Clovis City Council
July 6, 2026

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Extension Expenditure Plan. Through this funding, the FCTA established goals and core values for utilizing these funds for not only building roads but also completion of added bike lanes; expansion of Fresno and Clovis transit; and support for transit, ridesharing, and vanpools.

Fresno County Congestion Management Process
As the designated Congestion Management Agency (CMA) for Fresno County, Fresno COG is responsible for updating the County’s Congestion Management Process (CMP) and monitoring its implementation. The Fresno County CMP identifies four general objectives: (1) optimize the transportation facilities through efficient system management; (2) invest in strategies that reduce travel demand, improve system performance, increase safety, and provide effective incident management; (3) reduce VMT by encouraging alternative modes of transportation and promotion of sustainable land use development; and (4) improve public transit, extend bicycle and pedestrian systems, and promote car‐sharing and bike‐sharing programs to facilitate the development of an integrated multi‐modal transportation system in the Fresno region. d. Local Regulations
Clovis General Plan
The City of Clovis adopted a comprehensive General Plan Update on August 28, 2014 and a General Plan Amendment to the Circulation Element in 2022 to address statewide transportation planning requirements. The amended General Plan Circulation Element includes the following goals:

1. A context-sensitive and “complete streets” transportation network that prioritizes effective connectivity and accommodates a comprehensive range of mobility needs.

2. A roadway network that is well planned, funded, and maintained.

3. A multimodal transportation network that is safe and comfortable in the context of adjacent neighborhoods.

4. A well-planned and maintained pedestrian circulation network that promotes increased use of the City’s bicycle, and transit, and pedestrian facilities in order to reduce commuting by singleoccupancy vehicles whenever possible.

5. A complete system of trails and pathways accessible to all residents focusing on connectivity between adjacent neighborhoods, parks, trails, and goods and services.

6. Safe and efficient goods movement with minimal impacts on local roads and neighborhoods.

7. A regional transportation system that connects Clovis to the San Joaquin Valley region.

8. Improve and enhance the circulation network in a manner that reduces VMT through improved connectivity by focusing on modes of transportation that promotes the reduction in the use of single-occupancy vehicles whenever possible.

Clovis Transportation Impact Analysis Guidelines
The City of Clovis adopted guidelines for transportation impact analysis in July 2020. The Transportation Impact Analysis (TIA) Guidelines document provides guidance to City of Clovis staff, applicants, and consultants on the requirements to evaluate transportation impacts for projects in the city for the purpose of determining impacts under CEQA. It provides guidance for the two types of analysis that normally comprise a TIA report (1) CEQA Analysis, and (2) Local Transportation Analysis.

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For the CEQA VMT analysis, the TIA guidelines define the quantitative methodology, significance thresholds, and mitigation measures for conducting the transportation analysis in accordance with the requirements of SB 743 primarily based on VMT metrics. For land development projects, VMT per capita or VMT per employee are used to determine impacts. The guidelines document defines specific methodologies, criteria and thresholds for several project types, and discusses potential mitigation measures that can be considered to reduce VMT.

Clovis Active Transportation Plan
The 2022 ATP defines a clear vision for the city’s active transportation network and proposes a framework for implementing projects, programs, and policies to turn the vision into a reality. The ATP identifies strategies to improve safety and accessibility for active forms of travel such as walking and bicycling. It supplements other long-range plans and will help the City create a sustainable and multi-modal transportation network.

The ATP includes the following goals.

1. Improve the safety of people walking and bicycling.

2. Develop a well-connected network of trails, walkways, and bikeways.

3. Create a network that allows people of all socioeconomic circumstances the ability to travel safely throughout the city without a car.

4. Increase access to recreation by providing access to trails, walkways, and bikeways.

5. Increase the share of people who walk or ride a bicycle to get to work, school, shopping, and other activities
The ATP includes a list of project recommendations with specific locations, facility types and priority for implementation to improve walking and bicycling infrastructure throughout Clovis.

Fresno-Clovis Metropolitan Area Transit Short Range Transit Plan (SRTP) The Fresno-Clovis Metropolitan Area (FCMA) SRTP was adopted on June 29, 2023. It presents a biannual short-term operational, financial, and capital improvements plan for two transit providers:

FAX and Clovis Transit. The purpose of the SRTP is to promote a comprehensive, coordinated, and continuous planning process for transit service in the FCMA over the planning horizon.

4.13.3 Impact Analysis
a. Methodology and Significance Thresholds
Methodology
The analysis assesses how the city’s transportation system would operate with the implementation of the project. The potential impacts were identified based on a set of significance criteria based on the 2025 CEQA Guidelines. This section describes assumptions and methods used to assess potential impacts on the transportation system.

Vehicle Miles Traveled
VMT is determined by multiplying the number of vehicular trips by the trip distance in miles. For example, one vehicle that travels 10 miles in a day generates 10 VMT. For the purposes of this

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analysis, VMT is expressed on a daily basis for a typical weekday. VMT values in this analysis represent the full length of a given trip and are not truncated at jurisdiction boundaries.

Additionally, these VMT values are for trips beginning or ending in the city (i.e., are associated with land uses within Clovis). Trips passing through the city without stopping are not included in these VMT estimates, as the city has little or no control over such trips.

Although the absolute amount of VMT may be reported, transportation impact analysis is typically based on VMT expressed as an efficiency metric. VMT efficiency metrics, such as VMT per resident and VMT per employee, allow the VMT performance of different land use quantities to be compared. Such metrics provide a measure of travel efficiency and help depict whether people are traveling by vehicle more or less over time, across different areas, or across different planning scenarios. A per-capita or per-employee decline in VMT compared to a baseline condition indicates that the land use patterns and transportation network are operating more efficiently.

Two measures of VMT are used in this analysis:
 VMT per capita for residential land uses. Includes VMT for all trips produced by a dwelling unit’s residents, such as to work, school, or shop, on a typical weekday.  VMT per employee for non-residential land uses. Includes trips made by employees at the nonresidential land use on a typical weekday, not including visitors to the non-residential land use such as customers, patients, or deliveries.

Travel Demand Model
Forecasts of regional travel by various modes, regional average VMT per capita and VMT per employee values are determined using the Fresno COG regional travel model. The travel demand model is a set of mathematical procedures and equations that represent the variety of transportation choices that people make, and how those choices result in trips on the transportation network.

The Fresno COG regional travel model is an activity-based model that simulates the County’s population, based on detailed Census data, and models the daily activity patterns of each simulated individual along with resulting travel demand. The daily activity patterns in the travel model are based on a statistical analysis of a household travel survey, where a representative sample of households were asked to track all daily activities and trips by all members of their household. A simulated travel tour might consist of, for example, travel from the home to the gym to work to supermarket to home in a typical weekday. The travel model was calibrated to these surveyed travel patterns, and also validated by its ability to replicate counted traffic volumes, transit ridership, and total Fresno County VMT from the Highway Performance Measurement System (HPMS) which is based on traffic counts.

The model presumes that future background travel options and behaviors remain similar to current conditions and does not explicitly account for potential changes associated with disruptive trends, emerging technologies, and changes in travel preferences. The model also does not assume a significant increase in working at home compared to 2019 baseline conditions.

Land Use
The Fresno travel model requires land uses to be defined for each geographic area in the county.

The model defines land uses in micro-analysis zones (MAZs) which represent subareas of neighborhoods similar to Census blocks. The model also aggregates land uses to the more traditional transportation analysis zones (TAZs) which are typically bounded by major arterial or

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collector streets and are generally closer to the scale of Census tracts. The model land use inputs include numbers of households and employees by employment category, as well as enrollment at schools.

The future land use forecasts are consistent with the current General Plan land use map, as are the Fresno COG RTP/SCS forecasts for the 2046 horizon year from the most current RTP/SCS adopted in 2022. Table 4.13-2 summarizes the effect of the project on population, number of households, and employment based on the assumed land uses for each modeled scenario.

Table 4.13-2 Clovis Sphere of Influence Land Use Summary Land Use 2019 Baseline1 2019 Plus Project 2046 Cumulative with Project Households 42,877 46,297 55,810
Population 144,067 154,195 182,576
Employment 36,537 36,537 44,568
1 The 2019 land use inputs used by Fresno COG to establish VMT thresholds are 5 percent lower than the updated 2019 land use inputs used as a base for the project increment.

VMT Metrics and Thresholds
For land use plans such as specific plans, community plans, and general plan updates, consistent with OPR’s recommendations, the city requires comparing the applicable VMT thresholds (such as VMT per capita and/or VMT per employee) under existing conditions with the applicable VMT metrics for the expected horizon year for the land use plan. If there is a net increase in the applicable VMT metrics under horizon year conditions, then the project will have a significant impact.

The VMT per capita includes all trips made by residents, including their trips while away from home, but does not include trips visiting residences (e.g., trips made by delivery vans). The regional average VMT per capita is calculated by summing the vehicle mileage (excluding trips made by transit, bicycle or walking) for all trips made by Fresno County residents, and dividing by the county population.

The VMT per employee includes trips made by employees to and from their workplaces, including trips to and from points other than the employees’ homes, but does not include visitors to the employment sites. The regional average VMT per employee is calculated by summing the vehicle mileage (excluding trips made by transit, bicycle or walking) for all trips made by Fresno County employees, and dividing by the total number of employees in the county.

Consistent with the City’s TIA Guidelines, two measures of VMT are used in this analysis:

1. VMT Per Capita. Includes VMT for trips produced by a dwelling unit’s residents, such as to work, school, or shop, and with one end of the trip at the home, on a typical weekday. This metric is normally used for residential land uses.

2. VMT PER Employee. Includes all trips with one end at the land use, including trips by both employees, customers, and deliveries, on a typical weekday. This metric is normally used for non-residential land uses.

For informational purposes the total VMT, which includes all trips with at least one end in the planning area on a typical weekday, was provided.

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

1. Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities

2. Conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b)

3. Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)

4. Result in inadequate emergency access
b. Project Impacts and Mitigation Measures
Threshold 1: Would the project conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities? IMPACT T-1 THE PROJECT WOULD NOT CONFLICT WITH ADOPTED PLANS OR POLICIES ADDRESSING THE CIRCULATION SYSTEM, INCLUDING ROADWAY, TRANSIT, BICYCLE, AND PEDESTRIAN FACILITIES. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

The project would not conflict with adopted programs, plans, policies, or ordinances that address the circulation system, including transit, bicycle, and pedestrian facilities. The proposed Infill Rezone Program sites are served by the city’s existing and planned transportation system. The General Plan incorporates future networks and policies related to supporting transit, bicycle, and pedestrians in the city and Sphere of Influence. These networks are consistent with regional and local planning efforts supporting these modes of travel. The additional housing would potentially add traffic to streets which could affect conflicts with bicycle and pedestrian movements. However, the Infill Rezone Program sites will be implemented consistently with city standards and polices, and therefore there will be no conflicts with adopted programs, plans or polices. Therefore, there would be a less than significant impact.

Mitigation Measures
No mitigation measures are required.

Threshold 2: Would the project conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b)?
IMPACT T- 2 IMPLEMENTATION OF THE PROJECT WOULD CONTRIBUTE TO VMT PER CAPITA INCREASING ABOVE THE REGIONAL IMPACT THRESHOLD. WITH MITIGATION, IMPACTS WOULD REMAIN SIGNIFICANT AND UNAVOIDABLE.

Based on Appendix G of the CEQA Guidelines, the project could result in a significant transportation impact if it would conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b)(1), which states for land use projects, “Vehicle miles traveled exceeding an applicable threshold of significance may indicate a significant impact.” CEQA Guidelines § 15064.3, subdivision (b)(4) states, “A lead agency has discretion to choose the most appropriate methodology to evaluate a project's vehicle miles traveled, including whether to express the change in absolute terms, per capita, per household or in any other measure. A lead agency may use models to estimate a project's vehicle

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miles traveled and may revise those estimates to reflect professional judgment based on substantial evidence.”
For land use plans such as specific plans, community plans, and general plan updates, consistent with OPR’s recommendations, the city requires comparing the applicable VMT thresholds (such as VMT per capita and/or VMT per employee) with the applicable VMT metrics for the expected horizon year for the land use plan. If there is a net increase in the applicable VMT metrics under horizon year conditions, then the project will have a significant impact.

VMT was calculated for the Clovis area including current city limits and the sphere of influence (SOI).

Table 3 summarizes the total citywide VMT for the 2019 baseline, the applicable threshold, and the baseline VMT with the project. As shown in the table, conditions with the Infill Rezone Program project would result in decreased VMT per capita and slightly increased VMT per employee in comparison to the 2019 baseline condition in Clovis. Residential VMT per capita would decrease by

2.7 percent, from 16.1 to 15.7, but would still be above the regional impact threshold of 14.0. Nonresidential VMT per employee would increase by 0.4 percent, from 24.6 to 24.7, and would still be above the regional impact threshold of 22.3.

Table 4.13-3 Vehicle-Miles of Traveled Results
Units 2019 Fresno County 2019 Clovis SOI 2019 Clovis SOI Plus Project VMT Per Capita
Population 1,010,400 144,067 154,195
Residential VMT 16,267,400 2,153,575 2,235,892
VMT per Capita 16.1 16.1 15.7
Impact Threshold 14.0 14.0 14.0
VMT Per Employee
Employees 404,100 36,537 36,537
Employee VMT 10,345,340 900,158 901,600
VMT per Employee 25.6 24.6 24.7
Impact Threshold 22.3 22.3 22.3
Total VMT 51,389,619 5,451,855 5,554,389
Source: Kittelson & Associates, 2025, applying Fresno COG travel model.

As individual land use development projects are implemented, consistent with the Infill Rezone Program, a focused project-specific VMT analysis may determine if the VMT per capita or per employee for that individual project exceeds the impact threshold.

The General Plan includes goals and policies intended to reduce VMT. The overarching goal for the Circulation Element is “a comprehensive and well-maintained multimodal circulation system that provides for the safe and efficient movement of people and goods, as well as encourages reductions in Vehicle Miles Traveled (VMT) through well-planned pedestrian connections and improved connectivity.” The following is a list of policies added to the Circulation Element that would promote a reduction in VMT:
 Policy 2.6 Vehicle Miles Traveled. Development projects shall comply with the City’s Transportation Analysis Guidelines and provide the appropriate VMT mitigation measures as determined through the analysis.

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 Policy 2.7 VMT Mitigation Fee Program. Evaluate the feasibility of a VMT mitigation fee program and explore opportunities for establishing an in-lieu mitigation fee to offset VMT impacts from development.
 Policy 2.8 Partner with Local Agencies And Stakeholders. Partner with other local and regional agencies and stakeholders to explore VMT mitigation measures at the regional scale.  Policy 8.1 Transportation Demand Management. Develop Transportation Demand Management (TDM) measures that promote, enhance, and make available feasible alternative modes of transportation to residents, employees, and visitors.  Policy 8.2 Transit Routes. As development occurs in the City’s growth areas, continue to evaluate transit routes to determine the most efficient methods of transporting people between residential neighborhoods and goods and services.  Policy 8.3 Bicycle Lanes. Partner with any local bicycle advocacy groups to improve the design, location, and functionality of bicycle lanes to encourage safe and efficient travel lanes.  Policy 8.4 Connectivity between residential and commercial. Continue to explore opportunities for increased non-vehicular connectivity between new and existing residential development and commercial uses.
 Policy 8.5 Community Outreach and Education. Explore the feasibility of a community outreach and education program that promotes and highlights opportunities for safe and efficient nonvehicular modes of transportation for commuting and recreation.  Policy 8.6 Employer Commute Programs. Work with businesses to encourage commuter programs and infrastructure that promotes alternative modes of transportation reducing the use of single-occupancy vehicles, such as additional bicycle racks/lockers, on-site shower facilities, and perks for employees who commute.

Implementing the goals and policies presented above are intended to promote accessibility, encourage non-vehicle transportation modes, expand transit services, and develop TDM program requirements that reduce VMT associated with new development. When implemented, these types of policies can influence social behaviors by presenting a resident/employee with more transportation choices. The more times non-motorized transportation choices are selected as a method of travel, the more reduction in VMT per capita will be observed within the population.

While these policies can help to reduce the VMT per capita and VMT per employee, it is not anticipated that they would be sufficient to achieve the reduction of 13% below existing baseline for the city as a whole. The following mitigation measures would be required in conjunction with the development of land use and infrastructure projects in order to mitigate the VMT impacts to the extent feasible. However, there are no feasible mitigation measures that would fully mitigate this impact. This impact will remain significant and unavoidable.

Mitigation Measures
T-2a Street Network
For individual development projects within the Infill Rezone Program that will include an internal street network, provide a well-connected street network, particularly for non-motorized connections. Characteristics of street network connectivity include short block lengths, numerous three and four-way intersections, and minimal dead-ends (cul-de-sacs). Street connectivity helps to facilitate shorter vehicle trips and greater numbers of walk and bike trips and thus a reduction in

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VMT. The CAPCOA Handbook4 Measure T-17 uses increased vehicle intersection density as a proxy for street connectivity improvements. The CAPCOA Handbook estimates that VMT can be reduced up to 30 percent if a development provides a street grid that has much greater density (up to about three times) of streets and street intersections than the average American street grid density of 36 street intersections per square mile.

T-2b Bicycle Network
For individual development projects within the Infill Rezone Program, contribute to increasing the length of the area bicycle network, including separated trails available to bicycles as well as onstreet bike lanes. The CAPCOA Handbook Measure T-20 estimates that a 20 percent increase in bike network mileage could reduce citywide VMT by 0.01 percent. The total daily VMT generated in Clovis is approximately 4,285,900, so this increase in bike network would reduce daily VMT by approximately 430. Note that these VMT reductions would occur citywide and would not exclusively affect project trips.

T-2c Transit Service
For individual development projects within the Infill Rezone Program, contribute to implementation of expanded transit service in Clovis, including potentially extending service to the project areas.

Implementation of expanded transit service would require both capital expenditures for support facilities, including construction of transit stops and facilitating extensions of future transit routes.

The CAPCOA Handbook Measure T-25 estimates that a 25 percent increase in transit service hours could reduce citywide VMT by 0.3 percent. The total daily VMT generated in Clovis is approximately 4,285,900, so the expanded transit network would reduce daily VMT by approximately 12,850. Note that these VMT reductions would occur citywide and would not exclusively affect project trips.

Significance after Mitigation
Significant and unavoidable.

Threshold 3: Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
IMPACT T-3 DEVELOPMENT ASSOCIATED WITH THE PROJECT WOULD NOT INCREASE HAZARDS DUE TO GEOMETRIC DESIGN AND INCOMPATIBLE USES. THROUGH COMPLIANCE WITH APPLICABLE REGULATIONS, IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Implementation of the proposed project would increase the number of users on the city’s transportation system. There will be a need to ensure that hazards are not increased with the construction of new facilities and the addition of new users.

It is noted that the project is at a programmatic-level, which does not include actual design or construction of facilities. Hazards are typically assessed at the project-level when an actual design and construction of a circulation facility is proposed. Future development projects would be analyzed and evaluated in detail through the review process for those later projects. The city’s design and construction standards and specifications provide for coordinated and standardized 4 California Air Pollution Control Officers Association (CAPCOA), Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity, December, 2021. Accessible at:
https://www.airquality.org/ClimateChange/Documents/Final%20Handbook_AB434.pdf

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development of city facilities, including roadways. The standards apply to, regulate, and guide the design and preparation of plans, and the construction of streets, highways, alleys, drainage, traffic signals, site access, and related public improvements.

The General Plan Circulation Element contains policies in support of safe circulation by all modes, including requirements that roadways are designed consistent with city standards, designed to provide adequate emergency access and address safety concerns. The Circulation Element includes policies to minimize the number and enhance safety at vehicular conflict points (Policy 3.7), and to partner with advocacy groups to improve design, location, and functionality of bicycle lanes to encourage safe travel (Policy 8.3).

Implementation of General Plan policies would ensure that each future project would have a less than significant impact related to hazards.

Mitigation Measures
No mitigation measures are required.

Threshold 4: Would the project result in inadequate emergency access? IMPACT T-4 DEVELOPMENT ASSOCIATED WITH THE PROJECT WOULD NOT RESULT IN INADEQUATE EMERGENCY ACCESS. THROUGH COMPLIANCE WITH CITY DEVELOPMENT STANDARDS, IMPACTS WOULD BE LESS THAN SIGNIFICANT.

It is noted that the project is at a programmatic-level, which does not include actual site design or construction of facilities. The city’s design and construction standards and specifications provide for coordinated and standardized development of city facilities, including roadways. The standards apply to, regulate, and guide the design and preparation of plans, and the construction of streets, highways, alleys, drainage, traffic signals, site access, and related public improvements, and ensure that emergency access to each site meets applicable standards.

The General Plan Circulation Element contains policies in support of safe circulation by all modes, including requirements that roadways are designed consistent with city standards, designed to provide adequate emergency access and address safety concerns. The Circulation Element includes policies to minimize the number and enhance safety at vehicular conflict points (Policy 3.7), and to partner with advocacy groups to improve design, location, and functionality of bicycle lanes to encourage safe travel (Policy 8.3).

Implementation of city standards for individual site development would ensure that each future project would have a less than significant impact related to emergency access.

Mitigation Measures
No mitigation measures are required.

4.13.4 Cumulative Impacts
VMT was calculated for the Clovis area including current city limits and the SOI. Table 4.13-4 summarizes the total citywide VMT for the 2019 baseline, the applicable threshold, and the future cumulative 2046 VMT with the RTP/SCS and the project. As shown in the table, cumulative conditions with the Infill Rezone Program project would result in decreased VMT per capita and VMT per employee in comparison to the 2019 baseline condition in Clovis. Residential VMT per

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capita would decrease by 4.4 percent, from 16.1 to 15.4, but would still be above the regional impact threshold of 14.0. Non-residential VMT per employee would decrease by 10.6 percent, from

24.6 to 22.0, and would be below the regional impact threshold of 22.3.

While the General Plan policies can help to reduce the VMT per capita and VMT per employee, it is not anticipated that they would be sufficient to achieve the reduction of 13% below existing baseline for the city as a whole. The following mitigation measures would be required in conjunction with the development of land use and infrastructure projects in order to mitigate the VMT impacts to the extent feasible. However, there are no feasible mitigation measures that would fully mitigate this impact. This impact will remain significant and unavoidable.

Table 4.13-4 Cumulative Vehicle-Miles of Travel Results Units 2019 Fresno County 2019 Clovis SOI 2046 RTP/SCS Clovis SOI Plus Project VMT Per Capita
Population 1,010,400 144,067 182,576
Residential VMT 16,267,400 2,153,575 2,609,846
VMT per Capita 16.1 16.1 15.4
Impact Threshold 14.0 14.0 14.0
VMT Per Employee
Employees 404,100 36,537 44,568
Employee VMT 10,345,340 900,158 979,232
VMT per Employee 25.6 24.6 22.0
Impact Threshold 22.3 22.3 22.3
Total VMT 51,389,619 5,451,855 8,747,093
Source: Kittelson & Associates, 2025, applying Fresno COG travel model.

Mitigation Measures
Implement mitigation measures T-2a, T-2b, and T-2c.

Significance after Mitigation
Significant and unavoidable.

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4.14 Tribal Cultural Resources
This section evaluates the project’s potential impacts relating to tribal cultural resources (TCRs) and cultural places. Public Resources Code (PRC) Section 21074 (a)(1)(A) and (B) defines TCRs as “sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe.” Additionally, TCRs are those resources identified by California Native American tribes in consultation with lead agencies during tribal consultation [Senate Bill (SB) 18 and Assembly Bill (AB) 52 consultation]. Cultural places are defined as “a Native American sanctified cemetery, place of worship, religious or ceremonial site, or sacred shrine” (PRC Section 5097.9). The analysis in this section is based on a Cultural Resources Technical Report prepared by Rincon Consultants (Rincon) and the results of the City’s SB 18 and AB 52 consultation. The Cultural Resources Technical Report and Consultation letters are provided in Appendix C and Appendix D of this Environmental Assessment (EA).

4.14.1 Setting
The 20 Infill Rezone Program sites are located within the Clovis City limits within the Central Valley.

This region has been described as one of the largest intermontane basins extending 650 km from the Siskiyou to the Tehachapi mountains.1 No single chronological framework covers the entirety of the Central Valley, but California prehistoric cultural chronology of the Central Valley is presented following Rosenthal et al. (2007), Moratto (1984), and Burns et al. (2012), which ultimately divides the chronology into five major periods: the Paleoindian (11,550–8,550 BCE), Lower Archaic (8,550– 5,550 BCE), Middle Archaic (5,550–550 BCE), Upper Archaic (550 BCE–CE 1,100), and Emergent Period (CE 1,000 to Historic contact). Refer to Section 4.4, Cultural Resources, for more information on these time periods.

The project site is located in the traditional territory of the Penutian-speaking Yokuts, which includes San Joaquin Valley and surrounding foothills.
2,3 Three geographical divisions of the Yokuts
are the Northern Valley, Southern Valley, and Foothill Yokuts. The distinction between the three groups is primarily based on language dialect.4 The project is located at the approximate boundary between the ethnographic territories of the Northern and Southern Valley Yokuts, though more likely located within the ethnographic territory of the Southern Valley Yokuts, who occupied the southern San Joaquin Valley south of the San Joaquin River, to the foot of the Tehachapi Mountains.

More specifically, the vicinity of the project site was likely within the territory of the Tachi.3 The Yokuts established large permanent village settlements, or closely associated smaller settlements. Residential structures were most often of two types: single-family dwellings and larger communal residences that housed 10 families or more. Villages frequently included mat-covered granaries and a sweathouse.4,5 The closest known village sites to the project site were “Golon”, near the present-day community of Huron (approximately 16 miles south of the project site); and 1 Rosenthal, Jeffrey, Gregory White, and Mark Sutton. 2007.The Central Valley: A View from the Catbird’s Seat. In California Prehistory:

Colonization, Culture, and Complexity, edited by Terry L. Jones and Kathryn A. Klar. AltaMira Press, Lanham Maryland. 2 Kroeber, Alfred L. 1925 Handbook of the Indians of California. Bulletin 78, Bureau of American Ethnology, Smithsonian Institution.

Government Printing Office, Washington, D.C. Reprinted 1976 by Dover Publications, Inc., New York. 3 Wallace, William J. 1978 “Southern Valley Yokuts.” In “California,” edited by Robert F. Heizer, pp. 448–461. Handbook of North American Indians, Vol. 8, William C. Sturtevant, general editor, Smithsonian Institution, Washington. 4 Mithun, Marianne 2001 The Languages of Native North America. Reprinted. Originally published 1999. Cambridge University Press, New York.
5 Sutton, Mark Q., Jille K. Gardner, Kenneth W. Gobalet, and Nancy Valente 2016 “Archaeological Investigations at the Manifold Site (CAKER-4220), Buena Vista Lake, Southern San Joaquin Valley, California.” Pacific Coast Archaeological Society Quarterly, Vol. 52 (4), pp. 15-

82.

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“Udjiu”, in a location later known as Posa de Chine or Poso Chane (approximately 18 miles south of the project site).
3 Most of the western San Joaquin Valley is regarded as too arid to have supported permanent village sites, though the area was likely used for hunting and utilized for travel.6 The western periphery of the San Joaquin Valley was spanned by a major Native American trail, known by the Spanish name El Camino Viejo.7 El Camino Viejo stretched from modern-day Los Angeles to Alameda County, and Cantua Creek served as a campsite along the route. Prominent intersecting east-west trails were likely found along Panoche Creek (20 miles north of project site) and Los Gatos Creek (16 miles south of project site), connecting Yokuts communities to their western neighbors through the Coast Range.3 The Fresno Slough and other waterways also served as travel corridors by tule raft.3,6
The basic economic unit among the Yokuts was the nuclear family. The nuclear family was linked to totemic lineages based on patrilineal descent. Totem symbols were passed from father to offspring.

Families that shared the same totem formed an exogamous lineage. Totems were associated with one of two moieties. This moiety division played a role during ceremonies and other social events.

Yokuts were split into self-governing local groups that included several villages. Each group had a chief who directed ceremonies, mediated disputes, handled punishment of those doing wrong, hosted visitors, and provided aid to the impoverished. In certain cases, settlements had two chiefs, one for each moiety. Other political positions included the chief’s messenger and the spokesman.3 Shamans were an important part of Yokut village life. A Yokut Shaman gained power through a dream or vision. If, after this vision, the man accepted the role as shaman, he would pray, fast, and acquire talismans to aid him in his future work. Shamans had the ability to heal the sick and served a primary role in religious life.3
Yokuts subsistence strategy was based on a mixed economy focused on fishing, collecting, and hunting small game. Fishermen employed tule rafts and caught fish with nets, spears, basket traps, and bow and arrows. They often gathered mussels and hunted turtles in lakes, rivers, and streams.

Wild seeds and roots contributed a large portion to the Yokuts diet. Tule roots were gathered, dried, and pounded into a flour that was prepared as a mush. Tule seeds and grass and flowering herb seeds were prepared in the same way. Leaves and stems of certain plants, such as clover and fiddleneck, were also collected. Acorns, a staple of most California Native Americans, were not readily available in the ethnographic territory of the Yokuts. Some Yokuts tribes traded for acorns with neighboring groups, such as the Salinan and Chumash to the west, the Foothill Yokuts to the east, and the Kawaiisu and Kitanemuk to the southeast.2 Waterfowl was frequently hunted with snares, nets, and bow and arrow. Land mammals and birds contributed a smaller part of the Yokuts diet. Small game was occasionally taken in snares or traps or shot with bow and arrow. 3,5
Yokuts technology depended primarily on tule. Stems of the plant served as the raw material for baskets, cradles, boats, housing, and many other items. Manos and metates were used to process food and animal hides.8,5 Tools such as knives, projectile points, and scraping tools were made from imported lithic materials, because stone was not readily available in the Central Valley. Some tools, such as bead drills, could be made from obsidian obtained from some distance or obtained through trade (Sutton et al. 2016). Marine shells secured through trade with coastal groups were used as shell money and personal adornment items, such as Olivella beads.5,3 6 Gayton, A.H. 1945 Yokuts and Western Mono Social Organization. American Anthropologist 47(3):409-426. 7 Davis, James 1961 Trade Routes and Economic Exchange Among the Indians of California. Reports of the University of California Archaeological Survey 54.
8 Barton, Amber, Maria Del Carmen Guzman, and Breeann Romo 2010 The Preliminary Results of the 2008 Archaeological Investigations at the Bead Hill Site (KRE-450), Buena Vista Lake, California. SCA Proceedings 24: 1-12.

Environmental Impact Analysis
Tribal Cultural Resources
Environmental Assessment 4.14-3

4.14.2 Regulatory Setting
a. Federal Regulations
American Indian Religious Freedom Act and Native American Graves and Repatriation Act
The American Indian Religious Freedom Act (AIRFA), enacted in 1978, is a federal law that affirms and protects the rights of American Indians, Alaska Natives, and Native Hawaiians to practice their traditional religions. Prior to AIRFA, many Indigenous religious practices-such as ceremonies, access to sacred sites, and possession of sacred objects-were restricted or even banned by federal policy.

AIRFA recognizes the inherent right of Indigenous peoples to believe, express, and exercise their traditional religions, and it protects their access to sacred sites, the use and possession of sacred objects, and the freedom to conduct ceremonial rites. AIRFA requires federal agencies and institutions receiving federal funds (such as museums and universities) to return Native American human remains, funerary objects, sacred objects, and objects of cultural patrimony to lineal descendants and culturally affiliated tribes or Native Hawaiian organizations. The law also mandates consultation with tribes and descendants when remains or cultural items are discovered on federal or tribal lands and establishes processes for planned excavations and inadvertent discoveries. b. State Regulations
Senate Bill 18
California Government Code Section 65352.3 (adopted pursuant to the requirements of SB 18) requires local governments to contact, refer plans to, and consult with tribal organizations prior to making a decision to adopt or amend a general or specific plan. The tribal organizations eligible to consult have traditional lands in a local government’s jurisdiction and are identified, upon request, by the California Native American Heritage Commission (NAHC). As noted in the California Office of Land Use and Climate Innovation (LCI)’s Tribal Consultation Guidelines, “the intent of SB 18 is to provide California Native American tribes an opportunity to participate in local land use decisions at an early planning stage, for the purpose of protecting, or mitigating impacts to, cultural places.” 9 SB 18 refers to PRC Section 5097.9 to define cultural places as:
 A Native American sanctified cemetery, place of worship, religious or ceremonial site, or sacred shrine (PRC Section 5097.9)
Assembly Bill 52
AB 52 expanded the California Environmental Quality Act (CEQA) by defining a new resource category, “tribal cultural resources.” AB 52 establishes, “a project with an effect that may cause a substantial adverse change in the significance of a TCR is a project that may have a significant effect on the environment” (PRC Section 21084.2). It further states the CEQA lead agency shall establish measures to avoid impacts that would alter the significant characteristics of a TCR, when feasible (PRC Section 21084.3).
9 Office of Land Use and Climate Innovation. 2005. Tribal Consultation Guidelines. Available:
https://lci.ca.gov/docs/011414_Updated_Guidelines_922.pdf (accessed May 2025).

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PRC Section 21074 (a) defines TCRs as either of the following:
1) Sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either of the following:
a. Included or determined to be eligible for inclusion in the California Register of Historical Resources (CRHR).
b. Included in a local register of historical resources as defined in subdivision (k) of PRC Section 5020.1.
2) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of PRC Section 5024.1.

AB 52 also establishes a formal consultation process with California Native American tribes that must be completed before a CEQA document can be certified. Under AB 52, lead agencies are required to “begin consultation with a California Native American tribe that is traditionally and culturally affiliated with the geographic area of the proposed project.” California Native American tribes to be included in the process are those that have requested notice of projects proposed within the jurisdiction of the lead agency.

Assembly Bill 978
In 2001, AB 978 expanded the reach of Native American Graves Protection and Repatriation Act of 1990 and established a state commission with statutory powers to assure that federal and state laws regarding the repatriation of Native American human remains and items of patrimony are fully complied with. In addition, AB 978 also included non-federally recognized tribes for repatriation California Register of Historic Resources
The CRHR was established in 1992 and codified in PRC Section 5020, 5024 and 21085. The law creates several categories of properties that may be eligible for the CRHR. Certain properties are included in the program automatically, including: properties listed in the National Register of Historic Places (NRHP); properties eligible for listing in the NRHP; and certain classes of State Historical Landmarks. Determining the CRHR eligibility of historic and prehistoric properties is guided by California Code of Regulations (CCR) Section 15064.5(b) and PRC Section 21083.2 and 21084.1. Cultural resources, under CRHR guidelines, are defined as buildings, sites, structures, or objects that may have historical, architectural, archaeological, cultural, or scientific importance. A cultural resource may be eligible for listing on the CRHR if it:
 is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage;
 is associated with the lives of persons important in our past;  embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual or possesses high artistic values; or  has yielded, or may be likely to yield, information important in prehistory or history.

Environmental Impact Analysis
Tribal Cultural Resources
Environmental Assessment 4.14-5
c. Local Regulations
City of Clovis General Plan
The City’s 2014 General Plan includes several policies relevant to the project and the protection of TCRs. Such policies include:

Open Space and Conservation Element
Goal 2: Natural, agricultural, and historic resources that are preserved and promoted as key features for civic pride and identity.

Policy 2.9 National and State Historic Resources. Preserve historical sites and buildings of state or national significance in accordance with the Secretary of Interior Standards for Historic Rehabilitation.

Policy 2.12 Public Education. Support public education efforts for residents and visitors about the unique historic, natural, and cultural resources in Clovis.

Public Facilities and Services Element
Goal 4: Community facilities and programs that connect members of all ages and abilities to a broad range of cultural, informational, and recreational resources.

Policy 4.1 Cultural Facilities. Encourage the establishment of a broad range of facilities and events that expose Clovis residents to a variety of cultures, the arts, history, and technology.

4.14.3 Impact Analysis
a. Methodology and Significance Thresholds
Methodology
Given the programmatic nature of this EA, all future housing developments would require projectlevel tribal cultural analysis to identify the potential presence of TCRs. The Cultural Resources Technical Report (Appendix C) which supports this analysis utilized a background and archival research, CHRIS records search, and a NAHC Sacred Lands File (SLF) search. More information about the background archival research and CHRIS records search can be found in Section 4.4, Cultural Resources.

Rincon contacted the NAHC on April 9, 2025, to request a SLF search, as well as a contact list of Native Americans culturally affiliated with the project area. On April 9, 2025, the NAHC responded to Rincon’s SB 18 contacts request and SLF request, stating that the results of the SLF search were negative. See Appendix D for the NAHC response, including Tribal contacts list(s).

Rincon did not conduct any outreach to the Native American contacts in the area. The City conducted tribal outreach in accordance with SB 18 and AB 52 as seen below.

Senate Bill 18 and Assembly Bill 52 Consultation
On March 26, 2025, the City sent SB 18 and AB 52 notification letters via certified mail to 11 Native American tribal contacts from eight distinct tribes identified by the NAHC as being traditionally and culturally affiliated with the Place of Use. The tribes that were contacted include the following:

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 Amah Mutsun Tribal Band
 Kitanemuk & Yowlumne Tejon Indians
 Northern Valley Yokut / Ohlone Tribe
 Picayune Rancheria of the Chukchansi Indians
 Table Mountain Rancheria
 Traditional Choinumni Tribe
 Tule River Indian Tribe
 Wuksachi Indian Tribe/Eshom Valley Band
The City also sent AB 52 letters to tribes who have submitted written requests to be notified of any potential development within the City. These tribes include:
 Santa Rosa Rancheria Tachi-Yokut Tribe
 Table Mountain Rancheria
 Torres-Martinez Desert Cahuilla Indians
Under SB 18 and AB 52, tribes have 90 and 30 days to respond and request consultation, respectively.

As of the writing of this EA, the City has received two responses, one from the Traditional Choinumni Tribe and the other from the Table Mountain Rancheria. No responses were received from the other nine groups notified.

On April 2, 2025, the Traditional Choinumni Tribe responded to the City’s letter stating that they are always concerned regarding the potential unearthing of cultural resources during construction. If a cultural resource were to be discovered, all work must stop and a professional archaeologist would need to assess findings and make the appropriate mitigation recommendations. They had no other concerns with the project at this time.

On April 30, 2025, the Table Mountain Rancheria tribe responded to the City’s letter stating that they declined participation in consultation at this time but would like to be notified if any cultural resources are identified.

Significance Thresholds
According to Appendix G of the CEQA Guidelines, impacts related to TCRs would be significant if the proposed project would:

Cause a substantial adverse change in the significance of a TCR, defined in PRC Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American Tribe, and that is:
a) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC Section 5020.1(k), or b) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of PRC Section 5024.1. In applying the criteria set forth in subdivision (c) of PRC Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American Tribe.

Environmental Impact Analysis
Tribal Cultural Resources
Environmental Assessment 4.14-7
b. Project Impacts and Mitigation Measures
Threshold 1: Would the project cause a substantial adverse change in the significance of a TCR, defined in PRC Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American Tribe, and that is:
a. Listed or eligible for listing in the CRHR, or in a local register of historical resources as defined in PRC Section 5020.1(k), or
b. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of PRC Section 5024.1. In applying the criteria set forth in subdivision (c) of PRC Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American Tribe.

Impact TCR-1 NO KNOWN TCRS HAVE BEEN IDENTIFIED WITHIN THE INFILL REZONE PROGRAM SITES.

HOWEVER, THE PROJECT MAY CAUSE A SUBSTANTIAL ADVERSE CHANGE IN THE SIGNIFICANCE OF A

PREVIOUSLY UNKNOWN OR UNIDENTIFIED TCR DUE TO GROUND DISTURBANCE DURING PROJECT CONSTRUCTION ACTIVITIES. IMPACTS WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED.

The project itself would not generate any development or impacts to TCRs. Any future project resulting in development made possible by this upzoning project may be subject to project-level CEQA analysis and may require future, project-specific consultation with tribal groups. As such, project-level mitigation measures may arise through subsequent SB 18 and/or AB 52 consultation undertaken as part of CEQA analysis for future development projects.

Additionally, as identified by the Cultural Resources Technical Report discussed in Section 4.4, Cultural Resources, no TCRs listed or eligible for listing in the CRHR were identified. On April 9, 2025, as a part of the Cultural Resources Technical Report, the NAHC conducted a SLF search for the project area. The SLF search did not identify the presence of known TCRs within or in the vicinity of the Infill Rezone Program sites.

As discussed above, only two out of 11 contacted tribes responded to the City’s SB 18 and AB 52 letters alerting tribes of the project. Both tribes that responded wished to be notified if any TCRs were discovered during excavation of future development projects. There is always the potential to uncover buried archaeological and TCRs during ground disturbing activities, which could potentially be considered TCRs eligible for listing in the CRHR or a local register or be considered TCRs. Should project construction activities encounter and damage or destroy a TCR or resources, impacts would be potentially significant. Mitigation Measure (MM) TCR-1 would ensure that TCRs are preserved in the event they are uncovered during construction and would reduce impacts regarding disrupting TCRs to a less than significant level. Implementation of MM TCR-1 would ensure that consultation with local Native Americans would occur if resources of Native American origin are unearthed during construction, and that implementing a mitigation plan would be implemented if a previously unknown TCR is discovered during project construction. This would reduce impacts to TCRs to less than significant with mitigation.

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Mitigation Measure
TCR-1 Inadvertent Discoveries During Construction
In the event that cultural resources of Native American origin are identified during grading or construction, all earth disturbing work within a 50-foot radius of the find shall be temporarily suspended or redirected until a qualified archaeologist has evaluated the nature and significance of the find; an appropriate Native American representative, based on the nature of the find, is consulted; and mitigation measures are put in place for the disposition and protection of any find pursuant to Public Resources Code Section 21083.2. If the City, in consultation with local Native Americans, determines that the resource is a tribal cultural resource (TCR) and thus significant under the California Environmental Quality Act, a mitigation plan shall be prepared and implemented in accordance with state guidelines and in consultation with local Native American group(s) prior to continuation of any earth disturbing work within the vicinity of the find. The plan shall include avoidance of the resource or, if avoidance of the resource is infeasible, shall outline the appropriate treatment of the resource in coordination with the appropriate local Native American tribal representative and, if applicable, a qualified archaeologist. Examples of appropriate mitigation for TCRs include, but are not limited to, protecting the cultural character and integrity of the resource, protecting traditional use of the resource, protecting the confidentiality of the resource, or heritage recovery through capping in place, excavation and removal of the resource, interpretive displays, sensitive area signage, or other mutually agreed upon measures.

Significance after Mitigation
Less than significant with mitigation measure incorporated.

4.14.4 Cumulative Impacts
The geographic scope for cumulative impacts related to TCRs is the regional area. This geographic scope is appropriate because TCRs have the potential to extend across large areas.

Projects developed following the upzoning of Infill Rezone Program sites in conjunction with past, present, and reasonably foreseeable future projects, would result in ground disturbance in locations where TCRs have currently not been identified but have the potential to occur. As such, cumulative development could adversely impact TCRs. However, TCR evaluations and SB 18 and/or AB 52 consultations would be completed by the appropriate jurisdiction on a case-by-case basis for all future development. Compliance with applicable regulations and implementation of appropriate mitigation measures, including resource avoidance measures, monitoring during ground disturbance within culturally sensitive areas, and preparation of mitigation plans for the inadvertent discovery of TCRs, would address impacts related to TCRs associated with future development. Therefore, cumulative development would have a less-than-significant cumulative impact involving substantial adverse changes in the significance of a TCR.

Mitigation Measures
Implement mitigation measure TCR-1.

Significance after Mitigation
Less than significant with mitigation measures.

Environmental Impact Analysis
Utilities and Service Systems
Environmental Assessment 4.15-1

4.15 Utilities and Service Systems
This section analyzes the effects of the proposed project on utilities and service systems. It considers potential impacts to water supply and infrastructure, wastewater conveyance and treatment facilities, stormwater and drainage facilities, solid waste disposal, electricity and natural gas, as well as telecommunications facilities.

4.15.1 Setting
a. Water
The City of Clovis (City) relies upon groundwater, surface water, treated wastewater and recycled water for water supply. Potable water is supplied by underground aquifers and the City’s Surface Water Treatment Plant (SWTP).
1 Groundwater
The City boundaries lie within the Kings Groundwater Subbasin, a part of the San Joaquin Basin Hydrologic Area. The Kings Subbasin has been identified as critically overdrafted in the City’s Urban Water Management Plan (UWMP).
2 The City’s water system includes over 30 wells with a combined capacity of approximately 37,690 gallons per minute (gpm), with an additional 4,750 gpm planned in the coming years. In 2020, the City extracted 12,105 acre-feet (AF) of groundwater and performed 5,316 AF of intentional recharge activities.

To comply with the Sustainable Groundwater Management Act (SGMA), the City collaborated with other agencies in the subbasin to develop the North Kings Groundwater Sustainability Plan (NKGSP).

This plan outlines the subbasin’s characteristics and provides a roadmap for achieving sustainable aquifer management by 2040.3 The net impact in 2020 was positive, contributing to slowing or reversing groundwater level declines. The City remains committed to recharge efforts, as reflected in its projected intentional groundwater recharge activities. In 2020, recharge was 5,316 AF, while the City’s 30-year average groundwater recharge quantity is approximately 8,412 acre-feet per year (AFY).
4 Surface Water
Fresno Irrigation District
Surface water is supplied to the City through an agreement with the Fresno Irrigation District (FID) by which the City receives a portion of FID’s entitlement to Kings River Water proportional to the amount of FID land that lies within the City. FID is a member of the Kings River Water Association which holds water rights licenses for all of the Kings River and storage rights licenses on Kings River 1 City of Clovis. 2014. City of Clovis General Plan EIR. Accessible at:
https://www.clovisca.gov/services/planning_development/planning/general_plan/environmental_impact_report.php 2 City of Clovis. 2020. 2020 Urban Water Management Plan update. Accessible at:
https://cms2.revize.com/revize/clovis/documents/Services/Public%20Utilities/Water/2020-UWMP-Adopted-July2021_reduced.pdf?t=202507181312520&t=202507181312520 3 North Kings Groundwater Sustainability Agency. 2025. 2025 Groundwater Sustainability Plan. Accessible at:
https://northkingsgsa.org/groundwater-sustainability-plan/ 4 City of Clovis. 2020. 2020 Urban Water Management Plan update. Accessible at:
https://cms2.revize.com/revize/clovis/documents/Services/Public%20Utilities/Water/2020-UWMP-Adopted-July2021_reduced.pdf?t=202507181312520&t=202507181312520

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reservoirs. FID is entitled to water based upon a prorated monthly schedule determined by the natural flow of the Kings River. Surface water is treated before delivery to customers at the SWTP.

Two additional water districts are located within the City’s General Plan boundaries: Garfield Water District and International Water District.

Water Banking Facilities
Two banking facilities have been constructed in Central Fresno County: Waldron Pond and the Boswell Groundwater Banking Facility. The City entered into an agreement with FID to help finance the construction of the Waldron Banking Facilities, a dedicated water banking project. Under this agreement, the City is entitled to receive up to 90% of the annual yield (approximately 9,000 AF).

The purpose of these facilities is to reserve surplus water supplies, thereby making it available to the City as needed during dry periods. Excess that is not withdrawn from the aquifer will restore groundwater levels in the region. The City will have access to surplus water banked at the Boswell Groundwater Banking Facility whereby up to 4,500 AFY of surface water.

Wastewater and Recycled Water Supply
Clovis Water Reuse Facility
The City constructed a Water Reuse Facility, a wastewater treatment plant, that began service in 2009. The facility produces a disinfected, tertiary-treated water supply, which is used for both landscaping and agricultural uses.

Regional Wastewater Treatment Plant Exchange
A large portion of the City of Clovis' wastewater is treated at the Fresno-Clovis Regional Wastewater Reclamation Facility (RWRF), located southwest of the City of Fresno. It is approximately 16 miles by trunk sewer to the City. Currently, the water is treated to the secondary level and then some is spread in percolation ponds and some is used directly on non-food crops. The Fresno-Clovis RWRF serves approximately 510,000 residents in the Fresno/Clovis area.5 In 2016 the RWRF had a treatment capacity of 88 million gallons per day (mgd), making it the fourth largest municipal wastewater facility in Northern California.

Water Service
The City’s Public Utilities Department (PUD) is the sole municipal water purveyor to approximately 106,000 residents in the City and sphere of influence (SOI). The City’s PUD also provides water to Tarpey Village, a small unincorporated county island with a population of 3,609. 6 The applicable
service boundaries and City water distribution system are shown in Figure 4.15-1 below. 5 Environmental Protection Agency. City of Fresno Reclamation Facility. 2016. Accessed November 2025:
https://www.epa.gov/sites/default/files/2016-05/documents/wrrf_fresno_v2_may_12.pdf 6 U.S. Census. 2019. Tarpey Village , CA. Accessible at: https://censusreporter.org/profiles/16000US0677960-tarpey-village-ca/

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Utilities and Service Systems
Environmental Assessment 4.15-3
Figure 4.15-1 City of Clovis Water System Service Area

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Current and Projected Water Demand and Supply
Current and Projected Use
The majority of water demand within the City’s service area is for residential uses. Commercial, institutional, industrial, and landscape uses account for approximately 15 percent of the total water usage. Table 4.15-1 below shows the Actual Volume of current and projected potable and nonpotable water use in the city.

Table 4.15-1 Current (2020) and Future Potable and Non-potable Water Use Use Type 2020 Water Use (AF) Projected 2030 (AF) Projected 2035 (AF) Projected 2040 (AF) Single Family 16,638 18,558 20,353 22,237
Multi-Family 2,434 2,715 2,978 3,226
Commercial 2,518 3,346 3,670 4,026
Institutional 703 934 1,025 1,124
Industrial 267 355 389 427
Landscape 1,102 1,465 1,607 1,763
Other 76 101 111 122
Losses 1,090 1,449 1,589 1,743
Groundwater Recharge 5,316 8,400 8,400 8,400
Total 30,144 37,324 40,122 43,198
Source: Clovis UWMP. 2020.

Current and Projected Water Supply
Current and future supplies through 2040, as included in the 2020 UWMP, are shown in Table 4.15-2. The future supply projections assume normal surface water entitlements from the FID and incorporated water districts based on the most recent 30-year averages and anticipated growth rates for the City.

Table 4.15-2 Current (2020) and Future Potable and Non-potable Water Supply Water Supply
2020 Water Supply
(AF)* Projected 2030(AF)
Projected 2035
(AF)
Projected 2040
(AF)
Groundwater 12,105 10,753 10,076 9,400
Surface Water 18,039 27,584 32,508 39,400
Storage Supply 0 13,500 13,500 13,500
Recycled 710 5,500 6,300 9,400
Transfers (Garfield) N/A 1,100 1,650 1,750
Transfers (International WD) N/A 500 1,000 1,200
Total 30,854 58,937 65,034 74,650
Source: Clovis UWMP. 2020.
*The 2020 UMWP identifies 2020 as a dry year supply. The actual 2020 supply (Total Right or Safe Yield) for the service area consisting of surface water, groundwater, supply water from storage and recycled water for 2020 was 53,748 AF.

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Utilities and Service Systems
Environmental Assessment 4.15-5
As shown, water supply is projected to increase to 74,650 AFY in 2040. Water demand is projected to increase to 43,198 AFY in 2040. The City has identified adequate water supply to meet water demands as projected for 2040 in the 2020 UWMP.

Water Conservation
The City of Clovis UWMP provides mitigation measures for potential water shortages focused on both increasing supply and reducing demand. Methods to increase water supply in the City require the construction of new facilities and thus have a lead time of at least one year before production is increased. Demand reduction techniques are considered more feasible and immediate solutions to a potential water shortage.

Water Supply Contingency Plan
The Urban Water Management Planning Act (UWMPA) requires that each UWMP include a Water Shortage Contingency Analysis (WSCP). The WSCP includes actions an urban water supplier will take during water supply shortages, including scenarios where supplies are reduced by more than 50 percent. It must also define specific water supply conditions associated with each shortage level in compliance with California Water Code Sections 10632 and 10635.

The City’s 2020 WSCP classifies water shortages in four stages and details target demand reductions and necessary actions for each stage.7 In addition to these action levels, the City is required to establish mandatory prohibitions on certain water uses during shortages and implement consumption reduction measures at the most restrictive levels. b. Wastewater
Wastewater Service
The City’s PUD provides wastewater collection services within the City limits. The Clovis Wastewater Collection System Master Plan describes the sewer system infrastructure within the City and covers a service area of just over 23,500 acres and seven major service areas.8 These seven major wastewater service areas also represent the City’s entire water service area. According to the 2020 UWMP, under existing conditions, the Herndon, Fowler, Sierra, and Peach service areas discharge into the City’s regional trunks, which convey flows to the RWRF. Flow from the remaining three service areas (Northwest, Northeast, and Southeast) are conveyed to the Clovis Water Reuse Facility. Herndon, Fowler, Sierra, and Peach service areas will continue to discharge to regional trunk sewers and on to the Fresno-Clovis RWRF.

Wastewater Infrastructure
The wastewater collection and treatment infrastructure serving the City is provided by the PUD.

According to the 2017 Wastewater Collection System Master Plan, the City generates an average daily flow of 7.018 mgd (7,861 AFY).9 Wastewater system map is shown in Figure 4.15-2. 7 City of Clovis. Water Supply Contingency Plan. 2020. Accessible at:
https://cms2.revize.com/revize/clovis/documents/Services/Public%20Utilities/Water/2020-WSCP-Adopted-July2021_reduced.pdf?t=202507181312520&t=202507181312520 8 City of Clovis. 2017. Wastewater Collection System Master Plan. Clovis, CA: City of Clovis 9 Ibid.

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Figure 4.15-2 Clovis Wastewater Service Area
Source: 2014 Clovis General Plan. Public Facilities and Services Element.

Environmental Impact Analysis
Utilities and Service Systems
Environmental Assessment 4.15-7
Fresno-Clovis Regional Water Reclamation Facility
The majority of wastewater within the City is currently discharged to the Fresno-Clovis RWRF in southwest Fresno. The RWRF is owned and operated by the City of Fresno and currently has a treatment capacity of approximately 68 mgd.
10 By an agreement with the City of Fresno, the City is entitled to 9.3 mgd of this capacity. The City may also acquire additional capacity at the RWRF, if required. In 2020, 6,213 AF was treated at the RWRF.

Water Refuse Facility
The City operates the Water Reuse Facility to treat and disperse wastewater. In 2020, 2,496 AF of wastewater was treated at the Water Reuse Facility.
11 Water is used for irrigation of public and
private landscape within the service area.

Wastewater Treatment Capacity
The City’s Wastewater Master Plan provides estimates for current and projected wastewater treatment capacity. Construction and financing of major sewer trunk lines, treatment capacity and recycled water transmission to serve growth is funded in the City with development impact fees included in Clovis Municipal Code (CMC) Section 6.4.03.

The City’s 2014 General Plan Environmental Impact Report (EIR) examined the current and planned treatment capacity of the Water Refuse Facility and the RWRF as shown in Table 4.15-3 below.

Table 4.15-3 Wastewater Treatment Capacity
Treatment Facility 2008 Available Treatment Capacity (mgd) Planned Treatment Capacity (mgd) Clovis Water Refuse Facility 2.8 8.4
Fresno-Clovis RWRF 9.3 12.2
Total 12.1 20.6
Source: City of Clovis 2014 General Plan EIR.

According to the 2014 General Plan EIR, wastewater generated in the City was treated at regional wastewater treatment facilities. At that time, wastewater generation was estimated at approximately 7.0 mgd, based on flow metering data collected between June 2013 and May 2014.

With a population of 102,188, the per capita generation rate was about 69 gallons per person per day. The General Plan EIR evaluated a conservative estimate per person (85 for single-family and 95 for multi-family), and 0.2 gallons per square foot for non-residential and determined that total wastewater generations was approximately 11.15 mgd and projected the 2035 Scenario to generate about 19.7 mgd of wastewater.
10 City of Fresno. Fresno-Clovis Regional Wastewater Reclamation Facility. Accessed November 2025:
https://www.fresno.gov/publicutilities/sewer-wastewater/wastewater-facilities-infrastructure/#regional-wastewater-reclamation-facility 11 City of Clovis. 2020. 2020 Urban Water Management Plan update. Accessible at:
https://cms2.revize.com/revize/clovis/documents/Services/Public%20Utilities/Water/2020-UWMP-Adopted-July2021_reduced.pdf?t=202507181312520&t=202507181312520

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c. Stormwater
The storm drain system within the City is operated and maintained by the Fresno Metropolitan Flood Control District (FMFCD). The FMFCD service area includes both the Fresno and Clovis urban areas which are protected by three dams and seven large detention basins, and is served by a system of more than 700 miles of pipeline and more than 150 stormwater retention basins. FID canal system facilitates groundwater recharge during dry periods, providing an annual average of over 45,000 AF across approximately 100 basins.
12 d. Solid Waste
The City PUD collects solid waste; recycling and organic materials collection is provided under contract by Mid Valley Disposal. Solid waste generated within the City is delivered to the City’s landfill, American Avenue Disposal Site, and Avenal Regional Landfill. Construction debris and waste is hauled by City contractors, self-hauled by homeowners and businesses, or residual waste from recycling operations going to other landfills.

The City employs the “single stream” method of recycling in which all recyclable material (other than organic waste) goes into one collection receptacle. Recycling and organics are collected by the City’s contract service. The Integrated Waste Management Act (2000) requires all local jurisdictions to divert 50 percent of total annual solid waste tonnage to be recycled. The City’s total solid waste disposal amount in 2024 was approximately 100,178 tons.13 Construction and Demolition Debris
Construction and demolition debris within the City must adhere to CMC Chapter 6.3.1. Applicants must submit a Waste Management Plan to the Compliance Official unless they use an Authorized Construction and Demolition Debris Collector.

Hazardous Waste Disposal
The Clovis Dropoff Center, located at 79 North Sunnyside Avenue, allows residents to dispose of household hazardous materials such as batteries, motor oil, and household paints free of charge. e. Telecommunications, Electricity and Natural Gas
Telecommunications services in Clovis are provided by private companies, such as AT&T, Xfinity, Viasat, Verizon, and other providers which provide internet and phone services.

Pacific Gas & Electric Company (PG&E) is the primary provider of electricity and natural gas. PG&E services approximately 5.2 million residents throughout Northern and Central California with electric service and 4.3 million residents with natural gas. 14 Natural gas and electricity are addressed
in greater detail in Section 4.5, Energy.
12 Fresno Metropolitan Flood Control District. About Fresno Metropolitan Flood Control District. Accessed October 2025:
https://www.fresnofloodcontrol.org/
13 CalRecycle. 2024. Disposal Reporting. Accessible at:
https://www2.calrecycle.ca.gov/RecyclingDisposalReporting/Reports/JurisdictionDisposalAndBeneficial 14 Natural Gas and California. CPUC. Accessed October 2025: https://www.cpuc.ca.gov/industries-and-topics/natural-gas/natural-gas-andcalifornia

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4.15.2 Regulatory Setting
a. Federal Water Regulations
Clean Water Act
The federal Clean Water Act, enacted by Congress in 1972 and amended several times since, is the primary federal law that regulates water quality in the United States. It forms the basis for several State and local laws throughout the country. The Clean Water Act established the basic structure for regulating discharges of pollutants into the waters of the United States. The Clean Water Act gave the U.S. Environmental Protection Agency the authority to implement federal pollution control programs, such as setting water quality standards for contaminants in surface water, establishing wastewater and effluent discharge limits for various industry contaminants in surface water, establishing wastewater and effluent discharge limits for various industry categories, and imposing requirements for controlling nonpoint-source pollution. At the federal level, the Clean Water Act is administered by the U.S. Environmental Protection Agency and the U.S. Army Corps of Engineers (USACE). At the state and regional levels in California, the act is administered and enforced by the State Water Resources Control Board (SWRCB) and the nine Regional Water Quality Control Boards (RWQCBs).
b. State Water Regulations
Senate Bill 610
In 2001, California adopted Senate Bill (SB) 610, thereby amending California Water Code. Under this law, certain types of development projects are now required to provide detailed water supply assessments to planning agencies. Any project that is subject to CEQA and would demand more than 75 AFY of water, or an amount of water equivalent to, or greater than, the amount of water required by a 500-dwelling-unit project, is subject to SB 610 and is required to prepare a Water Supply Assessment (WSA). The primary purpose of a WSA is to determine whether the identified water supply or water supplier will be able to meet projected demands for the project, in addition to existing and planned future uses, over a 20-year projection and with consideration to normal, dry, and multi-dry water years.

Senate Bill 221
Whereas SB 610 requires a written assessment of water supply availability, SB 221 requires lead agencies to obtain an affirmative written verification of sufficient water supply prior to approval of certain specified subdivision projects. For this purpose, water suppliers may rely on an UWMP if the update to the General Plan (including a Housing and Safety Element Update) is accounted for within the UWMP, a WSA or other acceptable information that constitutes “substantial evidence.” “Sufficient water supply” is defined in SB 221 as the total water supplies available during normal, single-dry and multiple-dry water years within the 20-year (or greater) projection period that are available to meet the projected demand associated with the General Plan Update, in addition to existing and planned future uses. WSAs are required for residential projects of more than 500 units or a proposed shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space. Because the proposed project is a plan and not a subdivision project, it does not require affirmative written verification of sufficient water supply.

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California Safe Drinking Water Act
The California Safe Drinking Water Act (SDWA) (Health & Safety Code Section 116270 et seq.; 22 Cal.

Code Regs. Section 64400 et seq.) regulates drinking water more rigorously than the federal law.

Like the Federal SDWA, California requires that primary and secondary maximum contaminant levels be established for pollutants in drinking water; however, some California maximum contaminant levels are more protective of health. The Act also requires the SWRCB to issue domestic water supply permits to public water systems.

Implementation of the federal SDWA is delegated to the State of California. The SWRCB enforces the federal and state SDWAs and regulates more than 7,500 public water systems across the state.

The SWRCB’s Division of Drinking Water oversees the State’s comprehensive Drinking Water Program. The Drinking Water Program is the agency authorized to issue public water systems permits.

Sustainable Groundwater Management Act
In September 2014, the governor signed legislation requiring that California’s critical groundwater resources be sustainably managed by local agencies. The SGMA gives local agencies the power to sustainably manage groundwater and requires groundwater sustainability plans to be developed for medium- and high-priority groundwater basins, as defined by the Department of Water Resources (DWR).

Urban Water Management Planning Act
In 1983, the California Legislature enacted the UWMPA (Water Code, Section 10610 et seq.), which requires urban water suppliers to develop water management plans to actively pursue the efficient use of available supplies. Every five years, water suppliers are required to develop UWMPs to identify short-term and long-term water demand management measures to meet growing water demands.

Porter-Cologne Water Quality Control Act (California Water Code) The State of California is authorized to administer Federal or State laws regulating water pollution within the State. The Porter-Cologne Water Quality Control Act (Water Code Section 13000, et seq.) includes provisions to address requirements of the Clean Water Act. These provisions include National Pollutant Discharge Elimination System (NPDES) permitting, dredge and fill programs, and civil and administrative penalties. The Porter-Cologne Act is broad in scope and addresses issues relating to the conservation, control, and utilization of the water resources of the State.

Additionally, the Porter-Cologne Act states that the quality of all the waters of the State, including groundwater and surface water, must be protected for the use and enjoyment by the people of the State.

In California, the NPDES program is administered by the SWRCB through the RWQCB and requires municipalities to obtain permits that outline programs and activities to control wastewater and stormwater pollution. The federal Clean Water Act prohibits discharges of stormwater from construction projects unless the discharge follows an NPDES permit. The SWRCB is the permitting authority in California and adopted an NPDES General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities, otherwise known as the Construction General Permit (Order 2009-0009, as amended by Orders 2010-0014-DWQ and 2012-006-DWQ). The Order applies to construction sites that include one or more acre of soil disturbance. Construction

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activities include clearing, grading, grubbing, excavation, stockpiling, and reconstruction of existing facilities involving removal or replacement. The Construction General Permit requires that the landowner and/or contractor file permit registration documents prior to commencing construction and then pay a fee annually through the duration of construction. These documents include a notice of intent, risk assessment, site map, stormwater pollution prevention plan (SWPPP), and signed certification statement. The SWPPP must include measures to ensure that: all pollutants and their sources are controlled; non-stormwater discharges are identified and eliminated, controlled, or treated; site Best Management Practices (BMPs) are effective and result in the reduction or elimination of pollutants in stormwater discharges and authorized non-stormwater discharges; and BMPs installed to reduce or eliminate pollutants after construction are completed and maintained.

The Construction General Permit specifies minimum BMP requirements for stormwater control based on the risk level of the site. The Permit also specifies minimum qualifications for a qualified SWPPP developer and qualified SWPPP practitioner.
c. Local Water Regulations
Urban Water Management Plan
The City has adopted a 2020 UWMP, as required by California Water Code (CWC) sections 10610 to 10656 and WSCP (CWC Section 10632 and 10635). The UWMP was created in order to maintain efficient use of urban water supplies, continue to promote conservation programs and policies, ensure that sufficient water supplies are available for future beneficial use, including drought response. The WSCP addresses the City’s water system in a multiple dry year condition, the City will need to enact this WSCP to reduce demands through a variety of conservation efforts as demonstrated in the WSCP.

Clovis Municipal Code
CMC Chapter 6.5, Water System, addresses water connections and extensions, restrictions, water conversation and waste prevention, and water fees.

City of Clovis General Plan
The following goals and policies of the City’s General Plan related to water are applicable to the project.

Public Facilities and Services Element
Goal 1: Reliable and cost-effective infrastructure systems that permit the city to sustainably manage its diverse water resources and needs.

Policy 1.1: New development shall pay its fair share of public facility and infrastructure improvements.

Policy 1.2: Require that new development demonstrate contractual and actual sustainable water supplies adequate for the new development’s demands.

Policy 1.3: Prior to annexation, the city must find that adequate water supply and service and wastewater treatment and disposal capacity can be provided for the proposed annexation.

Existing water supplies must remain with the land and be transferred to the City upon annexation approval.

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Policy 1.4: The City may require developments to install onsite or offsite facilities that are in excess of a development’s fair share. However, the City shall establish a funding mechanism for future development to reimburse the original development for the amount in excess of the fair share costs.

Policy 1.5: Use recycled water to reduce the demands for new water supplies. Support the expansion of recycled water infrastructure throughout Clovis and require new development to install recycled water infrastructure where feasible.

Policy 1.6: Periodically update water, recycled water, wastewater, and stormwater master plans and require all new development to be consistent with the current master plans.

Policy 1.7: Stabilize groundwater levels by requiring that new development water demands not exceed the sustainable groundwater supply.

Policy 1.8: Protect existing and future water, wastewater, and recycled water facilities from encroachment by incompatible land uses that may be allowed through discretionary land use permits or changes in land use or zoning designations.

Open Space and Conservation Element
Goal 3: A built environment that conserves and protects the use and quality of water and energy resources.

Policy 3.3: Prohibit the use of new private wells in new development.

Policy 3.4: Promote water conservation through the use of drought tolerant landscaping on existing and new residential properties. Require drought-tolerant landscaping for all new commercial and industrial development and city-maintained landscaping, unless used for recreation purposes.

Policy 3.5: Encourage new development and substantial rehabilitation projects to exceed energy and water conservation and reduction standards set in the California Building Code. d. Federal Stormwater Regulations
Clean Water Act Section 402
Section 402 of the Clean Water Act requires that all construction sites on an acre or greater of land, as well as municipal, industrial and commercial facilities discharging wastewater or stormwater directly from a point source (e.g., pipe, ditch, or channel) into a surface water of the United States must obtain permission under the NPDES permit. All NPDES permits are written to ensure that the surface water receiving discharges will achieve specified water quality standards.

According to federal regulations, NPDES permit coverage for stormwater discharges associated with construction activity can be obtained through individual State permits or general permits. Individual permitting involves the submittal of specific data on a single construction project to the appropriate permitting agency that will issue a site-specific NPDES permit to a project. NPDES coverage under a general permit involves the submittal of a Notice of Intent by the regulated construction project that they intend to comply with a general permit to be developed by USEPA or a state with delegated permitting authority.

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Cobey-Alquist Floodplain Management Act
The Cobey-Alquist Floodplain Management Act (Water Code Section 8400-8435) gives support to the National Flood Insurance Program 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.
e. State Stormwater Regulations
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 Code of Federal Regulations (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 Protection Plan 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 Stormwater Pollution Protection Plans are designed to minimize erosion during construction, stabilize construction areas, control sediment and pollutants from construction materials, and address post construction runoff. The Stormwater Pollution Protection Plan 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.

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 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.

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f. Local Stormwater Regulations
Clovis General Plan
The following goals and policies of the City of Clovis General Plan related to stormwater are applicable to the project.

Open Space and Conservation Element
Policy 2.2: Encourage new development to incorporate on-site natural resources and low impact development techniques.

Policy 3.1: Encourage the use of low impact development techniques that retain or mimic natural features for stormwater management.

Policy 3.2: Minimize the use of non-point source pollutants and stormwater runoff. g. Federal Wastewater Regulations
Clean Water Act Section 401
Under Section 401 of the Clean Water Act, the RWQCBs have regulatory authority over actions in waters of the United States and/or the State of California through the issuance of water quality certifications, which are issued in conjunction with any federal permit (e.g., permits issued by the USACE under Section 404 of the Clean Water Act, described above). Section 401 of the Clean Water Act provides the SWRCB and the RWQCBs with the regulatory authority to waive, certify, or deny any proposed activity that could result in a discharge to surface waters of the State. To waive or certify an activity, these agencies must find that the proposed discharge would comply with State water quality standards, including those protecting beneficial uses and water quality. If these agencies deny the proposed activity, the federal permit cannot be issued. This water quality certification is generally required for projects requiring Section 404 authorization involving the discharge of dredged or fill material to wetlands or other waters of the United States.

Clean Water Act Section 402
Section 402 of the Clean Water Act requires that all construction sites on an acre or greater of land, as well as municipal, industrial and commercial facilities discharging wastewater or stormwater (as noted above in the stormwater section) directly from a point source, such as a pipe, ditch, or channel, into a surface water of the United States must obtain permission under the NPDES permit.

All NPDES permits are written to ensure that the surface water receiving discharges will achieve specified water quality standards.
h. State Wastewater Regulations
Title 22 of California Code of Regulations
Title 22 regulates the use of reclaimed wastewater. In most cases only disinfected tertiary water may be used on food crops where the recycled water comes into contact with the edible portion of the crop. Disinfected secondary treatment may be used for food crops where the edible portion is produced below ground and will not come into contact with the secondary effluent. Lesser levels of treatment are required for other types of crops, such as orchards, vineyards, and fiber crops.

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The California Department of Public Health sets specific requirements for treated effluent reuse, or recycled water, through Title 22 of the California Code of Regulations (CCR). These requirements are primarily set to protect public health. Title 22 CCR, Division 4, Chapter 3, Sections 60301 through 60355 are used to regulate recycled wastewater and are administered jointly by the California Department of Public Health and the RWQCBs. Title 22 contains effluent requirements for four levels of wastewater treatment, from un-disinfected secondary recycled water to disinfected tertiary recycled water. Higher levels of treatment have higher effluent standards, allowing for a greater number of uses under Title 22, including irrigation of freeway landscaping, pasture for milk animals, parks and playgrounds, and vineyards and orchards for disinfected tertiary recycled water.

California Plumbing Code
The California Plumbing Code is codified in Title 24, CCR, Part 5. The Plumbing Code contains regulations including, but not limited to, plumbing materials, fixtures, water heaters, water supply and distribution, ventilation, and drainage. More specifically, Part 5, Chapter 4, contains provisions requiring the installation of low flow fixtures and toilets. Existing development will also be required to reduce its wastewater generation by retrofitting existing structures with water efficient fixtures (SB 407 [2009] Civil Code Sections 1101.1 et seq.).
i. Local Wastewater Regulations
City of Clovis Municipal Code
Chapter 6.4 of the CMC addresses restrictions, fees, and development related to the public sewer system for the City. CMC Section 6.4.02 stipulates that any building or structure connected to a septic tank or cesspool must be connected to the public sewer system within three years of the sewer becoming available. CMC Section 6.4.03 permits the imposition of charges for sewer connections, including fees to support the construction of sewer mains and house branches extending from the mains to property lines. The specific fee amounts are outlined in the City’s Master Development Fee Schedule.

Clovis General Plan
The following goals and policies of the City of Clovis General Plan related to wastewater are applicable to the project.

Public Facilities and Services Element
Policy 1.1: New development shall pay its fair share of public facility and infrastructure improvements.

Policy 1.3: Prior to annexation, the city must find that adequate water supply and service and wastewater treatment and disposal capacity can be provided for the proposed annexation.

Existing water supplies must remain with the land and be transferred to the City upon annexation approval.

Policy 1.4: The City may require developments to install onsite or offsite facilities that are in excess of a development’s fair share. However, the City shall establish a funding mechanism for future development to reimburse the original development for the amount in excess of the fair share costs

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Policy 1.5: Use recycled water to reduce the demands for new water supplies. Support the expansion of recycled water infrastructure throughout Clovis and require new development to install recycled water infrastructure where feasible.

Policy 1.6: Periodically update water, recycled water, wastewater, and stormwater master plans and require all new development to be consistent with the current master plans.

Land Use Element
Policy 4.3: The City shall monitor development and plan for additional environmental clearance as development levels approach those evaluated in the General Plan EIR. j. Federal Solid Waste Regulations
Title 40 of the Code of Federal Regulations
Title 40 of the CFR, Part 258 (Resource Conservation and Recovery Act RCRA, Subtitle D) contains regulations for municipal solid waste landfills and requires states to implement their own permitting programs incorporating the federal landfill criteria. The federal regulations address the location, operation, design, groundwater monitoring, and closure of landfills. k. State Solid Waste Regulations
California Department of Resources Recycling and Recovery California Department of Resources Recycling and Recovery (CalRecycle) oversees, manages, and monitors waste generated in California. CalRecycle provides limited grants and loans to help California cities, counties, businesses, and organizations meet the State waste reduction, reuse, and recycling goals. It also provides funds to clean up solid waste disposal sites and co-disposal sites, including facilities that accept hazardous waste substances and non-hazardous waste. CalRecycle develops, manages, and enforces waste disposal and recycling regulations, including AB 939 and SB 1016, both of which are described below.

Assembly Bill 939
Assembly Bill (AB) 939 (Public Resources Code 41780) requires cities and counties to prepare integrated waste management plans and to divert 50 percent of solid waste from landfills beginning in calendar year 2000 and each year thereafter. AB 939 also requires cities and counties to prepare Source Reduction and Recycling Elements as part of the integrated waste management plans. These elements are designed to develop recycling services to achieve diversion goals, stimulate local recycling in manufacturing and stimulate the purchase of recycled products.

Senate Bill 1016
SB 1016 requires that the 50 percent solid waste diversion requirement established by AB 939 be expressed in pounds per person per day. SB 1016 changed the CalRecycle review process for each municipality’s integrated waste management plan. CalRecycle reviews a jurisdiction’s source reduction and recycling element and hazardous waste element once every two years.

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Assembly Bill 1826
In October 2014 Governor Brown signed AB 1826, requiring businesses to recycle their organic waste on and after April 1, 2016, depending on the amount of waste they generate per week. This law also requires that on and after January 1, 2016, local jurisdictions across the state implement an organic waste recycling program to divert organic waste generated by businesses, including multifamily residential dwellings that consist of five or more units (although multifamily dwellings are not required to have a food waste diversion program). Organic waste means food waste, green waste, landscape and pruning waste, nonhazardous wood waste, and food-soiled paper waste that is mixed in with food waste. This law phases in the mandatory recycling of commercial organics over time, while also offering an exemption process for rural counties. In particular, the minimum threshold of organic waste generation by businesses decreases over time, which means an increasingly greater proportion of the commercial sector will be required to comply.

California’s Short-Lived Climate Pollutant Reduction Strategy (SB 1383) Signed into law in September 2016, SB 1383 establishes methane emissions reduction targets for California in a statewide effort to reduce emissions of short-lived climate pollutants. The targets are to reduce organic waste disposal 50 percent by 2020 and 75 percent by 2025. The law also grants CalRecycle the regulatory authority required to achieve the organic waste disposal reduction targets and establishes an additional target that not less than 20 percent of currently disposed edible food is recovered for human consumption by 2025. Enforcement of these targets began January 1, 2022. l. Local Solid Waste Regulations
Countywide Integrated Waste Management Plan
The Countywide Integrated Waste Management Plan (WMP) is mandated by state law under AB 939. The Countywide Integrated WMP outlines the waste management infrastructure for Fresno County and its incorporated cities, including Clovis, Coalinga, Firebaugh, Fowler, Fresno, Huron, Kerman, Kingsburg, Mendota, Orange Cove, Parlier, Reedley, San Joaquin, Sanger, and Selma. The plan details countywide infrastructure and administrative processes, summarizes current solid waste management practices, and provides an overview of key elements such as Source Reduction and Recycling, Household Hazardous Waste, and Non-disposal Facilities. It also includes financing information for implementing the Countywide WMP.

City of Clovis Municipal Code
Chapter 6.3, Garbage and Rubbish, of the CMC establishes comprehensive standards for solid waste management and recycling. The CMC outlines regulations governing solid waste collection, residential green waste recycling, landfill liner development fees, and related provisions for waste disposal. Chapter 6.3.1, Recycling and Diversion of Construction and Demolition Debris, specifies requirements for diverting construction and demolition materials from landfills, including diversion thresholds, waste management plans, and reporting obligations. Additionally, Section 9.24.110 prescribes design and construction standards for solid waste and recyclable material storage areas in development projects. Section 9.40.160 introduces developmental and operational standards for recycling facilities, including collection and processing facilities.

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Clovis General Plan
The following are relevant policies of the Clovis 2014 General Plan that are related to solid waste regulation in Clovis.

Public Facilities and Services Element
Policy 2.1: Promote solid waste source reduction, reuse, and recycling; composting; and the environmentally-safe transformation of wastes.

Policy 2.2: Meet the state’s current and future waste diversion goals through the city’s recycling and diversion programs.

Policy 2.3: Increase recycling by commercial, industrial, and multifamily generators.

Policy 2.4: Encourage citywide participation in green waste reduction and household hazardous waste disposal programs.

Policy 2.5: Maintain at least 15 years of ongoing landfill capacity.

Policy 2.6: Protect existing or planned solid waste facilities from encroachment by incompatible land uses that may be allowed through discretionary land use permits or changes in land use or zoning designations
m. Federal and State Telecommunication Regulations
The California Public Utilities Commission (CPUC) develops and implements policies for the telecommunication industry. The Communications Division is responsible for licensing, registration and the processing tariffs of local exchange carriers, competitive local carriers, and non-dominant interexchange carriers. It is also responsible for registration of wireless service providers and franchising of video service providers. The Division tracks compliance with commission decisions and monitors consumer protection and service issues and Commission reliability standards for safe and adequate service. The Communications Division is responsible for oversight and implementation of the six public purpose Universal Service Programs. 15 4.15.3 Impact Analysis
a. Methodology and Significance Thresholds
Methodology
The analysis in this section focuses on impacts related to water supplies, wastewater, solid waste, and storm water conveyance, as well as electric power, natural gas, or telecommunications facilities.

Electric power and natural gas is discussed in greater detail in Section 4.5, Energy.

Significance Thresholds
The following thresholds are based on CEQA Guidelines Appendix G. For purposes of this EA, impacts related to water supplies, wastewater, solid waste, storm water conveyance, electric power, natural gas or telecommunications facilities are considered significant if implementation of the proposed project would:
15 Universal Service. CPUC. Accessed October 2025: https://www.cpuc.ca.gov/-/media/cpuc-website/aboutcpuc/documents/transparency-and-reporting/fact_sheets/universal_service_v_031723.pdf

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Require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects; Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years; Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the projects’ projected demand in addition to the provider’s existing commitments;
Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals; or Comply with federal, state, and local management and reduction statutes and regulations related to solid waste.
b. Project Impacts and Mitigation Measures
Threshold 1: Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Impact UTIL-1 DEVELOPMENT FACILITATED BY THE PROJECT MAY REQUIRE THE RELOCATION OR

CONSTRUCTION OF NEW OR EXPANDED WATER, WASTEWATER TREATMENT, STORMWATER DRAINAGE, ELECTRIC POWER, NATURAL GAS, AND TELECOMMUNICATIONS FACILITIES IN CLOVIS. WHILE NEW CONNECTIONS TO

EXISTING UTILITY SERVICE SYSTEMS WOULD BE REQUIRED, SUCH CONNECTIONS WOULD NOT RESULT IN DISTURBANCE BEYOND INDIVIDUAL DEVELOPMENT SITES AND ADJACENT INFRASTRUCTURE CORRIDORS.

IMPACTS WOULD BE LESS THAN SIGNIFICANT.

The City’s 2014 General Plan EIR evaluates impacts to utilities and service systems resulting from a 2035 population growth scenario and a complete buildout scenario. The 2035 scenario refers to a population increase to 188,224 persons which is higher than the maximum planned population increase of the project to 133,761 residents. The General Plan EIR found the following conclusions regarding impacts to utilities and service systems in the 2035 population growth scenario, separated by utility type including, water, wastewater, storm drainage, solid waste, and all other utilities.

The project would not in and of itself involve any development or significant change to utilities. As discussed in Section 4.11, Population and Housing, 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 analyzed under the 2014 General Plan EIR.16 The potential additional 4,640 residents that could result from future housing development from in the Infill Rezone Program would only make up 1.6 percent of the overall buildout capacity. This increase would not trigger the need for new utilities or service systems beyond what is currently planned. 16 City of Clovis. 2014. 2014 General Plan Update EIR. Accessible at:
https://www.clovisca.gov/services/planning_development/planning/general_plan/environmental_impact_report.php

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Water
The 2014 General Plan EIR found that development could have potentially significant impacts on the ability for the City to have sufficient water supplies. 17 However, in 2020, the City updated its UWMP
in accordance with the UWMPA. The purpose of the UWMP is to maintain efficient use of urban water supplies, continue to promote conservation programs and policies, ensure that sufficient water supplies are available for future beneficial use, and provide a mechanism for response during water drought conditions. The UWMP stated that the City is expected to grow by a population of approximately two percent each year, projected to reach a population of approximately 150,000 by the year 2030. This projection is higher than the anticipated maximum population increase to 133,761 residents that could result from increased housing development following the project.

A Water Service Analysis (WSA) was conducted and included as Appendix E of this EA. For Multifamily Residential, the Infill Rezone Program, if developed to maximum buildout would account for 9.6 percent of the total demand in 2030. A summary of the water demand as a result of the project is shown in Table 4.15-4 below.

Table 4.15-4 Planned Water Demand with Infill Rezone Program Use Type UWMP 2030 Projection (AF) Project Demands (AF) Percent of UWMP MFR Demand Multi-Family 2,715 259 9.6
Total 2,715 259 9.6
The WSA details that the City’s adherence to their planning documents and consistent development of these water supplies and infrastructure is critical for the City’s continued growth and development and will provide operational reliability into the future. The WSA concludes that if demand is as projected, the City will have sufficient water to meet dry year demands of all dry year event types. Therefore, impacts to water supplies would be less than significant.

Wastewater
Planned expansions of wastewater treatment facilities, as described in the City’s Wastewater Master Plan (for up to 20.7 mgd), would be sufficient to meet the wastewater generation by its 2035 Scenario (19.7 mgd).
18 The Infill Rezone Program would not cause a population increase substantially greater than projected in the 2035 population growth scenario but would place additional usage on existing facilities. Using the conservative estimate of 95 gallons per day for multi-family residential, there would be an additional need for 440,800 gallons per day for the units planned for as a result of the judgment. This would require 20.14 mgd capacity which is below the projected capacity with planned expansions. The change in wastewater demand from the population increase facilitated by the Infill Rezone Program potential future development would not exceed the capacity of the proposed infrastructure. Therefore, impacts to wastewater would be less than significant.

Storm Drainage
The FMFCD service consists of a system of more than 700 miles of pipeline and more than 150 stormwater retention basins. New drainage areas are required when a city expands their SOI. Any 17 City of Clovis. 2014. City of Clovis General Plan EIR. Accessible at:
https://www.clovisca.gov/services/planning_development/planning/general_plan/environmental_impact_report.php 18 City of Clovis. 2014. City of Clovis General Plan EIR. Accessible at:
https://www.clovisca.gov/services/planning_development/planning/general_plan/environmental_impact_report.php

Environmental Impact Analysis
Utilities and Service Systems
Environmental Assessment 4.15-21
future project facilitated by the Infill Rezone Program would be within the current City boundary and be subject to meeting current stormwater requirements. Therefore, impacts to storm drainage would be less than significant.

Other Utilities
Other utilities including electricity, natural gas, telephone, and cable would have a less than significant impact in a 2035 scenario as existing and/or proposed facilities would be able to accommodate project-generated utility demands.
19 For all future housing development projects, developers would be responsible for funding infrastructure improvements that are required to mitigate development impacts and have not been previously identified as part of a capital improvement program covered by development impact fees. Consistent with applicable State law, the City’s development fees will ensure that the developers pay the cost attributable to the increased demand for the affected public facilities reasonably related to the development project in order to refurbish the existing facilities to maintain the existing level of service and achieve an adopted level of service that is consistent with the City’s General Plan (California Government Code Section 66001(g)). All future housing developments would require specific, project-level assessment. Therefore, with implementation of regulations, General Plan policies, and mitigation measures listed in the General Plan EIR, impacts to utilities and service systems would be less than significant.

Mitigation Measures
No mitigation measures are required.

Threshold 2: Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
Impact UTIL-2 DEVELOPMENT FACILITATED BY THE INFILL REZONE PROGRAM WOULD PLACE INCREASED DEMAND ON WATER SUPPLY IN NORMAL AND DROUGHT YEARS. WHILE PROJECTIONS CONSIDERED IN THE

UWMP ARE SLIGHTLY LESS THAN THOSE AFFORDED BY IMPLEMENTATION OF THE INFILL REZONE PROGRAM,

SUFFICIENT WATER SUPPLY EXISTS TO SERVE THE POPULATION DUE TO CONSERVATION EFFORTS DURING MULTIPLE DRY YEARS. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

The City’s 2014 General Plan EIR evaluates impacts to Utilities and Service Systems resulting from a 2035 population growth scenario and a complete buildout scenario. The 2035 scenario refers to a population increase to 188,224 persons which is higher than the maximum planned population increase of the project to 133,761 residents. The 2020 UMWP projected potable water demand of 65,034 AFY, lower than the General Plan EIRs anticipated demand of 71,798 AFY.

The 2020 UWMP has estimated and shown that it will be able to meet a 2035 demand of 65,034 AFY. The City would have adequate water supply to meet the demand caused by population growth as a result of the Infill Rezone Program. However, future drought and the critically overdrafted status of the Kings Sub-basin creates uncertainty whether the City would be able to secure water supplies greater than those currently forecast for 2035 Buildout Scenario. The City has prepared the 19 City of Clovis. 2014. City of Clovis General Plan EIR. Accessible at:
https://www.clovisca.gov/services/planning_development/planning/general_plan/environmental_impact_report.php

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Infill Rezone Program

4.15-22
WSCP to address urban water shortage contingencies, pursuant to state law, to promote drought resiliency, even in multiple dry-year scenarios.20
The WSCP found that there are sufficient water supplies available to serve the reasonably foreseeable future housing development during normal, dry and multiple dry years with WSCP actions.
21 The prepared WSA analyzed the Infill Rezone Program project against the UWMP and WSCP and concluded that if demand is as projected, the City will have sufficient water to meet dry year demands of all dry year event types. Therefore, impacts to water supplies during drought conditions would be less than significant.

Mitigation Measures
No mitigation measures are required.

Threshold 3: Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? Impact UTIL-3 DEVELOPMENT FACILITATED THE INFILL REZONE PROGRAM WOULD NOT REQUIRE THE RELOCATION OR CONSTRUCTION OF NEW OR EXPANDED WASTEWATER TREATMENT FACILITIES IN CLOVIS.

IMPACTS WOULD BE LESS THAN SIGNIFICANT.

By an agreement with the City of Fresno, the City is entitled to 9.3 mgd of wastewater treatment capacity at the RWRF. The City may also acquire additional capacity at the RWRF, if required.

Planned expansions of wastewater treatment facilities of the Clovis Water Reuse Facility, as described in the City’s Wastewater Master Plan (for up to 20.7 mgd), would itself be sufficient to meet the wastewater generation by its 2035 Scenario (19.7 mgd).22 Using the same conservative estimate of 95 gallons per day for multi-family residential as the 2014 General Plan EIR, there would be an additional need for 440,800 gallons per day for the units planned for as a result of the Judgment. This would require 20.14 mgd capacity which is below the projected capacity with planned expansions.

The Infill Rezone Program would not cause a population increase substantially greater than projected in the 2035 population growth scenario but would place additional usage on existing facilities. The change in wastewater demand from the population increase facilitated by the Infill Rezone Program would not exceed the capacity of the proposed infrastructure. Therefore, impacts to wastewater would be less than significant.

Mitigation Measures
No mitigation measures are required.
20 City of Clovis. Water Supply Contingency Plan. 2020. Accessible at:
https://cms2.revize.com/revize/clovis/documents/Services/Public%20Utilities/Water/2020-WSCP-Adopted-July2021_reduced.pdf?t=202507181312520&t=20250718131252 22 City of Clovis. 2014. City of Clovis General Plan EIR. Accessible at:
https://www.clovisca.gov/services/planning_development/planning/general_plan/environmental_impact_report.php

Environmental Impact Analysis
Utilities and Service Systems
Environmental Assessment 4.15-23
Threshold 4: Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
Threshold 5: Would the project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
Impact UTIL-4 DEVELOPMENT FACILITATED BY THE INFILL REZONE PROGRAM WOULD NOT GENERATE

SOLID WASTE IN EXCESS OF STATE OR LOCAL STANDARDS, OR IN EXCESS OF THE CAPACITY OF LOCAL INFRASTRUCTURE. THE PROJECT WOULD NOT IMPAIR THE ATTAINMENT OF SOLID WASTE REDUCTION GOALS AND WOULD COMPLY WITH FEDERAL, STATE, AND LOCAL STATUTES AND REGULATIONS RELATED TO SOLID WASTE.

IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Three existing facilities could accommodate project-generated solid waste for the 2035 buildout scenario analyzed under the 2024 General Plan EIR and the City’s landfill would be able to accommodate at least an additional two decades of solid waste generation after two of the three landfills reach end of life in 2031. The 2014 General Plan policies related to solid waste would help the City meet the state mandated diversion goals in the Integrated Waste Management Act by minimizing the amount of solid waste generated by residents and businesses. Additionally, solid waste disposal within the City limits would continue to be subject to the provisions of the CMC Chapters 6.3 and 6.3.1 and Section 9.24.110.

Additionally, development would be required to comply with General Plan policies which reduce or mitigate impacts on utilities and utility expansion. The solid waste disposal increase as a result of development facilitated by the Infill Rezone Program would have a less than significant impact for local solid waste infrastructure.

Finally, future development as a result of the Infill Rezone Program could lead to the generation of additional solid waste, but not in excess of infrastructure capacity or federal, state, and local standards and reduction goals due to the small increase in population spread across the City.

Mitigation Measures
No mitigation measures are required.

4.15.4 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].).

Water
The analysis provided under Impact UTL-2 and UTIL-3 is cumulative in nature and considers water demand associated with development within the City’s PUD service area. Cumulative development within Clovis will continue to increase demands on water supplies. There would be sufficient existing water supplies to accommodate anticipated cumulative development and achieve full buildout of the housing opportunity sites for other nearby cities under normal and dry year conditions by relying on the estimated surplus and implementation of ongoing conservation measures. Therefore, the proposed project would not have a cumulatively considerable contribution to a significant cumulative impact regarding water supply services.

4.15-24

City of Clovis
Infill Rezone Program
Wastewater
As discussed above under Impact UTIL-1, new wastewater service connections would be installed as needed, on a project-specific basis; this would occur for non-residential developments within the cumulative scenario as it would for residential developments under the proposed project.

Solid Waste
The three existing solid waste facilities could accommodate generated solid waste for the 2035 population growth scenario under the 2014 General Plan growth assumptions. The City of Clovis Landfill would be able to accommodate at least an additional two decades of solid waste generation after two of the three landfills the City uses reach end of life in 2031. Therefore, the proposed project would not have a considerable cumulative impact on solid waste.

Electricity and Natural Gas
The geographic scope for cumulative electricity and natural gas impacts is the PG&E service area of central and northern California. This geographic scope is appropriate because the local providers are responsible for transmitting electricity and natural gas to all land uses within their service areas, including those that would occur on the housing opportunity sites. Development considered part of the cumulative analysis includes buildout of local General Plans.

PG&E is subject to the requirements set forth and/or enforced by the CPUC. The need for electric and natural gas infrastructure would be addressed on a case-by-case basis for each cumulative project, and would be subject to CPUC requirements, similar to those applicable to the proposed project. Therefore, cumulative impacts related to electric power and natural gas transmission facilities would be less than significant. Therefore, the proposed project would not have a cumulatively considerable contribution to a cumulative impact regarding electricity and natural gas.

Telecommunication
The geographic scope for cumulative telecommunications impacts is the telecommunication provider service area. This geographic scope is appropriate because local providers are responsible to provide adequate telecommunication infrastructure to all land uses within its service area, including the housing opportunity sites.

As discussed above under Impact UTIL-1, project implementation requires connections to existing utility infrastructure to meet the needs of site residents and tenants. Cumulative development in the City would increase demand for telecommunications infrastructure. All future development would be required to provide adequate telecommunications infrastructure on a project-by-project basis and would be subject to the same requirements as development projects on the Infill Rezone Program sites. Therefore, cumulative impacts related to telecommunications infrastructure would be less than significant.

Mitigation Measures
No mitigation measures are required.

Environmental Impact Analysis
Effects Found Not to be Significant
Environmental Assessment 4.16-1

4.16 Effects Found Not to be Significant
California Environmental Quality Act (CEQA) Guidelines Section 15128 requires the Environmental Assessment (EA) to briefly describe any possible effects that were determined not to be significant and were therefore not discussed in detail in the EA. This section includes the checklist questions listed in Appendix G of the CEQA Guidelines and a brief discussion of environmental impacts that were determined to have no impact on the included resources.

4.16.1 Agricultural and Forestry Resources
Would the project:
a. Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? b. Conflict with existing zoning for agricultural use, or a Williamson Act contract? c. Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))? d. Result in the loss of forest land or conversion of forest land to non-forest use? e. Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to nonforest use? The City of Clovis is a highly urbanized city, and farmland maps prepared by the California Department of Conservation (CDOC) show that the 20 Infill Rezone Program sites do not contain any Prime Farmland, Unique Farmland, or Farmland of Statewide Importance.1 The Infill Rezone sites are categorized as Farmland of Local Importance, Rural Residential Land of Urban and Built-up Land.

Pursuant to Action Item 4 of the court judgment, the project will amend the land use designation of 20 proposed Infill Rezone Program sites to High or Very High Density Residential and rezone them to the R-3 or R-4 zone districts to support affordable housing units within the city. Since the proposed housing developments would be located on parcels designated for residential use, the project would not impact agricultural or forestry resources. Additionally, the updated Housing Element policies would not affect agricultural lands or forestry areas. The project would not lead to the conversion of farmland to non-agricultural uses, nor would it conflict with existing agricultural zoning or Williamson Act contracts. Furthermore, it would not result in the conversion of forestland, timberland, or timber production zones. Therefore, the project would have no impact on agricultural or forestry resources.
1 California Department of Conservation. 2025. California Important Farmland Finder. Available:
https://maps.conservation.ca.gov/dlrp/ciff/app/#data_s=id%3Awidget_647_output_config_default_geocode_0_0%3A0. Accessed June 2025.

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Infill Rezone Program

4.16-2

4.16.2 Geology and Soils
Would the project:
a. Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
 Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault?
 Strong seismic ground shaking?
 Seismic-related ground failure, including liquefaction?  Landslides?
b. Result in substantial soil erosion or the loss of topsoil? c. Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
d. Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? e. Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater? f. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
The city of Clovis is not located in an Alquist-Priolo Fault Zone and there are no active faults present in the City of Clovis.2 Areas of the San Joaquin Valley in Fresno County are not considered conducive to liquefaction due to soil types that are either too coarse or too high in clay content.3 The topography of the 20 Infill Rezone Program sites is also flat and does not exhibit an elevation that would be conducive to landslide activity.

Although no physical development is included as part of the project, the rezoning of the 20 sites would facilitate development at greater densities. The sites are located on infill properties that are either undeveloped or have existing development with limited structures. The project does not propose development that would involve construction or grading activities in and of itself, and would therefore not result in soil erosion or loss of topsoil. As the topography of the sites are relatively flat and in areas of the city surrounded by existing development, any future development facilitated by the project would not result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse. Nor would any future project require the use of septic or alternative wastewater disposal systems. Therefore, there would be no impact to geology and soils. 2 City of Clovis. Clovis General Plan EIR. Accessed June 2025: https://cityofclovis.com/planning-and-development/planning/masterplans/general-plan/environmental-impact-report/ 3 Ibid.

Environmental Impact Analysis
Effects Found Not to be Significant
Environmental Assessment 4.16-3

4.16.3 Mineral Resources
Would the project:
a. Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
b. Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? The California Geological Survey Mineral Resources Program classifies Mineral Resource Zones (MRZs), or production and consumption lands with identified nonfuel mineral resources (i.e. limestone, gold, silver, copper, sand, gravel, and stone).4 The City of Clovis is mapped as MRZ-3 by the California Geological Survey, which means the significance of mineral deposits cannot be determined from available data.5 There are no actively used mineral resources or mining operations within the City of Clovis. There are no mineral resource sectors identified in or near any of the 20 Infill Rezone Program sites. The nearest resource sector is Sector S-11b, 1.1 miles northwest of city limits near the San Joaquin River.
6 Therefore, the project would not interfere with mining operations or the loss of availability of known mineral resources, therefore there would be no impact to mineral resources.

4.16.4 Wildfire
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a. Substantially impair an adopted emergency response plan or emergency evacuation plan? b. Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
c. Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? d. Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? There are no Very High Fire Hazard Severity Zones (VHFHZS) within or near the city limits of Clovis. 7 The nearest VHFHSZ is located approximately 50 miles southeast of Clovis. County emergency response plans are updated regularly and would reflect the most recent population estimates and growth projections. Implementation of the project would not substantially impair adopted emergency response or emergency evacuation plans as the proposed Infill Rezone Program sites would be accessed by existing roadways and would not impair the use of emergency evacuation 4 Mineral Resources Program. Accessed May 2025:
https://www.conservation.ca.gov/cgs/minerals/program#:~:text=The%20CGS%20Mineral%20Resources%20Program,mining%20activities %20throughout%20the%20state.
5 California Division of Mines and Geology. 1999, April 1. Open File Report 99-02: Update of Mineral Land Classification: Aggregate Materials in the Fresno Production-Consumption Region, California 6 California Division of Mines and Geology. 1999, April 1. Open File Report 99-02: Update of Mineral Land Classification: Aggregate Materials in the Fresno Production-Consumption Region, California 7 California Department of Forestry & Fire Protection (CALFIRE). 2025. Fire Hazard Severity Zones. Available:
https://experience.arcgis.com/experience/5065c998b4b0462f9ec3c6c226c610a9. Accessed June 2025.

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Infill Rezone Program

4.16-4
routes through the modification of roadways. Therefore, there would be no impact related to wildfire.

Development facilitated by the project would be constructed in accordance with federal, state, regional, and local requirements, which are intended to ensure the safety of residents and structures to the extent feasible. Compliance with these standard regulations would be consistent with the Clovis General Plan Public Facilities and Services Element, Fresno County Local Hazard Mitigation Plan, and the Fresno County Office of Emergency Services.

Future development from the project would be developed in areas of the city zoned for residential development that are not located in a VHFHZS. Development in the city would be required to conform with the latest fire code, including provisions for emergency access. The increase in population associated with the project would not result in significant impacts to evacuation routes or plans in the event of a wildfire, and proposed policies in the Environmental Safety Element and the Public Facilities and Services Element would increase coordination between safety and law enforcement agencies in the event of an emergency.

Additionally, the project would not impair emergency response or evacuation plans and would not involve the installation of infrastructure that may exacerbate fire risk or expose people or structures to significant risks associated with wildfire hazards. Accordingly, there would be no potential impacts.

Other CEQA Required Discussions
Environmental Assessment 5-1
5 Other CEQA Required Discussions
This section discusses the potential growth-inducing impacts and irreversible environmental impacts associated with the implementation of the proposed project.

5.1 Growth Inducement
Section 15126(d) of the California Environmental Quality Act (CEQA) Guidelines requires a discussion of a proposed project’s potential to foster economic or population growth, including ways in which a project could remove an obstacle to growth. Growth does not necessarily create significant physical changes to the environment. However, depending upon the type, magnitude, and location of growth, it can result in significant adverse environmental effects. The proposed project’s growth inducing potential is therefore considered significant if project-induced growth could result in significant physical effects in one or more environmental issue areas.

5.1.1 Population Growth
As discussed in Section 4.11, Population and Housing, while development facilitated by the proposed project would directly generate population growth, the City of Clovis (City) and the State of California have established the need for additional housing in Clovis. The proposed project would fulfill the requirements of the court judgment of facilitating the development of at least 1,284 housing dwelling units. To meet the objectives of the Regional Housing Needs Allocation (RHNA) carryover of the 4th cycle Housing Element and provide sufficient capacity for housing development, the proposed project specifies Infill Rezone Program sites for residential development and identifies implementation programs and zoning policies to encourage additional housing. Therefore, the proposed project would align with the City’s RHNA determination and the State statutory requirements, which are established based on anticipated and desired growth within the city.

Overall, full buildout under the proposed project could facilitate an estimated population growth of approximately 1,303 residential units (up to 1,651 in the maximum potential buildout) and an additional 3,622 residents (up to 4,640 residents) compared to the 2014 Program Environmental Impact Report (PEIR) cumulative assumptions for growth forecasted in the 2014 City’s General Plan and Development Code Update. Growth anticipated under the proposed project is intended to meet regional housing needs over the long term, as it includes State-mandated housing goals. The proposed project would be consistent with State requirements for the RHNA. The State requires that all local governments adequately plan to meet the housing needs of their communities. Given that the State is in an ongoing and protracted housing crisis due to an insufficient housing supply, the additional units under the proposed project would further assist in addressing the existing crisis and meeting the housing needs of the City without exceeding planned population growth in the City.

5.1.2 Economic Growth
Development facilitated by the project would generate temporary employment opportunities during construction. Because construction workers would be expected to be from the existing regional work force, project construction would not be growth-inducing from an employment

City of Clovis
Infill Rezone Program
5-2
standpoint. The proposed project would not induce substantial economic expansion to the extent that direct physical environmental effects would result.

5.1.3 Removal of Obstacles to Growth
As discussed in Chapter 2, Project Description, the identified sites are to be rezoned for multifamily housing. The Infill Rezone Program sites are located within city limits and can be served by existing infrastructure. As discussed in Section 4.13, Transportation, and Section 4.15, Utilities and Service Systems of this EA, existing infrastructure would be adequate to serve development facilitated by the Infill Rezone Program. No new water, sewer, or other utility infrastructure would be required, and no new roads would be required. Because the project would facilitate development on undeveloped, underdeveloped and underutilized lots within urbanized areas, project implementation would not remove obstacles for growth.

5.2 Irreversible Environmental Effects
CEQA Guidelines Section 15126.2(c) requires a discussion of significant irreversible environmental changes. This section addresses non-renewable resources, the commitment of future generations to the proposed uses, and irreversible impacts associated with the proposed project.

The project would facilitate infill residential development on undeveloped and underdeveloped sites in the City. Construction and operation of development facilitated by the project would involve an irreversible commitment of construction materials and non-renewable energy resources.

Development would involve the use of building materials and energy, some of which are nonrenewable resources, to construct new residential buildings and associated infrastructure and landscaping. Consumption of these resources would occur with any development in the region and are not unique to the proposed project.

Operation of development facilitated by the project would also irreversibly increase local demand for non-renewable energy resources such as petroleum products and natural gas. However, increasingly efficient building design would offset this demand to some degree by reducing energy demands of the project. As described in Section 4.5, Energy, development facilitated by the project would be subject to the energy conservation requirements of the California Energy Code (Title 24, Part 6, of the California Code of Regulations, California’s Energy Efficiency Standards for Residential and Nonresidential Buildings) and the California Green Building Standards Code (Title 24, Part 11 of the California Code of Regulations). The California Energy Code provides energy conservation standards for all new and renovated residential buildings, and the Green Building Standards Code requires solar access, natural ventilation, and stormwater capture. Consequently, development facilitated by the project would not use unusual amounts of energy or construction materials.

Therefore, impacts related to consumption of non-renewable and renewable resources would be less than significant. Consumption of these resources would occur with any development in the region and is not unique to the proposed project.

5.3 Mandatory Findings of Significance
Following each environmental impact discussion in Chapter 4, Environmental Impact Analysis, is a list of mitigation measures (if required) and the residual effects or level of significance remaining after implementation of the measure(s). In cases where the mitigation measure could cause a significant environmental impact in another issue area, this impact is discussed and evaluated as a

Other CEQA Required Discussions
Environmental Assessment 5-3
secondary impact. The impact analysis concludes with a discussion of cumulative effects, which evaluates the impacts associated with the project in conjunction with the build-out of the City General Plan.

CEQA Guidelines Section 15065 also requires the following specific Mandatory Findings of Significance be addressed as part of the environmental review for the project:
 The potential for the project to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory;  Project impacts are individually limited, but cumulatively considerable. (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects); and
 Environmental effects of the project which will cause substantial adverse effects on human beings, either directly or indirectly.

Besides air quality, noise, cultural resources, greenhouse gas emissions, public services, and transportation, the impact areas addressed by this Mandatory Findings of Significance section would be less than significant. Potential adverse environmental effects to human beings are discussed in Section 4.2, Air Quality, Section 4.4, Cultural Resources, Section 4.6, Greenhouse Gas Emissions, Section 4.10, Noise, and Section 4.13, Transportation. Furthermore, as discussed above, each environmental analysis section of the EA concludes with a discussion of the project’s contribution to cumulative effects.

The Executive Summary of this EA summarizes all impacts and mitigation measures that apply to the project.

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Alternatives
Environmental Assessment 6-1
6 Alternatives
As required by the California Environmental Quality Act (CEQA) Guidelines Section 15126.6, this chapter examines a range of reasonable alternatives to the proposed project that would attain most of the basic project objectives but would avoid or substantially lessen the significant adverse impacts.

As discussed in Chapter 2, Project Description, the project objectives are as follows:
 Ensure compliance with the Judgment issued by the Fresno County Superior Court on March 19, 2024, in the Martinez v. City of Clovis case, by implementing Action Item 4: Infill Rezone Program.
 Provide capacity to meet the State-required Regional Housing Needs Allocation (RHNA) carryover for lower income households related to the 4th and 5th Cycle Housing Element.  Ensure that housing development that is affordable to lower income households is achievable, through associated amendments to the Zoning Map of the Development Code.  Disperse housing sites throughout the City of Clovis (City) to ensure that no single neighborhood or area is overburdened or impacted.
 Encourage the development of additional housing and increase the overall availability of affordable housing by ensuring that development can occur at adequate densities by amending the Land Use Element of the General Plan.

This chapter analyses three alternatives including the required “no project” alternative that involves changes to the project that may reduce the project-related environmental impacts identified in this EA. Considering these alternatives provides a reasonable range of options to aid decision makers and the public in understanding the general implications of revising or eliminating certain components of the Infill Rezone Program.

The following alternatives are evaluated in this EA:

Alternative 1: No Project
Alternative 2: Alternative Candidate Sites
Alternative 3: Reduced Number of Rezone Sites at Higher Densities Table 6-1 below, provides a summary comparison of the proposed project and each of the alternatives considered. Detailed descriptions of the alternatives and the potential environmental impacts of each alternative are included in the impact analysis sections below. Impacts to be found not significant by the proposed project are found in Section 4.16, Effects Found Not to be Significant.

Chapter 4, Environmental Impact Analysis is comprised of analysis of environmental impact on each identified resource in greater detail.

City of Clovis
Infill Rezone Program
6-2
Table 6-1 Comparison of Project Alternatives’ Buildout Characteristics Proposed Project Alternative 1 Alternative 2 Alternative 3 Total maximum housing units 1,651* 95 1,284 1,284
Change in total maximum dwelling units
compared to project
N/A -1,556 -367 -367
Total additional residents (2.81/unit)** 4,640 267 3,608 3,608 Percent change in total population potential
over General Plan EIR total buildout scenario
(294,000 residents)

1.6 0.09 1.2 1.2
*The project is proposing an assumed density of 1,303 units; however, 1,651 is the maximum potential buildout of the sites under the new zoning designations.
**2.81 residents per housing unit estimate is used by the California Department of Finances Population Estimates for Fresno County.

6.1 Alternative 1: No Project Alternative
The CEQA Guidelines (Section 15126.6[e][2]) require that the alternatives discussion include an analysis of a No Project Alternative. Pursuant to CEQA and as required for the EA, the No Project Alternative refers to the analysis of existing conditions and what would reasonably be expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services. The No Project Alternative typically would proceed along one of two lines: (1) when a project is a revision of an existing regulatory plan or policy, the No Project Alternative will be continuation of the existing plan or policy; or (2) if a project is a development project on identifiable property, the No Project Alternative is the circumstance under which the project does not proceed. In this case, the No Project Alternative represents the continuation of existing zoning and General Plan land use designations on the Infill Rezone Program sites, and assumed full buildout under those existing designations. The analysis of this alternative assumes compliance with applicable City-required development regulations and typical development measures.

6.1.1 Description
The No Project Alternative assumes there is no change in zoning or General Plan land use designations for the 20 Infill Rezone Program sites. The future full buildout of the Infill Rezone Program sites would be controlled by the existing zoning and General Plan land use designations.

This assumption assumes that infill residential development might still occur, where allowed, but would fall short of the required 1,284 units.

6.1.2 Impact Analysis
Buildout of the 20 Infill Rezone Program sites under existing zoning would allow for a maximum potential buildout of 95 housing units, or an additional 267 residents, as shown in Table 6-2. This alternative would still allow for additional housing units within the City, approximately 95 units under existing zoning. However, it would not accomplish the objectives identified for the project, pursuant to the Judgment. It would not accomplish the project objectives of at least 1,284 new housing units. Additionally, reduction in maximum allowable density compared to the project as proposed would likely not allow future development to be affordable to lower income households.

Alternatives
Environmental Assessment 6-3
Table 6-2 Infill Rezone Program Sites with Current Zoning Site ID Existing Zoning Density Allowance (du/ac) Min Parcel Size (square feet) Unit Potential* 3 P-C-C 0 0 0
63 R-1-7500 – 7,500 22
72 R-1-7500 – 7,500 19
108 C-2 0 0 0
110 R-1 2.1 – 3
115 R-1 2.1 – 5
157 P-C-C 0 0 0
161 C-P 0 0 0
167 C-P 0 0 0
168 C-P 0 0 0
197 R-1-AH – 24,000 8
217 M-1 0 0 0
589 R-A – 18,000 19
590 R-1 2.1 – 6
592 R-A – 18,000 5
595 R-1 2.1 – 1
596 R-1 2.1 – 2
597 R-1 2.1 – 1
598 R-1 2.1 – 2
599 R-1 2.1 – 2
Total Units 95
du/ac = dwelling units per acre
*unit assumptions are rounded up to the nearest whole number a. Impacts Compared to Proposed Project
Alternative 1 assumes there would be no change to the existing zoning of the 20 Infill Rezone Program sites. Residential development could still occur on some of these sites; however, impact on environmental resources was analyzed under the 2014 General Plan EIR. Compared to the proposed project, impacts to environmental resources found not to be significant would also not be impacted by Alternative 1.
b. Cumulative Impacts
The proposed project was determined to have a cumulatively considerable contribution to cumulative impacts as discussed in Section 4, Environmental Impact Analysis. Alternative 1 would have fewer impacts to resources found significant and unavoidable, including air quality, greenhouse gas (GHG) emissions and noise, compared to the proposed project. This would be a result of development being at a lower density and consistent with development proposed in the City’s General Plan. Impacts to biological resources, cultural resources, and tribal cultural resources would be similar to or less than the proposed project as on site land disturbance would still occur

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and be subject to the same mitigation measures, similar to the proposed project. Alternative 1 would have fewer impacts to environmental resources than the Infill Rezone Program.

6.2 Alternative 2: Alternative Infill Rezone Program Sites

6.2.1 Description
This alternative assumes there exists an alternative 20 vacant and under-utilized sites across the City that are similar or equal to the 20 Infill Rezone Program sites. Current development standards would similarly be rezoned to allow for increased densities beyond what was analyzed in the 2014 General Plan EIR. Sites would be developed with strictly residential uses, in infill locations, similar to the proposed project. This assumption creates an alternative scenario that would relocate identified project impacts to other parts of the City compared to the proposed project.

Alternative 2 assumes that alternative Infill Rezone Program sites would accommodate the exact number of new dwelling units required by the Judgment, or 1,284 new dwelling units and approximately 3,608 new residents. This would equate to approximately 367 less units and approximately 1,032 less new residents than the maximum of the proposed project. Like the proposed project, this alternative also proposes various amendments to the Zoning Ordinance, General Plan Land Use Element, and ancillary amendments to other planning documents, as necessary for clarification. This alternative would meet the project objectives, however; the proposed Infill Rezone Program sites have been identified in accordance with the Judgment and applicable state housing element law, and any alternative sites would require additional analysis to determine potential compliance with the Judgment and housing element law and would delay the implementation of the project as currently proposed.

6.2.2 Impact Analysis
a. Impacts Compared to Proposed Project
Impacts to environmental resources found not to be significant would also not be impacted by Alternative 2. The impacts under this conceptual alternative, assuming that such sites exist, would have similar environmental impacts as the Infill Rezone Program with a slight reduction in potential residents (around 0.4 percent), but on different and unidentified locations. Identifying alternative sites than those selected for the project would also require revisiting the agreement of the Judgment.
b. Cumulative Impacts
The Infill Rezone Program was determined to have a cumulatively considerable contribution to cumulative impacts as discussed in Section 4, Environmental Impact Analysis. Based on the analysis herein, Alternative 2 would have similar impacts to aesthetics, air quality, energy, GHG emissions, hazards and hazardous materials, hydrology and water quality, land use and planning, noise, population and housing, public services and recreation, transportation, tribal cultural resources, and utilities and service systems as the Infill Rezone Program. Impacts to biological resources, cultural resources, including historical buildings, could have the potential to be greater than the proposed project, as the Infill Rezone Program sites were selected with an effort to avoid these resources.

Environmental Assessment 6-5

Site No. Acreage Assumed units under Alternative 3 (dwelling units per acre) 3 8.06 235 29.2
63 3.78 110 29.2
72 3.19 93 29.2
115 2.31 67 29.2
157 7.24 211 29.2
197 4.5 131 29.2
217 1.8 53 29.2
589 8.01 234 29.2
590 3.02 88 29.2
592 2.09 61 29.2
Total 44.00 1,284
Alternatives

6.3 Alternative 3: Reduced Sites at Higher Densities

6.3.1 Description
Under Alternative 3, the project would be implemented across a reduced number of sites, at higher densities, in order to meet the project objectives under the Judgment. This alternative conceptualizes the project proceeding with only 10 of the project sites with the largest acreages being included to meet the 1,284 units required by the Judgment. This assumption is made because larger sites might have a greater chance of being developed because the value of the developed sites would be largest and larger parcels allow for more flexible development designs and greater number of units.

This alternative would accommodate the exact number of new dwelling units required by the Judgment, or 1,284 new dwelling units and approximately 3,608 new residents. This would equate to approximately 367 less units and approximately 1,032 less new residents than the maximum of the proposed project. Like the proposed project, this alternative also proposes various amendments to the Zoning Ordinance, General Plan Land Use Element, and ancillary amendments to other planning documents, as necessary for clarification.

6.3.2 Impact Analysis
a. Impacts Compared to Proposed Project
In order to meet the objectives of the project, development across reduced sites would need to be denser with associated higher maximum heights. Table 6-3 below shows an alternative scenario for the project with the largest 10 sites with the required density to meet the unit objective. The 10 sites would all need to be rezoned to R-4 zoning with an assumed 29.2 units per acre, which exceeds the assumed 25.1 units per acre the City believes is a safe assumption for the sites.

Table 6-3 Reduced Infill Rezone Program Sites with Higher Densities Density assumption for Alternative 3

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Impact under Alternative 3 would reduce significant impacts on some resources, as development would be facilitated across fewer sites. Impacts to environmental resources found not to be significant or less than significant would also be impacted by Alternative 3, some to a lesser degree.

Impacts to aesthetics would be greater due to the larger mass of the buildings at the 10 sites.

Additionally, allowing greater densities beyond what is proposed for the Infill Rezone Program sites would require higher densities that may make it difficult or expensive (parking structures) to meet parking requirements. Impacts to land use and planning, and utility service and systems might also have a greater impact than the Infill Rezone Program, as development would place a more concentrated burden on existing facilities potentially beyond what was analyzed under the 2014 General Plan EIR with existing land use designations.
b. Cumulative Impacts
Based on the analysis herein, Alternative 3 would have fewer impacts to air quality, energy, GHG emissions, noise, and transportation than the proposed project since construction would occur across fewer sites and higher density development is more energy efficient. The higher density would likely result in reduced vehicle miles traveled per resident. However, impacts would likely remain significant and unavoidable. Impacts to biological resources, cultural resources, and tribal cultural resources would be similar to or less than the proposed project. Overall, impacts under Alternative 3 would be similar to the proposed project or incrementally greater and significant and unavoidable in terms of aesthetics, but was determined to not be cumulatively considerable.

6.4 Alternatives Considered but Rejected
The following summaries include those alternatives considered, but ultimately rejected for inclusion in the analysis as they would not meet the project objectives, would not substantially reduce impacts compared to the proposed project, or were determined to be infeasible.  Increase the allowable densities for R-3 and R-4 zones. This alternative was rejected as it would impact all R-3 and R-4 zoned sites, including those already developed, making It difficult to determine the actual increase in housing that this alternative would allow. It would have also concentrated the added housing in the areas of the City already at a higher density, potentially surpassing infrastructure capacity at those locations with the higher density. This alternative was not evaluated to determine if it complies with or satisfies the requirements of the Judgment or the City’s housing element.
 Allow residential development in other zones not currently permitted. This has the potential to create incompatible uses such as housing in industrial zones. This alternative was rejected for that reason. Additionally, impacts to infrastructure, such as utilities and service systems, would be far greater in areas not currently supporting residential use.  Allow an increase in allowable number of accessory dwelling units in residential zones. This would require a substantial number of homeowners (642 at two extra units per lot up to 1,284 at one extra unit per lot) to take advantage of this opportunity in order to reach the required 1,284 additional housing units. It is not reasonable to assume this development would occur; however, the affordability of the alternative sites is less likely to be affordable to lower-income households compared to higher density developments. This alternative was not evaluated to determine if it complies with or satisfies the requirements of the Judgment or the City’s housing element.

Alternatives
Environmental Assessment 6-7

6.5 Environmentally Superior Alternative
CEQA requires identification of the environmentally superior alternative among the alternatives to the proposed project. The environmentally superior alternative must be an alternative that reduces some of the project’s environmental impacts, regardless of the financial costs associated.

Identification of the environmentally superior alternative is an informational procedure and the alternative identified as the environmentally superior alternative may not be that which best meets the goals or needs of the proposed project. Table 6-4 indicates whether each alternative’s environmental impact is greater than, less than, or similar to that of the proposed project for each of the issue areas studied.

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Table 6-4 Impact Comparison of Alternatives
Issue
Proposed Project
Impact Classification
Alternative 1:

No Project
Alternative 2:

Alternative Candidate Sites
Alternative 3:

Reduced Rezone Sites at Greater Densities
Aesthetics LTS + = -
Air Quality SU - = +
Biological Resources LTSM + =/- +
Cultural Resources SU + =/- +
Energy LTS - = +
Greenhouse Gas Emissions SU - = +
Hazards and Hazardous Materials LTS = = =
Hydrology and Water Quality LTS = = +
Land Use and Planning LTS = = -
Noise SU + = +
Population and Housing LTS + = =
Public Services and Recreation LTS + = =
Transportation SU + = +
Tribal Cultural Resources LTSM = = =
Utilities and Service Systems LTS + = -
NI = No Impact; LTS = Less than Significant; LTSM = Less than Significant with Mitigation; SU = Significant and Unavoidable + Superior to the proposed project (reduced level of impact) - Inferior to the proposed project (increased level of impact) = Similar level of impact to the proposed project

Alternatives
Environmental Assessment 6-9
Alternative 2 would generally result in similar environmental impacts to all resources compared to the proposed project. Alternative 2 would develop on alternative locations, so impacts to biological, cultural, and tribal resources may experience more significant impact depending on the site selected.

Alternative 3 would reduce the number of Infill Rezone Program sites, therefore, development would need to occur at greater densities than proposed in order to meet the project objectives. This alternative would reduce impacts related to air quality, biological and cultural resources, energy, GHG emissions, hydrology and water quality, noise, and transportation. It has similar impacts to population and housing, public services and recreation, but increase impacts to aesthetics, land use and planning, and utilities and service systems.

Based on the analysis of alternatives in this section, the No Project Alternative 1 would be the environmentally superior alternative as it would lessen the severity of most impacts of the proposed project. Because the No Project Alternative would not generate new population within the City above existing buildout projections, impacts to population and housing, public services and recreation, and utilities and service systems would be eliminated. In addition, significant but mitigable impacts related to aesthetics, air quality, GHG, and noise would be reduced compared to the proposed project. However, this alternative would not meet the project objectives, as it would not increase the opportunities or encourage the development of housing in the City.

If the No Project Alternative is determined to avoid or reduce more impacts than any other alternative, CEQA requires that the EIR identify an environmentally superior alternative among the other alternatives (CEQA Guidelines Section 15126.6[e]). However, because the proposed project is necessary to bring the City’s housing element into compliance with the Judgment, and this is an EA in accordance with Government Code section 65759, and not an EIR, CEQA does not apply and no such identification of the environmentally superior alternative is required to be made.

Nevertheless, Alternative 3 would be the environmentally superior alternative as it would lessen the severity of the majority of impacts of the proposed project by developing less housing across fewer sites and at greater densities. Impact to resources that are significant and unavoidable would still be considered significant and unavoidable. Alternative 3 would require reaching another agreement to ensure it meets the requirement of the Judgment which would delay the project.

The proposed Infill Rezone Program project would meet all four of the project objectives identified in Chapter 2, Project Description, as it would provide a framework for accommodating a total of 1,303 units (maximum of 1,651), which satisfies the 1,284 units required by the court judgment and housing element, and is not substantially more impactful than any of the other alternatives.

Therefore, the proposed project is the preferred project, although it is not the environmentally superior alternative.

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References
Environmental Assessment 7-1
7 References

7.1 Bibliography
Executive Summary
Air Quality and Land Use Handbook: A Community Health Perspective. April 2005. Accessible at:
http://www.aqmd.gov/docs/default-source/ceqa/handbook/california-air-resources-boardair-quality-and-land-use-handbook-a-community-health-perspective.pdf California Air Pollution Control Officers Association (CAPCOA), Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity, December, 2021. Accessible at:
https://www.airquality.org/ClimateChange/Documents/Final%20Handbook_AB434.pdf.

California Code of Regulations, Title 14, § 15126.4(b)(1). (2025). Consideration and discussion of mitigation measures proposed to minimize significant effects. Accessible at:
https://regulations.justia.com/states/california/title-14/division-6/chapter-3/article9/section-15126-4/ Introduction
None.

Project Description
Court Judgment in Martinez v. City of Clovis entered on March 19, 2024. Accessed April 2025:
https://www.clovisca.gov/services/planning_development/planning/projects/infill_rezone_ program.php#docaccess54fc38050d7bda918714894e83c3417350ae0a817720abf5d68df687d03f2931 ______ 2014. Land Use Element Accessible at:
https://www.clovisca.gov/services/planning_development/planning/general_plan/land_use _element.php (accessed March 2026)
______ Title 9 Development Code. 2025. Accessed April 2025:
https://www.codepublishing.com/CA/Clovis/html/Clovis09/Clovis09.html Environmental Setting
None.

Aesthetics
California Department of Transportation (Caltrans). 2019. California State Scenic Highway System Map. Accessible at:
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______ List of eligible and officially designated State Scenic Highways. 2024. https://dot.ca.gov/programs/design/lap-landscape-architecture-and-communitylivability/lap-liv-i-scenic-highways (accessed May 2025)

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Clovis, City of. July 5 2006. City of Clovis Design Guidelines. Steven White, P.E. ______ Clovis Municipal Code. Article 3 (Development and Operational Standards), Division 9.22 (Performance Standards), Section 9.22.050
______ Clovis Municipal Code. (Exterior Light and Glare). https://www.codepublishing.com/CA/Clovis/#!/Clovis09/Clovis0922.html#9.22.050 (accessed May 2025)
______ Drought Tolerant Plants. 2008. Accessible at:
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Air Quality
California Air Resources Board (CARB). 2000. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. Available at https://ww2.arb.ca.gov/sites/default/files/classic/diesel/documents/rrpfinal.pdf ______ 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April. http://www.aqmd.gov/docs/default-source/ceqa/handbook/california-air-resources-boardair-quality-and-land-use-handbook-a-community-health-perspective.pdf (accessed January 2022)
______ 2016. Ambient Air Quality Standards. Last Modified May 4, 2016. https://ww2.arb.ca.gov/sites/default/files/2020-07/aaqs2.pdf. (accessed January 2022) ______. 2025a. Top 4 Summary. https://arb.ca.gov/adam/topfour/topfourdisplay.php ______. 2025b. Overview: Diesel Exhaust & Health. https://ww2.arb.ca.gov/resources/overviewdiesel-exhaust-and-health California Department of Conservation (DOC). 2000. A General Location Guide for Ultramafic Rocks in California – Areas More Likely to Contain Naturally Occurring Asbestos. August. https://ww2.arb.ca.gov/sites/default/files/classic//toxics/asbestos/ofr_2000-019.pdf California Department of Transportation (Caltrans). 2023. Traffic Census Program. https://dot.ca.gov/programs/traffic-operations/census
California Department of Public Health. 2022. Coccidioidomycosis in California Provisional Monthly Report January-December 2022. December.
https://www.cdph.ca.gov/Programs/CID/DCDC/CDPH%20Document%20Library/CocciinCAP rovisionalMonthlyReport.pdf
Clovis, City of. 2014. General Plan and Development Code Update Draft Program Environmental Impact Report Volume 1: Draft PEIR and Appendix A (SCH # 2012061069). https://www.clovisca.gov/services/planning_development/planning/general_plan/environ mental_impact_report.php
Los Angeles County Health Department. 2013. Preventing Work-Related Coccidioidomycosis (Valley Fever). Available at
http://publichealth.lacounty.gov/acd/docs/ValleyFeverPreventionforWorkFlyer.pdf San Joaquin Valley Air Pollution Control District (SJVAPCD). 2004. Rule 8021 Construction, Demolition, Excavation, Extraction, and Other Earthmoving Activities. Adopted November 15, 2001, Amended August 19, 2004. www.valleyair.org/rules/currntrules/r8021.pdf.

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Environmental Assessment 7-3
______ 2015. Guide for Assessing and Mitigating Air Quality Impacts, March 19, 2015. https://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT-GAMAQI.PDF ______. 2020. 2020 Reasonably Available Control Technology (RACT) Demonstration for the 2015 8- Hour Ozone Standard. Adopted June 18, 2020.
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______ 2022. Learn About Asbestos. https://www.epa.gov/asbestos/learn-about-asbestos Biological Resources
California Department of Fish and Wildlife. 2025a. California Natural Diversity Database, Rarefind V.

5.3.0 (accessed April 2025).
______ 2025c. California Sensitive Natural Communities. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=153609&inline (accessed April 2025). ______ 2025b. California Natural Diversity Database (CNDDB) Biogeographic Information and Observation System. http://bios.dfg.ca.gov (accessed April 2025). ______ 2025c. California Sensitive Natural Communities. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=153609&inline (accessed April 2025). ______. 2025b. California Natural Diversity Database (CNDDB) Biogeographic Information and Observation System. http://bios.dfg.ca.gov (accessed April 2025).

CNPS. Rare Plant Program. 2025. Inventory of Rare and Endangered Plants of California (online edition, v9.5.1). California Native Plant Society, Sacramento, CA. http://www.rareplants.cnps.org (accessed April 2025).

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______ 2014. Clovis General Plan and Development Code Update Draft PEIR. Prepared by Placeworks.https://www.clovisca.gov/services/planning_development/planning/general_pl an/environmental_impact_report.php (Accessed April 2025) USFWS. 2025a. Information for Planning and Consultation (IPaC). http://ecos.fws.gov/ipac/ (accessed April 2025).
______ 2025b. Critical Habitat Portal. Retrieved from: http://criticalhabitat.fws.gov (April 2025). ______ 2025c. National Wetlands Inventory. Retrieved from: http://www.fws.gov/wetlands/ (April 2025).

Cultural Resources
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______ § 5097.5. (2025). Protection of archaeological and historical resources on public lands.

Accessible at: https://california.public.law/codes/public_resources_code_section_5097.5 California Code of Regulations, Title 14, § 15126.4(b)(1). (2025). Consideration and discussion of mitigation measures proposed to minimize significant effects. Accessible at:
https://regulations.justia.com/states/california/title-14/division-6/chapter-3/article9/section-15126-4/ ______ Title 14, § 15064.5(b)(1). (2025). Determining the significance of impacts to archaeological and historical resources. Accessible at: https://regulations.justia.com/states/california/title14/division-6/chapter-3/article-5/section-15064-5/ California Office of Historic Preservation. 1995:2. Instructions for Recording Historical Resources.

Department of Parks and Recreation, Sacramento, California.

City of Clovis. 2014. Draft Program Environmental Impact Report, General Plan and Development Code Update.
https://www.clovisca.gov/services/planning_development/planning/general_plan/environ mental_impact_report.php (Accessed July 2025)
Fresno County Landmarks. 2025. https://www.fresnolandmarks.com/ (Accessed June 2025) Kroeber, Alfred L. 1925. Handbook of the Indians of California. Bulletin 78, Bureau of American Ethnology, Smithsonian Institution. Government Printing Office, Washington, D.C. Reprinted 1976 by Dover Publications, Inc., New York.

Mithun, Marianne. 2001. The Languages of Native North America. Reprinted. Originally published 1999. Cambridge University Press, New York.

Wallace, William J. 1978. Southern Valley Yokuts.” In “California,” edited by Robert F. Heizer.

Handbook of North American Indians, Vol. 8, pp. 448–461. Smithsonian Institution, Washington.

References
Environmental Assessment 7-5
Energy
Alternative Fuels Data Center. U.S. Department of Energy. 2025. Accessed May 2025:
https://afdc.energy.gov/stations#/find/nearest?country=US&fuel=BD&location=california California Air Resources Board (CARB). 2025. Accessible at: https://ww2.arb.ca.gov/ourwork/programs/fuels-enforcment-program/california-reformulated-gasoline California Department of Finance (DOF). Population Estimates for Cities, Counties, and the State 2021-2025. 2023. Accessed June 2025:
https://dof.ca.gov/Forecasting/Demographics/Estimates/e-4-population-estimates-forcities-counties-and-the-state-2021-2025-with-2020-census-benchmark/ CEC. 2022. Accessed May 2025: https://www.energy.ca.gov/data-reports/energyalmanac/california-electricity-data/california-energy-consumption-dashboards-1 ______ 2023. Accessed June 2025: http://www.ecdms.energy.ca.gov/elecbycounty.aspx ______ 2023. Accessed May 2025: https://www.energy.ca.gov/data-reports/energyalmanac/california-electricity-data/california-energy-consumption-dashboards-1 ______ 2022 Integrated Energy Policy Report Update. 2023. Accessed June 2025:
https://www.energy.ca.gov/data-reports/reports/integrated-energy-policy-reportiepr/2022-integrated-energy-policy-report ______ 2024. Accessed June 2025: https://www.energy.ca.gov/data-reports/energyalmanac/california-electricity-data/california-energy-consumption-dashboards-0 California Gas and Electric Utilities (CGEU) 2024. Accessed June 2025:
https://www.pge.com/pipeline/en/reference-library/regulatory/cgr.html California Public Resources Code Section 25301[a]). Accessed June 2025:
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______ 2022. Transportation Energy. Accessed June 2025:
https://www.eia.gov/energyexplained/use-of-energy/transportation.php ______ 2023. Accessed June 2025: https://www.eia.gov/state/seds/seds-data-complete.php ______ 2023. Accessed June 2025: https://www.eia.gov/energyexplained/diesel-fuel/use-ofdiesel.php ______ 2023. Accessed May 2025: https://www.eia.gov/energyexplained/us-energy-facts/data-andstatistics.php ________ 2023. Accessed June 2025: https://www.eia.gov/state/analysis.php?sid=CA

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Environmental Protection Agency & National Highway Traffic Safety Administration. 2012.77 Federal Register [FR] 62624 et seq. October 15, 2012, Table I-1. Accessed July 2025:
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PG&E. 2022. Accessed June 2025: https://www.pge.com/en/about/corporate-responsibility-andsustainability/taking-responsibility/clean-energy-solutions.html PlugShare 2025. https://www.plugshare.com/directory/us/california/clovis (Accessed May 2025) Greenhouse Gas Emissions
California Air Resources Board (CARB). 2011. Advanced Clean Cars Summary. https://ww2.arb.ca.gov/sites/default/files/2019-12/acc%20summary-final_ac.pdf ______. 2017. California’s 2017 Climate Change Scoping Plan. December 14, 2017. https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf ______. 2020. EMFAC Off-Model Adjustment Factors for Carbon Dioxide (CO2) Emissions to Account for the SAFE Vehicles Rule Part One and the Final SAFE Rule. https://ww2.arb.ca.gov/sites/default/files/2023-
02/emfac_off_model_co2_adjustment_factors_06262020-final.pdf ______. 2021. GHG 1990 Emissions Level & 2020 Limit. https://ww2.arb.ca.gov/ghg-2020-limit ______. 2022a. 2022 Scoping Plan for Achieving Carbon Neutrality. Adopted November 16, 2022. https://ww2.arb.ca.gov/sites/default/files/2023-04/2022-sp.pdf ______. 2022b. Appendix D, Local Actions, of the 2022 Scoping Plan for Achieving Carbon Neutrality. https://ww2.arb.ca.gov/sites/default/files/2022-05/2022-draft-sp-appendix-d-localactions_0.pdf ______. 2025. Current California GHG Emission Inventory Data. https://ww2.arb.ca.gov/ghginventory-data California Climate Change Center (CCCC). 2006. Climate Scenarios for California. https://research.fit.edu/media/site-specific/researchfitedu/coast-climate-adaptationlibrary/united-states/west-coast-amp-hawaix27i/california---statewide/CCCC.--2006.-- Climate-Scenarios-for-California.pdf
California Department of Food and Agriculture. 2020. “California Agricultural Production Statistics.” https://www.cdfa.ca.gov/statistics/
California Department of Water Resources. 2018. Indicators of Climate Change in California. May 2018. https://oehha.ca.gov/media/downloads/climatechange/report/2018caindicatorsreportmay2018.pdf California Energy Commission (CEC). 2022a. 2022 Building Energy Efficiency Standards. https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiencystandards/2022-building-energy-efficiency

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______. 2022b. 2022 Building Energy Efficiency Standards for Residential and Nonresidential Buildings: For the 2022 Building Energy Efficiency Standards Title 24, Part 6, and Associated Administrative Regulations in Part 1. https://www.energy.ca.gov/publications/2022/2022- building-energy-efficiency-standards-residential-and-nonresidential ______. 2022c. Energy Commission Adopts Updated Building Standards to Improve Efficiency, Reduce Emissions From Homes and Businesses. https://www.energy.ca.gov/news/2024- 09/energy-commission-adopts-updated-building-standards-expanding-requirementsheat#:~:text=SACRAMENTO%20%E2%80%93%20The%20California%20Energy%20Commissi on,climate%20and%20public%20health%20goals.

California Natural Resources Agency. 2009. 2009 California Climate Adaptation Strategy. March 2009. http://resources.ca.gov/docs/climate/Statewide_Adaptation_Strategy.pdf Caltrans. 2022. 2022 Annual Average Daily Traffic. https://dot.ca.gov/programs/trafficoperations/census Clovis, City of. 2014a. General Plan EIR.
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______. 2014b. General Plan.
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______. 2023. Active Transportation Plan.
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Goldfarb, M. I. Gomis, M. Huang, K. Leitzell, E. Lonnoy, J.B.R. Matthews, T. K. Maycock, T.

Waterfield, O. Yelekçi, R. Yu and B. Zhou (eds.)] Cambridge University Press. https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Full_Report.pdf National Aeronautics and Space Administration. 2020. “Global Climate Change – Vital Signs of the Planet – Sea Level.” https://climate.nasa.gov/vital-signs/sea-level/ National Oceanic and Atmospheric Administration. 2025. “Global Climate Report for Annual 2025” State of the Climate. January 2025.
https://www.ncei.noaa.gov/access/monitoring/monthly-report/global/202501 Parmesan, C. August 2006. Ecological and Evolutionary Responses to Recent Climate Change.

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San Joaquin Valley Air Pollution Control District (SJVACPD). 2009a. Guidance for Valley Land-us Agencies in Addressing GHG Emission Impacts for New Projects Under CEQA. December. ______ 2009b. Final Staff Report Addressing Greenhouse Gas Emissions Impacts Under the California Environmental Quality Act. December.
https://www.valleyair.org/Programs/CCAP/12-17-09/1%20CCAP%20- %20FINAL%20CEQA%20GHG%20Staff%20Report%20-%20Dec%2017%202009.pdf State of California. 2018. California’s Fourth Climate Change Assessment Statewide Summary Report. August 27, 2018. http://www.climateassessment.ca.gov/state/ U.S. EPA. 2021a. Climate Change Indicators: Atmospheric Concentrations of Greenhouse Gases. Last updated April 2021. https://www.epa.gov/climate-indicators/climate-change-indicatorsatmospheric-concentrations-greenhouse-gases ______. 2021b. Climate Change Indicators: Global Greenhouse Gas Emissions. Last updated April 2021. https://www.epa.gov/climate-indicators/climate-change-indicators-globalgreenhouse-gas-emissions ______. 2021c. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2019. April 2021. https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks1990-2019 World Meteorological Organization. 2022. Greenhouse Gases. https://wmo.int/topics/greenhousegases Hazards and Hazardous Materials
California Department of Forestry and Fire, 2025. Fire Hazard Severity Zone Viewer. https://experience.arcgis.com/experience/6a9cb66bb1824cd98756812af41292a0 (accessed September 2025).

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).

United States Environmental Protection Agency (EPA). 2024. Overview of the Asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP). https://www.epa.gov/asbestos/overview-asbestos-national-emission-standards-hazardousair-pollutants-neshap (accessed May 2025). ______.2024a. Learn About Asbsestos. https://www.epa.gov/asbestos/learn-aboutasbestos#:~:text=into%20the%20air.- ,Health%20Effects%20From%20Exposure%20to%20Asbestos,of%20developing%20harmful %20health%20effects. (accessed May 2025).
______. 2024b. Learn About Lead. https://www.epa.gov/lead/learnaboutlead#:~:text=Adults%20exposed%20to%20lead%20can,in%20both%20men%20and%2 0women). (accessed May 2024).

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Department of Toxic Substances Control (DTSC). EnviroStor Database. Accessed October 2025:
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&tiered _permit=True&evaluation=True&operating=True&post_closure=True&non_operating=True &inspections=True&inspectionsother=True
Federal Motor Carrier Safety Administration. 2024. National Hazardous Materials Route Registry – By State: California. https://www.fmcsa.dot.gov/regulations/hazardous-materials/nationalhazardous-materials-route-registry-state (accessed July 2025).

Fresno Council of Governments. 2023. Fresno County Airport Land Use Compatibility Plan Appendix D. https://www.fresnocog.org/wp-content/uploads/2025/01/Appendix-D-Fresno-YosemiteIntern9ational-Airport-FAT.pdf.

State Water Resources Control Board (SWRCB). 2025. GeoTracker Database. https://geotracker.waterboards.ca.gov/map/?CMD=runreport&myaddress=clovis Hydrology and Water Quality
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)
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_201 805.pdf (Accessed May 2025)
City of Clovis. 2014. General Plan. Available:
https://www.clovisca.gov/services/planning_development/planning/general_plan/index.ph phttps://cityofclovis.com/wp-content/uploads/2018/10/Clovis-General-Plan-2014.pdf. (Accessed May 2025)
______.2021. Urban Water Management Plan 2020 Update. Available:
https://www.clovisca.gov/services/public_utilities/water/index.php#docaccess513243771b4f1a89a630a287eeb11767f2aa5d4613bf20a797e0ac1fb6f18507. Accessed May 2025
______. 2022. Water Supply Assessment. Available: https://files.ceqanet.lci.ca.gov/284041- 1/attachment/gDuLMfphVf0CVi4YLFaTxWXwlFzitTVx4MCkw3XPL1aBFVntkQPWFjBmrJLt9Z OPUYPcyNKKb8oFGlE50. Accessed October 2025.
______.2025. Water. Available: https://www.clovisca.gov/services/public_utilities/water/index.php Federal Emergency Management Agency (FEMA). 2025. FEMA Flood Map Service Center. Available:
https://msc.fema.gov/portal/search?AddressQuery=Clovis. Accessed June 2025.

Fresno Metropolitan Flood Control District. 2025. Development in Fresno/Clovis. Available:
https://www.fresnofloodcontrol.org/development-in-fresno-clovis/ (Accessed June 2025)

City of Clovis
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Land Use and Planning
California Public Resources Code Sections 21155, 21155.1, 21155.2, 21159.28 City of Clovis. 2014. General Plan. Available:
https://www.clovisca.gov/services/planning_development/planning/general_plan/index.ph phttps://cityofclovis.com/wp-content/uploads/2018/10/Clovis-General-Plan-2014.pdf. (Accessed May 2025)
Noise
California Department of Transportation (Caltrans). 2013. Technical Noise Supplement to the Traffic Noise Analysis Protocol. (CT-HWANP-RT-13-069.25.2) https://dot.ca.gov/-/media/dotmedia/programs/environmental-analysis/documents/env/tens-sep2013-a11y.pdf (accessed June 2025).
______. 2020. Transportation and Construction Vibration Guidance Manual.: https://dot.ca.gov/- /media/dot-media/programs/environmental-analysis/documents/env/tcvgm-apr2020- a11y.pdf (accessed June 2025).

Clovis, City of. 2014a. City of Clovis General Plan.
https://www.clovisca.gov/services/planning_development/planning/general_plan/environ mental_impact_report.php (accessed June 2025).
______. 2014b. City of Clovis General Plan Environmental Impact Report. Accessible from:
https://www.clovisca.gov/services/planning_development/planning/general_plan/environ mental_impact_report.phphttps (accessed June 2025).
______. 2025. City of Clovis Municipal Code. May 12, 2025. Accessible from:
https://www.codepublishing.com/CA/Clovis/ (Accessed June 2025) Crocker, Malcolm J. (Editor). 2007. Handbook of Noise and Vibration Control Book, ISBN: 978-0-471- 39599-7, Wiley-VCH, October.

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

November. https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/researchinnovation/118131/transit-noise-and-vibration-impact-assessment-manual-fta-report-no0123_0.pdf (accessed June 2025).

Kittelson & Associates. 2025. Transportation Analysis. June 2025.

Population and Housing
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/ ______.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/ California Government Code. § 65589.5..Accessed June 2025:
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201920200SB330^ ______.§ 65583(c)(1). California Legislative Information. Accessed June 2025:
https://codes.findlaw.com/ca/government-code/gov-sect-65583/

References
Environmental Assessment 7-11
______.§ 66300(d). (2023). California Legislative Information. Accessed June 2025:
https://codes.findlaw.com/ca/government-code/gov-sect-66300/ City of Clovis. General Plan land Use Element Table LU-1. Accessed June 2025:
https://www.clovisca.gov/services/planning_development/planning/general_plan/land_use _element.php#docaccess1ccfb3580a11f4c0ae8949222fe6e07fbbc27a6c11e3a0117d8e964f4d6c6cf7 ______.Sixth Cycle Housing Element. 2024. Accessed May 2025:
https://www.clovisca.gov/services/planning_development/planning/general_plan/index.ph p#docaccess-7aed989b23068609d870bcd34c8bbf403c50c07dcbf90d2afd7926d01e63e4f9 Fresno Council of Governments. Fresno County 2023-2060 Growth Projections. Accessed June 2025:
https://agendas.fresnocog.org/wp-content/uploads/2024/10/2024-Fresno-COG-2023-2060- Growth-Projections-Draft.pdf
Public Services and Recreation
Clovis, City of. 2014. General Plan.
https://www.clovisca.gov/services/planning_development/planning/general_plan/index.php Clovis Fire Department. SOC and Annual Report. 2023. Accessed October 2025:
https://www.clovisca.gov/services/fire/about/soc_annual_report.php Clovis Unified School District. 2025. School Facilities Needs Analysis. https://files.smartsites.parentsquare.com/6245/clovis_usd_sfna_2025.pdf Transportation
California Air Pollution Control Officers Association (CAPCOA), Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity, December, 2021. Accessible at:
https://www.airquality.org/ClimateChange/Documents/Final%20Handbook_AB434.pdf Clovis, City of. Clovis Active Transportation Plan. 2023. Accessible at:, https://www.clovisca.gov/services/planning_development/engineering/active_transportati on_plan/index.phpGovernor’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 Fresno COG. 2022. Multijurisdictional Local Road Safety Plan. Accessible at:, https://www.fresnocog.org/wp-content/uploads/2022/06/26012_Fresno-COGMLRSP_Report-FINAL-April-update_Part1-1.pdf Tribal Cultural Resources
Barton, Amber, Maria Del Carmen Guzman, and Breeann Romo 2010 The Preliminary Results of the 2008 Archaeological Investigations at the Bead Hill Site (KRE-450), Buena Vista Lake, California. SCA Proceedings 24: 1-12.

Davis, James 1961 Trade Routes and Economic Exchange Among the Indians of California. Reports of the University of California Archaeological Survey 54.

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Gayton, A.H. 1945 Yokuts and Western Mono Social Organization. American Anthropologist 47(3):409-426.

Kroeber, Alfred L. 1925 Handbook of the Indians of California. Bulletin 78, Bureau of American Ethnology, Smithsonian Institution. Government Printing Office, Washington, D.C. Reprinted 1976 by Dover Publications, Inc., New York.

Mithun, Marianne 2001 The Languages of Native North America. Reprinted. Originally published 1999. Cambridge University Press, New York.

Office of Land Use and Climate Innovation. 2005. Tribal Consultation Guidelines. Available:
https://lci.ca.gov/docs/011414_Updated_Guidelines_922.pdf (accessed May 2025).

Sutton, Mark Q., Jille K. Gardner, Kenneth W. Gobalet, and Nancy Valente 2016 “Archaeological Investigations at the Manifold Site (CA-KER-4220), Buena Vista Lake, Southern San Joaquin Valley, California.” Pacific Coast Archaeological Society Quarterly, Vol. 52 (4), pp. 15-82.

Rosenthal, Jeffrey, Gregory White, and Mark Sutton. 2007.The Central Valley: A View from the Catbird’s Seat. In California Prehistory: Colonization, Culture, and Complexity, edited by Terry L. Jones and Kathryn A. Klar. AltaMira Press, Lanham Maryland.

Wallace, William J. 1978 “Southern Valley Yokuts.” In “California,” edited by Robert F. Heizer, pp. 448–461. Handbook of North American Indians, Vol. 8, William C. Sturtevant, general editor, Smithsonian Institution, Washington.

Utilities and Service Systems
California Public Utilities Commission(CPUC). Natural Gas and California. Accessed October 2025:
https://www.cpuc.ca.gov/industries-and-topics/natural-gas/natural-gas-and-california CalRecycle. 2024. Disposal Reporting. Accessible at:
https://www2.calrecycle.ca.gov/RecyclingDisposalReporting/Reports/JurisdictionDisposalAn dBeneficial
Clovis, City of. 2014. City of Clovis General Plan EIR. Accessible at:
https://www.clovisca.gov/services/planning_development/planning/general_plan/environ mental_impact_report.php
______.2020 Urban Water Management Plan Update. 2020. Accessible at:
https://www.clovisca.gov/services/public_utilities/water/index.php#docaccess513243771b4f1a89a630a287eeb11767f2aa5d4613bf20a797e0ac1fb6f18507 ______. Water Supply Contingency Plan. 2020. Accessible at:
https://www.clovisca.gov/services/public_utilities/water/index.php#docaccesse72e52d63e6a743057c5ba29347416d15ea22fbc90c340520384b67e581f21ae ______.2017. Wastewater Collection System Master Plan. Clovis, CA: City of Clovis Fresno, City of. Fresno-Clovis Regional Wastewater Reclamation Facility. Accessed November 2025:
https://www.fresno.gov/publicutilities/sewer-wastewater/wastewater-facilitiesinfrastructure/#regional-wastewater-reclamation-facility Environmental Protection Agency. City of Fresno Reclamation Facility. 2016. Accessed November 2025: https://www.epa.gov/sites/default/files/2016-
05/documents/wrrf_fresno_v2_may_12.pdf

References
Environmental Assessment 7-13
Fresno Metropolitan Flood Control District. About Fresno Metropolitan Flood Control District.

Accessed October 2025: https://www.fresnofloodcontrol.org/ North Kings Groundwater Sustainability Agency. 2025. 2025 Groundwater Sustainability Plan.

Accessible at: https://northkingsgsa.org/groundwater-sustainability-plan/ U.S. Census. 2019. Tarpey Village , CA. Accessible at:
https://censusreporter.org/profiles/16000US0677960-tarpey-village-ca/

7.2 List of Preparers
This environmental assessment (EA) was prepared by the City of Clovis, with the assistance of Rincon Consultants, Inc. Consultant staff involved in the preparation of the EA are listed below.

Rincon Consultants, Inc.

Matthew Maddox, AICP, Principal
Eric VonBerg, MRP, Project Manager/Supervising Planner
Jason Montague, Senior Environmental Planner
Erin Knight, Environmental Planner
Ryan Perry, Environmental Planner
Maya Ziff, Environmental Planner
Monet Bernard, Environmental Planner
Kaylee Herbold, Data Analyst
Alvin Flores, Publishing Specialist
Debra Jane Seltzer, Publishing Manager

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Appendix A
Air Quality (AQ) 1

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City of Clovis Rezone Detailed Report
Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds

2.2. Construction Emissions by Year, Unmitigated

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

3. Construction Emissions Details

3.1. Demolition (2026) - Unmitigated

3.3. Site Preparation (2026) - Unmitigated

3.5. Grading (2026) - Unmitigated

3.7. Building Construction (2026) - Unmitigated

3.9. Building Construction (2027) - Unmitigated

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3.11. Building Construction (2028) - Unmitigated

3.13. Building Construction (2029) - Unmitigated

3.15. Building Construction (2030) - Unmitigated

3.17. Building Construction (2031) - Unmitigated

3.19. Paving (2031) - Unmitigated

3.21. Architectural Coating (2029) - Unmitigated

3.23. Architectural Coating (2030) - Unmitigated

3.25. Architectural Coating (2031) - Unmitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

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4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

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5.3. Construction Vehicles

5.3.1. Unmitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities

5.6.2. Construction Earthmoving Control Strategies

5.7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.9. Operational Mobile Sources

5.9.1. Unmitigated

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.11. Operational Energy Consumption

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5.11.1. Unmitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated

5.13. Operational Waste Generation

5.13.1. Unmitigated

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

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5.18.2. Sequestration

5.18.2.1. Unmitigated

6. Climate Risk Detailed Report

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

6.3. Adjusted Climate Risk Scores

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores

7.2. Healthy Places Index Scores

7.3. Overall Health & Equity Scores

7.4. Health & Equity Measures

7.5. Evaluation Scorecard

7.6. Health & Equity Custom Measures

8. User Changes to Default Data

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1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name City of Clovis Rezone
Construction Start Date 1/1/2026
Operational Year 2031
Lead Agency —
Land Use Scale Plan/community
Analysis Level for Defaults County
Windspeed (m/s) 2.70
Precipitation (days) 21.4
Location Clovis, CA, USA
County Fresno
City Clovis
Air District San Joaquin Valley APCD
Air Basin San Joaquin Valley
TAZ 2437
EDFZ 5
Electric Utility Pacific Gas & Electric Company
Gas Utility Pacific Gas & Electric
App Version 2022.1.1.29

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
Apartments Mid
Rise
1,651 Dwelling Unit 54.3 1,584,960 0.00 0.00 4,623 —

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1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 23.1 22.5 29.2 54.7 0.06 1.24 8.35 9.00 1.14 3.96 5.11 — 12,628 12,628 0.35 0.67 26.8 12,861 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 22.6 21.9 27.3 47.6 0.06 1.12 8.35 8.67 1.03 1.98 2.48 — 11,743 11,743 0.44 0.70 0.77 11,963 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 16.0 15.5 17.1 32.5 0.03 0.68 5.89 6.10 0.63 1.40 1.67 — 8,430 8,430 0.26 0.47 8.26 8,585 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 2.91 2.84 3.12 5.93 0.01 0.12 1.07 1.11 0.11 0.25 0.31 — 1,396 1,396 0.04 0.08 1.37 1,421

2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — — —
2026 3.82 3.21 29.2 29.4 0.06 1.24 7.76 9.00 1.14 3.96 5.11 — 6,717 6,717 0.27 0.06 0.41 6,742

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2027 5.99 5.62 15.1 52.1 0.04 0.37 7.06 7.43 0.34 1.68 2.02 — 11,536 11,536 0.34 0.63 26.8 11,758 2028 5.71 5.19 14.3 49.5 0.04 0.33 7.06 7.39 0.31 1.68 1.99 — 11,349 11,349 0.34 0.63 24.0 11,568 2029 23.1 22.5 14.7 54.7 0.04 0.32 8.35 8.67 0.30 1.98 2.28 — 12,628 12,628 0.35 0.67 25.0 12,861 2030 22.8 22.2 14.4 51.9 0.04 0.30 8.35 8.65 0.28 1.98 2.26 — 12,426 12,426 0.33 0.42 22.1 12,582 2031 18.3 18.2 7.21 17.0 0.02 0.22 1.38 1.59 0.20 0.32 0.52 — 3,010 3,010 0.09 0.03 2.98 3,024 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2026 5.79 5.39 27.3 47.6 0.06 1.12 7.06 7.47 1.03 1.68 2.48 — 10,945 10,945 0.41 0.67 0.77 11,155 2027 5.48 4.91 15.8 45.1 0.04 0.37 7.06 7.43 0.34 1.68 2.02 — 10,767 10,767 0.41 0.65 0.70 10,973 2028 5.23 4.69 15.0 42.8 0.04 0.33 7.06 7.39 0.31 1.68 1.99 — 10,596 10,596 0.39 0.65 0.62 10,801 2029 22.6 21.9 15.6 47.3 0.04 0.32 8.35 8.67 0.30 1.98 2.28 — 11,743 11,743 0.44 0.70 0.65 11,963 2030 22.0 21.7 15.0 45.1 0.04 0.30 8.35 8.65 0.28 1.98 2.26 — 11,557 11,557 0.39 0.67 0.57 11,767 2031 21.8 21.5 14.3 43.0 0.04 0.28 8.35 8.64 0.25 1.98 2.23 — 11,381 11,381 0.36 0.65 0.51 11,585 Average
Daily
— — — — — — — — — — — — — — — — — —
2026 2.71 2.32 17.1 20.5 0.03 0.68 2.72 3.39 0.63 1.05 1.67 — 4,465 4,465 0.17 0.10 1.45 4,501 2027 3.95 3.69 11.1 32.5 0.03 0.26 4.97 5.24 0.24 1.18 1.43 — 7,845 7,845 0.26 0.47 8.26 7,999 2028 3.79 3.40 10.5 31.0 0.03 0.24 4.99 5.22 0.22 1.19 1.41 — 7,741 7,741 0.26 0.45 7.43 7,888 2029 11.0 10.5 10.5 32.1 0.03 0.22 5.51 5.73 0.21 1.31 1.52 — 8,165 8,165 0.26 0.46 7.24 8,316 2030 16.0 15.5 10.4 32.4 0.03 0.22 5.89 6.10 0.20 1.40 1.60 — 8,430 8,430 0.26 0.47 6.84 8,585 2031 9.12 9.05 2.83 7.88 0.01 0.07 1.19 1.26 0.06 0.28 0.34 — 1,781 1,781 0.05 0.04 1.18 1,796 Annual — — — — — — — — — — — — — — — — — —
2026 0.49 0.42 3.12 3.74 0.01 0.12 0.50 0.62 0.11 0.19 0.31 — 739 739 0.03 0.02 0.24 745 2027 0.72 0.67 2.02 5.93 0.01 0.05 0.91 0.96 0.04 0.22 0.26 — 1,299 1,299 0.04 0.08 1.37 1,324 2028 0.69 0.62 1.91 5.66 0.01 0.04 0.91 0.95 0.04 0.22 0.26 — 1,282 1,282 0.04 0.07 1.23 1,306 2029 2.00 1.92 1.91 5.86 0.01 0.04 1.01 1.05 0.04 0.24 0.28 — 1,352 1,352 0.04 0.08 1.20 1,377 2030 2.91 2.84 1.90 5.92 0.01 0.04 1.07 1.11 0.04 0.25 0.29 — 1,396 1,396 0.04 0.08 1.13 1,421 2031 1.66 1.65 0.52 1.44 < 0.005 0.01 0.22 0.23 0.01 0.05 0.06 — 295 295 0.01 0.01 0.19 297

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2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 52.9 50.2 28.9 285 0.69 1.28 58.2 59.4 1.24 14.7 16.0 714 81,795 82,508 61.1 2.76 146 85,004 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 44.2 42.1 30.5 135 0.63 1.23 58.2 59.4 1.21 14.7 16.0 714 76,028 76,742 61.0 2.89 14.9 79,145 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 48.4 46.1 29.9 195 0.65 1.25 57.4 58.6 1.23 14.5 15.8 714 77,728 78,442 61.1 2.83 69.7 80,882 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 8.84 8.41 5.46 35.6 0.12 0.23 10.5 10.7 0.22 2.65 2.88 118 12,869 12,987 10.1 0.47 11.5 13,391

2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 6.45 4.90 17.5 186 0.62 0.39 58.2 58.5 0.36 14.7 15.1 — 63,553 63,553 1.12 2.34 135 64,413 Area 45.2 44.7 0.87 94.0 < 0.005 0.04 — 0.04 0.03 — 0.03 0.00 250 250 0.01 < 0.005 — 251 Energy 1.23 0.61 10.5 4.46 0.07 0.85 — 0.85 0.85 — 0.85 — 17,849 17,849 1.91 0.11 — 17,931 Water — — — — — — — — — — — 138 142 280 0.50 0.30 — 383 Waste — — — — — — — — — — — 576 0.00 576 57.5 0.00 — 2,014 Refrig. — — — — — — — — — — — — — — — — 11.4 11.4

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Total 52.9 50.2 28.9 285 0.69 1.28 58.2 59.4 1.24 14.7 16.0 714 81,795 82,508 61.1 2.76 146 85,004 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 6.34 4.85 20.0 131 0.57 0.39 58.2 58.5 0.36 14.7 15.1 — 58,037 58,037 1.08 2.47 3.50 58,805 Area 36.6 36.6 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Energy 1.23 0.61 10.5 4.46 0.07 0.85 — 0.85 0.85 — 0.85 — 17,849 17,849 1.91 0.11 — 17,931 Water — — — — — — — — — — — 138 142 280 0.50 0.30 — 383 Waste — — — — — — — — — — — 576 0.00 576 57.5 0.00 — 2,014 Refrig. — — — — — — — — — — — — — — — — 11.4 11.4
Total 44.2 42.1 30.5 135 0.63 1.23 58.2 59.4 1.21 14.7 16.0 714 76,028 76,742 61.0 2.89 14.9 79,145 Average
Daily
— — — — — — — — — — — — — — — — — —
Mobile 6.35 4.84 19.0 144 0.58 0.39 57.4 57.7 0.36 14.5 14.9 — 59,613 59,613 1.10 2.41 58.3 60,418 Area 40.9 40.6 0.43 46.4 < 0.005 0.02 — 0.02 0.02 — 0.02 0.00 124 124 0.01 < 0.005 — 124 Energy 1.23 0.61 10.5 4.46 0.07 0.85 — 0.85 0.85 — 0.85 — 17,849 17,849 1.91 0.11 — 17,931 Water — — — — — — — — — — — 138 142 280 0.50 0.30 — 383 Waste — — — — — — — — — — — 576 0.00 576 57.5 0.00 — 2,014 Refrig. — — — — — — — — — — — — — — — — 11.4 11.4
Total 48.4 46.1 29.9 195 0.65 1.25 57.4 58.6 1.23 14.5 15.8 714 77,728 78,442 61.1 2.83 69.7 80,882 Annual — — — — — — — — — — — — — — — — — —
Mobile 1.16 0.88 3.47 26.3 0.11 0.07 10.5 10.5 0.07 2.65 2.72 — 9,870 9,870 0.18 0.40 9.66 10,003 Area 7.46 7.41 0.08 8.46 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 20.4 20.4 < 0.005 < 0.005 — 20.5 Energy 0.22 0.11 1.91 0.81 0.01 0.15 — 0.15 0.15 — 0.15 — 2,955 2,955 0.32 0.02 — 2,969 Water — — — — — — — — — — — 22.8 23.5 46.3 0.08 0.05 — 63.4 Waste — — — — — — — — — — — 95.3 0.00 95.3 9.53 0.00 — 333 Refrig. — — — — — — — — — — — — — — — — 1.88 1.88
Total 8.84 8.41 5.46 35.6 0.12 0.23 10.5 10.7 0.22 2.65 2.88 118 12,869 12,987 10.1 0.47 11.5 13,391

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3. Construction Emissions Details

3.1. Demolition (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

2.72 2.29 20.7 19.0 0.03 0.84 — 0.84 0.78 — 0.78 — 3,427 3,427 0.14 0.03 — 3,438 Demoliti
on
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

2.72 2.29 20.7 19.0 0.03 0.84 — 0.84 0.78 — 0.78 — 3,427 3,427 0.14 0.03 — 3,438 Demoliti
on
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.52 0.44 3.96 3.64 0.01 0.16 — 0.16 0.15 — 0.15 — 657 657 0.03 0.01 — 659

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Demoliti — — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — — Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.10 0.08 0.72 0.67 < 0.005 0.03 — 0.03 0.03 — 0.03 — 109 109 < 0.005 < 0.005 — 109 Demoliti
on
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.06 0.06 0.03 0.51 0.00 0.00 0.08 0.08 0.00 0.02 0.02 — 89.0 89.0 < 0.005 < 0.005 0.31 90.6 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.05 0.05 0.04 0.42 0.00 0.00 0.08 0.08 0.00 0.02 0.02 — 79.1 79.1 < 0.005 < 0.005 0.01 80.3 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 15.7 15.7 < 0.005 < 0.005 0.03 16.0 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.60 2.60 < 0.005 < 0.005 < 0.005 2.64

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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.3. Site Preparation (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

3.74 3.14 29.2 28.8 0.05 1.24 — 1.24 1.14 — 1.14 — 5,298 5,298 0.21 0.04 — 5,316 Dust
From
Material
Movement
— — — — — — 7.67 7.67 — 3.94 3.94 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.41 0.34 3.20 3.16 0.01 0.14 — 0.14 0.13 — 0.13 — 581 581 0.02 < 0.005 — 583 Dust
From
Material
Movement
— — — — — — 0.84 0.84 — 0.43 0.43 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

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Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.07 0.06 0.58 0.58 < 0.005 0.02 — 0.02 0.02 — 0.02 — 96.1 96.1 < 0.005 < 0.005 — 96.5 Dust
From
Material
Movement
— — — — — — 0.15 0.15 — 0.08 0.08 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.07 0.07 0.04 0.60 0.00 0.00 0.10 0.10 0.00 0.02 0.02 — 104 104 < 0.005 < 0.005 0.36 106 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 10.5 10.5 < 0.005 < 0.005 0.02 10.6 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.73 1.73 < 0.005 < 0.005 < 0.005 1.76 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.5. Grading (2026) - Unmitigated

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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

3.62 3.04 27.2 27.6 0.06 1.12 — 1.12 1.03 — 1.03 — 6,599 6,599 0.27 0.05 — 6,621 Dust
From
Material
Movement
— — — — — — 3.59 3.59 — 1.42 1.42 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

3.62 3.04 27.2 27.6 0.06 1.12 — 1.12 1.03 — 1.03 — 6,599 6,599 0.27 0.05 — 6,621 Dust
From
Material
Movement
— — — — — — 3.59 3.59 — 1.42 1.42 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.09 0.92 8.20 8.31 0.02 0.34 — 0.34 0.31 — 0.31 — 1,989 1,989 0.08 0.02 — 1,995

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Dust — — — — — — 1.08 1.08 — 0.43 0.43 — — — — — — —
From
Material
Movement
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.20 0.17 1.50 1.52 < 0.005 0.06 — 0.06 0.06 — 0.06 — 329 329 0.01 < 0.005 — 330 Dust
From
Material
Movement
— — — — — — 0.20 0.20 — 0.08 0.08 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.08 0.08 0.04 0.68 0.00 0.00 0.11 0.11 0.00 0.03 0.03 — 119 119 < 0.005 0.01 0.41 121 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.07 0.07 0.05 0.55 0.00 0.00 0.11 0.11 0.00 0.03 0.03 — 105 105 < 0.005 0.01 0.01 107 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.02 0.02 0.01 0.17 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 32.9 32.9 < 0.005 < 0.005 0.05 33.4 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

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Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 5.45 5.45 < 0.005 < 0.005 0.01 5.54 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.7. Building Construction (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.28 1.07 9.85 13.0 0.02 0.38 — 0.38 0.35 — 0.35 — 2,397 2,397 0.10 0.02 — 2,405 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.14 0.11 1.04 1.37 < 0.005 0.04 — 0.04 0.04 — 0.04 — 253 253 0.01 < 0.005 — 254 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —

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Off-Roa 0.02 0.02 0.19 0.25 < 0.005 0.01 — 0.01 0.01 — 0.01 — 41.9 41.9 < 0.005 < 0.005 — 42.1 d
Equipm
ent
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 4.33 4.20 3.01 32.9 0.00 0.00 6.47 6.47 0.00 1.52 1.52 — 6,265 6,265 0.26 0.31 0.63 6,364 Vendor 0.18 0.11 3.86 1.69 0.02 0.03 0.59 0.62 0.03 0.16 0.19 — 2,282 2,282 0.05 0.34 0.14 2,386 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.48 0.45 0.29 3.54 0.00 0.00 0.67 0.67 0.00 0.16 0.16 — 686 686 0.02 0.03 1.12 697 Vendor 0.02 0.01 0.40 0.17 < 0.005 < 0.005 0.06 0.07 < 0.005 0.02 0.02 — 241 241 0.01 0.04 0.24 252 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.09 0.08 0.05 0.65 0.00 0.00 0.12 0.12 0.00 0.03 0.03 — 114 114 < 0.005 0.01 0.18 115 Vendor < 0.005 < 0.005 0.07 0.03 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 39.9 39.9 < 0.005 0.01 0.04 41.7 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.9. Building Construction (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —

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Daily,——————————————————
Summer
(Max)
Off-Roa d
Equipm
ent

1.23 1.03 9.39 12.9 0.02 0.34— 0.34 0.31— 0.31— 2,397 2,397 0.10 0.02— 2,405 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
——————————————————
Off-Roa d
Equipm
ent

1.23 1.03 9.39 12.9 0.02 0.34— 0.34 0.31— 0.31— 2,397 2,397 0.10 0.02— 2,405 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
——————————————————
Off-Roa d
Equipm
ent

0.88 0.74 6.71 9.24 0.02 0.24— 0.24 0.22— 0.22— 1,712 1,712 0.07 0.01— 1,718 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Annual——————————————————
Off-Roa d
Equipm
ent

0.16 0.13 1.22 1.69 < 0.005 0.04— 0.04 0.04— 0.04— 283 283 0.01 < 0.005— 284 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Offsite——————————————————
Daily,
Summer
(Max)
——————————————————

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Worker 4.57 4.47 2.20 37.6 0.00 0.00 6.47 6.47 0.00 1.52 1.52 — 6,910 6,910 0.18 0.28 22.1 7,020 Vendor 0.19 0.12 3.50 1.57 0.02 0.03 0.59 0.62 0.03 0.16 0.19 — 2,229 2,229 0.05 0.33 4.67 2,333 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 4.07 3.77 2.73 30.5 0.00 0.00 6.47 6.47 0.00 1.52 1.52 — 6,136 6,136 0.26 0.31 0.57 6,235 Vendor 0.18 0.11 3.72 1.64 0.02 0.03 0.59 0.62 0.03 0.16 0.19 — 2,234 2,234 0.05 0.33 0.12 2,333 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 2.95 2.87 1.75 22.1 0.00 0.00 4.56 4.56 0.00 1.07 1.07 — 4,539 4,539 0.15 0.22 6.82 4,615 Vendor 0.13 0.08 2.60 1.14 0.01 0.02 0.42 0.44 0.02 0.12 0.14 — 1,594 1,594 0.04 0.23 1.44 1,666 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.54 0.52 0.32 4.03 0.00 0.00 0.83 0.83 0.00 0.19 0.19 — 752 752 0.02 0.04 1.13 764 Vendor 0.02 0.02 0.47 0.21 < 0.005 < 0.005 0.08 0.08 < 0.005 0.02 0.03 — 264 264 0.01 0.04 0.24 276 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.11. Building Construction (2028) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.18 0.99 8.92 12.9 0.02 0.30 — 0.30 0.28 — 0.28 — 2,397 2,397 0.10 0.02 — 2,406

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Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 truck
Daily,
Winter
(Max)
——————————————————
Off-Roa d
Equipm
ent

1.18 0.99 8.92 12.9 0.02 0.30— 0.30 0.28— 0.28— 2,397 2,397 0.10 0.02— 2,406 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
——————————————————
Off-Roa d
Equipm
ent

0.85 0.71 6.39 9.26 0.02 0.22— 0.22 0.20— 0.20— 1,717 1,717 0.07 0.01— 1,723 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Annual——————————————————
Off-Roa d
Equipm
ent

0.15 0.13 1.17 1.69 < 0.005 0.04— 0.04 0.04— 0.04— 284 284 0.01 < 0.005— 285 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Offsite——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 4.36 4.08 1.94 35.0 0.00 0.00 6.47 6.47 0.00 1.52 1.52— 6,776 6,776 0.18 0.28 19.9 6,884 Vendor 0.17 0.12 3.40 1.53 0.02 0.03 0.59 0.62 0.03 0.16 0.19— 2,175 2,175 0.05 0.33 4.12 2,278 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
——————————————————

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Worker 3.89 3.58 2.48 28.3 0.00 0.00 6.47 6.47 0.00 1.52 1.52 — 6,019 6,019 0.24 0.31 0.52 6,117 Vendor 0.16 0.11 3.61 1.60 0.02 0.03 0.59 0.62 0.03 0.16 0.19 — 2,179 2,179 0.05 0.33 0.11 2,278 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 2.82 2.60 1.57 20.6 0.00 0.00 4.57 4.57 0.00 1.07 1.07 — 4,465 4,465 0.15 0.20 6.16 4,534 Vendor 0.12 0.08 2.52 1.11 0.01 0.02 0.42 0.44 0.02 0.12 0.14 — 1,559 1,559 0.04 0.23 1.27 1,631 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.52 0.48 0.29 3.77 0.00 0.00 0.83 0.83 0.00 0.20 0.20 — 739 739 0.02 0.03 1.02 751 Vendor 0.02 0.02 0.46 0.20 < 0.005 < 0.005 0.08 0.08 < 0.005 0.02 0.03 — 258 258 0.01 0.04 0.21 270 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.13. Building Construction (2029) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.15 0.97 8.58 12.9 0.02 0.28 — 0.28 0.25 — 0.25 — 2,397 2,397 0.10 0.02 — 2,405 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —

City of Clovis Rezone Detailed Report, 7/14/2025
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Off-Roa 1.15 0.97 8.58 12.9 0.02 0.28 — 0.28 0.25 — 0.25 — 2,397 2,397 0.10 0.02 — 2,405 d
Equipm
ent
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.82 0.69 6.13 9.22 0.02 0.20 — 0.20 0.18 — 0.18 — 1,712 1,712 0.07 0.01 — 1,718 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.15 0.13 1.12 1.68 < 0.005 0.04 — 0.04 0.03 — 0.03 — 283 283 0.01 < 0.005 — 284 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 4.10 3.82 1.72 32.7 0.00 0.00 6.47 6.47 0.00 1.52 1.52 — 6,651 6,651 0.16 0.28 17.8 6,756 Vendor 0.16 0.10 3.27 1.50 0.02 0.03 0.59 0.62 0.03 0.16 0.19 — 2,117 2,117 0.05 0.31 3.63 2,215 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 3.68 3.37 2.25 26.4 0.00 0.00 6.47 6.47 0.00 1.52 1.52 — 5,909 5,909 0.24 0.31 0.46 6,007 Vendor 0.16 0.09 3.48 1.57 0.02 0.03 0.59 0.62 0.03 0.16 0.19 — 2,121 2,121 0.05 0.31 0.09 2,216 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

City of Clovis Rezone Detailed Report, 7/14/2025
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Average — — — — — — — — — — — — — — — — — —
Daily
Worker 2.65 2.43 1.41 19.1 0.00 0.00 4.56 4.56 0.00 1.07 1.07 — 4,371 4,371 0.13 0.20 5.48 4,439 Vendor 0.12 0.07 2.42 1.09 0.01 0.02 0.42 0.44 0.02 0.12 0.14 — 1,513 1,513 0.04 0.22 1.12 1,582 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.48 0.44 0.26 3.49 0.00 0.00 0.83 0.83 0.00 0.19 0.19 — 724 724 0.02 0.03 0.91 735 Vendor 0.02 0.01 0.44 0.20 < 0.005 < 0.005 0.08 0.08 < 0.005 0.02 0.03 — 251 251 0.01 0.04 0.18 262 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.15. Building Construction (2030) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.12 0.94 8.39 12.9 0.02 0.26 — 0.26 0.24 — 0.24 — 2,397 2,397 0.10 0.02 — 2,405 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.12 0.94 8.39 12.9 0.02 0.26 — 0.26 0.24 — 0.24 — 2,397 2,397 0.10 0.02 — 2,405 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

City of Clovis Rezone Detailed Report, 7/14/2025
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Average — — — — — — — — — — — — — — — — — —
Daily
Off-Roa
d
Equipm
ent

0.80 0.67 5.99 9.20 0.02 0.19 — 0.19 0.17 — 0.17 — 1,712 1,712 0.07 0.01 — 1,718 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.15 0.12 1.09 1.68 < 0.005 0.03 — 0.03 0.03 — 0.03 — 283 283 0.01 < 0.005 — 284 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 3.89 3.61 1.66 30.4 0.00 0.00 6.47 6.47 0.00 1.52 1.52 — 6,533 6,533 0.16 0.08 15.8 6,576 Vendor 0.16 0.10 3.18 1.48 0.02 0.03 0.59 0.62 0.03 0.16 0.19 — 2,056 2,056 0.04 0.31 3.16 2,152 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 3.27 3.16 2.00 24.6 0.00 0.00 6.47 6.47 0.00 1.52 1.52 — 5,805 5,805 0.21 0.28 0.41 5,895 Vendor 0.16 0.09 3.38 1.54 0.02 0.03 0.59 0.62 0.03 0.16 0.19 — 2,061 2,061 0.04 0.31 0.08 2,154 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 2.52 2.32 1.23 17.8 0.00 0.00 4.56 4.56 0.00 1.07 1.07 — 4,294 4,294 0.13 0.20 4.88 4,362 Vendor 0.11 0.07 2.36 1.08 0.01 0.02 0.42 0.44 0.02 0.12 0.14 — 1,470 1,470 0.03 0.22 0.98 1,537 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —

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Worker 0.46 0.42 0.22 3.25 0.00 0.00 0.83 0.83 0.00 0.19 0.19 — 711 711 0.02 0.03 0.81 722 Vendor 0.02 0.01 0.43 0.20 < 0.005 < 0.005 0.08 0.08 < 0.005 0.02 0.03 — 243 243 < 0.005 0.04 0.16 254 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.17. Building Construction (2031) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.10 0.92 8.12 12.8 0.02 0.24 — 0.24 0.22 — 0.22 — 2,397 2,397 0.10 0.02 — 2,405 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.09 0.07 0.64 1.01 < 0.005 0.02 — 0.02 0.02 — 0.02 — 188 188 0.01 < 0.005 — 188 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.02 0.01 0.12 0.18 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 31.1 31.1 < 0.005 < 0.005 — 31.2

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Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 truck
Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 3.11 3.03 1.74 22.9 0.00 0.00 6.47 6.47 0.00 1.52 1.52 — 5,710 5,710 0.18 0.28 0.36 5,799 Vendor 0.15 0.09 3.29 1.52 0.02 0.03 0.59 0.62 0.02 0.16 0.18 — 1,998 1,998 0.04 0.30 0.07 2,087 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.25 0.24 0.13 1.83 0.00 0.00 0.50 0.50 0.00 0.12 0.12 — 463 463 0.01 0.01 0.47 465 Vendor 0.01 0.01 0.25 0.12 < 0.005 < 0.005 0.05 0.05 < 0.005 0.01 0.01 — 156 156 < 0.005 0.02 0.09 163 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.04 0.04 0.02 0.33 0.00 0.00 0.09 0.09 0.00 0.02 0.02 — 76.6 76.6 < 0.005 < 0.005 0.08 77.1 Vendor < 0.005 < 0.005 0.05 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 25.9 25.9 < 0.005 < 0.005 0.02 27.0 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.19. Paving (2031) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —

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Off-Roa 0.75 0.63 6.13 9.88 0.01 0.21 — 0.21 0.19 — 0.19 — 1,511 1,511 0.06 0.01 — 1,516 d
Equipm
ent
Paving 0.00 0.00 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.75 0.63 6.13 9.88 0.01 0.21 — 0.21 0.19 — 0.19 — 1,511 1,511 0.06 0.01 — 1,516 Paving 0.00 0.00 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.15 0.13 1.26 2.03 < 0.005 0.04 — 0.04 0.04 — 0.04 — 310 310 0.01 < 0.005 — 311 Paving 0.00 0.00 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.03 0.02 0.23 0.37 < 0.005 0.01 — 0.01 0.01 — 0.01 — 51.4 51.4 < 0.005 < 0.005 — 51.6 Paving 0.00 0.00 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —

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Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.04 0.04 0.02 0.36 0.00 0.00 0.08 0.08 0.00 0.02 0.02 — 81.1 81.1 < 0.005 < 0.005 0.18 81.6 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.04 0.04 0.02 0.29 0.00 0.00 0.08 0.08 0.00 0.02 0.02 — 72.1 72.1 < 0.005 < 0.005 < 0.005 73.2 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 < 0.005 0.06 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 15.3 15.3 < 0.005 < 0.005 0.02 15.4 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.54 2.54 < 0.005 < 0.005 < 0.005 2.55 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.21. Architectural Coating (2029) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —

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Off-Roa 0.12 0.10 0.79 1.11 < 0.005 0.01 — 0.01 0.01 — 0.01 — 134 134 0.01 < 0.005 — 134 d
Equipm
Architect
ural
Coating
s

16.7 16.7 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.12 0.10 0.79 1.11 < 0.005 0.01 — 0.01 0.01 — 0.01 — 134 134 0.01 < 0.005 — 134 Architect
ural
Coating
s

16.7 16.7 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.05 0.04 0.33 0.47 < 0.005 0.01 — 0.01 < 0.005 — < 0.005 — 55.9 55.9 < 0.005 < 0.005 — 56.1 Architect
ural
Coating
s

7.01 7.01 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —

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Off-Roa 0.01 0.01 0.06 0.09 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 9.26 9.26 < 0.005 < 0.005 — 9.29 d
Equipm
ent
Architect
ural
Coating
s

1.28 1.28 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.82 0.76 0.34 6.53 0.00 0.00 1.29 1.29 0.00 0.30 0.30 — 1,330 1,330 0.03 0.06 3.56 1,351 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.74 0.67 0.45 5.29 0.00 0.00 1.29 1.29 0.00 0.30 0.30 — 1,182 1,182 0.05 0.06 0.09 1,201 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.31 0.28 0.17 2.24 0.00 0.00 0.53 0.53 0.00 0.13 0.13 — 513 513 0.02 0.02 0.64 521 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.06 0.05 0.03 0.41 0.00 0.00 0.10 0.10 0.00 0.02 0.02 — 84.9 84.9 < 0.005 < 0.005 0.11 86.2 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

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3.23. Architectural Coating (2030) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.12 0.10 0.78 1.11 < 0.005 0.01 — 0.01 0.01 — 0.01 — 134 134 0.01 < 0.005 — 134 Architect
ural
Coating
s

16.7 16.7 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.12 0.10 0.78 1.11 < 0.005 0.01 — 0.01 0.01 — 0.01 — 134 134 0.01 < 0.005 — 134 Architect
ural
Coating
s

16.7 16.7 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.09 0.07 0.56 0.79 < 0.005 0.01 — 0.01 0.01 — 0.01 — 95.4 95.4 < 0.005 < 0.005 — 95.7

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Architect
Coatings

11.9 11.9 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.02 0.01 0.10 0.14 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 15.8 15.8 < 0.005 < 0.005 — 15.8 Architect
ural
Coating
s

2.18 2.18 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.78 0.72 0.33 6.07 0.00 0.00 1.29 1.29 0.00 0.30 0.30 — 1,307 1,307 0.03 0.02 3.16 1,315 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.65 0.63 0.40 4.93 0.00 0.00 1.29 1.29 0.00 0.30 0.30 — 1,161 1,161 0.04 0.06 0.08 1,179 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.50 0.46 0.25 3.56 0.00 0.00 0.91 0.91 0.00 0.21 0.21 — 859 859 0.03 0.04 0.98 872 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —

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Worker 0.09 0.08 0.04 0.65 0.00 0.00 0.17 0.17 0.00 0.04 0.04 — 142 142 < 0.005 0.01 0.16 144 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.25. Architectural Coating (2031) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.12 0.10 0.78 1.10 < 0.005 0.01 — 0.01 0.01 — 0.01 — 134 134 0.01 < 0.005 — 134 Architect
ural
Coating
s

16.7 16.7 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.12 0.10 0.78 1.10 < 0.005 0.01 — 0.01 0.01 — 0.01 — 134 134 0.01 < 0.005 — 134 Architect
ural
Coating
s

16.7 16.7 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

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Average — — — — — — — — — — — — — — — — — —
Daily
Off-Roa
d
Equipm
ent

0.06 0.05 0.38 0.54 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 65.8 65.8 < 0.005 < 0.005 — 66.1 Architect
ural
Coating
s

8.25 8.25 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.01 0.01 0.07 0.10 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 10.9 10.9 < 0.005 < 0.005 — 10.9 Architect
ural
Coating
s

1.51 1.51 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.69 0.67 0.29 5.70 0.00 0.00 1.29 1.29 0.00 0.30 0.30 — 1,285 1,285 0.03 0.02 2.80 1,293 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.62 0.61 0.35 4.58 0.00 0.00 1.29 1.29 0.00 0.30 0.30 — 1,142 1,142 0.04 0.06 0.07 1,160 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

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Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.31 0.30 0.17 2.30 0.00 0.00 0.63 0.63 0.00 0.15 0.15 — 583 583 0.02 0.01 0.59 586 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.06 0.06 0.03 0.42 0.00 0.00 0.11 0.11 0.00 0.03 0.03 — 96.6 96.6 < 0.005 < 0.005 0.10 97.1 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated
Mobile source emissions results are presented in Sections 2.6. No further detailed breakdown of emissions is available.

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — — 4,538 4,538 0.73 0.09 — 4,583
Total — — — — — — — — — — — — 4,538 4,538 0.73 0.09 — 4,583

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Daily, — — — — — — — — — — — — — — — — — —
Winter
(Max)
Apartme
nts
Mid Rise
— — — — — — — — — — — — 4,538 4,538 0.73 0.09 — 4,583
Total — — — — — — — — — — — — 4,538 4,538 0.73 0.09 — 4,583 Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — — 751 751 0.12 0.01 — 759
Total — — — — — — — — — — — — 751 751 0.12 0.01 — 759

4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise

1.23 0.61 10.5 4.46 0.07 0.85 — 0.85 0.85 — 0.85 — 13,311 13,311 1.18 0.03 — 13,348 Total 1.23 0.61 10.5 4.46 0.07 0.85 — 0.85 0.85 — 0.85 — 13,311 13,311 1.18 0.03 — 13,348 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise

1.23 0.61 10.5 4.46 0.07 0.85 — 0.85 0.85 — 0.85 — 13,311 13,311 1.18 0.03 — 13,348 Total 1.23 0.61 10.5 4.46 0.07 0.85 — 0.85 0.85 — 0.85 — 13,311 13,311 1.18 0.03 — 13,348 Annual — — — — — — — — — — — — — — — — — —

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Apartme 0.22 0.11 1.91 0.81 0.01 0.15 — 0.15 0.15 — 0.15 — 2,204 2,204 0.20 < 0.005 — 2,210 nts
Mid Rise
Total 0.22 0.11 1.91 0.81 0.01 0.15 — 0.15 0.15 — 0.15 — 2,204 2,204 0.20 < 0.005 — 2,210

4.3. Area Emissions by Source

4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Consum
er
Product
s

33.9 33.9 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s

2.72 2.72 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent

8.55 8.09 0.87 94.0 < 0.005 0.04 — 0.04 0.03 — 0.03 — 250 250 0.01 < 0.005 — 251 Total 45.2 44.7 0.87 94.0 < 0.005 0.04 — 0.04 0.03 — 0.03 0.00 250 250 0.01 < 0.005 — 251 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Consum
er
Product
s

33.9 33.9 — — — — — — — — — — — — — — — —

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Architect
Coatings

2.72 2.72 — — — — — — — — — — — — — — — —
Total 36.6 36.6 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Annual — — — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 Consum
er
Product
s

6.19 6.19 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s

0.50 0.50 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent

0.77 0.73 0.08 8.46 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 20.4 20.4 < 0.005 < 0.005 — 20.5 Total 7.46 7.41 0.08 8.46 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 20.4 20.4 < 0.005 < 0.005 — 20.5

4.4. Water Emissions by Land Use

4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — 138 142 280 0.50 0.30 — 383
Total — — — — — — — — — — — 138 142 280 0.50 0.30 — 383 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —

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Apartme
Mid Rise
— — — — — — — — — — — 138 142 280 0.50 0.30 — 383
Total — — — — — — — — — — — 138 142 280 0.50 0.30 — 383 Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — 22.8 23.5 46.3 0.08 0.05 — 63.4
Total — — — — — — — — — — — 22.8 23.5 46.3 0.08 0.05 — 63.4

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — 576 0.00 576 57.5 0.00 — 2,014
Total — — — — — — — — — — — 576 0.00 576 57.5 0.00 — 2,014 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — 576 0.00 576 57.5 0.00 — 2,014
Total — — — — — — — — — — — 576 0.00 576 57.5 0.00 — 2,014 Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — 95.3 0.00 95.3 9.53 0.00 — 333
Total — — — — — — — — — — — 95.3 0.00 95.3 9.53 0.00 — 333

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4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — — — — — — 11.4 11.4
Total — — — — — — — — — — — — — — — — 11.4 11.4
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — — — — — — 11.4 11.4
Total — — — — — — — — — — — — — — — — 11.4 11.4
Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Mid Rise
— — — — — — — — — — — — — — — — 1.88 1.88
Total — — — — — — — — — — — — — — — — 1.88 1.88

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e

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Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetati
on
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

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4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —

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Daily, — — — — — — — — — — — — — — — — — —
Winter
(Max)
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —

5. Activity Data

5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Demolition Demolition 1/1/2026 4/9/2026 5.00 70.0 —
Site Preparation Site Preparation 4/10/2026 6/5/2026 5.00 40.0 — Grading Grading 6/6/2026 11/7/2026 5.00 110 —

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Building Construction Building Construction 11/8/2026 2/9/2031 5.00 1,110 — Paving Paving 2/10/2031 5/26/2031 5.00 75.0 —
Architectural Coating Architectural Coating 6/1/2029 9/9/2031 5.00 593 —

5.2. Off-Road Equipment

5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Concrete/Industrial
Saws
Diesel Average 1.00 8.00 33.0 0.73
Demolition Excavators Diesel Average 3.00 8.00 36.0 0.38 Demolition Rubber Tired Dozers Diesel Average 2.00 8.00 367 0.40 Site Preparation Rubber Tired Dozers Diesel Average 3.00 8.00 367 0.40 Site Preparation Tractors/Loaders/Back
hoes
Diesel Average 4.00 8.00 84.0 0.37
Grading Excavators Diesel Average 2.00 8.00 36.0 0.38
Grading Graders Diesel Average 1.00 8.00 148 0.41
Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Grading Scrapers Diesel Average 2.00 8.00 423 0.48
Grading Tractors/Loaders/Back
hoes
Diesel Average 2.00 8.00 84.0 0.37
Building Construction Cranes Diesel Average 1.00 7.00 367 0.29 Building Construction Forklifts Diesel Average 3.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Tractors/Loaders/Back
hoes
Diesel Average 3.00 7.00 84.0 0.37
Building Construction Welders Diesel Average 1.00 8.00 46.0 0.45 Paving Pavers Diesel Average 2.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Average 2.00 8.00 89.0 0.36 Paving Rollers Diesel Average 2.00 8.00 36.0 0.38

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Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition — — — —
Demolition Worker 15.0 7.70 LDA,LDT1,LDT2
Demolition Vendor — 4.00 HHDT,MHDT
Demolition Hauling 0.00 20.0 HHDT
Demolition Onsite truck — — HHDT
Site Preparation — — — —
Site Preparation Worker 17.5 7.70 LDA,LDT1,LDT2
Site Preparation Vendor — 4.00 HHDT,MHDT
Site Preparation Hauling 0.00 20.0 HHDT
Site Preparation Onsite truck — — HHDT
Grading — — — —
Grading Worker 20.0 7.70 LDA,LDT1,LDT2
Grading Vendor — 4.00 HHDT,MHDT
Grading Hauling 0.00 20.0 HHDT
Grading Onsite truck — — HHDT
Building Construction — — — —
Building Construction Worker 1,189 7.70 LDA,LDT1,LDT2
Building Construction Vendor 176 4.00 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck — — HHDT
Paving — — — —
Paving Worker 15.0 7.70 LDA,LDT1,LDT2

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Paving Vendor — 4.00 HHDT,MHDT
Paving Hauling 0.00 20.0 HHDT
Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 238 7.70 LDA,LDT1,LDT2
Architectural Coating Vendor — 4.00 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck — — HHDT

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies
Control Strategies Applied PM10 Reduction PM2.5 Reduction Water unpaved roads twice daily 55% 55%
Limit vehicle speeds on unpaved roads to 25 mph 44% 44%

5.5. Architectural Coatings
Phase Name Residential Interior Area
Coated (sq ft)
Residential Exterior Area
Coated (sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
Architectural Coating 3,209,544 1,069,848 0.00 0.00 —

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (cy) Material Exported (cy) Acres Graded (acres) Material Demolished (sq. ft.) Acres Paved (acres) Demolition 0.00 0.00 0.00 — —
Site Preparation — — 60.0 0.00 —
Grading — — 330 0.00 —

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Paving 0.00 0.00 0.00 0.00 —

5.6.2. Construction Earthmoving Control Strategies
Control Strategies Applied Frequency (per day) PM10 Reduction PM2.5 Reduction Water Exposed Area 2 61% 61%

5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Apartments Mid Rise — 0%

5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2026 0.00 204 0.03 < 0.005
2027 0.00 204 0.03 < 0.005
2028 0.00 204 0.03 < 0.005
2029 0.00 204 0.03 < 0.005
2030 0.00 204 0.03 < 0.005
2031 0.00 204 0.03 < 0.005

5.9. Operational Mobile Sources

5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Total all Land Uses 0.00 0.00 0.00 0.00 82,317 82,317 82,317 30,045,705

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5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated
Hearth Type Unmitigated (number)
Apartments Mid Rise —
Wood Fireplaces 0
Gas Fireplaces 0
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 0
Conventional Wood Stoves 0
Catalytic Wood Stoves 0
Non-Catalytic Wood Stoves 0
Pellet Wood Stoves 0

5.10.2. Architectural Coatings
Residential Interior Area Coated (sq
ft)
Residential Exterior Area Coated (sq
ft)
Non-Residential Interior Area Coated
(sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
3209544 1,069,848 0.00 0.00 —

5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 180

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5.11. Operational Energy Consumption

5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Apartments Mid Rise 8,120,932 204 0.0330 0.0040 41,533,746

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Apartments Mid Rise 64,513,896 0.00

5.13. Operational Waste Generation

5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Apartments Mid Rise 1,068 —

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Apartments Mid Rise Average room A/C &
Other residential A/C
and heat pumps
R-410A 2,088 < 0.005 2.50 2.50 10.0
Apartments Mid Rise Household
refrigerators and/or
freezers
R-134a 1,430 0.12 0.60 0.00 1.00

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5.15. Operational Off-Road Equipment

5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor

5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr)

5.17. User Defined
Equipment Type Fuel Type

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

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5.18.2. Sequestration

5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

6. Climate Risk Detailed Report

6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.

Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 32.1 annual days of extreme heat Extreme Precipitation 1.25 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
Wildfire 0.00 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events. Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise N/A N/A N/A N/A

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Wildfire N/A N/A N/A N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation N/A N/A N/A N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.

6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise N/A N/A N/A N/A
Wildfire N/A N/A N/A N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation N/A N/A N/A N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

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7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.

Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 88.7
AQ-PM 96.7
AQ-DPM 76.2
Drinking Water 47.6
Lead Risk Housing 54.2
Pesticides 0.00
Toxic Releases 64.2
Traffic 44.4
Effect Indicators —
CleanUp Sites 70.2
Groundwater 0.00
Haz Waste Facilities/Generators 84.8
Impaired Water Bodies 0.00
Solid Waste 0.00
Sensitive Population —
Asthma 93.4
Cardio-vascular 61.8
Low Birth Weights 82.9
Socioeconomic Factor Indicators —
Education 53.6
Housing 44.5
Linguistic 34.6
Poverty 75.7
Unemployment 60.6

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7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

Indicator Result for Project Census Tract
Economic —
Above Poverty 25.79237777
Employed 68.92082638
Median HI 17.77235981
Education —
Bachelor's or higher 27.90966252
High school enrollment 100
Preschool enrollment 1.873476197
Transportation —
Auto Access 19.3763634
Active commuting 31.77210317
Social —
2-parent households 53.52239189
Voting 27.71718209
Neighborhood —
Alcohol availability 35.32657513
Park access 59.42512511
Retail density 77.28730912
Supermarket access 36.23764917
Tree canopy 23.29013217
Housing —
Homeownership 20.76222251
Housing habitability 68.61285769
Low-inc homeowner severe housing cost burden 97.5875786 Low-inc renter severe housing cost burden 65.39201848

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Uncrowded housing 74.48992686
Health Outcomes —
Insured adults 43.11561658
Arthritis 8.9
Asthma ER Admissions 6.6
High Blood Pressure 15.4
Cancer (excluding skin) 15.0
Asthma 27.9
Coronary Heart Disease 9.8
Chronic Obstructive Pulmonary Disease 15.6
Diagnosed Diabetes 40.6
Life Expectancy at Birth 6.8
Cognitively Disabled 26.7
Physically Disabled 11.7
Heart Attack ER Admissions 23.7
Mental Health Not Good 39.0
Chronic Kidney Disease 14.8
Obesity 49.0
Pedestrian Injuries 50.1
Physical Health Not Good 38.5
Stroke 17.3
Health Risk Behaviors —
Binge Drinking 45.1
Current Smoker 47.6
No Leisure Time for Physical Activity 36.0
Climate Change Exposures —
Wildfire Risk 0.0
SLR Inundation Area 0.0

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Children 82.0
Elderly 17.2
English Speaking 92.8
Foreign-born 4.0
Outdoor Workers 21.2
Climate Change Adaptive Capacity —
Impervious Surface Cover 28.4
Traffic Density 38.4
Traffic Access 0.0
Other Indices —
Hardship 55.2
Other Decision Support —
2016 Voting 25.8

7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 78.0 Healthy Places Index Score for Project Location (b) 25.0 Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Project Located in a Low-Income Community (Assembly Bill 1550) Yes Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

7.4. Health & Equity Measures
No Health & Equity Measures selected.

7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.

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7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.

8. User Changes to Default Data
Screen Justification
Land Use Consistent with Project Description. Population based on pph of 2.8 (DOF 2025).

Construction: Construction Phases Conservatively assumes construction occurs in one phase, architectural coating starts in the middle of the building construction phase.

Operations: Hearths No wood stoves or fireplaces
Operations: Water and Waste Water WTP 100% aerobic

Appendix B
Air Quality (AQ) 2

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City of Clovis Rezone - Site 3 Detailed Report
Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds

2.2. Construction Emissions by Year, Unmitigated

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

3. Construction Emissions Details

3.1. Demolition (2026) - Unmitigated

3.3. Site Preparation (2026) - Unmitigated

3.5. Grading (2026) - Unmitigated

3.7. Building Construction (2026) - Unmitigated

3.9. Building Construction (2027) - Unmitigated

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3.11. Paving (2027) - Unmitigated

3.13. Architectural Coating (2026) - Unmitigated

3.15. Architectural Coating (2027) - Unmitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated

4.7. Offroad Emissions By Equipment Type

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4.7.1. Unmitigated

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

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5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities

5.6.2. Construction Earthmoving Control Strategies

5.7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.9. Operational Mobile Sources

5.9.1. Unmitigated

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated

5.13. Operational Waste Generation

5.13.1. Unmitigated

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5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

6. Climate Risk Detailed Report

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

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6.3. Adjusted Climate Risk Scores

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores

7.2. Healthy Places Index Scores

7.3. Overall Health & Equity Scores

7.4. Health & Equity Measures

7.5. Evaluation Scorecard

7.6. Health & Equity Custom Measures

8. User Changes to Default Data