Cities Index.
Agenda packet

Clovis City Council
May 20, 2024

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Failure to submit an approvable SIP or to implement the plan within the mandated timeframe may result in sanctions on transportation funding and stationary air pollution sources in the air basin.

The USEPA is also required to develop National Emission Standards for Hazardous Air Pollutants, which are defined as those which may reasonably be anticipated to result in increased deaths or serious illness, and which are not already regulated. An independent science advisory board reviews the health and exposure analyses conducted by the USEPA on suspected hazardous pollutants prior to regulatory development.

4.2.2.2 State Regulations
The CARB is the lead agency for implementing air quality regulations in the State. Key efforts by the State are described below.

California Clean Air Act. In 1988, the California Clean Air Act (CCAA) required that all air districts in the State endeavor to achieve and maintain California ambient air quality standards (CAAQS) for carbon monoxide, ozone, sulfur dioxide and nitrogen dioxide by the earliest practical date. The California Clean Air Act provides districts with authority to regulate indirect sources and mandates that air quality districts focus particular attention on reducing emissions from transportation and area-wide emission sources. Each nonattainment district is required to adopt a plan to achieve a 5 percent annual reduction, averaged over consecutive 3-year periods, in district-wide emissions of each nonattainment pollutant or its precursors. A Clean Air Plan shows how a district would reduce emissions to achieve air quality standards. Generally, the State standards for these pollutants are more stringent than the national standards.
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) 4.2-15 Legal authority for California to regulate sources of air pollution is found in federal and State law.

The CARB is charged with coordinating regional and local efforts to attain and maintain State and nation air quality standards. The CARB has been given authority to regulate many sources that would normally be pre‐empted by federal regulations through the issuance of waivers.

Pursuant to these authorities, CARB has adopted the world’s most stringent standards for passenger cars, light‐duty trucks, and medium‐duty vehicles. CARB has also adopted regulations establishing standards for heavy‐duty vehicles, offroad vehicles and engines, offroad recreational vehicles, off road diesel engines and equipment, offroad gasoline and liquefied petroleum gas (LPG) engines and equipment, and marine pleasure craft. Descriptions of these regulations are provided below.

Low-Emission Vehicle Program. The CARB first adopted Low‐Emission Vehicle (LEV) program standards in 1990. These first LEV standards ran from 1994 through 2003. LEV II regulations, running from 2004 through 2010, represent continuing progress in emission reductions. As the State’s passenger vehicle fleet continues to grow and more sport utility vehicles and pickup trucks are used as passenger cars rather than work vehicles, the more stringent LEV II standards were adopted to provide reductions necessary for California to meet federally mandated clean air goals outlined in the 1994 State Implementation Plan (SIP). In 2012, CARB adopted the LEV III amendments to California’s Low‐ Emission Vehicle (LEV) regulations. These amendments include more stringent emission standards for both criteria pollutants and greenhouse gases for new passenger vehicles.

Air Quality Land Use Handbook. The CARB has developed an Air Quality and Land Use Handbook7 which is intended to serve as a general reference guide for evaluating and reducing air pollution impacts associated with new projects that go through the land use decision-making process.

According to the CARB Handbook, recent air pollution studies have shown an association between respiratory and other non-cancer health effects and proximity to high traffic roadways. Other studies have shown that diesel exhaust and other cancer-causing chemicals emitted from cars and trucks are responsible for much of the overall cancer risk from airborne toxics in California. The CARB Handbook recommends that county and city planning agencies strongly consider proximity to these sources when finding new locations for "sensitive" land uses such as homes, medical facilities, daycare centers, schools and playgrounds.

Land use designations with air pollution sources of concern include freeways, rail yards, ports, refineries, distribution centers, chrome plating facilities, dry cleaners and large gasoline service stations. Key recommendations in the CARB Handbook include taking steps to avoid siting new, sensitive land uses:
• Within 500 feet of a freeway, urban roads with 100,000 vehicles/day or rural roads with 50,000 vehicles/day;
• Within 1,000 feet of a major service and maintenance rail yard; 7 California Air Resources Board. 2005. Air Quality and Land Use Handbook: A Community Health Perspective.

April.
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4.2 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) -16 • Immediately downwind of ports (in the most heavily impacted zones) and petroleum refineries; • Within 300 feet of any dry cleaning operation (for operations with two or more machines, provide 500 feet); and
• Within 300 feet of a large gas station (defined as a facility with a throughput of 3.6 million gallons per year or greater).

The CARB Handbook specifically states that its recommendations are advisory and acknowledges land use agencies have to balance other considerations, including housing and transportation needs, economic development priorities, and other quality of life issues.

The recommendations are generalized and do not consider site specific meteorology, freeway truck percentages or other factors that influence risk for a particular project site. The purpose of the land use compatibility analysis is to further examine the project site for actual health risk associated with the location of new housing on the project site.

4.2.2.3 Regional Regulations
San Joaquin Valley Air Pollution Control District. The SJVAPCD is responsible for controlling emissions primarily from stationary sources. The SJVAPCD maintains air quality monitoring stations throughout the basin. The SJVAPCD, in coordination with the eight county transportation agencies, is also responsible for developing, updating, and implementing air quality attainment plans for the Air Basin. The SJVAPCD also has roles under CEQA.

Guide for Assessing and Mitigating Air Quality Impacts. The SJVAPCD provides guidance and thresholds for CEQA air quality and greenhouse gas analyses. The result of this guidance as well as State regulations to control air pollution is an overall improvement in the Basin. In particular, the SJVAPCD’s Guide for Assessing and Mitigating Air Quality Impacts (GAMAQI) states the following:

The SJVAPCD’s Air Quality Attainment Plans include measures to promote air quality elements in county and city general plans as one of the primary means of reducing indirect emissions such as those from land use development projects. The approved General Plan is the primary long range planning document used by cities and counties to direct development. Since air districts have no authority over land use decisions, it is up to cities and counties to ensure that their general plans help achieve air quality goals. Section 65302.1 of the California Government Code requires cities and counties in the San Joaquin Valley to amend appropriate elements of their general plans to include data, analysis, comprehensive goals, policies, and feasible implementation strategies to improve air quality in their next housing element revisions.

The SJVAB is classified nonattainment for ozone, PM10, and PM2.5. The SJVAPCD had adopted project level thresholds based on a cumulative contribution of ozone precursors ROG and NOx of 10 tons per year and thresholds for PM10 and PM2.5 of 15 tons per year. 924
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) 4.2-17 Current Air Quality Plans. The SJVAPCD is responsible for formulating and implementing the Air Quality Management Plan (AQMP) for the Basin. The main purpose of an AQMP is to bring the area into compliance with federal and State air quality standards. The SJVAPCD does not have one single AQMP for criteria pollutants, rather the SJVAPCD address each criteria pollutant with its own Plan. The SJVAPCD has the following AQMPs:
• 2022 Plan for the 2015 8-Hour Ozone Standard
• 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards • 2016 Moderate Area Plan for the 2012 PM2.5 standard
• 2016 Plan for the 2008 8-Hour Ozone Standard
• 2013 Plan for the Revoked 1-Hour Ozone Standard
• 2007 PM10 Maintenance Plan
• 2004 Revision to the California State Implementation Plan for Carbon Monoxide The SJVAPCD’s AQMPs incorporate the latest scientific and technological information and planning assumptions, including updated emission inventory methodologies for various source categories. The SJVAPCD’s AQMPs included the integrated strategies and measures needed to meet the national ambient air quality standards (NAAQS), implementation of new technology measures, and demonstrations of attainment of the 1-hour and 8-hour ozone NAAQS as well as the latest 24-hour and annual PM2.5 standards.

The SJVAPCD’s current air quality plans are discussed below.

Ozone Plans. The SJVAPCD’s Governing Board approved the 2022 Plan for the 2015 8-hour ozone standard on December 15, 2022. The comprehensive strategy in this plan will reduce NOx emissions by 72 percent by 2037 and will bring the San Joaquin Valley into attainment of USEPA’s 2015 8-hour ozone standard as expeditiously as practicable by the 2037 attainment deadline.

Particulate Matter Plans. The SJVAPCD adopted the 2007 PM10 Maintenance Plan in September 2007 to assure the SJVAB’s continued attainment of the USEPA’s PM10 standard.

The USEPA designated the valley as an attainment/maintenance area for PM10.

The 2008 PM2.5 Plan builds upon the comprehensive strategy adopted in the 2007 Ozone Plan to bring the Basin into attainment of the 1997 national standards for PM2.5. The USEPA has identified NOx and SO2 as precursors that must be addressed in air quality plans for the 1997 PM2.5 standards. The 2008 PM2.5 Plan is a continuation of the SJVACPD’s strategy to improve the air quality in the SJVAB.

The SJVAPCD prepared the 2012 PM2.5 Plan to bring the San Joaquin Valley into attainment of the USEPA’s most recent 24‐hour PM2.5 standard of 35 μg/m³. The CARB approved the SJVAPCD’s 2012 PM2.5 Plan at a public hearing on January 24, 2013. The plan, approved by the SJVAPCD Governing Board on December 20, 2012, will bring the Valley into attainment of USEPA’s 1997 PM2.5 standard as expeditiously as practicable, but no later than, December 31, 2020.
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4.2 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) -18 The SJVAPCD adopted the 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards on November 15, 2018. This plan addresses the USEPA federal 1997 annual PM2.5 standard of 15 μg/m³ and 24-hour PM2.5 standard of 65 μg/m³; the 2006 24-hour PM2.5 standard of 35 μg/m³; and the 2012 annual PM2.5 standard of 12 μg/m³. This plan demonstrates attainment of the federal PM2.5 standards as expeditiously as practicable.

Rules and Regulations. The SJVAPCD rules and regulations that may apply to projects that will occur during buildout of the Plan Area include but are not limited to the following:
• Rule 2280—Portable Equipment Registration. Portable equipment used at project sites for less than six consecutive months must be registered with the SJVAPCD. The SJVAPCD will issue the registrations 30 days after receipt of the application. • Rule 2303-Mobile Source Emission Reduction Credits. A project may qualify for SJVAPCD vehicle emission reduction credits if it meets the specific requirements of Rule 2303 for any of the following categories:
○ Low-Emission Transit Buses
○ Zero-Emission Vehicles
○ Retrofit Passenger Cars, Light-Duty Trucks, and Medium-Duty Vehicles ○ Retrofit Heavy-Duty Vehicles
• Rule 4102 – Nuisance. The purpose of this rule is to protect the health and safety of the public, and applies to any source operation that emits or may emit air contaminants or other materials.
• Rule 4601 – Architectural Coatings. The purpose of this rule is to limit Volatile Organic Compounds (VOC) emissions from architectural coatings. Emissions are reduced by limits on VOC content and providing requirements on coatings storage, cleanup, and labeling.
• Rule 4641 – Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operations. The purpose of this rule is to limit VOC emissions from asphalt paving and maintenance operations. The paving operations for new development and existing paved surfaces will be subject to Rule 4641.
• Rule 8011—General Requirements: Fugitive Dust Emission Sources. Fugitive dust regulations are applicable to outdoor fugitive dust sources. Operations, including construction operations, must control fugitive dust emissions in accordance with SJVAPCD Regulation VIII. According to Rule 8011, the SJVAPCD requires the implementation of control measures for fugitive dust emission sources. For projects in which construction-related activities would disturb equal to or greater than 1 acre of surface area, the SJVAPCD recommends that demonstration of receipt of an SJVAPCDapproved Dust Control Plan or Construction Notification Form, before issuance of the first grading permit, be made a condition of approval.
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) 4.2-19 • Regulation VIII – Fugitive PM10 Prohibitions. Rules 8011‐8081 are designed to reduce PM10 emissions (predominantly dust/dirt) generated by human activity, including construction and demolition activities, road construction, bulk materials storage, paved and unpaved roads, carryout and track out, etc. All development projects that involve soil disturbance are subject to at least one provision of the Regulation VIII series of rules.
• Rule 9410 – Employer Based Trip Reduction. The purpose of this rule is to reduce vehicle miles traveled (VMT) from private vehicles used by employees to commute to and from their worksites in order to reduce emissions of NOx, VOC and PM. The rule requires larger employers (those with 100 or more eligible employees) to establish employee trip reduction programs to reduce VMT, reducing emissions associated with work commutes. The rule uses a menu-based Employer Trip Reduction Implementation Plan and periodic reporting requirements to evaluate performance on a phased‐in compliance schedule.
• Rule 9510 – Indirect Source Review. This rule reduces the impact of NOx and PM10 emissions from new development projects. The rule places application and emission reduction requirements on development projects meeting applicability criteria in order to reduce emissions through onsite mitigation, offsite SJVAPCD‐administered projects, or a combination of the two. Compliance with SJVAPCD Rule 9510 reduces emissions impacts through incorporation of onsite measures as well as payment of an offsite fee that funds emission reduction projects in the Air Basin. The emissions analysis for Rule 9510 is detailed and is dependent on the exact project design that is expected to be constructed or installed. Compliance with Rule 9510 is separate from the CEQA process, though the control measures used to comply with Rule 9510 may be used to mitigate significant air quality impacts.
• Odor impacts on residential areas and other sensitive receptors, such as hospitals, day‐care centers, schools, etc., warrant the closest scrutiny, but consideration could also be given to other land uses where people may congregate, such as recreational facilities, worksites, and commercial areas. While offensive odors rarely cause any physical harm, they can be very unpleasant, leading to considerable distress among the public and often generating citizen complaints to local governments and the SJVAPCD.

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. The SJVAPCD has determined the common land use types that are known to produce odors in the Basin. These types are shown in Table 4.2.E.
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4.2 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) -20 Table 4.2.E: Screening Levels for Potential Odor Sources Odor Generator 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
Source: San Joaquin Valley Air Pollution Control District (2015b).

Fresno Council of Governments. Fresno Council of Governments (FCOG) is responsible for regional transportation planning in Fresno county and participates in developing mobile source emission inventories used in air quality attainment plans.

Regional Transportation Plan/Sustainable Communities Strategy. Regional Transportation Plans (RTPs) are State-mandated plans that identify long-term transportation needs for a region’s transportation network. Fresno Council of Governments’ (FCOG) 2018 RTP charts the long‐range vision of regional transportation in Fresno county through the year 2042. The RTP identifies existing and future transportation related needs, while considering all modes of travel, analyzing alternative solutions, and identifying priorities for the anticipated available funding for the 1,100 projects and multiple programs included within it. Senate Bill 375 (SB 375), which went into effect in 2009, added statutes to the California Government Code to encourage planning practices that create sustainable communities. It calls for each metropolitan planning organization to prepare a Sustainable Communities Strategy (SCS) as an integrated element of the RTP that is to be updated every four years. The SCS is intended to show how integrated land use and transportation planning can lead to lower greenhouse gas (GHG) emissions from autos and light trucks. Fresno COG has included the SCS in its 2018 RTP.

Transportation Conformity. FCOG must ensure that transportation plans and projects comply with Federal Transportation Conformity. Transportation conformity is a way to ensure that Federal funding and approval are given to those transportation activities that are consistent with air quality goals. It ensures that these transportation activities do not worsen air quality or interfere with the "purpose" of the State Implementation Plan, which is to meet the NAAQS. Meeting the NAAQS often requires emissions reductions from mobile sources. According to the Clean Air Act, transportation plans, programs, and projects cannot:
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) 4.2-21 • Create new NAAQS violations;
• Increase the frequency or severity of existing NAAQS violations; or • Delay attainment of the NAAQS.

In practice, air quality plans include criteria pollutant emission budgets required for attainment of air quality standards by mandated deadlines. The budgets must not be exceeded considering projected growth in mobile source activity. The FCOG 2019 Conformity Analysis determined that the conformity tests for ozone, PM10 and PM2.5 revealed that all years are projected to be less than the approved emissions budgets and, as such, the conformity tests are satisfied.

4.2.2.4 Local Regulations
City of Clovis General Plan. The City of Clovis addresses air quality in the Air Quality Element of the General Plan. The Air Quality Element provides goals, policies, and action items that work to meet or exceed all State and federal air quality standards. Applicable air quality policies and action items from the Air Quality Element are listed in Table 4.2.F below.

Table 4.2.F: City of Clovis General Plan Policies Related to Air Quality Policy/Action
Item Number Policy/Action Item
Air Quality Element
Policy 1.1 Land use and transportation. Reduce greenhouse gas and other local pollutant emissions through mixed use and transit-oriented development and well-designed transit, pedestrian, and bicycle systems.

Policy 1.3 Construction activities. Encourage the use of best management practices during construction activities to reduce emissions of criteria pollutants as outlined by the San Joaquin Valley Air Pollution Control District (SJVAPCD).

Policy 1.6 Alternative fuel infrastructure. Encourage public and private activity and employment centers to incorporate electric charging and alternative fuel stations.

Policy 1.8 Trees. Maintain or plant trees where appropriate to provide shade, absorb carbon, improve oxygenation, slow stormwater runoff, and reduce the heat island effect.

Policy 2.1 Regional coordination. Support regional efforts to reduce air pollution (criteria air pollutants and greenhouse gas emissions) and collaborate with other agencies to improve air quality at the emission source and reduce vehicle miles traveled.

Policy 2.6 Innovative mitigation. Encourage innovative mitigation measures to reduce air quality impacts by coordinating with the SJVAPCD, project applicants, and other interested parties.

Source: City of Clovis General Plan (August 2014).

4.2.3 Impacts and Mitigation Measures
The following section presents a discussion of the impacts related to air quality that could result from implementation of the proposed project. The section begins with the criteria of significance, which establish the thresholds to determine if an impact is significant. The latter part of this section presents the impacts associated with implementation of the proposed project and the recommended mitigation measures. Mitigation measures are recommended, as appropriate, for 929
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4.2 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) -22 significant impacts to eliminate or reduce them to a less-than-significant level. Cumulative impacts are also addressed.

4.2.3.1 Significance Criteria
Based on CEQA Guidelines Appendix G, the proposed project would have a significant impact on air quality if it 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 is nonattainment under an applicable federal or state ambient air quality standard; c. Expose sensitive receptors to substantial pollutant concentrations; or d. Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

4.2.3.2 Regional Emissions Thresholds
A threshold of significance is defined by the SJVAPCD in its GAMAQI8 as an identifiable quantitative, qualitative, or performance level of a particular environmental effect. Non-compliance with a threshold of significance means the effect will normally be determined to be significant. Compliance with a threshold of significance means the effect normally will be determined to be less than significant. The SJVAPCD has established thresholds of significance for criteria pollutant emissions generated during construction and operation of projects as shown in Table 4.2.G below.

Table 4.2.G: SJVAPCD Construction and Operation Thresholds of Significance (Tons per Year)
CO NOx ROG SOx PM10 PM2.5
Construction Thresholds 100 10 10 27 15 15
Operation Thresholds 100 10 10 27 15 15
Source: Guidance for Assessing and Mitigating Air Quality Impacts (SJVAPCD 2015a).

The emissions thresholds in the SJVAPCD GAMAQI were established based on the attainment status of the air basin in regard to air quality standards for specific criteria pollutants. Because the concentration standards were set at a level that protects public health with an adequate margin of safety, these emission thresholds are regarded as conservative and would overstate an individual project’s contribution to health risks.
8 San Joaquin Valley Air Pollution Control District. 2015a. Guidance for Assessing and Mitigating Air Quality Impacts. Website: https://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT-GAMAQI.PDF (accessed January 2023.
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4.2.3.3 Health Risk Thresholds
Both the State and federal governments have established health-based ambient air quality standards (AAQS) for seven air pollutants. For other air pollutants without defined significance standards, the definition of substantial pollutant concentrations varies. For TACs, “substantial” is taken to mean that the individual health risk exceeds a threshold considered to be a prudent risk management level.

The following limits for maximum individual cancer risk (MICR) and noncancer acute and chronic Hazard Index (HI) from project emissions of TACs are considered appropriate for use in determining the health risk for projects in the Basin:
• MICR: MICR is the estimated probability of a maximum exposed individual (MEI) contracting cancer as a result of exposure to TACs over a period of 70 years for adults and 9 years for children in residential locations, 350 days per year. The SJVAPCD’s Update to the District’s Risk Management Policy to Address the OEHHA Revised Risk Assessment Guidance Document states that emissions of TACs are considered significant if an HRA shows an increased risk of greater than 20 in 1 million.
• Chronic HI: Chronic HI is the ratio of the estimated long-term level of exposure to a TAC for a potential MEI to its chronic reference exposure level. The chronic HI calculations include multipathway consideration when applicable. The project would be considered significant if the cumulative increase in total chronic HI for any target organ system would exceed 1.0 at any receptor location.
• Acute HI: Acute HI is the ratio of the estimated maximum 1-hour concentration of a TAC for a potential MEI to its acute reference exposure level. The project would be considered significant if the cumulative increase in total acute HI for any target organ system would exceed 1.0 at any receptor location.

4.2.3.4 Project Impacts
The following discussion describes the potential impacts related to air quality that could result from implementation of the proposed project.
a. Would the project conflict with or obstruct implementation of the applicable air quality plan? An air quality plan describes air pollution control strategies to be implemented by a city, county, or region classified as a nonattainment area. The main purpose of the air quality plan is to bring the area into compliance with the requirements of the federal and State air quality standards. To bring the San Joaquin Valley into attainment, the SJVAPCD adopted the 2022 Plan for the 2015 8-hour 931
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4.2 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) -24 ozone standard in December 2022 to satisfy Clean Air Act requirements and ensure attainment of the 70 parts per billion (ppb) 8-hour ozone standard.9
To ensure the SJVAB’s continued attainment of the USEPA PM10 standard, the SJVAPCD adopted the 2007 PM10 Maintenance Plan in September 2007.10 The SJVAPCD adopted the 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards in November 2018 to address the USEPA 1997 annual PM2.5 standard of 15 micrograms per cubic meter (µg/m3
) and 24-hour PM2.5 standard of 65 µg/m3, the
2006 24-hour PM2.5 standard of 35 μg/m³, and the 2012 annual PM2.5 standard of 12 μg/m³.11 CEQA requires that certain proposed projects be analyzed for consistency with the applicable air quality plan as it relates to a region’s non-attainment status. An air quality plan describes air pollution control strategies to be implemented in a non-attainment area. The main purpose of the air quality plan is to bring the area into compliance with the requirements of the federal and State air quality standards. As discussed above, the SJVAB is designated as non-attainment for O3 and PM2.5 for federal standards and non-attainment for O3, PM10, and PM2.5 for State standards.

Therefore, to bring the SJVAB into attainment, the SJVAPCD adopted the 2022 Plan for the 2015 8- Hour Ozone Standard in December 2022 to satisfy Clean Air Act requirements and ensure attainment of the 75 parts per billion (ppb) 8-hour ozone standard.

To assure the SJVAB’s continued attainment of the USEPA PM10 standard, the SJVAPCD adopted the 2007 PM10 Maintenance Plan in September 2007. SJVAPCD Regulation VIII (Fugitive PM10 Prohibitions) is designed to reduce PM10 emissions generated by human activity. The SJVAPCD adopted the 2018 plan for the 1997, 2006, and 2012 PM2.5 standards to address the USEPA federal annual PM2.5 standard of 12 µg/m3
, established in 2012.

For a project to be consistent with SJVAPCD air quality plans, the pollutants emitted from a project should not exceed the SJVAPCD emission thresholds or cause a significant impact on air quality. In addition, emission reductions achieved through implementation of offset requirements are a major component of the SJVAPCD air quality plans. As discussed below, construction of the proposed project is anticipated to occur in three consecutive phases occurring over a total 33-month period starting in December 2023 and would not result in the generation of criteria air pollutants that would exceed SJVAPCD thresholds of significance. In addition to the construction period thresholds of significance, the SJVAPCD has implemented Regulation VIII measures for dust control during construction. These control measures are intended to reduce the amount of PM10 emissions during the construction period. Implementation of the fugitive dust control measures outlined in 9 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2022. 2022 Plan for the 2015 8-Hour Ozone Standard. December 15. Website: https://ww2.valleyair.org/media/q55posm0/0000-2022-plan-for-the2015-8-hour-ozone-standard.pdf (accessed February 2023). 10 San Joaquin Valley Air Pollution Control District. 2007. 2007 PM10 Maintenance Plan and Request for Redesignation. Available online at: www.valleyair.org/Air_Quality_Plans/docs/Maintenance%20Plan10- 25-07.pdf (accessed September 2022). 11 San Joaquin Valley Air Pollution Control District. 2018. 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards. November 15. Website: http://valleyair.org/pmplans/documents/2018/pm-plan-adopted/ 2018-Plan-for-the-1997-2006-and-2012-PM2.5-Standards.pdf (accessed September 2022). 932
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) 4.2-25 Regulatory Compliance Measure AIR-2, would ensure that the proposed project complies with Regulation VIII, further reduces the short-term construction period air quality impacts, and ensures compliance with air quality plans. In addition, as discussed below and shown in Table 4.2.I, longterm operational emissions associated with the proposed project, including area, energy, and mobile source emissions, would also not exceed SJVAPCD established significance thresholds.

Therefore, impacts related to the proposed project’s potential to conflict with or obstruct implementation of the applicable air quality plan would be less than significant.

The proposed project’s potential air quality impacts from construction and operation would not exceed any applicable threshold of significance and would not conflict with or obstruct the applicable clean air plan. Therefore, the proposed project’s potential impacts on the applicable air quality plan are less than significant.

Impact AIR-1: The project would not conflict with or obstruct implementation of the applicable air quality plan.

Level of Significance Without Mitigation: Less than Significant. No mitigation is required. b. Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project is nonattainment under an applicable federal or state ambient air quality standard?
The SJVAB is designated as non-attainment for O3 and PM2.5 for federal standards and nonattainment for O3, PM10, and PM2.5 for State standards. The SJVAPCD’s nonattainment status is attributed to the region’s development history. Past, present, and future development projects contribute to the region’s adverse air quality impacts on a cumulative basis. By its very nature, air pollution is largely a cumulative impact. No single project is sufficient in size to, by itself, result in nonattainment of ambient air quality standards. Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts. If a project’s contribution to the cumulative impact is considerable, then the project’s impact on air quality would be considered significant.

In developing thresholds of significance for air pollutants, the SJVAPCD considered the emission levels for which a project’s individual emissions would be cumulatively considerable. If a project exceeds the identified significance thresholds, its emissions would be cumulatively considerable, resulting in significant adverse air quality impacts to the region’s existing air quality conditions.

The proposed project would consist of the annexation of 246 acres by the City of Clovis, and the development of 590 residential lots, averaging 3,329 square feet within the 71.54-acre project site.

No development is proposed within the remaining 174.46-acre annexation area surrounding the project site. The proposed project would include annexation of the 174.46-acre area from Fresno County jurisdiction to the City of Clovis. Any future development occurring within the annexation area would require a separate project-specific analysis. The following analysis assesses the potential project-level construction- and operation-related air quality impacts. 933
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4.2 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) -26 Short-Term Construction Emissions. During construction, short-term degradation of air quality may occur due to the release of particulate emissions generated by grading, paving, building, and other activities. Emissions from construction equipment are also anticipated and would include CO, NOx, ROG, directly-emitted particulate matter (PM2.5 and PM10), and TACs such as diesel exhaust particulate matter.

Construction activities associated with implementation of the proposed project would include demolition, site preparation, grading, paving, and building activities. Construction-related effects on air quality from the proposed project would be greatest during the site preparation phase due to the disturbance of soils. If not properly controlled, these activities would temporarily generate particulate emissions. Sources of fugitive dust would include disturbed soils at the construction site.

Unless properly controlled, vehicles leaving the site would deposit dirt and mud on local streets, which could be an additional source of airborne dust after it dries. PM10 emissions would vary from day to day, depending on the nature and magnitude of construction activity and local weather conditions. PM10 emissions would depend on soil moisture, silt content of soil, wind speed, and the amount of operating equipment. Larger dust particles would settle near the source, while fine particles would be dispersed over greater distances from the construction site.

Water or other soil stabilizers can be used to control dust, resulting in emission reductions of 50 percent or more. The SJVAPCD has implemented Regulation VIII measures for reducing fugitive dust emissions (PM10). With the implementation of Regulation VIII measures, fugitive dust emissions from construction activities would not result in adverse air quality impacts.

In addition to dust-related PM10 emissions, heavy trucks and construction equipment powered by gasoline and diesel engines would generate CO, SO2, NOx, ROG, and some soot particulate (PM2.5 and PM10) in exhaust emissions. If construction activities were to increase traffic congestion in the area, CO and other emissions from traffic would increase slightly while those vehicles idle in traffic. These emissions would be temporary in nature and limited to the immediate area surrounding the construction site.

Construction emissions for the proposed project were analyzed using CalEEMod. Construction of the proposed project is anticipated to occur in three phases over a 33-month period starting in December 2023 and ending in September 2026. Construction phases are expected to occur consecutively; therefore, this analysis evaluates construction emissions as a whole and not per phase. Site preparation would include demolition of existing structures, and removal of rocks, debris, and vegetation from the project site and grading would require the import of approximately 41,000 cubic yards of soil to level the project site, which was included in CalEEMod. In addition, this analysis assumes that the proposed project would be constructed using Tier 2 construction equipment, which was included in CalEEMod. Other precise details of construction activities are unknown at this time; therefore, default assumptions (e.g., construction worker and truck trips and construction fleet activities) from CalEEMod were used. Construction-related emissions are presented in Table 4.2.H. CalEEMod output sheets are included in Appendix D.

As described in a) above, for a project to be consistent with SJVAPCD air quality plans, the pollutants emitted from a project should not exceed the SJVAPCD emission thresholds or cause a significant 934
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) 4.2-27 impact on air quality, and a project should comply with applicable offset requirements that reduce project emissions pursuant to goals of SJVAPCD air quality plans.

As shown in Table 4.2.H, construction emissions for the proposed project would not exceed the SJVAPCD annual threshold for construction emissions. In addition to the construction period thresholds of significance, the SJVAPCD has implemented Regulation VIII measures for dust control during construction. These control measures are intended to reduce the amount of PM10 emissions during the construction period. Implementation of the fugitive dust control measures outlined in Regulatory Compliance Measure AIR-2, would ensure that the proposed project complies with Regulation VIII, further reduces the short-term construction period air quality impacts and ensures compliance with air quality plans.

Table 4.2.H: Project Construction Emissions (Tons Per Year) Project Construction ROG NOx CO SO2 PM10 PM2.5
2023 <0.1 0.3 0.2 <0.1 <0.1 <0.1
2024 0.2 4.7 3.6 <0.1 1.0 0.4
2025 0.2 2.7 2.8 <0.1 0.2 0.1
2026 0.1 1.8 1.9 <0.1 0.1 <0.1
Maximum Annual Construction
Emissions

0.2 4.7 3.6 <0.1 1.0 0.4
SJVAPCD Thresholds 10.0 10.0 100.0 27.0 15.0 15.0
Exceeds? No No No No No No
Source: Compiled by LSA (February 2023).

CO = carbon monoxide
NOX = nitrous oxides
PM2.5 = particulate matter less than 2.5 microns in size PM10 = particulate matter less than 10 microns in size
ROG = reactive organic compounds
SJVAPCD = San Joaquin Valley Air Pollution Control District SO2 = sulfur dioxide
Therefore, with compliance with regulatory requirements (as specified in Regulatory Compliance Measure AIR-2), construction of the proposed project would result in a less than significant impact related to a cumulative considerable net increase of any criteria pollutant for which the project region is in nonattainment under an applicable federal or State ambient air quality standard.

Long-Term Operational Emissions. Long-term air pollutant emission impacts associated with the proposed project are those related to mobile sources (e.g., vehicle trips), energy sources (e.g., natural gas), and area sources (e.g., architectural coatings and the use of landscape maintenance equipment). The proposed project would not include natural gas.

PM10 emissions result from running exhaust, tire and brake wear, and the entrainment of dust into the atmosphere from vehicles traveling on paved roadways. Entrainment of PM10 occurs when vehicle tires pulverize small rocks and pavement, and the vehicle wakes generate airborne dust. The contribution of tire and brake wear is small compared to the other PM emission processes.

Gasoline-powered engines have small rates of particulate matter emissions compared with dieselpowered vehicles. Trip generation rates for the proposed project were based on the project’s trip generation estimate, as identified in Section 4.5, Transportation. As discussed in Section 4.5, Transportation, the proposed project would generate approximately 5,564 average daily trips. 935
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4.2 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) -28 Energy source emissions result from activities in buildings for which natural gas is used. As identified above, the proposed project would not include natural gas; therefore, the proposed project would not result in energy source emissions.

Area source emissions associated with the proposed project would include emissions from the use of architectural coatings, consumer products, and landscaping equipment.

Emission estimates for operation of the project were calculated using CalEEMod. The primary emissions associated with the project are regional in nature, meaning that air pollutants are rapidly dispersed on release or, in the case of vehicle emissions associated with the project, emissions are released in other areas of the SJVAB. The annual emissions associated with project operational trip generation, energy, and area sources are identified in Table 4.2.I for ROG, NOx, CO, sulfur oxide (SOx), PM10, and PM2.5. CalEEMod output sheets are included in Appendix D.

Table 4.2.I: Project Operation Emissions (Tons Per Year) ROG NOX CO SOX PM10 PM2.5
Mobile source Emissions 3.4 3.3 22.7 0.1 2.0 0.4
Area Source Emissions 5.1 0.3 5.6 <0.1 0.8 0.8
Energy Source Emissions 0.0 0.0 0.0 0.0 0.0 0.0
Total Project Operation Emissions 8.5 3.6 28.3 0.1 2.8 1.2 SJVAPCD Significance Threshold 10.0 10.0 100.0 27.0 15.0 15.0 Exceed Threshold? No No No No No No
Source: Compiled by LSA (February 2023).

Note: Some values may not appear to add up correctly due to rounding.

CO = carbon monoxide
NOX = nitrous oxides
PM2.5 = particulate matter less than 2.5 microns in size PM10 = particulate matter less than 10 microns in size
ROG = reactive organic compounds
SJVAPCD = San Joaquin Valley Air Pollution Control District SOX = sulfur oxide
The results in Table 4.2.I indicate the proposed project’s operational emissions would not exceed the significance criteria for annual ROG, NOx, CO, SOx, PM10, or PM2.5 emissions. Therefore, operation of the proposed project would result in a less-than-significant impact related to a cumulatively considerable net increase of any criteria pollutant for which the proposed project region is in nonattainment under an applicable federal or State ambient air quality standard.

Impact AIR-2: Implementation of the proposed project would not result in a cumulatively considerable net increase of criteria pollutants for which the project region is non-attainment under an applicable federal or State ambient air quality standards.

Level of Significance Without Mitigation: Less Than Significant. No mitigation is required. The following regulatory compliance measure pertaining to air quality is applicable to the proposed project.

Regulatory Compliance Measure AIR-2 Consistent with SJVAPCD Regulation VIII (Fugitive PM10 Prohibitions), the following controls are required to be 936
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) 4.2-29 included as specifications for the proposed project and implemented at the construction site:
• All disturbed areas, including storage piles, which are not being actively utilized for construction purposes,
shall be effectively stabilized of dust emissions using water, chemical stabilizer/suppressant, covered with
a tarp or other suitable cover or vegetative ground
cover.
• All on-site unpaved roads and off-site unpaved access roads shall be effectively stabilized of dust emissions using water or chemical stabilizer/suppressant.
• All land clearing, grubbing, scraping, excavation, land leveling, grading, cut and fill, and demolition activities shall be effectively controlled of fugitive dust
emissions utilizing application of water or by
presoaking.
• When materials are transported off-site, all material shall be covered, or effectively wetted to limit visible dust emissions, and at least 6 inches of freeboard
space from the top of the container shall be
maintained.
• All operations shall limit or expeditiously remove the accumulation of mud or dirt from adjacent public
streets at the end of each workday. (The use of dry
rotary brushes is expressly prohibited except where
preceded or accompanied by sufficient wetting to
limit the visible dust emissions. Use of blower devices is expressly forbidden.)
• Following the addition of materials to, or the removal of materials from, the surface of out-door storage
piles, said piles shall be effectively stabilized of
fugitive dust emission utilizing sufficient water or
chemical stabilizer/suppressant.

With the implementation of Regulation VIII measures, fugitive dust emissions from construction activities would not result in adverse air quality impacts.

Level of Significance With Mitigation: Implementation of Regulatory Compliance Measure AIR-2 would further reduce project-related air quality impacts to a less than significant level. 937
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4.2 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) -30 c. Would the project expose sensitive receptors to substantial pollutant concentrations? Sensitive receptors are defined as residential uses, schools, daycare centers, nursing homes, and medical centers. Individuals particularly vulnerable to diesel particulate matter are children, whose lung tissue is still developing, and the elderly, who may have serious health problems that can be aggravated by exposure to diesel particulate matter. Exposure from diesel exhaust associated with construction activity contributes to both cancer and chronic non-cancer health risks. The closest sensitive receptors include single-family residential uses located approximately 30 feet south of the project site along Baron Avenue and Heirloom Lane, approximately 100 feet east of the project site across Baron Avenue, and approximately 230 feet west of the project site.

Known health effects related to ozone include worsening of bronchitis, asthma, and emphysema and a decrease in lung function. Particulate matter can also lead to a variety of health effects in people. These include premature death of people with heart or lung disease, heart attacks, irregular heartbeat, decreased lung function, and increased respiratory symptoms.

A construction HRA, which evaluates construction-period health risk to off-site receptors, was performed for the proposed project and is summarized below. The project site is located near existing residential uses that could be exposed to diesel emission exhaust during the construction period.

To estimate the potential cancer risk associated with equipment exhaust (including diesel particulate matter) released during construction of the proposed project, a dispersion model was used to translate an emission rate from the source location to a concentration at the receptor location of interest (i.e., a nearby residence and worksites). Dispersion modeling varies from a simpler, more conservative screening-level analysis to a more complex and refined detailed analysis.

This refined assessment was conducted using the CARB exposure methodology with the air dispersion modeling performed using the USEPA dispersion model AERMOD. The model provides a detailed estimate of exhaust concentrations based on site and source geometry, source emissions strength, distance from the source to the receptor, and meteorological data.

Both the State and federal governments have established health-based AAQS for seven air pollutants. For other air pollutants without defined significance standards, the definition of substantial pollutant concentrations varies. For TACs, “substantial” is taken to mean that the individual health risk exceeds a threshold considered to be a prudent risk management level.

The following limits for maximum individual cancer risk (MICR) and noncancer acute and chronic Hazard Index (HI) from project emissions of TACs are considered appropriate for use in determining the health risk for projects in the Basin:
• MICR: MICR is the estimated probability of a maximum exposed individual (MEI) contracting cancer as a result of exposure to TACs over a period of 70 years for adults and 9 years for children in residential locations, 350 days per year. The SJVAPCD’s Update to the District’s Risk Management Policy to Address the OEHHA Revised Risk Assessment Guidance Document states that emissions of TACs are considered significant if an HRA shows an increased risk of greater than 20 in 1 million.
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) 4.2-31 • Chronic HI: Chronic HI is the ratio of the estimated long-term level of exposure to a TAC for a potential MEI to its chronic reference exposure level. The chronic HI calculations include multipathway consideration when applicable. The project would be considered significant if the cumulative increase in total chronic HI for any target organ system would exceed 1.0 at any receptor location.
• Acute HI: Acute HI is the ratio of the estimated maximum 1-hour concentration of a TAC for a potential MEI to its acute reference exposure level. The project would be considered significant if the cumulative increase in total acute HI for any target organ system would exceed 1.0 at any receptor location.

Table 4.2.J, below, identifies the results of the analysis assuming the use of Tier 2 construction equipment, as proposed by the project, at the maximally exposed individual (MEI), which is the nearest sensitive receptor. Model images and details related to the modeled sources are shown in Appendix E of this EIR.

Table 4.2.J: Inhalation Health Risks from Project Construction to Off-Site Receptors
Carcinogenic Inhalation
Health Risk in One Million
Chronic Inhalation
Hazard Index
Acute Inhalation
Hazard Index
Sensitive Receptor Risk 9.93 0.009 0.000
Worker Receptor Risk 0.06 0.009 0.000
Threshold 20.0 1.0 1.0
Exceed? No No No
Source: LSA (February 2023)
µg/m3 = micrograms per cubic meter
PM2.5 = particulate matter less than 2.5 microns in size As shown in Table 4.2.J, the maximum cancer risk for the sensitive receptor MEI would be 9.93 in one million, which would not exceed the SJVAPCD cancer risk threshold of 20 in one million. The worker receptor risk would be lower at 0.06 in one million, which would also not exceed the threshold. The total chronic hazard index would be 0.009 for both the sensitive receptor MEI and worker receptor MEI, which would be below the threshold of 1.0. In addition, the total acute hazard index would be nominal (0.000), which would also not exceed the threshold of 1.0. Therefore, construction of the proposed project would not exceed SJVAPCD thresholds and would not expose nearby sensitive receptors to substantial pollutant concentrations and this impact would be less than significant.

Once the proposed project is constructed, the proposed project would not be a source of substantial emissions. Therefore, implementation of the proposed project would not result in new sources of TACs. Therefore, the project would not expose sensitive receptors to substantial levels of TACs and this impact would be less than significant.

As such, the proposed project’s potential air quality impacts from construction and operation would not expose sensitive receptors to substantial pollutant concentrations. The proposed project would 939
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4.2 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) -32 not result in any individual health risk in excess of the thresholds considered to be prudent risk management levels. Therefore, the proposed project’s potential air quality impacts on sensitive receptors are less than significant.

Impact AIR-3: Implementation of the proposed project would not expose sensitive receptors to substantial pollutant concentrations.

Level of Significance Without Mitigation: Less than Significant. No mitigation is required. d. Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
During construction, the various diesel-powered vehicles and equipment in use on site would create localized odors. These odors would be temporary and are not likely to be noticeable for extended periods of time beyond the project site. Because the project’s potential construction-related odor impacts are localized and temporary, they would not adversely affect a substantial number of people. Therefore, the project’s potential construction-related odor impacts are less than significant.

The SJVAPCD addresses odor criteria within the Guidance for Assessing and Mitigating Air Quality Impacts (GAMAQI)12. The district has not established a rule or standard regarding odor emissions, rather, the district has a nuisance rule: “Any project with the potential to frequently expose members of the public to objectionable odors should be deemed to have a significant impact”. After construction, the proposed land use of the project is not anticipated to emit any objectionable odors. Therefore, the proposed project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

Impact AIR-4: The project would not result in significant odors that could adversely affect a substantial number of people.

Level of Significance Without Mitigation: Less than Significant. No mitigation is required.

4.2.3.5 Cumulative Impacts
According to the SJVAPCD, regional air pollution is largely a cumulative impact. No single project is sufficient in size to independently create regional nonattainment of ambient air quality standards.

Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts.

The SJVAPCD is currently designated as a nonattainment area for State and national ozone standards and national particulate matter ambient air quality standards. SJVAPCD nonattainment status is attributed to the region’s development history. Past, present, and future development 12 San Joaquin Valley Air Pollution Control District. 2015a. Guidance for Assessing and Mitigating Air Quality Impacts. Website: https://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT-GAMAQI.PDF (accessed January 2023.
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.2-Air_Quality.docx (01/10/24) 4.2-33 projects contribute to the region’s adverse air quality impacts on a cumulative basis. By its very nature, air pollution is largely a cumulative impact. No single project is sufficient in size to, by itself, result in nonattainment of ambient air quality standards. Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts. If a project’s contribution to the cumulative impact is considerable, then the project’s impact on air quality would be considered significant.

In developing thresholds of significance for air pollutants, the SJVAPCD considered the emission levels for which a project’s individual emissions would be cumulatively considerable. If a project exceeds the identified significance thresholds, its emissions would be cumulatively considerable, resulting in significant adverse air quality impacts to the region’s existing air quality conditions.

Therefore, if the proposed project’s annual emissions of construction- or operational-related criteria air pollutants exceed any applicable threshold established by the SJVAPCD, the proposed project would result in a considerable contribution to a cumulatively significant impact. As shown in Table

4.2.H and Table 4.2.I, the proposed project would not generate significant construction and operational emissions. Additionally, with implementation of Regulatory Compliance Measure AIR-2, the proposed project would further reduce short-term construction impacts and would be compliant with air quality plans. As shown in the project-specific air quality impacts discussion above, the proposed project would not result in individually significant impacts and therefore the proposed project would not result in a cumulatively considerable contribution to regional air quality impacts. Cumulative impacts would be considered less than significant.

In addition, as demonstrated in the analysis, the health risk levels to nearby residents from project construction- and operation-related emissions of TACs would be well below the SJVAPCD’s HRA thresholds. Therefore, the proposed project would not result in any individual health risk in excess of the thresholds considered to be prudent risk management levels. Therefore, the proposed project’s cumulative air quality impacts on sensitive receptors are less than significant.

Impact AIR-5: The proposed project, in combination with past, present, and reasonably foreseeable projects, would not contribute to a less than significant cumulative impact with respect to air quality.

Level of Significance Without Mitigation: Less than Significant. No mitigation is required. 941
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4.3 GREENHOUSE GAS EMISSIONS
This section summarizes existing greenhouse gas (GHG) emissions and discusses global climate change, its causes, and the contribution of human activities. This section also estimates the likely GHG emissions that would result from construction and operational activities associated with implementation of the proposed project, including vehicular traffic, energy consumption and other emission sources. Mitigation measures are recommended where appropriate to reduce impacts to a less-than-significant level. The analysis in this section is based on the California Emissions Estimator Model version 2022.1 (CalEEMod) (Appendix D).

4.3.1 Environmental Setting
The following discussion describes existing GHG emissions in the City of Clovis (City) and the and the San Joaquin Valley Air Basin (SJVAB), beginning with a discussion of typical GHG types and sources, impacts of global climate changes, the regulatory framework surrounding these issues, and current emission levels.

4.3.1.1 Background
The following section provides background information on GHGs and global climate change.

Greenhouse Gases. GHGs are present in the atmosphere naturally, are released by natural sources, or are formed from secondary reactions taking place in the atmosphere. The gases that are widely seen as the principal contributors to human-induced global climate change are the following:
• Carbon dioxide (CO2)
• Methane (CH4)
• Nitrous oxide (N2O)
• Hydrofluorocarbons (HFCs)
• Perfluorocarbons (PFCs)
• Sulfur Hexafluoride (SF6)
Over the last 200 years, humans have caused substantial quantities of GHGs to be released into the atmosphere. These extra emissions are increasing GHG concentrations in the atmosphere, and enhancing the natural greenhouse effect, which is believed to be causing global warming. While manmade GHGs include naturally-occurring GHGs such as CO2, methane, and N2O, some gases, like HFCs, PFCs, and SF6 are completely new to the atmosphere.

Certain gases, such as water vapor, are short-lived in the atmosphere. Others remain in the atmosphere for significant periods of time, contributing to climate change in the long term. Water vapor is excluded from the list of GHGs above because it is short-lived in the atmosphere and its atmospheric concentrations are largely determined by natural processes, such as oceanic evaporation. For the purposes of this air quality analysis, the term “GHGs” will refer collectively to the six gases listed above.

These gases vary considerably in terms of Global Warming Potential (GWP), which is a concept developed to compare the ability of each GHG to trap heat in the atmosphere relative to another 943
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4.3 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) -2 gas. The global warming potential is based on several factors, including the relative effectiveness of a gas to absorb infrared radiation and length of time that the gas remains in the atmosphere (“atmospheric lifetime”). The GWP of each gas is measured relative to carbon dioxide, the most abundant GHG; the definition of GWP for a particular GHG is the ratio of heat trapped by one unit mass of the GHG to the ratio of heat trapped by one unit mass of CO2 over a specified time period.

GHG emissions are typically measured in terms of pounds or tons of “CO2 equivalents” (CO2e).

Table 4.3.A shows the GWP for each type of GHG. For example, sulfur hexafluoride is 23,900 times more potent at contributing to global warming than carbon dioxide.

Table 4.3.A: Global Warming Potential of Greenhouse Gases Gas Atmospheric Lifetime
(Years)
Global Warming Potential
(100-year Time Horizon)
Carbon Dioxide 50-200 1
Methane 12 25
Nitrous Oxide 114 310
HFC-23 270 11,700
HFC-134a 14 140
HFC-152a 1.4 140
PFC: Tetrafluoromethane (CF4) 50,000 6,500
PFC: Hexafluoromethane (C2F6) 10,000 9,200
Sulfur Hexafluoride (SF6) 3,200 23,900
Source: Second Update to the Climate Change Scoping Plan: Building on the Framework (CARB 2017b). Website: www.arb.ca.gov/ourwork/programs/ab-32-climate-change-scoping-plan/2017-scoping-plan-documents (accessed February 2023).

The following discussion summarizes the characteristics of the six GHGs and black carbon. Black carbon also contributes to climate change and is therefore discussed below.

Carbon Dioxide. In the atmosphere, carbon generally exists in its oxidized form, as CO2. Natural sources of CO2 include the respiration (breathing) of humans, animals and plants, volcanic out gassing, decomposition of organic matter and evaporation from the oceans. Human caused sources of CO2 include the combustion of fossil fuels and wood, waste incineration, mineral production, and deforestation. Natural sources release approximately 150 billion tons of CO2 each year, far outweighing the 7 billion tons of man-made emissions of CO2 each year.

Nevertheless, natural removal processes, such as photosynthesis by land- and ocean-dwelling plant species, cannot keep pace with this extra input of man-made CO2, and consequently, the gas is building up in the atmosphere. In 2020, total annual CO2 accounted for approximately 80.2 percent of California's overall GHG emissions.1 Transportation is the single largest source of CO2 in California, which is primarily comprised of on-road travel. Electricity production, industrial, and residential sources also make important contributions to CO2 emissions in California. 1 California Air Resources Board (CARB). 2022d. GHGs Descriptions & Sources in California. Website:
ww2.arb.ca.gov/ghg-descriptions-sources (accessed January 2023). 944
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) 4.3-3 Methane. Methane (CH4) is produced when organic matter decomposes in environments lacking sufficient oxygen. Natural sources include wetlands and oceans. Decomposition occurring in landfills accounts for the majority of human generated CH4 emissions in California and in the United States as a whole. Agricultural processes such as intestinal fermentation in dairy cows, manure management, and rice cultivation are also significant sources of CH4 in California. Total annual emissions of CH4 accounted for approximately 10.5 percent of GHG emissions in California in 2020.

Nitrous Oxide. Nitrous oxide (N2O) is produced naturally by a wide variety of biological sources, particularly microbial action in soils and water. Tropical soils and oceans account for most natural source emissions. Nitrous oxide is a product of the reaction that occurs between nitrogen and oxygen during fuel combustion. Both mobile and stationary combustion emit N2O, and the quantity emitted varies according to the type of fuel, technology, and pollution control device used, as well as maintenance and operating practices. Agricultural soil management and fossil fuel combustion are the primary sources of human generated N2O emissions in California.

N2O emissions in California. Nitrous oxide emissions accounted for approximately 3.5 percent of GHG emissions in California in 2020.

Hydrofluorocarbons, Perfluorocarbons, and Sulfur Hexafluoride.HFCs are primarily used as substitutes for ozone-depleting substances regulated under the Montreal Protocol.2 PFCs and SF6 are emitted from various industrial processes, including aluminum smelting, semiconductor manufacturing, electric power transmission and distribution, and magnesium casting. There is no aluminum or magnesium production in California; however, the rapid growth in the semiconductor industry has resulted in greater use of PFCs. HFCs, PFCs, and SF6 accounted for about 5.8 percent of GHG emissions in California in 2020. 3 Black Carbon. Black carbon is the
most strongly light-absorbing component of particulate matter (PM) formed by burning fossil fuels such as coal, diesel, and biomass. Black carbon is emitted directly into the atmosphere in the form of particulate matter less than 2.5 microns in size (PM2.5) and is the most effective form of PM, by mass, at absorbing solar energy. Per unit of mass in the atmosphere, black carbon can absorb one million times more energy than CO2.
4 Black carbon contributes to climate change
both directly, such as absorbing sunlight, and indirectly, such as affecting cloud formation.

However, because black carbon is short-lived in the atmosphere, it can be difficult to quantify its effect on global warming.
2 The Montreal Protocol is an international treaty that was approved on January 1, 1989, and was designated to protect the ozone layer by phasing out the production of several groups of halogenated hydrocarbons believed to be responsible for ozone depletion. 3 Ibid. 4 United States Environmental Protection Agency (USEPA). 2017. Black Carbon, Basic Information. February 14, 2017. Website: 19january2017snapshot.epa.gov/www3/airquality/blackcarbon/basic.html (accessed September 2022).
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4.3 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) -4 Most U.S. emissions of black carbon come from mobile sources (52 percent), particularly from diesel fueled vehicles.5 The other major source of black carbon is open biomass burning, including wildfires, although residential heating and industry also contribute. The CARB estimates that the annual black carbon emissions in California will be reduced approximately 50 percent below 2013 levels by 2030.6
Effects of Global Climate Change. Effects from global climate change may arise from temperature increases, climate-sensitive diseases, extreme weather events, and air quality. There may be direct temperature effects through increases in average temperature leading to more extreme heat waves and less extreme cold spells. Those living in warmer climates are likely to experience more stress and heat-related problems. Heat-related problems include heat rash and heat stroke. In addition, climate-sensitive diseases may increase, such as those spread by mosquitoes and other diseasecarrying insects. Such diseases include malaria, dengue fever, yellow fever, and encephalitis.

Extreme events such as flooding and hurricanes can displace people and agriculture. Global climate change may also contribute to air quality problems from increased frequency of smog and particulate air pollution.7
Additionally, according to the 2006 California Climate Action Team (CAT) Report,8 the following climate change effects, which are based on trends established by the United Nations Intergovernmental Panel on Climate Change (IPCC), can be expected in California over the course of the next century:
• The loss of sea ice and mountain snow pack, resulting in higher sea levels and higher sea surface evaporation rates with a corresponding increase in tropospheric water vapor due to the atmosphere’s ability to hold more water vapor at higher temperatures;9 • Rise in global average sea level, primarily due to thermal expansion and melting of glaciers and ice caps in the Greenland and Antarctic ice sheets;10
• Changes in weather that include widespread changes in precipitation, ocean salinity, wind patterns, and more energetic aspects of extreme weather, including droughts, heavy precipitation, heat waves, extreme cold, and the intensity of tropical cyclones;11 5 United States Environmental Protection Agency (USEPA). 2017. Black Carbon, Basic Information. February 14, 2017. Website: 19january2017snapshot.epa.gov/www3/airquality/blackcarbon/basic.html (accessed September 2022). 6 CARB. 2017c. Short-Lived Climate Pollutant Reduction Strategy. March. Website: https://ww2.arb.ca.gov/ sites/default/files/2020-07/final_SLCP_strategy.pdf (accessed September 2022). 7 U.S. Environmental Protection Agency, 2016. Climate Impacts on Human Health. Website: 19january 2017snapshot.epa.gov/climate-impacts/climate-impacts-human-health_.html (accessed March 7, 2022). 8 California Environmental Protection Agency. 2006. Climate Action Team Report to Governor Schwarzenegger and the Legislature. March. 9 Ibid. 10 Ibid. 946
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) 4.3-5 • Decline of the Sierra snowpack, which accounts for approximately one-half of the surface water storage in California by 70 percent to as much as 90 percent over the next 100 years;12 • Increase in the number of days conducive to ozone (O3) formation by 25–85 percent (depending on the future temperature scenario) in high O3 areas of Los Angeles and the San Joaquin Valley by the end of the 21st century;13 and
• High potential for erosion of California’s coastlines and seawater intrusion into the Delta and levee systems due to the rise in sea level.14
A summary of these potential effects is provided in Table 4.3.B below.

Effects of Rising Ocean Levels in California. Rising ocean levels, more intense coastal storms, and warmer water temperatures may increasingly threaten the Long Beach coastal region. As previously described, global surface temperatures have increased by 1.5 degrees Fahrenheit (°F) during the period from 1880 to 2012, with temperatures anticipated to rise in California by 3 to 10.5°F by the end of the century.

Rising sea levels may affect the natural environment in the coming decades by eroding beaches, converting wetlands to open water, exacerbating coastal flooding, and increasing the salinity of estuaries and freshwater aquifers. Coastal headlands and beaches are expected to erode at a faster pace in response to future sea level rise. The California Coastal Commission estimates that 450,000 acres of wetlands exist along the California coast,15 but additional work is needed to evaluate the extent to which these wetlands would be degraded over time, or to what extent new wetland habitat would be created if those lands are protected from further development. Cumulatively, the effects of sea level rise may be combined with other potential long-term factors such as changes in sediment input and nutrient runoff. The cumulative impacts of physical and biological change due to sea level rise on the quality and quantity of coastal habitats are not well understood. 16 11 Intergovernmental Panel on Climate Change. 2007. Climate Change 2007: The Physical Science Basis, Summary for Policymakers. February. 12 California Environmental Protection Agency. 2006. op. cit. 13 California Environmental Protection Agency. 2006. op. cit. 14 Ibid. 15 California Coastal Commission (CCC). Procedural Guidance for the Review of Wetland Projects in California’s Coastal Zone. Website: http://www.coastal.ca.gov/wetrev/wetch4.html (accessed September 2022). 16 Climate Change Science Program (CCSP) 4.1. January 15, 2009, 1 of 784 Final Report, United States CCSP, Synthesis and Assessment Product 4.1. Coastal Sensitivity to Sea-Level Rise: A Focus on the Mid-Atlantic Region. Lead Agency: U.S. Environmental Protection Agency, Other Key Participating Agencies: U.S.

Geological Survey, National Oceanic and Atmospheric Administration. Contributing Agencies: Department of Transportation.
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4.3 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) -6 Table 4.3.B: Potential Impacts of Global Warming and Expected Consequences for California
Potential Water
Resource Impacts Anticipated Consequences Statewide
Reduction of the State’s
average annual snowpack
 Specifically, the decline of the Sierra snowpack, would lead to a loss in half of the surface water storage in California by 70% to 90% over the next 100 years  Potential loss of 5 million acre-feet or more of average annual water storage in the State’s snowpack
 Increased challenges for reservoir management and balancing the competing concerns of flood protection and water supply
 Higher surface evaporation rates with a corresponding increase in tropospheric water vapor
Rise in average sea level  Potential economic impacts related to coastal tourism, commercial fisheries, coastal agriculture, and ports
 Increased risk of flooding, coastal erosion along the State’s coastline, seawater intrusion into the Delta and levee systems
Changes in weather  Changes in precipitation, ocean salinity, and wind patterns  Increased likelihood for extreme weather events, including droughts, heavy precipitation, heat waves, extreme cold, and the intensity of tropical cyclones Changes in the timing,
intensity, location, amount,
and variability of precipitation
 Potential increased storm intensity and increased potential for flooding  Possible increased potential for droughts
 Long-term changes in vegetation and increased incidence of wildfires  Changes in the intensity and timing of runoff
 Possible increased incidence of flooding and increased sedimentation  Sea level rise and inundation of coastal marshes and estuaries  Increased salinity intrusion into the Sacramento-San Joaquin River Delta (Delta)  Increased potential for Delta levee failure
 Increased potential for salinity intrusion into coastal aquifers (groundwater)  Increased potential for flooding near the mouths of rivers due to backwater effects Increased water
temperatures
 Increased environmental water demand for temperature control  Possible increased problems with foreign invasive species in aquatic ecosystems  Potential adverse changes in water quality, including the reduction of dissolved oxygen levels
 Possible critical effects on listed and endangered aquatic species Changes in urban and
agricultural water demand
 Changes in demand patterns and evapotranspiration
Increase in the number of
days conducive to O3
formation
 Increased temperatures
 Potential health effects, including adverse impacts to respiratory systems Source: U.S. Department of the Interior, Environmental Water Account Draft Supplemental EIS/EIR to the Environmental Water Account Final EIS/EIR, Bureau of Reclamation Mid-Pacific Region, Sacramento, California (October 2007).

EIR = Environmental Impact Report
EIS = Environmental Impact Statement
O3 = ozone
Sea level along the west coast of the United States is affected by a number of factors, including climate patterns such as El Niño, effects from the melting of modern and ancient ice sheets, and geologic processes such as plate tectonics. Regional projections for California, Oregon, and Washington show a sharp distinction at Cape Mendocino in northern California. South of that point, sea-level rise is expected to be very close to global projections. Projections are lower north of Cape 948
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) 4.3-7 Mendocino because the land is being pushed upward as the ocean plate moves under the continental plate along the Cascadia Subduction Zone.

Emissions Inventories. An emissions inventory that identifies and quantifies the primary humangenerated sources and sinks of GHGs is a well-recognized and useful tool for addressing climate change. This section summarizes the latest information on global, United States, and California GHG emission inventories.

Global Emissions. Worldwide emissions of GHGs in 2018 totaled 25.6 billion metric tons (MT) of CO2e. Global estimates are based on country inventories developed as part of the programs of the United Nations Framework Convention on Climate Change.17 United States Emissions. In 2020, the year for which the most recent data are available, the United States emitted about 5,222 million metric tons of CO2e (MMT CO2e). Overall, emissions in 2020 decreased by 11 percent since 2019 and were 21 percent lower than 2005 levels. The primary driver for the decrease was an 11 percent decrease in CO2 emissions from fossil fuel combustion. This decrease was primarily due to a 13 percent decrease in transportation emissions driven by decreased demand due to the ongoing COVID-19 pandemic. Electric power sector emissions also decreased 10 percent, reflecting both a slight decrease in demand from the COVID-19 pandemic and a continued shift from coal to less carbon intensive natural gas and renewables. Of the five major sectors – residential and commercial, agricultural, industry, transportation, and electricity generation – transportation accounted for the highest amount of GHG emissions in 2020 (approximately 27 percent), with electricity generation second at 27 percent and emissions from industry third at 24 percent. 18 State of California Emissions. The State emitted approximately 369.2 MMT CO2e emissions in 2020, 35.3 MMT CO2e lower than 2019 levels and 61.8 MMT CO2e below the 2020 GHG limit of 431 MMT CO2e.19 The California Air Resources Board (CARB) estimates that transportation was the source of approximately 37 percent of the State’s GHG emissions in 2020, which is a smaller share than recent years, as the transportation sector saw a significant decrease of 26.6 MMT CO2e in 2020, likely due in large part to the impact of the COVID-19 pandemic. The next largest sources included industrial sources at approximately 20 percent and electricity generation at 16 percent. The remaining sources of GHG emissions were commercial and residential activities at 10 percent, agriculture at 9 percent, high GWP at 6 percent, and waste at 2 percent. 20 17 United Nations Framework Convention on Climate Change (UNFCCC). 2021. GHG Data from UNFCCC.

Website: unfccc.int/process-and-meetings/transparency-and-reporting/greenhouse-gas-data/ghg-dataunfccc/ghg-data-from-unfccc (accessed June 2022). 18 USEPA. 2021. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2019. Website: https://www. epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks-1990-2019 (accessed September 2022). 19 CARB. 2022c. California Greenhouse Gas Emissions for 2000 to 2020, Trends of Emissions and Other Indicators Report. Website: https://ww2.arb.ca.gov/sites/default/files/classic/cc/inventory/2000-2020_ ghg_inventory_trends.pdf (accessed January 2023). 20 Ibid. 949
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4.3 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) -8 City of Clovis. The City of Clovis prepared a Greenhouse Gas Emissions Inventory in 2012. The Inventory identifies the major sources and quantities of GHG emissions produced within the City of Clovis’ jurisdictional boundaries in 2012 and forecasts emissions changes over time.

Table 4.3.C shows the inventory.

Table 4.3.C: 2012 City of Clovis Community-Wide GHG Emissions Inventory by Sector Sector Description GHG Emissions
(Metric Tons CO2e)
Percent of
Total
Transportation Emissions from vehicle trips beginning and ending in the City and from external/internal vehicle trips 370,517 63 Energy – Residential Electricity and natural gas consumption in residential buildings. 81,758 14
Energy – Nonresidential Electricity and natural gas consumption in nonresidential buildings (employment buildings; commercial, industrial, etc.)
45,685 8
Waste Solid waste generated and sent to landfills. 22,910 4 Water/Wastewater Emissions from electricity used to supply, treat, and distribute water based on the overall water demand and
wastewater generation of and within the City
23,649 4
Other – Off-road
Equipment
Consists of landscaping, light commercial, construction, and agricultural equipment. 46,415 8
Total 590,935 100
Source: City of Clovis General Plan and Development Code Update Program Environmental Impact Report (2014).

As shown in Table 4.3.C, in 2012, the City as a whole emitted approximately 590,935 metric tons of CO2e from the residential energy, nonresidential energy, transportation, waste, water and wastewater sectors. As shown in Table 4.3.C, the largest contributors of GHG emissions were the transportation (63 percent), residential energy (14 percent and nonresidential energy (8 percent) sectors. The remainder of emissions resulted from the off-road equipment (8 percent), waste (4 percent), and water and wastewater (4 percent) sectors.

4.3.2 Regulatory Setting

4.3.2.1 Federal Regulations
Federal Clean Air Act. The United States has historically had a voluntary approach to reducing GHG emissions. However, on April 2, 2007, the United States Supreme Court ruled that the United States Environmental Protection Agency (USEPA) has the authority to regulate CO2 emissions under the Federal Clean Air Act (FCCA). While there currently are no adopted federal regulations for the control or reduction of GHG emissions, the USEPA commenced several actions in 2009 to implement a regulatory approach to global climate change.

This includes the 2009 USEPA final rule for mandatory reporting of GHGs from large GHG emission sources in the United States. Additionally, the USEPA Administrator signed an endangerment finding action in 2009 under the Federal Clean Air Act, finding that six GHGs (CO2, CH4, N2O, HFCs, PFCs, and SF6) constitute a threat to public health and welfare, and that the combined emissions from motor vehicles cause and contribute to global climate change, leading to national GHG emission standards. 950
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) 4.3-9 In October 2012, the USEPA and the NHTSA, on behalf of the U.S. Department of Transportation, issued final rules to further reduce GHG emissions and improve corporate average fuel economy (CAFE) standards for light-duty vehicles for model years 2017 and beyond (77 Federal Register 62624). The NHTSA’s CAFE standards have been enacted under the Energy Policy and Conservation Act since 1978. This national program requires automobile manufacturers to build a single light-duty national fleet that meets all requirements under both federal programs and the standards of California and other states. This program would increase fuel economy to the equivalent of 54.5 miles per gallon, limiting vehicle emissions to 163 grams of CO2 per mile for the fleet of cars and light-duty trucks by model year 2025 (77 Federal Register 62630).

On March 31, 2022, the National Highway Traffic Safety Administration (NHTSA) finalized the Corporate Average Fuel Economy (CAFE) standards for Model Years 2024–2026 Passenger Cars and Light Trucks. The amended CAFE standards would require an industry wide fleet average of approximately 49 mpg for passenger cars and light trucks in model year 2026, by increasing fuel efficiency by 8 percent annually for model years 2024–2025, and 10 percent annually for model year 2026. The final standards are estimated to save about 234 billion gallons of gas between model years 2030 to 2050.

4.3.2.2 State Regulations
The CARB is the lead agency for implementing climate change regulations in the State. Since its formation, the CARB has worked with the public, the business sector, and local governments to find solutions to California’s air pollution problems. Key efforts by the State are described below.

Assembly Bill 1493 (2002). In a response to the transportation sector’s significant contribution to California CO2 emissions, Assembly Bill (AB) 1493 was enacted on July 22, 2002. AB 1493 requires the CARB to set GHG emission standards for passenger vehicles and light duty trucks (and other vehicles whose primary use is noncommercial personal transportation in the State) manufactured in 2009 and all subsequent model years. These standards (starting in model years 2009 to 2016) were approved by the CARB in 2004, but the needed waiver of Clean Air Act Preemption was not granted by the USEPA until June 30, 2009. CARB responded by amending its original regulation, now referred to as Low Emission Vehicle III, to take effect for model years starting in 2017 to 2025. The Trump administration revoked California’s waiver in 2019, but the Biden administration restored California’s waiver in 2021.

Executive Order S-3-05 (2005). Governor Arnold Schwarzenegger signed Executive Order (EO) S-3- 05 on June 1, 2005, which proclaimed that California is vulnerable to the impacts of climate change.

To combat those concerns, the executive order established California’s GHG emissions reduction targets, which established the following goals: GHG emissions should be reduced to 2000 levels by 2010;
• GHG emissions should be reduced to 1990 levels by 2020; and • GHG emissions should be reduced to 80 percent below 1990 levels by 2050.

The Secretary of the California Environmental Protection Agency (CalEPA) is required to coordinate efforts of various State agencies to collectively and efficiently reduce GHGs. A biannual progress report must be submitted to the Governor and State Legislature disclosing the progress made 951
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4.3 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) -10 toward GHG emission reduction targets. In addition, another biannual report must be submitted illustrating the impacts of global warming on California’s water supply, public health, agriculture, the coastline, and forestry, and report possible mitigation and adaptation plans to address these impacts.

The Secretary of CalEPA leads this CAT made up of representatives from State agencies as well as numerous other boards and departments. The CAT members work to coordinate statewide efforts to implement global warming emission reduction programs and the State’s Climate Adaptation Strategy. The CAT is also responsible for reporting on the progress made toward meeting the statewide GHG targets that were established in the executive order and further defined under AB 32, the “Global Warming Solutions Act of 2006.” The first CAT Report to the Governor and the Legislature was released in March 2006, which it laid out 46 specific emission reduction strategies for reducing GHG emissions and reaching the targets established in the Executive Order. The most recent report was released in December 2020.

Assembly Bill 32 (2006), California Global Warming Solutions Act. California’s major initiative for reducing GHG emissions is AB 32, passed by the State legislature on August 31, 2006. This effort aims at reducing GHG emissions to 1990 levels by 2020. The CARB has established the level of GHG emissions in 1990 at 427 million metric tons (MMT) of CO2e. The emissions target of 427 MMT requires the reduction of 169 MMT from the State’s projected business-as-usual 2020 emissions of 596 MMT. AB 32 requires the CARB to prepare a Scoping Plan that outlines the main State strategies for meeting the 2020 deadline and to reduce GHGs that contribute to global climate change. The Scoping Plan was approved by the CARB on December 11, 2008, and contains the main strategies California will implement to achieve the reduction of approximately 169 MMT CO2e, or approximately 30 percent, from the State’s projected 2020 emissions level of 596 MMT CO2e under a business-as-usual scenario (this is a reduction of 42 MMT CO2e, or almost 10 percent from 2002– 2004 average emissions). The Scoping Plan also includes CARB-recommended GHG reductions for each emissions sector of the State’s GHG inventory. The Scoping Plan calls for the largest reductions in GHG emissions to be achieved by implementing the following measures and standards: Improved emissions standards for light-duty vehicles (estimated reductions of 31.7 MMT CO2e); • The Low-Carbon Fuel Standard (15.0 MMT CO2e);
• Energy efficiency measures in buildings and appliances and the widespread development of combined heat and power systems (26.3 MMT CO2e); and
• A renewable portfolio standard for electricity production (21.3 MMT CO2e).

The Scoping Plan identifies 18 emission reduction measures that address cap-and-trade programs, vehicle gas standards, energy efficiency, low carbon fuel standards, renewable energy, regional transportation-related GHG targets, vehicle efficiency measures, goods movement, solar roof programs, industrial emissions, high speed rail, green building strategies, recycling, sustainable forests, water, and air. The measures would result in a total reduction of 174 MMT CO2e by 2020.

On August 24, 2011, the CARB unanimously approved both the new supplemental assessment and reapproved its Scoping Plan, which provides the overall roadmap and rule measures to carry out AB 32. The CARB also approved a more robust CEQA equivalent document supporting the 952
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) 4.3-11 supplemental analysis of the cap-and-trade program. The cap-and-trade took effect on January 1, 2012, with an enforceable compliance obligation that began January 1, 2013.

CARB has not yet determined what amount of GHG reductions it recommends from local government operations and local land use decisions; however, the Scoping Plan states that land use planning and urban growth decisions will play an important role in the State’s GHG reductions because local governments have primary authority to plan, zone, approve, and permit how land is developed to accommodate population growth and the changing needs of their jurisdictions (meanwhile, CARB is also developing an additional protocol for community emissions). CARB further acknowledges that decisions on how land is used will have large impacts on the GHG emissions that will result from the transportation, housing, industry, forestry, water, agriculture, electricity, and natural gas emission sectors. The Scoping Plan states that the ultimate GHG reduction assignment to local government operations is to be determined. With regard to land use planning, the Scoping Plan expects an approximately 5.0 MMT CO2e reduction due to implementation of SB 375.

In addition to reducing GHG emissions to 1990 levels by 2020, AB 32 directed the CARB and the CAT to identify a list of “discrete early action GHG reduction measures” that could be adopted and made enforceable by January 1, 2010. On January 18, 2007, Governor Schwarzenegger signed EO S-1-07, further solidifying California’s dedication to reducing GHGs by setting a new Low Carbon Fuel Standard (LCFS). This executive order sets a target to reduce the carbon intensity of California transportation fuels by at least 10 percent by 2020 and directs the CARB to consider the LCFS as a discrete early action measure. In 2011, U.S. District Court Judge Lawrence O’Neil issued an injunction preventing implementation of the LCFS, ruling that it is unconstitutional. In 2012, the Ninth Circuit Court of Appeal stayed the District Court’s injunction, allowing implementation of the LCFS. The Ninth Circuit decided to uphold the LCFS.

In June 2007, the CARB approved a list of 37 early action measures, including three discrete early action measures (LCFS, Restrictions on GWP Refrigerants, and Landfill CH4 Capture).21 Discrete early action measures are measures that were required to be adopted as regulations and made effective no later than January 1, 2010, the date established by Health and Safety Code Section 38560.5. The CARB adopted additional early action measures in October 2007 that tripled the number of discrete early action measures. These measures relate to truck efficiency, port electrification, reduction of PFCs from the semiconductor industry, reduction of propellants in consumer products, proper tire inflation, and SF6 reductions from the non-electricity sector. The combination of early action measures is estimated to reduce statewide GHG emissions by nearly 16 MMT.22 The CARB approved the First Update to the Climate Change Scoping Plan on May 22, 2014. The First Update identifies opportunities to leverage existing and new funds to further drive GHG emission reductions through strategic planning and targeted low carbon investments. The First Update defines CARB climate change priorities until 2020, and sets the groundwork to reach long-term goals 21 CARB. 2007b. Expanded List of Early Action Measures to Reduce Greenhouse Gas Emissions in California Recommended for Board Consideration. October. 22 CARB. 2007a. “ARB approves tripling of early action measures required under AB 32” News Release 07-46.

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4.3 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) -12 set forth in EOs S-3-05 and B-16-2012. The Update highlights California’s progress toward meeting the “near-term” 2020 GHG emission reduction goals as defined in the initial Scoping Plan. It also evaluates how to align the State’s “longer-term” GHG reduction strategies with other State policy priorities for water, waste, natural resources, clean energy, transportation, and land use. CARB released a second update to the Scoping Plan, the 2017 Scoping Plan,23 to reflect the 2030 target set by EO B-30-15 and codified by SB 32.

The 2022 Scoping Plan24 was approved in December 2022 and assesses progress toward achieving the SB 32 2030 target and laying out a path to achieve carbon neutrality no later than 2045. The 2022 Scoping Plan focuses on outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy deployment, natural and working lands, and others, and is designed to meet the State’s long-term climate objectives and support a range of economic, environmental, energy security, environmental justice, and public health priorities.

Senate Bill 97 (2007). SB 97, signed by the Governor in August 2007 (Chapter 185, Statutes of 2007; Public Resources Code [PRC], Sections 21083.05 and 21097), acknowledges climate change is a prominent environmental issue that requires analysis under CEQA. This bill directed the Governor’s Office of Planning and Research (OPR) to prepare, develop, and transmit to the California Resources Agency guidelines for mitigating GHG emissions or the effects of GHG emissions, as required by CEQA. The California Natural Resources Agency adopted the amendments to the State CEQA Guidelines in November 2018, which went into effect in December 2018. The amendments do not identify a threshold of significance for GHG emissions, nor do they prescribe assessment methodologies or specific mitigation measures. The amendments encourage lead agencies to consider many factors in performing a CEQA analysis, but preserve the discretion granted by CEQA to lead agencies in making their own determinations based on substantial evidence. The amendments also encourage public agencies to make use of programmatic mitigation plans and programs when they perform individual project analyses.

Senate Bill 375 (2008). SB 375, the Sustainable Communities and Climate Protection Act, which establishes mechanisms for the development of regional targets for reducing passenger vehicle GHG emissions, was adopted by the State on September 30, 2008. On September 23, 2010, the CARB adopted the vehicular GHG emissions reduction targets that had been developed in consultation with the Metropolitan Planning Organization (MPOs); the targets require a 6 to 15 percent reduction by 2020 and between 13 to 19 percent reduction by 2035 for each MPO. SB 375 recognizes the importance of achieving significant GHG reductions by working with cities and counties to change land use patterns and improve transportation alternatives. Through the SB 375 process, MPOs such as the Fresno Council of Governments will work with local jurisdictions in the development of Sustainable Communities Strategy (SCS) designed to integrate development patterns and the transportation network in a way that reduces GHG emissions while meeting housing needs and other regional planning objectives. Pursuant to SB 375, the Central Valley/San Joaquin reduction 23 CARB. 2017a. California’s 2017 Climate Change Scoping Plan. November. 24 CARB. 2022a. 2022 Scoping Plan. November 16. Website: https://ww2.arb.ca.gov/sites/default/files/ 2022-12/2022-sp.pdf (accessed January 2023).
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) 4.3-13 targets for per capita vehicular emissions were 6 to 13 percent by 2020 and are 13 to 16 percent by 2035 as shown in Table 4.3.D.

Table 4.3.D: Senate Bill 375 Regional Greenhouse Gas
Emissions Reduction Targets
Metropolitan Planning Organization By 2020
(%)
By 2035
(%)
San Francisco Bay Area 10 19
San Diego 15 19
Sacramento 7 19
Central Valley/San Joaquin 6–13 13–16
Los Angeles/Southern California 8 19
Source: California Air Resources Board (2018).

Executive Order B-30-15 (2015). Governor Jerry Brown signed Executive Order B-30-15 on April 29, 2015, which added the immediate target of:
• GHG emissions should be reduced to 40 percent below 1990 levels by 2030.

All State agencies with jurisdiction over sources of GHG emissions were directed to implement measures to achieve reductions of GHG emissions to meet the 2030 and 2050 targets. CARB was directed to update the AB 32 Scoping Plan to reflect the 2030 target, and therefore, is moving forward with the update process. The mid-term target is critical to help frame the suite of policy measures, regulations, planning efforts, and investments in clean technologies and infrastructure needed to continue reducing emissions.

Senate Bill 350 (2015) Clean Energy and Pollution Reduction Act. Senate Bill 350 (SB 350), signed by Governor Jerry Brown on October 7, 2015, updates and enhances AB 32 by introducing the following set of objectives in clean energy, clean air, and pollution reduction for 2030:
• Raise California’s renewable portfolio standard from 33 percent to 50 percent; and • Increasing energy efficiency in buildings by 50 percent by the year 2030.

The 50 percent renewable energy standard will be implemented by the California Public Utilities Commission for the private utilities and by the CEC for municipal utilities. Each utility must submit a procurement plan showing it will purchase clean energy to displace other non-renewable resources.

The 50 percent increase in energy efficiency in buildings must be achieved using existing energy efficiency retrofit funding and regulatory tools already available to state energy agencies under existing law. The addition made by this legislation requires state energy agencies to plan for and implement those programs in a manner that achieves the energy efficiency target.

Senate Bill 32, California Global Warming Solutions Act of 2016, and Assembly Bill 197. In summer 2016 the Legislature passed, and the Governor signed, SB 32, and Assembly Bill 197 (AB 197). SB 32 affirms the importance of addressing climate change by codifying into statute the GHG emissions reductions target of at least 40 percent below 1990 levels by 2030 contained in Governor Brown’s April 2015 Executive Order B-30-15. SB 32 builds on AB 32 and keeps us on the path toward 955
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4.3 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) -14 achieving the State’s 2050 objective of reducing emissions to 80 percent below 1990 levels, consistent with an IPCC analysis of the emissions trajectory that would stabilize atmospheric GHG concentrations at 450 parts per million CO2e and reduce the likelihood of catastrophic impacts from climate change.

The companion bill to SB 32, AB 197, provides additional direction to CARB related to the adoption of strategies to reduce GHG emissions. Additional direction in AB 197 meant to provide easier public access to air emissions data that are collected by CARB was posted in December 2016.

Senate Bill 100 (SB 100). On September 10, 2018, Governor Brown signed SB 100, which raises California’s Renewables Portfolio Standard (RPS) requirements to 60 percent by 2030, with interim targets, and 100 percent by 2045. The bill also establishes a state policy that eligible renewable energy resources and zero-carbon resources supply 100 percent of all retail sales of electricity to California end-use customers and 100 percent of electricity procured to serve all State agencies by December 31, 2045. Under the bill, the State cannot increase carbon emissions elsewhere in the western grid or allow resource shuffling to achieve the 100 percent carbon-free electricity target.

Executive Order B-55-18. Executive Order B-55-18, signed September 10, 2018, sets a goal “to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net negative emissions thereafter.” Executive Order B-55-18 directs CARB to work with relevant state agencies to ensure future Scoping Plans identify and recommend measures to achieve the carbon neutrality goal. The goal of carbon neutrality by 2045 is in addition to other statewide goals, meaning not only should emissions be reduced to 80 percent below 1990 levels by 2050, but that, by no later than 2045, the remaining emissions be offset by equivalent net removals of CO2e from the atmosphere, including through sequestration in forests, soils, and other natural landscapes.

California Building Efficiency Standards (Title 24, Part 6). The California Building Standards Code, or Title 24 of the California Code of Regulations (CCR) contains the regulations that govern the construction of buildings in California. Within the Building Standards Code, two parts pertain to the incorporation of both energy efficient and green building elements into land use development. Part 6 is California’s Energy Efficiency Standards for Residential and Non-Residential Buildings. These standards were first adopted in 1978 in response to a legislative mandate to reduce California’s energy consumption and are updated on an approximately 3-year cycle to allow consideration and possible incorporation of new energy efficient technologies and methods. In November 2008, the California Building Standards Commission established the California Green Building Standards Code (CALGreen Code), which sets performance standards for residential and non-residential development to reduce environmental impacts and encourage sustainable construction practices.

The CALGreen Code addresses energy efficiency, water conservation, material conservation, planning and design, and overall environmental quality. The current set of standards were adopted in 2022 and will apply to projects seeking building permits on or after January 1, 2023. Energy efficient buildings require less electricity; therefore, increased energy efficiency reduces fossil fuel consumption and decreases GHG emissions.

Cap and Trade. The development of a cap-and-trade program was included as a key reduction measure of the CARB AB 32 Climate Change Scoping Plan. The cap-and-trade program will help put California on the path to meet its goal of reducing GHG emissions to 1990 levels by 2020 and 956
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) 4.3-15 ultimately achieving an 80 percent reduction from 1990 levels by 2050. The cap-and-trade emissions trading program developed by the CARB took effect on January 1, 2012, with enforceable compliance obligations beginning January 1, 2013. The cap-and-trade program aims to regulate GHG emissions from the largest producers in the State by setting a statewide firm limit, or cap, on allowable annual GHG emissions. The cap was set in 2013 at approximately 2 percent below the emissions forecast for 2020. In 2014, the cap declined approximately 2 percent. Beginning in 2015 and continuing through 2020, the cap has been declining approximately 3 percent annually. The CARB administered the first auction on November 14, 2012, with many of the qualified bidders representing corporations or organizations that produce large amounts of GHG emissions, including energy companies, agriculture and food industries, steel mills, cement companies, and universities. On January 1, 2015, compliance obligation began for distributors of transportation fuels, natural gas, and other fuels. The capand-trade program was initially slated to sunset in 2020 but the passage of SB 398 in 2017 extended the program through 2030.25
Executive Order N-79-20. EO N-79-20, which was signed by the Governor on September 23, 2020, sets the following goals for the State: 100 percent of in-state sales of new passenger cars and trucks shall be zero-emission by 2035; 100 percent of medium- and heavy-duty vehicles in the State shall be zero-emission by 2045 for all operations where feasible and by 2035 for drayage trucks; and 100 percent of off-road vehicles and equipment in the State shall be zero-emission by 2035, where feasible.

California Integrated Waste Management Act. To minimize the amount of solid waste that must be disposed of in landfills, the State Legislature passed the California Integrated Waste Management Act of 1989 (AB 939), effective January 1990. According to AB 939, all cities and counties were required to divert 25 percent of all solid waste from landfill facilities by January 1, 1995, and 50 percent by January 1, 2000. Through other statutes and regulations, this 50 percent diversion rate also applies to State agencies. In order of priority, waste reduction efforts must promote source reduction, recycling and composting, and environmentally safe transformation and land disposal. In 2011, AB 341 modified the California Integrated Waste Management Act and directed the California Department of Resources Recycling and Recovery (CalRecycle) to develop and adopt regulations for mandatory commercial recycling. The resulting 2012 Mandatory Commercial Recycling Regulation requires that on and after July 1, 2012, certain businesses that generate four cubic yards or more of commercial solid waste per week shall arrange recycling services. To comply with this requirement, businesses may either separate recyclables and self-haul them or subscribe to a recycling service that includes mixed waste processing. AB 341 also established a statewide recycling goal of 75 percent; the 50 percent disposal reduction mandate still applies for cities and counties under AB 939, the Integrated Waste Management Act. In April 2016, AB 1826 further modified the California Integrated Waste Management Act, requiring businesses that generate a specified amount of organic waste per week to arrange for recycling services for that organic waste in a specified manner. If CalRecycle determines that statewide disposal of organic waste has not been reduced by 50 percent below 2014 levels by 2020, businesses generating more than two cubic yards of organic 25 CARB. 2014. Cap-and-Trade Program. Website: www.arb.ca.gov/cc/capandtrade/capandtrade.htm (accessed September 2022).
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4.3 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) -16 waste per week would be subject to these waste collection requirements. CalRecycle plans to make this assessment in the fall of 2020. Diverting organic waste from landfills reduces emissions of CH4.

This is equivalent to reducing anaerobic decomposition of organic waste that would have otherwise occurred in landfills where organic waste is often buried with other inorganic waste.

Low Carbon Fuel Standard. In January 2007, EO S-01-07 established an LCFS. This executive order calls for a statewide goal to be established to reduce the carbon intensity of California’s transportation fuels by at least 10 percent by 2020, and that an LCFS for transportation fuels be established for California. The LCFS applies to all refiners, blenders, producers, or importers (“Providers”) of transportation fuels in California, including fuels used by off-road construction equipment. In June 2007, CARB adopted the LCFS under AB 32 pursuant to Health and Safety Code Section 38560.5, and, in April 2009, CARB approved the new rules and carbon intensity reference values with new regulatory requirements taking effect in January 2011. The standards require providers of transportation fuels to report on the mix of fuels they provide and demonstrate they meet the LCFS intensity standards annually. This is accomplished by ensuring that the number of “credits” earned by providing fuels with a lower carbon intensity than the established baseline (or obtained from another party) is equal to or greater than the “deficits” earned from selling higher intensity fuels. In response to certain court rulings, CARB re-adopted the LCFS regulation in September 2015, and the LCFS went into effect on January 1, 2016. In 2018, CARB approved amendments to the regulation to readjust carbon intensity benchmarks to meet California’s 2030 GHG reductions targets under SB 32. These amendments include opportunities to promote zero emission vehicle (ZEV) adoption, carbon capture and sequestration, and advanced technologies for decarbonization of the transportation sector.

Advanced Clean Cars Program. In January 2012, CARB approved the Advanced Clean Cars program, which combines the control of GHG emissions and criteria air pollutants, as well as requirements for greater numbers of ZEVs, into a single package of regulatory standards for vehicle model years 2017 through 2025. The new regulations strengthen the GHG standard for 2017 models and beyond. This will be achieved through existing technologies, the use of stronger and lighter materials, and more efficient drivetrains and engines. The program’s ZEVs regulation requires battery, fuel cell, and/or plug-in hybrid electric vehicles to account for up to 15 percent of California’s new vehicle sales by 2025. The program also includes a clean fuels outlet regulation designed to support the commercialization of zero-emission hydrogen fuel cell vehicles planned by vehicle manufacturers by 2015 by requiring increased numbers of hydrogen fueling stations throughout the State. The number of stations will grow as vehicle manufacturers sell more fuel cell vehicles. By 2025, when the rules will be fully implemented, the statewide fleet of new cars and light trucks will emit 40 percent fewer GHGs and 75 percent fewer smog-forming emissions than 2012 model year vehicles.

Executive Order B-48-18. In January 2018, Governor Brown signed EO B-48-18 requiring all State entities to work with the private sector to have at least 5 million ZEVs on the road by 2030, as well as install 200 hydrogen fueling stations and 250,000 electric vehicle charging stations by 2025. It specifies that 10,000 of the electric vehicle charging stations should be direct current fast chargers.

This order also requires all State entities to continue to partner with local and regional governments to streamline the installation of ZEV infrastructure. The Governor’s Office of Business and Economic Development is required to publish a Plug-in Charging Station Design Guidebook and update the 958
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) 4.3-17 2015 Hydrogen Station Permitting Guidebook to aid in these efforts. All State entities are required to participate in updating the 2016 Zero-Emissions Vehicle Action Plan to help expand private investment in ZEV infrastructure with a focus on serving low-income and disadvantaged communities. Additionally, all State entities are to support and recommend policies and actions to expand ZEV infrastructure at residential land uses, through the LCFS Program, and recommend how to ensure affordability and accessibility for all drivers.

4.3.2.3 Regional Regulations
San Joaquin Valley Air Pollution Control District. The City of Clovis is located within the San Joaquin Valley Air Basin (SJVAB), which is under the jurisdiction of the San Joaquin Valley Air Pollution Control District (SJVAPCD). The SJVAPCD has regulatory authority over certain stationary and industrial GHG emission sources and provides voluntary technical guidance on addressing GHGs for other emission sources in a CEQA context. District initiatives related to GHGs are described below.

Climate Change Action Plan. The San Joaquin Valley Air Pollution Control District Climate Change Action Plan (CCAP) was adopted on August 21, 2008. The CCAP includes suggested best performance standards (BPS) for proposed development projects. However, the SJVAPCD’s CCAP was adopted in 2009 and was prepared based on the State’s 2020 GHG targets, which are now superseded by State policies (i.e., the 2019 California Green Building Code) and the 2030 GHG targets, established in SB 32.

San Joaquin Valley Carbon Exchange and Rule 2301. The SJVAPCD initiated work on the San Joaquin Valley Carbon Exchange in November 2008. The Exchange was implemented with the adoption of Amendments to Rule 2301 Emission Reduction Credit Banking on January 19, 2012.

The purpose of the carbon exchange is to quantify, verify, and track voluntary GHG emissions reductions generated within the San Joaquin Valley.

The SJVAPCD incorporated a method to register voluntary GHG emission reductions with amendments to Rule 2301. The purposes of the amendments to the rule include the following:
• Provide an administrative mechanism for sources to bank voluntary GHG emission reductions for later use.
• Provide an administrative mechanism for sources to transfer banked GHG emission reductions to others for any use.
• Define eligibility standards, quantitative procedures, and administrative practices to ensure that banked GHG emission reductions are real, permanent, quantifiable, surplus, and enforceable.

The SJVAPCD is participating in a new program developed by the California Air Pollution Control Officers Association (CAPCOA) to encourage banking and use of GHG reduction credits referred to as the CAPCOA Greenhouse Gas Reduction Exchange (GHGRx). The GHGRx provides information on GHG credit projects within participating air districts. The District is one of the first to have offsets available for trading on the Exchange. 959
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4.3.2.4 Local Regulations
City of Clovis General Plan. The City of Clovis General Plan provides goals, policies, and action items that work to meet or exceed all current and future state-mandated targets for reducing emissions of greenhouse gases. The policies and action items from the General Plan, listed in Table 4.3.E would be applicable to the proposed project.

Table 4.3.E: City of Clovis General Plan Policies Related to Greenhouse Gas Emissions Policy/Action
Item Number Policy/Action Item
Air Quality Element
Policy 1.1 Land use and transportation. Reduce greenhouse gas and other local pollutant emissions through mixed use and transit-oriented development and well-designed transit, pedestrian, and bicycle systems.

Policy 1.6 Alternative fuel infrastructure. Encourage public and private activity and employment centers to incorporate electric charging and alternative fuel stations.

Policy 2.1 Regional coordination. Support regional efforts to reduce air pollution (criteria air pollutants and greenhouse gas emissions) and collaborate with other agencies to improve air quality at the emission source and reduce vehicle miles traveled.

Policy 2.2 Cross-jurisdictional issues. Collaborate with regional agencies and surrounding jurisdictions to address cross-jurisdictional transportation and air quality issues.

Policy 2.3 Valleywide programs. Establish parallel air quality programs and implementation measures with other communities across the San Joaquin Valley.

Policy 2.4 Public participation. Encourage participation of local citizens, the business community, and interested groups and individuals in air quality planning and implementation.

Policy 2.6 Innovative mitigation. Encourage innovative mitigation measures to reduce air quality impacts by coordinating with the SJVAPCD, project applicants, and other interested parties.

Source: City of Clovis General Plan (August 2014).

4.3.3 Impacts and Mitigation Measures
The following section presents a discussion of the impacts related to greenhouse gas emissions that could result from implementation of the proposed project. The section begins with the criteria of significance, which establish the thresholds to determine if an impact is significant. The latter part of this section presents the impacts associated with implementation of the proposed project and the recommended mitigation measures, if required. Mitigation measures are recommended, as appropriate, for significant impacts to eliminate or reduce them to a less-than-significant level.

Cumulative impacts are also addressed.

4.3.3.1 Significance Criteria
Based on CEQA Guidelines Appendix G, the proposed project would have a significant impact related to greenhouse gas emissions if it would:
a. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; or
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) 4.3-19 b. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

Section 15064.4 of the State CEQA Guidelines states that: “A lead agency should make a good-faith effort, based to the extent possible on scientific and factual data, to describe, calculate or estimate the amount of greenhouse gas emissions resulting from a project.” In performing that analysis, the lead agency has discretion to determine whether to use a model or methodology to quantify GHG emissions, or to rely on a qualitative analysis or performance-based standards. In making a determination as to the significance of potential impacts, the lead agency then considers the extent to which the project may increase or reduce GHG emissions as compared to the existing environmental setting, whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project, and 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.

Neither the City of Clovis, nor the SJVAPCD has developed or adopted numeric GHG significance thresholds. Therefore, this analysis evaluates the GHG emissions based on the project’s consistency with State GHG reduction goals.

4.3.3.2 Project Impacts
a. Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
No development is proposed within the remaining 174.46-acre annexation area surrounding the project site. The proposed project would include annexation of the 246-acre area from Fresno County jurisdiction to the City of Clovis. Any future development occurring within the annexation area would require a separate project-specific analysis. The sections below discuss the 71.54 acre project’s potential impact related to the release of GHG emissions for both construction and project operation.

Construction GHG Emissions. Construction activities associated with the proposed project would produce combustion emissions from various sources. During construction, GHGs would be emitted through the operation of construction equipment and from worker and builder supply vendor vehicles, each of which typically use fossil-based fuels to operate. The combustion of fossil-based fuels creates GHGs such as CO2, CH4, and N2O. Furthermore, CH4 is emitted during the fueling of heavy equipment. Exhaust emissions from on-site construction activities would vary daily as construction activity levels change.

The City of Clovis does not have an adopted threshold of significance for construction related GHG emissions. However, emissions that would occur during construction were quantified and are disclosed for informational purposes. Using CalEEMod, it is estimated that construction of the proposed project would generate approximately 1,732.0 metric tons of CO2e. Table 4.3.F lists the annual GHG emissions (details are provided in the CalEEMod output in Appendix D). 961
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4.3 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) -20 Table 4.3.F: Construction Greenhouse Gas Emissions
Construction Year Annual Emissions (metric tons per year) CO2 CH4 N2O CO2e
2023 32.8 <0.1 <0.1 33.0
2024 785.0 <0.1 <0.1 797.0
2025 532.0 <0.1 <0.1 540.0
2026 357.0 <0.1 <0.1 362.0
Total Construction Emissions 1,732.0
Source: Compiled by LSA (February 2023).

CH4 = methane
CO2 = carbon dioxide
CO2e = carbon dioxide equivalent
N2O = nitrous oxide
Even though the City of Clovis does not have any adopted GHG emission thresholds, the emission results shown in Table 4.3.F would be temporary in nature, and would only occur for the duration construction.

Operational GHG Emissions. Long-term GHG emissions are typically generated from mobile sources (e.g., cars, trucks, and buses), area sources (e.g., maintenance activities and landscaping), indirect emissions from sources associated with energy consumption, waste sources (land filling and waste disposal), and water sources (water supply and conveyance, treatment, and distribution). Mobilesource GHG emissions would include project-generated vehicle trips to and from the project. Areasource emissions would be associated with activities such as landscaping and maintenance on the project site. Energy source emissions would be generated at off-site utility providers as a result of increased electricity demand generated by the project. Waste source emissions generated by the proposed project include energy generated by land filling and other methods of disposal related to transporting and managing project-generated waste. In addition, water source emissions associated with the proposed project are generated by water supply and conveyance, water treatment, water distribution, and wastewater treatment.

Emissions estimates for operation of the proposed project were calculated using CalEEMod.

Table 4.3.G shows the emissions sources by category; mobile source emissions are the largest category, at approximately 83 percent of total CO2e emissions, followed by energy source emissions at approximately 8 percent of the total, area source emissions at approximately 6 percent of the total, waste source emissions at approximately 3 percent of the total, and water source emissions with less than 1 percent of the total emissions. CalEEMod output sheets are included in Appendix D. 962
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) 4.3-21 Table 4.3.G: Operational Greenhouse Gas Emissions
Emissions Category
Operational Emissions (Metric Tons per Year)
CO2 CH4 N2O CO2e Percent of Total
Mobile Source 5,243.0 0.3 0.3 5,343.0 83
Area Source 350.0 0.6 <0.1 364.0 6
Energy Source 512.0 0.1 <0.1 517.0 8
Water Source 17.2 0.8 <0.1 43.2 <1
Waste Source 55.4 5.5 0.0 194.0 3
Total Operational 6,461.2 100.0
Source: Compiled by LSA (February 2023).

Note = Some values may not appear to add up correctly due to rounding.

CH4 = methane
CO2 = carbon dioxide
CO2e = carbon dioxide equivalent
N2O = nitrous oxide
As shown in Table 4.3.G, the proposed project would generate approximately 6,461.2 metric tons of CO2e annually. The proposed project would consist in the construction of a 590-lot residential development for single-family residences. Based on the City’s current Housing Element,26 the average number of persons residing in each household in Clovis is estimated to be 2.85 persons. As a result, following construction and occupation of the proposed project, it is estimated that approximately 1,682 residents would live within the proposed 590 residential units within the project site. The proposed project would not accommodate new employees; therefore, the total service population would be 1,682 people (residents plus employees). As such, the proposed project would result in 3.8 metric tons of CO2e per year per service population.

The SJVAPCD has not established a numeric threshold for GHG emissions. As discussed, the significance of GHG emissions may be evaluated based on locally adopted quantitative thresholds or consistency with a regional GHG reduction plan (such as a Climate Action Plan). Neither the City of Clovis, nor the SJVAPCD has developed or adopted numeric GHG significance thresholds. Therefore, the proposed project was analyzed for consistency with the 2022 Scoping Plan.

The 2022 Scoping Plan includes key project attributes that reduce operational GHG emissions in Appendix D, Local Actions27, of the 2022 Scoping Plan. As discussed in Appendix D of the 2022 Scoping Plan, absent consistency with an adequate, geographically specific GHG reduction plan such as a CEQA-qualified CAP, the first approach the State recommends for determining whether a proposed residential or mixed-use residential development would align with the State’s climate goals is to examine whether the project includes key project attributes that reduce operational GHG emissions while simultaneously advancing fair housing. With the implementation of recommended mitigation, the proposed project is generally consistent with the key project attributes recommended in the Scoping Plan, as further discussed below. 26 City of Clovis. 2016. Fresno Multi-Jurisdictional 2015-2023 Housing Element. Website: https://cityofclovis. com/wp-content/uploads/2019/02/Clovis-Housing-Element-1.pdf (accessed September 21, 2022). April. 27 CARB. 2022b. 2022 Scoping Plan Appendix D Local Actions. November. Website: https://ww2.arb.ca.gov/ sites/default/files/2022-11/2022-sp-appendix-d-local-actions.pdf (accessed February 2023). 963
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4.3 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) -22 The 2022 Scoping Plan recommends that a residential or mixed-use project provide EV charging infrastructure that, at minimum, meets the most ambitious voluntary standard in the California Green Building Standards Code at the time of project approval. CALGreen requires provision of infrastructure to accommodate EV chargers for new single family and attached dwelling units/town houses. It is not yet known whether the proposed project would include electric vehicle charging; therefore, implementation of Mitigation Measure GHG-1 would be required to ensure the proposed project would provide electric vehicle charging. With implementation of Mitigation Measure GHG-1, the proposed project would be consistent with this key project attribute.

The Scoping Plan further recommends that a proposed project be located on infill sites that are surrounded by existing urban uses and reuses or redevelops previously undeveloped or underutilized land that is presently served by existing utilities and essential public services (e.g., transit, streets, water, sewer). The proposed project is located in close proximity to other singlefamily residential uses that are presently served by existing utilities and essential public services (e.g., transit, streets, water, sewer). The project site and adjacent parcels have been identified for future development in the City of Clovis General Plan. As described in Section 4.5 Transportation, the project’s VMT was calculated to be 17.8 VMT per capita, 26.4 percent higher than the City’s VMT per capita threshold. However, as further discussed in Section 4.5, Transportation, as per information provided by the Project Applicant, the project intends to implement project design features that could help reduce project VMT. The project design features would include the following: pedestrian infrastructure; improve street connectivity; bicycle infrastructure/improvements; and provide electric vehicle charging capabilities (as required my Mitigation Measure GHG-1). The project would be generally consistent with the goals of the Scoping Plan with the implementation of the mitigation measure and design features.

CARB guidance recommends that, to be consistent with State goals, a proposed project should not result in the loss or conversion of natural and working lands. The project site is zoned within the Exclusive Agricultural Zoning District (AE-20) of Fresno County. In addition, the project site contains APN 556-030-14S, which is currently under a Williamson Act contract. Following approval of the proposed project and certification of the EIR, the City and Project Applicant will apply to have the project site and annexation area annexed into the City of Clovis, and the project site will be prezoned to the City of Clovis’ R-1 Zone District (R-1-PRD). Additionally, cancellation of the Williamson Act contract would occur prior to issuance of building permits, pursuant to Mitigation Measure AG2. Although the project would result in the conversion of farmland, as confirmed by the site-specific LESA Model prepared for the project, this impact would be a less than significant impact.

Additionally, conversion of farmland through development of the project site was already identified in the City of Clovis General Plan EIR. The project would result in no new impacts related to the loss or conversion of natural and working lands than those already identified in the City’s General Plan.

As such, implementation of the proposed project would not result in significant impacts related to the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to nonagricultural uses. Therefore, the proposed project would be consistent with this key project attribute.

The proposed project would also be generally consistent with the transit density criteria recommended in the Scoping Plan. The proposed project would include an approximately 20-foot964 AGENDA ITEM NO. 13.

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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) 4.3-23 wide parkway containing an approximately 6-foot-wide pedestrian sidewalk and landscaped areas would be included along the western side of North Baron Avenue along the project site. An approximately 16-foot-wide parkway containing an approximately 6-foot-wide pedestrian sidewalk and landscaped area that is reduced from the Heritage Grove Neighborhood Boulevard Street section would be included along the eastern side of North Baron Avenue. Through the implementation of these features, the proposed project would support the ability to use alternative modes of transportation. As such, the project would promote initiatives to reduce vehicle trips and VMT and would increase the use of alternate means of transportation.

The Scoping Plan recommends that a proposed project reduce parking requirements by eliminating parking requirements or including maximum allowable parking ratios (i.e., the ratio of parking spaces to residential units or square feet); or providing residential parking supply at a ratio of less than one parking space per dwelling unit; or for multifamily residential development, requiring parking costs to be unbundled from costs to rent or own a residential unit. The proposed project would consist of the annexation of 246 acres by the City of Clovis, and the development of 590 residential lots. Phase 1 would include the construction of approximately 44 parking spaces and Phase 3 would include the construction of approximately 91 parking spaces. Based on the minimal parking spaces when compared to the number of residential units, the proposed project would be consistent with this key project attribute.

An additional State goal is to advance the availability of fair housing. The proposed project would help to address the California housing shortage and would increase the number of residences available to residents of the San Joaquin Valley. Through increasing housing opportunities in this historically disadvantaged area, the proposed project would be consistent with State goals. The proposed project would include the removal of one existing 2,679 square-foot dwelling unit and garage, an existing propane tank, a 2,000 square-foot pole barn, two sheds, and an existing driveway on the project site. The removal of these structures would not result in a net loss of existing affordable uses and is therefore consistent with the goals of the 2022 Scoping Plan.

Finally, consistent with the recommendations in the 2022 Scoping Plan, the proposed project would be all-electric and would not include natural gas. Based on the Bay Area Air Quality Management District’s Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts From Land Use Projects and Plans28, the elimination of natural gas in new development would help projects implement their “fair share” of achieving long-term 2045 carbon neutrality consistent with State goals. As such, if a project does not utilize natural gas, a lead agency can conclude that it would be consistent with achieving the 2045 neutrality goal and will not have a cumulative considerable impact on climate change.

With implementation of Mitigation Measure GHG-1, the proposed project would be consistent with the 2022 Scoping Plan key residential and mixed-use project attributes related to EV charging 28 Bay Area Air Quality Management District (BAAQMD). 2022. Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts From Land Use Projects and Plans. April. Website:
https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa-thresholds-2022/justificationreport-pdf.pdf?la=en (accessed May 2023). 965
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4.3 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) -24 requirements. As demonstrated above, the proposed project is generally consistent with the key project attributes recommended by CARB for a residential project to have a less than significant impact due to GHG emissions. The implementation of Mitigation Measure GHG-1 would ensure consistency with the 2022 Scoping Plan key project attribute related to EV charging requirements.

Impact GHG-1: The project would generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.

Level of Significance Without Mitigation: Potentially Significant Impact.

Mitigation Measure GHG-1 In order to meet the 2022 Scoping Plan greenhouse gas (GHG) requirements, consistent with State GHG reduction and equity prioritization goals, each residential unit shall provide electric vehicle charging capabilities as part of the final project designs.

Level of Significance With Mitigation: Less than significant with mitigation. b. Would the project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
The SJVAPCD has adopted a CCAP, which includes suggested best performance standards (BPS) for proposed development projects. However, the SJVAPCD’s CCAP was adopted in 2009 and was prepared based on the State’s 2020 GHG targets, which are now superseded by State policies (i.e., the 2022 California Green Building Code) and the 2030 GHG targets, established in SB 32. As mentioned above, the City of Clovis has not developed or adopted numeric GHG significance thresholds. Therefore, this analysis evaluates the GHG emissions based on the project’s consistency with State GHG reduction goals.

The proposed project was analyzed for consistency with the goals of the 2022 Scoping Plan.

Scoping Plan. The following discussion evaluates the proposed project according to the goals of the 2022 Scoping Plan, EO B-30-15, SB 32, and AB 197.

EO B-30-15 added the immediate target of reducing GHG emissions to 40 percent below 1990 levels by 2030. CARB released a second update to the Scoping Plan, the 2017 Scoping Plan, to reflect the 2030 target set by EO B-30-15 and codified by SB 32. SB 32 affirms the importance of addressing climate change by codifying into statute the GHG emissions reductions target of at least 40 percent below 1990 levels by 2030 contained in EO B-30-15. SB 32 builds on AB 32 and keeps us on the path toward achieving the State’s 2050 objective of reducing emissions to 80 percent below 1990 levels.

The companion bill to SB 32, AB 197, provides additional direction to the CARB related to the adoption of strategies to reduce GHG emissions. Additional direction in AB 197 intended to provide easier public access to air emissions data that are collected by CARB was posted in December 2016.

In addition, the 2022 Scoping Plan assesses progress toward the statutory 2030 target, while laying out a path to achieving carbon neutrality no later than 2045. The 2022 Scoping Plan focuses on outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy 966
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) 4.3-25 deployment, natural and working lands, and others, and is designed to meet the State’s long-term climate objectives and support a range of economic, environmental, energy security, environmental justice, and public health priorities.

The 2022 Scoping Plan focuses on building clean energy production and distribution infrastructure for a carbon-neutral future, including transitioning existing energy production and transmission infrastructure to produce zero-carbon electricity and hydrogen, and utilizing biogas resulting from wildfire management or landfill and dairy operations, among other substitutes. Energy efficient measures are intended to maximize energy efficiency building and appliance standards, pursue additional efficiency efforts including new technologies and new policy and implementation mechanisms, and pursue comparable investment in energy efficiency from all retail providers of electricity in California. In addition, these measures are designed to expand the use of green building practices to reduce the carbon footprint of California’s new and existing inventory of buildings. As discussed above, the proposed project would comply with the CALGreen Code, regarding energy conservation and green building standards. The proposed project would also incorporate sustainable design features, including, but not limited, to installation of energy-efficient light fixtures, high-efficiency plumbing fixtures, and rooftop PV systems and solar panels, consistent with the requirements of Title 24. The proposed project would receive electricity from PG&E, which is required to reduce GHG emissions by increasing procurement from eligible renewable energy by set target years in support of State goals for GHG emissions reductions and carbon neutrality by 2045.

Therefore, the proposed project would comply with applicable energy measures included in the Scoping Plan.

Water conservation and efficiency measures are intended to continue efficiency programs and use cleaner energy sources to move and treat water. Increasing the efficiency of water transport and reducing water use would reduce GHG emissions. As noted above, the project would comply with the CALGreen Code, which includes a variety of different measures, including the reduction of wastewater and water use. In addition, the proposed project would be required to comply with the California Model Water Efficient Landscape Ordinance. Therefore, the proposed project would not conflict with any of the water conservation and efficiency measures.

The goal of transportation and motor vehicle measures is to develop regional GHG emissions reduction targets for passenger vehicles. Specific regional emission targets for transportation emissions would not directly apply to the proposed project. The second phase of Pavley standards will reduce GHG emissions from new cars by 34 percent from 2016 levels by 2025, resulting in a 3 percent decrease in average vehicle emissions for all vehicles by 2020. Vehicles traveling to the project site would comply with the Pavley II (LEV III) Advanced Clean Cars Program. The proposed project is located in the vicinity of several other housing developments and would offer pedestrian and bicycle connectivity and parkways along nearby roadways to encourage the use of alternative transportation, thereby helping to reduce VMTs. Therefore, the proposed project would not conflict with the identified transportation and motor vehicle measures.

Furthermore, the proposed project would directly increase the availability of housing opportunities in the San Joaquin Valley, helping to address California’s housing shortage and increasing the total number of residences in the State. The proposed project would therefore support addressing the State goals of increasing the availability of housing to Californian residents. 967
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4.3 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.3-Greenhouse_Gas_Emissions.docx (01/11/24) -26 As demonstrated above, and as further discussed in the proceeding section, the proposed project would be consistent with the 2022 Scoping Plan, and would therefore be consistent with other local and State plans for reducing GHGs.

Impact GHG-2: The project would not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

Level of Significance Without Mitigation: Less Than Significant Impact.

4.3.3.3 Cumulative Impacts
GHG impacts are by their nature cumulative impacts. Localized impacts of climate change are the result of the cumulative impact of global emissions. The combined benefits of reductions achieved by all levels of government help to slow or reverse the growth in GHG emissions. In the absence of comprehensive international agreements on appropriate levels of reductions achieved by each country, another measure of cumulative contribution is required. This serves to define the State’s share of the reductions regardless of the activities or lack of activities of other areas of the U.S. or the world. Therefore, a cumulative threshold based on consistency with State targets and actions to reduce GHGs is an appropriate standard of comparison for significance determinations.

As mentioned above, neither the City of Clovis nor the SJVAPCD has developed or adopted numeric GHG significance thresholds. Therefore, the proposed project was analyzed for consistency with State GHG reduction goals. Based on the analysis presented above, the proposed project would be consistent with the 2022 Scoping Plan key residential and mixed-use project attributes related building electrification, and with implementation of Mitigation Measure GHG-1, the EV charging requirements. Therefore, the proposed project would have a less than significant impact after the incorporation of mitigation measures.

Level of Significance Without Mitigation: Potentially Significant Impact.

Mitigation Measure: Refer to Mitigation Measures GHG-1.

Level of Significance With Mitigation: Less Than Significant Impact. 968
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4.4 NOISE
This section describes existing noise and vibration conditions, sets forth criteria for determining the significance of noise and vibration impacts, and estimates the likely noise and vibration impacts that would result from construction and operation of the proposed project. Mitigation measures are identified, as necessary, to address significant environmental impacts.

4.4.1 Environmental Setting
The setting section begins with an introduction to several key concepts and terms that are used in evaluating noise. This section also includes a description of current noise sources that affect the project site and the noise conditions that are experienced in the project site vicinity.

4.4.1.1 Characteristics of Sound
Noise is usually defined as unwanted sound and consists of any sound that may produce physiological or psychological damage and/or interfere with communication, work, rest, recreation, or sleep. To the human ear, sound has two significant characteristics: pitch and loudness. Pitch is generally related to annoyance, while loudness can affect our ability to hear through hearing damage. Pitch is the number of complete vibrations, or cycles per second, of a wave, resulting in the tone’s range from high to low. Loudness is the strength of a sound that describes a noisy or quiet environment and is measured by the amplitude of the sound wave. Loudness is determined by the intensity of the sound waves, combined with the reception characteristics of the human ear. Sound pressure refers to how hard the sound wave strikes an object, which in turn produces the sound’s effect. This characteristic of sound can be measured precisely with instruments. The project analysis defines the noise environment of the planning area in terms of sound pressure levels and the project’s effect on sensitive land uses.

4.4.1.2 Measurement of Sound
Sound intensity is measured with the A-weighted decibel scale to correct for the relative frequency response of the human ear. That is, an A-weighted noise level de-emphasizes low and very high frequencies of sound, similar to the human ear’s de-emphasis of these frequencies. Decibels, unlike linear units (e.g., inches or pounds), are measured on a logarithmic scale representing points on a sharply rising curve.

For example, 10 decibels (dB) is 10 times more intense than 1 dB, 20 dB is 100 times more intense than 1 dB, and 30 dB is 1,000 times more intense than 1 dB. Thirty decibels (30 dB) represents 1,000 times as much acoustic energy as 1 dB. The decibel scale increases as the square of the change, representing the sound pressure energy. A sound as soft as human breathing is about 10 times greater than 0 dB. The decibel system of measuring sound gives a rough connection between the physical intensity of sound and its perceived loudness to the human ear. A 10 dB increase in sound level is perceived by the human ear as only a doubling of the sound’s loudness.

Ambient sounds generally range from 30 dB (very quiet) to 100 dB (very loud).

Sound levels generate from a source, and their decibel level decreases as the distance from that source increases. Sound levels dissipate exponentially with distance from their noise sources. For a single point source, sound levels decrease approximately 6 dB for each doubling of distance from the source. This drop-off rate is appropriate for noise generated by stationary equipment. If noise is 969
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4.4 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) -2 produced by a line source (e.g., highway traffic or railroad operations) the sound decreases 3 dB for each doubling of distance in a hard site environment. Line source sound levels decrease 4.5 dB for each doubling of distance in a relatively flat environment with absorptive vegetation.

There are many ways to rate noise for various time periods, but an appropriate rating of ambient noise affecting humans also accounts for the annoying effects of sound. The equivalent continuous sound level (Leq) is the total sound energy of time-varying noise over a sample period. However, the predominant rating scales for human communities in the State of California are the Leq and Community Noise Equivalent Level (CNEL) or the day-night average noise level (Ldn) based on A-weighted decibels (dBA). CNEL is the time-varying noise over a 24-hour period, with a 5 dBA weighting factor applied to the hourly Leq for noise occurring from 7:00 p.m. to 10:00 p.m. (defined as relaxation hours) and a 10 dBA weighting factor applied to noise occurring from 10:00 p.m. to 7:00 a.m. (defined as sleeping hours). Ldn is similar to the CNEL scale but without the adjustment for events occurring during the relaxation and sleeping hours. CNEL and Ldn are within 1 dBA of each other and are normally interchangeable. The City uses the CNEL noise scale for long-term noise impact assessment.

Other noise rating scales of importance when assessing the annoyance factor include the maximum instantaneous noise level (Lmax), which is the highest exponential time-averaged sound level that occurs during a stated time period. The noise environments discussed in this analysis for short-term noise impacts are specified in terms of maximum levels denoted by Lmax, which reflects peak operating conditions and addresses the annoying aspects of intermittent noise. It is often used together with another noise scale, or noise standards in terms of percentile noise levels, in noise ordinances for enforcement purposes. For example, the L10 noise level represents the noise level exceeded 10 percent of the time during a stated period. The L50 noise level represents the median noise level. Half the time the noise level exceeds this level, and half the time it is less than this level.

The L90 noise level represents the noise level exceeded 90 percent of the time and is considered the background noise level during a monitoring period. For a relatively constant noise source, the Leq and L50 are approximately the same.

Noise impacts can be described in three categories. The first category includes audible impacts that refer to increases in noise levels noticeable to humans. Audible increases in noise levels generally refer to a change of 3 dB or greater because this level has been found to be barely perceptible in exterior environments. The second category, potentially audible, refers to a change in the noise level between 1 dB and 3 dB. This range of noise levels has been found to be noticeable only in laboratory environments. The last category includes changes in noise levels of less than 1 dB, which are inaudible to the human ear. Only audible changes in existing ambient or background noise levels are considered potentially significant.

Table 4.4.A contains a list of typical acoustical terms and definitions. Figure 4.4-1 shows representative outdoor and indoor noise levels in units of dBA. 970
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) 4.4-3 Table 4.4.A: Definitions of Acoustical Terms
Term Definitions
Decibel, dB A unit of level that denotes the ratio between two quantities proportional to power; the number of decibels is 10 times the logarithm (to the base 10) of this ratio.

Frequency, Hz Of a function periodic in time, the number of times that the quantity repeats itself in one second (i.e., number of cycles per second).

A-Weighted Sound Level,
dBA
The sound level obtained by use of A-weighting. The A-weighting filter de-emphasizes the very low and very high frequency components of the sound in a manner similar to the frequency response of the human ear and correlates well with subjective reactions to noise. All sound levels in this report are A-weighted, unless reported otherwise.

L01, L10, L50, L90 The fast A-weighted noise levels equaled or exceeded by a fluctuating sound level for 1 percent, 10 percent, 50 percent, and 90 percent of a stated time period.

Equivalent Continuous
Noise Level, Leq
The level of a steady sound that, in a stated time period and at a stated location, has the same A-weighted sound energy as the time varying sound.

Community Noise
Equivalent Level, CNEL
The 24-hour A-weighted average sound level from midnight to midnight, obtained after the addition of five decibels to sound levels occurring in the evening from 7:00 p.m. to 10:00 p.m. and after the addition of 10 decibels to sound levels occurring in the night between 10:00 p.m. and 7:00 a.m.

Day/Night Noise Level, Ldn The 24-hour A-weighted average sound level from midnight to midnight, obtained after the addition of 10 decibels to sound levels occurring in the night between 10:00 p.m. and 7:00 a.m.

Lmax, Lmin The maximum and minimum A-weighted sound levels measured on a sound level meter, during a designated time interval, using fast time averaging.

Ambient Noise Level The all-encompassing noise associated with a given environment at a specified time, usually a composite of sound from many sources at many directions, near and far; no particular sound is dominant.

Intrusive The noise that intrudes over and above the existing ambient noise at a given location. The relative intrusiveness of a sound depends upon its amplitude, duration, frequency, and time of occurrence and tonal or informational content as well as the prevailing ambient noise level.

Source: Handbook of Acoustical Measurements and Noise Control (Harris, Cyril 1998). 971
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4.4 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) -4 Figure 4.4-1: Typical A-Weighted Sound Levels
Source: Compiled by LSA (2016).

4.4.1.3 Physiological Effects of Noise
Physical damage to human hearing begins at prolonged exposure to sound levels higher than 85 dBA. Exposure to high sound levels affects the entire system, with prolonged sound exposure in excess of 75 dBA increasing body tensions, thereby affecting blood pressure and functions of the heart and the nervous system. In comparison, extended periods of sound exposure above 90 dBA would result in permanent cell damage. When the sound level reaches 120 dBA, a tickling sensation occurs in the human ear, even with short-term exposure. This level of sound is called the threshold of feeling. As the sound reaches 140 dBA, the tickling sensation is replaced by a feeling of pain in the ear (i.e., the threshold of pain). A sound level of 160–165 dBA will result in dizziness or a loss of equilibrium. The ambient or background noise problem is widespread and generally more concentrated in urban areas than in outlying, less-developed areas. 972
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4.4.1.4 Fundamentals of Vibration
Vibration energy propagates from a source through intervening soil and rock layers to the foundations of nearby buildings. The vibration then propagates from the foundation throughout the remainder of the structure. Building vibration may be perceived by occupants as the motion of building surfaces, the rattling of items sitting on shelves or hanging on walls, or a low-frequency rumbling noise. The rumbling noise is caused by the vibration of walls, floors, and ceilings that radiate sound waves. Annoyance from vibration often occurs when the vibration exceeds the threshold of perception by 10 dB or less. This is an order of magnitude below the damage threshold for normal buildings.

Typical sources of ground-borne vibration are construction activities (e.g., blasting, pile-driving, and operating heavy-duty earthmoving equipment), steel-wheeled trains, and occasional traffic on rough roads. Problems with both ground-borne vibration and noise from these sources are usually localized to areas within approximately 100 feet from the vibration source, although there are examples of ground-borne vibration causing interference out to distances greater than 200 feet.

When roadways are smooth, vibration from traffic, even heavy trucks, is rarely perceptible. It is assumed for most projects that the roadway surface will be smooth enough that ground-borne vibration from street traffic will not exceed the impact criteria; however, both construction of the project and the freight train operations could result in ground-borne vibration that may be perceptible and annoying.

Ground-borne noise is not likely to be a problem because noise arriving via the normal airborne path will usually be greater than ground-borne noise.

Ground-borne vibration has the potential to disturb people and damage buildings. Although it is very rare for train-induced ground-borne vibration to cause even cosmetic building damage, it is not uncommon for construction processes such as blasting and pile-driving to cause vibration of sufficient amplitudes to damage nearby buildings. Ground-borne vibration is usually measured in terms of vibration velocity, either the root-mean-square (RMS) velocity or peak particle velocity (PPV). The RMS is best for characterizing human response to building vibration, and PPV is used to characterize potential for damage. Decibel notation acts to compress the range of numbers required to describe vibration. Vibration velocity level in decibels is defined as:

Lv = 20 log10 [V/Vref]
where “Lv” is the vibration velocity in decibels (VdB), “V” is the RMS velocity amplitude, and “Vref” is the reference velocity amplitude, or 1 x 10-6 inches/second (in/sec) used in the United States.

Table 4.4.B illustrates human response to various vibration levels, as described in the Federal Transit Administration’s (FTA) Noise and Vibration Impact Assessment Manual (FTA Manual).1 1 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual. Office of Planning and Environment. Report No. 0123. September. 973
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4.4 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) -6 Table 4.4.B: Human Response to Different Levels of Ground-Borne Noise and Vibration
Vibration
Velocity Level
Noise Level
Low Human Response
Frequency1
Mid
Frequency2
65 VdB 25 dBA 40 dBA
Approximate threshold of perception for many humans. Low-frequency sound is usually inaudible; mid-frequency sound is excessive for quiet sleeping areas.
75 VdB 35 dBA 50 dBA
Approximate dividing line between barely perceptible and distinctly perceptible. Many people find transit vibration at this level unacceptable. Low-frequency noise is acceptable for sleeping areas; mid-frequency noise is annoying in most quiet occupied areas. 85 VdB 45 dBA 60 dBA
Vibration is acceptable only if there are an infrequent number of events per day. Low-frequency noise is unacceptable for sleeping areas; midfrequency noise is unacceptable even for infrequent events with institutional land uses, such as schools and churches.

Source: Transit Noise and Vibration Impact Assessment Manual (FTA 2018). 1 Approximate noise level when vibration spectrum peak is near 30 Hz. 2 Approximate noise level when vibration spectrum peak is near 60 Hz. dBA = A-weighted decibels
FTA = Federal Transit Administration
Hz = Hertz
VdB = vibration velocity decibels
Factors that influence ground-borne vibration and noise include:
• Vibration Source: Vehicle suspension, wheel types and condition, railroad track/roadway surface, railroad track support system, speed, transit structure, and depth of vibration source. • Vibration Path: Soil type, rock layers, soil layering, depth to water table, and frost depth. • Vibration Receiver: Foundation type, building construction, and acoustical absorption.

Among the factors listed above, there are significant differences in the vibration characteristics when the source is underground compared to at the ground surface. In addition, soil conditions are known to have a strong influence on the levels of ground-borne vibration. Among the most important factors are the stiffness and internal damping of the soil and the depth to bedrock.

Experience with ground-borne vibration indicates (1) vibration propagation is more efficient in stiff, clay soils than in loose, sandy soils; and (2) shallow rock seems to concentrate the vibration energy close to the surface and can result in ground-borne vibration problems at large distances from a railroad track. Factors such as layering of the soil and the depth to the water table can have significant effects on the propagation of ground-borne vibration. Soft, loose, sandy soils tend to attenuate more vibration energy than hard, rocky materials. Vibration propagation through groundwater is more efficient than through sandy soils.

4.4.1.5 Overview of the Existing Noise Environment
The ambient noise environment in the City of Clovis is affected by a variety of noise sources, including mobile source noise and stationary noise. As indicated in the City’s General Plan EIR, the most significant mobile sources of noise in the City include noise created by aircraft takeoffs and landings), and State Route 168 and other major roadways. Stationary noise sources in the City 974
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) 4.4-7 include operation of commercial, warehousing, and industrial uses and schools. Noise generated at construction sites is also a source of noise in Clovis. The following section describes the existing noise environment and identifies the primary noise sources in the vicinity of the project site.

Existing Traffic Noise. Motor vehicles with their distinctive noise characteristics are a major source of noise in the City of Clovis. The amount of noise varies according to many factors, such as volume of traffic, vehicle mix (percentage of cars and trucks), average traffic speed, and distance from the observer.

Existing roadway traffic noise levels in the project area were assessed using the Federal Highway Administration (FHWA) highway traffic noise prediction model (FHWA RD-77-108). Traffic volumes were obtained from the proposed project’s Transportation Impact Analysis (Appendix G). This model uses a typical vehicle mix for urban/suburban areas in California and requires parameters, including traffic volumes, vehicle speed, and roadway geometry, to compute typical equivalent noise levels during daytime, evening, and nighttime hours. The resultant noise levels are weighted and summed over 24-hour periods to determine the day-night average noise level (Ldn) values. Existing traffic noise contours along modeled roadway segments are shown in Table 4.4.C.

Existing Aircraft Noise. There are currently three airports near the City of Clovis, which are all within the City of Fresno: Fresno Yosemite International Airport, Fresno‐Chandler Executive Airport, and Sierra Sky Park Airport. Commercial jet aircraft operations are limited to Fresno Yosemite International Airport. The Air National Guard is also stationed there and operates military jets and other aircraft. Private and commercial operations with smaller aircraft use Fresno Chandler Downtown Airport, while only small private aircraft use Sierra Sky Park Airport. The Fresno Yosemite International Airport is located approximately 6.1 miles southwest of the project site, the Sierra Sky Airport, located approximately 9.3 miles southwest of the project site, and the Fresno Chandler Executive Airport, located approximately 11.3 miles southwest of the project site. Each of these airports is included in the Fresno County Airport Land Use Compatibility Plan (ALUCP), which guides approximate compatible land uses. The City of Clovis General Plan, other City land use plans, and all City land use decisions must be compatible with the adopted ALUCP. The ALUCP includes CNEL noise contours based on projected airport and aircraft operations. The project site is not within an ALUCP.2
Existing Railroad Noise. There are currently no railroad lines in the City of Clovis. The closest rail line to the project site is approximately 9 miles southwest of the project site. There are two major rail lines that traverse the nearby City of Fresno, including the Union Pacific Railroad line, which is generally runs along State Route (SR) 99, and the BNSF Railway, which diverges from SR‐99 in the southwest and travels through downtown Fresno (behind Fresno City Hall) to the northwest. Given the distance of the rail lines to the project site, railroad noise does not impact the City of Clovis. 2 City of Clovis. 2014. General Plan and Development Code Update Draft PEIR. Noise. Website:
https://cityofclovis.com/wp-content/uploads/2018/10/Chapter-05-12-Noise.pdf (accessed January 2023). 975
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4.4 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) -8 Table 4.4.C: Existing Traffic Noise Levels
Roadway Segment
Average
Daily
Trips
Centerline
to 70 dBA
CNEL
(feet)
Centerline
to 65 dBA
CNEL
(feet)
Centerline
to 60 dBA
CNEL
(feet)
CNEL (dBA)
50 Feet
From
Outermost
Lane
International Avenue between Willow Avenue and
Minnewawa Avenue
1,620 < 50 < 50 < 50 59.0
Behymer Avenue between Willow Avenue and
Minnewawa Avenue
2,360 < 50 < 50 61 60.6
Behymer Avenue between Minnewawa Avenue and
Clovis Avenue
3,720 < 50 < 50 83 62.6
Behymer Avenue between Clovis Avenue and Baron
Avenue
3,720 < 50 < 50 83 62.6
Shepherd Avenue between Willow Avenue and
Minnewawa Avenue
10,330 < 50 92 196 67.1
Shepherd Avenue between Minnewawa Avenue and
Clovis Avenue
9,420 < 50 87 184 66.7
Shepherd Avenue between Clovis Avenue and Sunnyside
Avenue
8,060 < 50 79 166 66.0
Shepherd Avenue between Sunnyside Avenue and
Fowler Avenue
7,040 < 50 71 152 65.9
Herndon Avenue between State Route 168 Eastbound
Ramps and Clovis Avenue
37,560 102 189 390 69.3
Willow Avenue between International Avenue and
Behymer Avenue
8,350 < 50 86 173 65.0
Willow Avenue between Behymer Avenue and Shepherd
Avenue
14,520 64 119 247 67.4
Minnewawa Avenue between International Avenue and
Behymer Avenue
6,020 < 50 53 114 64.7
Minnewawa Avenue between Behymer Avenue and
Shepherd Avenue
4,830 < 50 < 50 99 63.7
Baron Avenue between Behymer Avenue and Perrin
Avenue
0 < 50 < 50 < 50 20.1
Baron Avenue between Perrin Avenue and Clovis Avenue 0 < 50 < 50 < 50 20.1 Clovis Avenue between Baron Avenue and Shepherd
Avenue
1,410 < 50 < 50 < 50 56.9
Clovis Avenue between Shepherd Avenue and Teague
Avenue
4,570 < 50 < 50 98 62.0
Clovis Avenue between Teague Avenue and Nees Avenue 8,220 < 50 69 142 64.5 Clovis Avenue between Nees Avenue and Alluvial Avenue 10,870 < 50 82 171 65.7 Clovis Avenue between Alluvial Avenue and Herndon
Avenue
17,260 < 50 109 231 67.8
Source: Compiled by LSA (February 2023).

Note: Traffic noise within 50 feet of the roadway centerline should be evaluated with site-specific information.

ADT = average daily traffic
CNEL = Community Noise Equivalent Level
dBA = A-weighted decibels
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) 4.4-9 Existing Sensitive Land Uses. Sensitive receptors include residences, schools, hospitals, churches, and similar uses that are sensitive to noise. Construction and operation associated with the proposed project could adversely affect nearby noise-sensitive land uses. The closest sensitive receptors include single-family residential uses located approximately 55 feet east of the project site along Behymer Avenue, approximately 230 feet west of the project site, and approximately 530 feet southeast of the project site along Baron Avenue. The closest existing schools to the project site are the Woods Elementary School, located approximately 0.75 miles south of the project site, and Buchanan High School, approximately 1.08 miles southwest of the project site.

Stationary Noise Sources. Stationary noise sources can also have an effect on the population, and unlike mobile, transportation‐related noise sources, these sources generally have a more permanent and consistent impact on people. Stationary noise sources involve various uses and activities, including various industrial uses, commercial operations, agricultural production, school playgrounds, high school football games, on-site heating, ventilation, and air conditioning (HVAC) units, generators, lawn maintenance equipment, and swimming pool pumps.

4.4.2 Regulatory Setting

4.4.2.1 Federal Regulations
United States Environmental Protection Agency. In 1972, Congress enacted the United States Noise Control Act. This act authorized the United States Environmental Protection Agency (USEPA) to publish descriptive data on the effects of noise and establish levels of sound “requisite to protect the public welfare with an adequate margin of safety.” These levels are separated into health (hearing loss levels) and welfare (annoyance levels). For protection against hearing loss, 96 percent of the population would be protected if sound levels are less than or equal to 70 dBA during a 24-hour period of time. At 55 dBA Ldn, 95 percent sentence clarity (intelligibility) may be expected at 11 ft, with no community reaction. However, 1 percent of the population may complain about noise at this level and 17 percent may indicate annoyance. The USEPA cautions that these identified levels are guidelines, not standards.3
Federal Transit Administration. Vibration standards included in the FTA Manual are used in this analysis for ground-borne vibration impacts on human annoyance, as shown in Table 4.4.D. The criteria presented in Table 4.4.D account for the variations in project types, which differ widely among projects.

The criteria for environmental impact from ground-borne vibration and noise are based on the maximum levels for a single event. Table 4.4.E lists the potential vibration building damage criteria associated with construction activities, as suggested in the FTA Manual. 3 United States Environmental Protection Agency (USEPA). 1974. Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety. 977
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4.4 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) -10 Table 4.4.D: Interpretation of Vibration Criteria for Detailed Analysis Land Use Max Lv
(VdB)1 Description of Use
Workshop 90 Vibration that is distinctly felt. Appropriate for workshops and similar areas not as sensitive to vibration.

Office 84 Vibration that can be felt. Appropriate for offices and similar areas not as sensitive to vibration.

Residential Day 78 Vibration that is barely felt. Adequate for computer equipment and low-power optical microscopes (up to 20×).

Residential Night and
Operating Rooms
72 Vibration is not felt, but ground-borne noise may be audible inside quiet rooms.

Suitable for medium-power microscopes (100×) and other equipment of low sensitivity.

Source: Transit Noise and Vibration Impact Assessment Manual (FTA 2018). 1 As measured in 1/3-Octave bands of frequency over the frequency range 8 to 80 Hertz.

FTA = Federal Transit Administration
LV = velocity in decibels
Max = maximum
VdB = vibration velocity decibels
Table 4.4.E: Construction Vibration Damage Criteria
Building Category PPV (in/sec) Approximate LV (VdB)1
Reinforced concrete, steel, or timber (no plaster) 0.50 102 Engineered concrete and masonry (no plaster) 0.30 98
Non-engineered timber and masonry buildings 0.20 94
Buildings extremely susceptible to vibration damage 0.12 90 Source: Transit Noise and Vibration Impact Assessment Manual (FTA 2018). 1 RMS vibration velocity in decibels (VdB) re 1 µin/sec. µin/sec = microinches per second
FTA = Federal Transit Administration
in/sec = inch/inches per second
LV = velocity in decibels
PPV = peak particle velocity
RMS = root-mean-square
VdB = vibration velocity decibels
FTA Manual guidelines show that for potential annoyance thresholds, a level of up to 78 VdB is acceptable during the daytime hours at residential uses while a level of 87 VdB is appropriate for office uses, and a level of 90 VdB is appropriate for workshop uses. To assess damage potential, a vibration level of up to 102 VdB (equivalent to 0.5 in/sec in PPV) is considered safe for buildings consisting of reinforced concrete, steel, or timber (no plaster) and would not result in any construction vibration damage. For a non-engineered timber and masonry building, the construction building vibration damage criterion is 94 VdB (0.2 in/sec in PPV).

4.4.2.2 State Regulations
The State of California has established regulations that help prevent adverse impacts to occupants of buildings located near noise sources. Referred to as the State Noise Insulation Standard, it requires buildings to meet performance standards through design and/or building materials that would offset any noise source in the vicinity of the receptor. State regulations include requirements for the construction of new hotels, motels, apartment houses, and dwellings other than detached single-family dwellings that are intended to limit the extent of noise transmitted into habitable spaces. These requirements are found in the California Code of Regulations, Title 24 (known as the Building Standards Administrative Code), Part 2 (known as the California Building Code), Appendix Chapters 12 and 12A.
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) 4.4-11 The State has also established land use compatibility guidelines for determining acceptable noise levels for specified land uses.

4.4.2.3 Local Regulations
City of Clovis General Plan. The City of Clovis General Plan provides goals, policies, and action items that work to protect residents from the harmful effects of exposure to excessive noise. Table 4.4.F includes policies and action items from the General Plan that would be applicable to the proposed project, and Table 4.4.G shows the City’s Land Use and Noise Compatibility Matrix.

Table 4.4.F: City of Clovis General Plan Policies Related to Noise Policy/Action
Item Number Policy
Environmental Safety Element
Policy 3.1 Land use compatibility. Approve development and require mitigation measures to ensure existing and future land use compatibility as shown in Table 4.4.G Noise Level Exposure and Land Use Compatibility Matrix and the city’s noise ordinance.

Policy 3.2 Land use and traffic patterns. Discourage land use and traffic patterns that would expose sensitive land uses or noise-sensitive areas to unacceptable noise levels Policy 3.3 New residential. When new residential development is proposed adjacent to land designated for industrial or commercial uses, require the proposed development to assess potential noise impacts and fund feasible noise-related mitigation measures.

Policy 3.4 Acoustical study. Require an acoustical study for proposed projects that have the potential to exceed acceptable noise thresholds or are exposed to existing or future noise levels in excess of the thresholds in the city’s noise ordinance.

Policy 3.5 Site and building design. Minimize noise impacts by requiring appropriate site, circulation, equipment, and building design, and sound walls, landscaping, and other buffers.

Policy 3.6 Noise impacts. Minimize or eliminate persistent, periodic, or impulsive noise impacts of business operations.

Policy 3.7 Mixed-use buildings. Require that mixed-use structures be designed to prevent transfer of noise and vibration between uses.

Policy 3.14 Control sound at the source. Prioritize using noise mitigation measures to control sound at the source before buffers, soundwalls, and other perimeter measures.

Source: City of Clovis General Plan (August 2014).
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4.4 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) -12 Table 4.4.G: Land Use and Noise Compatibility Matrix
Land Uses Energy Average (CNEL)
Example Land Uses < 55 60 65 70 75 80>
Amphitheater, concert hall, auditorium, meeting hall B B C C D D D Mobile home A A B C C D D
Hospital, library, school, faith/religious uses A A B C C D D Hotel, motel, transient lodging A A B B C C D
Single family, multifamily, faith/religious uses A A B B C D D Parks A A A B C D D
Office building, research & development, professional office, city office building, and hotel A A A B B C D
Amusement park, miniature golf, go-cart track, health club, equestrian center A A A B B D D
Golf courses, nature centers, cemeteries, wildlife reserves, wildlife habitat A A A A B C C
Commercial retail, bank, restaurant, movie theater A A A A B B C Automobile service station, auto dealer, manufacturing, warehousing, wholesale, utilities A A A A B B B
Agriculture A A A A A A A
Source: General Plan City of Clovis. Table ES-2. (City of Clovis, August 2014).

Notes:

Compatibility zones indicate the degree to which the land uses listed are compatible with the noise levels (CNEL) shown in the table.

Zone A. Clearly Compatible. Specified land use is satisfactory, based upon the assumption that any buildings involved are of normal conventional construction without any special noise insulation requirements.

Zone B. Normally Compatible. New construction or development should be undertaken only after detailed analysis of the noise reduction requirements are made and needed noise insulation features in the design are determined. Conventional construction, with closed windows and fresh air supply systems or air conditioning, will normally suffice.

Zone C. Normally Incompatible. New construction or development should normally be discouraged. If new construction or development does proceed, a detailed analysis or noise reduction requirements must be made and needed noise insulation features must be included in the design.

Zone D. Clearly Incompatible. New construction or development should generally not be undertaken.

City of Clovis Municipal Code. The City’s Municipal Code contains noise standards and regulation for different activities and land uses in the City. See Section 9.22.080 of the Municipal Code for the City of Clovis Noise ordinance. Section 9.22.080 (D) sets exterior noise standards as shown in Table 4.4.H and interior noise standards as shown in Table 4.4.I.

Table 4.4.H: City of Clovis Maximum Exterior Noise Standards Noise
Zone Type of Land Use Allowable Exterior Noise Level (15-Minute Leq), dBA Daytime (7:00 AM to 10:00 PM) Nighttime (10:00 PM to 7:00 AM) I Single-, two- or multiple-family residential 55 50
II Commercial 65 60
III Residential portions of mixed-use
properties
60 50
IV Industrial or manufacturing 70 70
Source: City of Clovis Municipal Code
dBA = A-weighted decibel
Leq = equivalent continuous sound level
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) 4.4-13 Table 4.4.I: City of Clovis Maximum Interior Noise Standards Noise
Zone Type of Land Use Allowable Interior Noise Level (15-Minute Leq), dBA Daytime (7:00 AM to 10:00 PM) Nighttime (10:00 PM to 7:00 AM) I Residential 45 40
II Administrative/professional office 50 -
III Residential portions of mixed-use
properties
45 40
Source: City of Clovis Municipal Code
dBA = A-weighted decibel
Leq = equivalent continuous sound level
In addition, pursuant to the City of Clovis Municipal Code Section 5.27.604, construction activities are permitted between the hours of 7:00 a.m. and 7:00 p.m. Monday through Friday and between 9:00 a.m. and 5:00 p.m. on Saturday and Sunday. From June 1 through September 15, permitted construction activity may commence after 6:00 a.m. Monday through Friday.4

4.4.3 Impacts and Mitigation Measures
The following section presents a discussion of the impacts related to noise that could result from implementation of the proposed project. The section begins with the criteria of significance, which establish the thresholds to determine if an impact is significant. The latter part of this section presents the impacts associated with implementation of the proposed project and the recommended mitigation measures, if required. Mitigation measures are recommended, as appropriate, for significant impacts to eliminate or reduce them to a less-than-significant level.

Cumulative impacts are also addressed.

4.4.3.1 Significance Criteria
Based on State CEQA Guidelines Appendix G, the proposed project would have a significant impact related to noise if it would:
a. Generate 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;
b. Generate excessive groundborne vibration or groundborne noise levels; c. For a project located within the vicinity of a private airstrip an airport land use plan or, where such a plan has not been adopted, within 2 miles of a public airport or public use airport, expose people residing or working in the project area to excessive noise levels. 4 City of Clovis. 2021. Clovis Municipal Code. Title 5: Public Welfare, Morals and Conduct. Chapter 5.27:

Nuisances. Website: https://www.codepublishing.com/CA/Clovis/#!/Clovis05/Clovis0527.html#5.27.604 (accessed June 21, 2022).
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4.4.3.2 Project Impacts
The following discussion describes the potential impacts related to noise that could result from implementation of the proposed project.
a. Would the project generate 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? The following section describes the short-term construction and long-term operational noise impacts associated with implementation of the proposed project.

Short-Term Construction Noise Impacts. Project construction would result in short-term noise impacts on the nearby sensitive receptors. Maximum construction noise would be short-term, generally intermittent depending on the construction phase, and variable depending on receiver distance from the active construction zone. The duration of noise impacts generally would be from 1 day to several days, depending on the phase of construction. The level and types of noise impacts that would occur during construction are described below.

Construction would result in short-term noise impacts on the nearby sensitive receptors. Maximum construction noise would be short-term, generally intermittent depending on the construction phase, and variable depending on receiver distance from the active construction zone. The duration of noise impacts generally would be from one day to several days depending on the phase of construction. The level and types of noise impacts that would occur during construction are described below.

Short-term noise impacts would occur during grading and site preparation activities. Table 4.4.J lists typical construction equipment noise levels (Lmax) recommended for noise impact assessments, based on a distance of 50 feet between the equipment and a noise receptor, obtained from the FHWA Roadway Construction Noise Model. Construction-related short-term noise levels would be higher than existing ambient noise levels currently in the project area but would no longer occur once construction of the project is completed.

Two types of short-term noise impacts could occur during construction of the proposed project. The first type involves construction crew commutes and the transport of construction equipment and materials to sites, which would incrementally increase noise levels on roads leading to the site.

The second type of short-term noise impact is related to noise generated during grading and construction on the project site. Construction is performed in discrete steps, or phases, each with its own mix of equipment and, consequently, its own noise characteristics. These various sequential phases would change the character of the noise generated on site. Therefore, the noise levels vary as construction progresses. Despite the variety in the type and size of construction equipment, similarities in the dominant noise sources and patterns of operation allow construction-related noise ranges to be categorized by work phase.
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) 4.4-15 Table 4.4.J: Typical Construction Equipment Noise Levels Equipment Description Acoustical Usage Factor (%) Maximum Noise Level (Lmax) at 50 Feet1 Backhoes 40 80
Compactor (ground) 20 80
Compressor 40 80
Cranes 16 85
Dozers 40 85
Dump Trucks 40 84
Excavators 40 85
Flat Bed Trucks 40 84
Forklift 20 85
Front-end Loaders 40 80
Graders 40 85
Impact Pile Drivers 20 95
Jackhammers 20 85
Pick-up Truck 40 55
Pneumatic Tools 50 85
Pumps 50 77
Rock Drills 20 85
Rollers 20 85
Scrapers 40 85
Tractors 40 84
Welder 40 73
Source: Roadway Construction Noise Model (FHWA 2006).

Note: Noise levels reported in this table are rounded to the nearest whole number. 1 Maximum noise levels were developed based on Spec 721.560 from the Central Artery/Tunnel (CA/T) program to be consistent with the City of Boston’s Noise Code for the “Big Dig” project.

Lmax = maximum instantaneous sound level
Table 4.4.J lists maximum noise levels recommended for noise impact assessments for typical construction equipment, based on a distance of 50 feet between the equipment and a noise receptor. Typical maximum noise levels range up to 87 dBA Lmax at 50 feet during the noisiest construction phases. The site preparation phase, including excavation and grading of the site, tends to generate the highest noise levels because earthmoving machinery is the noisiest construction equipment. Earthmoving equipment includes excavating machinery such as backfillers, bulldozers, draglines, and front loaders. Earthmoving and compacting equipment includes compactors, scrapers, and graders.

Specific construction details (e.g., construction fleet activities) are not yet known, therefore, this analysis assumes a crane, forklift, tractor, welder, and compressor would be operating simultaneously during construction of the proposed project. Based on the typical construction equipment noise levels shown in Table 4.4.J, noise levels associated with a crane, forklift, tractor, welder, and compressor operating simultaneously would be approximately 87 dBA Lmax at 50 feet.

Noise-sensitive receptors include residences, schools, hospitals, churches, and similar uses that are sensitive to noise. As discussed above, the closest sensitive receptors include single-family residential uses located approximately 55 feet east of the project site along Behymer Avenue, approximately 230 feet west of the project site, and approximately 530 southeast of the project site along Baron Avenue. Construction of the proposed project could adversely affect these nearby 983
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4.4 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) -16 noise-sensitive land uses. At 55 feet, there would be a decrease of approximately 1 dBA from the increased distance compared to the noise level measured at 50 feet from the active construction area. Therefore, the closest sensitive receptor may be subject to short-term maximum construction noise reaching 86 dBA Lmax during construction. However, construction equipment would operate at various locations within the 71.54-acre project site and would only generate this maximum noise level when operations occur closest to the receptor.

As identified above, pursuant to the City of Clovis Municipal Code Section 5.27.604, construction noises are permitted between the hours of 7:00 a.m. and 7:00 p.m. Monday through Friday and between 9:00 a.m. and 5:00 p.m. on Saturday and Sunday. From June 1st through September 15th, permitted construction activity may commence after 6:00 a.m. Monday through Friday. While construction noise impacts are exempt from specific noise levels limits under the City’s Municipal Code, project construction noise would result in a potentially significant impact at the nearest offsite sensitive residential use. As such, Mitigation Measure NOI-1.1 would be required to ensure that all construction equipment, fixed or mobile, is equipped with properly operating and maintained mufflers consistent with manufacturers’ standards, which would reduce the potential impacts associated with construction equipment. Additionally, Mitigation Measure NOI-1.1 requires the project to designate a “disturbance coordinator” at the City who would be responsible for responding to any local complaints about construction noise. The disturbance coordinator would determine the cause of the noise complaint (e.g., starting too early, bad muffler) and would determine and implement reasonable measures warranted to correct the problem.

With implementation of Mitigation Measure NOI-1.1, the proposed project would result in a less than significant impact associated with the generation of a substantial temporary increase in ambient noise levels in the vicinity during construction.

Long-Term Operational Noise Impacts. Noise-generating uses associated with development of the proposed project would typically include vehicle traffic and operational noise, such as HVAC and pool pump equipment.

Traffic Noise Impacts. Traffic noise levels under the existing conditions and by phase were assessed using the FHWA Highway Traffic Noise Prediction Model (FHWA RD 77-108). Traffic volumes were obtained from the proposed project’s Transportation Impact Analysis (Appendix G). Existing, Near-Term (2026), and Cumulative (2046) without and with project traffic noise levels at 50 feet from the centerline of the outermost travel lane for each roadway segment in the project area are shown in Table 4.4.K. These noise levels represent the worstcase scenario, which assumes that no shielding is provided between traffic and the location where the noise contours are drawn.

Appendix F provides the specific assumptions used in developing these noise levels and model printouts.
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) 4.4-17 Table 4.4.K: Traffic Noise Levels Without and With Proposed Project Roadway Segment
Existing Existing With Project Near-Term (2026) Near-Term (2026) With Project Cumulative (2026) Cumulative (2026) With Project ADT
CNEL (dBA)
50 feet
from
Centerline
of Nearest
Lane
ADT
CNEL (dBA)
50 feet
from
Centerline
of Nearest
Lane
Increase
from
Existing
Conditions
ADT
CNEL (dBA)
50 feet
from
Centerline
of Nearest
Lane
ADT
CNEL (dBA)
50 feet
from
Centerline
of Nearest
Lane
Increase
from
NearTerm
Conditions
ADT
CNEL (dBA)
50 feet
from
Centerline
of Nearest
Lane
ADT
CNEL (dBA)
50 feet
from
Centerline
of Nearest
Lane
Increase
from
Cumulative
Conditions
International Avenue between Willow Avenue and Minnewawa Avenue 1,620 59.0 1,670 59.1 0.1 1,900 59.7 1,950 59.8 0.1 4,420 63.3 4,470 63.4 0.1 Behymer Avenue between Willow Avenue and Minnewawa Avenue 2,360 60.6 2,630 61.1 0.5 2,830 61.4 3,100 61.8 0.4 9,264 66.6 9,534 66.7 0.1 Behymer Avenue between Minnewawa Avenue and Clovis Avenue 3,720 62.6 4,170 63.1 0.5 4,140 63.1 4,590 63.5 0.4 9,833 66.8 10,283 67.0 0.2 Behymer Avenue between Clovis Avenue and Baron Avenue 3,720 62.6 4,170 63.1 0.5 4,060 63.0 4,510 63.4 0.4 10,482 67.1 10,932 67.3 0.2 Shepherd Avenue between Willow Avenue and Minnewawa Avenue 10,330 67.1 11,330 67.5 0.4 26,560 71.2 27,560 71.4 0.2 27,817 71.4 28,817 71.6 0.2 Shepherd Avenue between Minnewawa Avenue and Clovis Avenue 9,420 66.7 10,870 67.3 0.6 23,160 70.6 24,610 70.9 0.3 24,210 70.8 25,660 71.1 0.3 Shepherd Avenue between Clovis Avenue and Sunnyside Avenue 8,060 66.0 8,780 66.4 0.4 23,160 70.6 23,880 70.7 0.1 24,138 70.8 24,858 70.9 0.1 Shepherd Avenue between Sunnyside Avenue and Fowler Avenue 7,040 65.9 7,600 66.3 0.4 19,270 70.3 19,830 70.4 0.1 20,066 70.5 20,626 70.6 0.1 Herndon Avenue between State Route 168 Eastbound Ramps and Clovis Avenue 37,560 69.3 39,010 69.5 0.2 43,460 69.9 44,910 70.1 0.2 47,547 70.3 48,997 70.5 0.2 Willow Avenue between International Avenue and Behymer Avenue 8,350 65.0 8,840 65.3 0.3 14,310 67.4 14,800 67.5 0.1 14,994 67.6 15,484 67.7 0.1 Willow Avenue between Behymer Avenue and Shepherd Avenue 14,520 67.4 14,790 67.5 0.1 34,310 71.2 34,580 71.2 0.0 35,997 71.4 36,267 71.4 0.0 Minnewawa Avenue between International Avenue and Behymer Avenue 6,020 64.7 6,180 64.8 0.1 6,890 65.3 7,050 65.4 0.1 11,451 67.5 11,611 67.5 0.0 Minnewawa Avenue between Behymer Avenue and Shepherd Avenue 4,830 63.7 4,830 63.7 0.0 14,220 68.4 14,220 68.4 0.0 15,612 68.8 15,612 68.8 0.0 Baron Avenue between Behymer Avenue and Perrin Avenue - - 3,330 55.4 55.4 170 42.4 3,500 55.6 13.2 5,538 57.6 8,868 59.6 2.0 Baron Avenue between Perrin Avenue and Clovis Avenue - - 5,050 57.2 57.2 1,990 53.1 7,040 58.6 5.5 7,867 59.1 12,917 61.3 2.2 Clovis Avenue between Baron Avenue and Shepherd Avenue 1,410 56.9 6,460 63.5 6.6 7,650 64.2 12,700 66.4 2.2 9,552 65.2 14,602 67.0 1.8 Clovis Avenue between Shepherd Avenue and Teague Avenue 4,570 62.0 7,460 64.1 2.1 10,640 65.7 13,530 66.7 1.0 15,874 67.4 18,764 68.1 0.7 Clovis Avenue between Teague Avenue and Nees Avenue 8,220 64.5 10,890 65.8 1.3 14,010 66.8 16,680 67.6 0.8 17,672 67.9 20,342 68.5 0.6 Clovis Avenue between Nees Avenue and Alluvial Avenue 10,870 65.7 13,040 66.5 0.8 19,840 68.4 22,010 68.8 0.4 20,766 68.6 22,936 69.0 0.4 Clovis Avenue between Alluvial Avenue and Herndon Avenue 17,260 67.8 19,320 68.2 0.4 25,180 69.4 27,240 69.7 0.3 26,374 69.6 28,434 69.9 0.3 Source: Compiled by LSA (February 2023).

Note: Traffic noise within 50 feet of the roadway centerline should be evaluated with site-specific information.

Shaded cells indicate roadways adjacent to the project site.

ADT = average daily traffic
CNEL= Community Noise Equivalent Level
dBA = A-weighted decibels
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) 4.4-19 Off-Site Traffic Noise Impacts. As shown in Table 4.4.K, the largest off-site noise level increase in traffic-related noise as a result of the proposed project would be on Clovis Avenue between Shepherd Avenue and Teague Avenue, with up to a 2.1 dBA increase on under Existing With Project conditions, up to a 1.0 dBA increase under Near-Term (2026) With Project conditions, and up to a 0.7 dBA increase under Cumulative (2046) With Project conditions. This noise level increase would be below the significance criteria for noise-level increases of 3 dBA. As such, with implementation of the proposed project, the off-site traffic noise level increases would be well below the significance threshold for noise-level increases of 3 dBA or more and would not result in a perceptible increase in noise at nearby residential uses. Therefore, off-site traffic-related noise impacts would be less than significant.

On-Site Traffic Noise Impacts. As shown in Table 4.4.K, the largest increase in project-related traffic noise would be along Baron Avenue between Behymer Avenue and Perrin Avenue, with up to a 55.4 dBA increase under Existing With Project conditions, up to a 13.2 dBA increase under Near-Term (2026) with Project conditions, and up to a 2.0 dBA increase under Cumulative (2046) With Project conditions, and between Perrin Avenue and Clovis Avenue, with up to a 13.2 dBA increase under Existing With Project conditions, up to a 5.5 dBA increase under Near-Term (2026) With Project conditions, and up to a 2.2 dBA increase under Cumulative (2046) With Project conditions. In addition, noise level increases along Clovis Avenue between Baron Avenue and Shepherd Avenue would have a noise level increase of up to 6.6 dBA under Existing with Project conditions, up to 2.2 dBA under NearTerm (2026) With Project conditions, and up to 1.8 dBA under Cumulative (2046) With Project conditions.

Although these noise-level increases would be above the perceptible noise level increase of 3 dBA or greater under existing and near-term plus project scenarios, under cumulative plus project conditions, they would not exceed the 3 dBA increase considered to be perceptible by the human ear in an outdoor environment. However, the resultant ambient noise levels would be 59.6 dBA CNEL along Baron Avenue between Behymer Avenue and Perrin Avenue,

61.3 dBA CNEL along Baron Avenue between Perrin Avenue and Clovis Avenue under Cumulative Plus Project conditions, and 67.0 dBA CNEL along Clovis Avenue between Baron Avenue and Shepherd Avenue under Cumulative Plus Project conditions. These ambient noise levels would be considered Normally Compatible for single-family residential uses under the City’s Land Use and Noise Compatibility Matrix, as shown in Table 4.4.G above.

Normally compatible development requires detailed assessment of noise reduction requirements and implementation noise insulation features in project design to fulfill the City’s normally acceptable interior noise level criterion.

Based on USEPA Protective Noise Levels,5 with a combination of walls, doors, and windows, standard construction for Northern California buildings (STC-26) would provide more than 25 dBA in exterior-to-interior noise reduction with windows closed and 15 dBA or more with windows open. With windows open, the buildings would not meet the City’s normally acceptable interior noise standard of 45 dBA CNEL (i.e., 67.0 dBA – 15 dBA = 52 dBA). 5 USEPA. 1978. Protective Noise Levels, Condensed Version of EPA Levels Document. November. 987
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4.4 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) -20 Therefore, an alternate form of ventilation, such as an air-conditioning system, would be required to ensure that windows can remain closed for a prolonged period of time. A ventilation system would reduce noise levels for residents with windows closed and would meet the City’s normally acceptable interior noise level criterion of 45 dBA CNEL (i.e., 67.0 dBA – 25 dBA = 42 dBA). Therefore, the City should verify that buildings include fresh air ventilation.

Implementation of the HVAC system would allow windows to remain closed in order to reduce interior noise levels by 25 dBA, resulting in interior noise levels of 42 dBA CNEL, which would meet the City’s interior noise standard of 45 dBA CNEL. Mitigation Measure NOI-1.2 below would include modifications to ensure that buildings would comply with the City’s noise and land use compatibility standards and reduce interior noise impacts.

Implementation of Mitigation Measure NOI-1.2 would ensure that interior noise levels would be reduced to 45 dBA or less and would be acceptable under the City’s land use compatibility standards. Therefore, this impact would be less than significant with mitigation.

Stationary Operational Noise Impacts. Development of the proposed project may include the installation or creation of new stationary sources of noise, or could include the development of new sensitive land uses in the vicinity of existing noise sources. For residential uses, stationary noise sources may include HVAC equipment noise or pool pumps. These stationary sources of noise would have the potential to disturb adjacent sensitive receptors. However, noise generation would continue to be limited by the City of Clovis’ Noise Ordinance (Clovis Municipal Code, Title 9 Development Code, Chapter 9.22 Performance Standards, Section 9.22.080 Noise).

Precise details of HVAC systems and pump equipment, including future location and sizing, are unknown at this time; therefore, this analysis assumes that mechanical-related noise, including HVAC and pump equipment would generate noise levels of approximately 75 dBA Lmax at 3 feet.6 As discussed above, the closest sensitive receptors include single-family residential uses located approximately 55 feet east of the project site along Behymer Avenue, approximately 230 feet west of the project site, and approximately 530 feet southeast of the project site along Baron Avenue. However, as shown in Figures 3-4 through 3-6, the proposed single-family residential uses would be located across the proposed Baron Avenue, approximately 145 feet from the closest existing residence to the east along Behymer Avenue. At 145 feet, there would be a decrease of approximately 34 dBA over the reference noise level at 3 feet due to attenuation with distance. As such, HVAC-related noise would be approximately 41 dBA Lmax at 50 feet.

Based on this maximum noise level, when averaged over a 15-minute period, this noise level would not exceed the City’s maximum noise level standards of 50 dBA Leq during nighttime hours and 55 dBA Leq during daytime hours, as measured at the nearest receiving sensitive land use. Therefore, stationary operational noise associated with the proposed project would be less than significant.
6 Trane. 2002. Sound Data and Application Guide for the New and Quieter Air-Cooled Series R Chiller. 988
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) 4.4-21 Impact NOI-1: The project would generate 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.

Level of Significance Without Mitigation: Potentially Significant Impact.

Mitigation Measure NOI-1.1 The project contractor shall implement the following measures during construction of the proposed project:
• Equip all construction equipment, fixed or mobile, with properly operating and maintained mufflers consistent with
manufacturers’ standards.
• Place all stationary construction equipment so that emitted noise is directed away from sensitive receptors nearest the active project site.
• Locate equipment staging in areas that would create the greatest possible distance between construction-related noise sources and noise-sensitive receptors nearest the active project site during all construction activities.
• Ensure that all general construction related activities are restricted to between the hours of 7:00 a.m. and 7:00 p.m.

Monday through Friday and between 9:00 a.m. and 5:00 p.m. on Saturday and Sunday. From June 1st through September 15th, permitted construction activity may commence after 6:00 a.m.

Monday through Friday, consistent with the City’s Noise Ordinance.
• Designate a “disturbance coordinator” at the City who would be responsible for responding to any local complaints about construction noise. The disturbance coordinator would
determine the cause of the noise complaint (e.g., starting too early, bad muffler) and would determine and implement
reasonable measures warranted to correct the problem.

Mitigation Measure NOI-1.2 The project contractor shall implement the following measures during construction of the proposed project:
• In order for windows and doors to remain closed, mechanical ventilation such as air conditioning shall be provided for all units.
• All windows and glass doors shall be rated STC 26 or higher such that the noise reduction provided will satisfy the interior noise standard of 45 dBA CNEL.
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4.4 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) -22 Level of Significance With Mitigation: Less Than Significant Impact. Implementation of Mitigation Measure NOI-1.1 and Mitigation Measure NOI-1.2 would reduce project-related impacts to a less than significant level.
b. Would the project generate excessive groundborne vibration or groundborne noise levels? Vibration refers to ground-borne noise and perceptible motion. Groundborne vibration is almost exclusively a concern inside buildings and is rarely perceived as a problem outdoors. Vibration energy propagates from a source, through intervening soil and rock layers, to the foundations of nearby buildings. The vibration then propagates from the foundation throughout the remainder of the structure. Building vibration may be perceived by the occupants as the motion of building surfaces, rattling of items on shelves or hanging on walls, or as a low-frequency rumbling noise. The rumbling noise is caused by the vibrating walls, floors, and ceilings radiating sound waves.

Annoyance from vibration often occurs when the vibration exceeds the threshold of perception by 10 dB or less. This is an order of magnitude below the damage threshold for normal buildings.

Typical sources of ground-borne vibration are construction activities (e.g., pavement breaking and operating heavy-duty earthmoving equipment), and occasional traffic on rough roads. In general, ground-borne vibration from standard construction practices is only a potential issue when it occurs within 25 feet of sensitive uses. Groundborne vibration levels from construction activities very rarely reach levels that can damage structures; however, these levels are perceptible near the active construction site. With the exception of old buildings built prior to the 1950s or buildings of historic significance, potential structural damage from heavy construction activities rarely occurs. When roadways are smooth, vibration from traffic (even heavy trucks) is rarely perceptible. The streets surrounding the project site are paved and unlikely to cause significant ground-borne vibration.

Short-Term Vibration Impacts. Construction of the proposed project could result in the generation of ground-borne vibration. This construction vibration impact analysis discusses the level of human annoyance using vibration levels in VdB and will assess the potential for building damages using vibration levels in peak particle velocity (PPV inches per second [(in/sec]) because vibration levels calculated in RMS are best for characterizing human response to building vibration, while vibration level in PPV is best used to characterize potential for damage. The FTA Transit Noise and Vibration Impact Assessment Manual guidelines indicate that a vibration level up to 102 VdB (an equivalent to

0.5 in/sec in PPV) is considered safe for buildings consisting of reinforced concrete, steel, or timber (no plaster), and would not result in any construction vibration damage. For a non-engineered timber and masonry building, the construction vibration damage criterion is 94 VdB (0.2 in/sec in PPV).7
7 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual. pg. 186. Website: https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/ transit-noise-and-vibration-impact-assessment-manual-fta-report-no-0123_0.pdf (accessed March 21, 2022).
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) 4.4-23 Table 4.4.L shows the PPV and VdB values at 25 feet from a construction vibration source. As shown in Table 4.4.L, bulldozers and other heavy-tracked construction equipment (except for pile drivers and vibratory rollers) generate approximately 87 VdB of ground-borne vibration when measured at 25 feet, based on the Transit Noise and Vibration Impact Assessment. At this level, ground-borne vibration would result in potential annoyance to residents and workers but would not cause any damage to the buildings.

Table 4.4.L: Vibration Source Amplitudes for Construction Equipment Equipment Reference PPV/LV at 25 feet
PPV (in/sec) LV (VdB)1
Pile Driver (Impact), Typical3 0.644 104
Pile Driver (Sonic), Typical 0.170 93
Vibratory Roller 0.210 94
Hoe Ram 0.089 87
Large Bulldozer 0.089 87
Caisson Drilling 0.089 87
Loaded Trucks 0.076 86
Jackhammer 0.035 79
Small Bulldozer 0.003 58
Sources: Transit Noise and Vibration Impact Assessment Manual (FTA 2018). 1 RMS vibration velocity in decibels (VdB) is 1 µin/sec. µin/sec = micro-inches per second
FTA = Federal Transit Administration
in/sec = inches per second
LV = velocity in decibels
PPV = peak particle velocity
RMS = root-mean-square
VdB = vibration velocity decibels
Construction vibration, similar to vibration from other sources, would not have any significant effects on outdoor activities (e.g., those outside of residential buildings in the project vicinity).

Outdoor site preparation for the proposed project is expected to include the use of bulldozers and loaded trucks. The greatest levels of vibration are anticipated to occur during the site preparation phase. All other phases are expected to result in lower vibration levels. The distance to the nearest buildings for vibration impact analysis is measured between the nearest off-site buildings and the project boundary (assuming the construction equipment would be used at or near the project boundary) because vibration impacts occur normally within the buildings. The formula for vibration transmission is provided below.

LvdB (D) = LvdB (25 feet) – 30 Log (D/25)
PPVequip = PPVref x (25/D)1.5
Table 4.4.M lists the projected vibration level from various construction equipment expected to be used on the project site to the nearest buildings in the project vicinity. For typical construction activity, the equipment with the highest vibration generation potential is the large bulldozer, which would generate 87 VdB at 25 feet. The closest sensitive receptors include single-family residential uses located approximately 55 feet east of the project site along Behymer Avenue, approximately 230 feet west of the project site, and approximately 530 southeast of the project site along Baron Avenue.
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4.4 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) -24 Table 4.4.M: Summary of Construction Equipment and Activity Vibration Land Use Direction Equipment/Activity
Reference
Vibration
Level
(VdB) at
25 feet
Reference
Vibration
Level
(PPV) at
25 feet
Distance
(feet)
Maximum
Vibration
Level
(VdB)
Maximum
Vibration
Level
(PPV)
Single-Family
Residential East Large Bulldozers 87 0.089 55 77 0.027
Loaded Trucks 86 0.076 55 76 0.023
Single-Family
Residential West Large Bulldozers 87 0.089 230 58 0.003 Loaded Trucks 86 0.076 230 57 0.003
Single-Family
Residential South Large Bulldozers 87 0.089 530 47 0.001 Loaded Trucks 86 0.076 530 46 0.001
Source: Compiled by LSA (February 2023).

Note: The FTA-recommended building damage threshold is 0.2 PPV (in/sec) or approximately 94 VdB at the receiving property structure or building.

FTA = Federal Transit Administration
in/sec = inch(es) per second
PPV = peak particle velocity
VdB = vibration velocity decibel(s)
As shown in Table 4.4.M, the closest single-family residence located east of the project site would experience vibration levels of up to 77 VdB (0.027 PPV [in/sec]). This vibration level at the nearest building from construction equipment would not exceed the FTA threshold of 94 VdB (0.2 in/sec PPV) for building damage. Although construction vibration levels at the nearest offsite buildings would have the potential to result in annoyance, these vibration levels would no longer occur once construction of the project is completed. Therefore, ground-borne vibration impacts from construction activities associated with the proposed project would not be considered significant.

Impact NOI-2: The project would not generate excessive ground-borne vibration or ground-borne noise levels.

Level of Significance Without Mitigation: Less Than Significant Impact. No mitigation is required. c. For a project located within the vicinity of a private airstrip an airport land use plan or, where such a plan has not been adopted, within 2 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?
The nearest airports include the Fresno Yosemite International Airport, located approximately

6.1 miles southwest of the project site, the Sierra Sky Airport, located approximately 9.3 miles southwest of the project site, and the Fresno Chandler Executive Airport, located approximately

11.3 miles southwest of the project site. Each of these airports is included in the Fresno County ALUCP, which guides approximate compatible land uses.

The ALUCP includes CNEL noise contours based on projected airport and aircraft operations. The purpose of these noise contours is to minimize the effect of airport and aircraft noise on the adjacent community by determining land use compatibility and locations for noise mitigation measures during the planning, design, and development process. The Fresno County ALUCP establishes land uses that are either acceptable or unacceptable within each CNEL noise contour 992
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) 4.4-25 based on the noise sensitivity of the particular use. Noise‐sensitive land uses such as residential uses are typically only acceptable in areas outside the 65 dB CNEL and greater noise contours. It is within these areas that the Fresno County ALUC has determined that residential uses can occur while still minimizing the effects of adjacent and overhead aircraft noise on noise‐sensitive receptors. Any land use decision made within the jurisdictional boundary of the ALUCP, and based upon policies set forth by the approved General Plan, must be consistent with the ALUCP, including the land use compatibility policies based on CNEL noise contours, as required by law.

Based on Figure 5.12-6 of the Noise section of the City’s General Plan EIR, which shows the noise contours for these airports, the project site lies completely outside of the noise contours for these airports. As such, the proposed project would not include new residential uses or similar noise‐sensitive land uses within an ALUCP noise contour area. Furthermore, there are no private airstrips operating within the project site. As a result, any noise associated with private airstrips would not result in substantial noise levels within the project site. Therefore, implementation the proposed project would not result in impacts from adjacent and overhead aircraft noise on noise‐sensitive land uses. therefore, project implementation would not expose people residing or working in the project area to excessive noise levels, and impacts would be less than significant.

Impact NOI-3: 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, the proposed project would not expose people residing or working in the project area to excessive noise levels.

Level of Significance Without Mitigation: Less Than Significant Impact. No mitigation is required.

4.4.3.3 Cumulative Impacts
For the topic of noise, the scope for assessing cumulative impacts encompasses past, current, or probable future projects under review by the City and within proximity to the project site, as well as applicable planning level documents that affect the transportation network (i.e., land use assumptions from the General Plan that would increase trips on area roadways, thereby increasing traffic noise).

Based on the traffic forecasts shown in Table 4.4.K above, under Cumulative Plus Project conditions, cumulative project trips would represent a small increase in noise levels, up to approximately 2.2 dBA CNEL, which would not exceed the 3 dBA increase considered to be perceptible by the human ear in an outdoor environment. Given the small increase in noise levels generated by the proposed project and future cumulative projects that would be implemented in the project vicinity on the transportation network and the anticipated increase in traffic noise anticipated in the vicinity, the proposed project would not result in a cumulatively considerable increase in transportation-related noise.

However, as discussed above, on-site operational traffic noise would be considered Normally Compatible for single-family residential uses under the City’s Land Use and Noise Compatibility Matrix under Cumulative Plus Project conditions, and as such, the project would require implementation of noise reduction requirements and noise insulation features in project design to fulfill the City’s normally acceptable interior noise level criterion. With implementation of Mitigation Measure NOI-1.2, interior noise levels would be reduced to 45 dBA or less and would be acceptable 993
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4.4 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.4-Noise.docx (01/10/24) -26 under the City’s land use compatibility standards. Therefore, this impact would be less than significant with mitigation.

A significant cumulative impact could also occur if implementation of the proposed project would combine with other cumulative development projects to result in any permanent increase of 3 dBA or more in ambient noise levels at the existing sensitive receptors in the project site vicinity that are currently exposed to noise levels above the City’s normally acceptable threshold for that type of land use. As discussed above, long-term operation of the proposed project would not create a significant increase in stationary source noise. As such, permanent increases in noise generated by the proposed project would not be considered a cumulatively considerable contribution to the total noise environment in the project site vicinity, and this impact would be less than significant.

Finally, as discussed above, while construction noise impacts are exempt from specific noise levels limits under the City’s Municipal Code, project construction noise would result in a potentially significant impact at the nearest off-site sensitive residential use. With implementation of Mitigation Measure NOI-1.1, which would require that construction equipment is properly equipped with mufflers consistent with manufacturers’ standards, staged at the greatest distance possible from sensitive receptors, and would require the project to designate a “disturbance coordinator” at the City who would be responsible for responding to any local complaints about construction noise, the proposed project would not result in adverse noise impacts from construction activities. Although the proposed project may be under construction at the same time as one or more cumulative development projects, each project would be required to implement similar measures as those identified in Mitigation Measure NOI-1.1 to ensure that construction noise levels are reduced to the extent feasible and to ensure that construction activities comply with the City’s Noise Ordinance. In addition, construction-related noise impacts would be temporary and would no longer occur once construction of each project is completed. Therefore, construction activities would not be considered a cumulatively considerable contribution to the total noise environment in the project site vicinity, and this impact would be less than significant.

Impact NOI-4: The proposed project, in combination with past, present, and reasonably foreseeable projects, would contribute to a significant cumulative impact with respect to noise.

Level of Significance Without Mitigation: Potentially Significant Impact.

Mitigation Measures: Refer to Mitigation Measures NOI-1.1 and NOI-1.2.

Level of Significance With Mitigation: Less than Significant with Mitigation Measures NOI-1.1 and NOI-1.2.
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4.5 TRANSPORTATION
This section describes the existing transportation network of the proposed site and evaluates the potential impacts associated with the proposed project, both at the individual and cumulative levels.

The analysis in this section is based in part on the City’s General Plan, and on the Transportation Impact Analysis (TIA)1 prepared by LSA included in Appendix G of this Environmental Impact Report (EIR).

4.5.1 Environmental Setting

4.5.1.1 Roadway Network
Within the City of Clovis, major roadways are classified based on the roadway classification provided in the Circulation Element of the City of Clovis General Plan. The following is a brief description of major roadways within the project study area:
• Willow Avenue: Willow Avenue is designated as an arterial in the City’s General Plan. Between International Avenue and Shepherd Avenue, Willow Avenue is a six‐lane, divided arterial with a raised median. There are Class II bicycle lanes along both directions of this segment. However, there is no provision for on‐street parking.
• Minnewawa Avenue: Within the study area, Minnewawa Avenue is designated as a collector between International Avenue and Behymer Avenue, and as an arterial between Behymer Avenue and Shepherd Avenue in the City’s General Plan. Between International Avenue and Shepherd Avenue, Minnewawa Avenue is a two‐lane, undivided road. There are Class II bicycle lanes along both directions of this segment. However, there is no provision for on‐street parking. • Clovis Avenue: Clovis Avenue is designated as an arterial in the City’s General Plan. Between Baron Avenue and Herndon Avenue, Clovis Avenue is mostly a four‐lane, divided arterial with a raised median or a two‐way‐left‐turn lane (TWLTL) median. There are Class II bicycle lanes along some portions of this segment. However, there is no provision for on‐street parking. • Sunnyside Avenue: Sunnyside Avenue is designated as a collector in the City’s General Plan.

Within the study area, Sunnyside Avenue is a two‐lane, undivided road. There are no bicycle facilities in either direction in this segment. There is also no provision for on‐street parking. • Fowler Avenue: Fowler Avenue is designated as a rural collector between Behymer Avenue and Shepherd Avenue, and as an arterial between Shepherd Avenue and the State Route 168 (SR‐168) Westbound Ramps in the City’s General Plan. Between Behymer Avenue and Nees Avenue, Fowler Avenue is a two‐lane partly divided and partly undivided road. There is a Class II bicycle lane in the southbound direction only along a small portion of this segment near the intersection with Shepherd Avenue. There is no provision for on‐street parking. Between Nees Avenue and Goshen Avenue, Fowler Avenue is a three‐lane divided road with a raised median. There is a Class II bicycle lane only along the northbound direction of this segment. There is no provision for on‐street 1 LSA. 2023a. Transportation Impact Analysis Tract Map 6343 Project, Clovis, Fresno County, California.

August.
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4.5 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) -2 parking. Between Goshen Avenue and the SR‐168 Westbound Ramps, Fowler Avenue is a four‐ lane divided road with a raised median. There are Class II bicycle lanes along both directions of this segment. There is no provision for on‐street parking. • International Avenue: International Avenue is designated as a collector between Willow Avenue and Minnewawa Avenue in the City’s General Plan. Within the study area, International Avenue is a two‐lane, undivided road. There are no bicycle facilities in either direction in this segment.

There is also no provision for on‐street parking.
• Behymer Avenue: Within the study area, Behymer Avenue is designated as an arterial between Willow Avenue and Clovis Avenue, as a collector between Clovis Avenue and Sunnyside Avenue, and as a rural collector between Sunnyside Avenue and Fowler Avenue in the City’s General Plan.

Between Willow Avenue and Fowler Avenue, Behymer Avenue is a two‐lane, undivided road.

There are no bicycle facilities in either direction in this segment. There is also no provision for on‐ street parking.
• Shepherd Avenue: Within the study area, Shepherd Avenue is designated as an arterial between Willow Avenue and Clovis Avenue, and as an Expressway between Clovis Avenue and Fowler Avenue in the City’s General Plan. Between Willow Avenue and Sunnyside Avenue, Shepherd Avenue is a three‐lane, divided road with a raised median, while between Sunnyside Avenue and Fowler Avenue, it is a two‐lane, partly undivided and partly divided road. There are Class II bicycle lanes along both directions of the segment between Willow Avenue and Sunnyside Avenue. There are no bicycle facilities in any direction of the segment between Sunnyside Avenue and Fowler Avenue. There is no provision for on‐street parking along any of these segments. • Teague Avenue: Teague Avenue is designated as a collector in the City’s General Plan. Between Sunnyside Avenue and Fowler Avenue, Teague Avenue is a two‐lane, undivided arterial. There are no bicycle facilities in this segment. There is also no provision for on-street parking. • Nees Avenue: Within the study area, Nees Avenue is designated as an arterial in the City’s General Plan. Between Clovis Avenue and Sunnyside Avenue, Nees Avenue is a mostly two‐lane undivided road. There is a Class II bicycle lane in the eastbound direction only along a small portion of this segment near the intersection with Sunnyside Avenue. However, there is no provision for on‐ street parking. Between Sunnyside Avenue and Fowler Avenue, Nees Avenue is a three‐lane divided arterial with a raised median or a TWLTL median. There are Class II bicycle lanes along some portions of this segment; however, there is no provision for on‐street parking. • Alluvial Avenue: Within the study area, Alluvial Avenue is designated as a collector in the City’s General Plan. Between Clovis Avenue and Sunnyside Avenue, Alluvial Avenue is a two‐lane, divided collector with a TWLTL median. However, between Sunnyside Avenue and Fowler Avenue, Alluvial Avenue is a partly three‐lane and partly four‐lane undivided collector. There are Class II bicycle lanes along both directions of these segments; however, there is no provision for on-street parking.
• Herndon Avenue: Within the study area, Herndon Avenue is designated as an arterial in the City’s General Plan. Between the SR‐168 Eastbound Ramps and Clovis Avenue, Herndon Avenue is a 10‐ 996
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) 4.5-3 lane, divided arterial with a raised median. There are no bicycle facilities along either direction in this segment. There is also no provision for on‐street parking.

4.5.1.2 Bicycle Facilities
Caltrans provides the following descriptions for types of bikeway facilities:
• Class I Bikeway (Bike Path): Class I bikeways, also known as bike paths or shared-use paths, are facilities with exclusive right of way for bicyclists and pedestrians, away from the roadway and with cross flows by motor traffic minimized. Some systems provide separate pedestrian facilities.

Class I facilities support both recreational and commuting opportunities. Common applications include along rivers, shorelines, canals, utility rights-of-way, railroad rights-of-way, within school campuses, or within and between parks.
• Class II Bikeway (Bike Lane): Class II bikeways are bike lanes established along streets and are defined by pavement striping and signage to delineate a portion of a roadway for bicycle travel.

Bike lanes are one-way facilities, typically striped adjacent to motor traffic travelling in the same direction. Contraflow bike lanes can be provided on one-way streets for bicyclists travelling in the opposite direction.
• Class III Bikeway (Bike Route): Class III bikeways, or bike routes, designate a preferred route for bicyclists on streets shared with motor traffic not served by dedicated bikeways to provide continuity to the bikeway network. Bike routes are generally not appropriate for roadways with higher motor traffic speeds or volumes. Bike routes are established by placing bike route signs and optional shared roadway markings (sharrow) along roadways. • Class IV Bikeway (Separated Bikeways): A Class IV separated bikeway, often referred to as a cycle track or protected bike lane, is for the exclusive use of bicycles, physically separated from motor traffic with a vertical feature. The separation may include, but is not limited to, grade separation, flexible posts, inflexible barriers, or on-street parking. Separated bikeways can provide for oneway or two-way travel. By providing physical separation from motor traffic, Class IV bikeways can reduce the level of stress, improve comfort for more types of bicyclists, and contribute to an increase in bicycle volumes and mode share.

According to the City of Clovis Active Transportation Plan (ATP), the bikeway network within the City is classified into four categories:
• Class I (Trails)
• Class II (Bicycle Lanes)
• Class II (Buffered Bicycle Lanes)
• Class III (Bicycle Routes)
One of the long‐term visions of the City includes upgrading existing or recommended Class II Bicycle Lanes and Buffered Bicycle Lanes to Class IV Separated Bicycle Lanes. At present, Class II bicycle lanes exist along Clovis Avenue, Willow Avenue, and some segments of Shepherd Avenue and Fowler 997
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4.5 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) -4 Avenue within the study area. However, different bicycle facilities are proposed along other roadways within the study area, such as Sunnyside Avenue, Teague Avenue, Nees Avenue, and Alluvial Avenue.

4.5.1.3 Pedestrian Facilities
The City has an extensive pedestrian network, with sidewalks along most major roadways. However, since a portion of the study area falls within recently incorporated areas of the City, sidewalks are not present because they were previously developed as per unincorporated Fresno County design guidelines.

The City’s ATP has identified improvements to the pedestrian network based on a citywide sidewalk network gap analysis. Additionally, several potential locations have been identified to install midblock crossings to improve trail connectivity throughout Clovis. Two trails (i.e., the Dry Creek Trail and the Enterprise Trail) currently exist within the study area. However, additional trails are being proposed in the study area with potential mid‐block crossings.

4.5.1.4 Transit Facilities
Clovis Transit Stageline is the Transportation Service Agency within the City of Clovis and is responsible for coordinating transit services within its service area. Fresno Area Express (FAX), the Transportation Service Agency for the City of Fresno, provides four routes for Clovis Transit Stageline.

Clovis Transit Stageline Routes 10 and 80 operate within the study area for the proposed project.

Route 10 operates from Monday through Saturday, while Route 80 operates only on school days, based on the Clovis Unified School District schedule. Route 10 provides access to Fresno State University, and Route 80 provides access to Buchanan Education Complex. Fresno Area Express (FAX) Route 3 operates within the study area along Willow Avenue seven days a week. The route connects communities in Fresno to the different campuses of Clovis Community College.

In addition to fixed route services, Round Up is the Clovis paratransit service for disabled City residents. Round Up transit vehicles are all accessible in accordance with the Americans with Disabilities Act (ADA) standards.

4.5.2 Regulatory Setting

4.5.2.1 Federal Regulations
Federal Highway Administration. The Federal Highway Administration (FHWA) is a major agency of the United States Department of Transportation. In partnership with State and local agencies, the FHWA carries out federal highway programs to meet the nation’s transportation needs. The FHWA administers and oversees federal highway programs to ensure that federal funds are used efficiently.

Americans with Disabilities Act of 1990. Titles I, II, III, IV, and V of the ADA have been codified in Title 42 of the United States Code, beginning at Section 12101. Title III prohibits discrimination on the basis of disability in “places of public accommodation” (businesses and nonprofit agencies that serve the public) and “commercial facilities” (other businesses). The regulation includes Standards for Accessible Design, which establish minimum standards for ensuring accessibility when designing and constructing a new facility or altering an existing facility. 998
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) 4.5-5 Federal Transit Administration. The Federal Transit Administration (FTA) is an authority that provides financial and technical assistance to local public transit systems, including buses, subways, light rail, commuter rail, trolleys, and ferries. The FTA is funded by Title 49 of the United States Code, which states the FTA’s interest in fostering the development and revitalization of public transportation systems. The FTA invests approximately $12 billion annually to support and expand public transit.

4.5.2.2 State Regulations
Assembly Bill 32 (Global Warming Act of 2006) and Senate Bill 375. Assembly Bill (AB) 32, the California Global Warming Solutions Act of 2006, requires California to reduce its greenhouse gas (GHG) emissions to levels presented in the year 1990 by 2020. In response, the California Air Resources Board (CARB) is responsible for creating guidelines for this Act. In 2008, CARB adopted its proposed Scoping Plan, which included the approval of Senate Bill (SB) 375 as a means of achieving regional transportation-related GHG targets. SB 375 provides guidance on how curbing emissions from cars and light trucks helps the State comply with AB 32.

Established through CARB, SB 375 lists four major components and requirements: (1) it requires regional GHG emissions targets; (2) it requires creating a Sustainable Communities Strategy (SCS) that provides a plan for meeting the regional targets; (3) it requires that regional housing elements and transportation plans be synchronized on 8-year schedules; and (4) it requires transportation and air pollutant emissions modeling techniques consistent with guidelines prepared by the California Transportation Commission (CTC).

Assembly Bill 1358 (Complete Streets). The California Complete Streets Act requires general plans updated after January 30, 2011, to include Complete Streets policies so that roadways are designed to safely accommodate all users, including bicyclists, pedestrians, transit riders, children, the elderly, and persons with disabilities, as well as motorists. The goal of this act is to encourage cities to rethink policies that emphasize automobile circulation and prioritize motor vehicle improvements and produce creative solutions that emphasize all modes of transportation. Complete Streets roadways allow for more transportation options, more non-single-occupancy vehicles, and less traffic congestion. Additionally, increased transit ridership, walking, and biking can reduce air pollution while improving the overall travel experience for road users. While there is no standard for a Complete Streets design, it generally includes one or more of the following features: bicycle lanes, wide shoulders, well-designed and well-placed crosswalks, crossing islands in appropriate mid-block locations, bus pullouts or special bus lanes, audible and accessible pedestrian signals, sidewalk bulbouts, center medians, street trees, planter strips, and groundcover.

Senate Bill (SB) 743. On September 27, 2013, Governor Jerry Brown signed SB 743 into law and codified a process that changed transportation impact analysis as part of CEQA compliance. SB 743 directs the California Office of Planning and Research (OPR) to administer new CEQA guidance for jurisdictions that removes automobile vehicle delay and LOS or other similar measures of vehicular capacity or traffic congestions from CEQA transportation analysis. Rather, it requires the analysis of vehicle miles traveled (VMT) or other measures that “promote the reduction of greenhouse gas emissions, the development of multi-modal transportation networks, and a diversity of land uses,” to be used as a basis for determining significant impacts to circulation in California. The goal of SB 743 is to appropriately balance the needs of congestion management with statewide goals related to 999
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4.5 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) -6 reducing GHG emissions, encourage infill development, and promote public health through active transportation.

Guide for the Preparation of Traffic Impact Studies. Caltrans’ “Guide for the Preparation of Traffic Impact Studies”2 provides general guidance regarding the preparation of traffic impact studies for projects that may have an impact on the State Highway System. The guidance includes when a traffic study should be prepared and the methodology to use when evaluating operating conditions on the State highway system. The “Guide for the Preparation of Traffic Impact Studies” states, “Caltrans endeavors to maintain a target LOS at the transition between LOS “C” and LOS “D” on state highway facilities, however, Caltrans acknowledges that this may not always be feasible and recommends that the lead agency consult with Caltrans to determine the appropriate target LOS.” In accordance with this recommendation, consultation with Caltrans staff indicated that Caltrans would be willing to consider LOS D at the LOS D/E threshold when improvements become infeasible for State facilities.

The Guide for the Preparation of Traffic Impact Studies also states that where “an existing State highway facility is operating at less than the appropriate target LOS, the existing [measure of effectiveness (MOE)] should be maintained.”

4.5.2.3 Regional Regulations
Fresno County Council of Governments. The Fresno Council of Governments (COG) is a voluntary association of local governments and a regional planning agency comprised of 16 member jurisdictions, including the City of Fresno. The members are represented by a Policy Board consisting of mayors of each incorporated city, and the Chairman of the County Board of Supervisors, or their designated elected official. The Policy Advisory Committee (PAC), composed of the Chief Administrative Officer of each member agency, assists the Board in its decision-making process.

Others involved in the decision process include expert staff from member agencies, citizen and interest groups, and other stakeholders. The Fresno COG’s purpose is to establish a consensus on the needs of the Fresno County area and further action plans for issues related to the Fresno County region. The current regional transportation plan, known as the Fresno County Regional Transportation Plan (RTP) (2042), was adopted in 2018. The RTP addresses GHG emissions reductions and other air emissions related to transportation, with the goal of preparing for future growth in a sustainable way.

The plan specifies how funding will be sourced and financed for the region’s planned transportation investments, ongoing operations, and maintenance. The goals, objectives, and policies of the RTP are established to direct the courses of action that will provide efficient, integrated multi-modal transportation systems to serve the mobility needs of people, including accessible pedestrian and bicycle facilities, and freight, while fostering economic prosperity and development, and minimizing mobile sources of air pollution. They are organized into six broad transportation mode based categories: general transportation; highways, streets, and roads; mass transportation; aviation; active transportation; and rail.

Fresno County Regional Transportation Mitigation Fee. Local Regulations City of Clovis General Plan. The General Plan’s Circulation Element addresses the movement of people and goods throughout the City of Clovis transportation network. The Circulation Element 2 California Department of Transportation (Caltrans). 2002. Guide for the Preparation of Traffic Impact Studies. December.
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) 4.5-7 evaluates transportation circulation needs within the City and recommends circulation improvements that will accommodate the future demand for transportation service generated by the Land Use Element of the General Plan. Table 4.5.A lists the General Plan policies and actions related to transportation applicable to the proposed project.

In addition to the policies listed above the City of Clovis prepared a Supplemental Draft EIR to evaluate updates to the Circulation Element of the 2014 Clovis General Plan. The update to the Circulation Element included the addition of Policies 2.6 through 2.8 and Policies 8.1 through 8.6, as listed above.

The Supplemental EIR also included the following Mitigation Measures that are applicable to residential development.

Mitigation Measure TRANS-3 Provide Bicycle Facilities: The City shall require land uses that generate more than 500 daily trips (which is the threshold that screens small projects from a detailed VMT analysis) to provide bike parking, bike lockers, showers, and personal lockers. This measure is designed to promote commuting by bicycle and support transit first/last mile access. Bicycle facilities shall be required to be constructed in conjunction with each project and funded by the applicant.

Mitigation Measure TRANS-4 Improve Street Connectivity: The City shall require new area plans and new housing projects to provide a well-connected street network, particularly for non-motorized connections. Increased intersection density, alleyways, and mid-block pedestrian crossings may be a proxy for street connectivity and accessibility to connect a variety of land uses. Characteristics of street network connectivity include short block lengths, numerous three and four-way intersections, and minimal dead-ends (cul-de-sacs). Street connectivity helps to facilitate shorter vehicle trips and greater numbers of walk and bike trips and thus a reduction in VMT. 1001
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4.5 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) -8 Table 4.5.A: City of Clovis General Plan Policies Related to Transportation Policy/Action
Item Number Policy/Action Item
Land Use Element
Policy 1.2 Open to changes. Be open to potential changes in land use, circulation, and development standards to reposition areas identified on Figure LU-5 if necessary for revitalization and redevelopment.

Circulation Element
Policy 1.1 Multimodal network. The city shall plan, design, operate, and maintain the transportation network to promote safe and convenient travel for all users: pedestrians, bicyclists, transit riders, freight, and motorists.

Policy 1.2 Transportation decisions. Decisions should balance the comfort, convenience, and safety of pedestrians, bicyclists, and motorists.

Policy 1.3 Age and mobility. The design of roadways shall consider all potential users, including children, seniors, and persons with disabilities.

Policy 1.4 Jobs and housing. Encourage infill development that would provide jobs and services closer to housing, and vice versa, to reduce citywide vehicle miles travelled and effectively utilize the existing transportation infrastructure, as well as promote carpooling whenever possible.

Policy 1.6 Internal circulation. New development shall utilize a grid or modified-grid street pattern. Areas designated for residential and mixed-use village developments should feature short block lengths of 200 to 600 feet.

Policy 1.7 Narrow streets. The City may permit curb-to-curb dimensions that are narrower than current standards on local streets to promote pedestrian and bicycle connectivity and enhance safety.

Policy 1.8 Network completion. New development shall complete the extension of stub streets planned to connect to adjacent streets, where appropriate.

Policy 2.1 Level of service. The following is the City’s level of service (LOS) standards:

A. Achieve LOS D vehicle traffic operations during the a.m. and p.m. peak hours B. Allow exceptions on a case-by-case basis where lower levels of service would result in other public benefits, such as:
i. Preserving agriculture or open space land
ii. Preserving the rural/historic character of a neighborhood iii. Preserving or creating a pedestrian-friendly environment in Old Town or mixed-use village districts iv. Avoiding adverse impacts to pedestrians, cyclists, and mass transit riders v. Where right-of-way constraints would make capacity expansion infeasible Policy 2.2 Multimodal LOS. Monitor the evolution of multimodal level of service (MMLOS) standards. The city may adopt MMLOS standards when appropriate.

Policy 2.3 Fair share costs. New development shall pay its fair share of the cost for circulation improvements in accordance with the city’s traffic fee mitigation program.

Policy 2.4 Right-of-way dedication. The city may require right-of-way dedication essential to the circulation system in conjunction with any development or annexation. The City shall request the County of Fresno to apply the same requirements in the Clovis planning area Policy 2.6 Vehicle Miles Traveled. Development projects shall comply with the City’s VMT Transportation Analysis Guidelines and provide the appropriate VMT mitigation measures as determined through the analysis.

Policy 2.7 VMT Mitigation Fee Program. Evaluate the feasibility of a VMT mitigation fee program and explore opportunities for establishing an in-lieu mitigation fee to offset VMT impacts from development.

Policy 2.8 Partner with local agencies and stakeholders. Partner with other local and regional agencies and stakeholders to explore VMT mitigation measures at the regional scale.

Policy 3.1 Traffic calming. Employ traffic-calming measures in new developments and existing neighborhoods to control traffic speeds and maintain safety.

Policy 3.2 Neighborhood compatibility. Periodically review and update design standards to ensure that new and redesigned streets are compatible with the context of adjacent neighborhoods. 1002
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) 4.5-9 Table 4.5.A: City of Clovis General Plan Policies Related to Transportation Policy/Action
Item Number Policy/Action Item
Policy 3.7 Conflict points. Minimize the number of and enhance safety at vehicular, pedestrian, and bicycle conflict points.

Policy 4.1 Bike and transit backbone. The bicycle and transit system should connect Shaw Avenue, Old Town, the Medical Center/R&T Park, and the three Urban Centers.

Policy 4.2 Priority for new bicycle facilities. Prioritize investments in the backbone system over other bicycle improvements.

Policy 4.4 Bicycles and transit. Coordinate with transit agencies to integrate bicycle access and storage into transit vehicles, bus stops, and activity centers.

Policy 4.7 Bus rapid transit. Plan for bus rapid transit and transit-only lanes on transit priority corridors as future ridership levels increase.

Policy 5.1 Complete street amenities. Upgrade existing streets and design new streets to include complete street amenities, prioritizing improvements to bicycle and pedestrian connectivity or safety, consistent with the Bicycle Transportation Master Plan and other master plans.

Policy 5.2 Development-funded facilities. Require development to fund and construct facilities as shown in the Active Transportation Plan when facilities are in or adjacent to the development.

Policy 6.1 Truck routes. Plan and designate truck routes that minimize truck traffic through or near residential areas.

Policy 8.1 Transportation Demand Management. Develop Transportation Demand Management (TDM) measures that promote, enhance, and make available feasible alternative modes of transportation to residents, employees, and visitors.

Policy 8.2 Transit Routes. As development occurs in the City’s growth areas, continue to evaluate transit routes to determine the most efficient methods of transporting people between residential neighborhoods and goods and services.

Policy 8.3 Bicycle Lanes. Seek input from and/or partner with any local bicycle advocacy groups to improve the design, location, and functionality of bicycle lanes to encourage safe and efficient travel lanes.

Policy 8.4 Connectivity between residential and commercial. Continue to explore opportunities for increased non-vehicular connectivity between new and existing residential development and commercial uses.

Policy 8.5 Community outreach and education. Explore the feasibility of a community outreach and education program that promotes and highlights opportunities for safe and efficient non-vehicular modes of transportation for commuting and recreation.

Policy 8.6 Employer commute programs. Work with businesses to encourage commuter programs and infrastructure that promotes alternative modes of transportation reducing the use of singleoccupancy vehicles, such as additional bicycle racks/lockers, on-site shower facilities, and perks for employees who commute.

Source: City of Clovis General Plan (August 2014).

4.5.3 Impacts and Mitigation Measures
The following section presents a discussion of the impacts related to transportation and traffic that could result from implementation of the proposed project. The section begins with the criteria of significance, which establish the thresholds to determine if an impact is significant. The latter part of this section presents the impacts associated with implementation of the proposed project and the recommended mitigation measures, if required. Cumulative impacts are also addressed.

4.5.3.1 Significance Criteria
Based on CEQA Guidelines Appendix G, the proposed project would have a significant impact related to transportation if it would:
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4.5 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) -10 a. Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities;
b. Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b); c. Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); or d. Result in inadequate emergency access;

4.5.3.2 Project Impacts
The following discussion describes the potential impacts related to transportation and traffic that could result from implementation of the proposed project. a. Would the project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? The proposed project would consist of the annexation of 246 acres by the City of Clovis, and the development of approximately 590 residential lots, averaging approximately 3,329 square feet within the 71.54-acre project site. The proposed lots would be developed into single-family residences over time. Sixty-six outlot spaces that would potentially be developed into private roads, private parking, pedestrian walkways, landscaping, public utilities, and public park uses would also be included within the project site. No development is proposed within the remaining 174.46-acre annexation area surrounding the project site.

Phase 1 of the proposed project would occur in the southern portion of the project site, and would include the development of approximately 136 single-family residential units, the construction of approximately 44 parking spaces, an approximately 8,745-square-foot community pool and recreation area, an approximately 13,930 square-foot community park, approximately 0.51 acre of landscaped areas, and drainage and pedestrian infrastructure improvements along Perrin Avenue, among other improvements.

Phase 2 of the proposed project would occur in the central portion of the project site, and would include the development of approximately 214 single-family residential units, the construction of a 26-foot-wide drainage channel along Perrin Avenue, approximately 0.35 acre of landscaped areas, as well as storm drainage and pedestrian infrastructure improvements along Perrin Avenue and Hammel Avenue, among other improvements.

Phase 3 of the proposed project would occur in the northern portion of the project site, and would include the development of approximately 240 single-family residential units, the construction of approximately 91 parking spaces, an approximately 9,985-square-foot pool and recreation area, approximately 0.65 acre of landscaped areas, and drainage and pedestrian infrastructure improvements along Baron Avenue, among other improvements.

Under full buildout, the proposed project would generate 5,564 daily trips, with 413 trips occurring during the AM peak hour and 555 trips occurring during PM peak hour. 1004
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) 4.5-11 Transit. There are no existing dedicated transit facilities within the project site. As previously described, Clovis Transit Stageline Routes 10 and 80, as well as FAX Route 3, operate within the project’s study area. The proposed project would not introduce elements that would conflict with current and planned transit facilities and routes in the City. As a result, a less-than-significant impact would occur. No mitigation is required.

Bicycles. There are no existing dedicated bicycle facilities within the project site. At present, Class II bicycle lanes exist along Clovis Avenue, Willow Avenue, and some segments of Shepherd Avenue and Fowler Avenue within the study area. However, different bicycle facilities are proposed along other roadways within the study area, such as Sunnyside Avenue, Teague Avenue, Nees Avenue, and Alluvial Avenue. The proposed project would not conflict with the operation of existing bicycle facilities in the project area and would comply with planned development of bicycle facilities consistent with the City’s Active Transportation Plan. The proposed project would construct a total of 1.19 miles of bike lanes along North Baron Avenue. Design of proposed bicycle facilities would comply with City design requirements and with the multi-modal transportation goals of the City’s Active Transportation Plan or the General Plan. As a result, a less-than-significant impact would occur. No mitigation is required.

Pedestrian Facilities. There are no existing dedicated pedestrian facilities within the project site. The project study area currently includes approximately 10 miles of sidewalk. The proposed project would add approximately 1.8 miles of sidewalk/pedestrian access. The proposed project would construct pedestrian sidewalks with development of the proposed extension of North Baron Avenue.

Additionally, the project would develop internal pedestrian facilities within the project site to aid in pedestrian circulation. Proposed pedestrian facilities would be designed per City requirements. The proposed project would accommodate pedestrian circulation and increase connectivity with the City’s existing pedestrian network. Additionally, the project would not conflict with multi-modal transportation goals of the City’s Active Transportation Plan or the General Plan. As a result, a lessthan-significant impact would occur. No mitigation is required.

Roadways. Study intersections and roadway segments analyzed in this report are completely under the jurisdiction of the City of Clovis or lie at the borders of Clovis and Fresno. However, intersections located at freeway on‐ramps and off‐ramps are under the jurisdiction of the California Department of Transportation (Caltrans).

The City of Clovis considers LOS D as the LOS standard for study intersections and roadway segments, except for roadway segments that are adopted in the City’s General Plan EIR to operate at LOS E or F.

At study intersections under the jurisdiction of the City of Clovis, a significant impact would occur at a signalized intersection when LOS falls below the target LOS of D with the addition of project traffic or when a project increases the average delay at an intersection already operating at an unacceptable LOS; at unsignalized intersections, significant impacts would occur when LOS falls below the target LOS (from E or better to F) with the addition of project traffic and triggers the signal warrant criteria or when the project increases delay at an intersection already operating at an unacceptable LOS and triggers the signal warrant criteria. The City of Clovis TIA Guidelines do not define an operational deficiency criterion for roadway segments. However, for purposes of this analysis, at roadway segments under the jurisdiction of the City of Clovis, an operational deficiency has been considered when the project causes an unsatisfactory condition (deterioration from LOS A through D to E or F) or when the project contributes to an existing or forecast deficiency. 1005
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4.5 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) -12 Based on the City of Fresno General Plan Circulation Element, the City uses Traffic Impact Zone (TIZ) boundaries within the City to identify acceptable LOS for each TIZ. All study intersection and roadways segments in the study area within the City of Fresno judication are located within the City of Fresno Traffic Impact Zone (TIZ) III. Per the City of Fresno’s General Plan, all intersections and roadway segments within TIZ III should maintain a peak‐hour LOS standard of D or better. Therefore, as a conservative estimate, LOS D was considered as the minimum level of service criterion for all intersections. As such, an operational deficiency occurs when the project causes an unsatisfactory condition (deterioration from LOS A through D to LOS E or F) for intersections or when the project contributes to an existing or forecasted deficiency. In which case, a proposed project would need to identify improvements to improve the intersection LOS to an acceptable level. City of Fresno’s Traffic Impact Study guidelines do not define an operational deficiency criterion for roadway segments.

Therefore, for purposes of this analysis, at intersections under City of Fresno jurisdiction, an operational deficiency has been considered when the project causes an unsatisfactory condition (deterioration from LOS A through D to E or F) or when the project contributes to an existing or forecast deficiency.

For intersections under the jurisdiction of Caltrans, Caltrans considers an acceptable LOS to be between LOS C and D at all intersections (delay of 45 seconds at signalized intersections and delay of 30 seconds at unsignalized intersections). Caltrans does not have any operational deficiency criteria for study intersections. Therefore, an operational deficiency occurs when the project causes an unsatisfactory condition (deterioration from LOS A through D to E or F) for intersections or when the project contributes to an existing or forecast deficiency. The project needs to identify improvements to improve the intersection LOS to an acceptable level.

The TIA developed existing, near‐term, and cumulative plus project traffic volumes by adding project traffic to the traffic for the corresponding “without project” scenarios. The TIA identified the following roadway segment and study intersection LOS deficiencies under the different scenarios analyzed:
• Existing Levels of Service: Under existing conditions, four study intersections, summarized in Table 8-A of the TIA, operate at an unsatisfactory LOS. Additionally, as summarized in Table 8-B of the TIA, all the study roadway segments currently operate at a satisfactory LOS under existing conditions.
• Existing Plus Project Levels of Service: Under this scenario, four study intersections, summarized in Table 8-A of the TIA, would operate at an unsatisfactory LOS. Based on the operational deficiency criteria stated in this section, the project is forecast to create an operational deficiency at these intersections. It should be noted that all four intersections are currently operating at a deficient LOS, and as such, the project is forecast to add to the existing deficiencies at these intersections. Additionally, as summarized in Table 8-B of the TIA, all the study roadway segments are forecast to operate at a satisfactory LOS under this scenario. • Near‐Term (2026) Plus Project Levels of Service: Under this scenario, nine study intersections, summarized in Table 8-C of the TIA, would operate at an unsatisfactory LOS. Based on the operational deficiency criteria stated in this section, the project is forecast to create an 1006
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) 4.5-13 operational deficiency at these intersections. Additionally, as summarized in Table 8-D of the TIA, three roadway segments are forecast to operate at an unsatisfactory LOS under this scenario. • Cumulative (2046) Without Project Levels of Service: Under this scenario, 13 study intersections, summarized in Table 8-E of the TIA, would operate at an unsatisfactory LOS. Additionally, as summarized in Table 8-F of the TIA, six roadway segments are forecast to operate at an unsatisfactory LOS under this scenario.
• Cumulative (2046) Plus Project Levels of Service: Under this scenario, 13 study intersections, summarized in Table 8-E of the TIA, would operate at an unsatisfactory LOS. Based on the operational deficiency criteria stated in this section, the project is forecast to create an operational deficiency at these intersections. It should be noted that all 13 intersections are forecast to operate at a deficient LOS, and as such, the project is forecast to add to the existing deficiencies at these intersections. Additionally, as summarized in Table 8-F of the TIA, eight roadway segments are forecast to operate at an unsatisfactory LOS under this scenario. Based on the operational deficiency criteria stated in this section, the project is forecast to create an operational deficiency at these roadway segments. It should be noted that out of the eight roadway segments forecast to operate at a deficient LOS, six segments are forecast to operate at a deficient LOS under cumulative (2046) without project conditions. As such, the project is forecast to add to the forecasted deficiencies at these six roadway segments.

Table 4.5.B below summarizes the recommended improvements for study intersections under all scenarios. Tables 9‐B through 9-D of the TIA illustrate the post‐improvement intersection levels of service for the different scenarios. As shown in these tables, implementation of recommended improvements would improve operations at all study intersections to operate at satisfactory LOS levels. As shown in Table 9-H of the TIA, the project would pay into the Clovis Development Impact Fee (Clovis DIF) Program for six improvements and would pay the Regional Transportation Mitigation Fee for one intersection’s improvements (i.e. the Clovis Avenue/Herndon Avenue intersection).

Therefore, the intersections are forecast to operate at a satisfactory LOS with the implementation of the recommended improvements and impacts to the study intersections’ LOS would be less than significant.

Table 4.5.C below summarizes the recommended improvements for roadway segments for all analysis scenarios.
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4.5 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) -14 Table 4.5.B: Recommended Improvements for Intersections Intersection Jurisdiction Existing Plus Project
Improvements
Near-Term (2026)
Plus Project
Improvements
Cumulative (2046)
Plus Project
Improvements
Willow Avenue/International
Avenue
Clovis/Fresno Optimize signal
timing.

Optimize signal
timing.

Optimize signal timing
Willow Avenue/Shepherd
Avenue
Clovis/Fresno Add NBR and EBR
overlap phasing,
optimize signal
timing.

Minnewawa
Avenue/International Avenue
Clovis Convert from TWSC
to AWSC
Convert from TWSC to
AWSC
Install a signal. Add
NBL, SBL.

Minnewawa Avenue/Behymer
Avenue
Clovis Install a signal. Install a signal. Add
NBL, SBL.

Install a signal. Add

NBL, SBL, EBL, WBL,
WBR.

Minnewawa Avenue/Shepherd
Avenue
Clovis Add NBT, SBT, WBT.

Optimize the signal
timing.

Add NBT, SBT, WBT.

Add EBR overlap
phasing. Optimize
the signal timing.

Clovis Avenue/Behymer
Avenue
Clovis Install a signal. Add

NBL, SBL, EBL, EBR,
WBR, WBL.

Clovis Avenue/Baron Avenue Clovis Restripe NB approach
to NBU, NBT, and NBR
(Part of Clovis Avenue
Extension).

Install a signal.

Restripe NB approach
to NBU, NBT, and NBR
(Part of Clovis Avenue
Extension).

Clovis Avenue/Shepherd
Avenue
Clovis Optimize signal
timing.

Optimize signal
timing.

Clovis Avenue/Nees Avenue Clovis Optimize signal
timing.

Optimize signal
timing.

Clovis Avenue/Alluvial Avenue Clovis Optimize signal
timing.

Clovis Avenue/Herndon Avenue Clovis Add EBR and SBR
overlap phasing and
restrict NB and EB
U‐turns. Coordinate
and optimize signal
along with the SR‐168
ramp intersections.

Add EBR and SBR
overlap phasing and
restrict NB and EB
U‐turns. Coordinate
and optimize signal
along with the SR‐168
ramp intersections.

Baron Avenue/Behymer
Avenue
Clovis Install a signal with
E/W split phasing.

Sunnyside Avenue/Shepherd
Avenue
Clovis Install a signal. Add

NBL, SBL, SBR, EBL,

EBR, WBL, WBT,
WBR.

Install a signal. Add
NBL, SBL, SBR with
overlap phasing, EBL,

EBT, EBR, WBL, WBT,
WBR with overlap
phasing.

Fowler Avenue/Shepherd
Avenue
Clovis Optimize signal
timing.

Optimize signal
timing.

Optimize signal
timing.
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) 4.5-15 Table 4.5.B: Recommended Improvements for Intersections Intersection Jurisdiction Existing Plus Project
Improvements
Near-Term (2026)
Plus Project
Improvements
Cumulative (2046)
Plus Project
Improvements
Source: Transportation Impact Analysis Tract Map 6343 Project (LSA 2023b).

NB = Northbound, SB = Southbound, EB = Eastbound, WB = Westbound L = Left, T = Through, R = Right
AWSC= All‐Way Stop Control; TWSC = Two‐Way Stop Control Table 4.5.C: Recommended Improvements for Roadway Segments Roadway Segment Jurisdiction Near-Term (2026) Plus
Project Improvements
Cumulative (2046) Plus
Project Improvements
Segments on Behymer Avenue
between Minnewawa Avenue and
Clovis Avenue
Clovis Convert to 2‐Lane TWLTL
Collector
between Clovis Avenue and Baron
Avenue
Clovis Convert to 2‐Lane TWLTL
Collector
Segments on Shepherd Avenue
between Willow Avenue and
Minnewawa Avenue
Clovis Convert to 4‐Lane Raised
Median Arterial
Convert to 4‐Lane Raised
Median Arterial
between Clovis Avenue and Sunnyside
Avenue
Clovis Convert to 4‐Lane Raised
Median Expressway
Convert to 4‐Lane Raised
Median Expressway
between Sunnyside Avenue and Fowler
Avenue
Clovis Convert to 4‐Lane Raised
Median Expressway
Segments on Minnewawa Avenue
between International Avenue and
Behymer Avenue
Clovis Convert to 4‐Lane Undivided
Arterial
between Behymer Avenue and
Shepherd Avenue
Clovis Convert to 4‐Lane Undivided
Arterial
Convert to 4‐Lane Undivided
Arterial
Segments on Baron Avenue
between Perrin Avenue and Clovis
Avenue
Clovis Convert to 2‐Lane Divided
Collector
Source: Transportation Impact Analysis Tract Map 6343 Project (LSA 2023b).

TWLTL= two‐way‐left‐turn lane
All study roadway segments listed in Table 4.5.C would be able to implement improvements via payment to the Clovis DIF Program to improve operations and operate at satisfactory LOS levels.

However, in addition to the local roadways’ segments listed above in Table 4.5.C, the diverge segment at the SR‐168 westbound Herndon Avenue Off‐Ramp, under Caltrans jurisdiction, is forecast to operate at an unsatisfactory condition (LOS F) during PM peak hours under existing, near‐term (2026) and cumulative (2046) conditions.

As such, improvements would be required at this off‐ramp location to improve traffic operations on the freeway mainline. The project would be subject to payment of to the RTMF Program for its fair share contribution to regional improvements. As discussed above in Section 4.5.2.3, the RTMF is 1009
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4.5 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) -16 intended to ensure that future development contribute its fair share towards the costs of infrastructure to mitigate the cumulative indirect regional transportation impacts of new growth in a manner consistent with the provisions of the Mitigation Fee Act.

However, since the project has no direct control of implementing improvements at a Caltrans facility, and implementation of recommended improvements would be subject to Caltrans implementation schedule, which is unknown at this time, the deficiency at this location would remain significant and unavoidable.

Impact TRA-1: The project would conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities.

Level of Significance Without Mitigation: Potentially Significant Impact.

Mitigation Measures: No feasible mitigation measures are available.

Level of Significance With Mitigation: Significant and unavoidable. The TIA prepared for the proposed project identifies potential conflicts to the City’s established LOS standards for roadways in Clovis.

Where feasible, the proposed project would contribute a fair share allotment to improve deficient roadways to meet roadway standards for Clovis, Fresno, and Caltrans. However, one diverge segment under Caltrans’ jurisdiction is unlikely to be improved prior to implementation of the proposed project, due to the project having no direct control of implementing improvements at a Caltrans facility and Caltrans’ timing schedule for implementation of recommended improvements being unknown at this time. As a result, implementation of the proposed project would conflict with adopted policies that cannot be addressed, and a significant and unavoidable impact would occur. b. Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
On December 28, 2018, the California Office of Administrative Law cleared the revised CEQA Guidelines for use. Among the changes to the guidelines was removal of vehicle delay and LOS from consideration under CEQA. With the adopted guidelines, transportation impacts are to be evaluated based on a project’s effect on VMT, not LOS.

The City’s TIA Guidelines includes screening criteria, VMT analysis methodology, VMT impact thresholds, and VMT mitigation measures. The TIA Guidelines provide multiple project types and thresholds for land use projects. The project was compared with the screening criteria established in the “Project Screening” section of the TIA Guidelines to check if the project can be screened out of detailed VMT analysis. The following is a brief description of the project in relation with the project screening criteria:
• Small Project: The TIA Guidelines states that projects generating less than 500 daily trips could be screened out of a detailed VMT analysis. As previously discussed, the project is estimated to generate 5,564 daily trips. Therefore, the project does not satisfy this screening criteria. 1010
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) 4.5-17 • Provision of Affordable Housing: The project proposes to develop market‐rate, single‐family dwelling units. Therefore, this screening criteria does not apply to the project. • Local‐Serving Retail: The project consists of residential land use only; therefore, this screening criteria does not apply to the project.
• Project Located in a High‐Quality Transit Area (HQTA): The project is not located within an HQTA; therefore, this screening criteria does not apply to the project. • Project Located in Low VMT Area: The project is not located in a low VMT area; therefore, this criterion does not apply to the project.

As shown above, the project could not be screened out from detailed VMT analysis. For projects that are not screened out, a quantitative analysis of VMT impacts must be prepared and compared against the adopted VMT thresholds of significance.

In addition, as described above in Section 4.5.2.4, the City updated the City’s General Plan Circulation Element to address VMT by adding new policies. A Supplemental EIR was completed to evaluate the changes to the Circulation Element, and Mitigation Measure TRANS-3 and Mitigation Measure TRANS4, as included above in Section 4.5.2.4, would apply to proposed residential projects.

Thresholds of Significance. The proposed project consists of residential land use. The TIA Guidelines established VMT per capita as the appropriate metric to evaluate residential land use projects while defining Fresno County as the “region” for determining VMT thresholds. The project would have a significant VMT impact if the baseline project VMT per capita is greater than 87 percent of the baseline Fresno County VMT per capita. Based on the TIA Guidelines, baseline Fresno County VMT per capita is 16.1 and the corresponding threshold is 14.1 (which is 87 percent of 16.1). Therefore, the project would have a significant VMT impact if the project VMT per capita is greater than 14.1.

VMT Analysis. As recommended in the TIA Guidelines, the VMT analysis for the project was conducted using the Fresno COG Activity Based Model (ABM). The model database was updated with the project land use to calculate project VMT. The first step in preparation of this analysis was to update the traffic analysis zones (TAZs) in the model that include the project area. The Fresno COG ABM includes the ability to add or split zones. In order to isolate the project VMT, a new zone was created in the model. The project households were included in the newly created zone for modeling purposes. No project‐specific network modifications were required for the model run. A model run was conducted for the existing/base scenario with updated model inputs. The outputs from this updated model run were used to calculate the project VMT per capita. Based on the Fresno COG ABM model output, the project’s VMT was calculated to be 17.8 VMT per capita, 26.4 percent higher than the City’s VMT per capita threshold. Therefore, based on the TIA Guidelines, the project would have a significant VMT impact.

When a lead agency identifies a significant CEQA impact, the agency must identify feasible mitigation measures in order to avoid or substantially reduce that impact. VMT impacts can be mitigated through more behavioral changes. Enforcement of mitigation measures will be subject to the mitigation monitoring requirements under CEQA, as well as the regular police powers of the agency. These 1011
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4.5 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) -18 measures can also be incorporated as a part of plans, policies, regulations, or project designs. Project design features that encourage mode shift from automobiles to transit or nonmotorized modes can therefore help reduce project VMT as well. Typically, VMT reduction and benefits from these project design features are not accounted in the project VMT calculations conducted using the regional travel demand model. Therefore, VMT reduction credit can be accounted for these design features similar to VMT mitigation measures to help reduce the project’s VMT impact. Evaluation of VMT reductions should be evaluated using state‐of‐the‐practice methodologies recognizing that many of the VMT mitigation strategies/project design features are dependent on resident performance over time. The following is a detailed description of both and the corresponding potential reduction that could be achieved with implementation of these measures.

Project Design Features. As per information provided by the Project Applicant, the project intends to implement project design features that would help reduce project VMT. VMT reduction that can be achieved by the project’s design features has been estimated using the most recent California Air Pollution Control Officers Association’s (CAPCOA) “Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity – Designed for Local Governments, Communities, and Project Developers” (Handbook) dated December 20213 . The
purpose of the Handbook is to provide accurate, reliable, and standardized emission reduction quantification methods for project analysis and long-term planning. The Handbook includes a wide range of measures that are frequently used to reduce greenhouse gas emissions and provide other benefits, like improved air quality, energy and fuel savings, and water conservation. As transportationrelated emissions can be reduced by reducing VMT, the Handbook contains measures aimed to reduce VMT and encourage mode shifts from single-occupancy vehicles to shared (e.g., transit) or active modes of transportation (e.g., bicycle). CAPCOA transportation measures applicable to project VMT reduction are described below.
• Pedestrian Infrastructure: The proposed project would provide pedestrian improvements/ sidewalks both internal to the project site and along the project frontage. Providing sidewalk/ pedestrian improvements encourage people to walk instead of drive and thus reduces VMT.

CAPCOA transportation measure T‐18: “Provide Pedestrian Network Improvement”, was used to estimate the VMT reduction due to project related enhancements in pedestrian access and connectivity. The CAPCOA methodology requires existing sidewalk length in the project study area in addition to the length of sidewalk being provided by the project. In order to estimate the existing sidewalk length, a survey was conducted along the proposed project frontage. Based on the survey, the project study area includes approximately 10 miles of sidewalk. The project proposes to add approximately another 1.8 miles of sidewalk/pedestrian access. Therefore, this mitigation measure may reduce the project’s VMT by approximately 0.87 percent. However, the proposed project consists of only one land use type (residential), and the project site is currently located in an area surrounded mainly by agricultural and residential uses. The project site is not located within a walkable distance to mixed uses. As such, it is unlikely that residents of the project site would reduce their vehicle use due to implementation of pedestrian improvements, as 3 California Air Pollution Control Officers Association’s (CAPCOA). 2021. Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity – Designed for Local Governments, Communities, and Project Developers. December. 1012
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) 4.5-19 residents would still need to travel a significant distance from the project site to access services.

This feature is not expected to significantly reduce project VMT impacts. • Improve Street Connectivity: The project proposes to provide an internal circulation network.

Projects with higher density of intersections would help increase street connectivity, reduce trip lengths and promote the use of alternative transportation modes of travel. CAPCOA handbook identifies measure T-17: Improve Street Connectivity to evaluate project street network. The measure is recommended as an appropriate design feature for plans within urban or suburban areas. Measure T-17 estimates that an increased density of vehicular intersections improves street connectivity and helps in reduction in GHG emissions and corresponding VMT. As included in the CAPCOA handbook, this measure could be applied to a project for:
‘Projects that increase intersection density would be building a new street network in a subdivision or retrofitting an existing street network to improve connectivity (e.g., converting cul-de-sacs or dead-end streets to grid streets).’ The measure establishes the following numerical formula of VMT reduction due to increased intersection density and improved street connectivity:

𝐴𝐴 = 𝐵𝐵−𝐶𝐶
𝐶𝐶 ∗ 𝐷𝐷
Where,
A = Percent Reduction in GHG/VMT emission from vehicle Travel B = Intersection Density in project site with measure
C = Average Intersection Density for Typical developments (36) D = Elasticity of VMT with respect to intersection density (-0.14) CAPCOA suggests application of different VMT mitigation measures at different scales— project/ site scale or community/plan scale. Based on the CAPCOA Handbook, this mitigation measure is applicable at a plan/community scale, with appropriate limitations as described in the VMT Analysis section of the TIA. Due to these improved vehicular network connection and project design features, the project would achieve 3.39 percent reduction in VMT compared to the project VMT that was estimated from the regional travel demand model.

However, the project is a gated community which has specified entry/exit ways that reduces accessibility to all project related traffic. While the increased intersection density would facilitate a greater number ofshort trips, the project consists of only a single land use type (residential) and the amount of internal capture (trips that can be fulfilled within the project, with both origin and destinations within the project site) would be minimal. Residents of the project site would still need to travel off site to access a variety of services. As such, increased street connectivity within the project site is not expected to significantly reduce project VMT impacts. 1013
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4.5 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) -20 • Bicycle Infrastructure/Improvements: The project proposes to construct a total of 1.19 miles of bike lanes along the project frontage. Similar to pedestrian facilities, these bicycle design features included in the project can encourage an increase in active transportation mode share in the area.

The CAPCOA manual was utilized to estimate the reduction of project VMT due to proposed bicycle improvements. Specifically, CAPCOA transportation measure T‐19A: “Construct or Improve Bike Facility” was deemed applicable to estimate the VMT reduction due to project bicycle features. According to the measure, providing bicycle infrastructure helps to improve biking conditions within an area. This encourages a mode shift on the roadway parallel to the bicycle facility from vehicles to bicycles, displacing VMT and thus reducing GHG emissions. Based on CAPCOA estimates, the project bicycle design features have a potential to reduce up to

0.01 percent of the project VMT.
• Provide Electric Vehicle (EV) Parking and EV Charging Infrastructure: Accessible EV parking and provision of charging for electric vehicles in the residential units would encourage the use of EVs.

The latest California Green Building Standards (CALGreen), California Building Code, requires provision of infrastructure to accommodate electric vehicle chargers for new single family and attached dwelling units/townhouses. For new construction projects such as apartments, condominiums, hotels, and motels, CALGreen code requires the project to provide EV charging stations as a percentage of the total project parking. While it is understood that provision of electric charging infrastructure/stations might not reduce VMT given that the effectiveness of this measure for VMT reduction is subject to the number of project residents that would make use of electric vehicles instead of gasoline-powered vehicles (which is a matter of personal choice), it will reduce GHG, which can be considered equivalent to reduction in VMT. According to CAPCOA, provision of additional electric charging stations, in addition to CALGreen requirements, can be considered as a GHG/VMT mitigation. Provision of EV charging infrastructure has the potential to achieve a maximum VMT reduction of up to 11.9 percent. Currently, pursuant to CALGreen requirements and Mitigation Measure GHG-1, the project would provide electric vehicle charging capabilities in proposed residential units as part of the final project designs. However, the project would not provide additional EV charging points and stations. As such, while this project design feature has the potential to reduce GHG emissions, no direct VMT reduction has been accounted for this project design feature.

Conclusion.¶ In conclusion, the project would include design features that aim to promote overall mobility with the goal of reducing VMT and reducing greenhouse gas emissions. The project is consistent with Mitigation Measure TRANS-3 and Mitigation Measure TRANS-4 of the Subsequent EIR for the 2014 Clovis General Plan Circulation Element Update. Mitigation Measure TRANS-3 requires bicycle facilities for land uses that generate more than 500 daily trips, and Mitigation Measure TRANS4 requires improved street connectivity to facilitate shorter vehicle trips and greater numbers of walk and bike trips. Implementation of the above project design features may possibly reduce the project’s VMT by approximately up to 4.24 percent. However, due to the nature of the project and its location, the project design features identified in this section could help offset some of the VMT impacts of the project but will not reduce the impact to a less than significant level. Therefore, the project will have a significant and unavoidable impact.
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) 4.5-21 Impact TRA-2: The proposed project would conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b).

Level of Significance Without Mitigation: Potentially Significant Impact.

Mitigation Measures: No feasible mitigation measures are available.

Level of Significance With Mitigation: Significant and unavoidable. The proposed project would include project design features that could reduce the project’s VMT by up to 4.24 percent. However, this potential reduction would not help the project reach the required threshold of 14.1 VMT per capita. As a result, implementation of the proposed project would conflict with CEQA Guidelines section 15064.3, subdivision (b), and a significant and unavoidable impact would occur. c. 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)? The proposed project would consist of the annexation of 246 acres by the City of Clovis, and the development of 590 residential lots, averaging 3,329 square feet within the 71.54-acre project site.

The project site and annexation area are surrounded by agricultural and single-family residential uses to the south, rural residential and agricultural uses to the east, agricultural and commercial uses to the west, and agricultural and rural residential uses to the north. Implementation of the proposed project would increase the amount of vehicle traffic, which would require the improvement and expansion of the roadway network in the project area. The proposed project would include the extension of existing and construction of new roadways, bikeways, and sidewalks that would be constructed pursuant to City standards and would increase vehicle and pedestrian access and safety in the study area. New transportation facilities would be designed according to applicable federal, State, and local design standards, which would minimize traffic hazards. The proposed project would also include the installation of traffic signals where recommended as study intersection improvements, as detailed in Table 4.5.B above, to meet the City’s LOS standards. These improvements would improve safety and reduce traffic conflicts at study intersections. Traffic signals would be installed at the direction of the City Engineer upon meeting the necessary traffic warrants.

Sight Distance Analysis. Vehicular access to the project site would be provided by six intersections:
three on Baron Avenue, two on Hammel Avenue, and one on Perrin Avenue. All intersections would operate as full‐access intersections. A sight distance analysis was conducted at the project intersections along Baron Avenue and future intersection of Baron Avenue/Perrin Road. For purposes of this analysis, only the stopping sight distance and corner sight distance were evaluated.

According to the Caltrans Highway Design Manual4 (HDM) (dated July 2020), the stopping sight distance is the minimum sight distance along a roadway required to allow a driver to decrease their speed from the design speed to a complete stop. The corner sight distance is the minimum sight distance in which a driver at a stop‐controlled approach can see oncoming traffic on the major street to safely maneuver onto the roadway. For purposes of this analysis, the posted speed limit of 35 mph 4 Caltrans. 2020. Highway Design Manual – Seventh Edition. July 1. Website: https://dot.ca.gov/programs/ design/manual-highway-design-manual-hdm (February 2023). 1015
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4.5 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) -22 has been considered as the design speed for Baron Avenue. As stated in Table 201.1 of the HDM, the minimum stopping sight distance for a design speed of 35 mph is 250 feet. Therefore, the minimum stopping sight distance for all project intersections was determined to be 250 feet.

As for corner sight distance, Section 405.1 of the HDM states that corner sight distance requirements are not applicable for urban intersections unless signalized. At signalized intersections, the minimum corner sight distance was based on design speed, time gap, and type of vehicle for the minor road vehicle to enter the major road. Based on these design speeds and the requirements established in the HDM, it was determined that minimum corner sight distances of the project intersections and future intersection are as follows:
• Baron Avenue/Project Intersection 4: 390 feet
• Baron Avenue/Project Intersection 5: 390 feet
• Baron Avenue/Project Intersection 6: 390 Feet
• Baron Avenue/Perrin Road: 390 feet
Based on the sight distance analysis in the TIA, the proposed project intersections achieve adequate sight distances and have clear sight triangles for drivers.

Safe Routes to School Analysis. The project site would be under the jurisdiction of the Clovis Unified School District (CUSD). The schools in the vicinity of the project site currently include Riverview Elementary School, which is located approximately 2 miles from the project site, and Granite Ridge Intermediate School and Clovis North High School, both of which are located approximately 2.5 miles from the site. It should be noted that the project is within the vicinity of the proposed Heritage Grove Specific Plan project. Based on the project description of this project, an elementary school is being proposed within Planning Area 9 of the Specific Plan. Though the completion date for this elementary school is still undetermined, elementary school students from the proposed project are anticipated to attend this school once completed.

The proposed project would result in the construction of sidewalks along the project frontage, as well as contribute to the Clovis DIF and the RTMF programs as applicable for improvements at roadway segments and intersections within the project study area, which would include the addition of sidewalks and/or bike lanes along segments and installation of signals at intersections with marked crosswalks and other safety improvements. As such, the project would contribute safe walking and biking routes from the project to nearby schools.

In addition, the proposed project would not include any sharp curves or other roadway design elements that would create dangerous conditions. The project design features would be required to comply with standards set by the City’s General Plan and City Engineer. The proposed project would also be required to submit plans to the Clovis Fire Department (CFD) for review and approval prior to the issuance of building permits to ensure there are no substantial hazards associated with the project design. Therefore, the proposed project would not increase hazards due to design features or incompatible uses, and a less than significant impact would occur.

Impact TRA-3: The project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment). 1016
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) 4.5-23 Level of Significance Without Mitigation: Less Than Significant Impact. d. Would the project result in inadequate emergency access? Vehicular access to the project site would be provided by six intersections: three on Baron Avenue, two on Hammel Avenue, and one on Perrin Avenue. All intersections would operate as full‐access driveways. Additionally, the project would also include an emergency access intersection on Perrin Avenue that would provide exclusive access for emergency response vehicles to the project site. An enhanced roadway network that accommodates forecasted travel demand, through improvements identified in the TIA, would also provide adequate emergency access. Additionally, the proposed project’s site plan would be subject to review and approval by the CFD and the City’s Engineering Division to ensure the project includes adequate emergency access.

As a result, implementation of the proposed project would result in a less‐than‐significant impact related to emergency access. No mitigation is required.

Impact TRA-4: The project would not result in inadequate emergency access.

Level of Significance Without Mitigation: Less Than Significant Impact.

4.5.3.3 Cumulative Impacts
A proposed project would have a significant effect on the environment if it—in combination with other projects—would contribute to a significant cumulative impact related to transportation. The cumulative impact analysis for transportation considers the larger context of future development of the City of Clovis as envisioned by the General Plan and relies upon the projections of the General Plan and General Plan EIR. Cumulative impacts on transportation would be those impacts that result from continued buildout of the General Plan.

The proposed project would be consistent with applicable regulations, including the City’s General Plan policies and ATP guidelines as it relates to transit, bicycles, and pedestrian facilities, as described in Section 4.5.2. The proposed project would not conflict with existing and planned transit facilities in the City, and would construct bicycles, and pedestrian facilities that would increase the connectivity of the City and further implement the City’s General Plan policies and meet ATP multi-modal transportation goals.

The proposed project would not include the construction of hazardous or incompatible design features in the project site. The proposed project’s plans would be subject to review and approval by the CFD and the City’s Engineering Division to ensure the project includes adequate emergency access.

The TIA identifies roadways that would conflict with LOS standards of the Cities of Clovis and Fresno, and Caltrans with implementation of the proposed project. In most cases, in combination with cumulative conditions, the roadways and segments would be improved to meet the standards of the Clovis, Fresno, and Caltrans. However, one diverge segment in Caltrans’ jurisdiction is unlikely to be improved to meet Caltrans’ standards prior to implementation of the proposed project due to the project having no direct control of implementing improvements at a Caltrans facility and Caltrans’ timing schedule for implementation of recommended improvements being unknown at this time. As 1017
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4.5 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\4.5-Transportation.docx (01/11/24) -24 discussed above, implementation of the proposed project would result in conflicts with policies related to LOS standards that would not be able to be improved due to existing constraints. As a result, a significant and unavoidable cumulative impact would occur.

The proposed project’s VMT was calculated to be 17.8 VMT per capita, 26.4 percent higher than the City’s VMT per capita threshold of 14.1. Although the project includes design features that could reduce project’s VMT by up to 4.24 percent, this potential reduction would not help the project meet the required threshold of 14.1 VMT per capita. As a result, a significant and unavoidable VMT impact would occur.

Impact TRA-5: The proposed project, in combination with past, present, and reasonably foreseeable projects, would contribute to a significant cumulative impact with respect to transportation.

Level of Significance Without Mitigation: Potentially Significant Impact.

Mitigation Measures: No feasible mitigation measures are available.

Level of Significance With Mitigation: Significant and Unavoidable Impact. 1018
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5.0 ALTERNATIVES
In accordance with the California Environmental Quality Act (CEQA) and the State CEQA Guidelines (Section 15126.6), an Environmental Impact Report (EIR) must describe a range of reasonable alternatives to the project, or to the location of the project, that would “feasibly attain most of the project's basic objectives, while avoiding or substantially lessening any of the significantly adverse environmental effects of the project.” An EIR does not need to consider every conceivable alternative to a project; rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation. The range of alternatives required in an EIR is governed by a “rule of reason.” The proposed project would consist of the annexation of 246 acres by the City of Clovis, and the development of 590 residential lots, averaging 3,329 square feet, into single family residences in the

71.54-acre project site. The proposed project would be developed in three phases over a period of 33 months and would introduce a maximum of 590 new residential units in the City of Clovis. The proposed project has been described and analyzed in Chapter 4.0 with an emphasis on determining and evaluating potential significant impacts resulting from the project and identifying mitigation measures to avoid or reduce these impacts to a less-than-significant level. The following identifies and discusses three feasible alternatives to the proposed project, compares the impacts of each alternative to the impacts of the project, and determines whether the alternatives meet the basic project objectives and avoid or reduce project-related significant impacts.

5.1 SELECTION OF ALTERNATIVES
Section 21100 of the Public Resources Code and Section 15126.6 of the State CEQA Guidelines require an EIR to identify and discuss a No Project Alternative and a reasonable range of alternatives to the proposed project that would feasibly attain most of the basic objectives of the proposed project and that would avoid or substantially lessen any of the significant environmental impacts.

When selecting a set of alternatives to analyze, Section 15126.6(f) of the State CEQA Guidelines also discusses the consideration of alternative locations and determining whether any of the significant effects of a proposed project would be avoided or substantially lessened by putting the project in another location.

Based on the criteria listed above, three alternatives have been selected to avoid or substantially lessen the significant impacts of the proposed project. Therefore, the alternatives considered in this Draft EIR include the following:
• No Project Alternative: Under the No Project Alternative, the project site would not be developed, and existing land uses would remain. No modifications to existing site access or infrastructure would occur, and the annexation of 246 acres to the City of Clovis would not occur.
• Reduced Project Alternative: Under the Reduced Project Alternative, the proposed project would reduce the proposed density of 8.25 dwelling units per acre for (DU/acre) for the proposed project to 4.12 DU/acre, for a total of 295 residential units. Proposed site access and 1019
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5 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\5.0-Alternatives.docx (01/11/24) -2 infrastructure improvements would remain the same as those identified for the proposed project. Annexation 246 acres, as proposed by the project would occur. • Increased Phase Density Alternative: Under the Increased Phase Density Alternative 590 residential units would be constructed within the 71.54-acre project site, but the residential units would be constructed on approximately 24 acres on northern portion of the project site and 24 acres on the southern portion of the project site to reduce the overall construction period. The remaining approximately 23 acres of the project would be developed as public open space. Overall density of the project site would remain the same as the proposed project (8.25 DU/acre), but each 24-acre development area would have density of 12.3 DU/acre. Proposed site access and infrastructure improvements would remain the same as those identified for the proposed project. Annexation 246 acres, as proposed by the project would occur.

5.2 PROPOSED PROJECT

5.2.1 Project Description
As described earlier in Chapter 3.0, Project Description, the proposed project would consist of the annexation of 246 acres by the City of Clovis, and the development of approximately 590 residential lots, averaging approximately 3,329 square feet within the 71.54-acre project site. The proposed lots would be developed into single-family residences over time. Sixty-six outlot spaces that would potentially be developed into private roads, private parking, pedestrian walkways, landscaping, public utilities, and public park uses would also be included within the project site.

No development is proposed within the remaining 174.46-acre annexation area surrounding the project site. The proposed project would include annexation of the 246-acre area from Fresno County jurisdiction to the City of Clovis. Any future development occurring within the annexation area would require a separate project-specific analysis. The proposed project would be developed in three phases, as described below.

5.2.1.1 Phase 1
Phase 1 would include the development of approximately 136 single-family residential units with an average size of approximately 1,514 square feet per unit. Phase 1 would be located on the southern portion of the project site and would be accessed through one ingress and egress street on Perrin Avenue. Phase 1 would include the construction of approximately 44 parking spaces, an approximately 8,745 square-foot community pool and recreation area, an approximately 13,930- square-foot community park, approximately 0.51 acre of landscaped areas, and drainage and pedestrian infrastructure improvements along Perrin Avenue. The southern extension of North Baron Avenue from East Behymer Avenue and the extension of Perrin and Hammel Avenue within the project site would be constructed during Phase 1.

5.2.1.2 Phase 2
Phase 2 would include the development of approximately 214 single-family residential units with an average size of approximately 2,168 square feet per unit. Phase 2 would be located on the central portion of the project site and would be accessed through one gated ingress and egress street along the future southern extension of Baron Avenue, and one gated ingress and egress street along 1020
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\5.0-Alternatives.docx (01/11/24) 5-3 Hammel Avenue. Phase 2 would include the construction of an approximately 26-foot-wide drainage channel along Perrin Avenue, approximately 0.35 acre of landscaped areas, as well as storm drainage and pedestrian infrastructure improvements along Perrin Avenue and Hammel Avenue.

5.2.1.3 Phase 3
Phase 3 of the proposed project would include the development of approximately 240 single-family residential units with an average size of approximately 1,514 square feet per unit. Phase 3 would be located on the northern portion of the project site and would be accessed through two gated ingress and egress streets located along the future southern extension of Baron Avenue, and through one gated egress street access located along the future northern extension of Hammel Avenue. Phase 3 would include the construction of approximately 91 parking spaces, an approximately 9,985-square-foot pool and recreation area, approximately 0.65 acre of landscaped areas, and drainage and pedestrian infrastructure improvements along Baron Avenue.

In addition, development of the project site would include infrastructure improvements for water services along the East Behymer Avenue frontage and Baron Avenue frontage, as well as stormwater management infrastructure improvements along the Perrin Avenue frontage. The proposed project would also construct a two-lane, approximately 49-foot-wide and 2,650-foot-long extension of Baron Avenue south of East Behymer Avenue.

5.2.2 Project Objectives
Each alternative is analyzed to determine whether it achieves the basic objectives of the proposed project. As stated in Chapter 3.0, Project Description, the City has established the following intended specific objectives for the proposed project that would serve to aid decision-makers in their review of the proposed project and its associated environmental impacts:
• Provide residential housing opportunities that are visually attractive and accommodate the future housing demand in Clovis.
• Establish a mixture of housing types, sizes and densities that collectively provide for local and regional housing demand.
• Implement the City’s General Plan Land Use Element goal to facilitate annexation of large areas of land.
• Provide infrastructure that meets City Standards and is integrated with existing and planned facilities and connections.
• Develop a project that meets City Standards by implementing a logical phasing plan for development of public infrastructure improvements.

5.2.3 Significant Unavoidable Impacts of the Proposed Project As described in Chapter 4.0, Evaluation of Environmental Impacts, impacts in the following areas would be potentially significant without the implementation of mitigation measures but would be 1021
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5 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\5.0-Alternatives.docx (01/11/24) -4 reduced to a less than significant level if the mitigation measures recommended in this report are implemented: Section 4.1, Agricultural Resources; Section 4.2, Air Quality; Section 4.3 Greenhouse Gas Emissions; and Section 4.4 Noise. Impacts in the following area would be significant unavoidable impacts: Section 4.5, Transportation.

For the purpose of this analysis, it is assumed that all of the alternatives would comply with applicable federal, State, and local regulations, policies, and ordinances. It is also assumed that all mitigation measures required for implementation of the proposed project would apply to the project alternatives and similar corresponding reductions in impacts would be achieved through such mitigation. Therefore, the following discussion focuses on the ability of the alternatives to reduce significant unavoidable project impacts.

5.3 ALTERNATIVES CONSIDERED BUT NOT ANALYZED IN DETAIL
State CEQA Guidelines Section 15126.6(c) provides that an EIR “should also identify any alternatives that were considered by the lead agency but rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency’s determination. Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts.”
The following provides a description of potential alternatives that were identified and considered by the City, and the reasons why they were ultimately not selected for further evaluation in this EIR. In dismissing these alternatives from detailed evaluation in this EIR, primary considerations were whether the alternatives would meet most of the project objectives, or whether the alternatives were feasible, or whether they would reduce the significant impacts of the proposed project. The following alternatives was considered but was dismissed from further consideration as explained below.
• Off-Site Alternative. This alternative was not considered feasible, because there were no other feasible locations for the proposed project to be located due to ownership. Although relocation of the proposed project could serve to fulfill the project objectives, relocation of the project site to other areas near the City of Clovis would have increased the possibility of impacting specialstatus animal species. • Increased Density Alternative. This alternative was not considered feasible, because increasing the density and the overall number of residential units within the project site would result in design limitations and potential on-site safety impacts due to an increased population, relative to the proposed project. Although increasing the density of proposed project could serve to fulfill the project objectives, the potential on-site and off-site operational impacts are anticipated to increase significantly with increased density.

5.4 ALTERNATIVE 1: NO PROJECT ALTERNATIVE
The following provides a description of the No Project Alternative and its anticipated environmental impacts. The emphasis of the analysis is on comparing the anticipated environmental impacts of the 1022
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\5.0-Alternatives.docx (01/11/24) 5-5 No Project Alternative to the environmental impacts associated with the proposed project. The discussion includes a determination of whether or not the No Project Alternative would reduce, eliminate, or create new significant environmental impacts and would or would not meet the objectives of the proposed project.

5.4.1 No Project Alternative Description
The No Project Alternative assumes that the proposed project would not be developed and that the project site would generally remain in its current condition. The project site would continue to be agriculture and rural residential uses. No modifications to existing site access or infrastructure would occur. No annexation to the City of Clovis would take place.

5.4.2 Analysis of the No Project Alternative
The potential impacts associated with the No Project Alternative are described below.

5.4.2.1 Aesthetics
Under the No Project Alternative, no construction activities would occur, and the project site would remain undeveloped. The proposed project would result in less-than-significant impacts related to change in views of an around the project, character of the site, and lighting. As a result, with implementation of the No Project Alternative, no impacts to aesthetics would occur and, therefore, this alternative would result in fewer impacts when compared to the proposed project.

5.4.2.2 Agriculture and Forestry Resources
Under the No Project Alternative, no construction activities would take place, and the project site would remain undeveloped. The project site is currently under a Williamson Act Contract, and under this alternative, no cancellation of a Williamson Act contract would be needed. Implementation of Mitigation Measure AG-2 and Regulatory Compliance Measure AG-3 would not be required. No forestry resources are located within the project site or annexation area. With implementation of the No Project Alternative, impacts to agriculture and forestry would not occur and, therefore, this alternative would result in fewer impacts when compared to the proposed project.

5.4.2.3 Air Quality
Under the No Project Alternative, no construction activities would occur, and the site would remain undeveloped. Therefore, the proposed project’s construction and operational less than significant criteria pollutant impacts would be avoided under this alternative; therefore, implementation of Regulatory Compliance Measure AIR-2 would not be required. With implementation of the No Project Alternative, impacts to air quality would not occur and, therefore, this alternative would result in fewer impacts when compared to the proposed project.

5.4.2.4 Biological Resources
Under the No Project Alternative, no construction or grading activities would occur on the project site. As a result, the proposed project’s potentially significant impacts to special-status species, federally protected wetlands and nesting birds would be avoided under this alternative and implementation of Mitigation Measures BIO-1 through BIO-4 and Regulatory Compliance Measure 1023
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5 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\5.0-Alternatives.docx (01/11/24) -6 BIO-1 would not be required. In addition, under the No Project Alternative, no construction activities would occur that would impact a sensitive natural community, interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors. With implementation of the No Project Alternative, impacts to biological resources would not occur and, therefore, this alternative would result in fewer impacts when compared to the proposed project.

5.4.2.5 Cultural Resources
No construction or grading activities would occur on the project site under the No Project Alternative. Therefore, the proposed project’s potential impacts that would result from construction at the project site, including potentially significant impacts related to disturbance of previously unknown archaeological resources and human remains would be avoided under this alternative and implementation of Mitigation Measures CUL-1 and CUL-2 would not be required. With implementation of the No Project Alternative, impacts to cultural resources would not occur and, therefore, this alternative would result in fewer impacts when compared to the proposed project.

5.4.2.6 Energy
Under the No Project Alternative, no construction activities would occur, and the site would remain undeveloped. There would be no energy usage associated with construction or operation of the No Project Alternative, therefore, no impacts to energy would occur. When compared to the proposed project, this alternative would result in fewer impacts to energy.

5.4.2.7 Geology and Soils
Under the No Project Alternative, no construction or grading activities would occur on the project site. As a result, the proposed project’s potential impacts that would result from construction at the project site, including potentially significant impacts unknown unique paleontological resources or unique geologic features would be avoided under this alternative, and implementation of Mitigation Measure GEO-1 would not be required. Additionally, under this alternative, no construction activities that would expose people working or residing in the project site to geologic hazards, and result in soil erosion would occur. With implementation of the No Project Alternative, impacts to geology and, therefore, this alternative would result in fewer impacts when compared to the proposed project.

5.4.2.8 Greenhouse Gas Emissions
Under the No Project Alternative, no construction activities would occur, and the site would remain undeveloped. There would be no greenhouse gas (GHG) emissions associated with construction and operation of the proposed project. The proposed project’s potentially significant operational GHG emission impacts would be avoided under this alternative and implementation of Mitigation Measure GHG-1 would not be required. Therefore, implementation of the No Project Alternative would avoid the less than significant with mitigation GHG impact associated with the proposed project. Therefore, this alternative would result in fewer impacts when compared to the proposed project.
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5.4.2.9 Hazards and Hazardous Materials
Under this alternative, changes in land use would not occur and the existing conditions related to the accidental release of, or exposure to, hazardous materials would remain the same. Although the existing agricultural operations could continue to operate, the use of solvents or fuels related to maintenance of operations as proposed by the project would not occur. Therefore, this alternative would result in fewer impacts when compared to the proposed project.

5.4.2.10 Hydrology and Water Quality
Under this alternative, the existing pervious surfaces and agricultural land would not be altered.

With no physical changes occurring within the project site, the existing drainage patterns of the project site would not be altered. In addition, this alternative would not create a potential to violate any water quality standards or waste discharge requirements, or otherwise substantially degrade surface or ground water quality, because this alternative would not change the existing conditions within the project site. As a result, this alternative would result in fewer impacts related to hydrology and water quality when compared to the proposed project.

5.4.2.11 Land Use and Planning
Under this alternative, the land uses within project site would not change. Similar to the proposed project, this alternative would not divide an existing community or conflict with an existing land use plan. As a result, this alternative would result in similar impacts when compared to the proposed project.

5.4.2.12 Mineral Resources
There are no mineral resources located within the project site, and no mineral resources would be adversely affected under this alternative or the proposed project. As a result, this alternative would similarly result in no impacts to mineral resources.

5.4.2.13 Noise
Under the No Project Alternative, no construction activities would occur, and the site would remain undeveloped. There would be no noise associated with the construction and operation of the proposed project. The proposed project’s potentially significant construction and operational noise impacts would be avoided under this alternative and implementation of Mitigation Measures NOI-1.1 and NOI-1.2 would not be required. In addition, the proposed project’s construction and operational less than significant vibration impacts would be avoided under this alternative. With implementation of the No Project Alternative, there would be no impacts related to noise and, therefore, this alternative would result in fewer impacts when compared to the proposed project.

5.4.2.14 Population and Housing
Under this alternative population and housing would not be affected. This project would not displace any people or result in new residential units. As a result, this alternative would result in fewer impacts related to population and housing when compared to the proposed project. 1025
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5.4.2.15 Public Services
Under this alternative, the population of the project site would not change and there would be no increased demand for public services, including fire protection, police protection, public schools, parks and recreational facilities. The proposed project would increase the population of the project site, but a less-than-significant impact would occur. When compared to the proposed project, this alternative would result in fewer impacts because the population within the project site would not increase.

5.4.2.16 Recreation
Under this alternative, the land uses within the project site would not change and would not affect recreational facilities and open space. As a result, when compared to the proposed project, this alternative would result in fewer impacts related to construction and/or expansion of the recreational facilities.

5.4.2.17 Transportation
Under the No Project Alternative, no uses would be developed on the project site that would generate higher traffic levels that create and contribute to unsatisfactory level of service (LOS) conditions in roadways and contribute to cumulative VMT impacts in the City of Clovis and Fresno County. Therefore, implementation of the No Project Alternative would avoid the significant and unavoidable LOS and VMT impacts associated with the proposed project. Therefore, this alternative would result in fewer impacts when compared to the proposed project.

5.4.2.18 Tribal Cultural Resources
No construction or grading activities would take place on the project site under the No Project Alternative. Therefore, the proposed project’s potential impacts that would result from construction at the project site, including potentially significant impacts related to disturbance of previously unknown tribal cultural resources would be avoided under this alternative and implementation of Mitigation Measures CUL-1 and CUL-2, which address impacts to previously unknown tribal cultural resources, would not be required. With implementation of the No Project Alternative, there would be no impacts to tribal cultural resources and, therefore, this alternative would result in fewer impacts when compared to the proposed project.

5.4.2.19 Utilities and Service Systems
Under this alternative, no land uses or physical changes would occur within the project site, and therefore, no increased demand for utilities and service systems, including water supply, wastewater, stormwater, and electricity, natural gas, and telecommunications would occur. The proposed project would include water service and wastewater services through connections to the City’s systems to accommodate population increase in the project site. As a result, this alternative would result in fewer impacts to utilities when compared to the proposed project.

5.4.2.20 Wildfire
The project site is located in an area mapped by CAL FIRE as LRA Unzoned, indicating that the area is urbanized and not susceptible to wildland conflagrations, and is not located within a very high fire 1026
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\5.0-Alternatives.docx (01/11/24) 5-9 hazard severity zone (VHFHSZ). Under this alternative, no changes to the existing uses within the project site would occur. Similar to the proposed project, this alternative would not exacerbate wildfire risks. Because the proposed project would result in physical changes to the project site and this alternative would not, this alternative would result in fewer impacts related to wildfire when compared to the proposed project.

5.4.3 Comparison to Project Objectives
As discussed above, the No Project Alternative would avoid all of the less than significant and significant unavoidable impacts of the proposed project. However, the No Project Alternative would also not achieve any of the objectives of the proposed project. The No Project Alternative would not provide residential housing opportunities that are visually attractive and accommodate future housing demand in Clovis; establish a mixture of housing types, sizes, and densities that collectively provide for local and regional housing demand; implement the City’s General Plan Land Use Element goal to facilitate annexation of large areas of land; provide infrastructure that meets City Standards and is integrated with existing and planned facilities and connections; or develop a project that meets City Standards by implementing a logical phasing plan for development of public infrastructure improvements. As a result, this alternative would not meet any of the objectives of the proposed project.

5.5 ALTERNATIVE 2: REDUCED PROJECT ALTERNATIVE
The Reduced Project Alternative is being studied as a viable alternative to the proposed project in compliance with requirements of CEQA, and would involve reducing the size of the proposed project by reducing the proposed residential density of 8.25 DU/acre in the site to a density of 4.12 DU/acre. The Reduced Project Alternative would reduce the total proposed residential units from 590 to 295. Annexation of land to the City of Clovis, as well as other improvements, including site access and infrastructure improvements, would be the same as the proposed project.

5.5.1 Analysis of the Reduced Project Alternative
The potential impacts associated with the Reduced Project Alternative are described below.

5.5.1.1 Aesthetics
Similar to the proposed project, the Reduced Project Alternative would involve construction and operational activities on the project site. However, due to the reduced number of residential units proposed under this alternative, this alternative would result in less density within the project site.

Similar to the proposed project, this alternative would change the land use within the project site and would result in changes to views, site character, and lighting. Although this alternative would not result in the same number of residential units as the proposed project, this alternative would result in similar, less-than-significant impacts to aesthetics.

5.5.1.2 Agriculture and Forestry Resources
Similar to the proposed project, this alternative would result in less than significant impacts related to the conversion of agricultural land to residential land use and potentially significant impacts related to cancellation of a Williamson Act contract. Implementation of Mitigation Measure AG-2 1027
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5 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\5.0-Alternatives.docx (01/11/24) -10 and Regulatory Measure AG-3 would be required. No forestry resources would be impacted by this alternative or the proposed project. Because this alternative would develop the entire site, similar to the proposed project, this project would result in a similar, less-than-significant impact to agriculture resources.

5.5.1.3 Air Quality
Similar to the proposed project, the Reduced Project Alternative would involve construction and operational activities on the project site. However, due to the reduced number of housing proposed under this alternative, this alternative may result in reduced construction and operational emissions, including those due to vehicle trips, compared to those under the proposed project. However, construction of the proposed project would still require implementation of SJVAPCD Regulation VIII dust control measures to reduce short-term construction period air quality impacts. Thus, this alternative would still require the implementation of regulatory compliance Measure AIR-2 to reduce the impact to less than significant level. All other air quality impacts would be reduced compared to those of the proposed project and would be less than significant. As a result, this alternative would result in fewer impacts when compared to the proposed project.

5.5.1.4 Biological Resources
Similar to the proposed project, the Reduced Project Alternative would involve construction and operational activities on the project site. Due to the reduced number of residential units proposed under this alternative, this alternative would result in reduced construction and operational emissions. However, construction of the proposed project would still result in ground-disturbing activities that could impact special-status species, federally protected wetlands and nesting birds.

However, this alternative would implement Mitigation Measures BIO-1 through BIO-4 and Regulatory Compliance Measure BIO-1 to reduce potential impacts to less-than-significant levels.

With implementation of this alternative, potential impacts to biological resources would occur and, therefore, this alternative would result in similar impacts when compared to the proposed project.

5.5.1.5 Cultural Resources
Similar to the proposed project, the Reduced Project Alternative would involve construction and operational activities on the project site. Due to the reduced number of residential units proposed under this alternative, this alternative would result in reduced construction and operational emissions. However, construction of the proposed project would still result in ground-disturbing activities that could impact previously unknown archaeological resources and human remains.

However, this alternative would implement Mitigation Measures CUL-1 and CUL-2 to reduce potential impacts to less-than-significant levels. With implementation of this alternative, potential impacts to cultural resources would occur and, therefore, this alternative would result in similar impacts when compared to the proposed project.

5.5.1.6 Energy
Similar to the proposed project, the Reduced Project Alternative would involve construction and operational activities on the project site. However, due to the reduced number of housing proposed under this alternative, this alternative would result in reduced construction and operational energy use as a result of fewer mobile sources (e.g., cars, trucks, and buses) and less construction of 1028
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5.5.1.7 Geology and Soils
Similar to the proposed project, the Reduced Project Alternative would involve construction and operational activities on the project site. Due to the reduced number of residential units proposed under this alternative, this alternative would result in reduced construction and operational emissions. However, construction of the proposed project would still result in ground-disturbing activities that could impact previously unknown unique paleontological resources or unique geologic features. However, this alternative would implement Mitigation Measure GEO-1 to reduce potential impacts to less-than-significant levels. With implementation of this alternative, potential impacts to geology and soils would occur and, therefore, this alternative would result in similar impacts when compared to the proposed project.

5.5.1.8 Greenhouse Gas Emissions
Similar to the proposed project, the Reduced Project Alternative would involve construction and operational activities on the project site. However, due to the reduced number of housing proposed under this alternative, this alternative would result in reduced construction and operational GHG emissions, including those due to mobile sources (e.g., cars, trucks, and buses), area sources (e.g., maintenance activities and landscaping), indirect emissions from sources associated with energy consumption, waste sources (land filling and waste disposal), and water sources (water supply and conveyance, treatment, and distribution). The Reduced Project Alternative would still require consistency with the 2022 Scoping Plan, which requires the project to implement design features to meet State GHG reduction and equity prioritization goals. As such, this alternative would still require implementation of Mitigation Measure GHG-1 to ensure consistency with the 2022 Scoping Plan and result in a less than significant impact with mitigation. All other GHG project and would be less than significant.

5.5.1.9 Hazards and Hazardous Materials
Similar to the proposed project, this alternative would include changes in land use that could result in the accidental release of, or exposure to, hazardous materials. Although the number of residential units would be less than the proposed project, potential impacts related to the use of solvents or fuels related to maintenance of operations would also occur. Therefore, this alternative would result in similar impacts when compared to the proposed project.

5.5.1.10 Hydrology and Water Quality
Under this alternative, the existing pervious surfaces and agricultural land would be altered with construction of residential units. Similar to the proposed project, the existing drainage patterns of the project site would be altered over the entire project site. In addition, this alternative would affect water quality standards and waste discharge requirements, and degrade surface or ground water quality. However, these impacts would be similar to the proposed project given disturbance of the project site. As a result, this alternative would result in similar, less than significant impacts related to hydrology and water quality when compared to the proposed project. 1029
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5.5.1.11 Land Use and Planning
Under this alternative, the land uses within project site would change to residential uses. However, similar to the proposed project this alterative would not divide an existing community or conflict with an existing land use plan. As a result, this alternative would result in similar impacts when compared to the proposed project.

5.5.1.12 Mineral Resources
There are no mineral resources within the project site, and no mineral resources would be adversely affected under this alternative or the proposed project. As a result, this alternative would similarly result in no impacts to mineral resources.

5.5.1.13 Noise
Construction activities under the Reduced Project Alternative would involve the use of generally the same types of construction equipment and vehicles as the proposed project, and construction activities would occur at the same distances from the nearest receptors as under the proposed project. As a result, the daily construction noise levels generated under this alternative would be comparable to that generated by the construction of the proposed project, and this alternative would also result in a potentially significant construction noise impacts at the nearby sensitive receptors. As such, Mitigation Measure NOI-1.1 would be required. However, because the number of total units included under this alternative would be smaller than the proposed project, the duration of construction would be reduced, and the duration of exposure to noise impacts would be slightly shorter. Additionally, the Reduced Project Alternative would reduce project-generated traffic noise compared to the proposed project, which would reduce impacts related to excessive interior noise levels in the project site. Implementation of Mitigation Measure NOI-1.2 could still be required to ensure the project complies with the City’s interior noise standard of 45 dBA CNEL related to traffic-generated noise. In addition, as with the proposed project, construction and operational vibration impacts would be less than significant under this alternative. With implementation of this alternative, potential noise impacts would be fewer when compared to the proposed project, due to the reduced number of residential units proposed.

5.5.1.14 Population and Housing
Under this alternative population and housing would increase over the existing conditions of the project site, however this alternative would result in fewer residential units and less population, when compared to the proposed project. However, the proposed project would result in less-thansignificant impacts to population and displacement of existing residents. As a result, this alternative would result in similar less than significant impacts related to population and housing when compared to the proposed project.

5.5.1.15 Public Services
Under this alternative, the population of the project site would be less than the proposed project.

The proposed project would result in less-than-significant impacts resulting from increased demand for public services, including fire protection, police protection, public schools, parks and recreational facilities. Similar to the proposed project, population within the project site would increase, 1030
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\5.0-Alternatives.docx (01/11/24) 5-13 however the population within the project site would not increase to the level of the proposed project, due to fewer residential units. Fewer units would also generate fewer financial resources for funding of said facilities, (school fees, development impact fees, Clovis Fire Department fees, and property taxes). Compared to the proposed project, this alternative would result in fewer impacts, because the population within the project site would be less than that of the proposed project.

5.5.1.16 Recreation
Under this alternative, fewer residential units would be constructed when compared to the proposed project. As a result, demand for recreational facilities and open space would increase over existing conditions but would result in less demand when compared to the proposed project. Fewer units would also generate fewer financial resources for funding of said facilities, (school fees, development impact fees, park fees, and property taxes). As a result, when compared to the proposed project, this alternative would result in fewer impacts related to construction and/or expansion of the recreational facilities.

5.5.1.17 Transportation
Under the Reduced Project Alternative, the project site would be developed at a lower residential density than what was proposed in the proposed project. As such, this alternative would generate lower traffic levels than those of the proposed project. However, the proposed project would still increase traffic levels in the nearby circulation system, which could potentially create and contribute to unsatisfactory LOS conditions in roadways in the City. Additionally, the Reduced Project Alternative would generate lower VMT than the proposed project due to reduced vehicle traffic.

However, the Reduced Project Alternative would still contribute to cumulative VMT impacts in the City of Clovis and Fresno County. With implementation of the Reduced Project Alternative, the significant unavoidable LOS and VMT impacts that would result from the proposed project could still occur, despite the reduction in traffic and VMT. With implementation of this alternative, potential transportation impacts would be fewer when compared to the proposed project.

5.5.1.18 Tribal Cultural Resources
Similar to the proposed project, the Reduced Project Alternative would involve construction and operational activities on the project site. Due to the reduced number of residential units proposed under this alternative, this alternative would result in reduced construction and operational emissions. However, construction of the proposed project would still result in ground-disturbing activities that could impact previously unknown tribal cultural resources. However, this alternative would implement Mitigation Measures CUL-1 and CUL-2 to reduce potential impacts to less-thansignificant levels. With implementation of this alternative, potential impacts to tribal cultural resources would occur and, therefore, this alternative would result in similar impacts when compared to the proposed project.

5.5.1.19 Utilities and Service Systems
Under this alternative, the land uses and physical changes would occur within the project site would be similar to the proposed project, and would increase the demand for utilities and service systems.

However, because this alternative would include half as many residential units as the proposed project, the demand related to water supply, wastewater, stormwater, and electricity, and 1031
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5.5.1.20 Wildfire
The project site is located in an area mapped by CAL FIRE as LRA Unzoned, indicating that the area is urbanized and not susceptible to wildland conflagrations, and is not within a VHFHSZ. Similar to the proposed project, this alternative would not exacerbate wildfire risks. Because this alternative would result in physical changes that would be similar to the proposed project, this alternative would result in similar less than significant impacts.

5.5.2 Comparison to Project Objectives
As discussed above, the Reduced Project Alternative would reduce the overall size of the project by reducing the density of residential uses in the project site. The Reduced Project Alternative would partially address the City of Clovis’ future housing demand by providing a lower amount of visually attractive residential housing opportunities; partially meet local and regional housing demand by providing a single housing type, size and density; implement the City’s General Plan Land Use Element goal to facilitate annexation of large areas of land; and provide integrated and planned infrastructure and logical phasing of public improvements in compliance with City Standards.

However, because this alternative would provide half of the residential units and minimize mixture of housing types of the proposed project, this alternative would partially meet the objectives of the project.

5.6 ALTERNATIVE 3: INCREASED PHASE DENSITY ALTERNATIVE
The Increased Phase Density Alternative would involve focusing development of the proposed 590 single-family residences, but the development would occur in two, approximately 24-acre areas located in the southern and northern portions of the project site. The central portion of the project site, approximately 23 acres in size, would be developed as open space. Annexation of land to the City of Clovis would be the same as the proposed project. Location and design of vehicle access and infrastructure improvements to facilitate development in the two development areas would be similar to the proposed project.

5.6.1 Analysis of the Increased Phase Density Alternative The potential impacts associated with Increased Phase Density Alternative are described below.

5.6.1.1 Aesthetics
Similar to the proposed project, the Reduced Project Alternative would involve construction and operational activities on the project site. This alternative would result in the massing of buildings on the northern and southern portions of the project site, but similarly to the proposed project, this alternative would change the land use within the project site and would result in changes to views, site character, and lighting. As a result, this alternative would result in similar, less-than-significant impacts to aesthetics.
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5.6.1.2 Agriculture and Forestry Resources
Similar to the proposed project, this alternative would result in less than significant impacts related to the conversion of agricultural land to residential land use and potentially significant impacts related to the cancellation of a Williamson Act contract. Implementation of Mitigation Measure AG2 and Regulatory Compliance Measure AG-3 would still be required. No forestry resources would be impact by this alternative or the proposed project. Because this alternative would develop the entire site with residential and open space uses, similar to the proposed project, this project would result in a similar, less-than-significant impact to agriculture resources.

5.6.1.3 Air Quality
Similar to the proposed project, the Increased Phase Density Alternative would involve construction and operational activities on the project site. This alternative would concentrate construction activities in specific locations of the project site, which would limit the spread of construction emissions. The Increased Phase Density Alternative would require constructing more houses per construction phase, but would limit the overall construction period for each phase compared to the proposed project. Operational emissions under this alternative, including those due to vehicle trips, would be similar to emissions under the proposed project as the number of proposed units under this alternative has not been reduced. Construction of the proposed project would still require implementation of SJVAPCD Regulation VIII dust control measures through implementation of Regulatory Compliance Measure AIR-2 to reduce short-term construction period air quality impacts.

With implementation of this alternative, potential impacts resulting from construction would be reduced due to the reduction in the overall construction period. Therefore, this alternative would result in similar impacts when compared to the proposed project.

5.6.1.4 Biological Resources
Similar to the proposed project, the Increased Phase Density Alternative would involve construction and operational activities on the project site. Although this alternative would focus development of residential developments on the northern and portions of the project site, construction of the proposed project would still result in ground-disturbing activities that could impact special-status species, federally protected wetlands and nesting birds. This alternative would implement Mitigation Measures BIO-1 through BIO-4 and Regulatory Compliance Measure BIO-1 to reduce potential impacts to less-than-significant levels. With implementation of this alternative, potential impacts to biological resources would occur and, therefore, this alternative would result in similar impacts when compared to the proposed project.

5.6.1.5 Cultural Resources
Similar to the proposed project, the Reduced Project Alternative would involve construction and operational activities on the project site. Although this alternative would focus development of residential developments on the northern and portions of the project site, construction of the proposed project would still result in ground-disturbing activities that could impact previously unknown archaeological resources and human remains. This alternative would implement Mitigation Measures CUL-1 and CUL-2 to reduce potential impacts to less-than-significant levels.

With implementation of this alternative, potential impacts to cultural resources would occur and, therefore, this alternative would result in similar impacts when compared to the proposed project. 1033
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5.6.1.6 Energy
Similar to the proposed project, this alternative would involve construction and operational activities on the project site that would result in the same number of residential units. This alternative would result in a reduced construction duration due to increased density on the northern and southern portions of the project site, resulting in lower construction energy impacts.

However, as this alternative would introduce the same number of residential units and mobile sources (e.g., cars, trucks, and buses) to the project site as the proposed project, operational energy impacts under this alternative would be similar to the proposed project. As a result, this project would result in less energy consumption and fewer impacts when compared to the proposed project.

5.6.1.7 Geology and Soils
Similar to the proposed project, the Increased Phase Density Alternative would involve construction and operational activities on the project site. Although this alternative would focus development of residential units on the northern and portions of the project site, construction of the proposed project would still result in ground-disturbing activities that could impact previously unknown unique paleontological resources or unique geologic features. This alternative would implement Mitigation Measure GEO-1 to reduce potential impacts to less-than-significant levels. With implementation of this alternative, potential impacts to geology and soils would occur and, therefore, this alternative would result in similar impacts when compared to the proposed project.

5.6.1.8 Greenhouse Gas Emissions
Similar to the proposed project, the Increased Phase Density Alternative would involve construction and operational activities on the project site. The higher density of development proposed in this alternative would result in reduced operational GHG emissions. However, the Increased Phase Density Alternative would still require consistency with the 2022 Scoping Plan, which requires the project to implement design features to meet State GHG reduction and equity prioritization goals.

As such, this alternative would still require implementation of Mitigation Measure GHG-1 to ensure consistency with the 2022 Scoping Plan and result in a less than significant impact with mitigation.

All other GHG impacts would be fewer compared to those of the proposed project and would be less than significant.

5.6.1.9 Hazards and Hazardous Materials
Similar to the proposed project, this alternative would include changes in land use that could result in the accidental release of, or exposure to, hazardous materials would remain the same. Because the number of residential units would be the same as the proposed project, potential impacts related to the use of solvents or fuels related to maintenance of operations would also occur.

Therefore, this alternative would result in similar impacts when compared to the proposed project.

5.6.1.10 Hydrology and Water Quality
Under this alternative, the existing pervious surfaces and agricultural land would be altered with construction of residential units. Similar to the proposed project, the existing drainage patterns of the project site would be altered over the entire project site. In addition, this alternative would 1034
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\5.0-Alternatives.docx (01/11/24) 5-17 affect water quality standards and waste discharge requirements and degrade surface or ground water quality. These impacts would be similar to the proposed project given disturbance of the project site. As a result, this alternative would result in similar impacts related to hydrology and water quality when compared to the proposed project.

5.6.1.11 Land Use and Planning
Under this alternative, the land uses within project site would change to residential uses. However, similar to the proposed project this alterative would not divide an existing community or conflict with an existing land use plan. As a result, this alternative would result in similar less than significant impacts when compared to the proposed project.

5.6.1.12 Mineral Resources
There are no mineral resources located within the project site, and no mineral resources would be adversely affected under this alternative or the proposed project. As a result, this alternative would similarly result in no impacts to mineral resources.

5.6.1.13 Noise
Construction activities under the Increased Phase Density Alternative would involve the use of generally the same types of construction equipment and vehicles as the proposed project, and construction activities would occur at the same distances from the nearest receptors as under the proposed project. Although, the daily construction noise levels generated under this alternative would be comparable to that generated by the construction of the proposed project, this alternative would result in shorter overall construction period, which would reduce the duration of noisegenerating construction. Although Mitigation Measure NOI-1.1 would be required, construction would not require as much time to be completed. The Increased Phase Density Alternative would have similar levels of project-generated traffic compared to the proposed project but concentrated in smaller areas. As such, implementation of Mitigation Measure NOI-1.2 would still be required to ensure the project complies with the City’s interior noise standard of 45 dBA CNEL. In addition, as with the proposed project, construction and operational vibration impacts would be less than significant under this alternative. With implementation of this alternative, potential noise impacts would be fewer when compared to the proposed project.

5.6.1.14 Population and Housing
Under this alternative population and housing would increase over the existing conditions of the project site, and would result in the same number of residential units as the proposed project. The proposed project would result in less-than-significant impacts to population and displacement of existing residents. As a result, this alternative would result in similar impacts related to population and housing when compared to the proposed project.

5.6.1.15 Public Services
Under this alternative, the population of the project site would be similar to the proposed project.

The proposed project would result in less-than-significant impacts resulting from increased demand for public services, including fire protection, police protection, public schools, parks and recreational 1035
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5 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\5.0-Alternatives.docx (01/11/24) -18 facilities. When compared to the proposed project, this alternative would result in similar impacts less-than-significant impacts to population and housing.

5.6.1.16 Recreation
When compared to the proposed project, this alternative would result in the same number of residential units and comparable population increase. As a result, demand for recreational facilities and open space would increase over existing conditions and would be similar to the proposed project. As a result, when compared to the proposed project, this alternative would result in similar impacts related to construction and/or expansion of the recreational facilities.

5.6.1.17 Transportation
Under the Increased Phase Density Alternative, portions of the project site would be developed at a higher residential density than what was proposed in the proposed project, but the same number of residential units would be constructed. The proposed project would increase traffic levels in the nearby circulation system, which could potentially create and contribute to unsatisfactory LOS conditions in roadways in the City. Therefore, with implementation of the Increased Phase Density Alternative, the significant and unavoidable LOS impact that would result from the proposed project could still occur. In addition, when compared to the proposed project, this alternative would result in similar VMT significant and unavoidable impacts given the proposed land uses and location relative to other land uses. Impacts related to incompatible uses, geometric design features and emergency access would be less than significant similar to the proposed project. Therefore, this alternative would result in similar impacts when compared to the proposed project.

5.6.1.18 Tribal Cultural Resources
Similar to the proposed project, the Increased Phase Density Alternative would involve construction and operational activities on the project site. Although this alternative would focus development of residential units on the northern and southern portions of the project site, construction of the proposed project would still result in ground-disturbing activities that could impact previously unknown tribal cultural resources. This alternative would implement Mitigation Measures CUL-1 and CUL-2 to reduce potential impacts to less-than-significant levels. With implementation of this alternative, potential impacts to tribal cultural resources would occur and, therefore, this alternative would result in similar impacts when compared to the proposed project.

5.6.1.19 Utilities and Service Systems
Under this alternative, the land uses and physical changes would occur within the project site would be similar to the proposed project, and would increase the demand for utilities and service systems.

As a result, demand related to water supply, wastewater, stormwater, and electricity, natural gas, and telecommunications, would be similar to the proposed project. As a result, this alternative would result in similar impacts to utilities and service systems when compared to the proposed project.
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5.6.1.20 Wildfire
The project site is in an area mapped by CAL FIRE as Local Responsibility Area (LRA) Unzoned, indicating that the area is urbanized and not susceptible to wildland conflagrations, and is not within a very high fire hazard severity zone (VHFHSZ). Similar to the proposed project, this alternative would not exacerbate wildfire risks. Because this alternative would result in physical changes that would be similar to the proposed project, this alternative would result in similar impacts.

5.6.2 Comparison to Project Objectives
As discussed above, the Increased Phase Density Alternative would build 590 single-family residential units in a smaller area within the project site than what is proposed in the proposed project, increasing residential density in the site. The Increased Phase Density Alternative would accommodate future housing demands in Clovis by providing visually attractive single-family residences; partially provide for local and regional housing demand by establishing a single housing type, size, and density to accommodate higher residential density on the project site. Additionally, this alternative implements the City’s General Plan Land Use Element goal to facilitate annexation of large areas of land; and provides integrated and planned infrastructure and logical phasing of public improvements in compliance with City Standards. Because this alternative would provide the same number of units, but would minimize mixture of housing types included in the proposed project, this alternative would partially meet the objectives of the project.

5.7 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
Based on the alternatives analysis, of the alternatives analyzed, the No Project Alternative would have the fewest impacts and would be the environmentally superior alternative. Under CEQA, if the No Project Alternative is the environmentally superior alternative, the EIR must identify an environmentally superior alternative from among the other alternatives (State CEQA Guidelines Section 15126.6(e)(2)). Table 5.A provides, in summary format, a comparison of the level of impacts for each alternative to the proposed project.

The Reduced Project Alternative would have less than significant impacts in most resource topics that would be comparable to the proposed project. The alternative would have potentially reduced construction-phase air quality, and reduced operational-phase air quality, noise, GHG impacts, and transportation due to reduced development on the project site. Therefore, the Reduced Project Alternative is considered the environmentally superior alternative. 1037
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Environmental
Topic
Proposed Project
Level of Impact
After Mitigation
Alternative 1:

No Project
Alternative
Alternative 2:

Reduced Project
Alternative
Alternative 3:

Increased Phase
Density Alternative
Aesthetics Less than Significant Fewer Similar Similar
Agricultural
Resources
Less than Significant Fewer Similar Similar
Air Quality Less than Significant Fewer Fewer Similar
Biological Resources Less than Significant Fewer Similar Similar Cultural Resources Less than Significant Fewer Similar Similar Energy Less than Significant Fewer Fewer Fewer
Geology and Soils Less than Significant Fewer Similar Similar Greenhouse Gas
Emissions
Less than Significant Fewer Fewer Fewer
Hazards and
Hazardous Materials
Less than Significant Fewer Similar Similar
Hydrology and
Water Quality
Less than Significant Fewer Similar Similar
Land Use and
Planning
Less than Significant Similar Similar Similar
Mineral Resources Less than Significant Similar Similar Similar Noise Less than Significant Fewer Fewer Fewer
Population and
Housing
Less than Significant Fewer Similar Similar
Public Services Less than Significant Fewer Fewer Similar Recreation Less than Significant Fewer Fewer Similar
Transportation Significant
Unavoidable
Fewer Fewer, Significant
Unavoidable
Similar, Significant
Unavoidable
Tribal Cultural
Resources
Less than Significant Fewer Similar Similar
Utilities and Service
Systems
Less than Significant Fewer Fewer Similar
Wildfire Less than Significant Fewer Similar Similar
Attainment of
Project Objectives
Meets all of the
Project Objectives
Meets none of the
Project Objectives
Partially Meets the Project
Objectives
Partially Meets the
Project Objectives
Source: Compiled by LSA (May 2023).

Fewer = Fewer impacts than the proposed project
Similar = Similar impacts to the proposed project
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6.0 CEQA-REQUIRED ASSESSMENT CONCLUSIONS
Section 15126 of the California Environmental Quality Act (CEQA) Guidelines requires that all aspects of a project must be considered when evaluating its impact on the environment, including planning, acquisition, development, and operation. This chapter provides an overview of the potential impacts resulting from the implementation of the proposed project based on the analyses presented in the Initial Study prepared for the proposed project, and Chapter 4.0, Evaluation of Environmental Impacts, of this EIR. The topics covered in this chapter include impacts found not to be significant, growth inducement, significant and unavoidable impacts, and significant irreversible changes. A more detailed analysis of the effects the proposed project would have on the environment and proposed mitigation measures to minimize significant impacts are provided in Sections 4.1 through 4.5 of this EIR.

6.1 GROWTH INDUCEMENT
Section 15126.2(d) of the State CEQA Guidelines requires that an EIR discuss the ways in which a proposed project or the construction of additional housing, either directly or indirectly, could foster economic or population growth in the surrounding environment. Examples of projects likely to have significant growth-inducing impacts include extensions or expansions of infrastructure systems beyond what is needed to serve project-specific demand, and development of new residential subdivisions or industrial parks in areas that are only sparsely developed or are underdeveloped.

Typically, development projects on sites that are designated for development and surrounded by existing suburban uses are not considered adversely growth-inducing because growth in areas that already have development and infrastructure available to serve new development are generally considered environmentally beneficial. This section evaluates the potential of the proposed project to create such growth inducements. Not all aspects of growth inducement are negative; rather, negative impacts associated with growth inducement occur only where the growth associated with the proposed project would cause adverse environmental impacts.

As described in Section 3.14, Population and Housing, of the Initial Study prepared for this EIR, implementation of the proposed project would not exceed the City’s projections for population growth in the project site, as the project site is located within the Heritage Grove Area, a planned growth area identified in the General Plan. As such, additional housing units and population resulting from implementation of the proposed project have been anticipated by the City and do not exceed projections of the City. Additionally, employment growth resulting from the proposed project would occur only temporarily due to construction activities. Therefore, the proposed project would not induce substantial unplanned population growth in an area, either directly or indirectly, and this impact would be considered less than significant.

As discussed in Section 3.15, Public Services, and Section 3.19, Utilities and Service Systems, of the Initial Study, the project site would be served by the City’s public service or utility providers, including police protection services, fire prevention services, water, wastewater, telecommunications, electricity, and natural gas. The proposed project includes physical improvements to accommodate growth which would create an increased demand for public services and utilities within the project site. As the project site is currently not annexed to the City, the 1039
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6 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\6.0-CEQA-Required.docx (01/11/24) -2 Project Applicant would be required to complete the annexation process with the Fresno County Local Agency Formation Commission and the City, and pay required processing fees for the annexation process. Once the project site is annexed into the City, to address impacts to public services and utilities, the Project Applicant would be required to pay applicable impact fees in effect at the time the development application for the proposed project is submitted. City staff would review the site plan for the project to ensure the adequate provision of public services and utilities.

As the project site is located within the Heritage Grove Area, a planned growth area identified in the General Plan, and installation of infrastructure and provision of services would accommodate planned growth in the project site, the provision of services and construction of utilities’ infrastructure for the proposed project would not induce substantial unplanned population growth in an area, either directly or indirectly, and this impact would be less than significant.

Development of the proposed project would involve construction activities that could generate some temporary employment opportunities. However, given the temporary nature of such opportunities, it is unlikely that construction workers would need to relocate to the City a as a result of the proposed project. Thus, the proposed project would not be considered growth-inducing from an employment perspective.

6.2 SIGNIFICANT IRREVERSIBLE CHANGES
Section 15126.2(d) of the State CEQA Guidelines requires an EIR to discuss the extent to which the proposed project would commit nonrenewable resources to uses that future generations would probably be unable to reverse. The three CEQA-required categories of irreversible changes are discussed below.

6.2.1 Changes in Land Use Which Commit Future Generations The proposed project would involve the development of land in the project site currently used for agricultural production. Although the proposed development would commit future generations to using the project site for developed uses rather than agricultural purposes, such a commitment is consistent with planned residential uses for the project site, as identified in the City’s General Plan.

The General Plan has anticipated development in the project site that commits future generations, which was assessed under the General Plan EIR; the proposed project merely implements and carries out the vision of the General Plan.

6.2.2 Irreversible Damage from Environmental Accidents
Demolition and construction activities associated with implementation of the proposed project would involve some risk for environmental accidents. However, as discussed in Section 3.9, Hazards and Hazardous Materials, of the Initial Study, accidental spills and soil contamination would be addressed by City, State, and federal agencies, and would follow professional industry standards for safety and construction. Although there is a possibility for contaminated soil to be encountered during grading, excavation, and/or ground disturbance associated with implementation of the proposed project, it is likely that such contamination may have resulted from agricultural operations within the project site. However, the risks of accidental contamination from handling construction materials or transport of these materials off site would be reduced to a less-than-significant level through compliance with the many federal, State, and local regulations regarding the handling and 1040
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6.2.3 Consumption of Non-Renewable Resources
Consumption of non-renewable resources includes issues related to increased energy consumption, conversion of agricultural lands, and lost access to mining reserves. The proposed project would require water, and electricity service, as well as additional resources for construction. Construction and ongoing maintenance would irreversibly commit some materials and non-renewable energy resources. Materials and resources used during implementation of the proposed project would include, but are not limited to, non-renewable and limited resources such as oil, gasoline, sand, gravel, asphalt, and steel. These materials and energy resources would be used for infrastructure development, transportation of people and goods, and utilities. During the operational phase of the proposed project, energy sources including oil and gasoline would be used for lighting, heating, and cooling of residences, as well as transportation of people to and from the project site.

As discussed in Section 3.6, Energy, of the Initial Study, the projected electricity demands of the proposed project would be consistent with typical usage rates for residential uses in the City of Clovis, and would not result in a significant adverse impact related to the provision of electricity. In addition, the proposed project would comply with Title 24 of the California Code of Regulations (CCR) that requires conservation practices that would limit the amount of energy (California Energy Code Building Energy Efficiency Standards [Title 24, Part 6]) consumed through implementation of the proposed project. With the development of more cost-effective and accessible technologies, pursuant to the Appliance Efficiency Regulations (Title 20, CCR Sections 1601 through 1608), dependence on non-renewable resources used in association with future development envisioned under the proposed project may also be reduced. Furthermore, the proposed project would be required to undergo project-specific analysis (as required by CEQA) and comply with all California Green Building Standards Code (CALGreen Code) building efficiency standards (Title 24, Part 11) and mandatory residential building requirements in the California Energy Code Building Energy Efficiency Standards (Title 24, Part 6) (as required by State law). Additionally, resources that would be used during the operation of the proposed project would be similar to those currently consumed within the City. Nevertheless, the use of such resources would continue to represent a long-term commitment of essentially non-renewable or slowly renewable resources.

Implementation of the proposed project would also result in an increased demand for potable water and generation of wastewater. As discussed in Section 3.10, Hydrology and Water Quality, and Section 3.19 Utilities and Service Systems, the project is consistent with growth under the City’s General Plan and covered under the City’s 2020 Urban Water Management Plan Update. The proposed project would have sufficient water supplies available to meet future demand during normal, dry and multiple dry years. The adequacy of the water supply for the project is thus consistent with the basis of the analysis of the City’s water supply in the adopted 2020 Urban Water Management Plan Update.
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6 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\6.0-CEQA-Required.docx (01/11/24) -4 Although the construction and ongoing operation of the proposed project would involve the use of non-renewable resources, through the inclusion of energy-conserving features of the proposed project, and compliance with applicable standards and regulations, the proposed project would not represent an unjustified use of such non-renewable resources.

6.3 SIGNIFICANT UNAVOIDABLE IMPACTS
The environmental effects of the proposed project, along with recommended mitigation measures, are discussed in detail in Section 4.0, Evaluation of Environmental Impacts, and summarized in the Executive Summary. The following environmental issues were determined to result in less-thansignificant impacts, or can be reduced to less-than-significant levels with the incorporation of mitigation measures:
• Aesthetics
• Agricultural Resources (mitigation required)
• Air Quality
• Biological Resources (mitigation required)
• Cultural Resources (mitigation required)
• Energy
• Geology and Soils (mitigation required)
• Greenhouse Gas Emissions (mitigation required)
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Land Use and Planning
• Mineral Resources
• Noise (mitigation required)
• Population and Housing
• Public Services
• Recreation
• Tribal Cultural Resources (mitigation required)
• Utilities and Service Systems
• Wildfire
Section 15126.2(c) of the State CEQA Guidelines requires that an EIR describe any significant impacts, including those that can be mitigated but not reduced to less than significant levels, as a result of implementation of the project. The following environmental issues were determined to result in potential significant and unavoidable impacts, even after implementation of feasible mitigation.
• Transportation – potentially exceed thresholds of levels of service on roadways in conflict with approved General Plan and increase in VMT.
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7.0 REPORT PREPARATION

7.1 REPORT PREPARERS

7.1.1 City of Clovis
1033 Fifth Street
Clovis, California 93612
Lily Cha-Haydostian, MPA, AICP, Senior Planner
Sean K. Smith PE QSD, Supervising Civil Engineer

7.1.2 LSA Associates Inc.

Project Management and Report Production, Air Quality/Greenhouse Gas Emissions, Noise 2565 Alluvial Avenue, Suite 172
Clovis, California 93611
Amy Fischer, President, Principal in Charge
Kyle Simpson, Principal/Project Manager
Cara Carlucci, Associate
Nathaly Granda Bustamante, Environmental Planner
Patty Linder, Graphics/Document Production
Transportation
1500 Iowa Avenue, Suite 200
Riverside, California 92507
Ambarish Mukherjee, AICP, PE, Principal
Ravi Palakurthy, Senior Transportation Planner/Engineer Debmalya Sinha, Senior Transportation Planner
Kimberly Cervantes, Assistant Transportation Planner/Engineer Agricultural Resources
286 South Street, Suite P
San Luis Obispo, California 93401
Pam Reading, Principal
Ashley Honer, Environmental Planner

7.1.3 Argonaut Ecological Consulting, Inc.

Biological Resources
2377 Gold Meadow Way, Suite 100
Gold River, California 95670
Kathy R. Kinsland, Senior Scientist
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7.1.4 Peak & Associates, Inc.

Cultural Resources
3941 Park Drive, Suite 20 #329
El Dorado Hills, California 95762
Melinda A. Peak, Senior Scientist
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8.0 REFERENCES
California Air Pollution Control Officers Association’s (CAPCOA). 2021. Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity – Designed for Local Governments, Communities, and Project Developers.

December.

California Air Resources Board (CARB). 2000a. Fact Sheet – California’s Plan to Reduce Diesel Particulate Matter Emissions. October. Website: www.arb.ca.gov/diesel/fact sheets/ rrpfactsheet.pdf (accessed September 2022).
_____. 2000b. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. October. Prepared by the Stationary Source Division and Mobile Source Control Division. Website: www.arb.ca.gov/diesel/documents/rrpFinal.pdf (accessed September 2022).
_____. 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April. _____. 2007a. “ARB approves tripling of early action measures required under AB 32” News Release 07-46. October 25.
_____. 2007b. Expanded List of Early Action Measures to Reduce Greenhouse Gas Emissions in California Recommended for Board Consideration. October. _____. 2014. Cap-and-Trade Program. Website: www.arb.ca.gov/cc/capandtrade/capandtrade.htm (accessed September 2022).
_____. 2016. Federal and State Ambient Air Quality Standards. _____. 2017a. California’s 2017 Climate Change Scoping Plan. November. _____. 2017b. Second Update to the Climate Change Scoping Plan: Building on the Framework.

Website: www.arb.ca.gov/our-work/programs/ab-32-climate-change-scoping-plan/2017- scoping-plan-documents (accessed February 2023).
_____. 2017c. Short-Lived Climate Pollutant Reduction Strategy. March. Website: https://ww2.arb. ca.gov/sites/default/files/2020-07/final_SLCP_strategy.pdf (accessed September 2022). _____. 2018. Sources and Health Effects of Air Pollutants. _____. 2020. Inhalable Particulate Matter and Health (PM2.5 and PM10). Website: ww2.arb.ca.gov/ resources/inhalable-particulate-matter-and-health (accessed September 2022). _____. 2022a. 2022 Scoping Plan. November 16. Website: https://ww2.arb.ca.gov/sites/default/ files/2022-12/2022-sp.pdf (accessed January 2023).
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8 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\8.0 References.docx (01/11/24) -2 _____. 2022b. 2022 Scoping Plan Appendix D Local Actions. November. Website: https://ww2.arb. ca.gov/sites/default/files/2022-11/2022-sp-appendix-d-local-actions.pdf (accessed February 2023).
_____. 2022c. California Greenhouse Gas Emissions for 2000 to 2020, Trends of Emissions and Other Indicators Report. Website: https://ww2.arb.ca.gov/sites/default/files/classic/cc/ inventory/2000-2020_ghg_inventory_trends.pdf (accessed January 2023). _____. 2022d. GHGs Descriptions & Sources in California. Website: ww2.arb.ca.gov/ghgdescriptions-sources (accessed January 2023). _____. 2023. San Joaquin Valley Air Basin Air Quality Attainment Status.

California Air Resources Board (CARB) 2022 and United States Environmental Protection Agency (USEPA) 2022. Ambient Air Quality at Nearby Monitoring Stations.

California Coastal Commission (CCC). Procedural Guidance for the Review of Wetland Projects in California’s Coastal Zone. Website: http://www.coastal.ca.gov/wetrev/wetch4.html (accessed September 2022).

California Department of Conservation (DOC). 2016. California Important Farmland Finder. Website:
https://maps.conservation.ca.gov/DLRP/CIFF/ (accessed April 2023). _____. 2018. Farmland Mapping and Monitoring Program, 2018 Fresno County. Website: https:// gis.conservation.ca.gov/portal/home/group.html?id= b1494c705cb34d01acf78f4927a75 b8f#overview (accessed April 2023).

California Department of Transportation (Caltrans). 2002. Guide for the Preparation of Traffic Impact Studies. December.
_____. 2020. Highway Design Manual – Seventh Edition. July 1. Website: https://dot.ca.gov/ programs/design/manual-highway-design-manual-hdm (February 2023).

California Environmental Protection Agency (CalEPA). 2006. Climate Action Team Report to Governor Schwarzenegger and the Legislature. March.

California Government Code of the State of California, Sections 51201, 51231, 51238 and 51238.1.

City of Clovis. 2014. General Plan. August. General Plan and Development Code Update Preliminary Final Environmental Impact Report. Website: https://cityofclovis. com/wp-content/uploads/ 2018/10/Preliminary-Final-Environmental-Impact-Report-August-2014.pdf (accessed April 2023).
_____. 2016. Fresno Multi-Jurisdictional 2015-2023 Housing Element. April. Website: https://cityof clovis.com/wp-content/uploads/2019/02/Clovis-Housing-Element-1.pdf (accessed September 21, 2022).
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\8.0 References.docx (01/11/24) 8-3 _____. 2021a. Clovis Municipal Code.
_____. 2021b. Urban Water Management Plan 2020 Update. July. Website: https://cityofclovis. com/wp-content/uploads/2021/08/2020-UWMP-Adopted-July-2021_reduced.pdf (accessed April 2023).

Climate Change Science Program (CCSP) 4.1. 2009. January 15, 2009, 1 of 784 Final Report, United States CCSP, Synthesis and Assessment Product 4.1. Coastal Sensitivity to Sea-Level Rise: A Focus on the Mid-Atlantic Region. Lead Agency: U.S. Environmental Protection Agency, Other Key Participating Agencies: U.S. Geological Survey, National Oceanic and Atmospheric Administration. Contributing Agencies: Department of Transportation.

County of Fresno. 2013. Board Briefing Report, Status Report Regarding Administration of the Williamson Act Program, Alan Weaver, Director Department of Public Works and Planning, February 21, 2013.

Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual.

Office of Planning and Environment. Report No. 0123. September.

Fresno Metropolitan Flood Control District. 2019. Storm Drainage and Flood Control Master Plan.

Website: https://www.fresnofloodcontrol.org/wp-content/uploads/2021/03/exhibit-A11x17-1.pdf (accessed April 19, 2022).

Harris, Cyril, ed. 1998. Handbook of Acoustical Measurements and Noise Control.

Intergovernmental Panel on Climate Change (IPCC). 2007. Climate Change 2007: The Physical Science Basis, Summary for Policymakers. February.

Klingebiel, A.A. (Albert Arnold), and P.H. (Paul Hooper) Montgomery. 1961. Land-Capability Classification. Agricultural Handbook No. 210. Soil Conservation Service, U.S. Department of Agriculture. Website: https://naldc.nal.usda.gov/catalog/CAT10310193 (accessed May 2023).

Krazan & Associates, Inc. 2022. Geotechnical Engineering Investigation Proposed Tract No. 6343 Behymer Avenue, Clovis, California. June 29.

LSA Associates, Inc. 2022. Farmland Impact Assessment, Heritage Grove SB 2 Grant Technical Studies Project, City of Clovis, California. February.
_____. 2023a. Land Evaluation and Site Assessment Model (LESA Model) for the Tract Map (TM) 6343 Project. August 22.
_____. 2023b. Transportation Impact Analysis Tract Map 6343 Project, Clovis, Fresno County, California. August.
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8 P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\8.0 References.docx (01/11/24) -4 North Kings Groundwater Sustainability Agency. 2019. Groundwater Sustainability Plan. November

21. Propper, Ralph, Patrick Wong, Son Bui, Jeff Austin, William Vance, Álvaro Alvarado, Bart Croes, and Dongmin Luo. 2015. Ambient and Emission Trends of Toxic Air Contaminants in California.

American Chemical Society: Environmental Science & Technology. Website: pubs.acs.org/ doi/full/10.1021/acs.est.5b02766 (accessed January 2023).

Provost & Pritchard. 2022. Memorandum – Water Infrastructure Investigation for Tentative Tract Map 6343. December 19.

San Joaquin Valley Air Pollution Control District (SJVAPCD). 2007. 2007 PM10 Maintenance Plan and Request for Redesignation. Website: www.valleyair.org/Air_Quality_Plans/docs/ Maintenance%20Plan10-25-07.pdf (accessed September 2022). _____. 2015a. Guidance for Assessing and Mitigating Air Quality Impacts. March 19, 2015. Website:
https://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT-GAMAQI.PDF (accessed January 2023).
_____. 2015b. Screening Levels for Potential Odor Sources _____. 2018. 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards. November 15. Website:
http://valleyair.org/pmplans/documents/2018/pm-plan-adopted/2018-Plan-for-the-1997- 2006-and-2012-PM2.5-Standards.pdf (accessed September 2022). _____. 2022. 2022 Plan for the 2015 8-Hour Ozone Standard. December 15. Website: https://ww2. valleyair.org/media/q55posm0/0000-2022-plan-for-the-2015-8-hour-ozone-standard.pdf (accessed February 2023).

Storie, R. 1932. An index for rating the agricultural values of soils. Bulletin 556. Berkeley: California Agricultural Experiment Station.
_____. 1978. Storie index soil rating. Oakland: University of California Division of Agricultural Sciences Special Publication 3203.

Trane. 2002. Sound Data and Application Guide for the New and Quieter Air-Cooled Series R Chiller.

United Nations Framework Convention on Climate Change (UNFCCC). 2021. GHG Data from UNFCCC. Website: unfccc.int/process-and-meetings/transparency-and-reporting/green house-gas-data/ghg-data-unfccc/ghg-data-from-unfccc (accessed June 2022).

United States Department of Agriculture (USDA). 1961. Soil Conservation Service. Land Capability Classifications and Land Capability Subclass Units.
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P:\CIT2201-TM 6343\PRODUCTS\DEIR\Public Review\8.0 References.docx (01/11/24) 8-5 _____. 2020. Natural Resources Conservation Service. Title 430 – National Soil Survey Handbook.

Part 622 – Interpretive Groups, 622.2 – Land Capability Classification. Pgs. 622.A.2 – 622.A.3.

June. Website: https://directives.sc.egov.usda.gov/OpenNonWeb Content.aspx? content=48824.wba (accessed April 2023).
_____. 2021. National Agriculture Statistics Service (NASS). CropScape-Cropland Data Layer.

Website: https://nassgeodata.gmu.edu/CropScape/ (accessed May 26, 2022). _____. n.d. Soil Survey Staff, Natural Resources Conservation Service. Soil Survey Geographic (SSURGO) Database. Website: https://sdmdataaccess.sc.egov.usda. gov (accessed April 2023).

United States Department of the Interior. 2007. Environmental Water Account Draft Supplemental EIS/EIR to the Environmental Water Account Final EIS/EIR, Bureau of Reclamation MidPacific Region, Sacramento, California. October.

United States Environmental Protection Agency (USEPA). 1974. Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety.
_____. 1978. Protective Noise Levels, Condensed Version of EPA Levels Document. November. _____. 2016. Climate Impacts on Human Health. Website: 19january2017snapshot.epa.gov/climateimpacts/climate-impacts-human-health.html (accessed March 7, 2022). _____. 2017. Black Carbon, Basic Information. February 14, 2017. Website: 19january2017 snapshot.epa.gov/www3/airquality/blackcarbon/basic.html (accessed September 2022). _____. 2021. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2019. Website: https:// www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks-1990-2019 (accessed September 2022).

Western Regional Climate Center. n.d. Fresno Yosemite International Airport (043257), Period of Record Monthly Climate Summary. Website: https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?ca3257 (accessed January 2023).
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APPENDIX A

NOTICE OF PREPARATION AND INITIAL STUDY
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1 NOTICE OF PREPARATION

OF A DRAFT ENVIRONMENTAL IMPACT REPORT
FOR THE TRACT MAP 6343 PROJECT
Date: December 19, 2022
To: Office of Planning and Research, Responsible and Trustee Agencies, Other Public Agencies and Other Interested Parties
Subject: Notice of Preparation of Draft Environmental Impact Report for the Tract Map 6343 Project
Lead Agency: City of Clovis
Project Title: Tract Map 6343
Project Applicant: Wilson Premier Homes, Inc
Contact: Lily Cha, Senior Planner
Planning Division
1033 Fifth Street
Clovis, CA 93612
(559) 324-2335
[email protected]
Comment Period: December 19, 2022 to January 17, 2023

PURPOSE OF NOTICE
The City of Clovis (City) is the lead agency responsible for preparation of an Environmental Impact Report (EIR) for the Tract Map 6343 Project (proposed project). Pursuant to provisions of the California Environmental Quality Act (CEQA), the City has prepared this Notice of Preparation (NOP) for the proposed project. Once a decision is made to prepare an EIR, the lead agency must prepare a NOP to inform all responsible and trustee agencies that an EIR will be prepared (CEQA Guidelines Section 15082). The purpose of this NOP is to provide agencies, interested parties, and organizations with sufficient information describing the proposed project and its potential environmental effects to enable meaningful input related to the scope and content of information to be included in the EIR. 1053
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2 PUBLIC REVIEW PERIOD
As required by Section 15082 of the CEQA Guidelines, this NOP has been prepared and distributed to solicit comments from interested parties and potential responsible and trustee agencies and other public agencies so that project-related concerns relevant to each agency’s statutory responsibilities in connection with the proposed project can be addressed in the EIR, as well as any related issues from interested parties other than potential responsible and trustee agencies, including other agencies and affected members of the public. The EIR will be the environmental document of reference for Responsible and Trustee Agencies when considering subsequent discretionary approvals.

This NOP is being circulated for public review and comment for a period of 30 days beginning December 19, 2022. The City requests that any potential responsible or trustee agencies responding to this NOP reply in a manner consistent with Section 15082(b) of the CEQA Guidelines, which requires submittal of any comments in response to this notice no later than 30 days after receipt of the NOP.

Comments in response to this NOP will be accepted through 5:00 p.m., January 17, 2023.

Please send your written comments to Ms. Cha and include your name, address, phone number, and/or email address so that we may contact you for clarification, if necessary.

Copies of the Notice of Preparation may be reviewed at the following locations:
• Clovis Regional Library, 1155 5th Street, Clovis, during library hours; • City of Clovis, Planning and Development Department, 1033 Fifth Street, Clovis, between 8:00 a.m. and 4:00 p.m.; or
• Online at: https://cityofclovis.com/planning-and-development/planning/ceqa/

PROJECT DESCRIPTION
The proposed project would consist of the annexation of 246 acres by the City of Clovis, and the development of 590 residential lots, averaging 3,329 square feet within the 71.54-acre project site.

The proposed lots would be developed into single-family residences over time. Sixty-six outlot spaces that would potentially be developed into private roads, private parking, pedestrian walkways, landscaping, public utilities, and public park uses would also be included within the project site.

No development is proposed within the remaining 174.46-acre annexation area surrounding the project site. The proposed project would include annexation of the 246-acre area from Fresno County jurisdiction to the City of Clovis. Any future development occurring within the annexation area would require a separate project-specific analysis.

The proposed project would be developed in three phases. • Phase 1. Phase 1 would include the development of 136 single-family residential units with an average size of 1,514 square feet per unit. Phase 1 would be located on the southern portion of the project site and would be accessed through one ingress and egress driveway located on Perrin Avenue. Phase 1 would include the construction of 44 parking spaces, an 8,745 square-foot community pool and recreation area, a 13,930 square-foot community park, 0.51 acre of landscaped areas, and drainage and pedestrian infrastructure improvements along Perrin 1054
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3 Avenue. The southern extension of North Baron Avenue from East Behymer Avenue and the extension of Perrin and Hammel Avenue within the project site would be constructed during Phase 1.
• Phase 2. Phase 2 would include the development of 214 single-family residential units with an average size of 2,168 square feet per unit. Phase 2 would be located on the central portion of the project site and would be accessed through one gated ingress and egress driveway located along the future southern extension of Baron Avenue, and one driveway along Hammel Avenue. Phase 2 would include the construction of an approximately 26-foot-wide drainage channel along Perrin Avenue, approximately 0.35 acre of landscaped areas, as well as storm drainage and pedestrian infrastructure improvements along Perrin Avenue and Hammel Avenue. • Phase 3. Phase 3 of the proposed project would include the development of 240 single-family residential units with an average size of 1,514 square feet per unit. Phase 3 would be located on the northern portion of the project site and would be accessed through two gated ingress and egress driveways located along the future southern extension of Baron Avenue, and through one gated driveway located along the future northern extension of Hammel Avenue. Phase 3 would include the construction of approximately 91 parking spaces, an approximately 9,985 square-foot pool and recreation area, approximately 0.65 acre of landscaped areas, and drainage and pedestrian infrastructure improvements along Baron Avenue.

In addition, development of the project site would include infrastructure improvements for water services along the East Behymer Avenue frontage and Baron Avenue frontage, as well as stormwater management infrastructure improvements along the Perrin Avenue frontage. The proposed project would also construct a two-lane, approximately 49-foot-wide and 2,650-foot long extension of Baron Avenue south of East Behymer Avenue.

ALTERNATIVES TO BE ANALYZED IN THE EIR
In accordance with Section 15126.6 of the CEQA Guidelines, the EIR will assess a range of reasonable alternatives to the proposed project. The range of alternatives to be addressed will include alternatives that are specifically required by CEQA (e.g., the No Project Alternative), as well as other alternatives intended to reduce or eliminate potentially significant impacts, as identified through the coordinated consultation and planning process.

POTENTIAL ENVIRONMENTAL EFFECTS
The EIR will evaluate the potential environmental impacts of the proposed project, after having first established the environmental setting, or baseline, for the environmental analysis. The significance of potential impacts, cumulative impacts, and appropriate mitigation measures associated with the proposed project would be thoroughly discussed in the EIR.

The Initial Study prepared for this EIR evaluated the environmental issue topics required by CEQA.

The individual environmental topics evaluated in the Initial Study include the following:
• Aesthetics • Land Use and Planning
• Agriculture and Forestry Resources • Mineral Resources • Air Quality • Noise
• Biological Resources • Population and Housing
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4 • Cultural Resources • Public Services
• Energy • Recreation
• Geology and Soils • Transportation and Traffic
• Greenhouse Gas Emissions • Tribal Cultural Resources
• Hazards and Hazardous Materials • Utilities and Service Systems • Hydrology and Water Quality • Wildfire
The Initial Study identified potentially significant environmental issue topics that will be analyzed in more detail in the EIR. The topics include:
• Air Quality
• Greenhouse Gas Emissions
• Noise
• Transportation

PUBLIC SCOPING MEETING
The City will hold a public scoping meeting to inform interested parties about the proposed project, and to provide agencies and the public with an opportunity to provide comments on the scope and content of the EIR. The meeting time and location is as follows:

City of Clovis Council Chamber
1033 Fifth Street
Clovis, CA 93612
Date: Thursday, January 12, 2023
Time: 6:00 p.m.
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December 2022

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TRACT MAP 6343

INITIAL STUDY

CLOVIS CALIFORNIA
Submitted to:

Lily Cha, Senior Planner
Planning and Development Services
1033 Fifth Street
Clovis, California 93612
Prepared by:

LSA
2565 Alluvial Avenue, Suite 172
Clovis, California 93611
(559) 490-1210
Project No. CIT2201
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TABLE OF CONTENTS
TABLE OF CONTENTS ............................................................................................................................... i FIGURES AND TABLES ............................................................................................................................. ii LIST OF ABBREVIATIONS AND ACRONYMS............................................................................................ iii

1.0 PROJECT INFORMATION................................................................................... 1-1

2.0 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED........................................ 2-1

2.1 Determination...................................................................................................................2-1

3.0 CEQA ENVIRONMENTAL CHECKLIST.................................................................. 3-1

3.1 Aesthetics..........................................................................................................................3-1

3.2 Agriculture and Forestry Resources..................................................................................3-5

3.3 Air Quality .........................................................................................................................3-9

3.4 Biological Resources........................................................................................................3-13

3.5 Cultural Resources ..........................................................................................................3-20

3.6 Energy..............................................................................................................................3-24

3.7 Geology and Soils............................................................................................................3-26

3.8 Greenhouse Gas Emissions.............................................................................................3-30

3.9 Hazards and Hazardous Materials...................................................................................3-32

3.10 Hydrology and Water Quality .........................................................................................3-36

3.11 Land Use and Planning....................................................................................................3-42

3.12 Mineral Resources...........................................................................................................3-44

3.13 Noise................................................................................................................................3-45

3.14 Population and Housing..................................................................................................3-51

3.15 Public Services.................................................................................................................3-53

3.16 Recreation.......................................................................................................................3-56

3.17 Transportation ................................................................................................................3-57

3.18 Tribal Cultural Resources ................................................................................................3-61

3.19 Utilities and Service Systems...........................................................................................3-63

3.20 Wildfire............................................................................................................................3-67

4.0 LIST OF PREPARERS .......................................................................................... 4-1

5.0 REFERENCES..................................................................................................... 5-1

APPENDICES
A: AB 52 CONSULTATION REQUEST AND RESPONSE LETTERS
B: WATER INFRASTRUCTURE INVESTIGATION
C: WATER SUPPLY ASSESSMENT
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FIGURES AND TABLES

FIGURES
Figure 1-1: Regional and Local Context .............................................................................................. 1-7 Figure 1-2: Aerial Photograph of the Project Site and Surrounding Land Uses.................................. 1-9 Figure 1-3: General Site Plan............................................................................................................. 1-11 Figure 1-4: South: Phase 1 ................................................................................................................ 1-13 Figure 1-5: Central: Phase 2.............................................................................................................. 1-15 Figure 1-6: North: Phase 3 ................................................................................................................ 1-17 TABLES
Table 3.A: SJVAPCD Construction and Operation Thresholds of Significance (tons/yr)................... 3-10 Table 3.B: City of Clovis Maximum Exterior Noise Standards........................................................... 3-47 Table 3.C: City of Clovis Maximum Interior Noise Standards........................................................... 3-47 Table 3.D: Typical Construction Equipment Noise Levels................................................................. 3-48 1062
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LIST OF ABBREVIATIONS AND ACRONYMS
µg/m3 micrograms per cubic meter
AB 52 Assembly Bill 52
Active Transportation Plan 2021 Clovis Active Transportation Plan Update AF acre-feet
AFY acre-feet per year
AFY/ac acre-feet per year per acre
Air Basin San Joaquin Valley Air Basin
ALUCP Airport Land Use Compatibility Plan
APN Assessor Parcel Numbers
BMPs Best Management Practices
CAL FIRE California Department of Forestry and Fire Protection CalEPA California Environmental Protection Agency
CALGreen Code California Green Building Standards Code
California Register California Register of Historical Resources Caltrans California Department of Transportation
CARB California Air Resources Board
CCR California Code of Regulations
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
CESA California Endangered Species Act
CFC California Fire Code
CFD Clovis Fire Department
CH4 methane
City City of Clovis
CNDDB California Natural Diversity Database
CNEL Community Noise Equivalent Level
CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide equivalent
CPD Clovis Police Department
CRA Cultural Resource Assessment
CUSD Clovis Unified School District
db decibels
dBA A-weighted decibels
DTSC California Department of Toxic Substances Control
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EOP Emergency Operations Plan
EPA United States Environmental Protection Agency
FEMA Federal Emergency Management Agency
FHWA Federal Highway Administration
FID Fresno Irrigation District
FMFCD Fresno Metropolitan Flood Control District
FMMP Farmland Mapping and Monitoring Program
Fresno LAFCo Fresno County Local Agency Formation Commission GAMAQI Guidance for Assessing and Mitigating Air Quality Impacts GHG greenhouse gas
gpm gallons per minute
GWP Global Warming Potential
HCP Habitat Conservation Plan
HFCs hydrofluorocarbons
HP helipad
HQTA High-Quality Transit Area
IPaC Information for Planning and Consultation
Ldn day-night average level
Leq equivalent continuous sound level
LESA Land Evaluation and Site Assessment
Lmax maximum instantaneous noise level
LOS level of service
LRA Local Responsibility Area
MRZ-3 Mineral Resource Zone 3
N2O nitrous oxide
NAHC Native American Heritage Commission
NCCP Natural Communities Conservation Plan
NO2 nitrogen dioxide
NPDES National Pollutant Discharge Elimination System
O&M Operation and Maintenance
O3 ozone
OSHA Occupational Safety and Health Administration
Pb lead
PFCs perfluorocarbons
PM10 particulate matter less than 10 microns in size
PM2.5 particulate matter less than 2.5 microns in size
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PRC Public Resources Code
RWQCB Regional Water Quality Control Board
RWRF Regional Wastewater Reclamation Facility
SB 2 Senate Bill 2
SB 743 Senate Bill 743
SB 1383 Senate Bill 1383
SF6 sulfur hexafluoride
SHTAC Swainson’s Hawk Technical Advisory Committee
SJVAPCD San Joaquin Valley Air Pollution Control District SO2 sulfur dioxide
SOI Sphere of Influence
SR-168 State Route 168
SWPPP Stormwater Pollution Prevention Plan
SWQMP Storm Water Quality Management Program
SWRCB State Water Resources Control Board
TCRs Tribal Cultural Resources
USACE United States Army Corps of Engineers
USFWS United States Fish and Wildlife Service
USGS United States Geological Survey
UWMP Urban Water Management Plan
VHFHSZ very high fire hazard severity zone
VMT vehicle miles traveled
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1.0 PROJECT INFORMATION

1. Project Title:

Tract Map 6343

2. Lead Agency Name and Address:

City of Clovis
1033 Fifth Street
Clovis, CA 93612

3. Contact Person and Phone Number:

Lily Cha, Senior Planner
(559) 324-2335
[email protected]

4. Project Location:

Southwest of the intersection of East Behymer Avenue and North Sunnyside Avenue.

Assessor Parcel Numbers (APNs): 556-040-07S, 556-040-08S, 556-030-14S

5. Project Sponsor’s Name and Address:

Wilson Premier Homes, Inc.
7550 North Palm Avenue, Suite 102
Fresno, CA 93711

6. General Plan Designation:

Medium Density Residential

7. Zoning:

Exclusive Agricultural District (AE-20) (Fresno County)

8. Description of Project:

The proposed project would consist of the annexation of 246 acres by the City of Clovis (City), and the development of 590 residential lots in a 71.54-acre project site. Average lot size would be approximately 3,329 square feet. No development is proposed within the remaining 174.46- acre annexation area surrounding the project site. The proposed project would include annexation of the 246-acre area from Fresno County jurisdiction to the City. Any future development occurring within the annexation area would require a separate project-specific analysis.

The project site is located on the southwest quadrant of the intersection between East Behymer Avenue and North Sunnyside Avenue, as shown on Figure 1-1. The project site is located within the City of Clovis’ existing Sphere of Influence (SOI) and within the Northwest Urban Center area identified in the 2014 City of Clovis General Plan, now referred to as Heritage Grove. As such, this area is already planned and designated for urban growth and environmentally evaluated at 1067
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1 P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) -2 the programmatic level in the City’s General Plan Environmental Impact Report (EIR). 1 The
project site is currently being used for agriculture and contains one existing dwelling unit and associated structures. Parcel APN 556-030-14S of the project site is currently under a Williamson Act contract; however, a petition for a contract cancellation is currently in progress. The project site is bounded by East Behymer Avenue to the north, by the Enterprise Canal to the west and south, and by rural residential, a Fresno Metropolitan Flood Control District (FMFCD) ponding basin (Basin BY), and Tract Map 6200 to the east. Figure 1-2 shows the project site and surrounding land uses.

The proposed project would be developed over a period of approximately 33 months and over three Phases. There would also be 66 outlot spaces included in the proposed residential development. Although the site plan does not provide details on what would be constructed in these spaces, potential uses for the outlots would include private road, private parking, private pedestrian, private landscaping, public utility, and public park uses. The proposed project would include the removal of one existing 2,679-square-foot dwelling unit and garage, an existing propane tank, a 2,000-square-foot pole barn, two sheds of 1,785-square-foot and 2,250-squarefoot dimensions, and an existing driveway on the project site. Figure 1-3 shows the site plan for the proposed project.

Phase 1 of the proposed project would include the development of 136 single-family residential units with an average size of approximately 1,514 square feet per unit. Phase 1 would be located on the southern portion of the project site and would be accessed through one ingress and egress driveway located on Perrin Avenue. Phase 1 would include the construction of approximately 44 parking spaces, an approximately 8,745-square-foot community pool and recreation area, a approximately 13,930-square-foot community park, approximately 0.51 acre of landscaped areas, and drainage and pedestrian infrastructure improvements along Perrin Avenue. The southern extension of North Baron Avenue from East Behymer Avenue and the extension of Perrin Avenue and Hammel Avenue within the project site would be constructed during Phase 1. Figure 1-4 shows a site plan of Phase 1 of the proposed project.

Phase 2 of the proposed project would include the development of 214 single-family residential units with an average size of approximately 2,168 square feet per unit. Phase 2 would be located on the central portion of the project site and would be accessed through one gated ingress and egress driveway located along the future southern extension of North Baron Avenue, and one driveway along Hammel Avenue. Phase 2 would include the construction of a 26-foot-wide drainage channel along Perrin Avenue, approximately 0.35 acre of landscaped areas, and storm drainage and pedestrian infrastructure improvements along Perrin Avenue and Hammel Avenue. Figure 1-5 shows a site plan of Phase 2 of the proposed project.

Phase 3 of the proposed project would include the development of 240 single-family residential units with an average size of approximately 1,514 square feet per unit. Phase 3 would be located on the northern portion of the project site and would be accessed through two gated ingress 1 City of Clovis. 2014. General Plan and Development Code Update PEIR. Website: https://cityofclovis.com/ planning-and-development/planning/master-plans/general-plan/environmental-impact-report/ (accessed December 8, 2022).
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Phase 3 would include the construction of approximately 91 parking spaces, an approximately 9,985-square-foot pool and recreation area, approximately 0.65 acre of landscaped areas, and drainage and pedestrian infrastructure improvements along North Baron Avenue. Figure 1-6 shows a site plan of Phase 3 of the proposed project.

Water supply for the proposed project would be provided by the City of Clovis. The project would require the construction of a 24-inch water main along Behymer Avenue from Clovis Avenue to Baron Avenue. Additionally, the project would construct a 24-inch main along Baron Avenue, from Behymer Avenue to Perrin Avenue. The proposed improvements would be consistent with the City’s Water Master Plan and the City’s specifications on materials, depth, and resurfacing.

Wastewater services for the proposed project would be provided by the City of Clovis. The proposed project would connect to an existing wastewater main within the right-of-way of North Baron Avenue.

The FMFCD would provide flood control and urban storm water services to the project site.

Stormwater from the project site would be drained through surface and subsurface drainage infrastructure located along North Baron Avenue, Perrin Avenue, and Hammel Avenue as well as along internal roadways in the project site and redirected towards FMFCD Basin BY, which is located adjacent to the project site’s eastern boundary.

In addition, an approximately 1,300-foot-long, 26-foot-wide drainage channel would be constructed along the north side of the Perrin Avenue extension to direct stormwater flows west from the project site towards drainage infrastructure along the Enterprise Canal.

Storm drainage pipelines would be constructed along North Baron Avenue and along interior roadways in the project site to drain stormwater from the project site towards Basin BY. These storm drainage facilities would be constructed pursuant to requirements of the FMFCD Master Plan.

Solid waste collection for the project site would be provided by the City of Clovis, and recycling and green waste collection would be provided by Republic Services.

Electricity and natural gas services for the proposed project would be supplied by PG&E through connections to existing service lines. Telecommunication services to the project site would be provided by Comcast and AT&T.

Access to the project site would be provided by East Behymer Avenue and by a southern extension of North Baron Avenue, to be constructed during Phase 1 of the proposed project along the eastern boundary of the project site. The proposed project would construct approximately 2,650 feet of North Baron Avenue south of East Behymer to connect with the existing stretch of North Baron Avenue located southeast of the project site. This portion of North Baron Avenue would be approximately 49 feet wide and have two lanes. An 1069
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1 P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) -4 approximately 20-foot-wide parkway containing an approximately 6-foot-wide pedestrian sidewalk and landscaped areas would be included along the western side of North Baron Avenue along the project site. An approximately 16-foot-wide parkway containing an approximately 6-foot-wide pedestrian sidewalk and landscaped area that is reduced from the Heritage Grove Neighborhood Boulevard Street section would be included along the eastern side of North Baron Avenue, along the FMFCD Basin BY frontage. The eastern side of North Baron Avenue that is north of Basin BY will ultimately be built out with an approximately 20- foot-wide parkway, matching the Heritage Grove Neighborhood Boulevard Street section.

However, this section of the parkway will not be constructed with Tract 6343 in order to minimize the impact on the adjacent rural residential property. The pedestrian walk will continue north of Basin BY to East Behymer Avenue with Tract 6343, but will temporarily be constructed to share a combination pedestrian and widened bike lane as approved by the City Engineer with the project design plans.

To access the project site, three gated ingress and egress driveways would be constructed along the southern extension of North Baron Avenue. One gated ingress and egress driveway would also be constructed along Hammel Avenue. A temporary secondary access connecting Hammel Avenue to North Baron Avenue would be constructed along the northern end of Hammel Avenue during Phase 3. One gated ingress and egress driveway and one gated emergency access driveway would be constructed along Perrin Avenue.

Vehicle circulation within the project site would be provided by a network of two-way, 37.2- foot-wide private streets. Internal roadways within the project site would include Hammel Avenue, which is located along the project site’s western boundary, and Perrin Avenue, which crosses the project site west to east.

9. Surrounding Land Uses and Setting:

The 71.54-acre project site is located in the City of Clovis' SOI, within the Northwest Urban Center area identified in the City’s General Plan that is now referred to as Heritage Grove. The surrounding 246-acre annexation area encompasses the project site. The project site and annexation area include existing residential and agricultural uses. The project site and annexation area are surrounded by agricultural and single-family residential uses to the south, rural residential and agricultural uses to the east, agricultural and commercial uses to the west, and agricultural and rural residential uses to the north.

10. Other Public Agencies Whose Approval is Required (e.g., permits, financial approval, or participation agreements):
• County of Fresno/City of Clovis – Williamson Act Contract Cancellation • Fresno Local Agency Formation Commission – Annexation • State Water Resources Control Board – National Pollutant Discharge Elimination System (NPDES) General Permit (with requisite Storm Water Pollution Prevention Plan, Conceptual Storm Water Pollution Prevention Plan, and Permanent Control Measures) 1070
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11. Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resource Code section 21080.3.1? If so, is there a plan for consultation that includes, for example, the determination of significance of impacts to tribal cultural resources, procedures regarding confidentiality, etc.? In compliance with Assembly Bill 52 (AB 52), on November 4, 2022, the City sent letters regarding the proposed project to Big Sandy Rancheria of Western Mono Indians, Cold Springs Rancheria of Mono Indians, Dumna Wo-Wah Tribal Government, Kings River Choinumni Farm Tribe, North Fork Rancheria of Mono Indians, North Valley Yokuts Tribe, Picayune Rancheria of Chuckchansi Indians, Table Mountain Rancheria, Traditional Choinumni Tribe, Tule River Indian Tribe, and Wuksache Indian Tribe/Eshom Valley Band tribes based on the list of tribes provided by the Native American Heritage Commission (NAHC). Table Mountain Rancheria sent a response to the City on November 15, 2022, requesting the Cultural Resources Assessment2 prepared for the project, and did not request any further consultation. No further responses or requests for consultation were received by the City within the 30-day consultation period beginning November 4, 2022, and ending December 3, 2022. As such, AB 52 requirements for the proposed project have been fulfilled. AB 52 consultation request and response letters are included in Appendix A of this Initial Study.
2 Peak & Associates, Inc. 2022. Cultural Resource Assessment for the Tentative Tract Map 6343 and City of Clovis Annexation Area, County of Fresno, California. September 21. 1071
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Service Layer Credits: Sources: Esri, HERE,
Garmin, Intermap, increment P Corp.,

GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance
Survey, Esri Japan, METI, Esri China (Hong
Kong), (c) OpenStreetMap contributors, and

PERRIN RD

E BEHYMER AVE N MINNEWAWA AVE

UNINCORPORATED

FRESNO COUNTY

CITY OF
CLOVIS

E SHEPHERD AVE

N MINNEW

N MINNEWAWA AVE

N SUNNYSIDE AVE
SOURCE: Esri Streetmap (2021)
\\lsaazfiles.file.core.windows.net\images\CIT2201\GIS\MXD\Regional_Local_Context.mxd (12/6/2022) Tract Map 6343
Regional and Local Context
Madera
County
Fresno
County
Project
Location
Ã145
Ã180
Ã168
Ã41
Ã99
Project Vicinity
LEGEND
Project Location
Parcel Boundary
Annexation Boundary
Clovis City Limit 0 750 1500
FEET
FIGURE 1-1
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Nees Ave Nees Ave
W Teague Ave Teague Ave
Perrin Rd
E Shepherd Ave
E Behymer Ave N Minnewawa Ave
N Sunnyside Ave Sunnyside
A ve N Sunnyside Ave
N Dewi
Ʃ Ave N Dewi
Bloom Ave Enterprise Canal
Enterprise
Canal
Bloom Ave
N Preuss A ve N Preuss Ave
N Osmun A ve N Osmun Ave
Enterprise C anal
Enterprise Canal
E Shepherd Ave
E Behymer Ave
N Minnewawa Ave
Nees Ave Nees Ave
W Teague Ave Teague Ave
Perrin Rd
N Sunnyside Ave N Sunnyside
A ve N Sunnyside Ave

AGRICULTURE

AGRICULTURE

AGRICULTURE

RESIDENTIAL

RESIDENTIAL

AGRICULTURE
0 1000 2000
Project Site TM-6343 Boundary
AnnexaƟon Boundary
FEET
SOURCES: Google Earth 4/21/2021; LSA, 2022
I:\CIT2201\G\Aerial Photo of Site&Surrounding LU.ai (12/6/2022) FIGURE 1-2
Tract Map 6343
Aerial Photograph of the Project Site and Surrounding Land Uses 1075
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NOT TO SCALE
SOURCE: Harbor & Associates, January 2022:\CIT2201\G\General Site Plan.ai (9/22/2022) FIGURE 1-3
Tract Map 6343
General Site Plan
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Lorem
0 60 120
FEET
SOURCE: Harbor & Associates, January 2022:\CIT2201\G\South-Phase 1.ai (9/22/2022) FIGURE 1-4
Tract Map 6343
South: Phase 1
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FEET
SOURCE: Harbor & Associates, January 2022:\CIT2201\G\Central-Phase 2.ai (9/22/2022) FIGURE 1-5
Tract Map 6343
Central: Phase 2
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FEET
SOURCE: Harbor & Associates, January 2022:\CIT2201\G\North-Phase 3.ai (9/22/2022) FIGURE 1-6
Tract Map 6343
North: Phase 3
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2.0 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “Potentially Significant Impact” as indicated by the checklist in Chapter 3.0.

Aesthetics Agriculture and 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

2.1 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 agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.

I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.

I find that the proposed project MAY have a “Potentially Significant Impact” or “Potentially Significant Unless Mitigated” impact on the environment, 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 significant effects (a) have been analyzed adequately in an earlier ENVIRONMENTAL IMPACT REPORT or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier ENVIRONMENTAL IMPACT REPORT or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

Signature Date
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3.0 CEQA ENVIRONMENTAL CHECKLIST

3.1 AESTHETICS
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Except as provided in Public Resources Code Section 21099, would the project:
a. Have a substantial adverse effect on a scenic vista? b. Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway
c. In non-urbanized areas, 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 a 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?
d. Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?

3.1.1 Impact Analysis
a. Would the project have a substantial effect on a scenic vista? Less Than Significant Impact. A scenic vista is generally defined as a public vantage point with an expansive view of a significant landscape feature. The Open Space and Conservation Element of the City of Clovis’ General Plan identifies Clovis Avenue, Shaw Avenue, and Herndon Avenue as gateways to the community and important visual links to Old Town Clovis from the greater Fresno area. Other arterial roadways that travel east-to-west through the Clovis, such as Shepherd Avenue, Bullard Avenue, and Ashlan Avenue, span the community’s suburban/rural interface and therefore can also be construed as scenic corridors. These roadways provide a scenic and character transition through the nearly built-out core of Central Clovis into its pastoral agrarian areas to the north, east, and south.

The project site is currently undeveloped and used for agriculture. The project site is located in the vicinity of West Shepherd Avenue, one of the scenic corridors identified in the General Plan. The project site is also located within the City’s Northwest Urban Center, now referred to as Heritage Grove, which offers some of the most direct and unobstructed views of the Sierra Nevada and foothills in the City.3 The Heritage Grove area is specifically planned for urban growth. The proposed project would develop the 71.54-acre project site into a 590-lot single-family residential development. Although implementation of the proposed project would change the existing 3 City of Clovis. 2014. General Plan and Development Code Update PEIR. Aesthetics. Website:
https://cityofclovis.com/wp-content/uploads/2018/10/Chapter-05-01-Aesthetics.pdf (accessed April 14, 2022).
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3 P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) -2 agricultural land uses in the project site to a single-family residential use, the proposed residential use of the project site would be similar to existing residential uses south of the site, and therefore, the addition of single-family residences at the site would not substantially change views from public vista points. Additionally, the proposed single-family residences to be constructed at the project site would be consistent in size and scale to existing residential units in the vicinity of the project site and would not introduce oversized elements that could obstruct distant views of the Sierra Nevada and foothills.

Therefore, the proposed project would not have a substantial effect on scenic vistas in the vicinity of the project site, and the impact would be less than significant. This topic will not be discussed in the EIR.
b. 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. According to the California Department of Transportation (Caltrans) mapping of State Scenic Highways4
, there are no state-designated scenic highways in or near the City of Clovis.

However, State Route 168 (SR-168), an Eligible State Scenic Highway located approximately 2.5 miles south of the project site, bisects the City in a southwest to northeast direction.5 No Officially Designated or Eligible State Scenic Highways are located within or in the immediate vicinity of the project site. Therefore, the proposed project would not impact a designated or eligible State Scenic Highway or impact scenic resources located within the highway segments or its viewshed.

Therefore, no impact on scenic resources within a State Scenic Highway would occur as a result of the proposed project. This topic will not be discussed in the EIR. c. In non-urbanized areas, 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 a 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. The proposed project would include the construction of a 590-lot single-family residential development. The project site is currently undeveloped and used for agriculture, and it is surrounded by agricultural and single-family residential uses to the south, rural residential and agricultural uses to the east, agricultural and commercial uses to the west, and agricultural and rural residential uses to the north. The proposed project would change the agricultural use of the site to a residential use. Furthermore, the proposed project would introduce Single-Family Planned Residential Development (R-1-PRD) uses into a site zoned within the Exclusive Agricultural Zoning District (AE-20) of Fresno County.

The proposed project is located within Heritage Grove, a growth area identified for development in the City’s General Plan. The proposed project would require approval from Fresno County Local 4 California Department of Transportation (Caltrans). State Scenic Highways. Website: https://dot.ca.gov/ programs/design/lap-landscape-architecture-and-community-livability/lap-liv-i-scenic-highways (accessed May 12, 2022). 5 Ibid.
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P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) 3-3 Agency Formation Commission (Fresno LAFCo) for annexation to the City of Clovis. After annexation to the City, site zoning would be compatible with the proposed residential use of the proposed project. Additionally, the single-family residences to be constructed on the project site would be consistent in size and scale to existing residential units to the south of the project site.

Therefore, the proposed project would not conflict with applicable zoning or other regulations governing scenic quality in the City and would not substantially degrade the existing visual character or quality of public views of the project site and its surroundings, and the impact would be less than significant. This topic will not be discussed in the EIR. d. Would the project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Less Than Significant Impact. The proposed project would include the construction of 590 new single-family residential units within the project site, as well as landscaped, recreational, and utility areas. The construction of new buildings and infrastructure would introduce new sources of light into the project site and vicinity. Compliance with California Building Code (Title 24, California Code of Regulations) standards would reduce potential light and glare impacts. Furthermore, the City’s Development Code Update outlines performance standards related to exterior lighting to reduce impacts from new light sources under Article 3 (Development and Operational Standards), Section

9.22.050 (Exterior Light and Glare). Section 9.22.050 states the following:

A. Exterior Lighting

1. Exterior Lighting shall be:
a. Architecturally integrated with the character of on-site and adjacent structure(s);
b. Directed downward and shielded so that all direct light and glare is confined within the boundaries of the subject parcel;
c. Installed so that lights not blink, flash, or be of unusually high intensity or brightness. The blink and flash provision does not apply to allowed seasonal decorations in residential areas, 9.34.060(P). The unusually high intensity or brightness provision shall apply in all instances; and d. Appropriate in height, intensity, and scale to the uses they are serving.

2. Exterior lighting shall not:
a. Exceed 150 watts (or equivalent) or directly illuminate or be visible from adjacent properties.
b. Result in:
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3 P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) -4 1) Indirect illumination of adjacent properties in excess of 0.5 footcandles; 2) A point of overlap between light patterns greater than seven feet for pedestrian lighting systems; or
3) An intensity of lighting within the physical limits of an area required to be lighted that is greater than seven foot-candles.

B. Security Lighting. Security lighting shall be provided at all entrances/exits to structures. The minimum illumination shall be two footcandles at ground level in front of the entrance/exit.

C. Shielded Lighting. Light sources shall be shielded to direct light rays onto the subject parcel only. The light source, whether bulb or tube, shall not be directly visible from an adjacent property or public street rights-of-way. This Section does not apply to public street lighting, sign illumination, or traffic safety lighting.

Implementation of State and local policies and standards would reduce impacts associated with light and glare through the adoption and enforcement of development design standards. Additionally, the new sources of light and glare introduced by the proposed project would be comparable to the existing light and glare emitted by residential uses located south of the project site. Therefore, the adverse impacts related to light and glare resulting from the proposed project would be less than significant. This topic will not be discussed in the EIR. 1090
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3.2 AGRICULTURE AND FORESTRY RESOURCES
In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment Project; and the forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
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 nonagricultural use? b. Conflict with existing zoning for agricultural use, or a Williamson Act contract?
c. Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as
defined by Government Code Section 51104(g))?
d. Result in the loss of forest land or conversion of forest land to non-forest use?
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?

3.2.1 Impact Analysis
a. 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? Less Than Significant Impact. The project site is classified as “Unique Farmland” and “Farmland of Local Importance” by the California Department of Conservation Farmland Mapping and Monitoring Program (FMMP)6
. The proposed project would develop the 71.54-acre project site into a 590-lot single-family residential development. Therefore, development of the proposed project would result in the conversion of Unique Farmland and Farmland of Local Importance to a non-agricultural use. 6 California Department of Conservation. 2016. California Important Farmland Finder. Website:
https://maps.conservation.ca.gov/DLRP/CIFF/ (accessed April 14, 2022). 1091
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3 P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) -6 The City of Clovis General Plan identifies that build out of the General Plan would result in a significant unavoidable impact related to the conversion of Important Farmland to non-agricultural uses.

Mitigation Measure 2-1 of the General Plan EIR addresses conversion of important farmland associated with build out of the General Plan, and requires project applicants for properties that include 20 acres or more of designated Prime Farmland, Farmland of Statewide Importance, or Unique Farmland to prepare or fund an agricultural resource evaluation, such as a Land Evaluation and Site Assessment (LESA) Model, prior to project approval. The Senate Bill 2 (SB 2) Farmland Impact Assessment7 prepared for the City of Clovis prepared a LESA Model for the Heritage Grove growth area, which includes the project site, and concluded that conversion of farmland in the Heritage Grove growth area would result in significant unavoidable impacts to important farmland, consistent with the determination of the General Plan EIR.

Additionally, Mitigation Measure 2-1 requires that if farmland conversion is deemed significant, the City would require mitigation at a 1:1 ratio of converted to preserved acreage, or payment of its valuation equivalent if a fee mitigation program is established, or mitigation through a regional agricultural preservation program, if applicable. However, the General Plan EIR does state that even with implementation of Mitigation Measure 2-1, conversion of farmland through build out of the General Plan would represent a significant unavoidable impact. As such, farmland conversion covered under the General Plan cannot be mitigated.

Figure 5.2-5 in the Agriculture and Forestry section of the General Plan EIR identifies the location of Important Farmland in the City’s Planning Area to be converted by buildout of the General Plan.8 Sections of the proposed project currently used for agricultural activities are included among the Important Farmland to be converted by buildout of the General Plan. Additionally, the proposed project is located within Heritage Grove, a growth area identified for development in the General Plan. Development of the proposed project would be consistent with planned growth under the General Plan, and therefore, would not result in unplanned impacts to Important Farmland.

Therefore, a less than significant impact would occur. This topic will not be discussed in the EIR. b. Would the project conflict with existing zoning for agricultural use, or a Williamson Act contract? Less Than Significant Impact. The project site is zoned within the Exclusive Agricultural Zoning District (AE-20) of Fresno County. In addition, the project site contains APN 556-030-14S, which is currently under a Williamson Act contract. Following approval of the proposed project and certification of the EIR, the City and Project Applicant will apply to have the project site and annexation area annexed into the City of Clovis and cancellation of the Williamson Act contract, respectively.
7 LSA Associates, Inc. 2022. Farmland Impact Assessment, Heritage Grove SB 2 Grant Technical Studies Project, City of Clovis, California. February 2022. 8 City of Clovis. 2014. General Plan and Development Code Update PEIR. Agriculture and Forestry Resources. Figure 5.2-5: Important Farmland Converted at General Plan Buildout. Website:
https://cityofclovis.com/wp-content/uploads/2018/10/Chapter-05-02-Agriculture-and-ForestryResources.pdf (accessed July 7, 2022). 1092
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P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) 3-7 As noted in the SB 2 Farmland Impact Assessment prepared for the City for the Heritage Grove Growth Area, APN 556-030-014S (the project site) is currently under a Williamson Act contract. A petition for cancellation and statutory findings to support cancellation of the Williamson Act contract would need to be submitted by the Project Applicant as set forth under Government Code Section 51282(a). Additionally, payment of a cancellation fee equal to 12.5 percent of the unrestricted market value of the parcel is required as set forth under Government Code Section 51283(b). The cancellation process for APN 556-030-014S will be completed prior to development of the proposed project.

After annexation of APN 556-030-14S to the City of Clovis and cancellation of the Williamson Act contract, the parcel could develop uses that comply with the zoning designation of the parcel per the City’s Zoning Code without the proposed development being inconsistent with a Williamson Act contract.

Furthermore, the City’s General Plan identified a significant and unavoidable impact related to conversion of agricultural land uses in the Heritage Grove area to non-agricultural use. As a result, the potential impacts related to conflicts with existing zoning for agricultural use or a Williamson Act contract have been previously addressed in the General Plan EIR, and this project would not result in a new impact. As a result, a less-than-significant impact would occur. This topic will not be discussed in the EIR.
c. Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?
No Impact. The project site is zoned within the Exclusive Agricultural Zoning District (AE-20) of Fresno County. The project site is not currently used for timberland production, nor is it zoned for forest land or timberland. No forest lands or timberland are located on the project site. The proposed project would not conflict with the existing zoning for, or cause rezoning of forest land or conversion of forest land to non-forest uses. Therefore, the proposed project would have no impact on forest land or timberland. This topic will not be discussed in the EIR. d. Would the project result in the loss of forest land or conversion of forestland to non-forest use? No Impact. Please refer to the discussion for c) above. The proposed project would not result in the loss of forest land or conversion of forest land to non-forest uses. Therefore, the proposed project would have no impact. This topic will not be discussed in the EIR. e. Would the project 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?
Less Than Significant Impact. Please refer to discussions a) and c) of this section. The project site is not used for timberland production or zoned for forest land or timberland. The project site is classified as “Unique Farmland” and “Farmland of Local Importance” by the California Department 1093
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3 P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) -8 of Conservation FMMP. The proposed project would result in the conversion of farmland to nonagricultural uses. However, conversion of farmland resulting from the proposed project has already been identified in the General Plan EIR, and it would be consistent with planned growth in the City of Clovis under the General Plan. As a result, the proposed project would not result in the conversion of forestland or timberland, or the unplanned conversion of farmland beyond what has been identified by the General Plan. Therefore, the impact would be less than significant. This topic will not be discussed in the EIR.
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3.3 AIR QUALITY
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations.

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
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 nonattainment under an applicable federal or state ambient air quality standard?
c. Expose sensitive receptors to substantial pollutant
concentrations?
d. Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?

3.3.1 Impact Analysis
The proposed project is in the City of Clovis’ existing Sphere of Influence and northwest planned growth area. The project falls within the jurisdiction of the San Joaquin Valley Air Pollution Control District (SJVAPCD). The SJVAPCD is responsible for air quality regulation within the eight-county San Joaquin Valley region.

Both the California Air Resources Board (CARB) and the United States Environmental Protection Agency (EPA) have established health-based Ambient Air Quality Standards for six criteria air pollutants: carbon monoxide (CO), ozone (O3), nitrogen dioxide (NO2), sulfur dioxide (SO2), lead (Pb), particulate matter less than 10 microns in size (PM10), and particulate matter less than 2.5 microns in size (PM2.5). These standards are designed to protect the health and welfare of the populace with a reasonable margin of safety. Two criteria pollutants, O3 and NO2, are considered regional pollutants because they (or their precursors) affect air quality on a regional scale. Pollutants such as PM, CO, SO2, and Pb are considered local pollutants because they tend to accumulate in the air locally. The San Joaquin Valley Air Basin (Air Basin) is under State non-attainment status for ozone and particulate matter (PM10 and PM2.5) standards. The Air Basin is also classified as non-attainment for both the federal ozone 8-hour standard and the federal PM2.5 24-hour standard.

A threshold of significance is defined by the SJVAPCD in its Guidance for Assessing and Mitigating Air Quality Impacts (GAMAQI) as an identifiable quantitative, qualitative, or performance level of a particular environmental effect. Non-compliance with a threshold of significance means the effect will normally be determined to be significant. Compliance with a threshold of significance means the effect normally will be determined to be less than significant. The SJVAPCD has established 1095
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Table 3.A: SJVAPCD Construction and Operation Thresholds of Significance (tons/yr)
CO NOX ROG SOX PM10 PM2.5
Construction Thresholds 100 10 10 27 15 15
Operation Thresholds 100 10 10 27 15 15
Source: Guidance for Assessing and Mitigating Air Quality Impacts (SJVAPCD 2015a.) CO = carbon monoxide
NOX = oxides of nitrogen
PM10 = particulate matter less than 10 microns in size
PM2.5 = particulate matter less than 2.5 microns in size ROG = reactive organic gas
SJVAPCD = San Joaquin Valley Air Pollution Control District SOX = oxides of sulfur
tons/yr = tons per year
The emissions thresholds in the SJVAPCD GAMAQI were established based on the attainment status of the air basin in regard to air quality standards for specific criteria pollutants. Because the concentration standards were set at a level that protects public health with an adequate margin of safety, these emission thresholds are regarded as conservative and would overstate an individual project’s contribution to health risks.
a. Would the project conflict with or obstruct implementation of the applicable air quality plan? Potentially Significant Impact. The California Environmental Quality Act (CEQA) requires that certain proposed projects be analyzed for consistency with the applicable air quality plan. An air quality plan describes air pollution control strategies to be implemented by a city, county, or region classified as a non-attainment area. The main purpose of the air quality plan is to bring the area into compliance with the requirements of the federal and State air quality standards. To bring the Air Basin into attainment, the SJVAPCD adopted the 2016 Plan for the 2008 8-Hour Ozone Standard in June 2016 to satisfy Clean Air Act requirements and ensure attainment of the 75 parts per billion (ppb) 8-hour ozone standard.10
To assure the Air Basin’s continued attainment of the EPA PM10 standard, the SJVAPCD adopted the 2007 PM10Maintenance Plan in September 2007. SJVAPCD Regulation VIII (Fugitive PM10 Prohibitions) is designed to reduce PM10 emissions generated by human activity. The SJVAPCD adopted the 2016 Moderate Area Plan for the 2012 PM2.5 standard to address the EPA federal annual PM2.5 standard of 12 micrograms per cubic meter (µg/m3 ), established in 2012. In addition,
the SJVAPCD is in the process of developing an attainment strategy to address multiple PM2.5 9 San Joaquin Valley Air Pollution Control District. 2015b. Air Quality Thresholds of Significance – Criteria Pollutants. Website: http://www.valleyair.org/transportation/0714-GAMAQI-Criteria-PollutantThresholds-of-Significance.pdf (accessed on April 14, 2022). 10 San Joaquin Valley Air Pollution Control District. 2016. 2016 Plan for the 2008 8-Hour Ozone Standard.

Website: www.valleyair.org/Air_Quality_Plans/Ozone-Plan-2016.htm (accessed April 14, 2022). 1096
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For a project to be consistent with SJVAPCD air quality plans, the pollutants emitted from a project should not exceed the SJVAPCD emission thresholds or cause a significant impact on air quality.

Construction and operation of the proposed project may result in an increase in air pollutant emissions. As a result, the proposed project could have a potential adverse effect on the SJVAPCD’s implementation of clean air plans. Therefore, the EIR will provide further analysis of the proposed project’s consistency with the SJVAPCD’s clean air plans. b. Would the project 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?
Potentially Significant Impact. CEQA defines a cumulative impact as two or more individual effects, which when considered together, are considerable or which compound or increase other environmental impacts. Therefore, if annual emissions of construction- or operational-related criteria air pollutants exceed any applicable threshold established by the SJVAPCD, the proposed project would result in a cumulatively significant impact.

Short-term emissions would occur in association with construction activities, including grading, and vehicle/equipment use. Long-term operational emissions are associated with stationary sources and mobile sources. Stationary source emissions result from the consumption of natural gas and electricity. Mobile source emissions result from vehicle trips and result in air pollutant emissions affecting the entire air basin. As noted above, specific criteria for determining whether the potential air quality impacts of a project are significant are set forth by the SJVAPCD.

Construction and operation of the proposed project would result in the emission of air pollutants in the Air Basin, which is currently in non-attainment for federal and State air quality standards.

Therefore, implementation of the proposed project could potentially contribute to air quality impacts, which could cause a cumulative impact in the Air Basin. Therefore, the EIR will provide further analysis of cumulative air pollutant emissions associated with the project. c. Would the project expose sensitive receptors to substantial pollutant concentrations? Potentially Significant Impact. Sensitive receptors are defined as residential uses, schools, daycare centers, nursing homes, and medical centers. Exposure from diesel exhaust associated with construction activity contributes to both cancer and chronic non-cancer health risks. The closest potentially sensitive receptors to the project site include residential uses located directly adjacent to the project site’s eastern boundary and residential uses that are currently under construction south of the project site.

Construction of the proposed project may expose surrounding sensitive receptors to airborne particulates, as well as a small quantity of construction equipment pollutants (i.e., usually dieselfueled vehicles and equipment). Therefore, the EIR will provide further analysis of air pollutant emissions associated with the proposed project.
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3 P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) -12 d. Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Less Than Significant Impact. During construction of the proposed project, the various dieselpowered vehicles and equipment in use on site and off site would create localized odors. These odors would be temporary and are not likely to be noticeable for extended periods of time beyond the project site. The potential for diesel odor impacts is therefore considered less than significant. In addition, the proposed uses that would be developed within the project site are not expected to produce any offensive odors that would result in frequent odor complaints. The proposed project would not create objectionable odors affecting a substantial number of people during project construction or operation, and this impact would be less than significant. This topic will not be discussed in the EIR.
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3.4 BIOLOGICAL RESOURCES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
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 Wildlife or U.S. Fish and Wildlife Service?
b. Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
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?
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?
e. Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
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?
Argonaut Ecological Consulting conducted a Biological Resource Assessment11 (BRA) to assess potential impacts of the proposed project on biological resources. The following methodology was utilized to assess the biological study area of the proposed project:
• Data and Literature Review: Documents and sources of information used to prepare this evaluation include the following:
○ United States Department of Agriculture, Natural Resources Conservation Service, Soil Survey of Fresno Area (Soils Mapper)
○ Aerial photography (Google Earth®, Bing®, and historic aerials) ○ California Department of Fish and Wildlife (CDFW), California Natural Diversity Database (CNDDB/RareFind – Recent version with updates)
11 Argonaut Ecological Consulting. 2022. Biological Resources Assessment – Tentative Tract 6343 and City of Clovis Annexation Area. September 26.
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3 P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) -14 ○ CDFW Open Data Portal, ArcGIS GeoService
○ United States Fish and Wildlife Service (USFWS), National Wetland Inventory Map ○ USFWS Information for Planning and Consultation (IPaC). ○ United States Geological Survey (USGS), Historical Topographic Map, Clovis and Friant Quadrangles, 1919, University of Texas, Austin, Perry-Castañeda Map Collection Prior to review of the project site, the CNDDB/RareFind and the USFWS IPaC were consulted to determine the species potentially present within the biological study area based on location. • Aerial Photography and Wetland Mapping: Historical aerial photographs dating from the 1980s of the biological study area were reviewed to identify site features and determine land use changes over time. Wetland mapping and aerial photographs were also reviewed to determine if the biological study area recently supported wetlands. • Field Survey: A field survey was conducted on the project site on August 6 and 7, 2022. The project site was walked, and habitat features mapped. Review of the annexation area of the proposed project included a combination of observation from public roads, and limited foot surveys of accessible areas. Soils, vegetation, and drainage patterns within the biological study area were inspected to determine the habitat present and suitability for species of concern.

3.4.1 Impact Analysis
a. 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 Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
Less Than Significant with Mitigation Incorporated. The proposed project would result in the construction of a 590-lot residential development for single-family residences in the approximately

71.54-acre site located in the Heritage Grove area.

The project site is currently dominated by ruderal species and by nonnative grassland previously used for cattle grazing. No special‐status plant species are expected to occur within the project site or to be adversely affected by the proposed project. While no special‐status animal species (or signs of such species) were observed on site during the August 2022 survey, eight existing trees surrounding the existing residential unit within the project site could provide suitable nesting habitat for a variety of birds, including Swainson’s hawk (Buteo swainsoni). Additionally, there is potential for the western burrowing owl (Athene cunicularia) to nest in old pipelines around the existing residential unit or along the Enterprise Canal. No suitable habitat for any other specialstatus species occurs in the project site. Potentially significant direct and indirect impacts, including mortality, harassment, or other forms of incidental take, could occur during proposed removal of existing trees and the exiting residential unit in the project site and due to site disturbance associated with construction activities. Mitigation Measures BIO-1 through BIO-4, outlined below, 1100
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As such, the proposed project would not 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 CDFW or USFWS. The impact would be less than significant with mitigation, and this topic will not be discussed in the EIR.

Mitigation Measure BIO‐1 Nesting Bird Surveys and Active Nest Avoidance. Any initial ground disturbance or tree pruning, or removal should take place outside of the active nesting bird season (i.e., February 1–September 30), when feasible, to avoid impacts to nesting birds protected under the California Fish and Game Code and Migratory Bird Treaty Act.

Should phased construction require tree removal or initial ground disturbance to ruderal areas, a qualified biologist shall conduct a nesting bird survey no more than 15 days prior to each phase of clearing activities. If nesting birds are discovered during preconstruction surveys, the biologist shall identify an appropriate buffer where no clearing, grading, or construction activities with potential to have direct or indirect impacts on the nesting bird(s) are allowed to take place until after the nest is no longer active (e.g., the young birds have fledged), or as otherwise determined by the qualified biologist.

Mitigation Measure BIO-2 Conduct Surveys for Swainson’s Hawk Nests and Implement Avoidance and Minimization Measures. The qualified biologist will conduct surveys for Swainson’s hawk (Buteo swainsoni) during the nesting season (February 1 to August 31) along the existing trees within the project site. No sooner than 30 days prior to any ground disturbing activity, the qualified biologist will conduct preconstruction surveys of nests identified during the earlier surveys to determine if any are occupied. The initial nesting season surveys and subsequent preconstruction nest surveys will follow the protocols set out in the Recommended Timing and Methodology for Swainson’s Hawk Nesting Surveys in California’s Central Valley (Swainson’s Hawk Technical Advisory Committee [SHTAC] 2000) or guidance current at the time of project implementation. Available database records will be used to support the survey.

Any active Swainson’s hawk nests (defined as a nest used one or more times in the last 5 years) found within the existing trees on site during the nesting season will be monitored daily by the qualified biologist to assess whether the nest is occupied. If the nest is occupied, the qualified biologist will establish no-work buffers following California Department of Fish and Game’s 1994 Staff Report Regarding Mitigation for Impacts to Swainson’s Hawks (Buteo swainsoni) in the Central Valley of California, and the status 1101
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3 P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) -16 of the nest will be monitored until the young fledge or for the length of construction activities, whichever occurs first.

Adjustments to the buffer(s) may be made in consultation with the California Department of Fish and Wildlife (CDFW).

If an occupied Swainson’s hawk nest site is to be removed, an incidental take permit under the California Endangered Species Act (CESA) will be obtained, and impacts will be minimized through permitting with the CDFW and fully mitigated.

Mitigation Measure BIO-3 Conduct Pre-construction Clearance Surveys for Burrowing Owl. A pre-construction clearance survey will be conducted in the vicinity of the existing residence on site, as well as within the disturbed annual grassland and embankments of the Enterprise No. 109 Canal by a qualified biologist for burrowing owl (Athene cunicularia) no more than 30 calendar days prior to initiation of ground disturbance activities. All surveys will follow the California Department of Fish and Game 2012 Staff Report on Burrowing Owl Mitigation
methodology, or guidance current at the time of project implementation, and results shall be delivered to CDFW and the City of Clovis. If the survey results find an active burrow, the Project Applicant must coordinate with the CDFW to obtain applicable agency approval/permit prior to any ground disturbance activities on the site.

Mitigation Measure BIO-4 Passive Relocation Measures for Burrowing Owl. If burrowing owl (Athene cunicularia) are detected during the pre-construction surveys, occupied burrows will not be disturbed during the nesting season (February 1 through August 31 for owls and other raptors).

The non-disturbance buffer will include a minimum 330-foot (100- meter) buffer zone around any occupied burrow unless a qualified biologist approved by the CDFW verifies through non-invasive methods that either (1) burrowing owls have not begun egg laying and incubation, or (2) juveniles from the occupied burrows are foraging independently and are capable of independent survival.

The sizes of individual buffers may be modified through coordination with the CDFW based on site-specific conditions and existing disturbance levels. During the non-nesting season or if the qualified biologist determines either (1) or (2) above, the Project Applicant will coordinate with the CDFW to construct artificial burrows and passively relocate the owl(s). Passive relocation is defined as encouraging owls to move from occupied burrows to alternate natural or artificial burrows that are beyond approximately 160 feet (50 meters) from the impact zone and that are within or contiguous to a minimum of 6.5 acres of foraging 1102
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If passive relocation is required, a qualified biologist shall prepare a Burrowing Owl Exclusion and Mitigation Plan and Mitigation Land Management Plan in accordance with the CDFW 2012 Staff Report on Burrowing Owl Mitigation and for review by CDFW prior to passive relocation activities. Owls shall be excluded from burrows in the immediate impact zone and within an approximately 160-foot (50-meter) buffer zone by installing one-way doors in burrow entrances. One-way doors shall be left in place for 48 hours to ensure owls have left the burrow before excavation. One alternate natural or artificial burrow shall be provided for each burrow that will be excavated in the project impact zone. The project site shall be monitored daily for 1 week to confirm owl use of alternate burrows before excavating burrows in the immediate impact zone.

Whenever possible, burrows shall be excavated using hand tools and refilled to prevent reoccupation. Sections of flexible plastic pipe or burlap bags shall be inserted into the tunnels.
b. Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Less Than Significant Impact. No riparian habitat or other sensitive natural communities have been identified within the project site. The project site is disturbed from past agricultural activities, and mainly contains ruderal vegetation and nonnative grassland. As such, the proposed project would not have substantial adverse effects on riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the CDFW or USFWS, and the impact would be less than significant. This topic will not be discussed in the EIR. c. Would the project 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?
Less Than Significant with Mitigation Incorporated. The proposed project would result in the construction of a 590-lot residential development for single-family residences in an approximately

71.54-acre site in the Heritage Grove area.

The main aquatic feature in the vicinity of the project site is Enterprise No. 109 Canal (Enterprise Canal), an irrigation canal managed by the Fresno Irrigation District. Enterprise No. 109 Canal does not meet the current definition of a jurisdictional water of the United States and does not meet the wetland criteria wetland criteria outlined in the State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State, which excludes agricultural ditches with ephemeral flow that are not a relocated water of the state or excavated in a water of the state. 1103
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3 P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) -18 Nevertheless, the Enterprise No. 109 Canal may fall within the jurisdiction of CDFW under Section 1602 of the California Fish and Game Code and the Regional Water Quality Control Board (RWQCB) under the California Water Code (e.g., the Porter-Cologne Water Quality Control Act). Furthermore, given the recent substantial changes in operable definitions that have occurred and may continue to occur, and considering the regulatory revisions and potential court actions, it is not possible to definitively predict the regulations that will be in place at the time of a particular jurisdictional determination or permit action by the United States Army Corps of Engineers (USACE). Under currently effective Clean Water Act regulations and guidance, the USACE reserves the right to regulate certain resources on a case-by-case basis. Therefore, Regulatory Compliance Measure BIO-1 is recommended. Implementation of this measure would reduce potential impacts to protected wetlands to less than significant.

As such, the proposed project would not have a substantial adverse effect on state or federally protected wetlands, and the impact would be less than significant with mitigation. This topic will not be discussed in the EIR.

Regulatory Compliance Measure BIO-1 Agency Coordination for Enterprise No. 109 Canal.

Prior to any modifications to Enterprise No. 109
Canal, it is recommended to consult with the United
States Army Corps of Engineers (USACE), California
Department of Fish and Wildlife (CDFW), and
Regional Water Quality Control Board (RWQCB) to
verify the feature’s jurisdictional status and obtain
applicable permit(s) and/or authorization(s). If
direct modifications to the canal are proposed, a
notification of streambed alteration shall be
submitted to the CDFW in accordance with Section
1602 of the California Fish and Game Code. Unless
categorically excluded under effective definitions or
existing documentation confirms that no permit is
needed, the Central Valley RWQCB and Sacramento
District of the USACE shall be consulted regarding
potential permitting needs under the California
Water Code and federal Clean Water Act,
respectively, associated with the proposed
Enterprise No. 109 Canal modifications.
d. 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?
Less Than Significant Impact. The project site is disturbed from past agricultural activities, and mainly contains ruderal vegetation and nonnative grassland. Based on field observations and the location of the project site, there are no indications that the project site functions as a wildlife movement corridor, or an important stopover point for migratory species. The wildlife species that occur in the vicinity of the project site are adapted to the urban‐wildland interface. The noise, 1104
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P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) 3-19 vibration, light, dust, or human disturbance within construction areas would only temporarily deter wildlife from using areas in the immediate vicinity of construction activities. The proposed project would not place any permanent barriers within any known wildlife movement corridors or interfere with habitat connectivity.

Existing trees on site could provide limited nesting habitat to native and migratory bird species, including Swainson’s hawk. Furthermore, there is limited potential for Burrowing owls nesting in the vicinity of the existing residential unit onsite, as well as the vicinity of Enterprise No. 109 Canal.

Breeding‐season disturbance that causes nest abandonment and/or loss of reproductive effort is considered a form of take by the CDFW. Implementation of Mitigation Measures BIO-1 through BIO-4 would ensure that take of nesting migratory bird species, as well as of special-status species such as Swainson’s hawk and burrowing owl, is avoided.

As such, the proposed project would not 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. The impact would be less than significant. This topic will not be discussed in the EIR. e. 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 Clovis Development Code includes tree protection standards for any trees that may need to be removed during construction. Compliance with the tree protection standards of the Clovis Municipal Code would require the replacement of trees and/or payment of in-lieu fees. The project would be required to comply with the tree protection ordinance; therefore, the impact would be less than significant.
f. 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 PG&E San Joaquin Valley Operation and Maintenance (O&M) Habitat Conservation Plan (HCP) was approved in 2007 and covers portions of nine counties, including Fresno County. This HCP covers PG&E activities that occur as a result of ongoing O&M that would have an adverse impact on any of the 65 covered species and provides incidental take coverage from the USFWS and CDFW. The project site is not located within the covered area of any approved or draft HCP, Natural Communities Conservation Plan (NCCP), or other adopted local, regional or State HCP. Therefore, the proposed project would not conflict with the provisions of the PG&E HCP, and the proposed project would have no impact. This topic will not be discussed in the EIR. 1105
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3.5 CULTURAL RESOURCES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a. Cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
b. Cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
c. Disturb any human remains, including those interred outside of formal cemeteries?
Peak & Associates, Inc. prepared a Cultural Resource Assessment (CRA)12 for the proposed project to assess potential impacts to cultural resources. The following discussion summarizes the methodology and results of the study:
• Southern San Joaquin Valley Information Center: A record search of the study area for the proposed project and a 0.25-mile search radius was conducted on through the Southern San Joaquin Valley Information Center (SSJVIC) of the California Historical Resources Information System (CHRIS) on September 6, 2022 (SSJVIC Records Search File No. 22-334).

The record search results indicated that no portion of the project site has ever been previously surveyed for cultural resources. Two resources were identified within the study area: a waste disposal site (P-10-006461) found during excavation for a utility pole in the northeast corner of the annexation area in 2015, and the Enterprise Canal, recorded as P-FRE-3564-H. Within the

0.25-mile radius search, six historic period resources have been recorded. • Field Survey: On September 14, 2022, and September 15, 2022, Peak & Associates, Inc. staff conduced a field survey of the project site. The project site was walked on its entirety and surveyed.
• Results: No features or artifacts of historical or prehistoric nature were observed in the project site during the field survey. The existing residential unit onsite is less than 50 years old and would not be considered a historical resource.

3.5.1 Impact Analysis
a. Would the project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
Less Than Significant with Mitigation Incorporated. A historical resource defined by CEQA includes one or more of the following criteria: (1) the resource is listed, or found eligible for listing in, the California Register of Historical Resources (California Register); (2) listed in a local register of 12 Peak & Associates, Inc. 2022. Cultural Resource Assessment for the Tentative Tract Map 6343 and City of Clovis Annexation Area, County of Fresno, California. September 21. 1106
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P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) 3-21 historical resources as defined by Public Resources Code (PRC) Section 5020.1(k); (3) identified as significant in a historical resources survey meeting the requirements of PRC Section 5024.1(g); or (4) determined to be a historical resource by the project’s lead agency (PRC Section 21084.1; CEQA Guidelines Section 15064.5(a)). Under CEQA, historical resources include built-environment resources and archaeological sites.

The proposed project would result in the construction of a 590-lot residential development for single-family residences. According to the CRA for the project, no historical resources were identified within the project site during the record search or field survey. However, development of previously undeveloped land in the City could result in the discovery of previously unknown historical resources.

To reduce potential impacts on potentially undiscovered historical resources in the project site, Mitigation Measure CUL-1 shall be implemented. This mitigation measure would reduce potential impacts to undiscovered resources to a less than significant level by consulting with a qualified historical resources specialist and implementing applicable mitigation measures to protect resources found during project construction. This topic will not be discussed in the EIR.

Mitigation Measure CUL-1 Consultation with Qualified Historical Specialist for Resources Found During Project Construction. If previously unknown resources are encountered before or during grading activities, construction shall stop within 50 feet of the find and a qualified historical resources specialist shall be consulted to determine whether the resource requires further study.

The qualified historical resources specialist shall make recommendations to the City of Clovis on the measures that shall be implemented to protect the discovered resources, including but not limited to excavation of the finds and evaluation of the finds in accordance with Section 15064.5 of the CEQA Guidelines.

If the resources are determined to be unique archeological resources as defined under Section 15064.5(c)(1) of the CEQA Guidelines, measures shall be identified by a qualified archaeologist meeting the Secretary of the Interior’s Professional Qualifications Standards for Archaeology and recommended to the Lead Agency.

Appropriate measures for significant resources could include avoidance or capping, incorporation of green space, parks, or open space in undeveloped areas of the project site, or data recovery excavations of the finds.

No further grading shall occur in the area of the discovery until the Lead Agency approves the protection measures. Any historical artifacts recovered as a result of mitigation shall be provided to a City of Clovis-approved institution or person who is capable of providing long-term preservation to allow future scientific study. 1107
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3 P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) -22 A report of findings shall also be submitted to the Southern San Joaquin Valley Information Center .
b. Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
Less Than Significant with Mitigation Incorporated. Pursuant to CEQA Guidelines Section 15064.5(c)(1), “When a project will impact an archaeological site, a lead agency shall first determine whether the site is an historical resource...” Those archaeological sites that do not qualify as historical resources shall be assessed to determine if they qualify as “unique archaeological resources” pursuant to California PRC Section 21083.2. Archaeological cultural resources identified during project construction shall be treated by the City in consultation with a qualified archaeologist meeting the Secretary of the Interior’s Professional Qualifications Standards for Archaeology, and in accordance with Mitigation Measure CUL-1 as identified above in Section 3.5.a. With implementation of these measures, impacts to archaeological resources would be less than significant. This topic will not be discussed in the EIR. c. Would the project disturb any humans remains, including those interred outside of formal cemeteries?
Less Than Significant with Mitigation Incorporated. Disturbance of human remains interred outside of formal cemeteries would result in a significant impact. If human remains are identified during project construction, Section 7050.5 of the California Health and Safety Code and PRC Section 5097.98 shall apply, as appropriate. Furthermore, implementation of Mitigation Measure CUL-2 would ensure compliance with applicable laws and regulations pertaining treatment and disposition human remains, reducing potential impacts on unknown human remains to a less than significant level. This topic will not be included in the EIR.

Mitigation Measure CUL-2 In the event that human remains are unearthed during excavation and grading activities of any future development project, all activity shall cease immediately. Pursuant to Health and Safety Code Section 7050.5, no further disturbance shall occur until the County Coroner has made the necessary findings as to origin and disposition pursuant to Public Resources Code (PRC) Section 5097.98(a). If the remains are determined to be of Native American descent, the coroner shall within 24 hours notify the Native American Heritage Commission (NAHC). The NAHC shall then contact the most likely descendant of the deceased Native American, who shall then serve as the consultant on how to proceed with the remains.

Pursuant to PRC Section 5097.98(b), upon the discovery of Native American remains, the Project Applicant shall ensure that the immediate vicinity, according to generally accepted cultural or archaeological standards or practices, where the Native American human remains are located is not damaged or disturbed by further 1108
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3.6 ENERGY
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a. Result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation? b. Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?

3.6.1 Impact Analysis
a. 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 proposed project would be constructed using energy-efficient modern building materials and construction practices, and the proposed project also would use new modern appliances and equipment, in accordance with the Appliance Efficiency Regulations (Title 20, California Code of Regulations [CCR] Sections 1601 through 1608). The expected energy consumption during construction and operation of the proposed project would be consistent with typical usage rates for residential uses in the Clovis; however, energy consumption is largely a function of personal choice and the physical structure and layout of buildings. It can be assumed that implementation of the proposed project would result in additional energy demand in Clovis.

The proposed project would be required to comply with the City’s energy efficiency policies, including Policies 3.5, 3.6, and 3.7 from the Open Space and Conservation Element of the General Plan as follows:

Policy 3.5: Energy and Water Conservation. Encourage new development and substantial rehabilitation projects to exceed energy and water conservation and reduction standards set in the California Building Code.

Policy 3.6: Renewable Energy. Promote the use of renewable and sustainable energy sources to serve public and private sector development.

Policy 3.7: Construction and design. Encourage new construction to incorporate energy efficient building and site design strategies.

Therefore, the proposed project would not result in wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation. As such, the proposed project would have a less than significant impact. This topic will not be discussed in the EIR. 1110
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P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) 3-25 b. Conflict with or obstruct a state or local plan for renewable energy or energy efficiency? Less Than Significant Impact. As discussed in a) above, the proposed project would be required to comply with the Appliance Efficiency Regulations (Title 20, CCR Sections 1601 through 1608) and with General Plan policies for energy efficiency and conservation. The proposed project would also be required to implement the California Green Building Standards Code (CALGreen Code) (CCR Title 24, Part 11) and the California Energy Code (CCR Title 24, Part 6), which include provisions related to insulation and design aimed at minimizing energy consumption. Therefore, the proposed project would comply with State and local policies plan for renewable energy or energy efficiency, and the impact would be less than significant. This topic will not be discussed in the EIR. 1111
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3.7 GEOLOGY AND SOILS
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
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? Refer to Division of Mines and Geology Special Publication 42.
ii. Strong seismic ground shaking?
iii. Seismic-related ground failure, including liquefaction? iv. Landslides?
b. Result in substantial soil erosion or the loss of topsoil? 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?
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?
e. Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of
wastewater?
f. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?

3.7.1 Impact Analysis
a. 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? Refer to Division of Mines and Geology Special Publication 42.

Less Than Significant Impact. Fault ruptures are generally expected to occur along active fault traces that have exhibited signs of recent geological movement (i.e., within the past 11,000 years). Alquist-Priolo Earthquake Fault Zones delineate areas around active faults with potential surface fault rupture hazards that would require specific geological investigations prior to approval of certain kinds of development within the delineated area. The project site is not located within an Alquist-Priolo Earthquake Fault Zone. In addition, no known active or potentially active faults or fault traces are located in the vicinity of the project site. The closest active faults to the project site are the Nunez Fault, located approximately 60 miles southwest of the project site and the Ortigalita Fault, located approximately 66 miles southwest of the 1112
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P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) 3-27 project site. Due to the distance of these known faults, no people or structures would be exposed to potential substantial adverse effects, including the risk of loss, injury, or death from the rupture of a known earthquake fault as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map. Therefore, potential impacts related to fault rupture would be less than significant. This topic will not be discussed in the EIR. ii. Strong seismic ground shaking?
Less Than Significant Impact. While Clovis is not located within an Alquist-Priolo Earthquake hazard zone, some ground shaking may occur within the City Planning Area depending on the amount of energy released from a nearby fault, or the magnitude of the earthquake. The proposed project would be required to conform to California Building Code (CCR Title 24) seismic safety standards, which take multiple factors into account, such as occupancy type, soil type, and ground motion with a specified probability at the project site. Compliance with the California Building Code would ensure that geotechnical design of the proposed project would reduce potential impacts related to seismic ground shaking to less than significant. This topic will not be discussed in the EIR.
iii. Seismic-related ground failure, including liquefaction? Less Than Significant Impact. Soil liquefaction is a phenomenon primarily associated with saturated soil layers located close to the ground surface. During ground shaking, these soils lose strength and acquire “mobility” sufficient to permit both horizontal and vertical movements.

Soils that are most susceptible to liquefaction are clean, loose, uniformly graded, saturated, fine-grained sands that lie relatively close to the ground surface. However, loose sands that contain a significant amount of fines (silt and clay) may also liquefy. Liquefaction and lateral spreading potential in Fresno County and Clovis is considered very low due to the nature of the underlying soils and history of low ground-shaking potential in the region. Furthermore, compliance with the California Building Code would ensure potential impacts associated with seismic-related ground failure would be less than significant. This topic will not be discussed in the EIR.
iv. Landslides?
Less Than Significant Impact. Landslides typically occur in areas that experience ground shaking, are typically wet and/or have steep slopes. The proposed project is located in Clovis, which is an area that consists of mostly flat topography within the Central Valley and has low groundshaking potential. Additionally, the project site is not located next to any hills, rivers, creeks or unlined canals that could increase the risk of landslides. Therefore, the potential for the proposed project to expose people or structures to risk as a result of landslides would be less than significant. This topic will not be discussed in the EIR. b. Would the project result in substantial soil erosion or the loss of topsoil? Less Than Significant Impact. Grading and earthmoving during project construction has the potential to result in erosion and loss of topsoil. Exposed soils could be entrained in stormwater 1113
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This impact would be less than significant. This topic will not be discussed in the EIR. c. 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. As described in discussion a) in this section, soils on the project site would not be subject to liquefaction, lateral spreading, or landslides. Additionally, the proposed project would be required to conform with the California Building Code, which would reduce risks related to unstable soils. Therefore, the proposed project would have a less than significant impact related to unstable soils. This topic will not be discussed in the EIR. d. Would the project 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? Less Than Significant Impact. Expansive soils are characterized by the potential for shrinking and swelling as the moisture content of the soil decreases and increases, respectively. Shrink-swell potential is influenced by the amount and type of clay minerals present and can be measured by the percent change of the soil volume. The project site contains Exeter sandy loam, Tujunga loamy sand, Atwater sandy loam, and Ramona sandy loam, soils which have a medium to low shrink-swell potential.13 Compliance with California Building Code requirements would ensure the implementation of design features that would reduce potential impacts related to expansive soils to a less than significant level. As such, the risk of expansive soil affecting the proposed project is considered low and would represent a less than significant impact. This topic will not be discussed in the EIR.
e. Would the project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
No Impact. The City’s Public Utilities Department currently manages the City’s sewer system and wastewater treatment facilities. Wastewater from the City’s collection system is treated at the Clovis Water Reuse Facility and the Fresno-Clovis Regional Wastewater Reclamation Facility (RWRF).

Development of the proposed project would not involve the use of septic tanks or alternative wastewater disposal systems. The proposed project would be required to pay development fees and fund the construction or expansion of wastewater infrastructure, as applicable, to ensure that the public sewer system would serve the project site. Therefore, the proposed project would have no 13 Natural Resources Conservation Service. n.d. Web Soil Survey. Website: https://websoilsurvey.sc.egov. usda.gov/App/WebSoilSurvey.aspx (accessed April 14, 2022). 1114
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f. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Less Than Significant with Mitigation Incorporated. Paleontological resources are afforded protection under CEQA Guidelines, Appendix G. The CEQA Guidelines indicate that a project would have a significant impact on paleontological resources if it would disturb or destroy a unique paleontological resource or site, or a unique geologic feature. PRC Section 5097.5 also specifies that the unauthorized removal or damage of paleontological remains is a misdemeanor. The California Penal Code Section 622.5 also sets penalties for removal or damage of paleontological resources.

The project site has been partially developed and used for agricultural production. In addition, there have been no known discovery of occurrences of paleontological resources in the immediately surrounding areas. Although the project site has been previously disturbed, it is possible that paleontological resources could be inadvertently or accidentally discovered within the project site during construction activities. Mitigation Measure GEO-1 would serve to protect the accidental discovery of paleontological resources. As such, a less than significant impact with mitigation would occur. This topic will not be discussed in the EIR.

Mitigation Measure GEO-1 If any potentially significant paleontological resources are discovered during grading activities, all construction activities shall stop within 50 feet of the find and a certified professional paleontologist shall provide recommendations and mitigation measures to protect the resource.

If a potentially significant resource is encountered, then the qualified professional paleontologist, the City of Clovis, and the Project Applicant 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 City of Clovis as verification that the provisions for managing unanticipated discoveries have been met.
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3.8 GREENHOUSE GAS EMISSIONS
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the
environment?
b. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?

3.8.1 Impact Analysis
Greenhouse gases (GHGs) are present in the atmosphere naturally, are released by natural sources, or are formed from secondary reactions taking place in the atmosphere. The gases that are widely seen as the principal contributors to human-induced global climate change are:
• Carbon dioxide (CO2)
• Methane (CH4)
• Nitrous oxide (N2O)
• Hydrofluorocarbons (HFCs)
• Perfluorocarbons (PFCs)
• Sulfur hexafluoride (SF6)
Certain gases, such as water vapor, are short-lived in the atmosphere. Others remain in the atmosphere for significant periods of time, contributing to climate change in the long term. Water vapor is excluded from the list of GHGs above because it is short-lived in the atmosphere and its atmospheric concentrations are largely determined by natural processes, such as oceanic evaporation.

These gases vary considerably in terms of Global Warming Potential (GWP), which is a concept developed to compare the ability of each GHG to trap heat in the atmosphere relative to another gas. GWP is based on several factors, including the relative effectiveness of a gas to absorb infrared radiation and the length of time that the gas remains in the atmosphere (“atmospheric lifetime”).

The GWP of each gas is measured relative to carbon dioxide (CO2), which is the most abundant GHG; the definition of GWP for a particular GHG is the ratio of heat trapped by one unit mass of the GHG to the ratio of heat trapped by one unit mass of CO2 over a specified time period. GHG emissions are typically measured in terms of pounds or tons of “CO2 equivalents” (CO2e). a. Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Potentially Significant Impact. Construction activities, such as site preparation, site grading, on-site heavy-duty construction vehicles, equipment hauling materials to and from the project site and 1116
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P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) 3-31 motor vehicles transporting the construction crew would produce GHGs. The combustion of fossilbased fuels creates GHGs such as CO2, CH4, and N2O. Furthermore, CH4 is emitted during the fueling of heavy equipment. Long-term operation of the proposed project would generate GHG emissions from mobile and stationary sources. Mobile-source emissions of GHG would include vehicle-related emissions associated with the private vehicles owned by residents and employees of the project site. Stationary emissions of GHG would include electricity and natural gas consumption from residences at the project site.

The EIR will provide further analysis of the proposed project’s GHG emissions. b. Would the project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Potentially Significant Impact. As discussed above, the project has the potential to emit GHGs. As such, the EIR will include further evaluation of project-related emissions and associated emission reduction strategies to determine whether the proposed project conflicts with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions. 1117
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3.9 HAZARDS AND HAZARDOUS MATERIALS
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a. Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
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?
c. Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within onequarter 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?
e. For a project located within an airport land use plan or, where such a plan has not been adopted, within 2 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?
f. Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
g. Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?

3.9.1 Impact Analysis
a. 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. Construction activities associated with the proposed project would involve the use of limited amounts of potentially hazardous materials, including but not limited to, solvents, paints, fuels, oils, and transmission fluids. However, all materials used during construction would be contained, stored, and handled in compliance with applicable standards and regulations established by the California Department of Toxic Substances Control (DTSC), the EPA, and the Occupational Safety and Health Administration (OSHA). No manufacturing, industrial, or other uses utilizing large amounts of hazardous materials or emitting significant amounts of hazardous substances would occur within the project site. All storage, handling, and disposal of hazardous materials during project construction and operation would comply with applicable standards and regulations, including Policies 1.4, 2.1, 2.3, and 2.4 from the Environmental Safety Element of the General Plan:
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P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) 3-33 Policy 1.4: Facilities that use hazardous materials. Prohibit facilities using, storing, or otherwise involved with hazardous or toxic materials to be located in the 100- year flood zone unless all standards of elevation, flood proofing, and storage have been implemented.

Policy 2.1: Safe storage and maintenance. The use and storage of hazardous materials shall comply with applicable federal, state, and local laws to prevent and mitigate hazardous materials releases.

Policy 2.3: Truck routes for hazardous materials. Maintain designated truck routes for the transportation of hazardous materials through the City. Discourage routes that pass through residential neighborhoods to the maximum extent feasible.

Policy 2.4: Hazardous materials response team. Maintain a Type 1 hazardous materials response team serving the City of Clovis.

As a result, the proposed project would not create significant hazards to the public or environment through the transport, use or disposal of hazardous materials, and a less than significant impact would occur. This topic will not be included in the EIR. b. Would the project 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?
Less Than Significant Impact. See discussion a) above. The proposed project would not use substantial amounts hazardous materials which release would result in a significant hazard to the public or the environment. Additionally, the proposed project would also comply, as applicable, with General Plan Policies 1.4, 2.1, 2.3 and 2.4 from the Environmental Safety Element, which require compliance with local, State and federal standards and procedures for the handling, use, transport and disposal of hazardous materials. This impact would be less than significant. This topic will not be included in the EIR.
c. 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. The closest existing schools to the project site are Woods Elementary School, located approximately 0.75 mile south of the project site, and Buchanan High School, located approximately 1.08 miles southeast of the project site. As previously stated, the proposed project would not result in the use or emission of substantial quantities of hazardous materials that would pose a human or environmental health risk. In addition, all hazardous materials within the project site would be handled, stored, and disposed of in accordance with applicable standards and regulations. Therefore, because the proposed project would not result in the emission of hazardous materials or acutely hazardous substances in the vicinity of a school, a less than significant impact would occur. This topic will not be included in the EIR. 1119
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3 P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) -34 d. 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?
Less Than Significant Impact. According to the DTSC EnviroStor database,14 the project site is not located on a federal superfund site, State response site, voluntary cleanup site, school cleanup site, evaluation site, school investigation site, military evaluation site, tiered permit site, or corrective action site. Additionally, the project site is not included on the list of hazardous materials sites compiled pursuant to Government Code Section 65962.5.15 Therefore, the proposed project would not create a significant hazard to the public, and a less-than-significant impact would occur. This topic will not be included in the EIR.
e. Would the project be located within an airport land use plan or, where such a plan has not been adopted, within 2 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? Less Than Significant Impact. The nearest airports to the project site include the Fresno Yosemite International Airport, located approximately 6.5 miles southwest of the project site, Fresno Chandler Executive Airport, located approximately 11.7 miles southwest of the project site, and the Sierra Sky Airport, located approximately 9.6 miles southwest of the project site. The nearest medical center helipads (HP) to the project site include the Clovis Community Hospital HP located approximately

3.34 miles southeast of the project site, the Saint Agnes Medical Center HP, located approximately

4.2 miles southwest of the project site, and the Valley Children’s Hospital HP located approximately

5.33 miles west of the project site.16 Due to the distance between the project site and local airports and helipads, operations at these locations are not expected to pose a safety hazard for people residing in the project site. Therefore, the proposed project would not expose persons to airportrelated hazards, and the potential impact would be less than significant. This topic will not be included in the EIR.
f. Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Less Than Significant Impact. The California Emergency Services Act requires cities to prepare and maintain an Emergency Plan for natural, manmade, or war-caused emergencies that result in conditions of disaster or in extreme peril to life. The Clovis Fire Department maintains the City’s Emergency Operations Plan (EOP). The proposed project would include the construction of 590 new single-family residential units within the project site, as well as landscaped, recreational, and utility areas. The proposed project would also result in the construction of extensions of North Baron 14 California Department of Toxic Substances Control. 2007. EnviroStor. Website: https://www.envirostor. dtsc.ca.gov/public/map/?myaddress=clovis (accessed April 14, 2022). 15 California Environmental Protection Agency (CalEPA). 2018. Government Code Section 65962.5(a) Hazardous Waste and Substances Site List. Website: https://calepa.ca.gov/sitecleanup/corteselist/ section-65962-5a/ (accessed April 14, 2022). 16 California Department of Transportation (Caltrans). 2019. Caltrans HeliPlates. Website: https://heliplates. dot.ca.gov/# (accessed April 14, 2022).
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P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) 3-35 Avenue, Perrin Avenue, and Hammel Avenue to facilitate access to, and circulation within, the project site.

The proposed improvements to North Baron Avenue, Perrin Avenue, and Hammel Avenue are not expected to block the circulation of emergency response services in the vicinity of the project site or introduce elements that would conflict with the operations of the City’s EOP. After construction, the proposed extensions to North Baron Avenue, Perrin Avenue, and Hammel Avenue would improve access of emergency response vehicles to the project area and evacuation from the project area.

Therefore, the proposed project would not interfere with emergency evacuation plans in Clovis, and this impact would be less than significant. This topic will not be included in the EIR. g. Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
Less Than Significant Impact. The project site is located in an area mapped by the California Department of Forestry and Fire Protection (CAL FIRE) as Local Responsibility Area (LRA) Unzoned, indicating that the area is urbanized and not susceptible to wildland conflagrations, and is not located within a very high fire hazard severity zone (VHFHSZ).17 However, the project site is in the vicinity of a moderate fire hazard zone. As such, implementation of the proposed project could expose people and/or structures to fire hazard by development near a moderate fire hazard severity zone. In compliance with the General Plan EIR, projects built or developed within a fire hazard severity zone would be required to comply with Chapter 7A of the California Building Code. Any project developed or redeveloped surrounded by or next to forest, brush, grass, or other flammable vegetation would also be mandated to comply with requirements regarding hazardous vegetation, defensible space, and fuel management in California PRC Sections 4291 et seq. and in Sections 4906 and 4907 of the California Fire Code (CFC). Implementation of these regulations would reduce potential impacts associated with wildland fires to a less-than-significant level. This topic will not be included in the EIR.
17 California Department of Forestry and Fire Protection (CAL FIRE). 2007. Fresno County Fire Hazard Severity Zones in LRA. Website: https://osfm.fire.ca.gov/media/6673/fhszl06_1_map10.pdf (accessed April 14, 2022).
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3.10 HYDROLOGY AND WATER QUALITY
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a. Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality?
b. Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the
project may impede sustainable groundwater management
of the basin?
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 flooding on or off site;
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?
d. In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
e. Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?

3.10.1 Impact Analysis
a. Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality? Less Than Significant Impact. The State Water Resources Control Board (SWRCB) and nine RWQCBs regulate the water quality of surface water and groundwater throughout California. The proposed project is within the jurisdiction of the Central Valley RWQCB.

Pollutants of concern during construction include sediments, trash, petroleum products, concrete waste (dry and wet), sanitary waste, and chemicals. During project construction, there would be an increased potential to expose soils to wind and water erosion, which could result in temporary minimal increases in sediment load in nearby water bodies.

In compliance with the General Plan, any development project disturbing one or more acres of soil must obtain coverage under the General Permit for Discharges of Storm Water Associated with Construction Activity (Construction General Permit Order 2009‐0009‐DWQ). Construction activities subject to the Construction General Permit includes clearing, grading, and other ground‐disturbing 1122
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P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) 3-37 activities such as stockpiling or excavation. The Construction General Permit requires development and implementation of a SWPPP.

A SWPPP includes features designed to eliminate contact of rainfall and stormwater runoff with sources of pollution that occur on construction sites, the main source being soil erosion resulting from unstabilized soils coming in contact with water and wind. These features are known as BMPs.

Common BMPs to limit pollution in stormwater runoff from construction sites include maintaining or creating drainages to convey and direct surface runoff away from bare areas and installing physical barriers such as berms, silt fencing, waddles, straw bales, and gabions. Consistency with the Construction General Permit, including the SWPPP and BMPs, would reduce project construction impacts on water quality to less than significant levels.

To address long-term impacts to groundwater quality, the proposed project would comply with the Fresno-Clovis Storm Water Quality Management Program (SWQMP)18, which requires the implementation of BMPs to manage urban stormwater runoff in the Fresno Metropolitan Area.

These BMPs require the implementation of site drainage designs and post-construction measures that prevent stormwater pollution, as well as compliance with City of Clovis standards to improve stormwater quality. Compliance with this program would reduce potential impacts to groundwater quality from the proposed project. The Project Applicant would be required to pay Local Drainage Fees to fund drainage improvements pursuant to the FMFCD Master Plan and the SWQMP.

Therefore, the proposed project would not violate any water quality standards, waste discharge requirements, or substantially degrade surface or groundwater quality, and the impact would be less than significant. This topic will not be included in the EIR. b. Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
Less Than Significant Impact. Water supply, and water and wastewater circulation services for the proposed project would be provided by the City of Clovis through the Department of Public Utilities.

The City of Clovis relies upon groundwater, surface water, and recycled water for its water supply.

The City extracts groundwater from the Kings Subbasin, an unadjudicated basin with a status of critically overdrafted. The proposed project would construct a 590-lot residential development in a previously undeveloped site. The proposed project would result in an increase of impervious surfaces in the currently undeveloped project site. However, the project would not require groundwater pumping for project operations. As previously discussed, the City extracts groundwater from the Kings Subbasin through a well system containing 36 active wells and one standby well with a total capacity of approximately 37,690 gallons per minute (gpm) with another 4,750 gpm of additional capacity planned in the next few years. According to the City’s 2020 Urban Water 18 Fresno Metropolitan Flood Control District (FMFCD). 2020. Fresno-Clovis Storm Water Quality Management Program: FY 2019-20 Annual Report. October 1. Website:
http://www.fresnofloodcontrol.org/wp-content/uploads/2020/09/2019-20-Annual-Report-FINAL.pdf (accessed December 6, 2022).
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3 P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) -38 Management Plan19, the City conducted 5,316 acre-feet (AF) of intentional recharge activities at various basins, creeks, and landscape areas throughout the City’s service area. Stormwater throughout the City is collected in FMFCD basins, where collected stormwater is allowed to percolate into the soil as groundwater recharge. The FMFCD allows the City to utilize 17 stormwater basins throughout the City’s service area for recharge purposes. The FMFCD urban stormwater drainage system would provide groundwater infiltration for runoff from developed land uses in detention basins in the City’s drainage system service area. As Clovis continues to grow, the City intends to expand its surface water supply use, recycled water use, and to continue intentional groundwater recharge efforts to relieve pressure on the groundwater aquifer. The proposed project would aid groundwater recharge in the Kings Subbasin through compliance with the Urban Water Management Plan (UWMP) and construction of surface and subsurface drainage infrastructure, per design requirements of the City and FMFCD, along North Baron Avenue, Perrin Avenue, and Hammel Avenue as well as along internal roadways in the project site to direct stormwater towards FMFCD Basin BY, which is located adjacent to the project site’s eastern boundary. In addition, a 1,300-footlong, 26-foot-wide drainage channel would be constructed along the north side of the Perrin Avenue extension to direct stormwater flows west from the project site towards drainage infrastructure along the Enterprise Canal. As such, the proposed project would not interfere with groundwater recharge in the Kings Subbasin, and impacts would be less than significant.

In addition to the groundwater supplies, the City also has access to surface water through several different contracts, all of which are delivered to the City by the Fresno Irrigation District (FID). The various surface water supplies are from the Kings River and Central Valley Project (Class II supplies, which are less reliable than other surface water supplies). Lands located within the Kings River service area are generally entitled to an average annual allotment of approximately 2.24 acre-feet per year per acre (AFY/ac). According to a Water Infrastructure Investigation prepared for the proposed project, and included as Appendix B of this Initial Study, approximately 38.6 acres of the project site are located within the FID service area and 32.9 acres are located outside of the FID service area. The Water Infrastructure Investigation has determined that the proposed Medium Density Residential use of the project has a water demand of 3.3 AFY/ac, making annual water demand in the project site approximately 236 AFY. Because the water demand of the project is higher than the allocation of the FID, and the FID would only supply water for approximately 54 percent of the project site (approximately 86.5 AFY), the proposed project would require additional water supply from the City of Clovis. The proposed project would be required to pay applicable development fees to the City to fund acquisition of additional water supplies. After payment of applicable fees, the City would be able to provide sufficient water supply for the project.

As identified in the Water Supply Assessment, included as Appendix C of this Initial Study, the City will have sufficient water supplies to provide water to this project. As such, the proposed project would not substantially decrease water supplies or interfere substantially with groundwater recharge such that the proposed project may impede sustainable groundwater management of the basin. As a result, this project would result in a less-than-significant impact related to impeding the 19 City of Clovis. 2021. Urban Water Management Plan 2020 Update. July 12. Website: https://cityofclovis. com/wp-content/uploads/2021/08/2020-UWMP-Adopted-July-2021_reduced.pdf (accessed December 6, 2022).
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c. Would the project 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; Less Than Significant Impact. Ground-disturbing activities associated with construction of the proposed project would expose native soils that could be subject to the effects of wind and water erosion unless adequate measures are taken to limit the transport of soils in surface water from construction sites to downstream locations. As discussed under discussion a) in this section, the Project Applicant would be required to implement a SWPPP that would identify specific measures to address erosion and siltation resulting from grading and construction.

Stormwater collection and disposal, and flood control for the City of Fresno, City of Clovis, and the unincorporated areas within the City of Clovis SOI are provided by the FMFCD. Stormwater from the project site would be drained through surface and subsurface drainage infrastructure located along North Baron Avenue, Perrin Avenue, and Hammel Avenue, as well as along internal roadways in the project site, and redirected towards Basin BY, which is located adjacent to the project site’s eastern boundary. Compliance with the FMFCD’s SWQMP would require the implementation of BMPs that would manage the release of pollutants and sediments from the project site into stormwater, thus managing potential impacts resulting from erosion and saltation on the project site. Implementation of these measures would reduce potential impacts related to erosion and saltation to less than significant. This topic will not be included in the EIR. ii. Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on or off site;
Less Than Significant Impact. The proposed project would construct a 590-lot residential development in the project site. The project site is mainly undeveloped, and therefore, implementation of the proposed project would increase impervious surfaces at the project site that could increase surface runoff. Stormwater from the project site would be drained through surface and subsurface drainage infrastructure located along North Baron Avenue, Perrin Avenue, and Hammel Avenue as well as along internal roadways in the project site, and redirected towards Basin BY, located adjacent to the project site’s eastern boundary. The Project Applicant would be required to pay drainage fees to the FMFCD to fund drainage facilities and address impacts related to increased amount of surface runoff resulting from development of the project site. The construction of stormwater facilities would handle surface runoff in a manner that would exceed the capacity of existing or planned drainage infrastructure in the vicinity. Therefore, the impact would be less than significant. This topic will not be included in the EIR.
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3 P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) -40 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 Less Than Significant Impact. Please refer to discussions a) and c) i and ii in this section. The proposed project would result in an increase of impervious surfaces, which can contribute to surface runoff. However, implementation of a SWPPP and compliance with the City’s SWQMP would ensure that the proposed project would not generate additional sources of polluted runoff. Additionally, the Project Applicant would be required to pay drainage fees to the FMFCD to address impacts related to increased amount of surface runoff resulting from the proposed project. The construction of proposed stormwater facilities would handle surface runoff in a manner that would exceed the capacity of existing or planned stormwater drainage systems in the vicinity. Therefore, the impact would be less than significant. This topic will not be included in the EIR.
iv. Impede or redirect flood flows?
Less Than Significant Impact. Sections of the project site are located within a 100-year flood hazard zone as mapped by the Federal Emergency Management Agency (FEMA).20 The City of Clovis Municipal Code Section 8.12, Floodplain Management lists standards and design requirements for new construction and development within special flood zones. Policy 1.1 from the General Plan Environmental Safety Element also prohibits development within the 100-year flood zone unless adequate mitigation against flood hazards is provided. The proposed project would implement flood hazard mitigation required by the City’s Municipal Code.

Implementation of these requirements would ensure the proposed project does not impede or redirect flood flows, and the impact would be less than significant. This topic will not be included in the EIR.
d. In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?
Less Than Significant Impact. The project site is not located in tsunami or seiche zones. Parts of the proposed project are located within a 100-year flood zone but as discussed under discussion c) iv, the proposed project would implement standards and requirements of the City of Clovis Municipal Code to mitigate risks related to flood hazards. Refer to discussion a) in Section 3.9, Hazards and Hazardous Materials, regarding the use, transport and storage of hazardous materials for project construction and operation. As a result, the proposed project would not risk the release of pollutants due to project inundation, and a less than significant impact would occur. This topic will not be included in the EIR.
20 Federal Emergency Management Agency (FEMA). 2020. FEMA Flood Map Service Center: Search By Address. Website: https://msc.fema.gov/portal/search?AddressQuery#searchresultsanchor (accessed April 14, 2022).
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P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) 3-41 e. Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Less Than Significant Impact. The proposed project would comply with the City of Clovis UWMP, 21 which promotes programs and policies to manage water supplies, including groundwater, in Clovis.

The proposed project would also comply with the SWQMP and a site-specific SWPPP that would ensure water quality control at the project site, as applicable. The proposed project would not conflict or obstruct implementation of a water quality control or sustainable groundwater management plan, and the impact would be less than significant. This topic will not be included in the EIR.
21 City of Clovis. 2021. Urban Water Management Plan 2020 Update. July 12. Website:
https://cityofclovis.com/wp-content/uploads/2021/08/2020-UWMP-Adopted-July-2021_reduced.pdf (accessed December 6, 2022).
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3.11 LAND USE AND PLANNING
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a. Physically divide an established community?
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?

3.11.1 Impact Analysis
a. Would the project physically divide an established community? No Impact. The physical division of an established community typically refers to the construction of a physical feature (such as an interstate highway or railroad tracks) or removal of a means of access (such as a local road or bridge) that would impair mobility within an existing community, or between a community and outlying areas.

The proposed project would include the construction of a 590-lot residential development for single-family residences. The development would include landscaped spaces, private recreation, private streets, private pedestrian, public park and public utility uses. The project site is surrounded by agricultural and single-family residential uses to the south, rural residential and agricultural uses to the east, agricultural and commercial uses to the west, and agricultural and rural residential uses to the north.

The proposed project would not construct features that would physically divide an established community or remove means of access that would impair mobility in a community. Therefore, the proposed project would have no impact. This topic will not be included in the EIR. b. 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 land use for the project site, according to the City of Clovis General Plan, is Medium Density Residential.22 The project site is currently zoned within the Exclusive Agricultural Zoning District (AE-20) of Fresno County. The proposed zoning for the project site is within the Single-Family Planned Residential Development (R-1-PRD) District. The proposed project would require annexation to the City of Clovis and an annexation application would be required to be submitted to the Fresno LAFCo. The Project Applicant would also be required to pay required processing fees for the annexation process. After approval of annexation of the project site into the City of Clovis, the proposed project would be consistent with the City’s land use plans. 22 City of Clovis. 2014. General Plan and Development Code Update PEIR. Land Use Element. Figure LU-2:

Land Use Diagram. Website: https://cityofclovis.com/wp-content/uploads/2018/10/Figure-LU-2.pdf (accessed April 14, 2022).
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3.12 MINERAL RESOURCES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
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?
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?

3.12.1 Impact Analysis
a. 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?
Less Than Significant Impact. The Mineral Resources section of the Clovis General Plan EIR indicates that entire City of Clovis Planning Area is mapped as Mineral Resource Zone 3 (MRZ-3), meaning that the significance of potential mineral deposits cannot be determined from available data. The nearest area designated MRZ-2, where significant mineral resources are known or very likely to be found, is the San Joaquin River Resource Area, located approximately 4.5 miles west of the project site. Furthermore, the General Plan EIR does not identify any known mineral resources sectors or mineral resource extraction operations within or in the vicinity of the project site.23 Therefore, the proposed project would not result in the loss of any known mineral resources, and the impact would be less than significant. This topic will not be included in the EIR. b. Would the project 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? Less Than Significant Impact. Please refer to the discussion for a). The proposed project would not result in the loss of availability of any known locally important mineral resource recovery sites.

Therefore, the proposed project would have a less than significant impact. This topic will not be included in the EIR.
23 City of Clovis. 2014. General Plan and Development Code Update PEIR. Mineral Resources. Website:
https://cityofclovis.com/wp-content/uploads/2018/10/Chapter-05-11-Mineral-Resources.pdf (accessed April 14, 2022).
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3.13 NOISE
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project result in:
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? b. Generation of excessive groundborne vibration or
groundborne noise levels?
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 2 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?

3.13.1 Impact Analysis
a. 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? Potentially Significant Impact. Noise is usually defined as unwanted sound. Noise consists of any sound that may produce physiological or psychological damage and/or interfere with communication, work, rest, recreation, or sleep. Several noise measurement scales exist that are used to describe noise in a particular location. A decibel (dB) is a unit of measurement that indicates the relative intensity of a sound. Sound levels in dB are calculated on a logarithmic basis. An increase of 10 dB represents a 10-fold increase in acoustic energy, while 20 dB is 100 times more intense and 30 dB is 1,000 times more intense. Each 10 dB increase in sound level is perceived as approximately a doubling of loudness; and similarly, each 10 dB decrease in sound level is perceived as half as loud.

Sound intensity is normally measured through the A-weighted sound level (dBA). This scale gives greater weight to the frequencies of sound to which the human ear is most sensitive. The A-weighted sound level is the basis for 24-hour sound measurements that better represent human sensitivity to sound at night.

As noise spreads from a source, it loses energy so that the farther away the noise receiver is from the noise source, the lower the perceived noise level would be. Geometric spreading causes the sound level to attenuate or be reduced, resulting in a 6 dB reduction in the noise level for each doubling of distance from a single point source of noise to the noise sensitive receptor of concern.

There are many ways to rate noise for various time periods, but an appropriate rating of ambient noise affecting humans also accounts for the annoying effects of sound. Equivalent continuous sound level (Leq) is the total sound energy of time varying noise over a sample period. However, the predominant rating scales for human communities in the State of California are the Leq, the Community Noise Equivalent Level (CNEL), and the day-night average level (Ldn) based on dBA. 1131
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3 P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) -46 CNEL is the time varying noise over a 24-hour period, with a 5 dBA weighting factor applied to the hourly Leq for noises occurring from 7:00 p.m. to 10:00 p.m. (defined as relaxation hours) and 10 dBA weighting factor applied to noise occurring from 10:00 p.m. to 7:00 a.m. (defined as sleeping hours).

Ldn is similar to the CNEL scale, but without the adjustment for events occurring during the evening relaxation hours. CNEL and Ldn are within one dBA of each other and are normally exchangeable. The noise adjustments are added to the noise events occurring during the more sensitive hours.

A project would have a significant noise effect if it would substantially increase the ambient noise levels for adjoining areas or conflict with adopted environmental plans and goals of applicable regulatory agencies, including, as appropriate, the City of Clovis.

The City of Clovis addresses noise in the Environmental Safety Element of the General Plan and in the Municipal Code. The Environmental Safety Element provides goals and policies that work to protect residential and other noise-sensitive uses from exposure to harmful or annoying noise levels; to identify maximum acceptable noise levels compatible with various land use designations; and to develop a policy framework necessary to achieve and maintain a healthful noise environment. Applicable Environmental Safety Element policies include the following24:

Policy 3.1 Land use compatibility: Approve development and require mitigation measures to ensure existing and future land use compatibility as shown in the Noise Level Exposure and Land Use Compatibility Matrix and the city’s noise ordinance.

Policy 3.4 Acoustical study: Require an acoustical study for proposed projects that have the potential to exceed acceptable noise thresholds or are exposed to existing or future noise levels in excess of the thresholds in the city’s noise ordinance.

Policy 3.5 Site and building design: Minimize noise impacts by requiring appropriate site, circulation, equipment, and building design, and sound walls, landscaping, and other buffers.

Policy 3.14 Control sound at the source: Prioritize using noise mitigation measures to control sound at the source before buffers, soundwalls, and other perimeter measures.

In addition, the City of Clovis addresses construction noise in Section 9.22.080, Noise, of the Municipal Code. Section 9.22.080 (D) sets exterior noise standards as shown in Table 3.B and interior noise standards as shown in Table 3.C.

Section 5.27.604 states that construction noise is permitted by the City of Clovis provided that construction activities take place between 7:00 a.m. and 7:00 p.m. Monday through Friday and between 9:00 a.m. and 5:00 p.m. on Saturday and Sunday. However, between June 1 and September 15, construction may begin at 6:00 a.m. on weekdays. 24 City of Clovis. 2014. General Plan and Development Code Update PEIR. Environmental Safety Element.

Website: https://cityofclovis.com/wp-content/uploads/2018/10/Clovis-General-Plan-2014.pdf (accessed April 21, 2022).
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P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) 3-47 Table 3.B: City of Clovis Maximum Exterior Noise Standards Noise
Zone Type of Land Use Allowable Exterior Noise Level (15-Minute Leq), dBA Daytime (7:00 AM to 10:00 PM) Nighttime (10:00 PM to 7:00 AM) I Single-, two- or multiple-family residential 55 50
II Commercial 65 60
III Residential portions of mixed-use properties 60 50
IV Industrial or manufacturing 70 70
Source: City of Clovis Municipal Code
dBA = A-weighted decibel
Leq = equivalent continuous sound level
Table 3.C: City of Clovis Maximum Interior Noise Standards Noise
Zone Type of Land Use Allowable Interior Noise Level (15-Minute Leq), dBA Daytime (7:00 AM to 10:00 PM) Nighttime (10:00 PM to 7:00 AM) I Residential 45 40
II Administrative/professional office 50 -
III Residential portions of mixed-use properties 45 40
Source: City of Clovis Municipal Code
dBA = A-weighted decibel
Leq = equivalent continuous sound level
Certain land uses are considered more sensitive to noise than others. Examples of these sensitive land uses include residential areas, educational facilities, hospitals, childcare facilities, and senior housing. The nearest noise-sensitive land uses located within the vicinity of the project site includes residential uses located directly adjacent to the project site’s eastern boundary.

Short-Term (Construction) Noise Impacts. Project construction would result in short-term noise impacts on nearby sensitive receptors. Maximum construction noise would be short term, generally intermittent depending on the construction phase, and variable depending on receiver distance from the active construction zone. The duration of noise impacts generally would be from one day to several days depending on the phase (e.g., demolition, land clearing, grading, excavation, erection) of construction. The level and types of noise impacts that would occur during construction are described below.

Short-term noise impacts would occur during grading and site preparation activities. Table 3.D lists typical construction equipment noise levels (maximum instantaneous noise level [Lmax]) recommended for noise impact assessments, based on a distance of 50 feet between the equipment and a noise receptor, obtained from the Federal High Administration (FHWA) Roadway Construction Noise Model. Construction-related short-term noise levels would be higher than existing ambient noise levels currently in the vicinity of the project site but would no longer occur once construction of the proposed project is completed.
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Equipment Description Acoustical Usage Factor
(%)
Maximum Noise Level
(Lmax) at 50 Feet1
Backhoes 40 80
Compactor (ground) 20 80
Compressor 40 80
Cranes 16 85
Dozers 40 85
Dump Trucks 40 84
Excavators 40 85
Flat Bed Trucks 40 84
Forklift 20 85
Front-end Loaders 40 80
Graders 40 85
Impact Pile Drivers 20 95
Jackhammers 20 85
Pick-up Truck 40 55
Pneumatic Tools 50 85
Pumps 50 77
Rock Drills 20 85
Rollers 20 85
Scrapers 40 85
Tractors 40 84
Welder 40 73
Source: Roadway Construction Noise Model (FHWA 2006).

Note: Noise levels reported in this table are rounded to the nearest whole number. 1 Maximum noise levels were developed based on Spec 721.560 from the Central Artery/Tunnel (CA/T) program to be consistent with the City of Boston’s Noise Code for the “Big Dig” project.

FHWA = Federal Highway Administration
Lmax = maximum instantaneous sound level
Two types of short-term noise impacts could occur during construction of the proposed project. The first type involves construction crew commutes and the transport of construction equipment and materials to the site, which would incrementally increase noise levels on roads leading to the site. As shown in Table 3.D, there would be a relatively high single-event noise exposure potential at a maximum level of 84 dBA Lmax with trucks passing at 50 feet.

The second type of short-term noise impact is related to noise generated during grading and construction on the project site. Construction is performed in discrete steps, or phases, each with its own mix of equipment and, consequently, its own noise characteristics. These various sequential phases would change the character of the noise generated on site. Therefore, the noise levels vary as construction progresses. Despite the variety in the type and size of construction equipment, similarities in the dominant noise sources and patterns of operation allow construction-related noise ranges to be categorized by work phase.

Table 3.D lists maximum noise levels recommended for noise impact assessments for typical construction equipment, based on a distance of 50 feet between the equipment and a noise receptor.
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P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) 3-49 Typical maximum noise levels range up to 87 dBA Lmax at 50 feet during the noisiest construction phases. The site preparation phase, including excavation and grading of the site, tends to generate the highest noise levels because earthmoving machinery is the noisiest construction equipment.

Earthmoving equipment includes excavating machinery such as backfillers, bulldozers, draglines, and front loaders. Earthmoving and compacting equipment includes compactors, scrapers, and graders.

Typical operating cycles for these types of construction equipment may involve 1 or 2 minutes of full-power operation followed by 3 or 4 minutes at lower power settings.

As discussed in Section 1.0, Project Description, the proposed project would be constructed in three Phases, over a period of 33 months, and each phase would include the construction and addition of buildings, working areas and equipment to increase the production capacity of the project site. The closest sensitive receptor to the proposed project includes residential uses located directly adjacent to the project site’s eastern boundary.

As discussed above, construction noise is permitted by the City of Clovis provided that construction activities take place between 7:00 a.m. and 7:00 p.m. Monday through Friday and between 9:00 a.m. and 5:00 p.m. on Saturday and Sunday. In addition, Mitigation Measure NOI-1 would be required to limit construction activities to daytime hours and would reduce potential construction period noise impacts for the indicated sensitive receptors to less-than-significant levels.

Mitigation Measure NOI-1 The project contractor shall implement the following measures during construction of the proposed project:
• Equip all construction equipment, fixed or mobile, with properly operating and maintained mufflers consistent with
manufacturers’ standards.
• Place all stationary construction equipment so that emitted noise is directed away from sensitive receptors nearest the active project site.
• Locate equipment staging in areas that would create the greatest possible distance between construction-related noise sources and noise-sensitive receptors nearest the active project site during all construction activities.
• Ensure that all general construction related activities take place between 7:00 a.m. and 7:00 p.m. Monday through Friday and between 9:00 a.m. and 5:00 p.m. on Saturday and Sunday.

Construction may begin on weekdays at 6:00 a.m. between June 1st and September 15th.

Operational Noise Impacts. The proposed project would include the construction of 590 new singlefamily residential units in the project site. Motor vehicles with their distinctive noise characteristics are the dominant noise source in the vicinity of the project site. The amount of noise varies according to many factors, such as volume of traffic, vehicle mix (percentage of cars and trucks), 1135
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3 P:\CIT2201-TM 6343\PRODUCTS\IS\03_Public_Review\TM6343-Initial_Study.docx (12/16/22) -50 average traffic speed, and distance from the observer. Implementation of the proposed project would result in new daily trips on local roadways in the vicinity of the project site. The EIR will determine the significance of operational noise impacts of the proposed project. b. Would the project result in generation of excessive groundborne vibration or groundborne noise levels?
Less Than Significant Impact. No permanent noise sources would be located within the project site that would expose persons to excessive groundborne vibration or noise levels.

As discussed in discussion a) above, implementation of Mitigation Measure NOI-1 would require project construction activities to maintain the greatest possible distance to existing sensitive receptors to reduce potential impacts. Implementation of a buffer between sensitive receptors and construction activities would protect sensitive receptors from excessive groundborne vibration or groundborne noise levels.

Furthermore, the City of Clovis addresses temporary vibrations in Section 9.22.100, Noise, (D) of the Clovis Municipal Code, stating that vibrations from temporary construction/demolition and vehicles that leave the subject parcel (e.g., trucks) are exempt from the provisions of this section.

Therefore, the proposed project would not permanently expose persons within or around the project site to excessive groundborne vibration or noise and the impact would be less than significant. This topic will not be included in the EIR. 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 2 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? Less Than Significant Impact. The nearest medical center HPs to the project site include the Clovis Community Hospital HP located approximately 3.3 miles southeast of the project site, the Saint Agnes Medical Center HP, located approximately 4.2 miles southwest of the project site, and the Valley Children’s Hospital HP located approximately 5.3 miles west of the project site.25 The nearest airports to the project site include the Fresno Yosemite International Airport, located approximately

6.5 miles southwest of the project site, Fresno Chandler Executive Airport, located approximately

11.7 miles southwest of the project site, and the Sierra Sky Airport, located approximately 9.6 miles southwest of the project site. Each of the airports has an Airport Land Use Compatibility Plan (ALUCP) which guides local jurisdictions in determining appropriate compatible land uses with detailed findings and policies. The City of Clovis General Plan, other City land use plans, and all City land use decisions must be compatible with the adopted ALUCP for Fresno County. The project site is not within 2.0 miles of any public or private airstrip or helipad. Therefore, the proposed project would not result in the exposure of sensitive receptors to the excessive noise levels from aircraft noise sources. The impact would be less than significant. This topic will not be included in the EIR. 25 California Department of Transportation (Caltrans). 2019. Caltrans HeliPlates. Website: https://heliplates. dot.ca.gov (accessed April 14, 2022).
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3.14 POPULATION AND HOUSING
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
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)?
b. Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing
elsewhere?

3.14.1 Impact Analysis
a. Would the project 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)?
Less Than Significant Impact. The proposed project would consist in the construction of a 590-lot residential development for single-family residences. The proposed project would also include landscaped spaces, park areas, private streets, pedestrian, and utility infrastructure. The proposed project would also construct extensions to North Baron Avenue, Perrin Avenue, and Hammel Avenue to facilitate access to, and circulation around the project site. The project site is located within the Heritage Grove area, a growth area marked for development in the City’s General Plan.

The proposed project would introduce a residential use that would result in direct population growth. The project site is currently designated Medium Density Residential and zoned within the Exclusive Agricultural Zoning District (AE-20) of Fresno County. The proposed project would require annexation to the City of Clovis and an annexation application would be required to be submitted to the Fresno LAFCo.

Based on the City’s current Housing Element,26 the average number of persons residing in each household in Clovis is estimated to be 2.85 persons. As a result, following construction and occupation of the proposed project, it is estimated that approximately 1,682 residents would live within the proposed 590 residential units within the project site. The Clovis General Plan estimated that at full buildout of the General Plan, approximately 105,700 residents would be living in the areas located within the City’s Non-SOI Planning Area (which includes the project site). As a result, the proposed project would not result in unplanned population growth because the City’s General Plan identified and planned for the project site to be designated medium density residential. As such, the proposed project would be consistent with planned growth under the City’s General Plan.

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