HOUSING FARMWORKERS AND THEIR FAMILIES IN PATH OF WILDFIRE

 factual summary of environmental, health, and regulatory concerns

For more than fifty years, the property at 4884 N. Ventura Avenue has been used for commercial agriculture, primarily lemons and avocados. Historical pesticide use reports from the California Department of Pesticide Regulation (DPR) show continuous applications of multiple chemical classes, including:

• Organophosphates (e.g., chlorpyrifos, diazinon, phosmet, methidathion)

• Groundwater‑mobile herbicides (simazine, diuron)

• Highly toxic compounds (paraquat dichloride, strychnine, zinc phosphide)

• Copper fungicides (copper sulfate, copper oxychloride)

• Petroleum distillates and xylene‑based insecticides

• Avermectin‑class miticides

• Multiple glyphosate formulations

• Chloropicrin fumigants

Many of these chemicals are known to persist in soil for decades, migrate into groundwater, or volatilize into indoor air. Several are classified by state or federal agencies as toxic, restricted materials, or probable carcinogens.

Why This Matters for Housing

The proposed development at this location consists of 18 three‑story residential buildings intended for farmworker families. Under California law, farmworker housing is treated as residential exposure, which requires the highest level of environmental protection.

Residents may include:

• Children

• Pregnant individuals

• Elderly adults

• Farmworkers with existing occupational exposure

These groups are considered sensitive receptors under CEQA and OEHHA health‑risk guidelines.

Required Environmental Review

Under the California Environmental Quality Act (CEQA), a project must undergo a full Environmental Impact Report (EIR) when there is evidence of:

• Historical pesticide contamination

• Potential exposure to hazardous materials

• Groundwater contamination risk

• Vapor intrusion pathways

• Cumulative health impacts

• Wildfire evacuation constraints

All of these conditions are present at 4884 N. Ventura Avenue.

A complete environmental investigation typically includes:

• Phase I Environmental Site Assessment

• Phase II soil sampling

• Groundwater testing

• Soil‑gas sampling

• Vapor intrusion modeling

• A Human Health Risk Assessment (HHRA) under DTSC guidance

Fire Hazard and Evacuation

The property is located within a Very High Fire Hazard Severity Zone (VHFHSZ). Multi‑story residential structures in such zones require analysis of:

• Evacuation feasibility

• Roadway capacity

• Emergency response times

• Wildland‑urban interface risks

These factors must be evaluated before any approval.

Housing Streamlining Laws Do Not Apply

California has recently expanded farmworker housing protections through AB 2240, AB 3035, and SB 1105, but these laws do not override CEQA and do not apply to contaminated or high‑fire‑hazard sites.

Specifically:

• AB 2240 modernizes state‑run labor centers only.

• AB 3035 excludes sites with hazardous materials, contamination, or fire‑hazard constraints.

• SB 1105 addresses emergency worker protections, not land‑use approvals.

Additionally, SB 35 (Gov. Code §65913.4) — California’s primary housing streamlining law — explicitly excludes:

• Sites with hazardous materials

• Sites requiring cleanup

• Agricultural land

• Very High Fire Hazard Severity Zones

The 4884 N. Ventura Avenue site meets all four exclusion criteria.

Conclusion

The historical record shows that the 4884 N. Ventura Avenue property contains multiple indicators of potential soil and groundwater contamination from decades of agricultural pesticide use. Because the proposed project would house farmworker families, CEQA requires a full Environmental Impact Report and comprehensive environmental testing before any development can be approved.

Ensuring safe, healthy, and environmentally sound housing for farmworkers is not only a legal requirement — it is a public‑health necessity.

safefarmworkerhousing.com

 Pesticide Use in Ventura County