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RESPONSES TO LATE COMMENTS RECEIVED ON THE DRAFT SECOND SUBSEQUENT MNDINTRODUCTION The Draft Second Subsequent Mitigated Negative Declaration (MND) 2023-4 for the Camarillo Costco project 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 public 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 were responded to in the Responses to Comments Received on the Draft Second Subsequent MND section of the Preliminary Final Second Subsequent MND 2023-4 which has been incorporated as Appendix I to Final Second Subsequent MND 2023-4. Following the end of the 20-day public review period for the Draft Second Subsequent MND, but prior to the City of Camarillo Planning Commission public hearing for the project on December 5, 2023, the City received three memoranda from three different County of Ventura agencies. The comments submitted by these agencies were responded to verbally during City staff’s presentation to the Planning Commission. Following the Planning Commission’s approval of the project, the approval was appealed to the Camarillo City Council by two organizations. Each organization submitted a letter identifying their issues of concern and reason for requesting the appeal. The five memoranda and letters that were received from the County agencies and organizations are shown in the following list. The individual memoranda and letters are provided on the following pages along with the City’s responses to the individual comments. Commenting Agency or Organization Submittal Date Ventura County Public Works Agency, Watershed Planning & Permits Division December 5, 2023 County of Ventura, Resource Management Agency, Environmental Health Division December 5, 2023 Ventura County Air Pollution Control District December 5, 2023 Lozeau Drury LLP on behalf of Supporters Alliance for Environmental Responsibility November 30, 2023 Law Office of Darshann M. Weinick on behalf of Ventura County Citizens Against Mega Gas December 15, 2023 Responses to Late Comments
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1 Please see comments from Yunsheng Su, Watershed Jurisdictional Drainage review:
APPLICATION COMPLETENESS:
COMPLETE –for our area of concern
ENVIRONMENTAL IMPACT ANALYSIS:
Item 31a. Flood Control Facilities/Watercourses – Flood Control Facilities / Watercourses– Ventura County Public Works Agency, Watershed Protectionis deemed to beLess Than Significant (LS).
The proposed Project is situated about 500 feet from Camarillo Hills Drain, which is a WP jurisdictional redline channel. No direct connections to this WP channel or activities within WP’s easement appear to be proposed or indicated on the applicant’s submitted materials.
This proposed project would result in an increase of impervious area within the subject property. It is understood that impacts from the proposed increase in impervious area and stormwater drainage design within the project site will be required to be mitigated to less than significant under the conditions imposed by the City of Camarillo. The mitigation requires that runoff from the proposed project site be released at no greater than the existing flow rate and in such manner as to not cause an adverse impact downstream in peak discharge, velocity, or duration.
WP staff determines that the proposed project design with the conditions mentioned above mitigates the direct and indirect project-specific and cumulative impacts to flood control facilities and watercourses. Therefore, the environmental impact is lessthan significant (LS) on redline channels under the jurisdiction of the Ventura County Public Works Agency - Watershed Protection.
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2 WATERSHED PROTECTION COMMENTS:
None
WATERSHED PROTECTION CONDITIONS:
None
Sonnette S. Aquino
Supervising, Support Specialist
Watershed Planning & Permits Division
800 S. Victoria Ave. / #1610
Ventura, CA 93009
P: 805.650-4060
VCPWA Online|Facebook|Twitter
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Memorandum from the Ventura County Public Works Agency (VCPWA), Watershed Planning & Permits Division (no date) Comment VCPWA-1 APPLICATION COMPLETENESS: COMPLETE – for our area of concern ENVIRONMENTAL IMPACT ANALYSIS: Item 31a. Flood Control Facilities/Watercourses – Flood Control Facilities / Watercourses – Ventura County Public Works Agency, Watershed Protection is deemed to be Less Than Significant (LS). The proposed Project is situated about 500 feet from Camarillo Hills Drain, which is a WP jurisdictional redline channel. No direct connections to this WP channel or activities within WP’s easement appear to be proposed or indicated on the applicant’s submitted materials. This proposed project would result in an increase of impervious area within the subject property. It is understood that impacts from the proposed increase in impervious area and stormwater drainage design within the project site will be required to be mitigated to less than significant under the conditions imposed by the City of Camarillo. The mitigation requires that runoff from the proposed project site be released at no greater than the existing flow rate and in such manner as to not cause an adverse impact downstream in peak discharge, velocity, or duration. WP staff determines that the proposed project design with the conditions mentioned above mitigates the direct and indirect project-specific and cumulative impacts to flood control facilities and watercourses. Therefore, the environmental impact is less than significant (LS) on redline channels under the jurisdiction of the Ventura County Public Works Agency - Watershed Protection. WATERSHED PROTECTION COMMENTS: None WATERSHED PROTECTION CONDITIONS: None Response to Comment VCPWA-1 This comment provides the determination of the VCPWA that the environmental impact of the project would be less than significant on redline channels under the jurisdiction of the Ventura County Public Works Agency - Watershed Protection. This determination is consistent with the content and conclusions of the Final Second Subsequent MND 2023-4. No further response is required.
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CC G:\Admin\TECH SERVICES\FINALED Letters\Land Use\SR0021485 City of Camarillo CPD-226M(5) and CUP-422 Costco Wholesale - VC EHD memo - 11 15 2023 Page 1
November 15, 2023
City of Camarillo
Department of Community Development
601 Carmen Drive
Camarillo, CA 93010
ATTN: Jaclyn Lee, Planning Manager
Costco Wholesale, Environmental Document Review – Notice of Intent to Adopt a Mitigated Negative Declaration, (RMA REF #23-022)
Ventura County Environmental Health Division (Division) staff reviewed the information submitted for the subject project.
Proposed project includes:
• A 163,397-square foot retail warehouse with bulk grocery food sales, pharmacy, indoor food court, photo center, and an automotive tire shop; • Free-standing fuel facility.
The Division provided the following comments:
1. The proposed project includes the construction of a retail food facility with an indoor food court. Food facilities are subject to plan review and permitting by this Division. The applicant/ food facility operator must submit plans to the Ventura County Environmental Health Division, Community Services Section and obtain plan approval prior to beginning any construction or operation of the retail food facilities.
https://vcrma.org/en/consumer-food-protection
2. The proposed project includes the construction of a free-standing fuel station that will handle, store, or transport hazardous materials and may generate hazardous waste. Hazardous materials and/or hazardous waste at or above the reportable threshold must be reported to this Division’s Certified Unified Program Agency (CUPA). Contact CUPA for reporting and/or permitting requirements.
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CC G:\Admin\TECH SERVICES\FINALED Letters\Land Use\SR0021485 City of Camarillo CPD-226M(5) and CUP-422 Costco Wholesale - VC EHD memo - 11 15 2023 Page 2
https://vcrma.org/en/cupa
3. The proposed project included the construction of a free-standing fuel station with Underground Storage Tanks (UST). The Permittee shall obtain approval from the Ventura County Environmental Health Division/CUPA for UST installation, removal, modification, or repair. Businesses operating USTs must apply annually for a UST operating permit; annual submittal into the California Environmental Reporting System (CERS) satisfies the requirement to submit a UST permit application.
https://vcrma.org/underground-storage-tank-program.
4. The proposed project includes a pharmacy and optical center. All medical waste generators are required to register with Ventura County Environmental Health Division (EHD). Medical waste includes bio-hazardous waste, pathology waste, chemotherapy waste, sharps waste, or pharmaceutical waste. https://vcrma.org/en/medical-waste-program
If you have any questions, please contact me at (805) 654-2830 or [email protected].
Roxy Cabral, R.E.H.S.
Land Use Section
Environmental Health Division
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Memorandum from the County of Ventura, Resource Management Agency, Environmental Health Division (VCEHD) dated November 15, 2023 Comment VCEHD-1 Ventura County Environmental Health Division (Division) staff reviewed the information submitted for the subject project. Proposed project includes: A 163,397-square foot retail warehouse with bulk grocery food sales, pharmacy, indoor food court, photo center, and an automotive tire shop; Free-standing fuel facility. The Division provided the following comments: 1. The proposed project includes the construction of a retail food facility with an indoor food court. Food facilities are subject to plan review and permitting by this Division. The applicant/ food facility operator must submit plans to the Ventura County Environmental Health Division, Community Services Section and obtain plan approval prior to beginning any construction or operation of the retail food facilities. https://vcrma.org/en/consumer-food-protection 2. The proposed project includes the construction of a free-standing fuel station that will handle, store, or transport hazardous materials and may generate hazardous waste. Hazardous materials and/or hazardous waste at or above the reportable threshold must be reported to this Division’s Certified Unified Program Agency (CUPA). Contact CUPA for reporting and/or permitting requirements. https://vcrma.org/en/cupa 3. The proposed project included the construction of a free-standing fuel station with Underground Storage Tanks (UST). The Permittee shall obtain approval from the Ventura County Environmental Health Division/CUPA for UST installation, removal, modification, or repair. Businesses operating USTs must apply annually for a UST operating permit; annual submittal into the California Environmental Reporting System (CERS) satisfies the requirement to submit a UST permit application. https://vcrma.org/underground-storage-tank-program. 4. The proposed project includes a pharmacy and optical center. All medical waste generators are required to register with Ventura County Environmental Health Division (EHD). Medical waste includes bio-hazardous waste, pathology waste, chemotherapy waste, sharps waste, or pharmaceutical waste. https://vcrma.org/en/medical-waste-program Response to Comment VCEHD-1 This memorandum accurately describes the Costco development, except that it does not include a photo center. This memorandum also identifies several permits that would be required from the VCEHD for operation of the Costco project. These permits are required under applicable regulations and are not mitigation for potentially significant impacts of the Costco project. The requirement to obtain these permits Responses to Late Comments
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does not change the evaluation of project impacts in the Final Second Subsequent MND. The requirement to obtain these permits has been incorporated as Conditions of Approval for the project.
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VENTURA COUNTY
AIR POLLUTION CONTROL DISTRICT
Memorandum
TO: Jaclyn Lee, City of Camarillo DATE: December 4, 2023
FROM: Nicole Collazo, Air Quality Specialist, VCAPCD Planning Division
SUBJECT: Notice of Intent to Adopt Second Subsequent Mitigated Negative Declaration for the Camarillo Costco Wholesale Project (RMA 23-022)
Ventura County Air Pollution Control District (APCD) staff has reviewed the subject Second Subsequent Mitigated Negative Declaration (SSMND) for the project referenced above, which analyzed the environmental impacts of a project to request a major modification to Commercial Planned Development Permit (CPD-226M(5)) to modify the previously approved development plans and develop approximately 20 acres into a 163,177-square-foot retail warehouse and 32- pump freestanding fuel facility located between U.S. 101 and Ventura Boulevard, west of Camarillo Town Center West (Home Depot) and east of Springville Drive in the Commercial Planned Development (CPD) Zone (APN: 230- 0-020-250). The Lead Agency is the City of Camarillo.
APCD has the following comments regarding the project’s SSMND.
Item 1- The SSMND states on Page 11 that the “stacking” area for the vehicle queuing at the proposed gas station would allow for up to 42 vehicles to queue. However, the SSMND’s Figure 9 states this stacking area would allow up to 33 vehicles. Please clarify this discrepancy. Also, it is not clear which value was used to quantify the project’s operational mobile emissions.
Item 2- Page 14. The proposed total amount of EV parking stalls is approximately 20%, 46 stalls equipped with EV infrastructure at first operation and 135 for future use. The 135 future-EV-use stalls should have an implementation plan of when they will be phased in with concrete timelines.
No additional information was located on this phased in approach.
Item 3- Please modify Mitigation Measure AQ-2 to include a requirement that all off-road construction diesel equipment shall be rated at a minimum of Tier 3 and include Tier 4. MM AQ- 2 as-is is difficult to quantify the emission reduction from proposed mitigation, however, equipping all off-road construction diesel equipment to Tier 3 can reduce NOx emissions by up to 85% and can be quantified in the air emissions model CalEEMod.
Item 4- Table B-6 in Appendix B has a maximum operational mobile emission for Phase 1 of 23 lbs./day ROC and 23.8 lbs./day of NOx (PDF Page 146 of 169). However, Table 2 in the SSMND on Page 34 has a maximum mobile operational emission concentration of 25.4 lbs./day ROC and
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26.5 lbs./day NOx. Please clarify this discrepancy. Note- the emissions for Phase 2, regional shopping center, match in both Table B-6 and Table 2.
Item 5- Please modify MM AQ-1 to include a requirement to post the APCD 24-Hr Complaint Hotline number in a sign visible to the public on each construction perimeter fence to ensure construction operations are in compliance with APCD Rule, 51, Nuisance, for odors, dust, etc. The 24-hr complaint hotline phone number is 805-303-3700.
Item 6- It appears the CalEEMod air emissions model included area source emissions for estimated use of landscape equipment during its operational phase. As part of MM AQ-3, landscape equipment should be electrically powered, thus should not have been included in the modeling.
The SSMND states that operational air quality impacts would be reduced to Less than Significant Levels only with implementation of MM AQ-3 and AQ-4 (SSMND, Page 31).
Item 7- APCD recommends all feasible on-site mitigation be proposed prior to contributing to an off-site mitigation fund program (Air Quality Assessment Guidelines, AQAG, Page 7-15). Please consider additional on-site mitigation, with an emphasis on reducing proposed mobile emissions, such as:
• an employee rideshare incentive program,
• shuttles/vanpool service to transit/multi-modal center, • employee bicycle racks and lockers ,
• compressed work schedules,
• hiring locally,
• lunch/shopping shuttle service,
• on-site lunches,
• incentivizing employee electric/hybrid vehicle ownership, • reducing number of fuel pumps or staging area capacity, • phasing out diesel delivery trucks to ZE or NZE heavy duty trucks, • increasing proposed EV parking stall beyond what is already being proposed (20%), • and other measures contained in Table 7-2 of the AQAG
Other non-mobile mitigation measures can include adding solar panels to power the building and ultra-low to zero-VOC paints for building maintenance. Note- since most project emissions are generated from mobile sources, reducing emissions from energy or area emissions may be negligible and not enough to bring emissions down to Less than Significant levels.
As a reminder, the below list are the criteria for off-site mitigation fund programs outlined in our AQAG.
1. The lead agency should determine the basis for collection and how the funds are to be spent.
The funds should be spent or committed to a mitigation project within five years of receipt of the funds.
2. Funds should be used for mitigation projects or programs in areas that are either directly or indirectly impacted by the development project and are within Ventura County. Ridesharing Responses to Late Comments
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arrangements or public transit services that originate outside the area but serve the area directly or indirectly impacted by the development project are also eligible uses of the funds.
3. The lead agency should establish an off-site TDM fund to receive and hold the funds until the funds are spent on an approved mitigation project or program.
4. Funds should not be used for traffic engineering projects, including signal synchronization, intersection improvements, and channelization, as these projects are related to improving traffic congestion and not air quality.
5. Any on-site or off-site TDM facilities provided by a development project to mitigate its emissions before determining the funding should not be credited toward the funds paid by the development project as a mitigation measure. Doing so would be taking credit for the mitigation twice.
6. A development project that is to be developed in phases should calculate the pro-rata share of funding from each phase of development based on emissions for the year of complete buildout. Such pro-rata share of funding should be paid in one lump sum or spread out evenly over three years in order to minimize the initial cost and provide a stable funding source.
7. The lead agency should report annually to its respective governing board on collection, expenditure, and use of collected funds.
8. The calculation and use of funding to a mobile source emission reduction fund must be in accordance with all applicable statutory requirements.
Thank you for the opportunity to comment on the project’s SSMND. If you have any questions, you may contact me at [email protected].
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Memorandum from the Ventura County Air Pollution Control District (APCD) dated December 4, 2023 Comment APCD-1 Ventura County Air Pollution Control District (APCD) staff has reviewed the subject Second Subsequent Mitigated Negative Declaration (SSMND) for the project referenced above, which analyzed the environmental impacts of a project to request a major modification to Commercial Planned Development Permit (CPD-226M(5)) to modify the previously approved development plans and develop approximately 20 acres into a 163,177-square-foot retail warehouse and 32- pump freestanding fuel facility located between U.S. 101 and Ventura Boulevard, west of Camarillo Town Center West (Home Depot) and east of Springville Drive in the Commercial Planned Development (CPD) Zone (APN: 230- 0-020-250). The Lead Agency is the City of Camarillo. APCD has the following comments regarding the project’s SSMND. Item 1- The SSMND states on Page 11 that the “stacking” area for the vehicle queuing at the proposed gas station would allow for up to 42 vehicles to queue. However, the SSMND’s Figure 9 states this stacking area would allow up to 33 vehicles. Please clarify this discrepancy. Also, it is not clear which value was used to quantify the project’s operational mobile emissions. Response to Comment APCD-1 The value for the design basis of the “stacking” area is 28 vehicles for a peak queue length. This was the average peak queue observed during traffic count studies conducted at other existing Costco fuel facilities in California with 30-32 fueling positions. Up to 31 vehicles could stack within the gas station area as designed. Additionally, during atypical surges in demand, such as pre-holiday weekends, an additional 27 vehicles could queue outside the gas station through the implementation of a preestablished queue management plan that the gas station attendant is trained to implement. This would provide storage for a total of 58 vehicles (substantially more than the expected 28 vehicles during typical peak hours) without impeding circulation through the site or shared access driveway. The noted discrepancy in vehicle stacking capacity does not affect the analysis or conclusions of the Second Subsequent MND related to criteria air pollutant emissions. The Costco development’s criteria air pollutant emissions inventory is based upon the average Saturday queueing value as provided by Kittelson & Associates, Inc, the traffic engineers for the Costco project. The Saturday daily queueing value was used to determine the operational idling emissions since the emissions inventory is a daily value for criteria air pollutant emissions and an annual value for greenhouse gas emissions. The average Saturday daily queue length is 10 vehicles, which is a conservative value since the average weekday daily queue would be less. Comment APCD-2 Item 2- Page 14. The proposed total amount of EV parking stalls is approximately 20%, 46 stalls equipped with EV infrastructure at first operation and 135 for future use. The 135 future-EV-use stalls should have an implementation plan of when they will be phased in with concrete timelines. No additional information was located on this phased in approach.
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Response to Comment APCD-2 The Costco development will comply with applicable 2022 California Green Building Standards (CalGreen) Code requirements regarding EV parking and will provide all required charging infrastructure. However, the 2022 CalGreen Code 2022 does not require Costco to commit to a phasing in future EV infrastructure. The City has been informed that Costco is closely monitoring the market as new technologies take hold (e.g., battery electric vehicles, hydrogen fuel cell vehicles and plug-in hybrids) to provide its members with the infrastructure necessary to utilize their preferred transportation methods and consistent with how the EV mode of transportation develops. The City has been informed that Costco is committed to meeting the needs of its members and plans to phase in the electric vehicle infrastructure at the Camarillo site based on the members demand for electric vehicle chargers, as well as the availability of sufficient electricity capacity. Restricting the use of future EV parking spaces from use by non-EVs before there is sufficient demand for the chargers could lead to a situation where there is not enough parking at the project site, and drivers may need to drive around the site or the adjacent property looking for a place to park. This would increase the amount of emissions generated by people driving to the site. Comment APCD-3 Item 3- Please modify Mitigation Measure AQ-2 to include a requirement that all off-road construction diesel equipment shall be rated at a minimum of Tier 3 and include Tier 4. MM AQ-2 as-is is difficult to quantify the emission reduction from proposed mitigation, however, equipping all off-road construction diesel equipment to Tier 3 can reduce NOx emissions by up to 85% and can be quantified in the air emissions model CalEEMod. Response to Comment APCD-3 While the requested modification to mitigation measure AQ-2 is not required as the project’s construction-related air quality impacts would be less than significant, the applicant for the Costco development has informed the City that the following project design feature will be implemented to provide additional emissions reductions: PDF AQ-1: Construction equipment greater than 50 hp used at the site shall meet USEPA Tier 4 Final emission standards for PM10 and PM2.5. If Tier 4 Final equipment is viable but not commercially available, all construction equipment larger than 50 horsepower used at the site shall meet U.S. EPA emission standards for Tier 3 engines and include particulate matter emissions control equivalent to CARB Level 3 verifiable diesel emission control devices, other than the scrapers used during grading, which shall meet a minimum of U.S. EPA emission standards for Tier 4 Interim engines. This project design feature has been quantified in the following table and has been determined to result in a 33% reduction in maximum daily construction NOx emissions in 2024.
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Maximum Daily Air Pollutant Emissions for Project Construction Development Phase Year Emissions in Pounds Per Day without PDF AQ-1 Emissions in Pounds Per Day with PDF AQ-1 ROC NOx ROC NOx Costco 2024 47.8 36.1 47.8 24.1 Source of table data: Ramboll, January 24, 2024. Comment APCD-4 Item 4- Table B-6 in Appendix B has a maximum operational mobile emission for Phase 1 of 23 lbs./day ROC and 23.8 lbs./day of NOx (PDF Page 146 of 169). However, Table 2 in the SSMND on Page 34 has a maximum mobile operational emission concentration of 25.4 lbs./day ROC and 26.5 lbs./day NOx. Please clarify this discrepancy. Note- the emissions for Phase 2, regional shopping center, match in both Table B-6 and Table 2. Response to Comment APCD-4 The data as reported in the Second Subsequent MND is accurate as currently shown, as the values cited in the comment are not meant to be the same values. Table 2 of the Second Subsequent MND is an overall summary of the project operational emissions, while Table B-6 in Appendix B is a subset of those emissions. The emissions presented in Table 2 for Phase 1 (Costco) include emissions from transport refrigeration units (TRUs) (the daily TRU emissions are the same as those presented within Table 1 in Appendix B of the Second Subsequent MND). The 25.4 pounds per day of reactive organic compounds (ROC) shown in Table 2 is calculated as the sum of the mobile emissions from Table B-6 (23.03 pounds per day of ROC) and the TRU emissions from Table 1 (2.34 pounds per day of ROC). Similarly, the 26.2 pounds per day of nitrogen oxides (NOx) shown in Table 2 is calculated as the sum of the mobile emissions from Table B-6 (23.77 pounds per day of NOx) and the TRU emissions from Table 1 (2.39 pounds per day of NOx). Comment APCD-5 Item 5- Please modify MM AQ-1 to include a requirement to post the APCD 24-Hr Complaint Hotline number in a sign visible to the public on each construction perimeter fence to ensure construction operations are in compliance with APCD Rule, 51, Nuisance, for odors, dust, etc. The 24-hr complaint hotline phone number is 805-303-3700. Response to Comment APCD-5 While the requested modification to mitigation measure AQ-1 is not required as the project’s construction-related air quality impacts would be less than significant, the project applicant has informed the City that the requested language will be added as a project design feature: PDF AQ-2: The applicant or its contractor shall post the APCD 24-Hr Complaint Hotline number in a sign visible to the public on each construction perimeter fence to ensure construction operations are in compliance with APCD Rule 51, Nuisance, for odors, dust, etc. The 24-hr complaint hotline phone number is 805-303-3700.
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Comment APCD-6 Item 6- It appears the CalEEMod air emissions model included area source emissions for estimated use of landscape equipment during its operational phase. As part of MM AQ-3, landscape equipment should be electrically powered, thus should not have been included in the modeling. The SSMND states that operational air quality impacts would be reduced to Less than Significant Levels only with implementation of MM AQ-3 and AQ-4 (SSMND, Page 31). Response to Comment APCD-6 The language in mitigation measure AQ-3 provides flexibility as to what landscaping equipment may be used and states that the project developer shall “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).” In response to this comment, the second bullet of mitigation measure AQ-3 has been amended as follows: • 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). The project’s commitment to the use of zero-emission landscaping equipment would reduce the area source emissions by 3.58 pounds per day of VOC and 0.18 pounds per day of NOx. Comment APCD-7 Item 7- APCD recommends all feasible on-site mitigation be proposed prior to contributing to an off-site mitigation fund program (Air Quality Assessment Guidelines, AQAG, Page 7-15). Please consider additional on-site mitigation, with an emphasis on reducing proposed mobile emissions, such as: an employee rideshare incentive program, shuttles/vanpool service to transit/multi-modal center, employee bicycle racks and lockers, compressed work schedules, hiring locally, lunch/shopping shuttle service, on-site lunches, incentivizing employee electric/hybrid vehicle ownership, reducing number of fuel pumps or staging area capacity, phasing out diesel delivery trucks to ZE or NZE heavy duty trucks, increasing proposed EV parking stall beyond what is already being proposed (20%), and other measures contained in Table 7-2 of the AQAG. Other non-mobile mitigation measures can include adding solar panels to power the building and ultra-low to zero-VOC paints for building maintenance. Note- since most project emissions are generated from mobile sources, reducing emissions from energy or area emissions may be negligible and not enough to bring emissions down to Less than Significant levels.
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Response to Comment APCD-7 In response to this comment, the City of Camarillo Planning Commission added substantially all of item 7 as a condition of approval. The two exceptions were compressed work schedules and reducing the number of fuel pumps or staging area capacity. Costco informed the Planning Commission that compressed work schedules are not feasible based on Costco's work schedules, which require employees to be onsite to perform their work. Costco also informed the Planning Commission that its traffic engineer has conducted surveys at other Costco fuel facilities across the country and that reducing the number of fuel pumps or staging area capacity does not reduce the demand for fuel by its members. Instead, reducing the number of pumps leads to longer queue lines. This would increase the amount of emissions generated by customer vehicles waiting in line for fuel or driving to other locations for fuel after shopping at Costco. In addition, in compliance with Section 110.10 of Title 24, which includes mandatory requirements for solar-ready buildings, the Costco building has been designed to accommodate future solar panel installation, and, as such, would allow future implementation of an on-site renewable energy source. In the meantime, Costco has informed the City that it will enter into a Retail Power Purchase Agreement directly with a clean energy retailer to provide 100 percent clean power so that all electricity supplied to the Costco development will be from renewable sources. Comment APCD-8 As a reminder, the below list are the criteria for off-site mitigation fund programs outlined in our AQAG. 1. The lead agency should determine the basis for collection and how the funds are to be spent. The funds should be spent or committed to a mitigation project within five years of receipt of the funds. 2. Funds should be used for mitigation projects or programs in areas that are either directly or indirectly impacted by the development project and are within Ventura County. Ridesharing arrangements or public transit services that originate outside the area but serve the area directly or indirectly impacted by the development project are also eligible uses of the funds. 3. The lead agency should establish an off-site TDM fund to receive and hold the funds until the funds are spent on an approved mitigation project or program. 4. Funds should not be used for traffic engineering projects, including signal synchronization, intersection improvements, and channelization, as these projects are related to improving traffic congestion and not air quality. 5. Any on-site or off-site TDM facilities provided by a development project to mitigate its emissions before determining the funding should not be credited toward the funds paid by the development project as a mitigation measure. Doing so would be taking credit for the mitigation twice. 6. A development project that is to be developed in phases should calculate the pro-rata share of funding from each phase of development based on emissions for the year of complete buildout. Such pro-rata share of funding should be paid in one lump sum or spread out evenly over three years in order to minimize the initial cost and provide a stable funding source. 7. The lead agency should report annually to its respective governing board on collection, expenditure, and use of collected funds.
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8. The calculation and use of funding to a mobile source emission reduction fund must be in accordance with all applicable statutory requirements. Response to Comment APCD-8 The City of Camarillo is aware of the criteria for implementation and use of off-site TDM funds and has been implementing its program for more than 20 years to help reduce emissions throughout the community.
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Letter from Lozeau Drury LLP on behalf of Supporters Alliance for Environmental Responsibility (SAFER) dated November 30, 2023 Comment SAFER-1 The 2023 SMND Fails to Establish that Emissions of ROCs and NOx will be Less Than Significant. The City and the Ventura County Air Pollution Control District (“VCAPCD”) have established a 25 pounds/day (“lbs/day”) significance threshold for emissions of reactive organic compounds (“ROCs”) and nitrogen oxides (“NOx”). The 2023 SMND admits that the construction and operational phases of the Project will exceed the 25 lb/day threshold for ROCs and NOx. (SMND pp. 33-34.) The 2023 SMND then applies three mitigation measures (AQ-2, AQ-3, and AQ-4) to reduce these impacts. However, the 2023 SMND does not conclude or otherwise present evidence that the mitigation measures will actually reduce the emissions to a less-than-significant level. For construction-related emissions, the 2023 SMND claims, As discussed previously, the Ventura County Air Quality Assessment Guidelines do not require that mitigation bring construction emissions to below 25 pounds per day - only that mitigation reduce construction emissions to the extent feasible. If all appropriate emissions control measures recommended by the Ventura County Air Quality Assessment Guidelines are implemented for a project, then construction emissions are not considered significant. (2023 SMND, p. 33.) However, that is not what VCAPCD's guidelines or the City's guidelines say. VCAPCD's guidelines explicitly state that "[i]t is possible that project emissions will still be significant after inclusion of al feasible mitigation measures" and that "there are very few feasible measures available to reduce [ROC and NOx] emissions." (VCAPCD Guidelines §§ 7.2, 7.4.3). Furthermore, under the City's CEQA guidelines, there is a potentially significant impact where ROC or NOx emissions exceed 25 lbs/day regardless of whether mitigation has been applied. If ROC and NOx impacts have been mitigated to the extent feasible yet still remain significant, the proper CEQA document is a SEIR-not a SMND. Response to Comment SAFER-1 Per the 2003 Ventura County Air Quality Assessment Guidelines and conversations with Ventura County APCD staff, the significance thresholds in the guidance (25 pounds per day of ROC and/or NOx) are intended for operational emissions. For construction, the 25 pounds per day level is not a significance threshold, but the APCD’s recommendation is to incorporate mitigation measures when a project would generate construction-related emissions that exceed 25 pounds per day of ROC and/or NOx emissions. Specifically, Section 5.2 of the Ventura County Air Quality Assessment Guidelines states the following: Construction-related emissions (including portable engines and portable engine-driven equipment subject to the ARB’s Statewide Portable Equipment Registration Program, and used for construction operations or repair and maintenance activities) of ROC and NOx are not counted (emphasis added) towards the two significance thresholds, since these emissions are temporary. However, construction-related emissions should be mitigated if estimates of ROC and NOx emissions from the heavy-duty construction equipment anticipated to be used for a particular project exceed the 5 pounds per day threshold in the Ojai Planning Area, or the 25 pounds per day threshold in the remainder of the county.
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Section 7.4 of the Ventura County Air Quality Assessment Guidelines also states the following: As discussed in Section 5.2, “Calculating Ozone Precursor Emissions from Project Construction,” construction-related ROC and NOx emissions are not counted (emphasis added) toward the ROC and NOx significance thresholds, since these emissions are only temporary. The Second Subsequent MND has based the evaluation of the project’s construction-related air quality impacts on this direction for the APCD. Because the Second Subsequent MND includes mitigation measure AQ-2 for the specific purpose of reducing the emissions of pollutants generated by heavy-duty diesel-powered equipment operating at the project site throughout the project construction phases, it correctly concludes that the potential impact of the project would be less than significant. The APCD reviewed the Draft Second Subsequent MND and submitted comments after the end of the Draft Second Subsequent MND public review period. It is important to note that the APCD did not dispute the conclusion regarding the less than significant impact associated with project construction. The APCD only asked for a revision to mitigation measure AQ-2 to include a requirement that all off-road construction diesel equipment shall be rated at a minimum of Tier 3 and include Tier 4. While the requested modification to mitigation measure AQ-2 is not required as the project’s construction-related air quality impacts would be less than significant, the applicant for the Costco development has informed the City that the following project design feature will be implemented to provide additional emissions reductions: PDF AQ-1: Construction equipment greater than 50 hp used at the site shall meet USEPA Tier 4 Final emission standards for PM10 and PM2.5. If Tier 4 Final equipment is viable but not commercially available, all construction equipment larger than 50 horsepower used at the site shall meet U.S. EPA emission standards for Tier 3 engines and include particulate matter emissions control equivalent to CARB Level 3 verifiable diesel emission control devices, other than the scrapers used during grading, which shall meet a minimum of U.S. EPA emission standards for Tier 4 Interim engines. This project design feature has been quantified in the following table and has been determined to result in a 33% reduction in maximum daily construction NOx emissions in 2024. Maximum Daily Air Pollutant Emissions for Project Construction Development Phase Year Emissions in Pounds Per Day without PDF AQ-1 Emissions in Pounds Per Day with PDF AQ-1 ROC NOx ROC NOx Costco 2024 47.8 36.1 47.8 24.1 Source of table data: Ramboll, January 24, 2024. Comment SAFER-2 For operation emissions, the SMND claims that AQ-4 (which requires payments to a transportation demand management (“TDM”) fund) would reduce the Project’s cumulative impacts to a less-than-significant level. However, this again ignores VCAPCD’s guidelines and the City’s guidelines. Although Responses to Late Comments
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the VCAPCD guidelines acknowledge that TDM funding may “lessen[] or reduce[]” impacts of ROCs and NOx, VCAPCD guidelines also explicitly state, In most cases, the emissions from a development project will still exceed the … 25 pounds per day threshold in the remainder of the county … Therefore, each lead agency should determine if overriding considerations are necessary to approve the development project due to these emissions. (VCAPCD Guidelines 7.5.3.) Response to Comment SAFER-2 As discussed on page 19 of the City of Camarillo CEQA Environmental Guidelines: The Ventura County Air Quality Assessment Guidelines provides direction on how to evaluate potential air quality impacts, how to determine whether these impacts are significant, and how to mitigate these impacts (emphasis added). The City of Camarillo relies upon the expertise of the VCAPCD and utilizes the Ventura County Air Quality Assessment Guidelines as the guidance document for the environmental review of plans and development proposals within its jurisdiction. This comment provides one short quote from Section 7.5.3 of the Ventura County Air Quality Assessment Guidelines appears to support the commenter’s argument, but it does not include the information from the same paragraph in this section that supports the analysis and conclusions of the Second Subsequent MND. Specifically, this paragraph begins with the sentence stating that “Funding of this kind is considered to have lessened or reduced the significant environmental impact of the subject development project (see Section 7.2, “CEQA Requirements for Mitigation Measures”).” In addition to this statement from Section 7.5.3 of the Ventura County Air Quality Assessment Guidelines, APCD staff were also consulted and confirmed that a contribution to an off-site Transportation Demand Management (TDM) fund is an appropriate means of mitigation for ROC and/or NOx operational emissions that exceed 25 pounds per day. This is appropriate after feasible on-site mitigation for operational sources has been applied. The City of Camarillo has considered all feasible on-site mitigation for the project. Through the TDM fund contribution (which is estimated based on the level of emissions above 25 pounds per day), the project’s impact is able to be considered to be less than significant. Comment SAFER-3 Again, the standard for a SMND is not whether impacts have been reduced to the extent feasible, but rather whether the impacts have been rendered less than significant. Although AQ-2, AQ-3, and AQ-4 certainly reduce the Project's impacts, there is no evidence that the Project's emissions of ROCs and NOx will be reduced to less than 25 Ibs/day as required by VCAPCD's guidelines and the City's guidelines. Therefore, the Project may result in significant air quality impacts and an SEIR must be prepared prior to further consideration of the Project. Response to Comment SAFER-3 As discussed in the Response to Comment SAFER-1, the Response to Comment SAFER-2, and the Response to Comment SAFER-3, the construction-related and operational air quality impacts of the proposed project Responses to Late Comments
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will be mitigated to less than significant levels through the implementation of mitigation measures AQ-1 through AQ-4 based on the information presented in the Ventura County Air Quality Assessment Guidelines. Therefore, the Second Subsequent MND is an appropriate document to evaluate the potential environmental impacts of the project. Comment SAFER-4 The 2023 SMND Fails to Establish that the Project’s Energy Impacts Will be Less Than Significant. CEQA provides that all Projects must include measures "to reduce the wasteful, inefficient, and unnecessary consumption of energy." (Pub. Res. Code§ 21100(b)(3).) Energy conservation under CEQA is defined as the "wise and efficient use of energy." (CEQA Guidelines, app. F, § I.) The "wise and efficient use of energy" is achieved by "(l) decreasing overall per capita energy consumption, (2) decreasing reliance on fossil fuels such as coal, natural gas and oil, and (3) increasing reliance on renewable energy resources." (Id.) Mere compliance with the California Building Energy Efficiency Standards (Cal. Code Regs., tit. 24, part 6) ("Title 24") does not constitute an adequate analysis of energy. (League to Save Lake Tahoe Mountain Area Preservation Foundation v. County of Placer (2022) 75 Cal.App.5th 63, 165 (League to Save Lake Tahoe); Ukiah Citizens for Safety First v. City of Ukiah (2016) 248 Cal. App. 4th 256, 264-65; California Clean Energy Committee v. City of Woodland (2014) 225 Cal.App.4th 173, 209-13.) Even where an agency has concluded that a project's impacts on energy resources would be less than significant, a lead agency must still analyze implementation of all "renewable energy options that might have been available or appropriate for [a] project." (League to Save Lake Tahoe, supra, 75 Cal.App.5th at 166-67.) A lead agency's failure to consider implementation of all feasible renewable energy proposals raised during the environmental review process constitutes a "prejudicial error." (Id. at 168.) Despite CEQA's requirement to consider all renewable energy options, the 2023 SMND's analysis of alternative energy merely relies on compliance with Title 24. (SMND, pp. 56-57.) Because mere compliance with Title 24 is insufficient to determine that energy impacts are less than significant, the SMND's energy analysis is inadequate and its conclusion that the Project's energy impacts will be less than significant is unsupported. At a minimum, the City should consider the feasibility of solar PV panels for the Project's operational energy use. The 2023 SMND acknowledges that "the north-south orientation of the proposed Costco building and the flat roof would provide the optimum conditions for the use of passive and future active solar strategies." (2023 SMND, p. 101.) In order to comply with CEQA, feasible solar PV should be considered and required as a mandatory condition of approval for the Project. Response to Comment SAFER-4 In response to this comment, the attached Supplemental Energy Analysis has been prepared that amplifies, clarifies, and confirms the conclusion of the Second Subsequent MND that the project would not result in wasteful, inefficient, or unnecessary use of energy. This Supplemental Energy Analysis includes a quantification of the project’s energy use during construction and operation, and a discussion of renewable energy and energy conservation measures.
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With regard to electricity consumption, Costco will enter into a Retail Power Purchase Agreement directly with a clean energy retailer to provide 100 percent clean power, as defined by the U.S. Department of Energy (e.g., solar, wind, water, bioenergy/biomass, nuclear, and geothermal) to the Costco development. This will allow Costco to purchase clean electricity directly from specific certified clean power assets. This will provide the Costco development, which requires power 24 hours per day, seven days per week (e.g., for lighting and refrigeration), with a reliable source of clean power. The following project design feature is added to document Costco’s commitment that all electricity supplied to the Costco development will be from clean energy sources: PDF ENG-1: Costco will enter into a Retail Power Purchase Agreement directly with a clean energy retailer to provide 100 percent clean power, as defined by the U.S. Department of Energy, to the Costco development. With respect to other on-site renewable energy sources, because of the project’s location, there are no currently available renewable energy options to procure electricity, such as from the following sources: biodiesel, biomass hydroelectric and small hydro, digester gas, fuel cells, landfill gas, municipal solid waste, ocean thermal, ocean wave, and tidal current technologies, or multi-fuel facilities using renewable fuels. In addition, in compliance with Section 110.10 of Title 24, which includes mandatory requirements for solar-ready buildings, the Costco building has been designed to accommodate future solar panel installation, and, as such, would allow future implementation of an on-site renewable energy source. Comment SAFER-5 CONCLUSION Because the Project has remaining potentially significant impacts to air quality and energy, the 2023 SMND is improper under CEQA. Instead, SAFER respectfully requests that the City prepare and circulate a subsequent EIR prior to further consideration of the Project. Response to Comment SAFER-5 As discussed in the preceding responses, the air quality and energy impacts of the proposed project will continue to be less than significant. Therefore, the Second Subsequent MND is an appropriate document to evaluate the potential environmental impacts of the project.
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Letter from the Law Office of Darshann M. Wienick on behalf of Ventura County Citizens Against Mega Gas (VCCAMG) dated December 15, 2023 Comment VCCAMG-1 I am an attorney representing the unassociated group of Camarillo and Ventura County residents, neighbors, and merchants, collectively known as Ventura County Citizens Against Mega Gas ("VCCAMG"). I write to set forth bases for VCCAMG's appeal application (submitted concurrently herewith) challenging the City of Camarillo Planning Commission's decision to approve the Second Subsequent Mitigated Negative Declaration 2023-4 ("SSMND") for the proposed Costco project "Costco Project" to be located at the comer of Springville Drive and West Ventura Boulevard in the City of Camarillo. Please also see Exhibit A to this letter, which is the public comment letter submitted by VCCAMG on November 28, 2023, the contents of which are incorporated fully herein by reference. As you know, the original project was proposed nearly two decades ago and resulted in the Final Mitigated Negative Declaration ("FMND") adopted by the City of Camarillo Planning Commission and City Council in 2007. At the time, the proposed project was for a shopping center only-not a massive 32pump fuel station. It is simply not possible that the original FMND or even the Final Subsequent MND ("FSMND") approving the 2016 proposed shopping center project could have properly analyzed all the serious and significant impacts posed by the Costco Project. Response to Comment VCCAMG-1 Exhibit A is a copy of the letter from the VCCAMG dated November 28, 2023 that was thoroughly responded to in the Final Second Subsequent MND. No further response is necessary. Neither the 2007 Final MND nor the 2016 Final Subsequent MND analyzed the impacts of the Costco development, as it was not proposed at the time. Therefore, the City did not simply rely on the 2007 Final MND or 2016 Final Subsequent MND, but prepared a comprehensive Second Subsequent MND to analyze the potential impacts of changes to the approved Amara Shopping Center Project analyzed in the 2007 Final MND and 2016 Final Subsequent MND, specifically the Costco development, as well as changes in the circumstances under which the project will be undertaken. As set forth in the Second Subsequent MND, such changes would not result in any new significant impacts that would require the preparation of a subsequent Environmental Impact Report. Comment VCCAMG-2 Fugitive Dust/Excavation for Underground Storage Tanks ("USTs") The proponents of Costco Project have done their best to minimize the elephant in the room, namely the potential serious and significant environmental impacts posed by the proposed 32-pump fuel station. As Commissioner Limon pointed out during the December 5, 2023, Planning Commission meeting, no studies have been conducted to adequately inform the public of the environmental impacts associated with excavating and installing underground storage tanks, including the potential health and safety impacts of fugitive dust. Tellingly, proponents of the Costco Project do not even try to argue that these analyses have been performed and disseminated to the public, nor could they. The simple fact is that neither the 2007 FMND Responses to Late Comments
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nor the 2016 FSMND could have contemplated the massive-scale excavation that would be required to install USTs that could support a 32-pump fuel station. Perhaps new technology could minimize the environmental impacts to a point where they are not deemed significant under the California Environmental Quality Act (“CEQA”). However, that is not the point. A complete Environmental Impact Report must be prepared to analyze these potential significant impacts so that the members of the community are fully informed of the extent of these impacts. Indeed, this is the raison d’être of CEQA. Response to Comment VCCAMG-2 The Second Subsequent MND has fully evaluated the potential environmental impacts of project construction, including grading and excavation associated with the proposed 32-fueling position fuel facility. The Second Subsequent MND specifically evaluated the potential fugitive dust from the construction of the project. The project’s construction emissions include emissions from off-road equipment used during the site preparation and grading phases to move soil at the site which would generate fugitive dust. The fugitive dust emissions generated during construction can be found in the Appendix B – Air Quality Impact Evaluation of the Second Subsequent MND, within the CalEEMod® output presented in Appendix A for Phase 1 and Phase 2, denoted as “dust from material movement.” The Ventura County APCD has recommended fugitive dust control measures, and the project applicant has committed to the mitigation thoroughly detailed in mitigation measure AQ-1 in the Second Subsequent MND. This includes ten examples of measures which are currently required and recommended for achieving fugitive dust control. The project will also comply with APCD Rule 55 for Fugitive Dust. Comment VCCAMG-3 Energy Impacts Analysis pursuant to CEQA Guidelines Appendix F An EIR never has been prepared for any of the proposed projects at this site. Thus, it is not surprising that there has never been a study on the energy impacts that will result from the Costco Project. This is required by Appendix F to the CEQA Guidelines. See Ukiah Citizens for Safety First v. City of Ukiah, 248 Cal.App.4th 256 (2016); California Clean Energy Committee v. City of Woodland, 225 Cal.App.4th 173 (2014). In summary, to comply with the energy impacts analysis required in Appendix F of the CEQA guidelines, an EIR must consider potentially significant energy implications of a project, including energy use attributable to vehicle trips, operational and construction energy use, and renewable energy options. The EIR should also discuss mitigation measures to reduce wasteful, inefficient, and unnecessary consumption of energy. Both of the above-cited cases reviewed address the requirements of Appendix F of the CEQA guidelines. In Ukiah Citizens for Safety First v. City of Ukiah, the court discussed the importance of calculating energy use attributable to vehicle trips and operational and construction energy use. The court also noted that the CEQA guidelines require that "energy conservation measures, as well as other appropriate mitigation measures, shall be discussed when relevant" (p. 262). Thus, the court held that an EIR must include a discussion of mitigation measures to reduce wasteful, inefficient, and unnecessary consumption of energy. The California Clean Energy Committee v. City of Woodland case also is instructive. The court found that the City's EIR was inadequate for failing to assess or consider mitigation for transportation energy Responses to Late Comments
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impacts. The court emphasized that an EIR is "fatally defective" when it fails to include a detailed statement setting forth mitigation measures to reduce wasteful, inefficient, and unnecessary consumption of energy (p. 209). The court also noted that Appendix F requires consideration of "decreasing reliance on fossil fuels" and "increasing reliance on renewable energy sources" (p. 210). Response to Comment VCCAMG-3 Consistent with CEQA and the City of Camarillo CEQA Environmental Guidelines, the Second Subsequent MND assessed whether the project would result in the wasteful, inefficient, or unnecessary use of energy and concluded that impacts would be less than significant. Therefore, mitigation measures are not necessary. In response to this comment, the attached Supplemental Energy Analysis has been prepared that amplifies, clarifies, and confirms the conclusion of the Second Subsequent MND that the project would not result in wasteful, inefficient, or unnecessary use of energy. This Supplemental Energy Analysis includes a quantification of the project’s energy use during construction and operation and a discussion of renewable energy and energy conservation measures. The project also reduces potential vehicle fuel usage due to compliance with regulatory programs and its location that reduce vehicle miles traveled (VMT). As shown in Table 17 of the Second Subsequent MND, the Costco project and remaining shopping center would result in 4,591 fewer daily vehicle miles traveled than the previously approved Amara Shopping Center. This would provide a substantial reduction in transportation energy demands when compared to the approved Amara Shopping Center. Comment VCCAMG-4 Conclusion Simply put, the failure to conduct a comprehensive EIR tailored specifically to the Costco Project violates CEQA. Appellants respectfully request that the Planning Commission's decision on December 5, 2023, approving the Costco Project be set aside and that a new EIR be ordered in light of the foregoing. Response to Comment VCCAMG-4 As discussed in the preceding responses, the air quality and energy impacts of the proposed project will continue to be less than significant. Therefore, the Second Subsequent MND is an appropriate document to evaluate the potential environmental impacts of the project.
P:\C\Costco\Camarillo\Technical Work\Response to Comments\Final\2024.02.05 Ramboll Supplemental Energy Analysis.docx 1/6
Date: February 5, 2024
Ramboll
5 Park Plaza
Suite 500
Irvine, CA 92614
USA
T +1 949 261 5151
www.ramboll.com
MEMORANDUM
To: Jaclyn Lee
City of Camarillo
From: Eric Lu, Ramboll
Haley Ozcan, Ramboll
Copy: Diana P. Salazar, Costco Wholesale
Subject: Supplemental Energy Analysis for the modification to Commercial Planned Development permit (CPD-226) and Conditional Use Permit (CUP-422)
INTRODUCTION
The City of Camarillo (City) has prepared a Second Subsequent Mitigated Negative Declaration 2023-4 (SSMND) assessing the development of a vacant 44.84-acre site located within the Airport North Specific Plan area (Project Site ) with (a) 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 (Costco Development) on the eastern 20 acres of the Project Site, and (b) a future second phase that would include the remaining 335,823 square feet of building area of the originally approved 499,000 square feet of commercial space in the balance of the Project Site (collectively, the Project) The Planning Commission adopted the SSMND and granted land use approvals for the Costco Development on December 5, 2023. Bryan Flynn, on behalf of Supporters Alliance for Environmental Responsibility (SAFER), and Darshann Wienick, on behalf of Ventura County Citizens Against Mega Gas (VCCAMG), appealed the Commission’s action. Both appeals argue that the Project would result in wasteful, inefficient, or unnecessary use of energy.
This Supplemental Energy Analysis has been prepared in response to these arguments.
It amplifies, clarifies, and confirms the conclusion of the SSMND that the Project would not result in wasteful, inefficient, or unnecessary use of energy.
ANALYSIS
The Project would result in energy consumption during both construction and operation.
Ramboll calculated the Project’s construction and operational energy consumption from CalEEMod. The results are summarized in Tables 1 and 2 below.
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Table 1 - Construction Energy Resources Summary
Energy Resource Total Construction1 Maximum Annual Construction Gasoline (gallons) 36,108 20,631
Diesel (gallons) 110,022 45,650
Natural Gas (gallons) 1,027 622
Notes:
1Offroad and on-road emissions are calculated using methodology consistent with CalEEMod® version 2022.1. Off-road emission factors are from OFFROAD whereas on-road emission factors are from EMFAC2021.
Abbreviations:
CalEEMod® - CALifornia Emissions Estimator MODel
EMFAC - California Air Resources Board Emissions Factor Model
Table 2 – Operation Energy Resources Summary
Energy Resource Operation1
Electricity (kWh/yr) 6,611,010
Natural Gas (kBtu/yr) 3,080,265
Gasoline (gallons/yr) 1,065,679
Diesel (gallons/yr) 292,104
Notes:
1Project data are based on CalEEMod® output.
Abbreviations:
CalEEMod® - CALifornia Emissions Estimator MODel
EMFAC - EMission FACtors model
kWh - kilowatt hours
kBtu - kilo-British thermal unit
yr - year
A. Construction
1. Energy
During construction of the Project, it is anticipated that the limited amount of electricity used during construction (e.g., for temporary lighting and electric equipment) would be supplied by portable generators, and such use would cease upon completion of construction. When not in use, electric equipment would be powered off so as to avoid unnecessary energy consumption. As such, the Project’s
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demand for electricity during construction would not cause wasteful, inefficient, or unnecessary use of energy during construction.
2. Natural Gas
As shown on Table 1 above, the Project would consume a minimal amount of natural gas during construction (1,027 total gallons) as compared to annual operational demand, and such use would cease upon completion of construction. As such, the Project’s demand for natural gas during construction would not cause wasteful, inefficient, or unnecessary use of energy.
3. Transportation Energy
As shown in Table 1, on- and off-road vehicles would consume an estimated 36,108 gallons of gasoline and approximately 110,022 gallons of diesel fuel throughout the Project’s construction. Trucks and equipment used during proposed construction activities would comply with California Air Resources Board's (CARB) anti-idling regulations as well as the In-Use Off-Road Diesel-Fueled Fleets regulation. In addition to reducing criteria pollutant emissions, compliance with the anti-idling and emissions regulations would also result in efficient use of construction-related energy and reduce fuel consumption. In addition, on-road vehicles (e.g., haul trucks, worker vehicles) would be subject to federal and state fuel efficiency requirements. Therefore, Project construction activities would comply with existing energy standards with regard to transportation fuel consumption. As such, the Project’s demand for petroleum-based fuel during construction would not cause wasteful, inefficient, or unnecessary use of energy.
4. Construction Materials
This Supplemental Energy Analysis does not include a full life cycle analysis of energy usage that would occur over the production of materials used during the construction of the Project or used during the operational life of the Project, or the end of life for the materials and processes that would occur as an indirect result of the Project. Estimating the energy usage associated with these processes would be too speculative for meaningful consideration, would require analysis beyond the current state-of-the-art in impact assessment, and may lead to a false or misleading level of precision in reporting. Manufacture and transport of materials related to Project construction and operation is expected to be regulated under regulatory energy efficiency requirements.
Indirectly, construction energy efficiencies and energy conservation would be achieved through the use of bulk purchase, transport and use of construction materials. Use of materials in bulk reduces energy demands associated with preparation and transport of construction materials and the transport and disposal of construction waste and solid waste in general, with corollary reduced demands on area landfill capacities and energy consumed by waste transport and landfill operations.
Therefore, energy usage related to construction and operational materials would be consistent with current regulatory requirements regarding energy usage and would not cause wasteful, inefficient, or unnecessary use of energy.
B. Operation
1. Electricity
As shown in Table 2, with compliance with 2022 Title 24 standards and applicable CALGreen Code requirements, full buildout of the Project would result in a projected increase in the on-site demand for electricity totaling approximately 6,611,010 kWh per year. In addition to complying with CALGreen
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Code, the Costco Development would include the following sustainable design features that would reduce energy use:
• Parking lot light standards are designed to provide even light distribution and use 20% less energy compared to a greater number of fixtures at lower heights. The use of metal halide lamps provide a color corrected white light and a higher level of perceived brightness with less energy than other lamps such as high pressure sodium.
• Pre-manufactured building components, including structural framing and metal panels, are designed to minimize waste during construction. Pre-manufactured metal wall panels with insulation are designed to conserve energy by increasing R-value and solar reflectivity. Building heat absorption is reduced by a decrease in the thermal mass of the metal wall when compared to a typical masonry block wall.
• Building insulation will use ECOSE
® technology, which contains an average 61% recycled content. • Roof material will maintain a reflectance rating of.67, emittance of.85 and Solar Reflectance Index (SRI) of 81, lessening heat gain on the roof, meeting the requirements for the United States Environmental Protection Agency’s (USEPA) Energy Star energy efficiency program and lowering energy usage.
• The Project will use LED lighting technology to increase energy efficiency. • The Project will use energy and lighting management systems to control heating and cooling set points and set lighting schedules to minimize energy consumption. • Mechanical heat from refrigeration systems will be captured to pre-heat hot water tanks. • High efficiency restroom fixtures will reduce water consumption by 32 percent. • Tree plantings will reduce heat gain within the parking field. • Water monitoring systems will provide consumption monitoring and lower amount of energy necessary to run mechanical equipment and systems.
• Proposed planting will incorporate a substantial amount of drought tolerant species to reduce water consumption. The proposed irrigation system incorporates the use of deep root watering bubblers for parking lot shade trees to minimize water usage and ensure that water goes directly to the intended planting areas. The resulting reduction in water use will reduce energy consumption associated with the water distribution.
In addition, the Project would be subject to the 2022 Title 24 standards, which require greater efficiency than prior standards. As CalEEMod® is based on 2019 Title 24 standards, this analysis conservatively does not take into account additional energy usage reductions under 2022 Title 24. Future iterations of Title 24 are expected to increase energy efficiency requirements, and the Project would be required to comply with the latest Title 24 standards.
With respect to on-site renewable energy sources, because of the Project’s location, there are no local sources of energy from the following sources: biodiesel, biomass hydroelectric and small hydro, digester gas, fuel cells, landfill gas, municipal solid waste, ocean thermal, ocean wave, and tidal current technologies, or multi-fuel facilities using renewable fuels. In addition, in accordance with 2022 Title 24, the Project is designed to accommodate future solar panel installation, and, as such, would allow future implementation of an on-site renewable energy source.
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Moreover, Costco will enter into a Retail Power Purchase Agreement (PPA) directly with a clean energy retailer to provide 100 percent clean power, as defined by the US Department of Energy (e.g., solar, wind, water, bioenergy/biomass, nuclear, and geothermal) to the Costco Development. This will allow Costco to purchase clean electricity directly from specific certified clean power assets. This will provide the Costco Development, which requires power 24/7 (e.g., for lighting and refrigeration), with a reliable source of clean power. The use of clean energy would indirectly reduce use of fossil fuels required for electricity generation (natural gas, coal, oil).
Therefore, the Project’s demand for electricity during operation would not cause wasteful, inefficient, or unnecessary use of energy.
2. Natural Gas
As provided in Table 2, with compliance with 2022 Title 24 standards and applicable CALGreen Code requirements, at full buildout the Project would consume 3,080,265 kBTU/yr of natural gas per year during operation. As discussed above, in addition to complying with applicable regulatory requirements regarding energy conservation (e.g., California Building Energy Efficiency Standards and CALGreen Code), the Project would implement project design features to further reduce energy use. As also discussed above, the Project would be subject to the 2022 Title 24 standards. As CalEEMod ® is based on
2019 Title 24 requirements, this analysis conservatively does not take into account energy efficiency improvements under 2022 Title 24. In order to meet the 2022 Title 24 energy performance requirement, the Project will include use of efficient water heaters, cooking equipment and heating, ventilation, and air conditioning (HVAC) equipment. Therefore, the Project’s demand for natural gas during operation would not cause wasteful, inefficient, or unnecessary use of energy.
3. Transportation Energy
As provided in Table 2, the Project would result in the consumption of 1,065,679 gallons of gasoline and 292,104 gallons of diesel fuel per year during operation.
As set forth in Appendix G, Daily Trip Generation and Vehicle Miles Traveled (VMT), of the SSMND, the previously approved Amara Shopping Center would generate 89,421 daily VMT.1 The siting of the Project would reduce trip lengths for Costco members in Camarillo who currently travel to the Costco locations in Oxnard and Westlake Village, as the Project will be located closer to their homes. As such, the Project, together with the development of the remaining approved shopping center, would generate 84,830 daily VMT, which is 4,591 fewer daily vehicle miles traveled than the previously approved Amara Shopping Center. Therefore, the Project’s siting at this location would lessen transportation fuel consumption through the reduction of VMT, and the Project’s demand for gasoline and diesel fuel during operation would not cause wasteful, inefficient, or unnecessary use of energy.
C. Comparison to Approved Project
Final MND 2006-17 and Subsequent MND 2016-1 for the Amara Shopping Center did not evaluate the site development’s potential energy impacts since this was not a California Environmental Quality Act (CEQA) threshold of significance at that time. However, federal and state regulatory requirements regarding energy conservation requirements are much more stringent today than in 2016, when the City
1 Conservatively, based on the greenhouse gas emissions analysis for the 2016 Subsequent MND, the previously approved Amara Shopping Center would generate 89,421 daily VMT estimated by Kittelson & Associates using current assumptions, which is lower than the estimated 93,875 daily VMT for the approved Amara shopping center.
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approved the Amara Shopping Center. Moreover, as set forth above, the Project would result in reduced VMT, and associated transportation energy, as compared to the previously approved Amara Shopping Center. Therefore, it is reasonable to assume that (a) the Project would use energy more efficiently than the Amara Shopping Center, (b) the Project’s energy impacts would be less than the Amara Shopping Center’s energy impacts, and (c) the Project would not result in a new significant impact with respect to energy.
HO:tri