Agenda, first session — Solvang City Council, January 10, 2022 (part 2 of 7)

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City of Solvang and City of Guadalupe
Monterey Bay Community Power Participation Memorandum of Understanding It should also be noted that community collaboration and regionalism was a key value ofthe effort to create a local community choice energy program. This Memorandum of Understanding seeks to encourage further regional collaboration.

C. SHARED SEATS

1. Policy Board - The Policy Board representative shall serve for a term of two years and shall alternate between cities. SOLVANG shall provide the initial representative and will serve from December 2019 to December 2021 and thereafter shall rotate every two years between the City of Solvang and Guadalupe.
a. The City with the currently serving Policy Board representative shall distribute via email to both City Councils and City Managers, the meeting minutes and any additional narrative deemed necessary after each Policy Board meeting to stay informed ofpolicy, business or other related matters.
b. The Policy Board Director alternative shall be identified by the City currently holding the seat.

2. Operations Board - The Operations Board representative shall serve for a term of two -years and may be one of two options:
a. The City Manager for the City of the Policy Board representative; or b. A director or deputy - director level staff member as determined by the City Manager of the Policy Board representative.

3. Community Advisory Council — There shall be one Community Advisory Council member that shall serve a two- year term and be selected by the current Policy Board Member and their alternative. The pool of Community Advisory Committee applicants shall include all registered voters residing in the cities of Solvang and Guadalupe. The City currently providing the Policy Board representative shall conduct the Community Advisory Council selection process.

4. In all cases, the elected officials, staff, or public representing the joint interests of SOLVANG and GUADALUPE, for purposes of the MBCP, shall consider the program purposes outlined in the Central Coast Community Energy Joint Exercise of Powers Agreement:
a. Reducing greenhouse gas emissions;
b. Providing electric power to customers at a competitive cost; c. Carrying our programs to increase energy efficiency; d. Stimulating and sustaining the local economy by developing local jobs in renewable energy and energy efficiency; and
e. Promoting long-term rate stability and energy security and reliability for residents through local control of electric generation resources.

5. If a party fails to attend or otherwise comply with the Monterey Bay Community Power JPA and bylaws, and if the seat becomes vacated because of such conduct, the other party shall serve in that seat.

D. PROCESS
SOLVANG City Council will appoint its respective Board Members for the two- year term by February 2019. Terms shall run for two -years starting in December and concluding in November of even- numbered years.

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City of Solvang and City of Guadalupe
Monterey Bay Community Power Participation Memorandum of Understanding Future term appointees shall be made by alternating City Councils in November of the year that the term concludes ( e. g., SOLVANG in 2020, GUADALUPE in 2022, SOLVANG in 2024).

E. PRINCIPAL CONTACTS
The principal contacts for this MOU are:

SOLVANG:

Name
Xenia Bradford

GUADALUPE
Name
Todd Bodem
F. COST OBLIGATION
Role:

Acting City Manager, City Lead
Role:

City Administrator, City Lead
Each party to this Memorandum of Understanding shall be financially responsible for absorbing costs incurred for their own participation on the Policy Board, Operations Board, and Community Advisory Council.

G. COMMENCEMENVEXPIRATION DATE
This Memorandum of Understanding is executed as of the date of last signature and is effective until an additional local governmental agency within the Santa Barbara County jurisdiction joins MBCP, or SOLVANG or GUADALUPE withdraw from MBCP, or either party fails in good faith to resolve with the other party a conflict over a substantial issue concerning the MBCP or the parties' performance of this MOU. Prior to such termination, the party desiring to terminate this MOU shall provide the non -terminating party with written notice of its desire to terminate and the reasons therefore. Both parties agree to engage in a meet and confer process, and, in the case of termination based on a conflict over a substantial issue concerning the MBCP or the parties' performance ofthis MOU, the parties shall engage with one another in good faith to resolve the conflict. If a conflict still exists after such good faith negotiations, this MOU shall terminate upon thirty ( 30) days final written notice.

H. LIABILITIES
It is understood that neither party to this Memorandum of Understanding is the agent of the other and neither is liable for the wrongful acts, omissions or negligence of the other. Each parry shall be responsible for its wrongful or negligent acts or omissions and those of its officials, officers, employees, and agents, howsoever caused, to the extent allowed by law, and shall be responsible for their own Commercial General Liability, Auto, Worker' s Compensation and Errors and Omissions insurance and adherence to their respective City' s policies. Each party to this Memorandum ofUnderstanding agrees to indemnify, defend and hold the other, and their officials, officers, employees, and agents, against any liability, claim, personal injury, including death, or property damage caused by that party' s negligence or willful misconduct in their performance under this Memorandum of Understanding.

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City of Solvang and City of Guadalupe
Monterey Bay Community Power Participation Memorandum of Understanding I. NO ASSIGNMENT
The rights and obligations of the parties to this Memorandum of Understanding may not be assigned or delegated.

J. AMENDMENT
This Memorandum of Understanding may not be amended or modified in any manner whatsoever except by written agreement between the parties hereto.

IN WITNESS WHEREOF, the parties hereto have executed this agreement as of the last written date below.

FOR SOLVANG:

Date: / 0411 J
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FOR GUADALUPE
Date:

Xenia Bradford, Acting City Manager, City of Solvang
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Todd Bodem, City Administrator, City of Guadalupe

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City Council Reorganization

DEPARTMENT BUDGET UPDATES
Recommendation

1. Designate the Mayor Pro Tem for 2022

2. Designate the Seating Arrangement for 2022

3. Make Council member appointments to Board and
Committees
Current Appointments
Central Coast Community Energy – Mayor Uhrig
Santa Barbara County Library Advisory Committee – Councilmember Clarke Agenda Item Number: 8
Solvang City Council STAFF REPORT
PREPARED BY: Xenia Bradford, City Manager
MEETING DATE: January 10, 2022
SUBJECT: APPROVE GRANT FUNDING POLICY
RECOMMENDATION:

Review Grant Funding policy for non-profit organizations for Fiscal Year 2022- 24 Financial Plan development.

DISCUSSION:

The City of Solvang City Councils throughout the years have allocated funds through the “Grant” program to various non-profits and organizations in support of their mission. The Grant funding process is traditionally kicked- off by City Council review of the Grant Funding Policy ( see Attachment A). Each year, the Council reviews the policy and adopts the policy or provides staff with policy direction. Once the Grant Funding Policy is adopted, staff announces an open application timeline. Organizations interested in applying for a grant from the City of Solvang submit applications as directed by the City and City Council considers grant awards as part of the annual budget adoption process. In 2020, City Council significantly modified the Grant Funding Policy to limit awards to humanitarian service organizations only with a focus on senior services.

If desired, City Council could direct staff to develop recommendations for grant funds to organizations that have received grant funds over a long period of time on consistent basis, to be awarded on contract terms as a standing proposed line-item in the budget instead.

ALTERNATIVES:

FISCAL IMPACT:

There is no immediate fiscal impact with this item.

ATTACHMENTS
Grant Funding Policy
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CITY OF SOLVANG

HUMAN SERVICES GRANT FUNDING

POLICIES AND PROCEDURES
The Solvang City Council recognizes the importance of the human services and programs and organizations that serve community residents. As part of the annual budget process and financial plan development, the City Council shall appropriate such funds as it deems prudent and reasonable to award grants to non-profit community service organizations.

Policy
A. Organizations must provide services for Solvang residents.

B. Grants shall not be available to organizations who intend to directly or indirectly act as a conduit to provide the grant funding to other organizations.

D. The City will prioritize funding for senior citizen services.

E. City grant funds may not be used by the agency for administrative/ overhead types of costs.

Procedures
a. Staff will review applications for completeness and incomplete applications will be returned to the requesting organization.
b. Copies of all funding applications received will be provided to all City Council members and will be considered by Council in June as part of budget adoption hearing. c. A representative from the requesting agency must be available for questions from the City staff and/or City Council related to their grant funding application and must attend and present at the annual City budget hearing.
d. Following adoption of the annual City budget and execution of City standard Grant Funding Contract with the City, the City will disburse the funds within 30 days.

ATTACHMENT A
289
Agenda Item Number: 9
Solvang City Council STAFF REPORT
PREPARED BY: Xenia Bradford, City Manager
MEETING DATE: January 10, 2022
SUBJECT: REAPPOINT TOURISM ADVISORY COMMITTEE MEMBER

CHERYL SHALLANBERGER DUE TO COMMITTEE MEETING

TIME CHANGE
RECOMMENDATION:

Mayor pro tem Orona may consider reappointment of former member Cheryl Shallanberger to the Tourism Advisory Committee for the term to 12-31-2022 or appoint an alternate candidate.

DISCUSSION:

Due to the time change for the regular meetings of the Tourism Advisory Committee from 9:00 a.m. to 3:30 p.m. on the first Thursday of each month, former member Cheryl Shallanberger is now able to attend.

The Tourism Advisory Committee initially met at 5:00 p.m. and revised their regular meeting schedule to 9:00 a.m. on every first Thursday of the month. Due to a conflict with work and inability to attend the regularly scheduled 9:00 a.m. meeting time, TAC member Shallanberger had resigned from her appointment.

Tourism Advisory Committee has once again amended its regular meeting schedule to meet monthly on every first Thursday at 3:30 pm. When the regularly scheduled meetings were set for 9:00 am, due to conflict with work and inability to attend the regularly scheduled meeting time, TAC member Shallanberger had resigned from her appointment.

Mayor pro tem Orona had requested inquiring whether Member Shallanberger would like to remain on the Committee given the change in regularly set meetings. Cheryl Shallanberger has expressed desire and willingness to serve on the committee. Today’ s action is to re-appoint Cheryl Shallanberger to the Tourism Advisory Committee shall Mayor pro tem would like to do so. Cheryl Shallanberger was originally Mayor pro tem Orona’ s appointee.

The TAC membership is established by the City of Solvang Municipal Code section cited below.
2-5-2 Membership.
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A. Appointment. Each city council member shall appoint one ( 1) tourism advisory committee member selected from the qualified individuals who apply to the city council, which shall include incumbents. The city council by majority vote may appoint up to two ( 2) additional members selected from the qualified individuals who apply to the city council, which shall include incumbents. The tourism advisory committee shall be comprised of no more than seven (7) members. The city council may appoint an alternate member from a participating organization to serve as a voting member during the absence of the first appointee.

B. Qualification. The tourism advisory committee shall represent a cross section of the community as it relates to tourism and represent as many of the following categories as possible: large hotel, small hotel, large retailer, small retailer, shopping center, restaurant, cultural- visual and/or performing arts, real estate, local attraction or a profession within the marketing community. Each tourism advisory committee member shall be a legal resident within the boundaries of one ( 1) of the following zip codes at the time of the member’ s appointment and during the member’ s tenure in office: 93463, 93464, 93427, 93460, 93440 (Solvang, Buellton, Santa Ynez and Los Alamos). 212 C. Term and Vacancies. 1. The term of office for tourism advisory committee members shall be two ( 2) years. The term of all members shall expire on December 31 of each even year. Each tourism advisory committee member may be reappointed from term to term in the same manner as set forth in subsection A of this section. 2. Vacancies shall be filled for the unexpired portion of the term in the same manner as set forth in subsection A and in the same manner as the original appointment.

D. Removal— Termination Due to Nonattendance. 1. Committee members may be removed at any time by affirmative vote of three (3) members of the city council. Removal shall create a vacancy under subsection C of this section. 2. A tourism advisory committee member shall be permitted two ( 2) unexcused absences per calendar year and a third unexcused absence shall be deemed removed from membership without further action of the committee or city council, unless excused for cause by the chairperson, or if the chairperson, by a majority of the tourism advisory committee. The tourism advisory committee shall notify the city council immediately of any such removal due to nonattendance. Such removal shall create a vacancy under subsection C of this section.

E. Compensation and Expenses. 1. Any compensation of the tourism advisory committee members shall be fixed by resolution of the city council. 2. Tourism advisory committee members may be reimbursed for their necessary and actual expenses incurred on official city business in accordance with city policy. ( Ord. 21-0351 § 1) ALTERNATIVES:

Mayor pro tem Orona may continue the item to a future date.

FISCAL IMPACT:

N/A

ATTACHMENTS
N/A
291
Agenda Item Number: 10
Solvang City Council STAFF REPORT
PREPARED BY: Xenia Bradford, City Manager
Chelsea O’Sullivan, Assistant City Attorney
MEETING DATE: January 10, 2022
SUBJECT: CONSIDERATION OF A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SOLVANG, CALIFORNIA ADOPTING AN ADDENDUM TO THE 2011 WATER SYSTEM

MASTER PLAN UPDATE FINAL ENVIRONMENTAL IMPACT REPORT PURSUANT TO

THE CALIFORNIA ENVIRONMENTAL QUALITY ACT, AND APPROVING

MODIFICATIONS TO THE RIVER WELLS PROJECT
RECOMMENDATION:

That the City Council adopt Resolution No. 22-1154, a Resolution of the City Council of the City of Solvang, California adopting an Addendum to the 2011 Water Systems Master Plan Update Final Environmental Impact Report pursuant to the California Environmental Quality Act, and Approving the Revised River Wells Project.

SUMMARY:

The City is currently pursuing a Petition for Change before the State Water Resources Control Board’ s Administrative Hearing Office (“ AHO”) seeking changes to Permit 15878 for extraction of Santa Ynez River underflow. This project was originally evaluated under CEQA as part of the 2011 Water System Master Plan Update, but the scope of the project has since been modified and reduced such that the City prepared an Addendum to the prior EIR. The AHO has ordered the City to submit its CEQA documentation on or before February 1, 2022. The revised project and the Addendum, in conjunction with the prior EIR, is before the City Council for consideration.

DISCUSSION:

The City prepared an environmental impact report for the whole of the 2011 Water System Master Plan Update (“ Original Project”) and certified a Final Environmental Impact Report for the Original Project ( 2014 Certified FEIR) on February 24, 2014. The 2014 Certified FEIR did not identify any significant impacts and found that the Original Project would have no impact, less than significant impact or less than significant impact with mitigation. A mitigation monitoring and reporting program was prepared for the Original Project in January 2014 (2014 MMRR) to implement the mitigation measures identified in the 2014 Certified FEIR.

On or about May 5, 2015, the City submitted a Petition for Change and Petition for an Extension of Time with the State Water Resources Control Board (Board) for Permit 15878 to pursue the river wells portion of the Original Project. Alisal Guest Ranch; Santa Ynez River Water Conservation District, Improvement District No. 1; California Trout; and National Oceanic and 292
Atmospheric Administration/ National Marine Fisheries Services ( NOAA/ NMFS) submitted protests to the City’s Petitions. The City’ s Petitions were subsequently forwarded to the Board’ s Administrative Hearings Office (“ AHO”). The City, Alisal Ranch and ID No. 1 have entered into a Protest Dismissal Agreement resolving Alisal Guest Ranch’ s and ID No. 1’s respective protests.

The City has also since withdrawn its Petition for an Extension of Time but continues to pursue its Petition for Change, but for a revised and reduced version of the river wells portion of the Original Project.

The City is now seeking to install up to two (2) new wells downstream of the Alisal Bridge to extract river underflow, limit the City’ s annual diversion to the historic maximum of 1,368 and the production rate to a maximum of 2.84 cfs, and ultimately limit its reach of diversion and shift it downstream (“ Revised River Wells Project”). The City is also no longer pursuing the water treatment plant proposed in the Original Project. The Revised Project does not address other aspects of the Original Project. See Attachment C for a Revised Project description.

The City has prepared an Addendum to the 2014 Certified FEIR, a copy of which is included as Attachment B and incorporated herein by reference, for the Revised River Wells Project in accordance with CEQA Guideline Section 15164. A lead agency, such as the City, is required to prepare an addendum to a previously certified environmental impact report (“ EIR”) when “ some changes or additions are necessary but none of the conditions . . . calling for the preparation of subsequent EIR have occurred.”
Pursuant to CEQA Guidelines Section 15162, a subsequent EIR is required if the lead agency determines based on substantial evidence one or more of the following conditions exist:

Substantial changes are proposed in the project, or substantial changes occur with respect to the circumstances under which the project will be undertaken, which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;
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 EIR was certified as complete, shows:
o The project will have one or more significant effects not discussed in the previous EIR;
o Significant effects previously examined will be substantially more severe than shown in the previous EIR;
o 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
o 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 measure or alternative.

The Addendum did not identify any new or greater significant impacts and found that the Revised River Wells Project would have no impact, less than significant impact or less than significant impact with the mitigation identified in the 2014 Certified FEIR. The 2014 MMRR shall apply to the Revised River Wells Project and will still be implemented. The Addendum did not identify any 293
new significant impacts or a substantial increase in the severity of a previously identified impact or any new information of substantial importance that would trigger the need for a subsequent EIR. The Addendum does not need to be circulated for public review but is attached to the 2014 Certified FEIR. The City Council should consider the Addendum in conjunction with the 2014 Certified FEIR when considering approval of the Revised River Wells Project.

The Administrative Hearing Officer issued an order on November 12, 2021 ordering the City to submit its CEQA documentation supporting its Petition for Change by February 1, 2022.

ALTERNATIVES:

The City could decide not to adopt the Addendum and decline to approve the Revised River Wells Project. Such an action is not recommended as the Administrative Hearing Officer has ordered the City to submit its CEQA documentation by February 1, 2022.

FISCAL IMPACT:

Adoption of the Addendum will not have any additional fiscal impact beyond what is already contemplated for pursuing the Revised River Wells Project with the State Water Resources Board.

ATTACHMENTS:

A. Resolution No. 22-1154
B. Addendum to the 2011 Water Systems Master Plan Update Final Environmental Impact Report C. River Wells Project Description ( September 27, 2021) D. Final Environmental Impact Report for the 2011 Water System Master Plan Update, available at https:// www.cityofsolvang. com/ DocumentCenter/ 21 (under folders titled “Water Master Plan DEIR” and “ Water System Master Plan Final EIR”)
294
RESOLUTON NO. 22-1154

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SOLVANG, CALIFORNIA ADOPTING AN ADDENDUM TO THE 2011 WATER SYSTEM

MASTER PLAN UPDATE FINAL ENVIRONMENTAL IMPACT REPORT PURSUANT

TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT, AND APPROVING THE

REVISED RIVER WELLS PROJECT
WHEREAS, the City of Solvang, acting as lead agency, prepared, pursuant to the California Environmental Quality Act (“ CEQA”) ( Public Resources Code Section 21000 et seq.), an environmental impact report for the 2011 Water System Master Plan Update (“ Original Project”); and
WHEREAS, the Original Project consists of proposed future upgrades, new facilities, and programs to provide water to the current and future residents of the City, including the installation of up to six (6) new wells to extract river underflow at a maximum rate of 5 cubic feet per second cfs”) with a maximum annual diversion of 1,980 acre feet per year (“ AFY”) and to add 8,500 feet to the City’ s existing reach of diversion downstream of the Alisal Bridge; and WHEREAS, the City Council certified a Final Environmental Impact Report (“ EIR”) for the Original Project (“ 2014 Certified FEIR”) on February 24, 2014 ( State Clearinghouse 2011011007), which did not identify any significant and unavoidable impacts and found that the Original Project would have no impact, less than significant impact or less than significant impact with mitigation. A mitigation monitoring and reporting program was prepared for the Original Project in January 2014 (“ 2014 MMRR”) to implement the mitigation measures identified in the 2014 Certified FEIR; and
WHEREAS, on or about May 5, 2015 the City submitted a Petition for Change and Petition for an Extension of Time with the State Water Resources Control Board (Board) to pursue the river wells portion of the Original Project which the Board subsequently referred to the Board’ s Administrative Hearing Office (“ AHO”); and
WHEREAS, the City has since withdrawn its Petition for an Extension of Time but continues to pursue its Petition for Change, though the City is now proposing modifications to the project that reduced the scope of the river wells portion of the Original Project; and WHEREAS, the City is now seeking to install up to two (2) new wells downstream of the Alisal Bridge to extract river underflow, limit the City’ s annual diversion to the historic maximum of 1,368 and the production rate to a maximum of 2.84 cfs, and ultimately limit its reach of diversion and shift it downstream (“ Revised River Wells Project”). The City is also no longer pursuing the water treatment plant proposed in the Original Project. The Revised Project does not address other aspects of the Original Project; and
WHEREAS, under CEQA, the lead agency or a responsible agency shall prepare an addendum to a previously- certified EIR if some changes or additions are necessary to the prior EIR, but none of the conditions calling for preparation of a subsequent or supplemental EIR have occurred ( Public Resources Code Section 21166; CEQA Guidelines Sections 15162 and 15164).

Once an EIR has been certified, no supplement or subsequent EIR shall be prepared unless the Attachment A
295
lead agency or responsible agency determines that a specific condition has been met as required by CEQA Guidelines Section 15162( a)( 1),(2), and ( 3); and WHEREAS, the City has prepared an Addendum to the 2014 Certified FEIR, a copy of which is attached as Exhibit A and incorporated herein by reference, for the Revised River Wells Project in accordance with CEQA Guidelines Section 15164; and WHEREAS, the Addendum did not identify any new or greater significant impacts and found that the Original Project would have no impact, less than significant impact or less than significant impact with the mitigation identified in the 2014 Certified FEIR. The 2014 MMRR shall apply to the Revised River Wells Project and will still be implemented; and WHEREAS, the Addendum did not identify any substantial project changes or changed circumstances requiring major revisions to the 2014 Certified FEIR due to new significant impacts or a substantial increase in the severity of a previously identified impact or any new information of substantial importance, and as such a subsequent environmental impact report is not required; and
WHEREAS, the Addendum need not be circulated for public review but is attached to the 2014 Certified FEIR; and
WHEREAS, on January 10, 2022, at a duly-noticed meeting of the City Council of the City of Solvang, and during which there was an opportunity for public comment, the City Council considered the Addendum, and has reviewed and considered the Addendum in conjunction with the 2014 Certified FEIR and the findings in this Resolution; and WHEREAS, the AHO has ordered the City to submit its CEQA documentation supporting its Petition for Change on or before February 1, 2022.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF SOLVANG DOES HEREBY RESOLVE AS FOLLOWS:

SECTION 1. The recitals set forth above are true and correct and are adopted as findings in support of this Resolution.

SECTION 2. The City Council has independently reviewed and considered the contents of the Addendum prior to deciding whether to approve the Revised River Wells Project. The City Council finds, in its independent judgment after considering all relevant evidence in the record of proceedings for the Revised River Wells Project, that substantial evidence in the whole of the record supports the City Council’ s conclusion that none of the conditions requiring preparation of an environmental impact report or subsequent negative declaration have occurred, that the mitigation identified in the 2014 MMRR for the 2014 Certified FEIR applies to and addresses impacts from the Revised River Wells Project, and that no further environmental review is needed.

Specifically, the City Council finds as follows:
a. Major EIR revisions are not required: There is no evidence in the record that major changes to the 2014 Certified FEIR are required. No information has been presented to the City to demonstrate that any substantial changes have occurred with respect to the Revised River Wells Project involving new significant environmental effects or a substantial increase in the severity of previously identified significant effects. The Revised River Wells Project is consistent with the Original Project and alternatives analyzed in the 2014 296
Certified FEIR and is smaller in scope than what was analyzed in that FEIR. The analysis in the Addendum and the supporting technical analyses conclude that the impacts are similar to or reduced from the Original Project. The facts demonstrate that there are no new significant or more severe environmental impacts, and that the approval of the Revised River Wells Project would have the same or reduced impacts as those described in and already addressed in the 2014 Certified FEIR.
b. No substantial change in circumstances requiring major EIR revisions: There is no information in the record, or otherwise available, that indicates that there are substantial changes in circumstances that would require major changes to the 2014 Certified FEIR.

The Revised River Wells Project remains consistent with, and is smaller in scope than, the Original Project described in the FEIR. There have been no significant changes in the scope of the existing circumstances that would alter the ability of the Revised River Wells Project to remain consistent with, or less than, the environmental impacts analyzed in the FEIR.
c. No new information showing new or greater significant effects than identified in the EIR: There is no substantial new information, which was not available at the time the Certified 2014 FEIR was certified, indicating there will be a new, significant impact requiring major revisions of the FEIR. The revisions proposed as part of the Revised River Wells Project are lesser in scope than the Original Project and the City Council finds the Revised River Wells Project would not cause an increase in the severity of any environmental impact and that the impacts of the Revised River Wells Project are either similar or reduced than the Original Project analyzed in the FEIR. d. No new information showing ability to reduce significant effects identified in the EIR: There are no significant impacts requiring identification of new or additional alternatives to the Revised River Wells Project, or consideration of new or additional, more significant effects identified in the Certified 2014 FEIR. The FEIR included mitigation measures to reduce impacts to a level of less than significant, and the same mitigation measures apply to the Revised River Wells Project. No information, let alone substantial evidence, has been presented to suggest that the Revised River Wells Project has environmental impacts beyond those previously analyzed, disclosed, and mitigated as set forth in the FEIR. No information regarding any purported greater environmental impacts, or the need for additional mitigation or alternatives, has been presented.

SECTION 3. The City Council hereby adopts the Addendum and approves the Revised River Wells Project as described in the Addendum.

SECTION 4. The City Council directs staff to file a Notice of Determination for the Addendum.

SECTION 5. This resolution shall be effective immediately upon adoption SECTION 6. That the City Clerk shall certify to the passage and adoption of this Resolution and shall cause a certified copy to be filed in the book of original resolutions.

PASSED, APPROVED, AND ADOPTED on the 10th day of January 2022. 297
Charlie Uhrig, Mayor
APPROVED AS TO FORM: ATTEST:

Chelsea O’Sullivan, Assistant City Attorney Annamarie Porter, City Clerk 298

STATE OF CALIFORNIA )
COUNTY OF SANTA BARBARA ) ss

CITY OF SOLVANG )
I, Annamarie Porter, City Clerk of the City of Solvang, California do hereby certify that Resolution No. 22-1153 was passed and adopted by the City Council of the City of Solvang at a regular meeting of said City Council held on the 10th day of January 2022, and thereafter signed and approved by the Mayor and attested by the City Clerk, and that said resolution was adopted by the following vote:

AYES:

NOES:

ABSTAIN:

ABSENT:

Annamarie Porter, City Clerk
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Addendum
to the
2011 Water System Master Plan Update
Final Environmental Impact Report
State Clearinghouse No. 2011011007
PREPARED BY:

City of Solvang
411 Second Street
Solvang, California 93463
PREPARED WITH ASSISTANCE OF:

Westlake Village
920 Hampshire Road, Suite A5
Westlake Village, CA 91361
Los Angeles
706 S. Hill Street, 11th Floor
Los Angeles, CA 90014
January 2022
Attachment B
300

TABLE OF CONTENTS
Section Page

1.0 Introduction ............................................................................................................................... 10-1

1.1 Addendum Applicability ................................................................................................ 1.0-1

1.2 Background ................................................................................................................... 1.0-3

2.0 Project Description .................................................................................................................... 2.0-1

2.1 Revised Project Location ............................................................................................... 2.0-1

2.2 Revised Project ............................................................................................................. 2.0-5

2.3 Revised Project Objectives ............................................................................................ 2.0-9

2.4 Revised Project Construction ........................................................................................ 2.0-9

2.5 Revised Project Cumulative Scenario ......................................................................... 2.0-10

3.0 Impact Analysis .......................................................................................................................... 3.0-1

3.1 Hydrology, Water Supply, and Water Quality .............................................................. 3.0-2

3.2 Terrestrial Biological Resources .................................................................................. 3.0-46

3.3 Fisheries Resources ..................................................................................................... 3.0-79

3.4 Cultural Resources .................................................................................................... 3.0-147

3.5 Air Quality ................................................................................................................. 3.0-160

3.6 Greenhouse Gases .................................................................................................... 3.0-173

3.7 Land Use .................................................................................................................... 3.0-181

3.8 Recreation ................................................................................................................. 3.0-187

3.9 Noise ......................................................................................................................... 3.0-195

3.10 Hazards and Hazardous Materials ............................................................................ 3.0-207

3.11 Aesthetics .................................................................................................................. 3.0-211

3.12 Energy ....................................................................................................................... 3.0-222

3.13 Utilities/ Service Systems ........................................................................................... 3.0-231

3.14 Tribal Cultural Resources .......................................................................................... 3.0-236

4.0 References ................................................................................................................................. 4.0-1

5.0 Preparers .................................................................................................................................... 5.0-1 Appendices
Appendix A GSI Hydrogeologic Assessment
Appendix B GSI Estimates of Surface Water Flow
Appendix C Pax Terrestrial Biological Resources Report
Appendix D PaleoWest Cultural Resources Memo
Appendix E Air Quality and GHG CalEEMod Output Files
301
List of Figures
Figure Page

1.0-1 Existing and Additional Reach of Diversion at the Time of the Certified FEIR ........................... 1.0-8

1.0-2 Revised Proposed Reach of Diversion Map ............................................................................... 1.0-9

1.0-3 Existing Wells and Proposed Well Site Areas ........................................................................... 1.0-10

2.0-1 Revised Project Site Plan ............................................................................................................ 2.0-3

2.0-2 Revised Project and Reach of Diversion .................................................................................... 2.0-4 List of Tables
Table Page

1.0-1 Significance of Environmental Issues for the Approved Project ................................................ 1.0-5

2.0-1 Total Water Production Current and Future Supply by Source ................................................. 2.0-6

2.0-2 Annual Operations Plan for City Wells without Revised Project Wells ..................................... 2.0-7

2.0-3 Annual Operations Plan for City Wells with Revised Project Wells ........................................... 2.0-8

2.0-4 Comparison of Approved Project and Revised Project ............................................................. 2.0-9

2.0-5 Existing and Claimed Water Rights and Diversions ............................................................ 2.0-12-14

3.1-1 Mainstem Rearing Flows .......................................................................................................... 3.0-21

3.1-2 Flows (Wet and Above Normal Water Year Types) ................................................................. 3.0-23

3.1-3 Reclamation’ s Proposed Ramping Rates ................................................................................. 3.0-23

3.1-4 Summary of Santa Ynez River Flow at Alisal Bridge Relative to Baseline Conditions .............. 3.0-30

3.5-1 Estimated Construction Emissions of the Approved Project ................................................. 3.0-162

3.5-2 Estimated Operational Emissions of the Approved Project .................................................. 3.0-163

3.5-3 Estimated Construction Emissions of the Revised Project .................................................... 3.0-169

3.6-1 Estimated Construction GHG Emissions ................................................................................ 3.0-173

3.6-2 Estimated Operational GHG Emissions of the Certified FEIR ................................................. 3.0-174

3.6-3 Estimated Construction GHG Emissions of the Revised Project ............................................ 3.0-178

3.6-4 Estimated Operational GHG Emissions of the Revised Project ............................................. 3.0-178

3.12 1 Estimated Construction Energy Demand ............................................................................... 3.0-222

3.12-2 Estimated Operational Energy Demand of the Proposed Project ......................................... 3.0-224

3.12-3 Estimated Construction Energy Demand of the Revised Project .......................................... 3.0-228

3.12-4 Estimated Operational Energy Demand of the Revised Project ............................................ 3.0-229 302

1.0 INTRODUCTION
This document is an addendum to the Final Environmental Impact Report for the 2011 Water System Master Plan Update (“ 2011 Master Plan Update”) EIR ( SCH No. 2011011007), certified by the City in February 2014 (“ Certified FEIR”) to analyze changes to a portion of the previously approved 2011 Master Plan Update ( herein after referred to as the “2011 Master Plan Update” or the “Approved Project”). The Approved Project provided details on the existing City water system, proposed future upgrades, and new facilities to provide water to the current and future residents and businesses of the City. A major aspect of the Approved Project is the installation of new Santa Ynez River underflow wells to extract additional Santa Ynez River underflow under Water Right Permit No. 15878. Under the Approved Project the City had proposed to install up to six ( 6) new wells, with a capacity of about 300 gallons per minute ( gpm) each, to extract river under flow at a maximum extraction rate of 5 cubic feet per second (“ cfs”), with a maximum diversion of 1,980 acre feet per year (“ AFY”) and to add 8,500 feet to the City’s existing reach of diversion, downstream of the Alisal Bridge. The City is proposing modifications to the Approved Project, specifically with respect to the river wells portions of the project. While still within the areas analyzed under the Certified FEIR, the proposed modifications include significantly limiting the City’ s proposed river well production to its historical maximum annual diversion of 1,368 AFY, limit its production rate to a maximum of 2.84 cfs, installing no more than two new river wells, locating any new wells 3,500 or more feet downstream of the Alisal Bridge, and to ultimately reduce its reach of diversion and shift it downstream ( hereinafter referred to as the “ Revised Project”). Other aspects of the 2011 Master Plan Update are not addressed under this Addendum and are not part of the Revised Project. This Addendum serves as the California Environmental Quality Act (“ CEQA”) documentation for the Revised Project and is required to address the possible environmental effects associated with the Revised Project in comparison to the effects associated with the Approved Project that was analyzed in the Certified FEIR. The City, as lead agency, will consider this Addendum and the Certified FEIR prior to making a decision on the Revised Project.

1.1 ADDENDUM APPLICABILITY
The California Environmental Quality Act (CEQA) and the State CEQA Guidelines define standards and the procedure for additional environmental review. Sections 15162–15164 of the State CEQA Guidelines define the standards for determining the level of additional environmental review required when an EIR has been certified for a project.

Under Section 15164 of the CEQA Guidelines, 1 an addendum to a previously Certified FEIR shall be prepared if a lead agency must make a discretionary decisions regarding some changes or additions to a project analyzed under a previously Certified FEIR are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR are present. Under Public Resources Code 1 California Environmental Quality Act (CEQA), Guidelines, Section 15164, Addendum to an EIR or Negative Declaration. 303
PRC”) Section 21166 and CEQA Guidelines Section 15162, when an EIR has been certified or a negative declaration adopted for a project, no subsequent or supplemental EIR or negative declaration shall be prepared for the project unless the lead agency determines that one or more of the following conditions are met:

1. Substantial changes are proposed in the project which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;

2. Substantial changes would occur with respect to the circumstances under which the project is undertaken that require major revisions to the previous EIR or negative declaration due to the involvement of new significant environmental effects, or a substantial increase in the severity of previously identified significant effects; or

3. 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 EIR was certified as complete or the negative declaration was adopted, shows any of the following:
a. The project will have one or more significant effects not disclosed in the previous EIR or negative declaration.
b. Significant effects previously examined will be substantially more severe than identified in the previous EIR.
c. 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. 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 measure or alternative.

Pursuant to CEQA Guidelines Section 15164, a lead agency shall prepare an addendum to a Certified FEIR when some changes are additions are necessary but none of the above conditions described in CEQA Guidelines Section 15162 have occurred. An addendum need not be circulated for public review but can be included in or attached to the Certified FEIR and is considered by the lead agency in making a decision about the project.

When reviewing this Addendum, the question before the City is not whether the Certified FEIR complies with CEQA, but only whether one of the events triggering the need for a subsequent EIR has occurred. (A Local & Regional Monitor v. City of Los Angeles (1993) 12 Cal.App.4th 1773; Committee for Green Foothills v. Santa Clara County Board of Supervisors ( 2010) 48 Cal.4th 32.). 304
Based on the analysis herein, the City has determined that an addendum to the Certified FEIR is the appropriate environmental documentation pursuant to CEQA because none of the conditions in Guidelines Section 15162 have occurred. 2
This addendum provides an update to the environmental information in the Certified FEIR, analysis of the impacts of the Revised Project and presents a comparison of the environmental impacts of this proposal with the impacts identified in the Certified FEIR. In addition, it provides information for each environmental topic addressed in the original EIR as follows:

A summary of impacts identified in the Certified FEIR is provided for the Approved Project and any mitigation measures identified.

A description of the changes resulting from Revised Project relative to each environmental topic area, Where applicable, discussion of the City’ s Water Right Permit as well as other new City, State, or local plans and regulations and
A discussion of the potential impacts of the Revised Project under the current Appendix G criteria.

Revisions or updates to mitigation measures identified in the Certified FEIR and applicable, subsequent addendums, as needed, to reflect the Revised Project.

For each topical area discussion, this Addendum identifies whether there ( i) are substantial changes requiring major revisions to the EIR due to new significant impacts or a substantial increase in the severity of a previously identified impact, (ii) are substantial changes in circumstances requiring major revisions to the EIR due to new significant impacts or a substantial increase in the severity of a previously identified impact, ( iii) is new information of substantial importance showing new or substantially more severe significant effects, (iv) is new information of substantial importance showing the ability to substantially reduce significant impacts identified in the Certified FEIR, or ( v) there is no impact, no changes or circumstances requiring major revisions due to new or substantially more severe significant impacts, or no new information of substantial importance that would require preparation of an EIR. The City will consider the Addendum with the Certified FEIR prior to making a decision on the Revised Project.

1.2 BACKGROUND

1.2.1 Summary of Approved Project
The City completed the 2011 Master Plan Update in April 2011 that provided details on the existing City water system and proposed future upgrades and new facilities to provide water to the current and future residents and businesses of the City.

One major component of the 2011 Master Plan Update is the installation of new Santa Ynez River underflow wells to give the City increased pumping capacity to extract Santa Ynez River underflow under 2 CEQA Guidelines, Section 15164, Addendum to an EIR or Negative Declaration 305
Water Right Permit No. 15878. The newly installed wells was intended to be a primary water source for the City. The other major recommendation The 2011 Master Plan Update also planned to utilize the river wells in conjunction with the wide range of other water supplies available to the City to provide a highly reliable source to the water users within the City’s municipal coverage area during all water year types.

The 2011 Master Plan Update also planned for the construction of a water treatment plant.

Under the 2011 Master Plan Update, the City had proposed to install up to six ( 6) new wells, with a capacity of about 300 gallons per minute (gpm) each, and install filtration facilities so that the City will be able to meet potable water standards even when some wells are under the influence of surface water.

This would allow the City to achieve the maximum extraction rate of 5 cfs (or 2,250 gpm). The City also planned a maximum diversion of 1,980 acre feet per year (AFY). The City and planned to add an additional 8,500 feet to the Existing Reach of Diversion, downstream of the Alisal Bridge created reach of diversion of a total of approximately 19,500 feet. The new wells were proposed to be located in two areas, Well Site A and Well Site B. The proposed well sites located downstream of Alisal Bridge are designated Well Sites A and Well Sites are outside and above the ordinary high water mark of the active river channel.

Historical topographic maps indicates a currently operational gravel pit is located within the parameters of the possible location of Well Site B; the sand and gravel pit was in operation as early as 1942. Additional details of the Approved Project are provided below in comparison to the Revised Project.

1.2.2 Certified FEIR
The Certified FEIR was prepared for the Approved Project was prepared June 2012 and certified February 2014. The FEIR addressed the potential environmental effects of the Approved Project and studied the environmental issues determined to be potentially significant based on the Initial Study and responses to the Notice of Preparation ( NOP) that was circulated for a 30-day agency and public review period between January 4, 2011 and February 2, 2011.

The Certified FEIR focused on those environmental impact categories identified by the City as having potentially significant impacts during the notice of preparation, and public review period for the initial study. Environmental factors listed by the level of significance of their impacts, both project-specific and cumulative from the Certified FEIR are presented in Table 1.0-1: Significance of Environmental Issues from the Certified FEIR as determined in the initial study and analyzed in the Certified FEIR. The following issues were screened out of the Certified FEIR based on the initial study (See Appendix 1.0 of the Certified FEIR): Agricultural Resources, Geology and Soils, Mineral Resources, Population and Housing, Public Services, and Transportation and Traffic. As discussed further below, the components of the Revised Project would occur within the analyzed footprint of the Approved Project and, therefore, these issues were also screened out of this Addendum.
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Table 1.0-1
Significance of Environmental Issues for the Approved Project Significant and Unavoidable
Impacts ( Class 1)
Less than Significant Impacts with
Mitigation ( Class II)
Less than Significant Impacts
Class III)
None Hydrology, Water Supply, and
Water Quality Agricultural Resources
Terrestrial Biological Resources Energy
Fisheries Resources Geology and Soils
Cultural Resources Greenhouse Gas
Air Quality Hazards/ Hazardous Materials
Recreation Land Use
Noise Mineral Resources
Aesthetics Population and Housing
Public Services
Transportation and Traffic
Utilities/ Service Systems
Water
Wastewater
Solid Waste
Notes:

See Table ES- 1 in the Executive Summary of the Certified FEIR.

The following issues were not screened out and were addressed in detail in the Certified FEIR Hydrology, Water Supply, and Water Quality
Terrestrial Biological Resources
Fisheries Resources
Cultural Resources
Air Quality
Greenhouse Gas
Land Use
Recreation
Noise
Hazards and Hazardous Materials
Aesthetics
Energy
Utilities/ Services Systems.
307
The Certified FEIR determined the Approved Project would result in either no impact, a less than significant impact, or a less than significant impact with mitigation incorporated. The Certified FEIR’ s findings on these issues, including any applicable mitigation, are discussed in greater detail in each issue area below. The Certified FEIR utilized a “ Class” system to category impacts in the FEIR and this was their preferred way to categorize impact. Class I – Significant, Class II – Less than Significant with mitigation, Class III – less than significant, and Class IV – No Impact. This Addendum analyzes the Revised Project’ s potential impacts on these issues.

At the time of the Certified FEIR, Tribal Cultural Resources and Wildfire were not included in the CEQA Guidelines Appendix G Checklist and, therefore, analysis was not required. Although the Certified FEIR did not specifically respond to Tribal Cultural Resources Appendix G Checklist Questions, the Certified FEIR did discuss cultural resources and potential impacts to Native American tribes and resources. Thus, Certified FEIR contained enough information about existing conditions and tribal cultural resources on the Approved Project site that with the exercise of reasonable diligence, information about the potential effect of the Approved Project to tribal cultural resources was readily available to the public. The Revised Project’ s potential impacts to Tribal Cultural Resources are addressed in this Addendum in Section 3.14.

The initial study checklist for the Approved Project stated no impact would occur regarding exposure of people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands and it was screened out of the Certified FEIR. As the components of the Revised Project would occur within the analyzed footprint of the Approved Project, Wildfire was also screened out of this Addendum.

Since the Certified FEIR, Checklist Questions for Air Quality, Hydrology and Water Quality, and Noise have been updated in the CEQA Guidelines Appendix G Checklist. To determine whether the Revised Project would result in new impacts or an increase in the severity of previously identified impacts as analyzed by the Certified FEIR, provided in this Addendum is an update to the environmental information and analysis of the impacts of the Revised Project using the Checklist Questions from the current CEQA Guidelines Appendix G Checklist.

1.2.3 Water Right Permit No. 15878
The City’ s right to beneficially utilize water within the Santa Ynez River is permitted under Water Right Permit No. 15878 issued by the State Water Resources Control Board (SWRCB). Water Right Permit No. 15878 was issued in 19693 and allowed for the appropriation by direct diversion of Santa Ynez River underflow at a rate up to 5 cfs with a maximum annual diversion of 3,620 acre-feet each year. Under the Permit, the SWCRB may, after inspection, reduce the maximum amount of diversion the amount of diverted Santa Ynez River water put to the amount put to beneficial use. The City originally had until December 1, 1974 to demonstrate the application of water put to beneficial use. Since the initial issuance of the City’s Permit, the City has been granted various amendments to change the places of diversion and 3 The Permit was initially issued to the Solvang Municipal Improvement District and assigned to the City in 1986. 308
types of beneficial use, as well as obtaining extensions of time to complete its application of water to beneficial use. The most recently approved petition was granted in 1981 subject to the Diversion Agreement with Santa Ynez River Water Conservation District, Improvement District No. 1 (ID No. 1) and changed the diversion area. The City’ s Water Right Permit No. 15878 at the time of the Certified FEIR specified a reach of the river where diversions were allowed (the "Existing Reach of Diversion") and the additional reaches of diversion proposed with the Approved Project, as shown on Figure 1.0-1.

At the time of the 2011 Mater Plan Update the City had not put all the water available under Permit No. 15878 to beneficial use. To implement the river wells portion of the 2011 Master Plan Update to the City decided to pursue changes to its current water permit from the SWRCB to demonstrate additional diversion capacity and benefit use of additional Santa Ynez River Water. The City’s proposed changes to Water Right Permit No. 15878 would request the annual amount of water the City required at full buildout, the maximum rate of production permitted, and a new reach of diversion from the Santa Ynez River via groundwater withdrawal of the Santa Ynez River underflow.

At the time of the Certified FEIR the City proposed a change to its Existing Reach of Diversion by adding new wells approximately 1.5 miles downstream of Alisal Bridge and the downstream boundary of the Existing Reach of Diversion ( the " Additional Reach of Diversion") ( see Figure 1.0-1). When the Existing Reach of Diversion and the Additional Reach of Diversion are combined, they comprised the "Expanded Reach of Diversion" which is intended to provide the City the ability to locate future groundwater wells away from other permitted water rights diverters and critical habitat areas to minimize adverse impacts on the other diverters in the river, the riparian environment, and the fish, including steelhead.

1.2.4 Current Water Right Permit Status
In May 2015, the City submitted a Petition for Change and a Petition for Extension of Time to the SWRCB to amend its permit and request additional time to establish beneficial use of additional water under its permit. At that time, the City proposed to amend its Water Right Permit to withdraw a maximum of 1,980 acre-feet per year (AFY) and divert up to 5 cfs of river underflow, construct six (6) new river wells, and construct a new water treatment plant.

Currently, the City is no longer seeking a time extension and has revised the changes requested under its Petition for Change to reflect the Revised Project, which is described in greater detail below. The City’s Petition for Change is currently pending before the State Water Resources Control Board Administrative Hearing Officer. As discussed in further detail in Section 2.0, below, the Revised Project would reduce the Final Reach of Diversion to approximately 8,060 feet of total linear feet located entirely downstream of the Alisal Bridge and abandon 10,000 upstream feet of the Existing Reach of Diversion (Proposed Revised Amendment Reach of Diversion) as shown on Figure 1.0-2: Revised Proposed Reach of Diversion Map.

The locations of the existing City river wells and the proposed wells as part of the Revised Project are shown in Figure 1.0-3: Existing Wells and Proposed Well Site Areas. 309
Eastern Limit of
Solvang wells per 1975
agreement with ID# 1
Eastern Limit of
Solvang wells per 1975
agreement with ID# 1
Easement
with ID# 1’ s

6. 0 cfs well field
Easement
with ID# 1’ s

6. 0 cfs well field
Authorized Diversion Reach
Existing Reachof Diversion
Proposed
Diversion Reach
Approximately 1. 5 miles downstream)
Additional Reach
of Diversion
Approximately 1. 5 miles downstream)
City LimitCity Limit
Existing and Additional Diversion Reaches
at the Time of the Certified FEIR
1SOURCE: FIGURE 1.0-
City of Solvang Water System Master Plan Update EIR - May 2012 001-001-12

APPROXIMATE SCALE IN FEET
550027500 11000
N
310
FIGURE 1.0-
2 SOURCE: City of Solvang, River Wells Project Site Plan V6 jgg - 2021 Revised Proposed Reach of Diversion Map
001-005-19
N
311

SITE A SITE A

SITE BSITEB
33 7A7A[
5] 5] Inactive[Inactive
7] 7] Abandoned[ Abandoned
Legend
Existing City Well
Destroyed or Damaged City Well
Alisal Golf Course Well
Site Boundary
FIGURE 1.0-3
SOURCE: City of Solvang - 2021
Existing Wells and Proposed Well Site Areas
001- 001- 12

APPROXIMATE SCALE IN FEET
8004000 1600
N
312

2.0 PROJECT DESCRIPTION

2.1 REVISED PROJECT LOCATION
The well sites for the Approved Project that were evaluated under the Certified FEIR are located downstream of Alisal Bridge within designated Well Sites A and B, as shown in Figure 1.0-3. These well site areas, while within the 100-year floodplain, are outside and above the ordinary high water mark of the active river channel. Each of the new wellheads proposed under the Approved Project were to be placed at an elevation that is still within the 100-year floodplain. The well sites under the Approved Project were to be a minimum of approximately 150 feet from any surface water flows, in accordance with California Division of Drinking Water ( DDW) requirements for extraction without additional monitoring and filtration treatment. As shown in Figure 1.0-3, two locations were proposed for future wells (Wells Sites A and B) under the Approved Project; these locations were selected as a result of additional technical studies completed by Stetson Engineers. 1 Depending on the City’s ability to obtain access agreements, Well Site B would be utilized for the installation of the new wells 3,500 feet or more downstream of Alisal Bridge under the Revised Project. The City would be required to acquire additional easements along the Santa Ynez River for the new wells and associated water lines from owners downstream of Alisal Bridge.

Under the Revised Project, the City is proposing to reduce the number of new wells considered in the Approved Project from six (6) to two (2) new river wells. As shown in Figure 2.0-1: Revised Project Site Plan, the new wells would be within Well Site B and at least 150 feet from the high water mark of the Santa Ynez River in accordance with DDW requirements. The proposed well sites located downstream of Alisal Bridge are designated Well Sites A and Well Sites are outside and above the ordinary high water mark of the active river channel. Historical topographic maps indicates a currently operational gravel pit is located within the parameters of the possible location of Well Site B; the sand and gravel pit was in operation as early as 1942. Thus, the new wells would be within the area previously identified and analyzed in the Certified FEIR. No new wells are proposed in Well Site A under the Revised Project. Well Site A is located within the City’ s jurisdiction while Well Site B is located in unincorporated Santa Barbara County. The well locations under the Revised Project would be a minimum of 1,000 feet apart.

As previously discussed, the City’s Existing Reach of Diversion extends from the Alisal Bridge upstream approximately 11,000 feet. The Additional Reach of Diversion proposed under the Approved Project would add 8,500 feet to that the Existing Reach of Diversion, downstream of the Alisal Bridge for a total reach of diversion of approximately 19,500 feet. Under the Revised Project, the City is proposing to greatly 1 Stetson Engineers, Inc., Technical Memorandum No. 6, Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge, January 24, 2011 (Certified FEIR Appendix 5.1).
313
reduce the reach of diversion that is upstream of Alisal Bridge. In addition to the two (2) new wells, the City is proposing to reduce the Final Reach of Diversion to approximately 8,060 feet of total linear feet located entirely downstream of the Alisal Bridge and abandon 10,000 upstream feet of the Existing Reach of Diversion (Proposed Revised Amendment Reach of Diversion) as shown in Figure 2.0-2: Revised Project and Reach of Diversion. However, in the interim, the City will continue to divert water from its existing well 7A above the Alisal Bridge until it and the existing reach of diversion upstream of the Alisal Bridge are abandoned.

Supporting well infrastructure would also be constructed as part of the Revised Project that would connect the new wells to the City’ s existing water distribution system. The Certified FEIR stated the water lines for Well Site B would consist of connector pipes, a transmission pipe, and looping pipes, with a total pipe length of approximately 1.7 miles. The transmission pipe would range in diameter from 10- to 18- inches; with the size of the pipe segment dependent on the water flow. The Certified FEIR considered construction of pipeline infrastructure would occur in both Well Sites A and B and extend between both Well Sites to the proposed connection point with the City’ s existing water distribution system. The new wells proposed under the Revised Project would connect to a new 12-inch diameter waterline to be constructed from the new wells approximately 2,000 feet length to the City’ s existing water distribution system at the western end of Fjord Drive. The proposed width of the pipeline easement area and associated buffer is 40 feet wide in total (a 20-foot easement with a 10 foot buffer on both sides). The well infrastructure contemplated under the Revised Project is within the area evaluated in the Certified FEIR.
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2 4
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AlisalRdMissionDrFjor
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Fifth StFirst
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FIGURE 2.0-
1 SOURCE: City
of Solvang, River Wells
Project Site
Plan V6
jgg - 2021
Revised
Project
Site
FIGURE 2.0-2
SOURCE: City of Solvang, River Wells Project Site Plan V6 jgg - 2021 Revised Project and Reach of Diversion
001-005-19
SITE A
SITE B

PROPOSED WELL
AREA
MAX 2 NEW WELLS IN SITE B)
MINIMUM WELLSPACING OF 1,000'
NOTE: NEW WELL LOCATIONSSHOWN ABOVE ARE APPROXIMATE.

ALL NEW WELLS TO BE MINIMUM150 FT FROM BANK OF WETTEDLOW FLOW CHANNEL.

SITE B
316

2.2 REVISED PROJECT
Under the Revised Project the City’ s is proposing to significantly limit its proposed river well production to 1,368 AFY, limit its production rate to a maximum of 2.84 cfs, install no more than two new river wells, locate any new wells 3,500 or more feet downstream of the Alisal Bridge, and, as described above, to ultimately reduce its reach of diversion and shift it downstream.

The projected monthly water production from the City’ s existing two wells and the two new wells proposed under the Revised Project would range from 40 to 160 acre-feet per month under the Revised Project. The City currently operates Well 3 and Well 7A. Under the Revised Project City is also electing to cease production from Well 3 and Well 7A if flows at the Alisal Bridge ( as monitored by the USGS flow gage) drop below 1.5 cfs or if subsurface water flows drop below 360.3 as measured at the Alisal Ranch Well (under static conditions). Further, the City will not increase the existing production capacity of Well 7A and Well 3 above 200 gpm and 350 gpm, respectively. The City will also abandon its Well 7A and its existing reach of diversion upstream of the Alisal Bridge once the combined production capacity of Well 3 and any new downstream wells is at least 950 gpm or Solvang constructs two new wells in Site B. The City maintains an easement for Well 5 (that was destroyed) but does not intend to reconstruct this well or use this well site. The new wells proposed under the Revised Project would connect to a new 12-inch diameter waterline to be constructed from the new wells approximately 2,000 feet length to the City’ s existing water distribution system at the western end of Fjord Drive. The proposed width of the pipeline easement area and associated buffer is 40 feet wide in total (a 20-foot easement with a 10 foot buffer on both sides). Further, the previously planned water treatment plant identified in the 2011 Master Plan Update is no longer proposed in the Revised Project.

Based on the Water Master Plan Update and Integrated Water Supply Management Plan, 2 the City’s anticipated future water supply by source has been updated and is shown in Table 2.0-1: Total Water Production Current and Future Supply by Source. As demonstrated below, the long-term average production from the Revised Project wells is anticipated to be 650 AFY. However, the City is requesting a production level of 1,368 AFY because the City’ s need for water from the wells under the Revised Project will vary from year to year depending on availability from other water supply sources and climactic conditions. The requested production level of 1,368 AFY will accommodate these fluctuations and ensure the City has sufficient water supply for existing and future uses. 2 City of Solvang, Integrated Water Supply Management Plan, October 2018. 317
Table 2.0-1
Total Water Production Current and Future Supply by Source Supply Source
Annual
Capacity/ Production
AF)
Anticipated Long-Term
Average Production
AFY)
Local Sources
Revised Project Wells a 300 650
Upland Wells 510 510
Local Subtotal 810 1,160
External Sources
Improvement District No. 1
b 40 46
State Water Project Allocation 600 600
Suspended Table A State Water 0 174
External Subtotal 640 820
Total All Supply Sources 1,450 1,980
Notes:
a Higher production is expected from this source in certain years, while in other years production will be limited based on climatic conditions.
b Higher amounts could be obtained from this source. However, use is minimized due to the high cost of this source.

The City of Solvang has compiled records of diversion from their River Wells for the historic period of 2000 through 2020 on a monthly basis. The City has provided estimates of the monthly diversion from each of the City’s existing and the Revised Project wells. The annual operations in both AF and cfs by month for City wells without and with the Revised Project are presented in Table 2.0-2: Annual Operations Plan for City Wells without Revised Project Wells and Table 2.0-3: Annual Operations Plan for City Wells with Revised Project Wells and includes the details about the City’s planned operational scheduling of each of their wells on a monthly basis in response to system demands, planned maintenance, anticipated State Water Project availability in a given month, and total annual flow volume limitations. As indicated in Table

2.0-2, the existing City wells 7A and 3 would not accommodate the fluctuations in water supply from other sources and climactic conditions or provide sufficient water supply for existing and future uses without the Revised Project. With 1,368 AFY of diversion, the City would be able to provide sufficient water supply for existing and future uses with the annual operations of Well 3 and the two new wells proposed under the Revised Project as shown in Table 2.0-3.
318
Table 2.0-2
Annual Operations Plan for City Wells without Revised Project Wells Month
Maximum
Monthly
Diversion
Amount –
Well 7A
AF) a
Maximum
Monthly
Diversion
Amount
Well 3 (AF)
b, c
Maximum
Monthly
Diversion
Amount –
Proposed
Wells
AF)
Maximum
Monthly
Diversion
Amount –
Total (AF)
Maximum
Monthly
Diversion
Rate – Well
7A (cfs) d
Maximum
Monthly
Diversion
Rate – Well
3 (cfs) d
Maximum
Monthly
Diversion
Rate –
Proposed
Wells ( cfs)
Maximum
Monthly
Diversion
Rate –
Total ( cfs)
January 14 24 0 38 0.45 0.78 0 1.23
February 12 22 0 34 0.45 0.78 0 1.23
March 14 24 0 38 0.45 0.78 0 1.23
April 13 15 0 28 0.45 0.78 0 1.23
May 14 16 0 30 0.45 0.78 0 1.23
June 13 23 0 36 0.45 0.78 0 1.23
July 14 24 0 38 0.45 0.78 0 1.23
August 14 24 0 38 0.45 0.78 0 1.23
September 13 23 0 36 0.45 0.78 0 1.23
October 14 24 0 38 0.45 0.78 0 1.23
November 13 23 0 36 0.45 0.78 0 1.23
December 14 24 0 38 0.45 0.78 0 1.23
Total Diversion
Amount ( AFY) 162 266 0 428
Notes:
a Assumes Well 7A is unable to pump 25% of the time due to the PDA restrictions and mechanical problems, and operates an average of 16 hours/ day. b Assumes Well 3 is unable to pump 25% of the time due to the PDA restrictions and mechanical problems, and operates an average of 16 hours/ day. c Well 3 operation is governed by the Solvang- ID1-Alisal Protest Dismissal Agreement ( PDA). d Well 7A capacity = 0.45 CFS = 200 gpm; and Well 3 capacity = 0.78 CFS = 350 gpm. 319
Table 2.0-3
Annual Operations Plan for City Wells with Revised Project Wells Month
Maximum
Monthly
Diversion
Amount –
Well 7A
AF) a, b
Maximum
Monthly
Diversion
Amount
Well 3
AF) c, d
Maximum
Monthly
Diversion
Amount –
Proposed
Wells
AF) d
Maximum
Monthly
Diversion
Amount –
Total
AF)
Maximum
Monthly
Diversion
Rate –
Well 7A
cfs) a
Maximum
Monthly
Diversion
Rate –
Well 3
cfs) e
Maximum
Monthly
Diversion
Rate –
Proposed
Wells
cfs)
Maximum
Monthly
Diversion
Rate –
Total
cfs)
January 0 24 94 118 0 0.78 2.05 2.83
February 0 22 85 107 0 0.78 2.05 2.83
March 0 24 94 118 0 0.78 2.05 2.83
April 0 15 91 106 0 0.78 2.05 2.83
May 0 16 94 110 0 0.78 2.05 2.83
June 0 23 91 114 0 0.78 2.05 2.83
July 0 24 94 118 0 0.78 2.05 2.83
August 0 24 94 118 0 0.78 2.05 2.83
September 0 23 91 114 0 0.78 2.05 2.83
October 0 24 94 118 0 0.78 2.05 2.83
November 0 23 91 114 0 0.78 2.05 2.83
December 0 24 94 118 0 0.78 2.05 2.83
Total Diversion
Amount (AFY) 0 266 1,107 1,373
Notes:
a Well 7A capacity = 0.45 CFS = 200 gpm; and Well 3 capacity = 0.78 CFS = 350 gpm. b Well 3 operation is governed by the Solvang- ID1-Alisal Protest Dismissal Agreement ( PDA). c Assumes Site B Wells are unable to pump 10% of the time due to mechanical problems, and operate an average of 20 hours/ day. d Pumping hours will be reduced during some months to stay within the 1,368 AFY limit. e Estimated Site B two-well capacity = 920 gpm = 2.05 CFS.

Table 2.0-4: Comparison of Certified FEIR Project and Revised Project, compares the difference between the components which were previously analyzed in the Certified FEIR and the components identified under the Revised Project. As indicated in Table 2.0-4, the project components of the Revised Project would occur within the analyzed footprint of the Approved Project. 320
Table 2.0-4
Comparison of Approved Project and Revised Project
Project Components Approved Project Revised Project
Revised Project within
Approved Project’ s
Project Footprint?
Number of Existing Wells 2 1* Yes
Number of Proposed Wells 6 2 Yes
Total Number of Wells 8 3 Yes
Maximum Diversion ( AFY) 1,980 1,368 Yes
Max Diversion Rate (cfs) 5.00 2.84 Yes
Reach of Diversion ( Feet) 19,500 8,060 Yes
Wells in Site A Yes No Yes
Pumping Wells 3 & 7A during River Flows

1.5 cfs Yes No Yes
Proposed Wells located away from
identified steelhead flow target
areas in current Biological
Opinion and State Board
Order 2019-0148
No Yes Yes
Notes:

Once the combined production capacity of Well 3 and any new downstream wells is at least 950 gpm or upon completion of proposed wells.

2.3 REVISED PROJECT OBJECTIVES
The primary objectives of this Revised Project remain the same as objectives of the City of Solvang’ s 2011 Water Master Plan Update and Certified FEIR as follows:

Ensure a future reliable water supply to meet the projected water demand at City build out as provided for in the General Plan.

Provide for a reliable and diversified water supply through the use of multiple sources of supply.

Secure adequate water rights to reliably meet the City’s water supply requirements.

Provide the needed water supply at a reasonable cost.

Avoid impacts either to public trust resources or to other water rights holders.

2.4 REVISED PROJECT CONSTRUCTION
Due to the need to acquire easements for the new wells, construction of the new wells and pipeline infrastructure is anticipated to commence fall 2025 or later contingent upon successful easement 321
acquisition. Construction would be sequential with well drilling to be completed in four ( 4) months, wellhead improvements to be completed in 12 months, and pipeline infrastructure to be completed in four (4) months. No soil export would occur. Soil import of approximately 400 cubic yards (CY) may occur is estimated for the new wells. Excavation during construction of about 75 CY for each well would occur for the drilling pit for the drilling fluid is estimated, a total of 150 CY would occur.

The wells would be equipped with heavy duty electrical receptacles to allow the City’ s trailer-mounted 50-kilowatt ( kW) generator to be parked and plugged into a new well in the event of a power outage emergency. The proposed well design is unchanged from that presented in the Certified FEIR. The maximum well depth will be approximately 65 feet.

2.5 REVISED PROJECT CUMULATIVE SCENARIO
The Certified FEIR analyzed all cumulative impacts, separating the application for impacts for cumulative consideration into two categories: non-flow related impacts and flow-related impacts.

2.5.1 Non-Flow Related Cumulative Analysis
For issues that do not involve flow associated with the Santa Ynez River (such as aesthetics, land use and noise), the cumulative analysis considers the buildout of the City’s General Plan. The basis for the Master Plan Update in the Certified FEIR was to provide for water supply and treatment facilities and the rights to water supply necessary to meet the anticipated potable water demands of the City at buildout. This continues to be the basis of this Revised Project. The buildout of the City’ s General Plan has not changed since the Certified FEIR. Therefore, the cumulative analysis of the Revised Project in this Addendum considers the same buildout as the Certified FEIR Project.

2.5.2 Flow Related Cumulative Analysis
The Certified FEIR Project involved the continued diversion of subterranean flow from the Santa Ynez River within the existing and expanded reach of diversion. The Revised Project also involves the continued diversion from the Santa Ynez River, within the existing and final reach of diversion. Therefore, similar to the Certified FEIR Project, the “ cumulative context,” ( i.e., the range of project types and locations that could affect the same resources affected by the Proposed Revised) is relatively limited. To address the potential cumulative impacts, this Addendum presents a listing of existing and pending water rights and diversions within the Santa Ynez River watershed in order to frame the cumulative context for this discussion.

To evaluate cumulative impacts, the Certified FEIR and this Addendum examined existing and proposed water diversions within the Santa Ynez River from Bradbury Dam to the Highway 101 Bridge in Buellton. 322
Impacts caused by other water diversions within the stretch of the river could potentially combine with the Revised Project to create cumulative impacts. These impacts include potential effects on river hydrology, groundwater hydrology, water quality, soil erosion (due to increased application and runoff of irrigation water), and aquatic resources supported by river surface flow and subterranean flow.

At the time of the Certified FEIR, the State Water Resources Control Board ( SWRCB) had 39 permits or licenses, applications, small domestic use registrations, and statements of diversion and use (referred to herein as “ claims”) on file for the Santa Ynez River, including the Certified FEIR Project. Since that time, no new claims have been added to the SWRCB files for the Santa Ynez River. Table 2.0-5: Existing and Claimed Water Rights and Diversions along the Santa Ynez River, lists the existing water rights and pending applications within the watershed, along with the date, amount, location, type, and status of the application, claim, or registration. In addition to the list shown in Table 2.0-5, there are significant riparian water rights along the Santa Ynez River which are not included in the SWRCB database, including water rights protected by Order WR 2019-0148. These water rights were taken into account for the cumulative analysis of the Revised Project.
323
Table 2.0-5
Existing and Claimed Water Rights and Diversions
Location
Application
ID
Permit
ID
License
ID
Water Right
Type Status Holder Name Date Face Amount County Source
Bradbury Dam to
Alisal Bridge
Solvang)
S015195 Statement of
Diversion and Use
Claimed
John V. Crawford 11/ 19/ 1999 1000 acre-ft/yr Santa Barbara Santa Ynez River S020791 Statement of
Diversion and Use Claimed Palmer Gavit Jackson Trust 04/ 19/ 2011 778 acre-ft/yr Santa Barbara Santa Ynez S020793 Statement of
Diversion and Use Claimed Palmer Gavit Jackson Trust 04/ 19/ 2011 778 acre-ft/yr Santa Barbara Santa Ynez River A004007 1831 1261 Appropriative Licensed Anne V. Crawford 2/10/ 1933 1,219.90 acreft/yr Santa BarbaraSanta Ynez River
Underflow
A012601 7436 10415 Appropriative Licensed Santa Ynez River Water Conservation District, ID No. 1 7/ 21/ 1948 515 acre-ft/yr Santa Barbara Santa Ynez River A011331 11308 Appropriative Permitted U.S. Bureau of Reclamation 3/ 19/ 1958 347,397.80
acre-ft/yr Santa Barbara Santa Ynez River
A011332 11310 Appropriative Permitted U.S. Bureau of Reclamation 3/ 19/ 1958 311,198.90
acre-ft/yr Santa Barbara Santa Ynez River
A022423_ 02 15878 Appropriative Permitted City of Solvang 03/ 15/ 1966 3600 acre-ft/yr Santa Barbara Santa Ynez River
Underflow
A024578_ 01 17733 Appropriative Permitted Santa Ynez River Water Conservation District, ID No. 1 03/ 22/ 1974 2220 acre-ft/yr Santa Barbara Santa Ynez River
Underflow
A024579_ 01 17734 Appropriative Permitted Santa Ynez River Water Conservation District, ID No. 1 02/ 28/ 2001 3400 acre-ft/yr Santa Barbara Santa Ynez River
Underflow
Alisal Bridge to
101 Bridge
Buellton)
S020792 Statement of
Diversion and Use
Claimed Palmer Gavit Jackson Trust
U/A 2/ 25/ 88 04/ 19/ 2011 778 acre-ft/yr Santa Barbara Santa Ynez S020794 Statement of
Diversion and Use Claimed Palmer Gavit Jackson TrustU/A 2/ 25/ 88 04/ 19/ 2011 778 acre-ft/yr Santa Barbara Santa Ynez River 101 Bridge to
Pacific Ocean S015121 Statement ofDiversion and Use Claimed Mary Jane M. Edalatpour 11/ 02/ 1999 76 acre-ft/yr Santa Barbara Santa Ynez River 324
Location
Application
ID
Permit
ID
License
ID
Water Right
Type Status Holder Name Date Face Amount County Source
S015229 Statement of
Diversion and Use Claimed Alan H. Mercer 06/ 07/ 2000 50 acre-ft/yr Santa Barbara Santa Ynez River S016616 Statement of
Diversion and Use Claimed Georgia S. Gammie WeisterTrust 06/ 07/ 2010 1 acre-ft/yr Santa Barbara Santa Ynez River S016934 Statement of
Diversion and Use Claimed Mary Jane M. Edalatpour 06/ 08/ 2010 3 acre-ft/yr Santa Barbara Santa Ynez River S016935 Statement of
Diversion and Use Claimed Mary Jane M. Edalatpour 06/ 08/ 2010 118 acre-ft/yr Santa Barbara Santa Ynez River S016948 Statement of
Diversion and Use Claimed Allison Gammie Hill, et. al. 06/ 15/ 2010 1 acre-ft/yr Santa Barbara Santa Ynez River S016951 Statement of
Diversion and Use Claimed John S. Hill 06/ 15/ 2010 8.6 acre-ft/yr Santa Barbara Santa Ynez River S017091 Statement of
Diversion and Use Claimed Miller Merritt Trust 07/ 01/ 2010 11 acre-ft/yr Santa Barbara Santa Ynez River S017100 Statement of
Diversion and Use Claimed Miller Merritt Trust 7/1/ 2010 7.5 acre-ft/yr Santa Barbara Santa Ynez River S017124 Statement of
Diversion and Use Claimed Miller Merritt Trust 07/ 01/ 2010 162 acre-ft/yr Santa Barbara Santa Ynez River S017145 Statement of
Diversion and Use Claimed Bruce A. Steele 07/ 01/ 2010 59 acre-ft/yr Santa Barbara Santa Ynez River S017151 Statement of
Diversion and Use Claimed Bruce A. Steele 07/ 01/ 2010 0 acre-ft/yr Santa Barbara Santa Ynez River S020795 Statement of
Diversion and Use Claimed Palmer Gavit Jackson Trust 04/ 19/ 2011 701 acre-ft/yr Santa Barbara Santa Ynez River A002394A 1276 001313A Appropriative Licensed N Edalatpour 06/ 17/ 1921 53 acre-ft/yr Santa Barbara Santa Ynez River A002394B 1276 001313B Appropriative Licensed Gene Shaw 1/ 23/ 1969 50 acre-ft/yr Santa Barbara Santa Ynez River A003927A 000932A Appropriative Licensed Michael P. O’Brien 05/ 03/ 2002 146 acre-ft/yr Santa Barbara Santa Ynez River
Underflow
A003927B 000932B Appropriative Licensed John M. Sundheim 05/ 03/ 2002 36 acre-ft/yr Santa Barbara Santa Ynez River
Underflow
A022423_ 01 15878 Appropriative Permitted City of Solvang 03/ 15/ 1966 3600 acre-ft/yr Santa Barbara Santa Ynez River
Underflow
325
Location
Application
ID
Permit
ID
License
ID
Water Right
Type Status Holder Name Date Face Amount County Source
A022516_ 01 15879 Appropriative Permitted City of Buellton 07/ 01/ 1966 1385 acre-ft/yr Santa Barbara Santa Ynez River
Underflow
A023960_ 01 17447 Appropriative Permitted Santa Ynez River Water Conservation District 01/ 06/ 1972 40000 acre-ft/yr Santa Barbara Santa Ynez River Additional Statements Listed in SWRCB Cachuma Water Rights 2011 2nd Revised Draft EIR but not in eWRIMS Claimed Gildred Trust 27.12 acre-ft/yr Santa Barbara
Santa Ynez River
Alluvial Basin
Claimed Petersen Family Properties, 10.9 acre-ft/yr Santa Barbara Santa Ynez River
Alluvial Basin
Claimed Petersen Family Properties 0.01 acre-ft/yr Santa Barbara Santa Ynez River
Alluvial Basin
Claimed Petersen Family Properties 0.80 acre-ft/yr Santa Barbara Santa Ynez River
Alluvial Basin
Claimed Petersen Family Properties 10.80 acre-ft/yr Santa Barbara Santa Ynez River
Alluvial Basin
S0004237 Claimed Pitts

2.12 cfs from
Mar 1 to Oct 31 Santa Barbara
Santa Ynez River
Alluvial Basin
Claimed Slavik Trust 14.0 acre-ft/yr Santa Barbara
Santa Ynez River
Alluvial Basin
Source: State Water Resources Control Board (SWRCB), eWRIMS database. https:// waterrightsmaps. waterboards. ca.gov/ viewer/ index.html?viewer=eWRIMS. eWRIMS_ gvh#, Accessed November 2021. 326

3.0 IMPACT ANALYSIS
This analysis section includes separate subsections for each environmental topic addressed in the Certified FEIR.

Information for each environmental topic as it relates to the Revised Project is addressed compared to that provided in the original EIR. Each topical discussion is organized as follows:

A summary of impacts identified in the Certified FEIR is provided for the Approved Project and any mitigation measures identified.

A description of the changes resulting from Revised Project relative to each environmental topic area, Where applicable, discussion of changes in City, State, or local plans and regulations; A discussion of the potential impacts identified the Revised Project under the current Appendix G.

Revisions or updates to mitigation measures identified in the Certified FEIR and applicable, subsequent addendums, as needed, to reflect the Revised Project.

For each topical area discussion, this Addendum identifies whether there (i) are substantial changes requiring major revisions to the EIR due to new significant impacts or a substantial increase in the severity of a previously identified impact, (ii) are substantial changes in circumstances requiring major revisions to the EIR due to new significant impacts or a substantial increase in the severity of a previously identified impact, ( iii) is new information of substantial importance showing new or substantially more severe significant effects, ( iv) is new information of substantial importance showing the ability to substantially reduce significant impacts identified in the Certified FEIR, or ( v) there is no impact, no changes or circumstances requiring major revisions due to new or substantially more severe significant impacts, or no new information of substantial importance that would require preparation of an EIR.

As discussed in Section 1.2.2, above, at the time of the Certified FEIR, Tribal Cultural Resources and Wildfire were not included in the CEQA Guidelines Appendix G Checklist and, therefore, analysis was not required. Although the Certified FEIR did not specifically respond to Tribal Cultural Resources Appendix G Checklist Questions, the Certified FEIR did discuss cultural resources and potential impacts to Native American tribes and resources. Thus, Certified FEIR contained enough information about existing conditions and tribal cultural resources on the Approved Project site that with the exercise of reasonable diligence, information about the potential effect of the Approved Project to tribal cultural resources was readily available to the public. The Revised Project’ s potential impacts to Tribal Cultural Resources are addressed in this Addendum in Section 3.14. The initial study checklist for the Approved Project stated no impact would occur regarding exposure of people or structures to a significant risk of loss, injury or death 327
involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands and it was screened out of the Certified FEIR. As the Revised Project is a scaled down version of the Approved Project and components of the Revised Project would occur within the analyzed footprint of the Approved Project, wildfire was also screened out of this Addendum. All environmental issues that were not carried forward in the Certified FEIR (Agricultural Resources, Geology and Soils, Mineral Resources, Population and Housing, Public Services, Transportation and Traffic, and Mandatory Findings of Significance) were also not carried forward in this Addendum because the Revised Project is a scaled down version of the Approved Project and components of the Revised Project would occur within the analyzed footprint of the Approved Project.

Since the Certified FEIR, Checklist Questions for Hydrology and Water Quality, Biological Resources, Cultural Resources, Air Quality, Recreation, Noise, Hazards and Hazardous Materials, Energy, and Utilities and Service Systems have been updated in the CEQA Guidelines Appendix G Checklist. To determine whether the Revised Project would result in new impacts or an increase in the severity of previously identified impacts as analyzed by the Certified FEIR, provided in this Addendum is an update to the environmental information and analysis of the impacts of the Revised Project using the Checklist Questions from the current CEQA Guidelines Appendix G Checklist.

3.1 HYDROLOGY, WATER SUPPLY, AND WATER QUALITY

3.1.1 Summary of Analysis in the Certified FEIR
The analysis of hydrologic conditions, including surface water and groundwater, and water quality were completed for the Certified FEIR through a number of studies including the Preliminary Hydrogeology Study ( Hopkins Groundwater Consultants, Inc.) dated April 2003 and Stetson Engineers Inc (Stetson), Technical Memoranda Nos. 1 through 6.1 Specifically, Stetson Technical Memoranda Nos. 1 through 5 modeled all proposed river wells upstream of the Alisal Bridge. Technical Memorandum No. 6 analyzed wells downstream of the bridge. Stetson Memorandum No. 6 analyzed potential impacts to nearby wells, Cachuma Project water supply, and endangered steelhead trout ( Oncorhynchus mykiss or O. mykiss) steelhead). The Certified FEIR concluded no impacts would occur related to placing housing in 100-year flood hazard area; levee or dam failure; and risk of inundation by seiche, tsunami or mudflow Impacts related to water quality standards, existing drainage pattern, capacity of storm water drainage systems, and water quality, were determined to be less than significant, while impacts to groundwater supply and flood flows within 100-year fold hazard areas would be less than significant with implementation of MM HYD-1 through MM HYD-2, respectively.
1 See Appendix 5 of the Certified FEIR.
328

3.1.1.1 Violate Any Water Quality Standards or Waste Discharge Requirements
Construction Impacts
During construction of the Master Plan Update’ s various components, groundwater quality could potentially be impacted. Although the Project area is essentially flat and the potential for soil erosion is considered to be relatively low, peak stormwater runoff could result in short-term sheet erosion within areas of exposed or stockpiled soils. Additionally, the compaction of soils by heavy equipment may reduce the infiltration capacity of soils and increase runoff and erosion potential. Given this, the Certified FEIR stated pollutants such as soil, sediments, and other substances associated with construction activities e.g., oil, gasoline, grease, and surface litter) could directly enter the Santa Ynez River or filter into the local groundwater, during construction of the Approved Project.

The Certified FEIR Project would have disturbed an acre or more of land over the course of implementation of the Approved Project (i.e., the six wells in Well Sites A and B, water treatment plant, proposed diversion of 1,980 AFY and a diversion rate of 5 cfs and a Reach of Diversion of approximately 19,500 feet). As such, the City was required to obtain a General Permit for discharges of storm water associated with construction activity. The Certified FEIR identified the City would be required to implement a stormwater pollution prevention plan (SWPPP), according to SWRCB requirements, which would implement construction and post-construction Best Management Practices (BMPs) and monitoring plan to minimize discharge of pollutants in stormwater from the construction area and stormwater runoff and minimize the discharge of pollutants in stormwater from the construction area. In addition, the SWPPP must identify post-construction control measures and a monitoring plan. Consequently, the construction phases of the Master Plan Update would result in less than significant groundwater quality impacts. Construction activities under the Approved Project were determined to not impact the exercise of any existing water right on the river. The construction of wells and the water treatment plant would be subject to the City’s SWPPP. The SWPPP identifies construction BMPs as well as post-construction control measures and monitoring plan. The Certified FEIR concluded with implementation of the BMPs, the Certified FEIR Project would result in less than significant groundwater quality impacts (Class II).

Impacts During Operation
Operation of the components of the Certified FEIR Project would involve the extraction of Santa Ynez River underflow and distribution through the City’ s municipal water system. Water extracted from the Santa Ynez River would be pumped to the proposed water treatment plant. There the water would be treated to California Department of Public Health ( CDPH) standards for surface water treatment.

Chemicals anticipated to be utilized at the treatment plant include a coagulant, such as aluminum sulfate, 329
and liquid sodium hypochlorite for disinfection. Therefore, water diverted from the Santa Ynez River would be suitable for the City’s municipal use. The Certified FEIR determined impacts would be less than significant ( Class III).

3.1.1.2 Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted).

Construction Impacts
The Certified FEIR stated well drilling, completion, development, and testing will require about seven days at each well site. Work will likely be coordinated so that one well is being drilled while another is being developed and tested. Pump testing will occur immediately after well installation. The water lines and electrical conduits will be installed after well testing. The proposed well installation will be completed in a phased approach.

The release of the water pumped from each well and discharged to the open areas of the floodplain would include any fine-grained materials from the well. The water quality of the pumped groundwater would be similar to the flows within the river and the materials of discharge would be similar to the surrounding soil. As the well testing water is similar in nature to the surrounding environment, potential water quality impacts would be considered less than significant during well release. The Certified FEIR identified that construction related impacts of the Approved Project would not substantially reduce reservoir levels or storage to substantially impair designated beneficial uses ( Class III) and that impacts would be less than significant.

Impacts During Operation
At the time of the Certified FEIR, the City operated two wells (River Wells 3 and 7A—River Well 5 is not currently used as it was damaged in prior floods) to extract water from the Santa Ynez River, two upland wells (Wells 21 and 22 that were inactive due to water quality concerns), and one central well (Well 4) located near City Hall. The current combined pumping capacity at the time of the Certified FEIR of River Wells 3 and 7A total approximately 450 gpm, while Well 4 operates at a maximum of 320 gpm. The City's goal under the Approved Project was to have a pumping capacity of 5 cubic feet per second (cfs) from the Santa Ynez River to serve the City's peak demand. This was planned to be achieved by a combination of renovating Wells 3 and 7A, installing new wells and, potentially, renovating and equipping Well 5. New wells were planned to be on the City’s supervisory control and data acquisition ( SCADA) system and run 330
according to set points tied to reservoirs levels. System production will be dictated by demand on the system.

Water levels in the Santa Ynez River underflow in the vicinity of the City’s existing wells at the time of the Certified FEIR indicated that after extreme dry periods, water levels recover during winter runoff flows.

This response was due to resumption of Santa Ynez River flows associated with storm runoffs and resulting recharge to the river alluvium.

The operation of the Master Plan Update as contemplated in the Approved Project would have increased the diversion of Santa Ynez River underflow from 1,053 AFY at an extraction rate of 1.85 cfs, to 1,980 AFY diverted from the Santa Ynez River at up to a maximum peak extraction rate of 5 cfs.

Stetson evaluated the potential impact of combined pumping from wells at Well Site B at an annual rate of 2,400 AFY. This is considered a conservative analysis, as the Master Plan Update under the Approved Project contemplated pumping 1,980 AFY ( less than 2,400 AFY which was evaluated in Technical Memorandum No. 6). Also, Stetson’ s evaluation does not include the minimum flows (Cachuma releases) required under the Biological Opinion for the operation and maintenance of the Cachuma Project on the Santa Ynez River in Santa Barbara County, California issued by National Marine Fisheries Service ( NMFS) in 2000 (2000 BiOp) and the Lower Santa Ynez River (LSYR) Fish Management Plan (FMP) 2 for O. mykiss.

The river alluvial basins downstream of Bradbury Dam have been divided into the Above Narrows Alluvial Groundwater Basin and the Below Narrows Groundwater Basin. The Certified FEIR found the Above Narrows Riparian Aquifer was expected to recover to the same levels with the recharge of winter runoff under the baseline and Approved Project conditions; the key differences in water levels occur during dry years.

The Approved Project would have resulted in slightly more dewatered groundwater storage in the Above Narrows Riparian Aquifer ( 525 acre-feet). This would have involved a decrease in the Buellton Riparian Subbasin ( 492 acre-feet), and approximately the same groundwater storage for the Santa Ynez (11 acrefeet) and Santa Rita ( 16 acre-feet) Riparian Subbasins when compared to baseline conditions for each.

The Santa Ynez Subbasin includes Highway 154 and Alisal Bridge, which are the target sites under the 2000 BiOp for fish water releases. As indicated in Table 5.1-3 in Section 5.1: Hydrology, Water Supply, and Water Quality of the Certified FEIR, the Approved Project would increase dewatered storage space within the Above Narrows aquifer and the local riparian groundwater basins; in general, there is more total dewatered storage when the City’ s river well pumping increases. 2 Santa Ynez River Technical Advisory Committee with Technical Support by ENTRIX, Inc., Santa Ynez River Consensus Committee, Lower Santa Ynez River Fish Management Plan, October 2, 2000. 331
The Approved Project would have not changed the groundwater level elevation for the Santa Ynez Riparian Subbasin or for the Santa Rita Subbasin. The Approved Project would have resulted in an average decrease in elevation of 1 foot to the Buellton Subbasin. The Approved Project would have not decreased groundwater elevation to the groundwater basins above Alisal Bridge relative to baseline conditions.

The Certified FEIR noted that the calculated drawdown due to the proposed pumping of 2,400 AFY from the proposed Well Sites A and B at various times, distances, and directions was shown in Table 5.1-5 in Section 5.1: Hydrology, Water Supply, and Water Quality. The analysis was simulated for 24 months with no river or other inflows to the area to determine the potential drawdowns in the vicinity of the proposed wells that may occur over a summer period or during a drought with no flow in the river. The focus was on summer drawdowns because those are expected to occur when water levels in the area are at their lowest, particularly if there is no flow in the river. Calculated drawdowns toward the northern alluvial boundary ranged from a maximum of approximately 9 feet at a distance of 1,000 feet to approximately 7 feet at a distance of 3,000 feet from the proposed well fields in September. This calculation was based on no river or other inflows to the area.

The Certified FEIR noted that the calculated drawdown ranged from a maximum of approximately 6 feet at a distance of 2,000 feet to approximately 3 feet at a distance of 6,000 feet from the proposed well field in September. Again, this calculation was based on no river or other inflows to the area. It should be noted that these calculated drawdowns would be lower, near zero, within a distance of about 1,000 feet if the Santa Ynez River were flowing. The Approved Project would have resulted in lower drawdown of groundwater levels as the City would divert 1,980 AFY, 420 AFY less than the 2,400 AFY used to model potential impacts. Even the extreme case represented by the modeling indicated that the impacts would be less than significant due to the depth of the alluvium downstream of Alisal Bridge (Class III).

Analyses of the Approved Project with all of the new Santa Ynez River wells ( the Approved Project contemplated up to six [6] new wells) located downstream of Alisal Bridge indicated that development of a well field at this site would result in successful yields. The alluvial deposits are thicker and the yields are typically higher in this area compared with upstream of the Alisal Bridge. The reported performance of existing wells indicated that the aquifer would be able to meet both monthly average and peak demands of the City. Consequently, impacts to the groundwater level in the area of Alisal Bridge and upstream would be less than significant ( Class III).

The increase in the amount of pumping from the Santa Ynez River would occur primarily during the summer months. Lake Cachuma operations generally release allocations of water for water right holders during the summer and fall months. During this time, water released from Lake Cachuma percolates and replenishes the groundwater within the Above Narrows Alluvial Groundwater Basin. Precipitation during 332
winter months also replenishes groundwater levels within the Above Narrows Alluvial Groundwater Basin.

Therefore, the Approved Project would not result in the lowering of groundwater levels to cause land subsidence. Impacts would be less than significant ( Class III).

The Certified FEIR identified that an indirect environmental impact due to water supply shortages is considered significant if the Cachuma Project Member’ s make up for the shortage using a new source of water supply. Any potential indirect environmental impacts that may result from the acquisition of new sources of water supply to meet the Cachuma Project Member’ s future demand would be attributable to future growth in the Cachuma Project Member service areas, and would not be attributable to impacts to the Cachuma Project Member’ s Cachuma Project supply. Despite the fact that the Cachuma Project Member Units already have implemented a number of conservation measures, it may be possible to implement additional drought contingency measures identified as part of the Member Units’ urban water supply contingency analysis in order to make up for a temporary water supply shortage in a critical drought year or period. Project level water supply impacts from the Approved Project would be considered less than significant with the incorporation of Certified FEIR Mitigation Measure HYD-1.

3.1.1.3 Substantially Alter the Existing Drainage Pattern of the Site or Area, Including Through the Alteration of the Course of a Stream or River, in a Manner Which Would Result in Substantial Erosion or Siltation On- or Off-site, or Substantially Increase the Rate or Amount of Surface Runoff in a Manner Which Would Result in Flooding On- or Off-site?
Construction Impacts
Well Sites A and B evaluated in the Certified FEIR are located within a 100-year flood hazard zone.

Construction of the Approved Project components located outside of the 100-year floodplain of the Santa Ynez River would not reduce stream flow sufficiently to substantially alter the existing drainage pattern of the site or area.

As discussed above, the City would be required to implement a SWPPP, according to SWRCB requirements, which would implement construction and post-construction BMPs to minimize stormwater runoff. Therefore, the Approved Project would have resulted in less than significant impacts.

The only components of the Approved Project that would have the potential to reduce stream flow during construction would be the proposed wells along the Santa Ynez River. Development of the proposed water treatment plant included in the Approved Project would not interfere with stream flows as it would be located outside of the Santa Ynez River channel. Construction components of the Approved Project 333
located outside of the 100-year floodplain of the Santa Ynez River would not reduce stream flow sufficiently to substantially alter the existing drainage pattern of the site or area. Construction of the six 6) wells proposed under the Approved Project would have required access by construction equipment, trucks, and a drilling rig. Access to the new wells would have been provided by existing roadways along the north side of the river channel. Existing informal dirt roads on the floodplain would also have been used to access wells. At each well site, a 2,500-square-foot area (about 50 by 50 feet) would have been cleared and graded to a flat surface. It may have been necessary for construction trucks to also park along the existing dirt roads temporarily at each well site. The construction timeframe of the wells was temporary and short term in nature and would have been completed when water flow was low.

Therefore, the Certified FEIR concluded construction of the river wells would not sufficiently reduce stream flow to the Santa Ynez River to substantially alter the existing drainage pattern of the site or area and impacts would be less than significant ( Class III).

Impacts During Operation
To determine potential impacts to the flow of the Santa Ynez River, the Certified FEIR relied on a hydrologic analysis based on the Santa Ynez River Hydrology Model (SYRHM) that assessed impacts on Santa Ynez River flows, as well as on Cachuma Project operations, groundwater storage in the Above Narrows Riparian Aquifer, and water right releases. 3 The SYRHM also was the basis for numerous hydrologic studies of water releases for fish, water quality, and water rights in preparation of the 2000 BiOp, the FMP, the Settlement Agreement of 2002, 4 the Final EIR for the evaluation of U.S. Bureau of Reclamation’ s ( Reclamation) Applications for Modification of Water Permits 11308 and 11310 Applications 11331 and 11332) ( 2011), and the Draft EIR/ EIS ( 2003) on the Fish Management Plan and the 2000 BiOp.

The flows at Alisal Bridge under the Approved Project were very similar to the baseline flows. This would be due to the proposed Well Sites A and B being located downstream from the Alisal Bridge. Under the Approved Project, the average annual flows predicted by the SYRHM at Highway 154 Bridge would be 45,759 AFY, 48,701 AFY at the Alisal Bridge, and 64,863 AFY at the Lompoc Narrows. Under the Approved Project, flows would have increased slightly on average by 25 and 52 AFY at the Highway 154 Bridge and the Alisal Bridge when compared to baseline conditions due to a minor increase in releases from Lake Cachuma for water rights releases by about 183 AFY. Table 5.1-7: Median Monthly Flow of the Santa Ynez River in the Certified FEIR illustrated the median monthly flows at the Highway 154 Bridge and the Alisal Bridge locations along the Santa Ynez River. The median monthly flows at Highway 154 would largely be 3 See Stetson Memorandum No. 6 in Appendix 5 of the Certified FEIR. 4 Cachuma Conservation Release Board, Santa Ynez River Water Conservation District, Santa Ynez River Water Conservation District Improvement District No. 1, City of Lompoc, Settlement Agreement Relating to Operation of the Cachuma Project, 2002.
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unchanged from the baseline except when increases of 5.5 cfs and 0.75 cfs would occur in November and December, respectively; a slight decrease ( 0.5 cfs) would occur in January. At the Alisal Bridge, median monthly flows would remain similar for the majority of the year (January to September; within 0.25 cfs of the baseline) with increases occurring in October ( 0.75 cfs) and November ( 1.75 cfs); a slight decrease occurs in December ( 0.75 cfs). Median monthly flow at the Lompoc Narrows would remain essentially the same as the baseline from December through March with decreases occurring from April through November. The resulting changes in flows resulting from the Approved Project pumping proposed downstream of Alisal Bridge ( as modeled by Stetson) would be largely within the recognized fluctuation in the 2000 BiOp as changes in flow would vary from decreases of 0.75 cfs to increases of 5.5 cfs. Flows at Highway 154 would meet or exceed 5 cfs every month under Approved Project conditions, and flows at Alisal Road would meet or exceed 1.5 cfs about 92 percent of the time. These flows would be slightly less or more than baseline conditions depending on the month but would still meet the requirements of the 2000 BO. The Approved Project was determined to result in less than significant impacts to stream flow of the Santa Ynez River. The Certified FEIR stated that until the potential yield from the wells would be determined once the City completed the Approved Project’ s wells and performs well tests. However, based on the modeling conducted by Stetson, the Certified FEIR concluded impacts from operation of the Approved Project on existing drainage patterns would have been less than significant ( Class III).

3.1.1.4 Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?
Construction of the Approved Project’ s various components could have potentially impacted groundwater quality. The development of the Approved Project’ s proposed grading and construction activities would involve earth movement and the use of heavy equipment. Given the above, pollutants such as soil, sediments, and other substances associated with construction activities ( e.g., oil, gasoline, grease, and surface litter) could directly enter the Santa Ynez River or filter into the local groundwater, during project construction.

The Certified FEIR found the City would be required to implement a SWPPP, according to SWRCB requirements, which would implement construction and post-construction BMPs and monitoring plan to minimize discharge of pollutants in stormwater from the construction area and stormwater runoff. The Certified FEIR concluded that with the implementation of the SWPPP the water quality in the groundwater basin would not be altered and would not impair the beneficial uses, resulting in less than significant impacts to groundwater quality in the basin. Operation of the Approved Project involved the extraction of Santa Ynez River underflow and distribution through the City’ s municipal water system. Water extracted from the Santa Ynez River would have been pumped to the proposed water treatment plant. 335
There the water would have been treated to CDPH standards for surface water treatment. Chemicals anticipated to be utilized at the treatment plant include a coagulant, such as aluminum sulfate, and liquid sodium hypochlorite for disinfection. Therefore, the Certified FEIR determined the water diverted from the Santa Ynez River would be suitable for the City’ s municipal use and impacts would be less than significant. The Certified FEIR identified that water quality in the groundwater basin would not be altered and would not impair the beneficial uses. Impacts would have been less than significant to groundwater quality in the basin (Class III).

3.1.1.5 Otherwise Substantially Degrade Water Quality
Construction
Implementation of the Approved Project would occur over a span of 10 to 15 years. As such, the Certified FEIR determined the amount of water needed for construction, including well development, would be approximately 6 acre-feet, or less than 1 percent of Lake Cachuma storage capacity. 5 Construction is considered short and temporary in nature. Therefore, the Certified FEIR determined construction related impacts of the Approved Project would not substantially reduce reservoir levels or storage to substantially impar designated beneficial uses. Impacts would be less than significant ( Class III).

Impacts During Operation
Well Sites A and B would be located within the Santa Ynez River 100-year floodplain. As a result, there would be times when the river is at higher flows when surface water could be located within 150 feet of a proposed well. However, based on DPH regulations, water cannot be produced from a well while surface water is within 150 feet unless the water is filtered and meets the standards of the Surface Water Treatment Rule. 6
Additionally, Stetson performed a water quality impact analysis for the Approved Project. The focus of this water quality analysis was on the total dissolved solids ( TDS) concentration of the Santa Ynez River flow at the Lompoc Narrows. The Approved Project would increase diversions from the baseline condition of 1,053 AFY at an extraction rate of 1.85 cfs, to 1,980 AFY at a maximum extraction rate of 5 cfs of Santa Ynez River water. Stetson used the SYRHM model to analyze the potential impact of TDS concentrations of Santa Ynez River flows at the Lompoc Narrows under pumping conditions greater than the Approved Project (2,400 AFY which is greater than the proposed 1,980 AFY). According to Stetson, the primary effect of the Approved Project on the flow at the Lompoc Narrows is a decrease in the early fall flows. However, this is the period in which the TDS concentrations the Santa Ynez River flows near Lompoc are high, so the 5 See Section 5.1 of the Certified FEIR. 0.92 acre-foot per well * six wells = 5.52 acre-feet. 6 acre-feet/ 168,000 acre-feet average storage in April of Lake Cachuma) would be less than 1.0 percent. 6 California Code of Regulations, Title 22, Division 4, Chapter 17, “Surface Water Treatment.” 336
impact on TDS concentrations in the Lompoc groundwater basin is minimal or none due to minor changes in loading (increased TDS concentrations associated with reduced flows). In addition, water right releases would increase under the Approved Project compared to baseline conditions, which would help improve water quality at the Lompoc Narrows. The average differences in TDS concentrations in the Lompoc groundwater basin would be very small relative to the total TDS levels in the Lompoc wells (800 to 2,500 mg/ L).

Consequently, the Certified FEIR concluded the operation of the Approved Project would result in less than significant impacts on surface water quality.

3.1.1.6 Place housing within a 100-year flood hazard area? The Approved Project does not provide for any housing, as such no housing would be placed in the 100- year flood zone. Consequently, any wells constructed within the designated floodplain would need to be protected from potential flood damage. The Approved Project would not have placed people or structures at risk of flooding. The Approved Project was not in an area subject to seiches, tsunamis or mudflows.

There would be no impact (Class III).

3.1.1.7 Place within a 100-year flood hazard area structures which would impede or redirect flood flows?
Portions of areas of proposed Well Sites A and B within the City’ s jurisdiction are located within a 100- year flood hazard zone. According to the City’s Municipal Code Flood Control chapter, 7 the Master Plan Update would be required to design the new wells to minimize or eliminate infiltration of floodwaters to the systems and discharge from the systems into floodwaters. Therefore, the Certified FEIR determined impacts related to the potential for water infiltration were less than significant.

Portions of Well Sites A and B are located within the 100-year floodplain of the Santa Ynez River. As a result, the Certified FEIR stated the proposed well heads and surface infrastructure have the potential to be damaged by river flows during a 100-year flood event. Loss of production in future wells would limit the City’ s ability to provide its residents adequate water supplies. Consequently, any wells constructed within the designated floodplain would need to be protected from potential flood damage. These impacts would be potentially significant. The Certified FEIR stated the Approved Project would implement Certified FEIR Mitigation Measure HYD-2.
7 City of Solvang Municipal Code, Title 13, “ Flood Control.” 337
With implementation of Mitigation Measure HYD-2, the impacts from the Approved Project would be reduced to less than significant levels (Class II).

3.1.1.8 Expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam?
The Master Plan Update would not place people or structures, at risk of flooding. Impacts would be less than significant ( Class III).

3.1.1.9 Substantially increase the risk of inundation by seiche, tsunami, or mudflow?
The Certified FEIR stated the Project is not in an area subject to seiches, tsunamis or mudflows. There would be no impact (Class III).

3.1.1.10 Cumulative Impacts
The Certified FEIR found the Approved Project would have resulted in less than significant project level impacts. Cumulative impacts within the City limits were analyzed based on a full General Plan buildout condition. The Certified FEIR examined baseline and proposed water diversions within the Santa Ynez River from Bradbury Dam to the 101 bridge in Buellton. Below is a discussion of these cumulative impacts.

Water Rights
The Cachuma Project Settlement Agreement of 20028 governs the various parties with water right interests in the Lower Santa Ynez River. The purpose of operating the downstream water right releases in conjunction with the fish water releases, as provided in the Settlement Agreement of 2002, is to reduce the impacts on the Cachuma Project water supply while meeting the target rearing flows described in the 2000 BiOp. As provided in Order WR 73-37 and Order WR 89-18, the inflow to Lake Cachuma is credited to the Above Narrows Account to the extent there is no visible flow (live stream) at designated locations in the river from Bradbury Dam to Floradale Avenue in the Lompoc Valley. The Below Narrows Account is based on the difference between the actual percolation below the Narrows and the estimated percolation that would have occurred if Lake Cachuma did not impound river flows. Reclamation calculates monthly constructive” flows and percolation, and estimates the difference using two percolation curves adopted in Order WR 89-18. The downstream water right releases contributing to the conjunctive use operations 8 Cachuma Conservation Release Board, Santa Ynez River Water Conservation District, Santa Ynez River Water Conservation District Improvement District No. 1, City of Lompoc, Settlement Agreement Relating to Operation of the Cachuma Project, 2002.
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consist of either release from the Above Narrows Account or combined releases from the Above and Below Narrows Accounts.

Under the Cachuma Project water supply Master Contract between Reclamation and the Santa Barbara County Water Agency, Reclamation delivers an annual amount to the Member Units that does not exceed the “ Available Supply.” The latter represents the maximum amount of Lake Cachuma water that is available after Reclamation has met all requirements for water for other purposes under current and future state and federal laws, permits, orders, and requirements. Hence, Available Supply does not include water released pursuant to SWRCB Orders WR 89-18 and WR 94-5 for downstream groundwater replenishment, or water released under WR 94-5 for fish and to meet the requirements of the 2000 BiOp of NMFS for the endangered southern steelhead. The maximum Lake Cachuma allocation, or available supply, is 25,714 AFY for Member Units.

The Settlement Agreement of 2002 ensures that rights of water users downstream of Bradbury Dam would be protected. As such, cumulative water right impacts would be considered less than significant Class III).

Surface Water Hydrology
At the time of the Certified FEIR, the flows of the Santa Ynez River were analyzed at three key locations based on existing monitoring gauges when the Certified FEIR was prepared. The flow locations analyzed were at the Highway 154 Bridge, Alisal Bridge and at the Lompoc Narrows. Approved Project flows were analyzed from Bradbury Dam downstream to the proposed Well Site B location. Flows within the Santa Ynez River would increase slightly under cumulative conditions as additional requests for water releases would be made during the summer and early fall months. Conditions further downstream at the Buellton Bridge are similar to the impacts at Alisal Bridge, except attenuated by the additional tributary and groundwater contributions below Alisal Bridge. Impacts from increased City river pumping would attenuate even further downstream near the Salsipuedes Creek confluence and at the Lompoc Narrows.

Historic TDS concentrations were found to be cyclical with seasonal hydrologic conditions. Higher concentrations of TDS typically occur in summer and fall months when flows are minimal. Higher flows during the winter months results in lower TDS concentrations. An increase in river flows due to the increase in water rights releases would lower TDS concentrations during the summer and late fall months.

The Certified FEIR concluded cumulative surface water quality impacts would be less than significant (Class III).
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Groundwater Hydrology
Average dewatered groundwater storage in the Above Narrows Aquifer would increase with implementation of the Approved Project. Under cumulative conditions, surface water flows would increase during the summer and early fall months as a result of additional water right releases. These additional flows would contribute to groundwater recharge and percolation into the aquifers along the river. Therefore, cumulative groundwater impacts to the Above Narrows Aquifer would be less than significant.

However, if water levels decline in excess of operational criteria as a result of simultaneous pumping; potentially significant impacts would occur to the City’ s wells and adjacent well users. This scenario would only occur during low flow periods of the Santa Ynez River.

The primary area of concern would be the well fields upstream of Alisal Bridge which would include the City’ s Well 7A, Alisal Ranch wells and, further upstream, the ID No. 1, 6 cfs well field.

An existing agreement between ID No. 1 and Alisal Ranch that provides for monitoring of observation well 22F1, determines that once the groundwater elevation of well 22F1 reaches an elevation of 375 feet, ID No. 1 shall have to stop pumping groundwater, or supply water to Alisal Ranch. The Certified FEIR stated the City would operate the proposed wells downstream of Alisal Bridge to minimize potential environmental impacts upstream of Alisal Bridge. As discussed in the Certified FEIR and above, the Approved Project would result in less than significant groundwater elevation impacts. Therefore, cumulative groundwater elevation impacts would be less than significant ( Class III).

Water Supply
Critical dry and drought periods would result in shortages in water supply from the Cachuma Project to Member Units. The Approved Project was determined to result in similar water supplies within Lake Cachuma compared to baseline conditions in the Certified FEIR. However, shortages would still occur with or without the implementation of the Approved Project. The Certified FEIR stated as Approved Project level impacts would be reduced to less than significant levels with implementation of Mitigation Measure HYD- 1, cumulative water supply impacts would be considered less than significant with incorporation of this mitigation measure ( Class II). The Certified FEIR determined it may be possible to implement additional drought contingency measures identified as part of the Member Units’ urban water supply contingency analysis in order to make up for a temporary water supply shortage in a critical drought year or period (Class II).
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3.1.2 Description of the Changes Resulting from Revised Project The Revised Project would be similar to the river wells portion of the Approved Project but it would be constructed and operated at a reduced capacity and entirely eliminates the water treatment plant component of the Approved Project. The Revised Project includes a reduction of new wells from six to two river wells and limiting the location of any new wells to Well Site B. The Revised Project also results in less pumping than the Approved Project. The Revised Project proposes diversion of 1,368 AFY ( which must reduce from the 1,980 AFY contemplated under the Approved Project) and a diversion rate of 2.84 cfs ( which is again reduced from the 5 cfs contemplated under the Approved Project). The reach of diversion is also substantially reduced under the Revised Project. The Approved Project envisioned a Reach of Diversion of approximately 19,500 feet whereas the Final Reach of Diversion under the Revised Project is approximately 8,060 feet. Some aspects of the river wells portion of the Approved Project are the same under the Revised Project. For example, the design of the new wells is consistent with the Approved Project and the City still plans to abandon existing Well 7A. Additionally, other components of the Approved Project are no longer under consideration, including the previously planned water treatment plant as analyzed in the Certified FEIR. Other components of the Approved Project are not changed or addressed at all by the Revised Project.

A detailed description of the comparison between the Revised Project and the Certified FEIR Project is in the Review of Santa Ynez River Mechanics and Technical Memoranda Associated with City of Solvang’ s Revised River Wells Project prepared by GSI Water Solutions, Inc. ( GSI) in the Updated Technical Memoranda subsection below.

3.1.3 Changes in City, State, or Local Plans and Regulations Since the City certified the FEIR for the Approved Project, the following changes in City, State, or Local Plans and Regulations have occurred that affect the Santa Ynez River and are applicable to the Revised Project.

3.1.3.1 State Water Resources Control Board – 2019 Cachuma Project Order Under Order WR 2019-0148, issued on September 24, 2019, 9 the SWRCB amended the terms and conditions of the U.S. Bureau of Reclamation’ s (Reclamation) permits for the Cachuma Project ( Permits 11308 and 11310 [ Applications 11331 and 11332]) 10 to protect public trust resources and downstream 9 State Water Resources Control Board ( SWRCB), Order WR 2019-0148. Order Amending Permits 11308 and 11310 Applications 11331 AND 11332). In the Matter of Permits 11308 and 11310 (Applications 11331 and 11332) held by the United States Bureau of Reclamation for the Cachuma Project on the Santa Ynez River, September 17, 2019. 10 U.S. Department of Interior, Bureau of Reclamation’ s Water Right Permits 11308 and 11310 (Applications 11331 and 11332) To Protect Public Trust Values and Downstream Water Rights on the Santa Ynez River below Bradbury Dam ( Cachuma Reservoir).
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water rights on the Santa Ynez River below Bradbury Dam. The SWRCB also approved Reclamation’ s petition to change the authorized place of use and purposes of use for Permits 11308 and 11310 (“ the Permits”).

Background
SWRCB Order WR 94-511 established a deadline of December 1, 2000, to commence a hearing on the protection of downstream water right holders. The SWRCB held a hearing on that issue and on the issue of the measures needed to protect public trust resources over eight days in 2000, 2003, and 2012.

The Santa Ynez River provides habitat for the Southern California Distinct Population Segment of steelhead trout (Oncorhynchus mykiss or O. mykiss) ( steelhead), which is listed as an endangered species under the federal Endangered Species Act12 (ESA). The Cachuma Project has adversely affected the steelhead fishery by blocking access to the majority of suitable spawning and rearing habitat upstream, and by modifying flows in the mainstem of the lower Santa Ynez River ( mainstem) below Bradbury Dam to the point that the survival of the species is uncertain. Currently, Reclamation operates and maintains Bradbury Dam on the Santa Ynez River in accordance with the 2000 BiOp pursuant to Section 7 of the federal ESA. 13 Even though Reclamation has operated and maintained Bradbury Dam in accordance with the 2000 BiOp for more than a decade, the steelhead population in the Santa Ynez River remains at a critically low level.

The hearing record supports the conclusion that the population is unlikely to be restored to a sustainable level unless the amount of suitable spawning and rearing habitat to which the steelhead have access is increased. The hearing record supports the conclusion that higher flows are likely to benefit steelhead by providing additional spawning and rearing habitat as well as increasing passage opportunities in the lower mainstem river. At the same time, the record supports the need for development of additional information and adaptive management of flows to maximize the benefits of those flows to steelhead and avoid potential impacts during implementation. Weighing the competing uses of water, the SWRCB has found that it is necessary to protect and improve the critical condition of the remnant Santa Ynez River watershed steelhead population. Therefore, this order requires Reclamation to provide higher flows under an 11 State Water Resources Control Board (SWRCB), Order 94-5, Order Continuing Reserved Jurisdiction and issuing Amened Permits, Issued ) Order: WR 94-5 pursuant to Applications 11331 and 11332; the ) United States Bureau of Reclamation:

Permittee, November 17, 1994.
12 Endangered Species Act 16 U.S.C. § 1531 et seq., 1973. 13 Endangered Species Act 16 U.S.C. § 1531 et seq., Section 7, Consultations and Conferences, 1973. 342
adaptive management process during wet and above normal years when the water supply impacts of such flows would be minimized (Alternative 5C from the SWRCBs 2011 Final Environmental Impact Report). 14 Though the higher flows will only be provided in wet and above normal water years these higher instream flow requirements may increase, to some extent, projected water supply shortages during critically dry periods for those who rely on Cachuma Project water. These shortages are in addition to those already caused by implementation of the 2000 BiOp. As a result, additional water conservation and increased reliance on alternative water supplies may be necessary to compensate for future shortages during critically dry periods.

In coordination with CDFW and NMFS, Reclamation will be required to study the effects of the increased flows on steelhead to verify the amount of additional habitat provided by the flows and determine whether a different release schedule would be more beneficial to the fishery. In the unlikely event the results of the study demonstrate that the flows do not provide benefit to the steelhead fishery or are likely to harm the fishery, this order reserves the SWRCBs authority to reduce the required instream flows.

Although additional flows are necessary, the evidence in the record indicates that increasing flows will not be sufficient, without additional measures, to restore the steelhead fishery to good condition. Specifically, passage around Bradbury Dam, where the majority of the historic spawning and rearing habitat occurred and still persists, and other habitat restoration actions by other agencies and private and public interests to address the ecosystem as a whole will be necessary to solve this complex problem of restoring viable steelhead runs in the Santa Ynez River watershed. To improve the state of knowledge concerning the measures necessary to protect the steelhead fishery, this order also requires Reclamation to study the feasibility of additional measures that may be necessary to restore the fishery, including the feasibility of providing fish passage around Bradbury Dam.

The Cachuma Project contractors and downstream water right holders reached a settlement agreement 15 that resolved actual and potential disputes that existed among the parties relative to the obligation of Reclamation to make releases from Bradbury Dam for the protection of downstream water rights and water quality. Reclamation has requested that the SWRCB amend its Permits to be consistent with this agreement. This order amends Reclamation’ s Permits to be consistent with its request. The Settlement 14 State Water Resources Control Board (SWRCB), Final Environmental Impact Report, consideration of Modifications to the U.S. Bureau of Reclamation’ s Water Right Permits 11308 and 11310 (Applications 11331 and 11332) to Protect Public Trust Values and Downstream Water Rights on the Santa Ynez River below Bradbury Dam (Cachuma Reservoir) State Clearinghouse # 1999051051, December 2011.
15 Settlement Agreement between Cachuma Conservation Release Board, Santa Ynez River Water Conservation District, Santa Ynez River Water Conservation District Improvement District No. 1 (ID No. 1), and the City of Lompoc, relating to Operation of the Cachuma Project. December 17, 2002.
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Agreement ( Settlement Agreement of 2002) 16 assumes specific operating criteria, currently in place, will govern fish flows below Bradbury Dam. However, as already discussed above, Order WR 2019-0148 requires additional releases for the protection of public trust resources. The parties may need to negotiate changes to the Settlement Agreement in light of the releases for steelhead required by this order. As such, Order WR 2019-0148 reserves the SWRCB’ s authority to make any amendments to the Permits that may be necessary based on any changes to the Settlement Agreement.

Order Requirements
Under Order WR 2019-0148, Reclamation will be required to study the effects of the increased flows on steelhead and verify the utility of the additional amount of habitat created given temperature, dissolved oxygen, and substrate conditions. The SWRCB reserves authority to reduce or modify the flow requirement if the results of the study demonstrate that the flows do not provide the anticipated benefits to the steelhead fishery, or if greater water supply impacts are discovered. Also, with oversight from the Executive Director, NMFS or California Department of Fish and Wildlife (CDFW) can direct Reclamation to temporarily terminate or reduce the requirement to meet the increased flows to prevent any detrimental effects to the steelhead. Additionally, to maximize benefits to the fishery, an adaptive management approach allows for NMFS, CDFW, Reclamation, and the Member Units to modify the timing of the flows, provided that doing so does not cause any additional water supply impacts above those identified in the Final Environmental Impact Report for Order WR 2019-0148. 17 To improve the state of knowledge concerning the protection of the steelhead fishery, the order also requires Reclamation to specify one or more metrics that can be used to quantify what would constitute good condition of the fishery at the individual, population, and community levels. This order requires Reclamation to study the feasibility of additional measures that may be necessary to restore the fishery to good condition, including passage around Bradbury Dam, modified instream flows, and measures to address predators and other species with a potential to negatively affect steelhead. The SWRCB will reserve authority to determine the adequacy of the studies and, after satisfactory completion of the studies, to determine whether any additional measures should be implemented consistent with the Public 16 Settlement Agreement between Cachuma Conservation Release Board, Santa Ynez River Water Conservation District, Santa Ynez River Water Conservation District Improvement District No. 1 (ID No. 1), and the City of Lompoc, relating to Operation of the Cachuma Project. December 17, 2002.
17 Final Environmental Impact Report, Consideration of Modifications to the U.S. Bureau of Reclamation' s Water Right Permits 11308 and 11310 ( Applications. 1133.1 and. 11332) to. Protect Public Trust Values and Downstream Water Rights on the Santa Ynez River below Bradbury Dam (Cachuma Reservoir) ( State Clearinghouse# 1999051051} ( Final EIR). 344
Trust Doctrine 18 to restore steelhead to good condition. If greater habitat gains can be achieved through improvement projects that result in achieving good condition of the steelhead fishery, the SWRCB may require implementation of these projects in lieu of increased flow requirements.

For the protection of downstream rights, this order amended terms 5 and 6 of Reclamation’ s Permits, as modified by Order WR 73-37 and amended by Order WR 89-18, in accordance with the technical amendments proposed by the parties to the Settlement Agreement, dated December 17, 2002, and agreed to by Reclamation. The technical amendments generally provide for:

1. An alternative measurement location for the “ live-stream” determination at San Lucas Bridge Highway 154) in light of fish water releases that are routinely made and present at that location and have been since 1993;

2. Implementation of the conjunctive operation of the Below Narrows Account ( BNA), with respect to determining the application of Curve A and Curve B in determining the BNA credits; and

3. Recognition of additional measurements to be carried out with respect to water flows and quality.

The Order grants Reclamation’ s 1983 petition to change the place and purpose of use authorized under its Permits. Accordingly, the Permits were amended under the SWRCB Order WR-2019-0148 to include within the authorized place of use all lands within the Cachuma Member Units’ service areas, and a net of 40,250 irrigable acres within a gross area of 205,376 acres, as shown on specified maps. The Permits were also amended as part of WR-2019-0148 to authorize the following purposes of use: Irrigation, Municipal, Domestic, Industrial, Salinity Control, Incidental Recreation, Stock watering, and Fish and Wildlife Conservation.” As such, the operation of the river under WR-2019-0148 remains essential with regards to downstream diversion including the City.

Permits 11308 and 11310 shall be replaced with amended permits that contain all current terms and conditions set forth in the original permits, the applicable terms and conditions adopted pursuant to subsequent decisions and orders, and the terms, conditions, and changes specified herein. In addition, the amended permits shall be updated to include current mandatory terms and conditions. Specific term and 18 In California, the Public Trust Doctrine has been recognized to extend to the protection of navigable surface waters, to nonnavigable tributaries of those waters, to aquatic resources, and to birds and other wildlife. The State has a continuing duty to manage public trust resources for the benefit of the people of the State, traditionally by balancing three traditional interests: fishing, navigation and commerce. To those three traditional uses, the courts have added the right of the public to pass over public trust lands and waters free from restrictions by private landowners, and also protection of ecological units and recreation. The Public Trust Doctrine allows any person to bring a lawsuit against the State if it fails to fulfill its duty as Trustee to manage these protected resources in accordance with the Doctrine. The California Supreme Court decided National Audubon Society v. Superior Court (“ Mono Lake”) ( 33 Cal.3d 419 (1983)), formally bringing the Public Trust Doctrine into California water policy case law.
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condition numbers and corresponding references to those specific terms and conditions may be updated upon issuance of amended permits.

3.1.3.2 Cachuma Order WR-2019-0148 Term 18 Plan
As discussed above, on September 17, 2019, the SWRCB adopted Final Order WR-2019-0148 amending Reclamation’ s Permits for the Cachuma Project in Santa Barbara, California. Reclamation provided a Plan in accordance with Term 1819 of Order WR-2019-0148 to describe “ the measures inplace, or that will be implemented to ensure compliance with Terms 15 and 16” of Order WR-2019-0148.

Term 15 of Order WR 0148-2019
Term 15 of Order WR 0148-201920 requires Reclamation to “operate and maintain the Cachuma Project and implement conservation measures including but not limited to those described in Revised Section 3 Proposed Cachuma Project) of the Biological Assessment for Cachuma Project Operations and the Lower Santa Ynez River, June 2000, taking into consideration the 2013 Biological Assessment with any amendments and the 2016 Draft Biological Opinion (2016 Draft BiOp), and right holder shall comply with all of the Reasonable and Prudent Measures 5 and 7 through 13, and the Terms and Conditions in the NMFS’ Biological Opinion: U.S. Bureau of Reclamation operation and maintenance of the Cachuma Project on the Lower Santa Ynez River in Santa Barbara County, California, September 2000” ( 2000 BiOp).

Reclamation has and will continue to comply with terms and conditions of the 2000 BiOp. As 3 of the 6 passage barriers, to preclude the migration of steelhead predators such as large mouth and small mouth bass ( Micropterus salmoides and M. dolomieui), identified in the 2000 BiOp could not be completed by the end of 2005, Reclamation sent a letter to NMFS on December 29, 2005 requesting to reinitiate consultation on the Cachuma Project. Reconsultation with NMFS is ongoing. Reclamation will notice the SWRCB within 30 days of issuance of a new biological opinion pursuant to Term 15.

Term 15(a) of Order WR-2019-014821 requires Reclamation to “release or bypass water to maintain the following Mainstem Rearing instream flows in the Santa Ynez River, as set forth below [ in Table 3.1-1:

Mainstem Rearing Flows] at all times.” The flows in Table 3.1-1 are also required for Reclamation’ s continued compliance with the 2000 BiOp. Reclamation has operated the reservoir to meet 2000 BiOp 19 U.S. Department of Interior, Bureau of Reclamation, Cachuma Order WR 2019-0148 Term 18 Plan, Cachuma Project, California, dated May 2021.
20 State Water Resources Control Board ( SWRCB), Order WR 2019-0148. Order Amending Permits 11308 and 11310 Applications 11331 AND 11332).In the Matter of Permits 11308 and 11310 (Applications 11331 and 11332) held by the United States Bureau of Reclamation for the Cachuma Project on the Santa Ynez River, September 17, 2019. 21 State Water Resources Control Board ( SWRCB), Order WR 2019-0148. Order Amending Permits 11308 and 11310 Applications 11331 AND 11332). In the Matter of Permits 11308 and 11310 ( Applications 11331 and 11332) held by the United States Bureau of Reclamation for the Cachuma Project on the Santa Ynez River, September 17, 2019. 346
flow requirements and will continue to operate the reservoir to meet flow requirements of the 2000 BiOp and Order WR-2019-0148.

Table 3.1-1
Mainstem Rearing Flows
Reservoir Spilla ( acre-feet) Lake Storageb ( acre-feet) Flow (cfs) Requirements at:

Highway 154 Alisal Road
Stilling Basin &
Long Pool
20,000 NA 10 1.5c -
20,000
120,000 5 1.5d -
30,000 and
120,000

2.5 1.5d -
30,000 - - 30 acre-feet per
monthe
Notes:

NA – not applicable
A Reservoir spill is calculated cumulatively over the course of the water year (FEIR, Vol. IV, Appendix F, DraftTechnical Memorandum No. 5, p. 6), which begins October 1 (FEIR, Vol. IV, Appendix F, Draft Technical Memorandum No. 5, p. 8).

B Lake storage is measured on the first day of each month. (FEIR, Vol. IV, Appendix E, Technical Memorandum No. 1, p. 5.) C The specified flow applies only when Oncorhynchus mykiss are present.

D The specified flow applies only if there was reservoir spill greater than or equal to 20,000 acre-feet in the priorwater year and Oncorhynchus mykiss are present in the Alisal Reach.

E When there is less than 30,000 acre feet of total water stored in the reservoir, regardless of origin, right holder shall provide periodic releases of 30 acre-feet per month to refresh the Stilling Basin and Long Pool directly downstream of the dam to provide for Oncorhynchus mykiss (O. mykiss) rearing in these areas. Less than 30acre-feet per month may be released upon determination by the fishery agencies and the State Water Board that less water is necessary to refresh the Stilling Basin and Long Pool directly downstream of the dam for Oncorhynchus mykiss in these areas.

Source: Term 15(a) of Order WR-2019-0148.and Stetson Engineers. Technical Memorandum No. 6 – Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for a Time Extension for Water Rights Permit 15878– New Wells Downstream of Alisal Bridge, Table ES- 1, January 24, 2011.

In 2004, Stetson developed guidelines for releases from Bradbury Dam to meet required target flows pursuant to the 2000 BiOp. The table release was updated by Stetson in 2011. Since then, Reclamation has released flows from Bradbury Dam as prescribed in Table 3.1-122 to meet 2000 BiOp target flows.

To comply with Term 15(a) of Order WR-2019-0148, Reclamation has been releasing approximately 2.2 cfs more than is prescribed in Table 3.1-1 and is measuring flow in the Santa Ynez River at an alternate site near the east end of Refugio Road (Refugio Road Location) approximately 1.17 miles downstream from the Highway 154 bridge. There are ongoing issues with property access and flow measurements at 22 Stetson Engineers. Technical Memorandum No. 6 – Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for a Time Extension for Water Rights Permit 15878– New Wells Downstream of Alisal Bridge, Table ES-1, January 24, 2011.
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the Highway 154 bridge; therefore, Reclamation uses the Refugio Road Location in lieu of the Highway 154 bridge to measure target flows.

Measurements made since May 2020 have shown that system losses to the Refugio Road Location, below Highway 154, are approximately 2.2 cfs higher than predicted for the same months. Due to this recent finding and the new flow requirement at Alisal Bridge, Reclamation has developed new flow release tables to meet Term 15(a) flow requirements. The Term 15 Compliance Tables are intended to be living documents that will change as new information is developed.

Reclamation’ s assumptions for development of the Term 15 Compliance Tables:

Measuring flow of the Santa Ynez River at Refugio Road Location approximately 1.17 river miles downstream of the Highway 154 Bridge is an acceptable alternative to the required measurement at Highway 154 Bridge with no modification to the Water Order Term 15 flow requirements.

Losses due to groundwater usage, riparian phreatophytic flora uptake, and other causes arevariable throughout the calendar year and change over time.

Consistent with seasonal variations in plant metabolism and agricultural irrigation demands, peak losses are expected to occur in the summer with minimal losses occurring in the winter.

For Water Year 2020 and beyond, Reclamation will follow the release tables set forth in Attachment 2 of the Term 18 Plan23 to meet Term 15(a). Reclamation and Cachuma Operations and Maintenance Board COMB) Fisheries Division will continue taking monthly or more frequent measurements at the Refugio Road Location below Highway 154 to confirm that the releases are meeting target flows. Should flows be under or above required target requirements, Reclamation will make release adjustments accordingly.

Term 16(a)-16(b) of Order WR-2019-0148
Term 16(a) through 16(b) or WRO 2019-014824 requires Reclamation to “release or bypass water to meet the Table 3.1-2: Flows ( Wet and Above Normal Water Year Types) flows, set forth below, at all times during Wet and Above Normal water year types.” The flows in Table 3.1-2 (of Order WR-2019-0148) will be triggered when the cumulative inflow into Cachuma first reaches 33,707 acre feet in a water year, defined as beginning on October 1st and ending September 30th of the following year. 23 U.S. Department of Interior, Bureau of Reclamation, Cachuma Order WR 2019-0148 Term 18 Plan, Cachuma Project, California, dated May 2021.
24 State Water Resources Control Board ( SWRCB), Order WR 2019-0148. Order Amending Permits 11308 and 11310 Applications 11331 AND 11332). In the Matter of Permits 11308 and 11310 ( Applications 11331 and 11332) held by the United States Bureau of Reclamation for the Cachuma Project on the Santa Ynez River, September 17, 2019. 348
Table 3.1-2
Flows (Wet and Above Normal Water Year Types)
Minimum Flow
Requirement* Period of Flow Purpose of Flow
48 cfs 02/ 15 to 04/ 14 Spawning
20 cfs 04/ 15 to 06/ 01 Incubation and Rearing
25 cfs 06/ 02 to 06/ 09 Emigration
Ramp to 10 cfs by 06/ 30
10 cfs 06/ 30 to 10/ 01 Rearing and Resident FishMaintenance 5 cfs 10/ 01 to 02/ 15 Resident Fish
Notes:

The above flows shall be maintained at both San Lucas and Alisal bridges. These flows may be met with both natural stream flow and releases from Bradbury Dam.

Source: Term 16(a)-16(b) of Order WR-2019-0148.

As an initial starting point, Reclamation adapted Stetson’ s 2011 operating guidelines to develop Table 2A in Attachment 3 of the Term 1825 to meet Table 3.1-2 flows. Ramping protocol includes the proposed ramping schedule shown in Table 3.1-3: Reclamation’ s Proposed Ramping Rates in accordance with the 2000 BiOp.

Table 3.1-3
Reclamation’ s Proposed Ramping Rates
Release Rate ( cfs) Ramping Increment ( cfs)
Ramping Frequency
No more than once every)
90 25 4 hours
90 to 30 10 4 hours
30 to 10 5 4 hours
10 to 5 2.5 4 hours
5 to 3.5 1.5 4 hours

3.5 to 2.5 1 4 hours
Source: Term 16(a)-16(b) of Order WR-2019-0148.

Term 16 of Order WR-2019-0148 requires flows at Alisal Bridge ranging from 5 to 48 cfs. Reclamation is working on expanding the 2011 Stetson operating guidelines to meet the higher Table 3.1-2 target flows required at Highway 154 Bridge and Alisal Bridge. Development of compliance tables for Term 16, Table 25 U.S. Department of Interior, Bureau of Reclamation, Cachuma Order WR 2019-0148 Term 18 Plan, Cachuma Project, California, dated May 2021.
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3.1-2, will be done in conjunction with Term 15 compliance tables and follows the same process and assumptions as described in Attachment 1 of Term 18.26
Term 16(c)) through 16(e) describe the protocol required for temporary reductions or terminations of Table 3.1-2 flows for the protection of the steelhead in the Santa Ynez River, as determined by CDFW or NMFS. Reclamation will notify the Executive Director of the Water Board of any changes to Table 2 flows recommended by CDFW or NMFS in accordance with Term 16(c) of Order WR-2019-0148. The recommendation by CDFW or NMFS to temporarily modify Table 3.1-2 flows, as well as the required supporting information, will be posted on Reclamation’ s publicly accessible South-Central California Area Office ( SCCAO) Operations page. 27 Term 16(f) as defined in the Term 18 Plan28 requires Reclamation to “ confer with the Member Units to analyze reducing the safe yield of the Cachuma Project” within one year of the adoption of Order WR-2019-0148.

Reclamation is further required to notify the Executive Director of the Water Board “ in writing of any current or planned reduction to the Cachuma Project’ s safe yield” within 18 months of the adoption of Order WR-2019-0148. 29
Pursuant to Term 16(f), Reclamation is coordinating with the County of Santa Barbara and the Member Units regarding potential changes to the safe yield of the Cachuma Project. At present, there are no current or planned reductions to the Cachuma Project’ s safe and operational yield that would reduce downstream river flows and affect downstream water right holders.

3.1.3.3 Recent Hydrologic Conditions
Precipitation, Stream Runoff, and Bradbury Dam Spills
Historically, water year type for the Santa Ynez River alluvium has been defined as a dry year when rainfall e.g., precipitation) at Bradbury Dam is equal to or less than 15 inches, a normal ( average) year when rainfall is 15 inches to 22 inches, and a wet year when rainfall is equal to or greater than 22 inches. 30 The SWRCB uses different criteria that focus on river runoff (in this case inflow to the Cachuma Reservoir); a critically dry year when inflow is equal to or less than 4,550 acre-feet; a dry year when inflow is between 4,550 acre-feet and 15,366 acre-feet; a below normal year when inflow is between 15,366 acre-feet and 26 U.S. Department of Interior, Bureau of Reclamation, Cachuma Order WR 2019- 0148 Term 18 Plan, Cachuma Project, California, dated May 2021.
27 Reclamation’ s publicly accessible SCCAO Operations page is located at: https:// www.usbr.gov/ mp/ sccao/ operations.html. 28 U.S. Department of Interior, Bureau of Reclamation, Cachuma Order WR 2019-0148 Term 18 Plan, Cachuma Project, California, dated May 2021.
29 State Water Resources Control Board ( SWRCB), Order WR 2019-0148. Order Amending Permits 11308 and 11310 Applications 11331 AND 11332).In the Matter of Permits 11308 and 11310 (Applications 11331 and 11332) held by the United States Bureau of Reclamation for the Cachuma Project on the Santa Ynez River, September 17, 2019. 30 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
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33,707 acre-feet; an above normal year when inflow is between 33,708 and 117,842 acre-feet; and a wet year when inflow is greater than 117,842 acre-feet. Due to the long standing classification used in previous annual monitoring reports, the SWRCB approach will not be used in this report, although the designation would have been a below normal year at 26,229 acre-feet of computed inflow to Lake Cachuma.

Annual ( 2020) daily mean discharge hydrographs for the Lower Santa Ynez River ( LSYR) basin at the US Geological Survey (USGS) gauges arrows (USGS- 11133000), Salsipuedes Creek (USGS- 11132500), Solvang Alisal Bridge) ( USGS- 11128500), Bradbury Dam ( Reclamation), and Los Laureles ( USGS- 11123500) upstream of Lake Cachuma) gauges.

Water Year 2020 (WY2020) had 21.03 inches of rainfall at Bradbury Dam and was therefore classified as a normal year ( between 15 and 22 inches); 31 the long-term average ( 1953-2020) at the dam is 19.91 inches. with the highest amount of rainfall occurring in December, March, and April. Of the 68 year long record, this was the2 7th wettest and the 2nd driest year on record and the third normal water year since the beginning of the 2000 BiOp. The driest year on record occurred in 2007 with only 7.41 inches of rain and the wettest year on record was in 1998 with 53.65 inches of rain at Bradbury Dam. The largest storm of WY2020 ( 6.77 inches of rain) occurred on March 11, 2020 that saturated the watershed and made for excellent runoff conditions for subsequent storms. The next notable storm was on April 6, 2020 that recorded 3.56 inches of rain at Bradbury Dam and generated enough runoff to open up the LSYR lagoon on April 7, 2020 that remained open throughout the rest of the water year.

There was elevated stream runoff recorded within the LSYR mainstem and tributaries in WY2020, and the mainstem flow was sufficient to breach the sand bar and open the LSYR lagoon to provide upstream migration opportunities from the ocean and the lagoon for 55 days during the migration season and 177 days during the water year ( opened on April 7, 2020 – remained open throughout WY2020); that total number of days can be misleading when looking at flow conditions at the USGS gauge at H Street in Lompoc. 32 That section of the river is wide and has a sandy bottom that can be impassable for migrating fish at low flows even though the lagoon is open to the ocean. For example, recorded flows at H Street were less than 25 cfs on April 26, 2020, less than 10 cfs on May 12, 2020 and 0 cfs on May 17, 2020 for the rest of the water year. The USGS Narrows gauge recorded an instantaneous peak flow rate of 1,710 cfs on April 6, 2020. In Salsipuedes Creek, the highest recorded instantaneous peak discharge at the USGS gauging station at Jalama Road Bridge was 1,350 cfs recorded on April 6, 2020. Also measured at Jalama Road Bridge was a relatively small peak early in the season on December 25, 2019 of 118 cfs, followed by 31 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
32 Cachuma Operation and Maintenance Board ( COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
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nothing greater than 15 cfs until the first storm in April. The USGS Solvang gauge had a maximum instantaneous flow rate of 1,470 cfs on April 6, 2020.

There were 12 precipitation events in WY2020 with rainfall equal to or greater than 0.1 inches at Bradbury Dam. 33 The majority of the recorded precipitation at Bradbury Dam fell during the months of December

7.19 inches, 34.2 percent), March ( 8.13 inches, 38.7 percent) and April ( 3.58 inches, 17.0 percent).

Springtime rain helped maintain creek baseflow and initial rearing conditions. The necessary triggers to implement the Fish Passage Supplementation Program were met and are discussed below in a separate report ( 2020 Fish Passage Supplementation Report). 34 There was a BNA WR89-18 water release that began on August 31, 2020 and concluded on November 30, 2020 with 10,480 acre-feet released in total over 92 days.

At the beginning of the water year (October 1, 2019), there were 144,349 acre-feet of water stored in Lake Cachuma and 135,570 acre-feet at the end of the water year (September 30, 2020), with peak storage on April 25, 2020 at 156,960 acre-feet.35 The 2000 BiOp required target flows of a minimum of 5 cfs to the Highway 154 Bridge were maintained throughout the water year since reservoir storage was greater than 120,000 acre-feet throughout the period. Target flows to Hilton Creek of a minimum of 2 cfs were met throughout the water year through the Hilton Creek Watering System ( HCWS) by gravity flow to the Upper Release Point (URP). There were two (2) fish passage supplementation events (April 7, 2020 and April 25, 2020) that followed the established program criteria for passage release both in timing and discharge quantity. There was a Water Rights ( WR) 89-18 release in WY2020 that started on August 31, 2020 and continued until November 11, 2020 (a period of 92 days). This was a BNA release that discharged 10,480 acre-feet of water from Lake Cachuma to recharge downstream aquifers.

Annual hydrographs along the Santa Ynez River at Los Laureles, Solvang, Narrows and Salsipuedes Creek USGS gauges showed high spring stormflow runoff conditions throughout the basin. 36 The USGS Los Laureles gauge on the Santa Ynez River mainstem upstream of Lake Cachuma recorded continuous flow from December 22, 2019 through July 19, 2019 with peak daily discharge observed on March 16, 2020 at 301 cfs.

In Hilton Creek just upstream from the City of Solvang, there were two (2) high streamflow events from the upper watershed on December 25, 2019 and April 6, 2020, the latter brought down a large quantity 33 Cachuma Operation and Maintenance Board ( COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
34 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, Fish Passage Report, 2021. 35 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
36 Cachuma Operation and Maintenance Board ( COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
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of streambed material from the Whittier Fire burn scar. 37 The Hilton Creek gauge ( USGS- 11125605) is a low flow gauge only (less than 50 cfs) and during the December 23, 2019, March 11, 2020, and April 6, 2020 stormflow events, stream discharge was above the recording threshold December 25, 2019, March 16, 2020, and April 5, 2020, respectively. The peak release from Bradbury Dam ( Outlet Works plus the HCWS to Hilton Creek) was approximately 65.3.

3.1.3.4 Updated Technical Memoranda
In addition to the changes in City, State, or Local Plans and Regulations that have occurred since the Certified FEIR that affect the Santa Ynez River and are applicable to the Revised Project, GSI prepared technical memoranda to review the six prior hydrology- hydraulic technical memoranda, summarize past analyses, and including any relevant updates with respect to the Revised Project as well as address estimated flows for three scenarios: Existing ( Baseline) Conditions, conditions that are likely to occur if the City’s Petition for Change Project is denied, and conditions that are likely to occur if the Petition for Change is granted (and the Revised Project is able to be implemented). The two GSI technical memoranda are summarized below.

GSI Memo May 28, 2021 ( revised November 5, 2021) 2021) - Review of Santa Ynez River Mechanics and Technical Memoranda Associated with City of Solvang’ s Revised River Wells Project
GSI prepared a hydrogeologic assessment memorandum on May 28, 2021 ( Revised November 5, 2021) titled “Review of Santa Ynez River Mechanics and Technical Memoranda Associated with City of Solvang’ s Revised River Wells Project” ( hereafter referred to as “ GSI May 2021 memorandum”) ( see Appendix A) to provide an overview of the regulatory framework with respect to the Revised Project focused on 2000 BiOp and 2019 State Water Resource Control Board (SWRCB) for the Cachuma Project Water Rights Order 2019-0148) SWRCB Order amending permits 11308 and 11310 (Applications 11331 and 11332) issued on September 6, 2019. 38 This report compares the Revised Project relative to the Approved Project. This report also considers the implications of the NMFS Endangered Species Act (ESA) Section 7(a)(2) Biological Opinion ( NMFS Consultation Number WCRO- 2019-11596 [“ 2019 BiOp”] that was adopted on June 5, 2019) on the effect of river wells adjacent to the Santa Ynez River.

In an effort to provide technical background, this report provides an overview of six memoranda prepared by Stetson between 2004 and 2011, to identify the main effects related to the Revised Project pumping 37 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
38 GSI Water Solutions, Inc., City of Solvang Review of Santa Ynez River Mechanics and Technical Memoranda Associated with City of Solvang’ s Revised River Wells Project ( May 2021 revised November 5, 2021; see Appendix A to this Addendum). 353
plan to extract water from the Santa Ynez River alluvium from a reduced number of wells. This review of the six technical memoranda focuses on their relevance to the Revised Project, with particular focus on the sixth and most relevant of these memoranda.

Comparison of the Revised Project with Approved Project The Revised Project proposes to place up to two wells in Well Site B, which was analyzed under the Certified FEIR. The wells under the Revised Project are of a similar design as the wells analyzed under the Certified FEIR, though they will have reduced operational parameters. The wells under the Revised Project will also be at least 150 feet from the high water mark of the low flow wetted channel as assumed under the Certified FEIR. Based on the similar location and design of the Revised Project wells, GSI determined the Revised Project can be analyzed in the context of the Stetson Memoranda, specifically Stetson Memoranda No. 6.

Based upon review of (a) regulatory requirements as stipulated in the 2000 and 2019 BiOps and in Water Rights Order 2019-0148 and (b) technical analyses conducted to evaluate various pumping scenarios as presented in Stetson Technical Memoranda Nos 1 to 6, GSI determined the Revised Project will have less effect on river conditions than the Approved Project evaluated in the Certified FEIR. Based on results of modeling summarized in Stetson Technical Memorandum No. 6, pumping from four (4) new wells at Well Site B would not cause adverse effects on river flow conditions at Alisal Bridge. Because the Revised Project identifies only two (2) new wells in Well Site B, pumping less volume per year at a lower maximum instantaneous pumping rate, the effects will be significantly less than those identified in Stetson Technical Memorandum No. 6 and the Certified FEIR.

The modeling results from Stetson Technical Memorandum No. 6 indicate that the Santa Ynez River alluvium in Well Site B would be able to meet both the planned monthly average and peak demands of the City under the Certified FEIR Project ( at the time of the Stetson Technical Memorandum No. 6, the City’ s demands were based on a combined annual rate of 2,400 AFY and an instantaneous pumping rate of 5 cfs from the City’s river wells) because the alluvial deposits are thicker, and the well yields are typically higher in Well Site B compared to Well Site A.
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The GSI May 2021 memorandum concluded the Revised Project will have less impact than modeled because it will:
reduce the number of wells,
reduce the planned maximum annual pumping volume from 1,980 AFY to 1,368 AFY ( a 31 percent reduction), and
reduce the maximum instantaneous pumping rates from 5 to 2.84 cfs (a 43 percent reduction).

GSI Memorandum November 5, 2021 - Santa Ynez River Water Flows Under Three Scenarios Associated with City of Solvang’ s Revised River Wells Project GSI prepared a flow assessment memorandum November 5, 2021 titled “ Santa Ynez River Water Flows Under Three Scenarios Associated with City of Solvang’ s Revised River Wells Project” ( hereafter referred to as “ GSI November 2021 memorandum”) ( see Appendix B) that addressed the specific scenarios requested by the SWRCB Administrative Hearing Office (AHO) in its September 2, 2021 Order. Specifically, the AHO requested to receive evidence on the estimated flows for three scenarios: Existing ( Baseline) Conditions, conditions that are likely to occur if the City’ s Petition for Change Project is denied, and conditions that are likely to occur if the Petition for Change is granted (and the Revised Project is able to be implemented). Status Conference Order and Notice of New Status Conference and Planned Hearing Schedule, dated September 2, 2021. The GSI November 2021 memorandum analyzes estimated flows under these three scenarios. Specifically, the GSI November 2021 memorandum presents the data, analysis, and assumptions used to estimate surface water flow upstream of, adjacent to, and downstream of the City’ s existing and proposed points of diversion under existing and projected conditions.

A summary of the change of the river flow at Alisal Bridge under Scenarios 2(b) (which assume the City’s Petition for Change is denied) and 2(c) (which assume the City’ s Petition for Change is granted and the Revised Project is able to be implemented) relative to Existing (Baseline) Conditions is presented in Table

3.1-4: Summary of Santa Ynez River Flow at Alisal Bridge Relative to Baseline Conditions. Table 3.1-4 shows the average number of months in each water year (October 1 to September 30) type that exhibited reduced and higher flow at the Alisal Bridge, along with the average change in flow during those months.

These data are presented without climate change considered as the effects of climate change are discussed further below.

As presented on Table 3.1-4 and discussed in more detail in Appendix B, the calculated river flow at the Alisal Bridge was reduced in some months and higher in other months relative to the Existing ( Baseline) Conditions. During months when reduced flow would occur, the degree of this reduction of flow at the Alisal Bridge would be less under Scenario 2(c) Conditions ( which assume the City’ s Petition for Change is 355
granted and the Revised Project is able to be implemented) relative to Scenario 2(b) Conditions ( which assume the City’ s Petition for Change is denied). Likewise, this reduced flow would occur during fewer months under Scenario 2(c) Conditions) Conditions during Dry, Below Normal and Wet years; the number of months that would include reduced flow would be unchanged during Critical and Above Normal years.

Table 3.1-4
Summary of Santa Ynez River Flow at Alisal Bridge Relative to Baseline Conditions Petition for Change Denied (2b) Petition for Change Approved ( 2c) Water Year Type
Median Average
Daily Flow by Month
Increase / Decrease
Number of Months
Affected per Year1
Median Average
Daily Flow by Month
Increase / Decrease
Number of Months
Affected per Year1
Critical

0.4 cfs 7 - 0.1 cfs 7

0.2 cfs 1 + 0.2 cfs 2
Dry

0.3 cfs 3 - 0.1 cfs 2

1.5 cfs 7 + 1.5 cfs 7
Below Normal

0.3 cfs 6 - 0.2 cfs 5

1.1 cfs 5 + 1.0 cfs 7
Above Normal

0.4 cfs 3 - 0.2 cfs 3

12.5 cfs 9 + 11.2 cfs 9
Wet

0.4 cfs 8 - 0.2 cfs 7

1.8 cfs 4 + 1.9 cfs 4
Notes:
1 For any months unaccounted for during a given water year type, the median average daily flow by month is unchanged from baseline.

Tables 4 through 8 of Appendix B the specific months with during which increases or decreases in median average daily flow occur.

Conclusion of Scenario Comparisons
The GSI November 2021 memorandum concluded the results of these analyses indicate that during Above Normal and Wet years under both projected Scenarios 2(b) and 2(c), even under conservative assumptions, the planned diversions will not adversely affect streamflow at Alisal Bridge. 356
For all other water year types ( Critical, Dry, Below Normal), if the Petition for Change/ Revised Project were denied under Scenario 2(b), decreased flows at Alisal Bridge would occur compared to both Existing Baseline) Conditions and Scenario 2(c). This is because proposed monthly diversion volumes in Scenario 2(b) are typically greater than historical diversion volumes, and diversions that influence flow at the Alisal Bridge area are greater in Scenario 2(b) compared to Scenario 2(c).

Whereas, for water year types Critical, Dry, and Below Normal, if the Petition for Change were granted under Scenario 2(c), increased flows at Alisal Bridge would occur compared to both Baseline and Scenario 2(b) Conditions. Streamflow at the Lompoc Narrows under Scenario 2(c) may be slightly reduced (between

0.7 and 1.8 cfs on average) compared to both Baseline and Scenario 2(b) given the simplified assumptions used in this analytical approach that the City’s diversions from the Well Site B area directly reduce the downstream flows. It is well established, however, that there are other hydrologic considerations that may augment the downstream flow amounts or may contribute to streamflow loss between the City’s reach of diversion and the Lompoc Narrows.

Finally, based upon an analysis of changes to pumping curtailment days based on the operational criteria for the City’ s wells, Scenario 2(c) would result in fewer overall pumping curtailment days at Alisal Bridge compared to either Existing (Baseline) Conditions or Scenario 2(b) Conditions, indicating that Scenario 2(c) under which the City’s Petition for Change is granted) will cause less changes to river flows at Alisal Bridge than either the Existing (Baseline) Conditions or Scenario 2(b).

3.1.4 Comparison with the Potential Impacts in the Certified FEIR with the Revised Project
Since the Certified FEIR, Checklist Questions for Hydrology and Water Quality have been updated in the CEQA Guidelines Appendix G Checklist. To determine whether the Revised Project would result in new impacts or an increase in the severity of previously identified impacts as analyzed by the Certified FEIR, provided below is an update to the environmental information and analysis of the impacts of the Revised Project using the Hydrology and Water Quality Checklist Questions from the current CEQA Guidelines Appendix G Checklist.

3.1.4.1 Violate Any Water Quality Standards or Waste Discharge Requirements or Otherwise Substantially Degrade Surface or Groundwater Quality?
Construction Impacts
The Certified FEIR analyzed implementation of the Approved Project, which would occur over a span of 10 to 15 years. The Approved Project, which included six ( 6) new wells, would need 6 acre-feet or less 357
than 1 percent of Lake Cachuma storage capacity. Compared to the Approved Project, which would distribute more than an acre of land, the Revised Project would most likely disturb less than one acre of land. The Revised Project would be within the original footprint of the Approved Project and reduce construction of the number of wells (from six [ 6] to two [2] and no longer include the water treatment plant). For this reason, the City would most likely not be required to obtain a General Permit for discharges of storm water associated with construction activity associated with the Revised Project. The Certified FEIR identified the City would be required to implement a SWPPP, according to SWRCB requirements, which would implement construction and post-construction BMPs and monitoring plan to minimize discharge of pollutants in stormwater from the construction area and stormwater runoff and minimize the discharge of pollutants in stormwater from the construction area. In addition, the SWPPP must identify post-construction control measures and a monitoring plan. The Revised Project would implement these same measures. If the Revised Project disturbs more than one acre of land then it would be required to obtain a General Permit and implement a SWPPP. If the Revised Project disturbs less than one acre of land and a SWPPP under the General Permit is not required, the construction of the proposed wells under the Revised Project would be subject to the City’ s Stormwater Management Ordinance (Solvang Municipal Code Title 14) ( hereinafter the SWMO) and/ or applicable provisions of the Santa Barbara County’ s Stormwater Management and Discharge Control program ( Santa Barbara County Code, Title 29, Article IV) and grading permit requirements ( Santa Barbara County Code, Title 14). The City’s SWMO identifies construction BMPs as well as post-construction control measures and monitoring plan and would require an erosion and sediment control plan, or a SWPPP, for the Revised Project. The County code includes similar requirements.

As construction activities under the Approved Project were determined to be short term and temporary in nature and would not substantially degrade water quality, impacts of the Revised Project would be less than those identified in the Certified FEIR. The Certified FEIR determined construction activities under the Approved Project would not impact the exercise of any existing water right on the river. Because the footprint of the Revised Project is less than that of the Approved Project and within the original footprint analyzed under the Certified FEIR, impacts would be less than those identified in the Certified FEIR.

The Revised Project would result in less than significant groundwater quality impacts and no mitigation is required. With respect to water quality standards and waste discharge requirements during construction of the Revised Project, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR. 358
Impacts During Operation
Operation of the components of the Revised Project would involve the extraction of Santa Ynez River underflow and distribution through the City’ s municipal water system in the same fashion as the Approved Project, though through two wells (instead of six). The Certified FEIR stated Water extracted from the Santa Ynez River would be pumped to the proposed water treatment plant where it would be treated to CDPH standards for surface water treatment. Chemicals that would have been utilized at the treatment plant included a coagulant, such as aluminum sulfate, and liquid sodium hypochlorite for disinfection.

Water extracted from the Santa Ynez River would be pumped to the City’ s water distribution system.

While the Revised Project would not include a water treatment plant, water suitable for the City’s municipal use from the Revised Project wells would be diverted from the Santa Ynez River. The Certified FEIR determined impacts would be less than significant ( Class III) for the Approved Project; therefore, given the similar operational character ( river underflow extraction) but a smaller scale, impacts for the Revised Project would also be less than significant (Class III) and no mitigation is required. Therefore, with respect to water quality standards and waste discharge requirements during operation of the Revised Project, impacts would remain less than significant and the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

With regard to surface and groundwater quality, Well Sites A and B would be located within the Santa Ynez River 100-year floodplain. As a result, there would be times when the river is at higher flows when surface water could be located within 150 feet of a proposed well. However, based on DPH regulations, water cannot be produced from a well while surface water is within 150 feet unless the water is filtered and meets the standards of the Surface Water Treatment Rule.

Additionally, Stetson performed a water quality impact analysis for the Approved Project. The focus of this water quality analysis was on the total dissolved solids ( TDS) concentration of the Santa Ynez River flow at the Lompoc Narrows. The Approved Project would have increased diversions from the baseline condition of 1,053 AFY at an extraction rate of 1.85 cfs, to 1,980 AFY at a maximum extraction rate of 5 cfs of Santa Ynez River water. Stetson used the SYRHM model to analyze the potential impact of TDS concentrations of Santa Ynez River flows at the Lompoc Narrows under pumping conditions greater than the Approved Project (2,400 AFY which is greater than the proposed 1,980 AFY). According to the Stetson Engineers, the primary effect of the Approved Project on the flow at the Lompoc Narrows is a decrease in the early fall flows. However, this is the period in which the TDS concentrations the Santa Ynez River flows near Lompoc are high, so the impact on TDS concentrations in the Lompoc groundwater basin is minimal or none due to minor changes in loading (increased TDS concentrations associated with reduced flows).

In addition, water right releases would increase under the Approved Project compared to baseline 359
conditions, which would help improve water quality at the Lompoc Narrows. The average differences in TDS concentrations in the Lompoc groundwater basin would be very small relative to the total TDS levels in the Lompoc wells (800 to 2,500 mg/ L).

Consequently, the Certified FEIR concluded the Approved Project would result in less than significant impacts on surface water quality. As demonstrated by GSI’ s May 2021 memorandum the Revised Project will have less impact than the Approved Project because the Revised Project will:
reduce the number of wells,
reduce the planned maximum annual pumping volume from 1,980 AFY to 1,368 AFY ( a 31 percent reduction), and
reduce the maximum instantaneous pumping rates from 5 to 2.84 cfs (a 43 percent reduction).

As such, impacts would be less than those identified in the Certified FEIR and less than significant.

Therefore, with respect to surface and groundwater quality during operation of the Revised Project, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.1.4.2 Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin.

Construction Impacts
As noted in the Certified FEIR for the Approved Project, the Revised Project will include well drilling, completion, development, and testing at each well site. Work will likely be coordinated so that one well is being drilled while another is being developed and tested. Pump testing will occur immediately after well installation. The water lines and electrical conduits will be installed after well testing. The proposed well installation for the Revised Project will be completed in a similar manner in a phased approach ( see Section 2.4: Revised Project Construction, above).

As the well testing water is similar in nature to the surrounding environment, the Revised Project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge or 360
impede sustainable groundwater management of the basin. Impacts related to construction of the Revised Project would be less than significant and no mitigation is required. Therefore, with respect to groundwater supplies and recharge during construction of the Revised Project, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

Impacts During Operation
Under the Approved Project considered in the Certified FEIR, the City' s goal was to have a pumping capacity of 5 cfs from the Santa Ynez River to serve the City's peak demand. This would have been achieved by a combination of renovating Wells 3 and 7A, installing up to six new wells and, potentially, renovating and equipping Well 5. New wells would have been on the City’s SCADA system and run off of set points tied to reservoirs levels. System production will be dictated by demand on the system but the City would have been able to divert a maximum of 1,980 AFY.

As part of the Revised Project, the City is proposing to construct only two new wells and to have a maximum pumping capacity of 2.84 cfs and a maximum annual diversion of 1,368 AFY. The City is also now electing to cease production from Well 3 and Well 7A if flows at the Alisal Bridge ( as monitored by the USGS flow gage) drop below 1.5 cfs or if subsurface water flows drop below 360.3 as measured at the Alisal Ranch Well. Further, the City will not increase the existing production capacity of Well 7A and Well 3 above 200 gpm and 350 gpm, respectively. The City will also abandon its Well 7A and its existing reach of diversion upstream of the Alisal Bridge once the combined production capacity of Well 3 and any new downstream wells is at least 950 gpm or Solvang constructs two new wells in Site B or Solvang constructs two new wells in Well Site B. Furthermore, the City is opting to reduce it’s over all Reach of Diversion and shift it downstream.

The City maintains an easement for Well 5 (that was destroyed) but does not intend to reconstruct this well or use this well site under the Revised Project.

Changes reflected in the Revised Project were made to minimize possible river well pumping impacts to other upstream wells operated by Alisal Ranch and ID. No 1.

A summary of the relevant improvements to the Revised Project to the Certified FEIR Project considered in the Certified FEIR are summarized in Table 2.0-4.

As noted in the GSI May 2021 memorandum, based upon review of ( a) regulatory requirements as stipulated in the 2000 and 2019 BiOps and in Water Rights Order 2019-0148 and (b) technical analyses 361
conducted to evaluate various pumping scenarios as presented in Stetson’ s TM Nos 1 to 6, the Revised River Wells Project will have less effect on river conditions than the Approved Project evaluated in the Certified FEIR. Based on results of modeling summarized in Stetson Technical Memorandum No. 6, pumping from 4 new wells at Site B would not cause adverse effects on river flow conditions at Alisal Bridge. Because the Revised Project identifies only 2 new wells in Site B, pumping less volume per year at a lower maximum instantaneous pumping rate, the effects will be less than those identified in Stetson Technical Memorandum No. 6 and the Certified FEIR.

The Revised Project will have less impact on groundwater level than modeled because it will:
reduce the number of wells,
reduce the planned maximum annual pumping volume from 1,980 AFY to 1,368 AFY ( a 31 percent reduction), and
reduce the maximum instantaneous pumping rates from 5 to 2.84 cfs (a 43 percent reduction).

The Certified FEIR identified indirect environmental impacts due to water supply shortages, but found such impacts to be less than significant with implementation of Mitigation Measure HYD- 1. The City would implement Mitigation Measure HYD-1 under the Revised Project as well.

The revisions to the operation of Bradbury Dam implemented under WR-2019-0148 provide for continued flow to meet both water right diversion and requirements for fish under the 2000 BiOp. As such, the changes that the City is proposing under the Revised Project will not affect the overall operation of the River.

Operational impacts to groundwater supplies and recharge associated with the Revised Project would be less than significant and no new mitigation is required. Therefore, with respect to groundwater supplies and recharge during operation of the Revised Project, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR. 362

3.1.4.3 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 On- or Off-site; ( II) Substantially Increase the Rate or Amount of Surface Runoff in a Manner Which Would Result in Flooding On- or Off-site; (iii) Create or Contribute Runoff Water Which Would Exceed the Capacity of Existing or Planned Stormwater Drainage Systems or Provide Substantial Additional Sources of Polluted Runoff; or ( iv) Impede or Redirect Flood Flows.

Construction Impacts
The Approved Project considered in the Certified FEIR included both Well Sites A and B; both are located within a 100-year flood hazard zone. The Revised Project only includes wells located in Well Site B.

Construction of the components of the Revised Project (pipeline to connect to the City’ s water distribution system) located outside of the 100-year floodplain of the Santa Ynez River would not reduce stream flow sufficiently to substantially alter the existing drainage pattern of the site or area.

The Certified FEIR identified the City would be required to implement a SWPPP, according to SWRCB requirements, which would implement construction and post-construction BMPs and monitoring plan to minimize discharge of pollutants in stormwater from the construction area and stormwater runoff. The Certified FEIR concluded the water quality in the groundwater basin would not be altered and would not impair the beneficial uses, resulting in less than significant impacts to groundwater quality in the basin.

The Revised Project would be required to comply with the City’s SWMO and analogous Santa Barbara County requirements ( Santa Barbara County Code, Title 29, Article IV and Santa Barbara County Code, Title 14), as applicable, which would require implement construction and post-construction BMPs and an Erosion and Sediment Control Plan to minimize stormwater runoff. Therefore, the Revised Project would result in less than significant impacts.

The only components of the Revised Project that would have the potential to reduce stream flow during construction would be the proposed wells along the Santa Ynez River. The water treatment plant considered in the Approved Project is no longer a part of the Revised Project.

Construction components of the Revised Project located outside of the 100-year floodplain of the Santa Ynez River ( pipeline to connect to the City’ s water distribution system) would not reduce stream flow sufficiently or substantially alter the existing drainage pattern of the site or area. Portions of areas of proposed Well Site B of the Revised Project are within the City’s jurisdiction are located within a 100-year flood hazard zone. As a result, proposed well heads and surface infrastructure have the potential to be 363
damaged by river flows during a 100-year flood event. Construction of the two (2) wells proposed under the Revised Project would require access by construction equipment, trucks, and a drilling rig.

Loss of production in future wells would limit the City’ s ability to provide its residents adequate water supplies. Consequently, any wells constructed within the designated floodplain would need to be protected from potential flood damage. Without proper protection impacts from the Revised Project similar to the Approved Project) would be potentially significant. The Certified FEIR stated the Approved Project would implement Mitigation Measure HYD-2. The Revised Project would also implement Mitigation Measure HYD-2 to minimize flood damage to wells within a 100-year floodplain. With implementation of Mitigation Measure HYD-2 during construction, the impacts from the Revised Project would be reduced to less than significant levels and no new mitigation is required. Therefore, with respect to impeded or redirected flood flows, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

According to the City’ s Municipal Code Flood Control Chapter ( Title 13) the Revised Project would be required to design the proposed wells to minimize or eliminate infiltration of floodwaters to the systems and discharge from the systems into floodwaters. Therefore, impacts related to the potential for water infiltration are less than significant. The Revised Project does not provide for any housing, as such no housing would be placed in the 100-year flood zone. Consequently, any wells constructed within the designated floodplain would need to be protected from potential flood damage. There would be no impact.

Similar to the process described in the Certified FEIR for the Approved Project, access to the new wells to be constructed under the Revised Project would be provided by existing roadways along the north side of the river channel. Existing informal dirt roads on the floodplain would also be used to access wells. At each well site, a 2,500-square-foot area (about 50 by 50 feet) will be cleared and graded to a flat surface. It may be necessary for construction trucks to also park along the existing dirt roads temporarily at each well site. The construction timeframe of the two wells under the Revised Project is temporary and short term in nature and will be completed when water flow is low.

Therefore, the construction of the river wells considered under the Revised Project would not sufficiently reduce stream flow to the Santa Ynez River or substantially alter the existing drainage pattern of the site or area. Impacts would be less than significant and no mitigation is required. Therefore, with respect to existing drainage patterns during construction of the Revised Project, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, 364
and no new information of substantial importance has been identified that would require preparation of an EIR.

Impacts During Operation
To determine potential impacts to the flow of the Santa Ynez River, a hydrologic analysis was completed by GSI as noted their technical memoranda dated May 2021 and November 2021.

As noted in the GSI May 2021 memorandum, the Revised Project, the extraction of underflow from the Santa Ynez alluvium has been refined compared to that of the Approved Project considered in the Certified FEIR. Changes reflected in the Revised Project were made to minimize possible river well pumping impacts to other upstream wells operated by Alisal Ranch and ID. No 1. The City has elected to make the following modifications:

Utilizing only the proposed change in the Reach of Diversion previously discussed in the Certified FEIR downstream to solely use in Well Site B (minimizes impacts to Alisal Ranch and ID No. 1 River wells), Decreasing the original request for the length of Reach of Diversion discussed in the Certified FEIR from 19,500 feet to 8,060 feet,
Limit volume of planned river well pumping to its historical maximum annual diversion (from 1,980 to 1,368 AFY),
Limiting proposed maximum diversion rate to 2.84 cfs from 5 cfs as discussed in the Certified FEIR, and
Following the installation of two wells proposed for Well Site B, the City will abandon Well 7A as originally proposed in the Certified FEIR.

A summary of the relevant improvements to the Revised Project to the Approved Project considered in the Certified FEIR are summarized in Table 2.0-4. The components of the Revised Project would occur within the analyzed footprint of the Approved Project considered in the Certified FEIR.

Based upon review of (a) regulatory requirements as stipulated in the 2000 BiOp and 2019 BiOp and in Water Rights Order 2019-0148 and ( b) technical analyses conducted to evaluate various pumping scenarios as presented in Stetson Technical Memoranda Nos 1 to 6, the Revised Project will have less effect on river conditions than the Approved Project evaluated in the Certified FEIR. Based on results of modeling summarized in Stetson Technical Memorandum No. 6, pumping from four (4) new wells at Well Site B would not cause adverse effects on river flow conditions at Alisal Bridge. Because the Revised Project identifies only two (2) new wells in Well Site B, pumping less volume per year at a lower maximum instantaneous pumping rate, the effects will be less than those identified in Stetson Technical Memorandum No. 6 and the Certified FEIR.
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The modeling results from Stetson Technical Memorandum No. 6 indicate that the Santa Ynez River alluvium in Well Site B would be able to meet both the planned monthly average and peak demands of the City under the Approved Project (at the time of the Stetson Technical Memorandum No. 6, the City’s demands were based on a combined annual rate of 2,400 AFY and an instantaneous pumping rate of 5 cfs from the City’ s river wells) because the alluvial deposits are thicker, and the well yields are typically higher in Well Site B compared to Well Site A.

GSI found the Revised Project will have less effect than modeled because the Revised Project will:
reduce the number of wells,
reduce the planned maximum annual pumping volume from 1,980 AFY to 1,368 AFY ( a 31 percent reduction), and
reduce the maximum instantaneous pumping rates from 5 to 2.84 cfs (a 43 percent reduction).

In its November 2021 report GSI analyzed future surface water flow conditions to estimate the flow conditions that are likely to occur if the State Water Board denies Solvang’ s Petition for Change ( 2(b); and if the State Water Board grants Solvang’ s Petition for Change ( 2(c)).

As discussed in more detail in Appendix B, during Above Normal and Wet years, even under the conservative assumptions employed by GSI, the planned diversions under the Revised Project will not adversely affect streamflow at the Alisal Bridge. For Critical, Dry, and Below Normal years increase flows would occur at the Alisal Bridge under the Revised Project (compared to the baseline and scenario 2(b) if the City’ s Petition were denied). Flows at the Lompoc Narrows under the Revised Project would be slightly reduced when compared to the baseline and scenario 2(b) due to the very conservative assumptions made in GSI’ s report. However, given the distance from the Narrows, other hydrological considerations are likely responsible for the flow levels at the Lompoc Narrows. Finally, based on an analysis of when pumping would need to be curtailed under each scenario, the Revised Project will cause less changes to the river flows at the Alisal Bridge than either the baseline or scenario 2(b).

Based on the above analysis the Revised Project operations will not substantially alter existing drainage patterns or the site or area or alter the course of the river. Impacts associated with the Revised Project would less than significant and no mitigation is required. Therefore, with respect to existing drainage patterns during operation of the Revised Project, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR. 366

3.1.4.4 In Flood Hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
The Revised Project is not in an area subject to seiches or tsunamis. Portions of areas of proposed Well Site B of the Revised Project are within the City’ s jurisdiction are located within a 100-year flood hazard zone. According to the City’ s Municipal Code Flood Control Chapter, 108, the Master Plan Update would be required to design the proposed wells to minimize or eliminate infiltration of floodwaters to the systems and discharge from the systems into floodwaters. Therefore, impacts related to the potential for water infiltration are less than significant. Therefore, with respect flood hazard, tsunami or seiche zones, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.1.4.5 Conflict with or Obstruct Implementation of a Water Quality Control Plan or Sustainable Groundwater Management Plan
This Checklist question was not in the CEQA Guidelines Appendix G Checklist questions at the time for the Certified FEIR.

Construction
As discussed, the Revised Project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge or impede sustainable groundwater management of the basin.

Impacts related to construction of the Revised Project would be less than significant and no mitigation is required. Construction of the Revised Project would not conflict with the City, State, or local plans and regulations discussed in Section 3.1.3, above. The Santa Ynez River Valley Eastern Management Area Groundwater Sustainability Plan, which describes the Santa Ynez River Valley Eastern Management Area’ s physical setting, quantifies historical, present, and future water budgets, develops quantifiable management objectives that account for the interests of the EMA’ s beneficial groundwater uses and users, and identifies a group of projects and management actions that will allow the EMA to maintain or achieve sustainability within 20 years of plan adoption, 39 is currently in draft form. There are no other sustainable groundwater management plans relevant to the Revised Project site. Therefore, with respect to conflicting or obstructing the implementation of a water quality control plan or sustainable groundwater management plan during construction of the Revised Project, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant 39 Santa Ynez River Valley Groundwater Basin Eastern Management Area Groundwater Sustainability Agency, Public Draft Santa Ynez river Valley Groundwater Basin – Eastern Management Area Groundwater Sustainability Plan, https:// www. santaynezwater. org/ files/ 4352737ed/ EMA+GSP+ Public+ Draft+2021-09-08+with+hyperlinks. pdf, Accessed December 2021.
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impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

Impacts During Operation
Operational impacts to groundwater supplies and recharge associated with the Revised Project would be less than significant and no new mitigation is required as discussed in Section 3.1.4.2. Operation of the Revised Project, would not conflict with the City, State, or local plans and regulations described in Section

3.1.3, above. As discussed above, the Santa Ynez River Valley Eastern Management Area Groundwater Sustainability Plan is currently in draft form. There are no other sustainable groundwater management plans relevant to the Revised Project site. Therefore, with respect to conflicting or obstructing the implementation of a water quality control plan or sustainable groundwater management plan during operation of the Revised Project, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.1.4.6 Cumulative Impacts
To evaluate cumulative impacts, the Certified FEIR and this Addendum examined existing and proposed water diversions within the Santa Ynez River from Bradbury Dam to the Highway 101 Bridge in Buellton.

Impacts caused by other water diversions within the stretch of the river could potentially combine with the Revised Project to create cumulative impacts. These impacts include potential effects on river hydrology, groundwater hydrology, water quality, soil erosion (due to increased application and runoff of irrigation water), and aquatic resources supported by river surface flow and subterranean flow.

SWRCB’ s files list the existing water rights and pending applications within the watershed, along with the date, amount, location, type, and status of the application, claim, or registration ( see Table 2.0-5).

The Revised Project, as with the Approved Project evaluated in the Certified FEIR, would result in less than significant project level impacts with respect to hydrology and water quality. Cumulative impacts within the City limits were analyzed upon full General Plan buildout conditions. To evaluate cumulative impacts, this Addendum examined baseline and proposed water diversions within the Santa Ynez River from Bradbury Dam to the 101 bridge in Buellton.
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Water Rights
The Settlement Agreement of 2002 is still in place and ensures that rights of water users downstream of the Bradbury Dam will be protected. As discussed in Section 3.1.3, above, the Permits that were amended under the SWRCB Order WR-2019-0148 include within the authorized place of use all lands within the Cachuma Member Units’ service areas, and a net of 40,250 irrigable acres within a gross area of 205,376 acres. For this reason, the operation of the river under WR-2019-0148 remains essential with regards to downstream diversion including the City. Additionally, at present as a result of Cachuma Order WR-2019- 0148 Term 18 Plan, there are no current or planned reductions to the Cachuma Project’ s safe and operational yield that would reduce downstream river flows and affect downstream water right holders.

Therefore, just as under the Certified FEIR, cumulative water rights impacts from the Revised Project would be considered less than significant.

Surface Water Hydrology
As discussed in Section 3.1.3.4, above, the GSI November 2021 memorandum estimated flows for three scenarios: Existing (Baseline) Conditions, conditions that are likely to occur if the City’s Petition for Change Project is denied Scenario 2(b), and conditions that are likely to occur if the Petition for Change is granted and the Revised Project is able to be implemented Scenario 2(c)). As Scenario 2(b) and 2(c) include future conditions with and without the Revised Project and no new claims have been added to the SWRCB files for the Santa Ynez River along the Santa Ynez River since the time of the Certified FEIR, these scenarios take into account related projects and cumulative impacts. As presented in Table 3.1-4, the calculated river flow at the Alisal Bridge was reduced in some months and higher in other months relative to the Existing ( Baseline) Conditions. During months when reduced flow would occur, the degree of this reduction of flow at the Alisal Bridge would be less under Scenario 2(c) Conditions ( which assume the City’ s Petition for Change is granted) relative to Scenario 2(b) Conditions ( which assume the City’s Petition for Change is denied). Likewise, this reduced flow would occur during fewer months under Scenario 2(c) Conditions during Dry, Below Normal and Wet years; the number of months that would include reduced flow would be unchanged during Critical and Above Normal years.

Cumulative surface water hydrology impacts would be less than significant. Therefore, with respect to cumulative surface water hydrology, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR. 369
Groundwater Hydrology
The Certified FEIR stated average dewatered groundwater storage in the Above Narrows Aquifer would increase with implementation of the Approved Project as evaluated in the Certified FEIR. This would also occur with implementation of the Revised Project but, because the Revised Project is a scaled down version of the Approved Project, the increase would not be as high as that under the Approved Project.

Under cumulative conditions, surface water flows would increase during the summer and early fall months as a result of additional water right releases. These additional flows would allow for groundwater river alluvial) recharge and percolation into the alluvial aquifers along the river.

As previously noted, analysis and comparisons of Santa Ynez River streamflow conditions were conducted for three water use scenarios: 1) Baseline river conditions, 2) calculated river conditions if the City’s Petition for Change were denied, and 3) calculated river conditions if the City’s Petition for Change were granted. Based on the availability of data, the period between water years 2003 and 2020 was chosen to represent the Existing (Baseline) flow conditions near and downstream of the City’ s existing and proposed diversion facilities.

The results of these analyses indicate that during Above Normal and Wet years under both projected scenarios, even under conservative assumptions, the planned diversions will not adversely affect streamflow at Alisal Bridge.

0.7 and 1.8 cfs on average) compared to both Baseline and Scenario 2(b) (Petition for Change denied) Conditions given the simplified assumptions used in this analytical approach that the Solvang diversions from the Well Site B directly reduce the downstream flows.

Finally, based upon the analysis of changes to pumping curtailment days, Scenario 2(c) would result in fewer overall pumping curtailment days at Alisal Bridge compared to either Baseline or Scenario 2(b) Conditions, indicating that Scenario 2(c) will cause less changes to river flows at Alisal Bridge than either the Baseline or Scenario 2(b).

Therefore, cumulative impacts to stream flows would be less than significant. With respect to groundwater hydrology, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR. 370
Water Supply
As indicated in the Certified FEIR for the Approved Project, critical dry and drought periods would result in shortages in water supply from the Cachuma Project to Member Units. The Certified FEIR determined the Approved Project resulted in similar water supplies within Lake Cachuma compared to baseline conditions. However, shortages would still occur with or without the implementation of the Approved Project.

During Critical years, historical (Baseline) median flows at the Alisal Bridge gauge ranged from no flow in May, June, and July to 53.4 cfs in August. The estimated median flows at the Alisal Bridge under Scenario 2(b) Conditions ( conditions that are likely to occur if the SWRCB denies the City’ s Petition for Change) would be slightly lower than Baseline condition flows, by approximately 0.2 cfs on average. The estimated median flows at Alisal Bridge under Scenario 2(c) would be roughly the same as Existing ( Baseline) flows.

At the Lompoc Narrows, the median flows were lower than at the Alisal Bridge during Existing ( Baseline) Conditions. Historical median flows at the Narrows were highest during March, August, and September when flows were between 4.4 and 9.9 cfs; during the other months, the flow was between 0 and 1.2 cfs.

Under Scenario 2(b) Conditions, median flows at the Narrows would be slightly lower than Baseline flows, by approximately 0.1 cfs on average. Under Scenario 2(c) Conditions ( conditions that are likely to occur if the SWRCB grants the City’ s Petition for Change), the median flows would be further reduced, by approximately 0.7 cfs on average.

Under climate change conditions, the median flows at both streamflow gauges are estimated to be approximately 4 percent lower than estimated flows under normal (current) Conditions for both scenarios 2(b) and 2(c). As such, the Revised Project would not result in increased impacts compared to the Approved Project and cumulative impacts would be less than significant. Therefore, with respect to water supply, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.1.5 Revisions to Mitigation Measures
As discussed above, the mitigation measures identified in the Certified FEIR would be implemented with the Revised Project but no new mitigation measures are required. The following Certified FEIR mitigation measures will be imposed for the Revised Project:
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HYD-1 The Water Division of the Public Works Department of the City of Solvang will actively advertise, promote, and implement their Water Management Program to conserve water, reduce consumption and the need for water pumping during summer and fall, and during droughts.

HYD- 2 New wells constructed located within the 100-year floodplain shall be adequately anchored and constructed to resist flood damage. Wells shall be equipped with a watertight casing that extends from 1 foot above grade to 20 feet below grade. The casing could be ductile iron pipe which would be strong enough to resist debris impact or a commercially available protective well cover (e.g., metal boxes or cylinders).

3.1.6 Determination of the Potential Significance of Impacts Environmental impacts associated with the Revised Project would be less than significant with mitigation from the Certified FEIR incorporated.

Mitigation measures identified in the Certified FEIR shall be implemented for addressing potential impacts related to water conservation and floodplain damage and stormwater runoff (Mitigation Measures HYD1 and HYD-2) would reduce any impacts to less than significant.

Based on the above analysis, with respect to hydrology, water supply and water quality, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified.

3.2 TERRESTRIAL BIOLOGICAL RESOURCES

3.2.1 Summary of Analysis in the Certified FEIR
The Certified FEIR noted that new well locations proposed as part of the Approved Project are largely in a natural condition, and the proposed water treatment plant location is partially developed and supports disturbed vegetation. Potentially significant impacts associated with the Master Plan Update are those relating to listed and non-listed special-status species, sensitive natural communities and regulated waters, and native wildlife nursery sites ( nesting birds and bat roosts). The Master Plan Update design features avoid direct impacts to surface waters and incorporate containment methods to protect water quality. In conjunction with the Master Plan Update design features, mitigation measures are proposed to reduce potential impacts to levels that are less than significant ( Class II). All other impacts are less than significant ( Class III).
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3.2.1.1 Have a substantial adverse effect, either directly or through habitat modification, on any species identified as endangered, rare, or threatened, as listed in Title 14 of the California Code of Regulations Section 670.2 or 670.5) or Title 50 of the Code of Federal Regulations Sections 17.11 or 17.12).

Construction Impacts
The Certified FEIR database searches identified 30 sensitive plant species and 20 sensitive wildlife species in the area of the Approved Project. The Certified FEIR noted that impacts of listed plant species would not occur because no listed plant species are expected to occur within the Approved Project well sites including the proposed locations ( Well Sites A and B) for the new wells or water treatment facility.

However, plant species can become established subsequent to the Project inventory surveys, so periodic update surveys are required. The listed wildlife species with the potential to occur within the Approved Project area include least Bell’s vireo, California red-legged frog, and southwestern willow flycatcher.

Potential impacts to these species would be mitigated to a less than significant level, where these species could occur for breeding activities.

The Certified FEIR identified state and federally listed Rare, Threatened, and Endangered species known or having potential to be present within the Santa Ynez River 100-year floodplain within which well and pipeline construction are proposed, including California red-legged frog, southwestern willow flycatcher, and least Bell’ s vireo.

The Certified FEIR stated southwestern willow flycatcher and least Bell’s vireo are not expected to nest on site, as existing riparian vegetation is confined to a narrow band along the river and an isolated remnant within the gravel mining operation in proposed Well Site B, neither of which are extensive enough to support breeding by these species. Nevertheless, the Certified FEIR found suitable habitat is present south of proposed Well Sites A and B, and transient and foraging individuals may utilize the Approved Project site periodically. During construction and site preparation activities, individuals of southwestern willow flycatcher and least Bell’s vireo within habitat proposed for conversion, if present, could be expected to displace the remaining undisturbed habitats on site, or immediately adjacent off site. However, given the minimal amount of potential habitat that may exist, the Certified FEIR concluded impacts to these species would be considered less than significant.

Construction and site preparation activities could result in the direct loss of adult California red-legged frogs; this loss would be considered a substantial effect on this species and, therefore, a potentially significant impact. Depending on the number and extent of individuals of other special- status species or their denning or nesting sites on the Approved Project site that may be disturbed or removed through 373
Approved Project implementation, their loss would be considered a substantial effect on these specialstatus species and, therefore, a significant impact. Implementation of Certified FEIR Mitigation Measures TER-1 through TER-7 would reduce direct impacts related to mortality of adult California red-legged frogs to a less than significant level (Class II). Indirect impacts to aquatic habitats used by larval and juvenile red-legged frogs related to site preparation and construction activities would also be reduced to a level of less than significant with the implementation of Certified FEIR Mitigation Measures TER 1 through TER 7 (Class II).

The Certified FEIR stated that should well and pipeline construction impact special- status species, depending on the number and extent of individuals of other special- status species or their denning or nesting sites that may be disturbed or removed through project implementation, their loss would be considered a substantial impact on the regional populations of these special- status species and, therefore, impact could be potentially significant. Implementation of Certified FEIR Mitigation Measures TER-8 and TER-9 would reduce impacts to a level of less than significance.

Potential indirect impacts to special- status aquatic species related to stormwater runoff and construction activities would be reduced through the implementation of the SWPPP and BMPs, which would result in less than significant water quality impacts (Class III).

Resources and species that are dependent on current water releases ( i.e., riparian vegetation that is directly related to surface water availability) would not experience impact because Reclamation will continue water releases to downstream of the proposed Project area. Impacts would be less than significant.

Impacts During Operation
Operational impacts associated with the wells and treatment plant are related to noise, lighting, and access to the well sites by City personnel. Noise associated with the Approved Project is discussed in Section 5.9 of the Certified FEIR. Wells would use submersible pumps, noise from which is negligible, and far below that of the current background levels. Night lighting would not be installed on the wells, and maintenance and monitoring of the wells would be conducted by City staff during daylight hours, accessing the sites along existing dirt roads. These impacts are therefore considered less than significant.

The proposed water treatment plant to be located within the Alisal Commons open space area would be outside of any appropriate habitat areas for either southwestern willow flycatcher, least Bell’s vireo, or California red-legged frog. These impacts are therefore considered less than significant. 374
The Certified FEIR stated the water diversion of up to 1,980 AFY above the baseline of 1,053 AFY could modify habitat for California red-legged frog, a species that is dependent upon the riparian resources found along the Santa Ynez River. Other listed species that could make use of the riparian resources of the river include the southwestern willow flycatcher and least Bell’s vireo. The extraction of groundwater underflow of the Santa Ynez River associated with well pumping would create local depressions in the groundwater levels. If the water levels were to drop below the root zone of the riparian vegetation for an extended period ( of a year or more), these plants could become stressed and could eventually die.

However, the Certified FEIR determined the hydrological model of Stetson Engineers 40 for water extraction of 2,400 AFY indicate the water drawdown, when the Santa Ynez River experiences no river or other inflows in the area, would be localized within about 3,000 feet of the well site and would lower the groundwater level a maximum of 9 feet; the 9-foot drawdown is within the historical groundwater level fluctuation. Therefore, riparian resources are not expected to be affected by the water diversion of up to 1,980 AFY. Impacts would be less than significant.

A second type of potential impact from the operation of the proposed Master Plan Update is indirect impacts of the increased water diversions from the Santa Ynez River. The analysis of the Master Plan Update was limited to least Bell’ s vireo and impacts were found to be mitigated to a less than significant impact. Additional listed terrestrial species analyzed in this document include California red-legged frog, and southwestern willow flycatcher. Listed fish species are discussed in Section 5.3: Fisheries Resources of the Certified FEIR. The water diversion of up to 1,980 AFY above the baseline of 1,053 AFY could modify habitat for California red-legged frog, a species that is dependent upon the riparian resources found along the Santa Ynez River. Other listed species that could make use of the riparian resources of the river include the southwestern willow flycatcher and least Bell’ s vireo. The extraction of groundwater underflow of the Santa Ynez River associated with well pumping would create local depressions in the groundwater levels.

If the water levels were to drop below the root zone of the riparian vegetation for an extended period (of a year or more), these plants could become stressed and could eventually die. However, the hydrological model of Stetson Engineers 41 for water extraction of 2,400 AFY indicate the water drawdown, when the Santa Ynez River experiences no river or other inflows in the area, would be localized within about 3,000 feet of the well site and would lower the groundwater level a maximum of 9 feet ( see Table 5.1-5 in Section 5.1 of the Certified FEIR); the 9-foot drawdown is within the historical groundwater level 40 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge (see Appendix 5.1 of the Certified FEIR).
41 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge ( see Appendix 5.1 of the Certified FEIR).
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fluctuation. Therefore, riparian resources are not expected to be affected by the water diversion of up to 1,980 AFY. Impacts would be less than significant.

The Certified FEIR identified proposed mitigation measures would reduce impacts to less than significant.

3.2.1.2 Have a substantial adverse effect, either directly or through habitat modification, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the USFWS or California Department of Fish and Game ( CDFG).

Construction Impacts
The Certified FEIR stated there are no applicable local or regional plans that reference any candidate, sensitive or special- status species in the Approved Project area.

Proposed Wells and Water Treatment Plant
The Certified FEIR concluded potential impacts of well and pipeline installation would not directly affect aquatic species, including wetland- obligate plant species, as well and pipeline installation are not proposed for areas within the active channel or associated ponds and wetlands of the Santa Ynez River.

Hence direct impacts to Sonoran maiden fern, Bolander' s water-hemlock, Coulter' s goldfields, chaparral ragwort, and California sawgrass would not occur.

Non-listed special status species known or having potential to be present within the 100-year floodplain of the Santa Ynez River, within which well and pipeline construction are proposed, at the time of the Certified FEIR include the following: Santa Ynez groundstar, dwarf calycadenia, mesa horkelia, Southern California black walnut ( observed on site at the time of the Certified FEIR), Santa Barbara honeysuckle, Hoffmann' s bitter gooseberry, and Hoover' s bent grass, Foothill yellow-legged frog, Coast Range newt, silvery legless lizard, western pond turtle, two-striped garter snake ( observed on site), Cooper’ s hawk, Southern California rufous- crowned sparrow, oak titmouse ( observed on site), ferruginous hawk, pallid bat, and American badger. Implementation of Certified FEIR Mitigation Measures TER-1 – TER-7 would reduce direct impacts related to mortality of non-listed special- status animal species, except for bats, to a level of less than significant ( Class II).

The Certified FEIR stated well and pipeline installation is proposed within the 100-year floodplain and could therefore adversely affect certain special- status species as discussed below.

Santa Ynez groundstar ( CNPS Rank 1B.1), dwarf calycadenia ( CNPS Rank 1B.1), mesa horkelia ( CNPS Rank 1B.1), Santa Barbara honeysuckle ( CNPS Rank 1B.2), Hoover' s bent grass (CNPS Rank 1B.2)— Each of these 376
species may potentially be present within habitats to be impacted by development of the wells in Wells Sites A and B as proposed in the Master Plan Update. CNPS Rank 1B species are rare throughout their range with the majority of them endemic to California. All of the plants constituting Rank 1B meet the definitions of Section 1901, Chapter 10 (Native Plant Protection Act) or Sections 2062 and 2067 (California Endangered Species Act) of the California Department of Fish and Game Code, and are eligible for state listing. Impacts would be potentially significant. Implementation of Certified FEIR Mitigation Measure TER-8 would reduce impacts to special- status plant species potentially occurring in non-aquatic habitats to a level of less than significant ( Class II). Indirect impacts to special status plan species related to site preparation and construction activities would be reduced to a level of less than significance.

Hoffmann' s bitter gooseberry ( CNPS Rank 3) and Southern California black walnut (CNPS Rank 4.2) could also be adversely affected by the well and pipeline installation at the time of the Certified FEIR. The Certified FEIR determined City’s General Plan does not provide policy direction for the treatment of Rank 3 or Rank 4 plants. However, the loss of Hoffman’ s bitter gooseberry or any Southern California black walnut would be considered a potentially significant impact.

The Certified FEIR identified five special- status animal species— two-striped garter snake ( Thamnophis hammondii), great egret ( Ardea alba), great blue heron ( A. herodias), oak titmouse ( Baeolophus inornatus), and snowy egret (Egretta thula)— on site at Well Sites A and B during the October 2011 survey.

The great egret, snowy egret and great blue heron are not expected to nest in the area of Well Sites A and B. Additionally, the oak titmouse would not nest within the sparse riparian vegetation along the reach of the Santa Ynez River found in the area of Well Sites A and B. Construction impacts to these species would be significant if present in the Well Sites A and B or the water treatment facility.

During construction and site preparation activities for well drilling, installation and pipeline construction, individuals of some special- status species of high mobility such as non-breeding individuals of Cooper’ s hawk, Southern California rufous-crowned sparrow, oak titmouse, and ferruginous hawk present within habitat within Well Sites A and B could be displaced to remaining undisturbed habitats nearby. However, construction and site preparation activities could result in the direct loss of active bird nests, including eggs, young, or incubating adults, and a variety of other less mobile special- status species, including foothill yellow-legged frog, Coast Range newt, silvery legless lizard, western pond turtle, two-striped garter snake, pallid bat, and American badger.

Depending on the number and extent of individuals of other special- status species or their denning or nesting sites on the site that may be disturbed or removed through project implementation, their loss would be considered a substantial effect on these special- status species and, therefore, a significant impact. Implementation of Certified FEIR Mitigation Measures TER- 1 – TER- 7 would reduce direct impacts 377
related to mortality of non-listed special- status animal species, except for bats, to a level of less than significant (Class II). implementation of Mitigation Measure TER-9 would reduce impacts to special- status bat species to a level of less than significant ( Class II). Indirect impacts to wildlife species, including bats, related to site preparation and construction activities would be reduced to a level of less than significant Class II).

Impacts During Operation
The Certified FEIR stated operational impacts related to implementation of the Master Plan Update are related to land uses anticipated in the City’ s General Plan that would be achievable given the additional water availability called for in the Master Plan Update. Impacts of development on non-listed specialstatus species are analyzed above under construction impacts.

As discussed above, five special- status animal species— two-striped garter snake ( Thamnophis hammondii), great egret ( Ardea alba), great blue heron ( A. herodias), oak titmouse ( Baeolophus inornatus), and snowy egret (Egretta thula)— were observed on site at Well Sites A and B during the October 2011 survey. The Certified FEIR determined the great egret, snowy egret and great blue heron are not expected to nest in the area of Well Sites A and B. Additionally, the oak titmouse would not nest within the sparse riparian vegetation along the reach of the Santa Ynez River found in the area of Well Sites A and B. Impacts to these species would be less than significant from the operation of new water wells adjacent to the Santa Ynez River downstream of Alisal Bridge. The Certified FEIR also concluded the diversion of up to 1,980 AFY with a maximum extraction rate of up to 5 cfs would not significantly impact non-listed terrestrial special- status species because the hydrology modeling of Stetson Engineers 42 indicates that groundwater elevation levels would remain similar to the baseline levels.

The Certified FEIR determined long-term operation of the proposed new wells is expected on average, to result in similar groundwater levels to the baseline of 1,053 AFY based on the modeling analysis by Stetson Engineers. 43 Operational impacts to non-listed terrestrial special- status species from the extraction of 1,980 AFY at an extraction rate of up to 5 cfs, an increase of 927 AFY, over the baseline of 1,053 AFY at a rate of 1.85 cfs would be less than significant. The Certified FEIR identified operational impacts associated with the proposed new wells and treatment plant to be related to noise, lighting, and access to the well sites by City personnel. Noise associated with the Approved Project is discussed in Section 5.9 of the 42 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge (see Appendix 5.1 of the Certified FEIR).
43 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge ( see Appendix 5.1 of the Certified FEIR).
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Certified FEIR and Section 3.9 of this Addendum. As discussed above in Section 3.2.1.1 and under Threshold 5.2.6.1 in the Certified FEIR, indirect impacts would be less than significant.

3.2.1.3 Reduce the Number or Restrict the Range of an Endangered, Rare, or Threatened Species.

Construction Impacts
The Certified FEIR found the development allowed under the Master Plan Update is not expected to result in the restriction in range of any special- status species, because the projects under the Master Plan Update would take place primarily within areas that are currently developed or disturbed and that do not support habitat for special- status species. Potential impacts to the range of special- status species from the Master Plan Update would be less than significant. Construction and site preparation activities for the proposed wells and water treatment facilities could result in impacts to special- status species. The listed wildlife species with the potential to occur within the Approved Project area include least Bell’s vireo, California red-legged frog, and southwestern willow flycatcher. Impacts to these species that could occur.

However, implementation of Certified FEIR Mitigation Measures TER-1 through TER-7 would reduce potential impacts from construction of the Approved Project to special- status aquatic species potentially resulting in regional reductions in their populations or restrictions in their range. Indirect impacts to special- status aquatic species related to stormwater runoff and construction activities would be reduced through the implementation of the SWPPP and BMPs, which would result in less than significant water quality impacts (Class III).

Impacts During Operation
One type of operational impact of the Master Plan Update is land use anticipated in the City’s General Plan that would be achievable given the additional water supply reliability called for in the Certified FEIR Project. The Certified FEIR stated impacts of development on listed species allowed under the City’s General Plan have been previously analyzed as part of the General Plan environmental review.

A second type of potential impact from the operation of the Master Plan Update is indirect impacts of the increased water diversions from the Santa Ynez River. The Certified FEIR determined, based on modeling from Stetson Engineering, that long-term operation of the new wells proposed under the Approved Project would not substantially modify the groundwater levels, and therefore potential indirect impacts of the Approved Project from increased water diversion would not significantly reduce the number or restrict the range of an endangered, rare or threatened species and impacts would be less than significant. 379

3.2.1.4 Effect on Riparian Habitat or Other Sensitive Natural Communities Construction Impacts
Projects proposed under the Master Plan Update would take place primarily within areas that are currently developed or disturbed by residential, commercial or agricultural uses. Additionally, General Plan policies require that new development prioritizes the preservation of riparian and sensitive natural communities. Nevertheless, certain land uses that may be permissible under both the City’s and County’ s General Plans could require encroachment into riparian or other sensitive natural communities. Such impacts are potentially significant but they would be subject to the permitting requirements of state and federal agencies. The applicable permits would require appropriate mitigation if those independent projects go forward. Therefore, the Certified FEIR determined the increased Solvang diversions will not have significant impacts to jurisdictional waters, streambeds, or sensitive natural communities.

Proposed Wells and Water Treatment Plant
For the six (6) new wells proposed in the Approved Project, each wellhead will be placed at an elevation that is within the 100-year flood level but above the ordinary high-water mark of stream courses.

Locations for individual wells within Well Sites A and B were not determined at the time of the Certified FEIR, and could potentially be located within California buckwheat – California broomsage, willow thicket, or black cottonwood forest vegetation within CDFW jurisdiction. Well Site A is located within the City’s jurisdiction while Well Site B is located in unincorporated Santa Barbara County.

Construction of the wells would require access by construction equipment, trucks, and a drilling rig. Access to the new wells would be provided by existing roadways along the north side of the river channel. Existing informal dirt roads on the floodplain also would be used to access wells. Wells would not be accessed from the west because the bridge over Alamo Pintado Creek is not rated for large trucks or drilling rigs.

At each well site, a 2,500-square-foot area (about 50 by 50 feet) would be cleared and graded to a flat surface. The well would be installed within this area, which would also be used for the drilling rig, stockpiling, and other equipment parking. It may be necessary for construction trucks to also park along the existing dirt roads temporarily at each well site.

A 12- to 24-inch-high well pad, measuring about 25 by 25 feet, would be constructed at each site. The well pad would be constructed of native material at the site, including the suitable drilling cuttings. The wellhead would consist of several pipes and the well pump would be submersible, and therefore would not be visible. A 10- by 10-foot chain link enclosure, about six feet high, would be constructed around the wellhead.
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Water lines would be constructed to each well for the well sites; however, the potential routes were not identified at the time of the Certified FEIR. These pipes would consist of 6-inch-diameter high-density polyethylene ( HDPE) pipes that would be buried at least 18 inches below ground surface. The water lines in the river floodplain would be installed with a trenching machine that would excavate a 12-inch-wide trench and temporarily store the removed soils along the trench, which would be backfilled by a loader or backhoe, and then compacted to match existing grade. The temporary disturbance zone associated with pipe installation would be about 30 feet wide.

Permanent impacts of well construction would be limited to a small area (less than an acre total for all wells) within areas of California buckwheat – California broomsage scrub, black cottonwood forest, or willow thicket vegetation. Temporary impacts are yet undetermined, due to uncertainty in the final location of wells and subsequent routing of pipelines; however, it is assumed that at least some trenching will encroach into California buckwheat – California broomsage or black cottonwood forest vegetation types. Because each of these vegetation types is considered sensitive by CDFW, this impact would be significant. Implementation of Certified FEIR Mitigation Measures TER-10 and TER-11 would restore habitat functions and values, thereby reducing direct impacts to riparian habitats and other sensitive natural communities arising from construction and implementation of the Approved Project to a level of less than significant ( Class II).

Impacts During Operation
Operation of the Approved Project ( Master Plan Update, proposed water right Permit 15878 revisions, the proposed well sites and water treatment plant) would not exert any additional impacts on riparian or sensitive vegetation types beyond those of construction.

The City has determined that at buildout it will require a total of 1,980 AFY at a rate of up to 5 cfs to meet its demand. This would result in an increase in diversion of Santa Ynez River underflow from the baseline of 1,053 AFY and the current extraction rate of 1.85 cfs. The increased Solvang diversions would not alter the discharge requirements set forth by Order WR 94-5,44 issued by the State Water Resources Control Board (SWRCB), that requires Reclamation to manage Bradbury Dam water impoundments at a level that will ensure the long-term survival of steelhead and other fisheries resources within the Santa Ynez River.

As these resources are dependent on current water levels that also dictate the extent of riparian and floodway resources under the jurisdiction of CDFW and USACE, Reclamation will ensure that water flow downstream of the Approved Project area will not be significantly changed from present levels. 44 State Water Resources Control Board (SWRCB), Water Rights Order 94-5, In the Matter of Permits 11308 and 11310 Issued Order: pursuant to Applications 11331 and 11332; the United States Bureau of Reclamation: Permittee. November 17, 1994. 381
However, the extraction of groundwater associated with the Santa Ynez River underflow pumping could cause local depressions in the groundwater levels. If the water levels were to drop below the root zone of the riparian vegetation for an extended period of time, these plants would become stressed and could eventually die. The Certified FEIR indicated that water flow levels would be similar to the historical levels.

Therefore, operational impacts to riparian vegetation regulated by the CDFW would be less than significant.

3.2.1.5 Effect on Federally Protected Wetlands
Construction Impacts
Proposed Master Plan Update
Projects proposed under the Master Plan Update would take place primarily within areas that are currently developed or disturbed by residential, commercial or agricultural uses. Additionally, General Plan policies require that new development prioritizes the preservation of riparian and sensitive natural communities. Nevertheless, certain land uses that may be permissible under the City’ s General Plan could include encroachment into federally protected wetlands depending upon place of wells along the riverbank. Such impacts would be subject to the permitting requirements of the USACE and are potentially significant. Although ultimate locations of wells and associated pipelines is unknown, their construction could result in impacts to areas under CDFW jurisdiction and possibly the U.S. Army Corps of Engineers USACE). Impacts from construction would be limited in size and area (a few hundred square feet) at each well site and for the associated pipelines as wells as areas for access roads and staging. These impacts would be potentially significant. Implementation of Certified FEIR Mitigation Measures TER-10, TER-11, and TER-12 would reduce impacts to a level of less than significance.

The City has determined that at buildout it will require 1,980 AFY of water with a maximum extraction rate of up to 5 cfs to meet its demand. This would result in an increase in diversion from the baseline of 1,053 AFY and baseline extraction rate of 1.85 cfs, but would not alter the release requirements set forth by Order WR 94-5 that requires Reclamation to make releases at Bradbury Dam to ensure the long-term survival of steelhead and other fisheries resources within the Santa Ynez River. As these resources are dependent on current water releases that also dictate the extent of riparian and floodway resources under the jurisdiction of the USACE, impact to federally protected wetlands would be less than significant.

Proposed Wells and Water Treatment Plant
Direct and indirect impacts on the Santa Ynez River and adjacent riparian and scrub areas are subject to the jurisdiction of several state and federal agencies, including the USACE, the CDFW, and the Central Coast Regional Water Quality Control Board (RWQCB).
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As previously stated, the Santa Ynez River runs through the Approved Project site. A jurisdictional assessment was conducted for the reach of river and adjacent habitat areas within the Project site in October 2011 to determine the areas under jurisdiction of the USACE as waters of the United States and CDFW. The portion of the proposed Well Sites A and B located within and along the banks of the Santa Ynez River could be impacted as a result of the construction of bank stabilization. Although ultimate locations of wells and associated pipelines is unknown, their construction could result in impacts to areas under CDFW jurisdiction and possibly the USACE. Impacts from construction would be limited in size and area ( a few hundred square feet) at each well site and for the associated pipelines as wells as areas for access roads and staging. These impacts would be potentially significant.

Implementation of Certified FEIR Mitigation Measures TER-10, TER-11, and TER-12 would restore habitat functions and values. With implementation of Mitigation Measures TER-10, TER-11 and TER-12, impacts from the Approved Project construction to federally protected wetlands would be less than significant Class II).

Impacts During Operation
Operation of the Approved Project would not exert any additional impacts on federally protected wetlands beyond those of construction. Similar to the previous discussion above, the extraction of groundwater associated with the Santa Ynez River underflow pumping could cause local riparian vegetation to become stressed and could eventually die. However, as discussed above and in Section 5.1 of the Certified FEIR and summarized above in Section 3.1: Hydrology, Water Supply, and Water Quality, of this Addendum, the long-term modeling of Stetson Engineers have indicated that water flow levels would be similar to the baseline levels. In addition, groundwater elevations would fluctuate within the historical groundwater elevation range during no flow and no inflow conditions within the Santa Ynez River under the Master Plan Update. Therefore, impacts from Approved Project operation to federally protected wetlands would be less than significant.

3.2.1.6 Interfere Native Resident or Migratory Wildlife Terrestrial Species Construction Impacts
Proposed Master Plan Update
Projects proposed under the Master Plan Update would take place primarily within areas that are currently developed or disturbed by residential, commercial, or agricultural uses, which do not generally provide attributes suitable for wildlife movement. The primary movement corridor through the planning area is the Santa Ynez River, which provides movement opportunity for a variety of aquatic and terrestrial wildlife species. The Santa Ynez River corridor would not be developed as a result of implementation of 383
the Master Plan Update. Certain development activities that may be permissible under the City’ s General Plan could disrupt breeding activity by native bird species protected under state and federal laws. Such impacts would be significant. Implementation of Certified FEIR Mitigation Measure TER-13 would reduce direct impacts to less than significant ( Class II).

Proposed Wells and Water Treatment Plant
The Migratory Bird Treaty Act and the California Fish and Game Code prohibit the take (defined as destroy, harm, harass, etc.) of bird nests with eggs or young, and a number of bird species could be adversely affected as a result of implementation of the Master Plan Update. While the Master Plan Update is not expected to include the removal of mature trees and other nesting habitat, construction- related activities could result in the direct loss of active nests or the abandonment of active nests by adult birds during that year’s nesting season. This impact would be a potentially significant impact.

Implementation of Certified FEIR Mitigation Measure TER-13 would reduce direct impacts to less than significant ( Class II).

Impacts During Operation
The Master Plan Update design would introduce new wells downstream of Alisal Bridge. Hydrological connectivity through this reach would not be severed but the hydro-period of pools and other permanent and semi-permanent surface water features could be qualitatively altered ( See Section 5.3: Fisheries Resources of the Certified FEIR).

The City has determined that at buildout it will require 1,980 AFY of water with a maximum diversion rate of up to 5 cfs to meet its demand. This would result in an increase in diversion from the baseline of 1,053 AFY and baseline extraction rate of 1.85 cfs, but would not alter Order WR 94-5 that requires Reclamation to make releases at Bradbury Dam to ensure the long-term survival of steelhead and other fisheries resources within the Santa Ynez River through implementation of the requirements in the 2000 BiOp for operation and maintenance of Bradbury Dam. 45 As these resources are dependent on current water releases that also dictate the extent of riparian and floodway resources under the jurisdiction of CDFW and USACE, Reclamation will continue releases to downstream of the proposed Project area will remain at present levels. Therefore, the Certified FEIR concluded no impact to wildlife movement is anticipated.

Potential impacts to wildlife movement would be less than significant.

In the short term (less than 10 years), there may be a change in use of riparian habitats in areas where vegetation clearance is required; however, for most species currently using riparian habitat the general 45 National Marine Fisheries Service, ( NMFS), Biological Opinion for U.S. Bureau of Reclamation Operation and Maintenance of the Cachuma Project on the Santa Ynez River in Santa Barbara County, California September 11, 2000. 384
vegetative structure of the habitat can be expected to recover. Therefore, long-term movement opportunities are not expected to change for the suite of species dependent on dense riparian cover.

For upland species that may utilize the Santa Ynez River as a source of water or foraging opportunity, the installation of new wells is not expected to pose an insurmountable obstacle to transverse movements across the river floodplain.

Impacts to habitat connectivity are therefore less than significant ( Class III).

3.2.1.7 Conflict with Adopted HCP, Natural Communities Conservation Plan Construction Impacts
Proposed Master Plan Update
Projects proposed under the Master Plan Update would take place primarily within areas that are currently developed or disturbed by residential, commercial or agricultural uses, outside of any designated Habitat Conservation Plan ( HCP), Natural Communities Conservation Plan ( NCCP), or other approved local, regional, or state HCP. An exception to this is the Santa Ynez River, alterations of which are subject to the provisions of the recovery plan for southern steelhead, discussed in Section 5.3:

Fisheries Resources of the Certified FEIR and summarized in Section 3.3 of this Addendum.

There are no formal adopted HCPs or NCCPs within the City or adjacent unincorporated County. The Conservation and Open Space Element for the City and the Santa Ynez Valley Community Plan for the County contain provisions for protection of the Santa Ynez River. The discussion of the General Plan is found in Section 5.2.3.3 Local Regulations of the Certified FEIR.

As previously noted, pursuant to Order WR 94-5, requires Reclamation to make releases at Bradbury Dam to ensure the long-term survival of steelhead and other fisheries resources within the lower Santa Ynez River. Resources and species that are dependent on current water releases ( i.e., riparian vegetation that is directly related to surface water availability) would not experience impact because Reclamation will continue water releases to downstream of the proposed Project area. Impacts related to adopted HCP, NCCP or another plan would be less than significant ( Class III).

Proposed Wells and Water Treatment Plant
The proposed Well Sites A and B and the water treatment plant site in the Alisal Commons open space area do not lie within any area subject to the provisions of an adopted HCP, NCCP, or other approved local, regional, or state HCP, nor do they lie within an area designated as critical habitat for a terrestrial threatened or endangered species. There would be no impact. 385
The Santa Ynez River supports southern steelhead, and is subject to provisions set forth in the recovery plan for that species. For a detailed discussion of Certified FEIR Project impacts to southern steelhead, please see Section 5.3: Fisheries Resources of the Certified FEIR and summarized in Section 3.3 of this Addendum.

Impacts During Operation
As previously noted, pursuant to Order WR 94-5, Reclamation will make releases at Bradbury Dam to ensure the long-term survival of steelhead and other fisheries resources within the lower Santa Ynez River.

3.2.1.8 Cumulative Impacts
The Master Plan Update of the Certified FEIR would replace the City’ s current Water System Master Plan to ensure adequate and reliable water supply and infrastructure to meet future demand as forecast in the City’ s General Plan at buildout.

The Approved Project would include installation of new wells and associated pipelines in Wells Sites A and B along the Santa Ynez River in both the City and unincorporated areas of the County, and construction of a water treatment facility within the Alisal Commons open space area in the City. The previous discussion on project specific listed wildlife and special status plant impacts associated with the implementation of the Master Plan Update and the proposed water right Permit 15878 revisions conclude that impacts would be mitigated to a less than significant level. The proposed water treatment plant site supports ruderal vegetation dominated by non-native annual species, which is common in the region. The Certified FEIR concluded implementation of the Master Plan Update would therefore not result in significant cumulative impacts to biological resources beyond those previously recognized as resulting from implementation of the City’ s General Plan and the County’ s Santa Ynez Valley Community plan. The Certified FEIR Project contribution to cumulative impacts to biological resources will be less than significant ( Class III).

3.2.2 Description of the Changes Resulting from Revised Project The Revised Project would be similar to the river wells component of the Approved Project but it would be constructed and operated a reduced capacity. The Revised Project proposes up to two new river wells in Well Site B instead of up to 6 new wells in Well Site A and B under the Approved Project. The Revised Project also proposes diverting 1,368 AFY at a maximum rate of 2.84 cfs, which is reduced from the 1,980 386
AFY at 5 cfs proposed in the Approved Project. The reach of diversion has been substantially reduced from 19,500 feet in the Approved Project to a Final Reach of Diversion of 8,060 feet in the Revised Project.

Additionally, other components of the Master Plan Update are the same ( abandon existing Well 7A located between Alisal Ranch and Santa Ynez River Water Conservation District, ID No. 1 river wells) or no longer under consideration ( the previously planned water treatment plant is no longer proposed in the Revised Project) as analyzed in the Certified FEIR.

3.2.3 Changes in City, State, or Local Plans and Regulations There have been no changes to the city, state, or local plans and regulations to terrestrial biological resources for the City of Solvang.

Order WR-2019-0148 and Order WR-2019-0148 Term 18 Plan have been issued since the time of the Certified FEIR. Both affect the Santa Ynez River and are applicable to the Revised Project. They are discussed in further detail in Section 3.1.3, above.

3.2.4 Comparison of the Potential Impacts in the Certified FEIR with the Revised Project
Since the Certified FEIR, Checklist Questions for Biological Resources have been updated in the CEQA Guidelines Appendix G Checklist. To determine whether the Revised Project would result in new impacts or an increase in the severity of previously identified impacts as analyzed by the Certified FEIR, provided below is an update to the environmental information and analysis of the impacts of the Revised Project using the Biological Resources Checklist Questions from the current CEQA Guidelines Appendix G Checklist.

An updated terrestrial biological resources technical report (“Terrestrial Biological Report”) was prepared to update prior terrestrial biological information in the Certified FEIR ( see Appendix C). 46 The purpose of the updated Terrestrial Biological Report was to review of the Certified FEIR and conduct a reconnaissance level survey to provide any significant updates to the environmental conditions and potential impacts of the Revised Project on terrestrial biological resources. Field surveys were conducted as part of the Revised Project were completed on April 2, 2021. 47
46 PAX Environmental, Inc., Terrestrial Biological Resources Technical Report for the CEQA Documentation for the Proposed Revisions to the City of Solvang 2011 Master System Plan Update Environmental Impact Review (EIR), ( October 2021; see Appendix C to this Addendum).
47 PAX Environmental, Inc. Terrestrial Biological Resources Technical Report for the CEQA Documentation for the Proposed Revisions to the City of Solvang 2011 Master System Plan Update Environmental Impact Review ( EIR), ( October 2021; see Appendix C to this Addendum).
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Potential impacts to aquatic resources were not the focus of the Terrestrial Biological Report. Aquatic species are addressed in below in Section 3.3 of this Addendum. The Terrestrial Biological Report is utilized below to determine potential impacts of the Revised Project on terrestrial biological resources.

3.2.4.1 Have a substantial adverse effect, either directly or through habitat modification, 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 Game or U.S.

Fish and Wildlife Service?
Construction Impacts
The Certified FEIR noted plant species can become established subsequent to the Project inventory surveys, so period update surveys are required. As such, field surveys and database searched were conducted as part of the updated Terrestrial Biological Report (see Appendix C). 48 The updated plant and wildlife species database searches identified 30 sensitive plant species and 54 sensitive wildlife species, have the potential to utilize the Revised Project site or off-site areas affected by construction and operation of the Revised Project. The Certified FEIR database searches identified 30 sensitive plant species and 20 sensitive wildlife species. Two species that were noted in the Certified FEIR database search that were not identified in the updated database searches were round leaf filaree (California macrophylla) and dwarf calycadenia ( Calycadenia villosa). Even though these species did not show up it is not significant because the previous database searches found occurrences of these species far away from the Revised Project area and their habitat requirements are not present at the Revised Project area.

One special status plant species, Southern California black walnut (J. californica, CNPS 4.2) was detected in several locations in the Revised Project area, as well as detected during the Certified FEIR survey period.

Based on a review of the CNDDB database and the habitat types, there are six other special- status plant species with the potential to occur including Hoover’ s bent grass (Agrostis hooveri), Santa Ynez groundstar Ancistrocarphus keilii), mesa horkelia ( Horkelia cuneata var. puberula), Santa Barbara Honeysuckle Lonicera subspicata var. subspicata), chaparral ragwort (Senecio aphanactis), and Sonoran maiden’ s hair fern ( Thelypteris puberula var. sonorensis). Four special- status animal species were detected in the Revised Project area during the survey including great egret (A. alba), great blue heron (A. herodias), oak titmouse (B. inornatus), snowy egret (E. thula), and yellow warbler (S. petechia). These species were also previously detected in this area during the Certified FEIR survey period. 48 PAX Environmental, Inc. Terrestrial Biological Resources Technical Report for the CEQA Documentation for the Proposed Revisions to the City of Solvang 2011 Master System Plan Update Environmental Impact Review ( EIR). October 1, 2021. 388
The Revised Project components would occur within Wells Site B, which is within the analyzed footprint of the Approved Project evaluated in the Certified FEIR and would reduce the number of proposed wells from six (6) to two (2). Accordingly, the Revised Project’ s construction- related impacts on sensitive plant species would be similar to the identified impacts in the Certified FEIR, though they would occur only in Well Site B and associated areas for supporting infrastructure. As such, Certified FEIR Mitigation Measures TER-2 through TER-8 described in the Certified FEIR would remain applicable to the Revised Project and would be sufficient to minimize potential impacts to sensitive plant species. The Revised Project’ s potential impacts on these sensitive species would be less than significant with incorporation of the aforementioned Certified FEIR mitigation measures.

Five special- status animal species were detected in the Revised Project area during the survey including great egret (A. alba), great blue heron (A. herodias), oak titmouse (B. inornatus), snowy egret (E. thula), and yellow warbler (S. petechia). These species were also previously detected in what is now the Revised Project area during the Certified FEIR survey period. Based on a review of the CNDDB and eBird databases and the habitat types in the updated Terrestrial Biological Report, there are 14 other special status animal species with the potential to occur including Southern California steelhead (Oncorhynchus mykiss irideus), California red-legged frog (Rana draytonii), Coast Range newt (Taricha torosa), California legless lizard Anniella pulchra pulchra), southwestern pond turtle ( Actinemys pallida), two-stripped garter snake Thamnophis hammondii) Cooper’ s hawk (Accipiter cooperii), golden eagle (Aquila chrysaetos), Southern California rufous-crowned sparrow ( Aimophila ruficeps canescens), ferruginous hawk ( Buteo regalis), southwestern willow flycatcher (Empidonax traillii extimus, discussed below), least Bell’ s vireo (Vireo bellii pusillus, discussed below), pallid bat ( Antrozous pallidus), and American badger ( Taxidea taxus).

Discussion of Southern California steelhead ( Oncorhynchus mykiss irideus) is provided in Section 3.3:

Fisheries Resources of this Addendum.

The Revised Project components would occur within Well Site B, which is within the analyzed footprint of the Approved Project evaluated in the Certified FEIR and would reduce the number of proposed wells from six (6) to two (2). Accordingly, the Revised Project’ s construction- related impacts on sensitive animal species would be similar to the identified impacts in the Certified FEIR, though they would occur only in Well Site B and associated areas for supporting infrastructure. As such, Certified FEIR Mitigation Measures TER- 1 through TER- 7 and TER- 9 described in the Certified FEIR would remain applicable to the Revised Project and would be sufficient to minimize potential impacts to sensitive animal species. The Revised Project’ s potential impacts on these sensitive species would be less than significant with incorporation of the aforementioned Certified FEIR mitigation measures.

Southwestern willow flycatcher (E. traillii extimus) and least Bell’s vireo (V. bellii pusllus) are not expected to nest onsite because the existing riparian habitat vegetation located in a small band along the river and 389
a small remanent in the proposed Well Site B are not extensive enough to support breeding habitat for these species. More extensive riparian habitat which is more suitable for these species does occur approximately 1.3 miles downstream from Well Site B, which is well outside the Revised Project area that this Terrestrial Biological Resources Technical Report and survey focused on. Transient and foraging individuals may utilize the Revised Project area, however given the minimal amount of potential habitat that may exist, this is unlikely. Typically, flycatchers choose sites in dense riparian vegetation next to the Santa Ynez River channel. Flycatchers breeding on the river often choose sites with standing water or moist surface soils away from the main channel. If water extraction activities at the two new wells were to result in downstream fluctuations in water levels further downstream, they would have the potential to adversely affect southwestern willow flycatcher nesting. However, the Certified FEIR stated extraction of up to 1,980 acre-feet per year (AFY) would not be expected to cause effects to stream flow (other than potential localized effects and would be within historical groundwater level fluctuations. The Revised Project would reduce the planned maximum annual pumping volume from 1,980 AFY in the Certified FEIR to 1,368 AFY and reduces the planned instantaneous pumping rate from 5 to 2.84 cubic feet per second cfs) all of which are within the historic groundwater level fluctuation. The GSI May 2021 memorandum, taking into account current regulatory requirements as stipulated in the 2000 and 2019 BiOps and in Water Rights Order 2019-0148 concluded that the Revised Project will have less impact on stream flow than modeled under the Certified FEIR. Furthermore, the GSI November 2021 memorandum found that, even under conservative assumptions, the planned diversions under Revised Project, will not adversely affect streamflow at Alisal Bridge in Above Normal and Wet years and will result in increased flows compared to the baseline for Critical Dry, Dry and Below Normal years. Therefore, indirect impacts to Southwestern willow flycatcher ( E. traillii extimus) breeding populations due to flow reductions downstream as a result of the Revised Project are highly unlikely and less than significant. The Revised Project would implement Certified FEIR Mitigation Measures TER- 1 through TER- 7. With implementation of these mitigation measures, impacts would be reduced to less than significant levels.

Therefore, with respect to impacts to special- status species from construction of the Revised Project, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

Impacts During Operation
Operational impacts associated with the new wells proposed under the Revised Project are related to noise, lighting, and access to the well sites by City personnel. Noise associated with the Revised Project is discussed in Section 3.9: Noise of this Addendum. The new wells would have the same design as the wells proposed in the Approved Project. Wells would use submersible pumps, noise from which is negligible, 390
and far below that of the current background levels. Night lighting would not be installed on the wells, and maintenance and monitoring of the wells would be conducted by City staff during daylight hours, accessing the sites along existing dirt roads.

Additionally, the Certified FEIR stated the water diversion of up to 1,980 AFY above the baseline of 1,053 AFY could modify habitat for California red-legged frog and southwestern willow flycatcher and least Bell’s vireo that could make use of the riparian resources of the river. The extraction of groundwater underflow of the Santa Ynez River associated with well pumping of the Approved Project would have created local depressions in the groundwater levels. However, the Certified FEIR determined the hydrological model of Stetson Engineers 49 for water extraction of 2,400 AFY indicate the water drawdown, when the Santa Ynez River experiences no river or other inflows in the area, would be localized within about 3,000 feet of the well site and would lower the groundwater level a maximum of 9 feet; the 9-foot drawdown is within the historical groundwater level fluctuation. Therefore, the Certified FEIR determined riparian resources are not expected to be affected by the water diversion of up to 1,980 AFY and impacts would be less than significant.

The GSI May 2021 memorandum concluded the Revised Project will have less impact than modeled in the Stetson Technical Memorandum No. 6 because it will reduce the planned maximum annual pumping volume from 1,980 AFY to 1,368 AFY (a 31 percent reduction). Since the Revised Project would divert less than the Approved Project, riparian resources would also not be expected to be affected by the Revised Project’ s water diversion of up to 1,368 AFY. For these reasons, impacts to special status species during operation would be less than significant. Therefore, with respect to impacts to special- status species from operation of the Revised Project, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.2.4.2 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 US Fish and Wildlife Service?
The WY2020 Annual Monitoring Summary presents 50 the data and summarizes the results of monitoring Southern California steelhead/ rainbow trout ( Oncorhynchus mykiss, O. mykiss) and water quality 49 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge (see Appendix 5.1 of the Certified FEIR).
50 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
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conditions in the LSYR below Bradbury Dam during Water Year 2020 ( WY2020, October 1,2019 to September 30, 2020). Annual monitoring reports for prior years ( 2008 to 2019) by the COMB, Fisheries Division provide data and monitoring results for fish prior years. 51 Habitat quality monitoring during WY2020 within the LSYR Basin continued to be done via photo documentation, specifically by maintaining a long standing record of locations. 52 Photographs were taken at designated locations to track long-term and short-term changes that had occurred as a result of storm flows, spill events, phreatophyte growth, changes in canopy coverage and type, periods of drought, and the results of management activities in the drainage.

Photo point comparison between 2005 and 2020 showed an increase of LSYR mainstem riparian growth since the target flows were required to be met at the Alisal Bridge ( 2005), approximately 10.5 miles downstream from Bradbury Dam. 53 Sections of the mainstem that were nearly devoid of vegetation in 2005 now show abundant new growth with willow, sycamore, and cottonwood trees in excess of 20 feet in height. The recent drought caused significant die off of riparian vegetation throughout the mainstem with some areas being impacted harder than other areas. The last Bradbury Dam spill event occurred in 2011. Since 2011, the region has experienced 5 consecutive years of drought and decreased flows throughout the entire watershed. The last several years (WY2017, WY2019, and WY2020) of average to above average rainfall has resulted in positive changes to the riparian vegetation with new growth observed in areas hit hard by the drought. WR 89-18 releases provide a water source for riparian plants during the latter part of the summer and the fall. In addition, there hasn’t been a spill event to scour out the river channel all resulting in favorable conditions for riparian growth.

Documentation within Hilton Creek continues to show a maturing/ drought recovering riparian zone, particularly within the reach between the upper release point (URP) and lower release point (LRP) which was initially activated in 2005. 54 Larger trees (willows, alders, sycamores, and cottonwoods) are replacing the smaller understory within the drainage. Salsipuedes and El Jaro Creeks showed recolonization of riparian vegetation after the 2005 flow events, the drought and two years of channel changing flow events in 2017 and 2019. In addition, the cattle exclusionary fencing installed in lower Salsipuedes Creek 51 The Cachuma Operation and Maintenance Board ( COMB), a Joint Powers Authority under California Government Code section 6500 et seq., and its member agencies, supply the Annual Monitoring Summary Reports for the period from 2008 to 2020. The information is available at: http:// www. cachuma- board. org/ annual- reports- and-documents 52 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
53 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
54 Cachuma Operation and Maintenance Board ( COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
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completed in WY2015) has contributed to an increase in riparian growth in those reaches where cattle no longer eat, trample and damage emerging vegetation.

Construction Impacts
The updated Terrestrial Biological Report identified willow thickets, such as sandbar willow (Salix exigua) and arroyo willow ( Salix lasiolepis) with mulefat 5 ( Baccharis salicifolia) present within the canopy.

Saplings of Southern California black walnut (Juglans californica), western sycamore (Platanus racemose), black cottonwood ( Populus trichocarpa), red willow (Salix laevigata), and shining willow (Salix lasiandra) were also present. Well Site B supports a well-developed wetland/ pond/ woodland complex edged by willow thickets and black cottonwood forest and supporting a small marsh of California bulrush (Cyperus esculentus) and narrowleaf cattail ( Typha angustifolia). Also within Well Site B is a depression that supports an additional water- filled depression but lacks any appreciable mature vegetation.

The Terrestrial Biological Report identified several sensitive vegetation communities. Coastal sage scrub or California buckwheat vegetation community, dominated by California buckwheat ( Eriogonum fasciculatum) and California broomsage ( Lepidospartum squamatum) are in several areas of Well Site ‘A’ and assigned a sensitivity rank of G5 S5 by California Department of Fish and Wildlife ( CDFW). Riparian habitat is present within the Revised Project area including Arroyo willow thickets, Black cottonwood forests, and California bulbrush marshes, which are assigned a sensitive ranking of G4 S4, G5 S3, and G5 S4 respectively by CDFW. The Revised Project components would occur within Well Site B, which is within the analyzed footprint of the Approved Project evaluated in the Certified FEIR ( Well Sites A and B) and would reduce the number of proposed wells from six (6) to two (2). Wells proposed under the Revised Project will still be at least 150 feet from the high water mark of the Santa Ynez River. The construction and design of the proposed wells under the Revised Project would be the same as the wells analyzed in the Certified FEIR. The new wells would connect to a new 12-inch diameter waterline to be constructed from the new wells approximately 2,000 feet length to the City’s existing water distribution system at the western end of Fjord Drive. The proposed width of the pipeline easement area and associated buffer is 40 feet wide in total (a 20-foot easement with a 10 foot buffer on both sides).

The Terrestrial Biological Resources Report identified riparian and wetland areas including Arroyo willow thickets, Black cottonwood forests, and California bulbrush marshes within the Revised Project area. The Revised Project components would occur within the analyzed footprint of the Certified FEIR (Well Sites A and B) and would reduce the number of proposed wells from six ( 6) to two (2) all within Well Site B.

Accordingly, the Revised Project’ s construction- related impacts on riparian would be similar to the identified impacts in the Certified FEIR. As such, implementation of Certified FEIR Mitigation Measures TER- 10 and TER- 11 described in the Certified FEIR and listed in Appendix B would remain applicable to 393
the Revised Project and would restore habitat functions and values, thereby reducing direct impacts to riparian habitats and other sensitive natural communities to a level of less than significant. Additionally, the implementation of Certified FEIR Mitigation Measure TER-12 would ensure habitat enhancement and restoration would occur within Well Site B prior to construction of the proposed wells associated with the Revised Project. Accordingly, the Revised Project’ s construction- related impacts on sensitive vegetation communities would be similar to the identified impacts in the Certified FEIR. Therefore, with respect to impacts to riparian habitat from construction of the Revised Project, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

Impacts During Operation
Operation of the Revised Project would not exert any additional impacts on riparian or sensitive vegetation types beyond those of construction. Currently, the City has elected to limit its proposed river well pumping to a maximum of 1,368 AFY and its diversion rate to 2.84 cfs (compared to 1,980 AFY and 5 cfs in the Certified FEIR Project) and cease pumping from existing Well 3 (and 7A) if flows at the Alisal Bridge drop below 1.5 cfs.

Similar to the increased Solvang diversions in the Approved Project, the Revised Project diversions would not alter the discharge requirements set forth by Order WR 94-5,55 issued by the State SWRCB, that requires Reclamation to manage Bradbury Dam water impoundments at a level that will ensure the longterm survival of steelhead and other fisheries resources within the Santa Ynez River. As these terrestrial biological resources are dependent on current water levels that also dictate the extent of riparian and floodway resources under the jurisdiction of CDFW and USACE, Reclamation will ensure that water flow downstream of the Revised Project area will not be significantly changed from present levels.

However, the extraction of groundwater could cause local depressions in the groundwater levels. If the water levels were to drop below the root zone of the riparian vegetation for an extended period of time, these plants would become stressed and could eventually die. Based on the analysis in Section 3.1:

Hydrology, Water Supply, and Water Quality in this Addendum, water flow levels with the Revised Project would be similar to baseline conditions. Furthermore, the GSI May 2021 memorandum, taking into account current regulatory requirements as stipulated in the 2000 and 2019 BiOps and in Water Rights Order 2019-0148, concluded that the Revised Project will have less impact on stream flow than modeled under the Certified FEIR because it will reduce the planned maximum annual pumping volume 55 State Water Resources Control Board (SWRCB), Water Rights Order 94-5, In the Matter of Permits 11308 and 11310 Issued Order: pursuant to Applications 11331 and 11332; the United States Bureau of Reclamation: Permittee. November 17, 1994. 394
from 1,980 AFY to 1,368 AFY ( a 31 percent reduction). Furthermore, the GSI November 2021 memorandum found that, even under conservative assumptions, the planned diversions under Revised Project, will not adversely affect streamflow at Alisal Bridge in Above Normal and Wet years and will result in increased flows compared to the baseline for Critical Dry, Dry and Below Normal years. Since the Revised Project would divert less than the Approved Project, riparian resources would also not be expected to be affected by the Revised Project’ s water diversion of up to 1,368 AFY. Operational impacts to riparian vegetation regulated by the CDFW would be less than significant. Therefore, with respect to impacts to riparian habitat from operation of the Revised Project, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.2.4.3 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?
Construction Impacts
Similar to the Approved Project, direct and indirect impacts on the Santa Ynez River and adjacent riparian and scrub areas of the Revised Project are subject to the jurisdiction of several state and federal agencies, including the USACE, the CDFW, and the Central Coast RWQCB.

The Santa Ynez River runs through the Revised Project site. A portion of the proposed Well Site B is located within and along the banks of the Santa Ynez River.

Although ultimate locations of wells and associated pipelines is unknown, their construction could result in impacts to areas under CDFW jurisdiction and possibly the USACE, similar to the wells and pipelines analyzed in the Certified FEIR. Impacts from construction would be limited in size and area (a few hundred square feet) at each well site and for the associated pipelines as wells as areas for access roads and staging.

Compared to the Approved Project, the Revised Project would reduce the number of wells from six (6) to two (2), resulting in a more limited size and area for the well sites and associated pipeline. Nevertheless, similar to the Certified FEIR Project, these impacts would be potentially significant. Implementation of Certified FEIR Mitigation Measures TER-10, TER-11, and TER-12 would reduce impacts to a level of less than significance. Therefore, with respect to impacts to federally protected wetlands from construction of the Revised Project, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR. 395
Impacts During Operation
Operation of the Revised Project would not exert any additional impacts on federally protected wetlands beyond those of construction. Similar to the previous discussion above, the extraction of groundwater associated with the Santa Ynez River underflow pumping could cause local riparian vegetation to become stressed and could eventually die. However, as discussed above and in Section 3.1: Hydrology, Water Supply, and Water Quality, of this Addendum, the long-term modeling of Stetson Engineers have indicated that water flow levels would be similar to the baseline levels. Furthermore, the GSI May 2021 memorandum, taking into account current regulatory requirements as stipulated in the 2000 and 2019 BiOps and in Water Rights Order 2019-0148, concluded that the Revised Project will have less impact on stream flow than modeled under the Certified FEIR because it will reduce the planned maximum annual pumping volume from 1,980 AFY to 1,368 AFY ( a 31 percent reduction). Furthermore, the GSI November 2021 memorandum found that, even under conservative assumptions, the planned diversions under Revised Project, will not adversely affect streamflow at Alisal Bridge in Above Normal and Wet years and will result in increased flows compared to the baseline for Critical Dry, Dry and Below Normal years. Since the Revised Project would divert less than the Approved Project, riparian resources would also not be expected to be affected by the Revised Project’ s water diversion of up to 1,368 AFY. In addition, groundwater elevations would fluctuate within the historical groundwater elevation range during no flow and no inflow conditions within the Santa Ynez River under the Revised Project. Therefore, impacts to federally protected wetlands from operation of the Revised Project would be less than significant and the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.2.4.4 Interfere Substantially with 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?
Construction Impacts
The Migratory Bird Treaty Act and the California Fish and Game Code prohibit the take (defined as destroy, harm, harass, etc.) of bird nests with eggs or young, and a number of bird species could be adversely affected as a result of implementation of the Revised Project. While the Revised Project is not expected to include the removal of mature trees and other nesting habitat, construction- related activities could result in the direct loss of active nests or the abandonment of active nests by adult birds during that year’ s nesting season. The primary movement corridor is the Santa Ynez River, which provides movement opportunity for a variety of aquatic and terrestrial wildlife species. The Santa Ynez River corridor would 396
not be developed with the Revised Project, but construction of the two (2) wells could temporarily disrupt the movement opportunity for aquatic and terrestrial wildlife species. This impact would be a potentially significant impact. Implementation of Certified FEIR Mitigation Measure TER-13, which would reduce direct impacts to less than significant. Therefore, with respect to impacts to resident or migratory wildlife from construction of the Revised Project, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

Impacts During Operation
The Revised Project components would occur within Well Site B, which is within the analyzed footprint of the Approved Project evaluated in the Certified FEIR ( Well Sites A and B) and would reduce the number of proposed wells from six to two. The City has also elected to limit its proposed river well pumping to a maximum of 1,368 AFY ( compared to 1,980 AFY of diversion in the Certified FEIR Project). The Revised Project diversions would not alter the discharge requirements set forth by Order WR 2019-0148 and, therefore, releases downstream of the Revised Project area would continue. Additionally, the installation of the two (2) new wells would not pose an insurmountable obstacle to transverse movements across the river floodplain. As such, similar to the Approved Project analyzed in the Certified FEIR, operation of the Revised Project would not interfere substantially with the movement of any terrestrial wildlife species or with established native resident or migratory wildlife corridors or impede the use of native wildlife nursery sites. Therefore, impacts to resident or migratory wildlife species would be less than significant and the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.2.4.5 Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? This Checklist question was not in the CEQA Guidelines Appendix G Checklist questions at the time of the Certified FEIR. However, the Certified FEIR stated the Master Plan Update is not expected to include the removal of mature trees and resources and species that are dependent on current water releases, would not experience impact because Reclamation will continue water releases to downstream of the Project area as required by Order WR 94-5. Impacts were found to be less than significant.

As discussed above, the more recent Order WR 2019-0148 and Term 18 Plan also require water releases to downstream of the Project area. Thus, resources and species dependent on water release, would also not experience impact from the Revised Project because Reclamation will still continue to release water required by Order WR 2019-1048 and Term 18 Plan. The Conservation and Open Space Element for the 397
City and the Santa Ynez Valley Community Plan for the County contain provisions for protection of the Santa Ynez River and biological resources. As the Revised Project components would occur within the analyzed footprint of the Certified FEIR and result in a scaled down version of the Approved Project (i.e., the reduction in the number of proposed wells from six ( 6) to two (2)), implementation of the Revised Project does not conflict with any county or municipal policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. Therefore, impacts to local policies or ordinances protecting biological resources would be less than significant and the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.2.4.6 Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
Construction Impacts
The proposed Well Site B in the Revised Project area does not lie within any area subject to the provisions of an adopted HCP, NCCP, or other approved local, regional, or state HCP, nor do they lie within an area designated as critical habitat for a terrestrial threatened or endangered species. There would be no impact.

The Santa Ynez River supports southern steelhead, and is subject to provisions set forth in the recovery plan for that species. For a detailed discussion of Revised Project impacts to southern steelhead, please see Section 3.3: Fisheries Resources of this Addendum.

Impacts During Operation
The Conservation and Open Space Element for the City and the Santa Ynez Valley Community Plan for the County contain provisions for protection of the Santa Ynez River and biological resources. The Certified FEIR stated resources and species that are dependent on water releases, would not experience impact because Reclamation will continue water releases to downstream of the Project area as required by Order WR 94-5. As discussed above, the more recent Order WR 2019-0148 and Term 18 Plan also require water releases to downstream of the Project area. Thus, resources and species dependent on water release, would also not experience impact from the Revised Project because Reclamation will still continue to release water required by Order WR 2019-1048 and Term 18 Plan. As the Revised Project does not lie within any area subject to the provisions of an adopted HCP, NCCP, or other approved local, regional, or state HCP, nor do they lie within an area designated as critical habitat for a terrestrial threatened or endangered species, implementation of the Revised Project does not conflict with these plans. Therefore, 398
similar to the Certified FEIR Project, impacts would be less than significant and the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.2.4.8 Cumulative Impacts
Impacts resulting from implementation of the Revised Project would not result in potentially significant impacts after mitigation or in an increase in the severity of or new impacts previously disclosed in the City’ s Certified FEIR. Moreover, at the time of the preparation of the addendum, no changes or new SWRCB permits or licenses, applications, small domestic use registrations, and statements of diversion and use ( referred to herein as “ claims”) were on file for the Santa Ynez River, including the Revised Project. 56 There are currently 39 claims, the same amount at the time of the Certified FEIR. Since the time of the Certified FEIR, the more recent Order WR 2019-0148 and Term 18 Plan require water releases to downstream of the Revised Project area. Implementation of the Revised Project would therefore not result in significant cumulative impacts to terrestrial biological resources beyond those previously recognized. The Revised Project’ s contribution to cumulative impacts to terrestrial biological resources would be less than significant and the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.2.5 Revisions to Mitigation Measures
The mitigation measures previously identified Certified FEIR, with the following minor revisions in strike out and underline, will apply to the Revised Project:

TER-1 Prior to initiating construction activities within the 100-year floodplain of the Santa Ynez River, construction sites and access roads within the riverbed, as well as riverbed areas within 300 feet of the construction site and access road, shall be inspected by a qualified biologist for the presence of the listed species, California red-legged frog, and the nonlisted species foothill yellow-legged frog, Coast Range newt, silvery legless lizard, western pond turtle, two-striped garter snake, and American badger.

If any of these species are discovered within the construction work areas and access roads, these areas shall be cleared of the species listed above immediately before the prescribed work is to be carried out and immediately before any equipment is moved into or through the affected habitat areas. The removal of such species shall be conducted by 56 State Water Resources Control Board (SWRCB), eWRIMS database, https:// waterrightsmaps. waterboards. ca.gov/ viewer/ index. html?viewer=eWRIMS. eWRIMS_ gvh#. Accessed October 2021. 399
a qualified biologist using procedures approved by the USACE and CDFW, and with the appropriate collection and handling permits. Species shall be relocated to nearby suitable habitat areas but sufficiently distant from the construction area to minimize the likelihood of their return.

TER- 2 A qualified biologist shall be retained as a construction monitor to ensure that incidental construction impacts on biological resources are avoided, or minimized, and to conduct pre-grading field surveys for special- status plant and wildlife species, including those species listed in Mitigation Measure TER- 1 that may be destroyed as a result of construction or site preparation activities. Responsibilities of the construction monitor include the following:

The construction monitor shall attend pre-grade meetings to ensure that timing or location of construction activities do not conflict with mitigation requirements ( e.g., seasonal surveys for plants and wildlife).

Mark or flag the construction area in the field with the contractor in accordance with the final approved construction plan.

Supervise cordoning of natural areas that lie outside grading areas identified in the construction plans (e.g., with temporary fence posts and colored rope).

Conduct a field review of the staking (to be set by the surveyor) designating the limits of all construction activity. Any construction activity areas immediately adjacent to riparian areas or other special- status resources may be flagged or temporarily fenced by the monitor, at his or her discretion.

Conduct meetings with the contractor and other key construction personnel describing the importance of restricting work to designated areas. The monitor should also discuss procedures for minimizing harm or harassment of wildlife encountered during construction.

Periodically visit the site during construction to coordinate and monitor compliance with the above provisions.

TER- 3 Construction personnel shall be prohibited from entry into areas outside the designated construction area, except for necessary construction related activities, such as surveying.

All such construction activities shall be coordinated with the construction monitor.

TER-4 Vehicles and equipment shall not be operated in areas of ponded or flowing water or where wetland vegetation, riparian vegetation, or aquatic organisms may be destroyed unless there are no practicable alternative methods to accomplish the construction work, and only after prior approval by the CDFW and USACE. Approval shall be acquired by 400
submitting a request to CDFW and USACE no later than 30 days prior to construction. The request must contain a biological evaluation demonstrating that no sensitive fish, amphibians, or reptiles are currently present, or likely to be present during construction, at the construction site or along access roads.

TER- 5 Temporary sediment retention ponds shall be constructed downstream of construction sites that are located in the 100-year floodplain under the following circumstances:
the construction site contains flowing or ponded water that drains off site into the undisturbed streamflow or ponds; or
streamflow is diverted around the construction site, but the work is occurring in the period November 1 through April 15 when storm flows could inundate the construction site.

The sediment ponds shall be constructed of riverbed material and shall be located away from areas of ponded or flowing water to prevent discolored, silt-bearing water from reaching areas of ponded or flowing water during normal flow regimes. To the extent possible, ponds shall be located in barren or sandy areas devoid of existing riparian scrub, riparian woodland, or aquatic habitat. The ponds shall be maintained and repaired after flooding events, and shall be restored to pre-construction grades and substrate conditions within 30 days after construction has ended at that particular site. The location and design of sediment retention ponds shall be included in the Storm Water Pollution Prevention Plan ( SWPPP) prepared by the City for all construction activities that require a NPDES General Construction Activity Storm Water Permit, if applicable, or will be determined under the City’ s SWMO and analogous Santa Barbara County requirements ( Santa Barbara County Code, Title 29, Article IV and Santa Barbara County Code, Title 14), as applicable.

TER- 6 Water containing mud, silt, or other pollutants from construction activities shall not be allowed to enter a flowing stream, standing pools that native fauna may occupy, or be placed in locations that may be subject to normal storm flows during periods when storm flows can reasonably be expected to occur.

TER-7 Stationary equipment such as motors, pumps, generators, and welders that may be located within the riverbed construction zone shall be positioned over drip pans. No fuel storage tanks or equipment maintenance shall be allowed within the 100-year floodplain.

TER- 8 Focused surveys for potentially occurring special- status plant species shall be conducted by a qualified botanist prior to the commencement of construction related activities 401
within suitable on site habitat areas. The surveys shall be conducted no more than one year prior to commencement of construction activities within suitable habitat and during the appropriate season for detection of the target species. Should individuals of the species be documented within Well Sites A and B and any other impacted locations, a rescue/ replacement plan shall be developed prior to the issuance of grading permits and implemented by the City or its designee in accordance with the plan provisions.

Undeveloped portions of the Well Sites A and B, and any other impacted locations, shall be used as receptor sites for transplanted individuals or seeds. Other suitable mitigation sites may be used upon approval by USACE, CDFW and the City and/ or County. The plan shall demonstrate the feasibility of replacing the number of individual plants to be removed at a 1:1 ratio (of individual plants for woody species, and on an aerial basis for annual and herbaceous species). The plan shall specify the following:

1. the location of mitigation;

2. methods for harvesting seeds, and salvaging and transplantation of individual plants to be impacted;

3. site preparation procedures for the mitigation site;

4. a schedule and action plan to maintain and monitor the mitigation area;

5. a list of criteria and performance standards by which to measure success of the mitigation site;

6. measures to exclude unauthorized entry into the mitigation areas; and

7. contingency measures in the event that mitigation efforts are not successful.

TER-9 Preconstruction surveys for bat roosts within the Project impact area shall be conducted no earlier than one week prior to the commencement of any construction activity. If potential roosting habitat is found in Wells Sites A and B or other project locations, exclusion of bats shall be accomplished by identifying primary exit points and sealing all other escape routes greater than 0.25 inch. Care shall be taken to avoid sealing bats into the roost by placing a one-way valve over the primary exit points to prevent reentry.

Simple one-way valves may be constructed using wire mesh cones, PVC, and strips of clear plastic sheeting attached over exit points. Once the bats have been excluded, roost spaces can be permanently filled with a suitable substance. In order to minimize disturbance to bats, it is recommended that exclusion be initiated during the winter months when the fewest bats are present.
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TER-10 In order to compensate for permanent removal of jurisdictional habitats, including but not limited to sensitive vegetation types, the applicant shall control giant reed and other invasive exotic plant species within the Project site to improve and expand wildlife and endangered species habitat, reduce flooding, erosion, and fire hazards, improve water quality; and potentially increase stream flow and water quantity in the Project watercourses. Removal areas shall be kept free of exotic plant species for 5 years after initial treatment. In areas where extensive exotic removal occurs, revegetation with native plants or natural recruitment shall be documented.

TER- 11 Vegetation types temporarily impacted by the proposed Project will be restored. Native vegetation within temporary construction areas shall be mulched and set aside. Large trunks of removed trees may be utilized on site to provide habitat for invertebrates, reptiles, and small mammals or may be anchored within the Project site for erosion control. If the timing of the mulching and application is appropriate, the native mulch will be spread over the temporary impact areas in order to facilitate revegetation. If the period of mulch storage exceeds approximately one month, fresh native mulch may be applied to the temporary impact areas to provide seed propagules and native biomass.

After the completion of Year 1, the Project biologist will evaluate the progress of the passive restoration approach in the temporary impact areas to determine if natural recruitment has been sufficient for the site to eventually reach performance goals. In the event that the Project biologist determines native plant recruitment to not be adequate for successful habitat establishment, the applicant or its designee shall revegetate the temporary construction areas in accordance with the methods designed for permanent impacts ( i.e., seeding, container plants, or a temporary irrigation system may be recommended).

Areas temporarily disturbed by construction activities shall also be weeded annually, as needed, for up to 5 years following construction. Weeds shall be removed by hand, an approved herbicide application, or by mechanical equipment. These areas shall be annually monitored for 5 years after construction to document vegetation type establishment.

In the event that native plant cover does not reach 50 percent of the pre-construction native plant cover within 3 years, the City shall revegetate the temporary construction.

TER- 12 Prior to the drilling and construction of any wells in Wells Sites A or B, the City shall develop a habitat enhancement and restoration plan to improve the quality of the 403
riverine and wetland functions associated with on-site portion of the Santa Ynez River in the vicinity of proposed well sites. Enhancement and restoration actions will include control of invasive plant species (e.g., Italian stone pine, Peruvian- pepper [Schinus molle], fennel, castor-bean, white melilot, tree tobacco, date palm, and smilo grass [Piptatherum miliaceum]), creation of native riparian and scrub habitat, and for the planting of appropriate locally indigenous species for the habitat created.

TER-13 Active nests of native bird species are protected by the Migratory Bird Treaty Act ( 16 U.S.C. 704) and the California Fish and Game Code (Section 3503). If activities associated with construction or grading are planned during the bird nesting/ breeding season, generally January through March for early nesting birds ( e.g., Coopers hawks or hummingbirds) and from mid-March through September for most bird species, the City shall have a qualified biologist conduct surveys for active nests. To determine the presence/ absence of active nests, pre-construction nesting bird surveys shall be conducted weekly beginning 30 days prior to initiation of ground- disturbing activities, with the last survey conducted no more than three days prior to the start of clearance/ construction work. If ground-disturbing activities are delayed, additional preconstruction surveys shall be conducted so that no more than three days have elapsed between the survey and ground-disturbing activities.

3.2.6 Determination of the Potential Significance of Impacts Environmental impacts associated with the Proposed Project would be less than significant with mitigation from the Certified FEIR incorporated.

Mitigation measures identified in the Certified FEIR shall be implemented for special status species and sensitive vegetation communities ( Mitigation Measures TER-1 through TER-12). Implementation of Certified FEIR Mitigation Measures TER-10 and TER- 11 would restore habitat functions and values, thereby reducing direct impacts to riparian habitats and other sensitive natural communities arising from construction and implementation of the Revised Project to a level of less than significant. The implementation of Certified FEIR Mitigation Measure TER-12 would ensure development of a habitat enhancement and restoration plan for Well Site B prior to construction of the proposed wells associated with the Revised Project.

If active nests are present in the Project area prior to construction of the Revised Project, implementation of Mitigation Measure TER-13 described in the Certified FEIR would be sufficient to minimize impacts to nesting birds in the Revised Project area.
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If construction takes place during January through September, Certified FEIR Mitigation Measures TER13 would also reduce direct impacts related to direct loss of active nests or the abandonment of active nests by adult birds during nesting season to less than significant ( Class II). No new mitigation measures or protocol level surveys are recommended.

Accordingly, the Revised Project would not result in any new project or cumulative impacts to terrestrial biological resources beyond that which was disclosed and mitigated for as part of the Certified FEIR, and such impacts would be reduced to less than significant with mitigation adopted in the Certified FEIR.

Therefore, implementation of the Revised Project would not result in any new impacts or increase the severity of a previously identified significant impact as analyzed in the Certified FEIR and no new information of substantial importance has been identified that would require preparation of an EIR.

3.3 FISHERIES RESOURCES

3.3.1 Summary of Analysis in the Certified FEIR

3.3.1.1 A Substantial Adverse Effect on Any Species Identified as Endangered, Rare, or Threatened
Construction Impacts
The Certified FEIR stated temporary activities associated with installation of the wells could include access by construction equipment, and grading and vegetation removal in a relatively small area (approximately 2,500-square feet) for each well (which would be used for the drilling rig, stockpiling, and other equipment parking).

As the proposed well sites will be located outside of the active channel, and above the ordinary high water mark, these impacts are expected to be temporary. Additionally, standard BPMs associated with the SWPPP will be implemented in compliance with City and state policies and ordinances. Therefore, the Certified FEIR concluded impacts would be less than significant.

The Certified FEIR determined increases in Solvang pumping would increase Cachuma Project water shortages during droughts due to increases in water rights and fish water releases, which are directly related to the level of dewatered storage in the Santa Ynez River alluvium from which Solvang would be pumping. Based on the Stetson analysis, pumping at 2,400 AFY, impacts to water supply in critical drought 405
periods would decrease to 10,120 acre-feet as compared to 10,300 acre-feet for the baseline ( pumping at 1,053 AFY) for the critical drought year. The cumulative shortage would decrease to 20,470 acre-feet when withdrawing 2,400 AFY as compared 20,910 acre-feet for baseline conditions ( 1,053 AFY) for the three year critical drought period. As such, downstream of Alisal Bridge in Well Sites A and B completely mitigates the impacts to the Cachuma Project supply compared to baseline conditions. As the Approved Project planned to withdraw 1,980 AFY and not the 2,400 AFY used in the Stetson analysis, impacts from the Approved Project would be similar or have less impact than those modeled. The Certified FEIR stated implementation of Mitigation Measures FIS-1 through FIS-4 would reduce direct impacts to less than significant resulting from construction of the Approved Project wells.

Impacts During Operation
Proposed Master Plan Update
The Certified FEIR stated implementation of the Master Plan Update as part of the Certified FEIR would provide for a number of improvements. These improvements, with the exception of the proposed new wells and extraction of water from the underflow of the Santa Ynez River as discussed in Section 5.3 of the Certified FEIR and below, will have no impact on fisheries resources.

Proposed Wells and Water Treatment Facilities
At the time of the Certified FEIR, the City’s analysis of its future water demand determined that the full buildout need is 1,980 AFY of water with a maximum diversion rate of up to 5 cfs. This amount was greater than the documented use at the time since 1990 (see Table 3.0-2 in Section 3.0 of the Certified FEIR) and the maximum annual diversion determined by the SWRCB ( see Section 3.6: Existing Use and Baseline in the Certified FEIR) of 1,053 AFY at an extraction rate of 1.85 cfs.

However, the Certified FEIR determined diversion of up to 1,980 AFY with a maximum diversion rate of up to 5 cfs would not result in the potential to significantly impact listed special- status fish species because the hydrology modeling of Stetson Engineers 57 indicates that groundwater elevation levels and stream flow would remain similar to the existing levels.

The Certified FEIR concluded impacts to O. mykiss upstream migration would be considered less than significant as the implementation of the Approved Project would not significantly alter winter flows.

The proposed Well Sites A and B are downstream of the designated critical management reach for O. mykiss, which means additional releases for fish would not be required in order to maintain the habitat 57 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge ( see Appendix 5.1 of the Certified FEIR).
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and target flows upstream of the Alisal Bridge. However, the Certified FEIR noted during dry years it is anticipated that additional releases from the Cachuma Project would be required in order to satisfy the water right requirements of the “Above Narrows” basin if the groundwater levels decrease in response to pumping further downstream. Coordination with other pumpers upstream and downstream is needed to ensure that sufficient flow is maintained to support survival and recovery of the species to a “ good condition” during drought events. The 2000 BiOp does not identify the reach downstream of Alisal Bridge to be suitable for habitat maintenance.

An analysis by Stetson 58 modeled the portion of the Santa Ynez River directly downstream from Alisal Bridge, under both normal and drought conditions, including the Additional Reach of Diversion. Modeling indicates that implementation of the 2000 BiOp would increase average flows at the Alisal Bridge (which is the downstream limit of target flows for fish) and thereby increases flows downstream of the Bridge, reducing any potential impacts on surface flow compared to the baseline of 1,053 AFY.

In addition, the hydrological model Stetson Engineers 59 used for water extraction of 2,400 AFY indicates the water drawdown, when the Santa Ynez River experiences no river or other inflows in the area, would be localized within about 3,000 feet of the well site and would lower the groundwater level a maximum of 9 feet ( see Table 5.1-5: Calculated Drawdown North of the Proposed Well Fields in Section 5.1:

Hydrology, Water Supply and Water Quality in the Certified FEIR). The 9 foot localized drawdown is within the historical groundwater level fluctuation. As such, the Certified FEIR determined the effects of local drawdown of groundwater levels from the proposed wells along the Santa Ynez River downstream of Alisal Bridge would not extend to the Lompoc Narrows.

The modeling completed by Stetson is not meant to be predictive, but to be used as an analytical tool for statistical and comparative purposes. 60 Therefore, because there are no stream gage monitoring points downstream of Alisal Bridge until the Lompoc Narrows, actual impacts to the local groundwater and surface water flows on O. mykiss habitat within the Additional Reach of Diversion are unknown and should be monitored to confirm modeling predictions.

The Certified FEIR stated increases in the City’s pumping will increase Cachuma Project water shortages during droughts due to increases in water rights and fish water releases, which are directly related to the 58 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge( see Appendix 5.1 of the Certified FEIR).
59 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge(see Appendix 5.1 of the Certified FEIR).
60 Stetson Engineers. Technical Memorandum No. 1, Hydrologic Impact Analysis for City of Solvang’ s CEQA Environmental Document for a Time Extension for Water Right Permit 15878, April 2004 (see Appendix 5.1 in the Certified FEIR). 407
level of dewatered storage in the Santa Ynez River alluvium from which the City would be pumping. Based on the Stetson analysis, pumping at 2,400 AFY, impacts to water supply in critical drought periods would decrease to 10,120 acre-feet as compared to 10,300 acre-feet for the baseline ( pumping at 1,053 AFY) for the critical drought year. The cumulative shortage would decrease to 20,470 acre-feet when withdrawing 2,400 AFY as compared 20,910 acre-feet for baseline conditions ( 1,053 AFY) for the three-year critical drought period. As such, the Certified FEIR determined downstream of Alisal Bridge in Well Sites A and B completely mitigates the impacts to the Cachuma Project supply compared to baseline conditions. 61 As the City proposes to withdraw 1,980 AFY and not the 2,400 AFY used in the analysis, impacts would be similar or have less impact.

The Stetson analysis indicated that WR89-18 releases would be increased as a result of increased pumping by the City; the average annual release would increase from 5,819 under baseline conditions (pumping at 1,053 AFY; Alternative GW4) to 6,002 AFY when pumping at 2,400 AFY (Alternative GW5). 62 As the 2,400 AFY was greater than the Certified FEIR Project at 1,980 AFY, the Certified FEIR determined impacts would be similar or less, and would be less than significant.

Well Sites A and B are downstream of the designated critical management reach for O. mykiss. Therefore, the Certified FEIR concluded reduction in water levels in that reach where Well Sites A and B are located would not trigger additional releases for fish. In addition, reductions in groundwater levels in that reach would generally not require additional releases to maintain the habitat and target flows upstream of the Alisal Bridge. Impacts to O. mykiss upstream migration would be considered less than significant as the implementation of the Approved Project would not significantly alter winter flows.

During dry years it was anticipated that additional releases from the Cachuma Project would be required in order to satisfy the water right requirements of the “Above Narrows” account if the groundwater levels decrease in response to pumping further downstream. This would be implemented through Santa Ynez River Water Conservation District and COMB' s operational compliance with the 2000 BiOp. 63 The City is obligated to comply with the 2000 BiOp. The Certified FEIR stated continued coordination between the City with other pumpers upstream and downstream would occur to ensure that sufficient flow is maintained to support survival and recovery of the species to a “ good condition” during drought events. 61 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge, Table 17 ( see Appendix 5.1 in the Certified FEIR).
62 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge, Table 17 ( see Appendix 5.1 in the Certified FEIR).
63 National Marine Fisheries Service ( NMFS), Biological Opinion for U.S. Bureau of Reclamation Operation and Maintenance of the Cachuma Project on the Santa Ynez River in Santa Barbara County, California September 11, 2000. 408
As such, the Certified FEIR concluded impacts to O. mykiss from increases in pumping from new wells along the proposed extended area of diversion would be less than significant.

Wells would use submersible pumps, noise from which is negligible, and far below that of the current background levels. Night lighting (for emergencies) would not be installed on the wells, and maintenance and monitoring of the wells would be conducted during daylight hours, accessing the sites along existing dirt roads. The Certified FEIR determined these impacts would be considered less than significant.

The Certified FEIR also noted no impacts to federally endangered Tidewater goby would be anticipated as a result of the Approved Project as they are not found in this reach.

Implementation of Certified FEIR Mitigation Measure FIS-5 would reduce direct impacts of the Approved Project to less than significant ( Class II) resulting from operation of the Approved Project wells. Indirect impacts of the Approved Project related to site preparation and construction activities would also be reduced to less than significant ( Class II).

3.3.1.2 A Substantial Adverse Effect on Any Species Identified as a Candidate, Sensitive, or Special- Status Species in Local or Regional Plans, Policies, or Regulations or by the USFWS, CDFW, or NMFS At the time of the Certified FEIR, there were no applicable local or regional plans that reference any candidate, sensitive or special- status fish species in the Project area except for the O. mykiss as discussed in the Final Southern Steelhead Recovery Plan. 64
The Final Southern Steelhead Recovery Plan identifies the Monte Arido Highlands Biographic Population Group (BPG) which includes the Santa Ynez River. The Plan list the Santa Ynez River as Core 1 population, which has a high priority for recovery. Critical recovery actions identified for the Santa Ynez River include implementing operating criteria to:
ensure the pattern and magnitude of water releases from Bradbury, Gibraltar, and Juncal dams provide the essential habitat functions to support the life history and habitat requirements of adult and juvenile steelhead;
physically modify Bradbury, Gibraltar, Mono, and Juncal dams to allow natural rates of steelhead migration to upstream spawning and rearing habitats, and passage of smolts and kelts downstream to the estuary and ocean; and
identify, protect, and, where necessary, restore estuarine and freshwater rearing habitats. 64 National Marine Fisheries Service, Southern California Steelhead Recovery Plan, Public Review Draft Version, Southwest Regional Office, Long Beach, California. January 2012. 409
The Certified FEIR determined the Approved Project would not conflict with the Final Southern Steelhead Recovery Plan.

Construction Impacts
The Certified FEIR stated construction activities, including the well drilling and construction, would temporarily impact small areas ( approximately 2,500 square feet) for each of the well sites, as well as require the clearing of vegetation in a path ( approximately 25 to 30 feet wide) connecting the lateral pipelines from the wells to the main conveyance system. The Certified FEIR noted depending on the final well site selection for individual wells in either Well Sites A or B, there could be impacts to slopes along the riverbank as well. Impacts would be potentially significant. However, with implementation of Certified FEIR Mitigation Measures FIS-1 through FIS-4, direct and indirect impacts would be reduced to less than significant ( Class II).

As the proposed wells would be located outside of the active channel, and above the ordinary high water mark, the Certified FEIR determined impacts to habitat along the river edge are expected to be temporary and less than significant. The City would implement standard BMPs associated with the SWPPP in compliance with City and SWRCB policies and ordinances. Implementation of BMPs and revegetation according to CDFW standards required of Section 1602 streambed alteration agreements would reduce these impacts to less than significant.

For wells located outside of the City’ s boundary in unincorporated Santa Barbara County, the Certified FEIR stated the City would be required to comply with Santa Barbara County Ordinance No. 3095 that establishes creek and river setback requirements to address flood hazards to structures and other development. 65 In general, development shall be set back a minimum of 50 feet from the top of bank of streams and creeks and 200 feet from the top of bank of the Santa Ynez River.

The water treatment plant would be located in the Alisal Commons open space area but would not impact fisheries resources during construction. Impacts from construction to non-listed special- status species would be less than significant.

Impacts During Operation
Proposed Master Plan Update
As previously noted in Section 5.3 of the Certified FEIR and this section, the City’ s proposed increase in water diversion via groundwater wells to 1,980 AFY with a maximum diversion rate of up to 5 cfs from the baseline of 1,053 cfs at an extraction rate of 1.85 cfs would not result in the potential to significantly 65 Santa Barbara County Ordinance No. 3095, County Code 15B, Development Along Watercourses. 410
impact non-listed special- status fish species. The Certified FEIR determined impacts to the Arroyo chub California Species of Special Concern) were anticipated to be less than significant, as these small fish are adapted to seasonally interrupted flow conditions and move into refugia habitat as flows decrease during warm months.

As analyzed under Impact Threshold 5.3.6.1 in Section 5.3 of the Certified FEIR and above in this section, impacts to O. mykiss during various life stages and critical habitat during periods of low flow and drought conditions would be less than significant. Implementation of Certified FEIR Mitigation Measure FIS-5 would reduce direct and indirect impacts of the Approved Project to less than significant (Class II) resulting from operation of the Approved Project wells.

3.3.1.3 Substantially Degrade the Quality of the Environment ( CEQA Section 15065)
The Certified FEIR determined implementation of the various components of the Approved Project is not expected to result in a substantial degradation of the quality of the environment. Additionally, the increase in water diversion to 1,980 AFY with a maximum diversion rate of up to 5 cfs from the baseline of 1,053 cfs at 1.85 cfs via groundwater wells from the underflow of the Santa Ynez River would not result in a substantial degradation of the quality of the environment. Impacts were concluded to be less than significant.

Construction Impacts
Short term impacts associated with construction would be less than significant with the implementation of BMPs associated with the SWPPP in compliance with City and SWRCB policies and ordinances ( see prior discussion above).

Construction activities, including the well drilling and construction, would temporarily impact small areas for each of the well sites, as well as require the clearing of vegetation to construct the lateral pipelines from the wells to the main conveyance system. Depending on the final well site selection for individual wells in either Well Sites A or B, there could be impacts to slopes along the riverbank as well. Impacts would be potentially significant. Implementation of Certified FEIR Mitigation Measures FIS-1 through FIS4 would reduce direct and indirect impacts to less than significant ( Class II). 411
The water treatment plant would be located in the Alisal Commons open space area but would not impact fisheries resources during construction. Impacts would be less than significant.

Impacts During Operation
Proposed Master Plan Update
The Certified FEIR concluded implementation of the various components of the Master Plan Update is not expected to result in a substantial degradation of the quality of the environment.

Proposed Wells and Water Treatment Facilities
As discussed above, the Approved Project would not result in significant impacts associated with routine operation and maintenance of the six ( 6) new wells, or with impacts associated with extraction of groundwater resources. Long-term impacts associated with maintenance operations would be less than significant as disturbances would not cause substantial degradation to the quality of the environment.

Implementation of Certified FEIR Mitigation Measure FIS-5 would reduce direct and indirect impacts of the Approved Project to less than significant ( Class II) resulting from operation of the Approved Project wells.

3.3.1.4 Substantially Reduce the Habitat of a Fish or Wildlife Species ( CEQA Section 15065)
As analyzed under Impact Threshold 5.3.6.1 in Section 5.3 of the Certified FEIR and above in this section, implementation of the Approved Project would not result in a substantial reduction of the habitat for a fish or wildlife species.

The proposed increase in water diversion to 1,980 AFY of water with a maximum diversion rate of up to 5 cfs from the baseline of 1,053 AFY and 1.85 cfs via groundwater wells from the underflow of the Santa Ynez River would not result in a substantial reduction in the habitat of a fish species. The Certified FEIR concluded impacts would be less than significant.

Construction Impacts
Construction of the six (6) new wells could have the potential to impact the critically designated habitat for O. mykiss, and could temporarily disrupt the connectivity of fisheries habitat. However, the Certified FEIR determined short term impacts associated with construction will be less than significant with the implementation of BMPs associated with the SWPPP in compliance with City and SWRCB policies and ordinances.
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Implementation of the Approved Project could result in temporarily impacts to small areas of land for each potential well sites, as well as require the clearing of vegetation connecting the lateral pipelines from the wells to the main conveyance system. Depending on the final well site selection, there could be impacts to slopes along the riverbank as well. These impacts are potentially significant. However, implementation of Certified FEIR Mitigation Measures FIS-1 through FIS-4 would reduce direct and indirect impacts to less than significant ( Class II).

Impacts During Operation
As discussed under Impact Threshold 5.3.6.1 in Section 5.3 of the Certified FEIR and above in this section, long-term operation of the proposed new wells of 1,980 AFY at an extraction rate of up to 5 cfs, was expected to result in fish flow operations on average at about the same level as the current baseline of 1,053 AFY at an extraction rate of 1.85 cfs based on the modeled analysis by Stetson Engineers. 66 Therefore, the Certified FEIR concluded impacts would not substantially reduce the habitat of any fish species and are considered to be less than significant. Implementation of Certified FEIR Mitigation Measure FIS-5 would reduce direct and indirect impacts of the Approved Project to less than significant Class II) resulting from operation of the Approved Project wells.

3.3.1.5 Cause a Fish or Wildlife Population to Drop Below Self-Sustaining Levels ( CEQA Section 15065)
As analyzed under Impact Threshold 5.3.6.1 in Section 5.3 of the Certified FEIR and above in this section, implementation of the various components of the Certified FEIR Project, with the exception of the construction of the six (6) wells, would not have the potential to cause a fish population to drop below self-sustaining levels. The Certified FEIR determined impacts would be less than significant.

Construction Impacts
As discussed under Impact Threshold 5.3.6.2 in Section 5.3 of the Certified FEIR and above in this section, drilling and construction of the six (6) new wells under the Approved Project could temporarily impact a small area for each well sites. This would include the clearing of vegetation around each well site and connecting the lateral pipelines from the new wells to the main conveyance system. Depending on the final well site selection, there could be impacts to slopes along the riverbank. These impacts were determined to be potentially significant. Implementation of Certified FEIR Mitigation Measures FIS-1 through FIS-4 would reduce direct and indirect impacts to less than significant ( Class II). 66 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge. 413
Impacts During Operation
As previously mentioned under Impact Threshold 5.3.6.1 in Section 5.3 of the Certified FEIR and above in this section, the City proposes to increase Santa Ynez River underflow diversion to 1,980 AFY of water with a maximum diversion rate of up to 5 cfs, which is greater than the currently documented diversion amount of 1,053 AFY at an extraction rate of 1.85 cfs. Long-term operation of the proposed new wells at 1,980 AFY with a maximum extraction rate of up to 5 cfs is expected to result in fish flow operations, on average, similar to the current baseline of 1,053 AFY at extraction rates of 1.85 cfs based on the modeled analysis by Stetson Engineers. 67 As such, diversion of up to 1,980-AFY would not cause the fish population to drop below self-sustaining levels. Impacts were concluded to be less than significant. Implementation of Certified FEIR Mitigation Measure FIS-5 would reduce direct and indirect impacts of the Approved Project to less than significant ( Class II) resulting from operation of the Approved Project wells.

3.3.1.6 Substantially Reduce the Number or Restrict the Range of an Endangered, Rare, or Threatened Species ( CEQA Section 15065) With the exception of the construction of the six (6) wells, the various components of the Certified FEIR Project would not be expected to result in a substantial reduction in the number or restrict the range of an endangered, rare, or threatened fish species. The Certified FEIR determined impacts would be less than significant.

Construction Impacts
Drilling and constructing the six ( 6) new wells under the Approved Project would temporarily impact a small area for each potential well site, as well as require the clearing of vegetation to construct the lateral pipelines from the wells to the main conveyance system. Depending on the final well site selection, there could be impacts to slopes along the riverbank as well. These impacts would be potentially significant.

Implementation of Certified FEIR Mitigation Measures FIS-1 through FIS-4 would reduce direct and indirect impacts to less than significant ( Class II).

Impacts During Operation
Under the Approved Project the City proposed to increase water diversion to 1,980 AFY with a maximum diversion rate of up to 5 cfs via groundwater wells from the underflow of the Santa Ynez River. Long-term operation of the proposed new wells is expected to result in average fish flow operations at similar levels to the current baseline of 1,053 AFY at an extraction rate of 1.85 cfs based on the modeled analyses by Stetson Engineers. Because the conditions would be similar to the baseline, the diversion of 1,980-AFY 67 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge. 414
would not result in a substantial reduction in the number or restrict the range of an endangered, rare, or threatened fish species. A more detailed analysis was provided under Impact Threshold 5.3.6.1 in Section

5.3 of the Certified FEIR and above in this section. The Certified FEIR concluded impacts would be less than significant. Implementation of Certified FEIR Mitigation Measure FIS-5 would reduce direct and indirect impacts of the Approved Project to less than significant (Class II) resulting from operation of the Approved Project wells.

3.3.1.7 Reduce the Area or Habitat Value of Critical Habitat Areas Designated under FESA ( Essential Fish Habitat)
The Certified FEIR stated implementation of the various components the Certified FEIR Project, with the exception of the six (6) wells, would not potentially result in a reduction of the area or habitat value of critical habitat areas designated under FESA ( Essential Fish Habitat).

Construction Impacts
The Approved Project would have temporarily impacted a small area for each of the proposed new well sites as, and would require the clearing of vegetation connecting the lateral pipelines from the proposed new wells to the main conveyance system. Depending on the final well site selection, there could be impacts to slopes along the riverbank as well. These impacts were determined to be potentially significant.

Implementation of Certified FEIR Mitigation Measures FIS-1 through FIS-4 would reduce direct and indirect impacts to less than significant ( Class II).

Impacts During Operation
The Approved Project proposed to increase water diversion to 1,980 AFY with a maximum diversion rate of up to 5 cfs. Long-term operation of the proposed new wells is expected to result in, on average, similar fish flow operations to the current baseline of 1,053 AFY at an extraction rate of 1.85 cfs based on the modeled analysis by Stetson Engineers. As discussed in the first Impact Threshold, diversion of the 1,980- AFY with a maximum diversion rate of 5 cfs of Santa Ynez River underflow would not result in a reduction of the area or habitat value of critical habitat areas designated under FESA. Impacts would be less than significant. Implementation of Certified FEIR Mitigation Measure FIS-5 would reduce direct and indirect impacts of the Approved Project to less than significant (Class II) resulting from operation of the Approved Project wells.

Long-term impacts associated with maintenance operations were concluded to be less than significant with the implementation of routine standard practices and BMPs. 415

3.3.1.8 Cause a Substantial Adverse Effect on Any Riparian Habitat or Other Sensitive Natura Communities
The Certified FEIR noted with implementation of the various components of the Approved Project, except for construction of new wells along the Santa Ynez River, would not potentially result in a substantial adverse effect on any U.S. Fish and Wildlife Service ( USFWS), CDFW, or NMFS locally or regionally identified riparian habitat or other sensitive natural communities. Impacts were identified to be less than significant.

Construction Impacts
The Certified FEIR stated construction of the six (6) new wells under the Approved Project would be short term and impacts from such construction would be less than significant. However, as previously noted under Impact Threshold 5.3.6.1 in Section 5.3 of the Certified FEIR and above in this section, construction of new wells along the Santa Ynez River would temporarily impact a small area for each of the future well sites, as well as require the clearing of vegetation to construct the lateral pipelines from the wells to the main conveyance system. Depending on the final well site selection, there also could be impacts to slopes along the riverbank as well. The Certified FEIR concluded these impacts are potentially significant.

Implementation of Certified FEIR Mitigation Measures FIS-1 through FIS-4 would reduce direct and indirect impacts to less than significant ( Class II).

Impacts During Operation
As previously described under Impact Threshold 5.3.6.1 in Section 5.3 of the Certified FEIR and above in this section, long-term operation of the six (6) new wells to provide 1,980 AFY at an extraction rate of up to 5 cfs is expected to result in average fish flow operations similar to the current baseline of 1,053 AFY at an extraction rate of 185 cfs based on the modeled analysis by Stetson Engineers. 68 As such, diversion of the 1,980-AFY with a maximum diversion rate of up to 5 cfs would not result in an adverse effect on any USFWS, CDFG, or NMFS locally or regionally identified riparian habitat or other sensitive natural communities.

The Certified FEIR stated extraction of groundwater underflow of the Santa Ynez River associated with the water pumping could cause local depressions in the groundwater levels. If the water levels were to drop below the root zone of the riparian vegetation for an extended period of time, these plants could become stressed and could eventually die. The long-term modeling of Stetson Engineers, as presented in Table

5.1-4 and Table 5.1-7 in Section 5.1 Hydrology, Water Supply and Water Quality in the Certified FEIR and discussed in Section 3.1 of this Addendum, indicates that water flow levels would be similar to the 68 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge. 416
baseline. Therefore, operational impacts to riparian vegetation regulated by the CDFW would be less than significant. Implementation of Certified FEIR Mitigation Measure FIS-5 would reduce direct and indirect impacts of the Approved Project to less than significant (Class II) resulting from operation of the Approved Project wells.

Operation of the water treatment plant would not exert any additional impacts on riparian or sensitive vegetation types beyond those of construction. Impacts were concluded to be less than significant.

Long-term impacts associated with maintenance operations would also be less than significant.

3.3.1.9 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
Implementation of the various components of the Approved Project, except for construction of new wells along the Santa Ynez River, would not potentially result in a substantial impediment to the movement of any native resident or migratory fish species or with established native resident or migratory wildlife corridors. The Certified FEIR determined impacts will be less than significant.

Construction Impacts
As previously discussed under Impact Threshold 5.3.6.1 in Section 5.3 of the Certified FEIR and above in this section, drilling and construction of the six ( 6) new wells under the Approved Project would temporarily impact a small area for each potential well site as well as require the clearing of vegetation in a path connecting the lateral pipelines from the wells to the main conveyance system. Depending on the final well site locations, there could be impacts to slopes along the riverbank as well. The Certified FEIR concluded impacts would be potentially significant. However, with implementation of Certified FEIR Mitigation Measures FIS-1 through FIS-4, direct and indirect impacts would be reduced to less than significant ( Class II).

Impacts During Operation
The Approved Project would increase water diversion to 1,980 AFY with a maximum diversion rate of up to 5 cfs. As described above under Impact Threshold 5.3.6.1 in Section 5.3 of the Certified FEIR and above in this section, long-term operation of the proposed new wells is expected to result in average fish flow operations similar to the current baseline of 1,053 AFY at an extraction rate of 1.85 cfs based on the 417
modeled analysis by Stetson Engineers. 69 Impacts would be less than significant. Implementation of Certified FEIR Mitigation Measure FIS-5 would reduce direct and indirect impacts of the Approved Project to less than significant ( Class II) resulting from operation of the Approved Project wells.

3.3.1.10 Conflict with Any Local Policies or Ordinances Protecting Biological Resources
The Certified FEIR stated implementation of the various components of the Approved Project would not be expected to be in conflict with local policies or ordinances protecting fisheries resources as the City’s Conservation and Open Space Element Policy 4-a requires that all development proposals provide adequate mitigation measures for identified significant biological resources, including fisheries resources such as O. mykiss. Further, Santa Barbara County’ s Santa Ynez Valley Community Plan includes Policy BIOSYV-7 that states that Southern California steelhead trout is a federally listed endangered species that shall be protected.

As demonstrated in Impact Threshold 5.3.6.1 in Section 5.3 of the Certified FEIR and above in this section, the proposed water diversion of the 1,980-AFY with a maximum diversion rate of up to 5 cfs, a 927 AFY increase above the established baseline of 1,053 AFY and an extraction rate of 1.85 cfs, would not result in either surface or groundwater conditions that would conflict with local policies or ordinances protecting fisheries.

The implementation of the individual components of the Approved Project would comply with all local policies and/ or ordinances protecting biological resources. The Certified FEIR noted the Approved Project would be required to obtain necessary permits from CDFG ( 1602 Streambed Alteration Agreement), Regional Water Quality Control Board ( 401 Permit), USACE ( 404 Permit). Compliance with these regulatory and trustee agency permits would result in less than significant impacts for compliance with state and federal statutes. Further, the regulatory and trustee agencies would protect fisheries resources through enforcement to insure implementation of all conditions in such required permits. Impacts would be less than significant.

Although not a local policy or ordinance, the City is obligated to comply with implementation of the 2000 BiOp for the Cachuma Project. According to the Stetson Engineers analysis ( see first discussion above) 70, locating the six ( 6) new wells downstream of Alisal Bridge about 1.5 miles would mitigate potential impacts to O. mykiss because increased pumping downstream of Alisal Bridge would have less impact on 69 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge. 70 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge. 6.0 Summary and Conclusions ( see Appendix 5.1 in the Certified FEIR). 418
river flows than compared to upstream pumping. The FMP indicated that Alisal Bridge is the farthest downstream Santa Ynez River location from the Bradbury Dam in which the public trust O. mykiss has good to fair quality habitat conditions. 71 Therefore, the Certified FEIR concluded impacts would be less than significant ( Class III).

3.3.1.11 Substantially Degrade Structural Characteristics or Processes of the Aquatic Ecosystem
Implementation of the various components of the Approved Project, except for construction of new wells along the Santa Ynez River, would not substantially degrade any structural characteristics or process of the aquatic system. The Certified FEIR determined impacts will be less than significant.

Construction Impacts
Installation of the six (6) new wells along the Santa Ynez River as part of the Approved Project has potential short-term and long-term impacts that could substantially degrade structural characteristics or processes of the aquatic system. Short-term impacts are associated with construction of the wells, while long-term impacts are associated with both maintenance operations and extraction of groundwater resources.

Short-term impacts to riparian vegetation and the areas surrounding the wells associated with construction were determined to be less than significant.

As previously discussed in Impact Threshold 5.3.6.1 in Section 5.3 of the Certified FEIR and above in this section, the installation of the six (6) new wells would temporarily impact a small area for each potential well site, as well as require the clearing of vegetation to construct the lateral pipelines from the wells to the main conveyance system. Depending on the final well site selection, there also could be impacts to slopes along the riverbank. The Certified FEIR concluded these impacts were less than significant with implementation of BMPs associated with the SWPPP in compliance with City and SWRCB policies and ordinances and revegetation meeting or exceeding permit requirements. Implementation of Certified FEIR Mitigation Measures FIS-1 through FIS-4 would reduce direct and indirect impacts to less than significant Class II).

Impacts During Operation
The proposed increase in diversion to 1,980 AFY with a maximum diversion rate of up to 5 cfs from the Santa Ynez River underflow is discussed under Impact Threshold 5.3.6.1 above. Long-term operation of the proposed new wells is expected to result, on average, in fish flows similar to the current baseline of 1,053 AFY at an extraction rate of 1.85 cfs based on the modeled analysis by Stetson Engineers. Therefore, 71 Santa Ynez River Technical Advisory Committee. 2000. Lower Santa Ynez River Fish Management Plan. Volume I. Page 2-

54. Prepared for the Santa Ynez River Consensus Committee, Santa Barbara, California. Final Report. October 2, 2000. 419
the diversion of 1,980-AFY would not result in a substantial degradation of the structural characteristics or processes of the aquatic ecosystem. Impacts would be less than significant.

The Approved Project (2011 Master Plan Update) considered in the Certified FEIR would replace the City’s existing Water System Master Plan to provide the City with an adequate and reliable water supply and infrastructure to meet future demand forecast in the City’s General Plan at buildout. Implementation of Certified FEIR Mitigation Measure FIS-5 would reduce direct and indirect impacts of the Approved Project to less than significant ( Class II) resulting from operation of the Approved Project wells.

3.3.1.12 Cumulative Impacts
The Approved Project would replace the existing Water System Master Plan to provide the City with an adequate and reliable water supply and infrastructure to meet future demand forecast in the City’s General Plan at buildout. The previous discussion on Certified FEIR specific impacts in Section 5.3 Fisheries Biology in the Certified FEIR and in this section associated with the implementation of the Master Plan Update and the proposed water right Permit 15878 revisions concluded that impacts could be potentially significant but they can be reduced to less than significant with Certified FEIR Mitigation Measures FIS-6 and FIS- 7. The Approved Project contribution to cumulative impacts to fisheries resources would be less than significant with implementation of mitigation measures.

Impacts associated with installation of new wells within Well Sites A and B were determined to be shortterm and less than significant with mitigation, the impacts associated with long-term extraction of groundwater resources is less than significant because the riparian groundwater basin refills almost every winter.

Increasing the City’s maximum annual pumping by 927 AFY above the baseline ( 1,053 AFY with an extraction rate of 1.85 cfs) to 1,980 AFY with a maximum diversion rate of up to 5 cfs would incrementally reduce groundwater store in the Santa Ynez River underflow in the vicinity of the six ( 6) new wells downstream of Alisal Bridge. This is likely to require Reclamation to increase water rights releases from Bradbury Dam to provide fish flows consistent with the Cachuma Project 2000 BiOp because the significant City pumping will occur in the dry months; during that time, the 2000 BiOp requires fish flows downstream of Alisal Bridge. Because the City's pumping will dewater the groundwater storage, however, it could require additional releases of water rights water from the Above Narrows Account. These additional flows could have an incremental benefit for the steelhead, other fish species and riparian vegetation.

The City, Alisal Ranch and other water rights holders on the Santa Ynez river, and the Cachuma Project Contractors coordinate their water diversions and environmental restoration efforts. All parties recognize 420
that exercising their individual rights without careful coordination would potentially impact water available to each entity, as well as the flows required to support O. mykiss. Therefore, various agreements currently formalize some aspects of coordination to minimize impacts. Without the continued increases in coordination between the Santa Ynez River water right holders, water diversion downstream of the Bradbury Dam could result in significant impacts.

The 2000 BiOp that regulates the support and recovery of O. mykiss in the lower Santa Ynez River formally covers only the Cachuma Project. However, water rights holders on the Santa Ynez River have entered into an agreement with the Cachuma Project members to coordinate efforts to comply with requirements of the 2000 BiOp. 72 A reconsultation with NMFS was initiated at the time of the Certified FEIR that could have resulted in identification of additional Reasonable and Prudent Measures ( RPMs) beyond those described in the 2000 BiOp associated with flow management. Downstream of the Alisal Bridge, where the City proposes to install new wells to increase its diversions, the habitat was not as good as that found upstream of the bridge; however, further degradation of this reach would potentially incrementally reduce connectivity and further reduce habitat quality over time. Therefore, the Certified FEIR stated it was important that the proposed increased diversion of Santa Ynez River underflow, at worst, maintains conditions consistent with the current baseline. The proposed extraction of groundwater resources ( even with the new wells located below the Alisal Bridge flow target area) could require additional releases by the Cachuma Project to support groundwater recharge in the “Above Narrows” groundwater basin. Those additional flows will provide some mitigation for potential impacts of the City's increased pumping.

Potential impacts to steelhead migration, spawning and rearing during drought periods, and associated with continuing warming trends in Southern California as a consequence of global climate change are also of concern. The cumulative impact of additional City demands from the Santa Ynez River riparian groundwater basin would be managed as part of water rights releases to the above and below Narrows areas.

The cumulative impact of additional water right extractions would be managed as part of the downstream water rights releases. Participants in a regional coordinated water management effort may include Alisal Ranch, ID No. 1, the City, and other water right holders along the Santa Ynez River and in the proximity of 72 National Marine Fisheries Service ( NMFS), Biological Opinion for U.S. Bureau of Reclamation Operation and Maintenance of the Cachuma Project on the Santa Ynez River in Santa Barbara County, California September 11, 2000. 421
the Alisal Bridge, both upstream and downstream. Impacts associated with the Master Plan Update and the proposed water right Permit 15878 revisions would be less than significant through the application of the recommended cumulative Certified FEIR Mitigation Measure FIS- 6 and FIS- 7 (Class II). Cumulative impacts associated with the construction and installation of the new wells and lateral pipelines were determined to be less than significant ( Class II) as a result of Certified FEIR Mitigation Measures FIS-1 to FIS-4, and the continued implementation of the RPM 1 (Terms & Conditions 1[1]) in the 2000 BiOp to maintain and monitor residual pool depth in Alisal and Refugio reaches during spill years and the first year after spill years, if steelhead are present. The Certified FEIR concluded cumulative impacts associated with ongoing operation and maintenance of the proposed new wells can be reduced to less than significant by implementing a regional, coordinated water extraction plan that protects the public trust fisheries resources, as provided in the Certified FEIR Mitigation Measure FIS-6 (Class II).

3.3.2 Description of the Changes Resulting from Revised Project The Revised Project would be similar to the Certified FEIR but it would be constructed and operated a reduced capacity. The Revised Project proposes up to two new river wells in Well Site B instead of up to 6 new wells in Well Site A and B under the Approved Project. The Revised Project also proposes diverting 1,368 AFY at a maximum rate of 2.84 cfs, which is reduced from the 1,980 AFY at 5 cfs proposed in the Approved Project. The reach of diversion has been substantially reduced from 19,500 feet in the Approved Project to a Final Reach of Diversion of 8,060 feet in the Revised Project. Additionally, other components of the Master Plan Update are the same ( abandon existing Well 7A located between Alisal Ranch and Santa Ynez River Water Conservation District, ID No. 1 river wells) or no longer under consideration ( the previously planned water treatment plant is no longer proposed in the Revised Project) as analyzed in the Certified FEIR.

3.3.3 Changes in City, State, or Local Plans and Regulations Since the City certified the FEIR for the Approved Project, the following changes in City, State, or Local Plans and Regulations have occurred that affect fisheries resources in the Santa Ynez River and are applicable to the Revised Project.

3.3.3.1 2021 Biological Assessment for the Operation and Maintenance of the Cachuma Project
Reclamation adopted a Biological Assessment ( 2021 BA) 73 for the Operation and maintenance of the Cachuma Project in 2021. Reclamation, as the Action Agency, is submitted this 2021 BA to NMFS as part of a consultation process pursuant to section 7(a)(2) of the ESA. It also fulfills consultation requirements 73 US Department of the Interior Bureau of Reclamation South Central California Area Office, Biological Assessment for the Operation and Maintenance of the Cachuma Project, Cachuma Project, Santa Barbara, California Interior Region 10- California Great Basin, April 2021.
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for the Magnuson- Stevens Fishery Conservation and Management Act of 1976 for Essential Fish Habitat EFH).

The 2021 BA defines and evaluates the potential effects of Reclamation’ s proposed discretionary, and non-discretionary, activities at Bradbury Dam and related Cachuma Project facilities on the endangered Southern California Steelhead and their designated critical habitat in the Lower Santa Ynez River compared to baseline conditions as defined in the August 27, 2019 amendment to 50 CFR Part 402 (50 CFR 402, 2019). Although previous consultations have been conducted addressing various Reclamation activities in the Lower Santa Ynez River, the 2021 BA has been prepared to define more clearly the activities at the Bradbury Dam and related Cachuma Project ( the 2021 BA Proposed Action) 74, and potential effects on steelhead and their designated critical habitat attributed to the 2021 BA Proposed Action.

The 2021 BA Proposed Action is composed primarily of terms and flow releases required by the SWRCB Order WR-2019-0148 and non-discretionary activities to fulfill the Congressionally authorized purposes of the Cachuma Project, but also includes some discretionary contracting and maintenance associated conservation measures.

In 2015, NMFS and USFWS amended 50 CFR § 402 ( 80 FR26832) to add a definition of a “ mixed programmatic action” to the joint regulations implementing section 7 of the ESA. A mixed programmatic action is:

A Federal action that approves action(s) that will not be subject to further section 7 consultation, and also approves a framework for the development of future action(s) that are authorized, funded, or carried out at a later time, and any take of a listed species would not occur unless and until those future action(s) are authorized, funded, or carried out and subject to further section 7 consultation.
74 The 2021 BA Proposed Action is comprised of a variety of actions. Reclamation proposes to continue the long-term operation of the Cachuma Project to maximize water supply delivery consistent with applicable laws, contractual obligations, and agreements by storing, diverting, and conveying water in accordance with existing water contracts and agreements, including water service contracts, and current and future Warren Act Contracts, consistent with water rights and applicable laws and regulations including Order WR-2019-0148. Although Reclamation consults on the potential effects of the whole 2021 BA Proposed Action, certain outcomes and sub-actions associated with the 2021 BA Proposed Action are nondiscretionary. See US Department of the Interior Bureau of Reclamation South Central California Area Office, Biological Assessment for the Operation and Maintenance of the Cachuma Project, Cachuma Project, Santa Barbara, California Interior Region 10- California Great Basin, April 2021.
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The amendment also clarifies that an incidental take statement ( ITS) would be provided only for those program actions that are reasonably certain to cause take and are not subject to further section 7 consultation.

This distinction allows for an ITS to be issued for those parts of the action that are specific enough that NMFS can meet the regulatory burden of reasonable certainty. Where that degree of certainty is not met, NMFS may analyze the future action to determine whether jeopardy of a listed species or destruction or adverse modification of designated critical habitat is likely to result from the entirety of the Proposed Action under the 2021 BA, as defined above, and make an overall conclusion for the listed species and designated critical habitat. Once sufficient detail is available for future actions, Reclamation agrees to initiate specific section 7 consultation for these actions as appropriate.

These amendments allow NMFS to analyze the proposed programmatic action with respect to jeopardy and adverse modification standards and issue an ITS only for those actions authorized by the program and for which no additional consultation will occur.

The 2021 BA Proposed Action includes immediate site-specific actions, as well as future actions that may be subject to subsequent site-specific section 7 consultation. This aligns with the description of a “ mixed programmatic action,” and Reclamation proposes to consult on the overall action as such.

Background
Upon completion of conferencing with NMFS on the seismic retrofit project for Bradbury Dam, on April 7, 1999 Reclamation requested formal consultation for the on-going operations and maintenance of the Cachuma Project, including the operation and maintenance of the HCWS. A BiOp was issued by NMFS in 2000 (2000 BiOp). 75
RPM 4 of the 2000 BiOp required Reclamation to reinitiate consultation if the tributary passage impediment and barrier fixes described in the Project description were not completed by 2005. Several tributary projects were not completed by 2005 due to circumstances beyond Reclamation’ s control. 76 A letter requesting re-initiation of consultation on the tributary passage improvement projects was sent to NMFS on December 29, 2005. NMFS acknowledged that request on April 17, 2006. 77 The consultation 75 US Department of the Interior Bureau of Reclamation South Central California Area Office, Biological Assessment for the Operation and Maintenance of the Cachuma Project, Cachuma Project, Santa Barbara, California Interior Region 10- California Great Basin, April 2021.
76 US Department of the Interior Bureau of Reclamation South Central California Area Office, Biological Assessment for the Operation and Maintenance of the Cachuma Project, Cachuma Project, Santa Barbara, California Interior Region 10- California Great Basin, April 2021.
77 US Department of the Interior Bureau of Reclamation South Central California Area Office, Biological Assessment for the Operation and Maintenance of the Cachuma Project, Cachuma Project, Santa Barbara, California Interior Region 10- California Great Basin, April 2021.
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history, prior to the current Proposed Action, was identified in detail in previous consultations on the Cachuma Project.

In 2013, as part of the re-initiation of consultation, Reclamation provided NMFS with a draft BA for the operation and maintenance of the Cachuma Project ( 2013 BA). The 2013 BA evaluated the effects of existing and proposed modifications to Cachuma Project operations and maintenance, as well as proposed conservation measures for steelhead and their habitat in the Lower Santa Ynez River, its tributaries, and in streams on the South Coast. The 2013 BA also included Cachuma Project facilities and associated water transport and delivery structures ( i.e., Tecolote Tunnel, the South Coast Conduit, and four regulating reservoirs on the South Coast) which were not included in the previous consultation for the 2000 BiOp.

On November 28, 2016, NMFS provided the 2016 Draft BiOp to Reclamation which concluded that the proposed action in the 2013 BA was likely to jeopardize the continued existence of the federally endangered Southern California Steelhead DPS and was likely to destroy or adversely modify critical habitat for the species. As a result, the 2016 Draft BiOp included a Reasonable and Prudent Alternative RPA) that changed the operation of the Cachuma Project proposed by Reclamation to avoid jeopardy to the species and destruction or adverse modification of designated critical habitat for the species. The RPA was divided into eight elements containing multiple plans to be developed and studied by Reclamation and actions to be implemented by Reclamation, many of which were outside Reclamation’ s authority to implement.

In the 2016 Draft BiOp, NMFS provided information describing the reasons they believed Reclamation should reinitiate consultation on the Cachuma Project. Several of the factors that NMFS identified as ongoing sources of take were one-time incidents that were subsequently addressed and not repeated.

Current Consultation
On February 3, 2017, Reclamation transmitted an email to NMFS memorializing Reclamation’ s concerns regarding the 2016 Draft BiOp, which were related to the description and modification of Reclamation’ s proposed action, the scientific basis for the analysis and conclusions, and the scope and breadth of the proposed RPA and associated terms and conditions in relation to the limitations of Reclamation’ s legal authorities and the authorized purpose of the Cachuma Project. 78 On June 7, 2018, Reclamation notified NMFS that they would be submitting a revised proposed action and withdrawing the proposed action provided in the 2013 BA. On August 1, 2018, Reclamation provided 78 US Department of the Interior Bureau of Reclamation South Central California Area Office, Biological Assessment for the Operation and Maintenance of the Cachuma Project, Cachuma Project, Santa Barbara, California Interior Region 10- California Great Basin, April 2021.
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NMFS with a revised proposed action developed by the Local Interests2 which included voluntary conservation measures. On November 8, 2019, Reclamation submitted a BA (2019 BA) to NMFS containing the revised proposed action intended to avoid jeopardy of the Southern California Steelhead DPS. On October 25, 2019, the SWRCB provided Order WR-2019-0148, which contains several lawful terms that Reclamation is obligated to implement, and which are in conflict with the proposed action in the 2019 BA.

Reclamation then revised the proposed action to comply with Order WR-2019-0148 and submitted a new BA to NMFS on December 18, 2020 (2020 BA). NMFS notified Reclamation via letter on February 8, 2021 that the 2020 BA contained insufficient information to initiate formal consultation and identified the information needed to initiate consultation. Reclamation provided some of the requested information to NMFS via letter on March 18, 2021 and notified NMFS they would be submitting a revised BA near the end of April 2021.

New Data and Updated Analysis
New significant pieces of information regarding the Southern California Steelhead genetic data were listed in the 2011 five-year status review of the DPS and the 2016 five-year status review of the DPS. 79 Since publication of the 2011 status review new information indicated that significant new genetic data are available for populations across much of coastal California. The latest five-year status review of the Southern California Steelhead DPS concluded there is “ little new evidence to indicate that the status of the Southern California Coast Steelhead DPS has changed appreciably in either direction since the 2011 status review”. 80 NMFS stated that in the 2016 five-year status review of Southern California Steelhead DPS, that “The extended drought and the recent genetic data documenting the high level of introgression and extirpation of native O. mykiss stocks in the southern portion of the DPS has elevated the threats level to the already endangered populations; the drought, and the lack of comprehensive monitoring, has also limited the ability to fully assess the status of individual populations and the DPS as whole.” 81 Conclusions
Overall, the combined effects of the non-discretionary and discretionary aspects of the Cachuma Project Proposed Action on Southern California Steelhead are beneficial when compared to the Without Action WOA). The modeling results illustrate that operation of the Cachuma Project under Order WR-2019-0148 79 US Department of the Interior Bureau of Reclamation South Central California Area Office, Biological Assessment for the Operation and Maintenance of the Cachuma Project, Cachuma Project, Santa Barbara, California Interior Region 10- California Great Basin, April 2021.
80 US Department of the Interior Bureau of Reclamation South Central California Area Office, Biological Assessment for the Operation and Maintenance of the Cachuma Project, Cachuma Project, Santa Barbara, California Interior Region 10- California Great Basin, April 2021.
81 US Department of the Interior Bureau of Reclamation South Central California Area Office, Biological Assessment for the Operation and Maintenance of the Cachuma Project, Cachuma Project, Santa Barbara, California Interior Region 10- California Great Basin, April 2021.
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and the 2021 BA Proposed Action provides necessary flow to ensure adequate conditions for Southern California Steelhead in the Lower Santa Ynez River and Hilton Creek throughout the year.

There may be incidental take associated with the 2021 BA Proposed Action under the 2021 BA; therefore, while the overall effects of the Cachuma Project are considered beneficial to the species, the 2021 BA Proposed Action may adversely affect individual Southern California Steelhead. Avoidance and minimization measures will be implemented to avoid or reduce potential adverse effects, where applicable.

The implementation of the lawful terms of Order WR-2019-0148 is generally expected to improve critical habitat conditions when compared to the WOA. Although operations under the 2021 BA Proposed Action and Order WR-2019-0148 will reduce the quality of freshwater migration corridors when compared to the WOA, it is expected to improve the quality and quantity of spawning and freshwater rearing habitat in the Lower Santa Ynez River and Hilton Creek, which are critical in sustaining the Southern California Steelhead population.

The 2021 BA Proposed Action may occasionally result in temporary and localized adverse effects to critical habitat; however, these would be minimized with the implementation of conservation measures.

Overall, the combined effects of the non-discretionary and discretionary aspects of the Cachuma Project are expected to improve critical habitat conditions that would support egg to smolt survival of steelhead beyond the WOA; however, the Proposed Action under the 2021 BA may result in some adverse effects to freshwater migration corridors through a reduction in the frequency of passage opportunities in most WY types.

3.3.3.2 2019 Endangered Species Act (ESA) Section 7(a)(2) Biological Opinion 2019 BiOp)
On November 15, 2018, NMFS received an application from NMFS’ California Coastal Office in Long Beach applicant) to renew an ESA Section 10 Enhancement of Survival permit for the endangered Southern California ( SC) Distinct Population Segment ( DPS) of steelhead ( Oncorhynchus. mykiss). Although the proposed activities of the application are for the purpose of enhancing the conservation of endangered steelhead, the activities would nonetheless result in take of the species. Accordingly, NMFS prepared a biological opinion to assess the effects of authorizing the requested type and amount of take on the SC DPS. The biological opinion is based on the best scientific and commercial data available, including the description of the enhancement activities (NMFS 2018), a knowledge of and experience in the watershed and streams where the enhancement activities will be conducted, and expected effects of the activities on steelhead.
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NMFS prepared a biological opinion ( NMFS Consultation Number: WCRO- 2019-11596) 82 and incidental take statement ( ITS) in accordance with section 7(b) of the Endangered Species Act.83 The proposed federal actions involves NMFS renewing a 10-year research and enhancement permit 14159- 2R for the NMFS’ California Coastal Office in Long Beach (applicant; the current 10-year permit (#14159) expired on December 31, 2019. The applicant has requested non-lethal take of juvenile and adult steelhead, intentional lethal take of fry, and permission to recover carcasses.

Action area” means all areas to be affected directly or indirectly by the Federal action and not merely the immediate area involved in the action (50 CFR 402.02). The proposed action will take place throughout the entire range of the SC DPS which includes coastal streams from the Santa Maria River to the Mexican border, including the Santa Ynez River.

Based on a review of reports specific to many coastal streams and major rivers within the entire SC DPS, NMFS' familiarity with activities occurring in the action area, and the reported effects of habitat changes or alterations on the aquatic environment, evidence indicates a number of past and present anthropogenic activities have reduced the quality and quantity of habitat within the action area and killed steelhead. These activities involve construction and operation of water storage and diversion facilities, conversion of wildlands, wastewater release to the river, land-use activities, and groundwater pumping.

While some activities are upstream of the action area, which includes all areas throughout the entire range of the SC DPS which includes coastal streams from the Santa Maria River to the Mexican border.

The activities adversely affect steelhead in the action area (e.g., in the case of land-use activities causing input of sand and smaller particles to habitats within the action area, or in the case of a surface-water diversion reducing discharge in the action area).

Surface and groundwater pumping can have impacts on steelhead and their habitat in many coastal streams ( e.g., Gato Creek, San Ysidro Creek, Carpinteria Creek, Gobernador Creek, Rincon Creek, Romero Creek, Montecito Creek) and larger river systems ( e.g., Santa Maria River, Santa Ynez River, Ventura River, Santa Clara River). In some cases, these pumping operations have reduced available surface flows and even dried portions of streams, thereby reducing available habitat quantity and quality for rearing steelhead. In many watersheds there are certain portions of the stream that dry naturally, yearly.

Further, a significant conclusion state in the 20219 BiOp is that “local groundwater pumping over the last 100 years has severely depleted groundwater basins and reduced the frequency and duration of surface 82 National Marine Fisheries Service ( NMFS), Endangered Species Act ( ESA) Section 7(a)(2) Biological Opinion, NMFS Consultation Number: WCRO- 2019-11596, Southern California steelhead ( Oncorhynchus mykiss), June 5, 2019. 83 Endangered Species Act 16 U.S.C. § 1531 et seq., Section 7, Consultations and Conferences, 1973. 428
flows, with subsequent effects on steelhead trout migration and rearing”. 84 Historical accounts in several SC DPS river systems, such as the Santa Ynez River, indicate mainstem flows may have been present year round, suggesting the availability of over-summering habitat ( freshwater rearing sites) for juvenile steelhead in the mainstem. That juvenile steelhead historically reared in mainstem habitats would not be unexpected because such habitat use has been reported in other studies. Given the functional value of mainstem river and coastal stream habitats in the ecology of steelhead, loss of critical habitat such as freshwater rearing sites, through surface and groundwater pumping, is considered unfavorable for the conservation of steelhead. Reductions in the frequency and duration of surface-flow connectivity between tributaries and the mainstem Santa Ynez River, and within the river, increase the potential for disrupting emigration of juvenile steelhead.

3.3.3.3 Southern California Steelhead Recovery Plan
Section 4(f) of the ESA directs NMFS to develop and implement recovery plans ( Southern California Steelhead Recovery Plan [“ Recovery plan”]) for the conservation and survival of listed threatened and endangered species ( NMFS, 2012), including the Southern California Steelhead DPS. Recovery plans also guide federal agencies in fulfilling their obligations under section 7(a)(1) of the ESA, which calls on all federal agencies to “ utilize their authorities in furtherance of the purposes of this Act by carrying out programs for the conservation of endangered species and threatened species.” In addition to outlining proactive measures to achieve species recovery, recovery plans provide a context and framework for other provisions of the ESA with respect to federally listed species, including but not limited to consultations on federal agency activities under section 7(a)(2). Recovery plans must, to the maximum extent practicable, incorporate:
site-specific management actions necessary to achieve the goals of the recovery plans for the conservation and survival of the species;
objective, measurable criteria for the recovery of species that would allow determinations that the species were recovered and therefore eligible for removal from the list of endangered or threatened species; and
estimates of the time and costs required to carry out measures needed to achieve the plans’ goals, as well as intermediate steps toward those goals.

NMFS released the Draft Southern California Steelhead Recovery Plan in July 2009 and subsequently adopted the Final Southern California Steelhead Recovery Plan in 2012 which stated that the goals of the recovery plan were “ to prevent the extinction of Southern California Steelhead in the wild to ensure the 84 National Marine Fisheries Service ( NMFS), Endangered Species Act ( ESA) Section 7(a)(2) Biological Opinion, NMFS Consultation Number: WCRO- 2019-11596, Southern California steelhead ( Oncorhynchus mykiss), June 5, 2019. 429
long-term persistence of viable, self-sustaining populations of steelhead distributed across the Southern California DPS”, and “ to re-establish a sustainable Southern California Steelhead sport fishery”.

3.3.3.4 City of Solvang General Plan – Conservation Element The City updated its General Plan including the Conservation and Open Space Element in 2016. 85 The combined Conservation/ Open Space element ( COSE) promotes the balanced management of these resources based on an overarching theme of sustainability. When used in this COSE, sustainability is defined as the ability to meet the needs of the current generation without compromising the ability of future generations to meet their needs. In practical terms, a sustainable approach reduces resource consumption, avoids pollution, and helps people live healthier lives. In addition, sustainable practices will better position the City to respond to the growing challenges associated with climate change.

The Conservation Element identifies the following goals and policies that would apply to the Revised Project:

Goal 2.1 To Protect and Preserve the Quality of Water from Local Watersheds, Groundwater Basins , and Surface Water Bodies including Creeks and the Santa Ynez river.

Policy 2.1 The City shall promote the protection of surface and groundwater water resources within the local watershed and the Santa Ynez River.

Goal 3.1 To Protect Natural Open Space Areas, Sensitive Native Vegetation, and Wildlife Communities and Habitat.

Policy 3.1 The City shall promote the protection sensitive natural resources, wildlife communities and habitats.

3.3.3.5 Recent Fisheries Status
The COMB, Fisheries Division provides annual monitoring reports of recent fisheries statuses for the LYSR below Bradbury Dam, which is relevant to the Revised Project. Summaries of the 2020 report are provided below as it is relevant to the Revised Project and fisheries resources in the Revised Project area.

The WY2020 Annual Monitoring Summary presents 86 the data and summarizes the results of monitoring Southern California steelhead/ rainbow trout ( Oncorhynchus mykiss, O. mykiss) and water quality conditions in the LSYR below Bradbury Dam during Water Year 2020 ( WY2020, October 1,2019 to 85 City of Solvang, Conservation/ Open Space Element, May 23, 2016. 86 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
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September 30, 2020). Annual monitoring reports for prior years ( 2008 to 2019) by the COMB, Fisheries Division provide data and monitoring results for fish prior years. 87 The 2020 annual monitoring reports summarize data gathered since the prior water year ( WY2019) Annual Monitoring Summary and fulfills the annual 2020 reporting requirements of the Cachuma Project Biological Opinion (BiOp). The BiOp was issued by the NMFS to Reclamation analyses prepared by COMB Fisheries Division staff. In WY2020, some deviations to the monitoring program as described in the 2000 BiOp, Biological Assessment ( BA) prepared by Reclamation in 2000, FMP prepared by the Santa Ynez River Technical Advisory Committee ( SYRTAC) and prior Annual Monitoring Reports/ Summaries were necessary, specifically in relation to water quality monitoring, redd surveys, and migrant trapping. The modifications were required due to landowner access constraints, or program evolution from acquired field knowledge. A shortened version of this report, the WY2020 Annual Monitoring Report, is prepared by COMB Fisheries Division and provided by Reclamation to NMFS for compliance reporting established in the 2000 BiOp.

Since the issuance of the 2000 BiOp, Reclamation, with assistance from COMB, has completed many conservation actions for the benefit of southern steelhead including: the construction and operation of the HCWS and the HCEBS; the completion of tributary passage enhancement projects on Hilton, Quiota, El Jaro, and Salsipuedes creeks; the completion of the bank stabilization and erosion control projects on El Jaro Creek; target flow releases to the LSYR mainstem and Hilton Creek; and the implementation and management of the Fish Passage Supplementation Program. COMB was involved in the planning, design, permitting, and construction of all the tributary projects ( except the HCWS, HCEBS, and Cascade Chute Project in Hilton Creek) and was successful in acquiring grant funding for these projects from state and federal programs. These funds were supplemented by funding from the Cachuma Member Units which allowed for the construction of 14 fish passage projects ( by the end of 2019) restoring access to the upstream reaches of key tributaries in the lower Santa Ynez River Watershed for steelhead. The total number of stream restoration and fish passage projects completed since issuance of the 2000 BiOp is 21 projects.

Summary of WY2020 Monitoring Results
The monitoring tasks completed in WY2020 were performed below Bradbury Dam in the LSYR watershed and in Lake Cachuma, which is approximately half the drainage area ( 450 square miles) and stream 87 The Cachuma Operation and Maintenance Board ( COMB), a Joint Powers Authority under California Government Code section 6500 et seq., and its member agencies, supply the Annual Monitoring Summary Reports for the period from 2008 to 2020. The information is available at: http:// www. cachuma- board. org/ annual- reports- and-documents 431
distance ( 48 miles) to the ocean compared to the entire watershed. 88 The area is within the Southern California Steelhead Distinct Population Segment ( DPS) and the Monte Arido Highland Biogeographic Population Group (BPG) in the Southern Steelhead Recovery Planning Area. Monitoring focused on three management reaches ( Highway 154, Refugio, and Alisal reaches) and the Cadwell Reach on the LSYR mainstem, and tributaries ( Hilton, Quiota, El Jaro, and Salsipuedes creeks) known to support suitable habitat for O. mykiss.

Stormflow Events
There were two (2) stormflow events in Hilton Creek. The first on December 26, 2020 produced a rapid increase and subsequent decrease of the storm hydrograph, creating the potential for fish strandings in high flow channels and margin habitats. 89 One O. mykiss mortality was found. The second natural high flow event was associated with the large April 6, 2020 storm that triggered high streamflow and sediment transport that filled in most pool habitats once again. Nine O. mykiss mortalities were found that either were stranded as the flows receded or might have succumbed to high turbidity. The timing of this event was unfortunate as O. mykiss young-of-the-year (YOY) were already coming out of the gravels at some redd sites and were vulnerable to displacement due to high streamflow. In both events, a report was prepared for Reclamation for submittal to NMFS.

Water Releases
The following chronology is provided for events or milestones that directly influenced flow releases for the O. mykiss population downstream of Bradbury Dam ( including Hilton Creek) throughout the water year: 90
Reclamation released lake water to Hilton Creek through the HCWS by gravity to the URP throughout the water year.

State water deliveries to Lake Cachuma were conducted through the CCWA by-pass pipeline. No State Water was wheeled through the Outlet Works and Penstock. Deliveries were sporadic and of short duration.

December 26, 2020 stormflow event: A short duration streamflow event resulted in one O. mykiss mortality.

April 6, 2020 stormflow event: This large stormflow event resulted in 9 O. mykiss mortalities. 88 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
89 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
90 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
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April 7, 2020 - April 24, 2020: First Fish Passage Supplementation event.

April 25, 2020 – May 13, 2020: Second Fish Passage Supplementation event.

April 25, 202: Lake Cachuma reached peak volume for WY2020 at 156,960 acre-feet at a lake elevation of 740.45 feet above mean sea level.

August 31, 2020 – November 30, 2020: 2020 WR 89-18 releases with a total of 10,480 acre-feet released.

The Santa Ynez River breached on April 7, 2020 and remained open throughout the rest of the water year for a total of 177 days; 55 days were during the migration season ( Figures 2 and 3). During the days of ocean connectivity with the Santa Ynez River, no anadromous O. mykiss were captured or observed during migrant trapping efforts, redd surveys, or bank surveys. Streamflow went to zero at the H Street USGS gauge on May 17, 2020 and remained dry for the rest of the water year except for a short distance during a brief period of the 2020 WR 89-18 releases when the release waters reached about 100-200 feet downstream ( maximum downstream extent of the release).

There was one (1) storm during WY2020 migration season that met the established criteria for passage supplementation; April 7, 2020; a second pulse release was initiated on April 25, 2020 following the end of the first release to facilitate additional smolt movement downstream and was not related to any stormflow event. 91 Because the passage supplementation event occurred in the February to mid-April time period, the established protocol required Reclamation to conduct automatic supplementation. There were 51 days during the migration season where flows were in excess of 25 cfs at the USGS gauging station in Solvang and the lagoon was connected to the ocean. 37 days of the 51 days ( 73 percent) were associated with the Fish Passage Supplementation Program releases. Trapping activities were conducted in the LSYR mainstem ( and in Hilton Creek and Salsipuedes Creek) for all three passage supplementation events. There were five (5) O. mykiss smolts captured in the downstream LSYR mainstem trap (LSYR- 6.08) during the passage supplementation event.

There were no spills from Bradbury Dam in WY2020. 92 Reservoir storage remained above 120,000 acrefeet from the start of the water year (October 1, 2019) through the rest of the water year (September 30, 2020). That reservoir storage required Reclamation to maintain 2000 BiOp target flows of a minimum of 5 cfs to the Hwy 154 Bridge and a minimum of 2 cfs to Hilton Creek. Lake Cachuma water was delivered and discharged to Hilton Creek at the URP from the HCWS by gravity flow throughout the water year. 91 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
92 Cachuma Operation and Maintenance Board ( COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
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Water Rights releases are non-discretionary releases called for by the Santa Ynez River Water Conservation District (downstream Water Rights holders) as described in WR Order 89-18 (WR 89-18).93 There was a 2020 WR 89-18 BNA release that was initiated on August 31, 2020 and ended on November 30, 2020 that discharged 10,480 acre-feet of water from Lake Cachuma to recharge downstream aquifers.

Water Temperature
During WY2020, thermographs were deployed in one of two configurations: single units mainly in the tributaries and 3-unit vertical arrays at selected pool locations within the LSYR mainstem. 94 There were 30 thermograph units deployed at 15 sites on the LSYR mainstem; the LSYR Alisal Pool Thermograph is the nearest one to the City. In the tributaries, there were 12 thermograph units deployed at 12 sites during WY2020, all of which were single unit deployments: the Hilton creek Thermograph is upstream from the City of Solvang wells and Quiota Creek (downstream) are the two (2) closest thermographs for the creeks:

Hilton Creek (HC, 2 sites):

HC-lower (HC-0.12); and
HC-upper (HC-0.54)
Quiota Creek (QC, 1 site):

QC-Crossing 6 (QC-2.66).

The Alisal Bedrock Pool is a corner scour pool habitat approximately 60 feet long and 40 feet wide with a maximum depth of 9 feet. A vertical array was deployed in the habitat from April 30, 2020 to November 11, 2020. Water temperature data at the surface and middle are nearly identical with maximum temperatures fluctuating between 23 °C to 25 °C and minimum temperatures ranging from 20 °C to 22 °C.

Temperatures collected at the bottom of the habitat were notably cooler. No O. mykiss were observed at this habitat, only invasive warm water species.

Lower Hilton Creek ( HC-0.12)
A single thermograph was deployed in a run habitat approximately 250 feet upstream of the delta confluence of Hilton Creek and LSYR mainstem ( Long Pool). 95 The unit was deployed near the bottom in approximately 1.5-foot of water from April 29, 2020 to November 19, 2020. Water temperatures remained near or less than 16 °C during the majority of the deployment period. Year over year O. mykiss 93 Cachuma Operation and Maintenance Board ( COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
94 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
95 Cachuma Operation and Maintenance Board ( COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
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were observed throughout this area during all of WY2020. No invasive species were observed in the lower section of Hilton Creek during spring and fall snorkel surveys.

Upper Hilton Creek ( HC-0.54)
A single thermograph was deployed in a pool habitat adjacent to the URP release site from April 29, 2020 to November 19, 2020. 96 The instrument was placed at the bottom of a pool habitat 20 feet long and 10 feet wide with a depth of approximately 1.5 feet. Water temperatures remained at or less than 15 °C for the majority of the deployment period (Figure 8 (c) and Figure 42). O. mykiss were observed inhabiting the creek at this monitoring location throughout the year indicating optimal rearing conditions. No invasive species were observed in the upper portion of Hilton Creek during spring and fall snorkel surveys.

In comparing water temperatures differences between the Upper and Lower Hilton Creek, data showed less than a 1.5 °C increase in water temperature due to thermal heating between the upper and lower monitoring sites. Splitting the release between the URP and the LRP and increasing to a higher discharge rate would help reduce the effect of thermal heating within the creek and lower LSYR mainstem water temperatures downstream within the Highway 154 Reach during the critical dry season rearing period.

Quiota Creek ( QC- 2.66)
A single thermograph was deployed approximately 20 feet upstream of Crossing 6 on Refugio Road from May 1, 2020 through November 20, 2020. 97 The unit was placed at the bottom of a run habitat 30 feet long and 10 feet wide with a depth of approximately 2.5 feet. Maximum water temperatures fluctuated between 20 °C and nearly 24 °C (mid-August heatwave) during the period of deployment. Minimum water temperatures generally remained below 15 °C except during the heat wave in August. Juvenile O. mykiss were observed rearing in this habitat. However, on October 22, 2020, the pool was no longer maintaining residual pool depth and the creek was drying rapidly.

Migration - Trapping
Migrant trapping activities to monitor both migrating anadromous and resident O. mykiss have been conducted on the Santa Ynez River and/ or several of its tributaries every year since 1993. 98 There were a few exceptions to this due to the endangered listing of steelhead ( 1997), and threatened listing of California red-legged frog (2000) which caused trapping delays due to scientific permitting issues during 96 Cachuma Operation and Maintenance Board ( COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
97 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
98 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
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those years, and WY2013 due to a misinterpretation of a NMFS request by Reclamation. Results from this year’s migrant trapping effort remained below the 2000 BiOp established Incidental Take Statement (ITS) limits.

WY2020 was the seventh year since issuance of the 2000 BiOp that NMFS required staying within the juvenile (110) and adult (150) take limits as described within the BiOp ITS, even though juvenile take had been exceeded multiple times since 2000 and was reported to NMFS. In previous years, the adult take limit was reached but not exceeded; hence the juvenile take exceedance was the concern. To stay within the limits of the ITS and to maximize data gathering with limited take, the trapping effort was focused on upstream adult migration early in the migration season and downstream smolt (juvenile) migration from the middle to the end of the season. The downstream traps at Hilton Creek and Salsipuedes Creek can be modified with a pass-through gate system that allows any fish entering the trap to move through the trap unencumbered. Take was not exceeded during the WY2020 trapping season.

In WY2020, migrant traps were deployed at the same locations as during WY2019. 99 Three sets of paired upstream and downstream migrant traps were deployed for various periods of time at: (1) lower Hilton Creek ( tributary farthest from the ocean) 0.14 miles upstream from the confluence with the mainstem LSYR ( HC-0.14); ( 2) lower Salsipuedes Creek ( tributary closest to ocean) 0.7 miles upstream of the confluence with the LSYR mainstem ( SC-0.7); and ( 3) in the LSYR mainstem 6.08 miles downstream of Bradbury Dam (LSYR- 6.08). Migrant traps were installed in Hilton Creek (February 5, 2020 – May 19, 2020) and Salsipuedes Creek (March 24, 2020 – May 15, 2020) and at the LSYR mainstem ( April 9, 2020 to April 24, 2020). The reason for the late deployment at the LSYR mainstem site was due to low flows that were not favorable for fish passage. The LSYR mainstem trap was pulled early in order to provide unimpeded movement for smolts at the beginning of the second (pulse) Passage Supplementation event.

The weather pattern during WY2020 was not conducive in providing prolonged migratory conditions. 100 A wet December 2019 with 7.19 inches of rain (34.2%) was followed by a dry January ( 0.48 inches) and a dry February ( 0.06 inches). The watershed was primed for a significant runoff event following December, particularly since January and February are typically among the wettest months during the rain year.

However, that did not occur and drying conditions prevailed for the next 60 plus days. A wet March (8.13 inches, 38.2 percent) and April (3.58 inches, 17.0 percent) resulted in a large runoff event starting on April 6, 2020 that opened the lagoon to the ocean for the first time of the water year on April 7, 2020. The lagoon remained open throughout the rest of the water year but flow conditions at H Street reached zero 99 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
100 Cachuma Operation and Maintenance Board ( COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
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on May 17, 2020, eliminating passage opportunities for both upstream migrating anadromous adults and downstream migrating juvenile smolts.

During WY2020, there were 51 passage days with flows greater than 25 cfs at Solvang during the migration season. 101 There were two Passage Supplementation Releases that occurred ( see 2020 Passage Supplementation Report for additional details) near the end of the migration season. The first release occurred April 7, 2020-April 24, 2020 and created 18 passage days. The second release occurred April 25, 2020-May 13, 2020 and created 19 passage days. When combined, both Passage Supplementation Releases accounted for 72.5 percent of all passage days greater than 25 cfs at Solvang during the migration season. Catch per unit effort (CPUE) for the WY2020 at the Hilton, Salsipuedes, LSYR mainstem migrant traps was 82.7 percent, 90.2 percent, and 100 percent efficiency, respectively.

Nighttime fish movement is a well-documented adaptation to avoid predation during migration; the COMB-FD staff checks each trap a minimum of 4 times per 24-hour period. 102 Fish captures are recorded into the following time categories; 1st AM (05:00-10:00), 2nd AM (10:01-14:00), 1st PM (18:00-22:00) and 2nd PM ( 22:01-01:59) depending on when they were captured. WY2020 migrant trapping results suggested O. mykiss were more likely to move during the late night (2nd check) and early morning hours first check).

With 21.03 inches of rain recorded at Bradbury Dam, WY2020 ranked just above the 2 year recurrence interval in Santa Barbara County for total rainfall amount (2-year recurrence = 18.22 inches). The nearest County rainfall station in the El Jaro/ Salsipuedes Creek watershed is at Rancho San Julian (Station 389). 103 In December 2019, Rancho San Julian recorded 7.17 inches of rain. That amount of rain recharged the watershed but did not provide any significant long-term runoff, fish passage opportunity, or reach the lagoon proper as no flow was recorded at the USGS gauging station at H Street until the mid-March storms. It was not until the April 6, 2020 storm that the LSYR mainstem and its tributaries had sufficient streamflow for full ocean/ lagoon connectivity for upstream and downstream fish passage. By April 18, 2020, flows had decreased to less than 5 cfs indicating the small window of opportunity for any migrating adult steelhead attempting to reach Salsipuedes Creek and tributaries up the LSYR mainstem.

In the LSYR, the USGS Solvang gauge during the same storms described above created maximum flows of

36.3 cfs on December 26, 2020 and 1,470 cfs on April 6, 2020. Two passage supplementation releases 101 Cachuma Operation and Maintenance Board ( COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
102 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
103 Cachuma Operation and Maintenance Board ( COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
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were initiated in April and are discussed below. By May 9, 2020, flows in the mainstem had decreased to less than 25 cfs. Baseflows in Hilton Creek remained essentially greater than 3.0 cfs during the migration period, with peak flow events greater than 50 cfs occurring on December 25, 2019, March 16, 2020, March 22, 2020 and April 5, 2020. Migration opportunities were suitable for resident O. mykiss occupying areas downstream of Hilton Creek and within the Highway 154 Reach and are discussed below.

Hilton Creek Migrant Traps
Both upstream and downstream migrant traps were installed from February 5, 2020 through May, 19, 2020, 104 There were 49 upstream migrant captures ranging in size from 65 mm (2.6 inches) to 456 mm

18.0 inches) of which 4 were recaptures. Twenty one of the upstream migrants were classified as parr, 5 were classified as juveniles, 1 classified as a presmolt, and the remainder ( 22) were classified as adults.

Upstream migrating fish were captured throughout the trap deployment and numbers captured were not related to any particular runoff event. There were 90 downstream migrating fish captured ranging in size from 64 mm (2.5 inches) to 400 mm (15.7 inches) of which 10 were recaptures. Downstream migrating fish were captured throughout the trap deployment and numbers captured did show a response to increased flow conditions following elevated flow from stormflow events, particularly after March 24, 2020. Thirty six of the fish were classified as parr, 36 were classified as juveniles ( including smolts and presmolts and the remainder ( 18) were classified as adults. Of the downstream migrating fish, 32 were classified as smolts or presmolts with 2 captured in February, 11 in March, 17 in April, and 2 in May.

Average smolt size varied by month and the cumulative average was 141.7mm ( 5.6 inches). No anadromous O. mykiss were captured.

During the 104 days of trapping operations, both the upstream and downstream traps operated for a period of 86 days (82.7 percent efficiency). 105 The traps had to be removed for a total of 18 days during 3 storm events. The catch per unit effort (CPUE) for upstream and downstream fish was 0.57 and 1.05 captures per day, respectively. Of the 139 migrant captures, 100 (72 percent) occurred during the hours of darkness showing that the majority of migrating fish travel at night to reduce predation.

Salsipuedes Creek Migrant Traps
Trapping was conducted in Salsipuedes Creek from March 24, 2020 through May 15, 2020. 106 Only 2 upstream migrating O. mykiss were captured one measured 298 mm (11.7 inches) and the other measured 104 Cachuma Operation and Maintenance Board ( COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
105 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
106 Cachuma Operation and Maintenance Board ( COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
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73 mm ( 2.9 inches). There was only one downstream migrating fish captured measuring 68 mm ( 2.7 inches). All of the migrant captures occurred following the April 6, 2020 storm event.

No smolts were captured in Salsipuedes Creek in WY2020; this finding illustrates the detrimental impact of the previous drought in terms of O. mykiss survival and smolt production within the Salsipuedes/ El Jaro Creek watershed. The O. mykiss population in the basin is still recovering from the prolonged drought.

Only 1 of the 3 migrating fish was captured during the hours of darkness ( Table 9). No anadromous O. mykiss were captured.

During the 51 days of trapping operations, both the upstream and downstream migrant trap operated for a period of 46 days (90.2 percent efficiency). 107 The traps had to be removed for a total of 5 days during 1 storm event. The CPUE for Salsipuedes was an anemic 0.04 captures per day for upstream and 0.02 captures per day for downstream.

Trapping results in Salsipuedes Creek illustrated the impact that the recent drought has had on the O. mykiss population inhabiting the watershed. Prior to the drought, wet year types (1995, 1998, 2001, 2005, 2008, and 2011) resulted in numerous adult upstream captures and many downstream smolt captures. 108 During the last two wet years, ( WY2017 and WY2019), no upstream migrating fish have been captured and only one smolt has been captured at the Salsipuedes Creek trap site, with none captured in WY2020.

LSYR Mainstem Trap
Trapping was conducted in the LSYR mainstem approximately 6.08 miles downstream from Bradbury Dam from April 9, 2020 through April 24, 2020. 109 There were two consecutive Fish Passage Supplementation releases initiated ( April 7, 2020 and April 20, 2020), only during the first event was the trap operated.

During the second event ( Pulse flow release) the traps were pulled to assure no impediment to fish passage. Storm events in combination with passage supplementation releases provided 51 days of flow greater than 25 cfs at the Alisal Bridge (37 consecutive days from April 7, 2020 to May 13, 2020). Through the LSYR mainstem trap deployment, no upstream migrants were captured. There were 5 downstream migrating O. mykiss captured, all classified as smolts with an average length of 201.6 mm (7.9 inches). The first smolt was captured on April 12, 2020 and the last smolt was captured on April 24, 2020. The smallest smolt measured 169 mm ( 6.7 inches) and the largest measured 264 mm (10.4 inches). Invasive warm water species captured included largemouth bass, green sunfish, bluegill, carp, bullhead catfish, and 107 Cachuma Operation and Maintenance Board ( COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
108 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
109 Cachuma Operation and Maintenance Board ( COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
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bullfrogs. The vast majority of the invasive species were captured in the downstream trap indicating they were moving downstream with elevated flows during the Passage Supplementation event.

During the 15 days of trapping operations, both the upstream and downstream migrant traps operated for a period of 15 days ( 100 percent efficiency). 110 Even though the second Passage Supplementation Release ended on May 13, 2020, flow at Solvang recorded a daily flow of 23.0 cfs on May 10, 2020 and flows continued to decline for the remainder of the spring.

Fish Observations
There were 34 redds documented across the LSYR basin, none in the LSYR mainstem as all were in the tributaries. 111 Spring, summer, and fall snorkel surveys showed an elevated level of spawning success with many year over year (YOYs) observed in Hilton, Quiota and Salsipuedes/ El Jaro creeks. The number of observed YOYs was not as high as during WY2019, most likely due to the large stormflow event associated with the April 6, 2020 storm that washed out many YOYs and redds. There was ample fish passage potential for migrating fish but no anadromous fish were observed even with 2 fish passage supplementation events.

Status of Steelhead in the Action Area
Lower Santa Ynez River and Tributaries
Historically, O. mykiss in the Santa Ynez River probably supported the largest steelhead run in Southern California. 112
Population abundance and effective population size is low in the Lower Santa Ynez River. In 2008, estimates based on genetic analysis suggested that between 11 and 61 spawning adult O. mykiss mean=28.2) constituted the breeding population in Salsipuedes Creek and between 17 and 131 spawning adult O. mykiss ( mean=50.5) in Hilton Creek. The small effective population size of the Lower Santa Ynez River O. mykiss population puts it at risk of genetic drift, inbreeding, and potential extirpation from catastrophic events, such as the 2012–2016 drought, 2017–2018 Thomas Fire and subsequent debris flow, and sediment loading in streams used by O. mykiss.
110 Cachuma Operation and Maintenance Board ( COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
111 Cachuma Operation and Maintenance Board (COMB), Fisheries Division, WY2020 Annual Monitoring Summary, February 24, 2021.
112 US Department of the Interior Bureau of Reclamation South Central California Area Office, Biological Assessment for the Operation and Maintenance of the Cachuma Project, Cachuma Project, Santa Barbara, California Interior Region 10- California Great Basin, April 2021.
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Fish trapping data on the Santa Ynez River from 1995 to 2020 provides a multiyear set of quantitative data on steelhead numbers in the river (Tables 2 and 4 in Appendix D of the 2021 BA). Since 1995, migrant trapping efforts have resulted in the capture of 34 individual anadromous adult steelhead at the three trapping sites. This is a minimum count of actual returns because traps must be removed at high flows when anadromous fish are likely traveling upstream. During the latest drought ( 2012–2016), the Santa Ynez River lagoon bar did not breach during years 2013–2016, nor in 2018 (Table 1 in Appendix D of the 2021 BA); no adult steelhead were able to enter the river to spawn in those years. Likewise, smolts were not able to out migrate to the ocean during those years. In such instances, steelhead may stray to another stream that is open for upstream migration. Recent studies have determined there is substantial migration between the Santa Ynez River and other regional steelhead populations.

Fish conservation measures implemented as part of the Fish Management Plan 113 and 2000 BiOp resulted in an initial increased juvenile O. mykiss abundance. In 2005 and 2006, a dramatic increase in O. mykiss abundance occurred in the Refugio and Alisal reaches of the mainstem river. 2005 was the third wettest year on record, followed by 2006 which was an above normal year, and the high numbers of fish present in those years may have been a response to favorable, very wet year habitat conditions in conjunction with long-term target flows. However, abundance in the Refugio and Alisal reaches then declined after 2006, despite three out of four years (2007 through 2011) being Wet or Above Normal precipitation years SYRAMC, 2009; COMB 2011-2012; COMB, 2011; Reclamation, 2013a; Reclamation, 2011b). The observed lack of overall increase in O. mykiss abundance in the Refugio and Alisal reaches may be due to additional factors. These factors include potentially unsuitable water quality conditions, observed increases in predatory warm-water invasive species, and increases in beaver activity and dams which improve habitat for predatory warm-water species.

Adult and juvenile O. mykiss have been observed in several tributaries during snorkeling surveys and during downstream and upstream weir trapping as shown in Figure 3-3 and Tables 2 and 3 of Appendix D of the 2021 BA. More recent population abundance estimates are provided in NMFS’ five-year status reviews for the Southern California Steelhead DPS in 2005.

In the Lower Santa Ynez River, steelhead have access to the mainstem and its tributaries. Results of snorkel surveys and migrant trapping indicate that O. mykiss successfully reproduce and rear primarily in Hilton Creek, the Salsipuedes/ El Jaro drainage, Quiota Creek, and San Miguelito Creek.

Snorkel survey data indicate that the tributary O. mykiss overall abundance has increased over time whereas mainstem abundance is relatively flat. Completion of tributary passage projects increased access 113 Santa Ynez River Technical Advisory Committee with Technical Support by ENTRIX, Inc., Santa Ynez River Consensus Committee, Lower Santa Ynez River Fish Management Plan, October 2, 2000. 441
to rearing and spawning habitat which has in part contributed to this increasing trend. O. mykiss observations during the recent extended drought (2012–2016) indicate a sharp decrease in abundance in both tributaries and the mainstem, although in 2019, spring snorkel surveys observed a little more than 2,000 individuals, the majority of which were young of the year (YOY).

The Monitoring Program discontinued monitoring activities in Alisal, Nojoqui, Alamo Pintado, and San Miguelito creeks because exploratory monitoring activities indicated O. mykiss were not present in these streams or, if present, were physically isolated from the anadromous population.

Given the expected impacts from climate change, as well as impacts from natural climate patterns such as El Niño and WY type, impacts from catastrophic events will likely become more common and influence both the abundance and the distribution of adult and juvenile O. mykiss.

The extent of estuarine habitat use in the Lower Santa Ynez River watershed by steelhead has not been determined, although a few O. mykiss captured in the Salsipuedes Creek migrant traps were believed to have reared in the Santa Ynez River Estuary ( Reclamation, 2013b).

Status of Steelhead Critical Habitat in the Action Area Critical habitat in the Lower Santa Ynez River was initially issued by NMFS on February 16, 2000. 114 Critical habitat includes all waters and substrates below natural impassable barriers that have existed for several centuries and below several dams that block steelhead from using historical upstream habitat areas.

The Lower Santa Ynez River mainstem is an important migration corridor between the Pacific Ocean and Highway 154 Reach and Lower Santa Ynez River tributaries. Flows in the Lower Santa Ynez River mainstem are dependent on precipitation- induced runoff from the watershed downstream of Bradbury Dam and controlled and uncontrolled water releases from Bradbury Dam. Flow generally increases during the wet season, and then recedes in the spring as precipitation decreases. Storm events increase flows in the mainstem, providing connectivity through the mainstem migration corridor to the tributaries, where relatively higher quality spawning and rearing habitat is available. Spills at Bradbury Dam in combination with large storm events can cause large channel- altering flows in the mainstem, resulting in shifts of the geomorphology of the riverbed. Typically, these shifts do not alter the overall structure or location of critical passage riffles.

For steelhead to migrate into and out of the Santa Ynez River basin, flows must be sufficient to breach the berm of the lagoon. At times, the sandbar at the lagoon is breached solely by flows from Salsipuedes Creek 114 US Department of the Interior Bureau of Reclamation South Central California Area Office, Biological Assessment for the Operation and Maintenance of the Cachuma Project, Cachuma Project, Santa Barbara, California Interior Region 10- California Great Basin, April 2021.
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which can exceed 100 cfs and build up the hydraulic head against the berm. In Dry and Critical Dry years, the berm may not breach during the entire migration season.

The Passage Supplementation Program, implemented as part of the 2000 BiOp (and as amended in 2005 in accordance with RPM No. 3 in the 2000 BiOp) and continued under Order WR-2019-0148, extended the descending limb of selected storms’ hydrographs to aid in the migration of steelhead. Passage supplementation releases were determined to increase the migration opportunities for steelhead in the Lower Santa Ynez River over pre-2000 BiOp conditions. In WY 2006 and WY 2010, 18 and 23 additional passage days were provided through the passage supplementation program, respectively. Most recently in WY 2019 and WY 2020, an additional 44 and 32 passage days were provided through the Passage Supplementation Program, respectively.

In most years, water quality conditions are suitable for steelhead migrating upstream in the mainstem throughout the upstream migration season ( January through May). In some years, by April, water temperatures can reach levels that may inhibit steelhead migration at the Narrows near Lompoc and DO concentrations can fall to stressful or lethal levels in pool habitats near Solvang. In these years, habitat conditions may potentially limit late-season upstream migration. During the downstream migration season ( January through May), water quality is most suitable for juvenile O. mykiss outmigration in the early portion of the year before water temperatures exceed levels that inhibit smoltification. Water temperatures in the Highway 154 Reach are usually cooler than in the downstream reaches and remain suitable for smolt outmigration through the first half of the downstream migration season from January into March. Data from USGS gages downstream of the Highway 154 Bridge suggest that water temperatures may discourage smoltification of steelhead in those areas throughout much of the migration season.

In Hilton Creek, water temperatures are typically suitable for successful steelhead spawning and incubation throughout most of the spawning season. Substrate suitable for steelhead spawning is more available in Hilton Creek compared to the mainstem. Some observations suggest that since 2006, spawning substrate availability may have decreased in Hilton Creek due to decreased gravel abundance, possibly as a result of bank stabilization due to increased riparian growth. There is typically little fine sediment in Hilton Creek and turbidity is typically low, only becoming elevated in response to high flow storm events. In 2017, Reclamation implemented a short-term gravel augmentation project in Hilton Creek to provide additional spawning habitat and to monitor habitat usage and spawning. Redd usage of the new substrate was observed, in at least one case less than six days after the gravel augmentation.

Hilton Creek traditionally has been a sediment- starved system with limited spawning gravels and sources of replenishment available for O. mykiss. Gravel augmentation in Hilton Creek was implemented over a 443
two-year program starting in January 2018. Prior to gravel augmentation, the 2017 Whittier Fire burned an estimated 18,430 acres along Highway 154 including 40 percent (819 acres) of the upper watershed of Hilton Creek. Storm events in 2018 and 2019 mobilized sediments in Hilton Creek from runoff through the Whittier Fire burn areas. Both augmented and natural gravel deposition has increased the availability of spawning habitat for O. mykiss and likely contributed to the rebound of O. mykiss production after the extended drought (Figure 3, Appendix D of the 2021 BA).

Due to flow supplementation with cool water, over-summering water temperatures in Hilton Creek are appropriate for successful steelhead rearing. Of all monitoring locations in the Lower Santa Ynez River basin, Hilton Creek water temperatures are typically the coolest during the over-summering season, generally staying below 18°C in the reaches downstream of the HCWS release points. Water from the HCWS/ EBS is aerated as it is released, which ensures DO levels are suitable for steelhead. The riparian corridor of Hilton Creek is closed below the HCWS URP and provides bank vegetation, shading, woody debris input for habitat complexity, and cover from predators. Qualitative observations since 2001 also show substantial increases in instream cover components in the creek, which contribute to increased habitat diversity and quality for steelhead. Pools, some greater than three feet deep, accounted for approximately 25 percent of the habitat in the watered sections of Hilton Creek during a 2001 habitat survey.

However, observations during the 2019 Hilton Creek spring snorkel survey found that a large deposition of natural sediment from the Whittier Fire burn area had been mobilized due to high stream runoff from 2019 winter storms. Further, survey observations found that “ many of the historical pool habitats were either filled with sediment or are vastly reduced in size due to the high sediment load and deposition.” This continued into the Long Pool which was estimated to have lost approximately 50 percent of its size and depth due to sediment deposition, particularly towards to upstream end of the habitat. As surveyed in 2019, runs and riffles dominated the Hilton Creek habitat type from the URP through the confluence with the Lower Santa Ynez River.

3.3.3.6 Cachuma Project Operations
Reclamation currently provides releases from Bradbury Dam to the Lower Santa Ynez River to produce perennial flow conditions in the Highway 154 Reach pursuant to the 2000 BiOp and Order WR-2019- 0148. 115 Flows are also maintained in the Refugio and Alisal reaches by providing rearing releases in years when Bradbury Dam spills and the spill amount is greater than 20,000 AF and in years following a spill exceeding 20,000 AF. Under Order WR-2019-0148, flows are also required to be maintained at Alisal 115 US Department of the Interior Bureau of Reclamation South Central California Area Office, Biological Assessment for the Operation and Maintenance of the Cachuma Project, Cachuma Project, Santa Barbara, California Interior Region 10- California Great Basin, April 2021.
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Bridge in Wet and Above Normal water years ( WYs). Surface flows downstream of Alisal Bridge are intermittent and seasonal, with sections typically running dry by the end of the migration period in most years.

Order WR-2019-0148 requires Reclamation to release or bypass water to maintain the Mainstem Rearing Flows from the 2000 BiOp at all times, except during Wet and Above Normal WY types when higher flows are required. Reclamation has been implementing Order WR-2019-0148 flows as required since its release on September 17, 2019.

Releases for rearing habitat are made through a combination of the Bradbury Dam River Outlet Works and the HCWS and alternative water supply systems. Since its installation in 2000, the HCWS has been operated consistent with the system description in the 2000 BA Revised Section 3, except during periods of failure. Reclamation has installed the EBS and other alternative water supply systems to maintain required flows when needed. The HCWS was designed to provide perennial flow and habitat in Hilton Creek, which previously had only ephemeral habitat. Reclamation has met the requirement to maintain a minimum of 2 cfs in Hilton Creek through the HCWS since 1999, except during periods of flow interruption and Critical Drought Operations.

The HCWS is a mechanical system and, as such, is subject to unexpected failures such as those experienced during the recent drought. During these unexpected failures O. mykiss mortality and fish rescue occurred.

Reclamation has since installed alternative water supply systems. The provision of releases from the HCWS and alternative watering systems into Hilton Creek has resulted in perennial surface water and a dependent resident population of O. mykiss.

Prior to implementation of rearing target flows under the 2000 BiOp and Order WR-2019-0148, flow frequently ceased during the summer and fall in the Lower Santa Ynez River mainstem reaches below Bradbury Dam. Even prior to construction of Bradbury Dam and storage in Lake Cachuma, flows in the lower river typically dried up below the dam. Flow is now perennial in the Highway 154 Reach, due to water releases for rearing supplementation and the HCWS and alternative water supply systems. The increased surface flow has improved migration corridors in the Lower Santa Ynez River and Hilton Creek by increasing the amount of riparian growth present along the stream margins.

Despite an increase in riparian vegetation in the Alisal and Refugio reaches, temperatures remain high during the summer in these reaches, where water temperature and DO concentrations are potentially unsuitable for steelhead. The releases appear to influence water temperatures beneficially in only the 5- mile long reach from the dam through upper Refugio Reach (Appendix C of the 2021 BA). The habitat flow releases appear to moderate or counter the influence of air temperature on water temperature conditions 445
within the first 5 miles or so below the dam, but not farther downriver. There appears to be a large-scale geomorphic control on water temperature in the reach between approximately 5.5 miles and 6.5 miles below the dam, effectively overriding any cooling influence of water releases from Bradbury Dam downstream. Farther downstream, near the Alisal Bridge, water quality conditions do not appear to be conducive to supporting over-summering juvenile O. mykiss ( Appendix C of the 2021 BA), where water temperature and DO concentrations can be stressful to lethal during the rearing supplementation flow releases. In these areas, DO concentrations reach levels at night that appear low enough to preclude juvenile O. mykiss during portions of the summer.

Densities of O. mykiss appear to have initially increased in the upper portion of the Lower Santa Ynez River mainstem following implementation of the long-term target flows. These increases have been followed by an apparent decline in fall population numbers, which may be the result of typical population response to habitat maturation but may also be the result of an increase in the abundance of introduced predatory species and beaver dams. The recent, severe drought also impacted O. mykiss abundance throughout the Lower Santa Ynez River watershed (Appendix D of the 2021 BA).

Increased surface flow in the upper reaches of the Lower Santa Ynez River throughout the summer months has resulted in a substantial increase in beaver dams and associated pools, altering the passage conditions in the Lower Santa Ynez River mainstem. Beavers were observed only occasionally in the Lower Santa Ynez River mainstem and Salsipuedes and El Jaro creeks during fish monitoring activities from 1997 through 2004, and beaver dams increased in abundance in the years following implementation of longterm target flows in 2005. From 2007 to 2012, beaver dam surveys documented that the number of beaver dams in the mainstem has increased substantially. Beaver dams may be affecting steelhead migration corridors in the mainstem Lower Santa Ynez River by creating barriers and impediments that block or impair both upstream and downstream passage of steelhead when flows are not sufficient to overtop or breach beaver dams. Furthermore, beaver ponds can harbor warm-water, non-native species that are predators and competitors of salmonids.

Term 15 of Order WR-2019-0148 states that Reclamation, “ shall operate and maintain the Cachuma Project and implement conservation measures including but not limited to those described in Revised Section 3 of the Biological Assessment for Cachuma Project Operations and the Lower Santa Ynez River, June 2000…” Reclamation continues to implement the following actions described in the 2000 BA and 2000 BiOp pursuant to the 2000 BiOp and Term 15 of Order WR-2019-0148: The Fish Passage Supplementation Program, Emergency Winter Operations ( now referred to as “ Winter Storm Operations”), Water Rights Releases, ramping of flow releases, conservation measures for releases of CCWA’ s SWP water to the Lower Santa Ynez River, operation of the HCWS, fish rescue, and the Monitoring Program.
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The Fish Passage Supplementation Program has been operated as outlined in the 2000 BiOp, with modifications approved by NMFS, to provide additional migration opportunities in the mainstem for O. mykiss to reach the tributaries below Bradbury Dam. Trapping data from the years in which passage supplementation occurred ( WY 2006, WY 2010, WY 2019, and WY 2020), suggest that passage supplementation on the receding limb of a storm flow event may assist out migrating juvenile O. mykiss within the Lower Santa Ynez River mainstem. Evidence of anadromous adults returning during passage supplementation has not been confirmed.
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3.3.4 Comparison of the Potential Impacts in the Certified FEIR with the Revised Project

3.3.4.1 A Substantial Adverse Effect on Any Species Identified as Endangered, Rare, or Threatened
Construction Impacts
As with the Approved Project, the Revised Project will include temporary activities associated with installation of the wells could include access by construction equipment, and grading and vegetation removal in a relatively small area (approximately 2,500-square feet) for each well (which would be used for the drilling rig, stockpiling, and other equipment parking). However, the Revised Project only includes construction of up to two wells in Well Site B, instead of six wells in Well Sites A and B.

The development and testing of each well may require the release of up to approximately 300,000 gallons of pumped water. Releases of this water would be directed in such a way as to avoid sedimentation, erosion, and maximize groundwater recharge. As this water will be discharged at least 150 feet from the active river channel and the water will percolate back to the underflow, the Certified FEIR determined that impacts to surface water quality or quantity, and subsequent effects on fish in the River, not expected from the Approved Project. Since the Revised Project only includes construction of up to two wells in Well Site B (instead of six wells in Well Sites A and B) impacts to surface water quality or quantity (discussed in Section 3.1.4.1, above), and subsequent effects on fish in the River, are also not expected from the Revised Project.

As the proposed well sites will be located outside of the active channel, and above the ordinary high water mark, any impacts are expected to be temporary. Additionally, standard BPMs associated with the SWMO and analogous Santa Barbara County requirements ( Santa Barbara County Code, Title 29, Article IV and Santa Barbara County Code, Title 14), as applicable, will be implemented in compliance with City, County, and state policies and ordinances. Therefore, the impacts to fish species identified as endangered rare or threatened would be less than significant. Although the Revised Project would have less effect on endangered, rare, or threatened species, the implementation of Mitigation Measures FIS- 1 through FIS4 would document that the reduced direct impacts of the Revised Project would be less than significant.

Therefore, with respect to fish species identified as endangered rare or threatened, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.
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Impacts During Operation
At the time of the Certified FEIR, the City’s analysis of its future water demand has determined that the full buildout need is 1,980 AFY of water with a maximum diversion rate of up to 5 cfs. This amount was greater than the documented use at the time since 1990 ( see Table 3.0-2 in Section 3.0 of the Certified FEIR) and the maximum annual diversion from the Santa Ynez River underflow determined by the SWRCB see Section 3.6: Existing Use and Baseline in the Certified FEIR) of 1,053 AFY at an extraction rate of 1.85 cfs. However, the Certified FEIR determined diversion of up to 1,980 AFY with a maximum diversion rate of up to 5 cfs would not result in the potential to significantly impact listed special- status fish species because the hydrology modeling of Stetson Engineers 116 indicates that groundwater elevation levels and stream flow would remain similar to the existing levels.

The Certified FEIR noted operation of up to six (6) new wells located in either proposed Well Sites A or B may have limited long-term impacts on groundwater resources in the Additional Reach of Diversion immediately downstream of Alisal Bridge. The Revised Project includes only two (2) wells to be installed at Well Site B and shifts the Reach of Diversion downstream.

The Certified FEIR noted during dry years it is anticipated that additional releases from the Cachuma Project would be required in order to satisfy the water right requirements of the Above Narrows basin if the groundwater levels decrease in response to pumping further downstream. Coordination with other pumpers upstream and downstream is needed to ensure that sufficient flow is maintained to support survival and recovery of the species to a “good condition” during drought events. The 2000 BiOp does not identify the reach downstream of Alisal Bridge to be suitable for habitat maintenance.

The modeling results from Stetson Technical Memorandum No. 6 indicate that the Santa Ynez River alluvium in Site B would be able to meet both the planned monthly average and peak demands of the City under the Approved Project (at the time of the Stetson Technical Memorandum No. 6, the City’ s demands were based on a combined annual rate of 2,400 AFY and an instantaneous pumping rate of 5 cfs from the City’ s river wells) because the alluvial deposits are thicker, and the well yields are typically higher in Well Site B compared to Well Site A. The Certified FEIR concluded impacts to O. mykiss upstream migration 116 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge ( see Appendix 5.1 of the Certified FEIR).
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would be considered less than significant as the implementation of the Approved Project would not significantly alter winter flows.

The Revised Project would result in similar or less impacts as the Approved Project in that the City, is requesting a reduced production level of 1,368 AFY. This amount accommodates the City’ s need for water from the wells under the Revised Project taking into account year to year variability in the City’ s need for river underflow depending on availability from other water supply sources and climactic conditions. The requested production level of 1,368 AFY and up to 2.84 cfs is less than the 1,980 AFY and 5.0 cfs requested under the Approved Project evaluated in the Certified FEIR.

Changes reflected in the Revised Project were made to minimize possible river well pumping impacts to other upstream wells operated by Alisal Ranch and ID. No 1. The City has elected to make the following modifications:

Utilizing only the proposed change in the Reach of Diversion previously discussed in the Certified FEIR downstream to solely use in Well Site B (minimizes impacts to Alisal Ranch and ID No. 1 River wells),
Decreasing the original request for the length of Reach of Diversion discussed in the Certified FEIR from 19,500 feet to 8,060 feet,
Limit volume of planned river well pumping to its historical maximum annual diversion (from 1,980 to 1,368 AFY),
Limiting proposed maximum diversion rate to 2.84 cfs from 5 cfs as discussed in the Certified FEIR, and
Following the installation of two wells proposed for Well Site B, the City will abandon Well 7A as originally proposed in the Certified FEIR.

The GSI May 2021 Memorandum, based upon review of (a) regulatory requirements as stipulated in the 2000 and 2019 BiOps and in Water Rights Order 2019-0148 and ( b) technical analyses conducted to evaluate various pumping scenarios as presented in Stetson Technical Memoranda Nos 1 to 6, determined the Revised Project will have less impact than the diversion modeled by Stetson because it will:
reduce the number of wells,
reduce the planned maximum annual pumping volume from 1,980 AFY to 1,368 AFY ( a 31 percent reduction), and
reduce the maximum instantaneous pumping rates from 5 to 2.84 cfs (a 43 percent reduction).

The proposed Well Site B under the Revised Project is downstream of the designated critical management reach for O. mykiss, which means additional releases for fish would not be required in order to maintain 450
the habitat and target flows upstream of the Alisal Bridge and impacts to O. mykiss upstream migration would be considered similar to or less than those considered in the Certified FEIR in that the Revised River Wells Project will extract less water than the Approved Project.

The recent GSI November 2021 memorandum analyzed the portion of the Santa Ynez River directly downstream from Alisal Bridge, under Existing ( Baseline) Conditions, Critical, Dry, Below Normal Above Normal and Wet years.

The future surface water flow conditions were modeled analytically ( see GSI November 2021 memorandum; Appendix B) to estimate the flow conditions that would occur under two scenarios:

Scenario 2(b): Conditions that are likely to occur if the State Water Board denies Solvang’ s Petition for Change; and
Scenario 2(c) Conditions that are likely to occur if the State Water Board grants Solvang’ s Petition for Change.

The calculations of streamflow conditions were completed for the above two scenarios and baseline river conditions observed during the period of record. Following the summary of streamflow conditions, the effects of these changes are presented relative to the effects on “curtailment” of diversion from the City’s river wells.

A summary of the change of the river flow at Alisal Bridge under Scenarios 2(b) and 2(c) relative to Existing Baseline) Conditions is presented in Table 3.1-4, which shows the average number of months in each water year (October 1 to September 30) type that exhibited reduced and higher flow at the Alisal Bridge, along with the average change in flow during those months. These data are presented without climate change considered -- the effects of climate change are discussed later.

As presented on Table 3.1-4 and discussed in more detail in Section 3.1.3.4: Updated Technical Memoranda, above, for water year type on a monthly basis, the calculated river flow at the Alisal Bridge was reduced in some months and higher in other months relative to the Existing ( Baseline) Conditions.

During months when reduced flow would occur, the degree of this reduction of flow at the Alisal Bridge would be less under Scenario 2(c) Conditions ( which assume the City’ s Petition for Change is granted and the Revised Project can go forward) relative to Scenario 2(b) Conditions ( which assume the City’s Petition for Change is denied). Likewise, this reduced flow would occur during fewer months under Scenario 2(c) Conditions during Dry, Below Normal and Wet years; the number of months that would include reduced flow would be unchanged during Critical and Above Normal years. 451
The model results analyzed in Stetson Technical Memorandum No. 6 presented the predicted drawdown during the late summer months during which there is no flow within the Santa Ynez River and when the most drawdown would be expected. At the upstream boundary of Well Site B, drawdown at the previous, higher pumping rates as evaluated in the Certified FEIR varied between four (4) feet (at a distance of 3,000 feet upstream) and seven (7) feet (at a distance of 1,000 feet upstream) in the Stetson modeling results.

Similarly, drawdown under these conditions in the downstream direction varied between one (1) foot (at a distance of 6,000 feet) and four (4) feet (at a distance of 2,000 feet). When the Santa Ynez River is flowing even without the increased fishery releases under Order 2019-0148, the anticipated drawdown was predicted to be much less, at near zero drawdown, at a distance of 1,000 feet downstream. As such, as noted in the Certified FEIR for the Approved Project, under the Revised Project the effects of local drawdown of groundwater levels from the proposed wells along the Santa Ynez River downstream of Alisal Bridge would not extend to the Lompoc Narrows.

The GSI May 2021 Memorandum found the anticipated drawdown from the Revised Project would be less than what was modeled by Stetson. Given the reduced scope of the Revised Project, the effects of local drawdown will also not extend to the Lompoc Narrows.

Equally importantly, additional water rights releases and regulatory fishery releases from the Cachuma Project will ensure that target flows required by the 2000 BiOp and SWRCB Order 2019-0148 are satisfied.

Specifically, the Term 18 Plan provides guidance for these releases ( see Section 3.1, above). 117 Based on a comparison of the Stetson analysis, 118 pumping at 2,400 AFY, the GSI May 2021 Memorandum, and the recent GSI November 2021 memorandum that considered the City’ s reduced 1,368 AFY, the effects of the Revised Project would be less than that those of the Approved Project on stream flows, thereby resulting in less effect on any species within the Santa Ynez River.

As noted in the Certified FEIR, Well Site B to be used by the City under the Revised Project is downstream of the designated critical management reach for O. mykiss. Therefore, the Certified FEIR concluded reduction in water level in that reach where Well Site B is located would not trigger additional releases for fish. In addition, reductions in groundwater levels in that reach would generally not require additional releases to maintain the habitat and target flows upstream of the Alisal Bridge. Impacts to O. mykiss upstream migration would be considered similar to or less than those considered in the Certified FEIR in that the Revised River Wells Project will extract less water than the Approved Project; as such impact 117 U.S. Department of Interior, Bureau of Reclamation, Cachuma Order WR 2019-0148 Term 18 Plan, Cachuma Project, California, dated May 2021.
118 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge, Table 17 ( see Appendix 5.1 in the Certified FEIR).
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would be less than significant as the implementation of the Revised Project would not significantly alter winter flows.

During dry years it is anticipated that additional releases from the Cachuma Project would be required in order to satisfy the water right requirements of the Above Narrows account if the groundwater levels decrease in response to pumping further downstream. This would be implemented through Santa Ynez River Water Conservation District and COMB' s operational compliance with the 2000 BiOp 119 as well as under SWRCB Order WR 0148-2019.

The City is obligated to comply with the 2000 BiOp. The Certified FEIR stated continued coordination between the City with other pumpers upstream and downstream would occur to ensure that sufficient flow is maintained to support survival and recovery of the species to a “ good condition” during drought events. As such, as the Certified FEIR concluded that for both Well Sites A and B, impacts to O. mykiss from pumping from new wells along the proposed extended area of diversion at Wells Site B would be less than significant. The Revised Project would also have less than significant impacts to O. mykiss because upstream migration would be considered similar to or less than those considered in the Certified FEIR in that the Revised River Wells Project will extract less water than the Approved Project; as such impact would be less than significant as the implementation of the Revised Project would not significantly alter winter flows.

Wells would use submersible pumps, noise from which is negligible, and far below that of the current background levels. Night lighting would not be installed on the wells, and maintenance and monitoring of the wells would be conducted during daylight hours, accessing the sites along existing dirt roads. The Certified FEIR determined these impacts would be considered less than significant. This would be true also for the Revised Project, which proposes only two new wells in Wells Site B.

The Certified FEIR also noted no impacts to federally endangered Tidewater goby would be anticipated as a result of the Approved Project as they are not found in this reach. This would be true also for the Revised Project as it will result is less pumping and extraction of water.

Although the Revised Project would have less effect on potential river flows, the implementation of Certified FEIR Mitigation Measures FIS- 1 through FIS- 5 would document that the reduced direct impacts of the Revised Project would be less than significant resulting from construction and operation of the proposed new water wells. Indirect impacts of the Revised Project related to site preparation and construction activities would also be reduced to less than significant. 119 National Marine Fisheries Service ( NMFS), Biological Opinion for U.S. Bureau of Reclamation Operation and Maintenance of the Cachuma Project on the Santa Ynez River in Santa Barbara County, California September 11, 2000. 453
Therefore, with respect to fish species identified as endangered rare or threatened, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.3.4.2 A Substantial Adverse Effect on Any Species Identified as a Candidate, Sensitive, or Special- Status Species in Local or Regional Plans, Policies, or Regulations or by the USFWS, CDFW, or NMFS Construction Impacts
The Certified FEIR stated construction activities, including the well drilling and construction, would temporarily impact small areas ( approximately 2,500 square feet) for each of the well sites, as well as require the clearing of vegetation in a path ( approximately 25 to 30 feet wide) connecting the lateral pipelines from the wells to the main conveyance system. The Certified FEIR noted depending on the final well site selection for individual wells in either Well Sites A or B, there could be impacts to slopes along the riverbank as well. The Revised Project would only include Wells Site B and the same activities would occur but for only two wells. Impacts from the Revised Project would be potentially significant.

Implementation of Certified FEIR Mitigation Measures FIS-1 through FIS-4, direct and indirect impacts from the Revised Project would be reduced to less than significant ( Class II).

As the well would be located outside of the active channel, and above the ordinary high water mark, the Certified FEIR for the Approved Project determined impacts from either Wells Site A or B to habitat along the river edge are expected to be temporary and less than significant. As the Revised Project would only include Well Site B and involve installation of up to two wells, impacts also be less than significant.

If the Revised Project disturbs more than one acre of land then it would be required to obtain a General Permit and implement a SWPPP. If the Revised Project disturbs less than one acre of land and a SWPPP under the General Permit is not required, the construction of the proposed wells under the Revised Project would be subject to the City’ s SWMO and/ or applicable provisions of the Santa Barbara County’ s Stormwater Management and Discharge Control program ( Santa Barbara County Code, Title 29, Article IV) and grading permit requirements ( Santa Barbara County Code, Title 14). The City would also implement standard BMPs associated with the SWMO and analogous Santa Barbara County requirements ( Santa Barbara County Code, Title 29, Article IV and Santa Barbara County Code, Title 14), as applicable, in compliance with City, County, and SWRCB policies and ordinances. Implementation of BMPs and revegetation according to CDFW standards required of Section 1602 streambed alteration agreements would reduce these impacts to less than significant.
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Well Site B for the Revised Project is located outside of the City’s boundary in unincorporated Santa Barbara County, as such, as noted in the Certified FEIR for the Approved Project, the City would be required to comply with Santa Barbara County Ordinance No. 3095 that establishes creek and river setback requirements to address flood hazards to structures and other development. 120 In general, development shall be set back a minimum of 50 feet from the top of bank of streams and creeks and 200 feet from the top of bank of the Santa Ynez River; under the Revised Project, the City has committed to locating wells at least 100 feet from the top of bank of streams and creeks.

Impacts from construction to non-listed special- status species would be less than significant or less than significant with implementation of Certified FEIR Mitigation Measures FIS-1 through FIS-5. Therefore, with respect to non-listed special- status species, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

Impacts During Operation
As previously noted in Section 5.3 of the Certified FEIR the City’ s proposed increase in water diversion via groundwater wells under the Approved Project to 1,980 AFY with a maximum diversion rate of up to 5 cfs from the baseline of 1,053 cfs at an extraction rate of 1.85 cfs would not result in the potential to significantly impact non-listed special- status fish species. As explained further below, the Revised Project would result in less water diversion ( 1,368 AFY at a rate of up to 2.84 cfs), and potential impacts to nonlisted special status species from the operation of the Revised Project would also be less than significant.

The Certified FEIR determined impacts to the Arroyo chub (California Species of Special Concern) were anticipated to be less than significant, as these small fish are adapted to seasonally interrupted flow conditions and move into refugia habitat as flows decrease during warm months.

As analyzed under Impact Threshold 5.3.6.1 in Section 5.3 of the Certified FEIR for the Certified FEIR Project and above in Section 3.3.4.1 this Addendum, impacts to O. mykiss during various life stages and critical habitat during periods of low flow and drought conditions would be less than significant for the Revised Project.

The GSI November 2021 Memorandum found that in Above Normal and Wet years under if the Revised Project is implemented or if the City proceeds to operate under current operation criteria, even under conservative assumptions, the City’s planned diversions will not adversely affect streamflow at Alisal Bridge. For all other water year types (Critical, Dry, Below Normal), if the City’ s Petition for Change were 120 Santa Barbara County Ordinance No. 3095, County Code 15B, Development Along Watercourses. 455
denied, decreased flows at Alisal Bridge would occur compared to both current baseline conditions and of the Revised Project was implemented. This is because proposed monthly diversion volumes in if the City’ s Petition for Change is denied are typically greater than historical diversion volumes, and diversions that influence flow at the Alisal Bridge area are greater if the City’ s Petition for Change is denied than if the Revised Project is implemented.

As noted in the GSI November 2021 memorandum, whereas, for water year types Critical, Dry, and Below Normal, if the Petition for Change were granted increased flows at Alisal Bridge would occur compared to both baseline conditions and if the Petition for Change is denied. Streamflow at the Lompoc Narrows under the Revised Project may be slightly reduced (between 0.7 and 1.8 cfs on average) compared to both baseline conditions and if the Petition for Change is denied given the simplified assumptions employed by GSI that the Solvang diversions from the Well Site B area directly reduce the downstream flows. It is well established, however, that there are other hydrologic considerations that may augment the downstream flow amounts or may contribute to streamflow loss between the City’ s reach of diversion and the Lompoc Narrows.

As previously discussed in Section 5.1 of the Certified FEIR and Section 3.1 Hydrology, Water Supply, and Water Quality of this Addendum, the Certified FEIR determined surface water flow in the Santa Ynez River for the Approved Project would remain similar to the baseline and would therefore not result in potentially significant impacts to non-listed special- status fish species. Based on the analysis in the GSI November 2021 Memo summarized above, the Revised Project would result in increased flows at the Alisal Bridge when compared to current pumping levels. Streamflow at the Lompoc Narrows would be slightly reduced under the Revised Project under the very conservative and simplified assumptions used by GSI, but there are other hydrologic considerations that impact surface flow at the Lompoc Narrows.

Based on this analysis, the Revised Project will also not result in potentially significant impacts to nonlisted special- status fish species. The Revised Project would implement Certified FEIR Mitigation Measure FIS-5 to reduce direct and indirect impacts of the Revised Project to less than significant. Therefore, with respect to non-listed special- status species, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.3.4.3 Substantially Degrade the Quality of the Environment ( CEQA Section 15065)
Construction Impacts
Short term impacts associated with construction of the Revised Project would be less than significant with the implementation of BMPs associated with the SWMO and analogous Santa Barbara County 456
requirements ( Santa Barbara County Code, Title 29, Article IV and Santa Barbara County Code, Title 14), as applicable, in compliance with City, County, and SWRCB policies and ordinances.

As previously noted, construction activities, including the well drilling and construction, would temporarily impact small areas for each of the individual well locations with Well Site B, as well as require the clearing of vegetation to construct the lateral pipelines from the wells to the main conveyance system. As noted, wells will be located at least 100 feet from the from the top of bank of streams and creeks. Further, as previously noted, under NPDES Municipal General Permit for Small MS4s ( Order No. 2013-0001- DWQ) General Permit No. CAS0000004 Waste Discharge Requirements for Storm Water Discharges from Small Municipal Separate Storm Sewer Systems; the General Permit establishes certain unincorporated areas on the South Coast, including the Santa Ynez Valley, in which Santa Barbara County is responsible for water quality in storm-drains and surface drainages, 121 the City would also implement standard BMPs associated with the SWMO and analogous Santa Barbara County requirements ( Santa Barbara County Code, Title 29, Article IV and Santa Barbara County Code, Title 14), as applicable, in compliance with City, County, and SWRCB policies and ordinances. Implementation of BMPs and revegetation according to CDFW standards required of Section 1602 streambed alteration agreements would reduce these impacts to less than significant.

Impacts from the Revised Project would be potentially significant. Implementation of Certified FEIR Mitigation Measures FIS-1 through FIS-4 for the Revised Project would reduce direct and indirect impacts from the Revised Project to less than significant ( Class II). Therefore, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

Impacts During Operation
As discussed above, the Revised Project would not result in significant impacts associated with routine operation and maintenance of the two (2) new wells within Well Site B, or with impacts associated with extraction of groundwater resources. Long-term impacts associated with maintenance operations would be less than significant as disturbances would not cause substantial degradation to the quality of the environment. The Revised Project would implement Certified FEIR Mitigation Measure FIS-5 to reduce direct and indirect impacts of the Revised Project to less than significant.

Impacts from the Revised Project would be less than significant. Therefore, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant 121 County of Santa Barbara, Public Works Department, Stormwater Management program. Storm Water Management Program countyofsb. org)
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impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.3.4.4 Substantially Reduce the Habitat of a Fish or Wildlife Species ( CEQA Section 15065)
Construction Impacts
Construction of the two (2) new wells within Well Site under the Revised Project could have the potential to impact the critically designated habitat for O. mykiss, and could temporarily disrupt the connectivity of fisheries habitat. However, as with the proposed Project in the Certified FEIR, the Revised Project’ s short term impacts associated with construction will be less than significant with the implementation of BMPs associated with the SWMO and analogous Santa Barbara County requirements ( Santa Barbara County Code, Title 29, Article IV and Santa Barbara County Code, Title 14), as applicable, in compliance with City, County, and SWRCB policies and ordinances.

Implementation of the Revised Project could result in temporarily impacts to small areas of land for each potential induvial well site within Well Site B, as well as require the clearing of vegetation connecting the lateral pipelines from the wells to the main conveyance system. Depending on the final individual well site selection, there could be impacts to slopes along the riverbank as well. However, as noted, wells will be located at least 100 feet from the from the top of bank of streams and creeks.

These impacts are potentially significant. However, implementation of Certified FEIR Mitigation Measures FIS-1 through FIS-4 identified for the Approved Project would be implemented for the Revised Project to reduce direct and indirect impacts to less than significant ( Class II). Therefore, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

Impacts During Operation
As discussed under Impact Threshold 5.3.6.1 in Section 5.3 of the Certified FEIR and above in this Addendum, long-term operation of the proposed new wells of 1,368 AFY at an extraction rate of up to

2.84 cfs would be less than the 1,980 AFY and up to 5 cfs for the Approved Project. The Approved Project is expected to result in fish flow operations on average at about the same level as the baseline of 1,053 AFY at an extraction rate of 1.85 cfs that was the baseline at the time of the Certified FEIR based on the modeled analysis in the Certified FEIR for the Approved Project by Stetson Engineers 122 The Certified FEIR 122 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge. 458
concluded impacts from the Approved Project would not substantially reduce the habitat of any fish species and are considered to be less than significant.

Impacts from the Revised Project would be less than those of the Certified FEIR Project as the extraction and pumping rate is less as noted in the GSI May 2021 Memorandum. Furthermore, the GSI November 2021 memorandum found that, even under conservative assumptions, the planned diversions under Revised Project will not adversely affect streamflow at Alisal Bridge in Above Normal and Wet years and will result in increased flows compared to the baseline for Critical Dry, Dry and Below Normal years. The Revised Project would implement Certified FEIR Mitigation Measure FIS-5 to reduce direct and indirect impacts of the Revised Project to less than significant.

Therefore, impacts from the Revised Project would be less than significant. The changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.3.4.5 Cause a Fish or Wildlife Population to Drop Below Self-Sustaining Levels ( CEQA Section 15065)
Construction Impacts
As discussed under Impact Threshold 5.3.6.2 in Section 5.3 of the Certified FEIR and above in this Addendum, drilling and construction of the new wells could temporarily impact a small area for each individual well sites. This would include the clearing of vegetation around each well site and connecting the lateral pipelines from the new wells to the main conveyance system. As noted, wells will be located at least 100 feet from the from the top of bank of streams and creeks.

These impacts were determined to be potentially significant for the Approved Project and would be potentially significant for the Revised Project. Implementation of Certified FEIR Mitigation Measures FIS1 through FIS-4 identified for the Approved Project would be implemented for the Revised Project to reduce direct and indirect impacts to less than significant ( Class II). Therefore, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

Impacts During Operation
The City proposes a Santa Ynez River underflow diversion to 1,368 AFY of water with a maximum diversion rate of up to 2.84 cfs. Impacts from the Revised Project would be less than those of the Certified FEIR 459
Project as the extraction and pumping rate is less as noted in the GSI May 2021 Memorandum.

Furthermore, the GSI November 2021 memorandum found that, even under conservative assumptions, the planned diversions under Revised Project will not adversely affect streamflow at Alisal Bridge in Above Normal and Wet years and will result in increased flows compared to the baseline for Critical Dry, Dry and Below Normal years. As such, diversion of up to 1,368-AFY under the Revised Project would not cause the fish population to drop below self-sustaining levels and impacts would be to be less than significant. The Revised Project would implement Certified FEIR Mitigation Measure FIS-5 to reduce direct and indirect impacts of the Revised Project to less than significant. Therefore, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts as the Revised River Wells Project will divert less water (see the GSI May 2021 Memorandum) than evaluated in the Certified FEIR, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.3.4.6 Substantially Reduce the Number or Restrict the Range of an Endangered, Rare, or Threatened Species ( CEQA Section 15065) Construction Impacts
Drilling and constructing the two (2) new wells under the Revised Project could temporarily impact a small area for each potential individual well site, as well as require the clearing of vegetation to construct the lateral pipelines from the wells to the main conveyance system. As noted, wells will be located at least 100 feet from the from the top of bank of streams and creeks.

Impacts During Operation
The City proposes to increase water diversion to 1,368 AFY with a maximum diversion rate of up to 2.84 cfs via groundwater wells from the underflow of the Santa Ynez River. Impacts from the Revised Project would be less than those of the Certified FEIR Project as the extraction and pumping rate is less as noted in the GSI May 2021 Memorandum. Furthermore, the GSI November 2021 memorandum found that, even under conservative assumptions, the planned diversions under Revised Project will not adversely affect streamflow at Alisal Bridge in Above Normal and Wet years and will result in increased flows compared to 460
the baseline for Critical Dry, Dry and Below Normal years. As such, the diversion of 1,368 AFY would not result in a substantial reduction in the number or restrict the range of an endangered, rare, or threatened fish species. Impacts due to the Revised Project would be less than significant. The Revised Project would implement Certified FEIR Mitigation Measure FIS-5 to reduce direct and indirect impacts of the Revised Project to less than significant. Therefore, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.3.4.7 Reduce the Area or Habitat Value of Critical Habitat Areas Designated under FESA ( Essential Fish Habitat)
Construction Impacts
The Revised Project would temporarily impact a small area for each of the proposed individual new well sites and would require the clearing of vegetation connecting the lateral pipelines from the proposed new individual wells to the main conveyance system. Depending on the final well site selection, there could be impacts to slopes along the riverbank as well. However, as noted, wells will be located at least 100 feet from the from the top of bank of streams and creeks.

These impacts were determined to be potentially significant for the Certified FEIR Project and would be potentially significant for the Revised Project. Implementation of Certified FEIR Mitigation Measures FIS1 through FIS-4 identified for the Certified FEIR Project would be implemented for the Revised Project to reduce direct and indirect impacts to less than significant ( Class II). Therefore, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

Impacts During Operation
The City proposes to increase water diversion to 1,368 AFY with a maximum diversion rate of up to 2.84 cfs via groundwater wells from the underflow of the Santa Ynez River. Impacts from the Revised Project would be less than those of the Certified FEIR Project as the extraction and pumping rate is less as noted in the GSI May 2021 Memorandum. Furthermore, the GSI November 2021 memorandum found that, even under conservative assumptions, the planned diversions under Revised Project will not adversely affect streamflow at Alisal Bridge in Above Normal and Wet years and will result in increased flows compared to the baseline for Critical Dry, Dry and Below Normal years. As such, the diversion of 1,368 AFY would not result in a substantial reduction in the number or restrict the range of an endangered, rare, or threatened fish species. Long-term impacts associated with maintenance operations were concluded to be less than significant with the implementation of routine standard practices and BMPs. The Revised Project would 461
implement Certified FEIR Mitigation Measure FIS-5 to reduce direct and indirect impacts of the Revised Project to less than significant.

Impacts for the Revised Project would be less than significant. Therefore, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.3.4.8 Cause a Substantial Adverse Effect on Any Riparian Habitat or Other Sensitive Natural Communities
Construction Impacts
The Certified FEIR stated construction of the six (6) new wells for the Approved Project would be short term and impacts would be less than significant. The Revised Project is only constructing two (2) wells within Well Site B. Construction of these two new wells along the Santa Ynez River would also temporarily impact a small area for each of the future individual well sites, as well as require the clearing of vegetation to construct the lateral pipelines from the wells to the main conveyance system. Depending on the final well site selection, there also could be impacts to slopes along the riverbank as well. However, as noted, wells will be located at least 100 feet from the from the top of bank of streams and creeks.

These impacts were determined to be potentially significant for the Approved Project and would be potentially significant for the Revised Project. Implementation of Certified FEIR Mitigation Measures FIS1 through FIS-4 identified for the Approved Project would be implemented for the Revised Project and would reduce direct and indirect impacts to less than significant (Class II). Therefore, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

The Certified FEIR stated extraction of groundwater underflow of the Santa Ynez River associated with the water pumping from the Certified FEIR Project could cause local depressions in the groundwater levels.

As previously noted, the model results analyzed in Stetson Technical Memorandum No. 6123 presented the predicted drawdown during the late summer months during which there is no flow within the Santa Ynez River and when the most drawdown would be expected. At the upstream boundary of Well Site B, drawdown at the previous, higher pumping rates as evaluated in the Certified FEIR varied between 4 feet at a distance of 3,000 feet upstream) and 7 feet ( at a distance of 1,000 feet upstream). Similarly, drawdown under these conditions in the downstream direction varied between 1 foot (at a distance of 6,000 feet) and 4 feet (at a distance of 2,000 feet). When the Santa Ynez River is flowing even without the increased fishery releases under Order 2019-0148, the anticipated drawdown was predicted to be much less, at near zero drawdown, at a distance of 1,000 feet downstream.

Stetson Technical Memorandum No. 6 modeled four new wells at a combined annual rate of 2,400 AFY and an instantaneous pumping rate of 5 cfs within Well Site B. The number of wells, the volumes, and instantaneous pumping rates analyzed in Stetson Technical Memorandum No. 6 are higher than is currently being considered under the Revised Project. The Revised Project only includes two wells in Well Site B with a maximum combined annual pumping rate of 1,368 AFY and a maximum instantaneous pumping rate of 2.84 cfs. Furthermore, the modeled conditions under the Certified FEIR represented a scenario where the most drawdown would be anticipated.

The Revised Project includes fewer wells (two), lower overall annual pumping volumes ( 1,368 AFY) and a reduced maximum instantaneous pumping rate of 2.84 cfs compared to the modeled results as presented in the Certified FEIR. Thus, the Revised Project is smaller in scale than the scenario modeled in TM No. 6, feasible under current river conditions and reduces adverse effects associated with the Project, as considered in the Certified FEIR. Furthermore, greater than 50 percent of the diversion ( 800 AFY) will return to the Santa Ynez River alluvium as effluent from the City’ s wastewater treatment facility percolation ponds, 124 based on the last several years of data.

The Revised Project’ s extraction of underflow from the Santa Ynez alluvium has been refined compared to that of the Approved Project considered in the Certified FEIR. Changes reflected in the Revised Project 123 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge. 124 The City’ s wastewater treatment facility and associated percolation ponds are located on the south side of the Santa Ynez River at approximately the eastern ( upstream) extent of the Site B area. 463
were made to minimize possible river well pumping impacts to other upstream wells operated by Alisal Ranch and ID. No 1.

If the water levels were to drop below the root zone of the riparian vegetation for an extended period of time, these plants could become stressed and could eventually die. Impacts from the Revised Project would be less than those of the Certified FEIR Project as the extraction and pumping rate is less as noted in the GSI May 2021 Memorandum. Therefore, operational impacts to riparian or sensitive vegetation for the Revised Project would be less than significant.

Impacts from the Revised Project would be less than significant. The Revised Project would implement Certified FEIR Mitigation Measure FIS-5 to reduce direct and indirect impacts of the Approved Project to less than significant resulting from operation of the Revised Project wells. Therefore, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.3.4.9 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
Construction Impacts
Drilling and construction of new wells under the Revised Project would temporarily impact a small area for each potential individual well site as well as require the clearing of vegetation in a path connecting the lateral pipelines from the wells to the main conveyance system. As noted, wells will be located at least 100 feet from the from the top of bank of streams and creeks.

These impacts were determined to be potentially significant for the Approved Project and would also be potentially significant for the Revised Project. Implementation of Certified FEIR Mitigation Measures FIS1 through FIS-5 identified for the Approved Project would be implemented for the Revised Project to reduce direct and indirect impacts to less than significant ( Class II). Therefore, with respect to movement of resident or migratory species, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR. 464
Impacts During Operation
The City proposes to divert 1,368 AFY with a maximum diversion rate of up to 2.84 cfs via groundwater wells from the underflow of the Santa Ynez River. Impacts from the Revised Project would be less than those of the Certified FEIR Project as the extraction and pumping rate is less as noted in the GSI May 2021 Memorandum. Furthermore, the GSI November 2021 memorandum found that, even under conservative assumptions, the planned diversions under Revised Project will not adversely affect streamflow at Alisal Bridge in Above Normal and Wet years and will result in increased flows compared to the baseline for Critical Dry, Dry and Below Normal years. As such, the diversion of 1,368 AFY would not result in a substantial reduction in the number or restrict the range of an endangered, rare, or threatened fish species. Long-term impacts associated with maintenance operations were concluded to be less than significant with the implementation of routine standard practices and BMPs.

As with the Approved Project evaluated in the Certified FEIR, impacts for the Revised Project would be less than significant. Therefore, with respect to movement of resident or migratory species, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.3.4.10 Conflict with Any Local Policies or Ordinances Protecting Biological Resources
Implementation of the various components of the Revised Project would not be in conflict with local policies or ordinances protecting fisheries resources as the City’s Conservation and Open Space Element. 125 The Conservation Element, updated in 2016 after the Certified FEIR was approved, identifies the following goals and policies that would apply to the Revised Project:

Goal 2.1 To Protect and Preserve the Quality of Water from Local Watersheds, Groundwater Basins , and Surface Water Bodies including Creeks and the Santa Ynez river.

Policy 2.1 The City shall promote the protection of surface and groundwater water resources within the local watershed and the Santa Ynez River.

Goal 3.1 To Protect Natural Open Space Areas, Sensitive Native Vegetation, and Wildlife Communities and Habitat.
125 City of Solvang, General Plan, Conservation/ Open Space Element, May 23, 2016. 465
Policy 3.1 The City shall promote the protection of sensitive natural resources, wildlife communities and habitats.

Further, Santa Barbara County’ s Santa Ynez Valley Community Plan126 includes Policy BIO-SYV-7 that states that Southern California steelhead trout is a federally listed endangered species that shall be protected.

The proposed water diversion of the 1,369 AFY with a maximum diversion rate of up to 2.84 cfs would not result in either surface or groundwater conditions that would conflict with local policies or ordinances protecting fisheries because the impacts from the Revised Project would be less than those of the Certified FEIR Project as the extraction and pumping rate is less as noted in the GSI May 2021 Memorandum.

The implementation of the individual components of the Revised Project would comply with all local policies and/ or ordinances protecting biological resources. As with the Approved Project evaluated in the Certified FEIR, the Revised Project would be required to obtain necessary permits from CDFW ( 1602 Streambed Alteration Agreement), Regional Water Quality Control Board ( 401 Permit), USACE ( 404 Permit), as applicable. Compliance with these regulatory and trustee agency permits would result in less than significant impacts for compliance with state and federal statutes. Further, the regulatory and trustee agencies would protect fisheries resources through enforcement to insure implementation of all conditions in such required permits.

Impacts from the Revised Project would be less than significant.

Although not a local policy or ordinance, the City is obligated to comply with implementation of the 2000 BiOp for the Cachuma Project and the 2019 BiOp for the endangered SC DPS of steelhead ( Oncorhynchus mykiss). 127 According to the Stetson Engineers analysis, 128 locating the six (6) new wells downstream of Alisal Bridge about 1.5 miles would mitigate potential impacts to O. mykiss because increased pumping downstream of Alisal Bridge would have less impact on river flows than compared to upstream pumping.

The FMP129 indicated that Alisal Bridge is the farthest downstream Santa Ynez River location from the Bradbury Dam in which the public trust O. mykiss has good to fair quality habitat conditions. 130 126 County of Santa Barbara, Santa Ynez Valley Community Plan, October 6, 2009. 127 National Marine Fisheries Service ( NMFS), Endangered Species Act ( ESA) Section 7(a)(2) Biological Opinion, NMFS Consultation Number: WCRO-2019-11596, Southern California steelhead (Oncorhynchus mykiss), June 5, 2019. 128 Stetson Engineers. Technical Memorandum No. 6. Additional Alternative Analyses for City of Solvang’ s CEQA Environmental Document for Time Extension for Water Rights Permit 15878 – New Wells Downstream of Alisal Bridge. 6.0 Summary and Conclusions.
129 Santa Ynez River Technical Advisory Committee with Technical Support by ENTRIX, Inc., Santa Ynez River Consensus Committee, Lower Santa Ynez River Fish Management Plan, October 2, 2000. 130 Santa Ynez River Technical Advisory Committee. 2000. Lower Santa Ynez River Fish Management Plan. Volume I. Page 2-54.

Prepared for the Santa Ynez River Consensus Committee, Santa Barbara, California. Final Report. October 2, 2000. 466
Impacts from the Revised Project would be less than significant ( Class III). Therefore, with respect to local policies and ordinances protecting biological species, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.3.4.11 Substantially Degrade Structural Characteristics or Processes of the Aquatic Ecosystem
Construction Impacts
Installation of the new wells along the Santa Ynez River as part of the Revised Project have potential shortterm and long-term impacts that could substantially degrade structural characteristics or processes of the aquatic system. Short-term impacts are associated with construction of the wells, while long-term impacts are associated with both maintenance operations and extraction of groundwater resources. Short-term impacts to riparian vegetation and the areas surrounding the wells associated with construction were determined to be less than significant.

The installation of new wells would temporarily impact a small area for each individual potential well site, as well as require the clearing of vegetation to construct the lateral pipelines from the wells to the main conveyance system. Depending on the final well site selection, there also could be impacts to slopes along the riverbank.

Impacts from the Revised Project would less than significant with implementation of BMPs associated with the SWMO and analogous Santa Barbara County requirements ( Santa Barbara County Code, Title 29, Article IV and Santa Barbara County Code, Title 14), as applicable, in compliance with City, County, and SWRCB policies and ordinances and revegetation meeting or exceeding permit requirements. Although the Revised Project would have less effect on substantial degradation of characteristics or processes of the aquatic ecosystem, the implementation of Mitigation Measures FIS-1 through FIS-4 would document that the reduced direct impacts of the Revised Project would be less than significant. Therefore, with respect to aquatic ecosystems, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

Impacts During Operation
The Revised Project proposes a diversion of the 1,369 -AFY with a maximum diversion rate of up to 2.84 cfs. As discussed in Section 3.3.4.10, above, the Revised Project would not result in either surface or groundwater conditions that would conflict with local policies or ordinances protecting fisheries. 467
Impacts from the Revised Project would be less than those of the Certified FEIR Project as the extraction and pumping rate is less as noted in the GSI May 2021 Memorandum. Furthermore, the GSI November 2021 memorandum found that, even under conservative assumptions, the planned diversions under Revised Project will not adversely affect streamflow at Alisal Bridge in Above Normal and Wet years and will result in increased flows compared to the baseline for Critical Dry, Dry and Below Normal years.

Therefore, the diversion of 1,368 AFY would not result in a substantial degradation of the structural characteristics or processes of the aquatic ecosystem. Although the Revised Project would have less effect on substantial degradation of characteristics or processes of the aquatic ecosystem, the implementation of Mitigation Measure FIS- 5 would document that the reduced direct impacts of the Revised Project would be less than significant.

Impacts from the Revised Project would be less than significant. Therefore, with respect to aquatic ecosystems, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.3.4.12 Cumulative Impacts
The previous discussion on Certified FEIR specific impacts in Section 5.3 Fisheries Biology in the Certified FEIR and in this section associated with the implementation of the Master Plan Update and the proposed water right Permit 15878 revisions concluded that impacts could be potentially significant but they can be reduced to less than significant with Certified FEIR Mitigation Measures FIS- 6 and FIS- 7. The Certified FEIR Project contribution to cumulative impacts to fisheries resources would be less than significant with implementation of mitigation measures. Impacts associated with installation of new wells within Well Sites A and B under the Approved Project were determined to be short-term and less than significant with mitigation, the impacts associated with long-term extraction of groundwater resources were also found to be less than significant because the riparian groundwater basin refills almost every winter.

Setting the City’ s maximum annual pumping to 1,368 AFY with a maximum diversion rate of up to 2.84 cfs would incrementally reduce groundwater store in the Santa Ynez River underflow in the vicinity of the new wells downstream of Alisal Bridge. This may to require Reclamation to increase water rights releases from Bradbury Dam to provide fish flows consistent with the Cachuma Project 2000 BiOp because the significant City pumping will occur in the dry months; during that time, the 2000 BiOp requires fish flows downstream of Alisal Bridge. Because the City's pumping will dewater the groundwater storage, however, it could require additional releases of water rights water from the Above Narrows Account. These additional flows could have an incremental benefit for the steelhead, other fish species and riparian vegetation.
468
The City, Alisal Ranch and other water rights holders on the Santa Ynez river, and the Cachuma Project Contractors coordinate their water diversions and environmental restoration efforts. All parties recognize that exercising their individual rights without careful coordination would potentially impact water available to each entity, as well as the flows required to support O. mykiss. Therefore, various agreements currently formalize some aspects of coordination to minimize impacts. Without the continued increases in coordination between the Santa Ynez River water right holders, water diversion downstream of the Bradbury Dam could result in significant impacts.

Downstream of the Alisal Bridge, where the City proposes to install new wells under the Revised Project, to divert water within Well Site B, the habitat was not as good as that found upstream of the bridge; however, further degradation of this reach would potentially incrementally reduce connectivity and further reduce habitat quality over time. Therefore, as noted in the Certified FEIR for the Approved Project, it was important that the diversion of Santa Ynez River underflow, at worst, maintains conditions consistent with the current baseline. The proposed extraction of groundwater resources under the Revised Project ( even with the new wells located below the Alisal Bridge flow target area) could require additional releases by the Cachuma Project to support groundwater recharge in the “ Above Narrows” groundwater basin. Those additional flows will provide some mitigation for potential impacts of the City's increased pumping but would be within the requirements of WR 0148-2019133 regarding the operation of Bradbury Dam and Cachuma Reservoir.

Potential impacts to steelhead migration, spawning and rearing during drought periods, and associated with continuing warming trends in Southern California as a consequence of global climate change are also 131 Cachuma Conservation Release Board, Santa Ynez River Water Conservation District, Santa Ynez River Water Conservation District Improvement District No. 1, City of Lompoc, Settlement Agreement Relating to Operation of the Cachuma Project, 2002.
132 National Marine Fisheries Service ( NMFS), Biological Opinion for U.S. Bureau of Reclamation Operation and Maintenance of the Cachuma Project on the Santa Ynez River in Santa Barbara County, California September 11, 2000.
133 State Water Resources Control Board ( SWRCB), Order WR 2019-0148. Order Amending Permits 11308 and 11310 Applications 11331 AND 11332). In the Matter of Permits 11308 and 11310 ( Applications 11331 and 11332) held by the United States Bureau of Reclamation for the Cachuma Project on the Santa Ynez River, September 17, 2019. 469
of concern. The cumulative impact the City’s demands from the Santa Ynez River riparian groundwater basin would be managed as part of water rights releases to the above and below Narrows areas.

The cumulative impact of additional water right extractions would be managed as part of the downstream water rights releases under WR 0148-2019134 by Reclamation. Participants in a regional coordinated water management effort may include Alisal Ranch, ID No. 1, the City, and other water right holders along the Santa Ynez River and in the proximity of the Alisal Bridge, both upstream and downstream.

Impacts associated with the Revised Project and the proposed water right Permit 15878 revisions in associated with other water rights permits and SWRCB orders for water rights holders would be less than significant through the application of the recommended cumulative Certified FEIR Mitigation Measure FIS- 6 and FIS- 7 (Class II).

Cumulative impacts associated with the construction and installation of the new wells and lateral pipelines resulting from the Revised Project would be less than significant ( Class II) as a result of Mitigation Measures FIS-1 to FIS-4, and the continued implementation of the RPM 1 (Terms & Conditions 1[1]) in the 2000 BiOp and the 2019 BiOp to maintain and monitor residual pool depth in Alisal and Refugio reaches during spill years and the first year after spill years, if steelhead are present.

The cumulative impacts associated with ongoing operation and maintenance of the proposed new wells under the Revised Project can be reduced to less than significant by implementing a regional, coordinated water extraction plan that protects the public trust fisheries resources, as identified in Certified FEIR Mitigation Measure FIS- 6 ( Class II). Therefore, with respect to cumulative impacts to fisheries, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.3.5 Revisions to Mitigation Measures
The mitigation measures previously identified in the Certified FEIR would be applied to the Revised Project:

Construction
FIS-1 Prior to initiating construction of wells within the 100-year floodplain of the Santa Ynez River, refugia pools and the wetted width of channels downstream of the Alisal Bridge 134 State Water Resources Control Board ( SWRCB), Order WR 2019-0148. Order Amending Permits 11308 and 11310 Applications 11331 AND 11332). In the Matter of Permits 11308 and 11310 ( Applications 11331 and 11332) held by the United States Bureau of Reclamation for the Cachuma Project on the Santa Ynez River, September 17, 2019. 470
within the proposed Additional Reach of Diversion for water right Permit 15878 (Extended Reach) shall be identified and documented by a qualified biologist.

FIS- 2 No new wells or pipelines shall be constructed within 150 feet of the high water mark of the Santa Ynez River.

FIS-3 A qualified biologist shall be retained during drilling and construction of wells in Well Sites A and B to monitor operations and ensure that construction impacts on fisheries resources are avoided, or minimized, and to conduct daily surveys documenting the condition of refugia pools and the wetted channels mapped as part of Mitigation Measure FIS-1, which may be impacted as a result of construction or well development and testing. Responsibilities of the construction monitor include the following:

Prior to the initiation of construction activities, conduct a meeting with the contractor( s) and other key construction personnel describing the importance of restricting work to designated areas. The construction monitor shall attend preconstruction meetings to ensure that timing or location of construction activities do not conflict with mitigation requirements.

Prior to initiating construction activities, mark or flag any refugia pools and/ or wetted channels within 150 feet of the construction area in the field with the contractor in accordance with the final approved construction plan.

Supervise cordoning of wetted channels and refugia pools that lie within 150 feet of the construction areas (e.g., with temporary fence posts and colored rope).

Conduct a field review of the staking of well sites and pipelines designating the limits of all construction activity.

Conduct daily site visits during construction to coordinate and monitor compliance.

FIS- 4 Construction activities in Well Sites A and B shall be limited to the months of July through November during low flow conditions.

Operational
FIS-5 The Water Division of the Public Works Department of the City of Solvang, in coordination with other agencies involved with the management of the Santa Ynez River, will develop and implement an Operational Pumping Plan, including timing, rates of drawdown from each well, seasonal restrictions, and triggers to ensure that during critical drought periods dewatering associated with groundwater pumping does not adversely impact surface flows within the permitted Expanded Reach of Diversion. 471
Cumulative
FIS-6 The City of Solvang shall continue to coordinate with Alisal Ranch and ID No. 1 on their water demands and diversion of water from the Santa Ynez River. This shall include coordination with the Santa Ynez River Water Conservation District for water rights releases from Lake Cachuma.

FIS- 7 The City shall update the Conservation Element of the City’ s General Plan to include goals and policies that address the City’s contribution to cumulative effects related to extraction of groundwater resources throughout the designated critical habitat reach downstream from the Bradbury Dam and offer to participate in a regionally coordinated water management solution that protects O. mykiss.

3.3.6 Determination of the Potential Significance of Impacts Environmental impacts associated with the Revised Project would be less than significant with mitigation from the Certified FEIR incorporated.

Mitigation measures identified in the Certified FEIR shall be implemented for fisheries ( Mitigation Measures FIS-1 through FIS-7). Implementation of Mitigation Measures would restore habitat functions and values, thereby reducing direct impacts to fisheries habitats and protected and sensitive fish species arising from construction and implementation of the Revised Project to a level of less than significant.

Therefore, with respect to fisheries, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR. 472

3.4 CULTURAL RESOURCES

3.4.1 Summary of Analysis in the Certified FEIR

3.4.1.1 A Substantial Adverse Change in the Significance of Historical Resources
The Certified FEIR identified that development in the region could result in the damage or destruction of known archaeological and historical resources, as well as any existing undiscovered subsurface artifacts.

The vicinity of the City, including areas in the unincorporated Santa Barbara County is known to include both prehistoric and historic cultural resources. Although no evidence of prehistoric resources was discovered during field surveys of the Approved Project area, archaeological sites are located in the vicinity. Historic resources and prehistoric sites could also occur elsewhere in the City and in Santa Ynez Valley. The numerous laws, regulations, and statutes, on both the federal and state levels, which seek to protect cultural resources would apply to development within and outside the City.

Construction Impacts
Master Plan Update
Development under the Approved Project would involve construction activities at locations throughout the City’ s service area during the 20–year project timeline. Since the location of these activities were not yet known at the time of the Certified FEIR, site specific investigations were not performed for the entire Master Plan Update area and field reconnaissance was limited to the areas for Well Sites A and B, and the proposed water treatment facility. The Certified FEIR stated water supply infrastructure may be over 50 years old at the time it is replaced. Therefore, it could meet the general minimum age requirement for listing in the California Register of 50 years or older. However, the aging waterlines, fire hydrants, and valves are common features found in any urban setting and were mostly located in paved and otherwise disturbed areas. The Certified FEIR determined these features were unlikely to meet any of the criteria established by the SOI or for listing in the California Register as they did not have any important historical associations, and were unlikely to have distinctive design characteristics, and they were unlikely to yield information important to history.

However, since historic resources surveys were not completed for the study area, the Certified FEIR stated there is a potential that construction activities could disturb sites in the City that qualify as historic.

Therefore, construction associated with the Master Plan Update implementation would have the potential to damage or change the significance of a historic resource as defined in CEQA Guidelines Section 15064.5. The Certified FEIR concluded the impact to historical resources would be potentially significant. However, with implementation of Certified FEIR Mitigation Measure CUL- 1, impacts from alteration of a historic structure would be reduced to less than significant ( Class II). 473
Changes to Water Right Permit
The revision to the water right Permit 15878 at the time of the Certified FEIR would result in an extension of the Existing Reach of Diversion which would allow construction and operation of water facilities downstream of the existing area of diversion. Historical resources impacts associated with facilities throughout the Master Plan Update Project area, including the Extended Reach of Diversion downstream of Alisal Bridge are discussed above and below.

Proposed Wells and Water Treatment Facilities
Other than the necessary infrastructure improvements, there are no structures in the sites proposed for the wells to be located in Well Sites A and B. The proposed water treatment facility would include a small building to house mechanical equipment. There are no historical buildings or structures that would be modified or removed.

Impacts During Operation
The Certified FEIR stated operation of new facilities under the Approved Project (Master Plan Update and water right Permit 15878 revisions, including the proposed wells and water treatment facility) would not involve any ground disturbing activities that could potentially change the significance of a known historical resource. Therefore, operational of the activities would have no effect on the significance of historical resources. There would be no impact (Class III).
474

3.4.1.2 A Substantial Adverse Change in the Significance of Archaeological Resources
Construction Impacts
Master Plan Update
The Certified FEIR found that construction activities under the Approved Project could result in impacts to previously unidentified archaeological resources due to the potential to encounter archaeological resources throughout the City. Impacts to archaeological resources would be potentially significant.

Changes to Water Right Permits
The proposed revision to water right Permit 15878 would result in an extension of the Existing Reach of Diversion which would allow construction and operation of water facilities downstream of the existing area of diversion. Archaeological resources impacts associated with facilities throughout the Master Plan Update Project area, including the Extended Reach of Diversion downstream of Alisal Bridge, are discussed above and below and in Section 5.4: Cultural Resources of the Certified FEIR.

Proposed Wells and Water Treatment Facilities
One archaeological site, CA-SBA-21641, located adjacent to the water treatment plant site was identified in the records search for the wells and water treatment sites. Based on the information housed at the Central Coast Information Center ( CCIC), this site has not been tested for the existence of a subsurface deposit, precise boundaries, or potential significance. Therefore, to the extent that subsurface deposits may extend into the construction area for the water treatment plant, the ground disturbing activities could uncover subsurface archaeological resources of significance. In addition, while no surface resources were identified at the Wells Sites A and B during the field survey, the potential remains to impact subsurface archaeological resources during ground disturbing activities. The Certified FEIR concluded the impact would be potentially significant. However, with implementation of Certified FEIR Mitigation Measures CUL-2 through CUL-4, impacts would be reduced to less than significant ( Class II).

Impacts During Operation
Operation of facilities to be developed under the Approved Project, including the six proposed new wells and the water treatment plant, would not involve any ground disturbance that could potentially uncover archaeological resources. Therefore, the Certified FEIR determined there would be no impact from operation under the Approved Project, including the operation of the wells to be located in Well Sites A and B, and water treatment plant project. The proposed changes to water right Permit 15878 would not involve any ground disturbance and would not have impacts on archaeological resources. 475

3.4.1.3 Directly or Indirectly Destroy a Unique Paleontological Resource or Geologic Feature
There were no known areas in or around the City that have a significant potential for paleontological resources. 135 In addition, extensive excavation activities for buildings and infrastructure have taken place in the City and no unique paleontological or geologic resources have been encountered. Therefore, the potential to affect a unique paleontological resource or geologic feature would be low. The Certified FEIR concluded the impact would be less than significant ( Class III).

3.4.1.4 Disturb Any Human Remains, Including Those Interred Outside of Formal Cemeteries
Construction Impacts
Master Plan Update
Other than wells to be located in Well Sites A and B, and a proposed water treatment facility site, there were no site-specific studies conducted for proposed facilities included in the Master Plan Update.

Construction activities under the Approved Project could involve ground disturbance that may disturb unrecorded human remains. In the event that unrecorded human remains are encountered during construction, the Certified FEIR determined they could be adversely affected and result in a potentially significant impact. With the implementation of the Certified FEIR Mitigation Measures CUL-4 and CUL-5, impacts would be less than significant ( Class II).

Changes to Water Right Permit
The proposed revision to the water right Permit 15878 would result in an extension of the Existing Reach of Diversion to include areas downstream of Alisal Bridge, which would allow construction and operation of future well facilities in Well Sites A and B. Impacts to unrecorded human remains associated with facilities throughout the Master Plan Update Project area, including the Extended Reach of Diversion, are discussed above and below.

Proposed Wells and Water Treatment Facilities
No recorded historic or Native American cemeteries were identified in the Project area for the proposed wells and water treatment facilities. 136 However, the Certified FEIR noted there is always the potential to encounter unanticipated human remains and such an impact is considered potentially significant. 135 City of Solvang, General Plan, Conservation and Open Space Element, 1988), Page 28. 136 Compass Rose Archaeological, Inc., Phase I Cultural Resources Investigation, City of Solvang Water System Master Plan Update, Santa Barbara County, California ( 2011).
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Impacts During Operation
Operation of facilities to be developed under the Certified FEIR, including the future wells in Well Sites A and B, and a proposed water treatment plant, would not involve any ground disturbance that could potentially uncover human remains. Therefore, there would be no impact.

3.4.1.5 Cumulative Impacts
Evaluation of potential cumulative impacts on cultural resources is limited to the City of Solvang because impacts to cultural resources are confined to specific sites. Both pre-historic and historic resources are expected to be confined to local development patterns, and not found in a broader significance pattern per State CEQA Guidelines and the National Historic Preservation Act).

Development in the region could result in the damage or destruction of known archaeological and historical resources, as well as any existing undiscovered subsurface artifacts. The vicinity of the City, including areas in the unincorporated Santa Barbara County is known to include both prehistoric and historic cultural resources. Although no evidence of prehistoric resources was discovered during field surveys of the Master Plan Update Project area, archaeological sites are located in the vicinity. Historic resources and prehistoric sites could also occur elsewhere in the City and in Santa Ynez Valley. The numerous laws, regulations, and statutes, on both the federal and state levels, which seek to protect cultural resources would apply to development within and outside the City. Implementation of mitigation measures identified above would reduce Approved Project contributions to less than significant levels.

Certified FEIR Mitigation Measures CUL-1, CUL-2, CUL-3, CUL-4 and CUL-5 will reduce the Approved Project’ s contributions to cumulative cultural resources impacts in the City of Solvang and Santa Ynez Valley community by ensuring that appropriate surveys are conducted to identify cultural resources.

Cultural resources discovered within the Master Plan Update Project area will be properly recorded and handled, and known existing resources in the Master Plan Update Project area will be appropriately recorded and preserved. The Approved Project’ s contribution to the cumulative impact would not be considerable ( Class III).

3.4.2 Description of the Changes Resulting from Revised Project The Revised Project would be similar to the Approved Project but would be constructed and operated a reduced capacity. The Revised Project proposes up to two new river wells in Well Site B instead of up to 6 new wells in Well Site A and B under the Approved Project. The Revised Project also proposes diverting 1,368 AFY at a maximum rate of 2.84 cfs, which is reduced from the 1,980 AFY at 5 cfs proposed in the Approved Project. The reach of diversion has been substantially reduced from 19,500 feet in the Certified FEIR Project to a Final Reach of Diversion of 8,060 feet in the Revised Project. Additionally, other 477
components of the Master Plan Update are the same (abandon existing Well 7A located between Alisal Ranch and Santa Ynez River Water Conservation District, ID No. 1 river wells) or no longer under consideration ( the previously planned water treatment plant is no longer proposed in the Revised Project) as analyzed in the Certified FEIR.

3.4.3 Changes in City, State, or Local Plans and Regulations There have been no changes to the city, state, or local plans and regulations to cultural resources for the City of Solvang.

3.4.4 Comparison of the Potential Impacts in the Certified FEIR with the Revised Project
Since the Certified FEIR, Checklist Questions for Cultural Resources have been updated in the CEQA Guidelines Appendix G Checklist. To determine whether the Revised Project would result in new impacts or an increase in the severity of previously identified impacts as analyzed by the Certified FEIR, provided below is an update to the environmental information and analysis of the impacts of the Revised Project using the Cultural Resources Checklist Questions from the current CEQA Guidelines Appendix G Checklist.

A cultural resources technical memorandum, Updated Cultural Resource Inventory for the CEQA Documentation for the City of Solvang’ s Proposed Revisions to the 2011 Water System Master Plan Update Certified FEIR in Solvang, Santa Barbara County, California (“ Cultural Resources Memo”), was prepared by PaleoWest, LLC ( PaleoWest) to update cultural study appended to the Certified FEIR as Appendix 3.4.137 The Cultural Resources Memo included a literature review and records search of the California Historic Resource Information System ( CHRIS) and a review of the Sacred Lands File (SLF) by the Native American Heritage Commission ( NAHC) to determine cultural resources impacts of the Revised Project.

3.4.4.1 Cause a Substantial Adverse Change in the Significance of a Historical Resource pursuant to § 15064. 5?
Construction Impacts
A records search was conducted on March 24, 2021 for the Revised Project which included Well Site A, Well Site B, and the proposed and existing easements for the pipeline as well as a one-mile ( 1 mile) 137 PaleoWest, Updated Cultural Resource Inventory for the CEQA Documentation for the City of Solvang’ s Proposed Revisions to the 2011 Water System Master Plan Update Certified FEIR in Solvang, Santa Barbara County, California ( May 2021; See Appendix D to this Addendum).
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radius. 138 The records search also included a review of the Office of Historic Preservation Archaeological Determination of Eligibility and the Office of Historic Preservation Directory of Historic Properties Data File.

The records search indicated that 71 previous studies have been conducted within one mile of the Project area. Eight of these studies included or intersected the Project area (see Appendix D). Thirty six cultural resources were identified within the records search area, one of which is immediately adjacent to the proposed water main at the intersection of Fjord Drive and Glen Way. The site consists of a sparse scatter of prehistoric flaked and ground stone artifacts in the area. Additionally, a review of historical topographic maps indicates a currently operational gravel pit is located within the parameters of the possible location of Well Site B; the sand and gravel pit was in operation as early as 1942 which means this facility is of historic-age. Similar to the results in the Certified FEIR for Well Sites A and B, there are no historical buildings or structures that would be modified or removed.

The California State Historic Resources Inventory, the National Register of Historic Places, the California State Historical Landmarks, and the California Points of Historical Interest, were also consulted, and no properties were found on any of the listings within or adjacent to the Revised Project area. 139 The Revised Project would install new wells, and would not involve removing any facilities of historical significance as defined in Section 15064.5 of the State CEQA Guidelines. 140 There are no historic structures located within the areas designated for future wells (Wells Sites B) Furthermore, the water treatment facility is no longer proposed and the Revised Project does not propose any new wells in Well Site A. Therefore, the impact to historical resources from the Revised River Wells Project construction in Well Site B would be less than significant. Although the Revised Project would have less effect on a historical resource, the implementation of Mitigation Measures CUL-1 would document that the reduced direct impacts of the Revised Project would be less than significant. Therefore, with respect to historical resources, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.
138 PaleoWest, Updated Cultural Resource Inventory for the CEQA Documentation for the City of Solvang’ s Proposed Revisions to the 2011 Water System Master Plan Update Certified FEIR in Solvang, Santa Barbara County, California ( May 2021; See Appendix D to this Addendum).
139 PaleoWest, Updated Cultural Resource Inventory for the CEQA Documentation for the City of Solvang’ s Proposed Revisions to the 2011 Water System Master Plan Update Certified FEIR in Solvang, Santa Barbara County, California ( May 2021; See Appendix D to this Addendum).
140 CEQA Guidelines, sec. Section 15064. 5.
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Impacts During Operation
Operation of the proposed wells would not involve any ground disturbing activities that could potentially change the significance of a known historical resource. Therefore, operational of the activities would have no effect on the significance of historical resources. There would be no impact. Therefore, with respect to historical resources, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.4.4.2 Cause a Substantial Adverse Change in the Significance of an Archaeological Resource pursuant to § 15064. 5?
Construction Impacts
The Certified FEIR identified potentially significant impacts to the cultural resources and, as such, proposed mitigation measures to reduce these potential impacts to a less than significant level. The Certified FEIR identified potential for the Approved Project to impact archaeological site CA-SBA-21641 located adjacent to the formerly proposed water treatment plant. The City is no longer pursuing the water treatment plant. Therefore, under the Revised Project there will be no impacts to this previously identified archaeological resource. The records search conducted in the Cultural Resources Memo for the Revised Project identified 71 previous studies that have been conducted within one mile of the Project area. Eight 8) of these studies included or intersected the Revised Project area. Thirty- six (36) cultural resources were identified within the records search area, one of which (42-002641/ CA-SBA-2641) is immediately adjacent to the proposed water main at the intersection of Fjord Drive and Glen Way. The site consists of a sparse scatter of prehistoric flaked and ground stone artifacts that measures 260 by 70 meters in area. 141 The site record on file at the CCIC does not indicate any subsurface testing or significance evaluation efforts were conducted at the site. Additionally, a review of historical topographic maps indicates a currently operational gravel pit is located within the parameters of the possible location of Well Site B; the sand and gravel pit was in operation as early as 1942 which means this facility is of historic-age. While no surface resources were identified at the Wells Sites A and B during the records search, the potential remains to impact subsurface archaeological resources during ground disturbing activities in Well Site B.

The Revised Project is also not proposing any new wells in Well Site A, therefore there would be no impact associated with ground disturbance in that area. Further, as identified in the Certified FEIR, there are no known areas in or around the City that have a significant potential for paleontological resources. The Revised Project would be located within the analyzed footprint of the Approved Project. Therefore, the 141 See Appendix D.
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potential to affect unique paleontological or geologic resources have been encountered would be considered low. The impact would be less than significant.

The potentially significant impacts due to ground disturbance in Well Site B are addressed by Certified FEIR Mitigation Measures CUL-2 through CUL-4. With implementation of Certified FEIR Mitigation Measures CUL-2 through CUL-4 impacts to archaeological resources would be less than significant.

Although the Revised Project would have less effect on the significance of an archaeological resource, the implementation of Mitigation Measure CUL-1 would document that the reduced direct impacts of the Revised Project would be less than significant. Therefore, with respect to archaeological and paleontological resources, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

Impacts During Operation
Operation of facilities to be developed under the Revised Project, including the two (2) proposed new wells, would not involve any ground disturbance that could potentially uncover archaeological resources.

Operation of the wells would under the Revised Project would have less than significant impacts on paleontological resources. Therefore, there would be no impact from operation under the Revised Project or operation of the wells to be located in Well Site B. Therefore, with respect to archaeological resources and paleontological resources, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.4.4.3 Disturb Any Human Remains, Including Those Interred Outside of Formal Cemeteries
Construction Impacts
As identified in the Certified FEIR, there were no recorded historic or Native American cemeteries were identified in the Project area for the proposed wells and water treatment facilities. Moreover, the Cultural Resources Memo did not identify the presence of historic or Native American cemeteries. Under the Revised Project is only proposing two wells in Well Site B. No new wells will be installed in Well Site A and the water treatment plant will not be constructed. However, there is still the potential to encounter unanticipated human remains in Well Site B and such an impact is considered potentially significant. This potentially significant impact are addressed by Certified FEIR Mitigation Measures CUL-4 and CUL-5. With implementation of Certified FEIR Mitigation Measures CUL-4 and CUL-5 impacts to potential human remains would be less than significant. Therefore, with respect to human remains, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe 481
significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

Impacts During Operation
The Certified FEIR identified that operation of facilities to be developed within the Project area would not involve any ground disturbance that could potentially uncover human remains. The Revised Project would be located within the analyzed footprint of the Approved Project. Therefore, the Revised Project would not involve ground disturbance that could uncover human remains and there would be no impact.

Therefore, with respect to human remains, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.4.4.5 Cumulative Impacts
Development in the region could result in the damage or destruction of known archaeological and historical resources, as well as any existing undiscovered subsurface artifacts. The vicinity of the City, including areas in the unincorporated Santa Barbara County is known to include both prehistoric and historic cultural resources. Federal, state and local laws that protect cultural resources would apply to any development in the City and outside the City. As identified in records search in the Cultural Resources Memo, archaeological sites are located in the vicinity of Well Site B. Cultural resources discovered within the Revised Project area will be properly recorded and handled, and known existing resources in the Revised Project area will be appropriately recorded and preserved. However, given the presence of archaeological sites, cumulative impacts are considered potentially significant. Similar to the Certified FEIR, Mitigation Measures CUL-1 through CUL-5 would reduce Revised Project contributions to cumulative impacts. The Revised Project’ s contribution to the cumulative impact would not be considerable. Therefore, with respect to cumulative cultural resources impacts, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.4.5 Revisions to Mitigation Measures
The mitigation measures previously identified Certified FEIR, Mitigation Measures CUL-1 through CUL-5 are applicable to the Revised Project. The following Certified FEIR Mitigation Measures will be applied to the Revised Project:
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CUL-1 Before altering or otherwise affecting a building or structure 45 years of age or older, the City shall retain a qualified Architectural Historian to record it on a California Department of Parks and Recreation DPR 523 form or equivalent documentation. Its significance shall be assessed by a qualified Architectural Historian, using the significance criteria set forth using the significance criteria set forth for historic resources under the State CEQA Guidelines Section 15064.5 and shall meet OHP [ Office of Historic Preservation] standards.

CUL- 2 Prior to implementation of any Master Plan Update component that involves ground disturbance in native soils (with the exception of activities at Well Site A, Well Site B and the proposed water treatment plant location previously surveyed), the City of Solvang will arrange for the completion of a Phase I Cultural Resources Assessment by a qualified Cultural Resources Professional. The qualified Cultural Resources Professional shall meet the Secretary of the Interior' s professional qualification standards ( 36 Code of Federal Regulations 61). The Phase I Cultural Resources Assessment for each project under the Master Plan Update may include, but not be limited, to the following tasks, per the recommendations of the Cultural Resources Professional:

An archaeological/ historical/ cultural resources records search shall be conducted at the Central Coastal Information Center (CCIC), located at the University of California, Santa Barbara to identify potential impacts that may be caused by the project.

Consultation shall occur with the Native American Heritage Commission ( NAHC) in Sacramento regarding the possibility of special Native American sites that may be located in the vicinity of any project components shall be conducted. Consultation shall occur with local Native American representatives with knowledge regarding Native American sites in the Project area and shall be contacted in regard to each construction phase if the qualified Cultural Resources Professional determines that there is the potential to impact Native American resources.

A field survey by the appropriate qualified Cultural Resources Professional shall be conducted. A qualified Archaeologist shall be retained to visually examine the ground surface for evidence of prehistoric ( Native American) or historic ( non-Native American) archaeological materials, or other potential historic features ( e.g., structures, bridges, mines, or wells), in areas where ground disturbance is proposed in native soils.

The results of any additional Phase I Cultural Resource Studies shall be documented in a technical report prepared according to Archaeological Resource Management Report (ARMR) guidelines and OHP standards.
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CUL-3 If potential archaeological or paleontological resources are encountered during ground-disturbing activities or construction, work at that location shall be immediately stopped and redirected until a City approved archaeologist and Native American representative are retained by the City to evaluate the significant of the find pursuant to further investigation. If the resources are found to be significant, the applicant shall be subject to further recommendations for mitigation as determined by the archaeologist in consultation with Native Americans and the Planning & Community Development Director.

CUL- 4 Any construction involving ground-disturbing activities shall be monitored by an archaeologist and a local Santa Ynez Chumash tribal monitor. If evidence of the archaeological resource is exposed, the monitors may halt construction for a limited time to propose mitigation in consultation with the Project manager. When earth-disturbing work in the sensitive area is completed, monitoring will no longer be necessary, unless the archaeological resource or other cultural resources are encountered during construction.

CUL-5 In the event of a discovery of human bones, suspected human bones, or a burial, all excavation in the vicinity will halt immediately and the area of the find will be protected until a qualified archaeologist determines whether the bone is human. If the qualified archaeologist determines the bones are human, or if a qualified archaeologist is not present, the City will notify the Santa Barbara County Coroner before additional disturbance occurs. The City will ensure that the remains and vicinity of the find are protected against further disturbance until the Coroner has made a finding with regard to PRC 5097 procedures, in compliance with California Health and Safety Code Section 7050.5(b). If it is determined that the find is of Native American origin, the City will comply with the provisions of PRC Section 5097.98 regarding identification and involvement of the Native American Most Likely Descendant ( MLD).

3.4.6 Determination of the Potential Significance of Impacts Environmental impacts associated with the Revised Project would be less than significant with mitigation, similar to the impacts disclosed in the Certified FEIR.

Implementation of Certified FEIR Mitigation Measure CUL-1 would ensure that any structure of 50 years of age or older are evaluated for their significance as historical resources prior to being replaced. Impacts from alteration of a historic structure would be reduced to less than significant with mitigation. 484
The adopted mitigation measures identified in the Certified FEIR include monitoring by an archaeologist and a local Santa Ynez Chumash tribal monitor of any construction involving ground-disturbing activities.

The Certified FEIR Mitigation Measures CUL-2 and CUL-3 would still apply to the Revised Project. These mitigation measures require supplemental cultural resource studies for areas that may be impacted outside of the previously surveyed areas at Well Site B, as well as a mitigation measure stating that if any archaeological resources are encountered during ground-disturbing activities work will immediately be stopped and redirected until the resources can be further investigated. Another adopted mitigation measure identified in the Certified FEIR includes Mitigation Measure CUL-4 or monitoring by an archaeologist and a local Santa Ynez Chumash tribal monitor of any construction involving grounddisturbing activities. Implementation of Certified FEIR Mitigation Measures CUL-2, CUL-3, and CUL-4 would reduce any potential impacts from the Revised Project (which is limited to installing two new wells in Well Site B and associated infrastructure) to less than significant. Mitigation measures identified in the Certified FEIR shall be implemented for historical and archeological resources ( Mitigation Measures CUL1 through CUL-4; see above). The Cultural Resources Memo did not identify the presence of historic or Native American cemeteries; however, they identified Certified FEIR Mitigation Measure CUL- 5 for the unanticipated discovery of human remains protocols is still applicable for the Revised Project in order to reduce potential impacts to cultural resources to a less significant level. No new mitigation measures are recommended.

Certified FEIR Mitigation Measures CUL- 1, CUL- 2, CUL- 3, CUL- 4 and CUL- 5 will reduce the Revised Project’ s contributions to cumulative cultural resources impacts in the City of Solvang and Santa Ynez Valley community by ensuring that appropriate surveys are conducted to identify cultural resources.

Accordingly, the Revised Project would not result in any new project or cumulative impacts to cultural resources beyond that which was disclosed and mitigated for as part of the Certified FEIR, and such impacts would be reduced to less than significant with the mitigation adopted in the Certified FEIR.

Therefore, implementation of the Revised Project would not result in any new impacts or increase the severity of a previously identified significant impact as analyzed in the Certified FEIR, and no new information of substantial importance has been identified that would require preparation of an EIR. 485

3.5 AIR QUALITY

3.5.1 Summary of Analysis in the Certified FEIR

3.5.1.1 Conflict With or Obstruct Implementation of Applicable Air Quality Plans
Construction Impacts
As a public infrastructure improvement project, the Approved Project would serve existing and future water needs throughout the City. The Certified FEIR stated the Approved Project would adhere to and comply with applicable Santa Barbara County Air Pollution Control District SBCAPCD rules and regulations, including fugitive dust requirements. Therefore, the Certified FEIR concluded the Approved Project was consistent with the Clean Air Plan policies and SBCAPCD rules and regulations. Construction impacts related to conflicts with or obstruction of implementation of applicable air quality plans were determined to be less than significant ( Class III).

Impacts During Operation
Regarding operation, the Certified FEIR stated the Approved Project would have no impact on the land use and population forecasts for the City. Operational emissions, discussed further below, would be below SBCAPCD thresholds of significant. The Approved Project would also adhere to and comply with applicable SBCAPCD rules and regulations, including permitting requirements for emergency generators. As the Approved Project would be consistent with the land use and population forecasts used in the Clean Air Plan and with Clean Air Plan policies and SBCAPCD rules and regulations in place at the time of the Certified FEIR, operational impacts would be less than significant ( Class III).

3.5.1.2 Violate Any Air Quality Standards or Contribute Substantially to an Existing or Projected Air Quality Violation
The Certified FEIR identified that construction and operation of the Approved Project would result in emissions that do not exceed the SBCAPCD thresholds of significance.

Construction Impacts
Proposed Wells
As part of the Approved Project, the City proposed to install new wells in Well Sites A and B downstream of Alisal Bridge along the Santa Ynez River in order to withdraw 1,980 acre-feet per year ( AFY) at a maximum extraction rate of up to 5 cubic feet per second ( cfs) from the river underflow. The Certified FEIR stated previous studies indicated that up to six ( 6) new wells along the Santa Ynez River would be required to meet the forecast demand. Construction of the wells will require access by construction 486
equipment, trucks, and a drilling rig. Individual wells will be installed within these areas, which will also be used for the drilling rig, stockpiling, and other equipment parking. The Certified FEIR stated it may also be necessary for construction trucks to temporarily park along the existing dirt roads at each well site.

Water Treatment Plant
At the time of the Certified FEIR, the City determined that the most cost effective and reliable treatment technology is a conventional surface water treatment plant. The treatment plant would not normally be occupied, but would be visited a few hours each day by City operations personnel. Construction of the treatment plant would occur in the following phases:

1. Grading and construction of foundation and retaining wall, if necessary, on the east side of the building site;

2. Building construction;

3. Utility connections, including electricity, cable, sewer, and the water line from the proposed future wells downstream of Alisal Bridge; and

4. Installation of the treatment modules.

Construction activities were expected to be completed in a nine month period. The initial grading would involve the use of a loader and backhoe for several days, followed by concrete trucks. Building construction and system installation will involve various work trucks and construction worker vehicles.

As shown in Table 3.5-1: Estimated Construction Emissions of the Approved Project, construction emissions for the Approved Project would not exceed 25 tons in a 12-month period for any assessed pollutant. Thus, construction emissions would be less than significant. However, even if construction emissions would be less than the 25-ton threshold, the SBCAPCD requires that projects implement construction mitigation measures. Therefore, the Certified FEIR stated the Approved Project would comply with SBCAPCD required construction mitigation measures. These mitigation measures are reflected in Mitigation Measure AIR-1, shown below. Impacts related to air quality standards for construction- related activities would be less than significant with imposition of Mitigation Measure AIR1 (Class II). 487
Table 3.5-1
Estimated Construction Emissions of the Approved Project Source
VOC NOx CO SOx PM10 PM2.5
tons/ year
Infrastructure 1.11 7.26 4.67 0.01 7.42 0.59
Well Drilling, Installation, and Testing 0.06 0.42 0.30 0.00 0.06 0.00 Water Treatment Plant 0.38 2.72 1.67 0.00 0.17 0.14
Maximum Annual Emissions 1.55 10.40 6.64 0.01 7.65 0.73 SBCAPCD Threshold 25 25 — 25 25 25
Threshold exceeded? No No — No No No
Source: See Certified FEIR Section 5.5: Air Quality, Table 5.5-5: Estimated Construction Emissions.

Impacts During Operation
The Approved Project recommended the City implement an annual waterline, fire hydrant, and valve replacement program, and provide additional water storage capacity. This program would result in up to 12 additional vehicle trips per day ( up to four trips each for waterline, fire hydrant/ valve, and the additional water storage inspection/ maintenance), which would generate air pollutant emissions. The proposed future wells would also generate up to 24 additional vehicle trips per day (four trips for each well) for maintenance purposes. The proposed water treatment plant would not normally be occupied, but would be visited a few hours each day by City operations personnel (two crews each making four trips per day), which would also generate 8 additional vehicle trips per day and emissions. Stationary source emissions would be generated from two emergency generators that would be used to improve water supply reliability during power outages; one at the existing State Water Project ( SWP) Pumping Station and one at the proposed site for the water treatment plant. Emergency generators may be subject to SBCAPCD air quality permitting requirements and would be scheduled to operate during standard testing and maintenance activities, which is anticipated to be about 1 hour per week and 50 hours per year. As shown in Table 3.5-2: Estimated Operational Emissions of the Approved Project, operational emissions would not exceed the thresholds for mobile source emissions or the thresholds for emissions from all sources. Operational emissions would be less than significant ( Class II). 488
Table 3.5-2
Estimated Operational Emissions of the Approved Project Source
VOC NOx CO SOx PM10 PM2.5
pounds/ day
Summertime Emissions
Mobile 0.32 0.55 2.94 0.00 0.36 0.00
Area 0.03 0.00 0.00 0.00 0.00 0.00
Emergency Generators 1.89 26.61 14.75 0.03 1.88 1.88
Total Emissions 2.24 27.16 17.69 0.03 2.24 1.88
Wintertime Emissions
Mobile 0.34 0.57 3.14 0.00 0.36 0.00
Area 0.03 0.00 0.00 0.00 0.00 0.00
Emergency Generators 1.89 26.61 14.75 0.03 1.88 1.88
Total Emissions 2.26 27.18 17.69 0.03 2.24 1.88
SBCAPCD Threshold 240 240 — — 80 —
Threshold exceeded? No No — — No —
Source: See Certified FEIR Section 5.5: Air Quality, Table 5.5-6: Estimated Operational Emissions.

3.5.1.3 Cause Cumulatively Considerable Net Increases of Any Criteria Pollutant
Construction Impacts
As indicated in Table 3.5-1, the construction emissions that would be generated from construction activities under the Approved Project would not exceed the SBCAPCD threshold of 25 tons in a 12-month period for any assessed pollutant. Projects that do not exceed the project-level threshold would not contribute to cumulatively significant air quality impacts. However, even if construction emissions would be less than the 25-ton threshold, the SBCAPCD requires that projects implement construction mitigation measures. Therefore, the Certified FEIR determined the Approved Project will be required to comply with SBCAPCD required construction mitigation measures, which are reflected in Mitigation Measure AIR-1.

Impacts for construction- related activities would be less than significant with implementation of Mitigation Measure AIR-1 (Class II).

Impacts During Operation
The Master Plan Update evaluated in the Certified FEIR would have no impact on the land use and population forecasts for the City. Furthermore, the Approved Project’ s operational emissions, as shown in Table 3.5-2, would be below the SBCAPCD thresholds of significance. The Approved Project would 489
adhere to and comply with applicable SBCAPCD rules and regulations, including permitting requirements for emergency generators. Therefore, the Approved Project would be consistent with the land use and population forecasts used in the most recent Clean Air Plan, and would be consistent with Clean Air Plan policies and SBCAPCD rules and regulations. The Certified FEIR concluded operation of the Approved Project would result in a less than significant impact with respect to air quality (Class III).

3.5.1.4 Expose Sensitive Receptors to Substantial Pollutant Concentrations Construction Impacts
The Certified FEIR determined construction activities would likely be sporadic and would not be concentrated at a single location, but would occur at many locations throughout the City. As shown in Table 3.5-1, construction emissions from the Approved Project would be well below the SBCAPCD thresholds of significance, particularly for PM2.5, which is closely associated with diesel particulate matter, a known carcinogen. Construction activities at any one location would be short-term lasting up to five ( 5) days for each well construction and nine months for the water treatment plant construction.

Infrastructure improvements and replacements could last several years; however, each individual improvement or replacement would involve construction activity over a much shorter timeframe and would result in localized emissions less than the values shown in Table 3.5-1, which are already well below the SBCAPCD thresholds of significance. However, even if construction emissions would be less than the 25-ton threshold, the SBCAPCD requires that projects implement construction mitigation measures, which are reflected in Mitigation Measure AIR-1. Therefore, the Certified FEIR concluded the Approved Project will be required to comply with SBCAPCD required construction mitigation measures, Mitigation Measure AIR-1. Impacts for construction- related activities with respect to sensitive receptors would be less than significant with mitigation ( Class II).

Impacts During Operation
Operation of the Approved Project components under full buildout of the Master Plan Update would not result in substantial pollutant concentrations that would affect sensitive receptors. Operational emissions would be generated from vehicle trips associated with standard operation and maintenance activities. As previously discussed, emissions from these sources would be substantially below the SBCAPCD thresholds of significance. Maintenance trucks may be diesel powered, which would result in small amounts of diesel particulate matter. However, these emissions would be negligible, as shown in Table 3.5-2. In addition, ambient CO concentrations in the County are well below the ambient air quality standards and the additional vehicle trips associated with standard operation and maintenance activities would not cause or contribute to the formation of CO hotspots that would exceed the standards. As a result, the Certified 490
FEIR determined impacts from Project operational emissions to sensitive receptors would be less than significant ( Class III).

3.5.1.5 Cumulative Impacts
As indicated in Table 3.5-1 and Table 3.5-2 construction and operation of the Approved Project would result in emissions that do not exceed the SBCAPCD thresholds of significance. Projects that do not exceed the project-level threshold would not contribute to cumulatively significant air quality impacts. However, even if construction emissions would be less than the 25-ton threshold, the SBCAPCD requires that projects implement construction mitigation measures. Therefore, the Certified FEIR stated the Approved Project will comply with SBCAPCD required construction mitigation measures. The Approved Project would adhere to and comply with applicable SBCAPCD rules and regulations, including permitting requirements for emergency generators. Therefore, the Approved Project would be consistent with the land use and population forecasts used in the Clean Air Plan, and would be consistent with Clean Air Plan policies and SBCAPCD rules and regulations in place at the time the Approved Project was analyzed in the Certified FEIR. The Certified FEIR stated construction of the Approved Project would be potentially significant and require implementation of SBCAPCD recommended mitigation measures, reflected in Mitigation Measure AIR-1. Cumulative impacts for construction- related activities would be less than significant with implementation of Mitigation Measure AIR-1 (Class II). Operation of the Approved Project would result in a less than significant cumulative impact with respect to air quality (Class III).

3.5.2 Description of the Changes Resulting from Revised Project The Revised Project would be similar to the river wells component of the Approved Project but it would be constructed and operated a reduced capacity. The Revised Project proposes up to two new river wells in Well Site B instead of up to 6 new wells in Well Site A and B under the Approved Project. The Revised Project also proposes diverting 1,368 AFY at a maximum rate of 2.84 cfs, which is reduced from the 1,980 AFY at 5 cfs proposed in the Approved Project. The reach of diversion has been substantially reduced and shifted downstream from 19,500 feet in the Approved Project to a Final Reach of Diversion of 8,060 feet in the Revised Project. Additionally, other components of the Master Plan Update are the same (abandon existing Well 7A located between Alisal Ranch and Santa Ynez River Water Conservation District, ID No. 1 river wells) or no longer under consideration ( the previously planned water treatment plant is no longer proposed in the Revised Project) as analyzed in the Certified FEIR. 491

3.5.3 Changes in City, State, or Local Plans and Regulations The SBCAPCD updated its environmental review guideline in 2015. The SBCAPCD significance criteria 142 identifies that a proposed project will not have a significant air quality effect on the environment, if operation of the Project will:
emit (from all project sources, mobile and stationary) less than the daily trigger for offsets set in the SBCAPCD New Source Review Rule for any pollutant and
emit less than 25 pounds per day of oxides of nitrogen (NOx) or reactive organic compounds ( ROC) from motor vehicle trips only; and
not cause or contribute to a violation of any California or National Ambient Air Quality Standard except ozone); and
not exceed the SBCAPCD health risk public notification thresholds adopted by the SBCAPCD Board; and
be consistent with the adopted federal and state Air Quality Plans.

The SBCAPCD adopted the 2013 Clean Air Plan in March 2015,143 which is an update to the previous 2010 Clean Air Plan that was discussed in the Certified FEIR. The 2013 Clean Air Plan (Plan) is the sixth triennial update to the initial State Clean Air Plan adopted by the Santa Barbara County Air Pollution Control District Board of Directors in 1991. In this Plan, the proposed stationary source control measures from the 2010 Clean Air Plan have been carried over that are pending rule adoption except for two which have been reclassified as “ further study” measures. 144 However, the primary focus of the 2013 Clean Air Plan is on marine shipping emissions. The California Clean Air Act requires that progress be reported in meeting state mandates and revise our 1991 Air Quality Attainment Plan to reflect changing conditions on a triennial basis in the Clean Air Plan. There are two major items required in the 2013 Clean Air Plan Sections 40924 and 40925 of the California Health and Safety Code): a triennial progress report and a triennial plan revision. The triennial progress report must assess the overall effectiveness of an air quality program and the extent of air quality improvement resulting from the 2013 Clean Air Plan. The triennial plan revision must also incorporate new data or projections into the 2013 Clean Air Plan. The 2013 Clean Air Plan satisfies all state triennial planning requirements. 145 142 Santa Barbara County. Air Pollution Control District ( SBCAPCD). Environmental Review Guidelines. https:// www.ourair.org/ wp-content/ uploads/ APCDCEQAGuidelinesApr2015. pdf. Accessed October 2021. 143 Santa Barbara County. Air Pollution Control District ( SBCAPCD). Clean Air Plan. https:// www.ourair.org/ wpcontent/ uploads/ 2015-03bd-2013cap-att4.pdf. Accessed December 2021. 144 Santa Barbara County. Air Pollution Control District ( SBCAPCD). Clean Air Plan. https:// www.ourair.org/ wpcontent/ uploads/ 2015-03bd-2013cap-att4.pdf. Accessed December 2021. 145 Santa Barbara County. Air Pollution Control District ( SBCAPCD). Clean Air Plan. https:// www.ourair. org/ wpcontent/ uploads/ 2015-03bd-2013cap- att4.pdf. Accessed December 2021. 492

3.5.4 Comparison of the Potential Impacts in the Certified FEIR with the Revised Project
Since the Certified FEIR, Checklist Questions for Air Quality have been updated in the CEQA Guidelines Appendix G Checklist. To determine whether the Revised Project would result in new impacts or an increase in the severity of previously identified impacts as analyzed by the Certified FEIR, provided below is an update to the environmental information and analysis of the impacts of the Revised Project using the Air Quality Checklist Questions from the current CEQA Guidelines Appendix G Checklist.

Additionally, the Certified FEIR Initial Study (see Appendix 1.0 of the Certified FEIR) did not carry forward Air Quality question related to creation of objectionable odors affecting a substantial number of people to the Certified FEIR for analysis. Because the footprint of the Revised Project is less than that of the Approved Project and within the original footprint analyzed under the Certified FEIR, this Addendum also screens out this current CEQA Appendix G Checklist question from analysis of the Revised Project.

3.5.4.1 Conflict With or Obstruct Implementation of the Applicable Air Quality Plan
Construction Impacts
The Revised Project is a public infrastructure improvement project that would serve existing and future water needs throughout the City. Commercial and industrial projects are considered to be consistent with the Clean Air Plan if they are consistent with the SBCAPCD rules and regulations. As shown in Table 3.5-3:

Estimated Construction Emissions of the Revised Project and discussed later in this section, the Revised Project construction emissions would not exceed SBCAPCD thresholds, similar to the Approved Project.

Table 3.5-3 also compares the construction emissions of the Revised Project and the Approved Project.

As shown, the Revised Project would result in lower emissions compared to the Approved Project.

Moreover, the Revised Project would be constructed and operated at a much smaller capacity in comparison to the river wells component of the Approved Project analyzed in the Certified FEIR.

Construction of the Revised Project would adhere to and comply with applicable SBCAPCD rules and regulations, including fugitive dust requirements. Therefore, the Revised Project would be consistent with the Clean Air Plan policies and SBCAPCD rules and regulations. Construction impacts related to air quality would be less than significant. Therefore, with respect to air quality, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.
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Impacts During Operation
As discussed above, the Certified FEIR stated that it would have no impact on the land use and population forecasts for the City. Therefore, since the Revised Project would be similar to the river wells component of the Approved Project but constructed and operated at a reduced capacity, it would still have no impact on land use and population forecasts for the City. Operational emissions, discussed further below, would be below SBCAPCD thresholds of significance. The Revised Project would also adhere to and comply with applicable SBCAPCD rules and regulations, including permitting requirements for emergency generators.

As the Revised Project would remain consistent with the land use and population forecasts used in the most recent Clean Air Plan and with Clean Air Plan policies and SBCAPCD rules and regulations, operational impacts with respect to air quality would be less than significant. Therefore, with respect to air quality, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

3.5.4.2 Cause Cumulatively Considerable Net Increases of Any Criteria Pollutant
Construction Impacts
As shown in Table 3.5-3, the Revised Project would result in lower construction emissions compared to the Approved Project and remain below the SBCAPCD threshold of 25 tons in a 12-month period for any assessed pollutant. Moreover, construction emissions would not exceed the SBCAPCD Thresholds updated in the 2015 environmental review guidelines. 146 Construction of the Revised Project would not violate any air quality standards or contribute substantially to an existing or projected air quality.

Construction impacts with respect to air quality would remain less than significant. Projects that do not exceed the project-level threshold would not contribute to cumulatively significant air quality impacts.

However, SBCAPCD still requires project implementation of construction mitigation measures; therefore, the Revised Project will be required to comply with SBCAPCD required construction mitigation measures, which are reflected in Mitigation Measure AIR-1. With implementation of Mitigation Measure AIR-1, construction impacts would not cause cumulatively considerable new increases of any criteria pollutant.

Construction impacts with respect to air quality would remain less than significant with the imposition of Mitigation Measure AIR-1. Therefore, with respect to air quality, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, 146 Santa Barbara County. Air Pollution Control District ( APCD). https:// www.ourair. org/ greenhouse- gases- and-ceqa/.

Accessed October 2021.
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and no new information of substantial importance has been identified that would require preparation of an EIR.

Table 3.5-3
Estimated Construction Emissions of the Revised Project Maximum Annual Emissions
VOC NOx CO SOx PM10 PM2.5
tons/ year
Approved Project 1.55 10.40 6.64 0.01 7.65 0.73
Revised Project 0.21 1.81 1.84 < 0.01 0.10 0.07
SBCAPCD Threshold 25 25 — 25 25 25
Threshold exceeded? No No — No No No
Approved Project Emissions
Exceeded? No No — No No No
Refer to Appendix E, Section 2.1 for maximum annual construction emissions.

Impacts During Operation
As shown in Table 3.5-4: Estimated Operational Emissions of the Revised Project, the Revised Project would result in lower operational emissions compared to the Certified FEIR. Moreover, operational emissions would not exceed the SBCAPCD Thresholds updated in the 2015 environmental review guidelines. 147 As mentioned, the Revised Project would have no impact on the land use and population forecasts for the City. Therefore, the Revised Project would be consistent with the land use and population forecasts used in the most recent Clean Air Plan

3.5.4.3 Expose Sensitive Receptors to Substantial Pollutant Concentrations Construction Impacts
Construction activities would likely be sporadic and would not be concentrated at a single location, but would occur at many locations throughout the City. As shown in Table 3.5-3, construction emissions would be well below the SBCAPCD thresholds of significance and the emissions of the Approved Project articulated in the Certified FEIR, particularly for PM2.5, which is closely associated with diesel particulate matter, a known carcinogen. Construction activities would be short-term and temporary in nature. As mentioned, the Proposed Project would include a total of two (2) new wells limited to Well Site B. Revised Project would be constructed over a shorter timeframe and would result in localized emissions less than the values shown in Table 3.5-1 compared to the Approved Project, which are already well below the 147 Santa Barbara County. Air Pollution Control District (APCD). https:// www.ourair.org/ greenhouse- gases- and-ceqa/. Accessed October 2021.
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SBCAPCD thresholds of significance. However, even if construction emissions would be less than the 25- ton threshold, the SBCAPCD requires that projects implement construction mitigation measures.

Therefore, the Revised Project will be required to comply with SBCAPCD required construction mitigation measures, which are reflected in Mitigation Measure AIR-1. With implementation of Mitigation Measure AIR-1, impacts from the Revised Project with respect to exposure of sensitive receptors would be less than significant. Therefore, with respect to exposure of sensitive receptors, the changes reflected in the Revised Project and current circumstances do not result in new or substantially more severe significant impacts, and no new information of substantial importance has been identified that would require preparation of an EIR.

Solvang City CouncilJanuary 10, 2022

Solvang City Council
January 10, 2022