Ceres City Council
April 13, 2026

Hydrology
The West Turlock Subbasin Groundwater Sustainability Agency (GSA) is responsible for ensuring proposed developments within the Turlock Subbasin comply with the Turlock Subbasin Groundwater Sustainability Plan (GSP) as required by the Sustainable Groundwater Management Act. The proposed development project shall be referred to the GSA for review and comment.

Transportation/Circulation
The proposed project area’s southern boundary should be adjusted to include the full width of the Turlock Irrigation District’s (TID) canal right-of-way and should be adjusted to also include the TID right-of-way to the east to Morgan Road for uniformity.

Traffic operations and safety should be analyzed at the following locations to ensure they meet County General Plan requirements: Faith Home at Service intersection; Central at Grayson intersection; Central at Keyes intersection; and the Crows Landing Road corridor.

Traffic operations and safety should be analyzed on Central Avenue as the rural roadway transitions into the proposed project’s area from the south, including, but not limited to, the roadway geometrics (cross-section, roadway taper, and horizontal/vertical profile) and that access to Central Avenue from Gondring Road is not impacted.

Stanislaus County appreciates the opportunity to comment on this project, looks forward to further discussion to ensure a proper environmental analysis is conducted and requests to be included in any future publications or referrals for the EIR and Specific Plan.

Regards,
Tina M. Rocha
Assistant Executive Officer
Cc: Doug Dunford, Interim Ceres City Manager
Jody Hayes, Chief Executive Officer
Thomas Boze, County Counsel
Angela Freitas, Director, Planning and Community Development David Leamon, Director, Public Works Department
Robert Kostlivy, Director, Department of Environmental Resources Linda Pinfold, Agricultural Commissioner
EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-67 March 2026 RESPONSES TO COMMENT FROM STANISLAUS COUNTY C.E.O.

Response 8A: NEEDS CLARIFICATION FROM SPECIFIC PLAN AUTHORS Response 8B: The comment reinforces and adds to the airport safety discussion included in Chapter 11.0 of the EIR. No further response is necessary.

Response 8C: The EIR’s information regarding planned roadways is drawn from the Transportation section of the Specific Plan. The various roadway improvements, including the widening of Central Avenue south of the High School, the Central Avenue crossing of the TID canal, the available right-of-way and the transition to the two-lane section of Central Avenue through the unincorporated area south of the CTSP area and other design details will require and be worked out during interagency coordination, design and plan review and approvals involving the City, County and applicants, pursuant to the CTSP and other applicable City and County design requirements.

The comment highlights some of the County’s issues and concerns that will need to be addressed in the improvement plan approval process.

The referenced concerns are hereby included in the Final EIR. In their level of detail, the comments exceed the specificity of the CTSP roadway improvement plans, the EIR and the transportation impact analysis. These concerns will, however, be considered by the City and applicants in further processing of the CTSP, tentative maps and improvement plans. No further response is necessary.

Response 8D: This comment concerns City/County jurisdictional boundaries that would result from the CTSP annexation. The Stanislaus LAFCo (Comment #4) raises a related concern related to including the remainder of the TID canal in the annexation area. This is not an issue that would involve specific environmental impact but will require communication and coordination between the agencies, including TID, during the annexation process. No further response is required.

Response 8E: The vast majority of the Pocket Area is already developed, with approximately 25 scattered acres left vacant. Chapter 17.0 of the Draft EIR indicated that “Most of the developed portion of the Pocket Area is served by the City’s water system; the remaining portion either is served by individual groundwater wells or has no water service. In view of the City’s current surface water and groundwater supply, the potential water demand associated with any new development that may occur in the Pocket Area is not believed to be substantial.

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Copper Trails Specific Plan and Annexation Project, Final EIR 3-68 March 2026 Response 8F: The County’s NOP comment letter was inadvertently overlooked and not listed in the Draft EIR. The County’s concerns were, however, addressed in the Draft EIR as follows:

Agricultural Resources. Chapter 5.0 of the Draft EIR was devoted to issues associated with agricultural resources and minimizing agricultural land conversion impacts of
development.

Mandatory Findings. Chapter 18.0 of the Draft EIR
presented a subject-by-subject analysis of the potential cumulative effects of the project in each of the
environmental subject areas addressed in Chapters 4.0 –

17.0 of the EIR.

Hydrology. Chapter 12.0 Hydrology and Water Quality of
the Draft EIR included detailed discussion of groundwater resources in the Turlock Subbasin and the Sustainable
Groundwater Management Act.

Transportation/Circulation. The concerns are the same as identified as comment 8C and addressed in Response 8C,
above.

EXHIBIT A ITEM 13
COMMENT NO. 9
CERES UNIFIED SCHOOL DISTRICT
Harold M. Freiman
Attorney at Law E-mail: [email protected]
Limited Liability Partnership
2001 North Main Street, Suite 500 Walnut Creek, California 94596 Tel 925-953-1620 Fax 925-953-1625 August 29, 2025
By U.S. Mail & E-Mail: [email protected]
Ann Montgomery
Planning Administrative Secretary
City of Ceres
Planning Division
2220 Magnolia Street
Ceres, CA 95307
Re: Response of Ceres Unified School District to Draft Environmental Impact Report for the Copper Trails Specific Plan and Annexation Project
Dear Ms. Montgomery:

On behalf of the Ceres Unified School District (“District”), we hereby submit comments regarding the Draft Environmental Impact Report (“Draft EIR”) prepared for the proposed Copper Trails Specific Plan and Annexation Project (“Specific Plan” or “Project”). It is intended that these comments be included as part of the formal administrative record for the Project. As set forth in this letter, the Draft EIR does not comply with the California Environmental Quality Act (“CEQA,” Pub. Resources Code, §§ 21000, et seq.) and the CEQA Guidelines (Cal. Code Regs., tit. 14, §§ 15000, et seq.) for both technical and substantive reasons. Specifically, the District was not adequately consulted in the process of drafting the EIR as required by CEQA (Pub. Resources Code, § 21153, subd. (a)). Moreover, the Draft EIR, based on an improper interpretation of statutes added and amended by Senate Bill (SB) 50, does not include sufficient information to evaluate potential environmental impacts both on schools, and related to schools.

Through this letter, the District again wishes to emphasize that this Project, in combination with the numerous other projects currently pending before the City, has the potential to have a profound negative effect on the District’s students, their families, and residents who will reside in and near the Project
As another public agency serving the population of Ceres, the District prefers to cooperate with the City regarding the proposed Project so as to help ensure that it will meet this goal and benefit the entire community, without undue and unmitigated impacts. It remains the District’s hope that collaboration between the District and both the City and the Project developers can occur to address the significant concerns addressed below.

Nevertheless, the District submits its comments and concerns regarding the impacts that substantial development in the City is having and will continue to have on the District. It 9A
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remains our hope that coordination can occur regarding school related impacts before it is too late to do anything meaningful about those issues.

With the foregoing in mind, the District requests that the City revise the Draft EIR to address the serious deficiencies identified in this letter, develop appropriate mitigation measures for impacts that are identified as significant, and then recirculate the revised Draft EIR as required by CEQA. (CEQA Guidelines § 15088.5.) In that process, the District requests that the City and Developer coordinate with and meaningfully engage the District.

I. The City failed to meaningfully meet and confer with the District The environmental review process is guided by the CEQA framework that emphasizes the need for interagency communication and public input. Public Resource Code section 21153, subdivision (a), mandates that:

Prior to completing an environmental impact report, every local lead agency shall consult with, and obtain comments from, each responsible agency, trustee agency, any public agency that has jurisdiction by law with respect to the project, and any city or county that borders on a city or county within which the project is located unless otherwise designated annually by agreement between the local lead agency and the city or county, and may consult with any person who has special expertise with respect to any environmental impact involved.

This statutorily required meet and confer process is necessary to ensure that local agencies are coordinated when it comes to future development of the City.

The District’s jurisdiction encompasses the Project area and the existing school sites - Central Valley High School, Hidahl Elementary School, and Hanline Elementary School (“School Sites”) - within the Specific Plan Area. Further, school housing of the students generated by the Project will be the responsibility of the District. Despite the obvious and significant interest that the District has in this environmental review process, neither the City nor the Applicant has made any meaningful attempts to engage, confer, or consult with the District regarding this Project.

The lack of meaningful outreach to a public agency with clear interest and jurisdiction with respect to the project represents a major oversight in the environmental review process.

II. The Draft EIR does not meet its purpose as an informational document because it fails to provide an adequate description of the environmental setting related to schools.

One of CEQA’s basic purposes is to inform government decision-makers and the public about the potential significant environmental effects of proposed projects and to disclose to the public the reasons for approval of a project that may have significant environmental effects. (CEQA Guidelines § 15002, subds. (a)(1) and (a)(4).) In line with this goal, the preparer of an EIR must make a genuine effort to obtain and disseminate information necessary to the understanding of impacts of project implementation. (See, CEQA Guidelines § 15151; Sierra Club v. State Board of Forestry (1994) 7 Cal.App.4th 1215, 1236.)
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COMMENT NO. 9
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August 29, 2025

An EIR must describe existing environmental conditions in the vicinity of the proposed project from both a local and regional perspective, which is referred to as the “environmental setting.” (CEQA Guidelines § 15125.) This description of existing environmental conditions serves as the “baseline” for measuring the qualitative and quantitative changes to the environment that will result from the project and for determining whether those environmental effects are significant. (Id.; see also, CEQA Guidelines § 15126.2, subd. (a); Neighbors for Smart Rail v. Exposition Metro Line Constr. Auth. (2013) 57 Cal. 4th 439, 447.)
District facilities are a critical part of the Project location’s environment and should be considered throughout the Draft EIR impact categories. However, the Draft EIR fails to present adequate information needed to assess the Project’s environmental impacts on the District and District students. Each of the environmental setting sections preceding the impact analysis contain only a cursory mention of the School Sites or other District schools if at all. Specifically, the Draft EIR fails accurately and fully to address the current and projected future enrollment at the School Sites within the CTSP or any other District schools that will be affected by the Project; a description of how the District currently uses its facilities at the School Sites; and the current vehicular and pedestrian paths of travel used by District staff, students, and their families to get to and from these schools, in the context of a neighborhood that has already been severely impacted by traffic. Moreover, the Draft EIR makes no mention of current remaining capacity at any of the schools. Without consideration of these factors, it is impossible for the lead agency and public to assess whether there are any impacts posed by the Project on the District’s students, families, and staff, and whether those impacts are significant.

For example, the Draft EIR assumes that the Hanline Elementary School site is anticipated to transition to elementary school use “as demand requires.” (DEIR at 535.) While originally designed as an elementary school, the Hanline Elementary School site currently functions as a multi-program educational site that supports several key District initiatives including Central Valley High School (CVHS) overflow classrooms; the Leaps and Bounds Program, which is the District’s adult transition program for individuals with special needs; the Alternative to Suspension (“A2S”) Program which serves students who are referred in lieu of suspension; and the Ceres Adult School which offers daytime classes in General Education Development (“GED”) and High School Equivalency Test (“HiSET’) preparation, the English as a Second Language (“ESL”) Program, citizenship and independent study.

As noted above, the Hanline Elementary School supports several specialized programs that would face significant challenges if required to relocate or undergo a change in use due to an influx of new students. Programs such as Leaps and Bounds and AS2 rely heavily on Hanline’s unique physical layout, flexible space, and campus accessibility to meet the distinct needs of their students. Relocating these programs would likely result in the loss of purpose-built or adapted spaces essential to their operation and cause changes in traffic flows. Finding comparable facilities elsewhere would be difficult and could diminish both the quality and scope of services offered, particularly for students with special needs or those requiring structured behavioral and academic interventions.

Transitioning to new locations may also interrupt instruction, services, and student routines.

Such disruptions are especially destabilizing for students with Individualized Education Programs (IEPs), intensive support needs, or those participating in restorative discipline programs like A2S. Programs intentionally designed to operate in non-traditional, separate settings may be compromised if forced onto standard school campuses, undermining their 9D
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effectiveness and purpose. Transportation and access challenges further complicate relocation.

The A2S program currently coordinates with CVHS transportation routes and moving it could result in increased absenteeism and reduced access for students who rely on CVHS-aligned bus schedules. Similarly, adult learners enrolled in Ceres Adult School may struggle to reach new locations, especially if relocated to sites lacking public transit options or adequate parking.

In addition, programs like Leaps and Bounds benefit from quiet, structured environments separate from the general student population. Relocating to a busier or less secure campus could compromise student safety, independence training, and privacy, particularly for young adults with disabilities transitioning to life and work beyond school. Operationally, moving multiple programs may require modifications to existing campuses, additional supervision and security protocols, and increased burdens on maintenance, transportation, and administrative teams. Staff may face heavier workloads and challenges adapting curriculum or routines to new, less suitable environments, which could negatively impact service delivery and staff morale.

Finally, programs like A2S and Leaps and Bounds have cultivated a strong culture and identity tied to their current space. Relocation risks undermining student buy-in, lowering morale and engagement, and reducing program effectiveness especially for vulnerable or high-risk youth.

These cumulative impacts underscore the importance of preserving Hanline’s current use and ensuring that any proposed changes are carefully evaluated in consultation with the District and program stakeholders.

The current uses of the Hanline facility are neither detailed nor acknowledged in the Draft EIR, even though the Draft EIR provides that the Project will result in a change in use. The EIR cannot adequately analyze the associated impacts without first establishing and describing the baseline conditions of the facility. The Draft simply implies that the site will be used as an elementary school, without considering the full range of impacts that come with displacing existing programs. These impacts cannot be properly assessed without a clear description of the current uses, which the Draft EIR fails to provide.

III. The Draft EIR does not meet its purposes as an informational document because it fails to provide an adequate analysis of environmental impacts on and related to schools.

The Draft EIR states that the proposed Project would have a significant impact on the environment related to public services such as schools if it would:

Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or generate a need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for [Schools].
(DEIR at 15-6.)
The Draft EIR projects that the new students generated by the Project exceed the current capacity available at District schools but provides no details whatsoever as to how those students will be housed or where new facilities will be located. Without an understanding of where new facilities will be built and where existing facilities will have to be expanded, the Draft EIR cannot possibly attempt to provide an adequate analysis of the Project’s impact on schools. 9E
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In describing the current state of the District’s schools, the Draft EIR states that the District’s enrollment was 4,546 high school students grades 9 through 12, 2,120 junior high school students grades 7 through 8, and 7,873 students elementary school students grades K through 6. (DEIR at 15-8.) As noted above, the Draft EIR makes no mention of the remaining capacity, just that “[i]n its School Facility Needs Analysis, the CUSD determined there is excess capacity at the K-6 and 7-8 grade levels to house students generated from new development…” (Id.) However, the Draft EIR goes on to explain that the Project will generate a need for new or altered school facilities:

Development and occupation of the residential portions of the CTSP will lead to the generation of additional student populations over time. Potential future student generation would amount to approximately 1,291 K-6 students, 340 middle school students, and 581 high school students, based on the residential development potential of 1,050 residential units, and student generation factors used by CUSD, as presented in Table 15-1. (Id.) The Draft EIR notes that, “buildout of the CTSP would contribute to the projected need for school expansion or new schools within CUSD. . . the project would, over time, generate the need for two elementary schools to accommodate elementary students. . . new facilities would be required to accommodate the anticipated number of high school students” (Id.) It also notes that new facilities would be required to accommodate the anticipated number of high school students.

Despite this, the Draft EIR gives no consideration as to where the new students will be accommodated, which schools would need to expand their facilities or where the entirely new facilities will be located.

This data appears to be based on a School Facility Needs Analysis from 2019. As this large project will take years to construct, the Draft EIR relies on current enrollment statistics and does not account for or analyze potential future changes in enrollment trends in the attendance area.

The Draft EIR then goes on to claim that “[w]ith payment of development impact fees to CUSD, project impacts on schools are considered less than significant.” (DEIR at 15-9.) Through this short and conclusory analysis, the Draft EIR failed to appropriately analyze the Project’s potential impacts under the above-cited Public Services CEQA threshold.

In order to support a determination that environmental impacts are insignificant the lead agency must include in the EIR the reasons that the applicable environmental effects were determined to be insignificant. (Pub. Res. Code § 21100, subd. (c); CEQA Guidelines § 15128.) An unsubstantiated conclusion that an impact is not significant, without supporting information or explanatory analysis, is insufficient; the reasoning supporting the determination of insignificance must be disclosed. (See, City of Maywood v. Los Angeles Unified Sch. Dist. (2012) 208 Cal.App.4th 362, 393; San Joaquin Raptor/Wildlife Rescue Ctr. v. County of Stanislaus (1994) 27 Cal.App.4th 713 [findings that project will not pose biological impacts to wetlands must be supported by facts and evidence showing that the lead agency investigated the presence and extent of wetlands on the property, which analysis must be disclosed to the public].) The approach utilized in the Draft EIR oversimplifies and understates the various ways in which large residential and commercial development projects, like the Project, can impact a school district’s need for new or physically altered facilities in order to maintain performance 9E
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objectives. These documents fail to analyze all potential impacts under this standard, including but not limited to: (1) whether the influx of students would require “physically altered” school facilities unrelated to the accommodation of additional enrollment; (2) whether other impacts of the proposed Project, such as increased traffic, noise, or air pollutants in the neighborhood surrounding the Project area, could impact the District’s need for new or physically altered school facilities; and (3) whether other impacts of the proposed Project could otherwise interfere with the District’s ability to accomplish its own performance objectives.

Finally, the Draft EIR fails adequately to analyze cumulative public services impacts on the District due to extensive new development within District boundaries. EIRs must discuss cumulative impacts of a project when the project’s effects on the environment, viewed in conjunction with impacts of other past, present, or reasonably foreseeable future projects, is cumulatively considerable. (CEQA Guidelines § 15130(a); see, San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus (1994) 27 Cal.App.4th 713, 720, finding that piecemeal approval of several projects with related impacts could lead to severe environmental harm.) The purpose of the cumulative impacts analysis is to avoid considering projects in a vacuum, because failure to consider cumulative harm may risk environmental disaster. (Whitman v. Board of Supervisors (1979) 88 Cal.App.3d 397, 408.)
The District anticipates that the combined impact of the Project and all other residential development and commercial development projects in District boundaries and the Project neighborhood will significantly impact the District’s ability to provide its public service in accordance with established performance objectives, and that the Project’s incremental effect is cumulatively considerable. (CEQA Guidelines § 15130, subd. (a).) It is further anticipated that the Project, when viewed in conjunction with numerous other projects, will cause the District to need new or physically altered school facilities. At this point, given the extent of pending and approved development, the need for new or altered facilities has likely become unavoidable.

The Draft EIR was required to provide sufficient information for the public and lead agency to assess these impacts and potential mitigation measures. The environmental documents do not provide this information.

A. The Draft EIR contains an inadequate discussion of all other “school-related” impacts.

In addition to impacts on the District’s facilities under the Public Services CEQA threshold of significance noted above, the Draft EIR fails adequately to analyze probable Project impacts “related to” schools, as required by CEQA and case law interpreting CEQA. In disregarding these impacts, the Draft EIR and Initial Study attempt to rely on Government Code section 65996, enacted by SB 50. However, reliance on SB 50 and Government Code section 65996 as the remedy for all school impacts caused by the Project on the District demonstrates a misunderstanding regarding the law and developer fees.

The Draft EIR’s stated objectives include “Fiscal Responsibility” with the stated goal of creating a development plan that “can be implemented in a fiscally responsible manner, with neutral or positive fiscal impacts to the City and with identified revenue sources for the long-term maintenance of park facilities, open space areas, trails, landscape corridors, public services, and infrastructure.” (DEIR at 3-3.) However, there is no estimate of the cost of the Project to the 9E
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District. Without an estimate of the cost to the District, it is impossible to claim that the impact fees collected by the District would offset those costs.

Developer fees generally are fees that may be levied or imposed in connection with or made conditions of any legislative or adjudicative act by a local agency involving planning, use, or development of real property. (Ed. Code § 17620.) “Level 1” developer fees are levied against residential and commercial or industrial developments on a per square foot basis. If a school district is able to establish a sufficient “nexus” between the expected impacts of residential and commercial development and the district’s needs for facilities funding, then the district may currently charge up to $5.17 per square foot of residential development, and up to $0.84 per square foot of commercial development, which statutory amounts may be increased every two years based on the statewide cost index for class B construction.

The Draft EIR indicates that while the District qualifies to impose Level II development impact fees on new construction, it has chosen to continue levying Level I fees. The District wishes to clarify that this decision is due to the fact that the calculated Level II fee, which is based solely on factors spelled out in statute, would result in a lower fee than the existing Level I rate. The District is thus collecting the highest statutory fee for which it is eligible.

From a practical standpoint, the amount of developer fees received by school districts typically fall woefully short of alleviating the impacts caused by development. This is due largely to the facts that: (1) statutory developer fee amounts fail to acknowledge the differences in costs of school construction from one district to another; (2) the developer fee amounts fail to contemplate the special facilities needs of those districts experiencing rapid growth, such as the need for portable classrooms; and (3) the adjustment formula for developer fees is based on a “construction cost index” and does not include indexing related to the increases in land costs, resulting in the actual costs of facilities (i.e., land and improvements) increasing at a greater rate than the adjustment.

The inadequacy of developer fees as a source of funding for school facilities has forced school districts to rely increasingly on other sources of funding, primarily including local bond funds and State bond funds administered under the State’s School Facilities Program (SFP). However, these sources of funds can be equally unreliable. Local bond funds are difficult to generate, as local bonds are subject to school district bonding capacity limitations and voter approval. State funds are also unreliable and take considerable time to obtain. Either way, the funding formula was never intended to require the State and local taxpayers to shoulder a disproportionate portion of the cost of school facilities.

SB 50 declares that the payment of the developer fees authorized by Education Code section 17620 constitutes “full and complete mitigation of the impacts of any legislative or adjudicative act on the provision of adequate school facilities.” (Gov. Code § 65995(h); see also, Gov. Code § 65996(a).) However, California courts have since acknowledged that payment of developer fees does not constitute full and complete mitigation for school-related impacts other than impacts “on school facilities” caused by overcrowding. (Chawanakee Unified Sch. Dist. v. Cty. of Madera (2011) 196 Cal.App.4th 1016 (“Chawanakee”).) Chawanakee addressed the extent to which the lead agency (Madera County) was required to consider school-related impacts in an EIR for new development. The court determined that SB 50 does not excuse a lead agency from conducting environmental review of school impacts other than an impact “on school facilities.” The court required that the County set aside the certification of the EIR and approvals of the 9F
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project and take action necessary to bring the EIR into compliance with CEQA. (Id. at 1029.) In so holding, the court explained as follows:
[A]n impact on traffic, even if that traffic is near a school facility and related to getting students to and from the facility, is not an impact ‘on school facilities’ for purposes of Government Code section 65996, subdivision (a). From both a chronological and a molecular view of adverse physical change, the additional students traveling to existing schools will impact the roadways and traffic before they set foot on the school grounds.

From a funding perspective, the capped school facilities fee will not be used by a school district to improve intersections affected by the traffic. Thus, it makes little sense to say that the impact on traffic is fully mitigated by the payment of the fee. In summary ... the impact on traffic is not an impact on school facilities and, as a result, the impact on traffic must be considered in the EIR.
(Id. at 1028-29.)
Here, for example, the Draft EIR intimates that new school facilities will have to be built at undecided location, suggesting the District “may consider construction of new schools or redistribution of student load among existing schools.” (DEIR at 15-8.) Without even an estimation of where students may need to travel to attend school, it is impossible to estimate the vehicle miles traveled (VMT.) This has not been analyzed or addressed in the EIR as required. (Cal. Code Regs., tit. 14, § 15064.3.)
Contrary to the assertions of the Draft EIR, the payment of fees does not constitute full mitigation for all impacts caused by development, including those related to traffic, noise, biological resources, air quality, pedestrian safety, and all other types of impacts “related to” the District and its educational program. The Draft EIR’s approach is significantly flawed and inconsistent with the requirements of Chawanakee, as it failed to analyze the information necessary to determine whether the Project results in significant environmental impacts both on and related to schools.

Specific areas where the Draft EIR and Initial Study failed adequately to evaluate school-related impacts are discussed below:
i. Traffic and Transportation
Though the Draft EIR acknowledges that the Project will exacerbate existing traffic conditions and generally analyzes the traffic impacts anticipated by the Project, its analysis is inadequate, particularly as related to schools. The following issues require the City to revise and recirculate the Draft EIR.

The Draft EIR was required to address potential effects related to traffic, including noise, air quality, and any other issues affecting schools. (Pub. Resources Code, §§ 21000, et seq.; Cal.

Code Regs., tit. 14, §§ 15000, et seq.; Chawanakee, supra, 196 Cal.App.4th 1016.) Additionally, specifically related to traffic, the Draft EIR was required to analyze safety issues related to traffic impacts, such as reduced pedestrian safety, particularly as to students walking or bicycling to and from the School Sites located within the CTSP Area; potentially reduced response times for emergency services and first responders traveling to these schools; and increased potential for accidents due to gridlock during school drop-off and pick up hours. 9F
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The requirement to analyze student safety issues is rooted in both the California Constitution and CEQA. Article I, section 28(c), of the California Constitution states that all students and staff of primary, elementary, junior high, and senior high schools have the inalienable right to attend campuses that are “safe, secure, and peaceful.” CEQA is rooted in the premise that “the maintenance of a quality environment for the people of this state now and in the future is a matter of statewide concern.” (Pub. Res. Code § 21000(a).) Naturally, safety is crucial in the maintenance of a quality environment. “The capacity of the environment is limited, and it is the intent of the Legislature that the government of the state take immediate steps to identify any critical thresholds for health and safety of the people of the state and take all coordinated actions necessary to prevent such thresholds being reached.” (Pub. Res. Code § 21000, subd. (d).) The Legislature has made clear in declarations accompanying CEQA's enactment that public health and safety are of great importance in the statutory scheme. (Pub. Res. Code §§ 21000, subds. (b), (c), (d), (g); 2100, subds. (b), (d) (emphasizing the need to provide for the public's welfare, health, safety, enjoyment, and living environment.) (California Building Industry Assn. v. Bay Area Air Quality Management Dist. (2015) 62 Cal.App.4th 369, 386.) The Draft EIR concedes that potential environmental concerns associated with the Project include the general impacts of urban expansion on “existing traffic congestion during school arrival and departure hours, development impacts on public services and concerns regarding how the costs of services will be met, and safe routes to schools.” (DEIR at 1-7.) However, it fails to analyze the following issues:

1. The existing and the anticipated vehicular traffic and student pedestrian movement patterns to and from school sites, including movement patterns to and from the School Sites within the CTSP Area and any other school facilities where CTSP Area students would be traveling, and including consideration of bus routes.

2. The impact(s) of increased vehicular movement and volumes caused by the Project, including but not limited to potential conflicts with school pedestrian movement, school transportation, and busing activities to and from those School Sites.

3. The estimated travel demand and trip generation, trip distribution and trip assignment by including consideration of school sites and home-to-school travel.

4. The cumulative impacts on schools and the community in general resulting from increased vehicular movement and volumes expected from additional development already approved or pending.

5. The direct, indirect, and cumulative impacts on the circulation and traffic patterns in the community as a result of traffic generated by the transportation needs of students to and from the Project and schools throughout the District during the Project buildout.

6. The impacts on the routes and safety of students traveling to school by vehicle, bus, walking, and bicycles.

There is, therefore, no way for the lead agency or the public to assess how the Project will pose a traffic impact related to the District’s provision of public services. 9G
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The District has identified several traffic and safety concerns related to the Project. The area surrounding the School Sites already experience heavy traffic during student drop-off and pickup times. Parents often resort to parking in nearby orchards on Central Avenue or along unmarked shoulders due to lack of available and convenient parking. Additionally, its common to see students exiting vehicles in the middle of the road, creating serious safety hazards for both pedestrians and drivers. The addition of housing and students to this area will create an increase in the number of vehicles during peak school hours, worsening congestion and escalating safety risks.

The construction of, and traffic generated by, the Project will severely exacerbate the existing inadequacies in the City’s roadways noted above, the already impacted traffic in the general area, and the safety issues posed thereby. These impacts will severely inhibit the District’s ability to operate its educational programs, including at the School Sites.

However, none of these issues were properly analyzed in the Draft EIR.

The District’s concerns are validated by the City’s Transportation Impact Analysis and related conclusions. The Analysis identified significant and unavoidable impacts on traffic in the form of vehicle queuing that exceeds the roadway’s current capacity. A micro-simulation conducted as part of the Analysis that showed that the Project would have a queueing impact on the SR 99 Southbound Off-Ramp to Service Road under Near-Term Plus Project PM peak hour conditions as the queue is projected to exceed the available storage. (Transportation Impact Analysis at iii.) Further, the Vehicle Miles Traveled (VMT) metrics show that the CTSP VMT exceeds the VMT significance threshold. The Draft concludes that the efficacy of certain mitigation measures “cannot be reliably quantified at this time; as a result, the project would be potentially inconsistent with the objectives of CEQA Guidelines Section 15064(b), and the project’s VMT impacts would remain potentially significant and unavoidable.” (DEIR at 16-15.) However, there was absolutely no analysis of how these anticipated traffic impacts would affect schools and students, families and staff traveling to and from schools.

The Draft EIR is also required to provide sufficient information regarding any secondary impacts that may result from inadequate parking, such as safety impacts to students traveling to and from school. (See, Covina Residents for Responsible Development v. City of Covina (2018) 21 Cal.App.5th 712, 728.) Any secondary impacts on pedestrian and student safety caused by inadequate parking must be analyzed in the Draft EIR.

Finally, the Draft EIR’s cumulative traffic impacts analysis is deficient. As noted above, EIRs must discuss cumulative impacts of a project when the project’s effects on the environment, viewed in conjunction with impacts of other past, present, or reasonably foreseeable future projects, are cumulatively considerable. (CEQA Guidelines § 15130, subd. (a).) (See, San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus (1994) 27 Cal.App.4th 713, 720.) While a lead agency may incorporate information from previously prepared program EIRs into the agency’s analysis of a project’s cumulative impacts, the lead agency must address all cumulative impacts that were not previously addressed in the program EIR. (Pub. Res. Code § 21083.3, subd. (c); 14 CCR 14183, subd. (b)(3).)
The Project’s above-discussed anticipated traffic and safety impacts, combined with the anticipated traffic and safety impacts of the development projects that have recently been approved and are being considered for approval in Ceres are cumulatively considerable. When 9H
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considered together, their collective impacts on traffic, safety, and air quality in the neighborhood will be significant. These cumulative impacts on District schools were not adequately discussed in the Draft EIR, and the City proposes no clear measures that could successfully mitigate the impacts.
i. Greenhouse Gas Emissions (GHG)
The Draft EIR concedes that the Project would result significant GHG emissions even with application of GHG reduction measures and regulations and that Project impacts are considered significant and unavoidable. (10-12.) The Draft EIR fails to consider the GHG emission impacts on school sites and families, staff and students traveling to and from those sites, nor is there analysis of how the laws and regulations will work to reduce impacts to a level of less than significant. This analysis is again insufficient.
ii. Air Quality
The Draft EIR analyzes air quality impacts posed by construction and operation of the Project.

The Draft EIR further recognizes that the proposed Project would pose a significant environmental impact if it would expose “sensitive receptors,” including schools, to substantial pollutant concentrations. (Draft EIR at 6-12.) The Draft EIR does not, however, specifically discuss potential construction and operational air quality impacts as they pertain to the School Sites, and students traveling to and from the School Sites or to other schools outside the CTSP Area. Air quality impacts on the District, its students, and staff have the potential to disrupt classes, prevent students from being outside during construction, and prevent students from traveling to and from the School Sites. The Draft EIR is, therefore, required to analyze the following:

1. The direct and indirect air quality impacts of the Project on sensitive receptors, such as the District’s School Sites.

2. The cumulative air quality impacts on schools and the community in general resulting from increased vehicular movement and volumes expected from additional development already approved or pending in the area.

The City determined that the impact on sensitive receptors would be less than significant as it relates to criteria pollutants and less than significant as it relates to toxic air contaminants after application of mitigation measures. (Draft EIR at 6-20 to 6-21.) However, in its analysis of air quality impacts on sensitive receptors, the City states that San Joaquin Valley Air Pollution Control District (SJVAPCD) regulations would be followed, and thresholds would not be exceeded. Thus, the Draft EIR’s assumption that the Project will comply with air quality plans and applicable regulations appears to serve as the only form of analysis related to air quality impacts on the District’s students. There is no specific mention of District schools or students in this section of the Draft EIR. The District reiterates its desire for a more comprehensive analysis of air quality impacts.

As the Air Quality impacts discussion does not provide sufficient information needed to analyze air quality impacts on the District’s students and School Sites, the discussion of air quality impacts is lacking, and the Draft EIR is not in compliance with CEQA. 9J
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iii. Noise
In its analysis, the Draft EIR notes that a school is a noise sensitive land use. (Draft EIR at 14-

3.) As such, the Draft EIR appears to acknowledge that noise impacts on the School Sites must be analyzed and does so minimally. The Draft EIR states that a project may have a significant impact on noise if it would result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. Ceres Municipal Code Section 9.04.010 states that it is unlawful for any person to make, continue or cause to be made or continued any loud, unnecessary, or unusual noise or any noise which either annoys, disturbs, injures, or endangers the comfort, repose, health, peace, or safety of others. The Noise Element of the Ceres General Plan considers an exterior noise environment of up to 60 dBA “normally acceptable” and one up to 65 dBA is considered “conditionally acceptable” for multifamily residential, along with schools, libraries, churches, hospitals, and nursing homes. (City of Ceres 2018.)
Further, the following increases in traffic noise levels would be considered a significant impact:
+5.0 dB or more if ambient noise level without project is less than 60 dB, +3.0 dB or more if ambient noise level without project is 60-65 dB, +1.5 dB or more if ambient noise level without project is greater than 65 dB. (Draft EIR at 14-7.)
The Draft EIR states that the noise level as a result of project traffic noise would be significant, and noise from project operations and project construction noise would be potentially significant.

Mitigation measures include the use of “quiet pavement,” “acoustical analysis,” and certain limits on construction equipment use and type. However, the Draft EIR’s analysis of noise impacts generally contains insufficient quantifiable data and analysis that would allow the public and lead agency to understand whether noise and/or vibration generated from either construction or operation of the proposed Project, including in combination with all past, present, and reasonably foreseeable future projects, would cause specific significant impacts on the District’s educational programs at the existing School Sites.

Noise impacts could disrupt classes, prevent students from being able to be outside due to overwhelming outside noise that would affect teachers’ abilities to monitor and direct students because they cannot be heard. These impacts are particularly concerning given the current uses at the affected school sites, which house several specialized programs for students with unique learning needs, including the Leaps and Bounds program and the A2S program previously referenced. These students may be especially sensitive to environmental stressors such as air pollution and noise.

Because the Draft EIR did not include sufficient analysis related to the generation of noise and vibration impacts on the School Sites, the Draft EIR fails to serve its informational purpose. iv. Population and Housing
The District anticipates that this Project will generate a significant increase in new students, and specifically requested that the Draft EIR analyze:

1. Historical, current, and future population projections for the District. 9L
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2. The impacts of population growth within the District on the District’s ability to provide its educational program.

Population growth or shrinkage is a primary consideration in determining the impact that development may have on a school district, as a booming population can directly impact the District and its provision of educational services, largely because of resulting school overcrowding, while a district with declining enrollment may depend on new development to avoid school closure or program cuts. Overcrowding can constitute a significant impact within the meaning of the CEQA. (See, Cal. Code Regs., tit.14, §§ 15064(e).) This is particularly true where the overcrowding results in unsafe conditions, decreased quality of education, the need for new bus routes, and a need for new school construction. (See, Chawanakee, supra, 196 Cal.App.4th 1016.)
The foregoing categories of information are critical for determining the extent of both physical and fiscal impacts on the District caused by increased population growth. As discussed above, California school districts are dependent on developer fees authorized by the provisions of Government Code sections 65995, et seq., and Education Code sections 17620, et seq., for financing new school facilities and maintenance of existing facilities. The developer fees mandated by section 65995 provide the District the bulk of its local share of financing for facilities needs related to development. The adequacy of the statutory development fees to offset the impact of new development on local school districts can be determined only if the types of housing and average square footage can be taken into consideration. For instance, larger homes often generate approximately the same number of students as smaller homes. At the same time, however, a larger home will generate a greater statutory development fee, better providing for facilities to house the student being generated. It is for these reasons that the Government Code now requires a school district to seek – and presumably to receive – such square footage information from local planning departments. (Gov. Code § 65995.5(c)(3).) While funding considerations present fiscal issues, they translate directly into physical, environmental impacts, in that inadequate funding for new school construction can result in overcrowding of existing facilities. Furthermore, fiscal and social considerations are relevant to an EIR, particularly when they either contribute to or result from physical impacts. (Pub. Res.

Code § 21001, subd. (g); Cal. Code Regs., tit.14, §§ 15021, subd. (b), 15131, subds. (a)-(c), 15142 & 15382.)
Phasing of development is also a crucial consideration in determining the extent of impact on schools. Timing of development determines when new students are expected to be generated, and it therefore is an important consideration, particularly when considering the cumulative impact of a project in conjunction with other approved or pending development.

The District requests that the Draft EIR be modified to include or further explore the above categories of information so that the lead agency, District, and the public may adequately understand the direct and indirect impacts of the Project on the District. (CEQA Guidelines § 15126.2, subd. (a) [requires consideration of indirect impacts].) IV. SB 50 does not absolve lead agencies of their responsibility to ensure General Plan consistency.
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In Endangered Habitats League v. County of Orange (2005) 131 Cal.App.4th 777, the Court held that project approvals and findings must be consistent with the lead agency’s general plan, and that the EIR for such a project must provide sufficient information for the lead agency to make an informed decision regarding such consistency. A project is consistent with the general plan if it will further the objectives and policies of the general plan and not obstruct their attainment. (See Endangered Habitats League, supra, 131 Cal.App.4th 777, 782, quoting Corona-Norco Unified School District v. City of Corona (1993) 17 Cal.App.4th 985, 994.) Fostering quality education should be a priority to the City. The City’s General Plan includes goals to support “strategies to enable safer access to schools,” and “to minimize safety problems by providing adequate off-street parking and areas for student pick-up and drop-off.” (General Plan at 6.A.8 and 6.A.9.)
As discussed at length above, substantial evidence in the record establishes a significant possibility that the Project, in conjunction with all other projects being considered or approved in Ceres, by generating thousands of new residents and vehicles to the area within a few years, will have a negative impact on students, education, and educational facilities. These impacts, which were not adequately analyzed in the Draft EIR, will directly impede the fulfillment of the above General Plan policies and goals. As demonstrated in California case law, the mere payment of developer fees will not adequately mitigate all impacts of development related to the District’s schools. Thus, approval of the Project without adopting any feasible measures to address the negative impacts on schools would be contrary to the City’s General Plan.

V. The proposed mitigation measures and Project alternatives are inadequate to reduce the impacts related to schools to a less than significant level.

Based on the deficiencies of the Draft EIR described above, the Draft EIR’s conclusion that payment of school impact fees will mitigate school impacts to a less than significant level is inaccurate. Since the Draft EIR is lacking in detailed discussion and analysis of existing and projected Project conditions, taking into account both the impact on school facilities and the impacts related to schools, the City cannot reach the conclusion that developer fees are adequate to mitigate the Project’s school impacts because all impacts have not been evaluated.

Furthermore, the Draft EIR’s conclusion that SB 50 limits the City’s ability to prescribe other types of school mitigation for the Project is unsupported by law. Rather, under the Government Code, the City has a duty to coordinate with the District to provide effective school site planning.

The City should consider Project alternatives and/or alternative mitigation measures, such as those proposed below, to fulfill that duty.

A. The Legislature Intended Coordinated Planning for School Sites Government Code sections 65352 and 65352.2 (all subsequent code sections refer to the Government Code unless otherwise specified) require local cities and counties to coordinate planning of school facilities with school districts. The Legislature confirmed that the parties are meant to coordinate “[o]ptions for the siting of new schools and whether or not the local city or counties existing land use element appropriately reflects the demand for public school facilities, and ensures that new planned development reserves location for public schools in the most appropriate locations.”
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The Legislature recognized that new planned development should take into consideration and even “reserve” where schools would be located to serve the development because schools are as integral a part of planning for new development as is any other public service, such as fire, police, water and sewer. As it relates to the Project, the intent behind sections 65350, et seq., supports the District’s position that the City must analyze whether the District’s current facilities are adequate to accommodate and serve both its existing population and the new development, particularly in light of the Project impacts and cumulative factors addressed in this letter. The City can help the District provide adequate facilities resulting from any impacts of the Project, which are not addressed by developer fees, by requiring alternative mitigation measures to assure that there are adequate school facilities available to accommodate the District’s needs, that the impacts related to schools are sufficiently mitigated, and that impacts of the future school construction that will need to take place to accommodate students from the Project are addressed.

B. Alternative Mitigation Measures
District demands consideration of the following alternative mitigation measures to address impacts related to schools, each of which begin to address the actual school related impacts discussed above.
i. Land Dedication
One possible mitigation method, which was not addressed in the Draft EIR, would be for the City to consider adopting findings requiring any developer building as part of the development allowed by the Project to dedicate land and/or funding pursuant to Government Code sections 65970, et seq., which permit the City to require a developer to dedicate land to a school district.

Section 65974 specifically states that “for the purpose of establishing an interim method of providing classroom facilities where overcrowded conditions exist, . . . a city, county, or city and county may, by ordinance, require the dedication of land, the payment of fees in lieu thereof, or a combination of both, for classroom and related facilities for elementary or high schools as a condition to the approval of a residential development.” Nothing in SB 50/Government Code section 65996 precludes this approach. Land dedication is a permissible mitigation measure under Government Code section 65995, et seq. Section 65995(a) specifically states that “[e]xcept for a fee, charge, dedication, or other requirement authorized under Section 17620 of the Education Code, or pursuant to Chapter 4.7 (commencing with Section 65970), a fee, charge, dedication or other requirement for the construction or reconstruction of school facilities may not be levied. . . .” (Emphasis added.) Section 65995 expressly excludes Chapter 4.7, inclusive of section 65974, from this limitation, thus permitting a city to address conditions of overcrowding in school facilities or inadequately sized school sites by requiring, for example, the dedication of land.

A land dedication requirement would be good public planning benefiting all residents of the community, including future residents of the Project. Under Government Code sections 65352 and 65352.2, the City has a duty to help plan for adequate services to its residents by ensuring that future sites are set aside for schools. Failure to do so leads to inadequate services, future controversies, and the potential need for a school district to exercise its rights under eminent domain, displacing existing residents. Therefore, mitigation for the impacts stemming from the Project that are not considered in the Draft EIR are and should be made available. Additionally, identifying as part of the Project where the future schools will be located – schools that the Draft 9P
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EIR admits will be needed – allows for appropriate analysis of topics such as traffic and pedestrian safety for Project students.
ii. Phasing
Another method by which the City should work cooperatively with the District within all legal constraints to ensure adequate school facilities with regard to new development allowed by the Project, and which therefore can serve as an appropriate mitigation measure, is the requirement that all future development be phased. It appears that this Project will be constructed in phases, and future projects within the City should be required to follow suit. Timing development so as to balance the availability of school facilities with new development can significantly aid the District in its attempt to provide for the additional students who will be generated as a result of the Project and development following approval of the Project. Such phasing is not a denial of new development on the basis of insufficient school facilities in contravention to SB 50; it is instead appropriate planning to offset the impacts of new development.

Conclusion
It is the District’s position that the Draft EIR is incomplete and does not adequately analyze the Project’s potential impacts related to schools, or mitigation measures that would lessen these impacts. The safety of students is paramount to the District, and these safety concerns are not adequately addressed in the Draft EIR as currently constituted. Changes must be made to preserve the safety of the students and allow them to enjoy productive time at school, free from excessive traffic, noise, and pollution.

Therefore, the District requests that the Draft EIR be updated and recirculated. (See CEQA Guidelines § 15162(a); Mountain Lion Coalition v. Fish & Game Com. (1989) 214 Cal.App.3d 1043; Laurel Heights Improvement Assn. v. Regents of University of California (1993) 6 Cal.App.4th 1112, 1130, as modified on denial of reh'g (Feb. 24, 1994).) Further, the District requests that the City and Developer meaningfully involve the District in that process, so as to promote a positive educational environment for existing and incoming residents of Ceres.

Thank you for your consideration of the District’s comments.

Sincerely,

LOZANO SMITH
Harold M. Freiman
cc: Dr. Amy Peterson, Superintendent, Ceres Unified School District Dr. Kristi Britton, Assistant Superintendent, Business Services, Ceres Unified School District
4937-6017-0588, v. 6
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Copper Trails Specific Plan and Annexation Project, Final EIR 3-85 March 2026 RESPONSES TO COMMENT FROM CERES UNIFIED SCHOOL DISTRICT Response 9A: This comment introduces the commenter’s main assertions regarding the EIR and lists subjects to be addressed in more detail later in the comment letter:

Non-compliance with CEQA
District not adequately consulted during the EIR process EIR does not include sufficient information to analyze impacts on schools and related to schools
Cumulative impacts have potential for profound negative effects on the District student population and residents of the project area Response 9B: The comment expresses the hope that the District and City can work cooperatively to address issues related to the project and other development within Ceres that is causing school related issues. The City welcomes the opportunity to work with the District on community problems of mutual concern going forward. However, as discussed in Response 9C, the District’s concerns are only just now being brought to the attention of the City and do not recognize the City’s efforts to conform with the applicable EIR noticing requirements; 24 months have passed since the City brought the project to the District’s in the Notice of Preparation, which was published for the benefit of all interested persons and agencies, including the District, in September of 2023.

Response 9C: The comment states without supporting evidence that the City failed to meet and confer with the District during the environmental review process as required by CEQA. The City did specifically request the District’s input into the project in the Notice of Preparation but received no indication of interest or concern from the District; see the summary of NOP comments in Chapter 1.0 of the Draft EIR. The City’s specific obligations to other local agencies are met by advertising the City’s intent to prepare, make available for comment and consider adoption of the EIR by publishing a Notice of Preparation, Notice of Availability of the EIR and provision of its responses to comments submitted by agencies 10 days ahead of EIR certification. The District has been advised of the project using all of these means. The District does not identify any other specific means of communication required by CEQA that the City failed to utilize.

Having the same authority and power as the City or any other California local agency, the District has not made any known effort to engage with the City in joint planning activities in relating to the Copper Trails project. Despite the City’s CEQA notifications, the EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-86 March 2026 District has not until now communicated its concerns, eight months after the close of the Draft EIR review period.

Response 9D: Citing general CEQA requirements for inclusion of Environmental Setting information, which is well understood by the City and the EIR preparer, the District criticizes the EIR for failing to provide especially-detailed information on the existing school facilities within the CTSP area, not just location, size, enrollment and capacity, which is the norm for CEQA analysis, but an in-depth description of the specialized programs and related facilities at the Hanline ES facility.

This information, now being provided by the District, was not previously identified. See Response 9C.

The comment goes on to suggest that the EIR should account for the environmental setting information in each of the subject areas addressed in the EIR with respect to schools and student populations, such as paths of vehicular and pedestrian travel. This is beyond the scope of the EIR, which was addressed to a specific plan and annexation project and their environmental effects on the specific plan area and surroundings. The specific plan did not encompass any specific development projects and therefore addressed potential environmental effects at a programmatic level appropriate to the generalized definition of proposed land uses described in the specific plan. The level of detail the District indicates that the EIR might have been obligated to address would be more appropriate to the environmental review of subsequent development project applications under consideration by the City.

The District criticizes the EIR for not addressing the potential effects of having to relocate Hanline ES facilities and programs due to “an influx of new students” and how the affected student body would be impacted by having to deal with changed school locations, such as changes to class locations and bus schedules. These potential impacts are speculative; the comment identifies no chain of cause and effect that would lead to overcrowding at Hanline ES and displacement of existing general or special education programs. An EIR is not required to analyze speculative impacts, in this case based on potential student growth of unspecified proportions that may or may not occur during an unspecified timeframe, when the available information indicates that existing District has sufficient capacity to accommodate additional growth for the time being.

A more important point is that it is the District’s responsibility as a California local agency to account for potential growth, opening, closing and expansion of schools and how best to deliver the services, programs and the like that the Board of Education determines is in the EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-87 March 2026 best interests of the students and community. The comment letter implies that the District would be at the mercy of new development and powerless to prepare for community change when in fact it is their obligation to do so.

Response 9E: The comment correctly notes that the project could be expected to result in increases in student generation as new residential and other land uses are accommodated within the specific plan area but the EIR did not identify how and where potential student growth should be accommodated. Neither the City nor the developer has expertise in these matters, and the District has not yet, in response to the Notice of Preparation, or in these comments on the Draft EIR, provided any guidance on this matter from which the City’s EIR could draw such conclusions. In light of planned development in Copper Trails and the City of Ceres, and the potential for schools impact foreseen by the District, it should update its School Facility Needs Analysis and share its findings with the City.

The comment objects to the EIR’s conclusion that the City’s school analysis finds that potential impacts on schools would be less than significant as a result of payment of school impact fees, but neglects to mention the legal authority for this determination, which originates in the California Code:
“As set forth in California Government Code Section
65996(b), the payment of school impact fees is deemed to provide full and complete school facilities mitigation under CEQA.” (EIR p 15-9)
Here and in the first paragraph of the letter, the commenter emphasizes that the CTSP in combination with “numerous other projects” pending before the City have the potential to have a “profound negative effect on the District’s students, their families and persons residing in and near the CTSP area.” This statement is unsupported by submitted facts.

The commenter provides no listing of the pending projects by name, number or location or describe how the cumulative effects of these projects could lead to such profound effects. The comment goes on to say it will discuss the effects that substantial ongoing development is already having on the City but provides no specific references to cumulative impacts; each time this assertion is repeated, no supporting evidence is provided. The EIR included an analysis of potential cumulative impacts associated with the project in the manner prescribed by CEQA in each of the subject areas addressed in the EIR in a Chapter (18.0) devoted entirely to this subject, including cumulative impacts on public services. The comment did not provide any comment on the EIR’s analysis of this subject.

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Copper Trails Specific Plan and Annexation Project, Final EIR 3-88 March 2026 Response 9F: This comment describes the inadequacy of the EIR’s analysis of “school-related” impacts but instead is focused on the fiscal effects of new development on schools, faulting the EIR for not estimating the fiscal effects of the project on schools. Despite the State Legislature’s declaration in Government Code Section 65996(b), that the “payment of school impact fees is deemed to provide full and complete school facilities mitigation under CEQA,” the commenter argues the inadequacy of School Impact Fees. Further response to these comments involve legal arguments, which are beyond the scope of CEQA to address. In fact, fiscal and other economic and social effects are specifically excluded as proper subjects for CEQA analysis:

The legal citations in the comment letter regarding the justification for consideration of fiscal effects on schools refer to a Chawanakee case which defines exceptions for the adequacy of impact fee where schools are subject to specific overcrowding conditions.

The evidence included in the EIR suggests that the District facilities are not presently overcrowded. Whether or not overcrowding conditions exist in the future will be the responsibility of the District and apparently has not been made to date. In fact the Ceres Courier reported in March of this year that “enrollment has been steadily declining since the 2019- 20 school year.

Each of the potential impacts listed by the District as potentially being caused by new development, including traffic, noise, biology, air quality, pedestrian safety are subject that are addressed in the EIR in separate chapters devoted to each subject.

Response 9G: The commenter states that the EIR fails to identify the range of potential school safety concerns such as congestion at student dropoff and pickup times, pedestrian and bicycle routes. This analysis is far beyond the level of detail that is required or that can reasonably be provided in a specific plan EIR for generalized land use plans that do not include specific development proposals. The CTSP’s potential changes in land use, traffic and other environmental subject areas are not addressed at an individual project level. The types of information the District suggests that the EIR contain might appropriately be included in District planning activities that could be undertaken by the District and shared with the City, such as a “Safe Routes to School” engineering study or an evaluation of options for management of dropoff/pickup safety concerns at individual schools. The City acknowledges these as valid District concerns requiring further study, EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-89 March 2026 which could be addressed in conjunction with future development projects as they are processed under the CTSP.

Response 9H: The project’s GHG and air quality impacts are relatively uniform with respect to the general population, which includes the student population. Students as a group would not be subject to any greater criteria pollutant or hazardous air pollutant risk than any other group of residents. The information included in the EIR would enable the District to discern potential air quality related impacts on the student population just as much as it would be for the general population of the City and CTSP area.

The City is not aware of any noise information in the EIR that would suggest that any of the existing CUSD facilities would be subject to significant noise impacts.

The comment related to population and housing suggests that the EIR provide the District with forecasts of future housing development and increases in student population. Provided that future growth remains within the projections of the Ceres General Plan, there is no potentially significant effect to be documented. Again, this is a subject that is the responsibility of the District rather than the City or its EIR.

Response 9I: The greenhouse gas emissions associated with buildout of the CTSP were analyzed for the project as a whole and included all vehiclerelated emissions that may be associated with planned residential and commercial development of the specific plan area, including trips originating within the specific plan area and trips oriented to more distant destinations. The California Emissions Estimator Model, CalEEMod, estimates emissions associated with vehicular trips as well as emissions associated with area sources, such as emissions generated from electrical generation, use of garden tools and other sources.

Vehicle trips are likewise considered comprehensively, and include the range of home-work, home-shopping and other trips generated by the full range of land uses addressed in the specific plan, including trips to and from schools. Chapter 10.0 of the DEIR was devoted to GHG emissions as well as the multitude of policies and regulations applicable to reducing GHG emissions and global climate change.

Response 9J: The comment criticizes the air quality impact analysis of the EIR for lack of specific discussion of potential air quality effects on schools, the CUSD, students and staff, specifically the potential for air quality to disrupt classes and prevent outdoor use during construction. These potential impacts are analyzed in considerable detail in Draft EIR Chapter 6.0 Air Quality, which finds potential impacts to be less than significant; these findings are applicable to the project area as a whole EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-90 March 2026 and the existing and future general population, including students, school and the District. The standards against which potential impacts are evaluated are public health-based and applicable to the general population with thoughtful margins of safety for populations that may have acute sensitivity to high air pollution levels, such as children and seniors.

The DEIR analysis considers potential construction air quality impacts on nearby land uses, which would include schools. The applicable dust and construction emission controls imposed by the SJVAPCD include standard dust controls, including watering, speed controls, track-out prevention and covering of haul loads and storage piles. In addition, the SJVAPCD requires a construction permit that imposes these requirements and provides points of contact for citizen complaints.

It is important that the air quality analysis finds that potential impacts would be less than significant at buildout of the project; that is, the project would not cause exceedance of the various health-based standards adopted by the SJVAPCD, and there is no evidence provided by the commenter that potential impacts on CUSD students or staff would be any more significant than those described for the general population. The predicted less-than-significant impact level is assigned without consideration of the range of in-place air pollution-reducing regulations and other mitigation measures, which, as detailed in Chapter 6.0, would result in substantial reductions in the project’s predicted air pollution effects, which would without mitigation already be less-than-significant.

There is no known standard or CEQA requirement that would suggest that the potential air quality impacts of the project on schools, students and staff should be or need to be analyzed separately from potential impacts on the general population. The potential air quality impacts described in the DEIR are clearly applicable to the schools-related populations of concern to the commenter.

Response 9K: The DEIR included a detailed noise analysis prepared by a qualified acoustical consultant, whose technical study was included in the DEIR as Appendix F. The technical report details the quantitative data and analysis considered in the DEIR, including the applicable significance thresholds. The report and DEIR Chapter 14.0 discuss the potential impacts of project-related traffic, new land uses and related construction on sensitive receptors, including schools. The analysis is sufficient with respect to the general population of the project as well as to school students and staff.

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Copper Trails Specific Plan and Annexation Project, Final EIR 3-91 March 2026 The commenter provides no evidence other than information included in the DEIR that noise generated by the project would result in significant impacts on the District’s educational programs or result in overwhelming noise that would affect teachers’ ability to monitor and direct students because they cannot be heard.

Response 9L: This comment is related to population within the District and associated school needs, and the project’s effects on population growth or shrinkage. The potential population effects of the project were addressed together with land use and housing concerns in EIR Chapter

13.0. The source of population growth information is the Ceres General Plan.

The analysis requested by the District is directly-related to the District’s planning function and only indirectly related to the project.

The City is willing and available to engage with the District in reaching a better understanding of potential population growth and school needs in Ceres.

Response 9M: As repeated in several of the above responses, the District has not provided the City with any evidence of the inconsistency of the project with the Ceres General Plan, nor has the District provided any evidence that the project will result in a negative impact on students, education and educational facilities.

Response 9N: See previous responses regarding potential impacts on schools. See also the following Response 9O regarding alternative mitigation measures.

Response 9O: This is a misrepresentation of the California Government Code. This code section requires that a school district be notified when a City is preparing or amending the General Plan, which occurred with this application. This code section also requires consultation with the school district if a proposed project could affect school facilities, giving them an opportunity to provide input. This consultation occurred early on in the process of this project as noted in several email exchanges between District Staff and the applicant. Further, the onus to identify and purchase property for a future school is the responsibility of the school district, not the City, as the City does not a developer and does not purchase property or provide property for school construction.

Response 9P: The comment letter makes an effort to assign responsibility to the City and its EIR for the District’s duties. The District suggests alternative mitigation that might be applicable if and where a state of school overcrowding has been established; this, however, has not occurred.

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-92 March 2026 Response 9Q: Response Q: There is no prescribed phasing requirement for new residential development under SB 50. There is no realistic scenario where all of the units in the Copper Trails development at once given the multiple property owners in the Plan area. The project applicant does not own all of the properties within the Plan area and has no control over when those parcels will and won't develop. Given the difficulty in determining when property owners are interested in building units and where, there is no logical way for the City to restrict the number of units that can be developed at once. Units can only develop as infrastructure is constructed, and infrastructure can only be constructed as development occurs. As such, there will be natural phasing of this project which is sufficient to address this concern.

Response 9R: The commenter’s more specific comments related to traffic, noise and pollution are each addressed in the foregoing responses. Although the DEIR’s analyses are not specifically addressed to direct impacts on schools, they are adequately described with respect to the community in general, consistent with the requirements of CEQA and the general nature of the proposed project. See Responses 9G, 9J and 9K.

The commenter raises a number of potential environmental issues and shortfalls of the EIR with reference to general content requirements of CEQA and the CEQA Guidelines. Again, these are general references to EIR contents and requirements, unlike CEQA’s more specific requirements, for example, with respect to GHGs, cultural resources and other matters addressed in CEQA Guidelines at a higher level of detail. The commenter’s references to CEQA do not set forth any specific EIR guidelines or standards with which the DEIR fails to conform. To the best of the City’s knowledge, the EIR was drafted to meet all applicable CEQA requirements.

The commenter requests that the EIR be updated to reflect the many concerns identified in the District’s letter and recirculated. The comments do not identify any of the recirculation criteria Listed in CEQA Guidelines 15088.5 nor does the City believe that any of these requirements are triggered by the CTSP EIR.

Significant new information includes, for example, a disclosure that:
(1) a new significant environmental impact would result from the project or a new mitigation measure; (2) a substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted; (3) a feasible alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the project's significant impacts but the project's proponents decline to adopt it; or (4) the draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 3-93 March 2026 review and comment were precluded. CEQA notes that this guideline was “not intend[ed] to promote endless rounds of revision and recirculation of EIR's.” Rather, recirculation is
an exception, rather than the general rule.”
New information added to an EIR is not ‘significant’ unless ‘the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project's proponents have declined to implement.’
Recirculation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an otherwise
adequate EIR. An agency’s decision not to recirculate the draft EIR is entitled to substantial deference; the petitioner bears the burden of proof to show no substantial evidence supports the agency’s decision.

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 4-1 March 2026

4.0 DRAFT EIR ERRATA
This section of the Final EIR identifies corrections and documents the addition of new or revised information that is added to the Copper Trails EIR after completion of the public review of the DEIR. Changes to the EIR typically reflect the new or updated information that has become available since publication of the EIR or minor technical changes to the project that do not entail a significant impact on the environment. The changes to the DEIR described in this section are changes noted in the Chapter 3.0 Responses to Comments and consisting largely of minor modifications or clarifications and typically do not involve “significant new information,” or involve “new or more severe environmental effects than were discussed in the Draft EIR;” such changes, if present, could require recirculation of the EIR pursuant to CEQA Guidelines Section 15088.5.

Revisions to the Draft EIR are shown in underline and/or strikeout as appropriate.

Among other changes to the DEIR noted in Chapters 3.0 and 4.0 of this Final EIR are updates to many of the DEIR figures, especially those describing the Project in DEIR Chapter 3.0. The updated figures reflect relatively minor changes to the CTSP; none of these updates involve any substantial changes to the location and amount of new development that could result from approval of the CTSP, which is the subject of the EIR’s environmental impact analysis. The updated figures, listed below, are shown in FEIR Appendix B.
3-1 Proposed Land Use Plan
3-2 Transportation Key Map
3-3 Street Sections
3-4 Transit and Pedestrian Circulation
3-5 Proposed Potable Water System
3-6 Proposed Sanitary Sewer System
3-7 Proposed Non-Potable Water System
3-8 Proposed Storm Drainage System
ERRATA TO DRAFT EIR CHAPTER 1.0 – INTRODUCTION
The last paragraph on page 1-4 of the Draft EIR is modified to include reference to the SWRCB Division of Drinking Water, as follows:

Other potential Responsible Agencies may include the State Water Resources Control Board, Division of Drinking Water, Stockton District, California Department of Fish and Wildlife (CDFW), the Central Valley Flood Protection Board (CVFPB), and the Central Valley Regional Water Quality Control Board (RWQCB). These, and perhaps other agencies, may not be directly involved in review and approval of the CTSP but may be involved in permit review for individual development projects if and when the agencies’ regulatory EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 4-2 March 2026 requirements are triggered. Issues pertaining to these and other agencies are likewise addressed in this EIR.

ERRATA TO DRAFT EIR CHAPTER 2.0 – SUMMARY
In Summary Table 2-1 of the DEIR, the listing of Hazardous Materials impacts from DEIR Chapter 11.0 was in error. In the Summary Table, two impacts were shown as HAZ-2; the second of these is hereby renumbered HAZ-3 and is shown as such in the FEIR Summary Table. The subsequently-listed hazards impacts, which were labeled HAZ-3 through HAZ-8 in the DEIR Summary Table are hereby renumbered as HAZ-4 through HAZ-9 and are shown as such in the FEIR Summary Table.

In Summary Table 2-1 of the DEIR, the listing of two Biological Resource impacts, BIO4 and BIO-5, had incorrect titles. Impacts BIO-4 and BIO-5 are retitled as follows:

BIO-4 Migration Corridors and Nursery Sites
BIO-5 Local Policies and Ordinances
and are shown as such in the FEIR Summary Table.

ERRATA TO DRAFT EIR CHAPTER 3.0 – PROJECT DESCRIPTION
The following line item is added to Table 3-3 Required Permits and Approvals on page 3- 15 of the Draft EIR:

State Water Resource Control Board, Division. of Drinking Water, Stockton District
Approve water supply permit amendment that may be required to serve new development within the CTSP area.

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 4-3 March 2026 ERRATA TO DRAFT EIR CHAPTER 5.0 – AGRICULTURAL RESOURCES The discussion of Williamson Act contract cancellation is modified to include the following statement:

The process for termination of qualifying contracts upon annexation to the City is defined in the California Government Code at §51243.5(e) Draft EIR Mitigation Measure AG-1 is revised to delete the word “Prime” before the mention of “Farmland.”
The Draft EIR mitigation measure numbered AG-1 related to Williamson Act concerns is hereby re-numbered as AG-2
The following paragraph on page 5-8 is modified to read as shown below:

As previously discussed, there are five parcels within the project site that are under existing Williamson Act contracts. Planned urban development pursuant to the CTSP would conflict with the purpose of the Williamson Act contracts.

Williamson Act contracts in place at the time of annexation would remain until the City determines whether it would succeed to the County’s interest in the contracts or not. Prior to development, existing contracts Williamson Act contracts would either need to expire by non-renewal or would need to be canceled by the City subject to the cancellation process and related requirements as described in Government Code 51242.5, including consistency with immediate cancellation criteria, prior to development. This need would be defined and met during City processing of affected development applications. Potential inconsistency with Williamson Act contracts is considered a potentially significant environmental effect.

ERRATA TO DRAFT EIR CHAPTER 6.0 – AIR QUALITY
The DEIR found Impact AIR-1 to be less than significant, but this conclusion was not shown in the Summary Table 2-1. This error is corrected in the FEIR Summary Table.

The following information should be added prior to the last paragraph describing Impact AIR-2, as follows:

Although the SJVAPCD rules and regulations are adopted and already applicable to new development projects throughout the San Joaquin Valley, the following requirements should be included in Conditions of Approval or Mitigation Measures for future development within the CTSP project area.

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 4-4 March 2026 New development projects that exceed the significance thresholds defined in the SJVAPCD GAMAQI manual should be required, through Conditions of Approval or Mitigation Measures, to demonstrate conformance with applicable SJVAPCD rules and regulations, notably Rule 9510 the Indirect Source Rule.

The SJVAPCD notes that restaurant projects involving large under-fired broilers should be assessed for the significance of their potential particulate emissions. No such restaurant facilities are proposed by the CTSP.

ERRATA TO DRAFT EIR CHAPTER 7.0 – BIOLOGICAL RESOURCES
In response to comments from California Department of Fish and Wildlife and recognizing the limited potential for occurrence of burrowing owl and Crotch’s bumble bee in the project area, the following mitigation measures are hereby modified.

Mitigation Measure BIO-1 is hereby modified to read as follows:

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 hawk or burrowing owl nests are found to be present, a no-disturbance buffer consistent with CDFW conservation guidance for these species 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 addition) 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 bumble bee nesting, the biologist shall recommend appropriate mitigation which shall be required of the project.

Mitigation Measure BIO-3 is hereby revised as follows:

BIO-3: If construction of a development project is to commence during the general avian nesting season (March February 1 through September 15July 31), a pre-construction survey for all species of nesting birds shall be conducted by a qualified biologist. If active nests are found, work in the vicinity of the nests shall be delayed until the young have fledged as determined by the biologist. No survey is required if construction is to occur outside the general avian nesting season.

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 4-5 March 2026 ERRATA TO DRAFT EIR CHAPTER 12.0 – HYDROLOGY AND WATER

QUALITY
The first sentence in the Groundwater section on page 12-1 is modified as follows:

The City relies on its recently-completed surface water supply in conjunction with groundwater wells for its potable water supply. Additional discussion of water supply is provided in Chapter 17.0, Utilities and Energy).

Additional information regarding water supply is added following the paragraph above.

The City of Ceres (City) has historically relied entirely on groundwater from the Turlock Groundwater Subbasin as its primary drinking water source. Serving a population of approximately 48,000 residents, the current water supply is provided by 13 active groundwater wells and two storage tanks. In 2022 the City’s water division pumped more than 2 billion gallons of drinking water annually for its residential and commercial users, which averages 5.9 million gallons of water daily.

Groundwater is a limited resource that will not meet future demands and the State’s Sustainable Groundwater Management Act (SGMA) may mean that cities will have to reduce dependence on groundwater. To build a more resilient water supply, the City of Ceres has diversified its water portfolio by partnering in the Stanislaus Regional Water Authority’s (SRWA) Regional Surface Water Supply Project to build a new water treatment plant and bring a new surface water supply from the Tuolumne River to the City of Ceres. This project was brought online in 2023.

ERRATA TO DRAFT EIR CHAPTER 16.0 – TRANSPORTATION
The second paragraph on page 16-15 related to office VMT impacts is hereby modified as follows:

The potential for office development, and potential magnitude of Office VMT generation, in the CTSP area is relatively small. Office projects are not among the types of development anticipated by the CTSP and therefore are not listed in Table 3-2 of EIR Chapter 3.0 Project Description. In that “office commercial: is an allowable use within Ceres Administrative Professional and Commercial zoning districts, however, office uses could be accommodated within the CTSP area as new development projects are initiated in the area. Further quantification of potential Office VMT would, at this time, be speculative based on the available EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation Project, Final EIR 4-6 March 2026 information regarding future office development as a result, office VMT is not considered a significant transportation effect of the CTSP project under CEQA.

The final paragraph and conclusions regarding Impact TRANS-3 is modified as follows:

The various examples of other VMT reduction measures that could be assigned to CTSP development are shown in Table 6.15 below. Inclusion of these measures in the CTSP would provide additional potential to reduce the significant VMT impacts of the project. It is not known, however, which of the listed measures would be feasible to implement with future office projects, should they occur, while other VMT reduction measures not listed in Table 6.15 might also be implemented. Given the uncertainty at this time regarding which VMT measures may be implemented with respect to future CTSP development, and their efficacy, it is concluded that VMT reductions cannot be reliably quantified at this time; as a result, the project would be potentially inconsistent with the objectives of CEQA Guidelines Section 15064(b), and the project’s VMT impacts would remain potentially significant and unavoidable.

Level of Significance: Potentially significant (Office VMT) Mitigation Measures: No reliable or quantifiable mitigation is available TRANS-1: The City shall require applicants for residential projects to provide a professional report identifying available VMT mitigation measures that could be relied on to increase the project’s VMT contribution to 15% below the existing citywide residential VMT and to incorporate such measures into the project conditions of approval. The effectiveness of such measures cannot be determined at this time; therefore the potential impact will remain significant and unavoidable.

Level of Significance: Significant and unavoidable
EXHIBIT A ITEM 13
APPENDIX A
DRAFT EIR DISTRIBUTION LIST AND LEGAL NOTICES
EXHIBIT A ITEM 13
December 12, 2024
To: Responsible Agencies, Trustee Agencies, Interested Parties and Organizations Subject: Notice of Availability of the Copper Trails Environmental Impact Report Lead Agency: City of Ceres
Community Development Department
2220 Magnolia Street
Ceres, CA 95307
Applicant: Nav Athwal
c/o NorthStar Engineering Group, Inc.

Modesto, CA 95354
The City of Ceres Community Development Department has completed, independently reviewed, and analyzed the Draft Environmental Impact Report (DEIR) SCH #2023090637 for the Copper Trails Specific Plan and Annexation project. The City of Ceres is the Lead Agency for this project under the California Environmental Quality Act (CEQA). The annexation project includes a total of 680.7 acres in 244 existing parcels; the annexation area is comprised of the 534.6-acre Copper Trails Specific Plan (CTSP) area and an adjacent 146.1- acre area lying between the CTSP and the existing City of Ceres boundary. The Draft EIR discusses the range of environmental concerns listed in the latest CEQA Environmental Checklist and identifies potentially significant environmental effects in the following issue areas: Agricultural Resources, Air Quality, Biological Resources, Cultural Resources, Geology and Soils, Hazards and Hazardous Materials, Hydrology, Noise, Transportation and Utilities and Energy.

Copies of the Draft EIR are available for public review on the City’s website here:
https://www.ci.ceres.ca.us/1798/Copper-Trails-Specific-Plan The City will accept agency comments on the Draft EIR during a 45-day review period that will begin on December 12, 2024 and end on January 27, 2025. Comments may be submitted by mail 2220 Magnolia Street, Ceres, CA 95307 or by email to [email protected].

Community Development Department
Planning Division
2220 Magnolia Street
Ceres, CA 95307
209-538-5774
Fax 209-538-5675
EXHIBIT A ITEM 13
Image Image
Mall to:

STANISLAUS COUNTY CLERK

CEQA FILING COVER SHEET
50-2024-192
FILED
Name: City of Ceres-CD □
Address: 2220 Magnolia Street
November 6, 2024

DONNA LINDER

STANISLAUS COUNTY
CLERK-Rf.CORDER
By: SignatureSignature
Deputy Clerk
City, state, Zip Ceres, CA 95307

THIS SPACE FOR CLERK'S USE ONLY
Complete and attach this form to each CEQA Notice filed with the County Clerk

TYPE OR PRINT CLEARLY
Project Tltle
Copper Trails Specific Plan and Annexation project
Check Document being Flied:

Unchecked Box Environmental Impact Report (EIR)
Unchecked Box Mitigated Negative Declaration (MND) or Negative Declaration (ND) Unchecked Box Notice of Exemption (NOE)
Checked Box Checked box Image Other (Please fill In type): Notice of Availability FILED IN THE OFFICE OF. T E STANISLAUS
COUNTY Clerk ON 11 2024
Posted 11 6/2024 12 21 2024 Line Removed ..... -_ -. -
Returned to agency on _______ '
DEPUTY Initials
Flllng fees are due at the time a Notice of Determination/Exemption Is flied with our office.For more Information on flllng fees and No Effect Determinations please refer to California Code of Regulations, Title 14, section 753.5.

EXHIBIT A ITEM 13
-

PUBLIC NOTICE OF AVAILABILITY

DRAFT ENVIRONMENTAL IMPACT REPORT
(Pursuant to Public Resources Code Sections 21092 and 21092.3 and Cal. Code·of Regulations Title 14, Section 15087)
The City of Ceres Community Development Department has completed, independently reviewed, and analyzed the Draft Environmental Impact Report (DEIR) SCH #2023090637 for the Copper Trails Specific Plan and Annexation project. The City of Ceres is the Lead Agency for this project under the California Environmental Quality Act (CEQA). The annexation project includes a total of 680.7 acres in 244 existing parcels; the annexation area is comprised of the 534.6-acre Copper Trails Specific Plan (CTSP) area and an adjacent 146.1- acre area lying between the CTSP and the existing City of Ceres boundary. The Draft EIR discusses the range of environmental concerns listed in the latest CEQA Environmental Checklist and identifies potentially significant environmental effects in the following issue areas: Agricultural Resources, Air Quality, Biological Resources, Cultural Resources, Geology and Soils, Hazards and Hazardous Materials, Hydrology, Noise, Transportation and Utilities and Energy.

Copies of the Draft EIR are available for public review at:

City of Ceres Community Development Department
2220 Magnolia Street
Ceres, CA 95307
and at the City's website:
https://www.cl.ceres.ca. us/1798/Copper-Tralls-Speclfic-Plar.i The City will accept public and agency comments on the Draft EIR during a 45-day review period that will begin on November 5, 2024 and end on December 20, 2024. Comments may be submitted by mail to the address shown below or by email to [email protected]
City of Ceres
Community Development Department
2220 Magnolia Street
Ceres, CA 95307
Attn: Lea Simvoulakis
EXHIBIT A ITEM 13
608.7
95307
AppendirC
Notice of ,Comple,tion & Envi:.ronmentat Document Transmittal Mail to: State Clearingh.ou.-.c, P.O. !Box 3044, Sacramt;liltO, CA 9S8 ]2-3044 (916) 445-0613 For Hand Delivu.v/S,1-ee1 Address: 1400 Te,nth St·reet, SacrarnCJ1to, CA 9S8U S·CH # 202309 063 7 Proj,eet Tilto: . Copper Traiils Seeclfic Plan arid An11elfa1i0fil lead Agency: _a_·ty.,__o.f_C_611' __ es _______________________ _ Mi11h 118 Add~, 222.0 MagnOlla Slreet
Ciiy: Ceres
Contact Perron: lee Simvour-akis,
Pno11e: 209 538 5778
Zip: 95307 Coumy: Slarnslaus
------------iliiiiiiiiililiiiiii----·----------------iiiiii,,iiiiiiiii, _________________________ _ P,oject. Location: Co\J 1y: Staruslaus City/Nearest Comm1.1n1ty: Ceres, c ~ Streecs: State Route 99 / ---------------- Mliklhell Fload -------------------- Zip Code: ___ _ LongJ udc/Lui1udc (d'cgrcc.s-, minulcs am! seconds): .!!__.,, ~• .:!..__~ NI ~ ~• ~• W To1al Acres: -~------ A.ssessor's ParRl No.: Various Sectl:on: 2m3 Twp.: 4$ Range: 9 B:ue: MDBM Wu'hm 2 Miles: Stale Hwy#: _99 Waterways: TIO Irrigation Lalera1 ------------------------------------------ Aiipons: 1 ModestoCily-Oounty Railways: UP Schools: Cen Valley, Hfdahl _____________ , ___________________________ i,.... _______________________ _ Doooment Type:

CEQA- 0 NOP
□ &dyCor.s
0, I cg De<:

D Mil egDoc

11.ocal Action Typ ·:

D General P! n Upda1e
D Oener-al Phm Am:tmdmen
D Gen.eraT Pll.llil Elemen1
0 Comnumity Plan
D illelopment Tw,a:
~csidcnual: Un i(s 2393
'O Draft EIR
D Supph::numt/Subseguem EIR
(Prior SCH o.) _____ _
01:her.
--------------------
Specific Plan
D Master Pl an
D Pl:mn.ed Unit Devclopmen1
01 Si:lc Plan
Ac1es 260.3
NEPA: □ NOi 0th r.
□
0 D
□
Rez:0111e
DEA
□ [),afi EIS
0 FONSI
Pre;1onc
se Pemut
Lam! mvision {Subdivision. etc.)
D Joint Document
D Final Documen1
D 01her: ---------
(i] A1rmexa1ion
□ Redeve lopmen1
□ Coas1al Pemlit
□ Olliler:

D Offioe: Sq.ft. --~ Acres"""""'="""""-
Ac res 107.4
Employees. __ _ 0 Tran.•;poruiti.on. Type---------------------- Commm:in1Sq.ft Empl'0yccs __ _ 0 Mining: Mineral
D lndustnal; Sq.ft. 0 Educauona.l. ---
Acres __ _ Em;ploycc __ . __ □ Power: Type------------ ------------------------ MW,,..... ___ _ D Waste T1ea.1mcn1:Typc MCiD ____ _ ...,.,,..,,..----,,..._-----,,-------,,--------------- [j] R~iona 1: 42 .3 cres !or 1pa1kS aJl(j ope.n space 0 Water Facili1ks:Type ------------ MGD ____ _
D Ha<2, ,dous W stc-:Typc ___________ _
0 01he-1r. ~----------------
--------------~ .... ---------------------------------------------- Projoet I s.u s Disc:uss d in Document:

Ar:-sliu:1i,r;NiiuaJ D Fiscal Rccreaticm/Parks
A~CUilturai Land [ii Flood Ph1inl'Aooding Ill Sch.ool&lllniversiues ![ii Ai,: Qu lny O Fore I LHndfFice H:12a.rd O ScpltC Sys,ti:rnli0 ArchcologicaJ/Hi ·tolilc-.il - Geologic/Seismic O Sewer •Cllpacily ■ Biolo1J;1cal R.csou1ccs Ii) Minerals II) Soil ErosiooJCompactfonfGra.ding D Coast.ii Zeme Noise D Solid Waste
Ora inage/ Absmpuon PopulationlHous111g Balance Toxic/Hazardous D Ba:m,0011c/fobs ll) Public Scrviw~Facilities T1affidCiroula1ion 0 Vcge1a1ion
• Water Quality
Water Supply/Groundwater
□: Wetland!/'Riparian
D Growtb lnduceml!l'lt
Ill an.d Use
[i CumlllaLivc Effec-,s
Other: --------- ------------!!!!!!!!!!'-!ll!!!!!!!!l!!l!!l!!!P ________ !ll!l'J!!o _____ ....,. __ !!!!!!!!!!!!!'!!!!!lll!!!!!!!!P---------------·---!!!!!l'!l""'!!!!!!!!!!!!!!l!"!l!!!!!!!!l!l!!!!!!!!I'- !I P,es,ent Land Use/Zoning/Gtoera! Plan D tignation:

I!f!>~!!~l!!~~!~~~!Y---------------------------------·-----,-·----------· Project D • scrip on: (please use a separate page ff necessary) Coppru T • Sl;ll!Ci'tic Plan (CfSPI awrova and an adUon would rnuu IA •the ?Qlenli;!I d'eYe~nienl. o Dl)()mllim iely 200.3 acres Of' low-. medium-. metJum high-, end higtl-Gens.'lty reslden ill un Is wi~ lhe CTSP area, Tfl!l rotat ttwelliQQ Ul'!lls lhllt woutd be potenllally ~loped Is Z,38,ll ~xim .efy 107,4 IICII!:$ propoHd lo( Aegional Comm&rda' d9W!IO,Pfl181"11. wtlleh Is e11Hmated D , lffll,586 square •fee\ of 110or atea. 1'N CTSP a o pltlp0$8,S aw,oxlfflately 42-3 aQl',es Oi p • Md Of!All sp!roe, ltielutling 51reel,md'$Coll)k, aru:t 3,"4 acres 1'or new publiC u!>U \hat would ba i"I add!liilin to me 74. 1 .i.c~ !l.lnJa(!y ~vied b~ lhe centta 1/a'Jley M g1i School anc!t f.lidahl Eiemenlary School, boih opera1.ed by 1.lie Ceres l1J d Sch<lol ~t®I. Ttie CTSP plMn&d ~111111 aystom 'o'!!'OU!cl ut ,ie and lm,pro~e ~!I rcmds and WSd new roads nd siraets noo prnwje 1for d9velo,plneil11 al new bicyd and pedu,lnan ·1 and 0pff.ll space ~ka,as ta prov.i<le aocffl to ana lletwMn Ula; rAS!dl!!Nlall neiglibcrl'i0od$.

OOffltnerct.alieas. sdlods. ard pa& OI Ille dev,d0C841 GT$P &"Ii Nrui!': 11r"' Slalc Cf,i:1;m11glromt! mill o.ni •a fdr11'lifim1km ,mmb#ifo~ ,di ~"'"''pro} Pff','imu drafJ doe,rut.1em) 11fl!'tl1e fiJJ in.

EXHIBIT A ITEM 13
Reviewing Agenc,ies, C·heck:nst
Lead genci cs m y r«-0mmi:nd St ~e ac rin.gho~ di tributiOlil by marking en ic:
1r you h ve lrcady stn.t y ur documcm lO lh~ gt'n y pte SC O:C'QO[C ih l wi1h an " ". ~ Air Resourc,c Bo rd
aoatin & W krW:ays, Dcpartmern o
__ C Ii romia Errnc:rgc_.cy Man gcment Agcn . y
_X_· CaJiromia Highw y P11trol
X Ca 1rnns District 10
Caf11 n o • vi~ion of Aeronautics
.IC Cu1lrans Pli!l'nl inc
X Cenl • V Jtey oodl P,r ection Bo-,rd
__ Co . hellu Val ey 1M1n~. Gon..sc:rvaocy
Coastril' Co111mi iofl
ColotaJo R • V¢ Bo rd
X Con ervatton!, Dc:pa11men1 or
__ Conection!':, Dcp:u1.nu;nt of
Delt Protection o mis ion
Education Dcpanmcn1 or
X
X
-
En rgy Commis • on
nsh & Game R.cgiOlll N _4 __
Food & Agricu lure, Dep rtmcnt or
' mtry aoo fire, Prolcclion, Deparimcnl or
Gene I Services, De anmcnl or
Htahh ervkcs IOcp r1men1 of
H~LI Ln & C'~mmuni1y ~vcl0pm rn
Ii c An ri1 h Hcnt11 c mm ion
Otl'foc or H' toric P1cscrva1ion
Oflicc of Public School omtru tkrn
_x __ Park.,; & Rccr tion. Dep r1men1 f'
__ Pcr.tici t Regul lion, De rtm n1 of
Public U1ili.1ic Commi 'ion
.3._ R giora WQOB # __
Rso •e:sAgny
_ Re.source Recycling nd o, ery, DcpM11men1 of
_ S.F. Bay Con rv rion ,& Devclopmcm Comm,.

San Gabrkl. Lo er L. . Ri t . Mn , Conscf ncy
_ Sun Joaquin River Conscrv ncy
__ San Monica ttn.s. on rvancy

1.itc L~n -Cavnmi icn
SWRCB: C -an Wa,cr Grant
_ WRCB: W tcrQ. lily
_ __ T ka~ R:1,;giom1 1I P1 oning A ency
Tox·c Subs nc ntrol.' r rtmenl of
Wa,cr Rcs.ou:r•ce Dep r1m nt of
Other: ----------------- 0 ~ • --------------- __. _______________ illil',_.,,__,________________________________________ _ LCCII Publ C Rov tw P riod (Co be fill d 1ln by ft d il81'1Cy) LHd Agency tCetnpltlt If appllctbl ):
onsulhng fm'l'I: _e ___ :-- ____ 1a_1___ _
dd s~ :t1
City, late/Zip; _Li_i:d_C_•_BSJ_4_D _________ _
Cont· • t: Cltarl Simpson
Phone: 209 224 82 3
ndin,g El tc 12/2012024
illi!!!II--------------------------
Apphc nt: _. _.,1,,o,, ________________ _
ddress; .;;;.;;.;;.;;.........: .................. _. __________ _ C11y1 tc, Zip: C res. Ca 95307
fbone: 209 5315TT8
------~- S gn11ture of Lead .Agenc.y R,apr sentativo: ___ C¼.uu..::: • ..:::;:==· :;;:'::;...;S::.i::.~:;::;:.w1.·. ~-=..:."If,,.;;;·....,. _____ _ Aulhor y cited; Section 21083, Publlc ources Code Refare.m::e Secl1on 21161. PtJblk: Resource Code.

EXHIBIT A ITEM 13
From: Christine Asiata [email protected]
Subject: SCH Number 2023090637
Date: November 13, 2024 at 7:20PM
To: Rayanna L Beck [email protected]
Thank you for using CEQA Submit.

Public Resources Code (PRC) Section 21091(c)(3) and Guidelines Section 15105(e) allows the State Clearinghouse (SCH) to distribute CEQA documents within three working days after the date of receipt if the submittal is determined by the State Clearinghouse to be complete. Additionally, the State agency review period does not begin until the SCH distributes the CEQA document to State agencies. (Pub.

Resources Code, § 21093(c)(2).)
Your project is published and available for review. Please note the State and Local review ‘start’ and ‘end’ dates.

To view your project and any attachments via CEQAnet, from CEQA Submit: Click “Navigation” and select “Published Document”
Additional information is on State Clearinghouse (SCH) website - FAQs:
https://lci.ca.gov/sch/faq.html
Notice of Closing Letters: The SCH will not provide a close of review period acknowledgement on your CEQA environmental document. Comments submitted by State agencies are made available on CEQAnet by the SCH during and after the review period.

To view comments on your project via CEQAnet, please visit:
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· Under “Attachments,” view attachments labeled “State Comment Letters [Comments from State Reviewing Agency(ies)]”
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To get more information on a specific project, contact the lead agency responsible for it directly.
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Please contact the SCH with any questions at [email protected] or (916) 445-0613.

Thank you.

EXHIBIT A ITEM 13
Thank you.
**Note: No reply, response, or information provided constitutes legal advice.

Christine Asiata Rodriguez
Confidentiality Notice: The information contained in this email and any attachments is for the exclusive use of the intended recipient(s) and may contain confidential and privileged information. It is the property of the California Governor's Office of Planning and Research.

Unauthorized use, disclosure, or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify the sender immediately by return email and destroy all copies of the original message and any attachments.

EXHIBIT A ITEM 13
Copper Trails Specific Plan and Annexation
Summary
Contact Information
SCH Number
2023090637
Lead Agency
City of Ceres
Document Title
Copper Trails Specific Plan and Annexation
Document Type
EIR - Draft EIR
Received
11/13/2024
Present Land Use
Various/Urban/Agricultural/Commercial
Document Description
Copper Trails Specific Plan (CTSP) approval and annexation would result in the potential development of approximately 260.3 acres of low-,medium-, medium high-, and high-density residential units within the CTSP area. The total dwelling units that would be potentially developed is2,392. Approximately 107.4 acres is proposed for Regional Commercial development, which is estimated at 1,169,586 square feet of floor area.

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 Central Valley High School and Hidahl Elementary School, both operated by the Ceres Unified School District. The CTSP planned circulation system would utilize and improve existing roads and 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 CTSP area.

Name
City of Ceres - Lea Simvoulakis
Agency Name
City of Ceres
Job Title
Director
11/5/25, 2:54 PM Copper Trails Specific Plan and Annexation https://ceqanet.lci.ca.gov/2023090637/2 1/4
EXHIBIT A ITEM 13
Location
Contact Types
Lead/Public Agency / Project Applicant
Address
2220 Magnolia Street
Ceres, CA 95307
Phone
(209) 538-5778
Email
[email protected]
Name
Charlie Simpson
Agency Name
BaseCamp Environmental, Inc.

Job Title
Principal
Contact Types
Consulting Firm
Address
802 W Lodi Ave
Lodi, CA 95240
Phone
(209) 224-8213
Email
[email protected]
Coordinates
37°34'33"N 120°57'8"W
Cities
Ceres
Counties
Stanislaus
Regions
Citywide
Cross Streets
State Route 99 / Mitchell Road
11/5/25, 2:54 PM Copper Trails Specific Plan and Annexation https://ceqanet.lci.ca.gov/2023090637/2 2/4
EXHIBIT A ITEM 13
Notice of Completion
Zip
95307
Total Acres
680.7
Jobs
1 Parcel #
Various
State Highways
99 Railways
UP
Airports
Modesto City-County
Schools
Central Valley, Hidahl
Waterways
TID Irrigation Lateral
Township
4S
Range
9E
Section
22/23
Base
MDBM
State Review Period Start
11/13/2024
State Review Period End
12/27/2024
State Reviewing Agencies
California Air Resources Board (ARB), California Department of Conservation (DOC), California Department of Education, California Department of Fish and Wildlife, North Central Region 2 (CDFW), California Department of Housing and Community Development (HCD), California Department of Parks and Recreation, California Department of Pesticide Regulation (DPR), California Department of Resources Recycling and Recovery, California Department of Toxic Substances Control (DTSC), California Department of Transportation, District 10 (DOT), California Department of Transportation, Division of Aeronautics (DOT), California Department of Transportation, Division of Transportation Planning (DOT), California Department of Water Resources (DWR), California Energy Commission, California Fish and Game Commission (CDFGC), 11/5/25, 2:54 PM Copper Trails Specific Plan and Annexation https://ceqanet.lci.ca.gov/2023090637/2 3/4
EXHIBIT A ITEM 13
Attachments
Disclaimer: The Governor’s Office of Land Use and Climate Innovation (LCI) accepts no responsibility for the content or accessibility of these documents. To obtain an attachment in a different format, please contact the lead agency at the contact information listed above. For more information, please visit LCI’s Accessibility Site.

California Governor's Office of Emergency Services (OES), California Highway Patrol (CHP), California Native American Heritage Commission (NAHC), California Natural Resources Agency, California Public Utilities Commission (CPUC), California Regional Water Quality Control Board, Central Valley Sacramento Region 5 (RWQCB), California State Lands Commission (SLC), Central Valley Flood Protection Board, Department of General Services (DGS), Office of Historic Preservation, State Water Resources Control Board, Division of Drinking Water, District 10, State Water Resources Control Board, Division of Water Quality, State Water Resources Control Board, Division of Water Rights, State Water Resources Control Board, Divison of Financial Assistance, State Water Resources Control Board, Division of Drinking Water, California Department of Fish and Wildlife, Central Region 4 (CDFW)
State Reviewing Agency Comments
State Water Resources Control Board, Division of Drinking Water, California Department of Fish and Wildlife, Central Region 4 (CDFW)
Development Types
Residential (Units 2392, Acres 260.3), Commercial (Sq. Ft. 4678344, Acres 107.4, Employees 1), Recreational (42.3 acres for parks and open space)
Local Actions
Specific Plan, Annexation
Project Issues
Aesthetics, Agriculture and Forestry Resources, Air Quality, Biological Resources, Cumulative Effects, Drainage/Absorption, Flood Plain/Flooding, Geology/Soils, Greenhouse Gas Emissions, Hazards & Hazardous Materials, Hydrology/Water Quality, Land Use/Planning, Mineral Resources, Noise, Population/Housing, Public Services, Recreation, Schools/Universities, Transportation, Tribal Cultural Resources, Utilities/Service Systems
Public Review Period Start
11/5/2024
Public Review Period End
12/20/2024
Draft Environmental Document [Draft IS, NOI_NOA_Public notices, OPR Summary Form, Appx,] 3100 Public Review Draft 11624 copy 2 Copper Trails Draft EIR Notice of Availability Summary Form OCR
PDF 52775 K PDF 1042 K
PDF 1347 K
Notice of Completion [NOC] Transmittal form
NOC Copper Trails PDF 347 K
State Comment Letters [Comments from State Reviewing Agency(ies)] 2023090637_CDFW Comment PDF 228 K 2023090637_DDW Comment PDF 357 K 11/5/25, 2:54 PM Copper Trails Specific Plan and Annexation https://ceqanet.lci.ca.gov/2023090637/2 4/4
EXHIBIT A ITEM 13
APPENDIX B
UPDATED DEIR GRAPHICS
EXHIBIT A ITEM 13
Figure 3-1
BaseCamp Environmental PROPOSED LAND USE PLAN SOURCE: Wood Rodgers LEGEND
Low Density Residential (LDR)
Medium Density Residential (MDR)
Medium-High Density Residential (MHDR)
High Density Residential (HDR)
Regional Commercial (RC)
Parks & Open Space (P/OS)
Community Facilities (CF)
Schools (ES/HS)
MDR
MDR
LDR
LDR
LDR

LDR LDR

LDR LDR
RC
RC
RC
RC
HDR
HDR
MHDR
MHDR
P/OS
P/OS
P/OS
P/OS
P/OS
P/OS
ES
ES/HS
MDR
HDR
P/OS
CF CF
MDR
MDR
LDR
LDR
LDR

LDR LDR

LDR LDR
RC
RC
RC
RC
HDR
HDR
MHDR
MHDR
P/OS
P/OS
P/OS
P/OS
P/OS
P/OS
ES
ES/HS
MDR
HDR
P/OS
CF CF
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
EXHIBIT A ITEM 13
Figure 3-2
BaseCamp Environmental TRANSPORTATION KEY MAP SOURCE: Wood Rodgers LEGEND
Service Road (99’ ROW)
Service Road (103’-116’ ROW)
Central Ave & Moffett Rd (100’ ROW)
Interior Collector (84’ ROW)
Interior Collector (90’ ROW)
Interior Collector (70’ ROW)
Blaker Road (58’ ROW)
Service Road (85’ ROW)
Park Collector (44’ ROW)
Interior Collector (62’ ROW)
Moffett Road (6-Lane Arterial)
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
MDR
MDR
LDR
LDR
LDR

LDR LDR

LDR LDR
RC
RC
RC
RC
HDR
HDR
MHDR
MHDR
P/OS
P/OS
P/OS
P/OS
P/OS

P/OS CF CF
ES
ES/HS
MDR
HDR
P/OS
EXHIBIT A ITEM 13
BaseCamp
Figure 3-3
BaseCamp Environmental STREET SECTIONS

COPPER TRAILS SPECIFIC PLAN

STREET SECTIONS
FEBRUARY, 2026
EXHIBIT A ITEM 13
BaseCamp
Figure 3-4
BaseCamp Environmental TRANSIT AND PEDESTRIAN CIRCULATION Bike and Pedestrian , Transit
Public Transit
LEGEND
Preliminary StanRTA
Transit Route
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
MDR
MDR
LDR
LDR
LDR

LDR LDR

LDR LDR
RC
RC
RC
RC
HDR
HDR
MHDR
MHDR
P/OS
P/OS
P/OS
P/OS
P/OS

P/OS CF CF
ES
ES/HS
MDR
HDR
P/OS
LEGEND
12’ Multi-Use Path
8’ Multi-Use Path
8’ Sidewalk
5’ Sidewalk
On-Street Bike Lane
(Width Varies)
Gondring Road
UPRR
Service Road
Blaker Road
Mitchell Road
State Route 99
Mitchell Road
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
MDR
MDR
LDR
LDR
LDR

LDR LDR

LDR LDR
RC
RC
RC
RC
HDR
HDR
MHDR
MHDR
P/OS
P/OS
P/OS
P/OS
P/OS

P/OS CF CF
ES
ES/HS
MDR
HDR
P/OS
EXHIBIT A ITEM 13
Figure 3-5
BaseCamp Environmental PROPOSED POTABLE WATER SYSTEM
12” 12” 12” 12”
12”
12”
12” 12”
12”
12”
12”
12”
12” 16” 12”
12”
12”
12”
12”
12”
12” 12” 12”
24” 24” 24” 24”
24”
24”
8” 8”
10”
10”
8”
8”
24”
8”
16” 16” 16”
12”
W
W
LEGEND
Existing Water Line
Planned Water Line
Existing Well & Tank
Planned Well
Planned Tank
W
W
Point of Connection
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
MDR
MDR
LDR
LDR
LDR

LDR LDR

LDR LDR
RC
RC
RC
RC
HDR
HDR
MHDR
MHDR
P/OS
P/OS
P/OS
P/OS
P/OS

P/OS CF CF
ES
ES/HS
MDR
HDR
P/OS
EXHIBIT A ITEM 13
Figure 3-6
BaseCamp Environmental PROPOSED SANITARY SEWER SYSTEM
LEGEND
Existing Sewer Line
Planned Sewer Line
Existing Manhole
Direction of Flow (Existing Line)
Direction of Flow (Planned Line)
Planned Lift Station
Planned Manhole Point of Connection
15” 12” 18”
8”
8”
12”
8”
8” 8”
”21 ”01
8”
”01 ”8
8”
8”
8”
18” 18”
”42 ”42
”21
42” 42”
10”
42”
12”
42”
8”
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
MDR
MDR
LDR
LDR
LDR

LDR LDR

LDR LDR
RC
RC
RC
RC
HDR
HDR
MHDR
MHDR
P/OS
P/OS
P/OS
P/OS
P/OS

P/OS CF CF
ES
ES/HS
MDR
HDR
P/OS
EXHIBIT A ITEM 13
Figure 3-7
BaseCamp Environmental PROPOSED NON-POTABLE WATER SYSTEM MDR
MDR
LDR
LDR
LDR

LDR LDR

LDR LDR
RC
RC
RC
RC
HDR
HDR
MHDR
MHDR
P/OS
P/OS
P/OS
P/OS
P/OS

P/OS CF CF
ES
ES/HS
MDR
HDR
P/OS 8” 8” 8”
8”
8”
8” 8”
12”
12”
W
W
W
LEGEND
Planned Non-Potable Water Line
W Planned Irrigation Well
Point of Connection
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
EXHIBIT A ITEM 13
Figure 3-8
BaseCamp Environmental PROPOSED STORM DRAINAGE SYSTEM
ES
(NOT

A PART)
ES/HS
(NOT A PART)
42”
48”
42”
42”
42”
42”
42”
36”
48”
42”
48” 42”
54”
36” 42”
42”
42”
30”
30”
30”
30”
30”
48”
30”
30”
60”
24”
36”
36”
54”
60”
42”
30”
36”
30”
72”
30” 60” 60”
60”
54”
36”
24”
36”
30”
36”
30”
30”
36”
24”
36”
36”
42” 42”
54”
24”
30”
24”
18” 18”
18” 18”
LEGEND
Planned Storm Drain Line
Planned Direction of Flow
Storm Drain Manhole
Park/Landscape
Basin
Outfall Structure
Point of Connection
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
MDR
H7.5D
MDR
LDR
LDR
LDR

LDR LDR

LDR LDR
RC
RC
RC
RC
HDR
HDR
MHDR
MHDR
P/OS
P/OS
P/OS
P/OS
P/OS
P/OS
CF CF
MDR
HDR
MDR
LDR
LDR
LDR

LDR LDR

LDR LDR
RC
RC
RC
RC
HDR
HDR
MHDR
MHDR
P/OS
P/OS
P/OS
P/OS
P/OS
P/OS
CF CF
MDR
EXHIBIT A ITEM 13
PUBLIC REVIEW DRAFT
ENVIRONMENTAL IMPACT REPORT
FOR THE
November 2024
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 B ITEM 13
PUBLIC REVIEW DRAFT
ENVIRONMENTAL IMPACT REPORT
FOR THE
COPPER TRAILS SPECIFIC PLAN
AND ANNEXATION PROJECT
Ceres, CA
November 2024
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 B ITEM 13
i
TABLE OF CONTENTS
Page

1.0 Introduction 1-1

1.1 Project Overview 1-1

1.2 Project Background 1-2

1.3 EIR Requirements and Intended Uses 1-3

1.4 CEQA Procedures for the EIR 1-5

1.5 Intended Uses of the EIR 1-8

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 Project Description 3-1

3.1 Project Overview 3-1

3.2 Project Location 3-2

3.3 Project Objectives 3-2

3.4 Project Entitlements 3-4

3.5 Potential Developments Under the Specific Plan 3-7

3.6 Potential Development in the Pocket Area 3-13

3.7 Entitlements and Permits 3-13

4.0 Aesthetics 4-1

5.0 Agriculture and Forestry Resources 5-1

6.0 Air Quality 6-1

7.0 Biological Resources 7-1

8.0 Cultural Resources 8-1

9.0 Geology and Soils 9-1
EXHIBIT B ITEM 13
ii

10.0 Greenhouse Gas Emissions 10-1

11.0 Hazards and Hazardous Materials 11-1

12.0 Hydrology and Water Quality 12-1

13.0 Land Use, Population, and Housing 13-1

14.0 Noise 14-1

15.0 Public Services 15-1

16.0 Transportation 16-1

17.0 Utilities and Energy 17-1

18.0 Cumulative Impacts 18-1

19.0 Alternatives to the Proposed Project 19-1

20.0 Other CEQA Issues 20-1

20.1 Growth-Inducing Impacts 20-1

20.2 Irreversible Environmental Changes 20-3

20.3 Significant and Unavoidable Impacts 20-4

20.4 Environmental Justice 20-4

21.0 Referenced Cited and Persons Consulted 21-1

APPENDICES
A. Notice of Preparation and Comments
B. Annexation Map and Ownership List
C. Air Quality Modeling
D. Biological Resource Materials
E. Cultural Resource Materials
F. Noise Study
G. Transportation Impact Analysis
EXHIBIT B ITEM 13
iii
LIST OF TABLES Page
1-1 Summary of NOP Comment Letters 1-5
2-1 Summary of Environmental Impacts and Mitigation Measures 2-5 3-1 Proposed Pre-Zoning 3-4
3-2 Copper Trails Specific Plan Potential Development Summary 3-7 3-3 Required Permits and Approvals, Copper Trails Specific Plan 3-14 5-1 Williamson Act Parcels in Project Site 5-4
6-1 Air Pollutant Emissions in Stanislaus County, 2017 6-4 6-2 National and California Ambient Air Quality Standards 6-5 6-3 San Joaquin Valley Air Basin Attainment Status 6-6
6-4 Summary of SJVAPCD Air Quality Plans 6-9
6-5 Air Emissions from Construction, Maximum Development Year 6-14 6-6 Estimated Annual Operational Emissions in CTSP Area at Buildout 6-17 7-1 Special Status Plant and Wildlife Species Potentially Occurring in the 7-2 CTSP Vicinity
9-1 Soils on Project Site 9-3
10-1 GHG Emissions from Project Operations At Buildout 10-12 13-1 Population of Ceres, Stanislaus County, and California 13-2 14-1 Existing Background Noise 14-3
14-2 Effects of Vibration on People and Buildings 14-4
14-3 Maximum Allowable Exposure to Noise from Transportation 14-5 Noise Sources
14-4 Performance Standards for Stationary Noise Sources 14-6 14-5 Predicted Traffic Noise Levels and Noise Level Changes 14-7 14-6 Predicted Operational Noise Levels from Commercial Area 14-9 14-7 Construction Equipment Noise 14-11
15-1 Student Generation Rate Per Residential Household 15-8 16-1 Roadway Segment Average Daily Traffic – Existing and 16-10 Near-Term Conditions
16-2 VMT Significance Thresholds and CTSP VMT 16-14
17-1 Ceres Water Supply and Demand Comparison, 2025-2040 17-12 17-2 CTSP Potential Wastewater Generation at Buildout 17-13 17-3 CTSP Potential Solid Waste Generation at Buildout 17-15 17-4 CTSP Potential Annual Energy Consumption at Buildout 17-16 18-1 Roadway Segment Average Daily Traffic – Cumulative Conditions 18-13 19-1 Comparison of Alternatives to the Proposed Project Impacts 19-5 19-2 Comparison of Proposed and 2007 Copper Trails Specific Plan 19-7 Development
19-3 Current Ceres General Plan Designations for CTSP Area 19-9 EXHIBIT B ITEM 13
iv
LIST OF FIGURES Page
1-1 Regional Location Map 1-9
1-2 Project Location 1-10
1-3 Annexation Area with Pocket Area 1-11
1-4 USGS Map 1-12
1-5 Aerial Photo 1-13
3-1A Proposed CTSP Land Use Plan 3-16
3-1B Pocket Area Prezoning 3-17
3-2 Transportation Key Map 3-18
3-3 Street Sections 3-19
3-4 Transit and Pedestrian Circulation 3-20
3-5 Proposed Potable Water System 3-21
3-6 Proposed Sanitary Sewer System 3-22
3-7 Proposed Non-Potable Water System 3-23
3-8 Proposed Storm Drainage System 3-24
4-1A Representative Photos 4-9
4-1B Representative Photos 4-10
4-1C Representative Photos 4-11
4-1D Representative Photos, Pocket Area 4-12
5-1 Important Farmland Map 5-11
5-2 Williamson Act Lands 5-12
9-1 Soil Types 9-11
11-1 Airport Influence Area Map 11-15
13-1 Ceres General Plan 13-12
13-2 Stanislaus County General Plan 13-13
13-3 Stanislaus County Zoning 13-14
14-1 Existing (2017) Noise Contours 14-15
14-2 Noise Study Measurement Locations 14-16
14-3 Modesto Airport Noise Contours 14-17
15-1 Public Service Facilities 15-11
16-1 Study Roadway Segments 16-19
19-1 2007 Copper Trails Specific Plan Area 19-12
EXHIBIT B ITEM 13
v

ACRONYMS AND ABBREVIATIONS USED IN THIS DOCUMENT
AB Assembly Bill
ACE Altamont Corridor Express
ALUCP Airport Land Use Compatibility Plan
APN Assessor’s Parcel Number
ARB California Air Resources Board
BERD Built Environment Resource Directory
BMP Best Management Practice
BTU British thermal unit
CalEEMod California Emissions Estimator Model
CalEnviroScreen California Communities Environmental Health Screening Tool Cal Fire California Department of Forestry and Fire Protection CALGreen California Green Building Standards Code
CalRecycle California Department of Resources Recovery and Recycling Caltrans California Department of Transportation
CCIC Central California Information Center
CDFW California Department of Fish and Wildlife
CESA California Endangered Species Act
CEQA California Environmental Quality Act
CMP Congestion Management Process
CNDDB California Natural Diversity Database
CNEL Community Noise Equivalent Level
CO carbon monoxide
CO2e carbon dioxide equivalent
Corps U.S. Army Corps of Engineers
CPUC California Public Utilities Commission
CRHR California Register of Historical Resources
CUPA Certified Unified Program Agency
CTSP Copper Trails Specific Plan
CUSD Ceres Unified School District
DA Development Agreement
dB decibel
dBA A-weighted decibel
DPM diesel particulate matter
DTSC California Department of Toxic Substances Control
DUC Disadvantaged Unincorporated Community
DWR California Department of Water Resources
EXHIBIT B ITEM 13
vi
EIR Environmental Impact Report
EPA U.S. Environmental Protection Agency
ETRIP Employer Trip Reduction Implementation Plan
FEMA Federal Emergency Management Agency
GAMAQI Guide for Assessing and Mitigating Air Quality Impacts GHG greenhouse gas
GPEIR Ceres General Plan 2035 EIR
HCD California Department of Housing and Community Development kWh kilowatt-hour
LAFCo Local Agency Formation Commission
Ldn Day-Night Average Noise Level
Leq Equivalent Noise Level
LOS Level of Service
mgd million gallons per day
MRZ Mineral Resource Zone
MS4 Municipal Separate Storm Sewer System
NAHC Native American Heritage Commission
NOx nitrogen oxide
NOP Notice of Preparation
NPDES National Pollutant Discharge Elimination System
NRHP National Register of Historic Places
OPR Governor’s Office of Planning and Research
PG&E Pacific Gas and Electric Company
PM2.5 particulate matter less than 2.5 micrometers in diameter PM10 particulate matter less than 10 micrometers in diameter RCRA Resource Conservation and Recovery Act
RHNA Regional Housing Needs Assessment
ROG reactive organic gases
RTP Regional Transportation Plan
RWQCB Regional Water Quality Control Board
SB Senate Bill
SCS Sustainable Communities Strategy
SGMA Sustainable Groundwater Management Act
SJVAPCD San Joaquin Valley Air Pollution Control District SR State Route
SRRF Stanislaus Resource Recovery Facility
StanCOG Stanislaus Council of Governments
StanRTA Stanislaus Regional Transit Authority
EXHIBIT B ITEM 13
vii
SWPPP Storm Water Pollution Prevention Plan
SWRCB State Water Resources Control Board
TAC toxic air contaminant
TID Turlock Irrigation District
UPRR Union Pacific Railroad
USFWS U.S. Fish and Wildlife Service
UWMP Urban Water Management Plan
VOC volatile organic compound
VMT vehicle miles traveled
WSA Water Supply Assessment
WWTP Wastewater Treatment Plant
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 1-1 November 2024

1.0 INTRODUCTION

1.1 PROJECT OVERVIEW
This document is an Environmental Impact Report (EIR) that describes the potential environmental effects of adoption and implementation of the proposed Copper Trails Specific Plan (CTSP) and Annexation Project (project). The annexation project includes a total of 680.7 acres in 244 existing parcels; the 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 1-4). This EIR has been prepared in accordance with the requirements of the California Environmental Quality Act (CEQA).

CEQA and its requirements are described in more detail in Section 1.3, below. For CEQA purposes, the City of Ceres (City) is the Lead Agency for this project.

The Copper Trails Specific Plan would guide the future development of new urban land uses on 68 undeveloped or under-developed parcels located within the 534.6-acre CTSP Area, which is adjacent to and southwest of Ceres in unincorporated Stanislaus County (Figures 1-1 through 1-4); the CTSP area would be annexed to the City in conjunction with approval of the specific plan. The CTSP proposes a mix of commercial, public, park, and low- to high-density residential land uses. Total potential development pursuant to the CTSP would include 2,392 new single- and multi-family residential units and 1,169,586 square feet of new regional commercial development. It also would include approximately

42.3 acres of new parks and open space and 3.4 acres of new public space to add 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 basic urban service needs and encourage 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 are provided in Chapter 3.0, Project Description.

In addition to annexation of the 68 parcels within the CTSP Area, the project would also include annexation of another 176 parcels totaling146.1 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 total proposed annexation area would amount to 680.7 acres. The Pocket Area would be pre-zoned in conjunction with annexation consistent with the existing Ceres General Plan designations.

Annexation of the CTSP Area without the Pocket Area would create an unincorporated island within the City limits, which is contrary to LAFCo annexation policy. Approval of the CTSP and of subsequent development would consist of several interrelated City approvals and other actions. Annexation of the CTSP Area and other unincorporated lands would require the approval of the Stanislaus Local Agency Formation Commission (LAFCo).

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 1-2 November 2024

1.2 PROJECT BACKGROUND
The overall project site, including both the CTSP Area and the Pocket Area, is presently within the planning jurisdiction of Stanislaus County. The CTSP Area is approximately bounded by Mitchell Road to the east, Service Road to the north, Blaker Road to the west, and the Turlock Irrigation District (TID) Lower Lateral 2 to the south. Agricultural fields of orchards, livestock grazing and row crops and occupy the majority of the CTSP Area.

However, substantial residential, light industrial, and institutional development has also occurred. The most prominent developed features in the CTSP Area are Central Valley High School, adjacent to the intersection of Service Road and Central Avenue, Ceres Adult School, adjacent to and south of Central Valley High School, and Hidahl Elementary School, located along Redwood Road, east of Central Avenue.

The Pocket Area is bounded on the south by Service Road and by existing development within the existing City boundaries on the west and east. Land uses within this area consist of a mix of residential, commercial and industrial lands developed under County jurisdiction intermixed with vacant lands.

The overall annexation area, including the CTSP and Pocket Area, is within the Sphere of Influence of the City of Ceres and within the Planning Area of the Ceres General Plan 2035, which was adopted on May 14, 2018 (see Figure 13-1 in Chapter 13.0, Land Use).

Ceres has a relatively compact urban form, with large areas of agricultural land surrounding the City to the east, south, and west. The City of Modesto and its urban area is immediately north of Ceres. Due to a gridded pattern of main thoroughfares, the City is generally composed of large square areas of development, each a square mile (640 acres) in size, that are defined by transportation arterials running north/south or east/west, such as Hatch Road, Mitchell Road, Central Avenue, Service Road, Morgan Road, and Whitmore Avenue (City of Ceres 2018a).

A specific plan systematically implements a general plan of a local jurisdiction in a particular geographical area of that jurisdiction. Authority for the preparation of specific plans is found in California Government Code Sections 65450-65457. State law requires that a specific plan includes text and diagrams that specify the distribution and extent of land uses in the plan area, the standards and criteria by which development will proceed in the area, and a program of implementation measures necessary to carry out the plan, among other items. The specific plan also must include a statement of the relationship between the specific plan and the general plan of the local jurisdiction. The specific plan must be consistent with the general plan, and it must further the objectives and policies of the general plan and not obstruct their attainment. The procedures for adopting a specific plan are essentially the same as for a general plan, except that a specific plan may be adopted by either ordinance or resolution, and it can be amended as often as necessary. The Ceres City Council has approval authority for specific plans related to the City.

In 2003, the City received a request to prepare what became known as the Copper Trails Neighborhood Master Plan. The Master Plan covered an area southwest of Ceres of approximately 175 acres, considerably smaller than the CTSP Area. The Master Plan area was bounded by Central Avenue, Service Road, Blaker Road, and TID Lower Lateral 2 EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 1-3 November 2024 (City of Ceres 2007a). The Master Plan was released for public review in 2006, along with an EIR. After public comments were received, the Master Plan and the EIR were revised.

Public hearings by the Ceres Planning Commission on the Master Plan were scheduled in the fall of 2007, but these hearings were continued due to inconsistencies and unclear items in the Master Plan that City staff identified (City of Ceres 2007b). After discussions between the City and the project applicant regarding these items, further activities related to the Master Plan were discontinued in 2008. The Master Plan was not adopted by the City, and a proposed annexation of the Master Plan area was not pursued.

In 2016, the City adopted the latest version of the Housing Element to its General Plan.

The Housing Element identifies the City's housing needs for a specified time period, which for the current element is 2014-2023. It states the City's goals and objectives regarding housing production, rehabilitation, and conservation to meet those needs, and it defines the policies and programs that the community will implement to achieve the stated goals and objectives. Housing needs in part are determined by a Regional Housing Needs Allocation developed by the Stanislaus Council of Governments (StanCOG) and allocated to member jurisdictions. For the planning period covered by the Housing Element, the City’s share of the regional housing need is 2,571 units, divided into smaller shares based on household incomes (City of Ceres 2016b). It is expected that the proposed residential development under the CTSP would address the housing need described in the Housing Element. As discussed in Chapter 13.0, Land Use, the Housing Element is in the process of being updated.

1.3 EIR REQUIREMENTS AND INTENDED USES
The purpose of an EIR is to document existing environmental conditions on a project site, describe the potential environmental effects of approving and implementing a project, consider and recommend mitigation measures that could avoid or substantially reduce significant environmental effects if they are identified, analyze alternatives to a proposed project, and meet other applicable CEQA requirements. The EIR is an informational document that does not, in and of itself, determine whether the project should be or will be approved; rather, the EIR will provide information in support of the City's decision-making process.

This EIR has been prepared in accordance with the requirements of CEQA (Public Resources Code Section 21000 et seq.) and the State CEQA Guidelines (California Administrative Code Section 15000 et seq.). Enacted in 1970, CEQA is intended to ensure that state and local agencies consider the environmental effects of actions for which they propose to undertake, finance, or issue discretionary permits. The State CEQA Guidelines elaborate upon and apply these requirements to both development projects and to local land use plans. This EIR generally follows the analysis sequence of the latest version of the CEQA Environmental Checklist shown in CEQA Guidelines Appendix G.

The EIR includes all the areas of content required by CEQA, including a project description, analysis of environmental effects, and mitigation measures in each of the issue areas identified in the CEQA Guidelines Appendix G. It also includes an analysis of cumulative impacts and alternatives, and a summary of environmental impacts. Each of the EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 1-4 November 2024 technical sections of the EIR reports on the environmental setting of the project, the project’s environmental effects, and mitigation measures that could reduce potential effects to a less than significant level. The general scope and content of the EIR are outlined below. ● 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
● Appendices
CEQA requires the designation of a Lead Agency for a project. As defined in the CEQA Guidelines, the Lead Agency is the public agency that carries out a project or that has the greatest responsibility for supervising or approving a project. As the City of Ceres has approval authority over the CTSP and subsequent development of projects within the CTSP Area and the annexation area , the City is the Lead Agency for the proposed project.

The Stanislaus LAFCo would be designated a Responsible Agency for CEQA purposes. A Responsible Agency is a public agency, other than a Lead Agency, that has discretionary approval authority over a project. Under CEQA Guidelines Section 15096, a Responsible Agency complies with CEQA by considering the CEQA document prepared by the Lead Agency and by reaching its own conclusions on whether and how to approve the project involved. CEQA Guidelines Section 15041 states that a Responsible Agency has more limited authority than a Lead Agency in requiring changes to a project; only changes that lessen or avoid the effects of that part of a project which the agency will be called on to carry out or approve are allowed. This EIR includes analyses of issues that would be considered by the Stanislaus LAFCo during its decision-making process on the proposed annexation, and the LAFCo will have the opportunity to comment on the EIR and its EXHIBIT B ITEM 13
Copper Trails Specific Plan EIR 1-5 November 2024
content during the public review period. The Stanislaus LAFCo submitted comments during the Notice of Preparation review period, as shown in Table 1-1.

Other potential Responsible Agencies may include the California Department of Fish and Wildlife (CDFW), the Central Valley Flood Protection Board (CVFPB), and the Central Valley Regional Water Quality Control Board (RWQCB). These, and perhaps other agencies, would not be directly involved in review and approval of the CTSP but may be involved in permit review for individual development projects if and when the agencies’ regulatory requirements are triggered. Issues pertaining to these and other agencies are likewise addressed in this EIR.

After the current environmental review process for the CTSP is concluded, it is anticipated that project development plans for portions of the CTSP Area would be generated and submitted to the City for site plan and design review approval. The subsequent applications may require consideration under CEQA, including if the potential environmental effects of the project are adequately addressed by this EIR and/or which of the mitigation measures or other requirements described in this EIR apply to the project.

1.4 CEQA PROCEDURES FOR THE EIR

1.2.2 Notice of Preparation and Scoping
At the time the specific plan application process was initiated, the City of Ceres determined that an EIR would be required for the CTSP. In accordance with CEQA Guidelines Section 15060(d), no Initial Study was prepared. Instead, a Notice of Preparation (NOP) was distributed to potential responsible and trustee agencies on September 27, 2023 for a 30- day agency review and comment period. The purpose of the NOP was to provide notification that an EIR for the project was being prepared and to solicit guidance on the scope and content of the document. In addition, the NOP was published in the Ceres Courier, a newspaper of general circulation, to notify the public of an opportunity to provide comments on issues that should be addressed in the EIR or other pertinent content.

A copy of the NOP and all comments received on the NOP are included in Appendix A.

Written NOP comments from agencies and the public, and the EIR section(s) where the commenter’s issues and concerns are addressed, are summarized in Table 1-1.

TABLE 1-1

SUMMARY OF NOP COMMENT LETTERS
# Date Commenter Concerns Where Comment
Addressed in EIR
1 10/4/23 Native American
Heritage
Commission
Lead Agency should initiate
consultation with tribes pursuant to
AB 52 and SB 18. Recommends
CHRIS records search and NAHC
Sacred Lands File search, and an
archaeological survey if required,
Ch. 8.0, Cultural
Resources and Tribal
Cultural Resources
EXHIBIT B ITEM 13
Copper Trails Specific Plan EIR 1-6 November 2024
# Date Commenter Concerns Where Comment
Addressed in EIR
along with mitigation that covers
encounters with tribal cultural
resources.
2 10/6/23 Stanislaus County
Department of
Environmental
Resources,
Environmental
Health Division
None – project will not have a
significant impact on the
environment relative to agency’s
field of expertise.

Ch. 17.0, Utilities and
Energy
3 10/17/23 Stanislaus Local
Agency Formation
Commission
Address impacts on agricultural
resources, including impacts on
Williamson Act contract lands. Show
that Specific Plan area would have
adequate public services. Consider
impacts on special districts.

Ch. 5.0, Agricultural
Resources; Ch. 15.0,
Public Services; Ch.

17.0, Utilities and
Energy
4 10/17/23 California
Department of
Conservation
Conversion of agricultural land and
mitigation of such conversion.

Impacts on lands under Williamson
Act contract.

Ch. 5.0, Agricultural
Resources
5 10/26/23 Central Valley
Regional Water
Quality Control
Board
Provided information on regulatory
setting and permit requirements
related to water quality. No projectspecific comments.

Ch. 12.0, Hydrology
and Water Quality
6 10/26/23 Turlock Irrigation
District
Potential impacts on Ceres Main
Canal and Lower Lateral 2.

Recommended improvements to
some existing irrigation facilities
and removal of others. Use of canals
for storm drainage requires TID
approval. Consistency with TID
easement and front building setback
requirements. Understand electric
infrastructure requirements,
including for solar and EV charging,
and use of natural gas.

Ch. 12.0, Hydrology
and Water Quality;
Ch. 17.0, Utilities and
Energy
7 10/30/23 California
Department of Fish
and Wildlife
Special-status species, including
Swainson’s hawk. Nesting birds that
may be protected. Potential
alteration to TID laterals.

Cumulative impacts on biological
resources.

Ch. 7.0, Biological
Resources
In addition to circulating the NOP, the City scheduled an in-person scoping meeting during the NOP circulation period; the scoping meeting was held before the Ceres Planning Commission on October 16, 2023. Oral comments and concerns were provided by 7-8 persons in attendance, primarily landowners within the CTSP area.

EXHIBIT B ITEM 13
Copper Trails Specific Plan EIR 1-7 November 2024
Community development concerns spoken to during the meeting included affordable housing needs; infrastructure timing should precede development; how street, pedestrian and other urban improvement needs in the Pocket Area will be met; desire for complete future parks rather than linear landscaping strips; and the timing of planned improvements to the SR 99 / Service Road interchange. Potential environmental concerns associated with the project included the general impacts of urban expansion on “the environment,” desirability of developing of infill lands, existing traffic congestion during school arrival and departure hours, development impacts on public services and concerns regarding how the costs of services will be met, and safe routes to schools. General environmental concerns are addressed throughout this EIR; traffic and transportation concerns are addressed in Chapter 16.0 Transportation; development impacts on services are addressed in Chapter 15.0 Public Services; and potential service costs associated with the project are addressed in a fiscal impact study being prepared in conjunction with the CTSP and the EIR.

The CTSP and EIR documents were prepared concurrently. This process provided the opportunity for the environmental consultants to recommend mitigation measures for otherwise potentially significant adverse effects - measures that were subsequently incorporated within the CSTP. To the extent that this occurred, the CTSP is a “mitigated plan,” or a specific plan that contains environmental mitigations within its text and regulatory scope.

Regulatory agencies and members of the public have the opportunity to comment on the EIR and its adequacy in fulfilling the purposes of CEQA during a 45-day review period.

This document is the Public Review Draft EIR (Draft EIR) for the project, which will be available for review and comment from _____ to _____. Any comments or questions regarding this EIR should be submitted to the lead agency at the following address before the close of the review period.

City of Ceres
2220 Magnolia Street
Ceres, CA 95307
Attention: Lea Simvoulakis,
Community Development Director
After the close of the public review period, the City will provide written responses to each of the comments received. Those responses will be published in a Final EIR, which must be considered by the City and any other agencies with jurisdiction over the project, prior to project approval.

Before the City decides on the project, it first must certify that the Final EIR complies with the provisions of CEQA, that the City has reviewed and considered the information in the Final EIR, and that the Final EIR reflects the independent judgment of the City as to the environmental impacts of the project. The City is also required to make specific findings related to each of the significant effects identified in the EIR. If the project involves any significant and unavoidable environmental effects, the adopted CEQA findings must include findings related to the alternatives described in the EIR and a Statement of Overriding Considerations should the City in spite of any significant and unavoidable EXHIBIT B ITEM 13
Copper Trails Specific Plan EIR 1-8 November 2024
effects decide to approve the project. Mitigation measures described in the Final EIR will be incorporated into a Mitigation Monitoring and Reporting Program that will be adopted by the City in conjunction with project approval to ensure the mitigation measures are implemented.

1.5 INTENDED USES OF THE EIR
This EIR addresses the project’s environmental effects consistent with the level of definition of the CTSP and its components. The EIR is intended to provide “project”-level coverage for certain development types anticipated by the CTSP and may be found sufficient for such purposes by City staff and decision-makers, based on case-by-case review. Other projects may involve impacts that are not addressed in this EIR. All subsequent discretionary projects require consideration under CEQA. The level of CEQA review that would be required for individual future projects within the CTSP Area will be determined by the City on a case-by-case basis.

To the degree that a subsequent project’s environmental effects are adequately addressed by the EIR, environmental review can be reduced or avoided altogether. The City intends to use the EIR to simplify environmental processing for development projects within the CTSP Area. This would be accomplished in part by "tiering" off this EIR. Tiering is a CEQA streamlining tool that allows Lead Agencies to use previous analyses of larger-scale environmental issues in the review of individual development projects, when these issues are addressed in previously certified EIRs. CEQA Guidelines Section 15152 provides that lead agencies should limit environmental review documents on later projects to impacts that either 1) were not examined as significant effects on the environment in the prior EIR, or 2) are susceptible to substantial reduction or avoidance by the choice of specific revisions in the project, by the imposition of conditions, or other means.

The EIR has identified and analyzed potential environmental impacts and defined required mitigation measures for planned development to the extent feasible. To the degree that the EIR effectively addresses the potential environmental effects of future development, the amount and time required for CEQA review of this development can be reduced; projectspecific environmental documents could be tiered off this EIR and focused on issues not previously addressed.

New residential projects in the CTSP Area also may be eligible for CEQA exemptions, as provided in CEQA Guidelines Section 15182, which states:

Where a public agency has prepared an EIR on a specific plan after January 1, 1980, no EIR or negative declaration need be prepared for a residential project undertaken pursuant to and in conformity to that specific plan if the project meets the requirements of this section.

In addition, CEQA Guidelines Section 15183 provides that projects consistent with the development density established by existing zoning, community plan, or general plan for which an EIR was certified shall not require additional environmental review, except as EXHIBIT B ITEM 13
Copper Trails Specific Plan EIR 1-9 November 2024
might be necessary to examine whether there are significant impacts peculiar to the project or its site.

Many of the potential environmental effects of the proposed CTSP have also been considered on a programmatic level in the Ceres General Plan, adopted in 2018, and its associated EIR, certified the same year. The General Plan EIR addressed the potential environmental effects of urban development authorized by the General Plan, including development of the CTSP Area. The General Plan and EIR, cited below, are incorporated into this Draft EIR by reference:
• City of Ceres. 2018. Ceres General Plan 2035. Adopted May 14, 2018. • City of Ceres. 2018. Ceres General Plan 2035 Draft Environmental Impact Report. February 7, 2018.
• City of Ceres. 2018. Ceres General Plan 2035 Final Environmental Impact Report. April 24, 2018.

Copies of these documents are available for review at the Ceres City Hall, 2220 Magnolia Street, Ceres, CA 95307. They are also available for download from the City of Ceres website at https://www.ci.ceres.ca.us/193/Planning-Division.

EXHIBIT B 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 B ITEM 13
BaseCamp
Figure 1-2
BaseCamp Environmental PROJECT LOCATION

PROJECT SITE
EXHIBIT B ITEM 13
BaseCamp
Figure 1-3
BaseCamp Environmental ANNEXATION AREA WITH POCKET AREA

POCKET AREA

SPECIFIC PLAN AREA
EXHIBIT B ITEM 13
BaseCamp
Figure 1-4
BaseCamp Environmental USGS MAP
SOURCE: USGS Quadrangle Map, Ceres, CA 2021.

POCKET AREA

SPECIFIC PLAN AREA
EXHIBIT B ITEM 13
BaseCamp
Figure 1-5
BaseCamp Environmental AERIAL PHOTO
SOURCE: Google Earth

POCKET AREA

SPECIFIC PLAN AREA
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 2-1 November 2024

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. Proposed pre-zoning of this area is shown on Figure 3-1B.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 2-2 November 2024

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 B ITEM 13
Copper Trails Specific Plan and Annexation EIR 2-3 November 2024 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 B ITEM 13
Copper Trails Specific Plan and Annexation EIR 2-4 November 2024 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 B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-5 November 2024

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 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 Plan for Agricultural Preservation, as adopted by Stanislaus LAFCO in accordance with LAFCO Policy 22. (Previously addressed in Ceres General Plan EIR.) SU
EXHIBIT B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-6 November 2024 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 reduced through the required implementation of SJVAPCD
Regulation VIII and the Indirect Source Rule.

LS None required due to existing APCD rules and regulations 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 -
EXHIBIT B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-7 November 2024

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 EXHIBIT B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-8 November 2024 emissions, or at least six inches of freeboard space from the top of the container shall be maintained.
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
LS None required. -
EXHIBIT B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-9 November 2024 impacts. Individual projects would be subject to CEQA
review and potential mitigation measures if necessary.

Impact AIR-3: Exposure of Sensitive Receptors to Criteria Pollutants. Potentially significant CO effects could result 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.

LS None required. -
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 shall be conducted by a qualified wildlife biologist, following survey methods developed by the
Swainson’s Hawk Technical Advisory Committee (2000) prior to undertaking any ground-disturbing activities. The survey shall LS
EXHIBIT B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-10 November 2024 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 hawk nests are found to be present, a no-disturbance buffer of a minimum of 0.5 miles 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-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.

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 (March 1 through July 31), 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 B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-11 November 2024 Impact BIO-5: Local Biological Requirements.

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 B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-12 November 2024 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 human burials and/or associated funerary objects are encountered during construction, all construction activities within a 50-foot radius of the encounter shall be halted until the County Coroner and the City have been notified, If the Coroner determines that the remains are Native American in origin, then the Coroner must contact the Native American Heritage Commission within 24 hours and take other steps as required by California Health and Safety Code Section 7050.5.

A qualified archaeologist shall be retained by the contractor to examine the materials, evaluate their significance. and, in consultation with a tribal representative if needed, recommend mitigation measures needed to reduce potential effects to a level that is less than significant in a written report to the City.

Construction activities in the area of the find shall not resume until the mitigation measures are established. The contractor shall be responsible for retaining qualified professionals, implementing recommended mitigation measures, and
documenting mitigation efforts in written reports to the City.

LS

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
LS None required. -
EXHIBIT B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-13 November 2024 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.

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 site would be served by the City of Ceres wastewater
collection and treatment system.

NI None required. -
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. -
EXHIBIT B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-14 November 2024

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 None feasible. -
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. -
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-2: 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-3: 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 LS
EXHIBIT B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-15 November 2024 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 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-4: 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 LS
EXHIBIT B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-16 November 2024 made a condition of City approval unless the City overrides any recommendation in accordance with State law.

Impact HAZ-5: 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-6: 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-7: 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
Impact HAZ-8: 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
LS None required. -
EXHIBIT B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-17 November 2024 Management Program, the Construction General Permit,
and other regulations would minimize this impact.

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
could be divided by the project. The Pocket Area would be annexed to the City of Ceres.

NI None required. -
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 LS None required. -
EXHIBIT B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-18 November 2024 to the Agricultural Preservation Policy. Project would not substantially conflict with Modesto Airport ALUCP.

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, specific land uses could adversely affect nearby residences if placed too closely.

PS 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.

LS
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:

LS
EXHIBIT B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-19 November 2024 • 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.

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
EXHIBIT B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-20 November 2024 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. -

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 LS None required. - EXHIBIT B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-21 November 2024 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.

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 but not demonstrably avoid this
impact.

S TRANS-1: Prior to final approval of the Copper Trails Specific Plan, the City and the project applicant shall meet to identify and incorporate measures with substantial potential to reduce vehicle miles traveled generated by CTSP residential and office land uses within the Specific Plan area. The measures shall, if possible, quantify potential reductions in vehicle miles traveled and the degree to which CTSP VMT could approach the
respective significance thresholds for these land uses, as established in the Copper Trails Specific Plan Transportation Impact Analysis prepared by Wood Rodgers in March 2024.

These measures shall, to the degree feasible, be incorporated within the Copper Trails Specific Plan.

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
Service Road interchange. Mitigation would lead to
acceptable queuing.

PS TRANS-2: The applicant shall participate in the planning and design of the SR 99/Service Road SB and NB ramp intersections as needed to minimize queuing concerns associated with
Copper Trails development as described by Wood Rodgers in its 2024 Transportation Impact Analysis until the design and funding of the overall interchange improvement project is in place. The applicant shall be 100% responsible for the costs of temporary improvements, or the project’s proportionate share costs of the long-term improvements as determined by the City Engineer in coordination with the California Department of Transportation.

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

LS None required. -

17.0 UTILITIES AND ENERGY
EXHIBIT B ITEM 13
TABLE 2-1
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Significance Before Significance After
Potential Impact Mitigation Mitigation Measures Mitigation Copper Trails Specific Plan and Annexation EIR 2-22 November 2024 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. -
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 B ITEM 13
Copper Trails Specific Plan and Annexation EIR 3-1 November 2024

3.0 PROJECT DESCRIPTION

3.1 Project Overview
The proposed project consists of the annexation of a 680.7-acre area south and west of the City of Ceres, hereinafter referred to as the “project site.” The project “site” includes two components, which are referred to for convenience as the “CTSP Area” and the “Pocket Area,” both of which are proposed for annexation and future development.

The CTSP Area is linked with the proposed City adoption of the CTSP, approval of related permits and other approvals. The CTSP establishes a plan for, and would result in, development of residential, commercial, and other urban land uses on 68 existing parcels within the approximately 534.6-acre CTSP Area. Planned urban development within the CTSP would require City approvals of the CTSP, the proposed annexation, and pre-zoning of the CTSP Area. Future development within the CTSP Area is expected to require one or more development agreements and Tentative Map application submittals.

The project also proposes the annexation of the “Pocket Area,” comprised of 176 parcels totaling 146.1 acres of unincorporated land outside and north of the CTSP Area. The “Pocket Area,” is located between the existing City boundary and the CTSP area (Figures 1-1, 1-2 and 1-3). If the CTSP Area were annexed without the Pocket Area, the Pocket Area lands would become an unincorporated “island,” which is contrary to State statute and local annexation policies. Both the CTSP and Pocket Area annexations would require approval from the City and from the Stanislaus LAFCo.

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. A total of approximately 107.4 acres within the CTSP is proposed for Regional Commercial development. 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 Central Valley High School, Ceres Adult School, and Hidahl Elementary School, all operated by the Ceres Unified School District (CUSD). The planned circulation system within the CTSP Area would utilize and improve existing roads and add new roads and streets and would provide for development of new bicycle and pedestrian trails and open space linkages that would and between the planned residential neighborhoods, commercial areas, schools, and parks.

Annexation of the Pocket Area would include pre-zoning of the 146.1-acre Pocket Area consistent with existing Ceres General Plan designations; annexation of this area would make City utilities and services available to this largely developed unincorporated area.

The Pocket Area includes approximately 25 scattered acres comprising some 25 noncontiguous parcels of undeveloped land with some new development potential. The largest of these parcels, approximately 5.7 acres in size, would be pre-zoned for Neighborhood Commercial development in conjunction with the proposed annexation. Approximately 4.5 in two parcels acres would be available for Medium High Density Residential EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 3-2 November 2024 development, and 12 parcels totaling 17 acres would be available for Medium Density Residential development The Pocket Area includes several scattered parcels that would be available for Community Commercial or Industrial use. There are, however, no known plans for development of these lands.

3.2 Project Location
The project site is in unincorporated Stanislaus County south and west of the existing Ceres incorporated area (see Figures 1-1 through 1-5). The CTSP Area is bounded by SR 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.

The Pocket Area is located north and east of the CTSP Area and south of the existing City limits. This area is separated into western and eastern portions by SR 99. The western portion is approximately bounded by Service Road to the south, Central Avenue to the west, Industrial Way to the north, and SR 99 to the east. The eastern portion consists of the mainline SR 99 and associated State Highway right-of-way between 9th Street on the northwest and Moore Road to the southeast. An additional area is located between the SR 99 right-of-way and the existing City limits to the northeast.

The project site is shown on the Ceres, California, 7.5-minute series quadrangle map as being within Sections 22 and 23, Township 4 South, Range 9 East, MDBM (Figure 1-3).

The latitude of the approximate center of the CTSP Area is 37˚ 34' 33" North, and the longitude is 120˚ 57' 08" West.

3.3 Project Objectives

3.3.1 Overall Project Objectives
The objective of the annexation of the CTSP Area is the development of the residential, commercial, and recreational uses shown on the CTSP Proposed Land Use Plan (Figure 3- 1A). The objective of the annexation of the Pocket Area is to avoid creating an unincorporated island within the Ceres city limits.

3.3.2 Planning Objectives of the Copper Trails Specific Plan The development plan for the CTSP, as discussed in more detail below, is intended to achieve the following objectives:
• General Plan Implementation: Implement the General Plan by directing new development to the City’s Sphere of Influence (SOI), consistent with City-adopted policies and regulations defined in the General Plan, Zoning Ordinance, Improvement Standards, and other applicable plans, documents, and programs. • Comprehensive Planning: Prepare a Specific Plan and associated regulatory documents that create a comprehensive development plan for the orderly expansion of the City within The CTSP Sphere of Influence (SOI), consistent with the EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 3-3 November 2024 preliminary land uses identified on the adopted General Plan Land Use Diagram and as directed by General Plan policy that prioritizes growth in the City’s SOI. • Balanced Land Use Mix: Create a development plan with a mix of land uses that results in a balance of jobs and housing by accommodating approximately 2,300 residential units and 1.2-million square feet of non-residential, employmentgenerating uses, which are in town supported by neighborhood parks, open space areas, and various public/quasi-public uses.
• Housing Diversity: Designate areas for construction of a diverse array of housing types that provide housing choices in varying densities for all market segments, including opportunities for single-family homes in conventional and compact development patterns, townhomes, apartments, as well as opportunities for rental units and affordable housing consistent with the City’s General Plan. • Regional Housing Needs Allocation: Aid the City in achieving its fair share obligation to accommodate a percentage of the region’s forecasted population growth, as mandated by the California Department of Housing and Community Development and as directed by StanCOG.
• Land Use and Transportation Integration: Provide a mixture of land uses along the Service Road transportation corridor to take advantage of higher-intensity uses in proximity to State Route 99.
• Regional Roadway Planning: Establish a corridor for the future widening of Service Road, including land area for a planned interchange at State Route 99 and realignment of Lucas Road.
• Bicycle and Pedestrian Facilities: Develop a system of multi-use trails and Class II bikeway facilities that create alternative transportation modes within the CTSP Area and allow for connections to existing/planned bicycle/pedestrian facilities in the City.
• Backbone Infrastructure: Create a development plan that can be implemented in a phased manner and provides utility services via existing and planned infrastructure, which facilitates the logical, orderly expansion of the City adjacent to existing, urbanized areas.
• Economic Viability: Implement a public facility financing plan with logical development phases that enables the CTSP Area to develop in an economically feasible manner.
• Fiscal Responsibility: Create a development plan that can be implemented in a fiscally responsible manner, with neutral or positive fiscal impacts to the City and with identified revenue sources for the long-term maintenance of park facilities, open space areas, trails, landscape corridors, public services, and infrastructure.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 3-4 November 2024

3.4 PROJECT ENTITLEMENTS

3.4.1 Annexation
The proposed project would involve annexation of a total of 680.7 acres into the City of Ceres (Figure 3-2). The annexation area would include the approximately 534.6-acre CTSP Area, along with the 146.1-acre Pocket Area located to the north and east. A total of 244 parcels would be annexed, 68 of which are in the CTSP Area; the remaining 176 parcels are in the Pocket Area.

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. A comprehensive list of parcels and acreages proposed for annexation is provided in Appendix B of this EIR.

3.4.2 General Plan Amendments
As described in the CTSP, the specific plan is consistent with the planned land uses and requirements of the Ceres General Plan and has been prepared to achieve that consistency.

The adopted CTSP would include a range of graphic and text amendments to the Ceres General Plan. The CTSP’s proposed land uses generally conform to the existing Ceres General Plan Land Use/Circulation Diagram. However, the CTSP would modify existing designations to reflect more specific land use proposals. These changes would include the replacement of the existing Business Park designation and its replacement with a reconfigured Regional Commercial area adjacent to SR 99, elimination of a Neighborhood Commercial area, the more-specific locations of planned Medium- and High-Density Residential areas and the specific locations of new circulation routes, parks, trails, and open spaces. The Pocket Area would not require General Plan Amendments.

3.4.3 Pre-zoning
Ordinarily LAFCo policy requires that municipal annexations be pre-zoned by the City prior to annexation. The CTSP Area and the Pocket Area to be annexed are both within the planning jurisdiction of, and zoned by, Stanislaus County. Upon annexation, the City will assume planning jurisdiction for both areas. Table 3-1 shows the proposed pre-zoning of the annexation area and the acreages involved. Figure 3-1B shows the locations of the proposed land uses.

TABLE 3-1

PROPOSED PRE-ZONING
Land Use Zone Acres
Copper Trails Development Area
Planned Community P-C 521.1
Right-of-Way - 13.5
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 3-5 November 2024 Subtotal 534.6
Pocket Area
Single-Family Residential R-1 13.2
Medium Density Residential R-3 51.6
Medium-High Density Residential R-4 5.5
Neighborhood Commercial C-1 6.2
Community Commercial C-2 5.8
Light Industrial M-1 9.0
Right-of-Way - 15.4
SR 99/UPRR - 39.4
Subtotal 146.2
TOTAL 680.7
As shown in Table 3-1, the CTSP Area would be pre-zoned P-C, Planned Community.

Consistent with the regulations as outlined in Chapter 13 of the City’s Zoning Ordinance (Title 18 of the Ceres Municipal Code), the P-C zone allows the CTSP to function as the primary zoning tool and regulatory mechanism to implement the Copper Trails development plan. Pre-zoning would include modification of the Ceres Zoning Ordinance and zoning map to reflect the adoption of the CTSP and reference the CTSP’s Land Use Plan, detailed land use descriptions, and the allowable land uses and development standards as described in the CTSP. The Pocket Area, more conventionally, would be pre-zoned consistent with existing Ceres General Plan land use designations and the adopted Zoning Ordinance; development in this area would be subject to existing Ceres zoning requirements.

3.4.4 Copper Trails Specific Plan
The primary element of the proposed project is City approval of the CTSP. Figure 3-1B shows the boundaries of the CTSP Area and proposed land uses. Proposed development of the CTSP Area approval would involve completion of a series of related actions, including annexation of the CTSP Area, amendment of the Ceres General Plan to reconcile differences between the existing plan and the approved CTSP, and other actions that may be required to maintain consistency with the City’s adopted land use planning documents and implementing ordinances. Development standards for the CTSP area will be provided by the Specific Plan itself, in lieu of the Ceres Zoning Ordinance, which will apply to the CTSP area upon annexation. These actions are described in subsequent sections of this chapter.

The land use designations, improvement plans, guidelines and standards, and other provisions of the CTSP, which are described later in this chapter, will be the primary basis for City review and consideration of future development within the CTSP Area. These future actions would include review and approval of any tentative maps, site plan EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 3-6 November 2024 approvals, design review or other discretionary and non-discretionary approvals that would follow approval of the CTSP. The CTSP establishes the location, allowable types of development and the range of allowable development quantities for the CTSP Area. It is anticipated that the CTSP, if approved, will be adopted by City ordinance.

The potential environmental effects and mitigation measures needed to address the CTSP’s significant effects, and alternatives to the CTSP under CEQA, are reviewed in this EIR.

CEQA Guidelines Section 15182 provides an exemption for residential projects that conform to an adopted specific plan if that plan was the subject of an EIR. Pursuant to Section 15182, future residential projects that are consistent with the CTSP, and whose potential environmental effects are adequately addressed by the certified CTSP EIR, may be exempt from further CEQA review. The need for and scope of environmental review for future projects will be the responsibility of the City of Ceres; this discretion will be exercised on a project-by-project basis.

3.4.5 Tentative Subdivision Maps
The proposed project does not include a current request for City approval of tentative subdivision maps. However, it is anticipated that one or more tentative maps would be submitted in conjunction with future development of the CTSP Area; Tentative maps may also be submitted for vacant portions of the Pocket Area. All tentative subdivision maps would require approval by the Ceres Planning Commission, appealable to the Ceres City Council.

Future tentative maps for lands within the CTSP Area will be required to conform to the adopted CTSP. In the Pocket Area, new development would need to conform to the applicable Ceres General Plan and zoning standards.

Future tentative map approvals would generate the need for street and utility improvements, which would be attached to the approved tentative maps in the form of Conditions of Approval. To the degree that tentative maps for residential development implement and do not conflict with the CTSP, and are consistent with the EIR Project Description, the City of Ceres may determine that additional environmental review of these maps is not required.

3.4.6 Development Agreement
Development within the CTSP Area can be expected to include one or more requests for approval of a Development Agreement (DA) governing the relationship between the City and the project applicants. No DA content is defined at present; future DAs would outline the City and property owner(s) obligations and could be expected to address a variety of topics which may include variations in allowable land use types, development intensity and density, development standards, and other administrative and/or financial relationships that may need to be defined as the review of the CTSP and EIR proceed. DA content is generally outside the scope of this EIR. Development within the Pocket Area is not anticipated to require a DA.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 3-7 November 2024

3.4.7 Williamson Act Contract Cancellation
Three parcels within the CTSP Area are under existing Williamson Act contracts (see Chapter 5.0, Agricultural Resources). If these contracts are not canceled or have not had a Notice of Non-Renewal filed prior to annexation, the City of Ceres would automatically succeed to the County’s existing interest in the contracts.

To permit urban development of any Williamson Act parcels prior to expiration of the existing contracts, the property owner would need to apply for City approval of “immediate cancellation” of the contract, pursuant to Government Code Sections 51282 and 51284.

Alternatively, the property owner may file a Notice of Non-Renewal if planned development would not occur in the near future. Williamson Act contract cancellation and non-renewal, as well as potential environmental impacts associated with development of Williamson Act parcels, are discussed in Chapter 5.0, Agricultural Resources.

3.5 POTENTIAL DEVELOPMENT UNDER THE SPECIFIC PLAN
Approval of the CTSP and related approvals would entitle approximately 534.6 acres for urban development, subject to the development limitations, standards and described in the CTSP. The CTSP Land Use Summary provides for potential development of up to 2,392 single- and multi-family residential units and up to approximately 1.17-million square feet of new commercial development. The CTSP also defines approximately 42.4 acres of parks and open space and 3.4 acres of new public space in addition to the 74.1 acres of existing public space occupied by the existing school sites in the CTSP Area.

Table 3-2 summarizes the potential development within the CTSP Area, based on the CTSP Land Use Plan (see Figure 3-1A). These quantities will provide the basis for evaluation of potential environmental impacts in this EIR.

TABLE 3-2

COPPER TRAILS SPECIFIC PLAN

POTENTIAL DEVELOPMENT SUMMARY
Land Use Acres Dwelling Units
Building Square
Footage
Low-Density Residential 177.6 988 -
Medium-Density Residential 37.6 338 -
Medium High-Density Residential 16.8 336 -
High-Density Residential 30.8 730 -
Regional Commercial 106.5 - 1,169,586
Park/Open Space 42.4 - -
Community Facilities 3.4 - -
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 3-8 November 2024 Schools 74.1 - -
Major Roadway/Landscape Corridor 47.3 - -
TOTAL 534.6 2,392 1,169,586
As shown on the proposed Land Use Plan, primary circulation into and from the CTSP Area would be provided by existing roads in the CTSP Area; improvements to these roads will need to be made as needed to serve urban development; these requirements will be set as individual projects are brought to the City for approval. Overall anticipated major street improvements are shown on Figure 3-3. New streets would be installed where necessary to serve new development, along with buried infrastructure such as water and sewer lines, consistent with the adopted CTSP. Proposed vehicular circulation systems are intended to promote connectivity and travel convenience in the CTSP Area. Circulation improvements would also include pedestrian and bicycle facilities to promote walking, bicycling, and non-vehicular use, as illustrated on Figure 3-3.

Specific development standards and community design themes for planned land uses are defined in Chapter 9 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.

3.5.1 Specific Plan Land Uses
Residential
The Specific Plan Land Use Map (Figure 3-1A) provides for a mix of both employmentgenerating uses and residential neighborhoods. Residential neighborhoods, for the most part, would be located on lands west of Moffett Road. Higher-density residential areas would be located primarily along Moffett Road and East Redwood Road, near the planned Regional Commercial development area, while Low and Medium-Density neighborhoods would be located further west. Planned residential development would consist of the following:

Low Density Residential (up to 7.0 dwelling units per acre) Medium Density Residential (7.0-12.0 dwelling units per acre) Medium-High Density Residential (12.0-20.0 dwelling units per acre) High Density Residential (20.0-30.0 dwelling units per acre) This range of densities is projected to result in as many as 1,286 new single-family homes and 1,106 multifamily units, for a total of 2,392 dwelling units at CTSP buildout. This estimate assumes that 80% of the maximum possible housing units under proposed CTSP land use designations would be developed.

Regional Commercial
Planned non-residential development as proposed in the CTSP would consist primarily of Regional Commercial uses, located in an approximately 107-acre area east of Moffett Road and adjacent to and west of Mitchell Road. As described in the CTSP, the Regional EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 3-9 November 2024 Commercial land use designation provides for a broad range of retail goods and services, which is intended to serve both area residents and those from nearby communities.

Development can accommodate different types of commercial and service uses, including those that are oriented to highway travelers, those that serve as destination shopping centers, and those that provide goods for nearby residential neighborhoods. The types of uses envisioned for development of these parcels include “big-box” stores, national retailers, hotels, office buildings, entertainment venues, grocery stores, drug stores, gas stations, dining establishments, and service-type uses. Neighborhood-serving professional uses are also appropriate. Multi-family residential uses may be permitted if included as part of a mixed-use development project.

The CTSP states that no minimum lot area or lot width is required for the Regional Commercial designation. However, lot coverage shall be no greater than 50 percent, and the maximum building height is 65 feet. Minimum front/primary street landscape setback is 15 feet along public streets. Minimum side and rear setbacks are both 15 feet from the property line. Minimum interior separation between buildings is 20 feet.

Parks and Open Space
Planned City park lands, including recreational corridors, would be concentrated mainly along the southern and western boundaries of the CTSP Area. The CTSP proposes a sidewalk and open space corridor along the TID Lateral, considered the “greenbelt corridor” that provides for both recreation and for stormwater storage. The sidewalk would be eight feet wide and would be installed within a corridor 20 feet wide adjacent to the lateral. Landscaping would be planted on each side of the sidewalk, with one side approximately five feet wide and the other approximately seven feet wide. Adjacent to the sidewalk corridor, another corridor approximately 30 feet wide would be used for stormwater storage and treatment swales. Several small parks are planned along the TID lateral to provide both recreation activity areas for residents and visual screen for the watertreatment plant and major roadways. Consultation with TID on the design walkways, which are located within TID easements would be needed.

A total of five new various-sized neighborhood parks are planned throughout the CTSP.

The larger parks are designed to provide more active recreation such as multi-sport fields and large gathering spaces. The smaller parks are designed to include amenities for smaller neighborhood gatherings, water features and small turf areas. One new park of approximately 3.7 acres is proposed adjacent to and north of the existing Hidahl Elementary School. The CTSP also designates a plaza area of two acres at the intersection of Redwood Road and Moffett Road. The plaza is expected to be an open space area where public events may be held. Additional neighborhood parks would be provided within planned residential acres, consistent with City of Ceres standards for size and amenities.

The proposed project would include a trail system that will follow the project’s boundary and the major roads, providing non-vehicular transportation connections between the various land uses. The proposed trail system is intended to provide and encourage walkability within the CTSP Area.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 3-10 November 2024 Community Facilities
This designation applies to the use of land for major public facilities, such as fire stations and police substations. The CTSP proposes 3.4 acres for community facilities/public safety facilities (CF-PSF in Figure 3-1A). The CTSP shows two anticipated locations for future public uses in the area when they will be needed. In proximity to the CTSP’s most intensive residential and commercial uses, these sites can be utilized by the City to construct public safety facilities or other uses deemed necessary to augment public services. The location of these facilities remains flexible. Future decisions on the precise location of these facilities, in particular fire stations, will be dependent on ongoing discussions with the service providers and potentially on a standards of coverage study that would determine optimal facility locations to serve the planned development in the area (Darin Jesberg pers. comm.).

The distribution of responsibilities for fire protection among the agencies currently serving the CTSP and the proposed annexation area is currently under discussion. It is anticipated that service area boundaries will be adjusted at the completion of this process. These concerns will be discussed during the annexation process for the CTSP Area.

Schools
This designation covers the existing schools within the CTSP Area: Central Valley High School, Ceres Adult School, and Hidahl Elementary School. No changes to these existing land uses would occur with CTSP implementation.

3.5.2 Circulation
The CTSP proposes an open and interconnected circulation system for vehicles, bicyclists, and pedestrians that promotes connectivity and access to major focal points and public facilities, such as parks and schools. The CTSP defines the circulation concepts that provide for safe and convenient movement of residents and visitors throughout the CTSP Area. Circulation components include the proposed network of roadways, pedestrian/bicycle circulation, landscape easements and streetscape design. Figures 3-2 and 3-3 illustrate the proposed circulation plan for the CTSP Area, along with cross sections of proposed streets.

Primary vehicular access to the CTSP Area will be provided from SR 99 on the east. The State of California in coordination with Stanislaus County and the City is planning major improvements to the SR 99 interchange with East Service Road. While not fully designed, planning and design of the new interchange is expected to initiate in early 2025 and complete by the end of 2026.

Figure 3-2 depicts the proposed “backbone” street system for the CTSP Area. The proposed street system is centered on three roadways:
• Service Road would be improved from Blaker Road to Moffett Road. The segment from Blaker Road to east of Central Avenue would be widened from the existing three travel lanes and a center lane to four travel lanes and a center lane. Sidewalk would be installed on both sides of this segment, and a parking lane would be EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 3-11 November 2024 provided on the south side. On the segment from east of Central Avenue to Moffett Road, Service Road would be improved to four travel lanes and a center lane. A sidewalk and a parking lane would be provided on the south side of this segment.

On both segments, bicycle lanes would be installed on both sides of the road. • Blaker Road would be improved from Service Road to TID Lateral No. 2, with two travel lanes, a parking lane on the east side, and a bicycle lane on the west side. • Central Avenue would be improved to four travel lanes with a median island 14 feet in width. On both sides of Central Avenue, there would be a bicycle lane, a parking lane, a landscaping strip, and a sidewalk.

Existing roads such as Redwood Road and Moffett Road would be improved as interior collector streets, along with proposed new streets. Interior collector streets would have two travel lanes, along with a parking lane, a landscaping strip, and a sidewalk on both sides.

Some interior collector streets would also have a median island and bicycle lanes on both sides. These would include the improved Redwood Road and Moffett Road. Moffett Road south of Service Road may be considered for widening to four lanes to accommodate regional commercial and high-density residential traffic.

3.5.3 Utilities and Services
Chapter 7.0 of the CTSP provides a detailed description of utility improvements needed to service future urban development, summarized below.

Potable Water System
Potable water services would be provided by the City of Ceres through its water system.

Water pipelines would be extended to the CTSP Area from existing infrastructure in the City, typically installed in roadway corridors. The proposed on-site water distribution system would be designed as a looped system following major arterial and collector street alignments for a transmission main grid consisting of approximately 12-inch to 24-inch diameter mains. Significant water infrastructure projects include pipe extensions along Central Avenue, Moffett Road, Blaker Road, and East Redwood Road, pipe installations along the central, western, and commercial backbone streets (see Figure 3-5), and improvements along East Service Road.

With full buildout of the CTSP, on-site potable water infrastructure may require construction of groundwater wells, water storage tank(s), and similar facilities, sized and designed in accordance with the City of Ceres’ improvement standards. At least one water well and one water tank are anticipated to be constructed within the CTSP Area. Water would be supplied from the existing City well system, supplemented by surface water to be provided by the Regional Surface Water Supply Project.

Non-Potable Water
The CTSP proposes the installation of a non-potable water system. It is expected that this system would be used to provide irrigation water for parks and landscaped areas within the CTSP Area. Separate infrastructure, including pipeline, would be installed for the nonEXHIBIT B ITEM 13 Copper Trails Specific Plan and Annexation EIR 3-12 November 2024 potable water system. However, the infrastructure would be installed in the same locations as the potable water system facilities. The CTSP infrastructure plan anticipates the installation of landscape irrigation wells to supply the water.

Sanitary Sewer System
Sanitary sewer services would also be provided by the City of Ceres through its system.

Effluent generated by development in the CTSP would be directed to the Ceres Wastewater Treatment Plant (WWTP) for treatment. The WWTP is located west of the CTSP Area, south of Service Road and west of Blaker Road.

Wastewater flows would be directed to the WWTP by a network of pipes installed within street rights-of-way or easements. Sewage would be conveyed by both gravity lines and/or sewer force mains. As with water infrastructure, significant sanitary sewer infrastructure projects include pipe extensions along Central Avenue, Moffett Road, Blaker Road, and East Redwood Road, pipe installations along the central, western, and commercial backbone streets, and improvements along East Service Road. The site’s topography may require the installation of strategically placed on-site sewer lift stations for the force main sewer pipes.

Storm Drainage
Storm drainage services would be provided by the City of Ceres through its system.

Development of the CTSP Area would require installation of on-site drainage conveyance facilities, along with alteration of site topography in some areas to accommodate the proposed land uses while mitigating drainage impacts. Significant storm drainage infrastructure projects include the installation of facilities along Moffett Road, Blaker Road, and East Redwood Road, as well as along the central, western, and commercial backbone streets.

Drainage facilities would be sized to avoid increases in peak water flow rate and/or surface water elevation changes, both upstream and downstream, for up to and including the 24- hour, 50-year storm event. Further, stormwater retention will be provided to assure no impacts due to loss of stormwater storage capacity. Lastly, the CTSP would include onsite construction of stormwater quality treatment facilities. The City maintains its storm drainage system in accordance with State and Federal law. With full 100-year storm tailwater control, the City’s system is sufficient to ensure that water quality remains acceptable during collection and transfer.

Solid Waste
Solid waste collection is provided by Bertolotti Disposal, providing both residential and commercial services, as well as debris box services. Through the City’s franchise agreement, Bertolotti Disposal is responsible for collecting garbage, recyclables, organics, bulky items, and leaf and limb piles within the City limits. Material collected is transported to the Bertolotti Transfer Station located at 231 Flamingo Drive in Modesto, which receives waste from various cities in the area.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 3-13 November 2024 Regulated Utilities
Electrical, gas and communication services would be extended from existing facilities in or adjacent to the CTSP Area to new development as required. Utilities would be located within streets or within existing public utility easements or easements to be dedicated along street frontages. Except for electrical transmission lines, existing overhead electrical and communication facilities would be undergrounded.

3.5.4 Infrastructure Phasing
The CTSP provides for a comprehensively planned infrastructure system with coordinated construction of backbone facilities necessary to incrementally serve new development. A series of infrastructure construction phases are anticipated as the CTSP Area builds out over time.

The infrastructure requirements for each phase of development include all on-site backbone infrastructure and off-site facilities necessary for the buildout of each phase. These include roadways, water, sewer, storm drainage, dry utilities, parks and open spaces, and other public facilities and improvements. All in-tract water, sewer, storm drain, and dry utilities are to be installed as part of local project improvements.

This plan is intended to be implemented with flexibility to serve different areas of the CTSP based on market demand. The conceptual phasing plan is structured such that infrastructure improvements in each phase can support its respective development in compliance with City policies and standards, and that the development in each phase can support the costs of the required improvements. Infrastructure phases identified in the phasing plan may be modified at the discretion of the City, subject to any applicable criteria in approved Development Agreements.

3.6 POTENTIAL DEVELOPMENT IN THE POCKET AREA
Most of the Pocket Area has already been developed. No development plans have been prepared for lands in the Pocket Area. It is expected that any new development or redevelopment in this area would be consistent with the City zoning, including applicable development standards, that would take effect should annexation of the Pocket Area be approved. The planned development of the Pocket Area is shown in Table 3-1 above. All projects would be subject to City review, with the review process including any necessary CEQA environmental evaluation.

3.7 ENTITLEMENTS AND PERMITS
Table 3-3 identifies the approving authorities for all actions associated with the proposed project. The primary entitlement associated with the project is City approval of the CTSP.

The approval authority would rest with the Ceres City Council, based on recommendations from the Ceres Planning Commission. As noted, adoption of the CTSP would include a range of graphic and text amendments to the Ceres General Plan. Pre-zoning of the CTSP Area would occur with annexation, which is discussed below.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 3-14 November 2024 The CTSP would provide the planning framework for, and a regulatory tool governing, future development of the CTSP Area. The land use designations, infrastructure plans, development guidelines and standards, and other provisions of the CTSP would be the primary basis for City evaluation of future development proposals, including review and approval of tentative subdivision maps, site development plans, or other requests for City approval. The City anticipates that one or more DAs would be needed between the City and project applicants in conjunction with future development. Such agreements would need to be consistent with the CTSP.

CEQA requires that an EIR identify the principal discretionary actions under consideration in the EIR, as well as any other agency permits and approvals that may require consideration under CEQA. The principal discretionary permits and approvals required for the CTSP would be granted by the City of Ceres.

Permits and approvals from a number of other agencies may also be necessary in the course of implementing the CTSP and other aspects of the project. These other agencies are listed in Table 3-3. The most notable of them is the Stanislaus LAFCo, which has the authority to approve any proposed annexations to a city. The City of Ceres would submit an annexation application to LAFCo once the City approves other project-related actions. The annexation application would require submittal of a City Services Plan that demonstrates the financial capability of the City to provide adequate public services to the proposed annexation area. Also required is a Statement of Adequacy of Water Supplies and an Agricultural Land Conversion Statement that describes potential losses of agricultural lands. As noted, LAFCo would be a Responsible Agency under CEQA with respect to the CTSP and therefore would be expected to use this EIR in its decision-making process.

TABLE 3-3

REQUIRED PERMITS AND APPROVALS,

COPPER TRAILS SPECIFIC PLAN
Agency Permit/Approval
Ceres City Council Certify Final EIR
Adopt CEQA findings
Adopt Mitigation Monitoring Program
Approve Copper Trails Specific Plan
Approve Required General Plan Amendments
Approve Required Zoning Changes
Approve Development Agreements
Approve Tentative Subdivision Maps
Ceres Planning Commission Recommendations to City Council on the above items
Development Plans for new development
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 3-15 November 2024 Infrastructure Improvement Plans
Stanislaus Local Agency Formation
Commission
Approve annexation application
Accept City Services Plan, Agricultural Land
Statement, Statement of Availability of Water
Supply
Approve Ceres Fire Protection District
boundary adjustment
Regional Water Quality Control Board General Construction and MS4 Storm Water Permits for new development
Caltrans SR 99 encroachment permits
San Joaquin Valley Unified Air Pollution
Control District
Dust Control Plans
Indirect Source Rule Permits
Authority to Construct (if stationary sources)
Permit to Operate (if stationary sources)
Turlock Irrigation District Encroachment Permits
EXHIBIT B ITEM 13
Figure 3-1
A
BaseCamp Environmental PROPOSED LAND USE PLAN SOURCE: Wood Rodgers EXHIBIT B ITEM 13
Figure 3-1B
BaseCamp Environmental POCKET AREA PREZONING
SOURCE: Wood Rodgers
EXHIBIT B ITEM 13
Figure 3-2
BaseCamp Environmental TRANSPORTATION KEY MAP SOURCE: Wood Rodgers EXHIBIT B ITEM 13
BaseCamp
Figure 3-3
BaseCamp Environmental STREET SECTIONS
EXHIBIT B ITEM 13
BaseCamp
Figure 3-4
BaseCamp Environmental TRANSIT AND PEDESTRIAN CIRCULATION MDR
MDR
LDR
LDR
LDR

LDR LDR

LDR LDR
RC
RC
RC
RC
HDR
HDR
MHDR
MHDR
P/OS
P/OS
P/OS
P/OS
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P/OS CF CF
ES
ES/HS
MDR
HDR
P/OS
LEGEND
Preliminary StanRTA
Transit Route
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
LEGEND
12’ Multi-Use Path
8’ Multi-Use Path
8’ Sidewalk
5’ Sidewalk
On-Street Bike Lane
(Width Varies)
Gondring Road
UPRR
Service Road
Blaker Road
Mitchell Road
State Route 99
Mitchell Road
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
MDR
MDR
LDR
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LDR LDR

LDR LDR
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P/OS CF CF
ES
ES/HS
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HDR
P/OS
Bike and Pedestrian , Transit
Public Transit
EXHIBIT B ITEM 13
Figure 3-5
BaseCamp Environmental PROPOSED POTABLE WATER SYSTEM
12” 12” 12” 12”
12”
12”
12” 12”
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12” 16” 12”
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LEGEND
Existing Water Line
Planned Water Line
Existing Well & Tank
Planned Well
Planned Tank
W
W
Point of Connection
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
MDR
MDR
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P/OS CF CF
ES
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HDR
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EXHIBIT B ITEM 13
Figure 3-6
BaseCamp Environmental PROPOSED SANITARY SEWER SYSTEM
LEGEND
Existing Sewer Line
Planned Sewer Line
Existing Manhole
Direction of Flow (Existing Line)
Direction of Flow (Planned Line)
Planned Lift Station
Planned Manhole Point of Connection
15” 12” 18”
8”
8”
12”
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8” 8”
”21 ”01
8”
”01 ”8
8”
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18” 18”
”42 ”42
”21
42” 42”
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8”
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
MDR
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EXHIBIT B ITEM 13
Figure 3-7
BaseCamp Environmental PROPOSED NON-POTABLE WATER SYSTEM MDR
MDR
LDR
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LDR LDR

LDR LDR
RC
RC
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HDR
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P/OS CF CF
ES
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8” 8” 8”
8”
8”
8” 8”
12”
12”
W
W
W
LEGEND
Planned Non-Potable Water Line
W Planned Irrigation Well
Point of Connection
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
EXHIBIT B ITEM 13
Figure 3-8
BaseCamp Environmental PROPOSED STORM DRAINAGE SYSTEM
ES
(NOT

A PART)
ES/HS
(NOT A PART)
42”
48”
42”
42”
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42”
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48”
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54”
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30” 60” 60”
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36”
42” 42”
54”
24”
30”
24”
18” 18”
18” 18”
LEGEND
Planned Storm Drain Line
Planned Direction of Flow
Storm Drain Manhole
Park/Landscape
Basin
Outfall Structure
Point of Connection
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
Central Avenue
Gondring Road
E. Redwood Road
Moffett Road
UPRR
Service Road
Blaker Road
Lucas Road
Mitchell Road
State Route 99
Mitchell Road
Street B
Street A
Street C
MDR
HDR
MDR
LDR
LDR
LDR

LDR LDR

LDR LDR
RC
RC
RC
RC
HDR
HDR
MHDR
MHDR
P/OS
P/OS
P/OS
P/OS
P/OS
P/OS
CF CF
MDR
HDR
MDR
LDR
LDR
LDR

LDR LDR

LDR LDR
RC
RC
RC
RC
HDR
HDR
MHDR
MHDR
P/OS
P/OS
P/OS
P/OS
P/OS
P/OS
CF CF
MDR
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 4-1 November 2024

4.0 AESTHETICS
ENVIRONMENTAL SETTING
The City of Ceres is in the San Joaquin Valley, a predominantly level agricultural landscape that also includes substantial areas of urban development in cities located for the most part along the State Route (SR) 99 highway corridor, such as Bakersfield, Fresno, Merced, Turlock, Modesto and Stockton. Ceres abuts the City of Modesto along most of its northern boundary. Agricultural lands surround the City to the east, south, and west, although there is some developed land to the southeast of the City in the Keyes unincorporated community. The eastern, southern, and western edges of development in the city are relatively well defined, with areas developed with residential neighborhoods or community facilities adjacent to agricultural uses.

The topography throughout the area is almost completely level; there are no substantial hillsides providing natural raised vistas of its surroundings. Views over surrounding lands are, however, available from the SR 99 freeway overpasses at Whitmore, Hatch, Crows Landing roads. Mid-range views of farms with row crops and orchards are visible from ground level public roads in the urbanized city’s edges and from all the unincorporated areas within the City’s General Plan Planning Area. On clear days, the Sierra Nevada mountain range is visible to the east, and Mount Diablo and the surrounding foothills are visible to the west (City of Ceres 2018a).

Like many other cities in the San Joaquin Valley, Ceres is bisected by and gains its principal access from SR 99. Therefore, all of Ceres has close proximity to SR 99, and many visitors are introduced to Ceres from the freeway. Because development in the City is predominantly low-rise and changes in the elevation of SR 99 are minor, the views from the SR 99 corridor through the City are characterized by the tree buffer along the railroad and facades of directly adjacent development (City of Ceres 2018a).

The CTSP Area is currently a mix of agricultural, rural residential, and urban land uses.

The CTSP Area is predominantly agricultural and rural residential in its landscape; the area closest to of SR 99 provide views of orchards and grazing lands. Direct views of the CTSP Area are also available from the major existing public roads including Service Road, Blaker Road, Central Avenue, East Redwood Avenue, and smaller local roads. Substantial urban development has occurred along Central Avenue between Service Road and East Redwood Road, including Central Valley High School and the Ceres Adult School, and a mix of residential, agricultural, and commercial uses.

The Pocket Area north of Service Road is a predominantly urban landscape, with a mix of residential areas, commercial lots, and vacant land. Outside these two areas, agricultural and rural residential landscapes are more prominent. Existing public roads within the CTSP and Pocket Areas are minimally improved beyond provision of the necessary vehicle travel lanes. Many existing roads lack paved shoulders, and few if any have drainage improvements, curb and gutter or sidewalks.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 4-2 November 2024 Existing lighting in the CTSP vicinity is primarily concentrated in the existing developed areas north of Service Road. Along Service Road, streetlights have been installed along the frontage with Central Valley High School to the Central Avenue intersection. South of Service Road, lighting is mainly found at the schools, although its use most notably occurs during night sporting events at the high school football field. Outside the school areas, lighting is limited mainly to exterior lighting at rural residences. Another existing source is lighting is nighttime vehicle traffic on SR 99, but views of this lighting are confined to the areas adjacent to the roadway. The majority of lands within the CTSP Area are agricultural and unlighted.

REGULATORY FRAMEWORK
California Scenic Highway Program
California’s Scenic Highway Program was created by the Legislature in 1963 to preserve and protect scenic highway corridors from changes that would diminish the aesthetic value of lands adjacent to these highways. The State laws governing the Scenic Highway Program are in the California Streets and Highways Code, Section 260 et seq. A highway may be designated scenic based upon how much of the natural landscape can be seen by travelers, the scenic quality of the landscape, and the extent to which development intrudes upon the traveler’s enjoyment of the view.

The State Scenic Highway System includes a list of highways that are either designated as scenic highways or are eligible for designation. According to the California Department of Transportation (Caltrans) list of designated scenic highways under the California Scenic Highway Program, there is only one officially designated state scenic highway within Stanislaus County: Interstate 5 from the San Joaquin County Line to the Merced County Line in western Stanislaus County (Caltrans 2019); this roadway segment is more than 12 miles west of the CTSP Area.

Small Lot Design Guidelines
The Ceres Small Lot Design Guidelines were adopted in 2007 to provide builders with a clear set of design policies and to expedite the building permit review process. The Design Guidelines apply to single-family detached residential development on lots of 4,999 square feet or less, which can only occur in Planned Community zones. Small-lot housing is often more affordable than larger-lot development and easier to maintain. The guidelines are intended to provide for the following (City of Ceres 2007c):
• Small-lot, single-family projects that feature a variety of lot types, home sizes, housing types, designs and building materials,
• Small-lot, single-family developments that include interconnected, short blocks that diffuse traffic and provide easy, direct routes for pedestrians, bicyclists, and drivers around the neighborhood, and
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 4-3 November 2024 • Small-lot, single-family developments that emphasize pedestrian-oriented streetscapes, not dominated by garages and including street systems designed for pedestrians and bicyclists as well as for automobile use.

Ceres Municipal Code
Chapter 15.14, California Green Building Code
The City of Ceres has adopted the 2022 California Green Building Standards Code (California Code of Regulations, Title 24, Park 11) as Chapter 15.14 of the Municipal Code. The purpose of the California Green Building Standards Code (CALGreen) is to improve public health, safety, and general welfare by enhancing the design and construction of buildings through the use of building concepts having a reduced negative impact or positive environmental impact and encouraging sustainable construction practices. CALGreen includes both mandatory and voluntary measures for both residential and nonresidential development, including a nonresidential mandatory light pollution reduction measure that establishes maximum allowable light and glare standards for new nonresidential projects.

Section 17.26.080 Street Lights
Section 17.26.080 of the Ceres Municipal Code regulates streetlights. Streetlights shall be to the standard approved by the City Council. All light standards shall be placed at locations approved by the Community Development Director.

Section 18.42.240 Illumination
Section 18.42.240 of the Ceres Municipal Code regulates the illumination of signs. Direct or indirect lighting methods are allowed, provided they are not harsh, unnecessarily bright, and located or shielded to prevent glare to surrounding properties.

Section 18.40.040 Off-Street Loading Facilities
Section 18.40.040 of the Ceres Municipal Code regulates lighting in off-street loading facilities. If the loading area is illuminated, lighting shall be deflected away from adjacent uses so as to cause no annoying glare.

Section 18.38.060 Dangerous and Objectionable Elements
Section 18.38.060 of the Ceres Municipal Code establishes that every use shall be so operated that they do not emit direct or indirect glare in such quantities or degree so as to constitute a nuisance to adjacent or adjoining properties.

ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
Significance Thresholds
According to the CEQA Guidelines, a project will ordinarily have a significant effect on aesthetics and visual resources if it would:

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 4-4 November 2024 ● Have a substantial adverse effect on a scenic vista,
● Substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway, ● In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings; or, in an urbanized area, conflict with applicable zoning and other regulations governing scenic quality, or ● Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

A recent change to the Environmental Checklist in CEQA Guidelines Appendix G emphasizes aesthetic and visual resource impacts on public views in non-urbanized areas.

As defined in Appendix G, “public views” are views that are experienced from publicly accessible vantage points. Although not specifically defined, “publicly accessible vantage points” are assumed to include, though not necessarily limited to, public roads, parks, trails, and scenic vista turnouts. “Scenic vistas” are generally interpreted as long-range views of a specific scenic feature, such as open space lands, mountain ridges and open water.

Impact AES-1: Scenic Vistas
The topography of the Ceres area is almost completely level, providing no natural raised vistas of its surroundings. Because the city has maintained its status as a stand-alone urban area surrounded by agricultural uses, farms with row crops, livestock grazing and orchards are visible from ground level around the circumference of the urbanized city and from all areas in the unincorporated County land. On clear days, the Sierra Nevada mountain range is visible to the east, and Mount Diablo and the surrounding foothills are visible to the west (City of Ceres 2018a).

Land within the project site and surrounding area is similar topographically to the Ceres area. Some views over the CTSP Area are available from localized high spots and will become more available from westbound Service Road and the interchange transition ramps as the SR 99/Service Road interchange is constructed. Development within the project site, mainly within the CTSP Area, would have the potential to obstruct short-range views of farmland currently available to the public. These views could be partially or fully blocked in some public areas by new construction occurring beyond the current edge of development. However, what may be considered scenic vistas as defined above are already limited by existing urban development, particularly agricultural landscapes. The CTSP limits heights of multifamily residential buildings to no greater than 50 feet, and it designates multifamily development only at the intersection of Service Road and Moffett Road, and along East Redwood Road adjacent to the proposed regional commercial development. As such the potential obstruction of scenic vistas would be limited, and project impacts on scenic vistas would be less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 4-5 November 2024 Impact AES-2: Scenic Resources and Scenic Highways
As discussed in the previous section, development of the CTSP Area would result in the gradual conversion of existing agricultural open space to planned urban uses. However, there are no distinctive scenic resources located within the project site which would be threatened by planned development. The agricultural landscapes within the CTSP Area, while inherently attractive, are composed of features that are common in valley areas and would not result in a substantial adverse effect if the project site is developed. The GPEIR did not explicitly address this issue in its analysis of aesthetic impacts associated with the Ceres General Plan.

No outstanding scenic resources, such as tree groves or rock outcroppings, are on the project site. As noted, the only state scenic highway designated in Stanislaus County is Interstate 5. The project site is not located on or near Interstate 5. Neither the City nor Stanislaus County has designated any scenic highways. Project impacts on scenic resources and scenic highways would be less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
Impact AES-3: Visual Character and Quality
The project would not affect the visual character of the Pocket Area, which is already predominantly urban, developed under Stanislaus County jurisdiction. The project would not substantially change the existing visual landscape. Potential future development in the Pocket Area would be subject to City of Ceres design requirements and would not be expected to result in any substantial adverse effect on the visual landscape.

As has been indicated, adoption and implementation of the CTSP and planned urbanization of the CTSP Area can be expected to substantially change the visual landscape of the CTSP area. The CTSP Area currently contains a substantial agricultural landscape. Development pursuant to the CTSP would change the agricultural landscape to an urban landscape on a project-by-project basis., which would cumulatively be a significant aesthetic change. This loss of the agricultural landscape was addressed in the certified GPEIR relative to development of lands in accordance with the land use designations established by the General Plan 2035, and annexation of future urban land into the City. Impacts would be reduced with the implementation of General Plan policies such as prioritizing infill development, limiting development of agricultural lands only where contiguous to existing development, and developing a Plan for Agricultural Preservation upon application for annexation of agricultural land. Implementation of the CTSP would have no new or more severe impacts than those analyzed in the GPEIR. Therefore, as discussed in Section 1.2, no further consideration of this issue is required.

The CTSP is intended and expected to result in a cohesive and attractive urban development, with generally beneficial aesthetic effects. These effects would stem from actual development in accordance with the CTSP’s and City of Ceres land use and design guidelines and construction of the various open space areas. It also would integrate the EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 4-6 November 2024 existing two schools into a more coherent urban landscape, rather than remain isolated urban features in a mostly rural area.

Moreover, the CTSP design guidelines would improve the appearance and attractiveness of the permitted land uses, also contributing to beneficial aesthetic effects. Development of the CTSP Area as planned is expected to result in pleasing views that will have a beneficial or at least neutral impact on surrounding streets and adjacent land uses.

Proposed land uses would be visually compatible with urban land uses to the north. Future development projects in the CTSP Area would be subject to existing City review and design standards and guidelines as well as the more stringent requirements of the CTSP.

Planned urban development as envisioned in the CTSP will include the improvement of streets within and adjacent to project sites. These improvements would replace the minimally improved existing road system with landscaped corridors providing pedestrian and bicycle use separate from the roadway. Street improvements would include installation of landscaped medians on proposed Divider Collector Roads, Blaker Road and Central Avenue. Substantial streetside landscaping strips will be located along these roads as well as along Service Road and the Standard Collector Road. These improvements, together with the CTSP commercial and residential design requirements will result in a planned and organized aesthetic environment consistent with other areas of new development in the City of Ceres.

There is no known plan for the improvement of streets or other public facilities in the Pocket Area. Except for new development project that may require improvement of the adjacent street, streets in the Pocket Area will remain more or less in their current condition until an improvement plan is organized and funded.

In summary, while conversion of the existing largely agricultural visual landscape would occur, the resulting project development would be considered aesthetically pleasing with adherence to CTSP design guidelines and consistent with the Ceres General Plan. Overall, project impacts on visual character and quality would be less than significant and potentially beneficial.

Level of Significance: Less than significant
Mitigation Measures: None required
Impact AES-4: Light and Glare
The project would not involve substantial changes in lighting conditions in the Pocket Area. The Pocket Area is already substantially developed, and the project would not change existing conditions nor substantially alter future conditions in areas of existing development. New development on scattered parcels may result in new security lighting or new, or replacement, street lighting in selected areas; these improvements would contribute to the overall quality of development in the Pocket Area with no substantial adverse effect.

Development of the CTSP Area would involve additional night lighting sources. New sources would include high-intensity lighting of the proposed regional commercial development, including parking areas and signage. Signage could be expected to include EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 4-7 November 2024 one or more freeway-visible as well as monument, store advertisement and directional signs It can be expected that intersections surrounding the center will include additional width, signal control and enhanced lighting for night visibility and safety.

New residential areas would include new street lighting as well as varying levels of security and nightscape lighting. New multifamily residential development would likely involve architectural and decorative lighting, exterior lighting for individual units and security lighting in parking areas and common spaces. Lighting may also be installed in the park areas, depending on the amenities offered. Streetlights would be installed on streets in the developed areas per City standards. All this would contribute to a substantial increase in night lighting in the CTSP Area and would contribute to overall ambient light and nighttime sky glow effects.

The CTSP states that street lighting is required along all roadways and may vary in design and height based on a roadway’s size. Light fixture design, luminaries, specification, and installation are subject to the City’s adopted Improvement Standards and are subject to applicable regulations in the City of Ceres Municipal Code. As permitted by City standards, decorative street lighting that is consistently themed may be used on public streets in residential neighborhoods to maintain a cohesive design for the public realm. Where utilized, decorative fixtures are permitted on collector and residential streets. Decorative light fixtures are also encouraged on private streets within medium-high and high-density residential developments. In addition, development would comply with the lighting provisions of CALGreen. Compliance with these provisions would avoid significant light and glare effects on adjoining uses and reduce the potential impact of urban development on the night sky.

New development and associated lighting within the CTSP Area would involve generally minor effects on land uses outside the CTSP Area that could be light-sensitive. Urban land uses north of Service Road, which are already developed and have existing lighting, would likely notice little change in ambient lighting, particularly with a proposed open space corridor along Service Road acting as a buffer. Lands south and west of the CTSP Area are mostly agricultural fields that would not be affected by changes in lighting. CTSP Area development would not involve any substantial adverse effects on the SR 99 corridor to the east.

Scattered rural residences south of TID Lower Lateral 2 could experience changes in ambient lighting as a result of CTSP development. However, setbacks provided by the lateral right-of-way and the proposed open space corridor along the lateral, coupled with the City’s lighting requirements, would minimize the amount of lighting reaching these residences. A few residences west of Blaker Road may be subject to changes in ambient night lighting over time, especially with the anticipated addition of streetlights on the roadway. Compliance with the City’s street lighting requirements, along with a proposed open space corridor along Blaker Road, would minimize the amount of lighting reaching these residences.

In summary, the project would result in additional lighting, mainly in the CTSP Area.

However, compliance with City codes and CTSP standards would minimize potential EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 4-8 November 2024 lighting impacts. Therefore, project impacts related to light and glare would be less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
EXHIBIT B ITEM 13
Figure 2
BaseCamp Environmental Aerial Photo
EXHIBIT B ITEM 13
Figure 2
BaseCamp Environmental Aerial Photo
EXHIBIT B ITEM 13
Figure 2
BaseCamp Environmental Aerial Photo
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Figure 2
BaseCamp Environmental Aerial Photo
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 5-1 November 2024

5.0 AGRICULTURAL RESOURCES
ENVIRONMENTAL SETTING
Agriculture is an important part of the economy in Stanislaus County and the Central Valley. Approximately 75.5% of Stanislaus County’s land area was in farms and pasture as of 2017 (U.S. Department of Agriculture 2019). The County’s total gross value for agriculture production reached approximately $3.7 billion in 2022, an increase from approximately $3.5 billion in 2021. Stanislaus County ranked sixth in the state in agricultural production in 2022. The top five crops in 2022 were milk, almonds, poultry, cattle and calves, and fruit and nut nursery stock (Stanislaus County 2022).

As discussed in Chapter 4.0, Aesthetics, lands to the south, east, and west of Ceres are predominantly in agricultural land use. During the mid-19th century, the economy of Ceres was based on non-irrigated wheat farming, which later grew into a wider variety of crops after the introduction of irrigation to the area and formation of the TID. As of 2017, the majority of farmland in the City’s Planning Area is located outside of the Ceres city limits.

Most of the agricultural uses that are within the city limits are located west of Crows Landing Road and in the northeast of the City near Faith Home Road (City of Ceres 2018a); neither of these areas are within the project site. Agricultural lands within the CTSP Area are south of Service Road; lands in the Pocket Area are predominantly developed. CTSP Area agricultural lands livestock grazing lands and orchards.

Agricultural resources and the loss of agricultural land are issues that have been addressed in the Ceres General Plan and GPEIR. Over the life of the General Plan, which also includes planned urbanization of the CTSP Area, buildout would involve the conversion of 3,508 acres of Farmland, the majority of which is classified as Prime Farmland. This was identified as a significant and unavoidable impact of urbanization and accepted in a Statement of Overriding Considerations adopted in conjunction with the City’s adoption of the General Plan.

The Environmental Checklist in CEQA Guidelines Appendix G includes questions on forest lands in the Agricultural Resources section. Forest lands include National Forest lands, State forests, and private lands zoned for timber production. There are no forest lands or timberlands located in or near the City of Ceres. Because of this, the proposed project would not affect forestry resources, and this issue will not be discussed further in this EIR.

Important Farmland
The California Department of Conservation Important Farmland Maps for Stanislaus County categorize agricultural land in decreasing order of importance as "Prime Farmland," "Farmland of Statewide Importance," "Unique Farmland," "Farmland of Local Importance" and “Grazing Land.” The first three categories listed are considered Farmland as defined in CEQA Guidelines Appendix G; under CEQA, conversion of substantial amounts of “Farmland” may involve a significant environmental effect.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 5-2 November 2024 In Stanislaus County, total agricultural land as followed by the California Department of Conservation decreased by 14,682 acres from 2004 to 2020. Most of the decrease was in grazing land, which decreased by 47,567 acres. Among the three Farmland categories, Prime Farmland decreased by 12,051 acres; however, Farmland of Statewide Importance increased by 3,414 acres, and Unique Farmland increased by 54,071 acres. Farmland of Local Importance, which is not Farmland as defined by CEQA Guidelines Appendix G, decreased by 12,549 acres (FMMP 2020).

Figure 5-1 identifies Important Farmland on the project site. Lands in the CTSP Area that are defined as Farmland are designated primarily as Prime Farmland, which includes lands with the best combination of physical and chemical characteristics able to sustain longterm production of agriculture crops. A substantially smaller land area is designated Farmland of Statewide Importance, which includes lands that are not Prime Farmland but have a good combination of physical and chemical characteristics for agriculture production (FMMP 2018). Farmland acreages within the CTSP Area are as follows:
• Prime Farmland (approximately 309 acres)
• Farmland of Statewide Importance (approximately 10.5 acres) Other portions of the CTSP Area are not classified as Farmland. These include the following (FMMP 2018):
• Semi-Agricultural and Rural Commercial Land - lands which are suitable for agricultural storage and packing sheds, equine facilities, and other similar uses. • Rural Residential Land - includes residential areas of one to five structures per ten acres.
• Urban and Built-Up Land - occupied by structures with a building density of at least 1 unit to 1.5 acres, or approximately 6 structures to a 10-acre parcel.

Lands so designated in the CTSP Area include Central Valley High School, Ceres Adult School and Hidahl Elementary School, rural residential areas near the intersection of Central Avenue and East Redwood Avenue, and the Ceres Sports Arena in the southeastern area.

As noted, lands in the Pocket Area are predominantly developed. There is no Farmland in this area; lands are classified as Urban and Built-Up Land, Rural Residential Land, and Vacant or Disturbed Land, the latter including open field areas that do not qualify for an agricultural category (FMMP 2018).

LAFCo Prime Agricultural Lands
In processing annexation applications, the LAFCo evaluates potential impacts on “prime agricultural land” as defined in the Cortese-Knox-Hertzberg Act, which sets forth procedures for annexations. The Cortese-Knox-Hertzberg Act provides the following definitions of prime agricultural land:

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 5-3 November 2024 • Land that qualifies, if irrigated, for rating as Class 1 or Class 2 in the Natural Resources Conservation Service land use capability classification, whether or not land is actually irrigated, provided that irrigation is feasible. • Land that qualifies for 80 through 100 Storie Index Rating. • Land that supports livestock used for the production of food and fiber and that has an annual carrying capacity equivalent to at least one animal unit per acre as defined by the U.S. Department of Agriculture in the National Range and Pasture Handbook, Revision 1, December 2003.
• Land planted with fruit or nut-bearing trees, vines, bushes, or crops that have a nonbearing period of less than five years and that will return during the commercial bearing period on an annual basis from the production of unprocessed agricultural plant production not less than $400 per acre.
• Land that has returned from the production of unprocessed agricultural plant products an annual gross value of not less than $400 per acre for three of the previous five calendar years.

As described in more detail in Chapter 9.0, Geology, the project site has eight types of soil (see Table 9-1). Of these eight soil types, five are rated as Class 1 or Class 2: two types of Dinuba sandy loam, and three types of Hanford sandy loam. These five soil types are Class 1 or Class 2 soils when irrigated (SCS 1964). The portions of the project site containing these soils are considered to have prime agricultural land as defined by the Cortese-KnoxHertzberg Act. This land would be the subject of further analysis in the annexation application to LAFCo.

REGULATORY FRAMEWORK
Williamson Act
The Land Conservation Act of 1965, commonly known as the Williamson Act, was enacted to help preserve farmland in California. Under the Williamson Act, a contract is executed between landowners and local governments to voluntarily restrict development on property for a period of 10 years in exchange for lower property tax assessments based on the existing agricultural land use. The State formerly provided subvention payments to participating counties to offset reductions in property tax revenues, but these payments have been discontinued.

Contracts are entered into for a 10-year period and can be terminated only by non-renewal of the contract or by a cancellation process defined in the California Government Code.

The non-renewal process takes 10 years to complete from the date the Notice of Nonrenewal is submitted to the County. Cancellation of a Williamson Act contract takes effect immediately upon approval of the cancellation by the County Board of Supervisors.

However, the cancellation requires a public hearing, and the Board of Supervisors must make either of these findings consistent with State law: 1) the cancellation is consistent with the purposes of the Williamson Act, or 2) the cancellation is in the public interest. A non-renewal does not require a public hearing or findings.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 5-4 November 2024 In 2023, Stanislaus County had approximately 286,350 acres of prime agricultural land and 337,359 acres of non-prime agricultural land under Williamson Act contracts. The total acreage has remained fairly steady from year to year (John Silva pers. comm.).

The number of parcels within the project site under a Williamson Act contract were identified using the California Williamson Act Enrollment Finder database, managed by the California Department of Conservation. The database, in turn, receives data from counties that participate in the Williamson Act program. The most recent information from Stanislaus County is from 2022. Table 5-1 shows the three parcels within the project site that are under a Williamson Act contract. The total acres under contract are 67.78 acres.

TABLE 5-1

WILLIAMSON ACT PARCELS IN PROJECT SITE
APN Address Acres
041-010-007 6055 Central Avenue 19.0
041-010-008 4342 Central Avenue 38.0
041-010-015 2219 E. Redwood Avenue 10.78
Source: California Department of Conservation 2023.

Stanislaus LAFCo Agricultural Preservation Policy
The Stanislaus LAFCo, in its Policies and Procedures, contains an Agricultural Preservation Policy (Stanislaus LAFCo 2020). The goals of the Agricultural Preservation Policy are as follows:
• Guide development away from agricultural lands where possible and encourage efficient development of existing vacant lands and infill properties within an agency’s boundaries prior to conversion of additional agricultural lands. • Fully consider the impacts a proposal will have on existing agricultural lands. • Minimize the conversion of agricultural land to other uses. • Promote preservation of agricultural lands for continued agricultural uses while balancing the need for planned, orderly development and the efficient provision of services.

Upon application for annexation to a city providing one or more urban services that includes agricultural lands, a Plan for Agricultural Preservation must be provided to LAFCo with the application. The purpose of a Plan for Agricultural Preservation is to assist LAFCo in determining how a proposal meets the stated goals of the Agricultural Preservation Policy. The plan shall include the following:
• A detailed analysis of direct and indirect impacts to agricultural resources.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 5-5 November 2024 • A vacant land inventory and absorption study evaluating lands within the existing boundaries of the jurisdiction that could be developed for the same or similar uses. • Existing and proposed densities (persons per acre).
• Relevant county and city General Plan policies and specific plans. • Consistency with regional planning efforts (e.g., the San Joaquin Valley Blueprint and the Sustainable Communities Strategy).
• An analysis of mitigation measures that could offset impacts to agricultural resources.

The Plan for Agricultural Preservation shall specify the method or strategy proposed to minimize the loss of agricultural lands. LAFCo encourages the use of strategies such as an adopted policy or condition requiring agricultural mitigation at a ratio of at least 1:1. This can be achieved by acquisition and dedication of agricultural land, development rights and/or conservation easements to permanently protect agricultural land, or payment of inlieu fees to an established, qualified, mitigation program to fully fund the acquisition and maintenance of such agricultural land, development rights or easements (Stanislaus LAFCo 2020).

LAFCO may consider approval of an annexation containing agricultural land if the Plan for Agricultural Preservation demonstrates that insufficient alternative land is available within the existing SOI or boundaries of the agency and, where possible, growth has been directed away from prime farmland towards soils of lesser quality; that the development for an annexation proposal is imminent for all or a substantial portion of the proposal area; that the loss of agricultural lands has been minimized based on the selected agricultural preservation strategy; and that the proposal would result in planned, orderly, and efficient use of land and services. Since the LAFCO Agricultural Preservation Policy was adopted in 2012 and amended in 2015, the City has not had an occasion to adopt a Plan for Agricultural Preservation (City of Ceres 2018a).

ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
Significance Thresholds
According to Appendix G of the CEQA Guidelines, a project may have a significant impact on agricultural resources if it would:
● Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program, to non-agricultural use,
● Conflict with existing zoning for agricultural use or a Williamson Act contract, or ● Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 5-6 November 2024 CEQA Guidelines Appendix G contains two questions in the Agricultural Resources section of the Environmental Checklist related to forest lands and conflicts with zoning for timber production. There are no forest lands on the project site or in the Ceres area, and no lands have been zoned for timber production. Therefore, forest land issues will not be discussed further in this EIR.

Impact AG-1: Conversion of Farmland
Adoption of the CTSP can be expected to further the urban development of the CTSP Area, eventually resulting in the irreversible conversion of all its agricultural acreage to urban or other non-agricultural uses. Approximately 60% of the CTSP Area is Prime Farmland and Farmland of Statewide Importance. Provided that all potential development occurs as a result of adopting the CTSP, there would be an irreversible loss of approximately 319.5 acres of Farmland that is suitable for a variety of agricultural uses, and of the natural resource values represented by this farmland. As noted, the Pocket Area does not include any Farmland.

Agricultural resources and the loss of agricultural land is an issue that was addressed in the current Ceres General Plan and its GPEIR, as well as in prior General Plans and CEQA documents. Buildout of the CTSP Area would contribute to the projected conversion of agricultural land to urban uses accounted for in prior CEQA documents. The GPEIR identified several applicable General Plan policies that could reduce conversion of agricultural lands, such as prioritizing infill development, allowing development on, agricultural lands only where contiguous to existing urban development, and ensuring that development and the expansion of infrastructure in urban areas do not encourage the expansion of urban uses into areas designated for Agriculture on the Land Use Diagram.

Another policy minimizes the loss of agricultural lands by developing the LAFCo-required Plan for Agricultural Preservation.

Despite these policies and actions, the GPEIR concluded that agricultural land conversion impacts would be significant and unavoidable. A Statement of Overriding Considerations for this issue was adopted by the Ceres City Council in conjunction with adoption of the General Plan. CEQA Guidelines Section 15152(d) states that, where an EIR has been prepared and certified for a plan, any lead agency for a later project pursuant to or consistent with the plan should limit the project EIR or negative declaration to effects which were not examined as significant effects on the environment in the prior EIR, or are susceptible to substantial reduction or avoidance by the choice of specific revisions in the project, by the imposition of conditions, or other means.

The project would not introduce any new impacts related to conversion of Farmland, nor would it increase the severity of Farmland conversion beyond that described in the GPEIR.

As part of any application for annexation that includes agricultural lands, which would include the project, the Stanislaus LAFCo requires the preparation of a Plan for Agricultural Preservation that includes an analysis of mitigation measures that could offset impacts to agricultural land and a strategy to minimize the loss of agricultural lands, such as an urban growth boundary or agricultural mitigation policy. This requirement is consistent with Ceres General Plan Policy 4.A.7. Based on this, project impacts are expected to be consistent with the analysis and conclusions in the GPEIR, which were that, EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 5-7 November 2024 even with adoption of the Plan for Agricultural Preservation, impacts would be significant and unavoidable.

Although these conditions would apply to the project, preparation of a Plan for Agricultural Preservation is required as mitigation below in order to reduce Farmland conversion impacts. This measure comes from the EIR prepared for the Whitmore Ranch Specific Plan that was adopted by the City. Although the mitigation measure has the potential to reduce impacts, project impacts on Farmland conversion are still considered significant and unavoidable.

Level of Significance: Significant
Mitigation Measures:

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 Plan for Agricultural Preservation, as adopted by Stanislaus LAFCO in accordance with LAFCO Policy 22.

Significance After Mitigation: Significant and unavoidable. Previously addressed in Ceres General Plan EIR.

Impact AG-2: Conflict Between Agricultural and Urban Land Uses Intensive agricultural operations adjacent or close to urban development can result in use conflicts. These conflicts can result from agricultural practices that generate complaints and result in limits on these practices, such as dust generated during cultivation, smoke during burning, noise during harvesting operations, and drift from pesticide applications.

These potential conflicts are predominantly associated with the juxtaposition of agricultural and residential areas. Such juxtapositions could occur during a gradual (project-by-project) development of the CTSP Area, in which development could be placed adjacent to existing agricultural lands.

Stanislaus County has a "Right to Farm" ordinance, which prevents an existing agricultural operation using standard farming practices from being considered a nuisance by later adjoining uses. This protects farmers from attempts by nearby residents to curtail agricultural activities. The City has not enacted a Right to Farm ordinance; however, General Plan Policy 4.A.6 supports the County’s Right to Farm ordinance.

Also, Policy 4.A.5 of the City’s General Plan seeks to ensure that new development adjacent to agricultural uses is compatible with the continuation of the agricultural uses by minimizing conflicts through appropriate design criteria, such as site layout, landscaping, EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 5-8 November 2024 and buffers to provide adequate separation between habitable structures and active farmland.

The CTSP Area would be separated from agricultural lands to the south by TID Lower Lateral 2. A 50-foot landscape buffer would be placed between the lateral and adjacent residential lots to the north, while the lateral and its right-of-way would add another 50 feet of buffer area. Thus, the proposed open space and the TID lateral right-of-way provide an effective buffer between CTSP urban uses and continuing agricultural uses to the south, limiting by distance the potential for noise, air quality, and other impacts.

Based on the above discussion, project impacts related to conflicts between agricultural and urban land uses would be less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
Impact AG-3: Conflicts with Agricultural Zoning and Williamson Act Contracts As discussed in more detail in Chapter 13.0, Land Use, land within the Pocket Area is zoned for non-agricultural land uses. However, substantial areas within the CTSP Area are zoned for agricultural uses; existing zoning was applied by Stanislaus County in years past.

City adoption of the CTSP would nullify the existing County zoning upon annexation of the CTSP Area to the City; although development proposed under the CTSP would conflict with the County’s existing agricultural zoning, No conflict would exist with CTSP approval.

All the land within the project site is designated for urban development by the adopted Ceres General Plan. It is expected that, as part of the annexation application to the Stanislaus LAFCo, the City would pre-zone the project site consistent with the land use designations of the Ceres General Plan or the CTSP, whichever is applicable. The prezoning would eliminate agricultural zoning, as no agricultural uses are planned. Upon annexation of the project site, no conflict with agricultural zoning would remain.

As previously discussed, there are three parcels within the project site, totaling 67.78 acres, that are under Williamson Act contracts. Planned urban development would conflict with the purpose of the Williamson Act contracts. Williamson Act contracts at the time of annexation would remain in place, and the City would succeed to the County’s interest in the contracts. Prior to development, contracts on lands subject to Williamson Act contracts would either need to expire by non-renewal or would need to be canceled by the City subject to Government Code requirements, including consistency with immediate cancellation criteria, prior to development. This need would be met during City processing of development applications. Potential inconsistency with Williamson Act contracts is considered a potentially significant environmental effect.

Level of Significance: Potentially significant
Mitigation Measures:

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 EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 5-9 November 2024 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.

Significance After Mitigation: Less than significant
Impact AG-4: Indirect Agricultural Land Conversion
Urban development can result in indirect impacts that exert pressure on agricultural lands to convert to non-agricultural use. Such indirect impacts can include the division of large tracts of continuous agricultural land into smaller, less agriculturally viable tracts; increases in land values and taxes that exert pressure on agricultural landowners to convert to urban uses; and loss of agricultural support infrastructure, such as processing facilities. In addition, urban growth may increasingly compete with agriculture for the use of water resources, and it may conflict with operational use of area roadways (City of Ceres 2018a).

The annexation and subsequent development of the project site could exert pressure on nearby agricultural lands that may lead to their conversion to non-agricultural uses in the long term. Policies in the Ceres General Plan would serve to reduce impacts by limiting the expansion of urban uses into areas designated for agriculture (Policy 4.A.2); requiring compatibility between new development and adjacent agricultural uses (Policy 4.A.5); maintaining connections between agricultural lands and supporting uses (Policy 4.A.9); and supporting the local agricultural economy (Policy 4.A.11). As has been discussed above, the CTSP Area is designated for urban uses. The TID Lower Lateral 2 and setbacks from this facility would provide a buffer between proposed urban development and remaining agricultural uses to the south of the CTSP Area. Urban development outside of the CTSP Area would be discouraged by existing City and County planning requirements.

Lands outside the CTSP Area are within the City’s Sphere of Influence and new development proposals would be subject to City review and comment. Further urbanization would require annexation of new urban development areas to the City. Agricultural land outside the CTSP Area would remain under the jurisdiction of Stanislaus County. The Stanislaus County Code contains provisions that would reduce the potential for nuisance complaints and the siting of incompatible uses, thereby reducing conversion pressures.

Irrigation water is available within the CTSP Area from existing TID irrigation laterals as well as from individual irrigation wells. Continued urbanization of the CTSP Area would result in conversion of agricultural lands, eventually eliminating the need for agricultural irrigation. The TID irrigation system is, however, located within easements and other rights that will ensure that these facilities are not directly or adversely impacted by new development. As demands change, local demand on the existing laterals for irrigation EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 5-10 November 2024 water within the CTSP Area can be expected to be reduced. As this occurs, the TID will consider the needs of agriculture within and near the CTSP Area together with exercise and preservation of its water rights, regional water demands and other factors and determine if existing laterals would be kept in service, which would be in TID’s sole discretion.

In summary, the CTSP and existing City and County planning requirements are structured, and would be implemented, such that pressures to indirectly convert farmland would be reduced. Nevertheless, the Ceres General Plan EIR stated that existing and proposed policies would not eliminate the indirect impacts that could result in agricultural conversion. The expansion of non-agricultural uses to adjacent lands could exert development pressures that could lead to conversion. Additionally, General Plan buildout would also reduce the connectivity of agricultural lands along the southern portion of the Planning Area, and intensification of development near agricultural operations could lead to traffic conflicts along roadways used by agricultural vehicles. Therefore, the GPEIR considered the impact significant and unavoidable (City of Ceres 2018a). As the proposed project would have similar impacts to those of the General Plan, the CTSP’s impacts are likewise considered significant and unavoidable.

Level of Significance: Significant and unavoidable
Mitigation Measures: None feasible
EXHIBIT B ITEM 13
Figure 5-1
BaseCamp Environmental IMPORTANT FARMLAND MAP

PROJECT AREA
EXHIBIT B ITEM 13
Figure 5-2
BaseCamp Environmental WILLIAMSON ACT LANDS

POCKET AREA

SPECIFIC PLAN AREA
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-1 November 2024

6.0 AIR QUALITY
This chapter analyzes impacts of CTSP adoption and implementation on air quality, specifically as they relate to pollutants regulated by federal and California Clean Air Acts.

Greenhouse gases (GHGs), gases that trap heat generated by the sun, are regulated separately from other air pollutants. Chapter 10.0, Greenhouse Gas Emissions, discusses the GHG regulatory framework and the potential environmental impacts of the project as they relate to GHG emissions.

ENVIRONMENTAL SETTING
The project site is located within the northern portion of the San Joaquin Valley Air Basin.

The Air Basin is bounded generally by the Coast Ranges to the west and the Sierra Nevada and foothills to the east. The prevailing winds are from the west and north, a result of marine breezes that enter the Air Basin primarily through the Carquinez Strait but also through the Altamont Pass. Surrounding topography results in weak air flow, which makes the Air Basin highly susceptible to pollutant accumulation over time. Summers are hot and dry, and winters are cool. Most of the annual precipitation falls from November through April. The Air Basin enjoys more than 260 days of sunshine annually, but the amount of sunshine is reduced during the winter months. Inversions occur frequently during fall and early winter (SJVAPCD 2015).

On some days, pollutants transported from the Bay Area impact the northern San Joaquin Valley, mixing with local emissions to contribute to State and federal violations at Stockton and Modesto. Under certain conditions, pollutants from the San Joaquin Valley can be transported to Sacramento, and the Delta breeze typically carries polluted air from the valley to the Sierra Nevada and eastern foothills. Air Basin pollution can also significantly affect the Great Basin, Mojave Desert, and central California coast areas (ARB 2001).

Air Pollutants
Pollutants of concern for development projects typically include ozone, particulate matter, and carbon monoxide. Pollutants of concern for industrial and warehouse projects also include what are called “toxic air contaminants” (TACs).

In 2016, approximately 1,017 tons of ROG and 218 tons of NOx were emitted each day from sources in the San Joaquin Valley Air Basin. Approximately 316 tons of PM10, of which approximately 103 tons were PM2.5, were emitted daily. Areawide sources account for most of the ROG emissions; major sources include farming operations, solvent evaporation, cleaning and surface coatings, and waste disposal. Major sources of PM10 emissions are also areawide; these include farming operations, road and fugitive windblown dust, and wildfires. Most of the NOx emissions were caused primarily by motor vehicles. Wildfires were a major source of CO emissions in 2019, along with mobile sources (ARB 2020a).

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-2 November 2024 Ozone
Ozone is not directly produced; rather, it is the result of emissions of reactive organic gases (ROG) and nitrogen oxides (NOx) reacting in the presence of sunlight. ROG and NOx are referred to as “ozone precursors.” Motor vehicle emissions represent the principal source of ozone precursors. To control ozone pollution, it is necessary to control emissions of ROG and NOx.

High concentrations of ground-level ozone can adversely affect the human respiratory system and aggravate cardiovascular disease and many respiratory ailments. More specifically, ground-level ozone may:
● Make it more difficult to breathe deeply and vigorously. ● Cause shortness of breath, and pain when taking a deep breath. ● Cause coughing and sore or scratchy throat.
● Inflame and damage the airways.
● Aggravate lung diseases such as asthma, emphysema, and chronic bronchitis. ● Increase the frequency of asthma attacks.
● Make the lungs more susceptible to infection.
● Continue to damage the lungs even when the symptoms have disappeared. ● Cause chronic obstructive pulmonary disease.

People most at risk from breathing air containing ozone include people with asthma, children, older adults, and people who are active outdoors, especially outdoor workers. In addition, people with certain genetic characteristics, and people with reduced intake of certain nutrients, such as vitamins C and E, are at greater risk from ozone exposure (EPA 2018a).

Particulate Matter
Particulate matter includes any solid matter suspended in air. Standards are applied to particulates 10 micrometers in diameter or less (PM10), because these particles, when inhaled, are not filtered out prior to reaching the lungs, where they can aggravate respiratory diseases. Particulates originate from automobile traffic, urban construction, grading, farm tilling, and other activities that expose soil and dust. Dry summer conditions and daily winds can increase particulate concentrations. Numerous scientific studies have linked particle pollution exposure to a variety of problems, including:
● premature death in people with heart or lung disease
● nonfatal heart attacks
● irregular heartbeat
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-3 November 2024 ● aggravated asthma
● decreased lung function
● increased respiratory symptoms, such as irritation of the airways, coughing or difficulty breathing.

People with heart or lung diseases, children, and older adults are the most likely to be affected by particle pollution exposure (EPA 2018b).

Separate standards have been established for particulate matter that is 2.5 micrometers or less in size (PM2.5), sometimes referred to as “fine particulate matter.” The PM2.5 standards reflect health concerns related to respiration of smaller particles, which can go deeper into the lungs than larger particulate matter. Fine particulates include sulfates, nitrates, organics, ammonium, and lead compounds originating from activities in urban areas.

Carbon Monoxide
Carbon monoxide (CO) is an odorless, colorless gas that is highly toxic. It is formed by the incomplete combustion of fuels. The main source of CO in the San Joaquin Valley is onroad motor vehicles. Other CO sources in the Valley include other mobile sources, miscellaneous processes, and fuel combustion from stationary sources. Because of its ability to readily combine with hemoglobin and displace oxygen in the human body, high levels of CO can affect human health, causing fatigue, headache, confusion, and dizziness, especially for elderly people or individuals with respiratory ailments.

Toxic Air Contaminants (TACs)
TACs are air pollutants that cause or may cause short-term (acute) or long-term (chronic) adverse health effects. These health effects may include cancer, birth defects, neurological and reproductive disorders, or chronic eye, lung, or skin irritation. TACs also may cause adverse environmental and ecological effects. The State’s Air Toxics Inventory includes more than 250 substances considered TACs (ARB 2008a). They include such substances as chlorinated hydrocarbons, asbestos, dioxin, toluene, gasoline engine exhaust, particulate matter emitted by diesel engines, and metals such as cadmium, mercury, chromium, and lead compounds, among many others.

Most TACs are emitted by specialized industrial processes and are therefore uncommon.

However, they may also be emitted from a variety of common sources such as gasoline stations, automobiles, diesel engines, dry cleaners, and painting operations. Diesel particulate matter (DPM), emitted from diesel engines, is of special concern because it is present at some concentration in all developed areas of the state. DPM is designated by the State of California as a TAC, as it is a potential source of both cancer and non-cancer health effects. The California Air Resources Board (ARB) has identified DPM as a major contributor to ambient cancer risk levels; while it accounts for only about 4% of air toxic emissions in the state, it is associated with more than 70% of the 2000 cancer risk associated with outdoor ambient levels of all TACs. General risks can be elevated with proximity to the source, which for DPM includes freeways, ports and railyards, and distribution centers (ARB 2005). California has adopted and is implementing a number of EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-4 November 2024 aggressive toxic air contaminant control programs; these are discussed in more detail in the following Regulatory Framework section.

County Emissions Inventory
Table 6-1 shows the most recent information available on criteria pollutant emissions generated in Stanislaus County. These include emissions from stationary sources such as industrial processes and cleaning and surface coating activities, areawide sources such as solvent evaporation, mobile sources, and natural sources.

TABLE 6-1
AIR POLLUTANT EMISSIONS IN STANISLAUS COUNTY, 2017
Emission Source
Emissions (tons/day)
ROG NOx CO SOx PM10 PM2.5
Stationary Sources 9.39 2.79 1.14 0.81 1.47 0.76
Areawide Sources 19.25 1.11 8.17 0.04 25.64 4.94
Mobile Sources 8.62 18.40 60.39 0.07 1.43 0.95
Natural Sources 29.42 0.80 0.62 0.01 0.06 0.05
TOTAL 66.67 23.10 70.32 0.92 28.60 6.70
Totals may be affected by rounding.

Source: ARB 2017.

REGULATORY FRAMEWORK
Federal Clean Air Act
Federal air quality regulation stems from the Clean Air Act, as amended. The Clean Air Act requires the U.S. Environmental Protection Agency (EPA) to establish air quality standards for criteria pollutants, known as the National Ambient Air Quality Standards, as shown in Table 6-2. There are six criteria pollutants: ozone, carbon monoxide, particulate matter, nitrogen dioxide, lead, and sulfur dioxide. Two types of National Ambient Air Quality Standards are established:
● Primary standards to protect human health, based on EPA medical research and specific concentration thresholds derived therefrom; and ● Secondary standards to protect the public welfare from effects such as visibility reduction, soiling, nuisance, and other forms of damage.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-5 November 2024 TABLE 6-2

NATIONAL AND CALIFORNIA AMBIENT AIR QUALITY STANDARDS
Air Pollutant
Averaging
Time
California
Standards
Primary
National
Standards1
Secondary
National
Standards2
Ozone 1 Hour 0.090 ppm -- --
8 Hour 0.070 ppm 0.070 ppm 0.070 ppm
PM10 24 Hour 50 μg/m3 150 μg/m3 150 μg/m3
Annual Mean 20 μg/m3 -- --
PM2.5 24 Hour -- 35 μg/m3 35 μg/m3
Annual Mean 12 μg/m3 12 μg/m3 15 μg/m3
Carbon Monoxide 1 Hour 20 ppm 35 ppm --
8 Hour 9 ppm 9 ppm --
Nitrogen Dioxide 1 Hour 0.18 ppm 100 ppb --
Annual Mean 0.030 ppm 0.053 ppm 0.053 ppm
Sulfur Dioxide 1 Hour 0.25 ppm 75 ppb --
3 Hour -- -- 0.5 ppm
24 Hour 0.04 ppm 0.14 ppm* --
Annual Mean -- 0.030 ppm* --
Lead 30 Day Avg. 1.5 μg/m3 -- --
Calendar Qtr. -- 1.5 μg/m3 1.5 μg/m3
3 Month
Average
-- 0.15 μg/m3 0.15 μg/m3
Sulfates 24 Hour 25 μg/m3 N/A N/A
Hydrogen Sulfide 1 Hour 0.03 ppm N/A N/A
Vinyl Chloride 24 Hour 0.01 ppm N/A N/A
Visibility Reducing
Particles
8 Hour Extinction
coefficient of

0.23 per
kilometer.3

N/A N/A
Notes: ppm – parts per million; ppb – parts per billion; μg/m3– micrograms per cubic meter; N/A – not applicable 1 National Primary Standards: The levels of air quality necessary, with an adequate margin of safety, to protect the public health.
2 National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.
3 The “extinction coefficient” is a measure of the diminishing of light through scattering and absorption. * For certain areas.

Source: ARB 2016.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-6 November 2024 Regions of the country are classified with respect to their attainment of the National Ambient Air Quality Standards. Areas where these standards are exceeded are considered “nonattainment” areas and are subject to more intensive air quality management and more stringent regulation. Table 6-3 shows the attainment status of the Air Basin for federal standards. The Air Basin is designated Nonattainment/Extreme for ozone and Nonattainment for PM2.5. The Air Basin meets all other federal standards.

TABLE 6-3

SAN JOAQUIN VALLEY AIR BASIN ATTAINMENT STATUS
Pollutant
Designation/Classification
Federal Primary Standards State Standards
Ozone - One hour No Federal Standarda Nonattainment/Severe Ozone - Eight hour Nonattainment/Extremeb Nonattainment PM10 Attainmentc Nonattainment
PM2.5 Nonattainmentd Nonattainment
Carbon Monoxide Attainment/Unclassified Attainment/Unclassified Nitrogen Dioxide Attainment/Unclassified Attainment
Sulfur Dioxide Attainment/Unclassified Attainment
Lead (Particulate) No Designation/Classification Attainment Hydrogen Sulfide No Federal Standard Unclassified
Sulfates No Federal Standard Attainment
Visibility Reducing
Particles
No Federal Standard Unclassified
Vinyl Chloride No Federal Standard Attainment
a Effective June 15, 2005, the EPA revoked the federal 1-hour ozone standard, including associated designations and classifications. EPA had previously classified the SJVAB as extreme nonattainment for this standard. EPA approved the 2004 Extreme Ozone Attainment Demonstration Plan on March 8, 2010 (effective April 7, 2010). Many applicable requirements for extreme 1-hour ozone nonattainment areas continue to apply to the SJVAB.
b Though the Valley was initially classified as serious nonattainment for the 1997 8-hour ozone standard, EPA approved Valley reclassification to extreme nonattainment in the Federal Register on May 5, 2010 (effective June 4, 2010).
c On September 25, 2008, EPA redesignated the San Joaquin Valley to attainment for the PM10 National Ambient Air Quality Standard (NAAQS) and approved the PM10 Maintenance Plan. d The Valley is designated nonattainment for the 1997 PM2.5 NAAQS. EPA designated the Valley as nonattainment for the 2006 PM2.5 NAAQS on November 13, 2009 (effective December 14, 2009).

Source: SJVAPCD 2023.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-7 November 2024 The Clean Air Act requires states to submit a State Implementation Plan for nonattainment areas. The State Implementation Plan in California is prepared by the ARB and is reviewed and approved by the EPA, subject to a determination of adequacy in demonstrating how the federal standards will be achieved. The local air pollution or air quality management districts are responsible for preparation of Air Quality Attainment Plans for their jurisdictions. These Air Quality Attainment Plans become part of the State Implementation Plan.

California Clean Air Act
The California Clean Air Act provides the planning framework for California air quality.

It establishes the State’s own set of ambient air quality standards for criteria pollutants, known as the California Ambient Air Quality Standards (see Table 6-2). The State standards cover other pollutants besides the six criteria pollutants designated by the federal Clean Air Act; additionally, the State standards are generally more stringent than the corresponding federal standards.

Table 6-3 shows the attainment status of the Air Basin for California Ambient Air Quality Standards. For ozone, the Air Basin is designated Nonattainment/Severe by the State. The State also classifies the Air Basin as Nonattainment for PM10 and PM2.5. The Air Basin is in attainment of, or unclassified for, all other State standards. The California Clean Air Act requires areas that are designated nonattainment to achieve a 5% annual reduction in emissions until the standards are met. Responsibility for implementation of the California Clean Air Act requirements rests with the ARB.

ARB’s existing mobile source control program has achieved substantial reductions in air pollution in the San Joaquin Valley. Since 2000, NOx and PM2.5 emissions from mobile sources have been reduced by over 60 percent. Continued implementation of ARB’s current mobile source programs is anticipated to reduce NOx emissions from 2013 levels by 55 percent and PM2.5 emissions by nearly 40 percent by 2025 (SJVAPCD 2018).

California Toxic Air Contaminant Controls
The State regulates TACs primarily through the Tanner Air Toxics Act and the Air Toxics Hot Spots Information and Assessment Act of 1987. Under these programs, the State is responsible for an inventory of TACs, for analysis of exposure and risk, and for planning to reduce risk. Most recently, in 2017, Assembly Bill 617 was signed into law establishing the Community Air Protection Program. The program’s focus is to reduce exposure in communities experiencing high cumulative exposure to air pollution including air toxic chemicals. Many of these occur within disadvantaged communities.

The agencies primarily responsible for administering these programs are ARB and the Office of Environmental Health Hazard Assessment. Like other federal and state air quality requirements, the various elements of the State air toxics program are implemented by the local air districts.

DPM is regulated by the ARB under various programs and regulations designed to reduce emissions. These include the Advanced Clean Trucks regulation, which requires manufacturers to sell an increasing percentage of zero-emission trucks by 2035.

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Copper Trails Specific Plan and Annexation EIR 6-8 November 2024 California On-Road Heavy-Duty Vehicle Program
The ARB has adopted standards for emissions from various types of new on-road heavyduty vehicles. Section 1956.8, Title 13, California Code of Regulations contains California’s emission standards for on-road heavy-duty engines and vehicles, and test procedures. The ARB has also adopted programs and regulations to reduce emissions from in-use heavy-duty vehicles, including the Advanced Clean Truck Regulation described below.

Advanced Clean Truck Regulation
On June 25, 2020, the ARB adopted the Advanced Clean Truck Regulation. The goal of this proposed strategy is to achieve NOx and GHG emission reductions through advanced clean technology, and to increase the penetration of the first wave of zero-emission heavyduty technology into applications that are well suited to its use.

The regulation has two components. First, manufacturers who certify Class 2b-8 chassis or complete vehicles with combustion engines would be required to sell zero-emission trucks as an increasing percentage of their annual California sales. By 2035, zero-emission truck/chassis sales would need to be 55% of Class 2b-3 truck sales, 75% of Class 4-8 straight truck sales, and 40% of truck tractor sales. Second, large employers, including retailers, manufacturers, brokers, and others would be required to report information about shipments and shuttle services.

The ARB anticipates that by 2040, the Advanced Clean Truck Regulation would reduce NOx emissions by approximately 16% from baseline, PM2.5 emissions by approximately

14.5% from baseline, and GHG emissions by approximately 7% below baseline. “Baseline” is the anticipated emissions that would occur with implementation of other emission reduction regulations adopted by the State (ARB 2020b). The proposed regional commercial center is the land use most likely to generate traffic by trucks subject to this regulation.

San Joaquin Valley Air Pollution Control District
Projects within the Air Basin are subject to the regulatory authority of the San Joaquin Valley Air Pollution Control District (SJVAPCD), which implements and enforces air quality regulations in eight counties, from San Joaquin County in the north to western Kern County in the south. The SJVAPCD’s responsibilities include air quality standard attainment planning, regulation of emissions from non-transportation sources, and mitigation of emissions from on-road sources.

Air Quality Plans
Air quality plans adopted by the SJVAPCD to meet Clean Air Act standards, including those designed to protect human health, are presented in Table 6-4 below. All the plans include federal, State, and local measures that would be implemented through rule making or program funding to reduce air pollutant emissions in the Air Basin.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-9 November 2024 TABLE 6-4

SUMMARY OF SJVAPCD AIR QUALITY PLANS
Pollutant Plan Objective
Ozone 2022 Plan for the 2015 8-Hour
Ozone Standard
Attainment of the federal 2015 standard
for ozone (70 parts per billion).
2023 Maintenance Plan and
Redesignation Request for the
Revoked 1-Hour Ozone
Standard
Maintenance of attainment of the federal
1-hour ozone standard.

Particulate
Matter
2007 PM10 Maintenance Plan Continued attainment of federal PM10 standard met by the Air Basin.
2018 Plan for the 1997, 2006,
and 2012 PM2.5 Standards
Attainment of federal health-based
1997, 2006, and 2012 standards for fine
particulate matter.

The San Joaquin Valley will not be able to attain stringent health-based federal air quality standards without significant reductions in emissions from heavy heavy-duty trucks, the single largest source of NOx emissions in the San Joaquin Valley. The SJVAPCD’s 2018 PM2.5 Plan will obtain significant new reductions in emissions from heavy-duty trucks, including emissions reductions by 2023, through the implementation of the ARB’s Statewide Truck and Bus Regulation, which requires truck fleets operating in California to meet the 2010 0.2 grams per brake horsepower-hour (g/bhp-hr) NOx standard by 2023.

Additionally, to meet the federal air quality standards by the 2020 to 2024 attainment deadlines, the 2018 PM2.5 Plan relies on a significant and immediate transition of heavyduty truck fleets to zero or near-zero emissions technologies, including the near-zero truck standard of 0.02 g/bhp-hr NOx established by the ARB, primarily through the deployment of incentive-based measures. Under this plan, the San Joaquin Valley will attain all federal ambient air quality standards for PM2.5 by the end of 2025 (SJVAPCD 2018).

SJVAPCD Rules and Regulations
SJVAPCD has adopted several regulations that are applicable to the project. These regulations are summarized below.

Regulation VIII (Fugitive Dust PM10 Prohibitions)
Rules 8011-8081 which are, together, Regulation VIII, are designed to reduce PM10 emissions, predominantly dust/dirt, generated by human activity, including construction and demolition, road construction, bulk materials storage, paved and unpaved roads, carryout and track out, landfill operations, etc.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-10 November 2024 Rule 4101 (Visible Emissions)
Rule 4101 prohibits emissions of visible air contaminants to the atmosphere and applies to any source operation that emits or may emit air contaminants.

Rule 4601 (Architectural Coatings)
Rule 4601 limits emissions of volatile organic compounds from architectural coatings by specifying storage, clean up and labeling requirements. Under this rule, no person within the SJVAPCD shall apply any flat architectural coating with a volatile organic compound (VOC) content that exceeds 50 grams per liter. VOCs are carbon compounds that can emit ROG, an ozone precursor.

Rule 4641 (Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operations)
Rule 4641 limits emissions of volatile organic compounds by restricting the application and manufacturing of certain types of asphalt for paving and maintenance operations.

A person shall not manufacture for sale nor use rapid cure cutback asphalt, medium cure cutback asphalt, Slow cure asphalt containing more than 0.5 percent of organic compounds which evaporate at 500°F or lower, or emulsified asphalt containing organic compounds in excess of three percent by volume which evaporate at 500°F or lower.

Rule 9410 (Employer Based Trip Reduction)
The purpose of Rule 9410 is to reduce vehicle miles traveled (VMT) by private vehicles used by employees to commute to and from their worksites, which in turn would reduce emissions of NOx, volatile organic compounds (a component of ozone), and particulate matter. Employers are required to implement an Employer Trip Reduction Implementation Plan (ETRIP) for each worksite with 100 or more eligible employees to meet applicable targets specified in the rule. Employers are required to facilitate participation in the development of an ETRIP by providing information to its employees explaining the requirements and applicability of this rule. A SJVAPCD staff report indicates that a comprehensive trip program similar to ETRIP typically reduces peak-hour automobile trips by 5-20%, and more if supported by regional transportation demand management strategies.

Under Rule 9410, employers are required to collect information on the modes of transportation used for each eligible employee’s commutes both to and from work for every day of the commute verification period, as defined by using either the mandatory commute verification method or a representative survey method. An ETRIP for each worksite must be submitted to the SJVAPCD, and the ETRIP must be updated annually.

Annual reporting includes the results of the commute verification for the previous calendar year, along with the measures implemented and, if necessary, any updates to the ETRIP. As with other air district rules, penalties shall be imposed for noncompliance with Rule 9410 in accordance with California Health and Safety Code Sections 42402-42403.

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Copper Trails Specific Plan and Annexation EIR 6-11 November 2024 Rule 9510 (Indirect Source Review)
Rule 9510, also known as the Indirect Source Rule, is intended to reduce or mitigate emissions of NOx and PM10 from new development in the SJVAPCD including construction and operational emissions. This rule requires specific percentage reductions in estimated on-site construction and operation emissions, and/or payment of mitigation fees for required reductions that cannot be met on the project site. The mitigation fees are used to fund off-site emissions reduction projects. Construction emissions of NOx and PM10 exhaust must be reduced by 20% and 45%, respectively.

Operational emissions of NOx and PM10 must be reduced by 33.3% and 50%, respectively. Rule 9510 applies to light industrial development projects of 25,000 square feet and larger, so the project would be subject to this rule.

Health Risk Assessment
The SJVAPCD recommends that projects that could emit substantial amounts of carcinogens conduct a Health Risk Assessment if there are nearby sensitive receptors. To determine if a Health Risk Assessment would be necessary, a “facility prioritization” is conducted on all sources of potential toxic emissions, based on their estimated emissions.

If a project has a cancer facility prioritization score of 10 or more, or a chronic or acute score of 1 or greater, then a Health Risk Assessment is required to further evaluate the potential health effects of a project, both carcinogenic and non-carcinogenic. The Health Risk Assessment is conducted on an individual project basis, and not at a plan level.

Ambient Air Quality Analysis
An Ambient Air Quality Analysis uses air dispersion modeling to determine if emissions from a project will cause or contribute to a violation of the ambient air quality standards.

The SJVAPCD recommends that an Ambient Air Quality Analysis be performed for a project if emissions exceed 100 pounds per day of any pollutant. This analysis is conducted on an individual project basis, and not on a plan level.

ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
The air quality impact analysis is based on the methodology defined in the SJVAPCD’s Guide for Assessing and Mitigating Air Quality Impacts (GAMAQI). The analysis includes consideration of both project construction and long-term operation effects on criteria pollutants and air toxics.

Significance Thresholds
According to Appendix G of the CEQA Guidelines, a project may have a significant impact on air quality if it would:
● Conflict with or obstruct implementation of an applicable air quality plan, ● Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-12 November 2024 ambient air quality standard [see Chapter 18.0, Cumulative Impacts, for an analysis of potential cumulative air quality impacts],
● Expose sensitive receptors to substantial pollutant concentrations, or ● Result in other emissions, such as those leading to odors, adversely affecting a substantial number of people.

CEQA Guidelines Appendix G states that, where available, significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make significance determinations. In 2015, the SJVAPCD adopted a revised Guide for Assessing and Mitigating Air Quality Impacts, which defines methodology and thresholds of significance for the assessment of air quality impacts for projects within SJVAPCD’s jurisdiction, along with mitigation measures for identified impacts. Tables 6- 5 and 6-6 shows the significance thresholds established by SJVAPCD for project emissions from construction and operations, respectively, as set forth in the GAMAQI.

The SJVAPCD’s significance thresholds for criteria pollutants are applied to evaluate regional impacts of project-specific emissions of air pollutants. The SJVAPCD significance thresholds are based on offset thresholds established under SJVAPCD Rule 2201 - New Source Review. Rule 2201 is a major component of the SJVAPCD’s attainment strategy as it relates to growth and applies to new and modified stationary sources of air pollution. Under Rule 2201, all new permitted sources with emission increases exceeding two pounds per day, for any criteria pollutant is required to implement Best Available Control Technology. Furthermore, all permitted sources emitting more than the Rule 2201 thresholds for any criteria pollutant must offset all emission increases that exceed threshold levels. The SJVAPCD’s attainment plans, developed to meet air quality standards designed in part to protect human health, demonstrate that project-specific emissions below the offset thresholds would have a less-than-significant impact on air quality (SJVAPCD 2015).

The project’s construction and operational emissions were calculated using the California Emissions Estimator Model (CalEEMod) computer program, a modeling program recommended by SJVAPCD. The CalEEMod results are shown in Appendix C of this report. Construction emissions are the maximum estimated for a calendar year during the construction period that extends from 2023 to 2025. An assumed scenario for construction is provided in the discussion of Impact AIR-1 below. Operational emissions are estimates of ongoing annual emissions from the proposed development; the assumed operational scenario is full buildout of the CTSP
Although the SJVAPCD is in regional attainment for carbon monoxide (CO), CO emissions may still exceed standards where a large volume of traffic is highly congested.

The project’s impact on CO emissions is considered significant if the project would:
● Degrade operation of an intersection to Level of Service (LOS) E or F, or substantially worsen an intersection already operating at LOS F, and EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-13 November 2024 ● The Transportation Project-Level Carbon Monoxide Protocol or CALINE4 modeling indicates that CO standards would be exceeded adjacent to an impacted intersection. [See Chapter 16.0, Transportation, for a description of LOS.] Based on the GAMAQI, air toxics exposure will be considered significant if they would result in:
● A lifetime cancer risk for sensitive land uses, such as residential, that exceeds 10 in one million.
● Ground-level concentrations of non-carcinogenic toxic air contaminants that would result in a Hazard Index greater than one (1).

Impact AIR-1: Emissions from Project Construction
Adoption of the CTSP and subsequent development in the CTSP Area would result in new construction activity. Construction would generate particulate matter and ozone precursor emissions from heavy equipment operation and fugitive dust from earth moving activities.

As noted in GAMAQI, construction activities such as grading, excavation and travel on unpaved surfaces can generate substantial amounts of dust and can lead to elevated concentrations of PM10. The Pocket Area, because of its mostly developed state, is not expected to contribute significantly to construction emissions. Therefore, the focus of this analysis is construction emissions that would be generated in the CTSP Area.

The CTSP does not include a formal phasing or construction schedule, providing no basis for estimation of construction air quality impacts in any given year; the 2,392 residential units and 1.17 million square feet of commercial development allowed by the CTSP could occur over the potential buildout period. To quantify potential construction emissions, a “maximum construction year” scenario was analyzed. This scenario assumes conservatively the construction of about 20% of the total allowable development under the CTSP – approximately 478 residential units and 233,917 square feet of commercial development.

Construction impacts of this scenario were quantified using the CalEEMod modeling program, with default modeling assumptions and no assumed mitigation. Table 6-5 displays the results of the model run; detailed model results are shown in Appendix D. The CalEEMod results indicate that maximum year construction would result in pollutant emissions that are well below the GAMAQI significance thresholds.

All construction activities are subject to the requirements of SJVAPCD Regulation VIII.

The rules embodied in Regulation VIII require dust control measures that limit visible dust emissions to 20% opacity or less. Dust control measures must 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 and restricting access to inactive sites. For larger projects, the applicant must submit a Dust Control Plan for the review and approval of the Air Pollution Control Officer and then implement the plan in accordance with all relevant requirements.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-14 November 2024 TABLE 6-5

AIR EMISSIONS FROM CONSTRUCTION, MAXIMUM DEVELOPMENT YEAR Pollutants
ROG NOx CO SOx PM10 PM2.5
Significance Threshold 10 10 100 27 15 15
Estimated Emissions 3.64 1.21 2.01 0.01 0.31 0.12
Significant Impact? No No No No No No
ISR Mitigated - 0.97 - - 0.30 -
Note: All figures are in tons per year.

Sources: CalEEMod v. 2022.4.0, SJVAPCD 2015.

Along with Regulation VIII, project construction would be required to comply with other applicable SJVAPCD rules - Rule 4101 (Visible Emissions) and Rule 4601 (Architectural Coatings). In addition, Rule 9510 applies to construction activities, especially on large projects; ongoing enforcement of this rule would reduce NOx and PM10 exhaust emissions by 20% and 45%, respectively. These reductions are typically achieved by substitution of less-polluting equipment and construction site practices that the contractor commits to.

Compliance with Rule 9510 requirements would reduce potential NOx and PM10 construction emissions during the maximum construction year to 1.83 and 0.81 tons per year, respectively, as indicated in Table 6-4. The City typically requires projects to comply with these existing SJVAPCD rules and regulations. It is recommended that the CTSP be amended, or a condition of approval added to the project, that would require project conformance with existing SJVAPCD rules and regulations including Regulation VIII and Rule 9510 as discussed above.

In summary, project construction activities within the CTSP Area are not anticipated to result in emissions that exceed SJVAPCD significance thresholds. Project impacts would be less than significant assuming compliance with the applicable SJVAPCD rules and regulations.

Level of Significance: Less than significant
Mitigation Measures: None required due to requirements of existing rules and regulations
Recommendation: The CTSP and/or conditions of approval should specifically require project conformance with existing SJVAPCD rules and regulations, including Regulation VIII and Rule 9510, as shown in the following 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

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

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-15 November 2024 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 (2002).
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. 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.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-16 November 2024 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, prior to paving activities and provide the City of Ceres with evidence of consultation with the APCD, including confirmation of compliance with APCD Rule 4641.

Impact AIR-2: Criteria Pollutant Emissions from Project Operations As the CTSP Area develops over time, the occupancy and use of new land uses would result in new emissions of criteria air pollutants. Emissions from increased traffic, known as “mobile source” emissions, generated by development in the CTSP Area would be the major source of “operational” emissions. Other emissions would result from use of natural gas and other fuels by new land uses, primarily space and water heating; these are referred to as “area source” emissions. Air pollutants of concern are primarily ROG, NOx and PM.

Operational emissions also include relatively small amounts of carbon monoxide, sulfur dioxide and diesel particulate matter. The Pocket Area, because of its mostly developed state, is not expected to contribute significantly to operational emissions.

The CalEEMod model was used to describe the operational air quality impacts of the CTSP, excluding the two existing schools in the CTSP Area. The model generates pollutant emission estimates using project land use data from which vehicle fleet, trip length, and trip-start information is generated. Vehicle trip generation used data from the Transportation Impact Analysis prepared for the CTSP (see Chapter 16.0, Transportation).

Although some inputs were adjusted within the model, the potential impacts of the CTSP were generated using mostly default model assumptions. CalEEMod model was run for full buildout of the CTSP, which was assumed to occur in the year 2050 as that year is the last possible analysis year for CalEEMod. CalEEMod was run without mitigation and then again with consideration of following mitigation measures included in the CTSP or City of Ceres development review, including:
• Improved pedestrian and bicycle network
• Energy efficiency above Title 24
• Water conservation 20% indoor and 20% outdoor
• Solid waste recycling rate of 75% for commercial and multifamily residential The estimated annual operational emissions associated with the CTSP at buildout are shown in Table 6-6, along with a comparison to total emissions by development under the Ceres General Plan as provided in the GPEIR. CTSP emissions of ROG, NOx, CO, and PM10 would substantially exceed the SJVAPCD significance thresholds, and CalEEMod mitigations would not reduce these emissions below their thresholds. Participation in the ISR program would produce 33% and 50% reductions in NOx and PM10 emissions, but neither pollutant would be reduced to below the significance threshold, although both only EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-17 November 2024 slightly exceed their respective thresholds. Air pollutant emissions above their established thresholds would result in potentially significant air quality impacts.

TABLE 6-6

ESTIMATED ANNUAL OPERATIONAL EMISSIONS

IN CTSP AREA AT BUILDOUT
Pollutants
ROG NOx CO SOx PM10 PM2.5
Significance Thresholds 10 10 100 27 15 15
Estimated Emissions (unmit.) 41.2 17.5 142 0.37 34.0 11.4 Significant Impact? Yes Yes Yes No Yes No
Estimated Emissions (mit.) 40.2 16.5 136 0.35 32.0 10.9 ISR Mitigated - 11.0 - - 16.0 -
Significant Impact? Yes Yes Yes No Yes No
GPEIR Emissions 188 769 328 1.9 75 23
Note: All figures are in tons per year.

Sources: CalEEMod v. 2022.4.0, SJVAPCD 2015, City of Ceres 2018a.

Future development projects are required to apply for an ISR permit if they exceed the ISR permitting thresholds - 50 residential units or 2,000 square feet of commercial space. The ISR program requires that unmitigated operational NOx and PM emissions be reduced by

33.3% and 50%, respectively. Required emission reductions can be accomplished by incorporation of on-site mitigation measures into the project, which are credited to the reductions required by the ISR. Any emission reductions that are not accomplished through on-site mitigation require payment of a per-ton fee; ISR fees are used to achieve off-site emission reductions by funding clean air projects. The current fees are $9,350 per ton of NOx and $9,011 for PM; for operational emissions, the fee is assessed for ten years of emissions.

Table 6-6 shows the targeted ISR percentage reduction for the CTSP Area as a whole and the resulting emission amounts. To fulfill the requirements of the ISR, a project applicant will need to demonstrate that emissions will be further reduced or the required fee will need to be paid. The NOx and PM10 emission reductions sought by the ISR program would be achieved in either event, directly through on-site mitigation or indirectly through off-site mitigation purchased by the SJVAPCD with fee payment funds collected from project developers. As noted with respect to construction emissions, the City typically requires projects to comply with SJVAPCD rules and regulations; these requirements are also recommended below for inclusion in the CTSP or as conditions to CTSP approval.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-18 November 2024 The CTSP would retain and reinforce General Plan objectives for, and policies supporting development of, new job and shopping opportunities, thereby potentially reducing existing commute and shopping travel outside the City. The CTSP also proposes an extensive pedestrian and bicycle system that would internally connect neighborhoods, retail centers, and existing schools. CTSP streets would include pedestrian-friendly details such as streetside and median landscaping, sidewalks, and shade tree plantings. Green building, in particular energy and water conservation, would be incorporated in new residential and commercial development, in accordance with the adopted California Green Building Standards Code (CALGreen). These potential additional mitigating effects are discussed further in Chapter 10.0, Greenhouse Gas Emissions; Chapter 17.0, Transportation; and Chapter 19.0, Cumulative Impacts.

The potential air quality effects of urban development in the Ceres Planning Area were considered in the GPEIR. Potential emissions were identified as significant. Despite the implementation of General Plan policies, SJVAPCD regulations, Title 24 energy efficiency standards, and other measures, the air quality impacts of General Plan development were identified as significant and unavoidable.

Planned development within the CTSP Area would contribute to the air quality impact identified in the GPEIR, but it is not anticipated that it would introduce new or more severe impacts than those analyzed in the GPEIR. Features of proposed CTSP development, such as more intensive residential development, may reduce air quality impacts in the CTSP Area from those anticipated in the GPEIR. Also, future development would be required to comply with energy efficiency standards more stringent than those in effect at the time the GPEIR was prepared. State regulations requiring vehicles that would emit fewer pollutants, such as electric vehicles, would further reduce impacts of CTSP development.

Development in the CTSP Area will also be subject to General Plan policies that intend to reduce air emissions.

Individual future development projects within the CTSP or Pocket Areas, would be subject to CEQA analysis, including an analysis of their air quality impacts. Project construction and operational emissions are estimated and compared with the SJVAPCD significance thresholds. As noted, project emissions that do not exceed these thresholds are considered consistent with SJVAPCD air quality attainment plans and therefore would not have a significant impact. For emissions that do exceed SJVAPCD significance thresholds, mitigation measures specific to these projects would be required to reduce these emissions below these thresholds. Also, applicable SJVAPCD rules and regulations would apply to the projects, further reducing their impacts. It is expected that individual projects within the project site would not exceed SJVAPCD significance thresholds, either by themselves or with applicable mitigation.

In summary, the project would not contribute new or more severe air quality impacts than those analyzed in the GPEIR, and it may reduce some of those predicted impacts. In addition, individual projects would be subject to CEQA review and potential additional mitigation requirements, if necessary. Therefore, project impacts related to operational emissions are considered less than significant.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-19 November 2024 Level of Significance: Less than significant
Mitigation Measures: None required
Impact AIR-3: Exposure of Sensitive Receptors to Criteria Pollutants The SJVAPCD is in attainment of carbon monoxide standards on a regional basis, but the potential exists for localized exceedances in areas of high traffic congestion. Potentially significant CO effects could result from the CTSP if it would result in high traffic congestion. As noted, the screening threshold for potentially significant CO impacts is whether the project would cause the predicted level of service at intersections to degrade to LOS E or F, or substantially worsen traffic at intersections already operating at LOS E or F. If such intersections are near sensitive receptors, the project would result in a significant air quality effect.

This analysis of potential CO effects is based on the Transportation Impact Analysis for the CTSP, which is discussed in Chapter 16.0, Transportation. The analysis indicates that LOS on local street segments or intersection would not degrade to unacceptable levels of LOS. Therefore, the project would not likely result in areas of high congestion at intersections, and thus no elevated CO concentrations. Impacts related to exposure of sensitive receptors to criteria pollutants would be less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
Impact AIR-4: Exposure of Sensitive Receptors to Toxic Air Contaminants The proposed project would involve the development of retail commercial, institutional, and residential uses. The proposed CTSP does not specifically authorize any manufacturing, fuel handling or other land use that would generate substantial air toxic emissions. It is conceivable but unlikely that future proposed land uses could involve toxic air emissions; such potential effects would be identified and addressed during the City’s land use permit review.

SR 99 has been identified as a source of diesel particulate matter, mainly from emissions by truck traffic. Diesel particulate matter is classified as a TAC, and prolonged exposure of sensitive receptors to these emissions could pose a health risk. However, the nearest sensitive receptor to the project site that would be placed by the project – proposed highdensity residential development – would be approximately 900 feet from the edge of SR

99. The ARB’s Air Quality and Land Use Handbook recommends avoiding the siting of new sensitive land uses within 500 feet of a freeway (ARB 2005). Therefore, the potential exposure of the proposed high-density land uses would be minimal, and other residential development would be set back further away from SR 99.

Another source of diesel particulate matter emissions would be construction equipment.

Such emissions would be temporary and would cease when construction work is completed. Adverse impacts associated with diesel particulate matter emissions are generated by long-term exposure, which would not occur with this source. Therefore, EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-20 November 2024 project impacts related to exposure of sensitive receptors to toxic air contaminants would be less than significant.

Most of the proposed land uses, such as residential development and parks, would not generate TACs in any amounts that could present a risk to human health. Most of the likely Regional Commercial land uses would likewise not generate significant TAC emissions, other than possibly from truck traffic. Emissions from this source would come under more stringent regulations such as the Advanced Clean Truck Regulation, so the amount of TAC emissions from this source would be reduced.

The Regional Commercial designation in the CTSP allows for service stations with a Conditional Use Permit. Service stations, through the delivery and dispensing of fuels, can generate TACs such as benzene, toluene, and xylene. The ARB and the California Air Pollution Control Officers Association have developed a Gasoline Service Station Industrywide Risk Assessment Look-up Tool to screen service stations for their cancer and other risks. The tool takes the estimated fuel throughput (i.e., amount of fuel dispensed at a given time) of the proposed service station and estimates the potential increase in risk from emissions associated with fuel dispensing based on distances to the nearest sensitive receptors. The health risk scores are compared with the appropriate thresholds established by SJVAPCD. Mitigation described below would require the use of this Look-Up Tool to analyze potential TAC impacts of a service station as part of the CEQA review that would be conducted during the Conditional Use Permit review process.

In summary, development in the CTSP Area and the Pocket Area 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, including an analysis of potential air toxics impacts. Therefore, project impacts related to TACs are considered less than significant with application of the following mitigation measure for proposed service stations.

Level of Significance: Potentially significant
Mitigation Measures:

AIR-5: For service station projects, as part of the Conditional Use Permit evaluation process, the SJVAPCD 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 noncancer 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 formal 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.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 6-21 November 2024 These recommendations shall be incorporated as conditions of approval for the Conditional Use Permit and shall be implemented upon permit approval.

Impacts After Mitigation: Less than significant
Impact AIR-5: Odor Emissions
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 to local governments and the SJVAPCD. Land uses and industrial operations that are associated with odor complaints include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding (City of Ceres 2018a). Ceres General Plan Policy 4.G.8 does not permit new residential development within a half-mile radius of emitters of noxious odors.

Development under the Ceres General Plan, which would include the CTSP if adopted, would be required to meet all local, State, and federal regulations related to odor control, including permit requirements. The CTSP would not allow or promote development of odor sources. Planned new development consists of retail commercial, institutional and residential development, which are not typically sources of objectionable odors. Some new retail commercial development may consist of restaurants, which may result in the generation of food service-related odors. However, these odors are localized and generally are not considered unpleasant.

The Pocket Area already contains substantial development, including light industrial development that may allow for odor-generating activities. Future development in this area would be subject to CEQA review, which would analyze the potential for an odorgenerating activity. Since most of the Pocket Area is zoned for non-industrial uses, it is not likely that significant odor-generating activities would locate there.

Overall, project impacts related to odors are considered less than significant with compliance with Ceres General Plan Policy 4.G.8.

Level of Significance: Less than significant
Mitigation Measures: None required
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 7-1 November 2024

7.0 BIOLOGICAL RESOURCES
ENVIRONMENTAL SETTING
Vegetation
The Ceres General Plan EIR defined several habitat types in the Ceres Planning Area based on the predominant vegetation. Of these habitat types, the project site contains two: (1) Deciduous Orchard, Evergreen Orchard, Vineyard, and Irrigated Row and Field Crops, and (2) Urban (City of Ceres 2018a).

The Deciduous Orchard, Evergreen Orchard, Vineyard, and Irrigated Row and Field Crops habitat type is related to agriculture and is found throughout the Planning Area, primarily in the area outside of City limits. The orchards are typically single species tree-dominated habitats. The understory is usually composed of low-growing grasses, legumes, and other herbaceous plants, but may be managed to prevent understory growth totally or partially, such as along tree rows. Vineyards are composed of single species planted in rows, where the understory often consists of bare soil or a cover crop of herbaceous plants. Vegetation in irrigated crops vary in size, shape, and growing pattern. The majority of agriculture in the CTSP Area is deciduous orchards and livestock grazing with lesser amounts of row crop area.

The structure of Urban vegetation varies, with five types of vegetative structure defined:
tree grove, street strip, shade tree/lawn, lawn, and shrub cover. Typically, in cities, vegetative cover is least dense in the central downtown area and gradually increases towards the edge. The Pocket Area and developed portions of the CTSP Area are classified as Urban.

Wildlife
Some species of birds and mammals have adapted to these habitats. Wildlife such as deer and rabbits browse on the trees and crops. Others, such as squirrels and numerous birds, feed on fruit or nuts. In orchards, some wildlife species are more passive in their use of the habitat for cover and nesting sites. Many wildlife species act as biological control agents by feeding on weed seeds and insect pests.

In urban areas, species become richer and more diverse where vegetative cover is denser.

Typically, in cities, this follows a concentric pattern where cover is least dense in the central downtown area and gradually increases towards the edge.

Special-Status Species
Special-status species are plants and animals that are legally protected under the federal and California Endangered Species Acts or other regulations (see below). Special-status species also include other species that are considered rare enough by the scientific community and trustee agencies to warrant special consideration, particularly with regard to protection of isolated populations, nesting or denning locations, communal roosts, and EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 7-2 November 2024 other essential habitat. Special-status plants are those which are designated rare, threatened, or endangered and candidate species for listing by the U.S. Fish and Wildlife Service (USFWS), along with considered rare or endangered under the conditions of CEQA Guidelines Section 15380, such as plant species identified on Lists 1A, 1B and 2 in the Inventory of Rare and Endangered Vascular Plants of California by the California Native Plant Society. They also may include other species that are considered sensitive or of special concern due to limited distribution or lack of adequate information to permit listing or rejection for state or federal status, such as those included on California Native Plant Society List 3.

Ceres is a developed area that is surrounded by cultivated agricultural land; therefore, it is not an ideal habitat for many species. Nonetheless, certain special-status species have been known to occur in the Planning Area (City of Ceres 2016a). A search of the California Natural Diversity Database (CNDDB) was undertaken to identify special-status species that have been previously documented in the greater project vicinity or have the potential to occur based on presence of suitable habitat and geographical distribution. The results of the CNDDB search are available in Appendix B, and Table 7-1 summarizes the results.

Table 7-1 lists special-status species that have been documented or could potentially occur in the project vicinity, along with their status, habitat, and likelihood of occurrence on the project site.

TABLE 7-1

SPECIAL STATUS PLANT AND WILDLIFE SPECIES POTENTIALLY

OCCURRING IN THE CTSP VICINITY
Common
Name
Scientific
Name
Fed.

Status1
State
Status2
CNPS
List3 Habitat
Potential for
Occurrence
Plants
Heartscale Atriplex
cordulata var
cordulata
None None 1B In sandy,
alkaline soils of
saltbrush scrub
and grasslands.

Unlikely: the
CTSP Area does
not provide
suitable habitat
for this species.

Subtle orache Atriplex
subtilis
None None 1B Grasslands,
often in the
vicinity of
vernal pools.

Unlikely: the
CTSP Area does
not provide
suitable habitat
for this species.

Birds
Tricolored
blackbird
Agelaius
tricolor
None T N/A Nests in dense
brambles and
emergent
wetland
vegetation
associated with
open water
habitat.

Unlikely: the
CTSP Area does
not provide
suitable habitat
for this species.

Swainson’s
hawk
Buteo
swainsoni
None T N/A Breeds in stands
of tall trees in
Possible: this
species has been
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 7-3 November 2024 Common
Name
Scientific
Name
Fed.

Status1
State
Status2
CNPS
List3 Habitat
Potential for
Occurrence
open areas.

Requires
adjacent
suitable
foraging
habitats such as
grasslands or
alfalfa fields
supporting
rodents.
observed along
the Tuolumne
River. Existing
agricultural areas
may provide
suitable foraging
habitat, and some
trees in the area
may support
nesting hawks.

Burrowing owl Athene
cunicularia
None SC N/A Open, dry
annual or
perennial
grasslands,
deserts and
scrublands
characterized
by low-growing
vegetation.

Unlikely: the
CTSP Area does
not provide
suitable habitat
for this species.

Mammals
Townsend’s
big-eared bat
Corynorhinus
townsendii
None SC N/A Desert scrub,
mixed conifer
forest, and
pinyon-juniper
or pine forest;
primarily roosts
in caves, mines,
and buildings.

Unlikely: the
CTSP Area does
not contain
suitable roosting
habitat.

Fish
Chinook
salmon –
Central Valley
fall/late fall
run ESU
Oncorhynchus
tschawytscha
pop. 13
None SC N/A Spawning
habitat in
Sacramento and
San Joaquin
River basins.

None: there is no
aquatic habitat in
the CTSP Area.

Steelhead -
Central Valley
DPS
Oncorhynchus
mykiss irideus
pop. 11
T None N/A Riffle and pool
complexes with
adequate
spawning
substrates
within Central
Valley
drainages.

None: there is no
aquatic habitat in
the CTSP Area.

Hardhead Mylopharodon
conocephalus
None SC N/A Clear, deep
pools with sand
and gravel
bottoms in
tributaries to
the San Joaquin
and Sacramento
River.

None: there is no
aquatic habitat in
the CTSP Area.

Riffle sculpin Cottus gulosus None SC N/A Headwater
streams with
cold water;
None: there is no
aquatic habitat in
the CTSP Area.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 7-4 November 2024 Common
Name
Scientific
Name
Fed.

Status1
State
Status2
CNPS
List3 Habitat
Potential for
Occurrence
rocky or
gravelly
substrate
throughout
Central Valley
and coastal
drainages.

Invertebrates
Oregon floater Anondonta
oregonensis
None None N/A Found more
commonly in
ponds, lakes,
and reservoirs
but can also
occur in low
gradient reaches
of streams and
silty substrates
and sandbars at
stream
confluences.

None: there is no
aquatic habitat in
the CTSP Area.

Western
ridged mussel
Gonidea
angulata
C None N/A Prefers runs and
riffles in low- to
mid-gradient
streams.

None: there is no
aquatic habitat in
the CTSP Area.

Considered
extirpated from
the Central
Valley.

Valley
elderberry
longhorn
beetle
Desmocerus
californicus
dimorphus
T None N/A Elderberry
shrubs in the
Central Valley
and surrounding
foothills.

Possible: the
Ceres General
Plan EIR
identified this
species as
potentially
occurring in the
CTSP Area (City
of Ceres 2016a).

Moestan
blister beetle
Lytta moesta None S2 N/A Grasslands in
Central Valley
and Sierra
Nevada
foothills
Unlikely:
although the
Ceres General
Plan EIR
identified this
species as
potentially
occurring in the
Planning Area
(City of Ceres
2016a), the
CTSP Area does
not provide
suitable habitat
for this species.

Crotch bumble
bee
Bombus
crotchii
None CE N/A Open grassland
and scrub
Unlikely: the
CTSP Area does
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 7-5 November 2024 Common
Name
Scientific
Name
Fed.

Status1
State
Status2
CNPS
List3 Habitat
Potential for
Occurrence
habitats
throughout
California;
rarely found in
the Central
Valley.
not provide
suitable habitat
for this species.

American
bumble bee
Bombus
pensylvanicus
None None N/A Favors prairies
and grasslands,
but also
associated with
farmlands and
open fields.

Possible: the
CTSP Area may
provide suitable
habitat for this
species.

However, this is
a transitory
species that can
find suitable
habitat readily
available in the
project vicinity.

Obscure
bumble bee
Bombus
caliginosus
None None N/A Prefers
relatively
humid and often
foggy areas
along the coast.

Unlikely:
although the
Ceres General
Plan EIR
identified this
species as
potentially
occurring in the
Planning Area
(City of Ceres
2016a), the
CTSP Area does
not provide
suitable habitat
for this species.
1 T = Threatened; E = Endangered; C = Candidate.
2 T = Threatened; E = Endangered; CE = Candidate Endangered; SC = Species of Special Concern, R = Rare; S2 = Imperiled Species.
3 1B = Rare, threatened, or endangered in California and elsewhere; N/A = not applicable.

Source: CDFW 2023.

Waters of the U.S. and Wetlands
Waters of the U.S. include navigable waterways, their tributaries, and adjacent wetlands.

More specifically, Waters of the U.S. encompass territorial seas, tidal waters, and non-tidal waters. Other jurisdictional wetlands and Waters of the U.S. include, but are not limited to, perennial and intermittent creeks and drainages; lakes, seeps, and springs; emergent marshes; riparian wetlands; and seasonal wetlands. State and federal agencies regulate these waters (see below). The limit of federal jurisdiction of Non-Tidal Waters of the U.S. extends to the “ordinary high water mark,” which is established by physical characteristics such as a natural water line impressed on the bank, presence of shelves, destruction of terrestrial vegetation, or the presence of litter and debris.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 7-6 November 2024 Wetlands are vegetated areas that meet specific vegetation, soil, and hydrologic criteria defined by the Wetlands Delineation Manual and Regional Supplement of the U.S. Army Corps of Engineers (Corps). Wetlands that are adjacent to and hydrologically very closely associated with jurisdictional lakes, rivers, streams, and tributaries can also fall under Corps jurisdiction as “adjacent wetlands”. Geographically and hydrologically isolated wetlands are outside federal jurisdiction but are regulated as a “Water of the State” by the jurisdictional Regional Water Quality Control Board (RWQCB).

The USFWS maintains the National Wetlands Inventory database, which contains records of various types of streams, wetlands, and other water features. Results of a search of this database are available in Appendix D. Three features classified as “Riverine” were identified as traversing or bordering the project site. These features correspond to the TID Lower Lateral 2, the Ceres Main Canal, and another TID facility. No natural streams or wetlands were recorded on the project site (USFWS 2023).

REGULATORY FRAMEWORK
Federal Endangered Species Act
The federal Endangered Species Act protects fish and wildlife species, subspecies, or distinct population segments that are listed as endangered or threatened, along with their habitats. “Endangered” species are in danger of extinction through all or a significant portion of their range, while “threatened” species are likely to become endangered in the near future. The USFWS and the National Marine Fisheries Service are responsible for implementation of the Endangered Species Act, depending on the species. Section 9 of the Endangered Species Act prohibits the take of any fish or wildlife species listed as endangered. “Take” is defined as an action or attempt to hunt, harm, harass, pursue, shoot, wound, capture, kill, trap, or collect a species, as well as the destruction of habitat that prevents the species’ recovery.

When a species is proposed for listing as endangered or threatened under the Endangered Species Act, specific areas are identified that are considered essential to the conservation of the listed species; they are called “critical habitat.” The USFWS maintains maps of designated critical habitats. The project site is not within the designated critical habitat of any federally listed species.

California Endangered Species Act (CESA)
The CESA establishes State policy to conserve, protect, restore, and enhance threatened or endangered species and their habitats. It mandates that State agencies should not approve projects that jeopardize the continued existence of threatened or endangered species if reasonable and prudent alternatives are available that would avoid jeopardy. For projects that would affect a species that is on the federal and State lists, compliance with the federal Endangered Species Act satisfies CESA if the CDFW determines that the federal incidental take authorization is consistent with CESA under California Fish and Game Code Section 2080.1. For projects that would result in the take of only a State-listed species, the project proponent must apply for a take permit under Fish and Game Code Section 2081(b).

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 7-7 November 2024 Migratory Bird Treaty Act
The Migratory Bird Treaty Act (16 United States Code 703 et seq.) enacts the provisions of treaties between the United States, Great Britain, Mexico, Japan, and the former Soviet Union. It prohibits the take, possession, import, export, transport, selling, purchase, or barter of any migratory birds or their eggs, parts, or nests except as authorized under a valid permit. Offering the same for sale, purchase, or barter is likewise prohibited. Executive Order 13186 directs each federal agency taking actions that have or may have a negative effect on migratory bird populations to work with USFWS to develop a memorandum of understanding that will promote the conservation of migratory bird populations.

Clean Water Act
The federal Clean Water Act is the primary federal law regulating water quality. The objective of the Clean Water Act is to “restore and maintain the chemical, physical, and biological integrity of the Nation’s waters.” Waters of the U.S., including wetlands, are broadly defined in 33 Code of Federal Regulations Part 328.3(a) to include navigable waterways, their tributaries, and adjacent wetlands, as well as other waters described in the Environmental Setting portion of this chapter. Implementing the Clean Water Act is the responsibility of the EPA, but the EPA depends on other agencies, such as individual state governments and the Corp, to assist in implementation.

The definition of Waters of the U.S., and thereby the jurisdiction of the EPA and the Corps, has been the subject of legal and regulatory controversy over the past approximate three decades. On May 25, 2023, the U.S. Supreme Court, in its decision in Sackett v. EPA, held that the Clean Water Act’s definition of Waters of the U.S. extends to only those “wetlands with a continuous surface connection to bodies that are ‘waters of the United States’ in their own right,” so that they are “indistinguishable” from those waters. Based on the Supreme Court’s decision, the Clean Water Act covers only adjoining wetlands, a reading that excludes wetlands separated from jurisdictional waters by man-made dikes or barriers, natural river berms, beach dunes, and the like that had previously been protected. In response, the EPA and the Corps issued a rule on September 8, 2023, to conform the regulatory definition of Waters of the U.S. to the Sackett decision.

Sections 401 and 404 of the Clean Water Act apply to activities that would impact waters in the United States, such as creeks, ponds, and wetlands. For waters subject to federal jurisdiction, a permit under Section 404 of the Clean Water Act, issued by the Corps, must be secured prior to the discharge of dredged or fill materials into these waters. Projects requiring a Section 404 permit also must obtain a Water Quality Certification in accordance with Section 401 of the Clean Water Act; the Central Valley RWQCB would issue the Section 401 certification, if required.

Section 404
The Corps is responsible under Section 404 of the Clean Water Act for regulating the discharge of fill material into Waters of the U.S. and their lateral limits. As noted, the lateral limits of jurisdiction for a non-tidal stream are measured at the line of the “ordinary high water mark” or at the limit of adjacent wetlands. Any permanent extension of the limits of an existing water of the United States, whether natural or human-made, results in a similar extension of Corps jurisdiction.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 7-8 November 2024 In general, a permit must be obtained from the Corps before an individual project can place fill or grade in wetlands or other Waters of the U.S that are subject to Section 404. Along with general permits, the Corps has Nationwide Permits that apply to specific actions.

Mitigation for such actions will be required based on the conditions of the Corps permit.

The Corps is required to consult with the USFWS and/or the National Marine Fisheries Service under Section 7 of the Endangered Species Act if the action being permitted could affect federally listed species.

Section 401
Pursuant to Section 401 of the Clean Water Act, projects that require a Corps permit for discharge of dredge or fill material must also obtain a Water Quality Certification that confirms the project complies with State water quality standards before the Corps permit becomes valid, or a waiver or no-action determination. State water quality is regulated and administered by the SWRCB through the RWQCB with jurisdiction over the project. As noted, the project site is within the jurisdiction of the Central Valley RWQCB. Projects requiring a Section 401 Water Quality Certification must demonstrate compliance with CEQA.

Waters of the State
Under the Porter-Cologne Water Quality Control Act, “Waters of the State” fall under the jurisdiction of the SWRCB and the RWQCB with jurisdiction over the affected water. The RWQCBs are required to prepare and periodically update water quality control basin plans, which set forth water quality standards for surface water and groundwater, as well as actions to control nonpoint and point sources of pollution to achieve and maintain these standards. Projects that affect Waters of the State may also be required to meet Waste Discharge Requirements set by the RWQCB. SWRCB’s Resolution 2008-0026 identified a need to protect Waters of the State that are not subject to Section 404 permitting and associated Section 401 Water Quality Certification.

In April 2019, the SWRCB adopted the State Wetland Definition and Procedures for Discharges of Dredged or Fill Materials to Waters of the State (Procedures), which became operative on May 28, 2020 and were subsequently revised on April 6, 2021 (SWRCB 2021). The Procedures consist of four major elements:
● A wetland definition that is broader than the one for Waters of the U.S., ● A framework for determining if a feature that meets the wetland definition is a Water of the State,
● Wetland delineation procedures, and
● Procedures for application submittal and the review and approval of Water Quality Certifications and Waste Discharge Requirements for dredge or fill activities.

Applicants proposing to discharge dredged or fill material are required to comply with the Procedures unless an exclusion applies, or the discharge qualifies for coverage under a SWRCB General Order. The Central Valley RWQCB is expected to require issuance of Waste Discharge Requirements that authorize the impacts of filling isolated wetlands that EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 7-9 November 2024 are not subject to Section 404 permitting, or in some cases granting a waiver. It should be noted that these Procedures are the subject of ongoing litigation, and the 2021 revisions to the Procedures were adopted in part in response to this litigation.

CDFW Streambed Alteration Agreement
Sections 1600-1607 of the California Fish and Game Code require any agency that proposes a project that will substantially divert or obstruct the natural flow of or substantially change the bed or bank of a river, stream, or lake to notify CDFW before beginning construction. If CDFW determines that the project may substantially and adversely affect fish or wildlife resources, a Lake or Streambed Alteration Agreement will be required. CDFW jurisdictional limits are usually defined by the tops of the stream or lake banks or the outer edge of riparian vegetation, whichever is wider.

California Fish and Game Code
The California Fish and Game Code provides protection from take for a variety of wildlife species designated as “fully protected” species. Section 3511 lists fully protected species and prohibits their take. The California Fish and Game Code defines “take” as hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill. There are currently 34 wildlife species designated as fully protected species: 9 fish, 3 amphibians, 2 reptiles, 11 birds, and 9 mammals.

Until recently, all take of fully protected species was prohibited except when related to scientific research. On July 10, 2023, Governor Newsom signed into law SB 147, which creates a temporary, 10-year permitting regime that allows proponents of specific renewable energy and infrastructure projects to pursue authorization from the CDFW to proceed even when take of one or more fully protected species would occur. The CTSP would not qualify for this permitting process.

Section 3503 of the California Fish and Game Code states that it is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by this code or any regulation made pursuant thereto. Section 3503.5 prohibits the take, possession, or destruction of any raptor bird species, specifically those in the orders Falconiformes (falcons, hawks, eagles) or Strigiformes (owls) or of their nests or eggs.

Ceres General Plan
The Ceres General Plan contains the following goals and policies on the protection of biological resources that are applicable to the project area:
• Goal 4.C. Protect, restore, and enhance habitats and wildlife corridors that support fish and wildlife species to maintain populations at viable levels. • Goal 4.D. Protect environmentally sensitive lands and rare, threatened, or endangered plant and animal communities.
• Policy 4.D.1 Special-Status Species. Support the preservation of habitats of rare, threatened, endangered, and other special-status species. Require development in areas known to have value for wildlife to be carefully planned and, where possible, sited to maintain reasonable wildlife value of the habitat.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 7-10 November 2024 • Policy 4.D.3 Significant Biological Resources. Support and cooperate with the efforts of other local, State, and federal agencies and private entities engaged in the preservation and protection of significant biological resources from incompatible land uses and development, including efforts involving a Habitat Conservation Plan or other plan for habitat management or restoration.

Significant biological resources include endangered, threatened, or rare species and their habitats, wetland habitats, wildlife migration corridors, and locallyimportant species/communities. • Policy 4.D.5 Swainson’s Hawk Protection. Require that proposed development projects adhere to the following steps in order to ensure the protection of Swainson’s hawk in the Planning Area:
• If ground-disturbing activities would take place on sites where suitable nesting habitat may exist, a survey for nesting Swainson’s Hawks shall be conducted by a qualified wildlife biologist following survey methods developed by the Swainson’s Hawk Technical Advisory Committee (2000) prior to undertaking any grounddisturbing 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 hawk nests are found to be present, a no-disturbance buffer of a minimum of 0.5 miles shall be established around active nests until the breeding season has ended or until a qualified biologist has determined that the birds have fledged and are no longer reliant upon the nest or parental care for survival. If the 0.5-mile buffer is not feasible, the project proponent must consult with the California Department of Fish and Wildlife to determine if a smaller buffer would avoid take.

If it is determined that take cannot be avoided, the project proponent must acquire authorization through an Incidental Take Permit from the California Department of Fish and Wildlife in accordance with the California Endangered Species Act in order to continue. • Policy 4.D.6 Swainson’s Hawk Habitat Mitigation. Require mitigation for projects that would result in the loss of Swainson’s hawk foraging habitat within 10 miles of an active nest tree, which may include but is not limited to:
• For projects within one mile of an active nest tree, provide a minimum of one acre of habitat management land for each acre of development.
• For projects within between one and five miles of an active nest tree, provide a minimum of 0.75 acres of habitat management land for each acre of development.
• For projects within between five and 10 miles of an active nest tree, provide a minimum of 0.5 acres of habitat management land for each acre of development.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 7-11 November 2024 Alternative mitigation strategies are acceptable if approved by the California Department of Fish and Wildlife.

ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
Significance Thresholds
According to Appendix G of the CEQA Guidelines, a project may have a significant impact on biological resources if it would:
● Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or specialstatus species in local or regional plans, policies, or regulations, or by the CDFW or USFWS,
● Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the CDFW or USFWS,
● Have a substantial adverse effect on state or federally protected wetlands (including but not limited to marsh, vernal pool, coastal wetlands, etc.) through direct removal, filling, hydrological interruption, or other means, ● Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites, ● Conflict with local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance, or
● Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

The following analysis of environmental impacts focuses on the CTSP Area. The Pocket Area, which is already substantially developed, does not have substantial biological resources; therefore, project impacts on biological resources in that area would be less than significant.

Impact BIO-1: Special-Status Species
As indicated in Table 7-1, a CNDDB search found two special-status plant species and 15 special-status wildlife species that could potentially occur in the project vicinity. Most of these species, including both special-status plant species, are considered unlikely to occur in the CTSP Area due to lack of suitable habitat.

The CTSP proposes urban development in a predominantly rural area. As discussed in Chapter 5.0, Agricultural Resources, the CTSP anticipates the conversion of 319.5 acres of agricultural lands, mostly orchards, to urban development. This agricultural land conversion would be accompanied by a loss of associated biological values. These would include potential nesting and foraging habitat for special-status species such as Swainson’s EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 7-12 November 2024 hawk, listed as threatened under the California Endangered Species Act, and American bumble bee. Loss of habitat for these species is considered a potentially significant impact.

However, while Swainson’s hawk is considered a species that would occur in the area on more than a transitory basis, the American bumble bee is a transitory species that can find suitable habitat readily available in the project vicinity. Therefore, impacts on American bumble bee are considered less than significant.

Since the CTSP Area is mostly cultivated and has some urban development, there are very few natural lands there. However, it is possible that some portions of the CTSP Area may have natural vegetation such as blue elderberry shrubs. These shrubs provide habitat for the valley elderberry longhorn beetle, a species listed as threatened under the federal Endangered Species Act. Loss of elderberry shrubs would be considered a potentially significant impact.

Ceres General Plan Policy 4.D.5 requires that proposed development projects adhere to specified procedures to ensure the protection of Swainson’s hawk. These procedures are incorporated within one of the mitigation measures described below. Additional mitigation describes procedures to be followed should future development projects encounter blue elderberry shrubs. Implementation of these mitigation measures would reduce impacts on special-status species to a level that would be less than significant.

Level of Significance: Potentially significant
Mitigation Measures:

BIO-1: If ground-disturbing activities would take place on sites where suitable nesting habitat may exist, a survey for nesting Swainson’s hawks shall be conducted by a qualified wildlife biologist, consistent with survey methods developed by the Swainson’s Hawk Technical Advisory Committee (2000) prior to ground-disturbing activities. The biologist shall recommend mitigation measures for any potentially significant impacts resulting from the project.

If ground disturbing activities would take place during the nesting season (March 1 through August 31) and Swainson’s hawk nests are found to be present, mitigation measures may include establishing a no-disturbance buffer around active nests until the breeding season has ended or a qualified biologist determines that the birds have fledged.

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 guidelines.

Impacts After Mitigation: Less than significant
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 7-13 November 2024 Impact BIO-2: Riparian Areas and Other Sensitive Natural Communities As noted, no natural streams have been recorded in the CTSP or Pocket Area. The TID canals in the CTSP Area are maintained clear of vegetation. As such, there are no riparian areas on the project site. The CNDDB search did not identify any sensitive natural communities in the area, and none were identified in the Ceres General Plan EIR. Based on this, the project would have no impact on riparian areas or other sensitive natural communities.

Level of Significance: No impact
Mitigation Measures: None required
Impact BIO-3: Wetlands and Waters of the U.S.

As noted, no natural streams or wetlands have been recorded in the CTSP or Pocket Area.

The CTSP Area is presently developed with agricultural land use and limited urban uses, and the Pocket Area is predominantly urbanized and without water features; therefore, the project area does not have wetlands or waters that would be subject to Clean Water Act regulations.

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 is expected that future development would not directly affect the TID canals. However, the City proposes future storm drainage infrastructure serving future development in the CTSP Area that may include outfalls to the canals.

These outfalls may be subject to the Section 404 permitting process of the Corps. Corps permits typically contain conditions that are designed to minimize the environmental impacts of the permitted activity on the affected jurisdictional water. In addition, any physical changes to the canals would require permission from TID. As such, project impacts on wetlands and Waters of the U.S. are considered less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
Impact BIO-4: Migration Corridors and Nursery Sites
Well-developed riparian corridors are often utilized for movement by a wide range of wildlife species such as deer, coyote, red fox, and bobcat, as well as a variety of amphibians, reptiles, and fish. There are no riparian corridors in either the CTSP or Pocket Area. There are no continuous areas of native vegetation that would constitute potential wildlife movement corridors. Due to the lack of streams on or near the project, there are no fish movement corridors.

Existing trees within the CTSP Area could be used by migratory birds for roosting and nesting. It is possible that ground-nesting birds may nest in the CTSP Area, as well as songbirds in areas of dense grasses and weeds. Some of these birds could be protected by the Migratory Bird Treaty Act and the California Fish and Game Code. Mitigation EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 7-14 November 2024 presented below would avoid significant effects on nesting birds in the CTSP Area.

Implementation of this mitigation measure would reduce impacts on nesting birds to a level that would be less than significant.

Level of Significance: Potentially significant
Mitigation Measures:

BIO-3: If construction of a development project is to commence during the general avian nesting season (March 1 through July 31), a preconstruction survey for all species of nesting birds shall be conducted by a qualified biologist. If active nests are found, work in the vicinity of the nests shall be delayed until the young have fledged as determined by the biologist. No survey is required if construction is to occur outside the general avian nesting season.

Significance After Mitigation: Less than significant
Impact BIO-5: Local Policies and Ordinances
The Ceres General Plan has goals and policies intended to protect biological resources.

Applicable goals and policies are listed in the Regulatory Framework section above.

Through its development plan and regulatory framework, the CTSP implements the goals and policies of the City’s General Plan by providing specific direction for development activity in the CTSP Area. These include protection of biological resources. As noted in Impact BIO-1, impacts of the CTSP on Swainson’s hawk would be reduced through the implementation of Mitigation Measure BIO-1, which is consistent with Ceres General Plan Policy 4.D.5.

Neither the City of Ceres nor Stanislaus County has ordinances protecting biological resources, such as a tree preservation policy. Therefore, the project would not conflict with any such ordinances. Overall, project impacts related to local policies and ordinances on biological resources would be less than significant with mitigation.

Level of Significance: Potentially significant
Mitigation Measures: Implementation of Mitigation Measure BIO-1 Significance After Mitigation: Less than significant
Impact BIO-6: Conflict with Adopted Habitat Conservation Plan or Natural Community Conservation Plan
Pacific Gas & Electric (PG&E) has prepared a multi-species Habitat Conservation Plan (HCP) for PG&E’s natural gas and electrical transmission and distribution facilities, the lands owned by PG&E and/or subject to PG&E easements for these facilities, private access routes to infrastructure associated with operation and maintenance activities, minor facility expansion areas, and mitigation areas for impacts resulting from covered activities.

The HCP covers portions of nine counties, including Stanislaus County. However, the project site does not have any PG&E facilities. As discussed in Chapter 17.0, Utilities and Energy, electrical service is provided by TID, and TID facilities are not covered by any EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 7-15 November 2024 HCP. PG&E has interregional natural gas mains along the SR 99 corridor, but future development under the CTSP or in the Pocket Area is not expected to affect these mains.

There are no other HCPs applicable to the project site, and the project site is not covered by any Natural Community Conservation Plan or by any regional or local conservation plan. Therefore, the project would not conflict with any type of habitat conservation plan.

The project would have no impact on this issue.

Level of Significance: No impact
Mitigation Measures: None required
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 8-1 November 2024

8.0 CULTURAL RESOURCES AND
TRIBAL CULTURAL RESOURCES
ENVIRONMENTAL SETTING
Prehistoric Setting
The City of Ceres and the surrounding area are part of the ethnographic territory of the Northern Valley Yokuts, who inhabited the Central Valley from the Diablo Range in the west to the Sierra Nevada foothills in the east. The Yokuts were divided into 50 tribelets, based on linguistic variations, and primarily lived in large settlements along the banks of rivers and their tributaries.

The Yokuts used several dwelling types, including a mat-covered, gabled kawi, or communal dwelling; a wedge-shaped tule house, in which only one family lived; small, elliptical tule houses; conical, tule-covered dwellings that were placed in rows; and a bark house called a samish. A wide variety of foods were available to the Yokuts, who gathered many varieties of plants and seeds, in addition to hunting small game, fishing, and shellfishing. Where acorns were available, they served as a primary component of their subsistence. The Yokuts maintained trade links with coastal villages where they traded furs and other materials for shells, such as abalone and clams. Shell disks and dentalium beads, as well as polished, cylindrically-shaped magnesite rocks and bivalves, were used as money.

The late prehistoric Yokuts may have been the largest ethnic group in pre-contact California. European settlement of the territory led to a rapid decline in the Yokuts population due to conflicts, disease epidemics, and other forms of upheaval (City of Ceres 2018a). Despite this, the Yokuts tribe continues to exist today; the Nototomne/North Valley Yokut Tribe, Inc., represents the Northern Valley Yokuts in the region.

Historic Setting
The Euro-American presence in the area began with infrequent excursions by Spanish explorers traveling through the Sacramento-San Joaquin Valleys in the late 1700s to early 1800s. The City of Ceres was founded by Daniel Whitmore, who arrived in the Ceres area in 1867. The Whitmore family eventually acquired 9,000 acres, which included what would later become the town site of Ceres. By 1875, Daniel Whitmore’s brother, R.K. Whitmore, had surveyed the area, and a map was filed for the layout of the town. In 1872, the railroad crossed the Tuolumne River into Ceres, and the town became a flag stop. A few years later, a depot was built, and Mr. Whitmore had petitioned for a post office. The town was named "Ceres" - the name Daniel Whitmore had used in commenting on the first wheat crops - by Elma Carter, one of the town's residents.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 8-2 November 2024 In the late 1880s, in response to thriving agriculture, the Modesto and Turlock Irrigation Districts were created to allow local farmers to irrigate crops more efficiently and effectively. Dairy farming was also introduced into the area during this period. By the early 1900s, Ceres was still a small town, yet its population was growing at a steady rate. Ceres was incorporated in 1918 with a population of 1,000.

Ceres had a population of 1,332 before World War II, but the population nearly doubled after the postwar boom and reached 2,351 by 1950. Like most California cities, Ceres experienced residential growth during the post-World War II period. Subdivisions, including the Caswell Tract and Morrow Village, were established and new elementary and middle schools and a hospital were built. In 1968, Caltrans modernized SR 99, which traveled through the community of Ceres. The highway project bisected Ceres and resulted in the demolition of most of the central business district. However, the improved highway also brought growth and expansion to the city. By 1970, the population reached a high of 6,000. Ceres continued to grow in the 1980s, and by 1990 its population was 25,000. (City of Ceres 2018a).

During the preparation of this EIR, BaseCamp contacted the Central California Information Center (CCIC) at CSU Turlock to obtain a search of historical and archaeological records for the project area; the CCIC is a part of the California Historical Resources Information System (CHRIS). The CCIC search included:

CCIC map files
National Register of Historic Places (NRHP)
California Register of Historical Resources (CRHR)
California Inventory of Historic Resources (1976)
California Historical Landmarks
California Points of Historical Interest listing
Office of Historic Preservation Built Environment Resource Directory (BERD) and the Archaeological Resources Directory Survey of Surveys (1989) Caltrans State and Local Bridges Inventory
General Land Office Plats
Other pertinent historic data
The results of this search were provided by CCIC in a letter, which is available in Appendix E. The CCIC noted that there are no formally recorded prehistoric or historic archaeological resources within the search area. There are 20 historic buildings (single family properties) and two historic structures (Southern Pacific Railroad and the TID Ceres Main Canal) formally recorded on or adjacent to the project area; a list of these properties is provided in the CCIC report. Nineteen of the single-family properties and the Southern Pacific Railroad are referenced in the Office of Historic Preservation BERD with the EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 8-3 November 2024 evaluation status of “6Y”, which are properties determined ineligible for the National Register listing by consensus through the Section 106 process; these properties have not been evaluated for the California Register of Historical Resources listing or for local listing.

As documented in the CCIC report, despite the fact that numerous archaeology and historic resource studies have occurred in and near the CTSP Area over the years 1980-2017no archaeological resources have been recorded within the project vicinity (CCIC 2023).

On May 23, 2024, the City provided AB 52/SB 18 notice of the project to tribes having previously requested it in conjunction with the Notice of Preparation for the project, as well as to other tribes on a contact list provided by the NAHC; AB 52 and SB 18 requirements are discussed in detail in the following section. In all, a total of seven tribes were contacted:

Amah Mutsun, Calaveras Band of Mi-Wuk, California Valley Miwok, Northern Valley Yokuts, Southern Sierra Miwuk, Tule River, and Wuksachi/Eshom Valley Band. No correspondence, requests for information or consultation or any other indications of tribal cultural resources concern were received by the City from the contacted tribes. Therefore, the City considers its AB 52/SB 18 obligations fulfilled.

REGULATORY FRAMEWORK
National Historic Preservation Act
The National Historic Preservation Act was enacted in 1966 to encourage the preservation and wise use of the country’s historic resources. The Act defines historic preservation to include “the protection, rehabilitation, restoration, and reconstruction of districts, sites, buildings, structures, and objects significant in American history, architecture, archaeology, or culture.”
The Act established the NRHP. The eligibility criteria for the NHRP are quoted in full, as follows:

The quality of significance in American history, architecture, archeology, engineering, and culture is present in districts, sites, buildings, structures, and objects that possess integrity of location, design, setting, materials, workmanship, feeling, and association, and:

A. That are associated with events that have made a significant contribution to the broad patterns of our history; or
B. That are associated with the lives of significant persons in or past; or C. That embody the distinctive characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or
D. That have yielded or may be likely to yield, information important in history or prehistory.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 8-4 November 2024 Previous surveys have been conducted that determined the eligibility of sites in the Ceres area for NRHP listing (Figure 8-1). The Daniel Whitmore Home, at 2928 5th Street, is listed on the NRHP, none within the project area. Numerous other buildings were determined to not be eligible for NRHP listing (City of Ceres 2016a), including those listed in the CCIC report.

California Office of Historic Preservation
The California Office of Historic Preservation offers four different historical resource registration programs: California Historical Landmarks, California Points of Historical Interest, CRHR, and the NRHP in cooperation with the National Park Service. Each registration program is unique in the benefits offered and procedures required. If a resource meets the criteria for registration, it may be nominated by any individual, group, or local government to any program at any time. Resources do not need to be locally designated before being nominated to a state program, nor do they need to be registered at the state level before being nominated to the NRHP.

The CRHR program encourages public recognition and protection of resources of architectural, historical, archaeological, and cultural significance, identifies historical resources for state and local planning purposes, determines eligibility for state historic preservation grant funding, and affords certain protections under CEQA. Resources on the CRHR have met criteria for designation or have been included due to their presence on the NRHP, the State Historical Landmark program, or the California Points of Historical Interest program. The Daniel Whitmore Home and the 7th Street Bridge (the Lion Bridge) over the Tuolumne River are listed on the CRHR.

CEQA Guidelines Section 15064.5
Criteria specified in CEQA Guidelines Section 15064.5 suggest that an "important historical or archaeological resource" is one which generally meets the criteria for listing in the CRHR, including the following:
● Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage; ● Is associated with the lives of persons important in California’s past; ● Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic value; or
● Has yielded, or may be likely to yield, information important in prehistory or history.

If a resource does not meet any of the above criteria, it does not preclude a lead agency from determining that a resource may be a historical resource as defined in Public Resources Code Sections 5020.1(j) or 5024.1.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 8-5 November 2024 SB 18
SB 18, which became effective in 2005, permits California Native American tribes recognized by the Native American Heritage Commission (NAHC) to hold conservation easements on terms mutually satisfactory to the tribe and the landowner. “California Native American tribe” is defined to include federally recognized California Native American tribes and non-federally recognized California Native American tribes that are on a contact list maintained by the NAHC. SB 18 requires that, prior to the adoption or amendment of a general plan or a specific plan, the city or county consult with California Native American tribes for the purpose of preserving specified places, features, or objects located within the city’s or county’s jurisdiction. The planning agency shall provide the tribes specified by the NAHC with opportunities for involvement in the preparation of the general plan or specific plan.

AB 52
In 2014, the California Legislature enacted Assembly Bill (AB) 52, which requires CEQA consultation with Native American tribes on projects that could potentially affect resources of value to the tribes. The intent of this consultation is to avoid or mitigate potential impacts on “tribal cultural resources,” which are defined as sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe.

Under AB 52, consultation with tribes on a notice list shall be initiated prior to the release of the CEQA document for public review. When a tribe requests consultation, the lead agency must provide the tribe with notice of a proposed project within 14 days either of a project application being deemed complete or when the lead agency decides to undertake the project if it is the agency’s own project. The tribe has 30 days from receipt of the notification letter to respond in writing, including the designation of a lead contact person.

If the tribe requests consultation, then the lead agency has up to 30 days after receiving the tribe’s request to initiate formal consultation. The consultation process ends when either (1) the resource in question is not considered significant, (2) the parties agree to mitigate or avoid a significant effect on a tribal cultural resource, or (3) a party, acting in good faith and after reasonable effort, concludes that mutual agreement cannot be reached. Regardless of the outcome, a lead agency is still obligated under CEQA to mitigate any significant environmental effects, as explicitly noted in AB 52.

ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
Significance Thresholds
According to Appendix G of the CEQA Guidelines, a project may have a significant impact on cultural resources if it would:
● Cause a substantial adverse change in the significance of a historical resource as defined in CEQA Guidelines Section 15064.5,
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 8-6 November 2024 ● Cause a substantial adverse change in the significance of an archaeological resource as defined in CEQA Guidelines Section 15064.5, ● Disturb any human remains, including those interred outside of formal cemeteries.

Also, a project may have a significant impact on the environment if it would cause a substantial adverse change in the significance of a tribal cultural resource, defined in California Public Resources Code Section 21074 as a site, feature, place, sacred place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, or object with cultural value to a California Native American tribe, and that is:
● Listed or eligible for listing in the California Register of Historical Resources or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k), or
● A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in Public Resources Code Section 5024.1(c). In applying the Section 5024.1(c) criteria, the lead agency shall consider the significance of the resource to a California Native American tribe.

Impact CULT-1: Historical Resources
The Ceres General Plan EIR evaluated the presence of existing historical resources in the Planning Area, including the project site. Within the Planning Area, only four historical resources were identified: the Whitmore Mansion, the Daniel Whitmore Home, the Seventh Street Bridge, and the site of the Davis and Maze Ferry. None of these resources are located within or near the CTSP Area.

The CTSP Area contains existing residences, some of which may be considered historical resources. Under criteria established by the National Register of Historic Places, a historical property generally must be at least 50 years old to be considered for inclusion. It is possible that some existing residences within the CTSP Area are at least 50 years.

Demolition or other alteration of such buildings that are eligible for listing on either the National or California Register could constitute a potentially significant cultural resource impact under CEQA. The mitigation measure below would identify potential historical resources and procedures to address potential impacts. Implementation of this mitigation measure would reduce project impacts on historical resources to a level that would be less than significant.

Level of Significance: Potentially significant
Mitigation Measures:

CULT-1: Based on a determination of potential historical value by the Community Development Director, existing buildings or other structures on the site that are 50 years of age or older that are planned to be removed shall be evaluated by a qualified architectural historian EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 8-7 November 2024 to determine if they are eligible for listing on the National Register of Historic Places and/or the California Register of Historical Resources.

This evaluation shall be conducted prior to issuance of a demolition permit. 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.

Significance After Mitigation: Less than significant
Impact CULT-2: Archaeological Resources
The GPEIR evaluated the potential presence of archaeological and historic resources in the Planning Area, including the project area. The Ceres General Plan and EIR indicate that unspecified prehistoric and historic archaeological resources have been found in the Ceres Planning Area. There is the potential for the discovery of archaeological resources near the Tuolumne River (City of Ceres 2018a).

A data base search conducted during the preparation of this EIR found that no known archaeological resources have been recorded within the CTSP Area. The City provided notice of the project to a total of seven tribes during the preparation of this EIR; however, o correspondence, requests for information or consultation or any other indication of tribal concern were submitted by the contacted tribes. Therefore, the City considers the project area to be of relatively low tribal sensitivity and considers its AB 52/SB 18 obligations fulfilled.

The potential for encounter of archaeological resources or tribal cultural resources to be relatively low. Nonetheless, project construction activities have the potential to unearth and disturb previously undiscovered and potentially significant subsurface archaeological resources. Should this occur without adequate protection plans, this would be a potentially significant impact. Mitigation measures below outline procedures for inadvertent discovery of previously unknown archaeological resources. Implementation of these measures would reduce project impacts on archaeological resources to a level that would be less than significant.

Level of Significance: Potentially significant
Mitigation Measures:

CULT-2: If subsurface cultural resources are encountered within the Copper Trails Specific Plan area during project construction, 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 measures that would reduce EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 8-8 November 2024 potential effects on the find to a level that is less than significant.

Construction activities in the vicinity of the find shall not resume until the mitigation measures are established. 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 Community Development Department, consistent with the requirements of the CEQA Guidelines.

Significance After Mitigation: Less than significant
Impact CULT-3: Tribal Cultural Resources
As noted, tribal cultural resources are defined as sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe. The GPEIR stated that a search of the Sacred Lands File maintained by the NAHC in 2017 yielded negative results for the Planning Area. Given this and the lack of responses from local tribes to invitations to consult on the project per AB 52/SB 18, it is unlikely that any tribal cultural resources would be affected by the project.

As with archaeological resources, construction activities have the potential to unearth and disturb previously undiscovered and potentially significant subsurface tribal cultural resources, including Native American burials. The procedures required to be followed when unknown cultural resources are encountered outside a dedicated cemetery are defined in State law and encompassed by the following mitigation measure CULT-3.

California Health and Safety Code Section 7050.5 describes the procedure to be followed when human remains are uncovered in a location outside a dedicated cemetery. All work in the vicinity of the find shall be halted and the County Coroner shall be 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 provisions of California Health and Safety Code Section 7050.5 must be observed. 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 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 must rebury the remains and associated grave goods with appropriate dignity on the property in a location not subject to further disturbance.

Overall, it is not likely that project development would encounter any tribal cultural resources. However, should such resources be encountered, implementation of Mitigation Measure CULT-3, along with compliance with State codes applicable to the discovery of human remains, would reduce project impacts on tribal cultural resources to a level that would be less than significant.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 8-9 November 2024 Level of Significance: Potentially significant
Mitigation Measures:

CULT-3: If any human burials and/or associated funerary objects are encountered during construction, all construction activities within a 50-foot radius of the encounter shall be halted until the County Coroner and the City have been notified, If the Coroner determines that the remains are Native American in origin, then the Coroner must contact the Native American Heritage Commission within 24 hours and take other steps as required by California Health and Safety Code Section 7050.5.

A qualified archaeologist shall be retained by the contractor to examine the materials, evaluate their significance. and, in consultation with a tribal representative if needed, recommend mitigation measures needed to reduce potential effects to a level that is less than significant in a written report to the City. Construction activities in the area of the find shall not resume until the mitigation measures are established.

The contractor shall be responsible for retaining qualified professionals, implementing recommended mitigation measures, and documenting mitigation efforts in written reports to the City.

Significance After Mitigation: Less than significant
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 9-1 November 2024

9.0 GEOLOGY AND SOILS
ENVIRONMENTAL SETTING
Topography and General Geology
The CTSP area, together with the City of Ceres, is near the center of California's Central Valley, a large, northwest-trending, sediment-filled trough, which extends more than 400 miles from the Tehachapi Mountains in the south to the Cascade Range on the north. More specifically, the project site is in the San Joaquin Valley, the portion of the approximate southern portion of the Central Valley drained by the San Joaquin River. The San Joaquin Valley is a basin filled with deep layers of sediment accumulated over geologic time; surface soils consist mainly of alluvial sediments from the Sierra Nevada and Coast Ranges. The topography of Ceres and its surroundings is nearly flat, with elevations of about 80 to 100 feet above sea level (City of Ceres 2018a). The entire project site likewise has a nearly flat topography, with elevations ranging from 80 to 90 feet above sea level.

The Geologic Map of the San Francisco-San Jose Quadrangle shows that the project site is underlain mainly by the Modesto Formation (Wagner et al., 1991). The Modesto Formation is composed of arkosic alluvial deposits of tan and light gray gravely sand, silt, and clay.

The Modesto Formation can be differentiated into an upper member and a lower member.

The upper member consists of fine to medium sand and is exposed in some terraces and fans associated with major Sierra Nevada rivers, including the Tuolumne River north of Ceres. The lower member consists primarily of sand, with stratified deposits of silt and fine sand, and is associated with alluvial fans covering an extensive part of the northeastern San Joaquin Valley (City of Ceres 2018a).

Seismicity and Other Geological Conditions
The nearest “active” faults (those that have been active in the last 200 years) are about 40 miles away from the Ceres area - the Greenville Fault and Los Positas Fault near Livermore. Nearby potentially active faults that have not had displacement in the past 200 years include much of the Greenville Fault 30 miles west of Ceres and the Ortigalita Fault 25 miles to the southwest. The nearest potentially active fault line is about 11 miles northwest of Ceres (City of Ceres 2018a). Due to the absence of active faults in the Ceres area, the risk of surface rupture, or the breaking of the ground along a fault during an earthquake, is practically nonexistent.

Because there are no known active earthquake faults in the Ceres area, seismic activity is considered minimal. However, the active and potentially active faults in the region can subject Ceres to substantial groundshaking. Groundshaking effects can vary depending on the overall magnitude, distance to the fault, focus of earthquake energy, and type of geologic material, and can result in damage to or the collapse of buildings and other structures. On September 18-19, 2023, a series of earthquakes occurred in southwestern Stanislaus County, including one of 4.5 magnitude centered approximately nine miles EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 9-2 November 2024 southwest of the community of Westley. No damage or injuries were reported to have occurred in Ceres from these earthquakes.

Types of seismic ground failure include liquefaction, lateral spreading, subsidence, and landslides. Liquefaction is the rapid transformation of saturated, loose, fine-grained sediment, such as silt and sand, into a fluid state as a result of severe ground motion. Lateral spreading refers to a type of landslide that forms on gentle slopes and has rapid fluid-like movement. Factors determining the potential for liquefaction and lateral spreading are soil type, the level and duration of seismic ground motions, the type and consistency of soils, and the depth to groundwater. Due to the well-drained, relatively stable soils, distance from active faults, and depth of the groundwater table (at least 20 feet), the risk of liquefaction and lateral spreading in the Ceres area is low (City of Ceres 2018a).

Subsidence occurs when a large portion of land is displaced vertically. This typically is due to the withdrawal of groundwater, oil, or natural gas. In the Ceres area, this would most likely occur with the removal of groundwater from the Turlock Groundwater Subbasin.

Chapter 12.0, Hydrology and Water Quality, discusses the Turlock Subbasin in detail.

Shrink-Swell of soils is more likely to occur in soils with high clay content, as these soils have a higher potential for aquifer compaction. Soils in the Planning Area, however, have low clay content, and thus have a lower potential for shrink-swell concerns (City of Ceres 2018a).

A landslide is the downhill movement of masses of earth material under the force of gravity. Landslides are most likely to occur on sloped areas. As the Ceres area is relatively flat, it has almost no potential for landslides, except for steep banks along the Tuolumne River (City of Ceres 2018a). As noted, the project area is nearly flat and is approximately three miles from the Tuolumne River.

There are no other geological hazards identified in the Ceres area. The nearest site identified with volcanic activity – the Long Valley Caldera in Mono County – is approximately 120 miles to the east. The Ceres area is not subject to tsunami or seiche hazards, as it is not located near any large bodies of water where such events may occur.

Soils
Soil types within the project site are identified in the Natural Resource Conservation Service Web Soil Survey, based on information in the Soil Survey of the Eastern Stanislaus Area (SCS 1964, NRCS 2023). Technical soils information is provided in Table 9-1 below, and Figure 9-1 shows locations of these soil types. Determination as to whether a soil is prime agricultural soil is made based on Stanislaus LAFCo Policies and Procedures, which defines “prime agricultural land” in part as land that qualifies, if irrigated, for rating as class I or class II in the Natural Resources Conservation Service land use capability classification. The land does not actually have to be irrigated, only that irrigation of the land is feasible (Stanislaus LAFCo 2020).

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 9-3 November 2024 TABLE 9-1

SOILS ON PROJECT SITE
Name
Capability
Class
Prime
Ag Land Drainage Permeability
Erosion
Hazard Runoff
DkA- Dello
loamy sand
Class 3
(irrigated)
No Imperfect
to very
poor
Very rapid None Very slow
DrA – Dinuba
sandy loam
Class 2
(irrigated)
Yes Imperfect Moderate Slight Very slow
DuA- Dinuba
sandy loam,
poorly drained
Class 3
(irrigated)
No Poor Moderate None Ponded
DwA- Dinuba
sandy loam,
slightly salinealkali
Class 2
(irrigated)
Yes Imperfect Slow Slight Very slow
HdA – Hanford
sandy loam (0-
3% slopes)
Class 1
(irrigated)
Yes Good Rapid Slight Very slow
HdB – Hanford
sandy loam (3-
8% slopes)
Class 2
(irrigated)
Yes Good Rapid Slight Slow
HdpA – Hanford
sandy loam,
moderately deep
over silt
Class 2
(irrigated)
Yes Good Rapid Slight Very slow
TuA – Tujunga
loamy sand
Class 3
(irrigated)
No Somewhat
excessive
Very rapid Slight,
moderate
wind erosion
on fans
Very slow
Sources: SCS 1964, Stanislaus LAFCo 2020, NRCS 2023.

The predominant sandy loam soils (Dinuba and Hanford) are prime soils for agriculture, while the loamy sand soils (Dello and Tujunga) are not considered prime agricultural soils.

This classification roughly corresponds to the state mapping of Prime Farmlands and Farmlands of Statewide Significance discussed in Chapter 5.0, Agricultural Resources.

Existing agricultural use of the CTSP Area and the potential impacts of the project on that use are addressed in more detail in Chapter 5.0.

Expansive soils have shrink-swell capacity, meaning they may swell when wetted and shrink when dried. Expansive soils can be a hazard for built structures, and may cause cracks in building foundations, distortion of structural elements, and warping of doors and windows, along with potential damage to infrastructure. The higher the clay content of a soil, the higher its shrink-swell potential. Soils in the Ceres area, including those on the project site, have relatively low clay content and therefore low shrink-swell potential (City of Ceres 2018a).

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 9-4 November 2024 Paleontological Resources
Paleontological resources are fossils or groups of fossils that are unique, unusual, rare, uncommon, or important, and those that add to an existing body of knowledge in specific areas. Surface examination of a study or project area often does not reveal whether paleontological resources are present. The University of California Museum of Paleontology database contains 765 records of vertebrate fossils found in Stanislaus County. California’s Pleistocene sedimentary units—especially those that, like the Modesto and Riverbank Formations, record deposition in continental settings—are typically considered highly sensitive for paleontological resources because of the large number of recorded fossil finds in such units throughout the state (Stanislaus County 2016b). As noted, the project site is underlain by the Modesto Formation. However, no known paleontological resources have been uncovered in the Ceres area to date (City of Ceres 2018a).

Mineral Resources
The predominant mineral resources in Stanislaus County are sand and gravel, also known as “aggregate.” Aggregate resources are important because of their key role in most construction; aggregate typically cannot be replaced with other products and are most economical when used close to the area where they are mined because of the high cost of transportation. Mining activities occur primarily within fluvial deposits along river and stream drainages (Stanislaus County 2016b). The Ceres General Plan does not identify any mineral resources in the Planning Area, which includes the project site (City of Ceres 2018b).

Oil and natural gas deposits have been identified throughout the Central Valley; however, there are few active fields within Stanislaus County. The nearest active field to the project site is the Oakdale natural gas field, approximately 12 miles to the northeast. The project site does not contain any oil or natural gas fields (DOGGR 2023).

REGULATORY FRAMEWORK
Federal
National Pollution Discharge Elimination System
In California, the SWRCB and, in the Ceres area, the Central Valley Regional Water Quality Control Board (RWQCB) administer the National Pollution Discharge Elimination System (NPDES) program. The NPDES permit system was established as part of the Federal Clean Water Act to regulate both point source discharges and non-point source discharges to surface water of the United States, including the discharge of soils eroded from construction sites.

The NPDES program consists of characterizing receiving water quality, identifying harmful constituents (including siltation), targeting potential sources of pollutants (including excavation and grading operations), and implementing a comprehensive stormwater management program. Construction and industrial activities typically are EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 9-5 November 2024 regulated under statewide general permits that are issued by the SWRCB. Additionally, the SWRCB issues Waste Discharge Requirements that also serve as NPDES permits under the authority delegated to the RWQCBs, under the Clean Water Act. Chapter 12.0, Hydrology and Water Quality, provides more information about the NPDES.

State
Alquist-Priolo Earthquake Fault Zoning Act
The Alquist-Priolo Earthquake Fault Zoning Act, enacted in 1972 and subsequently amended, prohibits the location of most structures for human occupancy across the traces of active faults, thereby mitigating the hazard of fault rupture. Under the Act, the State Geologist is required to delineate Earthquake Fault Zones along known active faults in California. Cities and counties affected by the zones must regulate certain development projects within the zones, withholding development permits for sites within the zones until geologic investigations demonstrate that the sites are not threatened by surface displacement from future faulting (Bryant and Hart 2007).

The project site Is not within an area mapped by the State Geologist as a “Zone of Required Investigation,” which includes Alquist-Priolo Earthquake Fault Zones. A Zone of Required Investigation is established where required to reduce the threat to public health and safety and to minimize the loss of life and property posed by earthquake-triggered ground failures (California Geological Survey 2024).

Seismic Hazards Mapping Act
The Seismic Hazards Mapping Act was passed in 1990 to address earthquake hazards such as seismically induced liquefaction and landslides, with the purposes of reducing the threat to public health and safety and minimizing the loss of life and property that may result from earthquake-triggered ground failure. Under the Act, seismic hazard zones are mapped through the Seismic Hazards Zonation Program of the California Geological Survey to identify areas prone to earthquake-induced liquefaction, landslides, and amplified ground shaking. Section 2697(a) of the Act states that, prior to the approval of a project located in a seismic hazard zone, cities and counties shall require a geotechnical report defining and delineating any seismic hazard. As noted, the project site is not within an area mapped by the State Geologist as a Zone of Required Investigation, which includes Seismic Hazards Mapping Act zones.

California Building Code
The California Building Code is in Title 24 of the California Code of Regulations and incorporates the International Building Code, a model building code adopted across the United States. The California Building Code is updated every three years, and the 2022 version took effect January 1, 2023. The City of Ceres has adopted the 2022 California Building Code by reference.

The California Building Code contains building requirements that address likely ground shaking hazards that may occur in the Ceres area. It can require detailed soils and/or geotechnical studies in areas of suspected geological hazards, such as unstable geologic EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 9-6 November 2024 units that may be subject to collapse, subsidence, landslides, liquefaction, or lateral spreading.

Construction General Permit
Construction projects that involve one acre or more of ground disturbance are required to obtain a Construction General Permit, issued by the SWRCB. Discharges subject to the Construction General Permit must develop and implement a Storm Water Pollution Prevention Plan (SWPPP). The SWPPP includes a site map and description of construction activities and identifies the Best Management Practices (BMPs) that will be employed to prevent soil erosion and discharge of other construction-related pollutants that could contaminate nearby water resources. A monitoring program is generally required to ensure that BMPs are implemented according to the SWPPP and are effective at controlling discharges of stormwater-related pollutants.

Modifications to the Construction General Permit in 2010 established BMPs and monitoring requirements through a “risk-based” approach. Construction activities would be assessed for the risk that erosion and sedimentation generated by the activity would pose to water quality in the area, based on potential rainfall likelihood and intensity and on the sensitivity of waters receiving runoff from the construction site.

Surface Mining and Reclamation Act
As mandated by the Surface Mining and Reclamation Act, the California Geological Survey has classified mineral resource development potential of lands in counties into an appropriate Mineral Resource Zone (MRZ), in accordance with the California Mineral Land Classification System. Local agencies are required to use this information when developing land use plans and when making land use decisions. The MRZ classifications include:

MRZ-1–- Areas of No Mineral Resource Significance
MRZ-2–- Areas of Identified Mineral Resource Significance MRZ-3–- Areas of Undetermined Mineral Resource Significance MRZ-4–- Areas of Unknown Mineral Resource Significance
Neither the City of Ceres nor the Stanislaus County General Plans have identified any mineral resources on or near the project site in accordance with MRZ designations.

Local
Ceres Municipal Code
Section 17.05.040(D)(9) requires an applicant for a subdivision map to submit a preliminary soil report, prepared by a State registered civil engineer. The report shall be based on adequate test borings or excavations. If the preliminary soils report indicates the presence of critically expansive soils or other soil problems that would lead to structural defects if not corrected, the Community Development Director may require a soils EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 9-7 November 2024 investigation covering each lot in the subdivision as a precedent to consideration of the tentative map. The soils investigation shall be done in the manner provided in Government Code Section 66491, part of the Subdivision Map Act. Section 17.05.040(D)(11) also requires a preliminary grading plan; however, this plan may be waived by the Community Development Director when it is determined that the submittal of said plan is not required for proper grading, flood hazard mitigation, and erosion control of the proposed subdivision.

ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
Significance Thresholds
According to Appendix G of the CEQA Guidelines, a project may have a significant impact on geology, soils, and mineral resources if it would:
● Indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death, involving rupture of a known earthquake fault, strong seismic ground shaking, seismic-related ground failure (including liquefaction), or landslides.
● Result in substantial soil erosion or the loss of topsoil, ● Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse, ● Be located on expansive soil as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property,
● Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater [Since the project would connect to the City’s wastewater system; it would not use septic tanks or alternative wastewater disposal systems. Therefore, this issue is not analyzed in this EIR], ● Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature,
● Result in the loss of availability of a known mineral resource that would be of value to the region and residents of the state, or
● Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 9-8 November 2024 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. New development would be exposed to potential ground shaking associated with earthquake activity occurring on more distant fault systems. However, routine implementation and enforcement of the California Building Code adopted at the time of proposed development, including its seismic safety provisions that address design specifications related to seismic forces, would reduce the potential for earthquake damage to a level that is generally regarded by structural engineers throughout California as acceptable. Therefore, project impacts are considered less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
Impact GEO-2: Soil Erosion
Planned development of the CTSP and Pocket Areas would involve ground disturbance during mass grading and other construction activities. While soils would be exposed to potential water and wind erosion, the site is relatively flat, and the sandy loams and loamy sands of the project area are not highly susceptible to erosion. In the Pocket Area, new development would be limited, as most of this area is already developed.

New development would be required to comply with the City’s Storm Water Management Program, which is further discussed in Chapter 12.0, Hydrology and Water Quality.

Among other requirements, the program requires the incorporation of construction and post-construction BMPs that limit soil erosion. In addition, development projects of one acre or more would be required to obtain a Construction General Permit from the SWRCB, provisions of which include preparation of a SWPPP. Compliance with these requirements would mitigate potential erosion impacts to a level that is less than significant. Potential erosion-associated water quality impacts and the application of the referenced storm water requirements are discussed in more detail in Chapter 12.0, Hydrology and Water Quality.

Level of Significance: Less than significant
Mitigation Measures: None required
Impact GEO-3: Exposure to or Effects on Unstable Geologic Units or Soils Some improvements associated with implementation of the CTSP could be located on geologic units or soils that are unstable, or that could become unstable and result in geologic hazards if not addressed appropriately. Areas with underlying materials that include undocumented fills, soft compressible deposits, or loose debris could be inadequate to support development, especially multi-story buildings.

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 to determine the local soil suitability for specific projects in accordance with standard industry practices and state-provided requirements, such as California Building Code EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 9-9 November 2024 requirements that are used to minimize the risk associated with these hazards. In addition, Ceres Municipal Code Section 17.05.040 requires an applicant for a subdivision map to submit a preliminary soil report, prepared by a registered civil engineer who is registered by the State. If the preliminary soils report indicates the presence of critically expansive soils or other soil problems that would lead to structural defects if not corrected, the Community Development Director may require a soils investigation covering each lot in the subdivision as a precedent to consideration of the tentative map. Implementation of this Municipal Code provision would further reduce the potential for project exposure to any potential geologic hazards. Project impacts related to unstable soils would be less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
Impact GEO-4: Expansive Soils
Soils located within the project site do not have a high shrink-swell potential, as they are sandy loams or loamy sands, which have a relatively low clay content. As noted, Ceres Municipal Code Section 17.05.040 requires the preparation of soil and/or geotechnical reports in conjunction with a tentative subdivision map. Applicants are held responsible for complying with recommendations in the soils and geotechnical reports. With implementation of geotechnical report recommendations, any potential expansive soil impacts would be less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
Impact GEO-5: Adequacy of Soils for On-Site Wastewater Disposal Systems Future development within the project site would be served by the City of Ceres wastewater collection and treatment system. As discussed in Chapter 17.0, Utilities and Service Systems, sufficient collection line and treatment capacity is or will be available to accommodate CTSP or Pocket Area development. Annexation and CTSP approval would not involve or further the use of on-site septic tanks or alternative wastewater treatment systems; therefore, the project would have no impact on this issue.

Level of Significance: No impact
Mitigation Measures: None required
Impact GEO-6: Paleontological Resources
The project site does not contain any known paleontological resources or unique geological features. However, the project site is underlain by the Modesto Formation, which has been known to yield fossils in the past. Therefore, it is conceivable that excavation associated with future land development activities could unearth paleontological materials of unknown significance. Mitigation described below would establish procedures to address paleontological discoveries if they should occur. Implementation of this mitigation EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 9-10 November 2024 measure would reduce potential project impacts on paleontological resources to a level that would be less than significant.

Level of Significance: Potentially significant
Mitigation Measures:

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.

Significance After Mitigation: Less than significant
Impact GEO-7: Mineral and Energy Resources
As discussed in the Environmental Setting, there are no known mineral or energy resources present within the project site, including oil or natural gas deposits. As such, future development would not affect the availability of or access to mineral resources. The project would have no impact on this issue.

Level of Significance: No impact
Mitigation Measures: None required
EXHIBIT B ITEM 13
Figure 9-1
BaseCamp Environmental SOIL TYPES
SOILS
DuA - Dinuba sandy loam,
poorly drained
DwA - Dinuba sandy loam,
slightly saline - alkali
HdA - Handford sandy loam
(0-3% slopes)
HdB - Hanford sandy loam
(3-8% slopes)
HdpA - Hanford sandy loam,
moderately deep over silt
TuA - Tujunga loamy sand
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 10-1 November 2024

10.0 GREENHOUSE GAS EMISSIONS
ENVIRONMENTAL SETTING
Global Climate Change and Greenhouse Gases
Global climate change is a change in the Earth’s average weather conditions, as quantified by temperature, rainfall and other records, over a long period of time. Recent scientific observations and studies indicate that global climate change is now occurring and is linked to an increase in the average global temperature that has been observed. There is a consensus among climate scientists that the primary cause of this change is greenhouse gas (GHG) emissions generated primarily by human activities (CAPCOA 2009). A GHG is a gas that traps heat in the earth’s atmosphere. GHGs include carbon dioxide, the most abundant GHG, along with methane, nitrous oxide, and less abundant gases. GHGs vary in their heat-trapping properties. Because of this, measurements of GHG emissions are commonly expressed in carbon dioxide equivalent (CO2e), in which emissions of all other GHGs are converted to equivalent carbon dioxide emissions.

Concerns related to global climate change include the direct consequences of a warmer climate, but also include indirect effects such as reduced air quality, reduced snowpack, higher-intensity storms, and rising sea levels. All these changes have implications for the human environment, as well as existing ecosystems and the species that depend on them.

The United Nations Intergovernmental Panel on Climate Change has concluded that stabilization of greenhouse gases at a concentration of 400-450 parts per million (ppm) CO2e is required to keep mean global warming below 2° Celsius, which is considered necessary to avoid dangerous impacts of climate change (IPCC 2001). According to data collected by the National Oceanic and Atmospheric Administration, the monthly average carbon dioxide concentration in the atmosphere was 425.38 ppm in March 2024, an increase of 4.39 ppm from the monthly average in March 2023 (NOAA 2024).

The State of California has taken an active role in addressing climate change concerns.

Among other activities, through a collaboration of three agencies, the State has prepared Climate Change Assessments that provide scientific assessments on the potential impacts of climate change in California and reports potential adaptation responses. The most recent reports include assessments of climate change impacts by region, including the San Joaquin Valley. Potential climate change impacts occurring in the San Joaquin Valley include the following (Fernandez-Bou et al. 2021):
● Higher temperatures.
● Increasing potential evapotranspiration from plants and soils. ● Longer and more severe droughts.
● Declining snowpack.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 10-2 November 2024 ● More intense precipitation events.
● More frequent and extensive wildfires.

The consequences of these impacts would fall on the following sectors in the San Joaquin Valley. These would especially affect rural disadvantaged communities (Fernandez-Bou et al. 2021).
● Agriculture - fewer winter chill hours, shifts in water availability, and extreme heat have direct and indirect impacts such as changes in yield, crops water demand, increasing competition for water from other sectors, and reduced farm labor availability.
● Ecosystems - scarcer water supply will shape habitats and will be the determining factor for survival of many species, increases in soil salinity by saltwater intrusion, future droughts may lead to insufficient flooding and a decrease in food availability for waterfowl, warming in rivers contributing to local species extinction and facilitating the colonization by invasive species. ● Water resources - reduced water availability for irrigated agriculture, demand for groundwater for agriculture will increase while groundwater availability decreases, degradation of water quality.
● Infrastructure - accelerated deterioration of private property, canals, dams, roads, railways, and levees due to increasing land subsidence, droughts and associated over pumping, wildfires, and floods.
● Public health - more heat-related deaths and illnesses, illnesses caused by poor water quality, and other issues caused by droughts, wildfires, and some agricultural activities.

While many of these effects would not directly affect Ceres, several would involve indirect effects. For example, less precipitation and potentially reduced releases from Don Pedro Reservoir would mean less water for distribution or irrigation water by TID and potential recharge of the Ceres groundwater system. Portions of the City along the Tuolumne River could be more prone to flooding from extreme weather events, although the CTSP Area would likely be unaffected. Changes in agriculture would affect the Ceres community and the area economy. Increased heat, hot day frequency, and reduced air quality could negatively affect public health.

Although local activities can emit GHGs, the impacts of GHG emissions are global in character. While global climate change can influence regional and local environments, it is not possible to connect GHG emissions from an individual project to changes in the local environment that result from climate change, as these changes result from the cumulative accumulation of GHGs in the atmosphere. As such, this analysis of project impacts focuses on whether project GHG emissions would make a significant cumulative contribution to global GHG emissions, and therefore to cumulative GHG effects.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 10-3 November 2024 Existing GHG Emissions
GHG emissions in California in 2021, the most recent year for which data are available, were estimated at approximately 381.3 million metric tons CO2e – a decrease of approximately 21.5% from the peak level in 2004 but an increase of approximately 3% from the 2020 emissions. Transportation was the largest contributor to GHG emissions in California, with 39% of total emissions. Other significant sources include industrial activities, with approximately 22% of total emissions, and electric power generation, both in-state and imported, with approximately 16% of total emissions (ARB 2023).

As part of the recent update to the Ceres General Plan, a GHG emissions inventory was conducted for the Planning Area, using a baseline year of 2014. The inventory found Planning Area GHG emissions in 2014 totaled 327,665 metric tons CO2e annually. The transportation sector was the largest source of emissions, generating approximately 36 percent of total emissions. Transportation sector emissions were the result of diesel and gasoline combustion in vehicles traveling on both local roads and State highways that pass through the jurisdictional boundaries of the Planning Area. The second largest source of emissions was electricity and natural gas consumption within the residential sector, generating approximately 26 percent of the total. Electricity and natural gas use in the industrial sector, the third largest source, produced approximately 15 percent of total emissions (City of Ceres 2018a). More recent information on GHG emissions in Ceres is not available.

REGULATORY FRAMEWORK
Federal
As noted above, the EPA has found that GHG emissions endanger both the public health and public welfare under Section 202(a) of the Clean Air Act. However, the federal government currently does not have a comprehensive GHG strategy.

Some GHG emission reduction actions have been adopted at the federal level. In coordination with the U.S. Department of Transportation, EPA issued GHG emission and fuel economy standards for passenger vehicles and trucks that are intended to cut six billion metric tons of GHG emissions over the lifetimes of vehicles sold in model years 2012- 2025. In 2010, the EPA set GHG emissions thresholds to define when permits under the New Source Review Prevention of Significant Deterioration and Title V Operating Permit programs are required for new and existing industrial facilities.

In 2013, the EPA proposed standards to cut carbon emissions from new power plants, which were adopted in 2015. Also, in 2015, the EPA adopted the Clean Power Plan, which established guidelines for states in limiting carbon dioxide emissions from existing power plants. The Clean Power Plan was repealed in 2019, and a U.S. Supreme Court decision issued in 2022 limits EPA’s authority to regulate GHG emissions from existing plants.

However, the 2015 emission standards for new power plants remain in place.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 10-4 November 2024 In 2015, the Paris Agreement was reached among 196 countries, with each country pledging to take actions to decrease GHG emissions to reach the overall goal of limiting the increase in global temperature to no more than two degrees Celsius. The Paris Agreement does not set legally binding reduction targets; instead, all parties are to put forward their best efforts through “nationally determined contributions” and to strengthen these efforts in the years ahead. All parties are to report regularly on their emissions and their reduction implementation efforts. The United States was a signatory to the Paris Agreement, but it has not yet adopted a plan to meet the goals of the agreement.

State
California has addressed climate change on its own initiative as early as 1988, when the California Energy Commission was designated as the lead agency for climate change issues. However, the most significant state activities have occurred since 2005, when executive orders and State legislation established the current framework for addressing GHG emissions and climate change. Several of these actions are described below.

Executive Orders S-3-05 and B-30-15
Executive Order S-3-05, signed by Governor Schwarzenegger in 2005, established GHG emission reduction targets for California. Specifically, GHG emissions would be reduced to the level of emissions in the year 2000 by 2010, to the level of emissions in the year 1990 by 2020, and to 80% below the 1990 emissions level by 2050. The desired 2050 GHG emission reduction is consistent with the Intergovernmental Panel on Climate Change objectives for stabilizing global climate change. The 2020 reduction goal set forth by S-3- 05 was codified by AB 32, which is described below.

On April 29, 2015, Governor Brown signed Executive Order B-30-15, which advanced the goals of Executive Order S-3-05 by establishing a GHG reduction target of 40% below 1990 emission levels by 2030. The 2030 reduction goal set forth by B-30-15 was codified by Senate Bill (SB) 32, which also is described below. In 2022, AB 1279 was enacted, requiring statewide GHG emissions to be reduced to at least 85% below 1990 levels by 2045. This magnifies and accelerates the 2050 reduction goal set forth in Executive Order S-3-05. The AB 1279 goals have been incorporated in the recently adopted 2022 Scoping Plan (see SB 32 discussion below).

AB 32
AB 32, the Global Warming Solutions Act of 2006, is State legislation that sets goals of reducing GHG emissions to year 2000 levels by 2010 and to year 1990 levels by 2020.

These specific goals are directly related to the Governor’s overall objectives established in Executive Order S-3-05. The State’s initial planning efforts were oriented toward meeting the legislated 2010 and 2020 goals, while placing the State on a trajectory that will facilitate eventual achievement of the 2050 goal set forth in Executive Order S-3-05.

The ARB has primary responsibility for AB 32 implementation. ARB adopted a Climate Change Scoping Plan in 2008 with the purpose of meeting the AB 32 targets. The 2008 Scoping Plan proposed to reduce GHG emissions from the State’s projected 2020 "business-as-usual" emissions by approximately 29%. Nearly 85% of the GHG reductions EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 10-5 November 2024 would be achieved under a “cap-and-trade” program and “complementary measures,” including expansion of energy efficiency programs, increase in the use of renewable energy sources, and low-carbon fuel standards, among others. The remaining 15% would include measures applicable to GHG sources not covered by the cap-and-trade program (ARB 2008b).

The cap-and-trade program was the centerpiece of the GHG reduction program set forth in the 2008 Scoping Plan. In general, the program sets a “cap” on the total GHG emissions that would be allowed in California, which gradually decreases over time. Allowances for GHG emissions are sold at auction to industrial activities and utilities that emit large quantities of GHGs, which in turn can sell allowances that are unused to other activities that need more allowances (the “trade” component). The State Legislature recently extended the cap-and-trade program from its original expiration in 2020 to 2030, as part of a strategy to meet GHG reduction targets set by SB 32 (see below).

In May 2014, the ARB approved the First Update to the Scoping Plan. The 2014 Update lays the foundation for establishing a broad framework for continued emission reductions beyond 2020, on the path to the 2050 target set forth in Executive Order S-3-05. It recommended actions in nine sectors: energy, transportation, agriculture, water, waste management, natural and working lands, short-lived climate pollutants, green buildings, and the cap-and-trade program (ARB 2014).

According to the California Greenhouse Gas Emission Inventory, for the target year of 2020, state GHG emissions were 369.2 million metric tons CO2e, which was 35.3 million metric tons CO2e below 2019 emissions and 61.8 million metric tons CO2e below the AB 32 target. However, this substantial decrease was most likely caused by the lockdown ordered by the State that year in response to the COVID-19 pandemic. Economic recovery from the pandemic may result in GHG emission increases over the next few years (ARB 2022a). This observation appears to be confirmed by the 2021 figure mentioned above, which was an increase of 12.1 million metric tons CO2e from the 2020 figure.

SB 32
In 2016, SB 32 was enacted. SB 32 extends the GHG reduction goals of AB 32 by requiring statewide GHG emission levels to be 40% below 1990 levels by 2030, in accordance with the target established by Executive Order B-30-15. The State adopted an updated Scoping Plan in 2017 that sets forth strategies for achieving the SB 32 target. The 2017 Scoping Plan continues many of the programs that were part of the previous Scoping Plans, including the cap-and-trade program, low-carbon fuel standards, renewable energy, and methane reduction strategies. It also addresses for the first time GHG emissions from the natural and working lands of California, including the agriculture and forestry sectors. Both natural and working lands sequester carbon in trees, other vegetation, soils, and aquatic sediment. The 2017 Scoping Plan recommends protecting working lands from conversion, enhancing carbon sequestration, and encouraging innovation in the disposal of biomass from working lands (ARB 2017).

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 10-6 November 2024 On December 15, 2022, ARB adopted an update to the Scoping Plan. The 2022 Scoping Plan assesses progress towards achieving the SB 32 2030 reduction target and lays out a path to achieve carbon neutrality no later than 2045, in accordance with Executive Order B-55-18 (see below). Proposed strategies to achieve these reductions include rapid movement to zero-emission transportation, phasing out fossil fuel use for heating homes and buildings, further restricting use of chemicals and refrigerants that are thousands of times more powerful at trapping heat than carbon dioxide, expanded development of renewable energy sources, increased use of natural and working lands for incorporating and storing carbon, and greater employment of carbon removal technology (ARB 2022b).

Executive Order B-55-18
In 2018, Governor Brown signed Executive Order B-55-18. This executive order set a statewide goal of achieving carbon neutrality no later than 2045. “Carbon neutrality” refers to achieving net zero carbon emissions (i.e., GHGs) by balancing a measured amount of carbon released with an equivalent amount sequestered or offset. After 2045, California shall achieve and maintain net negative GHG emissions, or greater GHG sequestration or offsets than emissions. The carbon neutrality goal set by Executive Order B-55-18 was codified this year with the signing of AB 1279.

Executive Order N-79-20
In 2020, Governor Newsom issued Executive Order N-79-20, setting new statewide goals for phasing out gasoline-powered cars and trucks in California. Under this order, 100% of in-state sales of new passenger cars and trucks are to be zero-emission by 2035; 100% of in-state sales of medium- and heavy-duty trucks and buses are to be zero-emission by 2045 where feasible; all drayage trucks are to be zero-emission by 2035; and 100% of off-road vehicles and equipment sales are to be zero-emission by 2035 where feasible. The Governor directed ARB and other state agencies to develop regulations or take other steps within existing authority to achieve these goals.

SB 375/Sustainable Communities Strategy
In 2008, the State enacted SB 375, which is discussed in more detail in Chapter 16.0, Transportation. Relevant to this chapter, SB 375 requires a metropolitan planning organization to include a Sustainable Communities Strategy (SCS) in its Regional Transportation Plan (RTP). The SCS demonstrates an approach to how land use development and transportation can work together to meet GHG emission reduction targets for cars and light trucks. These targets, set by ARB, call for the region to reduce per capita GHG emissions. If a metropolitan planning organization is unable to meet the targets through the SCS, then an alternative planning strategy must be developed which demonstrates how targets could be achieved.

StanCOG is the metropolitan planning organization for Stanislaus County and its incorporated cities. The ARB provided GHG reduction targets for the StanCOG region in 2019, setting them at a 12% per capita reduction relative to 2005 levels by 2020, and a 16% per capita reduction relative to 2005 levels by 2035 (StanCOG 2022b).

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 10-7 November 2024 The 2022 SCS was adopted by StanCOG on August 17, 2022. The SCS includes strategies designed to attain the GHG per capita reduction targets, mainly through a Travel Demand Management program that intends to develop alternatives to single-occupancy vehicle travel, with the ultimate goal of reducing systemwide VMT, thereby reducing GHG emissions. Among the strategies that may be relevant to the project are investing in new and safe connections for walking and biking trips; promoting and encouraging “smart travel” through carpooling, vanpooling, riding transit, walking, and biking; and a VMT mitigation bank (StanCOG 2022a).

StanCOG has no authority to enforce the policies and strategies in the SCS; the ultimate authority regarding land use remains with the local governments. However, the Ceres General Plan has policies related to sustainability and multi-modal transportation objectives that would complement the goals and policies of the RTP/SCS (City of Ceres 2018a).

Renewables Portfolio Standard
Use of renewable energy sources (i.e., solar, wind, geothermal, hydroelectric from small generators, etc.) reduces the amount of energy generated by fossil fuels (i.e., coal, oil, and natural gas), the burning of which releases GHGs. In 2002, California adopted a Renewables Portfolio Standard, and subsequently modified it in 2006 and 2011. Under the 2011 modifications, all electricity retailers in the state must generate 20% of electricity they sell from renewable energy sources by the end of 2013, 25% by the end of 2016, and 33% by the end of 2020. As of the end of 2020, most retail electricity sellers, including all investor-owned utilities such as PG&E, have met or exceeded the 2020 target of 33 percent (CPUC 2021).

In 2015, SB 350 was signed into law, which increased the electricity generation requirement from renewable sources to 50% by 2030. In 2018, SB 100 was enacted. SB 100 accelerated the schedule for 50% electricity generation from renewable sources to the year 2026 and set a goal of 60% electrical generation from renewable sources by 2030. It also set the goal that zero-carbon resources will supply 100% of electricity to California by 2045. As of the end of 2022, most retail electricity sellers have met or exceeded the interim target for 2021, and all investor-owned utilities are on track to meet the overall 2021-2024 compliance period requirement of 44 percent (CPUC 2022).

TID is a public utility that provides electricity to the Ceres area. TID utilizes renewable energy sources such as solar, wind, and small hydroelectric. As of 2022, TID fully complied with renewable energy requirements by using generation from its current renewable resources and through the use of prior years’ qualifying energy and credits (TID 2023).

In 2023, SB 1020 was enacted, which sets additional goals for electricity generation from renewable sources - 90% by the end of 2035 and 95% by the end of 2040. The goals of SB 100 and SB 1020 are consistent with the carbon neutrality goal of Executive Order B-55-

18. EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 10-8 November 2024 Other State Regulations
Chapter 6.0, Air Quality, describes the Advanced Clean Truck Regulation adopted by ARB. This regulation aims to reduce GHG emissions generated by trucks, which are a major source of transportation GHG emissions. It is anticipated that, by 2040, the Advanced Clean Truck Regulation would reduce GHG emissions by approximately 7% below baseline (ARB 2020b).

In 2009, the ARB adopted the Low Carbon Fuel Standard regulation, which was one of the early action measures specified in the 2008 Scoping Plan that implemented AB 32. The Low Carbon Fuel Standard is designed to encourage the use of cleaner low-carbon transportation fuels in California, encourage the production of those fuels, and therefore, reduce GHG emissions and decrease petroleum dependence in the transportation sector.

The standards are expressed in terms of the "carbon intensity" of gasoline and diesel fuel and their respective substitutes. In 2018, the ARB approved amendments to the regulation, which among others included strengthening and smoothing the carbon intensity benchmarks through 2030, in line with California's 2030 GHG emission reduction target enacted through SB 32. Cumulatively from 2019 through 2030, the 2018 amendments would provide an additional 97 million metric tons CO2e emission reductions as compared to the 2016 existing conditions baseline and an additional 63 million metric tons CO2e emission reductions as compared to the business-as-usual scenario (ARB 2018).

Regional and Local
San Joaquin Valley Air Pollution Control District
The SJVAPCD adopted a Climate Change Action Plan in 2008 and issued guidance for development project compliance with the plan in 2009. The guidance adopted an approach that relies on the use of Best Performance Standards to reduce GHG emissions. Projects implementing Best Performance Standards would be determined to have a less than cumulatively significant impact. Such standards have been established for fossil fuel-fired boilers, steam generators and process heaters; fossil fuel-fired cogeneration plants; landfill operations; and wastewater treatment operations among other stationary sources (SJVAPCD 2009).

For projects not implementing Best Performance Standards, such as development projects, demonstration of a 29% reduction in project-specific (i.e., operational) GHG emissions from business-as-usual conditions is required to determine that a project would have a lessthan-significant cumulative impact (SJVAPCD 2009). However, the percentage reduction approach was called into question by the California Supreme Court in its 2015 decision on Center for Biological Diversity v. California Department of Fish and Wildlife, also referred to as the “Newhall Ranch case.” The court held that the GHG analysis for the Newhall Ranch project, which used percentage reduction, lacked supporting substantial evidence and a cogent explanation correlating the project-specific reductions to AB 32’s mandated state-wide reductions so as to demonstrate consistency with the latter’s goals under the approved methodology.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 10-9 November 2024 Ceres General Plan
The City of Ceres does not have a Climate Action Plan or other formal GHG reduction plan. However, the Ceres General Plan contains policies relevant to the project that are intended to reduce GHG emissions. Among these policies are the following (City of Ceres 2018b):
• 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.

Each residential areawide plan should at minimum address the following:

Provisions for linking residential neighborhoods, parks, schools, shopping areas, and employment centers through a system of pedestrian and bicycle pathways.
• Policy 2.I.3 - Pedestrian-Oriented Design. Promote architectural and landscape design features in new development that create more pedestrianfriendly neighborhoods, such as orientation to the street; rear, setback, or detached garages; front porches; tree-lined streets; and landscaped strips between streets and sidewalks.
• Policy 3.A.1- Multi-Modal Network. Provide for a comprehensive, integrated transportation network in accordance with the functional classification system described in this chapter and reflected in the Circulation Diagram with infrastructure and design that allows safe and convenient travel along and across streets for all users, including bicyclists, pedestrians, transit vehicles, truckers, and motorists, appropriate to the function and context of the facility. • Policy 4.G.5 - Reduce VMT. Emphasize transit-oriented, walkable, compact development patterns to reduce total vehicle miles traveled. • Policy 5.E.1 - Green Building Code. Continue to implement and enforce the California Green Building Code to promote energy efficient building design and construction.

ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
Significance Thresholds
According to Appendix G of the CEQA Guidelines, a project may have a significant impact related to GHG emissions if it would:
● Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment, or
● Conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases.

This EIR conducts its GHG analysis in accordance with CEQA Guidelines Section 15064.4, which states that a lead agency should make a good-faith effort, based to the EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 10-10 November 2024 extent possible on scientific and factual data, to describe, calculate, or estimate the amount of GHG emissions resulting from a project. CEQA Guidelines Section 15064.4(b) states that a Lead Agency should consider the following factors, among others, when assessing the significance of impacts from GHG emissions on the environment:
● The extent to which the project may increase or reduce GHG emissions as compared to the existing environmental setting.
● Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project.
● The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions.

Some jurisdictions have established quantitative thresholds for determining the significance of project GHG emissions from construction activities and project operations.

Neither the City nor SJVAPCD has established such quantitative significance thresholds.

As noted, the SJVAPCD recommended a 29% reduction from business-as-usual GHG levels for project operational emissions to determine consistency with GHG reduction goals, but the California Supreme Court has indicated this approach is not valid.

Impact GHG-1: GHG Emissions from Construction Activities GHG emissions would result from the construction of the land uses designated by the CTSP over the buildout period. Given the mostly developed state of the Pocket Area, construction GHG emissions anticipated to be generated from this area would be limited. Construction GHG sources would include construction employee travel, heavy equipment operation, and light vehicle and other equipment used in the construction process. Indirect GHG emissions would also result from electrical energy usage and construction materials manufacturing.

This analysis is limited to direct emissions that can be readily modeled.

The CalEEMod model was used to estimate GHG emissions from the assumed “maximum construction year,” as defined in Chapter 6.0, Air Quality. Default modeling assumptions were used, and no mitigation was assumed. The results of the CalEEMod run (see Appendix A) indicate that estimated GHG emissions from construction during the assumed maximum construction year would be 478 metric tons CO2e.

As noted, a quantitative GHG significance threshold has not been established by the SJVAPCD or the City. However, the nearby Sacramento Metropolitan Air Quality Management District has established a quantitative threshold of 1,100 metric tons CO2e to determine significance of project GHG emissions for CEQA purposes (SMAQMD 2021).

This threshold applies to both construction and operational emissions. CEQA Guidelines Section 15064.7 allows for the use of significance thresholds established by other agencies.

Based on this significance threshold, construction GHG emissions during the maximum construction year would be less than significant.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 10-11 November 2024 As noted in Chapter 6.0, some project construction of many projects in the CTSP Area would be required to comply with SJVAPCD Rule 9510, the ISR. The ISR requires a demonstration that construction NOx and PM10 exhaust emissions will be reduced by 20% and 45% respectively, or payment of ISR fees in lieu of emission reductions. On-site mitigation measures that reduce these emissions would also likely result in reduced GHG emissions. To be more competitive, construction contractors are modifying their construction equipment fleet to reduce emissions and therefore ISR permitting costs, which also would likely reduce GHG emissions. Statewide GHG emission reduction and air quality improvement programs can also be expected to result in further reductions in GHG emissions from off-highway equipment use.

In its NOP comment letter, the SJVAPCD made the following suggestions to further reduce GHG generated by construction emissions:
• The project should utilize the cleanest available off-road construction equipment.
• The DEIR should include measures to ensure compliance with the state antiidling regulation 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.

The City shall incorporate these recommendations from SJVAPCD as conditions of approval, even though construction GHG emission impacts have been determined to be less than significant. In any event, construction GHG emissions are short-term and would cease when construction work is completed, as opposed to long-term operational emissions that are discussed below. Project impacts related to construction GHG emissions are considered less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
Impact GHG-2: GHG Emissions from Project Operations
GHG emissions from various sources would result from future development under the CTSP. Given the mostly developed state of the Pocket Area, operational GHG emissions anticipated to be generated from this area are anticipated to change little from existing conditions. Operational GHG emissions are long-term, continuing indefinitely. “Area” GHG sources include use of natural gas for water and space heating in commercial and residential structures. Vehicle travel, considered a “mobile” GHG source, would emit tailpipe GHGs. Electrical heating, lighting, and other uses would indirectly produce GHG emissions from power generation plants, as would additional demands on water supply and waste disposal systems.

Operational GHG emissions were estimated at buildout of the CTSP Area, using the CalEEMod program. Emissions were modeled under unmitigated and mitigated conditions EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 10-12 November 2024 using CalEEMod model default settings; both values are shown in Table 10-1. Mitigation measures used in the mitigated CalEEMod run are the same as those described in Chapter

6.0, Air Quality.

TABLE 10-1

GHG EMISSIONS FROM PROJECT OPERATIONS AT BUILDOUT
GHG Emission Type
Emissions at Buildout (metric tons/year CO2e)
Unmitigated Mitigated
Area 1,596 1,596
Energy 15,410 15,078
Mobile 24,748 15,078
Waste 1,208 302
Water 656 525
Refrigerants 2,340 2,340
Total 45,959 43,005
Mitigation Reduction - 6.4%
As shown by Table 10-1, mobile sources contribute the most GHG emissions; the second highest emissions are contributed by energy usage. Emissions for energy, mobile, and area sources individually exceed the 1,100-metric ton CO2e significance threshold, as well as total emissions under both unmitigated and mitigated conditions. Absent other considerations, GHG emissions from project operations would be considered significant.

However, as discussed below, mitigated GHG emissions would be reduced from unmitigated emissions by a percentage that is consistent with the State’s GHG reduction plans. Additional GHG reduction measures to be implemented by the State, such as the Clean Fleet regulations and the Renewables Portfolio Standard would further reduce GHG emissions.

Nevertheless, GHG emissions resulting from CTSP development would remain significant even with application of GHG reduction measures and regulations. Therefore, project impacts are considered significant and unavoidable.

Level of Significance: Significant and unavoidable
Mitigation Measures: None feasible
Impact GHG-3: Consistency with Applicable GHG Plans and Policies As noted, the City of Ceres does not have a Climate Action Plan or other formal GHG reduction plan. The SJVAPCD has recommended a 29% reduction from business-as-usual GHG levels for project operational emissions to determine consistency with GHG EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 10-13 November 2024 reduction goals, but the California Supreme Court has indicated this approach to evaluating project environmental impacts related to GHG emissions is not valid. Therefore, the analysis of consistency of the CTSP with GHG reduction plans shall focus on SB 32 and its Scoping Plan below.

The 2017 Scoping Plan proposes various measures to achieve the 2030 target. Most of these are State measures, such as use of the cap-and-trade program, the Short-Lived Climate Pollutant Plan, and achievement of the 50% renewable sources of electricity in the Renewables Portfolio Standard. Based on estimates in the 2017 Scoping Plan, State actions would account for 89.8% of GHG reductions needed by 2030, with local actions accounting for approximately 9.3% of reductions. Applying this ratio to the percentage reduction for 2030, then approximately 6.0% of the reduction from 2030 business-as-usual levels would be achieved by local measures. A project that can show GHG reductions greater than 6.0% can be said to be consistent with the reduction goals of SB 32. Project GHG operational emission reductions would be approximately 6.4%, thereby exceeding this percentage.

Therefore, the project would be consistent with the reduction goals of SB 32.

Subsequent State legislation has established GHG emission reduction targets beyond 2030 to 2050. However, it is not clear at this time how these reduction targets would be achieved.

The State has not yet prepared plans that specify the measures and actions that would be implemented to attain these targets. Because of this, it is not clear what actions that CTSP development needs to take to ensure consistency with the reduction targets set by the State.

It is reasonably certain that CTSP implementation would be consistent with the reduction target set by SB 32, which does have its Scoping Plan. As noted above, the mitigated GHG emissions of the CTSP reduces emissions from unmitigated levels by an amount consistent with the Scoping Plan.

As previously noted, the Ceres General Plan contains policies intended to reduce GHG emissions. The policies and CTSP consistency are presented below:
• Policy 2.I.2 - Area-wide Plans. Consistent. The CTSP comprehensively plans for new neighborhood developments, and it includes provisions for linking residential neighborhoods, parks, schools, shopping areas, and employment centers through a system of pedestrian and bicycle pathways. • Policy 2.I.3 – Pedestrian-Oriented Design. Consistent. The CTSP includes design standards that promote more pedestrian-friendly neighborhoods. • Policy 3.A.1- Multi-Modal Network. Consistent. The CTSP proposes a circulation system that integrates vehicular and non-vehicular traffic, including bicyclists, pedestrians, and transit vehicles. • Policy 4.G.5 - Reduce VMT. Consistent. The CTSP includes land use design and circulation features that emphasize walkable, compact development patterns and use of non-vehicle transportation to reduce total vehicle miles traveled.
• Policy 5.E.1 – Green Building Code. Consistent. Project development within the CTSP Area would comply with the California Green Building Code.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 10-14 November 2024 Based on the analysis presented above, the CTSP would be consistent with the GHG reduction policies of the Ceres General Plan.

In summary, the project would be consistent with applicable GHG reduction policies and plans. Therefore, project impacts related to consistency with applicable GHG emission reduction plans are considered less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 11-1 November 2024

11.0 HAZARDS AND HAZARDOUS MATERIALS
This chapter identifies and considers existing or potential future conditions that could present a health or safety concern with respect to railroad and airport operations, waterways, environmental contamination or hazardous waste sites, and wildfires. Chapter

12.0, Hydrology and Water Quality, discusses potential flooding concerns. Potential concerns related to geologic hazards are addressed in Chapter 9.0, Geology and Soils. Air toxic emissions are discussed in Chapter 6.0, Air Quality.

ENVIRONMENTAL SETTING
Hazardous Materials
Hazardous materials are defined as substances or combinations of substances that may contribute to increases in serious illness or mortality or may pose a substantial hazard to human health or the environment when improperly treated, stored, transported, or disposed.

Hazardous wastes are contaminated materials that no longer have a practical use.

Hazardous materials or wastes are generally classified as toxic, ignitable, corrosive, or reactive. Although distinct from hazardous materials as defined, petroleum products such as motor vehicle fluids also represent potential concerns for health and environmental contamination.

As described in Chapter 5.0, Agricultural Resources, agricultural activities currently occur on lands within the project site. These activities typically involve the use of pesticides and other chemicals, which may be considered hazardous materials and can contaminate soil and water if not properly applied. There are no other activities, either on or immediately adjacent to the project site, that involve activities that handle substantial amounts of potentially hazardous materials, such as industrial land uses.

Data on hazardous waste and hazardous material use and transportation sites are kept in the GeoTracker database, maintained by the SWRCB, and in the EnviroStor database, maintained by the California Department of Toxic Substances Control (DTSC).

GeoTracker and EnviroStor map the locations and provide the names and addresses of hazardous material sites, along with their contamination history and cleanup status. A search of both databases indicated no record of active hazardous material sites within onehalf mile of the CTSP or Pocket Areas (SWRCB 2023, DTSC 2023). The Envirostor database contains five records of investigations of school sites on or near Central Valley High School. In all these cases, no further action was required (DTSC 2023).

A list of potentially hazardous solid waste disposal sites identified by SWRCB did not contain any locations in the project vicinity (CalEPA 2021a); listed sites exhibit waste constituent levels outside the waste management unit as being above hazardous waste screening criteria. Likewise, an SWRCB list of sites under Cease and Desist Orders and EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 11-2 November 2024 Cleanup and Abatement Orders showed no locations on or near the project site (CalEPA 2021b).

Transportation of Hazardous Materials
Within the Ceres area, hazardous materials may be transported by vehicle along roadways or through transmission lines such as pipelines. Pipelines are discussed in more detail in Chapter 17.0, Utilities and Energy. Major transportation routes include SR 99 and surface streets, particularly arterials and expressways that accommodate truck traffic such as Hatch Road, Whitmore Avenue, Service Road, Morgan Road, Central Avenue, and Mitchell Road (City of Ceres 2018a). SR 99 is adjacent to the northeast portions of the project site. Service Road marks the northern boundary of the proposed CTSP Area, and Central Avenue traverses its center.

The Union Pacific Railroad maintains railroad tracks parallel with and adjacent to SR 99, on its west side. The CTSP Area would share a portion of its eastern boundary with these railroad tracks. This line supports several train trips per day, some of which would have cars and/or tankers transporting hazardous materials.

Airport Hazards
Development near airports is potentially subject to hazards arising from airport operations.

In general, development that concentrates residents and employees near airports is discouraged, both to avoid potential hazards associated with aircraft takeoffs and landings and to reduce exposure to noise associated with aircraft. Chapter 14.0, Noise, discusses potential noise impacts related to airport operations.

The closest public airport to the project site is the Modesto City-County Airport, approximately three miles to the north. The airport is owned by the City of Modesto; however, a nine-member committee appointed by the Modesto City Council, Stanislaus County Board of Supervisors, and the Cities of Ceres and Turlock act in an advisory capacity on airport policy matters (Stanislaus County 2016). Modesto City-County Airport provides general aviation and charter flight services; commercial passenger air service is currently not offered.

The project site is not within either the safety zones or the land use compatibility planning area for Modesto City-County Airport, as designated by the Stanislaus County Airport Land Use Compatibility Plan (ALUCP) and by the Ceres General Plan (Stanislaus County 2016c, City of Ceres 2018b). However, the northern and eastern sections of the project site are within the Airport Influence Area of the airport as designated in the ALUCP (Figure 11-1). The Airport Influence Area is an area in which current or future airport-related noise, overflight, safety, or airspace protection factors may significantly affect land uses or necessitate restrictions on those uses. CEQA requires environmental documents for projects situated within an Airport Influence Area to evaluate whether the project would expose people residing or working in the project area to excessive levels of airport-related noise or to airport-related safety hazards (Public Resources Code Section 21096).

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 11-3 November 2024 Wildfire Hazards
Wildland fires occur in rural or heavily vegetated areas where abundant surface fuels are available to sustain a fire. Ceres and its surrounding Planning Area are at very low risk for wildland fires, due to the lack of forest, brush, or grasslands in the vicinity. The Planning Area has minimal surface fuels due to the developed nature of the city and irrigated croplands, and therefore has a low fire hazard (City of Ceres 2018a).

The Fire and Resource Assessment Program, managed by the California Department of Forestry and Fire Protection (Cal Fire), identifies the potential fire threat for an area based on two factors: fire frequency and potential fire behavior. These two factors are used to determine Fire Hazard Severity Zones, with designations of Moderate, High, and Very High. The Fire Hazard Severity Zones are mapped for State Responsibility Areas, where the State of California is financially responsible for the prevention and suppression of wildfires. The CTSP Area and surrounding lands are not within a State Responsibility Area and have not been placed in a Fire Hazard Severity Zone (Cal Fire 2022).

Waterways
An existing TID irrigation lateral is located along the southern boundary of the CTSP Area - Lower Lateral 2. The CTSP proposes development of a sidewalk and open space corridor along the TID lateral that would provide for both recreation and stormwater storage.

Potential hazards have been identified with irrigation canals and laterals, including the following:
• Canals contain water that is quickly moving, and fast-moving water in a narrow channel can cause a person to lose balance and be carried away, even by water that is only one foot deep.
• Canals can have deep water. If a person cannot swim or is hurt, falling into deep water could prove fatal. In addition to swift currents, irrigation canals may have undertows and turbulence that could drag even a strong swimmer under water. • Canals have steep slopes and slippery walls. The concrete or earthen sides of ditches and canals are sometimes steep and possibly slippery, making it difficult for a person to climb out.

Because of these and other hazards, TID does not allow any swimming, fishing, playing, or other recreational activities in or around its canals.

Railroad Hazards
The project site is adjacent to the Union Pacific Railroad (UPRR) tracks, which run parallel to and southwest of SR 99. As noted above, the railroad tracks may transport hazardous materials. In addition, potential accidents may also occur at railroad crossings where conflicts with vehicles may occur and with persons along the alignment trespassing on the railroad tracks. A search of the Federal Railroad Administration database revealed that there were six accidents on the UPRR tracks in Stanislaus County in 2022. All six accidents involved trespassers; four of these accidents were fatal (FRA 2023).

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 11-4 November 2024 REGULATORY FRAMEWORK
Federal
At the federal level, the principal agency regulating the generation, transport and disposal of hazardous substances is the U.S. Environmental Protection Agency (EPA), under the authority of the Resource Conservation and Recovery Act (RCRA). The RCRA established a federal hazardous substance “cradle-to-grave” regulatory program that regulates the generation, transportation, treatment, storage, and disposal of hazardous substances. Under RCRA, individual states may implement their own hazardous substance management programs if they are consistent with, and at least as strict as, the RCRA and if they receive EPA approval.

The EPA regulates hazardous substance sites under the Comprehensive Environmental Response Compensation and Liability Act, commonly referred to as Superfund. The purpose of Superfund is to provide authorities with the ability to respond to uncontrolled releases of hazardous substances from inactive hazardous waste sites that endanger public health and the environment. The subsequent Superfund Amendments and Reauthorization Act amended Superfund to, among other things, expand EPA’s response authority, strengthen enforcement activities at Superfund sites, and broaden the application of the law to include federal facilities. In addition, new provisions were added dealing with emergency planning and community right-to-know.

The U.S. Department of Transportation regulates the interstate transport of hazardous materials and wastes through implementation of the Hazardous Materials Transportation Act. This act specifies driver-training requirements, load labeling procedures, and container design and safety specifications. Transporters of hazardous wastes must also meet the requirements of additional statutes such as RCRA.

State
Several state agencies regulate the transportation and use of hazardous materials to minimize potential risks to public health and safety, including the California Environmental Protection Agency and the Office of Emergency Services. The California Highway Patrol and Caltrans enforce regulations related to hazardous materials transport.

The DTSC is part of the California Environmental Protection Agency. It has the primary authority to enforce hazardous materials regulations for the generation, transport, and disposal of hazardous wastes under the authority of the Hazardous Waste Control Law, with delegation of enforcement to local jurisdictions that enter into agreements with the agency. DTSC is also responsible for overseeing the evaluation and cleanup of contaminated properties throughout California, including military facilities, school construction and expansion projects, and permitted facilities.

Under both RCRA and the Hazardous Waste Control Law, the generator of a hazardous substance must complete a manifest that accompanies the waste from the point of generation to the ultimate treatment, storage, or disposal location. The manifest describes the waste, its intended destination, and other regulatory information about the waste.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 11-5 November 2024 Copies must be filed with the DTSC. Generators must also match copies of waste manifests with receipts from the treatment, storage, or disposal facility to which it sends waste.

California Fire Code
California Code of Regulations Title 24, Part 9 contains the California Fire Code, which is revised approximately every three years by the California Building Standards Commission.

It incorporates, by adoption, the International Fire Code of the International Code Council, with California amendments. This is the official Fire Code for the State and all political subdivisions. The City of Ceres has adopted the 2022 version of the California Fire Code, with amendments, as Chapter 15.08 of the Ceres Municipal Code.

Local
Certified Unified Program Agency (CUPA)
The Unified Hazardous Waste and Hazardous Management Regulatory Program, enacted in 1993, is a state and local effort to consolidate, coordinate, and make consistent existing programs regulating hazardous waste and hazardous materials management. The California Environmental Protection Agency adopted implementing regulations for the Unified Program in 1996.

The Unified Program is implemented at the local level by a Certified Unified Program Agency (CUPA). The Stanislaus County Environmental Resources Department was approved by the State as the CUPA for the County and its incorporated cities. In that role, the County Environmental Resources Department administers the California Accidental Release Prevention, Hazardous Waste Generator, Aboveground Petroleum Storage Act, and Underground Storage Tank programs.

The CUPA also provides the management and record keeping of hazardous materials through its Hazardous Materials Program. This program inspects businesses for compliance with the Hazardous Waste Control Law and issues hazardous materials/waste permits to businesses that handle quantities greater than or equal to 55 gallons of a liquid, 500 pounds of a solid, or 200 cubic feet of a compressed gas at any given time. Businesses issued these permits are required to submit a Hazardous Materials Business Plan, which includes an inventory of hazardous materials and hazardous wastes, and an emergency response plan for incidents involving hazardous materials and wastes.

Stanislaus County Emergency Operations Plan
An update to the Stanislaus County Emergency Operations Plan, prepared by the County Office of Emergency Services, was adopted in 2021. The Emergency Operations Plan addresses the County’s planned response to extraordinary emergency situations associated with natural disasters or human-caused emergencies in or affecting Stanislaus County. The top five risks identified are floods, wildfires, landslides, earthquakes, and dam failure. The plan establishes the emergency management organization required to mitigate any significant emergency or disaster affecting Stanislaus County, and it identifies the roles and responsibilities required to protect the health and safety of Stanislaus County residents, EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 11-6 November 2024 public and private property, and the environmental effects of natural, man-made, and technological emergencies and disasters (Stanislaus County OES 2021).

The Emergency Operations Plan notes that the State Highways and Interstate 5 are the major transportation routes through the county. These major highway/freeway routes would be highly utilized by both County residents and tourists as possible evacuation routes. SR 99 near the project site would be one of those highways (Stanislaus County OES 2021).

County Agricultural Commissioner
The County Agricultural Commissioner is directed by the County Office of Emergency Services to track agricultural uses and issue use permits for pesticide application on agricultural land. The Commissioner’s staff conducts routine inspections to ensure that farm operations comply with the requirements set forth in the Federal Insecticide, Fungicide, and Rodenticide Act, the main federal statute governing agricultural chemical use. This act, among other provisions, requires users to register when purchasing pesticides; later amendments to the law require users to take exams for certification as pesticide applicators.

Stanislaus County Airport Land Use Compatibility Plan
The ALUCP was adopted by the Stanislaus County Airport Land Use Commission in 2016 and subsequently amended in 2018. The basic function of the ALUCP is to promote compatibility between the three public use airports in the County and the land uses surrounding them to the extent that these areas have not already been devoted to incompatible uses. The ALUCP accomplishes this function through establishing a set of compatibility criteria applicable to new development around the airports. Neither the ALUCP nor the Airport Land Use Commission have authority over existing land uses or over operation of the airports. However, projects that could potentially affect airport operations are subject to review by the Airport Land Use Commission for consistency with the ALUCP prepared for the airport and to ensure that the project does not interfere with airport operations (Stanislaus County 2016c).

The three public use airports for which the ALUCP was prepared are the Modesto CityCounty Airport, the Oakdale Municipal Airport, and the former Crows Landing Air Facility in southwestern Stanislaus County. As noted, the project site is not within either the safety zones or the land use compatibility planning area for Modesto City-County Airport, the nearest public airport. However, the northern and eastern sections of the project site are within the Airport Influence Area of the airport. Projects affecting land within an Airport Influence Area – adoption or amendment of general plans, specific plans, zoning ordinances, or building codes – are subject to Airport Land Use Commission review. If the Commission determines that a proposed land use action, regulation, or permit is inconsistent with the ALUCP, the local government may override the inconsistency determination.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 11-7 November 2024 ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
Significance Thresholds
According to Appendix G of the CEQA Guidelines, a project may have a significant impact related to hazards and hazardous materials if it would:
● Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials,
● Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment,
● Emit hazardous emissions or handle hazardous or acutely hazardous materials within one-quarter mile of an existing or proposed school, ● Be located on a site included on a list of hazardous material sites compiled pursuant to Government Code Section 65962.5, and as a result create a significant hazard to the public or the environment,
● For a project located within an airport land use plan or within two miles of a public or public-use airport if no plan has been adopted, result in a safety hazard or excessive noise for people residing or working in the project area, ● Impair implementation of, or physically interfere with, an adopted emergency response plan or emergency evacuation plan, or
● Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires.

Impact HAZ-1: Hazardous Material Transportation
The CTSP proposes development in the vicinity of SR 99 and the UPRR railroad corridor south of SR 99. Both transportation facilities are used to transport hazardous materials that could be released during accidents, spills, or derailments. In addition, certain project site activities may require transportation of hazardous materials within the CTSP Area, such as fertilizers for the park areas and cleaners and solvents for commercial activities.

Development in the immediate vicinity of SR 99 and the UPRR tracks would be commercial in nature, while planned residential development would be set back more than 500 feet. For hazardous material spills or releases that may occur on these facilities or roads within the CTSP Area, the County Department of Environmental Resources maintains hazardous materials response teams to assist public and fire agencies during chemical spills. The City of Modesto Fire Department, which now provides fire protection services for the City of Ceres (see Chapter 15.0, Public Services and Recreation), has hazardous materials specialists and technicians who handle minor local hazardous materials incidents.

All transportation of hazardous materials would be required to comply with applicable local, state, and federal regulations. These requirements would include preparation and EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 11-8 November 2024 implementation of a Hazardous Materials Business Plan for activities that would transport or store specified quantities of hazardous materials, as described in the Regulatory Framework above. Compliance with these requirements would reduce impacts related to routine transport, use, and storage of hazardous materials to a level that would be less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
Impact HAZ-2: Hazardous Material Storage and Use
Future development proposed by the CTSP may require the storage, use, and disposal of hazardous materials, generally cleaning products, fuels, and solvents. Depending on the type of commercial activity, substantial quantities of hazardous materials may be used and stored.

It should be noted that current agricultural uses within the CTSP Area most likely use and store chemicals such as pesticides, herbicides, and fertilizers. Such chemicals, if not properly applied or stored, could lead to contamination of soil and water. With the proposed CTSP development, agricultural uses would be eliminated, as would agricultural chemical use and storage.

Project site activities that would store hazardous materials would be required to do so in compliance with applicable local, state, and federal regulations. These requirements would include preparation and implementation of a Hazardous Materials Business Plan for activities that would store quantities of hazardous materials, as specified in the Regulatory Framework above. Compliance with these requirements would reduce impacts related to routine transport, use, and storage of hazardous materials to a level that would be less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
Impact HAZ-3: Hazardous Material Releases
Construction activities on the project site may involve the use of hazardous materials such as fuels and solvents, and thus create a potential for hazardous material spills. Construction and maintenance vehicles would transport and use fuels in ordinary quantities. Fuel spills, if any occur, would ordinarily be minimal and would not typically have significant adverse effects. Potential hazardous materials spills during construction are addressed in the required SWPPP, described in Chapter 9.0, Geology. In accordance with SWPPP requirements, contractors have absorbent materials at construction sites to clean up minor spills. Other substances used in the construction process would be stored in approved containers and used in relatively small quantities, in accordance with the manufacturers’ recommendations and/or applicable regulations. Per SWPPP requirements, if a discharge violation occurs, the contractor shall immediately notify the City, and the City shall file a EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 11-9 November 2024 violation report electronically to the RWQCB within 30 days of identification of noncompliance.

As noted in the Impact HAZ-1 discussion, hazardous materials transportation and storage on the project site would be subject to federal, state, and local regulations that would ordinarily prevent release of hazardous materials to the soil and/or groundwater and the creation of new hazardous material or waste sites. These include preparation and implementation of a Hazardous Materials Business Plan. In case of hazardous materials release, the City and County have emergency response teams that would respond to incidents involving hazardous materials.

If the project does not propose to store hazardous materials in quantities requiring a Hazardous Materials Business Plan, the most likely source of releases would be leaks of fluids from motor vehicles and spills of cleaning products and solvents used in commercial operations. Spills of these materials would be minimal, and the building floors and pavement would prevent these materials from directly entering the soil.

As previously noted, a project may have significant impacts if it would emit hazardous emissions or handle hazardous or acutely hazardous materials within one-quarter mile of an existing or proposed school. As has been noted, there are two existing schools within the CTSP Area – Central Valley High School and Hidahl Elementary School. However, as noted above, future development is either not expected to use hazardous materials in substantial quantities or would be required to prepare and implement a Hazardous Material Business Plan. The CTSP does not propose any land uses, such as industrial, that may use acutely hazardous materials.

Overall, future development under the proposed project either would not use substantial amounts of hazardous materials or would be subject to regulations and requirements that would minimize the impacts of potential releases. Therefore, project impacts regarding hazardous material releases would be less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required.

Impact HAZ-4: Hazardous Material Sites
As noted, a search of the EnviroStor and GeoTracker databases revealed no records of active hazardous materials sites within the project site. A search of other SWRCB lists likewise found no record of hazardous material sites.

As noted, agricultural activities that are currently being conducted within the CTSP Area likely use agricultural chemicals such as pesticides and herbicides. Residues from these chemicals may be present in the soils of agricultural lands. These residues, if present, may involve a hazard to future residents of the CTSP Area.

Development of agricultural, largely vacant, and previously used properties may involve demolition of existing structures and potential for releases of asbestos-containing material (ACM) and lead-based paint (LBP), both of which pose a health risk. Existing structures EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 11-10 November 2024 have not been assessed for ACM or LBP. Newer structures are unlikely to have these substances; however, demolition of older structures could potentially release ACM and LBP into the environment.

Mitigation measures described below would require that future development projects conduct a Phase I Environmental Site Assessment and comply with requirements for any necessary Phase II remediation prior to project approval. In addition, an ACM and LBP assessment shall be conducted for structures proposed for demolition, and these materials if present must be handled in accordance with applicable regulations. Implementation of these mitigation measures would reduce project impacts related to hazardous material sites to a level that would be less than significant.

Level of Significance: Potentially significant
Mitigation Measures:

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 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 act 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 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 EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 11-11 November 2024 protections. Permit applications for uses regulated shall include a Demolition Permit Release Form from the SJVAPCD.

Significance After Mitigation: Less than significant
Impact HAZ-4: Airport Hazards
As noted, a portion of the project site is within the Airport Influence Area of the Modesto City-County Airport as delineated within the Stanislaus County ALUCP. The predominant land use proposed by the CTSP within the Airport Influence Area would be Regional Commercial. Low Density Residential and High Density Residential land uses are also proposed. Both residential and commercial development are allowed outside the safety zones established for the Modesto Airport, so long as such development does not present a height obstruction or visual or electronic hazard to airport traffic.

It is unlikely that proposed development within the CTSP Area covered by the Airport Influence Area of the Modesto City-County Airport would present any obstacles to airport operations. Nevertheless, proposed development within the Airport Influence Area would be subject to Airport Land Use Commission review, which would be triggered during the City site plan and design review process. Mitigation prescribed below sets forth this requirement, along with a requirement that recommendations of the Airport Land Use Commission be implemented unless overridden by the City. Implementation of this mitigation would reduce potential impacts of the project related to airport operations to a level that would be less than significant.

Level of Significance: Potentially Significant
Mitigation Measures:

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.

Significance After Mitigation: Less than significant
Impact HAZ-5: Interference with Emergency Vehicle Access and Evacuations Construction work associated with development within the CTSP Area would mostly occur off existing roads. However, the project would also include improvements to existing roadways, including frontage improvements, installation and modification of utility lines along roadways, and widening of existing roadways. Such work could potentially interfere with emergency vehicle access and evacuations in the area. Under existing conditions in the CTSP Area, this is not as significant an impact due to lack of substantial development, EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 11-12 November 2024 although emergency access to the two existing schools could be affected. However, as development occurs, this impact would become more significant, as more residents and businesses would be affected by lack of emergency access and interference with evacuations.

Work within the public right-of-way would require an encroachment permit from the City or County as applicable. Mitigation presented below reiterates this requirement, with an additional requirement that preparation and implementation of a Traffic Control Plan be incorporated as a condition of the encroachment permit. The Traffic Control Plan would ensure that emergency vehicle access would be provided. Implementation of the mitigation measure would reduce project impacts on emergency vehicle access or emergency evacuation plans to a level that would be less than significant.

Level of Significance: Potentially significant
Mitigation Measures:

HAZ-5: Encroachment permits for work within the public right-of-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.

Significance After Mitigation: Less than significant
Impact HAZ-6: Wildfire Hazards
The Pocket Area is mostly developed with a few vacant lots. As this portion is within a mostly developed area, the wildfire hazard is considered low.

As has been noted, the CTSP Area currently is mostly rural and agricultural, although two schools have been developed. Agricultural land typically has a low wildfire hazard. As noted, the project site is not within a State Responsibility Area nor is it within a designated Fire Safety Hazard Zone, which are the primary concerns of the recently updated CEQA Guidelines Appendix G.

As discussed in Chapter 15.0, Public Services, fire protection services to the project site would be provided by the Modesto Fire Department under contract with the City once the project site is annexed. As development occurs within the CTSP Area, the amount of agricultural land – already considered to have a low wildfire hazard – would be reduced, providing even less opportunity for wildfires to start or spread.

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 11-13 November 2024 Overall, the project would not be subject to a significant wildfire risk. Project impacts related to wildfires would be less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
Impact HAZ-7: Waterway Hazards
Planned residential development under the CTSP would involve substantial increases in resident populations in the proposed CTSP Area. Along with proposed trail development, this could potentially lead to increased access to and along TID Lower Lateral 2, which is a public safety concern.

Cross sections of development along the TID lateral indicate that a barrier would be placed between the lateral and the proposed trail. In a comment letter on the NOP for this EIR (see Appendix A), TID states that its standards require the construction of a concrete or masonry wall at a minimum six feet in height on developed property that adjoins a canal.

Construction of a wall in accordance with TID standards would minimize potential trespassing. Moreover, TID noted in its NOP comment letter that any proposed trails that adjoin TID’s right-of-way along its canals will be subject to TID review and approval. This requirement is incorporated in the mitigation measure below. Implementation of this mitigation measure would reduce potential waterway hazard impacts to a level that would be less than significant.

Level of Significance: Potentially significant
Mitigation Measures:

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.

Significance After Mitigation: Less than significant
Impact HAZ-8: Railroad Hazards
As has been noted, accidents have occurred along the UPRR tracks in Stanislaus County, some of which were fatal. The CTSP Area would be adjacent to the UPRR tracks along SR

99. Future residential development would place more residents near these tracks, and development in general would generate increased vehicle traffic that may cross these tracks.

The proposed residential development in the CTSP Area would be set back approximately 900 feet from the UPRR tracks at its closest point. An overpass on Service Road would provide a crossing over the tracks and SR 99, which would be a more convenient facility to use, as crossing the tracks would also mean crossing SR 99 to get to the area to the east.

Vehicle traffic would be routed to existing roads and railroad crossings, particularly to the EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 11-14 November 2024 overpass on Service Road. Therefore, it is expected that the project would not lead to an increase in pedestrian or vehicle accidents on the UPRR tracks. Project impacts would be less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
EXHIBIT B ITEM 13
FIGURE 11-1
BaseCamp Environmental AIRPORT INFLUENCE AREA MAP
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Airport Influence Area Policy Map
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SPECIFIC PLAN AREA
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 12-1 November 2024

12.0 HYDROLOGY AND WATER QUALITY
ENVIRONMENTAL SETTING
Surface Waters
The Tuolumne River is the primary surface water resource in the Ceres area. The river forms the approximate northern boundary of the City, dividing it from the City of Modesto to the north. The Tuolumne River arises in the Sierra Nevada mountains and flows for approximately 149 miles before discharging into the San Joaquin River approximately 12 miles west of Ceres. The project site is approximately three miles south of the Tuolumne River. There are no other natural surface water features in the Ceres area, including within the CTSP Area.

Drainage patterns on the Ceres area are influenced by the relatively flat topography, which means that that precipitation either percolates into the ground or flows to ditches. These patterns have been extensively modified by agricultural and urban development. The project site is within the TID irrigation system, which is operated seasonally to provide irrigation water to agricultural lands within and outside the CTSP area. TID operates Lower Lateral 2, located along the southern boundary of the CTSP Area. Lower Lateral 2 is the only significant surface water feature within the project area. Chapter 17.0, Utilities and Energy, discusses the TID irrigation system in more detail.

Groundwater
The City currently relies on groundwater for all its water supply (see Chapter 18.0, Utilities and Energy). Groundwater levels at the project site ranged from 40 to 60 feet below ground surface in 2017, the most recent year for which data are available (WTSGSA/ETSGSA 2022).

The project site, along with the Ceres area, is in the Turlock Subbasin of the San Joaquin Valley Groundwater Basin. The Turlock Subbasin is bounded by the Tuolumne River on the north, the Merced River on the south, and the San Joaquin River on the west, covering approximately 544 square miles. Three principal aquifers were defined in the Turlock Subbasin, based on the existence of the Corcoran Clay geological units: the Western Upper Principal Aquifer above the Corcoran Clay, the Western Lower Principal Aquifer below the Corcoran Clay, and the Eastern Principal Aquifer east of the Corcoran Clay. (WTSGSA/ETSGSA 2022). The Subbasin is relatively isolated from other subbasins.

Groundwater from the Turlock Subbasin is used to supply both agricultural and urban water demand. In addition to the City of Ceres, four agricultural water districts and nine communities withdraw water from the Subbasin (City of Ceres 2018a).

EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 12-2 November 2024 Discharges from the subbasin occur from well pumping; groundwater seepage to the Tuolumne, Merced, and San Joaquin Rivers; discharges from subsurface agricultural drains; and water use by riparian vegetation. The majority of groundwater recharge in the Subbasin results from agricultural and landscape irrigation. Approximately 72 percent of total recharge within the Subbasin has been attributed to cropland irrigation. Other sources of recharge include precipitation, percolation from the Tuolumne and Merced Rivers flow, leakage from Turlock Lake, underflow from the Sierra Nevada foothills, and upward seepage from deep geologic fractures (City of Ceres 2018a).

The California Department of Water Resources (DWR) estimated a volume of fresh groundwater in storage between about 23 million acre-feet and 30 million acre-feet in the Turlock Subbasin as of 2006. According to a recently prepared Groundwater Sustainability Plan for the Turlock Subbasin, the historical average inflow to the subbasin from the 1991 to the 2015 water years was approximately 533,400 acre-feet per year. The average outflow, which included pumping for agricultural and urban uses, was 597,300 acre-feet per year, leading to an average reduction in groundwater storage of approximately 63,900 acre-feet per year. Pumping in the Eastern Principal Aquifer has created a cone of depression of groundwater in the central Subbasin. Despite this, no land subsidence has been recorded (WTSGSA/ETSGSA 2022).

Data indicate that the groundwater level at the project site has varied from approximately 40 feet above mean sea level to more than 60 feet above mean sea level. Land elevation is approximately 80 feet above mean sea level (WTSGSA/ETSGSA 2022). This indicates that the groundwater table may at times be at a depth of 20 feet below the ground surface.

It should be noted that a drainage well, operated by TID, is located on Blaker Road near the intersection with Service Road. A drainage well is used to lower groundwater levels in localized, high-groundwater areas and to supplement other irrigation water supplies (TID 2021). This may indicate that localized groundwater levels may be relatively shallow.

Flooding
The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Maps identify flooding hazards of various intensities, including 100-year and 500-year flood zones. The 500-year flood zone indicates those areas that have a 0.2 percent chance of flooding in a given year, and the 100-year flood zone indicates those areas having a 1.0 percent chance. In the Ceres area, the risk of flooding is limited predominantly to property in the vicinity of the Tuolumne River. Within the City of Ceres, small areas of residential development along River Road are in the 500-year flood zone, and larger areas in Modesto where SR 99 crosses the river are in the 100-year and 500-year flood zones, as indicated in Figure 12-1 (City of Ceres 2018a). FEMA Map No. 6099C0555F indicates no designated flood zones within the CTSP Area (FEMA 2021).

Senate Bill (SB) 5, also known as the Central Valley Flood Protection Act, was signed into law in 2007. A key feature of SB 5 and related legislation was to restrict urbanization within the 100-year standard areas potentially subject to 200-year frequency flooding, a more stringent standard than imposed by FEMA. The DWR has compiled Best Available Mapping in response to SB 5, including U.S. Army Corps of Engineers and FEMA 100- year, 200-year, and 500-year floodplain maps. The CTSP Area is not within a 200-year EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 12-3 November 2024 flood area (DWR 2023) and therefore future development is not subject to SB 5 requirements.

Dam failure is the collapse or failure of a water impoundment that causes significant downstream flooding. Stanislaus County has mapped potential dam inundation areas in the Ceres area along the Tuolumne River. Dams that may pose a risk of inundation in the Ceres area include the Don Pedro Dam, the New Exchequer Dam, the San Luis Dam, and the New Melones Dam. The project site is not within any of the mapped potential inundation areas of these dams (City of Ceres 2018a).

Water Quality
Water quality in the surface and groundwater systems can be affected by point and nonpoint sources of pollution. Point sources are single identifiable sources of pollution, such as a pipe or a drain, and can be agencies, businesses, or other parties discharging pollutants directly to a water body. Non-point pollution comes from many diffuse sources, and generally results from runoff, drainage, seepage, or hydrologic modification. Activities common in Ceres, including driving, farming, and lawn maintenance, produce non-point source pollutants that can enter surface water or groundwater through runoff. Stormwater runoff during storm events and runoff from irrigation and other urban uses of water carry contaminants such as gasoline, oil, pesticides, herbicides, and fertilizer into the river or groundwater supply (City of Ceres 2018a).

The Central Valley RWQCB has identified the lower Tuolumne River from Don Pedro Reservoir to the San Joaquin River as an impaired water body under Section 303(d) of the federal Clean Water Act for the following constituents: chlorpyrifos, diazanon, and Group A pesticides - chemicals associated with agricultural operations. The river is also impaired for mercury, water temperature, and toxicity (SWRCB 2022). As noted, there are no surface water features on the project site, and the project site is not adjacent to the Tuolumne River.

Potential constituents of concern identified in groundwater within the Turlock Subbasin include naturally occurring arsenic, uranium, manganese, sulfur, and total dissolved solids.

Anthropogenic-sourced contamination includes nitrates, salinity, 1,2,3-trichloropropane (1,2,3-TCP), tetrachlorethylene (PCE), and dibromochloropropane (DBCP), all from various agricultural or industrial-related land uses (WTSGSA/ETSGSA 2022). 1,2,3-TCP has been detected in some of the City’s wells used for drinking water; otherwise, groundwater meets drinking water standards (see Chapter 18.0, Utilities and Energy). All water used as drinking water is treated and disinfected before it is distributed to residents (City of Ceres 2022).

REGULATORY FRAMEWORK
Federal
Clean Water Act
The Clean Water Act, as administered by the EPA, seeks to restore and to maintain the chemical, physical, and biological integrity of the nation’s waters. It employs a variety of EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 12-4 November 2024 regulatory and non-regulatory tools to reduce direct pollutant discharges into waterways, to finance municipal wastewater treatment facilities, and to manage polluted runoff.

Section 303(d) requires that each state identifies water bodies or segments of water bodies that are “impaired” - not meeting one or more of the water quality standards established by the State. These waters are identified in the Section 303(d) list as waters that are polluted and need further attention to support their beneficial uses. The intent of the 303(d) list is to identify water bodies that require future development of a Total Maximum Daily Load for the pollutants causing the conditions of impairment. The Total Maximum Daily Load is the maximum amount of a pollutant that a water body can receive and still meet water quality standards. Typically, it is the sum of the allowable loads of a single pollutant from all contributing point and nonpoint sources. The Tuolumne River is on the Section 303(d) list as having impaired water quality, as discussed earlier in this chapter.

National Pollutant Discharge Elimination System
The Clean Water Act authorizes the EPA to implement water quality regulations. The National Pollutant Discharge Elimination System (NPDES) permit program, established under Section 402(p) of the Clean Water Act, controls water pollution by regulating stormwater discharges into the waters of the United States. California has an approved State NPDES program. The EPA has delegated authority for regulating stormwater discharges to the SWRCB, which in turn delegates this authority to the RWQCBs. The City of Ceres is regulated under the SWRCB Water Quality Order No. 2013-0001-DWQ, NPDES General Permit No. CAS000004. A description of the City’s permit program is provided later in this section.

National Flood Insurance Program
The National Flood Insurance Act of 1968 and the Flood Disaster Protection Act of 1973 mandate FEMA to evaluate flood hazards. FEMA provides Flood Insurance Rate Maps for local and regional planners to promote sound land use and floodplain development by identifying potential flood areas based on the current conditions. To delineate these maps, FEMA conducts engineering studies referred to as Flood Insurance Studies. Using information gathered in these studies, FEMA engineers and cartographers delineate Special Flood Hazard Areas on Flood Insurance Rate Maps. The Special Flood Hazard Area is the area where the floodplain management regulations of the National Flood Insurance Program must be enforced and the area where the mandatory purchase of flood insurance applies. These areas typically coincide with the 100-year floodplains. The most recent maps for the City of Ceres were completed and published in 2021.

State
Water Quality Control Plan (Basin Plan)
The Central Valley RWQCB has prepared a Water Quality Control Plan for the Sacramento River and San Joaquin River Basins (Basin Plan). The Basin Plan identifies water quality standards that support beneficial uses and help maintain water quality objectives for those uses. Beneficial uses listed for surface water bodies in the vicinity of the project site include municipal and domestic supply, agriculture supply, wildlife habitat, warm and cold EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 12-5 November 2024 freshwater habitat, contact and non-contact recreation, warm and cold-water migration of aquatic organisms and spawning, industrial process and service supply, and groundwater recharge (RWQCB 2015). The City achieves consistency with the standards of the Basin Plan through implementation of the City’s MS4 permit program, which is described below, as well as compliance with Waste Discharge Requirements applied to its wastewater treatment system, which is described in Chapter 18.0, Utilities and Energy.

SWRCB General Permits
SWRCB has adopted a general permit for construction activity to maintain surface water quality. As described in Chapter 9.0, Geology and Soils, project construction that causes one acre of ground disturbance or more is required to obtain a Construction General Permit, conditions for which include preparation of a SWPPP. Also, the SWRCB had issued NPDES General Permit No. CAS000004 for municipal storm drainage systems. A description of the City’s permit program is provided below.

Sustainable Groundwater Management Act
In 2014, the California Legislature passed the Sustainable Groundwater Management Act (SGMA), the purpose of which is to give local agencies greater authority to manage groundwater supplies. The legislation requires the formation of local Groundwater Sustainability Agencies (GSAs) that must assess conditions in their local water basins and adopt locally based management plans. The Turlock Subbasin is covered by two GSAs:
the West Turlock Subbasin GSA and the East Turlock Subbasin GSA. The West Turlock Subbasin GSA has ten member agencies, two of which are the City of Ceres and Stanislaus County.

Under SGMA, Groundwater Sustainability Plans for critically overdrafted basins are to be adopted by January 31, 2020, while other groundwater basins are required to adopt plans by January 31, 2022. The Turlock Subbasin was not designated a critically overdrafted basin; however, it was designated a “high priority” basin that required submittal of a Groundwater Sustainability Plan for the Subbasin by the 2022 deadline. A Groundwater Sustainability Plan for the Turlock Subbasin, involving both Turlock GSAs, was adopted and submitted to the DWR on January 6, 2022. In a letter dated January 18, 2024, DWR determined the plan was “incomplete”, identifying deficiencies that needed to be addressed. The DWR stated that the plan must provide more detailed explanation and justification regarding the selection for the sustainable management criteria for the chronic lowering of groundwater sustainability indicator. The plan also must provide specific details of feasible projects and management actions that will be implemented to mitigate overdraft and that will raise groundwater levels from interim milestones towards the minimum thresholds and measurable objectives to achieve sustainability in the Subbasin (DWR 2024).

The Groundwater Sustainability Plan follows the method prescribed by SGMA to measure undesirable results, which involves setting minimum thresholds and measurable objectives for representative wells. Groundwater level monitoring networks were developed for measurement of groundwater levels, and a separate network was established for groundwater quality monitoring. The C2VSim-TM modeling program was used to model EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 12-6 November 2024 the Subbasin hydrological system and to develop water budgets from which sustainable groundwater use was developed. Based on these analyses, the sustainable yield for longterm groundwater production would be approximately 310,700 acre-feet per year (WTSGSA/ETSGSA 2022).

Achieving sustainability in the Turlock Subbasin would require implementation of projects and management actions. These include water supply projects that either directly recharge groundwater, promote in-lieu groundwater recharge, or conserve water. A final list of 23 projects is included in the Groundwater Sustainability Plan. One of these is a Regional Surface Water Supply Project, an in-lieu groundwater recharge project involving the cities of Turlock and Ceres. The Regional Surface Water Supply Project would provide treated drinking water from the Tuolumne River to supplement both cities’ existing groundwater supplies. Other projects involve proposed facilities and activities for TID, the Eastside Water District, the Cities of Modesto and Turlock, and the community of Hickman (WTSGSA/ETSGSA 2022).

Local
Storm Water Management Program
As noted above, the City is regulated under NPDES General Permit No. CAS000004. The General Permit describes Waste Discharge Requirements for stormwater discharges from small municipal separate storm sewer systems (MS4s). A MS4 is defined as a system of conveyances which includes roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, channels, or storm drains. On December 8, 1999, the EPA issued Phase II regulations, which requires permits for stormwater discharges from small MS4s and from construction sites disturbing between one and five acres of land.

Ceres is a co-participant, along with the Cities of Newman, Patterson, and Riverbank, in a Storm Water Management Program prepared in compliance with the SWRCB General Permit for Small Cities under NPDES Phase II. Ceres is an automatically designated small MS4 operator. MS4 operators are required to develop a plan to undertake Minimum Control Measures, performance standards, and a work plan. The six categories of Minimum Control Measures that are included in the program consist of public outreach and education, public participation and involvement, illicit discharge elimination, BMPs for construction sites more than one-acre, post-construction BMPs, and municipal activities.

The program contains specific objectives for each measure (City of Ceres 2018a).

The City defers to Stanislaus County for post-construction standards. The applicable County post-construction standards depend on the size of the project. For “small projects”, which install between 2,500 and 5,000 square feet of impervious surface, the standards require a project proponent to select and implement one or more of the following site design measures: stream setbacks and buffers, soil quality improvement and maintenance, tree planting and preservation, rooftop and impervious area disconnection, porous pavement, green roofs, vegetated swales, and rain barrels and cisterns. For “regulated projects”, which install more than 5,000 square feet of impervious surface, the project proponent must identify potential sources of pollutants and to include in the design the appropriate BMPs/Source Controls consistent with the recommendations provided in the appropriate EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 12-7 November 2024 Storm Water BMP Handbook prepared by the California Stormwater Quality Association.

In addition, the project must incorporate Low Impact Development design standards, as well as select one or more of the site design measures (Stanislaus County 2015).

Ceres Municipal Code
Ceres Municipal Code Chapter 13.20 is the City’s Storm Water Management and Discharge Control Ordinance. The purpose of this ordinance is to protect and promote the health, safety, and general welfare of the citizens of the City by controlling non-storm water discharges to the stormwater conveyance system from spills, dumping, or disposal of materials other than storm water, and by reducing pollutants in urban storm water discharges to the maximum extent practicable. Among other provisions, the ordinance may require any business in the City engaged in activities that may result in pollutant discharges to develop and implement a storm water pollution prevention plan, and it requires any person performing construction activities in the City to prevent pollutants from entering the storm water conveyance system and comply with all applicable federal, State, and local laws, ordinances or regulations, including but not limited to the Construction General Permit.

Municipal Code Chapter 18.100 is the City’s Floodplain Management and Flood Hazard Identification Regulations Ordinance. This ordinance promotes public safety with provisions designed to minimize the need for flood control projects and damage to buildings and utilities due to flooding. The ordinance also ensures that potential buyers and occupiers of areas of special flood hazard are aware of the property’s location in the hazardous area and assume responsibility for their occupation thereof.

ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
Significance Thresholds
According to Appendix G of the CEQA Guidelines, a project may have a significant impact on hydrology and water quality if it would:
● Violate any water quality standards or waste discharge requirements, or otherwise substantially degrade surface or ground water quality, ● Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin,
● Substantially alter the existing drainage pattern of the area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site, impede or redirect flood flows, substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site, or create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff,
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 12-8 November 2024 ● In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation, or
● Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

Impact HYDRO-1: Surface Water Features and Quality
As noted, there are no existing natural surface water features located within the project site.

Neither the CTSP Area nor the Pocket Area involves any off-site elements located in or near existing surface waters. Therefore, the project would have no direct effect on existing natural surface water features.

Development under the proposed CTSP would generate new surface runoff. A substantial water quality concern associated with urban areas is pollutants carried by storm water from construction sites and post-construction areas of buildings, pavement, and landscaping.

This “urban runoff” conveys these pollutants to the City’s storm drainage system, and eventually to the terminal surface waters. Urban runoff pollutants may include sediments, heavy metals, petroleum hydrocarbons, microbial pathogens, pesticides, materials toxic to aquatic life, and nutrients that may contribute to decreased dissolved oxygen levels.

Residential development generates urban runoff from streets, driveways and parking areas, and yard areas may produce fertilizer wastes and/or bacterial contamination from animal excrement.

As described in more detail in Chapter 17.0, Utilities and Energy, storm water runoff from the City of Ceres is disposed of in part by discharge to four TID canals at 25 locations, and discharge in four locations to the Tuolumne River. Runoff from the CTSP area would not be discharged to the Tuolumne River, so there would be no direct impact on water quality of the river. Urban runoff discharged to the TID laterals would directly affect water quality in these channels. Future development under the CTSP is anticipated to involve drainage infrastructure that would lead to discharges into Lower Lateral 2, as indicated in a draft version of the City’s Storm Drain Master Plan (City of Ceres 2024a). Runoff from the CTSP Area would be subject to the City’s Storm Water Management Program and the provisions of Ceres Municipal Code Chapter 13.20, which would reduce the pollutants received by the TID channels. Runoff from the Pocket Area parcels would also be subject to the City’s storm water requirements.

As discussed in Chapter 3.0, Project Description, the CTSP would include on-site construction of stormwater quality treatment facilities, as part of connection to the City’s storm drainage system. The City maintains its system in accordance with State and Federal law, through implementing the provisions of Municipal Code Chapter 13.20, and future CTSP development is expected to do the same.

As noted in Chapter 9.0, Geology and Soils, construction activities associated with this development could disturb and loosen soils, which could be transported off-site by runoff and could eventually enter surface waters. Construction may also result in releases of other pollutants to the soil and the storm drainage system, including oil and gas, chemical substances used in the construction process, accidental discharges, waste concrete and EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 12-9 November 2024 wash water. Chapter 9.0 notes that construction activities would be subject to the Construction General Permit, conditions of which include implementation of a SWPPP and of BMPs to reduce potential erosion issues. Also, as discussed in Chapter 11.0, Hazards and Hazardous Materials, in accordance with SWPPP requirements, contractors have absorbent materials at construction sites to clean up minor spills. Other substances used in the construction process would be stored in approved containers and used in relatively small quantities, in accordance with the manufacturers’ recommendations and/or applicable regulations.

As noted, the City participates in a Storm Water Management Program prepared in compliance with the SWRCB General Permit for Small Cities under NPDES Phase II. The City is required to develop a plan to undertake Minimum Control Measures, including BMPs for construction sites more than one acre, and post-construction BMPs. BMPs for construction sites include
In summary, the CTSP and development pursuant to the CTSP would not be expected to violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface water quality, with implementation of State permit conditions and existing City requirements. Project impacts on surface waters and their water quality would be less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
Impact HYDRO-2: Groundwater Resources and Quality
The project would lead to further urbanization of the CTSP Area, which would eventually result in the elimination of existing agricultural and vacant land as well as remaining vacant lands within the Pocket Area. Although the CTSP Area is presently served with irrigation water supplied by TID, elimination of agricultural use may also involve cessation of groundwater withdrawals from agricultural and residential wells within the CTSP Area.

Existing groundwater withdrawals in the project area are, for the purposes of this EIR, assumed to be small.

Planned development of the CTSP Area would result in increased potable and non-potable water consumption, which would be supplied from the City’s existing water systems.

Development of the CTSP Area lead to or require the installation of new municipal wells as part of the City’s potable water system, in accordance with the City’s adopted Water Master Plan. These water needs will be met from the underlying groundwater system.

Chapter 17.0, Utilities and Energy, describes the potential water demands associated with CTSP development, along with available water supplies to satisfy these demands. It was found that these needs can be met without affecting the stability or sustainability of the groundwater system underlying the City. As a result, the CTSP would have a less-thansignificant effect on groundwater quantity.

The presence of a TID drainage well off Blaker Road indicates the potential for relatively shallow groundwater levels in portions of the CTSP Area. Development work, including excavation, could intercept groundwater, thereby leading to potential groundwater EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 12-10 November 2024 contamination, along with construction issues. A construction dewatering permit from the RWQCB is required for construction activities such as excavating and trenching in areas with shallow groundwater. Dewatering is regulated under state requirements for stormwater pollution prevention and control. Discharge of non-stormwater from an excavation or trench that contains sediments or other pollutants to water bodies is prohibited. Discharge of uncontaminated groundwater from an excavation or trench is a conditionally exempted discharge by the RWQCB. Since the removed water could be contaminated by chemicals released from construction equipment, disposal of this water would require permits either from the RWQCB for discharge to surface creeks or local agencies for discharge to sewers. Dewatering operations would require a NPDES permit, or an exemption, from the RWQCB, which would establish discharge limitations for specific chemicals, as applicable. Mitigation presented below would require a construction dewatering permit in areas with shallow groundwater.

Proposed development of the CTSP Area would result in additional buildings and pavement on previously undeveloped lands and the diversion of rainfall that would otherwise have percolated into soils, and eventually to the groundwater system, into the City storm drainage system. This would involve a direct and potentially significant reduction in groundwater recharge. In addition, the conversion of land from agricultural production would mean no cropland irrigation, which has been identified as a major source of recharge in the Turlock Subbasin (City of Ceres 2018a).

However, the project proposes approximately 42 acres of parks and other open space areas that would allow continued percolation and groundwater recharge. In addition, the GPEIR noted that General Plan policies would assist in preserving permeable surfaces, thereby supporting continued groundwater recharge. These policies include promoting the use of permeable surfaces for hardscape and minimizing the area of impervious surfaces. The GPEIR concluded that no additional mitigation would be required regarding groundwater recharge (City of Ceres 2018a). Since the project would have no impacts different from those described in the GPEIR, then impacts related to groundwater recharge would be less than significant.

As noted in the discussion under Impact HYDRO-1, development under the proposed CTSP would generate urban runoff that contains pollutants that could be conveyed to the City’s storm drainage system, and eventually to the terminal surface waters. Urban runoff also could percolate into the ground, and pollutants in urban runoff could reach underlying aquifers. New development would include storm water management BMPs that may include infiltration or detention of storm waters. Prevention of impacts on groundwater is ordinarily achieved by maintaining adequate separation between the ground surface and the groundwater table. Adequate separation for such filtering is typically in the range of about five to ten feet, depending on soil conditions. As noted, the groundwater table is 40- 60 feet below the ground surface in the project vicinity. As a result, infiltration of onsite storm water should not result in significant effects on groundwater quality.

Sewage disposal for new residential development would be to the City’s collection and treatment system, and not to individual on-site septic systems that could be a potential source of groundwater contamination. Proposed residential uses would involve the application of fertilizers and pesticides to landscaping, but this is not expected to involve EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 12-11 November 2024 potentially significant contributions to degradation of groundwater quality. Proposed commercial uses would not be expected to involve any substantial use of hazardous materials use; any such use would be subject to state and federal controls on hazardous materials use, storage and waste management as well as CUPA hazardous materials reporting containment and cleanup requirements. The proposed land uses in the CTSP Area are not expected to result in any substantial degradation of groundwater quantity.

Groundwater wells provide potable water to existing residences in the CTSP Area. Upon development, future land uses would be connected to the City’s water system. Therefore, existing groundwater wells would need to be plugged and abandoned to prevent contaminants from entering the underlying aquifers through these wells. Mitigation described below would require groundwater well abandonment prior to the start of development. Implementation of this mitigation measure would ensure that project impacts on groundwater quality would be less than significant.

Level of Significance: Potentially significant
Mitigation Measures:

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.

Significance After Mitigation: Less than significant
Impact HYDRO-3: Exposure to Flooding Hazards
As noted, the project site is not within a designated flood zone. CTSP development would not involve new contribution to flood flows in the Tuolumne River or other waterways. As noted, Ceres is exposed to potential flooding from catastrophic failure to large dams located in the foothill areas to the east of the City. However, the CTSP Area is not within a predicted flood hazard area that has been identified for these dams. In any case, the risk of failure of these facilities has been judged to be low.

The project site is not next to an ocean or other large body of water. Therefore, it would not be at any substantial risk of exposure to seiches or tsunamis. Overall, flooding impacts of the project would be less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 12-12 November 2024 Impact HYDRO-4: Conflict with Water Plans
As discussed under previous topic headings, the project would be required by City ordinance to comply with water quality provisions in the City’s Storm Water Management Program, including post-construction BMPs. These provisions are designed to ensure the City complies with the conditions of its NPDES MS4 permit. In turn, compliance with storm water requirements would ensure consistency with the water quality objectives and standards of the Basin Plan.

As noted, the Groundwater Sustainability Plan for the Turlock Groundwater Subbasin has been submitted to DWR, which determined it had deficiencies that needed to be addressed.

The project, as described above, could place significant new demands on groundwater supplies. However, the Regional Surface Water Supply Project is expected to provide an alternative source of water. This project is one of the projects described in the Groundwater Sustainability Plan for the Turlock Subbasin. The project and its planned water supplies do not involve any known conflicts with the Regional Surface Water Supply Project or any other projects described in the Groundwater Sustainability Plan. Moreover, the Groundwater Sustainability Plan incorporated information from the current Ceres General Plan, which proposed development in the CTSP Area. The water budget used in the plan assumed projected water usage based on General Plan buildout of the jurisdictions within the Subbasin, including Ceres.

The deficiencies identified by the DWR are mainly deficiencies in detailed information on measuring sustainability and on project implementation. It is not expected that CTSP and Pocket Area development would conflict with the proposed actions of the Groundwater Sustainability Plan, since the current Ceres General Plan was used in preparation of the plan. Project impacts related to water quality and groundwater management plans would be less than significant.

Level of Significance: Less than significant
Mitigation Measures: None required
EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 13-1 November 2024

13.0 LAND USE, POPULATION, AND HOUSING
ENVIRONMENTAL SETTING
Existing Land Uses
Both the CTSP and Pocket Areas are adjacent to and south of the City of Ceres in unincorporated Stanislaus County. As noted in Chapter 1.0, Introduction, both areas are within the City’s Sphere of Influence. The Sphere of Influence covers areas outside the City limits that are most likely to be included in the City’s boundaries within the next 20 years (City of Ceres 2012). The City’s current Sphere of Influence was approved by the Stanislaus LAFCo in 2012.

As described in Chapter 1.0, Introduction, land uses in the CTSP Area are mainly agricultural fields of row crops and orchards. However, substantial residential, light industrial, and institutional development has occurred in the area. The most prominent developed features are Central Valley High School, adjacent to the intersection of Service Road and Central Avenue, and Hidahl Elementary School, located along East Redwood Road. As indicated in Chapter 4.0, Aesthetics, the Pocket Area contains a mix of residential and commercial uses, and vacant land.

Both the CTSP and Pocket Areas are adjacent to the City; thus, existing land uses to the north of the project site are associated with City development. These include industrial, commercial, and residential land uses, including some mixed use residential. The land use becomes more predominantly single-family residential with distance from SR 99. Land uses to the south of the CTSP Area, across TID Lower Lateral 2, are predominantly agricultural with intermixed rural residential areas. To the west, industrial development has occurred between Morgan Road and Crows Landing Road adjacent to Service Road. Also in that area is the Ceres Wastewater Treatment Plant immediately west of Blaker Road.SR 99 is located along the eastern boundaries of the CTSP and Pocket Areas; the prevailing land uses east of SR 99 include the intermixed residential and commercial areas of the Ceres downtown and more recent regional commercial development along Mitchell Road.

As noted in Chapter 12.0, Hydrology and Water Quality, the project site is within the boundaries of the TID. Existing TID laterals, most notably the Ceres Main Canal and Lower Lateral 2, provide irrigation water to agricultural lands in and near the CTSP Area.

Although TID is the primary source of irrigation water for the area, domestic wells serve some existing uses in the area. Additional information on agriculture and Williamson Act contracts is provided in Chapter 5.0, Agricultural Resources.

Population Trends
The population of Ceres has increased by about 1,000% between 1960 and 2015, increasing from approximately 4,400 residents to nearly 46,900 in 2015. In comparison, the population of Stanislaus County increased by about 250 percent, growing from EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 13-2 November 2024 approximately 158,000 in 1960 to 530,000 in 2015 (City of Ceres 2018a). As of the 2020 U.S. Census, Ceres had a population of 48,998, which was an increase from the 2010 U.S.

Census population of 45,417. The increase in the City’s population between the two censuses was greater than the increase in the State’s population and slightly greater than that for Stanislaus County as a whole. Table 13-1 shows the population trends in the City of Ceres, Stanislaus County, and the State of California between 2010 and 2020.

TABLE 13-1

POPULATION OF CERES, STANISLAUS COUNTY, AND CALIFORNIA
Jurisdiction 2010 Population 2020 Population
Population
Growth,
2010-2020
Ceres 45,417 48,998 7.9%
Stanislaus County 514,453 552,878 7.5%
State of California 37,253,956 39,538,223 6.1%
Source: U.S. Census Bureau.

Housing Trends
According to the 2020 U.S. Census, the number of housing units in Ceres was 13,828, an increase from the 2010 U.S. Census total of 13,673. In 2020, approximately 76.4 percent of the housing units in Ceres were single detached (single-family residential) units.

Approximately 8.5 percent were apartment units in buildings of five or more units, 5.3 percent were in single attached units, 5.2 percent were mobile homes, and 4.6 percent were units in buildings of two to four units (duplexes, fourplexes). The vacancy rate was 2.1 percent, which was below the State average of 6.4 percent. The number of persons per household in Ceres in 2020 was 3.55 (California Department of Finance 2023). The population of Ceres has been growing at a faster rate than the number of new housing units, meaning that the average household size is increasing (City of Ceres 2018a).

REGULATORY FRAMEWORK
Ceres General Plan
The Ceres General Plan can be considered the City’s development “constitution,” containing both a statement of the community’s vision of its long-term development and the policies to support that vision by guiding the physical growth of the city. The General Plan contains policies to guide decision-making related to development, housing, transportation, environmental quality, public services, parks, and open spaces. It plans in a manner that meets future land needs based on the projected population and job growth. It also provides the basis for establishing and setting priorities for detailed plans and EXHIBIT B ITEM 13
Copper Trails Specific Plan and Annexation EIR 13-3 November 2024 implementing programs, such as the zoning ordinance, subdivision regulations, specific and master plans, and the Capital Improvement Program (City of Ceres 2018a).

While the project area is currently outside the City limits, it is within the Planning Area of the Ceres General Plan. As such, the Ceres General Plan has designated the project site for a variety of urban land uses, as shown in Figure 13-1. The predominant General Plan designations are currently Low Density Residential and Business Park. However, there are also designations for other higher-density residential uses, as well as for community commercial development, applying in some cases to existing development. Also, the Schools designation has been applied to the two existing schools within the CTSP Area.

Ceres General Plan policies that are applicable to the proposed project include the following (City of Ceres 2018b):
● 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.
● 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.

Ceres Housing Element
The Housing Element is a part of the Ceres General Plan, although the current version was adopted separately from the remainder of the General Plan in 2016. The purpose of the Housing Element is to identify the community's housing needs, state the community's goals and objectives with regard to housing production, rehabilitation, and conservation to meet those needs, and define the policies and programs that the community will implement to achieve the stated goals and objectives.

The City recently submitted an update of its Housing Element to HCD for its review. The update is part of the sixth cycle of statewide Housing Element updates, and it covers the time period of 2023 to 2031. In a letter dated December 14, 2023, the HCD stated that the City’s Housing Element would require revisions so as to comply with State Housing Element Law (California Government Code Section 65580 et seq.). The HCD requested additional analysis and clarification of specific issues related to housing needs, resources, and constraints. It also requested more information on housing programs being implemented by the City. The revised Housing Element update was submitted to the California Department of Housing and Community Development (HCD) for its review on July 1, 2024.