It [Las Posas Rancho] has only one spring stream of water that of Las Posas which although very abundant is so deep that some labor is necessary to get its water out. Consequently it cannot be hoped that it will serve for irrigation and is only useful as a watering place for cattle. (Carrillo 1833)
Early inhabitants of the Calleguas Creek area used these springs and lakes as water sources for domestic water, crop irrigation, and cattle. The lake at Round Mountain was described as a primary source of water on Guadalasca Rancho by the grantee (Yorba 1837), and wet foothill valleys on Las Posas Rancho were also used as watering places for cattle (Tico 1834).
Ponds and wetlands were found in nearly every pocket valley between Mugu Lagoon and Pleasant Valley. Many occurred at the mouths of distributaries, along Conejo Creek, or coincident with springs. On Las Posas Rancho, some of these low valleys were “dependant [sic] on the seasons,” presumably referring to variable utility due to seasonal flooding and the summer dry season (Tico 1834).
This pattern is confirmed by an early diseño of Calleguas Rancho (roughly the Pleasant Valley area; U.S. District Court ca. 1840a; fig. 5.15). The map shows a series of wetlands (sienegas [sic]) and springs up against the hills east of Calleguas Creek (Arroyo de las Posas). While the diseño A considerable portion of this
rancho [Calleguas] has living springs
upon it…
— thompson and west [1883]1961
N
964
186 5. oxnard plain and calleguas creek • 187
is roughly drawn, it does depict the same pattern shown on our habitat map, suggesting that these wetlands and springs were persistent, historical features.
One notable feature was the freshwater lake at the terminus of Calleguas Creek (fig. 5.16). South of the lake, Calleguas Creek ceased to have a defined channel, instead connecting to Mugu Lagoon through a series of swales and wetlands. Guadalasca Rancho, on which the lake was located, was alternatively known as the Laguna Rancho: “The old Californians familiarly call the ‘Guadalasca’ the ‘Laguna’ (Thompson 1873, in Thompson 1869). In addition to flow from Calleguas Creek, two springs in the area—one called Guadalasca—formed the lake (Lugo 1855).
The lake was described as the “only considerable watering place” on the Fig. 5.15. While this ca. 1840s diseño is
very schematic, it provides a generalized
picture of the landscape of springs and
wetlands present between Calleguas Creek
(“Arroyo de las Pozas”) and the Santa Monica
Mountains. It depicts springs (shown as dark
circles with small radiating lines) flowing into
small creeks and wetlands (labeled “sienega”
[sic]). One wetland shown is up against
the base of the hills, while the other is just
upstream of the confluence of two creeks.
(U.S. District Court ca. 1840a, courtesy of The
Bancroft Library, UC Berkeley)
Guadalasca Rancho (Yorba 1837). During the wet season, overflow from the lake ran toward Mugu Lagoon both to the west and to the east of Round Mountain.
Likely as a legacy of this ecological history, some of these former wetland valleys, which were presumably relatively unattractive for development, are now parks and other public uses. Portions of the Camarillo Springs Golf Course and the area upslope of the Camrosa Water District storage ponds, for example, are located on areas mapped as former wetlands.
Previous studies have recognized some wetland restoration potential in these areas (David Magney Environmental Consulting 2000), which constitute the greatest concentration of documented freshwater wetlands in the study area.
Fig. 5.16. The Laguna. Historically one of the most prominent features on the Oxnard Plain, this lake was the namesake for the Guadalasca or Laguna Rancho. It was located at the terminus of Calleguas Creek; below the laguna series of shallow sloughs and overflow connected the creek to Mugu Lagoon. Historical mapping of the lagoon is shown at left; an early map of the lake is at right. (Reed ca. 1871, courtesy of The Bancroft Library, UC Berkeley)
early 1800s ca. 1871
N
1,000 feet
Perennial Freshwater Pond
Valley Freshwater Marsh
Alkali Meadow
Alkali Meadow/Flat
Grassland/Coastal Sage Scrub
Palustrine and Terrestrial Habitat
Intermittent or Ephemeral
Distributary
Hydrology
965
188 5. oxnard plain and calleguas creek • 189
Summary of findings
The following findings represent some of the significant conclusions drawn from our research and analysis. Combined with an understanding of modern conditions, these findings can support scientists and managers working to identify restoration opportunities on the Oxnard Plain and in the lower Calleguas Creek watershed.
1. The Oxnard Plain supported a diverse array of habitats, from the freshwater wetlands and lakes of the lower Calleguas watershed to the alkali meadows and flats, grassland, coastal sage scrub, and chaparral of the broader plain. Just under half of the plain supported alkali meadows and alkali flats, with the remainder mostly covered by grassland and coastal sage scrub.
2. The distribution of these habitats reflected underlying physical processes and characteristics. Topography, soils, geology, and groundwater availability were primary factors in determining historical habitat distribution.
3. Few trees were found on the Oxnard Plain. Only a small number of trees were documented on the plain by 19th century observers, mostly sycamores (and one live oak) on the sand and sandy loam soils marking the former route of the Santa Clara River to Point Hueneme.
4. Few streams traversed the Oxnard Plain, particularly in its western portion. The plain was notable for its extremely low drainage density (only 1.7 miles of creek per square mile). The few creeks and barrancas that did cross the plain were almost exclusively discontinuous, sinking into coarse alluvium or spreading into and across seasonally wet alkaline areas. Large sloughs such as Revolon Slough (a former channel of the Santa Clara River) formed the backbone of drainage for the central plain.
5. Calleguas Creek did not maintain a defined channel across the Oxnard Plain, instead spreading into a broad wash around present-day Highway 101 before re-emerging downslope near Conejo Creek. The creek terminated in a lake and distributary system near the current location of CSU Channel Islands. Calleguas Creek was hydrologically connected to Mugu Lagoon through shallow sloughs and sheet flow during floods.
6. Calleguas and Conejo creeks were intermittent on the Oxnard Plain. Though sources describe readily available water located below the surface in both creek beds, they are consistently described as dry for much of the year.
7. Sources document a concentration of perennial freshwater wetlands, ponds, and lakes along the eastern margin of the Oxnard Plain, particularly east of Conejo and Calleguas creeks. The majority of these wetlands occurred near the base of small alluvial valleys of creeks tributary to Calleguas and Conejo creeks, near contacts between alluvial deposits and the Conejo Volcanics of the western Santa Monica Mountains.
Management Considerations
• Former wetland locations in the Calleguas Creek watershed offer a number of potentially viable sites that should be considered for restoration. Many of these sites, still located on agricultural land, may be appropriate locations for future wetland restoration projects. • Some of these former wetland locations have already been identified through previous research as potential floodplain restoration sites. The large freshwater lake at the historical distributary of Calleguas Creek for which the Guadalasca/Laguna Rancho was named coincides with one of the sites identified for potential restoration in the Calleguas Creek Watershed Restoration Plan (David Magney Environmental Consulting 2000), which also includes Calleguas Creek and floodplain north of CSU Channel Islands and the Camrosa Water District facilities. In addition, Magney’s conceptual wetland restoration design for Calleguas Creek at Camarillo Regional Park may have the potential to incorporate historical wetland habitat behind the Camrosa Water District storage ponds (fig. 5.17).
Similar opportunities may exist at the site on Conejo Creek at Winding Brook Farm, where additional freshwater wetlands were documented. Future restoration activities at these sites could take advantage of the unique historical and hydrologic aspects of this area in designing floodplain characteristics.
• Drainage density of the Oxnard Plain has greatly increased with the construction of artificial drainage networks, creating more direct conduits between ocean and upland. This expansion of the drainage network has implications for contemporary distribution and residence time of water and sediment on the plain and should be considered in creek restoration projects, particularly in constructed reaches not historically present. For example, the historical form of Calleguas Creek helps explain current sedimentation issues downslope of Lewis Road. • Physical factors such as topography, soils, geology, and groundwater availability are still primary factors affecting contemporary habitat distribution. An understanding of how these drivers contributed to historical habitat patterns is an essential component of the success of restoration projects.
Fig. 5.17. Camrosa Water District storage ponds, 2008. The area behind these storage ponds, formerly the site of a freshwater marsh complex, may be a potential location for wetland habitat restoration. 966
6 • ventura county shoreline
Introduction
Nineteenth century Ventura County exhibited a complex and heterogeneous shoreline, with a variety of habitats and morphologies associated with different estuarine and wetland systems and different formative processes (fig. 6.2). At the Ventura River mouth, willowcottonwood forest transitioned into a small, intermittently closed lagoon, while a culturally significant beach-dammed freshwater wetland complex occupied a former river mouth to the east. A distinctive seasonal wetland area—the Pierpont lowlands—extended in a broad arc from Ventura to the Santa Clara River mouth, nearly connecting the eastern edge of the Ventura River corridor to the northwestern edge of the Santa Clara River (they were separated by less than one mile). Here sand dunes trapped Santa Clara River floodwaters and valley seepage in a recently prograded portion of the shoreline, creating a large area of seasonally inundated meadow. At the Santa Clara River mouth, willow swamps bordered a small seasonal estuary similar in form and function to the Ventura River delta (and including a freshwater wetland complex, McGrath Lake). To the south, a series of at least nine elongate lagoons—some brackish, some saline—incised the Oxnard Plain shoreline, marking former mouths of the meandering Santa Clara River. Usually blocked from the tides by substantial beaches and dunes, the water source for these lagoons was a varying mix of saline (through dune overwash and seepage) and fresh water (from precipitation, runoff, and springs). As a result, the lagoon complexes supported a gradient of heterogeneous habitats ranging from freshwater to brackish to saline, including vegetated marsh, salt flat, and open water. At the southern edge of the Oxnard Plain, Mugu Lagoon represented by far the largest coastal wetland system in the county, with extensive subtidal, tidal flat, tidal marsh, and salt flat habitat.
Recent research by Grossinger et al. (2011) puts these patterns within a Southern California regional context. The study examined these wetlands in the context of broader Southern California coastal wetlands, drawing conclusions about broad categories of estuarine systems in the region (see Grossinger et al. 2011 for more information). Ventura County historically represented at least three distinct estuarine habitat mosaics or archetypes:
the compressed estuaries merging into broad riparian forest associated Fig. 6.1. Mugu Lagoon from the east,
1923. This oblique aerial image of Mugu
Lagoon shows habitats of the eastern arm
of Mugu, including tidal flat, salt marsh,
and the lagoon itself. The patterns shown
bear a striking resemblance to those shown
on the T-sheet, surveyed over 50 years
earlier. (Harrington 1923a, courtesy of the
Smithsonian Institution)
Where the plain meets the eastern mountain
is the Laguna Mugu, with extensive marshes and a low,
narrow sand beach, with a slight tidal opening
as if the [Santa Clara] river may at one time have
emptied here.
—davidson 1897
967
192 6. ventura county shoreline • 193
Fig. 6.2. Habitats of the Ventura County shoreline, early 1800s. At least three general types of coastal systems, or coastal archetypes, can be identified along the Ventura shoreline:
freshwater-brackish estuaries associated with the Santa Clara and Ventura river mouths, dunedammed non-tidal lagoon systems (with associated salt/brackish marsh and salt flats) marking former Santa Clara River mouths, and the large coastal wetland system at Point Mugu.
PAGE
195 PAGE
200
oxnard
ventura
Ventura County
Los Angeles
County Pacific Ocean
N
1 mile
Santa Clara River
101
126
33 tsikatskats
pierpont
lowlands
mcgrath lake
west
grove
ponomo
1 PAGES
208-209
PAGES
226-227
101
salinas
laguna
hueneme
simomo/
spring hill
1 Perennial Freshwater Pond
Valley Freshwater Marsh
Willow Thicket
Wet Meadow
Alkali Meadow
Alkali Meadow/Flat
Oaks and Sycamores
Grassland/Coastal Sage Scrub
Palustrine and Terrestrial Habitat
Willow-Cottonwood
Forested Wetland
Other In-Channel Riparian
Characteristic Riparian Habitat
Intermittent or Ephemeral
Perennial
Distributary
Outer River Bank
Spring
Hydrology
Ocean
Beach
Dune
Tidal Lagoon (mostly open?)
Tidal Lagoon (seasonally open)
Non-Tidal Lagoon
Tidal Flat
Tidal Marsh
Seasonally Tidal Marsh
Salt/Brackish Marsh
Salt Flat/Seasonal Pond/Marsh Panne
High Marsh Transition Zone
Coastal and Estuarine Habitats
968
194 6. ventura county shoreline • 195
with the high-energy Ventura and Santa Clara river mouths and substantial freshwater influences; the distinctive Oxnard plain backbarrier lagoons associated with now-abandoned Santa Clara River mouths; and the large tidal wetland system at Mugu. These environments, exhibiting spatial and temporal variation in vegetation type, extent and duration of open water, salinity, and tidal connection, supported distinct mosaics of native species.
The following chapter provides a historical perspective on the patterns and characteristics of Ventura’s coastal features, including the Ventura River delta, the Santa Clara River mouth, the county’s backbarrier lagoons, and Mugu Lagoon.
Ventura River Delta
The Ventura River and floodplain empty into the ocean west of the city of Ventura. Historically, the estuary consisted of a large willow-cottonwood riparian forest with numerous distribuary channels, a tidal lagoon and tidal flat, salt marsh, high marsh transition zone, and a number of small seasonal ponds within the marsh (fig. 6.3). Similar habitat patterns largely persisted on the T-sheet resurvey (Greenwell and Forney 1870). By the 1933 resurvey, however, most of the estuarine features were no longer depicted, including the former lagoons, marsh, and willow-cottonwood forest (Kelsh 1933a).
Only limited trees (labeled “camping grounds in grove,” south of the 1855 extent of forest) and salt marsh are depicted on this later survey.
Apart from the T-sheets, there are limited data available describing the historical character of the Ventura River estuary. Ethnographer John P.
Harrington’s informants recalled tule marsh at the mouth of the river, where tule was collected and canoes were stored (Calendaria Valenzuela, in Hudson and Blackburn 1984; Timbrook 2007). These canoes were used on the lagoon at the Ventura River mouth (Simplicio Pico, in Hudson and Blackburn 1984). Wire rush (Juncus balticus) and Indian rush (J. textilis) were found in the sand dunes at the river mouth as well as “in the montes” and “at Sauzal,” both designations that probably refer to the willowcottonwood forest at the mouth (Blackburn 1963, Timbrook 2007).
Herbarium specimen records also describe the presence of this suite of marsh, flat, lagoon, and dune habitat at the Ventura River mouth, although most records are relatively late. The earliest collection, made by William Brewer in March 1861, describes the estuary and marsh as the “swamp by camp” (he collected distant phacelia [Phacelia distans]; Brewer [1930]1974).
Specimens collected in the dune community included marsh jaumea (Jaumea carnosa), beach saltbush (Atriplex leucophylla), California saltbush (Atriplex californica), branching phacelia (Phacelia ramossissima), Menzies’ goldenbush (Isocoma menziesii), sawtooth goldenbush (Hazardia squarrosa), silver bur ragweed (Ambrosia chamissonis), pink sand verbena (Abronia umbellata), and red sand verbena (A. maritima) (Pollard 1945, Hagerty 1950, Pollard 1962, 1963b, 1964). A more detailed exploration of 20th century botanical specimens can be found in Ferren et al. (1990).
The old Ventura canoe builders
stored their canoes in the tule marsh
at the mouth of the Ventura River.
They cut and piled up tule stems so
the canoe could rest out of the water,
and bent the tule growing on both
sides over the canoe as a sunshade.
The tips of the tule stalks interlaced
like the fingers of clasped hands, and
a pole was laid on top to hold them
in that position.
—timbrook 2007
Limited available evidence suggests that the Ventura River mouth did not close as regularly during the summer as did the Santa Clara River mouth, perhaps reflective of greater perennial flow in the lower reach in addition to lesser wave exposure. Based on the classification system of Jacobs et al. (2010), the river was a small to medium watershed in a prograding, low exposure (south facing) setting, with hydraulic estuarine formation, and would therefore be expected to be fully open or have subtidal closure more than half the time, with periodic closure up to and above high-high tide.
This analysis is supported by historical accounts. The earliest T-sheets for the two mouths, produced during the same year and the same (summer) season, show the Santa Clara River mouth separated from the ocean by a narrow barrier, while the lagoon at the Ventura River mouth maintained a narrow outlet. A GLO surveyor, surveying along the beach on July 1, 1869, noted crossing the “outlet of the mouth” of the river (Thompson 1869). The earliest evidence comes from the journal of explorer Juan Crespí in midAugust 1769 and May 1770. Crespí observed that the river “reached to the sea” in August, though at high tide there was no perceptible flow and an Fig. 6.3. Habitats of the Ventura River
mouth, early 1800s. Extensive riparian
willow-cottonwood forest and estuarine
habitat characterized the Ventura River
floodplain at its mouth.
N
1,000 feet
tsikatskats
101 1
33 Valley Freshwater Marsh
Willow Thicket
Wet Meadow
Grassland/Coastal Sage Scrub
Palustrine and Terrestrial Habitat
Willow-Cottonwood
Forested Wetland
Other In-Channel Riparian
Characteristic Riparian Habitat
Intermittent or Ephemeral
Perennial
Distributary
Outer River Bank
Hydrology
Ocean
Beach
Dune
Tidal Lagoon (mostly open?)
Tidal Flat
Tidal Marsh
Seasonally Tidal Marsh
Salt Flat/Seasonal Pond/Marsh Panne
High Marsh Transition Zone
Coastal and Estuarine Habitats
969
196 6. ventura county shoreline • 197
inlet was created (Crespí and Brown 2001). In May of the following year, however, his party was able to observe the river at low tide, and Crespí noted that “where we saw it the other time, it was not flowing but instead was ponded up and turning into an inlet; the tide was low this time, it was flowing almost as far as the very shore.”
The mouth did close, though closure dynamics are uncertain and not well documented. Timing, duration, and frequency of closure would have likely varied with yearly oscillations in rainfall, as well as with anthropogenic changes in flow in the lower river over time. The only historical evidence found that directly addresses the question is a newspaper article from 1909, describing a season with abnormally high flow:
The mouth of the Ventura river presents a sight more remarkable than for thirty years past. Indeed, not the oldest inhabitant can remember when it was just exactly as it is at present. There is a great volume of water still coming down from the mountains, and this is of a very beautiful dark green color. It has gathered in a great lagoon below the bridge, the lake presenting a frontage of almost a quarter of a mile to the ocean. Between the sea and the lagoon are piled up great masses of rock, of all sizes, tons and tons of it, and the waves run up on this at high tide, although they do not get over into the lake. The mouth of the river is at the extreme western point of the lake, a quarter of a mile further to the westward than it has ever been known to be…The stream shows small signs of closing up this summer, and very likely will not be closed. But if the lagoon remains as now, there will be plenty of duck shooting and lots of water for boating and for the boys to swim in. The lagoon in fact is deeper than it has been in years. The flood seems to have washed out the bed of the entire stream to an unparalleled depth below the old bed. (Ventura Free Press 1909b) One notable feature in the Ventura River delta was a brackish lake to the west of the end of Figueroa Street. The lake marked a former outlet of the river, and covered about 2.5 acres of open water and 9 acres of marsh.
This lake and former river mouth were also the site of a Chumash village, Mitsqanaqan. (See page 130 for more information on channel change at the mouth of the Ventura River.)
On the earliest (1855) T-sheet, the lake is shown occupying a low spot behind a narrow beach, not connected with the ocean and with substantial surrounding marsh (Johnson 1855c; fig. 6.4). It is documented similarly on the 1870 resurvey, though with a larger amount of open water adjacent to the beach. An unrelated survey from May 1868, however, shows a small lake with marsh in this vicinity with a clear connection to the ocean (Bard 1868). If this is indeed the same body of water, then the lake may have had at least an intermittent connection to the ocean.
The lake is vividly described by Chumash residents interviewed by John P. Harrington in the early 20th century. Though at the time they were interviewed the lake no longer existed, his informants recalled what it had been like decades earlier (fig. 6.5). The lake was called Tsikatskats (with variable spellings in Harrington’s notes), which was translated by his informants as “sweet water running below,” presumably referring to …there used to be a lake, but the
lake is gone now. This was not an
estero, nor did the water come from
the river, but seeped in from sea
through the sand.
—harrington 1913e
Fig. 6.4. Lake east of the Ventura River,
1855. This small brackish lake marked the
easternmost extent of the historical Ventura
River floodplain, and was surrounded by
extensive tule marsh (shown by the closely
spaced lines in the marsh on this map a ).
Though the symbol within the marsh is nonstandard b , we interpret it to be patches of grassy cover, such as saltgrass or seasonally
inundated meadow. (Johnson 1855c,
courtesy of the National Oceanographic and
Atmospheric Administration)
Fig. 6.5. Tsikatskats, the lake at the end of Figueroa Street. This photograph, taken in the fall of 1923, shows the remnant of what was once a well known brackish lake in the Ventura River floodplain. What are likely cattails (Typha latifolia) are visible in the foreground, along with stands of alkali bulrush (Scirpus [Bolboschoenus] maritimus) and bulrush/tule (Scirpus [Schoenoplectus] californicus; see particularly the matted vegetation to the right of the open water). Pickleweed (Salicornia virginica) dominates the foreground. (Harrington 1923b, courtesy of the Smithsonian Institution; plant interpretation, Baye pers. comm.)
N
200 feet
a
b
970
198 6. ventura county shoreline • 199
groundwater from the Ventura River found beneath an otherwise brackish lake (Harrington 1986a,b). It was described as a “pool of brackish water,” surrounded by abundant tule (Harrington 1986b):
The former lake situated where the pool of water is now situated, west of the lower end of Figueroa St. was called in V. tciqatcqatc, meaning “sweet water running below”. There used to be much tule there where the tule is now. The lake was where the water is now. (Harrington 1986b) Fig. 6.6. Two views looking across the city of Ventura to the shoreline. A circa 1875 image (top), taken from the hill behind Mission San Buenaventura facing southwest, shows the low floodplain area east of the Ventura River. A portion of what is likely Tsikatskats lake can be seen in the distance, at a . A nearly identical view (below), taken about eight years later, shows the same area in flood. What appears to be a small seasonal pond or panne, corresponding in shape to one depicted on the T-sheet 28 years earlier, can be seen at b . (This feature is visible on fig.
6.3 as the leftmost salt flat/seasonal pond/marsh panne, shown in pink.) (Unknown ca. 1875, Pierce ca. 1883; courtesy of the California Historical Society)
1875
1883
a
b
The lake, only present as a small pond/slough complex in 1913 as described by Harrington’s informants, was barely visible on the 1927 aerial imagery, and left unmapped on the 1933 T-sheet resurvey. The area, historically part of the Ventura River delta, continued to flood well into the 20th century (fig. 6.6). It has remained in relatively unintensive use even today (it is now the parking lot across from Seaside Park at the Derby Club).
Santa Clara River Mouth
The mouth of the Santa Clara River encompassed a diverse array of freshwater, brackish, and saline habitats. A seasonally open tidal lagoon, bordered by tidal marsh, formed the outlet of the river. To the north and south, alkaline/saline habitats (e.g., alkali meadows and salt flats) as well as abundant freshwater habitats (wet meadows, willow-cottonwood forests, and a freshwater lake and surrounding marsh) were also present (fig. 6.7 and 6.8). Under Jacobs et al.’s (2010) definitions, the Santa Clara River mouth regularly closed above high-high tide or perched, with seasonal breaching and opening to the subtidal level. This closure pattern reflects the river mouth’s exposure to wave action in addition to freshwater inputs from the watershed.
The seasonality of the estuary is well documented by historical accounts.
The earliest detailed depiction of the lagoon at the river mouth, surveyed during the 1855 summer field season, shows the lagoon separated from the sea by a narrow beach (Johnson 1855c). In a report associated with this survey, Johnson explains that though at the time of writing (October 1) the lagoon was not connected with the ocean, “after the rains of winter begin, it…has water enough to break through the narrow sand-beach at present separating it from the sea” (Johnson 1855a). A subsequent U.S. Coast Survey report supports this, stating that “in the rainy season a volume of water is brought down having sufficient force to break through the narrow sand beach and flow into the ocean” (Daily Alta California 1857; a direct quote from Davidson 1864). These descriptions are corroborated by other (albeit less precise) 19th century sources, which also describe a lagoon with “no visible communication with the sea, save when in winter the floods tear away the intervening wall of sand” (Thompson and West [1883]1961; see also Storke 1891) and a river “blocked up by sandhills in summer” (Cooper 1887).
Maps also support this variability: some cartographers showing the lagoon open to the ocean, while others show no connection. One early sketch shows a narrow “salt laguna” at the mouth of the river, with no connection to the ocean (Unknown ca. 1870). Another much later map also shows a large, disconnected lagoon (Farrell 1935). However, other maps show the lagoon with a clear tidal connection (e.g., Stow 1877, Schuyler 1900, Holmes and Mesmer 1901b, Kelsh 1933b; fig. 6.9). The earliest topographic quad and a historical soil survey contain an intermediate depiction, showing thin blue lines connecting the lagoon to the ocean (USGS 1904, I would state here that there is one
peculiarity in the creeks and many
of the rivers and small esteros on the
southern coast of California, and
that is that in the dry seasons the
creeks and rivers sink before they
get to the ocean, and their mouths
are closed or filled up with drifting
sand…
— unknown ca. 1869
971
200 6. ventura county shoreline • 201
oxnard
ventura
Ventura County
Los Angeles
County Pacific Ocean
101
1 126
west
grove
pierpont lowlands
mcgrath lake
Ocean
Beach
Dune
Tidal Lagoon
(seasonally open)
Non-Tidal Lagoon
Seasonally Tidal Marsh
Salt Flat/Seasonal Pond
/Marsh Panne
Coastal and Estuarine Habitats
Perennial Freshwater Pond
Valley Freshwater Marsh
Willow Thicket
Wet Meadow
Alkali Meadow
Alkali Meadow/Flat
Grassland/Coastal Sage Scrub
Palustrine and Terrestrial Habitat
Willow-Cottonwood
Forested Wetland
Other In-Channel Riparian
Characteristic Riparian Habitat
Intermittent or Ephemeral
Perennial
Distributary
Outer River Bank
Spring
Hydrology
Fig. 6.7. Habitats of the Santa Clara River mouth, early 1800s. A seasonally open tidal lagoon, tidal marsh, alkali meadows, and salt flats, as well as abundant freshwater habitats (wet meadows, willow-cottonwood forests, and a freshwater lake/surrounding marsh) characterized the mouth.
N
½ mile
Pierpont Bay
Mandalay Beach
Fig. 6.8. Habitats of the Santa Clara River mouth, here overlaid on a modern aerial image, illustrate the former extent of estuarine and riparian habitats. (USDA 2009)
972
202 6. ventura county shoreline • 203
Nelson et al. 1917; fig. 6.10). Unfortunately, none of these maps specify the season of survey.
The T-sheet resurvey for the river mouth, conducted in January and February 1933, supplies a detailed depiction of the lagoon in winter, and provides a useful counterpoint to the summer survey of 1855. In the resurvey, the lagoon is open through a narrow breach in the sand (Kelsh 1933b). The surveying party describe the closure dynamics in the accompanying descriptive report:
In dry weather this river mouth is practically or wholly closed. At the time of the survey (Jan-Feb 33) a steady shallow stream about 25 M. [80 feet]wide was flowing as shown, but when place was visited in October for additional notes on recent developments the mouth was closed. (Kelsh and Green 1934c)
This description is consistent with roughly contemporary descriptions of the lagoon from engineer C. E. Grunsky, who writes that “during the summer and fall, and, occasionally, throughout the entire year, the mouth of the river is blocked by a barrier of beach sand piled up by the ocean waves” (C.E. Grunsky Company 1925). He also explains some of the steps local landowners were taking to diminish the size of the lagoon:
The mouth of the river is closed to the ocean for a considerable period of time each year by a barrier of sand which is thrown up by the ocean waves. The crest of this barrier is usually at such a height that when the river begins to flow in early winter its water accumulates behind the same to a height which the landowners in the vicinity find undesirable.
An artificial cut is then made through the barrier and the ponded water escapes. If there is abundant rainfall and a fair amount of runoff the cut is kept open by the flowing water. If there is but little water to be discharged into the ocean the cut may be repeatedly closed by the ocean storms in a single season.
The limited available evidence describing tules, cattails, willows, and pondweed suggests substantial freshwater influence on the Santa Clara River estuary. The presence of perennial flow in the lowest reach of the river (see chapter 3) and persistent summer closure have the potential to create strong freshwater-brackish zones in the lagoon and surrounding wetlands (ESA PWA et al. 2011). The willow-cottonwood forest of West Grove also suggests freshwater conditions. A birder documented a “tule-bordered lagoon” near the mouth, as well as numerous sloughs with “a dense growth of pondweed [Stuckenia pectinata/Potamogeton pectinatus]” (Hoffmann 1921, 1926). Cooper, describing a visit to the river mouth in early spring of a dry year (1872), still noted fresh conditions, as well as the presumed interannual variability of habitats at the mouth:
On May 10, 1872, I visited the mouth of the river purposely to see what birds bred there, but I found only a Mallard sitting among the cat-tails in the wettest part of the marsh, most of which seemed too dry for safety… Cattle grazed all over the marshes…The advantages for birds to breed there must vary much in different years. (Cooper 1887)
Fig. 6.9. Seasonally tidal lagoon at the
mouth of the Santa Clara River, 1877. An
early depiction of the lagoon open to the
ocean. (Stow 1877, courtesy of the Museum
of Ventura County)
Fig. 6.10. Seasonally tidal lagoon at the
mouth of the Santa Clara River, 1904.
Rather than showing the lagoon as open or
closed, this historical topographic quad uses
thin blue lines perpendicular to the coastline
to represent the connection between the
lagoon and the ocean. (USGS 1904, courtesy
of CSU Northridge Geography Map Library)
1877
1904
N
1,000 feet
N
1,000 feet
In addition to West Grove, substantial freshwater habitat was present in the form of freshwater McGrath Lake and the extensive, seasonally flooded wet meadow covering the Pierpont lowlands (what today is the low-lying area around the Ventura harbor; fig. 6.11). These floodplain areas would have been inundated during extreme floods by the Santa Clara River.
McGrath Lake is one of the few remaining coastal water bodies on the Oxnard Plain shoreline, though its origins are different than the mostly closed, brackish/saline tidal lagoons historically to the south (and derived from ancient river flows). Unlike these lagoons, McGrath was a freshwater lake, with hydrologic inputs derived primarily from active surface flows from the Santa Clara River and groundwater. The lake is shown on the region’s T-sheet, labeled “fresh water” (Johnson 1855b; fig. 6.12). The lake as shown here was 8 acres, with 5 acres of fringing freshwater marsh. The lake occurred in a low spot between parallel ridges of sand dunes, and was also surrounded by willow thickets and seasonally inundated grassland. Cooper Quite a number of persons were
down in McGrath’s bottoms last
Sunday ‘a blackberrying,’ but the
crop seemed to be very light this
year…
—ventura free press 1891a
Fig. 6.11. This 1947 view of the coastline around the Santa Clara River mouth shows McGrath Lake a to the south of the closed river mouth b and the Pierpont lowlands to the north, together composing the low, broad floodplain of the river at its mouth. The city of Ventura can be seen in the background. (Spence Air Photos 1947, courtesy of the Benjamin and Gladys Thomas Air Photo Archives, UCLA Department of Geography) a
b
973
204 6. ventura county shoreline • 205
(1967) described stands of tule (Scirpus [Schoenoplectus] spp.) associated with the lake.
For whatever reason, the historical record is mostly silent on McGrath Lake, though it was likely the site of many summer excursions in the late 19th and early 20th centuries. One record, from a 1910 newspaper article identifying potential park locations on the Oxnard Plain, describes the lake as part of the larger habitat community at the site, noting that “another spot that is a very fine one for the people of Oxnard and community would be at the McGrath Grove, a willow grove beside a fine lake, the property of the Dominick McGrath estate and the scene of numerous picnics” (Oxnard Courier 1910).
Though the appellation has persisted, the precise location of the lake has shifted substantially over the past 150 years. What was historically considered to be McGrath Lake is currently predominantly willowcottonwood forest and developed land; only the tail of the historical lake overlaps with the current lake-marsh complex (fig. 6.13). It is unclear when this shift occurred, though it had clearly happened by the time the first aerial imagery was flown (1927) and the T-sheet resurveyed (1933).
Both sources show an extent of open water almost identical to what was present in 2005, with a large area of marsh north of the lake and covering the lake’s former position (Fairchild Aerial Surveys 1927, Kelsh 1933b).
Overall, the extent of the lake has increased from eight acres in 1857 to fifteen acres in 2005.
To the north of the mainstem Santa Clara River, the Pierpont lowlands were a broad, low coastal flat extending more than 2.5 miles northward, nearly to the Ventura River, and comprising the westernmost extent of the Santa Clara River delta (fig. 6.14). Located between sand dunes and a bluff marking a former coastline, the flat trapped water from the Santa Clara River during floods, creating a large area of seasonally inundated wet meadow. This feature of the Pierpont area is captured by the early T-sheet survey, where “overflowed during winter” is written across the entire plain. The feature is a result of progradation, as Ventura River sediments were deposited north of the convex Santa Clara River mouth (Putnam 1942).
By the turn of the 20th century, the seasonal wetland between the dunes and the bluff was under cultivation with beets and barley, though the area must have still been frequently flooded (Waud ca. 1899). By the late 1920s, the northern portion of the lowlands had been subdivided and a few houses built on the wetland and dunes, though evidently not without trouble—the T-sheet records that “small streets beyond those shown [are] buried in sand” (Fairchild Aerial Surveys 1927, Kelsh 1933b; see fig. 6.14). This area is what would become the modern subdivision at Pierpont Bay, north of the Ventura Marina. Flooding is still an issue in portions of the Pierpont area, and wetlands are still present at Alessandro Lagoon at the northeastern end of the lowlands (see fig. 6.29).
[Fig. XX63. detail of t-576 of McGrath and surroundings; with label “fresh water”]
Fig. XX63. McGrath Lake, 1855. The lake
occurs at the boundary of two T-sheets,
and is mapped by both. On this sheet,
covering the area from McGrath Lake to
Hueneme, the lake is labeled “fresh water,”
a rarity on the Oxnard Plain. (Johnson
1855[t-576], courtesy of the National
Oceanic and Atmospheric Administration)
Third day journeyed southwesterly
ten miles, and struck the sea; thence
fifteen more northerly to near the
mouth of the Santa Clara, and up
the lower bottom of that stream to
camping ground in the enclosure of
Mr. Pierpont.
—daily alta california 1868
Fig. 6.12. McGrath Lake, 1855. The lake
occurs at the boundary of two T-sheets, and
is mapped by both. On this sheet, covering
the area from McGrath Lake to Hueneme,
the lake is labeled “fresh water,” a rarity on
the Oxnard Plain. (Johnson 1855b, courtesy
of the National Oceanic and Atmospheric
Administration)
N
500 feet
Oxnard Plain Shoreline
From the mouth of the Santa Clara River to Mugu Lagoon, a broad barrier beach-dune system characterized the Ventura shoreline. Like the Oxnard Plain itself, this system—and the associated series of backbarrier lagoons and wetlands extending for nine miles downcoast—were formed by the Santa Clara River, each lagoon marking a former mouth of the river and dunes indicating the Ventura and Santa Clara rivers’ ample sediment supply.
These non-tidal lagoon complexes covered a total of 1,000 acres with open water and associated marsh habitats (compared to Mugu Lagoon’s 2,550 acres), collectively making them the second largest coastal wetland area in Ventura County (fig. 6.15). (These acreages do not include the adjacent high marsh transition zone, which accounts for an additional 1,640 acres of wetland habitat.) A combination of coastal development (including dredging and drainage), with the reduction of sediment supply from the Fig. 6.13. Comparison of historical and modern location and extent of McGrath Lake.
Between 1855 and 2005, McGrath Lake has shifted about 1,500 feet to the south. However, the extent of open water appears broadly comparable. The 1904 historical topographic quadrangle (at left) shows the lake covering a broad extent roughly comparable to the 1855 mapping (shown in red outline). (USGS 1904, courtesy of CSU Northridge Map Library; USDA 2005) 2005
N
500 feet
1904 2005
974
206 6. ventura county shoreline • 207
Fig. 6.14. Between 1855 and 2005, the seasonally inundated lowlands at Pierpont have been heavily developed. The beginnings of a street grid can faintly be seen on the historical aerial in the dunes (middle); this same street pattern has persisted to the present day (right).
Today, this area includes the Ventura Harbor. Note that a subdivision shown on the northern part of the Pierpoint lowlands is now part of San Buenaventura State Beach. (Johnson 1855c, courtesy of the National Oceanographic and Atmospheric Administration; Fairchild Aerial Surveys 1927, courtesy of Whittier College; USDA 2005)
1855 1927 2005
oxnard
ventura
Ventura County
Los Angeles
County Pacific Ocean
N
1,000 feet
Ventura and Santa Clara River watersheds, has drastically altered this portion of the shoreline (Orme 2005).
Broadly, the lagoon complexes shared multiple characteristics. Most had high marsh to open water ratios, and were dominated by extensive areas of vegetated emergent wetlands rather than open water. They also shared similar tidal dynamics, since each lagoon maintained little to no tidal access and most were blocked by substantial sand dunes. However, in other respects the systems were quite heterogeneous, with a broad array of variable ecological and hydrological expressions. In particular, the salinity concentrations and degree of seasonal inundation both varied widely across systems, in turn implying variations in lagoon depth and the quantity and source of hydrologic inputs. In addition to this inter-lagoon complexity, each lagoon complex also experienced yearly fluctuations in salinity and degree of inundation. As a result of these broad variations by year, season, and lagoon, early sources can be challenging to interpret.
Despite fragmentary historical documentation, many of these similarities and distinctions are captured by early accounts. While fine distinctions (e.g., perennially inundated lagoon versus seasonal pond) may be challenging to make with the available data, the overall characterization of the Oxnard Plain shoreline as a region with a matrix of perennial lagoons, seasonal ponds and salt flats, and salt/brackish marsh is very clear. These four factors—ecology, tidal access, seasonality, and salinity—are explored in detail below.
While they are typically thought of as lagoons, most (65%) of the aggregate area was vegetated marsh, as shown by the USCS T-sheet (Johnson 1855b, 1857). Seasonally flooded salt flats composed another significant proportion of the total area. (Our mapping shows 12% of the total area as salt flat, though this extent might have increased in dry years.) As is the case for other coastal wetland systems in Ventura County, however, little detailed documentation exists describing the historical plant community composition of these lagoon complexes. The idiosyncratic data we discovered mostly describes the Hueneme area, and emphasizes the marshy nature of these systems. Documented plants from narrative accounts include Indian rush (Juncus textilis) and a “salt grass point” in the Hueneme area (Eames 1889, Blackburn 1963). Early botanical specimens were collected at Hueneme from both brackish and salt marsh habitats, including obligate wetland species such as Virginia glasswort (Salicornia virginica), saltmarsh baccharis (Baccharis douglasii), salt sandspurry (Spergularia marina), the currently rare species saltmarsh bird’s-beak (Cordylanthus maritimus ssp. maritimus), and the federally endangered Ventura marsh milkvetch (Astragalus pycnostachyus var. lanosissimus) (Kline 1924, Peirson 1925, Craig 1927, Purer 1935). A few accounts also describe the abundant waterfowl found around these lagoons, especially in the winter, such as “flocks of wild duck” (Eames 1889) and “many thousands” of geese and ducks (Haydock 1971). One account, from a journal entry describing an outing in March 1902, records more detail:
Deponent avers that there are
numerous salt ponds along the whole
length of coast from the mouth of the
river Santa Clara to the south west
corner of the rancho…
–bard 1869
975
208 6. ventura county shoreline • 209
Fig. 6.15. A series of backbarrier lagoons, salt flats, and marshes stretched from south of the Santa Clara River mouth all the way to Mugu Lagoon (the western edge of which is at the right edge of this spread). Separated from the ocean by often extensive dunes, these systems were characterized by variable salinity, seasonality, and habitat proportions. (See fig. 6.24 for the modern aerial of this area.) oxnard
ventura
Ventura County
Los Angeles
County Pacific Ocean N
1,000 feet
Port Hueneme
salinas
Ocean
Beach
Dune
Non-Tidal Lagoon
Tidal Marsh
Salt/Brackish Marsh
Salt Flat/Seasonal Pond/Marsh Panne
High Marsh Transition Zone
Coastal and Estuarine Habitats
Willow-Cottonwood
Forested Wetland
Other In-Channel Riparian
Characteristic Riparian Habitat
Intermittent or Ephemeral
Perennial
Distributary
Outer River Bank
Spring
Hydrology
Mandalay Beach
laguna
hueneme
1 Ormond Beach
Palustrine and Terrestrial Habitat
Perennial Freshwater Pond
Alkali Meadow
Alkali Meadow/Flat
Grassland/Coastal Sage Scrub
976
210 6. ventura county shoreline • 211
Fig. 6.16. The earliest detailed surveys of the Ventura shoreline, completed in 1855 and 1857, show the coastal wetlands with impressive precision. (Johnson 1855b and Johnson 1857, courtesy of the National Oceanographic and Atmospheric Administration) N
1,000 feet
oxnard
ventura
Ventura County
Los Angeles
County Pacific Ocean
977
212 6. ventura county shoreline • 213
…we drive along in full view of several islands and observe the sand bar that waves have thrown up, that prevents the water from coming in where it formerly held sway thereby leaving a marsh and beach and many enclosed lakes and streams in and upon which are all kinds of denizens of the deep, fowls and some animals. We note three flamingoes, many water-snipe, pelicans in great numbers and ducks in flocks and pairs; and many familiar birds in these ponds are shovel-bills (resemble shovels and dig in sand)…There was an oyster bed at the point but it has been destroyed by waves and sand. (Wallace Weston Brown, in Brown 1981) By far the most detailed depiction of the suite of coastal lagoons is provided by a set of USCS T-sheets produced in the summers of 1855 and 1857, the maps upon which the bulk of our own historical habitat mapping is based (Johnson 1855b,c and Johnson 1857; fig. 6.16; see Grossinger 2011 for more discussion of these sources). These early surveys depict the lagoons as a series of open water/salt flat/marsh complexes separated from the ocean by sand dunes, which range from 300 to 3,300 feet wide and with high points consistently above 60 feet in elevation northwest of Hueneme.
None of the lagoons are shown with a tidal outlet, and the lagoons’ squareend shapes and the presence of the wide, vegetated barrier dunes suggests that these systems opened relatively infrequently. These systems, though A broad barrier beach-dune system stretched from the
Santa Clara River mouth to Mugu Lagoon, separating
the numerous lagoon-salt marsh complexes from the
ocean (fig. 6.17). The early T-sheets capture the complex Aeolian topography with characteristic detail, with solid and dashed (intermediate) red contour lines indicating
20 foot contour intervals. The mapping indicates that
the dunes were broader and taller north of Hueneme,
with the highest points consistently above 60 feet. Sand dune width ranges from 300 - 3,300 feet. This dune
topography was described by another observer as a
“continuous, high sandy beach or sea wall,” where “hills and sand ridges—some of them being 60 to 75 feet
high, lying parallel with the beach line—widen out and
occupy a space of from half to three fourths of a mile” (Reed 1871).
Vegetation varied with position on the dune structure,
with different species characterizing the foredune,
middle, and inner/backdune zones. These patterns
are described by Cooper (1967), who described
vegetation on the dunes near Hueneme: saltbush
(Atriplex leucophylla) and verbena (Abronia spp.) on the foredune, herbaceous cover and salt grass (mapped
as alkali meadow) and “extensive thickets of the usual
species of willow” on the middle zone, and shrubs
on the innermost dunes. Many of these patterns are
also reflected on the T-sheet, in particular the middle dune zone patterns of large patches of grass in dune
depressions and occasional willow trees and groves.
Dune species recorded near Mandalay Beach in 1930s
specimen records include yellow bush lupine (Lupinus
arboreus), beach evening-primrose (Camissonia
cheiranthifolia ssp. suffruticosa), and pink and red sand verbena (Abronia umbellata and A. maritima), among
many other species (Fosberg 1931a,b; Wolf 1931; fig.
6.18). Dunes in the Pierpont Bay region were recorded
to have seacliff buckwheat (Eriogonum parvifolium var.
parvifolium; Craig 1927).
lagoons and dunes
not identical, could generally be considered perched and/or dune-dammed (Jacobs et al. 2010).
This depiction of the lagoons—as a series of small systems with an infrequent tidal connection—is supported by supplementary sources, which confirm the persistence of these features throughout the 19th century. An early resident testified in 1869 that the two lagoons at Hueneme had been present as long as he had known the area, “as early as 1837 or before that time” (Gonzales 1869). Subsequent independent depictions of the lagoons are consistent with the T-sheet, matching the general location and extent of each feature, though these maps generally did not map salt marsh and fail to distinguish between salt flat and open water (Bard 1870a,b; Reed ca. 1871; Stow 1877; Schuyler 1900; Holmes and Mesmer 1901b; USGS 1904). None of these maps show any of the lagoons with a tidal connection. Narrative descriptions also support the largely non-tidal aspect of the lagoons. It was stated that the two lagoons at Point Hueneme “are some distance from and do not communicate with the sea” (Smith 1871), while the lagoons north of Point Hueneme “have no daily communication with the ocean, but on occasions of storms the waves sometimes wash over from the sea into said Fig. 6.17. Dune topography and vegetation near McGrath Lake, 1855 (left). Surveyors indicated a depression in the dunes with the letter “d” a , while the small red circles are thought to indicate dune tussocks b (Grossinger et al. 2011). The grassy symbol in some of the dune depressions (far left of image) is alkaline grassland c . A few willows are shown on higher portions of the dunes d . This detail is from the dunes north of West Fifth Street. (Johnson 1855/t-576, courtesy of the National Oceanic and Atmospheric Administration) Fig. 6.18. “Hueneme Point from east,” 1913 (right). Linguist and ethnographer John P. Harrington took Chumash elder Fernando Librado on a series of field trips around Ventura County, documenting significant places and place names. Librado, who would have been in his 70s at the time of this photo, is shown standing in the dunes at Point Hueneme. Some dune vegetation can be seen, including red sand verbena (Abronia maritima) and likely shrubby beach primrose (Camissonia cheiranthifolia ssp. suffruticosa; Baye, pers. comm.). This is consistent with Cooper (1967), who noted that verbena was characteristic of the “hillocks” of the foredunes near Hueneme. (Harrington 1913c, courtesy of the Smithsonian Institution) N
500 feet
a
b
c d
978
214 6. ventura county shoreline • 215
salt ponds” (Rodriguez 1871b). Of the two lagoons at Point Hueneme, one resident wrote:
Neither of these waters are connected with the sea, but both of them are disconnected from the beach by sand hills. It is possible that during the high Spring tides the water may swash over the sand hills in front of the Salinas, as there is very little vegetation growing on the sand hills in front of the said ‘Salinas’—but deponent has never witnessed such over swash, though he has been along the coast here at this point very frequently and at all seasons of the year… (Bard 1871)
Lagoons north of Point Hueneme were blocked from the tides by substantial sand dunes which would have almost never been breached by the ocean, while lagoons south of Point Hueneme, bordered by much smaller dunes, may have experienced more frequent dune overwash.
Though the series of lagoonal systems was composed of at least four distinct complexes, early observers often referred to them as one large, continuous backdune feature (with a few notable exceptions—see below). Early references to “a strip of swampy land full of sloughs, and lagunas…from a half to three quarter of a mile in width” or “sloughs and marsh lands back of the sand hills” extending from the Santa Clara River to Mugu Lagoon illustrate this point (Thompson 1867, Haydock 1971). This is consistent with the habitat patterns represented on the T-sheet, on which lagoons are connected by extensive tidal marsh and seasonally inundated alkali meadow. This entire wetland area would have been flooded for much of the winter, creating one large marsh extending, in some years, all the way to Mugu Lagoon. In the summer, large portions of the shallow lagoons dried up, creating extensive salt flats.
These fluctuations in the quantity of open water throughout the year present a challenge in mapping these systems, particularly the lagoon (open water) and salt flat components. Lagoons and salt flats are similar geomorphic features at different points of the hydrologic spectrum: substantial components of many coastal lagoons dried out during the summer, while many salt flats were flooded during the winter, making the distinction between an open water lagoon and a salt flat somewhat arbitrary. This is reflected in historical sources as well; a few features mapped as ponds or lagoons in one source are mapped as a salt flat in another. Luckily, many of these nuances were captured by early maps and accounts which specified the degree of inundation of various lagoons at different times of year. Olivas (1861) stated that between two of the lagoons north of Hueneme, “all the space between the two lakes at certain seasons of the year is covered with water—at other times it is dry between these.” At the south end of the lagoon series, another resident noted that the lagoons only connected with Mugu Lagoon “in years where there is much rain, when they may discharge their surplus waters in the said estero” (Rodriguez 1871a).
During the summer the region would have looked very different, with many of the seasonal ponds and even shallower lagoons drying up partially …there are no esteros, lagunas, or
salt ponds other than the Estero
Grande [Mugu Lagoon] that have
outlets to the sea…
—stow 1871
I know the two ponds [lagoons at
Hueneme]—they are well known,
at times there is dry land between
them—they are close together.
—antonio maria olivera 1857
Fig. 6.19. Coastal lagoons near Point
Hueneme, 1870. Four lagoons between
Point Hueneme (at left) and Mugu Lagoon
(western edge visible as “mud flat” at
right). Though we mapped each feature
as a non-tidal lagoon, note the labels on
the lagoons—meaningfully, each of the
four lagoons is labeled slightly differently.
The Salinas was so known because of its
use as a collection site for salt in the 19th
century, suggesting substantial hypersaline
and salt flat components. Similarly, the
“dry pond,” though it would not have
dried out completely every year, may have
been shallower than adjacent lagoons.
The “Laguna Hueneme” was well known
for its freshwater inputs. The “salt pond”
was found at the mouth of what is known
today as the Oxnard Industrial Drain at
Ormond Beach. Despite outward similarity,
this map suggests substantial variation in
hydrology and habitats across systems. (Bard
1870b, courtesy of The Bancroft Library, UC
Berkeley)
or completely. Ornithologist James G. Cooper spent two “uncommonly dry” summers in the region in 1872-1873, and noted that at that time he “could ride a horse through almost any part” of the coastal marshes, “the exceptions being some salt lagoons encrusted with the white crystals, and unfit for nests, besides being almost deserted by all the birds, those seen being only a few small Waders and Sparrows” (Cooper 1887). Another party inspecting the lagoons during the dry season as part of a land dispute in 1871 only found water in three of the lagoons: the two at Hueneme Point and another small lagoon to the east (Reed 1871). Reed further stated that “I judge the water in these lagunas to be about on a level with high tide; the ordinary tides rising only about four feet, and spring tides about five feet, on this coast…In the summer, they contain very little water—the evaporation being almost equal to the seepage through the sand hills from the sea.” (It should be noted that seepage from the ocean may have been unlikely prior to groundwater extraction on the Oxnard Plain; Swift pers. comm.)
These general observations are corroborated by annotations on an early map, which identifies some lagoons as “salt ponds” and another as “dry pond” (Bard 1870a; fig. 6.19). Remarkably, the T-sheet also has annotations describing summer conditions, written in exceptionally faint pencil within some of the lagoons and seasonal ponds. A few (for example, two seasonal ponds south of modern-day Channel Island Boulevard) are labeled “dry,” another portion of one as “salt land” (perhaps marking an exposed portion of the lagoon), while others are labeled “salt water.”
Despite outward similarity—each lagoon is consistently described as “salty” by 19th century observers—such variations in hydrology and topography across different lagoon complexes created variations in salinity between and within systems. Water sources for these lagoons were a mix of saline input (from sea spray and possibly from infrequent dune overwash and seepage) and fresh water input (from precipitation, runoff, and springs). Evidence indicates that some of these lagoons were fed by freshwater springs, and therefore would have maintained fresh-brackish-saline gradients and salinity stratification with depth (Parsons 2004, ESA PWA et al. 2011).
Conversely, other lagoons had extremely small watersheds and no defined oxnard
ventura
Ventura County
Los Angeles
County Pacific Ocean
N
½ mile
979
216 6. ventura county shoreline • 217
surface channel for freshwater input, and as a result maintained saline or hypersaline conditions. Different systems would have included different components, ranging from perennial freshwater zones in the upper portions of spring-fed lagoon/slough complexes to hypersaline salt lagoons, salt flats, and seasonal pannes.
An extreme example of this variability is found in the two ponds formerly near Hueneme (fig. 6.20). Both lagoons were well known in the 19th century, with names preserved in the historical record. To the west of Hueneme, at the current site of the port of Hueneme, was a salt water lagoon called Sitiptip by the Chumash (Harrington 1913e) and La Buena Salina or the Salinas by Spanish-speaking residents (Harrington 1986a).
The Salina was so called because of its use as a gathering place for salt, implying that substantial portions of the lagoon were shallow enough to dry out during the summer for salt harvesting (fig. 6.21). This lagoon was described as the place were early residents would gather salt, and which was “well known to and is designated by the older inhabitants as the place where a certain Dr. Poli, several years ago was accustomed to collect salt and to ship the same to San Francisco” (Bard 1869, Bard 1871). This is reflected in our mapping from the T-sheet, where the ratio of salt flat to open water is 1.4.
To the east of Hueneme, another lagoon covered approximately 35 acres.
Unlike the Salina to the west, this lagoon had a very low ratio of salt flat to open water, only 0.14. It was popularly known as Laguna Hueneme (and to the Chumash as Sislomow; Harrington 1913e). The use of the term laguna (lake) here is notable, and unique to this lagoon. It may refer to a greater water depth, the relative lack of salt flats, or to a difference in salinity from the salt ponds surrounding it. It was quite renowned, and was included in the language of the 1846 sale of the San Buenaventura Mission as a primary landmark: “the Laguna Hueneme, Palo Alto [a large sycamore tree on the Oxnard Plain], the cultivated fields of Santa Paula, [and] the Mission Cañon [Ventura River valley]” (Weber 1978).
The laguna, or lake, at Hueneme,
is shown on the diseño near Point
Hueneme, and also on the U.S.
Coast Survey map, and the small
‘salinas,’ or salt ponds, further
inland. Between the laguna and salt
ponds, at Hueneme, and the sea, is
a wide barrier of high land, ‘staying
the sea,’…
—fernald & richards and green
1871
Fig. 6.20. Lagoons near Hueneme, 1877.
Two well recognized lagoons were found on
either side of the town of Hueneme (shown
in its nascent form here). The “salt pond,” to
the west of town, was known as the Salinas.
To the east was spring-fed Laguna Hueneme.
(Stow 1877, courtesy of the Museum of
Ventura County)
N
1,000 feet
Fig. 6.21. The Salinas, 1913. These two
images provide two different views of the
Salinas lagoon, formerly located where the
port is now. The view is generally southwest;
high dunes (top and middle) and the Point
Hueneme lighthouse (top; built in 1874)
can be seen in the background. In the
foreground, extensive salt marsh (mainly
pickleweed, probably with some salt grass
component and visible pannes) stretches
toward the lake. A small boat (detail; at left)
can be seen on the lagoon in both pictures,
indicating some depth. (Harrington 1913b,d;
courtesy of the Smithsonian Institution)
980
218 6. ventura county shoreline • 219
The abundance of information preserved in the
historical record about these coastal lagoons, in
particular about the Salinas and Laguna Hueneme,
is in large part thanks to an early land dispute. The
resulting court case centered on the wedge of land on
the Oxnard Plain between two interpretations of the
eastern boundary position for the Río de Santa Clara o
la Colonia Rancho. The case largely hinged on the use
of the word estero in the original property description (translated variously as a salt marsh, tidal creek, or
estuary), where the boundary was described as hitting
the coastline “between two esteros.” But what, exactly, was an estero? And to what feature in Ventura County
did the term refer? The grant’s owners contended that
the term referred to the two sloughs or arms feeding
into Mugu Lagoon, and that estero should be translated
as “estuary,” and argued that the term must refer to
a water body with a tidal connection. The settlers,
however, interpreted the term to refer to Laguna
Hueneme and the Salinas, arguing that Mugu Lagoon
was an estuario (estuary), while estero was a broader
term that referred to the salt lake and marsh complexes along the coast and was unrelated to the tides. (The
settlers’ interpretation would have opened up a wedge
of land between Point Hueneme and Mugu Lagoon
for settlement.) Ultimately, the dispute was resolved in favor of the land owners, and the boundary line was run to Mugu Lagoon.
what is an estuary?
Fig. 6.22. “Duck shoot near Hueneme,” ca. 1889. This image shows a portion of Laguna Hueneme in the late 19th century. The lagoon is surrounded by tule (likely Scirpus [Schoenoplectus] californicus). What is likely sago pondweed (Potamogeton pectinatus/ Stuckenia pectinata) can be seen in the foreground (Collins pers. comm.). This photograph, also included as a lithograph in an 1889 article in Overland Monthly and Out West magazine on traveling in Ventura County, matches the description included in that article well: “spears of purple reeds [likely tule], with flocks of wild duck plowing luminous furrows across its steel-gray floor” (Eames 1889). (Brewster ca. 1889, courtesy of the Museum of Ventura County) The most notable aspect of Laguna Hueneme, however, was its freshwater input from springs on the Oxnard Plain. Though this characteristic was not unique to the laguna (it has also been documented for the lagoon immediately to the east; Parsons 2004), it is extremely well documented in this case. Early residents testified that the laguna was “fed by springs of fresh water” (Bard 1871). This characteristic of Laguna Hueneme is a product of its status as a former mouth of the Santa Clara River, relatively recently occupied and still the recipient of substantial freshwater flows (see page 71). Though Laguna Hueneme itself is long gone, this is still the case today: the Hueneme Drain/Bubbling Springs Drain, a man-made channel which occupies the location of the former slough which fed into the lagoon, has perennial flow today as a result of springs (HDR Engineering 2009).
Despite this, the laguna was still considered to be a “salty” lagoon, labeled “salt water” on the T-sheet and described as salty in court testimony:
“though the Hueneme is fed by fresh water springs” (Johnson 1855b, Reed 1871). It is likely that portions of the laguna (for example, closest to the shore) were saline, while other portions further upslope were brackish. An early image of a portion of the laguna shows abundant tule fringing the water (fig. 6.22).
Fragments of the Laguna Hueneme complex have persisted to the present day in the form of Moranda Park/Bard’s Bubbling Spring. Though the lagoon looks largely intact in the 1938 aerial imagery, it was drained shortly thereafter, apparently filled with sediment from the dredging of the harbor at the site of the Salina lagoon (Moranda 1999, Maulhardt 2005). Currently, though the lagoon has been completely drained and filled, the slough that fed it still runs to the ocean in the same location. This is also true of the formerly spring-fed lagoon to its east, at Ormond Beach.
Most traces of the other lagoon complexes have been completely obliterated over the past 100 years (figs. 6.23 and 6.24). Much of this change had already happened by the early 1930s, by which time a five mile long drainage ditch, stretching from south of the Santa Clara River all the way to its outlet at Hueneme and bisecting the former locations of many of the coastal lagoons, had been constructed to drain the area.
Many lagoons became salt flats or marshes, tidal marshes became alkali meadows, and alkali meadows were in large part flushed and cultivated.
Historical aerial imagery from 1927 and 1938 hint at this transformation, showing a long canal bisecting dry flats and clearly salt-affected land where 1850s surveyors mapped lagoons. The USCS T-sheet resurvey from winter 1933 captures the lagoons’ disappearance even more explicitly (Kelsh 1933b and Kelsh 1934; fig. 6.25). Precise annotations describe former lagoon locations as “former salt pond (now drained)” in the Mandalay Beach area, “ponds formerly shown now drained” near Channel Islands harbor, and “pond, apparently drying up” at the south end of Ormond Beach. Other lagoons are shown with a combination marsh/lagoon symbol. The obvious exception is the spring-fed Laguna Hueneme, shown with substantial water We stopped our horses on a rustic
bridge that we might better view the
Laguna, winding sinuously among
its spears of purple reeds, with flocks
of wild duck plowing luminous
furrows across its steel-gray floor.
—Eames 1889
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220 6. ventura county shoreline • 221
Fig. 6.23. Oxnard Plain shoreline,1927/1938. Traces of most of the 19th century lagoon complexes are still visible at the time these photos were taken in the 1920s and 1930s, though it is clear that many are in the process of being drained by the long canal seen at left a . A few lagoons, such as Laguna Hueneme b and the adjacent lagoon to the east, still appear to be filled with water. Traces of the former Santa Clara River channel are clearly visible at c , feeding into Laguna Hueneme. (Fairchild Aerial Surveys 1927, courtesy of Whittier College, USDA 1938, courtesy of Ventura County)
oxnard
ventura
Ventura County
Los Angeles
County Pacific Ocean
N
1,000 feet
a
c
b
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222 6. ventura county shoreline • 223
Fig. 6.24. Oxnard Plain shoreline, 2005. By 2005, most traces of the former lagoon complexes have been erased. A few markers remain, such as sloughs near Ormond Beach that used to empty into lagoons (portions of which have been repurposed as the Oxnard Industrial Drain and the Hueneme Drain). A lagoon similar to former features has formed to the east of Laguna Hueneme at Ormond Beach. (USDA 2005) 1 mile N
Beach
Dune
Non-Tidal Lagoon
Tidal Flat
Salt/Brackish Marsh
Salt Flat/Seasonal Pond/Marsh Panne
High Marsh Transition Zone
Coastal and Estuarine Habitats
Alkali Meadow
Palustrine and Terrestrial Habitat
oxnard
ventura
Ventura County
Los Angeles
County Pacific Ocean
N
1,000 feet
983
224 6. ventura county shoreline • 225
Fig. 6.25. In 1855, a small (14 acre) coastal lagoon was recorded by the U.S. Coast Survey, at what is now the end of West Wooley Road at Mandalay Bay (top left). Nearly 80 years later, in the descriptive report accompanying the T-sheet resurvey, the cartographers note that a drainage ditch (visible here on the aerials; top right) “has drained the salt pond shown on the former work… although the general shape as a dry hole is still apparent” (bottom left; Kelsh and Green 1934c). By 2005 all traces of the lagoon have been erased: only the drainage ditch remains (bottom right). (Johnson 1855b, courtesy of the National Oceanic and Atmospheric Administration; Fairchild Aerial Surveys 1927, courtesy of Whittier College; Kelsh 1933b; courtesy of IMC; USDA 2005)
1855 1927
1933 2005
oxnard
ventura
Ventura County
Los Angeles
County Pacific Ocean
N
500 feet
West Wooley Road
in the aerial imagery and apparently intact on the resurvey. The two lagoons on either side of it, the Salinas and another spring fed lagoon to the east (at Ormond Beach), are shown with what appears to be both open water and marsh components.
Changes are also documented in the surrounding former salt marsh and high marsh transition zone, labeled as “dried up marsh,” “meadow” or “marshy meadow,” and “dry salt meadow.” In a few portions of the former salt marsh (and in much of the former alkali meadow) the resurvey identifies “cultivated field.” In the descriptive report accompanying the T-sheet resurvey, the surveyors describe this transition:
East of this town [Hueneme] the country has remained in an undeveloped state except for the fact that farming has increased and developed this area for truck farming. As a result small swamps and sloughs have been filled in, and the farm land pushed out towards the coast, in turn tending to dry up the small ponds lying behind the sand dunes along the coast… From Hueneme west the beach area has been developed into a series (continuous) of summer resorts…Behind this ridge [of sand dunes] a long drainage ditch parallels the coast, draining into the sea just west of the Hueneme Lighthouse. This has completely eliminated the ponds previously shown, and the whole area has been developed into farming country. (Kelsh and Green 1934b) Mugu Lagoon
Mugu Lagoon, known historically as the Estero Grande or Mugu Laguna, was one of the largest coastal wetland systems in Southern California, covering about 2,550 acres in the mid-1850s. (An additional 1,110 acres of high marsh transition zone formed an ecotone between Mugu Lagoon and the alkali meadows of the Oxnard Plain.) The lagoon occurs in a structural basin formed by the folding and faulting of marine sediments. The lagoon itself is trapped in an embayment behind prograding beach spits (Warme 1971, Jacobs et al. 2010).
The lagoon/marsh complex was the site of a broad range of coastal wetland habitats, many of which are still present today due to Mugu Lagoon’s relative protection within the Point Mugu Naval Station. The complex contains the largest coastal wetland remnant in southern California today (Orme 2005).
A number of researchers have studied the history of cultural and physical change at Mugu Lagoon at length (e.g., Warme 1971, Steffen 1982, Onuf 1987, Swanson 1994, USACE 2003). An exhaustive search of the available historical record yielded little additional detail on early ecological patterns and processes at Mugu Lagoon, understandable given the region’s extensive salt marshes and subsequent lack of intensive early development. As a result, we focus here on discussion and interpretation of the 1857 T-sheet (the most detailed early picture of the area), bringing to bear supplementary sources to describe the patterns of historical habitat distribution in the area.
October 26. At noon we made a
little tea and were eating it when
suddenly the wind blew a spark into
a bunch of green tule, which was
in a blaze in a minute, the flames
spreading with great rapidity…
Fortunately an estero prevented its
spreading far and by night we had it
subdued.
—Bowers 1879, in Benson 1997; at
Point Mugu
984
226 6. ventura county shoreline • 227
Fig. 6.26. Habitats of Mugu Lagoon,
early 1800s. The historical habitat mosaic
surrounding Mugu Lagoon included
substantial amounts of subtidal habitat,
tidal flat, tidal marsh, tidal channels, marsh
pannes, salt flat, vegetated former dune
strands, and high marsh-alkali meadow
transitional zones.
oxnard
ventura
Ventura County
Los Angeles
County Pacific Ocean
N
1,000 feet
N
½ mile
Ocean
Beach
Dune
Tidal Lagoon (mostly open?)
Tidal Flat
Tidal Marsh
Salt Flat/Seasonal Pond/Marsh Panne
High Marsh Transition Zone
Coastal and Estuarine Habitats
Alkali Meadow
Alkali Meadow/Flat
Grassland/Coastal Sage Scrub
Palustrine and Terrestrial Habitat
Intermittent or Ephemeral
Perennial
Distributary
Hydrology
This map is now available in greater resolution than previously (Grossinger et al. 2011).
The historical habitat mosaic at Mugu Lagoon included substantial amounts of subtidal habitat, tidal flat, tidal marsh, tidal channels, salt pannes/ seasonal ponds, salt flat/playa, vegetated former dune strands, and high marsh-alkali meadow transitional zones (fig. 6.26). Most of these features are shown in detail in the 1857 US Coast Survey T-sheet (Johnson 1857; fig. 6.27). The predominant habitat type at this time was tidal marsh (58%), with the remainder of the area distributed among subtidal water (14%), tidal flat (12%), salt flat/marsh panne (10%), and open water ponds (5%).
Mugu Lagoon included a relatively large subtidal area compared to most other Southern California estuaries (Grossinger et al. 2011). Historical maps also show evidence of extensive tidal channel networks as well as former beach ridges reflecting former shoreline positions (Thompson 1994). Historical botanical records support the prevalence of tidal marsh in the first half of the 20th century, with specimen localities described as “salt marsh on shore of lagoon,” “dry salt marsh,” “border of salt marsh,” and “mudflats around tidal lagoon” (Fosberg 1931c,d; Hoffmann 1932a; Nobs and Smith 1948). Salt marsh vegetation captured in early (pre-1950) 1 985
228 6. ventura county shoreline • 229
records includes Virginia glasswort (Salicornia virginica), Parish’s glasswort (Salicornia subterminale), marsh jaumea (Jaumea carnosa), and marsh rosemary (Limonium californicum) (Howell 1927; Fosberg 1931c,d; Purer 1935). The T-sheet resurvey of 1932 described the salt marsh south of the western arm of the lagoon as “low coarse eel grass” (Kelsh 1933b).
Supplementary sources help confirm habitat interpretations on the T-sheet.
In particular, Thomas Bard’s 1870 map of Mugu Lagoon is another highly detailed mid 19th-century depiction of coastal wetlands, and provides independent confirmation (after the 1861-2 flood) of many of the features shown on the T-sheet 15 years earlier. For example, Bard (1870a) confirms stippled areas shown on the T-sheet at the marsh margin as unvegetated salt flats, and refers to the salt grass area and neighboring salt flats as “mudflats,” generally confirming their alkali playa characteristics. An early soils map helps confirm the extent of salt marsh depicted on the T-sheet (Nelson et al. 1917).
These sources also provide details not represented on the T-sheet, particularly at the upland edge of Mugu Lagoon (since the early T-sheet does not consistently map the full inland extent of tidal marsh). The full extent is indicated by these additional sources (6.28; see also fig. 6.2). The zone of strong alkali influence shown on the 1917 soils map provides a continuous boundary for the inland extent of tidally-influenced habitats We soon came to miles of marked
surface, overflown by salt water in
the winter and spring season, when
the tides and winds are highest.
At such times they are the shallow
extension of the western branches
of the Estero Grande—the now bare
surface being then covered with
water…
—reed 1871, describing the salt
flats of western mugu lagoon
Fig. 6.27. Mugu Lagoon, 1857. (Johnson
1857, courtesy of the National Oceanic and
Atmospheric Administration)
N
1,000 feet
across the entire lagoon complex, while the Bard map provides clues to the nature of the habitat at the upland edge of the marsh. The map shows a number of areas of “Juncal” or “Juncal Grande” on the upland edge of the marsh, a now-rare ecotone between tidal marsh and the adjacent lowlands of the Oxnard Plain that we mapped as high marsh transition zone. These depictions presumably represent large stands of Juncus, likely spiny rush (Juncus acutus), which was collected extensively in the area by native peoples for basketry (Timbrook 2007). Juncus acutus var. leopoldii was collected at the site in the 1950s and 1960s (Raven and Thompson 1959) and is reported today (USACE 2003). The presence of these large stands of rush indicates substantial brackish tidal marsh zones, both at the eastern margin towards the Calleguas Creek drainage and elsewhere in the marsh.
These habitats appear to have been greatly reduced today. This modification to Mugu Lagoon may have significant habitat implications. For example, the rare light-footed clapper rail (Rallus longirostris levipes) is found to nest at Mugu Lagoon primarily in the spiny rush stands (USACE 2003).
The T-sheet indicates the presence of this high marsh ecotone in a few places, using a subtle variation in symbology at the northwest edge of Mugu Lagoon to show the broad transitional area between the tidal marsh and adjacent alkali meadow (Johnson 1857). The surveyor fortunately provided a clue for the interpretation of this symbol, annotating the margin with 986
230 6. ventura county shoreline • 231
the words “line of salt grass” in faint handwritten pencil. We interpret this annotation as the distinction between the high marsh ecotone (which would have presumably had a high concentration of saltgrass (Distichlis spicata)), and the adjacent alkali meadow, which may have been a matrix of salt-tolerant and other grassland species.
Despite the detail these sources provide, the full former inland extent of the Mugu complex is unknown, and there is some indication that it once extended substantially further inland. Dr. William Livingston, who grew up in the Hueneme area in the 1870s and 1880s, recalled in a 1929 interview that Mugu Lagoon had shrunk considerably over his decades living on the plain:
Dr. Livingston also tells me that in his time Mugu Lagoon has filled up to a very great extent. Originally it was a large body of water and the probabilities are that it extended in the sixteenth century to the foot of the hills where the principal town was located. Indeed, it is possible that at that time it was open ocean at that point, the lagoon not having formed. Dr. Livingston states that one time the Santa Clara River emptied into the ocean in this neighborhood, the old channel being still plainly visible. (Wagner 1929, in King 2005)
This remark is corroborated by a member of an outing to Point Mugu in March 1902, who stated that “there are indications that the marsh extended further inland, and it is claimed that small steamers and boats used to come up to the now tidewater mark” (Wallace Weston Brown, in Brown 1981).
It is possible that these accounts capture early sedimentation and deposition on the marsh plain as a result of the construction of a channel connecting Calleguas Creek to Mugu Lagoon, reducing tidal extent. The initial date of channelization has been widely stated as 1884 (e.g., Steffen 1982, Onuf 1987, Swanson 1994, USACE 2000); while this is possible, the origin of the assertion is unclear and we found no direct evidence to support it. Regardless of the precise timing, however, it is clear that Calleguas Creek did not maintain a defined connection to Mugu Lagoon prior to channelization efforts, which would have likely been initiated sometime during the late 19th or early 20th century (see page 169). If this is the case, shrinking of Mugu Lagoon could have been a result of increased sedimentation from the Calleguas watershed after channelization, as sediments previously deposited on the Oxnard Plain during floods were transported instead to Mugu Lagoon and the ocean. This process is confirmed by sediment transport calculations, which estimate a ten-fold increase in sedimentation rates over geologic levels as a result of the channelization of Calleguas Creek (Warme 1971, Steffen 1982, Capelli and Cave 1983).
Another possibility is that the former extent of Mugu Lagoon before Mission times is not captured fully by the 1857 T-sheet survey and other early sources described above. There is no way to verify this with the available historical data, though early General Land Office survey notes –slightly predating the T-sheet—suggest that this might have been the case (fig. 6.28). Notes from two surveyors in 1853-4 indicate tidal influence above our mapped zone of tidal marsh and high marsh transition Fig. 6.28. Historical extent of tidal influence at Point Mugu, early 1800s. The Mugu Lagoon wetland complex, including high marsh transition zone areas, extended quite far inland in the 19th century compared to its current extent. Early surveyor’s notes hint that the tidal zone may have extended even further inland, as shown by the excerpts above. Excerpts along the survey line refer to a line segment rather than an individual point. (USDA 2009) over tide wash, to salt weed
overflow by tide water
low rich alluvial, almost
entirely overflowed by tide
from rich to thin sandy
surface, over flow from tide
rich low prairie…
overflowed by tide
oxnard
ventura
Ventura County
Los Angeles
County Pacific Ocean N
½ mile
Historical extent of tidal
influence (approximate)
987
232 6. ventura county shoreline • 233
zone. Washington (1853) described a mile-long transect “almost entirely overflowed by tide from the Pacific Ocean” crossing the western slough entering Mugu Lagoon, from 500 to 1,600 feet north of our mapped extent of tidal influence. He also noted “mostly rich low prairie…is overflowed by tide water” for nearly a mile west of modern Calleguas Creek, an area mapped by Bard (1870a,b) as “juncal” and largely interpreted in our mapping as high marsh transition zone, and noted “over flow from tide” more than 1,600 feet north of this mapped edge of high marsh transition zone. Hancock (1854) also noted “tide wash” extending 1,200 feet above the mapped edge of the high marsh transition zone above the western arm of the lagoon, differentiating between “tide wash” to the south and “salt weed” (presumably alkali meadow) to the north. We did not consider these points sufficient evidence to extend our mapping, since it is also possible that these areas were non-tidal, salt-affected lands (e.g., alkali meadows and flats) of the lowland Oxnard Plain. These accounts may also reflect flooding induced by perched conditions created by periodic or partial inlet closure (Jacobs pers. comm.).
Despite these changes, Mugu Lagoon has shown significant resilience over time. By the time of the T-sheet resurvey of November-December 1932, though most of the non-tidal lagoons to the north had been (or were in the process of being) drained, the subtidal and salt marsh components of Mugu Lagoon looked largely similar to the 1857 condition: so much so that the 1933 surveyors called the coastal complex “practically unchanged… even the small sloughs in the swamp area were found as shown” (Kelsh and Green 1934a). The major exception was the migration of the lagoon inlet, which had shifted almost 3,000 feet west during the intervening 76 years.
As might be expected, evidence of closure states for Mugu Lagoon indicate that the nature of the lagoon’s connection to the ocean was complex, dynamic, and variable. The cyclical migration and closure of Mugu Lagoon’s inlet in the 20th century has been well documented. Sources indicate repeated closure of the inlet and migration in response to onshore and longshore wave action balanced with hydraulic forces from the lagoon and the Calleguas Creek watershed (Bascom 1954). The general location of the mouth is governed by the presence of Mugu Canyon offshore, but its location moves from the northwest to southeast over time in response to longshore movement of sand. When the mouth gets to the southeastern portion of this range it is more susceptible to complete closure from the berms built during winter storms (Bascom 1954). The lagoon then breaks through again at the canyon head and repeats the process. In the mid-20th century, this process was documented to occur up to twice a year (Bascom 1954). This closure pattern was also documented by Warme (1971), who noted that “at present the lagoon mouth is naturally sealed off about every six months to one year” before being immediately dredged open.
Many of the above observations date from after significant modifications to the lagoon complex such as road building, diking, dredging, and the construction of a channel between Mugu Lagoon and Calleguas Creek. These activities would have impacted lagoon processes, reducing tidal prism, restricting tidal access, and altering sediment availability, distribution, and freshwater inputs. As a result, the relationship of these later observations to 18th and 19th century lagoon closure dynamics is uncertain and has been intensively debated. While Warme (1971) stated that Mugu Lagoon experienced a similar cycle of closure and mouth migration prior to the major modifications of the 20th century, Onuf (1987) asserted that even prior to channelization the lagoon’s tidal prism “would have been sufficient to keep the mouth open at all times.” Nineteenth century sources accentuate the relatively open character of the lagoon complex. Historical maps consistently show the lagoon with an open inlet, suggesting a direct connection to the ocean (e.g., Johnson 1857, Bard 1870b, Reed ca. 1871, Stow 1877, USGS 1904, Petit 1919). Early descriptions of the lagoon also emphasize its communication with the ocean, in contrast to the other lagoon complexes along the coast: “there are no esteros, lagunas, or salt ponds other than the Estero Grande [Mugu Lagoon] that have outlets to the sea” (Stow 1871). No 19th century source was found that described inlet closure. These data suggest that on the spectrum of Southern California estuaries, Mugu Lagoon likely had a greater degree of tidal connection than neighboring, smaller systems.
However, comparison of the early maps listed above also clearly shows changes in mouth position and width over time. One early surveyor described perceived changes in the nature of the outlet in the mid-19th century, noting that Mugu Lagoon’s “outlet to the sea, which is now only
25.00 chains or a little more than ¼ mile wide” had shrunk substantially:
“old residents informed me that its width had lessened one half, within the period of their knowledge of it” (Reed 1871). It is not clear whether these data represent cyclical mouth migration and periodic closure as described in the 20th century or change through time in the lagoon’s closure dynamics.
Southern California lagoons existed in a range of closure states, and were connected to or closed off from the ocean at different times.
Understanding of and terminology to describe these systems is currently in development, as advanced by Jacobs et al. (2010). Unfortunately, the historical record itself is insufficient at this time to resolve degree of closure or the former frequency, timing, and duration of closure patterns.
It seems clear from 19th century data that Mugu Lagoon was at least periodically tidally influenced. It is possible that the size of the open water area may have created a sufficiently large tidal prism to maintain connectivity with the ocean for extended periods of time (Onuf 1987, Coats et al. 1989). Nevertheless, it is important to note that though these data emphasize the lagoon’s connection to the ocean, they do not preclude occasional or regular cycles of closure, or closure in the subtidal/intertidal by a bar (Jacobs et al. 2010). Further archival and field-based research at Mugu and other sites may provide additional insight into the nature of these early lagoon dynamics.
988
234 6. ventura county shoreline • 235 Summary of Findings The following points represent some of the significant findings from our research on the Ventura County shoreline. Along with an understanding of modern conditions, these findings can support scientists and managers working to identify restoration opportunities in these coastal systems.
1. A diversity of coastal systems characterized the Ventura shoreline, each with differing habitat patterns and hydrologic dynamics. The overall habitat distribution is well documented, though available historical sources only begin to indicate the range of coastal processes that created these patterns, from Mugu Lagoon to the backbarrier lagoons, dunes, salt flats, and tidal marshes of the Oxnard Plain.
2. Coastal wetland habitats covered about 4,300 acres, accounting for a large proportion of former Ventura County wetlands. Differences in freshwater input, extent of vegetative cover, and closure regime led to varying support functions for native fish and wildlife.
3. Three distinct types of coastal estuarine systems characterized the Ventura County shoreline: the freshwater-brackish, intermittently or seasonally closed estuaries of the Ventura and Santa Clara rivers; the non-tidal lagoon complexes marking former Santa Clara River mouths; and the large, more tidally-influenced wetland system at Mugu.
4. The Ventura and Santa Clara River estuaries were periodically open to the Pacific Ocean.
Regular, seasonal cycles of closure were documented for the Santa Clara River mouth. The Ventura River mouth closed only occasionally (less frequently than the Santa Clara River), reflecting its greater historical volume of summer flow in the lowest reach, steeper channel gradient near the mouth, and lesser wave exposure.
5. The estuaries of both rivers also shared similar habitat mosaics. Both rivers had fairly compressed estuaries, with the relatively limited saline and brackish wetland habitat near their mouths bordered by extensive freshwater habitats, most notably the willow-cottonwood forest and wetland documented at both mouths.
6. McGrath Lake is a regionally significant feature, unique because of its persistence over the past centuries and its freshwater character. Though the lake has persisted, its location has shifted substantially since the mid-1850s; only a small portion of its current area overlaps with its historical extent.
7. An extensive suite of marsh, salt flats/pannes, and lagoons stretched from south of the Santa Clara River to the western edge of Mugu Lagoon. Prior to drainage and agricultural expansion, these systems were a significant component of the Ventura County shoreline.
They exhibited a range of habitat patterns based on variable salinity gradients and hydrologic inputs, from the spring-fed brackish Laguna Hueneme to the hypersaline Salinas near Point Hueneme.
8. Mugu Lagoon was the largest wetland complex in Ventura County, and the site of a broad range of coastal wetland habitats, including salt and brackish marshes, large salt flats, and extensive tidal channel networks. Dominant habitat cover was tidal marsh. There is some indication that the complex formerly extended substantially further inland than currently recognized. Its acreage has been dramatically reduced.
9. Salt flats and high marsh transition zone were major components of Mugu Lagoon. These transitional, high elevation habitats were particularly characteristic of the semi-arid climatic setting (Ferren et al. 2007), and have been disproportionately lost from this system. These features likely provided breeding habitat for shorebirds such as least tern and snowy plover (as small present-day remnants still do), as well as an inland migration zone for tidal marsh transgression in response to naturally rising sea level in the past.
Management Implications
• The preponderance of closed conditions in most lagoons along the Oxnard Plain suggests strategies for habitat rehabilitation in these areas. Efforts to restore coastal lagoon functions in these areas, for example at Ormond Beach, should consider these historical dynamics in restoration design. Current physical conditions at these sites (e.g., barrier dunes, small watersheds) may not reliably support open marine conditions without regular maintenance, but could potentially provide support functions for a range of native species. Restoration activities could also enhance the ecological functions of existing features. For example, the lagoon at Ormond Beach, though formed at a different location than historical features, currently exhibits similar closure dynamics. Sustaining and augmenting the geomorphic and ecological functions of this feature is an important restoration consideration. • Coastal lagoon complexes with high salinity levels and extensive surrounding salt marsh and salt flat were a significant component of the historical Ventura County shoreline. These complexes, which occurred in areas with extremely small watersheds and limited freshwater input, may be under-represented in Southern California today. • Conversely, brackish-freshwater conditions maintained in some coastal complexes may be considered a significant component of coastal habitat restoration strategy. While most coastal habitats historically exhibited high salinity levels, a few places maintained fresh-brackish conditions. In particular, the Santa Clara and Ventura river mouths and spring-fed lagoons such as Laguna Hueneme were less saline than surrounding systems. Maintenance of contemporary freshwater sources should be considered to restore or maintain such environments, with adequate consideration of water quality concerns.
• Re-establishing transitional habitats at Mugu Lagoon is an important component of habitat restoration, and may be of regional significance. Mugu Lagoon is recognized as the biggest coastal wetland complex in Southern California, yet it has lost much of its habitat area, particularly on its landward edge. High marsh ecotone, a transitional habitat between tidal marsh and alkali meadow, was a significant component of Mugu Lagoon and accounted for much of the region’s wetland area. Re-establishing portions of this ecotone may be an important component of the lagoon’s future persistence and resilience, and could provide room for inland 989
236
migration in response to sea level rise. This is one of the few places where this is possible in Southern California.
• Consideration should be given to potential brackish marsh areas within Mugu Lagoon. Rush stands documented at the northern edge of the complex may have been important historically for light-footed clapper rail, as they are today. Expansion of this habitat may be an important part of species recovery and enhancement plans.
Fig. 6.29. San Jon Road at
Highway 101, looking west.
Areas of the Pierpont lowland
are still susceptible to flooding,
as shown in this December
2008 photograph.
990
238 future research • 239
recommendedfuture research
This study documents historical landscape patterns of the Santa Clara and Ventura river valleys, the Oxnard Plain, and the Ventura County shoreline prior to major Euro-American modification. In particular, it focuses on former habitat distribution, riverine character and processes, and riparian ecology in each of these areas. However, there are a number of additional research directions that would enrich our understanding of the historical landscape and enhance our ability to apply these findings to current local management.
Additional geographic areas of interest
This research focused on the Ventura County portion of the Santa Clara River and valley, with limited investigation on upper (Los Angeles County) river reaches. Additional data on the upper river undoubtedly exists in Los Angeles County archives not visited during the course of this project, such as the Santa Clarita Valley Historical Society, the Los Angeles Public Library, the Braun Research Library, the Los Angeles County Surveyor’s Office, and the Los Angeles County Assessor’s Office. A more detailed understanding of this portion of the river, in conjunction with other studies (e.g., Stillwater Sciences 2011), would provide insight into the historical hydrogeomorphic processes and riparian patterns across the entire river.
The study area also excluded a few adjacent areas of possible interest.
These include the Ojai Valley east of the Ventura River, and the Santa Rosa Valley and Conejo Valley/Thousand Oaks area east of the Oxnard Plain. In addition, while the lowest reaches of major tributaries to the Santa Clara River were included within the study area, they were not the focus of our research. Subsequent data collection and analysis efforts could reveal more details on the historical dynamics of these systems, in particular Santa Paula, Sespe, and Piru creeks.
Future research directions
Though this study covers many aspects of the Ventura County historical landscape, it is not comprehensive. A number of additional topics merit further research, and would contribute to a better understanding of ecological and hydrogeomorphic pattern, process, and function in the region. While we performed limited analysis of historical botanical and ornithological records, the voluminous available data merit more substantial analysis. In addition, we did not explore historical faunal records. A detailed analysis of these wildlife records by regional experts may support interpretation of historical habitats and linkages with species support functions, which is for the most part not covered in this report.
This is particularly true for native fisheries use of Ventura County streams.
Future research into processes and dynamics that shaped the historical ecological landscape would further develop our understanding of former conditions. For example, more in-depth investigations of the history of invasive species introduction (such as Arundo donax), fire ecology, historical grazing impacts, and Chumash land management would provide important context for interpreting historical conditions.
In addition, future research may further elucidate historical trends and characteristics outlined here. Interviews with long-time county residents would deepen our understanding of local environmental change and persistence. Scientific studies using geoarchaeology, coring, remote sensing, and other techniques could also add additional detail to this picture of early conditions. More extensive field-based assessment of the findings outlined here would also be useful.
Application of report findings
The research presented in this report provides the foundation for supporting local and regional environmental management with detailed historical data. However, the historical record alone is insufficient to apply these findings on the ground. This research must be integrated with contemporary assessments of physical and biological conditions to develop practical, place-specific conservation strategies for use by local organizations. For example, the management implications explored here for floodplain and riparian restoration need to undergo feasibility analysis before application to particular sites. Partnerships between local residents, managers, and scientists is a crucial component of determining how and where to apply these data.
991
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U.S. Fish and Wildlife Service (USFWS). 2009. A system for mapping riparian areas in the western United States. U.S. Fish and Wildlife Service, Division of Habitat and Resource Conservation, Branch of Resource and Mapping Support, Arlington, VA.
U.S. Geological Survey (USGS). 1903a. Santa Paula Quadrangle, California :
15-minute series (Topographic): 1:62,500. Washington, D.C.
U.S. Geological Survey (USGS). 1903b. Santa Susana Quadrangle, California :
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U.S. Geological Survey (USGS). 1903c. Ventura Quadrangle, California : 15-minute series (Topographic) 1:62,500. Courtesy of Los Angeles Public Library.
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Vancouver G. [1798]1984. A voyage of discovery to the North Pacific Ocean and round the world, 1791-1795: with an introduction and appendices. Ed. WK Lamb.
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Van Dyke TS. 1890. Millionaires of a day: an inside history of the great Southern California “boom”. New York, NY: Fords, Howard & Hulbert.
Van Valkenburgh R. 1935. Notes on the ethnography and archaeology of the Ventureño Chumash Indians. Transcribed from microfilm on file at the Smithsonian Institute, Washington, D.C. (6042-Archaeology of California). Courtesy of Ojai Valley Historical Society and Museum.
Ventura County. 1945. [Aerial photos of Ventura County] C-9800. 1:14400.
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Ventura County Fish and Game Commission. 1973. The Ventura River recreational area and fishery: a preliminary report and proposal. Ventura County Fish and Game Commission, Ventura, CA.
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Ventura Daily Democrat. 1902. [Irrigation in Ventura County, 9/14/1902]. In Robert O. Browne (1974). San Buenaventura Mission water system. Ventura, CA.
Ventura Free Press. 1876. Santa Paula items. February 26, 1876. Courtesy of Museum of Ventura County.
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Ventura Free Press. 1878a. From Ventura to Santa Paula: small farms and lots of ‘em.
May 4, 1878. Courtesy of Museum of Ventura County.
Ventura Free Press. 1878b. [Heavy surf creates sand bank at the Santa Clara River mouth]. January 19, 1878. Courtesy of Museum of Ventura County.
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Ventura Free Press. 1878d. Notes from Santa Paula: ‘Old Jeff ’s’ weekly budget.
October 12, 1878. Courtesy of Museum of Ventura County.
Ventura Free Press. 1879. [Advertisement for May Day picnic, Santa Paula, May 1, 1879]. April 12, 1879. Courtesy of Museum of Ventura County.
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Ventura Signal. 1871a. A ride through the valley. [Signed by G.M.]. October 7, 1871.
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Ventura Signal. 1876a. Ranches of Ventura County. January 8, 1876. Courtesy of Museum of Ventura County.
Ventura Signal. 1876b. Water. August 19, 1876. Courtesy of Museum of Ventura County.
Wagner HR. 1941. Juan Rodríguez Cabrillo, discoverer of the coast of California.
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Watts WL. 1898. View looking S.E. from peak west of Piru, Ventura County.
F3735:2326. California State Mining Bureau, field work of 1898. Courtesy of the California State Archives.
Waud JB. 1903. Map showing the San Buenaventura River bed on lands belonging to W.I. Rice, John Meiners Estate and the Ventura Water Light & Power Co, Ventura County, California. Ventura, CA. 1 in.:300 ft. Courtesy of Museum of Ventura County.
Waud JB. ca. 1899. Continuation of road petitioned for by A. Levy et als. 800 ft:1 in.
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Weber FJ, editor. 1978. The Mission by the sea: a documentary history of San Buenaventura Mission. Hong Kong: Libra Press Limited.
Whipple AA, Grossinger RM, Davis FW. 2011. Shifting baselines in a California oak savanna: nineteenth century data to inform restoration scenarios. Restoration Ecology 19(101):88-101.
Wigington PJ, Ebersole JL, Colvin ME, et al. 2006. Coho salmon dependence on intermittent streams. Frontiers in Ecology and the Environment 4(10):513-518.
Wolf CB. 1931. Record for yellow bush lupine (Lupinus arboreus), Oxnard Plain sand dunes; May 14, 1931. Courtesy of The Jepson Online Interchange: California Floristics, UC Berkeley.
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Government Printing Office.
Yorba Y. 1837. U.S. v. Ysabel Yorba, Land Case No. 177 SD [Guadalazca Grant (Guadalasca)]. U.S. District Court, Southern District. p. 62. Courtesy of The Bancroft Library, UC Berkeley.
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ATTACHMENT 1
1009
CENTRAL COAST ALLIANCE UNITED FOR A SUSTAINABLE ECONOMY
EARTHJUSTICE
NATURAL RESOURCES DEFENSE COUNCIL
WISHTOYO CHUMASH FOUNDATION
February 14, 2022
VIA ELECTRONIC MAIL
Jay Dobrowalski
Senior Planner
City of Oxnard Planning Division
214 South C Street
Oxnard, CA 93030
Email: [email protected]
Re: The Port of Hueneme- Temporary Outdoor Vehicle Storage Facility Project (#2020069039) and PZ 18-500-02 (Special Use Permit)
Dear Mr. Dobrowalski:
We respectfully submit the following comments to the Draft Environmental Impact Report (“DEIR”) for the Port of Hueneme- Temporary Outdoor Vehicle Storage Facility Project (“Port of Hueneme Project” or “Project”) on behalf of the Central Coast Alliance United for a Sustainable Economy (“CAUSE”), Earthjustice, National Resources Defense Council (“NRDC”), and Wishtoyo Chumash Foundation.
CAUSE is a base-building organization with deep roots in the City of Oxnard. CAUSE has worked closely with Oxnard residents to organize around social, economic, and environmental justice issues for over two decades. CAUSE has worked to protect communities from the environmental hazards of liquified gas terminals, power plants, and metal scrapyards. For years, CAUSE has worked with residents of South Oxnard working towards a vision to deindustrialize the Oxnard coast and open access to Ormond Beach, where the environmental restoration of hundreds of acres of wetlands is underway. Many of its members live, work, and go to school in and around the Project. They have a direct interest in the decision at issue here that will shape Oxnard’s future, and specifically in the City of Oxnard Planning Department’s careful analysis regarding the impact of this Project on their neighborhoods and the surrounding areas.
Earthjustice is a nonprofit public interest environmental law organization serving grassroots environmental justice organizations across the country to preserve irreplaceable wildlands, protect biodiversity, demand clean air and water, and protect frontline communities from polluting industries. Earthjustice has represented several nonprofit organizations, community groups, and grassroots coalitions in Ventura County on a number of environmental issues. 1010
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NRDC is a non-profit organization that works to safeguard the earth, including its people, its plants and animals, and the natural systems on which all life depends. NRDC combines the power of roughly 3 million members and activists, including approximately 50 in South Oxnard and Port Hueneme, with the expertise of some 700 lawyers, scientists, and policy advocates across the globe to ensure the rights of all people to the air, the water, and the environment.
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 a 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.
With this DEIR, the City of Oxnard (“City”) seeks approval for a vehicle storage site to facilitate the Port of Hueneme’s (“Port”) operations off-site. At the outset, it is important to provide some perspective on the true magnitude of the Project and its potential impact on the surrounding communities. This Project, which will serve to bring port-related activity into the communities of South Oxnard, cannot be treated in isolation. It must be seen as part of a larger Port expansion project that includes plans to create similarly dedicated but much larger storage sites that will undoubtedly impact the region. Unfortunately, as described throughout these comments, the DEIR fails to comply with the California Environmental Quality Act (“CEQA”). As such, the City cannot rely on the document as a form of environmental impact review for the purpose of Project approval. Should the City decide to move this Project forward, it must engage in a new DEIR that allows the public and decision-makers an opportunity for meaningful review of the Project’s impacts.
The commenters reserve their right to supplement, amend and otherwise augment these comments at or prior to the hearing for this Project and any later hearings or proceedings pertaining to the Project.1 Commenters would be justified in submitting any later comments to supplement as they had requested an extension of time to accommodate the City and the Oxnard Harbor District’s slow responses to Public Records Act Requests seeking documents pertinent to many of the issues presented by the DEIR.
Commenters incorporate by reference all comments raising issues regarding the DEIR submitted prior to certification of the EIR for the Project.2 These comments follow previous comments that commenters CAUSE made on January 31, 2019 (MND Comment letter)3 in response to the Mitigated Negative Declaration, and by CAUSE, Natural Resources Defense Council, Wishtoyo 1 Cal. Gov. Code §65009(b); Cal. Pub. Rec. Code §2117)(a); Bakersfield Citizens for Local Control v. Bakersfield (2004) 124 Cal. App. 4th 1184, 1199-1203; Galante Vineyards v. Monterey Peninsula Water Management Dist. (1997) 60 Cal.App.4th 1109,1122. 2 Citizens for Clean Energy v. City of Woodland (2014) 225 Cal.App.4th 173,191 (finding that any party who has objected to a Project’s environmental documentation may assert any issue timely raised by other parties.) 3 Letter from Central Coast Alliance United for a Sustainable Economy to Oxnard Planning Department (January 31, 2019) (In response to Mitigated Negative Declaration) [hereinafter “January 2019 CAUSE Letter to Oxnard Planning Department”]
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Chumash Foundation, and others, on July 24, 2020 (NOP comment letter)4 in response to the Notice of Preparation related to this Project. The DEIR has failed to remedy many of the legal deficiencies noted in those letters, and for those reasons and others, it is inadequate under CEQA.
This letter supplements and expands upon certain of the arguments in those previous letters, but it is not intended to be exhaustive and incorporates by reference arguments made previously. 4 DEIR, Vol. II, Appendix B.
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TABLE OF CONTENTS
I. Experts and Addendums to Comments........................................................................... 7 II. The DEIR Is Inadequate as an Informational Document and Precludes Meaningful Public Review .................................................................................................................... 7 III. The DEIR’s Analyses of Impacts, Alternatives and Mitigation are Flawed and Based on an Improper and Incomplete Project Description.................................................... 8 IV. The DEIR Inadequately addresses the Cumulative Impacts that the Project Will Have on the Region ......................................................................................................... 16 V. The DEIR Fails to Properly Analyze Growth-inducing impacts................................. 20 VI. The Traffic Analysis Fails to Disclose and Mitigate Significant Traffic Impacts...... 24 VII. The DEIR Underestimates Health Risks from Toxic Air Contaminants and Increased Emissions and also Fails to Mitigate Health Impacts................................ 28
1. The DEIR Fails to Address how the Project will Shift Air Pollution Burdens of Port Operations onto Residents of South Oxnard Neighborhoods........................................ 29
2. The DEIR Fails to Properly Address the Project’s Impact on Regional Attainment of Air Quality Standards .................................................................................................... 30
3. The DEIR fails to offer a complete picture of Air Quality Impacts by not Incorporating Increased Port Activity .................................................................................................. 31 1013
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1. The DEIR should include a quantified construction and operational Health Risk Assessment..................................................................................................................... 34
2. The DEIR should Examine Cumulative Health Risks from Increased Air Quality Impacts........................................................................................................................... 35 VIII. The DEIR Underestimates the Impact to Biological Resources.................................. 39
1. DEIR fails to analyze the impact of permanent habitat loss.......................................... 40
2. DEIR relies on incomplete biological resources reports and incorrectly states that no special-status species rely on the site............................................................................. 40
3. There is evidence special-status species use the site...................................................... 41
4. DEIR fails to consider the impact from artificial lights, fence mortality, and car collisions........................................................................................................................ 43 IX. Cultural Impact Assessment: Fails to properly consider Tribal Cultural Resources in the area............................................................................................................................. 46 X. DEIR Presents Insufficient Analysis of Land Use Impacts from the Proposed Project ........................................................................................................................................... 46 XI. The DEIR’s Analyses of Other Relevant Impacts are Also Flawed and Should be Redone.............................................................................................................................. 53 1014
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XII. The DEIR violates CEQA Because it Fails to Address Environmental Justice Impacts, Which Renders it Inconsistent with State law and Oxnard’s 2030 General Plan................................................................................................................................... 59 XIII. Mitigation measures that are offered in the DEIR are inadequate............................. 63 XIV. Once Proper Assessment of the Project is completed, the DEIR must Consider Viable Mitigation Measures to Any Identified Significant Impacts........................... 67 XV. The DEIR fails to Consider a Range of Reasonable Alternatives Because the Project Objectives are Too Narrowly Defined........................................................................... 68
1. The Current Total Cost of Ownership of Battery-Electric Semi-Trucks is Less than Diesel Semi-Trucks........................................................................................................ 73
2. The Most Significant Technological Barriers to Widespread Usage of Battery-Electric Semi-Trucks Have Been Overcome with Immense Public and Private Investment...... 76
3. California’s Electric Utilities have Committed Hundreds of Millions of Dollars to Build Medium and Heavy-Duty Charging Infrastructure........................................................ 77
4. Class 7 and Class 8 Battery-Electric Semi-Truck Models are Available for Purchase, and Many Freight Facilities are Have Committed to Utilizing these Trucks................ 78
5. California Regulatory Agencies are Aggressively Pushing for Increased Utilization of Battery-Electric Semi-Trucks ........................................................................................ 79
6. There are Multiple Co-Benefits Associated with the Widespread Usage of Class 7 and 8 Zero-Emission Semi-Trucks as an Alternative .............................................................. 81 i. Requiring the Usage of Class 7 and 8 Battery-Electric Semi-Trucks will Reduce Local Air Pollution ..................................................................................................... 81 ii. Requiring Usage of Class 7 and 8 Battery-Electric Semi-Trucks will Aid California in Reaching its GHG and Air Pollution Reduction Goals .............................................. 81 iii. Electrification of Freight Fleets has Positive Economic Impacts for California ........ 82 XVI. Conclusion ........................................................................................................................ 83 1015
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I. Experts and Addendums to Comments
In addition to the comments outlined in this letter, we submit technical expert analysis and comment letters prepared by Matthew Hagemann and Dr. Paul Rosenfeld (Addendum A), Dr.
Shawn Smallwood (Addendum B), and Brenton Spies (Addendum C). We refer the City of Oxnard Planning Department to these expert comments throughout this letter for further discussion of the DEIR inadequacies. This letter incorporates by reference the arguments made in the attached technical expert comment letters and we ask that the City respond to each of the separate points made therein, even if not separately raised in the body of this comment letter.
II. The DEIR Is Inadequate as an Informational Document and Precludes Meaningful Public Review
The City recognized the need to provide DEIR-related documents in Spanish, but failed to translate any portion of the actual DEIR into Spanish other than a five-page executive summary.5 A large percentage of residents in the impacted areas include primary Spanish speakers.
According to the latest census data, in Oxnard as a whole, 66% of residents speak a language other than English at home, and 30% speak English less than “very well.”6 While Spanish speakers have access to the five-page Executive Summary for the DEIR, they do not have Spanish translation for any of the close to 1,000 pages of documents that provide the environmental review undertaken by the City and the details of the Project. If the City truly aims to provide meaningful opportunities for engagement and public review of the DEIR, it should translate the entire DEIR, technical reports, and attachments into Spanish. Once the translated documents are released, the City should provide a 60-day comment period for review and public comment.
The City also acknowledged that a significant percentage of Oxnard residents speak Mixteco and require oral translation of the relevant documents into their primary language. The City issued an 18-minute video interpreting the content of the Executive Summary into Mixteco with only 5 minutes of explanatory graphics. At the same time, however, the City rejected an extension request to comment on the DEIR and failed to respond to timely requests for a public hearing that would have allowed for outreach to the Mixteco community concerning the content of the DEIR as well as an opportunity for residents to engage with decisions makers in a public forum prior to closing the comment period. For these reasons, the City has not provided meaningful public review of the DEIR and should extend the public comment period to allow for a public hearing that will offer all residents an opportunity to fully engage in the commenting process. 5 Oxnard Harbor District- Spanish Language- Project Summary Port of Hueneme Installation of Temporary Outdoor Vehicle Storage Site EIR (January 2022); available at https://www.portofhueneme.org/wpcontent/uploads/2022/01/Spanish-Project-Summary-Puerto-de-Hueneme.pdf 6 U.S. Census Bureau (2021). Quick Facts- Oxnard, California. Retrieved from https://www.census.gov/quickfacts/oxnardcitycalifornia
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III. The DEIR’s Analyses of Impacts, Alternatives and Mitigation are Flawed and Based on an Improper and Incomplete Project Description
One of the key elements of CEQA is to foster greater transparency to ensure that decisionmakers and stakeholders are informed of potentially harmful environmental consequences of proposed projects. “Only through an accurate view of the project may outsiders and public decision-makers balance the proposal’s benefits against its environmental cost, consider mitigation measures, assess the advantage of terminating the proposal (i.e., the “no project” alternative) and weigh other alternatives in the balance.”7 Under CEQA, a “project” is defined as the whole of an action that has the potential to cause direct or indirect physical changes to the environment.8 CEQA mandates “that environmental considerations do not become submerged by chopping a large project into many little ones—each with a minimal potential impact on the environment—which cumulatively may have disastrous consequences.”9 A project description that omits integral components of the full project may result in an EIR that fails to disclose all the impacts of the project.10
“[A]n accurate, stable and finite project description is the sin qua non” of a legally sufficient EIR, and “the defined project and not some different project must be the EIR’s bona fide subject.”11 If a project is too narrowly defined, such as where a proposed development is divided into several segments, it will improperly limit the analysis to a portion of a project and run the danger “…that consideration of the cumulative impact on the environment of the two halves of the project may not occur.”12 CEQA prohibits the piecemealing of projects to avoid a more robust review of the potential direct or indirect physical changes to the environment caused by a project13. An EIR must include analysis of the environmental effects of future expansions or other actions when: a) a project is a reasonably foreseeable consequence of the initial project; and 2) the future expansion or action is significant in that it will likely change the scope or nature of the initial project or its environmental effects.14
The DEIR disingenuously omits plans to expand Port-Related Storage at a 250- acre site that will Serve as a Reasonably Foreseeable extension of the Project.
The DEIR lists project objectives for the Project to include the facilitation of “commercial success for Port clients to ensure they keep their business in the region.” as well as “[t]he consolidation of vehicle storage closer to the Port [to] enable more efficient movement of vehicles and reduce the need for heavy duty truck movement.”15 Yet the DEIR limits the description of the Project to approximately 34-acres which will be used to accommodate parking 7 County of Inyo v. City of Los Angeles (1977) 71 Cal.App.3d 185, 192 8 Cal. Code Regs., tit. 14, §15378(a) 9 Ozung v. Local Agency Formation Comm’n (1975) 13 Cal.3d 263, 283-84. 10 Santiago County Water Dist. V. County of Orange (1981) 118 Cal.App.3d 818, 829 (project description for sand and gravel mine omitted water pipelines serving project). 11 County of Inyo v. City of Los Angeles (1977) 71 Cal.App.3d 185, 199. 12 Citizens Assn. for Sensible Development of Bishop Area v. County of Inyo (1985) 172 Cal.App.3d 151, 166. 13 Berkeley Keep Jets Over the Bay Committee v. Board of Port Com’rs (2001) 91 Cal.App.4th 1344, 1358. 14 Laurel Heights Improvement Ass’n v. Regents of Univ. of Cal. (1988) 47 Cal.3d 367, 396. 15 DEIR Section 3.6 p. 3-15 1017
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for up to 4,944 vehicles.16 In fact, mention of the 250-acre site does not appear anywhere in the DEIR analysis even though it was specifically raised as an issue by commenters CAUSE, NRDC and Wishtoyo in response to both the Negative Mitigation Declaration and the Notice of Preparation. This omission of the 250-acre site from the DEIR is misleading and disingenuous and should raise serious misgivings about the reliability of the analysis and recommendations contained in the DEIR.
Yet the City and the applicant Oxnard Harbor District (“OHD”), which operates the Port of Hueneme, set their sights on a larger off-site port expansion well before this DEIR was drafted.17 The Port has previously sought federal funding to partially support the acquisition and permitting of 250 acres of land to build out a Multimodal Logistics Park with existing direct access to railroad shipping.18 OHD touted the 250-Acre Multimodal Logistics Park as part of their plan to transfer more cargo by train and truck to ocean-going vessels and “increase the capacity of the Port to accommodate exports and imports, while freeing up space for dockside operations.”19 In a fact sheet titled “Ensuring the Commercial Viability of major Ventura County Economic Engine- The Port of Hueneme (PoH)- for a better tomorrow at the City of Oxnard,” OHD cites to a “serious off port land deficit” of about 300 acres that is resulting in the Port and its clients operating above 100 percent operational land capacity- a situation it acknowledges is not sustainable.20 OHD cites as solutions the creation of an immediate “stop gap land measure” and a longer term accommodation near the port as critical to attracting additional business from customers such as GLOVIS.21 In the fact sheet used to apply for funding, OHD states:
The stop gap 34-acre measure discussed herein will ensure that the City of Oxnard and the POH will have sufficient time to structure and meet all regulatory requirements for the longer term 250-acre port logistics park with access to rail.22 The statement shows that it is reasonably foreseeable for the City to expect that the 250-acre development will become an extension of the 34-acre site, yet no mention of the 250-acre plan is referenced anywhere in the DEIR. Statements by OHD leadership bolster the notion that the Port has planned for some time to expand vehicle storage sites off-port and that the current Project is just a step in that direction. In an email dated July 2020, OHD executive staff reference budget allocations being made for continued efforts to secure additional off-port land expressing “how important addressing this a major commitment[sic]” is to OHD.23 The email states that the Port intends to build a larger storage lot that would leave the 34-acre site available for other uses.24 16 Id. 17 City of Oxnard & The Port of Hueneme Ensuring Commercial Viability Report [hereinafter, “Oxnard & POH Commercial Viability Report”], p.1. 18 INFRA FY19: Multimodal Optimization & Vehicle Efficiency Project Summary, p.1. 19 Id. at 2. 20 Oxnard & POH Commercial Viability Report, p.1. 21 Id. 22 Id. 23 Email from Dona Toteva Lacayo, Chief Commercial and Public Affairs Officer to Kristin Decas, OHD CEO (July 13, 2020)
24 Claudia Boyd-Barret, As California’s Ports Expand, Neighboring Communities Fight Back Against Pollution, California Health Report (March 18, 2019), available at: https://www.calhealthreport.org/2019/03/18/as-californiasports-expand-neighboring-communities-fight-back-against-pollution/ 1018
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These plans are consistent with OHD’s long-established ambitions regarding off-port vehicle storage as reflected in its FY2018 Financial Report, which states:
The Port is also working on two additional land developments within 1-2 miles of the entrance of its terminal. A 34-acre parcel on Port Hueneme Road to be used for temporary autos parking, and 250-acres on Port Hueneme Road to be used predominantly by automotive and fruit segments. Both properties represent the Port’s strategic plan to invest in more options for growing its footprint off-port in order to increase its throughput and velocity.25
These statements were echoed in meetings held between commenter, CAUSE, and the OHD leadership. Over the course of four meetings held between March 29th, 2018, and January 11, 2019, Port representatives shared their views regarding the importance of the 34-acre site.
According to executive staff, the site would serve as a 3-5 year bridge to hold access capacity of imported vehicles while the Port seeks permitting and rezoning for a 250-acre permanent expansion site in the area bounded by Hueneme Rd., Olds Rd., Edison Dr. and Sanford St.26 Port representatives shared that the short-term 34-acre site would be needed to accommodate growing shipment since the permitting process for the planned 250-acre site would take time as it would require annexation into the city and approval by the Ventura County Local Agency Formation Commission—a process that would likely take several years to complete.27 Other communications show that OHD has linked the 34-acre site to a much larger plan to expand to the 250-acre site sometime in the future. In a 2019 letter to the then U.S.
Transportation Secretary Elaine Chao, OHD refers to investments from the private sector to leverage $75,000,000 being solicited for the “acquisition, development, utilities, entitlements, and permitting for 250 acres of land located just 2.4 miles from the central gate of [the] port” to form part of the Multimodal Optimization and Vehicle Efficiency Project. 28 The “Port’s plan” to acquire and use the 250-acre property to expand the Port’s capacity to store cargo are referenced in emails between the OHD leadership and logistics representatives throughout 2020.29 In July 2020, OHD staff prepared a 250-Acre Site Development Checklist, which shows the Port’s checklist for everything from awarding contracts to development teams, drafting CEQA documents and putting them out for comment, report approval, and permit applications to the City of Oxnard, all the way to ribbon cutting.30 As of June 2021, standing weekly “Project 250” meetings- related to the 250-acre site development, had been put back on the calendar by OHD staff.31 The plan to acquire and develop the 250-acre site is not just a mere wish list item for the 25 Oxnard Harbor District, Comprehensive Annual Financial Report FY 2018 (July 2017 to June 2018), p. 7, [hereinafter “OHD FY18 Annual Financial Report”] available at https://www.portofhueneme.org/wpcontent/uploads/2019/01/FY-2018-CAFR-Oxnard-Harbor-District.pdf 26 Declaration of Lucas Zucker, February 26, 2019,[hereafter “Zucker Decl.”], ¶3. 27 Zucker Decl., ¶5. 28 Oxnard Harbor District, Letter to Secretary of U.S. Department of Transportation Elaine Chao Dated February 28, 2019.
29 Email from Dona Lacayo To Cameron Spencer, dated March 6, 2020; see also, Email from Cameron Spencer to Lucas Zucker, dated June 17, 2019, (referencing plans to “begin the master planning process for the Port’s future development and the potential of [the] 250 acre site will be included in that process”); 30 Oxnard Harbor District, Port of Hueneme 250 Acre Site Development Checklist and Status (7/13/20) 31 Email from Kristin Decas to Sandra Cruz, dated June 7, 2021 1019
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OHD, but part of a strategic plan underway to expand Port capacity as evidenced through funding solicitations and careful planning with Port property advisors.
The Future Expansion of the Project onto the 250-acre Site Will be Significant and Will Change the Nature of This Project and Its Environmental Effects The 250-acre storage site has more than seven times the capacity of the 34-acre site currently under review but will serve much the same purpose in storing vehicles awaiting shipment after arriving at the Port.32 As OHD has stated, the 34-acre site is merely one step to keeping GLOVIS as a customer by expanding capacity to accommodate 60,000 new cars.33 The 250-acre site, less than a mile east of the Project on W. Hueneme Road, will have a profoundly more significant impact on the environment and the local community as compared to the 34-acre site alone.
The 250-acre site would undoubtedly result in more vehicles being transported on Hueneme Road from the Port and through already impacted communities–therefore adding considerably more traffic impacts and emissions to the region.34 The 250-acre Multimodal Logistics Park will be a permanent operation, and will trigger even greater growth-inducing effects by expanding throughput capacity at the Port. Moreover, the project will include both refrigerated cargo capacity in addition to vehicle storage thus changing the makeup and quantity of emissions related to the site as compared to the original 34-acre site alone.35 32 Oxnard Harbor District, 2018. Comprehensive Annual Financial Report- Port Hueneme. Available at:
[https://www.portofhueneme.org/wp-content/uploads/2019/01/FY-2018-CAFR-Oxnard-Harbor-District.pdf] 33Letter from Kristin Decas to Greg Nyhoff dated January 20, 2017[hereinafter 2017 Letter from Kristin Decas to Greg Nyhoff], and Economic-Environment Partnership, Oxnard Harbor District, Presentation 34 In addition, OHD has invested in a new rail line with GLOVIS which is projected to grow GLOVIS’s annual income by 30% and increase total automobile throughput at the Port by 10%. See OHD FY18 Annual Financial Report, p.6. 35 Oxnard Harbor District INFRA Grant Narrative - Appendix C Benefit-Cost Analysis 1020
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Source: CAUSE, Port of Hueneme Expansion: How Would it Impact Us? (2019), p. 1 The DEIR should Include an Accurate Project Description that Encompasses Other Port Expansion Projects
Expanding the Port’s capacity to receive more automobile imports has been part of the OHD’s objectives for some time, and it has taken steps to put this in motion.36 In grant applications, OHD has described dredging and an on-site storage structure as the two primary components of its strategy to its double automobile capacity.37
The OHD has prioritized its plans to widen all five berths to facilitate expanding throughput because that will allow larger vessels to use the Port.38 The Port does not mince words in its 36 Oxnard Harbor District: 2030 Strategic Plan Port Infrastructure Workshop (April 8, 2021), Slide 25; Available at:
https://www.portofhueneme.org/wp-content/uploads/2021/04/10822-Infra-Workshop8Apr2021RFS.pdf (hereinafter 2030 Strategic Plan Port Infrastructure Workshop)
37 Oxnard Harbor District, “INFRA FY20: INVEST Project; Infrastructure Needed for Vehicle Exports to Support Trade Project” [hereinafter “INFRA FY20 Application Project Summary”] (OHD touts its proposed five-level structure to serve as a first or last point of rest for over 120,000 new automobile exports and imports each year, along with the DEEP Element- for deepening three berths at the port to accommodate auto carrier and fresh produce vessels).
38 Mike Harris, Army Corps of Engineers dredging Port of Hueneme channel, to replenish Hueneme Beach, Ventura County Star, January 8, 2021; available at https://www.vcstar.com/story/news/local/communities/porthueneme/2021/01/08/port-hueneme-army-corps-of-engineers-beach/4143430001/; see also Press Release, Los Angeles District, U.S. Army Corps of Engineers, Corps to begin dredging project at Port of Hueneme, January 5, 2021, available at: https://www.usace.army.mil/Media/News-Releases/News-Release-Article1021 Jay Dobrowalski
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capital improvement plan when describing how dredging will invite not only larger vessels with more cargo into the Port but also more vessels.39 The Port anticipates that it will also increase capacity to handle 229,000 tons more cargo annually40 and has stated that the deepening complements plans to land more cars at the Port.41
The City cannot afford to ignore the environmental impacts that the Port’s channel deepening and berth widening to receive larger ships will have on the region. Existing economic data and emerging research suggest that ports that expand their capacity to receive larger container ships may experience a variety of economic pressures to expand operations, many of which produce adverse environmental impacts. For example, a 2014 report by neighboring Port of Long Beach concludes: “[T]he trend toward larger vessels will have significant implications for ports that compete to service them as well as for the land side warehouse, trucking and rail operations that must accommodate an increase in volumes.”42 More recently, a 2021 study by Jungen et al. discussing the rise of ultra-large container vessels concluded, based on practical observations and empirical studies, that ultra-large container vessels experience “significantly longer port stay times” compared to smaller vessels, which in turn puts “enormous pressure on terminal operators to increase handling efficiency.”43 One way operators may handle such pressure is by increasing reliance on cargo handling equipment, and in particular, by increasing “crane intensity”: the number of cranes deployed per calling vessel.44 That research has already borne out in Florida, where Port Miami reportedly “raced” to replace its crane equipment to be ready to handle an influx in ultra-large “post-Panamax” vessels alongside a planned dredging project that would deepen its shipping canal.45 Thus, existing research shows it is reasonably foreseeable that callings by larger container ships could increase pressures on local Port-side infrastructure. In the case of the Port of Hueneme, the quest to accommodate larger capacity ships is already putting View/Article/2462330/corps-to-begin-dredging-project-at-port-of-hueneme/ (“Curtin Maritime Corp., the Corps’ contractor for the project, will be deepening the port’s federal navigation channels by dredging 385,000 total cubic yards of material. Deepening the harbor will accommodate Panama-sized vessels, which are currently unable to load to their maximum capacity.”); Press Release, Oxnard Harbor District, History in the Making! Port Celebrates Completion of Deepening Project, June 28, 2021, available at: https://www.portofhueneme.org/port-deepeningcompletion-06-28-2021/ (The Port was able to complete the widening of Berths 1 and 2 as of June 2021 and has received $5 million to dredge the Berth 3); Hrvacevic, Zlatan, $5M Funding Secured for Port of Hueneme Dredging Project, DredgingToday.com, October 25, 2021; available at https://www.dredgingtoday.com/2021/10/25/5mfunding-secured-for-port-of-hueneme-dredging-project/. 39 Oxnard Harbor District, Oxnard Harbor District Comprehensive Economic Development Strategy 2020, (Spring 2020), p. 32 available at: https://www.portofhueneme.org/wp-content/uploads/2020/04/OHD-2020-CEDS-FINAL04-08-2020.pdf [hereinafter “2020 OHD Comprehensive Economic Development Strategy”]. 40 Oxnard Harbor District, Port of Hueneme Deeping Project: New 40ft Channel at the Port of Hueneme to Benefit Local Economy and Support Beach Nourishment (2015), available at https://www.portofhueneme.org/wpcontent/uploads/2015/09/Dredging_Flyer_2015_Web.pdf 41 OHD FY18 Annual Financial Report at 7. 42 Dr. Noel Hacegaba, “Big Ships, Big Challenges: The Impact of Mega Container Vessels on U.S. Port Authorities” (June 30, 2014), https://www.supplychainbrain.com/ext/resources/ secure_download/KellysFiles/WhitePapersAndBenchMarkReports/PortofLongBeach/Hacegaba_PPM_PAPER_7_3 0_14.pdf. 43 Hendrik Jungen, et al., “The Rise of Ultra Large Container Vessels: Implications for Seaport Systems and Environmental Considerations,” Dynamics in Logistics 249-275 (2021) at pp. 258-59, https://link.springer.com/chapter/10.1007/978-3-030-88662-2_12. 44 Id. 45 “Port Miami Upgrades Cranes in Race for Giant Cargo Ships,” ColumbusCEO (Oct. 7, 2013), https://www.columbusceo.com/story/business/2013/10/07/portmiami-upgrades-cranes-in-race/22907038007/. 1022
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pressure on local communities as the Port seeks to increase its off-port storage capacity that will bring more shipping activities into their neighborhoods. The DEIR must analyze the environmental impacts of this encroachment.
Further, callings by ultra-large container ships also increase traffic flow to and through ports and nearby communities. The Jungen et al. study found a relationship between the number of containers handled per port call (also known as “call size”) and coastal road traffic, apparently by trucks transporting the cargo flowing to and from the ultra-large vessels increasingly calling on local ports.46 “Especially ports with a high modal share of road transportation show increased gate congestion in relation to arrivals of larger vessels.”47 In other words, as the number of containers per vessel goes up, so too does the local truck traffic. These data are further corroborated by a recent short paper issued by the California Air Resources Board on the emissions impacts of recent congestion at California ports, which noted the strong correlation between increases in cargo imports, traffic congestion at ports, and resulting regional air pollution.48
Locally, plans to increase volume at the Port will likely mean an increase in all modes of transporting goods through the region. The Port has also been investing in rail projects, for example, which will allow cargo to run through Port-owned rail lines that run adjacent to both the 34- and 250-acre sites. The Port has invested in a new rail line with GLOVIS, which is projected to grow GLOVIS’s annual income by 30% and increase total automobile throughput at the Port by 10%.49
With regard to the on-dock storage structure, the Port has sought funding for a proposed Structure for Transfer of Automobiles Creating Key Economic Development (“STACKED”)— an intermodal Planning project that is expected to expand capacity to accommodate 33% more automobiles at the Port.50 The project proposes to expand capacity to accommodate an additional 98% more automobiles on-site at the port, through the installation of a cargo transfer structure similar to a parking structure intended to be the on-dock first and last point of rest for both import and export of automobile cargo.51 An FY20 grant application by OHD shows that the STACKED project will be located on the North Terminal.52 46 Hendrik Jungen, et al. (2021), at pp. 258-60. 47 Id. at p. 261. 48 See Cal. Air Resources Board, “Emissions Impacts of Recent Congestion at California Ports” (Sept. 13, 2021), https://ww2.arb.ca.gov/sites/default/files/2021-
09/port_congestion_anchorage_locomotives_truck_emissions_final_%28002%29.pdf. 49 OHD FY18 Annual Financial Report at 6. 50 See 2020 OHD Comprehensive Economic Development Strategy, supra, p. 29; See also, INFRA FY20 Application Project Summary.
51 Ibid. 52 INFRA FY20 Application Project Summary
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Source: Oxnard Harbor District Fact Sheet INFRA FY20: INVEST Project While the 34-acre site is intended only to be temporary,53 the growth associated with this additional capacity is not. Since the Port intends the 34-acre site to facilitate increased capacity and throughput, once the 3-5-year term expires, another property will be needed to store cars.54 It is clear from executive staff communications, funding applications, and reports, that OHD has known for some time that the 34-acre site would only serve to facilitate a greater expansion of the Port’s vehicle storage capacity. Acquisition of the 34-acre site was always seen as just a provisional measure that would lead to even greater expansion of the Port’s capacity through the acquisition of larger plots of land to accommodate more cars.
The Port has had its sights on acquiring land outside its borders in order to expand port operations for over 40 years—yet the DEIR fails to make the connection between the off-port cargo storage yards and the overall expansion of Port operations. The 1978 Port Master Plan identifies the need to acquire more land to expand the Port’s capacity in the future.55 Indeed, the Plan identifies the 34-acre site as a “future port expansion.”56 This suggests that the Port has long aimed to acquire this property in order to expand its operations and increase cargo throughput.
There can be no surprise that the Port is pursuing utilization of the 34-acre and 250-acre sites to 53 OHD FY18 Annual Financial Report, at 7. 54 See id. at 6. 55 John J. McMullen Associates, Inc., A Master Development Plan for the Port of Hueneme, Vol. I: Executive Summary,[hereinafter, “POH Master Development Plan”] at pp. 5, 11, 12 56 Id. at p.11 1024
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increase its cargo throughput, but the DEIR fails to recognize this and analyze the impacts of expanded Port operations.
Each of these projects and investments are designed to increase Port capacity and highlight how the DEIR is flawed by having such a limited scope of inquiry. The DEIR, therefore, gives an incomplete picture of the full scope of direct and indirect impacts stemming from this Project when placed into context with the larger efforts to increase vehicle shipping capacity at the Port.
If this project is allowed to proceed with just an analysis of a temporary 34-acre site under consideration, it will violate CEQA and prevent proper vetting of the Project’s full environmental impacts.
IV. The DEIR Inadequately addresses the Cumulative Impacts that the Project Will Have on the Region
CEQA requires that the DEIR address cumulative impacts.57 Cumulative impacts are those that result from “the combination of the project evaluated in the EIR together with other projects causing related impacts.”58 The incremental effects of an individual project “are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.”59 Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time.60 A relatively “small” impact is not insignificant under CEQA if it contributes to an existing environmental problem.61 CEQA requires a cumulative impact analysis to contain, at minimum, either 1) a list of past, present, and reasonably anticipated future projects, including those projects outside the agency's control, which produce related or cumulative impacts62 or 2) a summary of such projections contained in an adopted general plan or related planning document which evaluates regional or areawide conditions.63 Failure to include a complete list of projects which produce related or cumulative impacts is a violation of CEQA.64
57 Cal.Code Regs.,tit.14, §15130; see also Cal.Code Regs.,tit.14, §15355 58 Cal.Code Regs.,tit.14, § 15130(a)(1). 59 Id. at § 15065(a)(3). 60 Id. at § 15355(b) (The cumulative impact from several projects is the change in the environment which results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time). 61 “[A] project’s cumulative environmental impact cannot be deemed insignificant solely because its individual contribution to an existing environmental problem is relatively small.” See, San Francisco Baykeeper, Inc. v. State Lands Comm’n (2015) 242 Cal.App.4th 202, 223. “In fact, ‘the greater the existing environmental problems are, the lower the threshold should be for treating a project's contribution to cumulative impacts as significant.’” Id. (quoting Cmtys for a Better Env’t v. Cal. Res. Agency (2002) 103 Cal.App.4th 98, 120). 62 CEQA suggests that agencies consider factors such as the nature of the environmental resource examined, location of project, and type. Cal.Code Regs.,tit.14, § 15130(b)(2). 63 Id. at § 15130(b)(1). 64 San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus (1994) 27 Cal.App.4th 713, 740, as modified (Sept. 12, 1994); See also, San Franciscans for Reasonable Growth v. City and County of San Francisco (1984) 151 Cal.App.3d 61, 80 (agency improperly failed to consider cumulative impacts of reasonably foreseeable development in addition to the four high-rise developments in the proposed project, and “[t]he inadequate cumulative analysis prevented the Commission from gaining a true perspective on the consequences of approving these projects”) 1025
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DEIR fails to analyze the cumulative impacts of the projects it lists as reasonably foreseeable, planned, and approved future projects
In Table 4-1, the City lists projects it considers to be “reasonably foreseeable, planned and approved future projects.”65 Notably, the DEIR lists these projects, but does not provide any analysis on the type of cumulative impact these projects would contribute to the region. One project, for example, is already being utilized as a warehouse shipping facility with outdoor vehicle storage and offices and is situated directly across Hueneme Road from the proposed Project site. 66 This proposed Project would likely contribute to congestion already attributed to logistics activities on the same thoroughfare, yet the DEIR fails to properly analyze these potential impacts. There are numerous other cumulative impacts from the listed projects the DEIR should have studied, which are discussed in more detail throughout this letter.
The DEIR fails to consider the full range of projects required of a cumulative impact analysis
Glaringly missing from the list is the 250-acre site planned for land further east on Hueneme Road.67 Through unlawful piecemealing, the DEIR attempts to avoid consideration of the cumulative impacts of both phases of the 34-acre and 250-acre expansion sites. By requiring that agencies evaluate the cumulative impacts of other similar projects, CEQA attempts to guard against the dangers of piecemealing, as attempted here, which would avoid a full analysis of the actual effects of a project.68 As discussed above, the OHD has described publicly, its intent to invest in a project that will grow its capacity. Therefore, the City must consider reasonably foreseeable projects such as widening the Port’s berths and on-dock expansions that are in the planning stages and have been sufficiently described by the OHD.
A project should be considered in a lead agency’s cumulative impact analysis if the physical elements of a project are sufficiently quantified so as to make an analysis of their future impacts more accurate.69 Here, the 250-acre project is cited in plans calling for greater capacity at the Ports by expanding storage areas. Memos and other documents from OHD make a clear connection between the “stop gap” 34-acre site and the 250-acre site.70 OHD’s own documents also show a projected timeline that includes submitting the project for environmental review.71 65 DEIR, Table 4-1, p. 4-2 66 Id. 67 Oxnard & POH Commercial Viability Report 68 Citizens Assn. for Sensible Development of Bishop Area v. County of Inyo (1985) 172 Cal.App.3d 151, 166; Las Virgenes Homeowners Federation, Inc. v. County of Los Angeles (1986) 177 Cal.App.3d 300, 306, citing Bozung v.
Local Agency Formation Com. (1975) 13 Cal.3d 263, 283–284. (“The purpose of this requirement is obvious:
consideration of the effects of a project or projects as if no others existed would encourage the piecemeal approval of several projects that, taken together, could overwhelm the natural environment and disastrously overburden the man-made infrastructure and vital community services. This would effectively defeat CEQA's mandate to review the actual effect of the projects upon the environment.”)
69 San Franciscans for Reasonable Growth v. City & County of San Francisco (1984) 151 Cal.App.3d 61, 76. 70 2017 Letter from Kristin Decas to Greg Nyhoff, Oxnard & POH Commercial Viability Report,, and EconomicEnvironment Partnership, Oxnard Harbor District, Presentation 71 Oxnard Harbor District, Port of Hueneme 250 Acre Site Development Checklist and Status (7/13/20) 1026
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The City also solicited federal dollars for the project and spent time and resources to secure funding for the project through federal grants.72
It is impossible to ignore the ties between the two parcels. • Both the 34-acre and 250-acre lots will have related and compounding impacts. • Both parcels of land are less than two miles from the port and slated to serve as storage for vehicles imported through the Port.
• Both parcels would access Hueneme Rd with a direct line to the Port, and both are immediately adjacent to rail.73
OHD has already invested considerable time and resources into preparing for the development of a Multimodal Logistics Park at the 250-acre site to make it a probably future site that should be included in the cumulative impact analysis.74 The cumulative impacts of both project phases must be considered in the DEIR’s analysis.
The DEIR also failed to analyze a host of other probable future projects, as well as existing projects that may have cumulative impacts similar to the types of impacts associated with the 34- acre project. These include, but are not limited to:
• INVEST Project. The OHD is prioritizing infrastructure to expand vehicle imports and exports. The project incorporates two interdependent investments- a five-story tall automobile storage facility for exports and the expansion of three berths at the Port to accommodate “larger and deeper vessels.”75 OHD makes references that INVEST will “influence and strengthen the efficiency of the Port Intermodal Corridor.”76 OHD touts the dredging projects as offering “increased flexibility to accept more vehicles in the growing international markets of automakers.”77 OHD identified capital investments to modernize Berth 3, 4, and 5 to allow logistics partner to accommodate existing customer’s larger-capacity vessels by berth and channel deepening to complement the intermodal improvement project.78 Moreover, the car storage component of the project is lauded as having the capacity to expand Port capacity to accommodate an additional 33% more automobiles on Port.79 The cumulative impact of the increased throughput from the INVEST project coupled with the 34-acre project and the 250-acre Multimodal Logistics Park must be analyzed in the DEIR.
• Rail expansions. Both the 34-acre and the planned 250-acre Multimodal Logistics Park are within close proximity to a Port-owned rail line.80 As far back as 2017, OHD was reportedly encouraging increased use of rail to help reduce dwell time and congestion as 72 OHD Letter to Secretary of U.S. Department of Transportation Elaine Chao Dated February 28, 2019 73 INFRA FY19 Multimodal Optimization & Vehicle Efficiency Project (map showing location of both sites in proximity to rail and Hueneme Road).
74 INFRA FY19: Multimodal Optimization & Vehicle Efficiency Project Summary (INFRA FY19 Project Summary by OHD protecting estimated costs for the Multimodal Logistics Park at the 250-acre site and seeking INFRA grant funding to compliment a 44% private funding match.) 75 INFRA FY20 Application Project Summary; 2020 OHD Comprehensive Economic Development Strategy 76 Id. 77 Id. 78 2020 OHD Comprehensive Economic Development Strategy 79 Oxnard Harbor District, Tiger IX Stacked Intermodal Project Overview- Project Summary. 80 INFRA FY19 Multimodal Optimization & Vehicle Efficiency Project 1027
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more than 300,000 units of imported vehicles and 38,000 units of exports are processed.81The Port recognized the need to expand Port capacity to accommodate more vehicle shipments.82 Increased use of rail from the Port is often touted for removing truck trips on roads. The increased volume, however, especially at existing rail crossings that impact proposed car routes to both the 34-acre site and the proposed Multimodal Logistics Park, are likely to impact traffic due to a lack of grade separations. The DEIR should consider this increased use of rail from the port as part of the cumulative impact analysis.
• BUILD Project. The BUILD project would call for port modernization which will increase storage areas and reefer plugs to handle an additional 7,200 forty-foot equivalent units of locally produced agriculture. The project is expected to begin construction in 2022 and be completed in 2023- resulting in expanded terminal space.83This increased capacity for agricultural exports at the Port will likely increase trucking of exports along the same roads proposed for the Project and the Multimodal Logistics Park. The DEIR’s cumulative impact analysis should include an analysis of the likely cumulative effect of this project on the local environment.
• Port Intermodal Corridor. In 2021, OHD applied for additional federal funding for Hueneme Modernization Project and recognized a “long-range vision for the Region’s Port Intermodal Corridor, a designated Freight Intermodal Corridor connecting the Port’s main entrance with Interstate Highway 101 via the Hueneme Road and Rice Road Corridors.”84This Project, along with the Multimodal Logistics Park, would increase traffic along Hueneme Road and connected throughfares. This plan is reiterated in the Ventura County Freight Study, which identifies Hueneme Road as the “primary last-mile access to the Port of Hueneme from Rice Avenue,” and highlights the corridor as a key transportation project of the Port of Hueneme Strategic Plan. The study identifies Hueneme Road as one that is slated for widening to four lanes, with special consideration being given to Oxnard’s Ormond Beach Restoration and Public Access Plan.85 There should be no doubt that planned road widening and the creation of a “Hueneme Road Corridor”86 will undoubtedly impact the surrounding area with increased volumes of freight traffic. The DEIR should, at a minimum, have included analysis of these cumulative impacts to traffic, air pollution, land use, and other elements impacting the vicinity of the Project site.
81 Oxnard Harbor District, Board of Commissioners Meeting Agenda- September 11, 2017-Press Report Attachment 82 Id. 83 Oxnard Harbor District, The Hueneme Modernization Project BCA Appendix - March 17 2021, [hereinafter “The Hueneme Modernization Project Appendix], p.3. 84 Oxnard Harbor District, The Hueneme Modernization Project INFRA Grant Application FY2021 85 Ventura County Freight Corridor Study, (October 2021), Prepared by Iteris, Inc., on behalf of Southern California Council of Governments, The Port of Hueneme, Caltrans and Ventura County Transportation Commission [hereinafter “Ventura County Freight Corridor Study”], p.36. 86 Id. at 35. 1028
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Source: OHD Hueneme Modernization Project INFRA GRANT 2021 Narrative87 Once the agency has a set of projected projects, CEQA requires that it also include a summary of the environmental effects expected to be produced by those projects and an analysis of whether those impacts are cumulatively considerable.88 Here, the City failed to even mention any of these projects in the DEIR. Many of the anticipated projects will increase air pollution from ship visits and truck and rail traffic, increase VMT, impact biological resources, further environmental injustice, and impede access to the coast.89 These impacts should be analyzed in the DEIR considering air quality and coastal access problems they could present to the region when fully operational alongside the construction, vehicle traffic, and other environmental impacts anticipated from the Project.
V. The DEIR Fails to Properly Analyze Growth-inducing impacts The DEIR must also describe growth-inducing impacts of the proposed project,90 including ways in which the project could directly or indirectly foster economic growth that could lead to an adverse physical change to the environment.91 The DEIR must discuss the growth-inducing 87 The Hueneme Modernization Project INFRA Grant Application FY2021 88 See Cal.Code Regs.,tit.14, § 15065(a)(3). 89 See e.g., San Franciscans for Reasonable Growth v. City and County of San Francisco (1984) 151 Cal.App.3d 61, 80 (agency improperly failed to consider cumulative impacts of reasonably foreseeable development in addition to the four high-rise developments in the proposed project, and “[t]he inadequate cumulative analysis prevented the Commission from gaining a true perspective on the consequences of approving these projects”). 90 Pub. Res. Code 21100(b)(5); Cal.Code Regs.,tit.14, § 15126(d). 91 Cal.Code Regs.,tit.14, §§ 15126.2(d), 15064(e); see also, Napa Citizens for Honest Gov’t v. Napa County Bd. Of Supervisors (2001) 91 Cal.App.4th 342, 368; Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184, 1205 (If the forecasted economic or social effects of a proposed project directly or indirectly will lead to adverse physical changes in the environment, then CEQA requires disclosure and analysis of these resulting physical impacts.); see also Cal.Code Regs.,tit.14, § 15131(a). 1029
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effects of the Project, even if the effects will manifest only indirectly from the Project.92 CEQA requires the inclusion of growth-induced impacts in an EIR when there has been evidence that economic activity resulting from a proposed project will lead to physical changes in the environment.93
The DEIR must analyze the growth-inducing effects associated with the Project’s potential to increase in port capacity and therefore spur future economic growth. In analyzing growthimpacts, “[i]t must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment.”94 The DEIR, “must discuss growth-inducing impacts even though those impacts are not themselves a part of the project under consideration, and even though the extent of the growth is difficult to calculate.”95 The DEIR erroneously concludes that the Project would not be growth-inducing, “in as much as it would not foster significant unanticipated economic expansion and growth opportunities.”96 The City’s analysis of growth-inducing impacts, however, is flawed because it involves only a piecemeal review of the overall Port expansion project. This allows for critical environmental considerations, such as growth-inducing impacts, to “become submerged by chopping a large project into many little ones”97 therefore obscuring proper analysis under CEQA.
It is impossible to ignore the Project’s connections to OHD’s larger port-expanding endeavors.
OHD has described both the Project and the proposed 250-acre Multimodal Logistics Park as strategic properties that will allow for increased automotive imports, stating that “[b]oth properties represent the Port’s strategic plan to invest in more options for growing its footprint off-port in order to increase its throughput and velocity.”98 OHD has also specifically identified that the 34-acre lot will “allow for increases in capacity and throughput for the ro-ro segment”99 and will “serve as a relief valve for auto cargo.”100 Repeatedly, OHD has acknowledged that the 92 Napa Citizens for Honest Gov’t v. Napa County Bd. Of Supervisors, 91 Cath 342, 368 (2001). 93 See Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184, 1207 (evidence suggesting that the economic and social effects caused by proposed shopping centers ultimately could result in urban decay or deterioration obligated the lead agency to assess this indirect impact); El Dorado Union High School Dist. v. City of Placerville (1983) 144 Cal.App.3d 123, 131 (potential of increased student enrollment in an already overcrowded school resulting from construction of the proposed apartment complex was an environmental effect that required treatment in an EIR because it could lead to the necessity of constructing at least one new high school); Citizens Ass’n. for Sensible Development of Bishop Area v. County of Inyo (1985) 172 Cal.App.3d 151, 171 (lead agency required to analyze whether physical deterioration of the downtown area would be an indirect environmental effect of the proposed shopping center); Citizens for Quality Growth v. City of Mt. Shasta (1988) 198 Cal.App.3d 433, 446 (must analyze proposed project’s possible result in business closures and physical deterioration of the downtown as an indirect environmental effect of the project). 94 See Cal.Code Regs.,tit.14, § 15126.2 (d) 95 Napa Citizens, supra, 91 Cal. App.4th at 368 96 DEIR, Section 7.1, p. 7-4. 97 City of Antioch v. City Council (1986) 187 Cal.App.3d. 1325, 1333. 98 OHD FY18 Annual Financial Report at 7. 99 Id. at 6. 100 See Oxnard Harbor District, Green Port Development Project 34 FAQs, https://www.portofhueneme.org/wpcontent/uploads/2019/02/34Acre_FAQs_01-2019.pdf. [hereinafter “OHD 34-acre Site FAQs”] at 1; see also Oxnard Harbor District, Green Project 34 Vehicle Storage Facility, fact sheet, available at https://www.portofhueneme.org/wp-content/uploads/2019/03/34Acre_PropStorage_03-2019.pdf. [hereinafter “OHD 34-acre Site Fact Sheet”]at 1.
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34-acre lot on its own, and both the 34-acre lot and 250-acre lot together, are intended to grow the Port’s capacity and throughput for automobiles.
Moreover, while OHD has stated that the 34-acre lot “will consolidate cars from other parts of the County,” which suggests it may replace or at least supplant the Port’s existing car storage facility in Ventura,101 OHD’s statements about growth and the fact that OHD has not committed to closing down the existing off-port vehicle storage sites undermine the assumption in the DEIR that the 34-acre site will only receive the cars that would otherwise go to Ventura or other sites.
Freeing up capacity at the Ventura site could allow the Port to import even more cars, or other goods that it did not have room to store before. Without assurances that existing sites will cease operations permanently, emissions resulting from trips to and from the Ventura and Oxnard sites must be accounted for, including the prospect that the sites shift to storing other cargo.102 The 34- and 250-acre lots have also long been associated with further expansion of the Port’s capacity to receive larger volumes of cargo, including the deepening of the harbor channels, which has been described as an opportunity to allow the Port to receive larger and more vessels and increase throughput.103 The combination of these projects would build out the long-term capacity of the Port to increase its car imports. In fact, OHD has already poured about $20 million from federal and other sources into infrastructure modernization during the past six years to increase its capacity.104 An increase in shipping capacity at the Port, in turn, would spur further economic activity, increasing the demand for workers in the area.
While the DEIR downplays the significance of the Project and does not address growth-related impacts, there is no denying the Project will enhance the Port’s ability to expand. The Port, one of the region’s most important economic engines, serves as a catalyst for job creation and consumer spending. According to The Local and Regional Economic Impacts of the Port of Hueneme Report, the Port generates more than 2,900 “induced” jobs, including those created by retail, wholesale, social, and educational services paid for by direct employees at the Port.105 According to the report, activity at the Port already generates $177.2 million in direct wages to direct employees, which in turn results in local purchases and an additional $405.9 million of income and local consumption expenditures supporting an additional 2,930 “induced” jobs.106 In addition, roughly 1,500 indirect jobs are created in the local economy by firms “directly dependent” on port activity.107 These “indirect” workers receive approximately $86.6 million in wages due to Port operations.108
101 See OHD 34-acre Site FAQs at 1; see also OHD 34-acre Site Fact Sheet at 1. 102 City of Long Beach v. City of Los Angeles (2018) 19 Cal. App. 5th 465, 487 103 OHD FY18 Annual Financial Report at 6. 104 In the shadow of LA congestion, Port Hueneme becomes cargo magnet, Hellenic Shipping News, 12/21/2021; available at https://www.hellenicshippingnews.com/in-the-shadow-of-la-congestion-port-hueneme-becomes-cargomagnet/. 105 Martin Associates, The Local and Regional Economic Impacts of the Port of Hueneme, (May 15, 2019), pp. 17- 19 106 Id. at 10. 107 Id. at 9. 108 Id. pp. 18, 23.
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Expansion of the Port will undoubtedly have a ripple effect across the region. The DEIR, therefore, cannot ignore these growth-impacts associated with the Project. One of the Project’s objectives is to facilitate the commercial success of GLOVIS to ensure they keep their business in the region.109 This is a clear example of a project serving as growth-accommodating infrastructure as illustrated by OHD’s own comments that the 34-acre site serves primarily as a “stop gap” measure for the eventual development of the Multimodal Logistics Park, allowing 60,000 additional units to be stored.110 The DEIR must analyze how the Project, when viewed as part of the planned development of the Multimodal Logistics Park, will foster greater Port throughput leading to even greater economic activity. This increased economic activity has the potential to bring population growth, increased traffic in the area, increased need for additional housing, increased air pollution, and otherwise cause physical changes to the environment. The DEIR must address these growth-inducing impacts as part of the analysis for this Project.
Finally, the DEIR analysis focuses almost entirely on the potential direct impacts of the 34-acre site without examining the effects of the project as a whole.111 For example, the City bases much of its conclusion that the project will not trigger population growth on the premise that the Project “does not include residential development, which would have a direct effect on population growth.”112 The City cannot avoid conducting a more thorough growth-inducing impact analysis under CEQA simply because a project does not itself call for the construction of housing113, CEQA requires114 that the DEIR discuss “the ways in which” the Project could “directly or indirectly” foster economic or population growth. 115
Here, the Project itself should be analyzed as serving new infrastructure that will be used to foster growth of OHD’s larger off-port vehicle storage expansion plans.116 The Project has repeatedly been described by OHD as a “stop gap” measure for the 250-acre port logistics park with access to rail117 In fact, OHD states in documents to the City that GLOVIS is operating overcapacity at its facilities and needs to process an additional 60,000 units on the West Coast and that “[i]f the District can secure adequate off port land for temporary storage, it will be able to capture this business for the District118 nd address supply chain issues at other Ports by taking on larger and more diverse cargo volumes. 119 The DEIR should therefore analyze Project’s growth-inducing impact serving as infrastructure for larger Port expansion plans. 109 DEIR, p. 1-1. 110 2017 Letter from Kristin Decas to Greg Nyhoff at 3.; also Economic-Environment Partnership, Oxnard Harbor District, Presentation, Slide 12
111 See Napa Citizens, supra, 91 Cal.App.4th at 369 112 DEIR, p. 7-3 113 See Napa Citizens, supra, 91 Cal.App.4th at 369 114 Id. 115 Cal. Code. Regs., tit. 14, §15126.2(e) 116 OHD FY18 Annual Financial Report at 7. 117Oxnard & POH Commercial Viability Report 1182017 Letter from Kristin Decas to Greg Nyhoff at 3. 119 In the shadow of LA congestion, Port Hueneme becomes cargo magnet, Hellenic Shipping News, 12/21/2021; available at https://www.hellenicshippingnews.com/in-the-shadow-of-la-congestion-port-hueneme-becomes-cargomagnet/ 1032
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VI. The Traffic Analysis Fails to Disclose and Mitigate Significant Traffic Impacts A proper traffic analysis is critical to understanding the impacts of any project. Here, the DEIR’s traffic analysis is faulty and fails to properly analyze traffic impact using updated CEQA guidelines on Vehicle Miles Traveled (VMT) and offers only a very narrow picture of this impact due to piecemealing of the project.
Thresholds Used do not Adequately Address CEQA Guidelines Concerning Vehicle Miles Traveled
California Public Resources Code §21099 and 14 Cal. Code Regs § 15064.3 (CEQA Guidelines), govern how agencies must determine the significance of transportation impacts for a project.
These rules generally provide that transportation impacts are to be based on the VMT generated by traffic that the project will draw or otherwise cause. According to Guideline 15064.3, VMT is “the most appropriate measure of transportation impacts,” and an increase in VMT should be treated as a significant impact.120
The DEIR does not carry out the VMT analysis with the level of vigor that would result in data reliable enough to inform proper decision-making according to Guideline 15064.3. OHD admits that “at this time, neither the City of Oxnard nor City of Port Hueneme have adopted a methodology for determining Vehicle Miles Traveled by development projects.”121 Indeed, no quantitative analysis of VMT was provided for this Project. Instead, OHD extrapolates possible VMT reductions based on the assumption that the two existing off-port sites will be consolidated onto the 34-acre project site.122 The DEIR analysis only accounts for one-way trips.123 Furthermore, the DEIR concludes that because the two current sites, Camarillo Airport and Tuff Shed, are farther from the Port than the Project site, vehicle miles traveled will be reduced.
We do not assume that the DEIR’s description of VMT is correct. But even this simplistic view of VMT ignores a critical fact —that currently, car-carrying trucks are capable of transporting multiple vehicles to and from these existing locations as opposed to driving the estimated maximum 240 vehicles individually each day to the Project site.124 The average U.S. car transport trailer can hold up to 9 cars at a time on average.125 Assuming each car carrier holds 9 cars and the same number of cars are delivered to a site daily as is currently proposed for the Project, the car carrier trucks would make around 26 trips each day.126 Accounting for the 26 trips by truck for 10.6 miles to the farthest current site located at Camarillo Airport, that adds up to 275.6 vehicle miles traveled if you count miles per vehicle driven. Assuming the 240 daily trips are made with each individual car for 1.65 miles to the proposed site, that amounts to 396 vehicle miles traveled. Even if VMT for the car carrier truck was weighted, the estimation used in the DEIR does not add up.
120 Cal. Code Regs., tit. 14, §150643(b)(1). 121 DEIR, p. 5.19-18. 122 DEIR, pp., 5.19-18, 5.19-19 123 DEIR, Section 3.0, p. 3-21. 124 DEIR, Section 5.19.5, p. 5.19-9. 125 https://www.quora.com/How-many-cars-can-the-largest-car-carrying-ship-hold 126 240 maximum daily trips divided by 9. 1033
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We, of course, are not advocating the use of diesel trucks as a preferred alternative. In fact, the City should more thoroughly consider zero-emissions trucks as a reasonable and viable alternative and mitigation measure for this Project (see section on alternatives below). However, because the DEIR fails to properly assess VMT for the Project, its conclusion that the VMT impact is not substantial cannot be relied upon.
Finally, the City uses a baseline for traffic impacts that assumes the elimination of two current off-port vehicle storage sites and status quo when it comes to the level of vehicle imports coming through the ports. The DEIR’s analysis, therefore, is premised on an examination of the project’s impacts on environmental conditions projected to exist in the future. To use such an analysis, OHD must first justify the decision by showing that the existing conditions are somehow misleading or without informational value.127 No such justification is offered. Instead, the analysis assumes the two existing sites will be consolidated without any evidence to suggest that such a plan is guaranteed to take place. Nowhere in the DEIR, for example, is there a concrete timeline for when the two current storage sites would be decommissioned. This analysis is misleading as it obscures the impact that the Project is likely to have either during an interim period, while the two existing sites are decommissioned, or under a scenario where GLOVIS or some other OHD customer decides to continue using the two sites as vehicle storage facilities.
The DEIR should account for the possibility that the Project will contribute to the traffic already flowing from the Port to these storage sites.
The increasing traffic is especially important given the Project’s proximity to Ormond Beach and the Ormond Beach Wetlands. As discussed further in these comments, the Ormond Beach Restoration and Public Access Plan (OBRAP) designates several entryways to the natural scenic area, including a bike path on Perkins Road leading to the wetlands and the beach, as well as an entry point near Saviers Rd. and Hueneme Rd. closest to the northeast corner of the proposed Project site.128 One of the main goals of OBRAP is to “[e]nhance opportunities for people to easily and safely visit Ormond Beach and enjoy the nature, educational opportunities, and recreation that are compatible with the restored Ormond Beach ecosystem.”129 The DEIR fails to reconcile with the fact that increased traffic volume on Hueneme and Perkins Roads will undoubtedly impact the OBRAP and has the potential for causing significant safety concerns to pedestrian and non-vehicle traffic from residents and members of the public attempting to access this natural recreational area.
The DEIR Underestimates the Traffic Impacts Associated with the Project The DEIR should evaluate the traffic impact based on the number of vehicles anticipated to arrive at the lot in the 3-5 years it may be operational. The updated traffic study used to support the DEIR findings estimated that there would be a maximum of 240 new vehicles transported to or from the Port to the Project site daily— with vehicles shuttled to or from the site 127 Neighbors for Smart Rail v. Exposition Metro Line Constr. Auth., (2013)57 Cal.4th 439, 304 P.3d 499 128 Ormond Beach Restoration and Public Access Project: Preferred Alternative and Preliminary Design Plan, (May 2021), figure ES-3. 129 Id. at ES-1.
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approximately 18 days each month.
130 This does not account for other vehicle traffic to the site or construction-related traffic. Total daily peak trips generated by shuttling employees to the site, in addition to new cars, amount to approximately 316 daily.131 Approximately 30 one-way vehicle trips can occur in one hour.132 The Port reported in FY 2019 that it received 326,585 automobile imports (up 13% from FY2018).133 Even assuming the Port will shuttle vehicles 365 days per year, that comes to approximately 895 vehicles per day. Adding an additional 60,000 new cars, which this Project is reported to help attain, would result in a nearly 20% increase in automobile processing.
The traffic study, however, assumed vehicles would only be shuttled 18 days per month.134 As cited in the FY2019 report, OHD would need to shuttle approximately 1,512 vehicles per day to keep up with the growing number of automobile imports. That traffic rate would certainly impact not only VMT analysis but also the overall picture for how traffic volume will increase on the streets leading to the site and raising safety concerns as stated above.
The numbers used to conclude that traffic would have no significant impact do not represent a realistic estimate of the number of vehicles the Project will ultimately contribute on the road.
The DEIR must rely on accurate data to determine the number of vehicles anticipated to enter and exit the 34-acre lot and the overall impact it will have on emissions, VMT, traffic congestion, and safety.
Analysis of Cumulative Traffic Conditions from Existing and Approved/Pending Project Conditions is Flawed
The DEIR relies on incomplete data and flawed analysis to conclude that the Project would not generate significant cumulative impacts to the surrounding communities based on the City of Oxnard’s traffic impact thresholds.135 As mentioned above, the analysis failed to properly consider VMT as required by CEQA Guideline 15064.3 and instead focuses exclusively on Level of Service and a study of traffic flow at intersections. Even with the analysis of LOS, however, the conclusion that the project will not have significant cumulative impacts fails to account for existing traffic flow from the Port of Hueneme and the potential future traffic triggered by the proposed 250-acre site planned farther east from the proposed Project site on Hueneme Road.
As noted throughout these comments, the Port is currently undertaking plans to expand, including channel deepening, berth widening, and increasing on-site and off-port storage.136 This port-side expansion is coupled with plans to enhance a freight corridor by widening Hueneme 130 DEIR, Appendix J, Associated Traffic Engineers- Port of Hueneme Outdoor Vehicle Storage Facility, Oxnard, California Traffic Study [hereinafter “Traffic Study”], Pp. 8-9 (May 4, 2021). 131 Traffic Study, P. 9. 132 Ibid. 133 OHD 2019 Year End Review at 5. 134 DEIR, Appendix J, P. 8. 135 DEIR, section 5.19.6, pp. 5.19-19 through 5.19-21. 136 See 2020 OHD Comprehensive Economic Development Strategy ; See also, INFRA FY20 Application Project Summary.
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Road.137 At a minimum, the DEIR should account for traffic currently being generated from existing Port throughput as well as projected growth at the Port in determining the cumulative traffic impact of the Project. We reassert that this Project cannot be studied in a vacuum and must be viewed considering its role in facilitating the planned 250-acre Multimodal Logistics Park.
The Associated Transportation Engineers Traffic Study (Traffic Study) that the DEIR relies on for its analysis of cumulative traffic conditions, completely ignores the recently published Ventura County Freight Corridors Study (Freight Study) published in October 2021.138 Had it included the findings of the Freight Study, the DEIR analysis on cumulative traffic conditions would have included the daily truck trips generated at the Port of Hueneme and other existing sites served by the same roads as the Project. Already, land use in the City of Oxnard generates 23 percent of Ventura County’s total truck trips.139 Based on the Freight Study, approximately 56,600 daily one-way truck trips begin and end from sites within Ventura County.140 These trips occur on many of the same roads that will be impacted by this Project, including Hueneme Road.
The 2021 Port Hueneme Road daily gate count shows that 350 truck trips are generated from the Port of Hueneme’s main gate.141 This number represents an average day with a ship in port and only accounts for trucks specific to the commercial port operations and not those truck trips generated by moving or trans-loading cargo from secondary distributions sites or warehouses142 like the proposed Project. The cumulative impact of this truck traffic should be accounted for in examining the Project’s contribution to the number of vehicles that will drive on local roads during peak hours.
Similarly, the DEIR leaves out of its impact analysis the 250-acre site being planned to expand off-Port capacity for vehicle storage even further.143 The 250-acre Multimodal Logistics Park is slated for a location east of the Project site on Hueneme Road144 and would likely add to traffic generated by the Project. Both properties represent the Port’s strategic plan to invest more options to grow its footprint off-port. Because the Project and the Multimodal Logistics Park will be located along what has been dubbed the Hueneme Road Freight Corridor145, the DEIR is wrong to ignore the connections and the cumulative impact this will bring to the region’s traffic. 137 Ventura County Freight Corridor Study at 36. 138 Id. 139 Id., Table 2 at p. 61. 140 Id., Section 1.2.1 Truck Trip Generation, p. 60 141 Ibid. 142 Ibid. 143 OHD FY18 Annual Financial Report at 7. 144 See CAUSE, Port of Hueneme Expansion: How Would it Impact Us? (2019), p. 2 [hereinafter “CAUSE Fact Sheet”].
145 Ventura County Freight Corridor Study, at 36
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VII. The DEIR Underestimates Health Risks from Toxic Air Contaminants and Increased Emissions and also Fails to Mitigate Health Impacts Air Quality Impacts
The DEIR must assess the direct and indirect impacts on air quality. This analysis must describe whether the project will result in increases of the six “criteria pollutants” for which there are national air quality standards: particulate matter (PM2.5 and PM10), nitrogen oxides (NOx), sulfur oxides (SOx), ground-level ozone, carbon monoxide, and lead.
Each phase of the project will have direct air quality impacts related to construction as well as the transport of cars to and from the storage sites. The Port has stated that to reach the 34-acre site, imported cars will roll off ships individually, then move either by rail, individually, or by truck to a short-term storage site just outside the Port.146 Employees will then drive the cars to the proposed storage lot individually, using a shuttle van to return to the short-term site as many times as is required to move every car to the 34-acre lot. 147 OHD asserts that the proposed 34- acre storage site will reduce emissions of criteria air pollutants by decreasing “truck traffic in Ventura County by consolidating car storage.”148
The City to date has only studied the emissions associated with the trips generated between the short-term storage site and the 34-acre lot, including employee trips.149 The DEIR assumes that there are 240 new car trips (one way) to or from the Port to the Project site, 24 shuttle trips to or from the Port, and 28 individual employee trips per day for a total 292 trips related to the project.150 Based on these vehicle trips alone, the City determined that the air quality impacts from the operation of the 34-acre site would not cause a significant effect on the environment.151 This analysis is incomplete. First, it fails to analyze multiple segments of the trips generated by the Project and instead focuses on one-way trips without providing clarity on the traffic impact of the back-and-forth movement of vehicles stored, shuttle service for employees, and employee commutes. This is something the Ventura County Air Quality Assessment Guidelines state should be used to evaluate all potential air quality impacts.152 Second, the DEIR should also evaluate the emissions from transporting cars to and from the 250-acre lot in addition to the 34- acre site. As highlighted throughout these comments, there is ample evidence showing that OHD had a vision for the 34-acre site to serve as a bridge for building the 250-acre project.153 By ignoring the connection to the Multimodal Logistics Park and improperly piecemealing the 146 OHD 34-acre Site Fact Sheet at 3; OHD 34-acre Site FAQs. 147 OHD 34-acre Site Fact Sheet at 3; OHD 34-acre Site FAQs. 148 Ibid. 149 Ass’n of Irritated Residents v. Kern County Bd. Of Supervisors (2017) 17 Cal.App.5th 708, 753. 150 DEIR, p. 5.3-11 151 Planning Division, City of Oxnard, Mitigated Negative Declaration No. 18-02 (Dec. 13, 2018), [hereinafter “Oxnard MND”], p.13. 152 Comment Letter on Notice of Preparation of DEIR for Somis Ranch Farmworker Housing Project PL 19-0046 from Nicole Collazoe, Air Quality Specialist, dated July 23, 2020. Attached in Volume II of the DEIR. 153 Oxnard & POH Commercial Viability Report 1037
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analysis of impacts, the DEIR fails to properly analyze traffic, air quality, and cumulative impacts of the Project, and therefore its conclusions cannot be relied upon.
Moreover, the analysis is incomplete because it fails to consider the connection to the already existing and continuing growth of Port-related activities mentioned in these comments. As this Project is tied to the expansion efforts of the Port and designed to facilitate increased throughput, an air quality impacts analysis that ignores port activity is flawed. OHD is undergoing efforts for significant expansion of Port activity, including deepening its harbor to bring in more imports154, and expanding off-port into various parts of the adjacent communities.155 As part of this endeavor, OHD plans to increase the utilization of rail.156 The Ventura County Railway line is located immediately adjacent to the southeastern portion of the Project site157, and the 250-acre Multimodal Logistics Park is slated to have rail capacity.158 According to the Port’s own emissions inventory from 2018, the locomotives servicing the Port use older, more heavily polluting technology. For example, the Port continues to use a locomotive with outdated locomotive engines such as Pre-Tier 0 or Tier 0 models that have been in operation since 2008.159 Since 2008, locomotive emissions at the Port have increased 41%.160 The DEIR must account for these emissions as part of its analysis as the Project would contribute to throughput and expand the use of these locomotives, which are utilized to take new vehicles to their ultimate destinations once they have been stored at the Project site.161
1. The DEIR Fails to Address how the Project will Shift Air Pollution Burdens of Port Operations onto Residents of South Oxnard Neighborhoods In addition to a complete evaluation of the emissions from the transport of the automobiles to both the 34-acre and 250-acre sites, the DEIR must also address that the Project will shift the burden of air pollution onto different populations. In City of Long Beach, the court faulted the EIR for failing to address the fact that the project would shift areas of high PM10 concentration to areas with homes and schools.162 As CAUSE has argued, and the Port has acknowledged, the project will shift vehicle traffic from the 9-mile stretch between the Port and the storage site in 154 Mike Harris, Army Corps of Engineers dredging Port of Hueneme channel, to replenish Hueneme Beach, Ventura County Star, January 8, 2021, available at: https://www.vcstar.com/story/news/local/communities/porthueneme/2021/01/08/port-hueneme-army-corps-of-engineers-beach/4143430001/ (Berths 1 and 2 were deepened to 40 feet last year); see also Wendy Leung, Construction to begin to deepen Port of Hueneme channel by 5 feet, Ventura County Star, February 22, 2019, available at: https://www.vcstar.com/story/news/2019/02/22/constructionbeing-deepen-port-hueneme-channel-five-feet/2887612002/ 155 2020 OHD Comprehensive Economic Development Strategy at p. 32. 156 Mike Harris, Army Corps of Engineers dredging Port of Hueneme channel, to replenish Hueneme Beach, Ventura County Star, January 8, 2021, available at: https://www.vcstar.com/story/news/local/communities/porthueneme/2021/01/08/port-hueneme-army-corps-of-engineers-beach/4143430001/ 157 DEIR, 5.10-7 158 INFRA FY19: Multimodal Optimization & Vehicle Efficiency Project Summary at p.1. 159 Port of Hueneme Draft Emissions Inventory, Calendar Years 2018, 2017, and 2008. 160 Id. at pp. 81, 89. 161 Mike Harris, Army Corps of Engineers dredging Port of Hueneme channel, to replenish Hueneme Beach, Ventura County Star, January 8, 2021, available at: https://www.vcstar.com/story/news/local/communities/porthueneme/2021/01/08/port-hueneme-army-corps-of-engineers-beach/4143430001/ 162 See City of Long Beach, supra, 19 Cal. App. 5th at 487. 1038
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Ventura to the 1-mile stretch between the Port and the 34-acre site in Oxnard.163 The proposed Oxnard site is across the street from Southwinds, one of Oxnard’s most densely populated neighborhoods.164 To reach the 34-acre site, traffic will pass by five elementary schools, one high school, two community parks, low-income housing, and a community health clinic, impacting several thousand young children who are more sensitive to air pollution, residents who may be seeking treatment for conditions exacerbated by poor air quality, and comprise a population that already experiences disproportionately high levels of air pollution.165 The DEIR fails to analyze the impact the project will have on these vulnerable populations by shifting air pollution away from the Ventura corridor towards them.166
2. The DEIR Fails to Properly Address the Project’s Impact on Regional Attainment of Air Quality Standards
The City must also address how the project’s emissions will contribute to the region’s ability to meet state and federal air quality standards. OHD is in the Ventura County Air Pollution Control District (VCAPCD), which is in serious nonattainment of the state and federal 8-hour ozone standard167, and the state particulate matter standards.168 Increases in ozone pollution and particulate matter could impact the VCAPCD’s ability to meet the standards, and mitigation measures should be developed and included in the DEIR to account for the Project’s contributions to already high levels of air pollution.
The DEIR must also discuss indirect air quality impacts from both phases of the Project. One indirect impact could be increased emission of criteria pollutants from reasonably foreseeable off-site activities caused by the Project. A lead agency must evaluate the significance of criteria air pollutants emitted by off-site activities that are a “reasonably foreseeable physical change to the environment.”169 For example, an EIR for a refinery expansion must analyze how the expansion will impact the movement of rail cars and the impacts on air quality from those rail changes.170
As mentioned throughout these comments, it was reasonably foreseeable that the 34-acre site will serve as a pathway for OHD to acquire and build the 250-acre Multimodal Logistics Park, yet the DEIR makes no mention of the latter in the air quality impact analysis. Had it properly done the analysis, the air quality impacts would include contributions of an increased number of cars being transported to and from the larger site. The analysis of air quality impact also omits consideration of the increased truck transport of vehicles once they are taken back to the Port for their final destination—an issue previously raised by CAUSE in response to the Mitigated Negative Declaration.171 As mentioned above, given the capacity-generating objective of the 163 See CAUSE Fact Sheet, p.2; OHD 34-acre Site Fact Sheet at 1. 164 CAUSE Fact Sheet, p.2. 165 Id. pp. 1-2. 166 See City of Long Beach, supra, 19 Cal.App.5th at 487. 167 Environmental Protection Agency, Air Quality Greenbook, Current Nonattainment Counties for All Criteria Pollutants, as of January 31, 2022; available at: https://www3.epa.gov/airquality/greenbook/ancl.html 168 DEIR, p. 5.3-3 169 Ass’n of Irritated Residents v. Kern County Bd. Of Supervisors, supra, 17 Cal.App.5th at 753. 170 Id. 750 – 51. 171 January 2019 CAUSE Letter to Oxnard Planning Department 1039
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Project, the air quality impact of increased Port throughput must also be considered. The analysis of air quality impacts is therefore flawed and must be revised.
3. The DEIR fails to offer a complete picture of Air Quality Impacts by not Incorporating Increased Port Activity
Reasonably foreseeable indirect air quality impacts from the addition of almost 5,000 parking spots one mile from the Port include increased emissions from the off-site ship, rail, truck, and cargo handling activities associated with expanding the port’s car storage capacity. If the sites increase the number of storage spots available to the Port, this will likely increase the Port’s capacity to ship cars, which OHD has indicated is its intention in expanding its offsite car storage capacity.172 OHD has gone as far as to say that the purpose of the 34-acre Project is to expand the Port’s capacity to bring in an additional 60,000 new cars for GLOVIS.173 Because these cars will eventually need to be distributed out from the Port, increases in rail, heavy-duty truck, or individual vehicle traffic and the resulting increased emissions are reasonably foreseeable.174 On the other end, it is also reasonably foreseeable that increased car imports will result in more ships visiting the Port, increased berthing, maneuvering, and cargo handling activities. The DEIR should consider the different effects and emissions that each transportation method will have on surrounding populations, given the types of fuel that each uses.175 Heavy-duty trucks and ships, for instance, use diesel fuel that contains higher levels of particulate matter than ordinary gasoline.176 Increased Port activity will likely contribute to higher levels of these pollutants in the South Central Coast Air Basin. Moreover, according to OHD’s 2020 Comprehensive Economic Development Strategy, the North terminal, where car-carrying ships dock, currently does not have shore power.177 This indicates that ships are not plugging in when they dock and instead are idling their engines, emitting even higher levels of emissions. Yet, the DEIR fails to capture any of this pollution in its analysis.
As mentioned, this Project is inherently tied to port operations. Both the Port and the Project site are in the Ventura County Air Pollution Control District (VCAPCD), which is in nonattainment of the state and federal 8-hour ozone standard, and state particulate matter standards. The Port acknowledges that its activities impact the surrounding communities and has identified ocean going vessels, harbor craft, heavy-duty drayage trucks, on-road mobile sources (vans and cars moving employees), and cargo handling equipment as the major emission sources associated with Port operations.178 Based on the Draft Inventory of Emissions for the Port of Hueneme, Ocean-going vessels accounted for 72% of NOx emissions from the port in 2018 and contributed 172 OHD FY18 Annual Financial Report at 6. 173 2017 Letter from Kristin Decas to Greg Nyhof 174 See Ass’n of Irritated Residents, supra, 17 Cal.App.5th at 753. 175 See City of Long Beach, supra, 19 Cal.App.5th at 487. 176 See CAUSE Fact Sheet at 1. 177 2020 OHD Comprehensive Economic Development Strategy, p.33.; see also, H3 Engineering Solutions, Inc, Draft Port of Hueneme Electrical Master Planning Report, prepared for Oxnard Harbor District, (January 12, 2019), p.18.
178 Oxnard Harbor District, Draft Environmental Management Framework Strategic Implementation Plans (April 22, 2013), p. 12, available at https://www.portofhueneme.org/wpcontent/uploads/2014/06/POH_E2_Framework_2015.pdf [hereinafter “2013 OHD Framework Plans”] 1040
Jay Dobrowalski
February 14, 2022