Attachment 11 - Responses to Comments — Camarillo City Council, February 14, 2024

Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 4 RESPONSES TO COMMENTS RECEIVED ON THE DRAFT SECOND SUBSEQUENT MND INTRODUCTION The Draft Second Subsequent MND was circulated for public review and comment for 20 days from November 9 through November 28, 2023. During this time period, public agencies, organizations, and the pubic in general were afforded the opportunity to review the Draft Second Subsequent MND and submit written comments regarding the documents and the proposed project. By the end of the public review period, the City of Camarillo had received 12 letters, emails, and online form submittals commenting on the Draft Second Subsequent MND. The 12 comment letters, emails, and online form submittals that were received from the organizations and individuals are shown in the following list and are provided on the following pages. Commenting Organization or Individual Submittal Date Mason Luna November 10, 2023 Melanie (last name not provided) November 11, 2023 Michael Gold November 13, 2023 Ventura Audubon Society November 13, 2023 David Long November 14, 2023 Ellen Schachter November 14, 2023 Kristen Kessler November 17, 2023 Joan Handzel November 18, 2023 Nomi Park November 22, 2023 Monique Fairfax November 27, 2023 Merrill Berge November 28, 2023 Ventura County Citizens Against Mega Gas November 28, 2023 Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 5

City of CamarilloPublic Comments
Friday, November 10, 2023 03:40 PMPUBLIC COMMENTS
NOTICEThis is a public document and will be posted as part of the public record. Any attachments, pictures, andinformation submitted will be subject to disclosure in accordance with applicable law, including the PublicRecords Act.

IDENTIFICATION
Name Mason Luna
Address 888 Palmer AveCamarillo, CA, 93010
Telephone
Email [email protected]
Public Records Acknowledgement By checking this box, I acknowledge that I understandanything I submit will become part of the public record and besubject to disclosure in accordance with applicable law,including the Public Records Act.

Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 6

City of CamarilloPublic Comments
Saturday, November 11, 2023 03:14 PMPUBLIC COMMENTS
NOTICEThis is a public document and will be posted as part of the public record. Any attachments, pictures, andinformation submitted will be subject to disclosure in accordance with applicable law, including the PublicRecords Act.

Meeting Date Tuesday, December 5, 2023
Agency Planning Commission
Item Type Agenda Item
Item Number or Subject Costco
Position Support
Comments It will be a huge benefit to the city and the residents. We need the gas station too. Camarillo has higher gas prices than other cities for some reason.

Upload Additional Information

IDENTIFICATION
Name melanie
Address Camarillo, Calif, 93012
Telephone
Email
Public Records Acknowledgement By checking this box, I acknowledge that I understandanything I submit will become part of the public record and besubject to disclosure in accordance with applicable law,including the Public Records Act.

Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 7

1 Sean Konenakeaw
From: Jaclyn LeeSent: Monday, November 13, 2023 10:02 AMTo: Janessa GutierrezCc: Sean KonenakeawSubject: FW: 226M(5)/CUP-422 Categories: To-Do
Please save this email for distribuƟon to the PC. Jackie Lee AICP , Planning Manager City of Camarillo | 601 Carmen Drive, Camarillo, CA 93010 (805) 383-5616 | [email protected] -----Original Message----- From: Michael Gold <[email protected]> Sent: Monday, November 13, 2023 10:01 AM To: Jaclyn Lee <[email protected]> Subject: 226M(5)/CUP-422 Please move to approve the Second Subsequent MND. It is a win-win for the city. Added tax base, added retail availability and all done with no impact on residenƟal areas Michael zHold Sent from my iPhone Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 8

venturaaudubon.org / P.O. Box 24198 Ventura, California 93002 Thursday, November ϭϯ, 2023
RE: Costco Development
Dear Councilmembers,
The Ventura Audubon Society ƚaŬĞsissuĞǁiƚh the proposed Camarillo Costco development.We are concerned about the impact the project will have on local wildlifeaŶdůŽssŽĨŽƉĞŶsƉaĐĞ.Bird populations are falling all over the United States; three billion birds have been lost in the U.S. and Canada since the 1970’s (State of Birds Report 2022; StateoftheBirds.org).

The proposed Costco site is a foraging ground for red-tailed hawks and other raptors, habitat for red- winged blackbirds and sŽŶŐďirds;sƉarrŽǁs͕ƉiƉiƚs͕ŐŽůdĨiŶĐh͕ĞƚĐ͘ͿaŶdŽƚhĞrŐrŽuŶdďirds;dŽǀĞs͕ ƉiŐĞŽŶsͿƚhaƚĨŽraŐĞaŶdƉŽƚĞŶƚiaůůyŶĞsƚƚhĞrĞ͘ /ƚis known to provide habitat for special status species including western burrowing owl and horned lark. Because of the development that is already in progress north of the 101, and the eventual development of the second field on Springville Drive and Ventura Road, we are concerned that birds will abandon the areaaŶdƚhĞiŶĐrĞasiŶŐůŽssŽĨŽƉĞŶsƉaĐĞ.

We contend it is inadequate to rely on the EIR conducted in 2008 to address current biological impacts of the proposed project because the biological survey upon which the assessment is based is 19 years old (conducted in January 2004). Furthermore, it provides inadequate data because it was conducted in winter when there are the lowest levels of flora and fauna activity. Spring is the optimal season for biological field surveys for projects where only one survey is conducted. Additionally, listing status of plants and animals have changed in the nearly 2 decades since 2004 and this information needs to be updated in the assessment.

A new CEQA-level assessment is necessary to determine potential impacts to and mitigation for biological resources. This assessment must be based on a current field survey along with updated literature review and regulatory analysis. Additional issues including habitat loss, greenhouse gases, night lighting, traffic, air pollution, and cumulative impacts must also be studied. We ask that a focused EIR or mitigated negative declaration be conducted to study these impacts. At a minimum, a new initial study should be prepared.

Thank you for your time and consideration.

Respectfully,
____________________________ ____________________________ Cynthia Hartley Rachel Ameche
Conservation Committee Chair President
[email protected] [email protected]

Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 9

City of CamarilloPublic Comments
Tuesday, November 14, 2023 03:56 PMPUBLIC COMMENTS
NOTICEThis is a public document and will be posted as part of the public record. Any attachments, pictures, andinformation submitted will be subject to disclosure in accordance with applicable law, including the PublicRecords Act.

Meeting Date Tuesday, December 5, 2023
Agency Planning Commission
Item Type Agenda Item
Item Number or Subject Costco development and gas pumps.

Position Support
Comments I am all in favor. We need it. It will be very good for Camarillo Upload Additional Information

IDENTIFICATION
Name David Long
Address 5025 Rexton DrCamarillo , CA, 93012
Telephone (818) 921-6160
Email [email protected]
Public Records Acknowledgement By checking this box, I acknowledge that I understandanything I submit will become part of the public record and besubject to disclosure in accordance with applicable law,including the Public Records Act.

Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 10

City of CamarilloPublic Comments
Tuesday, November 14, 2023 09:05 PMPUBLIC COMMENTS
NOTICEThis is a public document and will be posted as part of the public record. Any attachments, pictures, andinformation submitted will be subject to disclosure in accordance with applicable law, including the PublicRecords Act.

Meeting Date Tuesday, December 5, 2023
Agency City Council
Item Type Agenda Item
Item Number or Subject CPD-226M(5)/CUP-422, Costco Wholesale Position Support
Comments
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IDENTIFICATION
Name Ellen Schachter
Address 5025 Rexton DriveCamarillo, CA, 93012
Telephone (310) 962-2721
Email [email protected]
Public Records Acknowledgement By checking this box, I acknowledge that I understandanything I submit will become part of the public record and besubject to disclosure in accordance with applicable law,including the Public Records Act.

Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 11

City of CamarilloPublic Comments
Friday, November 17, 2023 08:16 PMPUBLIC COMMENTS
NOTICEThis is a public document and will be posted as part of the public record. Any attachments, pictures, andinformation submitted will be subject to disclosure in accordance with applicable law, including the PublicRecords Act.

Meeting Date Tuesday, December 5, 2023
Agency Planning Commission
Item Type Agenda Item
Item Number or Subject CPD-226M(5)/CUP-422, Costco Wholesale Position Oppose
Comments Dear Commissioners, I am opposed to the Costco project going through as planned. I urge you to require that an EIR be conducted. This is a massive project that will exceed allowable emissions for air pollution, yet no EIR is being conducted. There will be huge impacts on traffic, air pollution, emergency response times, and local wildlife. Please don't rush this process.

Thank you for your time and consideration.

Kristen Kessler
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IDENTIFICATION
Name Kristen Kessler
Address 10645 Vinca Lane, APT 102Ventura, CA, 93004
Telephone (805) 705-3520
1 Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 12

From: joan handzel
To: Jaclyn Lee
Subject: Need For Environmental Impact Report (EIR) re Inadequate Costco MND Date: Saturday, November 18, 2023 4:17:23 PM
Absent from the Subsequent Mitigated Negative Declaration (MND) regarding the proposed Costco
project is an in depth analysis of how the proposed Costco and its mega gas station will affect the quality of life of nearby residents.

Figure 11 (P. 43) of the MND ( Photo attached) illustrates the close proximity of about 1,200 apartments, townhomes, and single family homes built on nearly 174 acres east of Springville Drive just across the 101 Freeway from the proposed project. When the City approved the 2007 original plan, that area just across the Freeway was a strawberry field and the City did not require an EIR. Since then, in its various Declarations regarding the proposed commercial site, the City has ignored any likely adverse impacts a car-magnet Costco would have on nearby residents. One of those apartment buildings is home to hundreds of low- income seniors.

Though the report repeatedly states that there are indeed two entrances to the site from Ventura Boulevard, the MND overlooks routes that one has to travel to get there. Will drivers choose to take Ponderosa to avoid the dreaded Las Posas-Ventura Boulevard intersection? Will southbound traffic on Earl Joseph escalate, impacting residents wishing to take Ponderosa to exit the Springville development? How will increased traffic on the 101 affect those wishing to exit at the Springville off ramp?
The addtion of a mega gas station is most distressing. There is no need for another gas station.

One has recently been approved on Arneill Road and another is planned for Ralph's empty corner lot on Las Posas. The area on the Costco site where 42 vehicles will sit idling waiting for their turn at the pump and spewing pollution into the atmosphere is located in the "most remote area of the site," just next to the freeway, directly across the nearby residential area.

We don't need the additional pollutants.

The residents who will be affected by the proposed project deserve to have an INDEPENDENT EIR requiring a comprehensive study and analysis of impacts to traffic, air, existing businesses, and property values.

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Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 13

Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 14

From: Nomi Park
To: Jaclyn Lee
Subject: Attention: Jaclyn Lee, Planning Manager RE: Second Subsequent Mitigated Negative Declaration for Costco project and Mega Gas Station
Date: Wednesday, November 22, 2023 12:06:48 PM
Dear Jaclyn,
I am writing to express my deep concerns regarding the Second Subsequent MND for the Costco project and Mega Gas Station in Camarillo. I strongly believe that the scale and nature of this development necessitate a comprehensive Independent Environmental Impact Report to thoroughly assess potential environmental impacts. I cannot imagine the addition of another gas station, let alone a Mega Gas Station, in our small city will not have a negative impact on residents' quality of life, traffic, commute and emergency response times, soil, air, water, wildlife, existing businesses, etc. We already have at least 4 or 5 gas stations within a 2 mile radius from the Costco project site. The addition of a Mega Gas Station seems overkill.

Also, with California heading to fully electric vehicles by 2035 why would we want to add a Mega Gas Station to our city?
Please take my and my neighbors concerns into consideration when reviewing this project and the impact it will have on our community.

Thank you,
Nomi Park
Resident of Springville Community, Camarillo
Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 15

From: Monique Fairfax
To: Jaclyn Lee
Subject: No Costco
Date: Monday, November 27, 2023 12:29:48 PM
Please stop the proposed building of Costco in Camarillo. It will impact my neighborhood directly. The giant home construction project by Springville has increased mega-ton truck traffic significantly at all hours. We do not want delivery trucks on our residential streets due to the noise and pollution. The small windy road has a 10 Mph hairpin turn. It is unsafe for the amount of people that will are already residing here Soon, many more people will be moving into the new homes. There are many conveniences and supermarkets, gas stations in this area. We have Costco in Oxnard and it is very busy by all accounts. Accidents happen daily, and the noise is at an unhealthy high decibel reading. We don’t need more buildibg in this part of Camarillo. Please protect the limited safety and health we have left. The gas station alone will pollute the land; people may get sick or worse from the impact of this project. Please consider the community concerns before allowing this project to continue.

Respectfully,
Monique Fairfax
Sent from my iPhone
Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 16

From: Merrill Berge
To: Jaclyn Lee
Subject: Camarillo Costco Second Subsequent MND 2023-4
Date: Tuesday, November 28, 2023 11:36:48 AM
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Dear Jacqueline and the Camarillo Planning Commission,
I dove into the Camarillo Costco Draft Second Subsequent MND 2023-4 and have several areas of concern that would also seem to be of concern to the Camarillo Planning Commission.

Pg. 11 - There would be four covered fueling bays, each with four gas pumps which fuel two cars each. This results in 16 fueling dispensers that would provide a fueling capacity for 32 cars at a time. A proposed stacking area provides space for an additional 42 cars waiting to get to a fueling position. - see comment on "hotspot" below Pg. 12 - Four underground fuel tanks would be installed with the gas station. Specifically, there would be two 40,000-gallon regular gas tanks, one 40,000-gallon premium gas tank, and one 1,500-gallon fuel additive tank. - this is in addition to the fuel tanks already in place at 112 existing gas pumps along the main Camarillo arteries of Las Posas, Carmen and Arneill, plus those being installed at the 16 NEW gas pumps already approved on the corner of Las Posas Plaza and in the KMart redevelopment site. (see map at end) Pg. 14 - The preliminary site plan provides a total of 901 parking stalls, including 19 handicapped accessible stalls and 181 stalls for electric vehicles. Of the 181 electric vehicle stalls, 46 stall would provide electric vehicle supply equipment (EVSE) at first occupancy while the remaining 135 stalls would provide electrical infrastructure for the future installation of EVSE.

Only 5% of the 901 parking stalls would have EV charging infrastructure (901 minus the 46 initial EV charging spots = 855 parking spots w/o EV charging) Pg. 34
Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 17

Pg. 33
AQ-3 The project developer shall include in construction and building management contracts the following requirements or measures shown to be equally effective:
• Use solar or low-emission water heaters in the commercial buildings. • Require that commercial landscapers providing services at the common areas of project site use electric or battery-powered equipment, or other internal combustion equipment that is either certified by the California Air Resources Board or is three years old or less at the time of use, to the extent that such equipment is reasonably available and competitively priced in Ventura County (meaning that the equipment can be easily purchased at stores in Ventura County and the cost of the equipment is not more than 20 percent greater than the cost of standard equipment).
• Provide bus stops with shelters at locations along the project frontage with Ventura Boulevard. The number of bus stops shall be determined in consultation with Camarillo Area Transit.

AQ-4 The project developer shall contribute a total of $667,502 to a TDM fund managed by the City of Camarillo.

That's it?
No solar panels on the buildings? Or on parking lot shade structures? Only 5% of 855 parking stalls with EV charging?
Consider the following analysis from the So. Coast Air Quality Management District - for the Murietta Costco location
https://www.aqmd.gov/docs/default-source/ceqa/comment-letters/2020/July/RVC200626- Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 18

01.pdf?sfvrsn=8
The Lead Agency quantified the Proposed Project’s regional operational emissions in the Draft EIR. Based on this analysis, the Lead Agency found that the Proposed Project’s unmitigated regional operational air quality impacts would be significant for NOx and volatile organic compounds (VOCs) emissions at 60 lbs/day and 76 lbs/day12, respectively, which would exceed South Coast AQMD’s regional operational air quality CEQA significance thresholds for NOx and VOCs at 55 lbs/day. The exceedance of NOx emissions would be primarily due to mobile sources visiting the Proposed Project during operation13, while the exceedance of VOCs emissions would be primarily due to gasoline dispensing operations14 .

The Lead Agency is committed to implementing operational MM-AQ-2, which requires that the project applicant provide preferential parking for clean air vehicles and offer transit subsidies for all employees of the Proposed Project for three to six months15 . Implementation of MM-AQ2 may be effective at mitigating the Proposed Project’s operational NOx and VOCs emissions, but was not able to reduce those emissions to less than significant levels.

Therefore, the Proposed Project’s regional air quality impacts from operational NOx and VOC emissions would remain significant and unavoidable at 60 lbs/day and 76 lbs/day, respectively16 .

In the Draft EIR, the Lead Agency identified South Coast AQMD as a Responsible Agency for the Proposed Project20 and included a discussion of compliance with applicable South Coast AQMD Rules, including, but not limited to, Rule 431.2 – Sulfur Content of Liquid Fuels21 and Rule 461 – Gasoline Transfer and Dispensing22. The Final EIR should also include a discussion of compliance with other applicable South Coast AQMD Rules, including but not limited to, Rule 201 – Permit to Construct 23, Rule 203 – Permit to Operate24 , and Rule 1401 – New Source Review of Toxic Air Containments25 .

Since the gasoline service station of the Proposed Project will include 32 fueling pumps and has an annual throughput of 26 million gallons of gasoline, it is important that mobile source emissions from operation of the gasoline service station are fully and adequately evaluated in the air quality analysis in the Final EIR. 2. Recommended Revisions to Existing Project Design Features (PDFs)-AQ/GHG-1 and -AQ/GHG-2 In the Draft EIR, the Lead Agency is committed to installing 17 electric vehicle (EV) charging stations at the Proposed Project.

Three EV charging stations will be installed in the warehouse parking lot, and the remaining 14 stations will be installed in the parking lot for retail uses27. Since the Proposed Project will result in significant and unavoidable long-term air quality impacts from VOCs and NOx emissions, and to further reduce those emissions, South Coast AQMD staff recommends that the Lead Agency strengthen the existing project design features to include additional EV charging stations in the Final EIR. The recommended revisions to PDFs-AQ/GHG-1 and - AQ/GHG-2 are in strikethrough and underlines as follows. PDF-AQ/GHG-1 and PDF- AQ/GHG-2 Require at least six percent of the Proposed Project’s 1,215 vehicle parking spaces (or 73 parking spaces) to include EV charging stations, four of which shall be tied to solar source from the roofs of two buildings at the time of opening, or at a minimum, require the Proposed Project to be constructed with the appropriate infrastructure to facilitate sufficient electric charging for passenger vehicles and trucks to plug-in. Electrical hookups should be provided onsite for trucks to plug in any onboard auxiliary equipment. Electrical panels should be appropriately sized to allow for future expanded use. The Lead Agency should also include analyses to evaluate and identify sufficient power available for passenger vehicles, zero emission trucks, and supportive infrastructures (e.g., EV charging stations) in the Energy and Utilities and Service Systems Sections of the Final EIR, where appropriate.

Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 19

Technology is transforming the transportation sector at a rapid pace. Cleaner trucks such as ZE or NZE trucks are increasingly more feasible and commercially available as technology advances. If using ZE or NZE trucks as a mitigation measure to reduce the Proposed Project’s operational air quality impacts is not feasible today, cleaner trucks could become feasible in a reasonable period of time within the lifetime of the Proposed Project (CEQA Guidelines Section 15364). Therefore, it is recommended that the Lead Agency develop a process with performance standards to deploy the lowest emission technologies and incentivize the use of ZE or NZE heavy-duty trucks during operation (CEQA Guidelines Section 15126.4(a)). The Lead Agency can and should develop the performance standards as follows or any other comparable standards in the Final EIR.
• Develop a minimum amount of ZE or NZE heavy-duty trucks that the Proposed Project must use during each year of the operation to ensure adequate progress. Include this requirement in the Proposed Project’s tenant selection and operation management bid documents and business agreement.
• Establish a tenant/truck operator(s) selection policy that prefers tenant/truck operator(s) who can supply the use of ZE or NZE heavy-duty trucks at the Proposed Project. Include this policy in the bid documents and business agreement.
• Develop a target-focused and performance-based process and timeline to review the feasibility to implement the use of ZE or NZE heavy-duty trucks during operation. Include this process and timeline in the Proposed Project’s tenant selection and operation management bid documents and business agreement.
• Develop a project-specific process and criteria for periodically assessing progress in implementing the use of ZE or NZE heavy-duty trucks during operation. Include this process and criteria in the Proposed Project’s tenant selection and operation management bid documents and business agreement.

Carbon Monoxide
Pg. 36
Localized areas where ambient concentrations exceed national and/or state standards for CO are termed CO “hotspots.”
The greatest potential for a CO hotspot to occur in Ventura County today is at the roadway edge of a very congested intersection.

It would seem that the 42 car "stacking area" waiting for gas should be evaluated as an equivalent to a "very congested intersection". It is not considered in the carbon monoxide analysis
Toxic Air Contaminants
No mention is made of the cumulative toxic air contaminates load when combined with the adjacent Airport emissions.

Arrival flight tracks in proximity to Costco site
Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 20

Departure flight tracks in proximity to Costco site
Nor does it take into account the greater emissions due to the increase in jet and turboprop traffic (larger engines, greater emissions) being forecast as part of the Airport Layout Plan over the next 20 years.

Table 2N from Camarillo Airport 150 Noise Study - Chapter 2 "Forecast" Document Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 21

Pg 2-39 of the Airport 150 Noise Study
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7108289/
Aircraft engine exhaust emissions and other airport-
related contributions to ambient air pollution: A review Aircraft exhausts are only one of several sources of emission at an airport (ICAO, 2011). Although exhaust plumes from aircraft engines were conventionally considered to account for most of the emissions, other sources are present within modern airports and contribute to air pollution at the local scale.

Pg. 38 - . Residential receptors were identified within the modeling domain to the north of the site and U.S. Highway 101 within the Springville Specific Plan area. The locations of the modeled receptors are shown in Figure 12.

Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 22

Airport emissions, Costco parking and gas line "stacking", and the often congested 101 freeway traffic, ride the onshore ocean air currents towards Springville (sensitive receptor area) and Spanish Hills neighborhoods. This mix of significant emissions should be cumulatively analyzed for air quality impacts.

Over 1350 housing units are in the Springville Specific Plan...many are starter homes for new families with young children. Springville Park is less than 1/2 mi from the Costco site.

The uphill neighborhoods of Spanish Hills, the Spanish Hills Park tennis courts, golf course, homes on the upslope were not evaluated for cumulative air quality impacts Pg. 114
The project site is located to the north of Camarillo Airport. According to the Noise Element of the City of Camarillo General Plan, future noise levels in the southern part of the site attributable to Camarillo Airport would not exceed 65 dBA CNEL Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 23

Though the Costco site is identified as "outside" the 65CNEL Noise Contour...it is within 3200 ft of the Camarillo Airport 8-26 Runway.

Currently jets and turboprops flights are approx. 33 flights/day...increasing to 133/flights per day within the next 20 years.

Here are the noise "footprints" for various aircraft...in general, the larger the aircraft the larger noise footprint
Costco proximity is noted with a red dot. The outer dark blue contour represents 85 db SEL.

It is critically important at this point in time to fully, cumulatively, evaluate the development projects that are being considered for this area, and specifically, the impacts they will have in total on the Springville and Spanish Hills neighborhoods.

Thank-you for your time and expertise in evaluating this Camarillo Costco project Draft Second Subsequent MND 2023-4
Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 24

Merrill Berge
805/208-6058

Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 25

November 28, 2023

Department of Community Development
Attention: Jaclyn Lee, Planning Manager
601 Carmen Drive
Camarillo CA 93010

Dear Ms. Lee,
We are an unassociated group of Camrillo and Ventura County residents, neighbors and merchants who have concerns about Costco’s plans to build a new 160,000 sq. ft. warehouse, tire center, and 32 pump fuel station, on 12 acres of open space at the corner of Springville Drive and W. Ventura Blvd. in Camarillo.

Please accept into the public record, and for the City’s consideration and response(s), our comments on the Second Subsequent Mitigated Negative Declaration 2023-4 (hereafter referred to as “SSMND”).

We strongly disagree with Cadence Environmental Consultant’s determination that no new significant impacts were identified that would require the preparation of a subsequent Environmental Impact Report.

On the contrary, we believe that the SSMND is ripe with errors and relies on faulty data and analysis that raises more questions than answers. Specifically, as it relates to estimated project impacts to traffic, Vehicle Miles Traveled (VMT), air quality and CO2 emissions, and noise/light pollution.

We also believe that it is not only reasonable, but responsible, to demand that the city require that a comprehensive Environmental Impact Report (EIR) be conducted by an independent third party, so that neighbors will know the true impacts this project will have on their daily lives and on traffic, commute and emergency response times, pollution (air, water, noise and light), public safety, wildlife and birds that live on the property, and for existing businesses and jobs in the surrounding neighborhood.

The fact that a comprehensive EIR has not been carried out for this project site since before 2007, when it was converted from agricultural uses and cultivation to commercial retail uses, is unconscionable, given the scope and scale of the proposed Costco and Amara shopping center development and the significant impacts it would have on the surrounding community, residents, environment and wildlife.

The original project called for a massive commercial shopping center, and no fuel station, that only required an MND, not an EIR, that was approved by the Planning Commission and City Council, back in 2007.

When that proposed development fell through, the project was later modified back in 2016 (the Amara Shopping Center project) and the city determined then that the proposed Amara shopping center (again, with no fuel station proposed or studied), required only a subsequent MND, no EIR, which was approved by the Planning Commission (no Council review or action) in 2016 as the Final Subsequent MND. The 2016 Final Subsequent MND anticipated a 452K sq ft. Kohls anchored shopping center, but that project ultimately fell through as well.

Here we are now in November 2023, seven (7) years after the Final Subsequent MND was approved by the Planning Commission, faced with a proposal and plans for a very different project that calls for development of a new 163,177-square-foot, one-story Costco Wholesale retail building and free-standing Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 26

fuel facility with 16 dispensers (i.e., 32 fueling positions) and a parking lot consisting of approximately 901 stalls on the eastern 20 acres of the project site. The project application and SSMND also assesses a future “second phase” of the Amara Shopping Center that would include the remaining 335,823 square feet of building area of the approved 499,000 square feet of commercial space in the western portion of the project site.

The proposed development before the city is vastly different in scope and scale than what was proposed back in 2007, and more recently, in 2016. Specifically, the addition of the proposed 32-pump fuel station, with four massive underground tanks, should in and of itself, require a conditional use permit and an EIR since a fuel station, let alone one of this massive size, was not studied nor considered as part of the uses and approvals granted by the City for the subject property in 2007 and 2016, under the Final MND (2007) and Final Subsequent MND (2016), respectively.

It is clear that this is a wholly different proposed development and use, charading as a shadow of the project(s) for a single shopping center that was approved back in 2007 and 2016, respectively. It appears that the developer is simply tacking on a “second phase” of the Amara shopping center, to be included in the SSMND, to avoid having to conduct an EIR and new, separate studies and analysis, beyond what little is required in a Subsequent MND. Case in point, no applications, plans or uses for the “second phase” of the Amara shopping center have been submitted for the City’s consideration, so how can these impacts be properly assessed in the SSMND for this project when there is no Amara shopping center project being proposed or considered? This appears to be a new and standalone project with a major new use, a massive fuel station, never properly studied nor considered by the City.

An EIR is also called for to ensure that the City considers alternative plans for the site that do not include an unstudied fuel station and a two phased commercial retail development vs. a single connected shopping center. Furthermore, all the cumulative impacts from the many new developments, housing and construction that has since come to fruition in between and surrounding Ventura Blvd. and Springville Drive, have not adequately been assessed and studied, nor mitigations considered, as it relates to this project and cumulative impacts to VMTs, CO2 emissions, noise/light pollution and public safety.

For example, the City just approved a major expansion of the Camarillo airport, and there is a 47-acre property, proximate to the project site, that anticipates the development of an additional 268,500 square feet of commercial uses and 198,767 square feet of industrial and/or office uses. Where is the in-depth study and analysis of all these cumulative impacts for residents to review and assess so that they can make an informed decision on whether or not to purchase a home near all of this proposed construction and development?
Traffic
Given the major impacts that the proposed development is anticipated to have on traffic, VMTs and commute times in the surrounding area, we demand that the City require comprehensive study and analysis of project impacts to traffic by an independent third party, preferably as part of a much-needed EIR.

We take exception to the fact that the bulk of the data that the City is relying on in the SSMND, as it relates to traffic, is coming from a firm, Kittleson & Associates, that has conducted numerous traffic impact studies Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 27

on behalf of, and paid for by, Costco, all over the west coast. They are hardly an independent third party providing fair and balanced information to the City and residents.

With that said, we also object to the “fuzzy math” and analysis being used and relayed in the SSMND that tries to curtail and hide the true impacts that this massive development will have on traffic, VMTs and commute and emergency response times in the surrounding area. Specifically, trying to decrease the estimated number of new daily vehicle trips the project will generate (and that will very much impact the thousands of residents who live just north of the project site), by using unvetted (by an independent third party) data from Costco that discounts Camarillo based trips currently traveled to nearby Costco properties in other communities, to ultimately whittle that massive figure (16,239 trips) down to a laughable rough one-third of that estimated figure (5,963 trips). And all of this is being done using formulas, as opposed to current observed traffic studies in the field on peak days and times in the year.

While we don’t disagree that some Camarillo shoppers headed to Costco outside of our community will likely shop at a new proposed Costco store in Camarillo instead of driving out of town to do so, and that those averted trips may therefore slightly decrease the number of regional vehicle trips made by capturing Camarillo Costco shoppers, those same trips from other parts of Camarillo (16,239 trips) going to other Costco stores will instead all be converging on the new site and impacting all of the neighbors who live north of the site. Add in the 14,918 vehicle trips magically assumed from the non-existent plans for the “second phase” of the Amara shopping center, and you have 31,157 daily vehicle trips per day on the roads surrounding the project site. How does this not call for more thorough study and mitigation measures to offset these impacts? Common sense alone dictates that 31,157 vehicle trips per day is very much going to impact traffic, commute and emergency response times, and carbon emissions in the surrounding neighborhoods. This issue needs more independent study.

Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 28

Furthermore, the proposed project calls for a free-standing 32-pump fuel facility that was not envisioned for in the Amara Shopping Center plans. In addition, the vehicle trip generation characteristics of the proposed Costco are different than the trip generation assumptions for a shopping center as evaluated in Final MND 2006-17 and Subsequent MND 2016-1, and the URBan EMISsions (URBEMIS) model used to estimate air pollutant emissions in Final MND 2006-17 has been replaced with the California Emissions Estimator Model (CalEEMod). It is clear that a wholly different standard for assessing development impacts to traffic, as it relates to CEQA, has been mandated since the Final MND and Final Subsequent MND for this project site were approved back in 2007 and 2016, respectively. Simply putting in the old data from the 2007 and 2016 MNDs into new formulas to meet these new requirements is inadequate and requires more thorough review and actual field analysis and study.

Pollution
According to the City of Camarillo CEQA Environmental Guidelines, a potentially significant impact would occur if the project generates an increase of 25 pounds per day or more of operational emissions of ROC and/or NOx. As shown in Table 2 of the draft SSMND report, the daily operational emissions of both ROC and NOx would exceed 25 pounds per day.

Therefore, the air quality impact of the proposed project would continue to be potentially significant.

It appears that the consultant’s response to offset the “significant” impacts this project will have on air quality and carbon emissions for thousands of residents who live near the project site, is to have Costco make a modest contribution of $243,557 to a TDM fund, required under mitigation measure AQ-4. This is unacceptable. Why are Costco and the developer not being asked to make real modifications to their proposed development in order to offset the significant increase in carbon emissions and harmful air pollution that they will be generating? This is similar to massive polluters paying a fee to offset their carbon emissions rather than doing the real work and lowering their carbon footprint and practices. Why is Costco not being asked to consider alternative plans then that include no fuel station, or perhaps a fuel station with half the number of pumps, to offset the significant emissions they would be generating? Furthermore, the preliminary site plan (pg. 14) provides a total of 901 parking stalls (BTW, that’s over 100+ parking spaces beyond what is required, that’s a lot of unnecessary asphalt), including 19 handicapped accessible stalls and 181 stalls for electric vehicles. Of the 181 electric vehicle stalls, only 46 stalls would provide electric vehicle supply equipment (EVSE) at first occupancy while the remaining 135 stalls would provide electrical infrastructure for the future installation of EVSE. That means that only 5% of the 901 parking stalls would have EV charging infrastructure (901 minus the 46 initial EV charging spots = 855 parking spots w/o EV charging).

With the state of California requiring that all new cars sold in 2035 and beyond be zero-emission vehicles, and the fact that we as a city and state are supposed to be making a concerted effort to significantly decrease carbon emissions to address climate change, how does a 32-pump gas station and only 5% of the proposed parking lot spaces being truly EV charge ready, meet these new mandated standards? Simply put, it does not. More study is needed.

Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 29

We were also underwhelmed by the lack of thorough and independent analysis, if any, examining impacts the project will have on noise pollution (during and after construction), light pollution, and stormwater runoff pollution from dozens of acres of newly paved asphalt. In terms of light and noise pollution that the proposed gas station will generate, why is the fuel station not required to operate during the same hours as the proposed warehouse? The retail warehouse and tire center hours are anticipated to be Monday through Friday from 10:00 a.m. to 8:30 p.m., Saturday from 9:30 a.m. to 6:00 p.m., and Sunday from 10:00 a.m. to 6:00 p.m. The gas station hours are expected to be daily from 5:00 a.m. to 10:00 p.m. More study is needed.

For these reasons, and more (to be submitted at a later date), it is clear that there are simply more questions than answers that still need to be addressed before the city approves anything. We respectfully request that the city slow down and require that a comprehensive EIR be conducted by an independent third party, and that as part of that EIR, alternative plans, including those that include no or a smaller fuel station, be considered. We also request that meaningful mitigation measures be set in place as conditions of any project approvals and entitlements, that lessen projects impacts to traffic, VMTs, carbon emissions, pollution and to the environment.

Sincerely,
Ventura County Citizens Against Mega Gas

Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 30 RESPONSES TO COMMENTS CEQA does not require the lead agency to prepare responses to public comments submitted in response to an MND. (Public Resources Code Section 21091(f); State CEQA Guidelines Section 15074(b)). Nonetheless, the following responses are provided to create the most complete record possible. As several letters include the same comments, the responses are organized by topic rather than by letter to avoid duplication. Topic 1 - Preparation of a Subsequent MND rather than an EIR Comment Why did the City require preparation of a Second Subsequent MND rather than an EIR? Response On September 12, 2007, the Camarillo City Council approved General Plan Amendment GPA 2006-2, Change of Zone CZ-297 and CZ-298, Commercial Planned Development CPD-226, and Conditional Use Permit CUP-294 for the Paseo Camino Real commercial center project at a 44.84-acre site located within the Airport North Speciﬁc Plan area. This project involved the development of up to 499,000 square feet of building coverage with an assumed mix of 429,469 square feet of retail space, 29,531 square feet of restaurant space, and 40,000 square feet of ofﬁce space, which would be provided in buildings ranging from 2,400 square feet to 196,645 square feet. As is typical for many proposed developments, the actual building shapes and sizes would be determined during the building plan review process. However, the total amount of building space for the project would not exceed 499,000 square feet. In connection with this approval, the City Council adopted MND 2006-17, which evaluated the impacts the development of the proposed 499,000-square-foot commercial center. In 2011, the City of Camarillo Planning Commission approved a Major Modiﬁcation [CPD-226M(1)] to the approved commercial project and approved an addendum to MND 2006-17. In 2016, the Planning Commission approved another Major Modiﬁcation [CPD-226M(3)] to change the layout of the project site plan and changes to the allowed building elevations. The impacts of this Major Modiﬁcation were evaluated in a Subsequent MND (Subsequent MND 2016-1 for the Amara Shopping Center). Although no development of the property under any of the previous approvals has occurred to date, CPD-226M(3) represents the current approval for development of the overall property. MG2 Corporation is requesting approval of a Major Modiﬁcation to CPD-226M(3) to allow the development of a new 163,177-square-foot, one-story Costco Wholesale retail building and free-standing fuel facility with 16 dispensers (i.e., 32 fueling positions) and a parking lot consisting of approximately 901 stalls on the eastern 20 acres of the project site (proposed project). The future second phase of the Amara Shopping Center would include the remaining 335,823 square feet of building area of the approved 499,000 square feet of commercial space in the western portion of the project site. No modiﬁcation to the remaining western 24.84 acres of the project site is requested as part of the proposed project. The proposed Costco project represents a modiﬁcation to the approved Amara Shopping Center project which was previously assessed under CEQA. Therefore, special rules apply. Section 15162 of the State CEQA Guidelines addresses the situation of when an MND has previously been adopted for a project and a subsequent environmental document needs to be prepared. The lead agency (in this case the City of Camarillo) can only require a subsequent EIR when (a) substantial changes are proposed for a project that Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 31 require major revisions to the previously adopted MND due to new signiﬁcant environmental effects; (b) substantial changes occur with respect to the circumstances under which the project will be undertaken that will require major revisions to the previous MND due to new signiﬁcant environmental effects; or (c) there is new information of substantial importance not known at the time of the previous MND’s approval that shows a new signiﬁcant effect. If none of these criteria for a subsequent EIR are met, then the lead agency may decide whether to prepare a subsequent MND, an addendum, or no further documentation. In this case, the potential impacts of the proposed project have been evaluated in the Draft Second Subsequent MND, which was required to be circulated for public comment, unlike an addendum or no further documentation. The Second Subsequent MND includes updated technical analyses that reﬂect the City’s current adopted CEQA signiﬁcance thresholds, methodologies, and current conditions. The analyses have the same level of detail as would be required in an EIR. The preparation of the Second Subsequent MND is fully consistent with the requirements of CEQA. Preparation of an EIR or a new Initial Study would also not change the conclusions of the Draft Second Subsequent MND. Topic 2 – Independent Analysis Comment The City should not have relied on unvetted analysis provided by Costco. Response While the Draft Second Subsequent MND incorporates the information presented in certain technical reports prepared by experts under contract to Costco, the Draft Second Subsequent MND was prepared by Cadence Environmental Consultants under contract to the City of Camarillo. Prior to the use of the technical reports in the Draft Second Subsequent MND, the reports were reviewed for consistency and accuracy by Cadence and City staff and subject to revision. This is expressly allowed under CEQA and is consistent with other development projects in the City of Camarillo. Consistent with CEQA, the Draft Second Subsequent MND reﬂects the independent judgment of the City of Camarillo. This is even speciﬁed at the bottom of the Title Page for the Draft Second Subsequent MND which states that “The City of Camarillo has independently reviewed and approved the information presented in this document.” Topic 3 – Impacts to Biological Resources Comment The proposed project site is a foraging ground birds and is known to provide habitat for special status species. Because of the development that is already in progress north of the 101, and the eventual development of the second ﬁeld on Springville Drive and Ventura Road, birds will abandon the area and the increasing loss of open space. A new CEQA-level assessment is necessary to determine potential impacts to and mitigation for biological resources. Response As discussed on pages 44 through 46 of the Draft Second Subsequent MND, no new potential impacts to biological resources were expected for the proposed project due primarily to the fact that the ground cover at the site is comprised of non-native grasses and vegetation growth at the site is controlled on a regular Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 32 basis by a tribe of goats that are transported to the site for this purpose. Prior to the use of goats to control vegetation growth, the entire site was disced on an annual basis. That being said, an updated Biological Resources Assessment was prepared for the Costco portion of the project site in May 2022 but it was not provided to the City prior to the preparation of the Draft Second Subsequent MND. The updated Biological Resources Assessment is provided as Appendix A to this Preliminary Final Second Subsequent MND. The areas to the east and west of the project site are located within the Airport North Speciﬁc Plan area. The properties to the east of the site are developed with the Camarillo Town Center and Camarillo Town Center West developments. The Camarillo Town Center is developed with approximately 370,000 square feet of commercial uses anchored by a Target store. The Camarillo Town Center West development site is located adjacent to the project site and is anchored by a Home Depot. Springville Drive is located to the immediate west of the project site. Beyond Springville Drive is a 47-acre property that is presently vacant, but was approved in 2016 for the development of up to 268,500 square feet of commercial uses and 198,767 square feet of industrial and/or ofﬁce uses. Ventura Boulevard is located to the immediate south of the project site. A 3.64-acre property located to the south of Ventura Boulevard is designated for Research and Development in the General Plan and zoned LM. To the south of this area is the Camarillo Hills Drain, which services a larger area of the City and is under the jurisdiction of the Ventura County Watershed Protection District. South of the Camarillo Hills Drain is Camarillo Airport, which is a public use airport with only general aviation operations. The project site is not considered to be open space. The Open Space & Conservation Element of the City of Camarillo General Plan deﬁnes open space land as “any parcel or area of land or water which is essentially unimproved and devoted to the preservation of natural resources, used for the managed production of resources, outdoor recreation or for public health and safety and is also designated as open space on the general plan.” The General Plan identiﬁes three land uses for conservation with these being agriculture, natural open space, and urban reserve. While the project site is presently undeveloped, the General Plan land use designation is General Commercial and the underlying zoning is CPD (Commercial Planned Development). The site has had approved development entitlements since 2007. The vegetation at the project site is characterized as non-native annual grassland, consisting primarily of ruderal species and non-native annual grasses. Because of the developed and urban nature of the project vicinity and the vegetation composition, the site does not provide high quality habitat for many wildlife species, and only one special-status species (i.e., burrowing owl, Athene cunicularia) was determined to have a moderate potential to occur at the site. Common wildlife species such as raccoon (Procyon lotor) and Virginia opossum (Didelphis virginiana) are likely to pass through the site, and native and non-native bird species may use the site for nesting and foraging. While several common bird species may use the site for foraging during certain times of the year, loss of foraging habitat for common bird species is not a signiﬁcant environmental impact under CEQA, and these common wildlife species are not listed under the federal or state Endangered Species Acts. However, native nesting birds are protected under the federal Migratory Bird Treaty Act (MBTA), and raptors are speciﬁcally protected under Section 3503.5 of the California Fish and Game Code. No federally or state listed bird species were determined to have potential to occur in the project area. As a California species of special concern, take of burrowing owl is prohibited.

Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 33 To address the potential for burrowing owl or other native nesting birds to occur on the site, the updated Biological Resources Assessment recommends that a preconstruction nesting bird survey be performed by a qualiﬁed biologist no earlier than one week prior to any construction during the nesting season (generally February 15 through August 31 but variable based on seasonal and annual climatic conditions) to determine if any native birds are nesting on or near the site including a 250-foot buffer for burrowing owl and other raptors. Because compliance with the MBTA and California Fish and Game Code is mandatory, this recommendation will be included as a Condition of Approval and would ensure that the project would not have a substantial adverse effect on burrowing owl or native nesting birds protected by the MBTA or California Fish and Game Code. The information presented in the updated Biological Resources Assessment conﬁrms that the proposed project would not result in potential impacts to biological resources as discussed in the Draft Second Subsequent MND. The California Department of Fish and Wildlife typically determines that the results of these assessments are acceptable for use for up to ﬁve years from the date of the assessment. Therefore, no further biological assessment is warranted at this time. Topic 4 – Emissions from Idling Vehicles Comment The proposed project will result in signiﬁcant impacts from idling vehicles. Response The evaluation of air quality impacts was performed in accordance with the Ventura County Air Pollution Control District (VCAPCD)’s Ventura County Air Quality Assessment Guidelines. The analysis included the emissions from the idling of passenger vehicles and trucks at the proposed Costco gas station. As discussed on pages 33 and 34 of the Draft Second Subsequent MND, the daily operational emissions of both ROC and NOx would exceed 25 pounds per day. Therefore, the air quality impact of the proposed project would be potentially signiﬁcant. Implementation of mitigation measures AQ-3 and AQ-4 would reduce the cumulative air quality impacts of the proposed project to a less than signiﬁcant level. A Human Health Risk Assessment (HRA) was also prepared for the proposed project. This HRA included diesel particulate matter (DPM) from the idling of project trucks and the gasoline transfer and dispensing. As discussed on pages 37 through 41 of the Draft Second Subsequent MND, the emissions associated with operation of the proposed project are less than the VCAPCD signiﬁcance thresholds. Regarding carbon monoxide (CO) hotspots, a CO hotspot that would exceed the most stringent CO standard would only occur with very heavy trafﬁc and is not likely to be exceeded until the daily trafﬁc at an intersection exceeds more than 400,000 cars/day. The 42 cars in the queue would not generate enough CO to create a signiﬁcant CO hotspot impact. Topic 5 – Project-Specific and Cumulative Traffic Impacts Comment The proposed project will have project-speciﬁc and cumulative trafﬁc impacts. Response Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 34 As a preliminary matter, the City now assesses trafﬁc impacts under CEQA based on the vehicle miles travelled (VMT), as required under state law. Trafﬁc congestion (as measured by level of service (LOS)) is no longer a CEQA issue and was therefore not addressed in the Draft Second Subsequent MND. As shown in Tables 14 and 15 of the Draft Second Subsequent MND, the proposed project would result in a substantial reduction in VMT as compared to the approved Amara Shopping Center project. Therefore, the proposed project’s transportation impacts would be less than signiﬁcant. The Paseo Camino Real commercial center project (the original project) was approved by the City Council in 2007. At that time, the area to the north of U.S. Highway 101 was used for agricultural cultivation. However, the Springville Speciﬁc Plan was under development at that time and the City was aware of the potential for development of this area. The Springville Speciﬁc Plan was approved by the City Council in 2008 and construction of the U.S. Highway 101 and Springville Drive interchange commenced shortly thereafter. Final MND 2006-17 was unable to evaluate trafﬁc impacts on Earl Joseph Drive, Ponderosa Drive west of Las Posas Road, and the Springville Drive offramps because the planned extension of Springville Drive and the U.S. Highway 101 and Springville Drive interchange did not exist at that time. Trafﬁc impacts associated with cumulative development in this area, including the Paseo Camino Real commercial center project, were ﬁrst evaluated in the EIR for the Springville Speciﬁc Plan. By the time that Subsequent MND 2016-1 was prepared for the Amara Shopping Center, the Springville Speciﬁc Plan was approved, the U.S. Highway 101 and Springville Drive interchange was constructed, Ponderosa Drive was extended to Springville Drive, Springville Drive was constructed, and development within the Springville Speciﬁc Plan area had commenced. In addition, the improvements required under mitigation measures TRA-2 through TRA-7 for the Paseo Camino Real commercial center project had been implemented. All of this has resulted in substantially improved operations at the impacted intersections identiﬁed in Final MND 2006-17. As a result, the City Trafﬁc Engineer determined that an updated trafﬁc impact analysis was not necessary for the Amara Shopping Center project. Instead, the City Trafﬁc Engineer determined that data from the Trafﬁc and Circulation Study for the Springville Commercial Project was to be used to identify the potential trafﬁc and circulation impacts of the Amara Shopping Center project. The Springville Commercial Project was proposed for the property to the west of the Amara Shopping Center project site and Springville Drive. The Trafﬁc and Circulation Study for the Springville Commercial Project was prepared in August 2014, evaluated all of the same intersections as MND 2006-17 for the approved Paseo Camino Real commercial center project, and included the trafﬁc forecasts for the Paseo Camino Real (now Amara) commercial project in its analyses of future trafﬁc volumes. The analysis found that all of the study-area intersections were forecast to operate at LOS B or better with the addition of trafﬁc from both the Amara Shopping Center project site and the Springville Commercial Project. No signiﬁcant impacts would occur. The proposed Costco project represents a modiﬁcation to the approved Amara Shopping Center project. Therefore, the proposed project would be expected to increase trafﬁc on Ponderosa Drive, Earl Joseph Drive, and the Springville Drive offramps. The potential trafﬁc impacts at these locations associated with the development of the project site were evaluated in Subsequent MND 2016-1. Projects that were approved or are pending since the Trafﬁc and Circulation Study for the Springville Commercial Project was prepared in August 2014 (such as the Camarillo Hotel and Conference Center (EIR 2017-8)) included trafﬁc from the approved Amara Shopping Center project either speciﬁcally as an Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 35 approved (in-process) development or inherently under full build out of the General Plan. Therefore, cumulative impacts of the proposed project and the related projects have been adequately addressed. Topic 6 – Trip Generation Rates Comment The trip generation rates used in the Subsequent MND are not accurate. Response All of the trip generation rates used for the proposed Costco project (including pass-by and diverted rates) are based on actual observed trafﬁc counts and surveys conducted during peak times at similar Costco warehouse and fuel station sites. The data was collected in accordance with the procedures and methodology outlined in the Institute of Transportation Engineers’ (ITE) Trip Generation Handbook (TGH). Not only is this Costco-speciﬁc data more representative of the proposed project than using data in the standard reference ITE Trip Generation Manual (TGM) for a general Discount Club, but it is also more conservative, as using the Costco-speciﬁc trip generation data results in a higher number of total trips than using the general data in the TGM. Internal capture between the proposed Costco and the surrounding shopping center uses was estimated using standard daily retail-to-retail internal capture rates in the TGH. Therefore, the trip rates in the Draft Second Subsequent MND are based on industry-accepted engineering practices and result in conservative analysis results. Topic 7 – Air Quality Mitigation Measures Comment The proposed project should implement the same air quality mitigation measures as the Murrieta Costco. Response This comment refers to the Costco/Vineyard II Retail Development in Murrieta, which is a different project in a different city, and within a different air pollution control district (the South Coast Air Quality Management District (SCAQMD)) with different signiﬁcance thresholds for air quality impacts. The Draft EIR for that project (State Clearinghouse No. 2018061602) disclosed signiﬁcant and unavoidable operational air quality impacts. Therefore, the SCAQMD requested additional mitigation measures for that project. In accordance with CEQA, the City required the project to implement the requested measures to reduce the signiﬁcant impacts to the greatest extent feasible. In this case, the operational mitigation measures for the proposed project are approved mitigation strategies for control of operational emissions as dictated by the VCAPCD in the Ventura County Air Quality Assessment Guidelines (per Section 7.5 Project Mitigation in the Ventura County Air Quality Assessment Guidelines). And were already required for the approved Amara Shopping Center project. With these measures, the proposed project’s construction-related and operational air quality impacts would be less than signiﬁcant. Therefore, no further mitigation is warranted. Topic 8 – Cumulative Air Quality impacts Comment Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 36 The Draft Second Subsequent MND did not assess cumulative impacts from other projects. The cumulative analysis should include the airport operations and the 101 Freeway. Response As discussed on page 30 of the Draft Second Subsequent MND, the VCAPCD currently recommends that projects located everywhere in Ventura County outside of the Ojai Planning Area with operational emissions that exceed 25 pounds per day of ROC and/or NOx should be considered to have signiﬁcant individual project and cumulatively considerable impacts. These thresholds apply to individual development projects only and do not apply to the combined emissions of multiple projects. As stated in MND 2006-17: Because Ventura County is currently in nonattainment for ozone, related projects could exceed an air quality standard or contribute to an existing or projected air quality exceedance. With regard to determining the signiﬁcance of the proposed project contribution, the VCAPCD neither recommends quantiﬁed analyses of cumulative operational emissions nor provides methodologies or thresholds of signiﬁcance to be used to assess cumulative construction or operational impacts. Instead, the VCAPCD recommends that a project’s potential contribution to cumulative impacts should be assessed utilizing the same signiﬁcance criteria as those for project speciﬁc impacts. Therefore, this Initial Study assumes that individual development projects that generate operational emissions that exceed the VCAPCD recommended daily thresholds for project-speciﬁc impacts would also cause a cumulatively considerable increase in emissions for those pollutants for which the County is in nonattainment. As discussed previously, operational daily emissions associated with project development would exceed VCAPCD signiﬁcance thresholds for ROC and NOx. Therefore, the emissions generated by project would be cumulatively considerable regarding a substantial contribution to an existing or projected air quality violation. This would be mitigated to less-than-signiﬁcant levels by Mitigation Measures AQ-1 through AQ-4. The freeway and the airport are existing facilities and are part of the environmental baseline. CEQA only requires analysis of changes to the baseline resulting from the proposed project. Nor does the VCAPCD require an analysis of cumulative impacts with existing facilities, as set forth above. Therefore, no such cumulative analysis is necessary or appropriate. Topic 9 – Electric Vehicle Charging Comment The Costco should provide more EV/EVSE parking spaces. Response The proposed Costco will comply with CALGreen Code and adopted amendments for EV chargers and stalls. The ﬁnal number and layout will be determined at the building permit phase of the project. The EV charger count will be based on a combination of Direct Current Fast Chargers (level 3 chargers) and Level 2 Chargers, and they will be located immediately north of the entry canopy. The chargers require a signiﬁcant amount of power. Therefore, the number of EV chargers at the site will be partially limited by the amount of electricity that Southern California Edison (SCE) can provide, which is currently limited. It will also be partly limited by the actual current demand for EV chargers at the facility.

Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 37 Providing substantially more EV charging spaces than necessary at the present time would result in less parking for non-EV vehicles which currently make up the vast majority of the vehicle ﬂeet mix. However, Costco will add EV chargers in the future based on increases in the amount of available power and member demand. In addition, Costco is proposing a number of sustainable and environmentally features, including: a. The Costco project will use pre-manufactured building components, including structural framing and metal panels, to help minimize waste during construction. b. The main building structure will be constructed with a pre-engineered system that uses at least 80% recycled steel materials and is designed to minimize the amount of material utilized. c. Roof material will be 100% recycled standing seam metal panel, designed to maximum efﬁciency for spanning the structure. d. Construction waste shall be recycled whenever possible. e. Floor sealant will contain no volatile organic compounds (VOCs) and represents over 80% of the ﬂoor area. f. Light-emitting diode (LED) lamps will be installed in the parking lots. g. Parking lot and exterior lights will be controlled by a photo sensor and time clock. h. Pre-manufactured metal wall panels with insulation carry a higher Resistance Value (more commonly known as R-Value) and greater solar reﬂectivity will be installed to help conserve energy. Building heat absorption is further reduced by a decrease in the thermal mass of the metal wall when compared to a typical masonry block wall. i. A reﬂective roof material will be installed to produce lower heat absorption and thereby lowering energy requirements during the hot summer months. This rooﬁng material meets the requirements for the U.S. Environmental Protection Agency’s (EPA’s) Energy Star energy efﬁciency program. j. The Costco project will plant native, drought-tolerant vegetation that will use less water than other common species. k. The Costco project will install high-efﬁciency restroom ﬁxtures. l. Building envelopes will be insulated to meet or exceed current energy code requirements. m. Heating, ventilation, and air conditioning (HVAC) comfort systems will be controlled by a computerized building management system to maximize efﬁciency. n. HVAC units will be high-efﬁciency, direct-ducted units. o. HVAC units will not use hydrochloroﬂuorocarbons. p. Interior lighting will be controlled by the overall project energy management system. q. Gas water heaters will be direct vent and 94% efﬁcient or greater.

Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 38 r. Extensive recycling/reuse program will be implemented for warehouse and ofﬁce space including tires, cardboard, grease, plastics, and electronic waste. s. All Costco trucks will be equipped with an engine idle shut off timer. Topic 10 – Airport Noise Comment The project will be impacted by airport noise due to more noisier aircraft. Response The Airport Master Plan cited in the comment shows that that the project site is outside the 65 dBA CNEL noise contour both under the current and ultimate 65 dBA CNEL noise contour maps for Camarillo Airport. Therefore, the proposed project would not be adversely impacted by airport noise now or in the future. Topic 11 – Fuel Station Noise and Light Comment In terms of light and noise pollution that the proposed fuel station will generate, why is the fuel station not required to operate during the same hours as the proposed warehouse? Response As discussed in the Draft Second Subsequent MND the proposed project’s noise and lighting impacts would be less than signiﬁcant. The proposed project would comply with all City lighting requirements. As discussed on page 17 of the Draft Second Subsequent MND: Parking and site lighting would incorporate the use of cutoff lenses to keep light from overﬂowing beyond the project site boundaries. The main parking lot would be illuminated with standard downward pointing lights, each containing LED bulbs afﬁxed to a maximum 35-foot light pole. The lighting ﬁxtures are proposed of a contemporary minimalistic ﬂush lens style with the height of the pole providing the optimum light distribution to reduce the total number of pole mounted ﬁxtures required to safely illuminate the site for pedestrians and vehicles. Lighting for the parking lot would be controlled by an energy management system to minimize lighting after the warehouse has closed and employees are gone from the warehouse. This is typically one hour after the warehouse has closed for business. Parking lot lighting would only remain on to provide security and emergency lighting only along the main driveways. These features would be effective in reducing light and glare. Limiting the hours of the fuel station is not warranted. Topic 12 – Hydrology Comment More analysis is needed regarding stormwater runoff pollution from dozens of acres of newly paved asphalt.

Responses to Comments
Preliminary Final Second Subsequent Mitigated Negative Declaration 2023-4 Camarillo Costco 39 Response As discussed on page 17 of the Draft Second Subsequent MND: The proposed stormwater system would be developed in accordance with the City’s Municipal Stormwater Permit (Order No. R4-2021-0105) and related Ventura County Technical Guidance Manual. Stormwater for the Costco development is proposed to discharge to an underground detention system. Runoff would be collected via multiple storm drain inlets located throughout the Costco development area. The water quality ﬂow rate for each inlet would be treated with a tributary bioﬁltration system before discharging to a single underground detention system. The underground detention system would discharge offsite to an existing 66-inch reinforced concrete pipe (RCP) stub at the corner of Springville Drive and West Ventura Boulevard before ultimately discharging to the Camarillo Hills Drain. The connection to the existing 66-inch pipe would require a drainage easement. The easement would be dedicated to Costco as part of the purchase to sale agreement and Costco per the agreement would be responsible for the maintenance of the proposed connection pipe. As discussed on pages 79 of the Draft Second Subsequent MND: New and redevelopment land use projects are also required to meet the requirements of the Regional Municipal Separate Storm Sewer System (MS4) Permit for Los Angeles and Ventura Counties (CAS004004, Order R4-2021-0105) or current permit in effect, and related requirements of the Ventura County Technical Guidance Manual for Stormwater Quality Control Measures (TGM) that are in effect at the time of building development. Projects will be required to develop a Post Construction Stormwater Management Plan (PCSMP) in accordance with the City’s Municipal Stormwater Permit. The PCSMP shall address the project’s mitigation of pollutants and stormwater runoff volume from impervious surfaces through inﬁltration, reuse, evapotranspiration, bioretention, or bioﬁltration as required by the City’s Municipal Stormwater Permit. In compliance with these requirements, stormwater runoff will be captured by storm drain inlets at proposed low points throughout the Costco site, these inlets will have trash capture devices to capture initial trash debris. Stormwater will then be routed via underground storm drain lines to six Ecopure treatment devices which will serve as a bioﬁltration system to address water quality. Treated stormwater will then be routed to an ADS Detention System designed to hold 26,000 cubic feet of stormwater volume, to address pre- versus post- stormwater runoff volume generated by the site. Through compliance with existing laws and implementation of mitigation measures HYD-1 to HYD-3, which, among other things, require the treatment of all stormwater runoff, potential impacts to water quality would be less than signiﬁcant.

Camarillo City CouncilFebruary 14, 2024

Camarillo City Council
February 14, 2024