Agenda packet — Clovis City Council, November 18, 2024 (part 3 of 5)

Consequently, the Project itself would help to facilitate improved circulation by adding a pedestrian sidewalk along N. Baron and Perrin Avenues fronting the site, which would provide a complete connection of sidewalk to the existing developments to the south the Project.

The traffic conditions above recommend improvements for each study intersection. With incorporation of improvements recommended for each scenario all study intersections will operate at satisfactory LOS levels thus, the Project, will not conflict with the Circulation Element of the 2014 General Plan. Consequently, a lessthan-significant impact would occur. No mitigation measures are required.

Significant and Unavoidable Impact. Senate Bill 743 (SB 743) requires that relevant CEQA analysis of transportation impacts be conducted using a metric known as vehicle miles traveled (VMT) instead of level of service (LOS). VMT measures how much actual auto travel (additional miles driven) a proposed project would create on California roads. If the proposed project adds excessive car travel onto our roads, the proposed project may cause a significant transportation impact. Per CEQA Guidelines Section 15064.3(b)(4) a lead agency has discretion to choose the most appropriate methodology to evaluate a project’s VMT, including whether to express the change in absolute terms, per capita, per household or in any other measure. A lead agency may use models to estimate a project’s VMT, and may revise those estimates to reflect professional judgment based on substantial evidence. Any assumptions used to estimate VMT and any revisions to model outputs should be documented and explained in the environmental document prepared for the project.

With the recommended widening the intersection is expected to operate at LOS C during the a.m. peak hour and LOS D during the p.m. peak hour.

On October 17, 2022, the City of Clovis adopted the Transportation Impact Analysis Guidelines (Guidelines), dated September 15, 2022. Consistent with CEQA Guidelines Section 15064.3, the City of Clovis has adopted thresholds of significance to determine when a project will have a significant transportation impact based on VMT. The City has developed screening criteria to streamline the analysis for projects that meet certain criteria.

A project will require a detailed VMT analysis unless it meets at least one of the City’s five screening criteria34:
• Small Projects that generate less than 500 vehicle trips per day (i.e., Single-Family Residential developments with less than 53 dwelling units).

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• Project located in low VMT area
55 Less-Than-Significant Impact. The Project would result in a significant impact if it would include features that would create a hazard such as a sharp curve in a new roadway, or create a blind corner or result in sight distance issues from entryways. Through the entitlement process, the Project would undergo review by multiple City divisions, such as Planning and Engineering, to ensure that the site layout conforms to existing regulations, such as the CMC, and other applicable codes, such as the fire code and building code. During this review, the Project would need to make the necessary corrections to ensure that no hazardous design features would result from the Project. Further, the main roadway network (N. Baron and Perrin Avenues) will be constructed to City roadway standards. Therefore, because the Project would undergo site plan and design review to ensure The Project does not qualify for the screening criteria; therefore, shall be evaluated per Guidelines thresholds.

The significance thresholds and specific VMT metrics are described on page 10 of the City’s Transportation Impact Analysis Guidelines. Per the City’s Transportation Impact Analysis Guidelines, the residential land use impact threshold is 14.1 VMT per capita. The Project will generate 17.9 VMT per capita which is greater than the threshold of 14.1 VMT per capita; therefore, the Project would create a significant transportation impact.

Feasible mitigation measures must be identified to avoid or substantially reduce a significant impact under CEQA. Mitigation of VMT impacts typically requires changes in habits and behaviors of residents. Project design features that encourage mode shift from automobiles to transit or nonmotorized modes can potentially reduce project-specific VMT. The potential VMT reduction was estimated using the 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” dated December 2021.

The City adopted a Supplemental Environmental Impact Report (SEIR) for the 2014 General Plan Circulation Element Update on October 17, 2022. The SEIR evaluated potential land uses consistent with the General Plan and their associated VMT impacts. The SEIR finds that implementation of the 2014 General Plan may result in VMT metrics that are greater than the applicable thresholds. Mitigation measures include policies to reduce VMT. Because the City cannot demonstrate that the implementation of these policies would achieve VMT reductions to meet the VMT thresholds, the impacts would remain significant and unavoidable. Therefore, following approval of the SEIR, individual land use development projects that are consistent with the 2014 General Plan have the opportunity to tier their environmental review from the General Plan SEIR pursuant to section 15152 of the CEQA Guidelines. The SEIR has disclosed the VMT impacts of land use development consistent with the General Plan. Therefore, significant and unavoidable VMT impacts associated with the General Plan have already been disclosed. Because the proposed Project is consistent with the 2014 General Plan, the Project’s significant transportation impact does not require the preparation of a project specific EIR.

Although the Project, has been determined to be consistent with the 2014 General Plan and is tiering from the SEIR, it would remain a Significant and Unavoidable impact.

The Project will implement feasible mitigation measures such as constructing one (1) mile of sidewalks and less than one (1) mile of Class II Bike Lane on Baron and Perrin Avenues; however, implementation of the Project design features described above only reduces the calculated Project VMT by up to approximately 1.7 percent.

While the described mitigation measures can help offset a portion of the VMT impact, it will not reduce the impact to less than significant; therefore, the Project will have a significant and unavoidable transportation impact.
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)? LENNAR HOMES (TM6452)

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_____________________________________________________________________________________________________ CITY OF CLOVIS • Projects located in a High-Quality Transit Area (HQTA) as defined on page 8 of the City’s Transportation Impact Analysis Guidelines
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d) Would the project result in inadequate emergency access?

18. TRIBAL CULTURAL RESOURCES
X
in its discretion and supported by
X

ENVIRONMENTAL SETTING
56 Less Than
Significant
Impact
No
Impact
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
On September 25, 2014, Governor Jerry Brown signed Assembly Bill (AB52), which intends to protect a new class of recourse under CEQA. This new class is Tribal Cultural Resources and provides an avenue to identify Tribal Cultural resources through a consultation process. AB52 applies to all projects where a Notice of Determination is filed. Furthermore, the consultation process is required to be complete prior to filing a Notice of Intent.

The Cultural Study prepared by Applied Earthworks, Inc. dated November 2023 (included a records search from the CHRIS SSJVIC, as well as desktop archival research. substantial evidence, to be significant
pursuant to criteria set forth in subdivision
(c) of Public Resources Code Section
5024.1. In applying the criteria set forth in
subdivision (c) of Public Resources Section
5024.1 for the purposes of this paragraph,
the lead agency shall consider the
significance of the resource to a California
Native American Tribe?
City staff conducted Native American Consultation in compliance with AB52. In compliance with AB52, invitations for consultation were mailed on April 8, 2024, which affords Native tribes thirty (30) days to respond and to request consultation. During this timeframe, no requests for consultations were received.

Less-Than-Significant Impact. The Project would include two (2) ingress/egress access points to the proposed development, including access from N. Baron and Perrin Avenues. As part of the Project review, the Clovis Fire Department would review all plans to ensure adequate emergency access is provided. This review includes review for adequate roadway widths, turning radii, as well as adequate access to units and accessibility to water.

Consequently, because the Project plans would be required by the CMC to be reviewed and approved by Clovis Fire Department and Police Department prior to construction, this impact would be less than significant and no mitigation measures are required.

Would the project:_____________________
a. Listed or eligible for listing in the California
Register of Historical Resources, or in a
local register of historical resources as
defined in Public Resources Code section
5020.1(k)?______________________
b. A resource determined by the lead agency,
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consistency and adherence to applicable design and site layout guidelines, a less-than-significant impact would occur and no mitigation measures are required.
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DISCUSSION
No Impact. See discussion under Section 5a.

However,
35 Cultural Resource Study for the Clovis Tract 6452 prepared by Applied Earthworks, Inc., page 21, November 2023. 57 the potential remains that tribal cultural resources could be inadvertently or accidentally uncovered during ground-disturbing activities such as trenching, digging, and the installation of utilities and other infrastructure.

Less-Than-Significant Impact With Mitigation. The site’s ground has been minimally disturbed as a result of some light grading and the mowing of weeds and shrubs. Further, the Cultural Studyconcluded that there was Because there is the slight possibility for the accidental or inadvertent uncovering of tribal cultural resources during construction, Mitigation Measures TCR-1 and TCR-2 would serve to reduce those potential impacts by requiring the stopping of any work until any found artifacts can be properly removed and inventoried by a qualified archaeologist. Therefore, the Project would result in a less-than-significant impact with mitigation.

Mitigation Measure TCR-2: If human remains are discovered during construction or operational activities, further excavation or disturbance shall be prohibited pursuant to Section 7050.5 of the California Health and Safety Code and Project shall follow the procedures and protocols set for un CEQA Guidelines Section 1 5064.4(e)(1). If human remains are identified to be those of Native American, California Health and Safety Code 7050.5 requires the County coroner notify the NAHC within 24 hours of discovery. All b) Would the project cause a substantial adverse change to a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Section 5024.1 for the purposes of this paragraph, the lead agency shall consider the significance of the resource to a California Native American Tribe? If a potentially-eligible resource is encountered, then the qualified professional archaeologist, the Lead Agency, and the project proponent shall arrange for either 1) total avoidance of the resource or 2) test excavations to evaluate eligibility and, if eligible, total data recovery. The determination shall be formally documented in writing and submitted to the Lead Agency as verification that the provisions for managing unanticipated discoveries have been met.
a) Would the project cause a substantial adverse change to a listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)?
Mitigation Measure TCR-1: If archaeological or tribal resources or materials are encountered during construction activities, all work in the immediate vicinity of the find shall halt until a gualified professional archaeologist, can evaluate the significance of the find and make recommendations. Cultural resource materials may include prehistoric resources such as flaked and ground stone tools and debris, shell, bone, ceramics, and fire-affected rock as well as historic resources such as glass, metal, wood, brick, or structural remnants.

If the gualified professional archaeologist determines that the discovery represents a potentially significant cultural resource, additional investigations may be required to mitigate adverse impacts from project implementation. These additional studies may include avoidance, testing, and evaluation or data recovery excavation.

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no evidence of prehistoric archaeological sites, isolated artifacts, or other archaeological features.35 678
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19. UTILITIES AND SERVICE SYSTEMS
X
facilities,telecommunications the
the project and reasonablyserve
X
X
addition to the provider’s existing
X
management reduction and statutes X
regulations related to solid waste?

ENVIRONMENTAL SETTING
58 Potentially
Significant
Impact
Less Than
Significant
Impact
No
Would the project:_____________________ Impact
a. Require or result in the relocation or
construction of new or expanded water,
wastewater treatment or storm water
drainage, electric power, natural gas, or
Less Than
Significant With
Mitigation
Incorporated
Pacific Gas & Electric (PG&E) provides electricity and natural gas services in the City of Clovis. AT&T/SBC provides telephone service to the City.

The City’s water supply sources include groundwater drawn from the Kings Sub-basin of the San Joaquin Valley Groundwater Basin and treated surface water from the FID. Surface water is treated at the City of Clovis Surface Water Treatment Facility.

The City of Clovis provides sewer collection service to its residents and businesses. Treatment of wastewater occurs at the Fresno-Clovis Regional Wastewater Treatment Plant (RWTP). The Fresno-Clovis RWTP is operated and maintained by the City of Fresno and operates under a waste discharge requirement issued by the Central Valley Regional Water Quality Control Board. Additionally, the City of Clovis has completed a 2.8 mgd wastewater treatment/water reuse facility, which will service the City’s new growth areas. construction or relocation of which could
cause significant environmental effects?
b. Have sufficient water supplies available to
foreseeable future development during
normal, dry and multiple dry years?___
c. Result in a determination by the wastewater
treatment provider that serves or may serve
the project that it has adequate capacity to
serve the project’s projected demand in
commitments?___________________
d. Generate solid waste in excess of State or
local standards, or in excess of the capacity
of local infrastructure, or otherwise impair
the attainment of solid waste reduction
goals?__________________________
e. Comply with federal, state, and local
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reports, correspondence, and determinations regarding the discovery of human remains on the project site shall be submitted to the Lead Agency.
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DISCUSSION
59 Less-Than-Significant. The Project would introduce new solid waste throughout construction and operation of the Project. However, the Project would be required to comply with Chapter 6.3.1, Recycling and Diversion of Construction and Demolition Debris, of the CMC during construction. This section of the CMC requires that a minimum of fifty percent (50%) of waste tonnage from a project be diverted from disposal, and that all new residential (and commercial) construction within the City shall submit and obtain approval for a waste management plan prior to construction activities. Compliance with these measures would ensure that the Project a) Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? Less-Than-Significant Impact. Because the Project is of the type previously planned and accounted for in the 2014 Clovis General Plan, it is not likely that the Project would result in a demand that would exceed the capacity of the wastewater treatment facility. Further, the Project is reviewed by the appropriate departments and agencies to ensure compliance and adequate capacity with regard to infrastructure, such as the ability to provide adequate wastewater treatment. Consequently, the impact would be less than significant. No mitigation measures are required.

Less-Than-Significant Impact. The Project is of the type of development previously accounted for the in 2014 Clovis General Plan, and is adjacent to the south with existing urban uses which are served adequately with City water. The Project will be primarily served through surface water and will be required to purchase water allocation rights through Fresno Irrigation District. Therefore, the Project is anticipated to be adequately served by City water. Further, the Project would comply with current Green Building Codes, as well as the water efficient landscape policies with regards to water conserving features. Lastly, the Project would be required to comply several water conserving policies, such as Policy 3.4 and 3.5 of the Open Space and Conservation Element.

Overall, a less-than-significant impact would occur with no mitigation measures. c) Would the project result in a determination by the wastewater treatment provider that serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
Less-Than-Significant Impact. The Project includes construction of 153 residential units. As mentioned above, the site is a use previously accounted for in the 2014 Clovis General Plan. Further, as part of the review process for the Project, the wastewater impacts will be evaluated by the City Engineer to ensure compliance with the City’s Waste Water Master Plan, as well as FMFCD, so that the Project would not exceed wastewater treatment requirements such that a new facility would be required nor would the existing treatment facility need to be expanded. While the Project would introduce new units at this site, the type of development would be consistent with the land use designation and Zone District. Upon review and approval by the City Engineer, the Project would result in a less-than-significant impact. No mitigation measures are required. b) Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? d) Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? LENNAR HOMES (TM6452)

INITIAL STUDY
______________________________________________________________________________________________________________CITY OF CLOVIS The FMFCD has the responsibility for storm water management within the Fresno-Clovis metropolitan area of the Project site. Stormwater runoff that is generated by land development is controlled through a system of pipelines and storm drainage detention basins.
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Less-Than-Significant. See discussion 19d above.

20. WILDFIRE
a. Substantially impair adoptedan
X
X
X
X

ENVIRONMENTAL SETTING

DISCUSSION
36 Calrecycle, City of Clovis, https://www2.calrecvcle.ca.qov/LGCentral/DiversionProqram/JurisdictionDiversionPost2006, accessed April 17, 2024. 60 If located in or near state responsibility
areas or lands classified as very high fire
hazard severity zones, would the project:

Potentially
Significant
Impact
Less Than
Significant
Impact
No
Impact
Less Than
Significant With
Mitigation
Incorporated
The Project site is located on a vacant undeveloped site surrounded by existing residential homes at various densities to the south and east. The site’s topography is generally flat and characterized primarily by low lying shrubs and grasses.
e) Would the project comply with federal, state, and local management reduction statutes and regulations related to solid waste?
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does not result in a significant impact during the construction phase of the Project. Further, compliance with policies in the General Plan for the reduction and recycling of solid waste would serve to reduce impacts of solid waste by promoting and encouraging the recycling of materials. Lastly, according to the California Department of Resources Recycling and Recovery (CalRecycle), the City of Clovis has exceeded their target per resident disposal rate of 4.7 pounds per day per resident, meaning that Clovis residents are actually producing less solid waste than the target set by the State.36 Consequently, a less-than-significant impact would occur. No mitigation measures are required.
emergency response plan or emergency
evacuation plan?___________________
b. Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks, and
thereby expose project occupants to,
pollutant concentrations from a wildfire or
the uncontrolled spread of a wildfire?
c. Require the installation or maintenance of
associated infrastructure (such as roads,
fuel breaks, emergency water sources,
power lines or other utilities) that may
exacerbate fire risk or that may result in
temporary or ongoing impacts to the
environment?___________________
d. Expose people or structures to significant
risks, including downslope or downstream
flooding or landslides, as a result of runoff,
post-fire slope instability, or drainage
changes?
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21. MANDATORY FINDINGS OF SIGNIFICANCE
X
environment, substantially reduce the
61 Potentially
Significant
Impact
Less Than
Significant
Impact
No
Impact
Less-Than-Significant Impact. The Project is located at a site that is surrounded by existing residential development to the south and east. Further, the road network is in construction and will be in place from previous development. Although the Project could result in temporary traffic detouring or closures during buildout, these delays would be temporary and would be coordinated with the City Engineering Division and other departments to ensure safe access to and from the area is maintained. Further, the site itself would be reviewed by City departments to ensure adequate site access and circulation is provided in the event of an emergency. Overall, a less-than-significant impact would occur with no mitigation measures. c) Would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? Less Than
Significant With
Mitigation
Incorporated
Less-Than-Significant Impact. The general vicinity of the site is flat, therefore, is not of the type of topography nor in a location likely to exacerbate wildfire risks. Additionally, the Project site is located in an area mapped by CAL FIRE as “unzoned” per the Fire Hazard Severity Zone Viewer, indicating the area is not located in an area within State Responsibility Areas into Fire Hazard Severity Zones. Further, the Project would be required to comply with the latest fire codes and would be required to include sprinklers on the interior of the homes and require installation of several hydrants throughout the site. Lastly, the site plans would undergo review by the Clovis Fire Department to ensure that all fire safety regulations are met. Project site is Therefore, a less-thansignificant impact would occur with no mitigation measures.

Would the project:_____________________
a. Does the project have the potential to
substantially degrade the quality of the
Less-Than-Significant Impact. As a new development, installation of a private roadway network, water lines, and power lines would be required; however, these utilities and infrastructure are typical of residential development and would be constructed to standards of the respective agencies and departments which oversee them, as well as be required to comply all necessary plan review and permitting requirements of such departments and agencies. As such, a less-than-significant impact would occur. No mitigation measures are required.
b) Would the project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
No impact. The City of Clovis is generally flat topography, and the site itself is in an area that is not in close proximity to hillsides such that it would expose people or structures to significant risks associates with downstream flooding or landslides as a result of runoff or post-fire slope instability. As such, no impact would occur.
d) Would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? LENNAR HOMES (TM6452)

INITIAL STUDY
_________________________________________________________________________________________________________ CITY OF CLOVIS a) Would the project substantially impair an adopted emergency response plan or emergency evacuation plan?
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AGENDA ITEM NO. 13.
b. Does the project have impacts that are
individually limited, but cumulatively
X
X

ENVIRONMENTAL SETTING

DISCUSSION
62 Less-Than-Significant Impact. The Project includes mitigation measures in certain topic areas identified throughout this Initial Study, which would reduce potential impacts to a less-than-significant level. None of these impacts would be cumulatively considerable since most are either temporary impacts from construction or site specific. With the exception of air quality that is generally considered measurable cumulatively, the Project was found to have a less-than-significant impact as discussed in the GHG section of this Initial Study. As such, this Project would be required to comply with those same regulations, ensuring adequate mitigation as development c. Does the project have environmental effects
that will cause substantial adverse effects on
human beings, either directly or indirectly?
a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below selfsustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory?
Less-Than-Significant Impact. As discussed above throughout the Initial Study, the Project would not result in any significant impacts with implementation of mitigation measures prescribed above. Therefore, the Project would have a less-than-significant impact as it would not substantially degrade the quality of the environment.

No mitigation measures are required.
b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects) ?
The Project is located within the sphere of influence of the City of Clovis, within the jurisdiction of the County of Fresno, substantially surrounded by existing development to the south. considerable? (“Cumulatively considerable”
means that the incremental effects of a
project are considerable when viewed in
connection with the effects of past projects,
the effects of other current projects, and the
effects of probable future projects)?
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habitat of a fish or wildlife species, cause a
fish or wildlife population to drop below selfsustaining levels, threaten to eliminate a plant or animal community, substantially
reduce the number or restrict the range of a
rare or endangered plant or animal, or
eliminate important examples of the major
periods of California history or prehistory?
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AGENDA ITEM NO. 13.
63 Less-Than-Significant Impact. As discussed throughout the document, although the Project would result in a significant and unavoidable transportation impact; however, all other effects on human beings either directly or indirectly would not result in an impact that could not be mitigated to a less-than-significant level. Therefore, a less-than-significant impact would occur. No migration measures are required. c) Does the project have environmental effects that will cause substantial adverse effects on human beings, either directly or indirectly?
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______________________________________________________________________________________________________________CITY OF CLOVIS occurs. Lastly, while the Project would introduce 153 new residential units to an existing vacant site, the type of use was previously accounted for in the 2014 Clovis General Plan buildout. Thus, a less-than-significant impact would occur with no mitigation measures.
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AGENDA ITEM NO. 13.

LEAD AGENCY

TECHNICAL STUDIES
64 Traffic Impact Analysis
Proposed Tract 6452
Peters Engineering Group
Air Quality and Greenhouse Impact Assessment
Wilde North at Hertiage Grove Residential Development
Georgiena Vivian, Project Manager
VRPA Technologies, Inc.

Biological Evaluation Report
Lennar Homes Tract 6452
Austin Pearson, Vice President
Rebekah Jenson, Senior Project Manager and Ecologist
Live Oak Associates, Inc.

Cultural Resource Study
Clovis Tract 6254 Residential Development, City of Clovis, Fresno County, California Nicole Saenz
Applied Earthworks, Inc.

Acoustical Analysis
Tract 6452
WJV Acoustics, Inc.

Liz Salazar
Assistant Planner
City of Clovis
Planning & Development Services
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Report Preparation
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MITIGATION MONITORING AND REPORTING PROGRAM
TM6452
Proposed
Mitigation Summary of Measure Monitoring Responsibility Timing Verification
(Date and
Initials)
Biological Resources
BIO-1 Swainson’s Hawk. If possible, construction
activities should occur outside of the avian nesting
season, typically defined as February 1 – August

31. If that is not feasible, pre-construction surveys
shall occur if construction must occur between
February 1 – August 31. A qualified biologist shall
conduct surveys for active bird nests within seven
(7) days prior to the start of work during this period.

The survey area shall encompass the Project site
and accessible surrounding lands within ¼ mile for
nesting Swainson’s hawk, 500 feet for other nesting
raptors, and 250 feet for nesting birds. Should any
active nests be discovered in or near proposed
construction zones, the biologist will identify a
suitable construction free buffer around the nest.

This buffer will be identified on the ground with
flagging or fencing, and will be maintained until the
biologist has determined that the young have
fledged are capable of foraging independently.

City of Clovis Planning Prior to Permits
and During
Construction
Cultural Resources
CULT-1
If archaeological or tribal resources or materials are
encountered during construction activities, all work
in the immediate vicinity of the find shall halt until a qualified professional archaeologist, can evaluate
City of Clovis Planning Prior to Permits
and During
Construction
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AGENDA ITEM NO. 13.

Proposed
Mitigation Summary of Measure Monitoring Responsibility Timing Verification
(Date and
Initials)
the significance of the find and make
recommendations. Cultural resource materials may
include prehistoric resources such as flaked and
ground stone tools and debris, shell, bone,
ceramics, and fire-affected rock as well as historic
resources such as glass, metal, wood, brick, or
structural remnants.

If the qualified professional archaeologist
determines that the discovery represents a
potentially significant cultural resource, additional
investigations may be required to mitigate adverse
impacts from project implementation. These
additional studies may include avoidance, testing,
and evaluation or data recovery excavation.

If a potentially-eligible resource is encountered,
then the qualified professional archaeologist, the
Lead Agency, and the project proponent shall
arrange for either 1) total avoidance of the resource
or 2) test excavations to evaluate eligibility and, if
eligible, total data recovery. The determination shall
be formally documented in writing and submitted to
the Lead Agency as verification that the provisions
for managing unanticipated discoveries have been
met.

CULT-2 If human remains are discovered during
construction or operational activities, further
excavation or disturbance shall be prohibited
pursuant to Section 7050.5 of the California Health
and Safety Code and Project shall follow the
procedures and protocols set for un CEQA
City of Clovis Planning Prior to Permits
and During
Construction
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AGENDA ITEM NO. 13.

Proposed
Mitigation Summary of Measure Monitoring Responsibility Timing Verification
(Date and
Initials)
Guidelines Section 15064.4(e)(1). If human remains
are identified to be those of Native American,
California Health and Safety Code 7050.5 requires
the County coroner notify the NAHC within 24 hours
of discovery. All reports, correspondence, and
determinations regarding the discovery of human
remains on the project site shall be submitted to the
Lead Agency.

Geological Resources
GEO-1
If prehistoric or historic-era cultural materials are
encountered during construction activities, all work
in the immediate vicinity of the find shall halt until a qualified professional archaeologist and/or
paleontologist, can evaluate the significance of the
find and make recommendations. Cultural resource
materials may include prehistoric resources such as
flaked and ground stone tools and debris, shell,
bone, ceramics, and fire-affected rock as well as
historic resources such as glass, metal, wood, brick,
or structural remnants.

If the qualified professional determines that the
discovery represents a potentially significant
cultural resource, additional investigations may be
required to mitigate adverse impacts from project
implementation. These additional studies may
include avoidance, testing, and evaluation or data
recovery excavation.

City of Clovis Planning Prior to Permits
and During
Construction
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Proposed
Mitigation Summary of Measure Monitoring Responsibility Timing Verification
(Date and
Initials)
If a potentially-eligible resource is encountered,
then the qualified professional archaeologist and/or
paleontologist, the Lead Agency, and the project
proponent shall arrange for either 1) total avoidance
of the resource or 2) test excavations to evaluate
eligibility and, if eligible, total data recovery. The
determination shall be formally documented in
writing and submitted to the Lead Agency as
verification that the provisions for managing
unanticipated discoveries have been met.

Greenhouse Gas Emissions
GHG-1 In order to meet the 2022 Scoping Plan 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.

City of Clovis Planning Prior to Permits
and During
Construction
Noise
NOISE-1 Interior Noise. Mechanical ventilation or air
conditioning shall be provided for all homes to
enable windows and doors to remain closed for
sound insulation purposes.

City of Clovis Planning During
Construction and
Prior to
Occupancy
Tribal Cultural Resources
TCR-1
If archaeological or tribal resources or materials are
encountered during construction activities, all work
in the immediate vicinity of the find shall halt until a qualified professional archaeologist, can evaluate
the significance of the find and make
City of Clovis Planning Prior to Permits
and During
Construction
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Proposed
Mitigation Summary of Measure Monitoring Responsibility Timing Verification
(Date and
Initials)
recommendations. Cultural resource materials may
include prehistoric resources such as flaked and
ground stone tools and debris, shell, bone,
ceramics, and fire-affected rock as well as historic
resources such as glass, metal, wood, brick, or
structural remnants.

TCR-2 If human remains are discovered during
construction or operational activities, further
excavation or disturbance shall be prohibited
pursuant to Section 7050.5 of the California Health
and Safety Code and Project shall follow the
procedures and protocols set for un CEQA
Guidelines Section 15064.4(e)(1). If human remains
City of Clovis Planning Prior to Permits
and During
Construction
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AGENDA ITEM NO. 13.

Proposed
Mitigation Summary of Measure Monitoring Responsibility Timing Verification
(Date and
Initials)
are identified to be those of Native American,
California Health and Safety Code 7050.5 requires
the County coroner notify the NAHC within 24 hours
of discovery. All reports, correspondence, and
determinations regarding the discovery of human
remains on the project site shall be submitted to the
Lead Agency.
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AGENDA ITEM NO. 13.

Wilde North at Heritage Grove Residential Development
Air Quality & Greenhouse Gas Impact Assessment
January, 2024
Prepared by:

VRPA Technologies, Inc.
4630 W. Jennifer, Suite 105
Fresno, CA 93722
Project Manager: Georgiena Vivian
VRPA TECHNOLOGIES, INC.

Appendix A
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AGENDA ITEM NO. 13.

Table of Contents
Section Description Page

1.0 Introduction 1

1.1 Description of the Region/Project 1

1.2 Regulatory 1

1.2.1 Federal Agencies 1

1.2.2 Federal Regulations 5

1.2.3 State Agencies 6

1.2.4 State Regulations 11

1.2.5 Regional Agencies 14

1.2.6 Regional Regulations 15

1.2.7 Local Plans 17

2.0 Environmental Setting 18

2.1 Geographical Locations 18

2.2 Topographic Conditions 18

2.3 Climate Conditions 18

2.4 Anthropogenic (Man-made) Sources 20

2.4.1 Motor Vehicles 21

2.4.2 Agricultural and Other Miscellaneous 22

2.4.3 Industrial Plants 22

2.5 San Joaquin Valley Air Basin Monitoring 22

2.6 Air Quality Standards 25

2.6.1 Ozone (1-hour and 8-hour) 25

2.6.2 Suspended PM (PM10 and PM2.5) 27

2.6.3 Carbon Monoxide (CO) 28

2.6.4 Nitrogen Dioxide (NO2) 29

2.6.5 Sulfur Dioxide (SO2) 31

2.6.6 Lead (Pb) 31

2.6.7 Toxic Air Contaminants (TAC) 31

2.6.8 Odors 34

2.6.9 Naturally Occurring Asbestos (NOA) 35

2.6.10 Greenhouse Gas Emissions 35
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3.0 Air Quality Impacts 37

3.1 Methodology 37

3.1.1 CalEEMod 37

3.2 Short-Term Impacts 38

3.3 Long Term Emissions 39

3.3.1 Localized Operational Emissions 39
Ozone/Particulate Matter 39

3.3.2 Other Localized Operational Emissions 39

3.3.3 Indirect Source Review 50

4.0 Impact Determinations and Recommended
Mitigation 51

4.1 Air Quality 51

4.1.1 Conflict with or obstruct implementation
of the applicable air quality plan 51

4.1.2 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 52

4.1.3 Expose sensitive receptors to substantial
pollutant concentrations 52

4.1.4 Result in other emissions such as those leading to odors adversely affecting a substantial number of people 54

4.2 Greenhouse Gas Emissions 55

4.2.1 Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact
on the environment 55

4.2.2 Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases 57
Appendices
Appendix A – CalEEMod Worksheets
Appendix B– ISR FEE Estimate
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AGENDA ITEM NO. 13.

List of Tables
1 Ambient Air Quality Standards 9
2 Maximum Pollutant Levels at Fresno Garland Monitoring Station 23 3 Kings County Attainment Status 24
4 Recommendations on Siting New Sensitive Land Uses Such As Residences, Schools, Daycare Centers, Playgrounds, or Medical Facilities 33
5 Screening Levels for Potential Odor Sources 35
6 SJVAPCD Air Quality Thresholds of Significance 37
7 Project Construction Emissions 39
8 Project Operational Emissions (tons/year) 39
9 2005/2020 Operational Greenhouse Gas Emissions (tons/year) 50 10 Project Operational Greenhouse Gas Emissions (tons/year) 50 List of Figures
1 Regional Location 3
2 Project Location 4
3 San Joaquin Valley Air Basin 8
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1.0 Introduction

1.1 Description of the Region/Project
The proposed project aims to develop 153 single-family residential units in on Northern portion Clovis in unincorporated area of Fresno County. The project site spans approximately 18.23 acres of land and is situated in the northeast portion of Baron and Perrin Avenue within the sphere of influence of City of Clovis. It is positioned approximately 2.5 miles north of State Route (SR) 168 within the City of Clovis, which is located in Fresno County.

This Air Quality & Greenhouse Gas Impact Assessment has been prepared for the purpose of identifying potential project-specific or site-specific air quality impacts that may result from the Project. Figures 1 and 2 show the location of the Project long with major roadways and highways.

The City of Clovis is located in Fresno County one of the most polluted air basins in the country – the San Joaquin Valley Air Basin (SJVAB). The surrounding topography includes foothills and mountains to the east and west. These mountain ranges direct air circulation and dispersion patterns. Temperature inversions can trap air within the Valley, thereby preventing the vertical dispersal of air pollutants. In addition to topographic conditions, the local climate can also contribute to air quality problems. Climate in Fresno is characterized by hot, dry summers and cool winters with the notable presence of Tule fog.

1.2 Regulatory
Air quality within the Project area is addressed through the efforts of various federal, state, regional, and local government agencies. These agencies work jointly, as well as individually, to improve air quality through legislation, regulations, planning, policymaking, education, and a variety of programs. The agencies primarily responsible for improving the air quality within the City of Clovis and Fresno County are discussed below along with their individual responsibilities.

1.2.1 Federal Agencies
✓ U.S. Environmental Protection Agency (EPA)
The Federal Clean Air Bill first adopted in 1967 and periodically amended since then, established federal ambient air quality standards. A 1987 amendment to the Bill set a deadline for the attainment of these standards. That deadline has since passed. The other Clean Air Act (CAA) Bill Amendments, passed in 1990, share responsibility with the State in reducing emissions from mobile sources. The U.S. Environmental Protection Agency (EPA) is responsible for enforcing the 1990 amendments.

The CAA and the national ambient air quality standards identify levels of air quality for six “criteria” pollutants, which are considered the maximum levels of ambient air pollutants considered safe, with an adequate margin of safety, to protect public health and welfare. The VftPA I TECHNOLOGIES INC.
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AGENDA ITEM NO. 13.
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six criteria pollutants include ozone, carbon monoxide (CO), nitrogen dioxide, sulfur dioxide, particulate matter, and lead.

CAA Section 176(c) (42 U.S.C. 7506(c)) and EPA transportation conformity regulations (40 CFR 93 Subpart A) require that each new RTP and Transportation Improvement Program (TIP) be demonstrated to conform to the State Implementation Plan (SIP) before the RTP and TIP are approved by the Metropolitan planning organization (MPO) or accepted by the U.S.

Department of Transportation (DOT). The conformity analysis is a federal requirement designed to demonstrate compliance with the National Ambient Air Quality Standards (NAAQS). However, because the State Implementation Plan (SIP) for particulate matter 10 microns or less in diameter (PM10), particulate matter 2.5 microns or less in diameter (PM2.5), and Ozone address attainment of both the State and federal standards, for these pollutants, demonstrating conformity to the federal standards is also an indication of progress toward attainment of the State standards. Compliance with the State air quality standards is provided on the pages following this federal conformity discussion.

The EPA approved San Joaquin Valley reclassification of the ozone (8-hour) designation to extreme nonattainment in the Federal Register on May 5, 2010, even though the San Joaquin Valley was initially classified as serious nonattainment for the 1997 8-hour ozone standard.

In accordance with the CAA, EPA uses the design value at the time of standard promulgation to assign nonattainment areas to one of several classes that reflect the severity of the nonattainment problem; classifications range from marginal nonattainment to extreme nonattainment. In the Federal Register on October 26, 2015, the EPA revised the primary and secondary standard to 0.070 parts per million (ppm) to provide increased public health protection against health effects associated with long- and short-term exposures. The previous ozone standard was set in 2010 at 0.075 ppm.

Fresno County is located in a nonattainment area for the 8-hour ozone standard, PM2.5 standard, and PM10 standard.

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AGENDA ITEM NO. 13.
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1.2.2 Federal Regulations
✓ National Environmental Policy Act (NEPA)
NEPA provides general information on the effects of federally funded projects. The Act was implemented by regulations included in the Code of Federal Regulations (40CFR6). The code requires careful consideration concerning environmental impacts of federal actions or plans, including projects that receive federal funds. The regulations address impacts on land uses and conflicts with state, regional, or local plans and policies, among others. They also require that projects requiring NEPA review seek to avoid or minimize adverse effects of proposed actions and to restore and enhance environmental quality as much as possible. ✓ State Implementation Plan (SIP)/ Air Quality Management Plans (AQMPs) To ensure compliance with the NAAQS, EPA requires states to adopt SIP aimed at improving air quality in areas of nonattainment or a Maintenance Plan aimed at maintaining air quality in areas that have attained a given standard. New and previously submitted plans, programs, district rules, state regulations, and federal controls are included in the SIPs. Amendments made in 1990 to the federal CAA established deadlines for attainment based on an area’s current air pollution levels. States must enact additional regulatory programs for nonattainment’s areas in order to adhere with the CAA Section 172. In California, the SIPs must adhere to both the NAAQS and the California Ambient Air Quality Standards (CAAQS).

To ensure that State and federal air quality regulations are being met, Air Quality Management Plans (AQMPs) are required. AQMPs present scientific information and use analytical tools to identify a pathway towards attainment of NAAQS and CAAQS. The San Joaquin Valley Air Pollution Control District (SJVAPCD) develops the AQMPs for the region where the Fresno Council of Governments(FCOG) operates. The regional air districts begin the SIP process by submitting their AQMPs to the California Air Resources Board (CARB). CARB is responsible for revising the SIP and submitting it to EPA for approval. EPA then acts on the SIP in the Federal Register. The items included in the California SIP are listed in the Code of Federal Regulations Title 40, Chapter 1, Part 52, Subpart 7, Section 52.220. ✓ Transportation Control Measures
One particular aspect of the SIP development process is the assessment of available transportation control measures (TCMs) as a part of making progress towards clean air goals.

TCMs are defined in Section 108(f)(1) of the CAA and are strategies designed to reduce vehicle miles traveled, vehicle idling, and associated air pollution. These goals are generally achieved by developing attractive and convenient alternatives to single-occupant vehicle use.

Examples of TCMs include ridesharing programs, transportation infrastructure improvements such as adding bicycle and carpool lanes, and expansion of public transit.

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✓ Energy Policy Act of 1992 (EPAct)
The Energy Policy Act of 1992 (EPAct) was passed to reduce the country’s dependence on foreign petroleum and improve air quality. EPAct includes several parts intended to build an inventory of alternative fuel vehicles (AFVs) in large, centrally fueled fleets in metropolitan areas. EPAct requires certain federal, state, and local government and private fleets to purchase a percentage of light duty AFVs capable of running on alternative fuels each year.

In addition, financial incentives are included in EPAct. Federal tax deductions will be allowed for businesses and individuals to cover the incremental cost of alternative fueled vehicles (AFVs). States are also required by the act to consider a variety of incentive programs to help promote AFVs.

1.2.3 State Agencies
✓ California Air Resources Board (CARB)
CARB is the agency responsible for coordination and oversight of State and local air pollution control programs in California and for implementing its own air quality legislation called the California Clean Air Act (CCAA), adopted in 1988. CARB was created in 1967 from the merging of the California Motor Vehicle Pollution Control Board and the Bureau of Air Sanitation and its Laboratory.

CARB has primary responsibility in California to develop and implement air pollution control plans designed to achieve and maintain the NAAQS established by the EPA. Whereas CARB has primary responsibility and produces a major part of the SIP for pollution sources that are statewide in scope, it relies on the local air districts to provide additional strategies for sources under their jurisdiction. CARB combines its data with all local district data and submits the completed SIP to the EPA. The SIP consists of the emissions standards for vehicular sources and consumer products set by CARB, and attainment plans adopted by the Air Pollution Control Districts (APCDs) and Air Quality Management District’s (AQMDs) and approved by CARB.

States may establish their own standards, provided the State standards are at least as stringent as the NAAQS. California has established California Ambient Air Quality Standards (CAAQS) pursuant to California Health and Safety Code (CH&SC) [§39606(b)] and its predecessor statutes.

The CH&SC [§39608] requires CARB to “identify” and “classify” each air basin in the State on a pollutant-by-pollutant basis. Subsequently, CARB designated areas in California as nonattainment based on violations of the CAAQSs. Designations and classifications specific to the SJVAB can be found in the next section of this document. Areas in the State were also classified based on severity of air pollution problems. For each nonattainment class, the CCAA specifies air quality management strategies that must be adopted. For all nonattainment categories, attainment plans are required to demonstrate a five percent-perVftPA I TECHNOLOGIES INC. 701
AGENDA ITEM NO. 13.
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year reduction in nonattainment air pollutants or their precursors, averaged every consecutive three-year period, unless an approved alternative measure of progress is developed. In addition, air districts in violation of CAAQS are required to prepare an Air Quality Attainment Plan (AQAP) that lays out a program to attain and maintain the CCAA mandates.

CARB, in consultation with MPOs, has provided each affected region with reduction targets for GHGs emitted by passenger cars and light trucks in the region for the years 2020 and 2035.

For the Fresno Council of Governments (FCOG) region, CARB set targets at six(6) percent per capita decrease in 2020 and a thirteen (13) percent per capita decrease in 2035 from a base year of 2005. FCOG’s 2022 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), which was adopted in July 2022, projects that the Fresno County region would achieve the prescribed emissions targets.

Other CARB duties include monitoring air quality. CARB has established and maintains, in conjunction with local APCDs and AQMDs, a network of sampling stations (called the State and Local Air Monitoring [SLAMS] network), which monitor the present pollutant levels in the ambient air.

Fresno County is in the CARB-designated, SJVAB. A map of the SJVAB is provided in Figure 3.

In addition to Fresno County, the SJVAB includes Kings, Kern, Madera, Merced, San Joaquin, Stanislaus, and Tulare Counties. Federal and State standards for criteria pollutants are provided in Table 1.

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Table 1
Ambient Air Quality Standards
Concentration 3 Method 4Primary 3,5 Secondary 3,6 Method 7 1 Hour 0.09 ppm (180 µg/m3
) --
8 Hour 0.070 ppm (137 µg/m3
) 0.070 ppm (137 µg/m3)
24 Hour 50 µg/m3
150 µg/m3
Annual
Arithmetic Mean 20 µg/m3
--
24 Hour -- -- 35 µg/m3
Same as
Primary Standard
Annual
Arithmetic Mean 12 µg/m3 Gravimetric or Beta Attenuation 12.0 µg/m3 15 µg/m3
1 Hour 20 ppm (23 mg/m3
) 35 ppm (40 mg/m3) --
8 Hour 9.0 ppm (10 mg/m3
) 9 ppm (10 mg/m3) --
8 Hour
(Lake Tahoe) 6 ppm (7 mg/m3
) -- --
1 Hour 0.18 ppm (339 µg/m3
) 100 ppb (188 µg/m3) --
Annual
Arithmetic Mean 0.030 ppm (57 µg/m3
) 0.053 ppm (100 µg/m3)
Same as
Primary Standard
1 Hour 0.25 ppm (655 µg/m3
) 75 ppb (196 µg/m3) --
3 Hour -- --

0.5 ppm
(1300 µg/m3)
24 Hour 0.04 ppm (105 µg/m3
)

0.14 ppm
(for cetain areas) 11 --
Annual
Arithmetic Mean
--

0.030 ppm
(for cetain areas) 11 --
30 Day Average 1.5 µg/m3-- --
Calendar
Quarter
--

1.5 µg/m3
(for certain areas)11
Rolling 3-Month
Average
-- 0.15 µg/m3
Visibility Reducing
Particles 14 8 Hour See footnote 14
Beta Attenuation
and Transmittance
through Filter Tape
Sulfates 24 Hour 25 µg/m3Ion Chromatography
Hydrogen Sulfide 1 Hour 0.03 ppm (42 µg/m3
)
Ultraviolet
Fluorescence
Vinyl Chloride 12 24 Hour 0.01 ppm (26 µg/m3)
Gas
Chromatography
Nitrogen Dioxide
(NO2) 10
Sulfur Dioxide
(SO2) 11
Ultraviolet
Fluorescence
Ultraviolet
Fluorescence;
Spectrophotometry
(Pararosaniline
Method)
Gravimetric or
Beta Attenuation
Same as
Primary Standard
Inertial Separation
and Gravimetric
Analysis
Gas Phase
Chemiluminescence
Gas Phase
Chemiluminescence
No
National
Standards
Lead 12,13
High Volume
Sampler and Atomic
Absorption Same as
Primary Standard
Atomic Absorption
Pollutant
Averaging
Time
California Standards 1 National Standards 2
Ozone (O3) 8 Ultraviolet
Photometry
Same as
Primary Standard
Ultraviolet
Photometry
Fine Particulate
Matter (PM2.5) 9
Inertial Separation
and Gravimetric
Analysis
Carbon Monoxide
(CO)
Non-Dispersive
Infrared Photometry
(NDIR)
Non-Dispersive
Infrared Photometry
(NDIR)
See footnotes on next page …
Respirable
Particulate Matter
(PM10) 9
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Footnotes:

1. California standards for ozone, carbon monoxide (except 8-hour Lake Tahoe), sulfur dioxide (1 and 24 hour), nitrogen dioxide, and particulate matter (PM10, PM2.5, and visibility reducing particles), are values that are not to be exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations.

2. National standards (other than ozone, particulate matter, and those based on annual arithmetic mean) are not to be exceeded more than once a year. The ozone standard is attained when the fourth highest 8-hour concentration measured at each site in a year, averaged over three years, is equal to or less than the standard. For PM10, the 24 hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 μg/m3 is equal to or less than one. For PM2.5, the 24 hour standard is attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard. Contact the U.S. EPA for further clarification and current national policies.

3. Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas.

4. Any equivalent measurement method which can be shown to the satisfaction of the ARB to give equivalent results at or near the level of the air quality standard may be used.

5. National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health.

6. National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.

7. Reference method as described by the U.S. EPA. An “equivalent method” of measurement may be used but must have a “consistent relationship to the reference method” and must be approved by the U.S. EPA.

8. On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to 0.070 ppm.

9. On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 μg/m3 to 12.0 μg/m3. The existing national 24-hour PM2.5 standards (primary and secondary) were retained at 35 μg/m3, as was the annual secondary standard of 15 μg/m3. The existing 24-hour PM10 standards (primary and secondary) of 150 μg/m3 also were retained. The form of the annual primary and secondary standards is the annual mean, averaged over 3 years.

10. To attain the 1-hour national standard, the 3-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site must not exceed 100 ppb. Note that the national 1-hour standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm). To directly compare the national 1-hour standard to the California standards the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm.

11. On June 2, 2010, a new 1-hour SO2 standard was established and the existing 24-hour and annual primary standards were revoked. To attain the 1- hour national standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved.

Note that the 1-hour national standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm). To directly compare the 1-hour national standard to the California standard the units can be converted to ppm. In this case, the national standard of 75 ppb is identical to 0.075 ppm.

12. The ARB has identified lead and vinyl chloride as 'toxic air contaminants' with no threshold level of exposure for adverse health effects determined.

These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants.

13. The national standard for lead was revised on October 15, 2008 to a rolling 3-month average. The 1978 lead standard (1.5 μg/m3 as a quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.

14. In 1989, the ARB converted both the general statewide 10-mile visibility standard and the Lake Tahoe 30-mile visibility standard to instrumental equivalents, which are "extinction of 0.23 per kilometer" and "extinction of 0.07 per kilometer" for the statewide and Lake Tahoe Air Basin standards, respectively.

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1.2.4 State Regulations
✓ CARB Mobile-Source Regulation
The State of California is responsible for controlling emissions from the operation of motor vehicles in the State. Rather than mandating the use of specific technology or the reliance on a specific fuel, CARB’s motor vehicle standards specify the allowable grams of pollutant per mile driven. In other words, the regulations focus on the reductions needed rather than on the manner in which they are achieved.
✓ California Clean Air Act
The CCAA was first signed into law in 1988. The CCAA provides a comprehensive framework for air quality planning and regulation, and spells out, in statute, the state’s air quality goals, planning and regulatory strategies, and performance. The CCAA establishes more stringent ambient air quality standards than those included in the Federal CAA. CARB is the agency responsible for administering the CCAA. CARB established ambient air quality standards pursuant to the CH&SC [§39606(b)], which are similar to the federal standards. The SJVAPCD is one of 35 AQMDs that have prepared air quality management plans to accomplish a five percent (5%) annual reduction in emissions documenting progress toward the State ambient air quality standards.
✓ Tanner Air Toxics Act
California regulates Toxic Air Contaminants (TACs) primarily through the Tanner Air Toxics Act (AB 1807) and the Air Toxics Hot Spots Information and Assessment Act of 1987 (AB 2588).

The Tanner Act sets forth a formal procedure for CARB to designate substances as TACs. This includes research, public participation, and scientific peer review before CARB can designate a substance as a TAC. To date, CARB has identified more than 21 TACs and has adopted EPA's list of Hazardous Air Pollutants (HAPs) as TACs. Once a TAC is identified, CARB then adopts an Airborne Toxics Control Measure (ATCM) for sources that emit that particular TAC. If there is a safe threshold for a substance at which there is no toxic effect, the control measure must reduce exposure below that threshold. If there is no safe threshold, the measure must incorporate Best Available Control Technology (BACT) to minimize emissions.

AB 2588 requires that existing facilities that emit toxic substances above a specified level prepare a toxic-emission inventory, prepare a risk assessment if emissions are significant, notify the public of significant risk levels, and prepare and implement risk reduction measures. CARB has adopted diesel exhaust control measures and more stringent emission standards for various on-road mobile sources of emissions, including transit buses and offroad diesel equipment (e.g., tractors, generators).

These rules and standards provide for:

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▪ More stringent emission standards for some new urban bus engines, beginning with 2002 model year engines.
▪ Zero-emission bus demonstration and purchase requirements applicable to transit agencies
▪ Reporting requirements under which transit agencies must demonstrate compliance with the urban transit bus fleet rule.
✓ AB 1493 (Pavley)
AB 1493 (Pavley) enacted on July 22, 2002, required CARB to develop and adopt regulations that reduce greenhouse gases emitted by passenger vehicles and light duty trucks.

Regulations adopted by CARB would apply to 2009 and later model year vehicles. CARB estimated that the regulation would reduce climate change emissions from light duty passenger vehicles by an estimated 18 percent in 2020 and by 27 percent in 2030 [Association of Environmental Professionals (AEP) 2007)]. In 2005, the CARB requested a waiver from U.S.

EPA to enforce the regulation, as required under the CAA. Despite the fact that no waiver had ever been denied over a 40-year period, the then Administrator of the EPA sent Governor Schwarzenegger a letter in December 2007, indicating he had denied the waiver. On March 6, 2008, the waiver denial was formally issued in the Federal Register. Governor Schwarzenegger and several other states immediately filed suit against the federal government to reverse that decision. On January 21, 2009, CARB requested that EPA reconsider denial of the waiver. EPA scheduled a re-hearing on March 5, 2009. On June 30, 2009, EPA granted a waiver of CAA preemption to California for its greenhouse gas emission standards for motor vehicles beginning with the 2009 model year. ✓ Assembly Bill 32 (California Global Warming Solutions Act of 2006) California passed the California Global Warming Solutions Act of 2006 (AB 32; California Health and Safety Code Division 25.5, Sections 38500 - 38599). AB 32 establishes regulatory, reporting, and market mechanisms to achieve quantifiable reductions in GHG emissions and establishes a cap on statewide GHG emissions. AB 32 required that statewide GHG emissions be reduced to 1990 levels by 2020. December 31, 2020 is the deadline for achieving the 2020 GHG emissions cap. To effectively implement the cap, AB 32 directs CARB to develop and implement regulations to reduce statewide GHG emissions from stationary sources. AB 32 specifies that regulations adopted in response to AB 1493 should be used to address GHG emissions from vehicles. However, AB 32 also includes language stating that if the AB 1493 regulations cannot be implemented, then CARB should develop new regulations to control vehicle GHG emissions under the authorization of AB 32.

AB 32 requires CARB to adopt a quantified cap on GHG emissions representing 1990 emissions levels and disclose how it arrived at the cap; institute a schedule to meet the emissions cap; and develop tracking, reporting, and enforcement mechanisms to ensure that the state reduces GHG emissions enough to meet the cap. AB 32 also includes guidance on instituting emissions reductions in an economically efficient manner, along with conditions VftPA I TECHNOLOGIES INC.
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to ensure that businesses and consumers are not unfairly affected by the reductions. Using these criteria to reduce statewide GHG emissions to 1990 levels by 2020 would represent an approximate 25 to 30 percent reduction in current emissions levels. However, CARB has discretionary authority to seek greater reductions in more significant and growing GHG sectors, such as transportation, as compared to other sectors that are not anticipated to significantly increase emissions.

CARB’s 2017 Climate Change Scoping Plan builds on the efforts and plans encompassed in the initial Scoping Plan adopted in December of 2008. The current plan has identified new policies and actions to accomplish the State’s 2030 GHG limit. ✓ Senate Bill 375
SB 375, signed in September 2008 (Chapter 728, Statutes of 2008), aligns regional transportation planning efforts, regional GHG reduction targets, and land use and housing allocation. SB 375 requires Metropolitan Planning Organizations (MPOs) to adopt a sustainable communities strategy (SCS) or alternative planning strategy (APS) that will prescribe land use allocation in that MPO's regional transportation plan. CARB, in consultation with MPOs, has provided each affected region with reduction targets for GHGs emitted by passenger cars and light trucks in the region for the years 2020 and 2035. For the Fresno Council of Governments(FCOG), CARB set targets at six (6) percent per capita decrease in 2020 and a thirteen (13) percent per capita decrease in 2035 from a base year of 2018.

FCOG 2022 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), which was adopted in July 2022, projects that the Fresno County region would achieve the prescribed emissions targets.

This law also extends the minimum time period for the regional housing needs allocation cycle from five years to eight years for local governments located within an MPO that meets certain requirements. City or county land use policies (including general plans) are not required to be consistent with the regional transportation plan (and associated SCS or APS).

However, new provisions of CEQA incentivize (through streamlining and other provisions) qualified projects that are consistent with an approved SCS or APS, categorized as "transit priority projects."
✓ Executive Order B-30-15
Executive Order B-30-15, which was signed by Governor Brown in 2016, establishes a California greenhouse gas reduction target of 40 percent below 1990 levels by 2030 to ensure California meets its target of reducing greenhouse gas emissions to 80 percent below 1990 levels by 2050. Executive Order B-30-15 requires MPO’s to implement measures that will achieve reductions of greenhouse gas emissions to meet the 2030 and 2050 greenhouse gas emissions reductions targets.

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✓ California Global Warming Solutions Act of 2006: emissions limit, or SB 32 SB 32 is a California Senate bill expanding upon AB 32 to reduce greenhouse gas (GHG) emissions. SB 32 was signed into law on September 8, 2016, by Governor Brown. SB 32 sets into law the mandated reduction target in GHG emissions as written into Executive Order B30-15. SB 32 requires that there be a reduction in GHG emissions to 40% below the 1990 levels by 2030. Greenhouse gas emissions include carbon dioxide, methane, nitrous oxide, sulfur hexafluoride, hydrofluorocarbons, and perfluorocarbons. The California Air Resources Board (CARB) is responsible for ensuring that California meets this goal. The provisions of SB 32 were added to Section 38566 of the Health and Safety Code subsequent to the bill’s approval. The bill went into effect January 1, 2017. SB 32 builds onto Assembly Bill (AB) 32 written by Senator Fran Pavley and Assembly Speaker Fabian Nunez passed into law on September 27, 2006. AB 32 required California to reduce greenhouse gas emissions to 1990 levels by 2020 and SB 32 continues that timeline to reach the targets set in Executive Order B-30-15. SB 32 provides another intermediate target between the 2020 and 2050 targets set in Executive Order S-3-05.

1.2.5 Regional Agencies
✓ San Joaquin Valley Air Pollution Control District
The SJVAPCD is the agency responsible for monitoring and regulating air pollutant emissions from stationary, area, and indirect sources within Fresno County and throughout the SJVAB.

The District also has responsibility for monitoring air quality and setting and enforcing limits for source emissions. CARB is the agency with the legal responsibility for regulating mobile source emissions. The District is precluded from such activities under State law.

The District was formed in mid-1991 and prepared and adopted the San Joaquin Valley Air Quality Attainment Plan (AQAP), dated January 30, 1992, in response to the requirements of the State CCAA. The CCAA requires each non-attainment district to reduce pertinent air contaminants by at least five percent (5%) per year until new, more stringent, 1988 State air quality standards are met.

Activities of the SJVAPCD include the preparation of plans for the attainment of ambient air quality standards, adoption and enforcement of rules and regulations concerning sources of air pollution, issuance of permits for stationary sources of air pollution, inspection of stationary sources of air pollution and response to citizen complaints, monitoring of ambient air quality and meteorological conditions, and implementation of programs and regulations required by the FCAA and CCAA.

The SJVAPCD has prepared the following State Implementation Plans to address ozone, PM10 and PM2.5 that currently apply to non-attainment areas:
▪ The 2016 Ozone Plan (2008 standard) was adopted by SJVAPCD on June 16, 2016 and subsequently adopted by ARB on July 21, 2016.

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▪ The 2013 1-Hour Ozone Plan (revoked 1997 standard) was adopted by the SJVAPCD on September 19, 2013. EPA withdrew its approval of the plan due to litigation. The District plans to submit a “redesignation substitute” to EPA to maintain its attainment status for this revoked ozone standard.
▪ The 2007 PM-10 Maintenance Plan (as revised in 2015) was approved by EPA on July 8, 2016 (effective September 30, 2016).
▪ The 2012 PM2.5 Plan (as revised in 2015) was approved by EPA on August 16, 2016 (effective September 30, 2016).

The SJVAPCD Plans identified above represent SJVAPCD’s plan to achieve both state and federal air quality standards. The regulations and incentives contained in these documents must be legally enforceable and permanent. These plans break emissions reductions and compliance into different emissions source categories.

The SJVAPCD also prepared the Guide for Assessing and Mitigation Air Quality Impacts (GAMAQI), dated March 19, 2015. The GAMAQI is an advisory document that provides Lead Agencies, consultants, and project applicants with analysis guidance and uniform procedures for addressing air quality impacts in environmental documents. Local jurisdictions are not required to utilize the methodology outlined therein. This document describes the criteria that SJVAPCD uses when reviewing and commenting on the adequacy of environmental documents. It recommends thresholds for determining whether or not projects would have significant adverse environmental impacts, identifies methodologies for predicting project emissions and impacts, and identifies measures that can be used to avoid or reduce air quality impacts.

1.2.6 Regional Regulations
The SJVAPCD has adopted numerous rules and regulations to implement its air quality plans.

Following, are significant rules that will apply to the Project. ✓ Regulation VIII – Fugitive PM10 Prohibitions
Regulation VIII is comprised of District Rules 8011 through 8081, which 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, landfill operations, etc. The proposed Project will be required to comply with this regulation. Regulation VIII control measures are provided below:

1. 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.

2. All on-site unpaved roads and off-site unpaved access roads shall be effectively stabilized of dust emissions using water or chemical stabilizer/suppressant.

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3. All land clearing, grubbing, scraping, excavation, land leveling, grading, cut & fill, and demolition activities shall be effectively controlled of fugitive dust emissions utilizing application of water or by presoaking.

4. When materials are transported off-site, all material shall be covered, or effectively wetted to limit visible dust emissions, and at least six inches of freeboard space from the top of the container shall be maintained.

5. 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.

7. Within urban areas, track out shall be immediately removed when it extends 50 or more feet from the site and at the end of each workday.
✓ Rule 8021 – Construction, Demolition, Excavation, and Other Earthmoving Activities District Rule 8021 requires owners or operators of construction projects to submit a Dust Control Plan to the District if at any time the project involves non-residential developments of five or more acres of disturbed surface area or moving, depositing, or relocating of more than 2,500 cubic yards per day of bulk materials on at least three days of the project or residential projects which include 10 or more acres of disturbed surface area. The proposed Project will meet these criteria and will be required to submit a Dust Control Plan to the District in order to comply with this rule.
✓ Rule 4641 – Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operations
If asphalt paving will be used, then paving operations of the proposed Project will be subject to Rule 4641. This rule applies to the manufacture and use of cutback asphalt, slow cure asphalt and emulsified asphalt for paving and maintenance operations. ✓ Rule 9510 – Indirect Source Review (ISR)
The purpose of this rule is to fulfill the District’s emission reduction commitments in the PM10 and Ozone Attainment Plans, achieve emission reductions from construction activities, and to provide a mechanism for reducing emissions from the construction of and use of development projects through off-site measures. The rule is expected to reduce nitrogen oxides and particulates throughout the San Joaquin Valley by more than 10 tons per day.

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1.2.7 Local Plans
✓ City of Clovis General Plan
California State Law requires every city and county to adopt a comprehensive General Plan to guide its future development. The General Plan essentially serves as a “constitution for development”— the document that serves as the foundation for all land use decisions. The City of Clovis 2035 General Plan Update (2014) includes various elements, including air quality and greenhouse gases, that address local concerns and provides goals and policies to achieve its development goals.

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2.0 Environmental Setting
This section describes existing air quality within the San Joaquin Valley Air Basin and in Fresno County, including the identification of air pollutant standards, meteorological and topological conditions affecting air quality, and current air quality conditions. Air quality is described in relation to ambient air quality standards for criteria pollutants such as, ozone, carbon monoxide, and particulate matter. Air quality can be directly affected by the type and density of land use change and population growth in urban and rural areas.

2.1 Geographical Location
The SJVAB is comprised of eight counties: Fresno, Kern, Kings, Madera, Merced, San Joaquin, Stanislaus, and Tulare. Encompassing 24,840 square miles, the San Joaquin Valley is the second largest air basin in California. Cumulatively, counties within the Air Basin represent approximately 16 percent of the State's geographic area. The Air Basin is bordered by the Sierra Nevada Mountains on the east (8,000 to 14,492 feet in elevation), the Coastal Range on the west (4,500 feet in elevation), and the Tehachapi Mountains on the south (9,000 feet elevation). The San Joaquin Valley is open to the north extending to the Sacramento Valley Air Basin.

2.2 Topographic Conditions
Fresno County is located within the San Joaquin Valley Air Basin [as determined by the California Air Resources Board (CARB)]. Air basins are geographic areas sharing a common "air shed." A description of the Air Basin in the County, as designated by CARB, is provided in the paragraph below. Air pollution is directly related to the region's topographic features, which impact air movement within the Basin.

Wind patterns within the SJVAB result from marine air that generally flows into the Basin from the San Joaquin River Delta. The Coastal Range hinders wind access into the Valley from the west, the Tehachapi’s prevent southerly passage of airflow, and the high Sierra Nevada Mountain Range provides a significant barrier to the east. These topographic features result in weak airflow that becomes restricted vertically by high barometric pressure over the Valley. As a result, the SJVAB is highly susceptible to pollutant accumulation over time. Most of the surrounding mountains are above the normal height of summer inversion layers (1,500-3,000 feet).

2.3 Climate Conditions
Fresno is located in one of the most polluted air basins in the country. Temperature inversions can trap air within the Valley, thereby preventing the vertical dispersal of air pollutants. In addition to topographic conditions, the local climate can also contribute to air quality problems.

Climate in Fresno is characterized by warm, dry summers and cool winters with significant Tule fog.

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Ozone, classified as a “regional” pollutant, often afflicts areas downwind of the original source of precursor emissions. Ozone can be easily transported by winds from a source area. Peak ozone levels tend to be higher in the southern portion of the Valley, as the prevailing summer winds sweep precursors downwind of northern source areas before concentrations peak. The separate designations reflect the fact that ozone precursor transport depends on daily meteorological conditions.

Other primary pollutants, carbon monoxide (CO), for example, may form high concentrations when wind speed is low. During the winter, Fresno experiences cold temperatures and calm conditions that increase the likelihood of a climate conducive to high CO concentrations.

Precipitation and fog tend to reduce or limit some pollutant concentrations. Ozone needs sunlight for its formation, and clouds and fog block the required radiation. CO is slightly watersoluble, so precipitation and fog tends to “reduce” CO concentrations in the atmosphere. PM10 is somewhat “washed” from the atmosphere with precipitation. Precipitation in the San Joaquin Valley is strongly influenced by the position of the semi-permanent subtropical high-pressure belt located off the Pacific coast. In the winter, this high- pressure system moves southward, allowing Pacific storms to move through the San Joaquin Valley. These storms bring in moist, maritime air that produces considerable precipitation on the western, upslope side of the Coast Ranges.

Significant precipitation also occurs on the western side of the Sierra Nevada. On the valley floor, however, there is some down slope flow from the Coast Ranges and the resultant evaporation of moisture from associated warming results in a minimum of precipitation. Nevertheless, the majority of the precipitation falling in the San Joaquin Valley is produced by those storms during the winter. Precipitation during the summer months is in the form of convective rain showers and is rare. It is usually associated with an influx of moisture into the San Joaquin Valley through the San Francisco area during an anomalous flow pattern in the lower layers of the atmosphere.

Although the hourly rates of precipitation from these storms may be high, their rarity keeps monthly totals low.

Precipitation on the San Joaquin Valley floor and in the Sierra Nevada decreases from north to south. Stockton in the north receives about 20 inches of precipitation per year, Fresno in the center, receives about 10 inches per year, and Bakersfield at the southern end of the valley receives less than 6 inches per year. This is primarily because the Pacific storm track often passes through the northern part of the state while the southern part of the state remains protected by the Pacific High. Precipitation in the San Joaquin Valley Air Basin (SJVAB) is confined primarily to the winter months with some also occurring in late summer and fall. Average annual rainfall for the entire San Joaquin Valley is approximately 5 to 16 inches. Snowstorms, hailstorms, and ice storms occur infrequently in the San Joaquin Valley and severe occurrences of any of these are very rare.

The winds and unstable air conditions experienced during the passage of storms result in periods of low pollutant concentrations and excellent visibility. Between winter storms, high pressure and light winds allow cold moist air to pool on the San Joaquin Valley floor. This creates strong VftPA I TECHNOLOGIES INC.
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low-level temperature inversions and very stable air conditions. This situation leads to the San Joaquin Valley’s famous Tule Fogs. The formation of natural fog is caused by local cooling of the atmosphere until it is saturated (dew point temperature). This type of fog, known as radiation fog, is more likely to occur inland. Cooling may also be accomplished by heat radiation losses or by horizontal movement of a mass of air over a colder surface. This second type of fog, known as advection fog, generally occurs along the coast.

Conditions favorable to fog formation are also conditions favorable to high concentrations of CO and PM10. Ozone levels are low during these periods because of the lack of sunlight to drive the photochemical reaction. Maximum CO concentrations tend to occur on clear, cold nights when a strong surface inversion is present and large numbers of fireplaces are in use. A secondary peak in CO concentrations occurs during morning commute hours when a large number of motorists are on the road and the surface inversion has not yet broken.

The water droplets in fog, however, can act as a sink for CO and nitrogen oxides (NOx), lowering pollutant concentrations. At the same time, fog could help in the formation of secondary particulates such as ammonium sulfate. These secondary particulates are believed to be a significant contributor of winter season violations of the PM10 and PM2.5 standards.

2.4 Anthropogenic (Man-made) Sources
In addition to climatic conditions (wind, lack of rain, etc.), air pollution can be caused by anthropogenic or man-made sources. Air pollution in the SJVAB can be directly attributed to human activities, which cause air pollutant emissions. Human causes of air pollution in the Valley consist of population growth, urbanization (gas-fired appliances, residential wood heaters, etc.), mobile sources (i.e., cars, trucks, airplanes, trains, etc.), oil production, agriculture, and other socioeconomic activities. The most significant factors, which are accelerating the decline of air quality in the SJVAB, are the Valley's rapid population growth and its associated increases in traffic, urbanization, and industrial activity.

Carbon monoxide emissions overwhelmingly come from mobile sources in the San Joaquin Valley; on-road vehicles contributed 34 percent, while other mobile vehicles, such as trains, planes, and off-road vehicles, contribute another 20 percent in 2012 according to emission projections from the CARB. Motor vehicles account for significant portions of regional gaseous and particulate emissions. Local large employers such as industrial plants can also generate substantial regional gaseous and particulate emissions. In addition, construction and agricultural activities can generate significant temporary gaseous and particulate emissions (dust, ash, smoke, etc.).

Ozone is the result of a photochemical reaction between Oxides of nitrogen (NOx) and Reactive Organic Gases (ROG). Mobile sources contribute 84 percent of all NOx emitted from anthropogenic sources based on data provided in Appendix B of the Air District’s 2016 Ozone VftPA I TECHNOLOGIES INC.
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Plan. In addition, mobile sources contribute 26 percent of all the ROG emitted from sources within the San Joaquin Valley.

The principal factors that affect air quality in and around Fresno are:

1. The sink effect, climatic subsidence and temperature inversions and low wind speeds

2. Automobile and truck travel

3. Increases in mobile and stationary pollutants generated by local urban growth Automobiles, trucks, buses and other vehicles using hydrocarbon (HC) fuels release exhaust products into the air. Each vehicle by itself does not release large quantities; however, when considered as a group, the cumulative effect is significant.

Other sources may not seem to fit into any one of the major categories or they may seem to fit in a number of them. These could include agricultural uses, dirt roads, animal shelters; animal feed lots, chemical plants and industrial waste disposal, which may be a source of dust, odors, or other pollutants. For Fresno County, this category includes several agriculturally related activities, such as plowing, harvesting, dusting with herbicides and pesticides and other related activities. Finally, industrial contaminants and their potential to produce various effects depend on the size and type of industry, pollution controls, local topography, and meteorological conditions. Major sources of industrial emissions in Fresno County consist of agricultural production and processing operations.

The primary contributors of PM10 emissions in the San Joaquin Valley are farming activities (22%) and road dust, both paved and unpaved (35%) in 2020 according to emission projections from the CARB. Fugitive windblown dust from “open” fields contributed 14 percent of the PM10.

The four major sources of air pollutant emissions in the SJVAB include industrial plants, motor vehicles, construction activities, and agricultural activities. Industrial plants account for significant portions of regional gaseous and particulate emissions. Motor vehicles, including those from large employers, generate substantial regional gaseous and particulate emissions.

Finally, construction and agricultural activities can generate significant temporary gaseous and particulate emissions (dust, ash, smoke, etc.). In addition to these primary sources of air pollution, urban areas upwind from Fresno County including areas north and west of the San Joaquin Valley, can cause or generate emissions that are transported into Fresno County. All four of the major pollutant sources affect ambient air quality throughout the Air Basin.

2.4.1 Motor Vehicles
Automobiles, trucks, buses and other vehicles using hydrocarbon fuels release exhaust products into the air. Each vehicle by itself does not release large quantities; however, when considered as a group, the cumulative effect is significant.

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2.4.2 Agricultural and Other Miscellaneous Activities
Other sources may not seem to fit into any one of the major categories or they may seem to fit in a number of them. These could include agricultural uses, dirt roads, animal shelters, animal feed lots, chemical plants and industrial waste disposal, which may be a source of dust, odors, or other pollutants. For Fresno, this category includes several agriculturally related activities, such as plowing, harvesting, dusting with herbicides and pesticides and other related activities.

2.4.3 Industrial Plants
Industrial contaminants and their potential to produce various effects depend on the size and type of industry, pollution controls, local topography, and meteorological conditions. Major sources of industrial emissions in Fresno County consist of agricultural production and processing operations.

2.5 San Joaquin Valley Air Basin Monitoring
SJVAPCD and the CARB maintain numerous air quality monitoring sites throughout each County in the Air Basin to measure ozone, PM2.5, and PM10. It is important to note that the federal ozone 1-hour standard was revoked by the EPA and is no longer applicable for federal standards.

The closest monitoring station to the Project is located at Clovis-N Villa Avenue Monitoring Station. The station monitors particulates, ozone, carbon monoxide, and nitrogen dioxide.

Monitoring data for the past three years is summarized in Table 2.

Table 3 identifies the Fresno County’s attainment status. As indicated, the SJVAB is nonattainment for Ozone (1 hour and 8 hour) and PM. In accordance with the FCAA, EPA uses the design value at the time of standard promulgation to assign nonattainment areas to one of several classes that reflect the severity of the nonattainment problem; classifications range from marginal nonattainment to extreme nonattainment. The FCAA contains provisions for changing the classifications using factors such as clean air progress rates and requests from States to move areas to a higher classification.

On April 16, 2004 EPA issued a final rule classifying the SJVAB as extreme nonattainment for Ozone, effective May 17, 2004 (69 FR 20550). The (federal) 1-hour ozone standard was revoked on June 6, 2005. However, many of the requirements in the 1-hour attainment plan (SIP) continue to apply to the SJVAB. The current ozone plan is the (federal) 8-hour ozone plan adopted in 2007. The SJVAB was reclassified from a "serious" nonattainment area for the 8-hour ozone standard to “extreme” effective June 4, 2010.

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Table 2
Maximum Pollutant Levels at Clovis
Clovis-N Villa Monitoring Station
Time 2020 2021 2022
Pollutant Averaging Maximums Maximums Maximums National State Ozone (O3) 1 hour 0.142 ppm 0.123 ppm 0.109 ppm 0.119 ppm 0.114 ppm Ozone (O3) 8 hour 0.108ppm 0.1 ppm 0.084 ppm 0.070 ppm 0.070 ppm Nitrogen Dioxide (NO2) 1 hour 54 ppm 49 ppm 51 ppm 51 ppm 60 ppm Nitrogen Dioxide (NO2) Annual Average 9 ppm 8 ppm 9 ppm 8 ppm 8 ppm Particulates (PM10) 24 hour 296.4 µg/m3
281.0 µg/m3116.1 µg/m342 µg/m348 µg/m3
Particulates (PM10)
Federal Annual
Arithmetic Mean 45.8 µg/m3

37.6 µg/m335.5 µg/m3
- 18 µg/m3
Particulates (PM2.5) 24 hour 193.7 µg/m3
104.6 µg/m341.9 µg/m315.5 µg/m3
-
Particulates (PM2.5)
Federal Annual
Arithmetic Mean

18.4 µg/m3 15.1 µg/m3 10.5 µg/m3 - 18 µg/m3
Standards
"-"represents insufficient data available to determine the value.

Source: California Air Resources Board (ADAM) Air Pollution Summaries VftPA I TECHNOLOGIES INC.
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Table 3
Fresno County Attainment Status
Pollutant Federal Standards State Standards
Ozone - 1 Hour Revoked in 2005 Nonattainment
Ozone - 8 Hour Nonattainment/Extreme No State Standard
PM10 Attainment Nonattainment
PM2.5 Nonattainment Nonattainment
Carbon Monoxide Unclassified/Attainment Unclassified
Nitrogen Dioxide Unclassified/Attainment Attainment
Sulfur Dioxide Unclassified/Attainment Attainment
Lead (Particulate) Unclassified/Attainment Attainment
Hydrogen Sulfide No Federal Standard Unclassified
Sulfates No Federal Standard Attainment
Visibility Reducing Particles No Federal Standard Unclassified Source: CARB Website, 2023
Designation/Classification
a. Though the Valley was initially classified as serious nonattainment for the 1997 8-hour ozone standard, EPA approved Valley reclassification to extreme nonattainment in the Federal Register on May 5, 2010 (effective June 4, 2010).

Notes:

National Designation Categories
Non-Attainment Area: Any area that does not meet (or that contributes to ambient air quality in a nearby area that does not meet) the national primary or secondary ambient air quality standard for the pollutant.

Unclassified/Attainment Area: Any area that cannot be classified on the basis of available information as meeting or not meeting the national primary or secondary ambient air quality standard for the pollutant or meets the national primary or secondary ambient air quality standard for the pollutant.

State Designation Categories
Unclassified: A pollutant is designated unclassified if the data are incomplete and do not support a designation of attainment or non-attainment.

Attainment: A pollutant is designated attainment if the State standard for that pollutant was not violated at any site in the area during a three-year period.

Non-attainment: A pollutant is designated non-attainment if there was at least one violation of a State standard for that pollutant in the area.

Non-Attainment/Transitional: A subcategory of the non-attainment designation. An area is designated nonattainment/transitional to signify that the area is close to attaining the standard for the pollutant.

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2.6 Air Quality Standards
The FCAA, first adopted in 1963, and periodically amended since then, established National Ambient Air Quality Standards (NAAQS). A set of 1977 amendments determined a deadline for the attainment of these standards. That deadline has since passed. Other CAA amendments, passed in 1990, share responsibility with the State in reducing emissions from mobile sources.

In 1988, the State of California passed the CCAA (State 1988 Statutes, Chapter 568), which set forth a program for achieving more stringent California Ambient Air Quality Standards. The CARB implements State ambient air quality standards, as required in the CCAA, and cooperates with the federal government in implementing pertinent sections of the FCAA Amendments (FCAAA).

Further, CARB regulates vehicular emissions throughout the State. The SJVAPCD regulates stationary sources, as well as some mobile sources. Attainment of the more stringent State PM10 Air Quality Standards is not currently required.

The EPA uses six "criteria pollutants" as indicators of air quality and has established for each of them a maximum concentration above which adverse effects on human health may occur. These threshold concentrations are called the NAAQS.

The SJVAPCD operates regional air quality monitoring networks that provide information on average concentrations of pollutants for which State or federal agencies have established ambient air quality standards. Descriptions of nine pollutants of importance in Fresno County follow.

2.6.1 Ozone (1-hour and 8-hour)
The most severe air quality problem in the Air Basin is the high level of ozone. Ozone occurs in two layers of the atmosphere. The layer surrounding the earth’s surface is the troposphere.

Here, ground level, or “bad” ozone, is an air pollutant that damages human health, vegetation, and many common materials. It is a key ingredient of urban smog. The troposphere extends to a level about 10 miles up, where it meets the second layer, the stratosphere. The stratospheric, or “good” ozone layer, extends upward from about 10 to 30 miles and protects life on earth from the sun’s harmful ultraviolet rays.
“Bad” ozone is what is known as a photochemical pollutant. It needs reactive organic gases (ROG), NOx, and sunlight. ROG and NOx are emitted from various sources throughout Fresno County. In order to reduce ozone concentrations, it is necessary to control the emissions of these ozone precursors.

Significant ozone formation generally requires an adequate amount of precursors in the atmosphere and several hours in a stable atmosphere with strong sunlight. High ozone concentrations can form over large regions when emissions from motor vehicles and stationary VftPA I TECHNOLOGIES INC.
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sources are carried hundreds of miles from their origins.

Ozone is a regional air pollutant. It is generated over a large area and is transported and spread by wind. Ozone, the primary constituent of smog, is the most complex, difficult to control, and pervasive of the criteria pollutants. Unlike other pollutants, ozone is not emitted directly into the air by specific sources. Ozone is created by sunlight acting on other air pollutants (called precursors), specifically NOx and ROG. Sources of precursor gases to the photochemical reaction that form ozone number in the thousands. Common sources include consumer products, gasoline vapors, chemical solvents, and combustion products of various fuels. Originating from gas stations, motor vehicles, large industrial facilities, and small businesses such as bakeries and dry cleaners, the ozone-forming chemical reactions often take place in another location, catalyzed by sunlight and heat. High ozone concentrations can form over large regions when emissions from motor vehicles and stationary sources are carried hundreds of miles from their origins. Approximately 50 million people lived in counties with air quality levels above the EPA’s health-based national air quality standard in 1994. The highest levels of ozone were recorded in Los Angeles, closely followed by the San Joaquin Valley. High levels also persist in other heavily populated areas, including the Texas Gulf Coast and much of the Northeast.

While the ozone in the upper atmosphere absorbs harmful ultraviolet light, ground-level ozone is damaging to the tissues of plants, animals, and humans, as well as to a wide variety of inanimate materials such as plastics, metals, fabrics, rubber, and paints. Societal costs from ozone damage include increased medical costs, the loss of human and animal life, accelerated replacement of industrial equipment, and reduced crop yields. ✓ Health Effects
While ozone in the upper atmosphere protects the earth from harmful ultraviolet radiation, high concentrations of ground-level ozone can adversely affect the human respiratory system. Many respiratory ailments, as well as cardiovascular disease, are aggravated by exposure to high ozone levels. Ozone also damages natural ecosystems, such as: forests and foothill communities; agricultural crops; and some man-made materials, such as rubber, paint, and plastic. High levels of ozone may negatively affect immune systems, making people more susceptible to respiratory illnesses, including bronchitis and pneumonia. Ozone accelerates aging and exacerbates pre-existing asthma and bronchitis and, in cases with high concentrations, can lead to the development of asthma in active children. Active people, both children and adults, appear to be more at risk from ozone exposure than those with a low level of activity. Additionally, the elderly and those with respiratory disease are also considered sensitive populations for ozone.

People who work or play outdoors are at a greater risk for harmful health effects from ozone.

Children and adolescents are also at greater risk because they are more likely than adults to spend time engaged in vigorous activities. Research indicates that children under 12 years of age spend nearly twice as much time outdoors daily than adults. Teenagers spend at least VftPA I TECHNOLOGIES INC.
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twice as much time as adults in active sports and outdoor activities. In addition, children inhale more air per pound of body weight than adults, and they breathe more rapidly than adults. Children are less likely than adults to notice their own symptoms and avoid harmful exposures.

Ozone is a powerful oxidant—it can be compared to household bleach, which can kill living cells (such as germs or human skin cells) upon contact. Ozone can damage the respiratory tract, causing inflammation and irritation, and it can induce symptoms such as coughing, chest tightness, shortness of breath, and worsening of asthmatic symptoms. Ozone in sufficient doses increases the permeability of lung cells, rendering them more susceptible to toxins and microorganisms. Exposure to levels of ozone above the current ambient air quality standard leads to lung inflammation and lung tissue damage and a reduction in the amount of air inhaled into the lungs.

The CARB found ozone standards in Fresno County nonattainment of Federal and State standards.

2.6.2 Suspended PM (PM10 and PM2.5)
Particulate matter pollution consists of very small liquid and solid particles that remain suspended in the air for long periods. Some particles are large or concentrated enough to be seen as soot or smoke. Others are so small they can be detected only with an electron microscope. Particulate matter is a mixture of materials that can include smoke, soot, dust, salt, acids, and metals. Particulate matter is emitted from stationary and mobile sources, including diesel trucks and other motor vehicles; power plants; industrial processes; wood-burning stoves and fireplaces; wildfires; dust from roads, construction, landfills, and agriculture; and fugitive windblown dust. PM10 refers to particles less than or equal to 10 microns in aerodynamic diameter. PM2.5 refers to particles less than or equal to 2.5 microns in aerodynamic diameter and are a subset of PM10. Particulates of concern are those that are 10 microns or less in diameter. These are small enough to be inhaled, pass through the respiratory system and lodge in the lungs, possibly leading to adverse health effects.

In the western United States, there are sources of PM10 in both urban and rural areas. Because particles originate from a variety of sources, their chemical and physical compositions vary widely. The composition of PM10 and PM2.5 can also vary greatly with time, location, the sources of the material and meteorological conditions. Dust, sand, salt spray, metallic and mineral particles, pollen, smoke, mist, and acid fumes are the main components of PM10 and PM2.5. In addition to those listed previously, secondary particles can also be formed as precipitates from chemical and photochemical reactions of gaseous sulfur dioxide (SO2) and NOx in the atmosphere to create sulfates (SO4) and nitrates (NO3). Secondary particles are of greatest concern during the winter months where low inversion layers tend to trap the precursors of secondary particulates.

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The District’s 2008 PM2.5 Plan built upon the aggressive emission reduction strategy adopted in the 2007 Ozone Plan and strives to bring the valley into attainment status for the 1997 NAAQS for PM2.5. The District’s 2012 PM2.5 Plan provides multiple control strategies to reduce emissions of PM2.5 and other pollutants that form PM2.5. The plan’s comprehensive control strategy includes regulatory actions, incentive programs, technology advancement, policy and legislative positions, public outreach, participation and communication, and additional strategies.
✓ Health Effects
PM10 and PM2.5 particles are small enough—about one-seventh the thickness of a human hair, or smaller—to be inhaled and lodged in the deepest parts of the lung where they evade the respiratory system’s natural defenses. Health problems begin as the body reacts to these foreign particles. Acute and chronic health effects associated with high particulate levels include the aggravation of chronic respiratory diseases, heart and lung disease, and coughing, bronchitis, and respiratory illnesses in children. Recent mortality studies have shown a statistically significant direct association between mortality and daily concentrations of particulate matter in the air. Non-health-related effects include reduced visibility and soiling of buildings. PM10 can increase the number and severity of asthma attacks, cause or aggravate bronchitis and other lung diseases, and reduce the body’s ability to fight infections.

PM10 and PM2.5 can aggravate respiratory disease and cause lung damage, cancer, and premature death.

Although particulate matter can cause health problems for everyone, certain people are especially vulnerable to adverse health effects of PM10. These “sensitive populations” include children, the elderly, exercising adults, and those suffering from chronic lung disease such as asthma or bronchitis. Of greatest concern are recent studies that link PM10 exposure to the premature death of people who already have heart and lung disease, especially the elderly. Acidic PM10 can also damage manmade materials and is a major cause of reduced visibility in many parts of the United States.

The CARB found PM10 standards in Fresno County in attainment of Federal standards and nonattainment for State standards. The CARB found PM2.5 standards in Fresno County nonattainment of Federal and State standards.

2.6.3 Carbon Monoxide (CO)
Carbon monoxide (CO) is emitted by mobile and stationary sources as a result of incomplete combustion of hydrocarbons or other carbon-based fuels. CO is an odorless, colorless, poisonous gas that is highly reactive. CO is a byproduct of motor vehicle exhaust, contributes more than two thirds of all CO emissions nationwide. In cities, automobile exhaust can cause as much as 95 percent of all CO emissions. These emissions can result in high concentrations of CO, particularly in local areas with heavy traffic congestion. Other sources of CO emissions include industrial VftPA I TECHNOLOGIES INC.
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processes and fuel combustion in sources such as boilers and incinerators. Despite an overall downward trend in concentrations and emissions of CO, some metropolitan areas still experience high levels of CO.
✓ Health Effects
CO enters the bloodstream and binds more readily to hemoglobin than oxygen, reducing the oxygen-carrying capacity of blood and thus reducing oxygen delivery to organs and tissues.

The health threat from CO is most serious for those who suffer from cardiovascular disease.

Healthy individuals are also affected but only at higher levels of exposure. At high concentrations, CO can cause heart difficulties in people with chronic diseases and can impair mental abilities. Exposure to elevated CO levels is associated with visual impairment, reduced work capacity, reduced manual dexterity, poor learning ability, difficulty performing complex tasks, and in prolonged, enclosed exposure, death.

The adverse health effects associated with exposure to ambient and indoor concentrations of CO are related to the concentration of carboxyhemoglobin (COHb) in the blood. Health effects observed may include an early onset of cardiovascular disease; behavioral impairment; decreased exercise performance of young, healthy men; reduced birth weight; sudden infant death syndrome (SIDS); and increased daily mortality rate.

Most of the studies evaluating adverse health effects of CO on the central nervous system examine high-level poisoning. Such poisoning results in symptoms ranging from common flu and cold symptoms (shortness of breath on mild exertion, mild headaches, and nausea) to unconsciousness and death.

The CARB found CO standards in Fresno County as unclassified/attainment of Federal standards and attainment for State standards.

2.6.4 Nitrogen Dioxide (NO2)
Nitrogen oxides (NOx) is a family of highly reactive gases that are primary precursors to the formation of ground-level ozone and react in the atmosphere to form acid rain. NOx is emitted from combustion processes in which fuel is burned at high temperatures, principally from motor vehicle exhaust and stationary sources such as electric utilities and industrial boilers. A brownish gas, NOx is a strong oxidizing agent that reacts in the air to form corrosive nitric acid, as well as toxic organic nitrates. EPA regulates only nitrogen dioxide (NO2) as a surrogate for this family of compounds because it is the most prevalent form of NOx in the atmosphere that is generated by anthropogenic (human) activities.1
1 United States Environmental Protection Agency (EPA), Nitrogen Oxides (NOx). Why and How They Are Controlled, 456/F-99- 006R, November 2019
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✓ Health Effects
NOx is an ozone precursor that combines with Reactive Organic Gases (ROG) to form ozone.

See the ozone section above for a discussion of the health effects of ozone.

Direct inhalation of NOx can also cause a wide range of health effects. NOx can irritate the lungs, cause lung damage, and lower resistance to respiratory infections such as influenza.

Short-term exposures (e.g., less than 3 hours) to low levels of nitrogen dioxide (NO2) may lead to changes in airway responsiveness and lung function in individuals with preexisting respiratory illnesses. These exposures may also increase respiratory illnesses in children.

Long-term exposures to NO2 may lead to increased susceptibility to respiratory infection and may cause irreversible alterations in lung structure. Other health effects associated with NOx are an increase in the incidence of chronic bronchitis and lung irritation. Chronic exposure to NO2 may lead to eye and mucus membrane aggravation, along with pulmonary dysfunction.

NOx can cause fading of textile dyes and additives, deterioration of cotton and nylon, and corrosion of metals due to production of particulate nitrates. Airborne NOx can also impair visibility. NOx is a major component of acid deposition in California. NOx may affect both terrestrial and aquatic ecosystems. NOx in the air is a potentially significant contributor to a number of environmental effects such as acid rain and eutrophication in coastal waters.

Eutrophication occurs when a body of water suffers an increase in nutrients that reduce the amount of oxygen in the water, producing an environment that is destructive to fish and other animal life.

NO2 is toxic to various animals as well as to humans. Its toxicity relates to its ability to combine with water to form nitric acid in the eye, lung, mucus membranes, and skin. Studies of the health impacts of NO2 include experimental studies on animals, controlled laboratory studies on humans, and observational studies.

In animals, long-term exposure to NOx increases susceptibility to respiratory infections, lowering their resistance to such diseases as pneumonia and influenza. Laboratory studies show susceptible humans, such as asthmatics, exposed to high concentrations of NO2, can suffer lung irritation and, potentially, lung damage. Epidemiological studies have also shown associations between NO2 concentrations and daily mortality from respiratory and cardiovascular causes as well as hospital admissions for respiratory conditions.

NOx contributes to a wide range of environmental effects both directly and when combined with other precursors in acid rain and ozone. Increased nitrogen inputs to terrestrial and wetland systems can lead to changes in plant species composition and diversity. Similarly, direct nitrogen inputs to aquatic ecosystems such as those found in estuarine and coastal waters can lead to eutrophication as discussed above. Nitrogen, alone or in acid rain, also can acidify soils and surface waters. Acidification of soils causes the loss of essential plant nutrients and increased levels of soluble aluminum, which is toxic to plants. Acidification of surface waters creates conditions of low pH and levels of aluminum that are toxic to fish and other aquatic organisms.

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The CARB found NO2 standards in Fresno County as unclassified/attainment of Federal standards and attainment for State standards.

2.6.5 Sulfur Dioxide (SO2)
The major source of sulfur dioxide (SO2) is the combustion of high-sulfur fuels for electricity generation, petroleum refining and shipping. High concentrations of SO2 can result in temporary breathing impairment for asthmatic children and adults who are active outdoors. Short-term exposures of asthmatic individuals to elevated SO2 levels during moderate activity may result in breathing difficulties that can be accompanied by symptoms such as wheezing, chest tightness, or shortness of breath. Other effects that have been associated with longer-term exposures to high concentrations of SO2, in conjunction with high levels of PM, include aggravation of existing cardiovascular disease, respiratory illness, and alterations in the lungs’ defenses. SO2 also is a major precursor to PM2.5, which is a significant health concern and a main contributor to poor visibility. In humid atmospheres, sulfur oxides can react with vapor to produce sulfuric acid, a component of acid rain.

The CARB found SO2 standards in Fresno County as unclassified for Federal standards and attainment for State standards.

2.6.6 Lead (Pb)
Lead, a naturally occurring metal, can be a constituent of air, water, and the biosphere. Lead is neither created nor destroyed in the environment, so it essentially persists forever. Lead was used until recently to increase the octane rating in automobile fuel. Since the 1980s, lead has been phased out in gasoline, reduced in drinking water, reduced in industrial air pollution, and banned or limited in consumer products. Gasoline-powered automobile engines were a major source of airborne lead through the use of leaded fuels; however, the use of leaded fuel has been mostly phased out. Since this has occurred the ambient concentrations of lead have dropped dramatically.

Exposure to lead occurs mainly through inhalation of air and ingestion of lead in food, water, soil, or dust. It accumulates in the blood, bones, and soft tissues and can adversely affect the kidneys, liver, nervous system, and other organs. Excessive exposure to lead may cause neurological impairments such as seizures, mental retardation, and behavioral disorders. Even at low doses, lead exposure is associated with damage to the nervous systems of fetuses and young children.

Effects on the nervous systems of children are one of the primary health risk concerns from lead.

In high concentrations, children can even suffer irreversible brain damage and death. Children 6 years old and under are most at risk, because their bodies are growing quickly.

The CARB found Lead standards in Fresno County as unclassified/attainment of Federal standards and attainment for State standards.

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2.6.7 Toxic Air Contaminants (TAC)
In addition to the criteria pollutants discussed above, Toxic Air Contaminants (TAC) are another group of pollutants of concern. TAC are injurious in small quantities and are regulated despite the absence of criteria documents. The identification, regulation and monitoring of TAC is relatively recent compared to that for criteria pollutants. Unlike criteria pollutants, TAC are regulated on the basis of risk rather than specification of safe levels of contamination. The ten TAC are acetaldehyde, benzene, 1,3-butadiene, carbon tetrachloride, hexavalent chromium, para-dichlorobenzene, formaldehyde, methylene chloride, perchloroethylene, and diesel particulate matter (diesel PM). Caltrans’ guidance for transportation studies references the Federal Highway Administration (FHWA) memorandum titled “Interim Guidance on Air Toxic Analysis in NEPA Documents” which discusses emissions quantification of six “priority” compounds of 21 Mobile Source Air Toxics (MSAT) identified by the United States Environmental Protection Agency (USEPA). The six “priority” compounds are diesel exhaust (particulate matter and organic gases), benzene, 1,3-butadiene, acetaldehyde, formaldehyde, and acrolein.

Some studies indicate that diesel PM poses the greatest health risk among the TAC listed above.

A 10-year research program (California Air Resources Board 1998) demonstrated that diesel PM from diesel-fueled engines is a human carcinogen and that chronic (long-term) inhalation exposure to diesel PM poses a chronic health risk. In addition to increasing the risk of lung cancer, exposure to diesel exhaust can have other health effects. Diesel exhaust can irritate the eyes, nose, throat, and lungs, and it can cause coughs, headaches, lightheadedness, and nausea. Diesel exhaust is a major source of fine particulate pollution as well, and studies have linked elevated particle levels in the air to increased hospital admissions, emergency room visits, asthma attacks, and premature deaths among those suffering from respiratory problems.

Diesel PM differs from other TAC in that it is not a single substance but a complex mixture of hundreds of substances. Although diesel PM is emitted by diesel-fueled, internal combustion engines, the composition of the emissions varies, depending on engine type, operating conditions, fuel composition, lubricating oil, and whether an emission control system is present.

Unlike the other TAC, however, no ambient monitoring data are available for diesel PM because no routine measurement method currently exists. The CARB has made preliminary concentration estimates based on a diesel PM exposure method. This method uses the CARB emissions inventory’s PM10 database, ambient PM10 monitoring data, and the results from several studies to estimate concentrations of diesel PM. Table 4 depicts the CARB Handbook’s recommended buffer distances associated with various types of common sources.

Existing air quality concerns within Fresno and the entire SJVAB are related to increases of regional criteria air pollutants (e.g., ozone and particulate matter), exposure to toxic air contaminants, odors, and increases in greenhouse gas emissions contributing to climate change.

The primary source of ozone (smog) pollution is motor vehicles. Particulate matter is caused by dust, primarily dust generated from construction and grading activities, and smoke which is emitted from fireplaces, wood-burning stoves, and agricultural burning.

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TABLE 4
Recommendations on Siting New Sensitive Land Uses Such As Residences, Schools, Daycare Centers, Playgrounds, or Medical Facilities*

SOURCE CATEGORY ADVISORY RECOMMENDATIONS
Freeways and High-Traffic Roads 1
- 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.

Distribution Centers
- Avoid siting new sensitive land uses within 1,000 feet of a distribution center (that accommodates more than 100 trucks per day, more than 40 trucks with operating transport refrigeration units (TRUs) per day, or where TRU unit operations exceed 300 hours per week).
- Take into account the configuration of existing distribution centers and avoid locating residences and other new sensitive land uses near entry and exit points.

Rail Yards
- Avoid siting new sensitive land uses within 1,000 feet of a major service and maintenance rail yard. - Within one mile of a rail yard, consider possible siting limitations and mitigation approaches.

Ports
- Avoid siting of new sensitive land uses immediately downwind of ports in the most heavily impacted zones. Consult local air districts or the ARB on the status of pending analyses of health risks.

Refineries - Avoid siting new sensitive land uses immediately downwind of petroleum refineries. Consult with local air districts and other local agencies to determine an appropriate separation.

Chrome Platers - Avoid siting new sensitive land uses within 1,000 feet of a chrome plater.

Dry Cleaners Using Perchloroethylene
- Avoid siting new sensitive land uses within 300 feet of any dry cleaning operation. For operations with two or more machines, provide 500 feet. For operations with 3 or more machines, consult with the local air district.
- Do not site new sensitive land uses in the same building with perchloroethylene dry cleaning operations.

Gasoline Dispensing Facilities
- Avoid siting new sensitive land uses within 300 feet of a large gas station (defined as a facility with a throughput of 3.6 million gallons per year or greater). A 50 foot separation is recommended for typical gas dispensing facilities.

Source: SJVAPCD 2022
1: The recommendation to avoid siting new sensitive land uses within 500 feet of a freeway was identified in CARB’s Air Quality and Land Use Handbook published in 2005. CARB recently published a technical advisory to the Air Quality and Land Use Handbook indicating that new research has demonstrated promising strategies to reduce pollution exposure along transportation corridors. *Notes:
• These recommendations are advisory. Land use agencies have to balance other considerations, including housing and transportation needs, economic development priorities, and other quality of life issues. • Recommendations are based primarily on data showing that the air pollution exposures addressed here (i.e., localized) can be reduced as much as 80% with the recommended separation.
• The relative risk for these categories varies greatly (see Table 1-2). To determine the actual risk near a particular facility, a site-specific analysis would be required. Risk from diesel PM will decrease over time as cleaner technology phases in. • These recommendations are designed to fill a gap where information about existing facilities may not be readily available and are not designed to substitute for more specific information if it exists. The recommended distances take into account other factors in addition to available health risk data (see individual category descriptions).
• Site-specific project design improvements may help reduce air pollution exposures and should also be considered when siting new sensitive land uses.
• This table does not imply that mixed residential and commercial development in general is incompatible. Rather it focuses on known problems like dry cleaners using perchloroethylene that can be addressed with reasonable preventative actions. • A summary of the basis for the distance recommendations can be found in the ARB Handbook: Air Quality and Land Use Handbook: A Community Health Perspective.

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2.6.8 Odors
Typically, odors are regarded as an annoyance rather than a health hazard. However, manifestations of a person’s reaction to foul odors can range from psychological (e.g., irritation, anger, or anxiety) to physiological (e.g., circulatory and respiratory effects, nausea, vomiting, and headache).

With respect to odors, the human nose is the sole sensing device. The ability to detect odors varies considerably among the population and overall is quite subjective. Some individuals have the ability to smell minute quantities of specific substances; others may not have the same sensitivity but may have sensitivities to odors of other substances. In addition, people may have different reactions to the same odor; in fact, an odor that is offensive to one person (e.g., from a fast-food restaurant) may be perfectly acceptable to another. It is also important to note that an unfamiliar odor is more easily detected and is more likely to cause complaints than a familiar one. This is because of the phenomenon known as odor fatigue, in which a person can become desensitized to almost any odor and recognition only occurs with an alteration in the intensity.

For example, a person may use the word “strong” to describe the intensity of an odor. Odor intensity depends on the odorant concentration in the air.

When an odorous sample is progressively diluted, the odorant concentration decreases. As this occurs, the odor intensity weakens and eventually becomes so low that the detection or recognition of the odor is quite difficult. At some point during dilution, the concentration of the odorant reaches a detection threshold. An odorant concentration below the detection threshold means that the concentration in the air is not detectable by the average human.

The intensity of an odor source’s operations and its proximity to sensitive receptors influences the potential significance of odor emissions. The SJVAPCD has identified some common types of facilities that have been known to produce odors in the SJVAB. The types of facilities that are known to produce odors are shown in Table 5 along with a reasonable distance from the source within which, the degree of odors could possibly be significant. The Project does not propose any uses that would be potential odor sources; however, the information presented in Table 5 will be used as a screening level analysisto determine if the Project would be impacted by existing odor sources in the study area. Such information is presented for informational purposes, but it is noted that the environment’s effect on the Project, including exposure to potential odors, would not be an impact for CEQA purposes.

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TABLE 5
Screening Levels for Potential Odor Sources

2.6.9 Naturally Occurring Asbestos (NOA)
Asbestos is a term used for several types of naturally occurring fibrous minerals found in many parts of California. The most common type of asbestos is chrysotile, but other types are also found in California. Asbestos is commonly found in ultramafic rock and near fault zones. The amount of asbestos that is typically present in these rocks’ ranges from less than 1% up to approximately 25% and sometimes more. It is released from ultramafic rock when it is broken or crushed. This can happen when cars drive over unpaved roads or driveways, which are surfaced with these rocks, when land is graded for building purposes, or at quarrying operations.

Asbestos is also released naturally through weathering and erosion. Once released from the rock, asbestos can become airborne and may stay in the air for long periods of time. Asbestos is hazardous and can cause lung disease and cancer dependent upon the level of exposure. The longer a person is exposed to asbestos and the greater the intensity of the exposure, the greater the chances for a health problem.

The proposed Project's construction phase may cause asbestos to become airborne due to the construction activities that will occur on site. The Project would be required to submit a Dust Control Plan under the SJVAPCD’s Rule 8021.

2.6.10 Greenhouse Gas Emissions
Gases that trap heat in the atmosphere are often called greenhouse gases. Some greenhouse gases such as carbon dioxide occur naturally and are emitted to the atmosphere through natural processes and human activities. Other greenhouse gases (e.g., fluorinated gases) are created and emitted solely through human activities. The principal greenhouse gases that enter the Wastewater Treatment Facilities 2 miles
Sanitary Landfill 1 mile
Transfer Station 1 mile
Compositing 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 shops) 1 mile Food Processing Facility 1 mile
Feed Lot/Dairy 1 mile
Rendering Plant 1 mile
Type of Facility Distance
Source: SJVAPCD 2022
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atmosphere because of human activities are:
✓ Carbon Dioxide (CO2): Carbon dioxide enters the atmosphere through the burning of fossil fuels (oil, natural gas, and coal), solid waste, trees and wood products, and also as a result of other chemical reactions (e.g., manufacture of cement, asphalt paving, truck trips). Carbon dioxide is also removed from the atmosphere (or "sequestered") when it is absorbed by plants as part of the biological carbon cycle.
✓ Methane (CH4): Methane is emitted during the production and transport of coal, natural gas, and oil. Methane emissions also result from livestock and other agricultural practices and by the decay of organic waste in municipal solid waste landfills. ✓ Nitrous Oxide (N2O): Nitrous oxide is emitted during agricultural and industrial activities, as well as during combustion of fossil fuels and solid waste. ✓ Fluorinated Gases: Hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride are synthetic, powerful greenhouse gases that are emitted from a variety of industrial processes.

Fluorinated gases are sometimes used as substitutes for ozone-depleting substances (i.e., CFCs, HCFCs, and halons). These gases are typically emitted in smaller quantities, but because they are potent greenhouse gases, they are sometimes referred to as High Global Warming Potential gases ("High GWP gases").

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3.0 Air-Quality Impacts

3.1 Methodology
The impact assessment for air quality focuses on potential effects the Project might have on air quality within the Fresno region. The SJVAPCD has established thresholds of significance for determining environmental significance. These thresholds separate a project’s short-term emissions from its long-term emissions. The short-term emissions are mainly related to the construction phase of a project, which are recognized to be short in duration. The long-term emissions are primarily related to the activities that will occur indefinitely as a result of Project operations. Impacts will be evaluated both on the basis of CEQA Appendix G criteria and SJVAPCD significance criteria. The impacts to be evaluated will be those involving construction and operational emissions of criteria pollutants. The SJVAPCD has established thresholds for certain pollutants shown in Table 6.

Table 6
SJVAPCD Air Quality Thresholds of Significance

3.1.1 CalEEMod
CalEEMod is a statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both construction and operations from a variety of land use projects. The model quantifies direct emissions from construction and operations (including vehicle use), as well as indirect emissions, such as GHG emissions from energy use, solid waste disposal, vegetation planting and/or removal, and water use.

The model is an accurate and comprehensive tool for quantifying air quality impacts from land use projects throughout California. The model can be used for a variety of situations where an air quality analysis is necessary or desirable such as CEQA and NEPA documents, pre-project planning, compliance with local air quality rules and regulations, etc.

CO NOX ROG SOX PM10 PM2.5
Construction Emissions 100 10 10 27 15 15
Operational Emissions
(Permitted Equipment and Activities) 100 10 10 27 15 15 Operational Emissions
(Non-Permitted Equipment and Activities) 100 10 10 27 15 15 Project Type
Ozone Precursor Emissions (tons/year)
Source: SJVAPCD 2023
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3.2 Short-Term Impacts
Short-term impacts are mainly related to the construction phase of a project and are recognized to be short in duration. Construction air quality impacts are generally attributable to dust and exhaust pollutants generated by equipment and vehicles. Fugitive dust is emitted both during construction activity and as a result of wind erosion over exposed earth surfaces. Clearing and earth moving activities do comprise major sources of construction dust emissions, but traffic and general disturbances of soil surfaces also generate significant dust emissions. Further, dust generation is dependent on soil type and soil moisture. Exhaust pollutants are the non-useable gaseous waste products produced during the combustion process. Engine exhaust contains CO, HC, and NOx pollutants which are harmful to the environment.

Adverse effects of construction activities cause increased dust-fall and locally elevated levels of total suspended particulate. Dust-fall can be a nuisance to neighboring properties or previously completed developments surrounding or within the Project area and may require frequent washing during the construction period.

PM10 emissions can result from construction activities of the Project. The SJVAPCD has determined that compliance with Regulation VIII and other control measures will constitute sufficient mitigation to reduce PM10 impacts to a level considered less-than significant for most development projects. Even with implementation of District Regulation VIII and District Rule 9510, large development projects may not be able to reduce project specific construction impacts below District thresholds of significance.

Ozone precursor emissions are also an impact of construction activities and can be quantified through calculations. Numerous variables factored into estimating total construction emission include: level of activity, length of construction period, number of pieces and types of equipment in use, site characteristics, weather conditions, number of construction personnel, and amount of materials to be transported onsite or offsite. Additional exhaust emissions would be associated with the transport of workers and materials. Because the specific mix of construction equipment is not presently known for this Project, construction emissions were estimated using CalEEMod Model defaults for construction equipment.

Table 7 shows the CalEEMod estimated construction emissions that would be generated from construction of the Project. Results of the analysis show that emissions generated from construction of the Project will not exceed the SJVAPCD emission thresholds.

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Table 7
Project Construction Emissions (tons/year)

3.3 Long-Term Emissions
Long-Term emissions from the Project would be generated primarily by mobile source (vehicle) emissions from the Project site and area sources such as lawn maintenance equipment.

3.3.1 Localized Operational Emissions – Ozone/Particulate Matter The Fresno County area is nonattainment for Federal and State air quality standards for ozone, attainment of Federal standards for PM10 and nonattainment for State standards, and nonattainment for Federal and State standards for PM2.5. Nitrogen oxides and reactive organic gases are regulated as ozone precursors. Significance criteria have been established for criteria pollutant emissions as documented in Section 3.1. Operational emissions have been estimated for the Project using the CalEEMod Model and detailed results are included in Appendix A of this report.

Results of the CalEEMod analysis are shown in Table 8. Results indicate that the annual operational emissions from the Project will be less than the SJVAPCD emission thresholds for criteria pollutants.

Table 8
Project Operational Emissions (tons/year)

3.3.2 Localized Operational Emissions
✓ Carbon Monoxide
The SJVAPCD is currently in unclassified/attainment for Federal standards and unclassified Project Construction Emissions 2.42 2.22 2.67 0.01 0.39 0.21 428.69 SJVAPCD Level of Significance 100 10 10 27 15 15 None
Does the Project Exceed Standard? No No No No No No No
Source: CalEEMod
Summary Report CO NOX ROG SOx PM10 PM2.5 CO2e
Project Opeational Emissions 7.53 1.36 2.05 0.02 1.60 0.45 1957.22 SJVAPCD Level of Significance 100 10 10 27 15 15 None
Does the Project Exceed Standard? No No No No No No No
PM10 PM2.5 CO2e
Source: CalEEMod
Summary Report CO NOX ROG SOx
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for State standards for CO. An analysis of localized CO concentrations is typically warranted to ensure that standards are maintained. Also, an analysis is required to ensure that localized concentrations don’t reach potentially unhealthful levels that could affect sensitive receptors (residents, school children, hospital patients, the elderly, etc.).

Typically, high CO concentrations are associated with roadways or intersections operating at an unacceptable Level of Service (LOS). CO “Hot Spot” modeling is required if a traffic study reveals that the project will reduce the LOS on one or more streets to E or F or if the project will worsen an existing LOS F.

To analyze the Cumulative Year 2046 Plus Project “worst case” CO concentrations at study roadway segments, the analysis methodology considered the highest annual maximum CO concentration reported in 2013, using 1.0 PPM as an estimate of the background concentration for the 8-hour standard and 2.2 PPM for the 1-hour standard (source: CARB annual publications). Other modeling assumptions include a wind speed of .5 m/s, flat topography, 1,000-meter mixing height, and a 5 degree wind deviation. ✓ Toxic Air Contaminants (TAC)
The SJVAPCD’s Guidance Document, Guidance for Assessing and Mitigating Air Quality Impacts – 2015, identifies the need for projects to analyze the potential for adverse air quality impacts to sensitive receptors. Sensitive receptors refer to those segments of the population most susceptible to poor air quality (i.e., children, the elderly, and those with pre-existing serious health problems affected by air quality). Land uses that have the greatest potential to attract these types of sensitive receptors include schools, parks, playgrounds, daycare centers, nursing homes, hospitals, and residential communities. From a health risk perspective, the Project is a Type B Project in that it may potentially place sensitive receptors in the vicinity of existing sources.

The first step in evaluating the potential for impacts to sensitive receptors for TAC’s from the Project is to perform a screening level analysis. For Type B Projects, one type of screening tool is found in the CARB Handbook: Air Quality and Land Use Handbook: A Community Perspective. This handbook includes a table (depicted in Table 4) with recommended buffer distances associated with various types of common sources. The screening level analysis for the Project shows that TAC’s are not a concern based upon the recommendations provided in Table 4. An evaluation of nearby land uses considering CARB’s Pollution Mapping Tool shows that the Project will not place sensitive receptors in the vicinity of existing toxic sources. The Project is located a 2.5 mile from the State Route (SR) 168 freeway. Table 4 indicates that new sensitive land uses shouldn’t be sited within 500 feet of a freeway/urban roads with 100,000 vehicles/day, or rural roads with 50,000 vehicles/day. The Project is located more than 2.5 miles from the SR 168 freeway. As a result, a health risk assessment is not needed at this time.

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✓ Odors
Typically, odors are regarded as an annoyance rather than a health hazard. However, manifestations of a person’s reaction to foul odors can range from psychological (e.g., irritation, anger, or anxiety) to physiological (e.g., circulatory and respiratory effects, nausea, vomiting, and headache).

Quality and intensity are two properties present in any odor. The quality of an odor indicates the nature of the smell experience. For instance, if a person describes an odor as flowery or sweet, then the person is describing the quality of the odor. Intensity refers to the strength of the odor. For example, a person may use the word “strong” to describe the intensity of an odor. Odor intensity depends on the odorant concentration in the air.

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. Any project with the potential to frequently expose members of the public to objectionable odors should be deemed to have a significant impact.

The SJVAPCD requires that an analysis of potential odor impacts be conducted for the following two situations:
▪ Generators – projects that would potentially generate odorous emissions proposed to be located near existing sensitive receptors or other land uses where people may congregate, and
▪ Receivers – residential or other sensitive receptor projects or other projects built for the intent of attracting people locating near existing odor sources.

The Project will not generate odorous emissions given the nature or characteristics of the Project. The intensity of an odor source’s operations and its proximity to sensitive receptors influences the potential significance of odor emissions. The SJVAPCD has identified some common types of facilities that have been known to produce odors in the SJV Air Basin. The types of facilities that are known to produce odors are shown in Table 5 above along with a reasonable distance from the source within which, the degree of odors could possibly be significant. None of the facilities shown in Table 5 are located within two (2) miles of the Project.
✓ Naturally Occurring Asbestos (NOA)
Asbestos is a term used for several types of naturally occurring fibrous minerals found in VftPA I TECHNOLOGIES INC.
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many parts of California. The most common type of asbestos is chrysotile, but other types are also found in California. Construction of the Project may cause asbestos to become airborne due to the construction activities that will occur on site. The Project would be required to submit a Dust Control Plan under the SJVAPCD’s Rule 8021. Compliance with Rule 8021 would limit fugitive dust emissions from construction, demolition, excavation, extraction, and other earthmoving activities associated with the Project.

The Dust Control Plan may include the following measures:

1. Water wetting of road surfaces

2. Rinse vehicles and equipment

3. Wet loads of excavated material, and

4. Cover loads of excavated material
✓ Greenhouse Gas Emissions
CARB, in consultation with MPOs, has provided each affected region with reduction targets for GHGs emitted by passenger cars and light trucks in the region for the years 2020 and 2035.

For the Fresno Council of Governments(FCOG) region, CARB set targets at six (6) percent per capita decrease in 2020 and a thirteen (13) percent per capita decrease in 2035 from a base year of 2005. FCOG’s 2018 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), which was adopted in July 2022, projects that the Fresno County region would achieve the prescribed emissions targets.

In 2009, the SJVAPCD adopted the following guidance documents applicable to projects within the San Joaquin Valley:
✓ Guidance for Valley Land-use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA (SJVAPCD 2009), and
✓ District Policy: Addressing GHG Emission Impacts for Stationary Source Projects Under CEQA When Serving as the Lead Agency (SJVAPCD 2009).

This guidance and policy are the reference documents referenced in the SJVAPCD’s Guidance for Assessing and Mitigating Air Quality Impacts adopted in March 2015 (SJVAPCD 2015).

Consistent with the District Guidance and District Policy above, SJVAPCD (2015) acknowledges the current absence of numerical thresholds, and recommends a tiered approach to establish the significance of the GHG impacts on the environment:
i. If a project complies with an approved GHG emission reduction plan or GHG mitigation program which avoids or substantially reduces GHG emissions within the geographic area in which the project is located, then the project would be determined to have a less than significant individual and cumulative impact for GHG emissions; ii. If a project does not comply with an approved GHG emission reduction plan or mitigation program, then it would be required to implement Best Performance VftPA I TECHNOLOGIES INC.
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Standards (BPS); and
iii. If a project is not implementing BPS, then it should demonstrate that its GHG emissions would be reduced or mitigated by at least 29 percent compared to Business as Usual (BAU).

As shown in Table 9, the Project would generate 2608.35 Metric Tons of Carbon Dioxide Equivalent per year (MTCO2eq./year) using an operational year of 2005, which includes area, energy, mobile, waste, and water sources. “Business as usual” (BAU) is referenced in CARB’s AB 32 Scoping Plan as emissions projected to occur in 2020 if the average baseline emissions during the 2002-2004 period grew to 2020 levels, without control or Best Performance Standards (BPS) offsets. As a result, an estimate of the Project’s operational emissions in 2005 were compared to operational emissions in 2020 in order to determine if the Project meets the 29% emission reduction. The SJVAPCD has reviewed relevant scientific information related to GHG emissions and has determined that they are not able to determine a specific quantitative level of GHG emissions increase, above which a project would have a significant impact on the environment, and below which would have an insignificant impact. As a result, the SJVAPCD has determined that projects achieving at least a 29% GHG emission reduction compared to BAU would be determined to have a less than significant individual and cumulative impact for GHG. Results of the analysis show that the Project’s GHG emissions in the year 2020 is 2179.68 MTCO2eq./year. This represents an achievement of 16% GHG emission reduction on the basis of BAU, which does not meet the 29% GHG emission reduction target.

In the event that a local air district’s guidance for addressing GHG impacts does not use numerical GHG emissions thresholds, at the lead agency’s discretion, a neighboring air district’s GHG threshold may be used to determine impacts. In December 2008, the South Coast Air Quality Management District (SCAQMD) Governing Board adopted the staff proposal for an interim GHG significance threshold for projects where the SCAQMD is lead agency. The SCAQMD guidance identifies a threshold of 10,000 MTCO2eq./year for GHG for construction emissions amortized over a 30-year project lifetime, plus annual operation emissions. This threshold is often used by agencies, such as the California Public Utilities Commission, to evaluate GHG impacts in areas that do not have specific thresholds (CPUC 2015)2. Therefore, because this threshold has been established by the SCAQMD in an effort to control GHG emissions in the largest metropolitan area in the State of California, this threshold is considered a conservative approach for evaluating the significance of GHG emissions in a more rural area, such as Fresno County. Though the Project is under SJVAPCD jurisdiction, the SCAQMD GHG threshold provides some perspective on the GHG emissions generated by the Project. Table 10 shows the yearly GHG emissions generated by the Project as determined by the CalEEMod model, which is approximately 80% less than the threshold identified by the SCAQMD. Though the Project is under SJVAPCD jurisdiction, the SCAQMD 2 California Public Utilities Commission (CPUC). 2015. Section 4.7, “Greenhouse Gases.” Final Environmental Impact Report for the Santa Barbara County Reliability Project. May 2015. Accessed January 18, 2018. http://www.cpuc.ca.gov/environment/info/ene/sbcrp/SBCRP_FEIR.html.

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GHG threshold provides some perspective on the GHG emissions generated by the Project.

Table 10 shows the yearly GHG emissions generated by the Project as determined by the CalEEMod model.

Table 9
2005/2020 Operational greenhouse Gas Emissions
Table 10
Project Operational Greenhouse Gas Emissions

3.3.3 Indirect Source Review
The Plans assess current and proposed rules, along with state and federal regulations, to model future emissions and achieve pollution attainment. The proposed Project is subject to the SJVAPCD’s ISR program since there are more than 50 residential units. It applies to any applicant that seeks to gain final discretionary approval for a development project of more that 50 residential units as of projects approved after 2006. Rule 9510 and the Administrative ISR Fee Rule (Rule 3180) are the result of state requirements outlined in the California Health and Safety Code, Section 40604 and the State Implementation Plan (SIP). The purpose of the SJVAPCD’s ISR program is to reduce emissions of NOx and PM10 from new projects. In general, new development contributes to the air-pollution problem in the Valley by increasing the number of vehicles and vehicle miles traveled.

Operational Emissions Per Year (2005) 7368.31 MT/yr
Operational Emissions Per Year (2020) 6253.23 MT/yr
SJVAPCD Level of Significance 29% Reduction Compared to BAU Does the Project Meet the Standard No
Source: CalEEMod Emissions Model
Summary Report CO2e
Project Operational Emissions Per Year( Plus
amortized construction emissions)
1971.51 MT/yr
Summary Report CO2e
Source: CalEEMod
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Utilizing the ISR Fee Estimator calculator available on the SJVAPCD website, it was determined that the Project’s total cost for emission reductions is $108,033.12 without implementation of emission reduction measures. After the application of ISR rule Nox will be reduced by 0.44 MT/yr and PM10 will be reduced by 0.17 MT/yr during construction phase. The ISR Fee Estimator worksheets are included in Appendix B. The fee noted above may be reduced dependent upon the formal ISR review process.

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4.0 Impact Determinations and Recommended
Mitigation
In accordance with CEQA, when a proposed project is consistent with a General Plan for which an EIR has been certified, the effects of that project are evaluated to determine if they will result in project-specific significant adverse impacts on the environment. The criteria used to determine the significance of an air quality or greenhouse gas impact are based on the following thresholds of significance, which come from Appendix G of the CEQA Guidelines and the General Plan EIR. Accordingly, air quality or greenhouse gas impacts resulting from the Project are considered significant if the Project would:

Air Quality
a) Conflict with or obstruct implementation of the applicable air quality plan? b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
c) Expose sensitive receptors to substantial pollutant concentrations? d) Result in other emissions such as those leading to odors adversely affecting a substantial number of people?
Greenhouse Gas Emissions
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?

4.1 Air Quality

4.1.1 Conflict with or obstruct implementation of the applicable air quality plan The primary way of determining consistency with the air quality plan’s (AQP’s) assumptions is determining consistency with the applicable General Plan to ensure that the Project’s population density and land use are consistent with the growth assumptions used in the AQPs for the air basin.

As required by California law, city and county General Plans contain a Land Use Element that details the types and quantities of land uses that the city or county estimates will be needed for future growth, and that designate locations for land uses to regulate growth. FCOG uses the growth projections and land use information in adopted general plans to estimate future average daily trips and then VMT, which are then provided to SJVAPCD to estimate future emissions in VftPA I TECHNOLOGIES INC.
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the AQPs. Existing and future pollutant emissions computed in the AQP are based on land uses from area general plans. AQPs detail the control measures and emission reductions required for reaching attainment of the air standards.

The applicable General Plan for the project is the City of Clovis 2035 General Plan Update, which was adopted in 2014. The Project is consistent with the currently adopted General Plan for the City of Clovis and is therefore consistent with the population growth and VMT applied in the plan.

Therefore, the Project is consistent with the growth assumptions used in the applicable AQPs. As a result, the Project will not conflict with or obstruct implementation of any air quality plans.

Therefore, no mitigation is needed.

4.1.2 Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard
The Fresno County area is nonattainment for Federal and State air quality standards for ozone, in attainment of Federal standards and nonattainment for State standards for PM10, and nonattainment for Federal and State standards for PM2.5. The SJVAPCD has prepared the 2016 and 2013 Ozone Plans, 2007 PM10 Maintenance Plan, and 2012 PM2.5 Plan to achieve Federal and State standards for improved air quality in the SJVAB regarding ozone and PM. Inconsistency with any of the plans would be considered a cumulatively adverse air quality impact. As discussed in Section 4.1.1, the Project is consistent with the currently adopted General Plan for the City of Clovis and is therefore consistent with the population growth and VMT applied in the plan.

Therefore, the Project is consistent with the growth assumptions used in the 2016 and 2013 Ozone Plan, 2007 PM10 Maintenance Plan, and 2012 PM2.5 Plan.

Project specific emissions that exceed the thresholds of significance for criteria pollutants would be expected to result in a cumulatively considerable net increase of any criteria pollutant for which the County is in non-attainment under applicable federal or state ambient air quality standards. It should be noted that a project is not characterized as cumulatively insignificant when project emissions fall below thresholds of significance. As discussed in Section 3.1, the SJVAPCD has established thresholds of significance for determining environmental significance which are provided in Table 6.

As discussed above in Section 3.2 and 3.3, results of the analysis show that emissions generated from construction and operation of the Project will be less than the applicable SJVAPCD emission thresholds for criteria pollutants. Therefore, no mitigation is needed.

4.1.3 Expose sensitive receptors to substantial pollutant concentrations Sensitive receptors refer to those segments of the population most susceptible to poor air quality (i.e., children, the elderly, and those with pre-existing serious health problems affected by air quality). Land uses that have the greatest potential to attract these types of sensitive receptors VftPA I TECHNOLOGIES INC.
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include schools, parks, playgrounds, daycare centers, nursing homes, hospitals, and residential communities. From a health risk perspective, the Project is a Type B project in that it may potentially place sensitive receptors in the vicinity of existing sources.

This handbook includes a table (depicted in Table 4) with recommended buffer distances associated with various types of common sources. The screening level analysis for the Project shows that TAC’s are not a concern based upon the recommendations provided in Table 4. An evaluation of nearby land uses considering CARB’s Pollution Mapping Tool shows that the Project will not place sensitive receptors in the vicinity of existing toxic sources. The Project is located a

2.5 mile from the State Route (SR) 168 freeway. Table 4 indicates that new sensitive land uses shouldn’t be sited within 500 feet of a freeway/urban roads with 100,000 vehicles/day, or rural roads with 50,000 vehicles/day. The Project is located more than 2.5 miles from the SR 168 freeway. Therefore, no mitigation is needed.

Short-Term Impacts
The annual emissions from the construction phase of the Project will be less than the applicable SJVAPCD emission thresholds for criteria pollutants as shown in Table 8. The construction emissions are therefore considered less than significant with the implementation of the SJVAPCD applicable Regulation VIII control measures, which are provided below.

2. All on-site unpaved roads and off-site unpaved access roads shall be effectively stabilized of dust emissions using water or chemical stabilizer/suppressant.

6. Following the addition of materials to, or the removal of materials from, the surface of outdoor storage piles, said piles shall be effectively stabilized of fugitive dust emissions VftPA I TECHNOLOGIES INC.
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utilizing sufficient water or chemical stabilizer/suppressant.

7. Within urban areas, track out shall be immediately removed when it extends 50 or more feet from the site and at the end of each workday.

Naturally Occurring Asbestos (NOA)
The proposed Project's construction phase may cause asbestos to become airborne due to the construction activities that will occur on site. In order to control naturally-occurring asbestos dust, the Project will be required to submit a Dust Control Plan under the SJVAPCD’s Rule 8021.

The Dust Control Plan may include the following measures:

1. Water wetting of road surfaces

2. Rinse vehicles and equipment

3. Wet loads of excavated material, and

4. Cover loads of excavated material
Long-Term Impacts
Long-Term emissions from the Project are generated primarily by mobile source (vehicle) emissions from the project site and area sources such as lawn maintenance equipment.

Emissions from long-term operations generally represent a project’s most substantial air quality impact. Table 8 summarizes the Project’s operational impacts by pollutant. Results indicate that operational emissions from the Project will not exceed the SJVAPCD emissions threshold for any emissions, hence no mitigations are required.

4.1.4 Result in other emissions such as those leading to odors adversely affecting a substantial number of people
The SJVAPCD requires that an analysis of potential odor impacts be conducted for the following two situations:
✓ Generators – projects that would potentially generate odorous emissions proposed to be located near existing sensitive receptors or other land uses where people may congregate, and
✓ Receivers – residential or other sensitive receptor projects or other projects built for the intent of attracting people located near existing odor sources.

The proposed Project will not generate odorous emissions given the nature or characteristics of residential developments. The intensity of an odor source’s operations and its proximity to VftPA I TECHNOLOGIES INC.
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sensitive receptors influences the potential significance of odor emissions. The SJVAPCD has identified some common types of facilities that have been known to produce odors in the SJV Air Basin. The types of facilities that are known to produce odors are shown in Table 5 above along with a reasonable distance from the source within which, the degree of odors could possibly be significant. None of the facilities shown in Table 5 are located within two (2) miles of the Project.

Therefore, no mitigation is needed.

4.2 Greenhouse Gas Emissions

4.2.1 Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment
In 2009, the SJVAPCD adopted the following guidance documents applicable to projects within the San Joaquin Valley:
✓ Guidance for Valley Land-use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA (SJVAPCD 2009), and
✓ District Policy: Addressing GHG Emission Impacts for Stationary Source Projects Under CEQA When Serving as the Lead Agency (SJVAPCD 2009).

In the event that a local air district’s guidance for addressing GHG impacts does not use numerical GHG emissions thresholds, at the lead agency’s discretion, a neighboring air district’s GHG threshold may be used to determine impacts. In December 2008, the South Coast Air Quality Management District (SCAQMD) Governing Board adopted the staff proposal for an interim GHG significance threshold for projects where the SCAQMD is lead VftPA I TECHNOLOGIES INC.
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agency. The SCAQMD guidance identifies a threshold of 10,000 MTCO2eq./year for GHG for construction emissions amortized over a 30-year project lifetime, plus annual operation emissions. This threshold is often used by agencies, such as the California Public Utilities Commission, to evaluate GHG impacts in areas that do not have specific thresholds (CPUC 2015)3. Therefore, because this threshold has been established by the SCAQMD in an effort to control GHG emissions in the largest metropolitan area in the State of California, this threshold is considered a conservative approach for evaluating the significance of GHG emissions in a more rural area, such as Fresno County. Though 80% less than the threshold identified by the SCAQMD.

CARB’s California GHG Emissions Inventory provides estimates of anthropogenic GHG emissions within California, as well as emissions associated with imported electricity; natural sources are not included in the inventory. California’s GHG emissions for 2020 totaled approximately 358.76 million MTCO2eq. The proposed Project’s GHG emissions represents less than 0.001% of the total GHG emissions for the state of California when compared to year 2018 emissions data.

Based on the assessment above, the Project will not generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.

Therefore, any impacts would be less than significant.

4.2.2 Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases
California passed the California Global Warming Solutions Act of 2006. AB 32 requires that statewide GHG emissions be reduced to 1990 levels by 2020. Under AB 32, CARB must adopt regulations by January 1, 2011 to achieve reductions in GHGs to meet the 1990 emission cap by 2020. On December 11, 2008, CARB adopted its initial Scoping Plan, which functions as a roadmap of CARB’s plans to achieve GHG reductions in California required by AB 32 through subsequently enacted regulations. CARB’s 2017 Climate Change Scoping Plan builds on the efforts and plans encompassed in the initial Scoping Plan.

SB 375 requires MPOs to adopt a SCS or APS that will prescribe land use allocation in that MPO's regional transportation plan. CARB, in consultation with MPOs, has provided each affected region with reduction targets for GHGs emitted by passenger cars and light trucks in the region for the years 2020 and 2035. For the FCOF region, CARB set targets at six (6) percent per capita decrease in 2020 and a thirteen (13) percent per capita decrease in 2035 from a base year of 2005. FCOG’s 2022 RTP/SCS, which was adopted in July 2022, projects that the Fresno County 3 California Public Utilities Commission (CPUC). 2015. Section 4.7, “Greenhouse Gases.” Final Environmental Impact Report for the Santa Barbara County Reliability Project. May 2015. Accessed January 18, 2018. http://www.cpuc.ca.gov/environment/info/ene/sbcrp/SBCRP_FEIR.html.

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region would achieve the prescribed emissions targets.

Executive Order B-30-15 establishes a California greenhouse gas reduction target of 40 percent below 1990 levels by 2030 to ensure California meets its target of reducing greenhouse gas emissions to 80 percent below 1990 levels by 2050. Executive Order B-30-15 requires MPO’s to implement measures that will achieve reductions of greenhouse gas emissions to meet the 2030 and 2050 greenhouse gas emissions reductions targets.

The Project is consistent with the currently adopted General Plan for the City of Clovis and the adopted FCOG 2022 RTP/SCS and is therefore consistent with the population growth and VMT applied in those plan documents. Therefore, the Project is consistent with the growth assumptions used in the applicable AQP. It should also be noted that yearly GHG emissions generated by the Project (Table 9) are approximately 80% less than the threshold identified by the SCAQMD (see the discussion for Impact 4.2.1 above).

CARB’s 2017 Climate Change Scoping Plan builds on the efforts and plans encompassed in the initial Scoping Plan. The current plan has identified new policies and actions to accomplish the State’s 2030 GHG limit. Below is a list of applicable strategies in the Scoping Plan and the Project’s consistency with those strategies.
✓ California Light-Duty Vehicle GHG Standards – Implement adopted standards and planned second phase of the program. Align zero-emission vehicle, alternative and renewable fuel and vehicle technology programs for long-term climate change goals. ▪ The Project is consistent with this reduction measure. This measure cannot be implemented by a particular project or lead agency since it is a statewide measure. When this measure is implemented, standards would be applicable to light-duty vehicles that would access the Project. The Project would not conflict or obstruct this reduction measure.

✓ Energy Efficiency – Pursuit of comparable investment in energy efficiency from all retail providers of electricity in California. Maximize energy efficiency building and appliance standards.
▪ The Project is consistent with this reduction measure. Though this measure applies to the State to increase its energy standards, the Project would comply with this measure VftPA I TECHNOLOGIES INC.
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through existing regulation. The Project would not conflict or obstruct this reduction measure.
✓ Low Carbon Fuel – Development and adoption of the low carbon fuel standard. ▪ The Project is consistent with this reduction measure. This measure cannot be implemented by a particular project or lead agency since it is a statewide measure. When this measure is implemented, standards would be applicable to the fuel used by vehicles that would access the Project. The Project would not conflict or obstruct this reduction measure.

Based on the assessment above, the Project will not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases. Therefore, any impacts would be less than significant.

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Appendix-A
CalEEMod Worksheets
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Tract 000
Fresno County, Annual
Project Characteristics -
Land Use - project description

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population Single Family Housing 153.00 Dwelling Unit 18.63 275,400.00 438

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
3 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 45

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics

2.0 Emissions Summary
Utility Company Pacific Gas and Electric Company
Operational Year 2025
CO2 Intensity
(lb/MWhr)
203.98 CH4 Intensity 0.033
(lb/MWhr)
N2O Intensity 0.004
(lb/MWhr)
Table Name Column Name Default Value New Value
tblLandUse LotAcreage 49.68 18.63
tblWoodstoves NumberCatalytic 18.63 0.00
tblWoodstoves NumberNoncatalytic 18.63 0.00
CalEEMod Version: CalEEMod.2020.4.0 Page 1 of 31 Date: 1/10/2024 5:18 PM Tract 000 - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied —+
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750
AGENDA ITEM NO. 13.

2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2024 0.2460 2.2201 2.4298 4.8400e0030.2939 0.0962 0.3901 0.1209 0.0899 0.2107 0.0000 424.6752 424.6752 0.0960 5.4300e003428.6945 2025 2.6768 0.7936 1.0828 2.0400e0030.0307 0.0328 0.0635 8.3000e0030.0308 0.0391 0.0000 178.9658 178.9658 0.0358 2.8400e003180.7065 Maximum 2.6768 2.2201 2.4298 4.8400e0030.2939 0.0962 0.3901 0.1209 0.0899 0.2107 0.0000 424.6752 424.6752 0.0960 5.4300e003428.6945 Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2024 0.2460 2.2201 2.4298 4.8400e0030.2939 0.0962 0.3901 0.1209 0.0899 0.2107 0.0000 424.6748 424.6748 0.0960 5.4300e003428.6941 2025 2.6768 0.7936 1.0828 2.0400e0030.0307 0.0328 0.0635 8.3000e0030.0308 0.0391 0.0000 178.9656 178.9656 0.0358 2.8400e003180.7063 Maximum 2.6768 2.2201 2.4298 4.8400e0030.2939 0.0962 0.3901 0.1209 0.0899 0.2107 0.0000 424.6748 424.6748 0.0960 5.4300e003428.6941 Mitigated Construction
CalEEMod Version: CalEEMod.2020.4.0 Page 2 of 31 Date: 1/10/2024 5:18 PM Tract 000 - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied ■
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751
AGENDA ITEM NO. 13.

ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter) Maximum Mitigated ROG + NOX (tons/quarter) 1 1-10-2024 4-9-2024 0.9567 0.9567
2 4-10-2024 7-9-2024 0.5160 0.5160
3 7-10-2024 10-9-2024 0.5218 0.5218
4 10-10-2024 1-9-2025 0.5195 0.5195
5 1-10-2025 4-9-2025 0.4761 0.4761
6 4-10-2025 7-9-2025 1.7410 1.7410
7 7-10-2025 9-30-2025 1.2065 1.2065
Highest 1.7410 1.7410
CalEEMod Version: CalEEMod.2020.4.0 Page 3 of 31 Date: 1/10/2024 5:18 PM Tract 000 - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 752
AGENDA ITEM NO. 13.

2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 1.3748 0.0703 1.1593 4.3000e0040.0109 0.0109 0.0109 0.0109 0.0000 68.1364 68.1364 3.0500e0031.2200e00368.5747 Energy 0.0198 0.1695 0.0721 1.0800e0030.0137 0.0137 0.0137 0.0137 0.0000 309.1390 309.1390 0.0220 5.8100e003311.4214 Mobile 0.6651 1.1272 6.3070 0.0153 1.5673 0.0126 1.5799 0.4193 0.0118 0.4311 0.0000 1,452.252 0 1,452.252
0 0.0731 0.0778 1,477.268
9 Waste 0.0000 0.0000 0.0000 0.0000 32.0076 0.0000 32.0076 1.8916 0.0000 79.2975 Water 0.0000 0.0000 0.0000 0.0000 3.1626 7.0259 10.1884 0.3260 7.8100e00320.6642 Total 2.0598 1.3669 7.5384 0.0169 1.5673 0.0372 1.6045 0.4193 0.0364 0.4557 35.1702 1,836.553 2 1,871.723
4 2.3158 0.0927 1,957.226
7 Unmitigated Operational
CalEEMod Version: CalEEMod.2020.4.0 Page 4 of 31 Date: 1/10/2024 5:18 PM Tract 000 - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied ■
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AGENDA ITEM NO. 13.

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 1/10/2024 2/6/2024 5 20
2 Site Preparation Site Preparation 2/7/2024 2/20/2024 5 10 3 Grading Grading 2/21/2024 4/2/2024 5 30
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2020.4.0 Page 5 of 31 Date: 1/10/2024 5:18 PM Tract 000 - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied --I—
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AGENDA ITEM NO. 13.
4 Building Construction Building Construction 4/3/2024 5/27/2025 5 300 5 Paving Paving 5/28/2025 6/24/2025 5 20
6 Architectural Coating Architectural Coating 6/25/2025 7/22/2025 5 20 OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Architectural Coating Air Compressors 1 6.00 78 0.48
Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Building Construction Cranes 1 7.00 231 0.29
Demolition Excavators 3 8.00 158 0.38
Grading Excavators 2 8.00 158 0.38
Building Construction Forklifts 3 8.00 89 0.20
Building Construction Generator Sets 1 8.00 84 0.74
Grading Graders 1 8.00 187 0.41
Paving Pavers 2 8.00 130 0.42
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Demolition Rubber Tired Dozers 2 8.00 247 0.40
Grading Rubber Tired Dozers 1 8.00 247 0.40
Site Preparation Rubber Tired Dozers 3 8.00 247 0.40
Grading Scrapers 2 8.00 367 0.48
Building Construction Tractors/Loaders/Backhoes 3 7.00 97 0.37 Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37
Residential Indoor: 557,685; Residential Outdoor: 185,895; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 15
Acres of Grading (Grading Phase): 90
Acres of Paving: 0
CalEEMod Version: CalEEMod.2020.4.0 Page 6 of 31 Date: 1/10/2024 5:18 PM Tract 000 - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied I —t-- + +
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755
AGENDA ITEM NO. 13.

3.2 Demolition - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0224 0.2088 0.1971 3.9000e0049.6000e0039.6000e0038.9200e0038.9200e0030.0000 33.9961 33.9961 9.5100e0030.0000 34.2338 Total 0.0224 0.2088 0.1971 3.9000e0049.6000e0039.6000e0038.9200e0038.9200e0030.0000 33.9961 33.9961 9.5100e0030.0000 34.2338 Unmitigated Construction On-Site

3.1 Mitigation Measures Construction
Site Preparation Tractors/Loaders/Backhoes 4 8.00 97 0.37 Building Construction Welders 1 8.00 46 0.45
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 6 15.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Site Preparation 7 18.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 55.00 16.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Paving 6 15.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 1 11.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2020.4.0 Page 7 of 31 Date: 1/10/2024 5:18 PM Tract 000 - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 1 + r + F

A A A A A
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F I 1 I
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756
AGENDA ITEM NO. 13.

3.2 Demolition - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 4.3000e0042.7000e0043.2800e0031.0000e0051.2000e0031.0000e0051.2000e0033.2000e0041.0000e0053.2000e0040.0000 0.9308 0.9308 3.0000e0053.0000e0050.9390 Total 4.3000e0042.7000e0043.2800e0031.0000e0051.2000e0031.0000e0051.2000e0033.2000e0041.0000e0053.2000e0040.0000 0.9308 0.9308 3.0000e0053.0000e0050.9390 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0224 0.2088 0.1971 3.9000e0049.6000e0039.6000e0038.9200e0038.9200e0030.0000 33.9960 33.9960 9.5100e0030.0000 34.2338 Total 0.0224 0.2088 0.1971 3.9000e0049.6000e0039.6000e0038.9200e0038.9200e0030.0000 33.9960 33.9960 9.5100e0030.0000 34.2338 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 8 of 31 Date: 1/10/2024 5:18 PM Tract 000 - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied ■
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757
AGENDA ITEM NO. 13.

3.3 Site Preparation - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 2.6000e0041.6000e0041.9700e0031.0000e0057.2000e0040.0000 7.2000e0041.9000e0040.0000 1.9000e0040.0000 0.5585 0.5585 2.0000e0052.0000e0050.5634 Total 2.6000e0041.6000e0041.9700e0031.0000e0057.2000e0040.0000 7.2000e0041.9000e0040.0000 1.9000e0040.0000 0.5585 0.5585 2.0000e0052.0000e0050.5634 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0983 0.0000 0.0983 0.0505 0.0000 0.0505 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0133 0.1359 0.0917 1.9000e0046.1500e0036.1500e0035.6500e0035.6500e0030.0000 16.7285 16.7285 5.4100e0030.0000 16.8638 Total 0.0133 0.1359 0.0917 1.9000e0040.0983 6.1500e0030.1044 0.0505 5.6500e0030.0562 0.0000 16.7285 16.7285 5.4100e0030.0000 16.8638 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 10 of 31 Date: 1/10/2024 5:18 PM Tract 000 - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied ■
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759
AGENDA ITEM NO. 13.

3.4 Grading - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1381 0.0000 0.1381 0.0548 0.0000 0.0548 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0483 0.4857 0.4158 9.3000e0040.0200 0.0200 0.0184 0.0184 0.0000 81.7793 81.7793 0.0265 0.0000 82.4405 Total 0.0483 0.4857 0.4158 9.3000e0040.1381 0.0200 0.1581 0.0548 0.0184 0.0732 0.0000 81.7793 81.7793 0.0265 0.0000 82.4405 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 11 of 31 Date: 1/10/2024 5:18 PM Tract 000 - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied ■
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760
AGENDA ITEM NO. 13.

3.4 Grading - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 8.6000e0045.3000e0046.5500e0032.0000e0052.4000e0031.0000e0052.4100e0036.4000e0041.0000e0056.5000e0040.0000 1.8616 1.8616 5.0000e0055.0000e0051.8780 Total 8.6000e0045.3000e0046.5500e0032.0000e0052.4000e0031.0000e0052.4100e0036.4000e0041.0000e0056.5000e0040.0000 1.8616 1.8616 5.0000e0055.0000e0051.8780 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1381 0.0000 0.1381 0.0548 0.0000 0.0548 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0483 0.4857 0.4158 9.3000e0040.0200 0.0200 0.0184 0.0184 0.0000 81.7792 81.7792 0.0265 0.0000 82.4404 Total 0.0483 0.4857 0.4158 9.3000e0040.1381 0.0200 0.1581 0.0548 0.0184 0.0732 0.0000 81.7792 81.7792 0.0265 0.0000 82.4404 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 12 of 31 Date: 1/10/2024 5:18 PM Tract 000 - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied ■
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761
AGENDA ITEM NO. 13.

3.5 Building Construction - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.1435 1.3108 1.5763 2.6300e0030.0598 0.0598 0.0563 0.0563 0.0000 226.0529 226.0529 0.0535 0.0000 227.3893 Total 0.1435 1.3108 1.5763 2.6300e0030.0598 0.0598 0.0563 0.0563 0.0000 226.0529 226.0529 0.0535 0.0000 227.3893 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 13 of 31 Date: 1/10/2024 5:18 PM Tract 000 - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied ■
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762
AGENDA ITEM NO. 13.

3.5 Building Construction - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 1.6300e0030.0685 0.0201 3.1000e0040.0103 4.4000e0040.0108 2.9900e0034.2000e0043.4100e0030.0000 29.4908 29.4908 1.5000e0044.4400e00330.8175 Worker 0.0154 9.4900e0030.1171 3.6000e0040.0429 2.0000e0040.0431 0.0114 1.8000e0040.0116 0.0000 33.2767 33.2767 9.2000e0049.0000e00433.5692 Total 0.0170 0.0780 0.1372 6.7000e0040.0532 6.4000e0040.0539 0.0144 6.0000e0040.0150 0.0000 62.7675 62.7675 1.0700e0035.3400e00364.3867 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.1435 1.3108 1.5763 2.6300e0030.0598 0.0598 0.0563 0.0563 0.0000 226.0526 226.0526 0.0535 0.0000 227.3890 Total 0.1435 1.3108 1.5763 2.6300e0030.0598 0.0598 0.0563 0.0563 0.0000 226.0526 226.0526 0.0535 0.0000 227.3890 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 14 of 31 Date: 1/10/2024 5:18 PM Tract 000 - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied ■
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763
AGENDA ITEM NO. 13.

3.5 Building Construction - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0718 0.6547 0.8444 1.4200e0030.0277 0.0277 0.0261 0.0261 0.0000 121.7577 121.7577 0.0286 0.0000 122.4733 Total 0.0718 0.6547 0.8444 1.4200e0030.0277 0.0277 0.0261 0.0261 0.0000 121.7577 121.7577 0.0286 0.0000 122.4733 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 15 of 31 Date: 1/10/2024 5:18 PM Tract 000 - Fresno County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied ■
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764
AGENDA ITEM NO. 13.

3.5 Building Construction - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 8.6000e0040.0368 0.0106 1.6000e0045.5700e0032.4000e0045.8100e0031.6100e0032.3000e0041.8400e0030.0000 15.5744 15.5744 8.0000e0052.3400e00316.2749 Worker 7.6900e0034.5500e0030.0587 1.9000e0040.0231 1.0000e0040.0232 6.1400e0039.0000e0056.2300e0030.0000 17.4866 17.4866 4.5000e0044.5000e00417.6328 Total 8.5500e0030.0413 0.0692 3.5000e0040.0287 3.4000e0040.0290 7.7500e0033.2000e0048.0700e0030.0000 33.0610 33.0610 5.3000e0042.7900e00333.9077 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0718 0.6547 0.8444 1.4200e0030.0277 0.0277 0.0261 0.0261 0.0000 121.7576 121.7576 0.0286 0.0000 122.4731 Total 0.0718 0.6547 0.8444 1.4200e0030.0277 0.0277 0.0261 0.0261 0.0000 121.7576 121.7576 0.0286 0.0000 122.4731 Mitigated Construction On-Site
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3.6 Paving - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 9.1500e0030.0858 0.1458 2.3000e0044.1900e0034.1900e0033.8500e0033.8500e0030.0000 20.0193 20.0193 6.4700e0030.0000 20.1811 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 9.1500e0030.0858 0.1458 2.3000e0044.1900e0034.1900e0033.8500e0033.8500e0030.0000 20.0193 20.0193 6.4700e0030.0000 20.1811 Unmitigated Construction On-Site
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3.6 Paving - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 4.0000e0042.4000e0043.0500e0031.0000e0051.2000e0031.0000e0051.2000e0033.2000e0040.0000 3.2000e0040.0000 0.9084 0.9084 2.0000e0052.0000e0050.9160 Total 4.0000e0042.4000e0043.0500e0031.0000e0051.2000e0031.0000e0051.2000e0033.2000e0040.0000 3.2000e0040.0000 0.9084 0.9084 2.0000e0052.0000e0050.9160 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 9.1500e0030.0858 0.1458 2.3000e0044.1900e0034.1900e0033.8500e0033.8500e0030.0000 20.0192 20.0192 6.4700e0030.0000 20.1811 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 9.1500e0030.0858 0.1458 2.3000e0044.1900e0034.1900e0033.8500e0033.8500e0030.0000 20.0192 20.0192 6.4700e0030.0000 20.1811 Mitigated Construction On-Site
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3.7 Architectural Coating - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 2.9000e0041.7000e0042.2300e0031.0000e0058.8000e0040.0000 8.8000e0042.3000e0040.0000 2.4000e0040.0000 0.6662 0.6662 2.0000e0052.0000e0050.6717 Total 2.9000e0041.7000e0042.2300e0031.0000e0058.8000e0040.0000 8.8000e0042.3000e0040.0000 2.4000e0040.0000 0.6662 0.6662 2.0000e0052.0000e0050.6717 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Archit. Coating 2.5849 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 1.7100e0030.0115 0.0181 3.0000e0055.2000e0045.2000e0045.2000e0045.2000e0040.0000 2.5533 2.5533 1.4000e0040.0000 2.5567 Total 2.5866 0.0115 0.0181 3.0000e0055.2000e0045.2000e0045.2000e0045.2000e0040.0000 2.5533 2.5533 1.4000e0040.0000 2.5567 Mitigated Construction On-Site
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4.0 Operational Detail - Mobile
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 0.6651 1.1272 6.3070 0.0153 1.5673 0.0126 1.5799 0.4193 0.0118 0.4311 0.0000 1,452.252 0 1,452.252
0 0.0731 0.0778 1,477.268
9 Unmitigated 0.6651 1.1272 6.3070 0.0153 1.5673 0.0126 1.5799 0.4193 0.0118 0.4311 0.0000 1,452.252 0 1,452.252
0 0.0731 0.0778 1,477.268
9 4.1 Mitigation Measures Mobile

4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Single Family Housing 1,444.32 1,459.62 1308.15 4,180,793 4,180,793 Total 1,444.32 1,459.62 1,308.15 4,180,793 4,180,793
Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by Single Family Housing 10.80 7.30 7.50 48.40 15.90 35.70 86 11 3

4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Single Family Housing 0.521458 0.053308 0.175656 0.151963 0.025001 0.006656 0.014407 0.022718 0.000702 0.000287 0.023515 0.001463 0.002865 CalEEMod Version: CalEEMod.2020.4.0 Page 22 of 31 Date: 1/10/2024 5:18 PM Tract 000 - Fresno County, Annual
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5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Electricity
Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 112.8805 112.8805 0.0183 2.2100e003113.9967 Electricity
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 112.8805 112.8805 0.0183 2.2100e003113.9967 NaturalGas
Mitigated

0.0198 0.1695 0.0721 1.0800e0030.0137 0.0137 0.0137 0.0137 0.0000 196.2585 196.2585 3.7600e0033.6000e003197.4248 NaturalGas
Unmitigated

0.0198 0.1695 0.0721 1.0800e0030.0137 0.0137 0.0137 0.0137 0.0000 196.2585 196.2585 3.7600e0033.6000e003197.4248

5.1 Mitigation Measures Energy
Historical Energy Use: N
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5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
Single Family
Housing

3.67775e
+006

0.0198 0.1695 0.0721 1.0800e0030.0137 0.0137 0.0137 0.0137 0.0000 196.2585 196.2585 3.7600e0033.6000e003197.4248 Total 0.0198 0.1695 0.0721 1.0800e0030.0137 0.0137 0.0137 0.0137 0.0000 196.2585 196.2585 3.7600e0033.6000e003197.4248 Unmitigated
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
Single Family
Housing

3.67775e
+006

0.0198 0.1695 0.0721 1.0800e0030.0137 0.0137 0.0137 0.0137 0.0000 196.2585 196.2585 3.7600e0033.6000e003197.4248 Total 0.0198 0.1695 0.0721 1.0800e0030.0137 0.0137 0.0137 0.0137 0.0000 196.2585 196.2585 3.7600e0033.6000e003197.4248 Mitigated
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6.1 Mitigation Measures Area

6.0 Area Detail

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Single Family
Housing

1.22002e
+006
112.8805 0.0183 2.2100e003113.9967
Total 112.8805 0.0183 2.2100e003113.9967
Unmitigated
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Single Family
Housing

1.22002e
+006
112.8805 0.0183 2.2100e003113.9967
Total 112.8805 0.0183 2.2100e003113.9967
Mitigated
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 1.3748 0.0703 1.1593 4.3000e0040.0109 0.0109 0.0109 0.0109 0.0000 68.1364 68.1364 3.0500e0031.2200e00368.5747 Unmitigated 1.3748 0.0703 1.1593 4.3000e0040.0109 0.0109 0.0109 0.0109 0.0000 68.1364 68.1364 3.0500e0031.2200e00368.5747

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating

0.2585 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

1.0756 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Hearth 6.7000e0030.0572 0.0244 3.7000e0044.6300e0034.6300e0034.6300e0034.6300e0030.0000 66.2807 66.2807 1.2700e0031.2200e00366.6746 Landscaping 0.0341 0.0131 1.1350 6.0000e0056.3000e0036.3000e0036.3000e0036.3000e0030.0000 1.8557 1.8557 1.7800e0030.0000 1.9001 Total 1.3748 0.0703 1.1593 4.3000e0040.0109 0.0109 0.0109 0.0109 0.0000 68.1364 68.1364 3.0500e0031.2200e00368.5747 Unmitigated
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7.1 Mitigation Measures Water

7.0 Water Detail

0.2585 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

1.0756 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Hearth 6.7000e0030.0572 0.0244 3.7000e0044.6300e0034.6300e0034.6300e0034.6300e0030.0000 66.2807 66.2807 1.2700e0031.2200e00366.6746 Landscaping 0.0341 0.0131 1.1350 6.0000e0056.3000e0036.3000e0036.3000e0036.3000e0030.0000 1.8557 1.8557 1.7800e0030.0000 1.9001 Total 1.3748 0.0703 1.1593 4.3000e0040.0109 0.0109 0.0109 0.0109 0.0000 68.1364 68.1364 3.0500e0031.2200e00368.5747 Mitigated
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Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 10.1884 0.3260 7.8100e00320.6642
Unmitigated 10.1884 0.3260 7.8100e00320.6642

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Single Family
Housing

9.96857 /

6.28453

10.1884 0.3260 7.8100e00320.6642
Total 10.1884 0.3260 7.8100e00320.6642
Unmitigated
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7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Single Family
Housing

9.96857 /

6.28453

10.1884 0.3260 7.8100e00320.6642
Total 10.1884 0.3260 7.8100e00320.6642
Mitigated

8.1 Mitigation Measures Waste

8.0 Waste Detail
Total CO2 CH4 N2O CO2e
MT/yr
Mitigated 32.0076 1.8916 0.0000 79.2975
Unmitigated 32.0076 1.8916 0.0000 79.2975
Category/Year
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8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Single Family
Housing
157.68 32.0076 1.8916 0.0000 79.2975
Total 32.0076 1.8916 0.0000 79.2975
Unmitigated
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Single Family
Housing
157.68 32.0076 1.8916 0.0000 79.2975
Total 32.0076 1.8916 0.0000 79.2975
Mitigated

9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type CalEEMod Version: CalEEMod.2020.4.0 Page 30 of 31 Date: 1/10/2024 5:18 PM Tract 000 - Fresno County, Annual
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11.0 Vegetation

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
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Appendix-B
ISR Fee Estimate
781
AGENDA ITEM NO. 13.

Emissions Estimator Worksheet 1/12/2024
Yes q
Project
Phase Name
ISR
Phase
Construction
Start Date
Unmitigated
Baseline(1)
(TPY)
Mitigated
Baseline(2)
(TPY)
Achieved
On-site
Reductions(3)
(tons)
Required
Off-site
Reductions(4)
(tons)
Unmitigated
Baseline(1)
(TPY)
Mitigated
Baseline(2)
(TPY)
Achieved
On-site
Reductions(3)
(tons)
Required
Off-site
Reductions(4)
(tons)
ISR Phase NOx PM10
Ricchiuti Sunnyside 1 1/8/2025 2.2200 1.7760 0.4440 0.0000 0.3900 0.2145 0.1755 0.0000 1 0.4440 0.1755 2 0.0000 0.0000 0.0000 0.0000 2 0.0000 0.0000
3 0.0000 0.0000 0.0000 0.0000 3 0.0000 0.0000
4 0.0000 0.0000 0.0000 0.0000 4 0.0000 0.0000
5 0.0000 0.0000 0.0000 0.0000 5 0.0000 0.0000
6 0.0000 0.0000 0.0000 0.0000 6 0.0000 0.0000
7 0.0000 0.0000 0.0000 0.0000 7 0.0000 0.0000
8 0.0000 0.0000 0.0000 0.0000 8 0.0000 0.0000
9 0.0000 0.0000 0.0000 0.0000 9 0.0000 0.0000
10 0.0000 0.0000 0.0000 0.0000 10 0.0000 0.0000
Total 2.2200 1.7760 0.4440 0.0000 0.3900 0.2145 0.1755 0.0000 Total 0.4440 0.1755 Project
Phase Name
ISR
Phase
Operation
Start Date
Unmitigated
Baseline(1)
(TPY)
Mitigated
Baseline(2)
(TPY)
Achieved
On-site
Reductions(3)
(tons)
Required
Off-site
Reductions(4)
(tons)
Total
Emission
Reductions
Required by
Rule(6)
Average
Annual
Emission
Reductions
Required by
Rule(7)
Unmitigated
Baseline(1)
(TPY)
Mitigated
Baseline(2)
(TPY)
Achieved
On-site
Reductions(3)
(tons)
Required
Off-site
Reductions(4)
(tons)
Total
Emission
Reductions
Required by
Rule(6)
Average
Annual
Emission
Reductions
Required by
Rule(7)
ISR Phase NOx PM10
Ricchiuti SunnySide 1 9/9/2025 1.3600 1.3600 0.0000 3.4000 3.4000 0.3400 1.6000 1.6000 0.0000 8.0000 8.0000 0.8000 1 3.4000 8.0000 2 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2 0.0000 0.0000 3 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 3 0.0000 0.0000 4 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 4 0.0000 0.0000 5 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 5 0.0000 0.0000 6 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 6 0.0000 0.0000 7 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7 0.0000 0.0000 8 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 8 0.0000 0.0000 9 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 9 0.0000 0.0000 10 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 10 0.0000 0.0000 Total 1.3600 1.3600 0.0000 3.4000 3.4000 0.3400 1.6000 1.6000 0.0000 8.0000 8.0000 0.8000 Total 3.4000 8.0000

0.1755
Emission Reductions
Required by Rule(5)
Emission Reductions
Required by Rule(5)

0.0000

0.0000
Applicant/Business Name: Lennar Central Valley California Project Name:

Project Location:

District Project ID No.:

Wilde North at Heritage Grove Residential Development(Ricchiuti Sunnyside) Northeast portion of Perrin and Bryan Avenue, Fresno County Total Required Off-Site Reductions (tons)
Total Achieved On-Site Reductions (tons)
NOx
Project Operations Emissions (Area + Mobile)
PM10

0.4440

0.0000

0.4440

0.1755

0.0000

0.0000
NOx PM10
If applicant selected Construction Clean Fleet Mitigation Measure - Please select "Yes" from dropdown menu Project Construction Emissions
Notes:

TPY: Tons Per Year
(1) Unmitigated Baseline: The project's baseline emissions generated with no on-site emission reduction measures. (2) Mitigated Baseline: The project's baseline emissions generated after on-site emisison reduction measures have been applied. (3) Achieved On-site Reductions: The project's emission reductions achieved after on-site emission reduction measures have been applied. (4) Required Off-site Reductions: The project's remaining emission reductions required by Rule 9510 if on-site emission reduction measures did not achieive the required rule reductions. (5) Emission Reductions Required by Rule: The project's emission reductions required (20% NOx and 45% PM10) for construction from the unmitigated baseline. (6) Total Emission Reductions Required by Rule: The project's emission reductions required (33.3% NOx and 50% PM10) for operations from the unmitigated baseline over a 10-year period. (7) Average Annual Emission Reductions Required by Rule: The project's total emission reduction for operations required by Rule 9510 divided by 10 years. _____
3 782
AGENDA ITEM NO. 13.

Fee Estimator Worksheet 1/12/2024
NOTES:
(1) The start date for each ISR phase is shown in TABLE 1. (2) If you have chosen a ONE-TIME payment for the project, then the total amount due for ALL PHASES is shown under TABLE 2. (3) If you have chosen a DEFERRED payment schedule or would like to propose a DEFERRED payment schedule for the project, the total amount due for a specific year is shown in TABLE 3 according to the schedule in TABLE 1. * If you have not provided a proposed payment date, the District sets a default invoice date of 60 days prior to start of the ISR phase.

Yes q
TABLE 2 -
NO FDS TABLE 3 - APPROVED FEE DEFERRAL SCHEDULE (FDS) BY PAYMENT YEAR Project
Phase Name
ISR
Phase
Start Date
per Phase
Scheduled
Payment
Date*
Required Offsite Reductions
(tons) 2021 2021 2022 2023 2024 2025 2026 2027 2028 2029

3.4000 3.4000

8.0000 8.0000

0.0000 0.0000

3.4000 3.4000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000

8.0000 8.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 $31,790 $0 $0 $0 $0 $0 $0 $0 $0 $0
$72,088 $0 $0 $0 $0 $0 $0 $0 $0 $0
Administrative Fee ($) $4,155.12 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Offsite Fee ($) $103,878.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Total Project Offsite Fee ($) $108,033.12
Year Nox PM10
2021 and Beyond $9,350 $9,011
Lennar Central Valley California
Wilde North at Heritage Grove Residential Development(Ricchiuti Sunnyside) Northeast portion of Perrin and Bryan Avenue, Fresno County If applicant selected Fee Deferral Schedule -
Please select "Yes" from dropdown menu
2 3
5 Applicant/Business Name:

Project Name:

Project Location:

District Project ID No.:
1/8/25
TABLE 1 - PROJECT INFORMATION
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6 —
783
AGENDA ITEM NO. 13.

BIOLOGICAL EVALUATION
LENNAR HOMES TRACT 6452

FRESNO COUNTY, CALIFORNIA
Prepared by:

LIVE OAK ASSOCIATES, INC.

Austin Pearson, Vice President
Rebekah Jensen, Senior Project Manager and Ecologist
Prepared for:

Jeff Callaway
Lennar Central Valley
8080 North Palm Avenue, Suite 110
Fresno, CA 93711
November 8, 2023 PN 2817-01

LIVE OAK
ASSOCIATES, INC.

OAKHURST SAN JOSE SOUTI LAKE TAHOE
P: (559) 642-4880 | F: (559) 642-4883 (408) 224-8300 (408) 281-5885 WWW LOAINC. C O M
6840 Via Del Oro, Suite 220
San Jose, CA 95119
P.O. Box 7314
South Lake Tahoe, CA 96158
P.O. Box 2697 | 39930 Sierra Way #B
Oakhurst, CA 93644
Appendix B
784
AGENDA ITEM NO. 13.
ii

EXECUTIVE SUMMARY
Live Oak Associates, Inc. (LOA) investigated the biological resources of an approximately 18- acre site proposed for a residential development and evaluated potential project-related impacts to such resources pursuant to the California Environmental Quality Act (CEQA). The site is located immediately north of Clovis city limits, in unincorporated Fresno County, California. The project would subdivide the existing parcel into 153 single-family lots, annex the development into the City of Clovis, and change the zoning to accommodate medium- and low-density residential housing. Full buildout of the site is anticipated.

LOA’s analysis was based on a reconnaissance-level field survey conducted on September 25, 2023. At that time, the site consisted of a vacant field traversed by several dirt roads and containing several cleared and graded areas. It supported grasses and forbs typical of annual grasslands in the region, and could best be characterized as ruderal grassland habitat. It did not contain aquatic resources, wildlife movement corridors, sensitive natural communities, or designated critical habitat.

The project site has the potential to be used by various wildlife species, possibly including the special-status tricolored blackbird, Swainson’s hawk, golden eagle, pallid bat, spotted bat, and western mastiff bat. None of these species have the potential to nest or roost on the project site; however, the Swainson’s hawk could potentially nest close enough to the site that individuals could be disturbed by construction activities. Construction-related injury, mortality, and disturbance of nesting Swainson’s hawks and other nesting birds and raptors is considered a potentially significant impact of the project.

No other biological resources would be significantly impacted by project implementation. Impacts are considered less than significant for all regionally-occurring special status plant species, 22 of 23 regionally-occurring special status animal species, wildlife movement corridors, sensitive natural communities, jurisdictional waters, and designated critical habitat. The project appears to be consistent with City of Clovis and County of Fresno General Plan policies related to biological resources, and there are no known Habitat Conservation Plans or Natural Community Conservation Plans in the area.
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AGENDA ITEM NO. 13.
iii

TABLE OF CONTENTS
EXECUTIVE SUMMARY ........................................................................................................................................ ii

1.0 INTRODUCTION .................................................................................................................................................1

1.1 PROJECT DESCRIPTION..............................................................................................................................1

1.2 REPORT OBJECTIVES ..................................................................................................................................1

1.3 STUDY METHODOLOGY..............................................................................................................................4

2.0 EXISTING CONDITIONS...................................................................................................................................5

2.1 REGIONAL SETTING.....................................................................................................................................5

2.2 PROJECT SITE ................................................................................................................................................7

2.3 LAND USES / BIOTIC HABITATS................................................................................................................7

2.4 SPECIAL STATUS PLANTS AND ANIMALS .............................................................................................9

2.5 JURISDICTIONAL WATERS ......................................................................................................................16

2.6 SENSITIVE NATURAL COMMUNITIES...................................................................................................17

2.7 WILDLIFE MOVEMENT CORRIDORS ....................................................................................................17

2.8 DESIGNATED CRITICAL HABITAT.........................................................................................................17

3.0 RELEVANT GOALS, POLICIES, AND LAWS.............................................................................................19

3.1 CALIFORNIA ENVIRONMENTAL QUALITY ACT ...............................................................................19

3.2 OTHER RELEVANT LAWS AND POLICIES ...........................................................................................20

3.2.1 Fresno County and Clovis General Plans ................................................................................................. 20

3.2.2 Threatened and Endangered Species ........................................................................................................ 21

3.2.3 California Fully Protected Species ........................................................................................................... 22

3.2.4 Migratory Birds ........................................................................................................................................ 22

3.2.5 Birds of Prey............................................................................................................................................. 23

3.2.6 Nesting Birds............................................................................................................................................ 23

3.2.7 Habitat Conservation Plans and Natural Community Conservation Plans............................................... 23

3.2.8 Wetlands and Other Jurisdictional Waters................................................................................................ 23

4.0 IMPACTS AND MITIGATIONS ......................................................................................................................26

4.1 POTENTIALLY SIGNIFICANT PROJECT IMPACTS/MITIGATION .................................................26

4.1.1 Potential Project Impacts to Nesting Birds and Raptors including the Swainson’s Hawk ....................... 26

4.2 LESS THAN SIGNIFICANT PROJECT IMPACTS...................................................................................27

4.2.1 Potential Project Impacts to Special Status Plants................................................................................... 27

4.2.2 Project Impacts to Special Status Animal Species Absent from or Unlikely to Occur on the Project Site27

4.2.3 Project Impacts to Special Status Animal Species that Would Use the Site for Foraging Only............... 28

4.2.4 Project Impacts to Wildlife Movement Corridors..................................................................................... 29

4.2.5 Project Impacts to Sensitive Natural Communities and Critical Habitat .................................................. 29

4.2.6 Project Impacts to Jurisdictional Waters................................................................................................... 29

4.2.7 Consistency with Local Policies and Ordinances..................................................................................... 29

4.2.8 Consistency with Habitat Conservation Plans and Natural Community Conservation Plans................... 29 APPENDIX A: VASCULAR PLANT LIST...........................................................................................................31 APPENDIX B: TERRESTRIAL VERTEBRATE SPECIES THAT POTENTIALLY OCCUR ON THE PROJECT SITE ........................................................................................................................................................34 APPENDIX C: REPRESENTATIVE PHOTOS OF THE PROJECT SITE......................................................39 g’s
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AGENDA ITEM NO. 13.
1 1.0 INTRODUCTION
This technical report, prepared by Live Oak Associates, Inc. (LOA) in support of California Environmental Quality Act (CEQA) review, describes the biological resources of an approximately 18-acre site (“project site”) proposed for a residential development (“project”), and evaluates the potential impacts to biological resources associated with project implementation. The project is located immediately north of Clovis city limits in unincorporated Fresno County, California (Figure 1). It may be found on the Clovis and Friant U.S. Geological Survey (USGS)

7.5-minute quadrangles, in Section 20 of Township 12 South, Range 21 East, Mount Diablo Base and Meridian (Figure 2).

1.1 PROJECT DESCRIPTION
Lennar Homes Central Valley proposes a residential development on approximately 18 acres located between Barron and Sunnyside Avenues, north of Perrin Avenue. The existing Tract 6452 will be subdivided into 153 single-family lots and annexed into the City of Clovis. Current County of Fresno zoning is AE-20, which provides for agricultural and related uses on minimum 20-acre parcels; proposed City of Clovis zoning is Medium and Low Density Residential (M/L). The residential development will be located within the City of Clovis Heritage Grove Master Plan and will be subject to design development standards of the plan.

1.2 REPORT OBJECTIVES
This report summarizes a biological study conducted by LOA to facilitate environmental review pursuant to CEQA. As such, the report’s objectives are to:
• Characterize the project site’s existing biological resources, including biotic habitats, flora and fauna, soils, and aquatic resources.
• Evaluate the project site’s potential to support sensitive resources such as special status species, sensitive natural communities, and jurisdictional waters and wetlands. • Summarize all state and federal natural resource protection laws that may be relevant to project implementation.
• Identify and discuss potential project-related impacts to biological resources within the context of CEQA and other state and federal laws.
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AGENDA ITEM NO. 13.

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4 • Identify avoidance and mitigation measures that would reduce the magnitude of projectrelated impacts in a manner consistent with CEQA and species-specific guidelines.

1.3 STUDY METHODOLOGY
A reconnaissance-level field survey of the project site was conducted on September 25, 2023 by LOA ecologist Jeff Gurule. The survey consisted of walking and driving through the project site while identifying its principal land uses, biotic habitats, flora, and fauna, and assessing its potential to support special status species and other sensitive resources.

LOA conducted an analysis of potential project impacts based on the known and potential biotic resources of the project site. Sources of information used in the preparation of this analysis included the California Natural Diversity Data Base (CDFW 2023), Online Inventory of Rare and Endangered Vascular Plants of California (CNPS 2023), and manuals, reports, and references related to plants and animals of the project vicinity.
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AGENDA ITEM NO. 13.
5 2.0 EXISTING CONDITIONS

2.1 REGIONAL SETTING
The project site is located near the eastern margin of the San Joaquin Valley, about four miles southwest of the lowest Sierra foothills. The San Joaquin Valley is a large, nearly flat alluvial plain bordered by the Sierra Nevada to the east, the Tehachapi Mountains to the south, the California coast ranges to the west, and the Sacramento-San Joaquin Delta to the north.

Like most of California, the San Joaquin Valley experiences a Mediterranean climate. Warm, dry summers are followed by cool, moist winters. Summer temperatures commonly exceed 90 degrees Fahrenheit, and the relative humidity is generally very low. Winter temperatures rarely exceed 70 degrees Fahrenheit, with daytime highs often below 60 degrees Fahrenheit. Annual precipitation in the project vicinity varies considerably from year to year, but averages approximately 11 inches, almost all of which falls between the months of October and March (Western Regional Climate Center 2018). Nearly all precipitation falls in the form of rain.

The principal drainage of the project vicinity is Dry Creek, which originates in the Sierra Nevada foothills and flows past the project site approximately 0.6 mile to the southeast at its closest point.

Like many other natural drainages in Fresno County, Dry Creek in the project vicinity is heavily modified, having been channelized, realigned, dammed, and diverted to prevent flooding and to convey flows around developed areas.

The project site is located in the outskirts of Clovis, at the interface of urban and rural land uses.

It is situated in a mosaic of agricultural lands, rural residences, and low- to medium-density residential subdivisions. An adjacent Lennar Homes housing development, Tract 6200, is located immediately south of the site and was actively under construction at the time of LOA’s field survey. A Fresno Metropolitan Flood Control District (FMFCD) basin facility is located immediately to the north. To the east and west lie vacant land similar to the project site. The nearest areas of relatively undisturbed natural lands are located approximately 0.6 mile east and 2 miles north of the project site; both are annual grasslands that do not appear to have previously been used for agricultural cultivation. Please refer to Figure 3 for an aerial map of the project site and surrounding lands.
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AGENDA ITEM NO. 13.

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7 2.2 PROJECT SITE
The project site has relatively level topography and sits at an elevation of approximately 385 feet above sea level. At the time of LOA’s survey, it consisted of a vacant field traversed by several dirt roads. A portion of the eastern end of the site had elevated topography, possibly the result of excess soil storage, and a shallow excavated area was observed in the middle of the site. An approximately 2-acre area along the site’s southern boundary was enclosed by silt fencing associated with the adjoining Lennar Homes Tract 6200 project, which was under construction.

The project site does not appear to have previously been cultivated, other than possible dryfarming. Analysis of aerial imagery indicates that it is periodically disked and/or mowed, with some areas subject to grading, and that the configuration of dirt roads has changed over time.

The site contains two soil map units: Atwater sandy loam, 0 to 3 percent slopes; and Greenfield sandy loam, 0 to 3 percent slopes (NRCS 2023). Neither of these map units are considered hydric, meaning they do not have the propensity to pond water and support the growth of wetland vegetation.

Lists of the vascular plant species observed within the project site and the terrestrial vertebrates using, or potentially using, the site are provided in Appendices A and B, respectively.

Representative photographs are presented in Appendix C.

2.3 LAND USES / BIOTIC HABITATS
A single biotic habitat was identified within the project site: ruderal grassland. This habitat supported grasses and forbs typical of annual grasslands in the project vicinity, but was characterized by repeated disturbance including disking and mowing, road construction, and localized grading. Dominant plant species at the time of LOA’s survey were primarily non-native and included foxtail barley (Hordeum murinum), wild oats (Avena sp.), ripgut brome (Bromus diandrus), prickly lettuce (Lactuca serriola), doveweed (Croton setiger), jimsonweed (Datura wrightii), and red-stemmed filaree (Erodium cicutarium). g’s
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AGENDA ITEM NO. 13.
8 The degraded nature of this grassland, combined with its location within the outskirts of Clovis, limits its potential for faunal biodiversity. However, some wildlife species certainly utilize the grassland. Reptiles expected to occur in this habitat include the side-blotched lizard (Uta stansburiana), common kingsnake (Lampropeltis californiae), and Pacific gopher snake (Pituophis catenifer catenifer). Common amphibians such as the western toad (Bufo boreas) and Sierran treefrog (Pseudacris sierra) may breed at the adjoining FMFCD basin facility and subsequently disperse through the site’s grassland habitat.

The site’s ruderal grassland is expected to support both nesting and foraging by various avian species. Likely nesters include the western meadowlark (Sturnella neglecta) and mourning dove (Zenaida macroura), both of which nest in ground vegetation, and the killdeer (Charadrius vociferus), which preferentially nests in disturbed areas and may use sparsely vegetated or barren portions of the grassland. Likely foragers include the western kingbird (Tyrannus verticalis) in the summer, the Say’s phoebe (Sayornis saya) and savannah sparrow (Passerculus sandwichensis) in the winter, and the Brewer’s blackbird (Euphagus cyanocephalus), American kestrel (Falco sparverius) and red-tailed hawk (Buteo jamaicensis) year-round.

Small mammal use of the ruderal grassland is expected to include the deer mouse (Peromyscus maniculatus), California vole (Microtus californicus), and Botta’s pocket gopher (Thomomys bottae). At the time of LOA’s field survey, burrowing rodent activity was limited to a small area in the northwestern portion of the site that was recently used for bee boxes (Google Earth aerial imagery dated May 2023) and was relatively barren of vegetation. All burrows in this area were associated with the Botta’s pocket gopher and were plugged with soil. No open burrows were observed anywhere on the site.

Mammalian predators expected to use the site’s ruderal grassland include the coyote (Canis latrans), raccoon (Procyon lotor), and striped skunk (Mephitis mephitis). Due to the proximity of residences, domestic dogs (Canis familiaris) and cats (Felis catus) may also occur here from time to time.
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AGENDA ITEM NO. 13.
9 2.4 SPECIAL STATUS PLANTS AND ANIMALS
Many species of plants and animals within the state of California have low populations, limited distributions, or both. Such species may be considered “rare” and are vulnerable to extirpation as the state’s human population grows and the habitats these species occupy are converted to agricultural and urban uses. As described more fully in Section 3.2, state and federal laws have provided CDFW and the U.S. Fish and Wildlife Service (USFWS) with a mechanism for conserving and protecting the diversity of plant and animal species native to the state. A sizable number of native plants and animals have been formally designated as threatened or endangered under state and federal endangered species legislation. Others have been designated as “candidates” for such listing. Still others have been designated as “species of special concern” or “fully protected” by CDFW. The California Native Plant Society (CNPS) has developed its own ranking system, California Rare Plant Ranks (CRPR), for native plants considered rare, threatened, or endangered (CNPS 2023). Plants with a CRPR ranking of 1 or 2 meet the definitions of the California Endangered Species Act and are eligible for state listing. Collectively, all of the aforementioned plants and animals are referred to as “special status species.” The California Natural Diversity Data Base (CNDDB) (CDFW 2023) was queried for special status species occurrences in the twelve USGS 7.5-minute quadrangles containing and immediately surrounding the project site (Clovis, Friant, Little Table Mtn., Millerton Lake West, Millerton Lake East, Academy, Round Mountain, Sanger, Malaga, Fresno South, Fresno North, and Lanes Bridge). These species, and their potential to occur on site, are listed in Table 1 on the following pages. Sources of information for Table 1 included California’s Wildlife, Volumes I, II, and III (Zeiner et. al 1988), The Jepson Manual: Vascular Plants of California, second edition (Baldwin et al. 2012), CNPS’s Online Inventory of Rare and Endangered Vascular Plants of California (CNPS 2023), Calflora.org, and eBird.org.
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AGENDA ITEM NO. 13.
10 TABLE 1. LIST OF SPECIAL STATUS SPECIES THAT COULD OCCUR IN THE

PROJECT VICINITY
PLANTS (adapted from CDFW 2023, CNPS 2023)
Species Listed as Threatened or Endangered under the State and/or Federal Endangered Species Act Species Status Habitat / Range Occurrence on the Project Site Succulent owl’s clover
(Castilleja campestris var.
succulenta)

FT, CE,
CRPR 1B
Occurs in freshwater wetlands, and
occasionally in non-wetlands in
Valley grassland and foothill
woodlands, between 130 and 2,000 ft.
in elevation. Blooms April-May.

Absent. Suitable vernal pool habitat for
this species is absent from the project site.

California jewelflower
(Caulanthus californicus)

FE, CE,
CRPR 1B
Occurs in chenopod scrub, pinyon and
juniper woodland, and valley and
foothill grassland in sandy soils.

Elevations between 200 and 3,300
feet. Blooms February-May.

Absent. All historical populations of this
species on the San Joaquin Valley floor
are thought to have been extirpated by
1986 (USFWS 1998). There is only one
known occurrence of the California
jewelflower, historical or otherwise,
within approximately 50 miles of the
project site. It is generally mapped to
Fresno, based on a collection from the late
1890s or early 1900s. That population has
long since been extirpated (CDFW 2023).

Boggs Lake hedge-hyssop
(Gratiola heterosepala)

CE, CRPR
1B
Found in vernal pools or lake margins,
usually in clay soils; elevations up to
7,800 feet. Blooms April-August.

Absent. Suitable aquatic habitat for this
species is absent from the project site.

San Joaquin Valley orcutt
grass
(Orcuttia inaequalis)
FT, CE
CRPR 1B
Occurs in Central Valley vernal pools
between 130 and 820 ft. in elevation.

Requires deep pools with prolonged
periods of inundation. Blooms AprilSept.

Absent. Suitable vernal pool habitat for
this species is absent from the project site.

Hairy orcutt grass
(Orcuttia pilosa)
FE, CE
CRPR 1B
Occurs in Central Valley vernal pools
between 65 and 1,215 ft. in elevation.

Requires deep pools with prolonged
periods of inundation. Blooms MaySept.

Absent. Suitable vernal pool habitat for
this species is absent from the project site.

Hartweg’s golden sunburst
(Pseudobahia bahiifolia)
FE, CE
CRPR 1B
Occurs in grasslands of the western
foothills of the Sierra Nevada in
heavy clay soils of the Porterville,
Cibo, Mt. Olive and Centerville soil
series, between 230 and 525 ft. in
elevation. Blooms March-April.

Absent. Suitable soils for this species are
absent from the project site.

San Joaquin adobe sunburst
(Pseudobahia peirsonii)

FT, CE,
CRPR 1B
Annual sunflower occurs in
grasslands of the Sierra Nevada
foothills in heavy clay soils of the
Porterville and Centerville series,
between 300 and 2,625 ft. in
elevation. Blooms March-April.

Absent. Suitable soils for this species are
absent from the project site.

Greene’s tuctoria
(Tuctoria greenei)
FE, CR
CRPR 1B
Occurs in vernal pools between 130
and 3,740 ft. in elevation. Requires
deep pools with prolonged periods of
inundation. Blooms May-Sept.

Absent. Suitable vernal pool habitat for
this species is absent from the project site.
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AGENDA ITEM NO. 13.
11 TABLE 1. LIST OF SPECIAL STATUS SPECIES THAT COULD OCCUR IN THE

PROJECT VICINITY
PLANTS (cont’d)
CNPS-ranked Species
Species Status Habitat / Range Occurrence on the Project Site Hoover’s calycadenia
(Calycadenia hooveri)
CRPR 1B Occurs on exposed, rocky, barren soil
within valley grasslands and foothill
woodlands between 200 and 980 ft. in
elevation. Blooms June-September.

Absent. Suitable rocky soils for this
species are absent from the project site.

There is only one documented occurrence
of this species on the valley floor, recorded
in Stanislaus County in 1976. All other
known populations are on and around rock
formations in the lower foothills (CDFW
2023).

Bristly sedge
(Carex comosa)
CRPR 2B Found at the margins of lakes and
other marsh habitats within valley and
foothill grassland and coastal prairie
ecosystems. Elevations up to 2,000 ft.

Blooms May-September.

Absent. Suitable habitat for this species is
absent from the project site.

Tree-anemone
(Carpenteria californica)
CRPR 1B Found within on well-drained granitic
soils within woodland and chaparral
habitats, usually in north-facing
ravines and drainages. Elevations
1,100-4,400 feet; blooms April-July.

Absent. Habitat for tree-anemone is
absent from the project site, and the site is
situated below this species’ elevational
distribution.

Dwarf downingia
(Downingia pusilla)
CRPR 2B Occurs in vernal pools in valley and
foothill grassland habitats up to 1,460
ft. in elevation. Blooms March-May.

Absent. Suitable vernal pool habitat for
this species is absent from the project site.

Spiny-sepaled button-celery
(Eryginum spinosepalum)
CRPR 1B Occurs in vernal pools in valley and
foothill grasslands of the San Joaquin
Valley and the Tulare Basin, between
330 and 840 ft. in elevation. Blooms
April-May.

Absent. Suitable vernal pool habitat for
this species is absent from the project site.

California satintail
(Imperata brevifolia)
CRPR 2B Found in wetland seeps and riparian
areas within various types of scrub,
chaparral, and desert communities up
to 4,000 feet in elevation. Blooms
September-May.

Absent. Suitable habitat for this species is
absent from the project site.

Forked hare-leaf
(Lagophylla dichotoma)
CRPR 1B Occurs in woodland and valley and
foothill grassland habitats, sometimes
in clay soils, at elevations from 600 to
1,100 feet. Blooms April-May.

Absent. The site is below the typical
elevational range of the forked hare-leaf,
and its degraded grassland habitat would
be marginal, at best, for this species. There
are only seven CNDDB occurrences of the
forked hare-leaf; only one of these, from
1915, is mapped on the valley floor, and
there is considerable location uncertainty
associated with it. All other known
occurrences are in the lower foothills.

Madera leptosiphon
(Leptosiphon serrulatus)
CRPR 1B Found on dry slopes, often on
decomposed granite, within
cismontane woodlands and lower
montane coniferous forests. May
occur in disturbed locations such as
roadcuts (CDFW 2023, iNaturalist
2023). Elevations between 100 and
4,200 ft.; blooms April – May.

Absent. Habitat for Madera leptosiphon is
absent from the project site, and the site is
situated below this species’ elevational
distribution.
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AGENDA ITEM NO. 13.
12 PLANTS (cont’d)
CNPS-ranked Species
Species Status Habitat / Range Occurrence on the Project Site Orange Lupine
(Lupinus citrinus var.
citrinus)
CRPR 1B Found in association with rocky,
decomposed granitic outcrops in
chaparral, woodland, and lower
montane coniferous forest 2,000-
5,500 ft. in elevation. Blooms AprilAugust.

Absent. Habitat for orange lupine is
absent from the project site, and the site is
situated below this species’ elevational
distribution.

Pincushion navarretia
(Navarretia myersii ssp.
myersii)
CRPR 1B Found in vernal pools within annual
grassland habitats at elevations up to
1,000 ft. Blooms April-May.

Absent. Suitable vernal pool habitat for
this species is absent from the project site.

Sanford’s arrowhead
(Sagittaria sanfordii)
CRPR 1B Occurs in shallow freshwater
marshes, ponds, sloughs, and ditches
of the Central Valley and Sierra
Nevada foothills up to 2,100 ft. in
elevation. Blooms May-October.

Absent. Suitable aquatic habitat for this
species is absent from the project site.

ANIMALS (cont’d)
Species Listed as Threatened or Endangered under the State and/or Federal Endangered Species Act Crotch bumblebee
(Bombus crotchii)
CCE Once common in the Central Valley, this
species is now absent from most of it,
particularly in the central portion of its
historic range. Where present, it is
associated with open grassland and
scrub habitats, where it relies on food
plants of the Asclepias, Chaenactis,
Lupinus, Medicago, Phacelia, and
Salvia genera (Williams et al. 2014).

Unlikely. This species is unlikely to occur
in the matrix of residential and agricultural
lands that characterizes the project
vicinity. In fact, it is generally thought to
be absent from the valley floor.

Valley elderberry longhorn
beetle (VELB)
(Desmocerus californicus
dimorphus)
FT Lives in mature elderberry shrubs of
California’s Central Valley and Sierra
foothills, generally along waterways and
in floodplains.

Absent. The USFWS has revised its
understanding of VELB distribution to
exclude the San Joaquin Valley south of
Merced County. Moreover, elderberry
shrubs are absent from the project site.

Vernal pool fairy shrimp
(Branchinecta lynchi)
FT Occurs in vernal pools, clear to teacolored water in grass or mud-bottomed swales, and basalt depression pools.

Absent. Suitable vernal pool habitat for
this species is absent from the project site.

Vernal pool tadpole shrimp
(Lepidurus packardi)
FE Found in vernal pools and other seasonal
wetlands in the Central Valley, Bay
Delta, and eastern San Francisco Bay
Area.

Absent. Suitable vernal pool habitat for
this species is absent from the project site.

TABLE 1. LIST OF SPECIAL STATUS SPECIES THAT COULD OCCUR IN THE

PROJECT VICINITY
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AGENDA ITEM NO. 13.
13 ANIMALS (cont’d)
Species Listed as Threatened or Endangered under the State and/or Federal Endangered Species Act Species Status Habitat / Range Occurrence on the Project Site California tiger salamander
(CTS)
(Ambystoma californiense)
FT, CT Found primarily in annual grasslands;
requires vernal pools for breeding and
rodent burrows for aestivation. Although
most CTS aestivate within 0.4 mile of
their breeding pond, outliers may
aestivate up to 1.3 miles away (Orloff
2011).

Unlikely. CTS were historically common
in the project vicinity; the CNDDB lists 14
occurrences within 5 miles of the project
site. All extant occurrences in the project
vicinity are associated with contiguous
grassland habitats. The closest such
grassland is about 0.6 mile east of the
project site at its nearest point. The closest
extant CTS occurrences are in this same
grassland area, at about 0.9 and 1.3 miles
east of site boundaries. While CTS
associated with this block of natural land
may be physiologically capable of
accessing the project site, it is extremely
unlikely that individuals of this species
would forgo suitable habitat in favor of the
anthropogenic landscape that
characterizes the project vicinity.

Moreover, the site does not contain any
habitat features that could support CTS
life stages. Aquatic habitat is absent, and
at the time of LOA’s survey, the site
contained no open burrows within which
CTS could aestivate.

Western pond turtle
(Actinemys marmorata)
FPT,
CSC
Occurs in ponds, lakes, rivers, creeks,
marshes, and irrigation ditches with
abundant vegetation, and either rocky or
muddy bottoms. Logs, rocks, cattail
mats, and exposed banks are required for
basking. Eggs are deposited in a variety
of soil types on shore.

Unlikely. Suitable aquatic habitat for the
western pond turtle is absent from the
project site and adjacent lands. The
detention basins of the adjoining FMFCD
facility do not appear to have an adequate
inundation regime for this species.

Swainson’s hawk
(Buteo swainsoni)
CT This breeding migrant to California
nests in mature trees in riparian areas
and oak savannah, and occasionally in
lone trees at the margins of agricultural
fields. Requires adjacent suitable
foraging areas such as grasslands or
alfalfa fields supporting rodent
populations.

Possible. Swainson’s hawks are
occasionally sighted in the project vicinity
(eBird 2023), and there is some chance for
individuals of this species to forage on site
from time to time. Nesting habitat is
absent from the site itself, but may be
found on nearby rural residential
properties and along the Enterprise Canal.

Golden eagle
(Aquila chrysaetos)
CFP Found a wide range of habitats
throughout California’s mountains,
foothills, sage-juniper flats, and deserts.

Primarily nests on cliffs, but may also
use large trees in open areas.

Possible. Golden eagles may occasionally
pass over or forage on site, but nesting
habitat is absent from the site and
surrounding lands.

Western yellow-billed
cuckoo
(Coccyzus americanus
occidentalis)
FT, CE Frequents valley foothill and desert
riparian habitats in scattered locations in
California.

Absent. This species has been extirpated
from the project vicinity.

Least Bell’s vireo
(Vireo bellii pusillus)
FE, CE This breeding migrant nests in dense,
early-successional riparian vegetation,
and forages in adjacent chaparral and
coastal sage scrub. Winters in Mexico
and Central America.

Absent. Suitable habitat for this species is
absent from the project vicinity.

TABLE 1. LIST OF SPECIAL STATUS SPECIES THAT COULD OCCUR IN THE

PROJECT VICINITY
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AGENDA ITEM NO. 13.
14 ANIMALS (cont’d)
Species Listed as Threatened or Endangered under the State and/or Federal Endangered Species Act Species Status Habitat / Range Occurrence on the Project Site Tricolored blackbird
(Agelaius tricolor)
CT Nests colonially near fresh water in
dense cattails or tules, in thickets of
willows or shrubs, and increasingly in
grain fields. Forages in grassland and
cropland areas.

Possible. Tricolored blackbirds may
occasionally forage on the project site,
but nesting habitat is absent from the site
and surrounding lands.

Fresno kangaroo rat
(Dipodomys nitratoides
exilis)
FE, CE Historically occupied chenopod scrub
and grassland communities on the San
Joaquin Valley floor east of the wetlands
of the San Joaquin River and Fresno
Slough. Associated with bare alkaline
clay-based soils in level terrain.

Absent. The project site does not
contain suitable habitat for the Fresno
kangaroo rat, and no known populations
of this species remain in Fresno County.

San Joaquin kit fox (SJKF)
(Vulpes macrotis mutica)
FE, CT Frequents desert alkali scrub and annual
grasslands and may forage in adjacent
agricultural habitats. Utilizes enlarged
ground squirrel burrows as denning
habitat.

Unlikely. The highly disturbed habitats
of the project site and surrounding lands
are marginal, at best, for this species.

Moreover, there are no natural
occurrences of the SJKF in the project
vicinity. There is only one record of this
species within a 10-mile radius of the
project area, recorded in Friant in the
early 1990s. That sighting has since
been characterized by the observer as a
kit fox that had been domesticated and
transported from another part of the
state (D. Mitchell, pers. comm.).

California Species of Special Concern or Fully Protected Hardhead
(Mylopharadon
conocephalus)
CSC Occurs in clear deep streams with a slow
but present flow, in a low to midelevation environment. May also inhabit lakes or reservoirs. Spawns in pools,
runs, or rifles with a gravel and rocky
substrate.

Absent. Aquatic habitat is absent from
the project site.

Western spadefoot
(Spea hammondii)
CSC Occurs in grasslands of San Joaquin
Valley, where it breeds in vernal pools
or other seasonal wetlands and aestivates
in underground refugia such as rodent
burrows. Baumberger et al. (2019)
recorded a maximum distance of around
890 feet between breeding and
aestivation sites.

Unlikely. The project site does not
contain suitable habitat for the western
spadefoot. Aquatic habitat is absent, and
at the time of LOA’s survey, the site
contained no open burrows within
which this species could aestivate.

Moreover, although the western
spadefoot has been documented in
grassland habitats approximately 2.5
miles north of the project site, and may
also occur in the contiguous grassland

0.6 mile east of the site, it is unlikely to
have persisted in the anthropogenic
landscape that characterizes the
immediate project vicinity. The site is
well outside of the distance from
suitable habitat that this species is
capable of dispersing.

TABLE 1. LIST OF SPECIAL STATUS SPECIES THAT COULD OCCUR IN THE

PROJECT VICINITY
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AGENDA ITEM NO. 13.
15 ANIMALS (cont’d)
California Species of Special Concern or Fully Protected Species Status Habitat Occurrence on the Project Site
Northern California legless
lizard
(Anniella pulchra)
CSC Occurs in sparsely vegetated areas of
beach dunes, chaparral, pine-oak
woodlands, desert scrub, sandy washes,
and stream terraces with sycamores,
cottonwoods, or oaks. Requires moist
soils.

Absent. The project site does not
contain suitable habitat for the northern
California legless lizard. The only
CNDDB record for this species in the
Fresno/Clovis area is from the 1880s.

Coast horned lizard
(Phrynosoma blainvillii)
CSC Ranges from the central and southern
California coast inland through the
western Sierra Nevada, where it is found
in grassland and open areas within
woodland and forest habitats. Often
found in sandy areas including washes
and floodplains.

Absent. The only CNDDB record for
the coast horned lizard in the
Fresno/Clovis area is from 1893. Any
habitat for this species that may have
once been present in the project vicinity
would have been lost with the area’s
conversion to anthropogenic uses.

California glossy snake
(Arizona elegans
occidentalis)
CSC Inhabits arid scrub, rocky washes,
grasslands, and chaparral, where it
forages nocturnally, hiding in
underground burrows during the day.

Prefers loose, sandy soils.

Absent. The project site is outside of the
current distribution of this species
(California Herps 2023).

Burrowing owl
(Athene cunicularia)
CSC Frequents open, dry annual or perennial
grasslands, deserts, and scrublands
characterized by low growing
vegetation. Dependent upon burrowing
mammals, most notably the California
ground squirrel, for nest burrows.

Unlikely. The project site is situated in
the outskirts of Clovis, in a landscape
dominated by residential development,
orchards, and other uses incompatible
with burrowing owl ecology. The
closest known occurrences of this
species are approximately 3 miles to the
east in contiguous grassland habitat
associated with Dry Creek and the Big
Dry Creek Reservoir (eBird 2023).

Landscape factors are likely to preclude
burrowing owls from occurring in the
project vicinity and, by extension, the
site itself. Moreover, at the time of
LOA’s survey, the site contained no
California ground squirrel burrows or
any other open burrow within which
burrowing owls could nest or roost,
further limiting their potential for
occurrence.

Pallid bat
(Antrozous pallidus)
CSC Found in grasslands, chaparral, and
woodlands, where it feeds on groundand vegetation-dwelling arthropods, and occasionally takes insects in flight.

Prefers to roost in rock crevices, but
many also use tree cavities, caves,
bridges, and buildings.

Possible. The pallid bat could forage on
or over the site, but roosting habitat is
absent.

TABLE 1. LIST OF SPECIAL STATUS SPECIES THAT COULD OCCUR IN THE

PROJECT VICINITY
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AGENDA ITEM NO. 13.
16 ANIMALS (cont’d)
California Species of Special Concern or Fully Protected Species Status Habitat Occurrence on the Project Site
Spotted bat
(Euderma maculatum)
CSC Typically associated with prominent
rocky habitats where it roosts in
crevices, but is known to occur in a wide
range of habitats. Forages in large open
habitats, including Ponderosa pine
forests and marshlands.

Possible. The spotted bat could forage
over the site, but roosting habitat is
absent.

Western mastiff bat
(Eumops perotis ssp.
californicus)
CSC Frequents open, semi-arid to arid
habitats, including conifer, and
deciduous woodlands, coastal scrub,
grasslands, palm oasis, chaparral and
urban. Roosts in cliff faces, high
buildings, and tunnels.

Possible. The western mastiff bat could
forage over the site, but roosting habitat
is absent.

American badger
(Taxidea taxus)
CSC Found in drier open stages of most
shrub, forest, and herbaceous habitats
with friable soils. Utilize subterranean
burrows, usually self-dug, for rest and
reproduction.

Unlikely. The site’s disturbed nature
and urban setting make it highly
unlikely to be occupied or utilized by
American badgers.

OCCURRENCE DESIGNATIONS AND STATUS CODES

Present: Species observed on the site at time of field surveys or during recent past.

Likely: Species not observed on the site, but it may reasonably be expected to occur there on a regular basis.

Possible: Species not observed on the site, but it could occur there from time to time.

Unlikely: Species not observed on the site, and would not be expected to occur there except, perhaps, as a transient.

Absent: Species not observed on the site and precluded from occurring there because habitat requirements not met.

STATUS CODES
FE Federally Endangered CE California Endangered
FT Federally Threatened CT California Threatened
FC Federal Candidate CCE California Candidate Endangered FPT Federal Proposed Threatened CFP California Fully Protected CSC California Species of Special Concern
CR California Rare

CRPR CODES
1A Plants Presumed Extinct in California 2B Plants Rare, Threatened, or Endangered in 1B Plants Rare, Threatened, or Endangered in California, but more common elsewhere California and elsewhere

2.5 JURISDICTIONAL WATERS
Jurisdictional waters are those rivers, creeks, drainages, lakes, ponds, reservoirs, and wetlands that are subject to the authority of the USACE, CDFW, and/or the RWQCB. In general, the USACE regulates navigable waters, tributaries to navigable waters, and wetlands with a continuous surface connection to these waters, where wetlands are defined by the presence of hydric soils, hydrophytic vegetation, and wetland hydrology. All waters under USACE jurisdiction are also regulated by the RWQCB as waters of the State. Additionally, the RWQCB asserts jurisdiction over certain isolated TABLE 1. LIST OF SPECIAL STATUS SPECIES THAT COULD OCCUR IN THE

PROJECT VICINITY
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AGENDA ITEM NO. 13.
17 features disclaimed by the USACE. The CDFW has jurisdiction over waters that have a defined bed and bank. The regulation of jurisdictional waters is discussed in more detail in Section 3.2.8.

Aquatic features, including any potentially jurisdictional waters or wetlands, are absent from the project site.

2.6 SENSITIVE NATURAL COMMUNITIES
California contains a wide range of natural communities, or unique assemblages of plants and animals. These communities have largely been classified and mapped by CDFW as part of their Vegetation Classification and Mapping Program (VegCAMP). Natural communities are assigned state and global ranks according to their rarity and the magnitude and trend of the threats they face.

Any natural community with a state rank of 3 or lower (on a 1 to 5 scale) is considered “sensitive” and must be considered in CEQA review.

The project site does not contain or adjoin any sensitive natural communities.

2.7 WILDLIFE MOVEMENT CORRIDORS
Wildlife movement corridors are routes that animals regularly and predictably follow during seasonal migration, dispersal from native ranges, daily travel within home ranges, and interpopulation movements. Movement corridors in California are typically associated with valleys, ridgelines, and rivers and creeks supporting riparian vegetation.

The project site does not contain or adjoin any features likely to function as wildlife movement corridors.

2.8 DESIGNATED CRITICAL HABITAT
The USFWS often designates areas of “critical habitat” when it lists species as threatened or endangered. Critical habitat is a specific geographic area(s) that contains features essential for the conservation of a threatened or endangered species and that may require special management and protection.
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AGENDA ITEM NO. 13.
18 Designated critical habitat is absent from the project site and immediate vicinity. The nearest unit of critical habitat is located approximately 3.0 miles northeast of the project site at its closest point, and is designated for the protection of the succulent owl’s-clover (Castilleja campestris var. succulenta). Critical habitat for the San Joaquin Valley orcutt grass (Orcuttia inaequalis) and vernal pool fairy shrimp (Branchinecta lynchi) is located in the same general area, approximately

3.1 miles north-northeast of the project site.
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AGENDA ITEM NO. 13.
19 3.0 RELEVANT GOALS, POLICIES, AND LAWS

3.1 CALIFORNIA ENVIRONMENTAL QUALITY ACT
In California, any project carried out or approved by a public agency that will result in a direct or reasonably foreseeable indirect physical change in the environment must comply with CEQA. The purpose of CEQA is to ensure that a project’s potential impacts on the environment are evaluated and methods for avoiding or reducing these impacts are considered before the project is allowed to move forward. A secondary aim of CEQA is to provide justification to the public for the approval of any projects involving significant impacts on the environment.

According to Section 15382 of the CEQA Guidelines, a significant effect on the environment means a “substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project, including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic interest.” Although the lead agency may set its own CEQA significance thresholds, project impacts to biological resources are generally considered to be significant if they would meet any of the following criteria established in Appendix G of the CEQA Guidelines:
• 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 CDFW or USFWS.
• Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations or by CDFW or USFWS.
• 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.
• Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.
• Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.
• Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. g’s
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AGENDA ITEM NO. 13.
20 Furthermore, CEQA Guidelines Section 15065(a) requires the lead agency to make “mandatory findings of significance” if there is substantial evidence that a project may:
• Substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, or substantially reduce the number or restrict the range of an endangered, rare or threatened species. • Achieve short-term environmental goals to the detriment of long-term environmental goals.
• Produce environmental effects that are individually limited but cumulatively considerable, meaning that the incremental effects of the project are significant when viewed in connection with the effects of past projects, other current projects, and probable future projects.

3.2 OTHER RELEVANT LAWS AND POLICIES

3.2.1 Fresno County and Clovis General Plans
California state law requires cities and counties to adopt general plans to guide future development while conserving natural resources and working landscapes. In general, projects must be consistent with the goals and policies of these general plans. Because the proposed residential development will be annexed into the City of Clovis, it is assumed that it is subject to both the County of Fresno and City of Clovis general plans. The City of Clovis’s general plan was adopted in 2014, and has a planning horizon extending through 2035. The County of Fresno’s general plan was adopted in 2000, and has a planning horizon of 15 to 25 years.

The Open Space and Conservation Element of the Clovis General Plan includes goals concerning preservation of natural resources and protection of water quality. These goals are supported by numerous policies and implementation programs. Policies relevant to the project include: 1) encourage new development to incorporate on-site natural resources and low impact development techniques, 2) support the protection of biological resources through the conservation of high quality habitat, 3) encourage the use of native plant species and prohibit the use of invasive species, and 4) minimize the use of non-point source pollutants and storm water runoff.

The Open Space and Conservation Element of the Fresno County General Plan includes a number of goals, policies, and implementation programs concerning biological resources. Policies of g’s
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AGENDA ITEM NO. 13.
21 particular relevance to the project are summarized as follows: 1) the County shall support the “nonet-loss” wetlands policies of the USACE, USFWS, and CDFW, and shall require new development to fully mitigate the loss of regulated wetlands, 2) the County shall require new development to be designed in such a manner that pollutants and siltation do not significantly degrade the area, value, or function of wetlands, 3) the County shall require new developments to preserve and enhance native riparian habitat unless public safety concerns require removal of habitat, and shall require riparian protection zones around natural watercourses, 4) the County shall identify and conserve remaining upland habitat areas adjacent to wetland and riparian areas that are critically important to wildlife species associated with those wetland and riparian areas, 5) where practicable, the County shall support efforts to avoid the “net” loss of important wildlife habitat, and should preserve in a natural state those areas defined as habitats for rare and endangered animal and plant species, 6) if loss of important habitat for special status species or other valuable wildlife resources cannot be avoided, the County shall impose adequate mitigation, 7) the County shall require adequate buffer zones between construction activities and significant wildlife resources, 8) the County shall support the preservation of significant areas of natural vegetation, e.g. oak woodlands, riparian areas, and vernal pools, and 9) the County shall require that new developments preserve natural woodlands to the maximum extent possible.

3.2.2 Threatened and Endangered Species
In California, imperiled plants and animals may be afforded special legal protections under the California Endangered Species Act (CESA) and/or Federal Endangered Species Act (FESA). Species may be listed as “threatened” or “endangered” under one or both Acts, and/or as “rare” under CESA. Under both Acts, “endangered” means a species is in danger of extinction throughout all or a significant portion of its range, and “threatened” means a species is likely to become endangered within the foreseeable future. Under CESA, “rare” means a species may become endangered if their present environment worsens. Both Acts prohibit “take” of listed species, defined under CESA as “to hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture or kill” (California Fish and Game Code, Section 86), and more broadly defined under FESA to include “harm” (16 USC, Section 1532(19), 50 CFR, Section 17.3). The USFWS commonly interprets “take” to include the loss of habitat utilized by a listed species. g’s
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AGENDA ITEM NO. 13.
22 When state and federally listed species have the potential to be impacted by a project, the USFWS and CDFW must be included in the CEQA process. These agencies review the environmental document to determine the adequacy of its treatment of endangered species issues and to make project-specific recommendations for the protection of listed species. Projects that may result in the “take” of listed species must generally enter into consultation with the USFWS and/or CDFW pursuant to FESA and CESA, respectively. In some cases, incidental take authorization(s) from these agencies may be required before the project can be implemented.

3.2.3 California Fully Protected Species
The classification of certain animal species as “fully protected” was the State of California’s initial effort in the 1960s, prior to the passage of the California Endangered Species Act (CESA), to identify and provide additional protection to those species that were rare or faced possible extinction. Following CESA enactment in 1970, many fully protected species were also listed as California threatened or endangered. The list of fully protected species are identified, and their protections stipulated, in California Fish and Game Code Sections 3511 (birds), 4700 (mammals), 5050 (reptiles and amphibians), and fish (5515). Fully protected species may not be taken or possessed at any time and no licenses or permits may be issued for their take, except in conjunction with necessary scientific research and protection of livestock.

3.2.4 Migratory Birds
The Federal Migratory Bird Treaty Act (FMBTA: 16 USC 703-712) prohibits killing, possessing, or trading in any bird species covered in one of four international conventions to which the United States is a party, except in accordance with regulations prescribed by the Secretary of the Interior.

The name of the act is misleading, as it actually covers almost all birds native to the United States, even those that are non-migratory. The FMBTA encompasses whole birds, parts of birds, and bird nests and eggs.

Native birds are also protected under California state law. The California Fish and Game Code makes it unlawful to take or possess any non-game bird covered by the FMBTA (Section 3513), as well as any other native non-game bird (Section 3800), even if incidental to lawful activities. g’s
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23 3.2.5 Birds of Prey
Birds of prey are also protected in California under provisions of the State Fish and Game Code, Section 3503.5, 1992), which states that it is “unlawful to take, possess, or destroy any birds in the order Falconiformes or Strigiformes (birds of prey) or to take, possess, or destroy the nest or eggs of any such bird except as otherwise provided by this code or any regulation adopted pursuant thereto.” Construction disturbance during the breeding season could result in the incidental loss of fertile eggs or nestlings, or otherwise lead to nest abandonment. Disturbance that causes nest abandonment and/or loss of reproductive effort is considered “taking” by the CDFW.

3.2.6 Nesting Birds
In California, protection is afforded to the nests and eggs of all birds. California Fish and Game Code (Section 3503) states that it is “unlawful to take, possess, or needlessly destroy the nest or eggs of any bird except as otherwise provided by this code or any regulation adopted pursuant thereto.” Breeding-season disturbance that causes nest abandonment and/or loss of reproductive effort is considered a form of “take” by the CDFW.

3.2.7 Habitat Conservation Plans and Natural Community Conservation Plans Section 10 of the federal Endangered Species Act establishes a process by which non-federal projects can obtain authorization to incidentally take listed species, provided take is minimized and thoroughly mitigated. A Habitat Conservation Plan (HCP), developed by the project applicant in collaboration with the USFWS and/or NMFS, ensures that such minimization and mitigation will occur, and is a prerequisite to the issuance of a federal incidental take permit. Similarly, a Natural Community Conservation Plan (NCCP), developed by the project applicant in collaboration with CDFW, provides for the conservation of biodiversity within a project area, and permits limited incidental take of state-listed species.

3.2.8 Wetlands and Other Jurisdictional Waters
Section 404 of the federal Clean Water Act (CWA) regulates the discharge of dredged or fill material into “navigable waters” (33 U.S.C. §1344), defined in the CWA as “the waters of the United States, including the territorial seas” (33 U.S.C. §1362(7)). The CWA does not supply a g’s
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24 definition for waters of the U.S., and that has been the subject of considerable debate since the CWA’s passage in 1972. A variety of regulatory definitions have been promulgated by the two federal agencies responsible for implementing the CWA, the Environmental Protection Agency (EPA) and USACE. These definitions have been interpreted, and in some cases, invalidated, by federal courts.

Waters of the U.S. are presently defined by the EPA and USACE’s joint 2023 Revised Definition of ‘Waters of the U.S.’ Rule (2023 WOTUS Rule), issued in January 2023 and amended in August 2023. Generally speaking, waters of the U.S. include:
• Waters which are currently used, or were used in the past, or may be susceptible to use in interstate or foreign commerce, including all waters which are subject to the ebb and flow of the tide
• The territorial seas
• Interstate waters
• Impoundments of waters otherwise defined as waters of the United States under the definition
• Tributaries to other waters of the U.S. that are relatively permanent, standing or continuously flowing bodies of water
• Wetlands adjacent to other waters of the U.S. that have a continuous surface connection to those waters
The 2023 WOTUS Rule also defines a number of exclusions from the definition of waters of the U.S., many of which are longstanding exclusions from earlier regulatory regimes. These generally include:
• Waste treatment systems
• Prior converted cropland
• Ditches excavated wholly in and draining only dry land that do not carry a relatively permanent flow of water
• Certain artificial features, e.g. irrigation basins, swimming pools, borrow pits, and artificially irrigated areas
• Swales and erosional features characterized by low volume, infrequent, or short duration flow
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25 All activities that involve the discharge of dredge or fill material into waters of the U.S. are subject to the permit requirements of the USACE. Such permits are typically issued on the condition that the applicant agrees to provide mitigation that result in no net loss of wetland functions or values.

Under the Porter-Cologne Water Quality Control Act of 1969, the State Water Resources Control Board (SWRCB) has regulatory authority to protect the water quality of all surface water and groundwater in the State of California (“waters of the State”). Nine RWQCBs oversee water quality at the local and regional level. The RWQCB for a given region regulates discharges of fill or pollutants into waters of the State through the issuance of various permits and orders.

Discharges into waters of the State that are also waters of the U.S. require a Section 401 Water Quality Certification from the RWQCB as a prerequisite to obtaining a Section 404 Clean Water Act permit. Discharges into waters of the State that are not also waters of the U.S. require Waste Discharge Requirements (WDRs), or waivers of WDRs, from the RWQCB.

The SWRCB and RWQCBs also administer the federal National Pollution Discharge Elimination System (NPDES) program, which is concerned with the discharge of stormwater and other pollutants into water bodies. Projects that disturb one or more acres of soil must obtain coverage under the SWRCB’s current NPDES Construction Stormwater General Permit. A prerequisite for permit coverage is the development of a Storm Water Pollution Prevention Plan (SWPPP) by a certified Qualified SWPPP Developer. Other types of pollutant discharges into waters of the U.S., such as wastewater, may require coverage under a different NPDES general permit, and in some cases an individual permit.

CDFW has jurisdiction over the bed and bank of natural drainages and lakes according to provisions of Section 1601 and 1602 of the California Fish and Game Code. Activities that may substantially modify such waters through the diversion or obstruction of their natural flow, change or use of any material from their bed or bank, or the deposition of debris require a Notification of Lake or Streambed Alteration. If CDFW determines that the activity may adversely affect fish and wildlife resources, a Lake or Streambed Alteration Agreement will be prepared. Such an agreement typically stipulates that certain measures will be implemented to protect the habitat values of the lake or drainage in question.
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26 4.0 IMPACTS AND MITIGATIONS
The following discussions address the potential impacts to biological resources associated with future residential buildout of Tract 6452. In the absence of a detailed site plan, it is assumed that the full 18 acres will be developed.

4.1 POTENTIALLY SIGNIFICANT PROJECT IMPACTS/MITIGATION

4.1.1 Potential Project Impacts to Nesting Birds and Raptors including the Swainson’s Hawk Potential Impacts. The project site has the potential to be used for nesting by several avian species that nest in ground vegetation or barren areas. Trees and shrubs are absent from the site itself but occur on nearby lands; these could support nesting by a wide variety of birds and raptors, possibly including the Swainson’s hawk (Buteo swainsoni), a California Threatened species. If birds or raptors are nesting on or near the site at the time of future residential buildout, individual birds could be killed or disturbed such that they would abandon their nests. Construction-related mortality of nesting birds and construction-related disturbance leading to nest abandonment are potentially significant impacts of the project. Moreover, such incidents would violate the Migratory Bird Treaty Act, California Fish and Game Code, and, in the case of the Swainson’s hawk, the California Endangered Species Act.

Swainson’s hawks are not expected to be adversely affected by project-related loss of habitat.

Residential buildout will eliminate approximately 18 acres of ruderal grassland that could potentially be used by foraging Swainson’s hawks. However, the site is located in the outskirts of Clovis, where Swainson’s hawks are uncommon, and use of this grassland would be infrequent, at best. Following project development, considerable alternative foraging habitat for this species will remain available in the larger project vicinity, including contiguous blocks of grassland habitat located approximately 0.6 mile to the east and 2 miles to the north of the site.

Mitigation. The following measures will be implemented for the protection of nesting birds and raptors including the state-threatened Swainson’s hawk.

Mitigation Measure 4.1.1a (Construction Timing). If feasible, future construction activities will take place entirely outside of the avian nesting season, typically defined as February 1 to August 31.
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27 Mitigation Measure 4.1.1b (Preconstruction Surveys). If construction must occur between February 1 and August 31, a qualified biologist will conduct surveys for active bird nests within 7 days prior to the start of work during this period. The survey area will encompass the site and accessible surrounding lands within ¼ mile for nesting Swainson’s hawks, 500 feet for other nesting raptors, and 250 feet for nesting birds.

Mitigation Measure 4.1.1c (Avoidance of Active Nests). Should any active nests be discovered in or near proposed construction zones, the biologist will identify a suitable construction-free buffer around the nest. This buffer will be identified on the ground with flagging or fencing, and will be maintained until the biologist has determined that the young have fledged and are capable of foraging independently.

Implementation of the above measures will reduce potential project impacts to nesting birds and raptors, including the state-threatened Swainson’s hawk, to a less than significant level under CEQA and ensure compliance with state and federal laws protecting these species.

4.2 LESS THAN SIGNIFICANT PROJECT IMPACTS

4.2.1 Potential Project Impacts to Special Status Plants Potential Impacts. Nineteen special status plant species have been documented in the general vicinity of the project site (see Table 1). All 19 species are considered absent from or unlikely to occur on the project site due to an absence of suitable habitat and/or soils, the site’s being situated outside of the species’ distribution, or a combination thereof (see Table 1). The project is not expected to adversely affect these species, either directly or indirectly, and impacts are considered less than significant under CEQA.

Mitigation. No mitigation is warranted.

4.2.2 Project Impacts to Special Status Animal Species Absent from or Unlikely to Occur on the Project Site
Potential Impacts. Twenty-three special status animal species have been documented in the general vicinity of the project site, or are known to occur regionally (Table 1). Of these, 17 are considered absent from or unlikely to occur on the site due to the absence of suitable habitat, the site’s urban setting and other landscape factors, and/or the site’s being situated outside of the species’ known distribution. These comprise the Crotch bumblebee (Bombus crotchii), valley elderberry longhorn beetle (Desmocerus californicus dimorphus), vernal pool fairy shrimp g’s
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28 (Branchinecta lynchi), vernal pool tadpole shrimp (Lepidurus packardi), California tiger salamander (Ambystoma californiense), western yellow-billed cuckoo (Coccyzus americanus occidentalis), least Bell’s vireo (Vireo bellii pusillus), Fresno kangaroo rat (Dipodomys nitratoides exilis), San Joaquin kit fox (Vulpes macrotis mutica), hardhead (Mylopharadon conocephalus), western spadefoot (Spea hammondii), western pond turtle (Actinemys marmorata), northern California legless lizard (Anniella pulchra), coast horned lizard (Phrynosoma blainvillii), California glossy snake (Arizona elegans occidentalis), burrowing owl (Athene cunicularia), and American badger (Taxidea taxus). Because these species have no appreciable potential to occur on site, they are not expected to be affected by the project, directly or indirectly. Project impacts are considered less than significant under CEQA.

Mitigation. Mitigation measures are not warranted.

4.2.3 Project Impacts to Special Status Animal Species that Would Use the Site for Foraging Only
Potential Impacts. Five special status animal species, the golden eagle (Aquila chrysaetos), tricolored blackbird (Agelaius tricolor), pallid bat (Antrozous pallidus), spotted bat (Euderma maculatum), and western mastiff bat (Eumops perotis ssp. californicus), have the potential to forage on the site from time to time but would not nest or roost on or near enough to the site that they could be vulnerable to construction-related injury, mortality, or reproductive failure (see Table 1). Individuals of these species are unlikely to be injured or killed by construction activities because they are highly mobile while foraging and would be expected to simply avoid active work areas.

The project would not adversely affect any of these species through loss of foraging habitat. The site does not offer unique habitat for any of these species, nor is it likely to represent an important part of any individual foraging range, given its disturbed nature and urban setting. Similar and higher quality habitats, including contiguous blocks of grassland habitat located approximately 0.6 mile to the east and 2 miles to the north of the site, are regionally abundant. For these reasons, impacts to the golden eagle, tricolored blackbird, pallid bat, spotted bat, and western mastiff bat are considered less than significant under CEQA.
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29 Mitigation. Mitigation is not warranted.

4.2.4 Project Impacts to Wildlife Movement Corridors
Potential Impacts. The project site does not contain or adjoin features likely to function as a wildlife movement corridor. No impacts to such corridors are anticipated.

Mitigation. Mitigation is not warranted.

4.2.5 Project Impacts to Sensitive Natural Communities and Critical Habitat Potential Impacts. The project site does not contain or adjoin any sensitive natural communities or designated critical habitat. There will be no impact to such resources.

Mitigation. Mitigation is not warranted.

4.2.6 Project Impacts to Jurisdictional Waters
Potential Impacts. The project site does not contain any aquatic features. No impacts to jurisdictional waters are anticipated.

Mitigation. Mitigation is not warranted.

4.2.7 Consistency with Local Policies and Ordinances
Potential Impacts. The project appears consistent with Clovis and Fresno County General Plan policies related to biological resources.

Mitigation. Mitigation measures are not warranted.

4.2.8 Consistency with Habitat Conservation Plans and Natural Community Conservation Plans
Potential Impacts. There are no known HCPs or NCCPs in effect for the project vicinity.

Mitigation. Mitigation measures are not warranted.
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30 5.0 LITERATURE REFERENCED
Baldwin, B.G., D.H. Goldman, D.J. Keil, R. Patterson, T.J. Rosatti, and D. G. Wilken, editors. 2012. The Jepson Manual: Vascular Plants of California, second edition. University of California Press, Berkeley.

Baumberger, K. L., M. V. Eitzel, M. E. Kirby, and M. H. Horn. 2019. Movement and habitat selection of the western spadefoot (Spea hammondii) in southern California. PLoS ONE 14(10): e0222532. Available at: https://doi.org/10.1371/journal.pone.0222532 Calflora. 2023. Calflora: An online database of plant identification and distribution [web application]. Calflora, Berkeley, California. Available online at: http://www.calflora.org.

California Department of Fish and Wildlife (CDFW). 2023. California Natural Diversity Database.

The Resources Agency, Sacramento, CA.

California Herps. 2023. Available online at: https://californiaherps.com/ California Native Plant Society. 2023. Inventory of Rare and Endangered Vascular Plants of California. Available online at: http://cnps.site.aplus.net/cgi-bin/inv/inventory.cgi. eBird. 2023. eBird: An online database of bird distribution and abundance [web application]. eBird, Cornell Lab of Ornithology, Ithaca, New York. Available: http://www.ebird.org.

Natural Resources Conservation Service (NRCS). 2023. Soil Survey Staff, Natural Resources Conservation Service, United States Department of Agriculture. Web Soil Survey.

Available online at: https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx.

NRCS. 2011. National Hydric Soils List by State, California. U.S. Department of Agriculture.

State Water Resources Control Board (SWRCB). 2019. State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State. Adopted April 2, 2019.

U.S. Army Corps of Engineers (USACE). 1987. Corps of Engineers wetlands delineation manual.

Department of the Army.

Zeiner, David C., William F. Laudenslayer, Kenneth E. Mayer and Marshal White. Ed. 1988.

California’s wildlife, volume I, amphibians and reptiles, volume II, birds, and volume III, mammals. Department of Fish and Game. Sacramento, CA. (Online:
http://www.dfg.ca.gov/biogeodata/cwhr/cawildlife.aspx). g’s
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31 APPENDIX A: VASCULAR PLANT LIST
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32 APPENDIX A

VASCULAR PLANTS OF THE PROJECT SITE
The plants species listed below were observed on the project site during LOA’s September 25, 2023 surveys. The U.S. Fish and Wildlife Service wetland indicator status of each plant, if available, has been shown following its common name.

OBL - Obligate
FACW - Facultative Wetland
FAC - Facultative
FACU - Facultative Upland
UPL - Upland
AMARANTHACEAE – Amaranth Family
Amaranthus albus Pigweed Amaranth FACU
Amaranthus blitoides Prostrate Pigweed FACU
ASTERACEAE – Sunflower Family
Centaurea solstitialis Yellow Starthistle UPL
Centromadia pungens Common Tarweed FAC
Erigeron bonariensis Flax-leaved Horseweed FACU
Helianthus annuus Common Sunflower FACU
Heterotheca grandiflora Telegraph Weed UPL
Lactuca serriola Prickly Lettuce FACU
BORAGINACEAE- Borage Family
Amsinckia sp. Fiddleneck UPL
BRASSICACEAE – Mustard Family
Hirschfeldia incana Mustard UPL
CHENOPODIACEAE – Goosefoot Family
Chenopodium album Lambs Quarters FACU
CONVOLVULACEAE – Morning Glory Family
Convolvulus arvensis Field Bindweed UPL
EUPHORBIACEAE – Spurge Family
Croton setiger Turkey Mullein UPL
FABACEAE – Legume Family
Acmispon americanus Spanish Clover UPL
Trifolium hirtum Rose Clover UPL
GERANIACEAE – Geranium Family
Erodium cicutarium Redstem Filaree UPL
LAMIACEAE – Mint Family
Trichostema lanceolatum Vinegarweed FACU
ONAGRACEAE – Evening-Primrose Family
Epilobium brachycarpum Willow Herb FAC
POACEAE – Grass Family
Avena sp. Wild Oats UPL
Bromus diandrus Ripgut Brome UPL
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33 Bromus hordeaceus Soft Chess FACU
Cynodon dactylon Bermuda Grass FAC
Festuca myuros Rattail Sixweeks Grass UPL
Hordeum murinum Foxtail Barley FACU
POLYGONACEAE – Smartweed Family
Polygonum aviculare Prostrate Knotweed FAC
Rumex crispus Curly Dock FAC
SOLANACEAE – Nightshade Family
Datura wrightii Jimson Weed UPL
ZYGOPHYLLACEAE – Puncture Vine Family
Tribulus terrestris Puncture Vine UPL
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34 APPENDIX B: TERRESTRIAL VERTEBRATE SPECIES THAT POTENTIALLY

OCCUR ON THE PROJECT SITE
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35 APPENDIX B

TERRESTRIAL VERTEBRATE SPECIES THAT POTENTIALLY OCCUR

ON THE PROJECT SITE
The species listed below are those that may be expected to routinely and predictably use or pass through the project site during some or all of the year. An asterisk denotes a species observed on or immediately adjacent to the site during surveys conducted for the current project by LOA on September 25, 2023.

CLASS: AMPHIBIA
ORDER: ANURA (Frogs and Toads)
FAMILY: BUFONIDAE (True Toads)
Western Toad (Bufo boreas)
FAMILY: HYLIDAE (Treefrogs and Relatives)
Pacific Tree Frog (Pseudacris regilla)
FAMILY: RANIDAE (True Frogs)
American Bullfrog (Lithobates catesbeianus)
CLASS: REPTILIA
ORDER: SQUAMATA (Lizards and Snakes)
SUBORDER: SAURIA (Lizards)
FAMILY: PHRYNOSOMATIDAE
Side-blotched Lizard (Uta stansburiana)
Western Fence Lizard (Sceloporus occidentalis)
FAMILY: TEIIDAE (Whiptails and relatives)
Western Whiptail (Cnemidophorus tigris)
SUBORDER: SERPENTES (Snakes)
FAMILY: COLUBRIDAE (Colubrids)
Pacific Gopher Snake (Pituophis catenifer catenifer)
Common Kingsnake (Lampropeltis californiae)
FAMILY: VIPERIDAE (Vipers)
Western Rattlesnake (Crotalus viridis)
CLASS: AVES
ORDER: CICONIIFORMES (Herons, Storks, Ibises and Relatives) FAMILY: ARDEIDAE (Bitterns, Herons, and Egrets)
Great Blue Heron (Ardea herodias)
Great Egret (Ardea alba)
FAMILY: CATHARTIDAE (New World Vultures)
Turkey Vulture (Cathartes aura)
ORDER: FALCONIFORMES (Vultures, Hawks, and Falcons)
FAMILY: ACCIPITRIDAE (Hawks, Old World Vultures, and Harriers) *Red-tailed Hawk (Buteo jamaicensis)
FAMILY: FALCONIDAE (Caracaras and Falcons)
*American Kestrel (Falco sparverius)
ORDER: GALLIFORMES (Megapodes, Currassows, Pheasants, and Relatives) FAMILY: ODONTOPHORIDAE (New World Quails)
California Quail (Callipepla californica)
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36 ORDER: CHARADRIIFORMES (Shorebirds, Gulls, and relatives) FAMILY: CHARADRIIDAE (Plovers and relatives)
Killdeer (Charadrius vociferus)
ORDER: COLUMBIFORMES (Pigeons and Doves)
FAMILY: COLUMBIDAE (Pigeons and Doves)
Rock Pigeon (Columba livia)
Mourning Dove (Zenaida macroura)
Eurasian Collared Dove (Streptopelia decaocto)
ORDER: STRIGIFORMES (Owls)
FAMILY: TYTONIDAE (Barn Owls)
Barn Owl (Tyto alba)
ORDER: APODIFORMES (Swifts and Hummingbirds)
FAMILY: TROCHILIDAE (Hummingbirds)
Black-chinned Hummingbird (Archilochus alexandri)
Anna’s Hummingbird (Calypte anna)
ORDER: PASSERIFORMES (Perching Birds)
FAMILY: TYRANNIDAE (Tyrant Flycatchers)
Black Phoebe (Sayornis nigricans)
Say’s Phoebe (Sayornis saya)
Western Kingbird (Tyrannus verticalis)
FAMILY: CORVIDAE (Jays, Magpies, and Crows)
American Crow (Corvus brachyrhynchos)
Common Raven (Corvus corax)
FAMILY: ALAUDIDAE (Larks)
Horned Lark (Eremophila alpestris)
FAMILY: HIRUNDINIDAE (Swallows)
Cliff Swallow (Petrochelidon pyrrhonota)
Barn Swallow (Hirundo rustica)
Northern Rough-winged Swallow (Stelgidopteryx serripennis) FAMILY: AEGITHALIDAE (Bushtits)
Bushtit (Psaltriparus minimus)
FAMILY: TURDIDAE (Thrushes)
Western Bluebird (Sialia mexicana)
American Robin (Turdus migratorius)
FAMILY: MIMIDAE (Mockingbirds and Thrashers)
Northern Mockingbird (Mimus polyglottos)
FAMILY: STURNIDAE (Starlings and Allies)
European Starling (Sturnus vulgaris)
FAMILY: MOTACILLIDAE (Wagtails and Pipits)
American Pipit (Anthus rubrescens)
FAMILY: EMBERIZIDAE (Sparrows)
*Savannah Sparrow (Passerculus sandwichensis)
White-crowned Sparrow (Zonotrichia leucophrys)
Golden-crowned Sparrow (Zonotrichia atricapilla)
FAMILY: ICTERIDAE (Blackbirds, Orioles and Allies)
*Western Meadowlark (Sturnella neglecta)
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37 Red-winged Blackbird (Agelaius phoeniceus)
Great-tailed Grackle (Quiscalus mexicanus)
Brewer's Blackbird (Euphagus cyanocephalus)
Brown-headed Cowbird (Molothrus ater)
FAMILY: FRINGILLIDAE (Finches)
House Finch (Carpodacus mexicanus)
Lesser Goldfinch (Carduelis psaltria)
FAMILY: PASSERIDAE (Old World Sparrows)
House Sparrow (Passer domesticus)
CLASS: MAMMALIA
ORDER: DIDELPHIMORPHIA (Marsupials)
FAMILY: DIDELPHIDAE (Opossums)
Virginia Opossum (Didelphis virginiana)
ORDER: INSECTIVORA (Shrews and Moles)
FAMILY: TALPIDAE (Moles)
Broad-footed Mole (Scapanus latimanus)
ORDER: CHIROPTERA (Bats)
FAMILY: VESPERTILIONIDAE (Vespertilionid Bats)
Yuma Myotis (Myotis yumanensis)
California Myotis (Myotis californicus)
Western Pipistrelle (Pipistrellus hesperus)
Big Brown Bat (Eptesicus fuscus)
Pale Big-eared Bat (Corynorhinus townsendii pallescens) FAMILY: MOLOSSIDAE (Free-tailed Bat)
Brazilian Free-tailed Bat (Tadarida brasiliensis)
ORDER: LAGOMORPHA (Rabbits, Hares, and Pikas)
FAMILY: LEPORIDAE (Rabbits and Hares)
Audubon’s Cottontail (Sylvilagus audubonii)
Black-tailed Jackrabbit (Lepus californicus)
ORDER: RODENTIA (Rodents)
FAMILY: SCIURIDAE (Squirrels, Chipmunks, and Marmots)
California Ground Squirrel (Otospermophilus beecheyi)
FAMILY: GEOMYIDAE (Pocket Gophers)
*Botta’s Pocket Gopher (Thomomys bottae)
FAMILY: MURIDAE (Mice, Rats and Voles)
Western Harvest Mouse (Reithrodontomys megalotis)
Deer Mouse (Peromyscus maniculatus)
Norway Rat (Rattus norvegicus)
House Mouse (Mus musculus)
California Vole (Microtus californicus)
FAMILY: HETEROMYIDAE (Kangaroo Rats)
Heermann’s Kangaroo Rat (Dipodomys heermanni)
ORDER: CARNIVORA (Carnivores)
FAMILY: CANIDAE (Foxes, Wolves, and Relatives)
Red Fox (Vulpes vulpes)
Coyote (Canis latrans)
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38 Domestic Dog (Canis familiaris)
FAMILY: PROCYONIDAE (Raccoons and Relatives)
Raccoon (Procyon lotor)
FAMILY: MUSTELIDAE (Weasels and Relatives)
Striped Skunk (Mephitis mephitis)
FAMILY: FELIDAE (Cats)
Feral Cat (Felis catus)
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39 APPENDIX C: REPRESENTATIVE PHOTOS OF THE PROJECT SITE g’s
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40 Photos 1 (above) and 2 (below). The project site’s ruderal grassland habitat. Both photos were taken in the southern portion of the site; Photo 2 faces south toward the adjoining Lennar Homes Tract 6200 project, which was under construction at the time of LOA’s survey. g’s
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AGENDA ITEM NO. 13.
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AGENDA ITEM NO. 13.
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AGENDA ITEM NO. 13.

USGS Friant, CA and Clovis, CA 7.5′ quadrangles, T12S, R21E, Sec. 20

18.2 acres surveyed
Resources: None
Cultural Resource Study for the
Clovis Tract 6452 Residential Development,
City of Clovis, Fresno County, California
Nicole Saenz
Prepared By
Applied EarthWorks, Inc.
1391 W. Shaw Ave., Suite C
Fresno, CA 93711
Prepared For
Lennar Central Valley
8080 N. Palm Ave., Suite 110
Fresno, CA 93711
November 2023
Appendix C
829
AGENDA ITEM NO. 13.

Cultural Resource Study for the Clovis Tract 6452 Residential Development ii

MANAGEMENT SUMMARY
Applied EarthWorks, Inc. (Æ) conducted a cultural resource inventory for Lennar Central Valley’s proposed 18.2-acre Tract 6452 Residential Development Project (Project) in the city of Clovis within Fresno County, California. The Project is north of Perrin Road, between Clovis Avenue and North Sunnyside Avenue.

The proposed development will require a permit issued by the City of Clovis. Therefore, the Project is subject to the California Environmental Quality Act (CEQA), which mandates that public agencies determine whether a proposed project will cause a significant change to the environment, including cultural resources. To assist Lennar Central Valley in fulfilling their responsibility under CEQA, Ӕ conducted a cultural resource study to identify whether there are potential historical resources (i.e., cultural resources listed or eligible for listing in the California Register [CRHR]) within the Project area.

To meet the requirements under CEQA, Æ conducted: (1) a records search at the Southern San Joaquin Valley Information Center (SSJVIC) of the California Historical Resources Information System (CHRIS); (2) desktop research to better understand the history of land use in the Project area; (3) a search of the Native American Heritage Commission’s (NAHC) Sacred Lands File, and nongovernmental outreach to local tribes and individuals; and (4) an intensive pedestrian survey of the 18.2-acre Project area to identify archaeological and/or historical built environment cultural resources.

The SSJVIC records search identified no cultural resources within the Project area and only one cultural resource—the Enterprise Canal (P-10-005934/CA-FRE-3564H)—which runs southwest of the Project area. There have been four previous cultural resource investigations that overlap the Project area and one within the 0.25-mile search radius. A search of the NAHC’s Sacred Land File did not identify Native American cultural resources within or near the Project area, and no specific information was gleaned from outreach with local tribal representatives.

Ӕ’s intensive pedestrian survey of the Project area, conducted on August 23, 2023, covered the entirety of the 18.2-acre Project area. No cultural resources were identified in the Project area.

Ӕ’s inventory efforts found no historical resources within the Project area. However, if cultural resources are discovered during Project activities, all work should halt until a qualified archaeologist can assess the find. Additionally, if human remains are uncovered during construction, the Project operator shall immediately halt work within 50 feet of the find, contact the Fresno County Coroner to evaluate the remains, and follow the procedures and protocols set forth in CEQA Guidelines Section 15064.4(e)(1). If the remains are identified on the basis of archaeological context, age, cultural associations, or biological traits to be those of a Native American, then the California Health and Safety Code 7050.5 and Public Resource Code 5097.98 require that the county coroner notify the NAHC within 24 hours of discovery.

The NAHC will then identify the Most Likely Descendant, who will be afforded the opportunity to recommend treatment of the human remains following protocols in California Public Resources Code 5097.98.
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AGENDA ITEM NO. 13.

Cultural Resource Study for the Clovis Tract 6452 Residential Development iii Field notes and photographs for this Project are on file at Æ’s office in Fresno, California. A copy of this report will be transmitted to the SSJVIC at California State University, Bakersfield, for inclusion in the CHRIS.
831
AGENDA ITEM NO. 13.

Cultural Resource Study for the Clovis Tract 6452 Residential Development iv

CONTENTS
1 INTRODUCTION..............................................................................................................1

1.1 PROJECT DESCRIPTION......................................................................................1

1.2 REGULATORY CONTEXT...................................................................................1

1.3 PROJECT PERSONNEL.........................................................................................5

1.4 REPORT ORGANIZATION...................................................................................5 2 NATURAL AND CULTURAL SETTING......................................................................6

2.1 PHYSICAL ENVIRONMENT................................................................................6

2.2 PREHISTORY AND ARCHAEOLOGY................................................................6

2.3 ETHNOGRAPHY....................................................................................................8

2.4 HISTORIC CONTEXT ...........................................................................................9

2.4.1 Early Settlement in the Clovis Area (1853–1874).......................................9

2.4.2 Initial Development of Agriculture in the Fresno-Clovis Area (1875–1900)...............................................................................................10

2.4.3 Diversification and Water Issues (1900–1950)..........................................12

2.4.4 Modern Water Management (1950–Present).............................................13 3 METHODS.......................................................................................................................14

3.1 RECORDS SEARCH ............................................................................................14

3.2 BACKGROUND RESEARCH .............................................................................14

3.3 NATIVE AMERICAN OUTREACH....................................................................14

3.4 PEDESTRIAN SURVEY......................................................................................15 4 FINDINGS........................................................................................................................16

4.1 RECORDS SEARCH ............................................................................................16

4.1.1 Previous Studies.........................................................................................16

4.1.2 Previously Recorded Resources.................................................................16

4.2 BACKGROUND RESEARCH .............................................................................17

4.3 NATIVE AMERICAN OUTREACH....................................................................17

4.4 PEDESTRIAN SURVEY......................................................................................19 5 CONCLUSIONS AND RECOMMENDATIONS.........................................................21

5.1 RECOMMENDATIONS.......................................................................................21

5.1.1 Inadvertent Discovery of Archaeological Resources.................................21

5.1.2 Inadvertent Discovery of Human Remains................................................22 6 REFERENCES.................................................................................................................23

APPENDICES
A Personnel Qualifications
B Records Search Results
C Native American Outreach
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AGENDA ITEM NO. 13.

Cultural Resource Study for the Clovis Tract 6452 Residential Development v

FIGURES AND TABLES
Figure 1-1 Project vicinity in Fresno County, California..........................................................2 Figure 1-2 Project location on USGS Clovis and Friant 7.5-minute topographic quadrangles. ...................................................................................3 Figure 1-3 Aerial view of the Project area.................................................................................4 Figure 4-1 1856 GLO map showing transport routes and Big Dry Creek...............................17 Figure 4-2 Cleared and sparsely vegetated ground surface with high visibility; facing northeast................................................................................................19 Figure 4-3 Waist-high grass and star thistle with zero percent ground visibility; facing west.......................................................................................20 Table 4-1 Previous Studies in the Project Area and Surrounding 0.25-Mile Radius ..............................................................................................................16 833
AGENDA ITEM NO. 13.

Cultural Resource Study for the Clovis Tract 6452 Residential Development 1 1 INTRODUCTION
Applied EarthWorks, Inc. (Ӕ) prepared this cultural resource study in support of Lennar Central Valley’s proposed Tract 6452 Residential Development Project (Project) in the city of Clovis, Fresno County, California (Figure 1-1). The property is directly north of Perrin Road between Clovis Avenue and North Sunnyside Avenue, within Section 20 of Township 12 South, Range 21 East, as depicted on the U.S. Geological Survey (USGS) Clovis (1981), California

7.5-minute topographic quadrangle (Figure 1-2).

1.1 PROJECT DESCRIPTION
Lennar Central Valley proposes to construct 153 single-family lots on 18.2 acres of vacant land between Clovis Avenue and North Sunnyside Avenue in the city of Clovis (Figure 1-3). The proposed zoning for the Project will be M/L – Medium and Low Density Residential, while the current Fresno County zoning is AE-20. The property is currently in the County of Fresno, though it will be annexed to the City of Clovis (City). This residential development will be within the City of Clovis (City) Heritage Grove Master Plan and will be subject to design development standards of the plan.

1.2 REGULATORY CONTEXT
The Project is subject to the California Environmental Quality Act (CEQA), with guidelines for implementation codified in the California Code of Regulations (CCR), Title 14, Chapter 3, Section 15000 et seq. Historical resources are considered part of the environment and are subject to review under CEQA. Per CEQA, the lead agency, in this case the City, is required to determine whether a project may have a significant effect on historical resources, and therefore cause a significant effect on the environment (Public Resources Code [PRC] Section 5024.1[b]).

CEQA defines a substantial adverse change to a historical resource as the “physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of a historical resource would be materially impaired” (14 CCR Section 15064.5[b][1]). Where substantial adverse change is unavoidable and the historical resource cannot be preserved in an undisturbed state, the lead agency shall require mitigation measures to minimize substantial adverse changes to the resource’s significance (PRC Section 21083.2[c]). It is further stipulated that the “lead agency shall ensure that any adopted measures to mitigate or avoid significant adverse changes are fully enforceable through permit conditions, agreements, or other measures” (14 CCR Section 15064.5[b][4]; PRC Section 5020.1[q]).

For the purposes of this report, a cultural resource is defined as a prehistoric or historic-era archaeological site or a historic-era building, structure, or object. The importance or significance of a cultural resource depends on whether it qualifies for inclusion in the California Register of Historical Resources (CRHR). Cultural resources determined eligible for listing in the CRHR are called “historical resources.” (Title 14, Chapter 3, Article 5, Section 15064.5 of the CCR). The determination of eligibility is based on a set of significance criteria (14 CCR 15064.5). 834
AGENDA ITEM NO. 13.

Cultural Resource Study for the Clovis Tract 6452 Residential Development 2 Figure 1-1 Project vicinity in Fresno County, California.

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AGENDA ITEM NO. 13.

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AGENDA ITEM NO. 13.

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AGENDA ITEM NO. 13.

Cultural Resource Study for the Clovis Tract 6452 Residential Development 5

1.3 PROJECT PERSONNEL
Æ Managing Principal Archaeologist Erin Enright (M.A. Registered Professional Archaeologist [RPA] 16575) served as principal investigator for the project. Æ Principal Archaeologist Anna Hoover (M.S., RPA 28576661) served as project manager, overseeing the study efforts and technical reporting. Field Technician Charles Pansarosa (B.A.) conducted the pedestrian survey.

This report was prepared by Staff Anthropologist Nicole Saenz (M.S.) and Principal Archaeologist Emerita Mary Baloian (Ph.D., RPA 15189) reviewed the report for technical accuracy. Résumés for key personnel are provided in Appendix A.

1.4 REPORT ORGANIZATION
This document consists of six chapters. Following this introduction, Chapter 2 describes the environmental and cultural context of the Project area. Chapter 3 presents Ӕ’s methods for the study, including the records search, background research, Native American outreach, and pedestrian surveys, while Chapter 4 discusses the study results. Chapter 5 contains a summary and provides recommendations. A complete listing of references cited is in Chapter 6.

Appendix A contains résumés of Project personnel. Appendix B presents results of the records search, and Appendix C contains documentation of communication with the NAHC and local tribal representatives.

Field notes, maps, and a complete set of photographs from the current investigation are on file at Æ’s office in Fresno, California. A copy of the final version of this report will be submitted to the SSJVIC at California State University, Bakersfield. 838
AGENDA ITEM NO. 13.

Cultural Resource Study for the Clovis Tract 6452 Residential Development 6 2 NATURAL AND CULTURAL SETTING

2.1 PHYSICAL ENVIRONMENT
The Project area lies on the eastern margin of the San Joaquin Valley near the base of the Sierra Nevada foothills. In general, the valley is bordered on the east by the Sierra Nevada, on the west by the Coast Ranges, and on the south by the Tehachapi Range. The north-south orientation of the Sierra Nevada greatly influences the general hydrology of the region by directing the flow of rivers and streams westward into the San Joaquin Valley.

The complex geology of the adjacent foothills and the Sierra Nevada is reflected in the primary and secondary soils in the valley. Primary soils are developed by weathering the underlying granitic parent material. Secondary soils are formed by a combination of eolian and alluvial forces transporting a variety of granitic and assorted metamorphic and metavolcanic materials from mountain streams (Weir 1956). Quaternary and recent alluvium covers most of the valley basin.

The natural vegetation of the San Joaquin Valley has been severely compromised as a result of farming and ranching. Originally, the area was covered with native annual and perennial grasses such as needlegrass (Stipa spp.), bluegrass (Poa spp.), and three awn (Aristida divaricata) commonly found in the Valley Grassland Community (Munz and Keck 1973). Prior to EuroAmerican colonization, the valley floor was occupied by a diverse population of resident and migratory mammals and birds, which along with fish and other aquatic species provided a rich resource base for aboriginal subsistence. Historical and modern land use has greatly reduced the size and number of native habitats, eliminating numerous indigenous species. Most commonly found in the study vicinity today are jackrabbits, ground squirrels, field mice, snakes, and frogs, along with jays, mourning doves, crows, and red-tailed hawks.

The San Joaquin Valley lies within the Mediterranean climate zone typified by hot, dry summers and cool, wet winters. Temperatures range from highs of 90–100°F in the summer months to lows of 40–50°F in the winter (Weir 1956), although temperatures exceeding 100°F in the summer and dropping below freezing in the winter are not uncommon. Annual precipitation averages 10 inches per year, with most of the rain falling between October and March. Thick “tule” fog is common in the valley during December and January.

The natural topography of the proposed development is flat at 400 feet above mean sea level.

The natural watercourse closest to the Project area is Dry Creek, which flows directly southeast of the Project area.

2.2 PREHISTORY AND ARCHAEOLOGY
Archaeological evidence suggests that the valley’s initial occupants settled mostly in lakeshore and streamside environments and used the foothills seasonally. Early (“Paleoindian”) sites are typified by fluted points, stemmed dart points, scrapers, and flaked stone crescents. The middle and late Holocene witnessed mobile hunters and gatherers. As compared with their predecessors, 839
AGENDA ITEM NO. 13.

Cultural Resource Study for the Clovis Tract 6452 Residential Development 7 Archaic groups utilized a broad resource base, including both large and small game and hard seeds. Manos, milling slabs, mortars, and pestles are common in Archaic assemblages, as are atlatl dart points. Favorable climatic conditions between 3,000 and 3,500 years ago fostered widespread settlement along the Sierran west slope. The late Holocene witnessed various technological and social changes, including the adoption of the bow and arrow, expansion of trade, increasing use of acorns, and improved food storage techniques. As populations grew, social relations became more complex. Economic stress and social instability became more pronounced during a period of xeric climates between circa A.D. 450 and 1250. Thereafter, new levels of population growth were achieved, resulting in part from movement of new Sierran groups. By circa A.D. 1600–1700, most groups claimed the territories that would identify them ethnographically. The Project lies in the territory of the Gashowu, a tribelet of the Foothill Yokuts (see Section 3.3).

A number of prehistoric sites have been identified in Gashowu territory (Price 1992). Located in the foothills northeast of Clovis, these sites are primarily either extensive midden deposits found along both small ephemeral drainages and larger permanent watercourses or multiple bedrock milling features, sometimes with numerous individual stations.

Investigations at CAFRE1671, which may have formed the core of the Pohoniu village community, yielded radiocarbon dates showing that Yokuts settlement of the area extended from A.D. 1300 well into the historic period. An earlier occupation phase at the site was dated between circa 700 B.C. and A.D. 300 but could not be linked directly to the Gashowu or any other Yokuts group (Moratto 1988).

At CAFRE64, investigations showed that the Yokuts may have occupied the area as early as A.D. 1100–1200, with continuing occupation to around A.D. 1600. An even earlier component lacked the data to attribute it to the Gashowu but suggested that the steatite industry in the area may have begun as early as A.D. 800 (Wallace et al. 1989).

CAFRE1154 and 1155 are in the foothills east of the Project area. CAFRE1154, the Sharer Site, lies “along an abandoned oxbow bend associated with a channelized-stream”(Langenwalter et al. 1989). This site, interpreted as a seasonal procurement campsite, appears to have been used during a long temporal span from 850 B.C. to A.D. 1850. It consists of a midden ranging from 60 to 160 centimeters deep and a large bedrock boulder containing 76 mortars, cups, cupules, and slicks. Artifacts included ground and flaked stone tools, steatite bowl fragments, ornaments, crystals, daub, and ochre. Additionally, the remains of a juvenile burial were encountered.

CAFRE1155, the Harlan Site, contains a small but well-developed midden with thickness varying between 80 and 190 centimeters as well as five bedrock features. Artifacts similar to those from CAFRE1154 indicate that CAFRE1155 was used as a seasonal procurement site.

It appears to have been sporadically occupied between 850 B.C. and A.D. 300, with intensive occupation from A.D. 300 to 1500 (Langenwalter et al. 1989).

Surveys east of the current Project area have shown that many small processing stations and temporary camps occur along seasonal channels near the lower foothills (Meighan and Dillon 1987), suggesting a pattern of widespread but relatively ephemeral use of the area during the late Holocene (McGuire 1992).
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AGENDA ITEM NO. 13.

Cultural Resource Study for the Clovis Tract 6452 Residential Development 8 In the first half of the nineteenth century, the Gashowu population was decimated by disease, missionization, and military action. This led to a radical change in settlement: the surviving peoples abandoned the residential sites that they had occupied prehistorically and congregated at a small number of locations. Glass trade beads and other historical artifacts recovered from CA-FRE-687 and CAFRE1671 may be evidence of these postcontact settlements (Price 1992:32–33).

2.3 ETHNOGRAPHY
At the time of first contact with the Spanish missionaries, the Yokuts people collectively inhabited the San Joaquin Valley, as well as the eastern foothills of the Sierra Nevada from the Calaveras River southward to the Kern River. The Yokuts language belongs to the broader Penutian family, which subsumes a relatively diverse assemblage of languages that also includes Miwok, Costanoan, Maiduan, and Wintuan (Silverstein 1978). Compared to other Penutian languages, however, Yokuts shows considerable internal linguistic homogeneity, especially given its relatively wide geographic distribution. Dialects differed minimally and were mutually intelligible, at least among speakers of contiguous groups. This relative lack of linguistic differentiation suggests that ancestors of the Yokuts entered California after the arrival and subsequent radiation of the more linguistically diverse Penutian groups such as the Miwok and Costanoan (Moratto 1984:554).

Linguists and ethnographers have traditionally divided the Yokuts into Northern Valley, Southern Valley, and Foothill categories based primarily on linguistic similarities and differences. Yet such broad groupings were not mirrored in the larger structure of Yokuts society. Instead, the Yokuts were organized into relatively small autonomous tribes or tribelets, which maintained a fluid territory containing multiple semipermanent settlements.

Gayton (1945, 1948), Kroeber (1976), Spier (1978), and Wallace (1978, 1987) have produced primary source material on Yokuts ethnography. Secondary works on this subject include those authored by Langenwalter et al. (1989) Moratto (1984, 1988), and Wallace et al. (1989). The following discussion about Yokuts lifeways is drawn from these sources.

The Project area lies within the territory of the Gashowu, a tribelet of the Kings River Group of the Foothill Division; that occupied the drainages of Big Dry Creek and Little Dry Creek. Two major settlements are attributed to the Gashowu: Pohoniu, below Letcher on Big Dry Creek, and Yokau, on Little Dry Creek in Auberry Valley(Kroeber 1976:481, plate 47). These villages appear to have been central year-round settlements that were occupied more densely in the winter. At these locations, the Gashowu built conical structures 15–20 feet tall over excavated pits, each with a central rock-lined hearth. Other structures probably included acorn granaries, sweat houses, roofed ramadas, sunshades, and large communal houses. During the summer, residents moved with extended families or family groups to base camps within a day’s walk of the central village. These stations served as summer villages and temporary storage places for food until it was transferred to the main village. Summer villages contained smaller structures and are most commonly recognized archaeologically by midden deposits and multiple bedrock milling features. Seed-gathering forays in the spring or summer expanded the Gashowu range to the lowlands of present-day Clovis and Fresno.
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Cultural Resource Study for the Clovis Tract 6452 Residential Development 9 Acorns were a Gashowu staple, with additional nutrition culled from other nuts and seeds, berries, fruit, and game. These dietary items as well as tool stone and a variety of other resources were gathered at summer camps. Procurement loci survive today as scatters of lithic artifacts and as bedrock milling stations where plants and seeds were processed. In addition to these features, artifacts used to process procured resources (such as mortars, pestles, and manos) and the remains of resources gathered (such as bone and acorn shell) also may be found.

Steatite is available locally, and items made from this material (including cooking bowls, beads, and ornaments) are often found at Yokuts sites. Steatite goods also were traded with neighbors for obsidian, pine nuts, shell beads and ornaments, and other exotic commodities.

2.4 HISTORIC CONTEXT

2.4.1 Early Settlement in the Clovis Area (1853–1874)
The first Euro-American settlements in the greater Clovis area occurred not within the swampy “hog wallows” that once dotted the landscape of the present city limits but in the grassy plains around Dry Creek where the stream flows down from the foothills into the valley (Clough and Secrest 1984). A small outpost was established at the current intersection of Shepherd and Thompson avenues in 1853 and later became a stop along the Stockton to Los Angeles stage route (Smith 1991). For many years the lonely station, which eventually became known as Collins Corner, stood by itself with no other buildings in sight. After the Civil War, sheepherders, many from the southern United States, began to trickle into the area.

During the 1860s, homesteaders came to the valley to graze their herds or flocks in the pastures around the San Joaquin River and its drainages. The local cattle industry continued to grow until at least 1870, when, according to Vandor (1919), it reached its peak. There were, however, some bumps along the way. The erratic climate patterns of the 1860s—a decade that experienced alternating periods of severe flooding and drought—had considerable impact on the makeup of the Central Valley’s agrarian base. In particular, the 2-year-long drought that followed the great flood of 1862 decimated remaining old Spanish cattle that had escaped the deluge (Byron 1951).

In response, cattlemen restocked their herds with other varieties, including longhorns that had been driven from Texas Vandor (1919). For their part, shepherds adopted the annual cycle of Old World pastoralists: during the summer months they drove their flocks into the Sierra Nevada high country to conserve the lowland grasses for fall and winter grazing. The floods and droughts similarly wreaked havoc on production of agricultural goods, causing dramatic swings in commodity values. In the wake of the 1864 drought, crop failures depleted the supply of grain as the price of wheat on the San Francisco Market soared to $5.00 per cental (100 pounds) in March 1865 (Elliott 1883). By comparison, the price rarely breeched the $3.00 mark during the entire 1870s.

Along with the climate, political factors had a major hand in shaping the economic landscape.

Although the 1874 enactment of the “no fence” laws did not necessarily deal a death blow to valley ranching, the statute greatly curtailed the influence and importance of this industry. The law had both operational and monetary repercussions:

The “no fence” law obligated the stock owner to herd his cattle and sheep, whereas before the stock roamed at will and was not assembled except for the annual rodeo. He 842
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Cultural Resource Study for the Clovis Tract 6452 Residential Development 10 was also made responsible for damage done by his beasts. The farmer was not required to fence his holdings, though . . . he occasionally did so (Vandor 1919:163).

Without the entire extent of the San Joaquin Valley at his disposal and burdened by the continual task of containing his herds and flocks, the rancher found himself increasingly marginalized in the developing valley economy.

2.4.2 Initial Development of Agriculture in the Fresno-Clovis Area (1875–1900) In addition to pro-agriculture legislation and the arrival of the Southern Pacific Railroad in 1872, the development of irrigation systems greatly contributed to the growth of agriculture in Fresno County. Built in the early and mid-1870s, the first major water conveyance systems in the Fresno-Clovis area included the canals of the Fresno Canal and Irrigation Company (FCIC), the Kings River and Fresno Canal Company (KRFCC), and the Enterprise Canal Company (ECC).

These same systems, which use the waters of the Kings River, remain essential parts of the area’s agricultural industry today.

In local history, Moses Church—a former sheepherder from Napa County—is considered the chief developer of water conveyance in Fresno County. As early as 1870, Church began acquiring water rights along the Kings River; in February 1871, he and two business associates incorporated the FCIC (Elliott 1882; Willison 1980). His first objective was to deliver appropriated water to the farm of A. Y. Easterby, located in the present-day Sunnyside neighborhood of Fresno (Vandor 1919). In 1872, the company completed construction of the first main head gate on the Kings River that allowed 2,000 feet of water to be diverted into the irrigation system (Elliott 1882). The Fresno Canal was the FCIC’s primary channel. Although it runs a relatively short 12 miles, the Fresno Canal is the source of numerous large branch canals that still irrigate the fields south, west, and east of the Fresno-Clovis metropolitan area.

The KRFCC, also established in 1871, intended to build a similar system, although the project was not completed until 1873 when L. A. Gould purchased interest in the company (Clough and Secrest 1984; Willison 1980). By August of the same year, Gould’s farm was receiving irrigation water from the KRFCC Gould Canal, which taps the Kings River about 1.5 miles above the head gate of the Fresno Canal. The Gould Canal and its primary branch, the Helm Canal, irrigated the former agricultural lands in what is today the heart of the Fresno-Clovis metropolitan area.

While local sources are not specific about the incorporation of the ECC or the dates of its major conveyance, the Enterprise Canal, circumstantial evidence suggests that construction began sometime after 1875 and continued episodically until the early twentieth century when the canal appears to have reached its present-day length of 36.5 miles. According to Willison’s (1980) account, the KRFCC agreed to supply water to the ECC following the completion of the Gould Canal in 1873. This agreement was the basis for the eventual creation of the Enterprise Canal.

Although the Enterprise Canal is not represented on an 1875 map of the county, construction might have begun shortly after (Willison 1980). Moreover, Hall’s (1885) serial maps depicting irrigation in Fresno County as well as later county atlases suggest that the canal was built in stages. Whereas the first 15 miles of the Enterprise Canal (or “Enterprise Ditch”) as well as its head gate on the Gould Canal are shown and labeled on the Centerville and Kingsburg Sheet of the series, the lower reaches of the canal do not appear on the Fresno Sheet. Taken at face value, 843
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Cultural Resource Study for the Clovis Tract 6452 Residential Development 11 Hall’s (1885) maps indicate that in 1885 the Enterprise Canal terminated at Frolic Creek (present-day Dog Creek), southeast of the Project area. By the time of the 1891 Fresno County atlas, the canal had been lengthened another 9.5 miles through the Clovis area (directly west of the Project area) to its northernmost extent (in Section 18 of Township 12 South, Range 21 East); however, the canal’s existing southwesterly leg through what is today north Fresno had not been built yet (Thompson 1891).

Whatever the specific date(s) of the canal’s construction, the ECC’s dependence on the KRFCC and its Gould Canal clearly proved to be its undoing. In 1875, the KRFCC won a court battle with the FCIC that left KRFCC’s water rights intact (Willison 1980:77–83). Ten years later, however, the companies faced off again, but this time the FCIC succeeded in enjoining the KRFCC by drawing water from the Kings River (Mead 1901:277; Willison 1980:84). Without access to water from the river, the KRFCC and ECC were forced to sell their canals to the FCIC.

The court decision thus left the FCIC in control of all three canal systems.

Under the ownership of the FCIC, the Enterprise Canal continued to irrigate the farmlands north and east of the Fresno-Clovis area. It gave rise to several secondary canals along its route, including such Clovis-area branches as the Maupin Ditch, the Jefferson Canal, the Clovis Ditch, the Teague Ditch, and Helm Colonial Ditch as well as numerous unnamed laterals (Willison 1980). As early as 1900, the canal and its branches irrigated about 15,000 acres. By 1913, the lower portion of the canal appears to have been completed, bringing irrigation water to the area historically known as Forkner’s Fig Gardens (Progressive Map Service 1913:19). The Enterprise Canal, along with the rest of the FCIC’s system, was acquired by the Fresno Irrigation District in 1920 (Willison 1980).

For Church and other land promoters, the intended effect of irrigation was to increase the value of their properties so that they could be subdivided and sold to newly arriving homesteaders at a hefty profit. While this primary purpose was certainly achieved, the advent of intensive irrigation additionally led to a shift in both the types of crops grown and the size of a typical farm. Grain farming generally requires substantial acreage, but as irrigation water became more readily available, individual farmers realized that premium crops like grapes, citrus, and tree fruit could be profitably grown on lots as small as 20 acres.

Vandor’s history includes a commentary from (probably Charles) Nordoff, who describes how, with irrigation, bigger is not necessarily better.

Big ranches there are yet but they are hazardous ventures, and the fact is that in the big valley the twenty, forty and eighty-acre farmers brought the lasting and real agricultural prosperity. There, where wheat was once the big and only crop, the man with less than 320 acres classed himself as a humble small farmer. Slowly but gradually the conviction forced itself that eighty acres with water on a good location was a little too much, forty a liberal plenty with which to make a fair start in life, and twenty just enough for one man on which to make a comfortable living for self and family and have something over with industry and health for the proverbial rainy day. Wonders have been accomplished with ten acres by men who were not overambitious, not overburdened with money and hesitated not to combine brain and brawn in the labor in the field. Intelligent twenty-acre men are laying up what eastern farmers would consider a fortune . . . (Vandor 1919:261). 844
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Cultural Resource Study for the Clovis Tract 6452 Residential Development 12 Much like the “no fence” laws, the 1887 Wright Act, which provided for the creation of irrigation districts, is also seen as an important step in solidifying the interests of agriculture. In practice, it took some years before newly formed districts could gain the necessary legal and financial traction for operation, and these public cooperatives did not begin replacing private irrigation companies until the early twentieth century. At its passage, the Wright Act was, nevertheless, another legislative expression of the growing need for appropriated water. Another important development in the late nineteenth century was construction of the San Francisco & San Joaquin Valley Railroad in 1896, which provided Fresno with another rail line. Before then, farmers had complained about the Southern Pacific Railroad’s “ruinous” rates and were continually looking for alternative ways to ship their products to the Bay Area. This second railroad was acquired by the Atchison, Topeka, and Santa Fe Railway around 1900.

Agricultural growth in the San Joaquin Valley generally was accompanied by consistent population growth and urbanization, and with the rise in residential, commercial, and infrastructural development came an increase in demand for building materials. The one-man milling operations of the gold rush era had given way to late nineteenth-century lumber companies with the financial and technological means to harvest vast stands of timber in the nearby Sierra Nevada. It was primarily in this context that the town of Clovis arose.

Clovis originated in 1891 as a stop along the San Joaquin Valley Railroad, which extended from Fresno to the aspiring community of Pollasky (formerly called Hamptonville and later renamed Friant), located on the south bank of the San Joaquin River (Clough and Secrest 1984). Although Pollasky never fully materialized and the railroad was eventually sold off to the Southern Pacific, the new transportation link had opened the area northeast of Fresno for settlement and other ventures. Shortly afterward, the Fresno Flume and Irrigation Company, a combination lumber and irrigation venture, located its sawmill on a 60-acre parcel at the current site of Clark Intermediate School and the Clovis Rodeo Grounds. The mill was the end point of a 45-mile wooden flume from Shaver Lake. By its second year of operation in 1895, between 300 and 500 employees worked at the mill (Clough and Secrest 1984; Johnston 1997).

2.4.3 Diversification and Water Issues (1900–1950)
The trend toward smaller farms continued well into the new century. Between 1900 and 1920, 45,000 new farms were established in California, of which about 85 percent were less than 50 acres (Hall 1986). Yet whether a farm is small or large, the decision of which crop(s) to grow from year to year has historically been a speculative one for valley farmers. Given the decentralized nature of the industry, the market for a particular product was capable of unpredictable and dramatic changes. Oversupply of the previous year’s crop and the prospect of low prices have often compelled growers to look for other, more profitable alternatives. Out of this instability, many new fruit and vegetable varieties have been introduced to the valley.

The steady growth of the San Joaquin Valley’s agricultural base and its reliance on irrigation were beginning to erode the state’s water supply. In the period between 1909 and 1919, newly irrigated lands were placed under production at a rate of 155,000 acres per year (Hall 1986).

Established in 1920, the Fresno Irrigation District acquired the aging conveyance system of the FCIC, and immediately set out to revamp and add to the existing canals and structures (Willison 1980). Technological improvements to electric water pump technology allowed wells to extend 845
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Cultural Resource Study for the Clovis Tract 6452 Residential Development 13 even deeper into the aquifer, and by the mid-1920s the proliferation of wells had caused the water table to drop to alarmingly low levels. Among the most threatened were farmers who relied solely on wells for irrigation water. Along with a falling water table, California’s water issues included reducing the danger of flooding along the major rivers, providing for more dependable navigation on the Sacramento River, and improving the water quality in the East Bay area (Jackson 1977).

The solution was the Central Valley Project (CVP), a statewide multicomponent water conveyance system to control and redistribute the tremendous supply of water flowing from the Sierra Nevada. The CVP, which began at the state level, became part of the New Deal project in the mid-1930s because of the massive financing required for the project. Partially due to labor shortages created by World War II, the entire system was not completed until the early 1950s.

The Friant-Kern Canal, an original component of the CVP, flows about 5.5 miles east of the Project area.

In many ways, the Dry Creek drainage was a microcosm of the water issues facing the state during the 1920s and 1930s. Winding southwest from the foothills, Dry Creek disappears into a natural sink near the Old Fig Garden area in north-central Fresno. The natural flow from the creek raises the underground water table, which has been an important source of well irrigation water. Since the earliest days of Fresno, however, the annual flooding of the waterway caused traffic hazards, material damage, and even loss of life (Wilson 1932).

2.4.4 Modern Water Management (1950–Present)
Beginning in the mid-twentieth century, water management methods became more diverse and presently involve the storage of runoff in reservoirs for hydroelectric power and flood control and maintenance of underground water tables for such uses as irrigation and drinking water. As part of this larger process, the Dry Creek Project has sought to control the stream’s natural runoff by channeling the water into reservoirs (Fresno Bee 1948). Since beginning operation in 1948, the Dry Creek Project has expanded its scope to prevent flooding while managing the groundwater level (Clovis Unified School District 1984; Fresno Metropolitan Flood Control District 2004).

When it reached fruition in the 1950s, the CVP sparked a new wave of agricultural growth by providing an ample supply of federally subsidized water across the valley floor. The Friant-Kern Canal flows through the Dry Creek District and its primary function is to convey irrigation water to the counties of the southern San Joaquin Valley. Nevertheless, water from the channel does not pass through the greater Fresno area completely untouched; along with the City of Fresno, the Garfield Irrigation District and Harlan Ranch established the right to divert water from the Friant-Kern Canal (Clovis Unified School District 1984). 846
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Cultural Resource Study for the Clovis Tract 6452 Residential Development 14 3 METHODS
This chapter describes methods used to complete the cultural resource inventory of the Project area. This includes a records search to identify previous resources and studies within and adjacent to the Project area, background research, a search of the NAHC Sacred Lands File and contact with Native Americans who may have knowledge about the area, and an intensive pedestrian survey.

3.1 RECORDS SEARCH
At Æ’s request, the SSJVIC of the CHRIS at California State University, Bakersfield, performed a records search on June 31, 2023, to identify previously recorded resources and prior surveys within the Project area and surrounding 0.25-mile search radius. SSJVIC staff consulted cultural resource location and survey base maps, reports of previous investigations, and cultural resource records (Appendix B).

3.2 BACKGROUND RESEARCH
Prior to conducting a pedestrian archaeological survey, Æ conducted background research to identify areas within the Project area where extant historic-aged buildings, structures, or objects might be present, or where archaeological deposits might exist. Desktop and online library research focused on historical maps, aerial images, atlases, and photographs. Æ reviewed and compiled information from various sources including:
• General Land Office (GLO) maps (https://glorecords.blm.gov/default.aspx; 1856 and 1901);
• HistoricAerials.com administered by NETRonline topographic maps (https://www.historicaerials.com/viewer; T1922, T1923, T1946, T1955, T1965, T1974, T1975, T1982, T1995, T2012, T2015, T2018, and T2021); • Aerial photographs, accessed through the Map Aerial Locator Tool maintained by California State University, Fresno (http://malt.lib.csufresno.edu/MALT/; 1937 and 1964); FrameFinder administered by the University of California, Santa Barbara (http://mil.library.ucsb.edu/ap_indexes/FrameFinder/); and • HistoricAerials.com administered by NETRonline (1957, 1962, 1972, 1984, 1998, 2002, 2005, 2009, 2010, 2012, 2014, 2016, 2018, and 2020).

The result of Ӕ’s background research is discussed in Section 4.2.

3.3 NATIVE AMERICAN OUTREACH
Pursuant to California PRC Section 5097.9, state and local agencies cooperate with and assist the NAHC in its efforts to preserve and protect locations of sacred or special cultural and spiritual significance to Native Americans. On June 6, 2023, Æ contacted the NAHC to request a search 847
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Cultural Resource Study for the Clovis Tract 6452 Residential Development 15 of its Sacred Lands File to identify Native American resources in the Project area and obtain the names and contact information for individuals knowledgeable of such resources.

The NAHC responded on September 12, 2023, with its findings and attached a list of Native American tribes and individuals culturally affiliated with the Project area. Æ mailed a letter to each of the contacts identified by the NAHC. The letter summarized the Project and requested information about known cultural resources within the Project area and surrounding region. Ӕ additionally telephoned each contact to ensure they received the letter and to solicit information.

Outreach with the Native American tribes and individuals is standard best practices to complete a cultural resource inventory and is not part of formal government-to-government consultation under Assembly Bill (AB) 52. Æ’s record of tribal outreach is included in Appendix C.

3.4 PEDESTRIAN SURVEY
Æ Field Technician Charles Pansarosa performed an intensive pedestrian survey of the Project area using interval transects spaced 10 meters apart. Æ collected locational information on the survey coverage and photographed overviews of the Project area documenting the ground visibility and other conditions. All field records and photographs are archived at Æ’s office in Fresno, California.
848
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Cultural Resource Study for the Clovis Tract 6452 Residential Development 16 4 FINDINGS
This chapter provides results of the SSJVIC records search, Ӕ’s background research, the NAHC’s search of the Sacred Land’s File and Ӕ’s outreach to local Native American tribal representatives, and describes the pedestrian survey, including observations of field conditions and findings within the Project area.

4.1 RECORDS SEARCH
On July 31, 2023, the SSJVIC responded to Æ’s records search request (Records Search File No. 23-286). In its response, the SSJVIC identified four previous cultural resource investigations within the Project area and one previous investigation in the 0.25-mile search radius. In addition, the records search identified no cultural resources within the Project area and one previously recorded cultural resource within the 0.25-mile records search radius.

4.1.1 Previous Studies
There have been four studies previously conducted within the Project area and one study within the 0.25-mile radius (Table 4-1; Appendix B). The entirety of the Project area has been surveyed previously, portions of which were surveyed most recently in 2006, more than 15 years ago. All other previous studies were conducted more than 30 years ago.

Table 4-1
Previous Studies in the Project Area and Surrounding 0.25-Mile Radius CHRIS
Report No. Author(s) Year Title
Within the Project Area
FR-00534 Jones & Stokes
Associates, Inc.
1991 Archaeological Survey Report for the Behymer Lake Storm Drainage and Flood Control Project Initial Study
FR-01219 Bissonnette, L.D. 1993 Fresno Metropolitan Flood Control District Drainage Area "BY" Facilities
FR-02203 Varner, D.M. 2006 A Cultural Resource Study of the Battlin Brooks Property, Fresno County, California
FR-02289 Nettles, W.M. and
R. Baloian
2006 Cultural Resources Reconnaissance Survey of the City of Clovis Northwest Urban Center Specific Plan Area, Fresno County, California
Within the 0.25-Mile Radius
FR-03067 Stanley, W., R.

Baloian, and M.

Baloian.
2018 Cultural Resource Inventory and Evaluation for the Tract 6200 Development in the City of Clovis, Fresno County, California

4.1.2 Previously Recorded Resources
The records search identified no previously recorded resources within the Project area, and only one resource, the Enterprise Canal (P-10-005934), within the 0.25-mile records search radius. As 849
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Cultural Resource Study for the Clovis Tract 6452 Residential Development 17 discussed in Section 2.4.2, the Enterprise Canal was constructed in the mid-to-late 1870s to provide bulk irrigation water to the greater Clovis and North Fresno areas. The entire canal is

36.5 miles long.

4.2 BACKGROUND RESEARCH
Æ’s review of historical topographic maps and aerial photographs revealed moderate development in the area over the last 100 years. An 1856 map from the GLO depicts Big Dry Creek running southeast of the Project area (Figure 4-1). Big Dry Creek was present on the 1923 topographic map but on the 1947 map had been replaced with “Colonial Ditch.” The 1856 GLO shows “Road from Stockton to Kings River” and “Old Road” on either side of the Project area.

There were no remnants of these roads on the 1923 topographic map: all roads depicted on that map reflect their current state.

Figure 4-1 1856 GLO map showing transport routes and Big Dry Creek.

Ӕ’s review of historical atlases, aerials, and maps dating from 1891 to the present concluded that no structures have been built in the Project area. Two houses were built directly east of the Project area prior to 1957 and remained extant until circa 2000. Large, isolated buildings began appearing in the area in 1998, followed by housing developments east of Sunnyside Avenue between 1984 and 1998 and south of Shephard Avenue between 2005 and 2009. The Pacific Gas and Electric Shephard Substation was built directly south of the Project area between 2012 and 2014. The Project area and a significant portion of the surrounding area remain agricultural land.

4.3 NATIVE AMERICAN OUTREACH
On August 17, 2023, the NAHC stated in its search of the Sacred Lands File was negative for the presence of cultural resources in the Project area. The NAHC also supplied a list of individuals Fa“* 2.7 Mr, AOra’s
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Cultural Resource Study for the Clovis Tract 6452 Residential Development 18 to be contacted for information regarding locations of sacred or special sites of cultural or spiritual significance in the Project area.

On September 14, 2023, Æ sent a letter describing the Project and its location to:
• Chairperson Elizabeth Kipp of Big Sandy Rancheria of Western Mono Indians; • Tribal Administrator Tom Zizzo of Big Sandy Rancheria of Western Mono Indians; • Vice Chairperson Joel Marvin of Big Sandy Rancheria of Western Mono Indians; • Jared Aldern of Cold Springs Rancheria of Mono Indians; • Chairperson Carol Bill of Cold Springs Rancheria of Mono Indians; • Chairperson Robert Ledger of Dumna Wo-Wah Tribal Government; • Chairperson Ron Goode of North Fork Mono Tribe;
• Tribal Secretary Anna Phipps of North Fork Mono Tribe; • Council Member and Archaeological Director Jesse Valdez of North Fork Mono Tribe;
• Timothy Perez of North Valley Yokuts Tribe;
• Chairperson Katherine Perez of North Valley Yokuts Tribe; • Tribal Administrator Michael Wynn of Picayune Rancheria of the Chukchansi Indians;
• Tribal Historic Preservation Officer Heather Airey of the Picayune Rancheria of the Chukchansi Indians;
• Chairperson Janet Bill of the Picayune Rancheria of the Chukchansi Indians; • Cultural Resource Director Bob Pennell of Table Mountain Rancheria; • Chairperson Brenda Lavell of Table Mountain Rancheria; • Chairperson David Alvarez of the Traditional Choinumni Tribe; • Chairperson Neil Peyron of the Tule River Indian Tribe; • Environmental Department Kerri Vera of the Tule River Indian Tribe; • Tribal Archaeologist Joey Garfield of the Tule River Indian Tribe; and • Chairperson Kenneth Woodrow of the Wuksachi Indian Tribe/Eshom Valley Band. 851
AGENDA ITEM NO. 13.

Cultural Resource Study for the Clovis Tract 6452 Residential Development 19 Æ also distributed these letters via email on September 13, 2023, and followed up with all tribes by telephone on October 19, 2023. To date, Ӕ has received six responses from this outreach. • Big Sandy Rancheria of Mono Indians requested to be informed of any discoveries. • The North Fork Mono Tribe requested that work crews remain cognizant of the fact that there are several sites known through oral history in the area that have not yet been located.
• Table Mountain Rancheria requested a copy of the cultural resources report and a meeting to discuss the Project; this communication is being conducted by Lennar Central Valley.
• Picayune Rancheria of the Chukchansi Indians, Traditional Choinumni Tribe, and Tule River Indian Tribe all declined interest in the Project.

A log detailing the outreach efforts and responses is provided in Appendix C. Æ did not facilitate government-to-government consultation on behalf of the City.

4.4 PEDESTRIAN SURVEY
Ӕ conducted an intensive archaeological pedestrian survey on August 23, 2023, encompassing the entire 18.2 acres of the Project area. The Project area is an open vacant field. Ground visibility varied across the Project area (Figures 4-2 and 4-3). Portions of the Project area were clear and void of vegetation, whereas other portions were entirely obscured by overgrown vegetation with grasses reaching waist height. In addition to grasses, vegetation in the area includes sunflower, jimson weed, and lupine.

Figure 4-2 Cleared and sparsely vegetated ground surface with high visibility; facing northeast.

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Cultural Resource Study for the Clovis Tract 6452 Residential Development 20 Figure 4-3 Waist-high grass and star thistle with zero percent ground visibility; facing west.

Ӕ noted that the Project area appears to have been disked in the last year, and there also has been subsurface infrastructure improvements such as fire suppression, irrigation, and utilities in areas along the southern and western boundaries, likely associated with the adjacent development. Ӕ observed a graded dirt access road along the southern border. Modern debris including paper, plastic, polyvinyl chloride pipe segments, and fragments of concrete were also observed by the surveyor throughout the property. No cultural resources were identified in the Project area during the pedestrian survey.
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Cultural Resource Study for the Clovis Tract 6452 Residential Development 21 5 CONCLUSIONS AND RECOMMENDATIONS
Æ provided cultural resource services for the proposed Tract 6452 Residential Development Project in Fresno County, California for Lennar Central Valley. The Project proposes to construct 153 single-family lots on 18.2 acres of vacant land between Clovis Avenue and North Sunnyside Avenue, north of Perrin Road, in the city of Clovis. The proposed zoning for the Project will be M/L – Medium and Low Density Residential, while the current Fresno County zoning is AE-20. The property is currently in the County of Fresno and will need to be annexed to the City. This residential development will be within the City’s Heritage Grove Master Plan and will be subject to design development standards of the plan.

Æ conducted a cultural resource study to determine if archaeological or historical built environment cultural resources are present within the 18.2-acre Project area. Accordingly, Æ performed background research, obtained a records search from the SSJVIC of the CHRIS, requested a search of the NAHC Sacred Lands File, contacted local tribal representatives, and performed an intensive pedestrian survey of the Project area.

The SSJVIC records search identified four previous cultural resource investigations within the Project area and one previous investigation in the 0.25-mile search radius. In addition, the records search reported no previously recorded cultural resources within the Project area and one previously recorded cultural resource within the 0.25-mile records search radius. A search of the NAHC’s Sacred Lands File did not identify Native American cultural resources within or near the Project area and no specific information was gleaned from outreach with local tribal representative. No cultural resource sites were identified in the Project area from Ӕ’s survey efforts.

5.1 RECOMMENDATIONS
This study concludes that there are no historical resources within the Project area. Based on the results of this cultural resource inventory, Æ recommends the following management practices be adopted for the proposed Project.

5.1.1 Inadvertent Discovery of Archaeological Resources If unknown prehistoric or historic-era cultural resources are encountered during Project activities, all ground-disturbing activities within 50 feet of the find shall cease until a qualified archaeologist can evaluate the significance of the resource and recommend appropriate treatment measures. If necessary, per CEQA Guidelines Section 15126.4(b)(3)(A), project redesign and preservation in place shall be the preferred means to avoid impacts to significant cultural resources (i.e., historical resources). Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that a historical resource cannot be avoided, the qualified archaeologist shall develop mitigation practices in consultation with the City, which may include data recovery or other appropriate measures. The City also shall consult with interested Native American representatives in determining appropriate mitigation for unearthed cultural resources if the resources are prehistoric or Native American in nature. If preservation in 854
AGENDA ITEM NO. 13.

Cultural Resource Study for the Clovis Tract 6452 Residential Development 22 place is not possible and additional studies or data recovery mitigation is necessary, the qualified archaeologist shall prepare a report documenting these studies and/or additional mitigation of the resource. A copy of the report shall be provided to the City and to the SSJVIC. Construction can recommence based on the direction of the qualified archaeologist and with concurrence from the City.

5.1.2 Inadvertent Discovery of Human Remains
Æ advises that in the event human remains are uncovered during Project activities, the Fresno County Coroner is to be notified to evaluate the remains and follow the procedures and protocols set forth in CEQA Guidelines Section 15064.4 (e)(1). If the remains are identified to be those of a Native American, California Health and Safety Code 7050.5 requires that the county coroner notify the NAHC within 24 hours of discovery. The NAHC will then identify the Most Likely Descendant, who will be afforded the opportunity to recommend means for treatment of the human remains following protocols in California Public Resources Code 5097.98. 855
AGENDA ITEM NO. 13.

Cultural Resource Study for the Clovis Tract 6452 Residential Development 23 6 REFERENCES
Byron, William G.
1951 A Geographic Analysis of the Porterville Area, California. Master’s thesis, University of California, Los Angeles.

Clough, Charles W., and William B. Secrest, Jr.
1984 Fresno County—the Pioneer Years: From the Beginnings to 1900, edited by Bobbye Sisk Temple. Panorama West Books, Fresno, California.

Clovis Unified School District
1984 Images of an Age. Pacific Printing Press, Fresno, California.

Elliott, Wallace W.
1882 History of Fresno County, California, with Illustrations. Wallace W. Elliott & Co., San Francisco, California. Reprinted 1973, Valley Publishers, Fresno, California.

Elliott, Wallace W.
1883 History of Kern County, California. Wallace W. Elliott & Co., San Francisco, California.

Fresno Bee
1948 Water Flows into Reservoir of Dry Creek Flood Project. 14 April:17. Fresno, California.

Fresno Metropolitan Flood Control District
2004 Flood Control System. www.fresnofloodcontrol.org/flood_control_system, accessed June 2004.

Gayton, Anna H.
1945 Yokuts and Western Mono Social Organization. American Anthropologist 47(3):409– 426.
1948 Yokuts and Western Mono Ethnography II: Northern Foothill Yokuts and Western Mono. Anthropological Records Vol. 10(2). Berkeley and Los Angeles.

Hall, Richard D.
1986 Agriculture and Water. In Fresno County in the 20th Century: From 1900 to the 1980s, edited by Bobbye Sisk Temple, pp. 169–202. Panorama West Books, Fresno, California.

Hall, William Hammond
1885 Detail Irrigation Map: Fresno Sheet. 1:63,360. California Department of Engineering, Sacramento, California.
856
AGENDA ITEM NO. 13.

Cultural Resource Study for the Clovis Tract 6452 Residential Development 24 Jackson, W. Turrentine
1977 The Sacramento–San Joaquin Delta: The Evolution and Implementation of Water Policy: A Historical Perspective (UCAL-WRC-W-501). Water Resources Center Project. California Water Resources Center, University of California, Davis, 163.

Johnston, Hank
1997 The Whistles Blow No More: Railroad Logging in the Sierra Nevada. Stauffer Publishing, Fish Camp, California.

Kroeber, Alfred L.
1976 Handbook of the Indians of California. Dover Publications, New York. Originally published 1925, Bureau of American Ethnology Bulletin 78. Smithsonian Institution, Washington, D.C.

Langenwalter, P. E., and et al.
1989 Redbank and Fancher Creeks Archaeological Data Recovery Program CA-FRE-632, -633, -1154, and -1155, Fresno County.

Langenwalter, Paul E., II, Adella Schroth, Philip de Barros, and Franklin Fenenga 1989 Redbank and Fancher Creeks Archaeological Data Recovery Program, Final Report.

MITECH, Inc., Santa Ana, California. Prepared for the U.S. Army Corps of Engineers, Sacramento District, Sacramento, California, Contract DACW05-87-C0099.

McGuire, Kelly R.
1992 Rural Route 180, Fowler to Cove Avenues (06-FRE-180-R64.6/84.0 06-250-342500); Test Excavations at CA-FRE-61 and Extended Survey at CA-FRE-2851: A Preliminary Report, with contributions by R. Bethard, H. McCarthy, K. Tate, and E.

Wohlgemuth. Far Western Anthropological Research Group, Inc., Davis, California.

Submitted to Woodward-Clyde Consultants, Oakland, California, and California Department of Transportation, District 6, Fresno.

Meighan, Clement W., and Brian D. Dillon
1987 Redbank and Fancher Creeks Intensive Cultural Resources Survey. MITECH, Inc., Santa Ana, California. Submitted to U.S. Army Corps of Engineers, Sacramento District.

Moratto, Michael J.
1984 California Archaeology. Academic Press, Orlando, Florida. 1988 Archaeological Excavations at Site CA-FRE-1671, Fresno County, California. 2 vols.

INFOTEC Research, Inc., Sonora, California. Submitted to the California Department of Transportation, District 6, Fresno, California. California Department of Transportation, Publications Unit, Sacramento, California.

Munz, Phillip A., and David D. Keck, contributor
1973 A California Flora with Supplement. University of California Press, Berkeley. 857
AGENDA ITEM NO. 13.

Cultural Resource Study for the Clovis Tract 6452 Residential Development 25 Price, Barry A.
1992 Archaeological Survey Report of Route 168 Study Areas, with contributions by Michael J. Moratto and Clayton G. Lebow. INFOTEC Research, Inc., Fresno, California. Prepared for CH2M Hill, Emeryville, California.

Progressive Map Service
1913 Progressive Atlas of Fresno County. Progressive Map Service, Fresno, California.

Silverstein, Michael
1978 Yokuts: Introduction. In California, edited by Robert F. Heizer, pp. 446–447.

Handbook of North American Indians, Vol. 8, William C. Sturtevant, general editor.

Smithsonian Institution, Washington, D.C.

Smith, Ephraim K
1991 Historical Architectural Survey Report for Route 168 Rural Project, 6-Fre-168 R9.0/R14.75, EA #06-342700. California State University, Fresno Foundation.

Submitted to INFOTEC Research, Inc., Fresno, California.

Spier, Robert F. G.
1978 Monache. In California, edited by Robert F. Heizer, pp. 426–436. Handbook of North American Indians, Vol. 8, William C. Sturtevant, general editor. Smithsonian Institution, Washington, D.C.

Thompson, Thomas H.
1891 Official Historical Atlas Map of Fresno County. Thos. H. Thompson, Tulare, California.

Vandor, Paul E.
1919 History of Fresno County, California, with Biographical Sketches. 2 vols. Historic Record Company, Los Angeles, California.

Wallace, William J.
1978 Southern Valley Yokuts. In California, edited by Robert F. Heizer, pp. 448–461.

Handbook of North American Indians, Vol. 8, William C. Sturtevant, general editor.

Smithsonian Institution, Washington, D.C.
1987 Ethnohistory of the Redbank-Fancher Area: The Gashowu, a Little-Known Foothill Yokuts Tribelet. In Redbank and Fancher Creeks Intensive Cultural Resources Survey, edited by Clement W. Meighan and Brian D. Dillon, pp. 133–149. Institute of Archaeology, University of California, Los Angeles. Submitted to the U.S. Army Corps of Engineers, Sacramento District.

Wallace, William J., Adella Schroth, and Philip de Barros 1989 Archaeological Data Recovery at Prehistoric Archaeological Site CA-FRE-64.

Chambers Group, Inc., Santa Ana, California. Submitted to and on file at the California Department of Transportation, District 6, Fresno, California. 858
AGENDA ITEM NO. 13.

Cultural Resource Study for the Clovis Tract 6452 Residential Development 26 Weir, Walter W.
1956 Soils of Madera County, California. Soil Survey No. 12. Department of Soils and Plant Nutrition, University of California, Berkeley.

Willison, Paul H.
1980 Past, Present, & Future of the Fresno Irrigation District. Fresno Irrigation District, Fresno, California.

Wilson, L. H.
1932 Deaths, Injuries, Illness Caused by Dry Creek; Elimination Suggested. Fresno Morning Republican 19 January:7. Fresno, California.
859
AGENDA ITEM NO. 13.

APPENDIX A
Personnel Qualifications
860
AGENDA ITEM NO. 13.

CULTURAL RESOURCE MANAGEMENT | ARCHAEOLOGY | ARCHITECTURAL HISTORY | PALEONTOLOGY | GIS MARY CLARK BALOIAN Principal Archaeologist
Areas of Expertise
• Cultural resource management
• Prehistoric archaeology
• Project management
Years of Experience
• 30
Education
Ph.D., Anthropology, Southern
Methodist University, 2003
M.A., Anthropology, Southern
Methodist University, 1995
B.A., Anthropology, University of
California, Davis, 1989
Registrations/Certifications
• Registered Professional
Archaeologist 15189
Permits/Licensure
• Principal Investigator, California
BLM Statewide Cultural
Resources Use Permit CA-18-22
Professional Affiliations
• Society for American Archaeology
• Society for California Archaeology
Professional Experience
2021–2023 Principal Archaeologist, subconsultant for Applied EarthWorks, Inc., Fresno, California
2000–2020 President (2015–2020), Managing Principal (2015–2020), Regional Manager (2012–2014), Assistant Division
Manager (2010–2011), Principal Archaeologist/Project
Manager (2016–present), Senior Archaeologist/Project
Manager (2000–2015), Applied EarthWorks, Inc., Fresno,
California
1998–2001 Adjunct Faculty Member, Fresno City College, Fresno, California
1995–1996 Staff Archaeologist, Applied EarthWorks, Inc., Fresno, California
1994–1995 Staff Archaeologist, INFOTEC Research, Inc., Fresno, California
1992–1994 Teaching Assistant, Southern Methodist University, Dallas, Texas
1989–1991 Archaeological Project Leader, California Department of Transportation, Sacramento
Technical Qualifications
Dr. Clark Baloian has been involved in archaeology in California and the western United States since 1987. Her areas of expertise include the prehistory of the San Joaquin Valley, Sierra Nevada, Great Basin, central California coast, and the Iron Age of West Africa. Dr. Baloian has served as Principal Investigator/Project Manager, Field Supervisor, Crew Chief, or Field Technician for projects throughout California, Oregon, Nevada, New Mexico, Texas, Hawaii, and West Africa. Her experience in cultural resource management includes research design, data acquisition, laboratory analysis, and preparation of technical reports and compliance documents; she also has completed the Advisory Council on Historic Preservation course in National Historic Preservation Act (NHPA) Section 106 compliance policies and procedures. Her analytic skills include lithic and ceramic analyses as well as settlement pattern studies and spatial analysis, which were the foci of her doctoral research. As a Principal Archaeologist and subconsultant for Applied EarthWorks, Dr. Baloian provides quality assurance, high-level technical review, CEQA and Section 106 oversight, and overall professional guidance for project work, as needed.

Applied
EARTHWORKSIn
861
AGENDA ITEM NO. 13.

CULTURAL RESOURCE MANAGEMENT | ARCHAEOLOGY | ARCHITECTURAL HISTORY | PALEONTOLOGY | GIS ERIN ENRIGHT Vice President/Principal Archaeologist/Project Manager Areas of Expertise
• Cultural resource management
• Project management
• Archaeological field work/
Supervision
• GIS analysis and desktop site
assessments
• Faunal analysis
• Prehistory and history of California
and the Southwest
Years of Experience
• 22
Education
M.A., Anthropology and Applied
Archaeology, Eastern New Mexico
University, Portales, 2008
B.A., Classical and Near Eastern
Archaeology, Bryn Mawr College,
Pennsylvania, 2000
Registrations/Certifications
• Register of Professional
Archaeologists 16575 (2009)
• OSHA 40-hour HAZWOPER
(2019)
Permits/Licensure
• Principal Investigator, California
BLM Statewide Cultural
Resources Use Permit CA-21-21
Professional Affiliations
• Society for American Archaeology
• Society for California Archaeology
Professional Experience
2021– Vice President/Managing Principal/Principal
Archaeologist, Applied EarthWorks, Inc., San Luis
Obispo and Fresno, California
2019–2021 Managing Principal/Principal Archaeologist, Applied EarthWorks, Inc., San Luis Obispo, California
2014–2018 Senior Archaeologist/Project Manager, Applied EarthWorks, Inc., San Luis Obispo, California
2008–2014 Associate Archaeologist/Faunal Analyst, Applied EarthWorks, Inc., Lompoc, California
2004–2008 Faunal Analyst/Student Supervisor/ Educational Outreach, Blackwater Draw Archaeological Site and
Museum, Eastern New Mexico University, Portales
2001–2004 Staff Archaeologist, Cultural Resource Management Services, Paso Robles, California
2000 Field Archaeologist, Princeton Expedition, Polis
Chrysochous, Cyprus
1999 Archaeological Field School, Anathica Field School, Petras, Crete, Greece
Technical Qualifications
Ms. Enright is an experienced professional archaeologist, principal investigator, project manager, and field supervisor/director who has managed projects throughout California and the Southwest. She has participated at all levels within the cultural resource management industry with projects ranging from survey and site recording; testing and data recovery; National Register eligibly excavations; buried site testing (backhoe trenching); development of monitoring plans; database creation and maintenance; curation management; GIS; technical report production; and compliance assistance for NHPA and CEQA projects.

Ms. Enright has developed close relationships with tribal groups and individuals throughout the Central Coast and Central Valley. She has played a critical role in providing consultation support between agencies and Native American groups for AB 52, CEQA, and Section 106.

Additionally, she has experience managing large on-call contracts and complicated cultural resource management efforts with complex regulatory requirements. Several of these efforts have been in support of energy projects. Ms. Enright has authored or co-authored more than 70 technical reports and other NHPA, NEPA, and CEQA compliance documents, and presented research at state and national archaeological meetings.

Applied
EARTHWORKSIn
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AGENDA ITEM NO. 13.

CULTURAL RESOURCE MANAGEMENT | ARCHAEOLOGY | ARCHITECTURAL HISTORY | PALEONTOLOGY | GIS ANNA HOOVER Principal Archaeologist
Areas of Expertise
• Cultural resources management
• Prehistoric archaeology of
southern California
• Indigenous archaeology and Native
American/descendant community
coordination
• Federal, state, local environmental
laws and regulations
• Training, capacity building
• Traditional Cultural Property and
Landscape analysis
Years of Experience
• 24
Education
M.S., Anthropology, focus
Archaeology, 2003, University of
California, Riverside
B.S., Anthropology, 2000,
University of California, Riverside
B.A., Linguistics, 2000, University
of California, Riverside
A.A., English, 1996, Long Beach
City College
Registrations/Certifications
• Registered Professional
Archaeologist 28576661 (current)
• Cultural Consultant, Riverside
County #171 (current)
Permits/Licensure
• Field Director, California BLM
Statewide Cultural Resources Use
Permit CA-21-21
Professional Associations
• Society of California Archaeology
Professional Experience
2023– Principal Archaeologist, Applied EarthWorks, Inc. 2020–2022 Senior Archaeologist, Applied EarthWorks, Inc. 2017–2023 Senior Ethnoarchaeologist, Cultural Geographics Consulting
2007–2017 Deputy Tribal Historic Preservation Officer, Pechanga Band of Luiseño Mission Indians
2001–2015 Archaeological Assistant, San Bernardino County Coroner
2002–2007 Senior Archaeologist, L&L Environmental, Inc.

Technical Qualifications
Ms. Hoover has more than 24 years of experience in archaeological, cultural, and tribal resource management in southern California, Alta and Baja California, and Yucatan, Mexico. Ms. Hoover has collaborated with governmental agencies, environmental consultants, and indigenous communities to develop sustainable and practical applications for the identification and preservation of archaeological and tribal cultural resources, including landscapes and large, geographical features. As a capable Project Manager, she has coordinated dozens of CRM projects during all phases of development, including managing logistics and communications with various clients, lead agencies, Tribal communities, and project staff. Ms. Hoover is the designated archaeologist of record for three Native American Tribal Historic Preservation Offices (THPOs) in southern California.

Ms. Hoover has authored, co-authored, reviewed, and contributed to hundreds of California Environmental Quality Act (CEQA), Section 106 of the National Historic Preservation Act (NHPA), and National Environmental Policy Act (NEPA) technical reports; Programmatic, Memoranda, and Master Agreements; THPO development applications and associated tribal ordinances and historic preservation guidance; ethnographic studies and National Register of Historic Places eligibility forms; and other compliance and mitigation documents.

Ms. Hoover has presented collaborative projects, personal research, cultural resources education, and environmental regulation guidance trainings to a wide variety of audiences, including topics such as AB 52, SB 18 and CEQA guidance, cultural and tribal consultation best practices, and Tribal Monitoring Program trainings. She has contributed to CalTHPO organizational committees, participated in development of California and Federal archaeological and tribal consultation policies, and contributed to a published book on Tribal GIS applications.

Applied
EARTHWORKSIn
863
AGENDA ITEM NO. 13.

CULTURAL RESOURCE MANAGEMENT | ARCHAEOLOGY | ARCHITECTURAL HISTORY | PALEONTOLOGY | GIS NICOLE SAENZ Staff Anthropologist
Areas of Expertise
• Forensic anthropology
• Human osteology
• Faunal analysis/zooarchaeology
• Project administration
Years of Experience
• 6
Education
M.S., Forensic Anthropology,
Boston University Chobanian and
Avedisian School of Medicine, 2023
B.A., Anthropology, University of
California, Santa Cruz, 2012
Professional Experience
2023– Staff Anthropologist, Applied EarthWorks, Inc.
2022– Forensic Anthropology Consultant and Peer Reviewer, Puerto Rico Institute of Forensic Sciences
2022–2023 Field Technician, Applied EarthWorks, Inc.
2008–2012 Zooarchaeology Preparations and Curation Intern, University of California, Santa Cruz
Technical Qualifications
Ms. Saenz is a Staff Anthropologist at Applied EarthWorks, Inc. She received her Bachelor of Arts degree in Anthropology from the University of California, Santa Cruz and her Master of Science degree in Forensic Anthropology from the Boston University Chobanian and Avedisian School of Medicine. In addition, Ms. Saenz has completed internships in zooarchaeological preparation and curation, thermally altered scene analysis and remains recovery, and currently serves as a forensic anthropological consultant and peer reviewer for the Puerto Rico Institute of Forensic Sciences. Ms. Saenz’s professional responsibilities include project administration, osteological assessments, outreach with the Native American Heritage Commission and its recommendations, pre-field project preparations, writing technical reports, completing California Department of Parks and Recreation 523- series forms, and assisting with project proposals.

Applied
EARTHWORKSIn
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AGENDA ITEM NO. 13.

APPENDIX B
Records Search Results
865
AGENDA ITEM NO. 13.
7/31/2023

Milo Honsberger
Applied EarthWorks, Inc.
1391 W. Shaw Ave.

Fresno, CA 93711
Re: 4524 Clovis TR 0000
Records Search File No.: 23-286
The Southern San Joaquin Valley Information Center received your record search request for the project area referenced above, located on the Clovis & Friant USGS 7.5’ quads. The following reflects the results of the records search for the project area and the 0.25 mile radius:

As indicated on the data request form, the locations of resources and reports are provided in the following format: ☐ custom GIS maps ☒ GIS data
Resources within project area: None
Resources within 0.25 mile radius: P-10-005934
Reports within project area: FR-00534, 01219, 02203, 02289 Reports within 0.25 mile radius: FR-03067
NOTE:

Resource Database Printout (list): ☒ enclosed ☐ not requested ☐ nothing listed Resource Database Printout (details): ☒ enclosed ☐ not requested ☐ nothing listed Resource Digital Database Records: ☒ enclosed ☐ not requested ☐ nothing listed Report Database Printout (list): ☒ enclosed ☐ not requested ☐ nothing listed Report Database Printout (details): ☒ enclosed ☐ not requested ☐ nothing listed Report Digital Database Records: ☒ enclosed ☐ not requested ☐ nothing listed Resource Record Copies: ☒ enclosed ☐ not requested ☐ nothing listed ☐ not available Report Copies: ☒ enclosed ☐ not requested ☐ nothing listed ☐ not available Note:

OHP Built Environment Resources Directory: ☐ enclosed ☒ not requested ☐ nothing listed Archaeological Determinations of Eligibility: ☐ enclosed ☒ not requested ☐ nothing listed CA Inventory of Historic Resources (1976): ☐ enclosed ☒ not requested ☐ nothing listed Note: P-15-007046 is not listed in the BERD. The 2013 HPD page was included for this resource.

Fresno
Kern
Kings
Madera
Tulare
-
1 Southern San Joaquin Valley Information Center
California State University, Bakersfield
Mail Stop: 72 DOB
9001 Stockdale Highway
Bakersfield, California 93311-1022
(661) 654-2289
E-mail: [email protected]
Website: www.csub.edu/ssjvic
California
Historical
Resources
In formation
S y stem
k
866
AGENDA ITEM NO. 13.

Caltrans Bridge Survey: Not available at SSJVIC; please see https://dot.ca.gov/programs/environmental-analysis/cultural-studies/california-historical-bridges-tunnels Ethnographic Information: Not available at SSJVIC
Historical Literature: Not available at SSJVIC
Historical Maps: Not available at SSJVIC; please see
http://historicalmaps.arcgis.com/usgs/
Local Inventories: Not available at SSJVIC
GLO and/or Rancho Plat Maps: Not available at SSJVIC; please see http://www.glorecords.blm.gov/search/default.aspx#searchTabIndex=0&searchByTypeIndex=1 and/or http://www.oac.cdlib.org/view?docId=hb8489p15p;developer=local;style=oac4;doc.view=items Shipwreck Inventory: Not available at SSJVIC; please see https://www.slc.ca.gov/shipwrecks/
Soil Survey Maps: Not available at SSJVIC; please see
http://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx Please forward a copy of any resulting reports from this project to the office as soon as possible. Due to the sensitive nature of archaeological site location data, we ask that you do not include resource location maps and resource location descriptions in your report if the report is for public distribution. If you have any questions regarding the results presented herein, please contact the office at the phone number listed above.

The provision of CHRIS Data via this records search response does not in any way constitute public disclosure of records otherwise exempt from disclosure under the California Public Records Act or any other law, including, but not limited to, records related to archeological site information maintained by or on behalf of, or in the possession of, the State of California, Department of Parks and Recreation, State Historic Preservation Officer, Office of Historic Preservation, or the State Historical Resources Commission.

Due to processing delays and other factors, not all of the historical resource reports and resource records that have been submitted to the Office of Historic Preservation are available via this records search. Additional information may be available through the federal, state, and local agencies that produced or paid for historical resource management work in the search area. Additionally, Native American tribes have historical resource information not in the CHRIS Inventory, and you should contact the California Native American Heritage Commission for information on local/regional tribal contacts.

Should you require any additional information for the above referenced project, reference the record search number listed above when making inquiries. Invoices for Information Center services will be sent under separate cover from the California State University, Bakersfield Accounting Office.

Thank you for using the California Historical Resources Information System (CHRIS).

Sincerely,
Celeste M. Thomson
Coordinator
UL.O.0..A
867
AGENDA ITEM NO. 13.

Report List
Report No. Other IDs Year Author(s) Title Affiliation Resources SSJVIC Record Search 23-286
FR-00534 1991 Archaeological Survey Report for the
Behymer Lake Storm Drainage and Flood
Control Project Initial Study
Jones & Stokes Associates,
Inc.

Jones & Stokes
Associates, Inc.

FR-01219 1993 Fresno Metropolitan Flood Control District Drainage Area "BY" Facilities
Cultural Resources
Consulting
Bissonnette, Linda Dick
FR-02203 2006 A Cultural Resource Study of the Battlin
Brooks Property, Fresno County, California
Varner, Dudley M. Varner Associates
FR-02289 2006 Cultural Resources Reconnaissance Survey
of the City of Clovis Northwest Urban Center
Specific Plan Area, Fresno County, California
Nettles, Wendy M. and Applied EarthWorks, Inc.

Baloian, Randy
10-006109
FR-03067 2018 Cultural Resource Inventory and Evaluation for the Tract 6200 Development in the City of
Clovis, Fresno County, California
Stanley, Ward, Baloian, Applied EarthWorks, Inc.

Randy, and Baloian, Mary
10-005934

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Clovis City CouncilNovember 18, 2024

Clovis City Council
November 18, 2024