Ceres City Council
April 13, 2026

Jays Tires
2940 Geer Rd
Turlock, CA 95382
209-668-1286
Emp: 1-5 CW / 1-2 Admin
In Jan 15, 2026 8:03 AM Contact: 209-538-5715
Sold To:

CERES POLICE DEPARTMENT
2727 THIRD ST
CERES CA 95307
Business Phone: 209-538-5715
****WORK ORDER****
Ship To: Unit#: AVA
Vehicle: 25 FORD RANGER XL T
Licen se:

Mileage: In: 0 Out: 0
Vin#:

PO#:

BAR ID: ARD00232020
EPA ID: 1529855-01
Sa1esm,3n Mechanic Part# QTY Description Parts Labor FET Total 5 42 1.00 . RX8FFFF JUSTICE 50" LIGHTBAR
5 42 2.00 . VTX609A AMBER LED FRONT
5 42 1.00 . STPKT104 LIGHTBAR STRAP KIT
5 42 1.00 . VTX609K RIA LED REAR
5 42 1.00 . VTX609M B/A LED REAR
5 42 1.00 . CCP9 LIGHTBAR CONTROLLER
5 42 1.00 . CEM8 EXPANSION MODULE
5 42 1.00 . ARGES2 REMOTE SPOTLIGHT
5 42 1.00 . ARGES FENDER MOUNT CUSTOM
5 42 1.00 . ARGES CONTROL HEAD
5 42 1.00 . MINI HARNESS / SHOP SUPPLIES
5 42 1.00 . 6CKT FUSE BOX
5 42 1.00 . 7615 BSS TIMER
5 42 1.00 . BSS CKT BRK 100A
5 42 1.00 . SHIPPING
5 42 1.00 . WEATHERGUARD 137-5-04 TOOL BOX
5 42 1.00 . PKG-PSM-1005-T COMPUTER MOUNT
5 22 24.00 . LABOR - UNDERCAR
Signature:

2,099.00 0.00
103.95 0.00

31.00 0.00
113.95 0.00
113.95 0.00
383.20 0.00
166.20 0.00
684.00 0.00

72.00 0.00
258.75 0.00
350.00 0.00

54.13 0.00
133.52 0.00

54.08 0.00

0.00 125.00
1,178.00 0.00
786.20 0.00

0.00 125.00
Parts:

Labor:

Subtotal:

Sales Tax:

Total:

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00
2,099.00
207.90

31.00 113.95
113.95
383.20
166.20
684.00

72.00 258.75
350.00

54.13 133.52

54.08 125.00
1,178.00
786.20
3,000.00
6,685.88
3,125.00

0.00 9,810.88
576.66
$10,387.54

ATTACHMENT D
ITEM 10
ITEM 10
QUOTE-3422615

CERES POLICE DEPT, CITY OF
(1) L5M & Parking Enforcement
12/10/2025
The design, technical, pricing, and other information (“Information”) furnished with this submission is confidential proprietary information of Motorola Solutions, Inc. or the Motorola Solutions entity providing this quote (“Motorola”) and is submitted with the restriction that it is to be used for evaluation purposes only. To the fullest extent allowed by applicable law, the Information is not to be disclosed publicly or in any manner to anyone other than those required to evaluate the Information without the express written permission of Motorola.

MOTOROLA, MOTO, MOTOROLA SOLUTIONS, and the Stylized M Logo are trademarks or registered trademarks of Motorola Trademark Holdings, LLC and are used under license. All other trademarks are the property of their respective owners. © 2020 Motorola Solutions, Inc. All rights reserved.

ATTACHMENT E
ITEM 10
12/10/2025

CERES POLICE DEPT, CITY OF
2220 MAGNOLIA ST
CERES, CA 95307
RE: Motorola Quote for (1) L5M & Parking Enforcement
Dear David McCann,
Motorola Solutions is pleased to present CERES POLICE DEPT, CITY OF with this quote for quality communications equipment and services.  The development of this quote provided us the opportunity to evaluate your requirements and propose a solution to best fulfill your communications needs.

This information is provided to assist you in your evaluation process. Our goal is to provide CERES POLICE DEPT, CITY OF with the best products and services available in the communications industry. Please direct any questions to Kayla Zibricky at [email protected].

We thank you for the opportunity to provide you with premier communications and look forward to your review and feedback regarding this quote.

Sincerely,
Kayla Zibricky
QUOTE-3422615

ATTACHMENT E
ITEM 10
Billing Address:

CERES POLICE DEPT, CITY OF
2220 MAGNOLIA ST
CERES, CA 95307
US
Quote Date:12/10/2025
Expiration Date:02/08/2026
Quote Created By:

Kayla Zibricky
Kayla.Zibricky@
motorolasolutions.com
End Customer:

CERES POLICE DEPT, CITY OF
David McCann
[email protected]
209-595-6068
Summary:

Any sales transaction resulting from Motorola's quote is based on and subject to the applicable Motorola Standard Terms and Conditions, notwithstanding terms and conditions on purchase orders or other Customer ordering documents.

Motorola Standard Terms and Conditions are found at www.motorolasolutions.com/product-terms.

Line
#
Item Number Description Qty Term List Price Sale Price Ext. Sale Price L5M Mobile System
Purchase
1 CDMS-HWW MOBILE LPR CAMERA KIT

EXTENDED HARDWARE

WARRANTY - VALID FROM

STANDARD WARRANTY

EXPIRATION
3 4 YEARS $1,680.00 $1,092.00 $3,276.00
2 VS-DLF-01 DEVICE LICENSE FEE 3 1 YEAR $474.96 $308.72 $926.16 3 VSB-54039 CDM-3-233-L5M 8 12 12
L5M CAM W VLP
1 $12,000.00 $7,800.00 $7,800.00
4 VSD-39941 VS-LBB-FS-VBAR-02-CVSFEDSIG V-BAR BRKT
4CAMS 1PAIR L/R REVC
2 $1,050.00 $682.50 $1,365.00
5 VSM-44901 CAM-MNT-FLAT-ASSY-SET

FLAT CAM MNT SET
1 $150.00 $97.50 $97.50
Investigative LPR
Applications
6 VS-VME-HS SOFTWARE,VEHICLEMANA

GER ENTERPRISE HOSTED
SUBSCRIPTION*
1 5 YEAR $3,750.00 $2,437.50 $2,437.50
QUOTE-3422615
(1) L5M & Parking Enforcement
Any sales transaction following Motorola's quote is based on and subject to the terms and conditions of the valid and executed written contract between Customer and Motorola (the ""Underlying Agreement"") that authorizes Customer to purchase equipment and/or services or license software (collectively ""Products""). If no Underlying Agreement exists between Motorola and Customer, then Motorola's Standard Terms of Use and Motorola's Standard Terms and Conditions of Sales and Supply shall govern the purchase of the Products.

Motorola Solutions, Inc.: 500 West Monroe, United States - 60661 ~ #: 36-1115800

ATTACHMENT E
ITEM 10
Line
#
Item Number Description Qty Term List Price Sale Price Ext. Sale Price 7 VS-CLIENTPORTAL-H VIGILANT HOSTED/

MANAGED CENTRALIZED

LPR SERVER VIA CLIENT
PORTAL FOR PARKING*
1 $0.00 $0.00 $0.00
LPR Integrations and
Parking
8 VS-VPS-PT-01 PARKING ENFORCEMENT

SYSTEM TOOLKIT - SAAS
1 5 YEAR $4,999.80 $3,249.87 $3,249.87
9 VS-VPS-PI-INT PARKING INTEGRATION -

ANNUAL FEE - SAAS
1 5 YEAR $4,999.80 $3,249.87 $3,249.87
10 ACC-SFT-ENBL ACCOUNT/SOFTWARE

ENABLEMENT
1 $330.00 $214.50 $214.50
Subtotal $22,616.40
Estimated Tax $2,296.48
Grand Total $24,912.88(USD)
QUOTE-3422615
(1) L5M & Parking Enforcement
Any sales transaction following Motorola's quote is based on and subject to the terms and conditions of the valid and executed written contract between Customer and Motorola (the ""Underlying Agreement"") that authorizes Customer to purchase equipment and/or services or license software (collectively ""Products""). If no Underlying Agreement exists between Motorola and Customer, then Motorola's Standard Terms of Use and Motorola's Standard Terms and Conditions of Sales and Supply shall govern the purchase of the Products.

Motorola Solutions, Inc.: 500 West Monroe, United States - 60661 ~ #: 36-1115800

ATTACHMENT E
ITEM 10
Pricing Summary
Payment Term Upfront Sale Price
Upfront Costs*
$9,477.00
Upfront Subscription Fee
L5M Mobile System Purchase Annually $1,745.16
Investigative LPR Applications Annually $487.50
LPR Integrations and Parking Annually $1,299.95
Sub Total: $13,009.61
Payment Term Sale Price Annual Sale Price
Year 2 Subscription Fee
L5M Mobile System Purchase Annually $819.00 $819.00
Investigative LPR Applications Annually $487.50 $487.50 LPR Integrations and Parking Annually $1,299.95 $1,299.95 Year 3 Subscription Fee
L5M Mobile System Purchase Annually $819.00 $819.00
Investigative LPR Applications Annually $487.50 $487.50 LPR Integrations and Parking Annually $1,299.95 $1,299.95 Year 4 Subscription Fee
L5M Mobile System Purchase Annually $819.00 $819.00
Investigative LPR Applications Annually $487.50 $487.50 LPR Integrations and Parking Annually $1,299.95 $1,299.95 Year 5 Subscription Fee
Investigative LPR Applications Annually $487.50 $487.50 LPR Integrations and Parking Annually $1,299.95 $1,299.95 Sub Total: $9,606.79
Grand Total System Price (Inclusive of Upfront and Annual Costs) $22,616.40 *Upfront costs include the cost of Hardware, Accessories and Implementation, where applicable.

QUOTE-3422615
(1) L5M & Parking Enforcement
Any sales transaction following Motorola's quote is based on and subject to the terms and conditions of the valid and executed written contract between Customer and Motorola (the ""Underlying Agreement"") that authorizes Customer to purchase equipment and/or services or license software (collectively ""Products""). If no Underlying Agreement exists between Motorola and Customer, then Motorola's Standard Terms of Use and Motorola's Standard Terms and Conditions of Sales and Supply shall govern the purchase of the Products.

Motorola Solutions, Inc.: 500 West Monroe, United States - 60661 ~ #: 36-1115800

ATTACHMENT E
ITEM 10
Notes:
●   The Pricing Summary is a breakdown of costs and does not reflect the frequency at which you will be invoiced. ● Additional information is required for one or more items on the quote for an order. ● This quote contains items with approved price exceptions applied against them.

QUOTE-3422615
(1) L5M & Parking Enforcement
Any sales transaction following Motorola's quote is based on and subject to the terms and conditions of the valid and executed written contract between Customer and Motorola (the ""Underlying Agreement"") that authorizes Customer to purchase equipment and/or services or license software (collectively ""Products""). If no Underlying Agreement exists between Motorola and Customer, then Motorola's Standard Terms of Use and Motorola's Standard Terms and Conditions of Sales and Supply shall govern the purchase of the Products.

Motorola Solutions, Inc.: 500 West Monroe, United States - 60661 ~ #: 36-1115800

ATTACHMENT E
ITEM 10
QUOTE-3423504

CERES, CITY OF
APX8500 PD
12/10/2025
The design, technical, pricing, and other information (“Information”) furnished with this submission is confidential proprietary information of Motorola Solutions, Inc. or the Motorola Solutions entity providing this quote (“Motorola”) and is submitted with the restriction that it is to be used for evaluation purposes only. To the fullest extent allowed by applicable law, the Information is not to be disclosed publicly or in any manner to anyone other than those required to evaluate the Information without the express written permission of Motorola.

MOTOROLA, MOTO, MOTOROLA SOLUTIONS, and the Stylized M Logo are trademarks or registered trademarks of Motorola Trademark Holdings, LLC and are used under license. All other trademarks are the property of their respective owners. © 2020 Motorola Solutions, Inc. All rights reserved.

ATTACHMENT F
ITEM 10
12/10/2025

CERES, CITY OF
2220 MAGNOLIA ST

FINANCE DEPARTMENT
CERES, CA 95307
RE: Motorola Quote for APX8500 PD
Dear Dave McCann,
Motorola Solutions is pleased to present CERES, CITY OF with this quote for quality communications equipment and services.  The development of this quote provided us the opportunity to evaluate your requirements and propose a solution to best fulfill your communications needs.

This information is provided to assist you in your evaluation process. Our goal is to provide CERES, CITY OF with the best products and services available in the communications industry. Please direct any questions to Nathan Tran at [email protected].

We thank you for the opportunity to provide you with premier communications and look forward to your review and feedback regarding this quote.

Sincerely,
Nathan Tran
Motorola Solutions Manufacturer's Representative
QUOTE-3423504

ATTACHMENT F
ITEM 10
Billing Address:

CERES, CITY OF
2220 MAGNOLIA ST

FINANCE DEPARTMENT
CERES, CA 95307
US
Quote Date:12/10/2025
Expiration Date:02/08/2026
Quote Created By:

Nathan Tran
[email protected]
End Customer:

CERES, CITY OF
Dave McCann
[email protected]
209-595-6068
Line # Item Number Description Qty List Price Sale Price Ext. Sale Price APX™ 8500
1 M37TSS9PW1CN APX8500 ALL BAND MP
MOBILE
1 $6,558.00 $4,787.34 $4,787.34
1a GA00250AA ADD: GNSS/BT-WIFI THRU
MNT ANT, 17FT LOW LOSS
PFP-100A/240, QMA
1 $118.00 $86.14 $86.14
1b HA00694AA ADD: 7Y ESSENTIAL SERVICE
HTM
1 $604.80 $604.80 $604.80
1c GA01513AB ADD: ALL BAND MOBILE
ANTENNA (7/8/V/U)
1 $112.00 $81.76 $81.76
1d G51AT SOFTWARE LICENSE
ENH:SMARTZONE
1 $1,766.00 $1,289.18 $1,289.18
1e GA05508AA DEL: DELETE VHF BAND 1 -$800.00 -$584.00 -$584.00 1f GA05509AA DEL: DELETE UHF BAND 1 -$800.00 -$584.00 -$584.00 1g B18CR ADD: AUXILIARY SPKR 7.5

WATT APX
1 $71.00 $51.83 $51.83
1h G843AH ADD: AES ENCRYPTION AND
ADP
1 $560.00 $408.80 $408.80
1i G444AH ADD: APX CONTROL HEAD

SOFTWARE
1 $0.00 $0.00 $0.00
1j G67EH ADD: REMOTE MOUNT E5 MP 1 $350.00 $255.50 $255.50 1k GA01517AA DEL: NO J600 ADAPTER CABLE
NEEDED
1 $0.00 $0.00 $0.00
1l G806BL SOFTWARE LICENSE ENH:

ASTRO DIGITAL CAI OP APX
1 $607.00 $443.11 $443.11
QUOTE-3423504
APX8500 PD
Any sales transaction following Motorola's quote is based on and subject to the terms and conditions of the valid and executed written contract between Customer and Motorola (the ""Underlying Agreement"") that authorizes Customer to purchase equipment and/or services or license software (collectively ""Products""). If no Underlying Agreement exists between Motorola and Customer, then Motorola's Standard Terms of Use and Motorola's Standard Terms and Conditions of Sales and Supply shall govern the purchase of the Products.

Motorola Solutions, Inc.: 500 West Monroe, United States - 60661 ~ #: 36-1115800

ATTACHMENT F
ITEM 10
Line # Item Number Description Qty List Price Sale Price Ext. Sale Price 1m GA01670AA ADD: APX E5 CONTROL HEAD 1 $767.00 $559.91 $559.91 1n W22BA ADD: STD PALM

MICROPHONE APX
1 $85.00 $62.05 $62.05
1o QA09113AB ADD: BASELINE RELEASE SW 1 $0.00 $0.00 $0.00 1p W969BG SOFTWARE LICENSE ENH:

MULTIKEY OPERATION
1 $388.00 $283.24 $283.24
1q G361AH SOFTWARE LICENSE ENH: P25

TRUNKING SOFTWARE APX
1 $353.00 $257.69 $257.69
Subtotal $8,003.35
Estimated Tax $670.28
Grand Total $8,673.63(USD)
Notes:

QUOTE-3423504
APX8500 PD
Any sales transaction following Motorola's quote is based on and subject to the terms and conditions of the valid and executed written contract between Customer and Motorola (the ""Underlying Agreement"") that authorizes Customer to purchase equipment and/or services or license software (collectively ""Products""). If no Underlying Agreement exists between Motorola and Customer, then Motorola's Standard Terms of Use and Motorola's Standard Terms and Conditions of Sales and Supply shall govern the purchase of the Products.

Motorola Solutions, Inc.: 500 West Monroe, United States - 60661 ~ #: 36-1115800

ATTACHMENT F
ITEM 10
Purchase Order Checklist NA OM
Marked as PO/ Contract/ Notice to Proceed on Company Letterhead (PO will not be processed without this)
PO Number/ Contract Number
PO Date
Vendor = Motorola Solutions, Inc.

Payment (Billing) Terms/ State Contract Number
Bill-To Name on PO must be equal to the Legal Bill-To Name Bill-To Address
Ship-To Address (If we are shipping to a MR location, it must be documented on PO) Ultimate Address (If the Ship-To address is the MR location then the Ultimate Destination address must be documented on PO )
PO Amount must be equal to or greater than Order Total
Non-Editable Format (Word/ Excel templates cannot be accepted) Tax Exemption Status
Signatures (As required)
NOTE: When an email order is submitted a confirmation is sent from Motorola AutoNotify referencing a case number.

Once checklist is complete, order still must go through Order Validation/Credit Approval

ATTACHMENT F
ITEM 10
ITEM 10
2/25/2026 Quote Number 2601059
Ceres Police Department
Customer PO Number
TOTAL
Subtotal
Sales Tax (8.375%) _________________________________________ Approved by Date
STEPFORD, INC.
1160 Industrial Road, Unit 9
San Carlos, CA 94070

650-598-9990 Office
650-598-0179 Fax
[email protected]
www.Stepford.com

QUOTE FOR

LABOR & MATERIALS
Item Qty Part Number Description Unit Price Total
ST
Requestor: Mark Anderson
GETAC V120
REVISED v4.0

COG GETAC - OPTION A
V120 - Intel Core Ultra 7 255H Processor, 12.2IN with Windows Hello Webcam, Microsoft Windows 11 Pro x64 with 32GB RAM + TAA, 256GB PCIe SSD (user swappable), Sunlight Readable (WUXGA LCD+ Touchscreen) + HF RFID, US KBD + US Power Cord, Membrane Backlit KBD, WIFI + BT, Standard Batteries (2-pack) + Hard Handle + Large Bumper, 3 Year B2B Warranty
MSRP 5417.00

1.0 15280662 4,160.00 4,160.00T

COG - SW GETAC
Bumper to Bumper + Extended Warranty- Notebook, Tablet(Year 4 & 5) - Getac, Tablet&Notebook (A/ B/ F/ K/ V/UX/X600 Series),
Bumper-to-Bumper+Extended
MSRP 599.00

1.0 4166448 555.00 555.00

COG GETAC
Getac Rugged Keyboard, 3 year warranty (US)
MSRP 249.00

1.0 5731771 225.00 225.00T
4 inches l... 1.0 CA State Recycling Fee: More than 4 inches, less than 15 inches 4.00 4.00 Freightcom Freight Costs to be determined at time of order 0.00 0.00T

ATTACHMENT G
ITEM 10
2/25/2026 Quote Number 2601059
Ceres Police Department
Customer PO Number
TOTAL
Subtotal
Sales Tax (8.375%) _________________________________________ Approved by Date
STEPFORD, INC.
1160 Industrial Road, Unit 9
San Carlos, CA 94070
650-598-9990 Office
650-598-0179 Fax
[email protected]
www.Stepford.com

QUOTE FOR

LABOR & MATERIALS
Item Qty Part Number Description Unit Price Total
Disclaimer The information contained in this document, fax or email and any attachments in any form is strictly confidential and is for the use of the intended recipient. Any use, dissemination, distribution, or reproduction of any part of this email or any attachment is prohibited. If you are not the intended recipient, please notify STEPFORD, Inc. at (650)598-9990 or by email at [email protected] and delete and/or destroy all copies including attachments.

0.00 0.00

The information contained herein is confidential and is provided for the sole use of the customer named above. Distribution or transmission of this information to any third party is expressly prohibited without the consent of STEPFORD, Inc. $5,311.24
$4,944.00
$367.24

ATTACHMENT G
ITEM 10

SIGNS AND BANNERS EXPRESS
521 WINMOORE WY SUITE E
MODESTO, CA 95358
Bill To:

CERES POLICE
Ship To:

Number:

Date: February 18, 2026
Description Rate Tax Amount
Project
Estimate
E110

FORD RANGER GRAPHICS(VEHICLE ABATEMENT)
BLACK GRAPHIS PREMIUM 3M FILM
480.00  480.00
$480.00

42.63 $522.63
Sub-Total
State Tax 8.88% on 480.00
Total

ATTACHMENT H
ITEM 10
ITEM 10

ATTACHMENT I
PROFESSIONAL SERVICES AGREEME�T
THIS PROFESSlONAL SERVICES AGREE:WENT ( .. Agreernenr··) is made and entered into this 23rd da) of March. 2026 (the ··Effective Date .. ) . by and bet""een the City of Ceres.
a California municipal corporation ("•City .
. ). and .la) ·s Tires. a California corporation
(--Professional"·). Cit) and Professional may herein be referred to individually as a --Party .. and collectively as the --Parties.'· There are no other parties to this Agreement.

RECITALS
A. City seeks to hire an independent contractor to perform vehicle build out services for the City of Ceres Police Department (the --Project .. ) B. Professional has submitted a proposal to Cit) to provide such professional services.

A description of the services Professiona I proposes to provide (--services .. ) is attached hereto as Exhibit A: Services. City desires to retain Professional to perfom1 the Services. subject to the terms and conditions set forth in this Agreement.

C. The Parties have outlined the rates and method of payment to Professional for its performance of the Sen ices under this Agreement. \,\hich shall be included in the Scope of Services in Exhibit A.

NOW, THEREFORE, in consideration of the mutual promises and covenants set forth belov,, the Patties agree as follO\\S:

AGREEMENT
Section 1. Recitals. The recitals set forth above (--Recitals .. ) are true and correct and are hereby incorporated into and made part of· this Agreement by this reference. In the event of an) inconsistency between the Recitals and Sections I through 32 of this Agreement. Section I through 32 shall pre,ail.

Section 2. Term. The term of this Agreement shall be three years and will commence on March 23. 2026. and terminate on March 22. 2029 ( .
. Term .. ) unless the Term is extended or
the Agreement is terminated earlier pursuant to this Agreement.

Section 3. Extension of Agreement. City may elect to extend this Agreement for two (2) additional years, on the same tenns and conditions. upon issuing an --Election to Extend Agreement"· letter executed by the City Manager to Professional thirty (30) days prior to the expiration of this Agreement.

PROFESSIO:--;AL SERVICES AGREEMENT
City of Ceres and Jay·s Tires
Page I of 18
ITEM 10

ATTACHMENT I
Section -t Work.
-U. CONTRACTOR shall furnish all labor. materials. equipment. fuel. tools. licenses. bonds and insurance necessar;, to perform and complete the required \\Ork as specilieJ belo\., and in strict accordance \\ ith the conditions of the complete agreement.

CONTR.\CTOR shall do and perform the \.\.Ork contemplated hercb: in a good \.\Orkman-like manner under the direction of and to the satisfaction of the Cl rY repn:sentati,e.

CO l'RACTOR shal I maintain proper insurance \\ ith the CITY for the duration of the .\GREE\IE:--:T.

CO� rRACTOR shall maintain a CITY business license for the duration of the :\ G R F E \ tr:"- I
CONTRACTOR shall l'urnish said sci"\. ices at the folio\.\. ing AGREE\tll::NT rates.

STA OARD ORDER PARTS 1
Minimum Discount Off List Price
SPEC[AL ORDER PARTS2
\Iinimum Discount Off List Price
LABOR RA TES (per hour)
AGREE�ll::NT PRICI'.'-G
Pickup/Deli\. ery!Travel $125.00
Custom Bo, Fabrication S 125.00
La\\ Enforcement Small Vehicle Lptitting Strip-Outs $125. 00 Shop Rate $125.00
Fabrication S 125.00
\lobileSenice Sl25.00
Vehicle Dm\. n/Emcrgency $ I 25.00
1 ·\1,111durd-Or,/,.,- !'art, r,li:r, 10 pan, rn,111 rnanufodur,r, liir "hl,m the c11111ractllr i, ,1 licen,c<l n:,..:lkr. '
- --\1
>,'ct<1/ Urda l'.1rt1 · r,li:r, h> parh fn,111 manul,1L·tur,r, t,,r 11hllm the ,·ontra,mr i, !.!ill :t lict:11'cd re,dkr. -t.2. Services. Subject to the terms and conditiom set forth in this Agreement.

Professional ::.hall pro\ ide Cit.' the Sen ices described in Exhibit A. I fan) conflict exist bet\,een the terms of this Agreement and Exhibit A. the terms of this Agreement shall control. An) request for Sen ices not incluc.led in Exhibit A \\ ill be considered a request for additional or modi tied Sen ices ( .
. \tlodification·· or ··Modilications··). Professional shall not recei, e additional compensation for an) Modification of the Services unless the Parties agree otherv,ise in a ,Hiting executed b: both Parties.
-t.3. City Requested Modification of Services. Cit: ma). b: \.\ritten order. authorize Modifications to the Ser\'ices dc:scribed in Exhibit A. If such Modifications cause an increase in the cost or time required for performance of Professional"s Sen ices. the Parties shall enter into a \.\ ritten amendment to this Agreement to adjust the Sen ices and the rates to be paid to Professional.

PROFE-.SSIO\.-\L �ER\'ICl:S .·\GREE\IE\:T
Cit:,, of Ceres and Ja:, ·� I ires

ITEM 10

ATTACHMENT I
rl1e Sen, ices shall not be re\ iscd unless Cit) and Professional mutual!) agree to a ,Hitten amendment to this Agreement rellecting such revisions. additional comrcnsation. time for rerfonn::rnce. or such other terms or conditions mutual!) agreed upon b: the Parties. �A. Professional Requested \'lodification 111 Services. Profes ·ional --;hall not be compensated !'or \\Ork outside the Sen ices described 111 this Agreement. unless. prior to the commencement of the Sen ices:
(a) Professional rrovides Cit) \\ ith "ritten notice that specitic \\Ork requested b: Cit:, or required to complete the Project is oubiue the agreed uron Sen ices. Such notice shall:
( i) be supported by substantial evidence that the "ork is outs idc the Ser, ices: and (ii) set forth the Profes<,ional"s propo-,cd course or action for comrleting the \\nr"- ant.la specilic request for Cit:
to appro, e the :Vlodi lication to the �en ice-,: and
(b) Cit: agrees that the \\Ork requires a \lodilication:
(c) The Parties execute a" ritten amendment to this Agreement describing an:

Moditication. Compensation for an) additional Sen ices shall not e\.ceed One hundred t\\enl) fr,e Dollars (S 125.00) per hour.

Section 5. Com pcnsation.

5.1. Amount, Time. and Manner of Payment for Professional Scn'iccs. Cit) shall ra) Professional acrnrding 10 the rates and timing set forth in E"Xhibit A. Cit)·-, total compensation to Professional shall not exceed thirl) thousand Dollars ($30.000.00) (··Maximum Pa) ment . .
) per
, ehicle unless the Parties mutuall: agree in \Hi ting othern ise. Professinnal hcreb: m:kno" kdges that it accept:-- the risk that the sen ices to be prO\ ided rursuant to the Scope nf Sen ices ma: be more costl: or time consuming than Professional anticipates and that Professional shall not be entitled to additional rnrnpcnsation unless agreed other\\ ise b: the Parties.

5.2. Subsequent Pa�·mcnts. Cit) shall make monthl: rayments in the amount imoiced b) Professional ,, ithin thirt) (30) calend,ir da)S ot' recci, ing such imoice. In the e, ent that an amount of an im oicc is in dispute. Cit) shall inform Professional of the amount and basis for the dispute and ma: \.\ithhold the amount ,,hich is in dispute until the dispute has been resohed.

5.3. lnYoices. Professional shall pro\ ide Cit) "ith rnonthl) im oices sufticientl) evidencing Professional·s expense:-- and completion of the Sen ices. All invoices furnished to Cit) b) Professional shall be in a form appro, ed b: Cit:. The pa) rnents specified shall be the onl) ra: mcnts made to Professional for performance of the Services. including compensntion tor an:

Modification. Professional shall submit al I bi II ing� for Ser\ ices to Cit) \,\ ith in forty-Ii ve (--l-5) days or the rerformance of such Sen ices. Cit) shall issue pa) ment according LO Cit) ·s custumar:
procedures and practices for issuing pa) mt?nts to independent contractors.

5.-t. Reimbursement. Cit: shall pa) Professional for reimbursable expenses specitied 111 Exhibit A incurred related to Professional's performance 01· the Services. Such reimbursable PROH�SSIO'--\L SER\ ICES -\GRED-IE'. T
Cii:,, of Ceres and Ja:,, -� Tires
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ITEM 10

ATTACHMENT I
costs shall be im oiced and billed to Cit:;- on a month I: basis. pro, ided that in no eH:nt shall reimbursable expenses exceed thirt) thousand Dollars ($30.000.00) per ,chicle.

Section 6. �otice to Proceed. Protessional shall not commence the performance of the Scrv ices unti I it has been gi \ en notice b) City ("·Notice to Proceed··).

Section 7 Time of Performance. Prolessional \\ ill commence performance of the Sen ices vv ithin seven (7) calendar days of the date the Notice to Proceed. The time of performance is a material Lenn of this Agreement relied on b: Cit:, in entering into this Agreement.

Section 8. Professional's Resources. Professional shall. at its sole cost and expense. furnish all lacilitie!,. equipment. materials. information. personnel. and administrati, e assistance \\ hich ma) be required to perform its obligation!, under this Agreement.\\ ith the e".ception of items or Cit: assistance specified in Exhibit A.

Section 9. Duties of City. In order to permit Profe�sional to render the services required hereunder. Cit) shall. at its expense and in a time! :, manner: (a) Pro, ide such information as Professional ma: rcasonabl:, require to undertah.e or perform thl' Sen ice:,: (b) Prompt!) revie\\ an: and all documents and materials submitted to Cit::, by Professional in order to avoid unreasonable dela: s in Protessional·s performance of the Sen ices: and (c) Prompt I: not if:

Protessional of an:;- fault or defect in thlc' performance of Professional·s sen ices hereunder.

Section 10. Time and Personnel DeYote<l to ScrYices. Professional shall deHllC such time and personnel to the performance or this Agreement. as is necessar::- to perform the Sen ices in compliance ,, ith this Agreement.

Section 11. Performance by Qualified Personnel; No Subcontracting. Sen ices under this Agreement shall be performed onl:, b:;- competent personnel under the supen i-;ion and direct emplo: rnent of Professional. Prol'c.:ssional \\ ill conform \\ ith Cit:,·� reasonable requests regarding assignment of personnel. but all personnel. including those assigned at Cit) ·s request. shall be suren ised b: Prokssional. Professional is prohibited f rom subcontracting this Agreemem or an:
part of it unless such subcontracting is express I) appro\ ed b: Cit:;- in "riting. :"-Jeither Part:;- shall. on the basis of this Agreement. contract on behalf of. or in the name of the other Party. An agreement made in , iolation of this pro\ is ion shall confer no rights on an: Part: and shall be null and void.

Section 12. Representations of Professional. Cit: relies upon the folio,, ing represemations b) Professional in entering into this Agreement:

12.1. Qualifications. Professional represents that it is qualified to perform the en ices provided in Exhibit A and that it possesses the necessary licenses and permits required to perform the Sen ices or ,, ill obtain such licenses or permits prior to the time such licenses or permits arc required. Professional shall also ensure that all subcontractors are similar!:;- licensed and qualified.

Professional represents and warrants to City that Professional shall. at Prolessional's sole cost and expense. h.eep in eftect or obtain at all times during the Term or this Agreement. an: licenses.

PROFES�I0'-.:-\1. SERVICES :-\GREE\IE"T
Cit} of Ceres and Ja) ·s Tire,
Page -t of 18
ITEM 10

ATTACHMENT I
rermits. and approvals ""hich arc: legally required for Professional to practice Professional's profcs�ion at the time the Sen ices are rendered.

12.2. Professional Performance. Professional represents that all Sen-ices under this 1\greement shall be performed in a nrnnner consistent \\ ith the professional skill and care ordinaril) pro" ided b;- consultants rracticing in the same or similar local it:-, under the same or similar circumstanl..'.es. Professional shall perform its sen ices as e:--peditiousl: as is consistent \\ ith such professional skill and care and as neccssar) ror the orderly progress or the Project. Professional agree� that. if a Sen ice is not ::,o perfom1ed. in addition to all of its obligation� under this Agreement and at la""· Professional shall re-perform or replace unsatisfactory Ser\. ice at no additional expc:nsc to Cit).

12.3. '.'Jo Waiver of Claims. The granting ofan) rrogre'>s payment b: Cit). or the receipt thereof b: Professional. or an: in�rection. re\ ie\\ . arrroval or oral statement b:-, an: representatiYe of Cit:-,. or state certification shall not. in an:, v\ a). v,ai\ c. limit. or rerlace an:-, ce11ification or appr\n al procedure::, normal I: required or lessen the: liabilit) ot' Prote�sional to re-perform or replace unsatisfacto1') Sen, ice. including. but not limited to. cases \\ here the unsatisfactor) character or such Sen ice ma;- not ha\ e been apparent or detected at the time of sul..'.h pa) ment. inspel..'.tion. re\ ie\\ or appro, al.

12.-1. City's Remedies are CumulatiYe. 01othing in this Section shall constitute a \,ai\ er or limitation of any right or remedy. \\ hether in equit) or at la\\ . \\ hich City or Professional ma:
ha\e under this Agreement or an::- aprlicabk la\\ . ,\II right:-. and remedies of Cit;-. \\hether under this Agreement or applicable la,\. shall be cumulati\ e.

12.5. No Conflict of Interest. Prore�sional represents that no conflict of interest \\ ill be created under state or federal la\\ b:, entering into or in carr;-ing out this Agreement.

Section 13. Conformi�· with Law and Safety. Professional shall observe and comply ,vith all applicable l,l\\ s. ordinances. codes. regulations. and permits of go\ ernrnental agencies. including federal. state. municipal and local governing bodies havingjurisdiction O\ er an) or all of the scope of Ser\ ices. including all pro\ isions of the Occupational Safct;- and Health Act of 1979 as amended. all California Occupational Safet) and I lealth Regulations. the California Building Code. the American::,\\ ith Disabilities /\ct. an) cop:- right. patent. or trademark law. and all other applicable federal. state. municiral and local safct) regulations. appropriate trade association safet) standards. and appropriate equipment rnanu facturer instructions. All Sen ices performed by Professional must be in accordance"' ith the�e la\\ s. ordinances. codes. and regulations. including the administrative policies and guidelines of City pertaining to the vvork. Professional· s failure to
compl) \\ ith an;- lm\S. ordinances. codes. or regulations applicable to the performance or the Services hereunder shall consti lute a breach of contract. In cases ,vhere standards conflict. the standard pro\ id ing the highest degree of protection sh al I pre\ ai I.

If a death. serious personal injury. or substantial rropert) damage occurs in connection \\ ith the performance or this Agreement. Protessional shall irnmediatel) notif'::- Cit) t\lanager b) telephone. l r any accident occurs in connection v, ith this Agreement. Prolessional shal I prompt!) submit a ,, ritten report to Cit;-. in such form as Cit: ma;- require. This report shall include the PROFESSIO'-: \L SERVICES ,\GREE\IE'-:T
Cit) of Ceres and Ja� ·s Tires
Page S of 18
ITEM 10

ATTACHMENT I
l'ollo\, ing in formation: (a) >lame and address or the injured or deceased person( s ): ( b) >lame anJ address or Prolcssional's subcontractor. if an:: (c) ame and address or Professional's liabilit) insurance carrier: and ( d) A deta i leJ description of the accident. inc luJ ing "hethcr an: l)I. Cit: 's equipment. tools or materials \\ae im olved.

II' a rckase or a hazardous material. substance. or "aste occurs in connection "ith the performance or this Agreement. Professional shall immediate I) not if': Cit: Manager.

Section 1-t. Contact by Professional with Project Owner or Project Applicant. L'nlcss other\, ise set fnrth in the Sen ices. neither Professional nor Professional\ subcontractors shall direct I) contact the o,, na or the propert) im oh ed in the Project or an: pan:- ,\ho is the arplicant for the Project (""Interested Part) .. ). or an employee or contractor or an Interested Part). on an:
matter relating to the Project " ithout the prior consent of Cit). In nn C\ent shall Prokssional take an) in-..tructions or Jircctions from an Interested Pan: on an: mallcr pertaining to the Professional's Services to be performed for Cit) unJer this Agreement.

Section 15. Confidentiality
. Professional understands and agrees that. in the performance or Sen ices under this ,\greement or in the contcmplatilrn thereof. Professional ma:- have access to rri,ate or conlidential information that ma: be o\\ned or controlled b: Cit) and that such information may contain proprietary or confidential details. the disclosure or\,hich to third parties ma, be damaging to Cit) (--Confidential Information··).

Professional shall not. either during 0r after the l"crm. disclose to an: third part:- an:

Confidential lnlonnatinn \\ithout the prior \\ritten consent of Cit). If Cit) gi,cs Professional \Hitten authoril'.ation to make an) such disclosure. Professional shall do so onl: "ithin the limits and to the e:-.tent of that authorization. Prokssional ma:- be directed or ad, ised b: the Cit: ·s Ceneral Counsel on , arious matters relating to the performance or the Services l)ll the Project or on other matters pertaining to the Project and. in such event. Profcs-;ional agrees that it \\ ill treat all communications bet,,een itsclL its emplo:ces and its subcontractors as being communications vvhich an: within the allorney-client pri, ilege.

Not" ithstanding the l�lregoing. Prolessional ma: disclose Confidential Information required to be disclosed under lav,. provided that. prior to disclosure. Prot'cssional shall first give notice to Cit: and make a reasonable effon to obtain a protecti\e order requiring that Cit: ·s Confidential Information not be disclosed. rl1is c,ception is limited to the extent disclL)sure is requircJ under Im\.

Section 16. Ownership of Work Product. Any and all v,ork. art,vork. copy. posters. bi I I boards. photographs. videotapes. audiotapes. S) -;terns designs. soft" are. reports. designs. specifications. drawings. diagrams. surve) s. source codes. professional or technical information or data. photographs. notes. letters. emails or an: original \\Orks or authorship created b) Professional or its subcontractors or subcontractors in connection " ith Sen ices performed under this Agreement c·Proclucts .. ) shall be \\Orks lor hire as defined under Title 17 of the United States Code. and all cop:-rights in such ,,orks are the propert) of Cit:. In the e,ent it is e,er determined that an) Product created b: Professional or its subcontractors. or subcontractnrs under this Agreement. arc not v.nrks for hire under U.S. Im,. Protessional hcrcb) assigns all copyrights to PROFESSIO\:.-\L SERYICl:S .-\GREE\IE:--. T
City ofCacs and Ja:-, ·s Tires

ITEM 10

ATTACHMENT I
such Products 10 Cit). With the prior ,Hitten appro, al of Cit)· s point of contact for the Project.

Professional ma: retain and use copies of such Products for reference and as documentation of its e,perit:"nce and l.'.apabi I it ies.
/\ 11 Products sha 11 become the propt:"rt) of Cit: irrespective or,, here located or stored. and Profes,iona I agrees to de Ii, er a 11 such documents and in format ion to Cit). ,, ithout charge and in "' hatevcr form it exists. on the completion or the Professional's Sen ices hereunder. Prol"cssional shall ha, e no cm nership interest in such Products.

A 11 ,, ork product of Professiona I under th is Agreement. including \Hi tten in formation ,, h ich Cit: "ill cause to be distributed for either internal or public circulation. including both preliminar:
and final drafts. shall be deli, ered to Cit) in both printed and electronic form. or as ma) be specified in Exhibit A.
l ipon the conclusion of the Tenn or in the e, ent or Termination of thic; Agreement.

Profes:_..ional agret:"s. at its e,pense and in a timel:- manner. to rt'tum 10 Cit: all document:,. <lra\\ ings. photographs and other \Hit1cn or graphic material. ho,,\.'\ er produced. that it recei, ed from Cit:,-. its contractors. or agents. in connection ,, ith the performance of its Ser, ices under thi:, .\greemt'nt. /\II materials shall he returned in the same condition as recei, ed.

Section 17. .\ssignmcnt Prohibited. -:\o Part:,- tn this ,.\grt:"ement ma:,- assign am right or ohligati\ll1 pursuant to this \greement. An: attempt or purported assignment of an) right or obligatilln pursuant t11 this Agreement shall be void and of no effect.

Section 18. Excusable Delays: �otice to Other Par� of Delay·. Professional shall not be in breach or thi� :\greemcnt in th\.' e, t:'llt that performance of Sen ices is temporaril:,- interrupted or discontinued due to a ··Foret' \la_jeur\.'·· e,ent ,, hich is defined as: riots. ,,ars. sabotage. ci, il di-;turbanees. insurrections. e,plosion. natural disasters such as lloods. earthquakes. landslides.

Ii res. strikes. lockouts and other labor disturbances or other catastrorhic e, t'nts. ,, hich arc be) ond the rea-;onabk control or Prol"e-;sional. Force i\lajeur\.' does not include: (a) Professional"s linancial inabilit:,- to perform: (b) Prol"cssional"s lailurt' to obtain an:, necessar:,- permits or licenses f rom
other go\ernmental agencies: or (c) Professional"s failure to obtain the right to US\.' the facilities or an) public utilit::, whcrt' such failure i-; due sole!) to the acts or omissions or the Professional.

Section 19. Suspension of Services by City. Cit) resencs the right to suspend Profe�sional's Sen ice-; under this Agreement ,,·hen Cit: determines that it is necessar� to do so. When possible.

City shall gi, e Professional notice or such suspension and Professional shall. upon receipt of said notice. suspend all Services c,cept any Services. th\.' completion of \vhich is authorizt'd by the notice gi, en b: Cit). If the St'nices art:" suspended b) Cit: for more than si:,.;.t: (60) consecuti, e da)S. for reasons other than th\.' fault of the Professional. the Professional shall be compensated for Sen ices performed prior to notice of such suspt'nsion. When the Project is resumed. th\.' Professional's compensation :,hall be equitabl: ad_justed b) Cit::, to pro, idc for e:--penses incurred b: the interruption orthe Ser, ices. In this regard. Professional shall furnish to Cit) such linancial information that. in th\.' _judgment or the Cit) Manager. is nccessar::, to detcnnint' the reasonable \ alue of the Sen ices rendered b::, Professional during the pt'riod ,, hen Ser, ices ,, ere suspended.

PROFESSIO:\.-\L SERVICl:S .-\GREE\IE:S:-1
City of Ceres and Jay· s Tires

ITEM 10

ATTACHMENT I
Section 20. Termination of Work by City for Its Connnience. Cit: shall ha\ e the right to terminate thi-; Agreement at an: time for its com enience b:, gi, ing notice or such termination to Profcs:sional ( .
. Termination··). In the e,cnt Cit) shall give such notice or termination. Professional shall cease remlering Ser, ices upon receipt of said notice given as required in this Agreement. If Cit: tenninate:,, this Agreement:
(a) Professional shall deli,er copies of all Products prepared b:, it pursuant to this .\grecment.
(b) If Cit::, terminate-, this Agreement for conH:nience before Cit) issues the Notice to Proceed to Profe:ssional or before Professional commences an: Sen ices hereunder.\\ hiche\ er last occurs. Cit: shall not be obligated to make an) pa1rnem to Professional. If Cit: terminates this Agreement a lkr Cit: ha:,, issued the Nl)tice to Proceed to Profes'>ional and after Professional has commenced performance under this .\grcement. Cit:, shall pay Professional the reasonable , alue of the Sen ices rendered b: Protessional pursuant to thi-, .\greement prior to termination of this Agreement. Cit::, shall not in an::, manner be liable for Prolcssional's actual or projected lost prnfits had Professional completed the Sen ices. Prok:,,sional :,,hall furnish to ( it) :such financial information that. in the judgment of the Cit) i\lanager. i-, nece:ssar: to determine the reas,,nable value of the Services n:ndered b:- Professional prior to tcr111ination. (c) E:-..cept as prO\ ided in this Agreement. in no e, cnt shall Cit) be liable for ClbtS incurred b: or on behal r of Prolcssional alter the date or the notice or ter111 i nation. (d) '-<ot,, ithc;tanding thi-. Section. this Agreement ma: be terminated b:, Cit:, for cause based on the loss or suspension of an: licenses. permits or registrations required for the continued pro, i-.;ion of the Sen ict.:s. or Prolessional"s malfeasance. Tcnnination of the Agreement for cause as set forth in this Section shall relie, e City f
r
om compensating Professional.

Section 21. Assurance of Performance. If. at an: time. Cit: belie, cs Professional 111a: nnt be adequate!::, performing its obligations under thi-; ,1\greement or ma) fail to complete the Sen ices as required b) this Agreement. City 1ml) submit a \\Titten request to Professional for ,Hitten assurances 01· performance and a plan to correct ob:-.en ed deticiencies in Professional's performance. Failure to pro, ide ,, ritten assurances subsequent to :,,ueh \\ritten reque-,t. constitutes e:rounds to declare a breach under this /u:ree111cnt. - � Section 22. Cancellation for Breach by Either Par�·. Should either Part: fail tl) substantial!:
perform its obligations in accordance,, ith the provisions or this Agreement. the other Pat1) shall thereupon h;;ne the right to cancel the Agreement b) gi, ing \Hitten notice and specifying the effecti\c' date of such cancellation. If Cit) cancels this Agreement for breach and it is subsequent I:
determined that Professional did not fail to substantial!) perform its obligations in accordance,, ith this Agreement. then cancellation for breach b: Cit: shall be deemed. and treated. as termination for com enience.

Neither Pany ,\ai,es the right to reco,er damages against the other for breach of this Agreement. including an:, amount necessar: to compensate Cit:, for all detriment pro:--;imately caused b: Professional's failure to perform its obligations hereunder or \\ hich in the ordinary PROFESSIO�.\L SER\'IC[S .\GREE\IL'-. T
Cit! of Ceres and Ja� ·, fires

ITEM 10

ATTACHMENT I
course or thinus \,Ould be likeh lo result therefr
.._ ., om. Cit\
.,
resenes the rir!ht -- to offset such damaues .._
against an: pa) ments O\\ ed to Proles-,ional.

Cit) shall not in any manner be liable for Professional's actual or projected lost profits had Professional compktcd the Services required b) this Agreement.

Section 23. Dispu tc Resolution. In the e\ ent of an: cl ispute bet\\ een the Parties to th i" Agreement. the Parties agree to first negotiate in good faith tO\\ard a resolution \\ ith panicipation b) representatives or each part) holding sufficient authority to resohe the dispute. If such dispute cannut be resolved \\ ithin fifteen ( 15) business da)'s. the dispute shall be submitted to mediation as a condition precedent to initiating rormal litigation.

Section H. Insurance Con'ragc. During the I ern1. the Professional shall maintain in full l'orcc and cl'lect policies or insurance set forth herein.\\ hich shall be placed \\ ith insurers\\ ith a current AM lkst·s rating ol'nll less than;\ VII and ,,ill rrm ide Cit) \,\ ith ,Hillen prool'nfsaid insurance.

Prnfcs�ional shall rnaintain C0\ eragc as follo,,s:
2-U. General Liability. Protessional -,hall carr: gcneral liabilit: in ... urance in the amount of T\\O :

V
lillion Dollars C52.000.000.00) rer occurrence for bodily injur). personal injur:. and propert) darnage. If commercial general liabilit) insurance or another form ,,ith a general aggregate limit is used. either the general aggregate limit shall appl) separate!) w this Project or the general aggregate -;hall be T\\o \ti Ilion Dollars (S2.000.000.00).

H.2. Workers' Compensation Insurance and Employer's Liability . Protessional
shall catT) ,\orkers· compensation insurance as required b) the State of California under the Labor Code. Professional shall abn carr:- employer·s liabilit) insurance in the amount or One Million Dollar-, ($1.000.000.00) per accident. \\ ith a One \ti Ilion Dollar ($1.000.000.00) j)l)lic:- limit l'or bod ii: injur:- by disease. and a One i\lillion Dollar (S 1.000.000.00) limit for each employcc·s bodih injur: b) disease.
2-l.3. En-ors and Omissions Liability. Professional shall carry errors and omissions liabilit) insurance in the amount nrno less than l\\-o Million Dollars ($2.000.000.00) per claim or greater ii' appropriate for the Profe::-.sional's profession. An: deductibles or self-in�ured retentions must be declared to and appro\ ed b: Cit). At the option of the Cit). either the insurer shall reduce or eliminate such deductibles or self-insured retentions \\ ith resrect to the Cit) . elected and
arrointed councils. commissions. directors. officers. emplo:-ees. agents. and representati\ cs c·Cit) ·s Agents .. ): or the Professional shall prcl\ ide a financial guarantee satisl::1cltX) to the Cit:
guaranteeing pa:- ment or losses and related il1\ estigations. claims administration and defense expenses.
2-l.4. Commercial Automobile Liability
. Professional shall carry commercial
automobile liabilit)- insurance in the amount of One Million Dollars ($1.000.000) or greater per occurrence for O\\ ned. leased. hi red. and borTO\\ ed automobi lcs. 2-l.5. Waiver of Subrogation. \\'ith the exception or errors and om1ss1ons liabilit) insurance. Prolessional hereb) agrees to \,\ai\·e subrogation \\hich an) insurer or Protessional ma) PROFESSIO�,-\L SER\ IC.TS AGREE\tlF.'.T
Cit� of Ceres and Ja� · s Tire,

ITEM 10

ATTACHMENT I
acquire from Professional by virtue of the pa) ment of any loss. The commercial general I iabi I ity policy and \\Orkers· compensation policy shall be endorsed to contain a vvaiver of subrogation in favor of City for all work performed by Professional. its agents. employees. independent contractors. and subcontractors. Professional agrees to obtain any endorsement that may be necessary to affect this vvaiver of subrogation.

Section 25. Additional Insurance Requirements. Within five (5) days of the commencement of the Term. Professional shall provide City with ce1tificates of insurance for all of the policies required under this Agreement ( .. Certificates .. ). excluding the required workers· compensation insurance. Such Certificates shall be kept current for the Term of the Agreement and Professional shall be responsible for providing updated copies and notify ing City if a policy is cancelled.
suspended. reduced. or voided. With the exception of the vvorkers· compensation and errors and omissions liability insurance. all of the insurance policies required in this Agreement shall:
(a) PrO\ ide that the policy will not be cancelled. allo\ved to expire. or material I) reduced in coverage vvithout at least thirt:, (30) days· prior written notice to Cit) of such cancellation. expiration. or reduction and each pol icy shal I be endorsed to state such:
(b) Name City. and City"s Agents as additional insureds \\ ith respect to liabilit) arising out of Services. work. or operations performed by or on behalf of Professional:
( c) Co\ er products and completed operations of Professional. premises O\\ ned. occupied. or used by the Professional. or automobiles owned. leased. or hired or borrowed b1 the Professional: contain no special limitations on the scope of protection afforded to City (d) Be primary v.ith respect to an) insurance or self:-insurance programs CO\ering Cit)' or Cit) ·s Agents and any insurance or self-insurance maintained b) Cit) or City"s Agents shall be in excess of Professional"s insurance and shall not contribute to it:
(e) Contain standard separation of insured provisions: and (t) State that an1 failure to comply \Vith reporting or other provisions of the policy including breaches of v.arranties shall not affect the coverage provided to City.

Section 26. Indemnification by Professional. To the fullest extent permitted by la\v (including. without limitation. California Civil Code sections 2782 and 2782.8). Professional shall defend v\ith legal counsel reasonably acceptable to City. indemnify and hold harmless the City and City·s Agents from and against any and all claims. loss. cost. damage. injury (including. ,\ithout limitation. injury to or death of an employee of Professional or its subcontractors). expense and liability of every kind. nature and description that arise out of. pertain to or relate to acts or omissions of Professional. or any direct or indirect subcontractor. employee. contractor. representative or agent of Professional. or anyone that Professional controls (collectively ·•Liabilities.. ). Such obligations to defend. hold harmless and indemnify City and City·s Agents shall not apply to the extent that such Liabilities are caused in whole b) the sole negligence. active negligence. or willful misconduct of City or City"s Agents. but shall apply to all other Liabilities.

PROFESSIO'sAL. SER\'ICES AGREEMEl\T
City of Ceres and Jay·s Tires

ITEM 10

ATTACHMENT I
With respect to third-party claims against the Professional. the Professional vvaives an: and all rights of any type of express or implied indemnity against City and City·s Agents.

Section 27. Liability of City. 1 otv\ithstanding any other provision of this Agreement, in no event shall City be liable. regardless of whether any claim is based on contract or tort. for any special. consequential. indirect. or incidental damages. including. but not limited to. lost profits or revenue. arising out of or in connection \\ith this Agreement or the Services performed in connection vvith this Agreement.

Section 28. Independent Contractor. At all times during the Term. Professional shall be deemed to be an independent contractor and shall be\\ holly responsible for the manner in which Professional performs the Services required under this Agreement. Professional shall be liable for its acts and omissions and those of its employees. contractors. subcontractors. representati,es. volunteers. and its agents. Nothing contained herein shall be construed as creating an employment. agency. or partnership relationship betv,een Cit) and Professional. City shall ha,e the right to control Professional on!) insofar as the result of Professional" s Services rendered pursuant to this Agreement: hovvever. City shall not ha,·e the right to control the means b) v\ hich Professional accomplishes Services rendered pursuant to this Agreement.

Section 29. Professional Not Agent. Except as City ma) specify in \-Hiting. Professional shall have no authority. express or implied. to act on behalf of City in any capacity '"hatsoever as an agent. Professional shall haH: no authority. express or implied. pursuant to this Agreement to bind City to any obligation whatsoe, er.

Section 30. Payment of Taxes and Other Expenses. Payment of an) taxes. including California sales and use taxes. levied upon this Agreement. the transaction. or the Ser\-ices or goods delivered pursuant hereto. shall be the obi igation of Professional.

Section 31. Notices. ;\ny notice or communication required hereunder bet,,een City and Professional must be in writing. and may be given either personally. by registered or certified mail ( return receipt requested). or by Federal Ex press. UPS or other sim i Jar couriers providing overnight delivery. If personally delivered. a notice shall be deemed to ha,e been given \\hen delivered to the Party to v,hom it is addressed. \Jotices given by registered or certified mail shall be deemed to have been given and received on the first to occur of (a) actual receipt by any of the addressees designated below as the pa11y to "" horn notices are to be sent. (b) on the date de! ivered as shov,n on a receipt issued by the courier. or (c) five (5) days alter a registered or certified letter containing such notice. properly addressed. v\ith postage prepaid. is deposited in the United States mail. If gi,en by Federal Express or similar courier, a notice or communication shall be deemed to have been given and received on the date delivered as shO\rn on a receipt issued by the courier. Any Pa11y hereto may at any time. by giving ten ( I 0) days written notice to the other Party hereto. designate any other address in substitution or the address to "' hich such notice or communication shall be given. Such notices or communications shall be given to the Pa11ies at the addresses in this paragraph set fo11h below:

If to City: City of Ceres
PROFESSIO�AL SERVICES r\GREEi'vlEi\T
City of Ceres and Jay·s Tires

ITEM 10
With counesy copies to:

Ifto Professional:

Section 32. General Provisions.

Attn: City Manager
2220 Magnolia Street
Ceres, California 95307
White Brenner LLP
Attn: Nubia I. Goldstein
1608 T Street
Sacramento, CA 95811
Jay's Tires
Attn: Cody Williams
29-t0 Geer Road
Turlock, CA 95382

ATTACHMENT I
A. Modification. No alteration. modification. or termination of this Agreement shall be valid unless made in writing and executed by all Parties.

B. Wai·ver. No CO'v enant. term. or condition or the breach thereof shall be deemed \\a i ved. except b: \, rittcn consent of the Part) against whom the ,\ ai, er is claimed. and an:, \vai, er of the breach of an:, covenant. term. or condition shall not be deemed to be a waiver of any preceding or succeeding breach of the same or any other covenant. term. or condition.

C. Assignment. No Party shall assign. transfer. or othen,ise dispose of this Agreement in V\ hole or in part to an::, individual. firm. or corporation \\ ithout the prior ,Hitten consent of the other Part:,. Subject to the forgoing pro\ is ions. this Agreement shall be binding upon. and inure to the benefit of. the respective successors and assigns of the Parties.

D. Governing Law. This Agreement shall be go\emed b: and construed in accordance with the la\,\s of the state or California.

E. Venue. Venue for all legal proceedings shall be in the Superior Court of California for the County of Stanislaus.

F. Counterparts. This Agreement may be executed in tvvo or more counterparts. each of v,hich shall constitute an original and all of which shall be deemed a single agreement.

G. Severability. [f this Agreement in its entirety is determined by a court to be in val id or unenforceable. this Agreement shall automatically terminate as of the date of final entry of judgment. If any pro\ is ion of this Agreement shall be determined by a court to be invalid and unenforceable. or if any provision of this Agreement is rendered invalid or unenforceable according to the terms of any federal or state statute. v, hich becomes effective after the execution of this Agreement by an) Party. the remaining provisions shall continue in full force and effect and shall be construed to give effect to the intent of this Agreement PROFESSIO:\AL SERVICES AGREE\ilEJ\iT
City of Ceres and Jay·s Tires

ITEM 10

ATTACHMENT I
H. Audit. City shall have access at all reasonable times to all reports. contract records. contract documents. contract files. and personnel necessary to audit and verify Professional's charges to City under this Agreement.

I. Entire Agreement. This Agreement sets forth the entire understanding between the Parties as to the subject matter of this Agreement and merges all prior discussions. negotiations. proposal letters or other promises. ,,hether oral or in writing.

J. Supersedes Prior Agreement. It is the intention of the Parties hereto that this Agreement shall supersede an1 prior agreements. discussions. commitments. or representations. ,, hether \Hitten. electronic or oral. between the Parties "' ith respect to the subject matter of this Agreement.

K. Headings �ot Controlling. Headings used in this Agreement are for reference purposes only and shall not be considered in construing this Agreement.

L. Successors and Assigns. A 11 representations. covenants. and vv arranties speciticall) set forth in this Agreement. b::, or on behalf of. or for the benefit of. any or all of the Parties hereto. shall be binding upon and inure to the benefit of such Party. its successors and assigns.
'.\I. Interpretation. As used herein. any gender includes each other gender. the singular includes the plural and vice versa.

N. Mandato� and Permissive. ··Shall.. and ··v, ill .. and ··agrees are mandatory. ··Ma)-·· and --can .
.
are permissi,c.

0. Attorney's Fees and Costs. Ir an: action at hm or in equit). including action for declaratory rel icf. is brought to en force or interpret pro\. is ions or this Agreement. the pre\ailing Party shall be entitled to reasonable attorney's fees and costs. which ma) be set by the court in the same action or in a separate action brought for that purpose. in addition to any other relief to v,hich such Party may be entitled.

P. Time is of the Essence. Time is of the essence in this Agreement for each covenant and term of a condition herein.

Q. Authority
. All Parties to this /\grcement wa1Tant and represent that they have the power and authorit) to enter into this Agreement and the names. titles. and capacities herein stated on behalf of any entities. persons. states. or firms represented or purported to be represented by such entities. persons. states or firms and that all former requirements necessary or required by the state or federal law in order to enter into the Agreement have been fully complied \\ ith. Further. by entering into this Agreement. neither Party hereto shall have breached the terms or conditions of any other contract or agreement to which such Party is obligated. v\hich such breach would have a material effect hereon.

PROFESSIO>JAL SERVICES AGREEi\.-lE�T
Cit) of Ceres and Jay·s Tires

ITEM 10

ATTACHMENT I
R. Drafting and Ambiguities. Each Pa11y acknO\\ledges that it has revie\\ed this Agreement \\ ith its own legal counsel. and based upon the advice of that counsel. freely entered into this Agreement. Each Party has participated fully in the revie," and revision of this Agreement. Any rule of construction that ambiguities are to be resolved against the drafting pa,ty does not apply in interpreting this Agreement.
[Signatures on Following Pagel
PROFESSIO'\Ji\L SERVICES AGREEME:s;T
City of Ceres and Jay's Tires

ITEM 10
• Speal-.er and siren installation (grille or e:--.ternal mount).

ATTACHMENT I
------ ---------------------�----

9. SOFTWARE & SYSTEM PROGRAMMING
• Programming and configuration or lighting controllers; (e.g .. Whelen. Code 3. Federal). • Radio programming ( if pennitted b: agenc: ).
• Integration of "v!DT sol't\,are. cameras. GPS. ALPR. and vehicle gate\\a) s. • Troubleshooting net\\ or!-. connect i\ it: and de\ ice interoperahi I it:.

10. QUALI TY CONTROL & TESTING
• Full': ,tern p1)\\er-on diagnostic:-..
• Load tests. , oltage drop t..:sts. and alternator capac it: \ eri tication. • Operational te,h for light-.. :-,iren-.. cameras. radios. :VID I. serbors. and K-9 ': steni--. • Road te:,t (if ,tut h1iri1eJ ).

11. DOCUMENTATION & DELI VERY
• As-built wiring. diagram-.. e4uipment location<s. fuse charts. :-,erial numbers. • \,\ arTant: documentation and user in:,tructio11:-,.
• Vehicle hand-mer inspection,, ith agency pcr<sonnel.
• Post-dcliwr: �upport and maintenance plans.

12. OPTIONAL ONGOI G SUPPORT
• Pre\ cnti\ e maintenance checks.
• Warranty service and repair.
• Lpgrades. add-ons. or reconfiguration for nc" missions or tel·hnolog:-.

PROFESSIO:---:,-\L SERVICES .-\GREE\,JE'\T
Cit� of Cere, and Ja� ·., I in:s

ITEM 10

ATTACHMENT I
IN WITNESS WHEREOF. the Parties have executed this Agreement as of the last day and date below written.

CITY:

CITY OF CERES. a California municipal
Date: DL\ I o-z..1 VYl..lo
Approved as to Form:

Nubia I. Goldstein, City Attorney
ATTEST:.
-�V\1�
Fallon Martin, City Clerk
CltyofCern
_...,._ . ....

PROFESSIONAL:
· fornia corporation
Date:

PROFESSIONAL SERVICES AGREEMENT
City of Ceres and Jay's Tires

ITEM 10

ATTACHMENT G
IN WITNESS WHEREOF, the Parties have executed this Agreement ns of the lust day and date below written.

CITY:

CITY OF CERES, a California municipal
corporation
By:

Douglas D. Dunford, City Manager
Date:

Approved as to Fol'm:
�( Nubi . Goldstein, City Attorney
ATTEST:.

Fallon Martin, City Cleric
City of Ceres
PROFESSIONAL:
l'<>M.IJC...-' �(I)/ !!!1#1111
Date: I/, 'f I ,l., ?if/

PROFESSIONAL SERVICES AGREEMENT
City of Ceres and Jay's Tires

ITEM 10

ATTACHMENT G

EXHIBIT A
Services

SCOPE OF WORK - LAW ENFORCEMENT VEHICLE UPFITTING

1. Project lntake & Planning
• Vehicle inspection upon receipt (condition. mileage. baseline electrical checks). • Review ofagenc) specifications. equipment lists. \\iring diagrams. and operational requirements.
• Develop an upfitting plan including equipment layout. wiring route. pO\\er load calculations. and safety considerations.
• Coordination \vith fleet managers and command staff regarding special requirements.

2. REMOVAL & PREPARATION
• Removal of OEM interior panels. seats. trim. headliners. and consoles as needed. • Preparation of mounting surfaces for equipment.
• Installation or modilication of partitions. cargo storages:, stems. or K-9 transport units.

3. ELECTRICAL SYSTEM INTEGRATlON
• Installation of primary and secondary power distribution systems. • Use of agency-approved \\ iring standards (proper gauge. color coding. fusing. circuit protection). • Batter) management systems. idle reduction tech. and load-shedding systems. • Grounding. bonding. and surge protection.

PROFESSIOl\AL SERVICES AGREEMEl\T
Cit) of Ceres and Jay ·s Tires

ITEM 10

4. EMERGE CY LIGHTING & WARNING EQUlPME T
• Lightbar installation (roof. interior. lo\,-profile as specilied).

ATTACHMENT G
• Front rear1interior lighb. grille lighh. corner strobe�. and integration of siren amplitiers. • Proper::,) nchroniza1ion of flash pattern:--: cornpliancl.' \\ ith state regulations. • Testing li.ir line-of-sight visibilit) and electrical reliabilit). - - - -----�---�------
s. COMMU !CATION & TECHNOLOGY SYSTEMS
• Radios (VII� 't...:H F 700-800 \.I Ill). mobile data terminals ( \,I DTs ). docking stations. • GPS. A \'L :-.) stems. Lo.lac!--. broadband modem::,. r,)utc>r:-.. \\.i-Fi. • In-car , idi.:o S) stemc; (fr
ont.rear. bod) cam intc>gration ).
• E:-;ternal antenna in::,tallat ion \\ ith correct grounding and roof reinforcement. ---------

6. CONSOLES & INTERIOR EQUIPMENT
• Install at ion nf center ct1nsoles. equi rment racb. arnm:scs. and organiLer S) stem-... • Sv.-icch panels. control heads. cup holders. and cable management. • Gun rad:-. (, c>rtical. l10ri1ontal. trunl---nrnunted) \\ ith ::,l.'cure \\ iring tor locks. ---------------- -

1. VEHICLE PROTECTION SYSTEMS
• Push bumper�. prisont'r panitions. rear :-.Cal comer-;ions. \\ indo\\ barriers. • K-9 units: temperature sensors. fan::,. alarms. clog compartments. door pop S) stems. • Skid plates. brush guard::,. protecti,e hou::,ings for sensitive electronics.

8. EXTERNAL EQUIPMENT INSTALLATION
• Spotlight:,. ALPR s:,.stem::,. radar units.
• License plate brackets. stealth lighting. rear deck lighting..

PROFESSIO'-..-\L SER\ ICFS .\GREE\IF'\T
Citj of Ceres and Ja) ·, Tire::,

ITEM 10
ITEM 10

COUNCIL AGENDA REPORT

CITY COUNCIL
Javier Lopez, Mayor
James Casey, Dist.1
Rosalinda L. Vierra, Dist. 2
Cerina Otero, Dist. 3
Daniel A. Martinez, Dist. 4
MEETING DATE: April 13, 2026
TO: Mayor and City Council
FROM: Trenton Johnson, Acting City Manager
CONTACT: Joshua Casas, Deputy Director of Public Works
[email protected], (209) 661-6352
SUBJECT: Public Works Monthly Report for February 2026
RECOMMENDED COUNCIL ACTION:

Information only, no action required.

I. BACKGROUND:

Outlined below are the significant actions performed by the Public Works Department for the month of February 2026.

FACILITY SERVICES:
• Completed 49 Facilities Maintenance orders including: 22 service requests for electrical/lighting, plumbing repairs, HVAC issues, locksmith tasks, general repairs, and 27 preventive maintenance services.
• Community Center, install outdoor monitor for council agenda • Fire Station #17, installed 2 new App. Bay heaters
• Fleet, new shop heater installed
• Fire Station #15, installed air dryer for air compressor system • Whitmore House, service fire alarm system
• Custodians cleaned and disinfected all city facilities including trash and liter pick up in all parks
• Continued clean-up homeless camps at Independence Park and Roeding Park with the assistance of Code Enforcement.

Maintenance activities performed by (1) Supervisor, one (0) Senior Maintenance Worker, one (1) Facility Maintenance Worker and three (3) Custodians., one Facility Maintenance position vacant and one Custodial position vacant and one custodian out sick this month ITEM 11
FLEET SERVICES:

Completed 105 work orders.

Fleet, Department 20
• 2 Services

Fire, Department 15
• N/A
Police, Department 10
• Performed 46 Vehicle repairs
• Replace Front Differential in unit 112
• Service and repair S.W.A.T. Vehicle
Streets, Department 30
• Performed 17 Vehicle repairs
• Perform 90-day inspection on street sweepers
• Service and repair Street Sweeper 30-516-23
• Replace Tires on Street Sweepers
Water, Department 35
• Performed 12 Vehicle Repairs
• Replace Nox sensor on unit 32-243-11
• Repair Ditch Witch vacuum
Parks, Department 40
• Perform 3 vehicle repairs
• Repairing Small equipment
Wastewater, Department 25
• Perform 19 vehicle repairs
• Perform 90 inspection on unit 25-225-23
• Service John Deere Tractor 25-415-15
Facilities, Department 41
• 4 vehicle repairs
Emergency and non-emergency City vehicles and equipment are maintained and repaired by one (1) Supervisor, two (2) Maintenance Mechanics, one (1) Vacant Senior Fleet mechanic position.

LANDSCAPE MAINTENANCE:

Completed a total of 223 service requests in the following categories:
• Bike Path Repairs: 1
• City Grounds Maintenance: 4
• Park Landscape and Maintenance: 154
ITEM 11
• Parks Landscape chemical usage: 250 gallons used & 250 Merit • Playground and Equipment Repairs; Several playground parts that were ordered are within 120-day lead time for delivery; repair work will follow pending delivery. • Playground and Equipment Inspections: 13 plus 3 repairs. • Right of Way (ROW) Irrigation Repairs: 83 sprinklers. 4 valves • Park Trees: 8 Trimmed, by parks crews.
• Customer Requests Tree or Limb Down: 3
Parks sprinklers repaired or replaced:
• Barry Grove – 1 maintenance
• Costa Fields – 0 maintenance. Reviewed Scada with them • Don Pedro – 1 vandalism.
• Independence – 3vandalisms.
• Ochoa Park – 45 maintenances. Removed 33 5000s added 12 6504 • Dog Park – 0 maintenance.
• Neel Park – 2 maintenances.
• Persephone – 2 maintenances.
• Redwood – 0 maintenance.
• River Bluff – 4 vandalisms.
• Riverview – 1 vandalism.
• Roeding Heights – 3 maintenances.
• Sam Ryno – 1 maintenance.
• Smyrna – 8 vandalisms.
• Strawberry – 1 maintenance.
• Whitmore – 3 vandalisms.

Parks General Maintenance/Repairs:
• Graffiti removal at Sam Ryno (1), Strawberry (2), River Bluff (6), Roeding (2), Ochoa (3) Persephone (2), Smyrna (21), Don Pedro (2) Riverview (2) and Independence Park (3) Whitmore (5) By Parks crew
• WCA Currently handling emergency tree requests.
• Grid Prune Program is on hold due to FY 25-26 budget
Grounds
Rights of Way (ROWs):
• All ROW irrigation is turned on as inspections are being made. • Truck accident at 5th Street roundabout. Damaged Back flow, controller, meter and signs at location. PD took report.

Parks
City Parks:
• Treated River Bluff, Don Pedro and Riverview Trees for aphids. 250 gallons Sam Ryno:
• Sidecar motorcycle damaged. Part ordered quote.

ITEM 11
Smyrna Park:
• 15 trees stakes repaired.
• Playground 2/5 replaced ABC wheel from vandalism.

Costa Fields:
• Field irrigation was turned off due to field lighting improvement project.

Neel Park:
• No update
Roeding Park:
• Continue Flushing irrigation well due to sand sediment. Filter unit is at the Corp Yard and ready to install.
• Changed 3 sprinkler heads due to sand.

Persephone:
• Closed open holes in playground for excessive wasp nest inside tower.

Independence Park:
• Playground closed due to Fire. Pending insurance claims for reimbursement. • Fixed fence due to vandalism.
• Painted 2 trees for graffiti.

Riverview Park:
• Damaged 5/12 slide entrance area. Replaced with temporary fence. • Waiting on Playground parts for repairs due to vandalism.

River Bluff Park:
• Repaired gate at entrance to lower area, due to vandalism 3 times • Trimmed 6 trees.
• # goals vandalized.

Guillermo Ochoa Park:
• Continue installing 25-6504 more sprinklers for better coverage. • Changed 33 and added 12 6504 sprinklers.
• Still experiencing SCADA communication issues.
• Playground damaged vandalism. Elliptical Walker Replaced City Parks Landscaping and Maintenance is performed by one (1) Supervisor, one (1) Sr.

Parks Maintenance Worker, and Five (5) Park Maintenance Workers.

SOLID WASTE & RECYCLING:
• Highlights of solid waste and recycling collection by Bertolotti for February 2026:
▪ Residential…………………….… 1,107.53 tons
▪ Commercial………………………. 1,651.13 tons
ITEM 11
▪ Illegal dump/litter abate (code enforcement) 8.03 tons ▪ Illegal dump/litter abate (Public Works staff) 2.73 tons 15 locations ▪ Illegal dump (Bertolotti) ………. 3.24 tons, 12 locations ▪ Bulky items…………………….… 34.97 tons, 132 locations
▪ Bulky recycling………………….. 1.84 tons
▪ Leaf/limb ………...…………….… 5.72 tons
▪ Street Sweep………………….… 91.75 tons
▪ Residential Organics…………… 472.84 tons
▪ Commercial Organics…………. 119.46 tons
▪ Residential Recycle………….… 142.61 tons
▪ Commercial Recycle …………… 125.65 tons
▪ C&D (Construction/Demolition Debris) 93.14 tons
▪ Used oil…………………………… 324 gallons
▪ Used oil filter……………...……… 59
.
• There were 15 residential and commercial cart violations issued in February. • There were 43 Leaf & Limb Program violations issued in February by Public Works staff. • There were 3 requests for the off-season residential leaf & limb collection service offered by Bertolotti Disposal in February.
• The seasonal Leaf & Limb collection program ended on January 9th. Any piles left out after that date are subject to illegal disposal enforcement. For residents who have a need for additional off-season leaf & limb debris collection, additional services can be scheduled by contacting Bertolotti Disposal.
• The annual Community Free Disposal Day was held on Saturday, February 7th, 2026, at the River Bluff Regional Sports Complex from 8am to 11:45am. The event was the largest to date and had 541 vehicles participate.

Total material collected and event participation information are listed below.

Number of (40 yd) Bin Hauls = 25
• Total Weight = (139,000 lbs.) 69.5 Tons
• Number of Tires Collected = 913
EWASTE
• CRT's = 1834 lbs
• Flat Panels = 1834 lbs
• UWED = 6608 lbs
• towers = 736 lbs
• printers = 470 lbs
• laptops/phones/tablets =80 lbs
Solid Waste Division work is performed by one (1) Administrative Analyst.

STREETS SERVICES:
• Staff responded to 67 customer service requests
• Staff responded to 286 USA’s
ITEM 11
• Cleaned 27 DI’s
• Cleaned 6 French Drains
• Cleaned 6 Drywells
• Cleaned 5,685’ of storm drain pipeline
• Patched 296 potholes
• Repaired 31 Streetlights
• Responded to 11 locations for blight and graffiti removal • Disposed of 5,460 pounds of blight
• Deployed message boards for city community disposal event • 3 Staff members worked at the city community disposal event Streets Division maintenance is performed by one (1) Supervisor, two (2) Sr. Maintenance Workers, (6) Streets Maintenance Operators, and one (1) Street Sweeper Operator (2) part time Streets/Code Enforcement Maintenance workers.

WASTEWATER (WRRF):
• Responded to 5 customer service requests and 44 sewer problems, during working hours and after hours.
• Staff responded to 4 Smart Cover alerts & alarms that prevented Sanitary Sewer Overflows (SSO’s).
• Serviced or Repaired:
• Lift Stations – 16
• WWTP Equipment – 19
• Main line sewer plugs – 0
• Aerators – 2
• Staff inspected the forced main to Turlock.
• Staff cleaned 29,703 feet of sewer main line.
• Staff CCTV inspected 11,445 feet of sewer main line.
• Staff continues the process of updating the Wastewater Discharge Report (WDR), and Sewer Master Plan (SMP). Staff collected data, attended meetings & tours regarding the Ceres Water Resource Recovery Facility upgrades. • Staff assisted by Jeff Burrows trouble shot and repaired headworks plc and controls issues.
• RH Borden’s I&I study is concluded, they are preparing a final report. Areas identified to be of concern are being inspected in a targeted manner. 2 deficiencies have been found and rectified, which already had an impact on the storm water received in the sewer from the storm in February.
• Staff performed annual service on all city owned grease interceptors. • All wastewater generators had their annual service.
• Staff reinstalled Aerator R3-A2 and returned it to service. Currently 1 30HP aerator is in the shop being repaired.
• Staff are working on repairing and upgrading the headwork freshwater system.

This system is used to clean the equipment and facilities.

ITEM 11
• Santana Segura received his Wastewater Treatment Plant Operator Grade 1.

Currently all wastewater staff are certified operators. • City of Turlock sewer usage charge for the month of January $103,756.90 • City of Modesto sewer usage charge for the month of December $145,164.59 & January $143,460.53
• Effluent Biochemical Oxygen Demand (BOD) 49 mg/L.
• The Wastewater Treatment Plant treated and disposed of 75.40 MG (Million Gallons) of wastewater with an average of 2.43 MGD (Million Gallons per Day).

Ceres Wastewater Treatment Plant and Collections System operations and maintenance are performed by one (1) Supervisor, two (2) Sr. Wastewater Operators, two (2) Operator II, three (3) Operator I. Two (2) unfilled Wastewater Operator positions.

WATER SYSTEM MAINTENANCE:

Water, Department 35
• February 2026 well production was 22.5 million gallons. • Treated Water delivered from SRWA was 84 million gallons. • Average daily water use for February was .802 million gallons per day. • Water staff responded to 21 customer service requests. • Water staff responded to 97 Underground Service Alerts (USA) markings. • Meter statistics and repairs:
• Meters in water distribution system: 11,917
• Meters/radios serviced: 103
• Meters replaced: 16
• Meters upgraded from ¾”, 5/8” to 1”: 3
• Total valves in water distribution system: 4,402
• Blow-offs and hydrants flushed: 1
• Service line leaks: 2
• Service lines replaced: 4
• Hydrants replaced or reset: 0
• Water quality samples taken: 52
The 6th Street watermain replacement is still underway, as is the transmission line extension on Hatch Road.

Water Conservation, Department 36
• February 2026 calculated residential gallons used per person per day: 49.92 gallons
• Annual average is 72.40 gallons per person per day
• Responded to 18 water conservation service requests
• Water portal has 489 residents registered, which is 9 more than the previous month • Issued courtesy notifications: 36
• Performed 0 water audits
ITEM 11
• Delivered 5 water waste warnings and issued 1 water waste fine. • Rebates Issued: Dishwasher: 0, Smart Irrigation: 0, ULF Toilets: 4, Washing Machine: 1, and Turf Replacements: 1
• Total Rebates FYTD: 27
In previous reports, staff have reported water production data compared to a target-use capped total objective of 3,591 million gallons. The state has shifted away from targetbased use and moved to what is called objective-based use. Under the “Making Water Conservation a California Way of Life” regulations, urban water suppliers are now mandated to calculate an Urban Water Use Objective (UWUO). The UWUO is a water efficiency target set by the state to help cities and water suppliers use water more wisely.

It tells each agency how much water they should be using based on local conditions like population, climate, and land use. The chart below compares 2026 production data to date with the most recent UWUO.

Water system maintenance is performed by one (1) Superintendent, one (1) Supervisor, one (1) Administrative Analyst, two (2) Senior Water Operators, nine (9) Water Distribution Operators, two (2) Field Service Technicians, and one (1) Water Conservation Officer. There are currently two vacancies for Water Distribution Operator; one of which is due to promotion.

Approved by: _________________________
Trenton Johnson,
Acting City Manager
ITEM 11

COUNCIL AGENDA REPORT

CITY COUNCIL
Javier Lopez, Mayor
James Casey, Dist.1
Rosalinda L. Vierra, Dist. 2
Cerina Otero, Dist. 3
Daniel A. Martinez, Dist. 4
MEETING DATE: April 13, 2026
TO: Mayor and City Council
FROM: Trenton Johnson, Acting City Manager
CONTACT: Michael Beltran, City Engineer
[email protected]
SUBJECT:

Resolution No. 2026-XXX, Approving the Certification of the Environmental Impact Report for the Copper Trails Specific Plan and Annexation Project, Adopting the Mitigation Monitoring and Reporting Program, and Adopting the California Environmental Quality Act (CEQA) Findings of Fact, Including a Statement of Overriding Considerations
Resolution No. 2026-XXX, Approving an Amendment to the Ceres General Plan Land Use Map to Reflect the Land Uses Contained in the Copper Trails Specific Plan Area and Existing Land Uses in the Pocket Area
Ordinance No. 2026-XXXX, Approving the Pre-Zoning for the Copper Trails Specific Plan Area and Pocket Area Located within Unincorporated Stanislaus County, and Amending the City’s Zoning Map Accordingly
Resolution No. 2026-XXX, Adopting the Copper Trails Specific Plan and Associated Public Facilities Financing Plan
Resolution No. 2026-XXX, Authorizing Staff to Make and Execute Any and All Necessary Documents and Applications to the Stanislaus County Local Agency Formation Commission for Annexation of the Copper Trails Specific Plan Area and Pocket Area
ITEM 13
RECOMMENDED COUNCIL ACTION:

Staff recommends that the City Council take the following actions regarding the Copper Trails Specific Plan and Annexation Project:

1. Adopt a Resolution approving the certification of the Environmental Impact Report for the Copper Trails Specific Plan and Annexation Project, adopting the Mitigation Monitoring and Reporting Program, and adopting the California Environmental Quality Act (CEQA) Findings of Fact, including a Statement of Overriding Considerations; and

2. Adopt a Resolution approving an amendment to the Ceres General Plan Land Use Map to reflect the land uses contained in the Copper Trails Specific Plan area and existing land uses in the Pocket Area; and

3. Adopt an Ordinance approving the Pre-Zoning for the Copper Trails Specific Plan Area and Pocket Area located within unincorporated Stanislaus County, and amending the City’s Zoning Map accordingly; and

4. Adopt a Resolution adopting the Copper Trails Specific Plan and associated Public Facilities Financing Plan; and

5. Adopt a Resolution authorizing staff to make and execute any and all necessary documents and applications to the Stanislaus County Local Agency Formation Commission for annexation of the Copper Trails Specific Plan Area and Pocket Area.

I. BACKGROUND:

The proposed project is located along the southern edge of the City of Ceres in unincorporated Stanislaus County, west of State Route 99 and primarily south of Service Road. It consists of 681-acre Project Area that is comprised of two smaller geographic areas; the Copper Trails Specific Plan (CTSP) area and the Pocket Area. The Project Area is within the City’s Sphere of Influence and the General Plan acknowledges this as an area for future City expansion by establishing preliminary land use designations within it.

In February 2023, in response to a request from a property owner in the CTSP area, the City initiated a formal process to prepare a Specific Plan, Public Facilities Financing Plan, and Environmental Impact Report (EIR) for the proposed project. In September 27, 2023, the City issued a Notice of Preparation for an Environmental Impact Report (EIR) and the Planning Commission held a public scoping meeting in October 2023 to receive comments regarding the scope of the environmental analysis.

Shortly thereafter, a Specific Plan and EIR were prepared, along with several supporting technical studies including a Public Facilities Financing Plan, Fiscal Impact Analysis, Utility Master Plans, Traffic Impact Analysis, and other analyses needed for the EIR. In December 2024, a draft Specific Plan and EIR were released for public review over a 45- day comment period. After receiving public comments, responses to each were prepared and incorporated into a Final EIR, which was released in February 2026 for public review.

The proposed project includes the following components:
• An Environmental Impact Report that evaluates the effects of the project consistent with the California Environmental Quality Act (CEQA);
ITEM 13
• A General Plan Amendment to update the General Plan land use diagram consistent with the CTSP and existing land uses in the Pocket Area; • An amendment to the Zoning Map to pre-zone the Project Area with zoning districts that are defined in the Ceres Zoning Ordinance;
• A Specific Plan to establish the regulatory framework for development of a 535-acre land area with residential, commercial, park, public, and other urban uses; and • An Annexation to incorporate the 681-acre Project Area into the City of Ceres.

On March 2, 2026, the Planning Commission held a public hearing to consider the proposed project. After receiving a presentation from staff and hearing comments and testimony from the public, the Planning Commission deliberated and voted unanimously 4-0 (one Commissioner absent) to recommend that the City Council approve the proposed project.

The components of the project and supporting analysis is provided below:

GENERAL PLAN AMENDMENT
The 681-acre Project Area is currently located outside the City limits in unincorporated Stanislaus County. In order to establish the land uses for this area, an amendment to the City’s adopted General Plan land use diagram is required and would apply to the entire Project Area.

EXISTING AND PROPOSED LAND USES
Existing land use designations in the Project Area, as depicted on the Stanislaus County General Plan Land Use Map, consist of a mixture of Urban Transition, Agriculture, Commercial, Industrial, Low Density Residential, Medium/High Density Residential, and Planned Development. These designations are reflective of existing uses.

Although located in the County, the Project Area is within the City of Ceres’ Sphere of Influence (SOI) and General Plan planning area. As such the City’s General Plan includes preliminary land use designations for the Project Area in recognition that it is a logical area for the City to expand and accommodate additional urban growth. These designations consist of a mixture of Regional Commercial, Neighborhood Commercial, Community Commercial, School, Light Industrial, Low Density Residential, Medium Density Residential, Medium-High Density Residential, High Density Residential, Park and Open Space, and Community Facilities. The General Plan’s preliminary land uses established for the Project Area were previously evaluated in the Ceres General Plan 2035 EIR certified by the City in April 2018.

The General Plan land use diagram would be modified to be consistent with the land use map provided in the CTSP and with existing land uses in the Pocket Area. Land use designations would utilize the General Plan’s existing designations and definitions.

ANALYSIS OF GENERAL PLAN AMENDMENT
The City of Ceres General Plan serves as the long-term policy guide for the physical and economic development of the City. The City’s core values are the foundation of the ITEM 13
General Plan and the underlying basis for its vision and direction. As such, the General Plan includes a framework of goals and policies to implement these core values.

The proposed amendment to the General Plan Land Use Map has been evaluated for consistency with General Plan policies as discussed below:
• Policy 2.A.1 Land Use Designations. Enact the land use designations as shown in Figure 2-3: Land Use Diagram and detailed in Section 2-3 for the purposes of this General Plan; and
• Policy 2.A.2 Prioritize Growth in SOI. Prioritize growth within the Ceres Sphere of Influence. Permit development outside of the Sphere of Influence only when there is a demonstrated need for additional land and there is less than a five-year supply of appropriately designated land within the existing Sphere of Influence, in accordance with Stanislaus Local Agency Formation Commission (LAFCO).

Analysis: Although Ceres does not have jurisdiction in areas outside of its city limits, these areas have bearing on the City’s planning and must be considered in the General Plan, per California Government Code Section 65300. The General Plan’s Planning Area includes preliminary land use designations for properties that may see new development in the future. Additionally, it identifies opportunity sites that have the potential to accommodate new development within the planning horizon. The Project Area includes many opportunity sites as identified on Figure 2-2 of the General Plan.

The proposed land use designations for the Project Area, both in the CTSP and the Pocket, are consistent with the preliminary land use designations shown on the General Plan’s Land Use Diagram in Figure 2-3, consistent with Policy 2.A.1.

Additionally, the entire Project Area is located in the City’s Sphere of Influence and the new land use designations would prioritize growth in the City’s SOI, consistent with Policy 2.A.2.
• Policy 2.A.11 Prioritize Development with Community Benefits. Prioritize development projects that are needed to provide for the City’s fair share of regional housing needs, including very-low- and low-income housing, or provide substantial benefits to the community, including, but not limited to, unique economic development opportunities (e.g., substantial number of jobs, substantial sales tax revenues).

Analysis: The proposed land use designations would encourage development of new commercial areas so that residents have greater access to retail establishments and need not travel outside of the city to shop. They would also encourage a greater range of housing options to meet the needs of families, young people, senior citizens, and residents of all incomes. This would result in development that benefits the community and City at large, consistent with Policy 2.A.11.

Based on the analysis and findings above, staff recommends that the City Council approve an amendment to the Ceres General Plan Land Use Diagram to reflect the new land uses in the Project Area.

PRE-ZONING & ZONING MAP AMENDMENT
The 681-acre Project Area is currently located outside the City limits in unincorporated Stanislaus County. In order to establish zoning districts for this area, a “Pre-Zoning” action and an amendment to the City’s Zoning Map are required. Pre-zoning the Project ITEM 13
Area is required prior to the City filing an application to LAFCO for the proposed annexation. An amendment to the Zoning Map would occur after LAFCO’s approval of the annexation, which would effectuate the new zoning districts on properties in the entire Project Area.

EXISTING AND PROPOSED ZONING DISTRICTS
Existing zoning districts in the Project Area, as depicted on the Stanislaus County Zoning Map, consist of a mixture of Rural Residential, Multiple Family, Medium Density Residential, General Commercial, Industrial, General Agriculture 10 Acre Urban Transition, General Agriculture 40 Acre, and Highway Frontage. These zoning districts are reflective of existing uses in the Project Area.

The proposed pre-zoning of the Project Area would allow all properties in the annexation area to establish new zoning districts that align with the districts and definitions contained in the City’s Zoning Ordinance. See Figure 1 below for location of zoning districts and Table 1 below for zoning acreage summary.

Figure 1: Proposed Pre-Zoning and Zoning Map Amendment
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Table 1: Pre-Zoning District Summary
In the 146-acre Pocket Area, new zoning districts would consist of a mixture of SingleFamily Residential (R-1), Medium Density Residential (R-3), Medium-High Density Residential (R-4), Neighborhood Commercial (C-1), Community Commercial (C-2), and Light Industrial (M-1) uses, which would be applied to properties consistent with their existing uses.

In the 535-acre CTSP area, the Planned Community (P-C) zoning district would be applied to all properties irrespective of their existing use. As outlined in Chapter 18.13 of the Ceres Municipal Code, the purpose of the P-C zone district is to allow projects such as Copper Trails to be master-planned and to allow variations to the Zoning Ordinance’s typical standards. The intent is to custom-tailor the development plan’s regulatory structure in a manner that achieves the community vision and results in a built environment that is superior to what could be created under the application of the Zoning Ordinance’s typical regulations. As such, the CTSP functions as the Plan Area’s primary implementation and regulatory tool.

Upon annexation of the Project Area to the City of Ceres, the pre-zoning would take effect and the City’s Zoning Map would be amended to reflect the new zoning districts shown in Figure 1 above.

ANALYSIS OF PRE-ZONING & ZONING MAP AMENDMENT
The proposed pre-zoning and Zoning Map amendment have been evaluated for consistency with the City’s Zoning Ordinance, as discussed below:
• Zoning Ordinance Section 18.05.100 (Zoning Annexed Areas). This section establishes the requirements for zoning for areas to be annexed into the City. It includes a process to pre-zone the properties in an unincorporated area with a zone classification that is consistent with the General Plan land use designation.

Analysis: The proposed zoning districts for both the Pocket Area and the CTSP area, as described above and shown on the Pre-zoning exhibit, are consistent with the ITEM 13
proposed General Plan land use designations as required by the City’s Zoning Ordinance.
• Zoning Ordinance Chapter 32 (Amendments). This chapter establishes the requirements and procedures to amend the City’s Zoning Ordinance and/or Zoning Map. It recognizes that through implementation of the City’s General Plan, the need may arise to make changes in zoning boundaries and other regulations in the title. It further indicates that the Zoning Ordinance may be amended whenever the City Council deems that such amendment is required for the general health, safety, and welfare of the City of Ceres. Amendments include any measures to change zone boundaries, establish or disestablish zones, to change zone regulations, and to add, repeal or amend any other provisions of this title. It also establishes a public process, through hearings with both the Planning Commission and City Council, for which amendments to the Zoning Ordinance and/or Zoning Map are required to follow.

Analysis: The proposed project includes a General Plan Amendment and a Specific Plan that have land use designations and zoning districts that must remain internally consistent with one another. Part of this consistency is to establish zoning districts for the Project Area that align with the land uses in the General Plan and CTSP. The proposed zoning districts for both the Pocket Area and the CTSP area, as described above and shown on the Pre-zoning exhibit, are consistent with the proposed General Plan land use designations, as amended herein. Additionally, by holding public hearings with both the Planning Commission and City Council, the process to amend the Zoning Map is consistent with the requirements of Chapter 32 of the Zoning Ordinance.

Based on the analysis in this staff report, the following findings can be made:

1. The proposed pre-zoning and amendment to the Zoning Map for the Project Area are consistent with the purpose and intent of the applicable goals and policies of the City of Ceres General Plan and the Copper Trails Specific Plan;

2. The proposed pre-zoning and amendment to the Zoning Map for the Project Area will have no adverse effect on properties under the City's jurisdiction; and

3. This proposed project was reviewed pursuant to the California Environmental Quality Act (CEQA).

Based on the analysis and findings above, staff recommends that the City Council approve the proposed Pre-zoning for the Project Area and amend the City’s Zoning Map accordingly once annexation is complete.

SPECIFIC PLAN
The Copper Trails Specific Plan (CTSP) establishes a development framework for the 535-acre Plan Area and addresses aspects of land use, circulation, parks and recreation, public utilities, public services, phasing, financing, and implementation. Development regulations are provided for residential and commercial land uses to establish the permitted uses and development standards applicable to the Plan Area. Design Guidelines have been incorporated to provide design guidance for streetscape and neighborhood design. Finally, the CTSP incorporates a Public Facilities Financing Plan by reference, which provides a funding strategy for the construction and maintenance of public infrastructure and facilities.

ITEM 13
Implementation of the CTSP would allow development of:
• 988 single-family residential units on approximately 178 acres designated as Low Density Residential;
• 338 single-family residential units on approximately 38 acres designated as Medium Density Residential;
• 336 residential units on approximately 17 acres designated as Medium-High Density Residential;
• 730 multi-family units on approximately 29 acres designated as High Density Residential;
• Nearly 1.2-million square feet of non-residential uses on approximately 107 acres designated as Regional Commercial;
• Five neighborhood parks and several greenbelt corridors on approximately 42 acres designated as Parks & Open Space; and
• Community facilities on approximately 3 acres.

The CTSP also establishes a “School” land use designation for existing school sites in the Plan Area – uses that will remain. These consist of Central Valley High School, Ceres Adult School, and Hidahl Elementary School, all operated by the Ceres Unified School District (CUSD). The CTSP Land Use Plan is shown in Figure 2, below.

Refer to the Copper Trails Specific Plan document for additional information regarding land uses, development regulations, planned improvements for roadways, trails, streetscapes, utilities, and public services, along with all other aspects of the proposed project. A copy of the CTSP is attached to this staff report and is available to view on the City’s website at: https://www.ceres.gov/1798/Copper-Trails-Specific-Plan Figure 2: Land Use Plan
ITEM 13

PUBLIC FACILITIES FINANCING PLAN
A Public Facilities Financing Plan (PFFP) was prepared for the CTSP. It outlines the cost for all planned backbone infrastructure needed to serve development of the CTSP area.

It also incorporates a plan and associated funding mechanisms to construct public facilities. Funding mechanisms include City and County Impact Fees, School Impact Fees, developer financing, Community Facilities District(s), Homeowners’ Association(s), and other methods. A brief overview of Copper Trails’ financing strategies is provided in Chapter 10 of the CTSP. A copy of the CTSP PFFP is attached to this staff report and is available to view on the City’s website at: https://www.ceres.gov/1798/Copper-TrailsSpecific-Plan.

SPECIFIC PLAN ANALYSIS
The proposed Copper Trails Specific Plan has been evaluated for consistency with General Plan policies as discussed below:
• Policy 2.A.6 Range of Housing. Ensure that a range of residential densities and housing types, including small-lot single family, move-up, townhouses, apartments, accessory dwelling units, affordable housing, senior housing, and condominiums, is available to accommodate the housing needs of all residents.

Analysis: The CTSP’s residential uses support an array of housing types by utilizing several residential land use designations that collectively encourage a diverse mix.

This is comprised of LDR, MDR, MHDR, and HDR designations that each have a unique density range that allows for a mixture of lot sizes that can accommodate a variety of single-family and multi-family housing types. The CTSP would facilitate construction of a wide range of housing consistent with Policy 2.A.6. • Policy 2.F.1 Traditional Neighborhood Design. Promote the development of compact, complete neighborhoods that locate services and amenities within walking and biking distance of neighborhood residents, allowing people to meet their daily needs close to their homes.
• Policy 2.F.2 Neighborhood Interaction. Promote opportunities for neighborhood interaction with pedestrian-oriented streetscapes and urban design, as well as public spaces for meeting and gathering.
• Policy 2.F.4 Multi-Modal Accessibility. Maximize accessibility for automobiles, cyclists, and pedestrians.

Analysis: CTSP Chapter 9 includes Design Guidelines that address neighborhood design, with the intent to create residential areas that develop as a collection of neighborhoods that are walkable and well-connected. The Guidelines also include provisions for neighborhood and subdivision design to provide cross connectivity for automobiles, bicyclists, and pedestrians. Additionally, Chapter 6 provides a master plan for the construction of several neighborhood parks that are linked by a network of greenbelts that include multi-modal trails and paths to encourage neighborhood interaction and enhance multi-modal access throughout the Plan Area. These provisions collectively implement Policies 2.F.1, 2.F.2, and 2.F.4. • Policy 2.I.2 Area-wide Plans. Use area-wide plans (i.e., master plans or specific plans) to comprehensively plan for new neighborhood developments.

ITEM 13
Analysis: As described above, the Copper Trails Specific Plan provides a comprehensive regulatory framework to implement long-term development activity in the Plan Area, with plans for land uses, circulation, parks and recreation, utilities, and public services, consistent with Policy 2.1.2.
• Policy 2.I.3 Fiscal Responsibility. Require new development to pay for its fair share portion of costs of impacts on infrastructure.

Analysis: The CTSP incorporates a Public Facilities Financing Plan (PFFP) that provides the estimated costs to construct identified public improvements needed to facilitate development in each of the four development areas identified in the Specific Plan. It also describes the proposed funding mechanisms to fund those costs. The overall costs and funding sources in the Financing Plan have been estimated for the purpose of providing feasible financing strategies and mechanisms to construct the backbone infrastructure and public facilities required for CTSP development. The development, costs, and funding sources in this Financing Plan are based on the best information available at the time of preparation and may require updating as development progresses. Implementation of the PFFP is consistent with Policy 2.I.3. • Policy 2.L.1 Design Guidelines. Ensure quality design by adopting simple and effective Design Guidelines that clearly express desirable, in addition to discouraged, outcomes.
• Policy 2.L.5 Single-Family Residential Design. Ensure architecture and landscaping in single family residential projects contribute to a neighborhood identity with visual interest and variety.
• Policy 2.L.11 Regional Commercial Design. Ensure development in the Regional Commercial land use designation provides a commercial destination and other development attractive to the regional market.

Analysis: CTSP Chapter 9 includes Design Guidelines that address both residential and commercial development in the Plan Area. For residential development, the Guidelines provide clear objectives to ensure that residential neighborhoods are wellconnected, and that home design is architecturally harmonious in and of itself. They also provide design guidance to ensure that neighborhoods will be distinguishable in the community by encouraging living spaces to be oriented towards the street, to deemphasize the appearance of garages, and to include a variety of architectural details with a broad range of materials and colors.

For commercial development, the Guidelines ensure that the development of the Regional Commercial sites is appropriately designed to fit harmoniously with the context and identity of Ceres’ established character. They include design guidance for site planning, general architectural character and style, building scale and massing, colors, materials and exterior finishes, and service, storage and refuse areas. The CTSP’s Design Guidelines include measures to encourage high-quality, attractive design, consistent with Policies 2.L.1, 2.L.5, and 2.L.11.

Based on the analysis and evaluation herein, staff recommends that the City Council approve the Copper Trails Specific Plan.

ITEM 13

ANNEXATION
The Project Area is located entirely in unincorporated Stanislaus County, outside of the City’s current limits. It is also located in both the Ceres Fire Protection District (CFPD) and the Keyes Fire Protection District (KFPD), both outside of the City of Ceres Fire Department’s service area. As such, the proposed project involves annexation of the 680.7-acre Project Area (244 parcels total) into the City of Ceres and includes detachment from the CFPD and KFPD to allow the area to become part of the Ceres Fire Department’s service area.

The Project Area subject to annexation is comprised of two smaller areas: (1) the 534.6- acre Copper Trails Specific Plan (CTSP) area, with 68 parcels located south of Service Road; and (2) the 146.1-acre “Pocket Area” with 176 parcels located north of the CTSP and south of existing City limits. As described in this staff report, the Copper Trails Specific Plan would establish a comprehensive development plan for the CTSP area.

However, no development proposals are currently being considered in the Pocket Area.

If this area were excluded from the annexation, it would create an “unincorporated island” surrounded by the City, which is inconsistent with LAFCO policy.

The proposed annexation area is contiguous to the existing southern boundary of the City of Ceres. It includes the existing Central Valley High School, Ceres Adult School, and Hidahl Elementary School sites, which are all within the CTSP Area. The Project Area is currently within the jurisdiction of Stanislaus County, however upon annexation, jurisdiction would transition to the City of Ceres.

Figure 3 below shows the location of the proposed annexation area, which identifies the two existing school sites in the Project Area.

Figure 3: Annexation Area
ITEM 13

ANALYSIS OF ANNEXATION
The Stanislaus County Local Agency Formation Commission (LAFCO) is responsible for processing annexation requests. LAFCO is a regulatory agency with countywide jurisdiction, established by State law (the Cortese-Knox-Hertzberg Act of 2000) to coordinate logical and timely changes in local City boundaries, and to ensure that public services can be provided. For the proposed project, the City of Ceres is the responsible entity to initiate an annexation application to LAFCO. However, before the City can consider an annexation request from an applicant, it must first demonstrate that the proposed annexation is consistent with General Plan policy and any other applicable City regulations.

The proposed Copper Trails Specific Plan has been evaluated for consistency with General Plan policy as evaluated below:
• Policy 2.I.1 Annexations. Approve annexations only after City approval of an appropriate area-wide plan (e.g., master plan, specific plan) that addresses land use, circulation, housing, infrastructure, and public facilities and services, based on the City’s annexation policy, while also adhering to the policies of the General Plan.

Analysis: The Copper Trails Specific Plan serves as an area-wide plan that establishes a development plan and regulatory framework that addresses land use, circulation, housing, utilities, and public services, consistent with Policy 2.I.1. The CTSP is included as one of staff’s recommended approvals for the proposed project. • Annexation Policy. The City Council adopted an Annexation Policy in August 1995 that establishes several requirements for annexations to the City. In summary, the Policy requires:

1. An area-wide plan that addresses land use, circulation, housing, infrastructure, public facilities and public services.

2. An Infrastructure Study that provides an analysis of the public facilities and infrastructure (streets, traffic signals, water supply system, waste water treatment system, parks, public safety facilities, etc.) needed to accommodate the proposed development.

3. A fiscal impact study that compares the on going, operating costs (maintenance and operations) to the city for the delivery of public services with the revenues generated by the projects that will be developed.

4. Cost sharing provisions for all property owners in the Planning Area and/or who may have a future benefit from the preparation of a master plan and subsequent annexation, to equitably share the costs for preparing and processing the various applications and studies associated with the area-wide planning effort.

Analysis: There are several components and entitlements of the proposed project that have been prepared to meet the requirements of this policy. First, the Copper Trails Specific Plan serves as an area-wide plan that establishes a development plan and regulatory framework that addresses land use, circulation, housing, infrastructure, and public services. Second, utility master plans have been prepared that address infrastructure requirements to serve the CTSP, including water, sewer, and storm drainage. Third, a Public Facilities Financing Plan, incorporated in the CTSP by reference, provides estimated costs to construct public improvements and outlines the funding mechanisms to fund construction. And finally, Chapter 10, Implementation, of ITEM 13
the CTSP establishes the framework for the City to adopt a Specific Plan Fee with cost sharing provisions whereby the project sponsor/Applicant can be equitably reimbursed by non-participating property owners who benefitted from the CTSP planning effort.

Based on the analysis and findings above, staff recommends that the City Council direct City staff to initiate an annexation and file an application with the Stanislaus LAFCO to annex the Project Area into the City.

II. REASONS FOR RECOMMENDATION:

The proposed project has been found to be consistent with the City’s General Plan and Zoning Ordinance, and the Environmental Impact Report has been found to be prepared in compliance with the requirements of the California Environmental Quality Act.

III. FISCAL IMPACTS:

Full implementation of the proposed project would result in a positive fiscal effect to the City, as outlined in the Public Facilities Financing Plan attached to this staff report and as demonstrated in the Fiscal Impact Analysis on file with the City.

IV. EXISTING POLICY / RELATIONSHIP TO THE STRATEGIC PLAN:

N/A
V. POLICY ALTERNATIVES:

N/A
VI. INTERDEPARTMENTAL COORDINATION:

Preparation, review and processing of the proposed project included the participation of multiple departments. The effort was lead by the Community Development Department, with assistance from the Engineering, Public Works, Finance, Fire, and Police departments.

VII. PUBLIC PARTICIPATION:

The City’s review and processing of the Copper Trails Specific Plan and related project entitlements occurred over several years, commencing in 2023. The key milestones of the City’s review process, including opportunities for public input, are summarized below:
• Project Application: In February 2023, the City initiated a formal process to prepare a Specific Plan, Public Facilities Financing Plan, and Environmental Impact Report (EIR) for the proposed project based on a request from the project proponent and applicant. • Notice of Preparation (NOP): On September 27, 2023, the City issued a NOP for an Environmental Impact Report (EIR), which was circulated for a 30-day public review period as required by CEQA.
• Scoping Meeting: On October 16, 2023, the Planning Commission held a public scoping meeting to receive comments regarding the scope of the environmental analysis to be evaluated in the Draft EIR.

ITEM 13
• Notice of Availability for Draft EIR & Specific Plan: On December 12, 2024, the City issued a Notice of Availability and opened a 45-day public comment period for the Draft EIR, which ended on January 27, 2025.
• Notice of Public Hearing: On February 6, 2026, the City issued a Notice of Public Hearing indicating that the Planning Commission would consider the Copper Trails Specific Plan and Annexation Project at a public hearing on March 2, 2026.

VIII. ENVIRONMENTAL REVIEW:

Environmental review and analysis of the proposed project consists of several different components. These are listed below and each one has been evaluated independently for consistency with the Ceres General Plan, Zoning Ordinance, and other applicable City regulations, as contained in this staff report:
• Environmental Impact Report
• General Plan Amendment
• Pre-Zoning and Zoning Map Amendment
• Specific Plan
• Annexation
ENVIRONMENTAL IMPACT REPORT (SCH #2023090637)
Acting as “Lead Agency” to evaluate the proposed project as required by the California Environmental Quality Act (CEQA) Guidelines, the City determined that an EIR is required. On September 27, 2023, the City released a Notice of Preparation (NOP) for the Copper Trails Specific Plan (CTSP) and Annexation Project (Project), which was circulated to the State Clearinghouse, Responsible Agencies, Trustee Agencies, other public agencies, and interested parties around the project site. On October 16, 2023, a public scoping meeting was held with the Planning Commission to provide an overview of the Project and to receive public comments regarding the scope of the environmental analysis to be included in the Draft EIR. The NOP comment period closed on October 26, 2023 and seven comment letters were received. Comments focused on topics including cultural and tribal resources, utilities and energy, agricultural resources, public services, stormwater quality, and biological resources. These comments are summarized in the EIR and each comment raised was addressed in the EIR’s analysis.

Subsequently, an Environmental Impact Report (EIR) was prepared to evaluate the proposed project and to determine what impacts could result if approved. Its purpose is to document existing environmental conditions in the Project Area, describe the potential environmental effects of approving and implementing a project, consider and recommend mitigation measures that could avoid or substantially reduce any identified significant environmental effects, analyze alternatives to a proposed project, and meet other applicable CEQA requirements. The EIR has been prepared in accordance with the requirements of CEQA and the State CEQA Guidelines.

The EIR is an informational document that does not, in and of itself, determine whether the Project should be or will be approved. The information that it contains is intended to support the decision-making process in order to facilitate a requested action by the City’s elected and appointed officials.

ITEM 13

TOPICS ANALYZED IN DRAFT EIR
The Draft EIR contains the following sections to describe and evaluate the project’s environmental effects, and it includes mitigation measures where appropriate and/or feasible that are intended to reduce potential effects to a less than significant level. The general scope and content of the Draft EIR addresses the following topics:
• Aesthetics
• Agricultural Resources
• Air Quality
• Biological Resources
• Cultural Resources
• Energy
• Geology and Soils
• Greenhouse Gas
Emissions
• Hazards and Hazardous
Materials
• Hydrology and Water
Quality
• Land Use and Planning
• Mineral Resources
• Noise
• Population and Housing
• Public Services
• Recreation
• Transportation/Traffic
• Tribal Cultural
Resources
• Utilities and Service
Systems
• Wildfire
• Cumulative Impacts
• Alternatives
• Other CEQA Issues
The EIR comprehensively evaluates each of these topic areas. It identifies the potential environmental impacts associated with each topic area and it defines required mitigation measures for each to the extent feasible.

Upon completion of the Draft EIR, the City issued a public Notice of Availability for the CEQA document and opened a 45-day public comment period that began on December 12, 2024 and ended on January 27, 2025. The City received nine written comments on the Draft EIR. The ninth comment from the Ceres Unified School District was received several months after the close of the review period, however it was addressed with the same rigor of all other comments.

FINAL EIR
After completion of the public comment period on the Draft EIR, a Final EIR was prepared.

The Final EIR serves as the ultimate informational and disclosure document required by the CEQA before the City can approve a project that may have significant environmental impacts. It includes several topic areas as required by State CEQA Guidelines. Key components include:
• A summary of the Draft EIR, together with any modifications resulting from responses to comments received.
• Copies of all written comments received on the Draft EIR, including a formal response to each substantive comment pertaining to the EIR content and/or its processing pursuant to CEQA.
• Any corrections and changes to the Draft EIR, including changes that address public/agency comments and any pertinent revisions originated by City staff.

The City received nine comment letters on the Draft EIR and responses to each are included in Section 3 of the Final EIR. Based on comments received, several modifications were made to the initial mitigation measures contained in the Draft EIR.

Revised mitigation measures are provided in Section 2 of the Final EIR, with text revisions shown in underline/strikeout format. Revised mitigation measures are provided in the final Mitigation Monitoring and Reporting Program attached to this staff report.

ITEM 13
In summary, the Final EIR does not identify any new significant environmental impacts or impacts that are substantially more severe than those that were identified in the Draft EIR.

MITIGATION MONITORING AND REPORTING PROGRAM (MMRP)
CEQA requires that a Lead Agency (City) adopt a Mitigation Monitoring and Reporting Program (MMRP) to ensure that all mitigation measures included in EIR are implemented in order to address any identified significant or potentially significant environmental effects of the project. The MMRP is required to list all of the EIR’s identified mitigation measures and a responsibility party for their implementation and/or monitoring.

The MMRP is comprised of a comprehensive table that lists all impacts and associated mitigation measures, along with a responsible entity that tracks implementation and timing. Used in tandem with the Specific Plan, the MMRP is one of the key elements used as development proposals within the Project Area are evaluated and approved by the City.

OVERRIDING CONSIDERATIONS FOR SIGNIFICANT & UNAVOIDABLE IMPACTS The EIR determined that there were several significant and unavoidable environmental impacts that would result from implementation of the Project. CEQA Guidelines §15091 requires that no public agency shall approve or carry out a project for which an EIR has been certified that identifies one or more significant environmental effects of the Project unless the public agency makes written findings for all identified significant effects. This means that the City’s action to certify the EIR must also include an action to adopt Findings of Fact and a Statement of Overriding Considerations. The Statement of Overriding Considerations is included in the CEQA Findings of Fact, attached to this staff report. It identifies the economic, social, technical, and other benefits of the Project that the City Council can consider if they choose to override these significant environmental impacts that would result from the Project.

While mitigation measures are included in the MMRP to reduce project-related impacts to the maximum extent feasible, the EIR identifies five potentially significant environmental effects that are considered unavoidable. These include:

1. Impact AG-1: Conversion of Farmland. The project would result in the permanent conversion of 319.5 acres of Prime Farmland and Farmland of Statewide Importance under the California Department of Conservation Farmland Mapping Program to nonagricultural use.

2. Impact AG-4: Indirect Agricultural Land Conversion. The project may indirectly result in conversion of other agricultural land in the vicinity of the CTSP to non-agricultural uses.

3. Impact GHG-2: GHG Emissions from Project Operations. The project would result in potentially significant emissions of GHGs, which would be offset by project features that limit VMT and promote reduced GHG emissions and by compliance with applicable San Joaquin Valley Air Pollution Control District regulations and programs.

4. Impact TRANS-3: Vehicle Miles Traveled. The project would have a potentially significant impact on residential and commercial vehicle miles traveled (VMT).

5. Impact TRANS-5: Traffic Hazards – Queuing. The project would result in traffic levels that would lead to excessive queuing at southbound off-ramp and northbound on-ramp ITEM 13
at the SR 99/Service Road interchange. Reconstruction of the interchange is currently in the design process, however construction timing has not yet determined. Therefore, this impact may only be significant and unavoidable in the short term.

The adverse effects listed above are substantive issues of concern to the City. However, the City’s adopted General Plan includes preliminary land uses in its Sphere of Influence that are intended to accommodate the City’s future growth. Additionally, the impacts identified above are typical of new suburban development. The EIR process allows the City to examine these impacts against the benefits that the Project provides to the City and determine whether the benefits outweigh the impacts.

Some of the benefits that would result from implementation of the Project include, but are not necessarily limited to, additional tax revenue for the City, while providing recreational facilities and housing opportunities for current and future City residents. The Project would also increase and diversify the City’s housing supply, which could spur development, economic growth, and property tax generation. Moreover, the increased housing supply helps meet the ever-growing demand for housing in the region. The Project also helps the City meet the State of California’s housing production mandates.

Based on the entire record, including the Draft and Final EIR, the City can make the determination that the economic and social benefits of the Project outweigh and override the significant unavoidable environmental effects that would result from the Project. Any environmental detriment caused by the proposed Project has been minimized to the extent feasible through the mitigation measures identified in the EIR and, where mitigation is not feasible, the impact can be outweighed and counterbalanced by the significant social, environmental, and land use benefits to be generated within the region.

Based on the facts and finding presented in this report along with the entire record, staff believes that the City Council can make the findings necessary to certify the EIR.

EIR CERTIFICATION AND FINDINGS REQUIRED
Prior to approval of the Project, the City of Ceres as Lead Agency is required to certify that the EIR was completed in compliance with CEQA and that the EIR was reviewed and considered before taking action to approve the Project. Additionally, for projects where an EIR identifies one or more significant environmental effects, CEQA Guidelines require that a public agency make written findings for each significant effect, accompanied by a brief explanation of the rationale for each finding. For Copper Trails, this means that a written finding and rationale is required for each of the five potentially significant environmental effects previously summarized in this report.

A document titled “CEQA Findings of Fact for the Copper Trails Specific Plan and Annexation” project is attached to this report. It contains the required findings under CEQA for the significant and unavoidable impacts summarized in this report, along with findings for all other impacts that can be mitigated to a less than significant level and for project alternatives. It also includes a Statement of Overriding Considerations to address the significant and unavoidable impacts identified by the EIR. Prior to the City’s approval of the Project, the Findings of Fact shall be adopted as part of the certification of the EIR.

Based on the public record and the evaluation herein, staff recommends that the City Council certify the Environmental Impact report, adopt the Mitigation Monitoring and ITEM 13
Reporting Program, and adopt the CEQA Findings of Fact, including the Statement of Overriding Considerations.

The EIR and associated documents are available on the City’s web site via this link:
https://www.ceres.gov/1798/Copper-Trails-Specific-Plan
IX. STEPS FOLLOWING APPROVAL:

Following a City Council action to approve the proposed project, the following steps would occur:

1. Staff would prepare and file an Annexation application with LAFCO to annex the Project Area into the City;

2. Upon completion of the annexation, staff would amend the City’s General Plan Land Use Diagram to show that the Project Area is included in the City’s jurisdiction and would update the official land use designations consistent with those shown in the CTSP and existing uses in the Pocket Area;

3. Upon completion of the annexation, staff would modify the City’s Zoning Map to officially change the zoning districts in the Project Area to align with the approved prezoning designations; and

4. Staff would process development applications received for properties located in the Project Area.

Report prepared by: Vance Jones, Wood Rodgers, Planning Consultant Approved by: _________________________
Trenton Johnson,
Acting City Manager
Attachments:

1. Attachment A – City Council Resolution 2026-XXX certifying the Environmental Impact Report for the Copper Trails Specific Plan and Annexation Project, adopting the Mitigation Monitoring and Reporting Program, and adopting the CEQA Findings of Fact, including a Statement of Overriding Considerations. - Exhibit A: Final Environmental Impact Report, dated March 2026 - Exhibit B: Draft Environmental Impact Report, dated November 2024 - Exhibit C: Mitigation Monitoring & Reporting Program, dated March 2026 - Exhibit D: CEQA Findings of Fact, dated March 2026

2. Attachment B – City Council Resolution 2026-XXX amending the General Plan Land Use Diagram.
- Exhibit A: General Plan Land Use Designations Exhibit

3. Attachment C – City Council Ordinance 2026-XXX approving the Pre-Zoning for the Project Area and amending the City’s Zoning Map accordingly. - Exhibit A: Pre-Zoning Districts Exhibit
ITEM 13

4. Attachment D – City Council Resolution 2026-XXX approving the Copper Trails Specific Plan and associated Public Facilities Financing Plan. - Exhibit A: Copper Trails Specific Plan, Copper Trails Specific Plan, dated February 2026
- Exhibit B: Public Facilities Financing Plan, dated November 2025

5. Attachment E – City Council Resolution 2026-XXX authorizing staff to make and execute any and all necessary documents and applications to the Stanislaus County Local Agency Formation Commission for annexation.
- Exhibit A: Annexation Area Exhibit

6. Attachment F – Public Notice

7. Attachment G – Presentation
ITEM 13
ITEM 13

ATTACHMENT A
RESOLUTION NO. 2026-XXX

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CERES

APPROVING THE CERTIFICATION OF THE ENVIRONMENTAL

IMPACT REPORT FOR THE COPPER TRAILS SPECIFIC PLAN AND

ANNEXATION PROJECT, ADOPTING THE MITIGATION MONITORING

AND REPORTING PROGRAM, AND ADOPTING THE CALIFORNIA

ENVIRONMENTAL QUALITY ACT (CEQA) FINDINGS OF FACT,

INCLUDING A STATEMENT OF OVERRIDING CONSIDERATIONS

THE CITY COUNCIL
City of Ceres
WHEREAS, the City Council held a duly noticed public hearing on April 13, 2026, at 6:00 p.m. and considered the Copper Trails Specific Plan and Annexation Project (Project), consisting of an Environmental Impact Report, a General Plan Amendment, a Pre-Zoning, a Specific Plan, and an Annexation; and
WHEREAS, pursuant to Section 18.03.030 of the Ceres Zoning Ordinance, the City Council has the responsibility to hear and decide applications for zoning amendments, general plan amendments, community plans, specific/master plans, special planning areas, pre-zoning, and development agreements, and to direct planning-related special studies; and
WHEREAS, the City, as Lead Agency, has prepared an Environmental Impact Report (SCH #2023090637) to evaluate the Project pursuant to and in accordance with the California Environmental Quality Act (CEQA); and
WHEREAS, the Environmental Impact Report (EIR) was made available for the statutory minimum 45-day public review from December 12, 2024, to January 27, 2025, and public comments received were posted and responded to in the Final EIR; and WHEREAS, a Notice of Public Hearing was issued by the City on February 6, 2026, indicating that the Planning Commission would consider the Copper Trails Specific Plan and Annexation Project at a public hearing on March 2, 2026, and that a Final EIR was available for public review; and
WHEREAS, the EIR identified one or more significant and unavoidable environmental effects of the Project, however certain findings have been made as identified in the CEQA Findings of Fact for the Copper Trails Specific Plan and Annexation project, which includes a Statement of Overriding Considerations as required by CEQA; and;
WHEREAS, a Mitigation Monitoring and Reporting Program (MMRP) has been prepared to ensure that all mitigation measures included in EIR are implemented in order to address any identified significant or potentially significant environmental effects of the Project; and
ITEM 13

ATTACHMENT A
WHEREAS, the Project area is located within an unincorporated area of Stanislaus County and would require annexation into the City of Ceres prior to any development activity occurring under the City’s jurisdiction and pursuant to City standards and regulations; and
WHEREAS, the annexation area consists of the 680.7-acre Project Area (244 parcels total), which is comprised of two smaller areas including the 534.6-acre Copper Trails Specific Plan (CTSP) area, with 68 parcels located south of Service Road, and the 146.1-acre “Pocket Area” with 176 parcels located north of the CTSP and contiguous with a portion of the City’s southern limits; and
WHEREAS, the Project Area is located in the City of Ceres Sphere of Influence and Planning Area, as identified in the Ceres General Plan, which includes a Land Use Diagram that establishes preliminary land use designations for properties in the Project Area; and
WHEREAS, existing land uses for the Project Area as identified on the County of Stanislaus General Plan Land Use Map includes a mixture of Urban Transition, Agriculture, Commercial, Industrial, Low Density Residential, Medium/High Density Residential, and Planned Development designations; and
WHEREAS, the preliminary land uses for the Project Area, as identified in the Ceres General Plan, include a mixture of Regional Commercial, Neighborhood Commercial, Community Commercial, School, Light Industrial, Low Density Residential, Medium Density Residential, Medium-High Density Residential, High Density Residential, Park and Open Space, and Community Facilities designations; and WHEREAS, the existing zoning for the Project Area, as identified County of Stanislaus Zoning Map, includes a mixture of Rural Residential, Multiple Family, Medium Density Residential, General Commercial, Industrial, General Agriculture 10 Acre Urban Transition, General Agriculture 40 Acre, and Highway Frontage districts; and WHEREAS, the Pre-Zoning districts for the Project Area include a mixture of Planned Community (P-C), Single-Family Residential (R-1), Medium Density Residential (R-3), Medium-High Density Residential (R-4), Neighborhood Commercial (C-1), Community Commercial (C-2), and Light Industrial (M-1) districts, as defined in the Ceres Zoning Ordinance; and
WHEREAS, the Project includes establishing a development framework for the 535-acre CTSP area and addresses development aspects of land use, circulation, parks and recreation, public utilities, public services, phasing, financing, and implementation, in accordance with Title 7, Chapter 3, Article 8 (Sections 65450 – 65457), Planning and Zoning Law, of the California Government Code; and
WHEREAS, the CTSP incorporates a Public Facilities Financing Plan (PFFP) that estimates the costs and funding mechanisms to construct the public improvements necessary to facilitate development of the CTSP area; and ITEM 13

ATTACHMENT A
WHEREAS, the pre-zoning to be applied to the CTSP area is the Planned Community (P-C) district in accordance with Section 18.13 of the Ceres Zoning Ordinance, which allows projects such as Copper Trails to be master-planned and for a Specific Plan to function as the primary Zoning tool for its implementation; and WHEREAS, the annexation area is contiguous with the City of Ceres current City limits and is identified in the Ceres General Plan as a logical area for City expansion; and WHEREAS, the Project has been found to be consistent with applicable policies of the Ceres General Plan and Ceres Zoning Ordinance, as described in the City Council Staff Report dated April 13, 2026; and
WHEREAS, the Planning Commission held a duly noticed public hearing on March 2, 2026 at 6:00 p.m., and after receiving a staff report and public testimony, recommended that the City Council approve the Copper Trails Specific Plan and Annexation Project (Project), consisting of an Environmental Impact Report, a General Plan Amendment, a Pre-Zoning, a Specific Plan, and an Annexation; and
WHEREAS, the City Council has considered all information related to this matter, as presented at a public hearing, including any supporting reports by City staff, recommendation from the Planning Commission, and any information provided during public meetings.

NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Ceres, pursuant to the Ceres Municipal Code, and upon evidence in the staff report and associated documents incorporated by reference herein, certifies the Environmental Impact Report, adopts the CEQA Findings of Fact and Statement of Overriding Considerations, and adopts the Mitigation Monitoring and Reporting Program based on the following findings:

1. An Environmental Impact Report (EIR) was prepared in accordance with the California Environmental Quality Act (CEQA) that comprehensively evaluates the Project, which documents existing environmental conditions in the Project Area, describes the potential environmental effects of approving and implementing the Project, includes mitigation measures designed to avoid or substantially reduce any identified significant environmental effects, analyzes project alternatives, and meets other applicable CEQA requirements.

2. A Mitigation Monitoring and Reporting Program (MMRP) was prepared and considered by the Planning Commission, which lists all mitigation measures and identifies the responsibility party for MMRP implementation, in order to mitigate significant or potentially significant environmental effects of the Project to a less than significant level where feasible.

3. A document titled “CEQA Findings of Fact for the Copper Trails Specific Plan and Annexation” was prepared, which contains the required findings under CEQA for any identified significant and unavoidable impacts resulting from implementation of the Project, along with findings for all other impacts that can be mitigated to a less than significant level.

ITEM 13

ATTACHMENT A

4. A Statement of Overriding Considerations, included as part of the CEQA Findings of Fact was prepared in accordance with CEQA Guidelines sections 15091 and 15093, which identifies any significant and unavoidable impacts and provides a determination that the economic and social benefits of the Project’s implementation outweigh and override the significant unavoidable environmental effects that would result from the Project.

5. Certification of the EIR includes adoption of the MMRP, CEQA Findings of Fact, and a Statement of Overriding Considerations.

PASSED AND ADOPTED by the Ceres City Council at a regular meeting thereof held on the 13
th day of April 2026, by the following vote:

AYES: Councilmembers:

NOES: Councilmembers:

ABSENT: Councilmembers:

ABSTAIN: Councilmembers:
________________________________
Javier Lopez, Mayor
ATTEST:
_________________________________
Fallon Martin, City Clerk
ATTACHMENTS:

Exhibit A: Final Environmental Impact Report, dated March 2026 Exhibit B: Draft Environmental Impact Report, dated November 2024 Exhibit C: Mitigation Monitoring & Reporting Program, dated March 2026 Exhibit D: CEQA Findings of Fact, dated March 2026
ITEM 13
FINAL
ENVIRONMENTAL IMPACT REPORT
FOR THE
COPPER TRAILS SPECIFIC PLAN
AND ANNEXATION PROJECT
March 2026
Prepared for:

City of Ceres
Community Development Department
2220 Magnolia Street
Ceres, CA 95307
Prepared by:

BaseCamp Environmental, Inc.
802 W. Lodi Avenue
Lodi, CA 95240
EXHIBIT A ITEM 13
FINAL
ENVIRONMENTAL IMPACT REPORT
FOR THE
COPPER TRAILS SPECIFIC PLAN
AND ANNEXATION PROJECT
Ceres, CA
March 2026
Prepared for:

City of Ceres
Community Development Department
2220 Magnolia Street
Ceres, CA 95307
209-538-5774
Prepared by:

BaseCamp Environmental, Inc.
802 W. Lodi Avenue
Lodi, CA 95240
209-224-8213
www.basecampenv.com

EXHIBIT A ITEM 13
i
TABLE OF CONTENTS
Copper Trails Specific Plan and Annexation Project,
Final EIR
City of Ceres, CA
Page

1.0 Introduction 1-1

1.1 Project and EIR Overview 1-1

1.2 CEQA Processing and Final EIR 1-2

1.3 EIR Certification and Findings 1-3

2.0 Summary 2-1

2.1 Summary of Project Description 2-1

2.2 Summary of Impacts and Mitigation Measures 2-2

2.3 Summary of Alternatives 2-2

2.4 Other Project Considerations 2-3

3.0 Comments on Draft EIR and Lead Agency Responses to Comments 3-1

4.0 Draft EIR Errata 4-1

APPENDIX
A Draft EIR Distribution List and Legal Notices
B Updated DEIR Project Description Graphics

LIST OF FIGURES
1-1. Regional Location Map 1-5
1-2. Project Location 1-6
1-3. Proposed Annexation Area 1-7
1-4. USGS Map 1-8
1-5. Aerial Photo 1-9
EXHIBIT A ITEM 13
ii

LIST OF TABLES
2-1. Revised Summary of Impacts and Mitigation Measures 2-5 EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation, Final EIR 1-1 March 2026

1.0 INTRODUCTION

1.1 PROJECT AND EIR OVERVIEW
This Final Environmental Impact Report (Final EIR or FEIR) describes the potential environmental impacts that would result from the City of Ceres’ approval of the proposed Copper Trails Specific Plan (CTSP) and Annexation Project (project). The proposed annexation area is comprised of the 534.6-acre CTSP area and an adjacent 146.1-acre area lying between the CTSP and the existing City of Ceres boundary (Figures 1-1 through 1- 5). The overall annexation project includes a total of 680.7 acres in 244 existing parcels; The Copper Trails Specific Plan would guide and regulate the future development of new urban land uses on 68 undeveloped or under-developed parcels located within the CTSP area, which is adjacent to and southwest of Ceres in unincorporated Stanislaus County The CTSP area would be annexed to the City of Ceres in conjunction with approval of the specific plan. The CTSP proposes a mix of commercial, public, park, and low- to highdensity residential land uses. Total potential development pursuant to the CTSP would include an estimated 2,392 new single- and multi-family residential units and 1.2 million square feet of new regional commercial development. Development of the CTSP area would include approximately 42.3 acres of new parks and open space and 3.4 acres of new public space in addition to an existing 74.1 acres of public space (schools) within the CTSP Area.

The CTSP establishes locations and provides for the construction of streets and other public facilities that would meet urban service needs while encouraging use of alternate modes of transportation, such as walking and bicycling. Utilities and other supporting infrastructure would be installed in conjunction with planned new development. Additional project details can be found in Chapter 3.0 of the Draft EIR Project Description.

In addition to annexation of the 68 parcels that comprise the CTSP area, the project would also include annexation of another 176 parcels totaling 146.1 acres of other unincorporated but largely developed lands between the CTSP area and the existing City boundary to the north and east; this area is hereinafter referred to as the “Pocket Area.” The Pocket Area would be pre-zoned consistent with the existing Ceres General Plan designations for the area, which is within the City’s Sphere of Influence. Annexation of the CTSP Area, without including the Pocket Area, would result in an unincorporated island within the City limits, which is contrary to LAFCo annexation policy. The proposed annexation requires the approval of the Stanislaus Local Agency Formation Commission (LAFCo).

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation, Final EIR 1-2 March 2026

1.2 CEQA PROCESSING AND FINAL EIR
The Copper Trails EIR, including both the Draft EIR and this Final EIR, has been prepared in accordance with the requirements of CEQA and the State CEQA Guidelines. The City of Ceres is the “lead agency” for the proposed specific plan and annexation project. The City determined that an EIR would be required for the project and released a Notice of Preparation (NOP) on September 27, 2023 for agency and public review. The NOP comment period closed on October 26, 2023. A copy of the NOP and comments received in response to the NOP are included in Appendix A of the Draft EIR.

The Notice of Preparation (NOP), comments on the NOP received by the City, the Draft EIR and technical appendices to the Draft EIR are available for review at the City offices and on the City’s website:

City of Ceres Community Development Department
2220 Magnolia Street
Ceres, CA 95307
https://www.ci.ceres.ca.us/1798/Copper-Trails-Specific-Plan The City prepared a Draft EIR (the Public Review Draft EIR, dated November 6, 2024) that identified the potential environmental effects of the project. The Draft EIR was distributed locally and through the State Clearinghouse (SCH #2023090637) for agency and public comment between November 6, 2024 and January 27, 2025. The Draft EIR distribution list, legal notices and other information related to the public review period for the Draft EIR are shown in FEIR Appendix A. Public and agency comments received by the City during the public review period, together with the City’s responses to these comments, are shown in FEIR Section 3.0.

CEQA Guidelines Section 15132 specifies the content of a Final EIR as:
• The Draft EIR or a revision of the draft,
• Comments and recommendations received on the Draft EIR, either verbatim or in summary,
• A list of persons, organizations, and the public agencies commenting on the Draft EIR,
• The responses of the Lead Agency to significant environmental points raised in the review and consultation process, and
• Any other information added by the Lead Agency. This may include additional technical information or clarification to the Draft EIR.

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation, Final EIR 1-3 March 2026 This Final EIR provides the information required by the CEQA Guidelines. This Section

1.0 describes the purpose and format of the Final EIR and incorporates the Draft EIR by reference, below. Section 2.0 summarizes the Public Review Draft EIR, together with any modifications dictated by responses to comments on the Draft EIR (FEIR Section 3.0).

FEIR Section 3.0 lists and displays all of the comments received by the City concerning the Draft EIR verbatim, provides the City’s response to each substantive comment pertaining to the EIR content and/or its processing pursuant to CEQA. FEIR Section 4.0 sets forth any corrections and changes to the Draft EIR, including changes that address public and agency comments as well as any pertinent revisions originating with City staff.

FEIR Appendix A includes copies of transmittal documents, the Notice of Availability of the Draft EIR, the distribution list for the NOA the Notice of Completion, and other material related to the public review of the Draft EIR.

The Draft EIR, cited below, is hereby incorporated by reference. Copies of the Draft EIR are available for review at the City of Ceres Community Development Department, 2220 Magnolia Street, Ceres CA 95307, or on the City’s website at the link shown above.

Public Review Draft Environmental Impact Report for the Copper Trails Specific Plan and Annexation Project, Ceres, CA. November 6, 2024. Prepared for City of Ceres Department of Community Development, 2220 Magnolia Street, Ceres, CA 95307. Prepared by BaseCamp Environmental, Inc., 802 West Lodi, CA 95240.

State Clearinghouse Number 2023090637.

As required by CEQA, a copy of the City’s proposed responses to comments on the Draft EIR it received from agencies, as shown in Section 3.0 of this Final EIR, were provided to each commenting agency a minimum of 10 days ahead of the proposed certification of the Final EIR.

1.3 EIR CERTIFICATION AND FINDINGS
Sections 15090 through 15093 of the CEQA Guidelines outline required procedures for Lead Agency certification and findings related to the EIR. Before taking action on the project, the City must first certify that the EIR is adequate under CEQA. Then, in conjunction with its decision on the project, the City must make specific findings with respect to each of the significant environmental effects identified in the EIR.

CEQA Guidelines Section 15090 requires that the Lead Agency certify that 1) the Final EIR has been completed in compliance with CEQA, 2) that the Final EIR was presented to the decision-making body of the Lead Agency, and the decision-making body reviewed and considered the information contained in the Final EIR prior to a decision on the project, and 3) that the Final EIR reflects the Lead Agency’s independent judgment and analysis.

The EIR is intended by CEQA to be an informational document (CEQA Guidelines Section 15121). Decision-making on the project in relation to its environmental impacts is reserved to the Lead Agency and any interested Responsible Agencies. Consequently, information in the EIR does not limit the Lead Agency's ultimate discretion on the project, but as noted the Lead Agency must make specific findings with respect to each significant effect EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation, Final EIR 1-4 March 2026 identified in the EIR (CEQA Guidelines Section 15091). The City’s findings for the project are contained in a separate CEQA Findings document that accompanies this Final EIR and is expected to be adopted by the Ceres City Council at the time this EIR is certified. The possible findings are:

1. Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the Final EIR (i.e., the impact has been “mitigated”).

2. Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency (i.e., mitigation is the responsibility of an agency other than the City of Ceres).

3. Specific economic, legal, social, technological or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the Final EIR (i.e., the impact is acceptable because the project’s benefits outweigh it).

In the event that the City wishes to approve a project without providing substantial mitigation for all of its significant impacts (i.e., if the second or third finding options are utilized), then CEQA Guidelines Section 15093 allows the decision-makers to balance the project’s benefits against its unavoidable environmental risks. This decision must be documented in a Statement of Overriding Considerations, which is adopted by the Lead Agency. As documented in this Final EIR, the Copper Trails Specific Plan and Annexation Project would have significant and unavoidable environmental impacts; therefore, the City of Ceres will need to adopt a Statement of Overriding Considerations before it takes action on the project. A proposed Statement of Overriding Considerations is included in the CEQA Findings document for the project.

As a part of the project consideration and approval process described above, the City must also adopt a mitigation monitoring and/or reporting program (CEQA Guidelines Section 15097). The mitigation monitoring/reporting program is required to ensure that the mitigation measures and project revisions identified in the EIR are implemented. The measures and any revisions to this project are fully enforceable through permit conditions, agreements, or other measures. The mitigation monitoring/reporting program for this project is also contained in a separate document that accompanies this Final EIR and is expected to be adopted by the Ceres City Council at the time this EIR is certified.

EXHIBIT A ITEM 13
BaseCamp
Figure 1-1
BaseCamp Environmental REGIONAL LOCATION MAP
San Diego Imperial
Orange
Riverside
San Bernardino
Ventura Los Angeles
Santa Barbara
Kern San Luis
Obispo
Inyo
Tulare
Kings Monterey
Fresno
San
Benito
Mono
Madera
Mariposa
Tuolumne
Calaveras
Amador
El Dorado
Sacramento
Alpine
Santa
Clara
San
Joaquin
Contra
Costa
Merced
Marin
Napa
Yolo
Solano
Sutter
Placer
Nevada
Sierra Glenn Butte
Lake
Mendocino
Colusa Yuba
Sonoma
Stanislaus Alameda
Santa Cruz
San Mateo
San Francisco
www.csac.counties.org

CITY OF CERES

PROJECT AREA
EXHIBIT A ITEM 13
Figure 1-2
BaseCamp Environmental PROJECT LOCATION
SOURCE: Wood Rodgers

POCKET AREA
Copper Trails
Specic Plan
City of Ceres Planning Area Boundary
EXHIBIT A ITEM 13
BaseCamp
Figure 1-3
BaseCamp Environmental PROPOSED ANNEXATION AREA

POCKET AREA

COPPER TRAILS

SPECIFIC PLAN AREA

EXISTING
CERES

CITY LIMIT

PROPOSED ANNEXATION BOUNDARY
EXHIBIT A ITEM 13
BaseCamp
Figure 1-4
BaseCamp Environmental USGS MAP
SOURCE: USGS Quadrangle Map, Ceres, CA 2021.

POCKET AREA

COPPER TRAILS

SPECIFIC PLAN AREA
EXHIBIT A ITEM 13
Figure 1-5
BaseCamp Environmental AERIAL PHOTO

SPECIFIC PLAN AREA

POCKET AREA
SOURCE: Google Earth
EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation, Final EIR 2-1 March 2026

2.0 SUMMARY

2.1 SUMMARY OF PROJECT DESCRIPTION
This Environmental Impact Report (EIR) describes the potential environmental effects that would result from the approval of the Copper Trails Specific Plan (CTSP) and Annexation Project, including related permits and approvals. The CTSP establishes a plan for, and would result in, development of residential, commercial, and other urban land uses within the approximately 534.6-acre CTSP area south and west of Ceres. The project also proposes the annexation and pre-zoning of an additional 146.1 acres of currently unincorporated land outside and north of the CTSP Area, referred to as the Pocket Area; future development within the Pocket Area, which has already been largely developed under County jurisdiction, would likely be limited to remaining undeveloped or vacant parcels. The project area as a whole includes approximately 680.7 acres.

CTSP approval and annexation would result in the potential for development of approximately 260.3 acres of low-, medium-, medium high-, and high-density residential units within the CTSP Area – up to a total of 2,392 units. Another approximately 107.4 acres is proposed for Regional Commercial development, with up to 1,169,586 square feet of building space. The CTSP also proposes approximately 42.3 acres of parks and open space, including street landscapes, and 3.4 acres for new public uses that would be in addition to the 74.1 acres already occupied by the existing Central Valley High School, Ceres Adult School and Hidahl Elementary School.

The CTSP proposes a circulation system that would utilize and improve existing roads and add new roads and streets. It also would provide for the development of new bicycle and pedestrian trails and open space linkages that would and between the planned residential neighborhoods, commercial areas, schools, and parks. The CTSP is proposed to be developed in four phases, with streets and utilities to be installed during each phase in accordance with an Infrastructure Plan. Specific development standards and community design themes for planned land uses are defined in Chapter 3 of the CTSP. It can be anticipated that future development of the CTSP Area would be similar to existing development patterns seen in the City’s newer residential and commercial areas.

Annexation of the Pocket Area would include pre-zoning of the area consistent with the Ceres General Plan, extending the availability of City utilities and services to this largely developed unincorporated area. The Pocket Area includes some non-contiguous tracts of undeveloped land with new development potential. Potential development of the Pocket Area would be subject to the applicable provisions of the City’s existing zoning regulations.

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation, Final EIR 2-2 March 2026

2.2 SUMMARY OF IMPACTS AND MITIGATION MEASURES
The potentially significant environmental effects of the proposed project, and the mitigation measures needed to minimize these effects, are listed in Table 2-1 at the end of this chapter. The table identifies the level to which the proposed mitigation measures would reduce environmental effects. “Significant and unavoidable” impacts are those that remain significant or potentially significant after mitigation measures are applied.

2.3 SUMMARY OF ALTERNATIVES
Chapter 19.0 identifies and discusses a range of reasonable alternatives to the proposed project, including the "no project" alternative. Several alternatives were considered but not analyzed in detail as they were inconsistent with project objectives, were not feasible or did not offer an opportunity to reduce environmental effects. The alternatives addressed in detail include:

Alternative No. 1: No Project/No Development
Alternative No. 2: 2007 Copper Trails Specific Plan
Alternative No. 3: Current General Plan Map
The No Project alternative involves no action by the City with respect to the project or related development entitlement actions, including the proposed annexations. Under this alternative, existing County General Plan land use designations and zoning on the project site would remain in place, as would existing public roads and other urban infrastructure in the area. The County General Plan currently designates the entire project site as Urban Transition, but the CTSP Area is currently zoned General Agriculture. The continuation of existing uses would not result in any substantial change to the existing environment within or near the CTSP Area. However, the No Project alternative is not consistent with the project objectives nor with the proposed development in the City’s General Plan. Also, the City may be required to pursue alternative residential development, either through more intensive development, development on currently open space lands, or a combination of the two. This could result in new or more severe environmental impacts.

Under the 2007 CTSP Alternative, the CTSP as published for a public hearing in 2007 would be adopted. The 2007 CTSP covered approximately 175 acres, as opposed to the 534.6 acres covered by the proposed CTSP. It allowed for the development of up to 411 dwelling units of varying densities, along with parks and open space, but no commercial or other non-residential development. This alternative would reduce the proposed project’s direct physical environmental effects because of the reduced acreage involved. However, the 2007 CTSP Alternative would not meet all the objectives of the proposed project; specifically, the development of commercial uses and providing a balance of residential and non-residential land uses. Also, the City is unlikely to achieve its housing obligations under this alternative, which could lead to more housing development elsewhere, with attendant environmental impacts.

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation, Final EIR 2-3 March 2026 Under the Current Ceres General Plan Map Alternative, the project site would be developed in accordance with the current land use designations of the Ceres General Plan. The Ceres General Plan designates the CTSP Area for primarily medium and high-density residential, business park, and community recreation land uses. It allows for the development of up to 2,461 dwelling units. This alternative would meet the CTSP objectives of providing diversity in housing and in meeting housing targets, and the environmental impacts in general would be similar to those of the proposed project. However, this alternative may lead to more severe impacts on air quality, GHG emissions, noise, and traffic, due to more traffic being generated by the additional housing units that would be made available and to the introduction of more trucks. In addition, development of the Business Park area may introduce more hazardous materials to the area through transportation and storage.

Of these three alternatives, the No Project Alternative is considered the environmentally superior alternative. The 2007 CTSP Alternative would involve less severe environmental effects than the proposed project and therefore could be considered the Environmentally Superior Alternative behind the No Project Alternative.

2.4 OTHER PROJECT CONSIDERATIONS
CEQA Guidelines Section 15126(d) requires that an EIR shall consider the growthinducing impacts of a proposed project. The project would inherently have a growthinducing impact in that it would promote the urban development of the CTSP Area. The proposed CTSP has the potential to promote or stimulate future development of lands adjacent to the CTSP Area, mainly to the south and west. However, lands to the west are already substantially developed, and the Ceres General Plan has designated these lands for urban development. The agricultural lands south of the CTSP Area are not within either the Ceres General Plan Planning Area or the City’s Sphere of Influence; moreover, they would be separated from the proposed development by TID Lower Lateral 2, which would act as a barrier.

CEQA Guidelines Section 15126(c) requires that an EIR address significant irreversible environmental changes that would be involved in the proposed project if it were implemented. Urban development promoted by the CTSP would involve the irreversible commitment of non-renewable materials and energy consumption to construction of proposed urban infrastructure, residential and non-residential areas and related development. The CTSP would involve significant irreversible environmental changes in the loss of agricultural land, involving the conversion of approximately 319.5 acres of Important Farmland (see Chapter 5.0, Agricultural Resources) from the present agricultural and open space uses to urban residential, commercial, and other urban uses. Development of the CTSP Area would involve an essentially irreversible reduction in groundwater recharge that would otherwise occur on the undeveloped soils of the area.

The State of California has recently emphasized the incorporation of environmental justice concerns in land use and environmental planning. Low-income residents, communities of color, tribal nations, and immigrant communities have historically experienced disproportionate environmental burdens with their related health problems, in part due to inappropriate zoning and incomplete land use planning. In recognition of this, and in EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation, Final EIR 2-4 March 2026 accordance with applicable legislation, this EIR evaluated the presence of the project site in a Census tract defined as a disadvantaged community. It was determined that the project site is not within a disadvantaged community.

EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-5 March 2026

4.0 AESTHETICS AND VISUAL RESOURCES
Impact AES-1: Scenic Vistas. Views of scenic vistas already limited; project would not contribute substantially to
limiting views.

LS None required. -
Impact AES-2: Scenic Resources. There are no distinctive scenic resources on the project site. No scenic highways are in the area.

LS None required. -
Impact AES-3: Visual Character and Quality. Urban
development would replace existing open space areas.

New structures, site improvements, and landscaping
would be designed and constructed to meet the aesthetic standards of the CTSP and be consistent with General Plan policies.

LS None required. -
Impact AES-4: Light and Glare. Lighting would be installed on properties that currently have none. Compliance with City and CTSP standards would minimize light and glare
impacts.

LS None required. -

5.0 AGRICULTURAL RESOURCES
Impact AG-1: Conversion of Farmland. The CTSP would
convert 319.5 acres of Farmland as defined by CEQA
Guidelines Appendix G. The City’s Plan for Agricultural Preservation would compensate for impacts on Farmland
but not avoid conversion. [This issue was analyzed in the Ceres General Plan EIR and was determined to be
significant and unavoidable even with mitigating General Plan policies.]
S AG-1: Prior to the approval of improvement plans, building permits, or recordation of a final map, applicants for projects in the Specific Plan Area shall offset the loss of Prime Farmland. This shall be done in coordination with the City, through the acquisition of conservation easements in Stanislaus County at a 1:1 ratio (i.e., one acre on which easements are acquired to one acre of Prime Farmland removed from agricultural use) that provide in-kind or similar resource value protection; payment of in-lieu fees to an established, qualified, mitigation program to fully fund the acquisition and maintenance of agricultural land or easements; or compliance with the City’s adopted Plan for Agricultural Preservation, as adopted by Stanislaus LAFCO in accordance with LAFCO Policy 22.

SU
EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-6 March 2026 This same impact was previously addressed in Ceres General Plan EIR and was included in the City’s Statement of Overriding Considerations when the General Plan was adopted.

Impact AG-2: Conflict Between Agricultural and Urban
Land Uses. Intensive agricultural operations adjacent or close to urban development can result in use conflicts.

General Plan policies and existing physical buffers would minimize potential conflicts.

LS None required. -
Impact AG-3: Agricultural Zoning and Williamson Act. The CTSP Area is mostly zoned General Agriculture, while
three parcels within the project site are under a
Williamson Act contract. The project would rezone the
CTSP Area to be consistent with proposed urban
development, and the Williamson Act contracts would be
cancelled or not renewed.

PS AG-2: Project applicants for urban development of lands with a surviving Williamson Act contract shall apply to the City for approval of immediate cancellation of the contract. The application shall be processed pursuant to the requirements of Sections 51282 and 51284 of the Government Code, including detailed findings specified in the law, and review and comment by the California Department of Conservation:

1. That the cancellation is consistent with the purposes of this chapter, and

2. That cancellation is in the public interest.

Provided that required findings can be made, immediate
cancellation of remaining Williamson Act contracts will reduce potential conflicts to a less than significant level.

LS
Impact AG-4: Indirect Agricultural Land Conversion. The project may indirectly convert other agricultural land in the vicinity to non-agricultural uses, even with
implementation of policies to reduce conversion
pressures.

SU None feasible. -

6.0 AIR QUALITY
Impact AIR-1: Air Quality Plans and Standards –
Construction Emissions. Project construction emissions
would not exceed SJVAPCD significance thresholds in a
maximum development year, thereby being consistent
with adopted air quality plans. Dust emissions would be PS Recommended Air Quality Measures
AIR-1: Prior to the issuance of a Grading Permit for each phase of the Project, the Project Proponent shall prepare and submit a Dust Control Plan that meets all of the applicable requirements of APCD Rule 8021, Section LS
EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-7 March 2026 reduced through the required implementation of SJVAPCD
Regulation VIII and the Indirect Source Rule.

6.3, for the review and approval of the APCD Air Pollution Control Officer.

AIR-2: During all construction activities, the Project Proponent shall implement dust control measures, as required by
APCD Rules 8011-8081, to limit Visible Dust Emissions
to 20% opacity or less. Dust control measures shall include application of water or chemical dust
suppressants to unpaved roads and graded areas,
covering or stabilization of transported bulk materials, prevention of carryout or trackout of soil materials to public roads, limiting the area subject to soil
disturbance, construction of wind barriers, access restrictions to inactive sites as required by the applicable rules.

AIR-3: During all construction activities, the Project proponent shall implement the following dust control practices identified in Tables 6-2 and 6-3 of the GAMAQI (2016).
a. All disturbed areas, including storage piles, which are not being actively utilized for construction purposes, shall be effectively stabilized of dust emissions using water, chemical stabilizer/suppressant, or vegetative ground cover.
b. All on-site unpaved roads and off-site unpaved access roads shall be effectively stabilized of dust emissions using water or chemical stabilizer/suppressant.
c. All land clearing, grubbing, scraping, excavation, land leveling, grading, cut and fill, and demolition activities shall control fugitive dust emissions by application of water or by presoaking.
d. When materials are transported off-site, all material shall be covered, effectively wetted to limit visible dust emissions, or at least six inches of freeboard space from the top of the container shall be maintained.

EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-8 March 2026 e. All operations shall limit or expeditiously remove the accumulation of mud or dirt from adjacent public streets at least once every 24 hours when operations are occurring. The use of dry rotary brushes is expressly prohibited except where preceded or accompanied by
sufficient wetting to limit the visible dust emissions. Use of blower devices is expressly forbidden.
f. Following the addition of materials to, or the removal of materials from, the surface of outdoor storage piles, said piles shall be effectively stabilized of fugitive dust emissions utilizing sufficient water or chemical
stabilizer/suppressant.
g. Limit traffic speeds on unpaved roads to 5 mph.
h. Install sandbags or other erosion control measures
to prevent silt runoff to public roadways from sites with a slope greater than one percent.

AIR-4: Asphalt paving shall be applied in accordance with APCD Rule 4641, the purpose of which is to limit VOC
emissions by restricting the application and
manufacturing of certain types of asphalt for paving
and maintenance operations. This rule applies to the
manufacture and use of cutback asphalt, slow cure
asphalt and emulsified asphalt for paving and
maintenance operations. The Applicant shall
coordinate with the APCD and provide the City with
evidence of consultation with the APCD, including
confirmation of compliance with APCD Rule 4641.

Impact AIR-2: Air Quality Plans and Standards –
Operational Emissions. the project would not contribute new or more severe air quality impacts than those
analyzed in the GPEIR, and it may reduce some of these
impacts. Individual projects would be subject to CEQA
review and potential mitigation measures if necessary.

S LS None feasible required. SU-
Impact AIR-3: Exposure of Sensitive Receptors to Criteria Pollutants. Potentially significant CO effects could result LS None required. -
EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-9 March 2026 from the CTSP if it would result in high traffic congestion.

However, the transportation analysis indicates that
intersections would not reach congestion levels causing elevated CO concentrations that may present a health risk.

Impact AIR-4: Exposure of Sensitive Receptors to Toxic Air Contaminants. Development in the project site is unlikely to generate or be exposed to TACs at a level that can
present a risk to human health. Projects that could
generate potentially significant amounts of TACs would be subject to City review.

PS AIR-5: For service station projects, as part of the Conditional Use Permit evaluation process, the Gasoline Service Station Industrywide Risk Assessment Look-up Tool shall be used to screen service stations for their cancer and non-cancer chronic and acute risks. If the results of the Look-up Tool indicate that the proposed service station would not exceed the significance thresholds for cancer and non-cancer chronic and acute risks, as set by the San Joaquin Valley Air Pollution Control District (SJVAPCD), then no further action need be taken. However, if the service station project exceeds one or more of these thresholds, particularly the cancer risk threshold, then the project shall be required to prepare a Health Risk Assessment. The Health Risk Assessment shall quantify the health risks associated with the project and identify project or design changes sufficient to reduce these risks to levels below their respective significance thresholds. These recommendations shall be incorporated as conditions of approval for the Conditional Use Permit and shall be implemented upon permit approval.

LS
Impact AIR-5: Odor Emissions. The project would not
allow or promote development of significant odor sources.

LS None required. -

7.0 BIOLOGICAL RESOURCES
Impact BIO-1: Special-Status Species and Habitats. Project development would involve the potential for impacts on
foraging habitat for Swainson’s hawk and shrub habitat
for valley elderberry longhorn beetle.

PS BIO-1: If ground-disturbing activities would take place on sites where suitable nesting habitat may exist, a survey for nesting Swainson’s hawks and burrowing owl shall be conducted by a qualified wildlife biologist, following survey methods developed by the Swainson’s Hawk Technical Advisory Committee (2000) and CDFW’s Staff Report on Burrowing Owl Mitigation (2012) prior to undertaking any ground-disturbing activities. The survey shall include recommended mitigation measures for any potential impacts from the project.

If ground disturbing activities would take place during the nesting season (March 1 through August 31) and Swainson’s LS
EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-10 March 2026 hawk or burrowing owl nests are found to be present, a nodisturbance buffer consistent with CDFW guidance shall be established around active nests until the breeding season has ended or until a qualified biologist has determined that the birds have fledged.
(BIO-1 continued) A qualified biologist shall conduct a habitat assessment to determine if the project area contains habitat suitable to support Crotch’s bumble bee nesting, including identification of potential nesting sites. If the habitat assessment indicates high potential to support the bumble bee nesting, the biologist shall recommend appropriate mitigation.

BIO-2: Prior to the start of construction activities for an approved development project, a survey shall be conducted by a qualified biologist for blue elderberry (Sambucus mexicana) shrubs. Should such shrubs be discovered by the survey, the development project shall avoid removal of these shrubs to the extent feasible. If avoidance is not feasible, then the biologist shall recommend actions to be taken to minimize or to
compensate for any impacts on blue elderberry shrubs in accordance with the applicable state or federal regulations.

Impact BIO-2: Riparian and Other Sensitive Habitats.

There are no riparian or other sensitive habitats on the project site.

NI None required. -
Impact BIO-3: State and Federally Protected Wetlands. No wetlands have been identified on the project site. Potential impacts on TID canals would be covered under the Section 404 permitting process.

LS None required. -
Impact BIO-4: Migratory Fish and Wildlife Habitats.

Migration Corridors and Nursery Sites
Existing trees and grassy areas could be used by protected migratory bird species for nesting.

PS BIO-3: If construction of a development project commences during the general avian nesting season (February 1 through September 15), a pre-construction survey for all species of nesting birds shall be conducted. If active nests for any bird species are found, work in the vicinity of the nests shall be delayed until the young have fledged. No survey shall be required if construction occurs outside the general avian nesting season.

LS
EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-11 March 2026 Impact BIO-5: Local Biological Requirements. Local
Policies and Ordinances
Development on the project site would be consistent with Ceres General Plan policies on biological resources, with implementation of Mitigation Measure BIO-1. No local
ordinances protecting biological resources have been
enacted.

PS Mitigation Measure BIO-1. LS
Impact BIO-6: Habitat Conservation Plans. No habitat
conservation plans apply to the area.

NI None required. -

8.0 CULTURAL RESOURCES AND TRIBAL CULTURAL RESOURCES
Impact CULT-1: Historical Resources. No historical
resources have been recorded on the project site.

However, buildings of at least 50 years of age may exist.

PS CULT-1: Based on a determination of potential historical value by the Community Development Director, prior to issuance of a development permit for a site within the Copper Trails Specific Plan area, existing buildings or other structures on the site that are 50 years of age or older shall be evaluated by a qualified architectural historian to determine if they are eligible for listing on the National Register of Historic Places and/or the California Register of Historical Resources. Should any buildings be found eligible for such designation(s), then the architectural historian shall make recommendations concerning the
disposition of the identified buildings, which shall be implemented by the project developer. Recommendations may include, but are not limited to, preservation of the existing structure or reuse of the structure in accordance with historic property standards of the U.S. Secretary of the Interior.

LS
Impact CULT-2: Archaeological Resources. No
archaeological resources have been recorded on the
project site. However, it is possible that currently
unknown cultural resources may be uncovered during
project construction.

PS CULT-2: If any subsurface cultural resources are encountered during project construction that occurs within the Copper Trails Specific Plan area, the City of Ceres Community Development Department shall be immediately notified of the discovery, and all construction activity within 50 feet of the find shall be halted.

A qualified archaeologist shall examine the find and determine its significance. If the find is determined to be significant, then the archaeologist shall recommend further mitigation measures that would reduce potential effects on the find to a level that is less than significant. Recommended measures may include, but are not limited to, 1) avoidance and preservation in place, or 2) LS
EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-12 March 2026 excavation, recovery, and curation by qualified professionals.

Construction activities in the area of the find shall not resume until the mitigation measures are in place. The project developer shall be responsible for retaining qualified
professionals, implementing recommended mitigation
measures, and documenting mitigation efforts in a written report to the City’s Development Services Department,
consistent with the requirements of the CEQA Guidelines.

Impact CULT-3: Tribal Cultural Resources. No tribal
cultural resources have been identified on the project site.

However, it is possible that currently unknown tribal
cultural resources may be disturbed during project
construction.

PS CULT-3: If any subsurface tribal cultural resources, including human burials and associated funerary objects, are encountered during construction, all construction activities within a 50-foot radius of the encounter shall be immediately halted until a qualified archaeologist can examine these materials and evaluate their significance. The City shall be immediately notified in the event of a discovery, and the City shall notify the appropriate tribal representative, who may examine the
materials with the archaeologist and advise the City as to their significance. The archaeologist, in consultation with the tribal representative if contacted, shall recommend mitigation measures needed to reduce potential cultural resource effects to a level that is less than significant in a written report to the City, with a copy to the tribal representative. Avoidance is the preferred means of disposition of tribal cultural resources, but other means may be pursued. Construction activities in the area of the find shall not resume until the mitigation measures are in place. The contractor shall be responsible for retaining qualified professionals, implementing recommended mitigation
measures, and documenting mitigation efforts in written reports to the City.

CULT-4: In accordance with California Health and Safety Code Section 7050.5, if human remains are uncovered during project construction, then all work in the vicinity of the find shall be halted, and the County Coroner shall be immediately notified to determine if an investigation of the death is required. If it is determined that the remains are Native American in origin, then the County Coroner is required to contact the Native American Heritage Commission within 24 hours. The Native American Heritage Commission is required to identify the Most Likely Descendants of the deceased Native American, and the Most Likely Descendants may make recommendations on the
LS
EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-13 March 2026 disposition of the remains and any associated grave goods with appropriate dignity. If a Most Likely Descendant cannot be identified or fails to make a recommendation, or the landowner rejects the recommendations of the Most Likely Descendant, then the landowner shall rebury the remains and associated grave goods with appropriate dignity on the property in a location not subject to further disturbance.

Implementation of Mitigation Measure CULT-2

9.0 GEOLOGY, SOILS, AND MINERAL RESOURCES
Impact GEO-1: Fault Rupture, Seismic Shaking, and
Seismically Induced Failure. There are no active or
potentially active faults located on or in the vicinity of the project site. Routine implementation and enforcement of the California Building Code would minimize seismicity
impacts on new development.

LS None required. -
Impact GEO-2: Soil Erosion. Project construction activities would loosen the soil, leaving it exposed to potential
water and wind erosion. Project would be required to
obtain a Construction General Permit, which has
conditions that would reduce soil erosion impact, and
would comply with the City’s Storm Water Management
Program.

LS None required. -
Impact GEO-3: Exposure to or Effects on Unstable Geologic Units or Soils. The potential hazards of unstable soil or geologic units would be addressed largely through the
integration of geotechnical information in the planning and design process for projects, in accordance with
standard industry practices and state-provided
requirements.

LS None required. -
Impact GEO-4: Expansive Soils. Project site soils have low shrink-swell potential.

LS None required. -
Impact GEO-5: Adequacy of Soils for On-Site Wastewater
Disposal Systems. Future development within the project NI None required. -
EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-14 March 2026 site would be served by the City of Ceres wastewater
collection and treatment system.

Impact GEO-6: Paleontological Resources and Unique
Geological Features. The project site does not contain
unique geological features or any known paleontological resources; however, project construction could unearth
previously unknown paleontological materials of
significance.

PS GEO-1: If paleontological resources are encountered during project construction, the City of Ceres shall be immediately notified of the discovery, and construction activity within 50 feet of the encounter shall cease until a qualified paleontologist examines the materials, determines their significance under CEQA, and recommends mitigation measures that would be
necessary to reduce potentially significant effects to a level that is less than significant. The developer or its contractor shall be responsible for retaining a qualified paleontologist and for implementing recommended mitigation measures. Construction activities in the area of the find shall not resume until the mitigation measures are in place.

LS
Impact GEO-7: Mineral and Energy Resources. There are
no identified mineral resource areas, including oil and gas fields, on the project site.

NI None required. -

10.0 GREENHOUSE GAS EMISSIONS
Impact GHG-1: GHG Emissions from Construction
Activities. GHG emissions from a maximum construction
year would not exceed a quantitative threshold used to
determine significance of impact.

LS None required. -
Impact GHG-2: GHG Emissions from Project Operations.

Unmitigated operational GHG emissions would be reduced
by project features, but impacts would remain significant and unavoidable.

SU Project features will reduce GHG emissions. No other mitigation measures are available.

SU
Impact GHG-3: Consistency with Applicable GHG Plans and Policies. Project reductions would be consistent with
targets of SB 32 and the implementing Scoping Plan.

LS None required. -

11.0 HAZARDS AND HAZARDOUS MATERIALS
Impact HAZ-1: Hazardous Material Transportation.

Compliance with applicable local, state, and federal
regulations would minimize impacts.

LS None required. -
EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-15 March 2026 Impact HAZ-2: Hazardous Material Storage and Use.

Compliance with applicable local, state, and federal
regulations would minimize impacts. Also, agricultural
chemicals currently in use in CTSP Area would be
eliminated.

LS None required. -
Impact HAZ-23: Hazardous Material Releases. Compliance
with applicable local, state, and federal regulations would minimize potential releases. Schools located within the CTSP Area would not be exposed to any releases.

LS None required. -
Impact HAZ-34: Hazardous Material Sites. No active
hazardous material sites were identified on the project site. Past agricultural activities within the CTSP Area have the potential of leaving hazardous materials that could be released. Also, demolition of older buildings could release asbestos and lead-based paints into the environment.

PS HAZ-1: Prior to approval of a site plan or a tentative subdivision map for future development, a Phase I Environmental Site Assessment shall be conducted and submitted to the City Community Development Department. The Phase I Assessment shall evaluate the site for potential contamination, including residues of agricultural chemicals on sites of previous agricultural land use. If the Phase I Assessment determines the potential presence of any hazardous material contamination, then a Phase II Environmental Site assessment shall be conducted to identify the type and extent of hazardous material contamination. If necessary, the Phase II report shall include remediation measures. Project approval shall include requirements for completion of any Phase II remediation needed to permit the proposed land use under existing applicable regulations.

HAZ-2: If evidence of unusual odors or soil discoloration is noted during construction, construction shall be halted and the City shall be notified. The property owner or responsible party shall contact a qualified environmental professional to evaluate the situation and take action as required by applicable environmental regulations. Construction work at the identified site shall not resume until the site is either remediated or found to pose no risk to worker health.

HAZ-3: Demolition permits shall be obtained from the City for structures to be removed from development sites. Demolition would occur in accordance with the conditions of the City Demolition Permit, which shall include a Demolition Plan that is reviewed and approved by the Building Official. The Demolition Plan shall include the required qualifications of demolition LS
EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-16 March 2026 contractors, demolition procedures, safety requirements, testing for hazardous materials that shall include asbestos-containing material and lead-based paint, waste disposal worker and public health, and environmental protections. Permit applications for uses regulated shall include a Demolition Permit Release Form from the SJVAPCD.

Impact HAZ-45: Airport Hazards. A portion of the project site is within the Airport Influence Area established for the Modesto City-County Airport.

PS HAZ-4: For projects located within the Airport Influence Area of the Modesto City-County Airport, as delineated within the Stanislaus County Airport Land Use Compatibility Plan, site plan and design review submittals for the project shall be referred to the Stanislaus County Airport Land Use Commission for its review and recommendations. Implementation of applicable recommendations of the Airport Land Use Commission shall be made a condition of City approval unless the City overrides any recommendation in accordance with State law.

LS
Impact HAZ-56: Interference with Emergency Vehicle
Access and Evacuations. The project would also include
improvements to existing roadways that could potentially interfere with emergency vehicle access and evacuations in the area.

PS HAZ-5: Encroachment permits for work within the public rightof-way shall be obtained from the City of Ceres. As a condition of the permit, and prior to the start of project construction, the permittee shall prepare and implement a Traffic Control Plan, which shall include such items as traffic control requirements, resident notification of access closure, and daily access restoration. The contractor shall specify dates and times of road closures or restrictions, if any, and shall ensure that adequate access will be provided for emergency vehicles. The Traffic Control Plan shall be reviewed and approved by the City Department of Public Works and shall be coordinated with the Ceres Police Department and the applicable firefighting agency if construction will require road closures or lane restrictions.

LS
Impact HAZ-67: Wildfire Hazards. Project is in an
urbanizing area and has not been designated a fire hazard area by Cal Fire.

LS None required. -
Impact HAZ-78: Waterway Hazards. Residential
development adjacent to TID Lower Lateral 2 could lead
to trespassing that could endanger trespassers.

PS HAZ-6: Prior to the start of development within the Copper Trails Specific Plan area, design plans for any trails along Turlock Irrigation District (TID) canals shall be submitted to TID for its review and approval. TID approval shall be obtained for any trail construction along the TID canals.

LS
EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-17 March 2026 Impact HAZ-89: Railroad Hazards. Although project site is adjacent to UPRR tracks, it is unlikely that pedestrian or vehicle accidents at the tracks would increase in the area.

LS None required. -

12.0 HYDROLOGY AND WATER QUALITY
Impact HYDRO-1: Surface Water Features and Quality.

There are no existing natural surface waters within the project site. Surface runoff may contain urban pollutants, along with sediments, that could degrade surface water
quality. Compliance with the City’s Storm Water
Management Program, the Construction General Permit,
and other regulations would minimize this impact.

LS None required. -
Impact HYDRO-2: Groundwater Resources and Quality.

Project would be served by the City’s water system, which relies in part on groundwater. Project can be
accommodated from City’s existing groundwater supplies.

Project may reduce groundwater recharge through
increased impervious surfaces, but the impact is not
considered substantial. Existing groundwater wells would need to be plugged over course of development.

PS HYDRO-1: Prior to the start of development within any portion of the Copper Trails Specific Plan area, any remaining existing groundwater wells shall be plugged and abandoned in
accordance with the requirements of the Stanislaus County Department of Environmental Resources and the provisions of California Water Code Section 13751.

HYDRO-2: For areas containing a shallow groundwater table, a dewatering permit shall be obtained from the RWQCB prior to the start of construction activities. Dewatering shall be done in accordance with the conditions of the permit.

LS
Impact HYDRO-3: Exposure to Flooding Hazards. The
project site is not within a designated 100-year flood zone nor a potential dam failure inundation zone.

LS None required. -
Impact HYDRO-4: Conflict with Water Plans. The project
would comply with applicable water quality plans and be consistent with the Groundwater Sustainability Plan for the Turlock Groundwater Subbasin.

LS None required. -

13.0 LAND USE, POPULATION, AND HOUSING
Impact LUP-1: Division of Established Communities. The
CTSP Area is mostly agricultural uses with school
development. This does not constitute a community that
NI None required. -
EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-18 March 2026 could be divided by the project. The Pocket Area would be annexed to the City of Ceres.

Impact LUP-2: Conflict with Land Use Plans, Policies, and Regulations. With adoption of the required General Plan Amendments, the designations within the proposed CTSP
Area would be consistent with the Ceres General Plan.

Potential conflicts with General Plan policies designed to avoid or minimize environmental effects would be
resolved. Project may conflict with LAFCo policies
preserving agricultural land, but project would be subject to the Agricultural Preservation Policy. Project would not substantially conflict with Modesto Airport ALUCP.

LS None required. -
Impact LUP-3: Unplanned Population Growth. The project
would not induce population growth beyond that
anticipated in the Ceres General Plan.

LS None required. -
Impact LUP-4: Displacement of Housing and People. The
project site has single-family residences that would likely be demolished. However, the housing stock in the Ceres
area would increase, and plans to vacate and demolish
existing residences would be subject to agreements and
negotiations between developers and owners, or owners
and tenants.

LS None required. -

14.0 NOISE
Impact NOISE-1: Increase in Noise Levels in Excess of
Standards-Traffic. Traffic generated under Near Term Plus Project conditions would increase traffic noise levels along East Service Road by an amount exceeding applicable
significance thresholds. Mitigation would reduce this
impact.

S NOISE-1:To reduce traffic noise increases under Near-Term Plus Project conditions to less than +1.5 dB, the segment of East Service Road north of the Copper Trails Specific Plan boundary shall be paved with quiet pavement. The pavement would be required for any portion of the roadway passing a noisesensitive use, and for a distance of 100 feet on either side of the sensitive use.

LS
Impact NOISE-2: Increase in Noise Levels in Excess of
Standards-Other Project Noise. Noise from commercial
operations were determined to not significantly affect
nearby sensitive land uses, mainly residences. However, PS NOISE-2: To ensure compliance with the City’s noise level standards for stationary noise sources, the setback distances for the land uses listed in Table 14-7 of this EIR shall be maintained.

In lieu of this measure, an acoustical analysis may be performed by a qualified acoustical consultant demonstrating compliance with the City’s noise level standards.

LS
EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-19 March 2026 specific land uses could adversely affect nearby residences if placed too closely. NOISE-2:Proposed commercial and active sports recreational projects shall be subject to a preliminary review by Community Development staff for potentially significant noise impacts.

Where potential noise impacts may be significant, an acoustical analysis shall be performed by a qualified acoustical consultant as to the project’s consistency with exceed the City’s noise level standards and mitigation measures needed to bring the
proposed source into compliance with City standards.

Impact NOISE-3: Increase in Noise Levels in Excess of
Standards-Construction. Construction activities may
potentially increase ambient noise above City standards at nearby sensitive receptors.

PS NOISE-3:The City shall establish the following as conditions of approval for any permit that results in the use of construction equipment:
● Construction shall be limited to 7:00 a.m. to 8:00 p.m. unless allowed by special permit issued by the Building Inspector or City Engineer.
● All construction equipment powered by internal
combustion engines shall be properly muffled and
maintained.
● Quiet construction equipment, particularly air
compressors, are to be selected whenever possible.
● All stationary noise-generating construction equipment such as generators or air compressors are to be located as far as is practical from existing residences. In addition, the project contractor shall place such stationary construction equipment so that emitted noise is directed away from
sensitive receptors closest to the project site.
● Unnecessary idling of internal combustion engines is
prohibited. In accordance with State regulations, idling shall be limited to no more than five minutes.
● The construction contractor shall, to the maximum extent practical, locate on-site equipment staging areas to maximize the distance between construction-related noise sources and noise-sensitive receptors nearest the project site during all project construction.

LS
EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-20 March 2026 Impact NOISE-4: Groundborne Vibrations. Project
construction activities would not generate groundborne
vibrations at a level that would disturb people or risk damage to buildings.

LS None required. -
Impact NOISE-5: Airport and Airstrip Noise. The project site is outside noise contours established by the Modesto City-County Airport ALUCP. No private airstrips are in the vicinity.

NI None required. -

15.0 PUBLIC SERVICES AND RECREATION
Impact PSR-1: Fire Protection Service. New or expanded
facilities may be required in the future, but project has set aside land for a future fire station. Public Facility Fees will be paid, and the impacts of future development of a public facility are analyzed in this EIR.

LS None required. -
Impact PSR-2: Police Protection Services. New or
expanded facilities may be required in the future, but
project has set aside land for a future police station. Public Facility Fees will be paid, and the impacts of future
development of a public facility are analyzed in this EIR.

LS None required. -
Impact PSR-3: Schools. The project would generate new
students requiring services from the Ceres Unified School District. New development would be responsible for the
payment of school impact fees, the payment of which is
considered mitigation of impacts by State law.

LS None required. -
Impact PSR-4: Parks and Recreational Services. The CTSP would provide parkland at a population ratio that exceeds City standards.

LS None required. -
Impact PSR-5: Other Public Facilities. The project would not generate additional demand for library, hospital, and courthouse services, and therefore would not require new or expanded facilities.

LS None required. -
EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-21 March 2026

16.0 TRANSPORTATION
Impact TRANS-1: Conflict with Circulation Plans – Motor Vehicle. None of the roadway segments studied would
have LOS that would be unacceptable by City standards.

As such, the CTSP would be consistent with Ceres General Plan policies applicable to LOS. The CTSP is not expected to interfere with the implementation of 2022 RTP
projects, including the SR 99/Mitchell Road/Service Road interchange project.

LS None required. -
Impact TRANS-2: Conflict with Circulation Plans NonMotor Vehicle. The CTSP would not impact existing or proposed public transit, pedestrian or bicycle facilities in a way that would discourage their use. Therefore, it would not conflict with plans intended to promote the use of
these alternative modes of transportation.

LS None required. -
Impact TRANS-3: Vehicle Miles Traveled. Based on
thresholds developed for the project, the project would have a significant impact on VMT. Mitigation has the
potential to reduce impact to an estimated 12.2%, just
short of 15% to reach less than significant.

S TRANS-1: Prior to final approval of the Copper Trails Specific Plan, the City and the project applicant shall meet to discuss measures to reduce vehicle miles traveled generated by
residential and office land uses within in Specific Plan area. The measures shall demonstrate quantitatively that the resultant vehicle miles traveled generated by residential and office land uses shall be under the respective significance thresholds for these land uses, as established in the Copper Trails Specific Plan Transportation Impact Analysis prepares by Wood Rogers in March 2024. This measures shall be incorporated within the Copper Trails Specific Plan.

Other mitigation listed in Chapter 4.0 Errata would be assigned during review of future CTSP projects, which would increase potential VMT mitigation, but still leave the impact potentially significant and unavoidable.

SU
Impact TRANS-4: Traffic Hazards - Collisions. Project
traffic would use interchanges with below-average
collision rates. Construction of planned Service Road
interchange would further reduce rates.

LS None required. -
Impact TRANS-5: Traffic Hazards - Queuing. Project would lead to excessive queuing at off-ramp and on-ramp at
SU TRANS-2: The project shall contribute full costs to the reconfiguration of the proposed SR 99 southbound off-ramp to LS SU
EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-22 March 2026 Service Road interchange in the short term. Mitigation
would lead to acceptable queuing.

Service Road to include two southbound right-turn lanes and one southbound left-turn lane. Fair-share costs shall be determined by the City Engineer in coordination with the California Department of Transportation.

TRANS-3: The project shall contribute full costs to widening the eastbound entrance to the SR 99 northbound on-ramp at the Service Road interchange to two lanes and to converting the eastbound approach of Service Road at the SR 99 northbound on-ramp to consist of one dedicated left-turn trap lane onto the ramp, one shared left-through-lane, and one through lane. Fairshare costs shall be determined by the City Engineer in coordination with the California Department of Transportation.

None available other than planned interchange reconstruction; however, interchange reconstruction is expected to occur well ahead of CTSP buildout. Impact may be significant and
unavoidable but only in the short term.

Impact TRANS-6: Emergency Access. Adequate emergency
access would be provided to the entire project site.

LS None required. -

17.0 UTILITIES AND ENERGY
Impact UTIL-1: Relocation and Construction of
Infrastructure Facilities. Pocket Area served by existing infrastructure. The CTSP Area would require new
infrastructure, which would be provided in accordance
with City and State requirements and standards. Project may require removal or relocation of TID facilities.

PS UTIL-1: Prior to the start of development that impacts TID irrigation facilities, the project shall design one or more method acceptable to the City and TID that will minimize or avoid the impacts of development on the continued operation of existing TID irrigation facilities. The agreed-upon methods shall be incorporated as applicable into the design and construction of future development.

LS
Impact UTIL-2: Availability of Adequate Domestic Water
Supply. City has adequate water supplies for project, even during multiple dry years.

LS None required. -
Impact UTIL-3: Wastewater System Capacity. City has
adequate capacity at its treatment plant to accommodate project.

LS None required. -
EXHIBIT A ITEM 13
TABLE 2-1
REVISED SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation, Final EIR 2-23 March 2026 Impact UTIL-4: Storm Drainage Services. Project would
connect to City’s drainage system in accordance with
applicable City standards, specifications, and plans.

LS None required. -
Impact UTIL-5: Irrigation Water Systems. Demand for TID irrigation water would decrease with CTSP development.

Storm drainage discharges to TID canals, if any, would be subject to the provisions of the Master Storm Drain
Agreement between TID and the City.

LS None required. -
Impact UTIL-6: Solid Waste. Fink Road Landfill in the
County would have adequate capacity to accommodate
project solid waste. The project would comply with
applicable federal, state, and local statutes and regulations related to solid waste.

LS None required. -
Impact UTIL-7: Energy Consumption. The project would
not consume energy in a manner that is wasteful,
inefficient, or unnecessary due to compliance with
California Energy Code and CALGreen.

LS None required. -
Notes: S = Significant, PS = Potentially Significant, LS = Less than Significant, NI = No Impact, SU = Significant and Unavoidable (SU impacts addressed in the Ceres General Plan EIR).

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-1 March 2026

3.0 COMMENTS ON DRAFT EIR AND LEAD AGENCY
RESPONSES TO COMMENTS
This chapter displays the letters and other written comment received on the Draft EIR for the Copper Trails Specific Plan and Annexation Project; the Lead Agency's written responses to those comments are provided following each comment letter.

A total of 8 comment letters were received during the Draft EIR review period. One additional comment was submitted by attorneys for the Ceres Unified School District on August 29, 2025, approximately eight months after the close of the review period in December 2024.A list of agencies, organizations and persons that submitted comments during the review period is shown below. As required by CEQA, the City’s proposed responses to substantive comments from agencies were provided to the commenting agencies at least 10 days before the planned certification of the Final EIR.

Comments Received on the Public Review Draft EIR

1. Pacific Gas and Electric Company (6 pages)

2. State Water Resources Control Board (3 pages)

3. California Department of Fish and Wildlife (10 pages)

4. Stanislaus LAFCo (4 pages)

5. John and Patti Warren (2 pages)

6. Stanislaus County Department of Environmental Resources (1 page)

7. San Joaquin Valley Air Pollution Control District (15 pages)

8. Stanislaus County Chief Executive Office (4 pages)

9. Lozano Smith for Ceres Unified School District (16 pages) CEQA Guidelines Section 15088 states that the Lead Agency’s responses shall describe the disposition of significant environmental issues raised in comments on the Draft EIR.

In particular, the major environmental issues raised when the Lead Agency’s position is at variance with recommendations and objections raised in the comments must be addressed in detail, giving reasons why specific comments and suggestions were not accepted. There must be good-faith, reasoned analysis in response to comments; responses may not be conclusory but rather must be supported by substantial evidence.

Each of the comment letters related to the Draft EIR and are shown in full on the following pages. The comment letters appear in number order together with the comment number and commenter name at the bottom of each page. Each comment letter is followed by the Lead Agency’s response(s) to the individual comments in each letter, in EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-2 March 2026 sequence. Each comment letter is assigned a number code from the list shown above, and each comment within the numbered letter is assigned an alphabetical code. Thus, each comment has a unique code made up of the letter number and the alphabetical comment code. For example, comment “1A” is the first comment made by Commenter #1, the Pacific Gas and Electric Company.

EXHIBIT A ITEM 13
COMMENT NO. 1
PACIFIC GAS AND ELECTRIC
Plan Review Team
Land Management
[email protected]
PG&E Gas and Electric Facilities Page 1
Public
December 17, 2024
Lea Simvoulakis
City of Ceres
2220 Magnolia Street
Ceres, CA 95307
Ref: Gas and Electric Transmission and Distribution
Dear Lea Simvulakis,
Thank you for submitting the Copper Trails plans for our review. PG&E will review the submitted plans in relationship to any existing Gas and Electric facilities within the project area. If the proposed project is adjacent/or within PG&E owned property and/or easements, we will be working with you to ensure compatible uses and activities near our facilities.

Attached you will find information and requirements as it relates to Gas facilities (Attachment 1) and Electric facilities (Attachment 2). Please review these in detail, as it is critical to ensure your safety and to protect PG&E’s facilities and its existing rights.

Below is additional information for your review:

1. This plan review process does not replace the application process for PG&E gas or electric service your project may require. For these requests, please continue to work with PG&E Service Planning: https://www.pge.com/en/account/servicerequests/building-and-renovation.html.

2. If the project being submitted is part of a larger project, please include the entire scope of your project, and not just a portion of it. PG&E’s facilities are to be incorporated within any CEQA document. PG&E needs to verify that the CEQA document will identify any required future PG&E services.

3. An engineering deposit may be required to review plans for a project depending on the size, scope, and location of the project and as it relates to any rearrangement or new installation of PG&E facilities.

Any proposed uses within the PG&E fee strip and/or easement, may include a California Public Utility Commission (CPUC) Section 851 filing. This requires the CPUC to render approval for a conveyance of rights for specific uses on PG&E’s fee strip or easement. PG&E will advise if the necessity to incorporate a CPUC Section 851filing is required.

This letter does not constitute PG&E’s consent to use any portion of its easement for any purpose not previously conveyed. PG&E will provide a project specific response as required.

Sincerely,
Plan Review Team
Land Management
1A
EXHIBIT A ITEM 13
COMMENT NO. 1
PACIFIC GAS AND ELECTRIC
PG&E Gas and Electric Facilities Page 2
Public
Attachment 1 – Gas Facilities
There could be gas transmission pipelines in this area which would be considered critical facilities for PG&E and a high priority subsurface installation under California law. Care must be taken to ensure safety and accessibility. So, please ensure that if PG&E approves work near gas transmission pipelines it is done in adherence with the below stipulations. Additionally, the following link provides additional information regarding legal requirements under California excavation laws: https://www.usanorth811.org/images/pdfs/CA-LAW-2018.pdf

1. Standby Inspection: A PG&E Gas Transmission Standby Inspector must be present during any demolition or construction activity that comes within 10 feet of the gas pipeline. This includes all grading, trenching, substructure depth verifications (potholes), asphalt or concrete demolition/removal, removal of trees, signs, light poles, etc. This inspection can be coordinated through the Underground Service Alert (USA) service at 811. A minimum notice of 48 hours is required. Ensure the USA markings and notifications are maintained throughout the duration of your work.

2. Access: At any time, PG&E may need to access, excavate, and perform work on the gas pipeline. Any construction equipment, materials, or spoils may need to be removed upon notice.

Any temporary construction fencing installed within PG&E’s easement would also need to be capable of being removed at any time upon notice. Any plans to cut temporary slopes exceeding a 1:4 grade within 10 feet of a gas transmission pipeline need to be approved by PG&E Pipeline Services in writing PRIOR to performing the work.

3. Wheel Loads: To prevent damage to the buried gas pipeline, there are weight limits that must be enforced whenever any equipment gets within 10 feet of traversing the pipe.

Ensure a list of the axle weights of all equipment being used is available for PG&E’s Standby Inspector. To confirm the depth of cover, the pipeline may need to be potholed by hand in a few areas.

Due to the complex variability of tracked equipment, vibratory compaction equipment, and cranes, PG&E must evaluate those items on a case-by-case basis prior to use over the gas pipeline (provide a list of any proposed equipment of this type noting model numbers and specific attachments).

No equipment may be set up over the gas pipeline while operating. Ensure crane outriggers are at least 10 feet from the centerline of the gas pipeline. Transport trucks must not be parked over the gas pipeline while being loaded or unloaded.

4. Grading: PG&E requires a minimum of 36 inches of cover over gas pipelines (or existing grade if less) and a maximum of 7 feet of cover at all locations. The graded surface cannot exceed a cross slope of 1:4.

5. Excavating: Any digging within 2 feet of a gas pipeline must be dug by hand. Note that while the minimum clearance is only 24 inches, any excavation work within 24 inches of the edge of a pipeline must be done with hand tools. So to avoid having to dig a trench entirely with hand tools, the edge of the trench must be over 24 inches away. (Doing the math for a 24 inch EXHIBIT A ITEM 13
COMMENT NO. 1
PACIFIC GAS AND ELECTRIC
PG&E Gas and Electric Facilities Page 3
Public
wide trench being dug along a 36 inch pipeline, the centerline of the trench would need to be at least 54 inches [24/2 + 24 + 36/2 = 54] away, or be entirely dug by hand.) Water jetting to assist vacuum excavating must be limited to 1000 psig and directed at a 40° angle to the pipe. All pile driving must be kept a minimum of 3 feet away.

Any plans to expose and support a PG&E gas transmission pipeline across an open excavation need to be approved by PG&E Pipeline Services in writing PRIOR to performing the work.

6. Boring/Trenchless Installations: PG&E Pipeline Services must review and approve all plans to bore across or parallel to (within 10 feet) a gas transmission pipeline. There are stringent criteria to pothole the gas transmission facility at regular intervals for all parallel bore installations.

For bore paths that cross gas transmission pipelines perpendicularly, the pipeline must be potholed a minimum of 2 feet in the horizontal direction of the bore path and a minimum of 24 inches in the vertical direction from the bottom of the pipe with minimum clearances measured from the edge of the pipe in both directions. Standby personnel must watch the locator trace (and every ream pass) the path of the bore as it approaches the pipeline and visually monitor the pothole (with the exposed transmission pipe) as the bore traverses the pipeline to ensure adequate clearance with the pipeline. The pothole width must account for the inaccuracy of the locating equipment.

7. Substructures: All utility crossings of a gas pipeline should be made as close to perpendicular as feasible (90° +/- 15°). All utility lines crossing the gas pipeline must have a minimum of 24 inches of separation from the gas pipeline. Parallel utilities, pole bases, water line ‘kicker blocks’, storm drain inlets, water meters, valves, back pressure devices or other utility substructures are not allowed in the PG&E gas pipeline easement.

If previously retired PG&E facilities are in conflict with proposed substructures, PG&E must verify they are safe prior to removal. This includes verification testing of the contents of the facilities, as well as environmental testing of the coating and internal surfaces. Timelines for PG&E completion of this verification will vary depending on the type and location of facilities in conflict.

8. Structures: No structures are to be built within the PG&E gas pipeline easement. This includes buildings, retaining walls, fences, decks, patios, carports, septic tanks, storage sheds, tanks, loading ramps, or any structure that could limit PG&E’s ability to access its facilities.

9. Fencing: Permanent fencing is not allowed within PG&E easements except for perpendicular crossings which must include a 16 foot wide gate for vehicular access. Gates will be secured with PG&E corporation locks.

10. Landscaping: Landscaping must be designed to allow PG&E to access the pipeline for maintenance and not interfere with pipeline coatings or other cathodic protection systems. No trees, shrubs, brush, vines, and other vegetation may be planted within the easement area.

Only those plants, ground covers, grasses, flowers, and low-growing plants that grow unsupported to a maximum of four feet (4’) in height at maturity may be planted within the easement area.

EXHIBIT A ITEM 13
COMMENT NO. 1
PACIFIC GAS AND ELECTRIC
PG&E Gas and Electric Facilities Page 4
Public

11. Cathodic Protection: PG&E pipelines are protected from corrosion with an “Impressed Current” cathodic protection system. Any proposed facilities, such as metal conduit, pipes, service lines, ground rods, anodes, wires, etc. that might affect the pipeline cathodic protection system must be reviewed and approved by PG&E Corrosion Engineering.

12. Pipeline Marker Signs: PG&E needs to maintain pipeline marker signs for gas transmission pipelines in order to ensure public awareness of the presence of the pipelines.

With prior written approval from PG&E Pipeline Services, an existing PG&E pipeline marker sign that is in direct conflict with proposed developments may be temporarily relocated to accommodate construction work. The pipeline marker must be moved back once construction is complete.

13. PG&E is also the provider of distribution facilities throughout many of the areas within the state of California. Therefore, any plans that impact PG&E’s facilities must be reviewed and approved by PG&E to ensure that no impact occurs which may endanger the safe operation of its facilities.

EXHIBIT A ITEM 13
COMMENT NO. 1
PACIFIC GAS AND ELECTRIC
PG&E Gas and Electric Facilities Page 5
Public
Attachment 2 – Electric Facilities
It is PG&E’s policy to permit certain uses on a case by case basis within its electric transmission fee strip(s) and/or easement(s) provided such uses and manner in which they are exercised, will not interfere with PG&E’s rights or endanger its facilities. Some examples/restrictions are as follows:

1. Buildings and Other Structures: No buildings or other structures including the foot print and eave of any buildings, swimming pools, wells or similar structures will be permitted within fee strip(s) and/or easement(s) areas. PG&E’s transmission easement shall be designated on subdivision/parcel maps as “RESTRICTED USE AREA – NO BUILDING.”

2. Grading: Cuts, trenches or excavations may not be made within 25 feet of our towers.

Developers must submit grading plans and site development plans (including geotechnical reports if applicable), signed and dated, for PG&E’s review. PG&E engineers must review grade changes in the vicinity of our towers. No fills will be allowed which would impair ground-toconductor clearances. Towers shall not be left on mounds without adequate road access to base of tower or structure.

3. Fences: Walls, fences, and other structures must be installed at locations that do not affect the safe operation of PG&’s facilities. Heavy equipment access to our facilities must be maintained at all times. Metal fences are to be grounded to PG&E specifications. No wall, fence or other like structure is to be installed within 10 feet of tower footings and unrestricted access must be maintained from a tower structure to the nearest street. Walls, fences and other structures proposed along or within the fee strip(s) and/or easement(s) will require PG&E review; submit plans to PG&E Centralized Review Team for review and comment.

4. Landscaping: Vegetation may be allowed; subject to review of plans. On overhead electric transmission fee strip(s) and/or easement(s), plant only low-growing shrubs under the wire zone and only grasses within the area directly below the tower. Along the border of the transmission line right-of-way, plant only small trees no taller than 10 feet in height at maturity. PG&E must have access to its facilities at all times, including access by heavy equipment. No planting is to occur within the footprint of the tower legs. Greenbelts are encouraged.

5. Reservoirs, Sumps, Drainage Basins, and Ponds: Prohibited within PG&E’s fee strip(s) and/or easement(s) for electric transmission lines.

6. Automobile Parking: Short term parking of movable passenger vehicles and light trucks (pickups, vans, etc.) is allowed. The lighting within these parking areas will need to be reviewed by PG&E; approval will be on a case by case basis. Heavy equipment access to PG&E facilities is to be maintained at all times. Parking is to clear PG&E structures by at least 10 feet.

Protection of PG&E facilities from vehicular traffic is to be provided at developer’s expense AND to PG&E specifications. Blocked-up vehicles are not allowed. Carports, canopies, or awnings are not allowed.

7. Storage of Flammable, Explosive or Corrosive Materials: There shall be no storage of fuel or combustibles and no fueling of vehicles within PG&E’s easement. No trash bins or incinerators are allowed.

EXHIBIT A ITEM 13
COMMENT NO. 1
PACIFIC GAS AND ELECTRIC
PG&E Gas and Electric Facilities Page 6
Public

8. Streets and Roads: Access to facilities must be maintained at all times. Street lights may be allowed in the fee strip(s) and/or easement(s) but in all cases must be reviewed by PG&E for proper clearance. Roads and utilities should cross the transmission easement as nearly at right angles as possible. Road intersections will not be allowed within the transmission easement.

9. Pipelines: Pipelines may be allowed provided crossings are held to a minimum and to be as nearly perpendicular as possible. Pipelines within 25 feet of PG&E structures require review by PG&E. Sprinklers systems may be allowed; subject to review. Leach fields and septic tanks are not allowed. Construction plans must be submitted to PG&E for review and approval prior to the commencement of any construction.

10. Signs: Signs are not allowed except in rare cases subject to individual review by PG&E.

11. Recreation Areas: Playgrounds, parks, tennis courts, basketball courts, barbecue and light trucks (pickups, vans, etc.) may be allowed; subject to review of plans. Heavy equipment access to PG&E facilities is to be maintained at all times. Parking is to clear PG&E structures by at least 10 feet. Protection of PG&E facilities from vehicular traffic is to be provided at developer’s expense AND to PG&E specifications.

12. Construction Activity: Since construction activity will take place near PG&E’s overhead electric lines, please be advised it is the contractor’s responsibility to be aware of, and observe the minimum clearances for both workers and equipment operating near high voltage electric lines set out in the High-Voltage Electrical Safety Orders of the California Division of Industrial Safety (https://www.dir.ca.gov/Title8/sb5g2.html), as well as any other safety regulations.

Contractors shall comply with California Public Utilities Commission General Order 95 (http://www.cpuc.ca.gov/gos/GO95/go_95_startup_page.html) and all other safety rules. No construction may occur within 25 feet of PG&E’s towers. All excavation activities may only commence after 811 protocols has been followed.

Contractor shall ensure the protection of PG&E’s towers and poles from vehicular damage by (installing protective barriers) Plans for protection barriers must be approved by PG&E prior to construction.

13. PG&E is also the owner of distribution facilities throughout many of the areas within the state of California. Therefore, any plans that impact PG&E’s facilities must be reviewed and approved by PG&E to ensure that no impact occurs that may endanger the safe and reliable operation of its facilities.

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-9 March 2026 Responses to Pacific Gas and Electric Company, Letter of December 17, 2024
Response 1A: The comment letter and attachments appear to address general PG&E concerns related to potential future development projects that may result from City approval of the CTSP.

The City of Ceres Building and Public Works Departments are aware of the need to coordinate with PG&E and are routinely involved in referral of proposed projects to, and coordination with PG&E engineering staff. Where required, City referrals seek project-specific review and approval or recommendations from PG&E. Project-specific coordination with PG&E is mandatory where private development activities or City infrastructure improvements are in close proximity to PG&E facilities or may involve encroachment on those facilities. The Draft EIR identifies PG&E as the gas utility provider for the CTSP area. Turlock Irrigation District on the other hand is the electrical provider for the project area.

PG&E attaches information related to its requirements with respect to its gas (Attachment 1) and electrical (Attachment 2) facilities. These requirements are particularly relevant to design and construction safety associated with work adjacent to and across gas transmission facilities and can be expected to be applied by the utility as a part of its review of planned development activity within the project area.

EXHIBIT A ITEM 13
COMMENT NO. 2
STATE WATER RESOURCES CONTROL BOARD
State Water Resources Control Board
December 19, 2024
Lea Simvoulakis
City of Ceres
2220 Magnolia Street
Ceres, CA 95307

CITY OF CERES (CITY), ENVIRONMENTAL IMPACT REPORT (EIR) FOR THE COPPER TRAILS SPECIFIC PLAN AND ANNEXATION PROJECT (PROJECT); STATE CLEARINGHOUSE #2023090637
Dear Lea Simvoulakis:

Thank you for the opportunity to review the EIR for the proposed Project. The State Water Resources Control Board, Division of Drinking Water (State Water Board, DDW) is responsible for issuing water supply permits pursuant to the Safe Drinking Water Act.

This Project is within the jurisdiction of the State Water Board, DDW’s Stockton District.

DDW Stockton District issues domestic water supply permit amendments to public water systems pursuant to Waterworks Standards (Title 22 California Code of Regulations [Cal Code Regs.] chapter 16 et. seq.). A public water system requires a water supply permit amendment when changes are made to a domestic water supply source, storage, or treatment and for the operation of new water system componentsas specified in the Cal. Code Regs. § 64556.

The State Water Board, DDW, as a responsible agency under the California Environmental Quality Act (CEQA), has the following comments on the City’s EIR:
· The City will need to apply for a water supply permit amendment for approval of a new source (well) and operation of a new storage reservoir (PDF page 57). In the EIR, under subsection 1.3 EIR Requirements and Intended Uses, on PDF page 14, when identifying other potential responsible agencies, please include “the State Water Resources Control Board, Division of Drinking Water, Stockton District.” In Table 3-3 Required Permits and Approvals, Copper Trails Specific Plan (PDF pages 60 and 61), please include under “Agency”- “State Water Resources Control Board, Division of Drinking Water, Stockton District” and under “Permit/Approval”- “Approve water supply permit amendment.” · The EIR states that Cere’s groundwater supplies are treated at wellheads (PDF page 283). Possible contaminants in the Turlock Subbasin include: arsenic, uranium, manganese, sulfur, total dissolved solids, nitrates, salinity, 1,2,3- trichloropropane, tetrachlorethylene, and dibromochloropropane (PDF page 2A
2B
2C
EXHIBIT A ITEM 13
COMMENT NO. 2
STATE WATER RESOURCES CONTROL BOARD
Lea Simvoulakis - 2 - December 19, 2024
182). Please discuss the anticipated water quality of the new well at the proposed well site. If treatment may be needed, please discuss the possible types of treatment infrastructure that may be needed and the possible disposal of treatment waste, if applicable.
· The Project is proposing 2,392 new single and multi-residential units and the City currently has 11,881 connections, meeting the “project” and “public water system” thresholds under the Water Code, section 10912. The California Department of Water Resources Guidebook for Implementation of Senate Bill (SB) 610, identifies the SB 610 Water Supply Assessment (WSA) as occurring at a specific plan project level (https://cawaterlibrary.net/wpcontent/uploads/2017/06/guidebook.pdf, PDF page 15). Please provide the required WSA and summarize the information in the EIR. Otherwise, please further explain why a WSA does not apply.

When the CEQA review process is completed, please forward the following items with the permit application to the State Water Board, DDW Stockton District Office at [email protected]:
· Copy of the EIR and Mitigation Monitoring and Reporting Plan (MMRP); · Copy of all comment letters received and the lead agency responses as appropriate;
· Copy of the Resolution or Board Minutes certifying the EIR and adopting the MMRP; and
· Copy of the date stamped Notice of Determination filed at the Stanislaus County Clerk’s Office and the Governor’s Office of Land Use and Climate Innovation, State Clearinghouse.

Please contact Lori Schmitz of the State Water Board at (916) 449-5285 or [email protected], for questions regarding this comment letter.

Sincerely,
Lori Schmitz
Environmental Scientist
Division of Financial Assistance
Special Project Review Unit
1001 I Street, 16th floor
Sacramento, CA 95814
Cc:

Office of Planning and Research, State Clearinghouse
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EXHIBIT A ITEM 13
COMMENT NO. 2
STATE WATER RESOURCES CONTROL BOARD
Lea Simvoulakis - 3 - December 19, 2024
Bhupinder Sahota
District Engineer
Stockton District
Robert Lapp
Water Resources Control Engineer
Stockton District
EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-13 March 2026 Responses to State Water Resources Control Board, Letter of December 19, 2024
Response 2A: This initial portion of the SWRCB comment letter identifies the jurisdiction of the SWRCB’s Division of Drinking Water (DDW) as a permitting authority for changes and improvements to public water supply systems. The City’s potable water system is subject to DDW permit jurisdiction. As noted, improvements to the City’s potable water system needed to serve new urban development within the project area, including new water mains, storage, supply wells and treatment systems, may require one or more permit amendments, which will be clarified through coordination with DDW. The City of Ceres understands and expects to abide by all relevant drinking water requirements.

Response 2B: See Response 2A regarding compliance with the applicable SWRCB permit requirements. The recommended changes to the Draft EIR regarding DDW jurisdiction are incorporated in the EIR via FEIR Chapter 4.0 Errata.

Response 2C: The City understands and appreciates that a new groundwater well in the project area may contain contaminants such as those listed by the SWRCB. A new municipal well will be subject to DDW and County permitting and well production would be required to meet drinking water standards. If required, well development would involve installation of treatment equipment as dictated by applicable regulations and testing. Disposal of treatment waste, if any, will be determined based on future test data; water treatment waste will be transported to a disposal facility appropriately licensed to receive waste materials
Response 2D: The potential need for an SB 610 Water Supply Assessment (WSA) was specifically considered during the preparation of the Draft EIR, as documented on page 17-6. This analysis concluded that a WSA was not specifically required for a specific plan project, although SB 610 or SB 221 requirements may apply to subsequent development projects.

The SWRCB Guidebook identifies the Urban Water Management Plan as a key water supply planning document that can be used by a water supplier to fulfill the specific requirements of the two WSA statutes.

UWMP, which describes the City’s water system, water use, water supply sources and the reliability of the City’s water service for normal, dry, and five-year drought conditions for the next 20 years.

The UWMP planning area encompasses the City’s Sphere of Influence, which includes both the CTSP and Pocket Areas.

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-14 March 2026 Response 2E: Neither the City nor CTSP landowners and developers have specific short-term plans to modify the City’s water supply system; no new development pursuant to the CTSP will occur until after the specific plan is adopted by the City and the associated annexation is approved by the City and Stanislaus County LAFCo. Prior to development, applicants will need to prepare and submit improvement plans including water, wastewater and storm water disposal facilities to the City and other regulatory agencies. See also responses to Draft EIR comments submitted by LAFCo (Commenter No. 4). The
improvement-specific materials requested by the commenter will be submitted to the DDW by the City in conjunction with future applications for amendment of the City’s water supply permit.

EXHIBIT A ITEM 13
COMMENT NO. 2
STATE WATER RESOURCES CONTROL BOARD
State Water Resources Control Board
December 19, 2024
Lea Simvoulakis
City of Ceres
2220 Magnolia Street
Ceres, CA 95307

CITY OF CERES (CITY), ENVIRONMENTAL IMPACT REPORT (EIR) FOR THE COPPER TRAILS SPECIFIC PLAN AND ANNEXATION PROJECT (PROJECT); STATE CLEARINGHOUSE #2023090637
Dear Lea Simvoulakis:

Thank you for the opportunity to review the EIR for the proposed Project. The State Water Resources Control Board, Division of Drinking Water (State Water Board, DDW) is responsible for issuing water supply permits pursuant to the Safe Drinking Water Act.

This Project is within the jurisdiction of the State Water Board, DDW’s Stockton District.

DDW Stockton District issues domestic water supply permit amendments to public water systems pursuant to Waterworks Standards (Title 22 California Code of Regulations [Cal Code Regs.] chapter 16 et. seq.). A public water system requires a water supply permit amendment when changes are made to a domestic water supply source, storage, or treatment and for the operation of new water system componentsas specified in the Cal. Code Regs. § 64556.

The State Water Board, DDW, as a responsible agency under the California Environmental Quality Act (CEQA), has the following comments on the City’s EIR:
· The City will need to apply for a water supply permit amendment for approval of a new source (well) and operation of a new storage reservoir (PDF page 57). In the EIR, under subsection 1.3 EIR Requirements and Intended Uses, on PDF page 14, when identifying other potential responsible agencies, please include “the State Water Resources Control Board, Division of Drinking Water, Stockton District.” In Table 3-3 Required Permits and Approvals, Copper Trails Specific Plan (PDF pages 60 and 61), please include under “Agency”- “State Water Resources Control Board, Division of Drinking Water, Stockton District” and under “Permit/Approval”- “Approve water supply permit amendment.” · The EIR states that Cere’s groundwater supplies are treated at wellheads (PDF page 283). Possible contaminants in the Turlock Subbasin include: arsenic, uranium, manganese, sulfur, total dissolved solids, nitrates, salinity, 1,2,3- trichloropropane, tetrachlorethylene, and dibromochloropropane (PDF page 2A
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EXHIBIT A ITEM 13
COMMENT NO. 2
STATE WATER RESOURCES CONTROL BOARD
Lea Simvoulakis - 2 - December 19, 2024
182). Please discuss the anticipated water quality of the new well at the proposed well site. If treatment may be needed, please discuss the possible types of treatment infrastructure that may be needed and the possible disposal of treatment waste, if applicable.
· The Project is proposing 2,392 new single and multi-residential units and the City currently has 11,881 connections, meeting the “project” and “public water system” thresholds under the Water Code, section 10912. The California Department of Water Resources Guidebook for Implementation of Senate Bill (SB) 610, identifies the SB 610 Water Supply Assessment (WSA) as occurring at a specific plan project level (https://cawaterlibrary.net/wpcontent/uploads/2017/06/guidebook.pdf, PDF page 15). Please provide the required WSA and summarize the information in the EIR. Otherwise, please further explain why a WSA does not apply.

When the CEQA review process is completed, please forward the following items with the permit application to the State Water Board, DDW Stockton District Office at [email protected]:
· Copy of the EIR and Mitigation Monitoring and Reporting Plan (MMRP); · Copy of all comment letters received and the lead agency responses as appropriate;
· Copy of the Resolution or Board Minutes certifying the EIR and adopting the MMRP; and
· Copy of the date stamped Notice of Determination filed at the Stanislaus County Clerk’s Office and the Governor’s Office of Land Use and Climate Innovation, State Clearinghouse.

Please contact Lori Schmitz of the State Water Board at (916) 449-5285 or [email protected], for questions regarding this comment letter.

Sincerely,
Lori Schmitz
Environmental Scientist
Division of Financial Assistance
Special Project Review Unit
1001 I Street, 16th floor
Sacramento, CA 95814
Cc:

Office of Planning and Research, State Clearinghouse
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EXHIBIT A ITEM 13
COMMENT NO. 2
STATE WATER RESOURCES CONTROL BOARD
Lea Simvoulakis - 3 - December 19, 2024
Bhupinder Sahota
District Engineer
Stockton District
Robert Lapp
Water Resources Control Engineer
Stockton District
EXHIBIT A ITEM 13
COMMENT NO. 3
CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE
State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director Central Region 1234 East Shaw Avenue
Fresno, CA 93710
www.wildlife.ca.gov
December 26, 2024
Lea Simvoulakis, Community Development Director
City of Ceres
2220 Magnolia Street
Ceres, California 95307
(209) 538-5778
[email protected]
Subject: Copper Trails Specific Plan & Annexation Project (Project) Draft Environmental Impact Report (DEIR)
SCH: 2023090637
Dear Lea Simvoulakis:

The California Department of Fish and Wildlife (CDFW) received a DEIR from the City of Ceres for the Project pursuant to the California Environmental Quality Act (CEQA) and CEQA Guidelines.1
Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project that may affect California fish and wildlife.

Likewise, CDFW appreciates the opportunity to provide comments regarding those aspects of the Project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.

CDFW ROLE
CDFW is California’s Trustee Agency for fish and wildlife resources and holds those resources in trust by statute for all the people of the State. (Fish & G. Code, §§ 711.7, subd. (a) & 1802; Pub. Resources Code, § 21070; CEQA Guidelines § 15386, subd. (a)). CDFW, in its trustee capacity, has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species. (Id., § 1802). Similarly for purposes of CEQA, CDFW is charged by law to provide, as available, biological expertise during public

1 CEQA is codified in the California Public Resources Code in section 21000 et seq. The “CEQA Guidelines” are found in Title 14 of the California Code of Regulations, commencing with section 15000. 














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EXHIBIT A ITEM 13
COMMENT NO. 3
CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE
Lea Simvoulakis
Community Development Director
December 26, 2024

agency environmental review efforts, focusing specifically on projects and related activities that have the potential to adversely affect fish and wildlife resources.

CDFW is also submitting comments as a Responsible Agency under CEQA. (Pub.

Resources Code, § 21069; CEQA Guidelines, § 15381). CDFW expects that it may need to exercise regulatory authority as provided by the Fish and Game Code. As proposed, for example, the Project may be subject to CDFW’s lake and streambed alteration regulatory authority. (Fish & G. Code, § 1600 et seq.) Likewise, to the extent implementation of the Project as proposed may result in “take” as defined by State law of any species protected under the California Endangered Species Act (CESA) (Fish & G. Code, § 2050 et seq.), the Project proponent may seek related take authorization as provided by the Fish and Game Code.

Unlisted Species: Species of plants and animals need not be officially listed as Endangered, Rare, or Threatened (E, R, or T) on any State or Federal list to be considered E, R, or T under CEQA. If a species can be shown to meet the criteria for E, R, or T, as specified in the CEQA Guidelines section 15380, CDFW recommends it be fully considered in the environmental analysis for the Project.

Nesting Birds: CDFW has jurisdiction over actions with potential to result in the disturbance or destruction of active nest sites or the unauthorized take of birds. Fish and Game Code sections that protect birds, their eggs and nests include sections 3503 (regarding unlawful take, possession, or needless destruction of the nest or eggs of any bird), 3503.5 (regarding the take, possession, or destruction of any birds-of-prey or their nests or eggs), and 3513 (regarding unlawful take of any migratory nongame bird).

PROJECT DESCRIPTION SUMMARY
Proponent: City of Ceres
Objective: The Project establishes the plan for annexation, and eventual development of approximately 260.3 acres of low, medium, medium high, and high-density residential units within the Project site. The total dwelling units that would be potentially developed is 2,392. Approximately 107.4 acres is proposed for Regional Commercial development, which is estimated at 1,169,586 square feet of floor area. The Project also proposes approximately 42.3 acres of parks and open space, including street landscapes, and 3.4 acres for new public uses that would be in addition to the 74.1 acres already occupied by the Central Valley High School and Hidahl Elementary School, both operated by the Ceres Unified School District. The Project would utilize and improve existing roads, add new roads and streets, and provide for development of new bicycle and pedestrian trails and open space linkages to provide access to and between the residential neighborhoods, commercial areas, schools, and parks of the developed Project site. 














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EXHIBIT A ITEM 13
COMMENT NO. 3
CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE
Lea Simvoulakis
Community Development Director
December 26, 2024

Location: The Project is located in unincorporated Stanislaus County south of and adjacent to the City of Ceres.

COMMENTS AND RECOMMENDATIONS
CDFW offers the comments and recommendations below to assist the City of Ceres in adequately identifying and/or mitigating the Project’s significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources.

Editorial comments or other suggestions may also be included to improve the DEIR prepared for the Project.

CDFW submitted a Notice of Preparation (NOP) comment letter to the City of Ceres for the Project on October 30, 2023, with recommended mitigation measures for specialstatus species that could potentially be impacted by the Project. Currently, the DEIR acknowledges that the Project site is within the geographic range of special-status species and proposes specific mitigation measures to reduce impacts to less than significant. CDFW has concerns about the ability of some the proposed mitigation measures to reduce impacts to less than significant and avoid unauthorized take for the State threatened Swainson’s hawk (Buteo swainsoni); the State and federally threatened California tiger salamander Central California Distinct Population Segment (DPS) (Ambystoma californiense pop. 1); the State candidate western burrowing owl (Athene cunicularia hypugaea) and Crotch’s bumble bee (Bombus crotchii); and the State species of special concern western spadefoot (Spea hammondii).

Swainson’s Hawk
The DEIR notes that the Project could potentially impact (Impact BIO-1) Swainson’s hawk (SWHA) and mitigation measure (MM) BIO-1 is provided to mitigate for potential impacts. MM BIO-1 provides for a pre-construction survey and if nests are detected during breeding season, a ½-mile buffer shall be established around active nests until the breeding season has ended or a qualified biologist has determined the birds have fledged the nest. CDFW concurs with this measure and recommends that in the event an active SWHA nest is detected, and a ½-mile no-disturbance buffer is not feasible, consultation with CDFW is warranted to discuss how to implement the Project and avoid take. If take cannot be avoided, authorization through the acquisition of an Incidental Take Permit (ITP), pursuant to Fish and Game Code section 2081 subdivision (b) is necessary to comply with CESA.

California Tiger Salamander
The Project site is within the range of California tiger salamander (CTS) and based on aerial imagery and the information provided in DEIR, suitable habitat appears present within certain portions of the Project site such as near Central Avenue and East 














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EXHIBIT A ITEM 13
COMMENT NO. 3
CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE
Lea Simvoulakis
Community Development Director
December 26, 2024

Redwood Road. It does not appear that the DEIR evaluated CTS, and no mitigation measures were proposed to mitigate for potential Project-related impacts to the species.

As such, CDFW recommends the following:

Recommended Mitigation Measure 1: Focused CTS Protocol-level Surveys CDFW recommends that a qualified biologist conduct protocol-level surveys in accordance with the USFWS “Interim Guidance on Site Assessment and Field Surveys for Determining Presence or a Negative Finding of the California Tiger Salamander” (USFWS 2003) at the appropriate time of year to determine the existence and extent of CTS breeding and refugia habitat within the Project site.

The protocol-level surveys for CTS require more than one survey season and are dependent upon sufficient rainfall to complete. As a result, consultation with CDFW and the USFWS is recommended well in advance of beginning the surveys and prior to any planned vegetation- or ground-disturbing activities.

CDFW advises that the protocol-level survey also include a 100-foot buffer around the Project site in all areas that could support CTS. Please be advised that protocol-level survey results are viable for two years after the results are reviewed by CDFW.

Recommended Mitigation Measure 2: CTS Avoidance Buffer
If CTS protocol-level surveys as described in Recommended Mitigation Measure 1 are not conducted, CDFW advises that a minimum 50-foot no-disturbance buffer be delineated around all small mammal burrows in suitable upland refugia habitat within 1.3 miles of potential CTS breeding pools. Further, CDFW recommends potential or known breeding habitat within and/or adjacent to the Project site be delineated with a minimum 250-foot no-disturbance buffer. Both upland burrow and wetland breeding no-disturbance buffers are intended to minimize impacts to CTS habitat and avoid take of CTS individuals.

Recommended Mitigation Measure 3: CTS Take Authorization If through surveys it is determined that CTS are occupying or have the potential to occupy the Project site, consultation with CDFW is warranted to determine if the Project can avoid take. If take cannot be avoided, take authorization through the acquisition of an ITP, pursuant to Fish and Game Code section 2081 subdivision (b) is necessary to comply with CESA. As stated above, in the absence of protocol surveys, the applicant can assume presence of CTS within the Project site and obtain an ITP from CDFW.

Western Burrowing Owl
The Project site is within the known geographic range of western burrowing owl (BUOW), and the DEIR notes that the species is unlikely to occur, although it does not appear that focused BUOW surveys were conducted. CDFW does not concur that 














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EXHIBIT A ITEM 13
COMMENT NO. 3
CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE
Lea Simvoulakis
Community Development Director
December 26, 2024

BUOW are unlikely to occur within the agricultural and grassland habitats found throughout the Project site, particularly within or adjacent to the agricultural canals located throughout the area. CDFW would like to note that the California Fish and Game Commission (FGC) approved BUOW as a candidate for potential listing as a protected species under CESA on October 10, 2024, and published these findings in the California Regulatory Notice Register (Notice Register) on October 25, 2024. As such, BUOW is now considered a candidate under CESA and receives the same legal protection afforded to an endangered or threatened species (Fish & G. Code, §§ 2074.2 & 2085).

As BUOW have the potential to be present within the Project site or Project vicinity, it does not appear that focused BUOW surveys were conducted, and no mitigation measures were proposed to mitigate for potential Project-related impacts to the species, CDFW recommends the following:

Recommended Mitigation Measure 4: BUOW Preconstruction Surveys CDFW recommends that surveys, following CDFW’s “Staff Report on Burrowing Owl Mitigation” (CDFG 2012) be conducted within areas of suitable habitat the survey season immediately prior to construction.

Recommended Mitigation Measure 5: BUOW Avoidance Buffer Should a BUOW or known BUOW den (active or inactive) be detected, either during preconstruction surveys or construction activities, CDFW recommends that no-disturbance buffers, as outlined in the 2012 Staff Report on Burrowing Owl Mitigation (CDFG 2012), be implemented prior to and during any grounddisturbing activities. CDFW also recommends that these buffers be implemented for both wintering and breeding BUOW.

Recommended Mitigation Measure 6: BUOW Take Authorization If a BUOW or known BUOW den (active or inactive) is detected, and the nodisturbance buffers outlined in the 2012 Staff Report on Burrowing Mitigation are not feasible, consultation with CDFW is warranted to discuss how to implement the Project and avoid take. If take cannot be avoided, take authorization through the acquisition of an ITP, pursuant to Fish and Game Code section 2081 subdivision (b) is necessary to comply with CESA.

Crotch’s Bumble bee
The Project site is within the range of Crotch’s bumblebee (CBB) and the DEIR notes that the species is unlikely to occur, although it does not appear that focused CBB surveys were conducted. CDFW does not concur that CBB are unlikely to occur within certain portions of the Project site. CBB are known to inhabit areas of grasslands and scrub that contain requisite habitat elements for nesting, such as small mammal 














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EXHIBIT A ITEM 13
COMMENT NO. 3
CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE
Lea Simvoulakis
Community Development Director
December 26, 2024

burrows and bunch/thatched grasses, and these habitat elements may be present within portions of the Project site, such as along Central Avenue.

As CBB have the potential to be present within the Project site or Project vicinity, it does not appear that focused CBB surveys were conducted, and no mitigation measures were proposed to mitigate for potential Project-related impacts to the species, CDFW recommends the following:

Recommended Mitigation Measure 7: CBB Habitat Assessment CDFW recommends a qualified biologist conduct a habitat assessment to determine if the Project area and the immediate surrounding vicinity contain habitat suitable to support CBB. Potential nesting sites, which include all small mammal burrows, perennial bunch grasses, thatched annual grasses, brush piles, old bird nests, dead trees, and hollow logs would need to be documented as part of the assessment.

Recommended Mitigation Measure 8: CBB Surveys
If potentially suitable habitat is identified, CDFW recommends that a qualified biologist conduct focused surveys for CBB, and their requisite habitat features following the methodology outlined in the Survey Considerations for California Endangered Species Act Candidate Bumble Bee Species (CDFW 2023).

Recommended Mitigation Measure 9: CBB Avoidance
If CBB is detected, then CDFW recommends that all small mammal burrows and thatched/bunch grasses be avoided by a minimum of 50 feet to avoid take and potentially significant impacts. If ground-disturbing activities will occur during the overwintering period (October through February), consultation with CDFW is warranted to discuss how to implement Project activities and avoid take. Any detection of CBB prior to or during Project implementation warrants consultation with CDFW to discuss how to avoid take.

Recommended Mitigation Measure 10: CBB Take Authorization If take cannot be avoided, take authorization through the acquisition of an ITP, pursuant to Fish and Game Code section 2081 subdivision (b) is necessary to comply with CESA.

Western Spadefoot
The Project site is within the known geographic range of western spadefoot (WESP) and based on aerial imagery and the information provided in DEIR, suitable habitat may be present within certain portions of the Project area such as near Central Avenue and East Redwood Road. It does not appear that the DEIR evaluated WESP, and no 














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EXHIBIT A ITEM 13
COMMENT NO. 3
CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE
Lea Simvoulakis
Community Development Director
December 26, 2024

mitigation measures were proposed to mitigate for potential Project-related impacts to the species. As such, CDFW recommends the following:

Recommended Mitigation Measure 11: WESP Habitat Assessment.

CDFW recommends that a qualified biologist conduct a habitat assessment to determine if the Project site and the immediate surrounding vicinity contain habitat suitable to support WESP.

Recommended Mitigation Measure 12: WESP Surveys
If suitable habitat is identified, CDFW recommends a qualified biologist conduct focused surveys for western spadefoot and their requisite habitat features immediately prior to construction.

Recommended Mitigation Measure 13: WESP Avoidance
If burrows, cracks, loose soil areas or other refugia are found to be used by WESP during focused surveys, avoidance whenever possible is encouraged via delineation and observance of a 50-foot no-disturbance buffer around these resources. If WESP are observed on the Project site, Project activities in their immediate vicinity cease, allowing individuals to leave the Project site on their own accord. Alternately, a qualified biologist with appropriate authorization can relocate them to a more suitable location out of harm’s way.

Editorial comments and/or suggestions
Nesting Birds: CDFW encourages that Project ground-disturbing activities occur during the bird non-nesting season; however, if ground-disturbing or vegetation-disturbing activities must occur during the nesting season (February 1st through September 15th), the Project applicant is responsible for ensuring that implementation of the Project does not result in violation of the Migratory Bird Treaty Act or relevant Fish and Game Code sections as referenced above.

CDFW further recommends that a qualified biologist conduct a pre-construction survey for active nests no more than 10 days prior to the start of ground or vegetation disturbance to maximize the probability that nests that could potentially be impacted are detected. CDFW also recommends that surveys cover a sufficient area around the Project site to identify nests and determine their status. A sufficient area means any area potentially affected, either directly or indirectly, by the Project. In addition to direct impacts (i.e., nest destruction), noise, vibration, and movement of workers or equipment could also affect nests. CDFW recommends that a qualified biologist establish a behavioral baseline of all identified nests. Once Project activities begin, CDFW recommends having a qualified biologist continuously monitor nests to detect behavioral changes resulting from the Project. If behavioral changes occur, CDFW recommends 














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EXHIBIT A ITEM 13
COMMENT NO. 3
CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE
Lea Simvoulakis
Community Development Director
December 26, 2024

halting the work causing that change and consulting with CDFW for additional avoidance and minimization measures.

If continuous monitoring of identified nests by a qualified biologist is not feasible, CDFW recommends a minimum no-disturbance buffer of 250 feet around active nests of nonlisted bird species and a 500-foot no-disturbance buffer around active nests of nonlisted raptors. These buffers are advised to remain in place until the breeding season has ended or until a qualified biologist has determined the birds have fledged and are no longer reliant upon the nest or on-site parental care for survival. Variance from these no-disturbance buffers is possible when there is a compelling biological or ecological reason to do so, such as when the Project site would be concealed from a nest site by topography. CDFW recommends that a qualified biologist advise and support any variance from these buffers and notify CDFW in advance of implementing a variance.

Lake and Stream Alteration: CDFW’s October 30, 2023, NOP comment letter noted that potential streams such as Turlock Irrigation District’s (TID) Lateral and other waterbodies located within the Project site may be subject to notification under Fish and Game Code Section 1602. The DEIR states, “The TID canals are potential jurisdictional Waters of the U.S., as they convey water from a reservoir that would be considered a jurisdictional water (Turlock Lake), and water from the canals is eventually discharged into another jurisdictional water (San Joaquin River).” It follows by stating, “It is expected that future development would not directly affect the TID canals.” CDFW would like to note that storm drainage infrastructure installation was identified as a component of the Project serving future development in the Project area. As such, CDFW would like to reiterate that implementation of Project activities that substantially change the bed, bank, and channel of any river, stream, or lake are subject to CDFW’s regulatory authority pursuant Fish and Game Code section 1600 et seq. Fish and Game Code section 1602 requires an entity to notify CDFW prior to commencing any activity that may (a) substantially divert or obstruct the natural flow of any river, stream, or lake; (b) substantially change or use any material from the bed, bank, or channel of any river, stream, or lake (including the removal of riparian vegetation): (c) deposit debris, waste or other materials that could pass into any river, stream, or lake. “Any river, stream, or lake” includes those that are ephemeral or intermittent as well as those that are perennial and may include those that are highly modified such as canals and retention basins.

CDFW is required to comply with CEQA in the issuance of a Lake or Streambed Alteration Agreement (LSAA); therefore, if the CEQA document approved for the Project does not adequately describe the Project and its impacts to lakes or streams, a subsequent CEQA analysis may be necessary for LSAA issuance. For information on notification requirements, please refer to CDFW’s website (https://wildlife.ca.gov/Conservation/LSA) or contact CDFW staff in the Central Region Lake and Streambed Alteration Program at (559) 243-4593. 














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EXHIBIT A ITEM 13
COMMENT NO. 3
CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE
Lea Simvoulakis
Community Development Director
December 26, 2024

Cumulative Impacts: CDFW’s October 30, 2023, NOP letter recommended a cumulative analysis be conducted for all biological resources that will either be significantly or potentially significantly impacted by implementation of the Project. The DEIR has a very limited analysis for cumulative impacts for biological resources in Section 18.3.4 and states, “However, with applicable policies in place as described in the direct impact analysis in the GPEIR, the General Plan’s contribution to this potentially significant cumulative impact is less than cumulatively considerable.” CDFW would like to note this DEIR serves primarily as a planning level document and should consider the cumulative impacts of reasonably foreseeable projects. As such, CDFW recommends that a more focused cumulative impact analysis be conducted for all biological resources that will either be significantly or potentially significantly impacted by implementation of the Project, and potentially impacted by future tiered projects, even if those impacts are relatively small (i.e. less than significant). CDFW recommends cumulative impacts be analyzed using an acceptable methodology to evaluate the impacts of past, present, and reasonably foreseeable future projects on resources and be focused specifically on the resource, not the individual project. An appropriate resource study area identified and utilized for this analysis is advised. CDFW staff are available for consultation in support of cumulative impacts analyses as a trustee and responsible agency under CEQA.

California Natural Diversity Database: Please note that the California Natural Diversity Database (CNDDB) is populated by voluntary submissions of species detections. As a result, species may be present in locations not depicted in the CNDDB but where there is suitable habitat and features capable of supporting species. A lack of an occurrence record, or lack of recent occurrence records, in the CNDDB does not mean that a species is not present. In order to adequately assess any potential Projectrelated impacts to biological resources, surveys conducted by a qualified biologist during the appropriate survey period(s) and using the appropriate protocol survey methodology are warranted in order to determine whether or not any special-status species are present.

ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database which may be used to make subsequent or supplemental environmental determinations. (Pub. Resources Code, § 21003, subd. (e).) Accordingly, please report any special-status species and natural communities detected during Project surveys to the CNDDB. The CNDDB field survey form can be filled out and submitted online at the following link:
https://wildlife.ca.gov/Data/CNDDB/Submitting-Data. The types of information reported to CNDDB can be found at the following link:
https://www.wildlife.ca.gov/Data/CNDDB/Plants-and-Animals. 














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EXHIBIT A ITEM 13
COMMENT NO. 3
CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE
Lea Simvoulakis
Community Development Director
December 26, 2024

FILING FEES
The Project, as proposed, would have an impact on fish and/or wildlife, and assessment of environmental document filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the environmental document filing fee is required in order for the underlying project approval to be operative, vested, and final. (Cal. Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711.4; Pub. Resources Code, § 21089).

CONCLUSION
CDFW appreciates the opportunity to comment on the DEIR to assist the City of Ceres in identifying and mitigating Project impacts on biological resources. More information on survey and monitoring protocols for sensitive species can be found at CDFW’s website (https://www.wildlife.ca.gov/Conservation/Survey-Protocols). Questions regarding this letter or further coordination should be directed to John Riedel, Environmental Scientist, at (559) 807-1453, or [email protected].

Sincerely,
Julie A. Vance
Regional Manager
ec: State Clearinghouse
Governor’s Office of Planning and Research
[email protected]















3O
EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-25 March 2026 Responses to California Department of Fish and Wildlife, Letter of December 26, 2024
Response 3A: This paragraph does not comment on either the EIR content or its processing but rather identifies the CDFW’s statutory identity as a Trustee Agency for the fish and wildlife resources of the State. This comment provides authority for later comment by the CDFW with respect to certain fish and wildlife species of concern, including species not specifically listed as endangered, rare or threatened; these species are addressed below in Responses 3E through 3K No response to this comment is required.

Response 3B: Similar to Comment #3A, this paragraph does not make any specific comment on either the EIR content or its processing but rather identifies the CDFW’s role as a Responsible Agency with responsibility for regulation of potential lake and streambed impacts under Section 1600 of the Fish and Game Code, permit authority over “take” of protected species under Section 2050 et. seq. of the Fish and Game Code and disturbance or “take” of migratory birds. Like Comment 3A, CDFW’s authority is pertinent to certain protected species and migratory birds as addressed in species-specific responses below.

Response 3C: This paragraph does not comment on the EIR content or its processing but rather summarizes the proposed project as described in Chapter 3.0 Project Description of the Draft EIR. The comment does not distinguish between the proposed specific plan and later projectspecific development that would occur pursuant to the adoption of the CTSP and annexation of the CTSP and Pocket Area to the City of Ceres. No response is required.

Response 3D: These two paragraphs summarize the CDFW’s comments and recommendations with respect to the agency’s species-specific concerns related to the impacts of the project and mitigation measures needed to address those impacts. The species of concern, including Swainson’s hawk, burrowing owl, California tiger salamander, Crotch’s bumblebee and western spadefoot, are addressed specifically in individual responses below.

Response 3E: Swainson’s hawk. In this comment CDFW concurs with the Draft EIR’s analysis of potential impacts to and recommended mitigation measures for protection of Swainson’s hawk. CDFW provides additional recommendations for reduction of impact on Swainson’s hawk found nesting in the vicinity of a development project, including coordination with CDFW. The City will consider these
recommendations in the event that pre-construction surveys for future EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-26 March 2026 development projects encounter Swainson’s hawk nesting within the recommended search radius.

Response 3F: California tiger salamander (CTS). CDFW comments that, based on aerial imagery and information from the Draft EIR, suitable CTS habitat appears to be present in the project area. The Draft EIR, however, did not identify CTS as a potentially occurring species in the project area.

Further investigation during preparation of the Final EIR confirms that the project area is not in a known CTS occurrence area or, especially, critical habitat for the CTS. CTS habitat and occurrences are located, together with Critical Habitat for the species, in the low Sierra foothills and coastal foothills along the east and west edges of the Valley floor, respectively. The California Natural Diversity Data Base (CNDDB) does not include any CTS records in the vicinity of the project; the nearest records are approximately 11 miles west and 15 miles east of the project site.

Moore Biological Consultants conducted a reconnaissance level field survey of the project area on January 7, 2025. The field survey assessed a low area just northeast of the intersection of Central Avenue and East Redwood Road that appears wet in some historical aerial photographs. Moore Biological found that the low area to be part of a field being grazed by goats and was dry at the time of the winter survey. A culvert under East Redwood Road could convey water, presumably from the nearby irrigation lateral to the low area. Review of aerial photographs confirm this periodically flooded area does not, however, have a suitable hydrologic regime to support CTS breeding.

No potentially suitable breeding habitat for CTS was observed elsewhere in the project area.

Consequently, the City disagrees that the project has the potential to result in significant, or any, adverse effect on the CTS. As the project does not involve potential for CTS impacts, the City will not incorporate CDFW’s recommended mitigation measures into the Final EIR. In the event that CTS occurrence is later considered a substantial potential in the CTSP or other project areas, based on substantial evidence, the City will then consider CDFW’s recommendations in more detail.

Response 3G: Western Burrowing Owl. CDFW comments that suitable burrowing owl habitat may be present in the project area contrary to the EIR’s conclusion of Table 7-1 that no burrowing owl habitat occurs in the area and that the owl is unlikely to occur. Further investigation during preparation of the Final EIR confirmed that the project area is not EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-27 March 2026 within a known occurrence area; the only burrowing owl record in the CNDDB within 10 miles of the project site is a 1994 record over nine miles away in a part of Riverbank that is now a residential subdivision.

During its January 2025 survey, Moore Biological Consultants noted poor quality habitat for burrowing owl throughout most of project site.

Orchards, vineyards, irrigated cropland, and developed areas do not provide suitable habitat for burrowing owl. Moore also noted very few ground squirrels or their burrows occurring within the project area.

Burrowing owls are unlikely to occur in the site as they have become very limited in distribution over the past several years. Despite a very low potential to occur, but considering their listing status, the City concurs pre-construction surveys for burrowing owl are appropriate.

The CDFW recommended mitigation measures have been added to the EIR via Final EIR Chapter 4.0 Errata and are shown in the MMRP for the project.

Response 3H: Crotch’s Bumble Bee. In this comment CDFW notes the project site is within the range of Crotch’s bumble bee (CBB), that CBB has potential to occur in the project area and recommends a habitat assessment, followed by focused surveys for CBB if habitat is present.

If CBB is detected during surveys, CDFW provides recommendations for avoidance and identifies the need for an Incidental Take Permit if avoidance is infeasible.

During its January 2025 survey, Moore Biological found only poor quality habitat for CBB in the project area and concluded that the potential to occur is very low, both due to location of the site and lack of high-quality habitat. However, as CBB is a Candidate species for listing, the City will incorporate CDFW’s recommended CBB mitigation measures. The mitigation measures are added to the EIR via Final EIR Chapter 4.0 Errata and shown in the MMRP for the project.

Response 3I: Western Spadefoot. CDFW comments that based on aerial imagery and information from the Draft EIR, suitable habitat for western spadefoot appears to be present in the project area. Further investigation during preparation of the Final EIR confirms that the project area is not in a known occurrence area for the species. Similar to CTS, western spadefoot habitat and occurrences are located in the low Sierra foothills and coastal foothills along the east and west edges of the Valley floor, respectively. The CNDDB does not include any western spadefoot records in the vicinity of the project; the nearest records are approximately 12 miles west and 16 miles east of the project site.

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-28 March 2026 Similar to CTS, Moore Biological Consultants concluded the periodically flooded low area northeast of the intersection of Central Avenue and East Redwood Road does not have a suitable hydrologic regime to support western spadefoot. Additionally, Moore Biological Consultants did not observe potentially suitable breeding habitat for western spadefoot in the project area during the January 2025 survey.

Consequently, the City disagrees that the project has the potential to result in significant, or any, adverse effect on the western spadefoot.

As the project does not involve potential for western spadefoot impacts, the City will not incorporate the CDFW recommendations into the Final EIR. In the event that western spadefoot occurrence is later considered a substantial potential in the CTSP or other project areas, based on substantial evidence, the City will then consider CDFW’s recommendations in more detail.

Response 3J: Migratory Birds. In this comment CDFW suggests that grounddisturbing activities occur outside the avian nesting season, which CDFW describes as February 1 to September 15, and that project applicants are responsible for ensuring compliance with the Migratory Bird Treaty Act (MBTA) and the sections of Fish and Game Code of California FGCC) that protect nesting birds. CDFW provides recommendations on survey methodologies and buffers from active nests and recommends notifying CDFW in advance of implementing a variance to the recommended buffers.

The City understands trees, shrubs and grasslands in and near the project site may provide suitable nesting habitat for a variety of birds, and its obligation to comply with MBTA and FGCC. The City appreciates the CDFW’s recommendations on survey methodologies and buffers but will not incorporate these recommendations into the Final EIR verbatim. A migratory bird pre-construction survey measure is already included in the DEIR, and this measure will be revised to encompass ground-disturbing activities between February 1 and September 15, the broader nesting season recognized by CDFW.

Response 3K: Lake and Streambed Alteration. CDFW comments that Turlock Irrigation District’s Lateral and other waterbodies located in the project area may be subject to notification pursuant to FGCC Section 1602. CDFW acknowledges the DEIR states that the project will not directly affect TID canals but notes storm drain infrastructure as part of the project may affect these waterways. CDFW then reiterates that notification to CDFW would be warranted if project activities do substantially change the bed, bank, and channel of any river, lake, or stream.

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-29 March 2026 Moore Biological did not observe any streams or lakes in the project area that would be subject to CDFW jurisdiction under FGCC Section 1600 to 1616 during the January 7, 2025 survey.

The City understands its responsibility to comply with FGCC if water resources subject to Section 1600 requirements are subject to potential disturbance, but this determination will need to occur on a project-byproject basis. In the event that development project activities, including potential work in TID laterals, rise to the threshold of notification pursuant to FGCC Section 1602, the City will consider CDFW’s recommendations.

EXHIBIT A ITEM 13
COMMENT NO. 4
STANISLAUS LAFCO
4A
4C
4D
4B
EXHIBIT A ITEM 13
COMMENT NO. 4
STANISLAUS LAFCO
4E
4G
4H
4F
4I
EXHIBIT A ITEM 13
COMMENT NO. 4
STANISLAUS LAFCO
4I
4K
4M
4J
4L
EXHIBIT A ITEM 13
COMMENT NO. 4
STANISLAUS LAFCO
4M
4P
4M
4N
4L
4O
EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-34 March 2026 Responses to Stanislaus LAFCo comment letter of January 27, 2025 Response 4A: The Stanislaus LAFCo correctly identifies itself as a CEQA Responsible Agency, which will be obligated to utilize the City’s CEQA EIR when considering the proposed annexation. No further response is necessary.

Response 4B: The Stanislaus LAFCo’s comments on the City’s NOP were received, considered during the preparation and included in Draft EIR Appendix A. A summary of these comments was provided in Chapter 1.0 of the Draft EIR. The commenter’s more specific environmental concerns are addressed in following portions of the comment letter and in the following responses.

Response 4C: LAFCo concerns related to agriculture and agricultural preservation, including the requirement for preparation of a Plan For Agricultural Preservation, were discussed in detail in Chapter 5.0 of the Draft EIR.

The city is aware of the need to submit a standalone plan for agricultural preservation to LAFCo with its application to annex the CTSP area and the Pocket Area. This submittal will occur following the City’s certification of the EIR, decision to approve the specific plan and initiate the annexation process.

Response 4D: The draft EIR makes no distinction between the State Department of Conservation and the LAFCo definition of important farmland; the EIR reports that the project would result in the conversion of 319.5 acres of both Prime Agricultural Land and Farmland of Statewide Importance. This encompasses all of the lands within the CTSP area that are defined under LAFCo policy as needing preservation.

Mitigation Measure AG-1, which is worded ambiguously, applies to “Prime Farmland.” Chapter 4.0 Errata of this Final EIR modifies the language of the mitigation to apply to the more inclusive term “Farmland” as used in CEQA.

Response 4E: As noted in response for D, mitigation measure AG-1 has been modified to apply to the more inclusive term “Farmland,” which includes both Prime Farmland and Farmland of Statewide Importance.

Response 4F: See previous Responses 4D and 4E.

Response 4G: The City understands that the Plan for Agricultural Preservation would be adopted by the City and submitted to LAFCo. The modified mitigation measure AG-1 has been modified to delete the reference to LAFCo approval.

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-35 March 2026 Response 4H: The City appreciates LAFCo clarifying the process for cancellation of Williamson Act contracts. The referenced Draft EIR discussion has been modified to reference the processing requirements of the Government Code.

Response 4I: This comment makes note of an EIR statement regarding vacant lands in the City. The West Landing Specific Plan does contain substantial vacant land, but these lands are oriented to new housing development.

The Copper Trails project is oriented rather to economic and job development and supportive expansion of population and housing. The City understands the referenced LAFCo policies and will submit supplemental information on land use, vacancy, pressure for development within the CTSP area and information related to agricultural use. Prior to consideration of the project, an economic and fiscal impact study for the project will be submitted and reviewed.

Response 4J: Following certification and approval of the Specific Plan, the City will prepare and submit to LAFCo an application for annexation of the project area. The referenced concern will be addressed by the proposed annexation map. Whether or not the project would provide a consistent jurisdictional boundary considered by LAFCo to be adequate or of administrative benefit is not a matter of environmental concern that needs to be addressed in the EIR. No further response is needed Response 4K: There is no known recent source of mapping or designation of existing DUCs other than the cited reference, which has been corrected in the Final EIR. There is no known purpose for identifying potential DUCs as they are not subject to special protections or requirements, particularly as it concerns potential for identifying significant environmental effects under CEQA.

The proposed annexation as well as most of the City of Ceres and western Stanislaus County is located within a Disadvantaged Community for the purposes of SB 535, which is a mechanism for directing investment of proceeds from the state’s Cap-and-Trade Program, which are aimed at improving public health, quality of life and economic opportunity in California’s most burdened communities, and at the same time, reducing pollution that causes climate change.

The current CalEnviroScreen (4.0) map shows the Pocket Area as it is mapped as being within the 80% - 90% range, while the entirety of the CTSP area and surroundings to the south (Census Tract: 6099003002) is mapped as being within the 70% - 80% range. While the CalEnviroScreen mapping may indicate that the two areas are disproportionately burdened by multiple sources of pollution with EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-36 March 2026 respect to other census tracts in California and therefore “disadvantaged.” This is not the same as being a DUC.

The DUC is of no importance with respect to environmental impact analysis under CEQA. As discussed in the EIR’s air quality, the project would not include any major sources of new pollution that could impact either the CTSP or the Pocket Area or otherwise make worse any of the socio-economic factors that indicate that the areas are disadvantaged.

Response 4L: The City is aware of and will be required to comply with the Plan for Services requirement of GC 56653. This is a routine annexation requirement, and a Plan for Services will be submitted to LAFCo when the City submits its annexation application. Most of the information that is needed in the Plan for Services is already provided in the EIR.

Please refer to Chapters 15.0 Public Services and 17.0 Utilities of the Draft EIR; LAFCo makes no comment on the EIR content
information.

Financing mechanisms for expansion of public services to serve the annexation are the subject of detailed research and analysis in the Fiscal Impact Study for the project being prepared by EPA. This information will be incorporated into the City’s annexation application and submitted for LAFCo consideration.

Response 4M: A Utilities Master Plan has been prepared for the proposed Specific Plan and annexation. The Specific Plan’s portion of improvements needed to serve new development is addressed in the 17.0 Utilities chapter of the EIR. A copy of the Specific Plan is available for review on the City’s website. The City and the project applicant reviewed and discussed wastewater treatment capacity that would be available to the project as well as other planned development in the City, and based on this effort, the City believes that adequate capacity is available.

Response 4N: In November 2023, treated surface water was introduced into the Ceres potable water distribution system. This water is obtained from the Tuolumne River, treated at the new Stanislaus Regional Water Agency treatment plant, delivered by pipeline to the City reservoir and then delivered to Ceres customers through the City’s existing water distribution system. Information on the same subject was provided on page 17-1 of Draft EIR.

Response 4O: In the City’s response to the SWRCB on the same subject, it noted that the potential need for an SB 610 Water Supply Assessment (WSA) was specifically considered during the preparation of the Draft EIR, as documented on page 17-6. This analysis concluded that a WSA was EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-37 March 2026 not specifically required for a specific plan project, although SB 610 or SB 221 requirements may apply to subsequent projects. The City’s position on this subject remains the same.

The SWRCB Guidebook identifies the Urban Water Management Plan as a key water supply planning document that can be used by a water supplier to fulfill the specific requirements of the two WSA statutes.

On the same page, the EIR noted that the City had adopted its 2020 UWMP, which describes the City’s water system, water use, water supply sources and the reliability of the City’s water service for normal, dry, and five-year drought conditions for the next 20 years.

The UWMP planning area encompasses the City’s Sphere of Influence, which includes both the CTSP and Pocket Areas.

Response 4P: The City and the parties with responsibilities and interests in fire protection in the Ceres area are in ongoing discussion and negotiations regarding reorganization of fire protection responsibilities in the Ceres area, including the City’s continuing relationship with the City of Modesto for fire protection services beyond the expiration of the existing agreement in 2026. The anticipated changes will include detachment from the Ceres and Keyes Fire Protection districts and operational effects on these entities. These concerns as well as fiscal effects, will be resolved as a part of the larger action before it obtains the required approval of all of the involved entities. This action, including resolution of any fiscal effects between the agencies, will be concluded prior to submittal of the City’s annexation application to LAFCo. At that time, the City will be the sole entity with responsibility for fire protection in the annexation area.

EXHIBIT A ITEM 13
COMMENT NO. 5
JOHN AND PATTI WARRSY
COPPER TRAILS MASTER PLAN E. I. R. COMMENTS
In reviewing this 632-page report I was unable to find out what the total population of the Copper Trails area and the Pocket Area is. How many people live in these areas now. How many more Police OEicers, Fire personnel and public works employees will be needed if this area is annexed into the City of Ceres before building out is completed years from now. How is there wastewater currently disposed of? Are there any existing sewer lines, and do these lines connect to a disposal site? Is the whole area on septic systems or is some of it already connected to the city system? The Pocket Area too.

The report explains the Cities’ current wastewater treatment plant capacities and that wastewater is shipped to Turlock and Modesto. It does not explain that the facility is outdated and needs to be replaced. If wastewater was not shipped to these other cities the facility would not support the residents of Ceres, or this proposed project.

The E I R projects what the proposed project will look like when built out and completed many years down the road but does not explain how the city will be able to aEord to provide all the services required as the project moves along.

Will the taxes from the current properties support the services needed. Police OEicers, Fire Fighters, ambulance services, water, wastewater (the new treatment plant costs) garbage collection, street sweeping and various other services. Some of these utilities’ costs will be passed on to the property owners and are self-supporting but some are not. Will the tax base support all that is needed?
The report comments on additional Police OEicers needed on build out as being “9” with a ratio of 1.3 per 1 thousand residents. I did not find any comments on all the equipment needed by those 9 OEicers, or the costs associated. Again, Will this project area Tax Base with about 9 thousand new residents (½ will be children) support the needed public services.

The report does not indicate if the residents of Copper Trails or the Pocket Area want to be annexed to the city limits and are willing to pay these extra fees and 5C
5B
5A
5D
5E
EXHIBIT A ITEM 13
COMMENT NO. 5
JOHN AND PATTI WARRSY
taxes to support the services needed. Were they contacted in any manner regarding the issue of annexation to the city?
In looking at the Master Plan Map there are roads North and Southbound thru the project but no roads East and Westbound that are completely thru the project. I would suggest Street “B” continue from Central Avenue thru to Blaker Road or Redwood Road continue thru to Blaker Road. Both would be the best for TraEic flow and the response of Emergency Vehicles. Being able to pass through the CT project area without 90degree turns would be preferred.

Controlling the speed of TraEic can be accomplished by traEic calming methods developed by Engineering and Public Works.

What are the conditions of the roads that currently exist within the CT project, and the Pocket Area? What will the cost be to bring them up to present-day standards? The County should do this prior to annexation, or the project proponents should be required to do so. Going forward will be the responsibility of the city. Bringing things up to standard should not be.

Also, are there any City Council District boundary lines that have been drawn up or proposed based on the population (and other considerations) of the CTMP and Pocket Area? When the annexation is approved and is in place all these new city residents will have to be represented by someone on the City Council.

I believe all these questions should be answered and provided to the citizens of Ceres, the residents of the CT area and the Pocket Area before the City adopts the EIR and approves the CTMP.

I am aware that LAFCO must approve the project
5G
5F
5E
5H
5I
EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-40 March 2026 RESPONSES TO JOHN AND PATTY WARREN, UNDATED
Response 5A: This comment poses a number of questions to which answers are provided below.

The current population of the CTSP area and Pocket Area are estimated as follows, based on a count of homes and a fixed per unit population.

CTSP, estimated 70 homes x 3.5 persons/unit
Pocket Area, estimated 235 homes x 3.5 persons/unit
The EIR addresses future needs for police and fire personnel based on planned buildout. A fiscal study of the project is being prepared for consideration in conjunction with the project.

Existing wastewater disposal is to onsite septic tank and leach field systems. These systems will need to be abandoned as wastewater pipelines are extended into new development areas; wastewater will be collected and flow to the City’s existing wastewater treatment and disposal facility. No part of the annexation area is connected to the City system.

Response 5B: The capacity of the City’s wastewater system is based on the existing capacity of City facilities together with the City’s agreements with other wastewater treatment providers and the existing agreements between the cities. The City has determined during the review of the CTSP and annexation project that adequate capacity is or will be available to accept wastewater flows from planned growth.

Response 5C: A detailed analysis of the service obligations and revenue from the project is being prepared in a fiscal study for the project; the fiscal study and will be considered by the Planning Commission and City Council in their discussions of the project.

Response 5D: This information will be provided in the fiscal study referenced in Response 5C.

Response 5E: According to the California Government Code and Stanislaus County LAFCo, residents of the annexation area will be given an opportunity to formally vote on whether the annexation should or should not be approved.

Response 5F: This comment provides the commenter’s opinion as how the proposed circulation plan for the CTSP area could be improved. This comment will be considered by City Public Works and Community
EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-41 March 2026 Development staff as well as by the Planning Commission and City Council.

Response 5G: The condition of existing roads and the costs to provide improvements have been subjected to engineering analysis in materials that are under review by the City. Proposed standards for new or improved roads are shown in the Specific Plan. The road improvement costs vs. revenue generated by the project is being considered in the fiscal analysis discussed in Response 5C.

Response 5H: A plan for redistricting the City will be drawn up and considered by the City Council in conjunction with the annexation process.

Response 5I: The City’s draft responses to these comments as shown above will be made available to commenting agencies and the public prior to public meetings at which the proposed project will be discussed.

EXHIBIT A ITEM 13
COMMENT NO. 6
STANISLAUS COUNTY ERC

STANISLAUS COUNTY

CEQA REFERRAL RESPONSE FORM
TO: Stanislaus County Planning & Community Development
1010 10th Street, Suite 3400
Modesto, CA 95354
FROM: Stanislaus County Department of Environmental Resources - Hazardous Materials Division SUBJECT: NOTICE OF AVAILABILITY OF THE COPPER TRAILS DRAFT

ENVIRONMENTAL IMPACT REPORT
Based on this agency’s particular field(s) of expertise, it is our position the above described project:

Will not have a significant effect on the environment.

May have a significant effect on the environment.

X No Comments.

Listed below are specific impacts which support our determination (e.g., traffic general, carrying capacity, soil types, air quality, etc.) – (attach additional sheet if necessary)

1. 2.

3. 4.

Listed below are possible mitigation measures for the above-listed impacts: PLEASE BE SURE

TO INCLUDE WHEN THE MITIGATION OR CONDITION NEEDS TO BE IMPLEMENTED (PRIOR TO RECORDING A MAP, PRIOR TO ISSUANCE OF A BUILDING PERMIT, ETC.):

1. 2.

3. 4.

In addition, our agency has the following comments (attach additional sheets if necessary).

Response prepared by:

Ninos Shamoon Hazardous Materials Specialist 1/27/25
Name Title Date
6A
EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-43 March 2026 STANISLAUS COUNTY PLANNING AND COMMUNITY DEVELOPMENT
Response 6A: This comment consists of a single page form indicating the Planning and Community Development Department has no comment on the EIR. No response is necessary.

EXHIBIT A ITEM 13
COMMENT NO. 7
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL

DISTRICT
January 27, 2025
Lea Simvoulakis
City of Ceres
Community Development Department
2220 Magnolia Street
Ceres, CA 95307
Project: Draft Environmental Impact Report for the Copper Trails Specific Plan and Annexation Project
District CEQA Reference No: 20241475
Dear Ms. Simvoulakis:

The San Joaquin Valley Air Pollution Control District (District) has reviewed the Draft Environmental Impact Report (DEIR) from the City of Ceres (City) for the project mentioned above. Per the DEIR, the project consists of the annexation of 680.7 acres for the development of up to 2,392 dwelling units and approximately 1,169,586 square feet of non-residential space (i.e. community commercial or Industrial uses) (Project).

The Project is located south and west of the existing Ceres incorporated area, bounded by state route 99 and Mitchell Road on the east, Service Road on the north, Blaker Road on the west, and TID Lower Lateral 2 on the south, in the Ceres, CA.

The District offers the following comments at this time regarding the Project:

Land Use Planning
Nearly all development projects within the San Joaquin Valley Air Basin, from Specific Plans to individual projects have the potential to generate air pollutants, making it more difficult to attain state and federal ambient air quality standards.

Land use decisions are critical to improving air quality within the San Joaquin Valley Air Basin because land use patterns greatly influence transportation needs, and motor vehicle emissions are the largest source of air pollution in the Valley. Land use decisions and project design elements such as preventing urban sprawl, encouraging mix-use development, and project design elements that reduce vehicle miles traveled (VMT) have proven to be beneficial for air quality. The District recommends that the DEIR incorporate strategies that reduce VMTs and require the cleanest available heavy duty trucks, vehicles, and off-road equipment, including zero and near-zero technologies. VMTs can be reduced through encouragement of 7A
EXHIBIT A ITEM 13
COMMENT NO. 7
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL

DISTRICT
San Joaquin Valley Air Pollution Control District Page 2 of 15 District Reference No: 20241375
January 27, 2025
mix-use development, walkable communities, etc. Additional design element options can be found at:
https://ww2.valleyair.org/media/ob0pweru/clean-air-measures.pdf In addition, since the Project includes the development of non-residential space (i.e. community commercial or industrial uses) the District recommends that the DEIR incorporate strategies that will advance implementation of the best practices listed in Tables 5 and 6 of California Air Resource Board’s (CARB’s) Freight Handbook Concept Paper, to the extent feasible. This document compiles best practices designed to address air pollution impacts as “practices” which may apply to the siting, design, construction, and operation of freight facilities to minimize health impacts on nearby communities. The concept paper is available at:
https://ww2.arb.ca.gov/sites/default/files/2020-03/2019.12.12%20- %20Concept%20Paper%20for%20the%20Freight%20Handbook_1.pdf Health Risk Screening/Assessment
The City should evaluate the risk associated with the Project for sensitive receptors (residences, businesses, hospitals, day-care facilities, health care facilities, etc.) in the area and mitigate any potentially significant risk to help limit exposure of sensitive receptors to emissions.

To determine potential health impacts on surrounding receptors (residences, businesses, hospitals, day-care facilities, health care facilities, etc.) a Prioritization and/or a Health Risk Assessment (HRA) should be performed for future development projects that may be approved under implementation of the Project.

These health risk determinations should quantify and characterize potential Toxic Air Contaminants (TACs) identified by the Office of Environmental Health Hazard Assessment/California Air Resources Board (OEHHA/CARB) that pose a present or potential hazard to human health.

Health risk analyses should include all potential air emissions from the project, which include emissions from construction of the project, including multi-year construction, as well as ongoing operational activities of the project. Note, two common sources of TACs can be attributed to diesel exhaust emitted from heavy-duty off-road earth moving equipment during construction, and from ongoing operation of heavy-duty on-road trucks.

Prioritization (Screening Health Risk Assessment):

A “Prioritization” is the recommended method for a conservative screening-level health risk assessment. The Prioritization should be performed using the California Air Pollution Control Officers Association’s (CAPCOA) methodology. Please contact the District for assistance with performing a Prioritization analysis. 7A
7B
7C
EXHIBIT A ITEM 13
COMMENT NO. 7
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL

DISTRICT
San Joaquin Valley Air Pollution Control District Page 3 of 15 District Reference No: 20241375
January 27, 2025
The District recommends that a more refined analysis, in the form of an HRA, be performed for any project resulting in a Prioritization score of 10 or greater. This is because the prioritization results are a conservative health risk representation, while the detailed HRA provides a more accurate health risk evaluation.

Health Risk Assessment:

Prior to performing an HRA, it is strongly recommended that land use agencies/ project proponents develop and submit for District review a health risk modeling protocol that outlines the sources and methodologies that will be used to perform the HRA.

A development project would be considered to have a potentially significant health risk if the HRA demonstrates that the health impacts would exceed the District’s established risk thresholds, which can be found here:
https://ww2.valleyair.org/permitting/ceqa/.

A project with a significant health risk would trigger all feasible mitigation measures.

The District strongly recommends that development projects that result in a significant health risk not be approved by the land use agency.

The District is available to review HRA protocols and analyses. For HRA submittals please provide the following information electronically to the District for review:
 HRA (AERMOD) modeling files
 HARP2 files
 Summary of emissions source locations, emissions rates, and emission factor calculations and methodologies.

For assistance, please contact the District’s Technical Services Department by:
 E-Mailing inquiries to: [email protected]
 Calling (559) 230-5900
Recommended Measure: Development projects resulting in TAC emissions should be located an adequate distance from residential areas and other sensitive receptors to prevent the creation of a significant health risk in accordance to CARB's Air Quality and Land Use Handbook: A Community Health Perspective located at https://ww2.arb.ca.gov/our-work/programs/resource-center/strategydevelopment/land-use-resources. 7C
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COMMENT NO. 7
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Ambient Air Quality Analysis
An Ambient Air Quality Analysis (AAQA) uses air dispersion modeling to determine if emissions increases from a project will cause or contribute to a violation of State or National Ambient Air Quality Standards. The District recommends an AAQA be performed for any future development projects that may be approved under implementation of the Project with emissions that exceed 100 pounds per day of any pollutant.

An AAQA uses air dispersion modeling to determine if emission increase from a project will cause or contribute to a violation of State or National Ambien Air Quality Standards. An acceptable analysis would include emissions from both projectspecific permitted and non-permitted equipment and activities. The District recommends consultation with District staff to determine the appropriate model and input data to use in the analysis.

Specific information for assessing significance, including screening tools and modeling guidance, is available online at the District’s website:
https://ww2.valleyair.org/permitting/ceqa/.

Voluntary Emission Reduction Agreement
The District recommends the DEIR include a feasibility discussion on implementing a Voluntary Emission Reduction Agreement (VERA) as a mitigation measure for future development projects that may be approved under implementation of the Project that are determined to exceed the District’s CEQA significance thresholds.

A VERA is a mitigation measure by which the project proponent provides pound-forpound mitigation of emissions increases through a process that develops, funds, and implements emission reduction projects, with the District serving a role of administrator of the emissions reduction projects and verifier of the successful mitigation effort. To implement a VERA, the project proponent and the District enter into a contractual agreement in which the project proponent agrees to mitigate project specific emissions by providing funds for the District’s incentives programs.

The funds are disbursed by the District in the form of grants for projects that achieve emission reductions. Thus, project-related impacts on air quality can be mitigated.

Types of emission reduction projects that have been funded in the past include electrification of stationary internal combustion engines (such as agricultural irrigation pumps), replacing old heavy-duty trucks with new, cleaner, more efficient heavy-duty trucks, and replacement of agricultural equipment with the latest generation technologies.

In implementing a VERA, the District verifies the actual emission reductions that have been achieved as a result of completed grant contracts, monitors the emission reduction projects, and ensures the enforceability of achieved reductions. After the 7D
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project is mitigated, the District certifies to the Lead Agency that the mitigation is completed, providing the Lead Agency with an enforceable mitigation measure demonstrating that project-related emissions have been mitigated. To assist the Lead Agency and project proponent in ensuring that the environmental document is compliant with CEQA, the District recommends the environmental document includes an assessment of the feasibility of implementing a VERA.

Industrial/Warehouse Emission Reduction Strategies
The District recommends the City incorporate emission reduction strategies that can reduce potential harmful health impacts for future industrial uses, such as those listed below:
 Require cleanest available heavy-duty trucks and off-road equipment (see comment 7
 Require HHD truck routing patterns that limit exposure of residential communities and sensitive receptors to emissions (see comment 6)  Require minimization of heavy-duty truck idling (see comment 8)  Require solid screen buffering trees, solid decorative walls, and/or other natural ground landscaping techniques are implemented along the property line of adjacent sensitive receptors
 Orient loading docks away from sensitive receptors unless physically impossible
 Require loading docks a minimum of 300 feet away from the property line of sensitive receptor unless dock is exclusively used for electric trucks  Incorporate signage and “pavement markings” to clearly identify on-site circulation patterns to minimize unnecessary on-site vehicle travel  Require truck entries be located on streets of a higher commercial classification
 Require projects be designed to provide the necessary infrastructure to support use of zero-emissions on-road vehicles and off-road equipment (see comment 10)
 Require all building roofs are solar-ready
 Require all portions of roof tops that are not covered with solar panels are constructed to have light colored roofing material with a solar reflective index of greater than 78
 Ensure rooftop solar panels are installed and operated to supply 100% of the power needed to operate all non-refrigerated portions of the development project
 Require power sources at loading docks for all refrigerated trucks have “plugin” capacity, which will eliminate prolonged idling while loading and unloading goods
 Incorporate bicycle racks and electric bike plug-ins
 Require the use of low volatile organic compounds (VOC) architectural and 7E
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industrial maintenance coatings
 Designate an area during construction to charge electric powered construction vehicles and equipment, if temporary power is available  Prohibit the use of non-emergency diesel-powered generators during construction
 Inform the project proponent of the incentive programs (e.g., Carl Moyer Program and Voucher Incentive Program) offered to reduce air emissions from the Project
 Ensure all landscaping be drought tolerant
Truck Routing
Truck routing involves the assessment of which roads Heavy Heavy-Duty (HHD) trucks take to and from their destination, and the emissions impact that the HHD trucks may have on residential communities and sensitive receptors. Since the Project will include non-residential development (i.e. community commercial, industrial uses), the Project has the potential to generate HHD truck trips.

The District recommends the City evaluate HHD truck routing patterns for future development projects, with the aim of limiting exposure of residential communities and sensitive receptors to emissions. This evaluation would consider the current truck routes, the quantity and type of each truck (e.g., Medium Heavy-Duty, HHD, etc.), the destination and origin of each trip, traffic volume correlation with the time of day or the day of the week, overall Vehicle Miles Traveled (VMT), and associated exhaust emissions. The truck routing evaluation would also identify alternative truck routes and their impacts on VMT and air quality.

Cleanest Available Heavy-Duty Trucks
The San Joaquin Valley will not be able to attain stringent health-based federal air quality standards without significant reductions in emissions from HHD trucks, the single largest source of NOx emissions in the San Joaquin Valley. Accordingly, to meet federal air quality attainment standards, the District’s ozone and particulate matter attainment plans rely on a significant and rapid transition of HHD fleets to zero or near-zero emissions technologies.

Since the Project will include non-residential development (i.e. community commercial, industrial uses), the Project has the potential to generate HHD truck trips. For future development projects, the District recommends that the following measures be considered by the City to reduce Project-related operational emissions:
 Recommended Measure: Fleets associated with operational activities utilize the cleanest available HHD trucks, including zero and near-zero technologies. 7F
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 Recommended Measure: All on-site service equipment (cargo handling, yard hostlers, forklifts, pallet jacks, etc.) utilize zero-emissions technologies.

Reduce Idling of Heavy-Duty Trucks
The goal of this strategy is to limit the potential for localized PM2.5 and toxic air contaminant impacts associated with the idling of Heavy-Duty trucks. The diesel exhaust from idling has the potential to impose significant adverse health and environmental impacts.

The District recommends the DEIR include measures to ensure compliance of the state anti-idling regulation (13 CCR § 2485 and 13 CCR § 2480) and discuss the importance of limiting the amount of idling, especially near sensitive receptors. In addition, the District recommends the City consider the feasibility of implementing a more stringent 3-minute idling restriction and requiring appropriate signage and enforcement of idling restrictions.

Electric On-Site Off-Road and On-Road Equipment
Since the Project will include Industrial uses, future development projects may have the potential to result in increased use of off-road equipment (e.g., forklifts) and onroad equipment (e.g., mobile yard trucks with the ability to move materials). The District recommends that the DEIR include requirements for project proponents to utilize electric or zero emission off-road and on-road equipment.

Electric Infrastructure
The District recommends that the City require all nonresidential buildings be designed to provide electric infrastructure to support the use of on-road zero emissions vehicles, such as HHD trucks associated with a warehouse or commercial projects.

On-Site Solar Deployment
It is the policy of the State of California that renewable energy resources and zerocarbon resources supply 100% of retail sales of electricity to California end-use customers by December 31, 2045. While various emission control techniques and programs exist to reduce air quality emissions from mobile and stationary sources, the production of solar energy is contributing to improving air quality and public health. The District suggests that the City consider incorporating solar power systems as an emission reduction strategy for future development projects that may be approved under implementation of the Project.
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EXHIBIT A ITEM 13
COMMENT NO. 7
SAN JOAQUIN VALLEY AIR POLLUTION CONTROL

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San Joaquin Valley Air Pollution Control District Page 8 of 15 District Reference No: 20241375
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Under-fired Charbroilers
Future development projects have the potential to include restaurants with underfired charbroilers. Such charbroilers may pose the potential for immediate health risk, particularly when located in densely populated areas or near sensitive receptors.

Since the cooking of meat can release carcinogenic PM2.5 species, such as polycyclic aromatic hydrocarbons, controlling emissions from new under-fired charbroilers will have a substantial positive impact on public health. The air quality impacts on neighborhoods near restaurants with under-fired charbroilers can be significant on days when meteorological conditions are stable, when dispersion is limited and emissions are trapped near the surface within the surrounding neighborhoods. This potential for neighborhood-level concentration of emissions during evening or multi-day stagnation events raises air quality concerns.

Furthermore, reducing commercial charbroiling emissions is essential to achieving attainment of multiple federal PM2.5 standards. Therefore, the District recommends that the DEIR include a measure requiring the assessment and potential installation, as technologically feasible, of particulate matter emission control systems for new large restaurants operating under-fired charbroilers.

The District is available to assist the City and project proponents with this assessment. Additionally, the District is currently offering substantial incentive funding that covers the full cost of purchasing, installing, and maintaining the system during a demonstration period covering two years of operation. Please contact the District at (559) 230-5800 or [email protected] for more information, or visit:
https://ww2.valleyair.org/grants/restaurant-charbroiler-technology-partnership/ Vegetative Barriers and Urban Greening
For future development projects within the Project area, and at strategic locations throughout the Project area in general, the District suggests the City consider incorporating vegetative barriers and urban greening as a measure to further reduce air pollution exposure on sensitive receptors (e.g., residences, schools, healthcare facilities).

While various emission control techniques and programs exist to reduce air quality emissions from mobile and stationary sources, vegetative barriers have been shown to be an additional measure to potentially reduce a population’s exposure to air pollution through the interception of airborne particles and the update of gaseous pollutants. Examples of vegetative barriers include, but are not limited to the following: trees, bushes, shrubs, or a mix of these. Generally, a higher and thicker vegetative barrier with full coverage will result in greater reductions in downwind pollutant concentrations. In the same manner, urban greening is also a way to help 7M
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improve air quality and public health in addition to enhancing the overall beautification of a community with drought tolerant, low-maintenance greenery.

Clean Lawn and Garden Equipment in the Community
Since the Project consists of residential and commercial development, gas-powered residential and commercial lawn and garden equipment have the potential to result in an increase of NOx and PM2.5 emissions. Utilizing electric lawn care equipment can provide residents with immediate economic, environmental, and health benefits.

The District recommends project proponents consider the District’s Clean Green Yard Machines (CGYM) program which provides incentive funding for replacement of existing gas powered lawn and garden equipment. More information on the District CGYM program and funding can be found at:
https://ww2.valleyair.org/grants/clean-green-yard-machines-residential/ and https://ww2.valleyair.org/grants/zero-emission-landscaping-equipment-voucherprogram/.

District’s Bikeway Incentive Program
Incorporating design elements (e.g., installing bikeways) within the Project that enhance walkability and connectivity can result in an overall reduction of vehicles miles traveled (VMT) and improve air quality within the area. The Project is expected to result in an overall reduction in VMT by installing bikeways, and may be eligible for funding through the District’s Bikeway Incentive Program. The Bikeway Incentive Program provides funding for eligible Class 1 (Bicycle Path Construction), Class II (Bicycle Lane Striping), or Class III (Bicycle Route) projects. These incentives are designed to support the construction of new bikeway projects to promote clean air through the development of a widespread, interconnected network of bike paths, lanes, or routes and improving the general safety conditions for commuter bicyclists.

Only municipalities, government agencies, or public educational institutions are eligible to apply. More information on the grant program can be found at:
https://ww2.valleyair.org/grants/bike-paths/
Guidelines and Project Eligibility for the grant program can be found at:
https://ww2.valleyair.org/media/drpijuw1/bikeway-program-guidelines-62515.pdf Nuisance Odors
While offensive odors rarely cause any physical harm, they can be unpleasant, leading to considerable distress among the public and often resulting in citizen complaints.

The City should consider all available pertinent information to determine if future development projects could have a significant impact related to nuisance odors.

Nuisance odors may be assessed qualitatively taking into consideration the 7O
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COMMENT NO. 7
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proposed business or industry type and its potential to create odors, as well as proximity to off-site receptors that potentially would be exposed to objectionable odors. The intensity of an odor source’s operations and its proximity to receptors influences the potential significance of malodorous emissions. Any project with the potential to frequently expose members of the public to objectionable odors should be deemed to have a significant impact.

According to the District Guidance for Assessing and Mitigating air Quality Impacts (GAMAQI), a significant odor impact is defined as more than one confirmed complaint per year averaged over a three-year period, or three unconfirmed complaints per year averaged over a three-year period. An unconfirmed complaint means that either the odor or air contaminant release could not be detected, or the source of the odor could not be determined.

As the future development projects that will fall within the project area do not yet exist, the City should and stipulate odor mitigation measures in the DEIR as conditions of approval for those business and industry types. An example would be for a project proponent whose project is determined to have a potentially significant odor impact to draft and implement an odor management plan as a mitigation measure in the DEIR.

District Rules and Regulations
The District issues permits for many types of air pollution sources, and regulates some activities that do not require permits. A project subject to District rules and regulations would reduce its impacts on air quality through compliance with the District’s regulatory framework. In general, a regulation is a collection of individual rules, each of which deals with a specific topic. As an example, Regulation II (Permits) includes District Rule 2010 (Permits Required), Rule 2201 (New and Modified Stationary Source Review), Rule 2520 (Federally Mandated Operating Permits), and several other rules pertaining to District permitting requirements and processes.

The list of rules below is neither exhaustive nor exclusive. Current District rules can be found online at: https://ww2.valleyair.org/rules-and-planning/current-district-rulesand-regulations. To identify other District rules or regulations that apply to future projects, or to obtain information about District permit requirements, the project proponents are strongly encouraged to contact the District’s Small Business Assistance (SBA) Office at (209) 557-6446.
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District Rules 2010 and 2201 - Air Quality Permitting for Stationary Sources
Stationary Source emissions include any building, structure, facility, or installation which emits or may emit any affected pollutant directly or as a fugitive emission. District Rule 2010 (Permits Required) requires operators of emission sources to obtain an Authority to Construct (ATC) and Permit to Operate (PTO) from the District. District Rule 2201 (New and Modified Stationary Source Review) requires that new and modified stationary sources of emissions mitigate their emissions using Best Available Control Technology (BACT).

Future development projects may be subject to District Rule 2010 (Permits Required) and Rule 2201 (New and Modified Stationary Source Review) and may require District permits. Prior to construction, project proponents shall obtain an ATC permit from the District for equipment/activities subject to District permitting requirements.

Recommended Mitigation Measure: For projects subject to permitting by the San Joaquin Valley Air Pollution Control District, demonstration of compliance with District Rule 2201 (obtain ATC permit from the District) shall be provided to the City before issuance of the first building permit.

For further information or assistance, project proponents may contact the District’s SBA Office at (209) 557-6446.

District Rule 9510 - Indirect Source Review (ISR)
Future development projects within the project area may be subject to District Rule 9510 if upon full buildout, the project would equal or exceed any of the following applicability thresholds, depending on the type of development and public agency approval mechanism:
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Table 1: ISR Applicability Thresholds
Development
Type
Discretionary
Approval Threshold
Ministerial Approval /
Allowed Use / By Right
Thresholds
Residential 50 dwelling units 250 dwelling units
Commercial 2,000 square feet 10,000 square feet
Light Industrial 25,000 square feet 125,000 square feet Heavy Industrial 100,000 square feet 500,000 square feet Medical Office 20,000 square feet 100,000 square feet
General Office 39,000 square feet 195,000 square feet
Educational Office 9,000 square feet 45,000 square feet Government 10,00 square feet 50,000 square feet
Recreational 20,000 square feet 100,000 square feet
Other 9,000 square feet 45,000 square feet
District Rule 9510 also applies to any transportation or transit development projects where construction exhaust emissions equal or exceed two tons of NOx or two tons of PM.

The purpose of District Rule 9510 is to reduce the growth in both NOx and PM emissions associated with development and transportation projects from mobile and area sources; specifically, the emissions associated with the construction and subsequent operation of development projects. The Rule requires developers to mitigate their NOx and PM emissions by incorporating clean air design elements into their projects. Should the proposed development project clean air design elements be insufficient to meet the required emission reductions, developers must pay a fee that ultimately funds incentive projects to achieve off-site emissions reductions.

In the case the individual development project is subject to District Rule 9510, per Section 5.0 of the rule, an Air Impact Assessment (AIA) application is required to be submitted no later than applying for project-level approval from a public agency so that proper mitigation and clean air design under ISR can be incorporated into the public agency’s analysis.

Information about how to comply with District Rule 9510 can be found online at:
https://ww2.valleyair.org/permitting/indirect-source-review-rule-overview The AIA application form can be found online at:
https://ww2.valleyair.org/permitting/indirect-source-review-rule-overview/formsand-applications/ 7T
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District staff is available to provide assistance with determining if future development projects will be subject to Rule 9510, and can be reached by phone at (559) 230-5900 or by email at [email protected].

District Rule 9410 (Employer Based Trip Reduction)
Future development projects may be subject to District Rule 9410 (Employer Based Trip Reduction) if the project would result in employment of 100 or more “eligible” employees. District Rule 9410 requires employers with 100 or more “eligible” employees at a worksite to establish an Employer Trip Reduction Implementation Plan (eTRIP) that encourages employees to reduce singleoccupancy vehicle trips, thus reducing pollutant emissions associated with work commutes. Under an eTRIP plan, employers have the flexibility to select the options that work best for their worksites and their employees.

Information about District Rule 9410 can be found online at:
https://ww2.valleyair.org/compliance/rule-9410-employer-based-trip-reduction/.

For additional information, you can contact the District by phone at 559-230- 6000 or by e-mail at [email protected]
District Rule 4002 (National Emissions Standards for Hazardous Air Pollutants)
In the event an existing building will be renovated, partially demolished or removed, future development projects may be subject to District Rule 4002.

This rule requires a thorough inspection for asbestos to be conducted before any regulated facility is demolished or renovated. Information on how to comply with District Rule 4002 can be found online at:
https://ww2.valleyair.org/compliance/demolition-renovation/ District Rule 4601 (Architectural Coatings)
Future development projects may be subject to District Rule 4601 since it may utilize architectural coatings. Architectural coatings are paints, varnishes, sealers, or stains that are applied to structures, portable buildings, pavements or curbs. The purpose of this rule is to limit VOC emissions from architectural coatings. In addition, this rule specifies architectural coatings storage, cleanup and labeling requirements. Additional information on how to comply with District Rule 4601 requirements can be found online at:
https://ww2.valleyair.org/media/tkgjeusd/rule-4601.pdf
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District Regulation VIII (Fugitive PM10 Prohibitions)
Project proponents may be required to submit a Construction Notification Form or submit and receive approval of a Dust Control Plan prior to commencing any earthmoving activities as described in Regulation VIII, specifically Rule 8021 – Construction, Demolition, Excavation, Extraction, and Other Earthmoving Activities.

Should the project result in at least 1-acre in size, the project proponent shall provide written notification to the District at least 48 hours prior to the project proponents intent to commence any earthmoving activities pursuant to District Rule 8021 (Construction, Demolition, Excavation, Extraction, and Other Earthmoving Activities). Also, should the project result in the disturbance of 5- acres or more, or will include moving, depositing, or relocating more than 2,500 cubic yards per day of bulk materials, the project proponent shall submit to the District a Dust Control Plan pursuant to District Rule 8021 (Construction, Demolition, Excavation, Extraction, and Other Earthmoving Activities). For additional information regarding the written notification or Dust Control Plan requirements, please contact District Compliance staff at (559) 230-5950.

The application for both the Construction Notification and Dust Control Plan can be found online at: https://ww2.valleyair.org/media/fm3jrbsq/dcp-form.docx Information about District Regulation VIII can be found online at:
https://ww2.valleyair.org/dustcontrol
District Rule 4901 - Wood Burning Fireplaces and Heaters The purpose of this rule is to limit emissions of carbon monoxide and particulate matter from wood burning fireplaces, wood burning heaters, and outdoor wood burning devices. This rule establishes limitations on the installation of new wood burning fireplaces and wood burning heaters.

Specifically, at elevations below 3,000 feet in areas with natural gas service, no person shall install a wood burning fireplace, low mass fireplace, masonry heater, or wood burning heater.

Information about District Rule 4901 can be found online at:
https://ww2.valleyair.org/compliance/residential-wood-smoke-reductionprogram/ Other District Rules and Regulations
Future development projects may also be subject to the following District rules:

Rule 4102 (Nuisance) and Rule 4641 (Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operations).
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If you have any questions or require further information, please contact Harout Sagherian by e-mail at [email protected] or by phone at (559) 230-5860.

Sincerely,
Tom Jordan
Director of Policy and Government Affairs
Mark Montelongo
Program Manager
EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-59 March 2026 RESPONSES SAN JOAQUIN VALLEY APCD
Response 7A: The potential VMT impacts of the project were addressed in detail in the draft EIR, under the heading TRANS-3. This discussion included listing of specific plan features which would tend to reduce VMT, including alternative transportation modes and other methods such as Commute Reduction Programs, Ridesharing Programs, End of Trip Bicycle Facilities, and Employer-Sponsored Vanpools. The CTSP includes features that would promote pedestrian and bicycle transportation use. As noted in subsequent comments, the project is not, however expected to result in substantial use of heavy-duty trucks as the proposed land uses permitted by the CTSP are limited to residential, retail and service commercial land use designations.

Response 7B: This comment, related to analysis of freight facilities, is not applicable to the proposed project. Such land uses are not permitted in the CTSP.

See also responses to Comments 7F through 7K.

Response 7C: This comment concerns potential generation of, and exposure of sensitive receptors to, hazardous air emissions or toxic air contaminants (TACs). In the event that such uses are proposed within the project area, for example automobile fueling facilities, addressed in the Draft EIR Chapter 6.0 Air Quality analysis, the APCD recommendations would be applicable; no such facilities are proposed at this time. The remainder of the comment discusses procedures for in evaluating potential health risks associated with TAC emitting facilities. These requirements, and any potential risks associated with proposed projects, should be considered in future CEQA review for those projects
Response 7D: This recommendation applies to potential future development projects that may result in emissions of 100 pounds per day or more of any pollutant. Such projects would be ordinarily larger in scale and would be subject to conditions of City approval requiring conformance with APCD regulations.

Response 7E: As suggested by the title, a VERA is a voluntary contractual agreement between the SJVAPCD and a project developer. If a VERA is warranted and considered feasible, both of which are determinations that must be made on a project-by-project basis, a project proponent can agree to mitigate project-specific emissions by providing funds for the District’s incentive programs that achieve emission reductions via indirect means such as by electrification of stationary internal combustion engines (such as agricultural irrigation pumps) and EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-60 March 2026 replacing old vehicles with new and more efficient vehicles among other things.

The size and potential air emissions associated with future development projects are, however, undetermined at this point in time.

In the event that a future development project involves significant air emissions that cannot be mitigated, the City can suggest the applicant to enter into a VERA; the explanation and technical information provided by the APCD would be helpful in this event. An alternative, if necessary, would be for the project to purchase offsets for pollutant amounts that exceed the APCD significance thresholds.

Response 7F: This comment applies to projects that involve industrial and warehousing land uses. There are no such uses proposed in either the CTSP or proposed zoning for the Pocket Area.

Response 7G: This comment applies to projects that involve industrial and warehousing land uses and heavy truck traffic. There are no such uses proposed in either the CTSP or proposed zoning for the Pocket Area.

Response 7H: This comment applies to projects that involve industrial and warehousing land uses and heavy truck traffic. There are no such uses proposed in either the CTSP or proposed zoning for the Pocket Area.

Response 7I: This comment applies to projects that involve industrial and warehousing land uses and heavy truck traffic. There are no such uses proposed in either the CTSP or proposed zoning for the Pocket Area.

Response 7J: This comment applies to projects that involve industrial and warehousing land uses and off-road equipment. There are no such uses proposed in either the CTSP or proposed zoning for the Pocket Area.

Response 7K: This comment applies to future projects that may involve industrial and commercial land uses that include substantial use of HHD trucks.

There are no such uses proposed in either the CTSP or proposed zoning for the Pocket Area. CTSP commercial areas are anticipated to include retail and service uses not likely involving substantial potential for any intensive use of HHD trucks.

Response 7L: This is a recommendation that the City consider incorporating solar power as an emissions reduction strategy for future development projects. The City appreciates the recommendation and has adopted the latest CalGreen energy conservation requirements including provisions for solar power installations.

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-61 March 2026 Response 7M: Therefore, the District recommends that the DEIR include a measure requiring the assessment and potential installation, as technologically feasible, of particulate matter emission control systems for new large restaurants operating under-fired charbroilers.

Response 7N: The City will consider this recommendation in its review of public street improvements and associated landscaping as well as in its review of SR 99/Service Road interchange improvement plana Response 7O: This information is incorporated in the Copper Trails Final EIR and will be made available to project applicants seeking City approvals pursuant to the specific plan.

Response 7P: The CTSP includes provisions that will facilitate installation of bicycle and pedestrian alternatives to vehicle traffic. The incentives described by the APCD will be available and made known to project applicants seeking city approval of development projects pursuant to the CTSP.

Response 7Q: The CTSP provides for low density to high density residential development as well as retail and service commercial land uses. The specific plan does not address, and future projects are not expected to include land uses that would be the source of objectionable odors. In the event that such uses are proposed within the project area, the city can be expected to request information related to odor emissions for consideration under CEQA, and to provide that information to the APCD for consideration as a part of the City’s interagency referral; if a project would involve significant odor concerns, the City would attach conditions of approval to any such projects.

Response 7R: The City is familiar with the range of APCD rules and regulations pertinent to land development, including projects that may involve point sources of pollution, as well as fugitive dust and other non-point emission sources. APCD rules and regulations were discussed in Chapter 6.0 Air Quality of the Draft EIR including their applicability to projects that may be submitted for City approval following approval of the CTSP and annexation of the project area. Several of these rules and regulations were addressed in the Draft EIR and are addressed in the following comments and responses, including Regulation VIII, Rule 4101, Rule 4601, Rule 4641, Rule 9410 Employer Based Trip Reduction and Rule 9510 Indirect Source Rule.

Response 7S: Projects that may be subject to Rules 2210 and 2201, that is projects involving stationary source emissions and toxic emissions, such as commercial fueling facilities, were discussed in the discussion of Impact AIR-4 regarding potential exposure of sensitive receptors to toxic pollutants.

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-62 March 2026 Response 7T: As noted in Response 7R, the districts Rule 9510 was discussed in detail in the Draft EIR and would be applicable to development projects within the project area that meet the threshold criteria for rule compliance as listed by the APCD. A mitigation measure has been added to the EIR via FEIR Chapter 4.0 Errata requiring the submittal of an AIA application to the APCD in conjunction with projects that would be subject to Rule 9510.

Response 7U: Rule 9410 was discussed in the Draft EIR. Compliance with this and the following rules listed in the EIR would, as appropriate, be required by the City’s Conditions of Approval requiring compliance with the applicable SJVAPCD Rules and Regulations.

Response 7V: See Response 7U.

Response 7W: See Response 7U.

Response 7X: See Response 7U.

Response 7Y: See Response 7U. Compliance with Regulation VIII is specifically addressed in Draft EIR Chapter 6.0 discussion of Construction Air Quality effects and compliance is required as an EIR mitigation measure.

Response 7Z: See Response 7U.

EXHIBIT A ITEM 13
COMMENT NO. 8
STANISLAUS COUNTY CEO
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EXHIBIT A ITEM 13
COMMENT NO. 8
STANISLAUS COUNTY CEO
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EXHIBIT A ITEM 13
COMMENT NO. 8
STANISLAUS COUNTY CEO
October 27, 2023
Sent Via Email to: [email protected]
Christopher Hoem, AICP
Community Development Director City of Ceres
2200 Magnolia Street
Ceres, CA 95307
SUBJECT: ENVIRONMENTAL REFERRAL – NOTICE OF PREPARATION OF A

DRAFT ENVIRONMENTAL IMPACT REPORT FOR COPPER TRAILS

SPECIFIC PLAN AND ANNEXATION
Mr. Hoem:

Please accept this letter as the formal response from Stanislaus County to the abovereferenced project. Staff has reviewed the subject project and the comments below represent Stanislaus County’s response to the City of Ceres Notice of Preparation of a Draft Environmental Impact Report (EIR) for the Copper Trails Specific Plan and Annexation.

Agricultural Resources
The project area is located adjacent to land identified as Agriculture in the County’s General Plan and zoned General Agriculture (A-2). Please include in the project's environmental document how the City of Ceres plans to ensure the future development will not impact the existing agriculture use through the use of agricultural buffers or other methods. If any existing schools outside of the boundaries of the project area are intended to serve the new development, the environmental document should reflect how impacts to agricultural resources will be minimized.

Mandatory Findings of Significance
The environmental document should study the project's effects on the environment in connection with past projects, current projects, and potential future projects to gain a complete understanding of the cumulative effects.

EXHIBIT A ITEM 13
COMMENT NO. 8
STANISLAUS COUNTY CEO