Ventura County Citizens Against Mega Gas v. City of Camarillo CA2/6

CourtCalifornia Court of Appeal
DecidedFebruary 2, 2026
DocketB344843
StatusUnpublished

This text of Ventura County Citizens Against Mega Gas v. City of Camarillo CA2/6 (Ventura County Citizens Against Mega Gas v. City of Camarillo CA2/6) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ventura County Citizens Against Mega Gas v. City of Camarillo CA2/6, (Cal. Ct. App. 2026).

Opinion

Filed 2/2/26 Ventura County Citizens Against Mega Gas v. City of Camarillo CA2/6 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION SIX

VENTURA COUNTY 2d Civ. No. B344843 CITIZENS AGAINST MEGA (Super. Ct. No. GAS, 2024CUWM022213) (Ventura County) Plaintiff and Appellant,

v.

CITY OF CAMARILLO et al.,

Defendants and Respondents.

COSTCO WHOLESALE CORPORATION,

Real Party in Interest.

The City of Camarillo and its city council (collectively, the City) approved Costco Wholesale Corporation’s (Costco) application to build a retail store and gasoline fueling station (the project). Ventura County Citizens Against Mega Gas (VCCAMG) appeals from the denial of a petition for writ of mandate. It contends the City violated the California Environmental Quality Act (Pub. Resources Code,1 § 21000 et seq.; CEQA) when it issued a second subsequent mitigated negative declaration (SSMND) instead of an environmental impact report (EIR). It contends the City did not properly consider or mitigate substantial changes in the project and in the surrounding area since approval of prior versions of the project. We affirm. FACTUAL AND PROCEDURAL HISTORY In 2007, the City approved development of a commercial center in Camarillo. The project included a maximum building area of 499,000 square feet including multi-tenant retail, restaurant, and office space. It also included 2,411 parking spaces. The City adopted a general plan amendment, zoning amendments, a commercial planned development permit (CPD), conditional use permit (CUP), and a mitigated negative declaration (MND).2 Approval of the original project was subject to 224 conditions. Traffic impacts were analyzed and on-site and off-site improvements were required to accommodate traffic associated with the project, including payment of a traffic mitigation fee. Mitigation conditions included a $651,222 payment to the

1 Undesignated statutory references are to the Public Resources Code.

2 A “mitigated negative declaration” is prepared when the initial study about the project identifies potentially significant effects on the environment, but the applicant agrees to conditions that would avoid the effects or mitigate them to a point that does not have a significant effect on the environment. (§ 21064.5.)

2 transportation demand management fund to reduce emissions of reactive organic compounds (ROC) and nitrogen oxides (NOx). Air quality mitigation conditions included “fugitive dust control measures” during excavation and reduction of air pollution emissions, including limiting truck idling time, alternate fuel for construction equipment if cost effective, and minimizing use of construction equipment and vehicles during smog season. In 2011, the City approved an addendum to the MND. The site layout was changed to increase the building area for an anchor tenant (Lowe’s) to 155,628 square feet and to add a drive-through restaurant. The overall maximum building space remained at 499,000 square feet. The number of parking spaces was reduced to 2,074. Approval was subject to 255 conditions, including continuation of the previous air quality requirements, a traffic mitigation fee, and funds for local transit. In 2016, the City adopted a subsequent mitigated negative declaration (SMND) reflecting changes in the layout and building elevations. It included a small increase to 157,801 square feet for the anchor tenant. The maximum total building development remained at 499,000 square feet. The mitigation conditions remained the same as the 2011 addendum. The project as approved in 2007, 2011, and 2016 was not built. But in 2022, Costco applied to modify the project to build a 163,177 square foot retail warehouse and freestanding fuel facility with 16 dispensers (32 fueling positions). Following a public hearing, the City’s planning commission approved the project, including modification of the CPD, approving a CUP, and adopting the SSMND. The SSMND was prepared by Cadence Environmental Consultants (Cadence) and was 3,366 pages long. It analyzes 18 categories of environmental

3 impacts, including air quality, wildfire, energy, transportation, biological resources, hazardous materials, population, and housing. The planning commission found “there are no environmental impacts that cannot be adequately mitigated.” Mitigation conditions in the SSMND included a timetable for implementing each measure and for monitoring compliance. VCCAMG appealed to the city council. (§ 21151, subd. (c).) The council held a public hearing and reviewed the project de novo. A Cadence representative stated the addition of a gas station was “not minor,” but an SSMND rather than an EIR was appropriate because the mitigation conditions would reduce environmental impacts to a less than significant level. He said that if an EIR were prepared, it would add “a few more sections” but would not provide the City with any new information. The council denied the appeal and adopted the SSMND. VCCAMG filed a petition for writ of mandate requesting the City order an EIR. The trial court denied the petition. (§ 21168; Code Civ. Proc., § 1094.5.)3 DISCUSSION VCCAMG contends the City erred in approving Costco’s project based on the SSMND rather than an EIR in violation of CEQA. We are not persuaded. As discussed below, substantial evidence does not support a fair argument that changed circumstances would produce new significant environmental effects that would not be effectively remediated by the SSMND

3 The court also dismissed VCCAMG’s claim for declaratory relief as “not appropriate to review an administrative decision.” (State of California v. Superior Court (1974) 12 Cal.3d 237, 249.)

4 mitigation conditions. (CEQA Guidelines,4 § 15162, subd. (a)(1) & (2); Friends of College of San Mateo Gardens v. San Mateo County Community College Dist. (2017) 11 Cal.App.5th 596, 607 (Friends II).) “An appellate court’s review of the administrative record for legal error and substantial evidence in a CEQA case, as in other mandamus cases, is the same as the trial court’s: The appellate court reviews the agency’s action, not the trial court’s decision; in that sense appellate judicial review under CEQA is de novo.” (Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal.4th 412, 427.) We “independently determin[e] whether the administrative record demonstrates any legal error by the [City] and whether it contains substantial evidence to support the [City’s] factual determinations.” (Ibid.) VCCAMG has the burden to show substantial evidence that changed circumstances required preparation of an EIR. (Citizens for a Megaplex-Free Alameda v. City of Alameda (2007) 149 Cal.App.4th 91, 112.) “ ‘The event of a change in a project is not an occasion to revisit environmental concerns laid to rest in the original analysis. Only changed circumstances . . . are at issue.’ ” (Friends of College of San Mateo Gardens v. San Mateo County Community College Dist. (2016) 1 Cal.5th 937, 949 (Friends I).) Therefore, here we review only the incremental effects of Costco’s project compared to the earlier projects. (Temecula Band of Luiseño Mission Indians v. Rancho Cal. Water Dist. (1996) 43 Cal.App.4th 425, 438.)

4 The Natural Resources Agency’s CEQA Guidelines are contained in California Code of Regulations, title 14, section 15000 et seq.

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Ventura County Citizens Against Mega Gas v. City of Camarillo CA2/6, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ventura-county-citizens-against-mega-gas-v-city-of-camarillo-ca26-calctapp-2026.