Fresno City Council
March 30, 2023

Exhibit H – Environmental Assessment (Including Studies)

1 ENVIRONMENTAL CHECKLIST IN SUPPORT OF CEQA GUIDELINES SECTION 15183

STREAMLINE

PROJECT CONSISTENT WITH A COMMUNITY PLAN OR ZONING
Environmental Checklist Form for:

Development Permit Application No. P22-00565

1. Project title:

Development Permit Application No. P22-00565

2. Lead agency name and address:

City of Fresno
Planning and Development Department
2600 Fresno Street
Fresno, CA 93721

3. Contact person and phone number:

Thomas Veatch, Planner
City of Fresno
Planning and Development Department
(559) 621-8076
[email protected]

4. Project location:
791 & 998 E. North Avenue
Fresno, CA 93725
The proposed Project is located on two parcels at 791 and 998 E. North Avenue on the southwest corner of E. North Avenue and at S. East Avenue Streets in the City of Fresno, in Fresno County, California. Local access is provided from E North Avenue located to the north of the Project site and S. East Avenue located to the east of the Project site. Regional access to the Project site is provided State Route 57 (SR-41) approximately 0.65 mile to the west, State Route 99 (SR-99) approximately 0.85 mile to the east, which merges with SR-41 to the north in the area of the Project site. (APN: 329-090-16 & 329-090-17)

5. Project sponsor's name and address:

Lone Oak – Fresno, LLC
6250 N. River Road
Rosemont, IL 60018
2 6. General & Community plan land use designation:

Employment – Heavy Industrial (IH)

7. Zoning:

Heavy Industrial District/Urban Growth Management (IH/UGM)

8. Description of project:

Development Permit Application No. P22-00565 was filed by Lone Oak – Fresno, LLC (applicant). The applicant proposes to develop an approximately 205,000 square-foot warehouse building including approximately 23,000 square-feet of ancillary office space on two vacant parcels, Fresno County Assessor’s Parcel Number (APN) 329- 090-16 (7.44 acres) and 329-090-17 (7.39 acres), totaling 14.78-gross-acres. The site is located at the southwest corner of E. North Avenue and at S. East Avenue Streets in the City of Fresno. See Figure 1, Regional View. The Project site is relatively flat with elevations of about 284 feet above mean sea level (AMSL) and currently undeveloped covered with grassy vegetation. Vehicular access to the Project site is provided from unpaved driveway at S. East Avenue. See Figure 2, Aerial View. The Project also includes approximately 40,300 square-feet of additional warehouse space that would be constructed as part of a later phase. Additional improvements include 273 passenger vehicle parking spaces, 54 truck-trailer spaces, a clear height of 36’ starting at the speed bay, 29 dock-high doors, a truck wash and truck maintenance shop attached to the warehouse space, a small outdoor patio space, and stormwater/water quality management areas. The building would be fully air conditioned through natural and mechanical means to maintain temperatures between 45-85F, and would be used for Food and Beverage Industrial Storage Space and beverage distribution. The yard would be fully secured with rolling gates and fences, with full access from both E. North Avenue and S. East Avenue. Project grading would require 10,460 cubic yards of cut and 15,980 cubic yards of fill, necessitating 5,520 cubic yards of soil export. The Project is consistent with the underlying General Plan (GP) land use designation of Employment – Heavy Industrial (IH) and Heavy Industrial District/Urban Growth Management (IH/UGM) zoning for the site. Project entitlements include a Development Permit.

The front façade of the building would be oriented toward S. East Avenue, with loading dock activity in the rear of the building facing the southern adjacent development. Main building entrances are proposed, one in the northeast corner at the front façade and one in the southwest corner of the building. Additional, entrances are located along the east and south portions of the building. The site plan is illustrated on Figure 3, Conceptual Site Plan.
3 Architectural Design
The building incorporates a modern warehouse architectural design. The building exterior would be constructed with tilt-up concrete wall panels consisting of a primarily grey color palette, with accented wall panels of light and dark grays and white accent roof lines along the top of the light gray wall panels. The building would be approximately 43 feet 10 inches tall with varying roof lines to break up the perception of massing. Windows would be fitted with tinted light blue glass. The main building entrance would include metal canopy on the exterior of the building. The elevations and conceptual rendering of the building are illustrated on Figure 4, Proposed Elevations, and Figure 5, Conceptual Rendering.

Landscaping and Fencing
Landscaping is proposed along the entire site perimeter and throughout the Project site. Along the site’s E. North Avenue and S. East Avenue frontages, layered landscaping consisting of 15-inch box street trees, followed by 15-inch box backdrop trees, shrubs and assorted ground cover is proposed. In addition to landscaping along the site perimeter, trees and shrubs are proposed along the building perimeter.

Additionally, 15-inch box canopy trees are proposed at the driveway entrances, drive aisles and throughout the parking lot. To create visual interest, the landscaping palate includes assorted climate-appropriate ornamental trees, shrubs, and groundcover ranging from moderate to low water needs. Tree species include Deodar Cedar, Common Hackberry, Crape Myrtle, Saratoga Laurel, London Planetree, Interior Live Oak, and Chinese Elm. Additionally, all ground mounted utility equipment including air conditioners, transformers, backflow preventers, or similar equipment shall be screened with shrubs.

The yard would be fully secured with rolling gates and wrought iron fences, with ingress and egress from both E. North Avenue and S. East Avenue. In addition, the existing 6-feet chain link fences bordering the south and west portions of the Project would remain.

Lighting
The Project would include new exterior lighting for security, to accent the landscaping, and to light signage, walkways, and parking areas. Approximately 14 light pole fixtures and approximately 30 wall-mounted light fixtures are proposed on the exterior of the building, including 10 fixtures in the loading dock area in the rear of the building. The new lighting would be focused on the site, shielded away from offsite areas in conformance with the lighting requirements set forth in City of Fresno Municipal Code (FMC) Section 15-2508.
4 Access and Circulation
Vehicular access to the Project site is provided from E. North Avenue and S. East Avenue. Along E. North Avenue, vehicular access is provided by a 40-foot-wide driveway near the northwest portion Project site. In addition, a 36-foot-wide driveway is at the northern portion of the Project site. Along S. East Avenue at the southeast portion of the Project site is a 35-foot-wide driveway.

Onsite circulation includes a 34-foot-wide (minimum) drive aisle that goes around the building (to the south), connecting to both proposed driveways (northwest and southeast driveways). This drive aisle would provide vehicular access to the parking areas and loading docks in the rear of the building and would serve as the onsite fire lane where parking would be prohibited. Access to the loading dock area would be restricted via swinging tube steel gates. The northern driveway provides access to both driveways along with access to parking and building entrance at the northeast corner of the building.

Accessible pedestrian paths of travel to the building entrances are provided around the structure with gated access to rear. Pedestrian access from S. East Avenue is provided by pathway at east northeast parking area.

Parking and Loading Docks
The Project site would include parking areas to the north of the building, to the east of the building, and along the southern perimeter near the loading docks, which includes truck trailer parking stalls. Stalls near the northeast building entrance would be reserved for clean air vehicles and electrical vehicles in conformance with requirements set forth in CALGreen Building Code Section 5.106.5.

A total of 29 dock doors are proposed along the rear of the building in the loading dock area. Additionally, two grade level loading ramps, each with a grade door, are proposed. Access to loading ramps and docks would be provided via the drive aisle accessed from the proposed driveways. Table 1, Parking Count, identifies proposed parking counts for each type of parking.

Table 1: Parking Count
Parking Type Stall Count
Standard Parking a 273
Standard Accessible Parking 7
EV Standard Accessible Parking 15
Total Provided 295
Dock Door 29
Truck Trailer Parking 54
Short-Term Parking 7
Long-Term Parking 7
Note: EV = Electric Vehicle
5 Off-Site Improvements
The Project would remove the existing curb cut for the existing driveway and include two new curb cuts for the three proposed driveways within the right-of-way along E.

North Avenue and S. East Avenue. The Project also includes the installation of a new sidewalk along within the right-of-way both E. North Avenue and S. East Avenue. No other off-site improvements, including utility infrastructure improvements, are required for construction and operation of the Project.

Construction and Phasing
Construction activities include demolition and removal of the existing curb and gutter; site preparation; grading; building construction; paving; and architectural coating.

Approximately 5,458 cubic yards of soil export is estimated to be required for the Project.

Construction activities are anticipated to last approximately 12 months, commencing in 2023, with the entire Project constructed in one phase, however an additional phase may be implemented for additional 40,300 square feet of warehouse space. The proposed building is assumed to be operational by 2024. Project construction would occur within the hours allowed by the City’s Noise Ordinance, which limits construction noise to between the hours of 7:00 A.M. and 8:00 P.M. Monday through Saturday.

Construction activities are prohibited at any time on Sunday or a federal holiday.

Operational Characteristics
Building occupant(s) are assumed to use the space for food and beverage industrial storage. The building would be fully air conditioned. For purposes of this evaluation, the proposed building is assumed to be operational 24 hours a day, 7 days a week, with exterior loading dock area and parking areas illuminated at night.

The building is designed such that business operations would be conducted within the building, except for traffic movement, parking, trailer connection and disconnection, trailer storage and the loading and unloading of trailers at designated dock doors. The outdoor cargo handling equipment used during loading, and unloading of trailers (e.g., yard trucks, hostlers, yard goats, pallet jacks, forklifts) would be non-diesel powered, per contemporary industry standards.
6 9. Surrounding land uses and setting:

Planned Land Use Existing Zoning Existing Land Use
North Heavy Industrial Heavy Industrial District
Trailer Repair /
Employment – IH
East Heavy Industrial Heavy Industrial District Distribution / Employment – IH
South Heavy Industrial Heavy Industrial District Distribution / Employment – IH
West Heavy Industrial Heavy Industrial District DMV / Employment – IH

10. Other public agencies whose approval is required (e.g., permits, financing approval, or participation agreement):

City of Fresno
• Development Permit P22-00565 for the use of the proposed 204,264-square-foot warehouse.

11. Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code (PRC) Section 21080.3.1? If so, has consultation begun? Pursuant to PRC Section 21080.3.1, prior to the release of any negative declaration, mitigated negative declaration or environmental impact report (EIR) for a project, the lead agency shall begin consultation with the California Native American tribe that is traditionally and culturally affiliated with the geographical area of the proposed Project.

The proposed environmental assessment is a 15183 exemption, which is consistent with the development density established by existing zoning, community plan or GP policies for which an EIR was certified. AB 52 applies to EIRs, NDs and MNDs, but not to EIR Addendums and Exemptions. Therefore, tribal consultation is not required.

However, on September 19, 2019, compliant with Assembly Bill (AB) 52 and Senate Bill (SB) 18, the City provided formal notification for the GP Program EIR (PEIR) (State Clearinghouse (SCH) #2019050005) to interested Native American tribes that may be culturally or traditionally affiliated with the Project area and vicinity to conduct consultation. According to Appendix E of the PEIR, two tribes including Dumna Wo Wah Tribal Government and Table Mountain Rancheria were formally notified regarding AB 52 consultation and 13 tribes were formally notified regarding SB 18 7 consultation. None of the 15 tribes contacted responded via letter or telephone and indicated that consultation would not be requested. No other requests for consultation were received within the 30‐day period, and as a result, AB 52 and SB 18 requirements were fulfilled for the Program EIR (SCH #2019050005).
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RCCB Fresno Distribution Warehouse Figure 1
City of Fresno
Regional View
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Aerial View
RCCB Fresno Distribution Warehouse Figure 2
City of Fresno
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RCCB Fresno Distribution Warehouse
City of Fresno
Figure 3
Conceptual Site Plan
RRR
V VDN
17'-0 40'-0"
45'-0"
27'-0"
TYP.
624'-0"
27'-0"
TYP.
310'-0"
27'-0"
TYP. 36'-0"
27'-0"
TYP.
16'-0"
34'-0 1/16" ± 149'-10 1/8"
± 200'-1 3/8"
± 225'-0 9/16"
68'-6 7/8"
± 15'-0" 55'-0" 90'-0" 65'-0"
35'-0"
27'-0"27'-0"
± 17'-9 5/8"
27'-0"
TYP.
29'-0" 124'-8"
88'-3 1/16"
27'-0"
TYP.
7 10
10 10
10 3
10 10
10 10
7 5
10 10
4 4
54 10
20 30
40 50
3 7
5 6
2 6 4
10 10
10 8
5 10
10 9
9 3
4 5
9 10
10 3
10 7

RI A NAELC/ VE

LO OP NAV

DBT GNI KR AP ON ON

GNI KRAP

NO PA RKING NO PA RKING

RI A NAELC/ VE

LO OP NAV
DBT

RI A NAELC/ VE

LO OP NAV
DBT

RI A NAELC/ VE

LO OP NAV
DBT

RI A NAELC/ VE

LO OP NAV
DBT

RI A NAELC/ VE

LO OP NAV
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DBT

RI A NAELC/ VE

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DBT

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DBT

RI A NAELC/ VE

LO OP NAV
DBT

NO PA RKING

GENERATOR
TBD
T

TRUCK EV TRUCK EV TRUCK EV TRUCK EV TRUCK EV TRUCK EV TRUCK EV TRUCK EV TRUCK EV TRUCK EV TRUCK EV TRUCK EV 9'9' LANDSCAPE BUFFER AND

STRIPED AREA

SAME WIDTH AS SINGLE STALL

TYPICAL

TYPICAL PARKING STALL
9'x19'

POSSIBLE

TRANSFORMER

LOCATION
DEF
"0'-7 "3'-1
7'-0" 1'-3" FIRE LANE (PROVIDE 20' MIN. WITH FIRE LANE FOR CDS AS REQUIRED BY FFD)POLE MOUNTED LIGHT FIXTURE.WALLPACK LIGHT FIXTURE. 1 PARKING STALL COUNT TOTAL
DOCK HIGH TRUCK DOORGRADE LEVEL TRUCK DOORFIRE HYDRANT P.I.V. WITH TAMPERTRANSFORMER WITH CONCRETE PAD. (PROVIDE PROTECTION BOLLARDS PER LOCAL UTILITY OR PUBLIC WORK STANDARDS) TACCESSIBLE PATH OF TRAVEL. 1:20 MAX. SLOPE, 2% MAX. CROSS SLOPE.LANDSCAPE AND IRRIGATION AREA.PROPERTY LINE.

PROPOSED SITE

INDUSTRIAL BUILDING
FOOTPRINT: 193,465 SF
CLR HGT: 36'-0"
TYP.1012
TYP.1005
1012
10131002
TYP.
1003
TYP.
1018 1015
1030
S. EAST AVENUE
1031
TYP.1019
TYP.
1029
TYP.1020
TYP.1035
1028
1028
TYP.
1027
1001
TYP.1007 1028
1028
TYP.1017 OUTDOOR SEATING AREA 1032
TYP.1033
TYP.1033
TYP.101410161008
TYP.
1004
1034
1028
1031
1031
TYP.2017
1033
1036
1037
TYP.
1038
TYP.
1039 1033TYP.
1040
TYP.1041
TYP.1041
1037
A-8.1
1 TYP.

A-8.1
8 A-8.1a
2 A-8.1a
11 A-8.1a
12 A-8.1a
5 TYP.

A-8.1a
16 A-8.1a
17 10421041
A-8.1a
11 TYP.

A-8.1a
12 TYP.

A-8.1a
17 TYP.

A-8.1a
17 TYP.

A-8.1a
12 TYP.
2050
P.I.V.DDCV
10431044
10 Edelman
Irvine, CA, 92618
P 949.660.9128
JOB NO.:DRAWN BY.:PA/PM:

SHEET
THESE DRAWINGS AND SPECIFICATIONS ARE THE PROPERTY AND COPYRIGHT OF WARE MALCOMB AND SHALL NOT BE USED ON ANY OTHER WORK EXCEPT BY AGREEMENT WITH WARE MALCOMB. WRITTEN DIMENSIONS SHALL TAKE PRECEDENCE OVER SCALED DIMENSIONS AND SHALL BE VERIFIED ON THE JOB SITE. ANY DISCREPANCY SHALL BE BROUGHT TO THE NOTICE OF WARE MALCOMB PRIOR TO THE COMMENCEMENT OF ANY WORK CAUTION: IF THIS SHEET IS NOT 30"x42" IT IS A REDUCED PRINT BIM 360://IRV21-5026-02_Reyes Fresno Food & Beverage Industrial/5026_ARCH.rvt A. STEVENS A.R./M.H./A.M./C.B./O.D. IRV21-5026-02

SITE PLAN
A-1.1

RCCB FRESNO DISTRIBUTION

WAREHOUSE

EAST NORTH AVENUE
FRESNO, CALIFORNIA 93725

PARKING SUMMARY
KEYNOTES:

LEGEND
SITE AREA:

GROSS: 14.78 AC
643,817 SF
BUILDING FOOTPRINT: 193,465 SFBLDG. MEZZ. AREAS AT TRUCK SHOP, RECEIVING & MAIN OFFICE: 13,416 SF TOTAL BUILDING AREA 206,881 SFBUILDING USE:

WAREHOUSE 182,103 SFOFFICE 24,778 SF
PARKING REQUIRED:WAREHOUSE THE 1ST 10K SF 1/2000 5 STALLS 1/5000 SF 34 STALLS
OFFICE 1/300 SF 83 STALLSTOTAL 122 STALLSPARKING PROVIDED:AUTO 271 STALLS @ 23.8/1000 SF
REQUIRED ACCESSIBLE STALLS 6 STALLSPROVIDED ACCESSIBLE STALLS 7 STALLS TRAILER 54 STALLSTRUCK DOCKS:DOCK HIGH DOORS 29LONG-TERM BIKE PARKING REQUIRED (5% OF VISITOR STALLS, 136 STALLS x .05) 7 STALLSLONG-TERM BIKE PARKING PROVIDED 7 STALLSSHORT-TERM BIKE PARKING (5% OF VISITOR STALLS, 136 STALLS x .05) 7 STALLSSHORT-TERM BIKE PARKING PROVIDED 7 STALLS ZONING: "IH" - HEAVY INDUSTRIAL ZONING DISTRICT
LANDSCAPE SETBACK (SEE CIVIL DRAWINGS): 10'-0" FROM NORTH & EAST PROPERTY LINE ASSESSOR'S PARCEL NO.: 329-090-16 (PARCEL 1) & 329-090-17 (PARCEL 2) - SEE ALTA SURVEY & CIVIL DRAWINGS N
0 15' 30' 60' 150'
1"=30' N
1001 PROPERTY LINE.1002 ACCESSIBLE ENTRY SIGNAGE.1003 ACCESSIBLE PARKING STALL WITH SIGNAGE.1004 VAN ACCESSIBLE PARKING STALL WITH SIGNAGE.1005 PAINTED PARKING STRIPING PER CITY STANDARDS.1007 CMU TRASH ENCLOSURE WITH RECYCLE BIN PER CITY STANDARDS.1008 ACCESSBILE PATH OF TRAVEL. 1:20 MAX. SLOPE, 2% MAX. CROSS SLOPE.
1012 LANDSCAPE AND IRRIGATION AREA.1013 POURED IN PLACE CONCRETE MONUMENT SIGN WITH GROUND MOUNTED ILLUMINATION, GRAPHICS PROVIDED BY OTHERS.
1014 PROPOSED FLAG POLES, PER STATE REQUIREMENTS.1015 PRECAST CONCRETE WHEEL STOP, TYP.1016 SHORT-TERM BICYCLE PARKING.1017 FUTURE EV LOCATION TBD,+_25% OF REQUIRED EV TO BE FULLY INSTALLED, REMAINING TO BE FOR FUTURE(STUB UP FOR PWR.)

NEED ONE STANDARD ADA EV PARKING STALL & ONE VAN ADA EVPARKING STALL, THIS IS IN ADDITION TO STANDARD NON-EVACCESIBLE STALL REQUIREMENTS 1018 LONG-TERM BICYCLE PARKING.1019 CHAINLINK FENCE.1020 CHAINLINK GATE.1027 WROUGHT IRON FENCE.1028 AUTOMATED ENTRY EXIT.1029 WROUGHT IRON MAN GATE.1030 GROUND MOUNTED EQUIPMENT, SEE LANDSCAPE FOR SCREENING & CIVIL DRAWINGS FOR UTILITIES.
1031 CONCRETE RAMP, SEE CIVIL DRAWINGS.1032 SCREEN WALL.1033 STEEL BOLLARD, CONCRETE-FILLED PAINTED SAFETY YELLOW.1034 AUTOMATION FOR EXIT. CARD READER ONLY FOR ENTRY. (NO INTERCOM).
1035 MANUAL ENTRY EXIT.1036 RETAINING WALL SLOPED 6" TO 48". SEE STRUCTURAL AND CIVIL DRAWINGS.
1037 6" CONCRETE CURB MAX. SEE CIVIL DRAWINGS.1038 LIGHT POLE.1039 GRAVEL FOR FUTURE BUILDING EXPANSION.1040 2% SLOPE CONCRETE, SEE CIVIL.1041 EV CHARGER.1042 FUTURE EV CHARGER, ELECTRICAL TO PROVIDE STUB OUT FOR FUTURE HOOKUPS & CONNECTION.
1043 POST INDICATOR VALVE (P.I.V.) , SEE CIVIL.1044 DETECTOR VALVE (DDCV) , SEE CIVIL.2017 CONCRETE RETAINING WALL, SEE CIVIL DRAWINGS.2050 STEEL SAFETY RAIL BOLTED TO SLAB.

VICINITY MAP - N.T.S. (FOR REFERENCE ONLY)
SCALE: 1" = 30'-0" 1 SITE PLAN

DATE REMARKS

02.14.2022 PLANNING SUBMITAL 01

07.21.2022 PLANNING SUBMITTAL 02
BUILDING COVERAGE 28.60 %
LANDSCAPE AREA 101,570 S.F.LANDSCAPE COVERAGE 15.78 %
2022-08-01 - PLANNING SUBMITTAL 02 - REV
TYP.1035
12 A8.1a
V VDN
310'-0"
± 149'-10 1/8"
3/8"
± 225'-0 9/16"
68'-6 7/8"
± 15'-0" 55'-0" 90'-0" 65'-0"
35'-0"
27'-0"27'-0"
± 17'-9 5/8"
88'-3 1/16"
5 10 10
4 4
54 10
20 30
40 50
3 7
5 6
2 5
10 TRUCK EV TRUCK EV TRUCK EV TRUCK EV TRUCK EV TRUCK EV TRUCK EV TRUCK EV TRUCK EV TRUCK EV TRUCK EV TRUCK EV DEF
FIRE LANE (PROVIDE 20' MIN. WITH FIRE LANE FOR CDS AS REQUIRED BY FFD)POLE MOUNTED LIGHT FIXTURE.WALLPACK LIGHT FIXTURE. 1 PARKING STALL COUNT TOTAL
DOCK HIGH TRUCK DOORGRADE LEVEL TRUCK DOORFIRE HYDRANT P.I.V. WITH TAMPERTRANSFORMER WITH CONCRETE PAD. (PROVIDE PROTECTION BOLLARDS PER LOCAL UTILITY OR PUBLIC WORK STANDARDS) TACCESSIBLE PATH OF TRAVEL. 1:20 MAX. SLOPE, 2% MAX. CROSS SLOPE.LANDSCAPE AND IRRIGATION AREA.PROPERTY LINE.

PROPOSED SITE
FOOTPRINT: 193,465 SF
CLR HGT: 36'-0"
S. EAS
1031
TYP.1007 1028
1028
TYP.1033
TYP.1033
1034
1031
1031
TYP.2017
1033
1036
1037
TYP.
1039 1033TYP.
1037
A-8.1
8 A-8.1a
2 A-8.1a
5 TYP.
10421041
A-8.1a
12 TYP.
2050
JOB NO.:DRAWN BY.:PA/PM:

SHEET
THESE DRAWINGS AND SPECIFICATIONS ARE THE PROPERTY AND COPYRIGHT OF WARE MALCOMB AND SHALL NOT BE USED ON ANY OTHER WORK EXCEPT BY AGREEMENT WITH WARE MALCOMB. WRITTEN DIMENSIONS SHALL TAKE PRECEDENCE OVER A. STEVENS A.R./M.H./A.M./C.B./O.D. IRV21-5026-02

SITE PLAN
A-1.1

RCCB FRESNO DISTRIBU

WAREHOUSE

EAST NORTH AVENUE
FRESNO, CALIFORNIA 93725
LEGEND
TRUCK DOCKS:DOCK HIGH DOORS 29LONG-TERM BIKE PARKING REQUIRED (5% OF VISITOR STALLS, 136 STALLS x .05) 7 STALLSLONG-TERM BIKE PARKING PROVIDED 7 STALLSSHORT-TERM BIKE PARKING (5% OF VISITOR STALLS, 136 STALLS x .05) 7 STALLSSHORT-TERM BIKE PARKING PROVIDED 7 STALLS ZONING: "IH" - HEAVY INDUSTRIAL ZONING DISTRICT
LANDSCAPE SETBACK (SEE CIVIL DRAWINGS): 10'-0" FROM NORTH & EAST PROPERTY LINE ASSESSOR'S PARCEL NO.: 329-090-16 (PARCEL 1) & 329-090-17 (PARCEL 2) - SEE ALTA SURVEY & CIVIL DRAWINGS N
0 15' 30' 60' 150'
1"=30' N
VICINITY MAP - N.T.S. (FOR REFERENCE ONLY)
SCALE: 1" = 30'-0" 1 SITE PLAN

DATE REMARKS

02.14.2022 PLANNING SUBMITAL 01

07.21.2022 PLANNING SUBMITTAL 02
BUILDING COVERAGE 28.60 %
LANDSCAPE AREA 101,570 S.F.LANDSCAPE COVERAGE 15.78 %
2 This page intentionally left blank.

Proposed Elevations
RCCB Fresno Distribution Warehouse Figure 4a
City of Fresno

VISION G

SPANDRE

TEMPERE
GLASS:

ALL GLASS USED ON THE ENV

VERIFY AND MEET CITY STAND

PROVIDE TEMPERED GLAZING
SPANDREL AS REQUIRED.

F.F.E.
0"
T.O.P.
41'-10"
13 12 11 10 9 8 7 6 5 4 3 2 1
SEE ELEVATION 1A SEE ELEVATION 1B
F.F.E.
0"
T.O.P.
41'-10"
13 12 11 10 9 8 7
TYP.
4016
TYP.
4001
TYP.
4005
TYP.
4012
TYP.
4020 4003
2'-0"
TYP.
4006
TYP.
4005
4029
F.F.E.
0"
T.O.P.
41'-10"
7 6 5 4 3 2 1
4014
F.F.E.
0"

A B C D E F G
T.O.P.
43'-10"
1'-8"
TYP.
4001
TYP.
4020
TYP.
4006
4010
4007 4021
C.4 D.8 E.5 F.5 1'-4"
TYP.
4016
TYP.
4022 4007 4005
TYP.
4007
4014
KEYNOTES:

LEGEND
0 15' 30' 60' 150'
1"=30'
0 8' 16' 32' 64'
1/16"=1'-0"
SCALE: 1" = 30'-0" 1 OVERALL NORTH EXTERIOR ELEVATION
SCALE: 1/16" = 1'-0" 1A PARTIAL NORTH EXTERIOR ELEVATION SCALE: 1/16" = 1'-0" 1B PARTIAL NORTH EXTERIOR ELEVATION SCALE: 1/16" = 1'-0" 2 EAST EXTERIOR ELEVATION
4001 TILT-UP CONCRETE W
4003 2" REVEAL.
4005 REVEAL PATTERN AT
4006 ALUMINUM STOREFR
4007 CANOPY WITH PRE-F

METAL STUD FRAMIN

RECESSED CAN LIGH
4010 FINISH GRADE VARIE
4012 CLERESTORY WINDO
4014 BUILDING SIGN ±8'-0"

SIZE & LOCATION W/O

LOGO, PROVIDED BY
4016 ALUMINUM COMPOSI

DESIGN BY COLD-FO
4020 WALL PACK LIGHTING
4021 PREFINISHED STEEL

FRAMING, EXPANSIO

STEEL SOFFIT PANEL
4022 HYDRAULIC GLASS B
4029 PROVIDE BUILDING A

TO BE PROVIDED BY
41’-10”
41’-10”
41’-10”
43’-10”
2 This page intentionally left blank.

Proposed Elevations
RCCB Fresno Distribution Warehouse Figure 4b
City of Fresno

VISION G

SPANDRE

TEMPERE
GLASS:

ALL GLASS USED ON THE ENV

VERIFY AND MEET CITY STAND

PROVIDE TEMPERED GLAZING
SPANDREL AS REQUIRED.

F.F.E.
0"
1 2 3 4 5 6 7 8 9 10 11 12 13
T.O.P.
40'-10"
SEE ELEVATION 3A SEE ELEVATION 3B
F.F.E.
0"
1 2 3 4 4.2 4.6 5 6 7
T.O.P.
40'-10"
TYP.
4012 4001
TYP.
4017 4005 4003
4008 4009
TYP.
4020
TYP.
4003
TYP.
1031
F.F.E.
0"
7 8 9 10 11 12 13
T.O.P.
40'-10"

11.511.6 11.9 12.412.512.612.712.8
TYP.
4021
F.F.E.
0"

G F E D C B A
T.O.P.
40'-10"
TYP.
4001
TYP.
4003
TYP.
4005
1'-0"
TYP.
4020
1031
1031 CONCRETE RAMP,
4001 TILT-UP CONCRETE
4003 2" REVEAL.
4005 REVEAL PATTERN A
4008 DOCK BUMPER.
4009 DOCK SEAL.
4012 CLERESTORY WIND
4017 PREFINISHED META
4020 WALL PACK LIGHTI
4021 PREFINISHED STEE

FRAMING, EXPANS

STEEL SOFFIT PAN
KEYNOTES:

LEGEND
0 15' 30' 60' 150'
1"=30'
0 8' 16' 32' 64'
1/16"=1'-0"
SCALE: 1" = 30'-0" 3 OVERALL SOUTH EXTERIOR ELEVATION
SCALE: 1/16" = 1'-0" 3A PARTIAL SOUTH EXTERIOR ELEVATION SCALE: 1/16" = 1'-0" 3B PARTIAL SOUTH EXTERIOR ELEVATION SCALE: 1/16" = 1'-0" 4 WEST EXTERIOR ELEVATION
40’-10”
40’-10”
40’-10”
40’-10”
2 This page intentionally left blank.

RCCB Fresno Distribution Warehouse
City of Fresno
Figure 5
Conceptual Renderings
10 Edelman
Irvine, CA, 92618
P 949.660.9128
JOB NO.:

DRAWN BY.:PA/PM:

SHEET
THESE DRAWINGS AND SPECIFICATIONS ARE THE PROPERTY AND COPYRIGHT OF WARE MALCOMB AND SHALL NOT BE USED ON ANY OTHER WORK EXCEPT BY AGREEMENT WITH WARE MALCOMB. WRITTEN DIMENSIONS SHALL TAKE PRECEDENCE OVER SCALED DIMENSIONS AND SHALL BE VERIFIED ON THE JOB SITE. ANY DISCREPANCY SHALL BE BROUGHT TO THE NOTICE OF WARE MALCOMB PRIOR TO THE COMMENCEMENT OF ANY WORK CAUTION: IF THIS SHEET IS NOT 30"x42" IT IS A REDUCED PRINT C:\_Revit\5026_ARCH
2/8/2022 10:21:10 AM
A. STEVENS
Author
IRV21-5026-01
ACCESSIBILITY DETAILSA-0.1

RCCB FRESNO DISTRIBUTION

WAREHOUSE

EAST NORTH AVENUE,
FRESNO, CA 93725

DATE REMARKS

1.0 COLORED ELEVATIONS CORNER PERSPECTIVE

07.21.2022 PLANNING SUBMITTAL 02
2022-08-01 - PLANNING SUBMITTAL 02 - REV
2 This page intentionally left blank
1 PREVIOUS ENVIRONMENTAL ANALYSES OF THE PROPOSED PROJECT Applicable to the proposed Project, a Program EIR (PEIR) (SCH #2019050005) was prepared for the 2021 GP Amendment No. P19-04226 (2021 GPA). The 2021 GPA continues the implementation of a majority of the General Plan as approved in 2014, except for specific text changes to the Mobility and Transportation Element related to Vehicle Miles Traveled (VMT) analysis, and an update to the Greenhouse Gas Reduction Plan. The PEIR consists of the Draft PEIR from March 2020, the Response to Comments documents from July 2020, the Recirculated Draft PEIR from March 2021, and the Response to Comments documents from July 2021. The proposed Project would be consistent with the GP designation of Employment – Heavy Industrial, as described above. The PEIR assumed full development and buildout of the Project site, consistent with the uses and development standards proposed by the Project.

The cumulative impacts associated with buildout of the City as envisioned in the GP, including the Project site, were fully addressed in the PEIR.

CEQA Guidelines Section 15183 Streamline Analysis
CEQA Guidelines Section 15183 allows a streamlined environmental review process for projects that are consistent with the densities established by existing zoning, community plan or general plan policies for which an EIR was certified. As noted above, the proposed Project is consistent with the land use designation and densities established by the Fresno GP, for which an EIR was certified. The provisions contained in Section 15183 of the CEQA Guidelines are presented below.
15183. Projects Consistent with a Community Plan or Zoning a) CEQA mandates that projects which are consistent with the development density established by existing zoning, community plan, or general plan policies for which an EIR was certified shall not require additional environmental review, except as might be necessary to examine whether there are project-specific significant effects which are peculiar to the project or its site. This streamlines the review of such projects and reduces the need to prepare repetitive environmental studies.
b) In approving a project meeting the requirements of this section, a public agency shall limit its examination of environmental effects to those which the agency determines, in an initial study or other analysis:
1) Are peculiar to the project or the parcel on which the project would be located, 2) Were not analyzed as significant effects in a prior EIR on the zoning action, general plan, or community plan, with which the project is consistent, 3) Are potentially significant off-site impacts and cumulative impacts which were not discussed in the prior EIR prepared for the general plan, community plan or zoning action, or
4) Are previously identified significant effects which, as a result of substantial new information which was not known at the time the EIR was certified, are determined to have a more severe adverse impact than discussed in the prior EIR. 2 c) If an impact is not peculiar to the parcel or to the project, has been addressed as a significant effect in the prior EIR, or can be substantially mitigated by the imposition of uniformly applied development policies or standards, as contemplated by subdivision I below, then an additional EIR need not be prepared for the project solely on the basis of that impact.
d) This section shall apply only to projects which meet the following conditions:
1) The project is consistent with:

A. A community plan adopted as part of a general plan,
B. A zoning action which zoned or designated the parcel on which the project would be located to accommodate a particular density of development, or C. A general plan of a local agency, and
2) An EIR was certified by the lead agency for the zoning action, the community plan, or the general plan.
e) This section shall limit the analysis of only those significant environmental effects for which:
1) Each public agency with authority to mitigate any of the significant effects on the environment identified in the planning or zoning action undertakes or requires others to undertake mitigation measures specified in the EIR which the lead agency found to be feasible, and
2) The lead agency makes a finding at a public hearing as to whether the feasible mitigation measures will be undertaken.
f) An effect of a project on the environment shall not be considered peculiar to the project or the parcel for the purposes of this section if uniformly applied development policies or standards have been previously adopted by the City or county with a finding that the development policies or standards will substantially mitigate that environmental effect when applied to future projects, unless substantial new information shows that the policies or standards will not substantially mitigate the environmental effect. The finding shall be based on substantial evidence which need not include an EIR. Such development policies or standards need not apply throughout the entire City or county, but can apply only within the zoning district in which the project is located, or within the area subject to the community plan on which the lead agency is relying. Moreover, such policies or standards need not be part of the general plan or any community plan, but can be found within another pertinent planning document such as a zoning ordinance. Where a City or county, in previously adopting uniformly applied development policies or standards for imposition on future projects, failed to make a finding as to whether such policies or standards would substantially mitigate the effects of future projects, the decision-making body of the City or county, prior to approving such a future project pursuant to this section, may hold a public hearing for the purpose of considering whether, as applied to the project, such standards or policies would substantially mitigate the effects of the project. Such a public hearing need only be held if the City or county decides to apply the standards or policies as permitted in this section.
g) Examples of uniformly applied development policies or standards include, but are not limited to:
1) Parking ordinances.
2) Public access requirements.
3 3) Grading ordinances.
4) Hillside development ordinances.
5) Flood plain ordinances.
6) Habitat protection or conservation ordinances.
7) View protection ordinances.
8) Requirements for reducing greenhouse gas emissions, as set forth in adopted land use plans, policies, or regulations.
h) An environmental effect shall not be considered peculiar to the project or parcel solely because no uniformly applied development policy or standard is applicable to it. i) Where the prior EIR relied upon by the lead agency was prepared for a general plan or community plan that meets the requirements of this section, any rezoning action consistent with the general plan or community plan shall be treated as a project subject to this section. 1) “Community plan” is defined as a part of the general plan of a City or county which applies to a defined geographic portion of the total area included in the general plan, includes or references each of the mandatory elements specified in Section 65302 of the Government Code, and contains specific development policies and implementation measures which will apply those policies to each involved parcel. 2) For purposes of this section, “consistent” means that the density of the proposed project is the same or less than the standard expressed for the involved parcel in the general plan, community plan or zoning action for which an EIR has been certified, and that the project complies with the density-related standards contained in that plan or zoning. Where the zoning ordinance refers to the general plan or community plan for its density standard, the project shall be consistent with the applicable plan.
j) This section does not affect any requirement to analyze potentially significant offsite or cumulative impacts if those impacts were not adequately discussed in the prior EIR. If a significant offsite or cumulative impact was adequately discussed in the prior EIR, then this section may be used as a basis for excluding further analysis of that offsite or cumulative impact.

PROJECT-SPECIFIC ENVIRONMENTAL REVIEW
The Environmental Checklist includes a discussion and analysis of any peculiar or site-specific environmental impacts associated with construction and operation of the proposed Project. The Environmental Checklist identifies the applicable City of Fresno development standards and policies that would apply to the proposed Project during both the construction and operational phases and explains how the application of these uniformly applied standards and policies would ensure that no peculiar or site-specific environmental impacts would occur. None of the environmental factors below would be affected by this Project, as indicated by the checklist on the following pages.
☐ Aesthetics ☐ Agriculture and Forestry Resources
☐ Air Quality ☐ Biological Resources
☐ Cultural Resources ☐ Energy
4 ☐ Geology/Soils ☐ Greenhouse Gas Emissions
☐ Hazards and Hazardous Materials ☐ Hydrology/Water Quality ☐ Land Use/Planning ☐ Mineral Resources
☐ Noise ☐ Population/Housing
☐ Public Services ☐ Recreation
☐ Transportation ☐ Tribal Cultural Resources
☐ Utilities/Service Systems ☐ Wildfire
☐ Mandatory Findings of Significance

CONCLUSION
As described above, Development Permit Application No. P22-00565 (proposed Project) is consistent with the land use designation and development intensity assigned to the Project site by the City of Fresno. Cumulative impacts associated with development and buildout of the Project site, as proposed, were fully addressed in the City of Fresno PEIR (SCH No. 2019050005). Since the proposed Project is consistent with the land use designation and development intensity for the site identified in the GP and analyzed in the PEIR, implementation of the proposed Project would not result in any new or altered cumulative impacts beyond those addressed in the PEIR.

The analysis in the following CEQA Environmental Checklist demonstrates that there are no site-specific or peculiar impacts associated with the Project and identifies uniformly applied standards and policies that would be applied to the Project. The Project Requirements identified in the attached environmental analysis include requirements that must be implemented by the proposed Project in order to ensure that any site-specific impacts or construction-related impacts are reduced to a less-than-significant level. All Project Requirements identified in the attached Environmental Checklist shall be made a condition of Project approval and shall be implemented within the timeframes identified.

Thomas Veatch, Planner Date
5 ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
I. AESTHETICS – Except as provided in PRC Section 21099, would the project:
a) Have a substantial adverse effect on a
scenic vista?
b) Substantially damage scenic resources,
including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?
c) In non-urbanized areas, substantially
degrade the existing visual character or
quality public views of the site and its
surroundings? (Public views are those that
are experienced from publicly accessible
vantage point). If the project is in an
urbanized area, would the project conflict
with applicable zoning and other regulations
governing scenic quality?
d) Create a new source of substantial light
or glare which would adversely affect day or
nighttime views in the area?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
The City has highly valued features such as the San Joaquin River, Sierra Nevada foothills, Downtown Fresno building skyline, and the State scenic highway SR-99. The GP PEIR states that the land use changes in the planning area of the GP (Planning Area) would result in a combination of de‐intensifying in some areas and intensifying in other areas potentially affecting views of such valued features. However, within the Planning Area the GP has no locations designated as a scenic vista and there are no resources eligible for listing as a scenic highway. Therefore, the PEIR concluded the GP would have a less than significant impact on scenic vistas and scenic resources.

It was concluded in the GP PEIR the GP would result in a substantial alteration to the existing urban form and character of the existing Planning Area. Implementation of the GP objectives and policies within the Urban Form, Land Use and Design Element and the Mobility and Transportation Element reduced potential visual character impacts within the Planning Area.

However, the replacement of rural and agricultural uses and open space with urban land uses was considered a significant impact from potential changes to visual character.

It was also concluded that the new development outside and within the Planning Area would have a significant impact due to the increased amount light spillover onto adjacent properties within and adjacent, increased illumination of the sky at night, and increased the glare from building facades, signs, parking lots, roadways, and vehicles. Therefore, the PEIR introduced 6 mitigation measures MM AES-4.1 through -4.5 to reduce impacts; however impacts from the illumination of the night sky would remain significant.

GP GOALS AND POLICIES
The GP goals and policies that pertain to the Project’s aesthetics are as follows:

Policy LU-2-c: Infill Design Toolkit. Develop and distribute an infill design toolkit, consistent with the City's Infill Development Act to support and encourage infill development.

Commentary: The toolkit will use photos and diagrams to:
• Explain design and permit requirements and priority infill development incentives; • Illustrate context‐responsive best practices for prototype development; and • Address detailed issues such as parking, scale, privacy, outdoor spaces, housing types, transitions, building design, siting and street orientation, setbacks, windows, and general material guidelines and buffering for adjacent uses.

Policy UF-14-a: Design Guidelines for Walkability. Develop and use design guidelines and standards for a walkable and pedestrian‐scaled environment with a network of streets and connections for pedestrians and bicyclists, as well as transit and autos.

Commentary: These guidelines will highlight how to achieve these design ideas and avoid barriers to access, such as:
• Walls and fences that separate related uses or isolate neighborhoods; • Over reliance on cul‐de‐sacs and dead end streets that cut off access within neighborhoods;
• Disconnected bike and pedestrian paths;
• Wide streets that lack pedestrian support, such as sidewalks, median strips, and a landscaped strip that separates pedestrians from the street; • Street front parking lots that separate pedestrian from commercial operations; • Retail centers that are exclusively auto‐oriented;
• Transit stops that are not easily accessible from an individual’s starting point and destination; and
• Long blocks that discourage walking.

Policy D-3-d. Partner with utility companies the city will continue to pursue the undergrounding of overhead utilities as feasible.

GP PEIR MITIGATION MEASURES
MM AES‐4.1 Lighting for Street and Parking Areas. Lighting systems for street and parking areas shall include shields to direct light to the roadway surfaces and parking areas. Vertical shields on the light fixtures shall also be used to direct light away from adjacent light sensitive land uses such as residences. 7 MM AES‐4.2 Lighting for Public Facilities. Lighting systems for public facilities such as active play areas shall provide adequate illumination for the activity; however, low intensity light fixtures and shields shall be used to minimize spillover light onto adjacent properties.

MM AES‐4.3 Lighting for Non-Residential Uses. Lighting systems for non‐residential uses, not including public facilities, shall provide shields on the light fixtures and orient the lighting system away from adjacent properties. Low intensity light fixtures shall also be used if excessive spillover light onto adjacent properties will occur.

MM AES‐4.4 Signage Lighting. Lighting systems for freestanding signs shall not exceed 100 foot Lamberts (FT‐L) when adjacent to streets which have an average light intensity of less than 2.0 horizontal footcandles and shall not exceed 500 FT‐L when adjacent to streets which have an average light intensity of 2.0 horizontal footcandles or greater.

MM AES‐4.5 Use of Non-Reflective Materials. Materials used on building facades shall be non‐reflective.

PROJECT-SPECIFIC IMPACTS
a) Have a substantial adverse effect on a scenic vista? No New Impact. This topic was evaluated in the GP PEIR and was determined to have a less than significant impact.

The Project site is relatively flat and not within or near a scenic vista, and is located in an area surrounded by existing industrial and commercial uses. The Project is an infill development project, consistent with the Heavy Industrial GP land use designation. The proposed warehouse with mezzanine level would have a clearance height of 36 feet and have a maximum top of parapet height 44 feet 10 inches tall with varying roof lines to break up the perception of massing. Therefore, the height of the warehouse is within the maximum building height limit of 60 feet specified for the Employment - Heavy Industrial District (IH) zone. In addition, the IH includes a 15-foot front (major street) setback. As discussed in the GP PEIR, new buildings and development anticipated in the GP Planning Areas could reduce views of scenic vistas. Although the proposed warehouse massing and height are increased compared to existing vacant conditions, there would be no impact to scenic vistas. The proposed industrial warehouse would not substantially obstruct views from downtown skyline or obstruct distant views of the mountains beyond existing conditions. Therefore, the Project would result in no new impact to scenic vistas.
b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? No New Impact. This topic was evaluated in the GP PEIR and was determined to have a less 8 than significant impact. As discussed in the GP PEIR, the City has two nearest the GP Planning Area eligible State Scenic Highways; State Route 180 (SR-180), State Route 168 (SR-168).

However, the City does not have any officially designated State Scenic Highways and it was concluded future developed such as the proposed Project, in accordance with the GP would not impact such state scenic highways. Furthermore, the Project site is not visible from a state scenic highway or scenic roadway. Therefore, the Project would result in no new impact on scenic resources on a state scenic highway.
c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
No New Impact. This topic was evaluated in the GP PEIR and was determined to have significant and unavoidable impact.No feasible mitigation measures are available. The Project is in an industrial area, specifically within the IH zone. As discussed above, the Project proposes to construct a new industrial warehouse in an area surrounded by similar industrial development. Visual character and quality of the proposed industrial warehouse would be similar to existing buildings.

It was determined in the GP PEIR that significant visual character impacts were expected to occur within the Planning Area due to the replacement of rural, agricultural, and open space uses with urban land uses. To reduce these potential impacts, the GP implemented the objectives and policies as previously stated and also within the Urban Form, Land Use and Design Element and the Mobility and Transportation Element. The Project is located in a partially developed area of the City with scattered properties used for agricultural and industrial purposes. The Project would be consistent with the GP goals that pertain to the aesthetics listed above to improve the visual character and quality of industrial areas within the City.

However, the Project impact would remain significant and unavoidable due to replacement of the undeveloped property with urban land uses in the same manner as the PEIR. Therefore, the Project would result in no new impact with respect to existing visual character and quality. d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
No New Impact. This topic was evaluated in the GP PEIR and was determined to have a significant impact specifically pertaining to illumination of the sky at night. The GP PEIR determined lighting on properties adjacent to lighting systems and glare impacts would be less than significant.

The Project site is vacant and the surrounding area is primarily built‐out, and a substantial amount of ambient light from urban uses already exists. As further discussed in Biological Resources, the Project site is not located in the vicinity of sensitive habitat areas. Proposed parking areas and exterior of the building would include approximately 14 lighting fixtures (138 9 watt LED) and the building exterior would include approximately 30 attached lighting fixtures (202 watt LED), positioned along all sides of the building. The new lighting would be focused on the site for safety and illumination, and shielded from off-site areas. Such lighting specifications are as required for implementation as stated in Policy LU-6-b, and MM AES-4.1, AES-4.3 through -4.5, designed to reduce glare and light spillover on adjacent development.

Vehicle and truck traffic would introduce new light to the Project site. However, the lighting would be intermittent and transitory in nature and would not result in long-term permanent onsite lighting. MM AES-4.2 does not apply to the Project because it is not a public facility.

Therefore, with implementation of PEIR mitigation measures, the Project impact would be less than significant and no new impact would occur with respect to light and glare.

CONCLUSION
With regards to the issue area of Aesthetics, the following findings can be made:

1. No peculiar impacts from the Project or site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. Mitigation measures contained within the GP PEIR would be required to reduce similar Project specific impacts to less than significant.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
MM AES‐4.1 Lighting for Street and Parking Areas. Lighting systems for street and parking areas shall include shields to direct light to the roadway surfaces and parking areas. Vertical shields on the light fixtures shall also be used to direct light away from adjacent light sensitive land uses such as residences.

MM AES‐4.3 Lighting for Non-Residential Uses. Lighting systems for non‐residential uses, not including public facilities, shall provide shields on the light fixtures and orient the lighting system away from adjacent properties. Low intensity light fixtures shall also be used if excessive spillover light onto adjacent properties will occur.

MM AES‐4.4 Signage Lighting. Lighting systems for freestanding signs shall not exceed 100 foot Lamberts (FT‐L) when adjacent to streets which have an average light intensity of less than 2.0 horizontal footcandles and shall not exceed 500 FT‐L when adjacent to streets which have an average light intensity of 2.0 horizontal footcandles or greater.
10 MM AES‐4.5 Use of Non-Reflective Materials. Materials used on building facades shall be non‐reflective.
11 ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
II. AGRICULTURE AND FORESTRY RESOURCES – In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:
a) Convert Prime Farmland, Unique
Farmland, or Farmland of Statewide
Importance (Farm-land), as shown on the
maps prepared pursuant to the Farmland
Mapping and Monito-ring Program of the
California Resources Agency, to nonagricultural use?
b) Conflict with existing zoning for
agricultural use, or a Williamson Act
contract?
c) Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in Public
Resources Code section 12220(g)),
timberland (as defined by Public Resources
Code section 4526), or timberland zoned
Timberland Production (as defined by
Government Code section 51104(g))?
d) Result in the loss of forest land or
conversion of forest land to non-forest use?
e) Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of
Farmland, to non-agricultural use or
conversion of forest land to non-forest use?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
As concluded in the GP PEIR, implementation of the GP would result in the loss of farmland and the City acknowledged there are no feasible measures to replace the loss of farmland.

It was determined in the PEIR analysis in a worst‐case assumption, the GP would not conserve agricultural resources within the Planning Area. Implementation of the GP converted approximately 14,627 acres of FMMP‐designated farmland and approximately 11,495 acres of existing farmland to uses other than agriculture. This conversion was determined to have significant impact on agricultural resources. Although not encompassing the Project site, the GP has 603 acres in the Planning Area currently under a Williamson Act contract for designation as non‐agricultural uses.
12 The GP PEIR implemented Policy RC‐9‐b to reduce premature conversion of agricultural land within the Planning Area and outside the sphere‐of‐influence. Although this policy is intended to reduce some impacts on agricultural zoning and Williamson Act contracts, impacts remained significant.

GP GOALS AND POLICIES
The GP goals and policies that pertain to the Project’s agriculture and forestry impacts:

Objective RC-9. Preserve agricultural land outside of the area planned for urbanization under this General Plan.

Policy RC‐9‐b. Land Outside SOI. Express opposition to residential and commercial development proposals in unincorporated areas (excluding County Islands) within or adjacent to the Planning Area when these proposals would do any of the following:
• Make it difficult or infeasible to implement the General Plan; • Contribute to the premature conversion of agricultural, open space, or grazing lands; or
• Constitute a detriment to the management of resources and/or facilities important to the Fresno Metropolitan Area (such as air quality, water quantity and quality, traffic circulation, and riparian habitat).

Policy RC-9-c: Farmland Preservation Program. In coordination with regional partners or independently, establish a Farmland Preservation Program. When Prime Farmland, Unique Farmland, or Farmland of Statewide Importance is converted to urban uses outside City limits, this program would require that the developer of such a project permanently protect an equal amount of similar farmland elsewhere through easement to mitigate the loss of such farmland consistent with the requirements of CEQA. The Farmland Preservation Program shall provide several mitigation options that may include, but are not limited to the following: Restrictive Covenants or Deeds, In Lieu Fees, Mitigation Banks, Fee Title Acquisition, Conservation Easements, Land Use Regulation, or any other mitigation method that is in compliance with the requirements of CEQA. The Farmland Preservation Program may be modeled after some or all of the programs described by the California Council of Land Trusts.

GP PEIR MITIGATION MEASURES
None.

PROJECT-SPECIFIC IMPACTS
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? 13 No New Impact. The PEIR determined the GP Update would result in a significant impact regarding this topic. The Project site is not on Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. The site is designated farmland of local importance and is surrounded by urban and built-up land according to the California Department of Conservation’s California Important Farmland Finder Map. Although the Project would convert a site designed as farmland of local importance, the Project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance and therefore, impacts would not be considered significant. Thus, the Project would not result in new impacts related to the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural use.
b) Conflict with existing zoning for agricultural use or a Williamson Act contract? No New Impact. The GP PEIR determined the GP Update would result in a significant impact regarding this topic. The Project site is not currently under an active Williamson Act contract.

Therefore, the Project would not result in new impacts related to conflicts 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))?
No New Impact. This topic was not evaluated in the GP PEIR. The Project does not include forest land or timberland. The Project site is vacant and has a zoning designation of Heavy Industrial District/Urban Growth Management (IH/UGM). The proposed Project would be consistent the existing zoning. Therefore, the Project would not result in significant impacts related to rezoning of forest land or timber land. No new impacts related to conflicts with existing forest land or timberland zoning would occur.
d) Result in the loss of forest land or conversion of forest land to non-forest use? No New Impact. This topic was not evaluated in the GP PEIR. As previously discussed, the Project site is currently vacant. Therefore, the Project would not result in impacts to loss of forest land or conversion of forest land to non-forest use and no new impacts would occur. e) Involve other changes in the existing environment, which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use?
No New Impact. The GP PEIR determined the GP Update would impact Farmland, and impacts would be significant and unavoidable. The Project site is vacant and not designated or zoned for forest land. It has not been used as farmland since 2001. The proposed Project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to 14 nonagricultural use. Further, the Project would be consistent with the land use and zoning designation for the site and would be developed similar to the surrounding existing uses.

Therefore, the Project would not involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use. The Project would result in no new impacts.

CONCLUSION
With regards to the issue area of Agricultural/Forestry Resources, the following findings can be made:

1. No peculiar impacts from the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No mitigation measures contained within the GP PEIR would be required because Project specific impacts would be less than significant.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
None.
15 ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
III. AIR QUALITY – Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project:
a) Conflict with or obstruct implementation of
the applicable air quality plan (e.g., by having
potential emissions of regulated criterion
pollutants which exceed the San Joaquin
Valley Air Pollution Control Districts
(SJVAPCD) adopted thresholds for these
pollutants)?
b) Result in a cumulatively considerable net
increase of any criteria pollutant for which the
project region is non-attainment under an
applicable federal or state ambient air quality
standard (including releasing emissions
which exceed quantitative thresholds for
ozone precursors)?
c) Expose sensitive receptors to substantial
pollutant concentrations?
d) Result in other emissions (such as those
leading to odors) adversely affecting a
substantial number of people?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
The GP PEIR used two tests to determine if the GP conflicted or obstructed applicable air quality plans. First, if the GP exceeds the growth projections used in the applicable attainment plan, it would produce a potentially significant impact. Second, if the GP included goals, policies, and development standards that were in conflict with the development related control measures in the attainment plans, the GP would be potentially significant. Under these tests, the GP would not have a significant impact.

Growth projections used for the GP buildout year 2056 concluded that the amount of growth predicted for the GP is accommodated by the San Joaquin Valley Air Pollution Control District’s (SJVAPCD) attainment plan, and would not conflict with the ability for the air basin to attain the 8‐hour ozone standard by the 2023 attainment date. In addition, emissions were anticipated to continually decline due to implementation of planned air quality regulations and the introduction of newer, cleaner, vehicles into the vehicle fleet even with development and population increases. Furthermore, implementation of the GP was determined to increase the City’s sustainability efforts to reduce motor vehicle use and energy consumption by increasing development density and by providing a land use pattern and transportation infrastructure more supportive of public transportation, walking, and bicycling. As concluded in the GP PEIR, 16 the GP supported the implementation of SJVAPCD’s attainment plans and successfully met the two consistency tests.

As described in the GP PEIR, the SJVAPCD adopted rules and regulations specifically designed to reduce the impacts of growth on the applicable air quality plans (i.e., Rule 9510, Regulation III, and Rule 2201). It was concluded that development consistent with the approved GP would comply with these rules and regulations and would not interfere or obstruct with the application of the attainment plans. Therefore, the GP and the proposed Project, would be consistent with the air quality attainment plans resulting in a less than significant impact.

The PEIR concluded that implementation of the GP will reduce criteria pollutant emissions, the GP exceeded the SJVAPCD project level thresholds of significance for ROG, NOx, PM10, and PM2.5. While implementation of Mitigation Measures AIR‐2.1, AIR‐2.2, AIR‐3.1, AIR‐3.2 and AIR‐4.1 would reduce criteria air pollutant emissions generated by continued implementation of the approved GP, there was not enough information to quantify emissions of specific project development that may occur. Without quantification to guarantee a less than significant finding, future development projects were considered to have the potential to exceed the SJVAPCD regional significance thresholds and to have the potential to expose sensitive receptors to substantial pollutant concentrations. Therefore, cumulative impacts to air quality, localized pollutant concentrations and toxic air contaminants (TAC) would remain significant and unavoidable.

As described below, the PEIR included Mitigation Measures AIR‐2.1, AIR‐2.2, AIR‐3.1, AIR‐3.2 and AIR‐4.1 to require project-level technical studies for discretionary projects top determine if project specific mitigation is required to reduce impacts, which apply to the proposed Project.

GP GOALS AND POLICIES
The GP goals and policies that pertain to the Project’s air quality impacts:

Policy UF‐14‐a: Design Guidelines for Walkability. Develop and use design guidelines and standards for a walkable and pedestrian-scaled environment with a network of streets and connections for pedestrians and bicyclists, as well as transit and autos.

Commentary: These guidelines will highlight how to achieve these design ideas and avoid barriers to access, such as:
• Walls and fences that separate related uses or isolate neighborhoods; • Over reliance on cul-de-sacs and dead end streets that cut off access within neighborhoods;
• Disconnected bike and pedestrian paths;
17 • Wide streets that lack pedestrian support, such as sidewalks, median strips, and a landscaped strip that separates pedestrians from the street; • Street front parking lots that separate pedestrian from commercial operations; • Retail centers that are exclusively auto-oriented;
• Transit stops that are not easily accessible from an individual’s starting point and destination; and
• Long blocks that discourage walking.

Objective RC‐4. In cooperation with other jurisdictions and agencies in the San Joaquin Valley Air Basin, take necessary actions to achieve and maintain compliance with State and federal air quality standards for criteria pollutants.

Policy RC‐4‐a. Support Regional Efforts. Support and lead, where appropriate, regional, State and federal programs and actions for the improvement of air quality, especially the SJVAPCD’s efforts to monitor and control air pollutants from both stationary and mobile sources and implement Reasonably Available Control Measures in the Ozone Attainment Plan.

Policy RC‐4‐b. Conditions of Approval. Develop and incorporate air quality maintenance requirements, compatible with Air Quality Attainment and Maintenance Plans, as conditions of approval for General Plan amendments, community plans, Specific Plans, neighborhood plans, Concept Plans, and development proposals.

Policy RC‐4‐c. Evaluate Impacts with Models. Continue to require the use of computer models used by SJVAPCD to evaluate the air quality impacts of plans and projects that require such environmental review by the City.

Policy RC‐4‐d. Forward Information. Forward information regarding proposed General Plan amendments, community plans, Specific Plans, neighborhood plans, Concept Plans, and development proposals that require air quality evaluation, and amendments to development regulations to the SJVAPCD for their review of potential air quality and health impacts.

Policy RC-4-e. Support Employer-Based Efforts. Support and promote employer implementation of staggered work hours and employee incentives to use carpools, public transit, and other measures to reduce vehicular use and traffic congestion.

Policy RC‐4‐k: Electric Vehicle Charging. Develop standards to facilitate electric vehicle charging infrastructure in both new and existing public and private buildings, in order to accommodate these vehicles as the technology becomes more widespread.

Policy RC‐5‐c: GHG Reduction through Design and Operations. Increase efforts to incorporate requirements for GHG emission reductions in land use entitlement decisions, 18 facility design, and operational measures subject to City regulation through the following measures and strategies:
• Promote the expansion of incentive-based programs that involve certification of projects for energy and water efficiency and resiliency. These certification programs and scoring systems may include public agency “Green” and conservation criteria, Energy Star™ certification, CALGreen Tier 1 or Tier 2, Leadership in Energy and Environmental Design (LEED™) certification, etc.
• Promote appropriate energy and water conservation standards and facilitate mixeduse projects, new incentives for infill development, and the incorporation of mass transit, bicycle and pedestrian amenities into public and private projects. • Require energy and water audits and upgrades for water conservation, energy efficiency, and mass transit, pedestrian, and bicycle amenities at the time of renovation, change in use, change in occupancy, and change in ownership for major projects meeting review thresholds specified in an implementing ordinance. • Incorporate the City’s “Guidelines for Ponding Basin/Pond Construction and Management to Control Mosquito Breeding” as conditions of approval for any project using an on-site stormwater basin to prevent possible increases in vectorborne illnesses associated with global climate change. • Periodically evaluate the City’s facility maintenance practices to determine whether there are additional opportunities to reduce GHGs through facility cleaning and painting, parks maintenance, road maintenance, and utility system maintenance. • Periodically evaluate standards and mitigation strategies for highly vehicledependent land uses and facilities, such as drive-through facilities and autooriented development.

Policy RC‐8‐a: Existing Standards and Programs. Continue existing beneficial energy conservation programs, including adhering to the California Energy Code in new construction and major renovations.

Policy RC-8-b: Energy Reduction Targets. Strive to reduce per capita residential electricity use to 1,800 kWh per year and non-residential electricity use to 2,700 kWh per year per capita by developing and implementing incentives, design and operation standards, promoting alternative energy sources, and cost-effective savings.

Policy RC-8-c: Energy Conservation in New Development. Consider providing an incentive program for new buildings that exceed California Energy Code requirements by fifteen percent.

GP PEIR MITIGATION MEASURES
MM AIR-2.1 Prior to future discretionary project approval, development project applicants shall prepare and submit to the Director of the City Planning and Development Department, or designee, a technical assessment evaluating potential project construction phase-related air quality impacts. The evaluation shall be prepared 19 in conformance with SJVAPCD methodology for assessing construction impacts. If construction related air pollutants are determined to have the potential to exceed the SJVAPCD adopted threshold of significance, the Planning and Development Department shall require that applicants for new development projects incorporate mitigation measures into construction plans to reduce air pollutant emissions during construction activities. The identified measures shall be included as part of the Project Conditions of Approval.

Possible mitigation measures to reduce construction emissions include but are not limited to:
• Install temporary construction power supply meters on site and use these to provide power to electric power tools whenever feasible. If temporary electric power is available on site, forbid the use of portable gasoline- or dieselfueled electric generators. • Use of diesel oxidation catalysts and/or catalyzed diesel particulate traps on diesel equipment, as feasible.
• Maintain equipment according to manufacturers’ specifications. • Restrict idling of equipment and trucks to a maximum of 5 minutes (per California Air Resources Board [CARB] regulation).
• Phase grading operations to reduce disturbed areas and times of exposure. • Avoid excavation and grading during wet weather.
• Limit on-site construction routes and stabilize construction entrance(s). • Remove existing vegetation only when absolutely necessary. • Sweep up spilled dry materials (e.g., cement, mortar, or dirt track-out) immediately. Never attempt to wash them away with water. • Use only minimal water for dust control.
• Store stockpiled materials and wastes under a temporary roof or secured plastic sheeting or tarp.

MM AIR-2.2 Prior to future discretionary project approval, development project applicants shall prepare and submit to the Director of the City Planning and Development Department, or designee, a technical assessment evaluating potential project operation-related air quality impacts. The evaluation shall be prepared in conformance with SJVAPCD methodology in assessing air quality impacts. If operation-related air pollutants are determined to have the potential to exceed the SJVAPCD-adopted thresholds of significance, the Planning and Development Department shall require that applicants for new development projects incorporate mitigation measures to reduce air pollutant emissions during operational activities. The identified measures shall be included as part of the Project Conditions of Approval. Possible mitigation measures to reduce long-term emissions include but are not limited to:
• For site-specific development that requires refrigerated vehicles, the construction documents shall demonstrate an adequate number of electrical 20 service connections at loading docks for plugging in the anticipated number of refrigerated trailers to reduce idling time and emissions. • Applicants for manufacturing and light industrial uses shall consider energy storage (i.e., battery) and combined heat and power (CHP, also known as cogeneration) in appropriate applications to optimize renewable energy generation systems and avoid peak energy use.
• Site-specific developments with truck delivery and loading areas and truck parking spaces shall include signage as a reminder to limit idling of vehicles while parked for loading/unloading in accordance with CARB Rule 2845 (13 California Code of Regulations [CCR] Chapter 10, Section 2485). • Require that 240-volt electrical outlets or Level 3 chargers be installed in parking lots that would enable charging of neighborhood electric vehicles (NEVs) and/or battery powered vehicles.
• Maximize use of solar energy including solar panels; installing the maximum possible number of solar energy arrays on building roofs throughout the city to generate solar energy.
• Maximize the planting of trees in landscaping and parking lots. • Use light-colored paving and roofing materials.
• Require use of electric or alternatively fueled street-sweepers with HEPA filters.
• Require use of electric lawn mowers and leaf blowers. • Utilize only Energy Star heating, cooling, and lighting devices, and appliances.
• Use of water-based or low volatile organic compound (VOC) cleaning products.

MM AIR-3.1 Prior to future discretionary approval for projects that require environmental evaluation under CEQA, the City of Fresno shall evaluate new development proposals for new industrial or warehousing land uses that: (1) have the potential to generate 100 or more truck trips per day or have 40 or more trucks with operating diesel-powered transport refrigeration units, and (2) are within 1,000 feet of a sensitive land use (e.g., residential, schools, hospitals, or nursing homes), as measured from the property line of the project to the property line of the nearest sensitive use. Such projects shall submit a Health Risk Assessment (HRA) to the City Planning and Development Department. The HRA shall be prepared in accordance with policies and procedures of the most current State Office of Environmental Health Hazard Assessment (OEHHA) and the SJVAPCD. If the HRA shows that the incremental health risks exceed their respective thresholds, as established by the SJVAPCD at the time a project is considered, the Applicant will be required to identify and demonstrate that best available control technologies for toxics (T-BACTs), including appropriate enforcement mechanisms to reduce risks to an acceptable level. T-BACTs may include, but are not limited to:
21 • Restricting idling on site or electrifying warehousing docks to reduce diesel particulate matter;
• Requiring use of newer equipment and/or vehicles;
• Provide charging infrastructure for: electric forklifts, electric yard trucks, local drayage trucks, last mile delivery trucks, electric and fuel-cell heavy duty trucks; and/or
• Install solar panels, zero-emission backup electricity generators, and energy storage to minimize emissions associated with electricity generation at the project site.

T-BACTs identified in the HRA shall be identified as mitigation measures in the environmental document and/or incorporated into the site plan.

MM AIR-3.2 Locate sensitive land uses (e.g., residences, schools, and daycare centers) to avoid incompatibilities with recommended buffer distances identified in the most current version of the CARB Air Quality and Land Use Handbook: A Community Health Perspective (CARB Handbook). Sensitive land uses that are within the recommended buffer distances listed in the CARB Handbook shall provide enhanced filtration units or submit a Health Risk Assessment (HRA) to the City.

If the HRA shows that the project would exceed the applicable SJVAPCD thresholds, mitigation measures capable of reducing potential impacts to an acceptable level must be identified and approved by the City.

MM AIR-4.1 Require developers of projects with the potential to generate significant odor impacts as determined through review of SJVAPCD odor complaint history for similar facilities and consultation with the SJVAPCD, to prepare an odor impact assessment and to implement odor control measures recommended by the SJVAPCD or the City as needed to reduce the impact to a level deemed acceptable by the SJVAPCD. The City’s Planning and Development Department shall verify that all odor control measures have been incorporated into the project design specifications prior to issuing a permit to operate.

PROJECT-SPECIFIC IMPACTS
a) Conflict with or obstruct implementation of the applicable air quality plan? No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic.

The Project’s Air Quality, Health Risk, Greenhouse Gas, and Energy Impact Report (AQ/HR/GHG/Energy Study), dated 2022 prepared by LSA Associates, Inc. (LSA) is included in its entirety as Appendix A. As discussed in the AQ/HR/GHG/Energy Study, CEQA requires that certain projects be analyzed for consistency with the applicable air quality plan. For a project to be consistent with SJVAPCD air quality plans, the pollutants emitted from a project should not exceed the SJVAPCD emission thresholds or cause a significant impact on air 22 quality. In addition, emission reductions achieved through implementation of offset requirements are a major component of the SJVAPCD air quality plans. As analyzed below, construction of the Project would not result in the generation of criteria air pollutants that would exceed SJVAPCD thresholds of significance. Implementation of SJVAPCD Regulation VIII would further reduce construction dust impacts. Regulation VIII (SJVAPCD), Fugitive PM10 Prohibitions, requires actions to prevent, reduce, or mitigate anthropogenic fugitive dust emissions to reduce ambient concentrations of fine particulate matter, PM10. As a result, all construction sites are required to reduce fugitive dust emissions by, but not limited to; street sweeping, road paving improvements, increased urban greening and forestry to improve air quality, and installation of vegetative barriers around/near sources of concern. Rule 2201, New and Modified Stationary Source Review, requires new and modified stationary/industrial sources to provide emission controls and offsets that ensure that stationary sources decline over time and do not impact the applicable air quality plans. Industrial and commercial sources that emit more than two pounds per day of any regulated pollutant are required to obtain an Authority to Construct (ATC) and Permit to Operate (PTO) from the SJVAPCD, and to implement best available control technology (BACT). For such stationary sources that exceed offset thresholds contained in Rule 2201, emission offsets are required. Rule 9510, Indirect Source Review, provides emission reductions needed by the SJVAPCD to fulfill the SJVAPCD’s emission reduction commitments in the PM10 and Ozone Attainment Plans. The rule also provides a mechanism for reducing emissions from the construction of and use of development projects through off-site measures. Lastly, Rule 9510 achieves emission reductions through design features and on-site measures from the construction and use of development projects. As such individual projects within the GP area that exceed project level significance thresholds after accounting for Rule 9510 reductions would be required to implement additional mitigation measures to reduce significant emissions. Operational emissions associated with the Project would not exceed SJVAPCD established significance thresholds for ROG, NOx, CO, sulfur oxides (SOx), PM-10, or PM-2.5 emissions. NOx and PM10 emissions would further be reduced with implementation of Rule 9510 (Indirect Source Review) which requires the reduction of operation emission of NOx by 33.3 percent of the Project’s operational baseline and 50 percent of the Project’s operational PM-10 emissions.

Assembly Bill (AB 617) requires the California Air Resources Board (CARB) and air districts to develop and implement a Community Emission Reduction Plan (CERP) with additional emissions reporting, monitoring, and reduction plans and measures in an effort to reduce air pollution exposure in disadvantaged communities. Given that 20 of the 30 most disadvantaged communities in California are in the San Joaquin Valley, this process is expected to bring additional clean air resources and strategies to many Valley communities.

South Central Fresno is one of the communities selected by the CARB for investment of additional resources under AB 617. SJVAPCD established a steering committee for each of these communities comprising community residents, businesses, community advocates, and government representatives to assist in the development and implementation of community air monitoring and emission reduction programs. As such, AB 617 is implemented by SJVAPCD through their Community Emission Reduction Program (CERP) (2019). The proposed Project is located within the South Central Fresno boundary. The Project would comply with programs implemented by SJVAPCD and would comply with the CERP. 23 .

Therefore, the Project would not conflict with or obstruct implementation of SJVAPCD air quality plans. No new impacts related to conflicts with SJVAPCD’s air quality plans would occur.
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic.

SJVAPCD states that if an individual project results in air emissions of criteria pollutants (ROG, CO, NOx, SOx, PM-10, and PM-2.5) that exceed the SJVAPCD’s recommended yearly thresholds for project-specific impacts, then it would also result in a cumulatively considerable net increase of the criteria pollutant(s) for which the project region is in non-attainment under an applicable federal or state ambient air quality standard. The methodologies from the SJVAPCD adopted Guide for Accessing and Mitigating Air Quality Impacts (GAMAQI) are used in evaluating Project impacts. SJVAPCD has established thresholds for regional pollutant emissions, which are shown in Table 2.

Table 2: SJVAPCD Construction and Operation Thresholds of Significance (Tons per Year)
Pollutant Construction
(tons/year)
Operations
(tons/years)
CO
NOx
100
10 100
10 ROG
SOx
10 27
10 27
PM-10 15 15
PM-2.5 15 15
Source: LSA Associates, Inc., 2022 (Appendix A)
CO = carbon monoxide
NOX = nitrogen oxides
PM-10 = particulate matter less than 10 microns in
diameter
PM-2.5 = particulate matter less than 2.5 microns in
diameter
ROG = reactive organic gases
SOX = sulfur oxides
Construction
Short-term air quality impacts may occur due to the release of particulate emissions generated by grading, paving, building, and other construction related activities. Emissions from 24 construction equipment are also anticipated and would include CO, NOx, ROG, directlyemitted particulate matter PM-2.5 and PM-10, and toxic air contaminants (TACs) such as diesel exhaust particulate matter.

Construction related effects on air quality from the proposed Project would be greatest during the site preparation phase due to the disturbance of soils. As such, the Project would be required to comply with Regulation VIII (Fugitive PM10 Prohibition) to control fugitive dust.

SJVAPCD Rule 8011, General Requirements, and Rule 8021, Construction, Demolition Excavation, Extraction, and Other Earthmoving Activities, would also be applicable. With compliance with Regulation VIII measures and Rules 8011 and 8021, fugitive dust emissions from construction activities would not result in adverse air quality impacts.

Table 3: Project Construction Emissions
Construction
Year
Total Regional Pollutant Emissions1
(tons/year)
ROG NOx CO SOx PM-10 PM-2.5
2022 0.1 1.5 1.1 <0.1 0.2 0.1
2023 0.3 4.0 3.6 <0.1 0.5 0.2
2024 0.8 0.4 0.3 <0.1 <0.1 <0.1
Maximum 0.8 4.0 3.6 <0.1 0.5 0.2

SJVAPCD
Thresholds 10.0 10.0 100.0 27.0 15.0 15.0
Threshold
Exceeded? No No No No No No
Source: LSA Associates, Inc., 2022 (Appendix A)
1 All on-site and off-site emissions are presented as construction mitigation in the CalEEMod model output files.

As shown in Table 3, construction emissions associated with the Project would not exceed the SJVAPCD’s thresholds for ROG, NOx, CO, SOx, PM-2.5, or PM-10 emissions. Therefore, construction of the proposed Project would not result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is in nonattainment under an applicable federal or State AAQS, impacts are less than significant, requiring no mitigation.

No new impacts related to generation of cumulatively considerable net increase of any criteria pollutant during construction would occur.

Operation
Operational activities associated with the Project would result in emissions of CO, VOCs, NOX, SOX, PM2.5, and PM10. Long-term air pollutant of such emission impacts are those associated with mobile sources (e.g., vehicle trips), energy sources (e.g., electricity and natural gas), area sources (e.g., architectural coatings and the use of landscape maintenance equipment), and off-road sources (e.g., forklifts) related to the proposed Project.

The primary emissions associated with the Project are regional in nature, meaning air pollutants rapidly dispersed on release, or vehicle emissions. 25 The annual emissions associated with Project operational trip generation, energy, and area sources are identified below in Table 4. As shown, the Project would not exceed the significance criteria for annual ROG, NOx, CO, SOx, PM-2.5, or PM-10 emissions. As a result, the proposed Project would not have a significant effect on regional air quality. Operation of the Project would not result in a cumulatively considerable net increase of any criteria pollutant for which the Project is nonattainment under applicable CAAQS or NAAQS, and impacts are less than significant.

The Project would be required to implement District Rule 9510 Indirect Source Review as the Project would develop more than the 100,000 sf of industrial space threshold. Implementation of Rule 9510 would reduce operational emissions of NOx and PM-10 by 33.3 percent and 50 percent, respectively. The Project Applicant must submit an Air Impact Assessment to the SJVAPCD consistent with Rule 9510 prior to obtaining building permits. Therefore, impacts are less than significant, requiring no mitigation.

Table 4: Proposed Project Operational Emissions
Emission Type
Pollutant Emissions
(tons/day)
ROG NOx CO SOx PM-10 PM-2.5
Area Source 1.1 <0.1 <0.1 0.0 <0.1 <0.1
Energy Source <0.1 0.2 0.2 <0.1 <0.1 <0.1
Mobile Sour–e -
Vehicles 0.4 0.6 5.5 <0.1 1.6 0.4
Mobile Sour–e -
Trucks

0.1 8.2 1.1 0.1 2.1 0.7
Off-Road
Sources
<0.1 <0.1 <0.1 <0.1 <0.1 <0.1
Total Project
Emissions 1.6 9.0 6.8 0.1 3.7 1.1

SJVAPCD
Thresholds 10.0 10.0 100.0 27.0 15.0 15.0
Threshold
Exceeded?
No No No No No No
Source: LSA Associates, Inc., 2022 (Appendix A)
As a result of the Project’s construction and operational emissions not exceeding the SJVAPCD Thresholds, the proposed Project would not have a significant effect on regional air quality and impacts are considered to be less than significant, requiring no mitigation. No new impacts related to generation of cumulatively considerable net increase of any criteria pollutant during construction would occur.
c) Expose sensitive receptors to substantial pollutant concentrations? 26 No New Impact. The GP PEIR determined the GP Update would have a significant and unavoidable impact with mitigation incorporated (MM AIR-2.1 through -4.1) regarding this topic.

According to the AQ/HR/GHG/Energy Study, the closest sensitive receptors are residential uses located more than 1,500 feet from the Project site to the west along S. Cherry Avenue and the nearest worker receptors are located adjacent to the north, east, south, and west borders of the Project site.

The Health Risk Assessment (HRA) evaluated Project related construction-period health risks to off-site receptors as seen in Table 5. Results of the analysis assumed the use of Tier 2 construction equipment to the nearest sensitive receptors.

Table 5: Health Risks from Project Construction to Off-Site Receptors Location
Carcinogenic
Inhalation Health
Risk
in One Million
Chronic
Inhalation
Hazard Index
Acute Inhalation
Hazard Index
Worker Receptor Risk 1.07 0.059 0.000
Sensitive Receptor Risk 5.21 0.005 0.000

SJVAPCD
Significance
Threshold
20 1.0 1.0
Significant? No No No
Source: LSA (April 2022).

SJVAPCD = San Joaquin Valley Air Pollution Control District As shown in Table 5, the maximum cancer risk for the sensitive receptor would be 5.21 in one million, less than the threshold of 20 in one million. The worker receptor risk would be lower at 1.07 in one million. The total chronic hazard index would be 0.059 for the worker receptor and 0.005 for the sensitive receptor, which is below the threshold of 1.0. In addition, the total acute hazard index would be nominal (0.000), which would also not exceed the threshold of

1.0. As these results show, all health risk levels to nearby residents from construction-related emissions of TACs would be below the SJVAPCD’s HRA thresholds. No significant health risk would occur from Project construction emissions. No new impacts related to health risks from TACs during construction would occur.

According to the HRA, the potential operational health risk to people living and working near the proposed Project are associated with the exhaust of diesel-powered trucks and equipment. The carcinogenic and chronic health risks from the proposed Project are shown in Table 6. The residential risk incorporates both the risk for a child living in a nearby residence for 9 years (the standard period of time for child risk) and an adult living in a nearby residence for 70 years (considered a conservative period of time for an individual to live in any one residence).
27 Table 6: Health Risks from Project Operation to Off-Site Receptors Location
Carcinogenic
Inhalation
Health Risk in
One Million
Chronic
Inhalation Hazard
Index
Acute Inhalation
Hazard Index
Worker Receptor Risk 3.04 0.006 0.000
Sensitive Receptor Risk 1.39 0.000 0.000

SJVAPCD
Significance
Threshold
20 1.0 1.0
Significant? No No No
Source: LSA (April 2022).

SJVAPCD = San Joaquin Valley Air Pollution Control District As shown in Table 6, the maximum cancer risk for the sensitive receptor would be 3.04 in one million, less than the threshold of 20 in one million. The worker receptor risk would be lower at 1.39 in one million. The total chronic hazard index would be 0.006 for the worker receptor and nominal (0.000) for the sensitive receptor, which is below the threshold of 1.0. In addition, the total acute hazard index would be nominal (0.000), which would also not exceed the threshold of 1.0. As these results show, all health risk levels to nearby residents from operation-related emissions of TACs would be well below the SJVAPCD’s HRA thresholds.

As such, the Project will not cause a significant human health or cancer risk to nearby residences, requiring no mitigation. No new impacts related to health risks from TACs during operations would occur.
d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
No New Impact. The GP PEIR determined the GP Update would have a less than significant impact with mitigation incorporated (MM AIR-4.1) regarding this topic.

Heavy-duty grading equipment is likely to be used within the Project site during construction and would emit odors, primarily from the equipment exhaust. However, the construction activity would cease to occur after individual construction is completed. Delivery trucks may occasionally emit odors, primarily from exhaust. However, the Air District limits vehicle idling times such that any exhaust odor would be temporary in nature and would disperse quickly.

No other sources of objectionable odors have been identified for the Project, and no mitigation measures are required. No new impacts related to odors during construction would occur.

Furthermore, the SJVAPCD addresses odor criteria within the Guide for Assessing and Mitigating Air Quality Impacts (GAMAQI) and the district has not established a rule standard regarding odor emissions. The district has a nuisance rule stating “Any project with the potential to frequently expose members of the public to objectionable odors to be deemed to have a significant impact.” Construction odor emission would be temporary and not frequent. 28 Project operations would not involve any activities that would emit objectionable odors and would not require odor control measures. As such, MM AIR-4.1 requiring an odor impact assessment is not applicable to the proposed Project. Therefore, objectionable odors affecting a substantial number of people would not occur as a result of the Project. No new impacts related to odors during operations would occur.

CONCLUSION
With regards to the issue area of Air Quality, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. Mitigation measures contained within the GP PEIR would be required to reduce Project specific impacts to less than significant, however impacts c and d are significant and unavoidable.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
MM AIR-2.1 Prior to future discretionary project approval, development project applicants shall prepare and submit to the Director of the City Planning and Development Department, or designee, a technical assessment evaluating potential project construction phase-related air quality impacts. The evaluation shall be prepared in conformance with SJVAPCD methodology for assessing construction impacts. If construction related air pollutants are determined to have the potential to exceed the SJVAPCD adopted threshold of significance, the Planning and Development Department shall require that applicants for new development projects incorporate mitigation measures into construction plans to reduce air pollutant emissions during construction activities. The identified measures shall be included as part of the Project Conditions of Approval.

Possible mitigation measures to reduce construction emissions include but are not limited to:
• Install temporary construction power supply meters on site and use these to provide power to electric power tools whenever feasible. If temporary electric power is available on site, forbid the use of portable gasoline- or dieselfueled electric generators. • Use of diesel oxidation catalysts and/or catalyzed diesel particulate traps on diesel equipment, as feasible.
• Maintain equipment according to manufacturers’ specifications. 29 • Restrict idling of equipment and trucks to a maximum of 5 minutes (per California Air Resources Board [CARB] regulation).
• Phase grading operations to reduce disturbed areas and times of exposure. • Avoid excavation and grading during wet weather.
• Limit on-site construction routes and stabilize construction entrance(s). • Remove existing vegetation only when absolutely necessary. • Sweep up spilled dry materials (e.g., cement, mortar, or dirt track-out) immediately. Never attempt to wash them away with water. • Use only minimal water for dust control.
• Store stockpiled materials and wastes under a temporary roof or secured plastic sheeting or tarp.

Status: MM AIR-2.1 satisfied by Air Quality, Health Risk, Greenhouse Gas, and Energy Impact Report, dated 2022 prepared by LSA Associates, Inc. and included as Appendix A.

MM AIR-2.2 Prior to future discretionary project approval, development project applicants shall prepare and submit to the Director of the City Planning and Development Department, or designee, a technical assessment evaluating potential project operation-related air quality impacts. The evaluation shall be prepared in conformance with SJVAPCD methodology in assessing air quality impacts. If operation-related air pollutants are determined to have the potential to exceed the SJVAPCD-adopted thresholds of significance, the Planning and Development Department shall require that applicants for new development projects incorporate mitigation measures to reduce air pollutant emissions during operational activities. The identified measures shall be included as part of the Project Conditions of Approval. Possible mitigation measures to reduce long-term emissions include but are not limited to:
• For site-specific development that requires refrigerated vehicles, the construction documents shall demonstrate an adequate number of electrical service connections at loading docks for plugging in the anticipated number of refrigerated trailers to reduce idling time and emissions. • Applicants for manufacturing and light industrial uses shall consider energy storage (i.e., battery) and combined heat and power (CHP, also known as cogeneration) in appropriate applications to optimize renewable energy generation systems and avoid peak energy use.
• Site-specific developments with truck delivery and loading areas and truck parking spaces shall include signage as a reminder to limit idling of vehicles while parked for loading/unloading in accordance with CARB Rule 2845 (13 California Code of Regulations [CCR] Chapter 10, Section 2485). • Require that 240-volt electrical outlets or Level 3 chargers be installed in parking lots that would enable charging of neighborhood electric vehicles (NEVs) and/or battery powered vehicles.
30 • Maximize use of solar energy including solar panels; installing the maximum possible number of solar energy arrays on building roofs throughout the city to generate solar energy.
• Maximize the planting of trees in landscaping and parking lots. • Use light-colored paving and roofing materials.
• Require use of electric or alternatively fueled street-sweepers with HEPA filters.
• Require use of electric lawn mowers and leaf blowers. • Utilize only Energy Star heating, cooling, and lighting devices, and appliances.
• Use of water-based or low volatile organic compound (VOC) cleaning products.

Status: MM AIR-2.2 satisfied by Air Quality, Health Risk, Greenhouse Gas, and Energy Impact Report, dated 2022 prepared by LSA Associates, Inc. and included as Appendix A.

MM AIR-3.1 Prior to future discretionary approval for projects that require environmental evaluation under CEQA, the City of Fresno shall evaluate new development proposals for new industrial or warehousing land uses that: (1) have the potential to generate 100 or more truck trips per day or have 40 or more trucks with operating diesel-powered transport refrigeration units, and (2) are within 1,000 feet of a sensitive land use (e.g., residential, schools, hospitals, or nursing homes), as measured from the property line of the project to the property line of the nearest sensitive use. Such projects shall submit a Health Risk Assessment (HRA) to the City Planning and Development Department. The HRA shall be prepared in accordance with policies and procedures of the most current State Office of Environmental Health Hazard Assessment (OEHHA) and the SJVAPCD. If the HRA shows that the incremental health risks exceed their respective thresholds, as established by the SJVAPCD at the time a project is considered, the Applicant will be required to identify and demonstrate that best available control technologies for toxics (T-BACTs), including appropriate enforcement mechanisms to reduce risks to an acceptable level. T-BACTs may include, but are not limited to:
• Restricting idling on site or electrifying warehousing docks to reduce diesel particulate matter;
• Requiring use of newer equipment and/or vehicles;
• Provide charging infrastructure for: electric forklifts, electric yard trucks, local drayage trucks, last mile delivery trucks, electric and fuel-cell heavy duty trucks; and/or
• Install solar panels, zero-emission backup electricity generators, and energy storage to minimize emissions associated with electricity generation at the project site.
31 T-BACTs identified in the HRA shall be identified as mitigation measures in the environmental document and/or incorporated into the site plan.

Status: MM AIR-3.1 satisfied by Air Quality, Health Risk, Greenhouse Gas, and Energy Impact Report, dated 2022 prepared by LSA Associates, Inc. and included as Appendix A.

MM AIR-3.2 Locate sensitive land uses (e.g., residences, schools, and daycare centers) to avoid incompatibilities with recommended buffer distances identified in the most current version of the CARB Air Quality and Land Use Handbook: A Community Health Perspective (CARB Handbook). Sensitive land uses that are within the recommended buffer distances listed in the CARB Handbook shall provide enhanced filtration units or submit a Health Risk Assessment (HRA) to the City.

If the HRA shows that the project would exceed the applicable SJVAPCD thresholds, mitigation measures capable of reducing potential impacts to an acceptable level must be identified and approved by the City.

Status: MM AIR-3.2 satisfied by Air Quality, Health Risk, Greenhouse Gas, and Energy Impact Report, dated 2022 prepared by LSA Associates, Inc. and included as Appendix A. 32 ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
IV. BIOLOGICAL RESOURCES – Would the project:
a) Have a substantial adverse
effect, either directly or
through habitat modifications,
on any species identified as a
candidate, sensitive, or
special status species in local
or regional plans, policies, or
regulations, or by the
California Department of Fish
and Game or U.S. Fish and
Wildlife Service?
b) Have a substantial adverse
effect on any riparian habitat
or other sensitive natural
community identified in local
or regional plans, policies,
regulations or by the
California Department of Fish
and Game or US Fish and
Wildlife Service?
c) Have a substantial adverse
effect on federally protected
wetlands as defined by
Section 404 of the Clean
Water Act (including, but not
limited to, marsh, vernal pool,
coastal, etc.) through direct
removal, filling, hydrological
interruption, or other means?
33 ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
d) Interfere substantially with
the movement of any native
resident or migratory fish or
wildlife species or with
established native resident or
migratory wildlife corridors, or
impede the use of native
wildlife nursery sites?
e) Conflict with any local
policies or ordinances
protecting biological
resources, such as a tree
preservation policy or
ordinance?
f) Conflict with the provisions
of an adopted Habitat
Conservation Plan, Natural
Community Conservation
Plan, or other approved local,
regional, or state habitat
conservation plan?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
The GP PEIR discussed impacts to biological resources in Section 4.4. The GP PEIR analyzed the biological resources that are known to occur within the Planning Area, including vegetation communities, special‐status plant and wildlife species and their associated habitats, and special‐status natural communities, including riparian communities and wetlands. The study area for the GP PEIR included the Planning Area and areas within an approximately 5‐mile‐radius because implementation of the GP could have either direct or indirect effects on biological resources occurring within these areas. The GP PEIR also analyzed potential cumulative impacts from the eight counties that are located within the San Joaquin Valley; all of Kings County, most of Fresno, Kern, Merced, and Stanislaus counties, and portions of Madera, San Luis Obispo, and Tulare counties.

The GP PEIR determined that impacts to sensitive plant and animal species including suitable habitat could potentially occur from build out of the GP, and it was acknowledged that future projects may not be able to avoid such impacts. However, it was determined that buildout of 34 the GP Planning area was less than significant with implementation of the following the GP objectives and policies including GP PEIR MM BIO-1.1 through -3.2. Additionally, future projects would be required to implement GP objectives and policies (including project design features) and implement project-level mitigation that will reduce potential project-specific impacts to special‐status species and their associated habitats. According to the GP PEIR, development facilitated by the proposed GP would largely avoid impacts to wildlife movement corridors by emphasizing intensification/reuse of existing urbanized areas. Additionally, development under the GP would be in substantial conformance with federal, state, and local applicable policies protecting biological resources and the GP would not conflict with the provisions of any adopted local, regional, or state habitat conservation plan.

GP GOALS AND POLICIES
The following GP goals and policies pertain to the Project’s biological resources:

Policy POSS‐5‐a. Habitat Area Acquisition. Support state, federal, and local programs to acquire significant habitat areas for permanent protection and/or conjunctive educational and recreational use.

Policy POSS‐5‐b. Habitat Conservation Plans. Participate in cooperative, multi‐jurisdictional approaches for area‐wide habitat conservation plans to preserve and protect rare, threatened, and endangered species.

Policy POSS‐5‐c. Buffers for Natural Areas. Require development projects, where appropriate and warranted, to incorporate natural features (such as ponds hedgerows and wooded strips) to serve as buffers for adjacent natural areas with high ecological value.

Policy POSS‐5‐d. Guidelines for Habitat Conservation. Establish guidelines for habitat conservation and mitigation programs. These programs will include:
• An evaluation of the site’s environmental setting and proposed design and operating parameters of proposed mitigation measures.
• A graphic depiction of land to be acquired or set aside for mitigation activities. • Mitigation site preparation plans.
• Specification of the types and sources of plant material used for any revegetation. • Water irrigation plans.
• Post‐planting maintenance and other operational measures to ensure successful mitigation.
• Monitoring at an appropriate frequency by qualified personnel and reporting of data collected
• to permitting agencies.

Policy POSS‐5‐e. Pursue development of conjunctive habitat and recreational trail uses in flood control and drainage projects.
35 Policy POSS‐5‐f. Regional Mitigation and Habitat Restoration. Coordinate habitat restoration programs with responsible agencies to take advantage of opportunities for a coordinated regional mitigation program.

Policy POSS‐6‐b. Effects of Stormwater Discharge. Support efforts to identify and mitigate cumulative adverse effects on aquatic life from stormwater discharge to the San Joaquin River.
• Discharge of run off from industrial and commercial land uses to the San Joaquin River or other riparian corridors shall be avoided.
• Approve development on sites having drainage (directly or indirectly) to the San Joaquin River or other riparian areas upon a finding that adequate measures for preventing pollution of natural bodies of water from their runoff will be implemented. • Periodically monitor water quality and sediments near drainage out falls to riparian areas. If unacceptable levels of contaminant(s) occur, remedial measures shall be promptly instituted.

GP PEIR MITIGATION MEASURES
MM BIO‐1.1 Construction of a proposed project shall avoid, where possible, vegetation communities that provide suitable habitat for a special-status species known to occur within the Planning Area. If construction within potentially suitable habitat must occur, the presence/absence of any special-status plant or wildlife species must be determined prior to construction, to determine if the habitat supports any special-status species. If a special-status species are determined to occupy any portion of a project site, avoidance and minimization measures shall be incorporated into the construction phase of a project to avoid direct or incidental take of a listed species to the greatest extent feasible.

MM BIO‐1.2 Direct or incidental take of any state or federally listed species shall be avoided to the greatest extent feasible. If construction of a proposed project will result in the direct or incidental take of a listed species, consultation with the resources agencies and/or additional permitting may be required. Agency consultation through the CDFW 2081 and USFWS Section 7 or Section 10 permitting processes shall take place prior to any action that may result in the direct or incidental take of a listed species. Specific mitigation measures for direct or incidental impacts to a listed species will be determined on a case-bycase basis through agency consultation.

MM BIO‐1.3 Development within the Planning Area shall avoid, where possible, special-status natural communities and vegetation communities that provide suitable habitat for special-status species. If a proposed project will result in the loss of a special-status natural community or suitable habitat for special-status species, compensatory habitat-based mitigation is required under CEQA and 36 CESA. Mitigation shall consist of preserving on-site habitat, restoring similar habitat or purchasing off-site credits from an approved mitigation bank.

Compensatory mitigation shall be determined through consultation with the City and/or resource agencies. An appropriate mitigation strategy and ratio shall be agreed upon by the developer and lead agency to reduce project impacts to special-status natural communities to a less than significant level. Agreed-upon mitigation ratios shall depend on the quality of the habitat and presence/absence of a special-status species. The specific mitigation for project level impacts shall be determined on a case-by-case basis.

MM BIO‐1.4 Proposed projects within the Planning Area should avoid, if possible, construction within the general nesting season of February through August for avian species protected under Fish and Game Code 3500 and the Migratory Bird Treaty Act (MBTA), if it is determined that suitable nesting habitat occurs on a project site. If construction cannot avoid the nesting season, a preconstruction clearance survey shall be conducted by a qualified biologist to determine if any nesting birds or nesting activity is observed on or within 500- feet of a project site. If an active nest is observed during the survey, a biological monitor shall be on site to ensure that no proposed project activities would impact the active nest. A suitable buffer shall be established around the active nest until the nestlings have fledged and the nest is no longer active. Project activities may continue in the vicinity of the nest only at the discretion of the biological monitor. Prior to commencement of grading activities and issuance of any building permits, the Director of the City of Fresno Planning and Development Department, or designee, shall verify that all proposed project grading and construction plans include specific documentation regarding the requirements of the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code Section 3503, that preconstruction surveys have been completed and the results reviewed by staff, and that the appropriate buffers (if needed) are noted on the plans and established in the field.

MM BIO‐2.1 A pre‐construction clearance survey shall be conducted by a qualified biologist to determine if a proposed project will result in the removal or impact to any riparian habitat and/or a special‐ status natural community with potential to occur in the Planning Area, compensatory habitat‐based mitigation shall be required to reduce project impacts. Compensatory mitigation must involve the preservation or restoration or the purchase of off‐site mitigation credits for impacts to riparian habitat and/or a special‐status natural community.

Mitigation must be conducted in‐kind or within an approved mitigation bank in the region. The specific mitigation ratio for habitat‐based mitigation shall be determined through consultation with the appropriate agency (i.e., CDFW or USFWS) on a case‐by‐case basis. The project applicant/developer for a proposed project shall develop and implement appropriate mitigation regarding impacts on their respective jurisdictions.
37 MM BIO‐2.2 A pre‐construction clearance survey shall be conducted by a qualified biologist to determine if a proposed project will result in significant impacts to streambeds or waterways protected under Section 1600 of Fish and Wildlife Code and Section 404 of the CWA. The project applicant/developer for a proposed project shall consult with partner agencies such as CDFW and/or USACE to develop and implement appropriate mitigation regarding impacts on their respective jurisdictions, determination of mitigation strategy, and regulatory permitting to reduce impacts, as required for projects that remove riparian habitat and/or alter a streambed or waterway. The project applicant/developer shall implement mitigation as directed by the agency with jurisdiction over the particular impact identified.

MM BIO‐2.3 Prior to project approval, a pre‐construction clearance survey shall be conducted by a qualified biologist to determine if a proposed project will result in project‐related impacts to riparian habitat or a special‐status natural community or if it may result in direct or incidental impacts to special‐status species associated with riparian or wetland habitats. The project applicant/developer for a proposed project shall be obligated to address project‐specific impacts to special‐status species associated with riparian habitat through agency consultation, development of a mitigation strategy, and/or issuing incidental take permits for the specific special‐status species, as determined by the CDFW and/or USFWS.

MM BIO‐3.1 If a proposed project will result in the significant alteration or fill of a federally protected wetland, a formal wetland delineation conducted according to USACE accepted methodology is required for each project to determine the extent of wetlands on a project site. The delineation shall be used to determine if federal permitting and mitigation strategy are required to reduce project impacts. Acquisition of permits from USACE for the fill of wetlands and USACE approval of a wetland mitigation plan would ensure a “no net loss” of wetland habitat within the Planning Area. Appropriate wetland mitigation/creation shall be implemented in a ratio according to the size of the impacted wetland.

MM BIO-3.2 In addition to regulatory agency permitting, Best Management Practices identified from a list provided by the USACE shall be incorporated into the design and construction phase of the project to ensure that no pollutants or siltation drain into a federally protected wetland. Project design features such as fencing, appropriate drainage and incorporating detention basins shall assist in ensuring project-related impacts to wetland habitat are minimized to the greatest extent feasible.

PROJECT-SPECIFIC IMPACTS
38 a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact with mitigation incorporated (MM BIO-1.1 through -1.4) regarding this topic.

The Project site consists of highly disturbed and previously grubbed and cleared vacant land that is surrounded by industrial and commercial development. A Biological Technical Memo (BTM) (Appendix C) was prepared pursuant to MM BIO-1.1 through 1.4 and determined the Project site contained no drainages, and no sensitive species were observed during site surveys. The Project site is within an Irrigated Row and Field Crops designation according to Exhibit 5.4-A, Vegetation Communities Map Index in the GP PEIR. As defined in the GP PEIR, irrigated row and field crops contain active agriculture and are significantly disturbed.

Therefore, such designation does not provide suitable habitat for any special‐status plant species and limited habitat for special‐status wildlife species. Furthermore, the Project site is not identified within an area of special-status wildlife species or special-status plant species and critical habitat.

The BTM concluded that no significant ecological areas or land preserves are on or adjacent to the Project site. In addition, no species of significance were observed during the site visit.

There was no sign of kangaroo rats, kit fox, or blunt nosed leopard lizard habitat. As a result, MM BIO-1.1 through 1.4 are not applicable to the proposed Project. Therefore, the Project would have no impacts and no new impacts on any species identified as a candidate, sensitive, or special status species.
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service? No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact with mitigation incorporated (MM BIO-2.1 through -2.3) regarding this topic.

As discussed above, the Project site is disturbed vacant land. As previously stated, the Project site is not identified within an area of special-status wildlife species or special-status plant species and critical habitat.

The nearest sensitive habitat to the Project site are two Lacustrine designations; 0.2 miles to the west and 1.3 miles to the northwest. As defined in the GP PEIR, “Lacustrine communities consist of standing/open waters in topographic depressions (i.e., lakes) or dammed river channels. Lacustrine communities lack persistent emergent vegetation but may have submerged or floating‐leaved aquatic vegetation. Generally, lacustrine systems are surrounded by hydrophytic plants, grasses, and trees.” However, the Project does not propose alteration or impacts to these offsite Lacustrine areas. In satisfaction of MM BIO-2.1 through 39 -2.3, the BTM substantiates there that the Project does not contain riparian habitat and/or a special‐ status natural community. Therefore, the Project would result in no new impact on riparian habitat or other sensitive natural communities. c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
No New Impact The GP PEIR determined the GP Update would result in a less than significant impact with mitigation incorporated (MM BIO-3.1 through -3.2) regarding this topic.

As discussed above, the Project site is fully disturbed vacant land. The BTM substantiates that the Project site does not include drainages or wetlands. As such, MM BIO- 3.1 and BIO3.2 do not apply to the proposed Project. Therefore, the Project would result in no new impact on riparian habitat or other sensitive natural community. d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant regarding this topic
As discussed above, the Project site is fully disturbed vacant land. The Project site does not contain established native resident or migratory wildlife corridors and is not used as a native wildlife nursery site. The Project site is bordered by industrial and commercial development and would not result in impacts to migratory fish species. The Project site includes Russian thistle and Red brome, an invasive species that would be removed as part of the Project. MM BIO-1.4 applies to the Project and a pre-construction nesting bird survey would be required if clearing and grubbing of such vegetation occurs during the nesting bird season to ensure construction activities would not result in the disturbance of nesting migratory species covered under the Migratory Bird Treaty Act (MBTA). Therefore, a preconstruction nesting bird survey is not required. The Project would result in no new impact on migratory fish or wildlife species. e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
No New Impact. This topic was evaluated in the GP PEIR and was determined to be less than significant. As analyzed in the GP PEIR, future development would be required to comply with Article 3 of Section 13 of the FMC. The FMC requires preservation of trees within public property, including parkways, to beautify the City, purify its air, and provide shade for its inhabitants. No new impacts related to consistency with the City’s public tree ordinance would occur as the site is vacant consisting of only weeds and grass. f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural 40 Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
No New Impact. The GP PEIR determined the GP Update would result in no impact regarding this topic.

As concluded in the GP PEIR, the City of Fresno Planning Area is not located within the boundaries of any approved or draft Habitat Conservation Plan (HCP), Natural Community Conservation Plan (NCCP), or other adopted local, regional or state HCP. Therefore, development of the Project will not result in any impacts to an adopted HCP or NCCP.

Therefore, the Project would result in no new impact associated with consistency with habitat conservation plans.

CONCLUSION
With regards to the issue area of Biological Resources, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No mitigation measures contained within the GP PEIR would be required because Project specific impacts would be less than significant.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
MM BIO‐1.4 Proposed projects within the Planning Area should avoid, if possible, construction within the general nesting season of February through August for avian species protected under Fish and Game Code 3500 and the Migratory Bird Treaty Act (MBTA), if it is determined that suitable nesting habitat occurs on a project site. If construction cannot avoid the nesting season, a preconstruction clearance survey shall be conducted by a qualified biologist to determine if any nesting birds or nesting activity is observed on or within 500- feet of a project site. If an active nest is observed during the survey, a biological monitor shall be on site to ensure that no proposed project activities would impact the active nest. A suitable buffer shall be established around the active nest until the nestlings have fledged and the nest is no longer active. Project activities may continue in the vicinity of the nest only at the discretion of the biological monitor. Prior to commencement of grading activities and issuance of any building permits, the Director of the City of Fresno Planning and Development Department, or designee, shall verify that all proposed project 41 grading and construction plans include specific documentation regarding the requirements of the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code Section 3503, that preconstruction surveys have been completed and the results reviewed by staff, and that the appropriate buffers (if needed) are noted on the plans and established in the field.
42 ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
V. CULTURAL RESOURCES – Would the project:
a) Cause a substantial
adverse change in the
significance of a historical
resource as defined in
Section 15064.5?
b) Cause a substantial
adverse change in the
significance of an
archaeological resource
pursuant to Section 15064.5?
c) Disturb any human
remains, including those
interred outside of formal
cemeteries?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
The GP PEIR discussed impacts to cultural resources in Section 4.5. According to the GP PEIR, the GP Planning Area contains several designated historic resources that may be affected by development under the GP. Although many areas have been previously disturbed by farming activities or previous structural development, future development within the Planning Area will impact such resources. In addition, required excavation or construction activities for projects within the Planning Area will potentially occur in undisturbed soils.

Further stated in the GP PEIR, only 0.3 percent of the Planning Area has been surveyed by a professional archaeologist, therefore the prehistoric archaeological sensitivity of the majority of the Planning Area is uncertain and impacts were considered significant. However, the GP PEIR concluded that impacts to cultural resources would be less than significant with mitigation incorporated (MM CUL-1.1, -2, and -3 seen below). All projects in the City are subject to CEQA review, which would include evaluation of potential Project‐related impacts to national or California Register‐listed properties.

GP GOALS AND POLICIES
The GP goals and policies that pertain to the Project’s cultural resources:
43 Objective HCR‐1. Maintain a comprehensive, citywide preservation program to identify, protect and assist in the preservation of Fresno’s historic and cultural resources.

Policy HCR‐1‐c. Historic Preservation Ordinance. Maintain the provisions of the City’s Historic Preservation Ordinance, as may be amended, and enforce the provisions as appropriate.

Objective HCR‐2: Identify and preserve Fresno’s historic and cultural resources which reflect important cultural, social, economic and architectural features so that community residents will have a foundation upon which to measure and direct physical change.

Policy HCR‐2‐a: Identification and Designation of Historic Properties. City staff and the Historic Preservation Commission shall work in tandem to identify potential historic resources and districts and to prepare nomination forms for Fresno’s Local Register of Historic Resources. Historic resources may include not only buildings but also structures, objects and sites, as well as cultural and historic landscapes and traditional cultural properties (as defined by the National Park Service) – examples include farm complexes, canal systems, signage, gardens, infrastructure such as lighting and street furniture, and landscaped boulevards. As appropriate, resources may be forwarded to the State Historical Resources Commission for consideration for the California Register of Historical Resources and/or the National Register of Historic Places.

Policy HCR‐2‐b: Historic Surveys. Prepare historic surveys according to California Office of Historic Preservation protocols, as funding is available. Prioritize the survey of resources located on parcels within the Bus Rapid Transit corridors slated for development and intensification.

Policy HCR‐2‐c: Project Development. Prior to project approval, a subject parcel and its Area of Potential Effects (APE), without benefit of a prior historic survey, will be evaluated and reviewed for the potential for historical and/or cultural resources by a professional who meets the Secretary of Interior’s Qualifications. Survey costs shall be the responsibility of the project developer.

Policy HCR‐3‐c: Context Sensitive Design. Work with the development and planning communities to ensure that infill development is context sensitive in its design, massing, set‐ backs, color, and architectural detailing.

GP PEIR MITIGATION MEASURES
MM CUL‐1.1 If previously unknown resources are encountered before or during grading activities, construction shall stop in the immediate vicinity of the find and a qualified historical resources specialist shall be consulted to determine whether the resource requires further study. The qualified historical resources specialist shall make recommendations to the City on the measures that shall be implemented to protect the discovered resources, including but not limited to 44 excavation of the finds and evaluation of the finds in accordance with Section 15064.5 of the CEQA Guidelines and the City’s Historic Preservation Ordinance.

If the resources are determined to be unique historical resources as defined under Section 15064.5 of the CEQA Guidelines, measures shall be identified by the monitor and recommended to the Lead Agency. Appropriate measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds.

No further grading shall occur in the area of the discovery until the Lead Agency approves the measures to protect these resources. Any historical artifacts recovered as a result of mitigation shall be provided to a City‐approved institution or person who is capable of providing long‐term preservation to allow future scientific study.

MM CUL‐2 Subsequent to a preliminary City review of the Project grading plans, if there is evidence that a Project will include excavation or construction activities within previously undisturbed soils, a field survey and literature search for prehistoric archaeological resources shall be conducted. The following procedures shall be followed.

If prehistoric resources are not found during either the field survey or literature search, excavation and/or construction activities can commence. In the event that buried prehistoric archaeological resources are discovered during excavation and/or construction activities, construction shall stop in the immediate vicinity of the find and a qualified archaeologist shall be consulted to determine whether the resource requires further study. The qualified archaeologist shall make recommendations to the City on the measures that shall be implemented to protect the discovered resources, including but not limited to excavation of the finds and evaluation of the finds in accordance with Section 15064.5 of the CEQA Guidelines. If the resources are determined to be unique prehistoric archaeological resources as defined under Section 15064.5 of the CEQA Guidelines, mitigation measures shall be identified by the monitor and recommended to the Lead Agency. Appropriate measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds. No further grading shall occur in the area of the discovery until the Lead Agency approves the measures to protect these resources. Any prehistoric archaeological artifacts recovered as a result of mitigation shall be provided to a City‐approved institution or person who is capable of providing long‐term preservation to allow future scientific study.

If prehistoric resources are found during the field survey or literature review, the resources shall be inventoried using appropriate State record forms and submit the forms to the Southern San Joaquin Valley Information Center. The resources 45 shall be evaluated for significance. If the resources are found to be significant, measures shall be identified by the qualified archaeologist. Similar to above, appropriate mitigation measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds. In addition, appropriate mitigation for excavation and construction activities in the vicinity of the resources found during the field survey or literature review shall include an archaeological monitor. The monitoring period shall be determined by the qualified archaeologist. If additional prehistoric archaeological resources are found during excavation and/or construction activities, the procedure identified above for the discovery of unknown resources shall be followed.

MM CUL‐3 In the event that human remains are unearthed during excavation and grading activities of any future development project, all activity shall cease immediately.

Pursuant to Health and Safety Code (HSC) Section 7050.5, no further disturbance shall occur until the County Coroner has made the necessary findings as to origin and disposition pursuant to PRC Section 5097.98(a). If the remains are determined to be of Native American descent, the coroner shall within 24 hours notify the Native American Heritage Commission (NAHC). The NAHC shall then contact the most likely descendent of the deceased Native American, who shall then serve as the consultant on how to proceed with the remains. Pursuant to PRC Section 5097.98(b), upon the discovery of Native American remains, the landowner shall ensure that the immediate vicinity, according to generally accepted cultural or archaeological standards or practices, where the Native American human remains are located is not damaged or disturbed by further development activity until the landowner has discussed and conferred with the most likely descendants regarding their recommendations, if applicable, taking into account the possibility of multiple human remains. The landowner shall discuss and confer with the descendants all reasonable options regarding the descendants' preferences for treatment.

PROJECT-SPECIFIC IMPACTS
a) Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact with mitigation incorporated (MM CUL-1.1 and 1.2) regarding this topic.

CEQA defines a historical resource as something that meets one or more of the following criteria: (1) listed in, or determined eligible for listing in, the California Register of Historical Resources; (2) listed in a local register of historical resources as defined in Public Resources Code (PRC) Section 5020.1(k); (3) identified as significant in a historical resource survey meeting the requirements of PRC Section 5024.1(g); or (4) determined to be a historical 46 resource by a project’s Lead Agency (PRC Section 21084.1 and CEQA Guidelines Section 15064.5[a]).

The California Register defines a “historical resource” as a resource that meets one or more of the following criteria: (1) associated with events that have made a significant contribution to the broad patterns or local or regional history of the cultural heritage of California or the United States; (2) associated with the lives of persons important to local, California, or national history; (3) embodies the distinctive characteristics of a type, period, region, or method of construction or represents the work of a master or possesses high artistic values; or (4) has yielded, or has the potential to yield, information important to the prehistory or history of the local area, California, or the nation.

As part of the environmental review process, and in satisfaction of MM CUL-1.1 and CUL-1.2, Brian F. Smith and Associates, Inc. (BFSA) prepared the Project’s Cultural Records Search Letter Report, dated February 7, 2022 (Appendix B). A records search was requested from the Southern San Joaquin Valley Information Center (SSJVIC) at California State University, Bakersfield and was completed on January 31, 2022. In addition, the records search encompassed an area of one mile surrounding the Project.

The records search concluded that no resources had been recorded within the Project site, however, the search did identify 33 recorded resources within one mile of the Project parcels.

All the previously recorded resources are historic and include 30 historic buildings (mostly single-family residences), one historic railroad alignment, the historic Central Canal, and the historic Bowles farming community district. The closest resources to the Project site consist of an ancillary barn building (P-10-004650), approximately 500 feet north at 2943 S. East Avenue, and an industrial repair yard (P-10-004652), approximately 350 feet east at 1038 E.

North Avenue. The BFSA study concluded no resources have ever been recorded within the Project site. In addition, the site is undeveloped. Therefore, development of the Project site would not result in a new impact related to an adverse change in the significance of a historic resource.
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact with mitigation incorporated (MM CUL-2) regarding this topic.

According to the Phase I Environmental Site Assessment (Appendix D), dated November 2021, performed by Atlas, review of historical records and aerial photographs, the Project site was used for agriculture and included a small cluster of rural residences in the northeast corner of the site through 1998. The cluster of residences were likely demolished in late 1998 or 1999, and sometime in 2000 the sites agriculture (rows of crops) was cleared. Since 2001, the Project site has been undeveloped. The Project site is within an irrigated row and field crops designation which includes sites in active agriculture as well as sites that are significantly disturbed. Based on the Project’s Cultural Records Search Letter Report, the 47 previously recorded resources in the Project vicinity are historic and include 30 historic buildings, one historic railroad alignment, the historic Central Canal, and the historic Bowles farming community district. Therefore, as the site has been heavily disturbed in its current state and repeatedly during its agriculture uses and there are no archeological resources recorded within a mile of the Project site, there is limited potential for the Project to impact archeological resources.

However, because the previous cluster of rural residences through 1998, there is potential for archaeological resources to be inadvertently uncovered during Project construction and grading. As a result, MM CUL-1.1 and CUL-2 apply to the Project and state that if buried historic or prehistoric archaeological resources encountered during construction, work shall stop in the vicinity and a qualified archaeologist or historical resources specialist shall be consulted to determine whether the resource requires further study and take further appropriate action. Similar to the GP PEIR, with implementation of MM CUL-1.1 and CUL-2 would reduce Project impacts to less than significant.

Therefore, the Project would result in no new impacts related to adverse change in the significance of an archaeological resource.
c) Disturb any human remains, including those interred outside of formal cemeteries? No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact with mitigation incorporated (MM CUL-3) regarding this topic.

The Project site does not contain a cemetery, and no known formal cemeteries are located within the immediate vicinity of the Project site. Nevertheless, should human remains be unearthed during grading and excavation activities associated with Project development, the construction contractor would be required by California law to comply with California Health and Safety Code Section 7050.5 and Public Resources Code Section 5097.98. According to Section 7050.5(b) and (c), if human remains are discovered, the County Coroner must be contacted to determine the proper course of disposition. If the Coroner recognizes the human remains to be those of a Native American or has reason to believe that they are those of a Native American, the Coroner is required to contact the NAHC by telephone within 24 hours.

Pursuant to California Public Resources Code Section 5097.98, whenever the NAHC receives notification of a discovery of Native American human remains from a county coroner, the NAHC is required to immediately notify those persons it believes to be most likely descended from the deceased Native American. The descendants may, with the permission of the owner of the land, or his or her authorized representative, inspect the site of discovery of the Native American human remains and may recommend to the owner or the person responsible for the excavation work means for treatment or disposition, with appropriate dignity, of the human remains and any associated grave goods. The descendants shall complete their inspection and make recommendations or preferences for treatment within 48 hours of being granted access to the site. According to Public Resources Code Section 5097.98(k), the NAHC is authorized to mediate disputes arising between landowners and known descendants relating to the treatment and disposition of Native American human burials, skeletal remains, and 48 items associated with Native American burials.

Through mandatory compliance with California Health and Safety Code Section 7050.5 and Public Resources Code Section 5097.98 and implementation of MM CUL-3 (if remains found), the Project would not result in significant impacts to human remains, and impacts would be less than significant. Therefore, the Project would result in no new impact related to disturbance of human remains.

CONCLUSION
With regards to the issue area of cultural resources, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. Feasible mitigation measures contained within the GP PEIR (CUL-1.1, -2, and -3) would be applied to the Project. These mitigation measures, detailed below, require monitoring for archaeological and paleontological resources.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
MM CUL‐1.1 If previously unknown resources are encountered before or during grading activities, construction shall stop in the immediate vicinity of the find and a qualified historical resources specialist shall be consulted to determine whether the resource requires further study. The qualified historical resources specialist shall make recommendations to the City on the measures that shall be implemented to protect the discovered resources, including but not limited to excavation of the finds and evaluation of the finds in accordance with Section 15064.5 of the CEQA Guidelines and the City’s Historic Preservation Ordinance.

If the resources are determined to be unique historical resources as defined under Section 15064.5 of the CEQA Guidelines, measures shall be identified by the monitor and recommended to the Lead Agency. Appropriate measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds.

No further grading shall occur in the area of the discovery until the Lead Agency approves the measures to protect these resources. Any historical artifacts recovered as a result of mitigation shall be provided to a City‐approved institution or person who is capable of providing long‐term preservation to allow future scientific study.
49 MM CUL‐1.2 Prior to approval of any discretionary project that could result in an adverse change to a potential historic and/or cultural resource, the City shall require a site‐specific evaluation of historic and/or cultural resources by a professional who meets the Secretary of Interior’s Qualifications. The evaluation shall provide recommendations to mitigate potential impacts to historic and/or cultural resources and shall be approved by the Directory of Planning and Development.

Status: CUL-1.2 is satisfied Cultural Records Search Letter Report, dated February 7, 2022 prepared by Brian F. Smith and Associates, Inc. and included as Appendix B.

MM CUL‐2 Subsequent to a preliminary City review of the Project grading plans, if there is evidence that a Project will include excavation or construction activities within previously undisturbed soils, a field survey and literature search for prehistoric archaeological resources shall be conducted. The following procedures shall be followed.

If prehistoric resources are not found during either the field survey or literature search, excavation and/or construction activities can commence. In the event that buried prehistoric archaeological resources are discovered during excavation and/or construction activities, construction shall stop in the immediate vicinity of the find and a qualified archaeologist shall be consulted to determine whether the resource requires further study. The qualified archaeologist shall make recommendations to the City on the measures that shall be implemented to protect the discovered resources, including but not limited to excavation of the finds and evaluation of the finds in accordance with Section 15064.5 of the CEQA Guidelines. If the resources are determined to be unique prehistoric archaeological resources as defined under Section 15064.5 of the CEQA Guidelines, mitigation measures shall be identified by the monitor and recommended to the Lead Agency. Appropriate measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds. No further grading shall occur in the area of the discovery until the Lead Agency approves the measures to protect these resources. Any prehistoric archaeological artifacts recovered as a result of mitigation shall be provided to a City‐approved institution or person who is capable of providing long‐term preservation to allow future scientific study.

If prehistoric resources are found during the field survey or literature review, the resources shall be inventoried using appropriate State record forms and submit the forms to the Southern San Joaquin Valley Information Center. The resources shall be evaluated for significance. If the resources are found to be significant, measures shall be identified by the qualified archaeologist. Similar to above, appropriate mitigation measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open 50 space, or data recovery excavations of the finds. In addition, appropriate mitigation for excavation and construction activities in the vicinity of the resources found during the field survey or literature review shall include an archaeological monitor. The monitoring period shall be determined by the qualified archaeologist. If additional prehistoric archaeological resources are found during excavation and/or construction activities, the procedure identified above for the discovery of unknown resources shall be followed.

MM CUL‐3 In the event that human remains are unearthed during excavation and grading activities of any future development project, all activity shall cease immediately.

Pursuant to Health and Safety Code (HSC) Section 7050.5, no further disturbance shall occur until the County Coroner has made the necessary findings as to origin and disposition pursuant to PRC Section 5097.98(a). If the remains are determined to be of Native American descent, the coroner shall within 24 hours notify the Native American Heritage Commission (NAHC). The NAHC shall then contact the most likely descendent of the deceased Native American, who shall then serve as the consultant on how to proceed with the remains. Pursuant to PRC Section 5097.98(b), upon the discovery of Native American remains, the landowner shall ensure that the immediate vicinity, according to generally accepted cultural or archaeological standards or practices, where the Native American human remains are located is not damaged or disturbed by further development activity until the landowner has discussed and conferred with the most likely descendants regarding their recommendations, if applicable, taking into account the possibility of multiple human remains. The landowner shall discuss and confer with the descendants all reasonable options regarding the descendants' preferences for treatment. 51 ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
VI. ENERGY – Would the project:
a) Result in potentially
significant environmental
impact due to wasteful,
inefficient, or unnecessary
consumption of energy
resources, during project
construction or operation?
b) Conflict with or obstruct a
state or local plan for
renewable energy or energy
efficiency?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
The GP PEIR specifically analyzed impacts related to wasteful, inefficient, or unnecessary consumption of energy resources according to the threshold in the State CEQA Guidelines Appendix G. It was concluded that implementation of the preceding GP objectives and policies within the Planning Area resulted in no impacts related to the inefficient, wasteful and unnecessary consumption of energy, and no mitigations were required.

GP GOALS AND POLICIES
The GP goals and policies that pertain to energy related impacts:

Policy LU‐6‐b: Commercial Development Guidelines. Adopt commercial development guidelines to assure high quality design and site planning for large commercial developments, consistent with the Urban Form policies of this Plan.

Policy RC‐2‐b: Provide Infrastructure for Mixed‐Use and Infill. Promote investment in the public infrastructure needed to allow mixed‐use and denser infill development to occur in targeted locations, such as expanded water and wastewater conveyance systems, complete streetscapes, parks and open space amenities, and trails. Discourage investment in infrastructure that would not meet these criteria.
52 Policy RC‐8‐a. Existing Standards and Programs. Continue existing beneficial energy conservation programs, including adhering to the California Energy Code in new construction and major renovations.

Policy RC‐8‐b. Energy Reduction Targets. Strive to reduce per capita residential electricity use to 1,800 kWh per year and non‐residential electricity use to 2,700 kWh per year per capita by developing and implementing incentives, design and operation standards, promoting alternative energy source, and cost‐effective savings.

GP PEIR MITIGATION MEASURES
None.

PROJECT-SPECIFIC IMPACTS
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
No New Impact.

The PEIR did not identify significant impacts related to the inefficient, wasteful and unnecessary consumption of energy.

Construction
As stated in the Project’s Air Quality, Health Risk, Greenhouse Gas, and Energy Impact Report (Appendix A), construction of the proposed Project is anticipated to begin in September 2022 and end in March 2024, and would require energy for activities such as the manufacture and transportation of building materials, grading activities, and building construction. Construction of the proposed Project would require electricity to power construction-related equipment, however would not involve the consumption of natural gas.

Furthermore, the construction-related equipment would not be powered by natural gas, and no natural gas demand is anticipated during construction. Table 7 lists the potential construction equipment to be used during Project construction under each phase of construction.

Table 7: Diesel Construction Equipment Utilized by Construction Phase Construction
Phase
Off-Road Equipment
Type
Off-Road
Equipment
Unit
Amount
Hours
Used per
Day
Horsepow
er
Load
Factor
Site Preparation Rubber Tired Dozers 3 8 247 0.40
53 Tractors/Loaders/Backho
es
4 8 97 0.37
Grading Excavators 2 8 158 0.38
Graders 1 8 187 0.41
Rubber Tired Dozers 1 8 247 0.40
Scrapers 2 8 367 0.48
Tractors/Loaders/Backho
es
2 8 97 0.37
Building
Construction
Cranes 1 8 231 0.29
Forklifts 3 8 89 0.20
Generator Sets 1 8 84 0.74
Tractors/Loaders/Backho
es
3 8 97 0.37
Welders 1 8 46 0.45
Paving Pavers 2 8 130 0.42
Paving Equipment 2 8 132 0.36
Rollers 2 8 80 0.38
Architectural
Coating
Air Compressors 1 8 78 0.48
Source: Compiled by LSA using CalEEMod defaults (April 2022).

CalEEMod = California Emissions Estimator Model
Transportation energy represents the largest energy use during construction and would occur from the transport and use of construction equipment, delivery vehicles and haul trucks, and construction worker vehicles that would use petroleum fuels (e.g., diesel fuel and/or gasoline).

Estimates of fuel consumption (diesel fuel and gasoline) from construction equipment, construction trucks, and construction worker vehicles were based on default construction equipment assumptions and trip estimates from CalEEMod and fuel efficiencies from Emission Factor 2021 (EMFAC2021). Fuel consumption estimates are presented in Table 8.

CalEEMod output sheets and detailed energy calculations are included in Appendix A.

Table 8: Proposed Project Energy Consumption Estimates during Construction Energy Type Total Energy
Consumption
Percentage Increase
Countywide
Diesel Fuel (total gallons) 291,240 0.19
Gasoline (total gallons) 74,964 0.02
Source: Compiled by LSA (April 2022).

As indicated in Table 8, the Project would consume approximately 291,240 gallons of diesel fuel and approximately 74,964 gallons of gasoline during construction. Based on fuel consumption obtained from EMFAC2021, approximately 376.0 million gallons of gasoline and approximately 157.0 million gallons of diesel will be consumed from vehicle trips in Fresno County in 2022. Therefore, construction of the proposed Project would increase the annual 54 construction generated fuel use in Fresno County by approximately 0.19 percent for diesel fuel usage and 0.02 percent for gasoline fuel usage. As such, Project construction would have a negligible effect on local and regional energy supplies. Impacts related to energy use during construction would be temporary and relatively small in comparison to Fresno County’s overall use of the State’s available energy resources. No unusual Project characteristics would necessitate the use of construction equipment that would be less energy efficient than at comparable construction sites in the region or the State. In addition, construction activities are not anticipated to result in an inefficient use of energy as gasoline and diesel fuel would be supplied by construction contractors who would conserve the use of their supplies to minimize their costs on the Project. The Project would not cause or result in the need for additional energy facilities or an additional or expanded delivery system. For these reasons, fuel consumption during construction would not be inefficient, wasteful, or unnecessary, therefore impacts are less than significant requiring no mitigation, and no new impact would occur.

Operation
As stated in the Project’s Air Quality, Health Risk, Greenhouse Gas, and Energy Impact Report (Appendix A), operational energy use is typically associated with natural gas use, electricity consumption, and fuel used for vehicle trips associated with a project. Energy consumption was estimated for the proposed Project using default energy intensities by land use type in CalEEMod. The proposed Project would also result in energy usage associated with gasoline and diesel fuel consumed by Project-related vehicle and truck trips. Fuel use associated with vehicle and truck trips generated by the proposed Project was calculated based on the Project’s Trip Generation and Traffic Impact Study Screening Analysis (Appendix H) and VMT Screening Analysis (Appendix I) which identifies that the proposed Project would generate approximately 481 average daily trips, including 321 vehicle trips and 160 truck trips. The amount of operational fuel use was estimated using CARB’s EMFAC2021 model, which provided projections for typical daily fuel usage in Fresno County. Electricity, natural gas, and fuel usage estimates associated with the proposed Project are shown in Table 9.

Table 9: Proposed Project Energy Consumption Estimates during Operation Energy Type Annual Energy
Consumption
Percentage Increase
Countywide
Electricity Consumption
(kWh/year)
2,492,730 0.03
Natural Gas Consumption
(therms/year)
43,991 0.01
Automotive Fuel Consumption
Gasoline (gallons/year) 134,448 0.04
Diesel Fuel (gallons/year) 545,668 0.35
Source: Compiled by LSA (April 2022).
kWh = kilowatt-hours
55 As shown in Table 9, the estimated potential increase in electricity demand associated with the operation of the proposed Project is 2,492,730 kilowatt-hours (kWh) per year. Total electricity demand in Fresno County in 2020 was approximately 8,018 GWh (8,017,830,742 kWh). Therefore, operation of the proposed Project would increase the annual electricity consumption in Fresno County by approximately 0.03 percent.

As shown in Table 9, the estimated potential increase in natural gas demand associated with the proposed Project is 43,991 therms per year. Total natural gas consumption in Fresno County in 2020 was approximately 326 million therms (325,915,257 therms). Therefore, operation of the proposed Project would negligibly increase the annual natural gas consumption in Fresno County by approximately 0.01 percent. Electrical and natural gas demand associated with Project operations would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region. Furthermore, the proposed Project would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency. The Project would be required to adhere to all federal, State, and local requirements for energy efficiency, including the Title 24 standards. Title 24 building energy efficiency standards establish minimum efficiency standards related to various building features, including appliances, water and space heating and cooling equipment, building insulation and roofing, and lighting, which would reduce energy usage.

As shown in Table 9, fuel use associated with the vehicle trips generated by the proposed Project is estimated at 134,448 gallons of gasoline and 545,668 gallons of diesel fuel per year.

This analysis conservatively assumes that all vehicle trips generated as a result of Project operation would be new to Fresno County. Based on fuel consumption obtained from EMFAC2021, approximately 376.0 million gallons of gasoline and approximately 157.0 million gallons of diesel will be consumed from vehicle trips in Fresno County in 2022. Therefore, vehicle and truck trips associated with the proposed Project would increase the annual fuel use in Fresno County by approximately 0.04 percent for gasoline fuel usage and approximately 0.35 for diesel fuel usage. Fuel consumption associated with vehicle trips generated by Project operations would not be considered inefficient, wasteful, or unnecessary in comparison to other similar developments in the region, therefore impacts are less than significant, requiring no mitigation, and no new impacts would occur. b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
No New Impact. The GP PEIR concluded implementation of the GP would be consistent with applicable State and local plans related to renewable energy and energy efficiency, and no mitigation would be required. As previously described, the proposed Project would be required to meet the CCR Title 24 energy efficiency standards in effect during permitting of the Project.

Additionally, the City has developed a Green Plan to reduce energy demand within the City.

The GP also included policies targeted at increasing energy efficiency and encouraging use of renewable energies. As further discussed under Section 4.11, Land Use Planning, the Project was found to be consistent with all GP policies. 56 As stated in the Project’s Air Quality, Health Risk, Greenhouse Gas, and Energy Impact Report (Appendix A), SB 1389 was passed in 2002, which required the CEC to develop an integrated energy plan every two years for electricity, natural gas, and transportation fuels for the Integrated Energy Policy Report. The plan calls for the State to assist in the transformation of the transportation system to improve air quality, reduce congestion, and increase the efficient use of fuel supplies with the least environmental and energy costs. To further this policy, the plan identifies a number of strategies, including assistance to public agencies and fleet operators in implementing incentive programs for zero emission vehicles (ZEVs) and their infrastructure needs, and encouragement of urban designs that reduce VMT and accommodate pedestrian and bicycle access. The California Energy Commission (CEC) recently adopted the 2021 Integrated Energy Policy Report. The Integrated Energy Policy Report provides the results of the CEC’s assessments of a variety of energy issues facing California.. Fresno Green—The City of Fresno’s Strategy for Achieving Sustainability— was adopted in 2007 (Fresno Green). A project proposed as a Fresno Green project must have a minimum of 20 points spread over at least 5 of the major categories in either the Residential or Non-residential program. The proposed Project would is not seeking to become a certified Fresno Green project, but would include measures from the Fresno Green Non-Residential Checklist such as erosion controls during construction per SWPPP and installation of drought resistance/water efficient landscaping. Furthermore, the Project would install a minimum of 450kW of rooftop solar and would be consistent with CalRecycle Waste Diversion and Recycling Mandate for the diversion and reduction in accordance with the CAP.

As indicated above, energy usage on the Project site during construction would be temporary in nature and would be relatively small in comparison to the overall use in the County. In addition, energy usage associated with operation of the proposed Project would be relatively small in comparison to the overall use in Fresno County, and the State’s available energy resources. Therefore, energy impacts at the regional level would be negligible. Due to California’s energy conservation planning actions are conducted at a regional level, and because the proposed Project’s total impact on regional energy supplies would be minor, the proposed Project would not conflict with or obstruct California’s energy conservation plans as described in the CEC’s Integrated Energy Policy Report. Additionally, as demonstrated above, the proposed Project would not result in the inefficient, wasteful, and unnecessary consumption of energy. Potential impacts related to conflict with or obstruction of a State or local plan for renewable energy or energy efficiency would be less than significant, requiring no mitigation is required, and no new impacts would occur.

CONCLUSION
With regards to the issue area of Energy, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.
57 4. No mitigation measures contained within the GP PEIR would be required because Project specific impacts would be less than significant.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
None.
58 ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
VII. GEOLOGY AND SOILS – Would the project:
a) Directly or Indirectly cause
potential substantial adverse
effects, including the risk of
loss, injury, or death
involving:
i) Rupture of a known
earthquake fault, as
delineated on the most recent
Alquist-Priolo Earthquake
Fault Zoning Map issued by
the State Geologist for the
area or based on other
substantial evidence of a
known fault? Refer to Division
of Mines and Geology Special
Publication 42.
ii) Strong seismic ground
shaking?
iii) Seismic-related ground
failure, including liquefaction?
iv) Landslides?
b) Result in substantial soil
erosion or the loss of topsoil?
c) Be located on a geologic
unit or soil that is unstable, or
that would become unstable
as a result of the project, and
potentially result in on- or offsite landslide, lateral spreading, subsidence,
liquefaction or collapse?
59 ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
d) Be located on expansive
soil, as defined in Table 18-1-
B of the Uniform Building
Code (1994), creating
substantial risks to life or
property?
e) Have soils incapable of
adequately supporting the
use of septic tanks or
alternative waste water
disposal systems where
sewers are not available for
the disposal of waste water?
f) Directly or indirectly destroy
a unique paleontological
resource or site or unique
geologic feature?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
The GP PEIR discussed impacts related to Geology and Soils in Section 4.7. The basic geologic setting of the GP Planning Area has not changed since certification of the GP PEIR.

The GP PEIR found that all impacts related to geology, seismicity, and soils would be less than significant with required implementation of existing regulations, policies, and standard practices. Current California Building Code (CBC), Uniform Building Code (UBC), and the City’s GP Development Code requirements and guidelines for buildings constructed in areas of high seismic risk. According to the GP PEIR, no mitigation measures were necessary, as the objectives and policies included in the proposed GP fully mitigate potential impacts associated with implementation of the GP, and any future infill development and urban expansion projects as a result.

The GP PEIR analyzed impacts related to paleontological resources in significance criteria GEO-6 (Section 4.7.6.1). The GP PEIR discussed that ground-disturbing activities in fossilbearing soils and rock formations have the potential to damage or destroy paleontological resources that may be present below the ground surface. However, it concluded that with implementation of GP policies, impacts to paleontological resources would be less than significant with mitigation incorporated.
60 GP GOALS AND POLICIES
The GP goals and policies that pertain to the Project’s impacts related to geology and soils:

Objective NS‐2. Minimize risks of property damage and personal injury posed by geologic and seismic risks.

Policy NS‐2‐a. Seismic Protection. Ensure seismic protection is incorporated into new and existing construction, consistent with the Fresno Municipal Code.

Policy NS‐2‐b. Soil Analysis Requirement. Identify areas with potential geologic and/or soils hazards, and require development in these areas to conduct a soil analysis and mitigation plan by a registered civil engineer (or engineering geologist specializing in soil geology) prior to allowing on‐ site drainage or disposal for wastewater, stormwater runoff, or swimming pool/spa water.

Policy HS‐D.2. The County shall ensure that the General Plan and/or County Ordinance Code is revised, as necessary, to incorporate geologic hazard areas formally designated by the State Geologist (e.g., Earthquake Fault Zones and Seismic Hazard Zones). Development in such areas, including public infrastructure projects, shall not be allowed until compliance with the investigation and mitigation requirements established by the State Geologist can be demonstrated.

Policy HS‐D.3. The County shall require that a soils engineering and geologic‐seismic analysis be prepared by a California‐registered engineer or engineering geologist prior to permitting development, including public infrastructure projects, in areas prone to geologic or seismic hazards (i.e., fault rupture, groundshaking, lateral spreading, lurchcracking, fault creep, liquefaction, subsidence, settlement, landslides, mudslides, unstable slopes, or avalanche).

Policy HS‐D.4. The County shall require all proposed structures, additions to structures, utilities, or public facilities situated within areas subject to geologic‐seismic hazards as identified in the soils engineering and geologic‐seismic analysis to be sited, designed, and constructed in accordance with applicable provisions of the Uniform Building Code (Title 24 of the California Code of Regulations) and other relevant professional standards to minimize or prevent damage or loss and to minimize the risk to public safety.

Policy HS‐D.8. The County shall require a soils report by a California‐registered engineer or engineering geologist for any proposed development, including public infrastructure projects, that requires a County permit and is located in an area containing soils with high “expansive” or “shrinkswell” properties. Development in such areas shall be prohibited unless suitable design and construction measures are incorporated to reduce the potential risks associated with these conditions.
61 Policy HS‐D.9. The County shall seek to minimize soil erosion by maintaining compatible land uses, suitable building designs, and appropriate construction techniques. Contour grading, where feasible, and revegetation shall be required to mitigate the appearance of engineered slopes and to control erosion.

Policy HS‐D.11. The County shall not approve a County permit for new development, including public infrastructure projects where slopes are over thirty (30) percent unless it can be demonstrated by a California‐registered civil engineer or engineering geologist that hazards to public safety will be reduced to acceptable levels.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
MM GEO‐6.1Subsequent to a preliminary City review of the Project grading plans, if there is evidence that a Project will include excavation or construction activities within previously undisturbed soils, a field survey and literature search for unique paleontological/geological resources shall be conducted. The following procedures shall be followed:

If unique paleontological/geological resources are not found during either the field survey or literature search, excavation and/or construction activities can commence. In the event that unique paleontological/geological resources are discovered during excavation and/or construction activities, construction shall stop in the immediate vicinity of the find and a qualified paleontologist shall be consulted to determine whether the resource requires further study. The qualified paleontologist shall make recommendations to the City on the measures that shall be implemented to protect the discovered resources, including but not limited to, excavation of the finds and evaluation of the finds. If the resources are determined to be significant, mitigation measures shall be identified by the monitor and recommended to the Lead Agency. Appropriate mitigation measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds. No further grading shall occur in the area of the discovery until the Lead Agency approves the measures to protect these resources. Any paleontological/geological resources recovered as a result of mitigation shall be provided to a City‐approved institution or person who is capable of providing long‐ term preservation to allow future scientific study.

If unique paleontological/geological resources are found during the field survey or literature review, the resources shall be inventoried and evaluated for significance. If the resources are found to be significant, mitigation measures shall be identified by the qualified paleontologist. Similar to above, appropriate mitigation measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data 62 recovery excavations of the finds. In addition, appropriate mitigation for excavation and construction activities in the vicinity of the resources found during the field survey or literature review shall include a paleontological monitor. The monitoring period shall be determined by the qualified paleontologist. If additional paleontological/geological resources are found during excavation and/or construction activities, the procedure identified above for the discovery of unknown resources shall be followed.

PROJECT-SPECIFIC IMPACTS
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i. Rupture of a known earthquake fault, as delineated on the most recent AlquistPriolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.

No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. As stated in the GP PEIR, there are a number of potentially active and active fault systems located around the GP Planning Area, however the Nunez Fault is the nearest approximately 48 miles southwest. In addition, the City is not in an Alquist Priolo fault zone and is not in an area where structures are at significant risk from fault rupture.

According to the Project’s Geotechnical Engineering Investigation (Appendix E), the closest fault to the Project site is the Great Valley 13 (Coalinga) fault approximately 40 miles southwest of the Project site. Therefore, the Project would result in no new impacts on people or structures due to rupture of an earthquake fault in the Alquist Priolo fault zone. ii. Strong seismic ground shaking?
No New Impact. The GP PEIR determined the GP Update would result in less than significant impact with implementation of Objective NS-2 and Policies NS-2-a through -d regarding this topic. As discussed previously, there are no potentially active and active fault systems located within and near the City, nor the Project site. The site is not within a currently established State of California Earthquake Fault Zone for surface fault rupture hazards. Therefore, the potential for surface rupture due to faulting occurring beneath the site during the design life of the proposed development is considered low. According to the Geotechnical Engineering Report, a site Class D was selected for the Project site based on soil conditions with standard, and Project foundation design are to be based on the 2019 CBC. However, similar to the GP PEIR, the Project will incorporate Objective NS-2 and Policies NS-2-a and -b. Therefore, the Project would result in no new impacts on people or structures due to strong seismic ground shaking.
63 iii. Seismic-related ground failure, including liquefaction? No New Impact. This topic was evaluated in the GP PEIR. The PEIR determined impacts associated with this topic would be less than significant. The PEIR noted Fresno is located in an area that has varying potential for liquefaction near water-filled features such as canals, ditches, ponds, and lakes. As concluded in the PEIR, the potential for soil liquefaction within the Planning Area ranges from very low to moderate due to the variable density of the subsurface soils and the presence of shallow groundwater. Implementation of the GP objective and policies and the FMC standards reduce potential liquefaction impacts to less than significant. These objective and policies include Objective NS‐2 and Policies NS‐2‐a through NS‐2‐d.

The Geotechnical Engineering Investigation conducted for the Project determined the potential for liquefaction/seismic settlement impacts on the site would be low. This conclusion was based on the lack of groundwater within the upper 50 feet and relative density of soils, and the relatively low peak ground acceleration. Therefore, the Project would result in no new impacts to people or structures due to ground failure or liquefaction. iv. Landslides?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. The Project site is relatively flat, there are no known landslides at the site, nor is the site in the path of any known or potential landslides. Therefore, the Project would result in no new impacts to people or structures due to landslides. b) Result in substantial soil erosion or the loss of topsoil? No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. As stated in the PEIR, the local topography of the City is generally flat with gentle slopes. Similar to the Planning Area, the Project site is flat and does not contain sloped conditions that would result in conditions outside of those evaluated under the GP PEIR. Although impacts are less than significant pre and post construction, activities during construction would expose soil and there would be an increase in potential for soil erosion. As such, development greater than one acre in size is required to comply with the provisions of the Construction General Permit (CGP) adopted by the State Water Resources Control Board (SWRCB), which includes implementation of standard erosion control practices as required by a Stormwater Pollution Prevention Plan (SWPPP). Therefore, the Project would result in no new impacts from 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?
64 No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. As discussed above, the Project site is in an area that does not require further investigation due to risk of liquefaction. In addition, due to the relatively flat site topography and lack of groundwater near the surface, the potential of lateral spreading is considered low. The Geotechnical Engineering Investigation conducted for the Project determined structural design measures would effectively avoid impacts due to ground failure. According to Figure Levels of Earthquake Hazards in California, in Appendix E of the GP PEIR, the Project site was not identified as susceptible to such geological hazards.

Additionally, Chapter 18 of the CBC requires that a California Certified Engineering Geologist or California-licensed civil engineer provide site-specific engineering data for proposed structures, which are reviewed by the City for appropriate inclusion as part of the building plan check and development review process. Compliance with the requirements of the CBC for structural safety would reduce potential impacts to a less than significant level. Therefore, the Project would result in no new impacts from on- or offsite landslides, 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, as updated), creating substantial direct or indirect risks to life or property?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. As discussed in the Project’s Geotechnical Engineering Investigation, the Project surface soils (upper 5 to 10 feet) predominantly consist of sandy silt.

These soils are considered to have low to moderate compressibility characteristics, slight collapse potential, and a very low expansion potential. Furthermore, the surface soils are underlain by interbedded layers of sandy silt and silty sand, poorly-graded sand, and poorly graded sand with silt to the maximum depth of approximately 41.5 feet below site grade.

Therefore, the site is suitable for the proposed development to be supported using conventional shallow foundations. All soils imported as part of Project construction would consist of very low expansiveness. Therefore, the Project site does not contain expansive soils and no new impacts would occur related to expansive soil hazards. e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
No New Impact. The GP PEIR determined the GP Update would result in no impact regarding this topic. The Project would be connected to the City sewer and would not require the use of septic tanks or alternative wastewater disposal systems. Therefore, the Project would result in no new impact from soils incapable of adequately supporting the use of septic tanks. f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
65 No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact with mitigation incorporated (MM GEO-6.1) regarding this topic. According to the GP PEIR, there is potential within the city for paleontological resources to be present in fossil-bearing soils and rock formations below the ground surface.

As previously discussed in Cultural Resources, the site has previously been disturbed during prior agriculture use and when cleared for vacancy (existing condition). According to the Project’s Geotechnical Engineering Investigation (Appendix E), sediments currently at or near the surface are believed to be of Pleistocene non-marine Age (2 million years old or younger).

Based on review of the Geologic Map of California: Fresno Sheet1, the area of the subject site is in an area mapped as Great Valley Fan deposits (Qf). The GP PEIR states Pleistocene non-marine sediments are considered to have a high potential for paleontological sensitivity.

Therefore, excavation and/or construction activities on the Project site have the potential to impact paleontological/geological resources during excavation and construction activities within previously undisturbed soils.

The Project will be conditioned to ensure consistency with GP policies and objectives to reduce impacts to unknown geological or paleontological resources. In addition, in the event that unique paleontological/geological resources are discovered during excavation and/or construction activities, implementation of MM GEO-6.1 requires that all construction shall stop in the immediate vicinity of the find and a qualified paleontologist shall be consulted to determine whether the resource requires further study, MM GEO-6.1 would reduce potential impacts to less than significant, similar to the conclusion contained in the PEIR. Construction shall stop in the immediate vicinity of the find and a qualified paleontologist shall be consulted to determine whether the resource requires further study and take further appropriate action.

With implementation of the City GP policies and mitigation incorporated, no new impacts would occur related to paleontological resources.

CONCLUSION
With regards to the issue area of Geology and Soils, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No mitigation measures contained within the GP PEIR would be required because Project specific impacts would be less than significant by adhering to the Project conditions of approval, which are consistent with the GP PEIR.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
66 MM GEO‐6.1Subsequent to a preliminary City review of the Project grading plans, if there is evidence that a Project will include excavation or construction activities within previously undisturbed soils, a field survey and literature search for unique paleontological/geological resources shall be conducted. The following procedures shall be followed:

If unique paleontological/geological resources are not found during either the field survey or literature search, excavation and/or construction activities can commence. In the event that unique paleontological/geological resources are discovered during excavation and/or construction activities, construction shall stop in the immediate vicinity of the find and a qualified paleontologist shall be consulted to determine whether the resource requires further study. The qualified paleontologist shall make recommendations to the City on the measures that shall be implemented to protect the discovered resources, including but not limited to, excavation of the finds and evaluation of the finds. If the resources are determined to be significant, mitigation measures shall be identified by the monitor and recommended to the Lead Agency. Appropriate mitigation measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds. No further grading shall occur in the area of the discovery until the Lead Agency approves the measures to protect these resources. Any paleontological/geological resources recovered as a result of mitigation shall be provided to a City‐approved institution or person who is capable of providing long‐ term preservation to allow future scientific study.

If unique paleontological/geological resources are found during the field survey or literature review, the resources shall be inventoried and evaluated for significance. If the resources are found to be significant, mitigation measures shall be identified by the qualified paleontologist. Similar to above, appropriate mitigation measures for significant resources could include avoidance or capping, incorporation of the site in green space, parks, or open space, or data recovery excavations of the finds. In addition, appropriate mitigation for excavation and construction activities in the vicinity of the resources found during the field survey or literature review shall include a paleontological monitor. The monitoring period shall be determined by the qualified paleontologist. If additional paleontological/geological resources are found during excavation and/or construction activities, the procedure identified above for the discovery of unknown resources shall be followed. 67 ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
VII. Greenhouse Gases – Would the project:
a) Generate greenhouse gas
emissions, either directly or
indirectly, that may have a
significant impact on the
environment?
b) Conflict with an applicable
plan, policy or regulation
adopted for the purpose of
reducing the emissions of
greenhouse gases?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
The PEIR stated that implementation of the GP would generate new greenhouse gas emissions, directly and indirectly. However, GP policies were included to help the City achieve the goals of SCAG’s 2012‐2035 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), which would contribute to the achievement of SCAG’s goal for per capita GHG emissions reductions required by California State Senate Bill (SB) 375. In addition, the updated Greenhouse Gas (GHG) Reduction Plan is included as an Appendix to the PEIR to take into account the requirements of SB 32. The GHG Reduction Plan Update was prepared to re-evaluate the City’s existing GHG reduction targets and strategies. In addition, the GHG Reduction Plan Update provided new goals and measures to reflect and ensure compliance with changes in the local and State policies to achieve GHG reductions and maintain the “CEQA Qualified Plan” status. As required in Mitigation Measure GHG-1.1, development projects shall demonstrate they are consistent with the Recirculated GHG Reduction Plan Update and shall implement all measures deemed applicable to the project through the GHG Reduction Plan Update-Project Consistency Checklist (Appendix B to the GHG Reduction Plan Update). The Consistency Checklist is designed to help the City provide a streamlined review process for new development projects that are subject to discretionary review pursuant to CEQA. The GP PEIR concluded implementation of the GP decreases greenhouse gas emissions through buildout and serves to reduce the significant greenhouse gas impacts with implementation of migration measure GHG-1.1. Therefore, the PEIR concluded the GP would have a less than significant impact on greenhouse gases.

GP GOALS AND POLICIES
68 The GP goals and policies that pertain to the Project’s impacts related to greenhouse gases:

Policy LU‐2‐a. Infill Development and Redevelopment. Promote development of vacant, underdeveloped, and redevelopable land within the City Limits where urban services are available by considering the establishment and implementation of supportive regulations and programs.

Policy MT‐2‐c. Reduce VMT through Infill Development. Provide incentives for infill development that would provide jobs and services closer to housing and multi‐modal transportation corridors, and vice versa, in order to reduce citywide vehicle miles travelled.

Policy MT‐2‐b. Reduce Vehicle Miles Traveled and Trips. Partner with major employers and other responsible agencies, such the San Joaquin Valley Air Pollution Control District and the Fresno Council of Governments, to implement trip reduction strategies, such as eTRIP, to reduce total vehicle miles traveled and the total number of daily and peak hour vehicle trips, thereby making better use of the existing transportation system.

Policy MT‐1‐k. Multi‐Modal Level of Service Standards. Develop and use a tiered system of flexible, multi‐modal Level of Service standards for streets designated by the Circulation Diagram (Figure MT‐ 1). Strive to accommodate a peak hour vehicle LOS of D or better on street segments and at intersections, except where Policies MT‐1‐m through MT‐1‐p provide greater specificity. Establish minimum acceptable service levels for other modes and use them in the development and environmental review process.

Policy MT‐2‐n. Peak Hour Vehicle LOS. Maintain a peak‐hour vehicle LOS standard of D or better for all roadway areas outside of identified Activity Center and Bus Rapid Transit Corridor districts, unless the City Traffic Engineer determines that mitigation to maintain this LOS would be infeasible and/or conflict with the achievement of other General Plan policies.

Policy PU‐7‐d. Pursue the development of a recycled water system and the expansion of beneficial wastewater recycling opportunities, including a timely technical, practicable, and institutional evaluation of treatment, facility siting and water exchange elements.

Policy PU‐8‐g. Review Project Impact on Supply. Mitigate the effects of development and capital improvement projects on the long‐range water budget to ensure an adequate water supply for current and future uses
Policy RC‐4‐f. Continue to control and reduce air pollution emissions from vehicles owned by the City and municipal operations and facilities by undertaking the following:
• Expand the use of alternative fueled and electric vehicles in City fleets. • Create preventive maintenance schedules that will ensure efficient engine operation. • Include air conditioning recycling and charging stations in the City vehicle maintenance facilities, to reduce freon gases being released into the atmosphere and electrostatic 69 filtering systems in City maintenance shops, when feasible or when required by health regulations.
• Use satellite corporation yards for decentralized storage and vehicle maintenance. • Convert City‐owned emergency backup generators to natural gas fuels whenever possible, and create an advanced energy storage system.

Policy RC‐5‐b. Greenhouse Gas Reduction Plan. As is consistent with State law, prepare and adopt a Greenhouse Gas Reduction Plan as part of the Master Environmental Impact Report to be concurrently approved with the Fresno General Plan in order to achieve compliance with State mandates, assist development by streamlining the approval process, and focus on feasible actions the City can take to minimize the adverse impacts of growth and development on global climate change. The Greenhouse Gas Reduction Plan shall include, but not be limited to:
• A baseline inventory of all known or reasonably discoverable sources of GHGs that currently exist in the city and sources that existed in 1990. • A projected inventory of the GHGs that can reasonably be expected to be emitted from those sources in the year 2035 with the implementation of this General Plan and foreseeable communitywide and municipal operations.
• A target for the reduction of emissions from those identified sources. • A list of feasible GHG reduction measures to meet the education target, including energy conservation and “green building” requirements in municipal buildings and private development.
• Periodically update municipal and community‐wide GHG emissions inventories to determine the efficacy of adopted measures and to guide future policy formulation needed to achieve and maintain GHG emissions reduction targets.

Policy RC‐5‐d. SCS and CAP Conformity Analysis. Ensure that the City includes analysis of a project’s conformity to an adopted regional Sustainable Community Strategy or Alternative Planning Strategy (APS), an adopted Climate Action Plan (CAP), and any other applicable City and regional greenhouse gas reduction strategies in affect at the time of project review.

Policy RC‐5‐e. Ensure Compliance. Ensure ongoing compliance with GHG emissions reduction plans and programs by requiring that air quality measures are incorporated into projects’ design, conditions of approval, and mitigation measures.

Policy RC‐6‐b. Water Plans. Adopt and implement ordinances, standards, and policies to achieve the intent of the City of Fresno Urban Water Management Plan, Fresno‐Area Regional Groundwater Management Plan, and City of Fresno Metropolitan Water Resources Management Plan to ensure a sustainable supply of water.

Policy RC‐6‐h. Conditions of Approval. Include in the Development Code standards for imposing conditions of approval for development projects to ensure long‐term maintenance of adequate clean water resources. Require findings that adequate water supply must exist 70 prior to any discretionary project approval for residential and commercial development requiring annexation (excluding County Islands), as required by law.

Objective RC‐7. Promote water conservation through standards, incentives and capital investments.

Policy RC‐7‐a. Water Conservation Program Target. Maintain a comprehensive conservation program to help reduce per capita water usage in the city’s water service area to 243 gallons per capita per day (gpcd) by 2020 and 190 gpcd by 2035, by adopting conservation standards and implementing a program of incentives, design and operation standards, and user fees:
• Support programs that result in decreased water demand, such as landscaping standards that require drought‐tolerant plants, rebates for water conserving devices and systems, turf replacement, xeriscape landscape for new homes, irrigation controllers, commercial/industrial/institutional water conserving programs, prioritized leak detection program, complete water system audit, landscape water audit and budget program, and retrofit upon resale ordinance.
• Implement the U.S. Bureau of Reclamation Best Management Practices for water conservation as necessary to maintain the City’s surface water entitlements. • Adopt and implement policies in the event that an artificial lake is proposed for development.
• Work cooperatively toward effective uniform water conservation measures that would apply throughout the Planning Area.
• Expand efforts to educate the public about water supply issues and water conservation techniques.

Policy RC‐7‐h. Landscape Water Conservation Standards. Refine landscape water conservation standards that will apply to new development installed landscapes, building on the State Model Water Efficient Landscape Ordinance and other state regulations.

Policy RC‐8‐b. Energy Reduction Targets. Strive to reduce per capita residential electricity use to 1,800 kWh per year and non‐residential electricity use to 2,700 kWh per year per capita by developing and implementing incentives, design and operation standards, promoting alternative energy sources, and cost‐effective savings.

GP PEIR MITIGATION MEASURES
MM GHG‐1.1Development projects that require discretionary approval shall be consistent with the GHG Reduction Plan Update (2020) and shall implement all measures deemed applicable to the project through the GHG Reduction Plan Update‐ Project Consistency Checklist (Appendix B to the GHG Reduction Plan Update).

PROJECT-SPECIFIC IMPACTS
71 a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact with implementation of the GP regarding this topic.

The GP PEIR evaluated whether implementation of the GP would increase per capita GHG emissions. A GHG analysis was completed for the Project, as seen in the Air Quality, Health Risk, Greenhouse Gas, and Energy Impact Report (Appendix A), which assessed whether the Project would directly or indirectly generate GHG emissions beyond existing conditions, which could have a significant impact on the environment (LSA Associates, 2022).

Short-Term GHG Emissions
As stated in the GHG Analysis, construction activities associated with the proposed Project would produce combustion emissions through the operation of construction equipment and from worker and builder supply vendor vehicles, each of which typically use fossil-based fuels to operate. The City of Fresno does not have an adopted threshold of significance for construction related GHG emissions. However, emissions that would occur during construction were quantified and are disclosed for informational purposes. Construction of the proposed Project would generate approximately 1,148.7 metric tons of CO2e. Table 10 lists the annual GHG emissions (details are provided in the CalEEMod output in Appendix A) and such emissions would be temporary in nature and would only occur for the duration construction.

Table 10: Construction Greenhouse Gas Emissions (Mitigated) Construction
Year
Emissions (metric tons per year)
CO2 CH4 N2O Total CO2e
2022 220.8 <0.1 <0.1 224.6
2023 846.3 0.1 <0.1 863.2
2024 30.1 <0.1 <0.1 60.9
Total Construction Emissions 1,148.7
Source: Compiled by LSA (April 2022).

CH4 = methane
CO2 = carbon dioxide
CO2e = carbon dioxide equivalent
N2O = nitrous oxide
Long-Term GHG Emissions
Long-term GHG emissions are typically generated from mobile sources (e.g., vehicle trips), area sources (e.g., maintenance activities and landscaping), indirect emissions from sources associated with energy consumption, waste sources (land filling and waste disposal), and water sources (water supply and conveyance, treatment, and distribution). Operation of the proposed Project would generate approximately 5,717.4 metric tons of CO2e per year. 72 As previously stated, the GHG Reduction Plan Update includes a Consistency Checklist to help the City provide a streamlined review process for new development projects that are subject to discretionary review pursuant to CEQA. The Project’s Consistency Checklist is included as Table 11 below, and in Appendix D of the GHG analysis (provided as Appendix A herein). As shown in the Consistency Checklist, the proposed Project would be consistent with the applicable strategies from the GHG Reduction Plan Update.

Therefore, the proposed Project would not generate GHG emissions, either directly or indirectly, that may have a significant effect on the environment as identified in Appendix D in the GHG analysis (Appendix A). Therefore, the Project would result in no new impacts related to greenhouse gas emissions.
73 Table 11. Project Consistency Checklist
74 b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
No New Impact. This topic was evaluated in the GP PEIR and was determined to have a less than significant impact.

The proposed Project was analyzed for consistency with the goals of AB 32 and the AB 32 Scoping Plan. The following discussion evaluates the proposed Project according to the goals of AB 32, the AB 32 Scoping Plan, EO B-30-15, SB 32, and AB 197.

AB 32 is aimed at reducing GHG emissions to 1990 levels by 2020. AB 32 requires the CARB to prepare a Scoping Plan that outlines the main State strategies for meeting the 2020 deadline and to reduce GHGs that contribute to global climate change. The AB 32 Scoping Plan has a range of GHG reduction actions, which includes direct regulations, alternative compliance mechanisms, monetary and non-monetary incentives, voluntary actions, marketbased mechanisms such as a cap-and-trade system, and an AB 32 implementation fee to fund the program.

EO B-30-15 added the immediate target of reducing GHG emissions to 40 percent below 1990 levels by 2030. CARB released a second update to the Scoping Plan, the 2017 Scoping Plan, to reflect the 2030 target set by EO B-30-15 and codified by SB 32. SB 32 affirms the importance of addressing climate change by codifying into statute the GHG emissions reductions target of at least 40 percent below 1990 levels by 2030 contained in EO B-30-15.

SB 32 builds on AB 32 and keeps the State on the path toward achieving the 2050 objective of reducing emissions to 80 percent below 1990 levels. The companion bill to SB 32, AB 197, provides additional direction to the CARB related to the adoption of strategies to reduce GHG emissions. Additional direction in AB 197 intended to provide easier public access to air emissions data that are collected by CARB was posted in December 2016.

As identified above, the AB 32 Scoping Plan contains GHG reduction measures that work towards reducing GHG emissions, consistent with the targets set by AB 32 and EO B-30-15 and codified by SB 32 and AB 197. The measures applicable to the proposed Project include energy efficiency measures, water conservation and efficiency measures, and transportation and motor vehicle measures, as discussed below.

Energy efficient measures are intended to maximize energy efficiency building and appliance standards, pursue additional efficiency efforts including new technologies and new policy and implementation mechanisms, and pursue comparable investment in energy efficiency from all retail providers of electricity in California. In addition, these measures are designed to expand the use of green building practices to reduce the carbon footprint of California’s new and existing inventory of buildings. The proposed Project would be required to comply with the latest Title 24 standards of the CCR, established by the CEC, regarding energy conservation 75 and green building standards. Therefore, the proposed Project would comply with applicable energy measures.

Water conservation and efficiency measures are intended to continue efficiency programs and use cleaner energy sources to move and treat water. Increasing the efficiency of water transport and reducing water use would reduce GHG emissions. As noted above, the proposed Project would be required to comply with the latest Title 24 standards of the CCR, which includes a variety of different measures, including reduction of wastewater and water use. Therefore, the proposed Project would not conflict with any of the water conservation and efficiency measures.

The goal of transportation and motor vehicle measures is to develop regional GHG emissions reduction targets for passenger vehicles. The second phase of Pavley standards will reduce GHG emissions from new cars by 34 percent from 2016 levels by 2025, resulting in a 3 percent decrease in average vehicle emissions for all vehicles by 2020. Vehicles traveling to the Project site would comply with the Pavley II (LEV III) Advanced Clean Cars Program.

Therefore, the proposed Project would not conflict with the identified transportation and motor vehicle measures.

As such, the proposed Project would comply with existing State regulations adopted to achieve the overall GHG emissions reduction goals identified in AB 32 and would be consistent with applicable plans and programs designed to reduce GHG emissions.

Therefore, the proposed Project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. As a result, the Project would result in no new impact related to conflicts with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

CONCLUSION
With regards to the issue area of Greenhouse Gas Emissions, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No mitigation measures contained within the GP PEIR would be required because Project specific impacts would be less than significant.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
76 MM GHG‐1.1Development projects that require discretionary approval shall be consistent with the GHG Reduction Plan Update (2020) and shall implement all measures deemed applicable to the project through the GHG Reduction Plan Update‐ Project Consistency Checklist (Appendix B to the GHG Reduction Plan Update).

Status: MM GHG-1.1 satisfied by Air Quality, Health Risk, Greenhouse Gas, and Energy Impact Report, dated 2022 prepared by LSA Associates, Inc. and included in its entirety as Appendix A.
77 ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
IX. HAZARDS AND HAZARDOUS MATERIAL – Would the project:
a) Create a significant hazard
to the public or the
environment through the
routine transport, use, or
disposal of hazardous
materials?
b) Create a significant hazard
to the public or the
environment through
reasonably foreseeable upset
and accident conditions
involving the release of
hazardous materials into the
environment?
c) Emit hazardous emissions
or handle hazardous or
acutely hazardous materials,
substances, or waste within
one-quarter mile of an
existing or proposed school?
d) Be located on a site which
is included on a list of
hazardous materials sites
compiled pursuant to
Government Code Section
65962.5 and, as a result,
would it create a significant
hazard to the public or the
environment?
78 ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
e) For a project located within
an airport land use plan or,
where such a plan has not
been adopted, within two
miles of a public airport or
public use airport, would the
project result in a safety
hazard for people residing or
working in the project area?
f) Impair implementation of or
physically interfere with an
adopted emergency response
plan or emergency
evacuation plan?
g) Expose people or
structures, either directly or
indirectly, to a significant risk
of loss, injury or death
involving wildland fires?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
The PEIR discussed hazards and hazardous materials impacts in Section 4.9. The PEIR addressed potential hazardous materials, urban and wildland fire hazards, and emergency response and evacuation.

Potential Hazardous Materials
The PEIR determined that construction materials and materials used for periodic cleaning, repair, and maintenance or for landscape maintenance/pest control are potential sources of exposure to hazardous materials. The PEIR concluded that although the overall quantity of hazardous materials and waste generated in the City could increase as result of implementation of the GP, future projects that handle or use hazardous materials would be required to comply with regulations, standards, and guidelines established by the US EPA, state, Fresno County, and the City of Fresno. According to the PEIR, there are sites in the City either containing or potentially containing hazardous materials contamination and that any development on these sites would require remediation of the site contamination; impacts 79 associated with development on these sites would be considered less than significant after remediation and adherence to the GP Objectives and Policies.

GP GOALS AND POLICIES
GP Objectives and Policies applicable to the proposed Project include:

Policy NS‐4‐a: Processing and Storage. Require safe processing and storage of hazardous materials, consistent with the California Building Code and the Uniform Fire Code, as adopted by the City.

Policy NS‐4‐c. Soil and Groundwater Contamination Reports. Require an investigation of potential soil or groundwater contamination whenever justified by past site uses. Require appropriate mitigation as a condition of project approval in the event soil or groundwater contamination is identified or could be encountered during site development.

Policy NS‐4‐e. Compliance with County Program. Require that the production, use, storage, disposal, and transport of hazardous materials conform to the standards and procedures established by the County Division of Environmental Health. Require compliance with the County’s Hazardous Waste Generator Program, including the submittal and implementation of a Hazardous Materials Business Plan, when applicable.

Policy NS‐4‐f. Hazardous Materials Facilities. Require facilities that handle hazardous materials or hazardous wastes be designed, constructed, and operated in accordance with applicable hazardous materials and waste management laws and regulations.

Policy NS‐4‐g. Hazmat Response. Include policies and procedures appropriate to hazardous materials in the City’s disaster and emergency response preparedness and planning, coordinating with implementation of Fresno County’s Hazardous Materials Incident Response Plan.

The PEIR also concludes that, although there are schools in the GP area that could be within

0.25 mile of facilities with the potential to release hazardous materials, compliance with existing regulations and standard safety procedures related to the handling of hazardous materials at these facilities would be expected to reduce potential impacts to a less than significant level.

GP PEIR MITIGATION MEASURES
None.

Emergency Response and Evacuation
80 As discussed in the PEIR, the City's Police and Fire Departments are the lead agencies for all local emergency response efforts and the City's full‐time Emergency Preparedness Officer (EPO) is responsible for ensuring emergency response plans are up‐to‐date and implemented properly. The EPO also facilitates cooperation between City departments and other local, state and federal agencies that would be involved in emergency response operations (City of Fresno Emergency Response Plan Overview. 2012). The City’s Emergency Operations Center (EOC) serves as the coordination and communication between the City and Fresno County Operational Area EOC. The PEIR concluded that with implementation of GP objectives and policies, potential interference with an adopted emergency response plan or emergency evacuation plan would be reduced, however impacts could remain significant.

GP GOALS AND POLICIES
GP Objectives and Policies applicable to the proposed Project include:

Objective NS‐6. Foster an efficient and coordinated response to emergencies and natural disasters.

Policy NS‐6‐b. Disaster Response Coordination. Maintain coordination with other local, State, and Federal agencies to provide coordinated disaster response.

Policy NS‐6‐c. Emergency Operations Plan. Update the City’s Emergency Operations Plan periodically, using a whole community approach, which integrates considerations for People with access and functional needs in all aspects of planning.

Policy NS‐6‐d. Evacuation Planning. Maintain an emergency evacuation plan in consultation with the Police and Fire Departments and other emergency service providers, which shows potential evacuation routes and a list of emergency shelters to be used in case of catastrophic emergencies.

Policy NS‐6‐f. Emergency Vehicle Access. Require adequate access for emergency vehicles in all new development, including adequate widths, turning radii, hard standing areas, and vertical clearance.

GP PEIR MITIGATION MEASURES
MM HAZ‐6.1 The City shall establish an alternative Emergency Operations Center in the event the current Emergency Operations Center is under redevelopment or inaccessible
Airport Hazards
The PEIR concluded that impacts associated with hazards and hazardous materials, including compatibility and operation of applicable Airport Land Use Compatibility Plans, would be less 81 than significant following implementation of GP objective and policies, and no mitigation measures were required.

Wildland Fire Hazards
As described in the PEIR, the City is predominately designated as an area with little or no threat or moderate fire hazard, which is largely attributed to the City’s paved urban development similar to the Project’s surroundings. Although there are small areas along the San Joaquin River Bluff area in northern Fresno classified as high fire hazard areas, these area would not directly or indirectly affect the Project.

GP GOALS AND POLICIES
Policy PU-2-b: Maintain Ability. Strive to continually maintain the Fire Department’s ability to provide staffing and equipment resources to effectively prevent and mitigate emergencies in existing and new high-rise buildings and in other high-density residential and commercial development throughout the city.

Policy PU‐2‐e. Service Standards. Strive to achieve a community wide risk management plan that include the following service level objectives 90 percent of the time:
• First Unit on Scene – First fire unit arriving with minimum of three fire fighters and ability to apply suppressing agent within 6 minutes and 20 seconds from emergency call (7 minutes and 30 seconds with 9‐11 processing time). • Effective Response Force – Provide sufficient number of fire fighters on scene of an emergency (17 for low risk, 23 for high risk) within nine minutes and 20 seconds from time of alert to arrival.

Policy PU‐3‐a. Fire Prevention Inspections. Develop strategies to enable the performance of annual fire and life safety inspection of all industrial, commercial, institutional, and multi‐family residential buildings, in accordance with nationally recognized standards for the level of service necessary for a large Metropolitan Area, including self‐certification program.

Policy PU‐3‐d. Review All Development Applications. Continue Fire Department review of all development applications, provide comments and recommend conditions of approval that will ensure adequate on‐site and off‐site fire protection systems and features are provided.

Policy PU‐3‐e. Building Codes. Adopt and enforce amendments to construction and fire codes, as determined appropriate, to systematically reduce the level of risk to life and property from fire, commensurate with the City’s fire suppression capabilities. 82 Policy PU‐3‐f. Adequate Infrastructure. Continue to pursue the provision of adequate water supplies, hydrants, and appropriate property access to allow for adequate fire suppression throughout the City.

Policy PU‐3‐g. Cost Recovery. Continue to evaluate appropriate codes, policies, and methods to generate fees or other sources of revenue to offset the ongoing personnel and maintenance costs of providing fire prevention and response services.

GP PEIR MITIGATION MEASURES
None.

PROJECT-SPECIFIC IMPACTS
a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
No New Impact. A Phase I Environmental Site Assessment (Phase I ESA) was conducted for the Project to assess potential hazardous impacts (Atlas Technical, 2021) (Appendix D).

The Phase I ESA determined the Project site had been utilized for agriculture prior to 1940 to 2000, later cleared in 2001 and has remained vacant to present. However, the Phase I ESA revealed no evidence of recognized environmental conditions (RECs) or other notable findings in connection with the Subject Property, therefore the site is not considered a significant hazard to the public or the environment.

Construction
This topic was evaluated in the PEIR (Impact HAZ-1) and was determined to have a less than significant impact with implementation of the GP objectives and policies provided above.

Project construction would require clearing and grubbing of vacant site and construction of a new industrial building, which would require grading and soil export. Soil conditions on the site were identified as not having elevated levels of PCE, TCE, and TCA in soil. Furthermore, as stated in the Project’s Geotechnical Engineering Investigation, groundwater was not encountered at depths of 50 feet. Therefore, the routine transport, use, or disposal of soils during Project construction would not be considered to be a significant hazard to the public or the environment.

California Division of Occupational Safety and Health (Cal/OSHA) has regulations concerning the use of hazardous materials, including requirements for safety training, availability of safety equipment, hazardous materials exposure warnings, and emergency action and fire prevention plan preparation. Cal/OSHA enforces the hazard communication program regulations, which include provisions for identifying and labeling hazardous materials, describing the hazards of chemicals, and documenting employee-training programs. 83 Proposed construction activities would involve the routine transport, use, and disposal of other hazardous materials such as paints, solvents, oils, grease, and other construction-related materials. In addition, hazardous materials would routinely be needed for fueling and servicing construction equipment on the site. These types of materials are not acutely hazardous, and all storage, handling, use, and disposal of these materials are regulated by federal and state regulations that are implemented by the City of Fresno during building permitting for construction activities. As a result, hazardous material impacts during construction would be less than significant and consistent with the PEIR, and no new impact would occur.

Operation
Operation of the proposed Project includes food and beverage industrial storage. Although the Project would likely utilize common types of hazardous materials, normal routine use of these products pursuant to existing regulations would not result in a significant hazard to the environment or workers within or in the vicinity of the Project. Per the PEIR, both the federal and state governments require all businesses that handle more than a specified amount of hazardous materials to submit a business plan to a regulating agency. Specifically, any new business that meets the specified criteria must submit a full hazardous materials disclosure report that includes an inventory of the hazardous materials generated, used, stored, handled, or emitted; and emergency response plans and procedures to be used in the event of a significant or threatened significant release of a hazardous material.

Station No. 3 of the City of Fresno Fire Department (FFD) will conduct yearly inspections of the proposed Project, to confirm that the business plan is in order and up to date. Additionally, GP policies (Policy NS-4-h) include measures for handling hazardous materials within the City. Therefore, operational impacts related to routine transport, use, and disposal of hazardous materials during operation of the Project would be less than significant, and no new impact would occur.
b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
No New Impact. This topic was evaluated in the PEIR (Impact HAZ-2), where it was determined the GP would have a less than significant impact with implementation of the objective and policies provided above.

Construction
As discussed above, Project construction would require clearing of the vacant site and construction of a new industrial building. Through standard hazardous materials handling practices, the Project would not pose a significant hazard, and as concluded in the Phase I Assessment, the Project site is not considered hazardous to the public or environment. 84 To further avoid an impact related to an accidental release of hazardous materials from stormwater into the environment, the use of best management practices (BMPs) during construction would be implemented as part of a Stormwater Pollution Prevention Plan (SWPPP) as required by the National Pollution Discharge Elimination System General Construction Permit. Implementation of an SWPPP would minimize potential adverse effects to workers, the public, and the environment. Construction contract specifications would include strict on-site handling rules and BMPs that include, but are not limited to:
• Establishing a dedicated area for fuel storage and refueling and construction dewatering activities that includes secondary containment protection measures and spill control supplies;
• Following manufacturers’ recommendations on the use, storage, and disposal of chemical products used in construction;
• Avoiding overtopping construction equipment fuel tanks; • Properly containing and removing grease and oils during routine maintenance of equipment; and
• Properly disposing of discarded containers of fuels and other chemicals.

Operation
The Project would include operation of an industrial building. As discussed above, operational use of hazardous materials on the Project site would be subject to federal, state, and local requirements that aim to avoid and minimize the potential release of hazardous substances.

The FFD would inspect the facility to ensure compliance with proper handling measures identified in the hazardous materials disclosure report and emergency response plan.

Therefore, the Project would result in no impacts related to the accidental upset or release of hazardous materials.
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? No New Impact. This topic was evaluated in the PEIR where it was determined the GPE would have a less than significant impact. The nearest school is the Orange Center Elementary located at 3530 S Cherry Avenue, which is 0.7 mile to the southwest of the Project site. As described in the previous responses, Project construction and operation would involve the use and disposal of various hazardous materials, however all storage, handling, use, and disposal of these materials are regulated by federal state regulations that are implemented by the City. While the Project would involve the use and disposal of various hazardous materials, compliance with federal and state regulations would reduce impacts to a less than significant level and impacts would be consistent with the PEIR. Therefore, the Project would result in no new impacts related to hazardous emissions within on-quarter mile of a school. d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
85 No New Impact. This topic was evaluated in the PEIR where it was determined the GP would have a less than significant impact. As discussed in the PEIR, development within the City could be located on a site which are included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. Prior to issuance of development permit for a project, the site would be required to be remediated and mitigated for on‐site hazardous materials. In addition, the PEIR included GP objectives and policies within the Noise and Safety Element; Objective NS‐4 and Policies NS‐4‐a through NS‐4‐g and NS‐4‐I to reduce such impacts. As concluded in the PEIR, impacts would be anticipated to be less than significant.

According to the PEIR, contaminated sites are mainly associated with leaking underground storage tanks and are predominately clustered south of downtown, Fresno Yosemite International Airport, Palm Bluffs Corporate Center (northwest Fresno) and along the Union Pacific Railroad Tracks. According to the Project’s Phase I ESA, the closest hazardous waste or contaminated site is located 0.18 south of the Project, which was determined to have no impact on the Project site. In addition, the Project site is not located on a federal Superfund site, State response site, voluntary cleanup site, school cleanup site, corrective action site, or tiered permit site (Department of Toxic Substances Control 2021). Therefore, the Project would result in no new impact related to hazardous materials sites compiled pursuant to Government Code Section 65962.5.
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? No New Impact. This topic was evaluated in the GP PEIR where it was determined the GP would result in a less than significant without mitigation incorporated. The Project would not expose people working in the Project site to excessive noise levels from aircraft. The nearest airport is Fresno Chandler Executive Airport that is located approximately 3.6 miles northwest of the Project site, therefore the Project site is located outside of the safety zones according to the Fresno-Chandler Downtown Airport Zones, Exhibit 5.8-2, in Section 5.8 of the PEIR. As a result, implementation of the Project would not result in construction of residential, commercial, and industrial uses within the Fresno‐Chandler Downtown Airport Land Use Policy Plan. Mitigation measures from the PEIR would not be applicable to the Project as there are no impacts. Therefore, no new impacts related to airport safety hazards would occur. f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
No New Impact. This topic was evaluated in the PEIR where it was determined the GP would result in a less than significant with mitigation incorporated (MM HAZ-6.1). The Project would include the construction of a new industrial building on a vacant site within a developed area of the GP Planning Area. The Project would not result in roadway closure, or other activities that could impact emergency response or evacuation. During short-term construction activities, the proposed Project is not anticipated to result in any substantial traffic queuing on 86 nearby streets, and all construction equipment would be staged within the Project site. During the operational phase of the proposed Project, onsite access would be required to comply with standards established by the City. The proposed Project would provide adequate emergency access to the site via E. North Avenue and S. East Avenue. Therefore, the Project would result in no new impacts related to impairment of an adopted emergency response plan or emergency evacuation plan.
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
No New Impact. This topic was evaluated in the PEIR where it was determined the GP would result in a less than significant impact. According to the California Department of Forestry and Fire Protection's Fire and Resource Assessment Program (FRAP) Fire Hazard Severity Zones map, the Project is not within an area identified as a fire hazard safety zone (FHSZ).

Therefore, the Project would result in no impacts related to exposure of people or structures to significant risk involving wildland fires. No new impacts involving wildland fires would occur.

CONCLUSION
With regards to the issue area of Hazards and Hazardous Materials, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No mitigation measures contained within the GP PEIR would be required because Project specific impacts would be less than significant by adhering to the project conditions of approval, which are consistent with the GP PEIR as described above.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
None.
87 ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
X. HYDROLOGY AND WATER QUALITY – Would the project:
a) Violate any water quality
standards or waste discharge
requirements or otherwise
substantially degrade surface
or ground water quality?
b) Substantially decrease
groundwater supplies or
interfere substantially with
groundwater recharge such
that the project may impede
sustainable groundwater
management of the basin?
c) Substantially alter the
existing drainage pattern of
the site or area, including
through the alteration of the
course of a stream or river, or
through the addition of
impervious surfaces, in a
manner which would:
i) Result in a substantial
erosion or siltation on- or offsite;
ii) Substantially increase the
rate or amount of surface
runoff in a manner which
would result in flooding on- or
off-site:
iii) create or contribute runoff
water which would exceed the
capacity of existing or
planned stormwater drainage
systems or provide
substantial additional sources
of polluted runoff; or
88 ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
iv) impede or redirect flood
flows?
d) In flood hazard, tsunami, or
seiche zones, risk release of
pollutants due to project
inundation?
e) Conflict with or obstruct
implementation of a water
quality control plan or
sustainable groundwater
management plan?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
The GP PEIR discussed hydrology and water quality impacts and addressed the following potential impacts: water quality standards; groundwater; alteration of existing drainage patterns resulting in erosion or flooding; urban runoff in relation to storm drainage system capacity and increased pollutants; flood hazards; and inundation by seiche, tsunami, or mudflow.

Water Quality Standards
According to development under the GP PEIR, development under the GP would result in demolition and/or construction activity that could generate pollutants that have the potential to adversely affect urban runoff. Although development under the GP could result in an increase in pollutants in stormwater and wastewater, new development would be required to comply with all City requirements in the Storm Drainage Master Plan (SDMP) under the Fresno Metropolitan Flood Control District (FMFCD) and applicable National Pollutant Discharge Elimination System (NPDES) permit.

Preparation of a Stormwater Pollution Prevention Plan (SWPPP) is required for construction activities to achieve compliance with the NPDES General Construction Stormwater Activity Permit. New development projects within the GP Planning Area are required to obtain a Construction General Permit and thereby implement Best Management Practices (BMPs), such as regular watering of exposed soils to control dust during construction and vegetation of proposed landscaped/grassed swale areas as soon as feasible following grading activities. 89 Furthermore, the GP PEIR stated that policies within the GP would minimize stormwater and erosion impacts during construction.

The GP PEIR states that although the increase in volumes or rates of discharge and associated pollutants in runoff would be minimal, the operation of future development envisioned in the GP could potentially result in the addition of contaminants into both the stormwater runoff entering the City’s drainage system and the wastewater stream entering the local wastewater collection and treatment system. However, all development in the City would be subject to the provisions of the City’s NPDES Municipal Separate Storm Sewer Systems (MS4) Permit (Order No. R5‐2022‐0006).

Municipal Code Chapter 6 establishes provisions to ensure the health, safety, and general welfare of residents, and to protect the water quality of surface water and groundwater resources by reducing pollutants in urban stormwater. All discharges of material other than stormwater must comply with an NPDES permit issued for the discharge with appropriate structural BMPs, such as hydrodynamic devices, swales/biofilters, and basins, and nonstructural BMPs, such as activity restrictions and drought‐tolerant landscaping.

Groundwater
The GP PEIR discussed that future development occurring from implementation of the proposed GP would increase the demand for water, some of which would derive from groundwater sources. This increase in demand was determined to be beyond adequate supply of water needed, however only if demand is met through increase in ground pumping.

A number of objectives and policies proposed in the GP would serve provide an adequate water supply due to the increase in water conservation, supply of recycled water, and treatment of surface water supply. Additionally, the GP would serve to balance the amount of groundwater pumped to provide an adequate water supply. Therefore, the GP PEIR concluded that development would not substantially interfere with groundwater recharge, and this impact would be less than significant.

Alteration of Existing Drainage Patterns Resulting in Erosion or Flooding According to the GP PEIR, development under the GP would result in alterations to drainage, such as impervious surface additions from development of underdeveloped sites. The PEIR requires development that increases runoff to incorporate Low Impact Development (LID) stormwater management practices to specifically reduce the potential for development to alter existing drainage patterns as described in item 3 of mitigation measures MM HYD-3.2 through -3.3. Integration of LID stormwater management practices combined with GP policies, the City’s Municipal Code, and NPDES regulations were determined to reduce erosion risks from drainage alterations to less than significant.

Urban Runoff in Relation to Storm Drainage System Capacity and Increased Pollutants 90 The GP PEIR discussed that the majority of development under the GP would increase in stormwater runoff that would likely exceed existing drainage capacity or increase pollutants in stormwater runoff. In order to accommodate the capacity needs from the GP development, upgrades, expansion, and construction of necessary utilities are required per mitigation measures MM HYD-3.4 through -3.5. Therefore, the impact was determined to be less than significant.

Flood Hazards
The GP PEIR states that the City is within a 100‐year floodplain, as delineated by the Federal Emergency Management Agency (FEMA). The City participates in FEMA’s Flood Insurance Program (FIP) which requires a community adopt the Flood Insurance Rate Maps (FIRMs), appoint Floodplain Administrator, adopt a floodplain ordinance, and enforce the ordinance and the requirements that all new construction and substantial reconstruction of buildings located within an adopted floodplain be flood proofed and approve by the administrator.

The potential for flood events in the GP Planning Area are due to the development of housing in floodplains places near water sources. The sources as identified in the PEIR of flooding within the GP Planning Area include the San Joaquin River, Big Dry Creek and its associated Dry Creek Canal, Redbank Creek, and Fancher Creek. In addition, tributaries that flow into such creeks include the Pup Creek, Alluvial Drain, and Dog Creek. The GP PEIR stated the FIRMS the areas below the bluff line (Redbank Creek and Detention Basin) of the San Joaquin River are within the Special Flood Hazard Area (SFHA) Zone A which are areas within the floodplain of the base flood or 1 percent exceedance probability flood event (100‐year recurrence interval).

Although designed to reduce flood damage, dams and basins have the potential for floods event. Dams and basins within the Planning Area include; Big Dry Creek Dam, Redbank Creek Dam and Detention Basin, and the Fancher Creek Dam. These provide the community with a 0.5 percent exceedance probability level of protection (200-year recurrence interval).

As concluded in the GP PEIR, requirements set forth in the Floodplain Ordinance flood proofing development in floodplain and with implementation of the GP policies would reduce GP impacts associated with housing located in a 100‐year flood hazard area to less than significant. Therefore, the GP PEIR determined impacts to flood hazards would be less than significant.

Inundation by Seiche, Tsunami, or Mudflow
The GP PEIR discussed that the GP Planning Area is located outside a tsunami hazard zone according to the Statewide Tsunami Inundation Maps by California Emergency Management Agency. In addition, the nearest body of water that could produce a seiche is the Big Creek Dry Dam and Reservoir. However, development of the GP would not be introduced in or near the area, and due to its size would not create inundation. 91 The PEIR also concluded that the although the San Joaquin Bluffs are susceptible to soil erosion, the GP would not result in significant development near the Bluffs. To further minimize the potential impact, the GP included the objective NS-2 to implement policies to minimize potential hazardous geological and soil conditions. As a result, the PEIR concluded there would be no risk of inundation by seiche, tsunami or mudflow in the City, and would not be increased as a result of development under the GP. Therefore, no impact would occur.

GP GOALS AND POLICIES
Policy POSS-6-b: Effects of Stormwater Discharge. Support efforts to identify and mitigate cumulative adverse effects on aquatic life from stormwater discharge to the San Joaquin River.
• Avoid discharge of runoff from urban uses to the San Joaquin River or other riparian corridors.
• Approve development on sites having drainage (directly or indirectly) to the San Joaquin
• River or other riparian areas only upon a finding that adequate measures for preventing pollution of natural bodies of water from their runoff will be implemented.

Periodically monitor water quality and sediments near drainage outfalls to riparian areas. Institute remedial measures promptly if unacceptable levels of contaminant(s) occur.

Policy NS‐1‐a: Seismic Protection. Ensure seismic protection is incorporated into new and existing construction, consistent with the Fresno Municipal Code.

Objective NS‐2: Minimize risks of property damage and personal injury posed by geologic and seismic risks.

Policy NS‐2‐b: Soil Analysis Requirement. Identify areas with potential geologic and/or soils hazards, and require development in these areas to conduct a soil analysis and mitigation plan by a registered civil engineer (or engineering geologist specializing in soil geology) prior to allowing on‐site drainage or disposal for wastewater, stormwater runoff, or swimming pool/spa water.

Policy NS‐3‐e: Pollutants. Work with FMFCD to prevent and reduce the existence of urban stormwater pollutants pursuant to the requirements of the National Pollution Discharge Elimination Systems Act.

Policy PU-8-c: Conditions of Approval. Set appropriate conditions of approval for each new development proposal to ensure that the necessary potable water production and supply facilities and water resources are in place prior to occupancy.

Policy PU-8-g: Review Project Impact on Supply. Mitigate the effects of development and capital improvement projects on the long‐range water budget to ensure an adequate water supply for current and future uses.
92 Objective RC-6. Ensure that Fresno has a reliable, long‐range source of drinkable water.

Policy RC-6-a: Regional Efforts. Support cooperative, multi‐agency regional water resource planning efforts and activities on developing and implementing the Upper Kings Basin Integrated Regional Water Management Plan.

Policy RC-6-b: Water Plans. Adopt and implement ordinances, standards, and policies to achieve the intent of the City of Fresno Urban Water Management Plan, Fresno‐Area Regional Groundwater Management Plan, and City of Fresno Metropolitan Water Resources Management Plan to ensure a dependable supply of water.

Policy RC-6-c: Land Use and Development Compliance. Ensure that land use and development projects adhere to the objective of the Fresno Metropolitan Water Resources Management Plan to provide sustainable and reliable water supplies to meet the demand of existing and future customers through 2025.

GP PEIR MITIGATION MEASURES
MM HYD‐2.1 The City shall continue to be an active participant in the North Kings Groundwater Sustainability Agency and the implementation of the North Kings Groundwater Sustainability Plan in order to ensure that the Kings Subbasin has balanced levels of pumping and recharge.

MM HYD‐3.1 The City shall implement the following measures to reduce the impacts on the capacity of existing or planned SDFCMP collection systems:
• Coordinate with FMFCD to implement the existing Storm Drainage and Flood Control Master Plan (SDFCMP) for collection systems in drainage areas where the amount of imperviousness is unaffected by the change in land uses.
• Coordinate with FMFCD to update the SDFCMP in those drainage areas where the amount of imperviousness increased due to the change in land uses to determine the changes in the collection systems that would need to occur to provide adequate capacity for the stormwater runoff from the increased imperviousness.
• As development is proposed, implement current SDFCMP to provide stormwater collection systems that have sufficient capacity to convey the peak runoff rates from the areas of increased imperviousness. • Require developments that increase site imperviousness to install, operate, and maintain FMFCD approved on-site detention systems to reduce the peak runoff rates resulting from the increased imperviousness to the peak runoff rates that will not exceed the capacity of the existing stormwater collection systems
93 MM HYD‐3.2 The City shall implement the following measures to reduce the impacts on the capacity of existing or planned SDFCMP retention basins: Prior to approval of development projects, coordinate with FCMFCD to analyze the impacts to existing and planned retention basins to determine remedial measures required to reduce the impact on retention basin capacity to less than significant.

Remedial measures would include: 1. Increase the size of the retention basin through the purchase of more land or deepening the basin or a combination for planned retention basins. 2. Increase the size of the emergency relief pump capacity required to pump excess runoff volume out of the basin and into adjacent canal that convey the stormwater to a disposal facility for existing retention basins. 3. Require developments that increase runoff volume to install, operate, and maintain, Low Impact Development (LID) measures to reduce runoff volume to the runoff volume that will not exceed the capacity of the existing retention basins.

MM HYD‐3.3 The City shall implement the following measures to reduce the impacts on the capacity of existing or planned SDFCMP urban detention (stormwater quality) basins: Prior to approval of development projects, coordinate with FCMFCD to determine the impacts to the urban detention basin weir overflow rates and determine remedial measures required to reduce the impact on the detention basin capacity to less than significant. Remedial measures would include: 1.

Modify overflow weir to maintain the suspended solids removal rates adopted by the FMFCD Board of Directors. 2. Increase the size of the urban detention basin to increase residence time by purchasing more land. The existing detention basins are already at the adopted design depth. 3. Require developments that increase runoff volume to install, operate, and maintain, Low Impact Development (LID) measures to reduce peak runoff rates and runoff volume to the runoff rates and volumes that will not exceed the weir overflow rates of the existing urban detention basins
MM HYD‐3.4 The City shall implement the following measures to reduce the impacts on the capacity of existing or planned SDFCMP pump disposal systems: 1. Prior to approval of development projects, coordinate with FCMFCD to determine the extent and degree to which the capacity of the existing pump system will be exceeded. 2. Require new developments to install, operate, and maintain onsite detention facilities, consistent with FMFCD design standards, to reduce peak stormwater runoff rates to existing planned peak runoff rates. 3. Provide additional pump system capacity to maximum allowed by existing permitting to increase the capacity to match or exceed the peak runoff rates determined by the SDFCMP.

MM HYD‐3.5 The City shall coordinate with FCMFCD to develop and adopt a storm drainage update to the SDFCMP for the Southeast Development Area that is designed to 94 collect, convey and dispose of runoff rates and volumes based on the planned land uses of the approved General Plan

PROJECT-SPECIFIC IMPACTS
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic.

The Project is within the jurisdiction of the State Water Resources Control Board and the Central Valley Regional Water Quality Control Board (CVRWQCB).

Construction
The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. Implementation of the proposed Project includes the site preparation of the vacant site, and the development involving the construction of a new concrete tilt-up industrial building, ancillary structures, landscaping, and pavement. Site preparation includes the clearing and grubbing of the site which include activities to remove unwanted material such as; weeds, grass, trash, stumps, roots, and/or other material. These activities would expose and loosen sediment and building materials, which have the potential to mix with stormwater and urban runoff and degrade surface and receiving water quality.

Pollutants of concern during construction activity generally include sediment, trash, petroleum products, concrete water (dry and wet), sanitary waste, and chemicals. Each of these pollutants on its own or in combination with other pollutants can have a detrimental effect on water quality. In addition, chemicals, liquid products, petroleum products (such as paints, solvents, and fuels), and concrete-related waste may be spilled or leaded during construction, which would have the potential to be transported via stormwater runoff into nearby receiving waters and eventually may affect surface or groundwater quality. During construction activities, excavated soil would be exposed, thereby increasing the potential for soil erosion and sedimentation to occur compared to existing conditions. In addition, during construction, vehicles and equipment are prone to tracking soil from work areas to paved roadways, which could exacerbate sedimentation of receiving waters.

The Project would be required to comply with CVRWQCB regulations construction activities covered under NPDES would require development of a SWPPP. The Project would implement the use of BMPs during construction to ensure that Project impacts related to construction activities resulting in a degradation of water quality would be less than significant. As part of the SWPPP, erosion and sediment control measures would be included to minimize potential pollutants from entering stormwater during Project construction, and no new impact would occur.
95 Operation
The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. The proposed Project would operate an industrial warehouse for food and beverage distribution, which would introduce the potential for pollutants such as, chemicals from cleaners, pesticides and sediment from landscaping, trash and debris, and oil and grease from vehicles and trucks. These pollutants could potentially discharge into surface waters and result in degradation of water quality. However, the on-site runoff will be collected into catch basins, drain into the underground storm drain system, and then discharged into existing 60-inch storm drain in E. North Avenue near the northern and northeastern portion of the Project site.; The two discharge locations into the existing 60-inch storm drain include one at the northern portion of the site via an 18-inch storm drain, and one at the northeastern portion of the site via upgraded 18-inch to 30-inch storm drain. The proposed Project development would therefore be compliant with the requirements set by the FMFCD, SDMP, and the City’s hydrology and LID standards to minimize impervious surfaces and provide acceptable reduction in peak runoff and volume rates. Therefore, the Project would result in a less than significant impact on water quality standards or waste discharge requirements, and no new impacts would occur requiring no mitigation. b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
No New Impact The GP PEIR determined the GP Update would result in a less than significant impact with implementation of mitigation (MM HYD-2.1), regarding this topic.

Groundwater recharge is facilitated by percolation of stormwater through pervious surface areas to groundwater resources. Increasing the imperviousness of an area could interfere with groundwater recharge capabilities of a given landscape. The Project site is currently vacant and almost entirely pervious surface area. The Project proposes the construction of a new concrete tilt-up industrial building (approximate building footprint of 205,000 sf), ancillary structures, landscaping, and pavement. Although this increase in impervious surface area decreases infiltration, this site is not located in a groundwater recharge area. Therefore, the project would not impede the CVRWQCB ability to manage groundwater, thereby would not substantially deplete groundwater supplies or interfere substantially with groundwater.

Additionally, the City receives its water supply from groundwater and surface water. As detailed in the Urban Water Management Plan (UWMP), strategies are outlined to balance the City’s groundwater operations. As stated in Section XIX, water to the Project site would be adequately provided by the City’s Public Works Department. Furthermore, The Project would be required to comply with FMFCD’s MS4 permit by employing BMPs for on-site detention/retention of stormwater runoff. Therefore, the Project would not substantially interfere with groundwater recharge. No new impacts would occur and no mitigation is required.
96 c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or through the addition of impervious surfaces, in a manner which would:
i. Result in substantial erosion or siltation on- or off-site? No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. As discussed above, construction related to implementation of the proposed Project would expose and loosen building materials and sediment which has the potential to mix with stormwater runoff and result in erosion or siltation offsite. The Construction General Permit requires preparation of a SWPPP, as previously stated, to identify construction BMPs to be implemented as part of the Project to reduce construction related impacts to water quality including impacts associated with soil erosion and siltation. With compliance with the requirements in the Construction General Permit and implementation of the construction BMPs, and with compliance with the City’s Municipal Code, construction impacts related to on- or off-site erosion or siltation would be less than significant.

Additionally, the Project site would be developed with an industrial warehouse building, parking, and landscaping and post construction conditions would not include exposed soils.

Therefore, the Project would not be susceptible to substantial erosion or siltation on- or offsite. No new impacts would occur, and no mitigation is required. ii. Substantially increase the rate or amount of surface runoff in a manner, which would result in flooding on- or off-site?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. Implementation of the proposed Project would include construction activities that could temporarily alter the existing drainage pattern of the site and could result in flooding on- or off-site if drainage is not properly controlled. However, as described previously, the Construction General Permit requires the preparation of a SWPPP that would address site specific drainage issues related to construction activities and include BMPs to eliminate the potential of flooding or alteration of a drainage pattern during construction activities.

The Project site is vacant and relatively flat, When the site is fully developed, the site’s impervious surfaces would inherently increase. As previously stated, the on-site runoff will be collected into catch basins, drain into the underground storm drain system, and then discharged into existing 60-inch storm drain in E. North Avenue near the northern and northeastern portion of the Project site. Proposed development is compliant with the requirements set by the FMFCD and the City’s hydrology and LID standards. The Project would result in no increase in runoff and no flood risk to neighboring properties and existing storm drain system. The existing storm drain facility would serve the Project site. Therefore, the Project would result in a less than significant. No new impacts related to flooding on- or off-site would occur, and no mitigation is required.
97 iii. Create or contribute runoff water, which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact with implementation of mitigation (MM HYD-3.1 through -3.5 )regarding this topic. The Project site currently vacant and as previously discussed, once the Project site fully developed would minimally increase the site’s impervious surfaces. Therefore, would not substantially increase runoff from the site, and create a less than significant flood risk to neighboring properties and existing storm drain system. Furthermore, compliance with the MS4, as specified in the Construction General Permit, and other existing regulatory requirements, would reduce or eliminate the potential for project operations to cause substantial additional polluted runoff or runoff in excess of existing or planned stormwater drainage systems. Therefore, the Project would result in no new impacts related to runoff which would exceed the capacity of existing or planned stormwater drainage systems, and no mitigation is required.
iv. Impede or redirect flood flows?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. The Project site is located on FEMA Flood Insurance Rate Map (FIRM) 06019C2110H and is identified within Zone X, Area of minimal Flood Hazard. The Project would not impede or redirect flood flows that could directly or indirectly impact onsite drainages. Therefore, the Project would result in no new impacts impact related to flood flows, and no mitigation is required.
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. As discussed above, the Project site is not within a flood hazard zone, and flooding impacts would not be anticipated. The Project site is over 100 miles from the Pacific Ocean shoreline and based on the inland location of the site, the Project site is not within a tsunami zone. In addition, the nearest body of water with the potential to produce a seiche is the Big Creek Dry Dam and Reservoir, approximately 14 miles from the Project site, therefore not located in a seiche zones. As further discussed in Section IX, the use of hazardous materials within the Project site would have a less than significant impact on the release of hazardous materials. As a result, no new impacts would occur related to the release of pollutants due to project inundation in flood hazard, tsunami, or seiche zones, an no mitigation is required.
e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
98 No New Impact. This topic was not evaluated under the GP PEIR. The Project site is located within jurisdiction of the CVRWQCB. The CVRWQCB developed the Water Quality Control Plan for the Central Valley Region, The Water Quality Control Plan (Basin Plan) for the California Regional Water Quality Control Board Central Valley Region Fifth Edition (Central Valley Region, revised 2018). The Water Quality Control Plan is designed to preserve and enhance water quality and protect the beneficial uses of all regional waters.

Additionally, the Project site is located within the North Kings Groundwater Sustainability Agency (NKGSA) part of the Kings Subbasin. Furthermore, the Kings Subbasin is part of the larger San Joaquin Valley Groundwater Basin. The planning documents regarding water resources for the City include the City of Fresno UWMP and the City of Fresno Metropolitan Water Resources Management Plan. As noted above, the proposed Project would be required per the Construction General Permit to adhere to NPDES drainage control requirements during construction and operation as well as to FMFCD drainage control requirements. As a result, the proposed Project would not include any other waste discharges that could conflict with the Basin Plan. Therefore, the proposed Project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan and no new impacts would occur.

CONCLUSION
With regards to the issue area of Hydrology and Water Quality, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No mitigation measures contained within the GP PEIR would be required because Project specific impacts would be less than significant by adhering to the project conditions of approval, which are consistent with the GP PEIR as described above.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
None.
99 ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
XI. LAND USE AND PLANNING – Would the project:
a) Physically divide an
established community?
b) Cause a significant
environmental impact due to
a conflict with any land use
plan, policy, or regulation
adopted for the purpose of
avoiding or mitigating an
environmental effect?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
The PEIR discussed land use and planning‐related impacts in Section 4.11. The GP contains specific policies and objectives that ensure land use impacts are reduced with no mitigation required. The PEIR discussions of land use and planning‐related impact areas are summarized below.

As stated in the PEIR, the study area regarding land use and planning impacts is the City of Fresno Planning Area because potential development under the GP is limited to areas within the Planning Area. The Planning Area encompasses the City’s incorporated area approximately 113 square miles and the unincorporated areas located in Fresno County approximately 53 square miles.

According to the PEIR, development in accordance with the GP would result in a substantial amount of additional development throughout the Planning Area. Such development included infill and underutilized development within the City, revitalization of existing neighborhoods, new activity centers with mixed uses and neighborhoods, and development within rural/agriculture areas located outside the City and within the Planning Area.

It was anticipated future development in accordance with the GP could create conflicts between existing and new land uses. However, the previously mentioned objectives and policies would reduce land use conflicts and provide for orderly development to reduce the potential to divide established communities. As a result, impacts regarding division of established neighborhoods were determined to be less than significant. 100
Development in accordance with the GP requires consistency with various federal, state, and local plans, policies, and regulations. The GP serves as a consolidated location for current Community, Specific and other Plan types. As concluded in the PEIR, implementation of the GP was not inconsistent with these Plans, and potential impacts from conflicts with existing land use plans was considered to be less than significant.

PROJECT-SPECIFIC IMPACTS
a) Physically divide an established community?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. The Project would construct a new approximately 205,000 square foot concrete tilt-up industrial building and ancillary structures, landscaping, and pavement. The Project site is vacant and designated for Heavy Industrial and zoned IH similar to the surrounding uses. Therefore, the proposed Project would be consistent with the existing land use and zoning designations. The Project would not introduce roadways or other infrastructure improvements that would bisect or transect the Project site or surrounding area.

Therefore, the Project would result in no new impacts related to dividing an established community.
b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. The PEIR affirmed development in accordance with the GP would require consistency with various federal, state, and local plans, policies, and regulations.

As stated in the Project Description, the Project site is designated Employment - Heavy Industrial in the GP, and this land use is intended to accommodate the broadest range of industrial uses including manufacturing, assembly, wholesaling, distribution, and storage activities that are essential to the development of a balanced economic base. In addition, small-scale commercial services and ancillary office uses are also permitted. The maximum floor area ratio (FAR) is 1.5. The Project site is located in IH zoning district which allows for similar land uses.

As previously stated, the Project is consistent with the GP land use designation and the zoning. The Project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Therefore, the Project would result in no impact.

Objectives and policies applicable to the Project that are included in the General Plan are provided in Table 12, as well as identification of how the Project would be consistent with these objectives and policies.
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Table 12: Project Consistency with General Plan
Objective / Policy Project Consistency
Land Use Element
Policy LU-1-a: Promote Development within
the Existing City Limits as of December 31,
2012. Promote new development, infill, and
rehabilitation of existing building stock in the
Downtown Planning Area, along BRT corridors,
in established neighborhoods generally south of
Herndon Avenue, and on other infill sites and
vacant land within the City.

Consistent – The Project would include
construction of a new industrial building
including landscaping and architectural
treatments would result in an overall benefit to
the physical character of the vacant Project site
as the site.

Policy LU-1-b: Land Use Definition and
Compatibility. Include zoning districts and
standards in the Development Code that
provide for the General Plan land use
designations and create appropriate transitions
or buffers between new development with
existing uses, taking into consideration the
health and safety of the community.

Consistent – The Project would construct a
modern industrial building consistent with
Heavy Industrial GP land use designation. The
Project would also comply with all provisions of
the IH zone, which mirrors and implements the
Heavy industrial land use designation.

Mobility and Transportation
Objective MT-1: Create and maintain a
transportation system that is safe, efficient,
provides access in an equitable manner, and
optimizes travel by all modes.

Consistent – Implementation of the Project
provides the construction to complete
sidewalks, and curb and gutters along right-ofway at E North Avenue and S East Avenue ultimately tying into existing crosswalk at such
intersection. The Projective provides safe
pedestrian mobility, therefore is consistent with
objective.

Policy MT-2-b: Reduce Vehicle Miles Traveled
and Trips. Partner with major employers and
other responsible agencies, such the San
Joaquin Valley Air Pollution Control District and
the Fresno Council of Governments, to
implement trip reduction strategies, such as
eTRIP, to reduce total vehicle miles traveled
and the total number of daily and peak hour
vehicle trips, thereby making better use of the
existing transportation system.

Consistent – As indicated in Section XVII,
Project impacts regarding VMT were
determined to be less than significant.

Public Utilities and Services
Policy PU-2-e: Service Standards. Strive to
achieve a community wide risk management
plan that include the following service level
objectives 90 percent of the time:
• First Unit on Scene – First fire unit arriving
with minimum of three firefighters within 5
Consistent – The Project is within 4 min of the
nearest fire station, therefore within the 5-
minute response zone. As discussed in Section
XV, impacts are less than significant.
102
minutes and 20 seconds from the time the
unit was alerted to the emergency incident.
• Effective Response Force – Provide
sufficient number of firefighters on the scene
of an emergency within 9 minutes and 20
seconds from the time of unit alert to arrival.

The effective response force is measured as
15 firefighters for low risk fire incidents and
21 firefighters for high risk fire incidents and
is the number of personnel necessary to
complete specific tasks required to contain
and control fire minimizing loss of life and
property.

Policy PU-3-a: Fire Prevention Inspections.

Develop strategies to enable the performance
of annual fire and life safety inspection of all
industrial, commercial, institutional, and multifamily residential buildings, in accordance with nationally recognized standards for the level of
service necessary for a large Metropolitan Area,
including a self-certification program.

Consistent – Coordination with FFD would be
ongoing throughout Project planning,
construction, and operation.

Policy PU-4-c: System Extension and Cost
Recovery. Pursue enlargement or extension of
the sewage collection system where necessary
to serve planned urban development, with the
capital costs and benefits allocated equitably
and fairly between the existing users and new
users.

Consistent – As discussed in Section XIX, the
Project would install a sewer house branch to
connect to nearby 12-inch sewer main located
in S. East Avenue and pay Sewer Connection
Charges.

Policy PU-8-b: Potable Water Supply and Cost
Recovery. Prepare for provision of increased
potable water capacity (including surface water
treatment capacity) in a timely manner to
facilitate planned urban development consistent
with the General Plan. Accommodate increase
in water demand from the existing community
with the capital costs and benefits allocated
equitably and fairly between existing users and
new users, as authorized by law, and
recognizing the differences in terms of quantity,
quality and reliability of the various types of
water in the City’s portfolio.

Consistent – As discussed in Section XIX, the
Project would install water service and meter
boxes and pay the Water Capacity Fee for
installation.

Noise & Safety
Policy NS-1-a: Desirable and Generally
Acceptable Exterior Noise Environment.

Establish 65 dBA Ldn or CNEL as the standard
for the desirable maximum average exterior
noise levels for defined usable exterior areas of
residential and noise- sensitive uses for noise,
but designate 60 dBA Ldn or CNEL (measured at
Consistent – As discussed in Section XIII, the
Project would be consistent with City noise
standards and would not result in noise
impacts.
103
the property line) for noise generated by
stationary sources impinging upon residential
and noise- sensitive uses. Maintain 65 dBA Ldn
or CNEL as the maximum average exterior
noise levels for non-sensitive commercial land
uses, and maintain 70 dBA Ldn or CNEL as
maximum average exterior noise level for
industrial land uses, both to be measured at the
property line of parcels where noise is
generated which may impinge on neighboring
properties.

Policy NS-1-p: Airport Noise Compatibility.

Implement the land use and noise exposure
compatibility provisions of the adopted Fresno
Yosemite International Airport Land Use
Compatibility Plan, the Fresno-Chandler
Executive Airport Master and Environs Specific
Plan, and the Sierra Sky Park Land Use Policy
Plan to assess noise compatibility of proposed
uses and improvements within airport influence
and environs areas.

Consistent – As discussed in Section XIII, the
Project is not within an airport influence area,
therefore would not result in airport noise
compatibility impacts.

Policy NS-2-a: Seismic Protection. Ensure
seismic protection is incorporated into new and
existing construction, consistent with the Fresno
Municipal Code.

Consistent – As discussed in Section VII,
according to the Geotechnical Engineering
Report, a site Class D was selected for the
Project site based on soil conditions with
standard, and Project foundation design are to
be based on the 2019 CBC. Therefore, the
Project would be consistent with Chapter 11 of
the FMC.

Policy NS-3-b: Curb and Gutter Installation.

Coordinate with Fresno Metropolitan Flood
Control District (FMFCD) to install curbing,
gutters, and other drainage facilities with priority
to existing neighborhoods with the greatest
deficiencies and consistent with the Storm
Drainage and Flood Control Master Plan.

Consistent – As discussed in Section XIX, the
Project would construct and match existing curb
and gutters along S. East Avenue and E. North
Avenues, thereby tying into three proposed
driveways. Furthermore, the proposed on site
storm drain system would convey storm flows at
two northernly locations into the City’s 60-inch
storm drain (Project to upgrade northeastern
existing 18-inch storm drain to 30-inch storm
drain) in E. North Avenue.

Noise & Safety
Policy NS-4-a: Processing and Storage.

Require safe processing and storage of
hazardous materials, consistent with the
California Building Code and the Uniform Fire
Code, as adopted by the City.

Consistent – As identified in Section IX, Project
construction and operation would follow federal,
state, and local standards. By following
applicable standards, the Project would
minimize risk to life and property from
production, use, storage and transportation of
hazardous materials and waste.

Policy NS-6-f: Emergency Vehicle Access.

Require adequate access for emergency
Consistent – The Project had been viewed by
the FFD and would be required to comply with
104
vehicles in all new development, including
adequate widths, turning radii, hard standing
areas, and vertical clearance.
requirements of the most recent CBC. Through
compliance with City and fire connectivity
standards, emergency vehicle access
measures would be implemented.

Healthy Communities
Policy HC-2-c: Prevent Crime through Design.

Incorporate Crime Prevention Through
Environmental Design (CPTED) principles and
best practices into project review procedures for
new development and major renovations.

Consistent – As discussed in Section I, the
Project provides adequate site lighting for
safety, as well as a gated entry with adequate
emergency access for added site security.

Therefore, the Project would be consistent with
the City’s crime reduction efforts.

Policy HC-2-e: Bike and Pedestrian Network.

Continue to promote alternative modes of
transportation through development and
maintenance of a citywide pedestrian and
bicycle network.

Consistent – The Project proposes to connect
the proposed pedestrian walkways by matching
existing walkways with construction of new
driveways. Therefore, the Project would support
alternate modes of transportation within the
area.

Policy NS-4-e: Compliance with County
Program. Require that the production, use,
storage, disposal, and transport of hazardous
materials conform to the standards and
procedures established by the County Division
of Environmental Health. Require compliance
with the County’s Hazardous Waste Generator
Program, including the submittal and
implementation of a Hazardous Materials
Business Plan, when applicable.

Consistent – As identified in Section IV, Project
construction and operation would follow federal,
state, and local standards. By following
applicable standards, the Project minimize risk
to life and property from production, use,
storage and transportation of hazardous
materials and waste.

Resource Conservation and Resilience
Policy RC-5-a: Support State Goal to Reduce
Statewide GHG Emissions. As is consistent
with State law, strive to meet AB 32 goal to
reduce greenhouse gas emissions to 1990
levels by 2020 and strive to meet a reduction of
80 percent below 1990 levels by 2050 as stated
in Executive Order S-03-05. As new statewide
GHG reduction targets and dates are set by the
State update the City’s Greenhouse Gas
Reduction Plan to include a comprehensive
strategy to achieve consistency with those
targets by the dates established.

Consistent – Evaluation of Project impacts
related to greenhouse gas emissions is
discussed in Section VIII, Greenhouse Gases.

As concluded in Section VII, the Project would
be consistent with applicable GHG reduction
plans and would result in a less than significant
impact from GHG emissions.

Policy RC-6-b: Water Plans. Adopt and
implement ordinances, standards, and policies
to achieve the intent of the City of Fresno Urban
Water Management Plan, Fresno-Area
Regional Groundwater Management Plan, and
City of Fresno Metropolitan Water Resources
Management Plan to ensure a dependable
supply of water.

Consistent – As discussed in Section XIX, the
Project would install water service and meter
boxes and pay Water Capacity Fee for
installation.
105
Policy RC-7-h: Landscape Water Conservation
Standards. Refine landscape water
conservation standards that will apply to new
development installed landscapes, building on
the State Model Water Efficient Landscape
Ordinance and other State regulations.
• Evaluate and apply, as appropriate,
augmented xeriscape, “water-wise,” and
“green gardening” practices to be
implemented in public and private landscaping
design and maintenance.
• Facilitate implementation of the State’s
Water Efficient Landscape Ordinance by
developing alternative compliance measures
that are easy to understand and observe.

Consistent – The Project would be equipped
with a low flow irrigation system with smart
technology supporting climate-appropriate
ornamental trees, shrubs, and groundcover
ranging from moderate to low water needs.

Policy RC-8-a: Existing Standards and
Programs. Continue existing beneficial energy
conservation programs, including adhering to
the California Energy Code in new construction
and major renovations.

Consistent – Energy efficient and climatefriendly appliances and equipment would be incorporated into Project design as appropriate
and feasible.

Therefore, the Project would result in no new impacts related to conflicts with a land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

CONCLUSION
With regards to the issue area of Land Use and Planning, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No mitigation measures contained within the GP PEIR would be required because Project specific impacts would be less than significant. Therefore, the Project would not result in an impact which was not adequately evaluated by the GP PEIR.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
None.
106

ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
XII. 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 locallyimportant mineral resource
recovery site delineated on a
local general plan, specific
plan or other land use plan?
Summary of Impacts Identified in the GP PEIR
The PEIR concluded that impacts to mineral resources were less than significant with implementation of GP objective and policies to conserve aggregate mineral resources within the Planning Area. These mineral resources are located in and immediately adjacent to the Planning Area along the San Joaquin River Corridor, and are being removed via surface mining operations. Such activities have been and will continue to require conditional use permits. Furthermore, these activities will continue until the resources are substantially removed, and until it is no longer economically feasible to mine the areas as stated in the following policy of City’s 2000 GP, Land Use Element.

Policy LU‐C.6: The County may allow the extraction of rock, sand, and gravel resources along the San Joaquin River consistent with the Minerals Resources section policies of the Open Space and Conservation Element.

PROJECT-SPECIFIC IMPACTS
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?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. Although the City has active surface mining operations adjacent to the Planning Area, the California Department of Conservation does not designate the City as being within a Significant Mineral Aggregate Resource Area (SMARA). The GP 107
PEIR determined that principal mineral resources located in and immediately adjacent to the Planning Area are aggregate materials along the San Joaquin River corridor. The corridor is approximately 72 miles to the northeast of the Project site. Thus, known mineral resources associated with the corridor would not be found within the site. In addition, the Project site has not been previously used for mineral resource extraction and is zoned as heavy industrial district/urban growth management Subsurface conditions encountered by the geotechnical borings predominantly consisted of sandy silt underlain by interbedded layers of sandy silt and silty sand, poorly-graded sand, and poorly graded sand with silt to the maximum depth of

41.5 feet below site grade. Therefore, the Project site is not located in the area of such active mineral extraction activities, nor within SMARA. Therefore, no new impacts related to loss of availability of a known mineral resource would occur.
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? No New Impact. This environmental topic was included under Impact MIN-2 (Section 4.12) of the PEIR where it was concluded impacts from development of the GP would be less than significant. The GP includes designated areas of locally important mineral resource recovery within the San Joaquin River Corridor (MRZ-2). However, such area is designated Open Space and other surrounding areas including the Project site are within MRZ-3 designations which the City does not prohibit development. Therefore, the Project would result in no new impacts related to locally important mineral resources.

CONCLUSION
With regards to the issue area of Mineral Resources, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No mitigation measures contained within the GP PEIR would be required because Project specific impacts would be less than significant. Therefore, the Project would not result in an impact which was not adequately evaluated by the GP PEIR.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
None.
108

ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
XIII. NOISE – Would the project result in:
a) Generation of a substantial
temporary or permanent
increase in ambient noise
levels in the vicinity of the
project in excess of standards
established in the local
general plan or noise
ordinance, or applicable
standards of other agencies?
b) Generation of excessive
groundborne vibration or
groundborne noise levels?
c) For a project located within
the vicinity of a private airstrip
or an airport land use plan or,
where such a plan has not
been adopted, within two
miles of a public airport or
public use airport, would the
project expose people
residing or working in the
project area to excessive
noise levels?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
The PEIR discussed noise and vibration impacts in Section 4.13. The PEIR analyzed a range of potential impacts related to noise and vibration, including exposure of existing and new development to excessive noise levels, increased traffic noise from buildout projections, a cumulative increase in citywide noise levels, and construction‐related noise and vibration.

According to the PEIR, implementation of the GP would generate or expose noise sensitive receptors to ambient noise levels in excess of standards established in the City’s GP and noise ordinance.
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The GP includes Policies NS-1-a through NS-1-p to specifically address noise impacts from but not limited to cumulative noise level exposure from short-term construction activities, and long-term impacts from roadways, aircraft, trains, and stationary sources. This exposure was expected to occur in areas with high commercial and industrial uses, as well as such areas adjacent to residential uses. Adherence to these GP policies would reduce noise impacts from these sources; however, long-term impacts remained significant and unavoidable. Short-term construction impacts were determined to be less than significant due to requirements set forth in City’s noise ordinance and activities are to be conducted pursuant to construction permits.

Implementation of the following General Plan policies was determined to reduce noise impacts, although the long-term impacts would remain significant and unavoidable:

Policy NS‐1‐a. Desirable and Generally Acceptable Exterior Noise Environment.

Establish 60 dB LDN or CNEL as the standard for the desirable maximum average exterior noise levels for defined usable exterior areas of residential and noise‐sensitive uses for noise, but accept 65 dB LDN or CNEL for noise generated by transportation sources.

Policy NS-1-b. Conditionally Acceptable Exterior Noise Exposure Range. Establish the conditionally acceptable noise exposure level range for residential and other noise sensitive uses to be 65 dB Ldn or require appropriate noise reducing mitigation measures as determined by a site specific acoustical analysis to comply with the desirable and conditionally acceptable exterior noise level and the required interior noise level standards set in Table G below.

Policy NS-1-c. Generally Unacceptable Exterior Noise Exposure Range. Establish the exterior noise exposure of greater than 65 dB Ldn or CNEL to be generally unacceptable for residential and other noise sensitive uses for noise generated by sources in Policy NS-1-a, and study alternative less noise-sensitive uses for these areas if otherwise appropriate.

Require appropriate noise reducing mitigation measures as determined by a site specific acoustical analysis to comply with the generally desirable or generally acceptable exterior noise level and the required 45 dB interior noise level standards set in Table G as conditions of permit approval.

Policy NS‐1‐g. Noise mitigation measures which help achieve these noise level targets may include, without limitation, the following:
• Construct façades with substantial weight and insulation; • Use sound‐rated windows for primary sleeping and activity areas; • Use sound‐rated doors for all exterior entries at primary sleeping and activity areas; • Use minimum setbacks and exterior barriers;
• Use acoustic baffling of vents for chimneys, attic and gable ends; 110
• Install a mechanical ventilation system that provides fresh air under closed window conditions.

Policy NS‐1‐h. Interior Noise Level Requirement. Comply with the State Code requirement that any new multifamily residential, hotel, or dorm building exposed to exterior noise levels above 60 decibels CNEL must be designed to incorporate noise reduction measures to meet the 45 dB LDN interior noise criterion, and apply this standard as well to all new single‐family residential and noise sensitive issues.

Policy NS‐1‐i. Mitigation by New Development. Require a noise study where new development of industrial, commercial or other noise generating land uses (including transportation facilities such as roadways, railroads, and airports) may result in noise levels that exceed the noise level exposure criteria established by Tables 9‐2 and 9‐3 to determine impacts, and require developers to mitigate these impacts in conformance with Tables 9‐2 and 9‐3 as a condition of permit approval through appropriate means. • Noise mitigation measures may include, but are not limited to:
• Screen and control noise sources, such as parking and loading facilities, outdoor activities, and mechanical equipment;
• Increase setbacks for noise sources from adjacent dwellings; • Retain fences, walls, and landscaping that serve as noise buffers; • Use soundproofing materials and double‐glazed windows; • Use open space, building orientation and design, landscaping and running water to mask sounds; and
• Control hours of operation, including deliveries and trash pickup, to minimize noise impacts.
• Alternative acoustical designs that achieve the prescribed noise level reduction may be approved by the City, provided a qualified Acoustical Consultant submits information demonstrating that the alternative designs will achieve and maintain the specific targets for outdoor activity areas and interior spaces. As a last resort, developers may propose to construct noise walls along state routes (freeways and expressways), super arterials, and arterials when compatible with aesthetic concerns and neighborhood character. This would be a developer responsibility, with no City funding.

Policy NS‐1‐j. Significance Threshold. Establish, as a threshold of significance for the City’s environmental review process, that a significant increase in ambient noise levels is assumed if the project would increase noise levels in the immediate vicinity by 5 dB LDN or CNEL or more.

Policy NS‐1‐k. Proposal Review. Review all new public and private development proposals that may potentially be affected by or cause a significant increase in noise levels, per Policy NS‐1‐i, to determine conformance with the policies of this Noise Element. Require developers to reduce the noise impacts of new development on adjacent properties through appropriate means.
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Policy NS-1-m. Transportation Related Noise Impacts. For projects subject to City approval, require that the project sponsor mitigate noise created by new transportation and transportation related stationary noise sources, including roadway improvement projects, so that resulting noise levels do not exceed the City’s adopted standards for noise-sensitive land uses.

Policy NS‐1‐n. Best Available Technology. Require new noise sources to use best available control technology to minimize noise emissions.

GP PEIR MITIGATION MEASURES
MM NOI‐2 Construction Vibration. The use of heavy construction equipment within 25 feet of existing structures shall be prohibited.

PROJECT-SPECIFIC IMPACTS
a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or in other applicable local, state, or federal standards? No New Impact. The GP PEIR determined the GP Update would result in a less than significant impacts (short-term), and result in significant and unavoidable impacts, with no feasible mitigation measures available (long-term), regarding this topic.

Certain land uses are considered more sensitive to noise than others including residential areas, educational facilities, hospitals, childcare facilities, and senior housing. The Project site is primarily surrounded by industrial uses. For the purposes of this analysis, the surrounding noise receptors are the existing DMV office, approximately 120 feet west of the Project boundary, and the existing religious use building at 3060 S. Cherry Street, approximately 1,100 feet to the west of the Project boundary.

Sort-Term Construction Noise Impacts
Construction activities for the proposed Project are anticipated to include site preparation and grading, building construction of the proposed 205,000 sf industrial building, paving of onsite driveways, parking lots and truck loading area, and application of architectural coatings. Noise impacts from such construction activities would be a function of the noise generated by construction equipment, equipment proximity to nearby land uses, and the timing and duration of the construction activities.

Section 10-101 of the City’s Municipal Code contains the City’s Noise Ordinance, which establishes noise guidelines and exemptions for excessive noise. Standards are set for ambient noise based on district type (residential, commercial, and industrial) and time of day.

Industrial noise standards are applicable to the Project. Construction noise is exempt from 112
such standards when work takes place between 7:00 a.m. and 10:00 p.m. on any day except Sundays.

Construction noise impacts to the nearby sensitive receptors have been calculated as part of the Noise and Vibration Impact Analysis completed for the Project (Appendix G). Noise emission estimates show that the greatest noise generation would occur during the grading phase of construction, with a composite noise level as high as 87dBA Leq at a distance of 50 feet.

Table 13 shows the nearest sensitive uses to the Project site, and their distance from the center of construction activities, and composite noise levels expected during construction.

These noise level projections do not take into account intervening topography or barriers.

Construction equipment calculations are provided in Appendix B of the Noise and Vibration Impact Analysis.

Table 13: Potential Construction Noise Impacts at Nearest Receptor Receptor Direction
Composite Noise
Level
(dBA Leq) at 50
feet1
Distance
(feet)
Composite
Noise
Level (dBA
Leq)
DMV Commercial
Office
West
87 575 66
Religious Use West 1,480 58
Source: Compiled by LSA (2022).
1 The composite construction noise level represents the grading phase which is expected to result in the greatest noise level as compared to other phases.
dBA Leq = average A-weighted hourly noise level
While construction noise will vary, it is expected that composite noise levels during construction at the nearest off-site sensitive uses to the north would reach 66 dBA Leq. These predicted noise levels would only occur when all construction equipment is operating simultaneously, a conservative assumption that would overestimate Project noise levels at the sensitive receptor locations. While construction-related short-term noise levels have the potential to be higher than existing ambient noise levels in the Project area under existing conditions, the noise impacts would no longer occur once Project construction is completed.

As stated above, noise impacts associated with construction activities are regulated by the City’s noise ordinance. The proposed Project would be required to comply with the construction hours specified in the City’s Noise Ordinance, which states that construction activities are allowed between 7:00 a.m. and 10:00 p.m., any day except Sundays.

In addition to compliance with the City’s Municipal Code allowed days and hours of construction, the following construction best practices (Mitigation Measure, MM NOI-1), when implemented, further minimize construction noise impacts:
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• The Project construction contractor shall equip all construction equipment, fixed or mobile, with properly operating and maintained noise mufflers consistent with manufacturer’s standards.
• The Project construction contractor shall place all stationary construction equipment so that emitted noise is directed away from sensitive receptors nearest the Project site whenever feasible.

Through adherence to the limitation of allowable construction days and times for noise provided in Section 10-109 of the Municipal Code and the use of best management practices, construction-related noise levels would not exceed any standards established in the GP or Noise Ordinance nor would construction activities create a substantial temporary increase in ambient noise levels from construction of the proposed Project. No new impacts would occur, and no mitigation is required.

Long-Term Operation Noise Impacts
The proposed Project would consist of the development and operation of an industrial building used for food and beverage storage. As such, the near-by off-site DMV office and the religious use building would be potentially exposed to stationary-source noise impacts from the proposed Project’s on-site rooftop equipment, truck deliveries, truck maintenance facility, and loading and unloading activities. According to the Project’s Noise and Vibration Impact Analysis (Appendix G), 3-D noise modeling (SoundPLAN) was used to incorporate the site topography, and shielding from other building to determine the future noise impacts from Project operations to the noise sensitive uses.

The Project would have various rooftop mechanical equipment including HVACunits on the proposed building. Conservatively, the equipment could operate 24 hours per day and would generate sound power levels (SPL) of up to 98.6 dBA SPL, based on data provided by the Project engineer.

Air nozzles, torque guns, vehicle lifts, and other typical pieces of equipment used in an auto mechanic garage would be located in the truck maintenance area of the Project site to provide maintenance to vehicles and trucks. According to the noise analysis, sound-power levels for these pieces of equipment are 113.0 dBA SPL, 105.4 dBA SPL, and 92.4 dBA SPL, and it is assumed such equipment could operate for more than 30 minutes in a given hour conservatively.

Delivery trucks would arrive and depart the site via access at the most western driveway along E. North Avenue. Delivery trucks would approach the loading docks along the western portion of the Project site. Noise levels associated with truck engine noise, air brakes, and back-up alarms would generate a noise level of 76.3 dBA Leq at 20 ft (LSA measurements from similar study in 2016). These noise levels would occur for a shorter period of time (less than 5 minutes), and it was assumed conservatively in the noise analysis that truck arrivals and departure activities could occur for more than 30 minutes in a given hour. 114
Noise levels generated by delivery trucks would be similar to noise readings from truck loading and unloading activities, which generate a noise level of 75 dBA Leq at 20 ft (LSA measurements from similar study in 2016). It was assumed conservatively in the noise analysis that unloading activities could occur at all docks simultaneously for a period of more than 30 minutes in a given hour.

As shown in Table 14 below, the combined hourly noise levels generated by Project activities at the closest off-site land uses would range from 41.7 dBA Leq to 51.8 dBA Leq at the surrounding sensitive receptors. Although the Project has the potential to operate 24 hours a day and continuous during any given day, noise levels would be below the City’s more restrictive nighttime commercial use ambient noise standard of 60 dBA Leq. While the Project noise level impact analysis was completed to show compliance with nighttime noise level standards, the commercial uses are likely to be open during daytime and evening hours. As analyzed, the Project noise levels would not exceed the City’s ambient noise standards, therefore impacts would be less than significant.

Table 14: Commercial Use Exterior Noise Level Impact
Receptor Direction
Nighttime Ambient
Noise Level
Standard (dBA Leq)
Project
Generated
Noise
Levels (dBA
Leq)
Potential
Operational
Noise
Impact?
DMV Commercial
Office
West 60.0 51.8 No
Religious Use West 60.0 41.7 No
Source: Compiled by LSA (2022)
dBA = A-weighted decibels
Leq = equivalent noise level
As discussed above, long-term operation of the proposed Project would also not create a significant increase in traffic noise or stationary source noise, including noise associated with HVAC equipment, parking lot activities, truck maintenance operations and truck delivery and loading/unloading activities. Therefore, the Project would result in no new impacts related to increase in ambient noise levels in the vicinity of the Project in excess of standards established in the local general plan or noise ordinance.
b) Generation of excessive groundborne vibration or groundborne noise levels? No New Impact. This topic was evaluated in the PEIR in Section 4.13 (Impact NOI-2) where it was determined the GP would result in a less than significant impact with mitigation (MM NOI-2) required. As stated in the PEIR, the City’s Development Code (e.g., setbacks, easements, rights-of-way) ensures that in most cases onsite and offsite structures would be separated by at least 25 feet. Thus, construction activities would be buffered by at least 25 feet from existing offsite structures, therefore the GP would allow for more infill development 115
in more densely developed areas, such as the proposed Project and no new impacts would occur.

Construction
As discussed in the Project’s Noise and Vibration Impact Analysis (Appendix G), groundborne vibration is almost exclusively a concern inside buildings and is rarely perceived as a problem outdoors, where the motion may be discernible. Annoyance from vibration often occurs when the vibration exceeds the threshold of perception by 10 dB or less, which is an order of magnitude below the damage threshold for normal buildings.

As shown in Table 15, bulldozers and other heavy-tracked construction equipment (expected to be used for this Project) generate approximately 0.089 PPV in/sec or 87 VdB of groundborne vibration when measured at 25 ft, based on the Federal Transit Administration (FTA) Manual. The distance to the nearest buildings for vibration impact analysis is measured between the nearest off-site buildings and the Project construction boundary (assuming the construction equipment would be used at or near the Project setback line).

Table 15: Vibration Source Amplitudes for Construction Equipment Equipment Reference PPV/LV at 25 ft
PPV (in/sec) LV (VdB)1
Pile Driver (Impact), Typical 0.644 104
Pile Driver (Sonic), Typical 0.170 93
Vibratory Roller 0.210 94
Hoe Ram 0.089 87
Large Bulldozer2 0.089 87
Caisson Drilling 0.089 87
Loaded Trucks2 0.076 86
Jackhammer 0.035 79
Small Bulldozer 0.003 58
Source: Transit Noise and Vibration Impact Assessment Manual (FTA 2018). 1 RMS vibration velocity in decibels (VdB) is 1 µin/sec. 2 Equipment shown in bold is expected to be used on site. µin/sec = microinches per second ft = foot/feet
FTA = Federal Transit Administration in/sec = inch/inches per second LV = velocity in decibels PPV = peak particle velocity RMS = root-mean-square VdB = vibration velocity decibels
Based on the information provide in Table 16, vibration levels are expected to approach 0.008 in/sec in PPV at the surrounding structures and would be below the 0.2 in/sec PPV threshold according to the FTA guidelines for a non-engineered timber and masonry buildings (Transit Noise and Vibration Impact Assessment Manual, 2018). Therefore, a less than significant vibration impact is anticipated from construction of the proposed Project. 116
Table 16: Summary of Construction Vibration Levels
Land Use Direction Equipment
Reference
Vibration
Level (VdB)
at 25 ft
Reference
Vibration
Level
(PPV)
at 25 ft
Distance
(ft)1
Maximum
Vibration
Level
(VdB)
Maximum
Vibration Level
(PPV)
Industrial West Large
Bulldozers 87 0.089 120 67 0.008
Source: Compiled by LSA (2022).
1 Distances reflect the closest single-family residence to the construction equipment in each direction. All other homes in a given direction would experience lower vibration levels.
ft = foot/feet
FTA = Federal Transit Administration in/sec = inch/inches per second PPV = peak particle velocity
VdB = vibration velocity decibels
According to the FTA Manual, the threshold at which vibration levels would result in annoyance would be 84 VdB for commercial and office type uses. Based on the information provided in Table 16, vibration levels are expected to approach 67 VdB at the industrial office uses to the west and would not exceed the annoyance thresholds. Other building structures surrounding the Project site are farther away and would experience further reduced vibration.

Further reducing such impacts, according to the City’s Municipal Code Sec. 15-2507 Vibration, vibrations from temporary construction, demolition, and vehicles that enter and leave the subject parcel (e.g., construction equipment, trains, trucks, etc.) are exempt from this standard. Therefore, no construction new vibration impacts would occur. No vibration reduction measures are required.

Operation
The proposed Project would consist of the development of an industrial building and would result in the addition of passenger vehicles and trucks entering and exiting the site. As concluded in the vibration analysis, long-term Project operations would not generate substantive vibration due to rubber tires and suspension systems of on-road vehicles.

Therefore, vibration levels generated from Project-related traffic onsite and on adjacent roadways would be less than significant and no mitigation measures are required. Therefore, the Project would result in no new impacts related to ground born vibration. c) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
No New Impact. This topic was evaluated in the PEIR and it was determined the GP would result in a less than significant impact. The Project would not expose people working in the Project site to excessive noise levels from aircraft. The nearest airport is Fresno Chandler Executive Airport located approximately 3.6 miles to the northwest and the Project site is located outside of the noise contours of the airport. Therefore, the Project would result in no 117
new impacts related to exposure of people residing or working in the Project site to excessive noise levels from aircraft.

MITIGATION MEASURES
MM NOI-1 Construction Equipment Best Practices
• The Project construction contractor shall equip all construction equipment, fixed or mobile, with properly operating and maintained noise mufflers consistent with manufacturer’s standards.
• The Project construction contractor shall place all stationary construction equipment so that emitted noise is directed away from sensitive receptors nearest the Project site whenever feasible.

CONCLUSION
With regards to the issue area of Noise, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No mitigation measures contained within the GP PEIR have been incorporated into the Project. The mitigation measure, as detailed above, requires the construction contractor to implement best practices to further reduce short-term construction noise impact in addition to the requirement of project applicant to comply with the City Noise Ordinance.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) Municipal Code Section 10-109 - Exceptions
Municipal Code Section 15-2507 - Vibration

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
None.
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ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
XIV. POPULATION AND HOUSING – Would the project:
a) Induce substantial
unplanned population growth
in an area, either directly (for
example, by proposing new
homes and businesses) or
indirectly (for example,
through extension of roads or
other infrastructure)?
b) Displace substantial
numbers of existing people or
housing, necessitating the
construction of replacement
housing elsewhere?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
The PEIR addressed population and housing impacts in Section 4.14. According to the PEIR, implementation of the GP would facilitate the construction of new housing in Fresno, which would increase the city’s population over time. The 2050 population forecast by San Joaquin Valley Demographics Forecasts (SJVDF) predicts the City’s estimated population will increase to a total 970,000 residents by 2056 the buildout year. Development facilitated by the GP would result in approximately 332,004 total residential units and approximately 393,200 total jobs at buildout. Exceedance of SJVDF population forecasts is not anticipated.

The PEIR concluded population growth would not exceed anticipated forecasts, substantial growth would not occur, and GP‐related impacts to population and housing would be less than significant. Furthermore, the PEIR concluded that the GP would not result in the displacement of substantial numbers of people or housing. Impacts were less than significant, and no mitigation measures were required or identified.

PROJECT-SPECIFIC IMPACTS
a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
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No New Impact. This topic was evaluated in the PEIR (Section 4.14) where it was determined the GP would result in a less than significant impact, with no mitigation required. The proposed Project would not directly result in unplanned population growth because it does not propose any residential dwelling units and would be consistent with the GP land use and zoning designations for the site that are used by both local and regional agencies to determine anticipated growth.

The IH zoning designation does not include standards for lot size or density. The proposed Project would result in a FAR of 0.32. The Project is consistent with the IH property development standards, that are ultimately verified by the City during the development review and building approval process. Therefore, the Project would result in no new impacts related to unplanned population growth.
b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
No New Impact. This topic was evaluated in the GP PEIR where it was determined the GP would result in a less than significant impact. The Project proposes the construction of industrial warehouse building on a vacant site with no residences. The Project would not result in displacement of existing housing or residents, nor necessitate the need for housing elsewhere. Therefore, the Project would result in no new impacts.

CONCLUSION
With regards to the issue area of Population and Housing, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No mitigation measures contained within the GP PEIR would be required because Project specific impacts would be less than significant.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP GOALS AND POLICIES APPLICABLE TO THE PROJECT
None.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
None.
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ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
XV. PUBLIC SERVICES – Would the project:
a) Result in substantial
adverse physical impacts
associated with the provision
of new or physically altered
governmental facilities, need
for new or physically altered
governmental facilities, the
construction of which could
cause significant
environmental impacts, in
order to maintain acceptable
service ratios, response times
or other performance
objectives for any of the public
services:

Fire protection?
Police protection?
Schools?
Parks?
Other public facilities?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
The PEIR discussed impacts to public services in Section 4.15 where it was determined the GP would result in a less than significant with implementation of GP objectives, policies, and mitigation measures MM PSR-1.1 through -1.4. Each of the following public services is discussed separately in the Public Services chapter:

Police Protection
As discussed in the PEIR, there are multiple agencies that provide police protection services within the GP Planning Area. Agencies include the City of Fresno Police Department (FPD), the Fresno County Sheriff’s Department, the California Highway Patrol, Fresno State Police Department, and Fresno City College Police Department. According to the PEIR, buildout of the GP Planning Area would increase the population by approximately 425,000 additional 121
residents by 2056. Therefore, the GP would have an increase in need for law enforcement and police protection. Based on the FPD goal of 1.5 officers per 1,000 residents, an additional 638 new officers would be required as well as addition equipment and facilities. Although construction of such facilities could result in adverse environmental impacts, such development would be required to follow GP policies, Mitigation Measure PSR-1.2, and Municipal Code regulations to ensure impacts would be less than significant.

Policy PU-1-b: Involvement in General Plan. Facilitate Police Department participation in the implementation of General Plan policies, including citizen participation efforts and the application of crime prevention design measures to reduce the exposure of neighborhoods to crime and to promote community security.
• Facilitate Police Department communication with citizen advisory committees. • Refer appropriate development entitlements to the Police Department for review and comment.

Policy PU-1-c: Safety Considerations in Development Approval. Continue to identify and apply appropriate safety, design and operational measures as conditions of development approval, including, but not limited to, street access control measures, lighting and visibility of access points and common areas, functional and secure on‐site recreational and open space improvements within residential developments, and use of State licensed, uniformed security.

GP PEIR MITIGATION MEASURES
MM PSR‐1.2 As future police facilities are planned, environmental review of proposed facilities shall be completed to meet the requirements of CEQA. Typical impacts from police facilities include air quality/ greenhouse gas emissions, noise, traffic, and lighting.

Fire Protection
As discussed in the PEIR, the City of Fresno Fire Department (FFD) provides fire prevention, fire suppression, hazardous material mitigation, rescue, and emergency medical services within the City limits. Emergency medical service is provided to all City residents by the FFD, however emergency transport is provided by private carriers (e.g. private ambulance companies). When the GP was analyzed in 2014, the FFD did not meet target response times due to cuts in the number of units available to respond.

Buildout of the Planning Area may require additional FFD personnel and additional facilities to provide adequate fire protection services. New or physically altered fire facilities could result in adverse environmental impacts and implementation of the GP policies, mitigation measure PS-1.1, and Municipal Code regulation would ensure impacts would be less than significant.

Applicable GP Policies for the Project include:
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Policy PU‐2‐e. Service Standards: Strive to achieve a community wide risk management plan that includes the following service level objectives 90 percent of the time:
• First Unit on Scene – First fire unit arriving with minimum of three firefighters and ability to apply suppressing agent within 6 minutes and 20 seconds from emergency call (7 minutes and 30 seconds with 9‐11 processing time).
• Effective Response Force – Provide sufficient number of firefighters on scene of an emergency (17 for low risk, 23 for high risk) within nine minutes and 20 seconds from time to alert to arrival.

Policy PU-3-d: Review Development Applications. Continue Fire Department review of development applications, provide comments and recommend conditions of approval that will ensure adequate on‐site and off‐site fire protection systems and features are provided.

Policy PU-3-e: Building Codes. Adopt and enforce amendments to construction and fire codes, as determined appropriate, to systematically reduce the level of risk to life and property from fire, commensurate with the City’s fire suppression capabilities.

Policy PU-3-f: Adequate Infrastructure. Continue to pursue the provision of adequate water supplies, hydrants, and appropriate property access to allow for adequate fire suppression throughout the City.

Policy PU‐3‐g: Cost Recovery. Continue to evaluate appropriate codes, policies, and methods to generate fees or other sources of revenue to offset the ongoing personnel and maintenance costs of providing fire prevention and response services.

GP PEIR MITIGATION MEASURES
MM PS-1.1 As future fire facilities are planned, environmental review of proposed facilities shall be completed to meet the requirements of CEQA. Typical impacts from fire facilities include air quality/greenhouse gas emissions, noise, traffic, and lighting Schools
As discussed in the PEIR, the Planning Area of the GP includes various schools that provide primary, secondary, and post‐secondary education that would be impacted by the increase in student population anticipated due to the increase in residential development attributable to the GP. As stated in the PEIR, the projected increase in student population within the Planning Area would result in the need for substantial additional elementary, middle, and high schools to serve the future 65,518 students. As buildout of the GP Planning Area continues, construction of new schools or expansion of existing schools are planned accordingly to accommodate the new student populations. It was determined that significant adverse environmental impacts could occur from the construction and operation of the new schools or expansions. Furthermore, the PEIR stated that implementation of GP policy PF-1.8 (not applicable to the proposed Project) and the payment of mandatory school impact fees by 123
developers in the City, pursuant to Senate Bill 50, would reduce the impact on schools to less than significant.

Policy PF-1.8. The County and school districts should work closely to secure adequate funding for new school facilities. The County shall support the school districts’ efforts to obtain appropriate funding methods such as school impact fees.

GP PEIR MITIGATION MEASURES
None.

Parks and Recreational Facilities
According to the PEIR, buildout of the GP would result in a potential population increase of approximately 425,000 additional residents within the Planning Area, therefore increasing the demand for parks and recreational facilities. The PEIR determined, the proposed GP would not meet the City’s goal of 5 acres of parkland per 1,000 residents for all City park space and 3 acres per 1,000 residents for Pocket, Neighborhood, and Community Park Space. Although the GP buildout increased demand for parks and recreational facilities, implementation of the GP objectives and policies, and Municipal Codes 12-. would reduce impacts to less than significant. Furthermore, the GP parkland buildout would potentially have significant adverse environmental impacts from the construction and operation of the facilities.

Policy POSS‐2‐c. Review of Development Applications. Coordinate review of all development applications (i.e., site plans, conditional use permits, and subdivision maps) in order to implement the parks and open space standards of this Plan. • Assure the provision of adequate active and passive open spaces and facilities as appropriate within residential subdivisions through Development Code requirements for mandatory dedication and improvement of land and/or development fees. • Require the provision of appropriate outdoor living areas or private open space in multi‐ family residential developments not subject to the Subdivision Map Act. • Request open space easements where feasible and warranted to secure appropriate public use of sensitive areas with scenic or recreation values, and for buffering space for sensitive areas.
• Require provision of appropriate open space areas in private projects, in the form of trails, enhanced landscaped setbacks, parks, and water features. • Evaluate the merits of establishing a development bonus entitlement program in which development incentives (i.e., bonus densities, bonus floor area square footage) are provided for contributions to public recreational facilities on‐site or in the vicinity of the development project.
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GP PEIR MITIGATION MEASURES
MM PSR‐1.3 As future parks and recreational facilities are planned, environmental review of proposed facilities shall be completed to meet the requirements of CEQA.

Typical impacts from park facilities include air quality/greenhouse gas emissions, noise, traffic, and lighting.

Other Public Facilities
According to the PEIR, buildout of the GP Planning Area would increase the population, resulting in an increased demand for other public facilities such as court, libraries, and hospitals. It was determined the population increase (additional 425,000 people) had a substantial increase in the need for new and expanded courts, libraries, and hospitals to serve the future City residents. The PEIR stated there could be significant adverse environmental impacts from the construction and operation of these facilities. Implementation of Mitigation Measure MM PS-5 reduce impacts to less than significant.

MM PSR‐1.4 As future public facilities are planned by the City of Fresno (e.g., court, library, and hospital facilities), environmental review of the proposed facilities shall be completed to meet the requirements of CEQA. Typical impacts from public facilities include air quality/greenhouse gas emissions, noise, traffic, and lighting.

PROJECT-SPECIFIC IMPACTS
a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
i. Fire protection?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact with implementation of GP objectives, policies, and mitigation incorporated (MM PSR-1.1), regarding this topic. The nearest fire station is the FFD Station 5, located at 2571 S Cherry Ave, approximately one and a half mile to the north of the Project site and within the 5-minute response zone. As mentioned, the new industrial warehouse would introduce new employees from implementation of the proposed Project. As a result, the Project would have in an incremental increase in demand for fire protection and emergency medical services during construction and operation. The Project would have approximately 114 on-site employees. The increase in fire service demands from the Project would not require construction of a new or physically altered fire station that could cause environmental impacts. As discussed above in Section IX, the Project would be consistent with the City’s GP 125
goals and policies, including those related to fire hazard and safety. The Project is consistent with the land use and zoning goals for the site and would not result in a substantial or unplanned increase in fire protection service demand beyond that analyzed in the PEIR.

Therefore, the Project would no result in new impacts related to fire protection services.

Furthermore, ss stated in Section 4.15 of the PEIR, Development Impact Fees are collected for the provision of capital expenditures for future fire facilities subject to CEQA review at the time the facility comes to fruition.
ii. Police protection?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact with implementation of GP objectives, policies, and mitigation incorporated (MM PS-1.2), regarding this topic. The nearest police department is the Fresno Police Department, Southeast, located at 1617 S Cedar Avenue, approximately 3.9 miles to the northeast of the Project site.

As stated above, the new industrial warehouse would introduce 114 new employees from operation of the proposed Project, resulting in an incremental increase in demand for police protection. The Project would have the potential to increase capacity or population density in the area. However, the proposed Project land use and operation would be similar to surrounding development conditions as analyzed in the PEIR. Therefore, the Project would result in no new impacts related to police protection. In addition, Section 12-4.801 of the City’s Municipal Code institutes the collection of development impact fees for all development projects to help pay for future police facilities, subject to CEQA review at the time the facility comes to fruition.
iii. Schools?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact with implementation of GP objective and policies regarding this topic.

Although the Project does not include residential construction, the industrial Project does indirectly induce growth that would create additional students served by Orange Center Elementary School within the Orange Center School District, preschool through 8th grade, and Washington High School within the Washington Unified School District (WUSD), 9th through 12th grade. Therefore, the Project would result in no new impacts related to school services. iv. Parks?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact with implementation of GP objectives, policies, and mitigation incorporated (MM PS-1.3), regarding this topic. the Project would not create an additional need for housing; and would not directly increase the residential population of the City and generate additional need for parkland However, the Project would not require construction of new parks or expansion of existing parks that otherwise would result in an impact to the environment.

Therefore, the Project would result in no new impacts related to parks. 126
v. Other public facilities?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact with implementation of GP objectives, policies, and mitigation incorporated (MM PS-1.4), regarding this topic. As discussed above, the Project would result in growth in the area and would indirectly create additional demand for public services, including public health services and library services. However, this growth is minimal and would not require the construction of new or expanded public facilities that would otherwise create an impact to the environment. Therefore, the Project would result in no new impacts related to other public facilities.

CONCLUSION
With regards to the issue area of Public Services, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No mitigation measures contained within the GP PEIR would be required because Project specific impacts would be less than significant.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
None.
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ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
XVI. RECREATION – Would the project:
a) Increase the use of existing
neighborhood and regional
parks or other recreational
facilities such that substantial
physical deterioration of the
facility would occur or be
accelerated?
b) Does the project include
recreational facilities or
require the construction or
expansion of recreational
facilities which might have an
adverse physical effect on the
environment?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
The PEIR discussed recreational resource impacts in Section 4.15, Impact PSR-1.4. As presented in the PEIR, the City had 632 acres of developed park land as of that date. The PEIR concluded the current inventory of parks would not meet the City’s goal of 5 acres of parkland per 1,000 residents for all City park space, and 3 acres per 1,000 residents for Pocket, Neighborhood, and Community Park Space. Development facilitated by the GP would increase the City’s population with a commensurate increase in demand for parks and recreation facilities. Funding for park improvements and additions would be available through fees collected under the Quimby Act and other funds and would be expected to keep pace with population growth as it occurs under implementation of the GP. The following GP policies were included for the creation and maintenance of parks in the City. As such, the GP PEIR concluded that, with implementation of GP policies and collection of Quimby Act fees, impacts related to recreation would be less than significant.

PROJECT-SPECIFIC IMPACTS
a) Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
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No New Impact. This topic was not specifically evaluated in the PEIR. However, Section 4.15, Impact PS-1.4, of the GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. As discussed above, the Project would not create an additional need for housing; and would not directly increase the residential population of the City and generate additional need for parkland such that use of existing facilities would increase and physical deterioration would be accelerated. Therefore, the Project would result in no new impacts related to physical deterioration of park or recreational facilities. b) Include recreational facilities or require the construction or expansion of recreational facilities that might have an adverse physical effect on the environment?
No New Impact. This topic was not specifically evaluated in the PEIR. However, Section 4.15, Impact PS-1.4, of the GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. The Project does not propose the construction or expansion of recreational facilities. As discussed above, the Project would not create an additional need for housing and would not directly increase the residential population of the City that would result in the need for new or expanded recreational facilities the construction of which would result in an impact to the environment. Therefore, the Project would have no new impacts related to expansion of recreational facilities.

CONCLUSION
With regards to the issue area of Recreation, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No mitigation measures contained within the GP PEIR would be required because Project specific impacts would be less than significant.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP GOALS AND POLICIES
None.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
None.
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ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
XVII. TRANSPORTATION – Would the project:
a) Conflict with a program,
plan, ordinance or policy
addressing the circulation
system, including transit,
roadway, bicycle and
pedestrian facilities?
b) Conflict or be inconsistent
with CEQA Guidelines §
15064.3, subdivision (b)?
c) Substantially increase
hazards due to a geometric
design feature (e.g., sharp
curves or dangerous
intersections) or incompatible
uses (e.g., farm equipment)?
d) Result in inadequate
emergency access?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
The PEIR addressed transportation/traffic impacts in Section 4.16. Topics examined included roadway, transit, bicycle, pedestrian, rail, and aviation components of the transportation system in the City. The PEIR stated that the increase in population and employment generated as a result of development facilitated by the GP would increase vehicle trips and peak hour traffic volumes throughout and around the City. Thereby, impacting and/or conflicting with adopted policies, plans or programs regarding public transit, bicycle or pedestrian facilities. However, such impacts within the GP Planning Area were considered less than significant with implementation of the following transportation and traffic related objectives and policies. Cumulative impacts to areas outside of the City’s SOI (Fresno County, City of Clovis, and Caltrans) were considered significant due to the Project’s potential to conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system. Also, the added vehicle trips to roadways would result in operations below the adopted level of service thresholds in the City, unincorporated Fresno County, City of Clovis, and to Caltrans facilities. No mitigation measures beyond the proposed policies were considered feasible to reduce potential significant impacts. The PEIR 130
concluded that freeway facilities are controlled by Caltrans, and therefore the City cannot guarantee implementation of any capacity improvements to these segments.

The PEIR stated that implementation of the GP would not substantially increase hazards due to design features or incompatible uses due to the Projects processed under the GP would be required to meet all applicable local and state regulatory standards for adequate emergency access (including the Uniform Building Code, California Building Code, Uniform Fire Code, and applicable Municipal Code and Fire Code requirements). As stated in the PEIR, the following policies are related to the implementation of complete streets, the design of transportation facilities consistent with community character, and design of facilities to support economic development, including railroad, truck route design and safety. Therefore, impacts to design hazards and emergency access were determined to be less than significant.

GP GOALS AND POLICIES
The following GP goals and policies were included in the GP PEIR to reduce transportation/traffic impacts to a less than significant level:

Policy LU‐1‐a: Promote Development within the Existing City Limits as of December 31, 2012. Promote new development, infill, and rehabilitation of existing building stock in the Downtown Planning Area, along BRT corridors, in established neighborhoods generally south of Herndon Avenue, and on other infill sites and vacant land within the City.

Objective MT‐1. Create and maintain a transportation system that is safe, efficient, provides access in an equitable manner, and optimizes travel by all modes.

Policy MT‐1‐a: Transportation Planning Consistent with the General Plan. Continue to review local, regional and inter‐regional transportation plans and capital improvement plans, and advocate for the approval and funding of State highway and rail projects, consistent with the General Plan and discourage projects inconsistent with the General Plan.

Policy MT‐2‐l: Region‐wide Transportation Impact Fees. Continue to support the implementation of a metropolitan‐wide and region‐wide transportation impact fees sufficient to cover the proportional share of a development’s impacts to and need for a comprehensive multi‐modal transportation system that is not funded by other sources. Work with the Council of Fresno County Governments, transportation agencies (e.g., Caltrans, Federal Transportation Agency) and other jurisdictions in the region to develop a method for determining:
• Regional transportation impacts of new development.
• Regional highways, streets, trails, public transportation, goods movement system components, consistent with the General Plan, necessary to mitigate those impacts and serve projected demand.
• Projected full lifetime costs of the regional transportation system components, including construction, operations, and maintenance.
• Cost covered by established funding sources.
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Policy MT‐2‐i: Transportation Impact Studies. Require a Transportation Impact Study (currently named Traffic Impact Study) to assess the impacts of new development projects on existing and planned streets for projects meeting one or more of the following criteria, unless it is determined by the City Traffic Engineer that the project site and surrounding area already has appropriate multi‐modal infrastructure improvements. • When a project includes a General Plan amendment that changes the General Plan Land Use Designation.
• When the project will substantially change the off‐site transportation system (auto, transit, bike or pedestrian) or connection to the system, as determined by the City Traffic Engineer.
• Transportation impact criteria are tiered based on a project’s location with in the City’s Sphere of Influence. This is to assist with areas being incentivized for development.

The four zones, as defined on Figure MT‐4, are listed below. The following criteria apply, except for roadway segments identified in the traffic evaluation for the PEIR with LOS F for TIZ‐II or LOS E or F for TIZ‐III:
o Traffic Impact Zone I (TIZ‐I): TIZ‐I represents the Downtown Planning Area.

Maintain a peak hour LOS standard of F or better for all intersections and roadway segments. A TIS will be required for all development projected to generate 200 or more peak hour new vehicle trips.
o Traffic Impact Zone II (TIZ‐II): TIZ‐II generally represents areas of the City currently built up and wanting to encourage infill development. Maintain a peak hour LOS standard of E or better for all intersections and roadway segments. A TIS will be required for all development projected to generate 200 or more peak hour new vehicle trips.
o Traffic Impact Zone III (TIZ‐III): TIZ‐III generally represents areas near or outside the City Limits but within the SOI as of December 31, 2012. Maintain a peak hour LOS standard of D or better for all intersections and roadway segments. A TIS will be required for all development projected to generate 100 or more peak hour new vehicle trips.
o Traffic Impact Zone IV (TIZ‐IV): TIZ‐IV represents the southern employment areas within and planned by the City. Maintain a peak hour LOS standard of E or better for all intersections and roadway segments. A TIS will be required for all development projected to generate 200 or more peak hour new vehicle trips.

Policy MT‐2‐m: Use VMT analysis for CEQA. Use Vehicle Miles Traveled (VMT) as the criteria for evaluating transportation impacts under the California Environmental Quality Act (CEQA), pursuant to Senate Bill 743. Level of Service (LOS) may still be used for planning purposes and implementation of Capital Improvement Projects; however, VMT shall be used for determining mitigation under CEQA beginning in July of 2020.

Commentary: In 2013, the State of California passed Senate Bill 743, which eliminated automobile Level of Service (LOS) from transportation analysis under CEQA and replaced it with VMT. This shift from LOS to VMT is intended to better align with other statewide 132
transportation goals, including reduction of GHG emissions, the creation of multimodal networks, and the promotion of integrated land uses.

Objective MT‐5. Establish a well‐integrated network of pedestrian facilities to accommodate safe, convenient, practical, and inviting travel by walking, including for those with physical mobility and vision impairments.

GP PEIR MITIGATION MEASURES
None.

PROJECT-SPECIFIC IMPACTS
a) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? No New Impact. The GP PEIR determined the GP Update would result in a significant and unavoidable impact for only areas outside of the City unincorporated Fresno County, City of Clovis, and to Caltrans facilities. No feasible mitigation measures beyond implementation of GP Policy MT‐2‐j and MT‐2‐I. The PEIR determined that impacts within the GP Planning Area were less than significant with implementation of the objectives and policies of the GP.

Vehicular access to the Project site is provided from E. North Avenue and S. East Avenue.

Along E. North Avenue, vehicular access is provided by a 40-foot-wide driveway near the northwest portion Project site. In addition, a 36-foot-wide driveway is at the northern portion of the Project site. Along S. East Avenue at the southeast portion of the Project site is a 35- foot-wide driveway. Onsite circulation includes a 34-foot-wide (minimum) drive aisle that goes around the building (to the south), connecting to both proposed driveways (northwest and southeast driveways). This drive aisle would provide vehicular access to the parking areas and loading docks in the rear of the building and would serve as the onsite fire lane where parking would be prohibited. Accessible pedestrian paths of travel to the building entrances are provided around the structure with gated access to rear. Pedestrian access from S. East Avenue is provided by pathway at east northeast parking area. Pedestrian and vehicular traffic to and from the Project site would utilize the existing network of regional and local roadways that currently serve the Project site and that were analyzed under the PEIR. In addition, final design plans would be subject to review and approval by the City’s Public Works Department prior to the issuance of building permits. As such, the proposed Project would not introduce any new roadways or land uses that would interfere with adopted plans, programs, ordinances, or policies regarding roadway facilities.

The Project’s Trip Generation and Traffic Impact Study Screening Analysis, notes (Appendix H), a project would generally be required to prepare a Traffic Impact Analysis (TIA) if a project is expected to generate more than 100 vehicle trips during any peak hour, or if the project includes a General Plan Amendment. Project trip generation was evaluated using trip rates 133
from the Institute of Transportation Engineers (ITE) and estimates of employees, route deliveries and 3rd party deliveries provided by the Project applicant. As shown in Table 17, the Project would generate 59 AM and 84 PM peak hour PCE trips using the data supplied by the Project applicant. The Project would generate fewer than 100 peak hour trips. Therefore, a TIA is not be required for the Project per the City’s guidelines.

The Project would be consistent with the objectives and policies from the GP. Therefore, the Project would result in no new impacts as impacts are less than significant and mitigation is not required.
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Table 17: Project Trip Generation
AM Peak Hour PM Peak Hour
Land Use Daily In Out Total In Out Total
Trip Generation Based on ITE Trip Rates
Trip Rates
Warehouse (Automobile Trips)1Per TSF 1.65 0.12 0.03 0.15 0.03 0.12 0.15 Warehouse (Truck Trips)1 Per TSF 0.06 0.01 0.01 0.02 0.02 0.01 0.03

1.71 0.13 0.04 0.17 0.05 0.13 0.18
Project Trip Generation (Total Trips)
Automobile Trip Generation 245.564 TSF 405 30 7 37 9 28 37 Truck Trip Generation 245.564 TSF 15 3 2 5 4 4 7
Total Project Trip Generation 420 32 10 42 12 32 44
Project Trip Generation (PCE Trips) 2
Automobile Trip Generation 245.564 TSF 405 30 7 37 9 28 37 Truck Trip Generation 245.564 TSF 37 6 6 12 10 9 18
Total PCE Project Trip Generation 442 36 13 49 18 37 55 Trip Generation Based on Operational Data 3
Project Trip Generation (Total Trips)
Passenger Car Trips
Delivery Drivers (60 Drivers)4 120 0 0 0 0 0 0
On-Site Employees (70 Employees)5
158 0 0 0 25 0 25
Part-Time (2 Days/Week) On-Site Employees (15 Employees)6 14 14 0 14 0 14 14 Remote Workers On-Site Weekly (55 Employees)7
25 25 0 25 0 25 25
Remote Workers On-Site Monthly (50 Employees)8 6 6 0 6 0 6 6 Total Passenger Car Trips 321 44 0 44 25 44 69
Truck Trips
RCCB Fresno Daily Routes (50/day)
9 100 - - - - - -
3rd Party Deliveries9 60 3 3 6 3 3 6
Total 160 3 3 6 3 3 6
Total Project Trip Generation 481 47 3 50 28 47 75
Total PCE Generation2 721 51 8 59 33 51 84
TSF = Thousand Square Feet
1Trip rates from the Institute of Transportation Engineers, Trip Generation,11th Edition, 2021. Land Use Code 150 - Warehousing. 2A Passenger Car Equivalent (PCE) Factor of 2.5 is used for all truck trips. 3 Estimates of employees, routes and 3rd party deliveries provided by Reyes Holdings LLC. 4 Delivery drivers would work 5 days per week. There would be 2 shifts per day from 4:00 AM - 2:00 PM and from 5:00 AM - 3:00 PM. Delivery drivers would not arrive or depart during the peak hours.
5 Daily employee trips assume all employees drive alone and that up to 25 percent of employees will leave work during the day for lunch or other personal reasons. A rate of 2.25 trips per employee is used for all employees in the office on a given day. All employee shifts would start and end outside of peak commute periods except for 25 employees who would work from 5:00 PM - 1:30 AM 5 days per week. 6 A rate of 0.9 trips per employee per day is used for part time (2 days/week) employees. This is calculated assuming 2.25 trips per employee each day the employee is on-site and was calculated as follows: 2.25 trips/employee x 2 days per week/5 day week. 7 A rate of 0.45 trips per employee per day is used for employees who are on site 1 day per week. This is calculated assuming 2.25 trips per employee each day the employee is on-site and was calculated as follows: 2.25 trips/employee x 1 days per week/5 day week. 8 A rate of 0.1125 trips per employee per day is used for employees who are on site 1 day per month. This is calculated assuming 2.25 trips per employee each day the employee is on-site and was calculated as follows: 2.25 trips/employee x 1 days per month/20 day month. 9 Delivery route trips and 3rd party deliveries are calculated using 2 trips per day (one inbound, one outbound). Delivery route trucks would depart between 4:00 a.m. and 6:00 a.m. and would return between noon and 4:00 p.m., therefore all delivery route trips are outside of the peak hour. 3rd party deliveries are distributed equally throughout the day from 8:00 a.m. to 5:00 p.m. resulting in 11% of delivery trips during each peak hour. 135
b) Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
No New Impact. On June 25, 2020, the City of Fresno adopted CEQA Guidelines for Vehicle Miles Traveled (VMT) Thresholds. Consistent with Senate Bill 743, VMT thresholds apply to which refers to the analysis of the transportation of on-road cars and light-duty trucks. and do not apply to heavy-duty trucks which are subject to separate collection of rules under CRB jurisdiction and are addressed in previous sections of this document (i.e. air quality, greenhouse gas, and noise). The thresholds are referred to as the City of Fresno VMT Thresholds. The City of Fresno VMT Thresholds adopted a screening standard and criteria that can be used to screen out qualified projects that meet the adopted criteria from needing to prepare a detailed VMT analysis. For development projects, conditions may exist that would presume that a development project has a less than significant impact. These may be size, location, proximity to transit, or trip‐making potential. For transportation projects, the primary attribute to consider with transportation projects is the potential to increase vehicle travel, sometimes referred to as “induced travel.”
The proposed Project is screened out from requiring a VMT study because the Project would generate fewer than 500 daily trips. According to the City’s Screening Criteria 4 – Daily Trip Generation - projects generating less than 500 daily vehicle trips would not be required to complete a VMT assessment. Based on ITE trip rates, the Project would generate 420 daily trips, or when evaluated using operations data, the Project would generate 481 daily trips. Using either method, the Project would generate fewer than 500 daily trips. Therefore, the Project would meet Screening Criteria 4 – Daily Trip Generation and therefore, the project is presumed to have a less than significant impact on VMT and would require no further analysis.

In conclusion, the Project would result in a less than significant VMT impact and is consistent with CEQA Guidelines Section 15064.3(b).
c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. This topic was determined to have a less than significant impact as a result of the new and upgraded roadways would be designed according to applicable federal, state, and local design standards. It was determined implementation of the GP would increase the amount of vehicle traffic, and require improvement and expansion of the City’s transportation system. However, the objectives and policies outlined above from the GP support development of the transportation system based on complete street concepts that accommodate mobility of all system users and trip purposes as stated in the GP PEIR.

During construction, it is assumed construction activities would not result in roadway closures, or other activities that could create dangerous intersections or incompatible uses. During 136
short-term construction activities, the proposed Project is not anticipated to result in any substantial traffic queuing on nearby streets, and all construction equipment would be staged within the Project site.

As stated above, the Project proposes development of an industrial warehouse building that includes vehicular access to the Project site provided from E. North Avenue and S. East Avenue. Along E. North Avenue, vehicular access is provided by a 40-foot-wide driveway near the northwest portion Project site. In addition, a 36-foot-wide driveway is at the northern portion of the Project site. Along S. East Avenue at the southeast portion of the Project site is a 35-foot-wide driveway. In addition, the Project site would include a parking area to the north and east of the building, a parking area to the south of the building near the loading docks which includes truck trailer parking stalls. Access to loading ramps and docks would be provided via the half-loop drive aisle accessed from the proposed driveways. Construction of the proposed driveways would also include the installation of a new curb and gutters, and sidewalks to match the existing along Project’s frontage within the right-of-way on E North Avenue and S East Avenue. As anticipated by the GP PEIR, the Project is required to be designed according to applicable federal, state, and local design standards. Furthermore, final design plans would be subject to review and approval by the City’s Public Works Department prior to the issuance of building permits. As such, the proposed Project would not introduce any new roadways or land uses that would interfere with adopted plans, programs, ordinances, or policies regarding roadway facilities.

Project improvements would be consistent with development standards for streets, sidewalks, and other public places as specified in Chapter 15 of the City Code. The City Department of Public Works would ensure plans are consistent with design standards as part of building permitting. Therefore, the Project would result in no new impacts related to hazards due to a design feature.
d) Result in inadequate emergency access?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. The GP PEIR included objectives and policies that would support the GP implementation to provide adequate emergency access. Therefore, it was determined implementation of the GP would result in a less‐than‐significant impact related to emergency access.

As discussed in Section 5.9, the Project would not result in roadway closure, or other activities that could impact emergency response or evacuation. During short-term construction activities, the proposed Project is not anticipated to result in any substantial traffic queuing on nearby streets, and all construction equipment would be staged within the Project site.

As previously stated, the Project proposes the construction of driveways for vehicular access to the Project site from both E. North Avenue and S. East Avenue. Along E. North Avenue, vehicular access is provided by a 40-foot-wide driveway near the northwest portion Project site. In addition, a 36-foot-wide driveway is at the northern portion of the Project site. Along S. 137
East Avenue at the southeast portion of the Project site is a 35-foot-wide driveway. During the operational phase of the proposed Project, onsite access would be required to comply with standards established by the City within the FMC. The proposed Project would provide adequate emergency access to the site via E. North Avenue and S. East Avenue.

Onsite circulation includes a 34-foot-wide (minimum) drive aisle that goes around the building (to the south), of which connects both proposed driveways (northwest and southeast driveways). This drive aisle would provide vehicular access to the parking areas and loading docks in the rear of the building and would serve as the onsite fire lane where parking would be prohibited. Access to the loading dock area would be restricted via swinging tube steel gates. The northern driveway provides access to both driveways along with access to parking and building entrance at the northeast corner of the building. Accessible pedestrian paths of travel to the building entrances are provided around the structure with gated access to rear.

Pedestrian access from S. East Avenue is provided by pathway at east northeast parking area. All gated access would have emergency access override system as provided by the Project applicant which would be require City and FFD review and approval. Therefore, the Project would result in no new impacts to emergency access.

CONCLUSION
With regards to the issue area of Transportation and Traffic, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No mitigation measures contained within the GP PEIR would be required because Project specific impacts would be less than significant.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP GOALS AND POLICIES
Policy MT‐2‐l: Region‐wide Transportation Impact Fees. Continue to support the implementation of a metropolitan‐wide and region‐wide transportation impact fees sufficient to cover the proportional share of a development’s impacts to and need for a comprehensive multi‐modal transportation system that is not funded by other sources. Work with the Council of Fresno County Governments, transportation agencies (e.g., Caltrans, Federal Transportation Agency) and other jurisdictions in the region to develop a method for determining:
• Regional transportation impacts of new development.
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• Regional highways, streets, trails, public transportation, goods movement system components, consistent with the General Plan, necessary to mitigate those impacts and serve projected demand.
• Projected full lifetime costs of the regional transportation system components, including construction, operations, and maintenance.
• Cost covered by established funding sources.

Policy MT‐2‐i: Transportation Impact Studies. Require a Transportation Impact Study (currently named Traffic Impact Study) to assess the impacts of new development projects on existing and planned streets for projects meeting one or more of the following criteria, unless it is determined by the City Traffic Engineer that the project site and surrounding area already has appropriate multi‐modal infrastructure improvements. • When a project includes a General Plan amendment that changes the General Plan Land Use Designation.
• When the project will substantially change the off‐site transportation system (auto, transit, bike or pedestrian) or connection to the system, as determined by the City Traffic Engineer.
• Transportation impact criteria are tiered based on a project’s location within the City’s Sphere of Influence. This is to assist with areas being incentivized for development.

The four zones, as defined on Figure MT‐4, are listed below. The following criteria apply, except for roadway segments identified in the traffic evaluation for the PEIR with LOS F for TIZ‐II or LOS E or F for TIZ‐III:
o Traffic Impact Zone I (TIZ‐I): TIZ‐I represents the Downtown Planning Area.

Maintain a peak hour LOS standard of F or better for all intersections and roadway segments. A TIS will be required for all development projected to generate 200 or more peak hour new vehicle trips.
o Traffic Impact Zone II (TIZ‐II): TIZ‐II generally represents areas of the City currently built up and wanting to encourage infill development. Maintain a peak hour LOS standard of E or better for all intersections and roadway segments. A TIS will be required for all development projected to generate 200 or more peak hour new vehicle trips.
o Traffic Impact Zone III (TIZ‐III): TIZ‐III generally represents areas near or outside the City Limits but within the SOI as of December 31, 2012. Maintain a peak hour LOS standard of D or better for all intersections and roadway segments. A TIS will be required for all development projected to generate 100 or more peak hour new vehicle trips.
o Traffic Impact Zone IV (TIZ‐IV): TIZ‐IV represents the southern employment areas within and planned by the City. Maintain a peak hour LOS standard of E or better for all intersections and roadway segments. A TIS will be required for all development projected to generate 200 or more peak hour new vehicle trips.

Objective MT‐1. Create and maintain a transportation system that is safe, efficient, provides access in an equitable manner, and optimizes travel by all modes. 139
Policy MT‐2‐m: Use VMT analysis for CEQA. Use Vehicle Miles Traveled (VMT) as the criteria for evaluating transportation impacts under the California Environmental Quality Act (CEQA), pursuant to Senate Bill 743. Level of Service (LOS) may still be used for planning purposes and implementation of Capital Improvement Projects; however, VMT shall be used for determining mitigation under CEQA beginning in July of 2020.

Commentary: In 2013, the State of California passed Senate Bill 743, which eliminated automobile Level of Service (LOS) from transportation analysis under CEQA and replaced it with VMT. This shift from LOS to VMT is intended to better align with other statewide transportation goals, including reduction of GHG emissions, the creation of multimodal networks, and the promotion of integrated land uses.

Objective MT‐5. Establish a well‐integrated network of pedestrian facilities to accommodate safe, convenient, practical, and inviting travel by walking, including for those with physical mobility and vision impairments.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
None.
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ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
XVII. TRIBAL CULTURAL RESOURCES – Would the project:
a) Cause a substantial
adverse change in the
significance of a tribal cultural
resource, 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:
i) 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,
ii) 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.

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
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The GP PEIR discussed cultural resource impacts, including potential impacts to tribal resources, in Section 4.5. The City has a long cultural history and is within the ancestral territory of multiple tribes. Therefore, the presence of subsurface archaeological, paleontological, and human remains, which could also be tribal cultural resources, may be present, and subject to direct or indirect effects of ground‐disturbance activities associated construction from buildout of the GP. The GP PEIR concluded that impacts to archaeological and paleontological resources or human remains would have a less than significant impact with implementation of Mitigation Measure MM CUL‐3, Objectives G-11 and HCR-1, and Policy HCR-1-c.

Pursuant to the requirements of SB 18, the City notified eleven Native American tribes of the proposed GPU and accompanying plans. No requests for consultation were received (Appendix D-2 of the GPU PEIR). The GPU PEIR included multiple GP policies that ensure impacts to tribal cultural resources from future development would be less than significant.

GP GOALS AND POLICIES
Objective HCR‐1. Maintain a comprehensive, citywide preservation program to identify, protect and assist in the preservation of Fresno’s historic and cultural resources.

Policy HCR‐1‐c. Historic Preservation Ordinance. Maintain the provisions of the City’s Historic Preservation Ordinance, as may be amended, and enforce the provisions as appropriate.

Policy HCR-2-d: Native American Sites. Work with local Native American tribes to protect recorded and unrecorded cultural and sacred sites, as required by State law, and educate developers and the community-at-large about the connections between Native American history and the environmental features that characterize the local landscape.

Native American outreach procedures were completed by the City for the GP Planning Area.

The GP PEIR concludes that implementation of the GP policies would ensure impacts to archaeological and Native American cultural resources would be less than significant.

Therefore, the PEIR concluded the GP would have a less than significant impact on scenic vistas and scenic resources.

GP PEIR MITIGATION MEASURES
None.

PROJECT-SPECIFIC IMPACTS
a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size 142
and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact with mitigation incorporated (MM CUL-3), regarding this topic.

A Sacred Lands File (SLF) search from the Native American Heritage Commission (NAHC) was conducted on January 13, 2022, by Brian F. Smith & Associates (BFSA). However, no response from the NAHC has been received. Furthermore, as previously detailed in Section 5, Cultural Resources, the Project site does not meet any of the historic resource criteria and does not meet the definition of an historical resource pursuant to CEQA. Therefore, the Project would not result in impacts to historic resources that are listed or eligible for listing. As such, the Project would not result in new impacts related to historic resources that are listed or eligible for listing and have cultural value to a California Native American tribe. As a result, impacts are considered to be less than significant, requiring no mitigation ii. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

No New Impact. Impacts to cultural resources, including tribal cultural resources, were determined to be less than significant with mitigation incorporated (MM CUL-3). As previously stated, no tribal cultural resources are known to occur on the Project site or nearby. The Project is required to be consistent with G‐11. Objective, Objective HCR‐1, Policy HCR‐1‐c, Policy HCR-2-d, which require the preservation of the City’s historic and cultural resources, and to protect Native American history.

Assembly Bill (AB) 52 (Chapter 532, Statutes of 2014) establishes a formal consultation process for California tribes as part of the CEQA process and equates significant impacts on “tribal cultural resources” with significant environmental impacts (Public Resources Code [PRC] § 21084.2). AB 52 requires that lead agencies undertaking CEQA review evaluate, just as they do for other historical and archeological resources, a project’s potential impact to a tribal cultural resource. In addition, AB 52 requires that lead agencies, upon request of a California Native American tribe, begin consultation prior to the release of a negative declaration, mitigated negative declaration, or EIR for a project. AB 52 does not apply to a Addendum or Notice of Exemption, such as 15183 exemption checklist. 143
Nevertheless, should human remains be unearthed during grading and excavation activities associated with Project development, and as included in MM CUL-3, the construction contractor would be required by California law to comply with California Health and Safety Code Section 7050.5 and Public Resources Code Section 5097.98. According to Section 7050.5(b) and (c), if human remains are discovered, the County Coroner must be contacted and if the Coroner recognizes the human remains to be those of a Native American or has reason to believe that they are those of a Native American, the Coroner is required to contact the NAHC by telephone within 24 hours. Pursuant to California Public Resources Code Section 5097.98, whenever the NAHC receives notification of a discovery of Native American human remains from a county coroner, the NAHC is required to immediately notify those persons it believes to be most likely descended from the deceased Native American. The descendants may, with the permission of the owner of the land, or his or her authorized representative, inspect the site of discovery of the Native American human remains and may recommend to the owner or the person responsible for the excavation work means for treatment or disposition, with appropriate dignity, of the human remains and any associated grave goods. The descendants shall complete their inspection and make recommendations or preferences for treatment within 48 hours of being granted access to the site. According to Public Resources Code Section 5097.98(k), the NAHC is authorized to mediate disputes arising between landowners and known descendants relating to the treatment and disposition of Native American human burials, skeletal remains, and items associated with Native American burials.

Through mandatory compliance with California Health and Safety Code Section 7050.5 and Public Resources Code Section 5097.98, the Project would not result in significant impacts to human remains, and impacts would be less than significant. Therefore, the Project would result in no new impact related to disturbance of human remains. Therefore, the Project would not affect known tribal cultural resources, resulting in a less than significant impact with mitigation incorporated.

CONCLUSION
With regards to the issue area of Tribal Cultural Resources, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. Feasible mitigation measures contained within the GP PEIR (CUL-3) would be applied to the project. The mitigation measure, as detailed below, would require Native American consultation.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.
144

GP GOALS AND POLICIES
Objective G‐11. Safeguard Fresno’s heritage by preserving resources which reflect important cultural, social, economic, and architectural features so that community residents will have a foundation upon which to measure and direct physical change.

Objective HCR‐1. Maintain a comprehensive, citywide preservation program to identify, protect and assist in the preservation of Fresno’s historic and cultural resources.

Policy HCR‐1‐c. Historic Preservation Ordinance. Maintain the provisions of the City’s Historic Preservation Ordinance, as may be amended, and enforce the provisions as appropriate.

Policy HCR-2-d: Native American Sites. Work with local Native American tribes to protect recorded and unrecorded cultural and sacred sites, as required by State law, and educate developers and the community-at-large about the connections between Native American history and the environmental features that characterize the local landscape.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
MM CUL‐3 See Section V, Cultural Resources above.
145

ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
XIX. UTILITIES AND SERVICE SYSTEMS – Would the project:
a) Require or result in the
relocation or construction of
new or expanded water,
wastewater treatment or
storm water drainage, electric
power, natural gas, or
telecommunications facilities,
the construction or relocation
of which could cause
significant environmental
effect?
b) Have sufficient water
supplies available to serve
the project and reasonably
foreseeable future
development during normal,
dry and multiple dry years?
c) Result in a determination
by the waste water 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?
d) Generate solid waste in
excess of state or local
standards, or in excess of the
capacity of local
infrastructure, or otherwise
impair the attainment of solid
waste reduction goals?
146

ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
e) Comply with federal, state,
and local management and
reduction statutes and
regulations related to solid
waste?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
The GP PEIR discussed impacts on utilities and service systems in Section 4.17. The analysis addressed stormwater drainage, water supply, wastewater, and solid waste.

Water Supply
As discussed in the GP PEIR, the City’s Public Works Department provides water service for Fresno, and the projected water demand for the City at full buildout of the GP, based on a population of 970,000 by the year 2056, is 271,594 AF/year. It was concluded that implementation of the GP would not have sufficient water supplies to serve full buildout, therefore the GP PEIR determined implementation of GP policies and mitigation would be required to reduce impacts.

GP GOALS AND POLICIES
Objective E‐22. Manage and develop the City’s water facilities on a strategic timeline basis that recognizes the long life cycle of the assets and the duration of the resources, to ensure a safe, economical, and reliable water supply for existing customers and planned urban development and economic diversification.

Policy PU‐8‐c: Conditions of Approval. Set appropriate conditions of approval for each new development proposal to ensure that the necessary potable water production and supply facilities and water resources are in place prior to occupancy.

GP PEIR MITIGATION MEASURES
MM UTL-1.1.1 The City shall evaluate the water conveyance system and, at the time that discretionary projects are submitted for approval by the City, the City shall not approve development that would demand additional water and exceed the capacity of a facility until additional capacity is provided. The following 147
capacity improvements shall be evaluated for potential environmental impacts and constructed by the City by approximately 2025. • Construct 65 new groundwater wells, in accordance with Chapter 9 and Figure 9-1 of the 2014 Metro Plan Update. • Construct a 2.0 million gallon potable water reservoir (Reservoir T2) near the intersection of Clovis and California Avenues, in accordance with Chapter 9 and Figure 9-1 of the 2014 Metro Plan Update.
• Construct a 4.0 million gallon potable water reservoir (Reservoir T5) near the intersection of Ashlan and Chestnut Avenues, in accordance with Chapter 9 and Figure 9-1 of the 2014 Metro Plan Update. • Construct a 4.0 million gallon potable water reservoir (Reservoir T6) near the intersection of Ashlan Avenue and Highway 99, in accordance with Chapter 9 and Figure 9-1 of the 2014 Metro Plan Update.
• Construct 50.3 miles of regional water transmission mains ranging in size from 24- inch to 48-inch, in accordance with Chapter 9 and Figure 9-1 of the 2014 Metro Plan Update.

MM UTL‐1.2.1 The City shall evaluate the water supply system at the time discretionary projects are submitted and shall not approve development that would demand additional water until additional capacity is provided. By approximately the year 2025, the following capacity improvements shall be evaluated for potential environmental impacts and constructed by the City. • Construct an approximately 30 mgd expansion of the existing northeast surface water treatment facility for a total capacity of 60 mgd, in accordance with Chapter 9 and Figure 9-1 of the 2014 Metro Plan Update. • Construct an approximately 20 mgd surface water treatment facility in the southwest portion of the City, in accordance with Chapter 9 and Figure 9-1 of the 2014 Metro Plan Update.
• Construct a 25,000 AF/year recycled water facility as an expansion to the RWRF in accordance with the January 2014 City of Fresno Metropolitan Water Resources Management Plan. This improvement is required after the year 2025.

Wastewater
As discussed in the GP PEIR, the land use changes between the 2025 Fresno General Plan to the City of Fresno GP were projected to increase dry weather base flows to the treatment plants by an additional 33.6 million gallons per day (MGD). Wastewater treatment requirements and waste discharge requirements when analyzed, would be further exceeded, and potential significant impacts would occur. The GP PEIR concluded, to reduce the potential impacts associated with the wastewater discharge permits, the City needed to increase wastewater treatment capacity and obtain revised and new waste discharge permits. 148
Implementation of the policies and mitigation measures in the GP PEIR, rendered impacts to less than significant associated with wastewater treatment requirements and waste discharge requirements.

GP GOALS AND POLICIES
Objective PU-6. Ensure the provision of adequate sewage treatment and disposal by utilizing the Fresno‐Clovis Regional Wastewater Reclamation Facility as the primary facility, when economically feasible, for all existing and new development within the Metropolitan Area.

Policy PU‐6‐a: Treatment Capacity and Cost Recovery. Prepare for and consider the implementation of increased wastewater treatment and reclamation facility capacity in a timely manner to facilitate planned urban development within the Metropolitan Area consistent with this General Plan. Accommodate increase in flows and loadings from the existing community with the capital costs and benefits allocated equitably and fairly between existing users and new users, as authorized by law.

GP PEIR MITIGATION MEASURES
MM UTL‐1.3.1 The City shall evaluate the wastewater system at the time discretionary projects are submitted and shall not approve development that contributes wastewater to the wastewater treatment facility that could exceed capacity until additional capacity is provided. By approximately the year 2025, the City shall evaluate the potential environmental impacts and construct the following improvements.
• Construct an approximately 70 mgd expansion of the Regional Wastewater Treatment Facility prior to flows reaching 80 percent of rated capacity, and obtain revised waste discharge permits as the generation of wastewater is increased. • Construct an approximately 0.49 mgd expansion of the North Facility and obtain revised waste discharge permits as the generation of wastewater is increased. Mitigation Measure UTL‐1.3.2 The City shall evaluate the wastewater system at the time discretionary projects are submitted and shall not approve development that contributes wastewater to the wastewater treatment facility that could exceed capacity until additional capacity is provided. After approximately the year 2025, the City shall evaluate the potential environmental impacts of, and construct the following improvements.
• Construct an approximately 24 mgd Wastewater Treatment Facility within the Southeast Development Area and obtain revised waste discharge permits as the generation of wastewater is increased.
• Construct an approximately 9.6 mgd expansion of the Regional Wastewater Treatment Facility and obtain revised waste discharge permits as the generation of wastewater is increased.
149
Stormwater Runoff
As discussed in the GP PEIR, the stormwater collection and disposal, and flood control for the City of Fresno are provided by the Fresno Metropolitan Flood Control District (FMFCD).

The District has more than 170 urban watersheds that collect stormwater runoff and dispose of the runoff in retention basins, local canals, or the San Joaquin River. Implementation of the GP was determined to result in a significant impact on existing storm water drainage facilities due to the need for new and expanded facilities needed to support the increase in impervious surfaces. The GP PEIR further concluded that potential significant effects could occur with the construction and operation of the future storm water drainage facilities.

GP GOALS AND POLICIES
Policy N-3-b: Curb and Gutter Installation. Coordinate with Fresno Metropolitan Flood Control District (FMFCD) to install curbing, gutters, and other drainage facilities with priority to existing neighborhoods with the greatest deficiencies and consistent with the Storm Drainage and Flood Control Master Plan.

Policy NS-3-e: Pollutants. Work with FMFCD to prevent and reduce the existence of urban stormwater pollutants pursuant to the requirements of the National Pollution Discharge Elimination Systems Act.

GP PEIR MITIGATION MEASURES
MM UTL-1.4.1 Consistent with the Sewer System Management Plan, the City shall evaluate the wastewater collection system at the time discretionary projects are submitted, and shall not approve development that would generate additional wastewater and exceed the capacity of a facility until additional capacity is provided.

Solid Waste and Recycling
As discussed in the GP PEIR in Section 4.17, the City has two exclusive franchise haulers collecting and hauling commercial and multi-family solid waste and recycling material within the City of Fresno. Allied Services is responsible for servicing the northern portion of the City, and Mid Valley Disposal is responsible for servicing the southern portion of the City. Waste collected by the franchise haulers is conveyed to the two landfills that serve the City; American Avenue Landfill and Clovis Landfill.

It was determined that the increase in growth and development as a result of the build-out of the GP could result in an increase of solid waste to transfer centers, landfills, and could contribute to an increased demand for solid waste services throughout the Planning Area.

Implementation of the GP would generate approximately 973 tons of solid waste per day, and although the landfills were determined to be adequate to serve the City, implementation of mitigation (MM UTL-4.1) was required to monitor landfill capacity and closure impacts. The 150
GP PEIR concludes that impacts on waste management and recycling would be less than significant with mitigation incorporated.

GP GOALS AND POLICIES
Objective PU-9. Provide adequate solid waste facilities and services for the collection, transfer, recycling, and disposal of refuse.

Policy PU‐9‐b: Compliance with State Law. Continue to pursue programs to maintain conformance with the Solid Waste Management Act of 1989 or as otherwise required by law and mandated diversion goals.

GP PEIR MITIGATION MEASURES
MM UTL‐4.1 The City shall evaluate additional landfill locations at the time discretionary projects are submitted, and shall not approve development that could contribute solid waste to a landfill that is at capacity until additional capacity is provided.

PROJECT-SPECIFIC IMPACTS
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
No New Impact. This topic was evaluated in the GP PEIR (Section 4.17, Impact UTL-1.1 through 1.5) and was determined to be less than significant with mitigation incorporated (MM UTL-1.1.1 through -1.5.1). The Project proposes to clear the vacant site to construct a new 205,000 sf (approximate building footprint) concrete tilt-up industrial building, ancillary structures, landscaping, and pavement. The Project site is within Fresno City limits, therefore would be required to connect to City water, stormwater, solid waste, and wastewater services.

Natural gas, electricity, solid waste and recycling, and telecommunications are to be provided by private companies. In compliance with MM ULT- 1.1.1 and 1.3.1, the City and responsible agencies have reviewed the Project to determine adequate capacity in these systems and ensure compliance with applicable connection requirements. Requirements for the Project are as follows:
• Water Service: Install water service and meter boxes and pay Water Capacity Fee for installation at northeast portion of site along S East Avenue. • Wastewater: Install a sewer house branch to connect to nearby 12-inch sewer main located in S East Avenue western portion of the site and pay Sewer Connection Charges.
151
• Stormwater Drainage: Construct private facilities to discharge storm water runoff, including making 2 connections to existing facilities in E North Avenue and upgrading the northeastern 18-inch storm drain to 30-inch.
• Solid Waste & Recycling: Install one, 2-cell trash enclosures at southeast portion of site with a service frequency of 3 times a week to collect the estimated solid waste to be generated by the Project: 72 cubic yards of trash and 72 cubic yards of recycle (applicant provided information).

Although the storm drain connection to be made at the eastern portion of the site along E North Avenue requires off-site work for removal an 18-inch storm drain and replacement of a 30-inch storm drain, appropriate traffic control measures and permits would be required per to be performed in accordance with City oversite and direction.

In addition to connections to water, stormwater, solid waste, and wastewater services, the Project would be served by PG&E (Pacific Gas & Electric) for natural gas and electricity, Mid Valley Disposal for solid waste and recycling, and by the telecommunications provider AT&T for the Project area. Through compliance with the applicable connection requirements, impacts are reduced to less than significant as a result of the Project. Therefore, the Project would result in no new impacts related to construction of new or expanded utilities that could result in significant environmental effects.
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? No New Impact. This topic was evaluated in the GP PEIR (Impact 4.17, Impact UTL-2) and was determined to be less than significant. According to the UWMP, the City anticipates the service population to increase 1.4 percent annually from 2020 to 2056, a total of approximately 425,000 new residents by 2056. With this anticipated growth, the UWMP projects that the City will have adequate water supply, with normal conservation efforts, to meet demand through 2056 in average year, single dry year, and multiple dry year scenarios. The Project would be consistent with the land use and zoning designations analyzed under the GP PEIR. In satisfaction of MM UTL-1.3.1, the Project would not be capacity increasing or facilitate growth, which could increase demand for water supplies. Additionally, the Project would comply with GP policies Policy PF‐C.12 and Policy PF‐C.3, which includes measures to minimize water usage. Therefore, the Project would result in no new impacts related to water supplies. c) 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? No New Impact. This topic was evaluated in the GP PEIR (Impact 4.17, Impact UTL-3) and was determined to be less than significant with mitigation incorporated (MM UTL-1.3.1 and -

1.4.1), however impacts to agricultural resources and air quality were significant and avoidable. The City’s Department of Public Utilities has determined that adequate sanitary sewer and water services would be available to serve the proposed Project subject to the 152
payment of any applicable connection charges and/or fees and extension of services in a manner that is compliant with the Department of Public Utilities standards, specifications, and policies. In addition, the proposed Project is not expected to exceed wastewater treatment requirements of the Central Valley Regional Water Quality Control Board. As such, impacts would be less than significant. Furthermore, wastewater generated from the Project site would be treated by the Fresno-clovis Regional Reclamation Facility (RWRF) located at Jensen and Cornelia in southwest Fresno. RWRF has available capacity to treat approximately 88 mgd (million gallons per day). A conservative calculation for the Project’s wastewater generation of 25 gallons per day, per 1,000 square feet of industrial space would be 5,125 gallons of waste water generated per day (25 gal x (205,000 sf / 1,000 per sf)). Therefore, the plant has the capacity to treat the full increase in wastewater identified within the GP The Project complies the requirements of MM UTL‐1.3.1 and 1.4.1. Therefore, the Project would result in no new impacts related to wastewater treatment capacity of the service provider. d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
No New Impact. This topic was not specifically evaluated in the GP PEIR, however analyzed if the GP would be served by a landfill with sufficient permitted capacity to accommodate the GP’s solid waste disposal needs (Section 4.17, Impact UTL 4.1) and was determined to be less than significant with mitigation incorporated (MM UTL-4.1).

Three landfills were identified to serve the GP PEIR Planning Area, however one has closed.

According to CalRecycle, American Avenue Landfill has remaining capacity of 2,200 tons per day (operational till 2031); the Clovis Landfill has additional capacity of 2,000 tons per day (operational until 2047); and the Coalinga Landfill has been closed. The requirements of MM UTL-4.1 are satisfied because two landfills serving the City have capacity.

Project construction would generate solid waste for landfill disposal in the form of demolition debris from the existing buildings and infrastructure that would be removed from the site.

Construction waste in the form of packaging and discarded materials would also be generated by the proposed Project. However, Section 5.408.1 of the 2019 California Green Building Standards Code requires demolition and construction activities to recycle or reuse a minimum of 65 percent of the nonhazardous construction and demolition waste. Thus, the demolition and construction solid waste that would be disposed of at the landfill would be approximately 35 percent of the waste generated as required.

Operation of the Project includes operation of a new industrial facility which are estimated to produce 230.83 tons of solid waste per year (LSA 2022). However, pursuant to AB 341, at least 75 percent of the solid waste is required to be recycled, which would reduce the volume of landfilled solid waste to approximately 57.7 tons per year. Overall, the Project would result in the increase in solid waste from existing conditions and existing solid waste facilities would have capacity to serve the Project site as anticipated in buildout of the GP as analyzed in the GP PEIR. Therefore, the Project would result in no new impacts, requiring no new mitigation. 153
e) Comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
No New Impact. The GP PEIR determined the GP Update would result in a less than significant impact regarding this topic. As discussed above, the Project would be anticipated to result in 230.83 tons per year (LSA 2022). All solid waste-generating activities within the City are subject to the requirements set forth in Section 5.408.1 of the 2019 California Green Building Standards Code that requires demolition and construction activities to recycle or reuse a minimum of 65 percent of the nonhazardous construction and demolition waste, and AB 341 that requires diversion of a minimum of 75 percent of operational solid waste.

Furthermore, the proposed Project would comply with all standards and City ordinances (Section 6-201 Municipal Code) related to solid waste diversion, reduction, and recycling during Project construction and operation. Therefore, the proposed Project is anticipated to result in less than significant impacts related to potential conflicts with federal, State, and local management and reduction statutes and regulations pertaining to solid waste. Therefore, the Project would result in no new impacts.

CONCLUSION
With regards to the issue area of Utilities and Service Systems, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. Mitigation measures contained within the GP PEIR would be required because Project specific impacts would be less than significant.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP GOALS AND POLICIES
None.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
None.
154

ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
XX. 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?

SUMMARY OF IMPACTS IDENTIFIED IN THE GP PEIR
The GP PEIR did not specifically analyze impacts related to wildfires, as these were not individual and separate thresholds for impact analysis in State CEQA Guidelines Appendix G at the time the GP PEIR was written. However, the topic of wildfire risk was discussed within 155
the Hazards and Hazardous Materials section of the GP PEIR. As shown in the City of Fresno Map Atlas Existing Conditions Report (dated August 2011) of the GP PEIR, the City is proximate to high and very high fire hazard designated areas. A small area in the norther portion of the City is susceptible to wildfires along the San Joaquin River Bluff area due to relatively steep terrain with vegetation. However, as concluded in the GP PEIR, the City is largely categorized as little or no threat or moderate fire hazard largely attributing to amount of paved areas in the City. Thus, development under the approved GP adjacent to the San Joaquin River Bluff requires implementation of the objectives and policies within the GP reduce potential impacts from wildfires to less than significant. Therefore, the Project is not subject to such requirements as the site is not adjacent or near the San Joaquin River Bluff area, and impacts from wildfire are less than significant.

GP GOALS AND POLICIES
The GP goals and policies that pertain to the Project’s impacts from wildfires:

Policy PU‐2‐d. Station Siting. Use the General Plan, community plans, Specific Plans, neighborhood plans, and Concept Plans, the City’s Geographic Information Systems (GIS) database, and a fire station location program to achieve optimum siting of future fire stations.

Policy PU‐2‐e. Service Standards. Strive to achieve a community wide risk management plan that include the following service level objectives 90 percent of the time:
• First Unit on Scene – First fire unit arriving with minimum of three firefighters and ability to apply suppressing agent within 6 minutes and 20 seconds from emergency call (7 minutes and 30 seconds with 9‐11 processing time).
• Effective Response Force – Provide sufficient number of firefighters on scene of an emergency (17 for low risk, 23 for high risk) within nine minutes and 20 seconds from time of alert to arrival.

Policy PU‐3‐b. Reduction Strategies. Develop community risk reduction strategies that target high service demand areas, vulnerable populations (e.g. young children, older adults, non‐English speaking residents, persons with disabilities, etc.) and high life hazards occupancies.

Policy PU‐3‐e. Building Codes. Adopt and enforce amendments to construction and fire codes, as determined appropriate, to systematically reduce the level of risk to life and property from fire, commensurate with the City’s fire suppression capabilities.

Policy PU‐3‐f. Adequate Infrastructure. Continue to pursue the provision of adequate water supplies, hydrants, and appropriate property access to allow for adequate fire suppression throughout the City.

Policy PU‐3‐g. Cost Recovery. Continue to evaluate appropriate codes, policies, and methods to generate fees or other sources of revenue to offset the ongoing personnel and maintenance costs of providing fire prevention and response services. It is anticipated that 156
implementation of the above objectives and policies from the proposed General Plan Update will reduce project impacts to wildland fires to a less than significant level.

GP PEIR MITIGATION MEASURES
None.

PROJECT-SPECIFIC IMPACTS
a) Substantially impair an adopted emergency response plan or emergency evacuation plan?
No New Impact. The Project site does not contain any emergency facilities, nor does it serve as an emergency evacuation route. During construction and long-term operation, the Project would be required to maintain adequate emergency access for emergency vehicles via Project roadways. A fire lane is included in Project design to provide adequate access for fire services.

Furthermore, the Project would not result in a substantial alteration to the design or capacity of any public road that would impair or interfere with the implementation of evacuation procedures. Therefore, The Project would result in no new impacts related to impairment of an emergency response 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?
No New Impact. This topic was evaluated in the GP PEIR and was determined to have a less than significant impact. The Project proposes an industrial development in an area characterized by the surrounding existing heavy industrial uses. As such, the Project itself would not exacerbate wildfire risks as compared to existing conditions because it is representative of existing development in the area. The Project site is not in an area identified at risk of fire hazard as identified within the GP PEIR. According to the California Department of Forestry and Fire Protection's FRAP Fire Hazard Severity Zones map, the Project is not within an area identified as a FHSZ. Therefore, the Project would not result in new impacts related to exposure of people or structures to significant risk involving wildland fires. 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?
No New Impact. This topic was not analyzed in the GP PEIR. The Project would not include 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.

Therefore, the Project would result in no new impacts.
157
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?
No New Impact. This topic was not analyzed in the GP PEIR. As previously discussed in Section VII, the Project site is not in an area susceptible to flooding. Additionally, the Project site is flat and not in an area susceptible to landslides. As previously discussed in Section X, the Project proposes the construction of onsite storm drain system conveyed into City’s existing 60-inch storm drain at two locations in E. North Avenue. Therefore, the Project would result in no new impacts related to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.

CONCLUSION
Therefore, with regards to the issue area of Wildfire, the following findings can be made:

1. No peculiar impacts to the Project or its site have been identified.

2. There are no potentially significant off-site and/or cumulative impacts which were not discussed by the GP PEIR.

3. No substantial new information has been identified which results in an impact which is more severe than anticipated by the GP PEIR.

4. No mitigation measures contained within the GP PEIR would be required because Project specific impacts would be less than significant.

UNIFORMLY APPLIED DEVELOPMENT POLICIES OR STANDARDS (DP/S) None.

GP GOALS AND POLICIES
Policy PU‐2‐d. Station Siting. Use the General Plan, community plans, Specific Plans, neighborhood plans, and Concept Plans, the City’s Geographic Information Systems (GIS) database, and a fire station location program to achieve optimum siting of future fire stations.

Policy PU‐2‐e. Service Standards. Strive to achieve a community wide risk management plan that include the following service level objectives 90 percent of the time:
• First Unit on Scene – First fire unit arriving with minimum of three firefighters and ability to apply suppressing agent within 6 minutes and 20 seconds from emergency call (7 minutes and 30 seconds with 9‐11 processing time).
• Effective Response Force – Provide sufficient number of firefighters on scene of an emergency (17 for low risk, 23 for high risk) within nine minutes and 20 seconds from time of alert to arrival.

Policy PU‐3‐b. Reduction Strategies. Develop community risk reduction strategies that target high service demand areas, vulnerable populations (e.g. young children, older adults, 158
non‐English speaking residents, persons with disabilities, etc.) and high life hazards occupancies.

Policy PU‐3‐e. Building Codes. Adopt and enforce amendments to construction and fire codes, as determined appropriate, to systematically reduce the level of risk to life and property from fire, commensurate with the City’s fire suppression capabilities.

Policy PU‐3‐f. Adequate Infrastructure. Continue to pursue the provision of adequate water supplies, hydrants, and appropriate property access to allow for adequate fire suppression throughout the City.

Policy PU‐3‐g. Cost Recovery. Continue to evaluate appropriate codes, policies, and methods to generate fees or other sources of revenue to offset the ongoing personnel and maintenance costs of providing fire prevention and response services. It is anticipated that implementation of the above objectives and policies from the proposed General Plan Update will reduce project impacts to wildland fires to a less than significant level.

GP PEIR MITIGATION MEASURES APPLICABLE TO THE PROJECT
None.
159

ENVIRONMENTAL ISSUES
Project
Peculiar
Impact that is
not
Substantially
Mitigated by
Uniformly
Applied
Policies
Significant
Impact not
Analyzed as
Significant in
the Prior EIR
Potentially
Significant
Offsite or
Cumulative
Impact not
Discussed in
the prior EIR
Adverse
Impact More
Severe based
on Substantial
New
Information
No New
Impact
XIX. MANDATORY FINDINGS OF SIGNIFICANCE
a) Does the project have the
potential to 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, 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?
b) Does the project have
impacts that are individually
limited, but cumulatively
considerable? ("Cumulatively
considerable" means that the
incremental effects of a
project are considerable
when viewed in connection
with the effects of past
projects, the effects of other
current projects, and the
effects of probable future
projects)?
c) Does the project have
environmental effects which
will cause substantial adverse
effects on human beings,
either directly or indirectly?

DISCUSSION
160
a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of an endangered, rare, or threatened species, or eliminate important examples of the major periods of California history or prehistory?
The Project site is fully disturbed and is in an urbanized location. Review of the site by a biologist indicated there were no sensitive fish, wildlife, or plant species present. A cultural resources records search shows the Project site to have no identified cultural sensitivity.

The Project would therefore have no potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of an endangered, rare, or threatened species, or eliminate important examples of the major periods of California history or prehistory.
b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.)
The Project was determined to not have any significant environmental impacts. The proposed use is consistent with the planned industrial buildout of the site, which was assessed on a program level in the General Plan PEIR. The Project would have no potential to contribute to new cumulatively considerable environmental impacts. c) Does the project have environmental effects that will cause substantial adverse effects on human beings, either directly or indirectly? Based on the analysis provided in this document and supporting technical analyses, the Project has no potential to result in new substantial adverse effects on human beings, either directly or indirectly.

April 2022

A I R Q UA L I T Y, HEALTH RISK, GREENHO USE

GAS, AND ENERGY IMPA CT REPORT

REYES COCA COLA BOTTLING (RCCB)

FRESNO DISTRIBUTION WAREHOUSE PROJECT

FRESNO, CALIFORNIA
April 2022

A I R Q UA L I T Y, HEALTH RISK, GREENHO USE

GAS, AND ENERGY IMPA CT REPORT

REYES COCA COLA BOTTLING (RCCB)

FRESNO DISTRIBUTION WAREHOUSE PROJECT

FRESNO, CALIFORNIA
Submitted to:

EPD Solutions, Inc.
2 Park Plaza, Suite 1120
Irvine, California 92614
Prepared by:

LSA
2565 Alluvial Avenue, Suite 172
Clovis, California 93612
(559) 490-1210
Project No. ESL2201.16

AIR QUALITY , HEALTH RISK , GREENHOUSE GAS , AND ENERGY

I MPACT REPORT
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WAREHOUSE

F RESNO, C ALIFORNIA
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TABLE OF CONTENTS
TABLE OF CONTENTS ............................................................................................................................... i LIST OF ABBREVIATIONS AND ACRONYMS............................................................................................ iii INTRODUCTION .......................................................................................................... 8 Project Location And Description.................................................................................................. 8 Existing Land Uses in the Project Area ........................................................................................ 11 BACKGROUND .......................................................................................................... 12 Air Pollutants and Health Effects ................................................................................................ 12 Ozone ............................................................................................................................................... 13 Carbon Monoxide.............................................................................................................................13 Particulate Matter............................................................................................................................13 Nitrogen Dioxide...............................................................................................................................13 Sulfur Dioxide ...................................................................................................................................13 Lead .................................................................................................................................................. 14 Volatile Organic Compounds............................................................................................................14 Toxic Air Contaminants.....................................................................................................................14 Electricity..................................................................................................................................... 18 Natural Gas.................................................................................................................................. 18 Fuel.............................................................................................................................................. 19 Greenhouse Gases and Global Climate Change.......................................................................... 19 Carbon Dioxide .................................................................................................................................21 Methane ........................................................................................................................................... 21 Nitrous Oxide....................................................................................................................................22 Hydrofluorocarbons, Perfluorocarbons, and Sulfur Hexafluoride....................................................22 Black Carbon..................................................................................................................................... 22 Effects of Global Climate Change .....................................................................................................23 Air Quality Regulatory Setting..................................................................................................... 24 Federal Regulations..........................................................................................................................24 State Regulations..............................................................................................................................24 Regional Regulations........................................................................................................................26 Local Regulations..............................................................................................................................29 Energy Regulatory Setting........................................................................................................... 30 Federal Regulations..........................................................................................................................30 State Regulations..............................................................................................................................31 Regional Regulations........................................................................................................................33 Local Regulations..............................................................................................................................33 Global Climage Change Regulation ............................................................................................. 34 Federal Regulations..........................................................................................................................34 State Regulations..............................................................................................................................35 Regional Regulations........................................................................................................................43 Local Regulations..............................................................................................................................44 SETTING.................................................................................................................... 45 Existing Climate and Air Quality .................................................................................................. 45 Attainment Status ....................................................................................................................... 47

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» ii Air Quality Monitoring Results.................................................................................................... 47 Greenhouse Gas Emissions Inventory......................................................................................... 50 Global Emissions...............................................................................................................................50 United States Emissions ...................................................................................................................50 State of California Emissions............................................................................................................50 City of Fresno Emissions...................................................................................................................51 METHODOLOGY........................................................................................................ 52 Construction Emissions............................................................................................................... 52 Operational Emissions................................................................................................................. 52 Construction Health Risk Assessment......................................................................................... 53 Operational Health RIsk Assessment .......................................................................................... 53 Energy Use................................................................................................................................... 54 Greenhouse Gas Analysis............................................................................................................ 54 THRESHOLDS OF SIGNIFICANCE................................................................................. 55 Criteria Polluant Thresholds........................................................................................................ 55 Health Risk Thresholds................................................................................................................ 56 Greenhouse Gas Emissions ......................................................................................................... 57 IMPACTS ANALYSIS................................................................................................... 59 Air Quality Impacts...................................................................................................................... 59 Consistency with Applicable Air Quality Plans .................................................................................59 Criteria Pollutant Analysis ................................................................................................................59 Health Risk on Nearby Sensitive Receptors......................................................................................63 Odors................................................................................................................................................ 65 Energy Impacts............................................................................................................................ 65 Energy Consumption ........................................................................................................................65 Conflict with Renewable Energy or Energy Efficiency Plans.............................................................68 Greenhouse Gas Impacts ............................................................................................................ 69 Generate Greenhouse Gas Emissions...............................................................................................69 Consistency with Greenhouse Gas Emissions Reduction Plans........................................................70 CONCLUSIONS .......................................................................................................... 72

APPENDICES
A: CalEEMod Output Sheets
B: HRA Model Output
C: Energy Calculations
D: GHG Reduction Plan Update Consistency Checklist

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FIGURES AND TABLES

FIGURES
Figure 1: Project Location....................................................................................................................... 9 Figure 2: Site Plan................................................................................................................................. 10 TABLES
Table A: Sources and Health Effects of Air Pollutants.......................................................................... 15 Table B: Federal and State Ambient Air Quality Standards.................................................................. 16 Table C: Global Warming Potential of Greenhouse Gases................................................................... 21 Table D: Potential Impacts of Global Warming and Expected Consequences for California ............... 25 Table E: Senate Bill 375 Regional Greenhouse Gas Emissions Reduction Targets............................... 39 Table F: Attainment Status of the San Joaquin Valley Air Basin........................................................... 48 Table G: Ambient Air Quality at Nearby Monitoring Stations.............................................................. 49 Table H: City of Fresno GHG Emissions by Sector for 2016.................................................................. 51 Table I: SJVAPCD Construction and Operation Thresholds of Significance (Tons per Year) ................ 56 Table J: Tentative Project Construction Schedule................................................................................ 61 Table K: Diesel Construction Equipment Utilized by Construction Phase............................................ 61 Table L: Project Construction Emissions............................................................................................... 62 Table M: Project Operational Emissions .............................................................................................. 63 Table N: Health Risks from Project Construction to Off-Site Receptors .............................................. 64 Table O: Health Risks from Project Operation to Off-Site Receptors................................................... 65 Table P: Proposed Project Energy Consumption Estimates during Construction ................................ 66 Table Q: Proposed Project Energy Consumption Estimates during Operation.................................... 67 Table R: Construction Greenhouse Gas Emissions............................................................................... 69

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LIST OF ABBREVIATIONS AND ACRONYMS
µg/m3 micrograms per cubic meter
ºF degrees Fahrenheit
AB Assembly bill
AQMP Air Quality Management Plan
BPS best performance standards
BTU British Thermal Units
CAAQS California Ambient Air Quality Standards
CAFE corporate average fuel economy
CalEEMod California Emissions Estimator Model
CalEPA California Environmental Protection Agency
CalGreen Code California Green Building Standards Code
CalRecycle California Department of Resources Recycling and Recovery CAPCOA California Air Pollution Control Officers Association CARB California Air Resources Board
CAT Climate Action Team
CBC California Building Code
CBSC California Building Standards Commission
CCAA California Clean Air Act
CCAP Climate Change Action Plan
CCR California Code of Regulations
CEC California Energy Commission
CEQA California Environmental Quality Act
CFR Code of Federal Regulations
CH4 methane
City City of Fresno
CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide equivalent
CPUC California Public Utilities Commission

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» v DPM Diesel particulate matter
EIR Environmental Impact Report
EO Executive Order
FCAA Federal Clean Air Act
GAMAQI Joaquin Valley Air Pollution Control District’s Guidance for Assessing and Mitigating Air Quality Impacts
GHG greenhouse gas
GHGRx Greenhouse Gas Reduction Exchange
GWh gigawatt-hours
GWP global warming potential
H2S hydrogen sulfide
HFC hydrofluorocarbons
HI Hazard Index
HRA Health Risk Assessment
IPCC International Panel on Climate Change
kWh kilowatt-hour
LCFS Low Carbon Fuel Standard
LEED Leadership in Energy and Environmental Design
MEI maximally exposed individual
MICR maximum individual cancer risk
MMT million metric tons
MMT CO2e million metric tons of carbon dioxide equivalent mpg miles per gallon
mph miles per hour
MPOs Metropolitan Planning Organization
MW megawatt
N2O nitrous oxide
NAAQS National Ambient Air Quality Standards
NEPA National Environmental Policy Act
NHTSA National Highway Traffic Safety Administration
NO2 nitrogen dioxide

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O3 ozone
OEHHA California Environmental Protection Agency's Office of Environmental Health Hazard Assessment
OPR Governor’s Office of Planning and Research (OPR)
Pb lead
PFC perfluorocarbons
PG&E Pacific Gas and Electric
PM particulate matter
PM10 particulate matter less than 10 microns in diameter PM2.5 particulate matter less than 2.5 microns in diameter ppb parts per billion
ppm parts per million
PRC Public Resources Code
project Reyes Coca Cola Bottling (RCCB) Fresno Distribution Warehouse Project RCCB Reyes Coca Cola Bottling
ROCs reactive organic compounds
ROGs reactive organic gases
RPS Renewables Portfolio Standard
SAFE Safer Affordable Fuel-Efficient
SB Senate Bill
SCS Sustainable Communities Strategy
sf square foot/feet
SF6 sulfur hexafluoride
SJVAB San Joaquin Valley Air Basin
SJVAPCD San Joaquin Valley Air Pollution Control District SO2 sulfur dioxide
SOx sulfur oxides
TACs toxic air contaminants
UNFCCC United Nations Framework Convention on Climate Change USC United States Code

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USEPA United States Environmental Protection Agency
VMT vehicle miles traveled
VOCs volatile organic compounds
ZEVs zero emission vehicles

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INTRODUCTION
This air quality, heath risk, energy, and greenhouse gas (GHG) impact report has been prepared to evaluate the potential air quality and GHG emissions impacts associated with the Reyes Coca Cola Bottling (RCCB) Fresno Distribution Warehouse Project (project) in the City of Fresno (City), California. This report has been prepared using methods and assumptions recommended in the San Joaquin Valley Air Pollution Control District’s (SJVAPCD) Guidance for Assessing and Mitigating Air Quality Impacts (GAMAQI).1 In keeping with these guidelines, this analysis describes existing air quality, air quality and GHG emissions generated from project-related sources, regional air pollution, and global climate change. In addition, this analysis discusses energy use resulting from implementation of the proposed project and evaluates whether the proposed project would result in the wasteful, inefficient, or unnecessary consumption of energy resources or conflict with any applicable plans for renewable energy and energy efficiency.

PROJECT LOCATION AND DESCRIPTION
The proposed project is located at 791 and 998 E. North Avenue, at the southwest corner of the E.

North Avenue and S. East Avenue intersection in the City of Fresno. The project site is identified by Assessor’s Parcel Numbers 329-09-016 and 329-09-017. The project site is currently vacant. Figure 1 illustrates the project site location. Figure 2 depicts the proposed project’s site plan.

The proposed project would construct a 205,264-square-foot (sf) warehouse building with ancillary office space and a future expansion option of 40,300 sf of warehouse. The building shell would include a two-story office area to be constructed of concrete tilt-up panels, a panelized roof system, 29 dock-high doors, a truck wash and truck maintenance shop attached to the warehouse space, and a small outdoor patio space. Also included are a truck yard, automobile parking areas, truck parking, and stormwater management areas. The building would be fully air conditioned, and would be used for Food and Beverage Industrial Storage Space. The yard would be fully secured with rolling gates and fences, with ingress and egress from both E. North Avenue and S. East Avenue. The proposed project would not require a change to the General Plan land use designation or the current zoning and would be consistent with the City’s General Plan and Zoning Ordinance.

Typical operational characteristics include employees traveling to and from the site, delivery of products to the site, truck loading and unloading, and truck maintenance operations. The project is assumed to operate 24 hours a day, 7 days a week; however, this may shift depending on the tenant, as the hours of operation are unknown. The proposed project would generate approximately 481 average daily trips, including 321 vehicle trips and 160 truck trips. It is assumed that 20 daily truck trips would travel to and from Sacramento, 40 truck trips would travel to and from San Leandro, and 100 daily truck trips would make local deliveries. In addition, the proposed project would utilize 32 electric forklifts.

Construction would begin September 2022 and end March 2024. Construction of the proposed project would require the import of approximately 5,458 cubic yards of material. 1 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2015. Guidance for Assessing and Mitigating Air Quality Impacts. March 19. Website: www.valleyair.org/transportation/ceqa_idx.htm (accessed April 2022).

Project Location
SOURCE: ArcGIS Online Topographic Map (2020)
I:\ESL2201\G\Project_LocaƟon.ai (03/09/2022)
FIGURE 1
Fresno DistribuƟon Center Project
Project LocaƟon
0 400 800
FEET
LEGEND
Project Site
City Boundary
Madera
County
Fresno
County
Ã201 Ã43
Ã168
Ã180
Ã41
Ã99
Project Vicinity
Project Location

ACCESSIBLE STALLS

TYPICAL
27'
TYP.
27'
TYP.
65' 90' 55'
27'
TYP.
15'
17'
30'
TYP.
27'
TYP.
27'
TYP.
70'
TYP.
72'

OUTDOOR

SEATING
AREA
35'
TYP.

SLIDING GATES

LANDSCAPE BUFFER AND

STRIPED AREA

SAME WIDTH AS SINGLE STALL

TYPICAL

TYPICAL PARKING STALL
9'x19'
TRASH

ENCLOSURE
18'
TYP.
27'
TYP.

POSSIBLE

TRANSFORMER &

GENERATOR

LOCATION
40'
TYP.
34'
TYP.
16'
TYP.

DEF
10'±.
60' 46'
36'
TYP.

EMPLOYEES

OUTDOOR
BREAK
AREA
GATE
GATE
27'
TYP.

GATE
45'
TYP.

GATE

FUTURE EV TBA
± 25% OF REQ'd EV TO BE FULLY
INSTALLED, REMAINING TO BE FUTURENEED. ONE STANDARD ADA EV INSTALLED AND ONE VAN STALL.

POSSIBLELOCATION OFBIKE RACK

POSSIBLE LOCATION

OF BIKE RACK
GATE
GATE
FUTURE

EXPANSION
24'x4' ISLAND
FUTURE

EXPANSION
24'x4' ISLAND
TRASH
DOCK

DUMPSTER
SOURCE: Ware Malcomb
FEET
0 25 80
FIGURE 2
Site Plan
I:\ESL2201\G\Site_Plan.ai (03/09/2022)
Fresno DistribuƟon Center Project

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EXISTING LAND USES IN THE PROJECT AREA
For the purposes of this analysis, sensitive receptors are areas of the population that have an increased sensitivity to air pollution or environmental contaminants. Sensitive receptor locations include residences, schools, daycare centers, hospitals, parks, and similar uses that are sensitive to air quality. Impacts on sensitive receptors are of particular concern because those receptors are the population most vulnerable to the effects of air pollution.2 The project site is surrounded primarily by industrial uses. The areas adjacent to the project site include the following uses:
• North: Existing industrial uses, opposite E. North Avenue; • East: Existing industrial uses opposite S. East Avenue; • South: Existing industrial uses; and
• West: Existing Fresno Commercial Drive Test Center.

The closest sensitive receptors are residential uses, located more than 1,500 feet from the project site along S. Cherry Avenue, and the nearest worker receptors are located adjacent to the north, east, south, and west borders of the project site.
2 SJVAPCD. 2015. Guidance for Assessing and Mitigating Air Quality Impacts (GAMAQI). March. Website:
http://www.valleyair.org/transportation/GAMAQI_3-19-15.pdf (accessed April 2022).

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BACKGROUND
This section provides current background information on air pollutants and GHG emissions and their health effects. It also provides current regulatory background information, including information from the California Air Resources Board’s (CARB) Air Quality and Land Use Handbook3 (CARB Handbook); a description of the general health risks of toxics, and the significance criteria for project evaluation. In addition, this section provides background information on energy usage in the project area and provides regulatory background information, including federal, State, and local energy regulations.

AIR POLLUTANTS AND HEALTH EFFECTS
Both State and federal governments have established health-based ambient air quality standards (California Ambient Air Quality Standards [CAAQS] and National Ambient Air Quality Standards [NAAQS], respectively) for six criteria air pollutants:4 carbon monoxide (CO), ozone (O3), nitrogen dioxide (NO2), sulfur dioxide (SO2), lead (Pb), and suspended particulate matter (PM). In addition, the State has set standards for sulfates, hydrogen sulfide, vinyl chloride, and visibility-reducing particles. These standards are designed to protect the health and welfare of the populace with a reasonable margin of safety. Long-term exposure to elevated levels of criteria pollutants may result in adverse health effects. However, emission thresholds established by an air district are used to manage total regional emissions within an air basin based on the air basin’s attainment status for criteria pollutants. These emission thresholds were established for individual projects that would contribute to regional emissions and pollutant concentrations and could adversely affect or delay the projected attainment target year for certain criteria pollutants.

Because of the conservative nature of the thresholds and the basin-wide context of individual project emissions, there is no known direct correlation between a single project and localized air quality-related health effects. One individual project that generates emissions exceeding a threshold does not necessarily result in adverse health effects for residents in the project vicinity. This condition is especially true when the criteria pollutants exceeding thresholds are those with regional effects, such as ozone precursors like nitrogen oxides (NOx) and volatile organic compounds (VOCs).

Occupants of facilities such as schools, daycare centers, parks and playgrounds, hospitals, and nursing and convalescent homes are considered to be more sensitive than the general public to air pollutants because these population groups have increased susceptibility to respiratory disease.

Persons engaged in strenuous outdoor work or exercise also have increased sensitivity to poor air quality. Residential areas are considered more sensitive to air quality conditions, compared to commercial and industrial areas, because people generally spend longer periods of time at their residences, with greater associated exposure to ambient air quality conditions. Recreational uses 3 California Air Resources Board (CARB). 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April. 4 Criteria pollutants are defined as those pollutants for which the federal and State governments have established ambient air quality standards, or criteria, for outdoor concentrations in order to protect public health.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 13 are also considered sensitive compared to commercial and industrial uses due to greater exposure to ambient air quality conditions associated with exercise.

Ozone
Rather than being directly emitted, ozone (smog) is formed by photochemical reactions between NOx and VOC. Ozone is a pungent, colorless gas. Elevated ozone concentrations result in reduced lung function, particularly during vigorous physical activity. This health problem is particularly acute in sensitive receptors such as the sick, elderly, and young children. Ozone levels peak during the summer and early fall months.

Carbon Monoxide
CO is formed by the incomplete combustion of fossil fuels, almost entirely from automobiles. It is a colorless, odorless gas that can cause dizziness, fatigue, and impairments to central nervous system functions. CO passes through the lungs into the bloodstream, where it interferes with the transfer of oxygen to body tissues.

Particulate Matter
Particulate matter is the term used for a mixture of solid particles and liquid droplets found in the air. Coarse particles are those that are 10 microns or less in diameter, or PM10. Fine, suspended particulate matter with an aerodynamic diameter of 2.5 microns or less, or PM2.5, is not readily filtered out by the lungs. Nitrates, sulfates, dust, and combustion particulates are major components of PM10 and PM2.5. These small particles can be directly emitted into the atmosphere as byproducts of fuel combustion; through abrasion, such as tire or brake lining wear; or through fugitive dust (wind or mechanical erosion of soil). They can also be formed in the atmosphere through chemical reactions. Particulates may transport carcinogens and other toxic compounds that adhere to the particle surfaces and can enter the human body through the lungs.

Nitrogen Dioxide
NO2 is a reddish brown gas that is a byproduct of combustion processes. Automobiles and industrial operations are the main sources of NO2. Aside from its contribution to ozone formation, NO2 also contributes to other pollution problems, including a high concentration of fine particulate matter, poor visibility, and acid deposition. NO2 may be visible as a coloring component on high pollution days, especially in conjunction with high ozone levels. NO2 decreases lung function and may reduce resistance to infection.

Sulfur Dioxide
SO2 is a colorless, irritating gas formed primarily from incomplete combustion of fuels containing sulfur. Industrial facilities also contribute to gaseous SO2 levels in the region. SO2 irritates the respiratory tract, can injure lung tissue when combined with fine particulate matter, and reduces visibility and the level of sunlight.

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Leaded gasoline (phased out in the United States beginning in 1973), paint (on older houses and cars), smelters (metal refineries), and the manufacture of lead storage batteries have been the primary sources of lead released into the atmosphere. Lead has multiple adverse neurotoxic health effects, and children are at special risk. Some lead-containing chemicals cause cancer in animals.

Lead levels in the air have decreased substantially since leaded gasoline was eliminated. Ambient lead concentrations are only monitored on an as-warranted, site-specific basis in California. On October 15, 2008, the United States Environmental Protection Agency (USEPA) strengthened the NAAQS for lead by lowering it from 1.5 to 0.15 micrograms per cubic meter (µg/m3 ). The USEPA
revised the monitoring requirements for lead in December 2010. These requirements focus on airports and large urban areas, resulting in an increase in 76 monitors nationally.

Volatile Organic Compounds
VOCs (also known as reactive organic gases [ROGs] and reactive organic compounds [ROCs]) are formed from the combustion of fuels and the evaporation of organic solvents. VOCs are not defined as criteria pollutants, however, because VOCs accumulate in the atmosphere more quickly during the winter, when sunlight is limited and photochemical reactions are slower, they are a prime component of the photochemical smog reaction. There are no attainment designations for VOCs.

Toxic Air Contaminants
In addition to the criteria pollutants discussed above, toxic air contaminants (TACs) are another group of pollutants of concern. TACs are injurious in small quantities and are regulated by the USEPA and the CARB. Some examples of TACs include benzene, butadiene, formaldehyde, and hydrogen sulfide. The identification, regulation, and monitoring of TACs is relatively recent compared to that for criteria pollutants.

TACs do not have ambient air quality standards, but are regulated by the USEPA, CARB, and the SJVAPCD. In 1998, the CARB identified particulate matter from diesel-fueled engines as a TAC. The CARB has completed a risk management process that identified potential cancer risks for a range of activities using diesel-fueled engines.5 High-volume freeways, stationary diesel engines, and facilities attracting heavy and constant diesel vehicle traffic (e.g., distribution centers and truck stops) were identified as posing the highest risk to adjacent receptors. Other facilities associated with increased risk include warehouse distribution centers, large retail or industrial facilities, high-volume transit centers, and schools with a high volume of bus traffic. Health risks from TACs are a function of both concentration and duration of exposure.

Unlike TACs emitted from industrial and other stationary sources noted above, most diesel particulate matter is emitted from mobile sources—primarily “off-road” sources such as construction and mining equipment, agricultural equipment, and truck-mounted refrigeration units, as well as “on-road” sources such as trucks and buses traveling on freeways and local roadways. 5 CARB. 2000. Stationary Source Division and Mobile Source Control Division. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. October.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 15 Although not specifically monitored, recent studies indicate that exposure to diesel particulate matter may contribute significantly to a cancer risk (a risk of approximately 500 to 700 in 1,000,000) that is greater than all other measured TACs combined.6 The technology for reducing diesel particulate matter emissions from heavy-duty trucks is well established, and both State and federal agencies are moving aggressively to regulate engines and emission control systems to reduce and remediate diesel emissions. The CARB anticipated that by 2020, average statewide diesel particulate matter concentrations will decrease by 85 percent from levels in 2000 with full implementation of the CARB’s Diesel Risk Reduction Plan,7 meaning that the statewide health risk from diesel particulate matter is expected to decrease from 540 cancer cases in 1,000,000 to 21.5 cancer cases in 1,000,000. The CARB 2000 Diesel Risk Reduction Plan is still the most recent version and has not been updated.

Table A summarizes the sources and health effects of air pollutants discussed in this section. Table B presents a summary of CAAQS and NAAQS.

Table A: Sources and Health Effects of Air Pollutants
Pollutants Sources Primary Effects
Carbon
Monoxide (CO)
• Incomplete combustion of fuels
and other carbon-containing
substances, such as motor exhaust
• Natural events, such as
decomposition of organic matter
• Reduced tolerance for exercise
• Impairment of mental function
• Impairment of fetal development
• Death at high levels of exposure
• Aggravation of some heart diseases (angina)
Nitrogen Dioxide
(NO2)
• Motor vehicle exhaust
• High temperature stationary
combustion
• Atmospheric reactions
• Aggravation of respiratory illness
• Reduced visibility
• Reduced plant growth
• Formation of acid rain
Ozone
(O3)
• Atmospheric reaction of organic
gases with nitrogen oxides in
sunlight
• Aggravation of respiratory and cardiovascular diseases • Irritation of eyes
• Impairment of cardiopulmonary function
• Plant leaf injury
Lead
(Pb)
• Contaminated soil • Impairment of blood functions and nerve construction • Behavioral and hearing problems in children
Suspended
Particulate
Matter
(PM2.5 and PM10)
• Stationary combustion of solid
fuels
• Construction activities
• Industrial processes
• Atmospheric chemical reactions
• Reduced lung function
• Aggravation of the effects of gaseous pollutants
• Aggravation of respiratory and cardiorespiratory diseases • Increased cough and chest discomfort
• Soiling
• Reduced visibility
Sulfur Dioxide
(SO2)
• Combustion of sulfur-containing
fossil fuels
• Smelting of sulfur-bearing metal
ores Industrial processes
• Aggravation of respiratory diseases (asthma, emphysema) • Reduced lung function
• Irritation of eyes
• Reduced visibility
• Plant injury
• Deterioration of metals, textiles, leather, finishes, coatings, etc.

Source: California Air Resources Board (2015).
6 CARB. 2000. Stationary Source Division and Mobile Source Control Division. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. October. 7 Ibid.

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Averaging
Time
California Standardsa Federal Standardsb
Concentrationc Methodd Primaryc,e Secondaryc,f Methodg
Ozone
(O3)
h
1-Hour 0.09 ppm
(180 μg/m3) Ultraviolet
Photometry
– Same as
Primary
Standard
Ultraviolet
Photometry 8-Hour 0.07 ppm
(137 μg/m3)

0.070 ppm
(137 μg/m3)
Respirable
Particulate
Matter
(PM10)
i
24-Hour 50 μg/m3
Gravimetric or Beta
Attenuation
150 μg/m3
Same as
Primary
Standard
Inertial
Separation and
Gravimetric
Analysis
Annual
Arithmetic
Mean
20 μg/m3 –
Fine
Particulate
Matter
(PM2.5)
i
24-Hour - 35 μg/m3
Same as
Primary
Standard
Inertial
Separation and
Gravimetric
Analysis
Annual
Arithmetic
Mean
12 μg/m3 Gravimetric or Beta
Attenuation 12.0 μg/m3
Carbon
Monoxide
(CO)
8-Hour 9.0 ppm
(10 mg/m3) Non-Dispersive
Infrared
Photometry
(NDIR)
9 ppm
(10 mg/m3) – Non-Dispersive
Infrared
Photometry
(NDIR)
1-Hour 20 ppm
(23 mg/m3)
35 ppm
(40 mg/m3)
8-Hour
(Lake Tahoe)
6 ppm
(7 mg/m3) – –
Nitrogen
Dioxide
(NO2)
j
Annual
Arithmetic
Mean

0.03 ppm
(57 μg/m3
) Gas Phase
Chemi-luminescence
53 ppb
(100 μg/m3
)
Same as
Primary
Standard
Gas Phase
Chemiluminescence 1-Hour 0.18 ppm
(339 μg/m3)
100 ppb
(188 μg/m3) -
Lead
(Pb)l,m
30-Day
Average 1.5 μg/m3
Atomic
Absorption
– –
High-Volume
Sampler and
Atomic
Absorption
Calendar
Quarter – 1.5 μg/m3(for certain areas)l Same as
Primary
Standard
Rolling 3-
Month
Averagei
– 0.15 μg/m3
Sulfur
Dioxide
(SO2)
k
24-Hour 0.04 ppm
(105 μg/m3)
Ultraviolet
Fluorescence

0.14 ppm
(for certain areas) –
Ultraviolet
Fluorescence;
Spectrophotometry
(Pararosaniline
Method)
3-Hour – – 0.5 ppm
(1300 μg/m3)
1-Hour 0.25 ppm
(655 μg/m3)
75 ppb
(196 μg/m3)
k –
Annual
Arithmetic
Mean
– 0.030 ppm
(for certain areas)k –
VisibilityReducing
Particlesl
8-Hour See footnote n
Beta Attenuation
and Transmittance
through Filter Tape.

No
Federal
Standards
Sulfates 24-Hour 25 μg/m3 Ion Chromatography
Hydrogen
Sulfide 1-Hour 0.03 ppm (42 μg/m3)
Ultraviolet
Fluorescence
Vinyl Chloridej 24-Hour 0.01 ppm
(26 μg/m3) Gas Chromatography
Source: California Air Resources Board (2016) (Website: https://www.arb.ca.gov/research/aaqs/aaqs2.pdf).

Table notes are provided on the following page.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 17 a California standards for ozone, carbon monoxide (except 8-hour Lake Tahoe), sulfur dioxide (1- and 24-hour), nitrogen dioxide, and particulate matter (PM10, PM2.5, and visibility reducing particles), are values that are not to be exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations.
b National standards (other than ozone, particulate matter, and those based on annual arithmetic mean) are not to be exceeded more than once a year. The ozone standard is attained when the fourth highest 8-hour concentration measured at each site in a year, averaged over three years, is equal to or less than the standard. For PM10, the 24-hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 μg/m3 is equal to or less than one. For PM2.5, the 24-hour standard is attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard.

Contact USEPA for further clarification and current national policies. c Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas.
d Any equivalent measurement method which can be shown to the satisfaction of the CARB to give equivalent results at or near the level of the air quality standard may be used.
e National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health. f National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.
g Reference method as described by the USEPA. An “equivalent method” of measurement may be used but must have a “consistent relationship to the reference method” and must be approved by the USEPA. h On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to 0.070 ppm. i On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 μg/m3 to 12.0 μg/m3 . The existing national
24- hour PM2.5 standards (primary and secondary) were retained at 35 μg/m3 , as was the annual secondary standard of 15 μg/m3. The existing 24-hour PM10 standards (primary and secondary) of 150 μg/m3 also were retained. The form of the annual primary and secondary standards is the annual mean, averaged over 3 years. j To attain the 1-hour national standard, the 3-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site must not exceed 100 ppb. Note that the national 1-hour standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm). To directly compare the national 1-hour standard to the California standards the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm. k On June 2, 2010, a new 1-hour SO2 standard was established, and the existing 24-hour and annual primary standards were revoked. To attain the 1-hour national standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved.

Note that the 1-hour national standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm).

To directly compare the 1-hour national standard to the California standard the units can be converted to ppm. In this case, the national standard of 75 ppb is identical to 0.075 ppm.
l The CARB has identified lead and vinyl chloride as ‘toxic air contaminants’ with no threshold level of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants.
m The national standard for lead was revised on October 15, 2008, to a rolling 3-month average. The 1978 lead standard (1.5 μg/m3 as a quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.
n In 1989, the CARB converted both the general statewide 10-mile visibility standard and the Lake Tahoe 30-mile visibility standard to instrumental equivalents, which are “extinction of 0.23 per kilometer” and “extinction of 0.07 per kilometer” for the statewide and Lake Tahoe Air Basin standards, respectively.
°C = degrees Celsius
µg/m3 = micrograms per cubic meter
CARB = California Air Resources Board
mg/m3 = milligrams per cubic meter
ppb = parts per billion
ppm = parts per million
USEPA = United States Environmental Protection Agency

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ELECTRICITY
Electricity is a manmade resource. The production of electricity requires the consumption or conversion of energy resources (including water, wind, oil, gas, coal, solar, geothermal, and nuclear resources) into energy. Electricity is used for a variety of purposes (e.g., lighting, heating, cooling, and refrigeration, and for operating appliances, computers, electronics, machinery, and public transportation systems).

According to the most recent data available, in 2020, California’s electricity was generated primarily by natural gas (37.06 percent), renewable sources (33.09 percent), large hydroelectric (12.21 percent), nuclear (9.33 percent), coal (2.74 percent), and other and unspecified sources. Total electric generation in California in 2020 was 272,576 gigawatt-hours (GWh), down 2 percent from the 2019 total generation of 277,704 GWh.
8 The City receives its electricity from Pacific Gas and Electric’s (PG&E). According to the California Energy Commission (CEC), total electricity consumption in the PG&E service area in 2020 was 78,518.8 GWh (29,833.5 GWh for the residential sector and 48,685.3 GWh for the non-residential sector).9 Total electricity consumption in Fresno County in 2020 was 8,017.8 GWh (3,101.8 GWh for the residential sector and 4,916.0 for the non-residential sector).10

NATURAL GAS
Natural gas is a non-renewable fossil fuel. Fossil fuels are formed when layers of decomposing plant and animal matter are exposed to intense heat and pressure under the surface of the Earth over millions of years. Natural gas is a combustible mixture of hydrocarbon compounds (primarily methane) that is used as a fuel source. Natural gas is found in naturally occurring reservoirs in deep underground rock formations. Natural gas is used for a variety of uses (e.g., heating buildings, generating electricity, and powering appliances such as stoves, washing machines and dryers, gas fireplaces, and gas grills).

Natural gas consumed in California is used for electricity generation (45 percent), residential uses (21 percent), industrial uses (25 percent), and commercial uses (9 percent). California continues to depend on out-of-state imports for nearly 90 percent of its natural gas supply.11 PG&E is the natural gas service provider for the City of Fresno. According to the CEC, total natural gas consumption in the PG&E service area in 2020 was 4,508.5 million therms (1,891.3 million 8 California Energy Commission (CEC). 2021a. 2020 Total System Electric Generation. Website:
https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/2020-total-systemelectric-generation (accessed April 2022). 9 CEC. 2021b. Electricity Consumption by Entity. Website: ecdms.energy.ca.gov/elecbyutil.aspx (accessed April 2022). 10 CEC. 2021c. Electricity Consumption by County. Website: ecdms.energy.ca.gov/elecbycounty.aspx (accessed April 2022). 11 CEC. 2021d. Supply and Demand of Natural Gas in California. Website: https://www.energy.ca.gov/datareports/energy-almanac/californias-natural-gas-market/supply-and-demand-natural-gas-california (accessed April 2022).

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 19 therms for the residential sector and 2,617.2 million therms for the non-residential sector).12 Total natural gas consumption in Fresno County in 2020 was 325.9 million therms (110.0 million therms for the residential sector and 215.9 million therms for the non-residential sector).13 FUEL
Petroleum is also a non-renewable fossil fuel. Petroleum is a thick, flammable, yellow-to-black mixture of gaseous, liquid, and solid hydrocarbons that occurs naturally beneath the earth's surface.

Petroleum is primarily recovered by oil drilling. It is refined into a large number of consumer products, primarily fuel oil, gasoline, and diesel.

The average fuel economy for light‐duty vehicles (autos, pickups, vans, and SUVs) in the United States has steadily increased from about 14.9 miles per gallon (mpg) in 1980 to 22.2 mpg in 2019.14 Federal fuel economy standards have changed substantially since the Energy Independence and Security Act was passed in 2007. The Act, which originally mandated a national fuel economy standard of 35 mpg by year 202015, applies to cars and light trucks of Model Years 2011 through 2020. In March 2020, the United States Environmental Protection Agency (USEPA) and National Highway Traffic Safety Administration (NHTSA) finalized the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021–2026 Passenger Cars and Light Trucks, further detailed below.

Gasoline is the most used transportation fuel in California, with 97 percent of all gasoline being consumed by light-duty cars, pickup trucks, and sport utility vehicles. According to the most recent data available, total gasoline consumption in California was 289,918 thousand barrels or 1,464.7 trillion British Thermal Units (BTU) in 2020.16 Of the total gasoline consumption, 273,289 thousand barrels or 1,380.7 trillion BTU were consumed for transportation.17 Based on fuel consumption obtained from CARB’s California Emissions Factor Model, Version 2021 (EMFAC2021), approximately 376.0 million gallons of gasoline and approximately 157.0 million gallons of diesel will be consumed from vehicle trips in Fresno County in 2022.

GREENHOUSE GASES AND GLOBAL CLIMATE CHANGE
Global climate change is the observed increase in the average temperature of the Earth’s atmosphere and oceans in recent decades. The Earth’s average near-surface atmospheric 12 CEC. 2021e. Gas Consumption by Entity. Website: ecdms.energy.ca.gov/gasbyutil.aspx (accessed April 2022). 13 CEC. 2021f. Gas Consumption by County. Website: ecdms.energy.ca.gov/gasbycounty.aspx (accessed April 2022). 14 U.S. Department of Transportation (DOT). “Table 4‐23: Average Fuel Efficiency of U.S. Light Duty Vehicles.” Website: https://www.bts.dot.gov/bts/bts/content/average-fuel-efficiency-us-light-dutyvehicles (accessed April 2022). 15 U.S. Department of Energy. 2007. “Energy Independence & Security Act of 2007.” Website: https://www. afdc.energy.gov/laws/eisa (accessed April 2022). 16 A British Thermal Unit is defined as the amount of heat required to raise the temperature of one pound of water by one degree Fahrenheit. 17 U.S. Department of Energy, EIA. 2021a. California State Profile and Energy Estimates. Table F3: Motor gasoline consumption, price, and expenditure estimates, 2020. Website: eia.gov/state/seds/data.php? incfile=/state/seds/sep_fuel/html/fuel_mg.html&sid=CA (accessed April 2022).

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 20 temperature rose 0.6 ± 0.2° Celsius (°C) or 1.1 ± 0.4° Fahrenheit (°F) in the 20th century. The prevailing scientific opinion on climate change is that most of the warming observed over the last 50 years is attributable to human activities. The increased amounts of carbon dioxide (CO2) and other GHGs are the primary causes of the human-induced component of warming. GHGs are released by the burning of fossil fuels, land clearing, agriculture, and other activities, and lead to an increase in the greenhouse effect.18
GHGs are present in the atmosphere naturally, are released by natural sources, or are formed from secondary reactions taking place in the atmosphere. The gases that are widely seen as the principal contributors to human-induced global climate change are:
• CO2
• Methane (CH4)
• Nitrous oxide (N2O)
• Hydrofluorocarbons (HFCs)
• Perfluorocarbons (PFCs)
• Sulfur hexafluoride (SF6)
Over the last 200 years, humans have caused substantial quantities of GHGs to be released into the atmosphere. These extra emissions are increasing GHG concentrations in the atmosphere, and enhancing the natural greenhouse effect, which is believed to be causing global warming. While manmade GHGs include naturally-occurring GHGs such as CO2, methane, and N2O, some gases, like HFCs, PFCs, and SF6 are completely new to the atmosphere.

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

These gases vary considerably in terms of Global Warming Potential (GWP), which is a concept developed to compare the ability of each GHG to trap heat in the atmosphere relative to another gas. The global warming potential is based on several factors, including the relative effectiveness of a gas to absorb infrared radiation and length of time that the gas remains in the atmosphere (“atmospheric lifetime”). The GWP of each gas is measured relative to carbon dioxide, the most abundant GHG; the definition of GWP for a particular GHG is the ratio of heat trapped by one unit mass of the GHG to the ratio of heat trapped by one unit mass of CO2 over a specified time period.

GHG emissions are typically measured in terms of pounds or tons of “CO2 equivalents” (CO2e). 18 The temperature on Earth is regulated by a system commonly known as the “greenhouse effect.” Just as the glass in a greenhouse lets heat from sunlight in and reduces the heat escaping, greenhouse gases like carbon dioxide, methane, and nitrous oxide in the atmosphere keep the Earth at a relatively even temperature. Without the greenhouse effect, the Earth would be a frozen globe; thus, although an excess of greenhouse gas results in global warming, the naturally occurring greenhouse effect is necessary to keep our planet at a comfortable temperature.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 21 Table C shows the GWP for each type of GHG. For example, sulfur hexafluoride is 22,800 times more potent at contributing to global warming than carbon dioxide.

Table C: Global Warming Potential of Greenhouse Gases
Gas
Atmospheric Lifetime
(Years)
Global Warming Potential
(100-Year Time Horizon)
Carbon Dioxide 50-200 1
Methane 12 25
Nitrous Oxide 114 298
HFC-23 270 14,800
HFC-134a 14 1,430
HFC-152a 1.4 124
PFC: Tetrafluoromethane (CF4) 50,000 7,390
PFC: Hexafluoromethane (C2F6) 10,000 12,200
Sulfur Hexafluoride (SF6) 3,200 22,800
Source: Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the IPCC (Intergovernmental Panel on Climate Change, 2007).

The following discussion summarizes the characteristics of the six GHGs and black carbon.

Carbon Dioxide
In the atmosphere, carbon generally exists in its oxidized form, as CO2. Natural sources of CO2 include the respiration (breathing) of humans, animals and plants, volcanic out gassing, decomposition of organic matter and evaporation from the oceans. Human caused sources of CO2 include the combustion of fossil fuels and wood, waste incineration, mineral production, and deforestation. Natural sources release approximately 150 billion tons of CO2 each year, far outweighing the 7 billion tons of man-made emissions of CO2 each year. Nevertheless, natural removal processes, such as photosynthesis by land- and ocean-dwelling plant species, cannot keep pace with this extra input of man-made CO2, and consequently, the gas is building up in the atmosphere.

In 2019, total annual CO2 accounted for approximately 83 percent of California's overall GHG emissions.19 Transportation is the single largest source of CO2 in California, which is primarily comprised of on-road travel. Electricity production, industrial and residential sources also make important contributions to CO2 emissions in California.

Methane
Methane is produced when organic matter decomposes in environments lacking sufficient oxygen.

Natural sources include wetlands, termites, and oceans. Decomposition occurring in landfills accounts for the majority of human-generated CH4 emissions in California and in the United States as a whole. Agricultural processes such as intestinal fermentation, manure management, and rice 19 CARB. 2021. GHGs Descriptions & Sources in California. Website: ww2.arb.ca.gov/ghg-descriptionssources (accessed April 2022).

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 22 cultivation are also significant sources of CH4 in California. Total annual emissions of CH4 accounted for approximately 9 percent of GHG emissions in California. 20 Nitrous Oxide
Nitrous oxide is produced naturally by a wide variety of biological sources, particularly microbial action in soils and water. Tropical soils and oceans account for the majority of natural source emissions. Nitrous oxide is a product of the reaction that occurs between nitrogen and oxygen during fuel combustion. Both mobile and stationary combustion emit N2O, and the quantity emitted varies according to the type of fuel, technology, and pollution control device used, as well as maintenance and operating practices. Agricultural soil management and fossil fuel combustion are the primary sources of human-generated N2O emissions in California. Nitrous oxide emissions accounted for approximately 3 percent of GHG emissions in California in 2019. 21 Hydrofluorocarbons, Perfluorocarbons, and Sulfur Hexafluoride HFCs are primarily used as substitutes for ozone-depleting substances regulated under the Montreal Protocol.22 PFCs and SF6 are emitted from various industrial processes, including aluminum smelting, semiconductor manufacturing, electric power transmission and distribution, and magnesium casting. There is no aluminum or magnesium production in California; however, the rapid growth in the semiconductor industry leads to greater use of PFCs. HFCs, PFCs, and SF6 accounted for about 5 percent of GHG emissions in California in 2019.
23 Black Carbon
Black carbon is the most strongly light-absorbing component of PM formed by burning fossil fuels such as coal, diesel, and biomass. Black carbon is emitted directly into the atmosphere in the form of PM2.5 and is the most effective form of PM, by mass, at absorbing solar energy. Per unit of mass in the atmosphere, black carbon can absorb one million times more energy than CO2. 24 Black carbon
contributes to climate change both directly, such as absorbing sunlight, and indirectly, such as affecting cloud formation. However, because black carbon is short-lived in the atmosphere, it can be difficult to quantify its effect on global warming.

Most U.S. emissions of black carbon come from mobile sources (52 percent), particularly from diesel-fueled vehicles. The other major source of black carbon is open biomass burning, including wildfires, although residential heating and industry also contribute. The CARB estimates that the 20 CARB. 2021. GHGs Descriptions & Sources in California. Website: ww2.arb.ca.gov/ghg-descriptionssources (accessed April 2022). 21 Ibid. 22 The Montreal Protocol is an international treaty that was approved on January 1, 1989, and was designated to protect the ozone layer by phasing out the production of several groups of halogenated hydrocarbons believed to be responsible for ozone depletion. 23 CARB. 2021. op. cit. 24 U.S. Environmental Protection Agency (USEPA). 2015. Black Carbon, Basic Information. February 14, 2017.

Website: 19january2017snapshot.epa.gov/www3/airquality/blackcarbon/basic.html (accessed April 2022).

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 23 annual black carbon emissions in California will be reduced approximately 50 percent below 2013 levels by 2030.25
Effects of Global Climate Change
Effects from global climate change may arise from temperature increases, climate-sensitive diseases, extreme weather events, and air quality. There may be direct temperature effects through increases in average temperature leading to more extreme heat waves and less extreme cold spells.

Those living in warmer climates are likely to experience more stress and heat-related problems.

Heat-related problems include heat rash and heat stroke. In addition, climate-sensitive diseases may increase, such as those spread by mosquitoes and other disease-carrying insects. Such diseases include malaria, dengue fever, yellow fever, and encephalitis. Extreme events such as flooding and hurricanes can displace people and agriculture. Global climate change may also contribute to air quality problems from increased frequency of smog and particulate air pollution.26 Additionally, according to the 2006 California Climate Action Team (CAT) Report,27 the following applicable climate change effects, which are based on trends established by the United Nations Intergovernmental Panel on Climate Change (IPCC), can be expected in California over the course of the next century:
• The loss of sea ice and mountain snow-pack, resulting in higher sea levels and higher sea surface evaporation rates with a corresponding increase in tropospheric water vapor due to the atmosphere’s ability to hold more water vapor at higher temperatures.28 • Rise in global average sea level, primarily due to thermal expansion and melting of glaciers and ice caps in the Greenland and Antarctic ice sheets.29
• Changes in weather that include widespread changes in precipitation, ocean salinity, wind patterns, and more energetic aspects of extreme weather, including droughts, heavy precipitation, heat waves, extreme cold, and the intensity of tropical cyclones.30 • Decline of the Sierra snowpack, which accounts for approximately one-half of the surface water storage in California by 70 percent to as much as 90 percent over the next 100 years.31 25 CARB. 2017. Short-Lived Climate Pollutant Reduction Strategy. March. Website: https://ww2.arb.ca.gov/ sites/default/files/2020-07/final_SLCP_strategy.pdf (accessed April 2022). 26 USEPA. 2016. Climate Impacts on Human Health. April. Website: https://19january2017snapshot.epa.gov/ climate-impacts/climate-impacts-human-health_.html, last updated on February 24, 2017 (accessed April 2022). 27 California Environmental Protection Agency (CalEPA). 2006. Climate Action Team Report to Governor Schwarzenegger and the Legislature. March. 28 Ibid. 29 Ibid. 30 Intergovernmental Panel on Climate Change (IPCC). 2007. Climate Change 2007: The Physical Science Basis, Summary for Policymakers. February. 31 CalEPA. 2006, op. cit.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 24 • Increase in the number of days conducive to O3 formation by 25–85 percent (depending on the future temperature scenario) in high O3 areas by the end of the 21st century.32 • High potential for erosion of California’s coastlines and seawater intrusion into the Delta and levee systems due to the rise in sea level.33
A summary of these potential effects are identified in Table D.

AIR QUALITY REGULATORY SETTING
The USEPA and the CARB regulate direct emissions from motor vehicles. The SJVAPCD is the regional agency primarily responsible for regulating air pollution emissions from stationary sources (e.g., factories) and indirect sources (e.g., traffic associated with new development), as well as monitoring ambient pollutant concentrations.

Federal Regulations
The 1970 Federal Clean Air Act (FCCA) authorized the establishment of national health-based air quality standards and also set deadlines for their attainment. The Federal Clean Air Act Amendments of 1990 changed deadlines for attaining national standards as well as the remedial actions required of areas of the nation that exceed the standards. Under the Clean Air Act, State and local agencies in areas that exceed the national standards are required to develop State Implementation Plans to demonstrate how they will achieve the national standards by specified dates.

State Regulations
California Clean Air Act
In 1988, the California Clean Air Act (CCAA) required that all air districts in the State endeavor to achieve and maintain CAAQS for carbon monoxide, ozone, sulfur dioxide, and nitrogen dioxide by the earliest practical date. The California Clean Air Act provides districts with authority to regulate indirect sources and mandates that air quality districts focus particular attention on reducing emissions from transportation and area-wide emission sources. Each nonattainment district is required to adopt a plan to achieve a 5 percent annual reduction, averaged over consecutive 3-year periods, in district-wide emissions of each nonattainment pollutant or its precursors. A Clean Air Plan shows how a district would reduce emissions to achieve air quality standards. Generally, the State standards for these pollutants are more stringent than the national standards.

California Air Resources Board
The CARB is the State’s “clean air agency.” The CARB’s goals are to attain and maintain healthy air quality, protect the public from exposure to toxic air contaminants, and oversee compliance with air pollution rules and regulations.
32 CalEPA. 2006, op. cit. 33 Ibid.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 25 Table D: Potential Impacts of Global Warming and Expected Consequences for California
Potential Water Resource
Impacts Anticipated Consequences Statewide
Reduction of the State’s average
annual snowpack
• Specifically, the decline of the Sierra snowpack would lead to a loss in half of the surface water storage in California by 70% to 90% over the next 100 years • Potential loss of 5 million acre-feet or more of average annual water storage in the State’s snowpack
• Increased challenges for reservoir management and balancing the competing concerns of flood protection and water supply
• Higher surface evaporation rates with a corresponding increase in tropospheric water vapor
Rise in average sea level • Potential economic impacts related to coastal tourism, commercial fisheries, coastal agriculture, and ports
• Increased risk of flooding, coastal erosion along the State’s coastline, seawater intrusion into the Delta and levee systems
Changes in weather • Changes in precipitation, ocean salinity, and wind patterns • Increased likelihood for extreme weather events, including droughts, heavy precipitation, heat waves, extreme cold, and the intensity of tropical cyclones Changes in the timing, intensity,
location, amount, and variability
of precipitation
• Potential increased storm intensity and increased potential for flooding • Possible increased potential for droughts
• Long-term changes in vegetation and increased incidence of wildfires • Changes in the intensity and timing of runoff
• Possible increased incidence of flooding and increased sedimentation • Sea level rise and inundation of coastal marshes and estuaries • Increased potential for salinity intrusion into coastal aquifers (groundwater) • Increased potential for flooding near the mouths of rivers due to backwater effects Increased water temperatures • Increased environmental water demand for temperature control • Possible increased problems with foreign invasive species in aquatic ecosystems • Potential adverse changes in water quality, including the reduction of dissolved oxygen levels
• Possible critical effects on listed and endangered aquatic species Changes in urban and agricultural
water demand
• Changes in demand patterns and evapotranspiration
Increase in the number of days
conducive to O3 formation
• Increased temperatures
• Potential health effects, including adverse impacts to respiratory systems Source: United States Department of the Interior, Environmental Water Account, Draft Supplemental EIS/EIR to the Environmental Water Account Final EIS/EIR, Bureau of Reclamation Mid-Pacific Region, Sacramento, California (October 2007).

EIR = Environmental Impact Report
EIS = Environmental Impact Statement
O3 = ozone
Assembly Bill 2588 Air Toxics “Hot Spots” Information and Assessment Act. Under Assembly Bill (AB) 2588, stationary sources of air pollutants are required to report the types and quantities of certain substances their facilities routinely released into the air. The goals of the Air Toxics “Hot Spots” Act are to collect emission data, identify facilities having localized impacts, determine health risks, and notify nearby residents of significant risks.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 26 The California Air Resources Board Handbook. The CARB has developed an Air Quality and Land Use Handbook34which is intended to serve as a general reference guide for evaluating and reducing air pollution impacts associated with new projects that go through the land use decision-making process. According to the CARB Handbook, air pollution studies have shown an association between respiratory and other non-cancer health effects and proximity to high traffic roadways. Other studies have shown that diesel exhaust and other cancer-causing chemicals emitted from cars and trucks are responsible for much of the overall cancer risk from airborne toxics in California. The CARB Handbook recommends that county and city planning agencies strongly consider proximity to these sources when finding new locations for “sensitive” land uses such as homes, medical facilities, daycare centers, schools, and playgrounds.

Land uses that can produce air pollution sources of concern include freeways, rail yards, ports, refineries, distribution centers, chrome plating facilities, dry cleaners, and large gasoline service stations. Key recommendations in the CARB Handbook include taking steps to avoid siting new, sensitive land uses:
• Within 500 feet of a freeway, urban roads with 100,000 vehicles/day or rural roads with 50,000 vehicles/day;
• Within 1,000 feet of a major service and maintenance rail yard; • Immediately downwind of ports (in the most heavily impacted zones) and petroleum refineries; • Within 300 feet of any dry cleaning operation (for operations with two or more machines, provide 500 feet); and
• Within 300 feet of a large gas station (defined as a facility with a throughput of 3.6 million gallons per year or greater).

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

The recommendations are generalized and do not consider site-specific meteorology, freeway truck percentages, or other factors that influence risk for a particular project site. The purpose of this guidance is to help land use agencies determine when to further examine project sites for actual health risk associated with the location of new sensitive land uses.

Regional Regulations
The SJVAPCD has specific air quality-related planning documents, rules, and regulations. This section summarizes the local planning documents and regulations that may be applicable to the proposed project as administered by the SJVAPCD with CARB oversight. 34 CARB. 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 27 Rule 2280—Portable Equipment Registration
Portable equipment used at project sites for less than six consecutive months must be registered with the SJVAPCD. The SJVAPCD will issue the registrations 30 days after receipt of the application.35 Rule 2303—Mobile Source Emission Reduction Credits
A project may qualify for SJVAPCD vehicle emission reduction credits if it meets the specific requirements of Rule 2303 for any of the following categories: 36 • Low-Emission Transit Buses
• Zero-Emission Vehicles
• Retrofit Passenger Cars, Light-Duty Trucks, and Medium-Duty Vehicles • Retrofit Heavy-Duty Vehicles
Rule 4201 and Rule 4204—Particulate Matter Concentration and Emission Rates Rule 4201 and Rule 4202 apply to operations that emit or may emit dust, fumes, or total suspended particulate matter.37
Rule 8011—General Requirements: Fugitive Dust Emission Sources Fugitive dust regulations are applicable to outdoor fugitive dust sources. Operations, including construction operations, must control fugitive dust emissions in accordance with SJVAPCD Regulation VIII. According to Rule 8011, the SJVAPCD requires the implementation of control measures for fugitive dust emission sources. For projects in which construction-related activities would disturb equal to or greater than 1 acre of surface area, the SJVAPCD recommends that demonstration of receipt of an SJVAPCD-approved Dust Control Plan or Construction Notification Form, before issuance of the first grading permit, be made a condition of approval.

Rule 9510—Indirect Source Review
In December 2005, the SJVAPCD adopted the Indirect Source Rule (Rule 9510) to meet its emission reduction commitments in the PM10 and O3 Attainment Plans. Indirect Source Review regulation applies to any development project that includes at least 2,000 square feet of commercial space.

This Rule requires project applicants to reduce operation emission of NOx by 33.3 percent of the project’s operational baseline and 50 percent of the project’s operational PM10 emissions.

Guidance for Assessing and Mitigating Air Quality Impacts The SJVAPCD prepared the GAMAQI to assist lead agencies and project applicants in evaluating the potential air quality impacts of projects in the San Joaquin Valley Air Basin (SJVAB). The GAMAQI provides SJVAPCD-recommended procedures for evaluating potential air quality impacts during the 35 San Joaquin Valley Air Pollution Control District. 1996. Rule 2280 Portable Equipment Registration.

Amended May 16. 36 Ibid. 37 San Joaquin Valley Air Pollution Control District, 1992. Rule 4202 Particulate Matter – Emission Rate.

Amended December 17, 1992.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 28 CEQA environmental review process. The GAMAQI provides guidance on evaluating short-term (construction) and long-term (operational) air emissions. The most recent version of the GAMAQI, adopted March 19, 2015, was used in this evaluation. It contains guidance on the following:
• Criteria and thresholds for determining whether a project may have a significant adverse air quality impact;
• Specific procedures and modeling protocols for quantifying and analyzing air quality impacts; • Methods to mitigate air quality impacts; and
• Information for use in air quality assessments and environmental documents, including air quality, regulatory setting, climate, and topography data.

Regional Air Quality Management Plan
The SJVAPCD is responsible for formulating and implementing the Air Quality Management Plan (AQMP) for the SJVAB. The main purpose of an AQMP is to bring the area into compliance with federal and State air quality standards. The SJVAPCD does not have one single AQMP for criteria pollutants, rather the SJVAPCD address each criteria pollutant with its own Plan. The SJVAPCD has the following AQMPs:
• 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards • 2016 Moderate Area Plan for the 2012 PM2.5 Standard
• 2016 Plan for the 2008 8-Hour Ozone Standard
• 2013 Plan for the Revoked 1-Hour Ozone Standard
• 2007 PM10 Maintenance Plan
• 2004 Revision to the California State Implementation Plan for Carbon Monoxide The SJVAPCD’s AQMPs incorporate the latest scientific and technological information and planning assumptions, including updated emission inventory methodologies for various source categories.

The SJVAPCD’s AQMPs included the integrated strategies and measures needed to meet the National Ambient Air Quality Standards (NAAQS), implementation of new technology measures, and demonstrations of attainment of the 1-hour and 8-hour ozone NAAQS as well as the latest 24-hour and annual PM2.5 standards.

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

Ozone Plans. The SJVAPCD’s Governing Board approved the 2016 Plan for the 2008 8-Hour Ozone Standard on June 16, 2016. The comprehensive strategy in this plan will reduce NOx emissions by over 60 percent between 2012 and 2031, and will bring the San Joaquin Valley into attainment of USEPA’s 2008 8-hour ozone standard as expeditiously as practicable, no later than December 31, 2031.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 29 Particulate Matter Plans. The SJVAPCD adopted the 2007 PM10 Maintenance Plan in September 2007 to assure the SJVAB’s continued attainment of the USEPA’s PM10 standard. The USEPA designated the valley as an attainment/maintenance area for PM10.

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

The 2008 PM2.5 Plan is a continuation of the SJVAPCD’s strategy to improve the air quality in the SJVAB.

The SJVAPCD prepared the 2012 PM2.5 Plan to bring the San Joaquin Valley into attainment of the USEPA’s most recent 24‐hour PM2.5 standard of 35 μg/m³. The CARB approved the SJVAPCD’s 2012 PM2.5 Plan at a public hearing on January 24, 2013. The plan, approved by the SJVAPCD Governing Board on December 20, 2012, will bring the Valley into attainment of USEPA’s 1997 PM2.5 standard as expeditiously as practicable, but no later than, December 31, 2020.

The SJVAPCD adopted the 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards on November 15, 2018. This plan addresses the USEPA federal 1997 annual PM2.5 standard of 15 μg/m³ and 24-hour PM2.5 standard of 65 μg/m³; the 2006 24-hour PM2.5 standard of 35 μg/m³; and the 2012 annual PM2.5 standard of 12 μg/m³. This plan demonstrates attainment of the federal PM2.5 standards as expeditiously as practicable.

Local Regulations
Air quality is addressed in the City of Fresno General Plan, adopted on December 18, 2014. The General Plan includes goals, policies, and implementing actions that work toward clean air with minimal toxic substances and odor, clean air with minimal particulate content, effective and efficient transportation infrastructure, and coordinated and cooperative intergovernmental air quality programs. The following objective and implementing policies from the General Plan would be applicable to the proposed project.
• Objective RC‐4: In cooperation with other jurisdictions and agencies in the San Joaquin Valley Air Basin, take necessary actions to achieve and maintain compliance with State and federal air quality standards for criteria pollutants.
• Policy RC‐4‐a: Support Regional Efforts. Support and lead, where appropriate, regional, State and federal programs and actions for the improvement of air quality, especially the SJVAPCD’s efforts to monitor and control air pollutants from both stationary and mobile sources and implement Reasonably Available Control Measures in the Ozone Attainment Plan. • Policy RC‐4‐b: Conditions of Approval. Develop and incorporate air quality maintenance requirements, compatible with Air Quality Attainment and Maintenance Plans, as conditions of approval for General Plan amendments, community plans, Specific Plans, neighborhood plans, Concept Plans, and development proposals.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 30 • Policy RC‐4‐c: Evaluate Impacts with Models. Continue to require the use of computer models used by SJVAPCD to evaluate the air quality impacts of plans and projects that require such environmental review by the City.
• Policy RC‐4‐d: Forward Information. Forward information regarding proposed General Plan amendments, community plans, Specific Plans, neighborhood plans, Concept Plans, and development proposals that require air quality evaluation, and amendments to development regulations to the SJVAPCD for their review of potential air quality and health impacts. • Policy RC‐4‐k: Electric Vehicle Charging. Develop standards to facilitate electric vehicle charging infrastructure in both new and existing public and private buildings, in order to accommodate these vehicles as the technology becomes more widespread.

ENERGY REGULATORY SETTING
Federal and State agencies regulate energy use and consumption through various means and programs. On the federal level, the U.S. Department of Transportation (U.S. DOT), the United States Department of Energy, and the United States Environmental Protection Agency (USEPA) are three federal agencies with substantial influence over energy policies and programs. Generally, federal agencies influence and regulate transportation energy consumption through establishment and enforcement of fuel economy standards for automobiles and light trucks, through funding of energy-related research and development projects, and through funding for transportation infrastructure improvements. On the State level, the California Public Utilities Commission (CPUC) and the CEC are two agencies with authority over different aspects of energy.

The CPUC regulates privately owned electric, natural gas, telecommunications, water, railroad, rail transit, and passenger transportation companies and serves the public interest by protecting consumers and ensuring the provision of safe, reliable utility service and infrastructure at reasonable rates, with a commitment to environmental enhancement and a healthy California economy.

The CEC is the State's primary energy policy and planning agency. The CEC forecasts future energy needs, promotes energy efficiency, supports energy research, develops renewable energy resources, and plans for/directs state response to energy emergencies. The applicable federal, State, regional, and local regulatory framework is discussed below.

Federal Regulations
Energy Policy Act of 2005
The Energy Policy Act of 2005 seeks to reduce reliance on non-renewable energy resources and provide incentives to reduce current demand on these resources. For example, under this Act, consumers and businesses can obtain federal tax credits for purchasing fuel-efficient appliances and products (including hybrid vehicles), building energy-efficient buildings, and improving the energy efficiency of commercial buildings. Additionally, tax credits are available for the installation of qualified fuel cells, stationary microturbine power plants, and solar power equipment.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 31 Safer Affordable Fuel-Efficient Vehicles Rule
On March 21, 2020, the USEPA and National Highway Traffic Safety Administration (NHTSA) finalized the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021–2026 Passenger Cars and Light Trucks (SAFE Vehicles Rule). The SAFE Vehicles Rule amends certain existing Corporate Average Fuel Economy and tailpipe carbon dioxide (CO2) emissions standards for passenger cars and light trucks and establishes new standards, all covering model years 2021 through 2026. More specifically, the NHTSA set new Corporate Average Fuel Economy standards for model years 2022 through 2026 and amended its 2021 model year Corporate Average Fuel Economy standards, and the USEPA amended its CO2 emissions standards for model years 2021 and later.

State Regulations
Assembly Bill 1575, Warren-Alquist Act
In 1975, largely in response to the oil crisis of the 1970s, the State Legislature adopted Assembly Bill (AB) 1575 (also known as the Warren-Alquist Act), which created the CEC. The statutory mission of the CEC is to forecast future energy needs; license power plants of 50 megawatts (MW) or larger; develop energy technologies and renewable energy resources; plan for and direct State responses to energy emergencies; and, perhaps most importantly, promote energy efficiency through the adoption and enforcement of appliance and building energy efficiency standards. AB 1575 also amended Public Resources Code (PRC) Section 21100(b)(3) and State CEQA Guidelines Section 15126.4 to require Environmental Impact Reports (EIRs) to include, where relevant, mitigation measures proposed to minimize the wasteful, inefficient, and unnecessary consumption of energy caused by a project. Thereafter, the State Resources Agency created Appendix F to the State CEQA Guidelines. Appendix F assists EIR preparers in determining whether a project will result in the inefficient, wasteful, and unnecessary consumption of energy. Appendix F of the State CEQA Guidelines also states that the goal of conserving energy implies the wise and efficient use of energy and the means of achieving this goal, including (1) decreasing overall per capita energy consumption; (2) decreasing reliance on fossil fuels such as coal, natural gas, and oil; and (3) increasing reliance on renewable energy sources.

Senate Bill 1389, Energy: Planning and Forecasting
In 2002, the State Legislature passed Senate Bill (SB) 1389, which required the CEC to develop an integrated energy plan every 2 years for electricity, natural gas, and transportation fuels for the California Energy Policy Report. The plan calls for the State to assist in the transformation of the transportation system to improve air quality, reduce congestion, and increase the efficient use of fuel supplies with the least environmental and energy costs. To further this policy, the plan identifies a number of strategies, including assistance to public agencies and fleet operators in implementing incentive programs for zero emission vehicles (ZEVs) and their infrastructure needs, and encouragement of urban designs that reduce vehicle miles traveled (VMT) and accommodate pedestrian and bicycle access.

In compliance with the requirements of SB 1389, the CEC adopts an Integrated Energy Policy Report every 2 years and an update every other year. CEC approved the 2020 Integrated Energy Policy

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 32 Report in March 2021.38 The 2020 Integrated Energy Policy Report covers a broad range of topics, including decarbonizing buildings, integrating renewables, energy efficiency, energy equity, integrating renewable energy, updates on Southern California electricity reliability, climate adaptation activities for the energy sector, natural gas assessment, transportation energy demand forecast, and the California Energy Demand Forecast.

Renewable Portfolio Standard
SB 1078 established the California Renewable Portfolio Standards program in 2002. SB 1078 initially required that 20 percent of electricity retail sales be served by renewable resources by 2017; however, this standard has become more stringent over time. In 2006, SB 107 accelerated the standard by requiring that the 20 percent mandate be met by 2010. In April 2011, SB 2 required that 33 percent of electricity retail sales be served by renewable resources by 2020. In 2015, SB 350 established tiered increases to the Renewable Portfolio Standards of 40 percent by 2024, 45 percent by 2027, and 50 percent by 2030. In 2018, SB 100 increased the requirement to 60 percent by 2030 and required that all the State's electricity come from carbon-free resources by 2045. SB 100 took effect on January 1, 2019.39
Title 24, California Building Code
Energy consumption by new buildings in California is regulated by the Building Energy Efficiency Standards, embodied in Title 24 of the California Code of Regulations (CCR), known as the California Building Code (CBC). The CEC first adopted the Building Energy Efficiency Standards for Residential and Non-residential Buildings in 1978 in response to a legislative mandate to reduce energy consumption in the State. The CBC is updated every 3 years, and the current 2019 CBC went into effect on January 1, 2020. The efficiency standards apply to both new construction and rehabilitation of both residential and non-residential buildings, and regulate energy consumed for heating, cooling, ventilation, water heating, and lighting. The building efficiency standards are enforced through the local building permit process. Local government agencies may adopt and enforce energy standards for new buildings, provided these standards meet or exceed those provided in CCR Title 24.

California Green Building Standards Code (CALGreen Code) In 2010, the California Building Standards Commission (CBSC) adopted Part 11 of the Title 24 Building Energy Efficiency Standards, referred to as the California Green Building Standards Code (CALGreen Code). The CALGreen Code took effect on January 1, 2011. The CALGreen Code is updated on a regular basis, with the most recent update consisting of the 2019 CALGreen Code standards that became effective January 1, 2020. The CALGreen Code established mandatory measures for residential and non-residential building construction and encouraged sustainable construction practices in the following five categories: (1) planning and design, (2) energy efficiency, (3) water efficiency and conservation, (4) material conservation and resource efficiency, and (5) indoor environmental quality. Although the CALGreen Code was adopted as part of the State’s 38 CEC. 2020. 2020 Integrated Energy Policy Report. Docket No. 20-IEPR-01. 39 California Public Utilities Commission (CPUC). 2019. Renewables Portfolio Standard Program. Website:
cpuc.ca.gov/rps (accessed April 2022).

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 33 efforts to reduce greenhouse gas (GHG) emissions, the CALGreen Code standards have co-benefits of reducing energy consumption from residential and non-residential buildings subject to the standard.

Regional Regulations
There are no regional regulations that apply to the proposed project.

Local Regulations
Air quality is addressed in the City of Fresno General Plan, adopted on December 18, 2014. The General Plan includes goals, policies, and implementing actions that work to reduce the potential use of electricity, natural gas, and fuel. The following implementing policies from the General Plan would be applicable to the proposed project.
• Policy RC-4-e: Support Employer-Based Efforts. Support and promote employer implementation of staggered work hours and employee incentives to use carpools, public transit, and other measures to reduce vehicular use and traffic congestion. • Policy RC‐5‐c: GHG Reduction through Design and Operations. Increase efforts to incorporate requirements for GHG emission reductions in land use entitlement decisions, facility design, and operational measures subject to City regulation through the following measures and strategies:
○ Promote the expansion of incentive-based programs that involve certification of projects for energy and water efficiency and resiliency. These certification programs and scoring systems may include public agency “Green” and conservation criteria, Energy Star™ certification, CALGreen Tier 1 or Tier 2, Leadership in Energy and Environmental Design (LEED™) certification, etc.
○ Promote appropriate energy and water conservation standards and facilitate mixed-use projects, new incentives for infill development, and the incorporation of mass transit, bicycle and pedestrian amenities into public and private projects. ○ Require energy and water audits and upgrades for water conservation, energy efficiency, and mass transit, pedestrian, and bicycle amenities at the time of renovation, change in use, change in occupancy, and change in ownership for major projects meeting review thresholds specified in an implementing ordinance.
○ Incorporate the City’s “Guidelines for Ponding Basin/Pond Construction and Management to Control Mosquito Breeding” as conditions of approval for any project using an on-site stormwater basin to prevent possible increases in vector-borne illnesses associated with global climate change.
○ Periodically evaluate the City’s facility maintenance practices to determine whether there are additional opportunities to reduce GHGs through facility cleaning and painting, parks maintenance, road maintenance, and utility system maintenance.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 34 ○ Periodically evaluate standards and mitigation strategies for highly vehicle-dependent land uses and facilities, such as drive-through facilities and auto-oriented development. • Policy RC‐8‐a: Existing Standards and Programs. Continue existing beneficial energy conservation programs, including adhering to the California Energy Code in new construction and major renovations.
• Policy RC-8-b: Energy Reduction Targets. Strive to reduce per capita residential electricity use to 1,800 kWh per year and non-residential electricity use to 2,700 kWh per year per capita by developing and implementing incentives, design and operation standards, promoting alternative energy sources, and cost-effective savings.
• Policy RC-8-c: Energy Conservation in New Development. Consider providing an incentive program for new buildings that exceed California Energy Code requirements by fifteen percent.

GLOBAL CLIMAGE CHANGE REGULATION
This section describes regulations related to Global Climate Change at the federal, State, and local level.

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

This includes the 2009 USEPA final rule for mandatory reporting of GHGs from large GHG emission sources in the United States. Additionally, the USEPA Administrator signed an endangerment finding action in 2009 under the Clean Air Act, finding that six GHGs (CO2, CH4, N2O, HFCs, PFCs, SF6) constitute a threat to public health and welfare, and that the combined emissions from motor vehicles cause and contribute to global climate change, leading to national GHG emission standards.

In October 2012, the USEPA and the National Highway Traffic Safety Administration (NHTSA), on behalf of the U.S. Department of Transportation, issued final rules to further reduce GHG emissions and improve corporate average fuel economy (CAFE) standards for light-duty vehicles for model years 2017 and beyond (77 Federal Register 62624). The NHTSA’s CAFE standards have been enacted under the Energy Policy and Conservation Act since 1978. This national program requires automobile manufacturers to build a single light-duty national fleet that meets all requirements under both federal programs and the standards of California and other states. This program would increase fuel economy to the equivalent of 54.5 miles per gallon, limiting vehicle emissions to 163 grams of CO2 per mile for the fleet of cars and light-duty trucks by model year 2025 (77 Federal Register 62630).

On March 21, 2020, the USEPA and NHTSA finalized the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021–2026 Passenger Cars and Light Trucks (SAFE Vehicles Rule). The

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 35 SAFE Vehicles Rule amends certain existing CAFE and tailpipe CO2 emissions standards for passenger cars and light trucks and establish new standards, all covering model years 2021 through 2026. More specifically, NHTSA set new CAFE standards for model years 2022 through 2026 and amended its 2021 model year CAFE standards, and the USEPA amended its CO2 emissions standards for model years 2021 and later. On May 12, 2021, the NHTSA published a notice of proposed rulemaking in the Federal Register, proposing to repeal key portions of the SAFE Vehicles Rule that would have reduced CAFE standards. The final rule repealing portions of the SAFE Vehicles Rule was published on December 29, 2021. The repeal will allow California to set its own GHG standards if it chooses, even if the emissions standards conflict with CAFE standards enacted by the U.S. Department of Transportation.

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

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

Executive Order S-3-05 (2005)
Governor Arnold Schwarzenegger signed Executive Order (EO) S-3-05 on June 1, 2005, which proclaimed that California is vulnerable to the impacts of climate change. To combat those concerns, the executive order established California’s GHG emissions reduction targets, which established the following goals:
• GHG emissions should be reduced to 2000 levels by 2010; • GHG emissions should be reduced to 1990 levels by 2020; and • GHG emissions should be reduced to 80 percent below 1990 levels by 2050.

The Secretary of the California Environmental Protection Agency (CalEPA) is required to coordinate efforts of various State agencies in order to collectively and efficiently reduce GHGs. A biannual progress report must be submitted to the Governor and State Legislature disclosing the progress made toward GHG emission reduction targets. In addition, another biannual report must be submitted illustrating the impacts of global warming on California’s water supply, public health, agriculture, the coastline, and forestry, and report possible mitigation and adaptation plans to address these impacts.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 36 The Secretary of CalEPA leads this CAT made up of representatives from State agencies as well as numerous other boards and departments. The CAT members work to coordinate statewide efforts to implement global warming emission reduction programs and the State’s Climate Adaptation Strategy. The CAT is also responsible for reporting on the progress made toward meeting the statewide GHG targets that were established in the executive order and further defined under AB 32, the “Global Warming Solutions Act of 2006.” The first CAT Report to the Governor and the Legislature was released in March 2006, which it laid out 46 specific emission reduction strategies for reducing GHG emissions and reaching the targets established in the Executive Order. The most recent report was released in December 2020.

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

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

On August 24, 2011, the CARB unanimously approved both the new supplemental assessment and reapproved its Scoping Plan, which provides the overall roadmap and rule measures to carry out AB 32. The CARB also approved a more robust CEQA equivalent document supporting the supplemental analysis of the cap-and-trade program. The cap-and-trade took effect on January 1, 2012, with an enforceable compliance obligation that began January 1, 2013.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 37 CARB has not yet determined what amount of GHG reductions it recommends from local government operations and local land use decisions; however, the Scoping Plan states that land use planning and urban growth decisions will play an important role in the State’s GHG reductions because local governments have primary authority to plan, zone, approve, and permit how land is developed to accommodate population growth and the changing needs of their jurisdictions (meanwhile, CARB is also developing an additional protocol for community emissions). CARB further acknowledges that decisions on how land is used will have large impacts on the GHG emissions that will result from the transportation, housing, industry, forestry, water, agriculture, electricity, and natural gas emission sectors. The Scoping Plan states that the ultimate GHG reduction assignment to local government operations is to be determined. With regard to land use planning, the Scoping Plan expects an approximately 5.0 MMT CO2e reduction due to implementation of SB 375.

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

In June 2007, the CARB approved a list of 37 early action measures, including three discrete early action measures (LCFS, Restrictions on GWP Refrigerants, and Landfill CH4 Capture).40 Discrete early action measures are measures that were required to be adopted as regulations and made effective no later than January 1, 2010, the date established by Health and Safety Code Section 38560.5. The CARB adopted additional early action measures in October 2007 that tripled the number of discrete early action measures. These measures relate to truck efficiency, port electrification, reduction of PFCs from the semiconductor industry, reduction of propellants in consumer products, proper tire inflation, and SF6 reductions from the non-electricity sector. The combination of early action measures is estimated to reduce statewide GHG emissions by nearly 16 MMT.41 The CARB approved the First Update to the Climate Change Scoping Plan on May 22, 2014. The First Update identifies opportunities to leverage existing and new funds to further drive GHG emission reductions through strategic planning and targeted low carbon investments. The First Update defines CARB climate change priorities until 2020, and also sets the groundwork to reach long-term goals set forth in EOs S-3-05 and B-16-2012. The Update highlights California’s progress toward meeting the “near-term” 2020 GHG emission reduction goals as defined in the initial Scoping Plan. It also evaluates how to align the State’s “longer-term” GHG reduction strategies with other State policy priorities for water, waste, natural resources, clean energy, transportation, and land use. 40 CARB. 2007. Expanded List of Early Action Measures to Reduce Greenhouse Gas Emissions in California Recommended for Board Consideration. October. 41 CARB. 2007. “ARB approves tripling of early action measures required under AB 32” News Release 07-46.

October 25.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 38 CARB released a second update to the Scoping Plan, the 2017 Scoping Plan, 42 to reflect the 2030
target set by EO B-30-15 and codified by SB 32.

CARB is currently working on an update to the 2017 Scoping Plan, which will be released this year.

The 2022 Scoping Plan Update will assess progress towards achieving the SB 32 2030 target and lay out a path to achieve carbon neutrality no later than 2045.

Senate Bill 97 (2007)
SB 97, signed by the Governor in August 2007 (Chapter 185, Statutes of 2007; Public Resources Code [PRC], Sections 21083.05 and 21097), acknowledges climate change is a prominent environmental issue that requires analysis under CEQA. This bill directed the Governor’s Office of Planning and Research (OPR) to prepare, develop, and transmit to the California Resources Agency guidelines for mitigating GHG emissions or the effects of GHG emissions, as required by CEQA.

The California Natural Resources Agency adopted the amendments to the State CEQA Guidelines in November 2018, which went into effect in December 2018. The amendments do not identify a threshold of significance for GHG emissions, nor do they prescribe assessment methodologies or specific mitigation measures. The amendments encourage lead agencies to consider many factors in performing a CEQA analysis, but preserve the discretion granted by CEQA to lead agencies in making their own determinations based on substantial evidence. The amendments also encourage public agencies to make use of programmatic mitigation plans and programs when they perform individual project analyses.

Senate Bill 375 (2008)
SB 375, the Sustainable Communities and Climate Protection Act, which establishes mechanisms for the development of regional targets for reducing passenger vehicle GHG emissions, was adopted by the State on September 30, 2008. On September 23, 2010, the CARB adopted the vehicular GHG emissions reduction targets that had been developed in consultation with the Metropolitan Planning Organization (MPOs); the targets require a 6 to 15 percent reduction by 2020 and between 13 to 19 percent reduction by 2035 for each MPO. SB 375 recognizes the importance of achieving significant GHG reductions by working with cities and counties to change land use patterns and improve transportation alternatives. Through the SB 375 process, MPOs such as the Fresno Council of Governments will work with local jurisdictions in the development of Sustainable Communities Strategy (SCS) designed to integrate development patterns and the transportation network in a way that reduces GHG emissions while meeting housing needs and other regional planning objectives.

Pursuant to SB 375, the Central Valley/San Joaquin reduction targets for per capita vehicular emissions were 6-13 percent by 2020 and are 13-16 percent by 2035 as shown in Table E. 42 CARB. 2017. California’s 2017 Climate Change Scoping Plan. November.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 39 Table E: Senate Bill 375 Regional Greenhouse Gas Emissions Reduction Targets
Metropolitan Planning Organization By 2020 (percent) By 2035 (percent) San Francisco Bay Area 10 19
San Diego 15 19
Sacramento 7 19
Central Valley/San Joaquin 6-13 13-16
Los Angeles/Southern California 8 19
Source: California Air Resources Board (2018).

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

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

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

The 50 percent renewable energy standard will be implemented by the CPUC for the private utilities and by the CEC for municipal utilities. Each utility must submit a procurement plan showing it will purchase clean energy to displace other non-renewable resources. The 50 percent increase in energy efficiency in buildings must be achieved through the use of existing energy efficiency retrofit funding and regulatory tools already available to state energy agencies under existing law. The addition made by this legislation requires state energy agencies to plan for, and implement those programs in a manner that achieves the energy efficiency target.

Senate Bill 32, California Global Warming Solutions Act of 2016, and Assembly Bill 197 In summer 2016 the Legislature passed, and the Governor signed, SB 32, and AB 197. SB 32 affirms the importance of addressing climate change by codifying into statute the GHG emissions reductions target of at least 40 percent below 1990 levels by 2030 contained in Governor Brown’s April 2015 EO B-30-15. SB 32 builds on AB 32 and keeps us on the path toward achieving the State’s 2050 objective of reducing emissions to 80 percent below 1990 levels, consistent with an IPCC analysis of

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 40 the emissions trajectory that would stabilize atmospheric GHG concentrations at 450 parts per million CO2e and reduce the likelihood of catastrophic impacts from climate change.

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

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

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

Title 24, Part 11, Building Standards Code and CALGreen Code In November 2008, the California Building Standards Commission established the California Green Building Standards Code (CALGreen Code), which sets performance standards for residential and non-residential development to reduce environmental impacts and encourage sustainable construction practices. The CALGreen Code addresses energy efficiency, water conservation, material conservation, planning and design, and overall environmental quality. The CALGreen Code is updated every 3 years and was most recently updated in 2019 to include new mandatory measures for residential as well as non-residential uses; the new measures took effect on January 1, 2020. The next set of standards will be adopted in 2022 and apply to projects seeking building permits on or after January 1, 2023.

California Building Efficiency Standards (Title 24, Part 6) The California Building Standards Code, or Title 24 of the California Code of Regulations (CCR) contains the regulations that govern the construction of buildings in California. Within the Building Standards Code, two parts pertain to the incorporation of both energy efficient and green building elements into land use development. Part 6 is California’s Energy Efficiency Standards for Residential and Non-Residential Buildings. These standards were first adopted in 1978 in response to a legislative mandate to reduce California’s energy consumption and are updated on an

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 41 approximately 3-year cycle to allow consideration and possible incorporation of new energy efficient technologies and methods. All buildings for which an application for a building permit is submitted on or after January 1, 2020, must follow the 2019 standards. The next set of standards is anticipated for release in 2022. Energy efficient buildings require less electricity; therefore, increased energy efficiency reduces fossil fuel consumption and decreases GHG emissions.

Cap and Trade
The development of a cap-and-trade program was included as a key reduction measure of the CARB AB 32 Climate Change Scoping Plan. The cap-and-trade program will help put California on the path to meet its goal of reducing GHG emissions to 1990 levels by 2020 and ultimately achieving an 80 percent reduction from 1990 levels by 2050. The cap-and-trade emissions trading program developed by the CARB took effect on January 1, 2012, with enforceable compliance obligations beginning January 1, 2013. The cap-and-trade program aims to regulate GHG emissions from the largest producers in the State by setting a statewide firm limit, or cap, on allowable annual GHG emissions. The cap was set in 2013 at approximately 2 percent below the emissions forecast for 2020. In 2014, the cap declined approximately 2 percent. Beginning in 2015 and continuing through 2020, the cap has been declining approximately 3 percent annually. The CARB administered the first auction on November 14, 2012, with many of the qualified bidders representing corporations or organizations that produce large amounts of GHG emissions, including energy companies, agriculture and food industries, steel mills, cement companies, and universities. On January 1, 2015, compliance obligation began for distributors of transportation fuels, natural gas, and other fuels.

The cap-and-trade program was initially slated to sunset in 2020 but the passage of SB 398 in 2017 extended the program through 2030.

Executive Order N-79-20
EO N-79-20, which was signed by the Governor on September 23, 2020, sets the following goals for the State: 100 percent of in-state sales of new passenger cars and trucks shall be zero-emission by 2035; 100 percent of medium- and heavy-duty vehicles in the State shall be zero-emission by 2045 for all operations where feasible and by 2035 for drayage trucks; and 100 percent of off-road vehicles and equipment in the State shall be zero-emission by 2035, where feasible.

California Integrated Waste Management Act
To minimize the amount of solid waste that must be disposed of in landfills, the State Legislature passed the California Integrated Waste Management Act of 1989 (AB 939), effective January 1990.

According to AB 939, all cities and counties were required to divert 25 percent of all solid waste from landfill facilities by January 1, 1995, and 50 percent by January 1, 2000. Through other statutes and regulations, this 50 percent diversion rate also applies to State agencies. In order of priority, waste reduction efforts must promote source reduction, recycling and composting, and environmentally safe transformation and land disposal. In 2011, AB 341 modified the California Integrated Waste Management Act and directed the California Department of Resources Recycling and Recovery (CalRecycle) to develop and adopt regulations for mandatory commercial recycling.

The resulting 2012 Mandatory Commercial Recycling Regulation requires that on and after July 1, 2012, certain businesses that generate four cubic yards or more of commercial solid waste per week shall arrange recycling services. To comply with this requirement, businesses may either separate

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 42 recyclables and self-haul them or subscribe to a recycling service that includes mixed waste processing. AB 341 also established a statewide recycling goal of 75 percent; the 50 percent disposal reduction mandate still applies for cities and counties under AB 939, the Integrated Waste Management Act. In April 2016, AB 1826 further modified the California Integrated Waste Management Act, requiring businesses that generate a specified amount of organic waste per week to arrange for recycling services for that organic waste in a specified manner. If CalRecycle determines that statewide disposal of organic waste has not been reduced by 50 percent below 2014 levels by 2020, businesses generating more than two cubic yards of organic waste per week would be subject to these waste collection requirements. CalRecycle plans to make this assessment in the fall of 2020. Diverting organic waste from landfills reduces emissions of CH4. This is equivalent to reducing anaerobic decomposition of organic waste that would have otherwise occurred in landfills where organic waste is often buried with other inorganic waste.

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

In 2018, CARB approved amendments to the regulation to readjust carbon intensity benchmarks to meet California’s 2030 GHG reductions targets under SB 32. These amendments include opportunities to promote zero emission vehicle (ZEV) adoption, carbon capture and sequestration, and advanced technologies for decarbonization of the transportation sector.

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

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 43 implemented, the statewide fleet of new cars and light trucks will emit 40 percent fewer GHGs and 75 percent fewer smog-forming emissions than 2012 model year vehicles.

Executive Order B-48-18
In January 2018, Governor Brown signed EO B-48-18 requiring all State entities to work with the private sector to have at least 5 million ZEVs on the road by 2030, as well as install 200 hydrogen fueling stations and 250,000 electric vehicle charging stations by 2025. It specifies that 10,000 of the electric vehicle charging stations should be direct current fast chargers. This order also requires all State entities to continue to partner with local and regional governments to streamline the installation of ZEV infrastructure. The Governor’s Office of Business and Economic Development is required to publish a Plug-in Charging Station Design Guidebook and update the 2015 Hydrogen Station Permitting Guidebook to aid in these efforts. All State entities are required to participate in updating the 2016 Zero-Emissions Vehicle Action Plan to help expand private investment in ZEV infrastructure with a focus on serving low-income and disadvantaged communities. Additionally, all State entities are to support and recommend policies and actions to expand ZEV infrastructure at residential land uses, through the LCFS Program, and recommend how to ensure affordability and accessibility for all drivers.

Regional Regulations
The SJVAPCD has regulatory authority over certain stationary and industrial GHG emission sources and provides voluntary technical guidance on addressing GHGs for other emission sources in a CEQA context. SJVAPCD initiatives were developed in 2008 and do not reflect the latest targets from the State.

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

San Joaquin Valley Carbon Exchange and Rule 2301
The SJVAPCD initiated work on the San Joaquin Valley Carbon Exchange in November 2008. The Exchange was implemented with the adoption of Amendments to Rule 2301 Emission Reduction Credit Banking on January 19, 2012. The purpose of the carbon exchange is to quantify, verify, and track voluntary GHG emissions reductions generated within the San Joaquin Valley.

The SJVAPCD incorporated a method to register voluntary GHG emission reductions with amendments to Rule 2301. The purposes of the amendments to the rule include the following:
• Provide an administrative mechanism for sources to bank voluntary GHG emission reductions for later use.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 44 • Provide an administrative mechanism for sources to transfer banked GHG emission reductions to others for any use.
• Define eligibility standards, quantitative procedures, and administrative practices to ensure that banked GHG emission reductions are real, permanent, quantifiable, surplus, and enforceable.

The SJVAPCD is participating in a new program developed by the California Air Pollution Control Officers Association (CAPCOA) to encourage banking and use of GHG reduction credits referred to as the CAPCOA Greenhouse Gas Reduction Exchange (GHGRx). The GHGRx provides information on GHG credit projects within participating air districts. The SJVAPCD is one of the first to have offsets available for trading on the Exchange.

Local Regulations
The City of Fresno’s first GHG Reduction Plan was adopted in December 2014 to reduce local community GHG emissions to 1990 levels by the year 2020, consistent with the State objectives set forth in AB 32. In 2020, the City of Fresno updated its 2014 GHG Reduction Plan (GHG Reduction Plan Update) to conform with existing applicable State climate change policies and regulations to reduce local community GHG emissions to 40 percent below 1990 levels by the year 2030, consistent with the State objectives set by SB 32 and the 2017 Scoping Plan. The GHG Plan Update outlines strategies that the City will undertake to achieve its proportional share of GHG emission reductions. The GHG Reduction Plan Update includes a Consistency Checklist to help the City provide a streamlined review process for new development projects that are subject to discretionary review pursuant to CEQA.

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SETTING
This section provides the current SJVAPCD attainment status, climate and air quality, ambient air quality monitoring results, and GHG emissions inventory.

EXISTING CLIMATE AND AIR QUALITY
Air quality is a function of both local climate and local sources of air pollution. The amount of a given pollutant in the atmosphere is determined by the amount of the pollutant released and the atmosphere's ability to transport and dilute the pollutant. The major determinants of transport and dilution are wind, atmospheric stability, terrain, and for photochemical pollutants, sunshine.

The proposed project is located within the San Joaquin Valley Air Basin (SJVAB) and is under the jurisdiction of the SJVAPCD. A region’s topographic features have a direct correlation with air pollution flow and therefore are used to determine the boundary of air basins. The SJVAB is comprised of approximately 25,000 square miles and covers of eight counties including Fresno, Kings, Madera, Merced, San Joaquin, Stanislaus and Tulare, and the western portion of Kern. The SJVAB is defined by the Sierra Nevada mountains in the east (8,000 to 14,000 feet in elevation), the Coast Ranges in the west (averaging 3,000 feet in elevation), and the Tehachapi mountains in the south (6,000 to 8,000 feet in elevation). The valley is basically flat with a slight downward gradient to the northwest. The valley opens to the sea at the Carquinez Straits where the San JoaquinSacramento Delta empties into San Francisco Bay. An aerial view of the SJVAB would simulate a “bowl” opening only to the north. These topographic features restrict air movement through and out of the basin.

Although marine air generally flows into the basin from the San Joaquin River Delta, the Coast Range hinders wind access into the SJVAB from the west, the Tehachapi Mountains prevent southerly passage of air flow, and the high Sierra Nevada range is a significant barrier to the east. These topographic features result in weak air flow which becomes blocked vertically by high barometric pressure over the SJVAB. As a result, the SJVAB is highly susceptible to pollutant accumulation over time. Most of the surrounding mountains are above the normal height of summer inversion layers (1,500 to 3,000 feet).

Local climatological effects, including wind speed and direction, temperature, inversion layers, precipitation and fog, can exacerbate the air quality in the SJVAB. Wind speed and direction play an important role in dispersion and transport of air pollutants. Wind at the surface and aloft can disperse pollution by mixing vertically and by transporting it to other locations. For example, in the summer, wind usually originates at the north end of the SJVAB and flows in a south-southeasterly direction through the SJVAB, through Tehachapi pass, into the Southeast Desert Air Basin. In the winter, wind direction is reversed and flows in a north-northwesterly direction. In addition to the seasonal wind flow, a sea breeze flows into SJVAB during the day and a land breeze flowing out of the SJVAB at night. The diversified wind flow enhances the pollutant transport capability within SJVAB.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 46 The annual average temperature varies throughout the SJVAB, ranging from the low 40s to high 90s, measured in degrees Fahrenheit (°F). With a more pronounced valley influence, inland areas show more variability in annual minimum and maximum temperatures than coastal areas. The climatological station closest to the site is the Fresno Yosemite International Airport Station (043257). The monthly average maximum temperature recorded at this station from January 1948 to June 2016 ranged from 54.6°F in January to 98.3°F in July, with an annual average maximum of

76.5°F. The monthly average minimum temperature recorded at this station ranged from 37.3°F in December to 65.7°F in July, with an annual average minimum of 50.4°F.43 These levels are still representative of the project area. January and December are typically the coldest months and July and August are typically the warmest month in this area of the SJVAB.

The majority of annual rainfall in the SJVAB occurs between November and April. Summer rainfall is minimal and is generally limited to scattered thundershowers in desert regions and slightly heavier showers near the lower portion of the Basin and along the Sierra Nevada mountains to the east.

Average monthly rainfall during that period varied from 0.01 inches in July and August to 2.09 inches in January, with an annual total of 10.89 inches.44 Patterns in monthly and yearly rainfall totals are predictable due to the recognizable differences in seasons within the valley.

The vertical dispersion of air pollutants in the SJVAB is limited by the presence of persistent temperature inversions. Because of cooling of the atmosphere, air temperature usually decreases with altitude. A reversal of this atmospheric state, where the air temperature increases with height, is termed an inversion. Inversions can exist at the surface, or at any height above the ground. The height of the base of the inversion is known as the “mixing height.” This is the level within which pollutants can mix vertically. Air above and below the inversion base does not mix because of the differences in air density. Semi-permanent systems of high barometric pressure fronts frequently establish themselves over the SJVAB, preventing low pressure systems that might otherwise bring rain and winds that clean the air.

Inversion layers are significant in determining ozone formation, and CO and PM10 concentrations. O3 and its precursors will mix and react to produce higher ozone concentrations under an inversion.

The inversion will also simultaneously trap and hold directly emitted pollutants such as carbon monoxide. PM10 is both directly emitted and created in the atmosphere as a chemical reaction.

Concentration levels of pollutants are directly related to inversion layers due to the limitation of mixing space.

Surface or radiation inversions are formed when the ground surface becomes cooler than the air above it during the night. The earth’s surface goes through a radiative process on clear nights, where heat energy is transferred from the ground to a cooler night sky. As the earth’s surface cools during the evening hours, the air directly above it also cools, while air higher up remains relatively warm. The inversion is destroyed when heat from the sun warms the ground, which in turn heats 43 Western Regional Climate Center. n.d. Fresno Yosemite International Airport, California (043257), Period of Record Monthly Climate Summary. Website: https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?ca3257 (accessed April 2022). 44 Ibid.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 47 the lower layers of air; this heating stimulates the ground level air to float up through the inversion layer.

The combination of stagnant wind conditions and low inversions produces the greatest pollutant concentrations. On days of no inversion or high wind speeds, ambient air pollutant concentrations are lowest. Periods of low inversions and low wind speeds are conditions favorable to high concentrations of CO and PM10. In the winter, the greatest pollution problems are CO and NOx because of extremely low inversions and air stagnation during the night and early morning hours. In the summer, the longer daylight hours and the brighter sunshine combine to cause a reaction between hydrocarbons and oxides of nitrogen to form photochemical smog.

ATTAINMENT STATUS
The CARB is required to designate areas of the State as attainment, nonattainment or unclassified for all State standards. An attainment designation for an area signifies that pollutant concentrations did not violate the standard for that pollutant in that area. A nonattainment designation indicates that a pollutant concentration violated the standard at least once, excluding those occasions when a violation was caused by an exceptional event, as defined in the criteria. An unclassified designation signifies that data does not support either an attainment or nonattainment status. The California Clean Air Act divides districts into moderate, serious, and severe air pollution categories, with increasingly stringent control requirements mandated for each category.

The USEPA also designates areas as attainment, nonattainment, or classified. The air quality data are also used to monitor progress in attaining air quality standards. Table F provides a summary of the attainment status for the SJVAB with respect to the NAAQC and CAAQS.

AIR QUALITY MONITORING RESULTS
Air quality monitoring stations are located throughout the nation and are maintained by the local air pollution control district and State air quality regulating agencies. The SJVAPCD, together with the CARB, maintains ambient air quality monitoring stations in the Basin. The air quality monitoring stations closest to the project site located at 4706 Drummond Street, 1716 Winery, and 3727 First Street in the City of Fresno.

Pollutant monitoring results for years 2019 to 2021 at the Fresno ambient air quality monitoring stations are shown in Table G. As indicated in the monitoring results, the federal PM10 standard had one exceedance in 2019 and 2020 and no exceedances in 2021. The State PM10 standard was exceeded 13 times in 2019, 25 times in 2020, and an unknown number of times in 2021. PM2.5 levels exceeded the federal standard three times in 2019, 13 times in 2019, and an unknown number of times in 2021. State 1-hour ozone standards were exceeded once in 2019, 11 times in 2020, and once in 2021. In addition, the State 8-hour ozone standards were exceeded 10 times in 2019, 27 times in 2020, and 37 times in 2021 and the federal 8-hour ozone standards were exceeded 11 times in 2019, 27 times in 2020, and 37 times in 2021. The CO, SO2, and NO2 standards were not exceeded in this area during the 3-year period.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 48 Table F: Attainment Status of the San Joaquin Valley Air Basin Pollutant State Federal
O3 1-hour Nonattainment/Severe No Federal Standard1
O3 8-hour Nonattainment Extreme Nonattainment2
PM10 Nonattainment Attainment3
PM2.5 Nonattainment Nonattainment4
CO Attainment/Unclassified Attainment/Unclassified
NO2 Attainment Attainment/Unclassified
SO2 Attainment Attainment/Unclassified
Lead Attainment No Designation/Classification
All others Attainment/Unclassified N/A
Source: Ambient Air Quality Standards and Valley Attainment Status (SJVAPCD 2020). 1 Effective June 15, 2005, the U.S. Environmental Protection Agency (USEPA) revoked the federal 1-hour ozone standard, including associated designations and classifications. USEPA had previously classified the SJVAB as extreme nonattainment for this standard. USEPA approved the 2004 Extreme Ozone Attainment Demonstration Plan on March 8, 2010 (effective April 7, 2010).

Many applicable requirements for extreme 1-hour ozone nonattainment areas continue to apply to the SJVAB. 2 Though the Valley was initially classified as serious nonattainment for the 1997 8-hour ozone standard, USEPA approved Valley reclassification to extreme nonattainment in the Federal Register on May 5, 2010 (effective June 4, 2010). 3 On September 25, 2008, USEPA re-designated the San Joaquin Valley to attainment for the PM10NAAQS and approved the PM10 Maintenance Plan. 4 The Valley is designated nonattainment for the 1997 PM2.5 NAAQS. USEPA designated the San Joaquin Valley as nonattainment for the 2006 PM2.5 NAAQS on November 13, 2009 (effective December 14, 2009).

CO = carbon monoxide
N/A = not applicable
NAAQS = National Ambient Air Quality Standards
NO2 = nitrogen dioxide
O3 = ozone
PM10 = particulate matter less than 10 microns in size
PM2.5 = particulate matter less than 2.5 microns in size SJVAB = San Joaquin Valley Air Basin
SJVAPCD = San Joaquin Valley Air Pollution Control District SO2 = sulfur dioxide
USEPA = United States Environmental Protection Agency

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 49 Table G: Ambient Air Quality at Nearby Monitoring Stations Pollutant Standard 2019 2020 2021
Carbon Monoxide (CO)2
Maximum 1-hour concentration (ppm) 1.9 5.0 1.9
Number of days exceeded: State: > 20 ppm 0 0 0
Federal: > 35 ppm 0 0 0
Maximum 8-hour concentration (ppm) 1.5 2.5 1.7
Number of days exceeded: State: > 9 ppm 0 0 0
Federal: > 9 ppm 0 0 0
Ozone (O3)
Maximum 1-hour concentration (ppm) 0.099 0.123 0.125
Number of days exceeded: State: > 0.09 ppm 1 11 1
Maximum 8-hour concentration (ppm) 0.080 0.092 0.099
Number of days exceeded: State: > 0.07 ppm 10 27 37
Federal: > 0.07 ppm 11 27 37
Coarse Particulates (PM10)
Maximum 24-hour concentration (µg/m3) 181.3 350.4 149.0 Number of days exceeded: State: > 50 µg/m3 13 25 ND
Federal: > 150 µg/m3 1 1 0
Annual arithmetic average concentration (µg/m3) 39.6 59.9 ND Exceeded for the year: State: > 20 µg/m3 Yes Yes ND
Federal: > 50 µg/m3 No Yes ND
Fine Particulates (PM2.5)
1 Maximum 24-hour concentration (µg/m3) 44.7 143.3 81.3 Number of days exceeded: Federal: > 35 µg/m3 3 13 ND
Annual arithmetic average concentration (µg/m3) 11.2 18.5 13.8 Exceeded for the year: State: > 12 µg/m3 No No Yes
Federal: > 15 µg/m3 No No No
Nitrogen Dioxide (NO2)
Maximum 1-hour concentration (ppm) 0.042 0.067 0.055
Number of days exceeded: State: > 0.250 ppm 0 0 0
Annual arithmetic average concentration (ppm) 0.013 0.013 0.010 Exceeded for the year: Federal: > 0.053 ppm No No No
Sulfur Dioxide (SO2)
Maximum 1-hour concentration (ppm) 0.009 0.016 0.008
Number of days exceeded: State: > 0.25 ppm 0 0 0
Maximum 24-hour concentration (ppm) 0.002 0.002 0.003
Number of days exceeded: State: > 0.04 ppm 0 0 0
Federal: > 0.14 ppm 0 0 0
Annual arithmetic average concentration (ppm) 0.0004 0.0005 0.0004 Exceeded for the year: Federal: > 0.030 ppm No No No
Sources: CARB (2021) and USEPA (2022). 1 Data were taken from the 1716 Winery, Fresno monitoring station. 2 Data were taken from the 3727 First Street, Fresno monitoring station. µg/m3 = micrograms per cubic meter
CARB = California Air Resources Board
ND = No data. There were insufficient (or no) data to determine the value. ppm = parts per million
USEPA = United States Environmental Protection Agency

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

Global Emissions
Worldwide emissions of GHGs in 2018 totaled 25.6 billion metric tons of CO2e. Global estimates are based on country inventories developed as part of the programs of the United Nations Framework Convention on Climate Change.
45 United States Emissions
In 2019, the year for which the most recent data are available, the United States emitted about 6,558 million metric tons of CO2e (MMT CO2e). Overall, emissions in 2019 decreased by 1.7 percent since 2018 and were 13 percent 2005 levels. This decrease was driven largely by a decrease in emissions from fossil fuel combustion resulting from a decrease in total energy use in 2019 compared to 2018 and a continued shift from coal to natural gas and renewables in the electric power sector. Of the six major sectors – residential, commercial, agricultural, industry, transportation, and electricity generation – transportation accounted for the highest amount of GHG emissions in 2019 (approximately 29 percent), with electricity generation second at 25 percent and emissions from industry third at 23 percent.46
State of California Emissions
The State emitted approximately 418.2 MMT CO2e emissions in 2019, 7.2 MMT CO2e lower than 2018 levels and almost 13 MMT CO2e below the 2020 GHG Limit of 431 MMT CO2e.47 The CARB estimates that transportation was the source of approximately 40 percent of the State’s GHG emissions in 2019, followed by industrial sources at approximately 21 percent and electricity generation at 14 percent. The remaining sources of GHG emissions were agriculture at 8 percent, residential activities at 7 percent, commercial activities at 4 percent, high GWP at 5 percent, and waste at 2 percent.48
45 United Nations Framework Convention on Climate Change (UNFCCC). 2021. GHG Data from UNFCCC.

Website: unfccc.int/process-and-meetings/transparency-and-reporting/greenhouse-gas-data/ghg-dataunfccc/ghg-data-from-unfccc (accessed April 2022). 46 USEPA. 2021. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2019. Website: https://www. epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks-1990-2019 (accessed April 2022). 47 CARB. 2021. California Greenhouse Gas Emissions for 2000 to 2019, Trends of Emissions and Other Indicators Report. Website: https://ww3.arb.ca.gov/cc/inventory/pubs/reports/2000_2019/ghg_ inventory_trends_00-19.pdf (accessed April 2022). 48 Ibid.

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As shown in Table H, in 2016, the City of Fresno emitted approximately 2,923,633 metric tons of CO2e. As shown in Table H, motor vehicles were the largest source at approximately 52 percent of the City’s GHG emissions in 2016, followed by commercial and residential energy at 18 and 16 percent, respectively. The remaining sources included fugitive emissions at 9 percent and solid waste sources at 4 percent. Agriculture and industrial energy emissions each account for less than 1 percent of total emissions.

Table H: City of Fresno GHG Emissions by Sector for 2016 Sector 2016 (MT CO2e) Percent of Total Emissions
Motor Vehicles 1,520,052 52
Residential Energy 479,371 16
Commercial Energy 524,838 18
Fugitive Emissions 270,130 9
Solid Waste 119,167 4
Industrial Energy 10,055 <1
Agriculture Energy 20 <1
Total 2,923,633 100
Source: ICLEI Local Governments for Sustainability, City of Fresno 2016 Inventory Update (2018).

GHG = greenhouse gas
MT CO2e = metric tons of carbon dioxide equivalent

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METHODOLOGY
The methodology used to estimate air quality, health risk, GHG, and energy impacts is described below.

CONSTRUCTION EMISSIONS
Construction activities can generate a substantial amount of air pollution. Construction activities are considered temporary; however, short-term impacts can contribute to exceedances of air quality standards. Construction activities include demolition, site preparation, earthmoving, and general construction. The emissions generated from these common construction activities include fugitive dust from soil disturbance, fuel combustion from mobile heavy-duty diesel and gasoline powered equipment, portable auxiliary equipment, and worker commute trips.

The California Emissions Estimator Model version 2020.4.0 (CalEEMod) computer program was used to calculate emissions from on-site construction equipment and emissions from worker and vehicle trips to the site. This analysis assumes that construction would begin September 2022 and end March 2024. The proposed project would require the import of approximately 5,458 cubic yards of material, which was included in this analysis. This analysis also assumes the use of Tier 2 construction equipment and that the proposed project would comply with SJVAPCD Regulation VIII (Fugitive PM10 Prohibitions). All other construction details are not yet known; therefore, default assumptions (e.g., construction worker and truck trips and fleet activities) from CalEEMod were used.

OPERATIONAL EMISSIONS
The air quality analysis includes estimating emissions associated with long-term operation of the proposed project. Consistent with the SJVAPCD guidance for estimating emissions associated with land use development projects, the CalEEMod computer program was used to calculate the longterm operational emissions associated with the project. As discussed in the Project Description section, the proposed project would develop a 205,264 sf warehouse building with ancillary office space and a future expansion option of 40,300 sf of warehouse, as well as associated parking, landscaping, and infrastructure improvements. The proposed project analysis was conducted using land use codes Unrefrigerated Warehouse-No Rail, City Park, Parking Lot, and Other Non-Asphalt Surfaces. Trip generation rates used in CalEEMod for the project were based on the project’s Trip Generation and Traffic Impact Study Screening Analysis 49, which identifies that the proposed project would generate approximately 481 average daily trips, including 321 vehicle trips and 160 truck trips. This analysis assumes that 20 daily truck trips would travel to and from Sacramento, 40 truck trips would travel to and from San Leandro, and 100 daily truck trips would make local deliveries. To be conservative, separate CalEEMod analyses were prepared for the operational analysis. One CalEEMod run evaluated operational and vehicle trip emissions and another CalEEMod run evaluated truck trip emissions. In addition, the proposed project would utilize 32 electric forklifts, which were also included in CalEEMod. When project-specific data were not available, default assumptions from CalEEMod were used to estimate project emissions. 49 Environment Planning Development Solutions, Inc., 2022. op. cit.

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CONSTRUCTION HEALTH RISK ASSESSMENT
A construction health risk assessment (HRA), which evaluates construction-period health risk to offsite receptors, was performed for the proposed project. To estimate the potential cancer risk associated with construction of the proposed project from equipment exhaust (including diesel particulate matter), a dispersion model was used to translate an emission rate from the source location to a concentration at the receptor location of interest (i.e., a nearby residence and worksites). Dispersion modeling varies from a simpler, more conservative screening-level analysis to a more complex and refined detailed analysis. This refined assessment was conducted using the CARB exposure methodology with the air dispersion modeling performed using the USEPA dispersion model AERMOD. The model provides a detailed estimate of exhaust concentrations based on site and source geometry, source emissions strength, distance from the source to the receptor, and meteorological data.

OPERATIONAL HEALTH RISK ASSESSMENT
To determine the potential health risk to people living and working near the proposed project associated with the exhaust of diesel-powered trucks and equipment, an operational HRA was conducted for the proposed project. This HRA has been conducted using three models: (1) EMFAC2021 for on-road vehicle emissions factors and percentages of fuel type within the overall vehicle fleet; (2) the USEPA AERMOD air dispersion model to determine how the TACs would move through the atmosphere after release from sources both on site and on surrounding roadways; and (3) CARB’s HARP2 model to translate the pollutant concentrations from AERMOD into individual health risks at any sensitive receptor locations surrounding the project site.

The first step of an HRA is to characterize the project-related emissions of TACs. The proposed project would generate approximately 481 average daily trips, including 321 vehicle trips and 160 truck trips. The trucks would access the site by E. North Avenue and S. East Avenue. The proposed project would provide 29 dock-high doors; as the project would contain multiple loading docks, offsite queuing of trucks is not anticipated. While the TAC emissions from gasoline-powered vehicles have a small health effect compared to diesel particulate matter (DPM), this HRA includes both gasoline- and diesel-powered vehicle emissions. For the diesel exhaust emissions, it is sufficient to only consider the DPM (PM10 and PM2.5) portions of the exhaust; all the TACs for the gasoline exhaust emissions are contained in the ROG emissions. Using speciation data from CARB, the emission rates of the TAC components are derived from the total ROG emissions. These data are attached.

Project trucks would operate in two modes: stationary idling and moving on and off the site. The emissions from trucks while idling result in a much higher concentration of TACs at nearby sensitive receptors compared to the emissions from moving trucks. This is due to the dispersion of emissions that occurs with distance and with travel of the vehicle. For this HRA, the truck travel emissions were modeled as a series of volume sources along the on-site driveway, along E. North Avenue going east and west of the site driveway, and S. East Avenue going north and south of the site driveway. LSA assumed vehicles traveling on site would maneuver slowly, averaging approximately 5-15 miles per hour (mph), and that vehicles traveling on roadways would average 5–55 mph.

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\\azcorp04\ptrprojects\ESL2201.16\AQ\Products\ESL2201.16 AQ-HRA-Energy-GHG Study.docx «04/18/22» 54 The idling emissions of trucks operating on the project site were modeled as point sources within the area sources representing the planned loading docks. EMFAC2021 was used to determine the emissions factors of idling and operating diesel trucks to determine the total emissions of DPM.

While it is expected that the truck emissions rate will continue to reduce over time, an HRA only allows for a single emission rate to represent the entire 70-year exposure period. The use of emissions factors for the year 2022, was used as a conservative estimate of emissions, although, the project is not expected to be fully operational until 2024.