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Given that species of carnivora and northern goshawk
typically space themselves at fairly even distances due to territory maintenance, I interpreted the aforementioned pattern as an indication that these estimates were made at areas smaller than those occupied by the
"population." Each species in Smallwood {1999) appeared to have what I termed a threshold area, at which the number of individuals ceased to increase
proportionally with increasing study area size {as in
Fig. 6.8). The threshold area was the low end of a spatial scale domain {B), in which the number of individuals varied considerably but did not regress on study area size with a slope significantly different from zero.

I interpreted the numerical estimates within scale domain B to represent populations because no other demographic units have been defined for the clusters of twenty-five to sixty adults that are typical of this scale domain {Smallwood 1999).

Regardless of whether the estimates in scale domain
B represented distinct populations, the theoretical
foundation of animal ecology includes the population
as a key demographic unit with functional, goaldirected significance. Odum {1959) and Dasmann {1981) defined a population as some collection of organisms of the same species occupying a particular space and sharing a suite of attributes representing a
unique organizational structure. Yet our use of N
{number of individuals) and D {density) in habitat and
other analyses is usually given no meaning with respect to the population concept. Usually, no demographic unit is attributed to N or D in habitat models.

In conducting habitat analysis using a measured set of
environmental elements, what does it mean to compare three individuals in element X to fifty in element Y and to four hundred in element Z, when the three
individuals are a small portion of a population, the
fifty compose an entire population, and the four hundred are from six populations? The three in element X~ Demographic Organization
The demographic units represented by the numbers
compared also bear on habitat analyses (Van Home
1983). Whether or not demographic organization can
be related to use of environmental elements, it affects the pattern of distribution observed. I recently discov576 90 PREDICTING SPECIES OCCURRENCES
Scale domains
A
vide habitat analysts with a means to attribute social
meaning to the frequency counts used in the habitat
models. These domains revealed a possible demographic context against which frequency data can be compared. I lack the directed field research evidence
needed to conclude that the numerical estimates in
spatial scale domain B were distinct populations.

However, the population concept can still be used to
discuss the intent of habitat analysts and the meaning
of their results.
40:

No.of
nesting
Accipiter
gentilis
30 20'
101
0 0 100 200 400
Size of study area in km2
Figure 6.8. Based on the published estimates (summarized in Smallwood 1998), the number of nesting pairs of northern goshawks (Accipiter gentilis) increases proportionally with increasing size of study area until the study area is at least 100 square kilometers (scale domain A). Study areas larger than 100 square kilometers include aggregations that no longer increase with increasing study area size (scale domain B).

Home Range
Habitat analysis within the individual's home range
fails to reveal the significance of the location of the home range. Differential use of areas within the individual's home range is interesting at the microhabitat level, but the location of the home range itself can be influenced by the location of the population and the
social and demographic status of the individual (Van
Home 1983). An individual's home range can encompass low-quality habitat simply because it was forced to live there in order to participate as a member of the population (Stamps 1991). Leger et al. (1983) found
that California ground squirrels (Spermophilus
beecheyi) adjust their behaviors to access microhabitats that would otherwise pose increased risks of predation. Animals do not always go to a place because it provides the highest-quality habitat, but once at the
place, they make the best of it, Reports of habitat
studies based on telemetry locations of individuals
often provide no information of the demographic status of the individual or of the individual's spatial relationship to the population. 300 500
may occur in an ecological sink after having been
forced there by the fifty, which themselves occur in element y out of proportion to Y's availability but well within the space needed to support a population.

That the number of individuals in spatial scale domain B did not correlate with study area size also revealed a mathematical artifact in measuring animal density (Smallwood 1999). The number of individuals
in domain B is relatively similar in magnitude to those in larger-area domains (see Smallwood 1999). Regressing density on its corresponding study area size will force a slope of -1 when density was calculated
by dividing a constant number by a variable area. Similarly, regressing density on its corresponding study area size will force a slope of O when density was calculated using the numbers that increased proportionally with study area size, such as those in scale domain A and those forming the transitions between scale domains B and larger. Therefore, density appears to be a continuous variable only in the absence of demographic organization, and its discontinuity can confound habitat analyses based on the models in Table

6.1. Intrapopulation Numbers
Comparing numerical estimates made at the subpopulation level (scale domain A) can confound the habitat analysis with the proportional relationship between
the estimated number of individuals and study area
size (Smallwood 1999), unless study sites (plots) were
chosen randomly or systematically from a region, used
and unused sites were compared, or long-term observations were used. Habitat analysis at this numerical level risks observing proportional patterns of use simply because individuals or their home ranges are reguSpatial scale (extent) domains of distribution pro. larly distributed among microhabitat elements due to 577

6. Habitat Models Based on Numerical Comparisons 91
territoriality or other social interactions that partitioned the resources at this level. Habitat analysis at this level of organization mayor may not contribute
useful inference regarding habitat, as social interactions are driving the spatial distribution within a larger area of habitat. Unless home range size can be
related to habitat quality, habitat identified from a
home range or from within the bounds of a population was pseudoreplicated (Hurlbert 1984; Aebischer et al. 1993).

As an illustration of apparent habitat use based on
intra-population numbers, I compared a measure of
resource selection (Equation 6.9 in Table 6.1) to
Botta's pocket gopher (Thomomys bottae) density to
test whether measured selection for the edge of alfalfa (Medicago sativa L.) fields was density-dependent:

Hansen and Remmenga {1961) found a clustered gopher distribution to vanish as the increasing density shifted the gopher population to a regular distribution. This density-dependence of distribution was recognized before {Taylor et al. 1978), but the densitydependence of measuring selection preference or avoidance will require habitat analysts to reconsider
current reliance on measures and statistical tests based on use and availability of resources. Measured selection of environmental elements will be density- and therefore area- and time-dependent {also see Smallwood 1995), just as information theoretical measures {e.g., H', the composite index of species richness,
log2S and evenness, J) are dependent on sample size
{Cousins 1977) or on the spatial scale at which these
measurements are derived.

This density- or scale-dependence also bears on
the timing of habitat analysis. Measures of resource
use will vary depending on the stage of ecological
succession of a site or the stage at which a site is
being colonized. Preference can be clearly observed
during the early stages of colonization, but during
the later stages the preferred resources can be hidden
by overflow of individuals into relatively less-preferred conditions.

The density estimates were from 134 counts of burrows across thirty-seven alfalfa fields in Yolo County, California, during 1992 through 1994 (Smallwood
and Geng 1997).

At low density, gophers occurred along the field
edge at nearly five times the number expected by
chance (Fig. 6.7). However, increasing density reduced
my ability to quantitatively represent gopher selection for the field edge (? = 0.71, Root MSE = 0.49, p <

0.001):

Interpopulation Numbers
Comparing numbers {densities) between populations
poses two potential obstacles to recognizing true patterns of habitat association. The spatial shifting of aggregations summarized by Taylor and Taylor {1979) involves clustering at a subset of the available highquality habitat patches. Taylor and Taylor {1979) proposed four hypotheses to explain the frequently observed spatial shifting of aggregations: { 1) populations must move once they deplete their most limiting resources; {2) population members shift locations innately so as to prevent the exhaustion of resources; {3) dispersal and territory establishment of the next generation also establishes the location of the next aggregation, while the previous aggregation senesces; and, (4) a combination of hypotheses 1-3. Occupied habitat patches are either not different from many of those that are unoccupied at the time of the analysis or they are ephemeral in their quality. In the latter case, the results of habitat analysis are ephemeral. In the former ~e4-8°phers at edge =3.09-1.43 log Density
Expected gophers at edge
The obvious preference for the edge grew increasingly hidden as gophers invaded the interior of the field and approached a regular distribution due to saturation of territorial space, represented by a ratio of

1.0 between the observed and expected gophers at the
field edge. I do not think that gophers favored the
edge any less as density increased, but rather their
preference for the edge grew increasingly less recognizable as the overall density in the field increased (Fig. 6.7). As gophers saturated the field interior, the clustering along the edge became hidden, just as
578
92 PREDICTING SPECIES OCCURRENCES
likely to reveal meaningful differences and is therefore relatively uninteresting. In other words, density needs to vary considerably to reveal possible differences in
habitat quality, but intrapopulation regularity of distribution and mutually high-density populations will not vary sufficiently in N or D to provide inference regarding habitat selection.

The terms N and D in habitat models can be representative of whole populations, and the occurrence frequency or spatial areas occupied by these populations compared to the measured set of environmental elements within a region or the species' range. The N
or D representing a whole population can simply be
replaced by a 1 to denote presence or a O to denote absence, and little information would be lost so long as the populations are discrete and easily bounded. Representing whole populations, presence or absence might be just as informative as N or D. If this step
were taken, then the boundary of the area that is occupied by the population would need to be identified.

The area occupied by the population might be more
reliable as a measure of use than either N or D.
case, habitat analysis might measure use as less
than availability, and a strict adherence to the numerical comparison might mislead the investigator to conclude that the occupied habitat patches are less
preferred.

Today's absence at a site can be tomorrow's presence, as the spatial distribution is unique for each generation {Taylor and Taylor 1979). Habitat measured at time tl can represent the species' habitat at times t2 and t3 only if the same generation and the same environmental conditions span times tl through t3. If the species shifted locations between generations, as is
common according to Taylor and Taylor {1979) and
den Boer {1981), or if environmental conditions
changed between times tl, t2, and t3, then the analysis at time tl will be inadequate and misleading if the goal is to describe the species' habitat; it will contribute to a belief that the species relies on a narrower range of environmental conditions than it actually does. The
exception will be constrained aggregations, which will
be at the same locations at all times, so long as none
of the aggregations go extinct. However, habitat
analyses using constrained aggregations are predisposed to mislead simply due to the constraints on availability of suitable environmental elements.

An additional obstacle is the meaning we attach to
numerical variations of each population. Population
number can vary greatly, with increases and decreases
lagging behind changes in conditions of resources. Interannual variability in N typically cannot be characterized adequately until monitoring has been conducted spanning multiple generations {Cyr 1997).

Therefore, when comparing N or D from population
X to that of population Y, and N or D differs, can we
really conclude that habitat quality differs between the sites occupied by populations X and Y?
Presumably, sociality and energy and material resources maintain a carrying capacity just below which exists an optimal density. Within the spatial bounds of a population, density can vary somewhat but must be
constrained by territoriality or the habitat element in most limited supply. Comparing locations occupied by
populations, density might be nearly the same within
the bounds of each population {Smallwood 1999).

Comparing density within the spatial bounds of a
population or between high-density populations is unMegapopulation or Regional Numbers Demographic organization is again implicitly ignored
by habitat models that compare densities to measure
use and availability of elements between regions. Regions are usually large-enough areas to include multiple populations. Garshelis and Visser (1997) termed the collective abundance from regions as megapopulations because they did not know what else to call it.

Metapopulations, on the other hand, theoretically organize within regions (Hanski and Gilpin 1997), but empirical evidence is lacking for knowing the bounds
of a metapopulation or how many populations might
compose a metapopulation. Regional patterns of distribution are still largely theoretical, and the term megapopulation indicates that this theory is weak.

Comparing densities or use of regions poses the additional problem of comparing the availability of disparate measured sets of environmental elements (Wiens and Rotenberry 1981b). For example, Smallwood and Fitzhugh (1995) compared the number of puma track sets to represent use of available vegetation complexes and topographic categories across all the sampled areas of California, which included areas
579

6. Habitat Models Based on Numerical Comparisons 93
spanning the full north-south and east-west extents of
the state within the species' range. The topographic
categories were common across the state, consisting of
ridges, mountain peaks, basins, canyons, and so on.

These macrohabitat categories were fairly comparable
across California, much like Anderson's (1981) use of
vegetation structural elements across the United
States. However, sage-juniper forests are limited to
north-central and eastern California, and chaparrals
occur more to the west; they are not interspersed.

Comparing use to availability of vegetation categories
seemed uninformative on a statewide level, especially
when puma populations occurred in both sage-juniper
and chaparral. Knowing the range of environments
used by pumas in California is useful, and knowing
that pumas are more rare in the Mojave Desert than in
the Klamath Mountains is also useful, but habitat
analysis involving use and availability comparisons is
probably best conducted within regions, within
which key elements are more likely to be naturally
interspersed.
animals can be better represented by categories, including population occurrence, trace activity (i.e., a few individuals in a large area), and absence. Lidicker (1995) also summarized categorizations of habitat quality,
which were thought to bear directly on densities. Habitat analysts need to test whether animal aggregations are discrete or graded, whether population boundaries
can be identified, and whether densities are categorical in correspondence with habitat quality. Empirical evidence should be the foundation of theory, and theory that bears on gradients of abundance also bears on
habitat analysis.

It is well documented that individuals can occur in
what are regarded as ecological sinks for the species.

In fact, numerical estimates in ecological sinks can always be greater than zero just because dispersing animals are forced into the sink where the rates of recruitment outpace mortality. Habitat models based on numerical comparison will thus give ecological sinks
some positive habitat value in such cases, whereas the
true value should be negative (less than zero) with respect to the functionality of the population. Density estimates alone cannot inform of sink conditions
(Lidicker 1975, Van Home 1983), because density estimates cannot be negative-they range from zero to some presumed carrying capacity. Learning of sink
conditions requires intensive study, making use of
more information than numerical estimates (e.g.,
Morris 1989).

Gradient of Abundance
Animal density is often represented with contours,
which illustrate relatively smooth gradations in density from high to low across landscapes or regions (e.g.,
Taylor and Taylor 1977; Wiens and Rotenberry 1981b;
Cody 1985a,b; Scott et al. 1986; Root 1988a,b,c; Price
et al. 1995; Morrison et al. 1998). These gradients are mathematically derived using averaging and interpolation, whereas the actual spatial distribution may not be smoothly graded. This transformation of field observations into density contours expresses a world-view of distribution that acknowledges aggregation as the
norm for animal species but also facilitates the p~tentially erroneous idea that animal density corresponds to habitat quality. Habitat quality is assumed to be energy-related, as discussed previously, so it is related to the world-view that the laws of thermodynamics govern the spatial patterning of animal species, also previously discussed. However, this world-view, that density grades smoothly across the landscape, can be supported by few examples, just as sharply bounded aggregations can be supported by few examples (Morrison et al. 1998). It may be that spatial distributions of Preconception of Habitat
The map of available environmental elements is made
by the habitat analyst. Some a priori notion of habitat inevitably goes into construction of the incidence map
and will affect the typology of the map and its spatial grain (Austin, Chapter 5). For example, Smallwood
and Fitzhugh (1995) used typical home range size of
puma to decide on the quadrat size and transect
lengths for counting track sets in California. The volunteer biologists who selected the exact locations of the transect segments believed that roads along
ridgetops would produce more tracks. We later
learned that roads along streams were most productive. If we were to start a new sampling program for puma track sets, it would differ markedly from the
580
94 PREDICTING SPECIES OCCURRENCES
mographic conditions. Habitat models implicitly assume that deviations from the theoretical null patterns of distribution are immediate responses of individuals
to resources that are available in the measured space.

However, demographic organization can represent a
long-term response to energy and material resources
in the environment experienced by the species, and it
can pose much of the information useful to the individuals. If a suite of environmental and demographic conditions typified the success of the species over long time periods, then the species likely developed perceptions of habitat and demographic organization that are relatively reliable evolutionarily. Such stability
could be achieved by building the responsible neurons
early in ontogeny (Coss and Goldthwaite 1995). How
such perceptions would be manifested in the changed
landscapes of modern times can affect our interpretations of habitat.

Habitat analysis is bound to include plenty of noise
caused by conserved use of information from relic environments, which today may be missing from the studied environment. For example, after Hutto (1990)
experimentally reduced food supplies from under the
bark of specific trees, he found no difference in visits per tree or time spent at the tree by birds that depend on this food supply during the winter months in the
boreal forest. In another example, the carrying capacity of pocket gophers in alfalfa fields is determined not by the food source, which is plentiful, but by the home range size. The home range size was established by
natural selection in past environments where food
supplies were typically more limited. Pocket gophers
in alfalfa are so constrained by evolutionarily designed perceptions of space that they cannot fully exploit alfalfa stands, which are perhaps the most abundant food source these animals have ever encountered.

Management or policy decisions should acknowledge
a reasonable level of uncertainty in habitat analysis or assessment and should be very conservative.
1985 design, and the results would likely differ as
well.

Preconceived notions of habitat influence the
study's location, spatial extent, grain of mapping, and ultimately the replication and interspersion of the environmental elements in the map. Habitat analysts often collect the use and availability data from locations where the species was known to occur, often in abundance. By siting habitat studies this way, analysts may often force results that conform to preconceived
notions of habitat. Experimental design principles
should be applied to mensurative as well as to manipulative studies (Smallwood 1993). The spatial extent and grain of the study should be appropriate to measuring the species' differential use of the environment.

Replication and interspersion of treatments (i.e., environmental elements considered to be available to the species) also must be incorporated into mensurative
studies (also see Otis 1998; Austin, Chapter 5). Along
a transect or within a defined study area, replication
of available elements is achieved through multiple occurrence of each environmental element in the measured set of elements (e.g., vegetation complexes).

Those elements occurring once are pseudoreplicated
(sensu Hurlbert 1984) and association of the species
with that element should be considered dubious pending further research (e.g., environmental elements X and Z in Fig. 6.4 are pseudoreplicated, while y is
measured as two replicates). Interspersion is achieved
by each element's occurrence between other elements
in the measured set, such that gradient effects do not
cause spurious relationships between measured use
and availability. Thus, replication and interspersion of various environmental elements can be achieved when
the program of observation includes two or more
patches of each environmental element within the
study area or along the transect.

Given that the analyst is constrained by observing
extant environmental conditions, the observed use of
the environment by an individual, population, or
larger social unit need not reflect the species' perception of what constitutes habitat or high-quality habitat (Morrison et al. 1998). Much of what analysts may perceive as a numerical response to extant environmental conditions actually may be responses to the combination of both relic and current habitat and de-~
Conclusions
Comparing numerical terms for use and availability
cannot reliably characterize habitat without considering the environmental and demographic contexts of the numbers. The measurements and resulting associa581

6. Habitat Models Based on Numerical Comparisons 95
sented by the past and current environments, or to
predators and competitors. Each model has a theoretical root or history, and we need to decide whether the theoretical foundation is consistent with what we are
attempting to measure and how we should interpret
the resulting patterns.

Van Home's {1983) argument that density is a
misleading indicator of habitat quality remains valid,
and based on recent research on density, it is all the
more clear that numerical comparisons are currently
of dubious utility to habitat analysis. Density estimates are sensitive to whether they are derived from population "isolates" or from sampling of the statistical universe {Preston 1962a), and they are sensitive to the size of the study area examined {Smallwood
and Schonewald 1996). Until much more basic research on animal distribution has been conducted, the models in Table 6.1 should be used cautiously because their use can translate into inappropriate management decisions, sometimes with possible dire consequences for the species. tions are determined largely by the attributes of the
field study design, as well as those of the analytical, interpretive design. These attributes are themselves determined largely by the analyst's preconception of habitat, demographic organization of the species, how
the species is patterned spatially and temporally, and
the reasons for animals to congregate or associate
with environmental elements out of proportion to the
element's availability (Fig. 6.2). At our current state of knowledge, world-views may bear more heavily on
habitat analysis than does the procedure for measuring occurrence frequencies in environmental elements.

Some of these world-views can be tested as hypotheses
by directed field research. For example, how often do
animals aggregate for reasons that do not bear directly on the availability of a food resource? Are all aggregations truly populations? How sharply bounded are animal populations? Answers to these and other related questions can provide habitat analysts with meaning
for numerical comparisons that the models do not
provide.

The effectiveness of habitat analysis based on numerical comparisons is largely dependent on knowing how and why animals distribute themselves. The models in Table 6.1 will be prone to inappropriate application and erroneous interpretation until analysts largely agree on the extent to which animal species respond
numerically to energy availability, information preAcknowledgments I thank Michael Morrison and Linnea Hall for helpful
discussions on habitat. I thank Michael Morrison,
Leona Svancara, Martin Raphael, and J. Michael
Scott for critical review comments.
582
Edited by
J. MICHAEL SCOTT
PATRICIA J. HEGLUND
MICHAEL L. MORRISON
JONATHAN B. HAUFLER
MARTIN G. RAPHAEL
WILLIAM A. WALL
FRED B. SAMSON

ISLAND PRESS
Washington. Covelo .London
583
Copyright @ 2002 Island Press
All rights reserved under International and Pan-American Copyright Conventions. No part of this book may be reproduced in any form or by any means without permission in writing from the publisher: Island Press, 1718 Connecticut Avenue, N. w:, Suite 300, Washington, DC 20009.

Library of Congress Cataloging-in-Publication Data
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Manufactured in the United States of America
10987654321
Includes bibliographical references (p. )
ISBN 1-55963-787-0 (cloth: alk. paper)

1. Zoogeography. 2. Animal populations. 3. Habitat (Ecology) 4.

Spatial ecology. I. Scott, J. Michael.

QU01 .P642001
578'.09-dc21
584
Aeroecology: probing and modelling the aerosphere
Thomas H. Kunz,1,* Sidney A. Gauthreaux Jr,† Nickolay I. Hristov,*,# Jason W. Horn,* Gareth Jones,‡ Elisabeth K. V. Kalko,§ Ronald P. Larkin,
Gary F. McCracken,k Sharon M. Swartz,# Robert B. Srygley,** Robert Dudley,†† John K. Westbrook‡‡ and Martin Wikelski§§

Center for Ecology and Conservation Biology, Department of Biology, Boston University, Boston, MA 02215, USA; †
Department of Biological Sciences, Clemson University, Clemson, SC 29634, USA; ‡School of Biological Sciences, University of Bristol, Woodland Road, Bristol BS8 1UG, UK; § Department of Experimental Ecology, University of Ulm,
Albert-Einstein-Allee 11, 89069, Ulm, Germany;

Illinois Natural History Survey, 607 East Peabody Drive, Champaign, IL 61820, USA; k
Department of Ecology and Evolutionary Biology, University of Tennessee, Knoxville, TN 37996-1610, USA; # Department of Ecology and Evolutionary Biology, Brown University, Providence, RI 02912, USA;

USDA-ARS, 1500 N.

Central Avenue, Sidney, MT 59270, USA; ††Department of Integrative Biology, University of California, Berkeley, CA 94720, USA; ‡‡USDA-ARS, 2771 F&B Road, College Station, TX 77845, USA and §§Department of Ecology and Evolutionary Biology, Princeton University, Princeton NJ 08544, USA Synopsis Aeroecology is a discipline that embraces and integrates the domains of atmospheric science, ecology, earth science, geography, computer science, computational biology, and engineering. The unifying concept that underlies this emerging discipline is its focus on the planetary boundary layer, or aerosphere, and the myriad of organisms that, in large part, depend upon this environment for their existence. The aerosphere influences both daily and seasonal movements of organisms, and its effects have both short- and long-term consequences for species that use this environment. The biotic interactions and physical conditions in the aerosphere represent important selection pressures that influence traits such as size and shape of organisms, which in turn facilitate both passive and active displacements. The aerosphere also influences the evolution of behavioral, sensory, metabolic, and respiratory functions of organisms in a myriad of ways.

In contrast to organisms that depend strictly on terrestrial or aquatic existence, those that routinely use the aerosphere are almost immediately influenced by changing atmospheric conditions (e.g., winds, air density, precipitation, air temperature), sunlight, polarized light, moon light, and geomagnetic and gravitational forces. The aerosphere has direct and indirect effects on organisms, which often are more strongly influenced than those that spend significant amounts of time on land or in water. Future advances in aeroecology will be made when research conducted by biologists is more fully integrated across temporal and spatial scales in concert with advances made by atmospheric scientists and mathematical modelers. Ultimately, understanding how organisms such as arthropods, birds, and bats aloft are influenced by a dynamic aerosphere will be of importance for assessing, and maintaining ecosystem health, human health, and biodiversity.

Introduction
The biosphere has been traditionally viewed as being
composed of the lithosphere, hydrosphere and atmosphere, each of which interact dynamically with the other. In an ecological context, the Earth’s lower
atmosphere or troposphere has long been considered
an important functional component of the biosphere
through the exchange of nutrients, water, and gases
in the form of local, regional, and global climate
variation and biogeochemical cycles. However, to our
knowledge, the aerosphere—the relatively thin substratum of the troposphere closest to the Earth’s surface that supports life–has rarely been considered beyond
studies of meteorological conditions and functional
ecosystem relationships, such as nutrient cycling
and gas exchanges in the atmosphere (Oke 1987,
Sorbjan 1989, National Research Council 1997). Until
quite recently, ecologists with interests in organisms
that depend on the aerosphere as a fluid medium for
movement (e.g., dispersal, foraging, and migration),
a source of food and nutrients, and ever-changing
physical conditions (e.g., weather and air pollution),
have worked more or less independently of atmospheric scientists. Research goals of organismal biologists who study airborne organisms have mostly focused on the behavior, ecology, and evolution of
specific taxonomic groups (e.g., microbes, arthropods,
From the symposium ‘‘Aeroecology: Probing and Modeling the Aerosphere—The Next Frontier’’ presented at the annual meeting of the Society for Integrative and Comparative Biology, January 2–6, 2008, at San Antonio, Texas. 1 E-mail: [email protected]
1 Integrative and Comparative Biology, pp. 1–11
doi:10.1093/icb/icn037
 The Author 2008. Published by Oxford University Press on behalf of the Society for Integrative and Comparative Biology. All rights reserved.

For permissions please email: [email protected].

Integrative and Comparative Biology Advance Access published May 21, 2008 585
birds, and bats), or specific physiological or behavioral functions such as thermoregulation, water balance,
respiration, or flight. In contrast, research goals of
atmospheric scientists and engineers have largely
emphasized how severe weather and climate can
affect human well-being, and thus have focused on
the efficacy and efficiency of human developments,
including building construction (e.g., skyscrapers),
modes of transportation (e.g., sail boats, aircraft,
spacecraft), design and installation of communication
infrastructure (e.g., tall towers and transmission lines), and power generation (e.g., utility and residential scale wind energy facilities). Achieving these two sets of goals in large measure depends upon understanding the
dynamic properties of wind and associated meteorological conditions at local, regional, or global scales, and understanding how these conditions affect movements of organisms.

To our knowledge, no organism spends its entire
life in the aerosphere, yet many species spend a
significant portion of their lives in this environment
(Wilcove 2008). Species that spend significant
amounts of time in terrestrial and aquatic ecosystems
also may depend on the aerosphere for daily and
seasonal locomotion, and sometimes for courtship
and mating. Important selection pressures accordingly influence the biology of flight, including the size and shape of structures that comprise the flight
apparatus, and sensory modalities that provide information about the aerosphere, and the active and passive systems that control locomotor movements.

On both temporal and spatial scales, the aerosphere is more variable and dynamic than the lithosphere or hydrosphere. Relative to strictly terrestrial and aquatic organisms, species that regularly occupy
the aerosphere are almost immediately influenced
by changing atmospheric conditions (e.g., pressure,
wind, air density, precipitation, temperature), and
other physical factors (e.g., solar radiation, polarized light, moon light, and geomagnetic and gravitational
forces). Organisms that use the aerosphere for
foraging, dispersal, and seasonal movements have
evolved unique body forms and shapes, but also
specific physiological traits (e.g., increased production of hemoglobin at high altitudes), thermoregulatory and respiratory responses, and the like, in response to different selection pressures. The aerosphere and the organisms that compose it not only are strongly influenced by predictable atmospheric
conditions, but also by a myriad of anthropogenic
conditions (e.g., lighted towns and cities, skyscrapers, air pollution, aircraft, radio and television towers, and more recently from the proliferation of wind turbines
and communication towers) that increasingly have
adverse effects on such essential activities such as
feeding, dispersal, migration, and courtship (Kunz
et al. 2007a, 2007b; National Research Council 2007;
Arnett et al. 2008; Horn et al. 2008; Fig. 1). Similarly, human-altered landscapes (e.g., forest fragmentation,
agriculture, and urbanization) are rapidly and irreversibly transforming the quantity and quality of available habitats for organisms that use the aerosphere, conditions that also can affect the structure and function of terrestrial and aquatic ecosystems and the assemblages of organisms therein. Prevailing
climate change and its expected effects on global
circulation of the atmosphere and resultant changes
on local, regional, and weather conditions may have
profound effects on the historic migratory patterns
of animals that use the aerosphere (Wilcove 2008).

Challenges of probing and modeling the
aerosphere
Ecologists who study species that use the aerosphere
face three important challenges: (1) to discover how
best to detect the presence, taxonomic identity,
diversity, and activity of organisms that use this
space, (2) to identify ways to quantify relevant environmental variables at different temporal and spatial scales, and (3) to determine how best to understand
and interpret responses of organisms in the context
of complex meteorological events and patterns
within both natural and anthropogenically altered
environments. Efforts to address these challenges
require the collaboration of scientists from diverse
disciplines who have expertise and instruments
needed to probe the aerosphere whether by day or
night, in arid and humid conditions, at low and high
altitudes, in strong and weak magnetic fields, in cold
and warm climates, and during calm and windy
conditions. Increasingly available tools, some originally designed for military purposes, space exploration, climate modelling, and security applications, include remote sensing and imaging devices such as
radar, lidar, aircraft surveillance, weather satellites, night vision, and thermal infrared imaging cameras.

Other instruments designed specifically for the study
of animal movements, include radio-telemetry networks of ground-based stations and satellites, devices that detect audible and ultrasounds of birds and bats,
stable isotope and DNA markers for assessing migration, which can be particularly valuable when used in combination with remotely sensed atmospheric, oceanic, and landscape conditions. Availability of these tools and methods provides rich opportunities for addressing emerging questions in ecology and environmental sciences with an emphasis on the aerosphere.
2 T. H. Kunz et al.
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Fig. 1 The aerosphere is influenced by both natural phenomena and anthropogenic factors. (A) Aerospheric view of a volcanic eruption on the island of Montserrat (news.nationalgeographic.com); (B) Counter-clockwise swirl of clouds as a cyclone passed over Iraq, and dust being transported within the warm sector of the system (ucsu.colorado.edu/drewsc/sandstorm/); (C) Aerial view of the North American landscape at night, showing lighted cites and towns (www.usgcrp.gov/usgcrp/images/ocp2003/8.1b-HCR); (D) Aerospheric view of skyscrapers New York City (www.justinlagace.com); (E) Aerial view of an agricultural landscape, showing the influence of center pivot irrigation in an arid region of Colorado (www.discoverlife.org/IM/EL_DP/0010/mx); (F) Aerospheric view of land-based communication towers (hawkins.pair.com/voadelano/voa_delano03.jpg); (G) Aerospheric view of a modern U.S. Air Force F-16 Fighting Falcon aircraft (galleries.fototagger.com/image/f-16_fighting_); (H) Aerospheric view of a modern, utility-scale wind energy facility in Palm Springs, California (www.planetscience.org/revisiontime/wind2.jpg).

Aeroecology 3
587
The appropriate integration of diverse tools,
technologies, and multiple databases promises to
inform important ecological concerns and concepts,
ranging from spread of invasive species, changes in
biodiversity, and local- and global-scale animal
movements in response to altered terrestrial, aquatic,
and aerial environments. To date, ecologists have
been hampered by a lack of technological awareness,
inconsistent vocabularies, and challenges of working
across different disciplinary platforms, including the
complexities of establishing meaningful collaborations with atmospheric and computer scientists.

Similarly, ecologists interested in proximate and
evolutionary responses of airborne fauna to climate
change and other anthropogenic perturbations have
yet to optimally use the rich databases on landscapes
assembled by earth scientists and geographers using
remote sensing tools [e.g., American MODIS
(Moderate Resolution Imaging Spectroradiometer),
the European MERIS (Medium Resolution Imaging
Spectrometer), and the Indian IRS-P6 (Indian
Remote Sensing Satellite)].

Goals of the aeroecology symposium
The papers presented in this symposium address
some of the limitations and challenges highlighted
above, and highlight opportunities for gaining new
insights that could arise from overcoming these
challenges. To accomplish these goals, each of the
authors considered several ecological questions that
require analyses that embrace ecological and environmental sciences relevant to the aerosphere.

Specifically, questions relate to animal displacements, and atmospheric and biological factors that may
affect daily and seasonal patterns of prey density,
foraging behavior, and migration. In addition to
developing and promoting new tools and technologies to support research in aeroecology, it is important to integrate knowledge from different
disciplines by encouraging the participation of
scientists from varied backgrounds to develop a
broader understanding of complex processes and the
responses of organisms to a dynamic aerosphere. To
achieve these goals, the authors share ideas with
respect to novel tools, emphasize tangible and
specific scientific questions, and adopt novel research paradigms. To this end, we have identified instrumentation and software tools, and discuss their applications to improve our collective understanding
of the aerosphere and the interactions of airborne
organisms with the hydrosphere and lithosphere.

Several research areas were not included in this symposium because time was limited. Notwithstanding, we include brief comment on these and other
emerging disciplines relevant to understanding the
ecology of organisms that use the aerosphere.

Historical and current research on
aeroecology
Weather radar historically has been used for detecting groups of migrating birds (Able 1970; Bruderer and Steidinger 1972). Since the early 1990s, weather
surveillance, NEXRAD (NEXt Generation RADar)
Doppler radar has been used at various temporal
scales to quantify movements of birds (Diehl et al.
2003; Diehl and Larkin 2005; Larkin 2005;
Gauthreaux and Belser 2003, 2005; Gauthreaux
et al. 2003, 2006; Kunz 2004), although it has
become increasingly clear that many targets also
include bats and insects (Westbrook et al. 1998;
Kunz 2004; Cleveland et al. 2006; Cryan and Diehl in
press). Similarly, tracking radar is being used to
investigate foraging, dispersal, and migratory movements of flying arthropods, birds, and bats (Bruderer and Boldt 2001; Bruderer and Popa-Lisseanu 2005;
Larkin 2005). Additionally, use of vertical profiler
radar promises to provide new insight into the
distribution and movement of air masses, and of
arthropods, birds, and bats in the aerosphere (Smith
et al. 1993; Eaton et al. 1995; McLaughlin 2003; Kunz
et al. 2007b; T.A. Kelly, personal communication).

Advances in radio-telemetry (e.g., miniature radio
transmitters for insects, small birds and bats, and
satellite tracking with GPS for larger species), have
advanced our knowledge of movements at smaller
spatial and temporal scales than can be provided by
radar. Recent developments of integrated arrays of
receiving antennae and satellite tracking of small
birds and bats (Cochran and Wikelski 2005; Smith
et al. 2005; Wikelski et al. 2007), in addition to
advanced canopy-netting techniques (Hodgkison
et al. 2002), are beginning to yield new insights on
animal movements, pollination of flowers by nectarivores, and dispersal of seeds by frugivores (Hodgksion et al. 2003; Thies and Kalko 2004;
Croxall et al. 2005; Nathan et al. 2005; Thies et al.
2006)—research that also is relevant to the conservation of biodiversity (Trakhtenbrot et al. 2005) and for understanding the transmission and mitigation of
emerging diseases (Chivian 2003; Epstein et al. 2003).

Radio transmitters, together with other visualization methods, also are enabling researchers to quantify energy expenditure, wingbeat patterns,
respiration, and flight altitudes of small, free-ranging animals (e.g., Lord et al. 1962; Dudley 2000; Altshuler et al. 2004; Bowlin et al. 2005). Use of wind tunnels
4 T. H. Kunz et al.
588
and computer-aided visualization techniques (Srygley
and Thomas 2002; Altshuler and Dudley 2003;
Pivkin et al. 2005; Swartz et al. 2006; Hedenstro¨m
et al. 2007; Henningsson et al. 2008; Muijres et al.
2008) also are helping to inform field ecologists in
how flow dynamics and atmospheric conditions
influence flight behavior of bats, birds, and insects
(e.g., Dillon et al. 2006).

Measuring physiological traits of foraging and
migrating animals, under different atmospheric
conditions (Greenstone 1990, 1991), also has begun
to advance our knowledge of how animals respond
to different aerospheric conditions. Moreover, novel
efforts are being made to understand how insects,
birds, and bats navigate during migration (Holland
et al. 2006a, 2006b). Experimental manipulations
have included alteration of magnetic fields to
understand how animals navigate over long distances
(e.g., Cochran et al. 2004; Srygley et al. 2006;
Holland et al. 2006b; Wang et al. 2007). A recent
initiative to employ radio technology on a near-earth
satellite to track small animals around the globe
holds considerable promise for understanding migratory movements of free-ranging animals (Wikelski et al. 2007). A recent global initiative, known as the
International Cooperation for Animal Research
Using Space (ICARUS; www.icarusinitiative.org),
also has been formed to help achieve this goal.

Other initiatives, including NEON (National Ecological Observatory Network [http://www.neoninc.org/]), and related Research Coordination Networks, such as
MIGRATE (Migration Interest Group: Research
Applied toward Education [www.migrate.ou.edu]),
both funded by the National Science Foundation,
have been formed to help answer important questions
such as the influence behavioral plasticity of migrants, drivers of population dynamics of migratory animals,
determinants of individual fitness, and impacts of
environmental change on migratory life-histories
(JF Kelly, personal communication).

Recent developments in audible and ultrasonic
acoustic detection and analysis, coupled to highspeed infrared and thermal images now make it possible to quantify three-dimensional flight trajectories of bats as they pursue airborne arthropods (Schnitzler and Kalko 2001; Holderied et al. 2005;
Holderied and Jones in press; Hristov et al. 2008),
and to unambiguously identify the mix of freeranging bat species in both temperate and tropical assemblages (Parsons and Jones 2000; Brigham et al.
2004; Szewczak 2004; Parsons and Szewczak in press).

This technology now makes it possible to characterize
species richness and activity patterns that previously
been difficult to quantify or record species have gone
completely undetected, such as many aerial insectivorous bats, especially in tropical regions (Jung et al. 2007). Night vision devices and thermal infrared
cameras have become increasingly used to observe
birds, bats, and insects aloft, not only for assessing
foraging behaviors (Simmons 2005; Betke et al. 2007;
Horn et al. 2008; Hristov et al. 2008), but also for
censusing animals during nightly emergence flights
(Sabol and Hudson 1995; Frank et al. 2003; Betke
et al. 2007, 2008; Hristov et al. 2008). When used
simultaneously with tracking radar, night vision
devices and thermal infrared cameras also make it
possible to distinguish between birds and bats as they
respond to anthropogenic structures such as wind
turbines (Gauthreaux and Livingston 2006; Kunz et al.
2007a; 2007b).

Many important aspects of the behavior of flying
organisms in the aerosphere occur in groups, sometimes of immense sizes. Many collective behaviors are influenced by the three-dimensional geometry of
the environment, and by the cognitive abilities
of animals that interact with prevailing atmospheric
conditions. Understanding the behavior of individuals in isolation does not necessarily provide information about the properties of individuals
within groups (Couzin and Krause 2003). Increased
focus on empirical studies, self-organization theory,
and mathematical modelling of group and collective
behavior of insects, birds, and other organisms
promises to help advance knowledge about daily
flocking behavior at the population level and group
dynamics during migration (Couzin 2006a, 2006b).

Use of stable isotopes of carbon and nitrogen as
dietary tracers also can provide valuable insights into trophic relationships of airborne predators and their
prey (Iba´n˜ez et al. 2001; Sullivan et al. 2006: PopaLisseanu et al. 2007), and isotopes of hydrogen can additionally be used for discerning geographic
origins of nocturnal migrants (Hobson and
Wassenaar 2001; Cryan et al. 2004; Kelly et al.
2002; 2005, Hobson et al. 2006).

Collaborations of biologists with atmospheric scientists and aerospace engineers are needed to help advance understanding of animal behavior in the aerosphere. In turn, these collaborations can help advance the technical design and function of small, unmanned
aerial vehicles, as inspired by the ecology, behavior,
physiology, and biomechanics of real organisms (Watts
et al. 2001; Pivkin et al. 2005; Swartz et al. 2006).

The symposium
To the extent possible, each contribution from this
symposium has posed several important questions
Aeroecology 5
589
and has reviewed existing and upcoming applications that inform new answers. Interdisciplinary approaches are emphasized, particularly those
designed to optimally exploit the expertise of
domain scientists in behavior, ecology, biomechanics,
meteorology, computer science, and geography—
approaches that are central to developing meaningful
cross-disciplinary collaborations.

Using Doppler weather surveillance radar,
Gauthreaux et al. (2008) discuss major challenges
in understanding daily and seasonal movements of
airborne fauna. Reflectivity data contain information
on the quantity of organisms aloft, and data on
velocity and winds aloft are needed to determine the
different types of organisms that use the aerosphere.

The latter is accomplished by examination of
statistical distributions of the maximum ground
speeds of airborne fauna in the aerosphere. Because
migrating birds and bats have mean velocities greater
than most insects and randomly foraging birds and
bats in a sample volume of the aerosphere, these data
can often be used to detect and discriminate specific
targets aloft.

Horn and Kunz (2008) used NEXRAD databases
to explore how Brazilian free-tailed bats disperse
nightly into the aerosphere, and how this information can provide insight into local population dynamics. NEXRAD radar images are georeferenced
and compiled in a GIS along with colony locations
and landscape features. In temporal sequences of
NEXRAD images, identification of individual bat
colonies is accomplished by assessing reflectivity
from bats aloft using computer vision algorithms.

These measurements are used to compute relative
colony size and mean direction of travel and to
compare variation in emergence behavior both
within and among colonies. Analyses using circular
statistics suggest that multiple factors play a role in the nightly flight and dispersal behavior of bats, and
demonstrate that NEXRAD data can be a valuable
resource for monitoring the nightly behavior of large
bat colonies, and larger-scale seasonal and interannual changes in abundance of local populations.

Larkin and Szafoni (2008) discuss how tracking
radar data can be used to investigate nocturnal
aggregations of birds. Statistical analyses of detailed flight paths support the hypothesis that individual
birds that fly together (closer than 200–300 m) move in the same direction and at the same speed more often
than those that are widely dispersed. Evidence from
tracking radar suggests that birds flying together also may have similar wing beat frequencies than can be
expected by chance.

Hristov et al. (2008) provide an overview of recent
applications of thermal infrared imaging in ecological research and discuss how this technology has revolutionized our ability to observe and document
the behavior of free-ranging organisms in the dark.

Unlike traditional imaging that requires visible light, thermal infrared imaging relies on the emission of
heat energy from objects in the environment.

Temperature-sensitive cameras and computer vision
algorithms are used to detect differences in thermal
values in their fields of view and to depict
information visually as different brightness (temperature) values. As noted in this article, successful applications of thermal infrared imaging from
ongoing studies of bat ecology and behavior also
are relevant for the study other organisms.

Kalko et al. (2008) present results based on
recordings and analysis of echolocation calls of
Neotropical bats that, for the first time, permit
explicit species identification as well as assessment of foraging activity in these species-rich tropical assemblages. Use of miniature radio transmitters also makes it possible to assess foraging strategies, range
size, and differential habitat use of species that
previously have been otherwise difficult to study.

Given the high impact of bats as seed dispersers,
pollinators, and predators on arthropods, the fine
resolution of movements afforded by radio-telemetry
provides a better understanding of the links between
spatial use and resource distribution and abundance.

In turn, this provides novel information needed to
understand temporal dynamics, to help quantify the
ecosystem services provided by bats, and to predict
how anthropogenic changes may affect the abundance and distribution of their prey.

Jones and Holderied (2008) discuss how echolocation is used by bats to detect, localize, and classify airborne targets at night. As obstacles or prey species are approached, it has become increasingly clear that
the call structure of echolocating bats changes in
predictable ways: calls become shorter to reduce
overlap between pulse and echo, and calls change in
shape so that localization errors in the detection of
insect prey can be minimized. Echolocation behavior
and flight performance of bats are closely synchronized by monitoring both features simultaneously using stereo photo- and videogrammetry, and by
acoustic tracking of their flight paths. These
approaches make it possible to quantify the intensity
of signals used by free-ranging bats, and thus
demonstrate systematic changes in signal design in
relation to the proximity of obstacles (e.g., moving
insect prey and stationary objects) in the aerosphere.
6 T. H. Kunz et al.
590
Westbrook (2008) discusses long-distance migration of important agricultural pests, such as adult corn earworm moths (Helicoverpa zea), also called
cotton bollworm moths, and several other noctuid
moth species upon which bats and birds sometimes
feed. These seasonal geographic expansions of pest
populations and the consequent increased infestations
of agricultural crops are documented on a continental scale in North America. Observed patterns of migratory flight by these insect pests are largely
associated with vertical profiles of temperature and
wind direction and are concentrated in the atmospheric boundary layer. Collective patterns of moth migrations generally are related to wind direction, but often at significant angular deviations. Preliminary
analyses suggest that moth distributions in the aerosphere can be estimated from discrete moth counts using X-band radar and bulk reflectivity data from
NEXRAD Doppler radar.

McCracken et al. (2008) discuss bat echolocation
calls recorded using radio microphones suspended
in the aerosphere from kites and tethered helium
balloons. These data mostly include calls of Brazilian
free-tailed bats from ground-level up to 1118 m
above ground level (AGL). Altitudinal profiles show
significantly different levels of bat echolocation call activity at different levels AGL in the aerosphere.

Bat activity was greatest at ground level and
400–600 m AGL, coincident with the atmospheric
boundary layer and the highest densities of moths
as described in the paper by Westbrook (2008).

Feeding buzzes, indicating attacks on aerial prey,
were most abundant near ground level and at
400–600 m AGL, although some were detected at
altitudes up to 1 km AGL.

Srygley and Dudley (2008) review data on insects in
the atmospheric boundary layer by tracking individuals as they migrate across the Caribbean Sea and the Panama Canal. Data presented on dragonflies of the
genus Pantala show that migration occurs in October
and is associated with frontal systems. Butterflies
and dragonflies are capable of directed movement
towards a preferred compass direction in variable
winds, whereas moths of the genus Urania migrate
from Central to South America and drift with winds
over water. Butterflies navigating in the aerosphere
appear to use both global and local cues. In support
of optimal migration theory, butterflies and dragonflies appear to adjust their flight speeds to maximize migratory distance per unit energy, whereas moths
do not.

Swartz et al. (2008) examine the biomechanics and
physiology of flight of bats in the laboratory, and
explore how this knowledge can help advance
understanding of foraging, dispersal, and migration
of free-ranging animals. Laboratory studies of animal
flight in wind tunnels provide valuable information
for improving and understanding of airflow dynamics. Emphasis is placed on flow characteristics of distinct aerial environments as a critical first step
toward understanding the ecology of free-ranging
animals aloft. The dynamics of natural airflow, characterized by air speeds, variability, intensity, and turbulence, will likely influence many aspects of an
animal’s behavior in the aerosphere. A combination
of field- and laboratory-based research also is needed
to delineate conditions under which flight mechanics
and energetics are influenced by turbulence created
by other animals.

Cochran et al. (2008) discuss the advanced use of
miniaturized radio-transmitters that allow for the
continuous monitoring of behavioral and physiological variables of small, free-ranging animals that use the aerosphere. Monitoring of nocturnal migratory
flights of three species of neotropical thrushes in the mid-western US has revealed variations in wing beat
frequencies, flight speeds and body accelerations that
may reflect ascending and descending movements of
individuals during flights. Individual thrushes also
pause (in wingbeat) more often than expected during
their migratory flights, likely to save energy. The high variation in wingbeat frequencies also cautions
against categorizing radar echoes as particular types
of birds.

Future directions
To further advance the emerging discipline of
aeroecology, studies are needed that integrate the
research discoveries of atmospheric scientists, engineers, and computer scientists with those of ecologists, physiologists, and functional morphologists, to more fully understand the activity and movements of organisms in the aerosphere. Research that incorporates laboratory and field studies on biomechanics, physiology, behavior, and ecology also promises to provide new insights into how, where,
when, and why organisms interact with anthropogenic features in the aerosphere. To this end, studies are needed to assess: (1) physiological and behavioral
responses of airborne organisms to climate change,
(2) behavioral and ecological responses of organisms to structures that extend into the aerosphere (e.g., communication towers, tall buildings, and wind
turbines), (3) how landscape fragmentation and land
use change affects movements, and (4) how the
altered structure of aeroecological communities,
through the invasion of exotics, may affect species
Aeroecology 7
591
distributions and abundance (Lindenmayer and
Fischer 2006; National Research Council 2007;
Kunz et al. 2007a; Lian 2007; Wilcove 2008). Use
of stable isotopes to investigate trophic relationships between insects, birds, bats, and their prey also
promises to yield valuable insight into how the
myriad of organisms interact in the aerosphere.

Ultimately, understanding the ecosystem services
provided by arthropods, birds, and bats that use
the aerosphere is important for maintaining ecosystem health, human health, and biodiversity on the planet (Daily et al. 1997; Cleveland et al. 2006;
Chivian and Burnstein 2008).

Acknowledgments
We wish to thank the Society for Integrative and
Comparative Biology (SICB) Program Committee, its
program director, Linda Walters, the chairs of the
divisions of Vertebrate Zoology, Comparative Biomechanics, and Ecology and Evolution for supporting the ‘Symposium on Aeroecology.’ We also thank Sue Burk, SICB meeting director for making the
logistical arrangements to convene our symposium.

We are grateful to Paul Cryan, Mark Friedl, Jeff
Kelly, and Ana Popa-Lisseanu for their valuable
suggestions on an earlier draft of this manuscript.

We are especially grateful to Johnny Evers and
Willard Larkin for their encouragement and support
in convening this symposium. We wish to thank the
Air Force Office of Scientific Research, through a
grant to Boston University (FA9550-7-1-0449 to
THK), for providing partial travel support for each
of the speakers to present their papers as part of
the ‘Symposium on Aeroecology,’ and the SICB for
waiving registration fees for symposium speakers.

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Received: 11 December 2020 | Revised: 31 December 2021 | Accepted: 15 January 2022 DOI: 10.1002/jwmg.22216

RESEARCH ARTICLE
Utility‐scale solar impacts to volant wildlife
K. Shawn Smallwood
3108 Finch Street, Davis, CA 95616, USA
Correspondence
K. Shawn Smallwood, 3108 Finch Street,
Davis, CA 95616, USA.

Email: [email protected]
Abstract
To reduce carbon emissions from fossil fuel combustion, United States government agencies, including those in California, initiated aggressive programs to hasten development of utility‐ scale solar energy. Much of California's early development of solar energy occurred in deserts and annual grasslands, much of it on public land. Measurement of solar energy's impacts to wildlife has been limited to mortality caused by features of solar facilities, and has yet to include impacts from habitat loss and energy transmission. To estimate species‐specific bird and bat fatality rates and statewide mortality, I reviewed reports of fatality monitoring from 1982 to 2018 at 14 projects, which varied in duration, level of sampling, search interval, search method, and carcass detection trials. Because most monitors performed carcass detection trials using species of birds whose members were larger than birds and bats found as fatalities, I bridged the monitors' onsite trial results to offsite trial results based on the same methods but which also measured detection probabilities across the full range of body sizes of species represented by fatalities. This bridge preserved the project site's effects on detection probabilities while more fully adjusting for the effects of body size. My fatality estimates consistently exceeded those reported. Projected to California's installed capacity of 1,948.8 MW of solar thermal and
12,220 MW of photovoltaic (PV) panels in 2020 (14,168.8 MW total), reported estimates would support an annual statewide fatality estimate of 37,546 birds and 207 bats, whereas I estimated fatalities of 267,732 birds and 11,418 bats. Fatalities/ Journal of Wildlife Management 2022;e22216. wileyonlinelibrary.com/journal/jwmg | 1 of 29 https://doi.org/10.1002/jwmg.22216
This is an open access article under the terms of the Creative Commons Attribution License, which permits use, distribution and reproduction in any medium, provided the original work is properly cited. © 2022 The Authors. The Journal of Wildlife Management published by Wiley Periodicals LLC on behalf of The Wildlife Society. 596
MW/year averaged 11.61 birds and 0.06 bats at PV projects and 64.61 birds and 5.49 bats at solar thermal projects.

Fatalities/km/year averaged 113.16 birds and zero bats at generation tie‐ins, and 14.44 birds and 2.56 bats along perimeter fences. Bird fatality rates averaged 3 times higher at PV projects searched by foot rather than car. They were usually biased low by insufficient monitoring duration and by the 22% of fatalities that monitors could not identify to species. I estimated that construction grading for solar projects removed habitat that otherwise would have supported nearly 300,000 birds/year. I recommend that utility‐scale solar energy development be slowed to improve project decision‐making, impacts assessment, fatality monitoring, mitigation efficacy, and oversight.

KEYWORDS
bats, birds, carcass detection trials, collision mortality, fatality monitoring, solar energy, wildlife impacts
In response to environmental and economic threats posed by carbon emissions from fossil fuel combustion, state and federal governments embarked on ambitious plans to develop renewable energy in California, USA (California Public Utilities Commission 2008). Plans such as the Desert Renewable Energy Conservation Plan (California Energy Commission et al. 2014) were formulated to overcome regulatory and permitting barriers for utility‐scale renewable energy and its transmission to help Californians achieve the goal of obtaining 60% of its energy from renewable sources by 2030 and 100% of it by 2045. Because development of utility‐scale renewable energy projects comes with environmental costs, including impacts to wildlife, state and federal agencies collaborated on an Avian‐Solar Science Coordination Plan (Multiagency Avian‐Solar Collaborative Working Group 2016) to identify and prioritize information needs related to impacts to birds. Just as understanding of impacts to wildlife lagged the rapid expansion of wind energy development (May et al. 2015, 2017), understanding impacts to wildlife also lags the rapid expansion of utility‐scale solar energy projects (Multiagency Avian‐Solar Collaborative Working Group 2016, Kosciuch et al. 2020). For example, only recently was it learned that many of the animals killed at California's solar projects originated out of state (Conkling et al. 2020), thus elevating the impacts to the regional level.

Deliberation is needed concerning the environmental costs and benefits of utility‐scale solar energy compared to other forms of energy generation (e.g., wind, geothermal, hydroelectric, fossil‐fuels, nuclear, rooftop solar).

Accurate estimates of wildlife mortality would help determine impacts at project and regional levels. Researchers have calculated regional estimates of wind energy impacts to birds (Loss et al. 2013a, Smallwood 2013, Zimmerling et al. 2013, Erickson et al. 2014) and bats (Hayes 2013; Smallwood 2013, 2020; Zimmerling and Francis 2016).

Researchers have also discussed cumulative impacts (Calvert et al. 2013) and calculated regional estimates of wildlife mortality caused by other anthropogenic sources, such as from collisions with automobiles (Loss et al. 2014a), transmission lines (Rioux et al. 2013, Loss et al. 2014b), and buildings (Machtans et al. 2013, Loss et al. 2014c), and predation from house cats (Loss et al. 2013b). Accuracy of these regional estimates depends on representativeness of the monitored projects (or places) relative to the spatial distribution of all projects (Smallwood 2013, Huso and Dalthorp 2014). It also depends substantially on study design and field methods implemented at the project level.
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Before 2012, fatality monitoring at utility‐scale solar projects was rare, largely because few utility‐scale solar projects existed. The only wildlife fatality monitoring performed before 2012 had been at the 10‐MW Solar One project in 1982‒1983 near Barstow in San Bernardino, California (McCrary et al. 1986). Since monitoring at Solar One, much had been learned about fatality monitoring at wind projects from the late 1980s through the initial fatality monitoring plan for solar projects (Nicolai et al. 2011) and its update in 2016 (Huso et al. 2016). Managers formulated guidance documents to standardize survey methods for the purposes of accurately estimating and comparing fatalities among wind energy projects and to fatalities estimated for other forms of energy generation (Smallwood 2017b). Researchers deliberated field methods concerning their support of accurate fatality estimation (Smallwood 2007, Johnson et al. 2016, Reyes et al. 2016, Smallwood et al. 2018, Kitano et al. 2020), and the estimation methods themselves (Korner‐Nievergelt et al. 2011, Kitano and Shiraki 2013, Péron et al. 2013, Warren‐ Hicks et al. 2013, Smallwood et al. 2018). A new framework for testing the efficacy of bat, golden eagle (Aquila chrysaetos), and bald eagle (Haliaeetus leucocephalus) impact‐reduction strategies at wind energy projects (Sinclair and DeGeorge 2016) was also an important step in measuring and responding to utility‐scale renewable energy impacts to volant wildlife. Much of what has been learned from research of wind energy impacts to wildlife can contribute to improved fatality monitoring at utility‐scale solar projects, but solar projects also pose different risk factors, including to many species less vulnerable to wind energy impacts.

Once constructed, utility‐scale solar projects pose multiple fatality risk factors. Volant wildlife can collide with solar collectors, power block structures, project buildings, medium‐voltage overhead lines, gen‐tie lines (i.e., generator lead or transmission lines), fencing, and automobiles servicing the project. Some birds might collide with photovoltaic (PV) panels because of the lake effect, or the birds' perception of many closely spaced PV panels as a waterbody onto which they attempt to land (Kagan et al. 2014). Polarized light from PV panels might attract prey of insectivorous birds and hence the birds themselves (Horváth et al. 2010), or it might fool birds into trying to lick water from the panel while in flight (Horváth et al. 2009, 2010). Reflected self‐images on mirrors of solar thermal projects, or even of PV panels, might elicit aggressive responses of birds motivated to defend territory (Hager and Craig 2014, Kahle et al. 2016). Collisions might result from high‐speed predator‐ prey encounters in which the pursuer or pursued collide with a project feature (Dunn 1993). Bats might fail to detect angled collector panels or mirrors because of reduced echolocation output (Gorresen et al. 2017, Corcoran and Weller 2018) or confused echolocation feedback (P. R. Long, retired military pilot, personal communication). Bats might also misinterpret echolocation‐detected flat panels as water bodies from which they attempt to drink while in flight (Greif and Siemers 2010). At power tower projects, birds and bats die because of acute exposure to the zone of solar flux (Kagan et al. 2014). Data summarized herein indicate that birds also perish because of electrocution on energized portions of the project, entrapment or entanglement with project infrastructure such as fencing, and drowning in solar evaporation ponds. Until 2018, however, data needed to test hypothesized causal factors and to estimate regional fatalities were largely unavailable to the public.

Reviews of project‐level fatality estimates were reported by those with exclusive access to reports and data (Kagan et al. 2014, Cooper 2016, Walston et al. 2016, Kosciuch et al. 2020). These reviews, along with Harrison et al. (2016), discussed barrier effects, habitat loss, and displacement of wildlife, but they focused on the lesser impacts of mortality caused by operable projects. In the reviews other than Harrison et al. (2016), fatality rates at operative projects were compared mostly as they had been reported, and only Walston et al. (2016) attempted to adjust all project‐level fatality counts by carcass detection probabilities. I obtained and reviewed reports, data, environmental reviews, and communications related to bird and bat fatality monitoring at California utility‐scale solar energy projects (Table 1). The variety of study designs and methods I observed inspired my own estimations of project‐level fatality estimates. I became most concerned over liberal exclusions of fatalities from project‐level fatality estimates, use of automobiles in fatality searches, and placements of inappropriate carcasses to measure searcher detection and carcass persistence in carcass detection trials.

My first objective was to compare my independent estimates to originally reported estimates of bird and bat SOLAR IMPACTS | 3 of 29
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TABLE 1 Solar projects for which fatality data were made available for bats and bird mortalities 1982‒2018 at solar projects in California, USA, in response to United States Freedom of Information Act and California Public Records Act requests in 2018
Project Refa Countyb
Features
surveyedc MW Ha Year(s)
Other
surveysd
California Valley Solar Ranch 1 SLO PV, OL, G, F 258 476 2012–2014 Bat, BM Topaz Solar Farm 2 SLO PV, OL 550 677 2012–2016 Nest, Use, Bat, BM
Campo Verde Solar Project 3 Imp PV, G, F 139 584 2013–2016 None Centinela Solar Energy Project 4 Imp PV, G, F 170 665 2014–2015 None Imperial Solar Energy Center
South
5 Imp PV, G 130 383 2014 None
Calipatria Solar Project 6 Imp PV 20 64 2016 None
Midway Solar Farm II 7 Imp PV 30 113 2018 None
Desert Sunlight Solar Farm 8 Riv PV, G, F 550 1,700 2015–2016 None Stateline Solar Farm 9 SB PV, G 300 682 2017–2018 None
McCoy Solar Energy Project 10 Riv PV, G, F 250 914 2016–2017 None Blythe Solar Power Project 11 Riv PV, G, F 235 769 2016–2017 None Genesis Solar Energy Project 12 Riv SCA, PB, P, G, F 250 728 2015–2017 None Solar One 13 SB PT, HM, F, P 10 32 1982–1983 Use
Ivanpah Solar Electric
Generating System
14 SB PT, HM, G, F 377 1,457 2013–2018 Use
a
References: 1 = H.T. Harvey and Associates (2013, 2015a); 2 = Althouse and Meade (2012, 2014); 3 = Heritage Environmental Consultants (2014, 2015a 2016); 4 = Heritage Environmental Consultants (2015b), Chambers Group (2016); 5 = UltraSystems (2014a–e); 6 = Heritage Environmental Consultants (2017a,b,c); 7 = Shoener and Barrett's Biological Surveys (2018); 8 = Western EcoSystems Technology (2017a 2018a); 9 = Dudek (2018a); 10 = Martinson et al. (2018b); 11 = Doering and Santistevan (2013), Martinson et al. (2018a); 12 = Western EcoSystems Technology (2016, 2017c); 13 = McCrary et al. (1986); 14 = H.T. Harvey and Associates (2015b), Western EcoSystems Technology (2017b, 2018b, 2019).
b
SLO = San Luis Obispo, Imp = Imperial, Riv = Riverside, SB = San Bernardino. c
PV = photovoltaic panels mounted on ground‐based metal frames, OL = medium voltage overhead lines, G = gen‐tie, or generation tie‐ins to the nearest substation or transmission lines, F = perimeter security fence, SCA = solar collector arrays composed of parabolic mirrors, PB = power blocks, P = solar evaporation ponds, PT = power towers receiving reflected sunlight from heliostat mirrors, and HM = heliostat mirrors arranged to reflect solar energy to receiver on power tower. d
Bat = bat activity surveys performed using acoustic detectors; BM = background mortality surveys consisting of fatality searches in adjacent areas lacking solar project infrastructure; nest = nest survey, use = visual scans to detect and count birds during daylight hours.
fatality rates at monitored utility‐scale solar projects. I predicted my estimates would usually be higher. My second objective was to estimate statewide fatalities of birds and bats caused by the installed capacity of utility‐solar projects in 2020. My third objective was to apportion collision fatality impacts to project features to reveal which features warrant greatest concern. My fourth objective was to compare fatality rates among bird and bat species and among those with special status to identify species in relatively greater need of research and mitigation. My fifth objective was to identify additional sources of error and bias that warrant further research to increase accuracy of fatality estimates. 4 of 29 | SMALLWOOD
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STUDY AREA
The fatality monitoring studies I reviewed had been performed from 1982‒2018 at 14 utility‐scale solar energy projects on relatively flat terrain in annual grassland, desert, and agricultural environments within the desert of California (Figure 1; Table 1). Elevations ranged −4 m to 983 m. Climate was Mediterranean, with warmest temperatures and least rainfall during June–August, coolest temperatures and greatest rainfall during November–February, and transitional periods with increasing temperatures and decreasing rain in March–May, and deceasing temperatures and increasing rain during September–October. Twelve projects were located in Mojave and Sonoran deserts, where annual rainfall averaged <10 cm, and natural ground cover was desert scrub including creosote (Larrea tridentata). Two project sites were in San Luis Obispo County, where annual rainfall averaged 10–38 cm, and natural ground cover was annual grassland composed of red brome (Bromus madritensis rubens), soft chess (Bromus hordeaceus), foxtail barley (Hordeum murinum), six‐weeks fescue (Festuca octoflora) and wild oat (Avena fatua.). Wildlife typical of the desert sites included coyote (Canis latrans), desert kit fox (Vulpes macrois), bighorn sheep (Ovis canadensis), black‐tailed jackrabbit (Lepus californicus), canyon bat (Parastrellus hesperus), common raven (Corvus corax), desert sidewinder (Crotalus cerastes), and Agassiz desert tortoise (Gopherus agassizii).

FIGURE 1 Locations and rated capacities (MW) of solar energy project sites that were monitored for wildlife fatalities in California, 1982‒2018: 1 = California Valley Solar Ranch, San Luis Obispo County, 2 = Topaz Solar Farm, San Luis Obispo County, 3 = Campo Verde Solar Project, Imperial County, 4 = Centinela Solar Energy Project, Imperial County, 5 = Imperial Solar Energy Center South, Imperial County, 6 = Calipatria Solar Project, Imperial County, 7 = Midway Solar Farm II, Imperial County, 8 = Desert Sunlight Solar Farm, Riverside County, 9 = Stateline Solar Farm, San Bernardino County, 10 = McCoy Solar Energy Project, Riverside County, 11 = Blythe Solar Power Project, Riverside County, 12 = Genesis Solar Energy Project, Riverside County, 13 = Solar One, San Bernardino County, 14 = Ivanpah Solar Electric Generating System, San Bernardino County SOLAR IMPACTS | 5 of 29
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Wildlife typical of the grassland sites included coyote, San Joaquin kit fox (Vulpes macrotis mutica), black‐tailed jackrabbit, giant kangaroo rat (Dipodomys ingens), and northern Pacific rattlesnake (Crotalus oreganus oreganus).

All monitored projects had been graded flat and natural vegetation had been removed. Of the 3 solar energy technologies monitored, 1 technology included flat PV panels on ground‐mounted frames with solar trackers at most projects. The other 2 technologies were solar thermal, including solar‐trough parabolic mirrors referred to as solar collector arrays (SCAs) at Genesis Solar Energy Project, and heliostat mirrors reflecting light to receivers, or boilers, atop power towers at Ivanpah Solar Electric Generating System (Ivanpah) and the since‐decommissioned Solar One project. Solar projects connected to the grid via gen‐ties, which resemble transmission lines and their towers. Solar projects were also surrounded by perimeter security fences. Some projects also included medium‐ voltage overhead lines. Monitored projects totaled 3,259 MW, including 627 MW of solar thermal and 2,632 MW of PV. They included 163.35 km of security fence bordering 2,237 MW of solar arrays (0.073 km/MW) and

78.09 km of gen‐tie serving 2,237 MW of solar arrays (0.037 km/MW) that were monitored for fatalities.

METHODS
Through use of California Public Records Act (PRA) and federal Freedom of Information Act (FOIA) requests to agencies with regulatory authority over biological resources, I obtained reports, data, environmental reviews, and communications related to fatality monitoring at utility‐scale solar projects in California. Field and analytical methods of fatality monitoring varied among reports but all were intended to estimate the number of fatalities caused by the project. Monitors searched for fatalities by following protocols designed to account for proportions of fatalities not found, to extrapolate from sampling units to whole projects, and to compare fatality rates between project features and whole projects. Although monitors used various fatality estimators, the basic form was F = F ρ  ,
where F
 was the fatality estimate, F was the number of fatalities found, and ρ represented carcass detection probability.

Monitors typically searched by foot or by car for fatalities according to a periodic schedule and along evenly spaced transects across sampled portions or all of a solar project. At 6 projects, monitors applied distance sampling from transects. They usually removed all fatality finds upon discovery. Most performed carcass detection trials, in which testers placed carcasses on the study site to quantify searcher detection rates and carcass persistence time, or the time until the placed carcass was no longer detectable by searchers. Outcomes of carcass detection trials were used to estimate ρ. For fatality estimation, monitors usually omitted fatalities found incidental to scheduled searches or outside search areas. Some monitors set 5 or 10 fatality detections/species as thresholds for species' inclusion, and some separately reported fatality estimates between known and unknown cause of death. A few reports provided estimates for 10 species with the highest fatality rates.

From information I received following PRA and FOIA requests, I constructed data sets I needed to independently estimate fatalities at monitored solar projects (fatality data and their reported attributes, along with definitions of data fields [Table S1], are available in Supporting Information). I recorded each study's start date, duration of monitoring of each project feature, proportion of each project feature searched, whether searched by walking or car, transect width, whether distance sampling was used, fatality search interval, and fatality metric (Table 2). I recorded essential attributes of carcass detection trials that monitors used to represent ρ, including taxa, carcass source, body size classes into which trial carcasses were grouped, trial duration, and metric used to estimate the probability of carcasses persisting to the next search (r), which could be derived from R = proportion of carcasses remaining on the ith day into a trial, RC = mean daily carcass persistence upon the ith day into a trial, and t̅= mean days to carcass removal (Table S2, available in Supporting Information). Some of the monitors' detection trials included placements of feather piles as a separate class from small and large birds. I did not use the results of such trials because all fatalities found as feather piles began as complete carcasses. Starting a trial from a feather pile, as if the rest of the carcass never existed, was unrealistic. 6 of 29 | SMALLWOOD
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TABLE 2 Bird and bat fatality search methods reported at utility‐scale solar projects in California, USA, 1982–2018
Project Featurea Yrs Sample (%) Search Transect (m)b
I (days) in spring,
summer, fall,
winterc Fˆ metricd
CVSRe Gen‐tie 2.4 100 Walk 15 7, 7, 7, 7 F/(S × r)
CVSRe MVOH 1.8 100 Walk 18 7, 7, 7, 7 F/(S × r)
CVSRe Fence 2.0 20 Walk 3 7, 7, 7, 7 F/(S × r)
CVSRe PV 2.0 20 Walk 5 7, 7, 7, 7 F/(S × r)
Topaz MVOH 5.0 3.3 Walk 2.13 1 | 30 F/plot/search
Topaz PV 5.0 3.5 Walk 2.3 1 | 30 F/plot/search
Campo Verde Fence 2.5 100 Walk 1 | 30 None
Campo Verde Gen‐tie 2.5 30 Walk 7.5 1 | 30 None
Campo Verde PV 2.5 30 Walk 1 | 30 None
Centinela Gen‐tie 0.8 50 Walk 5 3.5, 3.5, 3.5, 3.5 F/(S × RC) Centinela Fence 1.0 100 Walk 1 | 30
Centinela PV 1.0 10 Walk 4.2 1 | 30 F/0.2 yr
Imperial Gen‐tie 0.4 100 Car 1 | 30 None
Imperial PV 0.4 10 Car 14.5 1 | 30 None
Calipatria PV 2.0 100 Walk 35 7, 21, 7, 21 Distancef
Midway PV 0.4 Car 60 7, 0, 18, 0
Desert Sunlight Fence 1.0 7 Car 7, 23, 8, 19 F/(S × r)
Desert Sunlight Gen‐tie 1.0 48 Walk 15 7, 23, 8, 19 F/(S × r) Desert Sunlight PV 1.0 30 Walk 70 7, 23, 8, 19 F/(S × r × A) Stateline Fence 1.0 100 Car 3 7, 21, 7, 21 F/(S × r)
Stateline Gen‐tie 1.0 50 Car 15 7, 21, 7, 21 F/(S × r)
Stateline PV 1.0 40 Car 120 7, 21, 7, 21 F/(S × r × A)
McCoy Fence 2.0 98 Car 3 7, 21, 7, 21 F/(S × r)
McCoy Gen‐tie 2.0 25 Walk 15 7, 21, 7, 21 F/(S × r)
McCoy PV 2.0 45 Car 160 7, 21, 7, 21 F/(S × r × A)
Blythe Fence 2.0 92 Car 3 7, 21, 7, 21 F/(S × r)
Blythe Gen‐tie 2.0 25 Walk 15 7, 21, 7, 21 F/(S × r × A) Blythe PV 2.0 41 Car 95 7, 21, 7, 21 F/(S × r × A)
Genesis Fence 2.0 100 Car ? 7, 20, 7, 19 F/(S × r)
Genesis Gen‐tie 2.0 25 Walk 15 7, 20, 7, 19 F/(S × r)
Genesis Ponds 2.0 100 Walk 7, 20, 7, 19 F/(S × r)
Genesis PBlocks 2.0 100 Walk 7.5 7, 20, 7, 19 F/(S × r) Genesis SCAs 2.0 30–50 Car 30 7, 20, 7, 19 F/(S × r × A) (Continues)
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Where monitors used distance sampling, I derived probabilities of searcher detection of trial carcasses within distance increments from transects, which were reported graphically. I multiplied each distance increment by transect length to calculate the search area, and hence the search area as a proportion of the project area (A) associated with a probability of searcher detection. Because all but the gen‐tie at Centinela did not report distances of fatalities from the transect, I usually could not assign fatalities to the distance increment for which detection probabilities had been characterized by trials. I therefore averaged S × A among the distance increments searched, where S was the proportion of placed trial carcasses found within the ith distance increment (of those available), and A was the searchable area between the car and the farthest point of the ith distance increment. Along with r, S × A composed ρ: F = F
rSA ××  .

Where carcass detection trials were not implemented, insufficiently described, or based on <8 carcass placements/ category of bats, small birds, and large birds (i.e., California Valley Solar Ranch [CVSR], Campo Verde, Centinela, Imperial, Solar One), I applied detection rates from my own trials of carcasses as part of 2 3‐year fatality monitoring studies in the Altamont Pass Wind Resource Area (APWRA). Given its short‐stature annual grassland cover, carcass visibility to scavengers and fatality searchers should be similar between the APWRA and the 5 project sites to which I applied APWRA‐ derived carcass detection rates, but to minimize differences, I relied solely on trial carcasses that had been placed on open ground to simulate conditions of ground visibility at the 5 solar project sites. The APWRA trials were integrated into routine fatality monitoring with placements that were periodic throughout each study and randomized within fatality search areas. In 1 study, trials included 276 bird carcasses of 79 species that ranged in mass from 2 g to 6,650 g (Smallwood et al. 2017a, 2018). In the other study, trials included 764 bird carcasses of 100 species ranging in mass from TABLE 2 (Continued)
Project Featurea Yrs Sample (%) Search Transect (m)b
I (days) in spring,
summer, fall,
winterc Fˆ metricd
Solar One Heliostats 0.8 100 Walk 7, 0, 7, 7 F/(r)
Solar One Tower 0.8 100 Walk 7, 0, 7, 7 F/(r)
Ivanpah Fence 2.0 100 Car 3 7, 25, 7, 25 F/(S × r)
Ivanpah Gen‐tie 2.0 100 Car 15 7, 25, 7, 25 F/(S × r)
Ivanpah Heliostats 2.0 24 Walk 5 7, 25, 7, 25 F/(S × r) Ivanpah Heliostats 2.0 8 Walk 7, 0, 0, 21 F/(S × r)
Ivanpah Towerg 2.0 100 Walk 7, 25, 7, 25 F/(S × r)
Ivanpah Towerg 100 Walk 7, 21, 7, 21 F/(S × r)
a
PV = photovoltaic panels mounted on ground‐based metal frames, MVOH = medium voltage overhead lines, Gen‐ tie = generation tie‐ins to the nearest substation or transmission lines, Fence = perimeter security fence, SCA = solar collector arrays composed of parabolic mirrors, PBlocks = power blocks, Ponds = solar evaporation ponds, Tower = power towers receiving reflected sunlight from heliostat mirrors, and Heliostats = mirrors arranged to reflect solar energy to a receiver on power tower.
b
Width of search area to one side of transect.
c
1 | 30 refers to daily searches for 7 consecutive days beginning again every 30 days. d
Fˆ = estimated number of fatalities, F = number of fatalities found, S = proportion of trial carcasses found, r = proportion of trial carcasses persisting to next search, A = proportion of search area that was searchable; empty spaces indicated the reporting was unclear which metric was used.
e
California Valley Solar Ranch. Also performed daily searches for 5 consecutive days once every 4 weeks. f
Used Program Distance (Miller 2016), but none of the models fit the data well. g
Included cleared ground around towers, power blocks, and inner rings of high‐density heliostat mirrors. 8 of 29 | SMALLWOOD
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3 g to 6,000 g, and 144 bat carcasses of 16 species ranging in mass from 2.3 g to 23.6 g (Brown et al. 2016). Trial carcasses were left indefinitely where placed. Whether searchers ever found the carcass determined each trial outcome. I logit‐ regressed trial outcomes of found or not found on log10 body mass (g) to estimate overall detection probability D:

D e
e = 1+ ,
a b log M
a b log M
− +×
− +×
10 10

where a and b were fitted coefficients and M was body mass (Figure 2). I estimated D separately for birds and bats, and among the 3 fatality search intervals that were implemented between the 2 APWRA studies: 5, 7, and 28 days. To simulate a daily search interval, I estimated D from carcass trial placements 1 day prior to the next search (Smallwood 2017a).
(A) (B)
FIGURE 2 Hypothetical fatality estimation from 1 bird of a 10‐g species found at a site where monitors used 78‐g bird carcasses to represent small birds of ≤100 g body mass in on‐site carcass detection trials, and then calibrated to carcass detection trial outcomes on open ground in the Altamont Pass Wind Resource Area (APWRA), California, USA, 2012‒2015, where carcass detection probability was modeled to variation in body mass. A) Predicted probability of carcass detection (D) and 95% confidence intervals based on outcomes of detection trials performed at 7‐day intervals and logit‐regressed on log10 body mass, and overlayed by overall detection measured for 78‐g bird carcasses in on‐site trials at 2 sites (shaded and striped diamond symbols) and in the APWRA (open square) and calibrated to D of the 10‐g bird that was found (oversized circle among mean D). Also overlaid are the detection probabilities derived from trials with 78‐g birds calibrated to that of the 10‐g bird (circles patterned to match symbols representing uncalibrated detection probabilities). B) Resulting fatality estimates (F ) derived from
3 types of adjustment: conventional trials for carcass persistence r and searcher detection S using 78‐g birds to represent small birds, D of a 10‐g bird, and the calibration bridge to introduce the effect of body size on detection probability while preserving the site effect: C = rS g on site D
rS APWRA
1 (× )78 (× )
g
g
10 78


 

  
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Although logit regression calculates asymptotic confidence intervals along with predicted detection probabilities of each body mass used to develop the model, the body masses of fatality finds can differ from those of the trial carcasses used to develop the model. To extend the model's confidence intervals to fatality finds, I fit nonlinear regression models to logit regression's 95% lower and upper confidence limits (Smallwood et al. 2018).

To the 5 studies at solar projects in need of carcass detection probabilities from my offsite studies, D served as ρ in the fatality estimator: F = F
D
  . I assumed that detection probabilities of carcasses placed on open ground depended more on variation in carcass size than on variation in carcass removal rates among project sites. Spatial variation in carcass removal rates remains unknown, but the effect of body mass on detection probability is strong (Figure 2). Given the strong effect of body mass, D served a second purpose in this study. Because I monitored trial carcasses in the APWRA for availability to be found by searchers so that I could also estimate fatalities using the conventional terms r × S, I had the means to calibrate r × S to D , the importance of which is discussed below.

Most fatality monitors at solar projects deployed birds in detection trials that were larger than most of the birds and bats found as fatalities. This practice emerged as a potential bias because the placed birds represented broad size categories in which the body size‐specific detection probabilities of the placed birds would be increasingly discrepant from the detection probabilities of increasingly smaller or larger species found as fatalities in the same broad size category (Figure 2). I therefore adjusted the results of detection trials to account for the effects of variation in body mass. I used integrated, overall detection trials performed in the APWRA to derive a unit‐free scaler to adjust for the effects of variation in body mass on trial outcomes. I formulated a body mass scaler C  as
follows:

C F
rS
D
rS = ×× ith solar project APWRA open ground ,


 







  
With C
 , I adjusted number of fatalities found for overall detection probability r × S based on the monitors' onsite trials, and then I adjusted fatalities by the ratio of overall detection probability D to overall detection probability r × S derived from the same conventional trials using the same‐sized carcasses as at the solar project. In these cases, C 
served as ρ. In the dividend, r × S were from the same‐sized species as r × S in the divisor, thereby serving to bridge the 2 sites, 1 site where D was additionally measured along a continuous range of body mass and the other site where F was additionally measured among species that varied continuously in body mass (Figure 2). This bridge preserved any differences in r and S between the sites. I applied this bridge to onsite detection trials and fatality data from Topaz, Desert Sunlight, McCoy, Midway, Calipatria, Blythe, Genesis, and Ivanpah. I was unable to apply this bridge to data from Stateline, to which I relied solely upon onsite detection trials.

I applied the body mass scaler to bird and bat fatalities where trial outcomes had been lumped into broad size categories. Monitors had performed detection trials for bats at only 1 solar project, but bats were represented by small birds in those trials. The scaling function I used for bats was D for bats relative to r × S for whichever bird species in my study represented small birds at the solar project, and again I relied only on bats and small birds in my study that had been placed on open ground (no occlusion) at Vasco Winds (Brown et al. 2016) or Sand Hill (Smallwood et al. 2018). To represent trial carcasses at solar projects, I selected APWRA bird trial carcasses ranging in size 24–32 g for house sparrows (Passer domesticus), 36–47 g for brown‐headed cowbirds (Molothrus ater), 50–70 g for Japanese quail (Coturnix japonica) chicks, 108–168 g for Japanese quail adults, 260–400 g for rock pigeons (Columba livia), 1,050–1,150 g for mallards (Anas platyrhynchos), and 1,200–2,300 g for ring‐necked pheasants (Phasianus colchicus). For application to fatality monitoring based on 21‐day search intervals, I averaged D between 7‐ and 28‐day intervals on open ground at Vasco Winds.

Only at CVSR were found fatalities sufficiently assigned to sampling units so that other researchers could estimate standard error attributable to variation among sampling units. Consistent with Smallwood et al. (2020), I used the delta method to estimate confidence intervals at CVSR. Otherwise, I relied on logit‐regressed estimates of confidence intervals to represent confidence intervals of fatality estimates. I estimated fatalities of every species 10 of 29 | SMALLWOOD
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represented by ≥1 fatality at operational solar projects. I assumed solar projects caused all fatalities found by monitors, but natural causes likely contributed to a few of the fatalities.

Although I endeavored to reduce the effects of bias on ρ by factoring in fatality detection probability as a function of interspecific variation in body mass, fatality estimates remained amply prone to error and bias (Smallwood 2007). To improve accuracy of fatality estimates going forward, I addressed 3 additional sources of error and probable bias. First, I compared monitoring outcomes between pedestrian and car surveys. I assumed bias would be indicated, though not verified, if estimated fatality rates differed between projects searched by foot and by car. Second, to indicate whether and to what degree wildlife species were represented in fatality monitoring results at solar projects, I related the cumulative number of species represented as detected fatalities by months since monitoring was initiated, similar to the approach used by Beston et al. (2015). To the fatality monitoring data of each project, I attempted to fit a nonlinear model for the purpose of identifying the asymptote of the cumulative number of species represented, and to determine whether the predicted asymptote had indeed been reached.

Third, I tallied fatalities that monitors had assigned to taxa or size groups other than the species level.

RESULTS
Attributes of fatality monitoring studies
Fatality monitoring studies varied greatly in attributes that affect fatality estimates (Tables 2, S1). As examples, fatality searches covered 3.3% to 100% of solar project features, and spanned 0.42 to 5 years in duration. Fatality search intervals ranged 1 to 25 days, but at 2 projects searches were daily for 5 to 7 consecutive days beginning at intervals of 28 to 30 days, respectively. Areas searched from transects varied within maximum distances of 2.1 to 160 m—a 76‐fold range. Distance sampling was used from a transect along the gen‐tie at Centinela, from transects intersecting PV arrays at Centinela, Imperial, Calipatria, Midway, Desert Sunlight, Midway, McCoy, and Blythe, and from transects intersecting SCAs at Genesis. The fatality metric at Topaz was fatalities/plot/search, which was incomparable to fatality metrics reported in other studies. No fatality estimates were reported at Campo Verde and Imperial, and none were reported for bats at Ivanpah.

Studies varied greatly in carcass detection trials needed to accurately represent ρ. Bat detection trials were implemented only at Genesis, where small birds served as surrogates for bats (Table S2). Bird carcasses were placed in all detection trials except for trials along the Centinela gen‐tie, where colorful bird‐shaped holiday ornaments were placed in searcher detection trials. Source of bird carcasses was unreported at all studies except CVSR, which used carcasses from wildlife rehabilitation facilities and fatalities found during monitoring. Two studies neglected to identify species used in detection trials. Monitors at Solar One and Calipatria did not perform searcher detection trials. Monitors at Centinela and Imperial did not perform detection trials of any type. Duration of carcass persistence trials ranged 5 to 42 days. The carcass persistence metric varied but was usually mean days to carcass removal (Table S2).

The majority of birds killed at solar projects were small‐bodied; most were smaller than the bird carcasses used to represent them in detection trials (Figure 3). Of bird species found as fatalities among solar projects, the typical adult body mass of 30% were <22 g, 50% were <42 g, 63% were ≤100 g, and only 22% were at least as large as rock pigeons. Of bird species found as fatalities at 11 PV projects, the typical adult body mass of 30% were ≤25 g, 50% were <56 g, 57% were <100 g, and only 25% were at least as large as rock pigeons. Among 3 projects (McCoy, Blythe, and Desert Sunlight), the smallest species used in small‐bird persistence trials was larger than 73% of the small birds found as fatalities (Figure S1, available in Supporting Information). The smallest species used in medium‐ bird persistence trials was larger than 33% of the medium bird species found. The largest species used in large‐bird persistence trials was smaller than 50% of the large birds found as fatalities. Accounting for the detection probabilities of fatalities of species smaller than detection trial carcasses increased fatality estimates of many small‐bird SOLAR IMPACTS | 11 of 29
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species, but it reduced estimates of a much smaller number of large‐bird species (Figure S2, available in Supporting Information). The onsite‐adjusted fatality estimates bridged to the APWRA's integrated overall detection trials related linearly to onsite‐adjusted fatality estimates without the bridge, indicative of an unbiased adjustment for interspecific variation in body mass (Figure S3, available in Supporting Information).

Body‐size adjusted fatality estimates
My bird fatality estimates exceeded originally reported estimates by factors of 1.07 at Campo Verde, 1.5 at Desert Sunlight, 1.88 at CVSR, 4.59 at McCoy, 6.59 at Blythe, 10.49 at Genesis, 10.5 at Calipatria, and 18–72 at Topaz (Table 3). No project‐wide fatality estimates were reported at Ivanpah, but my estimates for birds at Ivanpah's heliostat mirror arrays and in the tower area exceeded originally reported estimates by factors of 10 and 3.8, respectively.

My estimate of bird fatalities among Ivanpah's heliostat mirrors exceed that of the Tower Area by a factor of 6.2 (Table 3; Figure S4, available in Supporting Information). Some unknown portion of the fatalities found among heliostat mirrors was likely caused by exposure to the zone of solar flux. Bird fatality rates among mirrors at Genesis averaged only 20% of those among heliostat mirrors at Ivanpah. Bird mortality was highest at solar thermal projects (Table 3). On a per‐MW basis, the gen‐tie was the most dangerous project feature to birds at some projects, whereas the PV panels or mirrors were the most dangerous at others. On a project‐wide basis, however, more birds died by collision with solar collectors—mirrors and PV panels. (A) (B)
FIGURE 3 Body size‐distribution of bird fatalities relative to typical body mass of species used in searcher detection and carcass persistence trials (dashed vertical lines) among 13 California solar projects (Solar One not included) monitored 2012‒2018, where the clear zone represents small birds ≤100 g, light gray represents medium birds >100 g to ≤1,000 g, and dark gray represents large birds >1,000 g: A) proportion of estimated number of fatalities (Fˆ ) by 10‐g increments of typical species' body mass, and B) estimated annual fatalities by body mass on a continuous scale. Carcasses of many found fatalities were smaller than the species used in on‐site detection trials 12 of 29 | SMALLWOOD
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TABLE 3 Reported estimates and my own estimates of wildlife fatality rates at California utility‐scale solar energy projects and project features through 2020. I cannot explain the estimates that were not reported by monitors, but I did not estimate fatalities caused by medium‐voltage overhead lines and PV at Topaz because these facilities overlapped to a degree that I could not determine which caused the fatalities Fˆ/MW/year (95% CI)
Project Taxa Featurea Reportedb This study
CVSR Birds Gen‐tie 0.38 (0.32–0.48) 1.27 (0.89–1.93)
CVSR Birds MVOH 0.10 (0.08–0.12) 0.35 (0.26–0.48)
CVSR Birds Fence 0.72 (0.60–0.89) 1.15 (0.85–1.64)
CVSR Birds PV 8.97 (7.33–11.49) 16.17 (11.98–22.05)
CVSR Birds Project 10.07 (8.20–12.92) 18.98 (14.00–26.16) Topaz Birds MVOH 0.0546–0.2159c
Topaz Birds PV 0.0491–0.1909c
Topaz Birds Project 0.1037–0.4068c 7.48 (6.12–11.22)
Campo Verde Birds Fence 0.10 (0.08−0.14)
Campo Verde Birds Gen‐tie 0.50 (0.39−0.78)
Campo Verde Birds PV 20.49 (16.52−31.07)
Campo Verde Birds Project 19.65 21.09 (16.99−32.00)
Centinela Birds Fence 1.82 (1.49–2.77)
Centinela Birds Gen‐tie 1.68c 2.31 (1.7–3.82)
Centinela Birds PV 12.93 22.92 (18.52–34.71)
Centinela Birds Project 28.64 (23.09–43.76)
Imperial Birds Project 9.70 (8.22–14.65)
Calipatria Birds PV 2.1 22.09
Calipatria Birds Project 2.1 22.09
Midway Birds Project 3.22
Desert Sunlight Birds Fence 0.015 (0.005–0.042) 0.03 (0.02–0.03) Desert Sunlight Birds Gen‐tie 1.86 (0.87–4.99) 2.58 (1.68–4.32) Desert Sunlight Birds PV 1.05 (0.88–1.56) 1.68 (1.24–3.19) Desert Sunlight Birds Project 2.93 (2.03–6.67) 4.39 (3.01–7.70) Stateline Birds Gen‐tie 0.457 0.19
Stateline Birds PV 0.387 1.94
Stateline Birds Project 2.13
McCoyd Birds Fence 0.096
(0.016–0.20/8)

0.25 (0.17–0.36)
McCoyd Birds Gen‐tie 3.124 (2.36–4.04) 11.68 (7.19–21.13) McCoyd Birds PV 0.23 (0.04–0.49) 3.88 (2.58–6.04)
McCoyd Birds Project 3.45 (2.66–4.39) 15.83 (9.98–27.60) (Continues)
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TABLE 3 (Continued)
Fˆ/MW/year (95% CI)
Project Taxa Featurea Reportedb This study
McCoyd Bats Project 0.46 (0.01–0.73)
Blythed Birds Fence 0.09 (0.03–0.17) 0.38 (0.28–0.55)
Blythed Birds Gen‐tie 3.32 (2.51–4.30) 16.35 (10.07–28.96) Blythed Birds PV 0.18 (0.009–0.455) 6.67 (4.52–5.75)
Blythec Birds Project 3.59 (2.76–4.60) 23.65 (15.04–35.62) Genesis Bats Fence 0.012 (0.002–0.030) 1.67 (0.11–4.27) Genesis Bats Ponds 0.036 (0.008–0.078) 4.82 (0.13–7.90) Genesis Bats PBlocks 0.002 (0.002–0.006) 2.40 (0.09–4.77) Genesis Bats SCAs 0.052 (0.020–0.092) 0.56 (0.09–3.53)
Genesis Bats Project 0.106 (0.032–0.198) 10.92 (0.48–22.98) Genesis Birds Fence 0.39 (0.25–0.56) 5.63 (4.21–7.70)
Genesis Birds Gen‐tie 1.50 (0.66–2.73) 17.62 (11.26–31.09) Genesis Birds Ponds 0.39 (0.14–0.72) 5.57 (3.98–8.09)
Genesis Birds PBlocks 0.21 (0.13–0.29) 4.93 (3.51–7.06) Genesis Birds SCAs 2.41 (1.90–3.10) 12.93 (9.77–17.86)
Genesis Birds Project 4.56 (3.44–5.84) 47.83 (33.53–73.59) Solar One Birds Heliostats 26.20 (18.70–58.94)
Solar One Birds Tower area 16.24 (9.24–92.42)
Solar One Birds Project 9.88–11.44 42.44 (27.94–151.36) Ivanpah Birds Fence 0.19 (0.13–0.28) 0.58 (0.41–0.83)
Ivanpah Birds Gen‐tie 0.005 0.14 (0.09–0.25)
Ivanpah Birds Others 0.82 (0.45–5.23)
Ivanpah Birds Heliostats 6.41 (4.66–10.38) 63.91 (40.45–141.33) Ivanpah Birds Tower area 2.69 (1.82–4.46) 10.30 (5.79–52.95) Ivanpah Birds Project 75.74 (47.19–200.59)
Ivanpah Bats Tower area 1.79 (0.08–3.70)
a
Project = all features of the project, Fence = perimeter security fence, Ponds = solar evaporation ponds, Gen‐ tie = generation lead or transmission lines, MVOH = medium‐voltage overhead collector lines, PV = solar photo‐voltaic panels; and in solar thermal projects, Heliostats = heliostat mirrors, SCAs = solar collector arrays, Tower area = bare ground between SCAs and the power tower, PBlocks = power blocks, and Others = ancillary structures such as operations and maintenance buildings.
b
90% CI at California Valley Solar Ranch (CVSR) and Genesis. c
I calculated the value based on the reported estimate in terms of a different metric. d
I assumed methods remained unchanged in year 2, but the second‐year report was unavailable. Martinson et al. (2018a,b) reported results only for year 1, whereas I report results for both years 1 and 2. 14 of 29 | SMALLWOOD
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Bat mortality was highest at Genesis, followed by Ivanpah and McCoy. At Genesis, the most dangerous project feature to bats was the solar evaporation ponds, followed by power blocks, fences, and SCAs (Table 3). At Ivanpah, bat fatality estimates were possible only in the tower area, where mortality declined over the 5 years of monitoring (Figure 4). Species exhibiting the largest declines were canyon bat and California myotis (Myotis californicus). An ultrasonic bat deterrence method was implemented at unit 1 on 10 September 2014, and at units 2 and 3 on 23 April 2015.

California‐wide impacts of operative utility‐scale solar projects According to the California Energy Commission, 1,948.8 MW of solar thermal projects operated in California in 2020, and 12,220 MW of PV had been installed by the end of 2019. On average, utility‐scale solar energy projects required 3.48 ha/MW for solar thermal and 2.67 ha/MW for PV. Therefore, utility‐scale solar thermal projects covered 6,782 ha, and utility‐scale solar PV covered 32,627 ha. Projected to California's installed capacity of all utility‐scale solar projects in 2020, mean annual fatalities at monitored projects predicted 267,732 (95% CI = 186,071–495,391) bird fatalities and 11,418 (95% CI = 601–23,926) bat fatalities (Table S3). Only 8 studies reported project‐wide bird fatality estimates, and only 2 of these reported a confidence interval. Only 2 studies at solar thermal projects reported project‐wide bat fatality estimates. Projected to California's installed capacity of all utility‐scale solar projects in 2020, originally reported mean annual fatalities would predict 82,471 birds, but original reporting was insufficient for including a 95% confidence interval or for predicting statewide bat fatalities.

At utility‐scale solar PV projects, my estimates of F
/MW/year averaged 11.61 (95% CI = 8.37–17.56)
birds and 0.06 (95% CI = 0.01–0.10) bats (Table S4, available in Supporting Information). Projected to FIGURE 4 Estimates of annual bat fatalities in the tower area of Ivanpah Solar Electric Generating System, San Bernardino County, California, USA, 2013‒2018, spanning the cleared ground between the power tower and the mirror arrays and including all bats as a group, Mexican free‐tailed bats (Tadarida brasiliensis), canyon bats, and California myotis. Arrows point to years following installations of ultrasonic deterrents at power towers, 1 installation after the first year, and 2 more during the second year. Declines in bat mortality preceded installations of deterrents
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California's installed capacity of 12,220 MW of PV in 2019, my fatality rates predicted annual fatalities of 141,811 (95% CI = 102,227–214,593) birds and 716 (95% CI = 124–1,221) bats. At solar thermal projects my estimates of F
/MW/year averaged 64.61 (95% CI = 41.74–149.95) birds and 5.49 (95% CI = 0.25–11.65) bats (Table S4). Projected to California's installed capacity of 1,948.8 MW of solar thermal in 2020, my fatality rates predicted annual fatalities of 125,921 (95% CI = 81,346–292,225) birds and 10,701 (95% CI = 477–22,705) bats.

Along perimeter fences, I estimated F
 /km/year averaged 14.44 (95% CI = 10.88–20.34) birds and 2.56 (95% CI = 0.17–6.54) bats (Table S4). Projected to California's installed 900 km of fencing around solar projects in 2020, these rates predicted annual fatalities of 13,005 (95% CI = 9,802–18,324) birds and 2,304 (95% CI = 156–5,892) bats. I estimated fatalities along fences averaged almost 5% of birds and 20% of bats killed at solar projects.

Along gen‐ties, I estimated F
/km/year averaged 113.16 (95% CI = 71.78–198.42) birds and no bats (Table S4).

Projected to California's installed 461 km of gen‐ties at solar projects in 2020, these rates predicted annual fatalities of 52,162 (95% CI = 33,087–91,463) birds. I estimated fatalities along gen‐ties averaged 19% of birds and 0% of bats killed at solar projects.

Projected to the 2019 installed capacity, utility‐scale solar PV annually killed more mourning doves (Zenaida macroura) than any other species at 17,043, followed by 10,082 horned larks (Eremophila alpestris), and 7,628 western meadowlarks (Sturnella neglecta), and thousands of other grassland birds (Table S4). The PV panels killed 5,362 American coots (Fulica americana), 4,755 soras (Porzana carolina) among many other rails, grebes, and waterfowl, and 2,224 burrowing owls (Athene cunicularia), 958 American kestrels (Falco sparverius), and hundreds of other raptors. They also killed 1,486 common yellowthroats (Geothlypis trichas), 1,298 yellow warblers (Setophaga petechia), and thousands of additional likely migrants.

Projected to the 2020 installed capacity, utility‐scale solar thermal projects annually killed more unidentified small birds than any individual species, at 10,716. Solar thermal killed 8,118 canyon bats and members of ≥8 other bat species (Table S4). It killed likely migrants, including 7,043 yellow‐rumped warblers (Setophaga coronata), 5,582 yellow warblers, 4,470 Costa's hummingbirds (Calypte costae), and thousands of birds of other species. It killed many grassland and desert scrubland birds, including 3,678 white‐crowned sparrows (Zonotrichia leucophrys), 3,506 American pipits (Anthus rubescens), 3,116 western meadowlarks, and 1,498 loggerhead shrikes (Lanius ludovicianus).

I estimated that in 2020 fences surrounding solar projects killed 1,783 canyon bats, 1,385 western meadowlarks, 1,174 greater roadrunners (Geococcyx californianus), and 476 northern flickers (Colaptes auratus; Table S4). Fences also killed an estimated 226 burrowing owls, 172 yellow‐headed blackbirds (Chrysomus icterocephalus), and 108 northern harriers (Circus hudsonius).

I estimated that in 2020 gen‐ties of solar projects killed 8,425 Wilson's warblers (Cardellina pusilla), 7,144 Brewer's sparrows (Spizella breweri), 3,364 common yellowthroats, 2,031 yellow warblers, 899 loggerhead shrikes (Lanius ludovicianus), 241 American kestrels, and 195 red‐tailed hawks (Buteo jamaicensis; Table S4).

Fatalities at operational projects represented ≥8 bat species and ≥192 bird species. Of the 10 species of bats represented by fatalities at solar projects, 3 were California species of special concern. Western Bat Working Group ranked 4 species as high and 2 as moderate conservation priority. Of species of birds represented by fatalities at solar projects, 2 were listed as threatened or endangered under the federal or California Endangered Species Acts. California Fish and Game Code 3503.5 (i.e., birds of prey) protected ≥20 species, and additional statutes protected 8 of these species. Two bird species were California fully protected, and another 36 species were listed as a United States Fish and Wildlife Service bird species of conservation concern or California species of conservation concern, or listed on California's Watch List. Of species listed as California species of special concern, 8 were priority level 3, 9 were priority level 2, and 2 were priority level 1 (2 species were assigned no priority level). Including raptors, 45 special‐status species of vertebrate wildlife were documented as fatalities of utility‐scaled solar projects, or 23% of all species represented by fatalities. 16 of 29 | SMALLWOOD
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Additional sources of error and bias
The PV solar projects were searched by foot (n = 6) and car (n = 5), whereas SCAs at Genesis were searched by car, and power tower projects were searched by foot. Estimated fatalities differed between foot and car searches at PV projects (t9 = 2.44, P = 0.037), with respective means of 15.14 F /MW/year and 5.08 F/MW/year.

To indicate whether and to what degree wildlife species were represented in fatality monitoring results at solar projects, I fit nonlinear models to the cumulative number of species represented by fatalities with increasing number of months into the study at 5 projects that were monitored more extensively in space and time (Table 4).

The monitoring data from Ivanpah served to exemplify not only the asymptotic nature of species representation with monitoring duration, but also the effect of a change in search coverage (Figure 5A). Monitoring effort substantially lessened after 24 months when the monitor terminated fatality searches along the gen‐tie and fence and reduced search coverage among heliostat arrays from 24.1% to 8% (0% in the fifth year). Subsequent to the reduced search effort, the increase in number of additional species represented by fatalities was slower than predicted by the pattern in the data through 24 months (Figure 5A). Where fatality monitoring lasted long enough, the pattern in the data revealed how much longer it would have taken at sustained search efforts to achieve asymptotes in species representation by fatalities (Figure 5B). Fatality monitoring at 5 projects was too brief to reveal anything other than a linear increase of species with increasing monitoring duration (Figure 5C). The regression slopes of Blythe and McCoy were nearly identical (Figure 5C). These 2 projects were adjacent to each other, and monitored by the same consulting firm. But even after 2 years of monitoring and documentation of >50 species as fatalities, the pattern of increasing cumulative species represented by fatalities hinted of no imminent arrival to an asymptote. I could not fit a model to the cumulative number of species represented by fatalities with increasing number of months into the study from 4 PV projects. The MW‐years sampled among these 4 projects averaged only 11.4% of MW‐years at the other 7 PV projects, a significant difference (F1,9 = 22.76, P = 0.001).

Species represented by fatalities were often vulnerable to biased fatality estimates because of misrepresentation. Monitors did not identify nearly 22% of fatalities to species, and identified them instead to coarser levels such as genus, subfamily, small, medium, or large bird, or as unknown bird or bat (Table 5). The coarser the reported level of identification, the more I applied detection probabilities derived from lumped representations of body mass. For example, the degraded carcass of a Pacific‐slope flycatcher (Empidonax difficilis) found by a weekly TABLE 4 Best‐fit models of cumulative vertebrate species detected as fatalities at California, USA, utility‐scale solar projects relative to the number of months since the fatality monitoring began, where model 1 was of the form Y =+× abX, and model 2 was of the form Y = abc
1 +× log X 10
Project Model
Coefficients
r
2 RMSEa a bc
California Valley Solar Ranch 2 0.0157 0.4970 0.0490 0.99 51.34 Topaz 2 0.0032 0.2229 0.2548 0.96 266.20
Campo Verde 2 0.0096 0.2435 0.1401 0.97 81.30
Desert Sunlight 1 –2.5714 3.3571 0.96 1.44
Stateline 1 0.8 0.55 0.92 0.67
McCoy 1 3.2029 2.0804 0.96 1.44
Blythe 1 2.0000 2.1700 0.98 1.02
Genesis 2 0.0097 0.2305 0.0017 0.98 311.57
Ivanpah 2 0.0061 0.1762 0.0406 0.99 300.49
a
RMSE = root mean square error.

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(A)
(B)
(C)
FIGURE 5 Cumulative number of vertebrate species detected as fatalities, California, USA, 2012‒2018: A) during the first 2 years of monitoring (open circles) and last 3 years of reduced monitoring effort (filled circles) at the Ivanpah Solar Electric Generating System, San Bernardino County, California, along with best‐fit model to the first 2 years of data and projected to the last 3 years of monitoring; B) among solar projects where fatality monitoring lasted long enough to predict an asymptote of species represented by fatalities (vertical bars indicate duration of monitoring used to project the nonlinear pattern in the data); and C) among solar projects where fatality monitoring had not lasted long enough to predict an asymptote, and therefore insufficiently represented species affected.

Survey effort largely determined the number of species represented by found fatalities 18 of 29 | SMALLWOOD
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search on open ground might have been reported as a small bird. I assigned D = 0.197 to small birds, which was the value predicted for house sparrows–the smallest species placed in small‐bird detection trials among solar projects.

Had the Pacific‐slope flycatcher been accurately identified to species, it would have been adjusted by D = 0.10, resulting in twice the estimated fatality rate.

The same bias applies to bats. As one of the most often‐found bats among solar projects, canyon bats likely contributed most often to bats found and identified as unknown bat. At wind projects, an unknown bat would typically be adjusted using an overall detection probability quantified from the placements of all bats in carcass detection trials. I therefore used the mean from such trials to represent unknown bats with D = 0.1008. Overall detection for canyon bat was D = 0.0485. Again, had searchers been able to identify canyon bats to species instead of unknown bats, and assuming most of the unknown bats were canyon bats, each of these bats' contribution to bat fatality estimates would have doubled.

At Centinela, 47% of fatalities were not identified to species (Table 5). Other projects where monitors could not identify many fatalities to species included Solar One and Ivanpah at 28.8% and 27.7%, respectively. Projects where all fatalities were identified to species were surveyed briefly by car, including at Imperial where fatalities of only 4 large‐sized bird species were found, and at Stateline where fatalities of only 9 species were detected.

DISCUSSION
I largely achieved my study objectives. Original reports of fatality monitoring did not always provide fatality estimates for project features and whole projects, but of those that did, I compared my independent estimates to theirs. From my estimates of project‐level fatalities, I estimated statewide fatalities based on the installed capacity TABLE 5 Species of wildlife identified as fatalities among California's utility‐scale solar energy projects, USA, 1982‒2018, and the percentages of estimated fatalities (F ) that could and could not be identified to species
Solar project
Number of species
represented by fatalities
Percent of F
/MW/year of F
Identified Not identified
California Valley Solar Ranch 43 96.8 3.2
Topaz Solar Farm 17 95.3 4.7
Campo Verde Solar Project 45 81.4 18.6
Centinela Solar Energy Project 24 53.0 47.0
Imperial Solar Energy Center South 4 100.0 0.0
Calipatria Solar Project 13 77.8 22.2
Midway Solar Farm II 4 76.1 23.9
Desert Sunlight Solar Farm 53 83.3 16.7
Stateline Solar Farm 9 100.0 0.0
McCoy Solar Energy Project 49 79.9 20.1
Blythe Solar Power Project 54 82.6 17.4
Genesis Solar Energy Project 97 81.3 18.7
Solar One 25 71.2 28.8
Ivanpah Solar Electric Generating System 147 72.3 27.7
All projects 200 78.3 21.7
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of utility‐scale solar projects in 2020, and I did so per each project feature. An exception was for medium‐voltage overhead lines, which deposited bird carcasses too close to PV solar arrays to discern whether the fatalities were caused by collisions with the overhead lines or the PV solar arrays. I compared fatality rates among species of birds and bats, and among those with special status. I also identified sources of error and bias to alert investigators to research directions needed to improve accuracy of fatality estimation.

To achieve my study objectives, I assumed that the fatality data and carcass detection trial data I obtained from natural resource agencies were accurately reported. I assumed that I accurately interpreted reported study methods and descriptions of solar projects. Data inaccuracies or misinterpretation of methods would have diminished the accuracy of my independent fatality estimates. For biases and large sources of error that I understood from previous research on fatality estimation at wind energy projects, I endeavored to mitigate them by applying adjustment factors. For methods I believed were inappropriate, such as searches for fatalities from cars, I examined the data for evidence of bias and for opportunities to mitigate the effects of bias. I also applied a bridge from my study of the effects of variation in body mass on overall carcass detection probability to account for the disparity I found between carcasses placed in detection trials and those found as fatalities at solar projects. My estimates of fatalities at solar projects were as accurate as I could achieve but undoubtedly inaccurate to some unknown degree. Potential for inaccuracy was greatest for the smallest birds and bats. On the whole, I suspect I more often underestimated rather than overestimated fatality rates. My fatality estimates nevertheless indicate the magnitude of impacts caused by utility‐scale solar projects in California, and they can serve as a collective starting point for improving methods to increase accuracy of fatality estimates.

I estimated that by 2020 annual fatalities exceeded a quarter million birds and 11,000 bats at California solar projects. My statewide fatality estimates were based on the available, nonrandom pool of monitored projects, which means they were vulnerable to geographic biases of unknown direction. At the same time, the fatality monitoring performed to date has been prone to substantial biases that largely resulted in underestimation of fatalities. Earlier estimates of regional fatalities were much lower than mine. At PV and solar thermal projects in California, Walston et al. (2016) estimated a weighted mean 9.9 bird fatalities/MW/year, whereas I estimated a weighted mean 18.9 bird fatalities/MW/year. At solar PV projects, Kosciuch et al. (2020) estimated 2.49 bird fatalities/MW/year, whereas I estimated a mean 11.6 bird fatalities/MW/year without adding fatalities caused by perimeter fences and gen‐ties. The earlier regional estimates used reported estimates without sufficiently accounting for the effect of body mass on carcass detection probability. They also relied on project‐level estimates exclusive of the many species represented by F < 5, and because many of these excluded species were small‐ bodied, under‐estimation of F
 had been exacerbated. For these reasons, my fatality estimates were larger, but other biases indicate fatality estimates could be even larger. As examples, the monitors' use of cars for fatality searches and insufficient survey effort both appear to have negatively biased F  . Omitting the 7 fatality monitoring
studies that were either based on car surveys or cursory effort, the weighted mean increases 1.25‐fold from 11.605 to 14.51 bird fatalities/MW/year among PV projects.

Background mortality (i.e., mortality caused by natural processes) was often suggested as the source of fatalities for which cause of death could not be assigned (Kosciuch et al. 2020), but no reports raised the possibility of crippling bias, the rate of mortally injured animals leaving the search area undetected (Smallwood 2007). Some unknown number of animals mortally injured by exposure to the zone of solar flux, electrocution, or collision likely died, undiscovered, far from study areas. The very background mortality studies discussed by Kosciuch et al. (2020) and reported in (2013) and Althouse and Meade (2012, 2014) likely counted fatalities representative of both crippling bias and background mortality because the background mortality monitoring plots were adjacent to the solar energy projects. These studies could have lessened confounding had they begun monitoring ≥1 year in advance of project construction, and had they located study plots farther from the project to minimize counting of remains of birds that had been displaced by construction and rendered more vulnerable to predation and competition.
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Estimates of solar energy's impacts could be more complete by monitoring for fatalities along transmission lines constructed to accommodate the projects. Transmission lines kill many birds, mostly from collisions but also electrocutions. Loss et al. (2014) estimated 29.6 bird collision fatalities/km/year (95% CI = 9.3–66.4) in the United States based on a mix of studies with and without adjustment by ρ. Rioux et al. (2013) estimated 110.4 bird collision fatalities/km/year (95% CI = 43.5–177.2) across Canada after adjusting by ρ. Avian fatality rates along transmission lines have been rarely studied in California. The only study of which I was aware was at Mare Island in Solano County (Hartman et al. 1992). Weighted mean fatality rates along gen‐ties servicing solar projects (Table S4) could serve to estimate annual fatality rates along transmission lines that deliver power from solar projects, so long as one knows the length of transmission lines that do so.

Impacts of habitat loss
Estimates of solar energy's impacts could be more complete by also measuring numerical losses of wildlife populations caused by habitat loss. Project sites should be studied prior to construction to estimate densities in breeding and non‐breeding seasons, and to measure migratory activity levels, which based on isotopes in feathers collected from dead birds found at solar projects, appears high (Conkling et al. 2020). Wildlife use of the site could be compared before and after project construction and concurrent with studies of wildlife at reference sites.

By 2020 the installed capacity of solar energy projects covered 39,409 ha in California, including 25,453 ha (64.6%) in the Mojave and Sonoran deserts. Construction grading for these projects removed all native vegetation, which continued to be suppressed through project operations. Utility‐scale solar projects destroyed habitats of many wildlife species by eliminating breeding sites and forage. No studies were performed to estimate breeding and nonbreeding densities in advance of construction grading at any of the projects I reviewed. No efforts were made to estimate potential reductions in reproductive and numerical capacities of wildlife species.

Estimates of total bird nesting density are available, along with species‐specific density estimates, for indicator‐ level analysis of impacts. Bird nesting densities of 13.27 and 14.19 nest sites/ha were estimated at study sites composed of grassland, wetland, and woodland (Young 1948, Yahner 1982). Assuming 6.94 nest sites/ha, or half the average of Young's (1948) and Yahner's (1982) densities, would more realistically represent California's annual grasslands, this density multiplied against California's 12,414 ha of utility‐scale solar in non‐desert environments would predict a loss of 86,153 bird nest sites.

Franzeb (1978) provided a basis for applying bird breeding density to areas lost to solar projects in California's deserts. Franzeb (1978) estimated 0.366 breeding birds/ha at a Sonoran Desert site. Projected to 25,453 ha of California's desert environments, this density would estimate 9,316 breeding birds, or 4,658 nest sites, were lost to construction grading for solar projects. Added to the estimate above for non‐desert environments, I estimate that California solar projects displaced 90,811 bird nests by 2020. Assuming 25 years of operational impacts, and assuming an average fledging of 2.9 birds/nest/year (Young 1948) and a generation time of 5 years, the lost capacity of breeders and annual chick production would be 7,491,908 birds: {[nests/year × chicks/nest × number of years] + [2 adults/nest × nests/year × (number of years ÷ years/generation)]}. Averaged over 25 years of project operations, this indicator‐level approach would estimate an annual loss of 299,676 birds due to habitat destruction to accommodate California's 2020 installed capacity of utility‐scale solar.

Burrowing owls, in particular, face significant impacts from habitat loss caused by development of utility‐scale solar. Burrowing owls happen to select terrain conditions for breeding and foraging that are also sought by developers of solar projects: flat to gentle southwest‐ or south‐facing slopes. In the 1990s, an estimated 71% of California's entire burrowing owl population resided within the Imperial Valley, after the species had declined throughout the rest of its range in California (DeSante et al. 2007). The average density of breeding attempts was

8.13/km2 (0.081/ha). With 1,488.5 MW of solar PV installed in Imperial County as of 2019, and with an average

2.67 ha/MW, utility‐scale solar in Imperial County destroyed 3,974.3 ha of burrowing owl habitat. Assuming the SOLAR IMPACTS | 21 of 29
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estimate of burrowing owl breeding density from DeSante et al. (2007) still applies, I estimate this level of habitat loss reduced the capacity for breeding attempts by 322 and the number of breeding adults by ≥644. Assuming an average generation time of 8 years and an average 3 chicks produced/breeding attempt, the equation in the preceding paragraph would estimate an annual loss of 1,073 burrowing owls due to habitat loss.

Another form of habitat loss, or habitat degradation, was project‐generated wildfires. In June 2019, a bird landed on a power pole at CVSR, sparking a 486‐ha fire that removed 84% of the project's generating capacity. The fire reportedly did not damage solar panels, but it likely destroyed many bird nests on the grasslands that were burned next to the project.

Combined impacts to birds from collision mortality and habitat loss Assuming utility‐scale solar projects eliminate breeding habitat within the project footprint, then post‐construction collision mortality is largely to migrants or residents of adjacent habitat. If true, then I estimated the installed capacity of utility‐scale solar in 2020 removes from California >500,000 birds/year because of combined effects of collision mortality and loss of birds to habitat destruction. Over 25 years of operations of this installed capacity, I estimated California's loss of birds will be >12.5 million. I estimated just over half of this mortality was attributable to habitat destruction (53%), and the rest to operative solar energy projects, but source‐specific magnitudes of impacts likely would vary interspecifically.

For burrowing owls in particular, the estimated mean 0.182 collision fatalities/MW/year at solar PV projects applied to 1,488.5 MW of solar PV installed in Imperial County as of 2019 would estimate 271 burrowing owl fatalities/year in Imperial County, where most of California's burrowing owls live. Combined with the estimated impact of habitat loss, I estimate utility‐scale solar in Imperial County removed 1,344 burrowing owls annually as of 2020. With an estimated 5,600 burrowing owls in the Imperial Valley in the 1990s, my estimated loss could prove devastating for burrowing owls in Imperial Valley.

Avian mortality at utility‐scale solar projects might contribute cumulatively to an ongoing substantial decline of birds in North America (Rosenberg et al. 2019). Bat mortality at solar projects contribute cumulatively to increasingly large nationwide impacts to bats caused by wind turbines (Smallwood 2020). That many of the birds and bats killed at solar projects were special‐status species should heighten concern over the ecological and economic impacts of solar energy‐caused mortality. A suite of errors and biases suppress understanding of the ecological impacts of solar projects and how to mitigate them.

Additional sources of error and bias in collision fatality estimates Fatality monitoring efforts not only varied greatly among solar projects, but they introduced biases that resulted in inaccurate fatality estimates. Monitoring that lasted <1 year or covered small portions of a project likely generated incomplete lists of affected species and hence inaccurate fatality estimates. Searches of PV projects by car yielded a third of the fatality estimates of searches of PV projects by foot. No studies performed car surveys simultaneously with pedestrian surveys. Perhaps the most substantial bias was the use of carcasses in detection trials that were larger than many of the birds and bats found as fatalities. I endeavored to offset this latter bias, whereas I identified most others as likely. I also identified additional sources of error and bias that cannot be quantified without further effort on the parts of monitors going forward.

Monitors recorded fatalities of nonvolant wildlife at only 1 project. Either nonvolant animals died only at the 1 project or monitors ignored them at other projects. In another example of potential bias, monitors removed all fatality finds to prevent double counting of fatalities. If this practice altered forage availability and hence scavenger removal rates of carcasses placed in detection trials, then bias was possible. Omissions of fatalities found 22 of 29 | SMALLWOOD
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incidentally to routine searches introduced potential bias when those discoveries occurred on search plots. Also, where monitors searched daily for 5 to 7 consecutive days at beginning of monthly intervals, difficult decisions were necessary over how to treat fatalities found on the first day of each daily search sequence. Another potential bias was the practice of placing feather piles in bird carcass detection trials because doing so increased carcass persistence by offering scavengers inedible body parts that normally would not occur without flesh and bone upon a bird's death.

Monitors could not identify a fifth of all fatalities to species, which means they likely misidentified fatalities such as Allen's hummingbird (Selasphorus sasin) and rufous hummingbird (Selasphorus rufus). Such errors affect 2 species at once, the species inaccurately assigned the fatality and the species inaccurately denied it. Factors that diminish one's ability to identify fatalities to species include inexperience, insufficient motivation to examine remains carefully enough to identify them, and too much time between fatality searches. As search interval lengthens, more carcasses degrade to the point of becoming less recognizable to species. A related factor is lower detection probabilities of certain search methods. Human searchers miss more carcasses than do scent‐detection dogs (Smallwood et al. 2020), and judging from the 3‐fold difference in fatality rates between car and pedestrian surveys, searchers in cars likely miss more carcasses than do searchers on foot. Missed carcasses can later be found, but the delay in detection allows carcasses to be scavenged and decay, thereby increasing the likelihood they will not be identified to species. Species identification errors could not be fully quantified without viewing photographic evidence or preserved remains of all fatality finds. Such evidence was not forthcoming in responses to PRA and FOIA requests to state and federal agencies.

Mitigation measures and recommendations
Other than measures implemented to minimize hazards along powerlines, little testing was performed of candidate mitigation measures to minimize or reduce collision fatalities with solar collectors. Nearly all projects implemented mitigation measures to minimize bird collision mortality with gen‐ties and medium‐voltage overhead lines, and 1 implemented a measure to minimize avian collisions with solar PV panels (Dudek 2018b). At CVSR, for example, the gen‐tie and medium‐voltage overhead lines were fitted with Swan‐flight Diverters SFD1520 during fatality monitoring (H. T. Harvey & Associates 2013). An ultrasonic acoustic deterrent was also implemented at Ivanpah's Unit 1 on 10 September 2014 and on 23 April 2015 at both Units 2 and 3 to reduce bat exposure to the zone of solar flux.

The deterrent, however, was installed without experimental design elements that would have supported a conclusive hypothesis test of whether the deterrent reduced fatalities. Although bat fatalities declined throughout the study (Figure 4), the largest declines preceded installations of deterrents, which left the possibility that bat numbers were initially depleted by project‐caused mortality. Although guidance had been prepared on how to perform experiments to test mitigation efficacy (Sinclair and DeGeorge 2016), none of the mitigation measures were implemented along with sufficient experimental design to convincingly test the measure's efficacy.

Considering the objectives of fatality monitoring and mitigation measures implemented at utility‐scale solar projects, and considering what needs to be known of solar energy impacts to wildlife, I recommend the following changes and additions to wildlife studies: 1) perform baseline studies beginning ≥1 year prior to project construction to quantify relative abundance, densities in both breeding and nonbreeding seasons, and behavior patterns of resident and migratory wildlife species; 2) repeat fatality monitoring at projects where it was performed inadequately; 3) either monitor all new utility‐scale solar projects for fatalities, or sample projects from the available pool of projects to obtain region‐wide fatality estimates; 4) improve scientific access, transparency, and data sharing; 5) introduce peer review as a required standard of report preparation; 6) increase methodological standardization where it is most needed; 7) minimize fatality search intervals or use scent‐detection dogs (Paula et al. 2011, Mathews et al. 2013, Smallwood et al. 2020); 8) treat incidental fatality finds just like those found in scheduled searches, so long as they were located on sampling plots; 9) whenever trying a new search method, SOLAR IMPACTS | 23 of 29
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compare it to the conventional method through concurrent implementation of methods on, minimally, a suitable subsample of the search area; 10) integrate carcass detection trials into routine fatality monitoring, using appropriate species to quantify overall detection probability (Smallwood et al. 2018); 11) quantify and report observer error rates associated with monitoring, such as carcass detection rates and species misidentifications; 12) report species‐specific use rates and fatality rates in addition to use rates and fatality rates of all birds and all bats; and 13) implement tenets of experimental design to test hypothesized causal factors and the efficacy of mitigation measures (Sinclair and DeGeorge 2016, Smallwood and Bell 2020a).

Based on the impacts I quantified in this review, my first recommendation on performing baseline studies is of high priority. The reports I reviewed were overly focused on collision mortality and paid no attention to impacts of habitat loss. Whereas collision mortality is substantial, more animals are lost to habitat destruction caused by the development of utility‐scale solar projects. Resource agencies and permitting authorities need to view the impacts and how to mitigate them more comprehensively. I suggest directing 2 to 3 times more effort into measuring and mitigating habitat impacts than collision impacts. I suggest implementing macro‐siting strategies, and I note that I saw amid the data and reports I received via PRA and FOIA requests no evidence of siting to minimize impacts to wildlife. One strategy would be to site projects to avoid migration clusters or locations where rare or declining populations of particular species occur (Ruegg et al. 2020). Another would be to site projects to minimize collision mortality of all birds and bats, and yet another would be to site to minimize loss of breeding sites.

I suggest the formulation of a research fund to assess impacts of habitat loss, explore methodological improvements to more accurately predict and estimate impacts, quantify the effects of causal factors, and test the efficacy of mitigation measures. An example of research that would vastly improve understanding of causal factors of collision mortality would be surveys performed by behavioral ecologists. As in wind energy projects, the most effective means to learn of the circumstances of fatalities is to study animal behavior in the context of the project specific to birds (Hoover and Morrison 2005, Smallwood et al. 2009a,b; Hull and Muir 2013) and bats (Horn et al. 2008, Cryan et al. 2014). In my experience, careful observation of living animals can determine collision factors more effectively than can collections of dead animals (Smallwood et al. 2017, Smallwood 2017b, Smallwood and Bell 2020a,b). Lastly, I suggest follow‐up measures to reduce and compensate for impacts revealed by monitoring.

MANAGEMENT IMPLICATIONS
In light of the magnitudes of solar energy impacts to wildlife, it would be prudent to slow the development of utility‐ scale solar projects long enough to formulate more accurate impacts assessments and more effective project decision‐making, mitigation, and oversight. More than sufficient capacities exist for distributed generation and energy conservation to compensate for the time needed to develop policies and methods for safer development of utility‐scale solar energy. Time is needed to develop decision‐making frameworks that compare costs and benefits of solar technology, such as solar thermal versus PV, and alternative project locations. Time is needed to improve fatality monitoring and measurement of impacts, including routine implementation of baseline studies. Time is also needed to develop a more transparent oversight process, along with consequences for exceedance of mortality thresholds or for failing to meet standards of baseline studies and fatality monitoring.

ACKNOWLEDGMENTS
I thank N. L. Smallwood for organizing information from numerous reports and data provided in response to PRA and FOIA requests, and L. Neher for help with a geographic information system. I thank all those biologists who painstakingly searched for fatalities at solar projects. The paper benefited from the help of 2 anonymous reviewers.

CONFLICT OF INTEREST
The authors declare that there are no conflicts of interest. 24 of 29 | SMALLWOOD
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DATA AVAILABILITY STATEMENT
Data available in article supplementary material and in cited reports. Cited reports of fatality monitoring are also available from the author on request.

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Associate Editor: Courtney Duchardt.

SUPPORTING INFORMATION
Additional supporting information may be found in the online version of the article at the publisher’s website.

How to cite this article: Smallwood, K. S. 2022. Utility‐scale solar impacts to volant wildlife. Journal of Wildlife Management e22216. https://doi.org/10.1002/jwmg.22216 SOLAR IMPACTS | 29 of 29
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Oxnard Planning Commission Agenda October 20, 2022
Item F. 1. Public Hearing Port of Hueneme Outdoor Vehicle Storage Facility Comments: FEIR and Special Use Permit
Submitted by Shirley Godwin [email protected]
The EIR consultants have minimized the impacts of locating this facility at this particular location. While Hueneme Road is not designated a State or City scenic highway, it is designated as part of the Coastal Scenic Drive which extends from PCH (HWY1) along Hueneme Road, continuing through the City of Port Hueneme and heading north. It is also the Coastal Bikeway Route. Signs are posted along the way. Therefore, if the landscaping, chain link fencing and cloth wrapping are not maintained, this site will become a visual blight.

The consultants state that it will be maintained because the Special Use Permit requires that the site meet Oxnard’s 1986 landscape maintenance requirements or legal action will be taken. Unfortunately, the City has found this difficult. For example, the City has been unable to get the private property owner of the Halaco plant site on Perkins Road to even clean up the perimeter of the property.

I’m including 4 photos that I took as examples of chain link fencing in Oxnard with weeds and torn cloth wrap or slats: the busy intersection at the NW corner of Saviers Road and Pleasant Valley and two properties on Arcturas Ave. used by customers of the Port of Hueneme. These properties have remained in this blighted condition for about 10 years.

Another issue with using this 34 acre site for vehicle storage is the proximity to the Ormond Wetlands Preserve. The project description states that the land to the south of the proposed project is “vacant.” That property is owned by The Nature Conservancy and part of the Ormond Restoration area with restoration planning by The Nature Conservancy, the State Coastal Conservancy and the City of Oxnard as partners. TNC gives educational tours of their property and plans call for nature trails, signage and public access.
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NW corner of Saviers Road and Pleasant Valley Road

OCTOBER 16, 2022 OCTOBER 16, 2022

OCTOBER 16, 2022 OCTOBER 16, 20
6001 Arcturas Ave. 5980 Arcturas Ave.
633
October 20, 2022
Re: Public Hearing: Port of Hueneme - Temporary Outdoor Vehicle Storage Facility
Dear Oxnard Planning Commissioners,
The Community Environmental Council (CEC), founded in 1970, has worked for over 50 years to pioneer environmental solutions in California. For the last 15 years we have focused on building on-the-ground momentum to reverse the threat of the climate crisis, working most closely in Ventura, Santa Barbara, and San Luis Obispo counties. Our programs work across energy, transportation, and buildings to mitigate carbon emissions, sequester carbon in natural and working lands, and build equitable climate resilient communities.

CEC has reviewed the Final EIR and the staff recommendation to proceed with the Temporary Outdoor Vehicle Storage Facility; however, CEC urges the Oxnard Planning Commission to reject the FEIR and to vote NO on the proposed expansion of the Port.

CEC has collaborated on several projects and initiatives in Oxnard and the broader Ventura County region to advance building electrification, plan for and scale EV adoption, and build out EV charging infrastructure. CEC has supported, and commends, the City on its decision to join the Clean Power Alliance, draft a strong Climate Adaptation Plan, and conduct a Sustainable Transportation Plan. Additionally, CEC has worked closely with the Port of Hueneme for years to support and collaborate on their electrification efforts from supporting the installation of EV charging stations on site, to assessing the feasibility of electrifying the goods movement vehicles that work with the Port. Our mission is to accelerate these and other efforts community wide.

However, our intention is to ensure that this work is done equitably, in a way that builds community resilience and does not reinforce existing systemic inequities.

The communities of South Oxnard have long been burdened with the impacts of an industrialized coastline. They have fought to ensure that their families and neighbors no longer have to live in sacrifice zones, where their health and well-being are considered a necessary trade off in the name of economic progress.
634
CEC cannot support expansion of the Port in the absence of a strong target for electrification, stronger workforce opportunities and protections for jobs that would be created, and a full analysis of the potential near- and longterm pollution impacts from increased trucking and car trips on already impacted region.

We urge the Planning Commission to affirm the agency of the people of South Oxnard to take an active role in shaping the resilient future that is right for their particular community - even if that choice might seem at odds with the system they are operating in. We urge the Planning Commission to fully consider the impacts of increased diesel trucking in the neighborhoods surrounding the proposed project area. We urge the Planning Commission to consider the options that community members and CBOs in the region have uplifted as alternatives to the current proposal.

We thank you for the opportunity to comment on this project.

Respectfully,
Jennifer Hernandez
Climate Justice Manager
Community Environmental Council
635
10/20/22, 9:31 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747166115317489885&simpl=msg-f%3A17471661153… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
'alicia gallegos' via Planning <[email protected]> Wed, Oct 19, 2022 at 5:57 PM Reply-To: alicia gallegos <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Alicia Gallegos
Sent from my iPhone
636
10/20/22, 9:31 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747167455873408376&simpl=msg-f%3A1747167455… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Kimberly Rice <[email protected]> Wed, Oct 19, 2022 at 6:18 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancercausing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Kimberly Rice
637
10/20/22, 9:32 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747169610034500599&simpl=msg-f%3A1747169610… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Eva Reynoso <[email protected]> Wed, Oct 19, 2022 at 6:52 PM To: [email protected]
Dear Oxnard Planning Commissioners, I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34- Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods. It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage. The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term high-paying union jobs in our community. The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime. Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks. This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!
Sincerely, Eva Reynoso
638
10/20/22, 9:32 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747169631510986131&simpl=msg-f%3A1747169631… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Aylin Fernandez <[email protected]> Wed, Oct 19, 2022 at 6:53 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.
639
10/20/22, 9:32 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747169631510986131&simpl=msg-f%3A1747169631… 2/2 This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!
Sincerely,
Aylin Fernandez
This is a student email account managed by Oxnard Union High School District. The contents of this email are governed by the laws of the state and the board policies of the school district. 640
10/20/22, 9:32 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747170089056664183&simpl=msg-f%3A1747170089… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Zaide Pasion <[email protected]> Wed, Oct 19, 2022 at 7:00 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.
641
10/20/22, 9:32 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747170089056664183&simpl=msg-f%3A1747170089… 2/2 This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!
Sincerely,
Zaide Pasion
642
10/20/22, 9:33 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747170401628130074&simpl=msg-f%3A1747170401… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Tara Robinson <[email protected]> Wed, Oct 19, 2022 at 7:05 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Sent from my iPhone
643
10/20/22, 9:35 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747170410574822365&simpl=msg-f%3A1747170410… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Aracely Marin <[email protected]> Wed, Oct 19, 2022 at 7:05 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Sent from my iPhone
644
10/20/22, 9:36 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747170414043896405&simpl=msg-f%3A1747170414… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Zac Sherar <[email protected]> Wed, Oct 19, 2022 at 7:05 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
645
10/20/22, 9:37 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747170430135217280&simpl=msg-f%3A1747170430… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Trinity Tran <[email protected]> Wed, Oct 19, 2022 at 7:06 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Sent from my iPhone
646
10/20/22, 9:37 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747170439082783150&simpl=msg-f%3A1747170439… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Amanda Immer <[email protected]> Wed, Oct 19, 2022 at 7:06 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods. It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage. The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term high-paying union jobs in our community. The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime. Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks. This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!
Sincerely,
Amanda I.
647
10/20/22, 9:37 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747170460487583729&simpl=msg-f%3A1747170460… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Hattie Ellison <[email protected]> Wed, Oct 19, 2022 at 7:06 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
648
10/20/22, 9:39 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747170474326654457&simpl=msg-f%3A1747170474… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Jorge Palafox <[email protected]> Wed, Oct 19, 2022 at 7:06 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Jorge Palafox
649
10/20/22, 9:39 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747170493190933880&simpl=msg-f%3A1747170493… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Andie McNeil <[email protected]> Wed, Oct 19, 2022 at 7:06 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.
650
10/20/22, 9:39 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747170493190933880&simpl=msg-f%3A1747170493… 2/2 This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!
Sincerely,
Andie McNeil
651
10/20/22, 9:39 AM City of Oxnard Mail - [Ask Planning Action] Subject: 10/20 Public Hearing-Public comment to Vote NO on the The Port of Huene… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747170505980181584&simpl=msg-f%3A1747170505… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] Subject: 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Vanessa Makhlouf <[email protected]> Wed, Oct 19, 2022 at 7:07 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.
652
10/20/22, 9:39 AM City of Oxnard Mail - [Ask Planning Action] Subject: 10/20 Public Hearing-Public comment to Vote NO on the The Port of Huene… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747170505980181584&simpl=msg-f%3A1747170505… 2/2 This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!
Sincerely,
Vanessa Makhlouf
653
10/20/22, 9:40 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747170593120188622&simpl=msg-f%3A1747170593… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
[email protected] <[email protected]> Wed, Oct 19, 2022 at 7:08 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.
654
10/20/22, 9:40 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747170593120188622&simpl=msg-f%3A1747170593… 2/2 This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!
Sincerely,
Robin Odega
655
10/20/22, 9:40 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747171138347722645&simpl=msg-f%3A17471711383… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
George Pineda Jr. <[email protected]> Wed, Oct 19, 2022 at 7:17 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city. The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long-term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250-acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer-causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zeroemission trucks. 656
10/20/22, 9:40 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747171138347722645&simpl=msg-f%3A17471711383… 2/2 This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit. Oxnard deserves clean air and environmental justice!
Sincerely,
George Pineda Jr.
657
10/20/22, 9:40 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747171680155779371&simpl=msg-f%3A1747171680… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
'Evelyn Mendez' via Planning <[email protected]> Wed, Oct 19, 2022 at 7:25 PM Reply-To: Evelyn Mendez <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Evelyn Xahuentitla
658
10/20/22, 9:41 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747171909869448647&simpl=msg-f%3A1747171909… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Anastatia ortiz <[email protected]> Wed, Oct 19, 2022 at 7:29 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR 659
10/20/22, 9:41 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747171909869448647&simpl=msg-f%3A1747171909… 2/2 should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!
Sincerely,
Anastatia Ortiz
This is a student email account managed by Oxnard Union High School District. The contents of this email are governed by the laws of the state and the board policies of the school district. 660
10/20/22, 9:41 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747174142301068418&simpl=msg-f%3A1747174142… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
'Julissa Lopez' via Planning <[email protected]> Wed, Oct 19, 2022 at 8:04 PM Reply-To: Julissa Lopez <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Julissa Lopez
661
10/20/22, 9:41 AM City of Oxnard Mail - [Ask Planning Action] Subject: 10/20 Public Hearing-Public comment to Vote NO on the The Port of Huene… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747175324176886684&simpl=msg-f%3A1747175324… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] Subject: 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Alex Masci <[email protected]> Wed, Oct 19, 2022 at 8:23 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term high-paying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Alex Masci
--
662
10/20/22, 9:41 AM City of Oxnard Mail - [Ask Planning Action] Subject: 10/20 Public Hearing-Public comment to Vote NO on the The Port of Huene… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747175324176886684&simpl=msg-f%3A1747175324… 2/2 Alex Masci
(she/her/hers)
[email protected]
805.886.0559
663
10/20/22, 9:43 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747176779978776850&simpl=msg-f%3A1747176779… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
'Selina Magallon' via Planning <[email protected]> Wed, Oct 19, 2022 at 8:46 PM Reply-To: Selina Magallon <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Selina Magallon
664
10/20/22, 9:44 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747186581289120223&simpl=msg-f%3A1747186581… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Natalie Chaparro <[email protected]> Wed, Oct 19, 2022 at 11:22 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Natalie Chaparro
665
10/20/22, 9:45 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747186617802065626&simpl=msg-f%3A1747186617… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Monse Santoyo <[email protected]> Wed, Oct 19, 2022 at 11:23 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Monserrat Santoyo
Sent from my iPhone
666
10/20/22, 9:45 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747187975445829723&simpl=msg-f%3A1747187975… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Jada Escamilla <[email protected]> Wed, Oct 19, 2022 at 11:44 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.
667
10/20/22, 9:45 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747187975445829723&simpl=msg-f%3A1747187975… 2/2 This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!
Sincerely,
Jada Escamilla
Sent from my iPhone
668
10/20/22, 9:46 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747188730467008530&simpl=msg-f%3A1747188730… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
'Bryna Sullivan' via Planning <[email protected]> Wed, Oct 19, 2022 at 11:56 PM Reply-To: Bryna Sullivan <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Bryna S.
669
10/20/22, 9:46 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747189698609046672&simpl=msg-f%3A1747189698… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Dani Espindola <[email protected]> Thu, Oct 20, 2022 at 12:12 AM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and 670
10/20/22, 9:46 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747189698609046672&simpl=msg-f%3A1747189698… 2/2 environmental justice!
Sincerely,
Daniella Espindola
671
10/20/22, 9:46 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747191389049834877&simpl=msg-f%3A1747191389… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
王 宇迪 <[email protected]> Thu, Oct 20, 2022 at 12:39 AM To: "[email protected]" <[email protected]>
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Sent from my iPhone
672
10/20/22, 9:47 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747191399322997817&simpl=msg-f%3A1747191399… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
王 宇迪 <[email protected]> Thu, Oct 20, 2022 at 12:39 AM To: "[email protected]" <[email protected]>
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Sent from my iPhone
673
10/20/22, 9:50 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747210691695017259&simpl=msg-f%3A1747210691… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 2 messages
'Alexis Lopez' via Planning <[email protected]> Thu, Oct 20, 2022 at 5:45 AM Reply-To: Alexis Lopez <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Sent from my iPhone
'Alyssa Ramirez' via Planning <[email protected]> Thu, Oct 20, 2022 at 6:59 AM Reply-To: Alyssa Ramirez <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,
674
10/20/22, 9:50 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747210691695017259&simpl=msg-f%3A1747210691… 2/2 I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!
Sincerely,
Alyssa Ramirez
675
10/20/22, 9:51 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747217166211852348&simpl=msg-f%3A1747217166… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Katya Acuña <[email protected]> Thu, Oct 20, 2022 at 7:28 AM To: "[email protected]" <[email protected]>
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.
676
10/20/22, 9:51 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747217166211852348&simpl=msg-f%3A1747217166… 2/2 This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!
Sincerely,
Katya Acuña
677
10/20/22, 9:51 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747219000684563819&simpl=msg-f%3A1747219000… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
'Daniel O.' via Planning <[email protected]> Thu, Oct 20, 2022 at 7:57 AM Reply-To: "Daniel O." <[email protected]>
To: "[email protected]" <[email protected]>
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union.

We want long-term high-paying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Daniel O
678
10/20/22, 9:51 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747221377503671427&simpl=msg-f%3A1747221377… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Mariam Gendi <[email protected]> Thu, Oct 20, 2022 at 8:35 AM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Sent from my iPhone
679
10/20/22, 9:52 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Today's Public Hearing - Public comment to Vote NO on the The Port of Huene… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747222258766072702&simpl=msg-f%3A1747222258… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Today's Public Hearing - Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Rachel Kim <[email protected]> Thu, Oct 20, 2022 at 8:49 AM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city. The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the 34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit. Oxnard deserves clean air and environmental justice! Sincerely,
Rachel
680
10/20/22, 9:52 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747222714070451451&simpl=msg-f%3A1747222714… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
'Bella Abbatoye' via Planning <[email protected]> Thu, Oct 20, 2022 at 8:56 AM Reply-To: Bella Abbatoye <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.
681
10/20/22, 9:52 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747222714070451451&simpl=msg-f%3A1747222714… 2/2 This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!
Sincerely,
Bella Abbatoye
682
10/20/22, 9:52 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747223202142303117&simpl=msg-f%3A1747223202… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
'Sara Reynoso' via Planning <[email protected]> Thu, Oct 20, 2022 at 9:04 AM Reply-To: Sara Reynoso <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Sara Reynoso
683
10/20/22, 9:53 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747223417361105692&simpl=msg-f%3A1747223417… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Leila Benoun <[email protected]> Thu, Oct 20, 2022 at 9:08 AM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Leila Kaseke
Ventura County Resident
684
10/20/22, 9:54 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747223449240421641&simpl=msg-f%3A1747223449… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Elisabeth Lamar <[email protected]> Thu, Oct 20, 2022 at 9:08 AM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
685
10/20/22, 9:55 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747224287868938337&simpl=msg-f%3A1747224287… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Lisa Nguyen <[email protected]> Thu, Oct 20, 2022 at 9:21 AM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Lisa Marie Nguyen
686
10/20/22, 9:55 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747225885003612990&simpl=msg-f%3A1747225885… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
'Cristian Rodriguez' via Planning <[email protected]> Thu, Oct 20, 2022 at 9:47 AM Reply-To: Cristian Rodriguez <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.
687
10/20/22, 9:55 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747225885003612990&simpl=msg-f%3A1747225885… 2/2 This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!
Sincerely,
Cristian Rodriguez
688
10/20/22, 9:55 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747226304896336098&simpl=msg-f%3A1747226304… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Jillian Hall <[email protected]> Thu, Oct 20, 2022 at 9:54 AM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and 689
10/20/22, 9:55 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747226304896336098&simpl=msg-f%3A1747226304… 2/2 environmental justice!
Sincerely,
Jillian Hall
690
10/20/22, 10:15 AM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Te… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747226967217017208&simpl=msg-f%3A1747226967… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
David Camacho <[email protected]> Thu, Oct 20, 2022 at 10:04 AM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Sent from my iPhone
691
10/20/22, 12:04 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Te… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747228388717536022&simpl=msg-f%3A1747228388… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Adriana <[email protected]> Thu, Oct 20, 2022 at 10:27 AM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Adriana Bracamontes
692
10/20/22, 12:05 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Te… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747230995685124564&simpl=msg-f%3A1747230995… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Lisette Espinosa <[email protected]> Thu, Oct 20, 2022 at 11:08 AM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city. The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term high-paying union jobs in our community.

The Port has said cars stored at the 34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!
Sincerely,
Lisette Espinosa
693
10/20/22, 12:05 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Te… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747230995685124564&simpl=msg-f%3A1747230995… 2/2 --
Lisette Espinosa
Claremont Mckenna College | Class of 2015
805 - 890 - 6067
694
10/20/22, 12:14 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Te… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747231491913875060&simpl=msg-f%3A1747231491… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
'Zuleth Lucero' via Planning <[email protected]> Thu, Oct 20, 2022 at 11:16 AM Reply-To: Zuleth Lucero <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Zuleth Lucero
695
10/20/22, 12:14 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Te… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747232759843132007&simpl=msg-f%3A1747232759… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
'Eliah Tumalan' via Planning <[email protected]> Thu, Oct 20, 2022 at 11:36 AM Reply-To: Eliah Tumalan <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term high-paying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!
Sincerely,
696
10/20/22, 12:14 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Te… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747232759843132007&simpl=msg-f%3A1747232759… 2/2 Eliah Tumalan
697
10/20/22, 12:29 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Te… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747235290133395694&simpl=msg-f%3A1747235290… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Yari Jimenez <[email protected]> Thu, Oct 20, 2022 at 12:16 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancercausing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Yaritza
698
10/20/22, 12:29 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Te… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747235482866718194&simpl=msg-f%3A1747235482… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
'Rafael Ceja' via Planning <[email protected]> Thu, Oct 20, 2022 at 12:19 PM Reply-To: Rafael Ceja <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Rafael ceja
Sent from my iPhone
699
10/20/22, 3:31 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747235482866718194&simpl=msg-f%3A1747235482… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 3 messages
'Rafael Ceja' via Planning <[email protected]> Thu, Oct 20, 2022 at 12:19 PM Reply-To: Rafael Ceja <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Rafael ceja
Sent from my iPhone
'Bertha Guzman' via Planning <[email protected]> Thu, Oct 20, 2022 at 1:29 PM Reply-To: Bertha Guzman <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,<BR><BR>I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.<BR><BR>It is not accurate to describe this project as temporary when the <BR>FEIR fails to say 700
10/20/22, 3:31 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747235482866718194&simpl=msg-f%3A1747235482… 2/2 what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage. <BR><BR>The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term high-paying union jobs in our community.<BR><BR>The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. <BR>This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime. <BR><BR>Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks. <BR><BR>This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!<BR><BR>Sincerely,<BR><BR>
Sent from my iPhone
'Bertha Guzman' via Planning <[email protected]> Thu, Oct 20, 2022 at 1:29 PM Reply-To: Bertha Guzman <[email protected]>
To: [email protected]
[Quoted text hidden]
701
10/20/22, 3:31 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747239968334212018&simpl=msg-f%3A1747239968… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
[email protected] <[email protected]> Thu, Oct 20, 2022 at 1:31 PM To: [email protected], [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.
702
10/20/22, 3:31 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747239968334212018&simpl=msg-f%3A1747239968… 2/2 This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!
Sincerely,
S. Tara Grover
703
10/20/22, 3:32 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747240126744775712&simpl=msg-f%3A1747240126… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Kathryn Masci <[email protected]> Thu, Oct 20, 2022 at 1:33 PM To: "[email protected]" <[email protected]>
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Kathryn Masci
704
10/20/22, 3:33 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747241587211955031&simpl=msg-f%3A1747241587… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 2 messages
'Christian Sanjose' via Planning <[email protected]> Thu, Oct 20, 2022 at 1:56 PM Reply-To: Christian Sanjose <[email protected]> To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Best,
Christian San Jose
'Christiana Pennington' via Planning <[email protected]> Thu, Oct 20, 2022 at 1:57 PM Reply-To: Christiana Pennington <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods. 705
10/20/22, 3:33 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747241587211955031&simpl=msg-f%3A1747241587… 2/2 It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Christiana
Sent from my iPhone
706
10/20/22, 3:33 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747242447294912603&simpl=msg-f%3A1747242447… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
'Gabriela Magallon' via Planning <[email protected]> Thu, Oct 20, 2022 at 2:10 PM Reply-To: Gabriela Magallon <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Gabriela Magallon
Sent from my iPhone
707
10/20/22, 3:33 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747242686614480302&simpl=msg-f%3A1747242686… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Cynthia Echeverria <[email protected]> Thu, Oct 20, 2022 at 2:14 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Cynthia Echeverria
708
10/20/22, 3:33 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747243207496850440&simpl=msg-f%3A1747243207… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Eric Martinez <[email protected]> Thu, Oct 20, 2022 at 2:22 PM To: [email protected]
Dear Oxnard Planning Commissioners,
It is my personal opinion that this project should not go forward. I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Eric Martinez
Sent from my iPhone
709
10/20/22, 3:34 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747244187221288567&simpl=msg-f%3A1747244187… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
'Natalie Alhabash' via Planning <[email protected]> Thu, Oct 20, 2022 at 2:38 PM Reply-To: Natalie Alhabash <[email protected]> To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Natalie
Sent from my iPhone
710
10/20/22, 3:35 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747245123743460973&simpl=msg-f%3A1747245123… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Molly McCoy <[email protected]> Thu, Oct 20, 2022 at 2:53 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancercausing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. As a Ventura County resident and environmental science college student, I’m asking that you do not certify the FEIR and deny the Special Use Permit.

Oxnard deserves clean air and environmental justice!
Sincerely,
Molly McCoy
711
10/20/22, 3:35 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747245197478561605&simpl=msg-f%3A1747245197… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Alina Tong <[email protected]> Thu, Oct 20, 2022 at 2:54 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and 712
10/20/22, 3:35 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747245197478561605&simpl=msg-f%3A1747245197… 2/2 environmental justice!
Sincerely,
Alina Tong
713
10/20/22, 3:42 PM City of Oxnard Mail - [Ask Planning Action] Please Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage F… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747245417431315388&simpl=msg-f%3A1747245417… 1/2 Solis, Rogelio <[email protected]>
[Ask Planning Action] Please Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project
2 messages
Jonathan Ullman <[email protected]> Thu, Oct 20, 2022 at 2:57 PM To: [email protected]
Cc: Elisabeth Lamar <[email protected]>, "[email protected]" <[email protected]>, James Hines <[email protected]>, Katie Davis <[email protected]> Dear Oxnard Planning Commission members:

The Sierra Club Santa Barbara Chapter representing Ventura County and members who directly enjoy and benefit from restored wetlands adjacent to the property in the City of Oxnard and the restoration of these lands ask the Oxnard City Planning Commission to vote no on accepting the EIR and vote no to any permitting. Please instruct planning staff to return with findings of denial.

This is a bad project.

Sincerely,
Jonathan Ullman
Director, Sierra Club Santa Barbara-Ventura Chapter
--
Jonathan Ullman, Director
Sierra Club Santa Barbara-Ventura Chapter
P O Box 31241
Santa Barbara, CA 93130-1241
Phone: (805) 617-3106
Jonathan Ullman <[email protected]> Thu, Oct 20, 2022 at 3:25 PM To: [email protected]
Cc: Elisabeth Lamar <[email protected]>, "[email protected]" <[email protected]>, James Hines <[email protected]>, Katie Davis <[email protected]> A correction to our 2:57 p.m. email.

On Thu, Oct 20, 2022 at 2:57 PM Jonathan Ullman <[email protected]> wrote:

Dear Oxnard Planning Commission members:

The Sierra Club Santa Barbara-Ventura Chapter representing Ventura County and members who directly enjoy and benefit from restored wetlands adjacent to the property in the City of Oxnard and the restoration of these lands ask the Oxnard City Planning Commission to vote no on accepting the EIR and vote no to any permitting. Please instruct planning staff to return with findings of denial.

This is a bad project.

Sincerely,
Jonathan Ullman
Director, Sierra Club Santa Barbara-Ventura Chapter
--
Jonathan Ullman, Director
Sierra Club Santa Barbara-Ventura Chapter
714
10/20/22, 3:42 PM City of Oxnard Mail - [Ask Planning Action] Please Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage F… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747245417431315388&simpl=msg-f%3A1747245417… 2/2 P O Box 31241
Santa Barbara, CA 93130-1241
Phone: (805) 617-3106
[Quoted text hidden]
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10/20/22, 3:44 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747248090595222405&simpl=msg-f%3A1747248090… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
'Rebecca Carasco' via Planning <[email protected]> Thu, Oct 20, 2022 at 3:40 PM Reply-To: Rebecca Carasco <[email protected]>
To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Grace Carasco
716
10/20/22, 3:54 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747248376195136896&simpl=msg-f%3A1747248376… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Keenan Hancock <[email protected]> Thu, Oct 20, 2022 at 3:44 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods. It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage. The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term high-paying union jobs in our community. The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks. This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust. Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime. Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic. Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks. This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice!
Sincerely,
Keenan Hancock
--
Keenan P. Hancock
Pharm. D, M.S. HCDA
Tel: 1(760) 310-2214
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10/20/22, 3:54 PM City of Oxnard Mail - [Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Tem… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747248745555843669&simpl=msg-f%3A1747248745… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] 10/20 Public Hearing-Public comment to Vote NO on the The Port of Hueneme –Temporary Outdoor Vehicle Storage Facility Project 1 message
Bowen Liu <[email protected]> Thu, Oct 20, 2022 at 3:50 PM To: [email protected]
Dear Oxnard Planning Commissioners,
I am writing to urge you to reject the Final EIR (FEIR) and vote NO on the 34-Acre GLOVIS Port Expansion. As Commissioners, it is your job to conduct fair hearings that work to preserve the environment and health of Oxnard residents and avoid using false or inaccurate information when making important decisions for our city.The FEIR fails to include an accurate project description, does not consider impacts to air quality and pollution from diesel trucks, and avoids consideration of alternatives to alleviate the pollution burden on South Oxnard neighborhoods.

It is not accurate to describe this project as temporary when the FEIR fails to say what the long term plans are for Port Storage after the 3-5 years. It has been submitted to the record that the Port of Hueneme and GLOVIS already have plans, started contracts, and applied for grants to start a much bigger 250 acre expansion project, over seven times as big as this one farther down Hueneme Road, but it was left out of the FEIR. There cannot be a vote on this project without a study on long-term plans for Port storage.

The FEIR states the project will not be expanding more shipments into the port, but it also says the project is going to allow more shipments from GLOVIS to create more jobs at the port. Both cannot be true. This project will only bring 14 jobs, all of which are contracted by GLOVIS that pay around minimum wage and are non-union. We want long-term highpaying union jobs in our community.

The Port has said cars stored at the34-acre site will be picked up by diesel trucks to transport them to dealerships around the country but the FEIR does not consider impacts to air quality from diesel trucks.

This project will bring more diesel trucks on Hueneme Road, polluting our air with more cancer causing diesel exhaust.

Diesel exhaust is the #1 cancer-causing air pollutant and exposure can result in lung function damage in children that lasts a lifetime.

Right now, the port is using 31 acres of extra storage at the naval base to help the Port of LA during the pandemic.

Instead of turning more and more land in South Oxnard into port storage which brings more and more polluting trucks to our neighborhoods, the FEIR should consider other options like using space in the navy base and the use of zero emission trucks.

This FEIR fails to accurately examine the negative impacts of this project. I’m asking that you do not certify the FEIR and deny the Special Use Permit.Oxnard deserves clean air and environmental justice! Sincerely,
Sent from my iPhone
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10/20/22, 12:06 PM City of Oxnard Mail - [Ask Planning Action] Fwd: Item F-1: Port of Hueneme - Temporary Outdoor Vehicle Storage Facility Speci… https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747231448827376774&simpl=msg-f%3A1747231448… 1/1 Solis, Rogelio <[email protected]>
[Ask Planning Action] Fwd: Item F-1: Port of Hueneme - Temporary Outdoor Vehicle Storage Facility Special Use Permit PZ 18-500-02
1 message
Chaparro, Rose <[email protected]> Thu, Oct 20, 2022 at 11:15 AM Cc: Alexander Nguyen <[email protected]>, "Golden, Ashley" <[email protected]>, "Klima, Shiri" <[email protected]>, Stephen Fischer <[email protected]>, Planning <[email protected]>, Jay Dobrowalski <[email protected]>
Dear Council,
FYI - Please find attached below written comments received.

Rose Chaparro, City Clerk
City of Oxnard
300 West Third Street
Oxnard, CA 93030
Main Line: (805) 385-7803
[email protected]
---------- Forwarded message ---------
From: lucy cartagena <[email protected]>
Date: Thu, Oct 20, 2022 at 9:35 AM
Subject: Item F-1: Port of Hueneme - Temporary Outdoor Vehicle Storage Facility Special Use Permit PZ 18-500-02 To: <[email protected]>
My name us Lucy Cartagena. Iam a resident of Oxnard, and founder of Familys First, a non-profit that provides parenting classes as well as works in the community to raise literacy in our community.

I support the project as it aligns with the betterment of our society in ending global warming and raises the astetics of that blighted Part of our City that has been generational neglected.

I'm afraid those opposed the project still do not even have a plan, project or something to bring to the table or funding to implement thier pipe dream.

Oxnard , needs to move forward and change the landscape of that area today so that it can pave the way for those opposed to raise the funds needed to do what they only invision for tomorrow.

To not support movement or buetification of the Ports project will only leave that area that is currently neglected by the city to contiue for possibly another 20 years. Unless the opposition has concrete funding, with blueprint plans for that area it will contiue to be thier pipe dream, as lovely as it sounds. But, this 1 project will not fix the surrounding, nor will the opposition. So that leaves our community to grapple with the outcome of something that can benefit our communty, or nothing and contiue wishing for something.

And, on another note, I urge the commission to direct CAUSE and its affiliates to stop spreading false information of the project to the communty. It is not fair to the Port and all its wonderful employees to be slandered. ~Lucy
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City of Oxnard, Planning Division
Attn: Jay Dobrowalski, Senior Planner
214 South C Street
Oxnard, CA 93030
[email protected]
Dear Jay Dobrowalski,
On Behalf of the Wishtoyo Foundation (“Wishtoyo”) we submit the following comments on the Final Environmental Impact Report SCH NO. 2020069039 (FEIR) for the Port of Hueneme Temporary Outdoor Vehicle Storage Project (“Project”).

Founded in 1997, Wishtoyo Foundation is a California 501(c)(3) nonprofit public interest organization with members composed of Chumash Native Americans, First Nations People, and Santa Barbara, Ventura, and Los Angeles County residents. Wishtoyo is place, organization, and movement inspiring people to live in harmony with our Earth again. Wishtoyo serves as a “rainbow bridge” linking Chumash and Indigenous lifeways with the protection of natural and cultural resources, utilizing traditional ecological knowledge to provide environmental and cultural preservation and justice, education, research, and advocacy.

City of Oxnard’s Response to Comments
In brief, the FEIR's "Global Responses" fail to adequately respond to the community's comments. The FEIR, if approved, will greenlight a parking expansion with negative impacts to the environment and the animal and plant species, which it supports, and the Oxnard community.

The City’s Global Response 3 (“GR-3”) failed to properly respond to community comments over piecemealing of the project and expansion of the port. The FEIR has only included analysis of the 34-acre temporary storage facility, but fails to include any analysis of a 250-acre permanent storage facility that has not yet been subject to environmental review. The project in question is a 721
temporary vehicle storage facility that was planned in response to the Port’s contracts with GLOVIS. The FEIR makes no mention of a transitional plan or where vehicles will be stored after this temporary term. As referenced in the CAUSE comment letter submitted in February of this year, the Port of Hueneme has previously sought funding for the 250-acre Multimodal Logistics Park. Oxnard Harbor District and the City of Oxnard have long known of this 34-acre facility as a stop-gap measure that will give the Port of Hueneme and City of Oxnard time to meet regulatory requirements for the longer term 250-acre project. The City’s GR-3 response clearly demonstrates the City’s lack of understanding of the definition of “reasonably foreseeable” and “speculative”. The absence of applications for the 250-acre project to the City of Oxnard does not preclude the definition of reasonably foreseeable. As addressed in the CAUSE comment letter, substantive evidence exists in which the Port of Hueneme seeks to expand its operations and land acquisitions in Oxnard and the surrounding areas in order to keep up with its contracts with GLOVIS.

Follow-up Biological Resources Inventory - 2022
The City’s Follow-up Biological Resources Inventory included in Appendix FA in response to public comments concerning impacts to biological resources is woefully inadequate. For example, the first bird species of special concern listed is the Tricolored Blackbird. The inventory claims “Not expected to occur. This species has not been documented in Ventura County since 1994”. The Consultant Firm, Dudek, referenced the CDFW CNDDB database in this determination. The CNDDB database lacks input from citizen science projects, current research, and is overall exceptionally outdated and omits crucial plant and wildlife data.

Surprisingly, Dudek also referenced the database, ebird, for some of its other determinations in the biological resources inventory. If they had referenced the ebird database when making a determination for the Tricolored Blackbird, they would have found that Tricolored Blackbirds have been seen throughout Ventura County as recently as the summer of 2022, as well as the Ormond Beach wetlands, adjacent to the project site. I have personally observed a Tricolored Blackbird at Ormond Beach Wetlands in 2017 and ebird includes multiple pictures of the species at Ormond. There is no explanation why Dudek did not use ebird for their claims for this 722
particular species. The inventory also claimed that “the site lacks suitable wetland habitat to support this species”. Tricolored Blackbirds are not wetland obligate species. These blackbirds are known to forage rice fields, alfalfa, irrigated pastures, ripening or cut grainfields, annual grasslands, and even disturbed areas such as cattle feed lots and dairies1. Although the site is comprised of disturbed upland/grassland, it is entirely possible for Tricolored blackbirds, which have been observed in the adjacent wetlands, to use the project site.

This follow-up inventory did little more than the biological resources inventory used in the Draft EIR and completely failed to analyze the impacts to sensitive and listed species that use the project site and the adjacent habitats that could be affected by the project. These would include, but are not limited to the Peregrine Falcon, White-tailed Kite, Red-tailed Hawk, Tricolored Blackbird, Belding’s Savannah Sparrow, California glossy snake, San Diegan Tiger Whiptail, and Western Pond Turtle.

The City and its consultants must take their obligation to properly analyze the Project’s impacts to biological resources seriously. To date, the analysis of impacts to biological resources has been entirely lacking and has omitted impacts to the sensitive plants and wildlife that exist in the project area and the adjacent habitats. Please see attached letter from February of this year detailing Wishtoyo’s concerns with the environmental review of this project. The City has a duty to inform its citizens of all of the impacts that a project will have on the environment and has failed to do so.
1 Tricolored Blackbird Working Group. 2007. Conservation Plan for the Tricolored Blackbird (Agelaius tricolor).

Susan Kester (ed.). Sustainable Conservation. San Francisco, CA.

Mati Waiya
Executive Director
Wishtoyo Chumash Foundation
Tevin Schmitt
Watershed Scientist
Wishtoyo Chumash Foundation
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Attachment: Wishtoyo Foundation
February 14th, 2022 Comment Letter
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February 14, 2022
City of Oxnard, Planning Division
Attn: Jay Dobrowalski, Associate Planner
214 South C Street
Oxnard, CA 93030
[email protected]
Dear Jay Dobrowalski,
On Behalf of the Wishtoyo Foundation (“Wishtoyo”) we submit the following comments on the Draft Environmental Impact Report SCH NO. 2020069039 (DEIR) for the Port of Hueneme Temporary Outdoor Vehicle Storage Project (“Project”).

Founded in 1997, Wishtoyo Foundation is a California 501(c)(3) nonprofit public interest organization with members composed of Chumash Native Americans, First Nations People, and Santa Barbara, Ventura, and Los Angeles County residents. Wishtoyo is place, organization, and movement inspiring people to live in harmony with our Earth again. Wishtoyo serves as a “rainbow bridge” linking Chumash and Indigenous lifeways with the protection of natural and cultural resources, utilizing traditional ecological knowledge to provide environmental and cultural preservation and justice, education, research, and advocacy.

Project Description and Piecemeal
The DEIR has failed to properly disclose and analyze the full Project to include 1) the temporary vehicle storage facility discussed in this DEIR as Phase I and 2) the 250-acre permanent vehicle storage facility as Phase II of the Project. Separating these two phases is an impermissible 725
piecemeal of projects under the California Environmental Quality Act (“CEQA”) environmental review process. The CEQA Guidelines define “project” broadly as “the whole of an action, which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment ….” (Guidelines, § 15378, subd. (a)). Further, environmental analysis must include the environmental effects of future expansion or other action if: (1) it is a reasonably foreseeable consequence of the initial project; and (2) the future expansion or action will be significant in that it will likely change the scope or nature of the initial project or its environmental effects.

Phase II is a reasonably foreseeable consequence of the Project because the only purpose of the initial temporary facility is to serve as a bridge to the Port’s expansion of vehicle storage capabilities while the Port seeks the necessary approvals for the second facility. The Project is just Phase I of the Port’s expansion and is only being proposed in anticipation for the Port to expand its operations permanently. Officials from the Port have been clear about this with certain members of the community and the City. (See Attachment A1). While the Port has disclosed this two-phase approach to some, it and the City failed to include this necessary information in the DEIR and failed to provide the legally mandated environmental review of all aspects of the Project, including Phase I and Phase II. Thus, because the City and the Port knew and have been planning on implementing Phase I and Phase II of the Port’s vehicle storage expansion since the beginning, Phase II is a reasonably foreseeable consequence of the Project.

The future expansion of Phase II will also change the scope and nature of the environmental effects of the Project. First, Phase II will be a permanent vehicle storage facility, not a five-year Project as analyzed in the DEIR. The DEIR did not analyze the environmental impacts of a permanent vehicle storage facility. The DEIR must be conducted including analysis on the temporary and potential permanent siting of Phase I at the Project’s current location and the permanent siting of Phase II of the Project. The location of the Phase II vehicle storage facility must be disclosed in this DEIR to fully inform the public of its environmental impacts. Second, Phase II will very likely include more driving and parking of vehicles not analyzed in the DEIR, thus increasing the traffic impacts, air and water pollution associated with driving and parking, 1 See Attachment A for Declaration of Lucas Zucker
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environmental justice concerns, impacts to Chumash cultural and natural cultural resources, and be further inconsistent with the City’s general plan and wetlands restoration plans. Lastly, the DEIR misled the public into thinking the whole Project would be a minimal temporary hindrance to their community, instead of the hidden reality that the Project is just Phase I of the Port’s expansion and a much larger and permanent vehicle storage facility.

Tribal Cultural Resources
The County failed to adequately analyze the impacts of the project on cultural resources. The DEIR expresses a clear bias against the recognition that the Chumash people live in Oxnard and near the Project area today; that they have strong relationships with the Project area; that they currently utilize natural cultural resources throughout the Project area; and that Chumash tribes, bands, and clans are sovereign entities.

The EIR misuses the term “cultural site” by using it synonymously with “archeological site” showing a clear lack of understanding of what a cultural site is. Archeological sites are locations identified to be of archeological value to researchers. Cultural sites include archeological sites, but also include many locations that are of little interest to archeologists, such as village sites where the ground has been previously disturbed and areas where sedimentation has relocated Chumash artifacts. Furthermore, cultural sites also include but are not limited to sacred sites, gathering locations, and cultural landscapes.

Further, the City abused its discretion when failing to locate Tribal Cultural Resources widely known to likely be present in the Project area through the use of the best available and widely used technology and methods. Wishtoyo requests that specially trained forensic canines in combination with ground penetrating radar are utilized to identify the location of all Native American burials and cultural remains within the project site. These techniques were used to reliably identify the location of Ohlone/Esselen burials in the KB Homes Development in Santa Cruz and for other development projects. Wishtoyo used forensic canines to detect the presence of Chumash ancestral remains/burials for the Santa Clara River Estuary / McGrath State Beach Campground Relocation and Estuary Restoration Feasibility Study with California 727
State Parks. (Attachment 1
2 ) The use of specially trained canine forensics and ground penetrating radar, represent the best available technology and most reliable means for the identification of Native American burials, and thus should be used to identify potential impacts to Chumash Tribal Cultural Resources and to mitigate those impacts to a less than significant effect.

Under CEQA and California law, when cultural resources are identified, the preferred mitigation measure is avoidance, and if avoidance is not feasible, preservation in place as defined by the local Native nations. (CEQA Guidelines §15126.4). Avoidance and preservation in place mitigation measures cannot be implemented if Tribal Cultural Resources are not identified before the approval of the Project and its CEQA documents. Therefore, the Project’s mitigation measure MM CUL-2 is an insufficient mitigation of potential impacts to cultural resources. The presence of a Native American Monitor only during subsurface grading, trenching, and construction will not avoid impact to cultural resources. This is because once construction begins and no commitments to avoidance or preservation in place are secured, a monitor can only do so much (if anything) to secure lesser protections (such as movement of the resource to another location away from its Village location or burial ground, or recovery of the resource for storage or display in a museum) for the resources which are often damaged or destroyed by the excavating activity that resulted in its discovery. Additionally, the DEIR’s use of monitors is flawed because the DEIR fails to identify the process of selecting the Native American Monitor, and fails to contain procedures to ensure monitors from the proper Chumash Nations will be present during construction to best protect un-detected Chumash remain from harm and to help determine proper actions that must be taken to protect and preserve the Chumash remains encountered.

The DEIR has completely failed in its analysis of Project impacts to Tribal cultural resources and must properly categorize the finding of unidentified Tribal Cultural Resources and ancestral remains as a “potential significant impact” that must have adequate mitigation measures to ensure the proper consultation protocols and protections are in place.

Water Quality and Wetlands
2 See Attachment 1 for the Santa Clara River Estuary / McGrath State Beach Campground Relocation and Estuary Restoration Feasibility Study showing Wishtoyo’s use of canine forensic dogs. 728

1. No analysis of Specific Water Quality Impacts
The DEIR failed to analyze the type and amounts of hazardous materials and toxic metals associated with vehicle liquids and fluids (fuel, coolant, oil, etc.), vehicle tires, vehicle brake pads, vehicle paint, and the environmental impact these hazardous materials and metals will have on the wetlands. Southern California Coastal Water Research Project (SCCWRP) conducted a study on water quality and toxicity of runoff from parking facilities during storm events. (Attachment 2
3 ) The study found that runoff from these sites have high concentrations of Iron, Zinc, Copper, and Lead. (Id. at ii.) These pollutants are derived from the wear of breaks, tires, and other exposed auto parts, and spills of automotive fluids. Parking facilities also tend to accumulate wind and atmospheric transported pollutants over time (Id. at 1). Furthermore, because this Project is located on the coast, the salt in the air at the Project site will wear the paint and metal parts of the cars at an accelerated rate, leading to increased concentrations of metals discharged from the site in stormwater during rain events. Metal pollutants have acute, chronic, and sub-lethal effects on marine and aquatic life in the Pacific Ocean and Ormond Beach Wetlands. (Id. at 32). They can also biomagnify in the food chain, and cause these acute, chronic, and sublethal impacts on avian species. Without this necessary analysis on hazardous materials and metal pollutants that would be contained in stormwater discharges from the Project site, the City has not informed the public on the environmental impacts of the Project, needed mitigation to prevent impacts to aquatic and avian species in receiving waters, and should not have found less than significant impact in the DEIR. The DEIR provides no information regarding hazardous materials for the public and decision makers to evaluate and comment on, thus failing to meet the requirements of CEQA. The DEIR must fully analyze the impacts of the Project on Ormond Beach Wetlands and specifically, the impacts of metals and hazardous materials discharged from the Project site during storm events.

The DEIR failed to analyze whether the stormwater discharges from the Project site during or after construction will meet Clean Water Act Water Quality Standards; will harm wildlife, recreational, cultural, or tribal ceremonial beneficial uses; and will cause or contribute to harms to Clean Water Act 303(d) listed impaired waterways. As detailed above, sufficient information exists that indicates the contaminants in stormwater discharges from the Project will harm the 3 Southern California Coastal Water Research Project, Technical Report 343, Characteristics of Parking Lot Runoff Produced by Simulated Runoff (July, 2001).
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beneficial uses of the Ormond Lagoon Waterway, Ormond Lagoon, and the Pacific Ocean. In addition, further analysis is required because the Ormond Lagoon Waterway / Lagoon are listed by the U.S. EPA and State Water Resources Control Board on the Clean Water Act 303(d) list as impaired for bacteria, pH, and trash. (Attachment 3
4 ) Thus, a comprehensive analysis is
needed that ensures the project is not causing or contributing to these impairments. For instance, as detailed above, an analysis of impacts of metals and other pollutants in stormwater discharges from the Project is needed in part to see if the Project’s discharges will cause or contribute to the pH impairments in the Ormond Beach Lagoon identified on the 303(d) list. In addition, a comprehensive EIR analysis is needed, along with a comprehensive analysis of mitigation measures, to prevent the Project from accumulating and discharging trash into Ormond Lagoon Waterway and Ormond Lagoon, and the Pacific Ocean.17 This is especially the case because it is critical the Project does not cause or contribute to trash pollution of these waters, which are already 303(d) listed for trash. (See attachment 3.) Without this analysis, it is likely that the well-known trash littering and accumulation problem that plagues these waters and Oxnard’s streets near the wetlands, will be deposited onto the Project site (via littering / dumping activities, or via wind), and then will be conveyed either by wind or stormwater discharges from the Project’s graded and graveled surfaces into the adjacent Ormond Lagoon Water Way, Ormond Lagoon, tšumaš Creek, or the Pacific Ocean.

The City failed to implement necessary mitigation measures that would reduce the environmental impacts of metals, trash and hazardous materials to less than significant levels.

As discussed in the SCCWRP report, best management practices are needed to reduce the toxicity of stormwater runoff from parking facilities. (Attachment 2 at iii.) Best management practices could include bioretention areas that allow runoff from the Project to pond and filter through vegetation and soil. The Project could also include sand beds to filter the runoff and planted wetland vegetation to naturally treat and filter runoff before it enters Ormond Lagoon Waterway (Attachment 45). The DEIR failed to analyze or require any, and the necessary, best management practices for stormwater runoff to ensure the hazardous materials, trash, and 4 February 5, 2018 State Water Board Transmittal to the U.S. EPA – that includes relevant excerpts from the State Water Board’s 303(d) list approvals and 2014 / 2016 California Integrated report; U.S. EPA Approved California 2014-2016 Clean Water Act 303(d) List of Impaired Waters dated April 6, 2018. 5 Stormwater Management Practices at EPA Facilities (February 2017), (last accessed 1/28/2019) available at https://www.epa.gov/greeningepa/stormwater-management-practices-epa-facilities 730
metals associated with the Project would not impact water quality or the wetlands, during or after construction of the Project.

2. No analysis of Wetland Retreat in Response to Sea Level Rise The DEIR did not properly consider the Project’s consistency with Oxnard’s certified Local Coastal Plan (“LCP”) and the other approvals that may be required. If any portion of the project site is within the coastal zone, a coastal development permit and possibly an LCP amendment will be necessary. According to a study conducted by UCLA, the project site is located in the future Upland Transition Zone (“UTZ”) of Ormond Beach Wetlands (Attachment 5 6 (“UCLA
Study” or “Study”)). The Study predicts that the mean sea level will rise 0.6 m by 2050 due to projected impacts from climate change. (Id. at 11). The UCLA Study predicted that Southern California wetland habitat will naturally retreat inland. The preservation of habitat inland of these wetland areas is essential for their successful retreat. The project lies in an important location for UTZ wetland habitat (Id. at 37, Figure 14). The construction of this temporary parking facility and disturbance of this land would significantly degrade the suitability of this habitat for future sea level rise conditions, and would impair and prevent future reclaiming of the Ormond Beach wetlands Project site needed for the wetland habitat and the endangered wildlife (see below) that depends on it to exist. The DEIR failed to consider any projections of sea level rise or wetland retreat, the associated impacts of the Project on future Ormond Beach Wetlands habitat and the endangered species that rely on the Ormond Beach Wetlands, and City of Oxnard must prepare a full EIR to further analyze the Project’s impacts on retreating wetlands and UTZ habitat.
6 UCLA Institute of the Environment and Sustainability, Evaluating Physical Suitability, Land Use, and Cost Feasibility for Acquiring Land for Wetland Transgression in Selected Southern California Wetlands, (last accessed 1/28/2022) available at https://www.ioes.ucla.edu/wpcontent/uploads/wetlandspracticum_finalreport.pdf. 731
Furthermore, the DEIR must evaluate the Project’s direct, indirect, and cumulative impact on all community restoration and public access plans for the Ormond Beach Wetlands, including The Ormond Beach Restoration and Public Access Plan. While an EIR is required (1) to analyze the Project’s impacts on all restoration and public access plans for the Ormond Beach Wetlands, and to ensure consistency and no impacts to these plans, and (2) that includes scoping with the Oxnard community, California government agencies (such as the Coastal Conservancy), and nonprofits (such as the Nature Conservancy involved in such restoration plans to inform this analysis), the DEIR fails to analyze the impacts on all restoration and public access plans for the Ormond Beach Wetlands, and fails to analyze whether the Project will make the Ormond Beach Wetlands less or non-tourist/visitor friendly (a critical element to improving the local economy and providing a fulfilling experience that attracts residents and visitors), thereby being harmful or inconsistent with the Ormond Beach Restoration and Public Access Plan. For instance, see attached presentation of the Ormond Beach Restoration and Public Access Plan. (Attachment Project Site
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6 7
). A comprehensive analysis must be undertaken as to how the Project impacts public access to the Wetlands and enjoyment of the Wetlands, such as interaction with wildlife, aesthetic enjoyment and views when walking through and enjoying the wetlands, and spiritual enjoyment.

Further, the Project must be considered, and if it moves forward, planned in conjunction with any Ormond Beach Wetlands preservation, public access, and restoration project.

Harms to Wildlife

1. Poor Survey and Literature Review Informing the DEIR’s Biological Resources Analysis
The DEIR utterly fails in its analysis of the Project’s impacts to sensitive wildlife and surrounding ecosystems. The DEIR fails to even mention more than 20 listed or special status species that are known to exist in the area. The literature review and reconnaissance-level surveys conducted in 2018 and 2020 proved to be woefully inadequate in determining the full scope of impacts this project would have on wildlife and sensitive species habitats.

The reconnaissance-level surveys were conducted in April 2018 and October 2020. The 2018 survey was conducted between 10 and 11 am and the 2020 survey was conducted between 9:30 and 10:30 am. Both of these surveys were conducted too late in the day for representative avian species observations. April is typically too early for representative breeding bird surveys and October does not represent breeding season counts, and is too late in the year for a representative list of fall-migrating avian species. The description of these surveys included no standardized methodology for how these surveys were conducted, making them impossible to replicate or determine if observed species were identified and quantified properly. No nocturnal surveys were conducted to determine the presence of anuran species in the project location and no special status anuran species are mentioned in the DEIR. No surveys were conducted to determine bat species presence near the Project area and no special status bat species are mentioned in the DEIR.

2. Listed and Special Status Species Missing from DEIR
7 For additional information regarding the Ormond Beach Restoration Project please see attachments 18- 22 733
The DEIR’s lack of analysis of impacts to biological resources in the Project area and adjacent Ormond Beach Wetlands demonstrates the City’s complete ignorance of local ecology and biological resources. The use of the CNDDB and poorly conducted reconnaissance surveys provided meek species lists that are not at all representative of the project site or Ormond Wetlands. The DEIR failed to analyze the Project’s full impact on listed and special status species that exist in the Project area.

More than 200 bird species are known to use the Ormond Beach Wetlands for breeding, foraging, roosting, and migration. Among these avian species are multiple species of “birds of prey” which are protected under California Fish and Game Code section 3503.5. Birds of prey that exist in the project area and adjacent wetlands that are not included in the DEIR include:

White-tailed Kite, Northern Harrier, Red-tailed Hawk, Red-shouldered Hawk, Cooper’s Hawk, Sharp-shinned Hawk, American Kestrel, Peregrine Falcon, Merlin, and Osprey. A Red-tailed Hawk was even observed during a reconnaissance survey, but was not included as a special status species. All of these species have been observed either in the project area, or in the adjacent wetlands. All of these species are protected under California law and the DEIR must include analysis on the Project’s impacts to birds of prey.

Salt marsh and coastal wetland habitats have declined up to 90% in California, making Ormond Beach Wetlands a rare gem and an exceptionally important area for sensitive and endangered plants, invertebrates, fish, amphibians, reptiles, mammals, and birds. The Project may have a significant impact on the ecosystems on which these species rely. The Project will have stormwater runoff exit the facility and drain into Ormond Lagoon Waterway, and eventually into Ormond Lagoon. As mentioned in the Water Quality and Wetlands section, the Project area will be in the Upland Transitional Zone according to sea level rise and wetland retreat projections.

Species that rely on mixed vegetation communities will also need to retreat with wetlands, and will not be able to do so if the proposed Project area is disturbed further. As observed in the reconnaissance surveys performed for the DEIR, the Project area provides habitat for multiple prey species including small song birds and gopher snakes. If a parking lot, even temporary, is built here, this will limit foraging habitat for birds of prey and may increase the likelihood of harm from Project associated toxins or vehicle strikes.
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The DEIR failed to include an impact analysis of multiple California Species of Special Concern and Fully Protected species that are known to occur in and near the Project Area. The fully protected species the DEIR failed to analyze, or even mention, are the White-tailed Kite and Peregrine Falcon. As well as birds of prey, these species are also fully protected under California law FGC 3511. Species of Special Concern that are known to occur in and near the Project area, but do not appear in the DEIR are: San Diegan tiger whiptail, Blainville’s horned lizard, coast patch-nosed Snake, south coast garter snake, California glossy snake, western spadefoot, western pond turtle, and coast range newt. As these species are listed as species of special concern in California and are known to exist in the project area and surrounding habitats, the DEIR must include these species and analyses of Project impacts to these sensitive species.

The DEIR failed to include an impact analysis of multiple federally listed species that are known to occur in and near the Project Area. These species include California orcutt grass, Gambel’s watercress, marsh sandwort, spreading navarretia, Marbled Murrelet, Southwestern Willow Flycatcher, and vernal pool fairy shrimp. The DEIR must include these listed species and an analysis of Project impacts to these sensitive species and their habitats.

3. Impacts to Sensitive Wildlife and Their Habitats
Of great concern are the Project’s hazardous materials, trash, and metals entering the Ormond Lagoon Waterway and Ormond Lagoon through stormwater runoff, polluting the waters and harming the endangered tidewater goby that reside in the two water bodies. The U.S. Fish and Wildlife Service lists Ormond Lagoon Waterway and tšumaš Creek in the LA/Ventura Recovery Unit in their Recovery Plan for the endangered tidewater goby. (Attachment 7 8 at Figure B-17).

The DEIR provides no analysis of direct, indirect, and cumulative impacts from the Project on the tidewater goby, even though the project will discharge stormwater into the goby’s habitat which is located only 125 feet from the proposed Project site. Vital habitat for the tidewater goby has been lost or impacted by metal and industrial pollution in other streams. There is precedent 8 Pacific Region U.S. Fish and Wildlife Service, Recovery Plan for the Tidewater Goby (December, 2005) 735
of tidewater goby habitat becoming “Water Quality Limited” due to pollution associated with metal toxicity. The State Water Quality Control Board lists tidewater goby habitat in Goleta Slough as “Water Quality Limited”; partially due to metal pollutants which harm the species (Id. at C-26). The US Fish and Wildlife Service specifically lists “watercourse contamination resulting from vehicular activity in the vicinity of lagoons'' as a threat to the tidewater goby’s habitat (Attachment 8 at pg. 39) The hazardous materials from the Project, including Iron, Zinc, Copper, trash, and Lead, will contaminate the goby’s habitat and will contribute to the take of the tidewater goby, violating the Endangered Species Act and preventing the recovery of the species. The City must analyze the impact the Project will have on water quality of Ormond Lagoon Waterway and Ormond Lagoon and the Project’s impact on tidewater goby and its habitat.

The hazardous materials, trash, and metals discharged during storm events from the Project will also have a significant impact on the endangered California Least Tern. California Least Terns nest at Ormond Beach Wetlands from mid-April to late September. (Attachment 9 10 at 1).

Ormond Lagoon Waterway flows into Ormond Lagoon, which is an important foraging habitat for California Least Terns. Toxins and metals introduced from the Project’s runoff during storm events can accumulate in the tissues and gills of small fish species which are eaten by California Least Terns and fed to their young. Southern California Coastal Water Research Project (SCCWRP) conducted a study on aquatic toxicants and their presence in seabird eggshells. The study focused on four seabird species including the California Least Tern (Attachment 10
11 at 2). Heavy metals, as well as other toxicants were found in all of their California Least Tern eggshell samples (Id. at 7). California Least Terns are susceptible to the biomagnification of these toxicants due to their foraging habits in near-shore environments (Id. at 23). The MND failed to analyze the Project’s direct, indirect, secondary, and cumulative impacts from metal and other hazardous materials entering into waterways during storm events, accumulating in small fish and benthic macroinvertebrates, and impacting the endangered 9 U.S. Fish and Wildlife Service, Tidewater Goby, Humboldt Bay, (last accessed 1/28/2019) available at https://www.fws.gov/refuge/Humboldt_Bay/wildlife_and_habitat/TidewaterGoby.html. 10 California Department of Fish and Game South Coast Region, California Least Tern Breeding Survey 2009 Season (July, 2010)
11 Southern California Coastal Water Research Project, Technical Report 944, Contaminant Bioaccumulation in Seabird Eggs of the Southern California Bight (September, 2016). 736
California Least Tern. The City must prepare a full EIR because the Project may harm endangered species, a harm that must be adequately analyzed.

The DEIR completely failed to analyze the Project’s potential impacts on the Peregrine Falcon, a California fully protected species. The DEIR does not even mention Peregrine Falcons in the Biological Resources section, even though they are found throughout the region and observed frequently at Ormond Beach and in Oxnard. The Project description includes 240 vehicle trips to the temporary vehicle storage facility per day. Though the DEIR claims this is fewer trips and vehicle miles in the region because the site is closer to the Port than existing storage facilities, this is increasing vehicle traffic to a site adjacent to the Ormond Beach Wetlands and important hunting habitat for Peregrine Falcons. Studies on Peregrine Falcon mortality have found that collisions with motorized vehicles make up a significant percentage of deaths for fledgling, juvenile, and adult falcons (Attachment 1112). As mentioned in the water quality impacts section of this letter, the bioaccumulation of metals and other pollutants originating from this Project may impact California Least Terns and other foraging sea and shore birds. Terns, plovers, and other shore birds are important sources of prey for Peregrine Falcons, which are apex predators that specialize in hunting avian species. Bioaccumulation of metals and toxicants could have an even more severe effect on falcons since they prey on birds that are already affected by bioaccumulation. Heavy metals can significantly limit immune mechanisms in birds of prey, and increase their susceptibility to bacteria and parasite infection (Attachment 1213). Since the DEIR completely failed to recognize the Peregrine Falcon and its habitat in the Project and surrounding areas, there was no analysis on potential impacts to the fully protected species.

The DEIR must include an analysis of impacts on Peregrine Falcons and must include Mitigation Measures for these impacts.

Further, the Project’s location is connected to a greater wildlife corridor and the MND failed to analyze how the Project will impact wildlife accessing and using the neighboring wetlands. The 12 Gahbauer, Marcel & Bird, David & Clark, Kathleen & French, Tom & Brauning, Dan & Mcmorris, F.. (2015). Productivity, Mortality, and Management of Urban Peregrine Falcons in Northeastern North America. The Journal of Wildlife Management. 79. 10.1002/jwmg.803. 13 Pyzik, E., Dec, M., Stępień-Pyśniak, D., Marek, A., Piedra, J., Chałabis-Mazurek, A., Szczepaniak, K., & Urban-Chmiel, R. (2021). The presence of pathogens and heavy metals in urban peregrine falcons (Falco peregrinus). Veterinary world, 14(7), 1741–1751. https://doi.org/10.14202/vetworld.2021.1741- 1751
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Project’s proximity to Ormond Beach Wetlands and future designation as Upland Transitional Zone habitat makes the Project area an important habitat for wetland species and species that rely on transitional habitat zones. UTZs provide wildlife habitat, high tide refugia for wetland species, and vital space for the wetland to migrate in response to climate change and sea level rise (Attachment 1314, pg. 3-427). The City must conduct an analysis to determine the impacts of vehicle storage, grading, fencing, and hazardous materials entering the waterways on the wildlife corridor associated with the area and the wetlands.

DEIR also completely failed to analyze the Project’s impacts on the White-tailed Kite, a fully protected species under California Law. There is no mention of the White-tailed Kite in the DEIR, even though the species is found frequently in Ventura County, Ormond Beach Wetlands, and hunting in open spaces and along roadways. The DEIR completely failed to analyze potential impacts the project may have on any raptor species in the Project area. 1) The project will be grading and graveling 34 acres of open space. Though this lot may be disturbed, the Project site is habitat for prey species like mice, voles, gophers, snakes, song birds, and ground squirrels. Left as it is, the space is 34 acres of hunting habitat for White-tailed Kites, Cooper’s Hawks, Sharp-shinned Hawks, Northern Harriers, Red-shouldered Hawks, Red-tailed hawks, Great Horned Owls, Barn Owls, Burrowing Owls, Merlins, American Kestrels, and Peregrine Falcons. 2) The project will be increasing vehicle traffic with 240 vehicle trips to the Project site per day. A study conducted on North American urban raptor species found that vehicular strikes were the leading cause of mortality for 39% of the raptor species studied (Attachment 1415). 3) The temporary vehicle storage facility may introduce heavy metals pollution to the site and increase these pollutants’ concentrations in the adjacent waterways and wetlands. A review of bioaccumulation of heavy metals in the food web found that carnivorous birds experience the highest concentration of toxic heavy metals as a result of bioaccumulation of these pollutants (Attachment 1516). The DEIR completely failed to look into possible pathways for the Project’s pollutants to enter the food web and impact sensitive birds of prey like the White-tailed Kite. 14 Brian Fulfrost, Meg Marriott, Christina Sloop, David Thomson, Laura Valoppi, Management of MarshUpland Transitional Habitats 15 Hager, Stephen. (2009). Human-Related Threats to Urban Raptors. Journal of Raptor Research. 43. 210-226. 10.3356/JRR-08-63.1.
16 Hazrat Ali & Ezzat Khan (2019) Trophic transfer, bioaccumulation, and biomagnification of nonessential hazardous heavy metals and metalloids in food chains/webs—Concepts and implications for 738
Though the DEIR included the Burrowing Owl in its meager species list, it did not include any analysis of impacts to the species. As mentioned above, the Project site comprises 34 acres of habitat used by multiple rodent species, including ground squirrels. Burrowing Owls depend on burrowing mammal species, especially ground squirrels, for their breeding habitat and burrows.

Burrow availability is a key limiting resource for Burrowing Owls. Ground squirrels are essential for providing habitat and the recovery of the Burrowing Owl (Attachment 1617). By grading, graveling, and turning this area into a vehicle storage facility, the Project will remove 34 acres of possible breeding, burrowing, and foraging habitat for the Burrowing Owl.

Without analyzing the negative impacts that the Project will have on wildlife, especially endangered and threatened species, the City failed to provide sufficient disclosure of the Project’s environmental effects to allow the public and decision makers to evaluate and comment on the project’s environmental consequences.

Air Quality
The DEIR’s analysis of air quality and greenhouse gas impacts lacks any information regarding increased emissions from cold-starting engines. If 240 vehicles per day will be started and driven to the vehicle storage facility, that is 240 cold-starts per day. These vehicles will also be started and driven off the parking facility to distributors and customers regularly. The DEIR also states that up to 30,000 vehicles will be stored at this facility annually, bringing the total to at least 60,000 cold starts per year (engine ignition when leaving the Port, and engine ignition when leaving the storage facility). Catalytic systems that vehicles use to reduce greenhouse gas emissions are only designed to work at the vehicles’ normal operating temperature. When a vehicle is cold started, carbon monoxide and total hydrocarbon emissions increase significantly wildlife and human health, Human and Ecological Risk Assessment: An International Journal, 25:6, 1353- 1376, DOI: 10.1080/10807039.2018.1469398
17 See Attachment 16 for the Field Notes Entry from the Carlsbad Fish and Wildlife Office. 739
over normal driving conditions (Attachment 1718). The DEIR must include a full analysis of the Project’s greenhouse gas emissions, including increased emissions associated with cold-start.

While the DEIR did analyze specific localized emissions, there is no discussion on how the emissions will contribute to climate change and sea level rise contributing to the retreating wetlands. Further there is no discussion on how the Project hindering the goals of Assembly Bill 32 “in reducing … annual emissions of 14 tons of carbon dioxide equivalent for every man, woman and child in California down to about 10 tons per person by 2020… [and the fact that] [e]very part of California's economy needs to play a role in reducing greenhouse gas emissions.”19 The DEIR fails to mitigate against or analyze the significant direct, indirect, and cumulative impacts, thus the DEIR must fully analyze the issue and provide the necessary mitigation measures needed.

Traffic Congestion
The DEIR misleads the public concerning the Project’s impacts on traffic congestion in South Oxnard. The DEIR states that there will be less than significant impact on traffic congestion because these vehicles would normally be sent to other facilities in the region. This is misleading and a poor analysis of the Project’s impacts. There will be 240 vehicle trips to the Project site per day associated with this project. That is 240 more vehicles on the road per day traveling to the Project site. Current operations have these vehicles moving to storage by car carrier to other facilities and impacting traffic elsewhere in the county. The DEIR fails to analyze specific impacts to traffic congestion in the community surrounding the Project area. South Oxnard is already burdened by an industrialized coastline and continuous shipping of freight and cargo along Hueneme Rd. The DEIR must include this analysis, focused on South Oxnard and the cumulative traffic impacts to which this project would contribute.

DEIR is Inconsistent with the City of Oxnard’s duty to address Environmental Justice in Government Planning
18 Christos Dardiotis, Giorgio Martini, Alessandro Marotta, Urbano Manfredi. Low-temperature cold-start gaseous emissions of late technology passenger cars. Applied Energy. Volume 111. 2013. Pages 468- 478. ISSN 0306-2619. https://doi.org/10.1016/j.apenergy.2013.04.093. 19 Center for Biological Diversity v. Department of Fish & Wildlife (2015) 62 Cal. 4th 204, 220. 740
The DEIR fails to mention the City of Oxnard’s requirement to address Environmental Justice in the City’s General Plan, as is required by SB 1000. The Project would have major impacts on disproportionately burdened communities in South Oxnard. According to the Office of Environmental Health Hazard Assessment (OEHHA) and their program, CalEnviroScreen 3.0, Oxnard is a community disproportionately burdened by environmental pollution. The program identifies the region, where the Project is located, is in the 98th percentile for the pollution burden rating. This census district had the highest Pollution Burden Percentile out of the Oxnard districts and is considered to be a disadvantaged community under SB535. The DEIR ignored the community’s comments and requests that the DEIR analyze the extent to which the Project’s cumulative impacts on air quality, traffic congestion, aesthetics, and impacts from discharge of hazardous materials (including trash and metals) into receiving waterways will increase the pollution burdens felt by the Oxnard disproportionately burdened community. The City must conduct further analysis of the Project’s cumulative impacts on the Oxnard community, as a disadvantaged community that is already disproportionately burdened by environmental pollution. Failure to include this analysis would result in the DEIR being inconsistent with the City of Oxnard’s 2030 General Plan and the City’s failure to comply with SB 1000.
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Conclusion
As discussed at length in this letter, the DEIR utterly failed to analyze the full impacts the Project would have on cultural resources, water quality, wetlands, biological resources, air quality, traffic congestion, and environmental justice. The DEIR also failed to analyze the project as a whole and failed to inform the public of the Port of Hueneme’s full expansion plan, which includes the 250-acre permanent vehicle storage facility. The EIR must be redrafted to include this full analysis, and must include a complete analysis of the Project’s impacts to the environment. The City of Oxnard cannot proceed with this woefully inadequate environmental review.

Mati Waiya
Executive Director
Wishtoyo Chumash Foundation
Tevin Schmitt
Watershed Scientist
Wishtoyo Chumash Foundation
Eva Pagaling
Watershed Science Intern
Wishtoyo Chumash Foundation
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10/20/22, 3:44 PM City of Oxnard Mail - [Ask Planning Action] Fw: Port of Hueneme request for Vehicle Storage Facility at Ormond Beach https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747247856123980782&simpl=msg-f%3A1747247856… 1/3 Solis, Rogelio <[email protected]>
[Ask Planning Action] Fw: Port of Hueneme request for Vehicle Storage Facility at Ormond Beach
2 messages
Irene <[email protected]> Thu, Oct 20, 2022 at 3:36 PM To: "[email protected]" <[email protected]>, "[email protected]" <[email protected]> Cc: Larry Godwin <[email protected]>, "[email protected]" <[email protected]>, Aaron Greer <[email protected]>, "Chair, Ventura County Surfrider" <[email protected]>, "[email protected]" <[email protected]>
Sent from Windows Mail
From: Irene
Sent: Thursday, October 20, 2022 3:03 PM
To: [email protected]
Cc: Larry Godwin
To: the City of Oxnard and Planning Commissioners
Re: Port of Hueneme request for Vehicle Storage Facility at Ormond Beach a. Adopt a Resolution certifying Final Environmental Impact Report (EIR) No. 22-01 for the Port of Hueneme - Temporary Outdoor Vehicle Storage Facility (Governor's Office of Planning and Research State Clearinghouse No. 2020069039); and b. Adopt a Resolution approving Planning and Zoning Permit No. 18-500-02 (Special Use Permit) for a vehicle storage facility, subject to certain findings and conditions.

For Oxnard,
Please OPPOSE the Port of Hueneme Vehicle Storage at this location.

Oxnard can do better! A car park at Ormond is an imposition efforts any hope for a public project at Ormond.

Despite the Port’s claim that the project is temporary, it is an eyesore to the adjacent community already in need of improvements, and a threat to existing rare native coastal environment. This rare parcel is virtually the last remaining native land on our coastline… needs to be protected for a preserve at Ormond for the generations!
Irene Rauschenberger
Oxnard Resident
Sent from Windows Mail
Dobrowalski, Jay <[email protected]> Thu, Oct 20, 2022 at 3:37 PM To: "Loera, Miriam" <[email protected]>, Rogelio Solis <[email protected]> Hi Roy and Miriam,
Here is another comment letter.

Thanks,
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10/20/22, 3:44 PM City of Oxnard Mail - [Ask Planning Action] Fw: Port of Hueneme request for Vehicle Storage Facility at Ormond Beach https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747247856123980782&simpl=msg-f%3A1747247856… 2/3 Jay Dobrowalski | Planning Supervisor
Community Development Department
214 S C Street | Oxnard, CA 93030
O: 805.385.3948 | F: 805.385.7417
www.oxnard.org
Effective February 14, 2022, the Service Center and all public-interfacing City buildings will be open to the public.

Online services remain available through our online portal at www.oxnard.org/planning General inquiries should be sent via email to [email protected].

For new applications, email us at [email protected]. Large projects can be shipped with prior authorization. Smaller projects may be submitted via email.

For existing applications, contact your assigned Case Planner by direct email.

For the most up to date information on COVID-19 please visit https://www.venturacountyrecovers.org/ ---------- Forwarded message ---------
From: Chaparro, Rose <[email protected]>
Date: Thu, Oct 20, 2022 at 3:27 PM
Subject: Fwd: Port of Hueneme request for Vehicle Storage Facility at Ormond Beach To: Joe Pearson II <[email protected]>, Jay Dobrowalski <[email protected]>, Miriam Loera <[email protected]>, City Clerk <[email protected]> Hi Joe,
FYI - Additional public written comments received.

Rose Chaparro, City Clerk
City of Oxnard
300 West Third Street
Oxnard, CA 93030
Main Line: (805) 385-7803
[email protected]
---------- Forwarded message ---------
From: Irene <[email protected]>
Date: Thu, Oct 20, 2022 at 3:03 PM
Subject: Port of Hueneme request for Vehicle Storage Facility at Ormond Beach To: [email protected] <[email protected]>
Cc: Larry Godwin <[email protected]>
To: the City of Oxnard and Planning Commissioners
Re: Port of Hueneme request for Vehicle Storage Facility at Ormond Beach a. Adopt a Resolution certifying Final Environmental Impact Report (EIR) No. 22-01 for the Port of Hueneme - Temporary Outdoor Vehicle Storage Facility (Governor's Office of Planning and Research State Clearinghouse No. 2020069039); and 744
10/20/22, 3:44 PM City of Oxnard Mail - [Ask Planning Action] Fw: Port of Hueneme request for Vehicle Storage Facility at Ormond Beach https://mail.google.com/mail/u/0/?ik=94536ae8d9&view=pt&search=all&permthid=thread-f%3A1747247856123980782&simpl=msg-f%3A1747247856… 3/3 b. Adopt a Resolution approving Planning and Zoning Permit No. 18-500-02 (Special Use Permit) for a vehicle storage facility, subject to certain findings and conditions.

For Oxnard,
Please OPPOSE the Port of Hueneme Vehicle Storage at this location; Oxnard can do better! A car parking lot at Ormond is an imposition on efforts made for decades for an Ormond Beach public project, Oxnard lets get it done! Despite the Port’s claim that the project is temporary, it is an eyesore to the adjacent community already in need of improvements, and a threat to existing rare native coastal environment.

Important is Oxnard’s coastline is virtually built out, this rare parcel is virtually the last remaining native land on our coastline… that should be developed into a preserve for the generations! [Quoted text hidden]
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FINDINGS OF FACT
PORT OF HUENEME – TEMPORARY OUTDOOR

VEHICLE STORAGE FACILITY PROJECT

ENVIRONMENTAL IMPACT REPORT
SCH No. 2020069039

CITY OF OXNARD
214 South C Street
Oxnard, California 93030
September 2022
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Printed on 30% post-consumer recycled material.
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Port of Hueneme – Temporary Outdoor Vehicle Storage Facility Environmental Impact Report
Findings of Fact – September 2022 i
Table of Contents
Volume I PAGE NO.

1.0 Introduction ..........................................................................................................................1

1.1 Purpose...................................................................................................................................... 1

1.1.1 Custodian and Location of Records .............................................................................2

1.2 Project Description .................................................................................................................... 2

1.2.1 Project Objectives........................................................................................................3

1.2.2 Discretionary Actions...................................................................................................3

2.0 CEQA Findings of Independent Judgement..............................................................................5

2.1 Independent Review and Analysis............................................................................................. 5

2.2 Summary of Impacts.................................................................................................................. 5

2.3 Impacts Determined to Be Less Than Significant with Mitigation............................................. 6

2.3.1 Aesthetics.....................................................................................................................6

2.3.2 Biological Resources ....................................................................................................7

2.3.3 Cultural and Tribal Cultural Resources.........................................................................9

2.3.4 Geology and Soils.......................................................................................................12

2.3.5 Noise ..........................................................................................................................13

2.3.6 Police Protection........................................................................................................14

2.3.7 Transportation ...........................................................................................................14

3.0 Findings on Project Alternatives...........................................................................................17

3.1 Alternatives Considered and Eliminated During the Scoping/Project Planning Process.........17

3.2 Alternatives Selected for Further Analysis ..............................................................................19

3.2.1 Alternative One: No Project Alternative....................................................................19

3.2.2 Alternative Two: Two Existing Off-Port Vehicle Storage Locations...........................20

3.2.3 Alternative Three: Existing Zoning .............................................................................21

3.2.4 Environmentally Superior Alternative .......................................................................22

4.0 General CEQA Findings.........................................................................................................25

4.1 Findings Regarding Recirculation ............................................................................................25

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1.0 INTRODUCTION
These Findings of Fact (Findings) for the Port of Hueneme – Temporary Outdoor Vehicle Storage Facility Project (project) are made pursuant to the California Environmental Quality Act (CEQA) (California Public Resources Code [PRC] Section 21000 et seq.), specifically PRC Sections 21081, 21081.5, and 21081.6, and the CEQA Guidelines (14 CCR 15000 et seq.), specifically Sections 15091 and 15093. The Final Environmental Impact Report (EIR) examines the full range of potential effects of construction and operation of the project, identifies standard mitigation practices that could be employed to reduce, minimize, or avoid those potential effects, and evaluates alternatives to the project. The Final EIR is incorporated into these Findings by reference.

1.1 PURPOSE
PRC Section 21081, and CEQA Guidelines Section 15091 require that the lead agency, in this case the City of Oxnard (City), prepare written findings for identified significant effects, accompanied by a brief explanation of the rationale for each finding. Specifically, CEQA Guidelines Section 15091 states, in part, that:
a) No public agency shall approve or carry out a project for which an EIR has been certified which identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings for each of those significant effects, accompanied by a brief explanation of the rationale for each finding. The possible findings are:
1) Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the Final EIR.
2) Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency. 3) Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the Final EIR.

In accordance with PRC Section 21081, and CEQA Guidelines Section 15093, whenever significant effects cannot be mitigated to below a level of significance, the decision‐making agency is required to balance, as applicable, the benefits of the project against its unavoidable environmental risks when determining whether to approve the project. If the benefits of a project outweigh the unavoidable adverse environmental effects, the adverse effects may be considered “acceptable.” In that case, the decisionmaking agency may prepare and adopt a Statement of Overriding Considerations, pursuant to the CEQA Guidelines. State CEQA Guidelines Section 15091 does not require specific findings to address environmental effects that an EIR identifies as “no impact” or a “less than significant” impact.

Implementation of the proposed project would not result in any impacts that are considered significant, adverse, or unavoidable. All environmental issues were determined to result in less than significant impacts or can be reduced to less-than-significant levels with the incorporation of mitigation measures.

Thus, the City is not required to adopt a statement of overriding considerations. 753
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Section 15093 of the CEQA Guidelines states the following:
a) CEQA requires the decision-making agency to balance, as applicable, the economic, legal, social, technological, or other benefits of a proposed project against its unavoidable environmental risks when determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered “acceptable.”
b) When the lead agency approves a project which will result in the occurrence of significant effects which are identified in the Final EIR but are not avoided or substantially lessened, the agency shall state in writing the specific reasons to support its action based on the Final EIR and/or other information in the record. The statement of overriding considerations shall be supported by substantial evidence in the record. c) If an agency makes a statement of overriding considerations, the statement should be included in the record of the project approval and should be mentioned in the notice of determination. This statement does not substitute for, and shall be in addition to, findings required pursuant to Section 15091.

The Final EIR for the project identified potentially significant effects that could result from the project.

The City finds that the inclusion of certain mitigation measures as part of the approval of the project would reduce these effects to less-than‐significant levels.

The City also finds that the Mitigation Monitoring and Reporting Program for the project, which is incorporated by reference and made part of these Findings, meets the requirements of PRC Section 21081.6 by providing for the implementation and monitoring of measures intended to mitigate potentially significant effects of the proposed project.

Pursuant to PRC Section 21082.1(c)(3), the City also finds that these Findings reflect the City’s independent judgment as the lead agency for the project.

1.1.1 Custodian and Location of Records
The documents and other materials that constitute the Record of Proceedings for the City’s actions related to the project are located at the City of Oxnard, 214 South C Street, Oxnard, California 93030. The City is the custodian of the Record of Proceedings for the proposed project.

1.2 PROJECT DESCRIPTION
The project would include the construction and operation of a temporary outdoor vehicle storage facility (vehicle storage facility or facility) for a maximum of 5 years on the approximately 34-acre project site.

The facility would include the following:
• Vehicle parking area with gravel base
• Temporary guard house
• Portable restroom
• Perimeter site lighting
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• Security fencing (6-feet-high)
• Landscaping
• Site drainage
• Associated infrastructure improvements (e.g., curb cuts, apron) The temporary outdoor vehicle storage facility includes approximately 27.5 acres to accommodate parking for up to 4,944 vehicle spaces, which equates to a ratio of 180 spaces per acre.

Various permits, approvals, and actions by the City of Oxnard and various public agencies may be required to execute and implement the proposed project. The permits from the lead agency that are necessary include:
• City of Oxnard approval of Special Use Permit
• City of Oxnard issuance of Grading Permit
• City of Oxnard issuance of Building and Safety Permits • City of Oxnard Fire Department approval of proposed site improvement • City of Oxnard – water, sewer, and storm drain connection permits

1.2.1 Project Objectives
The Applicant has identified the following objectives for the project.

1. Facilitate commercial success for Port clients to ensure they keep their business in the region, keep 167 local citizens employed, and create the potential for more than 30 jobs in the future.

2. Reduce and consolidate, where feasible, Port vehicle customer reliance on off-Port satellite storage locations, which would reduce the need for car carrier truck movement to distribute vehicles to those locations. The consolidation of vehicle storage closer to the Port would enable a more efficient movement of vehicles and reduce the need for heavy duty truck movement.

3. Provide operational flexibility for the transport of goods (vehicles) that already flow through the Port for purposes of sale, while maintaining existing goods movement and the existing number or capacity of cargo ships.

1.2.2 Discretionary Actions
A discretionary action is an action taken by an agency that calls for the exercise of judgment in deciding whether to approve or how to carry out a project. The project would require consideration of the following discretionary actions by the City:
• Certification of the Final EIR and adoption of a Mitigation Monitoring and Reporting Program • Approval of the Special Use Permit
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2.0 CEQA FINDINGS OF INDEPENDENT JUDGEMENT

2.1 INDEPENDENT REVIEW AND ANALYSIS
Under CEQA, the lead agency must (1) independently review and analyze the EIR; (2) circulate draft documents that reflect its independent judgment; (3) as part of the certification of an EIR, find that the EIR or declaration reflects the independent judgment of the lead agency; and (4) submit copies of the documents to the State Clearinghouse if there is state agency involvement or if the project is of statewide, regional, or area-wide significance (PRC Section 21082.1[c]).

These Findings reflects the City’s independent judgment. The City has exercised independent judgment in accordance with CEQA Section 21082.1(c)(3) in retaining its own environmental consultant in the preparation of the EIR, as well as reviewing, analyzing, and revising material prepared by the consultant.

Having received, reviewed, and considered the information in the EIR, as well as any and all other information in the record, the City hereby makes findings pursuant to and in accordance with CEQA Sections 21081, 21081.5, and 21081.6.

2.2 SUMMARY OF IMPACTS
The EIR identified a number of direct and indirect potentially significant environmental effects (or “impacts”) resulting from the project. These potentially significant effects can be reduced to a less than significant level through the adoption of feasible mitigation measures.

As identified in Chapters 4, 5, 6, and 7 of the EIR, significant environmental impacts would not occur with regard to the following issues: agriculture and forestry resources, air quality, energy, greenhouse gas emissions, hazards and hazardous materials, hydrology and water quality, land use and planning, mineral resources, population and housing, parks and recreation, wildfire and fire protection, schools, water, wastewater, and solid waste. Additionally, significant environmental impacts would not occur with regard to the following issues: biological resources (federally protected wetlands, wildlife movement, consistency with an adopted habitat conservation plan; and cumulative impacts to biological resources); cultural resources (historical resources; paleontological resources; and cumulative impacts to cultural resources); geology and soils (rupture of an earthquake fault; unstable soils–landslides; expansive soil; seiches and tsunamis; dredging and other maintenance activities); noise (exceedance of established or applicable standards in the local general plan or noise ordinance or other agencies resulting in a temporary, periodic, or permanent increase in ambient noise levels; groundborne vibration or noise; excessive noise levels within the airport land use plan for Oxnard Airport or within 2 miles of Naval Base Ventura County Point Mugu; or cumulative noise impacts); police protection (impacts during operations); or transportation (within the airport land use plan for Oxnard Airport or within 2 miles of Naval Base Ventura County Point Mugu to excessive noise levels; Level of Service standards; change in air traffic patterns; hazards due to a design feature or incompatible uses; emergency access during operations; conflict with adopted policies, plans, or programs supporting alternative transportation; CEQA Guidelines Section 15064.3 Subdivision (B); and cumulative traffic impacts). State CEQA Guidelines section 15091 does not require specific findings to address environmental effects that an EIR identifies as “no impact” or a “less than significant” impact. As such, these issue areas are not discussed further within this document. 757
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As identified in Chapters 4, 5, 6, and 7 of the EIR, the project would mitigate, avoid, or substantially lessen to below a level of significance direct, indirect, and/or cumulative potentially significant environmental effects with regard to the following issues: aesthetics (visual character/quality), biological resources (nesting birds), cultural resources (archaeological resources; human remains; tribal cultural resources), geology and soils, noise (non-human species), police protection during construction, and transportation (emergency access).

2.3 IMPACTS DETERMINED TO BE LESS THAN SIGNIFICANT WITH MITIGATION The following summarizes the potentially significant impacts of the proposed project identified in the Final EIR that would be less than significant with implementation of mitigation measures.

2.3.1 Aesthetics

2.3.1.1 AESTHETIC IMPACT TO VISUAL CHARACTER/QUALITY OF THE SITE AND

ITS SURROUNDINGS

DESCRIPTION OF POTENTIAL IMPACT
The project would have a substantial adverse impact to the visual character/quality of the site and its surroundings.

MITIGATION MEASURE(S) AND STANDARD CONDITION(S)
Standard Conditions
SC AES-1 Prior to the issuance of building permits, the Applicant shall submit two copies of landscape and irrigation plans, along with appropriate permit application and fees, to the Development Services Division and obtain approval of such plans.

SC AES-2 Prior to the issuance of a certificate of occupancy, the Applicant shall install landscape and automatic irrigation systems.

SC AES-3 Prior to the issuance of a certificate of occupancy, the Applicant shall provide a watering schedule to the site manager and to the Planning Division or designee. The irrigation system shall include automatic rain shut-off devices, or instructions on how to override the irrigation system during rainy periods.

SC AES-4 The Applicant shall install an irrigation system that includes a water sensor shut-off device as a water conservation measure.

SC AES-5 All trees planted or placed on the property by the Applicant shall be a minimum of 24-inchbox size. All shrubs and vines shall be at least five-gallon size, except as otherwise specified by the Special Use Permit.

SC AES-6 The Applicant shall properly maintain landscape planting and all irrigation systems as required by the City Code and as specified by Special Use Permit for the life of the project.

Failure of the Applicant to do so may result in the revocation of this permit and initiation of legal proceedings against Applicant to ensure compliance. 758
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SC AES-7 The Applicant agrees that the project has aesthetic impacts arising from conversion of undeveloped land to developed land, which the landscaping improvements for the project are intended to mitigate. The Applicant further agrees that the landscaping improvements must be maintained for the life of the permit in order to continue to mitigate such impacts.

Mitigation Measures
MM AES-1 The Applicant shall install chain-link fencing with top and bottom rails to provide support for plants.

MM AES-2 In locations where chain-link gates are proposed and plants cannot grow, the Applicant shall install either privacy slats on the chain-link gates or solid gates to block views onto the site.

MM AES-3 Prior to vegetation maturation that effectively buffers views onto the project site, the Applicant shall install screening fabric on the chain-link fencing or other alternative temporary measures approved by the City to fill gaps in the vegetation.

MM AES-4 The Applicant shall provide visual screening of the existing water utility structure/chain-link fence enclosure on the southeast corner of Hueneme Road and Perkins Road complementary to the screening established with the project.

Findings
As discussed in Section 5.1, Aesthetics, of the EIR, the proposed project would be compatible with surrounding development, including the Hueneme Industrial Park, shopping center, and the City of Oxnard Advanced Water Purification Facility, and the proposed use is allowed in the M-1-PD (Light Manufacturing Zone with Planned Development Additive Zone) zone. While the proposed project incorporates screening and landscape measures, it is important that the proposed measures are properly installed and maintained. Thus, visual character/quality impacts are considered potentially significant. The proposed project would be subject to Standard Conditions SC AES-1 through SC AES-7 that require landscape and irrigation plans, and the proper installation and maintenance of site landscaping and irrigation systems in compliance with City Code Section 16-165, and Mitigation Measures MM AES-1 through MM AES-4, that ensure the site landscaping and the fencing provide adequate screening. Thus, implementation of Standard Conditions SC AES-1 through SC AES-7 and Mitigation Measures MM AES-1 through MM AES-4 would result in less than significant visual character/ quality impacts associated with the project.

2.3.2 Biological Resources

2.3.2.1 BIOLOGICAL RESOURCES IMPACT TO NESTING BIRDS

DESCRIPTION OF POTENTIAL IMPACT
The project would have a substantial adverse impact to suitable habitat for the burrowing owl (Athene cunicularia) and the California horned lark (Eremophila alpestris actia) and to ground-nesting bird species, including the western meadow lark (Sturnella neglecta), burrowing owl, and the California horned lark.

Mitigation Measure(s)
MM BIO-1 To avoid the disturbance of nesting and special-status birds, including raptor species protected by the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code 759
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(CFGC), activities related to the project including, but not limited to, vegetation removal, ground disturbance, demolition, and construction shall occur outside of the bird breeding season (February 1 through August 31), if practicable.

If construction must begin during the breeding season, then a pre-construction nesting bird survey shall be conducted no more than seven (7) days prior to initiation of ground disturbance and vegetation removal activities.

The pre-construction nesting bird survey shall be conducted on foot inside the project site, including a 50-foot buffer and in inaccessible areas (e.g., private lands) from afar using binoculars, to the extent practicable. The survey shall be conducted by a biologist familiar with the identification of avian species known to occur in southern California.

If nests are found, an avoidance buffer (dependent upon the species, the proposed work activity, and existing disturbances associated with land uses outside of the site) shall be determined and demarcated by the biologist with bright orange construction fencing, flagging, construction lathe, or other means. All construction personnel shall be notified as to the existence of the buffer zone and to avoid entering the buffer zone during the nesting season. No ground-disturbing activities shall occur inside this buffer until the avian biologist has confirmed that breeding/nesting is complete and the young have fledged the nest.

Encroachment into the buffer shall occur only if authorized by the qualified biologist, who shall monitor activities to ensure that nesting birds are not adversely affected.

In addition, for any construction activities, the applicant shall retain the services of a qualified biologist or environmental resources specialist to conduct sensitive species surveys (including birds and other terrestrial species) of the project site. The environmental resources specialist shall conduct surveys no more than two weeks prior to the approved construction activities to detect any active sensitive species. In the event that any sensitive species are present in or adjacent to the construction area but do not exhibit reproductive behavior and are not within the estimated breeding/reproductive cycle of the subject species, the environmental resources specialist shall implement a resource avoidance program with sufficient buffer areas to ensure adverse impacts to such resources are avoided.

Findings
As discussed in Section 5.4, Biological Resources, of the EIR, potential ground nesting species, such as the western meadow lark, identified on-site during the field reconnaissance survey, could nest on-site.

Additionally, there is the potential for the burrowing owl, known to winter in the Oxnard Plain, and California horned lark to occur on site. Construction activities associated with the proposed project could adversely affect nesting birds if they are present on or adjacent to the site, through direct mortality or abandonment of nests. The loss of a nest due to construction activities would be a violation of the MBTA and California Fish and Game Code Section 3503. Thus, implementation of the proposed project would result in potentially significant impacts to the following ground-nesting bird species: western meadow lark, burrowing owl, and California horned lark. Mitigation Measure MM BIO-1 would reduce project-related impacts to less than significant by encouraging site disturbance and construction activities outside of the bird breeding season or a pre-construction nesting bird survey and application of the biologist’s recommendations during the site disturbance and construction activities. Implementation of MM BIO-1 would reduce impacts to suitable habitat for the burrowing owl and the California horned lark, and impacts to ground-nesting bird species, including the western meadow lark, burrowing owl, and the California horned lark to less than significant. 760
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2.3.3 Cultural and Tribal Cultural Resources

2.3.3.1 CULTURAL AND TRIBAL CULTURAL RESOURCES IMPACT TO

ARCHEOLOGICAL RESOURCES

DESCRIPTION OF POTENTIAL IMPACT
The project could result in impacts to potentially undiscovered archaeological resources.

Mitigation Measure(s)
MM CUL-1 Archaeological Monitoring. Prior to ground disturbance activities, the Applicant and/or subsequent responsible parties shall retain a Principal Investigator/Archaeologist, meeting the Secretary of the Interior’s Standards, and with experience in California prehistoric and historic resources (experience within Ventura County preferred), to complete the following:
compose a Cultural Resource Monitoring and Inadvertent Discovery Plan (Plan), manage archaeological monitoring and address any inadvertent discoveries identified during project implementation. The purpose of the Plan is to outline cultural monitoring (archaeological and Native American/Tribal) protocols and a program of treatment and mitigation in the case of an inadvertent discovery of cultural (archaeological or Native American/Tribal) resources during ground-disturbing phases and to provide for the proper identification, evaluation, treatment, and protection of any cultural resources in accordance with CEQA throughout the duration of the project. Existence and importance of adherence to this Plan shall be stated on all projectsite plans intended for use by those conducting the ground disturbing activities.

The Principal Investigator/Archaeologist shall manage archaeological monitoring conducted by archaeological technicians during initial ground disturbances. Initial excavation is defined as initial construction-related earth moving of sediments from their place of deposition. As it pertains to cultural monitoring (archaeological or Native American/Tribal), this definition excludes movement of sediments after they have been initially disturbed or displaced by project-related construction. The retained Principal Investigator/Archaeologist shall oversee and establish monitoring efforts as needed (increase, decrease, or discontinue monitoring frequency) based on the observed potential for construction activities to encounter cultural deposits or material. The archaeological monitor shall be responsible for maintaining daily monitoring logs. The requirement for archaeological monitoring shall be noted on all construction plans to ensure implementation. Upon completion of all ground disturbing activities, an archaeological monitoring report shall be prepared within 30 business days following completion of ground disturbance and submitted to the City for review. This report shall document compliance with approved cultural mitigation, all monitoring efforts, and include an appendix with daily monitoring logs. The final report shall be submitted to the City and the South Central Coastal Information Center.

MM CUL-2 Native American/Tribal Monitoring - Prior to ground disturbance activities, the Applicant and/or subsequent responsible parties shall retain a Native American/Tribal monitor/entity selected from the list of California Native American Tribes (maintained by the NAHC) and that are traditionally and culturally affiliated with the geographic area of the project site. The Applicant and/or subsequent responsible parties shall make arrangements with the Native American/Tribal monitor/entity to enter into a contract with the intent of securing a total of 761
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one Native American/Tribal monitor to be present during initial ground disturbance. Initial ground disturbance is defined as initial construction-related earthmoving of sediments from their place of deposition. As it pertains to cultural resource (archaeological or Native American/Tribal) monitoring, this definition excludes movement of sediments after they have been initially disturbed or displaced by current project-related construction. The Plan created in compliance with MM-CUL-1 shall be provided to the Native American/Tribal monitor/entity under contract prior to commencement of ground disturbing activities. More than one monitor may be required if multiple areas within the projectsite are simultaneously exposed to initial ground disturbance causing monitoring to be hindered by the distance (more than 200 feet apart) of the simultaneous activities.

Findings
As discussed in Section 5.5, Cultural Resources, of the EIR, archival research indicated that there is one known archaeological site within a 0.25-mile radius of the project site boundaries. A foot reconnaissance of the project site in 2020 indicated two clusters (Locus1 1 and 2) of low density weathered marine shell, one chert biface fragment, and one weathered elasmobranch fish vertebra. Subsurface testing of the areas identified as Locus 1 and Locus 2 was performed and found that no known cultural resources exist within the proposed project site and based on the presence of disturbed and/or fill soils to depths below proposed depths of disturbance for the project, no impacts to known or unknown cultural resources are expected.

Nonetheless, the proposed project involves minimal on-site ground-disturbing activities (approximately 1/10th inch to 1.95 feet)2for grubbing, grading, or other activities. In addition, the installation of site drainage infrastructure could require grading of small areas to a depth of 24 inches (2 feet). On-site areas that would not be disturbed include the site’s periphery that has been previously disturbed by pipelines, roads, and the Ventura County Rail Road right-of-way. These activities could result in impacts to undiscovered archaeological resources. Mitigation Measures MM CUL-1 and MM CUL-2 require archaeological and Native American monitoring during ground disturbing activities to avoid or document any artifacts or archaeological features that may be encountered. Implementation of Mitigation Measures MM CUL-1 and MM CUL-2 reduce potentially significant impacts to less than significant.

2.3.3.2 CULTURAL AND TRIBAL CULTURAL RESOURCES IMPACT TO HUMAN REMAINS

DESCRIPTION OF POTENTIAL IMPACT
The project could disturb human remains, including those interred outside of dedicated cemeteries.

Mitigation Measure(s)
MM CUL-2 (see Section 2.3.3.1, above)
1 “Locus” is defined as the place where something is situated or occurs: site, location a center of activity, attention, or concentration. Source: Merriam-Webster Dictionary, https://www.merriam-webster.com/dictionary/locus, accessed March 1, 2021.
2 Source: Jensen Design & Survey, Inc., Cut & Fill Depths Analysis | Grading Plan, August 2019. 762
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Findings
As discussed in Section 5.5, Cultural Resources, of the EIR, no human remains or cemeteries are known to exist in or near the project site. However, there is always the possibility that subsurface construction activities associated with the proposed project improvements, such as trenching and grading, would potentially damage or destroy previously undiscovered human remains. In the event of the accidental discovery or recognition of any human remains, CEQA Guidelines Section 15064.5; Health and Safety Code Section 7050.5; Public Resources Code Section 5097.94 and Section 5097.98 must be followed.

Implementation of Mitigation Measure MM CUL-2 would reduce potentially significant impacts associated with the discovery of human remains to less than significant.

2.3.3.3 CULTURAL AND TRIBAL CULTURAL RESOURCES IMPACT TO TRIBAL CULTURAL

RESOURCES LISTED OR ELIGIBLE FOR LISTING IN THE CALIFORNIA REGISTER OF

HISTORICAL RESOURCES, OR IN THE LOCAL REGISTER OF HISTORICAL RESOURCES AS DEFINED IN PUBLIC RESOURCES CODE SECTION 5020.1(K)

DESCRIPTION OF POTENTIAL IMPACT
The project would cause a substantial adverse change in the significance of previously undiscovered tribal cultural resources.

Mitigation Measure(s)
MM CUL-2 (see Section 2.3.3.1, above)
Findings
As discussed in Section 5.5, Cultural Resources, of the EIR, no Native American Tribes have requested formal notification from the City pursuant to AB 52. The City also reviewed the results of the archaeological study that included a records search, archival and background research as well as a pedestrian survey and subsurface testing of the project site to further inform and consider the potential of tribal cultural resources to exist within the project site. All efforts to determine whether tribal cultural resources originating from the project site exist and may be impacted by proposed project implementation returned negative. Given the presence of the Ventureño Chumash in and around the City of Oxnard over millennia, and the proximity of a known site within 0.25 miles of the project site, there is the potential for construction of the project to impact unidentified tribal cultural resources. Thus, grounddisturbing activities, such as grading or excavation, could disturb previously unidentified subsurface resources. Implementation of Mitigation Measure MM CUL-2 would reduce any potentially significant impacts to previously undiscovered tribal cultural resources to less than significant.

2.3.3.4 CULTURAL AND TRIBAL CULTURAL RESOURCES IMPACT TO TRIBAL CULTURAL

RESOURCES DETERMINED BY THE LEAD AGENCY, IN ITS DISCRETION AND

SUPPORTED BY SUBSTANTIAL EVIDENCE, TO BE SIGNIFICANT PURSUANT TO 763
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THE CRITERIA SET FORTH IN SUBDIVISION (C) OF PUBLIC RESOURCES CODE SECTION 5024.1

DESCRIPTION OF POTENTIAL IMPACT
The project would result in potentially significant impacts to previously undiscovered tribal cultural resources.

Mitigation Measure(s)
MM CUL-2 (see Section 2.3.3.1, above)
Findings
Refer to Section 2.3.3.4, above.

2.3.4 Geology and Soils

2.3.4.1 GEOLOGICAL IMPACT TO SEISMIC GROUND SHAKING

DESCRIPTION OF POTENTIAL IMPACT
The project would directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking.

Mitigation Measure(s)
MM GEO-1 Prior to issuance of grading permits, the Applicant or designee shall prepare and submit a soils, geologic, and structural evaluation report prepared by a registered soils engineer and/or structural engineer for review and approval by the City of Oxnard Building and Engineering Division. The recommendations in the report shall be implemented during site grading and construction.

Findings
As discussed in Section 5.7, Geology and Soils, of the EIR, there are a number of potentially active/active faults in the region including the Oak Ridge, Pitas Point-Ventura, Anacapa, and Malibu Coast faults; however, these faults are located approximately 1.5 miles to 10 miles from the City. Although some structural damage is typically not avoidable during a large earthquake, the proposed project would be constructed to meet existing construction ordinances and the California Building Code in order to protect against building collapse and major injury during a seismic event. The California Building Code includes specific design measures, which are based on the determination of Site Classification and Seismic Design Categories specific to the project site. These design measures are intended to maximize structural stability in the event of an earthquake. Thus, adherence to the California Building Code requirements, as well as Mitigation Measure MM GEO-1 would reduce impacts related to strong seismic shaking to less than significant.
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2.3.4.2 GEOLOGICAL IMPACT RESULTING FROM UNSTABLE SOILS AND LIQUEFACTION

DESCRIPTION OF POTENTIAL IMPACT
The project would be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and result in unstable soils and on- or off-site liquefaction.

Mitigation Measure(s)
MM GEO-1 (see Section 2.3.4.1, above)
Findings
As discussed in Section 5.7, Geology and Soils, of the EIR, a majority of the City of Oxnard is susceptible to liquefaction as a result of underlying thick alluvial deposits and high groundwater levels. In addition, the City of Oxnard is located in a Seismic Hazard Area for liquefaction according to seismic hazard mapping conducted by the California Geological Survey. To ensure that the temporary on-site structures do not experience structural damage due to liquefaction, the Applicant shall implement the recommendations in the soils, geologic, and structural evaluation report required per Mitigation Measure GEO-1 and adhere to the California Building Code requirements for the guard house, which reduce potentially significant impacts to less than significant with mitigation incorporated.

In addition, the on-site soils are characterized as unstable soils. To ensure that the temporary on-site structures do not experience structural damage due to unstable soils, the Applicant shall implement the recommendations in the soils, geologic, and structural evaluation report required per Mitigation Measure MM GEO-1 and adhere to the California Building Code requirements for the guard house, which reduce potentially significant impacts to less than significant with mitigation incorporated.

2.3.5 Noise

2.3.5.1 NOISE IMPACT TO NON-HUMAN SPECIES

DESCRIPTION OF POTENTIAL IMPACT
The project would result in noise impacts to special-status species, including the western meadow lark, burrowing owl, and the California horned lark, as well as suitable habitat for the burrowing owl and the California horned lark.

Mitigation Measure(s)
MM BIO-1 (see Section 2.3.2.1, above)
Findings
The proposed project would result in a potentially significant impact to suitable habitat for the burrowing owl and the California horned lark, as well as a potentially significant impact to ground-nesting bird species: western meadow lark, burrowing owl, and the California horned lark. With the implementation of Mitigation Measure MM BIO-1, project-related impacts to these special-status species or habitat are reduced to less than significant.
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2.3.6 Police Protection

2.3.6.1 POLICE PROTECTION IMPACTS DURING CONSTRUCTION

DESCRIPTION OF POTENTIAL IMPACT
The project would result in potential construction-related traffic impacts on the California Highway Patrol, which regulates traffic in the City.

Mitigation Measure(s)
MM PP-1 Prior to construction, the Applicant shall prepare a Traffic Control Plan for implementation during the construction phase, as deemed necessary by the City Traffic Engineer. The Plan may include the following provisions, among others:
• At least one unobstructed lane shall be maintained in both directions on the following surrounding roadways: Hueneme Road and Perkins Road.
• At any time only a single lane is available, the Applicant shall provide a temporary traffic signal, signal carriers (i.e., flag persons), or other appropriate traffic controls to allow travel in both directions.
• If construction activities require the complete closure of a roadway segment, the Applicant shall provide appropriate signage indicating detours/alternative routes.

Findings
Construction-related traffic on the project site also is not expected to result in impacts on the California Highway Patrol, which regulates traffic in the City. Slow-moving construction-related traffic on adjacent roadways could reduce optimal traffic flows and could delay emergency vehicles traveling through the area. However, this would not result in a significant impact on traffic flows because construction-related traffic would only occur during short periods of time during the day and would cease upon completion. In order to prevent construction-related traffic impacts, Mitigation Measure MM PP-1 has been included to prepare a construction traffic control plan prior to the initiation of any construction activities and would reduce potentially significant impacts to less than significant.

2.3.7 Transportation

2.3.7.1 TRANSPORTATION IMPACTS ASSOCIATED WITH INADEQUATE

EMERGENCY ACCESS

DESCRIPTION OF POTENTIAL IMPACT
The project would result in potential construction-related traffic impacts.

Mitigation Measure(s)
MM PP-1 (see Section 2.3.6.1, above)
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Findings
Slow-moving construction-related traffic on adjacent roadways could reduce optimal traffic flows and could delay emergency vehicles traveling through the area. In order to prevent construction-related traffic impacts, Mitigation Measure MM PP-1 has been included to prepare a construction traffic control plan prior to the initiation of any construction activities and reduce potentially significant impacts to less than significant.
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3.0 FINDINGS ON PROJECT ALTERNATIVES
CEQA requires that an EIR describe a range of reasonable alternatives to a project, or to the location of the project, that could feasibly attain the basic objectives of that project, and to evaluate the comparative merits of the alternatives (14 CCR 15126.6[a]). The CEQA Guidelines direct that the selection of alternatives be governed by “a rule of reason” (14 CCR 15126.6[a], [f]). CEQA directs that the scope of alternatives considered shall be limited to ones that would avoid or substantially lessen the significant effects of the project (14 CCR 15126.6[f]). Notably, this project does not result in any significant and unavoidable impacts.

3.1 ALTERNATIVES CONSIDERED AND ELIMINATED DURING THE SCOPING/

PROJECT PLANNING PROCESS
The CEQA Guidelines provide that an EIR should “identify any alternatives that were considered by the Lead Agency but were rejected as infeasible during the scoping process and briefly explain the reasons underlying the Lead Agency’s determination” (14 CCR 15126.6[c]). The following is a discussion of the project alternatives proposed during the scoping and planning process and the reasons they were not selected for detailed analysis in the EIR.

With respect to the feasibility of potential alternatives to the proposed project, CEQA Guidelines Section 15126.6(t)(l) states, “Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries … and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site.” In determining an appropriate range of proposed project alternatives to be evaluated in the EIR, a number of possible alternatives were initially considered and then rejected. Proposed project alternatives were rejected because they could not accomplish the basic objectives of the proposed project, or they would not have resulted in a reduction of significant adverse environmental impacts.

REDUCED PROJECT ALTERNATIVE
The City considered a Reduced Project Alternative that would reduce the site acreage and would not utilize more than 50% of the approximately 34-acre site. The reduction in total acres would also reduce the acreage for temporary outdoor vehicle storage capacity from approximately 27.5 acres under the proposed project to approximately 14 acres. This would reduce the vehicle storage capacity from 4,944 to 2,472 vehicle spaces.

This Alternative does not fulfill a key project objective to reduce and consolidate Port vehicle customer reliance on Off-Port storage locations, nor would this Alternative eliminate the need for car carrier truck movement to distribute vehicles to those Off-Port storage locations.

In addition, fewer new jobs would be created under this Alternative, thus not fulfilling a second key project objective regarding employment in the region.
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Finding
The City rejects the Reduced Project Alternative on the following grounds, which provides sufficient justification for rejection of this alternative: the Reduced Project Alternative fails to meet most of the project objectives. Thus, the Reduced Project Alternative was rejected from further consideration in the EIR.

ELECTRIC CAR CARRIER TRUCKS ALTERNATIVE
The City considered an alternative that assumes that electric car carrier trucks would be used by the Port Customer to transport vehicles to existing Off-Port storage locations.

An electric truck is an electric vehicle powered by batteries designed to deliver cargo. The recent development of lithium batteries has broadened the applicability of electric trucks due to the increased range of several hundred miles. Battery powered electric vehicles have no exhaust emissions, but emissions are created from the production and distribution of the energy used to charge them.

At this time, the Port Customer is not using electric car carrier trucks to transport vehicles to existing OffPort storage locations, nor would car carrier trucks be used for the proposed project. While the use of electric trucks would reduce greenhouse gas emissions, the financial implications to the Port Customer to rent or purchase such equipment is unknown at this time, and as such, this Alternative is infeasible.

Additionally, to the knowledge of the Port Customer, there are no commercially available electric car carrier trucks. Therefore, it would not be financially possible for the Port or City to procure electric car carrier trucks for use in the proposed project, and electric car carrier trucks are not anticipated to be feasible for the Port or City to acquire during the five-year life of the proposed project. Therefore, under this alternative without the use of traditional car carrier trucks, vehicle transport would not be able to occur.

Because electric car carrier trucks are not a feasible option for vehicle transport at this time, this Alternative does not fulfill a key project objective to reduce and consolidate Port Customer reliance on Off-Port storage locations and thus, reduce the need for car carrier truck (diesel or electric) movement to distribute vehicles to those locations. Thus, the Electric Car Carrier Trucks Alternative was rejected from further consideration in the EIR.

Finding
The City rejects the Electric Car Carrier Trucks Alternative on the following grounds which provides sufficient justification for rejection of this alternative: this alternative is infeasible given that there are no commercially available electric car carrier trucks and no such trucks are likely to become available within the next 5 years. Thus, the Electric Car Carrier Trucks Alternative was rejected from further consideration in the EIR.

ALTERNATIVE LOCATIONS
Pursuant to Section 15126.6(f)(2) of the CEQA Guidelines, the City considered the potential for alternative locations to the project. The City is mostly developed, with the exception of some undeveloped land to the south of the project site, where the Ormond Lagoon and various undeveloped parcels are located.

Therefore, there are very limited areas of approximately equivalent size to the project site that could be used for the project. In addition, the project applicant does not control another site within the City of comparable land area that is available for development of the proposed project. One of the factors for 770
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feasibility of an alternative is “whether the proponent can reasonably acquire, control or otherwise have access to the alternative site.” Because the City is highly urbanized and is largely built out, obtaining another site of a similar size in a similar location is not considered feasible. It should also be noted that the project site is surrounded by development to the east, north, and west. As such, an alternative location was ultimately rejected from further analysis in the EIR.

Finding
The City rejects the Alternative Locations, on the following ground, which provides sufficient justification for rejection of this alternative: the alternative is infeasible given that the project applicant does not own or control any other property within the City that would be suitable for development of the proposed project. Therefore, this alternative is eliminated from further consideration.

3.2 ALTERNATIVES SELECTED FOR FURTHER ANALYSIS
This section discusses a reasonable range of alternatives to the proposed project, including a No Project Alternative, in compliance with CEQA Guidelines Section 15126.6(e). These alternatives are as follows:
• Alternative One: No Project Alternative
• Alternative Two: Two Existing Off-Port Vehicle Storage Locations • Alternative Three: Existing Zoning
These alternatives are evaluated for their ability to avoid or substantially lessen the impacts of the proposed project identified in the Final EIR, and in consideration of their ability to meet the basic objectives of the proposed project as described in the Final EIR.

3.2.1 Alternative One: No Project Alternative
Section 15126.6(e) of the CEQA Guidelines requires that an EIR evaluate and analyze the impacts of a No Project Alternative. The “purpose of describing and analyzing a no project alternative is to allow decision makers to compare the impacts of approving the proposed project with the impacts of not approving the proposed project” (14 CCR 15126.6[e][1]). When defining the No Project Alternative, the analysis must be informed by “what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services” (14 CCR 15126.6[e][2]).

Description
Section 15126.6(e) of the CEQA Guidelines requires that an EIR evaluate and analyze the impacts of the No Project Alternative, which reflects the “circumstances under which the project does not proceed.” Under the No Project Alternative, no development would occur on the project site. Accordingly, the site characteristics of this alternate would be equivalent to the existing conditions and would remain as vacant and undeveloped land.

Impacts
Under Alternative 1, the No Project/ No Build Alternative, all environmental impacts would be reduced further below the project’s less- than–significant impacts. 771
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Finding
The City rejects the No Project Alternative on the following grounds, each of which individually provides sufficient justification for rejection of this alternative: (1) the No Project Alternative fails to meet any of the project objectives; (2) the No Project Alternative does not reduce or eliminate any significant and unavoidable impacts associated with the project, as the project does not result in any significant and unavoidable impacts.

3.2.2 Alternative Two: Two Existing Off-Port Vehicle
Storage Locations
Description
Alternative Two assumes the existing vehicle storage operations of GLOVIS (Customer) at the Port of Hueneme (Port) and Off-Port locations for vehicle storage within the local area, including within Oxnard, Ventura, Camarillo, and Ventura County would continue.

As such, imported vehicles would be transported by Customer car carrier trucks from the Port to two OffPort storage locations:

1. Camarillo Airport (555 Airport Way, Camarillo)

2. Tuff Shed (3355 Ventura Road, Ventura)
The locations are approximately 10.6 miles and 9 miles, respectively, from the Port.

Impacts
Under Alternative Two, Two Existing Off-Port Vehicle Storage Locations, environmental impacts related to agriculture and forestry resources, hazards and hazardous materials, population and housing, parks and recreation, schools, and wastewater would be the same as compared to the project, or neither environmentally superior nor inferior to the project.

Alternative Two would result in reduced impacts to aesthetics, biological resources, cultural and tribal cultural resources, geology and soils, wildfire and fire protection, police protection, water, and solid waste, as Alternative Two would not result in development of an undeveloped site. Therefore, Alternative Two would be environmentally superior to the proposed project in regard to these environmental issue areas.

Alternative Two would result in increased impacts to air quality, energy, greenhouse gases, noise, and transportation due to the increased distances to the two locations (Camarillo Airport 10.6 miles, Tuff Shed 9 miles) from the Port. In addition, because the proposed project allows for the consolidation of multiple Off-Port storage locations to a single site within one jurisdiction in a zoning district that allows the proposed use, Alternative Two would result in increased impacts to land use. The Camarillo Airport site and proposed project site are located within MRZ-1, and thus does not contain mineral resources.

However, the Tuff Shed site in Ventura is located within MRZ-2 zone, which does contain mineral resources of regional and statewide significance, resulting in an increased impacts to mineral resources under Alternative Two. Lastly, while hydrology and drainage impacts would remain less than significant under both Alternative Two and the proposed project, the proposed project provides more pervious 772
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surface and infrastructure to improve hydrology and water quality impacts, both on-site and off-site.

Therefore, Alternative Two is considered environmentally inferior to the proposed project in regard to these environmental issue areas.

Objectives
Alternative Two would partially meet Objective 1, as the project would facilitate commercial success for Port clients to ensure they keep their business in the region, and keep 167 local citizens employed.

However, Alternative Two does not provide for new jobs. In addition, Alternative Two would not meet Objective 2, as Alternative Two would not reduce and consolidate Port vehicle customer reliance on offPort satellite storage locations, which would reduce the need for car carrier truck movement to distribute vehicles to those locations, to enable a more efficient movement of vehicles and reduce the need for heavy duty truck movement. Lastly, the project would meet Objective 3, as it would provide operational flexibility for the transport of goods (vehicles) that already flow through the Port for purposes of sale, while maintaining existing goods movement and the existing number or capacity of cargo ships.

Finding
The City rejects Alternative 2 on the following grounds, each of which individually provides sufficient justification for rejection of this alternative: (1) Alternative 2 would result in greater impacts to some environmental resource areas; and (2) Alternative 2 does not reduce or eliminate any significant and unavoidable impacts associated with the project, as the project does not result in any significant and unavoidable impacts.

3.2.3 Alternative Three: Existing Zoning
Description
Alternative Three, Existing Zoning, assumes the approximately 34-acre project site would be developed with a light manufacturing use consistent with the M-1-PD zone (Light Manufacturing Zone with Planned Development Additive) and in accordance with applicable use and development standards required per Oxnard City Code Chapter 16, Zoning.

The M-1-PD zone permits the following: maximum building height of 55 feet and a maximum floor area ratio of 70%. For this Alternative, the maximum development assumes a 40% floor area ratio and 587,189 square feet.

Impacts
Under Alternative Three, Existing Zoning, environmental impacts relative to agriculture and forestry resources, biological resources, cultural and tribal cultural resources, geology and soils, mineral resources, population and housing, and schools would be similar compared to the project.

Alternative Three would result in greater impacts relative to aesthetics, as the site would be developed with light manufacturing uses with buildings up to 55 feet in height, thus changing the visual character of the site. In addition, Alternative Three would result in greater impacts relative to air quality, energy, greenhouse gas emissions, and noise, as the duration of both construction and operations associated with Alternative Three would be increased compared to the project. Light manufacturing uses have the 773
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potential to manufacture, transport, use, or dispose of hazardous materials and thus impacts to hazards and hazardous materials would be increased under Alternative Three. Alternative Three would result in less pervious area and more impervious area compared to the project. Thus, impacts to hydrology and water quality would be increased compared to the project. Although Alternative Three would be consistent with the City’s Zoning Code and compatible with surrounding uses, similar to the proposed project, Alternative Three would be subject to the Ventura County Airport Comprehensive Land Use Plan (ACLUP) land use or compatibility guidelines, and Federal Aviation Regulations Part 77 height limitations and would be required to be consistent with the ACLUP and Federal Aviation Regulations Part 77.

Therefore, Alternative Three would result in greater impacts to lad use.

In addition, the number of employees associated with Alternative Three would increase, resulting in an increase in demand for parks and recreation, wildfire and fire protection, and police protection. Regarding transportation, the vehicle trips generated by a 587,189 square foot light manufacturing uses could result in significantly more peak daily, A.M. peak hour, and P.M. peak hour trips that affect a larger traffic impact area and would increase vehicle miles traveled. As Alternative Three would require water and wastewater infrastructure to be installed, impacts associated with water and wastewater would be increased compared to the project. Lastly, the quantity of solid waste generated is dependent upon the light manufacturing use but would be greater than the proposed project. Therefore, Alternative Three is considered environmentally inferior to the proposed project in regard to aesthetics, air quality, energy, greenhouse gas emissions, hazards and hazardous materials, hydrology and water quality, land use, noise, parks and recreation, wildfire and fire protection, police protection, transportation, water, wastewater, and solid waste.

Objectives
Alternative Three would not meet any of the project objectives. Alternative Three would not facilitate commercial success for Port client to ensure they keep their business in the region, keep 167 local citizens employed, and create the potential for more than 30 jobs in the future; reduce and consolidate, where feasible, Port vehicle customer reliance on Off-Port satellite storage locations, which would reduce the need for car carrier truck movement to distribute vehicle to those locations; or provide operational flexibility for the transport of goods (vehicles) that already flow through the Port for purposes of sale, while maintaining existing goods movement and the existing number or capacity of cargo ships.

Finding
The City rejects Alternative Three on the following grounds, each of which individually provides sufficient justification for rejection of this alternative: (1) Alternative Three fails to meet most of the project objectives; (2) Alternative Three would result in greater impacts to some environmental resource areas; and (3) Alternative Three does not reduce or eliminate any significant and unavoidable impacts associated with the project, as the project does not result in any significant and unavoidable impacts.

3.2.4 Environmentally Superior Alternative
Alternative One, the No Project Alternative, would result in the least environmental impacts and would be the environmentally superior alternative. However, Section 15126.6(e)(2) of the CEQA Guidelines states that if the environmentally superior alternative is the No Project Alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives. In this case, the environmentally superior alternative is Alternative Two, Two Existing Off-Port Vehicle Storage Locations. 774
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Alternative Two would partially meet Objective 1, would not meet Objective 2, and would meet Objective

3. As set forth above, the City rejects Alternative Two on the following grounds, each of which individually provides sufficient justification for rejection of this alternative: (1) Alternative Two would result in greater impacts to some environmental resource areas; and (2) Alternative Two does not reduce or eliminate any significant and unavoidable impacts associated with the project, as the project does not result in any significant and unavoidable impacts.
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4.0 GENERAL CEQA FINDINGS
Based on the foregoing Findings and the information contained in the administrative record, and as conditioned by the foregoing, the City has determined the following:

1. The plans for the proposed project have been prepared and analyzed so as to provide for public involvement in the planning and the CEQA processes.

2. To the degree that any impacts described in the Draft EIR are perceived to have a significant effect on the environment, or such impacts appear ambiguous as to their effect on the environment, any significant effect of such impacts has been substantially lessened or avoided by the mitigation measures set forth in the Draft and Final EIR.

3. Comments regarding the Draft EIR received during the public review period have been adequately addressed in the Final EIR. Any significant effects described in such comments were avoided or substantially lessened by the mitigation measures described in the Draft and Final EIR.

4.1 FINDINGS REGARDING RECIRCULATION
The City finds that the Draft EIR does not require recirculation under CEQA (CEQA Section 21092.1, CEQA Guidelines Section 15088.5). CEQA Guidelines Section 15088.5 requires recirculation of an EIR prior to certification of the Final EIR when “significant new information is added to the EIR after public notice is given of the availability of the draft EIR for public review.” As described in CEQA Guidelines Section 15088.5:

New information added to an EIR is not “significant” unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project’s proponents have declined to implement. “Significant new information” requiring recirculation includes, for example, a disclosure showing that:

1. A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented;

2. 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;

3. 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;

4. The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.

In addition, CEQA Guidelines Section 15088.5(b) provides that “recirculation is not required where the new information added to the EIR merely clarifies and amplifies or makes insignificant modifications in an adequate EIR.” Recirculation also is not required simply because new information is added to an EIR; 777
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indeed, new information is oftentimes added given CEQA’s public/agency comment and response process and CEQA’s post-Draft EIR circulation requirement of proposed responses to comments submitted by public agencies. In short, recirculation is “intended to be an exception rather than the general rule” (Laurel Heights Improvement Assn. v. Regents of University of California (1993) 6 Cal.4th 1112, 1132).

As such, the City makes the following Findings:
• None of the public comments submitted to the City regarding the Draft EIR present any significant new information that would require the Draft EIR to be recirculated for public review. • No new or modified mitigation measures are proposed that would have the potential to create new significant environmental impacts.
• The Draft EIR adequately analyzed project alternatives and there are no feasible alternatives or mitigation measures considerably different from others previously analyzed that would clearly lessen the significant environmental impacts of the project. • The Draft EIR was not fundamentally and basically inadequate and conclusory in nature and did not preclude meaningful public review and comment.

In this legal context, the City finds that recirculation of the Draft EIR prior to certification is not required.

In addition to providing responses to comments, the Final EIR includes revisions to expand upon information already presented in the Draft EIR; explain or enhance the evidentiary basis for the Draft EIR’s findings; update information; and to make clarifications, amplifications, updates, or helpful revisions to the Draft EIR. The Final EIR’s revisions, clarifications, and/or updates do not result in any new significant impacts or increase the severity of a previously identified significant impact. In sum, the Final EIR demonstrates that the proposed project would not result in any new significant impacts or increase the severity of a significant impact compared to the analysis presented in the Draft EIR. The changes reflected in the Final EIR also do not indicate that meaningful public review of the Draft EIR was precluded in the first instance. Accordingly, recirculation of the EIR is not required because revisions to the EIR are not significant as defined in Section 15088.5 of the CEQA Guidelines. 778
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11.0 MITIGATION MONITORING AND

REPORTING PROGRAM

11.1 INTRODUCTION
Section 15097 of the California Environmental Quality Act (CEQA) Guidelines requires that, whenever a public agency approves a project based on a Mitigated Negative Declaration or an Environmental Impact Report (EIR), the public agency shall establish a mitigation monitoring or reporting program to ensure that all adopted mitigation measures are implemented.

The mitigation monitoring and reporting program (MMRP) contained herein is intended to satisfy this requirement of the CEQA Guidelines as it relates to the Temporary Outdoor Vehicle Storage Facility Project (project). This MMRP is intended to be used by City of Oxnard (City) staff to ensure compliance with mitigation measures during project implementation. Mitigation measures identified in this MMRP were developed in the Draft EIR and finalized in the Final EIR prepared for the proposed project.

The Final EIR for the proposed project presents a detailed set of mitigation measures required for implementation. As noted above, the intent of the MMRP is to ensure the effective implementation and enforcement of all adopted mitigation measures. The MMRP will also provide for monitoring of construction activities, as necessary, and in the field identification and resolution of environmental concerns.

11.2 PURPOSE OF THE MITIGATION MONITORING AND

REPORTING PROGRAM
This MMRP has been prepared to ensure that all required mitigation measures are implemented and completed in a sufficient manner before and during project construction and operation. The MMRP may be modified by the City during project implementation, as necessary, in response to changing conditions or other refinements. The MMRP table has been prepared to assist the responsible parties in implementing the mitigation measures. The table identifies each mitigation measure or standard condition; the action required for the measure to be implemented; the time at which the monitoring is to occur; the monitoring conditions; and the agency or party responsible for ensuring that the monitoring is performed. The numbering of mitigation measures and standard conditions follows the numbering sequence found in the Final EIR.

11.3 ROLES AND RESPONSIBILITIES
Unless otherwise specified herein, the City is responsible for taking all actions necessary to implement the mitigation measures under its jurisdiction according to the specifications provided for each measure and for demonstrating that the action has been successfully completed. The City, 779
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at its discretion, may delegate implementation responsibility or portions thereof to a licensed contractor or other designated agent. The City would be responsible for overall administration of the MMRP and for verifying that City staff members and/or the construction contractor has completed the necessary actions for each measure.

Section 21081.6 of the Public Resources Code requires the lead agency to identify the “custodian of documents and other material” which constitutes the “record of proceedings” upon which the action on the project was based. Inquiries should be directed to:

City of Oxnard Community Development Department
Planning & Environmental Services Division
214 South C Street
Oxnard, California, 93030

11.4 REPORTING
Upon completion of the project, the City’s Planning Manager shall prepare a monitoring report on the compliance of the activity with the required mitigation measures. Information regarding inspections and other requirements shall also be compiled and explained in monthly or annual reports, as relevant. Information regarding inspections and other requirements shall be compiled and explained in the report. The report shall be designed to simply and clearly identify whether mitigation measures have been adequately implemented. At a minimum, each report shall identify the mitigation measures or conditions to be monitored for implementation, whether compliance with the mitigation measures or conditions has occurred, the procedures used to assess compliance, and whether further action is required.
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MITIGATION MONITORING AND REPORTING PROGRAM FOR THE TEMPORARY OUTDOOR VEHICLE STORAGE

FACILITY PROJECT

FINAL ENVIRONMENTAL IMPACT REPORT
Impact Mitigation Measure/Standard Condition Implementation Timing Monitoring Frequency Responsible Party Compliance
Verification
(Date/Initials/
Comments)

5.1 AESTHETICS
Implementation of the
proposed project could
substantially degrade
the visual
character/quality of the
site and its
surroundings
(Threshold AES-3).

SC AES-1: Prior to the issuance of building permits,
the Applicant shall submit two copies of landscape
and irrigation plans, along with appropriate permit
application and fees, to the Development Services
Division and obtain approval of such plans.

Prior to the issuance of
building permits.

One time prior to issuance
of building permits.

Applicant
SC AES-2: Prior to the issuance of a certificate of
occupancy, the Applicant shall install landscape and
automatic irrigation systems.

Prior to the issuance of a
certificate of occupancy.

Installation occurs one
time prior to the issuance
of a certificate of
occupancy.

Applicant
SC AES-3: Prior to the issuance of a certificate of
occupancy, the Applicant shall provide a watering
schedule to the site manager and to the Planning
Division or designee. The irrigation system shall
include automatic rain shut-off devices, or
instructions on how to override the irrigation system
during rainy periods.

Prior to the issuance of a
certificate of occupancy.

Provision of water
schedule occurs one time
prior to the issuance of a
certificate of occupancy.

Recommendations of the
watering schedule must
be implemented
throughout project
implementation.

Applicant
SC AES-4: The Applicant shall install an irrigation
system that includes a water sensor shut-off device
as a water conservation measure.

During project construction
and prior to project operation.

Installation occurs one
time during project
construction.

Ongoing maintenance
should occur when
necessary during project
implementation to ensure
sufficiency of irrigation
system.

Applicant
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MITIGATION MONITORING AND REPORTING PROGRAM FOR THE TEMPORARY OUTDOOR VEHICLE STORAGE

FACILITY PROJECT

FINAL ENVIRONMENTAL IMPACT REPORT
Impact Mitigation Measure/Standard Condition Implementation Timing Monitoring Frequency Responsible Party Compliance
Verification
(Date/Initials/
Comments)
SC AES-5: All trees planted or placed on the
property by the Applicant shall be a minimum of 24-
inch-box size. All shrubs and vines shall be at least
five-gallon size, except as otherwise specified by
the Special Use Permit.

During project construction
and prior to project operation.

Installation occurs one
time during project
construction.

Applicant
SC AES-6: The Applicant shall properly maintain
landscape planting and all irrigation systems as
required by the City Code and as specified by Special
Use Permit for the life of the project. Failure of the
Applicant to do so may result in the revocation of this permit and initiation of legal proceedings against
Applicant to ensure compliance.

Ongoing during project
operation for the life of the 5-
year Special Use Permit.

Ongoing during project
operation for the life of the
5-year Special Use Permit
as required by the City
Code.

Applicant
SC AES-7: The Applicant agrees that the project
has aesthetic impacts arising from conversion of
undeveloped land to developed land, which the
landscaping improvements for the project are
intended to mitigate. The Applicant further agrees
that the landscaping improvements must be
maintained for the life of the permit in order to
continue to mitigate such impacts.

Ongoing during project
operation for the life of the 5-
year Special Use Permit.

Ongoing during project
operation for the life of the
5-year Special Use Permit
as required by the City
Code.

Applicant
MM AES-1: The Applicant shall install chain-link
fencing with top and bottom rails to provide support
for plants.

During project construction
and prior to project operation.

Installation occurs one
time during project
construction.

Applicant
MM AES-2: In locations where chain-link gates are
proposed and plants cannot grow, the Applicant
shall install either privacy slats on the chain-link
gates or solid gates to block views onto the site.

During project construction
and prior to project operation.

Installation occurs one
time during project
construction.

Applicant
MM AES-3: Prior to vegetation maturation that
effectively buffers views onto the project site, the
Applicant shall install screening fabric on the chainlink fencing or other alternative temporary measures approved by the City to fill gaps in the vegetation.

Prior to vegetation maturation
that effectively buffers views
onto the project site.

Ongoing during project
operation for the life of the
5-year Special Use
Permit.

Applicant
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MITIGATION MONITORING AND REPORTING PROGRAM FOR THE TEMPORARY OUTDOOR VEHICLE STORAGE

FACILITY PROJECT

FINAL ENVIRONMENTAL IMPACT REPORT
Impact Mitigation Measure/Standard Condition Implementation Timing Monitoring Frequency Responsible Party Compliance
Verification
(Date/Initials/
Comments)
Applicant should regularly
assess vegetation to
determine whether
screening fabric or other
alternative temporary
measures are necessary.

Once vegetation has
matured to effectively
buffered views to the project
site, the Applicant should
remove fabric screening in
those areas.

MM AES-4: The Applicant shall provide visual
screening of the existing water utility
structure/chain-link fence enclosure on the
southeast corner of Hueneme Road and Perkins
Road complementary to the screening established
with the project.

During project construction
and prior to project operation.

Installation occurs during
project construction. Visual
screening methods should
complement the screening
established for the project.

Applicant should regularly
assess screening to ensure
it is sufficient and address
any degradation.

Applicant
Implementation of the
proposed project could
create a source of
substantial light or
glare, which could
affect daytime and/or
nighttime views in the
area (Threshold
AES-5).

SC AES-8: The project must comply with the
Outdoor Lighting Code & Guideline:
a. Outdoor lighting shall comply with Title 24,
Part 6, of the California Code of
Regulations: California’s Energy
Efficiency Standards for Residential and
Nonresidential Buildings.
b. All outdoor lighting shall be flat lens, full
cut-off fixtures with the light source fully
shielded with the exception of:

Ongoing during project
construction and operation.

Lighting installation occurs
during project
construction.

Ongoing compliance with
the Outdoor Lighting Code
& Guideline is required for
the life of the project
during the 5-year Special
Use Permit, consistent
Applicant
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MITIGATION MONITORING AND REPORTING PROGRAM FOR THE TEMPORARY OUTDOOR VEHICLE STORAGE

FACILITY PROJECT

FINAL ENVIRONMENTAL IMPACT REPORT
Impact Mitigation Measure/Standard Condition Implementation Timing Monitoring Frequency Responsible Party Compliance
Verification
(Date/Initials/
Comments)
i. Luminaires with a maximum
output of 260 lumens per fixture,
regardless of number of bulbs
(equal to one 20-watt
incandescent light), may be left
unshielded provided the fixture
has an opaque top to keep light
from shining directly up.
ii. Luminaires that have a
maximum output of 1,000
lumens per fixture, regardless of
number of bulbs (equal to on
60-watt incandescent light) may
be partially shielded provided
the bulb is not visible, and the
fixture has an opaque top keep
light from shining directly up.
c. Oxnard City Code 16-320: Lighting within
physical limits of the area required to be
lighted shall not exceed seven foot-candles,
nor be less than one foot-candle at any
point. A light source shall not shine upon, or
illuminate directly any surface other than the
area required to be lighted. No lighting shall
be of a type or in a location that constitutes a
hazard to vehicular traffic, either on private
property or on the abutting streets. The
height of light standards shall not exceed 26
feet. To prevent damage from automobiles,
standards shall be mounted on reinforced
concrete pedestals or otherwise protected.
with the Oxnard City
Code.
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MITIGATION MONITORING AND REPORTING PROGRAM FOR THE TEMPORARY OUTDOOR VEHICLE STORAGE

FACILITY PROJECT

FINAL ENVIRONMENTAL IMPACT REPORT
Impact Mitigation Measure/Standard Condition Implementation Timing Monitoring Frequency Responsible Party Compliance
Verification
(Date/Initials/
Comments)
SC-AES-9: Lighting instruments shall be metal
halide, LED, or similar in nature and spectrum
(3,000K to 20,000K Correlated Color Temperature).

Ongoing during project
construction and operation
Lighting installation occurs
during project
construction.

Maintenance and
replacement of lightbulbs
consistent with this
standard condition is
required during the life of
the project.

Applicant
SC AES-10: Lighting instruments shall be installed
so that light does not directly illuminate property
outside the project site. Instruments shall not create
glare for motorists or pedestrians.

Ongoing during project
construction and operation
Lighting installation occurs
during project
construction.

Maintenance and
replacement of lightbulbs
consistent with this
standard condition is
required during the life of
the project.

Applicant

5.4 Biological Resources
The proposed project
could have a
substantial adverse
effect on sensitive or
special status biological
resources, or riparian
habitats, or natural
communities
(Threshold BIO-1,
Threshold BIO-2).

MM BIO-1: To avoid the disturbance of nesting and
special-status birds, including raptor species
protected by the Migratory Bird Treaty Act (MBTA)
and California Fish and Game Code (CFGC),
activities related to the project including, but not
limited to, vegetation removal, ground disturbance,
demolition, and construction shall occur outside of
the bird breeding season (February 1 through
August 31), if practicable.

Conduct survey during
project planning or design to
allow lead time for mitigation
planning and implementation.

Report to be provided prior to
any ground disturbance.

No further action required if
surveys are negative, or if
habitat can be avoided.

Initial survey and
reporting.

Conduct monitoring if
required to comply with
Game Code Section 1600
and/or Sections 401 and
404 of the Clean Water
Act.

Applicant
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Impact Mitigation Measure/Standard Condition Implementation Timing Monitoring Frequency Responsible Party Compliance
Verification
(Date/Initials/
Comments)
If construction must begin during the breeding
season, then a pre-construction nesting bird survey
shall be conducted no more than seven (7) days
prior to initiation of ground disturbance and
vegetation removal activities.

The pre-construction nesting bird survey shall be
conducted on foot inside the project site, including a
50-foot buffer and in inaccessible areas (e.g.,
private lands) from afar using binoculars, to the
extent practicable. The survey shall be conducted
by a biologist familiar with the identification of avian species known to occur in southern California.

If nests are found, an avoidance buffer (dependent
upon the species, the proposed work activity, and
existing disturbances associated with land uses
outside of the site) shall be determined and
demarcated by the biologist with bright orange
construction fencing, flagging, construction lathe, or
other means. All construction personnel shall be
notified as to the existence of the buffer zone and to
avoid entering the buffer zone during the nesting
season. No ground-disturbing activities shall occur
inside this buffer until the avian biologist has
confirmed that breeding/nesting is complete and the
young have fledged the nest. Encroachment into the
buffer shall occur only if authorized by the qualified
biologist, who shall monitor activities to ensure that
nesting birds are not adversely affected.

Comply with Fish and Game
Code Section 1600 and/or
Sections 401 and 404 of the
Clean Water Act if surveys
are positive and habitat
cannot be avoided.

Incorporate measures into
construction contracts, as
relevant.
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In addition, for any construction activities, the
applicant shall retain the services of a qualified
biologist or environmental resources specialist to
conduct sensitive species surveys (including birds
and other terrestrial species) of the project site. The environmental resources specialist shall conduct
surveys no more than two weeks prior to the
approved construction activities to detect any active
sensitive species. In the event that any sensitive
species are present in or adjacent to the
construction area but do not exhibit reproductive
behavior and are not within the estimated
breeding/reproductive cycle of the subject species,
the environmental resources specialist shall
implement a resource avoidance program with
sufficient buffer areas to ensure adverse impacts to
such resources are avoided.

5.5 CULTURAL AND TRIBAL CULTURAL RESOURCES
The proposed project
could result in a
substantial adverse
change in the
significance of a unique
archaeological
resource pursuant to
state CEQA Guidelines
Section 15064.5
(Threshold CTC-2).

MM CUL-1: Archaeological Monitoring. Prior to
ground disturbance activities, the Applicant and/or
subsequent responsible parties shall retain a
Principal Investigator/Archaeologist, meeting the
Secretary of the Interior’s Standards, and with
experience in California prehistoric and historic
resources (experience within Ventura County
preferred ), to complete the following: compose a
Cultural Resource Monitoring and Inadvertent
Discovery Plan (Plan), manage archaeological
monitoring and address any inadvertent discoveries
identified during project implementation. The
purpose of the Plan is to outline cultural monitoring
(archaeological and Native American/Tribal)
A Principal
Investigator/Archaeologist
shall be retained prior to
ground-disturbance activities.

Monitoring is ongoing during
ground-disturbing activities.

Incorporate measure into
construction contracts.

Ongoing during grounddisturbing activities.Applicant
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protocols and a program of treatment and mitigation
in the case of an inadvertent discovery of cultural
(archaeological or Native American/Tribal)
resources during ground-disturbing phases and to
provide for the proper identification, evaluation,
treatment, and protection of any cultural resources
in accordance with CEQA throughout the duration of
the Project. Existence and importance of adherence
to this Plan shall be stated on all Project site plans
intended for use by those conducting the ground
disturbing activities.

The Principal Investigator/Archaeologist shall
manage archaeological monitoring conducted by
archaeological technicians during initial ground
disturbances. Initial excavation is defined as initial
construction-related earth moving of sediments from
their place of deposition. As it pertains to cultural
monitoring (archaeological or Native
American/Tribal), this definition excludes movement
of sediments after they have been initially disturbed
or displaced by project-related construction. The
retained Principal Investigator/Archaeologist shall
oversee and establish monitoring efforts as needed
(increase, decrease, or discontinue monitoring
frequency) based on the observed potential for
construction activities to encounter cultural deposits
or material. The archaeological monitor shall be
responsible for maintaining daily monitoring logs.

The requirement for archaeological monitoring shall
be noted on all construction plans to ensure
implementation. Upon completion of all ground
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disturbing activities, an archaeological monitoring
report shall be prepared within 30 business days
following completion of ground disturbance and
submitted to the City for review. This report shall
document compliance with approved cultural
mitigation, all monitoring efforts, and include an
appendix with daily monitoring logs. The final report
shall be submitted to the City and the South Central
Coastal Information Center.

MM-CUL-2: Native American/Tribal Monitoring -
Prior to ground disturbance activities, the Applicant
and/or subsequent responsible parties shall retain a
Native American/Tribal monitor/entity selected from
the list of California Native American Tribes
(maintained by the NAHC) and that are traditionally
and culturally affiliated with the geographic area of
the Project site. The Applicant and/or subsequent
responsible parties shall make arrangements with
the Native American/Tribal monitor/entity to enter
into a contract with the intent of securing a total of
one Native American/Tribal monitor to be present
during initial ground disturbance. Initial ground
disturbance is defined as initial construction-related
earthmoving of sediments from their place of
deposition. As it pertains to cultural resource
(archaeological or Native American/Tribal)
monitoring, this definition excludes movement of
sediments after they have been initially disturbed or
displaced by current Project-related construction.

The Plan created in compliance with MM-CUL-1
shall be provided to the Native American/Tribal
monitor/entity under contract prior to
A Native American/Tribal
Monitor shall be retained prior
to ground-disturbance
activities.

Monitoring is ongoing during
ground-disturbing activities.

Incorporate measure into
construction contracts.

Ongoing during grounddisturbing activities.Applicant
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commencement of ground disturbing activities.

More than one monitor may be required if multiple
areas within the Project site are simultaneously
exposed to initial ground disturbance causing
monitoring to be hindered by the distance (more
than 200 feet apart) of the simultaneous activities.

5.7 GEOLOGY AND SOILS
Implementation of the
proposed project could
result in the risk of loss,
injury, or death due to
strong seismic ground
shaking (Threshold
GEO-1b).

MM GEO-1: Prior to issuance of grading permits,
the Applicant or designee shall prepare and submit
a soils, geologic, and structural evaluation report
prepared by a registered soils engineer and/or
structural engineer for review and approval by the
City of Oxnard Building and Engineering Division.

The recommendations in the report shall be
implemented during site grading and construction.

Prior to issuance of grading
permits
Report must be submitted
prior to issuance of
grading permits.

Recommendations in the
report shall be
implemented during site
grading and construction
on an ongoing basis
during construction
activities.

Applicant
Review by City of
Oxnard Building and
Engineering
Division.

5.9 HAZARDOUS MATERIALS USE, GENERATION, TRANSPORT, OR DISPOSAL The proposed project
could result in an
increased risk of upset
associated with the
routine use, generation,
transport, or disposal of
hazardous materials
(Threshold HAZ-1).

SC HAZ-1: Prior to issuance of the grading permit,
the Applicant shall submit a Safety Plan to the City
of Oxnard Fire and Planning Departments. The
Safety Plan shall address best management
practices to address how vehicles are inspected for
leakage and how liquids and vehicle fluids are
inspected to ensure release does not occur. The
Safety Plan is subject to review and approval by the
City of Oxnard Fire and Planning Departments.

Prior to issuance of grading
permits
Safety Plan must be
submitted prior to
issuance of grading
permits.

Recommendations in the
report shall be
implemented during
project operation on an
ongoing basis.

Applicant
Review by City of
Oxnard Fire and
Planning
Departments

5.10 HYDROLOGY AND WATER QUALITY
The proposed project
could cause a violation
SC HYD-1: The Applicant shall design project to
minimize degradation of stormwater quality by
During project design. Stormwater quality
calculations and
Applicant
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of any adopted water
quality standards or
waste discharge
requirements
(Threshold HYD-1).
complying with the applicable sections of the Los
Angeles Regional Water Quality Control Board’s
municipal separate storm sewer system (MS4)
permit (Order R4-2010-0108 including all revisions)
for new development and redevelopment projects.

The Applicant shall submit stormwater quality
calculations and associated construction plans
demonstrating compliance with the MS4 permit.

Calculations shall generally be organized to follow
the steps outlined in Chapter 2 of the 2011
Technical Guidance Manual for Stormwater Control
Measures (2011 TGM).

Stormwater quality
calculations and associated
construction plans
demonstrating compliance
with the MS4 permit must be
submitted prior to issuance of
building or grading permits
(whichever comes first).
associated construction
plans demonstrating
compliance with the MS4
permit must be submitted
prior to issuance of
building or grading permits
(whichever comes first).

Ongoing compliance with
the MS4 permit is required
during the life of the
project.

SC HYD-2: The Applicant’s stormwater quality
calculations shall include site specific analysis and
recommendations from a geotechnical engineer,
and if applicable, a landscape architect for design
and implementation of stormwater treatment and
infiltration devices. Geotechnical Engineering
analysis and recommendations shall include, but
not necessarily be limited to, determination of sitespecific soil infiltration rates, depth to permeable soil layers, methods to reach permeable soil layers,
appropriate compaction rates, recommendations to
enhance infiltration, and other requirements of the
2011 TGM. Landscape architectural
recommendations shall include, but not necessarily
be limited to, suggestions regarding appropriate
vegetation and soil amendments for vegetated
infiltration devices. Project plans shall implement
approved design recommendations.

Stormwater quality
calculations and infiltration
plans must be determined
during project design.

Engineering and architectural
recommendations shall be
implemented throughout the
life of the project.

Stormwater issues will be
addressed during project
design.

Ongoing compliance with
the 2011 Technical
Guidance Manual for
Stormwater Control
Measures is required
throughout the life of the
project.

Applicant
Recommendations
required from a
geotechnical
engineer, and if
applicable, a
landscape architect
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SC HYD-3: Using forms provided by the
Development Services Division, the Applicant shall
submit a stormwater quality control measures
maintenance and operations plan (the Plan) for this
project. If the BMPs implemented with this project
include proprietary products that require regular
replacement and/or cleaning, the Applicant shall
provide proof of a contract with an entity qualified to provide such periodic maintenance. The property
owner is responsible for the long-term maintenance
and operation of all BMPs included in the project
design. Upon request by the City, property owner
shall provide written proof of ongoing BMP
maintenance operations. No grading or building
permit shall be issued until the Development
Services Manager approves the Plan and the
Applicant provides an executed copy of the City’s
stormwater covenant with the Plan included as an
exhibit for recordation by the City.

During project design and
prior to issuance of grading
and building permits
(whichever comes first).

Ongoing long-term
maintenance and
operation of all BMPs
included in the project
design.

Upon request by the City,
property owner shall
provide written proof of
ongoing BMP
maintenance operations.

Applicant
The property owner
is responsible for
the long-term
maintenance and
operation of all
BMPs included in
the project design.

SC HYD-4: The Applicant shall install ‘Full Capture
System Devices’ (Devices) certified by the State
Water Resources Control Board Executive Director
in compliance with the Statewide Trash
Amendments (Amendments) in all catch basins
accepting stormwater runoff from any portion of this
project that meets the definition of ‘Priority Land
Use’ as defined by the Amendments at the time of
issuance of a grading/site improvement permit. The
Devices shall be sized and designed in accordance
with requirements of the Amendments and the
Technical Guidance Manual for Stormwater Quality
Control Measures (TGM).

Installation occurs once
during project construction.

Ongoing maintenance as
needed to ensure the
system is sufficient.

Applicant
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5.17 POLICE PROTECTION
The proposed project
could increase the
demand for police
protection service such
that new or expanded
facilities would be
needed to maintain
acceptable service
levels, the construction
of which may have
significant
environmental effects
(Threshold PP-1).

MM PP-1: Prior to construction, the Applicant shall
prepare a Traffic Control Plan for implementation
during the construction phase, as deemed
necessary by the City Traffic Engineer. The Plan
may include the following provisions, among others:
● At least one unobstructed lane shall be
maintained in both directions on the following
surrounding roadways: Hueneme Road and
Perkins Road.
● At any time only a single lane is available, the
Applicant shall provide a temporary traffic
signal, signal carriers (i.e., flag persons), or
other appropriate traffic controls to allow travel
in both directions.
● If construction activities require the complete
closure of a roadway segment, the Applicant
shall provide appropriate signage indicating
detours/alternative routes.

Traffic Control Plan must be
developed prior to
construction, and must be
implemented during project
construction.

Ongoing implementation
during project
construction.

No action required during
project operation.

Applicant
Review by City
Traffic Engineer
required.
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