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Alignment B is Not Viable


We have been saying all along that Alignment B is not viable. Our attorneys have submitted a 16 page legal comment letter to challenge the County’s deficient and inaccurate environmental review document (MND) containing numerous errors, omissions, & obfuscations…etc…

Or, as we call it…an Unmitigated Disaster! Literally, omitting “special status” oak trees in their Alignment A that by County ordinance require…you guessed it…MITIGATION!

CAMP Legal Counsel – “Since the full complement of oaks trees subject to removal were not identified or addressed in the MND, the MND fails as an informational document. Moreover, the MND fails to provide mitigation measures for the oak trees that would be removed under Alignment A. For these reasons alone the MND should be rejected.”

“Any decision by the Board of Supervisors to approve the proposed Project as currently formulated will result in multiple violations of the California Environmental Quality Act. First, the Initial Study/Mitigated Negative Declaration (“MND”) prepared for the proposed Project contains numerous inaccuracies and fails as informational document. Second, Alignment B is not viable since it cannot be constructed in a manner consistent with the Conservation Easement in the Modoc Preserve that the Land Trust for Santa Barbara County currently holds. Third, Alignment A, as currently designed, is not tenable for multiple reasons, not the least of which being that it would destroy 29 majestic Canary Island Palm Trees and a number of native Oak trees not included in the MND’s tree survey.”

“the MND’s cumulative impact analysis is inadequate as a matter of law.”

Now, the Land Trust for Santa Barbara County (LTSB) and La Cumbre Mutual Water Company (LCMWC) have also both written legal responses to the County’s revised MND stating that it is “inaccurate and incomplete”.

LTSB – “the Land Trust cannot agree with Alignment B as described in the MND.”

LCMWC – “the MND fails to consider important Project components in its environmental
analysis…accordingly, the MND and the environmental analysis contained in the MND is incomplete.”

So, now the decision makers, and the public, really are being forced to come to grips with the fact that the removal of 48 trees, including 29 iconic and historic Canary Island date palms, in the County’s Alignment A, is not tenable

In fact, Gregg Hart told a CAMP member that not one of the CI date palms would be touched…”political suicide“…please write to Mr. Hart and remind him of this fact! Especially, since his opponent in the 37th Assembly District race, Mike Stoker, supports a recommendation to not destroy these iconic heritage palm trees.

Gregg Hart 2nd District Supervisor


CAMP points out in this latest blog post that extending the Obern Trail by 3/4 mile…the Greenbelt Alignment…running the MUP outside the tree line using existing asphalt infrastructure, will solve the problem…

Simply put, it is a 3/4 mile long extension of the Obern Trail.
The 4.5 mile Class I Obern Trail MUP (Multi-use Path) doesn’t also have adjacent Class II bike lanes for it’s 4.5 mile length. The County’s tree count and survey is inaccurate as there are native oak trees omitted (Oaktober Surprise) in the County’s revised MND Alignment A tables and maps, that the Board of Supervisors will be voting on Nov. 1. which renders the revised MND a failure as an informational document.

The main objective of this proposed  3/4 mile long Modoc Road Class I MUP, is to “bridge the gap” between the new 2.6 mile Class I MUP from Hendry’s Beach to Modoc Road…with the 4.5 mile Obern Trail Class I MUP to Goleta Beach…and, it can be done without cutting down a single tree…it’s the most cost effective and reasonable thing to do…

Clerk for SB County Board of Supervisors

Das Williams 1st District Supervisor

Joan Hartmann 3rd District Supervisor

Bob Nelson 4th District Supervisor

Steve Lavagnino

2nd District Candidate Laura Capps (Unopposed) 

The legal research work and letter that our attorneys have written outlining the discrepancies and deficiencies that we found in the revised MND…required a significant amount of billable hours that we are paying for…if you would like to help us offset these legal bills to protect the Modoc Road trees…


We are very grateful to you all…this thing is winnable…and, we couldn’t do this without you…thanks again so much!

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