Notes on Environmental Impact Analysis

Conejo Creek Specific Plan – 4.0 Aesthetics

On page 4.1-1 and 4.1-2 it states:
“Views of and Through the Plan Area. Views of the Plan Area are available along U.S.101 looking south, Pleasant Valley Road looking east, Lewis Road looking east, and from Ridgeview Street looking north and west. The most prominent public views of the site are those from motorists traveling northbound on U.S. 101 down the Conejo Grade, as the highway is above the grade of the site. Prominent views of the Plan Area also exist along the adjacent roadways of U.S. 101 Southbound and Pleasant Valley Road.”

On Page 4.1-9 it states:
“U.S. 101. Views of the Plan Area from U.S. 101 are readily available to both northbound and southbound travelers. Northbound and southbound travelers have views of agricultural uses in the foreground and middleground, and the Santa Monica foothills in the background. Northbound travelers approach the Plan Area from a bird’s eye view as they descend the Conejo Grade. Views from the top of the Conejo Grade consist not only of agricultural fields in the Plan Area, but of the surrounding urban setting as well. The expansive agricultural fields of the project area from U.S. 101 northbound are the prominent feature of motorists’ initial view of the valley and the City of Camarillo from this direction. Figure 4.1-3 provides a comparison of the existing view from Conejo Grade with a photosimulation of the same view with full buildout of the Plan Area. Figure 4.1-4 provides a before and after view of the Plan Area for southbound travelers. Development of the Plan Area would significantly alter foreground and middleground views for travelers in either direction along the U.S. 101.”

However, this picture is taken 1/2 way down the Conejo Grade.  You can see  Camarillo Springs directly to the left, which is nearly to the bottom of the Conejo Grade. This picture was not taken at the top of the Conejo Grade as referenced in the “Views of the Plan Area from the 101″ paragraph above which states: “The expansive agricultural fields of the project area from U.S. 101 northbound are the prominent feature of motorists’ initial view of the valley and the City of Camarillo from this direction. ”

The Final EIR should have a picture illustration of this “initial view” of the valley and the City of Camarillo when seen from the crest of the Conejo Grade, not 1/2 way down and lower in elevation.

This “view to the sea” the entire Western Ventura County knows and loves is at the very crest of the Conejo Grade…not 1/2 way down.

Conejo Creek Specific Plan EIR – Section 4.2 AGRICULTURAL RESOURCES

On page 4.2.1 it states:

“Table 4.2-1 shows the 2009 and 2010 values of major crop groupings in Ventura County. Gross revenue sales of agricultural products in the County increased from approximately $1.62 billion in 2009 to $1.85 billion in 2010.” 

This is a nearly $200,000 million increase in gross revenue sales in one year.

It goes on to say:

“Mild summer and winter temperatures, low occurrence of frost, and Mediterranean climate characterize agricultural lands near the coast. These climatic conditions in association with high quality soils and relatively flat aspect, such as those in the Project Area, combine to create some of the highest and most productive agricultural land in the nation. Farmland with these characteristics represents a limited and diminishing resource both county and statewide.”

As indicated in Table 4.2-2:

“the County of Ventura has experienced a two percent decrease (2,468 acres) of important farmland from the period of 2006 to 2008. The primary causes of irrigated farmland loss is conversion to urban lands or farmlands being taken out of production for uses such as low density housing, animal training, or cultivation of non-irrigated grain crops.”

However, the Draft EIR Comment Letter sent from the Department of Conservation’s Division of Land Resource Protection and the California Department of Food and Agriculture states the farmland statistics from 1984 – 2008,  which offers a longer perspective than the 2006 – 2008 stats noted in the EIR:

The CDFA letter states:

“Land use conversion statistics from the Important Farmland Data Availability webpage1 documents a net loss of more than 13,348 acres of Prime Farmland in Ventura County from 1984 to 2008, with an annual average loss of more than 550 acres per year.”

It goes on to note:

This cumulative loss represents a permanent impact to the agricultural resources of the County and the State, and shows why the remaining prime agricultural resources should be protected whenever feasible.”

This average loss of 550 acres per year adds up!  The Conejo Creek properties project would be yet another 740 acres of productive farmland lost.  NO FARMS, NO FOOD!


Conejo Creek Specific Plan – Section 4.6 Geology and Soils

Figure 4.6-1 within the Geology and Soils section illustrates the Bailey Fault which follows Lewis Rd. up from the coast, past CSUCI where it turns west through the adjoining agricultural land, entering the Specific Plan area at the Adhor Farm east end next to Pleasant Valley Rd.

It then crosses through the Pleasant Valley Rd. curve and reenters the Specific Plan area at the planned Ridgeview Rd. entrance where single family homes are proposed and continues through the man-made lake area and commercial/retail area next to 101 Freeway.

On page 4.6-4 the Bailey fault is described as such:

“Bailey Fault. The Bailey Fault marks the boundary between the western margin of the Santa Monica Mountains and the Oxnard Plain. It extends from the Mugu Lagoon area northerly to U.S. 101 and crosses through the northwest portion of the Plan Area. Available information is insufficient to conclude that the fault has not been active. Therefore, the fault is designated as potentially active.

In Page 4.6-5 under Seismic Risk and Ground Acceleration.  It states:

“The proximity of active faults is such that the Specific Plan area has experienced strong seismically induced ground motion and it is likely that the Plan Area will experience strong seismically induced ground motion in the future.”

In addition, Figure 4.6-2 Illustrates Areas of Potential Liquefaction

Image Source: CIRGIS, 2009.

This figure illustrates the liquefaction area, which as you can then see overlaps Bailey Fault at Pleasant Valley Rd. and the 101 corner.

On page 4.6-7 it states:

“Liquefaction and Compaction. Liquefaction is defined as the sudden loss of soil

strength due to a rapid increase in soil pore water pressures resulting from seismic ground shaking. Liquefaction potential is dependent on such factors as soil type, depth to groundwater, degree of seismic shaking, and the relative density of the soil. When liquefaction of the soil occurs, buildings and other objects on the ground surface may tilt or sink, and lightweight buried structures (such as pipelines) may float toward the ground surface. Figure 4.6-2 shows potential liquefaction within the proposed Specific Plan vicinity.

And yet, this Conejo Creek Specific Plan EIR does not analyze this liquefaction area in relation to the Bailey Fault.  The Conejo Creek Final EIR must address this overlapping area of liquefaction and the Bailey Fault, and the magnified seismic intensity that would result within the project’s area of liquefaction from seismic activity along the Bailey fault line.


Conejo Creek Specific Plan EIR – Section 4.8 Hazards and Hazardous Materials

In the 4.8.1 Setting section of the Hazards and Hazardous Materials portion of the EIR it states:

“Federal, state, and/or local government laws define hazardous materials as substances that are toxic, flammable/ignitable, reactive, or corrosive.”

This same paragraph states:

“Hazardous materials impacts are normally a result of project related activities disturbing or otherwise encountering such materials in subsurface soils or groundwater during site grading or dewatering”

Conditions such as would be created by dredging a 2 mile long, 300 foot wide, 20 foot deep bypass channel ditch and 2 lakes totaling 40 acres.  In addition, all this dredged soil would be graded and moved to add height to this farmland floodplain area.

It goes on to say:

“Other means for human contact with hazardous materials are transportation accidents associated with the transportation of hazardous materials along highways and railroads.”

Not to mention, the arterial roads connecting the industrial areas to the highways.  The proposed Conejo Creek development expanded industrial area would have second arterial streets routing truck and delivery traffic to both the Pleasant Valley Rd and through the Camarillo Springs area to reach the 101 Freeway.

on Page 4.8-7 in the Hazards and Hazardous Material section it states:

“As part of the Phase I ESA, GeoSearch was contracted to provide a database search of public lists of sites that generate, store, treat or dispose of hazardous materials or sites for which a release or incident has occurred. The GeoSearch search was conducted for the project site and included data from surrounding sites within a specified radius of the property.”

There are 27 listings of sites that “generate, store, treat or dispose of hazardous materials or sites for which a release or incident has occurred.” 

This is not a table of all the Pancho Rd industrial area companies that handle hazardous materials…but only a documentation of those 27 sites that have had a hazardous material “release or incident”.  The Final EIR should include a complete survey of all the businesses in the area that handle hazardous materials in order to adequately asses the Hazards and Hazardous Materials in this area

With 2,500 residential units and a population of 6,500 living within a mile of this existing industrial site, there must be a complete documentation of all the businesses within the Pancho Rd. area and their hazardous material use, in order to responsibly assess the danger of “release or incidents” occurring in this area in the future.


Conejo Creek Specific Plan EIR – Section 4.8 Hazards and Hazardous Materials

On Page 4.18-2 it states:

“As a result of soil sampling and analysis of onsite soils and an asbestos-containing material (ACM) and lead-based paint (LBP) survey of the onsite structures, the Phase II ESA determined the following:

Listed is the Stuart Property where Concentrations of the pesticide DDE and toxaphene exceeding screening levels to which they were compared were detected in the soil samples collected from portions of the proposed school location.”

Page 4.8-16  goes on to say in the Impact HAZ-2:

“The project would involve grading and excavation for development activities. Exposing contaminated materials, hazardous materials storage or waste disposal areas could result in health risks to construction workers or the public, and if left in place, could result in adverse health risks to occupants of buildings, as well as users of the parks and recreational facilities constructed over such materials. This would be a potentially significant impact.”

Yes, certainly a significant concern when an elementary or middle school is to be constructed on the site where DDE and Toxaphene concentrations have been found.

With all the dredging needed for the 2 mile long, 300 foot wide, 20 foot deep bypass channel and the 40 acres of lakes what studies would be done to monitor “toxic drift” from disturbed pesticides now banned, but still buried and persistent in the soil?

With the athletic fields of Adolfo Camarillo High School within 1 mile and hundreds of Woodside Greens and Camarillo Springs surrounding this huge construction site this risk of toxic drift is a significant public health issue.

As the residents of Woodside Greens can attest, the “dust control” measures of the Calleguas Creek widening certainly do not contain or eliminate the constant dust and dirt created by these projects.


Conejo Creek Specific Plan EIR – Section 4.9 – Hydrology and Water Quality

On Page 4.9-8 it states:

“Impact HWQ-3 –  Portions of the proposed Specific Plan area are located within the FEMA designated 100-year flood zone. However, the proposed bypass channel and levee systems within Conejo Creek would eliminate the 100-year flood hazard within the Specific Plan area.”  

However, though the development site might be “lifted” out of the floodplain, Figure 4.9-3 “FEMA 100-Year Floodplain With Proposed Specific Plan Improvements” illustrates the remaining flood areas surrounding the Conejo Creek development.

This flooding area surrounds the development on 3 sides.  The Conejo Creek development of 2,500 homes and 100+ acres of industrial development would then be, in the end, surrounded on 3 sides by 2 creeks draining 2 separate watersheds.

With the projected increase in intensity and duration of extreme-flooding in the future, how smart are we to develop this natural occurring floodplain?  This is farmland floodplain that is prime agricultural land because of this regular enrichment due to flooding.

Best management practices for flood control now advocate utilizing natural “spreading” areas that do not result in the ongoing maintenance and operation costs of man-made flood control systems.

Not only are we filling-in our agricultural “view to the sea”…we are filling-in a farmland floodplain that is meant to handle these creek overflows naturally.  Infrastructure flood control costs and the resulting “restitutions for damages” to residents and businesses when they fail are what we, the taxpayers, pay for in the end.


Conejo Creek Specific Plan EIR – Section 4.10 Land Use and Planning

On page 4.10-7 it is stated:

“LAFCO also enforces the County’s Guidelines for Orderly Development. The Guidelines for Orderly Development make Ventura County unique in the State in terms of County/City development issues. Originally adopted in 1969 by the Ventura LAFCO, Ventura County, and each of the cities in the County, the Guidelines for Orderly Development are statements of local policies which provide that urban development should occur, whenever and wherever practical, within incorporated cities.”

Not only should development occur within incorporated cities, but it should first occur within the City’s developed areas and not on our surrounding prime farmland.  In the Final EIR all the alternative sites within our City Limits that could absorb these residential, commercial and industrial land uses should be analyzed.

The 1,445 medium density homes planned for this development and defined as two and three story multi-family residential units at 15 – 18 units per acre, should be distributed throughout the City where the efficiencies of existing urban services and road infrastructure can be utilized.

As planned, within the Conejo Creek development these 1445 multi-family residential units are located on just 98 acres of densely populated housing.

In addition, the industrial “campus” should be analyzed as to whether it is regionally necessary or not.  The Sakioka Industrial area has already been approved to proceed on the farmland between Del Norte and Rice on the south side of the 101 Freeway.  This will be a 400 acre research and development business park within minutes of Camarillo.

Why do we need industrial development when the City of Oxnard is creating so much, so close to our community?  What are we becoming?


Conejo Creek Specific Plan EIR – 4.11 Noise section

The Conejo Creek Specific Plan as described in this Environmental Impact Report proposes to widen Pleasant Valley Road into a 6 lane thoroughfare.  The noise level for homes along Pleasant Valley Rd already exceeds Camarillo’s City Noise Ordinance by at least 10 decibels. The DEIR states that an increase of 3 decibels is actually equivalent to a doubling of sound energy.

If this project is built, the exterior noise level for two story homes is projected to be 75 decibels  (20 decibels over the Noise Ordinance).  The draft EIR states that, ambient noise levels greater than 65 decibels can interrupt conversations”.  

The noise level is recognized to be so great that for the new homes in this proposed development, one of  the noise mitigations is to provide air conditioning because it would be too noisy to open the doors and windows of their homes.

In speaking of the existing homes along Pleasant Valley Road in Woodside Greens, the Draft EIR states: ”the implementation of structural measures or sound barriers may be infeasible due to physical, economic, or other constraints”. To say that the mitigations required to bring the noise level down to acceptable levels is too costly, or physically impossible means that if this project is approved, then the existing residents will just have to live with not being able to carry on normal conversations in their homes.  This is obviously unacceptable.

There is a Noise Ordinance in place in the City of Camarillo to protect our quality of life.  Any plan or development must be required to adhere to it…or why then do we even have a Noise Ordinance in the first place?


Conejo Creek Specific Plan EIR – Section 4.13 Public Services

On page 4.13-9 it reads:

“Buildout of the proposed Specific Plan would increase demand for police protection services. Ventura County Sheriffs Dept.(VCSD) has reviewed the proposed Specific Plan and determined that no new or expanded police facilities would be required to serve the proposed Specific Plan area (Commander Steve DeCesari, January 19, 2010). 

However, the proposed Specific Plan would increase demand for additional personnel and equipment as development occurs. Based on the current officer-to-population ratio of 1 for every 1,283 and the 6,500 residents that would be generated by the proposed Specific Plan, the VCSD has determined that five additional officers would be needed to maintain acceptable levels of service and response times.  Additionally, an investigator would need to be added for the increased patrol beats and an office staff member may also be necessary to support the increased workload.”

A total of 5 new officers and 2 new staff people would be needed to sufficiently patrol both the City of Camarillo area and the Conejo Creek development of 6,500 residents.

3,800 of these 6,500 residents (figured by multiplying the 1,445 medium density housing units x the average 2.64 persons per housing unit) would be housed in multi-family residential units on 98 acres.

The Final EIR should speak to the additional policing issues created by this large number of 1,445 multi-family units in a dense, 98 acre area.

This section goes on to say:

“Funding for additional staffing and equipment is allocated to the VCSD through the City’s budget process and is not directly tied to individual development projects.”

So in other words, all of us, as residents of Camarillo, will be the ones to pay for the additional 5 sheriffs and 2 staff people needed to help cover the Conejo Creek development…and the added issues of policing a dense, multi-family housing situation adjacent to the 101 Freeway.

Just what kind of public safety situation are we getting ourselves into with this large, densely populated Conejo Creek Development?


Conejo Creek Specific Plan EIR – Section 4.13 Public Services

On Page 4.13-9 it states:

“Impact PS-3 – The proposed Specific Plan would generate an estimated 1,251 elementary and middle school students, and 293 high school students. The addition of these students could adversely affect the existing school facilities in the PVSD and OUHSD.”

Table 4.13-4 – “Project School Enrollment and Capacities” notes that the PVSD School District has a capacity of 4,015.

Current enrollment is now 3,777, which is 94% of current capacity.

Students generated by the Conejo Creek Project would be a total of 1,251 elementary and middle school students.

On page 4.13-12 the EIR addresses the cumulative effect of added students within the entire Pleasant Valley School District:

“Cumulative development under the General Plan, would include 5,824 additional residential units and 2.98 million square feet of non-residential development.  Cumulative residential development would be expected to generate approximately 3,816 students under cumulative conditions. The cumulative increase in students may exceed the capacity of schools within the PVSD and OUSD and therefore require new or altered school facilities in the future.”

With the current enrollment of 3,777, we would more than double our enrollment with the 3,816 expected students to be generated by our City’s cumulative development…bringing us to a 189% of capacity situation.

Though the Conejo Creek development would generate State mandated school impact fees, these fees would fall far short of covering the financial burden placed on our community to provide for the cumulative doubling of our student population into the future.


Conejo Creek Specific Plan EIR – Section 4.15 Transportation and Circulation

On Page 4.15-9 states:

U.S. 101 Northbound Auxiliary Lane. The project applicant shall fully fund construction of an auxiliary lane on the U.S. 101 northbound mainline. The auxiliary lane shall be constructed between interchanges from Santa Rosa Road/Pleasant Valley Road to Flynn Road; from Lewis Road to Carmen Drive; and from Carmen Drive to Las Posas Road.”

It goes on to say:

“However, traffic generated by the proposed Specific Plan would continue to contribute to unacceptable Levels of Service along the U.S. 101 mainline. 

The U.S. 101 mainline is expected to continue to operate at Level Of Service F with implementation of the Specific Plan and construction of the auxiliary lane. In addition, improvements that fall within Caltrans jurisdiction (i.e. the auxiliary lane) would be subject to Caltrans approval and therefore timing and implementation of any improvements within Caltrans jurisdiction cannot be assured at this time.

In other words, these “improvements” would not improve the Level of Service “F”  (essentially gridlock) on the 101 Freeway and are not assured to be approved and implemented by Caltrans.











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