Attachment 5
Final Environmental Impact Report
Volume 1, pages 1 to 2-15
For full Final Environmental Impact Report, see the following link:
https://rma.venturacounty.gov/wp-content/uploads/2024/04/somis-ranch-farmworker- housing-environmental-impact-report-volume-1-of-2.pdf
Somis Ranch Farmworker Housing Complex
Final
Environmental Impact Report
Volume I of II
SCH No. 2020049020
prepared by
Ventura County Resources Management Agency
Planning Division
800 South Victoria Avenue, L# 1740
Ventura,
California 93009
Contact: Justin Bertoline, Senior Planner
prepared with the assistance of
Rincon Consultants, Inc.
180 North Ashwood Avenue
Ventura, California 93003
January 2021
Table of Contents
Final Environmental Impact Report
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Table of Contents
Volume
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I and II
Volume I
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Final Environmental Impact Report
1 Introduction
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Responses to Comments on the Draft EIR
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1 3
Revisions to the Draft EIR
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1 4
Mitigation Monitoring and Reporting Program
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1 Volume
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Draft
Environmental Impact Report
Executive Summary
1 Introduction
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1 2
Project
Description
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1 3
Environmental Setting
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Environmental Impact Analysis
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Other CEQA Required Discussions
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Alternatives
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References
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1 Appendices
Appendix A
Notice of Preparation and Scoping Comments
Appendix B
Preliminary On
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Site
Wastewater Treatment System Design Report
Appendix C
Air Quality and Greenhouse Gas Modeling Results
Appendix D
Initial Study Biological Assessment (ISBA)
Appendix E
Cultural Resources Supplemental Memorandum and Cultural Resources Assessment
Appendix F
No
ise Modeling Results
Appendix G
Seepage Pit Performance Test Report
Appendix H
Traffic Study
Appendix I
Preliminary Hydrology Memorandum
Appendix J
Geotechnical Engineering Report
Appendix K
Domestic Water Use Calculations
Appendix L
AB 52 Correspondence
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Somis Ranch Farmworker Housing Complex
Volume I
–
Final
Environmental Impact Report
SCH No. 2020049020
prepared by
Ventura County Resources Management Agency
Planning Division
800 South Victoria Avenue, L# 1740
Ventura,
California 93009
Contact: Justin Bertoline, Senior Planner
prepared with the assistance of
Rincon Consultants, Inc.
180 North Ashwood Avenue
Ventura, California 93003
January 2021
This report prepared on 50% recycled paper with 50%
post
-
consumer content.
Table of Contents
Final Environmental Impact Report
i
Table of Contents
Volume I
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Final Environmental Impact Report
1 Introduction
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1 1.1
Final EIR Contents
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1 1.2
Draft EIR Public Review Process
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1 1.3
EIR Certification Process and Project
Approval
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2 1.4
Draft EIR Recirculation Not Required
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2 2
Responses to Comments on the Draft EIR
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1 3
Revisions to the Draft EIR
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Mitigation Monitoring and Reporting Program
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1 Ventura County
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Introduction
Final Environmental Impact Report 1-1
Introduction
1.1 Final EIR Contents
This Final Environmental Impact Report (Final EIR) has been prepared by the County of Ventura, Resource Management Agency, Planning Division (County) to evaluate the potential environmental impacts of the proposed Somis Ranch Farmworker Housing Complex Project (“proposed project” or “project”).
As prescribed by the California Environmental Quality Act (CEQA) Guidelines Sections 15088 and 15132, the lead agency, the County, is required to evaluate comments on environmental issues received from persons who have reviewed the Draft EIR and to prepare written responses to those comments. This document, together with the Draft EIR (incorporated by reference) comprise the Final EIR for this project. This Final EIR includes individual responses to each letter received during the public review period for the Draft EIR. In accordance with CEQA Guidelines Section 15088(c), the written responses describe the disposition of significant environmental issues raised.
The County has provided a good faith effort to respond to all significant environmental issues raised by the comments. The Final EIR also includes amendments to the Draft EIR consisting of changes suggested by certain comments, as well as minor clarifications, corrections, or revisions to the Draft EIR. The Final EIR includes the following contents:
Section 1: Introduction
Section 2: Responses to Comments on the Draft EIR, which also includes a list of all commenters and public comment letters
Section 3: Amendments to the Draft EIR
Section 4: Mitigation Monitoring and Report Program
Appendices, which includes revised appendices
1.2 Draft EIR Public Review Process
The County filed a notice of completion (NOC) with the Governor’s Office of Planning and Research to begin the 45-day public review period (Public Resources Code [PRC] Section 21161), which began on September 21, 2020 and ended on November 5, 2020. The Draft EIR was made available on the County’s website (https://vcrma.org/divisions/planning). A notice of availability (NOA) of the Draft EIR was published on September 18, 2020. As a result of these notification efforts, written and verbal comments on the content of the Draft EIR were received from six State and local agencies, one organization, and three individuals. Section 2, “Responses to Comments on the Draft EIR,” identifies these commenting parties, their respective comments, and responses to these comments.
None of the comments received, or the responses provided, constitute “significant new information” by CEQA standards (State CEQA Guidelines CCR Section 15088.5).
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1.3 EIR Certification Process and Project Approval
Before adopting the proposed project, the lead agency is required to certify that the EIR has been completed in compliance with CEQA, that the decision-making body reviewed and considered the information in the EIR, and that the EIR reflects the independent judgment of the lead agency.
Upon certification of an EIR, the lead agency makes a decision on the project analyzed in the EIR. A lead agency may: (a) disapprove a project because of its significant environmental effects; (b) require changes to a project to reduce or avoid significant environmental effects; or (c) approve a project despite its significant environmental effects, if the proper findings and statement of overriding considerations are adopted (State CEQA Guidelines Sections 15042 and 15043).
In approving a project, for each significant impact of the project identified in the EIR, the lead or responsible agency must find, based on substantial evidence, that either: (a) the project has been changed to avoid or substantially reduce the magnitude of the impact; (b) changes to the project are within another agency's jurisdiction and such changes have or should be adopted; or (c) specific economic, social, or other considerations make the mitigation measures or project alternatives infeasible (State CEQA Guidelines Section 15091). Per PRC Section 21061.1, feasible means capable of being accomplished in a successful manner within a reasonable period of time, taking into account, economic, environmental, legal, social, and technological factors.
If an agency approves a project with unavoidable significant environmental effects, it must prepare a written Statement of Overriding Considerations that sets forth the specific social, economic, or other reasons supporting the agency’s decision and explains why the project’s benefits outweigh the significant environmental effects (State CEQA Guidelines Section 15093).
When an agency makes findings on significant effects identified in the EIR, it must adopt a reporting or monitoring program for mitigation measures that were adopted or made conditions of project approval to mitigate significant effects (State CEQA Guidelines Section 15091[d]).
1.4 Draft EIR Recirculation Not Required
CEQA Guidelines Section 15088.5 requires Draft EIR recirculation when comments on the Draft EIR or responses thereto identify “significant new information.” Significant new information is defined as including:
A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.
A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance.
A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project's proponents decline to adopt it.
The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.
The comments, responses, and Draft EIR amendments presented in this document do not constitute such “significant new information;” instead, they clarify, amplify, or make insignificant modifications to the Draft EIR. For example, none of the comments, responses, and Draft EIR amendments Introduction
Final Environmental Impact Report 1-3
disclose new or substantially more severe significant environmental effects of the proposed project, or new feasible mitigation measures or alternatives considerably different than those analyzed in the Draft EIR that would clearly lessen the proposed project’s significant effects.
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Ventura County Resources Management Agency
Somis Ranch Farmworker Housing Complex Responses to Comments on the Draft EIR Final Environmental Impact Report
2 Responses to Comments on the Draft EIR
This section includes comments received during public circulation of the Draft Environmental Impact Report (EIR) prepared for the Somis Ranch Farmworker Housing Complex (Project).
The Draft EIR was circulated for a 30-day public review period that began on September 21, 2020 and ended on November 5, 2020. The Ventura County Resources Management Agency received 12 comment letters on the Draft EIR. The commenters and the page number on which each commenter’s letter appear are listed below.
Letter No. and Commenter Page No.
1 Greg Ramirez, City Manager, City of Camarillo 2-2
2 Mary Otten, General Manager, Pleasant Valley Recreation & Park District 2-16 3 Jesus Vaca, Superintendent/Principal, Somis Union School District 2-19 4 Nicole Collazo, Air Quality Specialist, Ventura County Air Pollution Control District 2-21 5 Miya Edmonson, IGR/CEQA Branch Chief, California Department of Transportation 2-26 6 Pat Abel, Coastal District Deputy, California Department of Conservation 2-30 7 House Farm Workers! 2-33
8 House Farm Workers! 2-36
9 Patrick Richards 2-39
10 Tom Woods 2-80
11 Tom Woods 2-82
12 Patricia Feiner Arkin 2-85
The comment letters and responses follow. The comment letters are numbered sequentially and each separate issue raised by the commenter, if more than one, has been assigned a number. The responses to each comment identify first the number of the comment letter, and then the number assigned to each issue (Response 1.1, for example, indicates that the response is for the first issue raised in Comment Letter 1).
Where a comment resulted in a change to the Draft EIR text, a notation is made in the response indicating that the text is revised. Changes in text are signified by strikeout font (strikeout font) where text was removed and by underlined font (underlined font) where text was added. These changes in text are also included in Section 3, Revisions to the Draft EIR. 2-1
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Letter 1
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Ventura County Resources Management Agency
Somis Ranch Farmworker Housing Complex Responses to Comments on the Draft EIR Final Environmental Impact Report
Letter 1
COMMENTER: Greg Ramirez, City Manager, City of Camarillo DATE: November 4, 2020
Response 1.1
The commenter states that the proposed project is located immediately adjacent to the City of Camarillo City limits and Sphere of Influence, and suggests that the City of Camarillo’s Community Design Element should be considered in evaluation of the project.
The project is located in unincorporated Ventura County and is not subject to the City guidelines.
Nevertheless, information regarding general compatibility is provided herein. The Community Design Element establishes goals, policies, and guidelines to assist the City in preserving and enhancing its physical and visual character. General goals of the City of Camarillo Community Design Element that are applicable to the project include promoting a hometown community with a strong sense of identity; including preserving historic agricultural roots; protecting greenbelts; preserving the character of residential neighborhoods, including an objective to ensure multi-family residential development is compatible with surrounding land uses; and promoting the use of green construction practices through sustainable design guidelines.
The proposed farmworker housing complex would support and preserve the community’s historic agriculture roots and ongoing industry by providing local farmworker housing proximate to agricultural operations in Somis. The project would also preserve a 17.93-acre continued agricultural use parcel on the project site. The architectural style of the residential buildings would be “Spanish Colonial” and would not degrade the visual character of the City. The project’s on-site amenities, such as community centers, play fields, tot lots/playgrounds, a basketball court, a community garden area, and a network of meandering pedestrian walkways would promote a “hometown” community. The proposed location would provide residents convenient access to nearby services such as a library, schools, commercial centers, and religious institutions. The nearest single-family residential community is located 250 feet to the southeast across Somis Road. In addition, the proposed CWWTF would provide high quality recycled water to adjacent agricultural fields. As such, the project is compatible with surrounding land uses. The project is generally consistent with the relevant provisions of the Community Design Element.
Response 1.2
The commenter requests that the project description and site plan include any proposed walls or fences. The commenter suggests that any walls or fences should be decorative and include screening planting.
Figure 2-6 of the Draft EIR shows the landscape plan for the proposed project. EIR preparers discussed this comment with the project applicant, who has confirmed that final design of any walls or fences would be consistent with the City’s Community Design Element. This design consistency has been added to page 2-12 of the Final EIR.
Response 1.3
The commenter suggests that the site plan should show the two access driveways. 2-6
Ventura County Resources Management Agency
Somis Ranch Farmworker Housing Complex Responses to Comments on the Draft EIR Final Environmental Impact Report
It was determined the addition of the access driveways to Figure 2-3b, Housing Complex Site Plan, in the Draft EIR would make the site plan illegible. The draft Tentative Parcel Map has been added as Appendix N to this Final EIR and includes the two access driveways.
Response 1.4
The commenter states construction noise impacts to Rancho Campana High School should be evaluated even though impacts would be temporary.
Construction noise impacts are analyzed under Impact N-1 in Section 4.5, Noise in the Draft EIR. As stated in Section 4.5.2.1 of the Draft EIR, construction noise levels were calculated to be 79.1 dBA Leq at 50 feet. The following text has been added to pages 4.5-10 of the Final EIR to specifically address construction noise levels at Rancho Campana High School:
The Ventura County Construction Noise Threshold and Control Plan defines noise-sensitive receivers according to their typical sensitive time period. Residential uses are considered sensitive during the evening and nighttime hours (7:00 p.m. to 7:00 a.m.), while schools, churches, and libraries are considered sensitive during the daytime hours when in use (7:00 a.m. to 7:00 p.m.). Project construction would only occur during the daytime hours; therefore, no noise-sensitive residences would be exposed to construction noise. Over the course of a typical construction day, construction equipment would be located as close as 350 feet to the nearest daytime noise-sensitive receiver structure at the Rancho Campana High School to the west. A conservative estimate of noise attenuation is that noise levels attenuate at 6 dBA per doubling distance; therefore, the noise level at the nearest structure Rancho Campana High School is estimated at 62.2 dBA Leq.
Section 10.34.120 of the City of Camarillo Municipal Code exempts construction noise from City standards, if construction does not occur between seven p.m. to seven a.m., on Sundays, or holidays. Construction would not occur during these hours. In lieu of a quantitative construction standard in the City, the FTA Transit Noise and Vibration Impact Assessment criteria 1 are used. The
FTA provides reasonable criteria for assessing construction noise impacts based on the potential for adverse community reaction. For residential uses (the most restrictive standard), the daytime construction noise threshold is 80 dBA Leq for an 8-hour period. Therefore, the project’s construction noise level of 62.2 dBA Leq is well below the FTA threshold. Impacts from project construction noise to Rancho Campana High School would be less than significant.
Response 1.5
The commenter states that the Transportation section of the Draft EIR should account for the truck route used for soil haul trips associated with the 33,600 cy of soil import.
The following text has been added to page 2-17 of the Final EIR:
Construction activities for Phases 1, 2, and 3 would require a total of approximately 1,500 cubic yards (cy) of cut soil and 35,100 cy of fill soil, resulting in the import of approximately 33,600 cy of soil to the project site. No soil export would be necessary. Roads used for soil haul trips would primarily include Highway 101 and SR 34. Construction staging and construction work parking would occur on the project site.
1 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment. November 2018. Available online:
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibration-impact-assessment- manual-fta-report-no-0123_0.pdf
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Somis Ranch Farmworker Housing Complex Responses to Comments on the Draft EIR
Final Environmental Impact Report
Based on assumptions used for the CalEEMod model run, there would be 1,400 trips each for the three grading phases with an average length of 20 miles. These phases include 45 days of construction each, resulting in about 31 trips per day on average of construction hauling trips. This is a negligible increase in traffic and would not be significant.
Response 1.6
The commenter suggests that the agricultural buffer running along the eastern side of the proposed development footprint should be extended south along the access driveway, as it appears in the project figures that the land adjacent to the driveway will continue to be used for agricultural activity.
The eastern driveway would follow a proposed 50-foot-wide easement north of the existing Bell Ranch residences and agricultural buildings and would provide access to the housing complex from the east. On this portion of the project site, the 50-foot-wide access road and easement would serve as a buffer between the project site and the adjacent agricultural use in the same way that the access road at the City’s Desalter Facility will serve as a buffer between the Desalter Facility and the adjacent agricultural use. No revision to agricultural buffer as identified in the Draft EIR is required in response to this comment.
Response 1.7
The commenter states that construction activities associated with the City’s North Pleasant Valley Groundwater Desalter will be occurring through December 2021 and the construction staging will occupy the southern portion of the project site. The commenter notes that this could interfere with the proposed project’s Phase 1 construction, which is scheduled to commence in August 2021.
Construction equipment would enter and exit the project site from the secondary access road and would not conflict with construction activities or access to the Desalter site. Clearing, grubbing, and mass grading of the project site are not anticipated to commence until after December 2021.
Response 1.8
The commenter states that Table 1-1: Agency Comments on the NOP and EIR Responses in the Draft EIR does not include item 9 from the City’s June 12, 2019 NOP letter, which is attached to this comment letter and pertains to the community wastewater treatment facility (CWWTF) effluent.
The commenter states the Draft EIR does not provide information on potential health impacts associated with recycled water. The commenter asks whether there are any health risks associated with the proposed seepage pits and the proposed use of recycled water for outdoor irrigation.
Public health impacts associated with operation of the CWWTF are discussed in Section 4.6, Public Health, of the Draft EIR.
As noted on page 4.6-5 of the Draft EIR:
An OWTS that is undersized, improperly installed, failing, or poorly maintained has the potential to create a public nuisance and/or contaminate groundwater. Wastewater from an OWTS can contain contaminants such as nitrates, bacteria, chemicals, and viruses. If an OWTS is designed incorrectly or is not constructed in conformance with applicable building codes and construction practices, contaminants can enter the groundwater supply or streams and may result in the ponding of sewage aboveground, causing direct exposure to people and animals. 2-8
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Somis Ranch Farmworker Housing Complex Responses to Comments on the Draft EIR Final Environmental Impact Report
As noted on page 4.6-2 of the Draft EIR:
Recycled water is used for agricultural irrigation applications throughout California. Beginning with the first use of recycled water for landscape irrigation about 100 years ago, agencies across California have continued to innovate and improve the process to treat and beneficially reuse their wastewater (WateReuse 2019).2 The SWRCB establishes general policies governing the permitting of recycled water projects, develops uniform water recycling criteria appropriate to particular uses of water, reviews and approves Title 22 engineering reports for recycled water use, and allocates and disperses funding for recycled water projects consistent with its roles of protecting water quality, public health, and sustaining water supplies. When used in compliance with the Water Quality Control Policy for Recycled Water (Recycled Water Policy), Title 22, and other applicable state and federal water quality laws, the SWRCB “finds that recycled water is safe for approved uses, and strongly supports recycled water as a safe alternative to fresh water or potable water for such approved uses” (SWRCB 2018).
3 Public health impacts related to the proposed use of recycled water for outdoor irrigation are discussed in detail on pages 4.6-6 and 4.6-7 of the Draft EIR. Public health impacts related to the proposed seepage pits are discussed on page 4.6-7 of the Draft EIR.
As discussed on page 4.6-7, regulatory standards for recycled water use are designed to be protective of human and environmental health. When used in compliance with the Recycled Water Policy, the Uniform Statewide Recycling Criteria, and applicable water quality laws, the SWRCB finds that recycled water is safe for approved uses, including agricultural irrigation. Compliance with applicable regulations would protect public health. Therefore, impacts related to the proposed project’s use of recycled water for agricultural irrigation would be less than significant.
As noted on page 4.6-7 of the Draft EIR:
The seepage pits would be located entirely underground and, therefore, would not provide a vector-related public health hazard (e.g., mosquito breeding habitat).
Seepage pits are typically used for septic tank systems, which provide basic treatment for domestic wastewater flows. The project’s CWWTF would provide a higher level of treatment than is typically offered by septic systems before discharging treated effluent to the seepage pits in the dispersal field. The CWWTF design, including seepage pit design, would be subject to review and approval from the County of Ventura Environmental Health Division and the CWWTF would be constructed in conformance with applicable building codes and construction practices.
The Ventura County Building Code (2019) identifies minimum setbacks between seepage pits and buildings, property lines, surface waters, domestic water wells and pipelines, and property lines. The Code also contains seepage pit sizing requirements and requirements pertaining to rock and sand fill.
Public health impacts related to seepage pits would be less than significant.
As such, public health impacts related to recycled water use and seepage pits are addressed in the Draft EIR.
2 Reference cited in Draft EIR, not in this Responses to Comments document. 3 Ibid
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Ventura County Resources Management Agency
Somis Ranch Farmworker Housing Complex Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 1.9
The commenter states that the southern access road shared by the City’s North Pleasant Valley Groundwater Desalter will require additional improvements, including a bicycle/pedestrian pathway, in order to accommodate the proposed project. The commenter states that the City will not be responsible for these improvements and that the access road needs to be available for operation of the Desalter.
As stated on page 2-11 of the Draft EIR: “The southern driveway would include a bicycle/pedestrian pathway.” The County acknowledges the applicant would be responsible for constructing the bicycle/pedestrian pathway as part of the proposed project. The project applicant would coordinate with the City of Camarillo to maintain access to the City’s Desalter throughout the construction period.
Response 1.10
The commenter requests clarification on a label in Draft EIR Section 2.5.1.2 and Figure 2-3b titled “Road to be built by others.”
The text on page 2-11 of the Final EIR has been revised to clarify the improvements to the southern access road:
The housing complex would be accessible from two driveways from Somis Road. The southern driveway would be located within an existing 40-foot-wide easement over a road built by others that provides access to the City’s Desalter Facility site. A portion of this road would be built by the City of Camarillo for access to the City’s Desalter Facility site. The proposed project would include additional improvements to the road. The southern driveway would include a bicycle/pedestrian pathway. The eastern driveway would follow a proposed 50-foot-wide easement north of the existing Bell Ranch residences and agricultural buildings and would provide access to the housing complex from the east. The eastern driveway would be constructed as part of the proposed project and would include an off-site portion of the driveway to connect the housing complex to Somis Road.
As described therein, the City of Camarillo would design and construct a portion of the southern access road. The project applicant would be responsible for additional improvements to connect the road to the project site.
Response 1.11
The commenter states that construction activities associated with the City’s North Pleasant Valley Groundwater Desalter will be occurring through December 2021 and that construction staging will occupy the southern portion of the project site. The commenter notes this could interfere with the proposed project’s Phase 1 construction, which is scheduled to commence in August 2021.
Please see Response 1.7.
Response 1.12
In reference to the Draft EIR Appendix H, Traffic Study, the commenter states there is a repeated typographical error in which “Las Posas Valley” is incorrectly referred to as “Fas Posas Valley” and requests a correction.
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Ventura County Resources Management Agency
Somis Ranch Farmworker Housing Complex Responses to Comments on the Draft EIR
Final Environmental Impact Report
The perceived typographical errors were due to the inadvertently incorrect printing (and PDFing) of the Traffic Study. Such issues have been resolved in the Traffic Study (see Appendix H).
Response 1.13
In reference to Figure 5 on page 14 of the Draft EIR Appendix H, Traffic Study, the commenter states the project trip distribution does not equal 100 percent. The commenter also states there are strange symbols on this figure that should be corrected.
The perceived errors in Figure 5 of the Traffic Study were due to the inadvertently incorrect printing (and PDFing). Such issues have been resolved in the Traffic Study (see Appendix H).
Response 1.14
The commenter references page 26 of the Draft EIR Appendix H, Traffic Study, which describes two shared access connections to Somis Road. The commenter states only the southern access connection to Somis Road would be shared between the City’s Desalter and the proposed project.
The Traffic Study has been revised to state a shared access agreement has been established which allows the proposed project to utilize the City’s Desalter access road, which would be used as the southern access to the project site.
Response 1.15
The commenter references page 31 of the Draft EIR Appendix H, Traffic Study, which describes safe routes to school. The commenter states that Rancho Campana High School is an academy school and limits enrollment. The commenter asks whether there have been discussions with the Oxnard Union High School District regarding this project.
The County and the project applicant have participated in discussions with the Oxnard Union High School District regarding the proposed project. The applicant would be responsible for payment of school impact fees as required under Senate Bill (SB) 50, which would provide funding for an increase in school capacity if needed to accommodate the proposed project. According to Section 65996 of the California Government Code, school development fees authorized by SB 50 are deemed to be “full and complete school facilities mitigation.” As noted on page 31 of the Draft EIR Appendix H, Traffic Study, Rancho Campana High School is located within walking distance of the project site. The proposed project “would provide cross-access to the high school via a gated access connection to the school parking lot. This would allow students to walk directly to the high school without having to access major streets.”
Response 1.16
The commenter states that there are “strange” symbols and confusing formatting throughout the Draft EIR Appendix H, Traffic Study.
The strange symbols and formatting were due to the inadvertently incorrect printing (and PDFing) of the Traffic Study. Such issues have been resolved in the Traffic Study (see Appendix H).
Response 1.17
The commenter references the last paragraph on page 4.7-10 of the Draft EIR, which describes direct access to the project site as being provided via two shared access connections to Somis Road with the North Pleasant Valley Groundwater Desalter Facility. The commenter clarifies that the City 2-11
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Somis Ranch Farmworker Housing Complex Responses to Comments on the Draft EIR Final Environmental Impact Report
of Camarillo will only be constructing a portion of the southern access road connection to Somis Road. The commenter states additional improvements to the access road, including a bicycle and pedestrian pathway, will be required to accommodate the proposed project.
Please see Responses 1.9 and 1.10. As noted therein, the County assumes the City of Camarillo will only be constructing a portion of the southern access road connection to Somis Road. Additional improvements to the access road to accommodate the proposed project, including a bicycle and pedestrian pathway, will be the responsibility of the project applicant.
The following text on page 4.7-10 of the Draft EIR has been revised to clarify the project applicant’s construction responsibilities in relation to the access roads:
Regional access to the project is provided by U.S. Highway 101 and State Route 118. Direct access to the project would be provided via two shared access connections to Somis Road (State Route 34). The southern entrance would be shared with the North Pleasant Valley Groundwater Desalter Facility. The City of Camarillo will construct a new access connection to Somis Road and improve an existing connection to Somis Road portion of the southern access road as part of the North Pleasant Valley Groundwater Desalter Facility, approximately 700 feet southwest of where the eastern driveway would intersect with Somis Road at a T-intersection. A shared access agreement allowing the project to utilize the two driveway connections has been established. The segment of Somis Road adjacent to the site access is relatively straight and level, providing good sight distance. The City of Camarillo and the project applicant will be required to construct the access connections to Somis Road to County of Ventura and Caltrans design standards. The two access connections to Somis Road will be designed to meet the County Fire Department design standards to provide emergency vehicles access.
Response 1.18
The commenter references a typographical error on page 4.8-1 of the Draft EIR in which “Wastewater” is spelled “Wafstewater” and requests a revision.
The typographical error has been corrected in the Final EIR.
Response 1.19
In reference to the first paragraph on page 4.8-3 of the Draft EIR, the commenter requests that the text be revised to delete the reference to the Camarillo Sanitary District on-site.
The reference to the Camarillo Sanitary District on-site wastewater treatment is a typographical error. This text should instead refer to the CWWTF. For clarification, the text on page 4.8-3 of the Final EIR is revised as follows:
The project site is located more than 200 feet from the closest existing Camarillo Sanitary District facilities and is outside both the Camarillo city limits and the Camarillo Sanitary District limits. For these reasons, the Camarillo Sanitary District on-site wastewater treatment on-site CWWTF would be required for the proposed housing complex.
Response 1.20
In reference to the second paragraph on page 4.8-3 of the Draft EIR, the commenter requests that the text be revised to refer to the “Camarillo Sanitary District sewer system” instead of the “City of Camarillo sewer system.”
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Ventura County Resources Management Agency
Somis Ranch Farmworker Housing Complex Responses to Comments on the Draft EIR Final Environmental Impact Report
As requested, the text on page 4.8-3 of the Final EIR has been revised as follows:
The CWWTF would not discharge effluent or solid waste into either the County or City of Camarillo Camarillo Sanitary District sewer systems.
Response 1.21
In reference to the third paragraph on page 4.8-3 of the Draft EIR, the commenter requests that the text be revised to include information on potential groundwater quality impacts related to the proposed project’s seepage pits. The commenter states that groundwater quality could be impacted by recycled water not meeting regulatory standards.
The proposed project’s CWWTF would comply with applicable regulatory standards governing effluent water quality, which would protect both surface water quality and groundwater quality. As discussed on page 4.9-12 of the Draft EIR, the CWWTF would be designed to treat wastewater generated on-site to meet Disinfected Tertiary Recycled Water requirements in accordance with California Code of Regulations (CCR) Title 22. Title 22 contains the highest water treatment standards for wastewater effluent. Excess recycled water and treated wastewater effluent not meeting Title 22 standards would be dispersed through a series of underground seepage pits, and would also be subject to Los Angeles RWCQB testing and regulation.
The Los Angeles Regional Water Quality Control Board (RWQCB) Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties (Basin Plan) establishes water quality objectives (WQOs) for both surface water and groundwater bodies within its jurisdiction. As described on page
4.9-4 of the Draft EIR:
If a water body is designated as “impaired,” then a Total Maximum Daily Load (TMDL) is developed and identified for the affected water body. A TMDL establishes the maximum daily amount of a pollutant allowed in an identified water body and is used as a planning tool in addressing water quality impairments and improving water quality.
As described on pages 4.9-12 to -13 in Section 4.9, Surface Water Quality, of the Draft EIR:
As required by CCR Titles 17 and 22, the Health and Safety Code and Water Code, the proposed CWWTF would require an Engineering Report (i.e., a Title 22 Report) for “Production, Distribution and Use of Recycled Water” to the [State Water Resources Control Board] for review and approval. The County’s Building and Safety Division also has approval authority over the CWWTF and the Los Angeles RWQCB would regulate the operation of the facility. As required by water discharge requirements and water reclamation requirements, constituents (pollutants) in the recycled water would be tested daily, weekly, and/or monthly to ensure the discharge is meeting the TMDLs for pollutants established under the [Clean Water Act] to protect the beneficial uses of receiving waters.
The text on page 4.11-15 of the Final EIR has been revised to include a discussion of potential groundwater quality impacts related to the proposed project’s seepage pits:
Hydrology/Water Quality. According to the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM) No. 06111C0932F, the project site is not located within a Special Flood Hazard Area (a 100-year floodplain) (FEMA 2015) and the proposed housing complex would be located outside the 500-year floodplain. 2-13
Ventura County Resources Management Agency
Somis Ranch Farmworker Housing Complex Responses to Comments on the Draft EIR Final Environmental Impact Report
As discussed in Section 4.9, Water Resources – Surface Water Quality, of this EIR, compliance with the NPDES General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities (Construction General Permit) (Order 2009- 0009, as amended by Orders 2010-0014-DWQ and 2012-006-DWQ) Best Management Practices (BMPs) for stormwater control and/or a project-specific stormwater pollution prevention plan (SWPPP) would control and minimize erosion and siltation during project construction. Additionally, operation of the project would not directly or indirectly cause stormwater quality to exceed water quality objectives or standards in the applicable Ventura County Municipal Separate Storm Sewer System (MS4) Permit. Impacts due to potential erosion/siltation hazard and flooding hazard would be less than significant.
As also discussed in Section 4.9, Water Resources – Surface Water Quality, the Los Angeles RWQCB would regulate operation of the CWWTF. The CWWTF would be designed to treat wastewater generated on-site to meet Disinfected Tertiary Recycled Water requirements in accordance with California Code of Regulations (CCR) Title 22. Title 22 contains the highest water treatment standards for wastewater effluent. Recycled water produced by the proposed CWWTF is anticipated to be of higher quality than the current groundwater.
Excess recycled water and treated wastewater effluent not meeting Title 22 standards would be dispersed through a series of underground seepage pits and would also be subject to Los Angeles RWCQB testing and regulation. As required by water discharge requirements and water reclamation requirements, pollutants in the recycled water would be tested daily, weekly, and/or monthly to ensure the discharge is meeting the TMDLs for pollutants established under the CWA to protect the beneficial uses of receiving waters, including the underlying groundwater basin. As such, recycled water applied as irrigation water and excess treated water directed to seepage pits would be subject to Los Angeles RWQCB regulation. With regulatory compliance, potential impacts to groundwater quality would be less than significant.
As requested, the third paragraph on page 4.8-3 of the Final EIR has been revised to reference the groundwater quality discussion as follows:
Recycled water would be applied as irrigation water on adjacent agricultural lands. Excess treated wastewater effluent would be dispersed via underground seepage pits. Potential surface water quality impacts related to the proposed project’s recycled water and seepage pits are analyzed in Section 4.10, Water Resources – Surface Water Quality. Potential groundwater quality impacts are discussed in Section 4.11, Less Than Significant Environmental Effects.
The change to the Draft EIR is not “significant new information” because it does not identify a new avoidable significant effect, show a substantial increase in the severity of an environmental impact, identify a feasible project alternative or mitigation measure considerably different from others previously analyzed, or involve a change to mitigation measures that were proposed in the Draft EIR. In addition, the proposed revision is a minor change to the EIR that merely clarifies, amplifies, or makes insignificant modifications to the document.
Response 1.22
The commenter states again that the Draft EIR should analyze potential groundwater quality impacts related to recycled water and seepage pits.
Please see Response 1.21.
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Ventura County Resources Management Agency
Somis Ranch Farmworker Housing Complex Responses to Comments on the Draft EIR Final Environmental Impact Report
Response 1.23
In reference to Section 4.9, Water Resources – Surface Water Quality, of the Draft EIR, the commenter suggests the addition of information about Ventura County’s LAMP regulatory program for septic systems.
This comment is interpreted to refer to the Ventura County Environmental Health Division Local Agency Management Program (LAMP) for Onsite Wastewater Treatment Systems (OWTS). The Environmental Health Division and its regulations, including the LAMP’s OWTS Technical Manual, are addressed in Section 4.6, Public Health, of the Draft EIR. As noted on page 4.6-6 of the Draft EIR, the proposed CWWTF would be subject to existing and future federal, state, and local health and safety requirements for the handling, storage, transportation, and disposal of hazardous materials, including requirements found in the Ventura County OWTS Technical Manual and Ventura County Building Code. No change to the Draft EIR is warranted in response to this comment.
Response 1.24
The commenter suggests that the discussion of water quality impairments in Calleguas Creek listed on page 4.9-3 of the Draft EIR needs to be revised to add trash, toxicity, and salts (chloride, TDS).
The commenter states Table 4.9-1 in the Draft EIR includes a complete listing of water quality impairments.
The water quality impairments listed on page 4.9-3 of the Final EIR has been revised as follows:
Water quality impairments in the Calleguas Creek and its tributaries include ammonia, boron, copper, bacteria, nitrogen, nitrate, selenium, trash, toxicity, salts, and sulfate, as well as insecticides and pesticides such as dichloro-diphenyl-trichloroethane (DDT), dieldrin, and toxaphene.
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