2 Should any underground storage tank(s) be found during the project, the applicant shall apply for and secure an Underground Storage Tank Removal Permit from the Fresno County Department of Public Health, Environmental Health Division. Contact the Fresno County Hazmat Compliance Program at (559) 600-3271 for more information.
The following comments pertain to the demolition of existing structures:
Should the structures have an active rodent or insect infestation, the infestation should be abated prior to demolition of the structures in order to prevent the spread of vectors to adjacent properties.
In the process of demolishing the existing structures, the contractor may encounter asbestos containing construction materials and materials coated with lead-based paints. If asbestos containing materials are encountered, contact the San Joaquin Valley Air Pollution Control District at (559) 230-6000 for more information. If the structures were constructed prior to 1979 or if lead-based paint is suspected to have been used in these structures, then prior to demolition and/or remodel work the contractor should contact the following agencies for current regulations and requirements:
California Department of Public Health, Childhood Lead Poisoning Prevention Branch, at (510) 620-5600.
United States Environmental Protection Agency, Region 9, at (415) 947-8000. State of California, Industrial Relations Department, Division of Occupational Safety and Health, Consultation Service (CAL-OSHA) at (559) 454-5302.
REVIEWED BY:
Kevin Tsuda, R.E.H.S.
Environmental Health Specialist II (559) 600-33271
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Lily Cha
City of Clovis
Planning and Development Services
1033 Fifth St.
Clovis, CA 93612
Project: The Palms at Alluvial 2 Initial Study and Mitigated Negative Declaration
District CEQA Reference No: 20221648
Dear Ms. Cha:
The San Joaquin Valley Air Pollution Control District (District) has reviewed the Initial Study (IS) and Mitigated Negative Declaration (MND) from the City of Clovis (City) for The Palms at Alluvial 2 residential development. Per the IS/MND, the project consists of 12 apartment units that are all designated for market rate rent, as well as a ± 3,160 square foot building for garages, associated landscaping, utility and pedestrian infrastructure, and sports fields (Project). The Project is located on the north side of Alluvial Avenue between Sunnyside and N. Fordham Avenues in Clovis, CA.
The District offers the following comments regarding the Project:
Project Related Emissions
Based on information provided to the District, Project specific annual criteria pollutant emissions from construction and operation are not expected to exceed any of the significance thresholds as identified in the District’s Guidance for Assessing and Mitigating Air Quality Impacts (GAMAQI):
https://www.valleyair.org/transportation/GAMAQI.pdf.
Construction Emissions
The District recommends, to reduce impacts from construction-related diesel exhaust emissions, the Project should utilize the cleanest available off-road construction equipment, including the latest tier equipment.
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Vegetative Barriers and Urban Greening
There are residential units located north and east of the Project. The District suggests the City consider the feasibility of incorporating vegetative barriers and urban greening as a measure to further reduce air pollution exposure on sensitive receptors (e.g., residential units).
While various emission control techniques and programs exist to reduce air quality emissions from mobile and stationary sources, vegetative barriers have been shown to be an additional measure to potentially reduce a population’s exposure to air pollution through the interception of airborne particles and the update of gaseous pollutants. Examples of vegetative barriers include, but are not limited to the following: trees, bushes, shrubs, or a mix of these. Generally, a higher and thicker vegetative barrier with full coverage will result in greater reductions in downwind pollutant concentrations. In the same manner, urban greening is also a way to help improve air quality and public health in addition to enhancing the overall beautification of a community with drought tolerant, low-maintenance greenery.
Clean Lawn and Garden Equipment in the Community
Since the Project consists of residential development, gas-powered lawn and garden equipment have the potential to result in an increase of NOx and PM2.5 emissions.
Utilizing electric lawn care equipment can provide residents with immediate economic, environmental, and health benefits. The District recommends the Project proponent consider the District’s Clean Green Yard Machines (CGYM) program which provides incentive funding for replacement of existing gas powered lawn and garden equipment. More information on the District CGYM program and funding can be found at: http://www.valleyair.org/grants/cgym.htm
and http://valleyair.org/grants/cgym-commercial.htm.
On-Site Solar Deployment
It is the policy of the State of California that renewable energy resources and zero- carbon resources supply 100% of retail sales of electricity to California end-use customers by December 31, 2045. While various emission control techniques and programs exist to reduce air quality emissions from mobile and stationary sources, the production of solar energy is contributing to improving air quality and public health. The District suggests that the City consider incorporating solar power systems as an emission reduction strategy for the Project.
Electric Vehicle Chargers
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charging infrastructure (Level 2 and 3 chargers). The purpose of the District’s Charge Up! Incentive program is to promote clean air alternative-fuel technologies and the use of low or zero-emission vehicles. The District recommends that the City and project proponents install electric vehicle chargers at project sites, and at strategic locations.
Please visit www.valleyair.org/grants/chargeup.htm for more information.
District Rules and Regulations
The District issues permits for many types of air pollution sources, and regulates some activities that do not require permits. A project subject to District rules and regulations would reduce its impacts on air quality through compliance with the District’s regulatory framework. In general, a regulation is a collection of individual rules, each of which deals with a specific topic. As an example, Regulation II (Permits) includes District Rule 2010 (Permits Required), Rule 2201 (New and Modified Stationary Source Review), Rule 2520 (Federally Mandated Operating Permits), and several other rules pertaining to District permitting requirements and processes.
The list of rules below is neither exhaustive nor exclusive. Current District rules can be found online at: www.valleyair.org/rules/1ruleslist.htm. To identify other District rules or regulations that apply to future projects, or to obtain information about District permit requirements, the project proponents are strongly encouraged to contact the District’s Small Business Assistance (SBA) Office at (559) 230-5888.
District Rules 2010 and 2201 - Air Quality Permitting for Stationary Sources
Stationary Source emissions include any building, structure, facility, or installation which emits or may emit any affected pollutant directly or as a fugitive emission. District Rule 2010 (Permits Required) requires operators of emission sources to obtain an Authority to Construct (ATC) and Permit to Operate (PTO) from the District. District Rule 2201 (New and Modified Stationary Source Review) requires that new and modified stationary sources of emissions mitigate their emissions using Best Available Control Technology (BACT).
This Project may be subject to District Rule 2010 (Permits Required) and Rule 2201 (New and Modified Stationary Source Review) and may require District permits. Prior to construction, the Project proponent should submit to the District an application for an ATC. For further information or assistance, the project proponent may contact the District’s SBA Office at (559) 230-5888.
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District Rule 9510 - Indirect Source Review (ISR)
The District has reviewed the information provided and has determined the project size is below the District Rule 9510, section 2.1 applicability threshold of 50 dwelling units for a residential development. Therefore, District Rule 9510 requirements and related fees do not apply to the project.
District Rule 4002 (National Emissions Standards for Hazardous Air Pollutants)
The Project will be subject to District Rule 4002 since the Project will include demolition, renovation, and removal of existing structures. To protect the public from uncontrolled emissions of asbestos, this rule requires a thorough inspection for asbestos to be conducted before any regulated facility is demolished or renovated. Any asbestos present must be handled in accordance with established work practice standards and disposal requirements.
Information on how to comply with District Rule 4002 can be found online at:
http://www.valleyair.org/busind/comply/asbestosbultn.htm.
District Rule 4601 (Architectural Coatings)
The Project will be subject to District Rule 4601 since it is expected to utilize architectural coatings. Architectural coatings are paints, varnishes, sealers, or stains that are applied to structures, portable buildings, pavements or curbs.
The purpose of this rule is to limit VOC emissions from architectural coatings.
In addition, this rule specifies architectural coatings storage, cleanup and labeling requirements. Additional information on how to comply with District Rule 4601 requirements can be found online at:
http://www.valleyair.org/rules/currntrules/r4601.pdf
District Regulation VIII (Fugitive PM10 Prohibitions)
The project proponent may be required to submit a Construction Notification Form or submit and receive approval of a Dust Control Plan prior to commencing any earthmoving activities as described in Regulation VIII, specifically Rule 8021 – Construction, Demolition, Excavation, Extraction, and Other Earthmoving Activities.
Should the project result in at least 1-acre in size, the project proponent shall provide written notification to the District at least 48 hours prior to the project proponents intent to commence any earthmoving activities pursuant to District Rule 8021 (Construction, Demolition, Excavation, Extraction, and Other Earthmoving Activities). Also, should the project result in the disturbance of 5- 341
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acres or more, or will include moving, depositing, or relocating more than 2,500 cubic yards per day of bulk materials, the project proponent shall submit to the District a Dust Control Plan pursuant to District Rule 8021 (Construction, Demolition, Excavation, Extraction, and Other Earthmoving Activities). For additional information regarding the written notification or Dust Control Plan requirements, please contact District Compliance staff at (559) 230-5950.
The application for both the Construction Notification and Dust Control Plan can be found online at:
https://www.valleyair.org/busind/comply/PM10/forms/DCP-Form.docx
Information about District Regulation VIII can be found online at:
http://www.valleyair.org/busind/comply/pm10/compliance_pm10.htm
District Rule 4901 - Wood Burning Fireplaces and Heaters
The purpose of this rule is to limit emissions of carbon monoxide and particulate matter from wood burning fireplaces, wood burning heaters, and outdoor wood burning devices. This rule establishes limitations on the installation of new wood burning fireplaces and wood burning heaters.
Specifically, at elevations below 3,000 feet in areas with natural gas service, no person shall install a wood burning fireplace, low mass fireplace, masonry heater, or wood burning heater.
Information about District Rule 4901 can be found online at:
http://valleyair.org/rule4901/
Other District Rules and Regulations
The Project may also be subject to the following District rules: Rule 4102 (Nuisance) and Rule 4641 (Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operations).
District Comment Letter
The District recommends that a copy of the District’s comments be provided to the Project proponent.
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If you have any questions or require further information, please contact Jacob Torrez by e-mail at [email protected] or by phone at (559) 230-6558.
Sincerely,
Brian Clements
Director of Permit Services
For: Mark Montelongo
Program Manager
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1 The Palms at Alluvial 2
GPA2022-001 & R2022-001
Initial Study and Mitigated Negative Declaration
December 2022
PREPARED BY:
Lily Cha
Senior Planner
Planning & Development Services
(559) 324-2335
[email protected]
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2 INITIAL STUDY
This Initial Study was prepared pursuant to the California Environmental Quality Act (CEQA) Public Resources Code Sections 21000 et seq ., CEQA Guidelines Title 14, Section 15000 et seq. of the California Code of Regulations.
PROJECT TITLE: The Palms at Alluvial 2
LEAD AGENCY NAME AND ADDRESS: City of Clovis
Planning & Development Services
1033 Fifth Street
Clovis, CA 93612
CONTACT PERSON AND PHONE
NUMBER:
Lily Cha, Senior Planner
(559) 324-2335
[email protected]
PROJECT LOCATION: 1491 Alluvial Avnue
Clovis, CA 93611
APN: 561-142-35
PROJECT SPONSOR’S NAME AND
ADDRESS:
Stallion Development and Construction
Arman Zakaryan
811 Barstow Avenue
Clovis CA 93612
LAND USE DESIGNATION: Low Density
ZONING DESIGNATION: See page 6 of this Initial Study
PROJECT DESCRIPTION See page 7 of this Initial Study
SURROUNDING LAND USES AND
SETTING:
See page 6 of this Initial Study
REQUIRED APPROVALS: See page 8 of this Initial Study
HAVE CALIFORNIA NATIVE AMERICAN
TRIBES REQUESTED CONSULTATION?
IF SO, HAS CONSULTATION BEGUN?
Yes
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3 TABLE OF CONTENTS
A. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED .......................................................................... 5 B. PROJECT OVERVIEW ................................................................................................................................... 6 C. PROJECT LOCATION .................................................................................................................................... 6 D. EXISTING SETTING ....................................................................................................................................... 6 Existing Conditions ............................................................................................................................... 6 Surrounding Conditions ........................................................................................................................ 6 Land Use Designation........................................................................................................................... 6 Zoning Designation ............................................................................................................................... 6 E. PROJECT DESCRIPTION .............................................................................................................................. 7 Project Entitlements .............................................................................................................................. 7 Project Construction.............................................................................................................................. 7 Site Preparation .................................................................................................................................... 7 Project Components ............................................................................................................................. 7 F. REQUIRED PROJECT APPROVALS ............................................................................................................. 8 G. TECHNICAL STUDIES ................................................................................................................................... 8 H. ENVIRONMENTAL CHECKLIST .................................................................................................................. 16
1. Aesthetics ........................................................................................................................................... 16
2. Agriculture and Forestry Resources.................................................................................................... 18
3. Air Quality ........................................................................................................................................... 20
4. Biological Resources .......................................................................................................................... 24
5. Cultural Resources ............................................................................................................................. 27
6. Energy ................................................................................................................................................ 29
7. Geology and Soils ............................................................................................................................... 30
8. Greenhouse Gas Emissions ............................................................................................................... 33
9. Hazards and Hazardous Materials ...................................................................................................... 36
10. Hydrology and Water Quality .............................................................................................................. 39
11. Land Use and Planning....................................................................................................................... 43
12. Mineral Resources .............................................................................................................................. 44
13. Noise................................................................................................................................................... 45
14. Population and Housing ...................................................................................................................... 47
15. Public Services ................................................................................................................................... 48
16. Recreation .......................................................................................................................................... 50
17. Transportation ..................................................................................................................................... 51
18. Tribal Cultural Resources ................................................................................................................... 52
19. Utilities and Service Systems .............................................................................................................. 54
20. Wildfire ................................................................................................................................................ 57
21. Mandatory Findings of Significance .................................................................................................... 58 I. REPORT PREPARATION ..................................................................................................................................... 61 346
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4 LIST OF FIGURES
FIGURE 1: PROJECT LOCATION AND EXISTING CONDITIONS .................................................................................................................... 10 FIGURE 2: GENERAL PLAN LAND USE DESIGNATION ............................................................................................................................. 11 FIGURE 3: ZONING ........................................................................................................................................................................ 12 FIGURE 4: SITE PLAN...................................................................................................................................................................... 13 FIGURE 5: CONCEPTUAL ELEVATIONS "MAIN BUILDING" ...................................................................................................................... 14 FIGURE 6: CONCEPTUAL ELEVATION "GARAGE BUILDING" .................................................................................................................... 15
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5 A. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
The environmental factors checked below would be potentially affected by this project, as indicated by the checklist and corresponding discussion in this Initial Study.
Aesthetics Agriculture & Forestry Resources Air Quality Biological Resources Cultural Resources Energy
Geology & Soils Greenhouse Gas Emissions Hazards & Hazardous Materials Hydrology & Water Quality Land Use/Planning Mineral Resources Noise Population/Housing Public Services
Recreation Transportation Tribal Cultural Resources
Utilities & Service Systems Wildfire Mandatory Findings of Significance
Determination
On the basis of this initial evaluation:
I find that the proposed Project COULD NOT have a significant effect on the environment and a NEGATIVE DECLARATION will be prepared.
I find that, although the proposed Project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or a greed to by the project proponents. A MITIGATED NEGATIVE DECLARATION will be prepared.
I find that the proposed Project MAY have a significant effect on the environmental, and an ENVI RONMENTAL IMPACT REPORT (EIR) will be prepared.
I find that the proposed Project MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact on the environmental, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets.
An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.
I find that although the proposed Project could have a significant effect on the environment, because all potentially signifi cant effects (a) have been analyzed adequately analyzed in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed Project, nothing further is required.
Prepared By:
______________________________ ____________________
Lily Cha, Senior Planner Date
City of Clovis Planning & Development Services
Approved By:
______________________________ ____________________
Renee Mathis, Director Date
City of Clovis Planning & Development Services
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6 B. PROJECT OVERVIEW
Arman Zakaryan, Stallion Development and Construction (applicant), proposes the construction of a multifamily residential complex totaling ±19,320 square feet along with associated site improvements (i.e. landscape, parking, sidewalks, and utilities infrastructure) on a ±1.04 acre site located north of Alluvial Avenue and east of Sunnyside Avenue in the City of Clovis, California, herein referred to throughout the document as “proposed Project” and/or “Project.” Details regarding the Project and operations are described more fully below beginning under Section E of this Initial Study.
C. PROJECT LOCATION
As shown in Figure 1 below, the Project is located on the north side of Alluvial Avenue, between Sunnyside and N. Fordham Avenues and is approximately 1.04 acres in area. The Project will occupy the entire parcel with Accessor’s Parcel Number (APN) 563-142-35.
D. EXISTING SETTING
This section describes the existing conditions, surrounding conditions, as well as the General Plan land use and zoning designations.
EXISTING CONDITIONS
As shown in Figure 1 below, t he existing a dilapidated residence with a detache d garage and accessory structure. A portion of the residence has been damaged by fire and had not been repaired. Both accessory buildings also appear to be in disrepair. The rest of the site is unimproved but shows signs of disturbance with routine maintenance for fire and weed abatement. The property is unoccupied.
SURROUNDING CONDITIONS
As referenced below in Table 1, and shown on Figure 1, the Project site is surrounded by existing residential development to the north, east, and south. To the west is a residential property that was converted into a church.
As mentioned above, some food processing activities would continue to occur at the northern portion of the site.
Table 1: Surrounding Land Uses
Land Use Designation Existing Zoning* Existing Land Use North Low Density Residential R-1-7500 Single-Family Residential East Low Density Residential R-1-7500 Single-Family Residential South Low Density Residential R-1-7500 Single-Family Residential West Church R-1-7500 Church
*R-1-7500 (Single-Family Residential – 7,500 square feet)
LAND USE DESIGNATION
As shown on Figure 2, the Project site has an existing General Plan Land Use designations of Low Density and Residential. The Low Density Residential designation allows for single-family residential development at a density of 2.1 to 4.0 dwelling units per acre. The applicant proposes to amend the General Plan Land Use to the Medium High Density that allows for residential development with a density of 7.1 to 15.0 dwelling units per acre. The amendment is being processed with General Plan Amendment GPA 2022-001.
ZONING DESIGNATION
As shown on Figure 3, the Project site is currently zoned R-1-7500 (Single-Family Residential– 7,500 square feet), however, proposes a rezone to the R-2 Zone District (Multifamily Medium -High Density). The R-2 Zone District is consistent with the proposed Medium High Density land use designation.
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7 E. PROJECT DESCRIPTION
The subject parcel is a ± 1.04 acre urban in-fill property designated for Low Density Single-Family development in the City of Clovis General Plan. The applicant is proposing to redesignate and rezone the project site to allow for the development of a multifamily complex. The Project proposes 12 apartment units that are all designated for market rate rent. The Project consists of a ± 16,160 square foot building to accommodate the 12 units, as well as a ± 3,160 square foot building for garages, associated landscaping, utility and pedestrian infrastructure, and sprots fields.
This section describes the components of the proposed Project in more detail, including site preparations, proposed structures, and on- and off- site improvements.
PROJECT ENTITLEMENTS
The Project would include several planning entitlements, including a general plan a mendment, rezone, and multiple family design review. The general plan amendment is to redesignate the property from the Low Density Residential designation to the Medium High Density designation, the rezone is to bring the zoning into consistency with the proposed general plan land use designation, and the multiple family design review is required to memorialize the design and layout of the buildings.
PROJECT CONSTRUCTION AND PHASING
The Project is anticipated to begin construction spring of 2023 with full buildout by Fall of 2023.
SITE PREPARATION
Site preparation would include the demolition of the existing structures and typical grading activities to ensure an adeuqatley graded site for drainage purposes. Part of the preparation would include the removal of any vegetation, crops, and trees necessa ry to accommodate the Project. Other site preparation activities would include minor excavation for the installation of utility infrastructure, for coneyance of water, sewer, stormwater, and irrigation.
PROJECT COMPONENTS
This section describes the overal l components of the Project, such as the proposed buildings, landscape, vehicle and pedestrian circulation, and utilities.
DEMOLITION
The existing residence and accessory buildings will be demolished with this site plan.
CONCEPTUAL SITE LAYOUT AND ELEVATIONS
While this section discusses the general site layout and elevations, it is important to note that the actual site will be reviewed more fully during the City’s multiple family design review process. As shown in Figure 4, the Project proposes construction of a ± 16,160 square foot building to accommodate the 12 apartment units. Of the 12 units, ten (10) are two-bedroom units and two (2) are 3-bedroom units. There will also be a ± 3,160 square foot building designated for individual garages. The apartment building is situated towards the street frontage of the site, while the garage building is towards the rear of the site. Additional parking stalls are provided along the west and east sides of the apartment building.
Conceptual elevations for th e apartment building is shown in Figure 5 respectively. As shown, the apartment building is 2 stories with a maximum height of 33 feet at its peak. Although conceptual at this time, the exterior has a modern look and feel with its shape and material using a mixture stucco, composite cladding and metal.
The garage building is single-story with a maximum height of 12 feet. The material will be the same as the main building. Development of the project will be in accordance with the City of Clovis’ Multifamily Objective Standards and the R-2 Zone District standards.
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8 SITE CIRCULATION AND PARKING
The Project would be accessed via two (2) points of ingress/egress from Alluvial Avenue. On-site parking would be provided per the CMC standards for parking spaces for m ulti-family development. Although ±26 vehicle spaces are proposed, the final parking calculation will be reviewed during the City’s Multi-Family Design Review process. Installation of pedestrian paths of travel would be required as part of the Project fro m the Alluvial Avenue frontage. Although the details have not yet been provided, these features would be per City of Clovis Development Code standards and/or in compliance with Americans with Disabilities Act (ADA) requirements.
LANDSCAPE
The Project would include landscape throughout the site. Landscaped areas would generally be located along the frontage of each structure where a variety of ornamental shrubs, plants, and trees would be planted, as well as landscape in areas throughout the parking lots, c onsistent with the CMC. Landscape plans are typically provided during the City’s Multi-Family Design Review process at which time the proposed landscape would be reviewed for compliance with the City’s water efficient landscape regulations and guidelines.
UTILITIES
Utilities for the site would consist of water, sewer, electric, cable, gas, and stormwater infrastructure. Minor trenching and digging activities would be required for the installation of necessary pipelines typical of commercial development. All utility plans would be required to be reviewed and approved by the appropriate agency, and/or department to ensure that installation occurs to pertinent codes and regulations. Other infrastructure would include new fire hydrants as required by the City of Clovis Fire Department.
Utilities are provided by and managed from a combination of agencies, including FID which provides the City’s water supply which is then supplied to customers by the City of Clovis, Fresno Metropolitan Flood Control District (FMFCD) which has responsibility for storm water management, and the City’s public utilities department which provides for solid waste collection, and sewer collection services. Pacific Gas & Electric (PG&E) provides electricity and natural gas within the City of Clovis.
F. REQUIRED PROJECT APPROVALS
The City of Clovis requires the following review, permits, and/or approvals for the proposed Project; however, other approvals not listed below may be required as identified throughout the entitlement process:
• General Plan Amendment
• Rezone
• Multi-Family Design Review
• Grading Permit
• Building Permit
• Sign Permit
• San Joaquin Unified Air Pollution Control District
• Fresno Metropolitan Flood Control District
G. TECHNICAL STUDIES
The analysis of the Project throughout this Initial Study relied in part on the technical studies listed below prepared for the Project, as well as other sources, including, but not limited to, the 2014 Clovis General Plan Environmental Impact Report (EIR), departmental staff, California Department of Conservation, and the California Department of Toxic Control Substances.
• Appendix A: Air Quality and Greenhouse Gas Technical Memorandum • Appendix B: Biological Resource Assessment
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9 • Appendix C: Archaeological Resources Survey
• Appendix D: Historical Evaluation
• Appendix E: Traffic Generation Analysis
• Appendix F: Water
• Appendix G: Sewer
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10 Figure 1: Project Location and Existing Conditions
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11 Figure 2: General Plan Land Use Designation
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12 Figure 3: Zoning
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13 Figure 4: Site Plan
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14 Figure 5: Conceptual Elevations "Main Building"
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15 Figure 6: Conceptual Elevation "Garage Building"
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16 H. ENVIRONMENTAL CHECKLIST
This section provides an evaluation of the potential environ mental impacts of the proposed p roject and are based on CEQA Guidelines Appendix G. For each issue area, one of four conclusions is made:
• No Impact: No project-related impact to the environment would occur with project development. • Less Than Significant Impact: The proposed project would not result in a substantial and adverse change in the environment. This impact level does not require mitigation measures. • Less Than Significant with Mitigation Incorporated : The proposed project would result in an environmental impact or effect that is potentially signi ficant, but the incorporation of mitigation measure(s) would reduce the project-related impact to a less than significant level. • Potentially Significant Impact: The proposed project would result in an environmental impact or effect that is potentially significant, and no mitigation can be identified that would reduce the impact to a less than significant level.
1. AESTHETICS
Except as provided in Public Resources
Code Section 21099, would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Have a substantial effect on a scenic
vista? X
b. Substantially damage scenic resources,
including, but not limited to, trees, rock
outcroppings, and historic buildings
within a state scenic highway?
X
c. Substantially degrade the existing visual
character or quality of public views of the
site and its surroundings? (Public views
are those that are experienced from
publicly accessible vantage point). If the
project is in an urbanized area, would the
project conflict with applicable zoning
and other regulations governing scenic
quality?
X
d. Create a new source of substantial light
or glare that would adversely affect day
or nighttime views in the area?
X
ENVIRONMENTAL SETTING
The City of Clovis is located within the San Joaquin Valley. Thus, much of the City and its surrounding areas are predominately flat. As a result, on clear days, the Sierra Nevada Mountains are visible to the east depending on your location. Aside from Sierra Nevada, there are no officially designated focal points or viewsheds within the City. However, Policy 2.3, Visual Resources, of the Open Space Element of the 2014 Clovis General Plan, requires maintaining public views of open spaces, parks, and natural features and to preserve Clovis’ viewshed of the surrounding foothills.
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17 As mentioned above in the Project Description, the site is located north of Alluvial and east of Sunnyside . In general, the Project site is within an urbanized area of the City surrounded by existing residential to the north, east, and south, as well as a church west of the site . A s a result, the area is characterized by a mix of development types and uses, as well as typical infrastructure, such as roadways, streetlights, parking lot lights, and ambient light sources typical of residential development.
DISCUSSION
Would the project have a substantial effect on a scenic vista?
Less-Than-Significant Impact. As mentioned above, there are no officially designated scenic vistas or focal points in the City of Clovis. While the Sierra Nevada Mountains can be viewed on clear days, the Project would be consistent with the proposed R -2 zone district standards which allows structures to be constructed at a maximum height of 35 feet. Although the maximum height limit is 35 feet/2-1/2 stories for R-2 zone district, the Project proposes a maximum height of approximately 3 3 feet, which is below what is allowed under the development standards. Lastly, General Plan Policy 2.3 requires that public views of open spaces, parks, and natural features be maintained; however, the Project site is not within the immediate vicinity of these features.
Therefore, because the Project would be constructed at a maximum height consistent with the proposed R-2 Zone District and surrounding R-1-7500 Zone District development standards, a less-than-significant impact would occur with regards to the Project having a substantial effect on a scenic vista. As a result, no mitigation measures are required.
Would the project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State scenic highway?
No Impact. As stated in the 2014 Clovis General Plan Environmental Impact Report EIR, there are no Caltrans- designated scenic highways within the City of Clovis.1 Further, there are no existing historical structures or rock outcroppings located on or within the immediate vicinity of the site, T herefore, the Project would result in no impact with regards to substantially damaging scenic resources within a State scenic highway, and no mitigation measures are required.
Would the project substantially degrade the existing visual character or quality of public views of the site and its surroundings ? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
Less-Than-Significant Impact. As mentioned previously, the existing site is within an urbanized area surrounded by primarily residential and church land uses. Thus, the area is generally characterized by different types of structurers at varying heights, design, and c haracter. The Project proposes to construct a ±16,160 square foot building to accommodate the 12 units, as well as a ±3,160 square foot building for garages. The main building will be 33 feet tall and situated near the front of the parcel. The garage building is 12 feet tall and situated behind the main building. Such uses would not substantially degrade from the existing visual character or quality of public views of the site and its surroundings. Further, as mentioned above, there are no officially designated scenic areas in the City, and none specifically at or surrounding the site itself.
In addition, the Project proposes that the structures would be at a height below the maximum height limit permitted under the proposed R-2 Zone District and surrounding R-1-7500 Zone District. Thus, the Project is within the scale and character of the area and would not substantially degrade the existing visual character.
Lastly, the Project would undergo Site Plan Review ( SPR) which would ensure that the overall design and
1 2014 Clovis General Plan EIR, June 2014, Page 5.1-1.
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18 character is consistent a nd/or complements the surrounding areas. The SPR process will ensure the Project complies with relevant design policies, such as General Plan, Multifamily Objective Standards, and the Clovis Development Code. During the review, the height, color and materials are reviewed for consistency with these plans and guidelines. Consequently, a less-than-significant impact would occur with regards to substantially degrading the existing visual character of the site and its surroundings, and no mitigation measures are required.
Create a new source of substantial light or glare that would adversely affect day or nighttime views in the area?
Less-Than-Significant Impact With Mitigation. The Project consists of a multifamily residential complex. The proposed Project would introduce new sources of light and glare , although there are current uses on the site that already produce light and glare. Light and glare from the Project would be typical of a multifamily residential type development, which may include sources such as exterior lighting for safety, and light and glare from vehicles reflecting from surfaces such as windshields. Other sources of light would be the interior lighting of the buildings at night. These sources of light and glare are not typically associated with causing significant effects on the environment. Further, the site is already surrounded by existing uses, such as residential and church, which as a result has established existing sources of light and glare . These sources of existing light and glare are comprised of streetlights, exterior and interior light and glare from existing homes, and from vehicles going to and from the neighborhood. Other sources of existing light and glare derive from vehicles travelling along Sunnyside and Alluvial Avenues.
Although the Project would introduce new s ources of light and glare, the SPR process would ensure that the design and placement of lighting is appropriate to minimize potential light and glare impacts to surrounding properties. In addition, compliance with Mitigation Measure AES-1 would ensure that light and glare impacts be less than significant with mitigation.
Mitigation Measure AES-1: The Project shall comply with Section 9.22.050, Exterior Light and Glare, of the Clovis Municipal Code (CMC or Development Code), which requires light sources to be shielded and that lighting does not spillover to adjacent properties.
2. AGRICULTURE AND FORESTRY RESOURCES
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. 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 of the California Resources
Agency, to non-agricultural use.
X
b. Conflict with existing zoning for
agricultural use, or a Williamson Act
contract? X
c. Conflict with existing zoning for, or
cause rezoning of, forest land (as
defined in Public Resources Code
X
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19 section 12220 (g)) or timberland (as
defined in Public Resources Code
section 4526)?
d. Result in the loss of forest land or
conversion of forest land to non-forest
use? X
e. Involve other changes in the existing
environment which, due to their
location or nature, could result in
conversion of Farmland to non -
agricultural use or conversion of forest
land to non-forest use?
X
ENVIRONMENTAL SETTING
The Project site is located in the northeast area of Alluvial and Sunnyside Avenues and considered an in-fill property. The site is within an urbanized area of the City and is surrounded a mix of existing developments types.
DISCUSSION
Would the project 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 of the California Resources Agency, to non-agricultural use?
No Impact. The project site is not Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland). The project site was previously used as a single -family residence. The Project proposes to redevelop the site to a multifamily residential complex.
Would the project conflict with existing zoning for agricultural use, or a Williamson Act Contract?
No Impact. As shown on Figure 5.2-2 of the Agricultural Resources Chapter of the 2014 Clovis General Plan EIR, the Project site is not under a Williamson Act Contract. Further, the site is not currently zoned or designated for agricultural use. As a result, the Project would have no impact with regards to conflicting with existing zoning for agricultural use or a Williamson Act Contract. No mitigation measures are required.
Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220 (g)) or timberland (as defined in Public Resources Code section 4526)?
No Impact. The Project site does not contain forest land. Further, the site is not zoned for forestry or other forestry related uses. As a result, no impact would occur with regards to conflicts with existing zoning for, or cause rezoning of, forest land. No mitigation measures are required.
Would the project result in the loss of forest land or conversion of forest land to non-forest use?
No Impact. See discussion under Section 2c.
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20 Would the project involve other changes in the existing environ ment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non- forest use?
No Impact. See discussion under Section 2a.
3. AIR QUALITY
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Conflict with or obstruct implementation
of the applicable air quality plan? X
b. 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 ambient air quality standard?
X
c. Expose sensitive receptors to
substantial pollutant concentrations? X
d. Result in other emissions (such as
those leading to odors) adversely
affecting a substantial number of
people?
X
ENVIRONMENTAL SETTING
An Air Quality and Greenhouse Gas Analysis Report (AQ/GHG Report) was prepared by Johnson Johnson and Miller Air Quality Consulting on June 29, 2022 (see Appendix A). Information in this AQ/GHG Report is used for the analysis included in both the Air Quality and Greenhouse Gas Emissions section of this Initial Study.
San Joaquin Valley Air Basin
The City of Clovis (City) is in the central portion of the San Joaquin Valley Air Basin (SJVAB). SJVAB consists of eight counties: Fresno, Kern (western and central), Kings, Tulare, Madera, Merced, San Joaquin, and Stanislaus. Air pollution from significan t activities in the SJVAB includes a variety of industrial -based sources as well as on - and off-road mobile sources. These sources, coupled with geographical and meteorological conditions unique to the area, stimulate the formation of unhealthy air.
The SJVAB is approximately 250 miles long and an average of 35 miles wide. It is bordered by the Sierra Nevada in the east, the Coast Ranges in the west, and the Tehachapi mountains in the south. There is a slight downward elevation gradient from Bakersfield i n the southeast end (elevation 408 feet) to sea level at the northwest end where the valley opens to the San Francisco Bay at the Carquinez Straits. At its northern end is the Sacramento Valley, which comprises the northern half of California’s Central Val ley. The bowl -shaped topography inhibits movement of pollutants out of the valley (SJVAPCD 2012a).
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21 Topography
The topography of a region is important for air quality because mountains can block airflow that would help disperse pollutants and can channel air from upwind areas that transports pollutants to downwind areas. The San Joaquin Valley Air Pollution Control District (SJVAPCD) covers the entirety of the SJVAB. The SJVAB is generally shaped like a bowl. It is open in the north and is surrounded by m ountain ranges on all other sides.
The Sierra Nevada mountains are along the eastern boundary (8,000 to 14,000 feet in elevation), the Coast Ranges are along the western boundary (3,000 feet in elevation), and the Tehachapi Mountains are along the southern boundary (6,000 to 8,000 feet in elevation).
Climate
The SJVAB is in a Mediterranean climate zone and is influenced by a subtropical high-pressure cell most of the year. Mediterranean climates are characterized by sparse rainfall, which occurs mainly in winter. Summers are hot and dry. Summertime maximum temperatures often exceed 100°F in the valley.
The subtropical high-pressure cell is strongest during spring, summer, and fall and produces subsiding air, which can result in temperature inversions in t he valley. A temperature inversion can act like a lid, inhibiting vertical mixing of the air mass at the surface.
Any emissions of pollutants can be trapped below the inversion. Most of the surrounding mountains are above the normal height of summer inversions (1,500–3,000 feet).
Winter-time high pressure events can often last many weeks, with surface temperatures often lowering into the 30°F. During these events, fog can be present and inversions are extremely strong. These wintertime inversions can inhibit vertical mixing of pollutants to a few hundred feet (SJVAPCD 2012a).
Ambient Air Quality Standards
The Clean Air Act (CAA) was passed in 1963 by the US Congress and has been amended several times. The 1970 Clean Air Act amendments strengthened previ ous legislation and laid the foundation for the regulatory scheme of the 1970s and 1980s. In 1977, Congress again added several provisions, including nonattainment requirements for areas not meeting National AAQS and the Prevention of Significant Deteriora tion program.
The 1990 amendments represent the latest in a series of federal efforts to regulate the protection of air quality in the United States. The CAA allows states to adopt more stringent standards or to include other pollution species. The California Clean Air Act (CCAA), signed into law in 1988, requires all areas of the state to achieve and maintain the California AAQS by the earliest practical date. The California AAQS tend to be more restrictive than the National AAQS, based on even greater health and welfare concerns.
These National and California AAQS are the levels of air quality considered to provide a margin of safety in the protection of the public health and welfare. They are designed to protect “sensitive receptors,” those most susceptible to further respiratory distress, such as asthmatics, the elderly, very young children, people already weakened by other disease or illness, and persons engaged in strenuous work or exercise. Healthy adults can tolerate occasional exposure to air pollu tant concentrations considerably above these minimum standards before adverse effects are observed.
Both California and the federal government have established health based AAQS for seven air pollutants. As shown in Table 3, Ambient Air Quality Standards for Criteria Pollutants, these pollutants are ozone (O3), nitrogen dioxide (NO2), carbon monoxide (CO), sulfur dioxide (SO2), coarse inhalable particulate matter (PM10), fine inhalable particulate matter (PM2.5), and lead (Pb). In addition, the s tate has set standards for sulfates, hydrogen sulfide, vinyl chloride, and visibility -reducing particles. These standards are designed to protect the health and welfare of the populace with a reasonable margin of safety.
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22 In addition to the criteria pollutants, toxic air contaminants (TACs) are another group of pollutants of concern.
TACs are injurious in small quantities and are regulated despite the absence of criteria documents. The identification, regulation and monit oring of TACs is relatively recent compared to that for criteria pollutants.
Unlike criteria pollutants, TACs are regulated based on risk rather than specification of safe levels of contamination.
Table 3: Ambient Air Quality Standards
Pollutant
Averaging
Time
Federal
Primary
Standard
State
Standard
Ozone 1-Hour
8-Hour
--
0.07 ppm
0.09 ppm
0.07 ppm
Carbon Monoxide 8-Hour
1-Hour
9.0 ppm
35.0 ppm
9.0 ppm
20.0 ppm
Nitrogen Dioxide Annual
1-Hour
0.053 ppm
0.100 ppm
0.03 ppm
0.18 ppm
Sulfur Dioxide Annual
24-Hour
3-Hour
1-Hour
0.03 ppm
0.14 ppm
0.5 ppm
0.075 ppm
--
0.04 ppm
0.25 ppm
PM10 Annual
24-Hour
--
150 ug/m3
20 ug/m3
50 ug/m3
PM2.5 Annual
24-Hour
12 ug/m3
35 ug/m3
12 ug/m3
--
Lead 30-Day Avg.
3-Month Avg.
--
1.5 ug/m3
1.5 ug/m3
--
Notes: ppm = parts per million; ug/m3 = micrograms per cubic meter.
Source: California Air Resources Board, 2008. Ambient Air Quality Standards (4/01/08), http://www.arb.ca.gov.aqs/aaqs2.pdf.
Attainment Status
The air quality management plans prepared by SJVAPCD provide the framework for SJVAB to achieve attainment of the state and federal AAQS through the SIP. Areas are classified as attainment or nonattainment areas for pollutants, depending on whether they meet the ambient air quality standards. Severity classifications for ozone nonattainment range in magnitude from marginal, moderate, and serious to severe and extreme.
At the federal level, the SJVAPCD is designated as extreme nonattainment for the 8 -hour ozone standard, attainment for PM 10 and CO, and nonattainment for PM 2.5. At the state level, the SJVAB is designated nonattainment for the 8-hour ozone, PM10, and PM2.5 standards. The SJVAB has not attained the federal 1-hour ozone, although this standard was revoked in 2005.
DISCUSSION
Would the project conflict with or obstruct implementation of the applicable air quality plan?
Less-Than-Significant Impact. Although the CEQA Guidelines indicate that a significant impact would occur if the Project were to conflict with or obstruct implementation of the applicable air quality plan, the SJVAPCDs 2015 Guide for Assessing and Mitigating Air Quality Impacts (GAMAQI) does not provide specific guidance on analyzing conformity with the plan. Thus, for purposes o f analyzing this potential impact, the AQ/GHG Report considered impacts based on: (1) whether the Project will result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations, or delay timely a ttainment of air quality 365
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23 standards; and (2) whether the Project will comply with applicable control measures in the air quality plan, primarily compliance with Regulation VIII – Fugitive PM10 Prohibitions and Rule 9510 – Indirect Source Review.
In general, regional air quality impacts and attainment of standards are the result of the cumulative impacts of all emission sources within the air basin. Thus, individual projects are generally not large enough to contribute measurably to an existing violation or air quality standards alone. Therefore, in order to analyze this threshold, and because of the region’s existing nonattainment status for several pollutants, the Project would be considered to cause significant impacts if it were to generate emissions tha t would exceed the SJVAPCD ’s significance thresholds. The District’s annual emission significance thresholds are as follows:
• 100 tons per year CO
• 10 tons per year NOx
• 10 tons per year ROG
• 27 tons per year Sox
• 15 tons per year PM10
• 15 tons per year PM2.5
Based on the AQ/GHG Report, the Project would not exceed these thresholds from construction and operation of the Project (As Shown in Table 4).2 Further, any impacts related to the construction activities of the Project, such as dust control, would be regulated through the SJVAPCD, which require measures such as frequent watering of the site during construction to minimize dust.
Table 4: CO, NOx, ROG, PM10, PM2.5 Thresholds, Maximum
Emission Source (Tons Per Year) CO NOx ROG
PM10
PM2.5
Highest Construction Emissions in Any Year (Unmitigated) 1.51 1.42 0.24 0.009 0.07 Operational Emissions at Buildout 0.43 0.07 0.11 0.10 0.03 Total Emissions 1.95 1.49 0.35 0.109 0.10
Significance Threshold 100 10 10 15 15
Exceed threshold – significant impact? No No No No No
Notes:
ROG = reactive organic gases
NOx = nitrogen oxides
PM10 and PM2.5 = particulate matter
Lastly, the SJVAPCD typically provides a comment letter indicating that the Project would be subject to compliance with the SJVAPCD Rule 9510 (Indirect Source Review), which is intended to mitigate a project’s impact on air quality through project design elements or by payment of in-lieu fees and Regulation VII (Fugitive PM10 Prohibitions), which requires a Construction Notification Form or approval of a Dust Control Plan prior to construction.
Consequently, compliance with SJVAPCD regulations would ensur e that the Project result in a less-than- significant impact and no mitigation measures are required.
Would the project r esult in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Less-Than-Significant Impact. See discussion under Section 3a above.
Would the project expose sensitive receptors to substantial pollutant concentrations?
2 Air Quality and Greenhouse Gas Analysis Report, Johnson Johnson and Miller Air Quality, starting on page 23, June 29, 2022. 366
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24 Less-Than-Significant Impact. Sensitive receptors are generally considered to include children, the elderly, and persons with pre -existing respiratory and cardiovascular illness. The SJVAPCD considers a sensitive receptor a location that houses or attracts children, the elderly, or people with illnesses. Examples of these receptors are hospitals, residences, schools and school facilities, and convalescent facilities. The nearest sensitive receptors to the Project site would be the existing residences adjace nt to the site to the north, south, and east , in addition to the church to the west . Based the AQ/GHG Report, the Project would not exceed emission thresholds that would result in a significant impact 3 based on compliance with SJVAPCD regulations and standards for construction and operation of this type of development. Therefore, a less-than-significant impact would occur.
Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Less-Than-Significant Impact. Generally, sources considered to emit odors are associated with wastewater treatment facilities, sanitary landfills, petroleum refineries, chemical manufacturing, and other industrial/manufacturing related uses. The Project wo uld include a multifamily residential complex thus, is unlikely to produce odors that would be considered to adversely affect a substantial number of people. Further, there are no major odor-generating sources within screening distance of the site. Although some odors would be emitted through the construction of the Project, such as diesel fuel and exhaust from construction equipment, these odors would be temporary in nature and last only during construction activities. Further, the types of uses allowed in the R-2 zone district such as a multifamily development are not generally considered to be odor - causing uses that would adversely affect a substantial number of people. Overall, a less-than-significant impact would occur.
4. BIOLOGICAL RESOURCES
Would the project:
Potentially
Significant
Impact
Less Than
Significant
With Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Have a substantial adverse effect,
either directly or through habitat
modifications, on any species
identified as a candidate,
sensitive, or special status
species in local or regional plans,
policies or regulations, or by the
California Department of Fish and
Game or U.S. Fish and Wildlife
Service?
X
3 Air Quality and Greenhouse Gas Analysis Report, Johnson Johnson and Miller Air Quality Consulting, starting on page 29, June 29, 2022. 367
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25 b. 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 California Department of
Fish and Game or US Fish and
Wildlife Service?
X
c. Have a substantial adverse effect
on state or federally protected
wetlands (including, but not
limited to, marsh, vernal pool,
coastal, etc.) through direct
removal, filling, hydrological
interruption, or other means?
X
d. 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?
X
e. Conflict with any local policies or
ordinances protecting biological
resources, such as a tree
preservation policy or ordinance?
X
f. Conflict with the provisions of an
adopted Habitat Conservation
Plan, Natural community
Conservation Plan, or other
approved local, regional, or state
habitat conservation plan?
X
ENVIRONMENTAL SETTING
A biological resources assessment (Biological Resources Assessment) was prepared by LSA. dated May 25, 2022 (see Appendix B). This Biological Resources Assessment included a literature review and records search to identify the existence and potential for occurrence of sensitive or special -status plant and animal species in the project vicinity. The site has been utilized as a single-family residence.
DISCUSSION
Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies or regulations, or by the California Depart ment of Fish and Game or U.S. Fish and Wildlife Service?
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26 Less-Than-Significant Impact With Mitigation. As described in the Biological Resources Assessment, the site was developed and is surrounded by substantial development. The site comprises of an existing single - family residence and no natural plant communities occur in the area of the Project site.4 No special-status wildlife species or diagnostic signs of special-status wildlife species were present on the Project site, and, according to the Biological Resources Assessment, the disturbed condition of the site would tend to preclude those species from occurring. Although no impacts to special -status species are expected, the Biological Resources Assessment concludes that there is a potentia l for the project to impact migratory bird s. In efforts to ensure protection of such species and waters, implementation of mitigation measure BIO -1 would ensure that a less- than-significant impact with mitigation occurs.
Mitigation Measure BIO -1: Nesting Bird Surveys and Active Nest Avoidance . Initial ground disturbance and vegetation removal should take place outside of the active nesting bird season (i.e., February 15-September 30), when feasible. Should project construction activities commence during this period, a qualified biologist should conduct a nesting bird survey prior to the onset of the work activities to ensure that birds are not engaged in active nesting within or immediately adjacent to the project site.
If nesting birds are discovered durin g preconstruction surveys, the biologist should identify an appropriate buffer (i.e., up to 500 feet depending on the circumstances and specific bird species) where no clearing, grading, or construction activities with potential to have direct or indirect impacts on the nesting birds are allowed to take place until after the birds have fledged from the nest, or the qualified biologist has determined that the nest is no longer active.
Would the project have a substantial adverse effect on any riparian habi tat or other sensitive natural community identified in local or regional plans, policies, or regulations or by the California Department of Fish and Game or US Fish and Wildlife Service?
Less-Than-Significant Impact. As mentioned previously, the Project site is characterized by agricultural and ornamental plants with some ruderal plant species scattered throughout. There are no riparian habitat s or sensitive natural communit ies identified at the site, nor are there any identified in local or regional plans .
Therefore, the Project would not result in a substantial adverse effect with respect to this threshold, and a less- than-significant impact would occur. No mitigation measures are required.
Would the project have a substantial adverse effect on state or federally protected wetlands as (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
No Impact. Based on the Biological Resources Evaluation prepared for the Project, no wetland features are known to exist at the Project site.
Would the project 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?
No Impact. The Biological Resources Evaluation did not identify the site as a regional or local wildlife movement corridors.5 Further, wildlife corridors typically serve as areas that wildlife traverse in order to migrate from one habitat to another and because the site is infill and surrounded by urban development, the site is unlikely to serve as any sort of wildlife corridor. Thus, no impact would occur, and no mitigation measures are required.
4 Biological Resources Evaluation prepared by LSA May 25, 2022, page 3. 5 Biological Resources Evaluation prepared by LSA, May 25, 2022, page 5. 369
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27 Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Less-Than-Significant Impact. The Project site does not indicate the presence of any sensitive habitat or wildlife features that would be significantly impacted. Although Policy 2.6 of the Open Space and Conservation Element of the 2014 General Plan calls for the protection of biological resources, the Biological Resources Evaluation did not identify any such resources at the site due to its location and being surrounded by urban development. Further, the Clovis Development Code does include tree protection standards for any trees that may need to be removed during construction. Compliance with the tree protec tion standards of the Clovis Municipal Code would require the replacement of trees and/or payment of in -lieu fees. Consequently, due to the lack of any identified sensitive species, and because the Project would be required to comply with the tree protection ordinance , the impact would be less-than-significant, and no mitigation measures would be required.
Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
No Impact. The Project site is not located within an adopted or approved Habitat Conservation Plan (HCP) or other conservation plan. However, the site is within the PG&E San Joaquin Valley Operation and Maintenance HCP, although the PG&E HCP applies only to PG&E construction and maintenance activities and does not apply to the site. Overall, no impact would occur, and no mitigation measures are required.
5. CULTURAL RESOURCES
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Cause a substantial adverse
change in the significance of a
historical resource pursuant to
§15064.5?
X
b. Cause a substantial adverse
change in the significance of
an archaeological resource
pursuant to §15064.5?
X
c. Disturb any human remains,
including those interred outside
of formal cemeteries? X
ENVIRONMENTAL SETTING
The Project site is located on a disturbed and developed site . The site has an existing single-family residence and is surrounded by existing residential developme nt as well as a church. A Cultural Resources Survey was prepared by LSA dated July 13, 2022 (See Appendix C ). The Cultural Resources Survey was based on information obtained at the Southern San Joaquin Valley Information Center, CSU Bakersfield, as well as review of other surveys conducted in the area. Based on the Cultural Resources Survey, no cultural resources have been identified within one-half mile of the Project Site.
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28 DISCUSSION
Would the project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
Less-Than-Significant Impact With Mitigation . As previously mentioned, the Project site is developed with an existing residence. A cultural resource records search was conducted within one-half mile of the Project. The search indicated that the subject property had never been surveyed for resources and it is not known if any exist on it. However, the Cultural Resources Survey concluded th at based on the results of the records search findings and lack of archeological resources previously identified within a one-half mile radius of the Project, the potential to encounter subsurface cultural resources is minimal. 6 Further, compliance with P olicy 2.9 of the General Plan, which calls for the preservation of historical sites and buildings of state or national significance, would ensure that if there were historical resources present, they would be protected. Because there is the slight possibility for the accidental or inadvertent uncovering of archaeological resources during construction, Mitigation Measure CULT-1 would serve to reduce those potential impacts by requiring the stopping of any work until any found artifacts can be properly remove d and inventoried by a qualified archaeologist. Therefore, regarding the Project causing a substantial adverse change in the significance of a historical resource the Project would result in a less-than-significant impact with mitigation.
Mitigation Measu re CULT -1: If prehistoric or historic -era cultural or archaeological materials are encountered during construction activities, all work in the immediate vicinity of the find shall halt until a qualified professional archaeologist, meeting the Secretary of the Interior’s Professional Qualification Standards for prehistoric and historic archaeologist, can evaluate the significance of the find and make recommendations. Cultural resource materials may include prehistoric resources such as flaked and ground stone tools and debris, shell, bone, ceramics, and fire-affected rock as well as historic resources such as glass, metal, wood, brick, or structural remnants.
If the qualified professional archaeologist determines that the discovery represents a potentially significant cultural resource, additional investigations may be required to mitigate adverse impacts from project implementation. These additional studies may include avoidance, testing, and evaluation or data recovery excavation.
If a potentially eligible resource is encountered, then the qualified professional archaeologist, the Lead Agency, and the project proponent shall arrange for either 1) total avoidance of the resource or 2) test excavations to evaluate eligibility and, if eligible, total data recovery. The determination shall be formally documented in writing and submitted to the Lead Agency as verification that the provisions for managing unanticipated discoveries have been met.
Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
Less-Than-Significant Impact With Mitigation. The site is developed with an existing residence and is surrounded by existing urban development. The site’s ground has been previously disturbed as a result of the agriculture, and residential uses and other ground disturbing activities throughout the years. Nevertheless, the potential remains that archeological resources could be inadvertently or accidentally uncovered during ground- disturbing activities such as trenching, digging, and the installation of utilities and other infrastructure.
6 Cultural Resources Technical Memorandum by LSA, July 13, 2022, page 2. 371
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29 Because there is the slight possibility for the accidental or inadvertent uncovering of archaeological resources during construction, Mitigation Measure CULT-1 would serve to reduce those potential impacts by requiring the stopping of any work until any found artifacts can be properly removed and inventoried by a qualified archaeologist. Therefore, the Project would result in a less-than-significant impact with mitigation.
Would the project disturb any human remains, including those interred outside of formal cemeteries?
Less-Than-Significant Impact With Mitigation. The site is developed with an existing residence and is surrounded by existing urban developed. The site’s ground has been previously disturbed as a result of the agriculture, and residential uses and other ground disturbing activities throughout the years. Nevertheless, the potential remains that human remains could be inadvertently or accidentally uncovered during ground-disturbing activities such as trenching, digging, and the installation of utilities and other infrastructure.
Because there is the slight possibility for the accidental or inadvertent uncovering of human remains during construction, Mitigation Measure CU LT-2 would serve to reduce those potential impacts by requiring the stopping of any work until any found human remains can be properly removed by the County coroner and/or tribes. Therefore, the Project would result in a less-than-significant impact with mitigation.
Mitigation Measure CULT -2: If human remains are discovered during construction or operational activities, further excavation or disturbance shall be prohibited pursuant to Section 7050.5 of the California Health and Safety Code. The specific protocol, guidelines, and channels of communication outlined by the Native American Heritage Commission, in accordance with Section 7050.5 of the Health and Safety Code, Section 5097.98 of the Public Resources Code ( Chapter 1492, Statutes of 1982, Senate Bill 297), and Senate Bill 447 (Chapter 44, Statutes of 1987), shall be followed. Section 7050.5(c) shall guide the potential Native American involvement, in the event of discovery of human remains, at the direction o f the County coroner. All reports, correspondence, and determinations regarding the discovery of human remains on the project site shall be submitted to the Lead Agency.
6. ENERGY
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Result in a potentially significant
environmental impact due to
wasteful, inefficient, or
unnecessary consumption of
energy resources, during project
construction or operation?
X
b. Conflict with or obstruct a state or
local plan for renewable energy or
energy efficiency? X
ENVIRONMENTAL SETTING
The Project is located on an infill site surrounded by existing urban uses, primarily residential and educational.
DISCUSSION
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30 Would the project result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Less-Than-Significant Impact. The Project proposes the construction of a multifamily residential complex.
Construction of such structures would require site preparation, grading, paving, architectural coating, and trenching. Construction would consist of typical activities for construction projects and therefore would not require use of new resources. While such activities would consume petroleum-based fuels, such consumption would be temporary and conclude upon completion of construction. The p roposed Project in operation would be served by Pacific Gas & Electric (PG&E) and would not require extensions of energy infrastructure or new energy supplies. As previously mentioned, the Project is located on an infill site surrounded by existing urban uses. Sources of operational energy consumption would include natural gas and/or electricity for space and water heating and transportation fuels (i.e., gasoline and diesel) for vehicle trips. Further, t he multifamily use would be subject to compliance with the latest energy efficiency standards in effect at the time of development and operation. This would include compliance with Title 24 Green Building Standards for energy efficiency, as well as be required to comply with the latest water efficient landsca pe policy regulations. Further, the Project would be required to comply with Clovis General Plan Policy 3.4, and 3.7 of the Open Space and Conservation, which call for the use of water conserving and drought tolerant landscape, as well as energy efficient buildings.
Conformance to these standards would be reviewed during the City’s site plan review process and during review of building plans.
Consequently, compliance with these measures would ensure that the Project does not result in a significant impact due to the unnecessary consumption of energy and less-than-significant impact would occur.
Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Less-Than-Significant Impact. See discussion under Section 6a above.
7. GEOLOGY AND SOILS
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Directly or indirectly cause potential
substantial adverse effects, including
the risk of loss, injury, or death
involving:
i) Rupture of a known earthquake
fault, as delineated on the most
recent Alquist-Priolo Earthquake
Fault Zoning Map issued by the
State Geologist for the area or based
on other substantial evidence of a
known fault?
X
ii) Strong seismic ground shaking? X
iii) Seismic-related ground failure,
including liquefaction? X
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31 iv) Landslides? X
b. Result in substantial soil erosion or
the loss of topsoil? X
c. 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?
X
d. 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?
X
e. Have soils incapable of adequately
supporting the use of septic tanks or
alternative waste disposal systems
where sewers are not available for
the disposal of wastewater?
X
f. Directly or indirectly destroy a unique
paleontological resource or unique
geologic feature? X
ENVIRONMENTAL SETTING
The 2014 Clovis General Plan EIR identified no geologic hazards or unstable soil conditions known to exist on the Project site. Although Figure 5.6-2 of the Geology and Soils Chapter of the General Plan EIR does show a fault, the fault is located several miles east of the Project site.
DISCUSSION
Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault?; ii) Strong seismic ground shaking?; iii) Seismic -related ground failure, including liquefaction?; iv) Landslides?
Less-Than-Significant Impact. Although the Project site does not have any known faults on the site, the potential remains that seismic ground-shaking could occur from the fault located east of the Project. However, adherence to the most current California Building Codes would ensure that the structures are constructed safely and in compliance with the appropriate Building Codes. With regards to liquefaction, the 2014 General Plan EIR states that the soil types in the area are not considered conducive to liquefaction due to their high clay content or from being to coarse.7 Further, the site is generally flat and therefore landslides would not occur at the Project site. Overall, due to the location away from a known fault, adherence to the most recent Californ ia Building
7 2014 Clovis General Plan EIR, Chapter 5: Geology and Soils, page 5.6-3. 374
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32 Codes, and the flat topography, a less-than-significant impact would occur with regards to potential impacts from seismic activity.
Would the project result in substantial soil erosion or the loss of topsoil?
Less-Than-Significant Impact. The topography of the Project site is relatively flat with little to no slope.
Development of the site would require grading and construction activities to ensure a flat and graded surface prior to construction. Such activitie s may result in the soil erosion and loss of topsoil. Such impacts would be addressed by applicable regulations set forth by the Regional Water Quality Control Board (RWQCB) including preparation of a Stormwater Pollution Prevention Plan (SWPPP) by a certified Qualified SWPPP Developer per the General Construction Permit requirements of the National Pollutant Discharge Elimination System (NPDES).
The SWPPP incorporates Best Management Practices for erosion and sediment controls and soil stabilization.
Further, as part of the Project, grading plans are required to be submitted and approved by the City Engineer Division to ensure appropriate grading of the site. Thus, th ese review and approval process es would ensure that a less-than-significant impact occur, and no mitigation measures are required.
Would the project 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?
Less-Than-Significant Impact. See discussion under Section 7a.
Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating direct or indirect substantial risks to life or property?
No Impact. According to the 2014 Clovis General Plan EIR, expansive soils are mostly present in areas along the northern edge of the non -Sphere of Influence (SOI) and the easternmost part of the Clovis non -SOI plan area. Because the Project is not within the vicinity of these areas, there would be no potential for creating direct or indirect substantial risks to life or property with regards to expansive soils. As a result, no impact would occur, and no mitigation measures are required.
Would the project have soils incapable of adequately supporting the use of septic tanks or alternative waste disposal systems where sewers are not available for the disposal of wastewater?
No Impact. The Project does not propose the use of septic tanks; therefore, no impact would occur.
Would the project directly or indirectly destroy a unique paleontological resource or unique geologic feature?
Less-Than-Significant Impact With Mitigation. The Project site has been previously disturbed, as well as the immediately surrounding areas with no known occurrences of the discovery of paleontological resources. In addition, the Cultural Resources Survey concluded that the potential for uncovering of archaeological or subsurface historical deposits (i.e. paleontological resources) is unlikely. Nevertheless, the possibility remains that the inadvertent or accidental discovery could occur during ground disturbing construction activities.
However, Mitigation Measure GEO-1, below, would serve to protect the accidental discovery of paleontological resources. As such, a less-than-significant with mitigation impact would occur.
Mitigation Measure GEO -1: If prehistoric or historic -era cultural materials are encountered during construction activities, all work in the immediate vicinity of the find shall halt until a qualified professional archaeologist and/or paleontologist, meeting the Secretary of the I nterior’s Professional Qualification Standards for prehistoric and historic archaeologist, can evaluate the significance of the find and make 375
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33 recommendations. Cultural resource materials may include prehistoric resources such as flaked and ground stone tools and debris, shell, bone, ceramics, and fire-affected rock as well as historic resources such as glass, metal, wood, brick, or structural remnants.
If the qualified professional determines that the discovery represents a potentially significant cultural resource, additional investigations may be required to mitigate adverse impacts from project implementation. These additional studies may include avoidance, testing, and evaluation or data recovery excavation.
If a potentially -eligible resource is encount ered, then the qualified professional archaeologist and/or paleontologist, the Lead Agency, and the project proponent shall arrange for either 1) total avoidance of the resource or 2) test excavations to evaluate eligibility and, if eligible, total data re covery. The determination shall be formally documented in writing and submitted to the Lead Agency as verification that the provisions for managing unanticipated discoveries have been met.
8. GREENHOUSE GAS EMISSIONS
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Generate greenhouse gas
emissions, either directly or
indirectly, that may have a
significant impact on the
environment?
X
b. Conflict with any applicable plan,
policy or regulation of an agency
adopted for the purpose of
reducing the emissions of
greenhouse gases?
X
ENVIRONMENTAL SETTING
Gases that trap heat in the atmosphere are referred to as greenhouse gases (GHGs) becau se they capture heat radiated from the sun as it is reflected into the atmosphere, much like a greenhouse does. The accumulation of GHG’s has been implicated as a driving force for global climate change. Definitions of climate change vary between and acr oss regulatory authorities and the scientific community, but in general can be described as the changing of the earth’s climate caused by natural fluctuations and anthropogenic activities which alter the composition of the global atmosphere.
Individual projects contribute to the cumulative effects of climate change by emitting GHGs during construction and operational phases. The principal GHGs are carbon dioxide, methane, nitrous oxide, ozone, and water vapor. While the presence of the primary GHGs in t he atmosphere are naturally occurring, carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O) are largely emitted from human activities, accelerating the rate at which these compounds occur within earth’s atmosphere. Carbon dioxide is the “reference gas” for climate change, meaning that emissions of GHGs are typically reported in “carbon dioxide -equivalent” measures.
Emissions of carbon dioxide are largely by -products of fossil fuel combustion, whereas methane results from off-gassing associated with agricultural practices and landfills. Other GHGs, with much greater heat-absorption 376
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34 potential than carbon dioxide, include hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride, and are generated in certain industrial processes.
There is intern ational scientific consensus that human -caused increases in GHGs have and will continue to contribute to global warming, although there is uncertainty concerning the magnitude and rate of the warming.
Potential global warming impacts in California may inc lude, but are not limited to, loss in snowpack, sea level rise, more extreme heat days per year, more high ozone days, more large forest fires, and more drought years.
Secondary effects are likely to include a global rise in sea level, impacts to agriculture, changes in disease vectors, and changes in habitat and biodiversity.
In 2005, in recognition of California’s vulnerability to the effects of climate change, Governor Schwarzenegger established Executive Order S -3-05, which sets forth a series of target dates by which statewide emission of greenhouse gases (GHG) would be progressively reduced, as follows: by 2010, reduce GHG emissions to 2000 levels; by 2020, reduce GHG emissions to 1990 levels; and by 2050, reduce GHG emissions to 80 per cent below 1990 levels. In 2006, California passed the California Global Warming Solutions Act of 2006 (AB 32), which requires the California Air Resources Board (CARB) to design and implement emission limits, regulations, and other measures, such that feasible and cost-effective statewide GHG emissions are reduced to 1990 levels by 2020 (representing a 25 percent reduction in emissions).
In April 2009, the California Office of Planning and Research published proposed revisions to the California Environmental Quality Act to address GHG emissions. The amendments to CEQA indicate the following:
• Climate action plans and other greenhouse gas reduction plans can be used to determine whether a project has significant impacts, based upon its compliance with the plan.
• Local governments are encouraged to quantify the greenhouse gas emissions of proposed projects, noting that they have the freedom to select the models and methodologies that best meet their needs and circumstances. The section also recommends consi deration of several qualitative factors that may be used in the determination of significance, such as the extent to which the given project complies with state, regional, or local GHG reduction plans and policies.
OPR does not set or dictate specific thre sholds of significance. Consistent with existing CEQA Guidelines, OPR encourages local governments to develop and publish their own thresholds of significance for GHG impacts assessment.
• When creating their own thresholds of significance, local governments may consider the thresholds of significance adopted or recommended by other public agencies or recommended by experts.
• New amendments include guidelines for determining methods to mitigate the effects of greenhouse gas emissions in Appendix F of the CEQA Guidelines. • OPR is clear to state that “to qualify as mitigation, specific measures from an existing plan must be identified and incorporated into the project; general compliance with a plan, by itself, is not mitigation.”
• OPR’s emphasizes the advantages of analyzing GHG impacts on an institutional, programmatic level. OPR therefore approves tiering of environmental analyses and highlights some benefits of such an approach.
• Environmental impact reports (EIRs) must specifically consider a project's energy us e and energy efficiency potential.
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35 On December 30, 2009, the Natural Resources Agency adopted the proposed amendments to the CEQA Guidelines in the California Code of Regulations.
In December 2009, the San Joaquin Valley Air Pollution Control District (SJ VAPCD) adopted guidance for addressing GHG impacts in its Guidance for Valley Land Use Agencies in Addressing GHG Impacts for New Projects Under CEQA. The guidance relies on performance -based standards, otherwise known as Best Performance Standards (BPS), to assess significance of project -specific GHG emissions on global climate change during the environmental review process.
Projects can reduce their GHG emission impacts to a less than significant level by implementing BPS. Projects can also demonstrate compliance with the requirements of AB 32 by demonstrating that their emissions achieve a 29% reduction below “business as usual” (BAU) levels. BAU is a projected GHG emissions inventory assuming no change in existing business practices and without conside ring implementation of any GHG emission reduction measures.
Significance Criteria
The SJVAPCDs Guidance for Valley Land Use Agencies in Addressing GHG Impacts for New Projects Under CEQA provides initial screening criteria for climate change analyses, as well as draft guidance for the determination of significance.
The effects of project specific GHG emissions are cumulative, and therefore climate change impacts are addressed as a cumulative, rather than a direct, impact. The guidance for determining sign ificance of impacts has been developed from the requirements of AB 32. The guideline addresses the potential cumulative impacts that a project’s GHG emissions could have on climate change.
Since climate change is a global phenomenon, no direct impact woul d be identified for an individual land development project. The following criteria are used to evaluate whether a project would result in a significant impact for climate change impacts:
• Does the project comply with an adopted statewide, regional, or local plan for reduction or mitigation of GHG emissions? If no, then
• Does the project achieve 29% GHG reductions by using approved Best Performance Standards? If no, then
• Does the project achieve AB 32 targeted 29% GHG emission reductions compared with BAU? Projects that meet one of these guidelines would have less than significant impact on the global climate.
Because BPS have not yet been adopted and identified for specific development projects, and because neither the ARB nor the City of Cl ovis has not yet adopted a plan for reduction of GHG with which the Project can demonstrate compliance, the goal of 29% below BAU for emissions of GHG has been used as a threshold of significance for this analysis.
DISCUSSION
Would the project generate g reenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Less-Than-Significant Impact. The Project would include the construction of a multifamily residential complex.
As such, GHG emissions would be produced through the construction and operational phases of the Project .
However, the SJVAPCD includes regulations to reduce GHG emissions such as standards for medium and 378
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36 heavy-duty engines and vehicles (i.e. tractors and construction equipment) that woul d apply to buildout of the Project. Further, compliance with Title 24 energy efficient building codes would apply, which also help to reduce GHG emissions during operation of the Project, by requiring minimum standards for insulation, energy efficiency, and window glazing, etc., which serve to maximize efficiency of new construction. Further, the Project would comply with the latest water efficient landscape standards which help to reduce energy usage. Overall, the AQ/GHG Report concluded that the Project, with implementation of required energy efficient standards, would sufficiently reduce emissions versus business as usual scenarios and would exceed the minimum percentage reduction of emissions required by the State, SJVAPCD, and the Clo vis General Plan EI R. In particular, the AQ/GHG Report found that the Project would achieve a reduction of 3 2.4% from BAU by 2024 and 4 1.1% by 2030 with regulations and design features incorporated. Therefore, a less-than-significant impact would occur.
Would the project c onflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases?
Less-Than-Significant Impact. Based on the AQ/GHG Report,8 the Project would include several features that would mi nimize GHG emissions, which are consistent with project -level strategies identified by the Air Resources Board Scoping Plan and the Clovis General Plan. Further, although the SJVAPCD has adopted a Climate Action Plan, it does not contain measures that are applicable to development projects. Since there are no other local or regional climate action plans, the Project was assessed for consistency with the Air Resources Board (ARBs) adopted scoping plans.
As indicated in the discussion above under Section 8a, the Project would result in GHG reductions that meet or exceed minimum targets by complying with the latest energy efficient standards, and water conservation.
Consequently, the AQ/GHG Report found this potential impact to be less than significant.
9. HAZARDS AND HAZARDOUS MATERIALS
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Create a significant hazard to the
public or the environment through the
routine transport, use, or disposal of
hazardous materials?
X
b. 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?
X
c. Emit hazardous emissions or handle
hazardous or acutely hazardous
materials, substances, or waste within
X
8 Air Quality and Greenhouse Gas Analysis Report, Johnson Johnson and Millar Aire Quality Consulting, page 48, June 29, 2022 379
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37 one-quarter mile of an existing or
proposed school?
d. Be located on a site which is included
on a list of hazardous materials sites
compiled pursuant to Government
Code Section 65962.5 and, as a
result, would it create a significant
hazard to the public or the
environment?
X
e. For a project located within an airport
land use plan or, where such a plan
has not been adopted, within two
miles of a public airport or public use
airport, would the project result in a
safety hazard or excessive noise for
people residing or working in the
project area?
X
f. Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency
evacuation plan?
X
g. Expose people or structures, either
directly or indirectly, to a significant
risk of loss, injury or death involving
wildland fires?
X
ENVIRONMENTAL SETTING
For purposes of this chapter, the term “hazardous materials” refers to both hazardous substances and hazardous wastes. A “hazardous material” is defined in the Code of Federal Regulations (CFR) as “substance or material that is capable of posing an unreasonable risk to health, safety, and property when transported in commerce” (49 CFR 171.8). California Health and Safety Code Section 25501 defines a hazardous material as follows:
“Hazardous material” means any material that, because of its quantity, concentration, or physical, or chemical characteristics, poses a significant present or potential hazard to human health and safety or to the environment if released into the workplace or the environment. “Hazardous materials” include, but are not limited to, hazardous substances, hazardous waste, and any material which a handler or the administering agency has a reasonable basis for believing that it w ould be injurious to the health and safety of persons or harmful to the environment if released into the workplace or the environment. “Hazardous wastes” are defined in California Health and Safety Code Section 25141(b) as wastes that:
…because of their q uantity, concentration, or physical, chemical, or infectious characteristics, [may either] cause or significantly contribute to an increase in mortality or an increase in serious illness, or pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.
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38 The nearest school to the Project site is Century Elementary School, located approximately 800 feet north of the Project site.
DISCUSSION
Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Less-Than-Significant Impact. The Project consists of the construction of an multifamily residential complex under the proposed R-2 zone district. The type of hazardous materials that would be associated with the Project are those typical of multifamily residential uses, such as the use of cleaners, landscape maintenance products, soaps, and potential pesticides (for pest control). It is not expected that the Project would routinely transport, use, or dispose of hazardous materials other than those typical of those associated with residential uses .
However, if transported, handled, and disposes of in accordance with regulations, these materials are not generally considered of the type or quantity that would pose a significant hazard to the public when used as directed. During construction, typical equipment and materials would be used that are associat ed with residential/commercial construction; however, any chemicals or materials would be handled, stored, disposed of, and/or transported according to applicable laws. Consequently, because the Project is not of the type of use that would routinely transp ort, use, or dispose of hazardous materials a less-than-significant impact would occur.
Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of h azardous materials into the environment?
Less-Than-Significant Impact. See discussion above under Section 9a.
Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?
Less-Than-Significant Impact. As previously discussed, the Project site is near Century Elementary School.
However, the Project is not of the type of use typically associated with emitting hazardous emissions or handling the type or quantity of hazardous materials such that it would pose a risk or threat to the school, or surrounding area. Therefore, a less-than-significant impact would occur.
Would the project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
No Impact. According the California Department of Toxic Substance Control EnviroStor Database, the Project site is not located on or within the immediate vicinity of a hazardous materials site.9 Therefore, no impact would occur.
For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?
9 California Department of Toxic Substance Control, EnviroS tor Database, https://www.envirostor.dtsc.ca.gov/public/map/?global_id=71003467, accessed on February 22, 2021.
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39 No Impact. The Project is located approximately five (5) miles northeast of the Fresno Yosemite International Airport and is not within the Airport Influence Area, safety zones, noise, or airspace and overflight areas .
Therefore, no impact would occur.
Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Less-Than-Significant Impact. The Project is located at a site that is surrounded by existing development.
Further, the road network is already in place from previous development. Although the Project could result in temporary traffic detouring or closures during buildout, these delays would be temporary and would be coordinated with the City engineering department and other departments to ensure safe access to and from the area is maintained. Further, the site itself would be reviewed by City departments to ensure adequate site access and circulation is provided in the event of an emergency. Overall, a less-than-significant impact would occur.
Expose people or structures , either directly or ind irectly, to a significant risk of loss, injury or death involving wildland fires?
Less-Than-Significant Impact. The site is an infill site surrounded by urban uses. Therefore, it is not in a location typically associated with wildfires. Although urban fir es could occur, the Project would be constructed to the latest fire code standards, which would include fire sprinklers in each unit, as well as the installation of several fire hydrants throughout the site as required by the Clovis Fire Department. Furthe r, other life safety features would be required such as smoke detectors, which would be reviewed and checked by the Fire Department to ensure proper operation prior to occupancy. Ultimately, a less-than-significant impact would occur.
10. HYDROLOGY AND WATER QUALITY
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Violate any water quality standards or
waste discharge requirements or
otherwise substantially degrade surface
or ground water quality?
X
b. Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the
project may impede sustainable
groundwater management of the basin?
X
c. Substantially alter the existing drainage
pattern of the site or 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: (i) result in substantial erosion or
siltation on- or off-site; (ii) substantially
increase the rate or amount of surface
runoff in a manner which would result in
X
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40 flooding on- or offsite; (iii) 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; or (iv) impede or
redirect flood flows?
i) Result in substantial erosion or
siltation on- or off-site? X
ii) Substantially increase the rate or
amount of surface runoff in a manner
which would result in flooding on- or
offsite?
X
iii) 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?
X
iv) Impede or redirect flood flows? X
d. In flood hazard, tsunami, or seiche
zones, risk release of pollutants due to
project inundation? X
e. Conflict with or obstruct implementation
of a water quality control plan or
sustainable groundwater management
plan?
X
ENVIRONMENTAL SETTING
The Plan Area is within the drainages of three streams: Dry Creek, Dog Creek, and Redbank Slough. On the north, Dry Creek discharges into the Herndon Canal in the City of Fresno west of Clovis. South of Dry Creek, Dog Creek is a tributary of Redbank Slough , which discharges into Mill Ditch south of Clovis (USGS 2012). A network of storm drains in the City and the Plan Area discharges into 31 retention basins, most of which provide drainage for a one - to two-square-mile area. Most of the Plan Area east and n ortheast of the City is not in drainage areas served by retention basins. Those areas drain to streams that discharge into reservoirs, including Big Dry Creek Reservoir in the north -central part of the Plan Area and Redbank Creek Dam and Reservoir in the southeast part of the Plan Area. Fancher Creek Dam and Reservoir are near the east Plan Area boundary.
The Project is located within the Fresno Metropolitan Flood Control District (FMFCD) boundary, and subject to its standards and regulations. Detention and retention basins in the FMFCD’s flood control system are sized to accommodate stormwater from each basin’s drainage area in built out condition. The current capacity standard for FMFCD basins is to contain runoff from six inches of rainfall during a ten -day period and to infiltrate about 75 to 80 percent of annual rainfall into the groundwater basin (Rourke 2014). Basins are highly effective at reducing average concentrations of a broad range of contaminants, including several polyaromatic hydrocarbons, total suspended solids, and most metals (FMFCD 2013). Pollutants are removed by filtration 383
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41 through soil, and thus don’t reach the groundwater aquifer (FMFCD 2014). Basins are built to design criteria exceeding statewide Standard Urban Stormwater Mitigation Plan (SUSMP) standards (FMFCD 2013). The urban flood control system provides treatment for all types of development —not just the specific categories of development defined in a SUSMP —thus providing greater water quality protection for surface water and groundwater than does a SUSMP.
In addition to their flood control and water quality functions, many FMFCD basins are used for groundwater recharge with imported surface water during the dry season through contracts with the Fresno Irrigation District (FID) and the cities of Fresno and Clovis; such recharge totaled 29,575 acre feet during calendar year 2012 (FMFCD 2013).
The pipeline collection system in the urban flood control system is designed to convey the peak flow rate from a two-year storm.
Most drainage areas in the urban flood control system do not discharge to other water bodies and drain mostly through infiltration into groundwater. When necessary, FMFCD can move water from a basin in one such drainage area to a second such basin by pumping water into a street and letting water flow in curb and gutter to a storm drain inlet in an adjoining drainage area (Rourke 2014). Two FMFCD drainage areas discharge directly to the San Joaquin River, and three to an irrigation canal, without storage in a basin. Six drainage areas containing basins discharge to the San Joaquin River, and another 39 basins discharge to canals (FMFCD 2013).
A proposed development that would construct more impervious area on its project site than the affected detention/retention basin is sized to accommodate is required to infiltrate some stormwater onsite, such as through an onsite detention basin or drainage swales (Rourke 2014).
The Big Dry Creek Reservoir has a total storage capacity of about 30 thousand acre -feet (taf) and controls up to 230-year flood flows. Fancher Creek Dam and Reservoir hold up to 9.7 taf and controls up to 200-year flood flows. Redbank Creek Dam and Reservoir hold up to 1 taf and controls up to 200-year flood flows.
Groundwater
In 2014, the Sustainable Gro undwater Management Act (SGMA) was signed into law which created the framework for groundwater management within California. As a result, SGMA requires governments and water agencies of high and medium priority basins to halt groundwater overdraft and brin g the groundwater basins back to a balance.
The City of Clovis is within the greater Kings Groundwater Sub basin, which is managed by the North Kings Groundwater Sustainability Agency for the area which the City is located and is considered critically over drafted.
The Kings Basin is a sub basin to the southern part of the San Joaquin Valley Basin and covers 1,530 square miles. Groundwater within the basin is monitored by the City, Fresno Irrigation District (FID), and the Kings River Conservation District.
The City of Clovis provides water through a combination of surface and groundwater sources, including averaging over 20,000 acre-feet per year from the Kings River, as well as several City-managed wells. In 2015, the City delivered approximately 20,030 acre-feet of water to its residents.
Lastly, a Water Infrastructure Investigation was completed by Provost and Pritchard on June 27, 2022 . The investigation was into the water system infrastructure required to serve the proposed development. Information from this investigation is used for the analysis in the Hydrology and Water Quality and Utilities and Service Systems sections of this Initial Study.
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42 DISCUSSION
Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
Less-Than-Significant Impact. The Project is located on a site that was previously anticipated for suburban development that the Project proposes. As with any development, existing policies and standards are required to be complied with, which are assessed during review of the entitlements. As such, the engineering department, as well as outside agencies such as the Fresno Metropolitan Flood Control District (FMFCD) review all plans to ensure that none of the water quality standards are violated and that waste discharge requirements are adhered to during construction and operation of the Project. Consequently, this process of Project review and approval would ensure that a less-than-significant impact occur.
Would the project substantially de crease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundw ater management of the basin?
Less-Than-Significant Impact. The Project would not deplete groundwater supplies or interfere with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table lev el due to the Project. The General Plan EIR identified a net decrease in ground water aquifer throughout the region, however, because the City’s domestic water system is primarily served through surface water via existing water entitlements, the loss of aquifer is less than significant.
The City has developed a surface water treatment plant (opened in June 2004) that reduces the need for pumped groundwater and has also expanded the municipal groundwater recharge facility. In addition , a ll landscaping shall be subject to MWELO requirements, which mandate drought tolerant and low water use landscaping. Further, the Water Infrastructure Investigation for the Project determined that the existing and planned water distribution system and recommended connections should be adequate to convey water supply to the Project to support anticipated demands from the Project. For these reasons, t he Project’s impacts to groundwater are less than significant.
Would the project substantially alter the existing drainage patt ern of the site or area, including through the alteration of the course of a stream or river, in a manner which would: (i) result in substantial erosion or siltation on - or off-site; (ii) substantially increase the rate or amount of surface runoff in a man ner which would result in flooding on - or offsite; (iii) 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; or (iv) impede or redirect flood flows?
Less-Than-Significant Impact. The Project site is located on an infill site that is generally flat and surrounded by existing urban uses. There are no streams or rivers on the site that would be altered as a result of the Project..
The infrastructure surrounding the site, such as storm drains are already in place from existing development.
The drainage pattern would be constructed per existing policies and regulations through review of the plans by the City engineering department and the FMFCD to ensure the site is properly and adequate ly drained such that the storm drain system is maintained and so that no flooding occurs. FMCD has reviewed the Project and there are existing facilities to serve the site subject to compliance with conditions of approval that would be required as part of the Project entitlements . Consequently, this review and approval by City engineers and FMFCD would mean that the Project result in a less-than-significant impact.
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43 Would the project, in flood hazard, tsunami, or seiche zones, risk release of pollutants d ue to project inundation?
Less-Than-Significant Impact. The Project site is located on an infill site substantially surrounded by existing urban uses. Due to the Central Valley’s location away from the ocean, an impact from a tsunami is unlikely.
However, the Project site is designated as a Federal Emergency Management Agency (FEMA) Flood Zone “X” which is considered by FEMA as a non-special flood hazard area and that the risk of a flood is low risk. A Flood Zone X has a 0.2 percent -annual-chance of flood (or a 500-year flood). Consequently, this is a low -risk area and as a result a less-than-significant impact would occur.
Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Less-Than-Significant Impact. The City of Clovis is within the North Kings County Groundwater Sustainability Agency (GSA). Pursuant to the Sustainable Groundwater Management Act of 2014 (SGMA), certain regions in California are required to develop and implement a groundwater management plan that sustainably manages groundwater resources. The North Kings County GSA adopted a groundwater management plan in 2019.
Although the groundwater sub basin which Clovis lies within is considered over drafted, the Project would derive its water from surface water sources and does not propose or include plans for groundwater use. With regards to water quality control, the Project would be required to adhere to appropriate storm drain conveyance and the protection of water resources which would include the installation of backflow preventers.
Further, the Water Infrastructure Investigation for the Project determined that the existing and planned water distribution system and recommended connections should be adequate to convey water supply to the Project to support anticipated demands from the Project. Consequently, the Project would result in a less-than- significant impact.
11. LAND USE AND PLANNING
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Physically divide an existing
community?
X
b. Cause a significant environmental
impact due to a conflict with any
land use plan, policy, or regulation
adopted for the purpose of avoiding
or mitigating an environmental
effect?
X
ENVIRONMENTAL SETTING
As described above in the Project Description, the Project site is considered an in-fill site in that the surrounding areas are urbanized. There are existing single-family residential uses to the north, east, and south, as well as a church to the west.
DISCUSSION
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44 Would the project physically divide an existing community?
Less-Than-Significant Impact. The site is developed and is within a general area that is urbanized with a mix of existing uses and land use types. Typically, physically dividing existing communities is associated with the construction of a new road intersecting an established area or intro ducing uses that are not necessarily in line with the existing uses and planned land uses of the area. The Project site is adjacent to Alluvial Avenue and between a church site and existing single-family residences. As a residential use, the Project is inl ine with the surrounding area. Therefore, a less-than-significant impact would occur, and no mitigation measures are required.
Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Less-Than-Significant Impact. The proposed use requires the amendment to the City’s General Plan Land Use Diagram from the existing Low Density Residential designation to Medium High Density Residential. The proposed rezone request to the R-2 zone district is consistent with the proposed Medium Hig h Density Residential designation. Further, through the entitlement process, the Project is reviewed for compliance with applicable regulations, including those intended for avoiding or mitigating an environmental effect. For example, the Project would be required to comply applicable lighting, landscape, and noise standards, which are regulated through the Clovis Municipal Code to ensure minimal impacts to the environment as well as with neighboring properties. Overall, with the review process ensuring General Plan and other applicable policies will be adhered to, the Project would result in a less-than-significant impact with regards to conflicting with a land use plan.
12. MINERAL RESOURCES
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Result in the loss of availability of
a known mineral resource that
would be of value to the region
and the residents of the state?
X
b. 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?
X
ENVIRONMENTAL SETTING
The City of Clovis 2014 General Plan EIR defines minerals as any naturally occurring chemical elements or compounds formed from inorganic processes and organic substances.10 The 2014 General Plan EIR indicates that there are no active mines or inactive mines within the Plan Area of the City of Clovis.
10 2014 Clovis General Plan EIR, Chapter 5: Mineral Resources, page 5.11-1. 387
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45 DISCUSSION
Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
No Impact. As stated above, the City of Clovis does not have any active mines or inactive mines. Further, the Project site is an infill site within the City and is not zoned, designated, or otherwise mapped for mineral resource extraction, or for having mineral resources of value to the region present on or below the surface of the site.
Therefore, no impact would occur, and no mitigation measures are required.
Would the project r esult 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?
No Impact. Please refer to the discussion under Section 12.a.
13. NOISE
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. 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?
X
b. Generation of excessive groundborne
vibration or groundborne noise levels? X
c. For a project located within the vicinity
of a private airstrip or an airport land
use plan or, where such a plan has
not been adopted, within two miles of
a public airport or public use airport,
would the project expose people
residing or working in the project area
to excessive noise levels?
X
ENVIRONMENTAL SETTING
As mentioned above in the Project Description, the site is located on the north side of Alluvial Avenue and east of Sunnyside Avenue. In general, the Project site is within an urbanized area of the City surrounded by existing residential to the north, east, and south, as well as a church to the west of the site. As such, existing ambient noise levels are typical of noises from these types of developments (i.e., schools, roadway networks, and residential).
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46 DISCUSSION
Would the project 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?
Less-Than Significant Impact. The Project would include the redevelopment of a site within Clovis. The Project would result in a temporary and permanent increase in ambient noise levels as a result. However, as mentioned above, the Project site is infill and is already surrounded by existing residential development and church uses.
Therefore, while the Project would introduce new ambient noise from the construction of the multifamily complex, it is likely that the Project would still meet City noise standards.
Further, the City of Clovis Municipal Code Section 9.22.080, Noise, sets forth noise standards for development which would need to be complied with. For example, construction would only be permitted between the hours of 7:00 a.m. and 7:00 p.m. on weekdays, and between 9 a.m. and 5:00 p.m. on weekends. However, between June 1 and September 15, construction may begin at 6 a.m. on weekdays.
Consequently, because the Project site is considered infill, already surrounded by similar uses, and because construction noise would be temporary in nature, the potential for a substantial increase in ambient or temporary noise increases is considered less-than-significant and no mitigation measures are required.
Would the project result in generation of excessive groundborne vibration or groundborne noise levels?
Less-Than Significant Impact. The Project would include the redevelopment of a site within Clovis.
Construction equipment typical of the development of multifamily residential buildings would be utilized temporarily. This equipment could include the use of heavy tractors, trucks, and other equipment; however, this type of equipment isn’t typically associated with excessive groundborne vibration given the distance of residential homes to the site. If any vibration were to occur, it’s likely that it would be temporary in nature and not at levels that would significantly impact the surrounding area.
Further, the Project would be required to comply with the provisions of Section 9.22.090 of the Clovis Municipal Code which requires that vibration not be perceptible along property lines and that it shall not interfere with operations or facilities on adjoining parcels. It’s important to note that temporary construction vibration and noise is exempt from these provisions since construction is temporary. Overall, because the type of equipment likely to be used in the development of the Project is not considered to be of the type and intensity to result in substantial vibration or groundborne noise, the impact would be less than significant and no mitigation measures are required.
For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
No Impact. The Project is not located within the vicinity of Fresno Yosemite International Airport, whic h is approximately five (5) miles southwest of the site. As such, it is located outside of the noise contour map of the airport.11 Therefore, people working at the church would not be exposed to excessive noise levels and no impact would occur.
11 Fresno Council of Governments, Airport Land Use Compatibility Plan, December 2018, Fresno Yosemite International Airport, Exh ibit D2, Noise Contours.
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47 14. POPULATION AND HOUSING
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Induce substantial unplanned
population growth in an area, either
directly (for example, by proposing
new homes and businesses) or
indirectly (for example through
extension of roads or other
infrastructure)?
X
b. Displace substantial numbers of
existing people or housing,
necessitating the construction of
replacement housing elsewhere?
X
ENVIRONMENTAL SETTING
The Project is located on an in -fill site that has previously been planned for residential use in the 2014 Clovis General Plan. As previously mentioned, a general plan amendment and rezone has been filed to redesignate the site to Medium High Density and rezone the site to R-2 to allow for the proposed multifamily project.
DISCUSSION
Would the project i nduce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example through extension of roads or other infrastructure)?
Less-Than-Significant Impact. As mentioned, the Project would include the development of a multifamily complex including 12 units. The proposed density change from the Low Density designation to the Medium High designation will increase the capacity of housing units and thus will increase the number of people in the area.
The existing designation will allow for 4 houses while the proposed project will provide 12 units (Ten 2-bedroom units and two 3-bedroom units). While the Project includes increasing the density for residential use, the overall area was planned for development and is considered an infill site. Further, unplanned population growth is typically associated with providing new services in remote areas of the City or other infrastructure that was not previously identified in the General Plan. The Project site itself is an in -fill site, thus, the primary infrastructure (i.e. road network, utilities, etc.) is already in place and would be able to serve the site. Thus, a less-than- significant impact would occur, and no mitigation measures are required.
Would the project d isplace s ubstantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
Less-Than-Significant Impact. The Project s ite is developed. While there is an existing home on the site, nobody currently lives at this location. The residence was damaged from a fire and had sat vacant for several years. Therefore, the Project would not result in the substantial displacement of existing people or housing.
Therefore, displacement of existing people or housing would not occur, and a less-than-significant impact would occur.
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48 15. PUBLIC SERVICES
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the Project result in substantial adverse
physical impacts associated with the provision
of new or physically altered governmental
facilities, 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 any of the public
services:
a. Fire protection? X
b. Police protection? X
c. Schools? X
d. Parks? X
e. Other public facilities? X
ENVIRONMENTAL SETTING
The Project is located on an in-fill site within the City, surrounded by existing residential and church uses. The Project would be served by the Clovis Fire Department, Clovis Police Department, with mutual aid from the City of Fresno or County of Fresno, when needed. The Project site would also be within the Clovis Unified School District.
The nearest fire station is Fresno County Fire Station 85, located approximately half a mile north of the site and Fire Station #3, located approximately one (1) mile southwest of the site. The Clovis Police department is located approximately one and a half (1.5) miles south of the site.
DISCUSSION
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significa nt environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection services?
Less-Than-Significant Impact. Although the Project would result additional residential units to the area, the site is in an urbanized area of the City already able to be served by the Clovis Fire Department. Also, the site itself is near Fire Station’s #3, which would mean that response times should be able to be maint ained during calls for service. As part of the entitlement process for the Project, the Clovis Fire Department reviewed the design and site layout to ensure adequate fire safety measures and site circulation are achieved. This review includes placement of new fire hydrants in certain locations throughout the site, adequate drive widths for fire truck and emergency vehicle access, and the appropriate application of fire codes, such as installation of sprinkler systems, fire alarms, and smoke detectors. The initial review by Fire Department determined that adequate fire services can be provided to the site subject to standard conditions of approval, including providing minimum clear paths of travel for fire access. Overall, construction that would meet the la test fire code standards, and review by the Clovis Fire Department, impacts related to effects on the performance of the Fire Department would be less-than-significant and no mitigation measures are required.
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49 Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintai n acceptable service ratios, response times or other performance objectives for police protection services?
Less-Than-Significant Impact. Although the Project would result in additional residential units to the area, the site is in an urbanized area of the City already able to be served by the Clovis Police Department. The Clovis Police Department headquarters are located at 1233 Fifth Street, which is approximately one and a half (1.5) miles from the site. As part of the entitlement process for the Projec t, the Clovis Police Department will review the design and site layout to ensure adequate safety measures are achieved. Lastly, the site is in an already urbanized area serviced by the Clovis Police Department, and thus access to and from the site would be similar to existing conditions when responding to calls for services. Consequently, a less-than-significant impact would occur, and no mitigation measures are required.
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, 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?
Less-Than Significant Impact. The Project includes construction of a multifamily residential complex which would generate students for schools. The Project request was distributed to the Clovis Unified School District for review and the school district did not express any concerns accommodating additional students that may result from the development of this project.
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, 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 parks?
Less-Than-Significant Impact. See discussion under Section 16, Recreation for the analysis related to parks.
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, 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 other public facilities?
Less-Than-Significant Impact. Although the Project would result in an increase in residential density, the increase can be considered less than significant. The project site is an infill development surrounded by existing residential and church uses. Further, through the entitlement process, the Project would undergo review by several departments and agencies for compliance with appropriate regulations and policies. This could result in various impact fees that are intended to maintain and enhance public facilities as appropriate. As such, payment of the typical development fees, as well as project review by the different department and agencies, would result in the Project having a less-than-significant impact to public facilities. No mitigation measures are required.
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50 16. RECREATION
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Would the project increase the use
of existing neighborhood and
regional parks or other recreational
facilities such that substantial
physical deterioration of the facility
would occur or be accelerated?
X
b. Does the project include
recreational facilities or require the
construction or expansion of
recreational facilities that might have
an adverse physical effect on the
environment?
X
ENVIRONMENTAL SETTING
The Project is located on an in-fill site surrounded by existing residential and church uses. The nearest park to the site is Dry Creek Park, located approximately half a mile west of the project site, and the nearest recreational trail is the Dry Creek Trail, which is also located half a mile west of the Project site.
DISCUSSION
Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
Less-Than-Significant Impact. As mentioned in the Population and Housing section of th is Initial Study, the Project proposes the construction of a multifamily residential complex which will generate new residents to the site that may increase utilization of the nearby park. However, the additional 12 units is not likely to substantially increase the usage of the park . Further, the Project itself would include landscaped common areas and play areas within its site for its residents. Overall, the type and use of Project would not likely increase the use of existing parks such that physical deterioration would occur. Therefore, the impact would be less-than- significant, and no mitigation measures are required.
Does the project include recreational facilities or require the con struction or expansion of recreational facilities that might have an adverse physical effect on the environment?
Less-Than-Significant Impact. The Project site itself would construct on site landscaping in compliance with City standards for residential development. However, it is not likely that the Project itself would require the construction or expansion of new recreational facilities that would have an adverse physical effect on the environment. The Project would also be required to contribute a propor tionate share towards the acquisition and development of future parks in order for the City to maintain its adopted ratio of providing four (4) acres of parkland per 1,000 residents, as stated in Policy 1.1 in the Open Space and Conservation Element of the 2014 General Plan, and Section 3.4.03 of the Clovis Municipal Code. As such, a less-than-significant impact would occur, and no mitigation measures are required.
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51 17. TRANSPORTATION
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Conflict with a program plan,
ordinance or policy addressing the
circulation system, including
transit, roadway, bicycle, and
pedestrian facilities?
X
b. Conflict or be inconsistent with
CEQA Guidelines section 15064.3,
subdivision (b)? X
c. Substantially increase hazards due
to a geometric design feature (e.g.,
sharp curves or dangerous
intersections) or incompatible uses
(e.g., farm equipment)?
X
d. Result in inadequate emergency
access? X
ENVIRONMENTAL SETTING
The Project is an infill site surrounded by existing residential subdivisions and a church. The site is bounded by Alluvial Avenue to the north and is located east of Sunnyside Avenue . According to the 2014 Clovis General Plan Circulation Diagram in the Circulation Element (Figure C -1 of the Circulation Element), Alluvial and Sunnyside Avenues are designated as collector streets. Collector streets are low-to-moderate capacity streets which serves to move traffic from local streets to arterial roads. A Trip Generation Analysis (TGA) was prepared by JLB Traffic Engineering on May 26, 2022 (included as Appendix D of this Initial Study). The information and analysis in the following section is based on the results of the TGA.
DISCUSSION
Would the project conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?
Less-Than-Significant Impact. As mentioned above, the site is within an urbanized area that was previously planned for residential development by the 2014 Clovis General Plan. The Project proposes a density of approximately 11.5 DU/Ac which is within the allowable density range of the Medium High Density land use designation. Although the existing land use designation is Low Density Residential, the applicant requests an increase to the Medium High Density land use designation.
As a result of the proposed increase, preparation of a TGA was required by the City Engineer to evaluate the potential difference in traffic generation of the proposed Project and that which could otherwise be developed consistent with the Clovis General Plan. The TGA focus on comparing the anticipated driveway trip generation during weekday, the AM peak hour and the PM peak hour of the project against that which could otherwise be developed consistent with the City of Clovis General Plan land use designation. Accordingly, the Project is 394
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52 estimated to generate more traffic by 43 daily trips, 2 AM peak hour trips and 2 PM peak hour trips. Based on this analysis, the City Engineer determined that there are less than significant impacts to program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.
Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Less-Than-Significant Impact. Under Senate Bill 743 (SB743) , traffic impacts are related to Vehicle Miles Traveled (VMT). The VMT metric became mandatory on July 1, 2020. The City Guidelines provide guidance relative to analyzing VMT for purposes of determ ining transportation impacts in accordance with CEQA. The City Guidelines also state that Projects that generate or attract fewer than 500 vehicle trips per day are presumed to cause a less-than-significant transportation impact. These Projects are identified as small project.
The Project is considered a small project and therefore will cause a less-than-significant impact.
Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
Less-Than-Significant Impact. The Project would result in a significant impact if it would include features that would create a hazard such as a sharp curve in a new roadway or create a blind corner or result in sight distance issues from entryways. Through the entitlement process, the Project would undergo review by multiple City departments, such as planning and engineering, to ensure that the site layout conforms to existing regulations, such as the City Development Code, and other applicable codes, such as the fire code and building code. During this review, the Project would need to make the necessary corrections to ensure that no hazardous design features would result from the Project. Therefore, because the P roject would undergo site plan and design review to ensure consistency and adherence to applicable design and site layout guidelines, a less-than- significant impact would occur. ‘
Would the project result in inadequate emergency access?
Less-Than-Significant Impact. The Project would include two ingress/egress access point s along Alluvial Avenue. As part of the Project review, the Clovis Fire Department would review all plans to ensure adequate emergency access is provided. This review includes review for adequate roadway widths, turning radii, as well as adequate access to units and accessibility to water. Consequently, because the Project plans would be required by the Clovis Municipal Code to be reviewed and approved by Clovis Fire Department and Police Department prior to construction, this impact would be less than significant, and no mitigation measures are required.
18. TRIBAL CULTURAL RESOURCES
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. 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)?
X
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53 b. A resource determined by the lead
agency, in its discretion and supported
by substantial evidence, to be
significant pursuant to criteria set forth
in subdivision (c) of Public Resources
Code Section 5024.1. In applying the
criteria set forth in subdivision (c) of
Public Resources Section 5024.1 for
the purposes of this paragraph, the lead
agency shall consider the significance
of the resource to a California Native
American Tribe?
X
ENVIRONMENTAL SETTING
On September 25, 2014, Governor Jerry Brown signed Assembly Bill AB52, which intends to protect a new class of recourse under CEQA. This new class is Tribal Cultural Resources and provides an avenue to identify Tribal Cultural resources through a consulta tion process, similar to SB18. However, unlike SB18, where consultation is required for all General Plan and Specific Plan Amendments, AB52, applies to all projects where a Notice of Determination is filed. Furthermore, the consultation process is requir ed to be complete prior to filing a Notice of Intent.
On May 17, 2022, consistent with SB18 and AB52, invitations to consult on the Project were mailed to 12 tribes within the area. Tribes have up to thirty (30) days to request consultation in accordance with AB52, while tribes have up to (90) days to request consultation in accordance with SB18. No requests for consultation were requested during these times. An Archaeological Resources Survey was prepared by LSA dated July 13, 2022 (See Appendix C). The Archeological Resources Memo was based on information obtained at the Southern San Joaquin Valley Information Center, CSU Bakersfield, as well as review of other surveys conducted in the area. Based on the Archeological Resources Survey, no cultural resources have been identified wit hin a half mile of the Project site.
DISCUSSION
Would the project cause a substantial adverse change to a 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)?
No Impact. As mentioned in the Project Description, the Project site is currently developed. There are no existing structures or features on the site that are listed or eligibl e in the California Register of Historical Resources, or in a local register. As such, the Project would have no impact and no mitigation measures are required.
Would the project cause a substantial adverse change to a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Section 5024.1 for the purposes of this paragraph, the lead agency shall consider the significance of the resource to a California Native American Tribe?
Less-Than-Significant Impact With Mitigation. As mentioned above, the City invited 1 2 Native American tribes to consult on the Project under AB52 and SB18, and no tribes requested consultation within the 30 -day 396
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54 or 90-day period. The Project site is developed but would require trenching and ground -disturbing activities during construction for the installation of utility infrastructure needed to serve the Project. Although no cultural resources were identified at the site, the potential remains that cultural resources could be inadvertently discovered during ground -disturbing activities. However, implementation of Mitigation Measures TCR -1 and TCR-2 below would reduce potential significant impacts and ensure protection in the event of accidental discovery of any cultural resources. With Mitigation Measure TCR -1 and TCR-2, impacts would be less-than- significant with mitigation.
Mitigation Measure TCR-1: If cultural or archaeological materials are encountered during construction activities, all work in the immediate vicinity of the find shall halt until a qualified professional archaeologist, meeting the Secretary of the Interior’s Professional Qualification Standards for prehistoric and historic archaeologist, can evaluate the significance of the find and make recommendations. Cultural resource materials may include prehistoric resources such as flaked and ground stone tools and debris, shell, bone, ceramics, and fire -affected rock as well as historic resources such as glass, metal, wood, brick, or structural remnants. If the qualified professional archaeologist determines that the discovery represents a potentially significant cultural resource, additional investigations may be required to mitigate adverse impacts from project implementation. These additional studies may include avoidance, testing, and evaluation or data recovery excavation. If a potentially eligible resource is encountered, then the qualified professional archaeologist, the Lead Agency, and the project proponent shall arrange for either 1) total avoidance of the resource or 2) test excavations to evaluate eligibility and, if elig ible, total data recovery. The determination shall be formally documented in writing and submitted to the Lead Agency as verification that the provisions for managing unanticipated discoveries have been met.
Mitigation Measure TCR-2: If human remains are discovered during construction or operational activities, further excavation or disturbance shall be prohibited pursuant to Section 7050.5 of the California Health and Safety Code. The specific protocol, guidelines, and channels of communication outlined by the Native American Heritage Commission, in accordance with Section 7050.5 of the Health and Safety Code, Section 5097.98 of the Public Resources Code (Chapter 1492, Statutes of 1982, Senate Bill 297), and Senate Bill 447 (Chapter 44, Statutes of 1987), shall be followed. Section 7050.5(c) shall guide the potential Native American involvement, in the event of discovery of human remains, at the direction of the County coroner. All reports, correspondence, and determinations regarding the discovery of human remains on the project site shall be submitted to the Lead Agency.
19. UTILITIES AND SERVICE SYSTEMS
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Require or result in the relocation or
construction of new or expanded water,
wastewater treatment or storm water
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which
could cause significant environmental
effects?
X
b. Have sufficient water supplies available
to serve the project and reasonably X
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55 foreseeable future development during
normal, dry and multiple dry years?
c. Result in a determination by the
wastewater treatment provider that
serves or may serve the project that it
has adequate capacity to serve the
project’s projected demand in addition
to the provider’s existing commitments?
X
d. Generate solid waste in excess of State
or local standards, or in excess of the
capacity of local infrastructure, or
otherwise impair the attainment of solid
waste reduction goals?
X
e. Comply with federal, state, and local
management reduction statutes and
regulations related to solid waste? X
ENVIRONMENTAL SETTING
Pacific Gas & Electric (PG&E) provides electricity and natural gas services in the City of Clovis. AT&T/SBC provides telephone service to the City.
The City’s water supply sources include groundwater drawn from the Kings Sub-basin of the San Joaquin Valley Groundwater Basin and treated surface water from the Fresno Irrigation District (MID). Surface water is treated at the City of Clovis Surface Water Treatment Facility.
The City of Clovis provides sewer collection service to its residents and busin esses. Treatment of wastewater occurs at the Fresno -Clovis Regional Wastewater Treatment Plant (RWTP). The Fresno -Clovis RWTP is operated and maintained by the City of Fresno and operates under a waste discharge requirement issued by the Central Valley Re gional Water Quality Control Board. Additionally, the City of Clovis has completed a 2.8 mgd wastewater treatment/water reuse facility, which will service the City’s new growth areas.
The Fresno Metropolitan Flood Control District (FMFCD) has the responsi bility for storm water management within the Fresno -Clovis metropolitan area of the Project site. Stormwater runoff that is generated by land development is controlled through a system of pipelines and storm drainage detention basins.
DISCUSSION
Would t he project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Less-Than-Significant Impact. The Project includes construction of a multifamily infill development. A Water Infrastructure Investigation for the Project was conducted by Provost and Pritchard Consulting Group (“P&P”) and a Wastewater Service Study for the Project was conducted by Blair, Church & Flynn Consulting Engineers.
In the technical memorandum dated June 27, 2022, P&P confirmed that the City’s existing and planned water distribution system and recommended connections should be adequate to convey water supply to the Project to support the anticipated demands form the Project. The Wastewater Service Study dated July 8, 2022 also 398
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56 indicates that the existing and planned wastewater collection system facilities can accommodate the proposed change from Low Density Residential to Medium High Density Residential land use for the subject site. Further, as part of the review process for the Project, the wastewater impacts will be evaluated by the City Engineer to ensure compliance with the City’s Waste Water Master Plan, as well as FMFCD, so that the Project would not exceed wastewater treatment requirements such that a new facility would be required nor would the existing treatment facility need to be expanded. FMCD has reviewed the Project and there are existing facilities to serve the site subject to mitigation. Further, while the Project would introduce new uses at this site, the type of development is consistent with the land use designation previously planned for. Upon rev iew and approval by the City Engineer, the Project would result in a less-than-significant impact.
Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
Less-Than-Significant Impact. The Project is entirely within the FID service area. Lands within the service area are entitled to an average annual allotment of approximately 2.24 acre -feet per acre. According to t he Water Infrastructure Inv estigation conducted by P&P, the Project would increase the Annual Average (AFY) from 2.6 to 3.4. The additional supply required (AFY) is 1.1 for the Project. In accordance with City Ordinance, the Project will need to pay additional fees so that the City can acquire additional water supply to serve the development. Water from the Kings River is available to offset the anticipated annual demand of 3.4 acre-feet.
Therefore, the Project will cause a less-than-significant impact on water supply.
Would the pro ject result in a determination by the wastewater treatment provider that serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
Less-Than-Significant Impact. The Wastewater Service Study was conducted by Blair, Church, and Flynn on July 8, 2022 , which determined that the existing and planned wastewater collection system facilities can accommodate the type of use proposed. For that reason, the impact would be less than significant.
Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
Less-Than-Significant Impact. The Project would introduce new solid waste throughout construction and operation of the Project. However, the Project would be required to comply with Chapter 6.3.1, Recycling and Diversion of Construction and Demolition Debris, of the Clovis Municipal Code during construction. This section of the Clovis Municipal Code requires that a minimum of fifty percent (50%) of waste tonnage from a project be diverted from disposal, and that all new residential (and commercial) construction within the City shall submit and obtain approval for a waste management plan prior to construction activities. Compliance with these measures would ensure that the Project does not result in a significant impact during the construction phase of the Project. Further, compliance with policies in the General Plan for the reduction and recycling of solid waste would serve to reduce impacts of solid waste by promoting and encouraging the recycling of materials. Lastly, according to the California Department of Resources Recycling and Recovery (CalRecycle), the City of Clovis has exceeded their target per employee disposal rate of 15.5 pounds per day per employee, meaning that Clovis residents are actually producing less solid waste than the target set by the State.12 Consequently, a less-than- significant impact would occur.
Would the project comply with federal, state, and local management reduction statutes and regulations related to solid waste?
Less-Than-Significant. See discussion 19d above.
12 Calrecycle, City of Clovis, https://www2.calrecycle.ca.gov/LGCentral/DiversionProgram/JurisdictionDiversionPost2006, accessed October 2022. 399
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57 20. WILDFIRE
If located in or near state responsibility
areas or lands classified as very high fire
hazard severity zones, would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Substantially impair an adopted
emergency response plan or
emergency evacuation plan? X
b. Due to slope, prevailing winds, and
other factors, exacerbate wildfire
risks, and thereby expose project
occupants to, pollutant concentrations
from a wildfire or the uncontrolled
spread of a wildfire?
X
c. Require the installation or
maintenance of associated
infrastructure (such as roads, fuel
breaks, emergency water sources,
power lines or other utilities) that may
exacerbate fire risk or that may result
in temporary or ongoing impacts to
the environment?
X
d. Expose people or structures to
significant risks, including downslope
or downstream flooding or landslides,
as a result of runoff, post-fire slope
instability, or drainage changes?
X
ENVIRONMENTAL SETTING
The Project site is located on an infill site surrounded by existing urban uses. The site’s topography is relatively flat with level terrain and is characterized primarily by the existing peach orchard.
DISCUSSION
Would the project substantially impair an adopted emergency response plan or emergency evacuation plan?
Less-Than-Significant Impact. The Project is located at a site that is relatively flat with level terrain and is surrounded by existing development. Further, the road network is already in place from previous development.
Although the Project could result in temporary traffic detouring or closures during buildout, these delays would be temporary and would be coordinated with the City engineering department and other departments to ensure safe access to and from the area is maintained. Further, the site itself would be reviewed by City departments to ensure adequate site access and circulation is provided in the event of an emergency. Overall, a less-than- significant impact would occur.
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58 Would the project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
Less-Than-Significant Impact. The Project site is relatively flat with level terrain, is partially developed, and is located on an infill site surrounded by existing urban uses. The general vicinity of the site is flat, therefore, is not of the type of topography nor in a location likely to exacerbate wildfire risks. Further, the Project would be required to comply with the latest fire codes and would be required to include spr inklers on the interior of the structures and require installation of several hydrants throughout the site. Lastly, the site plans would undergo review by the Clovis Fire Department to ensure that all fire safety regulations are met. Therefore, a less-than- significant impact would occur.
Would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
Less-Than-Significant Impact. The site is located in an area previously developed with urban uses. As a new development, installation of a private roadway network, water lines, and power lines would be required; however, these utilities and infrastructure are typical of development and would be constructed to standards of the respective agencies and departments which oversee them, as well as be required to comply all necessary plan review and permitting requirements of such departments and agencies. As such, a less-than-significant impact would occur.
Would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
No Impact. The City of Clovis is generally flat topography, and the site itself is in an area that is not in close proximity to hillsides such that it would expose people or structures to significant risks asso ciates with downstream flooding or landslides as a result of runoff or post -fire slope instability. As such, no impact would occur.
21. MANDATORY FINDINGS OF SIGNIFICANCE
Would the project:
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a. Does the project have the potential to
substantially degrade the quality of the
environment, substantially reduce the
habitat of a fish or wildlife species, cause
a fish or wildlife population to drop below
self-sustaining levels, threaten to eliminate
a plant or animal community, substantially
reduce the number or restrict the range of
a rare or endangered plant or animal, or
eliminate important examples of the major
periods of California history or prehistory?
X
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59 b. Does the project have impacts that are
individually limited, but cumulatively
considerable? (“Cumulatively
considerable” means that the incremental
effects of a project are considerable when
viewed in connection with the effects of
past projects, the effects of other current
projects, and the effects of probable future
projects)?
X
c. Does the project have environmental
effects that will cause substantial adverse
effects on human beings, either directly or
indirectly?
X
ENVIRONMENTAL SETTING
The Project is located on an infill site within the City of Clovis, substantially surrounded by existing development consisting of residential and educational uses.
DISCUSSION
Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self - sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory?
Less-Than-Significant Impact. As discussed above throughout the Initial Study, the Project would not result in any significant impacts with implementation of mitigation measures prescribed above. Therefore, the Project would have a less-than-significant impact as it would not substantially degrade the quality of the environment.
Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)?
Less-Than-Significant Impact. The Project includes mitigation measures in certain topic areas identified throughout this Initial Study which would reduce potential impacts to a less-than-significant level. None of these impacts would be cumulatively considerable since most are either temporary impacts from construction or site specific. While air quality that is generally considered to be cumulatively measured, the Project was found to have a less-than-significant impact through compliance with existing regulations from the SJVPACD. As such, future Projects in Clovis would be required to comply with those same regulations, ensuring adequate mitigation as development occurs. Thus, a less-than-significant impact would occur.
Does the project have environmental effects that will cause substantial adverse effects on human beings, either directly or indirectly?
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60 Less-Than-Significant Impact. As discussed throughout the document, the Project would not result in a significant impact that could not be mitigated to a less-than-significant level. Therefore, a less-than-significant impact would occur.
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61 I. Report Preparation
LEAD AGENCY
Lily Cha
Senior Planner
City of Clovis
Planning & Development Services
TECHNICAL STUDIES
Air Quality, Health Risk Analysis, and Greenhouse Gas Technical Memorandum 1491 Alluvial Residential Development Project
Richard Miller, Air Quality and Climate Change Specialist Johnson Johnson and Miller Air Quality Consulting Services
Biological Resources Assessment
1491 Alluvila Avenue Project
Kelly McDonald, Biologist
LSA Associates, Inc.
Archaeological Resources Survey Assessment
1491 Alluvial Avenue Project
Kerrie Collison, M.A, RPA 28731436, Associate/ Senior Cultural Resources Manager LSA Associates, Inc.
Historical Evaluation
1491 Alluvial Avenue Project
Casey Tibbet, M.A., Associate/ Cultural Resources Manager LSA Associates, Inc.
Traffic Generation Analysis
Alluvial Avenue Project
Carlos Ayala-Magana, Engineer I/II
JLB Traffic Engineering, Inc.
Wastewater Service Study
Proposed 12-unit Multi-Family Residential Development
Brad Kerner, PE
Blair, Church & Flynn Consulting Engineers
Water Infrastructure Investigation
Alluvial Avenue Project
Nicolas Jacobson, PE
Provost and Pritchard Consulting Group
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AGENDA ITEM NO. 12.
Proposed 1491 Alluvial Residential Development Project—Clovis, CA Air Quality, Health Risk Analysis, and Greenhouse Gas Technical Memorandum June 29, 2022
To: Crawford Architecture &
Planning
Attn: Nicholas Crawford, AIA
1755 Herndon Avenue
Clovis, CA 93611
[email protected]
From: Johnson Johnson and Miller Air Quality
Consulting Services
Richard Miller, Air Quality and Climate
Change Specialist
[email protected]
Kimber Johnson, Air Quality and
Climate Change Specialist
[email protected]
Proposed 1491 Alluvial Residential Development Project in Clovis, CA Date: June 29, 2022
Subject: Air Quality, Health Risk Analysis, and Greenhouse Gas Technical Memorandum This Air Quality, Health Risk Analysis, and Greenhouse Gas Emissions Technical Memorandum was prepared to evaluate whether the estimated criteria air pollutant, ozone precursor, toxic air contaminant (TAC), and/or greenhouse gas (GHG) emissions generated from construction and/or operation of the proposed 1491 Alluvial Residential Development Project in Clovis, CA (proposed project or project) would cause significant impacts to air resources in the project area. The respective analyses were conducted within the context of the California Environmental Quality Act (CEQA) (California Public Resources Code [PRC] § 21000, et seq.).
The methodology follows the Guidance for Assessing and Mitigating Air Quality Impacts (GAMAQI) prepared by the San Joaquin Valley Air Pollution Control District (SJVAPCD) for the quantification of emissions and evaluation of potential impacts to air resources1 and the SJVAPCD’s Guidance for Valley Land-Use Agencies in Addressing GHG Emission Impacts for New Projects under the California Environmental Quality Act.2 Project Location and Description
The proposed project consists of the construction of a residential development project in the City of Clovis, Fresno County, California. The proposed project covers approximately 1.04 acres generally located northwest of the intersection of North Fordham Avenue and Alluvial Avenue in Clovis, California. The Assessor’s Parcel Number (APN) associated with the project is 563-142-
35. The project would include demolition of an existing single-family residence on the project site. The use and density being proposed would require an amendment to the general plan land designation from L (Low Density Residential; 2.1-4 du.ac) to MH (Medium High Density Residential; 7.1 to 15 du/ac) and a rezone from R-1-7500 to R-2.
1 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015. Guidance for Assessing and Mitigating Air Quality Impacts.
February 19. Website: https://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT-GAMAQI.PDF. Accessed June 22, 2022.
2 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2009. Guidance for Valley Land-use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA. December 17. Website: https://www.valleyair.org/Programs/CCAP/12- 17-09/3%20CCAP%20-%20FINAL%20LU%20Guidance%20-%20Dec%2017%202009.pdf. Accessed June 22, 2022. 1 406
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An aerial view of the project site is shown in Figure 1. The project site plan is included as part of Attachment C (Additional Supporting Information).
Figure 1 – Project Site—Aerial Vicinity
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Modeling Parameters and Assumptions
The following modeling parameters and assumptions were used to generate criteria air pollutant (including precursors), Toxic Air Contaminants (TACs), and greenhouse gas (GHG) emissions for the proposed project.
Air Pollutants and GHGs Assessed
Criteria Pollutants Assessed
The following criteria air pollutants were assessed in this analysis: reactive organic gases (ROG), oxides of nitrogen (NOX), carbon monoxide (CO), sulfur oxides (SOX), particulate matter less than 10 microns in diameter (PM10), and particulate matter less than 2.5 microns in diameter (PM2.5).
Note that the proposed project would emit ozone precursors ROG and NOX. However, the proposed project would not directly emit ozone since it is formed in the atmosphere during the photochemical reaction of ozone precursors.
The project does not contain sources that would produce substantial quantities of SOX emissions during construction or operation. Modeling conducted for the project is provided in Attachment A and includes SO2 emission estimates. No further analysis of SO2 is required.
GHGs Assessed
This analysis was restricted to GHGs identified by AB 32, which include carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6), and nitrogen trifluoride (NF3). The proposed project would generate a variety of GHGs, including several defined by AB 32 such as CO2, CH4, and N2O.
Certain GHGs defined by AB 32 would not be emitted by the project. HFCs, PFCs, SF6, and NF3 are typically used in industrial applications, none of which would be used for typical residential operations. Therefore, it is not anticipated that the proposed project would emit those GHGs.
GHG emissions associated with the proposed project construction, as well as future operations were estimated using CO2 equivalent (CO2e) emissions as a proxy for all GHG emissions.
Construction GHG emissions were amortized over the lifetime of the proposed project. In order to obtain the CO2e, an individual GHG is multiplied by its Global Warming Potential (GWP). The GWP designates on a pound for pound basis the potency of the GHG compared to CO2.
Toxic Air Containments Assessed
Diesel particulate matter (DPM)
Studies indicate that diesel particulate matter (DPM) poses the greatest health risk among airborne TACs. The California Air Resources Board (CARB) conducted a 10-year research program that demonstrated that DPM from diesel-fueled engines is a human carcinogen and that chronic (long-term) inhalation exposure to DPM poses a chronic long-term health risk. 3 408
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DPM is part of a complex mixture that makes up diesel exhaust. Diesel exhaust is composed of two phases: gas and particle. The gas phase is composed of many of the urban hazardous air pollutants, such as acetaldehyde, acrolein, benzene, 1,3-butadiene, formaldehyde, and polycyclic aromatic hydrocarbons. The particle phase also has many different types of particles that can be classified by size or composition. The size of diesel particulates that are of greatest health concern are those that are in the categories of fine and ultra-fine particles. The composition of these fine and ultra-fine particles may be composed of elemental carbon with adsorbed compounds such as organic compounds, sulfate, nitrate, metals, and other trace elements. Diesel exhaust is emitted from a broad range of diesel engines, such as the on-road diesel engines of trucks, buses, and cars, and off-road diesel engines that include locomotives, marine vessels, and heavy-duty equipment.3
For purposes of this analysis, DPM exhaust emissions are represented as particulate matter that is 10 micrometers in diameter and smaller (PM10).
Asbestos
Asbestos is a fibrous mineral that both naturally occurs in ultramafic rock (a rock type commonly found in California) and is used as a processed component of building materials. Because asbestos has been proven to cause a number of disabling and fatal diseases, such as asbestosis and lung cancer, it is strictly regulated either based on its natural widespread occurrence or in its use as a building material. In the initial Asbestos National Emission Standards for Hazardous Air Pollutants rule promulgated in 1973, a distinction was made between building materials that would readily release asbestos fibers when damaged or disturbed (friable) and those materials that were unlikely to result in significant fiber release (non-friable). The U.S. Environmental Protection Agency (EPA) has since determined that, when severely damaged, otherwise non-friable materials can release significant amounts of asbestos fibers. Asbestos has been banned from many building materials under the Toxic Substances Control Act, the Clean Air Act, and the Consumer Product Safety Act. Naturally occurring asbestos (NOA) is known to occur in many parts of California and is commonly associated with ultramafic or serpentinite rock.
Model Selection
Criteria Pollutants and GHG Emissions—Model Selection
The California Emissions Estimator Model (CalEEMod) is a statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both construction and operations from a variety of land use projects. CalEEMod quantifies direct emissions from construction and operation activities (including vehicle use), as well as indirect emissions, such as GHG emissions from energy use, solid waste disposal, vegetation planting and/or removal, and water
3 California Air Resources Board (CARB). 2019. Overview: Diesel Exhaust and Health. Website:
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use. Furthermore, CalEEMod identifies mitigation measures to reduce criteria pollutant and GHG emissions along with calculating the benefits achieved from measures chosen by the user.
CalEEMod was developed for the California Air Pollution Control Officers Association (CAPCOA) in collaboration with the California Air Districts. Default data (e.g., emission factors, trip lengths, meteorology, source inventory, etc.) have been provided by the various California Air Districts to account for local requirements and conditions.
CalEEMod is a comprehensive tool for quantifying air quality impacts from land use projects located throughout California. The model can be used for a variety of situations where an air quality analysis is necessary or desirable such as preparing CEQA or National Environmental Policy Act documents, conducting pre-project planning, and, verifying compliance with local air quality rules and regulations, etc.
CalEEMod version 2020.4.0 was used to estimate project-generated emissions from construction and operations of the proposed project.
Construction DPM emissions (represented as PM10 exhaust) were estimated using CalEEMod version 2020.4.0. Emissions were estimated for the unmitigated scenario.
Toxic Air Containments—Model Selection and Parameters
An air dispersion model is a mathematical formulation used to estimate the air quality impacts at specific locations (receptors) surrounding a source of emissions given the rate of emissions and prevailing meteorological conditions. The air dispersion model applied in this assessment was the U.S. EPA AERMOD (version 21112) air dispersion model. Specifically, the AERMOD model was used to estimate levels of air emissions at sensitive receptor locations from potential sources of project-generated TACs during the construction period. The use of the AERMOD model provides a refined methodology for estimating construction impacts by utilizing long-term, measured representative meteorological data for the project site and a representative construction schedule.
The modeling analysis also considered the spatial distribution and elevation of each emitting source in relation to the sensitive receptors. Direction-dependent calculations were obtained by identifying the Universal Transverse Mercator (UTM) coordinates for each source location.
Terrain elevations were obtained for the project site using the AERMAP model, the AERMOD terrain data pre-processor. Specifically, terrain data from the U.S. Geological Survey (USGS) National Elevation Database (NED) for the project area was used. The air dispersion model assessment used meteorological data from the Fresno metrological station, located approximately 3.6 miles southwest of the project area. The meteorological data used was preprocessed for use with AERMOD by SJVAPCD and included data for the years 2013-2017; all years were used in the assessment. To evaluate the proposed project’s localized impacts at the point of maximum impact, all receptors were placed within the breathing zone at 1.2 meters above ground level. Furthermore, the closest sensitive receptors were existing residences directly adjacent to the project site. The health risk calculations were completed using residential factors for all receptors.
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For the construction period, construction emissions were assumed to be distributed over the project site with a working schedule of eight hours per day and five days per week. Emissions were adjusted by a factor of 4.2 to convert for use with a 24-hour-per-day, 365 day-per-year averaging period. This adjustment was completed in AERMOD by applying a variable hour work period. Detailed parameters and complete calculations are contained in Attachment B.
Assumptions
Construction Modeling Assumptions
Schedule
The proposed project would require various tasks including site preparation, grading, building construction, paving, and architectural coating (painting). The exact start and end times for various project phases are currently unknown. Table 1 shows the anticipated construction schedule. Construction of the project is expected to begin on 08/01/2023 and last for 4-6 months. The earliest anticipated operational start date for the project is 10/01/2023. The construction schedule utilized in the analysis represents a “worst-case” analysis scenario since emission factors for construction equipment decrease as the analysis year increases, due to improvements in technology and more stringent regulatory requirements. Therefore, construction emissions would decrease if the construction schedule moved to later years or is phased over multiple years. The duration of construction activity and associated equipment represent a reasonable approximation of the expected construction fleet as required per CEQA guidelines. The site-specific construction fleet may vary due to specific project needs at the time of construction.
Table 1: Project Construction Schedule
Construction Task Start Date End Date
Number of
Days per
Week
Number of
Workdays per
Phase
Demolition 8/1/2023 8/28/2023 5 20
Site Preparation 8/29/2023 8/30/2023 5 2
Grading 8/31/2023 9/5/2023 5 4
Paving 9/6/2023 9/19/2023 5 10
Building Construction 9/20/2023 1/18/2024 5 87
Architectural Coating 1/19/2024 2/1/2024 5 10
Source: CalEEMod Output (Attachment A); also shown in Additional Supporting Information (Attachment C).
Equipment
The off-road equipment fleet for construction were generated using default values from CalEEMod. CalEEMod generates construction fleets for construction activities based on the size of the construction areas. Construction equipment for each construction activity is shown in Table 2.
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Table 2: Project Construction Equipment
Construction Task Equipment Type
Pieces of
Equipment
Usage
(hours/day) Horsepower
Load
Factor Fuel Type
Demolition Concrete/Industrial Saws 1 8 81 0.73 Diesel
Rubber Tired Dozers 1 8 247 0.40 Diesel
Tractors/Loaders/Backhoes 3 8 97 0.37 Diesel
Site Preparation
Graders 1 8 187 0.41 Diesel
Rubber Tired Dozers 1 7 247 0.40 Diesel
Tractors/Loaders/Backhoes 1 8 97 0.37 Diesel
Grading
Graders 1 8 187 0.41 Diesel
Rubber Tired Dozers 1 8 247 0.40 Diesel
Tractors/Loaders/Backhoes 2 7 97 0.37 Diesel
Paving Cement and Mortar Mixers 1 6 9 0.56 Diesel
Pavers 1 6 130 0.42 Diesel
Paving Equipment 1 8 132 0.36 Diesel
Rollers 1 7 80 0.38 Diesel
Tractors/Loaders/Backhoes 1 8 97 0.37 Diesel
Building Construction Cranes 2 6.9 231 0.29 Diesel
Forklifts 2 6.9 89 0.20 Diesel
Generator Sets 2 9.2 84 0.74 Diesel
Tractors/Loaders/Backhoes 2 6.9 97 0.37 Diesel
Welders 6 9.2 46 0.45 Diesel
Architectural Coating Air Compressors 1 6 78 0.48 Diesel Source: CalEEMod Output (Attachment A); also shown in Additional Supporting Information (Attachment C).
Vehicle Trips
Table 3 provides a summary of the construction-related vehicle trips. CalEEMod default values were used to estimate the number of construction-related vehicle trips and were supplemented with additional purpose-based trips to avoid underestimating emissions from on-road vehicles anticipated during the construction period.
The default values for hauling trips are based on the assumption that a truck can haul 20 tons (or 16 cubic yards) of material per load. If one load of material is delivered, CalEEMod assumes that one haul truck importing material will also have a return trip with an empty truck (e.g., 2 one-way trips). Hauling trips were generated in the demolition phase based on the assumption that 1,111 tons of debris would be generated from the demolition of existing buildings (an existing residence and related outbuildings) and demolition/removal of existing hardscape currently occupying the project site (see Attachment A for calculations used to estimate the amount of debris to be generated). Based on applicant-provided information, cut and fill is 7 412
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expected to mostly balance on-site. For the purposes of estimating emissions, it was assumed that up to 1,000 cubic yards of material could be imported and 1,000 cubic yards of material could be exported during the grading phase.
The fleet mix for worker trips is light-duty passenger vehicles to light-duty trucks. The vendor trips fleet mix is composed of a mixture of medium and heavy-duty diesel trucks. The hauling trips were assumed to be 100 percent heavy-duty diesel truck trips. CalEEMod default trip lengths for a project in Fresno County and an urban setting were used for construction trips.
Table 3: Construction Vehicle Trips
Construction Task Worker Trips per Day Vendor Trips per Day Total Haul Truck Trips Demolition 13 0 120
Site Preparation 8 0 6
Grading 10 0 258
Paving 13 4 10
Building Construction 21 6 28
Architectural Coating 4 0 2
Source: CalEEMod Output (Attachment A); also shown in Additional Supporting Information (Attachment C)
Operational Modeling Assumptions
Operational emissions are those emissions that occur during operation of the proposed project.
The sources are summarized below.
Motor Vehicles
Motor vehicle emissions refer to exhaust and road dust emissions from the automobiles that would travel to and from the proposed project site. Assumptions were based on the CalEEMod default values for the low-rise multifamily residential land use. The default rates are based on information from the Institute of Transportation Engineers (ITE) Trip Generation Handbook, 10th Edition. Trip rates for the same land use were obtain from the ITE Trip Generation Handbook 11th Edition. As the CalEEMod default rates were higher than rates in the 11th Edition of ITE Trip Generation Handbook, default rates were retained to present a more conservative estimate of emissions.
The trip generation rates for each phase of the project are shown in Table 4.
Table 4: Project Daily Trip used to Estimate Emissions
Land Use Type Amount Units
Weekday Trip
Generation Rate
per Dwelling Unit
Saturday Trip
Generation Rate
per Dwelling Unit
Sunday Trip
Generation Rate
per Dwelling Unit
Trip Rates
12-unit Multifamily
Development 12 Dwelling
Units 7.32 8.14 6.28
Daily Trips
12-unit Multifamily Development (Trips per Day) 87.84 97.68 75.36 8 413
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Source of Trip Rates: Institute of Transportation Engineers (ITE), Trip Generation Manual 10th Edition, consistent with CalEEMod default values.
Pass-by trips are assumed to already be on the local roads; however, unlike internal capture, vehicles making pass-by trips are not necessarily making a single trip to visit multiple land uses within the project site. For the purposes of estimating air pollutant emissions, it is appropriate to account for the project-generated trips that would travel to and from the project site. CalEEMod default trip types were applied in the analysis. Please see Attachment A for detailed assumptions.
Trip Lengths
The CalEEMod default round trip lengths for an urban setting in Fresno County were used in this analysis. Trip lengths are for primary trips. Trip purposes are primary, diverted, and pass-by trips. Diverted trips take a slightly different path than a primary trip. The CalEEMod default rates for percentages of primary, diverted, and pass-by trips were used.
Vehicle Fleet Mix
The vehicle fleet mix is defined as the mix of motor vehicle classes active during the operation of the proposed project. Emission factors are assigned to the expected vehicle mix as a function of vehicle class, speed, and fuel use (gasoline- and diesel-powered vehicles). To estimate emissions associated with the proposed project, the vehicle fleet mixes were revised to reflect the residential fleet mix approved by the SJVAPCD for each year analyzed.
Area Sources
Consumer Products
Consumer products are various solvents used in non-industrial applications, which emit VOCs during their product use. “Consumer Product” means a chemically formulated product used by household and institutional consumers, including but not limited to: detergents; cleaning compounds; polishes; floor finishes; cosmetics; personal care products; home, lawn, and garden products; disinfectants; sanitizers; aerosol paints; and automotive specialty products. It does not include other paint products, furniture coatings, or architectural coatings. CalEEMod includes default consumer product use rates based on building square footage. The default emission factors developed for CalEEMod were used for consumer products were used.
Architectural Coatings (Painting)
Paints release VOC emissions. The residential building(s) included as part of the proposed project would be repainted on occasion. The project is required to comply with the SJVAPCD Rule 4601—Architectural Coatings. Effective January 1, 2022, nonflat gloss and semi-gloss paints will also be required to meet the 50 g/l standard, providing lower VOC emissions for buildings constructed after that date.
Landscaping Emissions
CalEEMod estimates a total of 180 days for which landscaping equipment would be used to estimate potential emissions for the proposed project.
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Indirect Emissions
For GHG emissions, CalEEMod contains calculations to estimate indirect GHG emissions.
Indirect emissions are emissions where the location of consumption or activity is different from where actual emissions are generated. For example, electricity would be consumed at the proposed project site; however, emissions associated with producing that electricity are generated off-site at a power plant. Since the electricity can vary greatly based on locations, the user should override these values if they have more specific information regarding their specific water supply and treatment.
Energy Use
The emissions associated with the building electricity and natural gas usage (non-hearth) were estimated based on the land use type and size. Values for a project served by Pacific Gas and Electric (PG&E) were used in the analysis.
The Renewables Portfolio Standard (RPS) is not accounted for in CalEEMod 2020.4.0. The Renewable Electricity Standards took effect in 2020. The Renewable Electricity Standard requires that electricity providers include a minimum of 33 percent renewable energy in their portfolios by the year 2020. CalEEMod 2020.4.0 includes PG&E emission factors based on actual rates reported by the utility. The latest information available in PG&E’s 2020 Sustainability Report were used to adjust the project’s CO2 intensity factor for the 2030 scenario.
Other Indirect Emissions (Water Use, Wastewater Use, and Solid Waste) CalEEMod includes calculations for indirect GHG emissions for electricity consumption, water consumption, and solid waste disposal. For water consumption, CalEEMod calculates embedded energy (e.g., treatment, conveyance, distribution) associated with providing each gallon of potable water to the project. For solid waste disposal, GHG emissions are associated with the disposal of solid waste generated by the proposed project into landfills. CalEEMod default data was used for inputs associated with solid waste.
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AIR QUALITY
Environmental Setting
Air quality impacts are both local and regional. Regional and local air quality is impacted by topography, dominant airflows, atmospheric inversions, location, and season. The project is located in Clovis, within Fresno County. The project site and all of Fresno County are in the San Joaquin Valley Air Basin (Air Basin or SJV Air Basin), which experiences some of the most challenging environmental conditions for air quality in the nation. The following section describes these conditions as they pertain to the Air Basin. The information in this section is primarily from the SJVAPCD’s GAMAQI.4
Topography
The topography of a region is important for air quality because mountains can block airflow that would help disperse pollutants and can channel air from upwind areas that transports pollutants to downwind areas. The SJVAPCD covers the entirety of the SJV Air Basin. The Air Basin is generally shaped like a bowl. It is open in the north and is surrounded by mountain ranges on all other sides. The Sierra Nevada mountains are along the eastern boundary (8,000 to 14,000 feet in elevation), the Coast Ranges are along the western boundary (3,000 feet in elevation), and the Tehachapi Mountains are along the southern boundary (6,000 to 8,000 feet in elevation).
Climate
The climate is important for air quality because of differences in the atmosphere’s ability to trap pollutants close to the ground, which creates adverse air quality; inversely, the atmosphere’s ability to rapidly disperse pollutants over a wide area prevents high concentrations from accumulating under different climatic conditions. The SJV Air Basin has an “inland Mediterranean” climate and is characterized by long, hot, dry summers and short, foggy winters.
Sunlight can be a catalyst in the formation of some air pollutants (such as ozone); the SJV Air Basin averages over 260 sunny days per year.
Inversion layers are significant in determining pollutant concentrations. Concentration levels can be related to the amount of mixing space below the inversion. Temperature inversions that occur on the summer days are usually encountered 2,000 to 2,500 feet above the valley floor. In winter months, overnight inversions occur 500 to 1,500 feet above the valley floor.
Dominant airflows provide the driving mechanism for transport and dispersion of air pollution.
The mountains surrounding the SJV Air Basin form natural horizontal barriers to the dispersion of air contaminants. The wind generally flows south-southeast through the valley, through the Tehachapi Pass and into the Mojave Desert Air Basin portion of Kern County. As the wind moves through the SJV Air Basin, it mixes with the air pollution generated locally, generally transporting air pollutants from the north to the south in the summer and in a reverse flow in the winter.
4 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015. Guidance for Assessing and Mitigating Air Quality Impacts.
February 19. Website: https://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT-GAMAQI.PDF. Accessed May 20, 2022.
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The winds and unstable air conditions experienced during the passage of winter storms result in periods of low pollutant concentrations and excellent visibility. Between winter storms, high pressure and light winds allow cold moist air to pool on the San Joaquin Valley floor. This creates strong, low-level temperature inversions and very stable air conditions, which can lead to Tule fog. Wintertime conditions favorable to fog formation are also conditions favorable to high concentrations of PM2.5 and PM10.
Criteria Air Pollutants
The Federal Clean Air Act (FCAA) establishes the framework for modern air pollution control.
The FCAA, enacted in 1970 and amended in 1990, directs the U.S. EPA to establish ambient air quality standards. These standards are divided into primary and secondary standards. The primary standards are set to protect human health, and the secondary standards are set to protect environmental values, such as plant and animal life. The FCAA requires the EPA to set National Ambient Air Quality Standards for the six criteria air pollutants. These pollutants include particulate matter (PM), ground-level ozone, carbon monoxide (CO), sulfur oxides, nitrogen oxides, and lead.
Toxic Air Contaminants
A toxic air contaminant (TAC) is an air pollutant not included in the California Ambient Air Quality Standards, but TACs are considered hazardous to human health. Toxic air contaminants are defined by the California Air Resources Board (CARB) as those pollutants that, “may cause or contribute to an increase in deaths or in serious illness, or which may pose a present or potential hazard to human health.”
The health effects associated with TACs are generally assessed locally rather than regionally.
Toxic air contaminants can cause long-term health effects such as cancer, birth defects, neurological damage, asthma, bronchitis, or genetic damage; TACs can also cause short-term acute effects such as eye watering, respiratory irritation, running nose, throat pain, and headaches. For evaluation purposes, TACs are separated into carcinogens and noncarcinogens. Carcinogens are assumed to have no safe threshold below which health impacts would not occur, and the cancer risk is expressed as excess cancer cases per one million exposed individuals (typically over a lifetime of exposure).
TACs of concern assessed in this analysis include asbestos and DPM.
Sensitive Receptors
Some land uses are considered more sensitive to air pollution than others due to the types of population groups or activities involved. Heightened sensitivity may be caused by health problems, proximity to the emissions source, and/or duration of exposure to air pollutants.
Children, pregnant women, the elderly, and those with existing health problems are especially vulnerable to the effects of air pollution. Accordingly, land uses that are typically considered to be sensitive receptors include residences, schools, childcare centers, playgrounds, retirement homes, convalescent homes, hospitals, and medical clinics.
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Air Quality Standards
The Clean Air Act requires states to develop a general plan to attain and maintain the standards in all areas of the country and a specific plan to attain the standards for each area designated nonattainment. These plans, known as State Implementation Plans or SIPs, are developed by state and local air quality management agencies and submitted to EPA for approval.
The SIP for the State of California is administered by the CARB, which has overall responsibility for statewide air quality maintenance and air pollution prevention. California’s SIP incorporates individual federal attainment plans for each regional air district. SIPs are prepared by the regional air district and sent to CARB to be approved and incorporated into the California SIP.
Federal attainment plans include the technical foundation for understanding air quality (e.g., emission inventories and air quality monitoring), control measures and strategies, and enforcement mechanisms.
The CARB also administers the California Ambient Air Quality Standards (CAAQS) for the 10 air pollutants designated in the California Clean Air Act. The 10 state air pollutants include the six federal criteria pollutant standards listed above as well as visibility-reducing particulates, hydrogen sulfide, sulfates, and vinyl chloride. The federal and state ambient air quality standards are summarized in Table 5.
Table 5: California and National Ambient Air Quality Standards Pollutant Averaging Time
California Standards National Standards
Concentration Primary Secondary
Ozone
1 Hour 0.09 ppm (180 μg/m3) —
Same as
Primary Standard 8 Hour 0.070 ppm
(137 μg/m3)
0.070ppm
(137 μg/m3)
Respirable
Particulate
Matter
24 Hour 50 μg/m3 150 μg/m3
Same as
Primary Standard Annual
Arithmetic Mean 20 μg/m3 —
Fine
Particulate
Matter
24 Hour — 35 μg/m3
Same as
Primary Standard Annual
Arithmetic Mean 12 μg/m3 12 μg/m3
Carbon
Monoxide
1 Hour 20 ppm (23 mg/m3) 35 ppm (40 mg/m3) —
8 Hour 9.0 ppm (10 mg/m3) 9 ppm (10 mg/m3) —
8 Hour
(Lake Tahoe) 6 ppm (7 mg/m3) — —
Nitrogen
Dioxide
1 Hour 0.18 ppm (339 μg/m3) 100 ppb (188 μg/m3) —
Annual
Arithmetic Mean 0.030 ppm (57 μg/m3) 0.053 ppm
(100 μg/m3)
Same as
Primary Standard
Sulfur Dioxide
1 Hour 0.25 ppm (655 μg/m3) 75 ppb (196 μg/m3) —
3 Hour — — 0.5 ppm
(1300 μg/m3)
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Pollutant Averaging Time
California Standards National Standards
Concentration Primary Secondary
24 Hour 0.04 ppm (105 μg/m3) 0.14 ppm
(for certain areas) —
Annual
Arithmetic Mean — 0.030 ppm
(for certain areas) —
Lead
30-Day Average 1.5 μg/m3 — —
Calendar Quarter — 1.5 μg/m3
Same as
Primary Standard Rolling 3-Month
Average — 0.15 μg/m3
Visibility-
Reducing
Particles
8 Hour See Footnote 1
No National Standards
Sulfates 24 Hour 25 μg/m3
Hydrogen
Sulfide 1 Hour 0.03 ppm (42 μg/m3)
Vinyl
Chloride 24 Hour 0.01 ppm (26 μg/m3)
Notes:
1 - In 1989, the CARB converted both the general statewide 10-mile visibility standard and the Lake Tahoe 30-mile visibility standard to instrumental equivalents, which are "extinction of 0.23 per kilometer" and "extinction of 0.07 per kilometer" for the statewide and Lake Tahoe Air Basin standards, respectively. μg/m3 =micrograms per cubic meter
CARB = California Air Resources Board
mg/m3 = milligrams per cubic meter
ppm = parts per million
Source: California Air Resources Board (CARB). 2017. Air Quality Standards. Website: https://www.baaqmd.gov/about-air- quality/research-and-data/air-quality-standards-and-attainment-status. Accessed March 23, 2022.
The local air quality can be evaluated by reviewing relevant air pollution concentrations near the project area. Table 6 summarizes 2018 through 2020 published monitoring data, which is the most recent 3-year period available. The table displays data from the Clovis-N Villa Avenue station (located approximately 2.22 miles southwest of the project site). The data shows that during the past few years, the project area has exceeded the standards for ozone (state and national, PM10 (state and national), and PM2.5 (state and national). The data in the table reflects the concentration of the pollutants in the air, measured using air monitoring equipment. This differs from emissions, which are calculations of a pollutant being emitted over a certain period.
No recent monitoring data for Fresno County or the San Joaquin Valley Air Basin was available for CO or SO2. Generally, no monitoring is conducted for pollutants that are no longer likely to exceed ambient air quality standards.
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Table 6: Air Quality Monitoring Summary
Air Pollutant
Averaging
Time Item 2018 2019 2020
Ozone1 1 Hour Max 1 Hour (ppm) 0.121 0.103 0.142
Days > State Standard (0.09 ppm) 13 6 12
8 Hour Max 8 Hour (ppm) 0.095 0.080 0.108
Days > State Standard (0.07 ppm) 43 27 36
Days > National Standard (0.075 ppm) 23 10 23
Carbon
monoxide (CO)
8 Hour Max 8 Hour (ppm) ND ND ND
Days > State Standard (9.0 ppm) ND ND ND
Days > National Standard (9 ppm) ND ND ND
Nitrogen dioxide
(NO2)2
Annual Annual Average (ppm) 0.009 0.008 0.009
1 Hour Max 1 Hour (ppm) 0.0645 0.0572 0.0543
Days > State Standard (0.18 ppm) 0 0 0
Sulfur dioxide
(SO2)
Annual Annual Average (ppm) ND ND ND
24 Hour Max 24 Hour (ppm) ND ND ND
Days > State Standard (0.04 ppm) ND ND ND
Inhalable coarse
particles (PM10)1
Annual Annual Average (µg/m3) 39.6 32.6 50.8
24 Hour 24 Hour (µg/m3) 118.6 155.7 296.0
Days > State Standard (50 µg/m3) 90.4 65.9 117.5
Days > National Standard (150 µg/m3) 0.0 0.0 5.8
Fine particulate
matter (PM2.5)1
Annual Annual Average (µg/m3) 15.6 10.2 ID
State Standard (12 µg/m3) Exceeded? Yes No ID
24 Hour 24 Hour (µg/m3) 82.3 39.1 193.7
Days > National Standard (35 µg/m3) 26.0 ID 40.0
Notes:
> = exceed ppm = parts per million µg/m3 = micrograms per cubic meter ID = insufficient data ND = no data max = maximum
Bold = exceedance
State Standard = California Ambient Air Quality Standard National Standard = National Ambient Air Quality Standard 1 Clovis-N Villa Avenue
Source: California Air Resources Board (CARB). 2022. Trends Summary. Website:
https://www.arb.ca.gov/adam/trends/trends1.php. Accessed June 20, 2022. 2 Clovis-N Villa Avenue
Source: California Air Resources Board (CARB). 2022. Top 4 Summary: Select Pollutant, Years, & Area. Website:
https://www.arb.ca.gov/adam/topfour/topfour1.php. Accessed June 29, 2022.
The health impacts of the various air pollutants of concern can be presented in a number of ways. One method is to compare concentrations in an area with the applicable state and federal ozone standards. If concentrations are below the standard, it is reasonable to conclude that no significant health impacts would occur. When concentrations exceed the standard, impacts will vary based on the amount by which the standard is exceeded. The EPA developed the Air 15 420
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Quality Index (AQI) as an easy-to-understand measure of health impacts compared with concentrations in the air. Table 7 provides a description of the health impacts of ozone at different concentrations.
Table 7: Air Quality Index and Health Effects from Ozone Air Quality Index/
8-hour Ozone Concentration Health Effects Description
AQI 51–100—Moderate Sensitive Groups: Children and people with asthma are the groups most at risk.
Concentration 55–70 ppb Health Effects Statements: Unusually sensitive individuals may experience respiratory symptoms.
Cautionary Statements: Unusually sensitive people should consider limiting prolonged outdoor exertion.
AQI 101–150—Unhealthy for
Sensitive Groups
Sensitive Groups: Children and people with asthma are the groups most at risk.
Concentration 71–85 ppb Health Effects Statements: Increasing likelihood of respiratory symptoms and breathing discomfort in active children and adults and people with respiratory disease, such as asthma.
Cautionary Statements: Active children and adults, and people with respiratory disease, such as asthma, should limit prolonged outdoor exertion.
AQI 151–200—Unhealthy Sensitive Groups: Children and people with asthma are the groups most at risk.
Concentration 86–105 ppb Health Effects Statements: Greater likelihood of respiratory symptoms and breathing difficulty in active children and adults and people with respiratory disease, such as asthma; possible respiratory effects in general population.
Cautionary Statements: Active children and adults, and people with respiratory disease, such as asthma, should avoid prolonged outdoor exertion; everyone else, especially children, should limit prolonged outdoor exertion.
AQI 201–300—Very Unhealthy Sensitive Groups: Children and people with asthma are the groups most at risk.
Concentration 106–200 ppb Health Effects Statements: Increasingly severe symptoms and impaired breathing likely in active children and adults and people with respiratory disease, such as asthma; increasing likelihood of respiratory effects in general population.
Cautionary Statements: Active children and adults, and people with respiratory disease, such as asthma, should avoid all outdoor exertion; everyone else, especially children, should limit outdoor exertion.
Sources:
Air Now. 2022. AQI Calculator: AQI to Concentration. Website: https://www.airnow.gov/aqi/aqi-calculator/. Accessed May 31, 2022.
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U.S. Environment Protection Agency (EPA). 2018. Technical Assistance Document for the Reporting of Daily Air Quality – the Air Quality Index (AQI). September. Accessed June 27, 2022.
The AQI for the 8-hour ozone standard is based on the current NAAQS of 70 parts per billion (ppb). Based on the AQI scale for the 8-hour ozone standard, the project area experienced 106 days in the last three years that would have violated the 70-ppb standard. The highest reading was 108 ppb in 2020 (AQI 203—Very Unhealthy).
Another pollutant of concern due to associated health impacts is PM2.5. An AQI of 100 or lower is considered moderate and would be triggered by a 24-hour average concentration of 12.1 to 35.4 µg/m3. An AQI of 101 to 105 or 35.5-55.4 µg/m3 is considered unhealthful for sensitive groups.
When concentrations reach this amount, it is considered an exceedance of the federal PM2.5 standard. The monitoring station nearest the project (Clovis-N Villa Avenue) exceeded the standard on at least 66 days in the three-year period spanning from 2018 to 2020. The highest number of exceedances was recorded in 2020 with 40.0 days over the national 24-hour standard. People with respiratory or heart disease, the elderly, and children are the groups most at risk. Unusually sensitive people should consider reducing prolonged or heavy exertion. The AQI of 151 to 200 is classified as unhealthy for everyone. This AQI classification is triggered when PM2.5 concentration ranges from 55.4 to 150.4 µg/m3. At this concentration, there is increasing likelihood of respiratory symptoms in sensitive individuals, aggravation of heart or lung disease and premature mortality in persons with cardiopulmonary disease, and in the elderly.
People with respiratory or heart disease, the elderly, and children should limit prolonged exertion.
Everyone else should reduce prolonged or heavy exertion. The highest 24-hour concentration recorded at the Clovis-N Villa Avenue monitoring station in the most recent 3-year period available was 193.7 µg/m3 (AQI 244—Very Unhealthy) in 2020. At this concentration, there is increasingly severe symptoms and impaired breathing likely in active children and adults and people with respiratory disease, such as asthma; increasing likelihood of respiratory effects in general population. Sensitive groups and active individuals should avoid all physical activity outdoors, move activities indoors, or reschedule to a time when air quality is better. Everyone else should avoid prolonged or heavy exertion, consider moving activities indoors, or reschedule to a time when air quality is better. The relationship of the AQI to health effects in shown in Table
8. 17
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Table 8: Air Quality Index and Health Effects of Particle Pollution Air Quality Index/
PM2.5 Concentration Health Effects Description
AQI 51–100—Moderate Sensitive Groups: Some people who may be unusually sensitive to particle.
Concentration 12.1–35.4 µg/m3 Health Effects Statements: Unusually sensitive people should consider reducing prolonged or heavy exertion.
Cautionary Statements: Unusually sensitive people: Consider reducing prolonged or heavy exertion. Watch for symptoms such as coughing or shortness of breath. These are signs to take it easier.
AQI 101–150—Unhealthy for
Sensitive Groups
Sensitive Groups: Sensitive groups include people with heart or lung disease, older adults, children, and teenagers.
Concentration 35.5–55.4 µg/m2 Health Effects Statements: Increasing likelihood of respiratory symptoms in sensitive individuals, aggravation of heart or lung disease and premature mortality in persons with cardiopulmonary disease, and the elderly.
If you have heart disease: Symptoms such as palpitations, shortness of breath, or unusual fatigue may indicate a serious problem. If you have any of these, contact your health care provider.
AQI 151–200—Unhealthy Sensitive Groups: Everyone
Concentration 55.5–150.4 µg/m3 Health Effects Statements: Increased aggravation of heart or lung disease and premature mortality in persons with cardiopulmonary disease and the elderly; increased respiratory effects in general population.
Cautionary Statements: Sensitive groups: Avoid prolonged or heavy exertion. Consider moving activities indoors or rescheduling. Everyone else: Reduce prolonged or heavy exertion. Take more breaks during outdoor activities.
AQI 201–300—Very Unhealthy Sensitive Groups: Everyone
Concentration 150.5–250.4 µg/m3 Health Effects Statements: Significant aggravation of heart or lung disease and premature mortality in persons with cardiopulmonary disease and the elderly; significant increase in respiratory effects in general population.
Cautionary Statements: Sensitive groups: Avoid all physical activity outdoors. Move activities indoors or reschedule to a time when air quality is better. Everyone else: Avoid prolonged or heavy exertion. Consider moving activities indoors or rescheduling to a time when air quality is better.
Source: Air Now. 2016. AQI Calculator: AQI to Concentration. Website: https://www.airnow.gov/aqi/aqi-calculator/. Accessed March 23, 2022 and June 20, 2022.
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Federal and state air quality laws require identification of areas not meeting the ambient air quality standards. These areas must develop regional air quality plans to eventually attain the standards. The SJV Air Basin is designated nonattainment for ozone, PM10, and PM2.5.5 Thresholds of Significance
Project-level Thresholds
The CEQA Guidelines define a significant effect on the environment as “a substantial, or potentially substantial, adverse change in the environment.” To determine if a project would have a significant impact on air quality, the type, level, and impact of emissions generated by the proposed project must be evaluated.
This analysis uses the air quality significance thresholds contained in Appendix G of the CEQA Guidelines, effective December 28, 2018. A significant impact would occur if the proposed project would:
a) Conflict with or obstruct implementation of the applicable air quality plan. b) 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 ambient air quality standard.
c) Expose sensitive receptors to substantial pollutant concentrations. d) Create objectionable odors affecting a substantial number of people.
The City of Clovis has not established specific CEQA significance thresholds. Where available guidance provided by the applicable air district can be used to make significance determinations for the CEQA questions listed above. While the final determination of whether a project is significant is within the purview of the Lead Agency pursuant to Section 15064(b) of the CEQA Guidelines, the SJVAPCD recommends that its quantitative air pollution thresholds be used to determine the significance of project emissions in accordance with the Appendix G requirements. If a Lead Agency finds that a project has the potential to exceed these air pollution thresholds, according to the SJVAPCD, the project should be considered to have significant air quality impacts.
Air pollutant emissions have regional effects and localized effects. This analysis assesses the regional effects of the project’s criteria pollutant emissions in comparison to SJVAPCD thresholds of significance for short-term construction activities and long-term operation of the project. Localized emissions from project construction and operation are also assessed using concentration-based thresholds that determine if the project would result in a localized exceedance of any ambient air quality standards or would make a cumulatively considerable contribution to an existing exceedance.
5 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2017. Ambient Air Quality Standards & Valley Attainment Status.
Website: https://www.valleyair.org/aqinfo/attainment.htm. Accessed May 20, 2022. 19 424
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The primary pollutants of concern during project construction and operation are ROG, NOX, PM10, and PM2.5. The SJVAPCD GAMAQI adopted in 2015 contains thresholds for ROG and NOX; SOX, CO, PM10, and PM2.5.
Ozone is a secondary pollutant that can be formed miles away from the source of emissions through reactions of ROG and NOX emissions in the presence of sunlight. Therefore, ROG and NOX are termed ozone precursors. The SJVAB often exceeds the state and national ozone standards. Therefore, if the project emits a substantial quantity of ozone precursors, the project may contribute to an exceedance of the ozone standard. The SJVAB also exceeds air quality standards for PM10, and PM2.5; therefore, substantial project emissions may contribute to an exceedance for these pollutants.
The SJVAPCD has adopted significance thresholds for construction-related and operational emissions. These thresholds will be identified and addressed in the appropriate section of this document.
Project construction would involve the use of diesel-fueled vehicles and equipment that emit DPM, which is considered a TAC. Once operational, a limited number of diesel-fueled vehicles would access the project site. The following project-specific health risk significance thresholds are applied in this analysis:
• Maximum Incremental Cancer Risk: >=20 in 1 million.
• Hazard Index (project increment) >=1.0.
Fugitive Dust
Construction
Fugitive dust would be generated from site grading and other earth-moving activities. Most of this fugitive dust would remain localized and would be deposited near the project site. However, the potential for impacts from fugitive dust exists unless control measures are implemented to reduce the emissions from the project site. Therefore, adherence to Regulation VIII would be required during construction of the proposed project. Regulation VIII would require fugitive dust control measures that are consistent with best management practices (BMPs) established by the SJVAPCD to reduce the proposed project’s construction-generated fugitive dust impacts to a less than significant level.
The SJVAPCD (SJVAPCD or District) adopted Regulation VIII in 1993 and its most recent amendments became effective on October 1, 2004. This is a basic summary of the regulation’s requirements as they apply to construction sites. These regulations affect all workers at a regulated construction site, including everyone from the landowner to the subcontractors.
Violations of Regulation VIII are subject to enforcement action including fines.6 Visible Dust Emissions may not exceed 20 percent opacity during periods when soil is being disturbed by equipment or by wind at any time. Visible Dust Emissions opacity of 20 percent
6 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2007. Compliance Assistance Bulletin. Website:
http://www.valleyair.org/busind/comply/pm10/forms/RegVIIICAB.pdf. Accessed May 29, 2021. 20 425
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means dust that would obstruct an observer’s view of an object by 20 percent. District inspectors are state certified to evaluate visible emissions. Dust control may be achieved by applying water before/during earthwork and onto unpaved traffic areas, phasing work to limit dust, and setting up wind fences to limit windblown dust.
Soil Stabilization is required at regulated construction sites after normal working hours and on weekends and holidays. This requirement also applies to inactive construction areas such as phased projects where disturbed land is left unattended. Applying water to form a visible crust on the soil and restricting vehicle access are often effective for short-term stabilization of disturbed surface areas. Long-term methods including applying dust suppressants and establishing vegetative cover.
Carryout and Trackout occur when materials from emptied or loaded vehicles falls onto a paved surface or shoulder of a public road or when materials adhere to vehicle tires and are deposited onto a paved surface or shoulder of a public road. Should either occur, the material must be cleaned up at least daily, and immediately if it extends more than 50 feet from the exit point onto a paved road. The appropriate clean-up methods require the complete removal and cleanup of mud and dirt from the paved surface and shoulder. Using a blower device or dry sweeping with any mechanical device other than a PM10-efficient street sweeper is a violation.
Larger construction sites, or sites with a high amount of traffic on one or more days, must prevent carryout and trackout from occurring by installing gravel pads, grizzlies, wheel washers, paved interior roads, or a combination thereof at each exit point from the site. In many cases, cleaning up trackout with water is also prohibited as it may lead to plugged storm drains.
Prevention is the best method.
Unpaved Access and Haul Roads, as well as unpaved vehicle and equipment traffic areas at construction sites must have dust control. Speed limit signs limiting vehicle speed to 15 mph or less at construction sites must be posted every 500 feet on uncontrolled and unpaved roads.
Storage Piles and Bulk Materials have handling, storage, and transportation requirements that include applying water when handling materials, wetting or covering stored materials, and installing wind barriers to limit visible dust emissions. Also, limiting vehicle speeds, loading haul trucks with a freeboard of six inches or greater along with applying water to the top of the load, and covering the cargo compartments are effective measures for reducing visible dust emissions and carryout from vehicles transporting bulk materials.
Dust Control Plans identify the dust sources and describe the dust control measures that will be implemented before, during, and after any dust generating activity for the duration of the project. Owners or operators are required to submit plans to the SJVAPCD at least 30 days prior to commencing the work for the following:
• Residential developments of ten or more acres of disturbed surface area. • Non-residential developments of five or more acres of disturbed surface area. • The relocation of more than 2,500 cubic yards per day of materials on at least three days.
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Operations may not commence until the SJAVPCD has approved the Dust Control Plan. A copy of the plan must be on site and available to workers and District employees. All work on the site is subject to the requirements of the approved dust control plan. A failure to abide by the plan by anyone on site may be subject to enforcement action.
Record Keeping is required to document compliance with the rules and must be kept for each day any dust control measure is used. The SJVAPCD has developed record forms for water application, street sweeping, and “permanent” controls such as applying long term dust palliatives, vegetation, ground cover materials, paving, or other durable materials. Records must be kept for one year after the end of dust generating activities (Title V sources must keep records for five years).
Exemptions exist for several activities. Those occurring above 3,000 feet in elevation are exempt from all Regulation VIII requirements. Further, Rule 8021 – Construction, Demolition, Excavation, Extraction, and Other Earthmoving Activities exempts the following construction and earthmoving activities:
• Blasting activities permitted by California Division of Industrial Safety. • Maintenance or remodeling of existing buildings provided the addition is less than 50% of the size of the existing building or less than 10,000 square feet (due to asbestos concerns, contact the SJVAPCD at least two weeks ahead of time). • Additions to single family dwellings.
• The disking of weeds and vegetation for fire prevention on sites smaller than ½ acre. • Spreading of daily landfill cover to preserve public health and safety and to comply with California Integrated Waste Management Board requirements.
Nuisances are prohibited at all times because District Rule 4102 – Nuisance applies to all construction sources of fugitive dust, whether or not they are exempt from Regulation VIII. It is important to monitor dust-generating activities and implement appropriate dust control measures to limit the public’s exposure to fugitive dust.
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Environmental Impact Analysis
This section discusses potential impacts related to air quality associated with the proposed project and provides mitigation measures where necessary.
Impact AIR-1 Conflict with or obstruct implementation of the applicable air quality plan? Impact Analysis
The CEQA Guidelines indicate that a significant impact would occur if the project would conflict with or obstruct implementation of the applicable air quality plan. The GAMAQI indicates that projects that do not exceed SJVAPCD regional criteria pollutant emissions quantitative thresholds would not conflict with or obstruct the applicable air quality plan (AQP). An additional criterion regarding the project’s implementation of control measures was assessed to provide further evidence of the project’s consistency with current AQPs. This document proposes the following criteria for determining project consistency with the current AQPs:
1. Will the project result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations, or delay timely attainment of air quality standards or the interim emission reductions specified in the AQPs? This measure is determined by comparison to the regional and localized thresholds identified by the District for Regional and Local Air Pollutants.
2. Will the project comply with applicable control measures in the AQPs?
Contribution to Air Quality Violations
A measure for determining if the project is consistent with the air quality plans is if the project would not result in an increase in the frequency or severity of existing air quality violations, cause or contribute to new violations, or delay timely attainment of air quality standards or the interim emission reductions specified in the air quality plans. Regional air quality impacts and attainment of standards are the result of the cumulative impacts of all emission sources within the air basin. Individual projects are generally not large enough to contribute measurably to an existing violation of air quality standards. Therefore, the cumulative impact of the project is based on its cumulative contribution. Because of the region’s nonattainment status for ozone, PM2.5, and PM10—if project-generated emissions of either of the ozone precursor pollutants (ROG and NOX), PM10, or PM2.5 would exceed the SJVAPCD’s significance thresholds—then the project would be considered to contribute to violations of the applicable standards and conflict with the attainment plans.
As shown in Table 9 and Table 10 under Impact AIR-2 below, the project’s construction and operational regional emissions would not exceed SJVAPCD’s regional criteria pollutant emissions quantitative thresholds. Therefore, the proposed project would not be considered in conflict with or obstruct implementation of the applicable air quality plan based on this criterion.
Compliance with Applicable Control Measures
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SJVAPCD’s AQPs contain a number of control measures, which are enforceable requirements through the adoption of rules and regulations. A description of rules and regulations that apply to this project is provided below.
Other control measures that apply to the project are Rule 4641—Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operation that requires reductions in VOC emissions during paving and Rule 4601—Architectural Coatings that limits the VOC content of all types of paints and coatings sold in the San Joaquin Valley. These measures apply at the point of sale of the asphalt and the coatings, so project compliance is ensured without additional mitigation measures. Other control measures that may apply include:
SJVAPCD Rule 9510—Indirect Source Review (ISR) is a control measure in the 2006 PM10 Plan that requires NOX and PM10 emission reductions from development projects in the San Joaquin Valley. The NOX emission reductions help reduce the secondary formation of PM10 in the atmosphere (primarily ammonium nitrate and ammonium sulfate) and also reduce the formation of ozone. Reductions in directly emitted PM10 reduce particles such as dust, soot, and aerosols. Rule 9510 is also a control measure in the 2016 Plan for the 2008 8-Hour Ozone Standard. Developers of projects subject to Rule 9510 must reduce emissions occurring during construction and operational phases through on-site measures, or pay off-site mitigation fees. The proposed project would not be subject to Rule 9510 based on the project’s size (12 dwelling units) unless the project is subject due to being a portion of a larger project.
Regulation VIII—Fugitive PM10 Prohibitions is a control measure that is one main strategies from the 2006 PM10 for reducing the PM10 emissions that are part of fugitive dust. Residential projects over 10 acres and non‐residential projects over 5 acres are required to file a Dust Control Plan (DCP) containing dust control practices sufficient to comply with Regulation VIII. In addition, projects that would move, deposit, or relation more than 2,500 cubic yards per day of bilk material on at least three days of the project would also be required to file a DCP. Projects not requiring a DCP will be required to submit a Construction Notification to the SJVAPCD.
The project would comply with all applicable SJVAPCD rules and regulations. Therefore, the proposed project would not conflict with or obstruct implementation of the applicable air quality attainment plan under this criterion.
Conclusion
As described above, the proposed project’s construction and operational regional emissions would not exceed SJVAPCD’s regional criteria pollutant emissions quantitative thresholds.
Furthermore, the proposed project would comply with all applicable SJVAPCD rules and regulations. Accordingly, the proposed project would not conflict with or obstruct implementation of the applicable air quality plans, and, therefore, this impact would be less than significant.
Level of Significance Before Mitigation
Less than significant.
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Mitigation Measures
No mitigation measures are necessary.
Impact AIR-2 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 ambient air quality standard?
Impact Analysis
To result in a less than significant impact, the following criteria must be true:
1. Regional analysis: emissions of nonattainment pollutants must be below the SJVAPCD’s regional significance thresholds. This is an approach recommended by the District in its GAMAQI.
2. Summary of projections: the project must be consistent with current air quality attainment plans including control measures and regulations. This is an approach consistent with Section 15130(b) of the CEQA Guidelines.
3. Cumulative health impacts: the project must result in less than significant cumulative health effects from the nonattainment pollutants. This approach correlates the significance of the regional analysis with health effects, consistent with the court decision, Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184, 1219-20.
Regional Emissions
Air pollutant emissions have both regional and localized effects. This analysis assesses the regional effects of the project’s criteria pollutant emissions in comparison to SJVAPCD thresholds of significance for short-term construction activities and long-term operation of the project. Localized emissions from project construction and operation are assessed under Impact AIR-3—Sensitive Receptors using concentration-based thresholds that determine if the project would result in a localized exceedance of any ambient air quality standards or would make a cumulatively considerable contribution to an existing exceedance.
The primary pollutants of concern during project construction and operation are ROG, NOX, PM10, and PM2.5. The SJVAPCD GAMAQI adopted in 2015 contains thresholds for CO, NOX, ROG, SOX, PM10, and PM2.5.
Ozone is a secondary pollutant that can be formed miles from the source of emissions, through reactions of ROG and NOX emissions in the presence of sunlight. Therefore, ROG and NOX are termed ozone precursors. The Air Basin often exceeds the state and national ozone standards.
Therefore, if the project emits a substantial quantity of ozone precursors, the project may contribute to an exceedance of the ozone standard. The Air Basin also exceeds air quality standards for PM10, and PM2.5; therefore, substantial project emissions may contribute to an exceedance for these pollutants. The SJVAPCD’s annual emission significance thresholds used 25 430
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for the project define the substantial contribution for both operational and construction emissions as follows:
• 100 tons per year CO
• 10 tons per year NOX
• 10 tons per year ROG
• 27 tons per year SOX
• 15 tons per year PM10
• 15 tons per year PM2.5
The project does not contain sources that would produce substantial quantities of SO2 emissions during construction and operation. Modeling conducted for the project show that SO2 emissions are well below the SJVAPCD GAMAQI thresholds, as shown in the modeling results contained in Attachment A. No further discussion of SO2 is required.
Construction Emissions
Construction activities associated with development of the proposed project would include site preparation, grading, building construction, paving, and architectural coatings. Emissions from construction-related activities are generally short-term in duration but may still cause adverse air quality impacts. During construction, fugitive dust would be generated from earth-moving activities. Exhaust emissions would also be generated from off-road construction equipment and construction-related vehicle trips. Emissions associated with construction of the proposed project are discussed below.
Table 9 provides the construction emissions estimate for the proposed project. Please refer to the Modeling Parameters and Assumptions section of this technical memorandum for details regarding assumptions used to estimate construction emissions. The duration of construction activity and associated equipment represent a reasonable approximation of the expected construction fleet as required pursuant to CEQA guidelines.
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Table 9: Construction Annual Emissions (Unmitigated)
Parameter
Air Pollutants
ROG NOX CO PM10 PM2.5
2023
Demolition 0.015 0.151 0.139 0.014 0.008
Site Preparation 0.001 0.013 0.007 0.003 0.002
Grading 0.003 0.045 0.021 0.010 0.005
Paving 0.004 0.033 0.046 0.002 0.002
Building Construction 0.131 0.996 1.080 0.051 0.044
2023 Subtotal 0.154 1.238 1.293 0.081 0.060
2024
Building Construction 0.023 0.180 0.205 0.009 0.007
Architectural Coating 0.059 0.006 0.010 0.000 0.000
2024 Subtotal 0.082 0.186 0.215 0.009 0.008
Total Emissions from All Construction Activities (2023-2024) Total Project Construction
Emissions (tons/year) 0.24 1.42 1.51 0.09 0.07
Significance Threshold
(tons/year) 10 10 100 15 15
Exceeds Significance
Threshold? No No No No No
Notes:
Calculations (including totals) use unrounded results; totals in the summary table may not appear to sum exactly due to rounding.
PM10 and PM2.5 emissions are from the mitigated output to reflect compliance with Regulation VIII—Fugitive PM10 Prohibitions.
NOX = oxides of nitrogen
PM10 = particulate matter 10 microns in diameter
PM2.5 = particulate matter 2.5 microns in diameter
ROG = reactive organic gases
Source: CalEEMod Output (Attachment A).
As shown in Table 9, estimated emissions from construction of project are below the SJVAPCD significance thresholds. Therefore, the regional construction emissions would be less than significant on a project basis.
Operational Emissions
As previously discussed, the pollutants of concern include ROG, NOX, CO, PM10, and PM2.5.
Emissions were assessed for full buildout operations in the 2023 operational year. The 2023 operational year was chosen as it would be the best representation of the project as it is year earliest year the project could become operational. Emissions were estimated assuming full 27 432
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buildout in the earliest year of operations, thus generating the full amount of expected operational activity. The SJVAPCD Criteria Air Pollutant Significance thresholds were used to determine impacts. Operational annual emissions are shown in Table 10 below.
Table 10: Operational Annual Emissions for Full Buildout (Unmitigated) Emissions Source
Tons per Year
ROG NOX CO SOX PM10 PM2.5
Area 0.077 0.006 0.091 < 0.001 0.001 0.001
Energy Consumption 0.001 0.008 0.003 < 0.001 0.001 0.001 Mobile (On-road Vehicles) 0.029 0.053 0.336 0.001 0.096 0.026 Total Project Annual
Emissions 0.11 0.07 0.43 < 0.01 0.10 0.03
Thresholds of Significance 10 10 100 27 15 15
Exceeds Significance
Threshold? No No No No No No
Notes:
Totals in the summary table may not appear to sum exactly due to rounding.
NOX = oxides of nitrogen
PM2.5 = particulate matter 2.5 microns or less in diameter PM10 = particulate matter 10 microns or less in diameter ROG = reactive organic gases
Source: CalEEMod Output (Attachment A).
As shown in Table 10, the proposed project would not result in net operational-related air pollutants or precursors that would exceed the applicable thresholds of significance. Therefore, project operations would not be considered to have the potential to generate a significant quantity of air pollutants; long-term operational impacts associated with the project’s criteria pollutant emissions would be less than significant.
Level of Significance Before Mitigation
Less than significant.
Mitigation Measures
No mitigation measures are necessary.
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Impact AIR-3 Expose sensitive receptors to substantial pollutant concentrations? Impact Analysis
Emissions occurring at or near the project have the potential to create a localized impact that could expose sensitive receptors to substantial pollutant concentrations. Sensitive receptors are considered land uses or other types of population groups that are more sensitive to air pollution than others due to their exposure. Sensitive population groups include children, the elderly, the acutely and chronically ill, and those with cardio-respiratory diseases. The SJVAPCD considers a sensitive receptor to be a location that houses or attracts children, the elderly, people with illnesses, or others who are especially sensitive to the effects of air pollutants. Examples of sensitive receptors include hospitals, residences, convalescent facilities, and schools.
The closest existing sensitive receptors (to the project site) are residences located directly adjacent to the project site. Any residential uses currently occupying the project site would not be exposed to emissions from the proposed project, as the existing buildings occupying the project site would be demolished to make way for the proposed development.
Localized Impacts
Emissions occurring at or near the project have the potential to create a localized impact also referred to as an air pollutant hotspot. Localized emissions are considered significant if when combined with background emissions, they would result in exceedance of any health-based air quality standard. In locations that already exceed standards for these pollutants, significance is based on a significant impact level (SIL) that represents the amount that is considered a cumulatively considerable contribution to an existing violation of an air quality standard. The pollutants of concern for localized impact in the SJVAB are NO2, SOX, and CO.
The SJVAPCD has provided guidance for screening localized impacts in the GAMAQI that establishes a screening threshold of 100 pounds per day of any criteria pollutant. If a project exceeds 100 pounds per day of any criteria pollutant, then ambient air quality modeling would be necessary. If the project does not exceed 100 pounds per day of any criteria pollutant, then it can be assumed that it would not cause a violation of an ambient air quality standard.
Construction: Localized Concentrations of PM10, PM2.5, CO, and NOX Local construction impacts would be short-term in nature lasting only during the duration of construction (anticipated to last 4-6 months for the proposed project). As shown in Table 11 below, on-site construction emissions would be less than 100 pounds per day for each of the criteria pollutants. To present a conservative estimate, on-site emissions for on-road construction vehicles were included in the localized analysis. Based on the SJVAPCD’s guidance, the construction emissions would not cause an ambient air quality standard violation. 29 434
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Table 11: Localized Concentrations of PM10, PM2.5, CO, and NOX for Construction Source
On-site Emissions (pounds per day)
ROG NOX CO PM10 PM2.5
Entire Project Construction Duration (2023-2024)
Maximum Daily
Construction (2023) 3.55 27.04 29.22 3.85 2.11
Maximum Daily
Construction (2024) 11.79 25.55 29.00 1.05 1.00
Maximum Daily On-
site Emissions 11.79 27.04 29.22 3.85 2.11
Significance
Thresholds — 100 100 100 100
Exceed Significance
Thresholds? — No No No No
Note: Overlap of construction activities is based on the construction schedule shown in Table 1 and Attachment A.
Source of Emissions: CalEEMod Output and Additional Supporting Information (Attachment A). Maximum daily emissions of NOX, CO, PM10, and PM2.5 were highest in the Winter scenario, while maximum daily emissions of ROG were highest in the Summer scenario.
Source of Thresholds: San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015. Guidance for Assessing and Mitigating Air Quality Impacts. February 19. Website: https://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT-GAMAQI.PDF.
Accessed May 20, 2022.
Operation: Localized Concentrations of PM10, PM2.5, CO, and NOX Localized impacts could occur in areas with a single large source of emissions, such as a power plant, or at locations with multiple sources concentrated in a small area, such as a distribution center. Although residential developments are typically less likely to cause a localized air quality impact compared to land uses with large sources of emissions or multiple concentrated sources of emissions, the proposed project would emit air pollutants that have the potential to create a localized impact. The maximum daily operational emissions would occur at project buildout, which was assumed to occur in 2023 to provide a conservative estimate of emissions.
Operational emissions include those generated on-site by area sources such as consumer products, and landscape maintenance, energy use from natural gas combustion, and motor vehicles operation at the project site. To assess localized air impacts, motor vehicle emissions were estimated for on-site operations using trip lengths for on-site travel. The trip lengths used to analyze on-site emissions was selected by measuring possible on-site paths using Google Earth; the length for the longest measured route for the appropriate vehicle type was selected to present a conservative estimate of on-site emissions. To account for localized emissions around the roadways adjacent to the project site, the trip length also included an additional 0.25 mile to account for localized off-site emissions.
As shown in Table 12 below, operational modeling of on-site emissions for the project indicate that the project would not exceed 100 pounds per day for each of the criteria pollutants.
Therefore, based on the SJVAPCD’s guidance, the operational emissions would not cause an ambient air quality standard violation. As such, impacts would be less than significant. 30 435
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Table 12: Localized Concentrations of PM10, PM2.5, CO, and NOX for Operations Source
On-site Emissions (pounds per day)
ROG NOX CO PM10 PM2.5
Area 0.45 0.12 1.03 0.01 0.01
Energy 0.00 0.04 0.02 0.00 0.00
Mobile (On-road
Vehicles) 0.19 0.11 0.72 0.03 0.01
Project Total 0.64 0.27 1.77 0.05 0.03
Significance
Thresholds — 100 100 100 100
Exceed
Significance
Thresholds?
— No No No No
Source of Emissions: CalEEMod Output and Additional Supporting Information (Attachment A). Maximum daily emissions of ROG were highest in the Summer scenario, while maximum daily emissions of NOX, CO, PM10, and PM2.5 were highest in the Winter scenario.
Source of Thresholds: San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015. Guidance for Assessing and Mitigating Air Quality Impacts. February 19. Website: https://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT-GAMAQI.PDF.
Accessed May 20, 2022.
Toxic Air Contaminants
Construction
Project construction would involve the use of diesel-fueled vehicles and equipment that emit DPM, which is considered a TAC. The SJVAPCD’s current threshold of significance for TAC emissions is an increase in cancer risk for the maximally exposed individual of 20 in a million (formerly 10 in a million).
A project-level assessment was conducted of the potential community health risk and health hazard impacts on surrounding sensitive receptors resulting from the emissions of TACs during construction. A summary of the assessment is provided below, while the detailed assessment is provided in Attachment B.
Construction activity using diesel-powered equipment emits DPM, a known carcinogen. Diesel particulate matter includes exhaust PM10 and exhaust PM2.5. A 10-year research program demonstrated that DPM from diesel-fueled engines is a human carcinogen and that chronic (long-term) inhalation exposure to DPM poses a chronic health risk.7 Health risks from TACs are a function of both concentration and duration of exposure. Construction diesel emissions are temporary, affecting an area for a period of weeks or months. Additionally, construction-related sources are mobile and transient in nature.
7 California Air Resources Board (CARB). 2015. The Report on Diesel Exhaust. Website:
https://ww2.arb.ca.gov/sites/default/files/classic/toxics/dieseltac/de-fnds.htm. Accessed October 8, 2021. 31 436
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The health risk assessment evaluated DPM (represented as exhaust PM10) emissions generated during construction of the proposed project and the related health risk impacts for sensitive receptors located within 1,000 feet of the project boundary.
The project site is located within 1,000 feet of existing sensitive receptors that could be exposed to diesel emission exhaust during the construction period. To estimate the potential cancer risk associated with construction of the proposed project from equipment exhaust (including DPM), a dispersion model was used to translate an emission rate from the source location to concentrations at the receptor locations of interest (i.e., receptors at nearby residences). A maximally exposed receptor (MER) was determined for construction of the project for off-site receptors and future residential receptors through the use of the dispersion modeling. Risks from all phases of construction were calculated for the MER location identified in each scenario.
Table 13 presents a summary of the proposed project’s construction cancer risk and chronic non-cancer hazard impacts at the MER from project construction prior to the application of any equipment mitigation. It should be noted that the assumptions that were used to estimate the potential risk of harm to public health are based on methods consistent with published OEHHA guidance and err on the side of health protection to avoid underestimation of risk.
Table 13: Unmitigated Health Risks from Project Construction to Off-Site Receptors Scenario Health Impact Metric
Carcinogenic
Inhalation
Health Risk
in One
Million
Chronic
Inhalation
Hazard
Index2
Risks and Hazards from Project Construction to the Off-site MER1 Total project
construction
Risks and Hazards at the MER: Infants 19.76 0.113
Risks and Hazards at the MER: Child 7.13 0.113
Risks and Hazards at the MER: Adult 0.68 0.113
Highest From Any Scenario
Total project
construction
Risks and Hazards at the MER (Infant
Scenario) 19.76 0.113
Applicable Threshold of Significance 20 1
Exceeds Individual Source Threshold? No No
Notes:
MER = Maximally Exposed Receptor
1 UTM for Off-site MER: 260169.13, 4081070.1
2 Chronic non-cancer hazard index was estimated by dividing the annual DPM concentration (as PM10 exhaust) by the REL of 5 μg/m3.
Source: Attachment B.
As shown in Table 13, estimated health risks from elevated DPM concentrations during construction of the proposed project would not exceed the cancer risk significance threshold or non-cancer hazard index significance threshold at the MER. Therefore, the proposed project would not result in a significant impact on nearby sensitive receptors from TACs during construction.
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Operations
The proposed project would develop a multifamily residential apartment complex consisting of 12 dwelling units and would not generate substantial on-site TAC emissions during operation.
Residential uses and on-site operational activities are not typically associated with the generation of TAC emissions; however a screening analysis was performed to assess potential impacts.
Operational DPM
The proposed project would primarily generate trips associated with residents and visitors traveling to and from the project site. The daily travel trips to and from the project site would primarily be generated by passenger vehicles. Because nearly all passenger vehicles are gasoline-combusted, the proposed project would not generate significant amount of DPM emissions during operation. Therefore, the proposed project would not result in significant health impacts to nearby sensitive receptors from emissions project-generated trips during operation.
Unlike warehouses or distribution centers, the daily vehicle trips generated by the proposed 12- unit residential project would be primarily generated by passenger vehicles. Passenger vehicles typically use gasoline engines rather than the diesel engines that are found in heavy-duty trucks. Gasoline-powered vehicles do emit TACs in the form of toxic organic gases, some of which are carcinogenic. Compared to the combustion of diesel, the combustion of gasoline has relatively low emissions of TACs. Thus, residential projects produce limited amounts of TAC emissions during operation.
Diesel truck trips could be generated by the project, such as in the form of delivery vehicles, trash pickups, tree trimming services, owner-operator tractors. For the purpose of estimating emissions for project buildout operations, the analysis used the SJVAPCD’s approved residential fleet mix for the 2023 year. This fleet mix assumes a lower amount of heavy-heavy- duty truck trips compared to the default value for Fresno County. Operational DPM emissions from diesel trucks were estimated using EMFAC 2017 emission factors and estimated truck travel and idling at the project site. The emissions were entered into the SJVAPCD Prioritization Screening Tool to determine the risk scores, with complete calculations and assumptions included as part of Attachment C. The results of the screening analysis are provided in Table
14. Table 14: Prioritization Tool Health Risk Screening Results (Operational DPM Emissions) Impact Source Cancer Risk Score Chronic Risk Score Acute Risk Score On-site Diesel Trucks during
Project Operations 0.085 0.004 0.000
Total Risk from Project
Operations 0.085 0.004 0.000
Screening Risk Score
Threshold 10 1 1
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Screening Thresholds
Exceeded? No No No
Source: Attachment C – Operational Health Risk Screening and Additional Supporting Information
As shown in Table 14, the project would not exceed the applicable screening levels. The primary source of the emissions responsible for chronic risk are from diesel trucks. DPM does not have an acute risk factor. Since the project does not exceed the applicable SJVAPCD screening risk thresholds for cancer risk, acute risk, or chronic risk, the impact related to the project’s potential to expose sensitive receptors to substantial pollutant concentrations from project operations would be less than significant.
Operations—The Project’s Potential to Locate Sensitive Receptor Near Existing Sources of TACs
The proposed project would develop approximately 1.04 acres with multi-family residential uses.
As the proposed project includes the development of residential uses, the project would locate new sensitive receptors that could be subject to existing sources of TACs at the project site.
However, the California Supreme Court concluded in California Building Industry Association v.
BAAQMD that agencies subject to CEQA are not required to analyze the impact of existing environmental conditions on a project’s future users or residents. This impact will not be further addressed in this document.
Valley Fever
Valley fever, or coccidioidomycosis, is an infection caused by inhalation of the spores of the fungus, Coccidioides immitis (C. immitis). The spores live in soil and can live for an extended time in harsh environmental conditions. Activities or conditions that increase the amount of fugitive dust contribute to greater exposure, and they include dust storms, grading, and recreational off-road activities.
The San Joaquin Valley is considered an endemic area for Valley fever. The San Joaquin Valley is considered an endemic area for Valley fever. During 2000–2018, a total of 65,438 coccidioidomycosis cases were reported in California; median statewide annual incidence was
7.9 per 100,000 population and varied by region from 1.1 in Northern and Eastern California to
90.6 in the Southern San Joaquin Valley, with the largest increase (15‐fold) occurring in the Northern San Joaquin Valley. Incidence has been consistently high in six counties in the Southern San Joaquin Valley (Fresno, Kern, Kings, Madera, Tulare, and Merced counties) and Central Coast (San Luis Obispo County) regions.8 California experienced 7,392 new probable or confirmed cases of Valley fever in 2020. A total of 448 confirmed or probable Valley fever cases were reported in Fresno County in 2020.9
8 Centers for Disease Control and Prevention (CDC). 2020. Regional Analysis of Coccidioidomycosis Incidence—California, 2000–2018. Website: https://www.cdc.gov/mmwr/volumes/69/wr/mm6948a4.htm?s_cid=mm6948a4_e. Accessed May 20, 2022.
9 California Department of Public Health (CDPH). 2021. Coccidioidomycosis in California Provisional Monthly Report January 2021. Website: https://www.cdph.ca.gov/Programs/CID/DCDC/CDPH%20Document%20Library/CocciinCA ProvisionalMonthlyReport.pdf. Accessed May 20, 2022.
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The distribution of C. immitis within endemic areas is not uniform and growth sites are commonly small (a few tens of meters) and widely scattered. Known sites appear to have some ecological factors in common suggesting that certain physical, chemical, and biological conditions are more favorable for C. immitis growth. Avoidance, when possible, of sites favorable for the occurrence of C. immitis is a prudent risk management strategy. Listed below are ecologic factors and sites favorable for the occurrence of C. immitis:
1) Rodent burrows (often a favorable site for C. immitis, perhaps because temperatures are more moderate and humidity higher than on the ground surface)
2) Old (prehistoric) Indian campsites near fire pits
3) Areas with sparse vegetation and alkaline soils
4) Areas with high salinity soils
5) Areas adjacent to arroyos (where residual moisture may be available)
6) Packrat middens
7) Upper 30 centimeters of the soil horizon, especially in virgin undisturbed soils
8) Sandy, well-aerated soil with relatively high water-holding capacities
Sites within endemic areas less favorable for the occurrence of C. immitis include:
1) Cultivated fields
2) Heavily vegetated areas (e.g., grassy lawns)
3) Higher elevations (above 7,000 feet)
4) Areas where commercial fertilizers (e.g., ammonium sulfate) have been applied
5) Areas that are continually wet
6) Paved (asphalt or concrete) or oiled areas
7) Soils containing abundant microorganisms
8) Heavily urbanized areas where there is little undisturbed virgin soil.10
The project is situated on a site previously disturbed that does not provide a suitable habitat for spores. Specifically, the project site is currently occupied with an existing residence and associated paving, landscaping, and outbuildings. Therefore, implementation of the proposed project would have a low probability of the site having C. immitis growth sites and exposure to the spores from disturbed soil.
Although conditions are not favorable, construction activities could generate fugitive dust that contain C. immitis spores. The project will minimize the generation of fugitive dust during
10 United States Geological Survey (USGS). 2000. Operational Guidelines (Version 1.0) for Geological Fieldwork in Areas Endemic for Coccidioidomycosis (Valley Fever), 2000, Open-File Report 2000-348. Website:
https://pubs.usgs.gov/of/2000/0348/pdf/of00-348.pdf. Accessed May 20, 2022. 35 440
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construction activities by complying with SJVAPCD’s Regulation VIII. Therefore, this regulation, combined with the relatively low probability of the presence of C. immitis spores would reduce Valley fever impacts to less than significant.
During operations, dust emissions are anticipated to be relatively small because most of the project area where operational activities would occur would be occupied by the proposed apartment complex and pavement associated with the proposed residential development. This condition would lessen the possibility of the project from providing habitat suitable for C. immitis spores and for generating fugitive dust that may contribute to Valley fever exposure. Impacts would be less than significant.
Naturally Occurring Asbestos
Review of the map of areas where naturally occurring asbestos in California are likely to occur found no such areas in the project area. Therefore, development of the project is not anticipated to expose receptors to naturally occurring asbestos.11 Impacts would be less than significant.
Impact Analysis Summary
In summary, the project would not exceed SJVAPCD localized emission daily screening levels for any criteria pollutant. The project is not a significant source of TAC emissions during short- term construction or long-term operations. The project is not in an area with suitable habitat for Valley fever spores and is not in area known to have naturally occurring asbestos. Therefore, the project would not result in significant impacts to sensitive receptors after incorporation of mitigation.
Level of Significance Before Mitigation
Less than significant.
Mitigation Measures
No mitigation measures are necessary.
11 U.S. Geological Survey. 2011. Van Gosen, B.S., and Clinkenbeard, J.P. California Geological Survey Map Sheet 59. Reported Historic Asbestos Mines, Historic Asbestos Prospects, and Other Natural Occurrences of Asbestos in California. Open-File Report 2011-1188 Website: https://pubs.usgs.gov/of/2011/1188/. Accessed May 20, 2022. 36 441
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Impact AIR-4 Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Impact Analysis
Two situations create a potential for odor impact. The first occurs when a new odor source is located near an existing sensitive receptor. The second occurs when a new sensitive receptor locates near an existing source of odor. According to the CBIA v. BAAQMD ruling, impacts of existing sources of odors on the project are not subject to CEQA review. Therefore, the analysis to determine if the project would locate new sensitive receptors near an existing source of odor is not used to determine significance for this impact.
Odor impacts on residential areas and other sensitive receptors, such as hospitals, day-care centers, schools, etc. warrant the closest scrutiny, but consideration should also be given to other land uses where people may congregate, such as recreational facilities, worksites, and commercial areas.
Although the project is less than one mile from the nearest sensitive receptor, the project is not expected to be a significant source of odors. The screening levels for these land use types are shown in Table 15.
Table 15: Screening Levels for Potential Odor Sources
Odor Generator Screening Distance
Wastewater Treatment Facilities 2 miles
Sanitary Landfill 1 mile
Transfer Station 1 mile
Composting Facility 1 mile
Petroleum Refinery 2 miles
Asphalt Batch Plant 1 mile
Chemical Manufacturing 1 mile
Fiberglass Manufacturing 1 mile
Painting/Coating Operations (e.g., auto body shop) 1 mile Food Processing Facility 1 mile
Feed Lot/Dairy 1 mile
Rendering Plant 1 mile
Wastewater Treatment Facilities 2 miles
Source of Thresholds: San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015. Guidance for Assessing and Mitigating Air Quality Impacts. February 19. Website: https://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT-GAMAQI.PDF.
Accessed May 20, 2022.
Project Construction and Project Operation
The occurrence and severity of odor impacts depend on numerous factors, including the nature, frequency, and intensity of the source; wind speed and direction; and the presence of sensitive receptors. Although offensive odors rarely cause any physical harm, they still can be very unpleasant, leading to considerable distress and often generating citizen complaints to local 37 442
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governments and regulatory agencies. Project operations would not be anticipated to produce odorous emissions, as the project would not be considered an odor generator based on the land uses shown in Table 15. Construction activities associated with the proposed project could result in short-term odorous emissions from diesel exhaust associated with construction equipment. However, these emissions would be intermittent and would dissipate rapidly from the source. In addition, this diesel-powered equipment would only be present onsite temporarily during construction activities. The temporary and intermittent nature of construction activities would decrease the likelihood of the odors concentrating in a single area or lingering for any notable period of time. As such, these odors would likely not be noticeable for extended periods of time beyond the project’s site boundaries. Therefore, construction would not create objectionable odors affecting a substantial number of people from use of diesel-powered equipment. As there would not be conditions under which the project would have the potential to expose a substantial number of people to odors emitted from construction or operations of the project, and the impact would be less than significant.
Level of Significance Before Mitigation
Less than significant.
Mitigation Measures
No mitigation measures are necessary.
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GREENHOUSE GASES
Environmental Setting
Greenhouse Gases
Greenhouse gases and climate change are cumulative global issues. The CARB and EPA regulate GHG emissions within the State of California and the U.S., respectively. Meanwhile, the CARB has the primary regulatory responsibility within California for GHG emissions. Local agencies can also adopt policies for GHG emission reduction.
Many chemical compounds in the Earth’s atmosphere act as GHGs as they absorb and emit radiation within the thermal infrared range. When radiation from the sun reaches the Earth’s surface, some of it is reflected into the atmosphere as infrared radiation (heat). Greenhouse gases absorb this infrared radiation and trap the heat in the atmosphere. Over time, the amount of energy from the sun to the Earth’s surface should be approximately equal to the amount of energy radiated back into space, leaving the temperature of the earth’s surface roughly constant. Many gases exhibit these “greenhouse” properties. Some of them occur in nature (water vapor, carbon dioxide [CO2], methane [CH4], and nitrous oxide [N2O]), while others are exclusively human made (like gases used for aerosols).
The principal climate change gases resulting from human activity that enter and accumulate in the atmosphere are listed below.
Carbon Dioxide
Carbon dioxide enters the atmosphere through the burning of fossil fuels (oil, natural gas, and coal), solid waste, trees and wood products, and chemical reactions (e.g., the manufacture of cement). Carbon dioxide is also removed from the atmosphere (or “sequestered”) when it is absorbed by plants as part of the biological carbon cycle.
Methane
Methane is emitted during the production and transport of coal, natural gas, and oil. Methane emissions also result from livestock and agricultural practices and the decay of organic waste in municipal solid waste landfills.
Nitrous Oxide
Nitrous oxide is emitted during agricultural and industrial activities, as well as during combustion of fossil fuels and solid waste.
Fluorinated Gases
Hydrofluorocarbons, perfluorinated chemicals, and sulfur hexafluoride are synthetic, powerful climate-change gases that are emitted from a variety of industrial processes. Fluorinated gases are often used as substitutes for ozone-depleting substances (i.e., chlorofluorocarbons, hydrochlorofluorocarbons, and halons). These gases are typically emitted in smaller quantities, but because they are potent climate-change gases, they are sometimes referred to as high global warming potential gases.
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Emissions Inventories and Trends
According to the CARB’s recent GHG inventory for the State, released 2021, California produced 418.2 million metric tons of carbon dioxide equivalent (MMTCO2e) in 2019. The major source of GHGs in California is transportation, contributing approximately 39.7 percent of the state’s total GHG emissions in 2019.12 This puts total emissions at 12.8 MMTCO2e below the 2020 target of 431 million metric tons. California statewide GHG emissions dropped below the 2020 GHG limit in 2016 and have remained below the 2020 GHG limit since then.
Potential Environmental Impacts
For California, climate change in the form of warming has the potential to incur and exacerbate environmental impacts, including but not limited to changes to precipitation and runoff patterns, increased agricultural demand for water, inundation of low-lying coastal areas by sea-level rise, and increased incidents and severity of wildfire events.13 Cooling of the climate may have the opposite effects. Although certain environmental effects are widely accepted to be a potential hazard to certain locations, such as rising sea level for low-lying coastal areas, it is currently infeasible to predict all environmental effects of climate change on any one location.
Emissions of GHGs contributing to global climate change are attributable in large part to human activities associated with the industrial and manufacturing, utility, transportation, residential, and agricultural sectors. Therefore, the cumulative global emissions of GHGs contributing to global climate change can be attributed to every nation, region, and city, and virtually every individual on Earth. A project’s GHG emissions are at a micro-scale relative to global emissions but could result in a cumulatively considerable incremental contribution to a significant cumulative macro- scale impact.
Regulatory Requirements
California has adopted statewide legislation addressing various aspects of climate change and GHG emissions mitigation. Much of this legislation establishes a broad framework for the state’s long-term GHG reduction and climate change adaptation program. The governor has also issued several executive orders (EOs) related to the state’s evolving climate change policy. Of particular importance are AB 32 and SB 32, which outline the state’s GHG reduction goals of achieving 1990 emissions levels by 2020 and a 40 percent reduction below 1990 emissions levels by 2030.
In the absence of federal regulations, control of GHGs is generally regulated at the state level and is typically approached by setting emission reduction targets for existing sources of GHGs, setting policies to promote renewable energy and increase energy efficiency, and developing statewide action plans.
12 California Air Resources Board (CARB). 2021. California Greenhouse Gas Emissions for 2000 to 2019. Website:
https://ww3.arb.ca.gov/cc/inventory/pubs/reports/2000_2019/ghg_inventory_trends_00-19.pdf. Accessed. March 1, 2022. 13 Moser et al. 2009. Moser, Susie, Guido Franco, Sarah Pittiglio, Wendy Chou, Dan Cayan. 2009. The Future Is Now: An Update on Climate Change Science Impacts and Response Options for California. Website:
http://www.susannemoser.com/documents/CEC-500-2008-071_Moseretal_FutureisNow.pdf. Accessed March 1, 2022. 40 445
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CEQA Guidelines
The CEQA Guidelines define a significant effect on the environment as “a substantial, or potentially substantial, adverse change in the environment.” To determine if a project would have a significant impact on GHGs, the type, level, and impact of emissions generated by the project must be evaluated.
The following GHG significance thresholds are contained in Appendix G of the CEQA Guidelines, which were amendments adopted into the Guidelines on March 18, 2010, pursuant to SB 97. A significant impact would occur if the project 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 GHGs.
Thresholds of Significance
San Joaquin Valley Air Pollution Control District
The SJVAPCD’s Guidance for Valley Land-use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA presents a tiered approach to analyzing project significance with respect to GHG emissions. Project GHG emissions are considered less than significant if they can meet any of the following conditions, evaluated in the order presented:
• Project is exempt from CEQA requirements;
• Project complies with an approved GHG emission reduction plan or GHG mitigation program;
• Project implements Best Performance Standards (BPS); or • Project demonstrates that specific GHG emissions would be reduced or mitigated by at least 29 percent compared to Business-as-Usual (BAU), including GHG emission reductions achieved since the 2002-2004 baseline period.
Project-level Thresholds
Section 15064.4(b) of the CEQA Guidelines’ amendments for GHG emissions states that a lead agency may take into account the following three considerations in assessing the significance of impacts from GHG emissions.
• Consideration #1: The extent to which the project may increase or reduce GHG emissions as compared to the existing environmental setting. • Consideration #2: Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project.
• Consideration #3: 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. Such regulations or requirements must be adopted by 41 446
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the relevant public agency through a public review process and must include specific requirements that reduce or mitigate the project’s incremental contribution of GHG emissions. If there is substantial evidence that the possible effects of a particular project are still cumulatively considerable notwithstanding compliance with the adopted regulations or requirements, an Environmental Impact Report (EIR) must be prepared for the project.
Newhall Ranch
In the California Supreme Court decision in the Center for Biological Diversity et al. vs.
California Department of Fish and Wildlife, the Newhall Land and Farming Company (62 Cal.4th 204 [2015], and known as the Newhall Ranch decision), the Supreme Court was concerned that new development may need to reduce GHG emissions more than existing development to demonstrate it is meeting its fair share of reductions. New development does do more than its fair share through compliance with enhanced regulations, particularly with respect to motor vehicles, energy efficiency, and electricity generation. If no additional reductions are required from an individual project beyond that achieved by regulations, then the amount needed to reach the 2020 target is the amount of GHG emissions a project must reduce to comply with AB 32 Statewide goals.
The State’s regulatory program implementing the 2008 Scoping Plan is now fully mature. All regulations envisioned in the Scoping Plan have been adopted by the responsible agencies and the effectiveness of those regulations have been estimated by the agencies during the adoption process and then are tracked to verify their effectiveness after implementation. Governor Brown, in the introduction to Executive Order B-30-15, states “California is on track to meet or exceed the current target of reducing greenhouse gas emissions to 1990 levels by 2020, as established in the California Global Warming Solutions Act of 2006 (AB 32).” The progress was evident in emission inventories prepared by CARB, which showed that the State inventory dropped below 1990 levels for the first time in 2016.14 The 2017 Scoping Plan Update includes projections indicating that the State will meet or exceed the 2020 target with adopted regulations.15 The State now projects that it will meet the 2020 target and achieve continued progress towards meeting the 2017 Scoping Plan target for 2030.
GHG Threshold Applied in the Analysis
The City of Clovis has not adopted a GHG reduction plan. In addition, the City has not completed the GHG inventory, benchmarking, or goal‐setting process required to identify a reduction target and take advantage of the streamlining provisions contained in the CEQA Guidelines amendments adopted for SB 97 and clarifications provided in the CEQA Guidelines amendments adopted on December 28, 2018. In the absence of an adopted numeric GHG emissions threshold consistent with the State’s 2030 target, the project’s GHG emissions impact determination is based on the extent to which the project complies with regulations or
14 California Air Resources Board (CARB). 2018. Climate Pollutants Fall Below 1990 Levels for the First Time. Website:
https://ww2.arb.ca.gov/news/climate‐pollutants‐fall‐below‐1990‐levelsfirst‐time. Accessed March 1, 2022. 15 California Air Resources Board (CARB). 2017. The 2017 Climate Change Scoping Plan Update, the Proposed Strategy for Achieving California’s 2030 Greenhouse Gas Target. January 17, 2017. Website:
https://www.arb.ca.gov/cc/scopingplan/2030sp_pp_final.pdf. Accessed March 1, 2022. 42 447
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requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions. The project’s GHG emissions are provided for informational purposes only.
Environmental Impact Analysis
This section discusses potential impacts related to GHGs associated with the proposed project and provides mitigation measures where necessary.
Impact GHG-1 Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Impact Analysis
The proposed project may contribute to climate change impacts through its contribution of GHGs. The proposed project would generate a variety of GHGs during construction and operations, including several defined by AB 32, such as CO2, CH4, and N2O from the exhaust of equipment during construction and on-road vehicle trips during construction and operations.
In the absence of an adopted numeric GHG emissions threshold consistent with the State’s 2030 target, the project’s GHG emissions impact determination is based on 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. The project’s GHG emissions are provided for informational purposes only.
Quantification of Greenhouse Gas Emissions for Informational Purposes Construction Emissions
Construction emissions would be generated from the exhaust of construction equipment, material delivery trips, haul truck trips, and worker commuter trips. Detailed construction assumptions are provided in Modeling Parameters and Assumptions section of this technical memorandum. Construction-generated GHGs were quantified and are disclosed in Attachment A. MTCO2e emissions during construction of the project are summarized below in Table 16.
Table 16: Construction Greenhouse Gas Emissions
Project Construction (2023-2024) MTCO2e
Demolition 26
Site Preparation 2
Grading 11
Paving 7
Building Construction 194
Architectural Coating 1
Total Construction MTCO2e 241
Emissions Amortized Over 30 Years1 8
Notes:
MTCO2e = metric tons of carbon dioxide equivalent
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Project Construction (2023-2024) MTCO2e
1 Construction GHG emissions are amortized over the 30-year lifetime of the project.
Source: CalEEMod Output (Attachment A).
During the construction of the proposed project, approximately 241 MTCO2e would be emitted.
Neither the City of Clovis nor the SJVAPCD have an adopted threshold of significance for construction related GHG emissions. Because impacts from construction activities occur over a relatively short-term period (4-6 months for the proposed project), they contribute a relatively small portion of the overall lifetime project GHG emissions. In addition, GHG emission reduction measures for construction equipment are relatively limited. Therefore, a standard practice is to amortize construction emissions over the anticipated lifetime of a project so that GHG reduction measures will address construction GHG emissions as part of the operational GHG reduction strategies. However, emissions were quantified for informational purposes only. The total emissions generated during construction were amortized based on the life of the development (30 years for residential development) and added to the operational emissions to determine the total emissions from the project, as shown below.
Operational Emissions
Operational or long-term emissions occur over the life of the project. Sources of emissions may include motor vehicles and trucks, energy usage, water usage, waste generation, and area sources, such as landscaping activities and residential woodburning. Operational GHG emissions associated with the proposed project were estimated using CalEEMod 2020.4.0.
Business-as-Usual Operational Emissions
Operational emissions under the business-as-usual scenario were modeled using CalEEMod 2020.4.0. Modeling assumptions for the year 2005 were used to represent 2020 business as usual conditions (without the benefit of regulations adopted to reduce GHG emissions). The CARB and SJVAPCD guidance recommend using regulatory conditions in 2002-2004 in the baseline scenario to represent conditions as if regulations had not been adopted to allow the effect of projected growth on achieving reduction targets to be clearly defined. CalEEMod defaults were used for project energy usage, water usage, waste generation, and area sources (architectural coating, consumer products, and landscaping). The vehicle fleet mixes were revised to reflect the project fleet mix identified for the buildout year.
Buildout Year Operational Emissions
Operational emissions for the year 2023 were modeled using CalEEMod. CalEEMod assumes compliance with some, but not all, applicable rules and regulations regarding energy efficiency, vehicle fuel efficiency, renewable energy usage, and other GHG reduction policies, as described in the CalEEMod User’s Guide.16
The reductions obtained from each regulation and the source of the reduction amount used in the analysis are described below.
16 California Air Pollution Control Officers Association (CAPCOA). 2021. California Emission Estimator Model (CalEEMod) Version 2020.4.0 User’s Guide. Website: https://www.aqmd.gov/docs/default-source/caleemod/user-guide-2021/01_user-39-s- guide2020-4-0.pdf?sfvrsn=6. Accessed October 20, 2021.
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The following regulations are incorporated into the CalEEMod emission factors:
• Pavley I and Pavley II (LEV III) motor vehicle emission standards • CARB Medium and Heavy-Duty Vehicle Regulation
• 2005, 2008, 2013, 2016, and 2019 Title 24 Energy Efficiency Standards
The following regulations have not been incorporated into the CalEEMod emission factors and require alternative methods to account for emission reductions provided by the regulations:
• Renewables Portfolio Standard (RPS) requirements for year 2030 • Green Building Code Standards (indoor water use)
• California Model Water Efficient Landscape Ordinance (outdoor water) • CalRecycle 75 Percent Initiative (solid waste)
Title 24 reductions for 2013 and 2016 updates were added to CalEEMod 2016.3.2 and were carried into CalEEMod 2020.4.0. Title 24 reductions for 2019 were added to CalEEMod 2020.4.0.
RPS is not accounted for in CalEEMod 2020.4.0. Reductions from RPS for operational years 2030 and beyond are addressed by revising the electricity emission intensity factor in CalEEMod to account for the utility RPS rate forecast for 2030. The utilities will be required by SB 100 to increase the use of renewable energy sources to 60 percent by 2030. The latest power content label for PG&E was used to estimate a revised CO2 intensity factor for use in the modeling.
Reductions in emissions from solid waste are based on the County achieving the CalRecycle 75 Percent Initiative by 2020 compared with a 50 percent baseline for 2005.17 Reductions are taken using the CalEEMod mitigation component.
Energy savings from water conservation resulting from the Green Building Code Standards for indoor water use and California Model Water Efficient Landscape Ordinance for outdoor water use are not included in CalEEMod. The Water Conservation Act of 2009 mandates a 20 percent reduction in urban water use that is implemented with these regulations.18 Benefits of the water conservation regulations are applied in the CalEEMod mitigation component.
GHG reductions from some design features and compliance with regulations that are not otherwise accounted for can be quantified in CalEEMod. Note that CalEEMod nominally treats these design elements and conditions as “mitigation measures,” despite their inclusion in the
17 California Department of Resources Recycling and Recovery (CalRecycle). 2016b. California’s 75 Percent Initiative: Defining the Future. Website: https://www.calrecycle.ca.gov/75percent#:~:text=The%20Legislature% 20and%20Governor%20Brown,decreasing%20California’s%20reliance%20on%20landfills. Accessed November 2, 2021. 18 California Department of Water Resources (CDWR). 2013. California Water Plan Update 2013, Chapter 3 Urban Water Use Efficiency.
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project description. Therefore, reported operational emissions are considered to represent unmitigated project conditions.
Operational GHG emissions by source are shown in Table 17. Full buildout of the project is anticipated to occur as early as 2023.
Table 17: Unmitigated Project Operational GHG Emissions (Buildout Year Scenario) Emission Source
Emissions (MT CO2e per year)
2023 Business as
Usual Total Emissions
(MT CO2e per year)
Buildout Year Total
Emissions with
Regulations and
Design Features
(MT CO2e per year)
Area 5 5
Energy 36 16
Mobile (On-road Vehicles) 121 87
Waste 3 2
Water 3 1
Amortized Construction Emissions 8 8
Total 176 119
Reduction from BAU 57
Percent Reduction 32.4%
Significance Threshold 29%
Exceeds Significance Threshold? (Shown For Informational Purposes) No MT CO2e = metric tons of carbon dioxide equivalent.
Totals may not appear to sum exactly due to rounding.
Source of Significance Threshold: San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015. Final Draft Guidance for Assessing and Mitigating Air Quality Impacts. Website: https://www.valleyair.org/transportation/GAMAQI- 2015/FINAL-DRAFT-GAMAQI.PDF. Accessed May 20, 2022.
Source of Business-as-Usual Emissions: CalEEMod output for the 2023 BAU Scenario (see Attachment A).
Source of Buildout Year Emissions: CalEEMod output for the year 2023 (Attachment A).
As shown in Table 17, the proposed project’s total GHG annual emissions would not exceed applicable thresholds of significance in either scenario analyzed.
Emissions were assessed for full buildout operations in years 2024 and 2030. The 2030 scenario summarized in Table 17 was prepared to assess the project’s consistency with the SB 32 2030 target.
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Table 18: Unmitigated Project Operational GHG Emissions (Year 2030 Scenario) Emission Source
Emissions (MT CO2e per year)
2030 Business as
Usual Total Emissions
(MT CO2e per year)
2030 Year Total
Emissions with
Regulations and
Design Features
(MT CO2e per year)
Area 5 5
Energy 36 16
Mobile (On-road Vehicles) 120 71
Waste 3 2
Water 3 1
Amortized Construction Emissions 8 8
Total 175 103
Reduction from BAU 72
Percent Reduction 41.1%
Significance Threshold 29%
Exceeds Significance Threshold? (Shown For Informational Purposes) No MT CO2e = metric tons of carbon dioxide equivalent.
Totals may not appear to sum exactly due to rounding.
1 Adjusted threshold to account for 2017 Scoping Plan Update 40 percent reduction goal by 2030.
Source of Business-as-Usual Emissions: CalEEMod output for the 2030 BAU Scenario (see Attachment A).
Source of 2030 Emissions: CalEEMod output for the year 2030 (Attachment A).
As shown in Table 17 and Table 18, the project would achieve a 32.4 percent reduction from BAU at project buildout (2023) and 41.1 percent reduction from BAU by the year 2030 with adopted regulations and design features incorporated. These values are above the 29 percent reduction required by the SJVAPCD threshold and are above the required 21.7 percent average reduction from all GHG emission sources to meet the AB 32 targets. The CARB originally identified a reduction of 29 percent from business as usual as needed to achieve AB 32 targets.
The 2008 recession and slower growth in the years since 2008 have reduced the growth forecasted for 2020 and the amount needed to be reduced to achieve 1990 levels as required by AB 32; the target was revised to 21.7 percent.
The 32.4 percent reduction from BAU is 10.7 percent beyond the average reduction required by the State from all sources to achieve the AB 32 2020 target. This surplus addresses the Supreme Court’s concern in the Newhall case that new development must do more than average to meet its fair share of emission reductions.
By 2030, the proposed project would achieve a 41.1 percent reduction from BAU or 19.4 percent above the 21.7 percent reduction necessary to meet the 2020 target.
The project’s occupancy is anticipated to be fully built out in 2023 at the earliest, thus an additional analysis is provided to show consistency with post-2020 State legislative GHG goals. 47 452
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The SB 32 goal of 40 percent below 1990 emission levels by 2030 is the target established by the 2017 Scoping Plan Update.
The 2017 Scoping Plan includes new strategies that are not incorporated in the analysis above.
Many measures that are likely to proceed include zero net energy buildings in future updates to Title 24 and enhanced motor vehicle fuel efficiency standards beyond 2025. The 2017 Scoping Plan identified an emission limit of 260 million metric tons of carbon dioxide equivalents (MMTCO2e). The 2030 BAU Inventory is estimated to be 392 MMTCO2e. The 2017 Scoping Plan identified that the bulk of its reductions would come from the Electric Power, Industrial fuel combustion, and Transportation. The continuance of the Cap and Trade would provide additional reductions. Although the 2017 Scoping Plan largely relies on state actions to achieve the GHG emissions limit, the CARB considers local governments partners in achieving the State’s goals for reducing GHG emissions. The 2017 Scoping Plan suggests that all new land use development implement feasible measures to reduce GHG emissions, however, it does not define feasible measures nor assign a required reduction amount to new development. A fair share quantitative threshold based on the 2017 Scoping Plan is not presently feasible as the nexus between a project’s contribution and its fair share mitigation is not well defined.
Based on the 32.4 percent reduction from BAU for the buildout year scenario (2023), the proposed project would not have a significant impact on GHG emissions as it would meet the SJVAPCD’s threshold of 29 percent and exceed the CARB’s 21.7 percent reduction necessary from all sources to meet the AB 32 emissions limit.
For the year 2030, the project achieves a 41.1 percent reduction from BAU, which demonstrates substantial progress towards achieving the 2030 target.
Regarding the years 2045 and 2050, there have been Executive Orders issued to address carbon neutrality and GHG reduction targets, respectively for those years, however, there are no existing GHG reduction plans that specifically address those Orders. Historically, the State would take the lead in developing regulatory and market measures to achieve the required reductions. The proposed project would participate in the reductions through adherence with regulations and continued improvements to the motor vehicle efficiencies accessing the project site. Studies have shown that in order to meet the 2050 targets, aggressive pursuit of technologies in the transportation and energy sectors, including electrification and the decarbonization of fuel, will be required. Because of the technological shifts required and the unknown parameters of the regulatory framework in 2050, quantitatively analyzing the proposed project’s impacts further relative to the 2050 goals is speculative for purposes of CEQA.
Impact Analysis (Project’s Compliance with Consideration No. 3 Regarding Consistency with Adopted Plans to Reduce GHG Emissions)
The following analysis assesses the project’s compliance with Consideration No. 3 regarding consistency with adopted plans to reduce GHG emissions. As discussed above, the City of Clovis has not adopted a GHG reduction plan. In addition, the City has not completed the GHG inventory, benchmarking, or goal‐setting process required to identify a reduction target and take advantage of the streamlining provisions contained in the CEQA Guidelines amendments adopted for SB 97 and clarifications provided in the CEQA Guidelines amendments adopted on 48 453
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December 28, 2018. The SJVAPCD has adopted a Climate Action Plan, but it does not contain measures that are applicable to the project. Therefore, the SJVAPCD Climate Action Plan cannot be applied to the project. Since no other local or regional Climate Action Plan is in place, the project is assessed for its consistency with CARB’s adopted 2008 and 2017 Scoping Plans.
This would be achieved with an assessment of the proposed project’s compliance with Scoping Plan measures contained in the 2017 Scoping Plan Update.
Greenhouse Gas Emissions Estimation Summary and Greenhouse Gas Impact Analysis Greenhouse Gas Impact Analysis
The following analysis assesses the proposed project’s compliance with Consideration No. 3 regarding consistency with adopted plans to reduce GHG emissions. The proposed project is assessed for its consistency with CARB’s adopted Scoping Plans. This would be achieved with an assessment of the proposed project’s compliance with Scoping Plan measures contained in the 2017 Scoping Plan Update.
Consistency with SB 32
The 2017 Climate Change Scoping Plan Update (2017 Scoping Plan) includes the strategy that the State intends to pursue to achieve the 2030 targets of Executive Order S‐3‐05 and SB 32.
The 2017 Scoping Plan includes the following summary of its overall strategy for reaching the 2030 target:
• SB 350
o Achieve 50 percent Renewables Portfolio Standard (RPS) by 2030. o Doubling of energy efficiency savings by 2030.
• Low Carbon Fuel Standard (LCFS)
o Increased stringency (reducing carbon intensity 18 percent by 2030, up from 10 percent in 2020).
• Mobile Source Strategy (Cleaner Technology and Fuels Scenario) o Maintaining existing GHG standards for light‐ and heavy‐duty vehicles. o Put 4.2 million zero‐emission vehicles (ZEVs) on the roads. o Increase ZEV buses, delivery and other trucks.
• Sustainable Freight Action Plan
o Improve freight system efficiency.
o Maximize use of near‐zero emission vehicles and equipment powered by renewable energy.
o Deploy over 100,000 zero‐emission trucks and equipment by 2030. • Short‐Lived Climate Pollutant (SLCP) Reduction Strategy 49 454
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o Reduce emissions of methane and hydrofluorocarbons 40 percent below 2013 levels by 2030.
o Reduce emissions of black carbon 50 percent below 2013 levels by 2030. • SB 375 Sustainable Communities Strategies
o Increased stringency of 2035 targets.
• Post‐2020 Cap‐and‐Trade Program
o Declining caps, continued linkage with Québec, and linkage to Ontario, Canada. o CARB will look for opportunities to strengthen the program to support more air quality co-benefits, including specific program design elements. In Fall 2016, CARB staff described potential future amendments including reducing the offset usage limit, redesigning the allocation strategy to reduce free allocation to support increased technology and energy investment at covered entities and reducing allocation if the covered entity increases criteria or toxics emissions over some baseline.
• By 2018, develop Integrated Natural and Working Lands Action Plan to secure California’s land base as a net carbon sink.
Table 19 provides an analysis of the project’s consistency with the 2017 Scoping Plan Update measures.
Table 19: Consistency with SB 32 2017 Scoping Plan Update Scoping Plan Measure Project Consistency
SB 350 50% Renewable Mandate. Utilities subject
to the legislation will be required to increase their
renewable energy mix from 33% in 2020 to 50% in
2030.
Consistent: The project will purchase electricity from a utility subject to the SB 350 Renewable Mandate SB 100
Renewable Mandate. SB 100 revised the Renewable
Portfolio Standard goals to achieve the 50 percent
renewable resources target by December 31, 2026, and
to achieve a 60 percent target by December 31, 2030.
The specific provider for the City of Clovis and the
proposed project is Pacific Gas and Electric (PG&E).
SB 350 Double Building Energy Efficiency by
2030. This is equivalent to a 20 percent reduction
from 2014 building energy usage compared to
current projected 2030 levels.
Not Applicable. This measure applies to existing
buildings. Renovations to existing buildings are not
proposed as part of the proposed project, which includes the development of new multifamily residential uses (12 dwelling units). New structures are required to comply
with Title 24 Energy Efficiency Standards that are
expected to increase in stringency until residential
housing achieves zero net energy.
Low Carbon Fuel Standard. This measure
requires fuel providers to meet an 18 percent
reduction in carbon content by 2030.
Consistent. Vehicles accessing the project site will use fuel containing lower carbon content as the fuel standard is implemented.
Mobile Source Strategy (Cleaner Technology
and Fuels Scenario). Vehicle manufacturers will be
required to meet existing regulations mandated by
Consistent. The project consists of residential
development and would not engage in vehicle
manufacturing; however, vehicles would access the
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Scoping Plan Measure Project Consistency
the LEV III and Heavy‐Duty Vehicle programs. The
strategy includes a goal of having 4.2 million ZEVs
on the road by 2030 and increasing numbers of
ZEV trucks and buses.
project site during project operations. Future project residents and visitors can be expected to purchase
increasing numbers of more fuel efficient and zero
emission cars and trucks each year. Home deliveries will be made by increasing numbers of ZEV delivery trucks.
Sustainable Freight Action Plan. The plan’s target
is to improve freight system efficiency 25 percent by
increasing the value of goods and services
produced from the freight sector, relative to the
amount of carbon that it produces by 2030. This
would be achieved by deploying over 100,000
freight vehicles and equipment capable of zero
emission operation and maximize near‐zero
emission freight vehicles and equipment powered
by renewable energy by 2030.
Not Applicable. The measure applies to owners and
operators of trucks and freight operations. However,
deliveries that would be made to the future residences
are expected to be made by increasing number of ZEV
delivery trucks.
Short‐Lived Climate Pollutant (SLCP) Reduction
Strategy. The strategy requires the reduction of
SLCPs by 40 percent from 2013 levels by 2030 and
the reduction of black carbon by 50 percent from
2013 levels by 2030.
Consistent. Sources of black carbon are already
regulated by the CARB and air district criteria pollutant and toxic regulations that control fine particulate
emissions from diesel engines and other combustion
source. The proposed apartments would not include
hearths or would include only electric or natural gas
hearths; natural gas hearths produce very little black
carbon compared to woodburning fireplaces and heaters.
SB 375 Sustainable Communities Strategies.
Requires Regional Transportation Plans to include
a sustainable communities strategy for reduction of
per capita vehicle miles traveled.
Not Applicable. The project does not consist of a
proposed regional transportation plan; therefore, this
measure is not applicable to the proposed project.
Post‐2020 Cap‐and‐Trade Program. The Post
2020 Cap‐and‐Trade Program continues the
existing program for another 10 years. The Cap‐
and‐Trade Program applies to large industrial
sources such as power plants, refineries, and
cement manufacturers.
Consistent. The post‐2020 Cap‐and‐Trade Program
indirectly affects people who use the products and
services produced by the regulated industrial sources
when increased cost of products or services (such as
electricity and fuel) are transferred to the consumers. The Cap‐and‐Trade Program covers the GHG emissions
associated with electricity consumed in California,
whether generated in‐state or imported. Accordingly,
GHG emissions associated with CEQA projects’
electricity usage are covered by the Cap-and‐Trade
Program. The Cap‐and‐Trade Program also covers fuel
suppliers (natural gas and propane fuel providers and
transportation fuel providers) to address emissions from such fuels and from combustion of other fossil fuels not directly covered at large sources in the program’s first compliance period.
Natural and Working Lands Action Plan. The
CARB is working in coordination with several other
agencies at the federal, state, and local levels,
stakeholders, and with the public, to develop
measures as outlined in the Scoping Plan Update
and the governor’s Executive Order B‐30‐15 to
Not Applicable. The project consists of multifamily
residential development and will not be considered
natural or working lands.
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Scoping Plan Measure Project Consistency
reduce GHG emissions and to cultivate net carbon
sequestration potential for California’s natural and
working land.
Source: California Air Resources Board (CARB). 2017. The 2017 Climate Change Scoping Plan Update. January 20.
Website: https://www.arb.ca.gov/cc/scopingplan/2030sp_pp_final.pdf. Accessed May 20, 2022.
Regarding goals for 2050 under Executive Order S‐3‐05, at this time it is not possible to quantify the emissions savings from future regulatory measures with any level of certainty, as they have not yet been developed; nevertheless, it can be anticipated that operation of the project would comply with whatever measures are enacted that state lawmakers decide would lead to an 80 percent reduction below 1990 levels by 2050. In its 2008 Scoping Plan, CARB acknowledged that the “measures needed to meet the 2050 are too far in the future to define in detail.” In the First Scoping Plan Update; however, CARB generally described the type of activities required to achieve the 2050 target: “energy demand reduction through efficiency and activity changes; large scale electrification of on‐road vehicles, buildings, and industrial machinery; decarbonizing electricity and fuel supplies; and rapid market penetration of efficiency and clean energy technologies that requires significant efforts to deploy and scale markets for the cleanest technologies immediately.” The 2017 Scoping Plan provides an intermediate target that is intended to achieve reasonable progress toward the 2050 target.
Accordingly, taking into account the proposed project’s design features and the progress being made by the State towards reducing emissions in key sectors such as transportation, industry, and electricity, the project would be consistent with State GHG Plans and would further the State’s goals of reducing GHG emissions to 1990 levels by 2020, 40 percent below 1990 levels by 2030, and 80 percent below 1990 levels by 2050, and does not obstruct their attainment.
Impacts would be less than significant.
Conclusion
Taking into account the proposed project’s design features and the progress being made by the State towards reducing emissions in key sectors such as transportation, industry, and electricity, the proposed project would be consistent with State and local GHG Plans would not obstruct their attainment. The proposed project’s GHG impacts would be less than significant.
Level of Significance Before Mitigation
Less than significant.
Mitigation Measures
No mitigation measures are necessary.
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Impact GHG-2 Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Impact Analysis
The analysis contained above under Impact GHG-1 evaluates whether the project would not conflict with any applicable plan, policy, or regulation of an agency adopted to reduce the emissions of GHGs. As discussed under Impact GHG-1 above, the proposed project would not conflict with any applicable plan, policy, or regulation of agency to reduce. As such, project impacts in this regard would be less than significant.
Level of Significance Before Mitigation
Less than significant.
Mitigation Measures
No mitigation measures are necessary.
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Attachments:
Attachment A – CalEEMod Output
Attachment B – Construction Health Risk Assessment
Attachment C – Operational Health Risk Screening and Additional Supporting Information
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ATTACHMENT A
CalEEMod Output
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CalEEMod Output
Table of Contents
CalEEMod Output Files
• Unmitigated Project Construction and Operations (Regional)—Annual • Unmitigated Project Construction and Operations (On-site and Localized)—Annual • Unmitigated Project Construction and Operations (On-site and Localized)—Summer • Unmitigated Project Construction and Operations (On-site and Localized)—Winter • Business-as-Usual Scenario (2023)—Annual
• Business-as-Usual Scenario (2030)—Annual
• Project Operations 2030 Operational Year Scenario
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Alluvial Development - Unmitigated Construction and 2023 Operations Fresno County, Annual
Project Characteristics - Alluvial Residential Development Project Project operations the earliest operational year (
2023
)
Land Use - Land use development (see site coverage summary for how project components are represented in CalEEMod) Construction Phase - Anticipated construction duration per applicant:
4-6
months
Construction start date:
08/01/2023
Off-road Equipment - Adjusted construction equipment usage to match CalEEMod default total building construction HP hours.
Trips and VMT - Additional truck trips were added to each phase for mobilization/demobilization of on-site equipment (two trips per piece of equipment).
Additional vendor trips added to the paving phase to account for delivery of materials.
Demolition - Existing site to be demolished (1,111 tons of debris from buildings + hardscape)
1.1 Land Usage
Land Uses
Size
Metric
Lot Acreage
Floor Surface Area
Population
Enclosed Parking Structure
3.16 1000sqft
0.07 3,160.00
0 Parking Lot
16.93 1000sqft
0.39 16,932.00
0 Unenclosed Parking Structure
7.00 Space
0.06 2,800.00
0 City Park
0.12 Acre
0.12 5,400.00
0 Apartments Low Rise
12.00 Dwelling Unit
0.75 17,010.00
34 1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
3 Wind Speed (m/s)
Precipitation Freq (Days)
2.2 45
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company
Pacific Gas and Electric Company
2023
Operational Year
CO2 Intensity
(lb/MWhr)
203.98
0.033
CH4 Intensity
(lb/MWhr)
0.004
N2O Intensity
(lb/MWhr)
CalEEMod Version: CalEEMod.2020.4.0
Date: 6/28/2022 10:44 AM