Santa Paula’s East Area 1 (EA1) Environmental Impact Report (EIR)

By Sheryl Hamlin

Chronology of Project

A history of the proposed East Area 1 project dates from 1998 to the present. Some key dates are as follows:

  • 2008: Santa Paula approves the EA1 project in a joint meeting of the City Council and the Planning Commission
  • 2008: EA1 Specific Plan Amendment was created and approved in 2008. A Specific Plan is an amendment to the city’s General Plan which extends or modifies the existing planning guidelines for a specific project.
  • June 3, 2008:   Voters approved the project in Measure G, a vote to amend the city’s urban restricting boundaries.
  • 2013: LAFCo approved annexation of the property into the boundaries of Santa Paula
  • 2013: EIR Approved Development Plan and EIR for East Area 2.
  • 2014: Limoneira filed to amend the approved 2008 Specific Plan Amendment thus triggering a Supplemental Environmental Impact Report (SEIR) based on these changes. Responses to this EIR were due May 2014.
  • 2014: A draft of the SEIR was produced (590 pages ) in October 2014 to which comments (4792 pages ) were compiled.
  • 2015: A final SEIR (156 pages) was produced in January 2015 summarizing changes and responding to comments .
  • February 17, 2015:   The Santa Paula City Council and Planning Commissions will hold a joint meeting about the Specific Plan Amendment (SPA) and the EIR. The staff report is available here.


The Staff Report outlines the changes and a view of the project with the proposed changes. In the Executive Summary, it says …

…the EA 1 SPA would reconfigure planning areas; leave the number of residential units (1 ,500) unchanged; and reduce the amount of light industrial and commercial areas. The intensity of allowed light industrial and commercial uses will be reduced from a combined total of 435,000 square feet to a combined total of 240,000. Minor modifications of the land plan reconfigure the EA 1 SP-3 to provide for three distinct planning areas that accommodate the residential neighborhoods, light industrial and commercial, and civic centers. Open space districts, including parks, greenways, and natural open space areas are also created. Development standards and design guidelines are updated, as are plans for utility infrastructure, internal traffic circulation, flood control features, and public services that account for the reconfigured land plan and Vesting Master Tentative Map….

East Area 1 Aerial Rendering

As viewed from a hypothetical rendering, EA1 is an annexed area of prime farmland adjacent to Santa Paula. There are two ways of ingress/egress: an extension of Santa Paula Street and a six-lane reconfigured Hallock Drive at Telegraph providing ingress/egress to Highway 126.



















 Road Changes

Although EA1 is an island, changes to certain existing streets will be required to support new traffic per the traffic study as described in the 4792 page Draft SEIR Appendices on page 122 of the pdf document:

Ojai Road is recommended to be widened to a pavement width of 50 feet. In the study area, widening is recommended on the section of Ojai Road between Santa Paula Street and Say Road. Sections of the existing roadway vary in width between 35 feet to 42 feet; the recommended roadway width is 50 feet. This widening can be accomplished within the existing right-of-way and would affect four analyzed intersections: Ojai Road/10th Street & Santa Paula Street (Intersection 12), Ojai Road & Saticoy Street (Intersection 11), Ojai Road & Orchard Street (Intersection 10), and Ojai Road & Richmond Road (Intersection 9).

Santa Paula Street. Santa Paula Street is recommended to be widened to a pavement width of 50 feet. Within the study area, this would apply to the section between SR-150 and the Santa Paula Creek. The existing roadway width is 36 feet; the widening can be accomplished within the existing right-of-way. This roadway widening would affect two analyzed intersections: Ojai Road/10th Street & Santa Paula Street (Intersection 12) and 12th Street & Santa Paula Street (Intersection 4). In particular, the west leg of the 12th Street & Santa Paula Street intersection and the east leg of the Ojai Road & 10th Street intersection would be widened

Caltrans noted that ten intersections would be at a Level of Service (LOS) of F (lowest) by 2025 at either am or pm peak hours.

Farmland Conversion

From the Resource Management Agency, County of Ventura (page 44 of the Final SEIR), the county says:

The proposed project would remove 150 acres of Prime Farmland and 194 acres of Unique Farmland from the project site. The removal of farmland listed on the State’s Important Farmland Inventory is a significant and unavoidable impact.   (Issue 7-7)

The response to Issue 7-7 was in part:

Accordingly, agricultural land was added to the San Buenaventura/Santa Paula Greenbelt to compensate for the loss of agricultural land on site.

No map was given to show where this “compensation” was made. The city discusses the Greenbelt in a document about agricultural resources dated 2012 saying:

While the application of a conservation easement will protect future agriculture resources, it will not fully mitigate the loss of existing prime farmland. As such, impacts will be significant and unavoidable.

Greenhouse Gas Emissions

From the Resource Management Agency, county of Ventura (page 46 of the Final SEIR0, the county says:

We recommend that the greenhouse gas (GHG) analysis of operational emissions be revised to more clearly explain why a finding of no significant impact was made for a project that would increase Santa Paula’s population by over 17 percent, increase its employment by about 10 percent, and result in 74 percent of vehicle trips originating from outside Santa Paula. We also recommend that the GHG analysis be aligned with the affordable housing issue, as affordable housing provisions within the project site will affect GHG emissions related to employment within commercial/industrial areas. (Issue 7-16)

The response to Issue 7-16 cited 1) live-work units to reduce traffic , 2) local retail to reduce trips , 3) open space,and 4) green design standards. They conclude with:

The Draft SEIR reference to 19 percent reduction criteria appears to be inadvertent. By exceeding the 16 percent reduction, as recommended by the CARB Scoping Plan, the Project would result in a less than significant impact.

The affordable housing part of the objection was answered with “the payment of an affordable  housing fee, which will be used by the City to provide affordable housing throughout the City.”


The water demand for EA1 is stated as follows:

…the annual average water demand for the EA1 SPA is 1,327.1 acre-feet per year (afy). Of this total, 1,014 afy is for potable water demand and 308.7 afy is nonpotable water demand for irrigation of parks, athletic fields, and agricultural preserves….

Further on they discuss recycled water:

In 2010, the City developed a Water Reclamation Facility (WRF) to meet the California Title 22 regulations for recycled water, as well as recycled water program for landscape irrigation. The City’s recycled water system conveyance plan includes a line in Telegraph Road, delivering recycled water to a point of connection (POC) near the intersection of Hallock Drive and the VCTC railroad ROW. The proposed Project includes a new recycled water distribution system. This distribution system will be comprised of a single 12-inch main to meet the higher irrigation flow demands of the schools and large landscape/park areas. The recycled water will terminate at two locations: 1) the end of Hallock Drive at the open space preserve; and 2) at the Soccer Field and Detention Area.

The Santa Paula Waste Water Treatment facility does not produce recycled water, nor is there a publicly published plan for producing recycled water. The EIR does not describe the interim plan to deliver the 308.7 afy of non-potable water demand to EA1.

They note that even though the county of Ventura has issued a well-drilling moratorium, this moratorium will not affect EA1 because the project is now within the city limits of Santa Paula and the moratorium only applies to wells outside city limits. New California groundwater legislation does not affect this project because the water in the Santa Paula Groundwater Basin is adjudicated:

Because the SPGWB has been adjudicated, it is not subject to the recent legislative changes to the same degree as other groundwater basins.


In response to a letter about the mismatch of the project to current demographics (issue 15-3), they quote population statistics for Santa Paula as follows:




Compound Annualized growth rate (CAGR) between 2003 and 2012 was 1.004071673 or .4%. The CAGR is the percent by which the value at the end of the year is increased giving a new total which is again multiplied by the CAGR for a total of the number of years in the series. In this case, the growth from 2003 to 2012 can be calculated by the following equation:


The CAGR between 2012 and 2020 is 2.2% so the calculation would be:


Because population occurs incrementally over time, the use of a compounding effect is logical. A linear view of this population growth can be seen as follows. Note that Santa Paula’s population is relatively stable between 2003 and 2012 and then increases by 2020 per the forecasted number. There is no explanation as to why the growth for Santa Paula would increase this dramatically. In fact, one site says the 2014 Santa Paula population is 29,321 which is slightly less that the population figure cited in the EIR for 2012 meaning that Santa Paula’s population has decreased.



Environmental Concerns

The Ventura Sierra Club submitted a letter citing issues with the following:

  • Premature flood protection
  • Increasing the capacity of the creeks with levees
  • Detention basins and effluent
  • Impacts of pets, loitering, vandalism, littering, vagrancy, graffiti in natural creeks
  • Safe passage of animal wildlife corridors

One of the mitigation measures (Issue 10-3) will be a special fee levied on EA1 to support a new Watershed Protection District to maintain the channel. It was not said if this fee was to be levied on the homeowners in perpetuity or one time via a developer fee. Dogs will be leashed and cats will have to wear bells. They will build a fence to contain the wild animals.

A letter from the Ventura CoastKeeper, a Program of the Wishtoya Foundation, stated:

Our overarching concern is that the Project’s impacts on water quality will severely impair the Santa Clara River Ecosystem, our coastal waters, aquatic species such as the Southern California Steelhead, and human health. We expect the Project to result in massive increases in pollutant loading to the Santa Clara River, increases in concentrations of pollutants of concern in the Santa Clara River, the Santa Clara River Estuary, and in marine waters, and an alteration of the natural flow regime of the Santa Clara River….

The consultants indicate that the storm water runoff passed an intensive peer review of specialists and provided a lengthy discussion of the runoff:

…the BMPs planned for the Amended Project, including detention/retention basins and other features designed to slow and infiltrate stormwater runoff on the Project site, will minimize potential hydrologic and water quality impacts to the adjacent creeks and the Santa Clara River. All runoff from urban development within the Project boundary during small and medium storm events, up to 85th percentile of storm events, will be captured and infiltrated on site.

Note: BMP means Best Management Practice.

The EIR shows two drawings: one of infiltration areas and one of discharge point. There is a lengthy discussion about scientific data and relevance with the consultant’s view that all conditions have been met properly.

Next Steps

The joint meeting on February 17,2015 with both the City Council and Planning Commission is designed to fast track the EIR by eliminating individual hearings with both bodies. This approach favors the applicant, but reduces the occasions for the citizens to comment in on the project. When the project was approved in 2008, the city also took a fast track approach with both Planning Commission and City Council convening together.

At the meeting, the bodies will be asked to approve a “Negative Declaration” or a “Mitigated Negative Declaration”. Another review will be published to which comments will be taken. In actuality, there may be litigation at this point, but in reality, litigation is not as prevalent as one would be led to believe.

Please refer to the Santa Paula website for more details and documents.


Sheryl Hamlin: With an MS in Industrial Engineering, Sheryl Hamlin spent years in technology with stints at Motorola, Tandem Computers and various startups. She has been on the boards of neighborhood organizations both in San Francisco and Palm Springs where planning issues were her specialty. She now resides in Santa Paula and loves the historic fabric of the city.  Ms. Hamlin’s blog Stealth Fashion  and  technology product ‘ Plug and Play Webmaster’.

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Nina Danza
Nina Danza
6 years ago

Thank you Sheryl for the clear summary, and please post a follow up story. While the attendance at the joint meeting on 2-17-15 was heavily pro-development there is no denying that urbanization, exactly like this project, deteriorates Southern California watercourses, streams and Rivers. My public comment to the City Council and Planning Commission as the Sierra Club Santa Clara River Committee Chair asked them to temper their decision knowing that this project will sacrifice the environment.