Santa Barbara Audubon is encouraging the City of Goleta to take a deeper look at the proposed development called the Village at Lake Los Carneros. The Environmental Impact Report (EIR) could use improvement regarding transportation, water and energy efficiency, mitigating creek impacts during development as well as selecting native plants to support local birds as part of their landscaping.
The Santa Barbara Audubon Society sent this letter in addition to speaking publicly at the November 17th hearing.
Download the original letter or read it below.
December 1, 2005
City of Goleta
Attention: Alan Hanson, Senior Planner
130 Cremona Drive, Suite B
Goleta, CA 93117
RE: Scoping EIR Village @ Los Carneros
Dear Mr. Hanson:
Santa Barbara Audubon has as part of its mission the protection and restoration of native habitats within its chapter boundaries, which includes the City of Goleta. We had a representative at the Scoping hearing for the Environmental Impact Report (EIR) on the proposed Village @ Los Carneros. These written comments expand on the verbal testimony given at that hearing on November 17, 2005.
I have also reviewed the Wetland Delineation submitted to the Goleta Planning Department by the applicant, which includes suggested mitigations for the impacts of the project. The impacts to natural resources are primarily related to the proposed new bridge over Tecolotito Creek.
Mitigation of Creek Impacts. The temporary impacts of bridge construction can feasibly be mitigated with invasive weed removal and planting of riparian and freshwater wetland plant species in the creek invert, on the banks, and the top-of-bank area within the bridge construction impact area. This should be evaluated in the EIR.
The permanent impacts–displacement of native vegetation from the bridge and shading by the bridge needs to be mitigated, and the adequacy of the mitigation should be evaluated in the EIR. The applicant proposes 3:1 mitigation planting for permanent loss of wetland habitat, “within the 2-acre park in the east of Lot 7.” According to the applicant’s representative at the scoping hearing, the site has not been selected. The optimal site may the drainage swale noted on the maps in the northern part of Lot 7. Site drainage could be directed to this area via a bioswale to cleanse the water before it reaches the creek; the natural swale is close to the creek and would feasibly mitigate for lost habitat value of the creek invert. A site which is not contiguous with the creek and which requires artificial hydration would unlikely be able to provide long-term replacement of lost resources. This needs to be evaluated in the EIR.
The removal of riparian trees anticipated for construction of the new bridge and roadway access to the project site is 13 trees: 9 Arroyo willow, 2 Western sycamore and 2 Coast live oak. An additional 11 trees (6 Arroyo willow and 5 Sycamore) may be impacted by construction, according to the Wetland Delineation Report. The applicant proposed 3:1 replacement of the Arroyo willow and 1:1 replacement of the smaller, recently planted trees. These are probably a Flood Control mitigation project. I recommend that these be replanted on a 3:1 basis for all, and be planted on the eastern side of Tecolotito Creek within the 50 foot buffer of the creek. This should be evaluated in the EIR.
Model Project. Kristen Amyx, of the Goleta Valley Chamber of Commerce, gave testimony at the scoping hearing in support of the plan and describing it as a model project. Especially from a transportation perspective with walking and biking distance for residents close to jobs in Goleta. Bus access should also be evaluated for minimizing traffic impacts.
Energy use is another perspective that should be evaluated. The 265 units are proposed in nine buildings, which generally is an energy efficient design. Green building techniques especially energy efficiency and solar water heating and or solar electric should be evaluated for reduced impacts of the project. See the attached articles from the Christian Science Monitor and Santa Barbara News-Press.
Water efficiency is another facet of “green building”, which can be incorporated in the project. The multi-family structures can improve water efficiency, especially in landscaping. The toilets, showers and appliances can be water efficient beyond code requirements. Landscaping should minimize lawn, and use low-water requirement plant species except in bioswale and creek native plantings. Evaluation of the project in this regard should be part of the EIR.
Landscape Plant List. The applicants planning consultant, Ms. Laurel Perez was able to provide me with the Preliminary Plant List that was posted on the plans on display at the scoping hearing. I wish to make some general comments and some specific comments regarding the plant palette. The plant list could include more local native plant species, which are adapted to the climate and in general will require less irrigation after establishment. This information should be evaluated in the EIR for positive impact, and reduced impact from invasive ornamental species.
Additional local native species that can appropriately be part of a landscape plan include: Coffeeberry, Holly-leaf cherry, Lemonadeberry, Redberry, Santa Barbara honeysuckle. The first three are good along with Toyon as screen shrubs. The last two are low shrubs. All native species should be from local genetic stock. The Santa Barbara honeysuckle might substitute for the Japanese honeysuckle.
Several species that can be invasive in our area are included and should be evaluated for exclusion not only for this project but for all Goleta projects. The California Invasive Plant Council is revising its list of California invasive plants, which can be found on the website cal-ipc.org. The Channel Islands chapter of the California Native Plant Society has a list of local invasive plants; this is under revision and will soon be available on their website at cnpsci.org; I’ve included the current list from 1995. Plant species of invasive concern on the Preliminary Plant List are: English Ivy, Cotoneaster, some species of Eucalyptus (“Eucalyptus sp.”), some species of Pittosporum–not sure of the ones listed, Chinese pistache in some situations. Oleo europa is invasive, although the “Fruitless olive” may not be. In the Goleta area, we found Holly oak to be invasive–on More Mesa, where saplings are establishing from mature trees planted in urban landscaping across Atascadero Creek. County Parks has removed dozens of seedlings and saplings, and many more remain.
Two listed species are problematic because they hybridize with related native species: the London plane tree hybridizes with the California sycamore. The Catalina Cherry, Prunus lyoni, is native to the Channel Islands, and hybridizes with the mainland Hollyleaf cherry, P. ilicifolia. The mainland species should be substituted.
Some of the listed species are high water use plants and may therefore be inappropriate: Camellia, Fuchsia and Giant Chain Fern. The latter is a native in our creeks and might be used in the creek restoration plant list.
Stormwater Management. The vacant parcels will have significant impervious surfaces with the dense development proposed. The EIR should evaluate ways to reduce the impervious surface ratio with pervious surfaces such as pervious concrete, pavers, planted open cell pavers, and/or decomposed granite for walkways and parking surfaces. Above ground bioswales can direct stormwater and encourage infiltration and allow for bio-filtration. Parking areas can direct run-off to planters rather than piping drainage to the creek. “The project plans include bioswales, permeable paving, some permeable sidewalks and catch basins with fossil-fuel filtration.” The EIR can evaluate the effectiveness of these measures as described in the Preliminary Drainage Report.
Summary. The impacts of the project need to be evaluated and the project modified if feasible to avoid or minimize negative impacts, and then mitigations proposed for any significant impacts. The significant biological resources are likely associated with Tecolotito Creek, which need to be evaluated in the EIR. Santa Barbara Audubon thanks you for the opportunity to comment on the scope of the EIR.
Sincerely,
Darlene Chirman, President
Santa Barbara Audubon Society
