VENTURA RANCH HOUSING proposal is 100% vHFHSZ 100% ILLEGAL
VSec. 8107 A farmworker housing complex shall be prohibited in any location designated a Very High Fire Hazard Severity Zone
NO FARMWORKER HOUSING IN VERY HIGH FIRE SEVERITY ZONES
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VENTURA RANCH PARTNERS APPARENTLY CHOOSES PROFITS OVER ETHICS
Agricultural_Worker_Housing_Public_Review_Draft_-_10.14.21.pdf (vcrma.org)
See all the adopted ordinance changes here, as the county and whoever requested and paid for them had them presented to the Board of Supervisors for adoption. SOAR was built around those original ordinances, and they should never have been changed without a SOAR vote. So, who was working with the county to alter the ordinances in favor of for-profit building on SOAR land? SOAR is now almost useless due to the reworking of agricultural worker housing laws and the issuance of discretionary permits that undermine everything it stands for. Simply put, this isn’t about a farmer trying to build housing for farmworkers as the change implied when it was voted in. This is a clear example of rewording and reworking ordinances to let big money players take advantage of our farm resources.
These laws were passed to protect farmworkers
STATE LAW SUMMARY
Farmworker Housing & Safety Legislation (AB 2240, AB 3035, SB 1105)
Relevance to the Proposed 4884 N. Ventura Ave. Project
Overview
In 2024, Governor Newsom signed three bills intended to improve conditions for farmworkers:
• AB 2240 – Modernizes state‑run farm labor centers
• AB 3035 – Streamlines eligible agricultural employee housing
• SB 1105 – Protects farmworkers during emergencies
These laws expand protections and access, but none override CEQA, none allow housing on contaminated land, and none apply to sites in Very High Fire Hazard Severity Zones.
1. AB 2240 – Farm Labor Centers Modernization
Purpose:
Improve and expand state‑operated migratory farm labor centers.
Key Points:
• Applies to existing state‑run centers, not private developments.
• Allows rehabilitation, upgrades, and expansion of state facilities.
• Does not change CEQA requirements.
• Does not authorize housing on contaminated agricultural land.
• Does not apply to the 4884 N. Ventura Ave. proposal.
Relevance:
This bill supports state‑managed centers only.
It has no bearing on private farmworker housing proposals on historically pesticide‑treated land.
2. AB 3035 – Agricultural Employee Housing Streamlining (Limited Scope)
Purpose:
Streamline certain agricultural employee housing projects only if the site meets strict eligibility criteria.
Key Points:
• Applies only to qualifying agricultural employee housing.
• Does not apply to sites with hazardous materials or contamination.
• Does not apply to parcels in a Very High Fire Hazard Severity Zone.
• Does not override CEQA or DTSC testing requirements.
• Requires compliance with all environmental, zoning, and safety laws.
Relevance:
The 4884 N. Ventura Ave. site:
• Has 50+ years of pesticide applications
• Is in a Very High Fire Hazard Severity Zone
• Requires Phase I/II testing under CEQA
Therefore, AB 3035 does not apply and cannot be used to streamline or approve this project.
3. SB 1105 – Farmworker Safety During Emergencies
Purpose:
Protect farmworkers during wildfires, heat waves, and declared emergencies.
Key Points:
• Expands emergency protections and sick leave access.
• Addresses worker safety, not land‑use or housing approvals.
• Does not modify CEQA or environmental review requirements.
• Does not authorize housing on unsafe or contaminated sites.
Relevance:
SB 1105 strengthens emergency protections for farmworkers but has no connection to approving or streamlining housing projects.
4. What These Laws Do Not Do
None of these laws:
• Override CEQA
• Allow housing on contaminated agricultural land
• Remove requirements for soil, groundwater, or vapor testing
• Apply to sites in Very High Fire Hazard Severity Zones
• Force counties to approve unsafe or untested housing
• Replace DTSC oversight
• Apply to multi‑story residential complexes on hazardous sites
5. Bottom Line
These laws were passed to protect farmworkers, not to place them on:
• Contaminated soil,
• Groundwater‑impacted land, or
• High‑fire‑hazard zones.
The proposed 4884 N. Ventura Ave. project does not qualify for any streamlining under AB 3035 or any other state housing law.
A full Environmental Impact Report and DTSC‑supervised testing are required.
Building on top of Contaminated Soil. in a Very High Fire Hazard Severity Zone
1. Site Background
• Parcel has been in continuous agricultural production since ~1971.
• Historic crops: lemons and avocados.
• Ventura County DPR records show 50+ years of pesticide applications, including chemicals now banned, restricted, or known to persist in soil and groundwater.
2. Documented Pesticides Used on This Parcel
Historical DPR/PUR records show repeated use of:
Persistent & High‑Risk Chemicals
• Chlorpyrifos (neurotoxic organophosphate; banned for food crops)
• Paraquat dichloride (EPA Category I toxin; linked to Parkinson’s)
• Simazine & Diuron (groundwater‑contaminating herbicides)
• Copper sulfate / copper oxychloride (bioaccumulative soil contaminants)
• Chloropicrin fumigants
• Xylene‑based insecticides
• Strychnine & zinc phosphide rodenticides
• Petroleum distillate spray oils
• Avermectin miticides
• Glyphosate (multiple formulations)
Many of these chemicals remain in soil for decades and migrate into groundwater or indoor air.
3. Why This Matters for Farmworker Housing
Farmworker housing is residential exposure, not agricultural exposure.
Residents include:
• Children
• Pregnant women
• Elderly individuals
• Farmworkers with cumulative occupational exposure
CEQA requires heightened protection for sensitive receptors.
4. Required Testing Before Any Approval
Under CEQA, DTSC, OEHHA, and EPA guidance, the following are required:
Environmental Testing
• Phase I Environmental Site Assessment
• Phase II soil sampling (0–6”, 6–24”, 24–48”)
• Groundwater sampling
• Soil‑gas sampling
• Vapor intrusion modeling
• DTSC Human Health Risk Assessment (HHRA)
Chemicals requiring testing
• Chlorpyrifos
• Diazinon
• Simazine
• Diuron
• Paraquat
• Copper (total & soluble)
• Petroleum hydrocarbons
• Xylene & aromatic solvents
• Strychnine
• Metaldehyde
• Chloropicrin
• Glyphosate & breakdown products
5. Fire Hazard & Evacuation Concerns
The site is located in a Very High Fire Hazard Severity Zone (VHFHSZ) with:
• Limited ingress/egress
• Adjacent wildland fuels
• Multi‑story residential structures proposed
CEQA requires analysis of evacuation feasibility.
6. Housing Streamlining Does Not Apply
California’s housing streamlining laws cannot be used here.
SB 35 (Gov. Code §65913.4) excludes:
• Sites with hazardous materials
• Sites requiring cleanup
• Agricultural land
• Sites in high fire hazard zones
This project fails all four criteria.
7. Requested Action
We respectfully request that the County of Ventura Planning Division:
1. Require a full Environmental Impact Report (EIR)
2. Require DTSC‑supervised soil, groundwater, and vapor testing
3. Reject any attempt to streamline the project under SB 35 or similar statutes
4. Evaluate cumulative exposure risks for farmworker families
5. Ensure wildfire evacuation feasibility is fully analyzed
https://farmworkerhousingventura.com/community-events/
SOAR VIOLATION CONFIRMED BY DEVELOPERS OWN FLYER
If even one unit is occupied by someone who is not a farmworker or a farmworker family member, the SOAR exemption does not apply.
Ventura Ranch Admits
In their own flyer, Ventura Ranch states:
• Two (2) onsite property managers living on the property 24/7
• Two (2) onsite maintenance personnel living on the property 24/7