Clovis City Council
July 6, 2026

Environmental Assessment 4.7-17
7 California Department of Forestry and Fire, 2025. Fire Hazard Severity Zone Viewer. https://experience.arcgis.com/experience/6a9cb66bb1824cd98756812af41292a0 (accessed September 2025).

Environmental Impact Analysis
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standards are generally more stringent than federal regulations. Under the former, the employer is required to monitor worker exposure to listed hazardous substances and notify workers of exposure. The regulations specify requirements for employee training, availability of safety equipment, accident-prevention programs, and hazardous substance exposure warnings. At sites known or suspected to be contaminated by hazardous materials, workers must have training in hazardous materials operations and a Site Health and Safety Plan must be prepared, which establishes policies and procedures to protect workers and the public from exposure to potential hazards at the contaminated site.

California Code of Regulations, Title 22, Hazardous Waste Management At the State level, under Title 22, Division 4.5 of the CCR, DTSC regulates hazardous waste in California primarily under the authority of the Federal RCRA and the California Health and Safety Code (HSC). The HWCL, under CCR 22, Chapter 30, establishes regulations that are similar to RCRA but more stringent in their application and empowers the DTSC to administer the State’s hazardous waste program and implement the federal program in California. The DTSC is responsible for permitting, inspecting, ensuring compliance, and imposing corrective action programs to ensure that entities that generate, store, transport, treat, or dispose of potentially hazardous materials and waste comply with federal and State laws. The DTSC defines hazardous waste as waste with a chemical composition or other properties that make it capable of causing illness, death, or some other harm to humans and other life forms when mismanaged or released into the environment.

The DTSC shares responsibility for enforcement and implementation of hazardous waste control laws with the SWRCB and, at the local level, the CVRWQCB, and city and county governments.

California Code of Regulations Title 23, Chapter 15 Discharges of Hazardous Waste to Land Section 2511(b)
CCR 23, Chapter 15 Discharges of Hazardous Waste to Land Section 2511(b) pertains to water quality aspects of waste discharge to land. The regulation establishes waste and site classifications as well as waste management requirements for waste treatment, storage, or disposal in landfills, surface impoundments, waste piles, and land treatment facilities. Requirements are minimum standards for proper management of each waste category, which allows regional water boards to impose more stringent requirements to accommodate regional and site-specific conditions. In addition, the requirements of CCR 23, Chapter 15 applies to cleanup and abatement actions for unregulated hazardous waste discharges to land (e.g., spills).

California Code of Regulations Title 24, Chapter 7A
Chapter 7A of the California Building Code (Title 24, Part 2) establishes construction standards for new buildings located within designated Fire Hazard Severity Zones. These standards address materials and methods for exterior elements such as roofing, attic ventilation, walls, windows, doors, decking, and underfloor areas to reduce wildfire risk. According to CAL FIRE, the City of Clovis is not located in a Fire Hazard Severity Zone.7

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California Code of Regulations Title 24, Part 9
The California Fire Code (Title 24, Part 9 of the California Code of Regulations) is based on the 2012 International Fire Code and incorporates state-specific amendments. It establishes fire safety building standards that are referenced throughout Title 24.

California Accidental Release Prevention (Cal ARP) Program The purpose of the Cal ARP program is to prevent accidental releases of substances that can cause serious harm to the public and the environment, to minimize the damage if releases do occur, and to satisfy community right-to-know laws. The Cal ARP requires any business that handles more than threshold quantities of an extremely hazardous substance per California regulations to develop a Risk Management Plan (RMP). The RMP is implemented by the business to prevent or mitigate releases of regulated substances that could have off-site consequences through hazard identification, planning, source reduction, maintenance, training, and engineering controls. The RMP contains the following elements:
 Safety Information
 A Hazard Review
 Operating Procedures
 Training Requirements
 Compliance Audits
 Incident Investigation Procedures
The 2019 Fire and Building Code establishes the minimum requirements consistent with nationally recognized good practices to safeguard the public health, safety, and general welfare for the hazards of fire, explosion, or dangerous conditions in new and existing buildings, structures and premises, and to provide safety and assistance to firefighters and emergency responders during emergency operations. The provisions of this code apply to the construction, alteration, movement enlargement, replacement, repair, equipment, use and occupancy, location, maintenance, removal, and demolition of every building or structure or any appurtenances connected or attached to such building structures throughout the State of California.

California Department of Forestry and Fire Protection
The California Department of Forestry and Fire Protection (CAL FIRE) is responsible for wildfire protection and land stewardship across over 31 million acres of state wildlands. The Office of the State Fire Marshal (OSFM) supports this mission through fire prevention programs, code enforcement, and public education. OSFM activities include regulating fire safety in state-owned buildings, licensing fire protection system inspectors, approving fireworks, and overseeing fire safety standards for materials and pipelines. CAL FIRE classifies Fire Hazard Severity Zones (FHSZ) as Moderate, High, or Very High based on factors such as flame length, ember production, and the likelihood of fire occurrence, using a science-based model that evaluates fire behavior over a 30- to 50-year period.

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c. Local Regulations
City of Clovis General Plan, Environmental Safety Element The following policies of the General Plan Environmental Safety Element related to hazards and hazardous materials are applicable to the proposed project.  Policy 1.4 Facilities that use hazardous materials. Prohibit facilities using, storing, or otherwise involved with hazardous or toxic materials to be located in the 100-year flood zone unless all standards of elevation, flood proofing, and storage have been implemented.  Policy 2.1 Safe storage and maintenance. The use and storage of hazardous materials shall comply with applicable federal, state, and local laws to prevent and mitigate hazardous materials releases.
 Policy 2.2 Mitigation and remediation of groundwater contamination. Actively participate in local and regional efforts directed at mitigating environmental exposure to and cleaning up contaminated groundwater.
 Policy 2.3 Truck routes for hazardous materials. Maintain designated truck routes for the transportation of hazardous materials through the City. Discourage routes that pass through residential neighborhoods to the maximum extent feasible.  Policy 2.4 Hazardous materials response team. Maintain a Type 1 hazardous materials response team serving the City of Clovis.
 Policy 2.5 Safer Alternatives. Minimize the use of hazardous materials by encouraging the selection of non-toxic alternatives that do not pose a threat to the environment.  Policy 2.6 Community education. Provide educational resources to residents and businesses to promote safe practices related to the use, storage, transportation, and disposal of hazardous materials.
 Policy 3.11 Airport land use compatibility. Approve land uses in a manner that is consistent with the Fresno Yosemite International Airport Land Use Compatibility Plan. 8 City of Clovis General Plan, Public Facilities and Services Element The following policies of the General Plan Public Safety and Services Element related to hazards and hazardous materials are applicable to the proposed project.  Policy 6.8 Emergency preparedness planning. Maintain an emergency operations plan, an emergency operations center, and a hazard mitigation plan to prepare for actual or threatened conditions of disaster or extreme peril.

Certified Unified Program Agency (CUPA)
The California Environmental Protection Agency (CalEPA) designates certain local agencies as CUPA to oversee the implementation of specific hazardous materials and waste management programs at the county level. In Fresno County, this role is fulfilled by the Environmental Health Division of the Fresno County Department of Public Health. As the CUPA, the Environmental Health Division administers programs including but not limited to the regulation of leaking underground storage tanks (LUSTs), Hazardous Materials Business Plan (HMP) requirements, and Cal-ARP programs. 8 City of Clovis. 2014a. General Plan, Environmental Safety and Public Facilities and Services Elements. https://www.clovisca.gov/services/planning_development/planning/projects/general_plan_update/index.php. (Accessed May 2025).

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Responsibilities include permitting, inspections, compliance assistance, investigation, and enforcement.

San Joaquin Valley Air Pollution Control District
The San Joaquin Valley Air Pollution Control District (SJVAPCD) has regulatory authority over air quality in the City of Clovis. The District oversees emissions from both stationary sources (such as dust, smoke, and certain asbestos-related activities) and mobile sources. Its responsibilities include responding to air quality complaints, managing air quality permits, and reviewing development proposals for consistency with applicable air quality and greenhouse gas thresholds. Additional information on air quality and the SJVAPCD’s role is provided in Section 4.2, Air Quality, of this EA.

Fresno County Local Hazard Mitigation Plan
The City of Clovis participates in the Fresno County Multi-Jurisdictional Hazard Mitigation Plan, which identifies local hazard risks and outlines mitigation strategies to reduce potential impacts to people, property, and infrastructure. The plan identifies dam failure, flooding, hazardous materials incidents, drought, and seismic activity as among the most significant hazards for the area. Clovis enforces a range of hazard-reduction policies through its General Plan Safety Element, zoning and subdivision ordinances, and floodplain management regulations. The City is a participant in the National Flood Insurance Program and coordinates with regional agencies such as the Fresno Metropolitan Flood Control District and the North Kings Groundwater Sustainability Agency to manage flood and water supply risks. For infill development, the City requires compliance with its master drainage plan and site-specific review to ensure that new residential projects do not exacerbate flood risks or conflict with existing hazard mitigation infrastructure. Emergency preparedness is supported by the City’s Emergency Operations Plan and public outreach programs.

These regulatory and planning frameworks help ensure that residential infill development is consistent with local hazard mitigation objectives and does not expose future residents to significant hazard-related risks.

Fresno County Office of Emergency Services
Emergency preparedness and planning for unincorporated areas within the SOI and broader project area is managed by the Fresno County Office of Emergency Services (OES), a division of the Fresno County Department of Public Health. The OES maintains the Fresno County Operational Area Master Emergency Services Plan, which guides emergency response efforts in these areas. Additionally, the Fresno County Multi-Jurisdictional Local Hazard Mitigation Plan outlines potential hazards, available resources, and agency responsibilities for disaster response and recovery. The City of Clovis and the other incorporated cities in Fresno County coordinate with the County OES on preparedness, response, and recovery activities.

Clovis Fire Department
The Clovis Fire Department (CFD) oversees emergency preparedness and urban search and rescue operations. The department’s Special Projects Manager also serves as the Emergency Operations Center coordinator and manages the City’s Emergency Operations Plan.

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4.7.3 Impact Analysis
a. Methodology and Significance Thresholds
Methodology
Project impacts to hazards and hazardous materials are evaluated based on the project’s adherence to local, state, and federal standards; the nature of demolition, construction, and operational activities; proximity to schools; proximity of hazardous materials sites to the project; proximity to airports and adherence to applicable airport land use standards; compliance with existing emergency response plans; and proximity to wildland areas and potential for fire.

Significance Thresholds
In accordance with Appendix G of the California Environmental Quality Act (CEQA) Guidelines, an impact related to hazards and hazardous materials would be significant if the proposed project would:

1. Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials

2. Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the likely release of hazardous materials into the environment

3. Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school

4. Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, create a significant hazard to the public or the environment

5. Result in a safety hazard or excessive noise for people residing or working in the project area 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

6. Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan

7. Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires

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b. Project Impacts and Mitigation Measures
Threshold 1: Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Threshold 2: Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Impact HAZ-1 THE PROPOSED INFILL REZONE PROGRAM PROJECT WOULD FACILITATE NEW RESIDENTIAL

DEVELOPMENT THAT MAY INVOLVE ROUTINE TRANSPORTATION, USE, OR DISPOSAL OF HAZARDOUS MATERIALS IN CLOVIS NEAR RESIDENTIAL LAND USES. NONETHELESS, REQUIRED COMPLIANCE WITH APPLICABLE

REGULATIONS RELATED TO HAZARDOUS MATERIALS AND COMPLIANCE WITH GENERAL PLAN POLICIES WOULD MINIMIZE THE RISK OF RELEASES AND EXPOSURE TO THESE MATERIALS. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Operation
Although no specific development projects are proposed as part of the project, development facilitated by the proposed project could facilitate the construction of an estimated 1,303 new residential units in Clovis.

Hazardous materials are typically utilized by most land uses such as industrial, retail/office, commercial, residential, agriculture, medical, and recreational uses, among other activities.

Residential uses do not typically use hazardous materials other than small amounts for cleaning and landscaping. These materials would not be different from household chemicals and solvents already in wide use throughout Clovis. Residents and workers are anticipated to use limited quantities of products routinely for periodic cleaning, repair, and maintenance or for landscape maintenance/pest control that could contain hazardous materials. Those using such products would be required to comply with all applicable regulations regarding the disposal of household waste.

Additionally, future development would be required to comply with policies 1.4, 2.1, 2.2, 2.3, 2.4,

2.5, 2.6, and 3.11 of the General Plan Environmental Safety Element (these policies would not change under the proposed updates to this Element under the proposed project), which outline requirements for the handling, storage, disposal, and transport of hazardous materials and household hazardous materials. Therefore, operation of new residential uses poses little risk of exposing the public to hazardous materials.

The proposed project would involve rezoning and land use amendments to accommodate additional housing. The proposed project would not facilitate the establishment of new industrial, warehouse, auto-service, or manufacturing uses. Therefore, the proposed project would not introduce new manufacturing, warehouse, or industrial uses that would sell, use, store, transport, or release substantial quantities of hazardous materials.

Construction Activities
Construction activities associated with development facilitated by the project would include demolition of existing structures, construction of new development, and the replacement and/or improvement of drainage facilities. Although no specific development projects are proposed as part of the project, development facilitated by the proposed project could facilitate the construction of an estimated 1,303 new residential units in Clovis. The following discussion addresses the use of hazardous materials during construction activities, the potential for release of existing

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contaminated materials during construction, and the potential for release of LBP or ACM during demolition or construction.

Use of Hazardous Materials During Construction
Construction associated with future development in Clovis may include the temporary transport, storage, and use of potentially hazardous materials including fuels, lubricating fluids, cleaners, or solvents. If spilled, these substances could pose a risk to the environment and to human health.

However, the transport, storage, use, or disposal of hazardous materials is subject to various federal, State, and local regulations designed to reduce risks associated with hazardous materials, including potential risks associated with upset or accident conditions. Hazardous materials would be required to be transported under U.S. DOT regulations (U.S. DOT Hazardous Materials Transport Act, 49 Code of Federal Regulations), which stipulate the types of containers, labeling, and other restrictions to be used in the movement of such material on interstate highways. In addition, the use, storage, and disposal of hazardous materials are regulated through the RCRA. The California DTSC is responsible for implementing the RCRA program, as well as California’s own hazardous waste laws. DTSC regulates hazardous waste, cleans up existing contamination, and looks for ways to control and reduce the hazardous waste produced in California. It does this primarily under the authority of RCRA and in accordance with the California Hazardous Waste Control Law (California H&SC Division 20, Chapter 6.5) and the Hazardous Waste Control Regulations (Title 22, California Code of Regulations, Divisions 4 and 4.5). DTSC also oversees permitting, inspection, compliance, and corrective action programs to ensure that hazardous waste managers follow federal and State requirements and other laws that affect hazardous waste specific to handling, storage, transportation, disposal, treatment, reduction, cleanup, and emergency planning. Additionally, Policy 2.1 of the General Plan Environmental Safety Element would continue to require that the handling, storage, and disposal of hazardous materials complies with all applicable local, county, state, and federal laws. Compliance with existing regulations would reduce the risk of potential release of hazardous materials during construction.

Hazardous Materials Transport
Hazardous materials may be transported into, throughout, and near Clovis on N. Academy Avenue from State Route 180 to State Route 168 and State Route 168 from N. Academy Avenue to Huntington Lake Road and Big Creek Road9 and collector and local streets. Accidents on these roadways could result in the release of hazardous materials.

The U.S. DOT’s Office of Hazardous Materials Safety regulates the transportation of hazardous materials, as described in Title 49 of the CFR, and implemented by Title 13 of the CCR.

Documentation of compliance with hazardous materials regulations codified in Titles 8, 22, and 26 of the CCR, and their enabling legislation set forth in Chapter 6.95 of the California Health and Safety Code, is required for all hazardous waste transport. In addition, individual contractors and property owners are required to comply with all applicable federal, State, and local laws and regulations pertaining to the transport, use, disposal, handling, and storage of hazardous waste, including but not limited to, Title 49 of the CFR. Adherence to applicable regulations and laws would reduce the potential hazards associated with the transport of hazardous materials, including accidental release of hazardous materials during transport. 9 Federal Motor Carrier Safety Administration. 2024. National Hazardous Materials Route Registry – By State: California. https://www.fmcsa.dot.gov/regulations/hazardous-materials/national-hazardous-materials-route-registry-state (accessed July 2025).

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In addition to mandatory adherence to laws and regulations, Policy 2.3 of the Environmental Safety Element of the General Plan, Truck Routes for Hazardous Materials, regulates the transport of hazardous material on Clovis streets. The policy states that the City must maintain designated truck routes for the transportation of hazardous materials through the City and discourage routes that pass through residential neighborhoods to the maximum extent feasible further reduces potential impacts to residential areas from the transportation of hazardous materials. These designated routes, identified above, are registered in the U.S. DOT’s Federal Motor Carrier Safety Administration National Hazardous Materials Route Registry. Following these laws and regulations reduces the risk of accidental release of hazardous materials in transport.

Hazardous Materials Use and Disposal
Although the overall quantity of hazardous materials used and requiring disposal in Clovis could incrementally increase as a result of implementation of the proposed project, all new development that uses hazardous materials would be required to comply with the regulations, standards, and guidelines established by the U.S. EPA, the State of California, Fresno County, and Clovis related to storage, use, and disposal of hazardous materials.

As described above in the Regulatory Setting discussion, the Fresno County Department of Environmental Health, the Clovis Local Hazard Mitigation Plan and the Clovis General Plan aim to minimize community exposure to hazardous and potentially hazardous materials by avoiding toxic cleaning and building materials and products in civic facilities and services; providing information, opportunities, and incentives to the community for proper disposal of toxic materials; and encouraging non-toxic materials and products in homes and businesses as an alternative to products containing potentially hazardous materials. Additionally, future development would be required to comply with existing policies 2.1, 2.4, 2.5, and 2.6 of the General Plan Environmental Safety Element. These policies outline requirements for the handling, storage, and disposal of hazardous materials and minimizing the use of toxic and hazardous household products. Compliance with these policies would further prepare the city, and protect the public, in the event of an accidental spill or exposure, and would reduce the potential for accidental exposure and hazards associated with the use and disposal of hazardous materials.

Demolition and Redevelopment Activities
Infill development under the proposed project could involve demolition of existing structures.

Demolition could result in the release and exposure of construction workers to lead and asbestos.

However, lead-based materials and asbestos exposure are regulated by CalOSHA. CCR Section 1532.1 requires testing, monitoring, containment, and disposal of lead-based materials such that exposure levels do not exceed CalOSHA standards. Under this rule, construction workers (and by extension, neighboring properties) may not be exposed to lead at concentrations greater than 50 micrograms per cubic meter of air averaged over an eight-hour period and exposure must be reduced to lower concentrations if the workday exceeds eight hours. Similarly, CCR Section 1529 sets requirements for asbestos exposure assessments and monitoring, methods of complying with exposure requirements, safety gear wear, communication of hazards, and medical examination of workers.

The control of asbestos during demolition or renovation of buildings is regulated under the Federal Clean Air Act (FCAA). The FCAA requires a thorough inspection for asbestos where demolition will occur and specifies work practices to control emissions, such as removing all asbestos-containing materials, adequately wetting all regulated asbestos-containing materials, sealing the material in

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leak tight containers, and disposing of the asbestos-containing waste material as expediently as practicable.10 Compliance with the CCR and FCAA would reduce the potential hazards and risks associated with release of lead and asbestos to a less than significant level. Additionally, Policies 2.1-

2.6 of the City of Clovis General Plan Environmental Safety Element would continue to ensure that hazardous building materials removed during redevelopment activities are properly handled and disposed of.

Demolition of housing and other residential uses would not require the use of hazardous materials in demolition activities and thereby pose little risk of exposing the public to hazardous materials.

Residential uses associated with future developments facilitated by the project would be subject to compliance with CCR, CalOSHA, and other agencies to ensure hazardous materials risks to the public are also minimized.

Summary
Compliance with existing applicable regulations and programs would minimize risks from routine transport, use, and disposal of hazardous materials, including potential hazards from the accidental release of hazardous materials, associated with possible future development under the Infill Rezone Program. Oversight by the appropriate federal, State, and local agencies and compliance by new development and new Clovis residents with applicable regulations related to the handling and storage of hazardous materials would minimize the risk of the public’s potential exposure to these materials. Therefore, impacts from a hazard to the public or the environment through routine transport, use, or disposal of hazardous materials, or from accidental release or exposure to these materials would be less than significant.

Mitigation Measures
No mitigation measures are required.

Threshold 3: Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school?
Impact HAZ-2 THE PROPOSED PROJECT WOULD NOT EMIT HAZARDOUS EMISSIONS OR HANDLE HAZARDOUS OR ACUTELY HAZARDOUS MATERIALS, SUBSTANCES, OR WASTE WITHIN 0.25 MILE OF AN EXISTING OR PROPOSED SCHOOL. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

The proposed Infill Rezone Program project would facilitate residential development at a higher density than currently allowed under existing zoning. As shown in Figure 4.7-1 through Figure 4.7-6, the proposed project would facilitate development within 0.25 miles of the six identified schools11 and various pre-schools and childcare facilities throughout Clovis. However, as described above under Impact HAZ-1, the proposed project would not involve new industrial or manufacturing uses.

Hazardous materials and waste generated from reasonably foreseeable development accommodated under the proposed project would not pose a health risk to nearby schools or childcare facilities as a majority of these developments would be residential, which is a use that does not typically handle or emit hazardous materials or substances. Residential uses may involve 10 United States Environmental Protection Agency (USEPA). 2024. Overview of the Asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP). https://www.epa.gov/asbestos/overview-asbestos-national-emission-standards-hazardous-air-pollutants-neshap (accessed May 2025).
11 Identified schools include Valley Crescent School, Garfield Elementary School, Charlie Keyan Armenian Community School, Jefferson Elementary School, Sierra View Christian Academy, and Tarpey Elementary School.

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use and storage of some materials considered hazardous, though primarily these would be limited to solvents, paints, chemicals used for cleaning and building maintenance, and landscaping supplies.

These materials would not be different from household chemicals and solvents already in general and wide use throughout Clovis. Uses in Clovis that sell, use, store, generate, or release hazardous materials must adhere to applicable federal, State, and local safety standards, ordinances, and regulations.

As mentioned in Impact HAZ-1, construction facilitated by the proposed project may include the temporary transport, storage, and use of potentially hazardous materials including fuels, paints, lubricating fluids, cleaners, or solvents. Specifically, demolition, grading, and excavation activities associated with new construction may result in emissions and transport of hazardous materials.

Further, the Infill Rezone Program sites subject to rezoning and land use amendments may have unrecorded pre-existing contamination that could be exposed during grading or construction activities. However, adherence to applicable policies regarding emission and transport of hazardous materials such as the TSCA, the RCRA, and the Hazardous Waste Control Act, as listed the Regulatory Setting and under Impact HAZ-1, would ensure potential impacts would be reduced.

Additionally, compliance with General Plan Environmental Safety Element policies would further reduce impacts. Therefore, potential impacts associated with hazardous materials, substances, or wastes within 0.25 mile of an existing or proposed school would be less than significant.

Mitigation Measures
No mitigation measures are required.

Threshold 4: Would the project be located on a site that is included on a list of hazardous material sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? Impact HAZ-3 IMPLEMENTATION OF THE PROPOSED PROJECT WOULD ACCOMMODATE DEVELOPMENT ON OR NEAR HAZARDOUS MATERIALS SITES. HOWEVER, COMPLIANCE WITH APPLICABLE REGULATIONS AND

STANDARD CONDITIONS OF APPROVAL REQUIRING SITE CHARACTERIZATION AND CLEANUP WOULD MINIMIZE HAZARDS FROM DEVELOPMENT ON CONTAMINATED SITES. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Existing sites that use or have historically used hazardous materials or that may contain contaminants in soils or groundwater in the city include large and small-quantity generators of hazardous waste, such as gas stations and dry cleaners. As described in Section 4.7.1, Setting, Clovis has 41 closed LUST sites, 1 open LUST site, 10 closed cleanup program sites, 2 voluntary agreement sites with no further action needed, and 8 school investigations with no further action needed. 12,13
None of the Infill Rezone Program sites have any active or open LUST cleanup sites or other active or open hazardous materials sites pursuant to Government Code Section 65962.5.14 As shown in Figure 4.7-5, Rezone Site 161 is located 182 feet away from a closed LUST cleanup site (gas station and liquor store), and as shown in Figure 4.7-4, Rezone Site 589 is located on a closed cleanup program site (Roger’s Helicopters, an aviation services provider). California Supreme Court in a 12 12 Department of Toxic Substances Control (DTSC). 2025. EnviroStor Database. https://www.envirostor.dtsc.ca.gov/public/search?CMD=search&city=Clovis&zip=&county=&case_number=&business_name=&FEDERAL _SUPERFUND=True&STATE_RESPONSE=True&VOLUNTARY_CLEANUP=True&SCHOOL_CLEANUP=True&CORRECTIVE_ACTION=True&tiere d_permit=True&evaluation=True&operating=True&post_closure=True&non_operating=True&inspections=True&inspectionsother=True 13 State Water Resources Control Board (SWRCB). 2025. GeoTracker Database. https://geotracker.waterboards.ca.gov/map/?CMD=runreport&myaddress=clovis 14 Ibid.

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Threshold 5: 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?
Impact HAZ-4 THE PROPOSED PROJECT WOULD NOT RESULT IN A SAFETY HAZARD OR EXCESSIVE NOISE RELATED TO AIRPORT OPERATION FOR PEOPLE RESIDING OR WORKING IN THE PROJECT AREA. MITIGATION WOULD NOT BE REQUIRED, AND THIS IMPACT WOULD BE LESS THAN SIGNIFICANT.

The airport nearest to the City of Clovis boundary, FYI is located approximately 3.5 miles southwest of the City center. The Infill Rezone Program sites are located outside of the CNEL contours generated by the Fresno County Council of Governments ALUCP. Five of the proposed Infill Rezone Environmental Impact Analysis
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December 2015 opinion (BIA v. BAAQMD) confirmed CEQA is concerned with the impacts of a project on the environment, not the effects the existing environment may have on a project; therefore, potential hazards impacts to future new residents on the rezone sites would not be an impact under CEQA.

However, redevelopment of the Infill Rezone Program sites with existing soil or groundwater contamination could potentially pose a significant hazard to the public or the environment through releases of hazardous materials into the environment. The extent to which soil or groundwater may be affected by LUST, metals, lead, or other potential contamination source, if at all, depends on the type of contaminant, the amount released, the duration of the release, distance from source, and depth to groundwater. If groundwater contamination is identified, characterization of the vertical and lateral extent of the contamination and remediation activities would be required by the Regional Water Quality Control Board prior to the commencement of any new construction activities that would disturb the subsurface. If contamination exceeds regulatory action levels, the developer would be required to undertake remediation procedures prior to grading and development under the supervision of the Regional Water Quality Control Board, depending upon the nature of any identified contamination. Further, the City of Clovis General Plan Environmental Safety Element as listed in Section 4.7.2, Regulatory Setting, provides measures to lessen the impact of sites contaminated with hazardous materials. For example, Policy 2.1, which requires the use and storage of hazardous materials comply with all applicable federal state, and local laws, Policy 2.2, Mitigation and remediation of groundwater remediation, which requires City participation in local efforts directed at mitigating environmental exposure to and cleaning up contaminated groundwater, and Policy 2.4, which maintains a Type 1 hazardous materials response team for the City of Clovis.

Given that the hazardous materials sites located near the Infill Rezone Program sites are closed, and, and that no Infill Rezone Program sites are located near an open LUST site, development facilitated in their vicinity would not expose construction workers nor future occupants to hazardous materials sites. Compliance with federal, State, and local regulations, including the General Plan policies listed above, would reduce potential impacts associated with development on a closed hazardous materials site. Therefore, the impact of posing a significant hazard to the public or the environment through the release of hazardous materials associated with implementation of the proposed project would be less than significant.

Mitigation Measures
No mitigation measures are required.

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Program sites, however, are located within Safety Compatibility Zone 6, the Traffic Pattern Zone as shown in Figure 4.7-7. There are no restrictions on land uses or on special characteristics (distracting lights or glare, sources of smoke or electrical interference, or attractors of birds) in Zone 6.

Height limitations are imposed on projects within an airport hazard area so that structures or trees do not obstruct the airspace required for the flight of aircraft in landing or taking off at an airport or are otherwise hazardous to the landing or taking off of aircraft. The Airspace Protection Surface associated with the nearby airport extends 10,000 feet horizontally from the runway at an elevation of 150 feet above airport elevation (486 feet above mean sea level [amsl]), then continues upward at a slope of 1 vertical foot to 20 horizontal feet for an additional 4,000 feet, reaching an elevation of 686 feet amsl. Within the City of Clovis, ground elevations under this surface range from approximately 335 feet amsl near the airport to 686 feet amsl at the northeastern extent. Allowable structure heights vary depending on location within this zone. Existing development in Clovis remains well below these height limits. Future development under the proposed Infill Rezone Program would be subject to FAA airspace protection regulations. 15 Therefore, potential impacts related to airspace protection are considered less than significant.

Mitigation Measures
No mitigation measures are required.

Threshold 6: Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Impact HAZ-5 THE PROPOSED PROJECT WOULD NOT IMPAIR IMPLEMENTATION OF OR PHYSICALLY INTERFERE WITH AN ADOPTED EMERGENCY RESPONSE PLAN OR EMERGENCY EVACUATION PLAN. MITIGATION WOULD NOT BE REQUIRED, AND THE IMPACT WOULD BE LESS THAN SIGNIFICANT.

Fresno County’s Master Emergency Services Plan functions as the primary emergency response framework for the unincorporated areas of the Fresno County Operational Area. It also supports coordination with other jurisdictions during regional emergencies.

The County has also adopted a Multi-Jurisdictional Hazard Mitigation Plan, most recently updated in 2024. This plan outlines strategies to reduce risks from natural and human-made hazards and supports eligibility for federal disaster assistance programs, including Federal Emergency Management Agency’s Hazard Mitigation Grant Program, Pre-Disaster Mitigation Program, and Flood Mitigation Assistance. It also contributes to compliance with the National Flood Insurance Program’s Community Rating System, potentially reducing flood insurance premiums in participating communities.

In the event of an emergency, major roadways in Fresno County may be used for evacuation, depending on the nature and location of the incident. The proposed project does not include any physical development and would not interfere with adopted emergency response or evacuation plans. Due to the lack of physical development, there are no planned construction activities that would be anticipated to result in significant road closures or traffic disruptions that would impede emergency access. Any construction requiring traffic control would be subject to City-approved traffic management plans. Compliance with General Plan policies as listed in Section 4.9.2, Regulatory Setting, would further ensure that development facilitated by the project would not 15 City of Clovis. 2014b. General Plan EIR. Accessed May 2025:
https://www.clovisca.gov/services/planning_development/planning/general_plan/environmental_impact_report.php

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result in the impairment of implementation or physical interference with evacuation or emergency response plans. Therefore, the project would result in a less than significant impact related to emergency response and evacuation.

Mitigation Measures
No mitigation measures are required.

Threshold 7: Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires? Impact HAZ-6 THE PROPOSED PROJECT WOULD NOT EXPOSE PEOPLE OR STRUCTURES, EITHER DIRECTLY OR INDIRECTLY, TO A SIGNIFICANT RISK OF LOSS, INJURY, OR DEATH INVOLVING WILDLAND FIRES. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Refer to Section 4.16 Effects Found Not to Be Significant, for a discussion of impacts related to wildfire. In particular, this analysis concludes that the Infill Rezone Program sites are not in or near moderate, high and very high fire hazard severity zones. As such, the project would not increase the likelihood of people or structures to be exposed to significant risk of loss, injury, or death involving wildland fires. The impact would be less than significant.

Mitigation Measures
No mitigation measures are required.

4.7.4 Cumulative Impacts
The geographic scope for cumulative hazardous materials impacts is limited to projects within 0.25 mile of future development sites. This geographic scope is appropriate for hazardous materials because risks associated with hazards and hazardous materials occur largely in a site-specific and localized context as adverse impacts from a hazardous materials release or spill diminish in magnitude with distance. Cumulative residential development in the vicinity of any identified hazardous materials sites would gradually increase the population exposed to the use and transport of hazardous materials; the routine use, storage, and disposal of hazardous materials; and listed hazardous materials sites. The magnitude of hazards for individual projects would depend upon the location, type, and size of development and the specific hazards associated with individual sites.

Implementation of existing laws and regulations, including remedial action on contaminated sites, as discussed with regard to the project under Impacts HAZ-1 through HAZ-5, would avoid potential hazard impacts.

Overall, hazards and hazardous materials impacts associated with individual developments are site specific in nature and must be addressed on a case-by-case basis. Since hazards and hazardous materials are required to be examined as part of the existing permit application and review process, potential impacts associated with individual projects would be adequately addressed prior to permit approval. In summary, all work needs to be monitored and follow best practices in order to minimize potential impacts. With adherence to existing regulatory standards and proposed new General Plan policies for hazardous materials, no significant cumulative human health impacts would occur, and the project would not have a cumulatively considerable contribution to a significant cumulative impact related to hazards and hazardous materials.

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Mitigation Measures
No mitigation measures are required.

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4.8 Hydrology and Water Quality
This section evaluates the potential environmental effects related to hydrology and water quality associated with implementation of the proposed project.

4.8.1 Setting
Watershed
The California Department of Water Resources divides surface watersheds in California into 10 hydrologic regions. Clovis lies within the San Joaquin Hydrologic Region (San Joaquin Region), which contains 16 alluvial groundwater basins, covers approximately 15,200 square miles, and includes major portions of San Joaquin, Stanislaus, Merced, Madera, and Fresno County. These counties are part of the agriculturally rich Central Valley and rely heavily on groundwater for irrigation and municipal use.1 The San Joaquin Region comprises numerous rivers including the San Joaquin, Stanislaus, Tuolumne, Merced, and Mokelumne River. These rivers are critical for surface water supply, recharge of groundwater basins, and ecological health.

Clovis is located in the eastern portion of California’s San Joaquin Valley. The area is influenced by several major watersheds, including those of the San Joaquin, Merced, and Kings Rivers, which contribute to the region’s surface and groundwater systems. Clovis is situated near the Kings River watershed, which plays a significant role in local water supply and groundwater recharge. The region includes a network of canals and creeks that support agricultural and urban water needs.

These waterways ultimately contribute to the San Joaquin River, which flows northward and eventually joins the Sacramento–San Joaquin Delta, connecting to the San Francisco Bay.

Groundwater
Clovis lies within the San Joaquin Valley Groundwater Basin, specifically the Kings Subbasin, for which the North Kings Groundwater Sustainability Agency (GSA) serves as the designated Groundwater Sustainability Agency. Water supply in Clovis is provided by the City of Clovis Public Utilities Department, which sources water from a combination of surface water from the Kings River, groundwater wells, and treated imported water. The majority of the surface water originates from the Kings River watershed, with supplemental supplies from the Fresno Irrigation District.

Groundwater recharge and management projects planned or implemented by local agencies, including the North Kings GSA and Fresno Irrigation District, allow for greater flexibility in response to changing conditions such as single-year or multi-year droughts.

Water Quality
Groundwater from the Kings Subbasin of the San Joaquin Valley Groundwater Basin is generally of good quality and is monitored by the North Kings GSA, which includes the City of Clovis as a member agency. Groundwater quality and levels are tracked through a network of monitoring wells across the subbasin. The North Kings GSA and its partners, including the Fresno Irrigation District, prepare regional groundwater monitoring reports to assess trends in groundwater levels, quality, and recharge activities. Recent assessments indicate that groundwater in the Kings Subbasin is generally of good quality, with most constituents below the secondary maximum contaminant levels (SMCLs). 1 California Department of Water Resources (CDW). 2020. California’s Groundwater Update 2020. Available:
https://data.cnra.ca.gov/dataset/calgw_update2020/resource/d2b45d3c-52c0-45ba-b92a-fb3c90c1d4be. Accessed May 2025.

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The monitoring efforts also evaluate the quality of surface water and stormwater used for managed aquifer recharge (MAR) projects. These recharge efforts, particularly during wet years, help replenish the aquifer and support long-term sustainability. The Central Valley Regional Water Quality Control Board (CVRWQCB) is the primary agency responsible for protecting and enhancing surface and groundwater quality in the region. The CVRWQCB designates beneficial uses for water bodies, sets water quality objectives, and implements programs to maintain or improve water quality.

Flood Hazards
Floodplains are areas that are subject to recurring inundation and flooding located adjacent to rivers, streams, and coastal areas. Floodplains are described in terms of statistical likelihood of flooding in a given year, e.g., a 100-year floodplain has a one percent chance of flooding in any year, while a 500-year floodplain has a 0.2 percent chance of flooding in any year.

The Federal Emergency Management Agency (FEMA) establishes base flood elevations (BFE) for 100-year and 500-year flood zones and establishes Special Flood Hazard Areas (SFHA). SFHAs are those areas within 100-year flood zones or areas that will be inundated by a flood event having a one percent chance of being equaled or exceeded in any given year. The National Flood Insurance Act of 1968 made flood insurance available for the first time. The Flood Disaster Protection Act of 1973 made the purchase of flood insurance mandatory for the protection of property located in Special Flood Hazard Areas. Portions of the City of Clovis are located within flood hazard zones as mapped by FEMA and SFHAs as mapped by Flood Disaster Protection Act of 1973.2

4.8.2 Regulatory Setting
a. Federal Regulations
Federal Clean Water Act
In 1972, Congress passed the Federal Water Pollution Control Act, commonly known as the CWA, with the goal of “restor[ing] and maintain[ing] the chemical, physical, and biological integrity of the Nation’s waters” (33 U.S.C. § 1251(a)). The CWA directs states to establish water quality standards for all “waters of the United States” and to review and update such standards on a triennial basis.

Section 319 mandates specific actions for the control of pollution from non-point sources. The Environmental Protection Agency (EPA) has delegated responsibility for implementation of portions of the CWA, including water quality control planning and control programs, such as the National Pollutant Discharge Elimination System (NPDES) Program, to the California State Water Resources Control Board (SWRCB) and the Regional Water Quality Control Boards (RWQCBs). The CVRWQCB is the CWA enforcement agency for the Central Valley, including Fresno County.

Section 303(c)(2)(b) of the CWA requires states to adopt water quality standards for all surface waters of the United States based on the water body’s designated beneficial use. Water quality standards are typically numeric, although narrative criteria based upon biomonitoring methods may be employed where numerical standards cannot be established or where they are needed to supplement numerical standards. Applicable water quality standards are contained in the CVRWQCB 2 Federal Emergency Management Agency (FEMA). 2025. FEMA Flood Map Service Center. Available:
https://msc.fema.gov/portal/search?AddressQuery=Clovis. Accessed May 2025.

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Basin Plan which analyzes the hydrologic units and subregions of the Central Valley, including Fresno County.

Section 303(d) of the CWA bridges the technology-based and water quality-based approaches for managing water quality. Section 303(d) requires that states make a list of waters that are not attaining standards after the technology-based limits are put into place. For waters on this list (and where the U.S. EPA administrator deems they are appropriate), states are to develop total maximum daily loads (TMDL). TMDLs are established at the level necessary to implement the applicable water quality standards. A TMDL must account for all sources of the pollutants that caused the water to be listed.

Section 404 of the CWA prohibits the discharge of any pollutants into “waters of the United States,” except as allowed by permit. (33 Code of Federal Resources § 328.3(a)(3).) Section 404 of the CWA authorizes the U.S. Army Corps of Engineers to issue permits for and regulate the discharge of dredged or fill materials into wetlands or other waters of the United States. Under the CWA and its implementing regulations, “waters of the United States” are broadly defined to consist of rivers, creeks, streams, and lakes extending to their headwaters, including adjacent wetlands.

National Pollutant Discharge Elimination System
In California, the NPDES program is administered by the SWRCB through the nine RWQCBs. Clovis lies within the jurisdiction of CVRWQCB (Region 5) and is subject to the waste discharge requirements of the Regional Phase I Municipal Separate Storm Sewer Systems (MS4) Permit (Order No. R4-2021-0105) and NPDES Permit No. CAS004004, which was adopted on July 23, 2021, became effective on September 11, 2021, and is set to expire on September 10, 2026.

MS4 permit requirements include reduction of pollutant discharges to the ‘maximum extent practicable’ and protection of water quality. Requirements also include identification of major outfalls and pollutant loads and control of discharges from new development and redevelopment.

To address these objectives, municipalities are required to prepare stormwater management plans.

Although the NPDES program does not regulate nonpoint sources of pollution, the CVRWQCB has other programs in place to address nonpoint sources.

Federal Emergency Management Agency
FEMA establishes BFEs for 100-year and 500-year flood zones and establishes SFHAs. SFHAs are those areas within 100-year flood zones or areas that will be inundated by a flood event having a one percent chance of being equaled or exceeded in any given year. The 500-year flood zone is defined as the area that could be inundated by the flood which has a 0.2 percent probability of occurring in any given year, or once in 500 years, and is not considered an SFHA. There are FEMAdesignated 100-year Flood Hazard Areas throughout city limits, however, the Clovis General Plan Environmental Safety Element, Policy 1.1 (Flood Zone) prohibits development within the 100-year flood zone and dam inundation areas unless adequate mitigation is provided against flood hazards.3 In 2000, FEMA adopted revisions to 44 Code of Federal Regulations (CFR), known as the Disaster Mitigation Act (DMA) or DMA 2000. Section 322 (a-d) of the DMA 2000 requires local governments to have a Hazard Mitigation Plan (HMP) as a condition of receiving federal disaster mitigation funds.

The HMP must:
3 City of Clovis. 2014. General Plan. Available:
https://www.clovisca.gov/services/planning_development/planning/general_plan/index.php. Accessed May 2025.

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 Describe the process for assessing hazards, risks, and vulnerabilities.  Identify and prioritize mitigation actions.
 Solicit input from the community (public), key stakeholders, and adjacent jurisdictions and agencies.

Clovis’s HMP is discussed under Local Regulations, below.

National Flood Insurance Act / Flood Disaster Protection Act The National Flood Insurance Act of 1968 made flood insurance available for the first time. The Flood Disaster Protection Act of 1973 made the purchase of flood insurance mandatory for the protection of property located in SFHA. These laws are relevant because they lead to mapping of regulatory floodplains and to local management of floodplain areas according to guidelines that include prohibiting or restricting development in flood hazard zones. There are portions of Clovis located within the SFHA.
4 National Toxics Rule and California Toxics Rule
In 1992, U.S. EPA promulgated the National Toxics Rule, 40 CFR 131, establishing numeric criteria for priority toxic pollutants in multiple states in order to bring all states into compliance with the Water Quality Standards (WQS) requirements of section 303(c) of the CWA. The National Toxics Rule established WQS for 42 pollutants not covered under California’s statewide water quality regulations at that time. After the court ordered revocation of California’s statewide Basin Plans in September 1994, U.S. EPA initiated efforts to promulgate additional federal WQS for California. In May 2000, U.S. EPA issued the California Toxics Rule, which includes all the priority pollutants for which the EPA has issued numeric criteria not included in the National Toxics Rule.

Safe Drinking Water Act
The Federal Safe Drinking Water Act was enacted in 1974, allowing the U.S. EPA to promulgate national primary drinking water standards specifying Maximum Contaminants Levels (MCLs) for each contaminant present in a public water system with an adverse effect on human health. Primary MCLs have been established for approximately 90 contaminants in drinking water. The U.S. EPA has also adopted secondary MCLs as non-enforceable guidelines for contaminants that may cause cosmetic or aesthetic effects. States have the discretion to adopt them as enforceable standards.

U.S. EPA has delegated to the SWRCB the responsibility for administering California’s drinking‐water program. In 1976, California adopted its own safe drinking water act (see California Safe Drinking Water Act described below).
b. State Regulations
Porter-Cologne Water Quality Control Act
The Porter-Cologne Water Quality Control Act of 1967 requires the SWRCB and the nine RWQCBs to adopt water quality criteria to protect State waters. These criteria include the identification of beneficial uses, narrative and numerical water quality standards, and implementation procedures.

The Water Quality Control Plan, or Basin Plan, protects designated beneficial uses of State waters 4 Federal Emergency Management Agency (FEMA). 2025. FEMA Flood Map Service Center. Available:
https://msc.fema.gov/portal/search?AddressQuery=Clovis. Accessed June 2025.

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through the issuance of waste discharge requirements (WDRs) and through the development of TMDLs. Anyone proposing to discharge waste that could affect the quality of the waters of the State must make a report of the waste discharge to the RWQCB or SWRCB as appropriate, in compliance with the Porter-Cologne Act.

The Central Valley Regional Water Quality Control Plan is the Basin Plan that covers Fresno County and is discussed under Local Regulations, below.

California Safe Drinking Water Act
The U.S. EPA has delegated to the California Department of Public Health responsibility for administering California’s drinking‐water program. In 1976, two years after the Federal Safe Drinking Water Act was passed, California adopted its own safe drinking water act (contained in the Health and Safety Code) and adopted implementing regulations (contained in 22 California Code of Regulations (CCR)). California’s program sets drinking water standards that are at least as stringent as the Federal standards. Each community water system also must monitor for a specified list of contaminants, and the monitoring results must be reported to the state. Responsibility for the state’s Drinking Water Program was transferred from the Department of Public Health to the Division of Drinking Water, which is a division of the SWRCB that was created in July 2014.

California General Plan Law, Government Code Section 65302 Government Code Section 65302(a) requires cities and counties located within the State to review the Land Use, Conservation, and Safety elements of the general plan "for the consideration of flood hazards, flooding, and floodplains" to address flood risks. The code also requires cities and counties in the State to annually review the Land Use element with respect to "those areas covered by the plan that are subject to flooding identified by floodplain mapping prepared by FEMA or the California Department of Water Resources."
Sustainable Groundwater Management Act
In September 2014, Governor Brown signed legislation requiring that California’s critical groundwater resources be sustainably managed by local agencies. The Sustainable Groundwater Management Act (SGMA) gives local agencies the power to sustainably manage groundwater, provides for the creation of regional GSAs and requires Groundwater Sustainability Plans (GSP) to be developed for medium- and high-priority groundwater basins. The Kings Subbasin is a High Priority Basin; in response to creating the North Kings Groundwater Sustainability Agency (NKGSA), formed in December 2016. The NKGSA’s GSP was recommended for approval in March 2023 by the Department of Water Resources.

Cobey-Alquist Floodplain Management Act
The Cobey-Alquist Floodplain Management Act (Water Code Section 8400-8435) gives support to the National Flood Insurance Program (NFIP) by encouraging local governments to plan, adopt, and enforce land use regulations for floodplain management, to protect people and property from flooding hazards. The Act also identifies requirements that jurisdictions must meet to receive State financial assistance for flood control.

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California Green Building Standards Code
The California Green Building Standards Code (24 CCR, Part 11) includes mandatory measures for residential and nonresidential development. For example, Section 4.106.2 requires residential projects that disturb less than one acre and are not part of a larger common plan of development to manage stormwater drainage during construction through on-site retention basins, filtration systems, and/or compliance with a stormwater management ordinance. Section 5.106.1 requires newly constructed nonresidential projects and additions of less than one acre to prevent the pollution of stormwater runoff from construction through compliance with a local ordinance or implementing Best Management Practices (BMPs) that address soil loss and good housekeeping to manage equipment, materials, and wastes. Section 5.303 sets measures for indoor water use for non-residential development requiring metering devices to conserve water.

California Construction Stormwater Permit
The California Construction Stormwater Permit (Construction General Permit), adopted by the SWRCB, regulates construction activities that include soil disturbance of at least one acre of total land area. The Construction General Permit authorizes the discharge of stormwater to surface waters from construction activities. It prohibits the discharge of materials other than stormwater, authorized non-stormwater discharges, and all discharges that contain a hazardous substance in excess of reportable quantities established at 40 CFR 117.3 or 40 CFR 302.4, unless a separate NPDES Permit has been issued to regulate those discharges.

The Construction General Permit requires that all developers of land where construction activities will occur over more than one acre do the following:
 Complete a Risk Assessment to determine pollution prevention requirements pursuant to the three Risk Levels established in the General Permit.
 Eliminate or reduce non-stormwater discharges to storm sewer systems and other waters.  Develop and implement a Stormwater Pollution Prevention Plan (SWPPP) which specifies BMPs that will reduce pollution in stormwater discharges to the Best Available Technology Economically Achievable/Best Conventional Pollutant Control Technology standards.  Perform inspections and maintenance of all BMPs.

Typical BMPs contained in SWPPPs are designed to minimize erosion during construction, stabilize construction areas, control sediment and pollutants from construction materials, and address post construction runoff. The SWPPP also includes a plan for inspection and maintenance of all BMPs, as well as procedures for altering or increasing BMPs based on changing project conditions. c. Regional Regulations
Central Valley Regional Water Quality Control Board
Regional authority for planning, permitting, and enforcement is delegated to the nine RWQCBs. The regional boards are required to formulate and adopt water quality control plans for all areas in the region and establish water quality objectives in the plans. Clovis is within the jurisdiction of the CVRWQCB (Region 5) and specifically falls within the Tulare Lake Basin portion of Region 5.

The CVRWQCB Tulare Lake Basin addresses region-wide water quality issues through the Basin Plan, updated most recently in May 2018. This Basin Plan designates beneficial uses of the state waters in

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Region 5, describes the water quality that must be maintained to support such uses, and provides programs, projects, and other actions necessary to achieve the standards established in the Basin Plan.5
Fresno Metropolitan Flood Control District
The Fresno Metropolitan Flood Control District (FMFCD) manages stormwater and flood control infrastructure, provides local drainage services, supports development with engineering design, reviews drainage plans, and addresses stormwater impacts in environmental reviews. The district’s local storm water development drainage system consists of storm drains, detention and retention basins, and pump stations. The district’s Storm Drainage and Flood Control Master Plan includes 158 drainage areas, each providing service to approximately one to two square miles. All but five of the developed drainage areas are served by a retention or detention facility. Local drainage services include topographic mapping, Master Plan engineering and facility design; system construction, operation, and maintenance; and engineering design services to ensure adequate drainage for new development.6
d. Local Regulations
City of Clovis General Plan
Clovis’s General Plan was adopted in August 2014 and consists of Land Use, Economic Development, Circulation, Housing, Public Facilities and Services, Environmental Safety, Open Space and Conservation, and Air Quality Elements. The General Plan lists several goals, policies, and actions as part of each element.

Open Space and Conservation Element
The Open Space and Conservation Element seeks to protect and preserve open space, productive agricultural areas, and environmental resources. This element also establishes goals for the conservation and protection of the quality of water and energy resources. The overarching goal of the element is to create recreation and open space that enhances quality of life, contributes to a healthy community, and conserves Clovis’ natural and cultural resources. The element also works in coordination with other plans like the City of Clovis Parks Master Plan and the Urban Forest Management Plan.7
Environmental Safety Element
The Environmental Safety Element focuses the protection of the community from environmental and man-made hazards. The overarching goal of the element is creating a well-prepared community that understands and limits exposure to potential natural and human-made hazards and effectively responds to and recovers from public safety emergencies.8 5 California Regional Water Quality Control Board Central Valley Region. 2018. Water Quality Control Plan for the Tulare Lake Basin Third Edition. Available: https://www.waterboards.ca.gov/centralvalley/water_issues/basin_plans/tularelakebp_201805.pdf. Accessed May 2025.
6 Fresno Metropolitan Flood Control District. 2025. Development in Fresno/Clovis. Available:
https://www.fresnofloodcontrol.org/development-in-fresno-clovis/. Accessed June 2025. 7 City of Clovis. 2014. General Plan. Available:
https://www.clovisca.gov/services/planning_development/planning/general_plan/index.php. Accessed May 2025. 8 Ibid.

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Public Facilities and Services Element
The Public Facilities and Services Element defines the nature and types of public facilities, services, and activities necessary to maintain a high quality of life in Clovis. The overarching goal of the element is having a full range of high-quality public services that sustains Clovis as the preeminent community in the Central Valley.9
Clovis Municipal Code
The Clovis Municipal Code (CMC) establishes regulations that govern the City of Clovis. Title 4, Public Safety, of the CMC describes the City’s public safety standards and requirements to reduce hazards including hydrologic hazards. Chapter 6.7, Urban Storm Water Quality Management and Discharge Control, of Title 6, Sanitation and Health, of the CMC establishes development measures and requirements to reduce stormwater pollution, erosion, and other forms of water pollution.

Fresno County Local Hazard Mitigation Plan
The City of Clovis participates in the Fresno County Multi-Jurisdictional Hazard Mitigation Plan, which identifies local hazard risks and outlines mitigation strategies to reduce potential impacts to people, property, and infrastructure. The plan identifies dam failure, flooding, hazardous materials incidents, drought, and seismic activity as among the most significant hazards for the area. Clovis enforces a range of hazard-reduction policies through its General Plan Environmental Safety Element, zoning and subdivision ordinances, and floodplain management regulations. The City is a participant in the NFIP and coordinates with regional agencies such as the FMFCD and the North Kings Groundwater Sustainability Agency to manage flood and water supply risks. For infill development, the City requires compliance with its master drainage plan and site-specific review to ensure that new residential projects do not exacerbate flood risks or conflict with existing hazard mitigation infrastructure. Emergency preparedness is supported by the City’s Emergency Operations Plan and public outreach programs. These regulatory and planning frameworks help ensure that residential infill development is consistent with local hazard mitigation objectives and does not expose future residents to significant hazard-related risks.

4.8.3 Impact Analysis
a. Methodology and Significance Thresholds
Methodology
This section describes the potential environmental impacts of development facilitated by the project as relevant to hydrology, water quality, and flood risk. The impact analysis is based on an assessment of baseline conditions for the Infill Rezone Program, including surface water, groundwater, and floodplain information gathered from the City of Clovis, Fresno County, and multiple state and federal agencies, as described above under Section 4.8.1, Setting. This analysis identifies potential impacts based on the predicted interaction between the affected environment and construction, operation, and maintenance activities related to the development facilitated by the proposed project.
9 City of Clovis. 2014. General Plan. Available:
https://www.clovisca.gov/services/planning_development/planning/general_plan/index.php. Accessed May 2025.

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Significance Thresholds
The following thresholds of significance are based on Appendix G to the California Environmental Quality Act (CEQA) Guidelines. For the purposes of this EA, project implementation may have a significant adverse impact if it would:

Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality.

Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin.

Substantially alter the existing drainage pattern of the 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 result in substantial erosion or siltation on- or off-site.

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 substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site.

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 that would 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.

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 impede or redirect flood flows.

In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation.

Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.
b. Project Impacts and Mitigation Measures
Threshold 1: Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? Impact HYD-1 DEVELOPMENT FACILITATED BY THE PROJECT WOULD NOT VIOLATE WATER QUALITY

STANDARDS OR WASTE DISCHARGE REQUIREMENTS, OR OTHERWISE SUBSTANTIALLY DEGRADE SURFACE OR GROUNDWATER QUALITY. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Construction
Construction activities associated with development facilitated by the project would include demolition of existing structures, construction of new development, and the replacement and/or improvement of drainage facilities. Similar to existing conditions, construction activities could result in soil erosion due to earth-moving activities such as excavation, grading, soil compaction and moving, and soil stockpiling. Elevation and slope vary minimally throughout the City. Runoff during storm events typically occurs as sheet flow across the site, and the types of pollutants contained in runoff may include sediment and other existing contaminants such as nutrients, pesticides, herbicides, trace metals, and hydrocarbons that can attach to sediment and be transported

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downstream through erosion via overland flow, ultimately entering nearby waterways and contributing to degradation of water quality.

Similar to existing conditions, construction activities would utilize hazardous materials such as diesel fuel, gasoline, lubricant oils, hydraulic fluid, antifreeze, transmission fluid, cement slurry, and other fluids required for the operation of construction vehicles or equipment. These types of hazardous materials are not acutely hazardous, and storage, handling, use, and disposal of these materials are regulated by county, state, and federal regulations and compliance with applicable standards discussed under Regulatory Setting. Transport of these materials to and from construction sites would also be regulated under multiple authorities as discussed in Section 4.7, Hazards and Hazardous Materials.

Development facilitated by the proposed project would be required to comply with State and local water quality regulations designed to control erosion and protect water quality during construction, as discussed in Regulatory Setting, above. This includes compliance with the requirements of the SWRCB Construction General Permit, which requires preparation and implementation of a SWPPP for projects that disturb one acre or more of land. Grading and drainage plans accompanying the permit application must include BMPs for erosion prevention and sediment control, fencing at waterways and in sensitive areas, and limitation of disturbed areas through temporary features. The permit applications must also demonstrate compliance with NPDES MS4 permit provisions.

Compliance with existing regulations and policies discussed above would reduce the risk of water degradation from soil erosion and other pollutants related to construction activities. Because violations of water quality standards would be minimized through existing regulations, impacts to water quality from construction activities from development facilitated by the project would be less than significant.

Operation
Development facilitated by the project is likely to increase impervious surfaces throughout the Infill Rezone Program sites as most of the sites are currently vacant and would be developed as infill, with only few being developed or underdeveloped sites. The project is subject to the Fresno-Clovis Urban Area MS4 Permit (NPDES No. CA0083500), issued by the CVRWQCB Region 5, which includes post-construction stormwater management requirements. Compliance with these standards through the installation of the proposed stormwater basin and implementation of low-impact development (LID) features ensures that the project would not violate water quality standards or waste discharge requirements, nor would it substantially degrade surface or groundwater quality.

Therefore, the impact would be considered less than significant.

As described in Regulatory Setting, above, the post-construction requirements of the Region 5 MS4 Permit authorize permitting agencies to enforce BMPs that control operational stormwater runoff and protect water quality. Enforcement of post-construction BMPs required under the Region 5 MS4 Permit is carried out by the City Manager or their designated representatives, as authorized under CMC Chapter 6.7, Urban Storm Water Quality Management and Discharge Control. Title 6 of the CMC, establishes development measures and requirements to reduce stormwater pollution, erosion, and other forms of surface and ground water pollution.

Compliance with the various regulations and permit requirements such as those under the NPDES program and applicable Water Quality Control Plans like the Basin Plan helps reduce water quality impacts during both construction and operation of projects within the Clovis Region. Adherence to County or municipal General Plan policies further ensures that runoff and pollutants are managed

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effectively, preventing their discharge from Infill Rezone Sites. While these measures may not entirely eliminate water quality impacts for every individual project, they significantly reduce the potential for violations of water quality standards or waste discharge requirements. As a result, such impacts are considered less than significant.

Mitigation Measures
No mitigation measures are required.

Threshold 2: 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?
Threshold 8: Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Impact HYD-2 DEVELOPMENT FACILITATED BY THE PROJECT WOULD NOT INTERFERE SUBSTANTIALLY WITH

GROUNDWATER SUPPLIES OR RECHARGE SUCH THAT THE PROJECT MAY IMPEDE WATER QUALITY CONTROL PLAN SUSTAINABLE GROUNDWATER MANAGEMENT OF LOCAL GROUNDWATER BASINS. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Clovis's water supply comes from two sources; imported water from the Kings River and groundwater. As described in Setting, above, the CVRWQCB is the primary agency responsible for protecting and enhancing surface and groundwater quality for the City of Clovis. Clovis is within the jurisdiction of the CVRWQCB (Region 5) and specifically falls within the Tulare Lake Basin portion of Region 5. The Tulare Lake Basin is considered a high priority under SGMA and is required to develop a GSP.

Development facilitated by the proposed project could increase the demand for water within the city. However, the city’s commitment to water efficiency through conservation measures, programs, and adherence to state and federal regulations positions allows for the accommodation of an increased demand if necessary. A Water Supply Assessment (WSA) was completed for the proposed project and prepared by Provost & Pritchard Consulting Group in May 2025 and the analysis confirms that the city has sufficient water resources to meet this increased demand without substantially depleting groundwater supplies or interfering with groundwater recharge. The WSA estimates an increase of 104.63 acre-feet per year (AFY) in water demand, which represents only

0.65 percent of the city’s projected excess supply in 2030 under normal year conditions (Appendix E). As of 2025, the City of Clovis has the capacity to treat and deliver up to 22.5 million gallons per day of potable water with planned infrastructure to expand that to 45 million gallons per day when needed.
10 The City of Clovis anticipates significant population growth, from approximately 122,350 in 2020 to 178,109 by 2040. To meet this demand, the city plans to rely on a diversified water portfolio including the Kings Subbasin, Kings River and Central Valley Project, recycled water, and banked water.
11 The 2020 Urban Water Management Plan (UWMP) Update projects the City’s water supply can keep pace with the growing demand for water use with the projected growth in population, as shown in Table 4.8-1. The City of Clovis’s Water Supply Assessment, prepared as part of its 2020 UWMP confirms that the City has sufficient water resources to meet projected demands 10 City of Clovis. 2025. Water. Available: https://www.clovisca.gov/services/public_utilities/water/index.php. Accessed May 2025 11 City of Clovis. 2021. Urban Water Management Plan 2020 Update. Available:
https://cms2.revize.com/revize/clovis/documents/Services/Public%20Utilities/Water/2020-UWMP-Adopted-July-2021_reduced.pdf.

Accessed May 2025

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through 2040 and beyond. The city relies on a diversified water portfolio that includes groundwater from the Kings Subbasin, surface water from the Kings River via the Enterprise Canal, recycled water, and banked water. The Clovis Surface Water Treatment Plant currently provides up to 22.5 million gallons per day (MGD) of potable water, with infrastructure in place to expand capacity to 45 MGD as needed.12
Table 4.8-1 2020 UWMP City Growth Projections
Growth Characteristic 2020 Existing Population Estimate 2040 Population Forecast Difference Citywide Population 122,350 178,109 45.6%
According to the 2020 UWMP, the City of Clovis had a service area population of approximately 122,350 in 2020. Over the 20-year planning horizon, the population by 2040 is projected to increase to 178,109, representing a growth of approximately 45.6 percent.13 The additional 1,303 units proposed in the project’s Infill Rezone Program would increase the City’s population by approximately 3,662 new residents. The maximum potential unit increase is 1,651, leading to a maximum potential population increase of 4,640 residents. In this maximum scenario the population could increase from 129,121 current residents to 133,761 residents, which remains at 45 percent of the City’s total buildout capacity of 294,300. 14 The potential additional 4,640 residents
that could result from future housing development in the Infill Rezone Program would only make up

1.6 percent of the overall buildout capacity. Therefore, the population increase associated with the project would remain well within the 2040 forecast established in the UWMP, which demonstrates that the City has sufficient water supplies to support this growth. As such, the project would result in a less than significant impact on water resources.

It is important to note that the City of Clovis maintains a diversified water supply portfolio, including surface water, recycled water, and groundwater recharge, and has committed to sustainable groundwater management under SGMA. Additionally, the City of Clovis is located within the jurisdiction of the CVRWQCB, which administers the Water Quality Control Plan for the Tulare Lake Basin (Basin Plan). This plan identifies beneficial uses of water resources and establishes water quality objectives to protect those uses. The Clovis stormwater infrastructure effectively manages stormwater and urban runoff while promoting groundwater recharge. Stormwater flows into storm drain inlets and is directed through a network of pipes to nearby ponding basins. These basins protect neighborhoods from flooding and allow water to infiltrate the ground, replenishing the groundwater aquifer, which is a primary source of drinking water for the community.15 This system not only mitigates flooding but also supports sustainable water management by enhancing groundwater recharge. The proposed project would be required to comply with all applicable state and local water quality standards. Therefore, with adherence to these regulatory frameworks, the project is not anticipated to adversely affect water quality or conflict with the objectives of the Basin Plan.
12 Clovis, City of. 2022. Water Supply Assessment. Available: https://files.ceqanet.lci.ca.gov/284041- 1/attachment/gDuLMfphVf0CVi4YLFaTxWXwlFzitTVx4MCkw3XPL1aBFVntkQPWFjBmrJLt9ZOPUYPcyNKKb8oFGlE50. Accessed October 2025.
13 Ibid.
14 Clovis, City of. 2014. General Plan and Development Code Update Draft PEIR. Available:
https://cms2.revize.com/revize/clovis/documents/Services/Planning%20Development/Planning/General%20Plan/Environmental%20Imp act%20Report/VolumeIII_FinalEIR.pdf?t=202507181313090&t=202507181313090. Accessed May 2025. 15 Fresno Metropolitan Flood Control District. 2025. Development in Fresno/Clovis. Available:
https://www.fresnofloodcontrol.org/development-in-fresno-clovis/. Accessed June 2025.

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Implementation of existing local regulations and policies would ensure that development facilitated by the proposed project would not interfere substantially with groundwater recharge or conflict with implementation of water quality control plan or sustainable groundwater management plan, and impacts would be less than significant.

Mitigation Measures
No mitigation measures are required.

Threshold 3: Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would result in substantial erosion or siltation on- or off-site?
Threshold 4: Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site?
Threshold 5: Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner that would 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? Threshold 6: Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would impede or redirect flood flows?
Impact HYD-3 DEVELOPMENT UNDER THE PROJECT WOULD NOT SUBSTANTIALLY ALTER THE EXISTING

DRAINAGE PATTERN OF FUTURE DEVELOPMENT SITES, INCLUDING THROUGH THE ALTERATION OF THE COURSE OF A STREAM OR RIVER, IN A MANNER WHICH WOULD RESULT IN SUBSTANTIAL EROSION OR SILTATION ON- OR OFFSITE OR SUBSTANTIALLY INCREASE THE RATE OR AMOUNT OF SURFACE RUNOFF IN A MANNER WHICH WOULD RESULT IN FLOODING OR EXCEED THE CAPACITY OF STORMWATER DRAINAGE SYSTEMS. IMPACTS RELATED TO DRAINAGE PATTERNS WOULD BE LESS THAN SIGNIFICANT.

Construction
Construction activities would involve grading, excavation, dredging, paving, and other earthdisturbing activities that could temporarily alter existing drainage patterns. As described above, compliance with SWRCB’s NPDES Construction General Permit. Local alteration of drainage at individual Infill Rezone Program sites from development facilitated by the proposed project may occur, but such drainage alteration would be considered prior to grading or permit approval, would be required to connect to the existing storm drainage system, and no alteration of the course of streams or creeks would occur. Therefore, impacts would be less than significant.

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Operation
Development facilitated by the project may alter the existing drainage patterns within proposed Infill Rezone Program sites through introduction of new impervious surfaces and infrastructure, such as driveways, roofs, and patios, as well as new downspout outflows from residential rain gutters and new runoff from landscaping irrigation. These alterations could increase the rate and/or amount of surface runoff, redirect runoff to different discharge locations, or concentrate runoff from sheet flow to channelized flow. Runoff that does not infiltrate and flows off site would be captured in the local storm drain systems into recharge basins.

Threshold 1 discusses applicable regulations that would limit pollutant discharges, including sediment and silt, from the proposed project. As discussed above, multiple layers of regulations require development facilitated by the project to reduce and eliminate stormwater pollutants, as well as implementation of BMPs to control pre-construction operational stormwater runoff. In particular, Clovis General Plan and CMC policies requiring adherence to the NPDES Permit as a condition of grading and use permit approval will work to enforce compliance with all relevant standards and regulations.

The Clovis General Plan goals and policies are intended to reduce flood hazards and overwhelming of the drainage system, such as Environmental Safety Element Policies 1.1 and 1.5 and Public Facilities and Services Element Policies 1.6 and 1.4, which would mandate all new development be consistent with the current stormwater master plan and allows the City to require developments to install stormwater facilities beyond their fair share, with a reimbursement mechanism for excess costs. In coordination with FMFCD, which is responsible for regional stormwater and flood control infrastructure, the City ensures that stormwater management systems are adequately planned and maintained. Implementation of these goals and policies, along with FMFCD’s oversight, would ensure that the runoff from development facilitated by the project does not exceed the capacity of existing and future storm drain systems. Thus, impacts would be less than significant.

The proposed project would not alter the existing drainage patterns or contribute runoff water in a manner which would result in substantial erosion, siltation, or flooding, nor would it exceed the capacity of existing or planned stormwater drainage systems or result in substantial additional polluted runoff. Thus, impacts would be less than significant.

Mitigation Measures
No mitigation measures are required.

Threshold 7: In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?
Impact HYD-4 DEVELOPMENT INCLUDED UNDER THE PROPOSED PROJECT WOULD NOT PLACE HOUSING AND OTHER STRUCTURES WITHIN FEMA-DESIGNATED FLOOD HAZARD AREAS AND TSUNAMI ZONES. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Clovis is separated from the Pacific Ocean by a coastal mountain range that would not be impacted by a tsunami and does not contain large surface water bodies that would result in seiches. There are FEMA-designated 100-year Flood Hazard Areas throughout city limits, however, according to the Clovis General Plan Environmental Safety Element, Policy 1.1 (Flood Zone) prohibits development within the 100-year flood zone and dam inundation areas unless adequate mitigation is provided

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against flood hazards.16 The City of Clovis and surrounding area are not within a Tsunami Hazard Area. Therefore, there are no proposed Infill Rezone Program sites within a flood hazard, tsunami, or seiche zone. Impacts would be less than significant.

Mitigation Measures
No mitigation measures are required.

4.8.4 Cumulative Impacts
A project’s environmental impacts are “cumulatively considerable” if the “incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects” (CEQA Guidelines Section 15065(a)(3)). The geographic scope for cumulative hydrology and water quality impacts is the extent of the watersheds located in Clovis, as described above in Section 4.8.1, Setting. This geographic scope is appropriate for hydrology and water quality because water quality impacts are localized in the watershed where the impact occurs.

As discussed throughout this analysis, development facilitated by the proposed project would increase the demand for water, which is supplied through imported and ground water. Any project associated with new residential development would be subject to project-specific environmental review and mitigation pursuant to CEQA. It is anticipated that the City’s review processes would adequately mitigate potential environmental impacts related to the construction and occupancy of new housing units. Cumulative development would not result in a significant cumulative impact with the implementation of each development project. The project’s impacts to groundwater supplies and groundwater management efforts would be less than significant as it is within the planned population growth of Clovis and therefore within its planned water usage. Therefore, the project would not have a cumulatively considerable contribution to a significant cumulative impact related to groundwater as it would comply with applicable water conservation measures, groundwater management plans, and regional sustainability goals and is within the planned projected water usage for the city.

Cumulative development would generally increase impermeable surface area and increase runoff into the Kings subbasin watershed. Development would potentially increase peak flood flows, alter drainage patterns, and increase pollutants in stormwater. However, cumulative development would also be required to adhere to all applicable State and local regulations designed to control erosion and protect water quality, including the CMC, NPDES Construction General Permit and MS4 General Permit, FMFCD and Basin Plan policies. All construction sites larger than one acre in size would be required to prepare and submit a SWPPP, thereby reducing the risk of water degradation on and off site from soil erosion and other pollutants, and smaller developments would still be required to adhere to any permit requirements imposed by the applicable policies and ordinances discussed under Impacts HYD-1 through HYD-4, above.

As discussed above under Impacts HYD-1 through HYD-4, development facilitated by the proposed project would increase impervious surface areas. However, compliance with relevant water quality regulations, BMPs, and policies would reduce the risk of water degradation from soil erosion and other pollutants related to construction and operational activities. Construction and operation of development facilitated by the project would not violate any water quality standards or Waste 16 City of Clovis. 2014. General Plan. Available:
https://www.clovisca.gov/services/planning_development/planning/general_plan/index.php. Accessed May 2025.

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Discharge Requirements or otherwise substantially degrade water quality. The project’s water quality and groundwater recharge impacts would be less than significant. Development facilitated by the proposed project would comply with NPDES, MS4, and City requirements related to stormwater runoff and water quality and consequently would not contribute to cumulative impacts to peak runoff, flooding, groundwater recharge, or water quality. Therefore, the project would not have a cumulatively considerable contribution to a significant cumulative impact related to water quality.

As discussed under Impact HYD-4, Clovis is located within the 100-year flood hazard area. However, the city prohibits development within the 100-year flood zone and dam inundation areas unless adequate mitigation is provided against flood hazards. Clovis is not within a zone at risk of inundation by flood or seiche and therefore are not at risk of release of pollutants due to inundation. Projects would be analyzed and mitigated on a case-by-case basis and would be designed to avoid or mitigate potential impacts related to flooding. Cumulative impact related to flooding or seiche would therefore be less than significant. As discussed under Impact HYD-4, development facilitated by the proposed project would not impede or redirect flood flows or risk release of pollutants due to inundation. Projects would be required to adhere to all applicable building and fire codes, zoning requirements, and design standards related to flood flows and project inundation. Impacts would be less than significant. The proposed project would not have a cumulatively considerable contribution to a significant cumulative impact related to flood hazard or inundation risks in the greater watershed or groundwater basin. Therefore, cumulative impacts to hydrology and water quality would be less than significant.

Mitigation Measures
No mitigation measures are required.

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Environmental Assessment 4.9-1

4.9 Land Use and Planning
This section of the Environmental Assessment (EA) analyzes the consistency of the proposed rezoning of 20 infill parcels and land use designation amendments with applicable land use plans, policies, and regulations adopted for the purpose of avoiding or mitigating environmental effects and identifies environmental effects that would arise from such inconsistencies.

4.9.1 Setting
a. Existing Land Uses
The project is composed of urban and rural residential and agricultural uses, with a majority of the project falling in low density residential, medium density residential, and rural residential land use designations. The City of Clovis encompasses approximately 18,066 acres (28 square miles), and is comprised of a number of land uses, with agricultural, rural residential, and single-family residential making up the majority as shown in Figure 4.9-1. Figure 4.9-2 shows the existing Zoning in the city.

Commercial and industrial uses are found primarily along the City’s major corridors (e.g., Shaw, Clovis, and Herndon Avenues). Table 4.9-1 lists the proposed Infill Rezone Program sites’ existing land use and zoning designations.

Table 4.9-1 Existing Land Use Designations and Zoning
Site ID* APN Address
Existing General Plan Land Use
Designation
Existing Zone
District
3 49102042 270 W Herndon Ave GC P-C-C
63 56303207 1933 Alluvial Ave L R-1-7500
72 56008207 437 W Nees Ave L R-1-7500
108 49123124 125 & 135 N Clovis Ave GC C-2
110 49906074 236 & 256 W Santa Ana Ave M R-1
115 55457044S 1671 Leonard Ave M R-1
157 55803359S De Wolf & Richmond Ave MU-V P-C-C
161 43043316 2930 Willow Ave O C-P
167 55128004 1871 Shaw Ave O C-P
168 55128003 1853 Shaw Ave O C-P
197 55849230 1497 N Locan Ave VL R-1-AH
217 49954013ST 885 Gettysburg Ave I M-1
589 55026023 2403 Bullard Ave L R-A
590 55458036S 3959 Shaw Ave M R-1
592 56303131 1160 N Fowler Ave L R-A
595 49817202 939 & 947 Sunnyside Ave L R-1
596 49817201 965 & 975 Sunnyside Ave L R-1
597 49817203 925 Sunnyside L R-1
598 49938442 2560 Fowler Ave L R-1
599 49938441 2612 Fowler Ave L R-1

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Figure 4.9-1 Existing Land Uses in Clovis

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Figure 4.9-2 Existing Zoning in Clovis

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4.9.2 Regulatory Setting
State, regional and local laws, regulations, plans, or guidelines that are potentially applicable to the project are summarized below. There are no federal regulations that are applicable to this section. a. State Regulations
California Housing Element Law
California Housing Element law (Government Code Sections 65580 to 65589.8) includes provisions related to the requirements for housing elements of local government General Plans. Among these requirements are an assessment of housing needs and an inventory of resources and constraints relevant to meeting these needs. Additionally, to assure that counties and cities recognize their responsibilities in contributing to the attainment of the State housing goals, this section of the Government Code calls for local jurisdictions to plan for, and facilitate the construction of, their fair share of the region’s projected housing needs, known as the Regional Housing Needs Allocation (RHNA). The City of Clovis adopted its 6th cycle 2023-2031 Housing Element on December 17, 2024.

To accommodate the 4th cycle Housing Element RHNA goal for lower income households as stated in Chapter 2, Project Description, the rezoning of 20 infill properties is necessary to provide sufficient housing development on sites that are adequate for accommodating lower income households.

General Plan Law (California Government Code Section 65300) California Government Code Section 65300 regulates the substantive and topical requirements of general plans. State law requires that each city and county adopt a general plan “for the physical development of the county or city, and any land outside its boundaries which bears relation to its planning.” The California Supreme Court has called the general plan the “constitution for future development.” The general plan expresses the community’s development goals and embodies public policy relative to the distribution of future land uses, both public and private.

Planning and Zoning Law
State law requires each city and county in California to adopt a general plan for the physical development of the land within its project area (Government Code Sections 65300-65404). The general plan must contain land use, housing, circulation, open space, conservation, noise, and safety elements, plus air quality for Valley cities, as well as any other elements that the city or county may wish to adopt. The circulation element of a local general plan must be correlated and consistent with the land use element.

Zoning authority originates from city and county police power and from the State’s Planning and Zoning Law, which sets minimum requirements for local zoning ordinances. The city or county zoning code is the set of detailed requirements that implement the general plan policies at the level of the individual parcel. The zoning code presents standards for different uses and identifies which uses are allowed in the various zoning districts of the jurisdiction. Since 1971, State law has required the city or county zoning code to be consistent with the jurisdiction’s general plan.

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California Complete Streets Act (Assembly Bill 1358)
On September 30, 2008, Assembly Bill (AB) 1358, the California Complete Streets Act, was signed into law and became effective January 1, 2011. AB 1358 places the planning, designing, and building of complete streets into the larger planning framework of the general plan by requiring jurisdictions to amend their circulation elements to plan for multimodal transportation networks.

Sustainable Communities and Climate Protection Act (Senate Bill 375) The Sustainable Communities and Climate Protection Act (Senate Bill (SB) 375) supports the State's climate goals by helping reduce greenhouse gas emissions through coordinated transportation, housing, and land use planning. Under the Act, the California Air Resources Board (CARB) set targets for 2020 and 2035 for each of the 18 metropolitan planning organization regions in 2010 and updated them in 2018. Each of the regions must prepare a Sustainable Community Strategy (SCS), as an integral part of its regional transportation plan, which contains land use, housing, and transportation strategies that, if implemented, would allow the region to meet CARB’s air quality targets. The Act establishes some incentives to encourage implementation of the development patterns and strategies included in a SCS. Developers can get relief from certain environmental review requirements under the California Environmental Quality Act (CEQA) if their new residential and mixed-use projects are consistent with a region’s SCS that meets the targets1 .
b. Regional and Local Regulations
Fresno Council of Governments
The Fresno Council of Governments (COG) represents the cities of Clovis, Coalinga, Firebaugh, Fowler, Fresno, Huron, Kerman, Kingsburg, Mendota, Orange Cove, Parlier, Reedley, San Joaquin, Sanger, and Selma, and the County of Fresno. Fresno COG is the federally recognized metropolitan planning organization (MPO) for this region. Fresno COG fosters intergovernmental communication and coordination, undertakes comprehensive regional planning with an emphasis on transportation, provides for citizen involvement in the planning process, and supplies technical services to its member governments. Fresno COG’s primary functions are transportation planning and programming.

As the region’s MPO, Fresno COG cooperates with other COGs in the valley, San Joaquin Valley Air Pollution Control District, California Department of Transportation (Caltrans), and other agencies in preparing regional planning documents. Fresno COG has developed regional plans to achieve specific regional objectives. The plan most applicable to the project is discussed below.

Regional Transportation Plan/Sustainable Communities Strategy Fresno COG has adopted a Regional Transportation Plan (RTP) to help coordinate development of the region’s transportation improvements over the next 20 years. On July 28, 2022, Fresno COG adopted the 2011 Regional Transportation Plan: Long-Range Transportation Vision for the Fresno County Region for 2022 to 2046. The RTP guides how and where people and goods will travel by identifying both existing and needed transportation facilities, and sets policies for a wide variety of transportation options and projects based on available and projected funding.

The RTP and SCS will continue addressing the region’s mobility needs through a long range vision towards 2046. The document is organized into chapters and addresses public participation, 1 California Public Resources Code Sections 21155, 21155.1, 21155.2, 21159.28

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environmental justice, sustainable communities strategy, and an action plan. New requirements for reducing greenhouse gas emissions from transportation sources under SB 375 are integrated into the development of the latest RTP/SCS.

San Joaquin Valley Blueprint
Rising to meet the San Joaquin Valley’s most pressing issues, the eight MPOs (including Fresno COG) representing the eight counties in the San Joaquin Valley initiated the San Joaquin Valley Regional Blueprint (Valley Blueprint) planning process in 2006 to develop and help implement a vision for growth in the valley to the year 2050. The Valley Blueprint is a vision for the future of the San Joaquin Valley, in which less land is consumed for development, more resources are preserved for future generations, distinctive communities are enhanced, and more travel choices are available. On April 1, 2009, the San Joaquin Valley Regional Policy Council, the decision-making body for the valley wide process, approved Scenario B+ and the 12 Smart Growth Principles and Preferred Growth Scenario, concluding the third year of the Valley Blueprint planning process and setting the stage for the transition to the implementation phase of the Valley Blueprint, which began soon after in 2009.

Scenario B+ was adopted as the Preferred Blueprint Growth Scenario for the San Joaquin Valley to the year 2050. This preferred scenario serves as guidance for the valley’s local jurisdictions with land use authority as they update their general plans. The 12 Smart Growth Principles represent the core values of the valley and are being used as the basis of future Blueprint planning and implementation. While each COG developed its own goals, objectives, and guiding principles, the 12 Smart Growth Principles were intended to reflect a regional perspective. The 12 Smart Growth Principles establish a benchmark for Blueprint-related decision making and provide guidance for achieving the Valley Blueprint.

Fresno Yosemite International Airport Land Use Compatibility Plan In 1997, the Airport Land Use Commission (ALUC) of Fresno County adopted the Fresno Yosemite International Airport and Environs Plan. Subsequently, in June 2012, ALUC amended the existing plan and renamed it the Airport Land Use Compatibility Plan (ALUCP). The Clovis City Council adopted the ALUCP on December 12, 2018, and it went into effect on December 12, 2018. The ALUCP is a land use compatibility plan that is intended to protect the public from adverse effects of aircraft noise, to ensure that people and facilities are not concentrated in areas susceptible to aircraft accidents, and to ensure that no structures or activities adversely affect navigable space.

The ALUCP identifies standards for development in the airport’s project area based on noise contours, safety zones, and building heights. ALUC is authorized under state law to assist local agencies in ensuring compatible land uses in the vicinity of airports. Primary areas of concern for ALUC are noise, safety hazards, and airport operational integrity.

The Fresno Yosemite International Airport is just outside the city’s southwestern boundary. A small portion of the southwestern boundary is within the Airport Influence Area (AIA) of the Fresno Yosemite International Airport. Portions of the southwestern boundary also fall within Zone 6 of the safety compatibility and noise contour zones of this airport.

City of Clovis General Plan
The current General Plan was last comprehensively updated in 2014. The General Plan functions as a guide for future development and city land use decisions. The General Plan is a “constitution” for local decision making that addresses the range of immediate, mid- and long-term issues with which the community is concerned, including but not limited to environmental sensitivity and

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preservation, public services, public safety, local transportation needs, sustainability, housing, and economic vitality. The 2014 General Plan is intended to allow land use and policy determinations to be made within a comprehensive framework that incorporates public health, safety, and quality of life considerations in a manner that recognizes that resource limitations and the fragility of the community’s natural environment. Policies from the Land Use Element, Circulation Element, Open Space and Conservation Element, and Housing Element would be most applicable to the project.

The action items presented in the Infill Rezone Program, as discussed further in Chapter 2, Project Description, require the rezoning and land use designation amendment of 20 Infill Rezone Program sites. The following are policies from the relevant General Plan Elements that would be applicable to the project.

Land Use Element
 Policy 3.6 Mix of Housing Types and Sizes. Development is encouraged to provide a mix of housing types, unit sizes, and densities at the block level. To accomplish this, individual projects five acres or larger may be developed at densities equivalent to one designation higher or lower than the assigned designation, provided that the density across an individual project remains consistent with the General Plan.
 Policy 3.8 Land Use Compatibility. Within Urban Centers, new development that is immediately adjacent to properties designated for rural residential and agricultural uses shall bear the major responsibility of achieving land use compatibility and buffering.  Policy 5.1 Housing Variety in Developments. The Clovis General Plan has been planned to provide a variety of housing product types suitable to each stage of a person’s life. Each development should contribute to the sizes and types within the standards appropriate to the land use designation. This policy does not apply to projects smaller than five acres.

Circulation Element
 Policy 1.4 Jobs and Housing. Encourage infill development that would provide jobs and services closer to housing, and vice versa, to reduce citywide vehicle miles traveled and effectively utilize the existing transportation infrastructure.
 Policy 3.2 Neighborhood Compatibility. Periodically review and update design standards to ensure that new and redesigned streets are compatible with the context of adjacent neighborhoods.

Open Space and Conservation Element
 Policy 1.1 Parkland Standard. Provide a minimum of 4 acres of public parkland for every 1,000 residents.

Housing Element
 Policy H-1.1 Housing Production Target. Maintain an adequate supply of appropriately zoned land to support the production of at least 8,977 housing units in Clovis between 2023 and 2031 to accommodate the local and regional housing needs.
 Policy H-1.2 Remove Barriers to Housing Production. Work to ensure that local policies and standards do not unreasonably constrain the production of affordable housing units.

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 Policy H-2.6 No Net Loss of Housing Stock. Ensure that sites being redeveloped for housing do not result in a net reduction in housing units, consistent with Government Code Section 66300(d).

City of Clovis Municipal Code
The City of Clovis Municipal Code establishes regulations that implement the City’s General Plan.

Title 9, Development Code, regulates the distribution and intensity of land uses in such categories as residential, commercial, and industrial. Regulations establish minimum lot size; building height and setback limits; fence heights; parking; and other development parameters within each land use.

City of Clovis Specific Plans and Master Plans
The City of Clovis contains several specific plans and master plans aimed at providing specific design and policy guidelines for communities throughout the city. Implications for the proposed rezones are analyzed by the goals and policies of the following adopted master and specific plans:
 Harlan Ranch Master Plan
 Heritage Grove Master Plan and Design
Guidelines
 Home Place Master Plan
 Loma Vista Community Center Master Plan
 Parks Master Plan
 Heritage Grove City Center Village Master Plan
 Dry Creek Preserve Master Plan
 Central Clovis Specific Plan
 Herndon-Sheperd Specific Plan
 Loma Vista Specific Plan
 Shaw Avenue Specific Plan
 Urban Greening Master Plan

4.9.3 Impact Analysis
a. Methodology and Significance Thresholds
Methodology
The analysis in this section focuses on the compatibility of land uses identified in the project with existing and planned land uses within Clovis, as well as consistency with any applicable land use plans, policies, or regulations.

Significance Thresholds
In accordance with Appendix G of the California Environmental Quality Act (CEQA) Guidelines, an impact related to land use and planning would be significant if the proposed project would:

1. Physically divide an established community

2. 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

Environmental Impact Analysis
Land Use and Planning
Environmental Assessment 4.9-9
b. Project Impacts and Mitigation Measures
Threshold 1: Would the project physically divide an established community? Impact LU-1 THE PROJECT INVOLVES IMPLEMENTING A REZONING PROGRAM ON 20 SITES, MAINLY IN DEVELOPED AREAS OF THE CITY, AND WOULD NOT PHYSICALLY DIVIDE AN ESTABLISHED COMMUNITY.

THEREFORE, THIS IMPACT WOULD BE LESS THAN SIGNIFICANT.

Threshold 2: 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?
Impact LU-2 THE PROJECT WOULD NOT RESULT IN A SIGNIFICANT ENVIRONMENTAL IMPACT DUE TO A

CONFLICT WITH ANY LAND USE PLAN AND POLICY OR REGULATION ADOPTED FOR THE PURPOSE OF AVOIDING OR MITIGATING AN ENVIRONMENTAL EFFECT. THEREFORE, THIS IMPACT WOULD BE LESS THAN SIGNIFICANT.

As set forth by State law, the General Plan serves as the primary planning document for the City and all subordinate documents and plans are required to be consistent with the General Plan. The project would amend the City of Clovis General Plan Land Use Element by allowing for higher density housing on 20 Infill Rezone Program sites throughout the city to facilitate affordable housing development. This change in density, upon approval, will be consistent with City land use plans and would not be in conflict with land use policies or regulations that mitigate environmental effects.

The project would involve the Infill Rezone Program that would allow for approximately 1,303 housing units in accordance with the Judgment, and up to a maximum of 1,651 housing units. The project would not involve any actual physical development. The project aims to rezone and redesignate parcels that are within infill areas and are mostly surrounded by existing developed parcels. The rezoning and land use changes of these sites would not result in the construction of barriers, such as new roads, that would divide the existing communities surrounding the Infill Rezone Program sites, as there is existing roads and infrastructure serving these areas.

The project is designed to support the city in meeting its low-income RHNA target and would promote higher density development in vacant, underdeveloped, or underutilized properties, thereby locating people closer to existing employment, goods and services within an established community. Of the Infill Rezone Program sites, nine sites are currently vacant, nine are used for residential, and two are used for commercial. Increased density throughout the city, as indicated in the City General Plan, would help create more unified, cohesive neighborhoods as future development occurs.

While the project would not introduce development directly, the rezoning and land use changes of 20 sites would result in future higher density development that could require some utilities and infrastructure improvements. This would potentially result in a temporary limit on access to isolated areas during construction; however, the project would not exceed the City’s population and housing projections as discussed in Section 4.11, Population and Housing, and would not require an unplanned demand for infrastructure and utility improvements that may divide an established neighborhood. Therefore, impacts would be less than significant.

Mitigation Measures
No mitigation measures are required.

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The project would facilitate higher density development; however, it would not exceed the buildout projections described in the General Plan, as discussed in Section 4.11, Population and Housing. The project plans to rezone and redesignate 20 sites, which would introduce up to 1,651 new housing units and 4,640 new residents, for a total of 133,761 Clovis residents after the project. This increase in population would require additional resources and potential land use changes in the future; however, Land Use Policy 1.2 states that the City shall be open to potential changes in land use, circulation, and development standards to reposition areas identified in the Land Use Map if necessary for revitalization and redevelopment, which aligns with the project’s housing goals and growth projections.

While the project would not introduce development, future development allowed by the project would be reviewed for consistency with the City’s development standards set forth in the City of Clovis Municipal Code as part of the design review process. The project would not remove or modify any policies or measures from the General Plan that are intended for environmental protection and would not conflict with any General Plan policies or measures that are intended for environmental protection.

Therefore, the project would not cause a significant environmental impact due to conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect, and potential impacts would be less than significant.

Mitigation Measures
No mitigation measures are required.

4.9.4 Cumulative Impacts
A project’s environmental impacts are “cumulatively considerable” if the “incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects”2 . The geographic
scope for cumulative land use and planning impacts includes the geographic area of the City of Clovis. Development that is considered part of the cumulative analysis includes buildout of the City’s General Plan.

Cumulative land use and planning impacts, such as the potential for conflicts with adjacent land uses and consistency with adopted plans and regulations, are typically site- and project-specific.

Subsequent projects allowed by the project may result in site-specific land use conflicts. However, because the exact size and nature of future developments and associated infrastructure improvements are not known at this time, it would be speculative to predict when impacts may occur. The project would not include any features that would physically divide an established community, and as such, would not contribute to cumulative impacts.

The project would remain consistent with the General Plan land use goals, as well as the Housing Element’s planned growth and RHNA target. Additionally, these projects would generally reduce motor vehicle trips, trip lengths, and associated environmental impacts by increasing housing development for a larger population near transit, jobs, services, and open spaces. Because the project’s impacts related to land use compatibility and consistency with local plans would be less than significant, the project’s contribution to cumulative land use impacts would be less than significant.
2 CEQA Guidelines Section 15065[a][3]

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Land Use and Planning
Environmental Assessment 4.9-11
Mitigation Measures
No mitigation measures are required.

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Environmental Impact Analysis
Noise
Environmental Assessment 4.10-1

4.10 Noise
This section analyzes noise-related impacts associated with development facilitated by the project, including temporary and permanent increases in ambient noise levels, the generation of groundborne vibration or noise, and the exposure of workers or residents to excessive airport noise.

Transportation data used in this section for both existing conditions and buildout of the proposed project were provided by Kittelson (Transportation Analysis) prepared for the proposed project in June 2025.

4.10.1 Setting
Noise Overview
Sound is a vibration that transmits through a medium (such as a gas, liquid, or solid) created by a moving or vibrating source, which is capable of being detected by the hearing organs. Noise is defined as sound that is loud, unpleasant, unexpected, or undesired and may therefore be classified as a more specific group of sounds.

Noise levels are commonly measured in decibels (dB) using the A-weighted sound pressure level (dBA). The A-weighting scale is an adjustment to the actual sound pressure levels so that they are consistent with the human hearing response, which is most sensitive to frequencies around 4,000 hertz (Hz) and less sensitive to frequencies around and below 100 Hz (Kinsler, et al. 1999). Decibels are measured on a logarithmic scale that quantifies sound intensity in a manner similar to the Richter scale used to measure earthquake magnitudes. A doubling of the energy of a noise source, such as the doubling of vehicle traffic volumes, results in a noise level increase of three dB, whereas dividing the energy in half results in a three dB decrease. 1 Human perception of noise has no simple correlation with sound energy, i.e., the perception of sound is not linear in terms of dBA or in terms of sound energy. Two sources, each containing the same sound energy, do not “sound twice as loud” as one source. It is widely accepted that the average healthy human ear can detect changes (either increases or decreases) of three dBA, which is recognized as being barely perceptible to most people. Similarly, a change of five dBA is readily perceptible and a change of 10 dBA sounds twice (or half) as loud. 2 Descriptors
The impact of noise is not a function of loudness alone. The time of day when noise occurs, and the duration of the noise are also important. In addition, most noise that lasts for more than a few seconds is variable in its intensity. Consequently, a variety of noise descriptors has been developed.

The noise descriptors used in this analysis are the equivalent continuous noise level (Leq) and the maximum noise level (Lmax). The Leq is defined as the single steady A-weighted level that is equivalent to the same amount of energy as that contained in the actual fluctuating levels over a period of time. Typically, Leq is equivalent to a one-hour period, even when measured for shorter durations as the noise level of a 10- to 30-minute period would be the same as the hour if the noise source is relatively steady. Lmax is the highest Root Mean Squared (RMS) sound pressure level within the sampling period.
1 Crocker, Malcolm J. (Editor). 2007. Handbook of Noise and Vibration Control Book, ISBN: 978-0-471-39599-7, Wiley-VCH, October. 2 Ibid.

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Propagation
Sound from a small, localized source (approximating a “point” source) radiates uniformly outward as it travels away from the source in a spherical pattern, known as geometric spreading. The sound level decreases or drops off at a rate of six dBA for each doubling of the distance away from the source. Other sources of noise, such as a road or railroad, are not a single, stationary point source of sound but rather, emanate noise from a line (“line” source). The drop-off rate for a line source is three dBA for each doubling of distance away from the source.

The propagation of noise is also affected by the absorption characteristics of the ground: a hard site, such as a parking lot or smooth body of water, provides no absorption/attenuation and the changes in noise levels with distance result simply from the geometric spreading of the source (i.e., three or six dBA reduction per doubling of distance for a point source or line source, respectively).

Conversely, a soft site, such as soft dirt, grass, or scattered bushes and trees, may provide additional absorption/attenuation, potentially reducing noise levels an additional 1.5 dBA per doubling of distance away from the source.
3 Noise levels may also be reduced by intervening structures. The amount of reduction provided by the “shielding” of these features depends on the size of the structure/s, the location of the structure/s relative to the noise source and receivers, and the frequency content of the noise levels.

Natural terrain features, such as hills and dense woods, and man-made features, such as buildings and walls, can significantly alter noise levels. Generally, any large structure blocking the line of sight between a noise source and receiver will provide at least a five-dBA reduction in source noise levels at the receiver (Federal Highway Administration [FHWA] 2011).

Vibration Overview
Vibration levels are usually expressed as a single-number measure of vibration magnitude in terms of velocity or acceleration, which describes the severity of the vibration without the frequency variable. The peak particle velocity (PPV) is defined as the maximum instantaneous positive or negative peak of the vibration signal, usually measured in inches per second. Since it is related to the stresses experienced by buildings, PPV is often used in monitoring and controlling construction vibration. Although PPV is appropriate for evaluating the potential of building damage, it is not suitable for evaluating human response. It takes some time for the human body to respond to vibrations. In a sense, the human body responds to an average vibration amplitude (Federal Transit Administration [FTA] 2018). Because vibration waves are oscillatory, the net average of a vibration signal is zero. Thus, the RMS amplitude is used to describe the “smoothed” vibration amplitude (FTA 2018). The RMS of a signal is the square root of the average of the squared amplitude of the signal, usually measured in inches per second. The average is typically calculated over a one-second period.

The RMS amplitude is always less than the PPV and is always positive. Decibel notation is used to compress the range of numbers required to describe vibration. The abbreviation “VdB” is used in this analysis for “vibration decibels” to reduce the potential for confusion with sound decibels.

Sensitive Receptors
The project area consists of 20 Infill Rezone Program sites within the existing City of Clovis boundaries. Noise exposure goals for various types of land uses reflect the varying noise sensitivities associated with those uses. The Clovis General Plan identifies “schools, hospitals, senior housing and 3 California Department of Transportation (Caltrans). 2013. Technical Noise Supplement to the Traffic Noise Analysis Protocol. Accessed June 2025: https://dot.ca.gov/-/media/dot-media/programs/environmental-analysis/documents/env/tens-sep2013-a11y.pdf

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Noise
Environmental Assessment 4.10-3
convalescent facilities, residential uses, places of worship, libraries, and passive outdoor recreation areas” as noise-sensitive land uses within the City.
4 The primary noise source in the City of Clovis is
vehicular traffic along State Route (SR)-168, Herndon Avenue, Shaw Avenue, Clovis Avenue and other arterial roadways. Other noise sources include overhead aircraft related to the FresnoYosemite Airport, located south of the Clovis city limits.

4.10.2 Regulatory Setting
a. Federal Regulations
Federal noise standards established by the United States (U.S.) Department of Housing and Urban Development (HUD) are applicable to residential projects that receive HUD assistance. These standards are presented in 24 Code of Federal Regulations (CFR) Part 51. New construction proposed in high noise areas (exceeding 65 dBA day-night average sound level (Ldn)) must incorporate noise attenuation features to maintain acceptable interior noise levels. A goal of 45 dBA Ldn is set forth for interior noise levels and attenuation requirements are geared toward achieving that goal. It is assumed that with standard construction, any building will provide sufficient attenuation to achieve an interior level of 45 dBA Ldn or less if the exterior level is 65 dBA Ldn or less.

Approvals in a "normally unacceptable noise zone" (exceeding 65 dBA, but not exceeding 75 dBA) require a minimum of five dBA of additional noise attenuation for buildings having noise sensitive uses (e.g., residences) if the day-night average is greater than 65 dBA, but does not exceed 70 dBA, or a minimum of 10 dBA of additional noise attenuation if the day-night average is greater than 70 dBA, but does not exceed 75 dBA.

There are additional federal regulations that influence the audible landscape, especially for projects where federal funding is involved. For example, the FHWA requires abatement of highway traffic noise for highway projects through rules in the CFR (23 CFR Part 772), the FTA, and Federal Railroad Administration (FRA). Each agency recommends thorough noise and vibration assessments through comprehensive guidelines for any highway, mass transit, or high-speed railroad projects that would pass by residential areas.

Occupational Health and Safety Administration
The federal government regulates occupational noise exposure common in the workplace through the Occupational Health and Safety Administration (OSHA) under the Environmental Protection Agency. Noise limitations would apply to the operation of construction equipment and could also apply to any proposed industrial land uses. Noise exposure of this type is dependent on work conditions and is addressed through a facility’s Health and Safety Plan, as required under OSHA, and is not addressed further in this analysis.
b. State Regulations
California Building Code
California Code of Regulations Title 24, Building Standards Administrative Code, Part 2, Chapter 12, and the California Building Code codify the State noise insulation standards. These noise standards apply to new construction in California to control interior noise levels as they are affected by 4 Clovis, City of. 2014a. City of Clovis General Plan. Accessible at:
https://www.clovisca.gov/services/planning_development/planning/general_plan/environmental_impact_report.phphttps://cityofclovis. com/wp-content/uploads/2018/10/Clovis-General-Plan-2014.pdf

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exterior noise sources and interior noise sources from separate areas. The regulations specify that interior noise levels shall not exceed 45 dBA community noise equivalent level (CNEL)/Ldn in any habitable room, as well as specifying sound transmission class requirements for walls, floors, and ceilings around sleeping units.

California Green Building Code
California Green Building Standards Code 2022 (CALGreen) Section 5.507.4, Acoustical Control, regulates construction of non-residential uses within the 65 dBA CNEL/Ldn contour of an airport, freeway, expressway, railroad, industrial noise source, or other fixed source. According to Section

5.507.4.1-2 “buildings exposed to a noise level of 65 dBA Leq (1-hr) during any hour of operation shall employ sound-resistant assemblies as determined by a prescriptive method or performance method.”
Projects may demonstrate compliance through the prescriptive method if wall and roof-ceiling assemblies exposed to the noise source meet a composite sound transmission class rating of at least 50 or a composite outdoor/indoor transmission class rating of no less than 40, with exterior windows of a minimum sound transmission class of 40 or outdoor/indoor transmission class of 30.

Projects may demonstrate compliance through the performance method if wall and roof-ceiling assemblies exposed to the noise source are constructed to provide an interior noise environment that does not exceed 50 dBA Leq (1-hr) in occupied areas during hours of operations. c. Local Regulations
City of Clovis General Plan
Table 4.10-1 presents the land use compatibility chart for community noise adopted by the State of California as part of its General Plan Guidelines and modified by the City of Clovis in its General Plan Update. This table provides urban planners with a tool to gauge the compatibility of new land uses relative to existing and future noise levels. This table identifies normally acceptable, conditionally acceptable, and clearly unacceptable noise levels for various land uses. A conditionally acceptable designation implies new construction or development should be undertaken only after a detailed analysis of the noise reduction requirements for each land use is made and needed noise insulation features are incorporated in the design. By comparison, a normally acceptable designation indicates that standard construction can occur with no special noise reduction requirements.

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Table 4.10-1 Land Use Compatibility Matrix
CNEL
Land Uses < 55 60 65 70 75 80>
Amphitheater, concert hall, auditorium,
meeting hall

B B C C D D D
Mobile home A A B C C D D
Hospital, library, school, faith/religious
uses

A A B C C D D
Hotel, motel, transient lodging A A B B C C D
Single family, multifamily, faith/religious
uses

A A B B C D D
Parks A A A B C D D
Office building, research & development,
professional office, city office building,
and hotel

A A A B B C D
Amusement park, miniature golf, go-cart
track, health club, equestrian center

A A A B B D D
Golf courses, nature centers, cemeteries,
wildlife reserves, wildlife habitat

A A A A B C C
Commercial retail, bank, restaurant,
movie theater

A A A A B B C
Automobile service station, auto dealer,
manufacturing, warehousing, wholesale,
utilities

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

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

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

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

CNEL = community equivalent noise level
Source: Clovis General Plan, 2014
City of Clovis Municipal Code
Section 9.22.080 of the City of Clovis Municipal Code (CMC) specifies maximum exterior noise limits that are not to be exceeded for various land use types. These noise limits, which apply at the property line, are shown in Table 4.10-2.

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Table 4.10-2 Maximum Exterior Noise Standards
Noise Zone Type of Land Use
Allowable Exterior Noise Level (15-Minute Leq)
7:00 a.m. to 10:00 p.m. 10:00 p.m. to 7:00 a.m.

I Single-, two- or multiple-family residential 55 dBA 50 dBA II Commercial 65 dBA 60 dBA
III Residential portions of mixed use
properties
60 dBA 50 dBA
IV Industrial or manufacturing 70 dBA 70 dBA

1. If the ambient exceeds the resulting standard, the ambient shall be the standard.

2. It is unlawful for any person to create any noise, or to allow the creation of any noise on property owned, leased, occupied or otherwise controlled by such person, which causes the noise level when measured on any property measured at the property line, to exceed either of the following within the incorporated area of the City:
a. The noise standard for the applicable zone for any fifteen (15) minute period; b. A maximum impulsive noise equal to the value of the noise standard plus twenty (20) dBA for any period of time (measured using A-weighted slow response). Impulsive noise which repeats four (4) or more times in any hour between 10:00 p.m. and 7:00 a.m. shall be measured as continuous sound and meet the noise standard for the applicable zone. dBA = A-weighted decibels; Leq = equivalent noise level Source: City of Clovis Municipal Code, Section 9.22.080, Table 3-1 (City of Clovis 2024).

Section 5.27.604 of the CMC contains regulations on noise produced by construction activities, stating “construction activities are only permitted between the hours of 7:00 a.m. and 7:00 p.m.

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

Monday through Friday. Extended construction work hours must at all times “be in strict compliance with the permit” (City of Clovis 2024).

Neither the Clovis General Plan nor the CMC provides a quantitative construction noise threshold.

Therefore, the limits specified in the FTA Transit Noise and Vibration Impact Assessment Manual (2018) were used to evaluate the project’s potential construction noise impacts. These construction noise limits are shown in Table 4.10-3.

Table 4.10-3 FTA Construction Noise Criteria
Land Use
dBA Leq (8-hour)
Day (7:00 a.m. to 10:00 p.m.) Night (10:00 p.m. to 7:00 a.m.) Residential 80 70
Commercial 85 85
Industrial 90 90
dBA = A-weighted decibels; Leq = equivalent noise level Source: FTA 2018
Based on the criteria shown in Table 4.10-3, construction noise would be significant if it were to exceed 80 dBA Leq for an eight-hour period for residential uses, applied at the project property line.

Additionally, construction noise would be considered significant if it were to occur outside of the allowable days and hours specified in Section 5.27.604 of the CMC.

Section 9.22.100 of the CMC addresses vibration, stating “vibrations from temporary construction/demolition and vehicles that leave the subject parcel (e.g., trucks) are exempt from the provisions of this section” (City of Clovis 2024). In absence of a quantitative vibration threshold, vibration limits used in this analysis to determine potential vibration impacts to surrounding

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Environmental Assessment 4.10-7
receptors during construction are based on thresholds for vibration damage potential established in the Transit Noise and Vibration Impact Assessment Manual (FTA 2018). These vibration limits are shown in Table 4.10-4.

Table 4.10-4 FTA Vibration Damage Potential Criteria
Building Category PPV (in/sec)
I. Reinforced concrete, steel, or timber (no plaster) 0.5 II. Engineered concrete and masonry (no plaster) 0.3
III. Nonengineered timber and masonry buildings 0.2
IV. Buildings extremely susceptible to vibration damage 0.12 PPV = peak particle velocity; in/sec = inches per second Source: FTA 2018
For a conservative analysis, construction vibration impacts would be significant if vibration levels exceed 0.2 in/sec PPV at the nearest offsite residential structures to the Infill Rezone Program site.

This is the level at which minor architectural (i.e., non-structural) damage may occur to buildings of standard residential construction.

4.10.3 Impact Analysis
a. Methodology and Significance Thresholds
Methodology
As discussed in Chapter 2, Project Description, the proposed project is a plan to accommodate forecasted growth and existing and future need for housing. The following discussion describes the methodology used to evaluate the significance of potential noise and vibration impacts related to the rezoning of the 20 Infill Rezone Program sites.

Construction Noise
The primary source of temporary noise associated with the proposed project would be construction activities associated with accommodated housing development. Construction equipment can be considered to operate in two modes: stationary and mobile. Stationary equipment operates in a single location for one or more days at a time, with either fixed-power operation (e.g., pumps, generators, and compressors) or variable-power operation (e.g., pile drivers, rock drills, and pavement breakers). Mobile equipment moves around a construction site with power applied in cyclic fashion, such as bulldozers, graders, and loaders. 5 Each phase of construction has its own
noise characteristics due to specific equipment mixes; some will have higher continuous noise levels than others and some may have high-impact intermittent noise levels. 6 Therefore, construction
noise levels may fluctuate depending on the type of equipment being used, construction phase, or equipment location. In typical construction projects, grading activities typically generate the highest noise levels because grading involves the largest equipment and covers the greatest area. 5 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment. Accessible at:
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibration-impact-assessmentmanual-fta-report-no-0123_0.pdf 6 Ibid.

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Foundation excavation and construction is often the second loudest phase, followed by paving and building construction.

Variation in power imposes additional complexity in characterizing the noise source level from construction equipment. Power variation is accounted for by describing the noise at a reference distance from the equipment operating at full power and adjusting it based on the duty cycle, or percent of operational time, of the activity to determine the Leq of the operation. 7 For assessment purposes, noise levels for common construction equipment provided in the FTA Transit Noise and Vibration Impact Assessment (2018) guidance document were used to analyze potential noise levels associated with future development under the Housing Element. The FTA provides typical noise levels at 50 feet from various types of equipment. Construction noise was also estimated using the FHWA’s Roadway Construction Noise Model (RCNM) (2006). RCNM predicts construction noise levels for a variety of construction operations based on empirical data and the application of acoustical propagation formulas. Using RCNM, construction noise levels were estimated at a distance of 50 feet from future development.

On-site Operational Noise
Stationary noise sources (i.e., on-site operational noise) for future development facilitated by the proposed project were analyzed in context of typical mechanical equipment on residential development such as heating, ventilation, and air conditioning (HVAC) units.

Off-site Operational Noise
The transportation analysis, on which the noise analysis is based, evaluates reasonably anticipated development that is expected to occur by 2035 as a result of the proposed project. 8 The reasonably
anticipated development is based on the acreage of land designated for each type of land use, allowable densities and intensities for each land use designation, and reasonably expected levels of development through the life of the proposed project.

Groundborne Vibration
Development carried out under the proposed project would not include substantial vibration sources associated with operation. Construction activities have the greatest potential to generate groundborne vibration affecting nearby noise-sensitive receptors. Construction vibration levels that could occur due to development carried out under the proposed project are based on reference vibration levels published by the FTA.

Significance Thresholds
In accordance with Appendix G of the California Environmental Quality Act (CEQA) Guidelines, the proposed project’s noise and vibration impacts would be significant if it would:

Generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies;
Generate excessive groundborne vibration or groundborne noise levels; or 7 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment. Accessible at:
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibration-impact-assessmentmanual-fta-report-no-0123_0.pdf 8 Kittelson & Associates. 2025. Transportation Analysis. June 2025.

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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, expose people residing or working in the project area to excessive noise levels.

The following discussion identifies specific thresholds used to analyze the general CEQA thresholds listed above.

Construction Noise
Although the CMC has established hours of construction in Section 5.27.604, the City of Clovis has not adopted a quantitative threshold for evaluating construction noise impacts. Therefore, this analysis relies on the reasonable criteria provided by the FTA for assessing construction noise impacts based on the potential for adverse community reaction in its Transit and Noise Vibration Impact Assessment Manual. For residential uses, the daytime noise threshold is 80 dBA Leq for an eight-hour period.

Operational Noise
The City has adopted noise standards in the CMC that regulate operational stationary noise sources in the City. Operational noise would result in a significant impact if it exceeds the ambient base noise levels established for residential/noise-sensitive uses as shown in Table 4.10-2.

Groundborne Vibration
The City’s Municipal Code or General Plan does not have vibration thresholds. Therefore, this analysis applies the following vibration thresholds established by the FTA for potential structural damage to buildings. The FTA thresholds in Table 4.10-4 are used to assess the potential structural damage to buildings from construction vibration. A significant impact would be identified if construction facilitated by the project would generate excessive vibration levels at surrounding receptors. Groundborne vibration levels exceeding 0.12 in/sec PPV would have the potential to result in cosmetic damage to buildings extremely susceptible to vibration damage (i.e., historic buildings), and groundborne vibration levels exceeding 0.2 in/sec PPV would have the potential to result in cosmetic damage to non-engineered timber and masonry buildings (i.e., residential buildings).

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b. Project Impacts and Mitigation Measures
Threshold 1: 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?
Impact NOI-1 CONSTRUCTION OF INDIVIDUAL PROJECTS CARRIED OUT UNDER THE PROPOSED PROJECT WOULD TEMPORARILY INCREASE NOISE LEVELS, POTENTIALLY AFFECTING NEARBY NOISE-SENSITIVE LAND USES.

DEVELOPMENT CARRIED OUT UNDER THE PROPOSED PROJECT WOULD ALSO INTRODUCE NEW NOISE SOURCES AND CONTRIBUTE TO INCREASES IN OPERATIONAL NOISE. IMPLEMENTATION OF MITIGATION MEASURE (MM) NOI-1 WOULD REDUCE CONSTRUCTION NOISE LEVELS; HOWEVER, CONSTRUCTION NOISE IMPACTS WOULD BE SIGNIFICANT AND UNAVOIDABLE EVEN WITH MITIGATION. OPERATIONAL NOISE WOULD NEED TO CONFORM TO EXISTING CITY REQUIREMENTS AND THEREFORE OPERATIONAL IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Construction
Construction noise from individual development facilitated by the proposed project would temporarily increase ambient noise levels on and adjacent to individual construction sites, including noise from construction traffic. Since the project does not propose any specific development projects, it is not possible to determine exact noise levels, locations, or time periods for construction of such projects. However, areas of Clovis adjacent to the proposed Infill Rezone Program sites, upzoning areas, and additional parcels would be exposed to the highest levels of construction noise for the longest duration, especially in areas where Infill Rezone Program sites, upzoning areas, and additional parcels are more concentrated. Construction noise associated with buildout facilitated by the proposed project would occur over the project’s planning period (2035).

Construction activities that would generate noise include but are not limited to construction traffic and hauling, demolition, and construction itself. Table 4.10-5 illustrates typical noise levels associated with various common types of construction equipment at a distance of 50 feet, which is representative of the exposure of adjacent noise-sensitive receptors to construction noise. Noise from stationary sources of equipment typically drops off at a rate of about six dBA per doubling of distance; therefore, noise levels would be about six dBA lower than shown in the table at 100 feet from source construction site and 12 dBA lower at a distance of 200 feet from source construction site.

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Table 4.10-5 Typical Noise Levels for Construction Equipment Equipment
Estimated Noise Levels at Nearest Sensitive Receptors (dBA Leq) 50 feet 100 feet 200 feet
Air Compressor 81 75 69
Backhoe 80 74 68
Concrete Mixer 85 79 73
Dozer 85 79 73
Grader 85 79 73
Jackhammer 88 82 76
Paver 89 83 77
Pile-drive (Impact) 101 95 89
Pile-driver (Sonic) 95 89 83
Saw 76 70 64
Scraper 89 83 77
Truck 88 82 76
Source: FTA 2018
As shown in Table 4.10-5, the loudest piece of construction equipment is a pile-driver, which could cause noise levels to approach 101 dBA Leq at a distance of 50 feet. Pile-drivers are used to install deep foundation piers and are not typically used for construction of residential development.

However, project-level details are not currently available for future projects that would be facilitated by the proposed project, and it cannot be guaranteed that future construction would not involve use of a pile-driver. Therefore, this sound level is considered to provide a conservative analysis. Accordingly, construction noise associated with buildout facilitated by the project would likely exceed ambient noise levels and may temporarily disturb people at neighboring properties.

Section 5.27.604 of the CMC contains regulations on noise produced by construction activities, stating “construction activities are only permitted between the hours of 7:00 a.m. and 7:00 p.m.

Monday through Friday and between 9:00 a.m. and 5:00 p.m. on Saturday and Sunday. From June 1st through September 15th, permitted construction activity may commence after 6:00 a.m. Monday through Friday. Extended construction work hours must at all times be in strict compliance with the permit” (City of Clovis 2024).

Compliance with Section 5.27.604 of the CMC would restrict the timing of construction activities authorized by a City permit to the hours of 7:00 a.m. to 7:00 p.m. Monday through Friday and 9:00 a.m. to 5 p.m. on Saturday and Sundays (City of Clovis 2024). In addition, implementation of and adherence to the following existing policies in the Environmental Safety Element of the General Plan would ensure continued application of the City’s existing timing restrictions on construction activity, or modification of those standard restrictions as necessary to protect noise-sensitive receptors.

While the project may involve revisions to the Environmental Safety Element, these existing policies would remain in effect:

City of Clovis
Infill Rezone Program

4.10-12
Goal 3: An environment in which minimized noise contributes to the public's health, safety, and welfare.

Policy 3.3: New residential. When new residential development is proposed adjacent to land designated for industrial or commercial uses, require the proposed development to assess potential noise impacts and fund feasible noise-related mitigation measures.

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

Implementation of Goal 3, Policy 3.3 and 3.4 would reduce construction noise impacts associated with future discretionary projects carried out under the proposed project. However, project-level details are not currently available for future projects that would be facilitated by the proposed project. Therefore, it is not possible to determine exact noise levels, locations, or time periods for construction of such projects, or construction noise at adjacent properties. Construction noise levels associated with future projects may exceed the FTA’s daytime construction noise limits, and impacts would be potentially significant and mitigation is required.

Implementation of MM NOI-1 below, as well as implementation of applicable goals and policies of the City’s General Plan would reduce potential impacts from noise during construction by reducing noise source impacts and creating sound barriers where required/necessary. However, as exact details of future project-specific construction activities are unknown at this time, construction noise could still exceed the daytime significance threshold or potentially need to occur during the more sensitive nighttime hours. Consequently, although implementation of MM NOI-1 would reduce construction noise impacts, it cannot be guaranteed that construction noise impacts would be reduced to below the significance threshold of 80 dBA Leq during the daytime at residential uses and other sensitive receptors in all cases. Therefore, the proposed project’s construction noise impacts would remain significant and unavoidable.

Operation
Stationary Noise
Stationary and other sources of noise in the City of Clovis include those associated with the standard operation of land uses. These sources could include, but are not limited to, landscape and building maintenance activities, stationary mechanical equipment (e.g., pumps, HVAC units), garbage collection activities, and other stationary and area sources such as people's voices and amplified music. Noise generated by residential uses are generally short-term and intermittent in nature. The project would provide for an increase in residential development throughout the city. Residential development tends to have lower noise levels compared to other uses, such as industrial or commercial uses.

The City would have the discretion to condition the approval of a new project to meeting the noise standards in the development code. Mitigation measures include equipment design, equipment selection, equipment location, the design of equipment enclosures, construction of sound walls, and limiting the hours of operation. The Environmental Safety Element includes the following goals and policies that pertain to operational stationary noise:

Environmental Impact Analysis
Noise
Environmental Assessment 4.10-13
Goal 3: An environment in which minimized noise contributes to the public's health, safety, and welfare.

Policy 3.1: Land use compatibility. Approve development and require mitigation measures to ensure existing and future land use compatibility as shown in the Noise Level Exposure and Land Use Compatibility Matrix and the city’s noise ordinance.

Policy 3.3: New residential. When new residential development is proposed adjacent to land designated for industrial or commercial uses, require the proposed development to assess potential noise impacts and fund feasible noise-related mitigation measures.

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

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

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

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

Policy 3.8: Existing uses. Require the use of noise abatement devices for existing uses that exceed acceptable noise thresholds.

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

Implementation of CMC Chapter 5.27.6 and implementation of Goal 3 and Policies 3.1, 3.3, 3.4, 3.5,

3.6, 3.7, 3.8 and 3.14 would reduce potential impacts associated with new noise-producing land uses by identifying mitigation that would reduce noise associated with new stationary noise sources below acceptable noise standards. As a result, stationary operational noise would not exceed the City’s standard for allowable noise exposure at residential sensitive receptors of 55 dBA Leq(15-min) during daytime hours and 50 dBA Leq(15-min) during nighttime hours. Therefore, on-site operational impacts from the project would be less than significant.

Traffic Noise
The transportation analysis, on which the traffic noise analysis is based, evaluates vehicle miles traveled associated with the project (see Section 4.13, Transportation). As shown in Table 4.10-6, vehicle miles traveled in Clovis would increase by approximately four percent with the project compared to the no project scenario. A four percent increase in traffic on a roadway would equate to an approximate increase of 0.2 dBA. Therefore, noise level increases of this size would not result in noise levels that are above the “normally unacceptable” category for land uses adjacent to these corridors, including residential, school, and commercial uses. Traffic noise impacts would be less than significant.

City of Clovis
Infill Rezone Program

4.10-14
Table 4.10-6 Traffic Noise Increase
Vehicle Miles Traveled
Clovis Sphere of Influence 2,153,575
Clovis Sphere of Influence with Project 2,235,892
Change in Vehicle Trips +82,317
Percent Change in Vehicle Trips (%) 4%
Estimated Traffic Noise Increase from Increase in Vehicle Trips 0.2 dBA Source: Kittelson & Associates. 2025. Transportation Analysis. June 2025.

Compliance with applicable goals and polices noted above, on-site operational impacts and traffic noise impacts would be less than significant without mitigation.

Mitigation Measures
NOI-1 Measures to Reduce Construction Noise
To minimize noise during construction, the City of Clovis shall require construction contractors to implement the following measures for construction activities conducted within the City for the 20 Infill Rezone Program sites. Construction plans submitted to the City shall include construction noise analysis and identify these measures on demolition, grading, and construction plans submitted to the City. The City of Clovis Building Division shall verify that grading, demolition, and/or construction plans submitted to the City include these notations prior to issuance of demolition, grading and/or building permits.
 Mufflers. During excavation and grading construction phases, all construction equipment, fixed or mobile, shall be operated with closed engine doors and shall be equipped with properly operating and maintained mufflers consistent with manufacturers’ standards.  Stationary Equipment. All stationary construction equipment shall be placed so that emitted noise is directed away from the nearest sensitive receivers.  Equipment Staging Areas. Equipment staging shall be located in areas that will create the greatest distance feasible between construction-related noise sources and noise-sensitive receivers.
 Smart Back-up Alarms. Mobile construction equipment shall have smart back-up alarms that automatically adjust the sound level of the alarm in response to ambient noise levels.

Alternatively, back-up alarms shall be disabled and replaced with human spotters to ensure safety when mobile construction equipment is moving in the reverse direction in compliance with applicable safety laws and regulations.
 Electrically-Powered Tools and Facilities. Electrical power shall be used to run air compressors and similar power tools and to power any temporary structures, such as construction trailers or caretaker facilities, where feasible.
 Noise Disturbance Coordinator. The project applicant shall designate a “noise disturbance coordinator” responsible for responding to any local complaints about construction noise. The disturbance coordinator shall determine the cause of any noise complaint and shall require that reasonable measures be implemented to correct the problem. A telephone number for the disturbance coordinator and the City shall be posted at the construction site.

Environmental Impact Analysis
Noise
Environmental Assessment 4.10-15
 Temporary Noise Barriers. Erect temporary noise barriers, where feasible, when construction noise is predicted to exceed the acceptable standards (e.g., 80 dBA Leq at residential receivers, schools or other sensitive receptors during the daytime) or when the anticipated construction duration is greater than is typical (e.g., two years or greater) and there are sensitive receptors within 500 feet of the construction site. Temporary noise barriers shall be constructed with solid materials (e.g., wood) with a density of at least 1.5 pounds per square foot with no gaps from the ground to the top of the barrier. If a sound blanket is used, barriers shall be constructed with solid material with a density of at least one pound per square foot with no gaps from the ground to the top of the barrier and be lined on the construction side with acoustical blanket, curtain or equivalent absorptive material rated sound transmission class 32 or higher.

Significance after Mitigation
Significant and unavoidable for construction.

Less than significant for operation and traffic noise.

Threshold 2: Would the project result in generation of excessive groundborne vibration or groundborne noise levels?
Impact NOI-2 CONSTRUCTION OF INDIVIDUAL DEVELOPMENT FACILITATED BY THE PROJECT COULD TEMPORARILY GENERATE GROUNDBORNE VIBRATION, POTENTIALLY AFFECTING ADJACENT SENSITIVE LAND USES.

IMPACTS WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

Construction
The construction of individual development facilitated by the proposed project could intermittently generate strong vibration on and adjacent to construction sites. Typical construction equipment that produces vibration include pile drivers, vibratory rollers for paving, caisson drills, bulldozers, loaded trucks, and jackhammers. Table 4.10-7 lists groundborne vibration levels from various types of construction equipment at various distances.

Table 4.10-7 Vibration Levels for Typical Construction Equipment Approximate Vibration Level (in/sec PPV)
Equipment
25 feet
from Source
50 feet
from Source
100 feet
from Source
200 feet
from Source
Caisson Drilling 0.089 0.031 0.011 0.004
Jackhammer 0.035 0.012 0.004 0.002
Large Bulldozer 0.089 0.031 0.011 0.004
Loaded Truck 0.076 0.027 0.010 0.003
Pile Driver (impact) Upper range 1.519 0.537 0.190 0.067 Typical 0.644 0.228 0.081 0.028
Pile Driver (sonic) Upper range 0.734 0.260 0.092 0.032 Typical 0.170 0.060 0.021 0.008
Small Bulldozer 0.003 0.001 <0.001 <0.001
Vibratory Roller 0.21 0.074 0.026 0.009
Source: FTA 2018.

City of Clovis
Infill Rezone Program

4.10-16
Based on Table 4.10-7, buildings and structures could experience the strongest vibration during the use of pile-drivers and vibratory rollers. Vibration levels from pile-drivers could approach 1.519 in/sec PPV at a distance of 25 feet from the source and 0.190 in/sec at 100 feet, and vibration levels from vibratory rollers could approach 0.21 in/sec PPV at a distance of 25 feet and 0.026 at 100 feet.

Pile-drivers are used to install deep foundation piers and vibratory rollers are used to compact soil, gravel, or asphalt. Pile-drivers and vibratory rollers are not used for every construction project.

However, project-level details are not currently available for future projects that would be facilitated by the proposed project, and it cannot be guaranteed that future development would not involve use of pile-drivers or vibratory rollers. Therefore, vibration levels from these pieces of equipment are considered to provide a conservative analysis.

In terms of impacting residents, compliance with CMC Section 5.27.604 would restrict the timing of construction activities to the hours of 7:00 a.m. to 7:00 p.m. Monday through Friday (except from June 1st to September 15th, the permitted hours for construction activity are 6:00 a.m. to 7:00 p.m.

Monday through Friday) and 9:00 a.m. to 5:00 p.m. on Saturdays and Sundays. This requirement for new development would protect residents from exposure to vibration during normal sleeping hours.

In terms of impacting structures, the threshold for historic structures is 0.12 in/sec PPV, and the threshold for non-historic buildings at 0.2 in/sec PPV. 9 As shown in Table 4.10-7, vibration levels
associated with pile-drivers and vibratory rollers operating at a distance of 25 feet could exceed the threshold for non-historic structures and pile-drivers operating at a distance of up to 100 feet could exceed the threshold for historic and non-historic structures. Table 4.10-8 summarizes the distances at which construction equipment would exceed vibration thresholds.

Table 4.10-8 Distances at Which Vibration Levels for Typical Construction Equipment Exceed Vibration Thresholds
Distance (feet) at Which Vibration Level (in/sec PPV) Exceeds Threshold1 Equipment
Historic Structures
(in feet)
Timber/Masonry
Buildings2 (in feet)
Engineered Concrete/
Masonry Buildings (in feet)
Pile-Driver 135 100 75
Vibratory Roller 40 25 25
Dozer/Large Earthmoving Equipment 20 15 15
1 The threshold for historic structures is 0.12 in/sec PPV, and the threshold for non-historic buildings at 0.2 in/sec PPV (FTA 2018). 2 Most residential buildings consist of non-engineered timber/masonry buildings. in/sec PPV = inches per second peak particle velocity
Because most Infill Rezone Program sites, rezoning areas, and additional parcels are located near or adjacent to existing structures, it is possible that construction of development facilitated by the project could generate vibration that exceeds applicable thresholds. In addition, as discussed in Section 4.4, Cultural Resources, historic-age structures are located throughout the City. Accordingly, future construction facilitated by the project may exceed applicable groundborne vibration thresholds. Impacts would be potentially significant and mitigation is required.

Implementation of MM NOI-1 and MM NOI-2 would reduce potential impacts from groundborne vibration to less than significant levels by requiring proper buffer distances to vibration-sensitive receptors depending on the type of construction equipment or requiring alternative construction 9 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment. Accessible at:
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibration-impact-assessmentmanual-fta-report-no-0123_0.pdf

Environmental Impact Analysis
Noise
Environmental Assessment 4.10-17
equipment to reduce vibration. Accordingly, construction vibration impacts would be less than significant with mitigation.

Operation
The project would primarily facilitate residential development, which does not typically generate vibration during operation. Commercial development facilitated by the project is not anticipated to involve industrial, high-intensity uses that could result in vibration during operation, such as mining operations or manufacturing uses. Therefore, project operational vibration impacts would be less than significant.

Mitigation Measures
Implement MM NOI-1 (as described above).

NOI-2 Measures to Reduce Construction Vibration
Prior to issuance of a building permit for a project requiring any of the following activities, the project applicant shall prepare a groundborne noise and vibration analysis to assess and mitigate potential noise and vibration impacts related to these construction activities.  Pile driving during construction within 135 feet of fragile structures such as historical resources  Pile driving during construction within 100 feet of non-engineered timber and masonry buildings (e.g., most residential buildings)
 Pile driving during construction within 75 feet of engineered concrete and masonry (no plaster)  Use of a vibratory roller within 40 feet of fragile historical resources or 25 feet of any other structure
 Use of a dozer or other large earthmoving equipment within 20 feet for a fragile historical structure or 15 feet of any other structure
This noise and vibration analysis shall be conducted by a qualified and experienced acoustical consultant or engineer. The groundborne noise and vibration analysis shall include measures to ensure that vibration levels shall not exceed Federal Transit Administration (FTA) architectural damage thresholds (e.g., 0.12 in/sec peak particle velocity (PPV) for fragile or historical resources,

0.2 in/sec PPV for non-engineered timber and masonry buildings, and 0.3 in/sec PPV for engineered concrete and masonry). If vibration levels would exceed this threshold, alternative uses such as drilling piles as opposed to pile driving, static rollers as opposed to vibratory rollers, and lower horsepower earthmoving equipment shall be used. If necessary, construction vibration monitoring shall be conducted to verify FTA vibration thresholds are not exceeded.

Significance after Mitigation
Less than significant with mitigation measures for construction.

Less than significant for operations.

City of Clovis
Infill Rezone Program

4.10-18
Threshold 3: For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
Impact NOI-3 DEVELOPMENT FACILITATED BY THE PROJECT WOULD BE LOCATED OUTSIDE OF NOISE CONTOURS ASSOCIATED WITH NEARBY AIRPORTS. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

There are no airports located within the City of Clovis city limits. The closest public or public use airport to the Infill Rezone Program sites is the Fresno-Yosemite International Airport. The airport is located approximately 0.4 miles south of the City and approximately 0.75 miles from the closest Infill Rezone Program site (site 161). The Fresno County Airport Land Use Compatibility Plan (ALUCP) Airport Influence Area and Safety Zone Exhibit D1 shows a southwest portion of the City of Clovis is located within the Traffic Pattern Zone. Infill Rezone Program sites 110, 161, 217, 598, and 599 are located within this Zone. This safety zone is related to airspace risk and does not influence maximum residential density. There are no Infill Rezone Program sites that are located within the future (year 2022) noise contours of the airport shown on Exhibit D2 of the Fresno County Airport Land Use Compatibility Plan. While new development facilitated by project would be exposed to aircraft noise, the City’s location outside noise contours associated with the nearby airport indicates that noise exposure to sensitive land uses would be within acceptable levels from airport noise.

Therefore, the project would not expose people residing or working in the housing sites, rezoning areas, or additional parcels to excessive aircraft noise. Impacts would be less than significant.

Mitigation Measures
No mitigation measures are required.

4.10.4 Cumulative Impacts
Construction Noise
Construction noise generated by projects carried out under the proposed project, in combination with construction activities for other cumulative projects that may be constructed simultaneously could, without mitigation, substantially increase noise levels in the vicinity of future projects. Goals, policies and mitigation measures have been identified to help reduce noise from construction equipment from future projects carried out under the proposed project. Therefore, unless construction of cumulative projects, including those carried out under the proposed project, occur in close proximity to each other and simultaneously, noise from individual construction projects has a small chance of combining to create significant cumulative impacts. Although this scenario is unlikely, and policies, actions, and mitigation measures would be implemented to the extent feasible, the potential remains for a cumulatively considerable increase in construction noise from projects carried out under the proposed project. The proposed project could result in a substantial contribution to this cumulatively significant impact. Therefore, the cumulative impact related to construction noise would be significant and unavoidable.

Operational Stationary Noise
Development carried out under the proposed project would introduce new stationary noise sources to the ambient noise environment in and around the project area, including new mechanical ventilation equipment. These sources may combine with noise from other nearby cumulative projects to result in higher noise levels. However, operational noise from these sources is localized

Environmental Impact Analysis
Noise
Environmental Assessment 4.10-19
and rapidly attenuates within an urbanized setting due to the effects of intervening structures and topography that block the line of sight, and due to other noise sources closer to receptors that obscure project-related noise. Implementation of the CMC noise standards would ensure that noise from new stationary sources as part of cumulative development would be within acceptable levels.

Therefore, the cumulative impact related to operational stationary noise would be less than significant.

Operational Mobile Noise
As discussed in Impact NOI-1, traffic noise increases from development facilitated by the proposed project would contribute to noise level increases that would not exceed impact criteria and therefore would not be cumulatively considerable. Therefore, in combination with traffic noise for other cumulative projects, the cumulative impact related to operational traffic noise would be less than significant.

Groundborne Vibration and Noise
Although there could be other cumulative projects simultaneously under construction near a development project carried out under the proposed project, the potential for construction groundborne vibration and noise impacts exists within a limited area (e.g., within approximately 25 feet for a vibratory roller). Since no two construction cumulative projects would both be within 25 feet of a given sensitive structure, cumulative groundborne vibration and noise impacts would be less than significant.

Airport Noise
Aircraft-related noise impacts occur only in the vicinity of airports or airstrips. Although citywide growth facilitated by the proposed Infill Rezone Program could increase the number of people who are exposed to aircraft-related noise impacts, such impacts would be localized in nature. In addition, new residential development and other development would not result in a direct increase to aircraft operations that would increase noise exposure to aircraft overflight patterns within and outside the City. Development facilitated by the proposed project would have no contribution to any cumulative impact related to airport hazards or noise. Impacts related to airport or airstrip noise would not be cumulatively considerable and cumulative impacts would be less than significant.

Mitigation Measures
Implement mitigation measures NOI-1 and NOI-2.

Significance after Mitigation
Less than significant for operations. Less than significant with mitigation measures for construction.

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Infill Rezone Program

4.10-20
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Environmental Impact Analysis
Population and Housing
Environmental Assessment 4.11-1

4.11 Population and Housing
This section analyzes impacts related to population and housing growth associated with development facilitated by the Infill Rezone Program project.

4.11.1 Setting
a. City of Clovis Existing and Forecasted Population and Housing The California Department of Finance (DOF) takes inventory on current housing stock, including single and multifamily housing units, and mobile home housing units, excluding accessory dwelling units. Table 4.11-1 provides the DOFs 2025 estimates of population and housing for Clovis and Fresno County as a whole. As of January 2025, Clovis has an estimated 2025 population of 129,121 and an estimated 47,817 housing units. 1
The DOF estimated the average household size in Clovis
was 2.70 persons, whereas the County average was 2.95 persons per household.2 The housing unit vacancy rate of the city (4.1 percent) is lower than that of Fresno County overall (5.6 percent).

Table 4.11-1 Current Population and Housing Stock Estimates for Clovis City of Clovis Fresno County
Population (#of people) 129,121 1,037,053
Average Household Size (persons/household) 2.70 2.95
Total Housing Units (# of units) 1 47,817 352,020
Vacant Housing Units 1,960 (4.1%) 19,713 (5.6%)
Source: California Department of Finance. 2025.

The City of Clovis’s 2014 General Plan outlines long-term growth expectations based on adopted land use designations and planning assumptions. According to Table LU-1 of the General Plan, full buildout of the project area, which includes the city limits, its Sphere of Influence (SOI), and surrounding project areas, is projected to accommodate approximately 107,100 dwelling units, a population of 294,300, and 106,900 jobs.3 Within the city limits alone, buildout is expected to support 46,000 dwelling units, 126,800 residents, and 63,200 jobs, while the SOI is projected to add another 22,600 units, 61,800 residents, and 15,000 jobs.4 To supplement the General Plan’s projections, the 2024 Fresno Council of Governments (Fresno COG) Growth Projections report for 2023 through 2060 provides updated regional forecasts for employment. According to this report, the number of jobs within the Clovis SOI is expected to grow from 40,550 in 2022 to 51,050 by 2060, representing a 26 percent increase over the 38-year period.

These projections support regional and local planning efforts, including the Sustainable Communities Strategy and updates to the Housing Element and General Plan. 1 California Department of Finance. E-5 Population and Housing Estimates for Cities, Counties, and the State, 2020-2025. Accessed June 2025: https://dof.ca.gov/forecasting/demographics/estimates-e1/ 2 California Department of Finance. E-1 Population and Housing Estimates for Cities, Counties, and the State – January1 2024 and 2025.

Accessed June 2025: https://dof.ca.gov/forecasting/demographics/estimates-e1/ 3 City of Clovis. General Plan land Use Element Table LU-1. Accessed June 2025: https://cityofclovis.com/wpcontent/uploads/2018/10/Table-LU-1.pdf 4 Fresno Council of Governments. Fresno County 2023-2060 Growth Projections. Accessed June 2025: https://agendas.fresnocog.org/wpcontent/uploads/2024/10/2024-Fresno-COG-2023-2060-Growth-Projections-Draft.pdf

City of Clovis
Infill Rezone Program

4.11-2
b. Projected Population Growth
In October 2024 the Fresno COG completed population growth projections through 2060 to assist with updating the Fresno COG Regional Transportation Plan (RTP) and the Sustainable Communities Strategy (SCS). The Fresno COG projections cover the SOIs of each of the county’s 15 cities and the unincorporated area outside the cities’ SOIs. Fresno COG’s overall county population projection is lower than both the 2024 DOF projections and the previous Fresno COG projections for 2050 (prepared in 2020). To support the RTP/SCS process, Fresno COG disaggregated the countywide population projection to the city SOI level using a population cohort survival model that accounted for age- and race-adjusted birthrate and death rate factors to estimate the natural change in population, as well as in-migration and out-migration patterns. Fresno COG also accounted for each city’s long-term development capacity based on adopted general plans. These lower projections are largely due to updated data on birth and mortality, as well as jurisdiction specific development capacity, and building activity.

Table 4.11-2 shows Fresno COG’s population projections in five-year increments from 2022 through 2060. Fresno COG projections suggest a continuation of the historic trend of an increasing percentage of population growth occurring in Fresno County’s bigger cities, compared with the unincorporated areas. Between 2022 and 2060, 96.7 percent of the population change is projected to occur in cities’ SOIs, of which 47 percent is expected to occur within the city of Fresno, and 26 percent is expected to occur within the city of Clovis.

4.11.2 Regulatory Setting
a. Federal Regulations
There are no applicable federal regulations on population and housing that are applicable to the project.
b. State Regulations
California Housing Law
California Housing Element law (Government Code Sections 65580 to 65589.8) requires that local jurisdictions outline the housing needs of their community, the barriers or constraints to providing that housing, and actions proposed to address these concerns over an eight-year planning period. In addition, Housing Element law requires each city and county to accommodate its “fair share” of the region’s projected housing need over the Housing Element planning period. Cities and counties must demonstrate that adequate sites are available to accommodate this need, and that the jurisdiction allows for development of a variety of housing types. This housing need requirement is known as the Regional Housing Needs Allocation (RHNA) and apportions to each jurisdiction a projected need. The City of Clovis 2023-2031 Housing Element was certified by the California Department of Housing and Community Development (HCD) on December 17, 2024. 5 5 City of Clovis. Sixth Cycle Housing Element. 2024. Accessed May 2025: https://cityofclovis.com/planning-anddevelopment/planning/planning-projects/housing-element-update/

Environmental Impact Analysis
Population and Housing
Environmental Assessment 4.11-3
Table 4.11-2 Fresno County Population Forecasts (2022 to 2060) Cities (within SOIs) 2022 2025 2030 2035 2040 2045 2050 2055 2060 Percent of Total
Change 2023-2060
Clovis 126,960 129,050 136,500 142,490 148,310 153,300 156,650 158,000 157,380 25.8% Coalinga 17,290 17,300 17,530 17,770 17,990 18,190 18,320 18,370 18,350 0.9% Firebaugh 8,420 8,410 8,670 8,830 8,990 9,120 9,210 9,250 9,230 0.7% Fowler 7,310 7,660 8,240 8,910 9,550 10,110 10,480 10,630 10,560 2.8% Fresno 592,280 595,370 605,800 617,840 629,520 639,540 646,260 648,980 647,730 47.0% Huron 6,170 6,230 6,260 6,390 6,520 6,630 6,710 6,740 6,720 0.50% Kerman 16,830 17,360 18,510 19,650 20,750 21,700 22,340 22,600 22,480 4.8% Kingsburg 12,750 13,210 13,750 14,550 15,340 16,010 16,460 16,650 16,560 3.2% Mendota 12,500 12,530 130,70 13,400 13,710 13,980 14,170 14,240 14,210 1.5% Orange Cove 9,590 9,600 9,670 9,780 9,890 9,990 10,050 10,070 10,060 0.4% Parlier 15,030 15,040 15,060 15,200 15,340 15,450 15,530 15,560 15,550 0.4% Reedley 25,290 25,830 25,900 26,740 27,550 28,250 28,710 28,900 28,820 3.0% Sanger 27,040 27,040 27,540 27,940 28,330 28,670 28,900 28,990 28,940 1.6% San Joaquin 3,670 3,610 3,640 3,670 3,700 3,720 3,740 3,750 3,740 0.1% Selma 26,540 26,650 28,250 29,150 30,030 30,790 31,290 31,490 31,400 4.1% Subtotal Cities 907,671 914,890 938,390 962,301 985,520 1,005,450 1,018,820 1,024,220 1,021,730 96.7% Unincorporated 102,880 103,050 103,280 104,290 105,280 106,120 106,680 106,910 106,800 3.3% Total County 1,010,550 1,017,950 1,041,670 1,066,610 1,090,820 1,111,570 1,125,490 1,131,120 1,128,530 100.0% Source: Fresno Council of Governments. 2025.

City of Clovis
Infill Rezone Program

4.11-4
Regional Housing Needs Allocation Plan
California’s Housing Element law requires that each county and city develop local housing programs to meet their “fair share” of future housing growth needs for all income groups, as determined by the DOF. The regional councils of government (COGs), including Fresno COG , are then tasked with distributing the State-projected housing growth need for their region among their city and county jurisdictions by income category. This fair share allocation is referred to as the RHNA process. The RHNA represents the minimum number of housing units each community is required to plan for through a combination of: 1) zoning “adequate sites” at suitable densities to provide affordability; and 2) housing programs to support production of below-market rate units. Table 4.11-3 shows Fresno County’s allocation from the 2013 RHNA Plan distributed among the four income categories.

These categories include: very low (up to 50 percent of area median income); low (between 51 and 80 percent of area median income); moderate (between 81 and 120 percent of area median income); and above moderate income. The City of Clovis is responsible for accommodating a total of 8,977 housing units within the 6th Cycle Housing Element.

Table 4.11-3 Fresno COG Unincorporated Area Housing Needs Allocations Jurisdiction Very Low Low Moderate Above Moderate Total Clovis 2,926 1,549 1,448 3,054 8,977
Coalinga 157 96 89 224 566
Firebaugh 102 46 66 229 443
Fowler 94 57 47 141 339
Fresno 9,440 5,884 5,638 15,904 36,866
Huron 45 45 55 174 319
Kerman 285 134 168 476 1,063
Kingsburg 248 161 150 323 882
Mendota 129 68 97 348 642
Orange Cove 66 49 86 268 469
Parlier 147 94 108 384 733
Reedley 403 183 211 666 1,463
Sanger 412 193 245 644 1,494
San Joaquin 39 28 36 97 200
Selma 393 165 233 701 1,492
Unincorporated County 706 391 370 883 2,350
Total 15,592 9,143 9,047 24,516 58,298
Source: Freno COG RHNA Plan 2022. 2025.

The Sustainable Communities and Climate Protection Act of 2008 (Senate Bill 375, Steinberg)
Senate Bill (SB) 375 focuses on aligning transportation, housing, and other land uses to achieve regional greenhouse gas (GHG) emission reduction targets established under the California Global Warming Solutions Act, also known as Assembly Bill (AB) 32. SB 375 requires Metropolitan Planning Organizations (MPO) to develop a SCS as part of the RTP, with the purpose of identifying policies and strategies to reduce per capita passenger vehicle-generated GHG emissions. As set forth in SB

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375, the SCS must: (1) identify the general location of land uses, residential densities, and building intensities within the region; (2) identify areas within the region sufficient to house all the population of the region, including all economic segments of the population, over the course of the planning period; (3) identify areas within the region sufficient to house an eight-year projection of the regional housing need; (4) identify a transportation network to service the regional transportation needs; (5) gather and consider the best practically available scientific information regarding resource areas and farmland in the region; (6) consider the state housing goals; (7) establish the land use development pattern for the region that, when integrated with the transportation network and other transportation measures and policies, will reduce GHG emissions from automobiles and light-duty trucks to achieve GHG emission reduction targets set by the California Air Resources Board (CARB), if there is a feasible way to do so; and (8) comply with air quality requirements established under the Clean Air Act.

The City of Clovis is located in the jurisdiction of Fresno COG, a Joint Powers Agency established under California Government Code Section 6502 et seq. Pursuant to federal and State law, Fresno COG serves as a COG, a Regional Transportation Planning Agency, and the MPO for Fresno County.

Fresno COG is responsible for the RTP, and meeting HCD’s RHNA in coordination with other State and local agencies. These documents include population, employment, and housing projections for the region.

Existing law requires local governments to adopt a housing element as part of their general plan and update the housing element every four to eight years. SB 375 requires the RHNA to allocate housing units within the region in a manner consistent with the development pattern adopted by the SCS.

Assembly Bill 1763
AB 1763, effective January 1, 2020, amends the State Density Bonus Law (Government Code Section 65915) to allow for taller and denser 100 percent affordable housing developments, especially those near transit, through the creation of an enhanced affordable housing density bonus.

California Housing Accountability Act
This State law, originally enacted in 1982 and last amended in 2017, prevents localities from disapproving proposed developments that comply with “all applicable, objective general plan, zoning, and subdivision standards and criteria,” unless they find that the development would have an unavoidable impact on public health or safety that can only be mitigated by rejecting the project or reducing its size.6 Compliance with objective standards and criteria is defined as “substantial evidence that would allow a reasonable person to conclude” that a project complies. The Housing Accountability Act also prevents localities from disapproving or reducing the size of developments that have a minimum amount of affordable housing (either 20 percent of units for lower-income households or 100 percent of units for moderate-income households), except under specific circumstances. Mixed-use developments with at least two-thirds of their square footage devoted to residential use also qualify for this protection.
6 California Government Code. § 65589.5. Accessed June 2025:
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201920200SB330^

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Senate Bill 35
In 2017, California enacted SB 35 to streamline the approval of affordable housing projects. This law applies in localities that are not meeting their RHNA goals for construction of above-moderate income housing units or units for households below 80 percent of the area median income (AMI).

These thresholds under SB 35 apply to the City of Clovis. Applicable localities are required to streamline the approval of eligible housing projects by providing a ministerial approval process. To qualify for streamlining, a project must meet all of a range of criteria related to affordability, including but not limited to the number of units, residential zoning, floor area dedicated to residential uses, environmental constraints, demolition of residential units, historic buildings, and consistency with objective zoning standards. The California Environmental Quality Act (CEQA) review is not required for eligible projects because they are subject to a ministerial approval process.

Housing Crisis Act
The Housing Crisis Act of 2019 (SB 330) seeks to speed up housing production in the next half decade by eliminating some of the most common entitlement impediments to the creation of new housing, including delays in the local permitting process and cities enacting new requirements after an application is complete and undergoing local review—both of which can exacerbate the cost and uncertainty that sponsors of housing projects face. In addition to speeding up the timeline to obtain building permits, the bill prohibits local governments from reducing the number of homes that can be built through down-planning or down-zoning or the introduction of new discretionary design guidelines. The bill is in effect as of January 1, 2020, and expires on January 1, 2030.

SB 330 also regulates demolition of existing housing. It prohibits urbanized jurisdictions from approving a housing development that requires demolition of residential units unless the project creates at least as many units as would be demolished. Local jurisdictions also are prohibited from approving a project that would demolish occupied or vacant “protected units,” unless the project meets several criteria (e.g., replacing all protected units, providing relocation benefits, and giving a right of first refusal to displaced residents for comparable units in the new development). Protected units are defined as subject to a covenant, ordinance, or law that restricts rent to levels affordable to people and families of lower or very low income; subject to rent control; or occupied by low or very low-income households; among other factors. These requirements for demolition do not supersede local demolition controls that are more protective of lower income households. c. Local Regulations
Fresno Council of Governments
The Fresno COG represents Fresno County and the cities of Clovis, Coalinga, Firebaugh, Fowler, Fresno, Huron, Kerman, Kingsburg, Mendota, Orange Cove, Parlier, Reedley, San Joaquin, Sanger, and Selma. As a regional planning agency, Fresno COG serves as a collaborative forum for addressing regional issues related to transportation, economic development, community planning, and environmental sustainability.

Regional Transportation Plan
Fresno COG’s most recent Regional Transportation Plan and Sustainable Communities Strategy (RTP/SCS) was adopted in 2022 and outlines a long-range vision through 2046. This plan addresses the region’s growing population and evolving transportation needs while aiming to reduce

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greenhouse gas emissions and promote sustainable development. The RTP/SCS is structured around key elements including policy direction, investment strategies, air quality compliance, and financial planning. The plan emphasizes multimodal transportation options, transit-oriented development, and equity in access to mobility. Fresno COG is currently in the process of developing the 2026 RTP/SCS, with public engagement and draft materials available through its dedicated planning portal.

Regional Housing Needs Allocation Plan
The Fresno County RHNA Plan is a state-required document updated every eight years. It guides cities and counties in planning for future housing needs as part of their general plans. The 2023– 2031 RHNA Plan is Fresno COG’s latest housing allocation strategy, developed in coordination with the HCD. The HCD assigns RHNA targets to Fresno COG, which then distributes these housing unit allocations to jurisdictions throughout Fresno County using a defined methodology. According to the 2023–2031 RHNA Plan, the City of Clovis is projected to need 8,977 new housing units during this cycle.

City of Clovis General Plan Housing Element
The Housing Element is one of the required elements of the Clovis General Plan, and the most recent version was certified by HCD on December 17, 2024, covering the eight year period of 2023- 2031. The Housing Element assesses current and projected housing needs and sets out policies and proposals for the improvement of housing. Additionally, the Housing Element ensures the provision of adequate sites for housing to meet the needs of all economic segments of the City as determined by the City’s RHNA described above. As described in Chapter 2, Project Description, the need to rezone for at least 1,284 affordable housing units was a result of the Judgment related to the carryover of unmet housing units from the City’s 4th cycle Housing Element that were not accommodated in the City’s 5th cycle Housing Element, and this infill rezoning program is independent of any rezoning programs required to fulfill the City’s RHNA for the current 6th cycle Housing Element. The following are policies from the relevant General Plan Elements that would be applicable to the project.

Housing Element
Policy H-1.1 Housing Production Target. Maintain an adequate supply of appropriately zoned land to support the production of at least 8,977 housing units in Clovis between 2023 and 2031 to accommodate the local and regional housing need.

Policy H-2.6 No Net Loss of Housing Stock. Ensure that sites being redeveloped for housing do not result in a net reduction in housing units, consistent with Government Code Section 66300(d).

City of Clovis Municipal Code
The City of Clovis Municipal Code establishes regulations and requirements for each zone. Title 9, Development Code, regulates the distribution and intensity of land uses in such categories as residential, commercial, and industrial. The Development Code establishes allowable uses, minimum lot size, building height and setback limits, parking and density within each Zoning District.

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4.11-8

4.11.3 Impact Analysis
a. Methodology and Significance Thresholds
Methodology
The proposed project does not involve specific development projects and so the project itself would not result in direct physical changes to population or housing. However, effects on population and housing could occur as a result of development facilitated by the proposed land use and zoning changes throughout Clovis. Future development projects could replace existing housing units or add additional units, increasing Clovis’s population. Population growth could result in physical changes related to transportation, air quality, noise, and public services and utilities, as well as other environmental topics and resource areas. Population growth and housing are studied in this section.

Other physical impacts are analyzed under the other sections analyzing environmental topics in this Environmental Assessment (EA).

Significance Thresholds
In accordance with Appendix G of the CEQA Guidelines, the proposed project would result in a significant impact on the environment related to population and housing if it would:

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); or
Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.

Pursuant to the provisions of GC § 65759, and in substantial conformance with the criteria, standards, and procedures of CEQA enacted in 1970, as amended (Public Resources Code, § 21000 et seq.), and the State CEQA Guidelines (California Code of Regulations Title 14 § 15000 et seq.) this EA considers the project’s growth-inducing impacts, and the applicable CEQA Guidelines provide that the EA “should not assume that growth is necessarily beneficial, detrimental, or of little significance.” The underlying purpose of the proposed Housing Element Implementation project is to accommodate housing needs, which includes needs as a result of population growth and existing growth in Clovis. Even substantial growth is not a significant impact if it accommodates growth projections for the city that can be accommodated by existing or planned facilities and services, and is consistent with the Clovis General Plan, as well as State and regional policies and regulations. As such, a significant impact for purposes of this threshold is whether the updates to the Housing Element will induce unplanned growth.

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b. Project Impacts and Mitigation Measures
Threshold 1: 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)? Impact POP-1 IMPLEMENTATION OF THE PROPOSED PROJECT WOULD FACILITATE DEVELOPMENT OF AN ASSUMED 1,303 ADDITIONAL HOUSING UNITS IN THE CITY AND ADD AN ESTIMATED 3,662 RESIDENTS.

GROWTH RESULTING FROM THE PROJECT IS ANTICIPATED AND WOULD NOT INVOLVE SUBSTANTIAL UNPLANNED POPULATION GROWTH. THIS IMPACT WOULD BE LESS THAN SIGNIFICANT.

Development under the proposed project could add an assumed 1,303 additional residential units (up to 1,651 in the maximum potential buildout) in the city compared to existing conditions. In order to facilitate affordable housing development in the city consistent with the provisions of the court judgment, the project will rezone and redesignate 20 sites to allow for an increase in permitted densities (see Chapter 2, Project Description). This additional housing would lead to an estimated increase of approximately 3,662 residents in the city with a maximum potential increase of 4,640 residents.

As discussed in Chapter 2, Project Description, the need for at least 1,284 affordable housing units was a result of a court judgment related to the City’s 4th and 5th cycle Housing Element and the rezoning and redesignation is independent of any rezoning programs from the current 6th cycle Housing Element. The HCD requires local jurisdictions to identify sufficient housing sites to cover the jurisdiction’s RHNA. According to State law, a housing element must address the City's fair share of the regional housing need and specific State statutory requirements and must reflect the vision and priorities of the local community. The City was unable to meet its 4th Cycle Housing Element RHNA for lower income households. This shortfall triggered a statutory requirement under California housing law to rezone sufficient land within the first year of the 5th cycle to accommodate the unmet need.7 The Judgment in 2024 determined the City failed to rezone sufficient property during the 5th cycle to accommodate the unmet need carried over from the 4th cycle. Accordingly, the project is separate and independent from the rezone program as part of the City’s 6th Cycle 2023 – 2031 Housing Element. This rezoning to meet the minimum of 1,284 housing units was planned for in previous housing element cycles.

Fresno COG’s more recent estimates have the Clovis population at 166,160 by the year 2050, 57 percent of the total buildout anticipated by the City’s General Plan. The total increase in city residents from development facilitated by the project is 4,640 residents. This would increase the existing 129,121 population to 133,761 residents, well under the Clovis General Plan 2014 buildout calculations at a total buildout of 294,000. Population growth facilitated by the project would equal

1.6 percent of the total capacity of the city under the framework of the existing General Plan.

The project would not involve the extension of roads or other infrastructure since project development would be constructed within City limits and connected to existing infrastructure systems in the area on infill sites. The proposed rezoning is intended to meet the RHNA of a prior housing element based on accommodating projected population increases in the region at the time.

The project is not driving newly anticipated growth, but facilitating development that was expected to occur, regardless of the rezoning, ensuring the city can respond appropriately to anticipated regional housing needs. Additionally, the total population growth of the project is only 1.6 percent 7 California Government Code § 65583(c)(1). California Legislative Information. Accessed June 2025:
https://codes.findlaw.com/ca/government-code/gov-sect-65583/

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of the total anticipated buildout of the city under the existing General Plan. This would have a less than significant impact.

Threshold 2: Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere? Impact POP-2 IMPLEMENTATION OF THE PROPOSED PROJECT WOULD NOT RESULT IN THE DISPLACEMENT OF SUBSTANTIAL NUMBERS OF PEOPLE OR HOUSING. THE PROPOSED PROJECT WOULD FACILITATE THE DEVELOPMENT OF NEW HOUSING AT HIGHER DENSITIES. THIS IMPACT WOULD BE LESS THAN SIGNIFICANT.

Nine of the Infill Rezone Program sites are vacant; there are no existing housing units or temporary housing accommodations on those project sites. Therefore, the project would not displace existing housing units or people on these sites. Another nine of the sites are currently occupied with low density uses such as single family homes on a large lot. Two of the sites contain buildings currently used for commercial businesses. Development facilitated as a result of the project on sites with existing units would replace any existing residences at greater densities than with previous zoning and land use designations. Existing Housing Element programs and policies, such as Policy H-2.6 No Net Loss of Housing Stock, which ensures that sites being redeveloped for housing do not result in a net reduction in housing units, consistent with state law8 , reduce the impact on displacement of
people due to future housing development by requiring replacement of any housing being replaced.

The project sites would be rezoned and redesignated to ensure that development would occur at higher densities than under existing zoning and General Plan Land Use designations. There would be a less than significant impact on substantial numbers of existing people or housing being displaced from development facilitated by the project.

Mitigation Measures
No mitigation measures are required.

4.11.4 Cumulative Impacts
The geographic scope of cumulative impacts of population and housing is the entire region, as housing availability in the City of Clovis can affect if people need to move to neighboring areas in the region to find housing. Therefore, this cumulative impact analysis is based on Fresno COG’s 2022 RTP/SCS and Fresno County’s most recent RTP/SCS. The proposed Infill Rezone Program would accommodate projected citywide population and housing growth under the City’s 4th cycle Housing Element. By its nature, the impact analysis under Impact POP-1, discussed above, considers cumulative impacts associated with population growth throughout the city and consistent with the Clovis General Plan. The proposed project incorporates regional growth anticipated by Fresno COG’s 4th housing cycle RHNA projections and thus considers cumulative growth. The proposed project would therefore not considerably contribute to a significant impact associated with unplanned population growth.

Implementation of the proposed project would accommodate the need for affordable housing as required by the terms of a judgment entered in the Martinez v. City of Clovis case in March 2024.

The proposed project would result in an overall net increase of affordable housing units in the city, as discussed in Chapter 2, Project Description, and would not result in substantial displacement of people or housing. The project would directly result in the demolition of some existing housing units 8 California Government Code § 66300(d). (2023). California Legislative Information. Accessed June 2025:
https://codes.findlaw.com/ca/government-code/gov-sect-66300/

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within the city; however, development facilitated by the project would allow for more units beyond what was demolished on each of those Infill Rezone Program sites. The 20 Infill Rezone Program sites were selected to minimize the loss of existing housing and to promote the growth of affordable housing. Continued implementation of existing City regulations and the 2023-2031 Housing Element would also preserve existing housing stock and assist those at risk of displacement. As a result, implementation of the proposed project would not considerably contribute to a significant cumulative impact from the displacement of substantial numbers of existing housing units or people.

Mitigation Measures
No mitigation measures are required.

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4.12 Public Services and Recreation
This section assesses potential impacts related to public services, including fire and police protection, public schools, parks and recreation facilities from the rezoning facilitated by the project. Impacts on water and wastewater infrastructure and solid waste collection and disposal are discussed in Section 4.16, Effects Found Not to be Significant.

4.12.1 Setting
a. Fire Services and Emergency Medical Services
Clovis Fire Department
The Clovis Fire Department (CFD) participates in a statewide mutual-aid system that provides fire department resources throughout the State of California. On a local basis, CFD provides fire protection to the City of Clovis and supplements protection through an automatic aid agreement with the Fresno Fire Department west and south of the City’s Sphere of Influence (SOI) and the Fresno County Fire Protection District (FCFPD) to the north and east of the City’s SOI.

The CFD represents 20 square miles and approximately 123,665 residents. The CFD operates six fire stations and one training center. Each station contains a minimum staffing capacity of 19 staff members per shift, including one battalion officer, six captains, six engineers, and six firefighters. A summary of the station locations and equipment is provided in Table 4.12-1.

Table 4.12-1 Clovis Fire Department Stations
Station Address Equipment
Station 1 633 Pollasky Avenue Truck, Reserve Truck
Station 2 2300 Minnewawa Avenue Engine, Reserve Engine, Urban Search and Rescue Unit Station 3 555 North Villa Avenue Engine, Reserve Engine Station 4 2427 Armstrong Avenue Engine, Water Tender, Brush Engine Station 5 790 North Temperance Avenue Engine, Hazmat Unit, OES Engine Station 6 2388 Encino Avenue Engine
Source: City of Clovis Emergency Services, 2025
The CFD 2022-2027 Strategic Plan indicates the CFD has a response time goal of arrival within four minutes or less for 90 percent of calls.

Fresno County Fire Protection District
The FCFPD provides fire services on the City’s fringe and unincorporated areas in the City’s SOI.

FCFPD is one of five special districts in Fresno County that provides fire protection to the unincorporated areas of the county. There are currently two FCFPD fire stations that serve the project area. One is in the City (Station 85) and one outside of the SOI (Station 86). A summary of the equipment and staffing at these two stations is provided in Table 4.12-2.

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Table 4.12-2 Fresno County Fire Protection District Equipment Summary Station Address Equipment
North Clovis Station 85 1392 Nees Avenue Type I, Triple Combination Pumper (Fire Engine), ¾ Ton Common Vehicle
Clovis Lakes Station 86 4925 N Nelson Avenue Type I, Triple Combination Pumper (Fire Engine), Type I, Heavy Water Tender
Source: Fresno County Fire Protection District, 2025
b. Police Services
The Clovis Police Department (CPD) provides police protection services for Clovis. The department is comprised of 219 employees, of which 116 are sworn officers. The department includes a Patrol Division, Communications Division, Investigations Division, Youth Services Division, Support Services Division, Animal Services Division, and Administration Division, working with the community to address crime and quality of life issues. The City of Clovis Police Department 2024 End of Year Report indicates the CPD has an average response time of 3.1 to 4.5 minutes. c. Schools
The Clovis Unified School District (CUSD) operates 18 elementary schools (K-5th grade), three middle schools (6th-8th grade), three high schools (9th-12th grade), and five alternative education/other schools (community day schools, Special Day Class (SDC) schools, charter, continuation, and coeducational schools) within the City of Clovis. CUSD operates 15 grade schools and two middle and high schools within the City of Fresno. The Fresno County Office of Education operates an additional elementary school, Clovis Global Academy, within city limits. There are also six private schools operating in the city. Table 4.12-3 lists the schools, location, and 2023-2024 enrollment for all schools in Clovis. The locations of these schools are shown on Figure 4.12-2. In addition to the schools listed below, the Terry P. Bradley Educational Center opened for the 2025-2026 school year.

The Terry P. Bradley Educational Center is CUSD’s fourth educational center, and is home to Clovis South High School, Phillip V. Sanchez Intermediate School, and a future elementary school, with an estimated capacity of 1,500 middle school and 2,500 high school students. Elementary school capacity is not yet known.

The District’s school building capacity in 2024 was determined to be 22,040 for grades TK-6, 6,486 for grades 7-8, 12,494 for grades 9-12, and 342 for SDC Severe 1 . With the addition of the Terry
Bradley Education Center, CUSD’s capacity for grades 7-8 increases to 7,986, and grades 9-12 increases to 14,994. CUSD spans across the City of Clovis and the City of Fresno. For the purposes of this project, this analysis focuses on schools in Clovis. However, CUSD schools within the City of Fresno are available for students living within Clovis city limits which would support student capacity. Table 4.12-3 shows each schools enrollment and Table 4.12-4 breaks down the facility capacity for each grade level within the City of Clovis. 2

1 School Facilities Needs Analysis. https://files.smartsites.parentsquare.com/6245/clovis_usd_sfna_2025.pdf 2 Table 4.12-3 only represents CUSD capacity within the City of Clovis; however, CUSD schools within the City of Fresno would be available to students within Clovis city limits if Clovis schools are over capacity.

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Figure 4.12-1 Fire and Police Stations

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Table 4.12-3 Schools and Enrollment for Clovis, 2023-2024 School Name Address 2023-2024 Enrollment
Clovis Global Academy 44 Shaw Avenue 268
Clovis Community Day Elementary 1715 David E Cook Way 4 Clovis Community Day Secondary 1715 David E Cook Way 38 Woods (Harold L.) Elementary 700 Teague Avenue 748
Reagan Elementary 3701 Ashlan Avenue 762
Bud Rank Elementary 3650 Powers Avenue 748
Clovis Online School 1655 David E Cook Way 667
Enterprise Alternative High School 1550 Herndon Avenue 52 Gateway High School 1550 Herndon Avenue 233
Buchanan High School 1560 North Minnewawa Ave. 2,668
Clovis East High School 2940 Leonard A Avenue 2,632
Clovis High 1055 Fowler Avenue 2,302
Cole Elementary 615 West Stuart Ave. 592
Dry Creek Elementary 1273 North Armstrong Avenue 735
Jefferson Elementary 1880 Fowler Avenue 532
Tarpey Elementary 2700 Minnewawa Avenue 652
Sierra Vista Elementary 510 Barstow Avenue 532
Weldon Elementary 150 DeWitt Avenue 532
Clark Intermediate 902 Fifth Street 1,276
Miramonte Elementary 1590 Bellaire Avenue 532
Mickey Cox Elementary 2191 Sierra Avenue 662
Gettysburg Elementary 2100 Gettysburg Avenue 592
Red Bank Elementary 1454 Locan Avenue 626
Alta Sierra Intermediate 380 West Teague Avenue 1,302
Garfield Elementary 1315 North Peach Avenue 565
Cedarwood Elementary 2851 Palo Alto Avenue 701
Clovis Elementary 1100 Armstrong Avenue 730
Reyburn Intermediate 2901 DeWolf Avenue 1,381
Century Elementary 965 North Sunnyside Avenue 592
Freedom Elementary 2955 Gettysburg Avenue 748
Charlie Keyan Armenian
Community School
108 North Villa Avenue N/A
Valley Crescent School 547 West Nees Avenue N/A
Clovis Christian School 3105 Locan Avenue N/A
Spectrum Center Clovis 30 W Shaw Avenue
Clovis, CA 93612
N/A
Our Lady of Perpetual Help 836 Dewitt Avenue N/A
Sierra View Christian Academy 3268 Wrenwood Avenue N/A
Total 36 23,752 (excluding schools
without attendance data)
Source: Clovis Unified School District

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Figure 4.12-2 Public Schools in Clovis 3

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Table 4.12-4 Clovis Unified School District Facility Capacity in the City of Clovis Grade Level Facilities Capacity District Enrollment (2024) Over Capacity? TK-6 10,859 11,472 Yes
7-8 3,959 4,596 Yes
9-12 7,602 8,305 Yes
Special Day Class (SDC) Severe 342 1,395 Yes
d. Parks and Recreational Facilities
The City categorizes its parks and recreational facilities based on type, acreage, and population served. These classifications are listed in Table 4.12-5. The City owns and/or operates 12 area parks, 11 basin parks, 5 community parks, 65 neighborhood parks, and 10 pocket parks, for a total of 323 acres of park space provided by the City. The City also has an agreement with CUSD that allows for the use of school recreational facilities by Clovis residents outside of school hours.

Basin parks operated by the Fresno Metropolitan Flood Control District (FMFCD) are also available for the City’s recreational needs. The uses of basin parks are limited to dry periods, due to their first priority as flood control facilities, and only acreages available for recreational purposes are listed in Table 4.12-6. Recreational opportunities are provided to residents through a contractual agreement between FMFCD and the City. There are currently three basin parks in the City that are approximately to 21.13 acres in total.

The State has an established parkland-to-population recommendation of 4.0 acres of parkland per 1,000 persons. The City’s 2024 population was estimated to be 129,121 and maintains approximately 2.2 acres of parkland per 1,000 persons.

Clovis Recreation (CAR) Department also provides recreational programs including adult and youth sports programs, leagues, and drop-in games. CAR provides basketball, softball, indoor co-ed soccer, floorball, and inline hockey leagues at the City of Clovis Recreation Center and Rotary Park.

Additional recreational facilities include a batting range at Sierra Bicentennial Park and a 27,000- square foot skate park at Letterman Park.

In addition to these facilities, the City maintains 28 miles of trails, including the Clovis Old Town trail, Dry Creek Trail, Enterprise Trail, and PG&E Trail. The City also partners with the Fresno Irrigation District under the Master Clovis Trails and Right-of-Way Use Agreement and Memorandum of Interpretation, which allows the City to connect existing trails and extend the trail system by using canal banks.

The City’s current inventory of parks and recreational facilities are outlined in Table 4.12-5 and listed in Table 4.12-6 City Parks.
3 Two schools (Enterprise Alternative High School and Gateway High School) share the same campus, resulting in the depiction of 34 schools in Figure 4.12-2 compared to the 36 schools listed in Table 4.12-4.

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Table 4.12-5 Park Classifications
Classification
Acres (per
1,000 population) Size Range (acres) Population Served Service Radius Pocket Park – Up to 1 Up to 500 Sub neighborhood
Neighborhood Park 1 1-2 500-2,500 ¼ mile
Area Park 1-2 3-20 2,000-10,000 ¼ - ½ mile
Community Park 2-5 15-100 10,000-50,000 ½ - 3 miles
Regional Park 5 100+ Entire population Within ½ hour
School Park (Clovis Unified
School District Campuses)
– 20-40 Varies Neighborhood to
community-wide
Basin Park – Varies Varies Neighborhood to
community-wide
Table 4.12-6 City Parks
Park Park Area (acres)
Deauville 3.67
Town & Country 0.58
Town & Country 1.06
Pinnacles 1.05
Northwood Estates 0.49
Rancho Paloma II 0.98
Century 5.00
Cambridge Colony 1.34
Quail Hollow 1.43
Williamsburg Manor II 0.65
Sierra Bicentennial 17.69
Bean 0.72
Treasure Ingmire 1.44
Fox Run 1.94
Rotary 13.30
Westcal 1.03
Monte Vista 21 1.02
Letterman 8.73
Monte Vista 10 0.99
Silverton 2 0.84
California Countrywood 1.67
Thorburn 3.87
San Gabriel 2.98
Helm and Holland 0.17
Basin 1E 0.42
Gettysburg 4.76
Summit 5 1.41

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Infill Rezone Program

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Park Park Area (acres)
Summit 4 1.18
Seville Estates 2 0.79
Westcal II 2.64
Kiwanis 0.27
Fifth/Harvard 0.18
Music 0.17
Los Arbolitos 2.86
Cell Tower 1.27
Village Green 6.22
Pasa Tiempo 5.27
Basin DP 32.62
Basin DO 31.40
Basin BW 10.04
Basin BC 23.43
Basin 5F 7.69
Basin 5B5C 19.39
Basin 4E 19.99
Basin 4D 4.96
David McDonald 12.29
Dry Creek 9.37
Bermuda Triangle 1.03
European Parc 1.27
Tract 5486 0.37
Tract 5486 0.64
Harlan Ranch 3.70
Sun River 0.35
Countryside 1.05
Portland 0.35
Railroad 6.51
Tract 6107 0.60
Tract 6086 0.21
Tract 6107 0.42
Sierra View 0.85
Palmina 1.56
East West 1.40
Gallery 0.49
Tract 5194 1.08
Cottonwood 2.95
Blackhorse Estates II 0.65
Monte Vista 31 0.93

Environmental Impact Analysis
Public Services and Recreation
Environmental Assessment 4.12-9
Park Park Area (acres)
Monte Vista 26 0.30
TR 5605 0.30
Pump House 0.78
Wawona Ranch Dry Creek Trail 1.85
Chadwick 0.24
Helm Ranch 2.01
Regent 0.36
Santerra 0.12
Wooten 1.97
Deauville East 0.92
Descanso 0.41
Bloom Field 3.20
Pasa Tiempo North 1.60
Arrowhead 0.29
Bunny 0.28
Regent 0.30
Dry Creek Trailhead 2.10
Tract 5486 0.44
Tenaya Sun Ranch 0.06
Bullard/Fifth Couplet 0.10
Liberty 0.67
Johnboy 0.79
Tract 4532 0.42
Tract 4532 0.77
Tract 4998 0.62
Soledad 0.99
Lennar 1.50
Birchwood Estates 0.64
Linear 1.54
Total 323.24

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Infill Rezone Program

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Figure 4.12-3 City Parks

Environmental Impact Analysis
Public Services and Recreation
Environmental Assessment 4.12-11

4.12.2 Regulatory Setting
a. State Regulations
Fire Protection
California Fire and Building Code
The State of California provides minimum standards for building design through the California Building Code (CBC), which is located in Part 2 of Title 24, California Building Standards Code, of the California Code of Regulations (CCR). The CBC is based on the International Building Code but has been amended for California conditions. It is generally adopted on a jurisdiction-by-jurisdiction basis, subject to further modification based on local conditions. Every three years, the California Fire Code is reviewed and modified where applicable and adopted by the California Building Standards Commission. The California State Fire Marshals Office has adopted the most recent California Fire Code (CFC). The City of Clovis Municipal Code 4.4.101 and 4.4.102 contains these standards, which are adopted or modified as necessary to ensure the safety of the community based on unique climatic, geological or topographical conditions. Commercial and residential buildings are planchecked by Prevention personnel within CFD for compliance with the CFC. Typical fire safety requirements of the CFC include: the installation of sprinklers in all high-rise buildings; the establishment of fire resistance standards for fire doors, building materials, and particular types of construction; and the clearance of debris and vegetation within a prescribed distance from occupied structures in wildfire hazard areas.

California Code of Regulations
The CCR, Title 5 Education Code, governs all aspects of education within the State. California State Assembly Bill (AB) 2926 – School Facilities Act of 1986 – was enacted by the State of California in 1986 and added to the California Government Code (Section 65995). It authorizes school districts to collect development fees, based on demonstrated need, and generate revenue for school districts for capital acquisitions and improvements. It also established that the maximum fees which may be collected under this and any other school fee authorization are $1.50 per square foot ($1.50/ft2 ) for
residential development and $0.25/ft2 for commercial and industrial development. AB 2926 was expanded and revised in 1987 through the passage of AB 1600, which added Section 66000 et seq. of the Government code. Under this statute, payment of statutory fees by developers serves as total mitigation under the California Environmental Quality Act (CEQA) to satisfy the impact of development on school facilities. However, subsequent legislative actions have alternatively expanded and contracted the limits placed on school fees by AB 2926.

California Fire Service and Rescue Emergency Aid System Clovis Fire Department participates in the California Fire Service and Rescue Emergency Mutual Aid System through which the California Governor’s Office of Emergency Service (OES), Fire and Rescue Division is responsible for the development, implementation and coordination of the California Fire Service and Rescue Emergency Mutual Aid Plan (Mutual Aid Plan) (Governor’s Office of Emergency Services, Fire and Rescue Division 2023). The Mutual Aid Plan outlines procedures for establishing mutual aid agreements at the local, operational, regional, and State levels, and divides the State into six mutual aid regions to facilitate the coordination of mutual aid. Clovis is located in Region V.

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Through the Mutual Aid Plan, the OES is informed of conditions in each geographic and organizational area of the state, and the occurrence or imminent threat of disaster.

California Governor’s Office of Emergency Services (Cal OES) In 2009, the State of California passed legislation creating the Cal OES and authorized it to prepare a Standard Emergency Management System (SEMS) program (Government Code (GC) Section 8607; Title 19 CCR Section 2401 et seq.), which sets forth measures by which a jurisdiction should handle emergency disasters. In California, SEMS provides the mechanism by which local government requests assistance. Non-compliance with SEMS could result in the state withholding disaster relief from the non-complying jurisdiction in the event of an emergency disaster. Cal OES coordinates the state’s preparation for, prevention of, and response to major disasters, such as fires, floods, earthquakes and terrorist attacks. During an emergency, Cal OES serves as the lead state agency for emergency management in the state. It also serves as the lead agency for mobilizing the state’s resources and obtaining federal resources. Cal OES coordinates the state response to major emergencies in support of local government. The primary responsibility for emergency management resides with local government. Local jurisdictions first use their own resources and, as they are exhausted, obtain more from neighboring cities and special districts, the county in which they are located, and other counties throughout the state through the statewide mutual aid system.

California Emergency Management Agency (Cal-EMA) maintains oversight of the state’s mutual aid system.

Public Schools
Senate Bill 50
The Leroy F. Greene School Facilities Act of 1998 (known as the Greene Act), enacted in 1998, is a program for funding school facilities largely based on matching funds. For new school construction, grants provide funding on a 50/50 State and local match basis. For school modernization, grants provide funding on a 60/40 State and local match basis. Districts that are unable to provide some, or all, of the local match requirement and are able to meet the financial hardship provisions and may be eligible for additional State funding through the Office of Public School Construction.

The Greene Act permits the local district to levy a fee, charge, dedication, or other requirement against any development project within its boundaries, for the purpose of funding the construction or reconstruction of school facilities. The Act also sets a maximum level of fees a developer may be required to pay. Pursuant to GC Section 65996, the payment of these fees by a developer serves to mitigate all potential impacts on school facilities that may result from implementation of a project to less than significant.

Parks and Recreation
Quimby Act (California Government Code Section 66477)
California GC Section 66477, also known as the Quimby Act, was enacted by the California legislature in 1965. The Quimby Act authorizes cities and counties to enact ordinances requiring the dedication of land, or the payment of fees for park and/or recreational facilities in lieu thereof, or both, by developers of residential subdivisions as a condition to the approval of a tentative tract map or parcel map.

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Public Services and Recreation
Environmental Assessment 4.12-13
b. Local Regulations
City of Clovis General Plan
Clovis’s General Plan was adopted in August 2014 and consists of the Land Use, Economic Development, Circulation, Housing, Public Facilities and Services, Environmental Safety, Open Space and Conservation, and Air Quality Elements. All elements bear equal weight, and no element has legal precedence over another. California GC Section 65583(c) requires the Housing Element to maintain internal consistency with other General Plan Elements. The following public services and recreation policies are applicable to the project as part of the Land Use, Circulation, Environmental Safety, Open Space and Conservation, and Public Facilities and Services Elements 4 :

Land Use Element
The Land Use Element describes existing land use patterns and provides the physical framework for land use and development in the City. The Land Use Element also contains policies to improve the City’s visual quality and livability, including its compatibility between neighborhoods, mixed-use areas, commercial areas, and industrial areas. It describes the economic context and sets out goals and policies to ensure new development is planned in coordination with infrastructure, public services, and recreation.

Policies
 Policy 3.7: Development is encouraged to provide a mix of housing types, unit sizes, and densities at the block level. To accomplish this, individual projects five acres or larger may be developed at densities equivalent to one designation higher or lower than the assigned designation, provided that the density across an individual project remains consistent with the General Plan.
 Policy 5.1: The Clovis General Plan has been planned to provide a variety of housing product types suitable to each stage of a person’s life. Each development should contribute to a diversity of housing sizes and types within the standards appropriate to the land use designation.

Circulation Element
The Circulation Element describes the existing transportation patterns and provides the framework for transportation development in the City. The Circulation Element also contains goals, policies, and specific measures to improve the City’s efficiency and safety of the City’s transportation system.

Policies
 Policy 1.4: Encourage infill development that would provide jobs and services closer to housing, and vice versa, to reduce citywide vehicle miles traveled and effectively utilize the existing transportation infrastructure.
 Policy 3.4: Minimize roadway width as feasible to serve adjacent neighborhoods while maintaining sufficient space for public safety services. 4 City of Clovis General Plan, 2014.

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Environmental Safety Element
The Environmental Safety Element focuses on the protection of the community from environmental and man-made hazards, specifically regarding natural disasters, hazardous materials, and noise. The Environmental Safety Element also establishes goals, policies, and specific measures to support public services, such as law enforcement, fire protection, and emergency medical services, to minimize danger to residents, workers, and visitors.

Policies
 Policy 1.2: Maintain a water system to provide adequate peak water supply and system redundancy for firefighting services.
 Policy 1.5: Locate and design critical and public facilities to minimize their exposure and susceptibility to flooding, seismic and geological effects, fire, and explosions. Ensure critical use facilities can remain operational during an emergency.

Open Space and Conservation Element
The Open Space and Conservation Element describes existing open space, parks, productive agricultural areas, and environmental resources, and establishes goals for the maintenance and provision of new and existing state parks. The element also contains goals, policies, and specific measures to preserve and enhance open space, parks, water quality, and recreation.

Policies
 Policy 1.1: Provide a minimum of 4 acres of public parkland for every 1,000 residents.  Policy 1.2: Upgrade and rehabilitate existing parks as necessary to meet the needs of the community and as the financial resources of the city allow.  Policy 1.3: Provide a variety of parks and recreation facilities in underserved and growing areas of the community.
 Policy 1.8: Require new development to provide pocket and neighborhood parks, dedicate land for area parks, and pay impact fees for community and regional parks. Require new development to establish lighting and landscape maintenance districts to fund operations and maintenance.

Public Facilities and Services Element
The Public Facilities and Services Element defines the nature and types of public facilities, services, and activities necessary to maintain a high quality of life in Clovis. The Element aligns funding resources with the level of service the community expects, and contains goals, policies, and specific measures to maintain public safety, quality of schools, and other valued public facilities.

Policies
 Policy 1.1: New development shall pay its fair share of public facility and infrastructure improvements.
 Policy 3.4: Partner with public and private educational institutions to jointly use facilities for both civic and educational purposes.
 Policy 6.1: Maintain staffing, facilities, and training activities to effectively respond to emergency and general public service calls.

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Public Services and Recreation
Environmental Assessment 4.12-15
City of Clovis Municipal Code
The City of Clovis Municipal Code identifies land use categories, development standards, and other general provisions that ensure consistency between the City’s General Plan and proposed development projects. The following provisions from the City’s municipal code focus on park service impacts associated with new development projects and are relevant to the project:
 Chapter 3.4, Section 3.4.03 (Park Acquisition and Development Fees): Requires developers to pay a fee for new residential developments, hotels, motels, assisted living facilities, commercial, professional, and industrial buildings. The park acquisition and development fees are based on land use type and are adjusted annually to reflect actual land acquisition and construction costs.

Fees go to acquiring and furnishing future parks and recreational facilities. Refer to Table 4.12-7 for the 2025 Parks Acquisition and Development Fees.

Table 4.12-7 Park Acquisition and Development Fees
Land Use Type Fee
All Residential $6,147 per unit
Retail $0.75 per building square foot
Office $1.63 per square foot
Industrial $0.53 per building square foot
Source: City of Clovis Master Development Fee Schedule, 2024-2025 City of Clovis Parks Master Plan
The City of Clovis Parks Master Plan adopted in March 2018 provides guidance in the provision of park services to best develop, promote, utilize, manage, and maintain a functional park system for the City of Clovis. The Master Plan provides a strategic action plan for the next 5 to 10 years, which identifies methods to develop public-private partnerships to improve the parks and trails systems, and address future growth of the City and identify opportunities that will expand the City Parks Division and address the needs of the growing community in Clovis.

4.12.3 Impact Analysis
a. Methodology and Significance Thresholds
Methodology
The project involves the rezoning and redesignating of 20 Infill Rezone sites to satisfy RHNA requirements from the City of Clovis 4th cycle Housing Element as required by the Judgment. The following discussion describes the methodology used to evaluate the significance of impacts to public services and recreation from population growth facilitated by the project.

This analysis considers whether the proposed rezoning, including future development accommodated by the project, would result in impacts related to the provision of public services and recreation. Public services information was acquired through review of relevant documents from the CFD, CPD, and CUSD. The determination that the project would or would not result in substantial adverse effects concerning public services considers the relevant policies and regulations established by State, local, and regional agencies, the project’s compliance with such policies, and

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whether the project would create the need for new or expanded facilities, the construction of which could result in environmental impacts.

Significance Thresholds
According to Appendix G of the CEQA Guidelines, impacts related to public services and recreation from implementation of the project would be significant if it would:

1. Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other objectives for any of the public services:
a. Fire protection;
b. Police protection;
c. Schools;
d. Parks; or
e. Other public facilities;

2. 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; or

3. Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.

Impacts related to thresholds 1(a), 1(b), 1(c), 1(d), 1(e) for libraries, 2 and 3 are analyzed below.

Impacts related to other public facilities (Threshold 1(e)) for water, wastewater and landfills are addressed in Section 4.16, Effects Found Not to be Significant. b. Project Impacts and Mitigation Measures
Threshold 1a: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered fire protection facilities, or the need for new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives?
IMPACT PSR-1 FUTURE DEVELOPMENT FACILITATED BY THE PROJECT WOULD RESULT IN AN INCREASE OF POPULATION AND BUILDING CAPACITY WITHIN CLOVIS. THIS WOULD INCREASE DEMAND FOR FIRE PROTECTION SERVICES, WHICH COULD RESULT IN THE NEED FOR NEW OR EXPANDED FIRE PROTECTION FACILITIES.

NONETHELESS, THIS IMPACT WOULD BE LESS THAN SIGNIFICANT.

Fire protection services in Clovis are provided by the CFD which operates out of six fire stations. The project would not expand the current service area but would result in an increased population within the existing service area. The increase in residents associated with the project could increase demand for fire protection and emergency medical services such that additional staff, equipment, or facilities would be needed to meet this goal.

Development facilitated by the project would increase calls for service for issues including, but not limited to, emergency medical service, structure or vegetation fires, and traffic collisions. The direct effect on CFD would include evaluation of staffing and resource deployment to accommodate the

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increase in call volume throughout the community. In 2023, CFD responded to 13,242 incidents5 annually for approximately 123,665 residents which is approximately 0.1 incidents per resident (13,242 / 123,665 = 0.1). Therefore, development facilitated by the project is estimated to induce an additional 464 annual incidents (4,640 maximum additional residents x 0.1 incidents per resident = 464). While an increase in population could result in 2.7 percent more incidents per year, the project would increase population incrementally within planned amounts and across the 20 Infill Rezone sites as new development is proposed, which would not result in the need to construct new or expanded facilities beyond what was planned for in the Clovis General Plan. Additionally, population growth and demand for public services is acknowledged and addressed in the Clovis General Plan Environmental Safety Element.

Therefore, the project would not result in significant environmental impacts associated with the need for the provision of new or physically altered fire protection facilities, and impacts would be less than significant.

Mitigation Measures
No mitigation measures are required.

Threshold 1b: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered police protection facilities, or the need for new or physically altered police protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives? IMPACT PSR-2 DEVELOPMENT FACILITATED BY THE PROJECT WOULD INCREASE THE POPULATION IN THE CITY, WHICH WOULD INCREASE DEMAND FOR POLICE PROTECTION SERVICES. HOWEVER, THIS INCREASE WOULD NOT REQUIRE ADDITIONAL AND/OR EXPANDED POLICE PROTECTION FACILITIES. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

As discussed in Section 4.11, Population and Housing, development facilitated by the project would add an estimated 3,662 residents or a maximum 4,640 new residents to the City, increasing Clovis’s population from 129,121 to 133,761. Based on the CPD’s current staffing level of approximately 116 sworn officers, the officer/resident ratio would drop from 0.81 to approximately 0.78 sworn officers per 1,000 residents. The City currently does not have standards set for its service ratio.

Policy 6.1 in the Clovis General Plan Public Facilities and Services Element requires the City to maintain staffing, facilities, and training activities to effectively respond to emergency and general public service calls. Additional demand for police service would be accommodated through the planned expansion of policy personnel and facilities to continue to maintain adequate police protection services. Policy 6.2 of the Public Facilities and Services Element requires the City to conduct service level studies to analyze crime and emergency service performance data to evaluate the effectiveness of prevention and reduction strategies, and to allocate resources accordingly.

Police protection service levels would continue to be evaluated and maintained by CPD in accordance with existing policies, procedures and practices as development occurs over the lifetime of the project. The project would not result in a population above the Clovis General Plan projected 5 Clovis Fire Department. SOC and Annual Report. 2023. Accessed October 2025:
https://www.clovisca.gov/services/fire/about/soc_annual_report.php

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buildout, nor would it concentrate development in a single location; therefore, the project would not result in a need for additional police facilities beyond what is currently planned.

The project itself would not result in the need for new or expanded police facilities; therefore the impact would be less than significant.

Mitigation Measures
No mitigation measures are required.

Threshold 1c: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered schools, or the need for new or physically altered schools, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives?
IMPACT PSR-3 DEVELOPMENT ACCOMMODATED BY THE PROJECT WOULD RESULT IN AN INCREASE IN

STUDENT ENROLLMENT IN CLOVIS, BUT WOULD NOT RESULT IN NEW SCHOOLS BEYOND WHAT IS PLANNED OR RESULT IN SUBSTANTIAL ADVERSE PHYSICAL IMPACTS. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

The project would incrementally increase the population across the city, but it would not result in a population above the Clovis General Plan projected buildout, nor would it concentrate development in a single location; therefore, the project would not result in a need for additional or expansion of schools within the City of Clovis or CUSD as there would only be an incremental increase in students at any given school within CUSD. Implementation of the project would add an estimated 1,303 dwelling units and 3,662 new residents, in which some of those residents would be school-aged children. Based on student generation rates from CUSD6
, the project could generate an estimated
253 students, including 159 elementary school students, 33 middle school students, and 61 high school students. Although CUSD schools within the City of Clovis are over capacity, CUSD has available capacity at other schools within the district, including schools in the City of Fresno. CUSD policy is to identify available space for students in nearby schools when the closest school is at capacity. With the opening of the Terry Bradley Education Center in Fresno County, CUSD has capacity for 1,068 middle school students and 2,145 high school students prior to project approval.

CUSD manages enrollment through district-wide policies, including boundary adjustments and student transfers, ensuring that all students have access to a school within the district, even if not at a specific preferred site. Table 4.12-8 shows the breakdown of student generation from the project by grade level and estimated available capacity after the project.

Table 4.12-8 Estimated Student Generation From Project
Grade Level
Students Per
Household Dwelling Units
Total Students
Generated
District Available
Capacity in Clovis
Exceeds
Capacity?
TK through 6 0.1213 1,303 159 0 Yes
7 through 8 0.0250 1,303 33 0 Yes
9 through 12 0.0462 1,303 61 0 Yes
Source: Clovis Unified School District
6 School Facilities Needs Analysis. https://files.smartsites.parentsquare.com/6245/clovis_usd_sfna_2025.pdf

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As shown in Table 4.12-8, enrollment capacity for CUSD schools in Clovis city limits as of school year 2023 to 2024 would not accommodate the estimated 253 students assumed as part of the project, as middle and high school facilities prior to the project are over capacity. However, in addition to CUSD’s enrollment management strategies described above and opening of the Terry Bradley Educational Center, CUSD would also offset the project’s potential impact to schools by implementing developer fees which reduce potential student impacts from development activity.

Any development facilitated by the project would be subject to these State-mandated school impact fees and collected at the time of building permit issuance. Pursuant to Section 65995.5 of the California Government Code (Senate Bill 50, chaptered August 27, 1998), the payment of statutory fees “is deemed to be full and complete mitigation of the impacts of any legislative or adjudicative act, or both, involving, but not limited to, the planning, use, or development of real property, or any change in governmental organization or reorganization.” The fees for 2025 are summarized in Table 4.12-9.

Table 4.12-9 2025 Clovis Unified School District Developer Fee Collection Rates Grade Level Fee Rate per Square Foot
Residential Construction (Level 2) $5.86
Residential Additions/Remodels (Level 1) $5.17
Commercial/Industrial $0.84
Source: Clovis Unified School District
CUSD is the agency responsible for providing adequate classrooms and the City of Clovis does not have authority to require CUSD to construct additional classrooms or schools within city limits.

CUSD is a government agency independent from the City of Clovis with separate jurisdictional boundaries, responsibilities, and governing board. Because they are governed independently from the City of Clovis (School Board compared to Clovis City Council), the City does not have the authority to require CUSD to take any actions such as building new schools. Therefore, as described above, existing laws and regulations such as the development impact fees would require funding for the provision or expansion of new school facilities to offset impacts from new residential development, and CUSD policies for accommodating new students within the District would provide sufficient student capacity for the anticipated student growth from the project. Therefore, through compliance with applicable regulations and the payment of developer fees, development facilitated by the project would have a less than significant impact.

Mitigation Measures
No mitigation measures are required.

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Threshold 1e: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered public facilities, or the need for new or physically altered public facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives?
IMPACT PSR-4 DEVELOPMENT UNDER THE PROJECT WOULD INCREMENTALLY INCREASE THE CITY POPULATION AND INCREASE THE USE OF EXISTING PUBLIC FACILITIES, SUCH AS LIBRARIES. IMPACTS RELATED TO THE PROVISION OF NEW OR PHYSICALLY ALTERED PUBLIC FACILITIES WOULD BE LESS THAN SIGNIFICANT.

The Clovis Regional Library is the main library in the City of Clovis, and is part of the 38-library Fresno County library system. The Clovis Regional Library is open Monday through Friday from 9 am to 9 pm, Saturday from 9 am to 5 pm, and Sunday from 12 pm to 5 pm. The library is 8,627 square feet and provides Wi-Fi services, a recycling site for e-waste, and laptop checkout services. The existing library will be replaced with a newly constructed approximately 26,000 square feet building located in Landmark Square. The new library will include a multi-use community room, quiet rooms, and a dedicated teen room, as well as an anticipated outdoor seating area. Construction is anticipated to be complete by 2027. As discussed in Section 4.11, Population and Housing, development facilitated by the project would potentially increase Clovis’s population from 129,121 to 133,761 persons, a 3.6 percent increase of the City’s 2024 population. Given that not all new residents would visit the library frequently, the increase in monthly visitation would be lower than

3.6 percent, which would be statistically insignificant. Therefore, project impacts to public facilities (libraries) would be less than significant.

Mitigation Measures
No mitigation measures are required.

Threshold 1d: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered parks, or the need for new or physically altered parks, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives? Threshold 2: 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?
Threshold 3: Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?
IMPACT PSR-5 DEVELOPMENT UNDER THE PROJECT WOULD INCREMENTALLY INCREASE THE CITY’S

POPULATION AND INCREASE THE USE OF EXISTING PARKS AND RECREATIONAL FACILITIES AND REDUCE THE CITY’S PARKLAND TO POPULATION RATIO. HOWEVER, IMPACTS RELATED TO THE PHYSICAL DETERIORATION OF

PARKLAND OR RECREATIONAL FACILITIES, AND THE NEED TO CONSTRUCT NEW FACILITIES WOULD BE LESS THAN SIGNIFICANT.

The project would facilitate an increase of up to 3,662 residents, resulting in a potential increase in the use of parks and recreational facilities throughout Clovis. The city currently has 285 acres of parkland, with a parkland to population ratio of 2.2 acres per 1,000 residents, in addition to access to CUSD recreational facilities after school hours. While the project would not directly introduce

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development, future development associated with the project would result in an increase in the City population to 133,760 residents and a parkland ratio of 2.13 acres per 1,000 residents. The current and projected population to parkland ratio is far below the State recommendation of 5.0 acres of parkland per 1,000 residents. The City of Clovis would not be able to achieve this goal as the City is made up primarily of agricultural and residential uses and lacks the amount of undeveloped land the City would need to be developed into parkland to meet the goal.

As future residential development projects are approved, parkland in-lieu fees (pursuant to the Quimby Act) would be required by the Clovis Municipal Code Section 3.4.03 as part of the individual projects. Funding for maintenance of new and existing facilities is provided through property assessments and taxes. Park and recreational facility maintenance and acquisition needs in the city are evaluated with respect to population growth, locational needs, and budget. The project would not preclude implementation or expansion of any parkland, trails, or recreation facility.

Any project associated with new or expanding parkland or recreation facilities would be subject to project-specific environmental review and mitigation pursuant to CEQA and pay any required recreational impact fee to pay for new parks. While the project would increase the number of people visiting parks and recreational facilities, the incremental increase across the city would not result in the need to construct new or expanded facilities beyond what was planned for in the Clovis General Plan. Therefore, the project would result in less than significant substantial physical deterioration of existing parkland or substantial adverse physical impacts associated with the provision of new or physically altered parkland.

Mitigation Measures
No mitigation measures are required.

4.12.4 Cumulative Impacts
Fire Protection
Cumulative development would increase the population such that there is an increase in reported incidents, leading to longer response times unless the Fire Department increases staffing. As described above under Impact PSR-1, with continued implementation of General Plan policies and Fire Code requirements, it is not anticipated that a new fire station beyond what is planned for is needed to serve cumulative development in Clovis. Because the project would not exceed the projected population growth planned for in the General Plan, the project would not have a cumulatively considerable impact on city fire protection. Therefore, the cumulative impacts related to fire protection facilities would be less than significant, and the project’s contribution to these impacts would not be cumulatively considerable.

Police Protection
Cumulative development would increase population such that there would be an increase in reported incidents leading to longer response times. Overall, although additional staffing may be needed in the future, this project’s impact on police protection would not be cumulatively considerable since the project would not exceed the projected population growth planned for in the General Plan and associated increase in police services to meet that demand or result in the need for more facilities to be built. Therefore, the cumulative impacts related to police facilities would be less than significant, and the proposed project’s contribution to these impacts would not be cumulatively considerable.

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Schools
Cumulative development would increase the number of children attending CUSD schools. CUSD is currently over capacity for elementary, middle, high, and SDC schools, and project implementation would add to this facility shortage. However, to offset the project’s potential impact to schools, the CUSD implements developer fees which reduce potential student impacts from development activity. Furthermore, compliance with Senate Bill 50 would require future development in Clovis to pay school impact fees established to offset potential impacts from new development. Additionally, the increase in population associated with the project would only increase the existing population by 3.6 percent, which would not result in the need for the expansion of existing schools or the development of new schools that have not already been accounted for by CUSD and General Plan population projections. CUSD also plans to open a new education center which would provide additional space for middle and high schools. The project itself would not have a significant impact, however, due to the contribution to middle and high schools in Clovis that are already over capacity, the project’s contribution to this impact would be cumulatively considerable.

Parks and Recreational Facilities
Cumulative development would increase demand for park and recreational facilities. As described in Impact PSR-5 above, the project would increase the population of Clovis thereby reducing the ratio of parkland within the city limits to parkland ratio to approximately 2.13 acres per 1,000 residents, which is below the State recommendation of five acres of parkland per 1,000 people. However, new development projects would have to adhere to Clovis Municipal Code Section 3.4.03 which requires development to provide Quimby parkland in-lieu fees and park improvement impact fees, which would ensure any cumulative significant impacts to park and recreational facilities would be reduced to less than significant. Recreational facilities such as libraries would potentially see an increase in visitations due to the cumulative development associated with the project; however, given that the project would only increase the population by 3.6 percent and not all new residents would utilize the library, the project would not have a considerable impact on the existing facility.

Future growth and demand for parks and recreational facilities associated with the project would also not exceed the projected population growth planned for in the City of Clovis General Plan, and therefore, cumulative impacts related to new or expanded park and recreation facilities, or the physical deterioration of existing park and recreation facilities, would be less than significant. The project would not have a cumulatively considerable contribution to a significant cumulative impact regarding park and recreation facilities.

Mitigation Measures
No mitigation measures are required.

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4.13 Transportation
This section analyzes impacts related to transportation associated with development facilitated by the Infill Rezone Program project.

4.13.1 Setting
This section describes the existing roadway, transit, bicycle and pedestrian components of the Clovis transportation system.
a. Roadway System
The network of roadways in and around Clovis consists of highways, arterials, collectors and local streets. Figure 4.13-1 presents the existing General Plan Circulation Diagram and the roadway classifications in the city.

Highways
State Route (SR) 168 is a divided four-lane highway running northeast to southwest through the city.

It provides a connection from the intercity Fresno area to the Sierra Nevada Mountain range. Access points to SR 168 within Clovis are located at Shaw Avenue, Bullard Avenue, Herndon Avenue, Fowler Avenue, Temperance Avenue, Owens Mountain Parkway and Shepherd Avenue. Most sections of SR 168 in the city have limited access but sections near Owens Mountain Parkway and Shepherd Avenue have at-grade intersections. The speed limit is generally set at 65 mph within the city.

Arterials
Clovis's arterial streets are the primary movers of traffic and provide a high level of mobility between freeways, expressways, other arterials, and collector roadways. Arterials are designed to move large volumes of traffic and provide connections between major residential, employment, and activity centers. Arterial streets typically have more right-of-way and a higher degree of access control than collector roadways. Most arterials in Clovis have four travel lanes, and opposing traffic may be separated by a median.

Collectors
Collector streets provide for relatively short distance travel between and within neighborhoods and are not designed to handle long-distance through-traffic. Driveway access to collectors is less restricted than on arterials. Speed limits on these streets are typically lower than those found on arterials. Collector streets differ from local streets in their ability to handle through traffic movements between arterials.

Local Streets
The remainder of Clovis’s roadways are considered local streets that are designed to provide direct roadway access to abutting land uses and serve short distance trips within neighborhoods. Traffic volumes and speed limits on local streets are low, and these roadways have no more than two travel lanes.

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Figure 4.13-1 Existing General Plan Circulation Diagram Source: Clovis General Plan (2014)

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b. Transit Service
This section summarizes current and proposed public transit services that connect destinations within the City of Clovis as well as around the region. This section includes a review of bus and passenger rail transit facilities.

Public Bus Transit
Public bus transit in the city is provided by Clovis Transit and Fresno Area Express (FAX). The William H. "Harry" Armstrong Transit Center, located at 785 Third Street, which opened in 2024, serves as the primary local and regional transit hub.

Local Transit Service
Clovis Transit provides local fixed-route service via a door-to-door paratransit service for eligible passengers with disabilities, offering free public transportation within Clovis. These services help connect residents to key destinations in Clovis, Tarpey, and parts of Fresno. All Clovis Transit buses are equipped with mounted bike racks that accommodate two bicycles.

The fixed-route service encompasses eight color-coded routes in Clovis as shown in Table 4.13-1 and Figure 4.13-2. The new routes run east/west and north/south on 30-minute headways, with multiple transfer points designed to enhance efficiency and reliability of service. The routes provide vital connections to key destinations, including educational institutions (such as high schools and colleges), medical facilities, social services, recreational centers - including the Clovis Senior Activity Center- and a variety of shopping locations. Additionally, a complementary microtransit service is available for passengers in outlying communities, facilitating their connection to the fixed-route system. Microtransit rides can be booked from three microtransit stops - located at the Dry Creek Trailhead, Harlan Ranch Park, and Pasa Tiempo Park - to designated bus stops.

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Table 4.13-1 Clovis Transit Routes
Route/Service Operating Hours Frequency Days Provided
Green Route (Shaw Avenue) 6:00 AM – 7:00 PM 30 minutes Monday - Friday 7:30 AM - 3:30 PM 30 minutes Saturday
No service No service Sunday
Orange Route (Ashlan Avenue) 6:00 AM – 7:00 PM 30 minutes Monday - Friday 7:30 AM - 3:30 PM 60 minutes Saturday
No service No service Sunday
Red Route (Bullard Avenue) 6:00 AM - 7:00 PM 30 minutes Monday - Friday 7:30 AM - 3:30 PM 30 minutes Saturday
No Service No Service Sunday
Teal Route (Herndon Avenue) 6:00 AM - 7:00 PM 30 minutes Monday - Friday 7:30 AM - 3:30 PM 30 minutes Saturday
No Service No Service Sunday
Pink Route (Temperance Avenue) 6:00 AM - 7:00 PM 30 minutes Monday - Friday 7:30 AM - 3:30 PM 30 minutes Saturday
No Service No Service Sunday
Purple Route (Sunnyside Avenue) 6:00 AM - 7:00 PM 30 minutes Monday - Friday 7:30 AM - 3:30 PM 30 minutes Saturday
No Service No Service Sunday
Yellow Route (Clovis Avenue) 6:00 AM - 7:00 PM 30 minutes Monday - Friday 7:30 AM - 3:30 PM 30 minutes Saturday
No Service No Service Sunday
Blue Route (Willow Avenue) 6:00 AM - 7:00 PM 30 minutes Monday - Friday 7:30 AM - 3:30 PM 30 minutes Saturday
No Service No Service Sunday
Microtransit Sites 6:00 AM - 7:00 PM Per Request Monday - Friday 7:30 AM - 3:30 PM Per Request Saturday
No Service No Service Sunday
Source: Clovis Transit and Fresno Area Express, (2025).

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Figure 4.13-2 Clovis Transit Routes
Regional Transit Service
The FAX routes are operated by the City of Fresno Transportation Department, providing public transit services throughout Fresno and extending into the City of Clovis as part of the broader Fresno-Clovis metropolitan area. Currently, several FAX routes serve Clovis, including Route 9 (Shaw), which runs along Shaw Avenue with stops like Sierra Vista Mall, and Route 28 (VenturaKings Canyon), which connects downtown Fresno to the Fresno County Department of Social Services (DSS) on Peach and Dakota. This site serves as a transfer point for FAX and Clovis Transit.  FAX Route 9 (Shaw Avenue): Connects Clovis to major destinations along Shaw Avenue, including Fashion Fair Mall, Fresno State University, and the River Park shopping area. Service operates on weekdays from 5:50 AM to 11:51 PM, and on Saturdays from 6:35 AM to 11:51 PM and Sundays from 6:35 AM to 7:03 PM.
 FAX Route 28 (Ashlan Avenue): Provides service along Ashlan Avenue, connecting Clovis residents to areas in Fresno, including Manchester Center and western Fresno neighborhoods.

Route 28 runs weekdays, typically from around 5:37 AM to 11:56 PM, and on Saturdays from

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6:40 AM to 11:55 PM, and Sundays from 6:40 AM to 7:03 PM, with buses departing every 30 minutes from Manchester Transit Center to areas near Clovis Avenue.

All FAX buses are equipped with front-mounted bike racks that accommodate two bicycles.

Passenger Rail Service
While Clovis does not currently have a dedicated passenger rail station, residents can access rail services through the Fresno Amtrak Station. The Fresno Amtrak Station (approximately nine miles from Downtown Clovis) is served by the Amtrak San Joaquin route, providing connections between Bakersfield and Oakland/Sacramento. An Amtrak Thruway motorcoach connection in Bakersfield offers service to the Los Angeles metropolitan area.

The City of Fresno is also a designated station along the future California High Speed Rail system, which will connect San Francisco to Los Angeles via the Central Valley. The planned Fresno station, located in downtown Fresno (about 10 miles from Downtown Clovis), will enhance regional connectivity for Clovis residents, offering high-speed transit options within the state. Future expansions of regional rail services, such as the Altamont Corridor Express (ACE) extension to Merced, may further improve rail connectivity for Clovis commuters. c. Bicycle Facilities
This section describes the bicycle circulation system in the City of Clovis. Caltrans classifies and defines bicycle facilities. Caltrans designates four classes of bicycle facilities: Classes I, II, III, and IV.

Figure 4.13-3 illustrates and describes the bicycle facility classifications.

Figure 4.13-4 displays the existing and proposed bike facilities throughout Clovis. The city provides several types of bike facilities such as trails, paseos, bike lanes, and bicycle wayfinding/signage. The existing bike network includes 59 miles of Class II bike lanes, primarily located on major arterials and collectors in the city. Off-street bicycle facilities include trails (Old Town Trail, Dry Creek Trail, Enterprise Trail, and Sierra Gateway Trail), paseos, and sidewalks. The city has 12.5 miles of offstreet trails and paseos.

The Clovis Active Transportation Plan (ATP)
1 proposed an additional 130 miles of bicycle network
comprised of different bicycle facilities to be added to the existing network. In addition to bicycle lanes and trails, the proposed network also includes Neighborhood Greenways. These are sometimes referred to as “Bicycle Boulevards,” which are local streets designated and designed to prioritize bicycle use.

The city has made progress in expanding its bike network (see Figure 4.13-4); however, many of these facilities are on roadways with high traffic volumes and posted speeds greater than 40 mph.

The Multi-Jurisdictional Local Road Safety Plan (LRSP)2 noted that bicyclists account for three percent of total reported collisions but nine percent of fatal and severe injury collisions. As such, the LRSP presented the following recommendations to improve bicycle safety within the City of Clovis:
 Install bike lanes,
 Install bike lane extensions through intersections, and  Install bike boxes.
1 Clovis Active Transportation Plan. 2023. Accessible at:
https://www.clovisca.gov/services/planning_development/engineering/active_transportation_plan/index.php 2 Multijurisdictional Local Road Safety Plan.2022. Accessible at: https://www.fresnocog.org/wp-content/uploads/2022/06/26012_FresnoCOG-MLRSP_Report-FINAL-April-update_Part1-1.pdf

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Figure 4.13-3 Types of Bicycle Facilities

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Figure 4.13-4 Existing and Proposed Bicycle Facilities
d. Pedestrian Facilities
Sidewalks are generally included on most roadways within the city, providing pedestrian access to residential, commercial, employment and school areas. Locations in the city where sidewalk infill is needed are primarily located in southwest and southeast Clovis. Figure 4.13-5 shows the locations of existing and missing sidewalks identified in the Clovis ATP.

The City of Clovis ATP noted that pedestrian connectivity would be improved by installing additional pedestrian crossings along arterials, where currently people have to walk more than a quarter mile to cross the street at a marked crosswalk. In addition to the lack of high-visibility crosswalks along arterials, there is a lack of infrastructure (i.e., advance stop bars and median refuge islands) that limit safe pedestrian mobility at signalized and unsignalized intersections.

Trails and Paseos
Trails and paseos are important to both the bicycle and pedestrian networks, since they provide an off-street travel option through tree-lined linear parks. The existing and planned trails and paseos are shown in Figure 4.13-6. The City of Clovis is dedicated to expanding its trail and paseo networks to provide more opportunities for the public. The city is partnering with the Fresno Irrigation District to allow people to walk along irrigation canals. The city has also identified potential locations to install mid-block crossings to increase trail connectivity throughout the city.

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Figure 4.13-5 Critical Gaps in Sidewalk System

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Figure 4.13-6 Existing and Planned Trails and Paseos

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4.13.2 Regulatory Setting
The General Plan, along with a variety of City, regional, State, and Federal plans, legislation, and policy directives provide guidelines for the safe operation of streets and transportation facilities in Clovis. While the City has primary responsibility for the maintenance and operation of local transportation facilities in its jurisdiction, Clovis staff works on a continual basis with responsible regional, State, and Federal agencies including County of Fresno, the Fresno Council of Governments, the California Department of Transportation (Caltrans), the Federal Highway Administration, and others to maintain, improve, and balance the competing transportation needs of the community and the region.
a. Federal Regulations
Federal Highway Administration
The Federal Highway Administration (FHWA) is the agency of the United States (US) Department of Transportation (DOT) responsible for the federally funded roadway system, including the interstate highway network and portions of the primary state highway network, such as SR 168 and SR 41.

Federal Transit Administration
The Federal Transit Administration (FTA) is an authority that provides financial and technical assistance to local public transit systems, including buses, subways, light rail, commuter rail, trolleys, and ferries. The FTA is funded by Title 49 of the United States Code, which states the FTA’s interest in fostering the development and revitalization of public transportation systems. b. State Regulations
Senate Bill 743
Senate Bill (SB) 743, passed in 2013, resulted in several statewide California Environmental Quality Act (CEQA) changes. It required the California Governor’s Office of Planning and Research (OPR) to establish new metrics for determining the significance of transportation impacts of projects within transit priority areas (TPAs) and allows OPR to extend use of the metrics beyond TPAs. OPR selected vehicle miles traveled (VMT) as the preferred transportation impact metric and applied their discretion to require its use statewide. This legislation also established that aesthetic and parking effects of residential, mixed-use residential, or employment center projects on an infill site within a TPA are not significant impacts on the environment. The revised CEQA Guidelines that implement this legislation became effective on December 28, 2018, and state that vehicle level of service (LOS) and similar measures related to vehicle delay shall not be used as the sole basis for determining the significance of transportation impacts for land use projects, and that as of July 1, 2020, this requirement shall apply statewide.

The OPR “Technical Advisory on Evaluating Transportation Impacts in CEQA” (December 2018) includes specifications for VMT methodology and recommendations for significance thresholds, screening of projects that may be presumed to have less than significant impacts, and mitigation.

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Screening criteria include:
 Small projects: The Technical Advisory concludes that, absent any information to the contrary, projects that generate 110 trips per day or less may be assumed to cause a less-than-significant transportation impact.
 Projects near transit stations: Projects located within ½ mile of an “existing major transit stop” or an “existing stop along a high-quality transit corridor” would have a less-than-significant impact on VMT.
 Affordable residential development: Projects consisting of a high percentage of affordable housing may be assumed to cause a less-than-significant transportation impact on VMT because they may improve jobs-housing balance and/or otherwise generate less VMT than market-based units.
 Redevelopment projects: If a proposed redevelopment project leads to a net overall decrease in VMT (when compared against the VMT of the existing land uses), the project would lead to a less-than-significant transportation impact.
 Local-serving retail: Trip lengths may be shortened and VMT reduced by adding “local-serving” retail opportunities that improve retail destination proximity. Page 17 of the Technical Advisory generally describes retail development including stores less than 50,000 square feet as localserving. In May 2020, OPR staff indicated during online webinars that any retail building that is 50,000 square feet or less may be considered local-serving.

Other key guidance includes:
 VMT is the most appropriate metric to evaluate a project’s transportation impact.  OPR recommends tour- and trip-based travel models to estimate VMT, but ultimately defers to local agencies to determine the appropriate tools.
 OPR recommends measuring VMT for residential and office projects on a “per rate” basis.

Specifically, OPR recommends VMT per capita for residential projects and VMT per employee for office projects.
 OPR recommends that a per capita or per employee VMT that is 15 percent below that of existing development may be a reasonable threshold.3 In other words, an office project that generates VMT per employee that is more than 85 percent of the regional VMT per employee could result in a significant impact. OPR notes that this threshold is supported by evidence that connects this level of reduction to the State’s emissions goals (pages 10-11).  For retail projects, OPR recommends measuring the net decrease or increase in VMT in the planning area with and without the project. The recommended impact threshold is any increase in total VMT.
 Lead agencies ultimately have the discretion to set or apply their own significance thresholds, provided they are based on significant evidence.
 Cities and counties still have the ability to use measures of delay such as LOS for other plans, studies, or network monitoring. However, according to CEQA section 15064.3, Determining the Significance of Transportation Impacts, “effect on automobile delay shall not constitute a significant environmental impact.”
3 Governor’s Office of Planning and Research. (2018). Technical Advisory on Evaluating Transportation Impacts in CEQA. Sacramento, CA:

State of California. Accessible at: https://lci.ca.gov/docs/20190122-743_Technical_Advisory.pdf

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Caltrans Vehicle Miles Traveled-Focused Transportation Impact Study Guide The Caltrans “Vehicle Miles Traveled-Focused Transportation Impact Study Guide” (TISG), dated May 20, 2020, was prepared to provide guidance to Caltrans districts, lead agencies, tribal governments, developers, and consultants regarding Caltrans’ review of VMT impact analysis for land use projects and land use plans. Caltrans seeks to reduce single occupancy vehicle trips, provide a safe transportation system, reduce per capita VMT, increase accessibility to destinations via cycling, walking, carpooling, and transit, and reduce greenhouse gas (GHG) emissions. The TISG notes that, for land use projects and plans, automobile delay is no longer considered a significant impact on the environment under CEQA. Caltrans’ primary review focus for a land use project’s transportation impacts is now VMT. The TISG generally endorses the OPR “Technical Advisory,” including the thresholds in that document. Caltrans may review VMT thresholds, methodology, and mitigations.

Caltrans Interim Land Development and Intergovernmental Review (LDIGR) Safety Review Practitioners Guidance
The Interim LDIGR Safety Review Practitioners Guidance (July 2020) was developed to provide immediate direction about the safety review while final guidance is being developed. This interim guidance does not establish thresholds of significance for determining safety impacts under CEQA.

The guidance notes that the significance of impacts should be determined with careful judgment on the part of a public agency and based, to the greatest extent possible, on scientific and factual data consistent with Caltrans’ CEQA guidance contained in Caltrans’ Standard Environmental Reference.

The guidance notes that Caltrans traffic safety staff will use available data to determine if the proposed project may influence or contribute to locations identified by traffic safety Investigations generated by network screening or initiated by Caltrans. c. Regional Regulations
Fresno Council of Governments Regional Transportation Plan and Sustainable Community Strategy
The Fresno County Council of Governments (Fresno COG) is a voluntary association of local governments and a regional planning agency comprised of 16 member jurisdictions, including the City of Clovis. The Fresno COG’s purpose is to establish a consensus on the needs of the Fresno County area and further action plans for issues related to the Fresno County region. The current Regional Transportation Plan and Sustainable Community Strategy (RTP/SCS) produced by Fresno COG was adopted in 2022. The RTP/SCS sets forth regional transportation policy and provides capital program planning for all regional, state, and federally funded projects. The RTP addresses GHG emission reductions and other air emissions related to transportation, with the goal of preparing for future growth in a sustainable way. The plan specifies how funding will be sourced and financed for the region’s planned transportation investments, ongoing operations, and maintenance.

Fresno County Transportation Authority and Measure C.

The Fresno County Transportation Authority (FCTA) is a regional agency that was created to administer the voter‐passed Measure C program in 1986. Measure C was a 20‐year program that achieved a half‐cent sales tax for transportation expenditures and infrastructure. After its 20‐year duration, the program was extended for another 20 years in 2006 and named the Measure C