Clovis City Council
May 4, 2026

Therefore, no impact

10. HYDROLOGY AND WATER QUALITY
discharge requirements otherwiseor X
b. Substantially decrease groundwater
X
39 supplies or interfere substantially with
groundwater recharge such that the project
may impede sustainable groundwater
management of the basin?
substantially degrade surface or ground
water quality?
Less Than
Significant
Impact
No
Impact
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less-Than-Significant Impact. The Project site it is not located in an area typically associated with wildfires.

Although urban fires could occur, the Project would be constructed to the latest fire code standards, which would include fire sprinklers in each unit, as well as the installation of several fire hydrants throughout the site as required by the Clovis Fire Department. Further, other life safety features would be required such as smoke detectors, which would be reviewed and checked by the Fire Department to ensure proper operation prior to occupancy. Ultimately, a less-than-significant impact would occur with no mitigation measures.

Less-Than-Significant Impact. The Project will connect in the internal street network to N. Baron, Perrin, and N. Marion Avenues already developed 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 Planning and Development Services Department and other departments to ensure safe access to and from the area is maintained. Further, the site itself would be reviewed by City departments to ensure adequate site access and circulation is provided in the event of an emergency. Overall, a less-thansignificant impact would occur with no mitigation measures.

Would the project:_____________________
a. Violate any water quality standards or waste
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? 23 California Department of Toxic Substance Control, EnviroStor Database, https://www.envirostor.dtsc.ca.qov/public/map/?myaddress=Clovis, accessed on April 11, 2024
No Impact. The Project is not within an airport land use plan nor is the site within two miles of a public airport.

Therefore, no impact would occur.
f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
LENNAR HOMES (TM6452)

INITIAL STUDY
_____________________________________________________________________________________________________________ CITY OF CLOVIS No Impact. According the California Department of Toxic Substance Control EnviroStor Database, the Project site is not located on or within the immediate vicinity of a hazardous materials site.23 would occur.

X
X
X
X
X
X
X

ENVIRONMENTAL SETTING
40 The Project is located within the FMFCD boundary, and subject to its standards and regulations. Detention and retention basins in the FMFCD’s flood control system are sized to accommodate stormwater from each basin’s drainage area in builtout condition. The current capacity standard for FMFCD basins is to contain runoff from six inches of rainfall during a ten-day period and to infiltrate about 75 to 80 percent of annual rainfall into the groundwater basin (Rourke 2014). Basins are highly effective at reducing average concentrations of a broad range of contaminants, including several polyaromatic hydrocarbons, total suspended solids, and most metals (FMFCD 2013). Pollutants are removed by filtration through soil, and thus don’t reach the groundwater aquifer (FMFCD 2014). Basins are built to design criteria exceeding statewide Standard Urban Stormwater Mitigation The City is within the drainages of three streams: Dry Creek, Dog Creek, and Redbank Slough. On the north, Dry Creek discharges into the Herndon Canal in the City of Fresno west of Clovis. South of Dry Creek, Dog Creek is a tributary of Redbank Slough, which discharges into Mill Ditch south of Clovis (USGS 2012). A network of storm drains in the City and the Plan Area discharges into 31 retention basins, most of which provide drainage for a one- to two-square-mile area. Most of the Plan Area east and northeast of the City is not in drainage areas served by retention basins. Those areas drain to streams that discharge into reservoirs, including Big Dry Creek Reservoir in the north-central part of the Plan Area and Redbank Creek Dam and Reservoir in the southeast part of the Plan Area. Fancher Creek Dam and Reservoir are near the east Plan Area boundary.

LENNAR HOMES (TM6452)

INITIAL STUDY

CITY OF CLOVIS
c. Substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or
river or through the addition of impervious
surfaces, in a manner which would: (i) result
in substantial erosion or siltation on- or offsite; (ii) substantially increase the rate or amount of surface runoff in a manner which
would result in flooding on- or offsite; (iii)
create or contribute runoff water which would
exceed the capacity of existing or planned
stormwater drainage systems or provide
substantial additional sources of polluted
runoff; or (iv) impede or redirect flood flows?
i) Result in substantial erosion or siltation onor off-site?_______________________ ii) Substantially increase the rate or amount
of surface runoff in a manner which would
result in flooding on- or offsite?_______
iii) Create or contribute runoff water which
would exceed the capacity of existing or
planned stormwater drainage systems or
provide substantial additional sources of
polluted runoff?___________________
iv) Impede or redirect flood flows?____
d. In flood hazard, tsunami, or seiche zones,
risk release of pollutants due to project
inundation?______________________
e. Conflict with or obstruct implementation of a
water quality control plan or sustainable
groundwater management plan?

Groundwater
41 New development in accordance with the General Plan Update would increase the amount of impervious surface in the Plan Area, potentially affecting the amount of surface water that filters into the groundwater supply.

Groundwater levels are monitored in the Plan Area by the FID and the City of Clovis. As described in the 2015 A proposed development that would construct more impervious area on its project site than the affected detention/retention basin is sized to accommodate is required to infiltrate some stormwater onsite, such as through an onsite detention basin or drainage swales (Rourke 2014).

The Big Dry Creek Reservoir has a total storage capacity of about 30 thousand acre-feet (taf) and controls up to 230-year flood flows. Fancher Creek Dam and Reservoir hold up to 9.7 taf and controls up to 200-year flood flows. Redbank Creek Dam and Reservoir hold up to 1 taf and controls up to 200-year flood flows.

The pipeline collection system in the urban flood control system is designed to convey the peak flow rate from a two-year storm.

Clovis is underlain by the Kings Groundwater Basin that spans 1,530 square miles of central Fresno County and small areas of northern Kings and Tulare counties. Figure 5.9-4, Kings Groundwater Basin, shows that the basin is bounded on the north by the San Joaquin River, on the west by the Delta-Mendota and Westside Subbasins, the south by the Kings River South Fork and the Empire West Side Irrigation District, and on the east by the Sierra Nevada foothills. Depth to groundwater in 2016 ranged from 196.5 feet at the northwest City boundary to 69.5 feet at the southeast City boundary (Clovis 2016), 25 feet at the southeast SOI boundary, and about 20 feet at the eastern Plan Area boundary (FID 2013). The Kings Subbasin has been identified as critically overdrafted (Provost & Pritchard 2011).

In addition to their flood control and water quality functions, many FMFCD basins are used for groundwater recharge with imported surface water during the dry season through contracts with the FID and the cities of Fresno and Clovis; such recharge totaled 48,139 acre feet of water in 2020.

In the Plan Area, groundwater levels are monitored by the City of Clovis and FID. The overall area has not experienced land subsidence due to groundwater pumping since the early 1900s (FID 2006). Subsidence occurs when underground water or natural resources (e.g., oil) are pumped to the extent that the ground elevation lowers. No significant land subsidence is known to have occurred in the last 50 years as a result of land development, water resources development, groundwater pumping, or oil drilling (FID 2006). The City has identified a localized area of subsidence of 0.6 feet in the vicinity of Minnewawa and Herndon Avenues within the last 14 years (Clovis 2016). Regional ground subsidence in the Plan Area was mapped as less than one foot by the US Geological Survey in 1999 (Galloway and Riley 1999). Groundwater levels in the San Joaquin Valley are forecast to hit an all-time low in 2014 (UCCHM 2014).

Most drainage areas in the urban flood control system do not discharge to other water bodies, and drain mostly through infiltration into groundwater. When necessary, FMFCD can move water from a basin in one such drainage area to a second such basin by pumping water into a street and letting water flow in curb and gutter to a storm drain inlet in an adjoining drainage area (Rourke 2014). Two FMFCD drainage areas discharge directly to the San Joaquin River, and three to an irrigation canal, without storage in a basin. Six drainage areas containing basins discharge to the San Joaquin River, and another 39 basins discharge to canals (FMFCD 2013).

LENNAR HOMES (TM6452)

INITIAL STUDY
______________________________________________________________________________________________________________CITY OF CLOVIS Plan (SUSMP) standards (FMFCD 2013). The urban flood control system provides treatment for all types of development—not just the specific categories of development defined in a SUSMP—thus providing greater water quality protection for surface water and groundwater than does a SUSMP.

DISCUSSION
42 Less-Than-Significant Impact. There are no streams or rivers on the site that would be altered as a result of the Project. Further, some of the infrastructure surrounding the site, such as stormdrains are already in place from existing development to the south. The site is mostly pervious since it is currently undeveloped, and as a result, the Project would increase the amount of impervious surfaces by installing paving for roadways and sidewalks. However, the drainage pattern would be constructed per existing policies and regulations through The FMFCD urban stormwater drainage system would provide groundwater infiltration for runoff from developed land uses in detention basins in the drainage system service area.

Less-Than-Significant Impact. The Project would not deplete groundwater supplies or interfere with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level due to the Project. The 2014 General Plan EIR identified a net decrease in ground water aquifer throughout the region, however, because the City’s domestic water system is primarily served through surface water via existing water entitlements, the loss of aquifer is less than significant. The City has developed a surface water treatment plant (opened in June, 2004) that reduces the need for pumped groundwater, and has also expanded the municipal groundwater recharge facility. The Projects impacts to groundwater are less than significant with no mitigation measures required.

Projects pursuant to the proposed General Plan Update and developed outside of the FMFCD urban stormwater drainage system would be required to meet the requirements of NPDES regulations, including the implementation of BMPs to improve water retention and vegetation on project sites. b) Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
Less-Than-Significant Impact. The Project is located on a site that was previously anticipated for residential use. As with any development, existing policies and standards are required to be complied with, which are assessed during review of the entitlements. As such, the Engineering Division, as well as outside agencies such as the FMFCD review all plans to ensure that none of the water quality standards are violated and that waste discharge requirements are adhered to during construction and operation of the Project. Consequently, this process of Project review and approval would ensure that a less-than-significant impact occur with no mitigation measures.
c) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would: (i) result in substantial erosion or siltation on- or off-site; (ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite; (Hi) create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or (iv) impede or redirect flood flows? a) Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
LENNAR HOMES (TM6452)

INITIAL STUDY
CITY OF CLOVIS_____________________________________________________________________________________________________________ City of Clovis Urban Water Management Plan (UWMP), groundwater recharge occurs both naturally and artificially throughout the City. The Kings Groundwater Basin area is recharged through a joint effort between the Cities of Clovis and Fresno and the FID (CDWR 2006). Approximately 8,400 acre-feet per year (afy) of water are intentionally recharged into the Kings Groundwater Basin by the City of Clovis, and approximately 7,700 afy of water naturally flow into groundwater in the City’s boundaries (Clovis 2011).

11. LAND USE AND PLANNING
Would the project:
divide existingan
X

ENVIRONMENTAL SETTING

DISCUSSION
43 Potentially
Significant
Impact
No
Impact
a. Physically
community?
Less Than
Significant
Impact
X
Less Than
Significant With
Mitigation
Incorporated
Less-Than-Significant Impact. The City of Clovis is within the North Kings County Groundwater Sustainability Agency (GSA). Pursuant to the Sustainable Groundwater Management Act of 2014 (SGMA), certain regions in California are required to develop and implement a groundwater management plan that sustainably manages groundwater resources. The proposed Project would comply with the 2020 City of Clovis UWMP which promotes programs and policies to manage water supplies. Nevertheless, the Project would derive the majority of its water from surface water sources and does not propose or include plans for groundwater use. With regards to water quality control, the Project would be required to adhere to appropriate storm drain conveyance and the protection of water resources which would include the installation of backflow preventers. Consequently, the Project would result in a less-than-significant impact with no mitigation measures.

Less-Than-Significant Impact. Due to the Central Valley’s location away from the ocean, an impact from a tsunami is unlikely. The majority of the site is located within the 1% annual flood (100-year flood) area as mapped by Federal Emergency Management Agency (FEMA); however, the CMC Section 8.12, Floodplain Management lists standards and requirements for new construction within special flood zones; therefore, the Project would implement flood hazard management as required by the CMC. As a result of adhering to required flood hazard management, the Project would not risk the release of pollutants due to inundation and consequently, the Project would result in a less-than-significant impact would occur with no mitigation measures. b. Cause a significant environmental
impact due to a conflict with any land
use plan, policy, or regulation adopted
for the purpose of avoiding or mitigating
an environmental effect?
As described above in the Project Description, the Project site is vacant and undeveloped and is surrounded by residential development, including existing rural residential to the east, residential to the south currently under construction, and development under entitlement processing to the west. e) Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
d) Would the project, in flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
LENNAR HOMES (TM6452)

INITIAL STUDY
______________________________________________________________________________________________________________CITY OF CLOVIS review of the plans by the City Engineering Division and the FMFCD to ensure the site is properly and adequately drained such that the stormdrain system is maintained and so that no flooding occurs. Consequently, this review and approval by City engineers and FMFCD would mean that the Project result in a less-than-significant impact would occur with no mitigation measures.

12. MINERAL RESOURCES
X
X
24 2014 Clovis General Plan EIR, Chapter 5: Mineral Resources, page 5.11-1. 44 Potentially
Significant
Impact
Less Than
Significant
Impact
No
Impact
Less Than
Significant With
Mitigation
Incorporated
Less-Than-Significant Impact. As mentioned in the Existing Setting Section above, the Project site is currently within the County of Fresno jurisdiction and zoned AE20 (Exclusive Agricultural). However, the Project site will be rezoned to the R-1-PRD (Single-Family Planned Residential Development) Zone District though a separate entitlement application (Rezone 2021-006). According to Section 9.10.010(B)(5) of the CMC, the R-1-PRD Zone District identifies areas appropriate for single-family small lot uses, including attached and detached singlefamily structures on small lots. If approved, the Project will be required to go through the RSPR entitlement process for review for compliance with relevant design policies, such as in the Heritage Grove Master Plan, the CMC, and the General Plan. During the review, the height, color and materials are reviewed for consistency with these plans and guidelines. As a result of the Project in complying with the land use and zoning designation upon approval, as well as the review process ensuring General Plan and other applicable policies are adhered to, the Project would result in a less-than-significant impact with regards to conflicting with a land use plan.

No mitigation measures are required.

Less-Than-Significant Impact. Although the site is currently vacant and undeveloped, the general area to the south is urbanized with residential uses of varying densities. Typically, physically dividing existing communities is associated with the construction of a new road intersecting an established area or introducing uses that are not necessarily in line with the existing uses and planned land uses of the area. However, the Project site has been previously designated in the 2014 Clovis General Plan and zoned for residential use.

Consequently, because the proposed Project is the type of use previously planned for this site and the general areas, it would not physically divide an existing community. Rather, it seeks to add new housing stock to the City with installation of a new public sidewalk and roadway infrastructure. Therefore, a less-than-significant impact would occur and no mitigation measures are required.

ENVIRONMENTAL SETTING
The City of Clovis 2014 General Plan EIR defines minerals as any naturally occurring chemical elements or compounds formed from inorganic processes and organic substances.24 The 2014 General Plan EIR indicates that there are no active mines or inactive mines within the Plan Area of the City of Clovis. b) Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? Would the project:_______________
a. Result in the loss of availability of a
known mineral resource that would
be of value to the region and the
residents of the state?________
b. Result in the loss of availability of a
locally important mineral resource
recovery site delineated on a local
general plan, specific plan or other
land use plan?
LENNAR HOMES (TM6452)

INITIAL STUDY
CITY OF CLOVIS_____________________________________________________________ a) Would the project physically divide an existing community?

DISCUSSION
No Impact. Please refer to the discussion under Section 12a.

13. NOISE
X
X
X

ENVIRONMENTAL SETTING
45 An acoustical analysis was prepared for the Project by WJV Acoustics on March 14, 2024 and the analysis below is based in part on the study. As part of the acoustical analysis, noise exposure from traffic on Perrin and N. Clovis Avenues was calculated for future (2046) conditions using the Federal Highway Administration Potentially
Significant
Impact
Less Than
Significant
Impact
No
Impact
Less Than
Significant With
Mitigation
Incorporated
No Impact. As stated above, the City of Clovis does not have any active mines or inactive mines. Further, the Project site is not designated, or otherwise mapped for mineral resource extraction, or for having mineral resources of value to the region present on or below the surface of the site. Therefore, no impact would occur and no mitigation measures are required.

The Project site is vacant and surrounded by residential development, including existing rural residential to the east, residential development to the south currently under construction, and residential development under entitlement processing to the west. As such, existing ambient noise levels are typical of those associated with residential development, such as the sound of vehicles passing by, the sound of talking, and recreating could be expected within the Project vicinity. As a result of construction to the south, existing ambient noise levels may be slightly elevated as a result of the use of construction equipment, such as large trucks, tractors, and other construction tools associated with residential development. These increases would be temporary, however, and would cease upon completion of the neighborhood.

Would the project:____________________
a. Generation of a substantial temporary or
permanent increase in ambient noise
levels in the vicinity of the project in excess
of standards established in the local
general plan or noise ordinance, or
applicable standards of other agencies?
b. Generation of excessive groundborne
vibration or groundborne noise levels?
c. For a project located within the vicinity of a
private airstrip or an airport land use plan
or, where such a plan has not been
adopted, within two miles of a public airport
or public use airport, would the project
expose people residing or working in the
project area to excessive noise levels?
b) Would the project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? a) Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
LENNAR HOMES (TM6452)

INITIAL STUDY

CITY OF CLOVIS

DISCUSSION
As such, the exterior noise exposure would not exceed the City’s b) Would the project result in generation of excessive groundborne vibration or groundborne noise levels? 25 Acoustical Analysis Tract 6452, VJV Acoustics, Inc, page 8, March 2024. 46 The acoustical analysis indicated that exterior traffic noise exposure at the closest proposed lots to Perrin Avenue would be approximately 61 dB CNEL for future traffic conditions and approximately 51 dB CNEL for the Less-Than Significant Impact. The Project includes development of 153 single-family homes and associated infrastructure (i.e., sidewalks, roadways, curb, gutter, stormdrains, etc.). Therefore, construction equipment typical of the development of residential homes would be utilized temporarily. This equipment could include the use of heavy tractors, trucks, and other equipment; however, this type of equipment isn’t typically associated with excessive groundborne vibration. If any vibration were to occur, it’s likely that it would be temporary in nature and not at levels that would significantly impact the surrounding area. Further, the Project would be required to comply with the provisions of Section 9.22.090 of the CMC which requires that vibration not be perceptible along property lines and that it shall not interfere with operations or facilities on adjoining parcels.

It’s important to note also that temporary construction vibration and noise is exempt from these provisions due to the fact that construction is temporary. Overall, because the type of equipment likely to be used in the Mitigation Measure 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.

Less-Than-Significant Impact With Mitigation. The Project would include development of 153 single-family homes on an undeveloped site. Thus, the Project would result in a temporary and permanent increase in ambient noise levels as a result of construction and operation. However, as mentioned above, the Project site will be surrounded by residential development of varying densities. The Project would introduce new ambient noise from the construction and operation of the homes, these noises would represent the typical type of noise levels that is expected for a planned residential land use. While increases in ambient noise would occur due to the construction of the Project, this increase would be temporary and would be required to adhere to local regulations limiting the hours of construction.

The CMC Section 9.22.080, Noise, sets forth noise standards for development which would need to be complied with. For example, construction would only be permitted between the hours of 7:00 a.m. and 7:00 p.m. on weekdays, and between 9:00 a.m. and 5:00 p.m. on weekends. However, between June 1 and September 15, construction may begin at 6:00 a.m. on weekdays.

The acoustical analysis indicated that the worst-case interior noise exposure within the proposed Project would be approximately 61 dB CNEL which exceeds the City’s standard for interior noise; however, the mitigation measures below would reduce these impacts sufficiently to meet the City standards for noise. Consequently, a less-than-significant impact with mitigation would occur. a) Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
LENNAR HOMES (TM6452)

INITIAL STUDY
CITY OF CLOVIS____________
(FHWA) Highway Traffic Noise Prediction Model. The acoustical analysis can be found in Appendix D of this Initial Study.
closest proposed lots to N. Clovis Avenue.25
exterior noise level of 65 dB CNEL.

14. POPULATION AND HOUSING
X
X

ENVIRONMENTAL SETTING

DISCUSSION
47 Potentially
Significant
Impact
Less Than
Significant
Impact
No
Impact
Less Than
Significant With
Mitigation
Incorporated
Less-Than-Significant Impact. The Project would result in 153 single-family homes. The Project site has two existing General Plan Land Use designations of Very Low Density Residential, which allows for a density range of 0.6 to 2.0 DU/AC and Medium Density Residential, which allows for a density range of 4.1 to 7.0 DU/AC.

Calculated with net acres, the Project site would require a range of 42 to 80 dwelling units. Thus, blending of density will be utilized with adjacent TM6200, to the south. TM6200 was recorded on December 24, 2019, which allowed for a maximum of 871 dwelling units. TM6200 has been processed in phases currently with 586 dwelling units approved for development which leaves a 283-unit surplus. Thus, the Project will utilize 73 units of the remaining 283 units for a blended product. Further, the Project includes residential use on a site that is planned for the type of use being proposed. Unplanned population growth is typically associated with providing new services in remote areas of the City or other infrastructure that was not previously identified in the General Plan.

Although the Project would result in new housing units and population to the site, this growth was previously planned and anticipated under the 2014 General Plan. Thus, a less-than-significant impact would occur and no mitigation measures are required.

The Project is located on a vacant site that is planned for residential use in the 2014 Clovis General Plan. The Project site is ±18 acres and proposes 153 single-family homes. c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? No impact. The Project is not located within the vicinity of a private airstrip or within an airport land use plan nor is the site within two miles a public airport. Therefore, no impact would occur. a) Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example through extension of roads or other infrastructure) ?
Would the project:___________________
a. Induce substantial unplanned population
growth in an area, either directly (for
example, by proposing new homes and
businesses) or indirectly (for example
through extension of roads or other
infrastructure)?________________
b. Displace substantial numbers of existing
people or housing, necessitating the
construction of replacement housing
elsewhere?
LENNAR HOMES (TM6452)

INITIAL STUDY
______________________________________________________________________________________________________________CITY OF CLOVIS development of the Project is not considered to be of the type and intensity to result in substantial vibration or groundborne noise, the impact would be less than significant and no mitigation measures are required.

15. PUBLIC SERVICES

ENVIRONMENTAL SETTING

DISCUSSION
48 Less-Than-Significant Impact. Although the Project would result in 153 new residential units, the site is located adjacent to an area of the City that is already able to be served by the Clovis Fire Department. Upon annexation (R2021-006), the Project will then be located in an area the City will be able to serve. Also, the site itself is in close proximity to Fire Station’s #3 and #5, which would mean that response times should be able to be maintained during calls for service. As part of the entitlement process for the Project, the Clovis Fire Department will review the design and site layout to ensure adequate fire safety measures and site circulation are achieved.

This would include placement of new fire hydrants in certain locations throughout the site, adequate drive widths for fire truck and emergency vehicle access, and the appropriate application of fire codes, such as installation of sprinkler systems, fire alarms, and smoke detectors. Overall, with the site’s close proximity to numerous fire Potentially
Significant
Impact
Less Than
Significant
Impact
No
Impact
Less Than
Significant With
Mitigation
Incorporated
The Project would be served by the Clovis Fire Department, Clovis Police Department, with mutual aid from the City of Fresno, when needed. The Project site would also be within the Clovis Unified School District.

The nearest fire station is Fire Station #3, located approximately three (3) miles southwest of the site. The other closest fire station is Fire Station #5, located approximately four (4) miles to southeast of the site.

No impact. The Project site is vacant and undeveloped; therefore, no impact would occur and no mitigation measure are required.
a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection services? X
X
X
X
X
LENNAR HOMES (TM6452)

INITIAL STUDY
CITY OF CLOVIS_____________________________________________________________________________________________________________ b) Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
Would the project:_____________________
Would the Project result in substantial adverse
physical impacts associated with the provision
of new or physically altered governmental
facilities, need for new or physically altered
governmental facilities, the construction of
which could cause significant environmental
impacts, in order to maintain acceptable
service ratios, response times or other
performance objectives for any of the public
services:______________________________
a. Fire protection?________________
b. Police protection?______________
c. Schools?_____________________
d. Parks?_______________________
e. Other public facilities?

49 Less-Than-Significant Impact. Although the Project would result in 153 new residential units, residential uses have been previously planned for in the 2014 Clovis General Plan in this area. Also, through the entitlement process, the Project would undergo review by several departments and agencies for compliance with Less-Than-Significant Impact. Although the Project proposes one (1) approximately 8,990 square foot pocket park, this park would not cause significant environmental impacts in order to maintain acceptable service ratios, response times or other performance objectives for parks. Furthermore, the Project is required to request annexation to and provide a covenant for the Landscape Maintenance District. Consequently, a less-thansignificant impact would occur and no mitigation measures are required. c) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for schools? d) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for parks? b) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for police protection services? Less-Than-Significant Impact. Although the Project would result in 153 new residential units, the site is located adjacent to an area of the City this already able to be served by the Clovis Police Department. Upon annexation (R2021-006), the Project will then be located in an area the City will be able to serve. The Clovis Police Department headquarters are located at 1233 Fifth Street, which is approximately five (5) miles from the site.

As part of the entitlement process for the Project, the Clovis Police Department will review the design and site layout to ensure adequate safety measures are achieved. Consequently, a less-than-significant impact would occur and no mitigation measures are required.

Less-Than-Significant Impact. As part of the review process, Clovis Unified School District (CUSD) is provided the opportunity to comment and work closely with the City as development is proposed. As mentioned previously, the Project site was previously planned for residential development, as indicated in the 2014 Clovis General Plan. As such, the CUSD has been aware of the potential for this type of development at this location.

As part of the process, the Project would be required to pay school fees which typically go towards the improvement and/or construction of new schools or expanding existing schools if and when needed, as determined by the CUSD. Therefore, because the Project is consistent with what was previously planned for at this site in addition to payment of appropriate school fees set by the CUSD, a less-than-significant impact would occur and no mitigation measures are required.
e) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for other public facilities? LENNAR HOMES (TM6452)

INITIAL STUDY
______________________________________________________________________________________________________________CITY OF CLOVIS stations, construction that would meet the latest fire code standards, and review by the Clovis Fire Department, impacts related to effects on the performance of the Fire Department would be less-than-significant and no mitigation measures are required.

16. RECREATION
X
beoccur or
X

ENVIRONMENTAL SETTING

DISCUSSION
50 Less-Than-Significant Impact. The Project site itself would construct on-site a pocket park. The Project itself would not require the construction or expansion of new recreational facilities elsewhere that would have an adverse physical effect on the environment. The Project would also be required to contribute a proportionate share towards the acquisition and development of future parks in order for the City to maintain its adopted ratio Potentially
Significant
Impact
Less Than
Significant
Impact
No
Impact
Less Than
Significant With
Mitigation
Would the project:__________________ Incorporated
a. Would the project increase the use of
existing neighborhood and regional
parks or other recreational facilities such
that substantial physical deterioration of
Less-Than-Significant Impact. As mentioned in the Population and Housing section of this Initial Study, the Project is of the type previously planned and accounted for in the 2014 Clovis General Plan. Although 153 new residential units would be constructed, therefore, adding new population to the area that may utilize parks within the surrounding area, this growth was planned for with regards to park usage throughout the city. Further, the Project itself would include landscaped and open space areas on-site for its residents, as well as a pocket park space within the neighborhood, thereby, providing areas of recreation within the site itself. The Project would also be required to comply with 2014 General Plan Policy 2.2 of the Open Space and Conservation Element which encourages the incorporation of on-site natural resources. b. Does the project include recreational
facilities or require the construction or
expansion of recreational facilities that
might have an adverse physical effect
on the environment?
The nearest existing recreational site is Dry Creek Trailhead, located at the corner of Shepherd and Sunnyside Avenues. A future community park is planned approximately 0.30 miles west of the Project site.

Overall, the Project is not likely to increase the use of existing parks such that physical deterioration would occur. Therefore, the impact would be less-than-significant and no mitigation measures are required. the facility would
accelerated?
a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? b) Does the project include recreational facilities or require the construction or expansion of recreational facilities that might have an adverse physical effect on the environment? LENNAR HOMES (TM6452)

INITIAL STUDY
CITY OF CLOVIS____________
appropriate regulations and policies. This could result in various impact fees that are intended to maintain and enhance public facilities as appropriate to be able to accommodate the Project. As such, payment of the typical development fees, as well as project review by the different department and agencies, would result in the Project having a less-than-significant impact to public facilities. No mitigation measures are required.

17. TRANSPORTATION
a program plan,
X
section 15064.3, X
sharp curves or dangerous X
X

ENVIRONMENTAL SETTING

DISCUSSION
51 Would the project:
a. Conflict with
Less-Than-Significant Impact. As mentioned above, the site is on land that was previously planned for residential use in the 2014 Clovis General Plan. As described in the Population and Housing section above, the Project will be consistent with the planned density through density blending with the adjacent TM6200. The 2024 Clovis General Plan considers level of service (LOS) D as the LOS standard vehicle traffic operations, except for roadway segments that are adopted in the City’s General Plan EIR to operate at LOS E or F. At study No
Impact
Less Than
Significant
Impact
c. Substantially increase hazards due
to a geometric design feature (e.g.,
Guidelines :
subdivision (b)?
Less Than
Significant With
Mitigation
Incorporated
According to the 2014 Clovis General Plan Circulation Diagram in the Circulation Element (Figure C-1 of the Circulation Element), N. Baron and Perrin Avenues are classified as “Collector” streets. Collectors generally intended to provide for relatively short distance travel between and within neighborhoods and that serve longer through trips. N. Baron Avenue is planned to connect to N. Clovis and N. Minnewawa Avenues "Arterials" to the west.

A Transportation Impact Analysis (TIA) was prepared by Peters Engineering Group on February 8, 2024 (included as Appendix E of this Initial Study). The information and analysis in the following sections is based in part on the results of the TIA.

The project is bounded by Perrin Avenue to the south, N. Baron Avenue to the west, a planned FMFCD basin to the north, and rural residential to the east. The circulation network serving the site including internal site circulation will be constructed as part of the project. a) Would the project conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities? ordinance or policy addressing the
circulation system, including transit,
roadway, bicycle, and pedestrian
facilities?__________________
b. Conflict or be inconsistent with CEQA
Significant
and
Unavoidable
intersections) or incompatible uses
(e.g., farm equipment)?_______
d. Result in inadequate emergency
access?
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______________________________________________________________________________________________________________CITY OF CLOVIS of providing four (4) acres of parkland per 1,000 residents, as stated in Policy 1.1 in the Open Space and Conservation Element of the 2014 General Plan, and Section 3.4.03 of the CMC. As such, a less-thansignificant impact would occur and no mitigation measures are required.

Existing Traffic Conditions
Existing-Plus-Project Conditions
Near-Term-With-Project Conditions
These conditions are based on buildout of the Project plus the near term planned or entitled projects that are reasonably foreseeable. The following projects were considered in the near-term analyses: TM6205, 605 single-family homes (NE of Shepherd and Sunnyside), TM6343, 590 single-family homes (NE of Behymer and Baron), TM6406, 51 single-family homes (SW of Perrin and Baron), TM6375, 387 single-family homes 30 Transportation Impact Analysis, Proposed Tract No 6452, Peters Engineering Group, February 8, 2024 page 16. 52 26 Transportation Impact Analysis, Proposed Tract No. 6452, Peters Engineering Group, February 8, 2024 page 2. 27 Transportation Impact Analysis, Proposed Tract No 6452, Peters Engineering Group, February 8, 2024 page 9. 28 Transportation Impact Analysis, Proposed Tract No. 6452, Peters Engineering Group, February 8, 2024 page 9. 29 Transportation Impact Analysis, Proposed Tract No 6452, Peters Engineering Group, February 8, 2024 page 15. (W of Clovis and Baron), and Heritage Grove, 18-acre mixed use development (SE of Willow and Shepherd).

Under this scenario, the intersections of Minnewawa and Behymer Avenues and Clovis and N. Baron Avenues would exceed acceptable LOS thresholds per City standards during peak hours.30 Additionally, per the TIS the intersection of N. Clovis and Shepherd Avenues would not meet the 95th percentile gueues for existing storage Existing-Plus-Project conditions represent existing conditions plus buildout of the Project if none of the pending and approved project in the vicinity were constructed. According to the TIA, all intersections currently operating at an acceptable LOS are not expected to operate below the City LOS standard.28 Although delays are expected to increase at the intersection of Minnewawa and Behymer Avenues, the delays are relatively minimal. Delays are also expected to increase at the intersection of Sunnyside and Shepherd Avenues during the p.m. peak hour causing the LOS to drop from E to F; however, construction of a traffic signal at the intersection is currently underway.

The TIA studied six (6) intersections 1) N. Minnewawa and Behymer Avenues, 2) N. Baron and Behymer Avenues, 3) N. Baron and Perrin Avenues, 4) N. Clovis and Baron Avenues, 5) N. Clovis and Shephard Avenues, and 6) Sunnyside and Sheperd Avenues for existing conditions, existing-plus-project conditions, near term with project conditions, and cumulative conditions to the year 2045. A discussion of each of these scenarios is included below. Each scenario is based on the Projects a.m. and p.m. peak hour trips as determined in the TIS. According to the TIS, the Project would result in 108 trips in the a.m. peak hours of between 7:00 a.m. and 9:00 a.m. and 144 trips in the p.m. peak hours between 4:00 p.m. and 6:00 p.m., as well as a total of 1,444 daily vehicle trips.

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intersections under the jurisdiction of the City of Clovis, a significant impact would occur at a signalized intersection when LOS falls below the target LOS of D with the addition of project traffic or when project increases the average delay at an intersection already operating at an unacceptable LOS.

Based on the TIA,26 existing traffic volumes were determined during morning peak hours of 7:00 a.m. to 9:00 a.m., and between evening peak hours of 4:00 p.m. and 6:00 p.m. on a weekday. According to the TIA, the intersections of Minnewawa and Behymer Avenues and Sunnyside and Shepherd Avenues are not currently operating at an acceptable LOS based on City of Clovis standards.27 In order for the intersection of Minnewawa and Behymer Avenues to operate at an acceptable LOS, the intersection may be signalized or at a minimum a dedicated left-turn lanes with protected left-turn phasing would be required on the northbound and southbound approaches. With signalization this intersection is expected to operate at LOS B during a.m. and p.m. peak hours.29

Cumulative 2045 Traffic Conditions
• Eastbound: two left turn lanes, two through lanes, and one right turn lane • Westbound: one left turn lane, two through lanes, and one right turn lane 31 Transportation Impact Analysis, Proposed Tract No. 6452, Peters Engineering Group, February 8, 2024 page 16. 32 Transportation Impact Analysis, Proposed Tract No 6452, Peters Engineering Group, February 8, 2024 page 16. 33 Transportation Impact Analysis, Proposed Tract No 6452, Peters Engineering Group, February 8, 2024 page 10. 53 In order for the intersection of Minnewawa and Behymer Avenues to operate at acceptable LOS, the intersection may be signalized or at a minimum dedicated left turn lanes with protected left turn phasing would be required on all four approaches and a dedicated right turn lame would be required on the westbound approach. With signalization, the intersection is expected to operate at LOS D during the a.m. and p.m. peak hours.

For Sunnyside and Shepherd Avenues to operate at acceptable LOS, the intersection would require modification from the planned signalized lane to the following:

To better accommodate the intersection of N. Clovis and Shepherd Avenues, striping may be modified to open the second left-turn on the northbound approach. With the modification the intersection is expected to operate at LOS C during the a.m. and p.m. peak hours.

In order for the intersection of N. Baron and Behymer Avenues to operate at acceptable LOS, the intersection may be signalized, at a minimum a dedicated left turn lane with protected left turn phasing would be required on the westbound approach. With signalization, the intersection is expected to operate at LOS B during the a.m. and peak hour and LOS A during the p.m. peak hour.

In order for the intersection of N. Baron and Perrin to operate at acceptable LOS, all way stop control may be installed. With all-way stop control, the intersection is expected to operate at LOS B during the a.m. and p.m. peak hours.

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______________________________________________________________________________________________________________CITY OF CLOVIS capacity for the left-turn lane on the northbound approach, right turn lanes on the eastbound and northbound approaches.

In order for the intersection of Minnewawa and Behymer Avenues to operate at an acceptable LOS the same improved condition as outlined above in the Existing-Plus-Project Conditions summary is recommended. In order for the intersection of N. Clovis and Baron Avenues to operate at an acceptable LOS, the intersection would require signalization. With signalization, the intersection is expected to operate at LOS B during the a.m. and p.m. peak hours. It is not recommended to require installation of signalization with the Project alone; the intersection should require signalization until N. Clovis Avenue is extended north of Baron Avenue.31 In order to better accommodate queues at the intersection of N. Clovis and Shepherd Avenues, striping may be modified to open the second left-turn lane on the northbound approach, with this modification the intersection is expected to operate at LOS C during a.m. and p.m. peak hours.32 These conditions represent anticipated traffic volumes for the year 2045 using the Fresno Council of Governments (Fresno COG) travel model. As described in the TIS, only one (1) study intersection would operate at an acceptable LOS for the year 2045.33

• Southbound: two left turn lanes, one through lane, and one right turn lane Bicycle Facilities
b) Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b) ? • Provision of affordable housing
• Local-serving retail projects with areas of 100,000 square feet and below 34 Transportation Impact Analysis Guidelines, City of Clovis, September 15, 2022 page 4. 54 With regards to bicycle facilities, Figure C-2 of the 2014 Clovis General Plan does not indicate any planned bicycle or trail systems fronting the Project.

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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INITIAL STUDY
CITY OF CLOVIS___________________________________________________________________________ • Northbound: one left turn lane, one through lane, and one right turn lane

• 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)

INITIAL STUDY
_____________________________________________________________________________________________________ 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

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.

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

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.

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)

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______________________________________________________________________________________________________________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.

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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INITIAL STUDY
CITY OF CLOVIS____________
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?

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?

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)?
LENNAR HOMES (TM6452)

INITIAL STUDY

CITY OF CLOVIS
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?

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?
LENNAR HOMES (TM6452)

INITIAL STUDY
______________________________________________________________________________________________________________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.

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
LENNAR HOMES (TM6452)

INITIAL STUDY

CITY OF CLOVIS
Report Preparation

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

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

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

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

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.

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.

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

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.

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 Page 617 of 1024
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

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

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

1 Wilde North at Heritage Grove Residential Development Air Quality & Greenhouse Gas Impact Assessment

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 Page 621 of 1024 INC.
2 Wilde North at Heritage Grove Residential Development Air Quality & Greenhouse Gas Impact Assessment
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.

VftPA I TECHNOLOGIES Page 622 of 1024 INC.
3 Wilde North at Heritage Grove Residential Development Air Quality & Greenhouse Gas Impact Assessment
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4 Wilde North at Heritage Grove Residential Development Air Quality & Greenhouse Gas Impact Assessment
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5 Wilde North at Heritage Grove Residential Development Air Quality & Greenhouse Gas Impact Assessment

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.

VftPA I TECHNOLOGIES Page 625 of 1024 INC.
6 Wilde North at Heritage Grove Residential Development Air Quality & Greenhouse Gas Impact Assessment
✓ 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 Page 626 of 1024 INC. 7 Wilde North at Heritage Grove Residential Development Air Quality & Greenhouse Gas Impact Assessment
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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9 Wilde North at Heritage Grove Residential Development Air Quality & Greenhouse Gas Impact Assessment
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 Page 632 of 1024 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.

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 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.
✓ 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 Page 639 of 1024 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 Page 640 of 1024 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.

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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 Page 645 of 1024 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 Page 646 of 1024 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 Page 648 of 1024 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.

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.

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.

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.

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)
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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 Page 662 of 1024 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 Page 666 of 1024 INC.
53 Wilde North at Heritage Grove Residential Development Air Quality & Greenhouse Gas Impact Assessment
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 Page 667 of 1024 INC.
54 Wilde North at Heritage Grove Residential Development Air Quality & Greenhouse Gas Impact Assessment
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. 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.

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.

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.

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 Page 668 of 1024 INC.
55 Wilde North at Heritage Grove Residential Development Air Quality & Greenhouse Gas Impact Assessment
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 Page 669 of 1024 INC.
56 Wilde North at Heritage Grove Residential Development Air Quality & Greenhouse Gas Impact Assessment
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).

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 VftPA I TECHNOLOGIES Page 670 of 1024 INC.
57 Wilde North at Heritage Grove Residential Development Air Quality & Greenhouse Gas Impact Assessment
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.

VftPA I TECHNOLOGIES, Page 671 of 1024 INC.
58 Wilde North at Heritage Grove Residential Development Air Quality & Greenhouse Gas Impact Assessment
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.

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 the AQPs. The applicable General Plan for the project is 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 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 Page 672 of 1024 INC.
59 Wilde North at Heritage Grove Residential Development Air Quality & Greenhouse Gas Impact Assessment
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.

VftPA I TECHNOLOGIES Page 673 of 1024 INC.

Appendix-A
CalEEMod Worksheets

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 —+
A & Ji
!
!
!
!

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 ■
A
A
A

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

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 ■
A
A
A
A
A
A
A
A
A

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 Mitigated Operational

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—
Ji Ji L
■
■
■
A
A
A
A
A
A
A

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
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A A 11 1 1 1
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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

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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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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 Mitigated Construction Off-Site

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
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 1.9000e0046.1500e0036.1500e0035.6600e0035.6600e0030.0000 16.7285 16.7285 5.4100e0030.0000 16.8638 Total 0.0133 0.1359 0.0917 1.9000e0040.0983 6.1500e0030.1044 0.0505 5.6600e0030.0562 0.0000 16.7285 16.7285 5.4100e0030.0000 16.8638 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 9 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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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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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 Mitigated Construction Off-Site

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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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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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 Mitigated Construction Off-Site

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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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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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 Mitigated Construction Off-Site

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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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
CalEEMod Version: CalEEMod.2020.4.0 Page 16 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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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 Mitigated Construction Off-Site

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
CalEEMod Version: CalEEMod.2020.4.0 Page 17 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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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
CalEEMod Version: CalEEMod.2020.4.0 Page 18 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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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 Mitigated Construction Off-Site

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
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 Unmitigated 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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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 Mitigated Construction Off-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

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 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

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

0.0000

0.0000

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

0.0000

0.0000

0.4440

0.1755

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

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

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

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

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

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
4 8
9 10
7 0
$0.00
Rule 9510 Fee Schedule ($/ton)
Offsite Fee by Pollutant ($)
TABLE 2 -
No Fee Deferral Schedule (FDS)

T O T A L
(tons)
NOx
PM10
NOx
PM10
Pollutant
NOx
PM10
NOx
PM10
NOx
PM10
NOx
PM10
NOx
PM10
PM10
NOx
PM10
NOx
NOx
PM10
NOx
PM10
NOx
PM10
1 FALSE
6 —

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

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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