This grants rebates for retrofits ranging $2,000 (reduces energy use by 20% or more) to $4,000 (reduces energy use by 35% or more) per individual households and up to $400,000 per multifamily buildings in the states.

Rebates are increased if applied at retrofits for low- and moderate-income homes.

The other half of the allocated funds to the state is dedicated to high efficiency electric home rebates. This includes point-of-sale rebates administered by states (see coupon referenced above).

Total amount of rebate is adjusted based on the consumer’s area median income. Caps for certain equipment apply.57,58
54 Detailed list of eligible energy efficiency measures for GoGreen are found here. 55 At least 50% of the unites are income-restricted. 56 Clean Energy Tax Credits for Consumers | Department of Energy 57 HOME and High Efficiency Electric Home Rebate
58 Inflation Reduction Act Residential Energy Rebate Programs in California | California Energy Commission Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Measure/Action 3: Benchmarking and Incentives for Building Performance Standards
This measure and associated actions involve the creation of building performance standards (BPS) for commercial buildings over 20,000 square feet with residential components of mixed-use development exempted beyond state building energy code requirements for commercial construction:59 BE-6: Reduce Commercial Natural Gas Consumption 10% Below 2019 Levels by 2030 and 18% by 2035
BE-6.2: Develop and implement a commercial and mixed-use building benchmarking program for commercial buildings over 20,000 square feet in advance of state building performance standards. The program would include reporting electricity and natural gas usage data through the ENERGY STAR portfolio manager. Establish monetary penalties for non-compliance. Residential portions of buildings that are part of a mixed-use development would be exempt. Create incentives for buildings not covered to encourage voluntary compliance.

This action is largely based on the California Energy Commission which created a statewide benchmarking program mandated by Assembly Bill 802 (AB 802), which establishes a statewide program for benchmarking and publicly disclosing building energy use for commercial, multifamily, and mixed-use buildings 50,000 square feet or larger.60 Typically, local governments develop building performance standards (BPS) to require energy and water efficiency, electrification, and GHG emission reduction compliance amongst larger buildings including commercial developments. While BPS hold contractors and developers up to high standards, enforcement is currently difficult given the variability of commercial buildings and the complexity of commercial building systems. A building benchmarking program will allow the City and property owners to gather more data on commercial buildings over time, perform cost saving retro59 Among other requirements, the 2022 California Building Energy Code requires new commercial construction over 5,000 square feet to install PV and storage to meet 60% of the building’s energy load and reduce exports to 10%. 60 State Assembly Bill 802
Implementing a Building Efficiency Program at Brisbane, California The Brisbane Building Efficiency Program (BBEP) addresses energy and water use in existing buildings, making them more efficient, thereby saving owners money, improving the safety and comfort of building stock, and reducing emissions that are driving climate change. The City of Brisbane created a map-based, interactive dashboard that shows compliance status and results. At a later stage of the program, buildings at the City of Brisbane will need to show that they are high-performing or take steps to improve. Requirements advance state goals and will include buildings that are (1) privately owned and is 10,000 square feet or more OR (2) owned by a local agency of the State that is required to comply with the City's building ordinances pursuant to California State Government Code Section 53090, et seq., or successor legislation, and is 10,000 square feet or more OR (3) Owned by the City of Brisbane and is 2,000 square feet or more.

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commissioning, and ultimately plan for the most cost effective decarbonization strategy and its enforcement.

Benefits and Cost Considerations
Benefits
When energy benchmarking is done correctly and is followed up with action (e.g. energy efficiency and subsequent electrification retrofits), a building will end up with lower energy costs, lower maintenance costs, and better lighting and comfort. In a case study of 11 deep energy retrofits by the New Buildings Institute, buildings were estimated to see annual cost savings ranging from $8,000 to an annual payback period of 4-6 years.

The Aventine, a medium-sized office
building located in La Jolla was
profiled in a case study analyzing
existing building benchmarking and
retrofits. The building is LEED-EB
Platinum, with a 75% better than
baseline rating, and an Energy Star
Score of 100. As part of the retrofit,
the design team upgraded the
building’s HVAC to a high-efficiency
all-variable-speed chiller plant,
added controls for HVAC, and
lighting retrofits to CFLs with sensors. Following this retrofit, energy use dropped by 63%. In total, the cost of the retrofits at the Aventine retrofits was $801,540 before rebates (approx. $3.02/sf). The project received $175,000 in utility incentives for central plant upgrades and lighting retrofits resulting in a projected payback period of 2-4 years. The project reduced electricity use by over 2 million kWhs of in year one. First-year energy and operating expenses fell by $116,000 and the building saw a 600,000 MT CO2e reduction in carbon emissions.
61 Though the initial switch from gas to all-electric technologies may cost more today due to comparatively low costs for gas, analysis of long-term gas rate costs project that there will be multifold increase in gas rates by 2045. As more households and governments make the switch from gas to carbon-free electricity to achieve carbon neutrality goals, the prices to maintain the same network of natural gas pipelines is projected to increase as a lower amount of natural gas flows through the same infrastructure to a shrinking customer base. The remaining natural gas customer base will then bear the burden of rising natural gas costs. In fact, the analysis states that if the transition from the natural gas system is not managed, remaining customers on natural gas could experience costs of $19/therm of gas by 2050 (in comparison to $3/ therm in 2018). This future trend is shown below in Figure 7. 62 61 A Case for Deep Savings: 11 Case Studies of Deep Energy Retrofits, September 2011 | New Buildings Institute 62 California’s Gas System in Transition: Equitable, Affordable, Decarbonized, and Smaller, 2019 | Gridworks Creating Partnerships for Comprehensive Building
Performance Standards
As BPS is still a relatively new strategy, knowledge sharing is critical to achieve success. This is the motivation behind the White House’s Building Performance Standards Coalition, a partnership of state and local governments with an interest in developing comprehensive nationwide energy efficient building standards alongside the US Department of Energy. Together, the member organizations have nearly 20% of the nation’s building square footage in their jurisdictions, so the group has the potential to influence the pursuit of more sustainable building codes.

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Figure 7: Impacts of Decline in Gas Demand on Future Gas Rates Source: Gridworks, California’s Gas System in Transition (2019) From many perspectives—the state and local government as well as property owners, facility operators, manager, and designers—benchmarking facilitates energy accounting, comparing a facility’s energy use to similar facilities to assess opportunities for improvement, and quantifying/verifying energy savings. Commercial building energy performance benchmarking is a foundational element of a property owner’s or organization’s energy management strategy— management of energy requires measurements.
63 According to the US EPA, the public disclosure of energy efficiency ratings has influence over people’s behavior in their energy consumption. A benchmarking tool—like the free Portfolio Manager by ENERGY STAR64—is a way to evaluate these efficiencies.

Benefits to Community
Energy assessments and benchmarking can help building managers or owners in several ways including:
1) receiving expert advice on energy performance and energy-saving recommendations, 2) understanding energy performance over time compared to other buildings, 3) uncovering hidden problems that may be making the building less efficient, 63 Building Energy Use Benchmarking | Department of Energy 64 Benchmark Your Building Using ENERGY STAR® Portfolio Manager® | ENERGY STAR Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

4) identifying potential health and safety concerns,
5) futureproofing the building ahead of municipal or statewide benchmarking and disclosure requirements.65
By reducing a building’s energy use the owners can lower their energy bill, reduce greenhouse gas emissions, improve air quality, and gain recognition for being energy efficient.66Resilient and efficient buildings are essential to grappling with inconsistent and increasingly expensive energy supplies in the region. Building benchmarking and performance standards allow for a greater level of flexibility for building owners compared to a more prescriptive approach. This allow building owners to identify the most cost effective and beneficial actions for their individual buildings.

Benefits to City
Energy assessments and benchmarking can help futureproof the building ahead of municipal or statewide benchmarking and disclosure requirements.67 Benefits of benchmarking of building energy include actionable information to market actors, identification of investment opportunities, a proven strategy for energy savings, enhanced real estate values, and stimulation of the local economy through the creation of building construction and energy service jobs.68 Costs
While there are several benefits to assessing and benchmarking energy efficiency in large buildings, this process comes with additional difficulties. Property owners may benefit in ways to reduce energy efficiency but concerns with privacy and competitiveness in the market may need to be addressed before benefits are realized. For example, since the ENERGY STAR score is based on a building’s energy consumption compared to similar buildings, building owners may not want the public or their tenants to know the inefficiencies of an owner’s building as compared to another.

Another issue is the up-front cost and labor. Energy use data must be collected and uploaded into the ENERGY STAR Portfolio Manager database, as an example, before certain deadlines. This would be an additional task that would need to be handled by the property owner and eventually relayed to the tenants as part of an initiative to reduce energy use in the property. There would be potential need for outreach, and in areas with disadvantaged communities or communities where the primary language 65 NYSERDA, 2023 66 Ruff, 2016 67 NYSERDA, 2023 68 NEEP, 2023 Chula Vista’s Benchmarking Map Tool
In 2021, as part of its CAP, the City of Chula Vista adopted their Building Energy Saving Ordinance. It stipulates that multifamily, commercial, and industrial buildings must benchmark and report their energy use through a web platform managed by the Energy Star Portfolio Manager. That data is then visualized on a public-facing map platform where citizens can see the emissions and energy efficiency of large buildings. The data gathered by Energy Star is also used by the City to perform audits that ensure compliance.

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is not spoken in English, translators may be needed. The upfront cost of integrating benchmarking and assessment is not without added time, labor, and finances.

Additional costs would be incurred if the performance standard required infrastructure changes to meet thresholds over time. In this case, costs would be dependent on the type of upgrades employed and the specific building characteristics.

Costs to Community
Compiling energy data into energy star portfolio manager could be done by existing staff/building owners.. If the benchmarking program ultimately included GHG or energy consumption thresholds for buildings to meet, additional costs may be incurred. These costs would depend on the thresholds set, the equipment in the building, and the age of the building. The City should utilize the benchmarking data to complete a more detailed analysis of building costs when setting potential future GHG reduction thresholds for commercial buildings.

Costs to City
Building benchmarking programs require upfront costs to develop the program and ordinance language and long term staffing by the City. The upfront costs to develop the standard would include the development of an ordinance, research into setting thresholds for reductions, and outreach and engagement. Recent costs for consultant support for building benchmarking programs are estimated to be between $100,000 and $200,000 depending on the detail of the work. The City could expect to save some money by combining this with the existing building electrification study which would include much of the same research and information. The number of staff required to run the program will be based on the requirements of the standard itself as well as the number of buildings covered by the program. Figure 6 provides examples for the number of FTEs from several building performance standards from programs covering between 900 and 1,850 units. The City’s actual operating costs would depend on staff salaries.69 Figure 6 Staffing Examples from Several Cities with Building Performance Standards Jurisdiction Number of Covered
Properties
BPS Staff Budget (including nonpersonnel costs)
Montgomery
County MD
1,850 7 FTEs $1.1 million annually
St. Louis MO ~900 4 FTEs $299,600
Washington DC 1,662 in 1st compliance
cycle; increasing to
5,000 by 3rd cycle
7 FTEs $1.1-1.2 million
annually
Other Examples of Funding and Financing Strategies
Support for the City’s mission of increasing building performance is not limited to utility providers.

The federal and state governments offer a broad range of grant and loan programs accessible to property owners to modify and upgrade their properties to standards. As an example, federal funding was specifically allocated to the County through the state Department of Energy (DOE) in 2013. The 69 Putting Policy in Action: Building Performance Standard Implementation Guide (imt.org) Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Elective Municipal Programs to Optimize Water, Energy and Renewables (emPower) program was supported by $2.4 million in federal seed money funded through the United States’ DOE’s Better Buildings Neighborhood Program which encouraged energy efficient home upgrades through a combination of financing, rebates, and technical advising and training.70,71 A sampling of funding and financing strategies for these actions follow below. Previously referenced funding or financing programs for Measure BE-5 including those currently provided by SCE as part of the utility’s energy efficiency partnerships and program may be applicable to BE-6.2.

City of Boston’s Building Emissions Reduction and Disclosure Ordinance (BERDO) Enforcement Fund Agency/Implementer: Local Governments | Program Type: Enforcement Fund | Beneficiary: Property Owners including Members of Environmental Justice Communities The City of Boston updated its BPS, called BERDO, in 2021 to meet the City’s significant decarbonization goals.72 While stringent, Boston’s BPS allows for flexibility. For example, emission standards for mixed-use buildings will be calculated as a weighted average based on the square footage of each use. With approval from the City, owners of multiple properties can comply based on its portfolio-wide emissions, but every portfolio will need to reach carbon neutrality by 2050.

Property owners can also opt in a Hardship Compliance Plan.

Property owners who do not meet emissions targets can pay an “Alternative Compliance Payment” of $234 per metric ton of CO2e in excess of each building’s target. The resulting revenue will be used for an “Equitable Emissions Investment Fund”. This fund will be assigned to environmental justice communities that need help in upgrading energy performance to relevant buildings.73 A “Review Board”—consisting of members of environmental justice communities (defined by the State of Massachusetts) and community-based organizations—ensures benefits of the fund are realized by these communities. The “Review Board” will administer the fund.74 Washington DC’s Green Bank Commercial Loan for Energy Efficiency and Renewables (CLEER) Agency/Implementer: Investment Banks | Program Type: Loans | Beneficiary: Advisory Neighborhood Commissions (ANCs); Business and Property Owners; and Developers The District of Columbia set a Green Bank alongside its building energy performance standards. In partnership with the Montgomery County Green Bank, the DC Green Bank runs the Commercial Loan for Energy Efficiency and Renewables (CLEER) program for multifamily, commercial, and industrial buildings—targeting retrofits, renovations, and additions. The loans are complementary with other financing including DC’s PACE program and rebates from DC Sustainable Energy Utility.

Initial funding is granted by the DC Government in 2018. CLEER provides 100% financing for projects that provide energy savings of at least 15% of a building’s current consumption over a 12- month baseline.75
70 Empowering Santa Barbara to Invest in Upgrades | Department of Energy 71 SB County emPower | Final Program Report
72 Boston’s BPS require buildings containing 20,000 or more square feet of gross floor area meet a series of emissions intensity targets starting in 2025 and ending at carbon neutrality in 2050. 73 BERDO Review Board, November 2023 | City of Boston 74 More information on the City of Boston’s BERDO from the Institute for Market Transformation. 75 Related enhancements that are not energy improvements may account for up to 30% of the total project cost financed. CLEER – DC Green Bank
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Energy Services Agreements (ESA) or Energy Savings Performance Contracting (ESPC) Agency/Implementer: Utility Provider or Energy Service Company | Program Type: Performance Savings Agreements | Beneficiary: Property Owners
An ESA or ESPC may allow a facility owner—typically large buildings or group of buildings such as city, county, and state buildings; schools; hospitals; commercial office buildings; and multifamily buildings—to implement agreed upon building energy efficiency upgrades upfront at no cost by contracting with a third-party to pay for the building upgrades who then benefit from the building energy savings. Private, commercial facilities often do not employ ESAs since they require a strict payback threshold; however, this “pay today-earn tomorrow” approach applies to government facilities more directly given their long-term ownership of their facilities and their longer financing terms. The City may employ ESAs to evaluate building performance standards and energy conservation measures at municipally owned facilities—namely, municipal offices—prior to enacting the BPS citywide.76
California Energy Commission’s 1% Interest Loan Energy Conservation Assistance Act (ECAA) Agency/Implementer: State Agencies | Program Type: Loan | Beneficiary: Local Governments; Other Public Entities
ECAA is a revolving loan fund—loan repayments fund the program—for public schools and public entities seeking to finance energy efficiency, electric vehicle infrastructure, and energy generation or storage projects. Cities are eligible for a 1% interest loan program with a maximum loan amount of $3 million. Eligible projects vary but must have net energy savings and wholly owned by the applicant. While this loan assistance program does not fund the creation or implementation of building performance standards in the private, commercial sector, the City could use funds to pilot energy efficiency project that tests building performance standards set as part of BE-5.5 at Cityowned facilities such as municipal offices.77 California Energy Commission’s Energy Partnership Program Agency/Implementer: State Agencies | Program Type: Assistance Program | Beneficiary: Local Governments; Special Districts; Other Public Entities
The CEC provides technical assistance services (up to $20,000 of a consultant’s costs) to help local governments and public entities in the state to identify energy savings opportunities for existing properties and new construction including development of equipment performance specifications, design review consultations, selection of contractors or energy efficiency expertise.78 The program is competitive and requires participants who are seeking assistance to commit to energy efficiency recommendations and to provide plans to fund energy efficiency project recommendations. Like the ECAA and ESA, the City can incorporate lessons learned from the technical assistance as it adopts BPS for large commercial buildings.
76 Energy Savings Performance Contracting | Department of Energy 77CEC ECAA
78 Applicants with studies beyond $20,000 may opt in to share in the cost or reduce the scope.

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Measure/Action 4: Off-road Equipment Decarbonization
This measure and associated actions involve the decarbonization of off-road equipment:

T-8: Electrify or otherwise decarbonize 6% of off-road equipment by 2030 and 20% by 2035 T-8 includes the alignment or expansion of AB 1346 which California Governor Gavin Newsom signed a law in 2021 ordering state regulators to ban the sale of new gas-powered equipment using small offroad engines, which includes generators, lawn equipment, and pressure washers, to help curb emissions from a category of small engines on pace to produce more pollution each year than passenger vehicles. This law orders regulators to offer rebates for people to replace their equipment and aims to electrify the landscaping business. These regulations are set to apply to engines produced on or after January 1, 2024.79 Other actions associated to the measure include education and outreach to local employers and City staff regarding the transition to zero-emission off-road equipment.

Benefits and Cost Considerations
Benefits
Off-road emissions make up 7% of the City of Santa Barbara’s overall GHG emissions profile (~44,000 MT CO2e). In addition, according to the California Air Resources Board, off-road equipment makes up the single largest source of mobile air pollution emissions in the state of California.80 Electrification of these end uses will reduce both GHG emissions and air pollution providing substantial health benefits for the community.

There is a wide range in the size and function of off-road equipment, ranging from large construction equipment to small lawn equipment. While adoption, operations, and maintenance of smaller offroad equipment like electric lawnmowers can be easily adopted at near cost-parity with existing gas alternatives, others like large construction equipment will likely require additional incentives to ease the cost burden of decarbonization.81 The State of California has already started making moves to increase incentives for large off-road equipment decarbonization through programs like the California Air Resources Board (CARB) Clean Off-Road Equipment Vouchers, which has allocated $273 million to incentivize California fleets to purchase or lease cleaner offroad equipment.82 Benefits to Community
Communities will benefit from reducing air pollution when converting to electric off-road equipment through vouchers and incentive programs. The diesel off-road equipment adds to the vehicle exhaust and poor air quality that is a precursor to lung and heart diseases, and an issue to tackle for both residents and the larger community. Construction with smaller electric construction vehicles could be applicable in settings where diesel vehicles were impractical, such 79 Air Pollution: small off-road engines, 2021 | Legiscan 80 https://ww2.arb.ca.gov/resources/documents/off-road-equipmentresearch#:~:text=Under%20current%20regulations%2C%20off%2Droad,of%20mobile%20emissions%20in%20California. 81 Gas vs. Electric Lawn Mower: Which Is Better? May 2023 | Consumer Reports 82 Funding for Fiscal Year 2022-2023. Project Background for Clean Off-Road Equipment Vouchers | California Air Resources Board Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

as indoor settings, orchards, and fish hatcheries.83 The operation of electric alternatives can also be substantially lower.84
Benefits to City
Providing cleaner air to the community is beneficial to the City and County following the County’s Regional Transportation Plan and agenda towards emissions reduction. Recently, some municipalities have passed propositions to alleviate property owners from the responsibility of maintaining sidewalks and street trees, shifting the responsibilities to cities and their operating engineers. Studies have shown that operating engineers (those that operate and maintain heavy construction equipment) have higher potential for exposure to numerous hazards includes wholebody vibration, dust, diesel exhaust, and noise.85 Electric off-road equipment would help to prevent many of the complications operating engineers would face if diesel equipment were replaced.

Costs
Although there are several benefits to off-road equipment, there are also several barriers and drawbacks to electrifying off-road vehicles. Benchmarking costs and performance of vehicles would be vital to improving product development and system operations. The federal government must continue to play a central role in convening diverse stakeholders, conducting foundational precompetitive research, development, and deployment, and coordinating case studies and technology validations to advance the industry.
86 Due to the numerous types of vehicles, the off-road sector has few one-size-fits-all solutions which does not allow for streamlined production of electrified vehicles, but rather would need high levels of customization.
87 A challenge to transitioning into electric equipment is ensuring capacity and availability of charging infrastructure.88 Additionally, grid support and stability will be necessary to evaluate, and municipalities and utilities would need to continuously find solutions and assess grid infrastructure.

Charging infrastructure varies between offroad equipment types. For example, large frequently used equipment may require similar chargers to electric on-road vehicles. However, the regulation referenced in this measure covers small motors which would use 110v electrical outlets common in every building. In the example of a commercial-electric lawn mower, initially higher costs are ultimately offset by the reduced maintenance costs (e.g. electric mowers don’t have belts, oil changes, etc.) and lower operation costs, meaning that the payback period for making the switch from gas to electric lawnmowers can be as short as two years.89
Costs to Community
In California, current off-road engines are focused on smaller, but highly polluting engine tools such as leaf blowers and lawn mowers. In the City of Santa Barbara, those tools are used primarily 83 Volvo Construction Equipment, 2021
84 https://www.fleetequipmentmag.com/electric-yard-trucks-cost/ 85 Whole-Body Vibration and Postural Stress among Operators of Construction Equipment: A Literature Review (cdc.gov) 86 Solutions Emerge for Decarbonizing Historically Difficult Off-Road Vehicle Sector | NREL, 2022 87 Off-Road Vehicle Decarbonization and Energy Systems Integration | NREL, 2022 88 Volvo Construction Equipment
89 Benefits of Electric Riding Lawn Mowers, Gravely
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for single-family household lawns and in the hotel industry, one of Santa Barbara County and City’s top employing industries.90 Figure 7 provides example costs of electric small off-road engines (SORE) rated at or below 25 horsepower. Costs vary by equipment with most being cost comparable (and much less cost to operate). Some equipment like larger mowers can incur more substantial marginal costs and is a good place to identify rebates or incentives. Long term cost savings should be seen for most if not all equipment similar to electric vehicles.91 It has been shown that operating an electric lawn mower would cost 32 times less than a gas lawn mower, according to some estimates leading to a payback period of around two years. 92 Electric
equipment needs no oil, no fuel mixing, minimal to no maintenance, and is cheaper to fuel than gas equipment.

Figure 7 Small Combustion Engine Electrification Upfront Cost Examples Equipment Gas Costs Cost source Electric
Cost Cost Source Marginal Cost
Soft
wash/Power
washer
$350 https://shorturl.at/fwIR0 $400 https://shorturl.at/t DJR7
$50
Zero turn
lawn mowers $3,800 https://shorturl.at/inJ69 $6,000
https://shorturl.at/
oxJNT $2,200
Residential
lawn mowers* $550 https://shorturl.at/uwSZ5
$500
https://tinyurl.com
/yfmpu32a
-$50
Leaf blowers $274 https://tinyurl.com/c57ksc
8w $250
https://tinyurl.com
/yzshseyr -$24
*Note that electric lawn mowers up to commercial size, likely have a payback period of up to two years [see reference above], depending on use case.
90 Major Employers in Santa Barbara County | State of California, 2023 91 https://thehill.com/changing-america/sustainability/energy/559971-finally-heres-the-exact-cost-of-owning-an-electric-car/ 92 https://smartenergy.illinois.edu/electric-lawn-mowers/ Appendix C - City of Santa Barbara CAP Costs and Benefits of Selected Actions - DRAFT Last Updated: June 20, 2024

Costs to City
The largest cost to the City is likely to be enforcement. Successfully implementing an off-road vehicle electrification requirement would require some level of enforcement for those who continue to operate fossil fuel equipment. This could be one or multiple FTEs, or potentially covered by existing code enforcement staff. As these types of municipal programs are largely in their exploratory stage across the State, the City should continue to monitor statewide and existing examples staffing and enforcement models for these types of enforcement and programming strategies.

Possible Funding and Financing Strategies
Transition into zero-emissions off-road equipment will require coordination and outreach efforts on behalf of the City to connect the users of machinery and equipment with applicable funding opportunities. The City itself will require additional funds to replace its existing fossil-fuel powered equipment alongside local enterprises. Some of the costs of vehicle replacement and the charging infrastructure can be recouped through specifically earmarked grant programs from state and federal governments. Existing partnerships with the Santa Barbara Air Pollution Control District can be leveraged for the creation of rebate and incentive programs. Examples below show possible funding and financing strategies for the City and independent, private operators.

County of Santa Barbara and Santa Barbara Air Pollution Control District (the District) Vehicle Replacement Grants and Local Charger Infrastructure
Agency/Implementer: Local Government; Local Air Districts | Program Type: Grants | Beneficiary:

Local Businesses; Local Governments; Other Public/Private Entities The District offers grants for replacing vehicles for lower-emissions options including off-road vehicles and agriculture equipment ranging in amount from $10,000 to $250,000. While the 2022 application window has closed, the 2023 grant categories should be announced in the coming months and will likely include similar project eligibility requirements.93 Though not dedicated to off-road equipment, the District pledged close to $150,000 for the expansion of local charger infrastructure in the County of Santa Barbara, which the County matched with about $60,000 in 93 Clean Air Grants for Off-Road Equipment | Santa Barbara County Air Pollution Control District (ourair.org) Heavy Duty Equipment and Infrastructure Enhancements in Los Angeles, California The Electric Crane Project for cargo handling equipment at the Port of Los Angeles has reduced crane emissions by 100%. A 1987 diesel ship-loading crane was replaced with a Liebherr 550 electric crane which has helped eliminate air pollutants such as nitrogen oxides, particulate matter, hydrocarbons, carbon monoxide, and GHG. The new electric crane is the Port of Los Angeles’ first electric mobile ship-loading crane for non-container cargo, an important step in the port’s goal of becoming a zero-emission green port.

Just the particulate matter emission eliminated from this replacement is equivalent to taking 3,400 heavy duty trucks off the road for a year. The funding for this project came from the EPA which granted a total of $1.3 million of Diesel Emission Reduction Act (DERA) funding.

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funding for the goal.94 This charging infrastructure will be pivotal for the success of T-8 and similar zero-emissions vehicle measures.

California Air Resources Board (CARB) Funding Agricultural Replacement Measures for Emission Reductions (FARMER) Program
Agency/Implementer: State Agencies; Local Air Districts | Program Type: Formula Grant | Beneficiary:

Farmers; Agricultural Businesses
The California Air Resource Board (CARB) FARMER Program funds the replacement of agricultural equipment with zero emissions replacements. Applications are evaluated on a case-by-case basis by CARB staff and grant funds are allocated to regional air districts before they are awarded to applicants. Eligible applicants must work entirely within the boundaries of the air district and project equipment can include off-road vehicles, tractors, irrigation pump engines, and other equipment used entirely for agricultural purposes.95
California Air Resources Board (CARB) Clean Off-Road Equipment (CORE) Voucher Agency/Implementer: State Agencies; Local Air Districts | Program Type: Formula Grant | Beneficiary:

Farmers; Agricultural Businesses
The State through CARB implemented the Clean Off-Road Equipment Voucher Incentive Project (CORE), which is a part of the California Climate Investments, a statewide initiative allocating billions of cap-and-trade dollars. The program provides funds for the replacement of heavy-duty and off-road equipment with zero-emissions models for California businesses. Specific funds are set aside to support micro and small businesses and can be used to purchase equipment from lawnmowers to construction equipment. CORE voucher amounts are tailored by the cost premium of new zero-emission alternatives over traditional equipment. 96 The program provides additional funding is available for charging infrastructure and equipment deployed in pollutionoverburdened and low-income communities.97 California Air Resources Board (CARB) Carl Moyer Program Lawn and Garden Equipment Replacement
Agency/Implementer: State Agencies; Local Air Districts | Program Type: Formula Grant | Beneficiary:

Individuals; Business Owners
94 County launches move to electric vehicle fleet; first 56 EVs to hit road by summer | Government and Politics | syvnews.com 95 Funding sources for the FARMER program varies including the state’s Air Pollution Fund, the Greenhouse Gas Reduction Fund, among others. More information at California Air Resource Board (CARB) FARMER Program. 96 California Off-Road - Advanced Clean Equipment | California Air Resources Board 97 Low-income communities as defined by AB1550
Agricultural Equipment Penetration Rates in California
A CalStart Technology and Market Assessment has shown that smaller and lightweight agricultural equipment are feasible to electrify for off-road equipment. While the number of electric tractors in the field to-date is small, penetration of zero- or low-emission agricultural equipment is expected to grow. In California, it is estimated that 12% of annual tractor sales will be batteryelectric by 2029 with another 8% being hybrid electric.

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In partnership with local air districts, CARB runs the Carl Moyer Program through which it funds fleet upgrades and replacement incentives for eligible equipment like heavy-duty trucks, emergency vehicles, solid waste collection vehicles, and charging infrastructure. The program has a Lawn and Garden Equipment (LG&E) Replacement program which provides California residents who own and operate existing combustion LG&E funds to replace or acquire batteries for electric LG&E. The program allows for bulk purchasing. Maximum funding amounts are set by equipment type and differ between residential and commercial users with a maximum amount of $15,000 for commercial ride-on or stand/site mowers.98
Disclaimer
Notice to Reader
This memo was prepared by Hatch and Rincon Consultants for the sole and exclusive use of the City of Santa Barbara (the “Client”). Hatch acknowledges that this report may be provided to third parties provided that all such parties shall rely upon this memo at their own risk and shall (by virtue of their receipt of the report) be deemed to have (a) acknowledged that Hatch shall not have any liability to any party other than the Client in respect of the report and (b) waived and released Hatch from any liability in connection with the report.

This report contains the expression of the opinion of Hatch using its professional judgment and reasonable care based on information available and conditions existing at the time of preparation.

The use of or reliance upon this report is subject to the following:
• this memo is to be read in the context of and subject to the terms of the relevant services agreement between Hatch and Rincon Consultants Inc., including any methodologies, procedures, techniques, assumptions, and other relevant terms or conditions specified in the services sub-agreement;
• this memo is meant to be read as a whole, and sections of the report must not be read or relied upon out of context; and
• unless expressly stated otherwise in this report, Hatch has not verified the accuracy, completeness or validity of any information provided to Hatch by the Client and the Prime and Hatch does not accept any liability in connection with such information. 98 CARB Carl Moyer Program
Master Environmental Assessment Guidelines
for Greenhouse Gas Emissions Analysis
Final Draft
prepared by
City of Santa Barbara
Sustainability and Resilience Department
801 Garden Street, Suite 200
Santa Barbara, California 93101
prepared with assistance from
Rincon Consultants, Inc.
319 East Carrillo Street, Suite 105
Santa Barbara, California 93101
May 2024
ATTACHMENT 5

Table of Contents
Final Draft i
Table of Contents
1 Introduction .................................................................................................................................... 1

1.1 GHG Emissions Analyses Under CEQA ................................................................................ 1

1.2 Qualified GHG Emissions Reduction Plan ........................................................................... 2 2 Determining Consistency with the CAP Update ............................................................................. 5

2.1 Step 1: CEQA Exemption ..................................................................................................... 7

2.2 Step 2: Consistency with Demographic Forecasts and Land Use Assumptions .................. 7

2.3 Step 3: Consistency with CEQA GHG Checklist ................................................................... 9 3 CEQA GHG Checklist .....................................................................................................................11

3.1 Application Submittal Requirements ................................................................................11 4 Quantitative CEQA GHG Thresholds .............................................................................................15

4.1 Thresholds Calculation Methodology ...............................................................................15

4.2 Thresholds and Use ...........................................................................................................18 5 Moving into the Future .................................................................................................................21 Tables
Table 1 CAP Consistency with CEQA Guidelines Section 15183.5(b)(1) for 2030 ........................... 3 Table 2 City of Santa Barbara Demographic Projections ...............................................................17 Table 3 City of Santa Barbara 2030 CAP Update-Adjusted Emissions and Communitywide GHG Thresholds .........................................................................................................................17 Table 4 City of Santa Barbara Locally Applicable Project CEQA GHG Emissions Thresholds .........19 Figures
Figure 1 Determining Consistency with the the CAP Update ............................................................ 5 Figure 2 Allowable GHG Emissions from Existing and New Development in 2030 ......................... 16 Figure 3 City of Santa Barbara GHG Efficiency Thresholds .............................................................. 18 Appendices
Appendix A Climate Action Plan Summary
Appendix B Overview of GHG Emissions and Climate Change Appendix C Quantifying GHG Emissions
Appendix D Regulatory and Legal Setting
Appendix E CEQA GHG Threshold Calculations
Appendix F Justification for Thresholds
Appendix G United States Green Building Council Building Area per Employee by Business Type Rates

Introduction
Final Draft 1
1 Introduction

1.1 GHG Emissions Analyses Under CEQA
The California Environmental Quality Act (CEQA) requires discretionary plans and projects to undergo an environmental review process, which includes an evaluation of project-related1 contribution of greenhouse gas (GHG) emissions. Section 15183.5 of the CEQA Guidelines establishes a framework for developing a qualified GHG emissions reduction plan to cumulatively reduce GHG emissions and allow CEQA lead agencies to analyze and mitigate the effects of planand project-level GHG emissions. This document is intended to provide methodological guidance and quantitative thresholds of significance for use by City planners, project applicants, consultants, agencies, and members of the public in the preparation of GHG emissions analyses under CEQA for projects located within the City of Santa Barbara (City).

The City prepared a Climate Action Plan (CAP) Update designed to be consistent with CEQA Guidelines Section 15183.5. See Appendix A Climate Action Plan Summary for more background information on the CAP Update process and the GHG emissions inventories, reduction strategies, and forecasts developed as part of the process. As required by Section 15183.5, the City updated the CAP with targets that are consistent with or exceed state goals. The CAP Update establishes a goal of achieving a 40 percent reduction in per capita GHG emissions compared to 1990 levels by 2030 (consistent with California Senate Bill [SB] 32) and a goal of achieving carbon neutrality by 2035 (ten years sooner than Assembly Bill [AB] 1279 goal of carbon neutrality by 2045).2 The 2030 goal is set using efficiency metrics (i.e., GHG emissions expressed as a per-capita metric) translated to a total GHG emission reduction target. In California Air Resource Board’s (CARB’s) 2017 Scoping Plan Update, the State recommends using efficiency metrics for local targets to avoid penalizing cities which are experiencing population growth at significant rates.3 Efficiency metrics still calculate GHG emissions on a per capita basis but are combined into a total GHG emission reduction goal. The State continues to recommend use of efficiency metrics in the 2022 Scoping Plan. The City’s goals translate to a short-term target of reducing communitywide GHG emissions to 486,949 metric tons of carbon dioxide equivalent (MT of CO2e)4 by 2030 and zero MT CO2e by 2035.5 In addition to meeting or exceeding State goals, a qualified GHG emissions reduction plan must undergo CEQA review and must be adopted by local decision makers. An Initial Study-Negative Declaration (IS-ND) was prepared for the CAP Update. With adoption of the CAP Update IS-ND and approval of the CAP Update by City Council, the CAP Update serves as a qualified GHG emissions 1 Project refers to the definition of a project under the California Environmental Quality Act within the CEQA Guidelines Section 15378 and Public Resources Code Section 21065.
2 Carbon neutrality is defined as net zero carbon emissions, which is achieved either by balancing carbon emissions with carbon removal or by completely eliminating carbon emissions.
3 California Air Resources Board. 2017. California’s Climate Change Scoping Plan, p. 99-102. 4 Different types of GHGs have varying global warming potentials (GWPs). The GWP of a GHG is the potential of a gas or aerosol to trap heat in the atmosphere over a specified timescale (generally, 100 years). Because GHGs absorb different amounts of heat, a common reference gas, CO2, is used to relate the amount of heat absorbed to the amount of the gas emissions, referred to as carbon dioxide equivalent (CO2e), and is the amount of a GHG emitted multiplied by its GWP. Carbon dioxide has a 100-year GWP of one. By contrast, methane has a GWP of 25, meaning its global warming effect is 25 times greater than CO2 on a molecule per molecule basis (Intergovernmental Panel on Climate Change 2007).
5 The 2030 target was calculated by reducing 1990 per capita GHG emissions (i.e., 8.40 MT CO2e/person) by 40 percent (providing a 2030 per capita target of 5.04 MT CO2e/person) and multiplying the resulting 2030 per capita target by Santa Barbara’s projected population in 2030 (i.e., 96,637 people). The result of the calculation provides a 2030 target for the City of 486,949 MT CO2e.

City of Santa Barbara
Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis 2 reduction plan consistent with CEQA Guidelines Section 15183.5. Appendix B, Overview of GHG Emissions and Climate Change, offers an overview of relevant regulations and case law pertaining to the analysis of GHG emissions consistent with the CEQA Statute and Guidelines.

Projects that are substantially consistent with the underlying demographic projections (i.e., residents and employees) and land use assumptions used in the CAP Update will be able to tier from the adopted CAP Update IS-ND pursuant to CEQA Guidelines Section 15183.5. The CAP Update relied on the Santa Barbara County Association of Governments (SBCAG) Connected 2050 projections and the land use assumptions for existing uses and densities allowed by land use designations in the City of Santa Barbara General Plan, including the Land Use Element and any associated amendments current as of 2023, and the 2023-2031 Housing Element. In addition, the assumptions account for the maximum buildout allowed by existing zoning districts, zoning overlays, and municipal code ordinances that increase density on top of the baseline density. To streamline the CEQA GHG emissions analysis process, the City has prepared a CEQA GHG Checklist that can be used in CEQA review documents to confirm that such proposed projects are consistent with the CAP Update GHG emissions reduction strategy. Section 2 of this document, Determining Consistency with the CAP Update and Section 3 of this document, CEQA GHG Checklist, include guidance on how to navigate the consistency determination process.

For projects that exceed the CAP Update’s demographic projections and assumptions based on existing land use designations and existing maximum densities allowed by zoning, including zoning ordinances as of 2023 related to housing overlays, multi-unit housing, and accessory dwelling units, a different methodology and assessment utilizing quantitative thresholds of significance would be necessary to evaluate GHG emissions impacts. Section 4 of this document, Quantitative CEQA GHG Thresholds, includes guidance on how to utilize the quantitative thresholds that were developed for purposes of evaluating the level of significance of GHG emissions impacts. Furthermore, Appendix C, Quantifying GHG Emissions, provides direction regarding how to quantify a project’s GHG emissions for comparison to the applicable threshold of significance.

The CAP Update acknowledges that additional actions beyond those identified in the plan will be required to achieve its long-term goal of carbon neutrality by 2035. As a result, the plan provides mechanisms for monitoring CAP Update progress which include providing the Sustainability Committee an annual update on progress, conducting regular GHG emission inventories, and preparing a new CAP Update by 2030 in order to incorporate new strategies and technologies that will further move the City toward meeting its longer-term carbon neutrality target. Section 5 of this document, Moving into the Future, offers further explanation of how CEQA review of plans and projects could be affected by future updates of the CAP Update.

1.2 Qualified GHG Emissions Reduction Plan
According to CEQA Guidelines Section 15183.5, a CEQA Lead Agency can determine that a project consistent with the CAP Update has GHG impacts that were already assessed as part of the CAP Update’s CEQA document. Project-specific environmental documents can tier from, or incorporate by reference, the CAP Update CEQA document when the project is deemed consistent with the GHG emissions reduction strategy included in the qualified GHG emissions reduction plan.

Introduction
Final Draft 3
As shown in Table 1, the CAP Update meets the requirements of a qualified GHG emissions reduction plan per CEQA Guidelines Section 15183.5(b)(1) for projects with buildout years through 2030.

Table 1 CAP Consistency with CEQA Guidelines Section 15183.5(b)(1) for 2030 CEQA Guidelines Section
15183.5(b)(1) Requirement1 Climate Action Plan Consistency

1. Quantify GHG emissions, both
existing and projected over a
specified time period, resulting
from activities within a defined
geographic area.

Consistent. The CAP Update includes a communitywide GHG emissions inventory for year 2019 and forecasts GHG emissions for years 2025, 2030, 2035, 2040 and 2045.

2. Establish a level, based on
substantial evidence, below which
the contribution to GHG emissions
from activities covered by the plan
would not be cumulatively
considerable.

Consistent. A key aspect of a qualified GHG emissions reduction plan is substantial evidence that the identified GHG emissions reduction target establishes a threshold where GHG emissions are not cumulatively considerable. The Association of Environmental Professionals’ (AEP) 2016 Beyond Newhall and 2020 white paper identifies this threshold as being a local target that aligns with the State legislative targets.1 The CAP Update establishes a long-term aspirational target of carbon neutrality by 2035 and short-term target equivalent to reducing GHG emissions 40 percent below 1990 per capita levels by 2030. As discussed in Appendix A, Climate Action Plan Summary, the plan’s measures will exceed the short-term target and reduce total communitywide GHG emissions 47 percent below 1990 emissions levels by 2030. Therefore, this local target meets the state goals of a 40 percent emission reduction in 1990 levels by 2030.

3. Identify and analyze the GHG
emissions resulting from specific
actions or categories of actions
anticipated within the geographic
area.

Consistent. The CAP Update divides its inventory and forecasts into sectors including transportation (passenger vehicles, commercial vehicles, buses, and off-road equipment), residential energy (electricity and natural gas), nonresidential energy (electricity and natural gas), water and wastewater, and solid waste.

4. Specify measures or a group of
measures, including performance
standards, that substantial
evidence demonstrates, if
implemented on a project-byproject basis, would collectively achieve the specified emissions
level.

Consistent. The CAP Update specifies measures and actions that the City will enact and implement between 2024 and 2030 to meet its 2030 GHG emissions target. As discussed in Appendix A, Climate Action Plan Summary, implementation of the plan will achieve a 47 percent reduction in total GHG emissions compared to 1990 emission levels by 2030, which exceeds the state goal of a 40 percent emission reduction in 1990 levels by 2030 and demonstrates substantial progress by 2030 toward achieving the City’s longerterm goal of carbon neutrality by 2035.

5. Establish a mechanism to monitor
the plan’s progress toward
achieving the level and to require
amendment if the plan is not
achieving specified levels.

Consistent. The CAP Update includes a process to complete community GHG emissions inventories every three years. The inventories will allow the City to measure progress towards meeting the CAP Update goals. If an inventory indicates that the City is not on track to meet the CAP Update GHG emissions targets, additional measures may be required at that time to increase emissions reduction strategies and maintain the CAP Update status as a CEQA qualified GHG emissions reduction plan.

6. Be adopted in a public process
following environmental review.

Consistent. The City prepared an IS-ND for the CAP Update that was circulated for public review and comment and adopted prior to approval of the CAP Update Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis by City Council.
1 AEP. Beyond Newhall and 2020: A Field Guide to New CEQA Greenhouse Gas Thresholds and Climate Action Plan Targets in California (October 2016). Accessed at: https://califaep.org/docs/AEP-2016_Final_White_Paper.pdf.

City of Santa Barbara
Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis 4 Development projects can demonstrate consistency with a qualified GHG emissions reduction plan if they are consistent with the plan’s assumptions regarding future growth projections and consistent with the plan’s GHG emissions reduction strategies.6 Projects consistent with the qualified GHG emissions reduction plan such as the CAP Update, including conformance with performance strategies applicable to the project, would not require additional GHG emissions analysis or mitigation under CEQA Guidelines Sections 15064(h) and 15183.5(b)(2). The City has developed the CEQA GHG Checklist to assist with determining project consistency with the CAP. The checklist is intended to provide individual projects the opportunity to demonstrate that they are minimizing GHG emissions while ensuring new development achieves its proportion of emissions reduction consistent with the assumptions of the CAP Update. Project consistency with a GHG emissions reduction plan can also be demonstrated through a quantitative analysis that demonstrates the project will not impede, or will facilitate, the City’s ability to meet its GHG emissions reduction targets.
6 CAPs typically use growth projections from the local jurisdiction’s General Plan or applicable Metropolitan Planning Organization’s regional demographic forecast.

Determining Consistency with the CAP Update
Final Draft 5
2 Determining Consistency with the CAP
Update
Projects that are 1) not exempt from CEQA, and 2) consistent with the demographic forecasts and land use assumptions in the CAP Update can use the City’s CEQA GHG Checklist to demonstrate consistency with the CAP Update measures and actions. If consistent, projects can tier from the environmental review contained in the CAP Update IS-ND. In doing so, these projects would result in less-than-significant GHG emissions and would not result in a cumulatively considerable GHG emissions impact. The following process (see Figure 1) shows how to demonstrate a project’s consistency with the CAP Update’s GHG emissions reduction plan and, thereby, tier from the IS-ND for the CAP Update. This approach is consistent with the recommendations of the AEP Climate Change Committee7 for tiering from qualified GHG reduction plans that demonstrate substantial progress toward meeting the next milestone statewide planning reduction target (i.e., a 40 percent reduction below 1990 levels by 2030 as set forth by SB 32). 7 Association of Environmental Professionals (AEP). 2015. Beyond 2020: The Challenge of Greenhouse Gas Reduction Planning by Local Governments in California. https://califaep.org/docs/AEP_White_Paper_Beyond_2020.pdf City of Santa Barbara
Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis 6 Figure 1 Determining Consistency with the the CAP Update Determining Consistency with the CAP Update
Final Draft 7
The following sections provide guidance for each step to determine project consistency with the CAP Update.

2.1 Step 1: CEQA Exemption
Step 1 consists of evaluating whether or not the project qualifies for any applicable exemption under CEQA. If the project qualifies for an exemption, no further action is required. If the project does not qualify for an exemption, then the lead agency would move to Step 2. The State CEQA Statute and Guidelines define types of projects that may be exempt from environmental review. A project that is exempt from CEQA is not required to undertake a consistency determination with the CAP Update. Statutory exemptions are enacted by the State Legislature based on policy goals and apply regardless of whether the exempted project or class of projects may have environmental impacts. Statutory exemptions that do not require a CAP Update consistency determination include those in the State CEQA Guidelines, Sections 15194, 15195, 15196, and 15261-15285. Within the CEQA Statute, statutory exemptions that do not require a CAP Update consistency determination include, but are not limited to, Public Resources Code (PRC) Section 21080 et seq., Section 21159.20 et seq. for special housing exemptions, and Section 21155.1 for Senate Bill 375 transit priority projects. Categorical exemptions are granted to classes of projects that generally are considered not to have any potential impacts on the environment. Projects that meet criteria for an exemption under State CEQA Guidelines Sections 15301-15333 do not require a consistency determination with the CAP Update. Further, ministerial projects and categorical exemptions defined in the City CEQA Ordinance, Santa Barbara Municipal Code 22.100.070 do not require a consistency determination with the CAP Update. The State CEQA Guidelines also codify the “common sense” exemption. This exemption can be used for projects “[w]here it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment.” Projects that meet criteria for an exemption under State CEQA Guidelines Section 15061[b][3]) do not require a consistency determination with the CAP Update and do not require completion of a CEQA GHG Checklist.

Please note projects subject to the following CEQA processes must proceed to Step 2:

1. Projects using the CEQA Streamlining process under CEQA Guidelines Section 15183, Projects Consistent with a Community Plan, General Plan, or Zoning.

2. Projects that require preparation of an Addenda to tier from a previously certified Environmental Impact Report or adopted Negative Declaration.

3. Projects that require preparation of an Initial Study or are not otherwise exempt from CEQA, including projects that require a Negative Declaration or Environmental Impact Report.

2.2 Step 2: New Development Project or Substantial
Redevelopment Project
Step 2 consists of determining if the project involves new or substantially redeveloped residential, commercial, or mixed-use buildings, or additions of more than 2,000 square feet in building floor area to existing residential, commercial, or mixed-use buildings. If the project is considered one of the following criteria, then the project screening would continue to Step 3:

1. A new development project that includes a residential, commercial or mixed-use building(s), or
City of Santa Barbara
Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis 8 2. A substantial redevelopment project that includes a residential, commercial or mixed-use building(s), or

3. An addition of over 2,000 square feet in building floor area for residential, commercial or mixed-use building(s).

If the project does not meet the above criteria, then the project can qualitatively be assumed to be consistent with the CAP Update without using the CEQA GHG Checklist and completion of a CEQA GHG Checklist is not required. Industrial uses that are not otherwise exempt from CEQA (Step 1) must conduct a project specific GHG quantitative analysis to determine significance and cannot streamline review with this checklist.

2.3 Step 3: Consistency with Demographic Forecasts
and Land Use Assumptions
The demographic forecasts of the CAP Update are based on both the SBCAG demographic forecasts and the growth projected in the City’s General Plan. If a project is consistent with the existing General Plan land use designation and maximum densities allowed by existing zoning as identified in the Santa Barbara General Plan and Santa Barbara Municipal Code and as allowed by state density bonus8, then the project is consistent with the business-as-usual demographic forecasts and land use assumptions of the CAP Update and can move on to Step 4. In such cases, the project’s associated GHG emissions were accounted for in the GHG emissions forecasts included in the CAP Update and, therefore, are within the scope of this plan’s analysis of communitywide GHG emissions. Accordingly, the analysis of the project’s GHG emissions in its CEQA document should include a reference to the project’s consistency with the existing General Plan land use designation and zoning, of the project site/area and should explain the aforementioned connection between the existing General Plan land use designation and the GHG emissions forecasts in the CAP Update.

After this is completed, the lead agency can proceed to Step 4.

If a project is not consistent with the existing General Plan land use designations and densities allowed by zoning and the state, will require a zoning or general plan amendment, but would (1) result in equivalent or fewer GHG emissions as compared the development anticipated for the site under the City’s existing General Plan and zoning9, then the project would still be within the demographic forecasts and land use assumptions of the CAP Update and can move on to Step 4. To provide substantial evidence for this determination of fewer GHG emissions, GHG emissions generated under existing General Plan land use buildout and the proposed project need to be quantified and included in the CEQA analysis. See Appendix C, Quantifying GHG Emissions, for guidance on quantifying GHG emissions for existing General Plan land use buildout and the proposed project. In this case, the analysis of the project’s GHG emissions in its CEQA document should include a quantitative comparison of the proposed project’s GHG emissions and GHG emissions generated by the development anticipated for the site under the City’s existing General Plan land use and zoning designations. The analysis should clearly explain how the project’s emissions with the proposed General Plan Land Use or zoning changes are equivalent or less than those generated by the development anticipated for the site under the existing General Plan land 8 Projects that use State Density Bonus Law retain consistency with the General Plan land use designation and are deemed consistent with the demographic forecasts and land use assumptions in the CAP Update. 9 Most considerable causes for equivalent or fewer GHG emissions include less VMT and lower per capita energy use. See Appendix C Quantifying GHG Emissions, Operational Emissions for more operational emissions sources that can be reduced. Proponent should provide rationale for this determination.

Determining Consistency with the CAP Update
Final Draft 9
use and zoning designations (whichever is higher). After this is completed, the lead agency can proceed to Step 4.

If a project is not consistent with the existing General Plan land use or zoning of the project site/area, would require a general plan or zoning amendment, and would result in either new development of undeveloped land or redevelopment with higher GHG emissions than the development anticipated for the site under the City’s existing General Plan land use and zoning designation, the project cannot use the CEQA GHG Checklist to tier from the adopted IS-ND for the CAP Update. Instead, the project’s GHG emissions can be evaluated using the quantitative GHG thresholds described in Section 4, Quantitative CEQA GHG Thresholds, to evaluate the significance of the project’s GHG emissions.

2.4 Step 4: Consistency with CEQA GHG Checklist
The City has prepared the CEQA GHG Checklist for projects to ensure they are consistent with the strategies of the CAP Update. The City can use the checklist to show that a project includes all applicable strategies of the CAP Update. Projects that use the CEQA GHG Checklist are not required to quantify reductions from the strategies included on the checklist, because the reductions from applicable strategies have already been quantified at a programmatic level in the CAP Update.

City of Santa Barbara
Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis 10 This page intentionally left blank.

CEQA GHG Checklist
Final Draft 11
3 CEQA GHG Checklist
The purpose of the CEQA GHG Checklist is to assist with determining project consistency with the CAP Update and provide a streamlined review process for proposed future development projects that are subject to discretionary review and trigger environmental review pursuant to CEQA. GHG reduction programs that are applicable to future development are summarized in the following CEQA GHG Checklist. This CEQA GHG Checklist identifies applicable regulations and monitoring and reporting required by those regulations.

This CEQA GHG Checklist contains measures that are required to be implemented on a project-byproject basis to ensure that the specified emissions targets identified in the CAP Update are achieved.

If a project is consistent with the applicable strategies on the CEQA GHG Checklist, then the project can tier from the programmatic GHG emissions environmental review included in the adopted IS-ND for the CAP Update pursuant to CEQA Guidelines Section 15183.5(b)(1). A project that is consistent with all applicable strategies of the CEQA GHG Checklist would result in less-than-significant GHG emissions and would not result in a cumulatively considerable impact related to GHG emissions and climate change.

Projects that are identified as not consistent with the CAP Update through the use of this CEQA GHG Checklist must prepare a project-specific analysis of GHG emissions, including quantification of existing and projected GHG emissions compared to the City’s GHG emissions thresholds outlined in Section 4, Quantitative CEQA GHG Thresholds.

This CEQA GHG Checklist only applies to projects that require a consistency determination with the CAP under Steps 3 and 4 of Figure 1 (see also Sections 2.3 and 2.4).

This CEQA GHG Checklist may be periodically updated to incorporate new GHG reduction techniques, to comply with later amendments to the CAP Update, or to reflect changes in other sustainability-focused local, state, or federal laws, regulations, ordinances, and programs.

3.1 CEQA GHG Checklist Requirements
The CEQA GHG Checklist as depicted on the next two pages is required for all projects that are not otherwise exempt from CEQA and are considered new or substantially redeveloped residential, commercial, or mixed-use buildings, or additions of 2,000 square feet or more to residential, commercial, or mixed-use buildings, and proposed within the City limits. The CEQA GHG Checklist is designed to assist the City and applicant in identifying consistency with the CAP Update. However, it may be necessary to supplement the completed CEQA GHG Checklist with supporting materials, calculations, or certifications to demonstrate compliance with the CAP Update and other applicable sustainability-focused requirements. The completed CEQA GHG Checklist will be included as an appendix to the CEQA document.

City of Santa Barbara
Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis 12 General Project Information
Contact Information
Project or Plan Name:

Address:

Applicant Name and Co.:

Contact Phone: Contact Email:

Was a consultant retained to complete this checklist? Yesտ Noտ If Yes, complete the following:

Consultant Name: ___________________________
Company Name: ____________________________
Contact Phone: _________________________
Contact Email: __________________________
Project Information
What is the size of the project site or plan area (acres)? Gross: _________________________
Net: ___________________________
Identify all applicable proposed land uses:
տ Residential (indicate # of single- dwelling units):
_________________________________________________________________________________________________ տ Residential (indicate # of multi-dwelling units):
_________________________________________________________________________________________________ տ Commercial (indicate total square footage, gross and net):
_________________________________________________________________________________________________ տ Municipal (indicate total square footage, gross and net):
_________________________________________________________________________________________________ տ Other (describe):
_________________________________________________________________________________________________ Project Description
This description should be consistent with the project description that will be used for the CEQA document. The description may be attached to the GHG Checklist if there are space constraints. __________________________________________________________________________________________________ __________________________________________________________________________________________________ __________________________________________________________________________________________________ __________________________________________________________________________________________________ __________________________________________________________________________________________________ __________________________________________________________________________________________________ __________________________________________________________________________________________________ __________________________________________________________________________________________________ CEQA GHG Checklist
Final Draft 13
Compliance Checklist Table
Checklist Applicability
Step 1 – The planner has confirmed
that the project is not exempt from
CEQA.

If the project is exempt from CEQA, then this compliance checklist does not apply and no further GHG analysis is required.

Step 2 – The planner has confirmed
that the project involves new or
substantially redeveloped residential,
commercial, or mixed-use buildings,
or additions of more than 2,000
square feet to existing residential,
commercial, or mixed-use buildings.

If the project involves preparation of a CEQA Initial Study, Negative Declaration, Environmental Impact Report, Section 15183 Streamlining Analysis, or EIR/ND Addenda; but does not include 1) new buildings, or 2) substantial redevelopment, or 3) additions of more than 2,000 square feet of floor area, then this compliance checklist does not apply and no further GHG analysis is required.

Section 1: Land Use Consistency
Regulation Requirements
Project/
Plan Compliance1 Required Explanation2
General Plan 1a. Does the Project include a land
use and/or zoning amendment?
If “No”, proceed to Section 2 – CAP
Strategies Consistency.

If “Yes”, proceed to question 1b.

Yes տ
No տ
__________________________________
__________________________________
__________________________________
General Plan 1b. Does the land use and/or zoning
amendment result in a more GHGintensive project when compared to the existing conditions?
Yes տ
No տ
__________________________________
__________________________________
__________________________________
1 If “Yes ” to both questions 1a and 1b , the applicant must prepare a Project -specific analysis of GHG emissions, including quantification of existing and projected GHG emissions compared to City GHG emissions thresholds or other GHG emissions thresholds determined appropriate by the City and incorporation of the CAP Update measures in this CEQA GHG Checklist to the extent feasible. 2 Every question included in this checklist is required to be answered with explanation of either: 1) how it will be achieved, 2) why it will not be achieved, or 3) why it is not applicable.

City of Santa Barbara
Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis 14 Section 2: CAP Update Measures Consistency
Regulation Requirements
Project/Plan
Compliance1 Required Explanation2
Building Energy
City CAP
Update
(Measure BE-4)

2. All Project Types - Building
Electrification. Will the Project/Plan comply
with CAP Update Measure BE-4 and be allelectric with no natural gas hookup? Yes ܆
No տ
N/A3 տ
______________________________________
______________________________________
______________________________________
City CAP
Update
(Measure BE-7)

3. All Project Types- Carbon Free
Electricity. Will the Project/Plan (whether
all new construction, remodel, or
combination thereof) retain Santa Barbara
Clean Energy (SBCE) as the energy provider
or otherwise utilize 100% carbon free
electricity?4
Yes տ
No տ
N/A3 տ
______________________________________
______________________________________
______________________________________
______________________________________
City CAP
Update
(Measure T-6
and T-7)

4. All Project Types - EV Charging
Infrastructure. Will the Project/Plan
(whether all new construction, remodel, or
combination thereof) meet or exceed the
requirements of the California Green
Building Standards Code, Title 24, Part 11,
(CALGreen) Tier II for EV charging
infrastructure?
Yes տ
No տ
N/A5 տ
__________________________
__________________________
__________________________
City CAP
Update
(Measure T-8)

5. All Project Types - Off-Road Equipment
Electrification. Will the Project/Plan
(whether all new construction, remodel, or
combination thereof) commit4 to the use of
electrified off-road landscaping equipment
(e.g., mowers, chippers, tractors) for
ongoing operations and maintenance?
Yes տ
No տ
N/A6 տ
______________________________________
______________________________________
______________________________________
Transportation
City CAP
Update
(Measure TR-2)

6. All Project Types Reduce VMT. Will the
Project/Plan demonstrate a Vehicle Miles
Traveled (VMT) reduction consistent with
the City’s CEQA Transportation Analysis
Guidelines?7
Yes տ
No ܆
N/A8 տ
______________________________________
______________________________________
______________________________________
1 If “No”, the applicant must prepare a Project/Plan-specific analysis of GHG emissions, including quantification of existing and projected GHG emissions compared to City GHG emissions thresholds or other GHG emissions thresholds determined appropriate by the City and incorporation of the CAP Update measures in this CEQA GHG Checklist to the extent feasible. 2 Every question included in this checklist is required to be answered with explanation of either: 1) how it will be achieved, 2) why it will not be achieved, or 3) why it is not applicable.
3 N/A applies to projects that do not consist of buildings that require energy usage. 4 Compliance with this measure will be included in the project’s Conditions of Approval. 5 N/A applies to projects that do not require electric vehicle infrastructure. 6 N/A applies to projects that do not consist of off-road landscaping equipment and do not require a landscape plan where maintenance would be required.
7 Only projects screened out from VMT analysis or mitigated sufficiently to meet the City’s reduction target can demonstrate consistency with the CAP Update through this checklist.
8 N/A applies to projects that would not generate VMT.

Quantitative CEQA GHG Thresholds
Final Draft 15
4 Quantitative CEQA GHG Thresholds
If the CEQA GHG Checklist does not demonstrate conformance with the CAP Update, a project can be evaluated using quantitative CEQA GHG thresholds derived from the assumptions of the CAP Update. If that project’s GHG emissions are at or below the applicable quantitative threshold and it has an initial operation year before 2030, the City can determine that the plan would result in a lessthan-significant GHG emissions impact. A CAP-specific project can tier from the existing programmatic environmental review contained in the adopted programmatic IS-ND for the CAP Update. In doing so, such plans/projects would result in less-than-significant GHG emissions and would not result in a cumulatively considerable impact related to GHG emissions and climate change.

Projects with post-2030 operation will need to demonstrate how they would achieve net zero MT of CO2e per year due to AB 1279 to be considered less-than-significant and to not result in a cumulatively considerable GHG emissions impact. Note that the CEQA GHG thresholds will need to be updated for consistency when new General Plan land use designations and amendments to the CAP Update are adopted. The following sections provide an explanation of the methodology used to calculate the quantitative GHG emissions thresholds and guidance on how to utilize the thresholds.

4.1 Thresholds Calculation Methodology
CEQA Guidelines Section 15064.4 does not establish a specific quantitative threshold of significance for evaluating GHG emissions associated with a proposed project. Lead agencies have the discretion to establish significance thresholds for their respective jurisdictions, and in establishing those thresholds, a lead agency may appropriately look to thresholds developed by other public agencies, or suggested by other experts, as long as the threshold chosen is supported by substantial evidence (CEQA Guidelines Section 15064.7[c]). The following methodology is consistent with guidance provided by the AEP Climate Change Committee in 2016 for establishing GHG emissions efficiency thresholds using the local jurisdictional GHG inventory and demographic forecasts.10 An efficiency threshold is a threshold expressed as a per-person metric (e.g., per resident, per employee, or per service person). Efficiency thresholds are calculated by dividing the allowable GHG emissions inventory in a selected calendar year by the residents, employees, or service population in that year. The efficiency threshold identifies the quantity of GHG emissions that can be generated on a per-person basis without significantly impacting the environment.

Locally appropriate, plan- and project-specific GHG emissions efficiency thresholds were derived from the GHG emissions forecasts calculated for the CAP Update. These thresholds were created to comply with CEQA and the CEQA Guidelines and interpretive GHG emissions analysis case law, which are summarized in Appendix D Regulatory and Legal Setting. The City of Santa Barbara GHG emissions efficiency thresholds were calculated using the emissions forecasts with all emissions sectors included, because plans and projects would generate vehicle trips and equipment use, consume energy and water, and produce wastewater and solid waste, thereby generating emissions 10 AEP. 2016. Final White Paper Beyond 2020 and Newhall: A Field Guide to New CEQA Greenhouse Gas Thresholds and Climate Action Plan Targets for California. https://califaep.org/docs/AEP-2016_Final_White_Paper.pdf.

City of Santa Barbara
Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis 16 in all categories. Efficiency thresholds were calculated for the year 2030 to provide GHG emissions thresholds for new development in line with the state’s milestone target for year 2030.

GHG emissions efficiency thresholds would be used during the CEQA review process for new residential, commercial, mixed-use plans and projects, and any other project that is subject to CEQA. Forecasted GHG emissions in the CAP Update were disaggregated into residential and nonresidential development for the threshold year of 2030 to calculate thresholds specific to residential, non-residential, and mixed-use projects. Forecasted GHG emissions are sometimes also disaggregated between new and existing development for the threshold year. For the City of Santa Barbara, a GHG threshold disaggregated between new and existing development places a disproportionately high emphasis on GHG emissions reduction from existing development, given the CAP Update measures. This necessitated applying the CAP Update emissions reduction across both new development and existing development to produce per capita GHG thresholds for residential projects, non-residential projects, and mixed-use projects. The results of the disaggregation of the GHG emissions forecast are presented in Figure 2, which summarizes the total amount of GHG emissions expected to be generated by existing, new residential, and new non-residential development for threshold year 2030.

Figure 2 Allowable GHG Emissions from Existing and New Development in 2030 Table 2 summarizes the demographic projections for the City of Santa Barbara that were used in calculating GHG efficiency thresholds for the year 2030. As shown in the table, the numbers of residents, employees, and service persons are all anticipated to increase between 2019 and 2030. 334,488
29,929
14,090
-
50,000
100,000
150,000
200,000
250,000
300,000
350,000
400,000
2030 GHG Emissions (MT CO2e)
New Nonresidential
New Residential
Existing
Quantitative CEQA GHG Thresholds
Final Draft 17
Table 2 City of Santa Barbara Demographic Projections
Metric 2019 Estimate 2030 Forecast2
Net Increase from New Development
(2019-2030)
Residents 87,670 96,637 8,967
Employees 76,772 80,963 4,190
Service Population1 164,442 177,600 13,158
1 The service population is equal to the residential population plus the number of employees. 2 The 2019 Community GHG Emissions Inventory and 2030 Forecast generally aligns with the projections from SBCAG. Due to a small difference in methodologies, the 2023-2031 Housing Element uses a forecast of 98,600. Both projections are estimates of the future.

However, the per capita emissions target adopted by the City of Santa Barbara will allow for alignment around the actual future population numbers, allowing for consistency across these plans.

Source: Santa Barbara, City of. 2023. 2019 Community GHG Emissions Inventory and 2030 GHG Emissions Forecast.

Table 3 shows how the remaining GHG emissions for existing and new development after implementation of CAP Update measures are reaggregated to create communitywide emissions thresholds for 2030, using the demographic projections from Table 2. The resulting GHG thresholds are specified in Table 3 while the allowable 2030 GHG emissions are specified in Table 4.

Table 3 City of Santa Barbara 2030 CAP Update-Adjusted Emissions and Communitywide GHG Thresholds
Residential
(Existing & New)
Non-Residential
(Existing & New)
Mixed-Use1
(Existing & New)
CAP Update-Adjusted 2030
Emissions (MT CO2e)
210,684 167,823 378,507
Demographic Metric 96,637 residents 80,963 employees 177,600 service people2 GHG Efficiency Threshold
(MT CO2e per demographic
metric per year)

2.18 per resident 2.07 per employee 2.13 per service person2 Notes: MT CO2e = metric tons of carbon dioxide equivalent 1 Itis not practical to disaggregate CAP Update-adjusted emissions forecasts into mixed-use, residential, and non-residential due to data constraints. The combined residential and non-residential emissions are used along with service population to calculate a mixed-use GHG threshold.
2 The service population is equal to the residential population plus the number of employees.

Source: Appendix E CEQA GHG Thresholds Calculations; and Appendix F Justification for Thresholds.

City of Santa Barbara
Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis 18 4.2 Thresholds and Use
The GHG efficiency thresholds for residential, commercial, and mixed-use projects that have an operational year before 2030 are presented in Figure 3 and Table 4. If a project’s emissions do not exceed the applicable threshold, then it is considered consistent with the Santa Barbara CAP Update and its GHG emissions impacts (both project- and cumulative-level) would not result in a cumulatively considerable impact related to GHG emissions and would, therefore, be less than significant. If a project’s emissions exceed the applicable threshold, then mitigation measures must be identified, and GHG emissions reduction calculations included within the respective CEQA review document in order to reduce project GHG emissions to at or below the applicable threshold level.

These thresholds are applicable to the following project types proposed in Santa Barbara:
ƒ Residential. Generally, all residential uses. Zones may include, but are not limited to, the following: Residential Single Unit, Two-Unit Residential, Residential Multi-Unit, Residential Multi-Unit and Hotel, Mobile Home Park Overlay, Planned Unit Development, Priority Housing Overlay.
ƒ Nonresidential. Generally, all commercial uses. Zones may include, but are not limited to, the following: Office Restricted, Office Medical, Commercial Restricted, Commercial General, Manufacturing Commercial , Light Manufacturing, Hotel and Related Commerce, Ocean Related Commercial, Ocean Oriented Light Manufacturing, Harbor Commercial, Park and Recreation, ACS Overlay – (Auto, Commercial, and Services), Research and Development. ƒ Mixed-use. A combination of at least one residential and at least one non-residential land use specified above. Zones may include any zone where both commercial and residential uses are allowed.

Figure 3 City of Santa Barbara GHG Efficiency Thresholds

2.18 2.07

2.13 2.00

2.02 2.04

2.06 2.08

2.10 2.12

2.14 2.16

2.18 2.20
Residential
(per resident)
Nonresidential
(per job)
Mixed-Use
(per service person)
GHG Emissions Threshold (MT CO2e/unit)
Quantitative CEQA GHG Thresholds
Final Draft 19
Table 4 City of Santa Barbara Locally Applicable Project CEQA GHG Emissions Thresholds
2030 New Development
New Residential New Non-Residential New Mixed-Use2
GHG Emissions Forecasted
(new MT CO2e)1
29,929 14,090 44,019
Demographic Metric 8,967 new residents 4,190 new employees 13,158 new service people3
GHG Efficiency Threshold
(MT CO2e per demographic
metric per year)

2.18 per resident 2.07 per employee 2.13 per service person3 Notes: MT CO2e = metric tons of carbon dioxide equivalent 1 GHG Emissions Forecasted represent the new GHG emissions forecasted between 2019 and 2030. This also represents the allowable GHG emissions for each sector.
2 GHG emissions from new mixed-use development would count against the total remaining GHG emissions budget for both new residential and new non-residential development rather than as a function of the number of new service people expected in 2030. This avoids double counting.
3 The service population is equal to the residential population plus the number of employees.

Source: Appendix F CEQA GHG Thresholds Calculations; and Appendix F Justification for Thresholds.

Typically, industrial uses that are subject to CEQA would increase jobs but also could increase GHG emissions in the City (such as manufacturing & processing, public facility, wholesaling, and other industrial uses) would not be able to utilize the GHG Efficiency Thresholds shown in Table 4 because 1) the City’s GHG Inventory and Forecast does not account for industrial emissions and 2) these industrial projects may be subject to Santa Barbara County Air Pollution Control District (APCD) stationary source permitting or the State cap-and-trade program, or any combination of these uses. Some public works projects (such as facility upgrades and roadway improvement projects) that are subject to CEQA would also not be able to utilize the GHG Efficiency Thresholds because construction emissions11 associated with those projects are not included in the City’s GHG Inventory and Forecast. A different methodology and assessment would be necessary to evaluate GHG emissions impacts.
11 Cumulative GHG emissions associated with construction from a project are generally orders of magnitude lower than the operational emissions from a project because construction emissions are generally short in duration compared to the project’s overall lifetime, and thus can be assessed qualitatively as part of related CEQA GHG emissions analysis. However, some projects may have long construction periods or entail large quantities of cut and fill that could result in construction-related GHG emissions that may be considered significant.

Thus, the City retains the discretion on a project-by-project basis to consider whether a project’s construction-related GHG emissions could be cumulatively considerable and require more detailed quantitative CEQA GHG emissions analysis and respective mitigation.

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Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis 20 This page intentionally left blank.

Moving into the Future
Final Draft 21
5 Moving into the Future
Full implementation of the CAP Update will reduce total communitywide GHG emissions by approximately 47 percent below 1990 levels by 2030 and 58 percent by 2035, which would leave a gap of approximately 297,689 MT CO2e in 2035. This gap represents emissions that will need to be addressed with additional actions beyond those identified in the plan and laws, regulations, policies, programs, and ordinances set forth by the federal and state governments, regional agencies, and local partners. Consequently, the CAP Update includes monitoring and tracking mechanisms so the City can determine what additional actions may be necessary and when they should be employed to meet the City’s carbon neutrality target.

Santa Barbara is committed to embracing that uncertainty, striving toward constant learning, engaging in systemic change using the tools and actions that local governments are uniquely suited to carry out, and positioning itself to take full advantage of future innovations, technologies, and policies and legislation that may be undertaken at the state and federal level. Technological innovation, clean-tech innovation, and changes to climate related policy and regulation occur rapidly. Several of the State’s most successful environmental policy initiatives also had a gap between what was known at the time of adoption and eventual successful implementation. By committing to the ambitious target of carbon neutrality by 2035, Santa Barbara intends to catalyze innovation, invite resources from funding sources and partners, and provide climate leadership.

The CAP Update acknowledges that additional actions beyond those identified in the plan will be necessary to achieve carbon neutrality and, therefore, provides a mechanism for updating and adopting a new CAP Update every five to ten years (with regular assessment of progress) in order to incorporate new measures and innovative technologies that will further Santa Barbara toward meeting its goal of carbon neutrality. As the CAP is updated, the associated CEQA GHG Checklist will also be updated as needed to incorporate new measures and actions that discretionary development projects will need to incorporate, as applicable, to demonstrate consistency with the latest CAP. At the time at which the City identifies measures to achieve its carbon neutrality goal in totality, the City will adopt those measures in a public process following CEQA review, at which time that updated CAP will become a qualified GHG emission reduction plan for projects with post-2030 buildout years. However, the quantitative thresholds included in this guidance document will not need to be updated, because residential, non-residential, and mixed-use projects with post-2030 buildout years will need to achieve GHG emissions equivalent to zero MT CO2e per year to demonstrate consistency with the CAP.

Finally, if future amendments or updates of the Santa Barbara Land Use Element occur, then such amendments or updates will be incorporated into future updates of the CAP Update to ensure that project applicants can continue to utilize the streamlining process, which is partly dependent on a project’s consistency with the demographic forecasts and land use assumptions based on the General Plan Land Use Element to the greatest extent practicable.

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Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis 22 This page intentionally left blank.

Appendix A
Climate Action Plan Summary

Climate Action Plan Summary
Final Draft A-1
Climate Action Plan Summary
The following sections provide an overview of the CAP Update, including the 2019 communitywide GHG emissions inventory, the communitywide GHG emissions forecast, and the proposed GHG emission reduction strategy.

Communitywide GHG Emissions Inventories
The City has completed a communitywide GHG emissions inventory for the year 2019. The City’s targets have been set based on the 2019 inventory. The City estimated 1990 emissions by backcasting the 2019 emissions to 1990 using the change in state emissions between the same time period as a proxy for change in the City. The 2019 inventory and 1990 estimate are summarized in Table 1. As shown therein, total communitywide GHG emissions declined by approximately 13 percent between 1990 and 2019.

Table 1 City of Santa Barbara 1990 and 2019 Communitywide GHG Emissions Levels Sector 19901 2019
Percent Change from
1990 to 2019 (%)
Electricity (MT CO2e) N/A 115,442 N/A
Natural Gas (MT CO2e) N/A 134,068 N/A
Transportation (MT CO2e) N/A 317,966 N/A
Solid Waste (MT CO2e) N/A 52,977 N/A
Water & Wastewater (MT CO2e) N/A 1,657 N/A
Total GHG Emissions (MT CO2e) 715,530 622,110 -13%
MT = metric tons; CO2e = carbon dioxide equivalents
Note: Mass emissions are rounded to the nearest integer and per capita emissions are rounded to the nearest tenth. 1 1990 GHG emissions were estimated by back-casting Santa Barbara’s total 2019 GHG emissions based on the change in the State’s GHG emissions between 2019 and 1990. 1990 GHG emissions were not estimated at the individual sector level.

Source: Santa Barbara, City of. 2023. Santa Barbara 2019 Community GHG Inventory, Forecast, and Targets.

GHG Emission Reduction Strategy
The CAP Update includes a series of measures and actions that are intended to reduce communitywide GHG emissions per capita by at least 40 percent below 1990 per capita levels by 2030. This provides substantial progress toward meeting the City’s longer-term carbon neutrality goal while also meeting the State’s 2030 goal. The CAP Update acknowledges that additional actions beyond those identified in the plan will be necessary to achieve the long-term target of carbon neutrality. Therefore, the CAP Update provides a mechanism for tracking performance over time, reporting annual progress to the City Council, conducting inventory updates at minimum every three years, and adopting a new CAP Update by 2030 (with the ability to adjust as needed based on progress), in order to incorporate new strategies and technologies that will further the City toward meeting its long-term aspirational goal of carbon neutrality.

As part of the CAP Update process, the City has developed a set of measures reducing communitywide GHG emissions in all sectors to exceed the City’s 2030 GHG emission reduction target and make substantial progress towards the City’s goal for carbon neutrality. Each measure is City of Santa Barbara
Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis A-2
supported by a set of actions that provide a measurable GHG emissions reduction that is supported by substantial evidence. The City has also developed measures and supportive actions for offsetting GHG emissions through carbon sequestration. Measures and actions are organized according to the following hierarchy:

1. Sectors. Sectors define the GHG emissions category in which the GHG emissions reduction will take place and include Building Energy, Transportation, Water, Waste, and Carbon Sequestration.

2. Measures. Measures identify specific goals (i.e., activity data targets by 2030 and 2035) to address GHG emissions in each sector. A single measure generally addresses a subsector; for example, three strategies may be established under the Transportation sector to address active transportation, shared/public transportation, and single-passenger vehicles.

3. Actions. Actions identify the programs, policies, funding pathways, and other specific commitments that the City will implement. Each strategy contains a suite of actions, which together have been designed to accomplish the measure goal.

Table 2 summarizes the GHG emissions reduction that are anticipated to be achieved by 2030 by the identified measures in the CAP Update and existing local programs (e.g. Santa Barbara Clean Energy [SBCE] and Santa Barbara’s ReSource Center waste management facility), in addition to state legislation and programs. As shown therein, implementation of state legislation and programs is expected to reduce 2030 total communitywide GHG emissions approximately 18 percent below 1990 emission levels. With current local programs, including continued enrollment in SBCE and the ReSource Center programs, 2030 total communitywide GHG emissions are further reduced by approximately 17 percent to 35 percent below 1990 levels. Implementation of the CAP Update measures would reduce 2030 total communitywide GHG emissions an additional 12 percent for a total reduction of approximately 47 percent below 1990 emission levels.

Climate Action Plan Summary
Final Draft A-3
Table 2 City of Santa Barbara GHG Emissions Reductions by 2030 Source
Absolute Annual Emissions Reductions
(MT of CO2e)
1990 Baseline Emissions 715,530
Business-as-Usual (BAU) 2030 Emissions 698,596
State Laws/Programs (112,176)
SBCE (75,608)
ReSource Center (44,690)
Buildings & Energy Strategies (21,512)
Transportation Strategies (63,081)
Waste Diversion Strategies1 (2,861)
Water & Wastewater Strategies (1.72)
Natural Systems Strategies (159)
Total Emissions Reduction (from BAU) (320,088)
Remaining 2030 Emissions 378,507
Percent Reduction below 1990 Levels (47%)
( ) denotes a negative number; numbers in table may not add to the total exactly due to rounding.

MT = metric tons; CO2e = carbon dioxide equivalents
1 Reductions listed here are those achieved in excess of SB 1383 compliance obligation for organic waste diversion and procurement requirements that have already been achieved with City enrollment at the ReSource Center beginning in 2021.

Source: City of Santa Barbara Climate Action Plan Update and GHG Emissions Reduction Measure Quantification and Evidence Appendix
GHG Emissions Forecast
Figure 1 and Table 3 summarize the communitywide GHG emissions forecast under four scenarios:
1) business-as-usual, 2) implementation of state laws and programs [State Legislative Adjusted Forecast], 3) State Legislative Adjusted Forecast in addition to continued enrollment in SBCE and use of the ReSource Center to meet SB 1383 compliance, and 4) forecasted reductions from implementation of the CAP Update measures and actions in addition to State laws and programs and current local programs (i.e., SBCE and ReSource Center) As shown therein, under the business-as-usual scenario, total communitywide GHG emissions are forecasted to increase by approximately 18 percent between 2019 and 2035 based on economic and population growth. However, with implementation of state laws and programs, total communitywide GHG emissions would decline by approximately 14 percent between 2019 and 2035. With continued enrollment in existing programs, specifically SBCE and use of the ReSource Center, total communitywide GHG emissions in 2035 are forecasted to decline by an additional 11 percent for a total decline of 25 percent below 2019 levels. Furthermore, full implementation of the CAP Update alongside state laws and programs and continued enrollment in current local programs (e.g., SBCE and ReSource Center), total communitywide GHG emissions are anticipated to decline 52 percent below 2019 levels by 2035. This trajectory equates to a 47 percent below 1990 emission levels by 2030 and 58 percent below 1990 emission levels by 2035.12 12 This represents significant progress towards the City’s long-term goal of carbon neutrality by 2035. The City will rely on new measures in the form of regular CAP updates, new state legislation and new technological advances to achieve this target.

City of Santa Barbara
Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis A-4
Figure 1 City of Santa Barbara GHG Emissions Forecast and GHG Emission Reduction Pathway, 2019 to 2045
2030 Target
486,949 MT CO2e
2035 Target
0 MT CO2e
2030 Emissions After
Reductions
378,507 MT CO2e
2035 Emissions After
Reductions
297,689 MT CO2e
0 100,000
200,000
300,000
400,000
500,000
600,000
700,000
800,000
900,000
2019 2025 2030 2035 2040 2045
GHG Emissions (MT CO2e)
1990 Baseline
Business-as-Usual Forecast
State Legislative Adjusted Forecast
State Legislative Adjusted Forecast with SBCE + ReSource Center Reductions GHG Emission Reduction Target Pathway
GHG Emissions after CAP Implementation
Climate Action Plan Summary
Final Draft A-5
Table 3 City of Santa Barbara GHG Emissions Forecast Through 2045 Sector
2019
(MT of CO2e)
2025
(MT of CO2e)
2030
(MT of CO2e)
2035
(MT of CO2e)
2040
(MT of CO2e)
2045
(MT of CO2e)
Business-as-Usual GHG Emissions
Electricity 115,442 119,973 123,748 127,524 130,031 132,431 Natural Gas 134,068 140,306 145,504 150,703 152,898 154,856 Transportation 317,966 345,687 370,338 395,247 420,077 444,944 Solid Waste 52,977 55,289 57,216 59,142 60,301 61,134
Water & Wastewater 1,657 1,730 1,790 1,850 1,887 1,913
Total 622,110 662,984 698,596 734,467 765,193 795,278
State Legislative Adjusted Forecast (GHG Emissions After Implementation of State Laws/Programs) Electricity 115,442 107,269 79,587 20,617 10,580 –
Natural Gas 134,068 139,975 144,898 149,822 151,959 153,869 Transportation 317,966 309,941 303,012 302,203 308,367 319,253 Solid Waste 52,977 55,289 57,216 59,142 60,301 61,134
Water & Wastewater 1,657 1,705 1,706 1,637 1,648 1,649
Total 622,110 614,180 586,420 533,421 532,854 535,905
GHG Emissions After Implementation of State Laws/Programs, SBCE, and ReSource Center Electricity 115,442 5,363 3,979 1,031 529 –
Natural Gas 134,068 139,975 144,898 149,822 151,959 153,869 Transportation 317,966 309,941 303,012 302,203 308,367 319,253 Solid Waste 52,977 12,119 12,526 12,933 13,198 13,399
Water & Wastewater 1,657 1,705 1,706 1,637 1,648 1,649
Total 622,110 469,104 466,122 467,625 475,700 488,170
GHG Emissions After Implementation of State Laws/Programs, SBCE, ReSource Center, and Santa Barbara CAP1 Electricity 115,442 5,363 3,979 1,031 529 –
Natural Gas 134,068 133,569 123,387 113,130 107,621 102,830 Transportation 317,966 261,244 239,931 175,033 66,395 24,455 Solid Waste 52,977 12,119 9,665 7,018 (1,877) (1,885)
Water & Wastewater 1,657 1704.05 1704.65 1636.41 1647.15 1648.54 Carbon Sequestration N/A (18) (159) (159) (159) (159)
Total 622,110 413,982 378,507 297,689 174,156 126,890
( ) denotes a negative number
1 The 2019 Santa Barbara GHG Inventory and Forecasts do not include carbon sequestration; however, the CAP Update has quantitative measures to increase carbon sequestration.

MT = metric tons; CO2e = carbon dioxide equivalents
Source: Santa Barbara, City of. 2023. Santa Barbara Forecasts through 2045.

At this time, the State has codified a target of reducing emissions to 40 percent below 1990 emissions levels by 2030 (SB 32) and has developed the 2022 Climate Change Scoping Plan to demonstrate how the State will achieve the 2030 target and make substantial progress toward the 2045 goal of carbon neutrality established by AB 1279.

While state and regional regulations related to energy and transportation systems, along with the State’s Cap and Trade program, are designed to be set at limits to achieve most of the GHG emissions reductions needed to achieve the State’s long-term goals, local governments can do their City of Santa Barbara
Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis A-6
fair share toward meeting the State’s goals by siting and approving projects that accommodate planned population growth and projects that are GHG-efficient. The Association of Environmental Professional (AEP) Climate Change Committee recommends that CEQA GHG analyses evaluate project emissions in light of the trajectory of state climate change legislation and assess their “substantial progress” toward achieving long-term reduction targets identified in available plans and legislation.

The City has adopted a longer-term target of achieving carbon neutrality by 2035 and has proposed the CAP Update as a pathway to make progress toward this target. Implementation of the CAP Update, in addition to state laws and continued enrollment in local programs (e.g., SBCE and ReSource Center), would achieve an approximately 47 percent reduction in total communitywide GHG emissions below 1990 emission levels by 2030—to 378,507 MT CO2e—and a 58 percent reduction below 1990 emission levels by 2035—to 297,689 MT CO2e in 2035). Therefore, the City’s longer-term target of carbon neutrality and the associated CAP Update establish a trajectory that provides GHG emissions reductions equal to or greater than those required by SB 32 for 2030.

Because SB 32 is considered an interim target toward meeting the State’s long-term goals, implementation of the CAP Update would make substantial progress toward meeting the State’s long-term goal. Avoiding interference with, and making substantial progress toward, these longterm state goals is important because these goals have been set at levels that achieve California’s fair share of international emissions reduction goals that will stabilize global climate change effects and avoid the adverse environmental consequences described in Appendix B Overview of GHG Emissions and Climate Change (AB 1279).

Appendix B
Overview of GHG Emissions and Climate Change

Overview of GHG Emissions and Climate Change
Final Draft B-1
Overview of GHG Emissions and Climate
Change
Climate Change and Greenhouse Gases
Climate change is the observed increase in the average temperature of Earth’s atmosphere and oceans along with other substantial changes in climate (such as wind patterns, precipitation, and storms) over an extended period. The term “climate change” is often used interchangeably with the term “global warming,” but “climate change” is preferred to “global warming” because it helps convey other changes in addition to rising temperatures. The baseline against which these changes are measured originates from historical records identifying temperature changes that have occurred in the past, such as during previous ice ages. The global climate changes continuously, as evidenced by repeated episodes of substantial warming and cooling documented in the geologic record. The rate of change has typically been incremental, with warming or cooling trends occurring over the course of thousands of years. The past 10,000 years have been marked by a period of incremental warming, as glaciers have steadily retreated across the globe. However, scientists have observed substantial acceleration in the rate of warming during the past 150 years. The United Nations Intergovernmental Panel on Climate Change (IPCC) expressed that the rise and continued growth of atmospheric CO2 concentrations is unequivocally due to human activities in the IPCC’s Sixth Assessment Report from 2021. Human influence has warmed the atmosphere, ocean, and land, which has led the climate to warm at an unprecedented rate in the last 2,000 years. It is estimated that between the period of 1850 through 2019, that a total of 2,390 gigatonnes of anthropogenic CO2 was emitted. It is likely that anthropogenic activities have increased the global surface temperature by approximately 1.07 degrees Celsius between the years 2010 through 2019.13 Furthermore, since the late 1700s, estimated concentrations of carbon dioxide (CO2), methane (CH4), nitrous oxides (N2O) in the atmosphere have increased by over 43 percent, 156 percent, and 17 percent, respectively, primarily due to human activity.14 Emissions resulting from human activities are thereby contributing to an average increase in Earth’s temperature.

Gases that absorb and re-emit infrared radiation in the atmosphere are called GHGs. The gases widely seen as the principal contributors to human-induced climate change include CO2, CH4, N2O, fluorinated gases such as hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). Water vapor is excluded from the list of GHGs because it is short-lived in the atmosphere, and natural processes, such as oceanic evaporation, largely determine its atmospheric concentrations.

GHGs are emitted by natural processes and human activities. Of these gases, CO2 and CH4 are emitted in the greatest quantities from human activities. Emissions of CO2 are usually by-products of fossil fuel combustion, and CH4 results from off-gassing associated with agricultural practices and 13 Intergovernmental Panel on Climate Change (IPCC). 2021. Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Masson-Delmotte, V., P. Zhai, A. Pirani, S. L.

Connors, C. Péan, S. Berger, N. Caud, Y. Chen, L. Goldfarb, M. I. Gomis, M. Huang, K. Leitzell, E. Lonnoy, J.B.R. Matthews, T. K. Maycock, T.

Waterfield, O. Yelekçi, R. Yu and B. Zhou (eds.)] Cambridge University Press. https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Full_Report.pdf 14 United States Environmental Protection Agency (U.S. EPA). 2021. Climate Change Indicators: Atmospheric Concentrations of Greenhouse Gases. Last updated April 2021. https://www.epa.gov/climate-indicators/climate-change-indicators-atmosphericconcentrations-greenhouse-gases City of Santa Barbara
Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis B-2
landfills. Human-made GHGs, many of which have greater heat-absorption potential than CO2, include fluorinated gases and SF6.15
Different types of GHGs have varying global warming potentials (GWP). The GWP of a GHG is the potential of a gas or aerosol to trap heat in the atmosphere over a specified timescale (generally, 100 years). Because GHGs absorb different amounts of heat, a common reference gas (CO2) is used to relate the amount of heat absorbed to the amount of the gas emitted, referred to as “carbon dioxide equivalent” (CO2e), which is the amount of GHG emitted multiplied by its GWP. Carbon dioxide has a 100-year GWP of one. By contrast, CH4 has a GWP of 30, meaning its global warming effect is 30 times greater than CO2 on a molecule per molecule basis.16,17 The accumulation of GHGs in the atmosphere regulates the earth’s temperature. Without the natural heat-trapping effect of GHGs, the earth’s surface would be about 33 degrees Celsius (°C) cooler.18 However, since 1750, estimated concentrations of CO2, CH4, and N2O in the atmosphere have increased by 36 percent, 148 percent, and 18 percent, respectively, primarily due to human activity.19 GHG emissions from human activities, particularly the consumption of fossil fuels for electricity production and transportation, are believed to have elevated the concentration of these gases in the atmosphere beyond the level of concentrations that occur naturally.

Greenhouse Gas Emissions Inventories
Global Emissions Inventory
In 2015, worldwide anthropogenic GHG emissions totaled 47,000 MMT of CO2e, which is a 43 percent increase from 1990 GHG levels. The largest source of GHG emissions were energy production and use (includes fuels used by vehicles and buildings), which accounted for 75 percent of the global GHG emissions. Agriculture uses and industrial processes contributed 12 percent and six percent, respectively. Waste sources contributed three percent. These sources account for approximately 96 percent.20
15 U.S. EPA. 2021. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2019. April 2021. https://www.epa.gov/system/files/documents/2022-02/us-ghg-inventory-2022-main-text.pdf 16 The IPCC’s Sixth Assessment Report from 2021 determined that methane has a GWP of 30. However, the 2017 Climate Change Scoping Plan published by the California Air Resources Board uses a GWP of 25 for methane, consistent with the Intergovernmental Panel on Climate Change’s Fourth Assessment Report from 2007. Therefore, this analysis utilizes a GWP of 25. 17 IPCC. 2021. Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Masson-Delmotte, V., P. Zhai, A. Pirani, S. L. Connors, C. Péan, S. Berger, N. Caud, Y. Chen, L.

Goldfarb, M. I. Gomis, M. Huang, K. Leitzell, E. Lonnoy, J.B.R. Matthews, T. K. Maycock, T. Waterfield, O. Yelekçi, R. Yu and B. Zhou (eds.)] Cambridge University Press. https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Full_Report.pdf 18 World Meteorological Organization. 2020. “Greenhouse Gases.” https://public.wmo.int/en/our-mandate/focusareas/environment/greenhouse%20gases 19 Forster, P., V. Ramaswamy, P. Artaxo, T. Berntsen, R. Betts, D.W. Fahey, J. Haywood, J. Lean, D.C. Lowe, G. Myhre, J. Nganga, R. Prinn, G. Raga, M. Schulz and R. Van Dorland. 2007. Changes in Atmospheric Constituents and in Radiative Forcing. Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M.Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. https://www.ipcc.ch/site/assets/uploads/2018/02/ar4-wg1-chapter2-1.pdf 20 U.S. EPA. 2023. Climate Change Indicators: Global Greenhouse Gas Emissions. Available at: https://www.epa.gov/climateindicators/climate-change-indicators-global-greenhouse-gas-emissions Overview of GHG Emissions and Climate Change
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United States Emissions Inventory
United States GHG emissions were 6,347.7 MMT of CO2e in 2021 (or 5,593.5 MMT CO2e after accounting for sequestration), a 6.8 percent increase from 2020 emissions. The increase from 2020 to 2021 was driven by an increase in CO2 emissions from fossil fuel combustion which increased 7 percent relative to previous years and is primarily due to the economic rebounding after the COVID19 pandemic. In 2020, the energy sector (including transportation) accounted for 81 percent of nationwide GHG emissions while agriculture, industrial and waste accounted for approximately 10 percent, 6 percent, and 3 percent respectively.21
California Emissions Inventory
Based on a review of the CARB California Greenhouse Gas Inventory for the years between 2000- 2020, California produced 369.2 MMT of CO2e in 2020, which is 35.3 MMT of CO2e lower than 2019 levels. The 2019 to 2020 decrease in emissions is likely due in large part to the impacts of the COVID-19 pandemic. The major source of GHG emissions in California is the transportation sector, which comprises 37 percent of the state’s total GHG emissions. The industrial sector is the second largest source, comprising 20 percent of the state’s GHG emissions while electric power accounts for approximately 16 percent. The magnitude of California’s total GHG emissions is due in part to its large size and large population compared to other states. However, a factor that reduces California’s per capita fuel use and GHG emissions as compared to other states is its relatively mild climate. In 2016, the state of California achieved its 2020 GHG emission reduction target of reducing emissions to 1990 levels as emissions fell below 431 MMT of CO2e.22 The annual 2030 statewide target emissions level is 260 MMT of CO2e.23
Potential Effects of Climate Change
Globally, climate change has the potential to affect numerous environmental resources through potential impacts related to future air temperatures and precipitation patterns. Scientific modeling predicts that continued GHG emissions at or above current rates would induce more extreme climate changes during the 21st century than were observed during the 20th century. Long-term trends have found that each of the past four decades has been warmer than all the previous decades in the instrumental record and the decade from 2011 through 2020 has been the warmest.

The observed global mean surface temperature (GMST) for the decade from 2011 to 2020 was approximately 1.09°C (0.95°C to 1.20°C) higher than the average GMST over the period from 1850 to 1900. Due to past and current activities, anthropogenic GHG emissions are increasing global mean surface temperature at a rate of 0.2°C per decade. In addition to these findings, the latest IPCC report states that “human-induced climate change is already affecting many weather and climate extremes in every region across the globe.”24 These climate change impacts include climate change 21 U.S. EPA. 2023. Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990-2021. Available at:
https://www.epa.gov/system/files/documents/2023-04/US-GHG-Inventory-2023-Main-Text.pdf 22 CARB. 2022. 2022 Scoping Plan for Achieving Carbon Neutrality. Available at: https://ww2.arb.ca.gov/sites/default/files/2023-04/2022- sp.pdf
23 CARB. 2017. California’s 2017 Climate Change Scoping Plan. Available at:
https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/scoping_plan_2017.pdf 24 IPCC. 2021. Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Masson-Delmotte, V., P. Zhai, A. Pirani, S. L. Connors, C. Péan, S. Berger, N. Caud, Y. Chen, L.

Goldfarb, M. I. Gomis, M. Huang, K. Leitzell, E. Lonnoy, J.B.R. Matthews, T. K. Maycock, T. Waterfield, O. Yelekçi, R. Yu and B. Zhou (eds.)] Cambridge University Press. https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Full_Report.pdf City of Santa Barbara
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sea level rise, increased weather extremes, and substantial ice loss in the Arctic over the past three decades.

According to California’s Fourth Climate Change Assessment, statewide temperatures from 1986 to 2016 were approximately 0.6 to 1.1°C higher than those recorded from 1901 to 1960. Potential impacts of climate change in California may include reduced water supply from snowpack, sea level rise, more extreme heat days per year, more large forest fires, and more drought years.25 In addition to statewide projections, California’s Fourth Climate Change Assessment includes regional reports that summarize climate impacts and adaptation solutions for nine regions of the State and regionally-specific climate change case studies.26 However, while there is growing scientific consensus about the possible effects of climate change at a global and statewide level, current scientific modeling tools are unable to predict what local impacts may occur with a similar degree of accuracy. A summary follows of some of the potential effects that could be experienced in California as a result of climate change.

Hydrology and Sea Level Rise
Climate change could affect the intensity and frequency of storms and flooding.27 Furthermore, climate change could induce substantial sea level rise in the coming century. Rising sea level increases the likelihood of and risk from flooding. The rate of increase of global mean sea levels between 1993 to 2020, observed by satellites, is approximately 3.3 millimeters per year, double the twentieth century trend of 1.6 millimeters per year.28,29 Global mean sea levels in 2013 were about

0.23 meter higher than those of 1880.30 Sea levels are rising faster now than in the previous two millennia, and the rise will probably accelerate, even with robust GHG emission control measures.

The most recent IPCC report predicts a mean sea level rise of 11 to 21.5 inches by 2100 under the lowest emissions scenario and a rise of 25 to 40 inches by 2100 under the very high emissions scenario.31
A rise in sea levels could erode 31 to 67 percent of California beaches and cause flooding of approximately 370 miles of coastal highways during 100-year storm events. This would also jeopardize California’s water supply due to saltwater intrusion and induce groundwater flooding and/or exposure of buried infrastructure.32 Furthermore, increased storm intensity and frequency could affect the ability of flood-control facilities, including levees, to handle storm events. 25 California, State of. 2018. California’s Fourth Climate Change Assessment Statewide Summary Report. August 27, 2018. https://www.energy.ca.gov/sites/default/files/2019-11/Statewide_Reports-SUM-CCCA4-2018-013_Statewide_Summary_Report_ADA.pdf 26 Ibid.
27 Ibid.
28 World Meteorological Organization. 2013. A summary of current and climate change findings and figures: a WMO information note.

March 2013. https://library.wmo.int/opac/index.php?lvl=notice_display&id=15892#.Wt9-Z8gvzIU 29 National Aeronautics and Space Administration. 2020. “Global Climate Change – Vital Signs of the Planet – Sea Level.” https://climate.nasa.gov/vital-signs/sea-level/
30 Ibid.
31 IPCC. 2021. Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Masson-Delmotte, V., P. Zhai, A. Pirani, S. L. Connors, C. Péan, S. Berger, N. Caud, Y. Chen, L.

Goldfarb, M. I. Gomis, M. Huang, K. Leitzell, E. Lonnoy, J.B.R. Matthews, T. K. Maycock, T. Waterfield, O. Yelekçi, R. Yu and B. Zhou (eds.)] Cambridge University Press. https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Full_Report.pdf 32 California, State of. 2018. California’s Fourth Climate Change Assessment Statewide Summary Report. August 27, 2018. https://www.energy.ca.gov/sites/default/files/2019-11/Statewide_Reports-SUM-CCCA4-2018-013_Statewide_Summary_Report_ADA.pdf Overview of GHG Emissions and Climate Change
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Air Quality
Scientists project that the annual average maximum daily temperatures in California could rise by

2.4 to 3.2°C in the next 50 years and by 3.1 to 4.9°C in the next century.33 Higher temperatures are conducive to air pollution formation, and rising temperatures could therefore result in worsened air quality in California. As a result, climate change may increase the concentration of ground-level ozone, but the magnitude of the effect, and therefore its indirect effects, are uncertain. In addition, as temperatures have increased in recent years, the area burned by wildfires throughout the State has increased, and wildfires have occurred at higher elevations in the Sierra Nevada Mountains.34 If higher temperatures continue to be accompanied by an increase in the incidence and extent of large wildfires, air quality could worsen. Severe heat accompanied by drier conditions and poor air quality could increase the number of heat-related deaths, illnesses, and asthma attacks throughout the State. However, if higher temperatures are accompanied by wetter, rather than drier conditions, the rains could tend to temporarily clear the air of particulate pollution, which would effectively reduce the number of large wildfires and thereby ameliorate the pollution associated with them.35 Water Supply
Analysis of paleoclimatic data (such as tree-ring reconstructions of stream flow and precipitation) indicates a history of naturally and widely varying hydrologic conditions in California and the west, including a pattern of recurring and extended droughts. Uncertainty remains with respect to the overall impact of climate change on future precipitation trends and water supplies in California.

Year-to-year variability in statewide precipitation levels has increased since 1980, meaning that wet and dry precipitation extremes have become more common.36 This uncertainty regarding future precipitation trends complicates the analysis of future water demand, especially where the relationship between climate change and its potential effect on water demand is not well understood. The average early spring snowpack in the western U.S., including the Sierra Nevada Mountains, decreased by about 10 percent during the last century. During the same period, sea level rose over 0.15 meter along the central and southern California coasts.37 The Sierra snowpack provides the majority of California's water supply as snow that accumulates during wet winters is released slowly during the dry months of spring and summer. A warmer climate is predicted to reduce the fraction of precipitation that falls as snow and the amount of snowfall at lower elevations, thereby reducing the total snowpack.38 Projections indicate that average spring snowpack in the Sierra Nevada and other mountain catchments in central and northern California will decline by approximately 66 percent from its historical average by 2050.39 33 Ibid.
34 Ibid.
35 California Natural Resources Agency. 2009. 2009 California Climate Adaptation Strategy. March 2009. http://resources.ca.gov/docs/climate/Statewide_Adaptation_Strategy.pdf 36 California Department of Water Resources. 2018. Indicators of Climate Change in California. May 2018. https://oehha.ca.gov/media/downloads/climate-change/report/2018caindicatorsreportmay2018.pdf 37 California, State of. 2018. California’s Fourth Climate Change Assessment Statewide Summary Report. August 27, 2018. https://www.energy.ca.gov/sites/default/files/2019-11/Statewide_Reports-SUM-CCCA4-2018-013_Statewide_Summary_Report_ADA.pdf 38 Ibid.
39 Ibid.

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Agriculture
California has an over $51 billion annual agricultural industry that produces over a third of the country’s vegetables and three-quarters of the country’s fruits and nuts.40 Higher CO2 levels can stimulate plant production and increase plant water-use efficiency. However, if temperatures rise and drier conditions prevail, certain regions of agricultural production could experience water shortages of up to 16 percent, which would increase water demand as hotter conditions lead to the loss of soil moisture. In addition, crop yield could be threatened by water-induced stress and extreme heat waves, and plants may be susceptible to new and changing pest and disease outbreaks (California Natural Resource Agency 2019). Temperature increases could also change the time of year certain crops, such as wine grapes, bloom or ripen, and thereby affect their quality.41 Ecosystems and Wildlife
Climate change and the potential resultant changes in weather patterns could have ecological effects on the global and local scales. Soil moisture is likely to decline in many regions as a result of higher temperatures, and intense rainstorms are likely to become more frequent. Rising temperatures could have four major impacts on plants and animals: timing of ecological events; geographic distribution and range of species; species composition and the incidence of nonnative species within communities; and ecosystem processes, such as carbon cycling and storage.42,43 40 California Department of Food and Agriculture. 2022. California Agricultural Production Statistics. Available at:
https://www.cdfa.ca.gov/Statistics/
41 California Climate Change Center (CCCC). 2006. Climate Scenarios for California. 42 Parmesan, C. August 2006. Ecological and Evolutionary Responses to Recent Climate Change. 43 California, State of. 2018. California’s Fourth Climate Change Assessment Statewide Summary Report. August 27, 2018. https://www.energy.ca.gov/sites/default/files/2019-11/Statewide_Reports-SUM-CCCA4-2018-013_Statewide_Summary_Report_ADA.pdf Appendix C
Quantifying GHG Emissions

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Quantifying GHG Emissions
There are a variety of analytical tools available to estimate project-level GHG emissions, including the California Emissions Estimator Model (CalEEMod),44 which is a free, publicly available computer model developed for the California Air Pollution Control Officers Association (CAPCOA) in collaboration with various air quality districts throughout the State. Alternative tools may be used to quantify emissions if they can be substantiated. In general, the most current version of CalEEMod should be used to calculate total emissions for discretionary development projects. The analysis should focus on carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O), because these are the GHGs that most development projects would generate in the largest quantities. Fluorinated gases, such as hydrofluorocarbons, perfluorocarbons, and sulfur hexafluorides, should also be considered for the analysis. Emissions of all GHGs should be converted into their equivalent global warming potential in terms of CO2 (CO2e). Calculations should be based on the current methodologies recommended by the CAPCOA and the APCD.45, 46 Construction GHG Emissions
Construction activities emit GHGs primarily though combustion of fuels (mostly diesel) in the engines of off-road construction equipment and in on-road construction vehicles and in the commute vehicles of the construction workers. Smaller amounts of GHGs are emitted indirectly through the energy required for water used for fugitive dust control and lighting for the construction activity. Every phase of the construction process, including demolition, grading, paving, and building, emits GHG emissions in volumes proportional to the quantity and type of construction equipment used. Heavier equipment typically emits more GHGs per hour than lighter equipment because of their engine design and greater fuel consumption.

The APCD recommends quantifying and disclosing construction related GHG emissions for informational purposes.47 CalEEMod generates a default construction schedule and equipment list based on the plan-/project-specific information, including land use, project size, location, and construction timeline.48 In general, if specific applicant-provided information is unknown, the default construction equipment list and phase lengths are the most appropriate inputs. However, if 44 The most current available version of CalEEMod should be used. As of August 2023, CalEEMod version 2022.1 is the most current version and should be used to quantify project-level emissions. 45 California Air Pollution Control Officers Association. 2008. CEQA and Climate Change: Addressing Climate Change through California Environmental Quality Act (CEQA). January 2008.
46Santa Barbara APCD. 2021. Environmental Thresholds and Guidelines Manual. Accessed at https://www.sblafco.org/files/f2915ea5d/Information_Item_No_1___Attachment_B_Environmental_Thresholds_Amended_January_202

1.pdf.
47 Cumulative GHG emissions associated with construction from a land use development project are generally orders of magnitude lower than the operational emissions from a project because construction emissions are generally short in duration compared to the project’s overall lifetime, and thus can be assessed qualitatively as part of related CEQA GHG emissions analysis. However, some projects may have long construction periods or entail large quantities of cut and fill that could result in construction-related GHG emissions that may be considered significant. Thus, the City retains the discretion on a project-by-project basis to consider whether a project’s constructionrelated GHG emissions could be cumulatively considerable and require more detailed quantitative CEQA GHG emissions analysis and respective mitigation.
48CAPCOA. 2022. California Emissions Estimator Model User Guide: Version 2022.1. Prepared by ICF in collaboration with Sacramento Metropolitan Air Quality Management District, Fehr & Peers, STI, and Ramboll. http://www.aqmd.gov/caleemod/user's-guide.

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more detailed site-specific equipment and phase information (i.e., data from the project applicant) is available, the model’s default values can (and should) be overridden.49 Operational GHG Emissions
CalEEMod estimates operational emissions of CO2, N2O, and CH4 generated by area sources, energy use, vehicle trips (i.e., mobile sources), waste generation, and water use and conveyance.

Operational emissions should be calculated for the year 2030, rather than the project buildout year, in order to provide an appropriate comparison of project emissions to the year 2030 threshold.

Area Source Emissions
Area sources include GHG emissions that would occur from the use of landscaping equipment, hearths, and woodstoves, which emit GHGs associated with the equipment’s fuel combustion. The landscaping equipment emission values in CalEEMod are derived from CARB’s Small Off-Road Engines Model v1.1 (SORE2020).50 Emission rates for combustion of wood and natural gas for wood stoves and fireplaces are based on those published by the U.S. EPA. Typically, no adjustments to landscaping equipment inputs are necessary. The number of hearths and woodstoves should be adjusted in CalEEMod to reflect the project design.

Energy Use Emissions
GHGs are emitted on-site during the combustion of natural gas for cooking, space and water heating, and decorative uses and off-site during the generation of electricity from fossil fuels in power plants. CalEEMod estimates GHG emissions from energy use by multiplying average rates of residential and non-residential energy consumption by the quantities of residential units and nonresidential square footage entered in the land use module to obtain total projected energy use. This value is then multiplied by electricity and natural gas GHG emission factors applicable to the project location and utility provider. Building energy use is typically divided into energy consumed by the built environment and energy consumed by uses that are independent of the building, such as plugin appliances. Non-building energy use, or “plug-in energy use,” can be further subdivided by specific end-use (refrigeration, cooking, office equipment, etc.). In California, Title 24 governs energy consumed by the built environment, mechanical systems, and some types of fixed lighting.

Electricity emissions are calculated by multiplying the energy use by the carbon intensity of the utility district per kilowatt hour.51 Projects would be served either by Santa Barbara Clean Energy [SBCE] or SCE. The specific energy intensity factors (i.e., the amount of CO2, CH4, and N2O per kilowatt-hour) for the applicable utility should be used in the calculations of GHG emissions.

As of publication of this guidance document, the current iteration of Title 24 includes the 2022 Building Energy Efficiency Standards. In accordance with Section 150.1(b)14 of the 2022 Building Energy Efficiency Standards, all new residential uses three stories or less must install photovoltaic (PV) solar panels that generate an amount of electricity equal to the expected electricity usage. The calculation method contained in Section 150.1(b)14 of the 2022 Building Energy Efficiency Standards should be utilized to estimate the number of kilowatts of PV solar panels that would be required for a residential project three stories or less. In addition, modeling should account for any local 49Ibid.
50Ibid.
51Ibid.

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regulations pertaining to mandatory solar provisions. Online resources can be used to determine the kilowatt-hours that would be generated per year by the required solar PV system.52 The energy reduction achieved by on-site PV solar panels should be included in CalEEMod. Future updates to Title 24 as they relate to the Building Energy Efficiency Standards should be incorporated into CalEEMod as applicable.

Mobile Source Emissions
CalEEMod quantifies mobile source emissions generated by vehicle trips associated with the proposed project. If available, project-specific trip generation rates or Vehicle Miles Travelled (VMT) data should be input in CalEEMod.

Water and Wastewater Emissions
The amount of water used, and the amount of wastewater generated by a project generate indirect GHG emissions. These emissions are a result of the energy used to supply, convey, and treat water and wastewater. In addition to the indirect GHG emissions associated with energy use, the wastewater treatment process itself can directly emit both CH4 and N2O.

CalEEMod calculates indoor residential water consumption based on per capita daily water use rates from the Residential End Uses of Water published by the Water Research Foundation in 2016. For non-residential land uses, indoor water use comes from the Pacific Institute’s (2003) Waste Not, Want Not: The Potential for Urban Water Conservation in California.53 Outdoor water use is based on the Maximum Applied Water Allowance Method established under the Model Water Efficient Landscape Ordinance. Wastewater generation is based on a reported percentage of total indoor water use.

Future updates to Title 24 as they relate to CALGreen water efficiency requirements should be incorporated into CalEEMod as applicable.

Solid Waste Emissions
The disposal of solid waste produces GHG emissions from the transportation of waste, anaerobic decomposition in landfills, and incineration. To calculate the GHG emissions generated by solid waste disposal, the total volume of solid waste is calculated using waste disposal rates identified by CalRecycle. The methods for quantifying GHG emissions from solid waste are based on the IPCC method, using the degradable organic content of waste. CEQA document preparers should contact the City's Public Works Department to obtain the City’s most recent solid rate diversion rate to be included in the calculation of solid waste GHG emissions.

Project Design Features
CEQA document preparers should use the “Mitigation” tabs in CalEEMod to include project design features applicable to the project.54 These features often include increased density, improved destination accessibility, proximity to transit, integration of below market rate housing, unbundling 52 Lane, Catherine. 2023.” How much electricity does a solar panel produce?” Last updated: June 13, 2023. https://www.solarpowerrocks.com/solar-basics/how-much-electricity-does-a-solar-panel-produce/. 53CAPCOA. 2022. California Emissions Estimator Model User Guide: Version 2022.1. Prepared by ICF in collaboration with Sacramento Metropolitan Air Quality Management District, Fehr & Peers, STI, and Ramboll. http://www.aqmd.gov/caleemod/user's-guide. 54 “Mitigation” is a term of art for the modeling input and is not equivalent to mitigation measures that may apply to the CEQA impact analysis.

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of parking costs, provision of transit subsidies, implementation of alternative work schedules, use of energy- and/or water-efficient appliances, use of reclaimed and/or grey water, and installation of water-efficient irrigation system. Users should consider the applicability of these features to the project and review the CAPCOA Quantifying Greenhouse Gas Mitigation Measures (2010) publication to ensure that the chosen features are relevant and feasible in light of the project.55 Residents, Employees, and Service Populations
The quantitative thresholds presented in Section 4, Quantitative CEQA GHG Thresholds, are expressed in terms of per resident for residential projects, per employee for non-residential projects, and per service person for mixed-use projects. Estimates of the resident, employee, or service population for a project should be based on substantial evidence. Data provided by the applicant as well as the following resources may be utilized in estimating resident and employee populations:
ƒ Persons per Household. Users should refer to the California Department of Finance website (https://www.dof.ca.gov/Forecasting/Demographics/Estimates/e-5/) for the most recent estimate of persons per household in the City of Santa Barbara. This estimate can be multiplied by the number of proposed residential units to estimate a project’s resident population. ƒ Proposed Number of Beds. For projects such as group homes, assisted living facilities, nursing homes, or similar uses, the number of beds can be used to determine the resident population. ƒ United States Green Building Council. The United States Green Building Council has published a summary of building area per employee by business type. These rates, which are expressed in terms of square feet per employee, can be utilized to estimate the number of employees a project would require. This document is included as Appendix G.

Modeling GHG Emissions from Existing Land Use
For a project that would result in a change in the plan area/project’s site General Plan land use designation, emissions anticipated for the existing General Plan land use designation must be calculated in conjunction with emissions for the proposed project to demonstrate whether the project would be more or less GHG-intensive than development anticipated for the existing General Plan land use designation for the site. In this case, GHG emissions should be reported for both the existing and proposed scenarios. If there is a land use designation that allows multiple uses, the project could model the most intensive permitted use from the GHG perspective and compare the project to that as the baseline.

Emissions anticipated for the existing land use should be quantified using the methods described in Construction Emissions, and Operational Emissions with consistent assumptions between the two scenarios as applicable. Any emission reduction credits applied to the proposed project scenario that are related to state legislation/policies (e.g., the RPS, vehicle standards, Title 24) or the plan area/project site location (e.g., proximity to transit, destination accessibility, etc.) should also be applied to the existing scenario.

Emission reduction credits that are specific to the proposed project (e.g., use of recycled water, increased density, installation of energy and/or water-efficient appliances, integration of below market rate housing, etc.) should only be included for the proposed project scenario. In addition, 55 CAPCOA. 2010. Quantifying Greenhouse Gas Mitigation Measures. August 2010. http://www.capcoa.org/wpcontent/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf.

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care should be taken to identify any emission reduction credits that might be unique to the existing land use designation that would not apply to the proposed project. For example, if the existing land use designation allows for single-family residences and the proposed land use designation would allow for only commercial uses, then the existing scenario should include the emission reduction credit associated with the 2022 Building Energy Efficiency Standards requirements for PV solar panels on residential uses that are three stories or less whereas the proposed project scenario should not include this credit unless PV solar panels are included as a project design feature.

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Appendix D
Regulatory and Legal Setting

Regulatory and Legal Setting
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Regulatory and Legal Setting
The following regulations, executive orders, and case law pertain to the analysis of GHG emissions consistent with CEQA and the CEQA Guidelines.

Relevant CEQA Guidelines Sections
Pursuant to the requirements of SB 97, the California Natural Resources Agency has adopted amendments to the CEQA Guidelines for the feasible mitigation of GHG emissions or the effects of GHG emissions. The adopted CEQA Guidelines provide general regulatory guidance on the analysis and mitigation of GHG emissions in CEQA documents, while giving lead agencies the discretion to set quantitative or qualitative thresholds for the assessment and mitigation of GHG emissions and climate change impacts.

Based on Appendix G of the CEQA Guidelines, impacts related to GHG emissions generated by a proposed project would be significant if the project would:
ƒ Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment; and/or
ƒ Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs.

The vast majority of individual projects do not generate sufficient GHG emissions to directly influence climate change. However, physical changes caused by a project can contribute incrementally to cumulative effects that are significant, even if individual changes resulting from a project are limited. As discussed in Appendix B, the adverse environmental impacts of cumulative GHG emissions, including sea level rise, increased average temperatures, more drought years, and more frequent and larger forest fires, are already occurring. As a result, cumulative impacts related to GHG emissions and climate change are significant. Therefore, per CEQA Guidelines Section 15064.4(b), the analysis of GHG emissions under CEQA typically involves an analysis of whether a project’s contribution towards an impact would be cumulatively considerable. “Cumulatively considerable” means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, other current projects, and probable future projects (CEQA Guidelines Section 15064[h][1]).

The following sections of the CEQA Guidelines pertain to the creation of significance thresholds and the analysis of a project’s GHG emissions.

CEQA Guidelines Section 15064(b)
(1) The determination of whether a project may have a significant effect on the environment calls for careful judgment on the part of the public agency involved, based to the extent possible on scientific and factual data. An ironclad definition of significant effect is not always possible because the significance of an activity may vary with the setting. For example, an activity which may not be significant in an urban area may be significant in a rural area.
(2) Thresholds of significance, as defined in Section 15064.7(a), may assist lead agencies in determining whether a project may cause a significant impact. When using a threshold, the City of Santa Barbara
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lead agency should briefly explain how compliance with the threshold means that the project’s impacts are less than significant. Compliance with the threshold does not relieve a lead agency of the obligation to consider substantial evidence indicating that the project’s environmental effects may still be significant.56
CEQA Guidelines Section 15064.4
(a) The determination of the significance of GHG emissions calls for a careful judgment by the lead agency consistent with the provisions in section 15064. A lead agency shall make a good-faith effort, based to the extent possible on scientific and factual data, to describe, calculate or estimate the amount of GHG emissions resulting from a project. A lead agency shall have discretion to determine, in the context of a particular project, whether to (1) Quantify GHG emissions resulting from a project; and/or (2) Rely on a qualitative analysis or performance-based standards. (b) In determining the significance of a project’s GHG emissions, the lead agency should focus its analysis on the reasonably foreseeable incremental contribution of the project’s emissions to the effects of climate change. A project’s incremental contribution may be cumulatively considerable even if it appears relatively small compared to statewide, national or global emissions. The agency’s analysis should consider a timeframe that is appropriate for the project. The agency’s analysis also must reasonably reflect evolving scientific knowledge and state regulatory schemes. A lead agency should consider the following factors, among others, when determining the significance of impacts from GHG emissions on the environment:
(1) The extent to which the project may increase or reduce GHG emissions as compared to the existing environmental setting.
(2) Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project.
(3) The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions (see, e.g., section 15183.5[b]). Such requirements must be adopted by the relevant public agency through a public review process and must reduce or mitigate the project’s incremental contribution of GHG emissions. If there is substantial evidence that the possible effects of a particular project are still cumulatively considerable notwithstanding compliance with the adopted regulations or requirements, an Environmental Impact Report (EIR) must be prepared for the project. In determining the significance of impacts, the lead agency may consider a project’s consistency with the State’s long-term climate goals or strategies, provided that substantial evidence supports the agency’s analysis of how those goals or strategies address the project’s incremental contribution to climate change and its conclusion that the project’s incremental contribution is not cumulatively considerable. (c) A lead agency may use a model or methodology to estimate GHG emissions resulting from a project. The lead agency has discretion to select the model or methodology it considers most appropriate to enable decision makers to intelligently take into account the project’s incremental contribution to climate change. The lead agency must support its selection of a 56 2023 CEQA Guidelines. Available at: https://www.califaep.org/docs/CEQA_Handbook_2023_final.pdf Regulatory and Legal Setting
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model or methodology with substantial evidence. The lead agency should explain the limitations of the particular model or methodology selected for use.57 CEQA Guidelines Section 15064.7
(a) A threshold of significance is an identifiable quantitative, qualitative or performance level of a particular environmental effect, non-compliance with which means the effect will normally be determined to be significant by the agency and compliance with which means the effect normally will be determined to be less than significant. (b) Each public agency is encouraged to develop and publish thresholds of significance that the agency uses in the determination of the significance of environmental effects. Thresholds of significance to be adopted for general use as part of the lead agency’s environmental review process must be adopted by ordinance, resolution, rule, or regulation, and developed through a public review process and be supported by substantial evidence. Lead agencies may also use thresholds on a case-by-case basis as provided in Section 15064(b)(2). (c) When adopting or using thresholds of significance, a lead agency may consider thresholds of significance previously adopted or recommended by other public agencies or recommended by experts, provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence.
(d) Using environmental standards as thresholds of significance promotes consistency in significance determinations and integrates environmental review with other environmental program planning and regulation. Any public agency may adopt or use an environmental standard as a threshold of significance. In adopting or using an environmental standard as a threshold of significance, a public agency shall explain how the particular requirements of that environmental standard reduce project impacts, including cumulative impacts, to a level that is less than significant, and why the environmental standard is relevant to the analysis of the project under consideration. For the purposes of this subdivision, an “environmental standard” is a rule of general application that is adopted by a public agency through a public review process and that is all the following:
(1) a quantitative, qualitative or performance requirement found in an ordinance, resolution, rule, regulation, order, plan or other environmental requirement; (2) adopted for the purpose of environmental protection; (3) addresses the environmental effect caused by the project; and, (4) applies to the project under review.58
CEQA Guidelines Section 15183.5
(a) Lead agencies may analyze and mitigate the significant effects of GHG emissions at a programmatic level, such as in a general plan, a long-range development plan, or a separate plan to reduce GHG emissions. Later project-specific environmental documents may tier from and/or incorporate by reference that existing programmatic review. Project-specific environmental documents may rely on an EIR containing a programmatic analysis of GHG emissions as provided in section 15152 (tiering), 15167 (staged EIRs) 15168 (program EIRs), 57 Ibid.
58 Ibid.

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15175–15179.5 (Master EIRs), 15182 (EIRs Prepared for Specific Plans), and 15183 (EIRs Prepared for General Plans, Community Plans, or Zoning). (b) Plans for the Reduction of GHG Emissions. Public agencies may choose to analyze and mitigate significant GHG emissions in a plan for the reduction of GHG emissions or similar document. A plan to reduce GHG emissions may be used in a cumulative impacts analysis as set forth below. Pursuant to sections 15064(h)(3) and 15130(d), a lead agency may determine that a project’s incremental contribution to a cumulative effect is not cumulatively considerable if the project complies with the requirements in a previously adopted plan or mitigation program under specified circumstances. (1) Plan Elements. A plan for the reduction of GHG emissions should:
(A) Quantify GHG emissions, both existing and projected over a specified time period, resulting from activities within a defined geographic area; (B) Establish a level, based on substantial evidence, below which the contribution to GHG emissions from activities covered by the plan would not be cumulatively considerable;
(C) Identify and analyze the GHG emissions resulting from specific actions or categories of actions anticipated within the geographic area;
(D) Specify measures or a group of measures, including performance standards, that substantial evidence demonstrates, if implemented on a project-by-project basis, would collectively achieve the specified emissions level; (E) Establish a mechanism to monitor the plan’s progress toward achieving the level and to require amendment if the plan is not achieving specified levels; (F) Be adopted in a public process following environmental review. (2) Use with Later Activities. A plan for the reduction of GHG emissions, once adopted following certification of an EIR or adoption of an environmental document, may be used in the cumulative impacts analysis of later projects. An environmental document that relies on a GHG reduction plan for a cumulative impacts analysis must identify those requirements specified in the plan that apply to the project, and, if those requirements are not otherwise binding and enforceable, incorporate those requirements as mitigation measures applicable to the project. If there is substantial evidence that the effects of a particular project may be cumulatively considerable, notwithstanding the project’s compliance with the specified requirements in the plan for the reduction of GHG emissions, an EIR must be prepared for the project. (c) Special Situations. As provided in Public Resources Code sections 21155.2 and 21159.28, environmental documents for certain residential and mixed use projects, and transit priority projects, as defined in section 21155, that are consistent with the general use designation, density, building intensity, and applicable policies specified for the project area in an applicable sustainable communities strategy or alternative planning strategy need not analyze global warming impacts resulting from cars and light duty trucks. A lead agency should consider whether such projects may result in GHG emissions resulting from other sources, however, consistent with these Guidelines.59
59 Ibid.

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CEQA Guidelines Section 15126.4(c)
Consistent with section 15126.4(a), lead agencies shall consider feasible means, supported by substantial evidence and subject to monitoring or reporting, of mitigating the significant effects of GHG emissions. Measures to mitigate the significant effects of GHG emissions may include, among others:
(1) Measures in an existing plan or mitigation program for the reduction of emissions that are required as part of the lead agency’s decision;
(2) Reductions in emissions resulting from a project through implementation of project features, project design, or other measures, such as those described in Appendix F of the CEQA Guidelines;
(3) Off-site measures, including offsets that are not otherwise required, to mitigate a project’s emissions;
(4) Measures that sequester GHGs;
(5) In the case of the adoption of a plan, such as a general plan, long range development plan, or plans for the reduction of GHG emissions, mitigation may include the identification of specific measures that may be implemented on a project-by-project basis. Mitigation may also include the incorporation of specific measures or policies found in an adopted ordinance or regulation that reduces the cumulative effect of emissions.60 Relevant State and Regional GHG Reduction Targets
Executive Order S-03-05
On June 1, 2005, the governor issued EO S-03-05, which established a statewide goal of reducing GHG emissions to 1990 levels by 2020 and created the Climate Action Team. The 2020 GHG emission reduction target contained in EO S-03-05 was later codified by Assembly Bill (AB) 32.

Assembly Bill 32
California’s major initiative for reducing GHG emissions is outlined in AB 32, the “California Global Warming Solutions Act of 2006,” which was signed into law in 2006. AB 32 codifies the State’s goal of reducing statewide GHG emissions to 1990 levels by 2020 and requires the California Air Resources Board (CARB) to prepare a Scoping Plan that outlines the main state strategies for reducing GHG emissions to meet the 2020 deadline. In addition, AB 32 requires CARB to adopt regulations to require reporting and verification of statewide GHG emissions. Based on this guidance, CARB approved a 1990 statewide GHG level and 2020 limit of 427 million metric tons (MMT) of CO2e. The Scoping Plan was approved by CARB on December 11, 2008, and included measures to address GHG emission reduction strategies related to energy efficiency, water use, and recycling and solid waste, among other measures. Many of the GHG reduction measures included in the Scoping Plan (e.g., Low Carbon Fuel Standard, Advanced Clean Car standards, and Cap-andTrade) have been adopted since approval of the Scoping Plan.61 In May 2014, CARB approved the first update to the AB 32 Scoping Plan. The 2013 Scoping Plan update defined CARB’s climate change priorities for the next five years and set the groundwork to 60 Ibid.
61 CARB. 2008. Climate Change Scoping Plan. December 2008. https://www.arb.ca.gov/cc/scopingplan/document/adopted_scoping_plan.pdf.

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reach post-2020 statewide goals. The update highlighted California’s progress toward meeting the “near-term” 2020 GHG emission reduction goals defined in the original Scoping Plan. It also evaluated how to align the State’s longer-term GHG reduction strategies with other state policy priorities, including those for water, waste, natural resources, clean energy, transportation, and land use. 62
Senate Bill 32
On September 8, 2016, the governor signed SB 32 into law, extending AB 32 by requiring the statewide reduction of GHG emissions to 40 percent below 1990 levels by 2030 (the other provisions of AB 32 remain unchanged). In November 2022, CARB published California’s 2022 Scoping Plan for Achieving Carbon Neutrality (Third Update). This update extends the previous Scoping Plans and lays out a path to achieve carbon neutrality no later than 2045, as directed by AB 1279. The previous 2017 Scoping Plan lays out a technologically feasible and cost-effective path to achieve the 2030 GHG reduction target by leveraging existing programs such as the Renewables Portfolio Standard, Advanced Clean Cars, Low Carbon Fuel Standard, Short-Lived Climate Pollutant (SLCP) Reduction Strategy, Cap-and-Trade Program, and Mobile Source Strategy that includes strategies targeted to increase zero emission vehicle fleet penetration. The 2022 Scoping Plan looks toward the 2045 climate goals and the deeper GHG reductions needed to meet the State’s statutory carbon neutrality target specified in AB 1279 and EO B-55-18.63 Senate Bill 375
SB 375, signed in August 2008, enhances the State’s ability to reach AB 32 goals by directing CARB to develop regional GHG emission reduction targets to be achieved from passenger vehicles by 2020 and 2035. SB 375 aligns regional transportation planning efforts, regional GHG reduction targets, and affordable housing allocations. Metropolitan Planning Organizations (MPOs) are required to adopt a Sustainable Communities Strategy (SCS), which allocates land uses in the MPO’s Regional Transportation Plan (RTP). Qualified projects consistent with an approved SCS or Alternative Planning Strategy categorized as “transit priority projects” would receive incentives to streamline CEQA processing.

On March 22, 2018, CARB adopted updated regional targets for reducing GHG emissions from 2005 levels by 2020 and 2035. The Association of Bay Area Governments (ABAG) was assigned targets of a 7 percent reduction in GHGs from transportation sources by 2020 and a 15 percent reduction in GHGs from transportation sources by 2035. ABAG adopted the 2050 RTP (Plan Bay Area 2050) in October 2021, which includes the region’s SCS and meets the requirements of SB 375.64 Assembly Bill 1279
AB 1279, signed in September 2022, builds upon EO B-55-18, which originally established California’s 2045 goal of carbon neutrality and tasked CARB with including a pathway toward the EO B-55-18 carbon neutrality goal in the 2022 Scoping Plan. AB 1279 codified the statewide carbon neutrality goal into a legally binding requirement for California to achieve carbon neutrality no later 62 CARB. 2014. First Update to the Climate Change Scoping Plan. May 15, 2014. Available at:
https://ww3.arb.ca.gov/cc/scopingplan/2013_update/first_update_climate_change_scoping_plan.pdf. 63 CARB. 2022. 2022 Scoping Plan for Achieving Carbon Neutrality. Available at: https://ww2.arb.ca.gov/sites/default/files/2023-04/2022- sp.pdf
64 Association of Bay Area Governments. October 2021. Plan Bay Area 2050.

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than 2045 and ensure 85 percent65 GHG emissions reduction under that goal. This goal is in addition to the existing statewide GHG emission reduction targets established by SB 375, SB 32, SB 1383, and SB 100.

Senate Bill 100
Adopted in September 2018, SB 100 supports the reduction of GHG emissions from the electricity sector by accelerating the State’s Renewables Portfolio Standard Program, which was last updated by SB 350 in 2015. SB 100 requires electricity providers to increase procurement from eligible renewable energy resources to 33 percent of total retail sales by 2020, 60 percent by 2030, and 100 percent by 2045.

Senate Bill 1383
Adopted in September 2016, SB 1383 (Lara, Chapter 395, Statutes of 2016) requires CARB to approve and begin implementing a comprehensive strategy to reduce emissions of short-lived climate pollutants. SB 1383 requires the strategy to achieve the following reduction targets by 2030:
ƒ Methane – 40 percent below 2013 levels
ƒ Hydrofluorocarbons – 40 percent below 2013 levels
ƒ Anthropogenic black carbon – 50 percent below 2013 levels SB 1383 also requires the California Department of Resources Recycling and Recovery (CalRecycle), in consultation with CARB, to adopt regulations that achieve specified targets for reducing organic waste in landfills.

Relevant GHG Emissions Analysis Case Law
Friends of Oroville v. City of Oroville (Case No. 070448) The Third District Court of Appeal decision in the Friends of Oroville v. City of Oroville case was published on August 19, 2013. This decision evaluated the methodology used to analyze GHG emissions in an EIR prepared for a Wal-Mart Supercenter development project that included replacing an existing Wal-Mart store with a Wal-Mart Supercenter in Oroville in Butte County. The EIR used consistency with the AB 32 emissions reduction target as its significance threshold for evaluating the project’s GHG emissions and compared the magnitude of the proposed project’s emissions to statewide 2004 emission levels as part of the analysis. The Court found that EIR applied “a meaningless, relative number to determine insignificant impact” rather than evaluating the project’s emissions in light of the AB 32 emissions reduction target. The Court also found that the EIR “misapplied the [AB] 32 threshold-of-significance standard by [1] failing to calculate the GHG emissions for the existing Wal-Mart and [2] failing to quantitatively or qualitatively ascertain or estimate the effect of the Project’s mitigation measures on GHG emissions.” The Court determined that the EIR could and should have performed these quantifications to adequately evaluate the project’s GHG emissions using the AB 32 emissions reduction target. 65 To achieve carbon neutrality, the remaining 15 percent of GHG emissions would be achieved through carbon capture and sequestration efforts.

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Sierra Club v. County of San Diego (Case No. 37-2018-00043084-CU-TT-CTL) The Fourth District Court of Appeal decision in the Sierra Club v. County of San Diego case was published on October 29, 2014. This decision evaluated the adequacy of the CAP Update prepared by the County of San Diego to satisfy Mitigation Measure CC-1.2 of the program EIR prepared for its 2011 General Plan. To reduce GHG emissions impacts of the 2011 General Plan to a less-thansignificant level, Mitigation Measure CC-1.2 required the preparation of a CAP Update that would include “more detailed GHG emissions reduction targets and deadlines” and that would “achieve comprehensive and enforceable GHG emissions reduction of 17 percent (totaling 23,572 MT of CO2e) from County operations from 2006 by 2020 and 9 percent reduction (totaling 479,717 MT of CO2e) in community emissions from 2006 by 2020.” The Court found the CAP Update did not include enforceable and feasible GHG emission reduction measures that would achieve the necessary emissions reduction; therefore, the CAP Update did not meet the requirements of Mitigation Measure CC-1.2 and would not ensure that the mitigation measure would reduce GHG emissions to a less-than-significant impact. In addition, the Court found that the County failed to evaluate the environmental impacts of the CAP Update and its associated thresholds of significance under CEQA.

Center for Biological Diversity v. California Department of Fish and Wildlife (Case No. 217763)
The California Supreme Court’s decision in the Center for Biological Diversity v. California Department of Fish and Wildlife case was published on November 30, 2015. This decision evaluated the methodology used to analyze GHG emissions in an EIR prepared for the Newhall Ranch development project that included approximately 20,885 dwelling units with 58,000 residents on 12,000 acres of undeveloped land in Los Angeles County. The EIR used a business-as-usual approach to evaluate whether the project would be consistent with the AB 32 Scoping Plan. The Court found there was insufficient evidence in the record of that project to explain how a project that reduces its GHG emissions by the same percentage as the business-as-usual reduction identified for the State to meet its statewide targets supported a conclusion that project-level impacts were below the level of significance.

The California Supreme Court suggested regulatory consistency as a pathway to compliance by stating that a lead agency might assess consistency with the State’s GHG reduction goals by evaluating for compliance with regulations designed to reduce GHG emissions. This approach is consistent with CEQA Guidelines Section 15064.4(b), which provides that a determination of an impact is not cumulatively considerable to the extent to which the project complies with regulations or requirements implementing a statewide, regional, or local plan to reduce or mitigate GHG emissions. The Court also found that a lead agency may rely on numerical and efficiency-based thresholds of significance for GHG emissions, if supported by substantial evidence.

Golden Door Properties, LLC v. County of San Diego/Sierra Club, LLC v.

County of San Diego (Case No. 072406)
The Fourth District Court of Appeal decision in the Golden Door Properties, LLC v. County of San Diego case (published on September 28, 2018) evaluated the County of San Diego’s 2016 Guidance Document’s GHG efficiency metric, which establishes a generally applicable threshold of significance for proposed projects. The Court held that the County of San Diego is barred from using its 2016 Guidance Document’s threshold of significance of 4.9 MT CO2e per service person per year for GHG analysis. The Court stated that the document violated CEQA because it was not adopted formally by ordinance, rule, resolution, or regulation through a public review process per CEQA Guidelines Regulatory and Legal Setting
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Section 15064.7(b). The Court also found that the threshold was not supported by substantial evidence that adequately explained how a service population threshold derived from statewide data could constitute an appropriate GHG metric to be used for all projects in unincorporated San Diego County. Nevertheless, lead agencies may make plan- or project-specific GHG emissions threshold determinations.

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Appendix E
CEQA GHG Threshold Calculations

CEQA GHG Threshold Calculations
Final Draft E-1CEQA GHG Threshold Calculations
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Master Environmental Assessment Guidelines for Greenhouse Gas Emissions AnalysisE-2 Appendix F
Justification for Thresholds

Justification for Thresholds
Final Draft F-1
Justification for Thresholds
Per CEQA Guidelines Section 15064(b)(1), “the determination of whether a project may have a significant effect on the environment calls for careful judgment on the part of the public agency involved, based to the extent possible on scientific and factual data.” In addition, CEQA Guidelines Section 15064(b)(2) states, “When using a threshold, the lead agency should briefly explain how compliance with the threshold means that the project’s impacts are less than significant.” Furthermore, CEQA Guidelines Section 15064.7(b) states “Thresholds of significance to be adopted for general use as part of the lead agency’s environmental review process must be adopted by ordinance, resolution, rule, or regulation, and developed through a public review process and be supported by substantial evidence.” Therefore, the key considerations when developing thresholds of significance are 1) the thresholds’ basis on scientific and factual data; 2) demonstration of how compliance with the thresholds reduces project impacts to a less-than-significant level; 3) support of the thresholds by substantial evidence; and 4) adoption of the thresholds by ordinance, resolution, rule, or regulation, and developed through a public review process. The following subsections address these four key considerations.

Basis of Scientific and Factual Data
As discussed in Appendix C Quantifying GHG Emissions, the quantitative thresholds were developed using data from the City’s 2019 communitywide GHG inventory and the GHG emissions forecasts for year 2030. The inventory and forecasts were developed by the City in compliance with all relevant protocols and guidance documents, including the U.S. Community Protocol for Accounting and Reporting of Greenhouse Gas Emissions, the Global Protocol for Community Scale GHG Emissions, and the Intergovernmental Panel on Climate Change (IPCC) Guidelines for National GHG Inventories.

Furthermore, the inventory and forecasts are based on locally appropriate data for the City of Santa Barbara provided by SBCAG, Southern California Edison (SCE), Southern California Gas (SoCalGas), Iteris, Inc., CARB, and the City of Santa Barbara.66 Therefore, the GHG emission inventory and forecast data underlying the thresholds is both scientific and factual.

As discussed in Appendix A Climate Action Plan Summary, implementation of the Santa Barbara CAP Update will achieve a 47 percent reduction in total communitywide GHG emissions below 1990 emissions levels by 2030. Therefore, this local target is aligned with the State’s goal of a 40 percent emission reduction in 1990 levels by 2030 and makes substantial progress toward achieving the State’s long-term goal of carbon neutrality by 2045. The quantitative thresholds are tied directly to the level of GHG emissions anticipated for new development in the CAP Update for year 2030. As a result, because the CAP Update is consistent with the State’s 2030 GHG emission goal, the quantitative thresholds are also consistent with the state milestone GHG emission reduction goal for 2030. The State’s GHG emission reduction goals for 2030 and 2045 are set at the levels scientists say are necessary to meet the Paris Agreement goals to reduce GHG emissions and limit global temperature rise below two degrees Celsius by 2100 in order to avoid dangerous climate change (CARB 2017; EO B-55-18). Therefore, the City’s GHG emission reduction targets that inform the CAP Update and the associated quantitative thresholds are based on scientific and factual data on the 66 Santa Barbara, City of. 2023. Community Greenhouse Gas Inventory, Forecast, and Target Analysis.

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level of emissions reduction necessary to avoid a cumulatively considerable contribution to the cumulative impact of climate change.

Reduction of Project Impacts to a Less-than-Significant Level
The quantitative GHG thresholds shown in Appendix A Climate Action Plan Summary, are tied directly to the level of GHG emissions anticipated for new development in the CAP Update for year 2030. Therefore, the thresholds are consistent with the City’s local GHG emission reduction target, which is consistent with the State’s GHG emission reduction goals. Since the quantitative thresholds are set at the level necessary to ensure the City does not have a cumulatively considerable contribution to the cumulative impact of climate change, plans and projects with GHG emissions at or below the quantitative thresholds would also not have a cumulatively considerable contribution to the cumulative impacts of climate change, and project impacts would be less than significant.

Support of Substantial Evidence
Substantial evidence regarding the calculation of the quantitative GHG emissions thresholds is provided in Appendix E CEQA GHG Threshold Calculations. The following subsections provide additional evidence of how the GHG emissions thresholds are locally appropriate and plan- or project-specific and how the thresholds distinguish between existing and new development.

Use of Local Data
The quantitative thresholds were developed using the City’s communitywide GHG emissions forecast for year 2030 and are therefore specific to the City of Santa Barbara. The thresholds are directly tied to the population and employment growth anticipated by SBCAG Connected 2050 projections, and in alignment with the Santa Barbara General Plan as well as to the City-specific GHG emission reduction measures that the City has proposed to reduce communitywide and per capita emissions. In addition, the magnitude of local GHG emission reduction achieved by state legislation/policies (i.e., vehicle fuel efficiency standards, the Renewable Portfolio Standard [RPS], and Title 24) was estimated based on City-specific growth and vehicle VMT forecasts. As a result, these locally appropriate thresholds directly address the concerns raised in the Golden Door Properties, LLC v. County of San Diego/Sierra Club, LLC v. County of San Diego (2018) case, because they are based on local GHG emissions data rather than statewide GHG emissions data.

Disaggregation of Existing versus New Development
For the City of Santa Barbara, a GHG threshold disaggregated between new and existing development places a disproportionately high emphasis on emissions reduction from existing development, given the proposed CAP Update measures. This necessitated applying the emissions reduction across both new development and existing development to produce per capita GHG thresholds. CAP-adjusted emissions for existing and new development were combined to create communitywide GHG emissions thresholds. This approach is more conservative than disaggregating by new versus existing development as it accounts for the relative ease for new development to be decarbonized and builds in some buffer for emissions reduction required of existing development to achieve CAP Update reductions. Therefore, these thresholds directly address the concerns raised in the Center for Biological Diversity v. California Department of Fish and Wildlife (2015) case regarding Justification for Thresholds
Final Draft F-3
the different rates of GHG emissions reduction anticipated for new development as compared to existing development in order to meet the specified GHG reduction target.

Selection of Sector-Specific Thresholds
The quantitative thresholds are separated into three categories – residential, non-residential, and mixed-use – which are intended to apply to the three main types of development projects in Santa Barbara. These thresholds were calculated by disaggregating the City’s business-as-usual GHG emissions forecasts for residential and non-residential development. The emissions reduction specific to residential and non-residential development achieved by state legislation/policies and the CAP Update were then subtracted from the business-as-usual forecast to determine “caps” of emissions for new residential and new non-residential development for year 2030. These emissions “caps” were then divided by the numbers of residents and employees forecast for the year 2030 to determine efficiency thresholds for residential and non-residential projects, respectively. For mixeduse development, the residential and non-residential emissions “caps” were summed, then divided by the service population forecast for 2030 to determine an efficiency threshold for mixed-use projects. As a result, these project-specific thresholds directly address the concerns raised in the Center for Biological Diversity v. California Department of Fish and Wildlife (2015) case, because they are specific to each development project type.

Adoption via Public Review Process
In compliance with CEQA Guidelines Section 15064.7(b), this guidance document and the quantitative thresholds contained herein was presented to the City Council for formal adoption via resolution through a public review process, which included an opportunity for public input. The public review process for this City of Santa Barbara Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis afforded the public to the ability to comment on the draft resolution item during a public meeting (i.e., City Council meeting) considering adoption of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions and CAP Update IS-ND.

This process directly addresses the concerns raised in the Golden Door Properties, LLC v. County of San Diego/Sierra Club, LLC v. County of San Diego (2018) case regarding formal adoption of new CEQA thresholds and how lead agencies should afford the opportunity for public review and input prior to adoption and use.

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Appendix G
United States Green Building Council Building Area per Employee by Business Type Rates

United States Green Building Council Building Area per Employee by Business Type Rates Final Draft G-1
United States Green Building Council Building
Area per Employee by Business Type Rates67
67 United States Green Building Council. 2008. “Building Area per Employee by Business Type.” May 13, 2008.

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CITY OF SANTA BARBARA

FINAL NEGATIVE DECLARATION FOR THE CLIMATE ACTION PLAN UPDATE AND MASTER

ENVIRONMENTAL ASSESSEMENT GUIDELINES FOR GREENHOUSE GAS EMISSION ANALYSIS Pursuant to the State of California Public Resources Code and the "Guidelines for Implementation of the California Environmental Quality Act of 1970," as amended to date, this Draft Negative Declaration has been prepared for the following project:

PROJECT LOCATION: City of Santa Barbara
PROJECT PROPONENT: City of Santa Barbara Sustainability and Resilience Department PROJECT DESCRIPTION: The Climate Action Plan Update (CAP Update) modernizes the City of Santa Barbara 2012 Climate Action Plan and provides a roadmap of specific actions to reduce greenhouse gas emissions and achieve City emission targets. The CAP Update also comprehensively analyzes and programmatically addresses the City’s greenhouse impacts and is considered a qualified greenhouse gas emission reduction plan for the purpose of meeting the requirements of the California Environmental Quality Act (CEQA). The Master Environmental Assessment Guidelines for Greenhouse Gas Emission Analysis (Guidelines) outlines how future development projects and plans demonstrate consistency with the CAP Update in a streamlined manner with a checklist. The Guidelines also establish a greenhouse gas impact analysis methodology and threshold of significance for those limited projects or plans that are not able to demonstrate consistency with the CAP Update through the checklist and must undergo more thorough review to satisfy the requirements of CEQA.

NEGATIVE DECLARATION FINDING:

Based on the attached Initial Study prepared for the proposed project, it has been determined that the proposed project will not have a significant effect on the environment.

Melissa Hetrick Date
Resilience Program Supervisor
Sustainability and Resilience Department
City of Santa Barbara
3/19/24
ATTACHMENT 6
City of Santa Barbara Climate Action Plan
Update and Master Environmental
Assessment Guidelines for Greenhouse
Gas Emissions Analysis
Final Initial Study – Negative Declaration
prepared for
City of Santa Barbara
Department of Sustainability & Resilience
801 Garden Street, Suite 200
Santa Barbara, California 93101
prepared by
Rincon Consultants, Inc.
319 East Carrillo Street, Suite 105
Santa Barbara, California 93101
May 2024

Table of Contents
Draft Initial Study – Negative Declaration i
Table of Contents
Initial Study.............................................................................................................................................1

1. Proposed Plan Title .............................................................................................................1

2. Lead Agency/Plan Sponsor Contact....................................................................................1

3. Plan Location and Physical Setting......................................................................................1

4. Existing Setting....................................................................................................................4

5. General Plan Designation and Zoning..................................Error! Bookmark not defined.

6. Description of Plan............................................................................................................10

7. Cumulative Projects Scenario ...........................................................................................28

8. Required Approvals...........................................................................................................29 Environmental Factors Potentially Affected.........................................................................................32 Determination ......................................................................................................................................32 Environmental Checklist.......................................................................................................................34 1 Aesthetics..........................................................................................................................34 2 Agriculture and Forestry Resources..................................................................................40 3 Air Quality .........................................................................................................................42 4 Biological Resources..........................................................................................................48 5 Cultural Resources............................................................................................................54 6 Energy ...............................................................................................................................61 7 Geology and Soils..............................................................................................................65 8 Greenhouse Gas Emissions...............................................................................................71 9 Hazards and Hazardous Materials ....................................................................................75 10 Hydrology and Water Quality ...........................................................................................79 11 Land Use and Planning......................................................................................................85 12 Mineral Resources ............................................................................................................87 13 Noise .................................................................................................................................90 14 Population and Housing....................................................................................................96 15 Public Services...................................................................................................................98 16 Recreation.......................................................................................................................100 17 Transportation ................................................................................................................102 18 Tribal Cultural Resources................................................................................................105 19 Utilities and Service Systems ..........................................................................................109 20 Wildfire............................................................................................................................117 21 Mandatory Findings of Significance................................................................................119 References..........................................................................................................................................121 Bibliography................................................................................................................................121 List of Preparers..........................................................................................................................126 City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
ii
Tables
Table 1 City of Santa Barbara 2019 Communitywide GHG Emissions by Sector..........................12 Table 2 City of Santa Barbara GHG Emission Reduction Targets..................................................13 Table 3 City of Santa Barbara CAP Update Measures and Actions by Strategy ...........................13 Table 4 City of Santa Barbara 2030 GHG Reduction Target by Sector ..........................................25 Table 5 City of Santa Barbara Future GHG Emissions Projection and Reduction Target ..............26 Figures
Figure 1 Regional Location................................................................................................................2 Figure 2 Plan Location.......................................................................................................................3 Figure 3 City of Santa Barbara Future GHG Emissions Projection and Reduction Target..............26 Appendices
Appendix A Sources, Health Effects, and Typical Controls Associated with Criteria Pollutants Appendix B Description of Greenhouse Gases of California Concern Initial Study
Draft Initial Study – Negative Declaration 1
Initial Study

1. Proposed Plan Title
City of Santa Barbara Climate Action Plan Update (CAP Update) and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis

2. Lead Agency/Plan Sponsor Contact
Lead Agency/Plan Sponsor
City of Santa Barbara
801 Garden Street, Suite 200
Santa Barbara, California 93101
Contact Person
Melissa Hetrick, Resilience Program Supervisor
City of Santa Barbara Environmental Services Division
Department of Sustainability & Resilience
(805) 991-2447
[email protected]

3. Plan Location and Physical Setting
The CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis apply to all areas within the City of Santa Barbara limits. Figure 1 shows the regional location, and Figure 2 shows the plan location. The plan location includes all of Santa Barbara’s incorporated lands.

The City of Santa Barbara is located in the State of California on Santa Barbara County’s South Coast; approximately 30 miles north of the city of Ventura and 75 miles south of the city of Santa Maria (Figure 2). Generally, the City encompasses approximately 12,636 acres (approximately 19.7 square miles) and extends from the Pacific Ocean on the south generally 3 to 5 miles north into the foothills of the Santa Ynez Mountains.

The City’s boundaries span approximately five miles from the Coast Village Road commercial corridor adjacent to the unincorporated community of Montecito on the east, to Hope Ranch and eastern Goleta Valley on the west (Figure 2). The City limits also include the 970-acre Santa Barbara Airport, located in the Goleta area, approximately four miles west of the City proper.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
2 Figure 1 Regional Location
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Figure 2 Plan Location
City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
4 The City of Santa Barbara is located on the Central Coast of California, between the Santa Ynez Mountains and the Pacific Ocean. The City has a mix of uses with a Mediterranean-style downtown area, suburbs, the Santa Barbara Airport, and many commercial uses such as fine dining and art. The downtown area is located adjacent to US-101, towards the southern part of the City, near Santa Barbara Harbor and Stearn’s Wharf.

The City receives approximately 22 inches of rain annually, 283 sunny days per year, with a July high temperature of 81°F and a January low temperature of 47°F.12Similar to the rest of the Central California Coast, climate conditions in Santa Barbara remain mild due to the City’s relativity to the Pacific Ocean.

4. Existing Setting
City of Santa Barbara Sustainability and GHG Reduction Efforts The City of Santa Barbara has established actions related to increasing sustainability and reducing GHG emissions and the potential impacts of climate change. These actions are outlined in the City’s various plans discussed below.
2035 Together to Zero Campaign
The Together to Zero Campaign encompasses the City of Santa Barbara’s goal of reaching carbon neutrality by 2035 via various climate-related plans, such as the Climate Action Plan. It encourages balancing greenhouse gas emissions with removal strategies and developing bold climate action strategies focused on improved infrastructure, active transportation, energy decarbonization, building decarbonization, carbon removal, and transportation electrification.3 City of Santa Barbara 2012 Climate Action Plan
In September 2012, the City Council adopted the Climate Action Plan to address climate change issues to the year 2030, in accordance with the Santa Barbara General Plan and the California Global Warming Solutions Act (AB 32). The purposes of the Climate Action Plan include reducing the rate of carbon emissions generated within the Santa Barbara community and planning for climate change adaptation. The Plan includes emissions reduction targets for vehicle emissions and citywide emissions inventories in the city for the years 2020 and 2030. Also included in the Plan are emissions reduction strategies such as renewable energy measures, energy efficiency and green building measures, travel and land use measures, vegetation measures, waste reduction measures, and water conservation measures. Climate adaptation planning strategies noted in the Plan include emergency preparedness, wildfire, flooding, water quality, coastal vulnerability and adaptation planning, public services, biological resources, and local economies strategies.4 1 Best Places. 2021. Climate in Santa Barbara, California. Available at: https://www.bestplaces.net/climate/city/california/santa_barbara.

Accessed October 12, 2023.
2 Cal-Adapt. 2023. Local Climate Snapshot for Santa Barbara, California. Available online at: https://cal-adapt.org/tools/local-climatechange-snapshot. Accessed November 2023. 3 Santa Barbara, City of. 2023. Sustainability and Resilience. Together to Zero. Available Online at:
https://sustainability.santabarbaraca.gov/together-to-zero/. Accessed October 12, 2023. 4 Santa Barbara, City of. 2012. Climate Action Plan. Available online at:
https://santabarbaraca.gov/sites/default/files/documents/Services/Climate%20Action%20Plan/Final%20Santa%20Barbara%20Climate%2 0Action%20Plan%20%28September%202012%29.pdf. Accessed October 12, 2023.

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Strategic Energy Plan
The Santa Barbara City Council adopted the Strategic Energy Plan (SEP) on June 7, 2017, with a goal of 100 percent renewable electricity for the entire community by 2030 and an interim goal of 50 percent renewable electricity for municipal facilities by 2020. The Strategic Energy Plan presents a flexible pathway towards achieving these goals through a combination of strategic policy and program options focused on developing local renewable energy resources and bolstering local reliability and resilience. The SEP identifies five Program Areas with accompanying strategies for the City to prioritize for the successful implementation of the plan goals. These Program Areas include Energy Partnerships, Plans and Structures, Community Engagement Initiatives, Funding Sources and Financial Incentives, Municipal Development and Pilot Projects, and Administrative Policies and Procedures.5
City of Santa Barbara Municipal Green Building Policy
The Municipal Green Building Policy was adopted by the Santa Barbara City Council in September 2020 and is a revision to the City’s 2008 Green Building policy, which encourages the construction of LEED Silver Buildings. The policy establishes ambitious energy efficiency targets and sets out to achieve Zero Net Carbon for new building construction and major renovations of all City-owned and occupied facilities to advance the City’s sustainability goals and reduce greenhouse gas emissions.

The policy states environmental performance requirements for new construction, major renovations, existing buildings, tenant improvements, and leased spaces. In addition, the plan details construction waste prevention, preservation, restoration, salvage, reuse, and recycling standards. The policy also establishes the Green Building Steering Committee to oversee and assist in advancing the sustainable performance of City construction projects. Finally, the policy establishes training, financing, technical assistance, reporting, and policy updates standards to ensure the successful implementation of the policy.6
2011 Plan Santa Barbara General Plan
The City’s General Plan is focused on ensuring that the City becomes a more sustainable community to enhance natural and built environments, social equity, and economic vitality as climate change influences local resources and community needs. The five key policy drivers for the Plan are Economic and Fiscal Health, Historic and Community Character, Growth Management, Public and Community Health, and Energy and Climate Change. The Plan has set principles including Economy, Environment, and Equity to elaborate on the basic components of sustainability and reflect the key challenges for establishing a Sustainable Santa Barbara. Additionally, the Plan established the Adaptive Management Program to track progress toward achieving the plan’s goals, objectives, and desired outcomes throughout the 20-year planning period.7 The City of Santa Barbara’s General Plan also includes the 2023-2031 Housing Element, which provides the basis for housing and population forecasts for the GHG emissions throughout the City. This plan identifies Santa Barbara’s housing needs, goals, and policies to produce affordable housing and sound community planning. The City of 5 Santa Barbara, City of. Strategic Energy Plan. 2017. Available online at:
https://santabarbaraca.gov/sites/default/files/documents/Public%20Works/Energy%20Programs/Strategic%20Energy%20Plan%20Overvi ew.pdf. Accessed October 12, 2023.
6 Santa Barbara, City of. Municipal Green Building Policy. 2020. Available online at: https://p7n920.a2cdn1.secureserver.net/wpcontent/uploads/2021/11/Green-Building-Policy_Final.pdf. Accessed October 12, 2023. 7 Santa Barbara, City of. Plan Santa Barbara. 2011. Available online at: https://santabarbaraca.gov/government/priorities-policies/generalplan/general-plan-elements-appendices. Accessed October 12, 2023.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
6 Santa Barbara 2023-2031 Regional Housing Needs Allocation (RHNA) was utilized in projecting GHG emissions in the CAP Update.

Municipal Zero Emission Vehicle Acquisition Policy
The City of Santa Barbara adopted the Municipal Zero Emissions Vehicle Acquisition Policy in March 2023 to replace internal combustion engine vehicles in the city’s fleet with battery electric vehicles once these vehicles reach end of life. This policy aims to accelerate the rate of reduction of greenhouse gas emissions in the City, in accordance with the goals of the 2011 General Plan and the Together to Zero Campaign.
8 Santa Barbara Pedestrian Master Plan
The Pedestrian Master Plan is derived from the 1997 City Circulation Element and was adopted by City Council on July 18, 2006. The main purpose of the Plan is to support the vision statement of the Circulation Element, which encourages alternative forms of transportation and mobility so that automobile use is not necessary. The Plan is broken into five main goals which seek to improve the pedestrian system, establish and enhance safe routes to school, protect and expand the Paseo system, create pedestrian environments that are attractive, functional and accessible, and encourage more people to walk. Overall, the Pedestrian Master Plan will help the City reach its GHG emissions reduction targets by supporting infrastructure to minimize automobile use throughout the city and encourage alternative forms of transportation.9 Regional Sustainability and GHG Reduction Efforts
In coordination with Santa Barbara County, the Santa Barbara County Association of Governments (SBCAG), the Southern California Association of Governments (SCAG), the State of California, and the Federal government, the City of Santa Barbara has committed to implementing regional and State policies related to GHG emissions reduction. As follows is a summary of the regional GHG emissions reduction efforts, which the City of Santa Barbara CAP Update is intended to be consistent with or exceed.

County of Santa Barbara 2010 Sustainability Action Plan The County of Santa Barbara adopted the Sustainability Action Plan to take immediate, cost effective and coordinated steps to reduce the County’s collective GHG emissions. The Plan highlights numerous actions to lessen the emissions from government operations including increasing energy efficiency in vehicle fleets and buildings, demonstrating the use of clean, renewable energy sources, implementing vehicle transportation plans that reduce usage, encouraging waste reductions, and joining the Santa Barbara Southern California Edison (SCE) and Pacific Gas & Electric (PG&E) Partnerships. The Plan also includes an in-depth GHG emissions inventory for all government operations to identify and quantify the sources of emissions from the Santa Barbara County government operations.10
8 Santa Barbara, City of. Municipal Zero Emission Vehicle Acquisition Policy. 2023. Available online at:
https://sustainability.santabarbaraca.gov/together-to-zero/. Accessed October 12, 2023. 9 Santa Barbara, City of. Pedestrian Master Plan. 2006. Available online at: https://santabarbaraca.gov/government/departments/publicworks/public-works-downtown-team/transportation-policy. Accessed October 12, 2023. 10 Santa Barbara, County of. Sustainability Action Plan. 2020. Available online at: https://content.civicplus.com/api/assets/655aa841-212f4e39-baeb-db6485dfd466. Accessed October 12, 2023.

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Connected 2050 Regional Transportation Plan and Sustainable Communities Strategy
The Santa Barbara County Association of Governments (SBCAG) adopted the Connected 2050 Regional Transportation Plan and Sustainable Communities Strategy (RTP/SCS) in August 2021. This Plan was developed to explore the region’s land use and travel patterns, account for the demographic growth that will create new demands on the land use and travel infrastructure and assist in achieving the State’s greenhouse gas reduction targets. Additionally, Connected 2050 incorporates the region’s first region-specific analysis of environmental justice indicators. The Plan has five goals that are centered around protecting and promoting a healthy environment, improving mobility and system reliability, ensuring socio-economic equity, improving health and safety, and achieving a prosperous economy.11
State Sustainability and GHG Reduction Efforts
As follows is a summary of the State GHG emissions reduction efforts, which the City of Santa Barbara CAP Update is intended to be consistent with or exceed.

California Senate Bill 375
In 2008, Senate Bill 375 (SB 375) enhanced the State’s ability to reach Assembly Bill (AB) 32 targets by directing CARB to develop regional GHG emissions reduction targets to be achieved from passenger vehicles for 2020 and 2035. In addition, SB 375 directs each of the State’s 18 major Metropolitan Planning Organizations (MPO) to prepare a sustainable community’s strategy (SCS) that contains a growth strategy to meet such regional GHG emissions reduction targets for inclusion in the respective regional transportation plan (RTP).

California Executive Order S-3-05
In 2005, the California governor issued Executive Order (EO) S-3-05, which identifies Statewide GHG emissions reduction targets to achieve long-term climate stabilization as follows:
▪ Reduce GHG emissions to 1990 levels by 2020
▪ Reduce GHG emissions to 80 percent below 1990 levels by 2050 California Assembly Bill 32
In 2006, the California legislature signed AB 32 – the Global Warming Solutions Act – into law, requiring a reduction in Statewide GHG emissions to 1990 levels by 2020 and California Air Resources Board (CARB) preparation of a Scoping Plan that outlines the main State strategies for reducing GHGs to meet the 2020 deadline. In addition, AB 32 required CARB to adopt regulations to require reporting and verification of Statewide GHG emissions. Based on this guidance, CARB approved a 1990 Statewide GHG level and 2020 limit of 427 metric tons of carbon dioxide equivalent (MTCO2e).

California Climate Change Scoping Plan (2008)
In 2008, CARB approved the original California Climate Change Scoping Plan, which included measures to address GHG emission reduction strategies related to energy efficiency, water use, and 11 Santa Barbara County Association of Governments Connected 2050: Regional Transportation Plan and Sustainable Communities Strategy. 2021. Available online at: http://www.sbcag.org/uploads/2/4/5/4/24540302/connected_2050_final.pdf. Accessed October 12, 2023.

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City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
8 recycling and solid waste, among other measures. Many of the GHG reduction measures included in the Scoping Plan (e.g., Low Carbon Fuel Standard, Advanced Clean Car standards, and Cap-andTrade) have been adopted and implemented since approval of the Scoping Plan.

California Climate Change Scoping Plan Update (2022)
On September 8, 2016, the governor signed SB 32 into law, extending AB 32 by requiring the statewide reduction of GHG emissions to 40 percent below 1990 levels by 2030 (the other provisions of AB 32 remain unchanged). In November 2022, CARB approved the third update to the California Climate Change Scoping Plan. The 2022 Scoping Plan extends the previous Scoping Plans and lays out a path to achieve carbon neutrality no later than 2045, as directed by AB 1279. The previous 2017 Scoping Plan lays out a technologically feasible and cost-effective path to achieve the 2030 GHG reduction target by leveraging existing programs such as the Renewables Portfolio Standard, Advanced Clean Cars, Low Carbon Fuel Standard, Short-Lived Climate Pollutant (SLCP) Reduction Strategy, Cap-and-Trade Program, and Mobile Source Strategy that includes strategies targeted to increase zero emission vehicle fleet penetration. The 2022 Scoping Plan looks toward the 2045 climate goals and the deeper GHG reductions needed to meet the State’s statutory carbon neutrality target specified in AB 1279 and EO B-55-18. To accomplish this goal, significant focus is placed on accelerating the transition to zero-emissions vehicles, expanding renewable energy sources such as solar and wind, enhancing carbon sequestration on natural and working lands, and prioritizing environmental justice.12
California Executive Order B-55-18
In 2018, the California governor issued Executive Order B-55-18, which established a new Statewide goal of achieving carbon neutrality by 2045 and maintaining net negative emissions thereafter. This goal is in addition to the existing Statewide GHG reduction targets established by SB 32.

California Senate Bill 32
In 2016, the California Governor signed SB 32 as a follow up to AB 32 – The California Global Warming Solutions Act of 2006, which required the state to reduce its GHG emissions to 1990 levels by 2020. SB-32 designates the California State Air Resources Board (CARB) as the state agency charged with monitoring and regulating sources of GHG emissions and to ensure the state’s GHG emissions are reduced to 40 percent below 1990 levels by 2030. To meet these standards, CARB is required to expand on or develop new regulations that are both technologically reasonable and cost-effective, while considering the state’s disadvantaged communities.

Assembly Bill 197, State Air Resources Board Greenhouse Gases Regulations In 2016, the California legislature approved AB 197, a bill linked to SB 32, which increases legislature oversight over the CARB and directs CARB to prioritize disadvantaged communities in its climate change regulations, and to evaluate the cost-effectiveness of measures it considers. AB 197 requires the CARB to “protect the State’s most impacted and disadvantaged communities [and] consider the social costs of the emissions of greenhouse gases” when developing climate change programs. The bill also adds two new legislatively appointed non-voting members to the CARB, increasing the Legislature’s role in the CARB’s decisions.
12 CARB. 2022. 2022 Scoping Plan for Achieving Carbon Neutrality. Available at: https://ww2.arb.ca.gov/sites/default/files/2023-04/2022- sp.pdf. Accessed October 2023.

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Senate Bill 350, Clean Energy and Pollution Reduction Act of 2015 In October 2015, SB 350 was signed into law, establishing new clean energy, clean air, and GHG reduction goals for 2030 and beyond. SB 350 codifies Governor Jerry Brown’s aggressive clean energy goals and establishes California’s 2030 GHG reduction target of 40 percent below 1990 levels. To achieve this goal, SB 350 increases California’s renewable electricity procurement goal from 33 percent by 2020 (legislation originally enacted in 2002) to 50 percent by 2030. Renewable resources include wind, solar, geothermal, wave, and small hydroelectric power. In addition, SB 350 requires the State to double Statewide energy efficiency savings in electricity and natural gas enduses (i.e., residential and commercial) by 2030 from a base year of 2015.

Senate Bill 100, The 100% Clean Energy Act of 2018
In September 2018, Governor Brown signed SB 100, requiring that the State’s load serving entities (including energy utilities and community choice energy programs) must procure energy generated 100 percent from Renewables Portfolio Standard (RPS) for eligible renewable resources by 2045.

California Energy Efficiency Strategic Plan of 2008
In September 2008, the California Public Utilities Commission (CPUC) adopted California’s first Long Term Energy Efficiency Strategic Plan, presenting a single roadmap to achieve maximum energy savings across all major groups and sectors in California. The Strategic Plan was subsequently updated in January 2011 to include a lighting chapter. The Strategic Plan sets goals of all new residential construction and all new commercial construction in California to be zero net energy (ZNE) by 2020 and 2030, respectively. In 2018, the California Energy Commission voted to adopt a policy requiring all new homes in California to incorporate rooftop solar. This change went into effect in January 2020 with the adoption of the 2021 Title 24 Code and is a step towards the State achieving its goal of all residential new construction being ZNE by 2020. Additionally, the Strategic Plan sets goals of 50 percent of existing commercial buildings to be retrofitted to ZNE by 2030 and all new State buildings and major renovations to be ZNE by 2025.

Senate Bill 1275, Charge Ahead Initiative
In September 2014, Senate Bill 1275 was signed into law, establishing a State goal of one million zero-emissions and near-zero-emissions vehicles in service by 2020 and directing the Air Resources Board to develop a long-term funding plan to meet this goal. SB 1275 also established the Charge Ahead California Initiative requiring planning and reporting on vehicle incentive programs and increasing access to and benefits from zero-emissions vehicles for disadvantaged, low-income, and moderate-income communities and consumers.

Assembly Bill 1493, the Pavley Bill
AB 1493 (2002), California’s Advanced Clean Cars program (referred to as Pavley), requires CARB to develop and adopt regulations to achieve “the maximum feasible and cost-effective reduction of GHG emissions from motor vehicles.” On June 30, 2009, US EPA granted the waiver of the Clean Air Act preemption to California for its GHG emission standards for motor vehicles beginning with the 2009 model year. Pavley I regulates model years from 2009 to 2016, and Pavley II, which is now referred to as “Low Emission Vehicle (LEV) III GHG”, regulates model years from 2017 to 2025. The Advanced Clean Cars program coordinates the goals of the LEV, Zero Emissions Vehicles (ZEV), and Clean Fuels Outlet programs, and would provide major reductions in GHG emissions. By 2025, when City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
10 the rules will be fully implemented, new automobiles will emit 34 percent fewer GHGs and 75 percent fewer smog-forming emissions from their model year 2016 levels.

Senate Bill 97, CEQA Guidelines for Addressing GHG Emissions The California Environmental Quality Act (CEQA) requires public agencies to review the environmental impacts of proposed projects, including General Plans, Specific Plans, and specific kinds of development projects. In February 2010, the California Office of Administrative Law approved the recommended amendments to the State CEQA Guidelines for addressing GHG emissions. The amendments were developed to provide guidance to public agencies regarding the analysis, mitigation, and effects of GHG emissions in draft CEQA documents.

5. Description of Plan
CAP Update
The CAP Update builds off and incorporates the climate protection programs noted above that the City has in place and will continue to reduce GHG emissions. Specifically, the CAP Update builds off the 2012 CAP, which was the City’s first official qualified GHG reduction plan. The City has developed the CAP Update in order to achieve a number of objectives, including a demonstration of environmental leadership, compliance with State environmental initiatives, promotion of green jobs, and increased sustainable development.

The CAP Update addresses municipal and communitywide GHG emissions and includes a goal of reducing communitywide GHG emissions output by 378,507 metric tons of carbon dioxide equivalent (MT CO2e) by 2030 (consistent with California Senate Bill 32 target for 2030).

Additionally, the City of Santa Barbara has aspirational goals to achieve carbon neutrality by 2035, which is significantly more aggressive than the state’s emissions reduction target of 40% below 1990 levels by 2030 (SB 32) and 85% below 1990 levels or net zero by 2045 (AB 1279).

The State of California uses 1990 as a reference year to remain consistent with Assembly Bill (AB) 32, which codified the State’s 2020 GHG emissions target by directing CARB to reduce Statewide emissions to 1990 levels by 2020. However, cities and counties throughout California typically elect to use years later than 1990 as baseline years because of the increased reliability of recordkeeping from those years and the large amount of growth that has occurred since 1990. The City of Santa Barbara does not have a 1990 GHG inventory, and the targets developed by the City in the 2012 CAP were instead compared to a 2005-2008 baseline following guidance in the California Air Resources Board’s (CARB) 2008 Climate Change Scoping Plan. This plan estimates 1990 emissions (also the 2020 target) as 15% below “current” (2005-2008) emissions.13 As such, the 2019 GHG inventory was established as the new baseline moving forward and emission levels were back-casted from this baseline to 1990 levels using the same proportion of increased GHG emissions at the state level from 1990 to the current level. Based on these back-casted calculations, the City of Santa Barbara emitted approximately 715,530 MT CO2e in 1990.

In 2019, approximately 622,110 MT CO2e were emitted in the City of Santa Barbara from the energy, transportation, solid waste, water, and municipal sectors. The municipal sector is a subset of the community emissions sectors, which consist of energy, transportation, solid waste, and water. The municipal sector is developed to establish metrics that allow the City to lead by example and reduce 13Governor’s Office of Planning and Research (OPR). 2017. General Plan Guidelines. Ch 8 Climate Change. P. 228. https://opr.ca.gov/docs/OPR_C8_final.pdf
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emissions at the municipal level. The energy sector represents emissions that result from electricity and natural gas used in both private and public sector buildings and facilities. The transportation sector includes emissions from private, commercial, and fleet vehicles driven within the City as well as the emissions from transit vehicles, the City-owned fleet, and off-road equipment such as garden equipment and construction equipment. Emissions generated from water usage and wastewater generation are due to the indirect electricity used to distribute water and collect and treat wastewater. Burning fossil fuels associated with buildings/facility energy, vehicle use, and (transportation) use are the largest contributors of Santa Barbara GHG emissions. Table 1 includes total Santa Barbara (i.e., community and municipal) GHG emissions in 2019 by sector as well as percentage of total City emissions.

The majority of the GHG emission reductions from 1990 levels to 2019 levels occurred in the transportation and energy sectors through increased fuel efficiency and increased renewable energy procurement by Santa Barbara Clean Energy (SBCE). In 2021, the City of Santa Barbara began receiving carbon-free electricity through SBCE, resulting in significant decreases in electricity emissions to near zero in the short term ahead of SB 100 requirements. GHG reductions associated with switching to SBCE carbon-free electricity accounts for a reduction of 75,608 MT CO2e in 2030 and 19,586 MT CO2e in 2035. SBCE carbon-free energy also provides the foundation needed for the electrification of buildings and vehicles which are both main pathways for GHG emission reduction in this CAP Update.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
12 Table 1 City of Santa Barbara 2019 Communitywide GHG Emissions by Sector Sector/Emission Source GHG Emissions (MT CO2e) Percentage of Total Natural Gas 134,068 22%
Residential Natural Gas 63,858 10%
Non-Residential Natural Gas 40,788 7%
Natural Gas Leakage 29,422 5%
Electricity 110,155 18%
Residential Electricity (EV adjusted) 35,529 6%
Non-Residential Electricity (EV adjusted) 73,888 12%
Electric Vehicles 738 <1%
Transportation 318,966 51%
Passenger On-Road Transportation 256,408 41%
Commercial On-Road Transportation 10,000 2%
Bus On-road Transportation 7,591 1%
Off-Road - Diesel 26,534 4%
Off-Road - Gasoline 15,078 2%
Off-Road Natural Gas (LPG) 2,355 <1%
Solid Waste2 52,977 9%
Solid Waste Generated/Disposal 52,977 9%
Water 1,658 <1%
Indirect Electricity from Imported Potable Water Supply 229 <1% Wastewater Treatment Process and Fugitive Emissions 1,429 <1% Cumulative Emissions 622,110 100%
Notes: MT CO2e = Metric tons of carbon dioxide equivalent 1 GHG emissions generated by electricity consumption involved in producing local groundwater supplies and the collection and treatment of wastewater are not added to the GHG emissions total to avoid double counting. The electricity consumption involved in these processes is already encompassed in non-residential electricity consumption in the energy sector. 2 GHG emissions generated by the collection and transport of waste generated within the City are captured in the Commercial On-road Vehicle source in the Transportation sector.

As shown in Table 1, the largest sectors of GHG emissions are related to energy and transportation, followed by solid waste and water. The City is preparing the CAP Update to include measures and actions addressing communitywide and municipal GHG emissions. Per the CAP Update, the City of Santa Barbara is committed to an emissions reduction target of 40 percent below 1990 levels by 2030 (SB 32 target year) and reaching a longer-term goal of carbon neutrality by 2035. Table 2 summarizes the emissions reduction targets included in the CAP Update compared to the reductions proposed in the 2012 CAP. This 2030 GHG emissions goal is selected to be consistent with SB 32 and CEQA Guidelines § 15183.5 for a qualified GHG emissions reduction strategy as well as to be achievable by City-supported measures identified in the CAP Update. The CAP Update includes a business-as-usual (BAU) and adjusted forecast of GHG emissions that will enable the City to quantitatively estimate the emissions reductions needed to meet its goal.

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Table 2 City of Santa Barbara GHG Emission Reduction Targets Target Year
Reductions
Compared to 1990 Levels
Reductions
Compared to 1990 Baseline
Remaining Emissions Gap
(MT CO2e)
2020 Meet 1990 Levels 15% Target Exceeded
2030 40% 47% 50,811
Achieving carbon neutrality will require significant changes to the technology and systems currently in place. The CAP Update aims to establish new systems that are resilient and equitable and allow for a transition to carbon neutrality in the future. This includes electrification of building and transportation systems, support for land use policies and growth policies that reduce vehicle miles traveled, increased usage of carbon neutral electricity, increased water use efficiency, and waste reduction and diversion. As these measures and actions are implemented, the City will gain more information, new technologies will emerge, and current pilot projects and programs will scale to the size needed to reach carbon neutrality. Furthermore, the state is expected to update state-level regulations and provide additional support for meeting carbon neutrality in the future. Future CAP updates past 2030 will also outline new measures and actions that the City of Santa Barbara will implement to close the remaining gap to achieve the carbon neutrality target. Table 3 includes a complete list of the measures and actions included in the CAP Update by strategy.

Table 3 City of Santa Barbara CAP Update Measures and Actions by Strategy ID # Measures and Actions
Building Energy Measures
Measure BE-1 (Municipal) Decarbonize 50% of Municipal Buildings and Facilities by 2030 and all Remaining Municipal Facilities by 2035
Action BE-1.1 Develop a plan to electrify 50% of City-owned municipal buildings by 2030 and decarbonize 100% of municipal facilities by 2035. The plan will include an inventory of fossil fuel-powered municipal building equipment, low/zero-carbon technologies available for replacing the equipment (where available), and a short- and long-term schedule for completion. Address diesel generators and recent natural gas investments. Address feasibility concerns around community swimming pool decarbonization. Any buildings that are unable to be electrified due to technological infeasibility should be decarbonized with other technology.

Action BE-1.2 By 2030, develop an ordinance to require the installation of solar and/or energy storage backup power instead of diesel generators, where feasible.

Action BE-1.3 Implement the municipal building decarbonization plan developed under BE-1.1 to decarbonize 100% of municipal buildings by 2035 (any buildings that are unable to be electrified due to technological infeasibility shall be decarbonized with other technology).

Action BE-1.4 Develop and implement a plan for retrofitting all remaining streetlights, facility lighting, and traffic signals to LEDs by 2035.

Action BE-1.5 Leverage the grant writer position(s) in strategy A-2.2 to expand funding efforts for municipal decarbonization.

Action BE-1.6 Include, at the time of lease renewal, requirements for City-owned leased buildings and facilities to be all-electric.

Measure BE-2 (Municipal) Procure Carbon Free or 100% Renewable Electricity for Municipal Operations by 2030 Action BE-2.1 Require all municipal electrical accounts to remain in SBCE's 100% Green option and purchase carbon-free electricity.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
14 ID # Measures and Actions
Measure BE-3 (Municipal) Increase Municipally Owned Distributed Renewable Energy Generation Throughout the City
Action BE-3.1 Implement all feasible microgrid projects at municipal facilities as identified by the 2017 Zero Net Energy study and re-evaluate viability of additional facilities.

Action BE-3.2 Conduct a feasibility study to understand the barriers of installing additional distributed energy resources such as solar and battery storage, or other renewable energy generation infrastructure, at municipal facilities. The City may need to re-evaluate plans for funding, energy storage capacity, and distributed energy resources to implement these projects. Focus municipal efforts around finding adequate space for energy storage and microgrid projects.

Measure BE-4 Expand Existing Natural Gas Prohibition Ordinance for New Construction Action BE-4.1 In 2025 and every 3 years thereafter, revisit building ordinances to update the scope and exemptions to align with industry technology and maximize GHG reduction. Examples include requiring all major remodels (over 50% of building effected or an addition of over 50% of gross floor space) and removing exemptions in the all-electric building requirements. The building code cycle updates are processed in 2025, effective in 2026, and updated every 3 years.

Measure BE-5 Reduce Existing Residential Natural Gas Consumption by 10% Below 2019 Levels by 2030 and 17% Below 2019 Levels by 2035
Action BE-5.1 Adopt a time of renovation energy efficiency and electrification requirement by 2025, effective 2026. This ordinance could require replacement of HVAC systems, hot water heaters, and other appliances to be all electric and low hydrofluorocarbons (HFC) gas emitters or provide a checklist of cost-effective efficiency and electrification options for renovations to complete based on the scope of the project. Adopt an electrification ordinance for existing residential buildings by 2028, effective 2029, to be implemented through the building permit process, which bans expansion or reconnection of natural gas infrastructure.

Action BE-5.2 Complete an existing building electrification feasibility analysis in collaboration with UCSB or another research institution by 2025 to determine the upfront and on-bill costs associated with building electrification strategies. This information will be used to inform and support future ordinances addressing existing building electrification as well as the building electrification accelerator (BE-5.3). The study will include extensive community input and an equity analysis to ensure all people have affordable access to the health, comfort, economic, and resilience benefits of building electrification.

Action BE-5.3 Create a residential building electrification accelerator program to increase community access to building electrification resources. This program should include the provision and expansion of resources needed to support residents in electrifying their homes. For example, by providing rebates, enhanced funding for income-qualified homeowners, technical expertise, and contractor support.

Action BE-5.4 Identify opportunities for the strategic reduction of gas infrastructure within the City and develop a gas infrastructure pruning pilot program.

Action BE-5.5 Complete a low income and affordable housing electrification pilot project in collaboration with affordable housing owners, utilities, and the community. The pilot project will ensure that there is not an increase to energy bills for occupants of pilot buildings.

Action BE-5.6 Provide a rebate at time of sale for qualifying building electrification upgrades including panels, wiring, and heat pump appliances. Implement the rebate program by 2025.

Action BE-5.7 Improve the City's building electrification permit process through a comprehensive permitting compliance program that streamlines processes, reduces fees, provides permit and inspection checklists, shortens review times, and educates affected trades and staff, thus reducing barriers to electrification and unlocking available incentives.

Action BE-5.8 Conduct a feasibility study of a smart building market demand program, such as Recurve’s flexgrid program. The study should include a pilot project that allows building owners to track the power generation and consumption of their retrofitted structures and work on making this a widely available and affordable option.

Initial Study
Draft Initial Study – Negative Declaration 15
ID # Measures and Actions
Action BE-5.9 Develop the program studied in BE-5.8 that allows building owners to track the power generation and consumption of their retrofitted structures to optimize energy management.

Action BE-5.10 Partner with ReCurve or similar entity to design and implement a market demand program that would pay energy users to save energy during times of peak demand, use energy more efficiently, and help balance the grid.

Action BE-5.11 Expand education programs directed at homeowners and renters on energy resource programs (examples include energy efficiency programs, demand response, and market demand programs).

Action BE-5.12 Promote residential energy disclosure legislation, requiring home energy score at time of all residential property sale or rental listings.

Action BE-5.13 Establish a program that provides targeted direct install services and cost share for specific electrification measures with multi-unit residential development owners. City to cover incremental cost in addition to an incremental electricity rate from SBCE.

Action BE-5.14 Develop and implement a multi-family residential property regulation by 2028 to promote phased building energy efficiency and decarbonization. The regulation would require periodic energy inspections and prescriptive energy efficiency and decarbonization points requirements from a standardized checklist, with required performance increasing over time.

Action BE-5.15 Develop an emergency hot water appliance program where the City provides residents with emergency natural gas hot water heaters within 24 hours of a request, with an agreement that the resident's gas-powered hot water heater will be replaced within 6 months with a heat pump water heater.

Action BE-5.16 Increase community awareness and understanding of tax benefits for residential building energy efficiency upgrades (Example: the Residential Energy Efficiency Property Tax Credit).

Action BE-5.17 Develop incentives for California Alternate Rates for Energy (CARE)/ Family Electric Rate Assistance (FERA) subsidized rate programs for low-income resident customers to increase energy assurance.

Action BE-5.18 Implement direct installation and/or incentive programs that facilitate the installation of combined solar and battery energy storage system installations on local area single family residential buildings.

Target 120 installations by 2035.

Action BE-5.19 Adopt a natural gas end of flow date by 2040.1 Create public engagement and education campaigns around this action to give the community advanced notice as well as signify all progress being made to make this possible.

Measure BE-6 Reduce Commercial Natural Gas Consumption 10% Below 2019 Levels by 2030 and 18% Below 2019 Levels by 2035
Action BE-6.1 Based on the results of measure BE-5.2, the existing building electrification feasibility analysis, develop and adopt an ordinance for existing commercial buildings by 2025, effective 2026, that requires the replacement of fossil fuel building systems such as HVAC and Domestic Hot Water systems with heat pumps at time of renovation. Any buildings that are unable to be electrified due to technological infeasibility shall be decarbonized with other technology. Adopt an electrification ordinance for existing commercial buildings by 2028, effective 2029, to be implemented through the building permit process, which bans expansion or reconnection of natural gas infrastructure.

Action BE-6.2 Develop and implement a commercial and mixed-use building benchmarking program for commercial and multifamily buildings over 20,000 square feet by 2025, effective 2026. The program would include reporting electricity and natural gas usage (and any other energy source) data through energy star portfolio manager. It would establish monetary penalties for non-compliance.

Residential portions of buildings that are part of a mixed-use development would be exempt. Create incentives for buildings not covered to encourage voluntary compliance.

Action BE-6.3 Develop and implement a building performance standard by 2028. The standard should identify a GHG emissions per square footage threshold for each commercial building type using the data collected under action BE-6.2. The program will start with larger commercial/multifamily residential buildings and decrease in size over time.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
16 ID # Measures and Actions
Action BE-6.4 Re-evaluate building performance program every 3 years to gauge implementation progress and possible expansion to smaller sized buildings.

Action BE-6.5 Work collaboratively (via SBCE) with SCE to incentivize all-electric retrofits by combining rebate programs and financing mechanisms to create cost effective electrification packages. Prioritize small, and under-resourced population-owned businesses.

Action BE-6.6 Expand education, outreach and engagement efforts relating to building electrification and energy resources, including these actions:
▪ Partner with the Santa Barbara South Coast Chamber of Commerce to inform and facilitate electrification for commercial business owners.
▪ Conduct a survey of small businesses detailing obstacles and needed resources to inform equity considerations of the ordinance.
▪ Conduct engagement efforts to the commercial sector to identify ways the City can support commercial energy storage installations and neighborhood scale microgrid opportunities. ▪ Leverage the grant writer position(s) in strategy A-2.2 to facilitate funding opportunities for commercial business electrification by identifying and supporting grant opportunities available to the community, prioritizing small and under-resourced population community owned. ▪ Implement feedback provided during the community outreach process to small businesses and under-resourced population-owned businesses to address potential equity impacts of the building performance program.

Action BE-6.7 Track and require rental energy use disclosures at all commercial property over 10,000 SF. Require an ASHRAE (American Society of Heating, Refrigeration, and Air-Conditioning Engineers) level-1 audit for properties over 10,000 SF, and property over 20,000 SF requires an ASHRAE level-2 audit to be conducted and disclosed to the City, tenants, and potential buyers prior to sale and/or listing.

Action BE-6.8 Establish a decarbonization incentive rate pilot program that would charge SBCE customers a reduced marginal cost rate for installation of specific electrification measures. Target commercial kitchens/restaurants, Hotel/Motels,etc.

Action BE-6.9 Publicize tax breaks for commercial building energy efficiency upgrades. For example, Section 179D Deduction is a federal tax deduction that allows commercial building owners to deduct up to $1.80 per square foot of the cost of qualifying energy-efficient upgrades made to their buildings, including HVAC systems, lighting, and building envelope improvements.

Action BE-6.10 Implement direct installation and/or incentive programs that facilitate the installation of combined solar and battery energy storage system installations on local area commercial buildings. Target 36 installations by 2035.

Action BE-6.11 Develop an emergency hot water appliance program where the City provides commercial residents with emergency natural gashot water heaters within 24 hours of a request, with an agreement that the hot water heater will be replaced within 6 months with a heat pump.

Action BE-6.12 Create a commercial and mixed-use building electrification accelerator program to increase community access to building electrification resources. This program should include the provision and expansion of resources needed to support building electrification. For example, providing rebates, enhanced funding for income-qualified homeowners, technical expertise, and contractor support.

Measure BE-7 Increase the Impact of Santa Barbara Clean Energy (SBCE) Action BE-7.1 Adopt a reach code requiring all non-residential new construction and major remodels to include solar PV.

Action BE-7.2 Convert SCE direct access customers to SBCE through targeted programs, incentives, and engagement. Direct access customers purchase electricity from a competitive provider called an Electric Service Provider (ESP), instead of from a regulated electric utility like Southern California Edison (SCE).

Action BE-7.3 Develop targeted rate structures and other incentives for large commercial customers including demand response.

Initial Study
Draft Initial Study – Negative Declaration 17
ID # Measures and Actions
Action BE-7.4 Develop a local education program detailing incentives for electrification and promoting the benefits of opting in to SBCE's service, particularly for under-resourced populations.

Action BE-7.5 Maintain SBCE opt-out rates below 10%.

Action BE-7.6 Create innovative pilots for SBCE through local partnerships addressing technical, low-income, market, and policy barriers to progress the City’s sustainability and resilience goals. Consider working with departments at UCSB like Technology and Management Program for innovative solutions that leverage technology, Engineering for data-driven solutions, and Environmental Science for cutting edge environmental research.

Action BE-7.7 Develop a Feed-In Tariff to increase and incentive distributed energy resources. Feed-In Tariffs allow eligible small-scale renewable energy generating sources to sell their energy back to the utility or major energy grid.

Transportation Measures
Measure T-1 (Municipal) Continue to Develop and Implement the Municipal Transportation Demand Management (TDM) Program
Action T-1.1 Provide free or discounted access to public transit passes and the electric bicycle share program for all municipal employees and expand the WorkTRIP program to offer additional carbon-free or carbon-reduced modes of travel incentives.

Action T-1.2 Develop a hybrid remote work program policy that supports municipal office employees to work from home as feasible (including alternative work schedules where feasible). City to provide financial assistance to help offset costs associated with home office needs.

Action T-1.3 Provide cash incentives or paid time off for City employees to bike, walk, and carpool to work.

Action T-1.4 Conduct a detailed survey of City staff commute data annually including employee feedback to identify both major emission sources and potential gaps in planning.

Action T-1.5 Identify opportunities for accessing bike lockers and showers at municipal office buildings.

Measure T-2 (Municipal) Electrify or Otherwise Decarbonize the Municipal Fleet by 2035.

Action T-2.1 Complete and implement the City's Zero Emission Vehicle Acquisition Policy to convert fossil fuel municipal fleet vehicles, where feasible, to electric or otherwise decarbonize the fleet by 2035, including a short and long-term schedule for completion as well as potential for regional bulk procurement. Gain approval from City Council to allow discretionary electric vehicle purchases from different vendors.

Action T-2.2 Install additional zero emission vehicle chargers in municipal parking lots for fleet and employee use.

Action T-2.3 Procure biofuels (renewable diesel and biogas) to operate municipally owned on and off-road equipment with no existing opportunities for decarbonization. Re-evaluate decarbonization opportunities regularly to ensure biofuels are not being used for equipment that could otherwise be decarbonized.

Action T-2.4 Develop and adopt a purchasing policy for smaller equipment (e.g., landscaping equipment) that includes reviews and prioritization of emissions-free equipment each time equipment is purchased.

Measure T-3 Implement Programs that Enhance Access to SafeActive Transportation, such as Walking and Biking, to Increase Active Transportation Mode Share to 6% by 2030 and to 10% by 2035 Action T-3.1 Implement the City's Bicycle Master Plan and Pedestrian Master Plan goals and policies to enhance community access to safe active transportation options. Using these guiding documents, identify, design, and procure funding for projects that can forward the goals of the BMP and PMP, and create bike and pedestrian infrastructure that is safer, easier to use, and widely accessible for all community members.

Action T-3.2 Pursue funding and coordinate with existing streets maintenance programs to close gaps in the pedestrian and bike network, as identified in the Bicycle Master Plan, Pedestrian Master Plan, and Capital Improvement Program.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
18 ID # Measures and Actions
Action T-3.3 Evaluate existing bike parking facilities and evaluate what improvements can be made to increase parking supply, reduce theft, and increase rider attraction. Include analysis of last mile limitations and hurdles and add bike parking near transit stops accordingly. Consider AB 2097 and expanding bike parking with private facilities when vehicle parking is limited.

Action T-3.4 Adopt the State’s Slow Streets Program and expand the City’s existing neighborhood traffic calming efforts with a focus on equity considerations for additional locations.

Action T-3.5 Engage MOVE SBC, SBCAG, MTD, Santa Barbara County Public Health Department, Cottage Hospital, school districts, local law enforcement, bike advocates, and community stakeholders to continue to identify and implement additional short-term and long-term bikeway and pedestrian infrastructure improvements, Vision Zero messaging and efforts, and general education regarding the safe utilization of our public active infrastructure.

Action T-3.6 Build new infrastructure to ensure there is equitable access to safe bike and pedestrian infrastructure in all areas of the city. Focus planning, development, and construction of active transportation infrastructure in regionally defined disadvantaged communities.

Action T-3.7 Evaluate amending the zoning ordinance to increase bike parking and types of bike parking facilities for land development projects.

Action T-3.8 Implement the recommended bike facilities outlined in the Santa Barbara Bicycle Master Plan to add 30 miles of bike ways to the City by 2030.

Action T-3.9 Implement Santa Barbara's Vision Zero Strategy to eliminate serious injuries and fatalities on City streets.

Action T-3.10 Leverage technology to track mode shifts to active transportation. Conduct an annual review of progress on implementation progress, data quality, and potential barriers to implementation. Once an effective tracking method is developed, the City shall aim to achieve 6% increase in active transportation mode share by 2030 and 10% by 2035.

Action T-3.11 Increase bike parking in nonresidential places like populated areas, City Parks, beaches, etc.

Action T-3.12 Accelerate the production and availability of affordable housing near urban centers by updating and adopting the Housing Element and Zoning Code to reduce vehicle miles traveled; by exploring alternative strategies to create and preserve affordable housing, such as co-ops, housing or land trusts; and by streamlining project review with objective design standards.

Measure T-4 Implement Programs to Encourage Public Transportation to Increase Public Transportation Mode Share to 7% by 2030 and to 8% by 2035
Action T-4.1 Explore alternative forms of public transit, such as micro transit and/or new electric shuttle routes, in areas with higher congestion and population densities. Micro transit is a type of on-demand, shared transportation service that typically operates with smaller vehicles, such as vans or minibuses, and offers flexible routes and schedules.

Action T-4.2 Market and publicize public transportation improvements as they are planned and implemented in a variety of methods (social media, newspaper, radio, etc.) and languages to help facilitate use and success of improvement.

Action T-4.3 Partner with Santa Barbara MTD to determine transit priority projects and determine best potential locations for expansion and increased service.

Action T-4.4 Work with nonprofit and community stakeholders to enhance public transit opportunities.

Action T-4.5 Work with Santa Barbara MTD to ensure public transportation access and improvements are prioritized in low-income and high population density areas of the City.

Action T-4.6 Work with MTD to identify and implement pilot projects and infrastructure updates to make transit safer, more consistent, and more convenient.

Initial Study
Draft Initial Study – Negative Declaration 19
ID # Measures and Actions
Measure T-5 Support and Promote Regional Programs that Reduce the Use of Single Occupancy Vehicles Action T-5.1 Continue to work with SBCAG to encourage employers to develop Transportation Demand Management (TDM) Plans for their employees. TDM plans should include incentives for employees to bike, walk, carpool, or take the bus to work and should be publicized on a website.

Action T-5.2 To enhance the Santa Barbara community’s ability to telecommute, implement SBCAG's Broadband Regional Study to identify areas of the City that have limited access to broadband service due to infrastructure and financial limitations.

Action T-5.3 To enable telecommuting, leverage the grant writer position(s) in strategy A-2.2 to identify funding opportunities to bridge the broadband access gap in the City by helping to fund installation of infrastructure or subsidize broadband service for low-income households.

Action T-5.4 Provide active and alternative transportation resources across all businesses in the city prioritizing small, women owned, and minority owned businesses regardless of Transportation Demand Management Plan (TDM) membership.

Action T-5.5 Implement 2022 California Assembly Bill 2097 – Residential, Commercial, or Other Development Types: Parking Requirements which prohibits the City from imposing minimum parking requirements on residential and commercial development, if located with ½ mile of public transit that is consistent with AB 2097.

Action T-5.6 In line with the General Plan, develop and implement a program to manage parking of singleoccupancy vehicles. Utilize on street parking pricing for all downtown parking locations and use revenue to fund active transportation, public transportation projects, and neighborhood improvements. The program should address parking issues citywide and consider measures to prevent impacts to surrounding areas and coastal access. This analysis may include citywide use of parking permit programs and other measures.

Action T-5.7 Develop the Pilot Bike Share Program into a permanent and dependable bike share network that provides access to key destinations throughout the City, and work with regional partners to assess potential for a regional bike share system.

Action T-5.8 Coordinate with SBCAG and regional partners to update regional active transportation maps.

Distribute active transportation maps and educational materials to various stakeholders. Prioritize education regarding digital mapping that is available on regularly used platforms like Google Maps.

Action T-5.9 Partner with the tourism and business sectors of the greater Santa Barbara County region to identify pathways to increase active transportation by tourists and employees.

Action T-5.10 Reduce driving of single occupancy vehicles through public education and engagement. Examine equity concerns around reducing single occupancy vehicles and ensure there are adequate resources available for alternative forms of transportation.

Action T-5.11 Explore options to address long distance commuter parking. For example, add a parking lot outside of the downtown area for long distance commuters and use mode share to bring these employees into the downtown area from the new parking lot, reducing parking congestion.

Measure T-6 Increase Zero-Emission Passenger Vehicle Use and Adoption to 30% by 2030 and 55% by 2035 Action T-6.1 In 2025 and every 3-years thereafter, amend the Municipal Code to require increased number of electric vehicle capable charging spaces in new construction and major redevelopment for commercial, mixed-use, and multi-family development.

Action T-6.2 In 2025 and every 3-years thereafter, revisit commercial and multi-family building ordinances to be updated and require large commercial (more than 10,000 square feet) and large multi-family (more than 20 units) building owners that are providing parking to install working electric vehicle chargers in 20% of parking spaces for existing buildings when undergoing a major remodel (over 50% of building effected or an addition of over 50% of gross floor space).

Action T-6.3 Add 1,788 (by 2030) and 3,536 (by 2035) new publicly accessible electric vehicle charging stations throughout the City and at City-owned facilities to support community EV charger access.

Action T-6.4 Support private development of EV charger installations by effectively streamlining City processes, such as expediting permitting, easing onerous regulations, develop a permitting design guide.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
20 ID # Measures and Actions
Action T-6.5 Identify private sector partnerships and develop affordable, zero-emission vehicle car share programs to serve affordable housing and/or multi-unit developments with a priority to target under-resourced populations.

Measure T-7 Accelerate Zero-Emission Commercial Vehicle Use and Adoption to 26% by 2030 and 45% by 2035 Action T-7.1 Develop and implement a City Zero Emission Vehicle Action Plan (ZEVAP) to identify policies to accelerate ZEV adoption community wide.

Action T-7.2 Identify and connect commercial vehicle owners, particularly those serving under-resourced communities, to resources that can incentivize vehicle electrification. This could include local tax breaks.

Action T-7.3 Provide information to the public on low-carbon fuel standards (LCSF) and how businesses can develop LCSF credits or other state and federal programs to help fund conversion of commercial fleets to zero emissions vehicles.

Action T-7.4 Create a small business truck buyback program to buyback trucks from local small businesses to upgrade to electric.

Measure T-8 Electrify or Otherwise Decarbonize 6% of Off-Road Equipment by 2030 and 20% by 20351 Action T-8.1 Align with or exceed 2021 California Assembly Bill 134 – Air Pollution: Small Off-Road Engines and expand enforcement of the ordinance that bans gas powered small offroad engines by 2024 (e.g., lawn and garden equipment). Provide income tiered incentives or buyback programs for burdened residents and businesses. Identify staffing needs for an enforcement and implementation tracking program run by the relevant City department.

Action T-8.2 Inform, educate, and support the transition of local employers to zero emission off-road equipment, including major construction companies, manufacturers, landscapers, and warehouse companies.

Action T-8.3 Investigate off-road equipment fleets in the City of Santa Barbara, identify fleets with highest decarbonization potential, and conduct engagement to under-resourced communities to understand how to support conversion.

Action T-8.4 Partner with Santa Barbara County Air Pollution Control District to expand rebate and incentive programs for upgrading off-road equipment to hybrids, biofuels, or fully electric.

Action T-8.5 Leverage the grant writer position(s) in strategy A-2.2 to source state funding to decarbonize offroad equipment as a result of Executive Order N-79-20 and State Climate Funding Package.

Action T-8.6 Develop a landscape equipment education and incentive program incentivizing motorized landscape equipment electrification (electric leaf blowers already required, but can get rolled into an education campaign) for hedge trimmers, etc.

Waste, Solid Waste, and Wastewater Measures
Measure W-1 (Municipal) Increase Municipal Procurement of Recovered Organics Waste Products Action W-1.1 Require City agencies to procure and apply compost generated from municipal organic waste to the exterior of suitable facilities as part of their operations.

Action W-1.2 Increase signage for municipal buildings, parking, and sidewalk bins on accepted landfill, recyclable, and compostable materials.

Action W-1.3 Investigate opportunities for procuring recovered organic waste products within municipal facilities.

Measure W-2 (Municipal) Reduce Municipal Water Consumption Action W-2.1 Continue implementing City policies for water-conserving equipment upgrades and practices at City government facilities. Implement additional facility, landscape, and procedure improvements to further conserve water as identified and determined feasible.

Action W-2.2 Create a Green Community Infrastructure Program based on the Stormwater BMP Guidance Manual with upgraded public spaces, green parking lots, green alleys and increased green stormwater infrastructure on City facilities.

Initial Study
Draft Initial Study – Negative Declaration 21
ID # Measures and Actions
Measure W-3 Reduce Per Capita Potable Water Consumption 1.05% by 2030 and 1.58% by 2035 Action W-3.1 Implement all cost-effective measures identified in the Water Conservation Strategic Plan.

Action W-3.2 Leverage the grant writer position(s) in strategy A-2.2 to source funding for the Water Conservation Strategic Plan programs and rebates.

Action W-3.3 Educate the community through the Water Resources division of Public Works to understand available incentives, options, and programs to reduce per capita water use.

Action W-3.4 Expand public engagement campaigns to promote the available rebates through the City's Water Conservation Programs.

Action W-3.5 Utilize available enhanced water consumption data from the City’s Automated Metering Infrastructure, along with the WaterSmart customer portal, to educate water customers about water use patterns and leak detection.

Action W-3.6 Leverage the grant writer position(s) in strategy A-2.2 to provide specialized rebate or other funding to low and medium incomes homes for installing laundry to landscape, rainwater catchment system, low-flow appliances, and fixing water leaks.

Measure W-4 Reduce Organic Waste 80% below 2014 levels by 2030 and 85% by 2035 Action W-4.1 Meet the requirements of 2016 California Senate Bill 1383 to reduce organics in the waste stream by 80% below 2014 levels. Include existing activities of:
▪ Pilot and evaluate emerging technologies like at sourceorganic waste digestion to reduce organic waste by restaurants and other major food waste producers. ▪ Implement enforcement and fee for incorrectly sorted materials with sensitivity to shared collection.
▪ Increase bin signage across commercial and residential areas of acceptable landfill, recyclable, and compostable materials.

Action W-4.2 Create a templated training for businesses to educate their employees about circular economybased practices annually by providing training resources and rebate program to fund employee time for training. Support lower-impact reusable and reduced packaging businesses.

Action W-4.3 Conduct targeted multicultural education and assistance campaigns to enhance reuse, ways to prolong the useful life of common materials and items, and sustainable purchasing practices.

Action W-4.4 Conduct a Bring Your Own (BYO) education and outreach training for the community on reusables and implementing more sustainable packaging into daily use. Provide resources of education on City website. Educate community on food scraps on resource center.

Action W-4.5 Conduct waste characterization studies every 4-5 years to inform programs and policies. Leverage study to understand the waste stream and create a plan to increase diversion and reduce contamination.

Action W-4.6 Collaborate with the County and Resource Conservation District to develop a regional compost trading program to provide farmers with compost to meet organic procurement target set by 2016 California Senate Bill 1383.

Action W-4.7 Establish regional consortium to plan and pursue funding for infrastructure beyond 2025 California Senate Bill 1383 targets.

Action W-4.8 Establish relationships with multi-unit property owners/managers to develop signage for their properties. Go door-to-door at each multi-unit unit yearly to provide supplies and education for proper sorting.

Action W-4.9 Conduct outreach campaign to low and medium -income residents educating them on issues related to abandoned waste and informing them on how to access bulky item and abandoned waste services at no cost.

Action W-4.10 Partner with the harbor, airport and other major Santa Barbara facilities to facilitate no single use plastic practices.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
22 ID # Measures and Actions
Action W-4.11 Continue to provide different bin size options for green waste, recycling, and trash at different costs (smaller bins being cheaper options) and work towards discontinuing the use of larger waste containers as feasible.

Action W-4.12 Ban items without means of recycling or recycling markets, such as sale of polystyrene, produce bags, plastic packaging, straws, plastics #4-7, and mixed materials.

Action W-4.13 Implement pilot project for reusable restaurant to-go containers.

Action W-4.14 Explore opportunities to promote a "circular economy" among local manufacturers and industry.

Build on existing AB 619 legislation to fund temporary or permanent food facility item reuse.

Action W-4.15 Partner with libraries and other existing facilities to market campaigns about waste reductions, reuse, and repair.

Action W-4.16 Partner with UCSB, ICLEI and other organizations to cost effectively evaluate and develop resources around consumption-based emissions. Utilize consumption-based emissions inventory to understand Santa Barbara's most carbon intensive consumption habits and emission reduction potential and promote closed-loop circular economy. Based on the results, create a plan to achieve the objective of zero growth of waste generation. Consider reusable diaper service, plant-based diets, etc.

Action W-4.17 Create a training/education program that is free and accessible to all residents and employees to learn about circular economy practices and diversion strategies and effects of overconsumption.

Carbon Sequestration
Measure CS-1 Increase Carbon Sequestration by Maintaining Existing Trees and Natural Lands and by Planting 4,500 New Trees throughout the Community by 2030
Action CS-1.1 Continue to implement and expand the City's Urban Forest Management Plan to include goals for promoting street tree health, enhancing resiliency, increasing the environmental benefits and cobenefits resulting from street trees and shading, community engagement around the urban forest.

Include activity to promote street tree health and maintaining existing trees through partnerships with the community and localnon-profits.

Action CS-1.2 Continue to look for opportunities to increase carbon sequestration via land acquisitions and tree protections in alignment with the City's Open Space, Parks and Recreation Element.

Action CS-1.3 Implement the City’s Community Wildfire Protection Plan to reduce fire risk and carbon loss due to wildfires by conducting vegetation management throughout the City. Ensure that vegetation management projects minimize full removal of vegetation or conversion of land cover type from a higher carbon sequestration land cover (shrubs and trees) to a lower carbon sequestration land cover type (annual grasses).

Action CS-1.4 Develop a Citywide, or participate in a regional, carbon sequestration analysis and plan to explore opportunities to increase sequestration in the City.

Action CS-1.5 Implement the City of Santa Barbara’s Creek Tree Program to assist private creekside landowners with improving wildlife habitat along creeks in Santa Barbara through the protection and planting of native trees. Develop a wildlife habitat install program where the City provides carbon sequestering plants and creek trees and removes non-natives as feasible for appropriate creekside properties.

Prioritize low-income areas for implementation of the Creek Tree Program and keep an updated publicly accessible page on the City website with important information about the program.

Action CS-1.6 Update tree canopy coverage data within the City to measure the change in coverage over time as it relates to sequestration as part of the next Urban Forest Management Plan update.

Action CS-1.7 Invest and participate in regional development of local carbon off-set program in partnership with the County and/or Central Coast Regional Collaborative.

Action CS-1.8 Prioritize low-income areas of the City with less existing tree canopy for tree plantings and increase shading in gathering spaces.

Initial Study
Draft Initial Study – Negative Declaration 23
ID # Measures and Actions
Measure CS-2 Explore New Carbon Sequestration and Carbon Capture Opportunities Action CS-2.1 Create an organizational body (internally within the City or through a partnership like with UCSB or the Santa Barbara Botanical Garden) to lead program development and research for facilitating emergent carbon sequestration and carbon capture plans relevant to the City.

Action CS-2.2 Pilot and promote carbon sequestering construction materials like low-carbon concrete and mass timber.

Action CS-2.3 Work with local architects, construction trades, and workforce development organizations to expand industry knowledge and adoption of carbon sequestering building materials and techniques.

Action CS-2.4 Conduct a feasibility study to explore carbon capture and storage opportunities for the community.

Action CS-2.5 Initiate a study partnering with local academic institutions and the ReSource Center to identify and research ways to create a circular economy around organic waste and increasing edible food rescue.

Action CS-2.6 Conduct a feasibility study to explore repurposing biosolids into biochar locally and replacing conventional fertilizer through Public Works.

Action CS-2.7 Invest in the existing kelp farming efforts by studying regional environmental impacts and sequestration potential through a partnership with UCSB.

Action CS-2.8 Partner with furniture, home renovation, and construction companies to promote sustainable and locally harvested timber to reduce embodied carbon from transit of construction materials and reduce the price premium of emerging timber uses.

Action CS-2.9 Leverage the grant writer position(s) in strategy A-2.2 to expand funding for the carbon sequestration program.

Action CS-2.10 If there are localized co-benefits to any sequestration projects focus development, when possible, to benefit historically adversely impacted under-resourced communities.

Measure CS-3 Maintain and Expand Existing Restoration Projects to Sequester Carbon through a 25-acre Net Increase in Restored Land Areas by 2030
Action CS-3.1 Develop a Citywide restoration plan in partnership with the Creeks Division, Parks and Recreation, and Public Works to achieve target net increases in restored land area and waterways. Prioritize implementation of restoration projects in disadvantaged communities. Facilitate community outreach through surveys and public meetings on ways to best restore lands and waterways within the City as well as identify additional priority areas.

Action CS-3.2 Should parcels be identified for potential rezoning from their existing state to a park or open space, consider the following:
1) provide flexible solutions for developing urban parks in infill areas where traditional neighborhood and community parks are not feasible;
2) aim to achieve the greatest carbon sequestration possible, given constraints around use and amenities to be included. Use and amenities are determined by Parks and Recreation staff through a community process; and
3) selection of parcels be made with an aim to serve underserved communities.

Action CS-3.3 Expand Creeks Division volunteering programs to help maintain creek restoration projects.

Coordinate projects with Parks and Recreation and Sustainability and Resilience Departments.

Action CS-3.4 Facilitate annual reporting as part of the urban forestry, wildfire prevention, and Citywide restoration efforts by developing and maintaining existing projects to gauge progress over time and identify any gaps related to ongoing projects. Incorporate GHG reduction calculations into this monitoring plan.

Action CS-3.5 Leverage the grant writer position(s) in strategy A-2.2 to pursue funding for restoration activities with a focus on projects that have not reached completion due to funding constraints.

Action CS-3.6 Include long term maintenance in restoration planning and implementation by partnering with the community and local organizations to assist in maintenance activities. Include continued maintenance and expansion of Creeks Division projects of the Upper Las Positas Creek, Mission Creek, Palermo Open Space, Arroyo Burro, and the Andree Clark Bird Refuge.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
24 ID # Measures and Actions
Measure CS-4 Increase Carbon Sequestration by Applying 0.08 tons of Compost per Capita Annually in the Community through 2030 and 2035
Action CS-4.1 Enforce compliance with 2016 California Senate Bill 1383 and aim to exceed the baseline requirement by establishing a minimum level of compost application per year on applicable/appropriate land throughout the City including City-owned land twice that of SB 1383 requirements.

Action CS-4.2 Identify additional locations within the City to apply compost and provide household incentives for small-scale implementation.

Action CS-4.3 Maintain procurement policies to comply with SB 1383 requirements for jurisdictions to purchase recovered organic waste products.

Action CS-4.4 Work with the ReSource Center to provide residents, businesses, and developers with educational material on where compost can be acquired and how it can be used (i.e., landscaping).

Action CS-4.5 Collaborate with Santa Barbara Community College, UC Santa Barbara, local schools, and Public Works to identify opportunities to apply compost to landscaping.

Measure CS-5 Reduce GHG Emissions of Residential and Commercial Building Materials 20% by 2030 and 40% by 2035 in Line with AB 2446
Action CS-5.1 Conduct a feasibility study on carbon capture technologies to locally produce calcium carbonate (low carbon concrete) creating sequestration via construction materials. Determine viability within the City and project demand.

Action CS-5.2 Partner with UCSB to pilot a building specific embodied carbon reduction project for planned construction.

Action CS-5.3 Develop a strategic construction and procurement plan to promote construction projects that use alternative materials to reduce embodied carbon. Include scoring criteria in City request for proposals for construction projects that identify resilience features such as water and energy efficiency, reduced urban heat, and decrease the embodied carbon in line with AB 2446.

Community Climate Potential
Measure CP-1 Encourage Community Innovation and Empower the Local Green Economy through Investment in a Green Technology Workforce
Action CP-1.1 Create a Green Technology incubator in partnership with UCSB to determine technological advancement research into clean power, built environment advancement, and carbon sequestration.

Action CP-1.2 Leverage the grant writer position(s) in strategy A-2.2 to source funding for the Green Technology incubator through involvement of venture capitalist and private equity firms.

Action CP-1.3 Facilitate workforce training by partnering with local academic institutions to offer scholarships for students pursuing climate trades.

Action CP-1.4 Partner with Santa Barbara Community College and/or UCSB to develop a clean energy technology certificate program.

Action CP-1.5 Leverage the grant writer position(s) in strategy A-2.2 to establish an Innovation Bootcamp with funding from SBCE to encourage forward thinking sustainability and resilience ideas and pilots. The Innovation Bootcamp will be tiered based on stages.

Action CP-1.6 Create a climate innovation competition for local area students where the prize is a scholarship or grant.

Source: Santa Barbara, City of. 2023. CAP Update.

Initial Study
Draft Initial Study – Negative Declaration 25
The measures included in the CAP Update combined with statewide legislation and initiatives and regional transportation programs will enable the City to meet its emissions reduction target of 40 percent below 1990 levels by 2030. Table 4 shows the contribution of the statewide initiatives along with the measures included in the CAP Update. The City needs to achieve a reduction of 211,647 MT CO2e by 2030 to meet its goal. The estimated GHG reductions accounted for in the CAP Update combined with the GHG reductions from State and SBCE Initiatives total 320,089 MT CO2e by 2030.

Table 4 City of Santa Barbara 2030 GHG Reduction Target by Sector State Initiative Sector 2030 Reduction in
City Emissions (MTCO2e)
Advanced Clean Cars Program, Pavley Standards,
Zero Emissions Vehicles Program, Clean Transit)
On-road Transportation 63,081
SB 1383 Water, Solid Waste, and
Wastewater
45,733
Title 24 Residential/Non-residential
Electricity and Natural Gas
13,594
A. Total State Initiative and SBCE Emissions Reductions 187,784 B. Total City CAP Update Emissions Reductions 132,305
C. Total Expected Emissions Reductions (A+B) 320,089
D. City of Santa Barbara Emissions Reduction Requirement 211,647 E. Meets/exceeds State Goals? (C > D) Yes
Source: Santa Barbara, City of. 2023. CAP Update.

Table 4 and Figure 3 illustrate how the BAU emissions are estimated to increase, thus widening the emissions reductions needed by 2030. Figure 3 also shows emissions reductions expected from State level actions as well as the reductions needed to reach the City of Santa Barbara emissions target.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
26 Figure 3 City of Santa Barbara Future GHG Emissions Projection and Reduction Target Source: Santa Barbara, City of. 2021. Santa Barbara CAP.

Table 5 City of Santa Barbara Future GHG Emissions Projection and Reduction Target Description Emissions (MTCO2e)
1990 Emissions 715,530
2019 Emissions 622,110
2030 BAU Emissions 698,596
2030 Adjusted Forecast 510,812
2030 Target Emissions (49% below 1990 levels) 486,949
2030 Required Reduction from Measures 132,305
Source: Santa Barbara, City of. 2023. Draft CAP Update
Implementation of the measures listed in Table 3 could result in physical changes to the environment that could potentially have a significant impact on the environment. While individual projects resulting from these measures have not been identified for the purposes of this document, the types of actions that could result from realization of the measures are taken into account in considering potential environmental impacts that could occur through implementation of the CAP Update. For example, projects or actions requiring ministerial approval, such as installation of electric vehicle charging stations and supporting infrastructure, new bicycle or pedestrian facilities, and solar photovoltaic (PV), may introduce physical changes related to the temporary presence and operation of construction vehicles and equipment during installation of required facilities and the long-term presence of new facilities such as bike and pedestrian facilities, solar arrays, and electric vehicle charging stations, which could alter pedestrian and vehicular traffic patterns. 2030 Target
486,949 MT CO2e
2035 Target
0 MT CO2e
2030 Emissions After
Reductions
378,507 MT CO2e
2035 Emissions After
Reductions
297,689 MT CO2e
-
100,000
200,000
300,000
400,000
500,000
600,000
700,000
2019 2025 2030 2035 2040 2045
GHG Emissions (MT CO2e)
State Legislative Adjusted Forecast
State Legislative Adjusted Forecast with SBCE + ReSource Center Reductions GHG Emission Reduction Target Pathway
GHG Emissions after CAP Implementation
Initial Study
Draft Initial Study – Negative Declaration 27
Additionally, electrification retrofits may change the physical environment through the need for upgraded service and electrical panels, branch circuit upgrades, and installation of condensate drains to facilitate the installation of electric heat pumps for water and space heating. The associated construction impacts and the physical changes these upgrades and additions would entail are dependent on the year of building construction and location of electrical and service panels and plumbing for connection of condensate drains, which in some cases may include modifications to the interior and/or exterior of buildings for wiring and panel replacement, and minor excavation for connection of drainage to sewer systems. Projects implemented in support of the CAP Update would be reviewed for consistency with the General Plan, other applicable regulatory land use actions, and would be subject to any required environmental assessment that would be completed prior to approval of any project. Future plans or projects would be subject to environmental review under CEQA, and individual impact analyses will identify required plan- or project-specific mitigation measures where applicable.

Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
In 2007, SB 97 acknowledged that climate change is an environmental issue that requires analysis in CEQA documents, and in 2010 the California Natural Resources Agency adopted amendments to the State CEQA Guidelines for the feasible mitigation of GHG emissions or the effects of GHG emissions.

The adopted guidelines gave lead agencies the discretion to set quantitative or qualitative thresholds for the assessment and mitigation of GHGs and climate change impacts. Specifically, Section 15183.5(b)(1)A-G of Title 14 of the California Code of Regulations was amended to state that a qualified GHG Reduction Plan may be used for tiering and streamlining the analysis of GHG emissions in subsequent CEQA project evaluation, provided that the GHG Reduction Plan does the following:
▪ Quantifies GHG emissions both existing and projected over a specific period of time, resulting from activities within a defined geographical area ▪ Establishes a level, based on substantial evidence, below which the contribution to greenhouse gas emissions from activities covered by the plan would not be cumulatively considerable
▪ Identifies and analyzes the GHG emissions resulting from specific actions or categories of actions anticipated within the geographic area
▪ Specifies measures or a group of measures, including performance standards, that substantial evidence demonstrates, if implemented on a project-by-project basis, would collectively achieve the specified emissions level
▪ Establishes a mechanism to monitor the plan's progress toward achieving the level and to require amendment if the plan is not achieving specified levels ▪ Be adopted in a public process following environmental review Therefore, the City proposes to also adopt a quantitative efficiency threshold for use in evaluating whether a plan or project’s GHG emissions would result in a potentially significant environmental impact under CEQA for plans or projects with pre-2030 buildout or initial operation years. The CEQA Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would be applied to plans or projects that cannot tier from the environmental analysis for the City’s CAP Update (as contained in this IS/ND) because the plan or project would not be consistent with the General Plan land use and zoning designations for the project site and would result in greater GHG City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
28 emissions than existing on-site development, or the plan or project would not be consistent with the CEQA GHG Emissions Analysis Compliance Checklist.

The threshold is set at the level of GHG emissions that new development would need to achieve to be consistent with the CAP Update’s communitywide emissions reduction target of 40 percent below 1990 emissions levels by 2030. The efficiency threshold, listed below, is expressed in terms of MT CO2e per service person14 and is applicable to plans or projects with pre-2030 buildout or initial operational years:
▪ 2.13 MT CO2e per service person15
Efficiency thresholds for beyond 2030 would be established later in conjunction with subsequent CAP Updates. Plans or projects that do not tier from the City CAP Update IS/ND that would generate GHG emissions in excess of these thresholds would result in a potentially significant impact on the environment related to GHG emissions and climate change. Mitigation measures would be required to be identified to reduce potentially significant impacts resulting from such plans or projects. Plans or projects that are unable to reduce GHG emissions below these thresholds through implementation of identified mitigation measures would result in a significant and unavoidable environmental impact. The Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis provides guidance during CEQA review and does not propose development or changes to land use and zoning. Thus, implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not have direct construction or operational impacts.

General Plan Designation and Zoning
The CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would be implemented throughout the City and would occur in all Santa Barbara General Plan designations and zoning designations. The plan would not alter any existing designations.

6. Cumulative Projects Scenario
For purposes of CEQA cumulative impacts analysis of the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis, the cumulative projects scenario is the total projected population growth, and the anticipated cumulative development to accommodate that growth, for Santa Barbara in 2030. Population and employment-based growth factors use the most recent SBCAG 2050 Connected - Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) demographic forecasts.16 Household based growth factors similarly use SBCAG 2020 RTP/SCS forecast; however, these are adjusted to account for the 6th Cycle Regional Housing Needs Assessment (RHNA) allocation of housing needs for the City of Santa Barbara between 2023 and 2031. As such, the number of households in the SBCAG region is expected to grow by 8,274 units between 2019 and 2030.
17As outlined in the CAP, the population included in
the CAP is different from the population included in the Housing Element because the Department 14 The service population is equal to the residential population plus the number of jobs. 15 Santa Barbara, City of. 2023. CAP Update.
16 Santa Barbara County Association of Governments. 2020. 2050 Connected Regional Transportation Plan/Sustainable Communities Strategy. https:// www.sbcag.org/wp-content/uploads/2023/09/Connected-2050-Final.pdf. Accessed October 2023. 17 Santa Barbara County Association of Governments. 2021. Regional Housing Needs Allocation Plan 6th Cycle 2023-2031. https://www.sbcag.org/wp-content/uploads/2023/08/final_rhna_plan.pdf. Accessed October 2023.

Initial Study
Draft Initial Study – Negative Declaration 29
of Housing and Community Development (HCD)18 recommends that each jurisdiction create a buffer in the housing element inventory of at least 15 to 30 percent more capacity than required to ensure that sufficient capacity exists in the housing element to accommodate the Regional Housing Need Allocation throughout the planning period. Including a buffer in the CAP could result in an overly conservative emissions reduction forecast and target because these scenarios are in part calculated based on future population scenarios.

7. Required Approvals
City of Santa Barbara
Required approvals include:
▪ Adoption of the CAP Update and CEQA Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis Initial Study-Negative Declaration ▪ Adoption of the CAP Update
▪ Adoption of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
Although individual plans or projects may be implemented later under the umbrella of the CAP Update, each individual plan or project would be subject to separate environmental review under CEQA.

Other Public Agencies
The City of Santa Barbara has sole approval authority over the CAP Update. There are no other public agencies whose approval is required.
18 HCD. June 10, 2020. Housing Element Site Inventory Guidebook Government Code Section 65583.2. https://www.hcd.ca.gov/community-development/housing-element/docs/sites_inventory_memo_final06102020.pdf City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
30 This page intentionally left blank.

Initial Study
Draft Initial Study – Negative Declaration 31
City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
32 Environmental Factors Potentially Affected
This project would potentially affect the environmental factors checked below, involving at least one impact that is “Potentially Significant” or “Less than Significant with Mitigation Incorporated” as indicated by the checklist on the following pages.
□ Aesthetics □ Agriculture and
Forestry Resources
□ Air Quality
□ Biological Resources □ Cultural Resources □ Energy
□ Geology and Soils □ Greenhouse Gas
Emissions
□ Hazards and Hazardous
Materials
□ Hydrology and Water
Quality
□ Land Use and Planning □ Mineral Resources
□ Noise □ Population/Housing □ Public Services
□ Recreation □ Transportation □ Tribal Cultural Resources □ Utilities and Service
Systems
□ Wildfire □ Mandatory Findings
of Significance
Determination
Based on this initial evaluation:
■ I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
□ I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions to the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
□ I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
□ I find that the proposed project MAY have a “potentially significant impact” or “less than significant with mitigation incorporated” impact on the environment, but at least one effect (1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

Determination
Draft Initial Study – Negative Declaration 33
□ I find that although the proposed project could have a significant effect on the environment, because all potential significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

Signature Date
Printed Name Title
City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
34 Environmental Checklist
1 Aesthetics
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
Except as provided in Public Resources Code Section 21099, would the project:
a. Have a substantial adverse effect on a
scenic vista? □ □ ■ □
b. Substantially damage scenic resources,
including but not limited to, trees, rock
outcroppings, and historic buildings
within a state scenic highway? □ □ ■ □
c. In non-urbanized areas, substantially
degrade the existing visual character or
quality of public views of the site and its
surroundings? (Public views are those
that are experienced from a publicly
accessible vantage point). If the project is
in an urbanized area, would the project
conflict with applicable zoning and other
regulations governing scenic quality? □ □ ■ □
d. Create a new source of substantial light
or glare that would adversely affect
daytime or nighttime views in the area? □ □ ■ □
a. Would the project have a substantial adverse effect on a scenic vista? b. Would the project substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? As described in Plan Location and Physical Setting, the City of Santa Barbara is located on Santa Barbara County’s South Coast, and the city’s limits extend into the Pacific Ocean. The majority of Santa Barbara is developed with the densest development and largest buildings located within the City’s downtown area. The primary arterial roadways in the City include U.S. Highway 101 (U.S. 101), U.S. Highway 192 (U.S. 192), and State Route 154 (SR 154). Views south of U.S. 101 include beaches, coastal bluffs, and the Mesa. North of U.S. 101, downtown cityscape of Santa Barbara, and the Santa Ynez Mountains and surrounding foothills, with single-unit residential development scattered in the Riviera on the lower elevations, provide a backdrop for the City. East of the City limits, Santa Barbara abuts the wooded, semi-rural community of Montecito, while to the west, suburban residential, commercial, and agricultural uses comprise Hope Ranch and the Goleta Valley.

Environmental Checklist
Aesthetics
Draft Initial Study – Negative Declaration 35
The City’s 2010 Program Environmental Impact Report for the General Plan Update (General Plan EIR) identifies ridgelines and foothills; ocean, beach and harbor; and substantial Open Space Areas as Important Visual Resources.
19 Surrounding steep hillsides, peaks, and rocky outcrops of the Santa Ynez Mountains contribute to the scenic quality of the City. Parks located in the foothills, such as Parma and Skofield Parks, support miles of scenic trails and provide views of the Pacific Ocean and City. Three creek systems, the Sycamore, Mission, and Arroyo Burro, provide natural corridors that contrast with existing urban development. Large groves of mature sycamore and oak trees along the Sycamore and Mission Creeks provide contrast with developed areas of the City, and woodlands along the Arroyo Burro Creek are important natural features in the San Roque, Hitchcock, and Hidden Valley neighborhoods. In addition, the City contains approximately 35,000 street trees, more than 9,000 public trees in developed parks and landscaped areas of public facilities, and around 30,000 trees within City-managed open spaces.
20 These trees soften the appearance of buildings,
roads, and parking lots which provide visual contrast to building masses in addition to pleasant scenery for residents, employees, and tourists. The City’s tree inventory contains 456 different varieties of trees.
21 These include specimen trees which are identified by the City’s Parks and Recreation Commission to be of high value because of their type, size, and/or age.

Santa Barbara’s shoreline extends approximately seven miles from Montecito on the east to Hope Ranch on the west and includes beaches, some with existing residential and commercial developments. Public beaches and waterfront and blufftop parks allow for public access to the area’s natural scenery, including wide, sandy beaches and steep coastal bluffs. The waterfront of Santa Barbara provides panoramic ocean and mountain views with single-story structures along the waterfront, allowing for views of the ocean and mountains. The line of palm trees within Chase Palm Park contributes to the scenic character of the area.

Sweeping views of the City are available within certain neighborhoods and on certain public streets that are elevated within the foothills. The Riviera and Eucalyptus Hill neighborhoods, and the north side of the Mesa and TV Hill, offer views of the City, Pacific Ocean, and surrounding hillsides. Roads located within the foothills, such as Alameda Padre Serra and Mountain Drive, provide views of downtown and the Pacific Ocean.

Views from downtown Santa Barbara are characterized by foreground views of the urban environment, including buildings, roads, sidewalks, street trees, and parking areas. The downtown streetscape includes a street grid with short blocks and active transportation facilities (sidewalks/bicycle lanes). The architecture, scattered parks, and parking lots provide a sense of openness through the downtown area. Views of the Santa Ynez Mountains, hillsides, and the Rivera occur intermittently throughout the downtown urban core, primarily along roadways, intersections, and across larger parking lots and lower buildings. These views are interrupted by taller buildings and street trees. Open spaces, such as Plaza De la Guerra, the municipal Santa Barbara Golf Club, and Alameda Park, provide public mountain views. Surrounding views can also be seen from the upper stories of buildings such as the County Courthouse and on top of parking garages. Notable 19 Santa Barbara, City of. 2010. Program Environmental Impact Report for the Plan Santa Barbara General Plan Update. September 2010. https://www.santabarbaraca.gov/services/planning/plan.asp. Accessed October 27, 2023. 20 Santa Barbara, City of. 2022. Trees and Urban Forestry. https://sbparksandrec.santabarbaraca.gov/programs-services/trees-and-urbanforestry#:~:text=The%20City%20of%20Santa%20Barbara%20Urban%20Forestry%20Program%2C,and%20around%2030%2C000%20trees %20within%20City-managed%20open%20spaces. Accessed October 27, 2023. 21 Santa Barbara, City of. 2014. Urban Forest Management Plan. https://santabarbaraca.gov/sites/default/files/documents/Parks%20%26%20Recreation/Urban%20Forestry/Urban%20Forest%20Manage ment%20Plan.pdf. Accessed October 27, 2023.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
36 structures, such as the County Courthouse and Main Post Office contribute to the visual character of downtown Santa Barbara.

According to the California Scenic Highway System, there is one officially designated scenic highway (SR 154) and one eligible scenic highway (U.S. 101) in the City. 22 The California Scenic Highway
Program preserves and protects scenic highway corridors from changes that would diminish the aesthetic value of lands adjacent to these scenic highways. The City’s General Plan Circulation Element contains the Scenic Highways Element which provides planning, design and maintenance standards for roads within the City including Cabrillo Boulevard, and Sycamore Canyon Road. The City of Santa Barbara Coastal Land Use Plan (Coastal LUP) identifies the segment of U.S. 101 within the Coastal Zone as providing a distinct visual gateway to the City with its landscaping, views of the mountains and ocean, and unique highway structures.
23 U.S. 101 enters the City’s Coastal Zone at
Mission Creek and extends to Olive Mill Road). In addition, the Coastal LUP recognizes Cabrillo Boulevard and Shoreline Drive for their visual qualities such the ability to view the Santa Barbara Channel and shoreline.
24 The City’s General Plan contains several goals and policies related to aesthetics and visual resources within the Land Use Element, Circulation Element, and Environmental Resources Element. The Land Use Element guides the physical and socioeconomic character of the City through environmental protection, growth management, community design, and neighborhoods. Land Use Element Goal LG-12 aims to strengthen and enhance design and development review standards and process to enhance community character, promote affordable housing, and strive towards community sustainability principles. The inclusion of design guidelines ensures that proposed development would not preclude preservation of visual assets; and building standards, including setbacks, height, and floor area ratios. Current Santa Barbara design guidelines include the Architectural Board of Review Guidelines, Chapala Street Guidelines, El Pueblo Viejo District Guidelines, Haley-Milpas Design Guidelines, Lower Riviera Special Design District Guidelines, Outdoor Lighting Design Guidelines, and more. 25
The Circulation Element contains the Scenic Highways Element which provides goals for development, establishment, and protection of scenic highways. Within the City, State Route (SR) 154 is the only officially designated scenic highway and U.S. 101 is eligible for official designation. An eligible State highway becomes officially designated only if the local government takes steps to pursue nomination of an eligible route. The Scenic Highways Element contain goals for potential State Scenic Highways (Cabrillo Boulevard [no longer a State Highway] and Sycamore Canyon Road (SR 144), Stanwood Drive (SR 192), Mission Ridge Road, (SR 192) Mountain Drive) and Potential City Scenic Routes (Shoreline Drive), including landscaping the public right-of-way, and the establishment of architectural controls and setbacks.
26 22 California Department of Transportation (Caltrans). 2018. California State Scenic Highway System Map. https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa. Accessed October 2023. 23 Santa Barbara, City of. 2019. Local Coastal Program. https://www.santabarbaraca.gov/civicax/filebank/blobdload.aspx?BlobID=202908.

Accessed October 2023.
24 Santa Barbara, City of. 2019. Local Coastal Program. https://www.santabarbaraca.gov/civicax/filebank/blobdload.aspx?BlobID=202908.

Accessed October 2023.
25 Santa Barbara, City of. 2011. Land Use Element.
https://www.santabarbaraca.gov/sites/default/files/documents/General%20Plan/General%20Plan/Land%20Use%20Element%2A.pdf.

Accessed October 2023.
26 Santa Barbara, City of. 2011. Circulation Element.
https://santabarbaraca.gov/sites/default/files/documents/General%20Plan/General%20Plan/Circulation%20Element%2A%20%28include s%20Scenic%20Highways%29.pdf. Accessed October 2023.

Environmental Checklist
Aesthetics
Draft Initial Study – Negative Declaration 37
The Environmental Resources Element, which includes the 1979 Conservation Element, addresses visual resources, including hillsides, shorelines, trees, and open space throughout the City. The Conservation Element’s Scenic Resources Map specifically designates scenic resources as:
▪ Riparian/Creekside open space resources;
▪ Hillsides (slope of 30% or greater);
▪ Shoreline; and
▪ Open Space (including Douglas Family Preserve, Montecito Golf Course, Andree Clark Bird Refuge, Clark Estate, Child’s Estate, and the “Kim Nursery” property on the westside).

These resources are mapped in the City as Visual Unique, Visual Hillside, and Visual Shoreline, derived from the City’s MEA Visual Resources map.

The Environmental Resources/Conservation Element incorporates goals and policies which intend to maintain the scenic character of the City. Implemented policies limit the alteration of natural topography and vegetation on hillsides, protect trees, limit the obstruction of scenic view corridors, and prevent degradation of riparian environments.
27 CAP measures and actions serve as high-level
guidance policies that would adhere to existing City design guidelines, minimizing impacts to scenic views and aesthetics.

Projects implemented in support of the CAP Update would be required to adhere to City development regulations and General Plan policies to retain character of the City and minimize environmental impacts. In addition, projects implemented in support of the CAP Update would be reviewed for consistency with the General Plan, other applicable regulatory land use actions, and would be subject to any required environmental assessment that would be completed prior to approval of any project. Additionally, all CAP measures that may result in potential visual changes will be subject to City review to ensure consistency with current City design guidelines. Although some projects may result in short-term changes related to ongoing construction, facilities upgrades, and transportation improvements, these changes would undergo City review to ensure adequate timeline and aesthetic approach to minimize any potential visual changes. Such measures that might result in short-term visual changes include Measure BE-1, Measure T-3, and Measure CS-1. These measures include updating existing infrastructure to improve building electrification, biking and walking infrastructure, and planting more trees throughout the City. As such, the CAP Update would not result in adverse impacts related to scenic vistas, viewing corridors, or scenic roadways within the City. Furthermore, due to intervening development typical of an urban setting, proposed projects included in the CAP Update would not likely be visible from the scenic vistas or resources.

Thus, scenic resources such as trees, rock outcroppings, and historic buildings would not be damaged within a scenic highway. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant impact related to scenic vistas and related to scenic resources within scenic highways.

LESS-THAN-SIGNIFICANT IMPACT
c. Would the project, in non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those experienced 27 Santa Barbara, City of. 2011. Environmental Resources Element. https://santabarbaraca.gov/sites/default/files/documents/General%20Plan/General%20Plan/Environmental%20Resources%20Element% 20%28includes%20Noise%2A%20and%20Conservation%2A%29.pdf. Accessed October 2023.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
38 from a publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? The character of the City of Santa Barbara is generally urbanized. Per CEQA Guidelines Section 15387, the City of Santa Barbara is an “urbanized area” because it is a city with a population of 50,000 or more. Distinct architectural styles, such as the California Adobe, Monterey Revival, and Spanish Colonial Revival are central to the City’s visual character. 28 Under Public Resources Code Section 21099, aesthetic and parking impacts resulting from new developments within a transit priority zone are exempt from being considered significant under CEQA for any project that would be considered residential development, mixed-use development, or an employment center. According to the California Public Resources Code Section 21099(a)(7), a transit priority area means an area within one-half mile of a major transit stop that is existing or planned, if the planned stop is scheduled to be completed within the planning horizon included in a Transportation Improvement Program.

The CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would include requirements for new development, such as all-electric building requirements. While these policies would influence development, they would not alter the visual character of portions of Santa Barbara, for example they would not cause changes to building heights that would surpass the City’s zoning and Charter height limits, and massing.. New development forecasted in accordance with the CAP Update would be subject to development standards and design guidelines in the zoning ordinance.. Thus, all projects would be subject to the maximum allowable height established in the City Charter.

Projects subject to the objective standards, such as building retrofits and active transportation infrastructure, would still require consistency with City design standards and could require design board approval per the City Charter but their review would be limited to confirming that projects comply with the objective standards. Project applicants who opt-in to using the objective design and development standards would still be required to abide by other applicable objective Municipal Code standards, which include height, outdoor lighting, specific architectural styles for projects within Landmark District and Historic District overlay zones, and landscaping materials.

If a project falls within a transit priority area it would still be subject to these City policies, as Public Resources Code Section 21099 does not alter or limit the ability of the City to enforce local design ordinances. Mandatory compliance with existing review procedures, policies, guidelines, and design standards would ensure that reasonably foreseeable development under the CAP Update would not substantially degrade the existing visual character or quality of public views of the site and its surroundings, or conflict with applicable zoning and other regulations governing scenic quality.

Therefore, this impact would be less than significant.

LESS-THAN-SIGNIFICANT IMPACT
d. Would the project create a new source of substantial light or glare that would adversely affect daytime or nighttime views in the area?
Glare is a common occurrence in the City, primarily due to the high number of days per year with direct sunlight and the highly urbanized nature of the City. Daytime glare can result from sunlight reflecting off glass, other structural fixtures of buildings, and windshields of parked and moving 28 Santa Barbara, City of. 2010. Program Environmental Impact Report for the Plan Santa Barbara General Plan Update. https://www.santabarbaraca.gov/services/planning/plan.asp. Accessed October 2023.

Environmental Checklist
Aesthetics
Draft Initial Study – Negative Declaration 39
vehicles within the roadways in the City. Development forecasted in accordance with the CAP Update would be required to comply with the provisions of the City Municipal Code, including Section 30.180.070, which states that no use shall be operated such that significant, direct glare, incidental to the operation of the use is visible beyond the boundaries of the lot where the use is located. Title 30 and Title 22 state that any project involving exterior lighting with apparent potential to create significant glare on neighboring parcels is required to undergo a noticed design review hearing.
29 Section 22.75.060 sets standards to control nuisance lighting and glare in and adjacent to residential zones through enforcement measures applied by the Community Development Department. Such measures could include the preparation and implementation of a professional lighting plan, control through the use of vegetation, or use of appropriate shielding.

Reasonably foreseeable development under the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not create a new source of substantial light or glare which would adversely affect surrounding areas or important public day or nighttime views in the area. Therefore, potential light and glare impacts would be less than significant.

LESS-THAN-SIGNIFICANT IMPACT
Cumulative Impacts
The cumulative projects scenario is total projected population growth for Santa Barbara (96,637 persons) in 2030. Cumulative impacts related to scenic resources, visual character, and increased light and glare would generally be site-specific, and cumulative projects are not anticipated to contribute to cumulative aesthetic impacts with adherence to the City’s Municipal Code and General Plan policies. Because of the developed nature of Santa Barbara, future infrastructure projects such as building electrification and active transportation infrastructure under the CAP Update, in combination with other cumulative projects, would not adversely impact the visual character of the City because they would comply with existing design standards and ordinances. Future development in the City, that this CAP update would influence, would be required to comply with the City’s objective design standards and be reviewed against applicable General Plan policies and City’s design standards and guidelines for design quality and compatibility with adjacent land uses.

Furthermore, as a guidance document, the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in cumulative impacts. Therefore, implementation of the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant cumulative impact related to aesthetics.

LESS-THAN-SIGNIFICANT IMPACT
29 Santa Barbara, City of. 2022. Santa Barbara Municipal Code. https://library.qcode.us/lib/santa_barbara_ca/pub/municipal_code.

Accessed October 2023.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
40 2 Agriculture and Forestry Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
Would the project:
a. Convert Prime Farmland, Unique Farmland,
or Farmland of Statewide Importance
(Farmland), as shown on maps prepared
pursuant to the Farmland Mapping and
Monitoring Program of the California
Resources Agency, to non-agricultural use? □ □ □ ■
b. Conflict with existing zoning for agricultural
use or a Williamson Act contract? □ □ □ ■
c. Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in
Public Resources Code Section 12220(g));
timberland (as defined by Public Resources
Code Section 4526); or timberland zoned
Timberland Production (as defined by
Government Code Section 51104(g))? □ □ □ ■
d. Result in the loss of forest land or
conversion of forest land to non-forest
use? □ □ □ ■
e. Involve other changes in the existing
environment which, due to their location
or nature, could result in conversion of
Farmland to non-agricultural use or
conversion of forest land to non-forest
use? □ □ □ ■
a. Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? or
b. Would the project conflict with existing zoning for agricultural use or a Williamson Act contract The City of Santa Barbara does not contain farmland or lands used for agricultural purposes. 30 Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas 30 Santa Barbara, City of. 2011. Santa Barbara 2011 General Plan. https://santabarbaraca.gov/sites/default/files/documents/General%20Plan/General%20Plan/Introduction.pdf . Accessed October 24, 2023.

Environmental Checklist
Agriculture and Forestry Resources
Draft Initial Study – Negative Declaration 41
Emissions Analysis would result in no impact related to degradation of agricultural resources or conversion of agricultural land to non-agriculture uses, nor would there be a conflict with existing zoning or general plan land use designations.

NO IMPACT
c. Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)); timberland (as defined by Public Resources Code Section 4526); or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?
or
d. Would the project result in the loss of forest land or conversion of forest land to non-forest use? The City does not contain forest or timberland resources. Additionally, Measure CS-1 facilitates the implementation and expansion of the Urban Forest Management Plan and seeks to plant and maintain 4,500 net new trees by the year 2030. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in no impact related to degradation of forestry resources or conversion of forest land to non-forest uses, nor would there be a conflict with existing zoning or General Plan land use designations.

NO IMPACT
e. Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use?
See impact discussions above under Topics 2a through 2d. The CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in other changes to the existing environment which, due to their location or nature, would result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use. No impact would occur.

NO IMPACT
Cumulative Impacts
The cumulative projects scenario is total projected population growth for Santa Barbara (96,637 persons) in 2030. The City does not contain farmland or lands used for agricultural purposes.

Additionally, the City does not contain forest or timberland resources. Cumulative projects are not anticipated to contribute to cumulative forestry impacts with adherence to General Plan policies. In addition, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not involve land use or zoning changes that could result in cumulative impacts related to conversion or loss of farmland or forest land. Therefore, implementation of the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in no cumulative impact related to agricultural and forestry resources.

NO IMPACT
City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
42 3 Air Quality
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
Would the project:
a. Conflict with or obstruct implementation
of the applicable air quality plan? □ □ ■ □
b. Result in a cumulatively considerable net
increase of any criteria pollutant for
which the project region is nonattainment under an applicable federal or state ambient air quality standard? □ □ ■ □
c. Expose sensitive receptors to substantial
pollutant concentrations? □ □ ■ □
d. Result in other emissions (such as those
leading to odors) adversely affecting a
substantial number of people? □ □ ■ □
a. Would the project conflict with or obstruct implementation of the applicable air quality plan? The City of Santa Barbara is located in the South Central Coast Air Basin (SCCAB), which includes San Luis Obispo, Santa Barbara, and Ventura counties. The Santa Barbara County portion of the SCCAB is under the jurisdiction of the Santa Barbara County Air Pollution Control District (SBCAPCD).

Geographic features that influence Santa Barbara’s air quality include the Santa Barbara Channel (Pacific Ocean) to the south, and the east-west trending Santa Ynez Mountains to the north, with elevations up to 4,707 feet. The regional climate in the SCCAB is Mediterranean and is characterized by warm summers and mild winters with relatively dry weather. The annual precipitation is 22 inches on average, with most (95 percent) occurring during the rainy season, which generally spans October through April. The warmest month is August, and the coolest month is January. 3132
As the local air quality management agency, SBCAPCD is required to monitor air pollutant levels to ensure that State and federal air quality standards are met and, if they are not met, to develop strategies to meet the standards. Depending on whether or not the standards are met or exceeded, the South Central Coast Air Basin is classified as being in “attainment” or “nonattainment.” Under State law, air districts are required to prepare a plan for air quality improvement for pollutants for which the district is in non-attainment. The Santa Barbara County portion of SBCAPCD is in nonattainment for the California Ambient Air Quality Standards (CAAQS) for ozone standards and PM10 (particulate matter up to 10 microns in size).
33 31 Western Regional Climate Center. 2016. Recent Climate in the West. https://www.wrcc.dri.edu. Accessed October 2023. 32 Cal-Adapt. 2023. Local Climate Snapshot for Santa Barbara, California. Available online at: https://cal-adapt.org/tools/local-climatechange-snapshot. Accessed November 2023. 33 California Air Resources Board (CARB). 2022. Top 4 summary: Select Pollutant, Years, & Area. https://www.arb.ca.gov/adam/topfour/topfour1.php. Accessed October 2023.

Environmental Checklist
Air Quality
Draft Initial Study – Negative Declaration 43
Under state law, air districts are required to prepare a plan for air quality improvement for pollutants for which the district is in non-compliance. The 2001 Clean Air Plan (2002) was the first plan prepared by SBCAPCD and established specific planning requirements to maintain the state one-hour ozone standard. In 2006, CARB revised the CAAQS and added an 8-hour average to the ozone standard. Both components of the standard must now be met before CARB can designate an area to be in attainment. The current 2022 Ozone Plan was adopted by SBCAPCD in December 2022 and is the tenth update to the 2001 Clean Air Plan. The 2022 Ozone Plan addresses SBCAPCD’s progress toward attaining the federal and state ozone standard. As with prior updates, the 2022 update includes an evaluation of feasible reduction measures for stationary sources and considers numerous factors such as technology advancements, efficiency measures, cost-effectiveness, and the successful implementation of measures at other California air districts. All of the control measures that were found to be feasible in prior ozone plan updates have been implemented. 34 The evaluation of whether a project would conflict with or obstruct implementation of the applicable air quality plan is based on the project’s consistency with the land use and population forecasts that underlie the air pollutant emissions forecasts contained in the plan. Therefore, consistency with the 2022 Ozone Plan is based on whether the population growth accommodated by the CAP Update was accounted for in SBCAG’s Regional Growth Forecast. In addition, in order to be consistent with the 2022 Ozone Plan, projects involving earthmoving activities must implement SBCAPCD’s standard dust control measures.

Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would have no impact on population growth associated with the CAP Update and would not result in construction or operational impacts. Additionally, the CAP Update would not involve land use or zoning changes but would rather promote infrastructure development and redevelopment. Implementation of proposed measures would be beneficial by helping Santa Barbara meet applicable air quality plan goals and generally reducing sensitive receptor exposure to pollutant concentrations. Although the purpose and intended effect of the CAP Update is to reduce GHG emissions generated in the City to help reduce the effects of climate change, many of its measures and supporting actions would also reduce criteria pollutant (i.e., air quality) emissions.

The energy- and transportation-related measures mentioned in Figure 3 would reduce air quality emissions as well as GHG emissions. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would have a less-than-significant impact related to a conflict with or obstruction of the applicable air quality plan.

LESS-THAN-SIGNIFICANT IMPACT
b. Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in construction or operational impacts related to an increase of criteria pollutants. The CAP Update would not involve land use or zoning changes but would instead promote infrastructure development and redevelopment. As a policy document, the CAP Update 34 Santa Barbara County Air Pollution Control District. 2022. Ozone Plan https://www.ourair.org/wp-content/uploads/2022-OzonePlan.pdf. Accessed October 2023.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
44 would not result in impacts related to criteria pollutants. However, implementation of the following measures may promote infrastructure development and redevelopment.

Measure BE-1 promotes the decarbonization of 50% of municipal buildings, Measure BE-4 promotes the expansion of the existing Natural Gas Prohibition Ordinance for new construction, Measure BE-5 promotes reducing residential natural gas consumption, and Measure B-6 promotes reducing commercial natural gas consumption. Measure T-1 involves the development and implementation of the Municipal Transportation Demand Management (TDM) Program, which aims to increase freeof-charge access to public transit and the electric bike share program in the City. Additionally, the TDM Program aims to provide cash incentives for city-employees to bike, walk, or carpool to work while Measure T-3 aims to implement programs to enhance access to safe active transportation.

Measure T-4 encourages the implementation of programs to increase public transportation mode share via public transit improvements, education, increased access, and creating pilot projects.

Measure T-7 aims to accelerate zero-emission commercial vehicle use and adoption to 26% by 2030 and Measure T-8 aims to electrify or decarbonize 6% of Off-Road equipment by 2030. Furthermore, Measure CS-1 facilitates the expansion of the City’s Urban Forest Management Plan and requires planting and maintaining 4,500 net new trees by the year 2030. Construction-related air quality impacts are generally associated with fugitive dust (PM10 and PM2.5) and exhaust emissions from heavy construction vehicles and soil-hauling trucks, in addition to Reactive Organic Gas (ROG) that would be released during architectural coatings drying. However, future projects or plans would be reviewed for consistency with SBCAPCD air quality regulations and other applicable local, State, and Federal regulations. Once project details and locations are known, they would be subject to environmental review under CEQA, and individual impact analyses will identify required plan or project-specific mitigation measures where applicable. Additionally, the projects included in the measures and actions would not typically warrant substantial construction emissions due to their minimal scale, keeping their emissions below construction thresholds for review under CEQA. Such projects might include implementing building retrofits to increase building electrification, increasing bike lane access, and building further walking paths to encourage alternative transportation. Thus, construction associated with implementation of the CAP Update would result in a less-thansignificant impact related to net increase of criteria pollutants.

With respect to operational emissions, many measures would have the secondary benefit of reducing criteria pollutant emissions. Measures included in the CAP Update aim to increase citywide renewable energy use, promote electric vehicles, reduce building natural gas use, reduce on-road gasoline fuel use, and reduce vehicle miles traveled. Implementation of such measures would be beneficial by helping Santa Barbara meet applicable air quality plan goals. In addition, projects implemented in support of the CAP Update would be reviewed for consistency with the General Plan, and other applicable regulatory land use actions, and would be subject to any required environmental assessment that would be completed prior to approval of any project. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant impact related to criteria pollutant emissions.

LESS-THAN-SIGNIFICANT IMPACT
c. Would the project expose sensitive receptors to substantial pollutant concentrations? Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in construction or operational impacts related to exposure of sensitive receptors to substantial pollutant concentrations. Implementation of the following measures may promote infrastructure development and redevelopment.

Environmental Checklist
Air Quality
Draft Initial Study – Negative Declaration 45
Measure BE-1 promotes the decarbonization of 50% of municipal buildings, Measure BE-4 promotes the expansion of the existing Natural Gas Prohibition Ordinance for new construction, Measure BE-5 promotes reducing residential natural gas consumption, and Measure B-6 promotes reducing commercial natural gas consumption. Measure T-1 involves the development and implementation of the Municipal Transportation Demand Management (TDM) Program, which aims to increase freeof-charge access to public transit and the electric bike share program in the City. Measure T-4 encourages the implementation of programs to increase public transportation mode share via public transit improvements, education, increased access, and creating pilot projects. Measure T-7 aims to accelerate zero-emission commercial vehicle use and adoption to 26% by 2030 and Measure T-8 aims to electrify or decarbonize 6% of Off-Road equipment by 2030. Furthermore, Measure CS-1 facilitates the expansion of the City’s Urban Forest Management Plan and requires planting and maintaining 4,500 net new trees by the year 2030.

Construction-related air quality impacts are generally associated with fugitive dust (PM10 and PM2.5) and exhaust emissions from heavy construction vehicles and soil hauling trucks, in addition to ROG that would be released during the drying phase upon application of architectural coatings. While the CAP Update could result in some construction-related impacts from toxic air contaminants and exposure to sensitive receptors, projects included in the CAP Update would be reviewed for consistency to comply with SBCAPCD air quality regulations and other applicable local, State, and federal regulations once project details and locations are known because future plans or projects would be subject to environmental review under CEQA, and individual impact analyses will identify required plan- or project-specific mitigation measures where applicable. If the project is exempt from these regulations, it would not need to undergo this review. Thus, the construction associated with implementation of the CAP Update would not result in substantial emissions of toxic air contaminants and exposure to sensitive receptors. No operational toxic air contaminant emissions are anticipated with implementation of the CAP Update. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would have a lessthan-significant impact related to exposure of sensitive receptors to toxic air contaminants.

LESS-THAN-SIGNIFICANT IMPACT
d. Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
The CARB 2005 Air Quality Land Use Handbook: A Community Health Perspective provides guidance for odor standards by identifying land uses associated with odor complaints, which include: sewage treatment plants, landfills, recycling facilities, waste transfer stations, petroleum refineries, biomass operations, auto body shops, coating operations, fiberglass manufacturing, foundries, rendering plants, and livestock operations.35 Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not have construction or operational impacts related to odors. Measure W-1 aims to increase municipal procurement of recovered organic waste products and promotes participation in recycling and organic waste programs. As such, the CAP Update could result in minor odors related to compost. However, green waste collection bins and compost application are not identified on the list of “Sources of Odor Complaints” (Table 1-4) as provided in the CARB Air Quality Land Use Handbook and would not be anticipated to result in other emissions, such as those leading to odors, adversely affecting a 35 California Air Resources Control Board (CARB). 2005. Air Quality and Land Use Handbook: A Community Health Perspective. https://ww3.arb.ca.gov/ch/handbook.pdf. Accessed October 2023.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
46 substantial number of people. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not facilitate development that could create adverse odors, and there would be a less-than-significant impact related to odors exposure.

LESS-THAN-SIGNIFICANT IMPACT
Cumulative Impacts
The cumulative projects scenario is total projected population growth for Santa Barbara (96,637 persons) in 2030. Implementation of the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would have a less than significant contribution related to potential cumulative air quality impacts within the air basin and on sensitive receptors within the City of Santa Barbara, given that the CAP Update would result in Citywide reduction of GHG emissions, energy use, single-occupancy vehicle travel, water use, and waste generation. As such, implementation of the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in adverse impacts related to contribution of criteria pollutants to the air basin, exposure of sensitive receptors to toxic air contaminants, or odors. Therefore, implementation of the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant cumulative impact related to air quality.

LESS-THAN-SIGNIFICANT IMPACT
Environmental Checklist
Air Quality
Draft Initial Study – Negative Declaration 47
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City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
48 4 Biological Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
Would the project:
a. Have a substantial adverse effect, either
directly or through habitat modifications,
on any species identified as a candidate,
sensitive, or special status species in local
or regional plans, policies, or regulations, or
by the California Department of Fish and
Wildlife or U.S. Fish and Wildlife Service? □ □ ■ □
b. Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, or regulations, or by the
California Department of Fish and Wildlife
or U.S. Fish and Wildlife Service? □ □ ■ □
c. Have a substantial adverse effect on state
or federally protected wetlands (including,
but not limited to, marsh, vernal pool,
coastal, etc.) through direct removal, filling,
hydrological interruption, or other means? □ □ ■ □
d. 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? □ □ ■ □
e. Conflict with any local policies or
ordinances protecting biological resources,
such as a tree preservation policy or
ordinance? □ □ ■ □
f. Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural
Community Conservation Plan, or other
approved local, regional, or state habitat
conservation plan? □ □ □ ■
Environmental Checklist
Biological Resources
Draft Initial Study – Negative Declaration 49
a. Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
Santa Barbara is a primarily urbanized community with creek corridors, beaches, parks and recreational and open spaces incorporated throughout the City including riparian habitats, wetlands, and coastal habitats. The City’s Municipal Code Titles 14, 15, 22,28, and 30, the Local Coastal Program, and the General Plan Environmental Resources Element incorporate goals, policies, and measures to protect biological resources, such as trees, plant habitats, and wildlife.

Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not have construction or operational impacts related to habitat modification. The CAP Update would not involve land use or zoning changes but would instead promote infrastructure development and redevelopment. As a policy document, the CAP Update would not directly result in impacts related to wildlife species identified as candidate, sensitive, or special status. However, implementation of the following CAP Update measures may promote infrastructure development and redevelopment and may result in impacts to species through habitat modification for purposes of infrastructure installation.

Measure BE-1 promotes the decarbonization of 50% of municipal buildings via retrofitting of existing infrastructure. As retrofitting would occur within the building, it would not impact species via habitat modification. Measure BE-3 promotes increasing municipally owned distributed renewable energy generation throughout the City, including sourcing new space for energy storage projects, which could impact habitat via infrastructure installation. Measure B-6 promotes reducing commercial natural gas consumption and electrifying existing commercial and mixed-use buildings, which could involve building retrofits within the building envelope and would not impact nearby habitat. Measure T-1 involves the development and implementation of the Municipal Transportation Demand Management (TDM) Program, which aims to increase free-of-charge access to public transit and the electric bike share program in the City. Additionally, the TDM Program aims to provide cash incentives for city-employees to bike, walk, or carpool to work while Measure T-3 aims to implement programs to enhance access to safe active transportation. These measures involve building enhanced walking and biking infrastructure throughout the city, which could impact sensitive species via habitat modification and infrastructure installation.

Future related projects would be required to undergo environmental review, including assessment and mitigation incorporation once project details and locations are known. The measures included in the CAP Update would not conflict with the Municipal Code or goals/policies of the General Plan Environmental Resources Element but rather would be consistent with and promote those plans. As such, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis itself would not have a substantial adverse effect on special-status wildlife species either directly through individual take or indirectly through species habitat modification.

Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant impact related to special-status wildlife species.

LESS-THAN-SIGNIFICANT IMPACT
City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
50 b. Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? c. Would the project have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not have construction or operational impacts related to riparian or other special habitats. The CAP Update would not involve land use or zoning changes but would instead promote infrastructure development and redevelopment. As a policy document, the CAP Update could result in impacts related to habitat whether riparian, wetland, or other sensitive natural community.

According to the General Plan Sustainable Resource Use Implementation Measures, new buildings and other elements of the built environment must be designed to enhance the wildlife corridor network, preserve existing trees within identified wildlife corridors, install and maintain appropriate native landscaping, minimize disturbance to existing biological resources, increase riparian habitat within the City, site new development outside of riparian woodlands to the extent feasible, and comply with creek setback standards.36
Measure BE-1 promotes the decarbonization of 50% of municipal buildings via retrofitting of existing infrastructure. As retrofitting would occur within the building, it would not impact species via habitat modification. Measure BE-3 promotes increasing municipally owned distributed renewable energy generation throughout the City, including sourcing new space for energy storage projects, which could impact habitat via infrastructure installation. Measure B-6 promotes reducing commercial natural gas consumption and electrifying existing commercial and mixed-use buildings, which could involve building retrofits within the building envelope and would not impact nearby habitat. Measure T-1 involves the development and implementation of the Municipal Transportation Demand Management (TDM) Program, which aims to increase free-of-charge access to public transit and the electric bike share program in the City. Additionally, the TDM Program aims to provide cash incentives for city-employees to bike, walk, or carpool to work while Measure T-3 aims to implement programs to enhance access to safe active transportation. These measures involve building enhanced walking and biking infrastructure throughout the city, which could impact sensitive species via habitat modification and infrastructure installation.

Future related projects would be required to undergo environmental review, including assessment and mitigation incorporation once project details and locations are known. Projects would be reviewed for consistency with applicable local, regional, and State regulations once project details and locations are known. These measures and actions would not conflict with the Municipal Code or objectives and policies of the General Plan but would rather be consistent with and promote those plans. As such, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not have a substantial adverse effect on riparian habitat or sensitive natural community, such as wetlands. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would have a less-than-significant impact related to sensitive natural plant communities.

LESS-THAN-SIGNIFICANT IMPACT
36 Santa Barbara, City of. 2011. General Plan. Environmental Resources Element. https://santabarbaraca.gov/sites/default/files/documents/General%20Plan/General%20Plan/Environmental%20Resources%20Element% 20%28includes%20Noise%2A%20and%20Conservation%2A%29.pdf. Accessed October 2023.

Environmental Checklist
Biological Resources
Draft Initial Study – Negative Declaration 51
d. 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? Migration corridors in the City exist primarily within the riparian corridors which provide nearly continuous pathways of native and natural vegetation used by wildlife species to move between open foothill lands and larger urban open spaces. Upland migration corridors such as oak woodland, eucalyptus groves, and coastal sage scrub provide migratory bird habitat in the City. Mission Creek, Sycamore Creek, and Arroyo Burro provide spawning and rearing habitat for southern steelhead, and habitat for tidewater goby.37 These corridors can be bordered on either side by urban land uses which could act as potential barriers to movement. Potentially significant effects on wildlife movement would occur if temporary disturbance during construction or permanent new residential development would result in the fragmentation or degradation of wildlife corridors or nursery sites.

Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not have construction or operational impacts related to interference with species movement. The CAP Update would not involve land use or zoning changes but would instead promote infrastructure development and redevelopment. As a policy document, the CAP Update would not result in impacts related to interference with species movement. However, implementation of the following CAP Update measures may promote infrastructure development and redevelopment.

Measure BE-1 promotes the decarbonization of 50% of municipal buildings, Measure BE-4 promotes the expansion of the existing Natural Gas Prohibition Ordinance for new construction, Measure BE-5 promotes reducing residential natural gas consumption, and Measure B-6 promotes reducing commercial natural gas consumption. Measure T-1 involves the development and implementation of the Municipal Transportation Demand Management (TDM) Program, which aims to increase freeof-charge access to public transit and the electric bike share program in the City. Additionally, the TDM Program aims to provide cash incentives for city-employees to bike, walk, or carpool to work while Measure T-3 aims to implement programs to enhance access to safe active transportation.

Measure T-4 encourages the implementation of programs to increase public transportation mode share via public transit improvements, education, increased access, and creating pilot projects.

Measure T-7 aims to accelerate zero-emission commercial vehicle use and adoption to 26% by 2030 and Measure T-8 aims to electrify or decarbonize 6% of Off-Road equipment by 2030. Furthermore, Measure CS-1 facilitates the expansion of the City’s Urban Forest Management Plan and requires planting and maintaining 4,500 net new trees by the year 2030.

Future related projects would be required to undergo environmental review, including assessment and mitigation incorporation once project details and locations are known. These CAP Update measures and supporting actions do not conflict with the Municipal Code or objectives and policies of the General Plan and instead are consistent with and promote those plans. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant impact related to interference with species movement.

LESS-THAN-SIGNIFICANT IMPACT
37 Santa Barbara, City of. 2010. Program Environmental impact Report for the Plan Santa Barbara General Plan Update. https://santabarbaraca.gov/sites/default/files/documents/General%20Plan/Certified%20Final%20Program%20Environmental%20Impact %20Report/Volume%20I.pdf. Accessed October 2023.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
52 e. Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Santa Barbara is a primarily urbanized community with parks and recreational and open spaces incorporated throughout the City including riparian habitats, wetlands, and coastal habitats. The City’s Municipal Code Titles 14, 15, 22,28, and 30, the Local Coastal Program, and the General Plan Environmental Resources Element incorporate goals, policies, and measures to protect biological resources, such as trees, plant habitats, and wildlife. Chapter 15.20 of the City’s Municipal Code details the Street Tree Ordinance, including regulations for planting, conformity with the Master Street Tree Plan, maintenance, permitting, removal, and more. 38 Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not have construction or operational impacts related to biological resources. The CAP Update does not involve land use or zoning changes but would rather promote infrastructure development and redevelopment. The purpose and intended effect of the CAP Update is to reduce GHG emissions generated within the Santa Barbara community, including related to City municipal operations, to help reduce the effects of climate change. Implementation of proposed measures and actions would be beneficial by helping Santa Barbara meet applicable local policies and ordinances for protecting natural and biological resources. The CAP Update would not conflict with or obstruct implementation of the applicable policies for preserving biological resources and would not affect the City’s ability to attain goals and policies that protect biological resources. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant impact related consistency with local biological resources protection policies.

LESS-THAN-SIGNIFICANT IMPACT
f. Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
The City of Santa Barbara is not located within any approved local, regional, or State Habitat Conservation Plan or Natural Community Conservation Plan.39 Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not conflict with any applicable conservation plan.

NO IMPACT
Cumulative Impacts
The cumulative projects scenario is total projected population growth for Santa Barbara (96,637 persons) in 2030. Implementation of cumulative projects could result in impacts to biological resources during infrastructure and building construction. The CAP Update would promote infrastructure development and redevelopment. However, infrastructure development or redevelopment resulting from implementation of the CAP Update would be required to comply with applicable General Plan policies and State and federal regulatory requirements regarding avoidance of special wildlife species and habitat. Furthermore, as a guidance document, the Master 38 Santa Barbara, City of. Municipal Code Title 15 Recreation, Beaches, and Parks. https://library.qcode.us/lib/santa_barbara_ca/pub/municipal_code/item/title_15-chapter_15_20?view=all 39 California Department of Fish and Wildlife (CDFW). 2022. California Natural Diversity Database. https://apps.wildlife.ca.gov/bios/?tool=cnddbQuick. Accessed October 2023.

Environmental Checklist
Biological Resources
Draft Initial Study – Negative Declaration 53
Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in cumulative impacts. Therefore, implementation of the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant cumulative impact related to biological resources.

LESS-THAN-SIGNIFICANT IMPACT
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City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
54 5 Cultural Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
Would the project:
a. Cause a substantial adverse change in
the significance of a historical resource
pursuant to §15064.5? □ □ ■ □
b. Cause a substantial adverse change in
the significance of an archaeological
resource pursuant to §15064.5? □ □ ■ □
c. Disturb any human remains, including
those interred outside of formal
cemeteries? □ □ ■ □
a. Would the project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
The City has put forth preservation regulations through the Historic Resources Element of the General Plan outlining overarching goals and policies aimed toward preserving and protecting Santa Barbara’s historic, cultural, and tribal cultural resources.40 Additionally, Santa Barbara has 17 properties listed under the National Register of Historic Places, including Andalucia Building, Santa Barbara Mission, Santa Barbara Presidio, and Virgina Hotel.41 The City’s Historic Preservation Ordinance and Historic Resources Element contain a regulatory framework that provide protections against the demolition of City-designated landmarks and structures of merit and establish procedures for proposed development that has the potential to affect designated historic resources. The City Architectural Historian maintains and updates the Historic Resources Inventory, which lists qualifying historic structures over 50 years old that are not currently designated as Landmarks, Structures of Merit, or contributing to a Historic District Overlay Zone. Any structure over 50 years old must be evaluated prior to any addition, alteration, or demolition to determine if the structure qualifies as a historic resource as per CEQA requirements.

Pursuant to the City’s Municipal Code, these resources are also defined as historic resources and subject to the same local regulations as designated historical resources. Projects that would alter these eligible historical resources, as determined by the City Architectural Historian and/or Historic Landmarks Commission, would be subject to project-specific environmental review whereby adverse effects to historical resources would be minimized. 40 Santa Barbara, City of. 2012. General Plan Historic Resources Element. https://santabarbaraca.gov/sites/default/files/documents/General%20Plan/General%20Plan/Historic%20Resources%20Element.pdf.

Accessed October 2023.
41National Parks Service. National Register Database and Research. https://www.nps.gov/subjects/nationalregister/databaseresearch.htm Accessed October 2023.

Environmental Checklist
Cultural Resources
Draft Initial Study – Negative Declaration 55
Under existing regulations, individual projects are reviewed by the City for consistency with the Historic Preservation Ordinance. The Historic Landmarks Commission reviews projects that may have a significant effect on character-defining features of a historic resource.

Existing City policies and regulatory processes provide an extensive framework for preservation of the integrity of important historic resources and historic and landmark districts. Application of Municipal Code provisions would minimize potential impacts on the character of the City’s historic resources and districts. The City’s MEA Guidelines for Archaeological Resources establish procedures for the evaluation and protection of archaeological resources and sites, consistent with the CEQA Statute and Guidelines. In addition, Municipal Code Chapter 22.12 provides standard conditions in the event of unanticipated discovery of archaeological resources. Through imposition of standard conditions, survey requirements, and procedures for unanticipated discovery, the City ensures impacts to archaeological resources are minimized for discretionary development applications.

Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in construction or operational impacts related to historical resources. The CAP Update would not involve land use or zoning changes. Rather the CAP Update would promote infrastructure development and redevelopment.

The CAP Update would not involve land use or zoning changes but would promote building energy retrofits as well as infrastructure development and redevelopment that would be complimentary to existing development. Projects in Santa Barbara would be required to comply with the Historic Preservation Ordinance and Historic Resources Element.

Implementation of the following measures may promote infrastructure development and redevelopment, which could potentially impact known and unknown historical resources within the city. Measure BE-1 promotes the decarbonization of 50% of municipal buildings, Measure BE-4 promotes the expansion of the existing Natural Gas Prohibition Ordinance for new construction, Measure BE-5 promotes reducing residential natural gas consumption, and Measure B-6 promotes reducing commercial natural gas consumption. These building measures regulate new and existing development, such as requiring all-electric buildings or building retrofits. Typically building electrification is completed in a manner that doesn’t impact the building’s character that qualifies it as a historical resource. Measure T-1 involves the development and implementation of the Municipal Transportation Demand Management (TDM) Program, which aims to increase free-ofcharge access to public transit and the electric bike share program in the City. Additionally, the TDM Program aims to provide cash incentives for city-employees to bike, walk, or carpool to work while Measure T-3 aims to implement programs to enhance access to safe active transportation. Measure T-4 encourages the implementation of programs to increase public transportation mode share via public transit improvements, education, increased access, and creating pilot projects. These alternative transportation measures involve the addition of alternative transportation routes, bike lanes, and pedestrian and cyclist safety measures. The construction of alternative transportation infrastructure may occur at or near a historical site.

The physical changes these upgrades and additions would entail are dependent on the year of building construction and location of electrical and service panels and plumbing for connection of condensate drains, which in some cases may include modifications to the interior and/or exterior of buildings for wiring and panel replacement and minor excavation for connection of drainage to sewer systems. However, it is anticipated that retrofit activities would avoid alterations to the historic materials and distinguishing character (e.g., overall shape of the building, its materials, City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
56 craftsmanship, decorative details, interior spaces and features, and aspects of its site and environment) of identified historic resources and, if warranted, be reviewed by the Historic Landmarks Commission. As such, implementation of the CAP Update would not conflict with or obstruct the City’s ability to comply with applicable historical resources preservation policies.

Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant impact related to historical resources.

LESS-THAN-SIGNIFICANT IMPACT
b. Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
The Santa Barbara region was favorable to Native American settlement and the City contains known archaeological sites and areas of archaeological sensitivity. There is the potential to encounter previously unidentified archaeological resources on sites that may be developed with residential uses under the CAP Update. While the City is largely developed with few vacant parcels, undeveloped properties have a higher probability of containing previously unidentified archaeological resources given the probable lack of previous ground-disturbing activities on these properties. However, ground disturbance into native (previously undisturbed) soils on any development site could encounter previously undiscovered prehistoric or historic-period resources.

The potential exists for archaeological resources to occur below the ground surface throughout Santa Barbara, which may be disturbed and damaged by grading and excavation activities associated with new housing development.

The City’s MEA Guidelines for Archaeological Resources establish procedures for the evaluation and protection of archaeological resources and sites, consistent with the CEQA Statute and Guidelines.

In addition, Municipal Code Chapter 22.12 provides standard conditions in the event of unanticipated discovery of archaeological resources. Through imposition of standard conditions, survey requirements, and procedures for unanticipated discovery, the City ensures impacts to archaeological resources are minimized for discretionary development applications.

Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not have construction or operational impacts related to archaeological resources.

The CAP Update would not involve land use or zoning changes but would promote building energy retrofits as well as infrastructure development and redevelopment.

Measure BE-1 promotes the decarbonization of 50% of municipal buildings, Measure BE-4 promotes the expansion of the existing Natural Gas Prohibition Ordinance for new construction, Measure BE-5 promotes reducing residential natural gas consumption, and Measure B-6 promotes reducing commercial natural gas consumption. These building measures promote the development of new infrastructure, such as building retrofits and increasing the electric grid in the city. Thus, the development involved in these measures could impact potential historical resources within the city.

Measure T-1 involves the development and implementation of the Municipal Transportation Demand Management (TDM) Program, which aims to increase free-of-charge access to public transit and the electric bike share program in the City. Additionally, the TDM Program aims to provide cash incentives for city-employees to bike, walk, or carpool to work while Measure T-3 aims to implement programs to enhance access to safe active transportation. Measure T-4 encourages the implementation of programs to increase public transportation mode share via public transit improvements, education, increased access, and creating pilot projects. These alternative transportation measures involve the addition of alternative transportation routes and bike lanes.

Environmental Checklist
Cultural Resources
Draft Initial Study – Negative Declaration 57
The construction involved in these projects may interfere with potential historical sites. Measure T-7 aims to accelerate zero-emission commercial vehicle use and adoption to 26% by 2030 and Measure T-8 aims to electrify or decarbonize 6% of Off-Road equipment by 2030. Furthermore, Measure CS-1 facilitates the expansion of the City’s Urban Forest Management Plan and requires planting and maintaining 4,500 net new trees by the year 2030.

As a policy document, the CAP Update would not directly result in impacts related to archaeological resources. Implementation of the CAP Update measures and supporting actions may promote infrastructure development and redevelopment that could result in an impact on these resources during construction. Future related projects would be required to undergo environmental review, including assessment and mitigation incorporation once project details and locations are known.

The CAP Update would not conflict with or obstruct the applicable policies for preserving archeological resources and would not affect the City’s ability to attain goals and policies that protect archeological resources. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant impact related to archaeological resources.

LESS-THAN-SIGNIFICANT IMPACT
c. Would the project disturb any human remains, including those interred outside of formal cemeteries?
Human burials outside of formal cemeteries can occur in prehistoric archaeological contexts.

Excavations during construction activities could have the potential to disturb these resources, which could include Native American burial sites. Although it is unlikely that human remains are present, development forecasted in accordance with the CAP Update has at least the possibility of uncovering previously unidentified human remains.

Human burials, in addition to being potential archaeological resources, have specific provisions for treatment in PRC Section 5097. The California Health and Safety Code (Section 7050.5, 7051, and 7054) has specific provisions for the protection of human burial remains. Existing regulations address the illegality of interfering with human burial remains, and protect them from disturbance, vandalism, or destruction. They also include established procedures to be implemented if Native American skeletal remains are discovered. PRC Section 5097.98 also addresses the disposition of Native American burials, protects such remains, and established the NAHC to resolve any related disputes.

All development projects are subject to State of California Health and Safety Code Section 7050.5 which states that, if human remains are unearthed, no further disturbance can occur until the County Coroner has made the necessary findings as to the origin and disposition of the remains pursuant to PRC Section 5097.98. If the remains are determined to be of Native American descent, the County Coroner has 24 hours to notify the NAHC, which will determine and notify a most likely descendant (MLD). The MLD shall complete the inspection of the site and make recommendations to the landowner within 48 hours of being granted access.

Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not have construction or operational impacts related to human remains. The CAP Update would not involve land use or zoning changes. Rather the CAP Update would promote infrastructure development and redevelopment that could have an impact on these resources during construction. Therefore, development forecasted in accordance with the CAP Update and City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
58 Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would have less-than-significant impacts on human remains.

LESS-THAN-SIGNIFICANT IMPACT
Cumulative Impacts
The cumulative projects scenario is total projected population growth for Santa Barbara (96,637 persons) in 2030. There is the possibility of encountering buried archaeological deposits and human remains throughout Santa Barbara. Implementation of the cumulative projects would include infrastructure and building development that could have an impact on cultural resources during construction. Impacts to historic and archaeological resources are generally site-specific.

Accordingly, as required under applicable laws and regulations, potential impacts associated with cumulative developments would be addressed on a case-by-case basis. No known cultural resources would be removed, modified, or otherwise affected by the implementation of the CAP Update. In addition, future projects in Santa Barbara, including those associated with implementation of the CAP Update, would be required to comply with the Historic Preservation Ordinance and Historic Resources Element, with the main purpose of recognizing, preserving, and protecting historic resources in the interest of the health, prosperity, social and cultural enrichment, and general welfare of the people. Furthermore, as a guidance document, the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in cumulative impacts. Therefore, implementation of the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant cumulative impact related to cultural resources.

LESS-THAN-SIGNIFICANT IMPACT
Environmental Checklist
Cultural Resources
Draft Initial Study – Negative Declaration 59
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City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
60 Environmental Checklist
Energy
Draft Initial Study – Negative Declaration 61
6 Energy
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
Would the project:
a. Result in a potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption
of energy resources, during project
construction or operation? □ □ ■ □
b. Conflict with or obstruct a state or local
plan for renewable energy or energy
efficiency? □ □ ■ □
a. Would the project result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
California is one of the lowest per-capita energy users in the United States, ranked 48th in the nation, due to its energy efficiency programs and mild climate.42 California consumed 285,488 gigawatt-hours (GWh) of electricity and 2,137,920 cubic feet of natural gas in 2018. 43 ,44,45 The single
largest end-use sector for energy consumption in California is transportation (39.1 percent), followed by industry (23.5 percent), commercial (18.3 percent), and residential (18.3 percent).46 Adopted in 2018, SB 100 accelerates the State’s Renewable Portfolio Standards Program, codified in the Public Utilities Act, by requiring electricity providers to increase procurement from eligible renewable energy resources to 33 percent of total retail sales by 2020, 60 percent by 2030, and 100 percent by 2045.

The City of Santa Barbara has demonstrated its commitment to energy efficiency and renewable energy. Southern California Edison (SCE) delivers electricity to Santa Barbara, procured by Santa Barbara Clean Energy. At a minimum, energy procured through Santa Barbara Clean Energy provides 50 percent carbon-free energy, and buildings are automatically opted-in to the Santa Barbara Clean Energy system.
47 As such, development forecasted in accordance with the CAP Update would utilize a minimum of 50 percent carbon-free energy, which is more carbon-free energy than what is currently collectively served by California investor-owned utilities (36 percent) and assists in 42United States Energy Information Administration (USEIA). 2018. California Profile Overview. <https://www.eia.gov/state/?sid=CA.> Accessed October 2023.
43 California Energy Commission (CEC). 2021. 2018 Total System Electric Generation. https://www.energy.ca.gov/data-reports/energyalmanac/california-electricity-data/2019-total-system-electric-generation/2018. Accessed October 2023. 44 California Energy Commission (CEC). 2021. Environmental Health and Equity Impacts from Climate Change and Mitigation Policies in California: A Review of the Literature. Accessed October 2023. 45USEIA. 2018. Natural Gas Consumption by End Use. https://www.eia.gov/dnav/ng/ng_cons_sum_dcu_SCA_a.htm . Accessed October 2023.
46USEIA. 2018. California Profile Overview. https://www.eia.gov/state/?sid=CA . Accessed October 2023. 47 Santa Barbara Clean Energy. 2022. Services and Incentives. https://www.sbcleanenergy.com/services-incentives. Accessed October 2023.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
62 reaching the Renewable Portfolio Standards goal of 60 percent renewable energy retail sales by 2030.48 The City has also completed a total (i.e., community and municipal) GHG emissions inventory for 2019, which is summarized in Table 1. The largest sectors of GHG emissions are related to energy and transportation, followed by solid waste and water. According to the California Energy Commission (CEC), Santa Barbara County consumed approximately 2,804 GWh in 2022. 49 Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in construction or operational impacts related to wasteful consumption of energy resources. The CAP Update is a policy document containing climate action measures and supporting actions to reduce Santa Barbara GHG emissions. The CAP Update would not involve land use or zoning changes but would promote infrastructure development and redevelopment.

Furthermore, the purpose and intended effect of the CAP Update is to reduce GHG emissions generated in the City to help reduce the effects of climate change, including those emissions generated by energy demand and supply. The CAP Update encourages electrification, use of renewable energy, and energy efficiency in existing residential and commercial building stock as well as proposed new residential and commercial buildings.

Measures BE-1 through BE-7 propose the expansion of decarbonization and electrification efforts for municipal buildings and construction as well as increasing the impact of Santa Barbara Clean Energy (SBCE) throughout the City. In addition, Measure T-8 focuses on electrifying Off-Road Equipment used in construction and other maintenance to ensure compliance with Assembly Bill 1346. As such, the CAP Update would not result in the use of non-renewable resources in a wasteful or inefficient manner. Therefore, the CAP Update would result in a less-than-significant impact related to the wasteful, inefficient, or unnecessary consumption of energy. Rather, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would assist in reducing use of non-renewable energy resources.

LESS-THAN-SIGNIFICANT IMPACT
b. Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
New development forecasted in accordance with the CAP Update would be subject to the energy conservation requirements of the California Energy Code (Title 24, Part 6 of the California Code of Regulations, California’s Energy Efficiency Standards for Residential and Nonresidential Buildings) and the California Green Building Standards Code (Title 24, Part 11 of the California Code of Regulations). Thus, the CAP Update would not conflict with adopted renewable energy or energy conservation plans. The Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in construction or operational impacts related to consistency with a State or local renewable energy plan. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant impact related to consistency with State and local renewable energy and energy efficiency plans.

Rather, the CAP Update would be consistent with State and local plans for renewable energy and energy efficiency.
48 California Public Utilities Commission. 2022. CCA Regulatory Information – List of Registered CCA’s – Community Choice Aggregators. https://www.cpuc.ca.gov/consumer-support/consumer-programs-and-services/electrical-energy-and-energy-efficiency/communitychoice-aggregation-and-direct-access-/cca-regulatory-information. Accessed October 2023. 49 California Energy Commission. 2016. Electricity Consumption by County. <http://ecdms.energy.ca.gov/elecbycounty.aspx>. Accessed October 2023.

Environmental Checklist
Energy
Draft Initial Study – Negative Declaration 63
Thus, the CAP Update would revise but would not conflict with adopted renewable energy or energy conservation plans. Therefore, the CAP Update would result in a less-than-significant impact related to consistency with State and local renewable energy and energy efficiency plans. Rather, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would be consistent with State and local plans for renewable energy and energy efficiency.

LESS-THAN-SIGNIFICANT IMPACT
Cumulative Impacts
The cumulative projects scenario is total projected population growth for Santa Barbara (96,637 persons) in 2030. Implementation of the CAP Update would result in reducing use of non-renewable energy resources across the community and in particular with remodels and new construction. As such, construction of cumulative projects within the City could result in temporary energy consumption impacts. However, the energy used would not be wasteful and would comply with all applicable requirements. Furthermore, as a guidance document, the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would not result in cumulative impacts. Therefore, implementation of the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss and GHG Emission Thresholds would result in a less-than-significant cumulative impact related to energy.

LESS-THAN-SIGNIFICANT IMPACT
City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
64 This page intentionally left blank.

Environmental Checklist
Geology and Soils
Draft Initial Study – Negative Declaration 65
7 Geology and Soils
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
Would the project:
a. Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving:
▪ Rupture of a known earthquake fault,
as delineated on the most recent
Alquist-Priolo Earthquake Fault
Zoning Map issued by the State
Geologist for the area or based on
other substantial evidence of a
known fault? □ □ ■ □
▪ Strong seismic ground shaking? □ □ ■ □
▪ Seismic-related ground failure,
including liquefaction? □ □ ■ □
▪ Landslides? □ □ ■ □
b. Result in substantial soil erosion or the
loss of topsoil? □ □ ■ □
c. Be located on a geologic unit or soil that
is unstable, or that would become
unstable as a result of the project, and
potentially result in on- or off-site
landslide, lateral spreading, subsidence,
liquefaction, or collapse? □ □ ■ □
d. Be located on expansive soil, as defined
in Table 1-B of the Uniform Building Code
(1994), creating substantial direct or
indirect risks to life or property? □ □ ■ □
e. Have soils incapable of adequately
supporting the use of septic tanks or
alternative wastewater disposal systems
where sewers are not available for the
disposal of wastewater? □ □ □ ■
f. Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature? □ □ ■ □
City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
66 a. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
▪ rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault;
▪ strong seismic ground shaking;
▪ seismic-related ground failure, including liquefaction; or ▪ landslides?
The City of Santa Barbara, as with the majority of the state of California, is susceptible to seismic activity. Established in the Alquist-Priolo Earthquake Fault Zoning Act, Alquist-Priolo earthquake fault zones are regulatory zones compiled by the California Geological Survey which designate the surface traces of active faults in California.50 For the purposes of the Alquist-Priolo Earthquake Fault Zoning Act, an active fault is defined as a fault that has ruptured in the past 11,000 years.51 There are no Alquist-Priolo earthquake fault zones that partially or fully intersect the City. 52 The nearest
Alquist-Priolo earthquake fault zone is the Red Mountain Fault – South Strand, located approximately 12.6 miles southeast of the City.53 As such, development setback regulations pertaining to the Alquist-Priolo Earthquake Fault Zoning Act do not apply. However, several documented faults do exist within the City that could indicate near-surface faulting and surface warps; these faults have not been thoroughly evaluated for fault activity. For development projects on or near fault zones on the City geologic map, geological and geotechnical evaluations may be required during the permitting process. Incorporation of project-specific measures such as fault hazard avoidance, setbacks, and structural engineering solutions to accommodate acceptable levels of discrete movement and surface warping, would not result in significant environmental impacts.

According to the City’s Map Analysis and Printing System, high liquefaction potential exists at the Santa Barbara Airport and at the southeastern portion of the City abutting a stretch of coast from Leadbetter Beach to East Beach and extending northwest into the downtown area.54 Proposed development located in areas of high liquefaction potential (identified in the City’s Map Analysis and Printing System) may require a geotechnical report during the permitting process.55 Geotechnical reports identify liquefaction potential and provide recommendations to minimize the potential for impacts associated with liquefaction to occur. Municipal Code, Chapter 22.04, lists the adoptions of California Codes by reference, which includes CBC and subsequent measures such as requiring sitespecific geotechnical investigations and incorporating site specific recommendations regarding suitability and foundation design. Compliance with the Municipal Code and CBC requirements would 50 California Department of Conservation (DOC). 2019. Alquist-Priolo Earthquake Fault Zones. https://www.conservation.ca.gov/cgs/alquist-priolo Accessed October 2023. 51 California Department of Conservation (DOC). 2019. Alquist-Priolo Earthquake Fault Zones. https://www.conservation.ca.gov/cgs/alquist-priolo Accessed October 2023. 52 California Department of Conservation. 2021. Earthquake Zones of Required Investigation. September 23, 2021. https://maps.conservation.ca.gov/cgs/EQZApp/app/ . October 2023. 53 California Department of Conservation. 2021. Earthquake Zones of Required Investigation. September 23, 2021. https://maps.conservation.ca.gov/cgs/EQZApp/app/ . Accessed October 2023. 54 Santa Barbara, City of. 2010. Program Environmental Impact Report for the Plan Santa Barbara General Plan Update. September 2010. https://www.santabarbaraca.gov/services/planning/plan.asp. Accessed October 2023. 55 Santa Barbara, City of. 2022. Environmental Review Universal Screening Tool. https://santabarbaraca.gov/sites/default/files/documents/Services/Planning%20Handouts%20- %20updated/Environmental%20Screening%20Guide.pdf. Accessed October 2023.

Environmental Checklist
Geology and Soils
Draft Initial Study – Negative Declaration 67
ensure current engineering practices and standards are followed, reducing impacts related to adverse effects from liquefaction risk.

Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in construction or operational impacts related to risk of loss, injury, or death involving rupture of a known earthquake fault, strong seismic ground shaking, seismic-related ground failure including liquefaction, or landslides. The CAP Update is a policy document containing climate measures and supporting actions to reduce GHG emissions and is consistent with the Santa Barbara General Plan and other regional regulations. The CAP Update does not propose habitable development that could result in exposure of people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, strong seismic ground shaking, seismic-related ground failure, including liquefaction, or landslides.

Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in less-than-significant impact related to seismic- and landsliderelated hazards.

LESS-THAN-SIGNIFICANT IMPACT
b. Would the project result in substantial soil erosion or the loss of topsoil? Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in construction or operational impacts related to substantial loss of topsoil. The CAP Update would not involve land use or zoning changes, but it would promote infrastructure development and redevelopment. As a policy document, the CAP Update would not directly require ground-disturbing activities. However, implementation of the following measures may promote infrastructure development and redevelopment. Measure BE-1 promotes the decarbonization of 50% of municipal buildings, Measure BE-4 promotes the expansion of the existing Natural Gas Prohibition Ordinance for new construction, Measure BE-5 promotes reducing residential natural gas consumption, and Measure B-6 promotes reducing commercial natural gas consumption. These building measures involve regulating new infrastructure and electrification retrofits. To implement these retrofits, associated construction could interfere with soils around existing and new developments. Similarly, the following transportation measures involve the creation of new bike and walking lanes throughout the city. This construction could also result in the loss of topsoil around construction sites and contribute to erosion. Measure T-1 involves the development and implementation of the Municipal Transportation Demand Management (TDM) Program, which aims to increase free-of-charge access to public transit and the electric bike share program in the City. Additionally, the TDM Program aims to provide cash incentives for cityemployees to bike, walk, or carpool to work while Measure T-3 aims to implement programs to enhance access to safe active transportation. Measure T-4 encourages the implementation of programs to increase public transportation mode share via public transit improvements, education, increased access, and creating pilot projects. Furthermore, Measure CS-1 facilitates the expansion of the City’s Urban Forest Management Plan and requires planting and maintaining 4,500 net new trees by the year 2030.Increasing the urban forest via the planting of trees could result in soil erosion or loss of topsoil, as workers may need to disturb current soil to plant the trees. Although this soil disturbance may occur throughout the City as trees are planted, these effects will likely be temporary and will return to normal once the trees are planted.

The physical changes these installations and enhancements would entail are dependent on the location of construction for the electric vehicle charging connections, active transportation pathways, and trees/green spaces, which in some cases may include minor temporary excavation.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
68 As such, the CAP Update could result in construction-related soil erosion and topsoil loss impacts associated with such installations and plantings. However, projects would be reviewed for consistency with Santa Barbara General Plan policies and other local and State geology and soils regulations prior to final siting and construction. Further, compliance with existing regulations, including California Building Code requirements, City-issued permit requirements, and construction general permit requirements, would minimize potential cumulative seismic and geologic impacts.

Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant impact related to soil erosion, loss of topsoil, and the presence of unstable soils.

LESS-THAN-SIGNIFICANT IMPACT
c. Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
d. Would the project be located on expansive soil, as defined in Table 1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in construction or operational impacts related to project location on expansive soil. Additionally, the CAP Update is a policy document containing measures that are consistent with the General Plan. Some of the proposed measures of CAP Update would support construction projects, such as electric vehicle charging station construction. However, the City’s Building and Safety Division would determine which projects would be required to conduct geotechnical studies based on the scope of the development and adhere to related recommendations prior to final siting and construction that would reduce impacts. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant impact related to risks associated with location on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse as well as expansive soils.

LESS-THAN-SIGNIFICANT IMPACT
e. Would the project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
The CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not involve the development of habitable structures and, thus, no use of septic tanks or alternative wastewater disposal systems. Therefore, no impact would occur related to soil capability support of alternative wastewater disposal systems.

NO IMPACT
f. Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in construction or operational impacts related to paleontological resources. The CAP Update would not involve land use or zoning changes. Rather the CAP Update Environmental Checklist
Geology and Soils
Draft Initial Study – Negative Declaration 69
would promote infrastructure development and redevelopment. As a policy document, the CAP Update would not directly result in impacts related to paleontological resources or unique geologic features. However, implementation of the following CAP Update measures and supporting actions may promote infrastructure development and redevelopment.

Measure BE-1 promotes the decarbonization of 50% of municipal buildings, Measure BE-4 promotes the expansion of the existing Natural Gas Prohibition Ordinance for new construction, Measure BE-5 promotes reducing residential natural gas consumption, and Measure B-6 promotes reducing commercial natural gas consumption. Measure T-1 involves the development and implementation of the Municipal Transportation Demand Management (TDM) Program, which aims to increase freeof-charge access to public transit and the electric bike share program in the City. Additionally, the TDM Program aims to provide cash incentives for city-employees to bike, walk, or carpool to work while Measure T-3 aims to implement programs to enhance access to safe active transportation.

Measure T-4 encourages the implementation of programs to increase public transportation mode share via public transit improvements, education, increased access, and creating pilot projects.

Measure T-7 aims to accelerate zero-emission commercial vehicle use and adoption to 26% by 2030 and Measure T-8 aims to electrify or decarbonize 6% of Off-Road equipment by 2030. Furthermore, Measure CS-1 facilitates the expansion of the City’s Urban Forest Management Plan and requires planting and maintaining 4,500 net new trees by the year 2030. However, geotechnical and design guideline studies would be required for future projects, in addition to adherence with related recommendations prior to final siting and construction. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a lessthan-significant impact related to paleontological resources or unique geologic features.

LESS-THAN-SIGNIFICANT IMPACT
Cumulative Impacts
The cumulative projects scenario is total projected population growth for Santa Barbara (96,637 persons) in 2030. Cumulative projects could expose additional people and property to seismic and geologic hazards that are present in the region. The magnitude of geologic hazards for individual projects, including those associated with implementation of the CAP Update, would depend upon the location, type, and size of development and the specific hazards associated with individual sites.

Specific geologic hazards associated with individual project sites would be limited to those sites without affecting other areas. Similarly, potential impacts to paleontological resources associated with each individual site would be limited to that site without affecting other areas, and impacts related to these resources would be minimized on a case-by-case basis. Compliance with existing regulations, including California Building Code requirements, City-issued permit requirements, and construction general permit requirements, would minimize potential cumulative seismic and geologic impacts. Seismic and geologic hazards would be addressed on a case-by-case basis and would not result in cumulative impacts. Furthermore, as a guidance document, the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in cumulative impacts. Therefore, implementation of the CAP Update and GHG Emission Threshold would result in a less-than-significant cumulative impact related to geology and soils.

LESS-THAN-SIGNIFICANT IMPACT
City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
70 This page intentionally left blank.

Environmental Checklist
Greenhouse Gas Emissions
Draft Initial Study – Negative Declaration 71
8 Greenhouse Gas Emissions
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
Would the project:
a. Generate greenhouse gas emissions,
either directly or indirectly, that may
have a significant impact on the
environment? □ □ ■ □
b. Conflict with an applicable plan, policy, or
regulation adopted for the purpose of
reducing the emissions of greenhouse
gases? □ □ ■ □
a. Would the project generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment?
The greenhouse effect is a natural occurrence that helps regulate the temperature of the Earth. The majority of radiation from the Sun hits Earth’s surface and warms it. The surface in turn radiates heat back towards the atmosphere, known as infrared radiation. Gases and clouds in the atmosphere trap and prevent some of this heat from escaping into space and re-radiate it in all directions. This process is essential to support life on Earth because it warms the planet by approximately 60°F. Emissions from human activities since the beginning of the industrial revolution (approximately 270 years ago) have been adding to the natural greenhouse effect by increasing the gases in the atmosphere that trap heat and contribute to an average increase in Earth’s temperature. Global warming is the observed increase in the average temperature of the Earth’s surface, and climate change is the resultant change in wind patterns, precipitation, and storms over an extended period.

GHGs produced by human activities include CO2, methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorinated compound (PFC), and sulfur hexafluoride (SF6).

Combustion of fossil fuels (gasoline, natural gas, and coal), deforestation, and decomposition of waste release carbon into the atmosphere that had been locked underground and stored in oil, gas, and other hydrocarbon deposits or in the biomass of surface vegetation. Since 1750, estimated concentrations of CO2, CH4, and N2O in the atmosphere have increased by over 36 percent, 148 percent, and 18 percent respectively, primarily due to human activity. Emissions of GHGs affect the atmosphere directly by changing its chemical composition.

Changes to the land surface also indirectly affect the atmosphere by changing the way in which Earth absorbs gases from the atmosphere. Potential impacts in California due to climate change include sea level rise, more extreme-heat days and high-ozone days, larger and more frequent forest fires, and more drought years.56 Although GHG emissions do not typically cause direct health 56 California Energy Commission (CEC). 2009. Environmental Health and Equity Impacts from Climate Change and Mitigation Policies in California: A Review of the Literature. Accessed October 2023.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
72 impacts at a local level, GHG emissions can result in indirect health impacts by contributing to climate change, which can have public health implications. The primary public health impacts of climate change include the following:57
▪ Increased incidences of hospitalization and deaths due to increased incidences of extreme heat events
▪ Increased incidences of health impacts related to ground-level ozone pollution due to increased average temperatures that facilitate ozone formation
▪ Increased incidences of respiratory illnesses from wildfire smoke due to increased incidences of wildfires
▪ Increased vector-borne diseases due to the growing extent of warm climates ▪ Increased stress and mental trauma due to extreme events and disasters, economic disruptions, and residential displacement
The City of Santa Barbara has completed a total Santa Barbara (i.e., community and municipal) GHG emissions inventory for the year 2019, which is summarized in Table 1. The largest sectors of GHG emissions are related to energy and transportation, followed by solid waste and water. The measures and actions address municipal and communitywide GHG emissions. Per the CAP Update, the City of Santa Barbara is committed to an emissions reduction target of 40 percent below 1990 levels by 2030 (SB 32 target year) and reaching a longer-term goal of carbon neutrality by 2035.

Table 2 summarizes the emission reduction targets included in the CAP Update compared to the reductions proposed in the 2012 CAP. This 2030 GHG emissions goal is selected to be consistent with SB 32 and CEQA Guidelines § 15183.5 for a qualified GHG emissions reduction strategy as well as to be achievable by City-supported measures identified in the CAP Update. The CAP Update includes a business-as-usual (BAU) and adjusted forecast of GHG emissions that will enable the City to estimate the amount of emissions reductions needed to meet its goal.

The CAP Update includes measures to increase use of zero-emission vehicles; increase use of public, active, and shared transportation; reduce water consumption and waste generation; increase recycling and composting; and increase tree planting. Table 3 includes a complete list of measures and descriptions of respective supporting actions included in this CAP Update. The measures included in the CAP Update combined with Statewide legislation and initiatives and regional transportation programs will enable the City to meet its emissions reduction target of 40 percent below 1990 levels by 2030 (SB 32 target year) and its carbon neutral goal by 2035. Table 5 shows the contribution of the Statewide initiatives along with the measures and actions. The City needs to achieve 132,305 MT CO2e of GHG emissions reductions by 2030 to meet its goal. The total estimated GHG reductions accounted for in the CAP Update total 320,089 MT CO2e by 2030.

Figure 3 and Table 5 illustrate how the BAU emissions are estimated to increase, thus widening the emissions reductions needed by 2030. Figure 3 also shows emissions reductions expected from State level actions as well as the reductions needed to reach the Santa Barbara emissions target.

The measures and supporting action combined with Statewide legislation and initiatives and Countywide transportation programs will enable the City of Santa Barbara to meet its 2030 emissions reduction target.

The CAP Update includes a list of measures intended to reduce Santa Barbara GHG emissions.

Implementation of the CAP Update would result in the reduction of community and municipal 57 California Natural Resources Energy. 2018. California’s Fourth Climate Change Assessment Statewide Summary Report. <http://www.climateassessment.ca.gov/state/>. Accessed October 2023.

Environmental Checklist
Greenhouse Gas Emissions
Draft Initial Study – Negative Declaration 73
operational GHG emissions, while only generating temporary GHG emissions during construction of infrastructure development and redevelopment such as electric vehicle charging stations, bicycle paths, et cetera. Additionally, the CAP Update would serve as a pathway to reduce GHG emissions and introduce other beneficial environmental and sustainability effects. These benefits include reduction in building energy consumption and vehicle miles traveled (and thus air pollution), water consumption, and solid waste generation. The Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would establish GHG emissions targets and analysis methodologies that are enforced during CEQA review with the intention of reducing GHG emissions associated with construction and operation of future projects and plans in the City. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant impact related to generation of GHG emissions.

LESS-THAN-SIGNIFICANT IMPACT
b. Would the project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
The CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis are policy-level documents that set strategies to reduce GHG emissions within the City in an effort to also comply with State regulations. As discussed under Topic 8a above, the CAP Update includes measures and actions to reduce City GHG emissions from forecasted levels by approximately 132,035 MT CO2e by 2030. The purpose of the CAP Update is to meet Santa Barbara’s proportionate fair share of the Statewide GHG emissions reduction target set by AB 32 and SB 32 and work toward the State’s longer-term target of carbon neutrality identified in Executive Order B55-18. The CAP Update would not conflict with any applicable GHG reduction plans, including the California Climate Change Scoping Plan and the California Climate Change Scoping Plan Updates. For example, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis specifically include policies and a locally appropriate quantitative threshold consistent with Statewide per-capita goals, as recommended by the 2022 Scoping Plan. The CAP Update identifies how the City would achieve consistency with the Statewide GHG emissions limit.

The Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would establish GHG emissions targets and analysis methodologies that are enforced during CEQA review with the intention of reducing GHG emissions associated with construction and operation of future projects and plans in the City. The CAP Update would serve as a pathway to reduce GHG emissions and introduce other beneficial environmental and sustainability effects. These benefits include reduction in building energy consumption and vehicle miles traveled (and thus air pollution), water consumption, and solid waste generation. Therefore, the CAP Update and GHG Emission Threshold would result in a less-than-significant impact related to consistency with applicable GHG emissions reduction plans, policies, and regulations.

LESS-THAN-SIGNIFICANT IMPACT
Cumulative Impacts
The cumulative projects scenario is total projected population growth for Santa Barbara (96,637 persons) in 2030. Analyses of GHG emissions and climate change are cumulative in nature, as they affect the accumulation of GHG emissions in the atmosphere. Cumulative projects that exceed the thresholds discussed above would have a significant impact related to GHG emissions and climate change, both individually and cumulatively. The CAP Update creates a GHG emissions reduction strategy (consistent with Section 15183.5 of the CEQA Guidelines) for the City of Santa Barbara. The City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
74 CAP Update includes a series of strategies, measures, and actions that are intended to reduce communitywide GHG emissions by approximately 40 percent below 1990 levels by 2030, which provides substantial progress toward meeting the City carbon neutrality goal by 2035, while meeting State goals. The CAP Update acknowledges that additional actions beyond those identified in the plan will be necessary to achieve carbon neutrality and, therefore, provides a mechanism for updating and adopting a new plan triennially in order to incorporate new measures and technologies that will further the City toward meeting its goal of carbon neutrality. As such, the CAP Update would result in the reduction of GHG emissions rather than generating GHG emissions.

Furthermore, as a guidance document, the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in cumulative impacts. Rather, the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would establish GHG emissions targets and analysis methodologies that are enforced during CEQA review with the intention of reducing GHG emissions associated with construction and operation of cumulative buildout.

LESS-THAN-SIGNIFICANT IMPACT
Environmental Checklist
Hazards and Hazardous Materials
Draft Initial Study – Negative Declaration 75
9 Hazards and Hazardous Materials
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
Would the project:
a. Create a significant hazard to the public
or the environment through the routine
transport, use, or disposal of hazardous
materials? □ □ ■ □
b. 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? □ □ ■ □
c. Emit hazardous emissions or handle
hazardous or acutely hazardous
materials, substances, or waste within

0.25 mile of an existing or proposed
school? □ □ ■ □
d. Be located on a site that is included on a
list of hazardous material 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? □ □ ■ □
e. For a project located in an airport land
use plan or, where such a plan has not
been adopted, within two miles of a
public airport or public use airport, would
the project result in a safety hazard or
excessive noise for people residing or
working in the project area? □ □ ■ □
f. Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan? □ □ ■ □
g. Expose people or structures, either
directly or indirectly, to a significant risk
of loss, injury, or death involving wildland
fires? □ □ ■ □
City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
76 a. Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? b. Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in construction or operational impacts related to creating a significant hazard. The CAP Update is a policy document containing actions and supporting measures to reduce GHG emissions. The proposed CAP Update does not involve identified site-specific development, nor would it facilitate new development. Implementation of the CAP Update measures and supporting actions would not involve the routine transport, use, or disposal of hazardous materials and would not create reasonably foreseeable upset and/or accidental conditions involving the release of hazardous materials into the environment.

Implementation of some of the CAP Update measures and actions, such as the installation of bicycle facilities, energy retrofits, and electric vehicle charging stations, may involve the use and transport of fuels, lubricating fluids, and solvents, among other activities. These types of materials are not considered acutely hazardous, and all storage, handling, and disposal of these materials are regulated by the California Department of Toxic Substances Control (CDTSC), United States Environmental Protection Agency (USEPA), Occupational Safety & Health Administration (OSHA), and Los Angeles County Department of Public Health - Environmental Health Division. Additionally, future development would be subject to review by the City for compliance with the General Plan and Municipal Code and would also be required to comply with applicable local, State, and Federal regulations. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant impact related to creating a significant hazard.

LESS-THAN-SIGNIFICANT IMPACT
c. Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school? Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in construction or operational impacts related to handling hazardous materials. The CAP Update is a policy document containing measures and actions to reduce GHG emissions. The proposed CAP Update does not include site-specific proposals and development, nor would it emit or handle hazardous materials. Implementing some measures and actions may require future development or improvements, such as bike paths, solar panels, electric vehicle charging stations, battery storage, or building improvements related to electrification. However, projects would be reviewed for consistency with the General Plan and Municipal Code and applicable local, State, and federal regulations. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant impact related to handling of hazardous materials in proximity to an existing or proposed school.

LESS-THAN-SIGNIFICANT IMPACT
d. Would the project be located on a site that is included on a list of hazardous material 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?
Environmental Checklist
Hazards and Hazardous Materials
Draft Initial Study – Negative Declaration 77
Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in construction or operational impacts related to project site location on a site listed on a hazardous material site. The CAP Update is a policy document containing measures and supporting actions to reduce GHG emissions. The CAP Update does not include site-specific proposals and development, but implementation of the measures and actions could result in projects that may be located on listed hazardous materials site. However, future projects would be reviewed for consistency with the General Plan and Municipal Code and would be required to comply with applicable local, State, and federal regulations. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a lessthan-significant impact related to location on a listed hazardous materials site.

LESS-THAN-SIGNIFICANT IMPACT
e. For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? The City operates the Santa Barbara Airport, located in the Goleta area, approximately four miles west of the City proper. The Airport property is within the City’s jurisdiction, and City-designated land use and zoning patterns apply to the approximate 950-acre property. Airport zoning, defined by Title 29 of the City of Santa Barbara Municipal Code, provides restrictions for residential development.58 59
The CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis are policy documents and implementation of which would not increase airport activity or otherwise increase potential exposure to aircraft-related hazards. Additionally, projects associated with the CAP Update would undergo project-level CEQA review. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in less-than-significant impact related to risks associated with location proximate to a public airport.

LESS THAN SIGNIFICANT IMPACT
f. Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Construction activities associated with development forecasted in accordance with the Building Energy and Transportation Measures included in the CAP Update could interfere with adopted emergency response or evacuations plans as a result of temporary construction activities within rights-of-way, which could impede emergency access. Any temporary construction barricades or other obstructions that could impede emergency access on State highway systems/routes would be subject to the standards set forth in the California Manual of Uniform Traffic Control Devices (Manual).60 The Manual requires the creation and approval of temporary traffic control plans to be used for facilitating road users through a work zone. Adherence to the requirements of the Manual for all construction activity would minimize potential impacts associated with the impairment or physical interference of an adopted emergency response plan or evacuation procedures for State 58 Santa Barbara, City of. 2021. Santa Barbara Municipal Code. https://qcode.us/codes/santabarbara/. Accessed October 2023. 59 Santa Barbara, City of. 2003. Coastal Plan Component 9: Airport. https://www.santabarbaraca.gov/civicax/filebank/blobdload.aspx?BlobID=16924. Accessed October 2023. 60 California Department of Transportation (Caltrans). 2021. California Manual on Uniform Traffic Control Devices. 2014 Edition Revision 6. https://dot.ca.gov/-/media/dot-media/programs/safety-programs/documents/ca-mutcd/rev6/camutcd2014-rev6.pdf. Accessed October 2023.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
78 highways. Future development forecasted in accordance with the CAP Update will be reviewed by the Santa Barbara City Fire Department to ensure consistency with emergency access requirements.

Infrastructural improvements that involve work in the public right-of-way would be subject to applicable City requirements to ensure appropriate traffic control, pursuant to the Santa Barbara Municipal Code Chapter 10.55. Additionally, as part of standard development procedures in the City, development plans must be submitted to the City’s Community Development Department for review and approval to ensure that all new development would have adequate emergency access and escape routes in compliance with existing City and Fire Department regulations pursuant to the regulations as set forth by the CWPP.

The CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis are policy documents intended to reduce GHG emissions. The proposed CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis do not involve site-specific development. Any new development associated with the CAP would be subject to adherence to the Manual, review by the Santa Barbara City Fire Department, and/or Municipal Code Chapter 10.55 ensuring adequate emergency access requirements are met and construction would not interfere with adopted emergency plans. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in less-than-significant impact related to impairment or interference with implementation of an emergency response or evacuation plan.

LESS THAN SIGNIFICANT IMPACT
g. Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
The CAP Update is a policy-level document that does not propose specific or other physical changes such as habitable development that could be put at risk in the case of a wildfire, nor does it grant entitlements for development that would have the potential to directly cause wildfire. Rather, the CAP Update would aim to reduce natural gas infrastructure that poses wildfire risk if damaged during seismic events and to underground new or restructured electric power lines that pose wildfire risk if damaged during high-wind events. Thus, the CAP Update and Emissions Threshold would result in less-than-significant impact related to wildfire.

LESS THAN SIGNIFICANT IMPACT
Cumulative Impacts
The cumulative projects scenario is total projected population growth for Santa Barbara (96,637 persons) in 2030. Hazards and hazardous materials impacts are typically site specific in nature.

Cumulative projects, including the CAP Update, are not anticipated to contribute to cumulative hazards and hazardous materials impacts with adherence to applicable General Plan policies, applicable regional and County regulations, and applicable State and Federal regulatory requirements. Furthermore, as a guidance document, the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would not result in cumulative impacts.

Therefore, implementation of the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant cumulative impact related to hazards and hazardous materials.

LESS-THAN-SIGNIFICANT IMPACT
Environmental Checklist
Hydrology and Water Quality
Draft Initial Study – Negative Declaration 79
10 Hydrology and Water Quality
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
Would the project:
a. Violate any water quality standards or
waste discharge requirements or
otherwise substantially degrade surface
or ground water quality? □ □ ■ □
b. Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the
project may impede sustainable
groundwater management of the basin? □ □ ■ □
c. 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
which would:
(i) Result in substantial erosion or
siltation on- or off-site; □ □ ■ □
(ii) Substantially increase the rate or
amount of surface runoff in a
manner which would result in
flooding on- or off-site; □ □ ■ □
(iii) 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; or □ □ ■ □
(iv) Impede or redirect flood flows? □ □ ■ □
d. In flood hazard, tsunami, or seiche zones,
risk release of pollutants due to project
inundation? □ □ ■ □
e. Conflict with or obstruct implementation
of a water quality control plan or
sustainable groundwater management
plan? □ □ ■ □
City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
80 a. Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would not result in construction or operational impacts related to water quality standards.

The CAP Update is a policy document containing measures and actions intended to reduce GHG emissions in the City. Future projects would be reviewed for consistency with local and State regulations, including the implementation of stormwater pollution prevention plans (SWPPPs). As such, the CAP Update’s related infrastructure changes would not utilize or alter water supply or result in new or different wastewater discharge. Additionally, projects would be small in scale and would not typically warrant substantial adverse construction impacts related to surface or groundwater quality, thus maintaining impact levels below CEQA thresholds. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less than significant related to surface or groundwater water quality in Santa Barbara.

LESS THAN SIGNIFICANT IMPACT
b. Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would not result in construction or operational impacts related to groundwater supplies.

The CAP Update is a policy document containing measures and supporting actions that are consistent with the City’s General Plan. In addition, implementation of the CAP Update actions related to infrastructure development and redevelopment would not substantially degrade groundwater quality or groundwater recharge. As a result, no adverse impacts related to groundwater supplies or resources would occur.

Measure CS-1 facilitates the expansion of the City’s Urban Forest Management Plan and requires planting and maintaining 4,500 net new trees by the year 2030. Encouragement of tree planting would increase the amount of pervious areas in the City, thus increasing groundwater recharge. As such, implementing the CAP Update would have a beneficial effect related to local groundwater recharge as well as support groundwater management in Santa Barbara. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less than significant impact related to impedance of sustainable groundwater management in the Santa Barbara local Groundwater Basins.

LESS THAN SIGNIFICANT IMPACT
Environmental Checklist
Hydrology and Water Quality
Draft Initial Study – Negative Declaration 81
c. 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 which would:
i. result in substantial erosion or siltation on- or off-site; ii. substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site;
iii. 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; or
iv. impede or redirect flood flows?
Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would not result in construction or operational impacts related to alterations in polluted runoff. Implementation of the following CAP Update measures and supporting actions may promote infrastructure development and redevelopment. Measure BE-1 promotes the decarbonization of 50% of municipal buildings, Measure BE-4 promotes the expansion of the existing Natural Gas Prohibition Ordinance for new construction, Measure BE-5 promotes reducing residential natural gas consumption, and Measure B-6 promotes reducing commercial natural gas consumption.

Measure T-1 involves the development and implementation of the Municipal Transportation Demand Management (TDM) Program, which aims to increase free-of-charge access to public transit and the electric bike share program in the City. Additionally, the TDM Program aims to provide cash incentives for city-employees to bike, walk, or carpool to work while Measure T-3 aims to implement programs to enhance access to safe active transportation. Measure T-4 encourages the implementation of programs to increase public transportation mode share via public transit improvements, education, increased access, and creating pilot projects. Measure T-7 aims to accelerate zero-emission commercial vehicle use and adoption to 26% by 2030 and Measure T-8 aims to electrify or decarbonize 6% of Off-Road equipment by 2030. Furthermore, Measure CS-1 facilitates the expansion of the City’s Urban Forest Management Plan and requires planting and maintaining 4,500 net new trees by the year 2030.

Projects would be required to undergo environmental review, including assessment and mitigation incorporation, including the implementation of a SWPPP and compliance with applicable local, State, and Federal regulations once project details and locations are known. Further, CAP Updaterelated infrastructure changes would be designed to not result in substantial additional erosion or runoff. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would result in a less-than-significant impact related to drainage flows and polluted runoff.

LESS-THAN-SIGNIFICANT IMPACT
City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
82 d. In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?
As described by the Santa Barbara Tsunami Response Plan, parts of the City are designated as tsunami inundation zones including the waterfront area extending into the downtown area and the Santa Barbara Airport.61 Portions of the City are within the 100- and 500-year flood zones defined by Federal Emergency Management Agency (FEMA).62
Pursuant to the City’s Floodplain Management Ordinance, proposed development located in FEMA Flood Hazard Zones requires a base flood elevation determination from the Building and Safety Division.63 New development forecasted in accordance with the CAP Update that takes place within a special flood hazard zone would be required to obtain a flood development permit granted by the Floodplain Administrator for the City of Santa Barbara, pursuant to the City of Santa Barbara Municipal Code Section 22.24.110.64 The Floodplain Administrator grants the permit on the condition that all permit requirements in Chapter 22.24 have been met, including standards for floor elevations, elevations in areas of shallow flooding, elevation or floodproofing of nonresidential structures, wet floodproofing standards, floodway encroachments, and coastal development standards.65 All development in a special flood hazard zone is required to abide by these standards.

As a result, implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis and CAP Update would not conflict with floodway or floodplain regulations and this impact would be less than significant.

LESS-THAN-SIGNIFICANT IMPACT
e. Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would not result in construction or operational impacts related to obstruction of a water quality control plan. The CAP Update measures would not include direct extraction of groundwater and would rather encourage water savings through conservation. The CAP Update would not interfere with or obstruct implementation of water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would result in a less than significant impact related to consistency with a water quality control plan or sustainable groundwater management plan.

LESS THAN SIGNIFICANT IMPACT
61 Santa Barbara, City of. 2012. Tsunami Response Plan. https://santabarbaraca.gov/sites/default/files/documents/Fire/City%20Emergency%20Plan/2012%20Tsunami%20Response%20Plan.pdf.

Accessed October 2023.
62 Santa Barbara, City of. 2018. City Flood Zones. https://www.santabarbaraca.gov/services/home/floodzones.asp. Accessed October 2023.
63 Santa Barbara, City of. 2022. Environmental Review Universal Screening Tool. https://santabarbaraca.gov/sites/default/files/documents/Services/Planning%20Handouts%20- %20updated/Environmental%20Screening%20Guide.pdf. Accessed October 2023. 64 Santa Barbara, City of. 2021. Santa Barbara Municipal Code. https://qcode.us/codes/santabarbara/. Accessed October 2023. 65 Santa Barbara, City of. 2021. Santa Barbara Municipal Code. https://qcode.us/codes/santabarbara/. Accessed October 2023.

Environmental Checklist
Hydrology and Water Quality
Draft Initial Study – Negative Declaration 83
Cumulative Impacts
The cumulative projects scenario is total projected population growth for Santa Barbara (96,637 persons) in 2030. Cumulative projects, including the CAP Update, are not anticipated to contribute to cumulative hydrology and water quality impacts with adherence to applicable General Plan policies and other applicable City policies, as well as applicable State and federal regulatory requirements. Implementation of the CAP Update would not contribute to an increase in growth and development in Santa Barbara but could result in infrastructure development or redevelopment projects, including renewable energy facilities and alternative transportation thoroughfares. As such, implementation of the CAP Update and other cumulative projects could have incremental impacts related to hydrology and water quality, with potential minor alterations to existing drainage patterns in the City. However, cumulative projects would comply with applicable local, State, and Federal regulations related to hydrology and water quality. Therefore, implementation of the CAP Update would result in a less-than-significant cumulative impact related to hydrology and water quality.

LESS-THAN-SIGNIFICANT IMPACT
City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
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Environmental Checklist
Land Use and Planning
Draft Initial Study – Negative Declaration 85
11 Land Use and Planning
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
Would the project:
a. Physically divide an established
community? □ □ □ ■
b. 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? □ □ ■ □
a. Would the project physically divide an established community? Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would not result in construction or operational impacts related to division of an established community. The CAP Update is a policy document containing measures and actions that are consistent with the Santa Barbara General Plan and does not include specific development projects that would divide an established community. Measure T-1 involves developing and implementing a Municipal Transportation Demand Management Program, Measure T-3 involves enhancing access to safe active transportation, such as walking or biking, Measure T-4 involves implementing programs to encourage public transportation, and Measure T-5 supports and promotes the reduction of single occupancy vehicles. These measures are aimed at decreasing vehicle miles traveled and increasing active transportation within the City. Such measures and supporting actions would help to increase connectivity within the Santa Barbara community.

Therefore, the CAP Update would result in no impact related to the division of an established community.

NO IMPACT
b. 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?
Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would not result in impacts related to conflict with a land use plan. The CAP Update is a policy document containing measures and actions that are consistent with the Santa Barbara General Plan and that are designed to reduce adverse environmental impacts associated with climate change. Nonetheless, implementing the CAP Update would require some modification of existing policies, including developing and implementing new programs, and projects, or modifying existing ones. For example, Measures BE-1, BE-2, T-1, T-2, T-3, T-4, T-5, T-6, T-7, W-1, and CS-1 call for the adoption of new codes/ordinances related to building electrification, solar and electric vehicle charging infrastructure installation, natural gas ban, organic waste collection and recovery, and shade trees.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
86 The physical changes these upgrades and additions would entail are dependent on the year of building construction and location of electrical and service panels and plumbing for connection of condensate drains, which in some cases may include modifications to the interior and/or exterior of buildings for wiring and panel replacement and minor excavation for connection of drainage to sewer systems. In order to implement these measures and the supporting actions, the City Municipal Code, General Plan, and other applicable documents may need to be amended to reflect new or modified requirements.

However, where modifications of existing policies are needed, such as updates to policies related to energy and active transportation, the measures would result in greater avoidance or reduction of environmental effects. Therefore, the CAP Update and GHG Emission Thresholds would result in less-than-significant impact related to consistency with current land use plans or policies.

LESS THAN SIGNIFICANT IMPACT
Cumulative Impacts
The cumulative projects scenario is total projected population growth for Santa Barbara (96,637 persons) in 2030. The CAP Update is a policy document containing measures and actions that are consistent with the City’s General Plan. Nonetheless, implementing the CAP Update would require some modification of existing policies and ordinances, including developing and implementing new programs, and projects, or modifying existing ones. The proposed policy changes are consistent with the intent of the goals and policies established within the City General Plan and Zoning Regulations and would not cumulatively contribute to population growth or the loss of housing. Cumulative projects, including the CAP Update, would be required to adhere to City development regulations and General Plan policies to retain land use character and minimize environmental impacts. Any CAP Update projects would be reviewed for consistency with the General Plan and other applicable regulatory land use actions prior to approval. Furthermore, as a guidance document, the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would not result in cumulative impacts. Therefore, implementation of the CAP Update would result in a less-thansignificant cumulative impact related to land use.

LESS-THAN-SIGNIFICANT IMPACT
Environmental Checklist
Mineral Resources
Draft Initial Study – Negative Declaration 87
12 Mineral Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
Would the project:
a. Result in the loss of availability of a
known mineral resource that would be of
value to the region and the residents of
the state? □ □ □ ■
b. Result in the loss of availability of a
locally important mineral resource
recovery site delineated on a local
general plan, specific plan, or other land
use plan? □ □ □ ■
a. Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
b. Would the project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? The California Geological Survey’s (CGS) Updated Mineral Land Classification Map for ConcreteGrade Aggregates in the San Luis Obispo-Santa Barbara Production-Consumption Region, California – South Half map indicates that the City is within Mineral Resources Zones-1 (MRZ) and MRZ -3 (CGS 2011). MRZ-1 designations indicate areas containing little or no mineral deposits and MRZ-3 designations indicate deposits identified but require further evaluation. The CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would not facilitate infrastructure development projects within the City that could result in the loss of availability of known mineral resources. Therefore, the CAP Update would result in no impact related to mineral resource.

NO IMPACT
Cumulative Impacts
The cumulative projects scenario is total projected population growth for Santa Barbara (96,637 persons) in 2030. The CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis do not include components capable of limiting or extracting known mineral resources. The City of Santa Barbara does not operate mineral extraction facilities and development forecasted in accordance with the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not be located on an area where important mineral resources are present. Therefore, the CAP Update and Master Environmental Assessment City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
88 Guidelines for Greenhouse Gas Emissions Analysis would not result in the loss of a locally important mineral resource recovery site and would have no cumulative impact related to mineral resources.

NO IMPACT
Environmental Checklist
Mineral Resources
Draft Initial Study – Negative Declaration 89
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City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
90 13 Noise
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
Would the project result in:
a. Generation of a substantial temporary or
permanent increase in ambient noise
levels in the vicinity of the project in
excess of standards established in the
local general plan or noise ordinance, or
applicable standards of other agencies? □ □ ■ □
b. Generation of excessive groundborne
vibration or groundborne noise levels? □ □ ■ □
c. For a project located within the vicinity of
a private airstrip or an airport land use
plan or, where such a plan has not been
adopted, within two miles of a public
airport or public use airport, would the
project expose people residing or
working in the project area to excessive
noise levels? □ □ ■ □
a. Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Noise is unwanted sound that disturbs human activity. Environmental noise levels typically fluctuate over time, and different types of noise descriptors are used to account for this variability. Noise level measurements include intensity, frequency, and duration, as well as time of occurrence. Noise level (or volume) is generally measured in decibels (dB) using the A-weighted sound pressure level (dBA). Because of the way the human ear works, a sound must be about 10 dBA greater than the reference sound to be judged as twice as loud. In general, a 3 dBA change in community noise levels is noticeable, while 1-2 dBA changes generally are not perceived. Quiet suburban areas typically have noise levels in the range of 40-50 dBA, while arterial streets are in the 50-60+ dBA range.

Normal conversational levels are in the 60-65 dBA range, and ambient noise levels greater than 65 dBA can interrupt conversations.

Noise levels typically attenuate (or drop off) at a rate of 6 dBA per doubling of distance from point sources (such as construction equipment). Noise from lightly traveled roads typically attenuates at a rate of about 4.5 dBA per doubling of distance. Noise from heavily traveled roads typically attenuates at about 3 dBA per doubling of distance, while noise from a point source typically attenuates at about 6 dBA per doubling of distance. Noise levels may also be reduced by the introduction of intervening structures. For example, a single row of buildings between the receptor Environmental Checklist
Noise
Draft Initial Study – Negative Declaration 91
and the noise source reduces the noise level by about 5 dBA, while a solid wall or berm that breaks the line-of-sight reduces noise levels by 5 to 10 dBA.

The Environmental Resources Element of the City’s General Plan, which incorporates the 1979 Noise Element, is intended to identify sources of noise and provide goals, objectives, and policies that ensure that noise from various sources, including transportation and stationary sources, does not create an unacceptable noise environment. The City has adopted land use compatibility standards for use in assessing the compatibility of various land use types with noise levels. The noise environment in Santa Barbara is predominantly characterized by transportation sources: vehicles, freight and passenger trains, and aircraft overflights. Vehicle noise affects large areas of the City along major transportation corridors, particularly communities near U.S. Route 101 (U.S. 101), which generates noise levels at or above 70 dBA Ldn generally extending out between 250 and 300 feet from the corridor. Major roadways that generate noise between 65-69 dBA Ldn include Upper State Street, Las Positas Road, and Cabrillo Boulevard, whereas roadways that generate noise between 60-64 dBA Ldn include those within the City’s Downtown and Mesa neighborhoods. Freight and passenger train operations intermittently generate high noise levels often exceeding 100 dBA at 100 feet from the track centerline. For instance, portions of U.S. 101 noise overlap that associated with the Union Pacific Railroad (UPRR), which intermittently increases noise exposure at communities near these portions of the corridor. Aircraft overflights also intermittently create higher noise levels citywide. However, the nearest airport is Santa Barbara Airport, which is within the City limits but located in the Goleta area approximately four miles west of City proper. The airport’s 65 dBA CNEL noise contour extends approximately 3,000 feet east of the airport which does not reach City proper, located adjacent to La Cumbre Country Club.66 Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would not result in construction or operational impacts related to excessive noise levels.

The CAP Update is a policy document containing programs that are consistent with the General Plan. Some of the measures and actions included in the CAP Update would support construction projects, such as electric vehicle charging station construction that may result in a temporary increase in noise levels. However, future projects identified as measures/actions in the CAP Update would be reviewed for consistency with the General Plan Environmental Resources Element and the City’s noise ordinance, found in Municipal Code Title 9 Chapter 16, and would be required to comply with applicable local, State, and Federal regulations.67 The City of Santa Barbara General Plan identifies noise-sensitive land uses and noise sources and policies to provide for the protection of the community from the adverse effects of excessive noise.

The CAP Update encompasses a suite of GHG-reduction opportunities that affect the transportation sector. For example, Measure T-1 involves developing and implementing a Municipal Transportation Demand Management Program, Measure T-3 involves enhancing access to safe active transportation, such as walking or biking, Measure T-4 involves implementing programs to encourage public transportation, and Measure T-5 supports and promotes the reduction of single occupancy vehicles. These measures would not only reduce vehicle miles traveled but also reduce traffic-related noise in Santa Barbara. Therefore, the CAP Update and Master Environmental 66 Santa Barbara, City of. 2010. Program Environmental Impact Report for the Plan Santa Barbara General Plan Update. https://santabarbaraca.gov/sites/default/files/documents/General Plan/Certified Final Program Environmental Impact Report/Volume I.pdf. Accessed October 2023.
67 Santa Barbara, City of. 2020. Municipal Code Chapter 9.16. Noise. https://library.qcode.us/lib/santa_barbara_ca/pub/municipal_code/item/title_9-chapter_9_16. Accessed October 2023 City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
92 Assessment Guidelines for Greenhouse Gas Emissions Analysis would not generate excessive noise levels and, therefore, would result in a less-than-significant impact related to noise exposure.

LESS-THAN-SIGNIFICANT IMPACT
b. Would the project result in generation of excessive groundborne vibration or groundborne noise levels?
While people have varying sensitivities to vibrations at different frequencies, in general they are most sensitive to low-frequency vibration. Vibration in buildings, such as from nearby construction activities, may cause windows, items on shelves, and pictures on walls to rattle. Vibration of building components can also take the form of an audible low-frequency rumbling noise, referred to as groundborne noise.68 Although groundborne vibration is sometimes noticeable in outdoor environments, it is almost never annoying to people who are outdoors. The primary concern of vibration is that it can be intrusive and annoying to building occupants and vibration-sensitive land uses.

Vibration amplitudes are usually expressed in peak particle velocity (PPV) or Root Mean Square (RMS) vibration velocity. The PPV and RMS velocity are normally described in inches per second (in/sec). PPV is defined as the maximum instantaneous positive or negative peak of a vibration signal. PPV is often used in monitoring of blasting vibration because it is related to the stresses that are experienced by buildings.69 Vibration significance ranges from approximately 50 vibration decibels (VdB), which is the typical background vibration-velocity level, to 100 VdB, the general threshold where minor damage can occur in fragile buildings.70 The general human response to different levels of groundborne vibration velocity levels is described in Table 6.

Table 6 Human Response to Different Levels of Groundborne Vibration Vibration Velocity Level Human Reaction
65 VdB Approximate threshold of perception for many people 75 VdB Approximate dividing line between barely perceptible and distinctly perceptible. Many people find that transportation-related vibration at this level is unacceptable. 85 VdB Vibration acceptable only if there are an infrequent number of events per day VdB = vibration decibels
Source: Federal Transit Administration. Transit Noise and Vibration Impact Assessment Manual. 2018.71 Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would not result in construction or operational impacts related to groundborne vibration.

The CAP Update is a policy document containing measures that are consistent with the General Plan. Some of the measures and actions would support construction projects, such as electric 68 California Department of Transportation (Caltrans). 2013. Transportation and Construction Vibration Guidance Manual (CT-HWANP-RT13-069.25.3). <http://www.dot.ca.gov/hq/env/noise/pub/TCVGM_Sep13_FINAL.pdf>. Accessed October 2023. 69 Federal Highway Administration (FHWA). 2006. Highway Construction Noise Handbook. (FHWAHEP-06-015; DOT-VNTSC-FHWA-06-02). <http://www.fhwa.dot.gov/environment/construction_noise/handbook>. Accessed October 2023. 70 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual. <https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibration-impact-assessmentmanual-fta-report-no-0123_0.pdf>. Accessed October 2023. 71 Federal Transit Administration. 2018. Transit Noise and Vibration Impact Assessment Manual. <https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibration-impact-assessmentmanual-fta-report-no-0123_0.pdf>. Accessed October 2023.

Environmental Checklist
Noise
Draft Initial Study – Negative Declaration 93
vehicle charging station construction that may result in a temporary increase in groundborne vibration. However, future projects would be subject to review by the City for compliance with the General Plan and Municipal Code and would be required to comply with applicable local, State, and Federal regulations. Additionally, due to the small scale of the projects included in the measures and actions, major ground disturbing equipment is unlikely to be used, thus minimizing instances of groundborne vibration. Therefore, the CAP would result in a less-than-significant impact related to groundborne vibration.

LESS-THAN-SIGNIFICANT IMPACT
c. For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
The Santa Barbara Airport’s 65 dBA CNEL noise contour extends approximately 3,000 feet to the east of the airport; however, the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis and the CAP Update do not propose new residential uses within this noise contour. Therefore, any development that would occur immediately surrounding the Santa Barbara Airport is outside of the scope of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis and the CAP Update, and no residential development would be located within the Airport’s 65 CNEL noise contour. Although aircraft overflights have the potential to expose people residing or working in the City to aircraft noise, this intermittent and temporary noise disturbance is present under existing conditions., Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would not result in noise exposure impacts related to airports, airstrips, or helicopters. The CAP Update does not propose land use or zoning changes related to airports, airstrips, or heliports, nor does it include development that would increase exposure to excessive noise levels associated with operation of airports, airstrips, or heliports. and implementation of the GHG Emissions. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss impacts related to aviation-related noise exposure would be less-than-significant.

LESS THAN SIGNIFICANT IMPACT
City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
94 Cumulative Impacts
The cumulative projects scenario is total projected population growth Santa Barbara (96,637 persons) in 2030. The CAP Update is a policy document containing measures and actions that are consistent with the City of Santa Barbara General Plan. Some of the measures would support construction projects, such as electric vehicle charging station construction, which may result in a temporary increase in groundborne vibration or noise levels. However, cumulative projects, including the CAP Update, would be subject to review by the City for compliance with the General Plan and Municipal Code and would be required to comply with applicable State and federal regulations. Additionally, the CAP Update encompasses a suite of GHG-reduction opportunities that would decrease traffic and traffic-related noise. As such, implementation of the CAP Update would not generate excessive groundborne vibration or noise levels. Therefore, the CAP Update would result in a less-thansignificant cumulative impact related to noise.

LESS-THAN-SIGNIFICANT IMPACT
Environmental Checklist
Noise
Draft Initial Study – Negative Declaration 95
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City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
96 14 Population and Housing
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
Would the project:
a. Induce substantial unplanned population
growth in an area, either directly (e.g., by
proposing new homes and businesses) or
indirectly (e.g., through extension of
roads or other infrastructure)? □ □ □ ■
b. Displace substantial numbers of existing
people or housing, necessitating the
construction of replacement housing
elsewhere? □ □ □ ■
a. Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
or
b. Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would not result in construction or operational impacts related to substantial unplanned population growth. Likewise, the CAP Update does not include measures or actions that would increase the population or induce additional population growth that would displace people or housing. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in no impact related to population and housing.

NO IMPACT
Cumulative Impacts
The cumulative projects scenario is total projected population growth for Santa Barbara (96,637 persons) in 2030. Cumulative projects, including the CAP Update, are not anticipated to displace people or housing nor induce substantial unplanned population growth in the City. Specifically, the CAP Update would not contribute to person or housing displacement in the City of Santa Barbara nor result in population growth beyond that already assumed and planned for in the General Plan.

Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in no cumulative impact related to population and housing.

NO IMPACT
Environmental Checklist
Population and Housing
Draft Initial Study – Negative Declaration 97
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City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
98 15 Public Services
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
a. Would the project result in substantial
adverse physical impacts associated
with the provision of new or physically
altered governmental facilities, or the
need for new or physically altered
governmental facilities, the construction
of which could cause significant
environmental impacts, in order to
maintain acceptable service ratios,
response times or other performance
objectives for any of the public services:
▪ Fire protection? □ □ □ ■
▪ Police protection? □ □ □ ■
▪ Schools? □ □ □ ■
▪ Parks? □ □ □ ■
▪ Other public facilities? □ □ □ ■
a. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered facilities, or the need for new or physically altered facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for:
▪ Fire protection;
▪ Police protection;
▪ Schools;
▪ Parks; or
▪ Other public facilities?
Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would not result in construction or operational impacts related to public services. The CAP Update is a policy document containing measures and actions that are consistent with the Santa Barbara General Plan. Implementation of the CAP Update would not result in increases in population or induce additional population growth. As such, the CAP Update would not require the construction of new or physically altered governmental facilities to serve additional population, the construction of which could cause significant environmental impacts. Furthermore, future projects identified as measures/actions in the CAP Update would be reviewed for consistency with the City of Santa Barbara General Plan and other applicable local and State regulations.

Environmental Checklist
Public Services
Draft Initial Study – Negative Declaration 99
Nonetheless, implementing the CAP Update would require some modification of existing policies, including developing and implementing new programs and projects, or modifying existing ones. The CAP Update is designed to reduce adverse environmental impacts associated with climate change.

While modifications of existing policies are needed, the measures and actions included in the CAP Update would not result in increases in population or induce additional population growth that would result in the provision of new or physically altered governmental facilities or the need for new or physically altered governmental facilities. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in no impact related to public services in terms of need for the construction of new or altered governmental facilities.

NO IMPACT
Cumulative Impacts
The cumulative projects scenario is total projected population growth for Santa Barbara (96,637 persons) in 2030. Implementation of cumulative projects, including the CAP Update, would not result in increases in population or induce additional population growth beyond that assumed under the City of Santa Barbara General Plan. Therefore, implementation of the CAP Update would not result in substantial cumulative need to expand public services facilities. Therefore, the CAP Update would result in no cumulative impact related to public services.

NO IMPACT
City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
100
16 Recreation
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
a. Would the project increase the use of
existing neighborhood and regional parks
or other recreational facilities such that
substantial physical deterioration of the
facility would occur or be accelerated? □ □ □ ■
b. Does the project include recreational
facilities or require the construction or
expansion of recreational facilities which
might have an adverse physical effect on
the environment? □ □ □ ■
a. Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
b. Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? Recreational amenities in Santa Barbara include approximately 1,827 acres of park land comprised of passive parks, neighborhood parks, community parks, regional parks, beach parks, open space parks, and sports fields.72 Many of these parks include indoor and outdoor facilities that provide or host adult classes, aquatics, camps, outdoor picnics, weddings, photo shoots, and special events.

City Parks and Recreation charges use fees that fund Parks staff and maintenance crews to ensure the facilities do not deteriorate.

Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would not result in construction or operational impacts related to neighborhood or regional parks. The CAP Update is a policy document containing programs that are consistent with the Santa Barbara General Plan. Additionally, the CAP Update would not result in substantial population growth or direct land use changes. As such, implementation of the CAP Update would not result in a substantial physical deterioration of parks or other recreational facilities or result in the need to expand recreational facilities. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in no impact related to the need for construction of new or altered recreational facilities.

NO IMPACT
72 Santa Barbara, City of. 2022. Resources Inventory.
https://sbparksandrec.santabarbaraca.gov/sites/default/files/documents/Parks%20%26%20Recreation/Parks%20%26%20Recreation/Par ks%20and%20Recreation%20Resources%20Inventory.pdf. Accessed October 2023.

Environmental Checklist
Recreation
Draft Initial Study – Negative Declaration 101
Cumulative Impacts
The cumulative projects scenario is total projected population growth for Santa Barbara (96,637 persons) in 2030. Implementation of cumulative projects, including the CAP Update, would not result in increases in population or induce additional population growth beyond that assumed under the General Plan. In addition, the CAP Update would not result in population growth or direct land use change. Therefore, implementation of the CAP Update would not result in substantial cumulative physical deterioration of parks or other recreational facilities or result in the cumulative need to expand recreational facilities. Therefore, implementation of the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in no cumulative impact related to recreation.

NO IMPACT
City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
102
17 Transportation
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
Would the project:
a. Conflict with a program, plan, ordinance
or policy addressing the circulation
system, including transit, roadway,
bicycle and pedestrian facilities? □ □ ■ □
b. Conflict or be inconsistent with CEQA
Guidelines section 15064.3, subdivision
(b)? □ □ ■ □
c. Substantially increase hazards due to a
geometric design feature (e.g., sharp
curves or dangerous intersections) or
incompatible use (e.g., farm equipment)? □ □ ■ □
d. Result in inadequate emergency access? □ □ ■ □
a. Would the project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? b. Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Transportation issues are addressed in adopted City, County, State and federal plans, policies and regulations. Within the City, primary responsibility for these issues is addressed in the City’s General Plan and Municipal Code as administered by the City’s Public Works and Community Development Departments. In 2011, the City Council adopted Plan Santa Barbara, which included a readoption of the 1997 Circulation Element and new 2011 Circulation Element policies. The comprehensive goal and vision of the 2011 Circulation Element is: “While sustaining or increasing economic vitality and quality of life, Santa Barbara should be a city in which alternative forms of transportation and mobility are so available and attractive that use of an automobile is a choice, not a necessity.” Supporting transportation planning documents include the Pedestrian Master Plan (2006), Bicycle Master Plan (2016) and Vision Zero Strategy (2018), which aims to eliminate all severe injuries and fatalities on the City’s road network. There are also neighborhood specific transportation management plans (NTMP) focusing on neighborhood livability by improving the active transportation network. Examples of neighborhood plans include Eastside NTMP (2013), Westside and Lower West NTMP (2020), Cliff Drive Vision Zero Planning Effort (2022) and Milpas Street Corridor (2020/2022).

The City embraces a policy direction to make Santa Barbara a place where bicycling and walking are encouraged and fostered, and where safety, education and facilities are provided as an ongoing part of transportation and recreational planning and programs. While allowing people to circulate without cars is an emphasis of the Circulation Element, another emphasis is getting people to share Environmental Checklist
Transportation
Draft Initial Study – Negative Declaration 103
rides and reduce the number of vehicular trips. The CAP transportation measures are consistent with the Circulation Element, which includes several policies regarding alternative forms of transportation. Such policies include themes such as reducing dependence on automobiles, improving pedestrian and bicycle use, enhancing alternative transportation services and infrastructure, achieving equality of convenience among transportation options, developing urban design standards that facilitate alternative transportation, increasing regional transit services, designating a Bicycle Coordinator, expanding Transportation Demand Management programs, and educating residents on alternative forms of transportation.

In addition, SBCAG is required by State and federal law to prepare, update, and adopt a Regional Transportation Plan (RTP) every four years. The most recent update to the RTP was completed by SBCAG in 2021 (Connected 2050) and sets forth long-range transportation planning goal describing how the region will meet its transportation needs for the 30-year period from 2020 to 2050.

Connected 2050 provides a collective vision for the region's future that balances transportation and housing needs with social, economic, and environmental goals. Connected 2050 helps guide future planning efforts and policy decisions that affect transportation, including its relationship with housing and land use, with the goal to reduce regional greenhouse gas emissions. Connected 2050 is based, in part, on SBCAG’s Regional Growth Forecast which projects population and employment data to 2050. SBCAG designates RHNA allocations based on the Regional Growth Forecast.

Connected 2050 includes five goal areas – Environment, Mobility & System Reliability, Equity, Health & Safety, and Prosperous Economy – with respective policies to meet each goal areas, which are expected to result in significant benefits to the region, not only with respect to transportation and mobility, but also economic activity, safety, and social equity. Policies in Connected 2050 applicable to the CAP Update address land use, circulation, alternative transportation, affordable housing, and safe roads and highways.

Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysiss would not result in construction or operational impacts related to conflict with a program, plan, ordinance, or policy addressing the transportation circulation system. The CAP Update is a policy document containing measures and actions that are consistent with the City General Plan Circulation Element, with many that are aimed at facilitating the implementation of the local transportation programs and improvements.

Implementation of some of the measures and actions included in the CAP Update may require future infrastructure development or improvements, such as bike paths and lockers. However, projects would be subject to review by the City for compliance with the General Plan and be required to comply with applicable local, State, and Federal regulations. Additionally, the projects included in the measures and actions support decreasing vehicle miles traveled by encouraging alternative forms of transportation and the development of related infrastructure, thus reducing total GHG emissions from transportation throughout the City. This reduction in vehicle miles traveled supports the City’s 2021 updated Environmental Thresholds and Guidance Manual, which provides guidelines and standards for vehicle miles traveled for residential, employment, and retail projects.73 Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in less-than-significant impact related to consistency with plans addressing the transportation circulation system. 73 Santa Barbara, County of. Planning and Development. Environmental Thresholds and Guidelines Manual. 2021. https://cosantabarbara.app.box.com/s/vtxutffe2n52jme97lgmv66os7pp3lm5. Accessed 2024.

City of Santa Barbara
City of Santa Barbara Climate Action Plan Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis
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LESS-THAN-SIGNIFICANT IMPACT
c. Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible use (e.g., farm equipment)? d. Would the project result in inadequate emergency access? Implementation of the Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would not result in construction or operational impacts related to risk associated with transportation design or features. The CAP Update is a policy document containing measures and supporting actions that are consistent with the City General Plan and would not facilitate development beyond that allowed under the General Plan. The CAP measures and supporting actions included in Table 3 would promote active transportation, ridership, and sustainable transportation practices within the community to enhance bicycle, pedestrian, and transit connectivity. The development of alternative transportation infrastructure would occur in a manner that complies with existing city guidelines and ordinances and would not be designed or developed in a way that increase hazards or cause inadequate emergency access.

The CAP Update does not include measures and actions that would substantially increase transportation hazards due to a design feature or incompatible land uses. Furthermore, projects would be reviewed for consistency with the Santa Barbara General Plan and other applicable local and State regulations. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant impact related to transportation hazards and emergency access.

LESS-THAN-SIGNIFICANT IMPACT
Cumulative Impacts
The cumulative projects scenario is total projected population growth for Santa Barbara (96,637 persons) in 2030. The CAP Update is a policy document containing measures and actions that are consistent with the City’s General Plan, and, similar to the other cumulative projects, the CAP Update does not propose development beyond that anticipated under the General Plan that would require transportation facilities. The measures and actions included in the CAP Update promote alternative modes of transportation and reduction of the amount of vehicle miles traveled throughout the City. In addition, the CAP Update measures and actions would not conflict with the objectives and policies of the General Plan but would rather be consistent with and promote those plans. Therefore, the CAP Update and Master Environmental Assessment Guidelines for Greenhouse Gas Emissions Analysis would result in a less-than-significant cumulative impact related to transportation.

LESS-THAN-SIGNIFICANT IMPACT
Environmental Checklist
Tribal Cultural Resources
Draft Initial Study – Negative Declaration 105
18 Tribal Cultural Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-thanSignificant
Impact No Impact
Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in a Public Resources Code Section 21074 as either a site, feature, place, or 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
Resources Code Section 5024.1, the lead
agency shall consider the significance of
the resource to a California Native
American tribe. □ □ ■ □
a. Would the project cause a substantial adverse change in the significance of a tribal cultural resource as defined in Public Resources Code Section 21074 that is 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)?
b. Would the project cause a substantial adverse change in the significance of a tribal cultural resource as defined in Public Resources Code 21074 that is 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? The Santa Barbara region was favorable to Native American settlement and the City contains known archaeological sites and areas of archaeological sensitivity. There is the potential to encounter previously unidentified archaeological resources on sites that may be developed with residential uses under the CAP Update. While the City is largely developed with few vacant parcels, undeveloped properties have a higher probability of containing previously unidentified archaeological resources given the probable lack of previous ground-disturbing activities on these properties. However, ground disturbance into native (previously undisturbed) soils on any development site could encounter previously undiscovered prehistoric or historic-period resources.