Santa Cruz City Council
April 26, 2022

ASSIGNMENT/SCOPE OF SERVICES
Development plans for a multiple residential building and associated access and parking areas are proposed for vacant land located 415 Natural Bridges Drive. The Housing Authority of Santa Cruz County retained me to evaluate the health, structural stability and suitability of the seven trees on the site.

I have completed the following scope of services to complete the impact analysis. • Review site plans prepared by Thacher & Thompson Architects. • Locate number and map seven trees growing on the site • Identify trees as to species and measure trunk diameter at 54 inches above grade. • Visually inspect each tree to evaluate health status, structural integrity and suitability for incorporation into the development project. • Rate each tree as “good”, “fair”, or “poor” based on overall condition and species tolerances.
• Determine the Critical Root Zone areas based on trunk diameter and tree condition.
• Prepare a protection plan and provide recommendations for tree removal/retention based on construction impacts or overall condition.

SUMMARY
I have completed a visual assessment of seven individual trees growing on undeveloped property located at 415 Natural Bridges Drive. Acacia is the dominant species on the site, one coast live oak, one tulip tree and one walnut are growing on the site. A mature cedar tree is growing on the northern property boundary.

The development plans have been reviewed and impacts to the trees have been analyzed.

The attached inventory includes specific impacts and recommendations for protecting the trees.

Tree removal will be necessary to develop the property as proposed. The trees are generally in poor condition and six trees will require removal. The mature cedar will be retained and protected during development.

Five of the trees meet the definition of “heritage” as stated in the City of Santa Cruz ordinance (9.56). Four “heritage” size trees are proposed for removal. I recommend planting replacement trees within the new landscape and parking areas.

25.60 Tree Resource Evaluation/Project Impact Analysis
Undeveloped Land/415 Natural Bridges Drive
June 2021

TREE INVENTORY OVERVIEW
To complete the inventory and assessment of trees on this project site, I made two site visits in May and June of this year. The tree locations are documented on the attached site plan and correspond with the data in the inventory spreadsheet. The inventory includes the following information for the trees on this undeveloped site:

Tree Number
Tree locations are documented on the attached site plan prepared by Thacher & Thompson Architects.

Tree Species
The inventory indicates the “common” name for each tree. The botanical names of the trees in the project boundaries are listed here:
• Coast live oak (Quercus agrifolia)
• Acacia (Acacia baileyana)
• Deodar cedar (Cedrus deodara)
• Walnut (Juglans sp.)
• Tulip (Liriodendron tulipifera)
Trunk Diameter
The diameter of each trunk/trunks was measured at a point 54 inches above natural grade (DBH) using a diameter tape. Trees greater than 14 inches in diameter qualify as “heritage” trees within the City of Santa Cruz.

Tree Condition
The trees were visually inspected to evaluate health status and structural integrity. This type of assessment includes an evaluation of the biology and mechanics of each tree based on the visual analysis procedures developed by Claus Mattheck published in The Body Language of Trees. The health and structure of the tree is then rated as “good”, “fair”, or “poor” in the attached inventory.

The biological assessment determines health status and includes an evaluation of the following:
• Vitality of the leaves, bark and twigs
• Presence of fungi or decay
• Percentage and size of dead branching
• Status of old wounds or cavities.

25.61 Tree Resource Evaluation/Project Impact Analysis
Undeveloped Land/415 Natural Bridges Drive
June 2021

Healthy trees rated as “good” display dense full canopies with dark green foliage. Dead branching is limited to small twigs and branches less than one inch in diameter. No evidence of disease, significant decay or inspect activity is visible. Vigorous, health trees are much better able to tolerate site alteration and invasive construction impacts than less vigorous trees of the same species.

Trees in “fair” health have 10-30% foliar dieback, small areas of dead branching greater than one inch in diameter and minor evidence of disease, decay or insect activity.

Trees in “poor” health display greater than 30% foliar dieback, dead branches greater than two inches in diameter and/or areas of decay, disease or insect activity.

Trees that contain dead branching, decayed areas or other structural defects that cannot be mitigated are not suitable for preservation on developed sites and should not be retained in areas where improvements are proposed.

Tree health and tree structure are evaluated separately. A “healthy” tree can be weakly structured and represent a risk; a well-structured tree can be “unhealthy” or in poor vigor.

Impact Rating
Trees rated as having low impact potential are outside the development area, but require the protection provided by exclusionary fencing.

Trees rated as having a moderate impact potential are within 10 to 15 feet of excavation, grade changes or demolition activities. Fencing in combination with straw bale barricades are recommended to protect these trees.

Trees rated as having a high impact potential have excavation, grade changes or other site alterations proposed within the Critical Root Zone. Trees in these areas may be subjected to alternative construction methods or special treatments (manual grading or special construction methods) and require fencing and straw bale barricades to create a defined exclusion zone. Monitoring of all activities adjacent to, or within, the CRZ will be required.

In some circumstances using alternative methods cannot reduce impacts and tree removal becomes necessary. Excavation that removes structural roots can destabilize the tree and lead to failure.

Critical Root Zone (CRZ)
The “Critical Root Zone” is the optimum rooting area around a single tree or group of trees in which no grading or construction activity should occur. The zone should be large enough to retain sufficient root and crown area to maintain tree health and stability. The size of this zone depends on a number of factors (Matheny, Clark & Harris 1999).

25.62 Tree Resource Evaluation/Project Impact Analysis
Undeveloped Land/415 Natural Bridges Drive
June 2021

This optimum area is based on the British Standards Institute (BS5837:1991 and BS 5837:2005). This method is based on ranges in tree diameter, tree age and vigor.

The CRZ does not always represent a radius around the tree. When necessary the area can be offset or shaped in a manner that accepts tree canopy constraints or existing conditions.

Comments/Recommendations
Recommendations for tree removal/retention are listed here.

PROJECT DESCRIPTION
The project includes the development of a single structure with multiple dwellings, associated landscape, paved access and parking areas.

OBSERVATIONS
Site Description
The site is an undeveloped property bordering a public street with commercial structures and rail road access.

Tree Description
The cedar tree is healthy and well structured. It is standing at the northern property boundary, straddling the property boundaries (pictured at right).

Tree #2, a coast live oak is growing near the center of the vacant property. Although the canopy appears healthy, the tree has been under attack by oak bark beetles for a long period of time. In addition, the main trunk is decayed in several areas (pictured below).

25.63 Tree Resource Evaluation/Project Impact Analysis
Undeveloped Land/415 Natural Bridges Drive
June 2021

The three acacia are in various stages of decline with thinning canopies. Acacia as a species have been defined as “invasive” by the Invasive Plant Council. The negative species characteristics have been documented as the following:
• Copious seed spread
• Displacement of native plants
• Increased fuel loads
Construction Impacts
The impacts to trees on this site have been rated from moderate (tree #1) to high. The six remaining trees are growing within the footprint of the proposed residential structure of access roadway and will require removal.

CONCLUSION
I recommend the installation of replacement trees within the proposed landscape and parking areas (if possible).

The project will require the removal of six trees that are generally in poor condition. Tree #1, the cedar will be retained and protected by exclusionary fencing and straw bale barricades.

Any questions regarding the trees on this site or the content of this report can be directed to my office.

Respectfully submitted,
Maureen Hamb- Certified Arborist WE2280

25.64 Housing Authority
415 Natural Bridges Drive
Highlighted Cells Indicate “Heritage” Trees 1
Tree # Species Diameter
@ 54" Condition Impact Description
Impacts: High
Moderate Low
Critical Root
Zone Radius
in feet
Comments/Recommendations
1 cedar 24.9 good landscaping
area
moderate 12
Healthy, well structured tree growing on the northern
property/Limit plantings within the CRZ. Protect root zone with fencing and straw bale barricades
2 coast live
oak 21.8 poor within building footprint high 11
Damage and oak bark beetles have infested the trunk.

Growing within the proposed building footprint/Remove
due to impacts
3 tulip 37.5 poor within building
footprint high 18
Foliar canopy is 80% dead. Growing within proposed
building footprint./Remove due to tree condition and
impacts.
4 acacia 14.4 poor
within
proposed
driveway
high 7 Leaning structure, thinning lower canopy. Growing within proposed driveway access/Remove due to impacts
5 acacia 15 poor
within
proposed
driveway
high 8 Significant decay at base of trunk. Growing within proposed driveway/Remove due to condition and impacts
6 acacia double poor
within
proposed
driveway
high 8
Two main trunks with weak structural attachments and
thinning canopy. Growing within proposed
driveway/Remove due to impacts
7 walnut 13 poor
at edge of
proposed
driveway
high 12 Sensitive species that cannot tolerate impacts/Remove due to impacts

25.65 N O R T H
34" TREE
36" ACACIA
14" ACACIA

LOADING DOCK
S83°27'22"W 125.19' 87.51'
125.00' 94.39'
EVCS
5 BIKE RACKS

EXISTING BUILDING

TODAL FITNESS

EXISTING CITY CURB,

GUTTER AND SIDEWALK N A T U R A L B R I D G E S D R I V E SITE PLAN 1 SCALE: 1/8"=1'-0"

SOUTHERN PACIFIC RAILWAY
ACCESS

PROPOSED BUILDING
24'-0"
31'-0"

EXISTING

PROPERTY LINE

PROPOSED

PROPERTY LINE
NEW 6' HIGH

WALL OR FENCE

EXISTING TODAL

FITNESS PARKING LOT

SOUTHERN PACIFIC

RIGHT OF WAY

SOUTHERN PACIFIC

RIGHT OF WAY

CONCRETE WALK

COVERED ENTRY
TRASH/
RECYCL

DOOR TO
STOR. LOCKERS

SIDE ENTRY

LANDSCAPING

EXISTING TREE

TO REMAIN
38"
TREE
22"
OAK
STUMP 14'-0"
6' HIGH CONC. BLK AND

PAINTED STUCCO WALL
23'-8"
2'-6" PLANTING
STRIP
19'-0"
STD
CONC. DRIVEWAY
CONC. DRIVEWAY
ACCESSIBLE PATH 5'-0" 4'-0"

COM COM

EXISTING CURB
COM 12' 24' 5'-0"
NEW 6' HIGH
WALL OR FENCE 17'-0"
7'-6"
COM 12'-0"
STD
STD
STD
ACCESS
AISLE 8'-6"
STD
ACCESS
AISLE14'-0" 8'-2"
5' HIGH

PRIVACY
FENCE
7' x 8' CONC. PATIO

DOOR TO
STOR. LOCKERS
8' x 11' CONC. PATIO 5'-0"
METERS
4'-0"
NEW 6' HIGH

WALL OR FENCE

EXISTING TODAL

FITNESS PARKING LOT
A2
UNAUTHORIZED USE IS PROHIBITED. LIABILITY TO THE ARCHITECT. BE THE USER'S RESPONSIBILITY WITHOUT ELECTRONIC TRANSFER OF DATA SHALL CONSENT OF THE ARCHITECT. THE PROPER

REPRODUCED, OR USED WITHOUT THE
SERVICE AND MAY NOT BE ALTERED, ARCHITECTS. IT IS AN INSTRUMENT OF THE PROPERTY OF THACHER & THOMPSON

THE DATA CONTAINED ON THIS SHEET IS

THACHER &

THOMPSON
ARCHITECTS HOUSING AUTHORITY OF 415 NATURAL BRIDGES DRIVE, SANTA CRUZ, CA 95060 PRELIMINARY NOT FOR CONSTRUCTION C 12725

THOMAS THACHER
DECEMBER 31, 2021

EXPIRATION
215 OREGON STREET
SANTA CRUZ, CA 95060
(831) 566-3079
www.tntarch.com
c 2020 THACHER & THOMPSON ARCHITECTS

DRAWING DATE
MAY 6, 2021

ISSUED TO FACILITATE
CONSTRUCTION:

DATE PENDING
PROJECT FILE NAME:

NAT.BRIDGES 20.SD LICENSED ARCHITECTSTATE OF CALIFORNIA SANTA CRUZ COUNTY

25.66 415 Natural Bridges Drive
Environmental Review -1- February 2022
City of Santa Cruz

E N V I R O N M E N T A L C H E C K L I S T

FOR DETERMINATION OF CEQA EXEMPTION
I. BACKGROUND

1. Application No: CP21-0059

2. Project Title: 415 Natural Bridges Drive Project

3. Lead Agency Name and Address:

City of Santa Cruz Planning and Community Development Department 809 Center Street, Room 101
Santa Cruz, CA 95060

4. Contact Person and Contact Information:

Clara Stanger, Senior Planner
(831) 420-5247; [email protected]

5. Project Location: 415 Natural Bridges Drive (APN 003-011-06); see Figure 1.

6. Project Applicant / Sponsor Name and Address:

Tom Thacher, 877 Cedar Street #248, Santa Cruz, CA 95060 Owner: Housing Authority of the County of Santa Cruz, 2160 41st Avenue, Capitola, CA 95010

7. General Plan Designation: Low Medium Density Residential (LM), Community Facilities (CF)

8. Zoning: Multiple Residences (R-L) / Coastal Zone Overlay (CZ-O) / Shoreline Protection Overlay (SP-O)/PF (Public Facilities)

9. Other Public Agencies Whose Approval is Required: None known

10. Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.31? No
II. PROJECT DESCRIPTION
Proposed Uses and Site Plan. The proposed project consists of a Lot Line Adjustment, Planned Development Permit, Design Permit, and Coastal Permit to transfer land to/from APN 003- 011-10 and construct a 100% affordable, 20-unit Single Room Occupancy (SRO) project. The

25.67 415 Natural Bridges Drive
Environmental Review -2- February 2022
project requests a variation to allowed uses in the R-L zone to allow an SRO use and variations to development standards for building height, side yard setback, and number of required parking spaces that will be reviewed and approved through the Planned Development Permit.

This project involves the removal of four heritage trees. The project is proposed as an 100% affordable housing project, and units would be available to very-low income households.

As shown on Figure 2, the proposed site plan includes a rectangular-shaped building. The proposed building would be three levels and cover 10,519 gross square feet. The 20 living units would occupy a total of 6,791 square feet, and residential units would be located on all three levels. The three-story building is proposed to be 36 feet high from grade to top of the third-floor parapet. Common areas include a lobby, common area room, laundry room, and third floor deck, would occupy a total of 720 square feet. The building would also have 20 private storage units for its residents.

The proposed lot line adjustment would transfer 4,054 square feet of property from APN 003- 011-10 to the west of the project site that is approximately 2.8 acres in size. This would result in the project being located on a 15,423-square foot lot; see Figure 3 for the proposed lot line adjustment. The land area subject to the lot line adjustment is currently used for parking and would continue to be used for parking as part of the proposed project.

Access and Parking. Access to the project site would be provided from a new driveway running along the southern perimeter of the site to and from Natural Bridges Drive. A total of 12 parking spaces are proposed for the development. Five spaces would be compact stalls, six standard stalls, and one would be ADA accessible. The project includes frontage improvements along Natural Bridges Drive per City standards, including sidewalks.

The project would be enclosed by a new six-foot wall or fence around the northern, southern, and eastern perimeters of site. Bicycle parking for residents would be made available through the 20 private storage units within the building. Five additional bicycle parking spaces for residents and visitors would be made available via a new outdoor bicycle rack. Resident access to and from the building would be provided through new paved sidewalks along the northern and southern portions of the site to a main building entrance and side building entrance.

Landscaping. The project would involve the removal of four heritage trees, as defined by the City’s Heritage Tree Ordinance. The project would be landscaped with three new myrtle trees along the site’s Natural Bridges Drive street frontage. Several other landscape plants and groundcover are proposed along the perimeter of project’s parking lot and within the project’s front yard setback area. The project would be subject to provisions of the City’s Water Efficient Landscape Ordinance (WELO), per Chapter 16.16 of the City’s Municipal Code.

Stormwater. The project would create a total 10,392 square feet of paved impervious surface. Stormwater would be controlled with a new storm drain system and several Low Impact Development (LID) methods outlined in the project’s Stormwater Management Plan.

These include limiting potential disturbance to natural drainage features, limiting clearing and

25.68 415 Natural Bridges Drive
Environmental Review -3- February 2022
grading of native vegetation, and implementing Best Management Practices (BMPs) that would minimize stormwater runoff. The project proposes to install a bioretention mechanical filtration system that would be located in the front yard setback area. The project site is designed so that stormwater would collect into this system. Stormwater would be filtered through this system before it is discharged from the site.

Construction Schedule and Earthwork. Construction would be expected to occur over approximately one year with excavation of the site taking approximately one month. The net earth material would be balanced on site; approximately 150 cubic yards (cy) of earth material would be cut form the site and approximately 150 cy of earth material would be filled.

Therefore, there would be no excess excavated earth material no hauling of earth material on or off site is anticipated.

III. ENVIRONMENTAL SETTING
The approximately 0.35-acre (15,305-square-foot) project site is located at 415 Natural Bridges Drive, north of Delaware Avenue in the western portion of the City. . The project site is located within the coastal zone, approximately 0.60-mile north of the Pacific Ocean. The project is bordered by Natural Bridges Drive and developed commercial uses on north, east, and west. Adjacent commercial uses include office buildings directly to the north and east and a fitness club/gymnasium directly to the west. The project site is bordered by an inactive rail line and the Santa Cruz Coastal Rail Trail to the south. Across the rail line and trail, is a property owned by the University of California Santa Cruz (UCSC) that is used for parking lot and tennis courts. Natural Bridges State Beach and Visitor Center is approximately 0.25-miles south of the site. This area is characterized by a residential development and visitor-serving open space amenities including parking, trails, and beach access.

The project site is currently split between two parcels (APNs 003-011-06 and 003-011-10).

Under the project, a lot line adjustment would enlarge APN 003-011-06 by 4,054 square feet to accommodate parking needs of the proposed project. Currently, the eastern lot (APN 003- 011-06) is a vacant lot with grass and six trees; the western lot (APN 003-011-10) currently is developed with a fitness club and gymnasium. The portion that would be transferred to the project lot is currently paved parking for gym members and employees.

The project is relatively flat with existing onsite elevations varying between approximately 73 feet above mean sea level (MSL) on the northwest portion of the site to approximately 71 feet MSL on the southeast portion of the site. Slopes on site generally vary between 0.5% and 1% from northwest to southeast.

As noted above, a total of six existing trees of various conditions are located on the project site, of which four are heritage trees pursuant to City regulations (SOURCE V.101):
• 3 arcadia (Acacia baileyana)
1 All cited sources/references are identified in Section V at the end of this document.

25.69 415 Natural Bridges Drive
Environmental Review -4- February 2022
• 1 deodar cedar (Cedrus deodara)
• 1 coast live oak (Quercus agrifolia)
• 1 tulip (Liriodendron tulipifera)
F I G U R E 1 : Project Location

Source: Adapted from Patricia Paramoure Archaeological Consulting 2021.

25.70 415 Natural Bridges Drive
Environmental Review -5- February 2022
F I G U R E 2 : Site Plan
Source: Adapted from Thacher and Thompson Architects 2021.

25.71 415 Natural Bridges Drive
Environmental Review -6- February 2022
F I G U R E 3 : Proposed Lot Line Adjustment
Source: Adapted from Ifland Engineers 2021.

25.72 415 Natural Bridges Drive
Environmental Review -7- February 2022
IV. ENVIRONMENTAL CHECKLIST
A. Introduction and Background
In analyzing a proposed project, the City may consider whether existing environmental documents already provide an adequate analysis of potential environmental impacts. An earlier analysis may be used where, pursuant to tiering, program environmental impact report (EIR), or other California Environmental Quality Act (CEQA) provisions, if it can be determined that one or more effects have been adequately analyzed in an earlier EIR or negative declaration (State CEQA Guidelines section 15063(c)(3)(D)). If an earlier analysis is used, the Initial Study checklist discussion should identify: a) the earlier analyses and state where they are available for review; b) identify which effects were adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis; and c) describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project.

CEQA also allows a lead agency to avoid repeating analyses that were already provided in a certified General Plan EIR for a development project that is consistent with the General Plan.

Public Resources Code section 21083.3 and its parallel CEQA Guidelines provision, section 15183, provide for streamlined environmental review for projects consistent with the General Plan for which an EIR was certified. Pursuant to section 21083.3(b), if a development project is consistent with the general plan for which an environmental impact report was certified, the application of CEQA shall be limited to effects on the environment which are “peculiar to the parcel or to the project” and which were not addressed as significant effects in the prior environmental impact report, or which substantial new information shows will be more significant than described in the prior environmental impact report. Subsection (d) further indicates that an effect of a project upon the environment shall not be considered “peculiar to the parcel or to the project,” “if uniformly applied development policies or standards” have been previously adopted by the city or county, with a finding based upon substantial evidence, that the development policies or standards will substantially mitigate that environmental effect when applied to future projects, unless substantial new information shows that the policies or standards would not substantially mitigate the environmental effect. Under these provisions of CEQA, a project that is consistent with a General Plan that was adopted pursuant to a certified EIR, could be potentially partially or wholly exempt from further CEQA analyses.

Section 15183 of the State CEQA Guidelines provides further guidance related to Public Resources Code section 21083. Specifically, if a project is consistent with an agency’s General Plan for which an EIR has been certified, the agency shall limit its examination of environmental effects to those which the agency determines, in an initial study or other analysis:

25.73 415 Natural Bridges Drive
Environmental Review -8- February 2022
(1) Are peculiar to the project or the parcel on which the project would be located; (2) Were not analyzed as significant effects in a prior EIR on the zoning action, general plan, or community plan, with which the project is consistent; (3) Are potentially significant off-site impacts and cumulative impacts which were not discussed in the prior EIR prepared for the general plan, community plan, or zoning action; or
(4) Are previously identified significant effects which, as a result of substantial new information which was not known at the time the EIR was certified, are determined to have a more severe adverse impact than discussed in the prior EIR. (State CEQA Guidelines section 15183(b).)
Guidelines section 15183, subdivision (c) further provides that “if an impact is not peculiar to the parcel or to the project, has been addressed as a significant effect in the prior EIR, or can be substantially mitigated by the imposition of uniformly applied development policies or standards…then an additional EIR need not be prepared for the project solely on the basis of that impact.” “[D]evelopment policies or standards need not apply throughout the entire city or county, but can apply only within the zoning district in which the project is located…such policies or standards need not be part of the general plan or any community plan, but can be found within another pertinent planning document such as a zoning ordinance.” (Guidelines, § 15183, subd. (f).)
B. Use of Earlier Analyses
On June 26, 2012, the Santa Cruz City Council adopted the General Plan 2030 after certifying an EIR for the plan. The General Plan 2030 EIR includes the Draft EIR volume (September 2011) and the Final EIR volume (April 2012). The General Plan EIR reviewed all of the topics included on the Appendix G environmental checklist in the State CEQA Guidelines as well as all sections required to be included in an EIR.

The General Plan EIR is a “program” EIR prepared pursuant to State CEQA Guidelines Section 15168, which reviewed environmental impacts associated with future development and buildout within the City’s planning area that would be accommodated by the General Plan. A program EIR can be used for subsequent projects implemented within the scope of the program/plan. Typically, site-specific or new significant impacts that weren’t addressed in the program EIR would be evaluated in an Initial Study, leading to preparation of a Negative Declaration, Mitigated Negative Declaration, or EIR. Mitigation measures adopted for the General Plan also would be a part of future development projects, as relevant, and supplemented, as may be necessary, with any site-specific mitigation measures identified in the project-specific environmental review process.

As indicated above, pursuant to Public Resources Code section 21083.3, certain (or potentially all) aspects of a development project that are consistent with a General Plan for which an EIR was certified may be exempt from additional CEQA analyses (i.e., negative declaration,

25.74 415 Natural Bridges Drive
Environmental Review -9- February 2022
mitigated negative declaration, or EIR) of issues that were adequately covered in the General Plan EIR. The project site is designated Low Medium Density Residential (LM) in the City’s General Plan 2030 and is zoned Multiple Residences with Coastal Zone and Shoreline Protection Overlays (R-L/CZ-O/SP-O). The proposed residential project is consistent with the General Plan land use designation. According to the General Plan, this designation is intended to provide “…moderately higher densities in areas with a mix of single-family and multifamily residential uses. Accommodates a variety of residential building types that can fit within a single-family neighborhood, including low-rise apartments, condominiums, and townhomes.” Although the project’s General Plan Land Use designation of Low Medium Density Residential, prescribes a density limitation of 10.1 dwelling units per acre (du/acre) to 20 du/acre, the project is not subject to this maximum density limitation because General Plan Land Use Policy LU3.8 allows for certain residential uses (including SROs) to exceed maximum density limitations. Because the proposed project involves the development of exclusively SROs, the project would not be subject to maximum density limitations. Therefore, the proposed project residential densities would be considered consistent the City’s General Plan and General Plan 2030 EIR.

The 4,054-square foot area to be transferred to the project site with the proposed lot line adjustment is on an approximately 2.8-acre site that is designated as Community Facilities (CF) and zoned for Public Facilities. The area transferred to the project site is currently used as a parking lot and would continue to be used for parking, which is consistent with the existing General Plan designation on the site that would include parking areas to support permitted land uses.

While the General Plan 2030 EIR considered the impacts of repurposing, intensifying, and redeveloping existing developed parcels in the City as a whole, specific future development of the project site was not noted or specifically evaluated in the General Plan 2030 EIR, and there were no site-specific impacts identified for the project site. However, as part of the overall estimated buildout, the EIR considered construction of new housing units and nonresidential uses in the City with an estimated buildout of 3,350 new residential units and approximately 1,090,000 square feet of commercial uses throughout the City by the year 2030 (SOURCE V.1b, DEIR volume-page 3-13). Since adoption of the General Plan, approximately 1,925 residential units have been constructed or approved throughout the City. Thus, the proposed 20 residential units would be within the remaining residential buildout estimates considered in the city-wide General Plan EIR impact analyses.

The proposed project is located within the “Lower Westside” neighborhood area that was identified in the General Plan EIR for the purposes of evaluating potential growth. The General Plan EIR identified additional development in the Lower Westside to include 188 residential units. Since adoption of the General Plan, approximately 30 housing units have been constructed, are under construction, or have been approved in the Lower Westside area. The proposed project would not exceed the buildout estimates considered in the General Plan EIR for the Lower Westside area and, as discussed above, the project would be within city-wide buildout estimates in the General Plan EIR.

25.75 415 Natural Bridges Drive
Environmental Review -10- February 2022
C. Environmental Checklist Review
The purpose of the checklist presented on the following pages is to evaluate the impact categories covered in the City’s certified General Plan EIR to determine whether the project’s impacts have been adequately analyzed in the EIR or whether any new significant impacts peculiar to the project or project site would result. Where an impact resulting from the project was adequately analyzed previously, the review provides a cross-reference to the pages in the General Plan EIR where information and analysis may be found relative to the environmental issue listed under each topic. The checklist also identifies whether the project involves new significant impacts or substantially more severe impacts than analyzed in the General Plan EIR or new significant impacts not peculiar to the site or project. As indicated above, an impact would not be considered “peculiar” to the site or project if uniformly applied development policies or standards will substantially mitigate an environmental effect.

Therefore, the following review includes mitigation measures identified in the General Plan EIR that would be applicable to the site or project and/or relevant applicable development policies or standards that will be applied to the project.

The General Plan 2030 EIR is on file at the City’s Planning and Community Development Department, 809 Center Street, Room 101, Santa Cruz, California from 7:30 AM to 11:30 AM, Monday through Thursday. The documents are also available for review on the City of Santa Cruz Planning Department’s website at: https://www.cityofsantacruz.com/government/citydepartments/planning-and-community-development/long-range-policy-planning/generalplan.

D. Conclusion
Based on the following review, it has been determined that the City’s General Plan 2030 EIR has adequately addressed the following issues, and no further environmental review is required pursuant to Public Resources Code section 21083.3: energy; geology and soils (seismic, geologic hazards, erosion soils, paleontological resources); greenhouse gas emissions; hydrology and water quality (conflict with plans); hazards/hazardous materials; population and housing; public services; recreation; and utilities (wastewater treatment and solid waste disposal).

The following site-specific impacts have been analyzed and determined to be less than significant and/or less than significant with General Plan policies, zoning regulations and/or development standards that are uniformly applied to development projects throughout the City: aesthetics (scenic resources, visual character and light and glare); air quality (project emissions, sensitive receptors); biological resources (nesting birds, conflicts with local tree ordinance); cultural resources (archaeological resources); hydrology/water quality (drainage and water quality); land use; noise increases; transportation/traffic; utilities (infrastructure and water supply); and cumulative impacts. Thus, pursuant to Public Resources Code section 21083.3 and State CEQA Guidelines section 15183, no further environmental analysis is required.

25.76 415 Natural Bridges Drive
Environmental Review -11- February 2022
The following site-specific issues reviewed in this document were within the scope of issues and impacts analyzed in the General Plan EIR, and site-specific analyses did not identify new significant impacts. No impacts peculiar to the project or the project site have been identified related to aesthetics (scenic views), agricultural and forest resources, air quality (conflicts with Air Quality Management Plan and odors), biological resources (special status species and sensitive habitat), cultural resources (historical resources), hydrology-water quality (groundwater, flood risks), mineral resources, tribal cultural resources, and wildfire.

E. Checklist and Discussion

1. AESTHETICS
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Standards
Except as provided in Public
Resources Code Section 21099,
would the project:
a) Have a substantial adverse effect on a
scenic vista?
DEIR pp. 4.3-2
to 4.3-7, 4.3-13
to 4.3-15
FEIR pp. 3-2
No No None
b) Substantially damage scenic
resources, including but not limited to
trees, rock outcroppings, and historic
buildings within a state scenic
highway?
DEIR pp. 4.3-14
to 4.3-17 No No None
c) In non-urbanized areas, substantially
degrade the existing visual character
or quality public views of the site and
its surroundings? (Public views are
those that are experienced from
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?
DEIR pp. 4.3-7
to 4.3-8, 4.3-15
to 4.3-19
FEIR pp. 3-2
No No
Design Review &
Permit
Requirements
Municipal Code
section

24.08.400-430
d) Create a new source of substantial
light or glare which would adversely
affect day or nighttime views in the
area?
DEIR pp. 4.3-19
to 4.3-20 No No
Standard
Condition of
Approval to
prevent offsite
lighting
(a) Scenic Views. The project site is located in a developed area of the City of Santa Cruz that is characterized by existing commercial and residential development. The General Plan indicates that prominent scenic views mostly are those that are oriented toward Monterey Bay and the Pacific Ocean or toward the Santa Cruz Mountains that frame the northern boundary of Santa Cruz (SOURCE V.1b, DEIR volume). According to maps developed for the City’s General Plan 2030 and included in the General Plan EIR (SOURCE V.1b-DEIR Figure 4.3-1), the project site is not mapped in proximity to a

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panoramic view, urban view, or visual landmark. The nearest scenic view is mapped on Natural Bridges State Beach, but these views are oriented toward the Pacific Ocean, away from the project site. This viewpoint is located over a half mile south of the project site. The project site is not visible from panoramic or scenic views mapped within the General Plan EIR. Views of the Pacific Ocean and mountains are not available within the immediate vicinity of the project site due to site’s flat topography as well as intervening development and distance from those natural features.

The General Plan EIR concluded that most of the future development accommodated by the General Plan would not be in areas that are part of a public scenic view. The EIR discussed several limited areas in which potential disruption to scenic views could occur with future development, but the project site is not located within these areas. None of the General Plan policies and actions directed toward protection of scenic views are applicable to the project as no scenic views would be affected by the proposed project. The proposed project would not have an adverse effect on a scenic view as none have been identified, mapped or observed that include the project site. Thus, the proposed project would not result in impacts peculiar to the project or the site or substantially more severe impacts than evaluated in the General Plan 2030 EIR, and no further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183. (b) Scenic Resources. There are no designated state scenic highways or roads within the City. The project site is not located near a state scenic highway. The project site is mostly undeveloped and contains grasses and six trees, including three acacias, one cedar, one coast live oak, and one tulip.

The western portion of the project site, which would be added to the subject property via a lot line adjustment, is currently developed with a paved surface parking lot. There are no structures on the project site that would be considered scenic resources.

The project would involve the removal of five of the six trees (one of which straddles the property line with the adjacent parcel to the north) Four of the trees to be removed are considered Heritage trees, and the Heritage Tree Ordinance requires replacement plantings at a ratio of one 24-inch box tree or three 15-gallon trees per tree removed or payment of an equivalent in-lieu fee. Local Coastal Plan Policy CD 6.1.2 requires this replacement ratio to be doubled for Heritage trees removed in the coastal zone. A condition of approval requires the project to meet this tree replacement requirement.

A Tree Resource Evaluation (arborist report) was performed for the project that concludes trees to be removed are generally in poor condition; the report recommends replacement (SOURCE V.10). The trees are not tall (the tallest tree is approximately 25 feet high) and do not represent a significant or prominent visual element of the surrounding area; removal would not substantially alter the visual character of the area.

The General Plan EIR concluded that, with implementation of General Plan policies and actions, future infill development accommodated by the Plan would not result in significant impacts to scenic resources. The General Plan seeks to preserve natural features that visually define areas and provide scenic benefits (CD1.1), as well as to protect significant vegetation that provides scenic value (CD

4.3.3). The project would remove five existing trees on-site. Despite the fact that four of the trees proposed to be removed are of heritage size, the trees proposed for removal are not visible from a wide-ranging area, are not visually prominent or distinctive, and are not considered scenic resources.

Thus, the project would not have an impact on scenic resources.

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For these reasons, the proposed project would not result in impacts to scenic resources that would be peculiar to the project or the site or substantially more severe than evaluated in the General Plan 2030 EIR, and no further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.
(c) Effects on Visual Character. As described above in Section IV(E)(1)(a), the project would not impact prominent views or landmarks designated under the General Plan. The project area is characterized by existing commercial and residential development. The project proposes a three-story residential building with varied exterior plastering and vertical siding that would align with the architectural and visual characteristics of the surrounding commercial buildings.

The General Plan 2030 EIR concluded that most of the future development accommodated by the General Plan would not substantially degrade the visual character of surrounding areas with implementation of General Plan policies and actions to develop design guidelines and review infill development to protect “distinctive design characteristics” and landmarks of neighborhoods (CD2.1, CD2.3) in combination with continued application of design review as part of Design Permit approvals.

The proposed project consists of three floor, 20-unit building with a surface parking lot. The structure’s 36-foot height would be similar to the adjacent commercial buildings, and the overall massing would also be similar, although the proposed structure’s building footprint is smaller than other adjacent and nearby buildings. There are no regulations on floor area ratio for project per the site’s General Plan Land Use designation (Low Medium Density Residential).

As described in Section II, Project Description, the project requests variations to development standards for parking, building height, and side yard setback that will be approved through the Planned Development Permit and also reviewed through the Design Permit process. Per Section

24.08.400 of the Municipal Code, the purpose of the City’s Design Permit review is to “promote the public health, safety and general welfare through the review of architectural and site development proposals and through application of recognized principles of design, planning and aesthetics and qualities typifying the Santa Cruz community.” To receive Design Permit approval, the project would require findings from the City’s approving authority that would consider and grant variations to the zoning district regulations. Design Permit review and approval would be considered application of uniformly applied development standard, which would reduce potential visual character impacts related to zoning variations to a less-than-significant level.

The City of Santa Cruz is an “urbanized area” under the definition of the term in CEQA Guidelines section 15387. Therefore, per the CEQA Guidelines Environmental Checklist question that was amended subsequent to the certification of the General Plan EIR, the City need not specifically consider existing visual character or the quality of the existing views and the project’s potential effect on them. Nonetheless, this analysis has considered these issues and concludes that the project would not substantially degrade the existing visual character of the site or its surroundings, nor the quality of the views to or from the site as described above.

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Furthermore, the proposed project does not affect coastal views between the sea and the first public roadway parallel to the sea, and thus is consistent with required findings for a coastal development permit set forth in Municipal Code section 24.08.250. The project site does not have existing views along the ocean or of scenic coastal areas, which must be protected as required finding for a Design Permit pursuant to Municipal Code section 24.08.430. The project does not conflict with applicable zoning and other regulations governing scenic quality. Therefore, the proposed project would not result in aesthetic impacts peculiar to the project or the site or substantially more severe impacts than evaluated in the General Plan 2030 EIR and would not substantially degrade the visual character of the site or area, and no further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.
(d) Light and Glare. The project would not result in introduction of a major new source of light or glare, although there would be introduction of windows and typical exterior lighting for residential buildings. This type of lighting would be oriented so as to not create off-site light. Exterior building lighting would be further reviewed by City staff as part of the Design Permit review.

The General Plan EIR concluded that new infill development accommodated by the plan could result in potential sources of light and glare, but would not result in creation of “substantial” new sources of light and glare or result in a significant impact. The EIR indicated that infill buildings would have standard window and exterior lighting treatments, but would not be expected to result in new sources of substantial light or glare as future development projects would largely replace or redevelop existing urban uses. Exterior lighting would be included as part of the development, but would be typical of residential and commercial lighting in the area, and would not result in nighttime illumination levels beyond the property line. Additionally, section 24.14.266 of the City’s Municipal Code prohibits direct or sky-reflected glare. Furthermore, the Design Permit review that is required for most larger development projects would ensure project compliance with City standards and regulations.

Therefore, the proposed project would not result in a significant impact related to creation of a new source of substantial light or glare or result in off-site impacts. Details of lighting would be reviewed by City staff as part of the Design Permit. A standard condition of approval requires all exterior lighting required to be shielded to contain the light source in a downward direction and avoid glare and illumination of adjacent properties. An approved Design Permit, including findings pursuant to Municipal Code Section 24.08.430 and inclusion of a standard condition of approval regarding shielding of exterior lighting would be considered application of uniformly applied development standards. There would be no light and glare impacts peculiar to the project or the site with uniformly applied development standards imposed as part of the design review process. Thus, no further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.

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2. AGRICULTURE AND
FOREST RESOURCES2
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
a) Convert Prime Farmland, Unique
Farmland, or Farmland of Statewide
Importance (Farmland), as shown on
the maps prepared pursuant to the
Farmland Mapping and Monitoring
Program of the California Resources
Agency, to non-agricultural use?
DEIR pp. 4.15-3,

4.15-6 to 4.15-8
No No None
b) Conflict with existing zoning for
agricultural use, or a Williamson Act
contract?
DEIR pp. 4.15-3,

4.15-6 to 4.15-8
No No None
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))?
DEIR pp. 4.15-3,

4.15-5 to 4.15-6
No No None
d) Result in the loss of forest land or
conversion of forest land to nonforest use?
DEIR pp. 4.15-3,

4.15-5 to 4.15-6
No No None
e) Involve other changes in the existing
environment which, due to their
location or nature, could result in
conversion of Farmland to nonagricultural use or conversion of forest land to non-forest use?
DEIR pp. 4.15-3,

4.15-5 to 4.15-8
No No None
The project site is located within the developed urban area of the City of Santa Cruz. The project site does not contain prime farmland or other agricultural lands as mapped on the State Farmland Mapping and Monitoring Program (SOURCE V.1b, DEIR Figure 4.15-1). The site is not designated for agricultural uses in the City’s General Plan and is not located adjacent to agricultural lands. The 2 In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement Methodology provided in Forest Protocols adopted by the California Air Resources Board.

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project site is not zoned Timberland Preserve. The General Plan EIR concluded that impacts to agriculture and forest resources would not occur or would be less than significant as a result of future development accommodated by the General Plan. The proposed project would not result in conversion of agricultural or forest lands, as these resources are not present on or adjacent to the project site. Therefore, the proposed project would not result in impacts on agriculture and forest resources that would be peculiar to the project or the site or substantially more severe than evaluated in the General Plan 2030 EIR, and no further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.

3. AIR QUALITY3
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
a) Conflict with or obstruct
implementation of the applicable air
quality plan?
DEIR pp.

4.11-11 to

4.11-12, 4.11-15
to 4.11-18
FEIR p. 3-24
No No
GP EIR
Mitigation

4.11-1
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?
DEIR pp. 4.11-6
to 4.11-7,

4.11-9 to

4.11-10, 4.11-18
to 4.11-34
FEIR 3-24 to 3-
26 No No
GP Policies &
Actions HZ 2.2,
HZ2.2.1,
HZ2.2.2, LU1.2,
LU1.2.1 that
require project
level reviews
c) Expose sensitive receptors to
substantial pollutant concentrations?
DEIR pp. 4.11-7
to 4.11-8,

4.11-10 to

4.11-11,

4.11-18, 4.11-24
to 4.11-26
No No None
d) Result in other emissions (such as
those leading to odors adversely
affecting a substantial number of
people?
DEIR pp.

4.11-26 to

4.11-27
No No None
(a) Conflict with Air Quality Management Plan. In 1991, the Monterey Bay Air Resources District (MBARD), formerly the Monterey Bay Unified Air Pollution Control District (MBUAPCD), adopted the Air Quality Management Plan (AQMP) for the Monterey Bay Region in response to the California Clean Air Act of 1988, which established specific planning requirements to meet the ozone standards.

The California Clean Air Act requires that AQMPs be updated every three years. The MBARD has 3Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations.

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updated the AQMP seven times. The most recent update, the 2012-2015 Air Quality Management Plan (2016 AQMP), was adopted in 2017. The 2016 AQMP relies on a multilevel partnership of federal, state, regional, and local governmental agencies. The 2016 AQMP documents the MBARD’s progress toward attaining the state 8-hour ozone standard, which is more stringent than the state 1-hour ozone standard. The 2016 AQMP builds on information developed in past AQMPs and updates the 2012 AQMP. The primary elements from the 2012 AQMP that were updated in the 2016 revision include the air quality trends analysis, emission inventory, and mobile source programs (SOURCE V.6).

The MBARD has an approved procedure for determining whether a residential project conflicts with the District’s adopted AQMP that uses the Association of Monterey Bay Area Governments’ (AMBAGs) adopted housing unit forecast instead of population, and the MBARD has developed a spreadsheet to assist jurisdictions with developing calculations, which was used to determine whether the proposed project conflicts with the AQMP. The City had 24,169 existing dwelling units as of January 1, 2021 (SOURCE V.4), and approximately 1,356 residential units are under construction or have been approved. With the addition of these units, the City’s housing units would total 25,525 dwelling units. With existing units and the proposed project’s increase of 20 residential units, there would be a total of 25,545 dwelling units within the City, which is below the AMBAG 2018 Regional Growth Forecast of 27,706 dwelling units for the year 2025 (SOURCE V.3a). Therefore, the proposed project would be consistent with the AQMP, and would not conflict with or obstruct implementation of the AQMP.

The General Plan 2030 EIR concluded that future development accommodated by the Plan could result in development of dwelling units that exceed regional projections, which could result in conflicts with the AQMP according to the MBARD’s methodology for determining consistency. The General Plan EIR includes a mitigation measure (Mitigation 4.11-1) that directs City staff to work with AMBAG staff in future updates of population and housing forecasts and indicates that the potential population growth and housing unit increase exceedance would not occur for at least 10+ years, if it occurs at all. Subsequent to adoption of the General Plan, AMBAG updated and adopted regional population and housing forecasts in June 2014 and in June 2018. At this time, the City’s residential population and existing and approved housing units do not exceed adopted regional housing forecasts, and the proposed project would not result in an exceedance of the regional housing forecast. Thus, there would be no impact related to conflicts with the current adopted AQMP.

Given the foregoing, the proposed project would not result in impacts related to conflicts with the AQMP that would be peculiar to the project or the site or substantially more severe than evaluated in the General Plan 2030 EIR, and no further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.
(b) Project Criteria Pollutant Emissions. The U.S. Environmental Protection Agency (EPA) and the California Air Resources Board (CARB) have established ambient air quality standards that are the maximum levels of ambient (background) air pollutants considered safe, with an adequate margin of safety to protect public health and welfare. Criteria pollutants include ozone (O3), nitrogen dioxide (NO2), carbon monoxide (CO), sulfur dioxide (SO2), inhalable particulates (PM10), fine particulates (PM2.5), and lead. High O3 levels are caused by the cumulative emissions of reactive organic gases (ROG) and nitrogen oxides (NOx), which react under certain meteorological conditions to form O3. In

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California, sulfates, vinyl chloride, hydrogen sulfide, and visibility-reducing particles are also regulated as criteria air pollutants. An area is designated as “in attainment” when it is in compliance with the federal and/or state standards, as further discussed below.

The project site is located within the North Central Coast Air Basin (NCCAB), which is under the jurisdiction of the MBARD and includes Santa Cruz, Monterey, and San Benito Counties. The NCCAB is designated attainment for the federal PM10 and SO2 standards, and is designated attainment/unclassified for the other federal standards. The NCCAB is designated attainment for the state PM2.5, NO2, SO2, and lead standards, and is designated unclassified for CO in Santa Cruz County.

The NCCAB has nonattainment designations for state O3 and PM10 standards.

The MBARD 2012-2015 AQMP, adopted March 15, 2017, identifies a continued trend of declining O3 emissions in the NCCAB primarily related to lower vehicle miles traveled (VMT), showing that the region is continuing to make progress toward meeting the state O3 standard during the three-year period reviewed (SOURCE V.6).

The General Plan 2030 EIR concluded that future development accommodated by the Plan could result in air pollutant emissions, but overall future emissions of ozone precursor pollutants are projected to decrease or remain nearly unchanged over the next 20 years, and thus, project-level emissions would not contribute to existing or potential future violations of air quality standards related to O3. Furthermore, General Plan Actions LU1.2, LU1.2.1 and HZ2.2.1 (as modified by the General Plan EIR), require future project-level review and implementation of mitigation measures if warranted, consistent with the adopted standards in the MBARD’s CEQA Guidelines. The General Plan EIR concluded that with implementation of the General Plan policies and actions and compliance with MBUAPCD requirements and air quality control measures, contributions to air pollutant emissions would be less than significant.

The proposed project would result in construction of a three-story, 10,519 gross square foot residential building with 20 SRO units. The project would indirectly generate air pollutant emissions through new regional vehicle trips. The MBARD CEQA Guidelines provide several land use types with corresponding screening threshold levels to assess ozone impacts. While SROs are not specifically listed as a land use type, it can be reasonably concluded that MBARD’s “condominium/townhouse – general” land use type is most similar to the proposed SRO land use; both residential uses are higher density and contained within shared building spaces. The proposed project size is substantially below the MBARD’s screening levels for condominium/townhouse uses (1,195 dwelling units) which is used to determine potential significant ozone impacts as set forth in the MBAED’s CEQA Air Quality Guidelines (SOURCE V.7a). Therefore, project emissions would not be considered substantial or result in an air quality violation, and this would be a less-than-significant impact.

Project construction could result in generation of dust and PM10 emissions as a result of site excavation and grading. According to MBARD’s CEQA Air Quality Guidelines (SOURCE V.7a), construction activity on 8.1 acres per day with minimal earthmoving or 2.2 acres per day with grading and excavation are assumed to be below the MBARD’s PM10 significance threshold of 82 pounds per day. The project site is approximately 0.35 acres in size, which is below screening-level threshold.

Because the site is below screening threshold size, project construction dust and PM10 emissions

25.84 415 Natural Bridges Drive
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would not be considered substantial or result in an air quality violation; this would be a less-thansignificant impact.

Therefore, the project-level review required by the General Plan 2030, and as considered in the General Plan EIR, finds that potential emissions would be less than significant compared to the MBARD’s adopted CEQA significance thresholds, and the project would not violate current air quality standards or expose sensitive receptors to substantial pollutant concentrations. The proposed project would not result in impacts peculiar to the project or the site, or substantially more severe impacts than evaluated in the General Plan EIR, and no further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.

According to the MBARD CEQA Air Quality Guidelines, projects that are consistent with the AQMP would not result in cumulative impacts as regional emissions have been factored into the AQMP. The MBARD prepares air quality plans which address attainment of the state and federal emission standards, and incorporate growth forecasts developed by AMBAG. As indicated in subsection 3(a) above, the proposed project would not conflict with or obstruct the implementation of the AQMP, which takes into account cumulative development within the City. Therefore, the proposed project would not result in a cumulatively considerable criteria pollutant increase.

Therefore, the project-level review required by the General Plan 2030 and as considered in the General Plan EIR finds that potential emissions would be less than significant compared to the MBARD’s adopted CEQA significance thresholds, and the project would not violate current air quality standards or expose sensitive receptors to substantial pollutant concentrations. The proposed project would not result in impacts peculiar to the project or the site, or substantially more severe impacts than evaluated in the General Plan EIR, and no further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.
(c) Sensitive Receptors. For CEQA purposes, a sensitive receptor is defined as any residence, including private homes, condominiums, apartments, and living quarters; education resources such as preschools and kindergarten through grade 12 schools; daycare centers; and healthcare facilities such as hospitals or retirement and nursing homes. A sensitive receptor includes long term care hospitals, hospices, prisons, and dormitories or similar live-in housing (SOURCE V.7a). The project site is mostly surrounded by non-sensitive receptors, with commercial uses to the north, east, and west. The nearest sensitive receptors are residences approximately 630 feet west of the site which are screened by intervening vegetation. The proposed residential project would not introduce a new source of stationary emissions, and thus, would not expose sensitive receptors to substantial pollutant concentrations.

Diesel Particulate Emissions. Diesel particulate matter was identified as a toxic air contaminant (TAC) by the State of California in 1998. The General Plan 2030 EIR discusses construction-related impacts in which diesel particulate matter could be emitted from construction equipment. The impact was found to be less than significant due to the California Air Resources Board’s ongoing adoption of regulations for in-use, off-road diesel vehicles that will significantly reduce particulate matter emissions by requiring fleet owners to accelerate turnover to cleaner engines and install exhaust retrofits. The EIR also noted that the California Code of Regulations, Title 13, section 2486(c)(1)

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prohibits idling of a diesel engine for more than five minutes in any location, thereby further limiting particulate matter emissions. Additionally, emissions during construction are of a short-term duration in comparison to life-long exposure and health risks. Construction-related diesel emissions at the project site would be of limited duration (i.e., primarily during grading) and temporary. Thus, project construction would not expose sensitive receptors to potential exposure of sensitive receptors to diesel emissions and associated risks are considered a less-than-significant impact. Since the proposed project is within the overall buildout analyzed in the General Plan EIR, and no new significant impacts have been identified, no further environmental analysis regarding diesel particulate emissions is required pursuant to Public Resources Code section 21083.3 and the State CEQA Guidelines section 15183.
(d) Odors. According to the Air District’s CEQA Air Quality Guidelines (SOURCE V.7a), land uses associated with odor complaints typically include landfills, agricultural uses, wastewater treatment plants, food processing plants, chemical plants, and refineries. The proposed residential project does not include any uses associated with odors. Therefore, potential odor related impacts would be less than significant.

4. BIOLOGICAL RESOURCES
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
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?
DEIR pp. 4.8-13
to 4.8-14,

4.8-16 to

4.8-21, 4.8-41,

4.8-43 to

4.8-44, 4.8-48
to 4.8-51
FEIR pp. 3-22,
3-25 to 3-40
No No None
b) Have a substantial adverse effect on
any riparian habitat or other sensitive
natural community identified in local
or regional plans, policies, regulations
or by the California Department of
Fish and Wildlife or U.S. Fish and
Wildlife Service?
DEIR pp. 4.8-14
to 4.8-15,

4.8-24, 4.8-26
to 4.8-30,

4.8-22, 4.8-38
to 4.8-41,

4.8-48 to 4.8-51
FEIR p. 3-22
No No None
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?
DEIR pp. 4.8-15,

4.8-41, 4.8-38
to 4.8-39,

4.8-48 to 4.8-51
No No None

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4. BIOLOGICAL RESOURCES
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
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?
DEIR pp. 4.8-22
to 4.8-25,

4.8-41, 4.8-44
to 4.8-45
No No
GP Action
NRC2.2.1 and
Condition of
Approval for
Pre-construction
bird nesting
surveys
e) Conflict with any local policies or
ordinances protecting biological
resources, such as a tree preservation
policy or ordinance?
DEIR pp. 4.8-41,

4.8-45 to 4.8-47 No No
Heritage Tree
Removal Permit,
required
replacement
trees, and
payment of inlieu fees
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?
DEIR pp. 4.5-11
to 4.5-12,

4.8-25 to

4.8-26, 4.8-37
FEIR p. 3-23
Not Applicable Not Applicable None
(a-c) Special-Status Species, Sensitive Habitat. The project site is undeveloped and consists of nonnative grass and six trees. The western portion of the project site, which would be added to the project property via a lot line adjustment, is currently developed with a paved surface parking lot.

According to maps developed for the City’s General Plan 2030 and included in the General Plan EIR, the project site is not located within or adjacent to a sensitive habitat area (SOURCE V.1b, DEIR Figure

4.8-3). Areas of riparian and wetland habitat associated with Moore Creek and Antonelli Pond are located approximately 300 and 500 feet, respectively to the west and southwest of the site; however, no riparian habitat is located on or adjacent to the project site. The project site is not located within in or adjacent to the management area or riparian and development setback areas for Moore Creek established in the City-wide Creeks and Wetlands Management Plan. The infill project site is surrounded by commercial development and uses. For these reasons, no special-status plant or wildlife species or sensitive are expected to be present on the project site.

The General Plan EIR concluded that the City is primarily developed, and new development would predominantly occur within developed areas without impacts to sensitive habitats or special status species. The EIR evaluated potential impacts of development on identified vacant sites, and indicates that development adjacent to streams and riparian habitats could result in impacts to sensitive riparian habitat areas with future development accommodated by the General Plan 2030. As

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indicated above, the project site is not located within or adjacent to a stream or wetland and would not result in direct or indirect impacts to these resources.

Therefore, no impacts to sensitive habitat or special-status species would occur as a result of the project. There would be no significant impacts or impacts peculiar to the project or the site, no further review is necessary pursuant to CEQA Section 21083.3 and CEQA Guidelines Section 15183. (d) Wildlife Movement/Breeding. The General Plan EIR concluded that with implementation of the proposed General Plan 2030 goals, policies and actions, as well as future environmental review of specific development projects and compliance with local regulations and plans, potential impacts related to wildlife movement would be considered less than significant. The primary wildlife movement corridors are located along major watercourses and within City-owned open space lands, which would be protected from future development impacts. Projects adjacent to watercourses would be subject to setback requirements set forth in the City’s Creeks and Wetlands Management Plan.

The project site is located within a developed urban area. As noted above, the project is not mapped within or adjacent to sensitive habitat areas delineated by the General Plan EIR. The site does not contain habitat, nor does it connect to other habitat areas. The proposed project is not located adjacent to or within close proximity to a watercourse. Thus, the project would have no effect on wildlife movement.

There are six trees located on the project site, five of which would be removed. The trees on and adjacent to the project site could provide potential nesting habitat for migratory birds which are protected by the Migratory Bird Treaty Act (MBTA). Tree removal during the breeding season (generally March 1 to August 1) has the potential to destroy bird nests, eggs or chicks if any are present during the removal. However, General Plan NCR2.2.1 establishes biological survey protocols, including pre-construction nesting bird surveys with establishment of appropriate construction buffers if needed, if tree removal and/or construction were to commence during the nesting season.

Implementation of a pre-construction nesting survey and recommendations is a standard project condition of approval that is included in the project conditions of approval. The General Plan EIR concluded that potential impacts of future development that could directly or indirectly interfere with wildlife breeding/nesting would be less than significant with implementation of the General Plan policies and actions for resource protection, which include a requirement to conduct preconstruction nesting bird surveys to protect nesting birds if present at a construction site, which is a standard condition of approval. Inclusion of a standard condition of approval to require a preconstruction bird nesting survey would be considered application of uniformly applied development standards. Therefore, potential project impacts would be considered less than significant with application of uniformly applied development standards (condition of approval to conduct preconstruction nesting survey). There would be no significant impacts or impacts peculiar to the project or the site. Therefore, no further review is necessary pursuant to CEQA Section 21083.3 and CEQA Guidelines Section 15183.
(e-f) Conflicts with Local Plans. indicated in the arborist report prepared for the project, the proposed project would result in the removal of four heritage trees, subject to approval of a heritage tree

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removal permit pursuant to the City’s Heritage Tree Ordinance. Approval of a heritage tree removal permit automatically requires replacement trees or payment of an in-lieu fee. Removal of a heritage tree that is consistent with the criteria, provisions, and requirements set forth in City regulations would not result in a conflict with a local ordinance. City regulations require tree replacement for removal of a heritage tree to consist of replanting three 15-gallon or one 24-inch size specimen for each heritage tree approved for removal. Because the site is located in the Coastal Zone, coastal policy CD 6.1.2 doubles the replanting ratio. In-lieu fees may also be accepted that to go to the City’s Tree Trust Fund for off-site planting of trees. The project’s proposed landscape plan includes a total of three new trees. The project proposes to plan three new white crape myrtles (Lagerstroemia indica) which would each be sized at 15-gallons. A condition of approval will require the full replanting requirement to be met.

The proposed tree planting would not meet 3:1 replanting ratio 15-gallon box trees for all of the removed trees. Therefore, the project would be also required to pay in-lieu fees as determined by City planning staff. This fee would contribute to the City’s Tree Trust Fund for off-site planting of trees. This requirement would be issued as a condition of approval for the project and considered uniformly applicable development standard. Replanting of three new white crape myrtle trees, along with payment of the applicable in-lieu fee, would ensure the project is compliant with the City’s Heritage Tree Ordinance.

The General Plan 2030 EIR concluded that development accommodated by the General Plan could result in the removal of heritage trees; however, with implementation of General Plan goals, policies, and actions, as well as compliance with local regulations and plans, impacts would be less than significant. Removal of heritage trees that is consistent with City regulations and requirements would not be considered a significant impact of the project or an impact peculiar to the project. Approval of a heritage tree removal permit automatically requires replacement trees or payment of in-lieu fees as set forth above.

The proposed trees shown on the landscape plan comply with the types of replacement trees per the City’s Heritage Tree Ordinance. Measures to protect a retained tree along the northern property line, as recommended by the project arborist report, would be implemented during construction as a standard condition of approval. Inclusion of a standard condition of approval to require protection of retained trees during construction would be considered application of uniformly applied development standards. For these reasons, the proposed project would not result in new significant impacts related to conflicts with local ordinances or impacts peculiar to the project or the site with the application of uniformly applied development standards set forth in the heritage tree regulations, and no further review is necessary pursuant to CEQA Section 21083.3 and CEQA Guidelines Section 15183.
(f) Habitat Conservation Plans. There are no adopted Habitat Conservation or Natural Community Conservation Plans in the project vicinity. The City’s recently approved Operations and Maintenance Habitat Conservation Plan (O&M HCP) is not applicable to the proposed project or project site as it was developed for improvements or projects related to City facilities with the potential to take federally listed species and other non-listed special-status species.

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5. CULTURAL RESOURCES
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
a) Cause a substantial adverse change in
the significance of a historical
resource as pursuant to Section
15064.5?
DEIR pp. 4.9-12
to 4.9-14,

4.9-15, 4.9-21,

4.9-23 to 4.9-24
No No None
b) Cause a substantial adverse change in
the significance of an archaeological
resource pursuant to Section
15064.5?
DEIR pp. 4.9-10
to 4.9-12,

4.9-19 to 4.9-23
No No
GP EIR
Mitigation 4.9-1
and Municipal
Code section

24.12.430
c) Disturb any human remains, including
those interred outside of formal
cemeteries?
DEIR pp. 4.9-10
to 4.9-12,

4.9-19 to 4.9-23
No No
GP EIR
Mitigation 4.9-1
and Municipal
Code section

24.12.430
(a) Historical Resources. According to maps developed for the City’s General Plan 2030 and included in the General Plan EIR, the project site is not located within a designated historic district (SOURCE V.1b, DEIR Figure 4.9-4). The project property is currently vacant and undeveloped and the portion that would be added via a lot line adjustment currently developed with a surface parking lot and contains no structures. For these reasons, the project would not result in impacts to a historical resource.

Furthermore, field survey conducted as part of the archaeological investigation did not result in the finding of intact historical deposits (SOURCE V.14).

The adjacent Southern Pacific Railroad alignment was recorded in 1999 as a historic cultural resource, and the historic alignment of California State Route 1 was also recorded as a historic archaeological site. Additionally, a portion of the right-of-way of the Ocean Shore Railroad was recorded as a historic archaeological site in 2011; Delaware Avenue to the south of the project site, was the former route of the Ocean Shore Railroad. Furthermore, the records search found that three historic buildings have been recorded along nearby Mission Street, within the ¼ mile study area. However, these historic resources are not within the boundaries of the project site and would not be impacted due to the proposed project construction or operation (SOURCE V.14). (b-c) Archaeological Resources. According to a map developed for the City’s General Plan 2030 and included in the General Plan EIR and updated in 2018, the project site is located in an area identified as sensitive for archaeological resources (SOURCE V.1c). A preliminary project archaeological reconnaissance investigation was conducted, which included a files records search of the Northwest Information Center (NWIC) at Sonoma State University (SOURCE V.14). The records search found that the project parcel had not been previously surveyed. However, the search did find that properties to the north and west had both been surveyed with negative results. The NWIC search also included a

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review of previously recorded cultural resources and previous archaeological investigations performed within ¼ mile of the project site. Archival research indicated that there are six recorded historical resources within ¼ mile of the project site. These are described in further detail below (SOURCE V.14).

The archaeological investigation also included a pedestrian field survey to identify any potentially significant archaeological resources on the project site. The survey did not reveal any indication of precontact or historical era archaeological deposits on the project site. The field survey did not result in the finding of surface or subsurface archaeological deposits or evidence of those deposits.

The archaeological report did not reveal evidence of the existence of any archaeological resources or deposits on the project site and did not predict archaeological impacts due to the project operation or proposed ground0disturbing activities. Therefore, no subsurface testing was recommended for the project. However, the report did recommend in the event that construction ground-disturbing activities expose unanticipated archaeological materials, that a qualified archaeologist be retained to immediately inspect and assess the find.

Section 24.12.430 of the City’s Municipal Code sets forth the procedure to follow in the event that previously unknown prehistoric or cultural features are discovered during construction. Under provisions of this Code section, work shall be halted within 100 feet of the find and the Planning Director shall be immediately notified to determine the appropriate course of action, including implementation of potential mitigation measures. Additionally, the County Coroner shall be notified in accordance with provisions of Public Resources Code 5097.98-99 in the event human remains are found and the Native American Heritage Commission shall be notified in accordance with the provisions of Public Resources Code section 5097 if the remains are determined to be Native American.

Furthermore, the General Plan EIR concluded that new development accommodated by the plan would result in construction that could result in impacts to buried archaeological resources. However, implementation of the proposed General Plan policies and actions, compliance with local and state regulations, and General Plan EIR Mitigation 4.9-1 would reduce potential impacts to a less-thansignificant level. Mitigation 4.9-1 added an Action to the General Plan (HA1.2.2), which establishes a procedure for preparing archaeological investigations for development within areas designated as “sensitive” or “highly sensitive” and implementing site-specific mitigation measures if significant impacts are identified, with which the proposed project has complied.

An archaeological report and field survey were conducted consistent with the requirements of the General Plan 2030 policies and actions (HA1.2.2) as set forth in the General Plan EIR. The project archaeological investigation did not identify sensitive resources, and therefore, the project would not result in archaeological impacts peculiar to the site or project. In addition, implementation of standards set forth in the City’s Municipal Code (Section 24.12.430) related to potential discovery of unidentified archaeological resources during construction would be considered application of uniformly applied development standards. Discovery of unidentified (e.g., buried) cultural resources during any construction would be subject to this requirement as a standard condition of approval.

Thus, the proposed project would not result in significant impacts to archaeological resources not

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otherwise addressed in the General Plan EIR or impacts peculiar to the project or the site with the application of uniformly applied development standards. No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.

6. ENERGY
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
a) Result in potentially significant
environmental impact due to
wasteful, inefficient, or unnecessary
consumption of energy resources,
during project construction or
operation?
DEIR pp. 4.6-27
to 4.6-29, 4.6-
45 to 4.6-46, 5-
4 to 5-6
No No None
b) Conflict with or obstruct a state or
local plan for renewable energy or
energy efficiency?
No No None
(a) Energy Use. Construction of the project would require consumption of nonrenewable energy resources, primarily in the form of fossil fuels (including fuel oil, natural gas, and gasoline) for automobiles and construction equipment, and other resources including, but not limited to, lumber, sand, gravel, asphalt, metals, and water. Construction would include energy used by construction equipment and other activities at the Project site (e.g., building demolition, excavation, paving), in addition to the energy used to manufacture the equipment, materials, and supplies and transport them to the project site. It is expected that nonrenewable energy resources would be used efficiently during future construction of residential units accommodated by the project. Therefore, the amount and rate of consumption of such resources during construction and maintenance activities would not result in the unnecessary, inefficient, or wasteful use of energy resources.

The proposed project avoids or reduces inefficient, wasteful, and unnecessary consumption of energy in part through siting. As further explained below in Section 17- Transportation, there are two existing transit stops on Natural Bridges Drive near the project site. The project site also is in proximity to bike lane and a multi-use path. The project also provides indoor and outdoor bicycle parking spaces.

The project would be subject to approval of building permits that meet the California Building Code and City Green Building Code requirements, as well as compliance with City requirements for water conservation fixtures and features, including drought-resistant landscaping. These measures are consistent with those recommended for residential uses in the City’s adopted Climate Action Plan related to building and energy efficiency and water conservation. Additionally, Santa Cruz residents are enrolled in Monterey Bay Community Power electricity service, which supplies electricity generated from hydropower, solar and wind, which are renewable resources.

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The General Plan EIR reviewed energy use associated with development accommodated by the General Plan. The estimated energy demand was found to be within state per capita projections for the planning area, and the EIR concluded that overall, the future consumption of electrical and natural gas resources would not represent unnecessary, inefficient, or wasteful use of resources given the implementation of policies that address lighting and energy conservation measures. The proposed project would result in an increase of 20 SRO dwelling units. This level of development would be within the overall amount of residential and commercial development evaluated in the General Plan EIR and within remaining potential development as described in Section IV.B. Therefore, the proposed project would not result in impacts related to inefficient or wasteful use of energy that would be peculiar to the project or the site or substantially more severe than evaluated in the General Plan 2030 EIR. No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.
b) Conflicts with Plans. The proposed project would not result in conflicts with or obstruct a state or local plan for renewable energy or energy efficiency. The proposed project transportation features, design elements, and compliance with building code requirements described above are consistent with the City’s CAP provisions related to energy efficiency. Therefore, no further review is necessary.

7. GEOLOGY AND SOILS
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
a) Directly or indirectly cause potential
substantial adverse effects, including
the risk of loss, injury, or death
involving:
i) 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?
DEIR pp. 4.10-7
to 4.10-9,

4.10-20
No No None
ii) Strong seismic ground shaking?
DEIR pp. 4.10-6
to 4.10-14,

4.10-21 to

4.10-23
No No
California
Building Code
Seismic Design
Criteria
iii) Seismic-related ground failure,
including liquefaction?
DEIR pp.

4.10-12 to

4.10-13, 4.10-21
to 4.10-23
No No
Condition of
approval
requiring
geotechnical
investigation
iv) Landslides? DEIR pp.

4.10-13 to
No No None

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7. GEOLOGY AND SOILS
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards

4.10-14, 4.10-22
to 4.10-24
b) Result in substantial soil erosion or
the loss of topsoil?
DEIR pp.

4.10-17 to

4.10-18, 4.10-25
to 4.10-26
No No
City Municipal
Code section

24.14.060 and
Chapter 18.45
regarding
grading and
erosion control
plans
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 onor off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
DEIR pp. 4.10-5
to 4.10-6,

4.10-15 to

4.10-16, 4.10-24
to 4.10-25
No No None
d) Be located on expansive soil, as
defined in Table 18-1-B of the
Uniform Building Code (1994),
creating direct or indirect substantial
risks to life or property?
DEIR pp.

4.10-16 to

4.10-17, 4.10-19
No No
California
Building Code
Requirements
for Geotechnical
Reports
e) Have soils incapable of adequately
supporting the use of septic tanks or
alternative waste water disposal
systems where sewers are not
available for the disposal of waste
water?
Not Applicable Not Applicable Not Applicable Not Applicable f) Directly or indirectly destroy a unique
paleontological resource or site or
unique geologic feature?
DEIR pp. 4.9-14
to 4.9-16,

4.9-21, 4.9-24
to 4.9-25
No No
GP EIR
Mitigation 4.9-2;
standard
Condition of
Approval for
Accidental
Discovery of
Paleontological
Resources
(a-i) Fault Rupture. The project site is located in a seismically active region of California, which has the potential to be subject to very intense shaking during a seismic event. The City of Santa Cruz is situated between two major active faults: the San Andreas, approximately 11.5 miles to the northeast, and the San Gregorio, approximately 10 miles to the southwest. Other known active faults in the vicinity of the site include the Zayante – Vergeles (approximately 10.5 miles from the site) and

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Sargent (14 miles from the site) (SOURCE V.9). There are no active fault zones or risk of fault rupture within the City (SOURCE V.1b, DEIR volume). Therefore, fault rupture through the site would not occur. (a-ii – iv, c) Seismic and Geologic Hazards. The project could be subject to strong seismic shaking during an earthquake on regional faults. According to maps developed as part of the City’s General Plan 2030 and included in the General Plan EIR, the project site is not located within a liquefaction hazard zone (SOURCE V.1b, DEIR Figure 4.10-4). Subsurface materials on the project site consist of lowest emergent coastal terrace deposits (SOURCE V.1b, DEIR Figure 4.10-2). The project site is relatively level and is not in an area susceptible to landslides (SOURCE V.1b, DEIR Figure 4.10-3). The project site is not located in an area of steep slopes (SOURCE V.1b, DEIR Figure 4.10-5).

The General Plan EIR concluded that adherence to existing regulations and standards, including the CBC and various policies and actions established in the proposed General Plan 2030 would minimize harm to people and structures from adverse seismic and geologic events and conditions. Buildings must be designed in accordance with the latest edition of the California Building Code (CBC), which sets forth structural design parameters for buildings to withstand seismic shaking without substantial structural damage. Conformance to the CBC as required by state law and the City would ensure the maximum practicable protection available for structures and their associated trenches, excavations and foundations. The General Plan EIR also reported that the CBC requires preparation of a geotechnical report for most new structures, except geotechnical reports are not required for one-story, wood-frame and light-steel-frame buildings of Type II or Type V construction and 4,000 square feet or less in floor area (SOURCE V.1b, DEIR volume).

Prior to issuance of construction (grading or building) permits, the applicant would be required to prepare a project-specific geotechnical report as part of issuance of a building permit. The geotechnical report would be performed by a qualified professional to assess the geological site conditions, identify potential hazards, and prescribe building design measures to ensure the project would not cause substantial adverse effects, including the risk of loss, injury, or death due to potential geologic hazards. With implementation of the recommendations in the geotechnical report prepared for the project, impacts related to seismic and geologic hazards would be less than significant.

The General Plan EIR concluded that with adherence to existing regulations and standards, including preparation of a project-specific geotechnical report and adherence to the California Building Code and various policies and actions established in the General Plan, harm to people and structures from adverse seismic events would be minimized (SOURCE V.1b, DEIR volume). The requirement to prepare a project geotechnical investigation and implement the recommendations would be considered application of a uniformly applied development standard. The proposed project is not located in areas of known geological hazards, and a geotechnical report will be required at the time of building permit application that demonstrates that the building is designed to current seismic design standards. Thus, the proposed project would not result in new significant impacts related to seismic and geologic hazards not otherwise addressed in the General Plan EIR or impacts peculiar to the project or the site with the application of uniformly applied development standards for required geological and geotechnical investigations and implementation of recommendations contained in

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these reports. No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.
(b) Erosion. According to maps developed as part of the City’s General Plan 2030 and included in the General Plan EIR, the project site consists of Watsonville loam soils with 0 to 2 percent slopes (SOURCE V.1b, DEIR Figure 4.10-6). As described in the General Plan EIR, erosion potential for this soil profile is not high (SOURCE V.1b, DEIR volume). The proposed project would result in approximately 150 cubic yards of cut earth material and 150 cubic yards of filled earth material. Thus, the project site would be considered balanced and no transfer of earth material would be required. See subsection 10(a) below regarding potential water quality impacts due to grading.

The General Plan EIR concluded that future development accommodated by the Plan could result in erosion during construction, but could be mitigated with adherence to local regulations that require implementation of erosion control plans, and thus, potential erosion during construction would be minimized, resulting in a less-than-significant impact. Implementation of required erosion control plans and erosion control standards and requirements set forth in the City’s Municipal Code Chapter

18.45 would be considered application of a uniformly applied development standard. Thus, the project would not result in new significant erosion impacts not otherwise addressed in the General Plan EIR or impacts peculiar to the project or site with the application of uniformly applied development standards. No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.
(d) Expansive Soils. Expansive soils contain large amounts of clays that expand when wetted and contract when dried. Soils at the project site consist of Watsonville loam, which a low expansive soil potential. However, as discussed above, the project would be required to perform a design-level geotechnical report that would assess soil conditions; the report would determine if the project is located on expansive soils and would prescribe building design features that would reduce potential risks to life and property to a less-than-significant level. Implementation of recommendations set forth in the project geotechnical report is required by the California Building Code and City regulations and policies, which would ensure that potential exposure to geotechnical hazards associated with potentially expansive soils would be mitigated.

The General Plan EIR concluded that future development accommodated by the Plan could be exposed to expansive soils, which would be addressed through compliance with state and local regulations, including the California Building Code requirements and Section 24.14.070 of the City’s Municipal Code (requirement for geotechnical investigations), which would ensure that buildings are designed and to prevent structural damages based on project-specific geotechnical investigations.

The requirement to prepare a project geotechnical investigation and implement the recommendations would be considered application of a uniformly applied development standard.

Thus, with implementation of the foregoing uniformly applied development standards and regulations that require preparation of geotechnical report and implementation of recommendations set forth in the geotechnical investigation, the proposed project would not result in significant impacts not otherwise addressed in the General Plan EIR or peculiar to the project or site. No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.

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(e) Use of Septic Systems. The project would be connected to City sanitary sewers and would not use septic systems.
(f) Paleontological Resources. According to maps developed for the City’s General Plan 2030 and included in the General Plan EIR, the project site is within an area mapped as Late Pleistocene alluvium formations (SOURCE V.1b, DEIR Figure 4.9-5). Late Pleistocene alluvium is one of the four geologic units in the General Plan area known to contain paleontological resources (SOURCE V.1b, DEIR volume).

The General Plan EIR Mitigation 4.9-2 added General Plan Action HA1.2.3 which requires the City to notify applicants within paleontologically sensitive areas of the potential for encountering such resources during construction and condition approvals that work will be halted and resources examined in the event of encountering paleontological resources during construction. If the find is significant, the City would require treatment in accordance with the recommendations of the evaluating paleontologist. Treatment may include, but is not limited to, specimen recovery and curation or thorough documentation. This provision was added to the City’s Municipal Code (section 24.12.431) and all projects are subject to this requirement, which is included as a project condition of approval.

Inclusion of a standard condition of approval that specifies actions to take in the event of discovery of paleontological resources would be considered application of uniformly applied development standards. Therefore, with implementation of the General Plan EIR mitigation measure, the proposed project would not result in significant paleontological resource impacts not otherwise addressed in the General Plan EIR with application of uniformly applied development standards. No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.

8. GREENHOUSE GAS

EMISSIONS
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
a) Generate greenhouse gas emissions,
either directly or indirectly, that may
have a significant impact on the
environment?
DEIR pp.

4.12-13 to

4.12-17, 4.12-21
to 4.12-28
FEIR pp. 3-26 to
3-27
No No None
b) Conflict with an applicable plan, policy
or regulation adopted for the purpose
of reducing the emissions of
greenhouse gases?
DEIR pp.

4.12-18 to

4.12-20, 4.12-29
to 4.12-a31
No No None
(a) Greenhouse Gas Emissions. Climate change refers to any significant change in measures of climate, such as average temperature, precipitation, or wind patterns over a period of time. Climate

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change may result from natural factors, natural processes, and human activities that change the composition of the atmosphere and alter the surface and features of the land. Significant changes in global climate patterns have recently been associated with global warming, an average increase in the temperature of the atmosphere near the Earth’s surface, attributed to accumulation of greenhouse gas (GHG) emissions in the atmosphere. Greenhouse gases trap heat in the atmosphere, which in turn heats the surface of the Earth. Some GHGs occur naturally and are emitted to the atmosphere through natural processes, while others are created and emitted solely through human activities. Climate change models predict changes in temperature, precipitation patterns, water availability, and rising sea levels, and these altered conditions can have impacts on natural and human systems in California that can affect California’s public health, habitats, ocean and coastal resources, water supplies, agriculture, forestry, and energy use (SOURCE V.1b, DEIR volume).

The most common GHG that results from human activity is carbon dioxide, followed by methane and nitrous oxide. The primary contributors to GHG emissions in California are transportation (about 37 percent), electric power production (24 percent), industry (20 percent), agriculture and forestry (6 percent), and other sources, including commercial and residential uses (13 percent).

Approximately 81 percent of California’s emissions are carbon dioxide produced from fossil fuel combustion (SOURCE V.1b, DEIR volume).

The State of California passed the Global Warming Solutions Act of 2006 (AB 32), which seeks to reduce GHG emissions generated by California. The Governor’s Executive Order S-3-05 and AB 32 (Health & Safety Code, § 38501 et seq.) both seek to achieve 1990 emissions levels by the year 2020.

Executive Order S-3-05 further requires that California’s GHG emissions be 80 percent below 1990 levels by the year 2050. AB 32 defines GHGs to include carbon dioxide, methane, nitrous oxide, hydrocarbons, perfluorocarbons and sulfur hexafluoride.

The California Air Resources Board (CARB) is the lead agency for implementing AB 32. In accordance with provisions of AB 32, CARB conducts an annual statewide GHG Emission Inventory that provides estimates of the amount of GHGs emitted to the atmosphere by human activities within California.

In accordance with requirements of AB 32, CARB adopted an Initial Scoping Plan in 2008 and is required to update the scoping plan at least every five years. The First Update to the Scoping Plan, approved in 2014, established a 2030 emissions target of 40 percent below 1990 levels. The current (2017) Scoping Plan identifies a balanced mix of strategies to meet the State’s 2030 GHG limit.

The City’s General Plan 2030 includes goals, policies, and actions on climate change, including reducing communitywide GHG emissions 30 percent by 2020, reducing 80 percent by 2050 (compared to 1990 levels), and for all new buildings to be emissions neutral by 2030. In October 2012, the City also adopted a “Climate Action Plan” that outlines the actions the City will take over the next 10 years to reduce GHG emissions by 30 percent.

The General Plan EIR estimated greenhouse emissions that could result from potential development and buildout accommodated by the plan that included 3,350 residential dwelling units with an associated population increase of 8,040 residents and approximately 3,140,000 additional square feet of new commercial, office, and industrial uses by the year 2030 with an estimated 8,665 new employees. The General Plan EIR analysis determined that the GHG emission levels associated with

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potential buildout that would be accommodated by the General Plan would not be considered substantial compared to long-term forecasts and state and regional targets, and would be less than forecast statewide per-capita emission rates. Implementation of the proposed General Plan 2030 policies and actions, including the Climate Action Plan, as well as planned implementation of statewide actions, would further reduce emissions. Therefore, the impact was considered less than significant.

The proposed project would result in an increase of 20 SRO dwelling units within the City. This level of development would be within the overall amount of residential development evaluated in the General Plan EIR and within remaining potential development as described in Section IV.B. Because the project size (and resulting GHG emissions) is within the total amount of potential residential development and level of emissions analyzed in the General Plan EIR, no impacts peculiar to the site or substantially more severe impacts would occur. No further environmental analysis is required pursuant to Public Resources Code section 21083.3 and State CEQA Guidelines section 15193. (b) Conflicts with Applicable Plans. The project would not conflict with state plans adopted for the purpose of reducing GHG emissions. The General Plan EIR found no impacts related to conflicts with applicable plans related to GHG emissions and reduction strategies.

In October 2012, the Santa Cruz City Council adopted a Climate Action Plan (CAP) to address citywide greenhouse emissions and reduction strategies. The CAP outlined the actions the City and its partners may take pertaining to reduction of GHG emissions to meet the goals and implement the policies and actions identified in the General Plan 2030. The CAP provided City emissions inventories, identifies an emissions reduction target for the year 2020, and included measures to reduce energy use, reduce vehicle trips, implement water conservation programs, reduce emissions from waste collection, increase solar systems, and develop public partnerships to aid sustainable practices. Measures were outlined for the following sectors: municipal, residential, commercial, and community programs.

Each chapter, as well as Appendix A, provided a table of actions necessary to meet each reduction measure, quantified the potential GHG emission reduction, and prioritized implementation based on funding, ease, and current infrastructure. With a couple of exceptions, all measures established the year 2020 as the target date to achieve the specified reductions. The CAP included an Implementation chapter that identifies tracking and reporting of the success of the measures, including City staff responsibilities.

The City’s Climate Action Plan (CAP) 2020 included 12 climate action milestones, addressing energy use, renewable energy, sustainable transportation, waste diversion and increasing tree canopy, and these milestones were tracked through 13 indicator metrics. Four of the 13 indicator targets were achieved by the sunset of the CAP 2020. The City is developing a Climate Action Plan 2030 that is anticipated to be adopted in August 2022 and will include updated climate goals and the strategies the City will implement to achieve them.

The project would be subject to approval of building permits that meet the California Building Code and City Green Building Code requirements, as well as compliance with City requirements for water conservation fixtures and features, including drought-resistant landscaping. These uniformly applicable standards are consistent with goals for residential uses in the CAP related to building and

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energy efficiency and water conservation. Thus, the project would not conflict with provisions of the CAP.

Furthermore, the proposed project location and uses are consistent with the sustainable transportation and land use planning goals set forth in the City’s CAP that encourage higher density development, particularly along transit corridors and activity centers, to support efficient, accessible, and sustainable transportation options. The project site is located in proximity to transit stops, is adjacent to the rail corridor, and is near emerging activity centers on the westside of the City.

In addition, the AMBAG, as a metropolitan planning organization (MPO), is required by state law (2008 Senate Bill (SB) 375) to develop a Sustainable Communities Strategy (SCS)—an integrated transportation, land use, and housing plan that addresses ways to accommodate future population growth and reduce greenhouse gas emissions from cars and light trucks. Moving Forward Monterey Bay 2040 is the MTP/SCS for the three-county Monterey Bay Area. The MTP/SCS identifies Opportunity Areas with the highest chance for successful sustainable growth in the future.

Opportunity Areas are generally located where Transit Priority Areas (TPAs) and Economic Development Areas (EDAs) within the AMBAG region overlap. An Opportunity Area is an area within

0.5 miles of an existing or planned “high-quality transit corridor” (as defined in California Public Resources Code Section 21064.3) that has the potential for transit-oriented development, including mixed use. The proposed project is not located within an identified Opportunity Area, but given its density, affordability, and proximity to transportation corridors and activity center, the proposed project would be consistent with goals and policies of the SCS Strategy.

Given the foregoing, the project would not result in impacts related to conflicts with plans related to GHG emissions and reduction strategies that would be peculiar to the site or substantially more severe than described in the General Plan 2030 EIR. No further environmental analysis is required pursuant to Public Resources Code section 21083.3 and the State CEQA Guidelines section 15183.

9. HAZARDS AND

HAZARDOUS MATERIALS
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
a) Create a significant hazard to the
public or the environment through
the routine transport, use, or disposal
of hazardous materials?
DEIR pp. 4.14-9
to 4.14-10 No No None
b) Create a significant hazard to the
public or the environment through
reasonably foreseeable upset and
accident conditions involving the
DEIR pp. 4.14-5
to 4.14-7,

4.14-9 to

4.14-11
No No None

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9. HAZARDS AND

HAZARDOUS MATERIALS
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
release of hazardous materials into
the environment?
c) Emit hazardous emissions or handle
hazardous or acutely hazardous
materials, substances, or waste within
¼ miles of an existing or proposed
school?
DEIR pp.

4.14-12 No No None
d) Be located on a site which is included
on a list of hazardous materials sites
compiled pursuant to Government
Code Section 65962.5 and, as a result,
would it create a significant hazard to
the public or the environment?
DEIR pp. 4.14-5
to 4.14-7
No No None
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 for people residing or
working in the project area?
Not Applicable Not Applicable Not Applicable Not Applicable f) Impair implementation of or
physically interfere with an adopted
emergency response plan or
emergency evacuation plan?
DEIR pp. 4.6-2
to 4.6-5, 4.6-33
to 4.6-37
No No None
g) Expose people or structures, either
directly or indirectly, to a significant
risk of loss, injury or death involving
wildland fires?
DEIR pp. 4.6-3
to 4.6-4, 4.6-34
to 4.6-35
No No
Standard Fire
Department
Conditions of
Approval
(a-b) Use or Release of Hazardous Materials. The proposed project consists of a residential land uses which would not involve the routine transport, use, or disposal of hazardous materials or wastes, and would not result in the creation of a public health hazard.

The General Plan EIR concluded that new development accommodated by the General Plan that utilizes hazardous materials or generates hazardous waste would be regulated pursuant to federal, state, and local laws to ensure proper transportation, handling, and disposal. With adherence to local and state regulations, as well as implementation of these proposed policies and actions, the General Plan 2030’s impacts related to creation of hazards due to hazardous material transport, use, or

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disposal was considered less than significant. Thus, the proposed project would not result in significant impacts not otherwise addressed in the General Plan EIR or peculiar to the project or site.

No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.
(c-d) Exposure to Hazardous Materials. A search of databases managed by the Department of Toxic Substances Control (EnviroStor) and the State Water Resources Control Board (GeoTracker) was conducted. The project site is not included on the list of hazardous material sites compiled pursuant to Government Code Section 65962.5. Two sites with open cases are listed on the EnviroStor and GeoTracker databases are located within 0.5 miles of the site; both sites are currently undergoing remediation and cleanup efforts.

The General Plan EIR concluded that new development accommodated by the General Plan could result in exposure to hazardous materials due to proximity to contaminated sites but, with adherence to federal, state, and local regulations, impacts would be less than significant. The proposed project would not result in exposure to hazardous materials and would not result in significant impacts not otherwise addressed in the General Plan EIR or peculiar to the project or site. No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183. (e) Airport Safety. The project site is not located within two miles of a public airport or air strip and would not be subjected to potential aircraft hazards.
(f) Emergency Response. Existing access to the project site would be provided from Natural Bridges Drive via Mission Street, Swift Street and Delaware Avenue. The project would not include any changes to existing public roadways that provide emergency access to the site, except for improvements along the project’s Natural Bridges Drive frontage for a new curb cut, driveway, and sidewalk. Therefore, the project would not impair implementation of or physically interfere with an emergency response or evaluation plan, and would not result in an impact. (g) Wildland Fire Hazards. According to maps developed for the City’s General Plan 2030 and included in the General Plan EIR, the project site is not located within a fire hazard area (SOURCE V.1b, DEIR Figure

4.6-1). Thus, the proposed project would not result in significant impacts not otherwise addressed in the General Plan EIR or peculiar to the project or site. No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.

10. HYDROLOGY AND

WATER QUALITY
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
a) Violate any water quality standards or
waste discharge requirements or
DEIR pp. 4.6-22,

4.7-8 to 4.7-12,
No No City Municipal
Code Section

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10. HYDROLOGY AND

WATER QUALITY
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
otherwise substantially degrade
surface or ground water quality?

4.7-24 to 4.7-25 24.14.060, and
Chapters 16.19
and 18.45
regarding water
quality and
erosion control
b) Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the
project may impede sustainable
groundwater management of the
basin?
DEIR pp. 4.5-6
to 4.5-7, 4.5-39
to 4.5-42,

4.7-24 to 4.7-25
No No
City Municipal
Code section

24.14.090
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:

DEIR pp. 4.7-5
to 4.7-8, 4.7-22
to 4.7-24
No No
City Municipal
Code Section

24.14.050, and
Chapter 16.19
and 18.45
regarding runoff
control, grading
and erosion
control
(i) Result in substantial erosion or
siltation on- or off-site;
DEIR pp. 4.7-5
to 4.7-8, 4.7-22
to 4.7-24
No No See above
(ii) Substantially increase the rate or
amount of surface runoff in a manner
which would result in flooding on- or
off-site;
DEIR pp. 4.7-5
to 4.7-8, 4.7-22
to 4.7-24
No No See above
(iii) Create or contribute runoff water
which would exceed the capacity of
existing or planned storm water
drainage systems or provide
substantial additional sources of
polluted runoff; or
DEIR pp. 4.7-7
to 4.7-8, 4.7-22
to 4.7-24
No No
General Plan
2030 Action
CC5.1.8 and
Municipal Code
Chapters 16.19
and 24.14
regarding
drainage and
BMPs
(iv) Impede or redirect flood flows?
DEIR pp. 4.7-12
to 4.7-14,

4.7-25 to 4.7-27
No No None
d) In flood hazard, tsunami or seiche
zones, risk release of pollutants due
to project inundation?
DEIR pp. 4.7-15,

4.7-25 to

4.7-26, 4.10-14
No No
General Plan
Policy HZ6.6 and
actions

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10. HYDROLOGY AND

WATER QUALITY
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
e) Conflict with or obstruct
implementation of a water quality
control plan or sustainable
groundwater management plan?
DEIR pp. 4.7-17 No No
(a) Water Quality/Discharges. The proposed project does not involve any discharges that would violate any water quality standards or waste discharge requirements.

Within urbanized areas such as the City, pollutants frequently associated with stormwater include sediment, nutrients, oil and grease, heavy metals, and litter. The primary sources of stormwater pollution in urban areas include automobiles, parking lots, landscape maintenance, construction, illegal connections to the stormwater system, accidental spills, and illegal dumping.

Urban runoff and other “non-point source” discharges are regulated by the 1972 Federal Clean Water Act (CWA), through the National Pollutant Discharge Elimination System (NPDES) permit program that has been implemented in two phases through the California Regional Water Quality Control Boards (RWQCB). Phase I regulations, effective since 1990, require NPDES permits for storm water discharges for certain specific industrial facilities and construction activities, and for municipalities with a population size greater than 100,000. Phase II regulations expand the NPDES program to include all municipalities with urbanized areas and municipalities with a population size greater than 10,000 and a population density greater than 1,000 persons per square mile (SOURCE V.1b. DEIR volume).

The City has developed a Storm Water Management Program (SWMP) in order to fulfill the requirements of the Phase II NPDES General Permit for Discharges of Storm Water from Small Municipal Separate Storm Sewer Systems (MS4) (General Permit) and to reduce the amount of pollutants discharged in urban runoff. In compliance with the Phase II regulations, the City’s comprehensive SWMP is designed to reduce the discharge of pollutants to the Maximum Extent Practicable (MEP) and to protect water quality (SOURCE V.1b, DEIR volume). The City also adopted an ordinance for “Storm Water and Urban Runoff Pollution Control” (Chapter 16.19 of the City’s Municipal Code), as part of its Storm Water Management Plan in accordance with the RWQCB’s requirements. The ordinance identifies prohibited discharges and required Best Management Practices (BMPs) for construction and new development. City regulations (Municipal Code section

16.19.140) requires that any construction project, including those undertaken under any permit or approval granted pursuant to Titles 15 (Streets and Sidewalks), 18 (Buildings and Construction), and 24 (Zoning) of the Municipal Code, shall implement best management practices including the City’s mandatory BMPs as detailed in the latest BMP manual published by the City’s Public Works Department. BMPs shall be maintained in full force and effect during the duration of the project. The

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City’s BMP manual requires a development project to include a structural or treatment control BMPs, or a combination of BMPs, to reduce potential pollutant loadings in storm water runoff to the maximum extent practicable.

The City’s mandatory BMPs, as detailed in the latest BMP manual published by the City’s Public Works Department, must be implemented to protect water quality into the municipal storm drain system.

The project would also be subject to the Central Coast Post-Construction Requirements (PCRs) that were enacted by the Central Coast RWQCB in July 2013. The PCRs are for projects that create and/or replace ≥2,500 square feet of impervious surfaces. Based on the amount of new/replaced impervious surface area created by the project (10,392 square feet), the project would be required to comply with the project would be required to comply with Tiers 1 through 4 (Site Design, Water Quality Treatment, Runoff Retention, and Peak Management). However, the project is exempt from Tier 4 requirements because stormwater runoff from the project site discharges to a continuous underground storm drain system that discharges to the marine nearshore waters.

The project would include drainage features to collect and treat stormwater runoff. The project proposes to install a bioretention mechanical filtration system that would be located in the front yard setback area. The project site is designed so that stormwater would collect into this system.

Stormwater would be filtered through this system before it is discharged from the site. Runoff would also be reduced by the use of pervious pavement or pavers along the parking stalls and portions of the proposed pedestrian walkways.

Construction activity on projects that disturb one or more acres of soil must obtain coverage under the State’s General Permit for Discharges of Storm Water Associated with Construction Activity (Construction General Permit, 99-08-DWQ). Construction activity subject to this permit includes clearing, grading, and disturbances to the ground such as stockpiling or excavation. The Construction General Permit requires the development and implementation of a Stormwater Pollution Prevention Plan (SWPPP). The SWPPP must list best management practices (BMPs) that the discharger will use to protect stormwater runoff and the placement of those BMPs. A Notice of Intent (NOI) and SWPPP must be prepared prior to commencement of construction. Proposed grading and development on the project site would not disturb more than one acre and, thus, the project would not be subject to the Construction General Permit and preparation of a SWPPP. However, the City’s regulatory requirements and BMPs, as detailed in the “Stormwater Best Management Practices Manual” published by the City’s Public Works Department, must be implemented.

The General Plan EIR concluded that with implementation of General Plan policies and adherence to City regulations to protect water quality, impacts from future development on water quality, including potential erosion, would be less than significant. Compliance with regulations contained in the City’s Municipal Code regarding implementation of stormwater BMPs, grading requirements and implementation of erosion control plans (Chapters 16.19 and 18.45 and section 24.14.060), as well as, preparation and implementation of a SWPPP during construction, would mitigate potential storm runoff water quality and erosion impacts during excavation and construction as discussed above and would be considered application of uniformly applied development standards. Thus, the proposed project would not result in significant water quality impacts not otherwise addressed in the General Plan EIR, and the project would not result in water quality impacts peculiar to the site or project with

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application of uniformly applied development standards. No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183. (b) Groundwater. Development within groundwater mapped recharge areas is regulated in Municipal Code section 24.14.090 in order to minimize adverse environmental impacts. The project site is located within a developed area. The City is primarily developed, and no groundwater recharge areas are identified or mapped in the City’s General Plan 2030 or General Plan EIR; groundwater resources utilized as part of the City’s water supply are obtained from aquifers outside of the City (SOURCE V.1b.

DEIR volume). The project would be connected to the City’s public water system and does not include the use of a groundwater well. Therefore, the project would not affect groundwater supplies or recharge or impede sustainable groundwater management of the basin. (c[i-iii]) Drainage. The project site is located within a developed urban area. Most of the site is comprised of vegetation and pervious surface area; however, the western portion of the project site, which would be added to the subject property via a lot line adjustment, is currently developed with a paved (impervious) surface parking spaces. As described above, the project would lead to an overall increase of 10,392 square feet of impervious surface. On-site stormwater retention and filtration is planned through engineered control measures detailed in the project’s stormwater control and management plans. These plans are designed so that the project would not generate a flow of stormwater that would exceed the capacity of storm water facilities, or result in substantial erosion.

The General Plan EIR concluded that potential impacts related to increased stormwater runoff would be a less-than-significant impact with implementation of General Plan policies and actions that require new development to maintain pre-development runoff levels (CC5.1.8). The project’s stormwater would be required to be maintained at pre-development runoff levels in accordance with General Plan and City requirements. The project would not alter existing drainage patterns. Section

24.14.050 of the City’s Municipal Code requires preparation of a drainage plan. Drainage improvements would be required to be designed in accordance with City standards and Public Works requirements in order to meet water quality standards and maintain pre-project runoff levels.

Implementation of measures identified in a stormwater plan in accordance with requirements of the City’s Municipal Code would be considered application of uniformly applied development standards.

The proposed project would not result in significant drainage impacts not otherwise addressed in the General Plan EIR or peculiar to the site or project with implementation of uniformly applied development standardsrelated to stormwater management. No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183. (c [iv], d) Flood Hazard Areas and Risk of Release of Pollutants. According to maps prepared for the General Plan 2030 and included in the General Plan EIR, the project site is not located within a flood hazard zone (SOURCE V.1b, DEIR Figure 4.7-1) or a tsunami inundation zone (SOURCE V.1b, DEIR Figure 4.7-2).

Therefore, the project would not result in risk of release of pollutants in flood areas. With implementation of the proposed policies and actions related to flood control and adherence to other City plans and regulations, the General Plan EIR concluded that future development would not result in substantial risk of exposure of structures or people to flood hazards and impacts would be less than significant. The proposed project would not result in significant flood hazards not otherwise

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addressed in the General Plan EIR or peculiar to the site or project. No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.

Sea Level Rise. The General Plan EIR reported that sea level rise, storms of increasing intensity, and an alternating series of floods and droughts threaten the City of Santa Cruz in the coming decades.

The EIR indicated that the City was in the process of drafting a “Climate Change Adaptation Plan” to identify and evaluate the potential impacts of climate change on the City of Santa Cruz, analyze the severity of the hazards that the City faces, and develop potential adaptation responses to reduce the risk and exposure of the City to these hazards. The City prepared a “Climate Adaptation Plan” with funding from FEMA. The objectives of this Plan are to identify and evaluate the potential impacts of climate change on the City of Santa Cruz, analyze the severity of the hazards that the City faces, and develop potential adaptation responses to reduce the risk and exposure of the City to these hazards.

The potential risks were identified in a “Vulnerability Study.” that identified potential facilities vulnerable to risks of sea level rise, including beaches, the City’s wastewater treatment facility, and the Santa Cruz Harbor (SOURCE V.1d, DEIR volume).

The Climate Adaptation Plan Update 2018-2023, adopted by the City Council in October 2018, further addresses sea level rise. The project site is not located within an area identified as being subject to potential effects of sea level rise. Thus, the proposed project would not result in significant impacts related to sea level rise not otherwise addressed in the General Plan EIR related to sea level rise, and the project would not result in impacts peculiar to the site or project. No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183. (e) Conflict with Plans. The project site is not located adjacent to a water course or water body and would not conflict with or obstruct implementation of a water quality control plan. A sustainable groundwater management plan for the area in which the project is located has not yet been prepared. Therefore, the project would not conflict with adopted plans.

11. LAND USE
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
a) Physically divide an established
community?
DEIR pp. 4.1-21
to 4.1-22 No No None
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?
DEIR pp. 4.1-9
to 4.1-14,

4.1-25 to 4.1-27
No No
Coastal Permit
Review and
Requirements
Municipal Code
section

24.10.2430

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(a) Physically Divide an Established Community. The project site is located within a developed urban area of the City and the project would not physically divide an established community. (b) Conflict with Policies and Regulations. As indicated in Section IV.B., the proposed project is consistent with General Plan 2030 land use designations. The project site is located within the Coastal Zone and Shoreline Protection Overlays. Pursuant to the California Coastal Act, the City has a Local Coastal Program (LCP) that was certified by the California Coastal Commission (CCC). The LCP consists of a land use plan, implementing ordinances and maps applicable to the coastal zone portions of the City, and applies to all private and public projects located within the coastal zone. The purpose of these overlay districts is to preserve and protect the coastal and environmental resources within the City and to provide the means of carrying out policies of the Coastal Act and City’s Local Coastal Program. Per sections 24.10.2400 and 24.10.2500 of the Municipal Code, the project would be subject to a City Coastal Permit. For Coastal Permit approval, the City’s approving authority would be required to make findings pursuant to section 24.10.2430 of the Municipal Code related to grading, erosion control, coastal hazards, public views, shoreline access, and more generally, the goals of the Local Coastal Program. Coastal Permit review and approval would be considered application of uniformly applied development standard, which would ensure project compliance with its Costal Zone and Shoreline Protection Overlay designations.

The proposed use is consistent with General Plan and zone district land use designations as discussed in section IV.B and C. Based on the analyses contained in this Environmental Checklist and a review of the General Plan 2030 and LCP, the proposed project would not result in a conflict with any policies or regulations adopted for the purpose of avoiding or mitigating an environmental impact. The proposed project is consistent with the General Plan, and the project would not result in land use impacts peculiar to the site or project. No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.

12. MINERAL RESOURCES
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
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?
DEIR pp. 4.15-3
to 4.15-4,

4.15-6
No No None
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?
DEIR pp. 4.15-3
to 4.15-4,

4.15-6
No No None

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a-b) Loss of Mineral Resources. There are no mineral resources within the City (SOURCE V.1b, DEIR volume).

13. NOISE
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project result in: Standards
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?
DEIR pp. 4.13-4
to 4.13-8,

4.13-10 to

4.13-22
No No
GP Action
HZ3.1.1,
HZ3.1.2, HZ3.1.3
& HZ3.1.5
b) Generation of excessive ground borne
vibration or ground borne noise
levels?
DEIR pp.

4.13-10 No No None
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?
Not Applicable No No None
(a) Noise Increases. The primary existing noise source within the project area is traffic noise along Natural Bridges Drive, which is a short local street. There are no developed noise contours for this street in the General Plan 2030 s (SOURCE V.1b, DEIR Figures 4.13-1 and 4.13-2).

The General Plan 2030 includes goals, policies and actions that set forth measures to avoid and minimize adverse impacts regarding exposure to noise. In particular, noise-land use compatibility standards will be applied to all new residential projects (HZ3.2.1), and the General Plan seeks to ensure that noise standards are met in the siting of noise-sensitive uses (HZ3.2). The policies also establish an interior noise level of 45 dBA for all residential uses, consistent with state law. The General Plan indicates that exterior noise levels to 65 dBA are normally acceptable for new multifamily development; noise levels to 70 dBA are considered conditionally acceptable and typically require an acoustical study to determine whether additional insulation or window treatments are required. Normal noise attenuation within residential structures with closed windows is about 20 dBA. As noted above, the project is located within an 60-dBA noise contour; therefore, the project conditions would be below the 65-dBA exterior noise threshold as designated by the General Plan EIR.

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At the end of 2018, amendments to the State CEQA Guidelines were adopted by the State of California that included changes to the Appendix G environmental checklist, including elimination of question related to exposure to noise. The questions focus on the potential permanent and temporary noise generated by a project. The proposed project would include residential development; this land use is not associated with substantial permanent increases in ambient noise levels. Noise associated with the project’s parking area would not represent a substantial increase in noise, because much of the proposed parking area is already developed with surface parking.

Operational noise associated with project is also anticipated to comply with the City of Santa Cruz noise standards and not predicted to result in significant noise impacts at nearby noise-sensitive receptors. Therefore, the project would not result in significant permanent noise increases not otherwise addressed in the General Plan EIR.

There would be a temporary increase in existing noise levels during grading and construction of the project. Noise impacts resulting from construction would depend on the noise generated by various pieces of construction equipment, the timing and duration of noise-generating activities, and the distance between construction noise sources and noise-sensitive receptors, as well as existing ambient noise levels. Noise generated during construction would vary throughout the construction period and on any given day, depending on the construction phase and the type and amount of equipment used at the construction site. The highest noise levels would be generated during grading of the site, with lower noise levels occurring during building construction and finishing. There are no sensitive noise receptors immediately adjacent to the site; the nearest sensitive noise receptors are residences approximately 630 feet west of the site. However, these residences are separated from the site by intervening vegetation and a commercial business. In addition, as explained in the General Plan EIR, construction sound levels would be intermittent and varied through a single day as well as the duration of project construction.

The General Plan 2030 includes goals, policies and actions that set forth measures to avoid and minimize adverse impacts of increased noise resulting from construction or operation of development projects (HZ3.1.1,3.1.2, 3.1.3, and 3.1.5). The General Plan EIR concluded that with implementation of General Plan policies and adherence to City regulations, noise impacts from future development would be less than significant. Section 9.36.010 prohibits offensive noise between the hours of 10 PM and 8 AM and Section 9.36.020 prohibits unreasonably disturbing noises.

Furthermore, Section 24.14.260 prohibits increases of sound levels above five dBA above the local ambient on a residential property. These regulations are intended to prevent increases in ambient noise levels and would be considered uniformly applied regulations to which the proposed Project would be subject to compliance. The proposed project would not result in significant impacts not otherwise addressed in the General Plan EIR or peculiar to the project or site regarding permanent or temporary increases in noise. No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.
(b) Vibration. The proposed residential use would not result in generation of or exposure to vibration as neither the proposed use or other existing residential uses in the vicinity are known to be sources of vibration. Construction noise and vibration will be performed during daytime hours and be temporary in nature. Construction noise and vibration is predicted to comply with the City of Santa

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Cruz criteria, as well as Caltrans and FTA recommended guidelines. Therefore, no significant construction-related vibration project impacts would occur. (e-f) Airport Noise. The project site is not located near an airport or private airstrip.

14. POPULATION

AND HOUSING
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
a) 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)?
DEIR pp. 4.2-2
to 4.2-6, 4.2-12
to 4.2-14
Not Applicable Not Applicable None
b) Displace substantial numbers of
existing people or housing,
necessitating the construction of
replacement housing elsewhere?
DEIR pp. 4.2-14
to 4.2-15 Not Applicable Not Applicable None
(a) Inducement of Substantial Population Growth. The General Plan 2030 EIR estimated population and housing increases that could result from potential development and buildout accommodated by the plan that included 3,350 residential dwelling units with an associated population increase of 8,040 residents by the year 2030. The project would include construction of 20 new dwelling units. The proposed SRO units are within the total remaining unbuilt residential development analyzed in the General Plan EIR; see discussion in Section IV.B. The project would not induce substantial population growth in the City as it would be consistent with population growth projections developed for the City and the amount of development described in the General Plan EIR (SOURCE V.1b, DEIR volume).

The City had a population of 56,156 people as of January 1, 2021 (SOURCE V.4). Given that SROs are designed and intended to house a single occupant, the proposed project would result in a population increase of 20 residents when added to the City’s existing population. This is within the regional population forecast of 72,091 for the city of Santa Cruz for the year 2025 (SOURCE V.3a). Therefore, the proposed project would not substantially induce unplanned population growth. Since the potential population growth resulting from the proposed project would fall within the total level of development analyzed in the General Plan EIR and is consistent with current regional forecasts, no further environmental analysis is required pursuant to Public Resources Code section 21083.3 and State CEQA Guidelines section 15183.

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(b) Displacement of Existing Housing or People. No housing units exist on the project site. The project site consists of an undeveloped grass area and parking lot. Therefore, the project would not result in displacement of housing or residents.

15. PUBLIC SERVICES
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Standards
a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities or need for new or physical 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?
DEIR pp. 4.6-2
to 4.6-4, 4.6-33
to 4.6-36
FEIR pp. 3-19
No No None
Police protection?
DEIR pp. 4.6-4
to 4.6-5, 4.6-36
to 4.6-37
No No None
Schools?
DEIR pp. 4.6-20
to 4.6-21,

4.6-40 to 4.6-41
No No
Payment of
School Impact
Fees
Parks?
DEIR pp. 4.6-5
to 4.6-20,

4.6-37 to 4.6-40
FEIR pp. 3-20 to
3-22
No No None
Other public facilities? Not Applicable No No None
Police and Fire Protection Services. As indicated in Section IV.B above, the City’s General Plan EIR considered construction of approximately 3,350 residential units within the City to the year 2030 (SOURCE V.1b); the proposed project is within the total and remaining unbuilt residential units and commercial square footage. Thus, the project’s proposed 20 residential would be within the overall amount of development evaluated in the General Plan EIR. The EIR analyses concluded that impacts of potential development and buildout accommodated by the General Plan would be less than significant for fire and police protection services. Thus, construction of any new public facilities to serve the project would not be warranted with General Plan buildout. Since the proposed project size would fall within the total amount of potential development analyzed in the General Plan EIR and would not result in more severe impacts than analyzed in the General Plan EIR, no further environmental analysis is required regarding these public services pursuant to Public Resources Code section 21083.3 and State CEQA Guidelines section 15183.

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School Enrollments. The General Plan EIR concluded that buildout of the Plan could result in potentially significant impacts to schools but, with required payment of school impact fees to fund necessary facility expansion and/or additions in conjunction with potential reuse of the former Natural Bridges Elementary School if needed, the impact would be mitigated to a less-than-significant level. The EIR concluded that potential addition or expansion of school classroom facilities is not expected to result in significant physical impacts due to the location of existing facilities within developed footprints. As the proposed project would be within the amount of development analyzed in the General Plan EIR and would be required to pay school impact fees, no new or substantially worsened impacts to schools or impacts peculiar to the project or site would occur and no further environmental analysis is required regarding these public services pursuant to Public Resources Code section 21083.3.

Parks and Recreation. See Section IV.E.16 below regarding impacts to parks and recreational facilities.

16. RECREATION
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
a) 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?
DEIR pp. 4.6-5
to 4.6-20,

4.6-37 to 4.6-40
No No
Parks and
Recreation
Facilities Tax
b) Include recreational facilities or
require the construction or expansion
of recreational facilities?
DEIR pp. 4.6-10
to 4.6-11 No No None
(a) Use of Existing Parks and Recreational Facilities. The City has responsibility for management, maintenance and operation of over 1,700 acres of parks and open space lands, and various community/recreational facilities, and oversees development of new parks and improvements within City-owned parks, open space, and community facilities. In the project area, the Santa Cruz Coastal Rail Trail provides pedestrian and bicycle access to coastal recreational sites. The project site is also in the vicinity of Natural Bridges State Beach and Sergeant Derby Park.

As indicated in Section IV.B above, the City’s General Plan EIR considered construction of approximately 3,350 residential units within the City to the year 2030 (SOURCE V.1b, DEIR volume), and the proposed project is within the total and remaining unbuilt residential units. Thus, the proposed project would be within the overall amount of development evaluated in the General Plan EIR. The EIR analyses concluded that, while the City does not meet its goal for neighborhood parks of 2.0 acres per 1,000 residents and for community parks of 2.5 acres per 1,000 residents, implementation of General Plan goals, policies, and actions that set forth measures to avoid and minimize adverse

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impacts on park and recreational facilities, as well as compliance with local regulations, would ensure that impacts to parks and recreational facilities resulting from buildout of the General Plan would be less than significant.

Furthermore, the City imposes a “Parks and Recreation Facilities Tax” (pursuant to Chapter 5.72 of the Municipal Code) on new residential development within the City, payable at the time of issuance of a building permit. The collected taxes are placed into a special fund, and “shall be used and expended solely for the acquisition, improvement and expansion of public park, playground and recreational facilities in the city” (Municipal Code section 5.72.100). The required fees for park expansion and improvements would be considered an application of uniformly applied development standards. (It is noted that projects that have dedicated land or fees in accordance with Municipal Code Chapter 23.28 requirements for subdivisions are exempt from this tax). Thus, with implementation of uniformly applied development standards, the proposed project would not result in significant impacts to parks and recreational facilities not otherwise addressed in the General Plan EIR or peculiar to the project or site. No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.
(b) New Recreational Facilities. The project does not include public recreational facilities. As indicated above, the General Plan concluded that potential impacts to parks and recreational facilities with growth accommodated by the General Plan would be less than significant. The proposed project would not result in significant impacts to parks and recreational facilities not otherwise addressed in the General Plan EIR or peculiar to the project or site. No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.

17. TRANSPORTATION

AND TRAFFIC
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
a) Conflict with a program, ordinance or
policy addressing the circulation
system, including transit, roadway,
bicycle and pedestrian facilities?
DEIR pp. 4.4-2
to 4.4-26,

4.4-31 to 4.4-45
No No
GP Actions
M3.1.3, M3.1.4,
M2.3.2
regarding traffic
improvements
and Traffic
Impact Fee
Program
b) Would the project conflict or be
inconsistent with CEQA Guidelines
section 15064.3, subdivision (b)?
Not Applicable No No None
c) Substantially increase hazards due to
a geometric design feature (for
example, sharp curves or dangerous
DEIR pp. 4.4-45
to 4.4-46 No No None

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17. TRANSPORTATION

AND TRAFFIC
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
intersections) or incompatible uses
(for example, farm equipment)?
d) Result in inadequate emergency
access?
DEIR pp. 4.6-33
to 4.6-37 No No None
(a) Conflict with Circulation Plan, Policy or Ordinance. The project site is located on Natural Bridges Drive between Mission Street and Delaware Avenue. Project access will be provided via a new driveway on Natural Bridges Drive. A total of 12 parking spaces are proposed for the development on a new surface parking lot. Additionally, the project applicant is proposing improvements in the Natural Bridges Drive public right-of-way and frontage, including construction of a curb cut, sidewalk, and gutter per City standards.

The local roadway network serving the project site includes Highway 1 (State Route 1), Mission Street, Natural Bridges Drive, Western Drive, and Delaware Avenue. The Santa Cruz Metro Transit District (METRO) has bus route service along Natural Bridges Drive, Delaware Street, and Western Drive. Local METRO bus stops are located on Natural Bridges Drive immediately in front the project site (Route 20), along the intersection of Natural Bridges Drive and Delaware Avenue (Route 20), and along the intersection of Highway 1 and Western Drive (Routes 40 and 42). Pedestrian and bicycle facilities are located in the area, including the multi-use path along the Santa Cruz Coastal Rail Trail. The project includes five outdoor bicycle racks and indoor bicycle storage for tenants. Natural Bridges Drive is developed with Class II bike lanes and the project vicinity has multi-use paths, transit stops, and Citysponsored bike share program.

The Draft General Plan 2030 includes goals, policies and actions that set forth comprehensive measures to reduce vehicle trips, increase vehicle occupancy, encourage use of alternative transportation modes, and promote alternative-sustainable land use patterns, all of which would help reduce vehicle trips, avoid and minimize adverse impacts related to traffic. The City’s General Plan strives to maintain the established “level of service” D or better at signalized intersections (M3.1.3). “Level of service” (LOS) is typically used to evaluate traffic operations, in which operating conditions range from LOS “A” (free-flowing) to LOS “F” (forced-flow). Caltrans endeavors to maintain a target LOS at the transition between LOS C and D on State highway facilities. Delays for signalized intersections are evaluated for the overall peak hour as an “average.” The methodologies for unsignalized intersections also evaluates the delays for the each “critical” movement (e.g. stop sign controlled approaches on the minor street and main line left turn). The City’s General Plan also accepts a lower level of service and higher congestion at major regional intersections if necessary improvements would be prohibitively costly or result in significant, unacceptable environmental impacts (M3.1.4).

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The proposed project would result in a net increase of less than 200 daily trips and 20 weekday peak hour trips, which would not result in substantial changes in roadway operations or LOS due to the minimal volume spread out over the day and hour. The proposed affordable housing project is located in proximity to bus, bicycle, and pedestrian facilities and close to neighborhood businesses and activity centers on the westside, such that alternative transportation modes like would be used for some of the project’s daily trips.

The City’s General Plan 2030 EIR concluded that adoption and implementation of the General Plan 2030 would accommodate future development that would result in increased vehicle trips and traffic, which would cause changes in some intersection levels of service to unacceptable levels or further deterioration of intersections currently operating at unacceptable levels of service at some locations.

The EIR identified one impacted intersection near the project site resulting from development accommodated by the General Plan-the Swift Street/Delaware Avenue intersection. Improvements are planned as part of the City’s Traffic Impact Fee program the intersection that would involve construction of a new roundabout and/or signal. With implementation of proposed General Plan 2030 policies and actions, including road improvements identified in an updated TIF program, the General Plan EIR concluded that intersection operations would be improved to an acceptable LOS at the Swift/Delaware intersection. In addition, the approved project on Delaware that is currently under development must install the traffic signal when a deficient LOS is reached.

The General Plan EIR found that with implementation of the identified intersection improvements and General Plan 2030 policies and actions to reduce vehicular traffic, increase vehicle occupancy and support/encourage use of alternative transportation measures, the identified impact could be reduced to a less-than-significant level at the remaining impacted intersections. However, funding availability likely would remain constrained for major facility improvements and expansion of transit service into the foreseeable future. The General Plan concluded that implementation of recommended improvements and alternative transportation facilities cannot be assured, and that the impact to the intersections identified as operating at unacceptable levels of service under the proposed General Plan 2030 was conservatively assumed to be significant.

The project would be subject to payment of traffic impact fees that are applied uniformly throughout the City to all new development as part of the city-wide TIF program. The proposed project would not result in significant impacts related to conflicts with policies or regulations regarding the City’s circulation system or peculiar to the project or site. The project does not conflict with General Plan mobility policies regarding level of service goals, transportation improvements, reduction of vehicle trips, and encouraging multi-modal and alternative transportation systems. The project would not conflict with adopted policies, plans or programs that support alternative transportation. Thus, no further environmental analysis is required pursuant to Public Resources Code section 21083.3 and the State CEQA Guidelines section 15183.
(b) Conflicts with State CEQA Guidelines. Subsequent to certification of the General Plan 2030 EIR, amendments to the State CEQA Guidelines at the end of 2018 added a new question of whether or not a project would conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b).

This is a new section that codifies the switch from LOS to vehicle miles traveled (VMT) as the metric

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for transportation analysis pursuant to state legislation adopted in 2013. In September 2013 Governor Brown signed Senate Bill 743 which made significant changes to how transportation impacts are to be assessed under CEQA. SB 743 directs the Governor’s Office of Planning and Research (OPR) to develop a new metric to replace LOS as a measure of impact significance and suggests vehicle miles travelled as that metric. According to the legislation, upon certification of the guidelines, automobile delay, as described solely by LOS shall not be considered a significant impact (Section 21009(a)(2)). SB 743 also creates a new CEQA exemption for certain projects that are consistent with the regional Sustainable Communities Strategy.

CEQA Guidelines section 15064.3(b) indicates that development projects that exceed an applicable VMT threshold of significance may indicate a significant impact. Generally, projects within one-half mile of either an existing major transit stop or a stop along an existing high quality transit corridor should be presumed to cause a less than significant transportation impact. Projects that decrease vehicle miles traveled in the project area compared to existing conditions should be presumed to have a less than significant transportation impact.

In accordance with the amended CEQA Guidelines, the City has transitioned from intersection level of service (LOS) formerly used for traffic impact analyses to VMT as the metric for determining potentially significant impacts. The City adopted a VMT transportation threshold on June 9, 2020 in accordance with CEQA and state requirements. The threshold generally establishes that a project exceeding a level of 15% below the County-wide average VMT may result in a significant transportation impact.

The City’s guidelines to determine whether a land use project is within the VMT threshold includes a screening process in which situations are identified under which projects are determined to not have a significant impact and further analysis is not required. Projects, or portions of the project, that meet the screening criteria do not require a CEQA transportation analysis. Such projects will have a non-significant CEQA transportation impact based on their project location and characteristics. These include:
• Small projects that generate fewer than 110 trips per day; • Projects near high quality transit: within a ½ mile of a major transit stop or a high quality transit corridor with a combined service interval frequency of 15 minutes or less during the AM and PM peak hours;
• Local-serving retail;
• Local essential service;
• Affordable housing projects;
• Map based screening; and
• Redevelopment projects that do not result in a net increase in VMT (SOURCE V.1d).

City staff has reviewed the project in accordance with the City’s guidelines and concluded that the project would not result in a significant impact related to VMT. The City’s VMT Guidelines report reference the State’s 2018 OPR Guidance, page 14. As described, “Evidence supports a presumption of less than significant impact for a 100 percent affordable residential development (or the residential

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component of a mixed-use development) in infill locations.” The project is a 100%-affordable housing project and on an infill site in the western portion of the City. Thus, the project would not result in a significant impact related to VMT based on the City’s adopted threshold and would not conflict or be inconsistent with CEQA Guidelines section 15064.3. It is also noted that there are two transit stops on Natural Bridges Drive near the project site, but they do not operate at 15-minute headways. (c, d) Design-Safety and Emergency Access. The project has been designed in accordance with City requirements, and there are no access designs that would substantially increase hazards. Fire truck access would be provided along the eastern boundary of the property off of Natural Bridges Drive.

The fire lane is proposed to have a width of 14 feet with no overhead clearance restrictions. The project would be designed in accordance with City police and fire department requirements and would provide for adequate emergency access. Therefore, the project would not result in increased hazards related to project design and would not provide inadequate emergency access.

18. TRIBAL CULTURAL

RESOURCES
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
a) Listed or eligible for listing in the
California Register of Historical
Resources, or in a local register of
historical resources as defined in
Public Resources Code section
5020.1(k), or
Not Evaluated Not Applicable Not Applicable None
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?
Not Evaluated Not Applicable Not Applicable
GP EIR
Mitigation 4.9-1
and Municipal
Code section

24.12.430

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State Assembly Bill 52, effective July 1, 2015 after the City’s adoption of the General Plan 2030, recognizes that California Native American prehistoric, historic, archaeological, cultural, and sacred places are essential elements in tribal cultural traditions, heritages, and identities. The law establishes a new category of resources in the California Environmental Quality Act called “tribal cultural resources” that considers the tribal cultural values in addition to the scientific and archaeological values when determining impacts and mitigation. Public Resources Code section 21074 defines a “tribal cultural resource” as either:
(1) Sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either of the following:
(a) Included or determined to be eligible for inclusion in the California Register of Historical Resources.
(b) Included in a local register of historical resources as defined in subdivision (k) of Section 5020.1.
(2) 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 Section 5024.1. (a-b) Tribal Cultural Resources and Consultation. The California Public Resources Code section 21084.2 establishes that “[a] project with an effect that may cause a substantial adverse change in the significance of a tribal cultural resource is a project that may have a significant effect on the environment.” The Public Resources Code requires a lead agency to consult with any California Native American tribe that requests consultation and is traditionally and culturally affiliated with the geographic area of a proposed project. To date, no such request has been made to the City of Santa Cruz.

The requirements for review of impacts to tribal cultural resources were added after the certification of the General Plan EIR. While there are no known tribal cultural resources meeting the above definition on the project site per the project archaeological report (SOURCE V.14), the project site is located within an area identified as being sensitive for archaeological resources (SOURCE V.1b, DEIR Figure 4.9-1). As described above in Section 5, Cultural Resources, the archaeology review and field survey conducted of the project site concluded that the site appears to have a very low potential archaeological materials and that no prehistoric materials are anticipated to be encountered on the site from project construction or operation (SOURCE V.14). Section 24.12.430 of the City’s Municipal Code sets forth the procedure to follow in the event that unknown archaeological materials are unearthed during construction, as described in Section 5 above. Thus, the project would have a lessthan-significant impact on tribal cultural resources.

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19. UTILITIES AND

SERVICE SYSTEMS
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
a) Require or result in the relocation or
construction of new or expanded
water, wastewater treatment
facilities, or storm water drainage,
electric power, natural gas, or
telecommunications facilities, the
construction or which could cause
significant environmental effects?
DEIR pp. 4.6-21
to 4.6-25,

4.6-41 to

4.6-43, 4.5-29
to 4.5-38
FEIR pp. 3-2 to
3-19
No No None
b) Have sufficient water supplies
available to serve the project and
reasonably foreseeable future
development during normal, dry and
multiple dry years?
DEIR pp. 4.5-3
to 4.5-42
FEIR pp. 3-2 to
3-19
No No
Municipal Code
sections 16.02-
04 regarding
Water
Conservation,
Plumbing
Fixtures, &
Water Service
Charges
c) Result in a determination by the
wastewater treatment provider which
serves or may serve the project that it
has adequate capacity to serve the
project’s projected demand in
addition to the provider’s existing
commitments?
DEIR pp. 4.6-21
to 4.6-25,

4.6-41 to 4.6-43
No No None
d) Generate solid waste in excess of
State or local standards, or in excess
of the capacity of local infrastructure,
or otherwise impair the attainment of
solid waste reduction goals?
DEIR pp. 4.6-25
to 4.6-27,

4.6-43 to 4.6-44
FEIR p. 3-22
No No None
e) Comply with federal, state, and local
management and reduction statutes
and regulations related to solid
waste?
DEIR pp. 4.6-25
to 4.6-27 No No None
(a) Relocation or Construction of Utilities. Subsequent to certification of the General Plan 2030 EIR, the CEQA Guidelines Appendix G questions were modified to include a new question regarding need for new, relocated, or expanded infrastructure systems. The project would be served by existing utilities, and the General Plan EIR concluded that the City’s wastewater treatment facility would be adequate to handle growth and development accommodated by the General Plan and would not require expansion or construction of facilities to serve future growth; see subsection (c) below.

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Because the size of the proposed project would fall within the total amount of potential development analyzed in the General Plan EIR, the proposed project would not result in more severe impacts than evaluated in the General Plan EIR. The project does not require or result in the relocation or construction of new or expanded water, wastewater treatment, storm water drainage, electric power, natural gas, or telecommunications facilities. No further environmental analysis is required pursuant to Public Resources Code section 21083.3 and the State CEQA Guidelines section 15183. (b) Water Supply. The project site is located within the service area of the City of Santa Cruz Water Department, which serves an approximate 20-square-mile area. The service area includes the entire City of Santa Cruz, adjoining unincorporated areas of Santa Cruz County, a small part of the City of Capitola, and coastal agricultural lands north of the City. Water is treated at the City’s Graham Hill Water Treatment Plant (GHWTP), except for groundwater, which is treated as part of the Beltz well system.

The City’s General Plan EIR provides a comprehensive analysis of impacts of water demand within the City’s service area, including potential buildout accommodated by the General Plan. The General Plan EIR predicted that water supplies would be adequate in normal years to serve estimated growth within the City of Santa Cruz water service area, although the document acknowledges that the outcome of the pending Habitat Conservation Plan (HCP) for anadromous fisheries may affect supplies. The General Plan EIR concluded that impacts to the City’s water supply would be significant and unavoidable during times of prolonged drought and potentially significant during normal years by the year 2030. Measures are identified in General Plan policies and actions to further conserve water, reduce demand and implement a desalination facility to provide a supplemental water supply during droughts.

Subsequent to the City’s General Plan 2030, the City adopted the 2015 Urban Water Management Plan (UWMP), and in November 2021, the City adopted the 2020 UWMP. The 2015 UWMP reported that water demand in the City’s water service area has ranged between nearly 3,800 million gallons per year (MGY) in 2006 to approximately 2,500 MGY in 2015 (SOURCE V.2b). The 2020 UWMP reported that annual water use had decreased since the early 2000s, but annual water use fell to a level of about 2.5 billion gallons, similar to the level experienced during the 1970s drought. However, in 2020, demand was still at a similar level as 2015, about 2.6 billion gallons, despite several years above longterm average rainfall from 2016 and 2020. Current projections forecast that water use over the next 25 years, including projected population growth, will increase at a very slow rate to reach approximately 2.8 billion gallons per year by 2045 (SOURCE V.2c).

With implementation of the City’s proposed water rights modifications and water supply augmentation strategies as summarized below, the City projects having sufficient water available in normal years and single dry years to serve anticipated demand throughout the 2020-2045 UWMP planning period. However, the City’s 2020 UWMP predicts that under multi-year drought conditions in the near term (2025) with proposed water rights modifications but before implementation of the planned aquifer storage and recovery (ASR) facilities and planned infrastructure projects, available supplies would meet projected demand in years one through four of the multi-year drought scenario, but would fall short of demand by 27% in year five, although such a shortage could occur sooner and persist longer through a multiple dry year period. Under multi-year drought conditions after 2030,

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with implementation of the ASR and planned infrastructure projects, available supplies would meet projected demand in years one through four of the multi-year drought scenario, and the year-five shortage is anticipated to be substantially reduced with projected shortages no larger than a negligible two percent or five percent with consideration of climate change parameters in dry years (SOURCE V.2c).

The General Plan EIR predicted that water supplies would be adequate in normal years to serve estimated growth within the City of Santa Cruz water service area, although the documents acknowledge that the outcome of the pending HCP may affect supplies. The General Plan 2030 EIR concluded that impacts to the City’s water supply would be significant and unavoidable during times of drought and potentially during normal years by the year 2030 with growth and development within the City’s water service area if recent water use trends change. Measures are identified in General Plan policies and actions to further conserve water, reduce demand and implement a supplemental water supply during droughts.

However, the 2020 UWMP indicates that while the City is vulnerable to water shortages during later years of a multiple dry year period primarily due to the limitation in when and how much water is available to meet system demand, exacerbated by a lack of storage within the system, the City is actively planning and implementing a number of projects and major investments in the water system designed to secure future water supply reliability. Since 2015, the City of Santa Cruz has been pursuing a Water Supply Augmentation Strategy (WSAS) developed by the Water Supply Advisory Committee, a citizen committee, which was formed in 2014 by Santa Cruz City Council with the charge to analyze potential solutions to deliver a safe, adequate, reliable, affordable and environmentally sustainable water supply for the City of Santa Cruz. The WSAS portfolio elements, which are being pursued on a concurrent timeline, include:
• Element 0: Demand Management. Demand Management, or conservation, is not considered a water supply for the purposes of the UWMP, but is addressed in the UWMP 2020. • Element 1: Transfers and Exchanges. The City has been piloting water transfers to the Soquel Creek Water District since 2018, as water supplies are available, under a cooperative piloting agreement that extends through 2025. Potential water transfers and exchanges with local water districts in addition to the Soquel Creek Water District, include Central Water District, Scotts Valley Water District, and San Lorenzo Valley Water District, which would be facilitated by the City’s proposed water rights modifications to place of use as briefly summarized below. • Element 2: Aquifer Storage and Recovery (ASR). The City has been evaluating the feasibility of ASR in both the Santa Cruz Mid-County and in the Santa Margarita Groundwater Basins, with current work primarily focused on the portion of Santa Cruz Mid-County Basin within the City of Santa Cruz service area. Pilot testing has been conducted at the existing Beltz 8 and Beltz 12 well facilities to better understand potential water quality and operational constraints. Implementation of ASR also may occur in the future in the Santa Margarita Groundwater Basin.
• Element 3: Recycled Water or Desalination. Following completion of the 2017 Desalination Feasibility Update Review Report, further study of recycled water has been prioritized over study of seawater desalination. The City is continuing to examine the use of recycled water

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through commissioned engineering studies. The 2018 Recycled Water Facilities Planning Study recommendation includes two projects that would provide non-potable reuse in the City. The City is also committed to exploring other reuse opportunities, including:
coordination with Soquel Creek Water District’s Pure Water Soquel project, exploring groundwater replenishment and reuse at Beltz Well system, and exploring groundwater replenishment and reuse in Santa Margarita Groundwater Basin (SOURCE V.2c).

The City is also pursuing the Santa Cruz Water Rights Project to support the implementation of the WSAS. The project involves the modification of the City’s existing water rights to increase the flexibility of the water system by improving the City’s ability to utilize surface water within existing allocations. This project also incorporates into the City’s water rights bypass flow requirements for all of the City’s surface water sources which are protective of local anadromous fisheries. The primary components of the Santa Cruz Water Rights Project include:
• Water rights modifications related to place of use, method of diversion, points of diversion and re-diversion, underground storage and purpose of use, extension of time, and stream bypass requirements for fish habitats;
• Water supply augmentation components, including new aquifer storage and recovery (ASR) facilities at unidentified locations, ASR facilities at the existing Beltz Well facilities, water transfers and exchanges and intertie improvements; and
• Surface water diversion improvements, including the Felton Diversion fish passage improvements and the Tait Diversion and Coast Pump Station improvements (SOURCE V.2c).

In addition, as required by California Water Code and to manage risks due to water supply shortages that can be expected in the future, the 2020 UWMP includes a Water Shortage Contingency Plan that addresses how the City’s water system would be managed during a water shortage emergency that arises as a result of drought, which could result in required customer water use reductions (SOURCE V.2c). Furthermore, the City continues to administer its water conservation program, has completed a Conservation Master Plan.

As indicated in section IV.B, the City’s General Plan EIR considered development of approximately 3,350 new residential units throughout the City to the year 2030 (SOURCE V.1b, DEIR volume), and the proposed project would be within the total and remaining unbuilt residential development evaluated in the General Plan EIR. Because the number of new residential units falls within the projected number of units within the EIR, the water demand generated by the proposed project would fall within the total level of water demand estimated and analyzed in the General Plan EIR. As indicated above, annual water demand projections are less than what was analyzed in the General Plan EIR, and the City currently predicts potential negligible shortages during multi-year droughts with implementation of proposed water augmentation projects. However, the proposed project would be subject to uniformly applied development standards that include requirements for installation of water conservation fixtures and landscaping for new construction. In addition, the project would pay the required “System Development Charge” for the required new service connection. This charge as

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set forth in Chapter 16.14 of the City’s Municipal Code is intended to mitigate the water supply impacts caused by new development in the City of Santa Cruz water service area, and the funds are used for construction of public water system improvements and conservation programs. Thus, the proposed project would not result in significant impacts related to availability of water supplies not otherwise addressed in the General Plan EIR or peculiar to the project or site with implementation of uniformly applied development standards. No further review is necessary pursuant to CEQA section 21083.3 and the State CEQA Guidelines section 15183.
(b) Wastewater Treatment Capacity. The project would be served by existing utilities, and the General Plan EIR concluded that the City’s wastewater treatment facility would be adequate to handle growth and development accommodated by the General Plan and would not require expansion or construction of facilities to serve future growth. As indicated in section IV.B above, the City’s General Plan EIR considered development of approximately 3,350 residential units within the City to the year 2030 (SOURCE V.1b), and the proposed project is within the total and remaining unbuilt residential units. The EIR analyses concluded that impacts of potential development and buildout accommodated by the General Plan would be less than significant for wastewater treatment. Since the size of the proposed project would fall within the total amount of potential development analyzed in the General Plan EIR, the proposed project would not result in new significant impacts or more severe impacts than evaluated in the General Plan EIR or impacts peculiar to the project or site. No further environmental analysis is required pursuant to Public Resources Code section 21083.3. (d-e) Solid Waste Disposal. The project would be served by existing utilities, and the General Plan EIR concluded that the City’s landfill would be adequate to handle growth and development accommodated by the General Plan and would not require expansion or construction of facilities to serve future growth. As indicated in section IV.B above, the City’s General Plan EIR considered development of approximately 3,350 residential units within the City to the year 2030 (SOURCE V.1b); and the proposed project is within the total and remaining unbuilt residential units. The EIR analyses concluded that impacts of potential development and buildout accommodated by the General Plan would be less than significant for solid waste disposal. Since the size of the proposed project would fall within the total amount of potential development analyzed in the General Plan EIR, the proposed project would not result in new significant impacts or more severe impacts than evaluated in the General Plan EIR or impacts peculiar to the project or site. No further environmental analysis is required regarding solid waste pursuant to Public Resources Code section 21083.3.

20. WILDFIRE
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Standards
If located in or near state
responsibility areas or lands
classified as very high fire hazard
severity zones, would the project:
a) Substantially impair an adopted
emergency response plan or
emergency evacuation?
DEIR pp. 4.6-2
to 4.6-5, 4.6-33
to 4.6-37
No No None

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20. WILDFIRE
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Standards
If located in or near state
responsibility areas or lands
classified as very high fire hazard
severity zones, would the project:
b) Due to slope, prevailing winds, and
other factors, exacerbate wildfire
risks, and thereby expose project
occupants to, pollutant
concentrations from a wildfire or the
uncontrolled spread of a wildfire?
Not Evaluated Not Applicable Not Applicable None
c) Require the installation or
maintenance of associated
infrastructure (such as roads, fuel
breaks, emergency water sources,
power lines or other utilities) that
may exacerbate fire risk or that may
result in temporary or ongoing
impacts to the environment?
Not Evaluated Not Applicable Not Applicable None
d) Expose people or structures to
significant risks, including downslope
or downstream flooding or landslides,
as a result of runoff, post-fire slope
instability, or drainage changes?
Not Evaluated Not Applicable Not Applicable None
(a) Emergency Plans. The project site is not located in or near a state responsibility area or lands classified as very high fire hazard severity zones (SOURCE V.5). See also Section 9(f). (b-d) Emergency Plans. The 2019 CEQA Guidelines amendment added a question regarding wildfire impacts and exposure. The project site is not located in or near a state responsibility area or lands classified as very high fire hazard severity zones; see also 9(g). The project site is located in a local responsibility area. Local responsibility areas are located within incorporated city limits, and therefore, fire protection would be provided by the City’s fire department.

The site is flat and surrounding by development in an urban setting, and is not located near steep slopes. The project would result in construction of habitable structures, but the project would not exacerbate wildfire risks or expose people or structures to significant risks including downslope or downstream flooding or landslides as a result of post-fire conditions. Therefore, no impacts would occur. See also section IV.9(g) above.

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21. MANDATORY FINDINGS

OF SIGNIFICANCE
Where Impact
is Addressed in
General Plan
2030 EIR
Does Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Impacts
Peculiar to
Project or
Site?
Relevant
General Plan
Mitigation
Measures or
Other Uniformly
Applicable
Development
Would the project: Standards
a) Have the potential to substantially
degrade the quality of the
environment, substantially reduce the
habitat of a fish or wildlife species,
cause a fish or wildlife population to
drop below self-sustaining levels,
threaten to eliminate a plant or
animal community, substantially
reduce the number or restrict the
range of a rare or endangered plant or
animal or eliminate important
examples of the major periods of
California history or prehistory?
DEIR pp. 4.8-13
to 4.8-21,

4.8-24, 4.8-26
to 4.8-30,

4.8-41, 4.8-38
to 4.8-44,

4.8-48 to

4.8-51, 4.9-10
to 4.9-12,

4.9-19 to 4.9-23
FEIR pp. 3-22,
3-25 to 3-40
No No
GP Action
NRC2.2.1 &
Project
Assessment
Protocols for
Special Status
Species; GP EIR
Mitigation 4.9-1
and Municipal
Code section

24.12.430
b) Have impacts that are individually
limited, but cumulatively
considerable? (“Cumulatively
considerable” means that the
incremental effects of a project are
considerable when viewed in
connection with the effects of the
past projects, the effects of other
current projects, and the effects of
probable future projects.)
DEIR pp. 5-8 to
5-36
FEIR pp. 3-27 to
3-33
No No None
c) Have environmental effects which will
cause substantial adverse effects on
human beings, either directly or
indirectly?
DEIR pp. 4.13-4
to 4.13-8,

4.13-10 to

4.13-20
No No None
(a) Quality of the Environment. The project would not degrade the quality of the environment or otherwise affect fish and wildlife habitat as discussed in Section 4 (Biological Resources) of this Environmental Checklist review. As discussed in Section 5 (Cultural Resources), the project would have no significant effect on cultural resources with implementation of uniformly applied development standards, regulations, and policies, and would not result in elimination of important examples of a major period of California history or prehistory. (b) Cumulative Impacts. The General Plan EIR identified potential significant cumulative impacts related to traffic, water supply, population, and noise. Vehicle trips resulting from the proposed project would contribute to cumulative noise impacts along Swift Street that were identified in the General Plan EIR. However, project trips would be minimal, and the proposed project is within the

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overall development considered in the General Plan EIR and thus considered in the traffic and noise modeling conducted for the General Plan EIR.

As indicated in Section 13, regional population forecasts have been revised since certification of the General Plan EIR, and cumulative development as a result of development accommodated by the General Plan would not exceed regional population forecasts for the year 2030; therefore, no significant cumulative impacts related to population would occur with project implementation.

The proposed project would contribute to significant cumulative impacts related to water supply identified in the General Plan EIR. As indicated in Section IV.B above, the City’s General Plan EIR considered development of approximately 3,350 residential units within the City to the year 2030 (SOURCE V.1b), and the proposed project is within the total and remaining estimated unbuilt residential units. Furthermore, as explained in Section IV.E.19(b), projected water demands have decreased since certification of the General Plan 2030 EIR. The proposed project would not result in new or more severe significant impacts relating to water supply than analyzed in the General Plan EIR, nor would the project result in any new significant impacts that are peculiar to the site or project that were not considered in the General Plan EIR. The project would be subject to City requirements for installation of water-conserving fixtures and landscaping in accordance with current City Municipal Code and building requirements.

Under multi-year drought conditions, the project, like other City customers, would be subject to water use restrictions. The increase in water demand due to the proposed project would not substantially exacerbate water supply reliability in the future or during a drought because the amount of additional demand when spread across all service area customers would not result in any noticeable increase in the timing or extent of curtailment in customer use that would otherwise be implemented during drought conditions. In addition, the project would pay the required “System Development Charge” for the required new service connection. This charge, as set forth in Chapter

16.14 of the City’s Municipal Code, is intended to mitigate the water supply impacts caused by new development in the City of Santa Cruz water service area, and the funds are used for construction of public water system improvements and conservation programs. Payment of the System Development Charge and implementation of other water conservation measures would mitigate the project’s contribution to cumulative water supply impacts. Therefore, the project’s incremental contribution to a significant cumulative water supply impact would not be cumulatively considerable. Because the potential project contribution to cumulative impacts falls within the total level of those analyzed in the General Plan EIR, no further environmental analysis is required pursuant to Public Resource Code section 21083.3 and CEQA Guidelines section 15183.

The proposed project would contribute to significant cumulative traffic impacts analyzed in the General Plan 2030 EIR. The General Plan EIR identified significant cumulative impacts in the project vicinity at the Delaware Avenue/Swift Street intersections. Improvements are planned as part of the City’s Traffic Impact Fee program that would involve construction of a new roundabout and/or signal.

With implementation of proposed General Plan 2030 policies and actions, including road improvements identified in an updated TIF program, the General Plan EIR concluded that intersection operations would be improved to an acceptable LOS at the Swift/Delaware intersection. While, the proposed project would contribute minor trips to this intersection, the project would be required to

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pay traffic impact fees. Furthermore, changes to CEQA since certification of the General Plan EIR no longer use intersection LOS as a basis for determining transportation impacts. As discussed in Section IV.E.17(b), VMT is the new metric used to evaluate transportation impacts, and the project was found to result in a less-than-significant impact, consistent with City guidelines, and thus would not contribute to potential cumulative impacts related to VMT. There are no significant pending projects within the vicinity of the proposed project, and future development projects would be individually evaluated for potential VMT impacts. There are no new significant cumulative impacts to which the project would contribute that have not been addressed in the General Plan EIR.

Therefore, the proposed project would not result in new significant impacts or substantially more severe impacts than analyzed in the General Plan EIR. Nor would the project result in cumulative water supply or traffic impacts peculiar to the project or site with implementation of uniformly applied development standards. No further review is necessary pursuant to CEQA section 21083.3 and State CEQA Guidelines section 15183.
(c) Substantial Adverse Effects on Human Beings. No environmental effects have been identified that would have direct or indirect adverse effects on human beings.

V. REFERENCES AND DATA SOURCE LIST
Agency Plans and Studies

1. City of Santa Cruz General Plan and EIR
a. Adopted June 26, 2012. General Plan 2030. Available online at https://www.cityofsantacruz.com/government/city-departments/planning-andcommunity-development/long-range-policy-planning/general-plan. b. .April 2012. City of Santa Cruz General Plan 2030 Final EIR. SCH #2009032007. Certified June 26, 2012. Includes Draft EIR document, dated September 2011. Available online at:
https://www.cityofsantacruz.com/government/city-departments/planning-andcommunity-development/long-range-policy-planning/general-plan. c. July 2018. “Cultural Resources Background Report Update with Policies, Programs, and Maps, City of Santa Cruz, Santa Cruz County, California.” Prepared by Dudek. d. May 27, 2020. SB 743 Implementation Guidelines, City of Santa Cruz.

2. City of Sana Cruz Adopted Plans.
a. Adopted October 2018. Climate Adaptation Plan Update 2018-2023. b. Adopted August 2016. 2015 Urban Water Management Plan. Prepared by City of Santa Cruz Water Department.
c. Adopted November 2022. 2020 Urban Water Management Plan. Prepared by the City of Santa Cruz, Water Department. Available online at:
https://www.cityofsantacruz.com/government/city-departments/water/urban-watermanagement-plan-2020.

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3. AMBAG.
a. Adopted June 2018. “2018 Regional Growth Forecast.”
b. Adopted June 2018. Monterey Bay 2040 Moving Forward, 2040 Metropolitan Transportation Plan / Sustainable Communities Strategy.

4. California Department of Finance. May 2021. “Table 2: E-5 City/County Population and Housing Estimates, 1/1/2021.” Available online at:
https://dof.ca.gov/Forecasting/Demographics/Estimates/E-5/documents/E5_2021_InternetVersion.xlsx.

5. California Department of Forestry and Fire Protection (CAL FIRE). 2007. Fire Hazard Severity Zones in SRA Map. Available online at: https://osfm.fire.ca.gov/divisions/wildfire-planningengineering/wildland-hazards-building-codes/fire-hazard-severity-zones-maps/.

6. Monterey Bay Air Resources District. Adopted March 15, 2017. 2012-2015 Air Quality Management Plan. Available online at:
http://www.co.monterey.ca.us/home/showdocument?id=62318.

7. Monterey Bay Unified Air Pollution Control District. a. February 2008. CEQA Air Quality Guidelines. Available online at:
https://www.mbard.org/files/f665829d1/CEQA_full+%281%29.pdf. b. Adopted April 1996-Revised February 2016. Guidelines for Implementing the California Environmental Quality Act.

8. Santa Cruz County Regional Transportation Commission. Adopted June 2018. 2040 Santa Cruz County Regional Transportation Plan.

9. United States Geological Survey. 2021. “U.S. Quarternary Faults.” Accessed online:
https://usgs.maps.arcgis.com/apps/webappviewer/index.html?id=5a6038b3a1684561a9b0aadf 88412fcf
Project Studies and Other References

10. Ifland Engineers. May 2021. “Preliminary Stormwater Control Plan for 415 Natural Bridges Drive, Santa Cruz, California, APN: 003-011-06.”

11. Ifland Engineers. June 1, 2021. “Housing Authority of Santa Cruz County, 415 Natural Bridges Drive, Santa Cruz, California” (preliminary civil plan set, pages C1.0 – C4.0).

12. Maureen Hamb Professional Consulting Services. June 2021. “Tree Resource Evaluation Project Impact Analysis, 415 Natural Bridges Drive.”

13. Megan Bishop Design. April 26, 2021. “Landscape Plan – L1.0, 415 Natural Bridges Drive, Santa Cruz, CA.”

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14. Patricia Paramoure Archaeological Consulting. May 6, 2021. “Preliminary Archaeological Reconnaissance, 415 Natural Bridges Drive, Santa Cruz, Santa Cruz County, California (APN 003- 011-06).”

15. Thacher & Thompson Architects. May 6, 2021. “Housing Authority of Santa Cruz County, 415 Natural Bridges Drive, Santa Cruz, CA” (architectural plan set, pages A1 – A6).

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MANAGEMENT PLAN
For
415 Natural Bridges Drive
Santa Cruz,CA 95060

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Table of Contents
A. Introduction and Purpose
B. Management Policies
C. Rental Procedures
D. Apartment Rental Agreement
E. Maintenance Plans

1. Landscape Maintenance Plan/Integrated Pest Management Plan

2. Stormwater Maintenance/Monitoring Plan
F. Security Procedures

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Section A. Introduction and Purpose
This Management Plan has been prepared to guide and direct the Manager and tenants of 415 Natural Bridges Drive. This Management Plan is intended to satisfy City of Santa Cruz Municipal Code Section 24.12 regarding Single Room Occupancy Housing. In addition, this Management Plan is intended to satisfy applicable Conditions of Approval for development applications associated with Development application # CP21-0059. For the purposes of this document, the property and buildings located at 415 Natural Bridges Drive shall be known as "the Project.” This Management Plan may be refined and/or modified in the future to accommodate conditions or situations unanticipated at the time of preparation of this document.

Section B. Management Policies
Residential

1. In accordance with City of Santa Cruz Municipal Code Section 24.12.1040, the Project shall have a Responsible Party/Caretaker that is available to serve as a contact person for the property management company, 24 hours per day. The Responsible Party/Caretaker for the Project shall reside on the project site as designated by the property management company. The property management company shall be responsible for carrying out all leasing functions and enforcing the rules and regulations of the complex.

2. The property management company shall comply with all local State, and Federal laws and regulations regarding the selection of tenants. Neither the Responsible Party/Caretaker nor the property management company and/or the owner of the Project shall discriminate against prospective tenants on the basis of actual or perceived sex or gender, sexual orientation, marital status, disability, age, color, race, ethnicity, national origin, religion or any other protected class.

3. The Responsible Party/Caretaker, the property management company and/or the owner of the Project shall comply with City of Santa Cruz Municipal Code

25.133
Section 24.16 in regard to renting of the twenty (20) low-income housing units.

4. It shall be the policy of the property management company of the Project to provide a high level of maintenance of the buildings (both interior and exterior) and the grounds (landscaping and site improvements) of the Project.

The property management company of the Project shall conduct regular inspections of the buildings and the grounds and schedule maintenance work as needed. Inspection of the inside of the apartments shall also occur at regularly scheduled intervals.

5. The property management company shall be responsible for filling vacancies with eligible low-income households and to select and retain tenants who are respectful of their neighbor's desire for privacy and quiet. Tenants who violate their lease shall be cited in writing by the property management company. Tenants who continue to violate the rules may be evicted by the property management company but only with the approval of the property owner, and as a last resort after all other remedies have been exhausted.

6. It shall be the policy of the property management company and the owner of the Project to protect the environment to the extent feasible. The property management company of the project will conduct, or cause to be conducted, all regular inspections of the storm drain system including stormwater filtration devices in accordance with the requirements of this Management Plan.

7. It shall be the policy of the property management company and owner of the Project to minimize energy use. To that end, energy efficient "Energy Star" appliances will be installed in each unit and Laundry Room.
. .

Section C. Residential Rental Procedures

1. Prospective tenants will obtain a Rental Application from the property management company. Prospective tenants will complete that Rental Application for review by the property management company.

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2. After the prospective tenant completes the application, the property management company will review the application and conduct a screening process to determine if the applicant meets the rental criteria that is in place.

All prospective applicants will be asked for some form of identification such as a driver's license, passport, or military ID so that the property management company can confirm the identity of the Applicant. The property management company will also verify the identification with information given on the rental application such as the social security number, driver's license number, and current address. The property management company may request from the prospective tenant any personal information permitted by law including, but not limited to, references regarding rental history, income, employment and credit information, and such information may be used by the property management company in determining the applicant’s acceptability.

3. If a Rental Application is deemed acceptable and the property management company decides to rent or lease an apartment to the Applicant, property management company will ensure that a written lease or rental agreement is exercised between the parties.

4. If an Applicant does not meet the application criteria, the property management company will document the basis of that decision. The property management company will be honest, direct, and polite in informing the applicant of the decision.

The property management company will not have the power to deviate from the established tenant selection criteria and all criteria will be enforced uniformly for all prospective tenants. Upon the tenant being informed that the application does not meet the required criteria, the applicant will have the right to appeal the decision to the property owner.

Section D. Sample Apartment Rental Agreement – See Attached Exhibit B

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. . .

Section E. Maintenance Plans

1. Landscape Maintenance Plan/Integrated Pest Management Plan Landscape maintenance services will be provided by a professional company experienced in all facets of landscape maintenance, irrigation maintenance, and Integrated Pest Management. Said company(ies) will furnish all labor, supervision, tools, and equipment necessary to maintain all landscaped areas of the project site in accordance with the specifications below. Whenever feasible, Integrated Pest Management techniques will be employed by the landscape maintenance company in lieu of using · pre-emergent or postemergent herbicides,fungicides, and insecticides.

Water and Irrigation
All water for the landscaping will be supplied by the City of Santa Cruz Water Department and the Landscaping Company shall provide' the necessary oversight for irrigation.

Automatic irrigation shall be accomplished on a scheduled basis with such frequency as to promote healthy growth. This shall be accomplished by adjusting the automatic_ controller, based upon changes in rainfall and temperature. Any damage to the irrigation system shall be promptly repaired by the landscape maintenance contractor.

Trees, Shrubs and Vines
Pruning, thinning, and trimming of shrubs and trees, and training and trimming of vines, shall be accomplished on a regular basis to maintain a neat appearance and promote healthy growth. Work will include removal of suckers, crossed branches and dead wood. Staking of trees shall be inspected regularly and changed as required to permit growth expansion.

Pruning of trees above 15 feet in height shall be accomplished under the direction of a professional tree company.

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.

Ground Cover and Flower Beds
Maintenance shall consist of trimming ground cover around trees, shrubs, etc. Beds shall be weeded and cleaned of leaves and debris to maintain a neat and clean appearance.

Walkways, Patios and Driveways
Leaves and debris shall be removed from paved areas on a regular basis to provide a neat and clean appearance.

Bio-retention/filtration area
Maintenance shall consist of inspecting the bio-retention/filtration area on a regular basis and removing leaves and landscape debris that could impede water flow in the swale. If the swale accumulates excessive sediment, it shall be removed from the swale.

Miscellaneous Inclusions
Landscape maintenance shall include collection of trash in landscaped or hardscaped areas.

Integrated Pest Management Guidelines
A. Perform thorough in- field assessments of each pest problem.

B. Use pest resistant plants and planting systems that minimize pest infestation.

C. Establish injury levels and action· thresholds for each individual pest species based upon how much biological, aesthetic, or economic damage the site can tolerate to determine when corrective action must be initiated.

D. Establish scouting or inspection procedures to monitor pest population levels and severity of the pest problem.

E. Select corrective actions using the following criteria:
• Least disruptive of natural controls
• Least hazardous to human health
• Least toxic to non-target organisms
• Least damaging to the general environment
• Most likely to produce permanent reduction of the pest easiest to carry out

25.137
effectively
• Most cost-effective in the short-term and long-term
F. The guidelines should be modified as needed to effectively manage pest problems
Stormwater Maintenance/Monitoring Plan
The project is provided with a bio-retention/filtration area located with the front landscaped area.

A. Maintenance of the bio-retention/filtration area
Maintenance of the bio-retention/filtration area is not particularly labor-intensive. However, the following procedures must be followed on a regular basis to ensure proper operation of the system over time.

1. The swale should be inspected and cleared of leaves and landscape debris by the landscape maintenance company at least once a month.

2. The property management company shall inspect the swale on a regular basis to ensure that it is not blocked by debris or accumulated sediment. If any blockage has occurred, the property management company will instruct the landscape maintenance crew to remove the sediment or debris.

3. The property management company will inspect parking lot areas for oil/grease stains on a regular basis to insure property maintenance of the driveway is being sustained. If excessive stains are found, oil absorbers will be used, and the resulting debris shall be disposed of properly. Vehicles that repeatedly stain parking areas with oil or grease may be prohibited from parking on the project site at the discretion of the property management company.

4. The property management company will strictly enforce rules prohibiting washing of vehicles and repair of vehicles on the project site.

25.138
Section F: Security Procedures
A. The property management company will oversee security for the property.

B. The property management company will be available to all tenants who identify specific security concerns. The property management company will investigate all security concerns raised by said tenants. The property management company will involve the Santa Cruz Police Department if necessary.

C. The property management company will regularly inspect all area of the grounds and buildings. The inspection will include checking the parking lot.

D. The property management company will perform or cause to be performed, regular inspections of all fire safety and life safety equipment located on the project site. The property management company will repair or replace any damaged or ineffective equipment.

E. The Laundry Room will remain locked and be accessible only to tenants with keys.

Issuance and return of these keys will be controlled by the property management company.

F. The property management company will ensure that fencing and lighting are maintained in good working condition.

25.139

25.140

CITY OF SANTA CRUZ
City Hall
809 Center Street
Santa Cruz, California 95060

PLANNING COMMISSION
Regular Meeting

ACTION SUMMARY
March 17, 2022
Call to Order-The meeting was called to order at 7:00 p.m.

Roll Call-Commissioners Conway, Greenberg, Kennedy, Maxwell, Mesiti-Miller, Schiffrin, and Dawson were present.

Absent w/notification-None.

Statements of Disqualification-Commissioner Schiffrin recused himself from hearing item 2 to avoid the appearance of a conflict due to his service on the Housing Authority Board of Commissioners.

Oral Communications-None.

Consent Public Hearing

17. City-Wide Project No. A22-0001 Green Building Zoning Ordinance Amendment MOTION: Motion made by Commissioner Kennedy, seconded by Commissioner Schiffrin, to recommend to City Council approval of the proposed amendment to Chapter 24.15 of the Municipal Code (Green Building Regulations) by making the findings referenced in the staff report dated March 11, 2022.

ACTION: The motion passed by the following vote:

AYES: Conway, Greenberg, Kennedy, Maxwell, Mesiti-Miller, Schiffrin, and Dawson
NOES: None
ABSENT: None

25.141
Public Hearings

2. 415 Natural Bridges Drive Project No. CP21-0059 Lot Line Adjustment, Planned Development Permit, Design Permit, and Coastal Permit to transfer 4,054 square feet of land to/ from APN 003-011-10 and construct a 100% affordable, 20 unit SRO (Single Room Occupancy) project with a variation to allowed uses to allow an SRO use and variations to development standards for building height, side yard setback, and number of required parking spaces on a vacant lot in the R-L/CZ-O/SP-O (Multiple Residence - Low-Density/Coastal Zone Overlay/Shoreline Protection Overlay) zone district. This project involves the removal of four Heritage trees.

MOTION: Motion made by Commissioner Greenberg, seconded by Commissioner Kennedy, to recommend approval of the Planned Development Permit, Design Permit, Coastal Permit, and Lot Line Adjustment to City Council based on the environmental determination, findings included in the staff report, and the Conditions of Approval listed in Exhibit “A” in the staff report dated March 11, 2022, and with the amended condition number 17 as follows:

17. All utilities and transformer boxes shall be placed underground in accordance with the provisions of Section 24.12.700 through 24.12.740 of the Zoning Ordinance.

Transformer boxes shall be placed underground to the extent feasible. Any transformer boxes placed above ground shall be shown on final building permit plans with a location and visual screening approved by the Planning Department.

ACTION: The motion passed by the following vote:

AYES: Conway, Greenberg, Kennedy, Maxwell, Mesiti-Miller, and Dawson NOES: None
ABSENT: Commissioner Schiffrin (See statements of Disqualification) Information Items
Subcommittee/Advisory Body Oral Reports
Items Referred to Future Agendas
Adjournment-The meeting adjourned at 7:48 p.m.

25.142
1 Rosemary Balsley
From: Rafa Sonnenfeld <[email protected]>
Sent: Monday, April 25, 2022 4:32 PM
To: City Council
Subject: In Support of Affordable Housing - 415 Natural Bridge Dr Good Afternoon,
I am writing to support the 100% affordable housing project proposed at 415 Natural Bridges Dr. Santa Cruz needs as much affordable housing as possible, and this project makes some very reasonable zoning variance requests that will allow it to maximize the use of this space for affordable housing.

Thank you,
Rafa

25.143

CITY COUNCIL

AGENDA REPORT
DATE: April 19, 2022
AGENDA OF: April 26, 2022
DEPARTMENT: Planning and Community Development
SUBJECT: A20-0008: Slope Regulation Ordinance Amendments to Chapters 18.45, 24.04,

24.08, 24.14, and 24.22 of the Santa Cruz Municipal Code (PL) RECOMMENDATION: Introduce for publication an ordinance amending Chapters 18.45,

24.04, 24.08, 24.14, and 24.22 of the Santa Cruz Municipal Code (SCMC), acknowledging the Addendum to the 2030 General Plan certified Environmental Impact Report (EIR).

BACKGROUND: The Slope Regulations in the City’s Zoning Ordinance regulate development on slopes of thirty percent or greater. They were last updated in 1995 and implemented policies of the previous General Plan (General Plan 1990-2005). The 2030 General Plan provides specific direction to consider revisions to slope development provisions in the Zoning Ordinance in accordance with best management practices and technical analyses, rather than solely based on the proximity to land with a particular percentage of slope. The revisions under consideration with the subject amendments have been contemplated for the past decade, since the General Plan’s approval in 2012, and they respond to the new General Plan policies.

Staff originally proposed amending the slope regulations to implement the 2030 General Plan policies with a package of other ordinance amendments in 2020. At the Planning Commission (Commission) public hearing for this ordinance on September 17, 2020, the Planning Commission voted to continue the Slope Regulation amendments to a date uncertain. Staff had offered additional code revisions shortly before the hearing, and Planning Commission felt it would be of benefit to have this ordinance receive separate discussion and evaluation at a later date. They also expressed concerns about the environmental review for the ordinance.

Staff contracted with an environmental consultant to prepare an Addendum to the 2030 General Plan EIR and presented the amendments to the Planning Commission on January 20, 2022, where the Commission voted 4-3 to recommend approval of a portion of the amendments related to minor development but continued the remaining portion due in part to concerns regarding environmental review. Staff provided revisions to the Addendum and provided a memo from California Environmental Quality Act (CEQA) and land use legal specialists Remy, Moose, Manley, LLP (RMM) to the Planning Commission on February 17, 2022, when the Planning Commission voted 5-2 to recommend that the Council approve the whole amendment package.

Discussion of the amendments is included below, including more detail on the Planning Commission’s recommendations, and more detailed information is in the attached Planning Commission staff reports.

26.1 DISCUSSION: In addition to the direction in the 2030 General Plan, the Current Planning Division regularly receives applications for minor projects such as deck extensions or terracing projects on sloped properties. These projects either require significant investment in time and money for a public hearing or must be denied under the current ordinance even when the project is minor and would not result in unstable slope conditions. This is because the percent of slope is not necessarily indicative of whether development would result in unstable slope conditions. The proposed amendment to the slope regulations would revise the dependence on percent of slope and instead base slope development decisions on geotechnical reports based on the specific conditions of the property and the proposed development.

The current slope regulations are based on the recommendations of the 1990-2005 General Plan, which laid out specific restrictions to development on or within 20 feet of slopes greater than 30 percent and prohibited development on or within 20 feet of slopes greater than 50 percent. The 2030 General Plan, approved in 2012, does not include those restrictions and instead contains policies related to development on slopes that are science-based and centered on the individual characteristics of the property, not just the steepness of the slope itself. The following policies and actions are recommended by the 2030 General Plan:
 CD 1.3.2 Update the Zoning Ordinance to address new construction techniques and “best management practices” related to construction on slopes.  CD 1.3.3 Review the slope development provisions of the Zoning Ordinance and update them as deemed necessary.
 HZ6.2 Discourage development on unstable slopes.
 HZ6.2.1 Recommend requiring engineering geology reports when, in the opinion of the City’s Planning Director, excavation and grading have the potential for exposure to slope instability or the potential to create unstable slope or soil conditions.

Proposed Code Changes
Based on this direction from the General Plan, this proposed amendment to the slope regulations has three key features: (1) precludes minor projects that would not have visual impacts or affect slope stability from needing a discretionary planning permit, though they could still trigger a building permit; (2) institutes a Slope Development Permit requirement where qualifying projects proposed on slopes between 30 and 50 percent are to be processed administratively and qualifying projects proposed on slopes above 50 percent require a Zoning Administrator public hearing; and (3) requires, where a Slope Development Permit is triggered, a site-specific geological review to determine whether such projects are feasible and what engineering and architectural strategies are necessary to ensure the safety and visual compatibility of the slope development.

The intent of this proposed amendment is to move from a somewhat arbitrary development standard based strictly on setbacks from an area with a certain slope percentage to a process that examines the specifics of the site to determine whether development is feasible. Staff held a series of meetings with design professionals including architects, engineers, and geotechnical engineers to discuss options from a technical standpoint. Several suggestions from the design professionals were incorporated into the ordinance revisions including the type of technical report required and the types of projects that can safely be exempted from the requirement for a slope development permit. Staff also held two community meetings related to the proposed amendments (the first on December 9, 2020 and the second on May 24, 2021) as well as one community meeting on July 23, 2020 when the slope ordinance was one of the packet of cleanup

26.2 items addressed. Staff also developed a web page that describes the proposed amendment and provides contact information for the public to provide input. Public input included agreement that smaller projects that would not affect slope stability or public views should be allowed without a specific slope development permit and concern that larger projects receive a public hearing. Because the types of larger projects that were of concern to the public would require other permits such as design permits and/or use permits that would require public hearings, staff does not believe that it is necessary to include additional public hearing requirements to address this concern.

Local Coastal Program
As this ordinance is also part of the City’s Local Coastal Program (LCP) implementing measures, it was brought to the Planning Commission as an LCP Amendment as well as a Zoning Ordinance Amendment. However, the current LCP is still based on the 1990-2005 General Plan, which includes the prescriptive language that is proposed to be removed from the slope regulations. Staff is in the process of updating the LCP, so Coastal Commission and City staff agreed that it would be more productive to bring the LCP Amendment forward at a later date, after the LCP is updated to be consistent with the current General Plan. In the meantime, the current regulations would still apply in the Coastal Zone, with the amended regulations in effect outside the Coastal Zone. Relatively few developable properties with slopes over 30 percent are within the Coastal Zone, so this Coastal Commission delay will have minimal implications (mostly on the western side of Western Drive) until the LCP is updated. These changes inside the Coastal Zone will be brought back to the Council as LCP and Zoning Ordinance Amendments after the LCP itself has been updated.

Planning Commission Summary
The proposed amendment was presented to the Planning Commission on January 20, 2022. One Commissioner was concerned about the impacts of the proposed amendment combined with the impacts of SB 9, a bill recently passed by the State legislature that allows most single-family properties to be subdivided into two parcels, each of which could have two units. The City’s CEQA consultant had already prepared an Addendum to the City’s General Plan 2030 EIR that addressed potential environmental impacts of the proposed amendment. Following the Commissioner’s comments, staff provided a verbal response with the legal opinion from staff’s discussions with RMM, stating that the impacts of SB 9 were independent of the impacts of the proposed amendment. The Commissioner remained unconvinced, and a second Commissioner expressed concerns about climate change, particularly related to increased danger from wildfires.

At the January 20, 2022 meeting, the Commission then voted 4-3 to recommend approval to City Council of only one portion of the amendment (Section 24.14.030(g) regarding minor development). They continued the remainder of the amendment “for additional CEQA review to incorporate potential impacts of development in areas of steep slopes from increased development potential on projects on parcels in single family districts that were not considered in the 2030 General Plan EIR, to provide additional analysis of potential wildfire impact, and to evaluate the elimination of the prohibition of development on 50 percent slopes with the increased development potential in single family districts.” For the next Planning Commission public hearing, staff provided the Commission with a written legal memo from land use and CEQA law specialists RMM (attached). In their legal opinion, RMM demonstrated that the addendum was the appropriate review and clearance method under CEQA. The legal memo also analyzed the questions related to SB 9 in relation to the proposed

26.3 amendment and determined that changes in State law subsequent to the approval of an environmental review did not trigger the need for a new analysis and that environmental review of a “project” was limited to the impacts of the project and did not include the impacts due to changes in State law. The City’s CEQA consultant also revised the Addendum to include additional information related to potential wildfire impacts to address concerns expressed at the first Planning Commission public hearing. More detail on CEQA is in the Environmental Determination section below.

This item was considered again by the Planning Commission on February 17, 2022. Staff prepared an additional staff report that concentrated on areas of concern expressed at the previous Planning Commission meeting and also provided written responses to the continued concerns expressed by one Commissioner. After reviewing that updated report, the revised Addendum, the RMM legal memo, and responses from City staff, the Planning Commission voted 5-2 to recommend that City Council acknowledge the Addendum and approve the proposed ordinance amendment.

More detail about the ordinance amendment is in the two Planning Commission staff reports, the Addendum, the legal memo by RMM, and the Commissioner correspondence with staff responses, all attached to this staff report.

Amendment Correction
In reviewing the proposed amendment in preparation for the City Council submittal, staff realized that the wording in the description of the review trigger could cause confusion. The description for the review of greater slopes was “on or within 20 feet of a 50% or greater slope,” while the description of the review for lesser slopes was “on or within 20 feet of a 30% to 50% slope.” As written, there might be some confusion as to the proper process for a slope that is exactly 50%. To rectify this issue, the proposed ordinance has been amended to state “on or within 20 feet of a slope greater than or equal to 30% and less than 50%.” HEALTH IN ALL POLICIES (HiAP): In 2019, the City adopted a Health in All Policies strategy in order to eliminate inequities in health and well-being and attain equity for all residents. The proposed revisions to the Slope Regulations support the City’s HiAP strategy as the intent of the revisions is to remove existing burdens in the development process for property owners and their tenants on sloped properties and to support development of housing in additional areas of the City where said development would not create safety or slope stability concerns.

ENVIRONMENTAL DETERMINATION: The proposed revisions to the Slope Regulations are consistent with the City’s 2030 General Plan and, therefore, are covered by the 2030 General Plan EIR certified by the City Council on June 26, 2012. To ensure consistency with the California Environmental Quality Act (CEQA), the City retained Dudek, an environmental and planning firm, to review the ordinance for consistency with the 2030 General Plan and the EIR.

Dudek prepared an Addendum to the EIR for the proposed amendments (see attached). Pursuant to Section 15164 of the State CEQA Guidelines, an addendum to a certified EIR may be prepared if only minor technical changes or additions are necessary and none of the conditions described in State CEQA Guidelines Section 15162 that call for preparation of a subsequent EIR have occurred. Dudek determined that none of the conditions listed in Section 15162 that would require the preparation of a subsequent EIR would occur with the approval of the proposed amendment to the slope regulations.

26.4 Based on comments from one Commissioner, staff consulted with land use and CEQA law specialists at RMM. RMM provided the City with a legal opinion regarding whether an addendum to the 2030 General Plan EIR was the appropriate review method under CEQA and whether the passage of SB 9 created new or changed circumstances that required additional CEQA analysis (see attached legal memo from RMM). RMM asserted that the proposed amendment would not change the impacts of SB 9, and CEQA analysis is required only on changes that a project makes to the environment. RMM also noted that new legal enactments do not trigger the need for subsequent environmental review in general and are not considered to be a change in the circumstances under which the General Plan EIR was undertaken. RMM stated that CEQA does not require review of speculative development and case law has determined that development that is possible but not a part of the proposed project is speculative and, therefore, does not require review. In addition, any such SB 9 development is, by law, ministerial and therefore exempt from CEQA.

FISCAL IMPACT: The proposed amendment would have no direct impacts on the General Fund. While this proposed amendment seeks to eliminate permits required for minor slope development and to streamline the approval process with one slope permit type rather than two, these reductions would also correspondingly reduce staff and Planning Commission time spent processing such permits, so there would be minimal to no impact on the General Fund.

Prepared by:

Katherine Donovan
Senior Planner
Matt VanHua
Principal Planner
Submitted by:

Lee Butler
Director of Planning and
Community Development
Approved by:

Matt Huffacker
City Manager
ATTACHMENTS:

1. Ordinance - clean copy

2. Ordinance – track changes

3. Slope Regulation General Plan 2030 EIR Addendum, revised February 2022

4. Staff Report for the January 20, 2022 Planning Commission meeting

5. Minutes of the January 20, 2022 Planning Commission meeting

6. Staff Report for the February 17, 2022 Planning Commission meeting

7. Minutes of the February 17, 2022 Planning Commission meeting

8. Email from Com. Schiffrin dated January 18, 2022, with Staff’s response and Com.

Schiffrin’s response to staff’s responseCom. Schiffrin’s response to attorney’s opinion, 2/14/2022, with responses from staff

9. Legal opinion memo from Remy, Moose, Manley, dated February 7, 2022

10. Public Correspondence

26.5 Attachment 1
ORDINANCE NO. 2022-XX

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF SANTA CRUZ AMENDING CHAPTERS 18.45, 24.04, 24.08, 24.14, AND 24.22 OF THE CITY OF SANTA

CRUZ MUNICIPAL CODE TO REVISE THE REQUIREMENTS FOR DEVELOPMENT ON SLOPED PROPERTY TO BE BASED ON SITE-SPECIFIC GEOTECHNICAL REPORTS.

THIS ORDINANCE ALSO AMENDS THE LOCAL COASTAL PROGRAM TO INCLUDE

THESE AMENDMENTS
BE IT ORDAINED By the City of Santa Cruz as follows:

Section 1. Chapter 18.45 “Excavation and Grading” of the City of Santa Cruz Municipal Code is hereby amended as follows:

Chapter 18.45 EXCAVATION AND GRADING REGULATIONS

18.45.010 through 18.45.020 – no change.

18.45.030 GENERAL GRADING PERMIT REQUIREMENTS.
(3) Prohibited Grading Areas. No grading permit shall be issued for a project located in a protected natural resource area, including species-protected area, archaeologically sensitive area, riparian corridor, or on slopes of thirty percent or greater unless an appropriate zoning permit for the special area is first obtained. No grading permit shall be issued within twenty feet of any thirty percent or greater slope, unless a slope development permit pursuant to Section 24.08 (Part 9) of the Zoning Ordinance is first obtained.

18.45.035 through 18.45.150 – no change.

Section 2. Chapter 24.04 “Administration” of the City of Santa Cruz Municipal Code is hereby amended as follows:

Chapter 24.04 – ADMINISTRATION

24.04.010 through 24.04.020 – no change.

24.04.030 TYPES OF PERMITS AND OTHER ACTIONS AUTHORIZED BY THIS TITLE.

The following permits and actions are established in order to carry out the purposes and requirements of this title:

1. Appeals;

2. Coastal permit;

26.6 3. Conditional driveway permit;

4. Conditional fence permit;

5. Design permit;

6. Demolition/conversion permit:
a. Demolition authorization permit for residential structures, b. Historic demolition permit;

7. Extension of permits;

8. Historic building survey: building designation and deletion;

9. Historic alteration permit;

10. Administrative historic alteration permit;
10a. Historic landmark designation;

11. Mobile homes: certificate of compatibility;

12. Mobile home park conversion;

13. Planned development permit;

14. Relocation permit;

15. Revocation of permits;

16. Signs:
a. Design permit (for signs),
b. Building permit (for signs),
c. Sign permit – public art exception;

17. Slope Development Permit (on or within 20 feet of a slope greater than or equal to 30% and less than 50%)
18 through 23 – no change.

24.04.040-24.04.080 – no change.

24.04.090 PUBLIC HEARING REQUIREMENT.

A public hearing shall be required for the following:
1 through 10 – no change.

11. Slope Development Permit (on or within 20 feet of a 50% or greater slope)

12. Relocation of structures;

13. Revocation of permits;

14. Use permits:
a. Administrative use permit, except when the proposed use is temporary, as defined in this title; for variations to parking design requirements and number of spaces; and half baths in accessory structures;
b. Special use permit (including historic district/historic landmark use permit);

15. Variance;

16. Watercourse variance;

17. Project modifications, pursuant to Section 24.04.160(4)(c);

18. Zoning Ordinance and General Plan text and map amendments.

26.7 24.04.100 through 24.04.120 – no change.

24.04.130 DECISION-MAKING BODY WITH FINAL AUTHORITY ON APPLICATION APPROVAL.

The following table indicates the decision-making body who can approve, deny or conditionally approve an application, whether or not a public hearing is required, and the bodies to which appeals can be made:

1. The planning commission and city council may refer certain aspects of any application to the zoning administrator for final action.

2. The zoning administrator may refer any of the matters on which he/she is authorized to act to the planning commission or historic preservation commission.

3. Recommendations for approval on General Plan matters and zoning ordinance text and map amendments shall require a majority vote of the planning commission; all other actions shall require a majority of the hearing body present at the meeting.

Public Hearing Requirement and
Decision-Making Body Which Can
Approve an Application
No
Public
Hearing
Public Hearing
Permits/Actions**** Action Recommendation Action
Appeal Bodies
(in order)
Coastal Permit ZA
(ADU)
ZA* CPC/CC/CCC*
Administrative Use Permit:

Large Family Daycare Homes
and Temporary Uses

ZA CPC/CC
Other uses as listed by individual
zoning districts as requiring an
Administrative Use Permit

ZA CPC/CC
Conditional Driveway Permit ZA CPC/CC
Conditional Fence Permit ZA ZA CPC/CC
Slope Development Permit (on
or within 20 feet of a 50% or
greater slope)

ZA CPC/CC
Slope Development Permit (on
or within 20 feet of a slope that
is greater than or equal to 30%
and less than 50%)

ZA CPC/CC

26.8 Public Hearing Requirement and
Decision-Making Body Which Can
Approve an Application
No
Public
Hearing
Public Hearing
Permits/Actions**** Action Recommendation Action
Appeal Bodies
(in order)
Design Permit – ZA CPC/CC
Substandard lots: new two-story
structures and second-story
additions, including ADUs

ZA CPC/CC
Substandard lots: single-story
ADUs

ZA CPC/CC
Large homes per Section

24.08.450

ZA CPC/CC
Wireless telecommunications
facilities

ZA ZA CPC/CC
New structures or improvements
to existing structures in the
WCD Overlay which are exempt
or excluded from coastal permit
requirements

ZA CPC/CC
New structures or improvements
to existing structures in the
WCD Overlay which require a
coastal permit

ZA CPC/CC
Demolition Permit

1. Single-family residential ZA CPC/CC

2. Multifamily residential CPC CC

3. Historic demolition permit HPC CC

4. Nonresidential ZA** ZA** CPC/CC
General Plan Text and Map
Amendments
CPC CC/CCC***
Historic Alteration Permit HPC CC
Administrative Historic
Alteration Permit

ZA HPC/CC
Historic Building Survey:

Building designation, deletion HPC CC

26.9 Public Hearing Requirement and
Decision-Making Body Which Can
Approve an Application
No
Public
Hearing
Public Hearing
Permits/Actions**** Action Recommendation Action
Appeal Bodies
(in order)
Historic District Designation HPC/CPC CC
Historic Landmark Designation HPC CC
Mobile Homes (Certificate of
Compatibility)

ZA CPC/CC
Mobile Home Park Conversion CPC CC
Outdoor Extension Areas per
Section 24.12.192

ZA CPC/CC
Planned Development Permit CPC CC
Project (Major) Modification Hearing by ZA or body
approving application
Appeal to next
highest body(ies)
Project (Minor) Modification ZA CPC/CC
Relocation of Structures Permit ZA CPC/CC
Revocation Permit Hearing by ZA or body
approving application
Appeal to next
highest body(ies)
Sign Permit ZA CPC/CC
Special Use Permit CPC CC
Variance ZA CPC/CC
Watercourse Variance CPC CC
Watercourse Development
Permit

ZA CPC/CC
Zoning Ordinance Text and Map
Amendments
Amendments recommended by
CPC
CPC CC/CCC***
Amendments not recommended
by CPC
CPC CC/CCC***
CCC = California Coastal Commission CC = City Council CPC = City Planning Commission
HPC = Historic Preservation Commission ZA = Zoning Administrator

26.10 Public Hearing Requirement and
Decision-Making Body Which Can
Approve an Application
No
Public
Hearing
Public Hearing
Permits/Actions**** Action Recommendation Action
Appeal Bodies
(in order)
* For projects seaward of the mean high tide line, and in the case of appealable actions, the California Coastal Commission shall be the decision-making body which can finally approve an application.
** Such permits shall be issued administratively, without a public hearing, unless a cultural resources evaluation, prepared by a qualified consultant as determined by the zoning administrator, determines that the building or structure is eligible for listing on the city Historic Building Survey.
*** California Coastal Commission in case of CLUP policy, CLIP elements. **** At a regularly scheduled meeting, a majority of the council may take an action to direct any project or amendment to be called from a lower hearing body prior to a final action or during an appeal period in accordance with Section 24.04.175(2).

24.04.140 through 24.04.250 – no change.

Section 3. Part 8: Planned Development Permit and Part 9: Slope Regulations Modifications of Chapter 24.08 “Land Use Permits and Findings” of the City of Santa Cruz Municipal Code are hereby amended as follows:

Chapter 24.08 LAND USE PERMITS AND FINDINGS
Part 8: PLANNED DEVELOPMENT PERMIT

24.08.700 through 24.08.710 – no change.

24.08.720 GENERAL PROVISIONS.

A planned development permit provides variation on district regulation, where appropriate, in the following areas:

1. Building setbacks.

2. Street standards.

3. Lot coverage.

4. Parking and loading.

5. Landscaping.

6. Open space.

7. Lot area.

26.11 8. Uses.

9. Height, not to exceed one story or twenty percent of height (in feet) over and above regulations established in district regulations for the district in which the project is proposed.

All aspects of the proposed development which represent a departure from strict application of district regulations shall be explained in the application and reasons given why the proposed development plan affords greater public benefits than would be achieved through application of conventional zoning regulations.

24.08.730 through 24.08.790 – no change.

Part 9: SLOPE DEVELOPMENT PERMIT

24.08.800 PURPOSE.

Development on slopes presents opportunities and challenges. Construction on unstable slopes can lead to erosion, steep terrain can present wildfire and evacuation hazards, and buildings constructed on hilltops often have exceptional views while having the potential to adversely impact public views. Such development is therefore regulated by the provisions of Section

24.14.030 (slope regulations) to ensure that risks to public and private property and adverse impacts to public views are minimized. “Public views” include scenic views of the ocean, beaches, and the Santa Cruz Mountains from public property, including from parks and public rights-of-way. This section is also part of the Local Coastal Implementation Plan.

24.08.810 PROCEDURE.

Projects on or within twenty feet of a slope of thirty percent or greater must apply for a slope development permit unless the project is exempted from the need for such a permit under Section

24.14.030(1)(g). This permit may be granted by the zoning administrator under Section

24.14.030(1)(c) without a hearing if the project is on or within twenty feet of a slope greater than or equal to thirty-percent and less than fifty-percent and is consistent with the findings in Section

24.08.820, unless the slope development permit is accompanied by an application that must be heard by a higher body. Projects on or within twenty feet of a slope of fifty percent or greater must be considered at a public hearing by the zoning administrator and must also be consistent with the findings in Section 24.08.820 unless the project is exempted from such a permit per Section 24.14.030(1)(g). In the case of construction of an accessory dwelling unit pursuant to Section 24.16.100 et seq., this section shall apply only when alternative site configurations are available to an applicant that would permit the construction of a detached accessory dwelling conforming to the development standards in Section 24.16.140 without the need for a slope development permit; when no alternative site configuration will allow the construction of a detached accessory dwelling unit in conformance with Section 24.16.140, the applicant shall comply with the maximum possible number of findings in Section 24.08.820, but shall not be denied a building permit for the accessory dwelling unit based on this section.

26.12 24.08.820 FINDINGS REQUIRED.

A slope development permit may be granted when all of the following applicable conditions are found or when, pursuant to the provisions of Section 24.08.810, an application for an accessory dwelling unit meets as many of the following conditions as possible:

1. Measures have been included within the design of the project to mitigate impacts on environmental constraint areas identified in the Natural Resources and Conservation Element and the Safety Element of the General Plan and the Local Coastal Program.

2. Landscaping of an appropriate type, size, and quality is proposed to mitigate any adverse environmental effect.

3. Usable open space is proposed in an amount equal to that normally required.

4. A registered civil engineer or other qualified professional will design streets, buildings, and other manmade structures to conform with existing landforms and topography.

5. Adequate fire safety measures as required by the city fire department have been incorporated into the design of the proposed development, when located in a designated fire hazard area.

6. The proposed project employs architectural and design elements which in total serve to reduce the mass and bulk of structures to protect public views. Such elements may include:
a. Multiple floor levels which follow natural slopes;
b. Multiple roof lines to provide visual interest and break up the visual impact of the building;
c. Decks and balconies to provide building articulation; d. Foundation types such as poles, piles, or stepped levels which minimize cut and fill and need for retaining walls;
e. Fence lines, walls, and other features which blend with the terrain rather than strike off at an angle against it.

7. If a project proposed for construction is in a landslide area identified in a site-specific geological report prepared pursuant to Section 24.14.030.d, findings must be made that mitigation measures necessary to fulfill the purpose of this part have been incorporated into project design, based on the project’s environmental review and geotechnical reports.

26.13 Section 4. Part 1: Conservation Regulations of Chapter 242.14 “Environmental Resource Management” of the City of Santa Cruz Municipal Code is hereby amended as follows:

Chapter 24.14 ENVIRONMENTAL RESOURCE MANAGEMENT
Part 1: CONSERVATION REGULATIONS

24.14.010 through 24.14.020 – no change.

24.14.030 SLOPE REGULATIONS.

1. Applicability and Purpose. The following regulations are enacted to minimize the risks associated with project development in areas characterized by combustible vegetation and steep and/or unstable slopes. Minor sculpted landforms, such as berms or swales, shall be exempt from the following regulations. A further purpose is to avoid excessive height, bulk, and mass normally associated with building on slopes.
a. Building permit applications for new structures on slopes of ten percent or greater shall include an accurate topographic map. The map shall contain contours of two-foot intervals for slopes of twenty percent grade.
b. Slopes thirty percent or greater shall not be considered in the density determination of a property.
c. Construction of buildings (as defined in Section 24.22.154) or structures (as defined in Section 24.22.822) on or within twenty feet of slopes of fifty percent or greater shall require approval of a slope development permit at a public hearing before the zoning administrator, unless they are exempted pursuant to subsection (g) below. Construction of buildings (as defined in Section 24.22.154) on or within twenty feet of slopes greater than or equal to thirty but less than fifty percent shall require administrative approval of a slope development permit with no public hearing required, unless they are exempted pursuant to subsection (g) below.
d. When a slope development permit is required pursuant to subsection (c) above, a sitespecific geological review consistent with the California Division of Mines and Geology guidelines shall be provided by a state-qualified professional. The review shall include consideration of material, height of slope, slope gradient, load intensity, and erosion characteristics of slope material. The recommendations contained in the review, including but not limited to California Building Code requirements, shall be incorporated into the design of the building project to prevent slope instability as a result of new development. e. All development on slopes shall be designed so that drainage water to and from the site complies with applicable local, Regional Water Quality Control Board, and State standards.

26.14 f. Proposed buildings on parcels within or adjacent to fire hazard areas as designated in the Safety Element of the General Plan shall maintain separation from combustible vegetation as required by the city fire department. Removal of combustible vegetation may also be required as part of project approval.
g. Minor development, not including buildings (as defined in Section 24.22.154) or grading over fifty cubic yards, may encroach on slopes greater than or equal to thirty percent. Minor development can include things such as walkways, fences, retaining walls less than three feet high above existing grade, planter boxes, stairways, decks extending not more than five feet into a slope greater than or equal to thirty percent, and similar features, or similar minor development as determined by the zoning administrator, may encroach on slopes greater than or equal to thirty percent without a slope development permit. h. No new lot shall be created that does not comply with the requirements of Section

23.04.050.3 “Subdivision Principles – Buildable Lots.”
i. For all development within one hundred feet of a coastal bluff, a site-specific geologic report consistent with the California Division of Mines and Geology guidelines shall be prepared by a state qualified professional.

24.14.030(i)(2) “Driveway Design Standards” - no change.

24.14.050 through 24.14.090 – no change.

Section 5. Chapter 24.22 “Definitions” of the City of Santa Cruz Municipal Code is hereby amended as follows:

Chapter 24.22 - Definitions

24.22.010 through 24.22.496 – no change.

24.22.498 LOT AREA, NET.

The contiguous area within the lot lines with less than thirty percent slope and not within a riparian corridor as defined in Section 24.08.2110(g) or a Floodplain (F-P) District.

24.22.502 through 24.22.936 – no change.

Section 6. This ordinance shall take effect and be in force thirty (30) days after final adoption except within the Coastal Zone, where it shall take effect upon certification by the California Coastal Commission.

26.15 PASSED FOR PUBLICATION this 26th day of April, 2022, by the following vote:

AYES:

NOES:

ABSENT:

DISQUALIFIED:

APPROVED: ______________________________
Sonja Brunner, Mayor
ATTEST: _________________________________
Bonnie Bush, City Clerk Administrator
PASSED FOR FINAL ADOPTION this 10th day of May, 2022 by the following vote:

AYES:

NOES:

ABSENT:

DISQUALIFIED:

APPROVED: ______________________________
Sonja Brunner, Mayor
ATTEST: _________________________________
Bonnie Bush, City Clerk Administrator
This is to certify that the above
and foregoing document is the
original of Ordinance No. 2022-xx
and that it has been published or
posted in accordance with the
Charter of the City of Santa Cruz.
________________________________
Bonnie Bush, City Clerk Administrator

26.16 Attachment 2
ORDINANCE NO. 2022-XX

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF SANTA CRUZ AMENDING CHAPTERS 18.45, 24.04, 24.08, 24.14, AND 24.22 OF THE CITY OF SANTA

CRUZ MUNICIPAL CODE TO REVISE THE REQUIREMENTS FOR DEVELOPMENT ON SLOPED PROPERTY TO BE BASED ON SITE-SPECIFIC GEOTECHNICAL REPORTS.

THIS ORDINANCE ALSO AMENDS THE LOCAL COASTAL PROGRAM TO INCLUDE THESE AMENDMENTS.

Strike-out indicates existing text that is proposed to be removed. Underline and red text indicates new text proposed to be included.

BE IT ORDAINED By the City of Santa Cruz as follows:

Section 1. Chapter 18.45 “Excavation and Grading” of the City of Santa Cruz Municipal Code is hereby amended as follows:

Chapter 18.45 EXCAVATION AND GRADING REGULATIONS

18.45.010 through 18.45.020 – no change.

18.45.030 GENERAL GRADING PERMIT REQUIREMENTS.
(3) Prohibited Grading Areas. No grading permit shall be issued for a project located in a protected natural resource area, including species-protected area, archaeologically sensitive area, riparian corridor, or on slopes of thirty percent or greater than thirty percent unless an appropriate zoning permit for the special area is first obtained. No grading permit shall be issued within ten twenty feet of any thirty percent or greater slope exceeding thirty percent, unless a variance granting such slope modificationslope development permit pursuant to Section 24.08 (Part 9) of the Zoning Ordinance is first obtained.

18.45.035 through 18.45.150 – no change.

Section 2. Chapter 24.04 “Administration” of the City of Santa Cruz Municipal Code is hereby amended as follows:

Chapter 24.04 – ADMINISTRATION

24.04.010 through 24.04.020 – no change.

24.04.030 TYPES OF PERMITS AND OTHER ACTIONS AUTHORIZED BY THIS TITLE.

The following permits and actions are established in order to carry out the purposes and requirements of this title:

26.17

1. Appeals;

2. Coastal permit;

3. Conditional driveway permit;

4. Conditional fence permit;

5. Conservation regulations modifications;

56. Design permit;

67. Demolition/conversion permit:
a. Demolition authorization permit for residential structures, b. Historic demolition permit;

78. Extension of permits;

89. Historic building survey: building designation and deletion; 910. Historic alteration permit;
10a. Administrative historic alteration permit;
10a11. Historic landmark designation;
1112. Mobile homes: certificate of compatibility;
1213. Mobile home park conversion;
1314. Planned development permit;
1415. Relocation permit;
1516. Revocation of permits;
1617. Signs:
a. Design permit (for signs),
b. Building permit (for signs),
c. Sign permit – public art exception;

17. Slope Development Permit (on or within 20 feet of slope greater than or equal to 30% and less than 50%)
18 through 23 – no change.

24.04.040-24.04.080 – no change.

24.04.090 PUBLIC HEARING REQUIREMENT.

A public hearing shall be required for the following:
1 through 10 – no change.

11. Slope Development Permit (on or within 20 feet of a 50% or greater slope) 1112. Relocation of structures;
1213. Revocation of permits;
1314. Use permits:
a. Administrative use permit, except when the proposed use is temporary, as defined in this title; for variations to parking design requirements and number of spaces; and half baths in accessory structures;
b. Special use permit (including historic district/historic landmark use permit);

26.18

1415. Variance;
1516. Watercourse variance;
1617. Project modifications, pursuant to Section 24.04.160(4)(c); 1718. Zoning Ordinance and General Plan text and map amendments.

24.04.100 through 24.04.120 – no change.

24.04.130 DECISION-MAKING BODY WITH FINAL AUTHORITY ON APPLICATION APPROVAL.

The following table indicates the decision-making body who can approve, deny or conditionally approve an application, whether or not a public hearing is required, and the bodies to which appeals can be made:

1. The planning commission and city council may refer certain aspects of any application to the zoning administrator for final action.

2. The zoning administrator may refer any of the matters on which he/she is authorized to act to the planning commission or historic preservation commission.

3. Recommendations for approval on General Plan matters and zoning ordinance text and map amendments shall require a majority vote of the planning commission; all other actions shall require a majority of the hearing body present at the meeting.

Public Hearing Requirement and
Decision-Making Body Which Can
Approve an Application
No
Public
Hearing
Public Hearing
Permits/Actions**** Action Recommendation Action
Appeal Bodies
(in order)
Coastal Permit ZA
(ADU)
ZA* CPC/CC/CCC*
Administrative Use Permit:

Large Family Daycare Homes
and Temporary Uses

ZA CPC/CC
Other uses as listed by individual
zoning districts as requiring an
Administrative Use Permit

ZA CPC/CC
Conditional Driveway Permit ZA CPC/CC
Conditional Fence Permit ZA ZA CPC/CC
Slope Regulations Modifications
(Variance)

ZACPC CPC/CC

26.19

Public Hearing Requirement and
Decision-Making Body Which Can
Approve an Application
No
Public
Hearing
Public Hearing
Permits/Actions**** Action Recommendation Action
Appeal Bodies
(in order)
Slope Development Permit (on
or within 20 feet of a 50% or
greater slope)
Slope Regulations Modifications
(Design Permit)
Slope Development Permit (on
or within 20 feet of a slope
greater than or equal to 30% and
less than 50%)

ZA CPC/CC
Design Permit – ZA CPC/CC
Substandard lots: new two-story
structures and second-story
additions, including ADUs

ZA CPC/CC
Substandard lots: single-story
ADUs

ZA CPC/CC
Large homes per Section

24.08.450

ZA CPC/CC
Wireless telecommunications
facilities

ZA ZA CPC/CC
New structures or improvements
to existing structures in the
WCD Overlay which are exempt
or excluded from coastal permit
requirements

ZA CPC/CC
New structures or improvements
to existing structures in the
WCD Overlay which require a
coastal permit

ZA CPC/CC
Demolition Permit

1. Single-family residential ZA CPC/CC

2. Multifamily residential CPC CC

3. Historic demolition permit HPC CC

4. Nonresidential ZA** ZA** CPC/CC

26.20

Public Hearing Requirement and
Decision-Making Body Which Can
Approve an Application
No
Public
Hearing
Public Hearing
Permits/Actions**** Action Recommendation Action
Appeal Bodies
(in order)
General Plan Text and Map
Amendments
CPC CC/CCC***
Historic Alteration Permit HPC CC
Administrative Historic
Alteration Permit

ZA HPC/CC
Historic Building Survey:

Building designation, deletion HPC CC
Historic District Designation HPC/CPC CC
Historic Landmark Designation HPC CC
Mobile Homes (Certificate of
Compatibility)

ZA CPC/CC
Mobile Home Park Conversion CPC CC
Outdoor Extension Areas per
Section 24.12.192

ZA CPC/CC
Planned Development Permit CPC CC
Project (Major) Modification Hearing by ZA or body
approving application
Appeal to next
highest body(ies)
Project (Minor) Modification ZA CPC/CC
Relocation of Structures Permit ZA CPC/CC
Revocation Permit Hearing by ZA or body
approving application
Appeal to next
highest body(ies)
Sign Permit ZA CPC/CC
Special Use Permit CPC CC
Variance ZA CPC/CC
Watercourse Variance CPC CC
Watercourse Development
Permit

ZA CPC/CC
Zoning Ordinance Text and Map
Amendments

26.21

Public Hearing Requirement and
Decision-Making Body Which Can
Approve an Application
No
Public
Hearing
Public Hearing
Permits/Actions**** Action Recommendation Action
Appeal Bodies
(in order)
Amendments recommended by
CPC
CPC CC/CCC***
Amendments not recommended
by CPC
CPC CC/CCC***
CCC = California Coastal Commission CC = City Council CPC = City Planning Commission
HPC = Historic Preservation Commission ZA = Zoning Administrator * For projects seaward of the mean high tide line, and in the case of appealable actions, the California Coastal Commission shall be the decision-making body which can finally approve an application.
** Such permits shall be issued administratively, without a public hearing, unless a cultural resources evaluation, prepared by a qualified consultant as determined by the zoning administrator, determines that the building or structure is eligible for listing on the city Historic Building Survey.
*** California Coastal Commission in case of CLUP policy, CLIP elements. **** At a regularly scheduled meeting, a majority of the council may take an action to direct any project or amendment to be called from a lower hearing body prior to a final action or during an appeal period in accordance with Section 24.04.175(2).

24.04.140 through 24.04.250 – no change.

Section 3. Part 8: Planned Development Permit and Part 9: Slope Regulations Modifications of Chapter 24.08 “Land Use Permits and Findings” of the City of Santa Cruz Municipal Code are hereby amended as follows:

Chapter 24.08 LAND USE PERMITS AND FINDINGS
Part 8: PLANNED DEVELOPMENT PERMIT

24.08.700 through 24.08.710 – no change.

24.08.720 GENERAL PROVISIONS.

A planned development permit provides variation on district regulation, where appropriate, in the following areas:

26.22

1. Building setbacks.

2. Street standards.

3. Lot coverage.

4. Parking and loading.

5. Landscaping.

6. Open space.

7. Lot area.

8. Uses.

9. Slope regulation modifications, pursuant to procedures set forth in Chapter 24.08, Part 9 (Slope Regulations Modifications).
109. Height, not to exceed one story or twenty percent of height (in feet) over and above regulations established in district regulations for the district in which the project is proposed.

All aspects of the proposed development which represent a departure from strict application of district regulations shall be explained in the application and reasons given why the proposed development plan affords greater public benefits than would be achieved through application of conventional zoning regulations.

24.08.730 through 24.08.790 – no change.

Part 9: SLOPE REGULATIONS MODIFICATIONSDEVELOPMENT PERMIT

24.08.800 PURPOSE.

Development on slopes presents opportunities and challenges. Construction on unstable slopes can lead to erosion, steep terrain can present wildfire and evacuation hazards, and buildings constructed on hilltops often have exceptional views while having the potential to adversely impact public views. Such development is therefore regulated by the Slope regulation modifications may be permitted to allow for development in unique situations where mitigation measures achieve the purpose of provisions of Section 24.14.030(1)(d) (slope regulations) to ensure that risks to public and private property and adverse impacts to public views are and where strict compliance with Section 24.14.030(1)(d) creates a particular physical hardship and where no reasonable alternative to the exception exists, and when the extent of the exception is minimized. “Public views” include scenic views of the ocean, beaches, and the Santa Cruz Mountains from public property, including from parks and public rights-of-way. This section is also part of the Local Coastal Implementation Plan.

24.08.810 PROCEDURE.

Projects on or within twenty feet of a slope of thirty percent or greater requiring an exception to slope standards established by Section 24.14.030 must apply for a slope modification development permit unless the project is exempted from the need for such a permit under Section

24.14.030(1)(g). This permit may be granted by the zoning administrator under Section

26.23

24.14.030(1)(c) without a hearing if the project is no closer than ten feet from the top edge on or within twenty feet of a slope greater than or equal to thirty-percent slope and less than fifty percent and is consistent with the findings in Section 24.08.820, unless the slope modificationdevelopment permit is accompanied by an application which that must be heard by a higher body. Should a pProjects on or within twenty feet of a slope of fifty percent or greater closer than ten feet to a thirty-percent slope, then it must be considered at a public hearing by the zoning board administrator as a variance which and must also be consistent with the findings in Section 24.08.820 unless the project is exempted from such a permit per Section 24.14.030(1)(g).

In the case of construction of an accessory dwelling unit pursuant to Section 24.16.100 et seq., this section shall apply only when alternative site configurations are available to an applicant that would permit the construction of a detached accessory dwelling conforming to the development standards in Section 24.16.140unit up to eight hundred square feet in size without the need for a slope modificationdevelopment permit; when no alternative site configuration will allow the construction of an eight-hundred-square-foot a detached accessory dwelling unit in conformance with Section 24.16.140, the applicant shall comply with the maximum possible number of findings in Section 24.08.820, but shall not be denied a building permit for the accessory dwelling unit based on this section.

24.08.820 FINDINGS REQUIRED.

A slope modification development permit may be granted when all of the following applicable conditions are found or when, pursuant to the provisions of Section 24.08.810, an application for an accessory dwelling unit meets as many of the following conditions as possible:

1. Measures have been included within the design of the project to mitigate impacts on environmental constraint areas identified in the Environmental Quality Natural Resources and Conservation Element and the Safety Element of the General Plan and the Local Coastal Program.

2. Landscaping of an appropriate type, size, and quality is proposed to mitigate any adverse environmental effect.

3. Usable open space is proposed in an amount equal to that normally required.

4. To conform with existing land forms and topography, A registered civil engineer or other qualified professional will design streets, buildings, and other manmade structures to conform with existing landforms and topography have been designed by a registered civil engineer or other qualified professional.

5. Adequate fire safety measures as required by the city fire department have been incorporated into the design of the proposed development, when located in a designated fire hazard area.

6. The proposed project employs architectural and design elements which in total serve to reduce the mass and bulk of structures to protect public views. Such elements may include:

26.24

a. Multiple floor levels which follow natural slopes;
b. Multiple roof lines to provide visual interest and break up the visual impact of the building;
c. Decks and balconies to provide building articulation; d. Foundation types such as poles, piles, or stepped levels which minimize cut and fill and need for retaining walls;
e. Fence lines, walls, and other features which blend with the terrain rather than strike off at an angle against it.

7. If a project proposed for construction is in a designated landslide area identified in a sitespecific geological report prepared pursuant to Section 24.14.030.d, before granting a modification to Section 24.14.030(1)(d), findings must be made that mitigation measures necessary to fulfill the purpose of this part have been incorporated into project design, based on the project’s environmental review and geotechnical reports.

Section 4. Part 1: Conservation Regulations of Chapter 242.14 “Environmental Resource Management” of the City of Santa Cruz Municipal Code is hereby amended as follows:

Chapter 24.14 ENVIRONMENTAL RESOURCE MANAGEMENT
Part 1: CONSERVATION REGULATIONS

24.14.010 through 24.14.020 – no change.

24.14.030 SLOPE REGULATIONS.

1. Applicability and Purpose. The following regulations are enacted to minimize the risks associated with project development in areas characterized by combustible vegetation and steep and/or unstable slopes. Such areas include canyons, arroyos, slopes over thirty percent (see Maps EQ-6 and EQ-7 in the General Plan). Minor sculpted landforms, such as berms or swales, shall be exempt from the following regulations. A further purpose is to avoid excessive height, bulk, and mass normally associated with building on slopes.
a. Building permit applications for new structures on slopes of ten percent or greater shall include an accurate topographic map. The map shall contain contours of two-foot intervals for slopes of twenty percent grade.
b. Slopes thirty percent or greater shall not be considered in the density determination of a property.

26.25

c. Parcels with a portion of the area in slopes of thirty percent or greater shall require the minimum lot area of the applicable zoning district in slopes of less than thirty percent. The area in slopes of less than thirty percent must be contiguous to the proposed building site.Construction of buildings (as defined in Section 24.22.154) or structures (as defined in Section 24.22.822) on or within twenty feet of slopes fifty percent or greater shall require approval of a slope development permit at a public hearing before the zoning administrator, unless they are exempted pursuant to subsection (g) below. Construction of buildings (as defined in Section 24.22.154) on or within twenty feet of slopes greater than or equal to thirty but less than fifty percent shall require administrative approval of a slope development permit with no public hearing required, unless they are exempted pursuant to subsection (g) below.
d. No building or structure shall be located on a slope of thirty to fifty percent, or within twenty feet of a thirty to fifty percent slope, unless an exception is granted pursuant to Section 24.14.040 or a variance is granted pursuant to Section 24.08.810 When a slope development permit is required pursuant to subsection (c) above, a site-specific geological review consistent with the California Division of Mines and Geology guidelines shall be provided by a state-qualified professional. The review shall include consideration of material, height of slope, slope gradient, load intensity, and erosion characteristics of slope material. The recommendations contained in the review, including but not limited to California Building Code requirements, shall be incorporated into the design of the building project to prevent slope instability as a result of new development. e. No structure shall be located on a slope greater than fifty percent.All development on slopes shall be designed so that drainage water to and from the site complies with applicable local, Regional Water Quality Control Board, and State standards. f. Proposed buildings on parcels within or adjacent to fire hazard areas as designated in the Safety Element of the General Plan (Map S-11) shall maintain separation from combustible vegetation as required by the city fire department. Removal of combustible vegetation may also be required as part of project approval. g. No development except mMinor development on parcels of one-half acre or less, not including buildings (as defined in Section 24.22.154) or grading over fifty cubic yards, may encroach on slopes greater than or equal to thirty percent. Minor development can include things such as walkways, fences, retaining walls less than three feet high above existing grade, planter boxes, stairways, decks extending not more than five feet into a slope greater than or equal to thirty percent, and similar features, or similar minor development as determined by the zoning administrator, will be allowed tomay encroach on slopes greater than or equal to thirty percent slopes without an exception listed in Section 24.14.040 a slope development permit.

26.26

h. No new lot shall be created that does not comply with the requirements of Section

23.04.050.3 “Subdivision Principles – Buildable Lots.”which will require the house to be sited within twenty feet of a thirty-percent slope.
i. For all development within one hundred feet of a coastal bluff, a site-specific geologic investigation report consistent with the California Division of Mines and Geology guidelines shall be prepared by a state qualified professional consistent with the California Division of Mines and Geology guidelines shall be prepared.

24.14.030(i)(2) “Driveway Design Standards” - no change.

24.14.040 EXCEPTION.

The zoning administrator may, through slope modification permit procedures, grant exception to Section 24.14.030, subsection (1)(d) when the exception is no less than 10 feet from the top edge of the slope and to Section 24.14.030 subsection (1)(g) when the exception is not a building, where strict compliance with that subsection creates a particular physical hardship and there are no reasonable alternatives to the exception, and when the applicable conditions in Section 24.08.820 are found.

24.14.050 through 24.14.090 – no change.

Section 5. Chapter 24.22 “Definitions” of the City of Santa Cruz Municipal Code is hereby amended as follows:

Chapter 24.22 - Definitions

24.22.010 through 24.22.496 – no change.

24.22.498 LOT AREA, NET.

The contiguous area within the lot lines with less than thirty percent slope and not within a riparian corridor as defined in Section 24.08.2110(g) or a Floodplain (F-P) District.

24.22.502 through 24.22.936 – no change.

Section 6. This ordinance shall take effect and be in force thirty (30) days after final adoption except within the Coastal Zone, where it shall take effect upon certification by the California Coastal Commission.

26.27 City of Santa Cruz
GENERAL PLAN 2030 EIR ADDENDUM
Proposed Revisions to Slope Regulations
JANUARY 2022
REVISED FEBRUARY 2022
I . B A C K G R O U N D
Project Title: City of Santa Cruz Revisions to Slope Regulations Lead Agency Name and Address:

City of Santa Cruz, Planning and Community Development Department 809 Center Street, Room 107
Santa Cruz, CA 95060
Contact Person and Phone Number: Katherine Donovan, (831) 420-5134 Project Applicant’s/Sponsor’s Name and Address: City of Santa Cruz Project Location: City of Santa Cruz (see Figure 1, Regional Location).

Project Overview: The proposed project consists of revisions to the City of Santa Cruz (“City”) Municipal Code. The revisions include changes to development restrictions and requirements on or adjacent to slopes of 30 percent or greater, including a new permit process for issuance of slope development permits for grading and construction on or within 20 feet of 30 percent or greater slopes.

City of Santa Cruz General Plan 2030 Background: In June 2012, the Santa Cruz City Council adopted the General Plan 2030 (after certification of the Environmental Impact Report (EIR) prepared for the General Plan). The General Plan is a comprehensive, long-range plan to guide development within the City that is required pursuant to state law. The adopted General Plan 2030 covers an approximate 20-year planning period and provides goals, policies and actions that address: land use; transportation; community design; historic preservation, arts and culture; community facilities; hazards, safety and noise; parks, recreation and open space; and natural resources and conservation. The plan also includes a land use map as required by state law with a range of land use designations.

C O N T E N T S :

I. Background
II. Project Description
III. Environmental Setting
IV. Use of An Addendum
V. Environmental Review
VI. References
VII. Figures

26.28 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 2 F e b r u a r y 2 0 2 2 F I G U R E 1 : R e g i o n a l L o c a t i o n

26.29 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 3 F e b r u a r y 2 0 2 2 The General Plan 2030 includes policies and actions related to development on or near steep slopes. In particular, revisions to the City’s Zoning Ordinance in the City Municipal Code regarding the City’s slope regulations are recommended in the General Plan (Policy-Action CD1.3.2 and 1.3.3) as set forth below. These revisions are also required in the General Plan 2030 Implementation chapter.

CD1.3 Ensure that development is designed to be in harmony with natural topography and vegetation.

CD1.3.2 Update the Zoning Ordinance to address new construction techniques and “best management practices” related to construction on slopes.

CD1.3.3 Review the slope development provisions of the Zoning Ordinance and update them as deemed necessary.

The City’s General Plan 2030 guides the location, density and intensity of future development and also recommends revisions to the City’s slope regulations. The General Plan 2030 EIR is a “program” EIR prepared pursuant to the State CEQA Guidelines Section 15168, which reviewed indirect impacts of implementation of the General Plan, as well as environmental impacts associated with future development and buildout within the City’s planning area that would be accommodated by the General Plan. As part of the overall estimated buildout, the EIR considered construction of new housing units and non-residential uses in the City with an estimated buildout of 3,350 new residential units throughout the City by the year 2030 (City of Santa Cruz 2012, DEIR volume, page 3-13).

The Slope Regulations in the City’s Zoning Ordinance regulate development on thirty percent or greater slopes. Currently, the Slope Regulations require either a Slope Modification Permit or a Slope Variance for development on slopes between thirty and fifty percent and prohibit development on slopes greater than fifty percent.

I I . P R O J E C T D E S C R I P T I O N
The proposed project consists of revisions to Chapter 24 (Zoning) of the City’s Municipal Code regarding development on or adjacent to slopes greater than 30 percent and establishes new requirements and permit procedures. The proposed revisions include changes to the following sections, which are further described below:
 24.04.030 (Types of Permits): Minor revisions to add slope development permit  24.04.090 (Public Hearing Requirements): Minor revisions to add slope development permit
 24.04.130 (Decision-Making Body with Final Authority on Applications Approval):

Minor revisions to reference slope development permits
 24.08.720 (General Provisions of Part 8 [Planned Development Permit]): Revisions to eliminate slope regulation modifications as part of a planned development permit

26.30 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 4 F e b r u a r y 2 0 2 2  24.08.800, 24.08.810, 24.08.820 (Slope Development Permit-Purpose, Procedure, and Findings required of Part 9: Slope Regulations Modifications): Revisions to set requirements and procedures for issuance of slope development permits  24.04.030 (Slope Regulations): Revisions to slope regulations, including requirements for studies and review
 24.14.040 (Exceptions): Delete the provision to consider exceptions to slope regulations, which are replaced by the previous noted provisions for slope development permits
 24.22.498 (Definitions - Lot Area, Net): Minor revision to clarify area is contiguous The project also includes a proposed revision to Chapter 18 (Building and Construction), under section 18.45.030 (General Grading Permit Requirements) to change the distance for requiring approval of a slope development permit prior to issuance of a grading permit for grading from within 10 feet to within 20 feet of any slope greater than 30 percent.

The proposed revisions to the City’s Municipal Code Section 24.14.030 would eliminate the existing regulation that prohibits structures on slopes greater than 50 percent. However, the proposed revisions retain the requirement that slopes 30 percent or greater shall not be considered in the density determination of a property.

The proposed revisions would allow construction of buildings or structures on or within 20 feet of slopes greater than 50 percent with approval of a slope development permit, subject to a public hearing before the City’s Zoning Administrator. Construction of buildings or structures on or within 20 feet of slopes between 30 and 50 percent would require administrative approval of a slope development permit with no public hearing. The existing regulation that indicates that no building shall be located on a slope of 30 to 50 percent or greater or within 20 feet of a 30-50 percent slope unless an exception is granted would be deleted and replaced with these slope development permit provisions that are further described below. The existing Section 24.14.040 that pertains to exceptions to slope modification permits also is proposed to be deleted as both slope modification permits and slope variances have been replaced by the slope development permit requirements and process.

For slope development permit approval, revisions to Section 24.14.030 would require that a site-specific geologic review be performed by a state-qualified professional that considers building material, height of slope, slope gradient, load intensity, and erosion characteristics of slope material. The proposed revisions require that recommendations contained in the site-specific geologic review be incorporated into building design, and that all development on slopes shall be designed so that water drainage to and from the site complies with local, Regional Water Quality Control Board (RWQCB), and state standards. Section 24.14.030 also would be modified to allow for the creation of new lots that are sited within 20 feet of 30 percent slopes if they comply with requirements of Section 23.04.050.3, Subdivision Principles – Buildable Lots. This existing regulation states that “All lots created by a subdivision shall be developable for the intended use. No subdivision shall include lots which are

26.31 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 5 F e b r u a r y 2 0 2 2 impractical to improve for the intended use because of slope of terrain, watercourse locations, sewerage problems, excessive driveway grades, easements, or other physical conditions.” Additionally as indicated above, the existing provision of Section 24.14.030.1b has been retained, in which slopes 30 percent or greater shall not be considered in the density determination of a property.

The project includes revisions to the City’s Municipal Code Sections 24.08.800 through 24.08.820 regarding the purpose, procedure, and findings required for a slope development permit, which currently are in place for consideration of a slope modification permit or exception to slope regulations. These revisions recognize that there are benefits and hazards of allowing development on and near steep slopes and that the regulations are intended to ensure that risks to public and private property and adverse impacts to public views are minimized. The proposed revisions define “public views” as including scenic views of the ocean, beaches, and the Santa Cruz Mountains from public property, including from parks and public rights-of-way. The proposed revisions also establish the application process and applicability of the slope development permit, and outline the findings required for slope development permit approval.

The proposed project also involves other minor revisions to the City’s Municipal Code. Section

24.22.498 would be revised to redefine net lot areas as contiguous areas within lot lines with less than 30 percent slope; currently the definition does not stipulate whether the areas should be contiguous, however, this limitation is currently contained in Section 24.12.100 “Minimum Building Site” of Part 2: General Site Design Standards in Chapter 24.12 – Community Design.

Additionally, Section 24.04.130, the decision-making body with final authority on application approval, would be revised to identify approval authority for slope development permits, pursuant to the revised requirements in Section 24.24.030. Section 24.08.720 also is proposed to be revised to eliminate slope regulations modifications as a variation to district regulations that is currently allowed for consideration under a planned development permit.

I I I . E N V R I O N M E N T A L S E T T I N G
The City of Santa Cruz is located along the northern shore of Monterey Bay, approximately 75 miles south of San Francisco, 25 miles south of San Jose and 40 miles north of Monterey. The City has a total land area of 12.7 square miles, and is bordered by parks, open space, and residential uses to the north, open space lands on the west, the Monterey Bay on the south, and a portion of the unincorporated urban community of Live Oak on the east. The City’s western and northern borders are mostly defined by publicly- and privately-owned open space, agricultural, and park lands. City-owned open space lands have helped establish a greenbelt around the City.

Areas of known steep slopes are located along the sea cliffs bounding the City to the south and along some of the banks of the San Lorenzo River valley. Other areas containing steep slopes are primarily within managed, public open space areas, such as Moore Creek Preserve, Pogonip and DeLaveaga Park. Areas of steep slopes also include portions of the westside of Santa Cruz, including the Western Drive area and in the northeastern portion of the City in the Prospect Heights, Branciforte Drive and Carbonera Drive areas. The City’s General Plan 2030 shows areas

26.32 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 6 F e b r u a r y 2 0 2 2 of the City with slopes 30 to 50 percent and over 50 percent; this map is shown on Figure 2 in this document.

I V . U S E O F A N A D D E N D U M
Pursuant to Section 15164 of the State CEQA Guidelines, an addendum to a certified EIR may be prepared if only minor technical changes or additions are necessary and none of the conditions described in State CEQA Guidelines Section 15162 that call for preparation of a subsequent EIR have occurred. Under State CEQA Guidelines Section 15162, no subsequent EIR would need to be prepared unless the lead agency determines, on the basis of substantial evidence, one or more of the following:
 Substantial changes are proposed in the project which will require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;  Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or
 New information of substantial importance, which was not known and could not have been known at the time the previous EIR was prepared, shows any of the following:
 The project will have one or more significant effects not discussed in the previous EIR;
 Significant effects previously discussed will be substantially more severe than shown in the previous EIR;
 Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measures or alternatives; or
 Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation or alternative.

Project Review
The proposed project consists of revisions to the City’s Municipal Code, Chapters 18 and 24. The revisions include changes to development standards and requirements for construction on or within 20 feet of 30 percent or greater slopes as explained Section II above. The revisions, in part, are proposed pursuant to directives in the General Plan 2030. The project is consistent with the General Plan policy recommendations in that the slope development provisions are updated and further direction is provided regarding construction requirements and permit approvals.

26.33 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 7 F e b r u a r y 2 0 2 2 F I G U R E 2 : A r e a s i n C i t y w i t h S t e e p S l o p e

26.34 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 8 F e b r u a r y 2 0 2 2 Furthermore, Government Code 65400 requires the City, after adopting a new general plan, to investigate and make recommendations to the City Council regarding reasonable and practical means for implementing the general plan, including subjects addressed in the plan. Updating the slope regulations is identified in the General Plan Implementation chapter, and thus, the proposed project is consistent with the General Plan’s implementation requirements.

Under the existing regulations slopes 30 percent or greater shall not be considered in the density determination of a property, and this provision would remain in effect with the proposed revisions.

However, the existing regulation to prohibit structures on slopes greater than 50 percent would be deleted with the proposed revisions. Therefore, the revisions could potentially result in structures, including dwelling units, being constructed on slopes greater than 50 percent that couldn’t have been sited on 50 percent or greater slopes under the existing regulations.

While the existing regulation to prohibit development on slopes greater than 50 percent would be eliminated, the General Plan 2030 sets density based on gross lot area. The General Plan indicates that: “A site’s density must be at or above the minimum unless constraints associated with the natural environment require a lower density.” Thus, the current regulation does not affect the number of units that could be developed on a particular property. This proposed revision would, however, change the potential location where a structure could be built (not the number of units).

Elimination of the existing regulation to prohibit structures on slopes greater than 50 percent could result in encroachment of a structure, which includes decks, retaining walls and similar improvements in addition to buildings, on slopes greater than 50%. According to City staff, there are currently approximately 30 vacant parcels and 65 developed parcels with areas of slopes greater than 50 percent large enough to develop that have a General Plan residential land use designation. City staff review of these parcels indicates that most of these properties also have other environmental constraints such as creek setbacks or sensitive habitat issues that would also restrict development. However, City staff estimates that of the parcels containing slopes greater than 50 percent found on developed residential lots, a total of 12 units could potentially be built on 50 percent or greater slopes. On vacant parcels, City staff estimates that a total of 15 units potentially could be developed on portions of existing lots with slopes greater than 50 percent with the proposed revisions. However, 9 of these potential units are on City-owned parcels with other constraints and are unlikely to be developed.

Therefore, for the purpose of this review, it is estimated that 18 to 27 residential units potentially could be constructed on slopes greater than 50 percent as a result of the proposed revisions. The lots are dispersed throughout the City, including westside neighborhoods that are currently developed, a parcel adjacent to Pogonip (City-owned lot) and in the Branciforte, Carbonera and Tanner Heights (off Graham Hill Road) neighborhoods.

As previously indicated, the General Plan EIR, as a “program” EIR, reviewed environmental impacts associated with future development and buildout within the City’s planning area that would be accommodated by the General Plan. As part of the overall estimated buildout, the EIR considered construction of new housing units and non-residential uses in the City with an estimated buildout of 3,350 new residential units throughout the City by the year 2030 (City of Santa Cruz 2012, DEIR volume). Since adoption of the General Plan, approximately 1,925 residential units have been

26.35 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 9 F e b r u a r y 2 0 2 2 constructed or approved throughout the City. The proposed revisions would not increase the number of units that could be constructed on sloped properties, but would expand the possible location, i.e., on slopes greater than 50 percent, of those units that would already be allowed under the General Plan density requirements. Any units constructed on 50 percent or greater slopes would be within the remaining residential buildout estimates considered in the citywide General Plan 2030 EIR impact analyses.

With the proposed revisions, existing requirements for setbacks from 30 percent or greater slopes would be replaced with a new requirement for a slope development permit for any development on or within 20 feet of a 30 percent or greater slope. While this revision could lead to development on or within 20 feet of 30 percent or greater slopes, the existing regulations also allow this for 30 to 50 percent slopes with approval of an exception or variance. Section 24.14.030, Slope Regulations, of Title 24 of the City’s Municipal Code states that no building shall be located on a slope of 30 to 50 percent, or within twenty feet of a 30 to 50 percent slope, unless an exception is granted pursuant to section 24.14.040 or a variance is granted pursuant to section 24.08.810.

The Planned Development Permit Chapter of the Municipal Code (Section 24.08.700) allows certain zoning regulations to be varied in an effort to foster development plans which serve public objectives more fully than development plans under conventional zoning regulations. Under the current ordinance, slope regulations are one of the zoning regulations that can be varied with a planned development permit.

Revisions to the City’s slope regulations involve changes to development restrictions on or adjacent to 30 percent or greater slopes and establish a new permit process for slope development permits that replaces existing exceptions to regulations through a slope modification permit or variance process, resulting in an unified permit process for any development on or within slopes greater than 30 percent. The proposed revisions also eliminate modifications to slope regulations as a potential variation with a planned development permit.

Additionally, the proposed revisions include new requirements for completion of geological review and drainage controls. The revisions could allow siting of structures on 50 percent or greater slopes, but this would require a geological report with incorporation of the report’s recommendations into the project design and approval of a slope development permit at a public hearing. Similarly, construction on or within 20 feet of slopes that are 30 to 50 percent or greater also would require a slope development permit with preparation of a geological report, but a public hearing would not be required. The proposed revisions provide additional criteria for review which are not included in the existing regulations, to prevent erosion, slope instability, and/or adverse impacts to public views.

The proposed revisions would not directly result in new development or impacts on the physical environment. However, the revisions could indirectly lead to construction of 18 to 27 residential units already allowed under the General Plan density on slopes greater than 50 percent, but only with preparation of geological reports that review whether or not development could cause slope instability or other drainage or erosion impacts. The number of units that could be constructed on sloped properties is within the amount evaluated in the General Plan EIR. As shown on Figure 2,

26.36 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 10 F e b r u a r y 2 0 2 2 areas of slopes greater than 30 percent generally include the upper westside and eastside neighborhoods, including near Western Drive, Pogonip, Branciforte Drive, Prospect Heights, and Carbonera Drive. Other areas of the City with steep slopes are generally undevelopable because they are managed as open space or located on riverbanks or sea cliffs.

The revisions require a new permit process and approval of the slope development permit with required findings. However, the proposed changes would not alter density allowed on a given parcel. Minor structures such as decks, walkways, fences, and other similar structures specified in the proposed revision would be allowed to encroach onto slopes greater than 30 percent without a slope development permit. These types of structures also are currently exempt from existing requirements to obtain an exception or variation to the slope regulations if there is encroachment onto slopes between 30 to 50 percent.

Future development would be constructed in accordance with existing General Plan and zoning designations; the project involves no proposed land use or zone designation changes. The proposed revisions to the City’s slope regulations would allow for development in parts of the City with steep slopes, including the upper westside and eastside neighborhoods near Western Drive, Prospect Heights, and Carbonera Drive. No specific development proposals are part of the project. Future development would be constructed by private and non-profit entities subject to City approvals, including project-specific environmental review.

Conclusion
The proposed revisions to the City’s slope regulations are within the scope of the program of the General Plan 2030, and potential development evaluated in the General Plan 2030 EIR.

Implementation of the proposed revisions would not directly result in new development or impacts on the physical environment. However, implementation of the revised regulations could indirectly lead to potential development of structures on or within 20 feet of slopes greater than 50 percent.

However, the proposed revisions include new specific requirements for technical reports and reviews, as well as issuance of a slope development permit, for any structures to be located on or within 20 feet of slopes greater than 30 percent.

The proposed revisions could indirectly lead to construction of 18 to 27 residential units on slopes greater than 50 percent. However, this number of units would be allowed under the current regulations, although the location of the units could change with the proposed revisions. As a result, adoption and implementation of the proposed revisions to the Municipal Code regarding slope regulations would not result in a net increase in new development not otherwise potentially allowed under existing regulations and any units built on sloped property would be within the remaining residential buildout estimates considered in the General Plan 2030 EIR impact analyses.

Furthermore, the proposed revisions specify new requirements for technical reports and design to prevent erosion, slope instability and visual impacts with provisions for a new required slope development permit process. Therefore, the proposed project would not result in new significant environmental impacts or a substantial increase in the severity of impacts previously identified and evaluated in the General Plan EIR. Similarly, there are no substantial changes with respect to the circumstances under which the project is undertaken or new information of substantial importance that would result in new significant impacts or a substantial increase in the significance of

26.37 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 11 F e b r u a r y 2 0 2 2 previously identified impacts as summarized below. Furthermore, future development projects also would be subject to City approvals, including project-specific environmental review.

Completion of the following checklist document has led to the conclusion that the adoption and implementation of the proposed revisions to Slope Regulations in the Santa Cruz Municipal Code would not result in new potentially significant impacts or substantially more severe significant impacts than those already identified in the 2012 certified EIR for the General Plan. Given this finding, an Addendum to the existing General Plan EIR has been prepared in accordance with the California Environmental Quality Act (CEQA) Section 15162 as described above. Based on the level of previous environmental review and the scope of the proposed revisions to existing regulations, the City has determined that the project changes are minor and no substantial changes in the project or environmental conditions have occurred since certification of the General Plan 2030 EIR on June 26, 2012. Thus, the City has determined that an Addendum to the General Plan 2030 EIR is the appropriate environmental review document for the proposed project modifications.

V . E N V I R O N M E N T A L R E V I E W
Organization of Section
The purpose of the checklist presented on the following pages is to evaluate the impact categories in terms of any “changed condition” (i.e., changed circumstances, project changes, or new information of substantial importance) that may result in a changed environmental result. A “no” answer does not necessarily mean that there are no potential impacts relative to the environmental category, but that there is no change in the condition or status of the impact since it was analyzed and addressed with mitigations in prior environmental documents.  Where Impact Was Analyzed. This column provides a cross-reference to the pages of the prior environmental documents where information and analysis may be found relative to the environmental issue listed under each topic.
 Do Proposed Changes Involve New Significant Impacts? Pursuant to Section 15162(a)(1) of the State CEQA Guidelines, this column indicates whether the changes represented by the current project will result in new significant impacts that have not already been considered and mitigated by the prior environmental review or whether the new information or changes will substantially increase the severity of significant impacts that have not already been considered and mitigated by the prior environmental review.  Any New Circumstances Involving New Impacts? Pursuant to Section 15162(a)(2) of the CEQA Guidelines, this column indicates whether there have been changes in circumstances under which the project is undertaken, which have occurred subsequent to the prior environmental documents, which would result in the current project having new significant environmental impacts that were not considered in the prior environmental documents or that substantially increase the severity of a previously identified impact.  Any New Information Requiring New Analysis or Verification? Pursuant to Section 15162(a)(3)(A-D) of the CEQA Guidelines, this column indicates whether new information of substantial importance which was not known and could not have been known with the exercise of reasonable diligence at the time the previous environmental documents were certified as complete is available, requiring an update to the analysis of the previous

26.38 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 12 F e b r u a r y 2 0 2 2 environmental documents to verify that the environmental conclusions and mitigations remain valid. If the new information shows that: (A) the project will have one or more significant effects not discussed in the prior environmental documents; or (B) that significant effects previously examined will be substantially more severe than shown in the prior environmental documents; or (C) that mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or (D) that mitigation measures or alternatives which are considerably different from those analyzed in the prior environmental documents would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative, than the question would be answered ‘Yes,’ requiring the preparation of a subsequent or supplemental EIR.

However, if the additional analysis completed as part of this environmental review finds that the conclusions of the prior environmental documents remain the same and no new significant impacts are identified, or identified environmental impacts are not found to be more severe, or additional mitigation is not necessary, than the question would be answered ‘No’ and no additional environmental documentation (supplemental or subsequent EIR) is required.
 Mitigations Implemented or Address Impacts. Pursuant to Section 15162(a)(3) of the CEQA Guidelines, this column indicates whether the prior environmental documents provide mitigations to address effects in the related impact category. In some cases, the mitigations have already been implemented. A “yes” response will be provided in either instance. If “NA” is indicated, this Environmental Review concludes that the impact does not occur with this project and therefore no mitigations are needed.
 Discussion. A discussion of the elements of the checklist is provided under each environmental category in order to clarify the answers. The discussion provides information about the particular environmental issue, how the project relates to the issue and the status of any mitigation that may be required or that has already been implemented.  Mitigation Measures. Applicable mitigation measures from the prior environmental review that apply to the project are listed under each environmental category.  Conclusions. A discussion of the conclusion relating to the analysis contained in each section.

26.39 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 13 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?

1. Aesthetics. Would the project:
a) Have a substantial adverse effect on a scenic
vista?
DEIR, pg 4.3-2 to 4.3-7; 4.3-13 to

4.3-14; 4.3-15
FEIR, pg 3-2
No No No No
b) Substantially damage scenic resources, including,
but not limited to, trees, rock outcroppings, and
historic buildings within a state scenic highway?
DEIR, pg 4.3-14 to 4.3-17
No No No No
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 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?
DEIR, pg 4.3-7 to 4.3-8; 4.3-15 to

4.3-19
FEIR pg 3-2
No No No
Design Permit
May Be
Required
d) Create a new source of substantial light or glare
which would adversely affect day or nighttime
views in the area?
DEIR, pg 4.3-19 to 4.3-20
No No No Design Permit
May Be required
Discussion: (a-b) The General Plan 2030 EIR identified less-than-significant impacts related to scenic views and resources. The General Plan EIR concluded that most of the anticipated new development under the General Plan buildout would be infill development that would not be located within panoramic scenic public viewsheds. The existing and proposed Municipal Code revisions could allow for future development on steep slopes, primarily in the upper westside and eastside neighborhoods. According to maps developed for the City’s General Plan 2030 and included in the General Plan EIR, there are three panoramic views within these neighborhoods, two in the Prospect Heights area toward the Monterey Bay, and one along Western Drive.

The proposed revisions could result in construction of a structure that could potentially be sited on or within slopes of 30 percent or greater. However, the proposed revisions to the slope regulations indicate that one of the purposes of the revisions is to protect against impacts to public views that can occur with development on sloping terrain. The revisions define public views as “scenic views of the ocean, beaches, and the Santa Cruz Mountains from public property, including from parks and public rights-of-way.” Given the areas where private development could occur, future development would not adversely affect public views. Furthermore, findings for issuance of a slope development permit are similar to existing regulations, which require mitigation of any adverse impacts. Based on City staff review of parcels on which a new residential unit could be constructed, none of the parcels are within the panoramic viewpoints identified in the General Plan.

26.40 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 14 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
In addition, there are no designated state scenic highways or roads within the City. Therefore, the proposed revisions would not directly or indirectly lead to development located near a state scenic highway. For these reasons, the proposed project would not affect scenic views or resources. (c) The General Plan 2030 EIR identified less-than-significant impacts regarding potential degradation of the visual character of an area. Future new residential units could be constructed on developed and vacant parcels within the City, although the proposed project does not change requirements related to density and retains provisions of the existing ordinance that require density to be based on the area of a parcel that is less than 30 percent slope. The majority of the parcels on steeper slopes are already developed; new construction would be consistent with the City’s General Plan and Zoning designations and development standards and therefore would not be expected to substantially degrade the visual character of the surrounding areas. Revisions to the City’s slope regulations could indirectly lead to construction of approximately 18 to 27 residential units on slopes greater than 50 percent. The General Plan EIR states that new buildings may result in substantial degradation of the visual character of the surrounding area if new buildings are overly massive, substantially taller or out of scale with adjacent areas, especially residential areas next to mixed-use areas. However, the proposed Municipal Code revisions retain and expand findings required with approval of a slope modification permit, including design of structures to conform with existing landforms and topography and use of architectural and design elements to reduce the mass and bulk of structures to protect public views, such as multiple floors that follow natural slopes and multiple roof lines to break up building mass. Thus, the potential new residential units would be designed to avoid/minimize impacts to the visual character of surrounding areas and would be located throughout the City in primarily existing residential neighborhoods. Furthermore, future site-specific development would be subject to site-specific environmental review, as well as permit and design review, including building design, massing and exterior lighting.

Changes to the CEQA Guidelines in late 2018 now require consideration of substantial degradation of visual character based on conflicts with applicable zoning and other regulations governing scenic quality. The City of Santa Cruz is an “urbanized area” under the definition of the term in CEQA Guidelines section 15387. Therefore, per the amended Environmental Checklist question, the City need not specifically consider existing visual character or the quality of the existing views and the project’s potential effect on them. Scenic views require consideration as part of approval of a coastal development permit as set forth in Municipal Code section 24.08.250. Protection of the ocean or of scenic coastal areas is a required finding for a Design Permit pursuant to Municipal Code section 24.08.430. As indicated in subsection (a), while the project would affect properties that are within public views, the proposed revisions specifically seek to prevent adverse effects to public views, which include views of the ocean, beaches and mountains. Therefore, the project does not conflict with applicable zoning and other regulations governing scenic quality. (d) The General Plan EIR concluded that residential development likely would include exterior lighting that is typical of a residential neighborhood in an urbanized setting, but with implementation of General Plan and zoning requirements, the EIR concluded that the impact would be less than significant.

The proposed project could indirectly lead to new structural development on or within 20 feet of 50 percent slopes as discussed above, which would consist of residential or accessory structures that would not contain any design elements or features that would result in the introduction of a substantial new source of light or glare not otherwise considered in the General Plan EIR.

26.41 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 15 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
Mitigation Measures: None were identified in the EIR. None are required with the proposed project as a significant impact has not been identified.

Conclusion: Revisions to the Municipal Code slope regulations, as well as potential future development allowed under those revisions, would not result in new significant impacts or substantially more severe impacts than the less-than-significant impacts identified and analyzed in the certified General Plan EIR related to scenic views/features, potential degradation of the visual character of surrounding areas and/or creation of a source of substantial light or glare.

2. Agriculture. Would the project:
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of
the California Resources Agency, to nonagricultural use? DEIR, pg 4.15-3, 4.15-6 to 4.15-8
No No No NA
b) Conflict with existing zoning for agricultural use,
or a Williamson Act contract?
DEIR, pg 4.15-3; 4.15-6 to 4.15-8
No No No NA
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))?
DEIR, pg 4.15-3; 4.15-5 to 4.15-6
No No No NA
d) Result in the loss of forest land or conversion of
forest land to non-forest use?
DEIR, pg 4.15-3; 4.15-5
No No No NA
e) Involve other changes in the existing environment
which, due to their location or nature, could
result in conversion of Farmland, to nonagricultural use or conversion of forest land to non-forest use?
DEIR, pg 4.15-3; 4.15-5 to 4.15-8
No No No NA
Discussion: The General Plan 2030 EIR concluded that impacts to agricultural and forest resources would not occur or would be less-than-significant as a result of future development accommodated by the General Plan as these resources are not present within City limits. There are no designated

26.42 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 16 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
agricultural lands or timberland preserve lands within the City, and areas of mixed evergreen, redwood forest and oak woodlands within the City are located primarily within the City-owned open space greenbelt lands. The proposed revisions to the City’s slope regulations are recommended in the General Plan, Policy-Actions CD1.3.2 and 1.3.3, and would not directly or indirectly lead to development on agricultural or forest lands, and therefore, would have effect on agricultural or forest resources.

Mitigation Measures: None were identified in the EIR and none are required with the proposed project.

Conclusion: Revisions to the Municipal Code slope regulations, as well as potential future development allowed under those revisions, would not result in new significant impacts or substantially more severe impacts than the less-than-significant impacts identified and analyzed in the certified General Plan EIR related to agricultural or forest resources.

3. Air Quality. Would the project:
a) Conflict with or obstruct implementation of the
applicable air quality plan?
DEIR pg 4.11-11 to 4.11-12; 4.11-
15 to 4.11-18; FEIR pg 3-24 No No No
General Plan EIR
Mitigation
Measure 4.11-1
b) 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?
DEIR pg 4.11-6 to 4.11-10; 4.11-18
to 4.11-24
FEIR pg 3-24 to 3-26
No No No No
c) Expose sensitive receptors to substantial
pollutant concentrations?
DEIR pg 4.11-7 to 4.11-8; 4.11-10
to 4.11-11; 4.11-18; 4.11-24 to

4.11-26
No No No No
d) Result in other emissions (such as those leading
to odors) adversely affecting a substantial
number of people?
DEIR pg 4.11-26 to 4.11-27
No No No No
Discussion: (a) The General Plan 2030 EIR concluded that future development accommodated by the General Plan could result in population increases that exceed Air Quality Management Plan (AQMP) projections for which one mitigation measure was included that calls for the City to work with AMBAG to ensure that population projections reflect City growth. Subsequent to the City’s certification of the General Plan EIR and adoption of the General Plan 2030, AMBAG updated its population and housing projections twice, which now go to the year 2040. The current AMBAG-adopted regional growth projections forecast a slightly higher population for the year 2030 than identified in the General Plan EIR. The proposed revisions to the City’s slope regulations are recommended in the General Plan, Policy-Actions CD1.3.2 and 1.3.3. These Policy-Actions call for review and revisions of the Zoning Ordinance to address new construction techniques, best management practices, and slope development provisions related to construction on

26.43 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 17 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
slopes within the City. The proposed revisions would not change allowed density on parcels with 30 percent or greater slopes, but could indirectly lead to construction of 18 to 27 residential units on slopes greater than 50 percent, which could indirectly result in air emissions. However, this level of potential development does not represent a net increase in units that could otherwise have been constructed under existing General Plan density and regulations. This development potential also is within the range and remaining development potential that was evaluated in the General Plan EIR and within regional population forecasts. Thus, the proposed project would be consistent with the AQMP, and would not conflict with or obstruct implementation of the AQMP. Therefore, the project is consistent with the AQMP, would not conflict with or obstruct implementation of the AQMP, and would not result in a substantially more severe significant impact than evaluated in the General Plan EIR. (b-d) The General Plan EIR concluded that future development could result in air emissions, but overall future emissions of ozone precursor pollutants were projected to decrease or remain nearly unchanged over the next 20 years after its certification. General Plan Actions LU21.2.1 and HZ2.2.1 (as modified by the General Plan EIR), require future project-level review and implementation of mitigation measures if warranted, consistent with the adopted standards in the Monterey Bay Air Resources District’s (formerly Monterey Bay Unified Air Pollution Control District) CEQA Guidelines. The General Plan EIR concluded that contributions to air emissions as a result of development accommodated by the General Plan would be less than significant. The proposed revisions to the City’s slope regulations could indirectly lead to construction of approximately 18 to 27 residential units on slopes greater than 50 percent, which could result in air pollutant emissions. However, these units would be developed on individual lots throughout the City and would be within development estimates analyzed in the General Plan EIR. Given the type of land uses envisioned in the General Plan, the General Plan EIR concluded that implementation of the General Plan and future development would not result in introduction of new sources of substantial odors. No significant impacts were identified regarding exposure of sensitive receptors to substantial pollutant concentrations. According to the Air District’s CEQA Guidelines, land uses associated with odor complaints typically include landfills, agricultural uses, wastewater treatment plants, food processing plants, chemical plants, and refineries.

Mitigation Measures: Mitigation Measure 4.11-1 is not applicable to the proposed project because the project would not result in conflicts with the AQMP and would not result in a new significant impact. No new mitigation measures are required as no significant impacts have been identified.

Conclusion: Revisions to the City’s slope regulations, as well as future development allowed under those revisions, would not result in new significant impacts or substantially more severe impacts than the impacts identified and analyzed in the certified General Plan EIR related to air quality.

4. Biological Resources. 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
DEIR pg 4.8-13 to 14; 4.8-16 to 4.8-
21; 4.8-41; 4.8-43 to 4.8-44; 4.8-
48 to 4.8-51
FEIR pg 3-23, 3-25 to 3-40
No No No No

26.44 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 18 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
Fish and Game 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,
regulations, or by the California Department of
Fish and Game or U.S. Fish and Wildlife Service?
DEIR pg 4.8-9 to 4.8-10;4.8-12; 4.8-
14 to 4.8-15; 4.8-22; 4.8-24; 4.8-26
to 4.8-30; 4.8-22; pg 4.8-38 to 4.8-
41; 4.8-48 to 4.8-51
FEIR pg 3-23
No No No No
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?
DEIR pg 4.8-7 to 4.8-9; 4.8-15; 4.8-
41; 4.8-38 to 4.8-39; 4.8-41; 4.8-48
to 4.8-51 No No No No
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?
DEIR pg 4.8-22 to 4.8-25; 4.8-41;
pg 4.8-44 to 4.8.45
No No No No
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
DEIR pg 4.8-41; pg 4.8-45 to 4.8.47
No No No No
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?
DEIR pg 4.5-11 to 4.5-12; 4.8-25 to

4.8-26; 4.8-37
FEIR pg 3-23
No No No No
Discussion: (a-f) The City of Santa Cruz is primarily developed, but supports special status species and sensitive habitat areas, mostly within the Cityowned and managed greenbelt and open space areas and along creeks and watercourses. A number of special status plant and wildlife species are found within the City, typically in managed greenbelt and open space areas. Sensitive habitat areas include riparian areas, wetlands and native grassland areas. The City adopted a Creeks and Wetlands Management Plan that identifies major resources and provides required development setbacks, standards and guidelines. There are no Habitat Conservation Plans (HCPs) or Natural Community Conservation Plans that are applicable to the proposed project. The HCP for City activities or projects that may affect a federally-listed species was described in the General Plan EIR, and the HCP for operation and maintenance of City facilities was issued in 2021. However, this does not pertain to the proposed project as the project does not involve maintenance and operation of specified City facilities and operational and maintenance activities.

26.45 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 19 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
The proposed revisions to the City’s slope regulations are recommended in the General Plan, Policy-Actions CD1.3.2 and 1.3.3. These Policy-Actions call for review and revisions of the Zoning Ordinance to address new construction techniques, best management practices, and slope development provisions related to construction on slopes within the City. The General Plan 2030 EIR identified less-than-significant impacts related to biological resources. Revisions to the City’s slope regulations could indirectly lead to construction of approximately 18 to 27 residential units on slopes greater than 50 percent. However, this level of potential development does not represent a net increase in units that could otherwise have been constructed under existing General Plan density and regulations and also is within the amount of potential development considered in the General Plan 2030 EIR with regards to impacts to biological resources. The proposed revisions do not involve changes to land use designations, land use intensity or zoning designations. The propose project does not change density determinations for development on slopes over 30 percent.

The EIR concludes that with implementation of General Plan policies and actions related to new development, future development accommodated by the General Plan would not result in significant impacts to biological resources as most development areas are infill areas that are not located within or adjacent to sensitive habitats or areas with biological resources. The General Plan EIR provides protocols for project-level biological assessments to protect sensitive resources as set forth in General Plan policies and actions. Furthermore, future site-specific development would be subject to sitespecific environmental review, including review for consistency with City resource management plans, which include the City-wide Creeks and Wetlands Management Plan and San Lorenzo Urban River Plan, as well as compliance with Zoning Ordinance environmental regulations contained in Chapter

24.14 of the Santa Cruz Municipal Code and heritage tree requirements.

Mitigation Measures: None were identified in the EIR, and none are required with the proposed project as a significant impact has not been identified.

The General Plan and EIR provide project-level assessment protocols to protect biological resources.

Conclusion: Revisions to the City’s slope regulations, as well as future development allowed under those revisions, would not result in new significant impacts or substantially more severe impacts than the less-than-significant impacts identified and analyzed in the certified General Plan EIR regarding biological resources.

5. Cultural Resources. Would the project:
a) Cause a substantial adverse change in the
significance of a historical resource as defined in
§15064.5?
DEIR pg 4.9-12 to 4.9-1; 4.9-15;

4.9-21; 4.9-23 to 4.9-24
FEIR pg 3-24
No No No None
b) Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to §15064.5?
DEIR pg 4.9-10 to 4.9-12; 4.9-19 to

4.9-23 No No No
General Plan EIR
Mitigation
Measure 4.9-1
and Municipal

26.46 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 20 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
Code section

24.12.430
c) Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
DEIR pg 4.9-14 to 4.9-16; 4.9-21;

4.9-24 to 4.9-25 No No No
General Plan EIR
Mitigation
Measure 4.9-2
d) Disturb any human remains, including those
interred outside of formal cemeteries?
DEIR pg 4.9-10 to 4.9-12; 4.9-19 to

4.9-23
No No No
General Plan EIR
Mitigation
Measure 4.9-1
and Municipal
Code section

24.12.430
Discussion: (a-d) The General Plan 2030 EIR identified less-than-significant impacts related to historical resources. The EIR concluded that future development accommodated by the General Plan would not result in potential impacts to archaeological resources with implementation of EIR Mitigation Measures 4.9-1 and 4.9-2, which includes General Plan Actions (HA1.2.2 and HA1.2.3) that were subsequently added to the General Plan. The action sets forth the process for preparation of archaeological investigations and project-level significance determinations and mitigations for development projects located within sensitive archaeological areas. Furthermore, Section 24.12.430 of the City’s Municipal Code sets forth the procedure to follow in the event that prehistoric or cultural features are discovered during the monitoring or accidentally discovered during construction. Under provisions of this Code section, work shall be halted within 100 feet of the find and the Planning Director shall be immediately notified to determine the appropriate course of action, including implementation of potential mitigation measures. Additionally, the County Coroner shall be notified in accordance with provisions of Public Resources Code 5097.98-99 in the event human remains are found and the Native American Heritage Commission shall be notified in accordance with the provisions of Public Resources Code section 5097 if the remains are determined to be Native American.

Revisions to the City’s slope regulations could indirectly lead to construction of approximately 18 to 27 residential units on slopes greater than 50 percent. However, this level of potential development does not represent a net increase in units that could otherwise have been constructed under existing General Plan density regulations and also is within the amount of potential development considered in the General Plan 2030 EIR with regards to impacts to cultural resources. Future site-specific development would be subject to site-specific environmental review, which would include the appropriate level of review of cultural resources as required by the General Plan. Future individual residential construction enabled by the slope regulation revisions would also be required to comply with Zoning Ordinance environmental regulations regarding discovery of unknown archaeological resources during construction.

26.47 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 21 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
Mitigation Measures: Mitigation Measures 4.9-1 and 4.9-2 of the General Plan EIR are intended to establish procedures for archaeological investigations. Adherence to these procedures would be required during construction of new residential units allowed under the proposed revisions to the City’s slope regulations. No new mitigation measures are required as no significant impacts have been identified.

Conclusion: Revisions to the City’s slope regulations, as well as future development allowed under those revisions, would not result in new significant impacts or substantially more severe impacts than the less-than-significant impacts identified and analyzed in the certified General Plan EIR regarding cultural resources.

6. Energy. 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?
DEIR pp. 4.6-27 to 4.6-29, 4.6-45 to

4.6-46, 5-4 to 5-6 No No No NA
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency? No No No NA
Discussion: (a-b) Subsequent to certification of the General Plan EIR, the CEQA Guidelines were updated in December 2018 to include a separate section related to wasteful or inefficient energy use in Appendix G. The General Plan EIR reviewed energy use associated with development accommodated by the General Plan. The estimated energy demand was found to be within state per capita projections for the planning area, and the EIR concluded that overall, the future consumption of electrical and natural gas resources would not represent unnecessary, inefficient, or wasteful use of resources given the implementation of policies that address lighting and energy conservation measures.

The proposed revisions would not change allowed density on parcels with 30 percent or greater slopes, although 18 to 27 residential units could potentially be constructed on slopes greater than 50 percent in locations throughout the City with the proposed revisions to the City’s existing slope regulations. The proposed revisions could indirectly involve the consumption of energy resources as a result of new development. Future development projects, including potential new structures allowed under the revisions to slope regulations, are subject to approval of building permits that meet the California Building Code and City Green Building Code requirements, as well as compliance with City requirements for water conservation fixtures and features, including drought-resistant landscaping. These measures are consistent with those recommended for residential uses in the City’s adopted Climate Action Plan related to building and energy efficiency and water conservation. Additionally, future residential development would be enrolled in Central Coast Community Energy (formerly Monterey Bay Community Power) electricity service, which supplies electricity generated from hydropower, solar and wind, which are renewable resources.

26.48 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 22 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
The proposed revisions to the City slope regulations as well as future residential development allowed under the revisions would not result in wasteful or inefficient energy consumption or conflicts with plans for renewable energy or energy efficiency. Therefore, the proposed project would not result in new significant impacts or substantially more severe impacts related to energy.

Mitigation Measures: None were identified in the EIR. No mitigation measures are required with the proposed project as no significant impacts have been identified.

Conclusion: Revisions to the City’s slope regulations, as well as future development allowed under those revisions, would not result in new significant impacts or substantially more severe impacts than the less-than-significant impacts identified and analyzed in the General Plan EIR regarding energy.

7. Geology and Soils. Would the project:
a) Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury,
or death involving::
i. Rupture of a known earthquake fault, as
delineated on the most recent AlquistPriolo Earthquake Fault Zoning Map issued by the State Geologist for the
area or based on other substantial
evidence of a known fault? Refer to
Division of Mines and Geology Special
Publication 42.
ii. Strong seismic ground shaking?
iii. Seismic-related ground failure, including
liquefaction?
iv. Landslides?
DEIR pg 4.10-6 to 4.10-14; 4.10-21
to 4.10-23
No No No
California
Building Code
Seismic Design
Criteria
b) Result in substantial soil erosion or the loss of
topsoil?
DEIR pg 4.10-16 to 4.10-19; 4.10-
25 to 4.10-26
No No No
City Municipal
Code section

24.16.060 and
Chapter 18.45
regarding
grading and

26.49 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 23 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
erosion control
plans
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 onor off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
DEIR pg 4.10-5 to 4.10-6; 4.10-15
to 4.10-16; 4.10-23 to 4.10-24
No No No
California
Building Code,
City Municipal
Code section

24.14.070 & GP
Actions HZ6.2.1
& HZ6.3.6
d) Be located on expansive soil, as defined in Table
18- 1-B of the Uniform Building Code (1994),
creating substantial risks to life or property?
DEIR pg 4.10-16 to 4.10-17; 4.10-
19; 4.10-24 to 4.10-25
No No No No
e) Have soils incapable of adequately supporting the
use of septic tanks or alternative waste water
disposal systems where sewers are not available
for the disposal of waste water?
DEIR pg 4.10-16 to 4.10-17; 4.10-
19; 4.10-24 to 4.10-25 No No No No
f) Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
DEIR pg 4.9-14 to 4.9-16; 4.9-21;

4.9-24 to 4.9-25 No No No GP EIR
Mitigation 4.9-2
Discussion: (a-e) The General Plan 2030 EIR identified less-than-significant impacts related to geology and soils. The EIR concluded that new development accommodated by the General Plan would be subjected to seismic and/or geologic hazards, including seismic shaking and liquefaction.

However, with implementation of the General Plan 2030 policies and actions (including requirements for preparation of geotechnical reports) and adherence to local regulations, the EIR concluded that future buildings would be designed to minimize damages and reduce exposure of people or structures to significant risks associated with seismic hazards, resulting in a less-than-significant impact. There are no active fault zones or risk of fault rupture within the City (City of Santa Cruz, 2012-DEIR volume). Properties within the City are served by municipal wastewater treatment and are not on septic systems.

The proposed revisions to the City’s Slope Regulations could indirectly lead to construction of approximately 18 to 27 residential units on slopes greater than 50 percent that could result in impacts related to geology and soils. However, this level of potential development does not represent a net increase in units that could otherwise have been constructed under existing General Plan density and regulations and also is within development estimates evaluated in the General Plan EIR. Furthermore, future development would be required to comply with building code requirements and would be subject to site-specific environmental review as well as permit and design review, including review for compliance with Zoning Ordinance

26.50 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 24 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
environmental regulations contained in Chapter 24.14 of the city of Santa Cruz Municipal Code that pertain to slope regulations (see discussion below).

Typically, buildings constructed in accordance with Building Code requirements and recommendations of geotechnical reports can withstand major damages resulting from seismic and other geologic hazards. Future residential structures would be required to be designed in accordance with recommendations of geotechnical reports. Erosion control plans are required for major grading activities. (c-Slope Instability) The General Plan 2030 EIR concluded that future development accommodated by the General Plan could result in exposure of people and property to potential hazards associated with landslides, slope stability, and/or coastal bluff retreat, which was identified as a less-thansignificant impact with adherence to City regulations and General Plan goals, policies and actions, which would prevent future development from being located on unstable areas related to slope instability, landslides or coastal bluff retreat. The EIR also noted that slope instability can sometimes occur on less than 50 percent slopes, but the risk is typically lower than on slopes steeper than 50 percent. The General Plan EIR indicated that development on steep slopes is regulated by the City’s Municipal Code’s slope regulations, which prohibit development on slopes over 50 percent and require setbacks from slopes steeper than 30 percent. While the proposed regulations would remove the prohibition of siting structures on 50 percent or greater slopes and remove a specific requirement for setbacks, the proposed revisions add new requirements that a site-specific geological report be prepared and that recommendations be incorporated into project designs with the express stated purpose of preventing slope instability issues. Specifically, as contained in the proposed revisions, the review shall include consideration of material, height of slope, slope gradient, land intensity, and erosion characteristics of slope material. The recommendations contained in the geotechnical review, including but not limited to California Building Code requirements, shall be incorporated into the design of the building to prevent slope instability as a result of new development. Therefore, the proposed revisions provide additional requirements for development on or adjacent to steep slopes that would avoid or minimize potential impacts. Therefore, the proposed project would not result in new significant impacts or more severe impacts than evaluated in the General Plan EIR. (f) The General Plan EIR identified potentially significant impacts to paleontological resources as a result of future development accommodated by the Plan. The General Plan EIR Mitigation 4.9-2 added General Plan Action HA1.2.3 which requires the City to notify applicants within paleontologically sensitive areas of the potential for encountering such resources during construction, and require the City to condition project approvals so that work will being halted and resources examined in the event of encountering paleontological resources during construction. If the find is significant, the City would require treatment in accordance with the recommendations of the evaluating paleontologist. Treatment may include, but is not limited to, specimen recovery and curation or thorough documentation. This provision was added to the City’s Municipal Code (section 24.12.431) and all projects are subject to this requirement, which is included as a project condition of approval. Such a measure would be included for any project subject to a slope development permit. Therefore, with implementation of the General Plan EIR mitigation measure, the proposed project would not result in significant paleontological resource impacts not otherwise addressed in the General Plan EIR.

Mitigation Measures: Mitigation 4.9-2 is not applicable to the proposed project because the measure has been incorporated into the City’s General Plan and Zoning Ordinance and would be included as a project condition of approval, where applicable. No mitigation measures are required with the proposed project as no significant impacts have been identified.

26.51 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 25 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
Conclusion: Revisions to the City’s slope regulations, as well as future development allowed under those revisions, would not result in new significant impacts or substantially more severe impacts than the less-than-significant impacts identified and analyzed in the certified General Plan EIR regarding geologic hazards and soils constraints.

8. Greenhouse Gas Emissions. Would the project:
a) Generate greenhouse gas emissions, either
directly or indirectly, that may have a
significant impact on the environment?
DEIR pg 4.12-13 to 4.12-17; 4.12-
21 to 4.12-28
FEIR pg 3-26 to 3-27
No No No No
b) Conflict with an applicable plan, policy or
regulation adopted for the purpose of reducing
the emissions of greenhouse gases?
DEIR pg 4.12-18 to 4.12-20; 4.12-
29 to 4.12-31 No No No NA
Discussion: (a) The General Plan 2030 includes goals, policies and actions on climate change, including reducing community-wide greenhouse gas emissions 30 percent by 2020 and by 80 percent by 2050 (compared to 1990 levels). The General Plan specifically calls for implementation of a Climate Action Plan that is also considered in the General Plan EIR analysis as part of General Plan measures to reduce greenhouse gas emissions. A Climate Action Plan was subsequently adopted by the City Council in October 2012. The General Plan EIR concludes that new development accommodated by the plan would result in greenhouse gas (GHG) emissions that contribute to global climate change impacts. However, the amount of estimated GHG emissions are generally within future forecasts, and the addition of emissions resulting from General Plan buildout would not substantially change per capita emission rates within the City, and would, in fact, slightly reduce them. Both the 2005 and 2030 City per capita GHG emission rates were found to be below the per capita rate that has been determined necessary to successfully implement the State’s AB 32 reduction goals statewide. Thus, the EIR concluded that the indirect GHG emissions resulting from the General Plan would not make a cumulatively considerable contribution to substantial adverse physical effects on the environment related to global climate change.

The proposed revisions would not change allowed density on parcels with 30 percent or greater slopes, although 18 to 27 residential units could potentially be constructed on slopes greater than 50 percent in locations throughout the City, which could indirectly result in development that would generate greenhouse gas emissions. However, this level of potential development does not represent a net increase in units that could otherwise have been constructed under existing General Plan density and regulations, and this amount of potential development is within the amount of remaining development analyzed in the General Plan EIR. Therefore, the proposed project would not result in new significant impacts or substantially more severe impacts related to GHG emissions.
(b) The General Plan EIR concluded that implementation of the General Plan and future buildout would not conflict with adopted plans related to GHG reduction. The City’s Climate Action Plan addresses citywide GHG emissions and reduction strategies. The CAP outlines the actions the City and its

26.52 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 26 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
partners may take pertaining to reduction of greenhouse gas emissions to meet the goals and implement the policies and actions identified in the General Plan 2030. The CAP provides City emissions inventories, identifies an emissions reduction target for the year 2020, and includes measures to reduce energy use, reduce vehicle trips, implement water conservation programs, reduce emissions from waste collection, increase solar systems, and develop public partnerships to aide sustainable practices. Measures are outlined for the following sectors: municipal, residential, commercial, and community programs. The CAP included 12 climate action milestones, addressing energy use, renewable energy, sustainable transportation, waste diversion and increasing tree canopy, and these milestones were tracked through 13 indicator metrics. Four of the 13 indicator targets were achieved by the sunset of the CAP 2020. The City is developing a Climate Action Plan 2030 that is anticipated to be adopted in August 2022 and will include updated climate goals and the strategies the City will implement to achieve them.

Future residential developed allowed under the proposed slope regulation revisions would be subject to approval of building permits that meet the California Building Code and City Green Building Code requirements, as well as compliance with City requirements for water conservation fixtures and features, including drought-resistant landscaping. These uniformly applicable standards are consistent with goals for residential uses in the CAP related to building and energy efficiency and water conservation. Therefore, the proposed revisions to City’s slope regulations, and future residential development allowed under those revisions, would not conflict with applicable plans or policies.

Mitigation Measures: None were identified in the EIR. None are required with the proposed project as a significant impact has not been identified.

Conclusion: Revisions to the City’s slope regulations, as well as future development allowed under those revisions, would not result in new significant impacts or substantially more severe impacts than the less-than-significant impacts identified and analyzed in the certified General Plan EIR regarding greenhouse gas emissions.

9. Hazards and Hazardous Materials. Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use,
or disposal of hazardous materials?
DEIR 4.14-9 to 4.14-10
No No No No
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?
DEIR pg 4.14-5 to 4.14-7; 4.14-9 to

4.14-11
No No No No
c) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or
waste within one-quarter mile of an existing or
DEIR pg 4.14-5 to 4.14-7; 4.14-12
No No No No

26.53 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 27 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
proposed school?
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a
result, would it create a significant hazard to the
public or the environment?
DEIR pg 4.14-5 to 4.14-7
No No No No
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?
Not Applicable
No No No NA
f) Impair implementation of or physically interfere
with an adopted emergency response plan or
emergency evacuation plan?
DEIR pg 4.6-2 to 4.6-5; 4.6-33 to

4.6-37 No No No No
g) Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or
death involving wildland fires?
DEIR pg 4.6-3 to 4.6-4; 4.6-34 to

4.6-35 No No No No
Discussion: (a-f) The General Plan 2030 EIR identified less-than-significant impacts related to transport, use and/or disposal of hazardous materials and/or exposure to contaminated sites or release of hazardous materials with compliance with and adherence to federal, state and local regulations related to hazardous materials. The City of Santa Cruz is not located near an airport or air strip. The proposed revisions would not change allowed density on parcels with 30 percent or greater slopes, although 18 to 27 residential units could potentially be constructed on slopes greater than 50 percent in locations throughout the City. Revisions to the City’s slope regulations that could indirectly result in development could result in impacts related to hazards and hazardous materials. Future residential development allowed under the proposed revisions typically would be residential development that would not involve the use, disposal or emission of hazardous materials that would constitute a threat of explosion or other significant release that would pose a threat to neighboring properties. Additionally, the amount of potential development that could occur as a result of the proposed project would not result in a net increase in units that could otherwise have been constructed under existing General Plan density and regulations and also is within development levels analyzed in the General Plan EIR. (g) The General Plan 2030 EIR found that none of the major vacant sites are within identified fire hazard zones. Areas targeted as “likely” to have a wildland fire include the Arroyo Seco/Meder Canyon, DeLaveaga, Pogonip, Moore Creek area and Arana Gulch. The proposed revisions would not change allowed density on parcels with 30 percent or greater slopes, although 18 to 27 residential units could potentially be constructed on slopes

26.54 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 28 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
greater than 50 percent, which could be within high or extreme fire hazard areas as mapped in the General Plan. The General Plan EIR concluded that regulation of development in and adjacent to fire hazard areas would require adequate siting, design, and emergency access to reduce potential hazards and facilitate emergency response in accordance with General Plan policies; these requirements would reduce hazards related to wildland fires, which would also be applicable to any development permitted in these areas as a result of the proposed project. See also subsection 20 below for further discussion of wildfire risks.

Mitigation Measures: None were identified in the EIR and none are required with the proposed project.

Conclusion: Revisions to the City’s slope regulations, as well as future development allowed under those revisions, would not result in new significant impacts or substantially more severe impacts than the less-than-significant impacts identified and analyzed in the certified General Plan EIR regarding hazards and hazardous materials.

10. Hydrology and Water Quality. Would the Project:
a) Violate any water quality standards or waste
discharge requirements or otherwise
substantially degrade surface or groundwater
quality?
DEIR pg 4.6-22; 4.7-8 to 4.7-12
No No No None
b) Substantially decrease groundwater supplies or
interfere substantially with groundwater
recharge such that the project may impede
sustainable groundwater management of the
basin?
DEIR pg 4.5-6 to 4.5-7; 4.5-39 to

4.5-42
o No No
General Plan
2030 Action
CC3.3.8
c) Substantially alter the existing drainage pattern
of the site or area, including through the
alteration of the course of a stream or river, in a
manner which would:
i) result in substantial erosion or siltation onor off-site; ii) substantially increase the rate or amount of
surface runoff in a manner which would
result in flooding on- or offsite;
iii) create or contribute runoff water which
would exceed the capacity of existing or
DEIR pg 4.7-5 to 4.7-8; 4.7-22 to

4.7-25
No No No
General Plan
2030 Action
CC5.1.8 and
Municipal Code
Chapters 16.19,

18.45, and 24.14
regarding
drainage, BMPs,
grading, and
erosion control

26.55 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 29 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
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?
DEIR pg 4.7-15; 4.7-25 to 4.7-26;

4.10-14 No No No None
e) Conflict with or obstruct implementation of a
water quality control plan or sustainable
groundwater management plan?
DEIR pg 4.5-6 to 4.5-7; 4.5-39 to

4.5-42 No No No None
Discussion: (a, c, d) The General Plan 2030 EIR identified less-than-significant impacts related to water quality degradation, stormwater runoff and exposure to flood hazards with implementation of General Plan policies applicable to site-specific developments and adherence to City regulations regarding project-level drainage control, drainage design, measures to protect water quality, and flood hazards, including General Plan actions that require new development to maintain pre-development runoff levels (CC5.1.8). Revisions to the City’s slope regulations could indirectly lead to construction of 18 to 27 residential units on slopes greater than 50 percent that could result in hydrologic or water quality impacts. However, this level of potential development does not represent a net increase in units that could otherwise have been constructed under existing General Plan density and regulations and also is within the level of development evaluated in the General Plan EIR. Future residential development would be in accordance with existing General Plan and Zoning designations, and the proposed revisions would not result in changes to permitted densities.

The General Plan EIR indicated that General Plan Policy 7.4 seeks to minimize impacts of future sea level rise, consistent with policies in the General Plan. Future site-specific development projects would be subject to site-specific environmental review as well as permit and design review, including review for compliance with City plans and regulations, which include the City’s Storm Water Management Plan. Future residential development allowed under the proposed revisions to the slope regulations would be required to design and construct drainage improvements in accordance with City standards and Public Works requirements. Drainage improvements would be required to meet water quality standards and maintain pre-project runoff levels.

It is also noted that subsequent to certification of the EIR, amendments to the State CEQA Guidelines were approved in December 2018 that changed some of the recommended questions on the Environmental Checklist (Appendix G) regarding flooding. The revised questions focus on whether a project would impede or redirect flood flows or release pollutants due to project inundation from a flood hazard, tsunami or seiche. The proposed revisions to the slope regulations would have no effect on flood flows and would not release pollutants as stormwater would be pre-treated on the project site prior to discharge into the City’s storm drain system. Therefore, the project would not result in a significant impact under the current questions in Appendix G of the State CEQA Guidelines.

26.56 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 30 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
(b) With regards to groundwater, the General Plan 2030 EIR concluded that potential future development would be connected to the City’s public water system and would not include the use of groundwater. The General Plan EIR includes Action CC3.3.8 that encourages the City to provide a reliable production of groundwater of million gallons per day (mgd). The proposed revisions, which could indirectly lead to development on slopes greater than 50 percent, would be located in areas of the City that are not served by water sources obtained from groundwater. (e) It is also noted that subsequent to certification of the EIR, amendments to the State CEQA Guidelines were approved in December 2018 that changed some of the recommended questions on the Environmental Checklist (Appendix G) regarding consistency with water quality and groundwater management plans. Water quality objectives are included in the Water Quality Control Plan for the Central Coastal Basin (Basin Plan) for protection of surface water and groundwater quality in the Central Coast Region. This Basin Plan lists beneficial uses for surface waters and describes the water quality objectives that must be maintained to allow those uses. The General Plan EIR concluded that the General Plan is consistent with provisions of the RWQCB Basin Plan with policies that protect water quality, and stormwater water and water quality control requirements would be required of new development in accordance with City stormwater plans and regulations. Although, the proposed revisions could indirectly lead to development not otherwise considered in the General Plan EIR, it would be within the level of growth analyzed in the General Plan EIR that did not identify water quality impacts or conflicts with the Basin Plan.

A sustainable groundwater management plan for the area in which the project is located has not yet been prepared. Therefore, the project would not conflict with adopted water quality or groundwater plans. Therefore, the project would not result in a significant impact under the current questions in Appendix G of the State CEQA Guidelines regarding conflicts with regional water quality and groundwater plans.

Mitigation Measures: None were identified in the EIR and none are required with the proposed project.

Conclusion: Revisions to the City’s slope regulations, as well as future residential development allowed under those revisions, would not result in new significant impacts or substantially more severe impacts than the less-than-significant impacts identified and analyzed in the certified General Plan EIR regarding hydrology and water quality.

11. Land Use and Planning. Would the project:
a) Physically divide an established community? DEIR pg 4.1-21 to 4.1-22 No No No No 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?
DEIR pg 4.1-9 to4.1-14; 4.1-25 to

4.1-27
No No No No

26.57 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 31 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
Discussion: (a-b) The General Plan EIR found no impacts related to the potential physical division of an established community or conflicts with adopted land use plans or policies. The EIR found that new mixed-use land use designations would not result in new land uses that would be considered incompatible with other adjacent or nearby land uses. The General Plan 2030 includes goals, policies and actions related to land use location, density/intensity, and areas of mixed land uses. The proposed project would result in revisions to the City’s slope regulations that would be consistent with General Plan policies directing updates to these regulations. The proposed revisions to the City’s slope regulations do not conflict with General Plan policies and actions, and in many cases support basic General Plan goals and policies.

Mitigation Measures: None were identified in the EIR and none are required with the proposed project.

Conclusion: Revisions to the City’s slope regulations, as well as future development allowed under those revisions, would not result in new significant impacts or substantially more severe impacts than the less-than-significant impacts identified and analyzed in the certified General Plan EIR regarding land use and planning.

12. Mineral Resources. 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?
DEIR pg 4.15-3 to 4.15-4; 4.15-6
No No No NA
b) Result in the loss of availability of a locallyimportant mineral resource recovery site delineated on a local general plan, specific plan or
other land use plan?
DEIR pg 4.15-3 to 4.15-4; 4.15-6
No No No NA
Discussion: (a-b) The General Plan 2030 EIR concluded that there would be no impacts to mineral resources as a result of future development accommodated by the General Plan as there are no designated mineral resources within the City, its existing Sphere of Influence, or the General Plan 2030 planning area. Therefore, development accommodated by the General Plan, and as an indirect result of the proposed project, would have no impact to mineral resources.

Mitigation Measures: None were identified in the EIR and none are required with the proposed project.

Conclusion: Revisions to the City’s slope regulations, as well as future residential development allowed under those revisions, would not result in new significant impacts or substantially more severe impacts than the less-than-significant impacts identified and analyzed in the certified General Plan EIR regarding mineral resources.

26.58 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 32 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?

13. Noise. 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?
DEIR pp. 4.13-4 to 4.13-8, 4.13-10
to 4.13-22
No No No
GP Actions
HZ3.1.1,
HZ3.1.2,
HZ3.1.3 &
HZ3.1.5
b) Generation of excessive groundborne vibration or
groundborne noise levels?
DEIR pp. 4.13-10
No No No None
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?
Not Applicable
No No No None
Discussion: (a-c) The General Plan 2030 EIR identified less-than-significant impacts related to noise exposure and ambient noise level increases. The EIR concluded that with implementation of General Plan policies and actions, future development accommodated by the General Plan would not result in significant impacts related to noise with implementation of General Plan policies and actions to require new development to be sited and designed to meet land-use noise compatibility standards set forth in the General Plan and EIR. At the end of 2018, amendments to the State CEQA Guidelines were adopted by the State of California that included changes to the Appendix G environmental checklist, including elimination of a question related to exposure to noise. The questions focus on the potential permanent and temporary noise generated by a project. The proposed revisions to the City’s slope regulations would not increase density, although 18 to 27 residential units could potentially be constructed on slopes greater than 50 percent; however, this level of potential development does not represent a net increase in units that could otherwise have been constructed under existing General Plan density and regulations. Residential land use typically is not associated with substantial permanent increases in ambient noise levels. The General Plan 2030 includes goals, policies and actions that set forth measures to avoid and minimize adverse impacts of increased noise resulting from construction or operation of development projects (HZ3.1.1, 3.1.2, 3.1.3, and 3.1.5). The General Plan EIR concluded that with implementation of General Plan policies and adherence to City regulations, noise impacts from future development would be less than significant.

Proposed revisions to the City’s slope regulations could indirectly lead to construction of 18 to 27 residential units on slopes greater than 50 precent, but the units would be located throughout the City, and would not result in activities that could result in significant noise impacts. Future residential development allowed under the slope regulation revisions would be consistent with the General Plan Land Use Element land use designations that were

26.59 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 33 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
evaluated in the General Plan EIR. The General Plan 2030 includes goals, policies and actions that set forth measures to avoid and minimize adverse impacts regarding exposure to noise. In particular, noise-land use compatibility standards would be applied to all new residential projects (HZ3.2.1), and the General Plan seeks to ensure that noise standards are met in the siting of noise-sensitive uses (HZ3.2). The policies also establish an interior noise level of 45 dBA for all residential uses, consistent with state law. The General Plan indicates that exterior noise levels to 65 dBA are normally acceptable for new multi-family development; noise levels to 70 dBA are considered conditionally acceptable and typically require an acoustical study to determine whether additional insulation or window treatments are required.

Areas adjacent to the major roadways are projected to be exposed to noise levels exceeding 65 decibels (dBA), the normally acceptable maximum level for residential uses, and in some cases would be exposed to 70 dBA. However, new development would be required to meet land-use noise compatibility standards set forth in the General Plan and interior sound levels established by state law, consistent with the conclusions of the General Plan EIR.

Mitigation Measures: None were identified in the EIR and none are required with the proposed project.

Conclusion: Revisions to the City’s slope regulations, as well as future residential development allowed under those revisions, would not result in new significant impacts or substantially more severe impacts than the less-than-significant impacts identified and analyzed in the certified General Plan EIR regarding noise.

14. Population and Housing. Would the Project:
a) 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)?
DEIR pg 4.2-2 to 4.2-6; 4.2-12 to

4.2-14
No No No NA
b) Displace substantial numbers of existing people
or housing, necessitating the construction of
replacement housing elsewhere?
DEIR pg 4.2-14 to 4.2-15
No No No NA
Discussion: (a-b) The General Plan EIR identified a less-than-significant impact related to population growth and displacement of housing or people. The EIR concludes that population resulting from development accommodated by the General Plan would be within historic growth levels and would not result in a significant impact. The proposed project would not increase density, although 18 to 27 residential units could potentially be constructed on slopes greater than 50 precent that would not otherwise occur in those locations under existing regulations. However, this level of potential development does not represent a net increase in units that could otherwise have been constructed under existing General Plan density and

26.60 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 34 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
regulations. Additionally, the resulting population would be within the level of development analyzed in the General Plan EIR and also within the current regional growth projections adopted by AMBAG. Therefore, the project would not induce substantial unplanned population growth in the City and any development occurring under the existing or revised slope regulations would be consistent with population growth projections developed for the City and the amount of development described in the General Plan EIR. Furthermore, residential development allowed under the proposed slope regulations would not lead to displacement of housing or residents because future construction would be on vacant parcels, accessory to primary dwelling units or be built to replace and upgrade existing housing units in-kind.

Mitigation Measures: None were identified in the EIR as no significant impacts were identified.

Conclusion: Revisions to the City’s slope regulations, as well as future development allowed under those revisions, would not result in new significant impacts or substantially more severe impacts than the less-than-significant impacts identified and analyzed in the certified General Plan EIR regarding population and housing.

15. Public Services.

Would the project result in substantial adverse
physical impacts associated with the provision of new
or physically altered governmental facilities, the
construction of which could cause significant
environmental impacts, in order to maintain
acceptable service ratios, response times or other
performance objectives for any of the public services:
a) Fire protection? DEIR pg 4.6-2 to 4.6-4; 4.6-33 to

4.6-36
FEIR pg 3-19 No No No No
b) Police protection? DEIR pg 4.6-4 to 4.6-5; 4.6-36 to

4.6-37
No No No No
c) Schools? DEIR pg 4.6-20 to 4.6-21; 4.6-40
to4.6-41
No No No No
d) Parks? DEIR pg 4.6-5to 4.6-20; 4.6-37 to

4.6-40
FEIR pg 3-20 to 3-22
No No No No

26.61 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 35 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
e) Other public facilities? Not Applicable No No No No
Discussion: (a-e) The General Plan 2030 EIR identified less-than-significant impacts related to fire and police protection services, schools, parks, and other public facilities. The EIR identified a potentially significant impact regarding elementary school capacity potentially being exceeded under the General Plan buildout; however, the EIR concluded that no mitigation measures were required beyond payment of school impact fees that would fund needed school facility expansion and additions in conjunction with potential reuse of the former Natural Bridges Elementary School. As previously indicated, the proposed project would not increase density, although 18 to 27 residential units could potentially be constructed on slopes greater than 50 percent. However, this level of potential development does not represent a net increase in units that could otherwise have been constructed under existing General Plan density and regulations. The project does not involve changes to current zoning or General Plan designations, and future residential development that could potentially occur as a result of the proposed project would be in accordance with existing General Plan and Zoning designations, and within the level of development and growth analyzed in the General Plan EIR. Proposed revisions to the City’s slope regulations would not result in new significant impacts or substantially more severe impacts related to public services.

Mitigation Measures: None were identified in the EIR and none are required for the currently proposed project.

Conclusion: Revisions to the City’s slope regulations, as well as future development allowed under those revisions, would not result in new significant impacts or substantially more severe impacts than the impacts identified and analyzed in the certified General Plan EIR related to public services.

16. Recreation. Would the Project:
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?
DEIR pg 4.6-5 to 4.6-20; 4.6-37 to

4.6-40
No No No No
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?
DEIR pg 4.6-10 to 4.6-11
No No No No
Discussion: (a-b) The EIR identified less-than-significant impacts related to recreation. The proposed project would not increase density, although 18 to 27 residential units could potentially be constructed on slopes greater than 50 percent, that could not otherwise have occurred in that location under existing regulations. Proposed revisions to the City’s slope regulations and potential future development that could potentially occur as a result of the proposed project would be within the level of development and growth analyzed in the General Plan EIR and would not result in new significant impacts

26.62 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 36 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
or substantially more severe impacts related to recreational facilities than considered in the General Plan EIR.

Mitigation Measures: None were identified in the EIR and none are required for the currently proposed project.

Conclusion: Revisions to the City’s slope regulations, as well as future residential development allowed under those revisions, would not result in new significant impacts or substantially more severe impacts than the impacts identified and analyzed in the certified General Plan EIR related to recreation.

17. Transportation. Would the project:
a) Conflict with a program, plan, ordinance or policy
addressing the circulation system, including
transit, roadway, bicycle and pedestrian facilities?
DEIR pg 4.4-2 to 4.4-27; 4.4-31 to

4.4-46
No No No
GP Actions
M3.1.3, M3.1.4,
M2.3.2
regarding traffic
improvements
and Traffic
Impact Fee
Program
b) Would the project conflict or be inconsistent with
CEQA Guidelines section 15064.3, subdivision (b)? NA
c) Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm
equipment)?
DEIR pg 4.4-45 to 4.46
No No No No
d) Result in inadequate emergency access? DEIR pg 4.6-33 to 4.6-37 No No No No Discussion: (a) The proposed revisions to the City’s slope regulations would not directly or indirectly result in new development that would create conflicts with policies, plans or programs regarding circulation system facilities. Therefore, the proposed project would result in no impact. (b) The EIR identified significant unavoidable impacts related to traffic as a result of development accommodated by the General Plan. As indicated above, the proposed project would not result in new development not already potentially allowed under existing regulations. In addition, subsequent to certification of the General Plan EIR, amendments to the State CEQA Guidelines were approved in December 2018 that changed required review of transportation impacts. CEQA Guidelines section 15064.3, subdivision (b) codifies the switch from level of service (LOS) to vehicle miles traveled (VMT) as the metric for transportation analysis pursuant to state legislation adopted in 2013. The State CEQA Guidelines amendments gave all agencies until July 2020 to adopt their own VMT standards, and the City of Santa Cruz adopted a VMT threshold prior to this deadline. The proposed project would not increase density, although 18 to 27 residential units could potentially be constructed on slopes greater than 50 percent that could not otherwise

26.63 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 37 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
occur in that location under existing regulations. This potential development would occur on existing vacant and developed single-family lots throughout the City and is within the development thresholds reviewed in the General Plan EIR. In adopting its threshold, the City developed VMT Guidelines to determine how to review projects for impacts and includes a screening process whereby certain types of projects have been determined to result in less-than-significant VMT impacts. This includes small projects that generate less than 110 trips per day. Since potential development resulting from the proposed revisions would consist of single-family homes on separate lots that would each generate approximately 10 trips per day based on Institute of Traffic Engineers trip generation rates, future development arising would be considered small projects, resulting in less-thansignificant impacts. Therefore, the proposed project would not conflict with provisions in the amended CEQA Guidelines regarding transportation impacts related to VMT.
(c-d) The proposed revisions to the slope regulations do not directly include geometric design features, involve incompatible use, or impact emergency access. Potential residential development allowed under the slope regulation revisions would be designed in accordance with City police and fire department requirements and would provide for adequate emergency access. Therefore, the project would not result in increased hazards related to project design and would not provide inadequate emergency access.

Mitigation Measures: The General Plan EIR identifies General Plan policies and actions that seek to reduce vehicle trips, encourage alternative transportation modes, and support infill and mixed-use development that would reduce trips. Residential development allowed under the proposed slope regulation revisions would also be required to pay City traffic impact fees that would be used to fund improvements to impacted intersections identified in the General Plan EIR. Future development allowed under the proposed slope regulation revisions would be within the projected buildout levels analyzed in the EIR and no new significant impacts have been identified. Therefore, no additional mitigation measures are required as no significant impacts have identified.

Conclusion: Revisions to the City’s slope regulations, as well as future development allowed under those revisions, would not result in new significant impacts or substantially more severe impacts than the impacts identified and analyzed in the certified General Plan EIR related to transportation.

18. Tribal Cultural Resources.
a) Would the project cause a substantial adverse
change in the significance of a tribal cultural
resource, defined in Public Resources Code
section 21074 as either a site, feature, place,
cultural landscape that is geographically defined
in terms of the size or scope of the landscape,
sacred place, or object with cultural value to a
California Native American tribe, and that is:

NA
No No No NA

26.64 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 38 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
i) Listed or eligible for listing in the California
Register of Historical Resources, or in the
local register of historical resources as
defined in Public Resources Code Section
5020.1(k), or
ii) A resource determined by the lead agency, in
its discretion and supported by substantial
evidence, to be significant pursuant to criteria
set forth in 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.

Discussion: (a) Subsequent to certification of the EIR, State Assembly Bill 52 was passed and became effective on July 1, 2015. The law establishes a new category of resources in the California Environmental Quality Act called “tribal cultural resources” that considers the tribal cultural values in addition to the scientific and archaeological values when determining impacts and mitigation. Public Resources Code section 21074 defines a “tribal cultural resource” as either: (1) sites, features, places, cultural landscapes, sacred places and objects with cultural value to a California Nature American tribe that is either listed, or determined to be eligible for listing, on the national, state, or local register of historic resources; or (2) a resource that the lead agency chooses, in its discretion and supported by substantial evidence, to treat as a tribal cultural resource. The California Public Resources Code section 21084.2 now establishes that “[a] project with an effect that may cause a substantial adverse change in the significance of a tribal cultural resource is a project that may have a significant effect on the environment.” The Public Resources Code requires a lead agency to consult with any California Native American tribe that requests consultation and is traditionally and culturally affiliated with the geographic area of a proposed project.

To date, no Native American tribe has contacted the City of Santa Cruz and requested consultation.

The proposed revisions to the City’s slope regulations would not increase development density, although 18 to 27 residential units could potentially be constructed on slopes greater than 50 percent, in locations not otherwise considered in the General Plan EIR. Future development would be subject to the provisions within Section 24.12.430 of the City’s Municipal Code that set forth procedure to follow in the event that unknown archaeological materials are unearthed during construction, as described in Section 5 above. Furthermore, future residential development would be subject to City approvals, including project-specific environmental review that would evaluate potential impacts to tribal cultural resources potentially existing on a project-by-project basis. Thus, the project would have a less-than-significant impact on tribal cultural resources.

26.65 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 39 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
Mitigation Measures: None were identified in the EIR, and no new mitigation measures are required with the proposed project modifications as no new significant impacts have been identified.

Conclusion: The proposed project modifications would not result in new significant impacts or substantially more severe impacts related to tribal cultural resources than the impacts identified in the certified EIR.

19. Utilities and Service Systems. Would the project:
a) Require or result in the relocation or construction
of new or expanded water, wastewater treatment
or storm water drainage, electric power, natural
gas, or telecommunications facilities, the
construction or relocation of which could cause
significant environmental effects?
DEIR pg 4.5-29 to 4.5-38; 4.7 -7 to

4.7-8; 4.6-21 to 4.6-25; 4.6-41 to

4.6-43; 4.7-22 to 4.7-24
FEIR pg 3-2 to pg 3-19
No No No No
b) Have sufficient water supplies available to serve
the project and reasonably foreseeable future
development during normal, dry and multiple dry
years?
DEIR pg 4.5-3 to 4.5-42
FEIR pg 3-2 to pg 3-19 No No No No
c) Result in a determination by the wastewater
treatment provider which serves or may serve the
project that it has adequate capacity to serve the
project’s projected demand in addition to the
provider’s existing commitments?
DEIR pg 4.6-21 to4.6-25; 4.6-41to

4.6-43
No No No No
d) Generate solid waste in excess of State or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment
of solid waste reduction goals?
DEIR pg 4.6-25 to 4.6-27; 4.6-43 to

4.6-44
FEIR pg 3-22
No No No No
e) Comply with federal, state, and local management
and reduction statutes and regulations related to
solid waste?
DEIR pg 4.6-25 to 4.6-27
No No No No
Discussion: (a-b) The General Plan EIR identified significant unavoidable impacts related to water demand and water supply as a result of development accommodated by the General Plan, and less-than-significant impacts related to wastewater and solid waste disposal. The proposed revisions to the

26.66 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 40 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
City’s slope regulations would not directly or indirectly result in new development not otherwise considered in the General Plan EIR that could result in additional water supply demand and impacts.

Subsequent to the City’s General Plan 2030, the City prepared and adopted the 2015 Urban Water Management Plan (UWMP) and the 2020 UWMP in November 2021. The 2020 UWMP reports that water demand in the City’s water service area has decreased over the past 20 years, and current demand is approximately 2.6 billion gallons per year (City of Santa Cruz 2021). The adopted 2020 UWMP forecasts that water use over the next 25 years, including projected population growth, will increase at a very slow rate to reach approximately 2.8 billion gallons per year by 2045 (Ibid.).This 20- year water demand is reduced from the estimated 3,500 MGY forecast in the 2010 UWMP that was used in the General Plan EIR analysis and also less that the forecast 3,200 MGY forecast in the 2015 UWMP.

The General Plan EIR and the subsequent City-adopted 2015 UWMP predicted that water supplies would be adequate in normal years to serve estimated growth within the City of Santa Cruz water service area. The General Plan 2030 EIR concluded that impacts to the City’s water supply would be significant and unavoidable during times of drought and potentially during normal years by the year 2030 with growth and development within the City’s water service area if recent water use trends change. Measures are identified in General Plan policies and actions to further conserve water, reduce demand and implement a supplemental water supply during droughts. The current adopted 2020 UWMP projects that the City will have sufficient water available in normal years and single dry years to serve anticipated demand to 2024 with implementation of the proposed water rights modifications and water augmentation strategies that are being implemented (City of Santa Cruz 2021). Available water supplies would not meet projected demands in 2025 for year five of a multi-year drought with estimated shortfall of 27 percent. However, by the year 2030, the City estimates that some planned water supply augmentation strategies will be implemented, which would substantially reduce potential shortages to a negligible two to five percent (Ibid.)
The proposed project could indirectly lead to construction of 18 to 27 residential units on slopes greater than 50 percent, a location not already considered in the General Plan EIR. As these units would not represent a net increase the number of units allowed under the General Plan density requirements, the location of the units on 50 percent or greater slopes would not result in new water demand, and demand from future development would fall within the total level of water demand estimated and analyzed in the General Plan EIR. Thus, the proposed project would not result in significant impacts related to availability of water supplies not otherwise addressed in the General Plan EIR. (c) The General Plan EIR concluded that the City’s wastewater treatment facility would be adequate to handle growth and development accommodated by the General Plan and would not require expansion or construction of facilities to serve future growth. The proposed revisions to the City’s slope regulations would not increase development density, although 18 to 27 residential units could potentially be constructed on slopes greater than 50 percent, on locations not otherwise considered in the General Plan EIR. However, this level of development is within the amount analyzed in the General Plan EIR. Therefore, the proposed project would not result in more severe impacts than evaluated in the General Plan EIR.

26.67 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 41 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
(d-e) The General Plan EIR concluded that the City’s landfill would be adequate to handle growth and development accommodated by the General Plan and would not require expansion or construction of facilities to serve future growth. The EIR analyses concluded that impacts of potential development and buildout accommodated by the General Plan would be less than significant for solid waste disposal. The proposed revisions to the City’s slope could indirectly lead to construction of 18 to 27 residential units on slopes greater than 50 percent, in locations not otherwise considered in the General Plan EIR. However, this level of development is within the amount analyzed in the General Plan EIR. Therefore, the project would not result in new significant impacts or more severe impacts than evaluated in the General Plan EIR Mitigation Measures: The General Plan EIR identifies General Plan policies and actions to reduce water demand, as well as the City’s efforts to supplement existing water supplies. Future residential development allowed under the project would be subject to City regulations regarding use of low-flow fixtures, appliances and landscaping. No additional mitigation measures are required.

Conclusion: Revisions to the City’s slope regulations, as well as future development that may occur as a result, would not result in new significant impacts or substantially more severe impacts than the impacts identified and analyzed in the certified General Plan EIR related to water and utilities.

20. Wildfire. If located near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted emergency
response plan or emergency evacuation plan?
DEIR pp. 4.6-2 to 4.6-5, 4.6-33 to

4.6-37
No No No
NA
b) Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose
project occupants to, pollutant concentrations
from a wildfire or the uncontrollable spread of
wildfire?
NA
No No No NA
c) Require the installation or maintenance of
associated infrastructure (such as roads, fuel
breaks, emergency water sources, power lines, or
other utilities) that may exacerbate fire risk or
that may result in temporary or ongoing impacts
to the environment?
NA
No No No NA
d) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
NA
No No No NA

26.68 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 42 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
Discussion: Subsequent to certification of the General Plan EIR, the State CEQA Guidelines were amended in December 2018, which requires evaluation of a new section on wildfire. Some of the steep-sloped areas in the City also are within wildland fire hazard areas. As indicated in subsection 7(c) above, the proposed project could indirectly result in construction of 18 to 27 residential units in areas with slopes greater than 50 percent that are often located in areas designated as high or extreme fire hazard areas in the City’s General Plan 2030. The project site is not located in or near a state responsibility area, but is located in a local responsibility area. Local responsibility areas are located within incorporated city limits. The City of Santa Cruz adopted a Wildland Urban Interface (WUI) Ordinance in 2019 (Title 19.05.270 of the Municipal Code) that identifies properties considered to be at risk The adoption of this ordinance allows the Building Division to utilize this information to enforce the provisions of 2019 CRC R337, Materials and Construction Methods for Exterior Wildfire Exposure, and 2019 CBC Chapter 7A (SFM), Materials and Methods for Exterior Wildfire Exposure, for properties these properties. The Fire Department also reviews any projects located in a WUI area.

All potential future development resulting from the proposed revisions to the City’s slope regulations would be required to comply with state and local regulations included in building and fire codes. These regulations include requirements for provision of adequate access and water supply, provision of fire sprinkler systems in new buildings, and provision of defensible exterior space. Thus, future development would be reviewed by the City’s Fire Department to ensure that adequate emergency access is provided. The construction of an additional structure on existing lots which may occur as a result of the proposed project would not be of a magnitude that would substantially impair an adopted emergency response plan or emergency evacuation plans.

New development in areas of steep slopes would be required to be designed in accordance with building and fire codes, which include requirements related to exterior building, window and roof materials. Therefore, future development that may occur as a result of the project development would be required to be designed to minimize risks resulting from exposure to wildland fire hazards. Furthermore, construction of an additional structure on existing lots throughout the City would not result in conditions that would exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrollable spread of wildfire. As discussed in subsection 7(c) above, any development on slopes greater than 50 percent would be required to be designed in accordance with recommendations of a geological report in order to prevent impacts related to slope instability, erosion or water quality. With these requirements, future development would be designed to avoid erosion or drainage impacts and would not be expected to result in downslope post-fire flooding or slope instability as a result of stormwater runoff. Therefore, the project would not result in new significant or more severe impacts related to slope stability that could lead to erosion or exacerbate potential wildland fire risks. Therefore, the project would not result in a new significant impact.

Mitigation Measures: None were identified in the EIR, and no new mitigation measures are required with the proposed project modifications as no new significant impacts have been identified.

Conclusion: The proposed project modifications would not result in new significant impacts or substantially more severe impacts related to wildfire.

26.69 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 43 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?

21. Mandatory Findings of Significance. Would the project:
a) Have the potential to degrade the quality of the
environment, substantially reduce the habitat of a
fish or wildlife species, cause a fish or wildlife
population to drop below self-sustaining levels,
threaten to eliminate a plant or animal
community, substantially reduce the number or
restrict the range of an endangered, rare or
threatened species or eliminate important
examples of the major periods of California
history or prehistory?
DEIR pg 4.8-13 to 4.8-21; 4.8-24;

4.8-26 to 4.8-30; 4.8-41; 4.8-38 to

4.8-45; 4.8-48 to 4.8-51; 4.9-10 to

4.9-12; 4.9-19 to 4.9-23
FEIR pg 3-22, 3-25 to 3-40
No No No
GP Action
NRC2.2.1 &
Project
Assessment
Protocols for
Special Status
Species; GP EIR
Mitigation 4.9-1
and Municipal
Code section

24.12.430
b) Does the project have impacts that are
individually limited, but cumulatively
considerable? (“Cumulatively considerable”
means that the incremental effects of a project
are considerable when view in connection with
the effects of past projects, the effects of other
current projects, and the effects of probable
future projects)?
DEIR pg 5-8 to 5-36
FEIR pg 3-27 to 3-31
No No No No
c) Does the project have environmental effects
which will cause substantial adverse effects on
human beings, either directly or indirectly?
DEIR pg 4.13-4 to 4.13-8; 4.13-10
to 4.13-20 No No No No
Discussion: (a) As discussed above in subsections 4-Biological Resources and 5-Cultural Resources, no new significant impacts were identified as a result of the proposed project. Thus, the General Plan buildout would not threaten wildlife populations or eliminate an important example of California history or prehistory.
(b) The EIR identified significant unavoidable cumulative impacts related to traffic, water supply, population growth, and noise as a result of cumulative development. As indicated above, the proposed project could indirectly result in construction of 18 to 27 residential units on slopes greater than 50 percent. However, the proposed project would not increase the number of units that could be constructed on a property and this level of development would be within the amount analyzed in the General Plan 2030 EIR with regards to cumulative impacts. Therefore, the proposed project would not change the density or intensity of use considered in the certified EIR and would not substantially increase the severity of impacts analyzed in the EIR.

Therefore, the proposed project would not result in new significant cumulative impacts or substantially more severe cumulative impacts.

26.70 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 44 F e b r u a r y 2 0 2 2 Environmental Issue Area
Where Impact Was Analyzed in Prior
Environmental Documents
Do Proposed
Changes Involve
New Significant
Impacts or
Substantially More
Severe Impacts?
Any New
Circumstances
Involving New
Significant
Impacts or
Substantially
More Severe
Impacts?
Any New
Information
Requiring New
Analysis or
Verification?
Prior
Environmental
Documents
Mitigations
Implemented or
Address Impacts?
(c) Potential adverse effects on human beings were considered in the Noise section of the General Plan EIR as discussed above in subsection 12-Noise.

The project would not result in additional environmental effects than those identified in the certified EIR; therefore, no new significant or substantially more severe effects on human beings would occur.

Mitigation Measures: The EIR identifies General Plan policies and actions to reduce the City’s contribution to significant cumulative impacts, and no additional mitigation measures are required as no significant impacts have identified.

Conclusion: The proposed revisions to the City’s slope regulations, as well as future residential development, would not result in new significant impacts or substantially more severe impacts than the impacts identified and analyzed in the certified General Plan EIR related to topics requiring a mandatory finding of significance.

26.71 C I T Y O F S A N T A C R U Z REVISIONS TO SLOPE REGULATIONS GENERAL PLAN 2030 EIR ADDENDUM 45 F e b r u a r y 2 0 2 2 V I I . R E F E R E N C E S
City of Santa Cruz. General Plan 2030 and EIR.
a. Adopted June 26, 2012. General Plan 2030. Available online at https://www.cityofsantacruz.com/government/city-departments/planning-andcommunity-development/long-range-policy-planning/general-plan. b. April 2012. City of Santa Cruz General Plan 2030 Final EIR. SCH #2009032007. Certified June 26, 2012. Includes Draft EIR document, dated September 2011 Final EIR volume, dated April 2012. Available online at:
https://www.cityofsantacruz.com/government/city-departments/planning-andcommunity-development/long-range-policy-planning/general-plan.

City of Santa Cruz. Adopted November 9, 2021 City of Santa Cru 2020 Urban Water Management Plan. Prepared by City of Santa Cruz Water Department. November 2021. Available online at:
https://www.cityofsantacruz.com/government/city-departments/water/urban-watermanagement-plan-2020. .

Monterey Bay Air Resources District (Formerly Monterey Bay Unified Air Pollution Control District).
a. February 2008. CEQA Air Quality Guidelines. Available online at:
https://www.mbard.org/files/f665829d1/CEQA_full+%281%29.pdf. b. Adopted April 1996-Revised February 2016. Guidelines for Implementing the California Environmental Quality Act.

26.72 Attachment 4
Planning Commission

AGENDA REPORT
DATE: 12/18/2021
AGENDA OF: 1/20/2022
DEPARTMENT: Planning and Community Development
SUBJECT: A20-0008: Slope Regulations Amendment Ordinance (PL) RECOMMENDATION: That the Planning Commission recommend that the City Council: 1) Acknowledge the Addendum to the 2030 General Plan certified Environmental Impact Report (EIR); 2) Approve the proposed Slope Regulations Update Ordinance and amendments to the Local Coastal Program; and 3) Direct the City Manager to submit the amendments to the Local Coastal Program to the California Coastal Commission for approval.

BACKGROUND: The Slope Regulations in the City’s Zoning Ordinance regulate development on slopes of thirty percent or greater. They were last updated in 1995 and implement policies of the previous General Plan (General Plan 1990-2005). Staff originally proposed amending the slope regulations to implement the General Plan 2030 policies with a package of other ordinance amendments in 2020. At the Planning Commission public hearing for this ordinance on September 17, 2020, the Planning Commission voted to continue the Slope Regulation amendments to a date uncertain, recommending that the City Council approve the remainder of the amendments in the package and requesting that staff return with the slope regulations separately. Staff had brought additional revisions to the slope regulations to the meeting that had not been included in the packet and the majority of Planning Commission felt it would be of benefit to have this ordinance receive separate discussion and evaluation at a later date.

DISCUSSION: The 2030 General Plan includes several actions to address development on slopes. Action CD 1.3.2 recommends that the City “Update the Zoning Ordinance to address new construction techniques and “best management practices” related to construction on slopes.” In addition, Action CD 1.3.3 recommends that the City “Review the slope development provisions of the Zoning Ordinance and update them as deemed necessary.” The proposed amendments are intended to implement both of these General Plan recommendations.

Generally speaking, the current slope regulations require buildings to maintain a 20-foot setback from slopes exceeding 30 percent. A Slope Modification Permit is required if a building is proposed between 10 and 20 feet from a 30 percent or greater slope, which can be administratively approved by the Zoning Administrator unless combined with an entitlement that requires a public hearing. For buildings less than 10 feet from a 30 percent or greater slope, a Slope Variance is required, which is heard by the Planning Commission. Buildings are not allowed on slopes exceeding 50 percent.

26.73 Planning Commission Meeting of January 20, 2022
Slope Regulation Amendment A20-0008