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environmental analysis under CEQA is impermissibly limited, thus minimizing the project’s impacts and undermining meaningful public review.33 A lead agency may not hide behind its failure to obtain a complete and accurate project description.34 CEQA Guidelines section 15378 defines “project” to mean “the whole of an action, which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment.”35 “The term “project” refers to the activity which is being approved and which may be subject to several discretionary approvals by governmental agencies. The term project does not mean each separate governmental approval.36 Courts have explained that a complete description of a project must “address not only the immediate environmental consequences of going forward with the project, but also all “reasonably foreseeable consequence[s] of the initial project.”37 “If a[n]…EIR…does not adequately apprise all interested parties of the true scope of the project for intelligent weighing of the environmental consequences of the project, informed decisionmaking cannot occur under CEQA and the final EIR is inadequate as a matter of law.”
A. The DEIR Fails to Identify the End Users of the Project The Project description typically need not identify the end user for a project because CEQA is concerned with the project’s environmental impacts, not who uses it.38 However, courts have held that where the tenant, or type of business, is known and there is evidence that an impact unique to that tenant or type of business will result, an EIR must disclose that information.39 Here, the type of end users of the Project may have significant environmental impacts depending on the truck trips that those end users will generate.

The DEIR assumes that the end users of the site will generate truck trips consistent with the average trip generation rate of 2.13 trucks per 1,000 square feet found in the Western Riverside Council of Governments (“WRCOG”) Transportation Uniform Mitigation Fee (“TUMF”) High‐Cube Warehouse Trip Generation Study 33 Id.
34 Sundstrom v. County of Mendocino (1988) 202 Cal.App.3d 296, 311 (“Sundstrom”). 35 14 C.C.R. 15378(a).
36 CEQA Guidelines § 15378.
37 Laurel Heights, 47 Cal.3d at p. 396 (emphasis added); see also Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal.4th 412, 449-50. 38 Maintain Our Desert Env’t v. Town of Apple Valley (2004) 124 CA4th 430. 39 Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 CA4th 1184, 1213.

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(“WRCOG Study”).40 However, the WRCOG Study shows that trip generation rates can vary widely depending on the end user of a project. For example, the WRCOG Study found that an Amazon facility generated 4.5 daily trips per 1,000 square feet, twice the rate assumed in the DEIR.41 This approach is unsupported and is likely to underestimate impacts. Since the City lacks information about the type of end user that will ultimately occupy the Project warehouses after construction, the DEIR should have analyzed truck trips based on the most intensive reasonably foreseeable use of the site, not an average use, because the City has no evidence that Project truck trips will less intensive, or “average,” when compared to other comparable facilities.

The DEIR relies on average trip generation rates for its analysis of the Project’s operational air quality, health risk, GHG emissions, energy, noise, and vehicle miles traveled (“VMT”) impacts. The DEIR may therefore substantially underestimate the severity of each of these impacts of a more trip-intensive use occurs at the Project site. The DEIR should be revised to calculate impacts based on the most intensive foreseeable uses at the Project site.

B. The DEIR Fails to Disclose Whether the Project Will Require Use of Backup Generators
An EIR must include an analysis of the environmental effects of a proposed future expansion or other future action at a project site if: (1) it is a reasonably foreseeable consequence of the initial project; and (2) the future expansion or action will be significant in that it will likely change the scope or nature of the initial project or its environmental effects.42 Commercial and industrial businesses commonly rely on backup generators (“BUG”) to supply emergency power during project operations in order to limit downtime.

A recent study of BUG use in California (“BUG Study”) found that backup generator use is sharply rising among commercial and industrial land uses, and are clustered in existing environmentally burdened communities.43 For example, in the South Coast Air Quality Management District, BUG use significantly expanded between 2020 and 2021, growing from 12,104 in 2020 to 14,785 in 2021, a 22 40 DEIR, 4.10-9.
41 Marshall, p. 4.
42 Id.
43 M.Cubed, Diesel Back-Up Generator Population Grows Rapidly in the Bay Area and Southern California (“BUG Use Study”) (2021) p. 7. Available at
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percent increase.44 The BUG Use Study found that forty-seven percent of generators are sited in communities classified as being in CalEnviroScreen’s 80th to 100th percentile for pollution burden, with 33 percent of BUGs located in communities above the 90th percentile.45 Backup generators commonly rely on fuels such as natural gas or diesel,46 and thus can significantly impact air quality, GHG emissions, and public health through toxic diesel particulate (“DPM”) emissions.47 As the end users of the Project will likely not want to stop operations during power supply emergencies, it is reasonably foreseeable that the Project would use on-site BUGs. Therefore, the DEIR must disclose whether the Project will use BUGs, and, if so, analyze the effects of the Project’s use of generators. The DEIR’s failure to provide any information about the use of generators causes the DEIR to fail as an informational document.

C. The DEIR Fails to Disclose Whether the Project Will Require Use of Diesel Fire Pumps
The DEIR fails to analyze the diesel emissions from routine testing and operation of fire pumps at the Project site. An email from the City Fire Department to the City Planning Department sent on September 16, 2022 explains that “warehouse developments of this [Project’s] size will typically have high demand fire sprinkler systems for high rack storage and fire sprinkler systems will be 44 BUG Use Study, p. 8.
45 BUG Use Study, p. 7.
46 SCAQMD, Fact Sheet on Emergency Backup Generators,
http://www.aqmd.gov/home/permits/emergency-generators (“Most of the existing emergency backup generators use diesel as fuel”).
47 California Air Resources Board, Emission Impact: Additional Generator Usage Associated with Power Outage (January 30, 2020), available at
https://ww2.arb.ca.gov/resources/documents/emissions-impact-generator-usage-during-psps (showing that generators commonly rely on gasoline or diesel, and that use of generators during power outages results in excess emissions); California Air Resources Board, Use of Back-up Engines for Electricity Generation During Public Safety Power Shutoff Events (October 25, 2019), available at https://ww2.arb.ca.gov/resources/documents/use-back-engines-electricity-generation-during-publicsafety-power-shutoff (“When electric utilities de-energize their electric lines, the demand for back-up power increases. This demand for reliable back-up power has health impacts of its own. Of particular concern are health effects related to emissions from diesel back-up engines. Diesel particulate matter (DPM) has been identified as a toxic air contaminant, composed of carbon particles and numerous organic compounds, including over forty known cancer-causing organic substances. The majority of DPM is small enough to be inhaled deep into the lungs and make them more susceptible to injury. Much of the back-up power produced during PSPS events is expected to come from engines regulated by CARB and California’s 35 air pollution control and air quality management districts (air districts)”).

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supplemented with private fire pumps as needed.”48 However, the DEIR’s CalEEMod output sheets located in Appendix C, which show the results of the DEIR’s air quality impacts analysis, fail to include an output for the Project’s fire pumps.49 The DEIR’s failure to provide any information about the Project’s use of fire pumps causes the DEIR to fail as an informational document.

IV. THE DEIR FAILS TO ADEQUATELY ESTABLISH THE EXISTING

BASELINE
The DEIR fails to accurately disclose the baseline environmental conditions related to the Project’s health risk impacts. As a result, the DEIR lacks the necessary baseline information against which to measure the Project’s environmental impacts with regard to impacts on sensitive receptors from construction.

The existing environmental setting is the starting point from which the lead agency must measure whether a proposed project may cause a significant environmental impact.50 CEQA defines the environmental setting as the physical environmental conditions in the vicinity of the project, as they exist at the time the notice of preparation is published, from both a local and regional perspective.51 Describing the environmental setting accurately and completely for each environmental condition in the vicinity of the Project is critical to an accurate, meaningful evaluation of environmental impacts. The courts have clearly stated that,“[b]efore the impacts of a project can be assessed and mitigation measures considered, an [environmental review document] must describe the existing environment. It is only against this baseline that any significant environmental effects can be determined.”52
48 DEIR, Appendix A: NOP Comments, pdf. p. 65. Email from Byron Beagles to Steven Martinez re Notice of Preparation (NOP) of an Environmental Impact Report (EIR) for 2740 W. Nielsen Office/Warehouse Project (September 16, 2022)
49 DEIR, Appendix C: CalEEMod Output Sheets, p. 34 of 34. 50 See, e.g., Communities for a Better Env’t v. S. Coast Air Quality Mgmt. Dist. (March 15, 2010) 48 Cal.4th 310, 316.
51 CEQA Guidelines §15125(a) (emphasis added); Riverwatch v. County of San Diego (1999) 76 Cal.App.4th 1428, 1453 (“Riverwatch”). 52 County of Amador v. El Dorado County Water Agency (1999) 76 Cal.App.4th 931, 952.

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A. The DEIR Fails to Adequately Establish the Existing Baseline with Respect to Valley Fever
The DEIR includes a single paragraph describing the cause of Valley Fever and its impacts on health.53 However, the DEIR fails to explain the significance of Valley Fever with regard to the Project site, thereby failing to provide context on the environmental setting of the Project. This results in the failure to analyze the potential impacts of Valley Fever exposure to Project construction workers and nearby sensitive receptors.

Valley Fever is a disease that can spread when persons are exposed to Coccidioides immitis (“Cocci”) fungus spores during ground disturbance.54 Impacts to human health from Valley Fever can be severe, cause long lasting health problems, and can even result in death.55 The fungus lives in the top 2 to 12 inches of soil, and when disturbed by activities such as digging, construction activities (e.g. site preparation and grading), dust storms, or during earthquakes, the fungal spores become airborne.56 The Project will disturb up to 120 acres of soil during construction which may lead to the release of fungus spores resulting in impacts to Project workers and nearby sensitive receptors.57
Valley Fever is highly endemic in Fresno County.58 According to the California Department of Public health, Fresno County had a Valley Fever case rate of 43.6 per 100,000 residents in 2020, and 39.8 per 100,000 residents in 2021.59 The Valley Fever case rate in Fresno County was approximately double the statewide case rate averages in 2020 and 2021 of 18.2 and 20.1 respectively and the County has the fifth highest case rate among California’s 58 counties.60 For this reason, the Legislature mandates that employers at worksites in Fresno County provide effective awareness training on Valley Fever to all employees.61 53 DEIR, pp. 4.2-5 – 4.2-6.
54 Clark, p. 4.
55 California Department of Public Health (“CDPH”), Valley Fever Basics (May 7, 2020), available at https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/ValleyFeverBasics.aspx. 56 Clark Comments, p. 4. 57 DEIR, Appendix C, CalEEMod Output Sheets, p. 9 of 34. 58 Labor Code § 6709(b).
59 California Department of Public Health, Epidemiologic Summary of Valley Fever (Coccidioidomycosis) in California, 2020-2021 (hereinafter “Valley Fever Report”) (December 2022) p.

5. Available at
https://www.cdph.ca.gov/Programs/CID/DCDC/CDPH%20Document%20Library/CocciEpiSummary2 020-2021.pdf 60 Valley Fever Summary, p. 5.
61 Labor Code § 6709(a)-(d).

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Despite the known presence of Valley Fever in the Project’s vicinity and the potential impacts posed by exposure to the fungus spores, the DEIR fails to provide any information regarding the prevalence of Cocci fungus spores in the Project’s vicinity, fails to discuss applicable construction worker Valley Fever training requirements and fails to include any Valley Fever-specific mitigation in the MMRP. This lack of information precludes meaningful analysis and mitigation of the potential health impacts the Project will cause to onsite construction workers and other individuals in close proximity to the Project site from disturbing soils which may be contaminated with Valley Fever spores site during Project construction.

The City must prepare a revised DEIR which includes a proper discussion of the potential for the presence of Cocci fungus spores at the Project site in order to accurately analyze and mitigate the Project’s potentially significant health risk impacts from Valley Fever.

V. THE DEIR FAILS TO DISCLOSE, ANALYZE AND MITIGATE

POTENTIALLY SIGNIFICANT IMPACTS
An EIR must fully disclose all potentially significant impacts of a Project and implement all feasible mitigation to reduce those impacts to less than significant levels. The lead agency’s significance determination with regard to each impact must be supported by accurate scientific and factual data.62 An agency cannot conclude that an impact is less than significant unless it produces rigorous analysis and concrete substantial evidence justifying the finding.63 Moreover, the failure to provide information required by CEQA is a failure to proceed in the manner required by CEQA.64 Challenges to an agency’s failure to proceed in the manner required by CEQA, such as the failure to address a subject required to be covered in an EIR or to disclose information about a project’s environmental effects or alternatives, are subject to a less deferential standard than challenges to an agency’s factual conclusions.65 In reviewing challenges to an 62 CEQA Guidelines § 15064(b).
63 Kings Cty. Farm Bur. v. Hanford (1990) 221 Cal.App.3d 692, 732. 64 Sierra Club v. State Bd. Of Forestry (1994) 7 Cal.4th 1215, 1236. 65 Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal.4th 412, 435.

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agency’s approval of an EIR based on a lack of substantial evidence, the court will ‘determine de novo whether the agency has employed the correct procedures, scrupulously enforcing all legislatively mandated CEQA requirements.’66 Additionally, CEQA requires agencies to commit to all feasible mitigation measures to reduce significant environmental impacts.67 In particular, the lead agency may not make required CEQA findings, including finding that a project impact is significant and unavoidable, unless the administrative record demonstrates that it has adopted all feasible mitigation to reduce significant environmental impacts to the greatest extent feasible.68 Even when the substantial evidence standard is applicable to agency decisions to certify an EIR and approve a project, reviewing courts will not ‘uncritically rely on every study or analysis presented by a project proponent in support of its position. A clearly inadequate or unsupported study is entitled to no judicial deference.’”69
A. The DEIR Fails to Adequately Disclose, Analyze and Mitigate the Project’s Significant Transportation Impacts
The DEIR concludes that the transportation impacts of the Project will be less than significant.70 However, the transportation impacts analysis is flawed in with respect to the analysis of the Project’s trip generation and the vehicle miles traveled (“VMT”) impacts. In addition, the DEIR’s incorrect and unsupported conclusions with respect to VMT and trip generation undermine the DEIR’s analyses of the Project’s air quality, health risk, energy, and GHG emissions impacts, which rely heavily on DEIR’s trip generation and VMT calculations in their respective analyses.

1. The DEIR Incorrectly Calculates the Project’s Operational Trip Generation and Trip Length
The DEIR’s trip generation analysis is not supported by substantial evidence because it relies on unsupported assumptions which contradict assumptions made elsewhere in the DEIR.
66 Id., Madera Oversight Coal., Inc. v. County of Madera (2011) 199 Cal. App. 4th 48, 102. 67 CEQA Guidelines § 15002(a)(2). 68 PRC § 21081(a)(3), (b); CEQA Guidelines §§ 15090, 15091; Covington v. Great Basin Unified Air Pollution Control Dist. (2019) 43 Cal.App.5th 867, 883. 69 Berkeley Jets, 91 Cal.App.4th at 1355. 70 DEIR, p. 4.10-14.

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As described above, the DEIR’s transportation impacts analysis relies on the WRCOG Study to estimate the Project’s trip generation.71 The DEIR estimates that the Project would generate approximately 1,920 daily trips, with the AM and PM peak hours generating 110 and 148 trips respectively.72 The DEIR lacks substantial evidence to support the estimated trip generation because the DEIR unreasonably and without justification relies on the average derived from the WRCOG study. Mr. Marshall explains that data in the WRCOG Study are much more variable than the average rates suggest.73 The WRCOG Study is based on counts at 16 warehouses, segmented between 11 fulfillment centers and 5 parcel hubs. As seen in Figure 1 below, the fulfillment center sites studied exhibited a wide range of trip generation rates, with an Amazon facility having an especially high rate.

Figure 1: WRCOG Study Facility Trip Generation Measurements74 Based on the results of the WRCOG Study, it is clear that information regarding the future use of the Project site is crucial in understanding the trip generation rates of the Project. The DEIR admits that the future tenants of the 71 DEIR, p. 4.10-9.
72 DEIR, p. 4.10-9.
73 Marshall Comments, p. 2.
74 Marshall Comments, p. 2.

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Project site have not been identified.75 Because the future tenants are unknown, the City lacks the justification to assume that the Project will generate the average rate determined in the WRCOG Study, and should instead analyze a more intensive trip rate to ensure that the severity of the Project’s potential transportation impacts is accurately disclosed. Mr. Marshall explains that, if the Amazon trip generation rate were applied to the Project, the Project would result in a trip generation rate twice as high as estimated in the DEIR.76 Additionally, if the parcel hub rate of approximately 14 trips per 1,000 square feet were applied, the Project would generate over six times the number of trips estimated in the DEIR.77 Because the City does not have information on the future tenants of the Project site, nor what the eventual use of the Project buildings will be, the City’s reliance on the selected trip rates is unreasonable and unsupported. To reasonably analyze the full scope of the Project’s impacts related to future tenant uses, analysis of the Projects trip generation should use the most conservative estimate and present the data in a revised and recirculated DEIR for public review.

2. The DEIR Fails to Disclose and Analyze the Project’s Potentially Significant VMT Impacts
The City’s CEQA Guidelines for Vehicle Miles Traveled Thresholds (“VMT Guidelines”) establish the criteria for evaluating a project’s VMT impacts.78 Specifically, the VMT Guidelines state that VMT per employee is the appropriate metric against which to measure a project’s impacts, and that a project would have a significant impact if it will generate 13 percent or greater employee VMT than the existing regional average for specific uses.79 The DEIR’s transportation impact analysis relies on the Fresno Council of Governments (“COG”) Activity Based Model (“ABM”) and the trip generation rates discussed above to calculate the Project’s anticipated VMT.80 The DEIR’s transportation analysis states that the existing regional average is 25.6 VMT per employee and that the Project will generate 19.8 75 DEIR, p. 1-3.
76 Marshall Comments, p. 3.
77 Marshall Comments, p. 3.
78 City of Fresno, CEQA Guidelines for Vehicle Miles Traveled Thresholds (hereinafter “VMT Guidelines”) (June 18, 2020) available at
https://fresno.legistar.com/View.ashx?M=F&ID=8601948&GUID=9AEF1630-3BE3-45BF-9BB8- 3D4BB9DB1677 79 VMT Guidelines, p. 26.
80 DEIR, p. 4.10-14.

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VMT per employee.81 Based on these figures, the DEIR concludes that the Project’s VMT per employee rate is 22.66 percent lower than the existing regional average and therefore will not result in a significant impact.82 In his review, Mr. Marshall found that the Project’s VMT analysis likely underestimates Project VMT. Mr. Marshall states that the DEIR estimates that

10.2% of daily trips are made by heavy trucks (5+ axles) and another 7.6% are made by medium trucks (2-4 axles) and that the average trip lengths are calculated to be

9.5 miles for work trips, and 7.3 miles for “other” trips.83 However, these estimates are likely much lower than the actual average truck trip lengths that could be generated by the Project. Mr. Marshall notes that major intermodal facilities that would serve a warehouse distribution use at the Project site are located far away from the Project site, including:
• Rail intermodal facilities in Bakersfield 110 miles,
• Rail intermodal facilities in Stockton 120 miles,
• Port of Oakland 175 miles, and
• Port of Los Angeles 240 miles.

As explained above, without knowing what the eventual use of the Project site will be, it is impossible to fully evaluate trip lengths. However, until more is known about the facility operations the City must account for the possibility of much greater truck trip length generation by the Project. Additionally, Mr. Marshall found that the DEIR’s VMT analysis fails to incorporate data regarding trips that originate from outside of the Fresno COG ABM region.84 As discussed above, this failure to include out of region trips is particularly important to understanding truck trip lengths to intermodal facilities and ports.

A full VMT analysis should be completed for the Project, including explicit consideration of truck trip length and truck VMT, and included in a revised and recirculated DEIR for the Project.
81 DEIR, p. 4.10-14.
82 DEIR, p. 4.10-14.
83 Marshall Comments, p. 5.
84 Marshall Comments, p. 6.

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3. The DEIR Fails to Require Mitigation Measures to Reduce the Project’s Potentially Significant Impacts
As discussed above, the Project may result in significant transportation impacts. Pursuant to the City’s VMT Guidelines, when a Project exceeds the threshold, the Project’s environmental document must include a section that contains mitigation measures to reduce the VMT impacts.85 As the VMT Guidelines note, the California Air Pollution Control Officers Association (“CAPCOA”) Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (“Handbook”)86 includes various strategies to reduce VMT which should be considered for implementation where a project will have a significant VMT impact.87 The Handbook includes data regarding GHG emissions and proven effective methods that a local agency can employ to reduce GHG impacts, including reduction in GHG impacts from VMT.88
The DEIR states that the Project may be subject to SJVAPCD Rule 9410 – Employer Based Trip Reduction, which requires employers with 100 or more eligible employees to establish employee trip reduction programs to reduce VMT, reducing emissions associated with work commutes.89 However, compliance with this rule is not included in any mitigation measures for the Project. SJVAPCD Rules 9410 is similar to CAPCOA’s measure “T-6 Implement Commute Trip Reduction Program (Mandatory Implementation and Monitoring)” which, according to CAPCOA, can result in up to 26 percent reduction in GHG emissions from VMT.90 The Handbook states that the VMT reduction (and therefore, GHG emissions reduction) could be as great as 45 percent with the implementation of additional measures which include:
• T-7 Implement Commute Trip Reduction Marketing
• T-8 Provide Ridersharing Program
• T-9 Implement Subsidized or Discounted Transit Program 85 VMT Guidelines, p. 27.
86 California Air Pollution Control Officers Association (“CAPCOA”) Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (hereinafter “CAPCOA Handbook”) (December 2021) available at https://www.airquality.org/ClimateChange/Documents/Final%20Handbook_AB434.pdf 87 VMT Guidelines, p. 41. 88 CAPCOA Handbook, p. 35.
89 DEIR, p.
90 CAPCOA Handbook, pp. 86-87.

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• T-10 Provide End-of Trip Bike Facilities
• T-11 Provide Employer-Sponsored Vanpool
• T-12 Price Workplace Parking
• T-13 Implement Employee Parking Cash-Out91
Many of the individual measures included in the Handbook offer high potential reductions even if only one measure is used. For example, the maximum reduction produced by “T-11 Provide Employer-Sponsored Vanpool” is 20.4 percent.92
The DEIR fails to include any mitigation measures to reduce the Project’s VMT impacts and fails to include analysis of the feasibility of the above methods, or any other methods, to reduce the Project’s potentially significant impacts. The City must evaluate the feasibility and effectiveness of mitigation measures to reduce the Project’s VMT impacts in a revised and recirculated DEIR for the Project.

B. The DEIR Fails to Disclose, Analyze, and Mitigate the Project’s Potentially Significant Health Risk Impacts

1. The DEIR Fails to Accurately Analyze the Project’s Operational Health Risk
In order to assess the impact of the Project’s operational emissions, the DEIR prepared a health risk assessment (“HRA”) using AERMOD, which is used to estimate exhaust concentrations based on site and source geometry, source emissions strength, distance from the source to the receptor, and meteorological data.93 Here, AERMOD was used to calculate the ground level concentration of DPM emissions associated with the project.94 However, Dr. Clark found that that the air dispersion model used to calculate the Project’s operational emissions has a structural flaw that results in inaccurate estimates of the Project emissions within the community.95
Dr. Clark reviewed the City’s AERMOD modeling and found that the City failed to account for the impact on emissions from building downwash, rendering the analysis incomplete. Dr. Clark explains that building downwash occurs as the wind flows over and around buildings and impacts the dispersion of pollution from 91 CAPCOA Handbook, pp. 89-115.
92 CAPCOA Handbook, p. 104.
93 DEIR, p. 4.2-32.
94 Clark Comments, p. 8.
95 Clark Comments, p. 8.

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nearby stacks.96 A plume caught in the path of this flow is drawn into the wake, temporarily trapping it in a recirculating cavity which leads to higher ground-level concentration of chemicals emitted from sources.97 Furthermore, the downwash effect increases as the relative difference between the release height and top of the building increases.98 This effect is well-understood and is commonly used in emissions modeling. For example, analysis and mitigation of downwash is discussed in Section 123 of the Clean Air Act.99
The DEIR completely fails to account for this impact in its AERMOD modeling, nor does it provide any justification why. When a standard, accepted methodology is available to assess a significant impact, an EIR must evaluate the impact unless a reasoned basis for not doing so is provided.100 In Berkeley Keep Jets Over the Bay Comm. v. Board of Port Comm’rs, the court reviewed a DEIR’s failure to analyze health risk from TAC exposure. The DEIR claimed that no methodology or standards of significance existed for assessing the health risk from TAC exposure.101 The court determined that the lead agency abused its discretion, reasoning that the lead agency failed to consider, in good faith, comments from the public showing that it was feasible to analyze health risk from TAC exposure:102 The Port has not cited us to any reasonably conscientious effort it took either to collect additional data or to make further inquiries of environmental or regulatory agencies having expertise in the matter.…At the very least, the documents submitted by the public raised substantial questions about the project's effects on the environment and the unknown health risks to the area’s residents...the Port has not offered any justification why more definitive information could not have been provided.

Here, the City failed to analyze a critical dispersion factor - building downwash – which affects the rate and severity of exposure to toxic air contaminants, without explaining why. The City’s failure to include this emission 96 Clark Comments, p. 8.
97 Clark Comments, p. 8.
98 Clark Comments, p. 8.
99 42 U.S. Code § 7423 - Stack heights (“For purposes of this section, good engineering practice means, with respect to stack heights, the height necessary to insure that emissions from the stack do not result in excessive concentrations of any air pollutant in the immediate vicinity of the source as a result of atmospheric downwash, eddies or wakes which may be created by the source itself, nearby structures or nearby terrain obstacles”).
100 Berkeley Keep Jets Over the Bay Comm. v. Board of Port Comm’rs (2001) 91 CA4th 1344, 1370 101 Id. at 1369. 102 Id. at 1370.

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factor in its health risk analysis represents a failure to accurately analyze and disclose the ground level concentration of DPM emissions generated by the Project.

The DEIR fails as an informational document in this respect, and must be revised.

2. The DEIR Fails to Analyze and Mitigate Valley Fever Impacts from Project Construction
As explained above, the DEIR fails to disclose the potential presence of Cocci fungus spores and fails to discuss any Valley Fever employee training measures the Applicant intends to take to protect its construction workers from Valley Fever exposure. As a result, the DEIR fails to analyze the Project’s threat of Valley Fever exposure to workers and sensitive receptors, and fails to include mitigation measures to reduce the health risk impacts of Valley Fever.

According to the DEIR’s air quality analysis, Project construction will include 40 days of site preparation which will disturb 60 acres of soil, and 40 days of grading activities which will disturb 120 acres of soil at the Project site.103 Dr.

Clark explains that, when soil containing the spores are disturbed by construction activities, the spores become airborne, exposing construction workers and other nearby sensitive receptors to potential infection.104 Sensitive receptors near the Project site, including workers and those who live nearby are at risk from exposure from disturbed dust during Project construction.105
Dr. Clark states that the most at-risk populations are construction and agricultural workers.106 Additionally, he notes that the potentially exposed population in surrounding areas is much larger than construction workers because the nonselective raising of dust during Project construction will carry the very small spores which measure 0.002–0.005 millimeters into nonendemic areas, potentially exposing large non-Project-related populations.107 According to the DEIR, the closest sensitive receptors to the Project site include the single-family residences located approximately 110 feet south of the project site across West Nielsen Avenue.108 These sensitive receptors are at risk of Valley Fever infection from Project construction resulting in a significant health risk impact, and are not subject to the training requirements of Labor Code 6702. Furthermore, the small fungus spore particles will not be controlled by the conventional construction dust 103 DEIR, Appendix C, CalEEMod Output Sheets, pp. 8 and 9 of 34. 104 Clark Comments, p. 4. 105 Clark Comments, p. 4. 106 Clark Comments, p. 6. 107 Clark Comments, p. 6. 108 DEIR, p. 4.2-31.

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control mitigation measures proposed in the DEIR under Mitigation Measure (“MM”) Air-1.109 Thus, off-site sensitive receptors may have a significant risk of exposure to Valley Fever spores with no mitigation.

The DEIR must be revised and recirculated to include an analysis of the Project’s significant Valley Fever impacts, and to require that any and all mitigation measures that will reduce Valley Fever risks are incorporated as binding mitigation in the Project’s Mitigation Monitoring and Reporting Program (“MMRP”).

3. Feasible Mitigation is Available to Reduce the Project’s Significant Health Risk Impacts from Valley Fever
CEQA imposes the duty on the City to adopt all feasible mitigation measures to reduce significant health impacts from the Project. Yet here, the DEIR fails to incorporate any mitigation measures that would address Valley Fever risks to construction employees and sensitive receptors.

In his comments, Dr. Clark proposes a variety of feasible mitigation measures the DEIR should consider and adopt in a revised DEIR to reduce potential health impacts from Valley Fever.110 The following mitigation measures identified in Dr. Clark’s comments are based on actual experience during construction of projects in areas affected by the fungi that cause Valley Fever, these measures should be included in the DEIR’s mitigation measures in addition to the measures required under MM Air-1:111
(1) Include specific requirements in the Project’s Injury and Illness Prevention Program regarding safeguards to prevent Valley Fever. (2) Control dust exposure through the following methods:
• Apply chemical stabilizers at least 24-hours prior to high wind event; • Apply water to all disturbed areas a minimum of three times per day.

Watering frequency should be increased to a minimum of four times per day if there is any evidence of visible wind-driven fugitive dust; • Provide National Institute for Occupational Safety and Health (NIOSH)-approved respirators for workers with a prior history of Valley Fever.
• Half-face respirators equipped with a minimum N-95 protection factor 109 Clark Comments, p. 6. See also DEIR, pp. 4.2-30 – 4.2-31. 110 Clark Comments, pp. 6-8. 111 Id. pp. 4-8.

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for use during worker collocation with surface disturbance activities.

Half-face respirators equipped with N-100 or P-100 filters should be used during digging activities. Employees should wear respirators when working near earth-moving machinery.
• Prohibit eating and smoking at the worksite, and provide separate, clean eating areas with hand-washing facilities.
• Avoid outdoor construction operations during unusually windy conditions or in dust storms.
• Consider limiting outdoor construction during the fall to essential jobs only, as the risk of cocci infection is higher during this season. (3) Prevent transport of cocci outside endemic areas:
• Prevent spillage or loss of bulk material from holes or other openings in the cargo compartment’s floor, sides, and/or tailgate;
• Provide workers with coveralls daily, lockers (or other systems for keeping work and street clothing and shoes separate), daily changing and showering facilities.
• Clothing should be changed after work every day, preferably at the work site.
• Train workers to recognize that cocci may be transported offsite on contaminated equipment, clothing, and shoes; alternatively, consider installing boot-washing.
• Post warnings onsite and consider limiting access to visitors, especially those without adequate training and respiratory protection. (4) Improve medical surveillance for employees:
• Employees should have prompt access to medical care, including suspected work-related illnesses and injuries.
• Work with a medical professional to develop a protocol to medically evaluate employees who have symptoms of Valley Fever.
• Consider preferentially contracting with 1-2 clinics in the area and communicate with the health care providers in those clinics to ensure that providers are aware that Valley Fever has been reported in the area. This will increase the likelihood that ill workers will receive prompt, proper and consistent medical care.
• Respirator clearance should include medical evaluation for all new employees, annual re-evaluation for changes in medical status, and annual training, and fit-testing.

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• Skin testing is not recommended for evaluation of Valley Fever.112 • If an employee is diagnosed with Valley Fever, a physician must determine if the employee should be taken off work, when they may return to work, and what type of work activities they may perform.

Any mitigation measures must be included in the DEIR and be fully enforceable through permit conditions, agreements, or other legally binding instruments.113 Failure to include enforceable mitigation measures is considered a failure to proceed in the manner required by CEQA.114 In order to meet this requirement, mitigation measures must be incorporated directly into the EIR to be enforceable.115
The DEIR must be revised and recirculated to include mitigation measures such as the those proposed by Dr. Clark to reduce the impacts of exposure to Valley Fever causing fungus spores and mitigate impacts to sensitive receptors.

C. The DEIR Fails to Analyze the Project’s Potentially Significant Air Quality Impacts
The DEIR’s air quality modeling fails to account for the use of diesel fueled backup generators and fire pumps during Project operation, resulting in a failure to accurately analyze the Project’s air quality impacts. Additionally, as discussed above, the Project’s trip generation rates are unsupported and cannot be relied upon by the City to determine that the Project will not have significant transportation impacts. The unsupported trip generation and VMT calculations resulted in a failure to analyze the Project’s GHG emissions and air quality impacts. The failure to analyze specific Project components, and the reliance on unsupported conclusions in the DEIR undermined the Project’s air quality analysis and prevented the City from finding that the Project will not result in significant air quality impacts. 112 Short-term skin tests that produce results within 48 hours are now available. See Kerry Klein, NPR for Central California, New Valley Fever Skin Test Shows Promise, But Obstacles Remain, November 21, 2016; available at http://kvpr.org/post/new-valley-fever-skin-test-shows-promiseobstacles-remain. 113 CEQA Guidelines §15126.4(a)(2). 114 San Joaquin Raptor Rescue Ctr. v. County of Merced (2007) 149 Cal.App.4th 645, 672. 115 Lotus v. Dept of Transportation (2014) 223 Cal. App. 4th 645, 651-52.

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1. The DEIR Fails to Analyze Air Quality Impacts from the Operation of Backup Generators
The DEIR’s air quality analysis fails to account for the operation of backup generators (“BUGs”) during Project operation. Dr. Clark explains that diesel powered backup generators are commonly used in industrial warehouse Projects and would be operated during routine testing and in the event of a power failure.116 The operation of BUGs generates diesel particulate matter (“DPM”) which is identified as a toxic air contaminant, composed of carbon particles and numerous organic compounds, including over forty known cancer-causing organic substances.117
Additionally, by omitting BUGs from the air quality analysis, the DEIR fails to analyze all uses that stem from the reasonably foreseeable increase of generator use during Public Safety Power Shutoff (“PSPS”) events and extreme heat events.118 The recent rise of Extreme Heat Events (“EHEs”) in the State has increased the amount of PSPS events and thus increased the amount of time generators are used.119
EHEs “are defined as periods where in the temperatures throughout California exceed 100 degrees Fahrenheit.”120 In 2021, the Governor released one Executive Order regarding EHEs and one Proclamation for a State of Emergency with the intention to help avoid PSPS events.121 CARB notes though that the number of Extreme Heat Events is likely to increase, and thereby PSPS events, with the continuing change in climate that the State is currently undergoing.122 According to the California Public Utilities Commission (“CPUC”) deenergization report in October 2019, there were almost 806 PSPS events that impacted almost 973,000 customers (~7.5% of households in California) of which 116 Clark Comments, p. 14.
117 Clark Comments, p. 14.
118 Clark Comments, p. 15.
119 Clark Comments, p. 15.
120 Governor of California. 2021. Proclamation of a state of emergency. June 17, 2021; Clark Comments p. 6.
121 Cal. Governor Executive Order N-11-21, https://www.gov.ca.gov/wp-content/uploads/2021/07/EON-11-21-Extreme-Heat-Event-07.10.21.pdf; Cal. Governor Proclamation of a State of Emergency, June 16, 2021, https://www.gov.ca.gov/wp-content/uploads/2021/06/6.17.21-Extreme-Heatproclamation.pdf. 122 CARB 2017 Scoping Plan, p. 6,
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~854,000 of them were residential customers, and the rest were commercial, industrial, medical baseline, and other customers. 123 CARB’s data also shows that on average each of these customers had about 43 hours of power outage in October 2019.124 Dr. Clark notes that CARB concluded that PSPS events in October of 2019 alone generated 126 tons of NOx, 8.3 tons or particulate matter, and 8.3 tons of DPM.125
Dr. Clark concludes that every EHE and PSPS that occurs during Project operation would result in increased DPM from the reasonably foreseeable operation of BUGs at the Project.126 While the City is not required to analyze the worst-case scenarios, there is substantial evidence demonstrating that PSPS events and EHE are reasonably foreseeable events which will require the use of BUGs at the Project site.

A detailed analysis of the emissions and noise from the hours of BUG testing and operation should be included in a revised EIR, including the extra time the BUG will need to run to account for EHEs and PSPS.

2. The DEIR Fails to Analyze Air Quality Impacts from the Project’s Truck Trips
As described above, the Project’s transportation impact analysis fails to accurately analyze the Project’s operational truck trip generation rates and likely underestimates the Project’s VMT. The Project’s air quality analysis relies on the transportation impact analysis’ trip generation numbers and VMT in order to calculate the Project’s air emissions and analyze the Project’s air quality and GHG emissions impacts.127 The DEIR’s failure to accurately calculate the Project’s trip generation results in the failure to accurately calculate the emissions from truck traffic during Project operation. The Project’s transportation impact analysis must be corrected to accurately analyze the Project’s air quality impacts in a revised DEIR.
123 https://www.cpuc.ca.gov/deenergization/ as cited in CARB, 2020. Potential Emission Impact of Public Safety Power Shutoff (PSPS), Emission Impact: Additional Generator Usage associated With Power Outage.
124 CARB, 2020. Potential Emission Impact of Public Safety Power Shutoff (PSPS), Emission Impact:

Additional Generator Usage associated With Power Outage. 125 Clark Comments, p. 15.
126 Clark Comments, p. 15. 127 DEIR, Appendix C, CalEEMod Output Sheets, p. 1 of 34 (explaining that the vehicle trips and fleet mix used in the air quality analysis are “[b]ased on the trip generation prepared for the proposed project.”)
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D. The DEIR Fails to Adequately Analyze Potentially Significant Noise Impacts
The DEIR’s noise analysis concludes that Project construction and operational noise is significant but will be reduced to less than significant with mitigation measures included in the DEIR.128 Additionally, the DEIR found that the noise impacts from project-related traffic on offsite sensitive receptors would be less than significant and does not require mitigation.129 However, the DEIR relies on a faulty methodology to analyze the Project’s construction noise and improperly relies on a relative threshold of significance with regard to the Project’s operational noise from traffic. The DEIR therefore fails to properly analyze and mitigate the Project’s significant construction and operational noise impacts.

CEQA requires agencies to conduct noise analyses for projects that consider both the absolute noise levels expected, and the degree noise levels are expected to increase. Noise studies that rely on a single measure that excludes possible significant impacts from noise increases or noise extremes do not receive deference by reviewing courts.

In King & Gardiner Farms, LLC v. County of Kern, the Court of Appeal held that an agency cannot simply rely on compliance with local noise regulations to conclude there will be no significant noise impacts without considering the impacts of increases in noise.130 The County approved an EIR for proposed zoning amendments to streamline oil and gas permitting.131 The EIR included an analysis of noise impacts that determined significance based solely on whether the 65 decibel day-night average (“dBA DNL”) threshold in the County General Plan would be exceeded.132 The Court of Appeal reasoned that the County General Plan did not conclude that all increases in the magnitude of noise are insignificant until the 65 dBA DNL threshold is exceeded, so the General Plan “does not constitute substantial evidence that the magnitude of an increase in ambient noise is irrelevant.”133 Rather, an EIR’s noise analysis should consider both the increase in noise level and the absolute noise level associated with a project in determining the 128 DEIR, pp. 4.9-18 and 4.9-23. 129 DEIR, p. 4.9-21. 130 King & Gardiner Farms, LLC v. County of Kern (2020) 45 Cal.App.5th 814, 894. 131 Id. at 829. 132 Id. at 830, 889. 133 Id. at 894.

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significance of the project’s noise impacts.134 The Court of Appeal concluded that an agency cannot exclusively rely on “a single cumulative DNL metric for determining the significance of the project's noise impacts” while deciding “the magnitude of the increase in ambient noise is irrelevant.”135
In Berkeley Jets, the Court of Appeal invalidated the Port of Oakland’s EIR for expansion of the Oakland Airport because of its reliance on an improper noise standard.136 The EIR evaluated the significance of noise impacts based on whether the estimated level of sound would exceed 65 dB Community Noise Equivalent Level (“CNEL”).137 However, as the Court of Appeal explained, the CNEL metric— which averages noise over the course of a day—could not be the sole indicator of significant effects from noise because it does not provide a meaningful analysis of the “degree single overflights will create noise levels over and above the existing ambient noise level at a given location, and the community reaction to aircraft noise, including sleep disturbance.”138 Therefore, the Court concluded, a revised EIR with additional study of noise impacts from flights was necessary.139

1. The DEIR Fails to Consider the Totality of Noise Impacts With regard to the Project’s traffic noise the DEIR relies only on a relative threshold to determine that the Project will not result in a significant impact. The DEIR states: “[b]ecause noise levels would increase less than 3.0 dBA, this is consistent with General Plan Policy NS-1-j: Significance Threshold which states that an increase of 3 dBA CNEL or more is considered significant.”140 However, as Mr. Watry points out, this rationale ignores the absolute increase in the noise environment and the cumulative effects of noise on sensitive receptors.141 The DEIR cannot solely rely on a relative threshold of significance when looking at the sum of all noise sources against absolute criteria would reveal a significant noise impact. Indeed, as the court in King & Gardiner Farms held, an EIR should evaluate both the noise level increase and the absolute noise level associated with a Project when determining the significance of noise impacts.142 134 Id. 135 Id. 136 Berkeley Jets, 91 Cal.App.4th at 1381–1382. 137 Id. at 1373. 138 Id. at 1381–1382. 139 Id. at 1382. 140 DEIR, p. 4.9-21. 141 Watry Comments, p. 3. 142 King & Gardiner Farms, 45 Cal.App.5th at 894.

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Similarly, the DEIR should evaluate the total noise impacts from the Project on nearby residential receptors. CEQA Guidelines require EIRs to “analyze any significant environmental effects the project might cause or risk exacerbating by bringing development and people into the area affected.”143 The City’s General Plan Policy NS-1-a establishes “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” such as those along Nielsen Avenue, south of the Project site.144 Based on the data provided in the DEIR, the roadway segment on Nielsen Avenue between Marks and Hughs will see an increase from the existing 64.0 dBA CNEL to 66.1 dBA CNEL with Project construction.145 Based on the DEIR’s own data, the Project will cause noise levels at nearby sensitive receptors to exceed the desirable maximum average exterior noise levels for defined usable exterior areas of residential and noise-sensitive uses of 65 dBA CNEL, resulting in a significant impact.

Mr. Watry notes that both Caltrans and the Federal Transit Administration (“FTA”) recognize the need for absolute thresholds of significance in addition to relative thresholds when determining the significance of noise impacts for projects.146 The FTA’s noise impact assessment guidelines dictate that a 3 dBA Ldn increase in noise exposure at residences would only be allowed if the existing noise exposure is 55 dBA Ldn or less.147 When the existing noise environment is above 55 dBA Ldn, the allowable increase is progressively smaller.148 For example, under the FTA’s criteria, where the existing noise exposure is 64.0 dBA CNEL, as it is at the Project site along Nielsen Avenue, the allowable increase is 1.5 dBA.149 Under the absolute threshold established by the FTA, the Project’s anticipated 2.1 dBA CNEL increase results in a significant impact.
143 CEQA Guidelines § 15126.2(a). 144 City of Fresno, General Plan, Chapter 9: Noise and Safety, p. 9-19 available at https://www.fresno.gov/darm/wp-content/uploads/sites/10/2022/12/upload_temp_Consolidated-GP-10- 13-2022.pdf
145 DEIR, p. 4.9-19, Table 4.9.L. 146 Watry Comments, p. 3. 147 Watry Comments, p. 4. 148 Watry Comments, p. 4. 149 Watry Comments, p. 4.

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2. The DEIR Fails to Analyze and Mitigate Potentially Significant Construction Noise Impacts
The DEIR’s construction noise analysis calculates the noise levels expected from Project construction based on the Federal Highway Administration’s (“FHWA”) Roadway Construction Noise Model (“RCNM”).150 The DEIR includes the equations used to calculate the composite average noise level for construction equipment which considers: the reference noise emission level, the amount of time each piece of equipment is typically used, distance, and the total amount of equipment anticipated to be used on site.151 However, as Mr. Watry states, the DEIR erroneously relies on FTA guidance which dictates that when specific information regarding Project construction is not known, construction noise may be calculated by combining the two loudest pieces of equipment assuming they are running at full power, 100 percent of the time.152 Here however, specific project construction information is available, and can be used to produce a detailed calculation of the Project’s construction noise impacts.

Mr. Watry used the construction equipment inventory information contained in the DEIR’s Appendix C: CalEEMod Output sheets to generate the list of equipment that will be used during each phase of Project construction. Using the reference noise emission levels and usage factors for the equipment from the DEIR in Table 4.9.K153 Mr. Watry calculated the noise levels generated during each phase of construction combined with the existing ambient noise levels to determine the noise impacts on the closest residential receptors located south of the Project site.154 Mr. Watry found that the Project’s site prep phase will result in a noise level of 70.2 dBA Leq, while grading will result in noise levels of 71 dBA Leq, and building construction will result in noise levels of 69.0 dBA Leq.155 When compared to the existing ambient noise level of 62.3 dBA Leq, Mr. Watry found that Project construction will result in noise exposure increases of 7.9, 8.7 and 6.7 dBA Leq during the Projects site prep, grading, and building phases respectively.156 Therefore, the Project will exceed the DEIR’s threshold of 5 dBA Leq during three phases of construction, resulting in a significant impact. 150 DEIR, p. 4.9-16. 151 Watry Comments, p. 5. 152 Watry Comments, p. 5. 153 DEIR, p. 4.9-16. 154 Watry Comments, p. 5.
155 Watry Comments, p. 6.
156 Watry Comments, p. 6.

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Finally, Mr. Watry notes that the requirements of MM NOI-1, which mandates the use of mufflers and the designation of a “disturbance coordinator” would not reduce the Project’s significant construction noise impacts. First, Mr.

Watry explains that the noise calculations use reference levels from equipment that are already equipped with mufflers, and it is unreasonable to believe that a second muffler would be added to construction equipment.157 Second, he notes that while having a disturbance coordinator may be helpful to resolve noise issues as they arise, a noise coordinator will not reduce the noise emitted from Project construction equipment.158
The City must revise the construction noise analysis in a recirculated DEIR and implement feasible construction noise mitigation measures to reduce the Project’s significant noise impacts.

E. The DEIR Fails to Disclose, Analyze, and Mitigate the Project’s Potentially Significant Energy Resources Impacts

1. The DEIR Lacks Evidentiary Support for the Determination that the Project Would Not Result in a Significant
Environmental Impact Due to Wasteful, Inefficient, or
Unnecessary Consumption of Energy Resources During Project Construction and Operation
CEQA Guidelines Appendix F identifies the following means to achieve the goal of conserving energy: decreasing overall per capita energy consumption, decreasing reliance on fossil fuels, and increasing reliance on renewable energy sources.159 In order to ensure that energy impacts are considered in project decisions, CEQA requires that EIRs include a discussion of the potential energy impacts of proposed projects and a detailed statement of mitigation measures designed to “minimize significant effects on the environment, including, but not limited to, measures to reduce the wasteful, inefficient, and unnecessary consumption of energy.”160
157 Watry Comments, p. 5. 158 Watry Comments, p. 5.
159 Appendix F at § I.
160 PRC § 21100(b)(3); CEQA Guidelines, Appendix F, Energy Conservation (“Appendix F”), § I.

Appendix F defines “Unavoidable Adverse Effects” as “wasteful, inefficient and unnecessary consumption of energy during the project construction, operation, maintenance and/or removal that cannot be feasibly mitigated.”
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Appendix F directs an EIR to consider the energy impacts of project operation, the effects on local and regional energy supplies, the effects on peak and base electricity demand, compliance with existing energy standards, and other effects on energy resources.161 Further, Appendix F notes an EIR should consider whether the project involves “Unavoidable Adverse Effects” such as “wasteful, inefficient and unnecessary consumption of energy during the project construction, operation, maintenance and/or removal that cannot be feasibly mitigated.”162 Without the requisite energy analysis, the DEIR falls short of the mandates of Appendix F.

First, the DEIR fails to adequately analyze the significance of the Project’s energy impacts related to the Project’s use of fossil fuels consumed by Project related vehicle trips. One of the stated goals in Appendix F is to decrease reliance on fossil fuels.163 The DEIR states that the Project will increase gasoline consumption in the City of Fresno by 0.11 percent and diesel consumption by 0.5 percent and concludes that the increased fuel consumption from the Project is minimal and therefore not significant.164 However, the DEIR fails to establish a threshold for fossil fuel consumption that would be significant. Therefore, the conclusion that the increased fuel consumption resulting from Project operation would not be significant is unsupported.

The City must determine the appropriate threshold against which to measure the Project’s fossil fuel consumption in order to determine whether the Project will result in a significant impact to energy resources. The analysis in the DEIR is deficient insofar as it does not assess or consider the significance of the increase in fossil fuel usage for the Project on energy resources consistent with Appendix F and does not consider mitigation to “minimize significant effects on the environment, including, but not limited to, measures to reduce the wasteful, inefficient, and unnecessary consumption of energy.”165
Additionally, as detailed in the analysis of the Project’s transportation impacts above, the DEIR fails to accurately account for the Project’s trip generation, which Mr. Marshall found could exceed the DEIR’s estimate by 100% or more.

Increased trip generation would lead to increased fossil fuel use, and therefore, energy use, from Project related vehicle trips.
161 Appendix F §§ I, II.C, II.D.
162 Appendix F § II.F.
163 Id.
164 DEIR, p. 4.5-9.
165 PRC § 21100(b)(3).

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Second, another stated goal for conserving energy set forth in Appendix F is “increasing reliance on renewable energy sources.”166 Appendix F further states that “Mitigation Measures may include: … 4. Alternate fuels (particularly renewable ones) or energy systems.”167 In line with Appendix F, the Fresno 2020 Greenhouse Gas Reduction Plan Update includes a Solar Assistance Policy intended to “[i]dentify and publicize information about financial mechanisms for private solar installations and provide over-the-counter permitting for solar installations meeting specified standards, which may include maximum size (in kV) of units that can be so approved.”168
Here, the DEIR’s discussion of renewable energy generation is virtually nonexistent and fails to provide a meaningful “investigation into renewable energy options that might be available or appropriate for the project.”169 In California Clean Energy Comm. v. City of Woodland, the court held that the city’s EIRs failed to comply with the requirements of Appendix F by not discussing or analyzing renewable energy options.170 The court determined that “the City’s EIRs omit any discussion or analysis of renewable energy options for Gateway II. CEQA is violated when an EIR contains no discussion of a potentially significant environmental consideration.”171
Here, the DEIR states that the Project would “comply with the “CALGreen Code (CCR Title 24, Part 11) and the California Energy Code (CCR Title 24, Part 6), which includes provisions related to insulation and design aimed at minimizing energy consumption.”172 However, the DEIR quickly dismisses any examination of further energy use reduction strategies by stating “[t]he California Energy Code includes solar photovoltaic system requirements for all newly constructed low-rise residential buildings; however, it currently does not include solar requirements for nonresidential buildings.”173 The DEIR must be revised to adequately analyze potential renewable energy generation for the Project and sufficiently analyze the related energy impacts.
166 Appendix F § I.
167 Appendix F § II.D.4.
168 City of Fresno, Greenhouse Gas Reduction Plan Update (March 2020) p. 5-16. Available at https://www.fresno.gov/darm/wp-content/uploads/sites/10/2020/03/Appendix_GGHG_Reduction_Plan_Update.pdf 169 California Clean Energy Comm. v. City of Woodland (2014) 225 Cal. App. 4th 173, 213. 170 Id.
171 Id.
172 DEIR, p. 4.5-11.
173 DEIR, p. 4.5-11.

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Finally, compliance with the Building Code and other energy efficiency requirements does not, by itself, constitute an adequate assessment of measures that can be taken to address the energy impacts during construction and operation of the Project. In Ukiah Citizens for Safety First v. City of Ukiah, the court held that the EIR inadequately described the energy impacts of a Costco project where the EIR relied on the project’s compliance with energy conservation standards to conclude that energy consumption would be less than significant, and did not separately evaluate energy impacts from transportation, construction, or operation.174 Here, the DEIR relies on the California Building Code and Title 24 energy efficiency standards, CALGreen code, green building practices, and a number of green building measures and design features, consistent with the Fresno General Plan and GHG Reduction strategy to support the less than significant determination.175 However, as described above, additional analysis is necessary under the requirements of Appendix F to support a determination that the Project would not result in the wasteful, inefficient, and unnecessary consumption of energy during construction and operations.

Therefore, the DEIR fails to comply with Appendix F energy analysis requirements.

F. The DEIR Fails to Disclose the Project’s Inconsistencies with Land Use and Planning Laws and Regulations
Pursuant to Appendix G of the CEQA Guidelines, a project will have a significant adverse environmental impact on land use and planning if it will 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.176 Here, the DEIR fails to disclose inconsistency with the City’s General Plan which result in a significant adverse environmental impact on land use and planning.

1. The DEIR Fails to Disclose the Project’s Inconsistencies with the Noise Element of the City’s General Plan
Under California law, a general plan serves as a “charter for future development”177 and embodies “fundamental land use decisions that guide the 174 Ukiah Citizens for Safety First v. City of Ukiah (2016) 248 Cal. App. 4th 256, 263-266. 175 DEIR, p. 4.5-11. 176 CEQA Guidelines, Appendix G §X(b). 177 Lesher Communications, Inc. v. City of Walnut Creek (1990) 52 Cal.3d 531, 54.

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future growth and development of cities and counties.”178 The general plan has been aptly described as “the constitution for all future developments” within a city or county.179 Further, the “propriety of virtually any local decision affecting land use and development depends upon consistency with the applicable general plan and its elements.”180 The consistency doctrine has been described as the “linchpin of California’s land use and development laws; it is the principle which infuses the concept of planned growth with the force of law.”181
The City of Fresno’s General Plan Noise Element includes objectives and policies that work to protect the citizens of the City from the harmful and annoying effects of exposure to excessive noise. The Noise Element includes the following policy to guide development:

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 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.182
As demonstrated above, the Project will result in significant noise impacts during Project operation that will violate Policy NS-1-a. Mr. Watry provides substantial evidence that the Project will exceed the desirable and generally acceptable noise thresholds established in Policy NS-1-a, and as a result, the DEIR fails to demonstrate consistency with the General Plan.
178 City of Santa Ana v. City of Garden Grove (1979) 100 Cal.App.3d 521, 532. 179 Families Unafraid to Uphold Rural El Dorado County v. Board of Supervisors of El Dorado County (1998) 62 Cal.App.4th 1334, 1335. 180 Citizens of Goleta Valley v. Board of Supervisors of County of Santa Barbara (1990) 52 Cal.3d 553, 570.
181 Corona-Norco Unified School District v. City of Corona (1993) 17 Cal.App.4th 985, 994. 182 City of Fresno, General Plan, Chapter 9: Noise and Safety, p. 9-19 available at https://www.fresno.gov/darm/wp-content/uploads/sites/10/2022/12/upload_temp_Consolidated-GP-10- 13-2022.pdf
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VI. THE DEIR FAILS TO CONSIDER THE OFFICE OF THE ATTORNEY GENERAL’S BEST PRACTICES AND MITIGATION MEASURES

FOR WAREHOUSE PROJECTS
In September 2022, the California Office of the Attorney General (“OAG”) released an updated version of its guidance document titled “Warehouse Projects:

Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act” (“Best Practices”).183 The Best Practices were developed to aid local agencies to achieve CEQA compliance, and promote environmentallyjust development when they are considering warehouse project proposals.184 The OAG developed the Best Practices based on knowledge gained from monitoring, providing comments on, and litigating, warehouse development projects in California.185 The Best Practices state that while CEQA analysis is necessarily project-specific, the document provides feasible best practices and mitigation measures which were adapted from actual warehouse projects in California.186 The purpose of the Attorney General’s guidance is to ensure that warehouse projects reduce their individual and cumulative impacts on the communities in which they are located to the greatest extent feasible.

The Best Practices provides examples of environmentally superior methods of developing warehouse projects and offers sample mitigation measures that a local agency should consider when faced with a project such as the Project proposed here.

For example, the Best Practices encourage local governing bodies to proactively plan for logistics projects by establishing industrial districts near major highway and rail corridors but away from sensitive receptors in order to help attract investment while avoiding conflicts between warehouse facilities and residential communities.187
Here, the proposed Project defies many of the recommendations in the Best Practices. For example:
• Per CARB guidance, siting warehouse facilities so that their property lines are at least 1,000 feet from the property lines of the nearest sensitive receptors.
183 California Office of the Attorney General, Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act (hereinafter “Best Practices”) (September 2022) available at https://oag.ca.gov/system/files/media/warehouse-best-practices.pdf 184 Best Practices, p. 1. 185 Best Practices, p. 1 186 Best Practices, p. 1. 187 Best Practices, p. 3.

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• Placing facility entry and exit points from the public street away from sensitive receptors, e.g., placing these points on the north side of the facility if sensitive receptors are adjacent to the south side of the facility. 188
As noted above, the closest receptor is 110 feet to the south of the project site, considerably closer than what is recommended by the Best Practices. Additionally, the entry and exit point to the Project site on Nielsen Avenue faces the sensitive receptors to the south, increasing the likelihood of causing significant impacts to those receptors.

The Best Practices also recommend that local jurisdictions take care when considering potential impacts from air quality and GHG emissions from project construction and operation. The DEIR does not comply with many of the recommendations and fails to include mitigation measures that conform with the Best Practices, which for construction include:
• Requiring off-road construction equipment to be zero-emission, where available, and all diesel-fueled off-road construction equipment, to be equipped with CARB Tier IV-compliant engines or better, and including this requirement in applicable bid documents, purchase orders, and contracts, with successful contractors demonstrating the ability to supply the compliant construction equipment for use prior to any grounddisturbing and construction activities. • Prohibiting grading on days with an Air Quality Index forecast of greater than 100 for particulates or ozone for the project area. • Limiting the amount of daily grading disturbance area. • Providing electrical hook ups to the power grid, rather than use of dieselfueled generators, for electric construction tools, such as saws, drills and compressors, and using electric tools whenever feasible.189 For operational air quality and GHG emissions impacts, the Best Practices recommend:
• Requiring all heavy-duty vehicles entering or operated on the project site to be zero-emission beginning in 2030.
• Requiring on-site equipment, such as forklifts and yard trucks, to be electric with the necessary electrical charging stations provided. 188 Best Practices, p. 6. 189 Best Practices, p. 8.

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• Requiring tenants to use zero-emission light- and medium-duty vehicles as part of business operations.
• Forbidding trucks from idling for more than two minutes and requiring operators to turn off engines when not in use.

The DEIR fails to demonstrate conformance with any of the above recommendations. The Best Practices also include several recommendations and suggested mitigation measures regarding warehouse noise and transportation impacts that the DEIR fails to take into account.

The City must consider all of the recommendations of the OAG and incorporate any feasible measures recommended in the Best Practices as mitigation measures in the DEIR to further reduce the Project’s potentially significant air quality, GHG emissions, transportation, energy, and noise impacts.

VII. THE CITY CANNOT MAKE THE FINDINGS REQUIRED FOR

PROJECT APPROVAL
The Project requires approval of a Development Permit and a Tentative Parcel Map by the City. Pursuant to the Fresno City Code (“Code”) the City Planning Director (“Director”) has the authority to approve, conditionally approve, or deny the Project’s applications based on specific sets of findings applicable to each permit.190 In order to approve the Development Permit for the Project, the Director must find that the Project is consistent with the following:

1. The applicable standards and requirements of [the City] Code.

2. The [City’s] General Plan and any operative plan or policies the City has adopted.

3. Any applicable design guidelines adopted by the City Council.

4. Any approved Tentative Map, Conditional Use Permit, Variance, or other planning or zoning approval that the project required.

5. Fresno County Airport Land Use Compatibility Plan (as may be amended) adopted by the Fresno County Airport Land Use
Commission pursuant to California Public Utilities Code Sections 21670—21679.5.191
190 Fresno City Code (“FCC”) § 15-5203 (Development Permit); see also FCC § 15-3308 (Tentative Parcel Map).
191 FCC § 15-5206.

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Additionally, pursuant to the Code, the Director may approve or conditionally approve a Tentative Parcel Map based on the following findings:

1. The proposed subdivision, together with the provisions for its design and improvement, is consistent with the General Plan, any applicable operative plan, adopted policies or guidelines, and the Municipal Code.

2. A subdivision for which a Tentative Map is required shall provide pursuant to the Map Act (Section 66473.1), to the extent feasible, for future passive or natural heating or cooling opportunities in the subdivision.

3. Water will be available and sufficient to serve a proposed subdivision with more than 500 dwelling units in accordance with the Map Act (Section 66473.7).

4. There exists sufficient infrastructure capacity for water, runoff, storm water, wastewater, and solid waste systems to serve the proposed subdivision. In cases where existing infrastructure is found to be deficient, plans shall show how sufficient capacity will be provided.

5. The proposed subdivision is compliant with the City of Fresno Floodplain Management Ordinance and the State of California Code of Regulations Title 23, as well as any other applicable State or federal law.192
The City cannot make all of the above findings for the Project, thereby precluding approval of the Project’s land use permits. As demonstrated in the foregoing comments, the Project is inconsistent with the General Plan’s Noise and Safety Element. Therefore, the Director cannot find that the Project is consistent with the General Plan, precluding finding No. 2 for the Development Permit and Finding No. 1 of the Tentative Parcel Map and cannot make the necessary findings to approve the Project’s entitlements until the deficiencies in the DEIR are corrected.

VIII. THE PROJECT FAILS TO COMPLY WITH THE SUBDIVISION MAP ACT
As explained above, the Project requires the approval of a Tentative Parcel Map to subdivide the existing two parcels into four parcels.193 192 FCC § 15-3309. 193 DEIR, pg. 3-13.

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The DEIR fails to analyze this component of the Project. The DEIR therefore lacks substantial evidence to support the Map Act’s required factual findings to approve the Tentative Parcel Map, which require the City to find that a proposed subdivision is consistent with the general plan/specific plan, and does not have any detrimental environmental or public health effects.194 In addition, as discussed above, there is substantial evidence demonstrating that the Project is likely to have, potentially significant impacts related to transportation, air quality, health risk, GHG emissions, noise, energy, and land use and planning. These impacts are not adequately mitigated in the DEIR. As a result of these unmitigated impacts, the Project fails to comply with mandatory Map Act requirements and the City cannot make the requisite findings to approve the Project’s Tentative Parcel Map.

The purpose of the Map Act is to regulate and control design and improvement of subdivisions with proper consideration for their relation to adjoining areas, to require subdividers to install streets and other improvements, to prevent fraud and exploitation, and to protect both the public and purchasers of subdivided lands.195 Before approving a tentative map, the Map Act requires the agency’s legislative body to make findings that the proposed subdivision map, together with the provisions for its design and improvement, is consistent with the general plan and any specific plan.196 The Map Act also requires the agency’s legislative body to deny a proposed subdivision map in any of the following circumstances:197
a) The proposed map is not consistent with applicable general and specific plans as specified in Section 65451.
b) The design or improvement of the proposed subdivision is not consistent with applicable general and specific plans.
c) The site is not physically suitable for this type of development. d) The site is not physically suitable for the proposed density of development. e) The design of the subdivision or the proposed improvements are likely to cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat. f) The design of the subdivision or type of improvements is likely to cause serious public health problems.
194 Gov Code §§66473.5, 66474. 195 Pratt v. Adams (1964) 229 Cal.App.2d 602. 196 Gov Code § 66473.5. 197 Gov. Code § 66474 (emphasis added).

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g) The design of the subdivision or the type of improvements will conflict with easements, acquired by the public at large, for access through or use of property within the proposed subdivision.

Residents’ experts provide substantial evidence demonstrating that the Project is likely to have significant, unmitigated impacts to public health from exposure to Valley Fever causing fungus spores; on the environment and public health from construction and operational noise; and on the climate from excess GHG emissions and energy consumption. These impacts demonstrate that the Project, as analyzed in the DEIR, fails to comply with the General Plan, is “likely to cause substantial environmental damage,” and “is likely to cause serious public health problems.”198 These unmitigated impacts render the Project inconsistent with Map Act requirements. The Map Act therefore requires the City to deny the Project’s Tentative Parcel Map pursuant to Government Code Sections 66473.5 and 66474(a), (b), (e), and (f).

IX. CONCLUSION
For the foregoing reasons, we urge the City to fulfill its responsibilities under CEQA by preparing a legally adequate EIR that sufficiently addresses the potentially significant impacts described in this comment letter and the attached expert comments. A revised EIR is necessary to ensure that the Project’s significant environmental impacts are mitigated to less than significant levels.

Thank you for your attention to these comments.

Sincerely,

Kevin Carmichael
KTC:ljl
198 Gov. Code §§ 66474(a), (b), (e), and (f).

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ATTACHMENT A
1 | Page
May 19, 2023
Adams Broadwell Joseph & Cardozo
520 Capitol Mall, Suite 350
Sacramento, CA 95814
Attn: Mr. Kevin T. Carmichael
Subject: Comments On Draft Environmental Impact Report
(DEIR) For Development Permit Application No. P21-
02699 & Tentative Parcel Map No. P21-05930
Dear Mr. Carmichael:

At the request of Adams Broadwell Joseph & Cardozo (ABJC), Clark and Associates (Clark) has reviewed materials related to the February 2023 City of Fresno (the City) DEIR for the above referenced project.

Clark’s review of the materials in no way constitutes a validation of the conclusions or materials contained within the plan. If we do not comment on a specific item this does not constitute acceptance of the item.

Project Description:

According to the City’s DEIR, Development Permit Application No. P21-02699 and Tentative Parcel Map No. P21-05930 was filed by Scannell Properties. The applicant proposes to construct four office/warehouse buildings with a total area of 901,438 square feet, as well as associated circulation, parking, and infrastructure improvements.

The buildings’ exterior would be up to 44 feet high with an interior height of up to 36 feet and designed with a total of 201 loading dock doors on the north and south sides of the buildings. The four buildings would be comprised of the following: Building 1 would be 468,812 square feet and would provide 122 loading dock doors; Building 2 would be 248,786 square feet and would provide 46 loading OFFICE
12405 Venice Blvd
Suite 331
Los Angeles, CA 90066
PHONE
310-907-6165
FAX
310-398-7626
EMAIL
[email protected]
Clark & Associates
Environmental Consulting, Inc.

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dock doors; Building 3 would be 93,074 square feet and would provide 18 loading dock doors; and Building 4 would be 90,766 square feet and would provide 15 loading dock doors. The proposed project would also subdivide the project site into four separate parcels and would consist of each proposed building on a separate parcel. A total of 594 on-site parking spaces would be provided for vehicles and trucks. Of the 594 parking spaces, 385 spaces would be dedicated for standard vehicles, 11 spaces would be dedicated for accessible standard vehicles, and 10 spaces would be dedicated for accessible vans. The remaining 188 spaces would be dedicated for trailers and would be located along the eastern and western edges of the project site and would be located behind two 8-foot-tall gates, which would be installed to separate the general parking area from the truck storage and dock loading area.

Figure 1: Project Site Plan
The 48.03-acre project site is currently vacant but formerly consisted of an industrial warehouse that has since been demolished. The project site is bounded to the north by partially developed land, to the east by North Hughes Avenue, to the south by West Nielsen Avenue, and to the west by North Marks Avenue. Regional access to the site is provided by State Route 180 (SR-180), which is located approximately 0.3 mile south of the project site, and State Route 99 (SR-99), which is located approximately 0.8 miles east of the project site.

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Figure 2: Site Vicinity Map
The City’s analysis assumes that the proposed project would be operational 24 hours per day, 7 days per week. A total of 594 on-site parking spaces would be provided for vehicles and trucks. Of B3-37
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the 594 parking spaces, 385 spaces would be dedicated for standard vehicles, 11 spaces would be dedicated for accessible standard vehicles, and 10 spaces would be dedicated for accessible vans. The remaining 188 spaces would be dedicated for trailers and would be located along the eastern and western edges of the project site and would be located behind two 8-foot-tall gates, which would be installed to separate the general parking area from the truck storage and dock loading area.

According to the conclusions of the DEIR, the proposed project is not expected to result in any significant unavoidable adverse impacts. The conclusion from the City that there will not be significant air quality impacts is not supported by the facts of the Project. There are substantial impacts that are not addressed in the City’s analysis that must be addressed in a revised draft environmental impact report (RDEIR).

Specific Comments:

1. The DEIR Fails To Address Impacts from Exposure to Coccidiodes Immitis (Valley Fever Cocci) From Particulate Matter Released From Site During Construction Activities of The Project.

The DEIR fails to adequately address the known presence/issue of Coccidiodes Immitis (Valley Fever Cocci) in the Fresno, California area. Dust exposure is one of the primary risk factors for contracting Valley Fever (via Coccidiodes imimitis (cocci) exposure). When soil containing the cocci spores are disturbed by construction activities, the fungal spores become airborne, exposing construction workers and other nearby sensitive receptors.

The fungus lives in the top 2 to 12 inches of soil. When soil containing this fungus is disturbed by activities such as digging, vehicles, construction activities, dust storms, or during earthquakes, the fungal spores become airborne. According to the Air Quality Analysis of the DEIR (Appendix C), the project will involve 40 days of site preparation which will disturb 60 acres of soil and 40 days of grading activities which will disturb 120 acres of soil.

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Figure 3: Details From CalEEMOD Analysis of Project
The most at-risk populations are construction and agricultural workers.1 Construction workers are the very population that would be most directly exposed by the Project. A refereed journal article on occupational exposures notes that “[l]abor groups where occupation involves close contact with the soil are at greater risk, especially if the work involves dusty digging operations.”2 The potentially exposed population in surrounding areas is much larger than construction workers because the nonselective raising of dust during Project construction will carry the very small spores, 0.002–0.005 millimeters (“mm”), into nonendemic areas, potentially exposing large nonProject-related populations.3 ,
4 These very small particles are not controlled by conventional construction dust control mitigation measures.
1 Lawrence L. Schmelzer and R. Tabershaw, Exposure Factors in Occupational Coccidioidomycosis, American Journal of Public Health and the Nation’s Health, v. 58, no. 1, 1968, pp. 107–113, Table 3; available at http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1228046/?page=1. 2 Ibid., p. 110.
3 Schmelzer and Tabershaw, 1968, p. 110; Pappagianis and Einstein, 1978 4 Pappagianis and Einstein, 1978, p. 527 (“The northern areas were not directly affected by the ground level windstorm that had struck Kern County but the dust was lifted to several thousand feet elevation and, borne on high currents, the soil and arthrospores along with some moisture were gently deposited on sidewalks and automobiles as ‘a mud storm’ that vexed the residents of much of California.” The storm originating in Kern County, for example, had major impacts in the San Francisco Bay Area and Sacramento).

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Since 2014, the number of cases of Valley Fever in Fresno County has increased from 161 in 2014 to 828 in 2017, as reported by the California Department of Public Health (CDPH).5 In 2022, 450 cases were recorded in Fresno County,6 almost three times (2.8 times exactly) as many as the amounts reported in 2014. In the first quarter of 2023, Fresno County reported 83 cases.

2. The DEIR Fails To Include Adequate Mitigation Measures And Medical Monitoring Information To Prevent Exposure to Coccidiodes Immitis (Valley Fever Cocci) From Disturbed Soils On Site.

Standard fugitive dust mitigation measures are not adequate to protect construction workers and nearby sensitive receptors from this risk. In addition to the mitigation measures required under the DEIR’s Mitigation Measure Air-1, the City should require the following measures from the Proponent to actively suppress the spread of VF by:

1. Include specific requirements in the Project’s Injury and Illness Prevention Program (as required by Title 8, Section 3203) regarding safeguards to prevent Valley Fever.

2. Control dust exposure:
- Apply chemical stabilizers at least 24-hours prior to high wind event; - Apply water to all disturbed areas a minimum of three times per day. Watering frequency should be increased to a minimum of four times per day if there is any evidence of visible wind-driven fugitive dust;
- Provide National Institute for Occupational Safety and Health (NIOSH)-approved respirators for workers with a prior history of Valley Fever. - Half-face respirators equipped with a minimum N-95 protection factor for use during worker collocation with surface disturbance activities. Half-face 5 CDPH. 2019. Epidemiologic Summary of Valley Fever (Coccidiodomycosis) In California, 2019. Surveillance and Statistics Section, Infection Diseases Branch, Division of Communicable Disease Control, Center For Infectious Diseases, California Department of Public Health.
https://www.cdph.ca.gov/Programs/CID/DCDC/CDPH%20Document%20Library/CocciEpiSummary2019.pdf 6 CDPH. 2023. Coccidiodomycosis In California, Provisional Monthly Report, January – March 2023 (as of March 31, 2023). Surveillance and Statistics Section, Infection Diseases Branch, Division of Communicable Disease Control, Center For Infectious Diseases, California Department of Public Health. https://www.cdph.ca.gov/Programs/CID/DCDC/CDPH%20Document%20Library/CocciinCAProvisionalMonthlyReport .pdf
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respirators equipped with N-100 or P-100 filters should be used during digging activities. Employees should wear respirators when working near earth-moving machinery.
- Prohibit eating and smoking at the worksite, and provide separate, clean eating areas with hand-washing facilities.
- Avoid outdoor construction operations during unusually windy conditions or in dust storms.
- Consider limiting outdoor construction during the fall to essential jobs only, as the risk of cocci infection is higher during this season.

3. Prevent transport of cocci outside endemic areas:
- Prevent spillage or loss of bulk material from holes or other openings in the cargo compartment’s floor, sides, and/or tailgate;
- Provide workers with coveralls daily, lockers (or other systems for keeping work and street clothing and shoes separate), daily changing and showering facilities. - Clothing should be changed after work every day, preferably at the work site. - Train workers to recognize that cocci may be transported offsite on contaminated equipment, clothing, and shoes; alternatively, consider installing boot-washing. - Post warnings onsite and consider limiting access to visitors, especially those without adequate training and respiratory protection.

4. Improve medical surveillance for employees:
- Employees should have prompt access to medical care, including suspected workrelated illnesses and injuries. - Work with a medical professional to develop a protocol to medically evaluate employees who have symptoms of Valley Fever.
- Consider preferentially contracting with 1-2 clinics in the area and communicate with the health care providers in those clinics to ensure that providers are aware that Valley Fever has been reported in the area. This will increase the likelihood that ill workers will receive prompt, proper and consistent medical care. - Respirator clearance should include medical evaluation for all new employees, annual re-evaluation for changes in medical status, and annual training, and fittesting.

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- Skin testing is not recommended for evaluation of Valley Fever.7 - If an employee is diagnosed with Valley Fever, a physician must determine if the employee should be taken off work, when they may return to work, and what type of work activities they may perform.

The mitigation measures identified in this comment, based on actual experience during construction of projects in endemic areas, should be required for the Project. The City must include concrete measures like the ones listed above in a revised DEIR of the Project.

3. The Air Quality Analysis Of Operational Emissions Is Incomplete And Fails To Include Emissions From The Fire Pump System That Will Be Installed Onsite.

According to the Air Quality Analysis prepared by LSA8 for the Project, operational emissions were calculated using the CalEEMOD (Version 2020.4.0) software. Included in the analysis are area source emissions and mobile source emissions. Not included in the analysis are emissions from the fire flow pump system that will need to be installed for the buildings to be compliant with the California Fire Code (CFC) and local fire authority requirements.

In the CalEEMOD outputs provided in the Appendix C to the DEIR prepared by LSA9, no fire pump system is included in the analyses.
7 Short-term skin tests that produce results within 48 hours are now available. See Kerry Klein, NPR for Central California, New Valley Fever Skin Test Shows Promise, But Obstacles Remain, November 21, 2016; available at http://kvpr.org/post/new-valley-fever-skin-test-shows-promise-obstacles-remain. 8 LSA. 2023. Public Review Draft Environmental Impact Report Technical Appendices – Volume I – Appendices A-I. 2740 West Nielsen Avenue Office/Warehouse Project, Fresno, California. 9 LSA. 2023. Public Review Draft Environmental Impact Report Technical Appendices – Volume I – Appendices A-I. 2740 West Nielsen Avenue Office/Warehouse Project, Fresno, California.

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Figure 4: CalEEMOD Output For Annual Operational Phase
The City’s analysis is therefore incomplete and must be corrected in a revised DEIR for the Project.

4. The Project’s Air Quality Analysis Is Incomplete And Fails To Adequately Consider The Use of Refrigeration Units and TRU’s Onsite
According to the DEIR, the proposed project would result in the construction of four office/warehouse buildings that would be configured for heavy industrial uses by tenants that have not been identified. The project is being built as a “spec” building whereby tenant(s) would perform the final improvements, while the proposed project would fully build the office spaces. The description provided does not preclude the use of the buildings as refrigerated/cold storage warehouses. Given the vague description of the Project end use, the City should include an analysis of the Project assuming that the buildings could be used for cold storage and should also include the use of Transport Refrigeration Units (TRUs) on site in the air quality analysis.

Transport Refrigeration Units (TRU) are refrigeration systems powered by diesel internal combustion engines designed to refrigerate or heat perishable products that are transported in various containers, including truck vans, semi-truck trailers, shipping containers, and railcars. CARB10 defines diesel exhaust as a complex mixture of inorganic and organic compounds that exists in gaseous, liquid, and solid phases. CARB and U.S. EPA identify 40 components of the exhaust as suspected human carcinogens, including formaldehyde, 1,3-butadiene, and benzo[a]pyrene. While acrolein is one of the most TAC in diesel exhaust it is not the only TAC. The inhalation unit risk factor identified by OEHHA for use in risk assessments is for the particulate matter (DPM) fraction 10 CARB. 1998. Report to the Air Resources Board on the Proposed Identification of Diesel Exhaust as a Toxic Air Contaminant, Part A, Public Exposure To, Sources and Emissions of Diesel Exhaust In California. April 22, 1998. Pg A-1.

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of diesel exhaust and not the vapor phase components identified by CARB and U.S. EPA.

Given the lack of a clear project description of the use of the Project Site, it is therefore reasonable to conclude that refrigeration units and TRUs are a foreseeable project component. The refrigeration units and TRU emissions have not been quantified in the DEIR, intentionally underestimating the foreseeable health risk to the community as well as the associated GHG emissions from the operation of the refrigeration units and TRUs. The City must assess the impacts since they are allowing for the potential future use of these sources of pollution onsite in a revised DEIR.

5. The DEIR’s Emission Estimates For Passenger Vehicles Is Different Than The Value Included In The Technical Appendices.

According to the DEIR, the proposed Project would result in a total of 1,920 vehicle trips per day. Of the 1,920 trips, there would be 1,578 car trips daily. The remaining 342 trips would be associated with trucks using the Project Site.

Figure 5: Daily Trip Estimation
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A review of the underlying tables in Appendix C of the technical appendices shows that LSA assumed a different rate of trip generation. On page 227 of the pdf, the table for passenger vehicles shows a value of 1,589 passenger vehicles per day. 11
Figure 6: Passenger Vehicle Estimates From Technical Appendices The City must correct the numbers within the technical appendices and the DEIR to ensure there is consistency in the whole report. The City should provide those corrected results in a revised DEIR.

5. The Underlying Assumptions Regarding The Number of Vehicles Associated With Each Square Foot of Building Utilized In The Air Quality Analysis Under Estimates The Number of Daily Trips And Does Not Reflect The Range Of Values Reported By ITE.

The choice of the daily trip rate has a profound impact on the calculated emissions for operational associated with the Project. The City’s choice for the trip rate is at the lowest end of the values reported in the literature. The ITE manual includes a variety of average daily vehicle trips for HCWs which range from a low of 1.4 per 1,000 square feet for transload and short-term storage warehouses to a high of 6.44 trips per square feet for fulfillment center warehouses.12 An averaged value of all the warehouse HCW types reported in the ITE manual would be 3.28 trips per 1,000 square 11 LSA. 2023. Public Review Draft Environmental Impact Report Technical Appendices – Volume I – Appendices A-I. 2740 West Nielsen Avenue Office/Warehouse Project, Fresno, California. 12 Institute of Transportation Engineers (2020).

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feet. The 2019 study of warehouse trip generation performed by WSP for the Western Riverside Council of Governments (WR-COG) cited in the DEIR, calculates an average daily trip rate across the 11 fulfillment centers of 2.13 per 1000 square feet, well below the average value for the ITE studies.

The value reported in the WR-COG study is significantly lower than the average of the ITE studies (35% lower than the ITE average).

Figure 7: Trip rates per 1,000 square feet as reported in ITE manual Figure 8: Project Description in CalEEMOD
Using the ITE manual rates above, the proposed 901,440 square foot HCW Project could result in 1,262.0 to 5,805.27 daily trips. The averaged value of the daily trips (assuming 3.28 trips per thousand feet on average) is 2,956.72 trips, nearly 1,000 more trips per day than those assumed in the DEIR.

1.4 1.81

6.44 4.63

2.12 2.13
0 1
2 3
4 5
6 7
Transload And
Shortz-Term
Storage
Warehouse
Fulfillment Center
Warehouse - No
Sort
Fulfillment Center
Warehouse - Sort
Parcel Hub
Warehouse
Cold Storage
Warehouse
Rate Used In DEIR
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The ITE studies suggest that the value used to justify the number of vehicle trips per day utilized by the City are not supportable, and the DEIR lacks any supporting evidence to justify its reliance on a 2.13 daily trip rate. Based on the evidence and reasonable calculations provided in the ITE studies, the City should, at a minimum, re-evaluate the Project’s operational emissions based on the average value reported by ITE (3.28) in a revised DEIR.

6. The Air Dispersion Model Used For The Health Risk Assessment For Operational Phases Of The Project Has A Structural Flaw That Result In Inaccurate Estimates Of The Project Emissions Within The Community
The modeling approach has a significant flaw - the model does not account for the impact on emissions from building downwash. If the building downwash were included in the model, then the Proponent would be reasonably expected to call that out in the text summary of the model. The AERMOD model calculates the ground-level concentration of DPM emission associated with the project.

Building downwash occurs as the wind flows over and around buildings and impacts the dispersion of pollution from nearby stacks. A plume caught in the path of this flow is drawn into the wake, temporarily trapping it in a recirculating cavity. This downwash effect leads to higher groundlevel concentration of chemicals emitted from sources. The downwash effect increases as the relative difference between the release height and top of the building increases.13 For the closest receptors to the site, the residences to the east of the Project, this difference will create an additional air quality impact that is not accounted for in the City’s analysis. Guidance from authoritative bodies in California regarding the preparation of health risk assessments of mobile sources of diesel emissions14 requires the inclusion of building heights and dimensions for building downwash calculations. 13 The so-called good engineering practice height (GEP) of the source. The GEP is defined in Section 123 of the Clean Air Act as “the height necessary to ensure that emissions from a stack do not result in excessive concentrations of any air pollutant in the immediate vicinity of the source as a result of atmospheric downwash, eddies or wakes which may be created by the source itself, nearby structures or nearby terrain obstacles.” 14 SCAQMD. 2003. Health Risk Assessment Guidance For Analyzing Cancer Risks From Mobile Source Diesel Emissions. August, 2003. Page 2.

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Omission of the building downwash effect underestimates the exposure point concentrations for receptors near the building(s). The City should address the impact of this issue in a R-DEIR.

7. The Air Quality Analysis Failed To Account For The Back-up Generator (BUG) Usage Onsite.

The DEIR’s Air Quality Analysis does not account for the need for back-up generators on-site.

Backup generators would only be used in the event of a power failure and would not be part of the Project’s normal daily operations. In the CalEEMOD outputs provided in the Appendix C to the DEIR prepared by LSA15, no BUGs are included in the analyses.

Figure 9: CalEEMOD Output For Annual Operational Phase
The City’s analysis is therefore incomplete and must be corrected in a revised DEIR for the Project.

In addition to the testing emissions the air quality analysis must include the substantial increase in operational emissions from BUGs in the Air Basin due to unscheduled events, including but not limited to Public Safety Power Shutoff (PSPS) events and extreme heat events. Extreme heat events are defined as periods where in the temperatures throughout California exceed 100 degrees Fahrenheit.

The total duration of the PSPS events lasted between 141 hours to 154 hours in 2019. In 2021, the Governor Of California declared that during extreme heat events the use of stationary generators shall be deemed an emergency use under California Code of Regulations (CCR), title 17, section 93115.4 sub. (a) (30) (A)(2). The number of Extreme Heat Events is likely to increase in California with the continuing change in climate the State is currently undergoing. 15 LSA. 2023. Public Review Draft Environmental Impact Report Technical Appendices – Volume I – Appendices A-I. 2740 West Nielsen Avenue Office/Warehouse Project, Fresno, California.

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Power produced during PSPS or extreme heat events is expected to come from engines regulated by CARB and California’s 35 air pollution control and air quality management districts (air districts). Of particular concern are health effects related to emissions from diesel back-up engines.

Diesel particulate matter (DPM) has been identified as a toxic air contaminant, composed of carbon particles and numerous organic compounds, including over forty known cancer-causing organic substances. The majority of DPM is small enough to be inhaled deep into the lungs and make them more susceptible to injury.

According to the California Public Utilities Commission (CPUC) de-energization report in October 2019, there were almost 806 PSPS events (emphasis added) that impacted almost 973,000 customers (~7.5% of households in California) of which ~854,000 of them were residential customers, and the rest were commercial/industrial/medical baseline/other customers. CARB’s data also indicated that on average each of these customers had about 43 hours of power outage in October 2019. Using the actual emission factors for each diesel BUG engines in the air district’s stationary BUGs database, CARB staff calculated that the 1,810 additional stationary generators running during a PSPS in October 2019 generated 126 tons of NOx, 8.3 tons or particulate matter, and 8.3 tons of DPM.

For every PSPS or Extreme Heat Event (EHE) triggered during the operational phase of the project, significant concentrations of DPM will be released. A R-DEIR should be prepared for the Project that includes an analysis of the operation of BUGs that will occur at the project site that are not accounted for in the current air quality and GHG analyses.

Conclusion
The facts identified and referenced in this comment letter lead me to reasonably conclude that the Project could result in significant unmitigated impacts if the DEIR is approved. The City must reevaluate the significant impacts identified in this letter by requiring the preparation of a revised draft environmental impact report.

Sincerely,
.

B3-46
cont.

B3-47

EXHIBIT A
CV
James J. J. Clark, Ph.D.

Principal Toxicologist
Toxicology/Exposure Assessment Modeling
Risk Assessment/Analysis/Dispersion Modeling
Education:

Ph.D., Environmental Health Science, University of California, 1995 M.S., Environmental Health Science, University of California, 1993 B.S., Biophysical and Biochemical Sciences, University of Houston, 1987 Professional Experience:

Dr. Clark is a well-recognized toxicologist, air modeler, and health scientist. He has 30 years of experience in researching the effects of environmental contaminants on human health including environmental fate and transport modeling (SCREEN3, AEROMOD, ISCST3, Johnson-Ettinger Vapor Intrusion Modeling, RESRAD, GENII); exposure assessment modeling (partitioning of contaminants in the environment as well as PBPK modeling); conducting and managing human health risk assessments for regulatory compliance and risk-based clean-up levels; and toxicological and medical literature research.

SELECTED AIR MODELING RESEARCH/PROJECTS
Client(s) - Confidential
Dr. Clark performed a historical dose reconstruction for community members from an active 700 acre petroleum refinery in Los Angeles. The analysis included a multi-year dispersion model was performed in general accordance with the methods outlined by the U.S. EPA and the SCAQMD for assessing the health impacts in Torrance, California. The results of the analysis are being used as the basis for injunctive relief for the communities surrounding the refinery.

Client(s) – Multiple
Indoor Air Evaluations, California: Performed multiple indoor air screening evaluations and risk characterizations consistent with California Environmental Protection Agency’s (Cal/EPA) Department of Toxic Substances Control (DTSC) and Regional Water Quality Control Board (RWQCB) methodologies. Characterizations included the use of DTSC’s Clark & Associates
Environmental Consulting, Inc
Office
12405 Venice Blvd.

Suite 331
Los Angeles, CA 90066
Phone
310-907-6165
Fax
310-398-7626
Email
[email protected]
B3-48
modified Johnson & Ettinger Model and USEPA models, as well as the attenuation factor model currently advocated by Cal/EPA’s Office of Environmental Health and Hazard Assessment (OEHHA).

Client – Adams, Broadwell, Joseph Cardozo, P.C.

Dr. Clark has performed numerous air quality analyses and risk assessments of criteria pollutants, air toxins, and particulate matter emissions for sites undergoing evaluation via the California Environmental Quality Act (CEQA) process. The analyses include the evaluation of Initial Study (IS) and Environmental Impacts Reports (EIR) for each project to determine the significance of air quality, green house gas (GHG), and hazardous waste components of the projects. The analyses were compiled as comment letters for submittal to oversight agencies.

Client – Confidential
Dr. Clark performed a comprehensive evaluation of criteria pollutants, air toxins, and particulate matter emissions from a carbon black production facility to determine the impacts on the surrounding communities. The results of the dispersion model were used to estimate acute and chronic exposure concentrations to multiple contaminants and were be incorporated into a comprehensive risk evaluation.

Client – Confidential
Dr. Clark performed a comprehensive evaluation of air toxins and particulate matter emissions from a railroad tie manufacturing facility to determine the impacts on the surrounding communities. The results of the dispersion model have been used to estimate acute and chronic exposure concentrations to multiple contaminants and have been incorporated into a comprehensive risk evaluation.

PUBLIC HEALTH/TOXICOLOGY
Client: Confidential
Dr. Clark performed a historical dose reconstruction for community members from radiologically impacted material (RIM) releases from an adjacent landfill. The analysis was performed in general accordance with the methods outlined by the Agency for Toxic Substances Control (ATSDR) for assessing radiation doses from historical source areas in North St. Louis County, Missouri.

Client: City of Santa Clarita, Santa Clarita, California Dr. Clark managed the oversight of the characterization, remediation and development activities of a former 1,000 acre munitions manufacturing facility for the City of Santa B3-48
cont.

Clarita. The site is impacted with a number of contaminants including perchlorate, unexploded ordinance, and volatile organic compounds (VOCs). The site is currently under a number of regulatory consent orders, including an Immanent and Substantial Endangerment Order. Dr. Clark assisted the impacted municipality with the development of remediation strategies, interaction with the responsible parties and stakeholders, as well as interfacing with the regulatory agency responsible for oversight of the site cleanup.

Client: Confidential
Dr. Clark performed a historical dose reconstruction for community members exposed to radioactive waste released into the environment from legacy storage facilities. The releases resulted in impacts to soils, sediments, surface waters, and groundwater in the vicinity of the sites. The analysis was performed in general accordance with the methods outlined by the Agency for Toxic Substances Control (ATSDR) for assessing radiation doses from historical source areas in the community.

Client: Confidential
Dr. Clark performed a dose assessment of an individual occupationally exposed to metals and silica from fly ash who later developed cancer. A review of the individual’s medical and occupational history was performed to prepare opinions regarding his exposure and later development of cancer.

Client: Brayton Purcell, Novato, California
Dr. Clark performed a toxicological assessment of residents exposed to methyl-tertiary butyl ether (MTBE) from leaking underground storage tanks (LUSTs) adjacent to the subject property. The symptomology of residents and guests of the subject property were evaluated against the known outcomes in published literature to exposure to MTBE. The study found that residents had been exposed to MTBE in their drinking water; that concentrations of MTBE detected at the site were above regulatory guidelines; and, that the symptoms and outcomes expressed by residents and guests were consistent with symptoms and outcomes documented in published literature.

Client: Confidential
Dr. Clark performed a toxicological assessment of an individual occupationally exposed to hexavalent chromium who later developed cancer. A review of the individual’s medical and occupational history was performed to prepare opinions regarding her exposure and later development of cancer.

B3-48
cont.

Client: Covanta Energy, Westwood, California
Evaluated health risk from metals in biosolids applied as soil amendment on agricultural lands. The biosolids were created at a forest waste cogeneration facility using 96% whole tree wood chips and 4 percent green waste. Mass loading calculations were used to estimate Cr(VI) concentrations in agricultural soils based on a maximum loading rate of 40 tons of biomass per acre of agricultural soil. The results of the study were used by the Regulatory agency to determine that the application of biosolids did not constitute a health risk to workers applying the biosolids or to residences near the agricultural lands.

Client: Kaiser Venture Incorporated, Fontana, California Prepared PBPK assessment of lead risk of receptors at a 1,100-acre former steel mill. This evaluation was used as the basis for granting closure of the site by lead regulatory agency.

RISK ASSESSMENTS/REMEDIAL INVESTIGATIONS
Kaiser Ventures Incorporated, Fontana, California
Prepared health risk assessment of semi-volatile organic chemicals and metals for a fiftyyear old wastewater treatment facility used at a 1,100-acre former steel mill. This evaluation was used as the basis for granting closure of the site by lead regulatory agency.

ANR Freight - Los Angeles, California
Prepared a comprehensive Preliminary Endangerment Assessment (PEA) of petroleum hydrocarbon and metal contamination of a former freight depot. This evaluation was as the basis for reaching closure of the site with lead regulatory agency.

Kaiser Ventures Incorporated, Fontana, California
Prepared comprehensive health risk assessment of semi-volatile organic chemicals and metals for 23-acre parcel of a 1,100-acre former steel mill. The health risk assessment was used to determine clean up goals and as the basis for granting closure of the site by lead regulatory agency. Air dispersion modeling using ISCST3 was performed to determine downwind exposure point concentrations at sensitive receptors within a 1 kilometer radius of the site. The results of the health risk assessment were presented at a public meeting sponsored by the Department of Toxic Substances Control (DTSC) in the community potentially affected by the site.

B3-48
cont.

Unocal Corporation - Los Angeles, California
Prepared comprehensive assessment of petroleum hydrocarbons and metals for a former petroleum service station located next to sensitive population center (elementary school).

The assessment used a probabilistic approach to estimate risks to the community and was used as the basis for granting closure of the site by lead regulatory agency.

Client: Confidential, Los Angeles, California
Managed oversight of remedial investigation most contaminated heavy metal site in California. Lead concentrations in soil excess of 68,000,000 parts per billion (ppb) have been measured at the site. This State Superfund Site was a former hard chrome plating operation that operated for approximately 40-years.

Client: Confidential, San Francisco, California
Coordinator of regional monitoring program to determine background concentrations of metals in air. Acted as liaison with SCAQMD and CARB to perform co-location sampling and comparison of accepted regulatory method with ASTM methodology.

Client: Confidential, San Francisco, California
Analyzed historical air monitoring data for South Coast Air Basin in Southern California and potential health risks related to ambient concentrations of carcinogenic metals and volatile organic compounds. Identified and reviewed the available literature and calculated risks from toxins in South Coast Air Basin.

IT Corporation, North Carolina
Prepared comprehensive evaluation of potential exposure of workers to air-borne VOCs at hazardous waste storage facility under SUPERFUND cleanup decree. Assessment used in developing health based clean-up levels.

Professional Associations
American Public Health Association (APHA)
Association for Environmental Health and Sciences (AEHS) American Chemical Society (ACS)
International Society of Environmental Forensics (ISEF) Society of Environmental Toxicology and Chemistry (SETAC) Publications and Presentations:

Books and Book Chapters
B3-48
cont.

Sullivan, P., J.J. J. Clark, F.J. Agardy, and P.E. Rosenfeld. (2007). Synthetic Toxins In The Food, Water and Air of American Cities. Elsevier, Inc. Burlington, MA.

Sullivan, P. and J.J. J. Clark. 2006. Choosing Safer Foods, A Guide To Minimizing Synthetic Chemicals In Your Diet. Elsevier, Inc. Burlington, MA.

Sullivan, P., Agardy, F.J., and J.J.J. Clark. 2005. The Environmental Science of Drinking Water. Elsevier, Inc. Burlington, MA.

Sullivan, P.J., Agardy, F.J., Clark, J.J.J. 2002. America’s Threatened Drinking Water:

Hazards and Solutions. Trafford Publishing, Victoria B.C.

Clark, J.J.J. 2001. “TBA: Chemical Properties, Production & Use, Fate and Transport, Toxicology, Detection in Groundwater, and Regulatory Standards” in Oxygenates in the Environment. Art Diaz, Ed.. Oxford University Press: New York.

Clark, J.J.J. 2000. “Toxicology of Perchlorate” in Perchlorate in the Environment.

Edward Urbansky, Ed. Kluwer/Plenum: New York.

Clark, J.J.J. 1995. Probabilistic Forecasting of Volatile Organic Compound Concentrations At The Soil Surface From Contaminated Groundwater. UMI.

Baker, J.; Clark, J.J.J.; Stanford, J.T. 1994. Ex Situ Remediation of Diesel Contaminated Railroad Sand by Soil Washing. Principles and Practices for Diesel Contaminated Soils, Volume III. P.T. Kostecki, E.J. Calabrese, and C.P.L. Barkan, eds. Amherst Scientific Publishers, Amherst, MA. pp 89-96.

Journal and Proceeding Articles
Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008) A Statistical Analysis Of Attic Dust And Blood Lipid Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equialency Quotients (TEQ) In Two Populations Near Wood Treatment Facilities. Organohalogen Compounds, Volume 70 (2008) page 002254.

Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008) Methods For Collect Samples For Assessing Dioxins And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds, Volume 70 (2008) page 000527 Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (2007). “Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility.” Environmental Research. 105:194-199.

Rosenfeld, P.E., Clark, J. J., Hensley, A.R., and Suffet, I.H. 2007. “The Use Of An Odor Wheel Classification For The Evaluation of Human Health Risk Criteria For Compost Facilities” Water Science & Technology. 55(5): 345-357.

Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. 2006. “Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility.” The 26th International Symposium on Halogenated Persistent Organic Pollutants – B3-48
cont.

DIOXIN2006, August 21 – 25, 2006. Radisson SAS Scandinavia Hotel in Oslo Norway.

Rosenfeld, P.E., Clark, J. J. and Suffet, I.H. 2005. “The Value Of An Odor Quality Classification Scheme For Compost Facility Evaluations” The U.S. Composting Council’s 13th Annual Conference January 23 - 26, 2005, Crowne Plaza Riverwalk, San Antonio, TX.

Rosenfeld, P.E., Clark, J. J. and Suffet, I.H. 2004. “The Value Of An Odor Quality Classification Scheme For Urban Odor” WEFTEC 2004. 77th Annual Technical Exhibition & Conference October 2 - 6, 2004, Ernest N. Morial Convention Center, New Orleans, Louisiana.

Clark, J.J.J. 2003. “Manufacturing, Use, Regulation, and Occurrence of a Known Endocrine Disrupting Chemical (EDC), 2,4-Dichlorophnoxyacetic Acid (2,4-D) in California Drinking Water Supplies.” National Groundwater Association Southwest Focus Conference: Water Supply and Emerging Contaminants. Minneapolis, MN.

March 20, 2003.

Rosenfeld, P. and J.J.J. Clark. 2003. “Understanding Historical Use, Chemical Properties, Toxicity, and Regulatory Guidance” National Groundwater Association Southwest Focus Conference: Water Supply and Emerging Contaminants. Phoenix, AZ. February 21, 2003.

Clark, J.J.J., Brown A. 1999. Perchlorate Contamination: Fate in the Environment and Treatment Options. In Situ and On-Site Bioremediation, Fifth International Symposium. San Diego, CA, April, 1999.

Clark, J.J.J. 1998. Health Effects of Perchlorate and the New Reference Dose (RfD).

Proceedings From the Groundwater Resource Association Seventh Annual Meeting, Walnut Creek, CA, October 23, 1998.

Browne, T., Clark, J.J.J. 1998. Treatment Options For Perchlorate In Drinking Water.

Proceedings From the Groundwater Resource Association Seventh Annual Meeting, Walnut Creek, CA, October 23, 1998.

Clark, J.J.J., Brown, A., Rodriguez, R. 1998. The Public Health Implications of MtBE and Perchlorate in Water: Risk Management Decisions for Water Purveyors.

Proceedings of the National Ground Water Association, Anaheim, CA, June 3-4, 1998.

Clark J.J.J., Brown, A., Ulrey, A. 1997. Impacts of Perchlorate On Drinking Water In The Western United States. U.S. EPA Symposium on Biological and Chemical Reduction of Chlorate and Perchlorate, Cincinnati, OH, December 5, 1997.

Clark, J.J.J.; Corbett, G.E.; Kerger, B.D.; Finley, B.L.; Paustenbach, D.J. 1996. Dermal Uptake of Hexavalent Chromium In Human Volunteers: Measures of Systemic Uptake From Immersion in Water At 22 PPM. Toxicologist. 30(1):14.

B3-48
cont.

Dodge, D.G.; Clark, J.J.J.; Kerger, B.D.; Richter, R.O.; Finley, B.L.; Paustenbach, D.J. 1996. Assessment of Airborne Hexavalent Chromium In The Home Following Use of Contaminated Tapwater. Toxicologist. 30(1):117-118.

Paulo, M.T.; Gong, H., Jr.; Clark, J.J.J. (1992). Effects of Pretreatment with Ipratroprium Bromide in COPD Patients Exposed to Ozone. American Review of Respiratory Disease. 145(4):A96.

Harber, P.H.; Gong, H., Jr.; Lachenbruch, A.; Clark, J.; Hsu, P. (1992). Respiratory Pattern Effect of Acute Sulfur Dioxide Exposure in Asthmatics. American Review of Respiratory Disease. 145(4):A88.

McManus, M.S.; Gong, H., Jr.; Clements, P.; Clark, J.J.J. (1991). Respiratory Response of Patients With Interstitial Lung Disease To Inhaled Ozone. American Review of Respiratory Disease. 143(4):A91.

Gong, H., Jr.; Simmons, M.S.; McManus, M.S.; Tashkin, D.P.; Clark, V.A.; Detels, R.; Clark, J.J. (1990). Relationship Between Responses to Chronic Oxidant and Acute Ozone Exposures in Residents of Los Angeles County. American Review of Respiratory Disease. 141(4):A70.

Tierney, D.F. and J.J.J. Clark. (1990). Lung Polyamine Content Can Be Increased By Spermidine Infusions Into Hyperoxic Rats. American Review of Respiratory Disease. 139(4):A41.

B3-48
cont.

ATTACHMENT B

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–ǣ 2740 West Nielsen Avenue Office/Warehouse Project
Fresno, California
Review and Comment on Draft EIR Noise Analysis
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Mitigated Negative Declaration for Development Permit Application No. P21-02699 & Tentative Parcel Map No P21-05930 (“MND”)
Project Address: 2740 West Nielsen Avenue, Fresno, California City of Fresno, Planning and Development Department
May 13, 2022
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Public Review Draft Environmental Impact Report (“DEIR”) 2740 West Nielsen Avenue Office/Warehouse Project
LSA Project No. SNN2102
February 2023
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B3-50
B3-49
2740 W Nielsen Ave, Fresno, Calif.

Review of DEIR Noise Analysis
2 Adverse Effects of Noise1
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—Ž– –‘ ˆƒŽŽƒ•Ž‡‡’ǡ„›™ƒ‹‰
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‘˜‡‡– ȋȌ •Ž‡‡’Ǥ  ‘‹•‡ ‡š’‘•—”‡ ˆ‘” ’‡‘’Ž‡ ™Š‘ ƒ”‡ •Ž‡‡’‹‰ Šƒ• ƒŽ•‘ „‡‡ Ž‹‡† –‘ ‹
”‡ƒ•‡†„Ž‘‘†’”‡••—”‡ǡ‹
”‡ƒ•‡†Š‡ƒ”–”ƒ–‡ǡ‹
”‡ƒ•‡‹„‘†›‘˜‡‡–•ǡƒ†‘–Š‡”’Š›•‹‘Ž‘‰‹
ƒŽ
‡ˆˆ‡
–•Ǥ‘–•—”’”‹•‹‰Ž›ǡ’‡‘’Ž‡™Š‘•‡•Ž‡‡’‹•†‹•–—”„‡†„›‘‹•‡‘ˆ–‡‡š’‡”‹‡ ‡•‡
‘†ƒ”›‡ˆˆ‡
–•
•—
Šƒ•‹
”‡ƒ•‡†ˆƒ–‹‰—‡ǡ†‡’”‡••‡†‘‘†ǡƒ††‡
”‡ƒ•‡†™‘”’‡”ˆ‘”ƒ
‡Ǥ
Cardiovascular and Physiological Effects. 
—ƒǯ• „‘†‹Ž› ”‡ƒ
–‹‘• –‘ ‘‹•‡ƒ”‡ ”‘‘–‡†‹ –Š‡
Dzˆ‹‰Š–‘”ˆŽ‹‰Š–dz”‡•’‘•‡–Šƒ–‡˜‘Ž˜‡†™Š‡ƒ›‘‹•‡••‹‰ƒŽ‡†‹‹‡–†ƒ‰‡”ǤŠ‡•‡‹ Ž—†‡
‹
”‡ƒ•‡†„Ž‘‘†’”‡••—”‡ǡ‡Ž‡˜ƒ–‡†Š‡ƒ”–”ƒ–‡ǡƒ†˜ƒ•‘
‘•–”‹
–‹‘Ǥ”‘Ž‘‰‡†‡š’‘•—”‡ –‘ƒ
—–‡
‘‹•‡•
ƒ”‡•—Ž–‹’‡”ƒ‡–‡ˆˆ‡
–••—
Šƒ•Š›’‡”–‡•‹‘ƒ†Š‡ƒ”–†‹•‡ƒ•‡Ǥ
Impaired Cognitive Performance.–—†‹‡•Šƒ˜‡‡•–ƒ„Ž‹•Š‡†–Šƒ–‘‹•‡‡š’‘•—”‡‹’ƒ‹”•’‡‘’Ž‡ǯ• ƒ„‹Ž‹–‹‡•–‘’‡”ˆ‘”
‘’Ž‡š–ƒ••ȋ–ƒ••–Šƒ–”‡“—‹”‡ƒ––‡–‹‘–‘†‡–ƒ‹Ž‘”ƒƒŽ›–‹ ƒŽ’”‘
‡••‡•Ȍƒ†
‹–ƒ‡•”‡ƒ†‹‰ǡ’ƒ›‹‰ƒ––‡–‹‘ǡ•‘Ž˜‹‰’”‘„Ž‡•ǡƒ†‡‘”‹œ‹‰‘”‡†‹ˆˆ‹ —Ž–ǤŠ‹•‹•™Š›
–Š‡”‡ƒ”‡•–ƒ†ƒ”†•ˆ‘”
Žƒ••”‘‘„ƒ
‰”‘—†‘‹•‡Ž‡˜‡Ž•ƒ†™Š›‘ˆˆ‹
‡•ƒ†Ž‹„”ƒ”‹‡•ƒ”‡†‡•‹‰‡†
–‘ ’”‘˜‹†‡ “—‹‡– ™‘” ‡˜‹”‘‡–•Ǥ  Š‹Ž‡ •Š‡Ž–‡”‹‰Ǧ‹Ǧ’Žƒ ‡ †—”‹‰ –Š‡ 
Ǧͳͻ ’ƒ†‡‹
ǡ
ƒ›’‡‘’Ž‡ƒ”‡ˆ‹†‹‰™‘”‹‰ƒ†Ž‡ƒ”‹‰‘”‡†‹ˆˆ‹ —Ž–„‡
ƒ—•‡–Š‡‹”Š‘‡‡˜‹”‘‡–‹•‘–
ƒ•“—‹‡–ƒ•–Š‡‹”‘ˆˆ‹
‡‘”•
Š‘‘Ž™ƒ•Ǥ
1 More information on these and other adverse effects of noise may be found in Guidelines for Community Noise, eds B Berglund, T Lindvall, and D Schwela, World Health Organization, Geneva, Switzerland, 1999. (https://www.who.int/docstore/peh/noise/Comnoise-1.pdf) B3-51
2740 W Nielsen Ave, Fresno, Calif.

Review of DEIR Noise Analysis
3 Comments on Operational Noise Analysis – Traffic Noise —”
‘‡–•‘–Š‡ƒ›•—

‹
–Ž›„‡•—ƒ”‹œ‡†ƒ•ǣ
ͳǤ Š‡ˆƒ‹Ž‡†–‘ƒ

‘—–ˆ‘”–”—
‘‹•‡ˆ”‘–Š‡’”‘’‘•‡†ˆƒ
‹Ž‹–›ǡƒ†
ʹǤ Š‡•‡Ž‡
–‹˜‡Ž›
Š‘•‡™Š‹
Š‹–›’‘Ž‹
›–‘—•‡–‘‡•–ƒ„Ž‹•Š –Š”‡•Š‘Ž†•‘ˆ•‹‰‹ˆ‹
ƒ
‡ǡ
–Š‡”‡„›’‘–‡–‹ƒŽŽ›ˆƒ‹Ž‹‰–‘‹†‡–‹ˆ›•‘‡•‹‰‹ˆ‹
ƒ–‹’ƒ
–Ǥ
Š‡

‘””‡
–•–Š‡ˆ‹”•–ˆƒ‹Ž‹‰ǡƒ†ǡ‹†‘‹‰•‘ǡ•—„•–ƒ–‹ƒ–‡•–Š‡•‡ ‘†ˆƒ‹Ž‹‰Ǥ
‘Ž‹
›ǦͳǦƒ‘ˆ ”‡•‘
‡‡”ƒŽŽƒǡŠƒ’–‡”ͻǡ‘‹•‡ƒ†ƒˆ‡–›ǡ•–ƒ–‡•ǣ
Desirable and Generally Acceptable Exterior Noise Environment.•–ƒ„Ž‹•Š͸ͷ†† ‘”ƒ•–Š‡•–ƒ†ƒ”†ˆ‘”–Š‡†‡•‹”ƒ„Ž‡ƒš‹—ƒ˜‡”ƒ‰‡‡š–‡”‹‘”‘‹•‡Ž‡˜‡Ž•ˆ‘”†‡ˆ‹‡† —•ƒ„Ž‡‡š–‡”‹‘”ƒ”‡ƒ•‘ˆ”‡•‹†‡–‹ƒŽƒ†‘‹•‡Ǧ•‡•‹–‹˜‡—•‡•ǤǤǤʹ

–‹•˜‡”›‹’‘”–ƒ––Šƒ–
‹–‹‡•Ž‹‡ ”‡•‘ƒ†‘’–ƒ„•‘Ž—–‡•–ƒ†ƒ”†•ˆ‘”–Š‡‘‹•‡‡˜‹”‘‡–•‘ˆ –Š‡‹”
‹–‹œ‡•„‡
ƒ—•‡‹ˆ‘Ž›”‡Žƒ–‹˜‡•–ƒ†ƒ”†•ƒ”‡—•‡†ȂŽ‹‡–Š‡•‘Ž‡•–ƒ†ƒ”†ƒ†‘’–‡†„›–Š‡ 
Ȃ –Š‡–Š‡”‡™‘—Ž†Ž‹–‡”ƒŽŽ›„‡‘Ž‹‹––‘‡˜‹”‘‡–ƒŽ‘‹•‡‡š’‘•—”‡‘˜‡”–‹‡Ǥ— Šƒ‘–‹‘

Ž‡ƒ”Ž›”—•
‘–”ƒ”›–‘–Š‡•’‹”‹–‘ˆǤ
Š‡
ƒ†‘’–•ƒ•–Š‡•‹‰‹ˆ‹
ƒ
‡
”‹–‡”‹ƒˆ‘”–”ƒˆˆ‹
‘‹•‡ƒ”‡Žƒ–‹˜‡‹
”‡ƒ•‡‘ˆ͵ǤͲ†ǡƒ†
‹–
‘
Ž—†‡•–Šƒ––Š‡”‡•‹†‡
‡•ƒŽ‘‰‹‡Ž•‡˜‡—‡™‹ŽŽ‘–„‡•‹‰‹ˆ‹
ƒ–Ž›‹’ƒ
–‡†„›’”‘Œ‡
–
‘‹•‡„‡
ƒ—•‡–Š‡‹
”‡ƒ•‡™‹ŽŽ„‡ǡƒ–‘•–ǡʹǤͳ†Ǥȏ
ƒ–’ǤͶǤͻǦʹͳȐŠ‡‘„˜‹‘—•ˆƒŽŽƒ
›‘ˆ
–Š‹• ƒƒŽ›•‹•‹• –Šƒ–‹ˆ –Š‡ ’”‘Œ‡
– ™ƒ–‡† –‘ ‡š’ƒ†‹–• ‘’‡”ƒ–‹‘•ǡ •ƒ›ǡ ͷ ›‡ƒ”• ƒˆ–‡”‹– „‡ ‘‡•
‘’‡”ƒ–‹‘ƒŽǡ –Š‡ ‡š–

‘—Ž† ƒ†‘’– –Š‹• •ƒ‡ –Š”‡•Š‘Ž†ǡ –Š‡ ‘‹•‡
‘—Ž†‹
”‡ƒ•‡ „› ƒ‘–Š‡”
ʹǤͳ†ȋ–Š‡„ƒ•‡Ž‹‡„‡‹‰Dz”‡•‡–dz–‘–Š‡–Š‡Ǧ’”‡˜ƒŽ‡– ‘†‹–‹‘•Ȍǡƒ†–Šƒ–™‘—Ž†ƒŽ•‘„‡
†‡‡‡†ƒŽ‡••Ǧ–ŠƒǦ•‹‰‹ˆ‹
ƒ–‹’ƒ
–†‡•’‹–‡–Š‡ͶǤʹ†‹
”‡ƒ•‡”‡Žƒ–‹˜‡–‘–‘†ƒ›ǯ•
—””‡–

‘†‹–‹‘•ǤŠ‡
‘–‹—ƒŽ—•‡‘ˆƒ”‡Žƒ–‹˜‡–Š”‡•Š‘Ž†‡ƒ„Ž‡•’‹‡
‡‡ƒŽ‹‰’”‘Œ‡
–†‡˜‡Ž‘’‡–™‹–Š
•‹‰‹ˆ‹
ƒ–Ž‘‰Ǧ–‡”‹’ƒ
–•–Šƒ–‡˜ƒ†‡‹†‡–‹ˆ‹
ƒ–‹‘Ǥ
Š‡‘„˜‹‘—•™ƒ›–‘
Ž‘•‡–Š‹•Ž‘‘’Š‘Ž‡‹–Š‡ƒ’’Ž‹
ƒ–‹‘‘ˆ‹•–‘ƒ†‘’–ƒƒ„•‘Ž—–‡–Š”‡•Š‘Ž†
‹
‘Œ—
–‹‘™‹–Šǡ‘–‹Ž‹‡—‘ˆǡƒ”‡Žƒ–‹˜‡–Š”‡•Š‘Ž†ǤƒŽ–”ƒ•”‡ ‘‰‹œ‡•–Š‡‡‡†ˆ‘”„‘–Š–›’‡•
‘ˆ•–ƒ†ƒ”†•™Š‡†‡–‡”‹‹‰‹’ƒ
–•ǣ
”ƒˆˆ‹
‘‹•‡‹’ƒ
–•ƒ•†‡ˆ‹‡†‹ʹ͵ ͹͹ʹǤͷ‘

—”™Š‡–Š‡’”‡†‹
–‡†‘‹•‡Ž‡˜‡Ž‹–Š‡
†‡•‹‰ ›‡ƒ” ƒ’’”‘ƒ
Š‡• ‘” ‡š
‡‡†• –Š‡ ‘‹•‡ „ƒ–‡‡– ”‹–‡”‹ƒ ȋȌ •’‡
‹ˆ‹‡† ‹
ʹ͵ ͹͹ʹǡ ‘” ƒ ’”‡†‹
–‡† ‘‹•‡ Ž‡˜‡Ž •—„•–ƒ–‹ƒŽŽ› ‡š
‡‡†• –Š‡ ‡š‹•–‹‰ ‘‹•‡ Ž‡˜‡Ž ȋƒ
Dz•—„•–ƒ–‹ƒŽdz‘‹•‡‹
”‡ƒ•‡ȌǤ͵
2 The day-night average sound level (Ldn) is a 24-hour weighted average that incorporates a 10 dBA penalty during the night hours (10 p.m. to 7 a.m.) to account for the heighted sensitivity of people to noise during the night. The community noise exposure level (CNEL) additionally includes a 5 dBA penalty during the evening hours (7 p.m. to 10 p.m.). For transportation-dominated environments, the Ldn and CNEL are very similar, with the CNEL typically being higher than the Ldn by 0.1 to 0.5 dBA. In environmental acoustics, they are used interchangeably. 3 California Department of Transportation, Division of Environmental Analysis. Traffic Noise Analysis Protocol for New Highway Construction, Reconstruction Projects, and Retrofit Barrier Projects. April 2020. p. 3-1.

B3-53
B3-52
2740 W Nielsen Ave, Fresno, Calif.

Review of DEIR Noise Analysis
4 Š‡ʹ͵ ͹͹ʹ‘‹•‡„ƒ–‡‡–”‹–‡”‹ƒƒ”‡ƒ„•‘Ž—–‡ǡ‘–”‡Žƒ–‹˜‡ǡ˜ƒŽ—‡•Ǥ Š‡ ‡†‡”ƒŽ”ƒ•‹–†‹‹•–”ƒ–‹‘ȋ ȌƒŽ•‘”‡
‘‰‹œ‡•–Šƒ–ƒ•–Š‡ƒ„•‘Ž—–‡Ž‡˜‡Ž‘ˆ‘‹•‡‡š’‘•—”‡
‹
”‡ƒ•‡•ǡ–Š‡”‡Žƒ–‹˜‡‹
”‡ƒ•‡–Šƒ–”‡•—Ž–•‹ƒ•‹‰‹ˆ‹
ƒ–‹’ƒ
–”‡†—
‡•Ǥ
‹–•ˆ‘”—Žƒ–‹‘‘ˆ‘‹•‡
‹’ƒ
–ƒ••‡••‡–ǡƒ͵††‹
”‡ƒ•‡‹‘‹•‡‡š’‘•—”‡ƒ–”‡•‹†‡
‡•™‘—Ž†‘Ž›„‡ƒŽŽ‘™‡†‹ˆ
–Š‡‡š‹•–‹‰‘‹•‡‡š’‘•—”‡‹•ͷͷ††‘”Ž‡••Ǥ„‘˜‡–Šƒ–ǡ–Š‡ƒŽŽ‘™ƒ„Ž‡‹ ”‡ƒ•‡‹•’”‘‰”‡••‹˜‡Ž›
•ƒŽŽ‡”ǤŠ‡”‡–Š‡‡š‹•–‹‰‘‹•‡‡š’‘•—”‡‹•͸ͶǤͲ†ǡƒ•‹–‹•ƒŽ‘‰‹‡Ž•‡˜‡—‡ƒ

‘”†‹‰
–‘–Š‡
ǡ–Š‡ƒŽŽ‘™ƒ„Ž‡‹
”‡ƒ•‡‹•ͳǤͷ†Ǥȏ
ƒ„Ž‡ͶǤͻǤƒ–’ǤͶǤͻǦͳͻȐ
Reference: FTA Transit Noise and Vibration Impact Assessment Manual, FTA Report No. 0123, September 2018. p. 30.
ƒ„Ž‡
’”‡•‡–•‹ˆ‘”ƒ–‹‘‡š–”ƒ
–‡†ˆ”‘
ƒ„Ž‡ͶǤͻǤȏ’ǤͶǤͻǦͳͻȐǤ‘–‡–Šƒ–ƒ–‡˜‡”›’‘‹–‹ –‹‡–Šƒ––Š‡‘‹•‡‹•ƒ••‡••‡†ǡ–Š‡‘‹•‡‡š’‘•—”‡‰‘‡•ˆ”‘ƒŽ‡˜‡Ž–Šƒ–‹•Ž‘™‡”–Šƒ–Šƒ–‡•–ƒ„Ž‹•Š‡† „›
‡‡”ƒŽŽƒ‘Ž‹
›ǦͳǦƒȋ͸ͷ†Ȍ–‘‘‡–Šƒ–‹•Š‹‰Š‡”ǤŠ‹•
‘•–‹–—–‡•ƒ•‹‰‹ˆ‹
ƒ–‘‹•‡
‹’ƒ
–Ǥ
Table I Traffic Noise Levels Without and With Proposed Project Roadway Segment
CNEL (dBA) 50 ft from Centerline of Nearest Lane
Existing Opening Year Year 2035
Without With Without With Without With
Nielsen Ave
between Marks and Hughes 64.0 66.1 64.4 66.4 64.4 66.4
B3-53
cont.

B3-54
2740 W Nielsen Ave, Fresno, Calif.

Review of DEIR Noise Analysis
5 Comments on Construction Noise Analysis
Š‡’”‘Œ‡
–
‘•–”—
–‹‘‘‹•‡ƒƒŽ›•‹•‹•’”‡•‡–‡†‘’ƒ‰‡•ͶǤͻͳͷ–‘ͶǤͻǦͳͺ‘ˆ–Š‡ Ǥ’ƒ‰‡
ͶǤͻǦͳ͸ǡ ”‡ˆ‡”‡
‡ ‘‹•‡ Ž‡˜‡Ž• ˆ‘” ˜ƒ”‹‘—• –›’‡• ‘ˆ
‘•–”—
–‹‘ ‡“—‹’‡– ƒ”‡ ’”‡•‡–‡†Ǥ  Š‡•‡
”‡ˆ‡”‡
‡Ž‡˜‡Ž•ƒ”‡–ƒ‡ˆ”‘–Š‡
‘ƒ†™ƒ›‘•–”—
–‹‘‘‹•‡‘†‡Žƒ†ƒ”‡ƒ

‡’–ƒ„Ž‡Ǥ
’ƒ‰‡ͶǤͻǦͳ͹ǡ–Š‡
’”‡•‡–•‡“—ƒ–‹‘•–‘
ƒŽ
—Žƒ–‡–Š‡
‘’‘•‹–‡ƒ˜‡”ƒ‰‡ȋ‡“—‹˜ƒŽ‡–Ȍ‘‹•‡
Ž‡˜‡Žˆ‘”
‘•–”—
–‹‘‡“—‹’‡–ǡƒŽ‡˜‡Ž–Šƒ––ƒ‡•‹–‘ƒ

‘—––Š‡”‡ˆ‡”‡
‡‘‹•‡‡‹••‹‘Ž‡˜‡Žǡ
–Š‡ƒ‘—–‘ˆ–‹‡‡ƒ
Š’‹‡
‡‘ˆ‡“—‹’‡–‹––›’‹
ƒŽŽ›—•‡†ǡ†‹•–ƒ
‡ǡƒ†Ȃ’‘–‡–‹ƒŽŽ›Ȃ–Š‡–‘–ƒŽ
ƒ‘—– ‘ˆ‡“—‹’‡–ƒ–‹
‹’ƒ–‡† –‘ „‡ —•‡†‘ •‹–‡Ǥ 
™”‹–‡ Dz’‘–‡–‹ƒŽŽ›dz „‡
ƒ—•‡ –Š‡
 ‘Ž›

ƒŽ
—Žƒ–‡†Dz–Š‡
‘’‘•‹–‡‘‹•‡Ž‡˜‡Ž‘ˆ–Š‡–™‘Ž‘—†‡•–’‹‡
‡•‘ˆ‡“—‹’‡– ˆ‘”‡ƒ
Š
‘•–”—
–‹‘
’Šƒ•‡dzǤȏ
ƒ–’ǤͶǤͻǦͳ͹ǤŠ‹•‹•ƒ
‘‘‡””‘”–Šƒ–•–‡•ˆ”‘ ‰—‹†ƒ
‡–Šƒ–’”‡Ž‹‹ƒ”‹Ž›ǡ
„‡ˆ‘”‡—
Š‹•‘™ƒ„‘—–
‘•–”—
–‹‘ǡ–Š‡‘”†‡”‘ˆƒ‰‹–—†‡‘ˆ
‘•–”—
–‹‘‘‹•‡ƒ›„‡Šƒ†
„›
‘„‹‹‰–Š‡Ž‡˜‡Ž•‘ˆ –Š‡ –™‘Ž‘—†‡•–’‹‡
‡•‘ˆ‡“—‹’‡–ƒ••—‹‰–Š‡›ƒ”‡”—‹‰ƒ– ˆ—ŽŽ
’‘™‡”ͳͲͲΨ‘ˆ–Š‡–‹‡Ǥ
–Š‹•ƒ––‡”ǡ–Š‡–›’‡•ƒ†—„‡”‘ˆ‡“—‹’‡–‹•‘™‹†‡–ƒ‹Žˆ”‘ –Š‡ƒ‹”“—ƒŽ‹–›ƒ••‡••‡–ǡ•‘‹–‹•ƒ’’”‘’”‹ƒ–‡–‘
‘†—
–ƒ†‡–ƒ‹Ž‡†
ƒŽ
—Žƒ–‹‘‘ˆ
‘•–”—
–‹‘‘‹•‡Ǥ
•ƒƒ•‹†‡ǡ–Š‡
ƒŽ
—Žƒ–‹‘–Šƒ––Š‡
ƒ‡•†‘‡•‘–ƒ••—‡—•ƒ‰‡ͳͲͲΨ‘ˆ–Š‡–‹‡ˆ‘”–Š‡–™‘ Ž‘—†‡•–’‹‡
‡•‘ˆ‡“—‹’‡–ǡ•‘†‘‡•‘–‡˜‡
‘’‘”–™‹–Š–Š‡ ’”‡Ž‹‹ƒ”›‰—‹†ƒ
‡Ǥ
ƒ„Ž‡

•Š‘™•ƒ’”‘’‡”ƒƒŽ›•‹•‘ˆ–Š‡‘‹•‡Ž‡˜‡Ž•ˆ‘”–Š‡ˆ‹”•––Š”‡‡’Šƒ•‡•‘ˆ ‘•–”—
–‹‘ǤŠ‡
–›’‡• ƒ† —„‡” ‘ˆ ‡“—‹’‡– ƒ”‡ –ƒ‡ ˆ”‘ –Š‡   ’’‡†‹šǡ ƒŽ‘† —–’—– Š‡‡–•ǡ
ͻȀʹͲȀʹͲͲʹǡ’ǤͻǤŠ‡”‡ˆ‡”‡
‡‡‹••‹‘Ž‡˜‡Ž•ȋǤ ǤȌƒ†—•ƒ‰‡ˆƒ
–‘”•ȋǤ ǤȌƒ”‡ˆ”‘ƒ„Ž‡ͶǤͻǤ‘ˆ
–Š‡
Ǥ ‹ƒŽŽ›ǡ–Š‡Dzƒ˜‡”ƒ‰‡ƒ
‘—•–‹
ƒŽ†‹•–ƒ
‡dz—•‡†ˆ‘”–Š‡
ƒŽ
—Žƒ–‹‘•‹•ǡƒ•–Š‡
‡š’Žƒ‹•ǡ
Dz
ƒŽ
—Žƒ–‡†„›—Ž–‹’Ž›‹‰–Š‡•Š‘”–‡•–†‹•–ƒ
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B3-55
B3-56
B3-58
B3-57
2740 W Nielsen Ave, Fresno, Calif.

Review of DEIR Noise Analysis
6 Table II Construction Noise Calculations
Table III Construction Noise Assessment
Site Preparation
Equipment E.L. U.F. No. Distance Lmax Leq
Dozer 85 40% 3 471 ft 66 66.3
Tractor/Loader/Backhoe 84 40% 4 471 ft 65 66.6
Total 66 69.4
Grading
Equipment E.L. U.F. No. Distance Lmax Leq
Excavator 85 40% 2 471 ft 66 64.5
Grader 85 40% 1 471 ft 66 61.5
Dozer 85 40% 1 471 ft 66 61.5
Scraper 85 40% 2 471 ft 66 64.5
Tractor/Loader/Backhoe 84 40% 2 471 ft 65 63.5
Total 66 70.3
Bldg Construction
Equipment E.L. U.F. No. Distance Lmax Leq
Crane 85 16% 1 471 ft 66 57.6
Forklift 85 20% 3 471 ft 66 63.3
Tractor/Loader/Backhoe 84 40% 3 471 ft 65 65.3
Welder 73 40% 1 471 ft 54 49.5
Total 66 67.9
RCNM Ref Values @ 50 ft Noise Level @ Receptor
RCNM Ref Values @ 50 ft Noise Level @ Receptor
RCNM Ref Values @ 50 ft Noise Level @ Receptor
Site Prep Grading Building
Ambient 62.3 62.3 62.3
Construction Noise 69.4 70.3 67.9
Combined 70.2 71.0 69.0
Increase 7.9 8.7 6.7
Noise Levels, dBA Leq
B3-59
2740 W Nielsen Ave, Fresno, Calif.

Review of DEIR Noise Analysis
7 Conclusion
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B3-60
B3-61

ATTACHMENT C
1 794 Sawnee Bean Road
Thetford Center VT 05075
Norman Marshall, President
(802) 356-2969
[email protected]
May 19, 2023
Kevin T. Carmichael
Adams Broadwell Joseph & Cardozo
520 Capitol Mall, Suite 350
Sacramento, CA 95814
Subject: 2740 West Nielsen Avenue Warehouse Project
Dear Mr. Carmichael,
I have reviewed trip generation, vehicle miles traveled (VMT) impacts and greenhouse gas (GHG) impacts of the City of Fresno Draft Environmental Impact Report for a proposed warehouse project at 2740 West Nielsen Avenue (“DEIR”). I make the following findings:
1) Given that the tenants have not been identified, trip generation is highly uncertain. The trip generation study the DEIR relies on includes warehouse sites with trip rates of two to six times the rate used in the DEIR.
2) Undercounting trips translates directly into undercounting VMT and GHG. 3) The DEIR applied the Fresno COG ABM to estimate that the project would generate 19.8 VMT per employee per day. The model covers only Fresno County and excludes the portion of travel outside the county. This issue is particularly important for truck trips because major intermodal facilities are 110 – 240 miles from the proposed project. The VMT analysis should be supplemented to include an analysis of external travel with a particular focus on truck travel. 4) The DEIR answers affirmatively that the project includes transportation demand strategies. The DEIR needs to document these trip reduction programs and explain how they will be enforced on the currently unknown tenants.

B3-62
2 Project Trip Generation Could Be Much Higher Than Assumed The project is comprised of four office/warehouse buildings with a total gross floor area of 901,438 square feet. (DEIR, p. 1-3) The tenants have not been identified, and the nature of the operations are unknown at this time.

The DEIR estimates trip generation based on a 2019 study of warehouse trip generation done by WSP for the Western Riverside COG.1
This study was based on counts at 16 warehouses, segmented between 11 fulfillment centers and 5 parcel hubs. Using average rates, the DEIR calculated trip generation is shown in Table 8, partially reproduced here. The DEIR estimates that the project will generate 1,920 trips per day including 342 truck trips per day.

The data in the Western Riverside COG study are much more variable than the average rates suggest. As shown in the figure below, the different fulfillment center sites have wildly different trip generation rates, with an Amazon facility having an especially high rate. 1 https://wrcog.us/AgendaCenter/ViewFile/Agenda/_02212019-292 B3-63
3 Other businesses are copying many of Amazon’s logistics methods, so the higher rate could be applicable to many new operations. For example, the trip generation rate at the Walmart site in the Western Riverside COG study also is higher than the average used in the DEIR. If the Amazon rate were applied to the proposed Fresno warehouse, project trip generation would be twice as high as estimated in the DEIR.

The observed trip generation rates at two of the parcel hub sites are even higher, i.e., more than six times the rate used in the DEIR.

B3-63
cont.
4 To be conservative, the DEIR should apply the Amazon trip generation rate, or possibly the even higher parcel hub rate if parcel hub tenants are possible in this project. The Amazon rate is about 4.5 daily trips per 1000 square feet. With the Amazon trip generation rate, the project would generate about 4,000 trips per day, i.e., twice the 1,920 trips per day estimated in the DEIR. The parcel hub trip generation rates are about 14 trips per day per 1000 square feet. At the parcel rate, the project would generate about 12,600 trips per day, i.e., over six times as many as estimated in the DEIR.

B3-63
cont.
5 Project VMT and GHG Emissions Could Be Much Higher Than Assumed The DEIR estimates project 5.6 million VMT per year using CalEEMod Version 4.0 (DEIR Vol. 1 Appendices A – I p. 146 of 1022). In CalEEMod, VMT is calculated from a combination of the assumed daily trip generation rate (discussed above) and assumptions about trip lengths.

If the Amazon trip generation rate were used instead, the VMT output from CalEEMod would be twice as high. If the parcel hub rate were used, the VMT output would six times as high.

The default CalEEMod trip lengths were applied in the DEIR:
• Work trips 9.5 miles
• Other trips 7.3 miles
If these default values are too low, this also would cause VMT to be underestimated. The DEIR estimates that 10.2% of daily trips are made by heavy trucks (5+ axles) and another 7.6% are made by medium trucks (2-4 axles). It is likely that the average truck trip lengths are much higher than assumed in the CalEEMod default values. Major intermodal facilities are far from the project site including:
• Rail intermodal facilities in Bakersfield 110 miles,
• Rail intermodal facilities in Stockton 120 miles,
• Port of Oakland 175 miles, and
• Port of Los Angeles 240 miles.

It is impossible to fully evaluate trip lengths until more is known about the facility operations.

Any VMT underestimation translates to underestimating GHG as well.

B3-64
6 The DEIR Likely Underestimates VMT Impacts
The DEIR applied the Fresno COG ABM to estimate that the project would generate 19.8 VMT per employee per day. (DEIR, XHIBIT-6.-2740-W-Nielsen-Appendices-Vol-2_J-M-Copy.pdf, p. 396-398 of 786.

As shown in the Figure2
below, the Fresno ABM covers only Fresno County.

A significant percentage of Fresno County trips have origins or destinations that are outside the County.

As this issue is not discussed in the DEIR, it appears that all of the VMT outside the County (“external” travel) is excluded from the analysis.

This issue is particularly important for truck trips. As discussed in the previous section, major intermodal facilities are 110 – 240 miles from the proposed project. The VMT analysis should be supplemented to include an analysis of external travel with a particular focus on truck travel. 2 Fresno Council of Governments. Fresno Activity-Based Model. agendas.fresnocog.org/itemAttachments/596/II_D_Modeling_101_Slides.pdf B3-65
7 Transportation Demand Strategies Not Described in the DEIR The DEIR includes a Greenhouse Gas (GHG) Reduction Plan Update – CEQA Project Consistency Checklist as Appendix H. This checklist answers in the affirmative:
• Does the project implement pedestrian bicycle, and transit linkages with surrounding land uses and neighborhoods? For GHG Reduction Plan consistency, the project must include all sidewalks, paths, trails, and facilities required by the General Plan and Active Transportation Plan, as implemented through the Fresno Municipal Code and project conditions of approval. • Will the project accommodate a large employer (over 100 employees) and will it implement trip reduction programs such as increasing transit use, carpooling, vanpooling, bicycling, or other measures to reduce vehicle miles traveled pursuant to San Joaquin Valley Air Pollution Control District Rule 9410?
These transportation demand strategies are not described anywhere else in the DEIR, and they should be. In particular, the DEIR needs to explain how the second bullet regarding trip reduction programs will be enforced on the currently unknown tenants.

Sincerely,
Norman L. Marshall
B3-66
8 Resume
NORMAN L. MARSHALL, PRESIDENT
[email protected]
EDUCATION:

Master of Science in Engineering Sciences, Dartmouth College, Hanover, NH, 1982 Bachelor of Science in Mathematics, Worcester Polytechnic Institute, Worcester, MA, 1977 PROFESSIONAL EXPERIENCE: (33 Years, 19 at Smart Mobility, Inc.) Norm Marshall helped found Smart Mobility, Inc. in 2001. Prior to this, he was at RSG for 14 years where he developed a national practice in travel demand modeling. He specializes in analyzing the relationships between the built environment and travel behavior and doing planning that coordinates multi-modal transportation with land use and community needs.

Regional Land Use/Transportation Scenario Planning
Portland Area Comprehensive Transportation System (PACTS) – the Portland Maine Metropolitan Planning Organization. Updating regional travel demand model with new data (including AirSage), adding a truck model, and multiclass assignment including differentiation between cash toll and transponder payments.

Loudoun County Virginia Dynamic Traffic Assignment – Enhanced subarea travel demand model to include Dynamic Traffic Assignment (Cube). Model being used to better understand impacts of roadway expansion on induced travel.

Vermont Agency of Transportation-Enhanced statewide travel demand model to evaluate travel impacts of closures and delays resulting from severe storm events. Model uses innovate Monte Carlo simulations process to account for combinations of failures.

California Air Resources Board – Led team including the University of California in $250k project that reviewed the ability of the new generation of regional activity-based models and land use models to accurately account for greenhouse gas emissions from alternative scenarios including more compact walkable land use and roadway pricing. This work included hands-on testing of the most complex travel demand models in use in the U.S. today.

Climate Plan (California statewide) – Assisted large coalition of groups in reviewing and participating in the target setting process required by Senate Bill 375 and administered by the California Air Resources Board to reduce future greenhouse gas emissions through land use measures and other regional initiatives.

Chittenden County (2060 Land use and Transportation Vision Burlington Vermont region) – led extensive public visioning project as part of MPO’s long-range transportation plan update.

Flagstaff Metropolitan Planning Organization – Implemented walk, transit and bike models within regional travel demand model. The bike model includes skimming bike networks including on-road and off-road bicycle facilities with a bike level of service established for each segment.

Chicago Metropolis Plan and Chicago Metropolis Freight Plan (6-county region)— developed alternative transportation scenarios, made enhancements in the regional travel demand model, and used the enhanced B3-67
9 model to evaluate alternative scenarios including development of alternative regional transit concepts.

Developed multi-class assignment model and used it to analyze freight alternatives including congestion pricing and other peak shifting strategies.

Municipal Planning
City of Grand Rapids – Michigan Street Corridor – developed peak period subarea model including nonmotorized trips based on urban form. Model is being used to develop traffic volumes for several alternatives that are being additional analyzed using the City’s Synchro model City of Omaha - Modified regional travel demand model to properly account for non-motorized trips, transit trips and shorter auto trips that would result from more compact mixed-use development. Scenarios with different roadway, transit, and land use alternatives were modeled.

City of Dublin (Columbus region) – Modified regional travel demand model to properly account for nonmotorized trips and shorter auto trips that would result from more compact mixed-use development. The model was applied in analyses for a new downtown to be constructed in the Bridge Street corridor on both sides of an historic village center.

City of Portland, Maine – Implemented model improvements that better account for non-motorized trips and interactions between land use and transportation and applied the enhanced model to two subarea studies.

City of Honolulu – Kaka’ako Transit Oriented Development (TOD) – applied regional travel demand model in estimating impacts of proposed TOD including estimating internal trip capture.

City of Burlington (Vermont) Transportation Plan – Led team that developing Transportation Plan focused on supporting increased population and employment without increases in traffic by focusing investments and policies on transit, walking, biking and Transportation Demand Management.

Transit Planning
Regional Transportation Authority (Chicago) and Chicago Metropolis 2020 – evaluated alternative 2020 and 2030 system-wide transit scenarios including deterioration and enhance/expand under alternative land use and energy pricing assumptions in support of initiatives for increased public funding.

Capital Metropolitan Transportation Authority (Austin, TX) Transit Vision – analyzed the regional effects of implementing the transit vision in concert with an aggressive transit-oriented development plan developed by Calthorpe Associates. Transit vision includes commuter rail and BRT.

Bus Rapid Transit for Northern Virginia HOT Lanes (Breakthrough Technologies, Inc and Environmental Defense.) – analyzed alternative Bus Rapid Transit (BRT) strategies for proposed privately-developing High Occupancy Toll lanes on I-95 and I-495 (Capital Beltway) including different service alternatives (point-to-point services, trunk lines intersecting connecting routes at in-line stations, and hybrid).

Roadway Corridor Planning
I-30 Little Rock Arkansas – Developed enhanced version of regional travel demand model that integrates TransCAD with open source Dynamic Traffic Assignment (DTA) software, and used to model I-30 alternatives.

Freeway bottlenecks are modeled much more accurately than in the base TransCAD model.

B3-67
cont.
10 South Evacuation Lifeline (SELL) – In work for the South Carolina Coastal Conservation League, used Dynamic Travel Assignment (DTA) to estimate evaluation times with different transportation alternatives in coastal South Caroline including a new proposed freeway.

Hudson River Crossing Study (Capital District Transportation Committee and NYSDOT) – Analyzing long term capacity needs for Hudson River bridges which a special focus on the I-90 Patroon Island Bridge where a microsimulation VISSIM model was developed and applied.

PUBLICATIONS AND PRESENTATIONS (partial list)
DTA Love: Co-leader of workshop on Dynamic Traffic Assignment at the June 2019 Transportation Research Board Planning Applications Conference.

Forecasting the Impossible: The Status Quo of Estimating Traffic Flows with Static Traffic Assignment and the Future of Dynamic Traffic Assignment. Research in Transportation Business and Management 2018.

Assessing Freeway Expansion Projects with Regional Dynamic Traffic Assignment. Presented at the August 2018 Transportation Research Board Tools of the Trade Conference on Transportation Planning for Small and Medium Sized Communities.

Vermont Statewide Resilience Modeling. With Joseph Segale, James Sullivan and Roy Schiff. Presented at the May 2017 Transportation Research Board Planning Applications Conference.

Assessing Freeway Expansion Projects with Regional Dynamic Traffic Assignment. Presented at the May 2017 Transportation Research Board Planning Applications Conference.

Pre-Destination Choice Walk Mode Choice Modeling. Presented at the May 2017 Transportation Research Board Planning Applications Conference.

A Statistical Model of Regional Traffic Congestion in the United States, presented at the 2016 Annual Meeting of the Transportation Research Board.

MEMBERSHIPS/AFFILIATIONS
Associate Member, Transportation Research Board (TRB)
Member and Co-Leader Project for Transportation Modeling Reform, Congress for the New Urbanism (CNU) B3-67
cont.
3-229

RESPONSE TO COMMENTS DOCUMENT
S EPTEMBER 2023
2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

F RESNO, C ALIFORNIA
\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) LETTER B3
Adams Broadwell Joseph & Cardozo
Kevin Carmichael
May 19, 2023
Response B3-1: This introductory comment is noted. This comment also provides a brief project description and does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Recirculated Draft EIR. Therefore, no further response is necessary.

Response B3-2: This introductory comment asserts that the DEIR fails to adequately analyze many of the project’s significant environmental impacts and fails to propose enforceable mitigation measures that can reduce those impacts to a less than significant level. This comment is noted. Comments provided in this letter and in the technical appendices prepared by Clark and Associates, Wilson Ihrig, and Smart Mobility are further responded to below.

Response B3-3: This comment is a statement of the commenter’s interest in enforcing environmental laws in the City of Fresno. The comment is noted, but it does not raise any significant environmental issues related to the project, or the analysis contained in the Recirculated Draft EIR.

Response B3-4: This comment is a statement of the commenter’s understanding of various requirements under CEQA. The comment is noted, but it does not raise any significant environmental issues related to the project, or the analysis contained in the Recirculated Draft EIR.

Response B3-5: This comment claims that the Recirculated Draft EIR does not meet CEQA’s requirements because it fails to include an accurate and complete Project Description, rendering the entire analysis inadequate.

Section 15124 of the CEQA Guidelines states that the description of the project shall contain the following information but should not supply extensive detail beyond that needed for evaluation and review of the environmental impact:
(a) The precise location and boundaries of the proposed project shall be shown on a detailed map, preferably topographic. The location of the project shall also appear on a regional map.
(b) A statement of the objectives sought by the proposed project. A clearly written statement of objectives will help the lead agency develop a reasonable range of alternatives to evaluate in the EIR and will aid the decision makers in preparing findings or a statement of overriding considerations, if necessary. The statement of objectives should include 2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

F RESNO, C ALIFORNIA

RESPONSE TO COMMENTS DOCUMENT
S EPTEMBER 2023
3 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) -230 the underlying purpose of the project and may discuss the project benefits.
(c) A general description of the project’s technical, economic, and environmental characteristics, considering the principal engineering proposals, if any, and supporting public service facilities. (d) A statement briefly describing the intended uses of the EIR, including: a list of the agencies that are expected to use the EIR in their decision making; a list of permits and other approvals required to implement the project; and a list of related environmental review and consultation requirements of federal, State, or local laws, regulations, or policies. To the fullest extent possible, the lead agency should integrate CEQA review with these related environmental review and consultation requirements and decisions subject to CEQA should be listed, preferably in the order in which they will occur.

Chapter 3.0, Project Description, of the Recirculated Draft EIR is consistent with these requirements and describes the characteristics of the proposed project. Figure 3-1 shows the project site’s regional and local context and Figure 3-2 shows the project site and surrounding land uses, consistent with the requirements of Section 15124(a). In addition, the proposed project’s objectives are listed in Section 3.2, Project Objectives, consistent with the requirements of Section 15124(b). A description of the proposed project is included in Section 3.3, Project Description, consistent with the requirements of Section 15124(c). In addition, the list of agencies and potential permits and approvals that may be required is included in Section 3.4, Approvals/Permits, consistent with the requirements of Section 15124(d). As such, the Project Description is consistent with CEQA requirements.

Response B3-6: This comment states that the Recirculated Draft EIR fails to identify the end uses of the project. Further, this comment suggests that the Recirculated Draft EIR uses an inappropriate trip generation rate. This comment claims that since the City lacks information about the type of end user that will ultimately occupy the project warehouses after construction, the Recirculated Draft EIR should have analyzed truck trips based on the most intensive reasonably foreseeable use of the site, such as an Amazon facility.

Further, the comment also claims that since the Recirculated Draft EIR relies on average trip generation rates for its analysis of the project’s operational air quality, health risk, GHG emissions, energy, noise, and VMT impact, the Recirculated Draft EIR may underestimate the severity of each of these impacts if a more trip-intensive use occurs at the project site.

The commenter claims that the Recirculated Draft EIR should have analyzed truck trips based on the most intensive reasonably foreseeable use of the site, such as an Amazon facility. As discussed in the Recirculated Draft EIR, the 3-231

RESPONSE TO COMMENTS DOCUMENT
S EPTEMBER 2023
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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) proposed project would result in the construction of four office/warehouse buildings that would be configured for heavy industrial uses by tenants that have not been identified. However, the project applicant has confirmed an Amazon facility is not under consideration to be a possible tenant. Since Amazon has not been identified as a tenant, using Amazon trip generation rates would not be accurate or applicable to the proposed project. The suggestion that Amazon trip generation rates would more accurately reflect the project’s impacts is therefore speculative and unsupported by substantial evidence. (See CEQA Guidelines, § 15064, subd. (f)(5).) It should also be noted that Amazon has multiple existing facilities already located in Fresno. It is possible that Amazon could build another facility in Fresno; however, Amazon is not expected to locate another facility at the project site. (See id. at § 15145.)
As discussed in the TIS in Appendix M of the Recirculated Draft EIR, the trip generation for the proposed project was developed using rates from the Western Riverside Council of Governments (WRCOG) Study, included as an appendix to the TIS (Appendix M of the Recirculated Draft EIR). As discussed in the TIS, trip generation rates from the ITE manual for the High‐Cube Fulfillment Center Warehouse land use have a small sample size. The WRCOG Study facilitated a trip generation study for such facilities. Further, trip generation rates using the WRCOG study are higher than trip generation rates from the ITE manual for the High‐Cube Fulfillment Center Warehouse land use. As such, trip generation rates from the WRCOG Study are conservative and are appropriate for use. The WRCOG Study provides separate trip generation rates for passenger vehicles, 2‐to 4-axle trucks, and 5+ axle trucks.

The truck trips were converted to passenger car equivalent (PCE) trips using a PCE factor of 2.0 for 2‐ to 4-axle trucks, consistent with Highway Capacity Manual (HCM) recommendations. However, as a conservative approach, a PCE factor of 3.0 was used for 5+ axle trucks, consistent with the practices in several regions within the State. Additionally, as established in the WRCOG Study, the Amazon facility is an outlier. However, as further noted, that facility was also included to calculate the average trip generation rates for High-Cube Fulfilment Center Warehouse land uses. This methodology is also consistent with the recommended trip generation estimate methodology by ITE, which recommends using average trip generation rates for land uses. The WRCOG Study found that for larger projects, percentages of truck trips compared to total trips are lower than a fulfillment center of a smaller size.

Therefore, the commenter is incorrect in stating that the trip generation assumptions substantially underestimated project trips.

As such, the project’s operational air quality, health risk, GHG emissions, energy, noise, and VMT analyses used the correct traffic assumptions and the commenter has not provided evidence of a potentially significant environmental impact. This comment does not identify any new significant 2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

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3 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) -232 environmental issues or impacts that were not already addressed in the Recirculated Draft EIR. Neither this comment nor the response constitutes new information requiring recirculation of the Recirculated Draft EIR.

Response B3-7: This comment states that the Recirculated Draft EIR did not disclose whether the project would require the use of backup generators. As discussed in the Recirculated Draft EIR, the proposed project would result in the construction of four office/warehouse buildings that would be configured for industrial uses by tenants that have not been identified. The use of such equipment would be dependent on specific tenants and is not being proposed as part of the project.

However, as described in Response A4-6, to be conservative, a supplemental analysis to evaluate potential emissions associated with equipment, emergency backup generators, and diesel fire pumps was conducted using CalEEMod. This supplemental analysis conservatively assumed that 40 dieselpowered forklifts would be used for 8 hours per day and that four dieselpowered 500 HP emergency backup generators and four diesel-powered 500 HP diesel fire pumps would be used for up to 50 hours per year. The results of the supplemental analysis, shown in Table A under Response A4-6, indicate that the use of equipment, emergency backup generators, and diesel fire pumps would not exceed the significance criteria for annual ROG, NOX, CO, SOX, PM10, or PM2.5 emissions. Because emissions would still be below the SJVAPCD’s thresholds, operational emissions would still be considered less than significant. However, it is important to note that the use of equipment, emergency backup generators, and diesel fire pumps would be dependent on specific tenants and is not being proposed as part of the project.

Response B3-8: This comment states that the Recirculated Draft EIR did not disclose whether the project would require the use of diesel fire pumps. The comment also states that an email from the City Fire Department to the City Planning Department states that warehouse developments of this size will typically have high demand fire sprinkler systems for high rack storage and fire sprinkler systems will be supplemented with private fire pumps as needed.

The email from the City Fire Department states the following:

A site plan entitlement has been submitted to the City of Fresno Planning and Development and circulated for comments from effected public agencies. With multiple public street frontages and the availability of 14 and 16 inch public water mains along those frontages, adequate fire access and water service connections for private fire hydrants and fire sprinkler systems are available. Based on the proposed buildings sizes, all buildings are required to install automatic fire sprinkler systems connected to an approved fire alarm monitoring service for rapid initiation 3-233

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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) of a fire department response. Warehouse developments of this size will typically have high demand fire sprinkler systems for high rack storage and fire sprinkler systems will be supplemented with private fire pumps as needed.

As such, this email states that fire sprinkler systems are only supplemented with private fire pumps needed. Diesel fire pumps are not being proposed as part of the project. Identifying such equipment would be speculative and unsupported by evidence. Further, as discussed in the Initial Study (provided in Appendix B of the Recirculated Draft EIR), the proposed project would be required to comply with all applicable codes for fire safety and emergency access. In addition, the project applicant would be required to submit plans to the FFD for review and approval prior to the issuance of building permits to ensure the project would conform to applicable building and fire codes.

However, as discussed in Responses A4-6 and B3-7, to be conservative, a supplemental analysis to evaluate potential emissions associated with equipment, emergency backup generators, and diesel fire pumps, was conducted using CalEEMod. This supplemental analysis conservatively assumed that 40 diesel-powered forklifts would be used for 8 hours per day and that four diesel-powered 500 HP emergency backup generators and four diesel-powered 500 HP diesel fire pumps would be used for up to 50 hours per year. The results of the supplemental analysis, shown in Table A under Response A4-6, indicate that the use of equipment, emergency backup generators, and diesel fire pumps would not exceed the significance criteria for annual ROG, NOX, CO, SOX, PM10, or PM2.5 emissions. Because emissions would still be below the SJVAPCD’s thresholds, operational emissions would still be considered less than significant. However, it is important to note that the use of equipment, emergency backup generators, and diesel fire pumps would be dependent on specific tenants and is not being proposed as part of the project.

Response B3-9: This comment incorrectly claims that the Recirculated Draft EIR fails to accurately disclose the baseline environmental conditions related to the project’s health risk impacts and that it lacks necessary baseline information against which to measure the project’s environmental impacts with regard to impacts on sensitive receptors from construction.

The commenter is incorrect that the Recirculated Draft EIR fails to disclose the baseline environmental conditions related to the project’s health risk impacts. Section 4.2.1, Environmental Setting of the Recirculated Draft EIR provides an overview of existing air quality conditions in the region and in the City of Fresno. Ambient air quality standards and the regulatory framework are summarized and climate, air quality conditions, and typical air pollutant types and sources are also described. Further, as identified on page 4.2-31 of the Recirculated Draft EIR, the closest sensitive receptors include the single- 2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

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3 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) -234 family residences located approximately 110 feet south of the project site across West Nielsen Avenue.

As identified on pages 4.2-10 and 4.2-11 of the Recirculated Draft EIR, the OEHHA, on behalf of the CalEPA, released Version 4.0 of CalEnviroScreen in October 2021. CalEnviroScreen identifies California communities by census tract that are disproportionately burdened by, and vulnerable to, multiple sources of pollution. Pollution Burden scores for each census tract are derived from the average percentiles of the seven Exposures indicators (ozone and PM2.5 concentrations, DPM emissions, drinking water contaminants, pesticide use, toxic releases from facilities, and traffic density) and the five Environmental Effects indicators (cleanup sites, impaired water bodies, groundwater threats, hazardous waste facilities and generators, and solid waste sites and facilities). According to the CalEnviroScreen 4.0 Map,1 the project site has a pollution burden percentile of 97. Surrounding areas have pollution burdens ranging from 56 to 100.0. In addition, according to the SB 535 Disadvantaged Communities Map,2 the project area is designated as an SB 535 disadvantaged community.

Although the project site has a pollution burden percentile of 97, there is no methodology to quantify the cumulative areawide or localized health risks within a community-wide area. The SJVAPCD’s recommended thresholds of significance apply to individual development projects and evaluate the incremental increase in emissions from a proposed source. These thresholds do not apply to cumulative projects. The City relies on the SJVAPCD’s recommended methodology to evaluate cumulative impacts, which is to conclude that an impact considered to be significant on a project-specific basis would also cause a significant cumulative impact. As shown in Table

4.2.K of the Recirculated Draft EIR, a project-specific HRA shows that the project would not result in a significant health risk to surrounding receptors at the project or cumulative level.

In addition, as described on page 4.2-26 of the Recirculated Draft EIR, the SJVAB is designated as non-attainment for ozone and PM2.5 for federal standards and non-attainment for ozone, PM10, and PM2.5 for State standards.

The SJVAPCD’s non-attainment status is attributed to the region’s development history. Past, present, and future development projects contribute to the region’s adverse air quality impacts on a cumulative basis.

By its very nature, air pollution is largely a cumulative impact. No single project is sufficient in size to, by itself, result in non-attainment of ambient 1 Office of Environmental Health Hazard Assessment (OEHHA). 2021. CalEnviroScreen 4.0. Website:
https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40 (accessed May 2021). 2 OEHHA. 2022. SB 535 Disadvantaged Communities using CalEnviroScreen 4.0 results. Website:
https://experience.arcgis.com/experience/1c21c53da8de48f1b946f3402fbae55c/page/SB-535- Disadvantaged-Communities/.pdf (accessed October 2022). 3-235

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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) air quality standards. Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts. If a project’s contribution to the cumulative impact is considerable, then the project’s impact on air quality would be considered significant. In developing thresholds of significance for air pollutants, the SJVAPCD considered the emission levels for which a project’s individual emissions would be cumulatively considerable. If a project exceeds the identified SCAQMD significance thresholds, its emissions would be cumulatively considerable, resulting in significant adverse air quality impacts to the region’s existing air quality conditions. Therefore, since a project’s individual emissions are not cumulatively considerable, additional analysis to assess cumulative impacts is not necessary.

As shown in Tables 4.2-G and 4.2-H of the Recirculated Draft EIR, the proposed project would generate construction and operational emissions that are below the SJVAPCD’s thresholds. As such, the proposed project would not result in a cumulative air quality impact.

Response B3-10: This comment states that the Recirculated Draft EIR fails to adequately establish the existing baseline with respect to Valley Fever. In addition, this comment asserts that the Recirculated Draft EIR must include a proper discussion of the potential for the presence of coccidioidomycosis fungus spores at the project site in order to accurately analyze and mitigate the project’s potentially significant health risk impacts from Valley Fever.

Background information regarding Valley Fever is discussed on pages 4.2-5 and 4.2-6 of the Recirculated Draft EIR. However, the air quality analysis contained in Section 4.2, Air Quality, of the Recirculated Draft EIR was prepared using the methodologies and assumptions contained in the SJVAPCD’s GAMAQI. The GAMAQI does not include requirements or thresholds of significance for addressing Valley Fever. The closest sensitive receptors include the single-family residences located approximately 110 feet south of the project site across West Nielsen Avenue. Except under high wind conditions, this distance is sufficient that particulate matter will settle prior to reaching the nearest sensitive receptor. In addition, crosswinds influenced by adjacent traffic intersections would help dissipate any particulate matter associated with the construction phase of the project.

Therefore, any Valley Fever spores suspended with the dust will not reach the sensitive receptors. However, during project construction, it is possible that workers could be exposed to Valley Fever through fugitive dust. Dust control measures, consistent with SJVAPCD Regulation VIII (as required by Mitigation Measure AIR-1), would reduce the exposure of the workers. Dust from the construction of the project is not anticipated to exacerbate or significantly add to the existing exposure of people to Valley Fever. 2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

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3 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) -236 Response B3-11: This comment is a statement of the commenter’s understanding of CEQA’s “substantial evidence” standard and discusses the standard of review that applies when a court is determining whether a lead agency failed to proceed in a manner required by law. The comment is noted, but it does not raise any significant environmental issues related to the project or the analysis contained in the Recirculated Draft EIR.

Response B3-12: This comment claims that the transportation impacts analysis is flawed with respect to the analysis of the project’s trip generation and VMT impacts.

As discussed in Response B3-6, the proposed project would result in the construction of four office/warehouse buildings that would be configured for heavy industrial uses by tenants that have not been identified. However, the project applicant has confirmed that an Amazon facility is not under consideration to be a possible tenant. Since Amazon has not been identified as a tenant, using Amazon trip generation rates would not be accurate or applicable to the proposed project. The suggestion that Amazon trip generation rates would more accurately reflect the project’s impacts is therefore speculative and unsupported by substantial evidence. (See CEQA Guidelines, § 15064, subd. (f)(5).) It should also be noted that Amazon has multiple facilities already located in Fresno. It is possible that Amazon could build another facility in Fresno; however, Amazon is not expected to locate another facility at the project site. (See id. at § 15145.) In addition, as demonstrated in Response B3-14, the Fresno COG ABM was used for the proposed project’s VMT analysis. As discussed on page 4.10-14 of the Draft EIR, the project is non-residential in nature but would not be classified as an office or retail project. Additionally, the project does not require a General Plan Amendment. Therefore, the project’s VMT per employee was compared to the existing regional average VMT per employee.

The existing regional average is 25.6 VMT per employee, as established in the City of Fresno CEQA Guidelines for Vehicle Miles Traveled Thresholds. Based on the Fresno COG ABM output, the project’s VMT was calculated to be 19.8 VMT per employee. As such, the project’s VMT per employee rate is 22.66 percent lower than the existing regional average VMT per employee or the City’s threshold. In conclusion, the project would result in a less than significant VMT impact concerning consistency with CEQA Guidelines Section 15064.3(b). Therefore, the commenter is incorrect in stating that the trip generation and VMT assumptions were flawed.

Response B3-13: This comment claims that the Recirculated Draft EIR incorrectly calculates the project’s operational trip generation because the City does not have information on the future tenants of the project site or what the eventual use of the project buildings will be. The comment states the City’s reliance on the selected trip rates is therefore unreasonable and unsupported. 3-237

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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) Please refer to Response B3-6. The commenter claims that the Recirculated Draft EIR should have analyzed truck trips based on the most intensive reasonably foreseeable use of the site, such as an Amazon facility. As discussed in the Recirculated Draft EIR, the proposed project would result in the construction of four office/warehouse buildings that would be configured for heavy industrial uses by tenants that have not been identified. However, the project applicant has confirmed that Amazon is not under consideration as a possible tenant. Since Amazon has not been identified as a tenant, using Amazon trip generation rates would not be accurate or applicable to the proposed project. As discussed in Response B3-6, Amazon has multiple existing facilities already located in Fresno and is not expected to locate another facility at the project site. The project applicant has confirmed that no tenants have been identified, and the suggestion that Amazon trip generation rates would more accurately reflect the project’s impacts is therefore speculative and unsupported by substantial evidence. (See CEQA Guidelines, § 15064, subd. (f)(5).) Additionally, as established in the WRCOG Study, the Amazon facility is an outlier. Also, the WRCOG Study recommends using the average rates on page 4 of the WRCOG Study. However, as further noted, that facility was also included to calculate the average trip generation rates for High-Cube Fulfilment Center Warehouse land uses. This methodology is also consistent with the recommended trip generation estimate methodology by ITE, which recommends using average trip generation rates for land uses.
1 It should also be noted that the WRCOG Study
found that for larger projects, percentages of truck trips compared to total trips are lower than a fulfillment center of a smaller size. Therefore, the commenter is incorrect in stating that the trip generation assumptions were not adequate. The commenter has not shown substantial evidence of a potentially significant environmental impact.

Response B3-14: This comment asserts that the Recirculated Draft EIR underestimates project VMT. This comment states that the Recirculated Draft EIR estimates that 10.2 percent of daily trips are made by heavy trucks (5+ axles) and another 7.6 percent are made by medium trucks (2 to 4 axles), and that the average trip lengths are calculated to be 9.5 miles for work trips and 7.3 miles for other trips. This comment claims that these estimates are likely much lower than the actual average truck trip lengths that could be generated by the project.

As discussed on pages 4.10-12 through 4.10-14 of the Recirculated Draft EIR, the Fresno COG ABM was used to estimate the project VMT and VMT metric.

ABM is a tour-based model that captures the travel behavior of the region comprehensively. As such the project employee VMT included VMT from all employee tours and sub-tours. This comprises employee commute tours, project-related delivery tours within the region, and any other tours related 1 Institute of Transportation Engineers. 2017. Trip Generation Handbook, 3rd Edition (page 26). September. 2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

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3 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) -238 to the project. Also, project VMT and the VMT metric used for this analysis are consistent with both the City’s and the Fresno COG’s adopted methodology/guidelines for preparation of VMT analysis. The guidelines provide substantial evidence demonstrating the appropriateness of the VMT analysis methodology consistent with the intended goals for SB 743.

The commenter is incorrect in stating that the VMT analysis did not include or fully evaluate trips that originate/are destined outside Fresno County. As shown in Appendix G of the traffic study, the project VMT included employee trips that originated/were destined outside of Fresno County (internalexternal/external-internal trips). Therefore, the project VMT estimates accounted for trips originating from outside the Fresno COG ABM region as well.

In addition, truck trips were not included in the VMT analysis, consistent with the CEQA Guidelines Section 15064.3, subdivision (a), which states “For the purposes of this section, ‘vehicle miles traveled’ refers to the amount and distance of automobile travel attributable to a project.” The technical guidance from OPR does say that heavy-duty truck VMT “could be included”; however, the Guidance goes on to state that this would be for modeling convenience and ease of calculation. Heavy-duty trucks are not included in the CEQA guidelines for VMT analysis, are not included in the Fresno COG model, and therefore were not included in the VMT analysis. “An agency’s use of a reasonable standard for gauging the significance of an impact may not be set aside on the ground the impact would have been found significant if other recognized standards had instead been used.” (Kostka, § 6.45, p. 6- 50/50; see Jensen, supra, 23 Cal.App.5th at 887; Citizens for Responsible Equitable Environmental Development, supra, 197 Cal.App.4th at 336–336.) This comment does not identify any new significant environmental issues or impacts that were not already addressed in the Recirculated Draft EIR.

Neither this comment nor the response constitutes new information requiring recirculation of the Recirculated Draft EIR.

Response B3-15: This comment claims that the Recirculated Draft EIR fails to include any mitigation measures to reduce the project’s VMT impacts and fails to include analysis of the feasibility of the above methods, or any other methods, to reduce the project’s potentially significant impacts.

Refer to Responses B2-13 and B3-14. As discussed on pages 4.10-13 and 4.10- 14 of the Recirculated Draft EIR, a detailed VMT analysis discussion is included in Chapter 13 of the TIS (see Appendix M), consistent with the requirements of SB 743. As recommended in the City of Fresno CEQA Guidelines for Vehicle Miles Traveled Thresholds, for projects that could not be screened out from a quantitative VMT assessment, the VMT analysis should be conducted using the Fresno COG ABM, which is a tour-based model. Therefore, the Fresno 3-239

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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) COG ABM was used for the project VMT analysis. The model database was updated with the project land uses to calculate project VMT.

The project is non-residential in nature but would not be classified as an office or retail project because of the warehouse and heavy industrial uses contemplated for the buildings. Additionally, the project does not require a General Plan Amendment. Therefore, the project’s VMT per employee was compared to the existing regional average VMT per employee. The existing regional average is 25.6 VMT per employee, as established in the City of Fresno CEQA Guidelines for Vehicle Miles Traveled Thresholds. Based on the Fresno COG ABM output, the project’s VMT was calculated to be 19.8 VMT per employee. As such, the project’s VMT per employee rate is 22.66 percent lower than the existing regional average VMT per employee, or the City’s threshold. In conclusion, the project would result in a less than significant VMT impact concerning consistency with CEQA Guidelines Section 15064.3(b). The commenter did not demonstrate that the project would result in a potentially significant environmental impact based on substantial evidence. Therefore, the Recirculated Draft EIR properly determined that the proposed project would result in a less than significant impact related to VMT. As such, identification and analysis of mitigation measures is not required.

Response B3-16: The comment asserts that the Recirculated Draft EIR states that the project may be subject to SJVAPCD Rule 9410 – Employer Based Trip Reduction, but that it does not include this rule as mitigation for the project. In addition, this comment claims that the Recirculated Draft EIR fails to include any mitigation measures to reduce the project’s VMT impacts, including individual measures included in SJVAPCD Rule 9410.

As discussed in Response A4-18, the proposed project would comply with all required SJVAPCD rules and regulations. In addition, as identified in Appendix H, Greenhouse Gas Reduction Plan Update Checklist, of the Recirculated Draft EIR, the project would have over 100 employees and would be required to comply with SJVAPCD Rule 9410. Further, as discussed in Response B3-15, the project would result in a less than significant VMT impact concerning consistency with CEQA Guidelines Section 15064.3(b). As such, identification and analysis of mitigation measures is not required.

Response B3-17: This comment claims that the Recirculated Draft EIR failed to accurately analyze the project’s operational health risk and that the air dispersion model used in the analysis has a structural flaw that results in inaccurate estimates of the project emissions within the community. In addition, this comment claims that building downwash effect was not included, resulting in an underestimation of exposure concentrations.
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3 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) -240 As discussed on page 4.2-34 of the Recirculated Draft EIR, an HRA was prepared in accordance with policies and procedures of the State OEHHA and the SJVAPCD. It evaluates the project against the significance criteria established by the SJVAPCD and was prepared in compliance with all applicable requirements, including, but not limited to, the City of Fresno General Plan Program EIR Mitigation Measure AIR-3.1. In order to assess the dispersion of emissions associated with the project, air dispersion modeling was performed using AERMOD. The model is approved by the USEPA when estimating the air quality impacts associated with point and fugitive sources in simple and complex terrain. The model was used to calculate the annual average pollutant concentrations associated with each emitting source.

CARB’s HARP2 model was used to translate the TAC concentrations from AERMOD into long-term carcinogenic and chronic, and short-term acute health risk levels following the guidance in the SJVAPCD risk assessment guidelines. To estimate chronic noncancer risks at residential receptors, the “OEHHA-Derived Method” risk-calculation option was used. Following the OEHHA guidance, an 8-hour chronic noncancer risk was calculated for residential receptors because the project would operate more than 8 hours per day and 5 days per week.

Discrete variants for daily breathing rates, exposure frequency, and exposure duration were obtained from relevant distribution profiles presented in the OEHHA guidance document entitled Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments and guidance from SJVAPCD. As such, the modeling conducted for the HRA is adequate.

The SJVAPCD Guidance suggests that building downwash effects be included.

The commenter incorrectly states that the EIR fails to account for building downwash. In fact, the modeling conducted for the project included building downwash, as recommended by the SJVAPCD. The following image shows a snapshot of the model and 3-D representation of the building heights that were used to model the downwash effect. The model was made available to the public for review and download at the City. As such, the HRA represents an accurate representation of the project and the disclosed emissions are accurate.
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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) Response B3-18: This comment states that the Recirculated Draft EIR fails to analyze and mitigate Valley Fever impacts from project construction. Refer to Response B3-10. Background information regarding Valley Fever is discussed on pages

4.2-5 and 4.2-6 of the Recirculated Draft EIR. The air quality analysis contained in Section 4.2, Air Quality, of the Recirculated Draft EIR was prepared using the methodologies and assumptions contained in the SJVAPCD’s GAMAQI. Neither the GAMAQI nor the State CEQA Guidelines include requirements or thresholds of significance for addressing Valley Fever. The closest sensitive receptors include the single-family residences located approximately 110 feet south of the project site across West Nielsen Avenue. Except under high wind conditions, this distance is sufficient that particulate matter will settle prior to reaching the nearest sensitive receptor.

In addition, crosswinds influenced by adjacent traffic intersections would help dissipate any particulate matter associated with the construction phase of the project. Therefore, any Valley Fever spores suspended with the dust will not reach the sensitive receptors. Dust control measures, consistent with SJVAPCD Regulation VIII (as required by Mitigation Measure AIR-1), would reduce the exposure of the workers. Dust from the construction of the project is not anticipated to exacerbate or significantly add to the existing exposure of people to Valley Fever.

Response B3-19: This comment states that the Recirculated Draft EIR fails to incorporate mitigation measures that would address Valley Fever risks to construction employees and sensitive receptors. Refer to Response B3-18. As noted above, there are no CEQA standards for coccidioidomycosis exposure. Any exposure to workers would be subject to the Occupational Safety and Health (OSH) Act of 1970, 29 United States Code (USC) 654(a)(1), and other appliable 2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

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3 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) -242 Occupational Safety and Health Administration requirements, including Respiratory Protection (29 CFR 1910.134), which covers respirator use in the workplace. However, the proposed project would not exacerbate or significantly add to the existing exposure of people to Valley Fever and therefore mitigation to reduce CEQA impacts is not required.

Response B3-20: This comment states that the Recirculated Draft EIR did not analyze air quality impacts associated with the use of backup generator and fire pumps. This comment also claims that the project’s trip generation rates and VMT are unsupported, resulting in significant air quality and GHG impacts.

The proposed project did not identify the use of backup generators or fire pumps. As discussed in the Recirculated Draft EIR, the proposed project would result in the construction of four office/warehouse buildings that would be configured for heavy industrial uses by tenants that have not been identified. The use of such equipment would be dependent on specific tenants and is not being proposed as part of the project.

However, as discussed in Responses A4-6 and B3-7, to be conservative, a supplemental analysis to evaluate potential emissions associated with equipment, emergency backup generators, and diesel fire pumps was conducted using CalEEMod. This supplemental analysis conservatively assumed that 40 diesel-powered forklifts would be used for 8 hours per day and that four diesel-powered 500 HP emergency backup generators and four diesel-powered 500 HP diesel fire pumps would be used for up to 50 hours per year. The results of the supplemental analysis, shown in Table A under Response A4-6, indicate that the use of equipment, emergency backup generators, and diesel fire pumps would not exceed the significance criteria for annual ROG, NOX, CO, SOX, PM10, or PM2.5 emissions. Because emissions would still be below the SJVAPCD’s thresholds, operational emissions would still be considered less than significant. However, it is important to note that diesel fire pumps are not being proposed as part of the project.

For a discussion of the project’s trip generation rates and VMT, please refer to Responses B3-6, B3-12, B3-13, B3-14, and B3-15. As explained in these responses, the Recirculated Draft EIR properly evaluated the project’s trip generation rates and VMT. As such, the project’s air quality and GHG analyses used the correct trip generation and VMT assumptions and the commenter has not shown substantial evidence of a potentially significant environmental impact.

Response B3-21: This comment states that the Recirculated Draft EIR fails to account for the operation of backup generators. As discussed in the Recirculated Draft EIR, the proposed project would result in the construction of four office/warehouse buildings that would be configured for heavy industrial uses by tenants that have not been identified. However, as discussed in 3-243

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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) Responses A4-6 and B3-7, to be conservative, a supplemental analysis to evaluate potential emissions associated with equipment, emergency backup generators, and diesel fire pumps was conducted using CalEEMod. This supplemental analysis conservatively assumed that 40 diesel-powered forklifts would be used for 8 hours per day and that four diesel-powered 500 HP emergency backup generators and four diesel-powered 500 HP diesel fire pumps would be used for up to 50 hours per year. The results of the supplemental analysis indicate that the use of equipment, emergency backup generators, and diesel fire pumps would not exceed the significance criteria for annual ROG, NOXx, CO, SOX, PM10, or PM2.5 emissions. Because emissions would still be below the SJVAPCD’s thresholds, operational emissions would still be considered less than significant. However, it is important to note that generators are not proposed as part of the project.

Response B3-22: This comment asserts that the transportation impact analysis fails to accurately analyze the project’s operational truck trip generation rates and likely underestimates the project’s VMT. This comment also asserts that the project’s air quality analysis relies on the transportation impact analysis’ trip generation numbers and VMT in order to calculate the project’s air emissions and analyze the project’s air quality and GHG emissions impacts. This comment claims that the project’s transportation impact analysis must be corrected to accurately analyze the project’s air quality impacts.

As described in Responses B3-6, B3-12, B3-13, B3-14, and B3-15, the traffic assumptions are supported by substantial evidence further explained in the TIS that was prepared for the project, included in Appendix M of the Recirculated Draft EIR. The Technical Memorandum prepared by WSP and dated January 29, 2019, which was included as an appendix to the TIS, explains in great detail the basis for the trip generation rates used in the traffic analysis and air quality analysis. Further, the air quality analysis did not incorporate the VMT from the TIS as the VMT analysis for SB 743 uses a different methodology than air quality. The air quality analysis utilized default trip lengths provided in CalEEMod. Refer to Response A4-3 for a detailed discussion of CalEEMod default assumptions. As demonstrated in Response A4-3, since a project-specific truck trip length is not yet known, the use of CalEEMod defaults is appropriate for projects in the SJVAPCD and the city of Fresno and is consistent with standard practice. As such, the project’s air quality analyses used the correct trip generation and VMT assumptions.

Response B3-23: This comment claims that the Recirculated Draft EIR relies on a faulty methodology to analyze the project’s construction noise and improperly relies on a relative threshold of significance with regard to the project’s operational noise from traffic. It also claims that the Recirculated Draft EIR fails to properly analyze and mitigate the project’s significant construction and operational noise impacts. This comment also states that CEQA requires 2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

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3 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) -244 agencies to conduct noise analyses for projects that consider both the absolute noise levels expected and the degree noise levels are expected to increase. It claims that noise studies that rely on a single measure that excludes possible significant impacts from noise increases or noise extremes do not receive deference by reviewing courts.

This comment provides an introduction to following comments, which are responded to further in Response B3-24 and Response B3-25.

Response B3-24: This comment states that the Recirculated Draft EIR only relies on a relative threshold to determine that the project will not result in a significant impact.

Further, this comment states that the City’s General Plan Policy NS-1-a establishes “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” such as those along Nielsen Avenue, south of the project site. This comment also claims that based on the data provided in the Recirculated Draft EIR, the roadway segment on Nielsen Avenue between Marks Avenue and Hughes Avenue will see an increase from the existing 64.0 A-weighted decibels (dBA) Community Noise Equivalent Level (CNEL) to 66.1 dBA CNEL with the addition of project-generated traffic. Based on the Recirculated Draft EIR’s own data, the project will cause noise levels at nearby sensitive receptors to exceed the desirable maximum average exterior noise levels for defined usable exterior areas of residential and noise-sensitive uses of 65 dBA CNEL, resulting in a significant impact.

As identified on page 4.9-13 of the Recirculated Draft EIR, as established in General Plan Policy NS-1-j: Significance Threshold, the City considers a 3 dBA increase to be a significant increase in ambient noise. As described on pages

4.9-18 through 4.9-21 of the Recirculated Draft EIR, project-related traffic noise would be no greater than 2.1 dBA. Noise level increases less than

3.0 dBA are not considered perceptible to most people in an outdoor environment. In addition, as shown in Table 4.9.D of the Recirculated Draft EIR, existing daily noise levels along West Nielsen Avenue near the existing sensitive receptors range from 67.6 dBA CNEL to 68.1 dBA CNEL. Because noise levels would increase less than 3.0 dBA, this is consistent with General Plan Policy NS-1-j: Significance Threshold, which states that an increase of 3 dBA CNEL or more is considered significant. There is currently no General Policy stating that a less than 3 dBA increase resulting in levels going from below 65 dBA CNEL to above 65 dBA CNEL would constitute a significant impact. Further, the 65 dBA CNEL standard applies to new development as a land use compatibility standard and is not an applicable threshold of significance for noise level increases. Therefore, the commenter is incorrect that 65 dBA CNEL is an applicable threshold. As such, traffic noise impacts from project-related traffic on off-site sensitive receptors would be less than significant.
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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) Response B3-25: The commenter claims that they calculated the noise levels generated during each phase of construction combined with the existing ambient noise levels to determine the noise impacts on the closest residential receptors located south of the project site and found that the site preparation phase will result in a noise level of 70.2 dBA Leq, while grading will result in a noise level of 71 dBA Leq and building construction will result in a noise level of 69.0 dBA Leq.

Further, this comment claims that Mitigation Measure NOI-1 would not reduce the project’s significant construction noise impacts.

As identified in Table 4.9.K of the Recirculated Draft EIR, construction noise levels were based on the Federal Highway Administration Roadway Construction Noise Model. In addition to the reference maximum noise level, the usage factor provided in Table 4.9.K is used to calculate the hourly noise level impact for each piece of equipment. Each piece of construction equipment operates as an individual point source. Therefore, a composite noise level can be calculated when multiple sources of noise operate simultaneously.

Using the equations from the methodology identified on page 4.9-17 of the Recirculated Draft EIR, the reference information in Table 4.9.K, and the construction equipment list provided, the composite noise level of the two loudest pieces of equipment for each construction phase was calculated. The project construction composite noise levels at a distance of 50 feet for would range from 74 dBA equivalent continuous noise level (Leq) to 84 dBA Leq, with the highest noise levels occurring during the grading phase.

Once composite noise levels are calculated, reference noise levels can then be adjusted for distance. In general, doubling the distance would decrease noise levels by 6 dBA, while halving the distance would increase noise levels by 6 dBA.

The Recirculated Draft EIR evaluated construction noise levels based on the composite noise level of the two loudest pieces of equipment for each construction phase, consistent with the Federal Transit Administration (FTA) Noise and Vibration Impact Assessment Manual (FTA Manual). The FTA Manual states that while it is not the purpose of the manual to specify standardized criteria for construction noise impacts, the guidelines can be considered reasonable criteria for assessment. The FTA Manual provides two options for noise assessment: Option A, General Assessment, to evaluate the two noisiest pieces of equipment for each phase of construction; and Option B, Detailed Analysis, to evaluate all equipment for each phase of construction.

The air quality analysis utilized a default construction fleet from CalEEMod, which was used in the noise analysis. However, since the proposed project’s specific construction equipment list is unknown at this time, for purposes of the noise assessment, it is likely that two pieces of equipment would be used at a specific distance from the receptor at any one time. 2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

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3 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) -246 As discussed on pages 4.9-17 and 4.9-18 of the Recirculated Draft EIR, while construction noise will vary, it is expected that composite noise levels during construction at the nearest off-site sensitive residential use to the south would reach an average noise level of 64 dBA Leq during daytime hours. While construction-related, short-term noise levels have the potential to be higher than quieter daytime ambient noise levels in the project area under existing conditions, the construction noise impacts would be approximately 1.7 dBA greater than the existing average daytime noise level of 64.7 dBA Leq during the allowable hour of construction. When logarithmically combined with the existing average ambient noise level, the total noise level would be 66.2 dBA Leq, resulting in an increase of 3.9 dBA Leq. As identified in Table 4.9.I of the Recirculated Draft EIR, for stationary sources, mitigation shall only be required to limit noise to the ambient plus 5 dBA. Because the increase would be less than 5 dBA, construction noise would be considered less than significant.

However, when utilizing the detailed construction methodology and information from the CalEEMod results, assuming each piece of equipment operating simultaneously over the site for each phase, as suggested by the commenter, the composite noise levels during construction at the nearest off-site sensitive residential use to the south would reach an average noise level of 68.9 dBA Leq at the acoustical average distance of 471 feet during daytime hours. Additionally, based on CalEEMod results, it is assumed that equipment would operate for no more than 8 hours per day. In order to provide a more accurate assessment consistent with CalEEMod results and the FTA methodology, the average ambient noise level at the nearest residential uses between the hours of 7:00 a.m. and 4:00 p.m., a period including an 8-hour work day and a 1 hour lunch, is 66.0 dBA Leq. This noise level would be approximately 2.9 dBA greater than the existing average daytime noise level of 66.0 dBA Leq during the allowable hours of construction. When logarithmically combined with the existing average ambient noise level, the total noise level would be 70.7 dBA Leq, resulting in an increase of 4.7 dBA Leq. Because the increase would still be less than 5 dBA, construction noise would still be considered less than significant.

The discrepancy between the 68.9 dBA Leq calculated in the noise analysis and the commenter’s calculation of 71 dBA Leq is a result of the noise analysis using the actual measured noise levels as compared to spec data within the Roadway Construction Noise Model (RCNM). It is our professional opinion that the use of actual measured data is more accurate than spec data.

In addition, as discussed in the Recirculated Draft EIR, although the project’s potential construction-related noise level increase would be less than 5 dBA, project construction noise has the potential to result in annoyance to surrounding receptors. Therefore, the applicant would be required to 3-247

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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) implement Mitigation Measure NOI-1, which would ensure that all equipment, fixed or mobile, would be required to be equipped with properly operating and maintained mufflers, consistent with manufacturers’ standards. Additionally, Mitigation Measure NOI-1 requires the project to designate a “disturbance coordinator” at the City who would be responsible for responding to any local complaints about construction noise. The disturbance coordinator would determine the cause of the noise complaint (e.g., starting too early, bad muffler) and would determine and implement reasonable measures warranted to correct the problem. This measure would reduce annoyance associated with construction noise as a significant construction noise impact was not identified. Additional construction noise mitigation measures are not required.

Response B3-26: This comment states that CEQA requires that EIRs include a discussion of the potential energy impacts of proposed projects and a detailed statement of mitigation measures designed to minimize significant effects on the environment (including, but not limited to, measures to reduce the wasteful, inefficient, and unnecessary consumption of energy). This comment also claims that the Recirculated Draft EIR falls short of the mandates of Appendix F.

As discussed in Section 4.5.3.1 of the Recirculated Draft EIR, thresholds for impacts related to energy used in the analysis are consistent with Appendix G of the State CEQA Guidelines, which state that development of the proposed project would result in a significant impact related to energy if it would: result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation; or conflict with or obstruct a State or local plan for renewable energy or energy efficiency.

Further, Appendix F of the State CEQA Guidelines states that EIRs must include a discussion of the potential energy impacts of proposed projects, with particular emphasis on avoiding or reducing inefficient, wasteful, and unnecessary consumption of energy. As demonstrated in Section 4.6, Energy, the proposed project would not result in inefficient, wasteful, and unnecessary consumption of energy, and the project would not result in a significant energy impact.

Response B3-27: This comment asserts that the Recirculated Draft EIR fails to adequately analyze the significance of the project’s energy impacts related to the project’s use of fossil fuels consumed by project-related vehicle trips. Further, this comment states that the Recirculated Draft EIR states that the project would increase gasoline consumption in the city of Fresno by 0.11 percent and diesel consumption by 0.5 percent, but that the Recirculated Draft EIR fails to establish a threshold for fossil fuel consumption that would be significant. Therefore, the comment claims that the conclusion that the 2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

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3 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) -248 increased fuel consumption resulting from project operation would not be significant is unsupported.

As discussed on page 4.5-8, the proposed project would result in energy usage associated with gasoline and diesel fuel consumed by project-related vehicle trips. Trip generation rates for the proposed project were based on the project’s trip generation estimates, as identified in Section 4.10, Transportation, of the Recirculated Draft EIR, which estimates that the proposed project would generate approximately 1,920 average daily trips, including 1,578 vehicle trips and 342 truck trips. Based on the operational energy consumption estimates shown in Table 4.5.B, operation of the proposed project would increase the annual natural gas consumption in Fresno County by approximately 0.05 percent. Further, vehicle and truck trips associated with the proposed project would increase the annual fuel use in Fresno County by approximately 0.11 percent for gasoline fuel usage and approximately 0.05 percent for diesel fuel usage.

The comment claims that the City must determine the appropriate threshold against which to measure the project’s fossil fuel consumption in order to determine whether the project will result in a significant impact to energy resources. However, as identified in Response B3-26 and as discussed in Section 4.5.3.1 of the Recirculated Draft EIR, thresholds for impacts related to energy used in the analysis are consistent with Appendix G of the State CEQA Guidelines, which states that development of the proposed project would result in a significant impact related to energy if it would: result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation; or conflict with or obstruct a State or local plan for renewable energy or energy efficiency. Further, there is no quantitative energy threshold under CEQA, and given that the gasoline and diesel fuel demand generated by vehicle trips associated with the proposed project would be a minimal fraction of gasoline and diesel fuel consumption in Fresno County, project gasoline and fuel demand would not be considered wasteful, inefficient, or unnecessary consumption.

Therefore, as demonstrated in Section 4.6, Energy, the proposed project would not result in inefficient, wasteful, and unnecessary consumption of energy and the project would not result in a significant energy impact. The commenter has not shown evidence of a potentially significant environmental impact.

Response B3-28: This comment claims that the Recirculated Draft EIR fails to accurately account for the project’s trip generation, which would lead to increased fossil fuel and energy use.
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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) Refer to Response B3-6 for a discussion of the project’s trip generation. The trip generation for the proposed project was developed using rates from the WRCOG Study based on a trip generation study for high-cube fulfilment center facilities. As demonstrated in Response B3-6, the commenter is incorrect in stating that the trip generation assumptions substantially underestimated project trips.

Response B3-29: This comment states that another goal for conserving energy is increasing reliance on renewable energy sources and that the Recirculated Draft EIR’s discussion of renewable energy generation is virtually nonexistent and fails to provide a meaningful investigation into renewable energy options that might be available or appropriate for the project. This comment also claims that compliance with the Building Code and other energy efficiency requirements does not, by itself, constitute an adequate assessment of measures that can be taken to address the energy impacts during construction and operation of the project.

As discussed on page 4.5-8 of the Recirculated Draft EIR, the proposed buildings would likely be constructed using the 2022 Title 24 standards; however, based on available modeling tools, the CalEEMod analysis of energy use assumed the construction of buildings based on the 2019 Title 24 standards, which is a conservative analysis. As discussed on page 4.5-8, Title 24 Standards contain energy efficiency requirements and establish performance metrics in the form of an “energy budget” based on energy consumption per square foot of floor space. For this reason, the Title 24 Standards include both a prescriptive option, allowing builders to comply by using methods known to be efficient, and a performance option, allowing builders complete freedom in their designs provided the building achieves the same overall efficiency as an equivalent building using the prescriptive option. Reference appendices are adopted along with the Title 24 Standards containing data and various compliance tools to help builders achieve compliance. As discussed in Response, B1-7, after approval and preparation of detailed building plans, the project would be required to demonstrate compliance with Title 24 using the CBECC model.

In addition, as discussed on pages 4.5-9 and 4.5-10 of the Recirculated Draft EIR, proposed new development would be constructed using energy-efficient modern building materials and construction practices, and the proposed project also would use new modern appliances and equipment, in accordance with the Appliance Efficiency Regulations (Title 20, CCR Sections 1601 through 1608). The expected energy consumption during construction and operation of the proposed project would be consistent with typical usage rates for industrial uses; however, energy consumption is largely a function of personal choice and the physical structure and layout of buildings. 2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

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3 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) -250 PG&E is the private utility that would supply the proposed project’s electricity and natural gas services. In 2021, a total of 50 percent of PG&E’s delivered electricity came from renewable sources, including solar, wind, geothermal, small hydroelectric, and various forms of bioenergy.1 PG&E reached California’s 2020 renewable energy goal in 2017 and is positioned to meet the State’s 60 percent by 2030 renewable energy mandate set forth in SB 100.

In addition, PG&E plans to continue to provide reliable service to its customers and upgrade its distribution systems as necessary to meet future demand.

Further, as discussed in Response B3-26, Appendix F of the State CEQA Guidelines states that EIRs must include a discussion of the potential energy impacts of proposed projects, with particular emphasis on avoiding or reducing inefficient, wasteful, and unnecessary consumption of energy. As demonstrated in Section 4.6, Energy, the proposed project would not result in inefficient, wasteful, and unnecessary consumption of energy and would not result in a significant energy impact.

Response B3-30: This comment states that the Recirculated Draft EIR fails to disclose inconsistency with the City’s General Plan, which would result in a significant adverse environmental impact on land use and planning. As discussed in Section 3.1.3, Existing Zoning and General Plan Land Use Designation, in the Recirculated Draft EIR, the project site is designated Heavy Industrial in the City of Fresno General Plan. 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. Small-scale commercial services and ancillary office uses are also permitted. The maximum FAR is 1.5. In addition, as discussed in the Initial Study (provided in Appendix B of the Recirculated Draft EIR), 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. Therefore, the project is consistent with the City’s General Plan and would not result in a significant adverse environmental impact on land use planning.

Response B3-31: This comment asserts that the proposed project would exceed the City’s Noise Element Policy NS-1-a Desirable and Generally Acceptable Exterior Noise Environment, which establishes 65 dBA day-night average level (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 the property line) for noise generated by stationary sources impinging upon residential and noise1 Pacific Gas and Electric (PG&E). 2022. Exploring Clean Energy Solutions. Website: https://www.pge.com/ en_US/about-pge/environment/what-we-are-doing/clean-energy-solutions/clean-energy-solutions.page? WT.mc_id=Vanity_cleanenergy (accessed October 2022).
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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) sensitive uses. The policy further states that they should 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 that may impinge on neighboring properties.

As discussed in Response B3-24, the 65 dBA CNEL standard applies to new residential development as a land use compatibility standard when new residential development is proposed and is not an applicable threshold of significance for noise level increases. Because the proposed project would develop a new industrial use, the 65 dBA CNEL would not apply as a tool used to make a land use compatibility decision. Therefore, the commenter is incorrect that 65 dBA CNEL used for determining where residential uses may be placed is an applicable threshold.

Further, as it relates to potential noise impacts on surrounding residential uses due to traffic noise, the 65 dBA CNEL policy that is being referred to is derived from applying a 10 dBA penalty to nighttime noise level hourly standards presented in Section 10-102 of the Municipal Code to calculate a daily noise level. The Recirculated Draft EIR and supporting Noise Impact Analysis Memorandum (Appendix L of the Recirculated Draft EIR) provide an in-depth analysis of impacts to the residential uses to the south using the appropriate standards presented in Section 10-102 of the Municipal Code.

With the implementation of MM NOI-2, operational noise levels would be less than significant.

For commercial uses during nighttime conditions (the more conservative conditions), the hourly noise level standard is 60 dBA Leq and the anytime noise level for industrial uses is 70 dBA Leq. As presented in the SoundPLAN printouts of the Noise Impact Analysis Memorandum (Appendix L of the Recirculated Draft EIR), the 60 dBA Leq noise contour is within the site boundary to the east and west. At the northern property line, operational noise levels are expected to approach 64 dBA Leq, which is below the 70 dBA Leq standard for industrial uses. As such, the proposed project would not exceed maximum exterior noise level standards. Thus, the project complies with both absolute and relative noise level standards.

Response B3-32: This comment includes a number of recommendations to reduce impacts related to air quality and GHG and asserts that the DEIR fails to consider the Attorney General’s Best Practices and mitigation for warehouse projects.

Comments related to the design of the proposed project are noted. As discussed in Section 4.3, Air Quality, of the Recirculated Draft EIR, implementation of Mitigation Measure AIR-2 requires the use of Tier 4 construction equipment, consistent with the recommendations to require diesel-fueled off-road construction equipment to be equipped with CARB Tier 2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

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3 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) -252 4-compliant engines. In addition, through implementation of Mitigation Measure AIR-3, the project applicant shall ensure that the proposed project would provide the infrastructure for AC and/or DC chargers for electric heavyduty trucks. The infrastructure provided shall accommodate a minimum of one future charger per 50,000 square feet. Mitigation Measure AIR-3 is consistent with the recommendations relating to zero-emission heavy-duty vehicles. With implementation of Mitigation Measures AIR-2 and AIR-3, the proposed project’s potential air quality impacts from construction and operation would not expose sensitive receptors to substantial pollutant concentrations and impacts would be less than significant. The comment does not present substantial evidence of the identification of a potentially significant environmental impact requiring additional mitigation.

Response B3-33: This comment claims that the City cannot make all of the findings for the proposed project, precluding approval of the project’s land use permits. In addition, this comment claims that the project is inconsistent with the General Plan’s Noise and Safety Element and is therefore inconsistent with the General Plan. Refer to Responses B3-24 and B3-25 for a discussion of consistency with the General Plan Noise Element. For the reasons explained in the responses above, the Recirculated Draft EIR properly evaluated the proposed project’s potential impacts, and the commenter has not presented evidence to the contrary. Therefore, a revised EIR is not required.

Response B3-34: This comment claims that the project is likely to have potentially significant impacts related to transportation, air quality, health risk, GHG emissions, noise, energy, and land use and planning, and, as a result, would fail to comply with the Subdivision Map Act.

For the reasons explained in the responses above, the Recirculated Draft EIR properly evaluated the proposed project’s potential impacts related to transportation, air quality, health risk, GHG emissions, noise, energy, and land use and planning, and the proposed project would not result in any significant and unavoidable impacts. The project complies with the Subdivision Map Act and is consistent with the General Plan and zoning as described in the Recirculated Draft EIR. The commenter has not presented evidence to the contrary.

Response B3-35: This comment states that the City must prepare a revised EIR for the proposed project. This comment is noted. For the reasons explained in the responses above, the Recirculated Draft EIR properly evaluated the proposed project’s potential impacts, and the commenter has not presented evidence to the contrary. Therefore, a revised EIR is not required.

Response B3-36: This introductory comment is noted. This comment does not contain any substantive comments or questions about the environmental analysis or 3-253

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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) conclusions contained in the Recirculated Draft EIR. Therefore, no further response is necessary.

Response B3-37: This comment provides a brief project description and does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Recirculated Draft EIR. Therefore, no further response is necessary.

Response B3-38: This introductory comment asserts that the Recirculated Draft EIR fails to adequately analyze significant environmental impacts. This comment is noted. Comments provided in this letter are further responded to below.

Response B3-39: This comment states that the Recirculated Draft EIR fails to address impacts from exposure to Coccidiodes immitis (Valley Fever cocci) from particulate matter released from the project site during construction activities.

Refer to Response B3-10. Background information regarding Valley Fever is discussed on pages 4.2-5 and 4.2-6 of the Recirculated Draft EIR. However, the air quality analysis contained in Section 4.2, Air Quality, of the Recirculated Draft EIR was prepared using the methodologies and assumptions contained in the SJVAPCD’s GAMAQI. The GAMAQI does not include requirements or thresholds of significance for addressing Valley Fever. The closest sensitive receptors include the single-family residences approximately 110 feet south of the project site across West Nielsen Avenue.

Except under high wind conditions, this distance is sufficient that particulate matter will settle prior to reaching the nearest sensitive receptor. In addition, crosswinds influenced by adjacent traffic intersections would help dissipate any particulate matter associated with the construction phase of the project.

Therefore, any Valley Fever spores suspended with the dust will not reach the sensitive receptors. However, during project construction, it is possible that workers could be exposed to Valley Fever through fugitive dust. Dust control measures, consistent with SJVAPCD Regulation VIII (as required by Mitigation Measure AIR-1), would reduce the exposure of the workers. Dust from the construction of the project is not anticipated to exacerbate or significantly add to the existing exposure of people to Valley Fever.

Response B3-40: This comment claims that the Recirculated Draft EIR fails to include adequate mitigation measures and medical monitoring information to prevent exposure to Coccidiodes immitis (Valley Fever cocci) from disturbed soils on site. This comment also recommends the inclusion of several mitigation measures in the Recirculated Draft EIR.

Refer to Responses B3-10 and B3-39, above. The GAMAQI does not include requirements or thresholds of significance for addressing Valley Fever.

Further, dust control measures, consistent with SJVAPCD Regulation VIII (as required by Mitigation Measure AIR-1), would reduce the exposure of the 2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

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3 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) -254 workers. Dust from the construction of the project is not anticipated to exacerbate or significantly add to the existing exposure of people to Valley Fever. Implementation of the proposed project would not exceed any applicable SJVAPCD significance criteria and would result in a less than significant impact; the commenter has not presented evidence to the contrary. As such, identification and analysis of mitigation measures suggested in the comment would not be required to reduce emissions to a less than significant level.

Response B3-41: This comment states that the air quality analysis contained in the Recirculated Draft EIR did not include emissions from an on-site fire pump system.

As discussed in the Recirculated Draft EIR, the proposed project would result in the construction of four office/warehouse buildings that would be configured for heavy industrial uses by tenants that have not been identified.

However, as discussed in Responses A4-6 and B3-7, to be conservative, a supplemental analysis to evaluate potential emissions associated with equipment, emergency backup generators, and diesel fire pumps was conducted using CalEEMod. This supplemental analysis conservatively assumed that 40 diesel-powered forklifts would be used for 8 hours per day and that four diesel-powered 500 HP emergency backup generators and four diesel-powered 500 HP diesel fire pumps would be used for up to 50 hours per year. The results of the supplemental analysis indicate that the use of equipment, emergency backup generators, and diesel fire pumps would not exceed the significance criteria for annual ROG, NOX, CO, SOX, PM10, or PM2.5 emissions. Because emissions would still be below the SJVAPCD’s thresholds, operational emissions would still be considered less than significant.

However, it is important to note that diesel fire pumps have not been identified as part of the project and are not included as part of the proposed project evaluated in this Recirculated Draft EIR.

Response B3-42: This comment claims that the air quality analysis contained in the Recirculated Draft EIR fails to consider the use of refrigeration units and transport refrigeration units (TRUs), resulting in underestimated foreseeable health risk to the community as well as associated GHG emissions.

The air quality analysis contained in the Recirculated Draft EIR assumed the trucks accessing the project site would idle using their main engines rather than an auxiliary power unit or plugging in to on-site electrical hookups throughout their time at the project site. This is a conservative assumption, as the loading docks are required to have electrical hookups and the trucks to have the ability to run their accessories from that electricity during any extended period of idling, so it is likely that the trucks would only briefly operate on their own power when maneuvering on site. It was also assumed that any refrigerated trucks would use the electrical hookups to power the 3-255

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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) TRUs rather than operate their onboard diesel engines. Additionally, the CARB has developed a technical advisory to transition to near-zero-emission technologies and ultimately zero-emission technologies. These technologies will be phased in over time, possibly beginning in the 2020s and extending out to 2050. As such, because TRU trucks would be required to plug in, any increase in emissions associated with TRUs would be minimal and would not result in a significant increase in emissions. Therefore, no revisions to the analysis in the Recirculated Draft EIR are warranted.

Response B3-43: This comment states that the Recirculated Draft EIR states that the proposed project would result in a total of 1,920 average daily trips, including 1,578 passenger vehicle trips and 342 truck trips. This comment also claims that Appendix C of the Recirculated Draft EIR shows a total of 1,589 passenger vehicle trips per day.

Appendix C of the Recirculated Draft EIR contains the CalEEMod output sheets, which estimate that the proposed project would result in a total of 1,920 average daily trips. Appendix D of the Recirculated Draft EIR contains the HRA and its model output. The model output contained in Appendix D of the Recirculated Draft EIR does estimate 1,589 daily passenger vehicle trips and 344 truck trips, resulting in a total of 1,933 average daily trips. The proposed project’s estimated trip generation is slightly less than the trip generation evaluated in the HRA; therefore, the analysis is conservative and likely overestimates operational project emissions. No revisions to the analysis in the Recirculated Draft EIR are warranted.

Response B3-44: This comment suggests that the Recirculated Draft EIR underestimates trip generation.

Refer to Response B3-5. As discussed in the TIS in Appendix M of the Recirculated Draft EIR, the trip generation for the proposed project was developed using rates from the WRCOG Study, which is included as an appendix to the TIS (Appendix M of the Recirculated Draft EIR). The study provides separate trip generation rates for passenger vehicles, 2‐ to 4-axle trucks, and 5+ axle trucks. The truck trips were converted to PCE trips using a PCE factor of 2.0 for 2‐ to 4-axle trucks, consistent with HCM recommendations. However, as a conservative approach, a PCE factor of 3.0 was used for 5+ axle trucks, consistent with the practices in several regions within the State. This methodology is also consistent with the recommended trip generation estimate methodology by ITE, which recommends using average trip generation rates for land uses. The WRCOG Study found that for larger projects, percentages of truck trips compared to total trips are lower than for a fulfillment center of a smaller size. Therefore, the commenter is incorrect in stating that the trip generation assumptions underestimated project trips.
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3 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) -256 Response B3-45: This comment claims that the Recirculated Draft EIR failed to account for the impact on emissions from building downwash, resulting in an underestimation of exposure concentrations.

Refer to Response B3-17. The SJVAPCD Guidance suggests that building downwash effects be included. The commenter incorrectly states that the EIR fails to account for building downwash. In fact, the modeling conducted for the project included building downwash, as recommended by the SJVAPCD.

The image included in Response B3-17 shows a snapshot of the model and a 3-D representation of the building heights that were used to model the downwash effect. The model was made available to the public for review and download at the City. As such, the HRA represents an accurate representation of the project, and the disclosed emissions are accurate.

Response B3-46: This comment states that the air quality analysis contained in the Recirculated Draft EIR failed to account for backup generators.

The proposed project would not involve the use of backup generators. As discussed in the Recirculated Draft EIR, the proposed project would result in the construction of four office/warehouse buildings that would be configured for heavy industrial uses by tenants that have not been identified. Therefore, such equipment has not been identified and is not included as part of the proposed project.

However, as discussed in Responses A4-6 and B3-7, to be conservative, a supplemental analysis to evaluate potential emissions associated with equipment, emergency backup generators, and diesel fire pumps was conducted using CalEEMod. This supplemental analysis conservatively assumed that 40 diesel-powered forklifts would be used for 8 hours per day and that four diesel-powered 500 HP emergency backup generators and four diesel-powered 500 HP diesel fire pumps would be used for up to 50 hours per year. The results of the supplemental analysis indicate that the use of equipment, emergency backup generators, and diesel fire pumps would not exceed the significance criteria for annual ROG, NOX, CO, SOX, PM10, or PM2.5 emissions. Because emissions would still be below the SJVAPCD’s thresholds, operational emissions would still be considered less than significant.

However, it is important to note that emergency backup generators are not being proposed as part of the project.

Response B3-47: This comment claims that the City must prepare a revised EIR for the proposed project. This comment is noted. For the reasons explained in the responses above, the Recirculated Draft EIR properly evaluated the proposed project’s potential impacts, and the commenter has not presented evidence to the contrary. Therefore, a revised EIR is not required. 3-257

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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) Response B3-48: This comment includes the commenter’s resume. The comment is noted, but it does not raise any significant environmental issues related to the project or the analysis contained in the Recirculated Draft EIR.

Response B3-49: This introductory comment is noted. This comment does not contain any substantive comments or questions about the environmental analysis or conclusions contained in the Recirculated Draft EIR. Therefore, no further response is necessary.

Response B3-50: This comment includes the commenter’s qualifications. The comment is noted, but it does not raise any significant environmental issues related to the project or the analysis contained in the Recirculated Draft EIR.

Response B3-51: This comment is a statement of references presenting a summary related to the adverse effects of noise. The comment is noted, but it does not raise any significant environmental issues related to the project or the analysis contained in the Recirculated Draft EIR.

Response B3-52: This comment summarizes comments previously provided on the Initial Study prepared for the proposed project. This comment is noted and is responded to further in Responses B3-53 through B3-59.

Response B3-53: This comment presents Policy NS-1-a of Fresno General Plan, Chapter 9, Noise and Safety, and states that it is important that cities like Fresno adopt absolute standards for the noise environments of their citizens because if only relative standards are used, then there would be no limit to environmental noise exposure over time. In addition, this comment claims that the FTA also recognizes that as the absolute level of noise exposure increases, the relative increase that results in a significant impact reduces.

Refer to Responses B3-2 and B3-31, above. As identified on page 4.9-13 of the Recirculated Draft EIR, as established in General Plan Policy NS-1-j:

Significance Threshold, the City considers a 3 dBA increase to be a significant increase in ambient noise. There is currently no General Policy stating that a less than 3 dBA increase resulting in levels going from below 65 dBA CNEL to above 65 dBA CNEL would constitute a significant impact. As such, traffic noise impacts from project-related traffic on off-site sensitive receptors would be less than significant.

Response B3-54: This comment presents information extracted from Table 4.9.L in the Recirculated Draft EIR. This comment states that the noise exposure goes from a level that is lower than that established by General Plan Policy NS-1-a (65 dBA CNEL) to one that is higher, constituting a significant noise impact.

Refer to Responses B3-24 and B3-31. As identified on page 4.9-13 of the Recirculated Draft EIR, as established in General Plan Policy NS-1-j:
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3 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) -258 Significance Threshold, the City considers a 3 dBA increase to be a significant increase in ambient noise. As such, traffic noise impacts from project-related traffic on off-site sensitive receptors would be less than significant.

Response B3-55: This comment asserts that the Recirculated Draft EIR only calculated the composite noise level of the two loudest pieces of equipment for each construction phase. The comment claims that is a common error that stems from FTA guidance that preliminarily, before much is known about construction, the order of magnitude of construction noise may be determined by combining the levels of the two loudest pieces of equipment, assuming they are running at full power 100 percent of the time. The comment also claims that the types and number of equipment are known in detail from the air quality assessment, so it is appropriate to conduct a detailed calculation of construction noise. The commenter also claims that the calculation include in the Recirculated Draft EIR does not assume usage 100 percent of the time for the two loudest pieces of equipment, so it does not even comport with the FTA preliminary guidance. Refer to Response B3- 25, above.

Response B3-56: This comment asserts that the commenter properly estimated noise levels using the CalEEMod output contained in Appendix C of the Recirculated Draft EIR and based on the reference emission levels and usage factors from Table

4.9.K of the Recirculated Draft EIR. This comment also states that the average acoustical distance used for the calculations is, as the Recirculated Draft EIR explains, calculated by multiplying the shortest distance between the receiver and the noise source area by the farthest distance, and then taking the square root of the product, which is 471 feet. Refer to Response B3-25, above.

Response B3-57: This comment states that construction noise levels would result in an increase over the 5 dBA threshold of significance identified in the Recirculated Draft EIR. Refer to Response B3-25, above.

Response B3-58: This comment states that Mitigation Measure NOI-1 requires the use of mufflers and the designation of a “disturbance coordinator.” The commenter states that while both of these are good ideas that should be implemented, neither would reduce the noise levels. Refer to Response B3-25, above.

Response B3-59: This comment includes the commenter’s calculation of construction noise level increases. Refer to Response B3-25, above.

Response B3-60: This comment includes a conclusion and a summary of the comments provided in the letter. This comment is noted. For the reasons explained in the responses above, the Recirculated Draft EIR properly evaluated the proposed project’s potential impacts, and the commenter has not presented evidence to the contrary.
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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) Response B3-61: This comment provides a closing to the comment letter and does not question the adequacy of the analysis included in the Recirculated Draft EIR.

No further response is required.

Response B3-62: This comment provides an introduction to following comments, which are responded to further in Responses B3-63 through B3-66.

Response B3-63: This comment states that the project’s trip generation could be much higher than assumed as the different fulfillment center sites have different trip generation rates, with an Amazon facility having an especially high rate. This comment also suggests that the Recirculated Draft EIR apply the Amazon trip generation rate.

Refer to Response B3-6. As discussed in the Recirculated Draft EIR, the proposed project would result in the construction of four office/warehouse buildings that would be configured for heavy industrial uses by tenants that have not been identified. However, the project applicant has confirmed an Amazon facility is not under consideration to be a possible tenant. Since Amazon has not been identified as a tenant, using Amazon trip generation rates would not be accurate or applicable to the proposed project. The suggestion that Amazon trip generation rates would more accurately reflect the project’s impacts is therefore speculative and unsupported by substantial evidence. (See CEQA Guidelines, § 15064, subd. (f)(5).) It should also be noted that Amazon has multiple existing facilities already located in Fresno. It is possible that Amazon could build another facility in Fresno; however, Amazon is not expected to locate another facility at the project site. (See id. at § 15145.)
As discussed in the TIS, trip generation rates from the ITE manual for the High‐ Cube Fulfillment Center Warehouse land use have a small sample size. The WRCOG Study facilitated a trip generation study for such facilities. Further, trip generation rates using the WRCOG study are higher than trip generation rates from the ITE manual for the High‐Cube Fulfillment Center Warehouse land use. As such, trip generation rates from the WRCOG Study are conservative and are appropriate for use. The WRCOG Study provides separate trip generation rates for passenger vehicles, 2‐ to 4-axle trucks, and 5+ axle trucks. The truck trips were converted to PCE trips using a PCE factor of 2.0 for 2‐ to 4-axle trucks, consistent with HCM recommendations.

However, as a conservative approach, a PCE factor of 3.0 was used for 5+ axle trucks, consistent with the practices in several regions within the State.

Additionally, as established in the WRCOG Study, the Amazon facility is an outlier. However, as further noted, that facility was also included to calculate the average trip generation rates for High-Cube Fulfilment Center Warehouse land uses. This methodology is also consistent with the recommended trip generation estimate methodology by ITE, which recommends using average trip generation rates for land uses. The WRCOG Study found that for larger 2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

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3 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) -260 projects, percentages of truck trips compared to total trips are lower than a fulfillment center of a smaller size. Therefore, the commenter is incorrect in stating that the trip generation assumptions substantially underestimated project trips.

Response B3-64: This comment claims that project VMT and GHG emissions could be much higher than assumed because if the Amazon trip generation rate were used instead, the VMT output from CalEEMod would be twice as high. If the parcel hub rate were used, the VMT output would six times as high.

As described in Responses B3-6, B3-12, B3-13, B3-14, and B3-15, the traffic assumptions are supported by substantial evidence further explained in the TIS that was prepared for the project, included in Appendix M of the Recirculated Draft EIR. The Technical Memorandum prepared by WSP and dated January 29, 2019, which was included as an appendix to the TIS, explains in great detail the basis for the trip generation rates used in the traffic analysis and air quality analysis. Further, the air quality analysis did not incorporate the VMT from the TIS as the VMT analysis for SB 743 uses a different methodology for air quality. The air quality analysis utilized default trip lengths provided in CalEEMod. Refer to Response A4-3 for a detailed discussion of CalEEMod default assumptions. As demonstrated in Response A4-3, since a project-specific truck trip length is not yet known, the use of CalEEMod defaults is appropriate for projects in the SJVAPCD and the city of Fresno and is consistent with standard practice. As such, the project’s air quality analyses used the correct trip generation and VMT assumptions.

Further, the commenter states that GHG emissions could be much higher than assumed. However, as described in Response 2-2, the City evaluated the proposed project using the Consistency Checklist for consistency with the City’s GHG Reduction Plan Update as discussed on pages 4.6-22 and 4.6-23 of the Recirculated Draft EIR. The project’s Consistency Checklist is included in Appendix H of the Recirculated Draft EIR. 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, and impacts would be less than significant.

Response B3-65: This comment claims that a significant percentage of Fresno County trips have origins or destinations that are outside the county and claims that the Recirculated Draft EIR excluded all VMT outside of the county.

The commenter is incorrect in stating that the VMT analysis did not include or fully evaluate trips that originate/are destined outside Fresno County. As shown in Appendix G of the traffic study, the project VMT included employee trips that originated/were destined outside of Fresno County (internal- 3-261

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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) external/external-internal trips). Therefore, the project VMT estimates accounted for trips originating from outside the Fresno COG ABM region as well.

In addition, as discussed in Response B3-14, truck trips were not included in the VMT analysis, consistent with the CEQA Guidelines Section 15064.3, subdivision (a), which states, “For the purposes of this section, ‘vehicle miles traveled’ refers to the amount and distance of automobile travel attributable to a project.” The technical guidance from OPR does say that heavy-duty truck VMT “could be included”; however, the Guidance goes on to state that this would be for modeling convenience and ease of calculation. Heavy-duty trucks are not included in the CEQA Guidelines for VMT analysis, are not included in the Fresno COG model, and therefore were not included in the VMT analysis. “An agency’s use of a reasonable standard for gauging the significance of an impact may not be set aside on the ground the impact would have been found significant if other recognized standards had instead been used.”
Response B3-66: This comment asserts that transportation demand management strategies, including implementation of pedestrian, bicycle, and transit linkages with surrounding land uses and neighborhoods and trip reduction programs consistent with SJVAPCD Rule 9410.

As discussed on page 4.10-11 of the Recirculated Draft EIR, there are no existing dedicated transit facilities within the study area for the proposed project. The proposed project is not located in an important transit corridor in the city; therefore, it is not anticipated that the construction of additional transit facilities would be required in the study area as a result of the proposed project. Further, as discussed on page 4.10-11, there are existing Class II bike lanes along Marks Avenue and Nielsen Avenue within the study area for the proposed project, in the vicinity of the project site. Pursuant to the City’s Active Transportation Plan, future Class II bike lanes will be added along Belmont Avenue and Hughes Avenue within the project study area to improve bicycle and pedestrian accessibility and connectivity in the vicinity of the project site. In addition, as discussed on page 4.10-11, paved sidewalks are currently present intermittently on both sides of Belmont Avenue and Marks Avenue. Pursuant to the City’s Active Transportation Plan, the City recommends pedestrian sidewalks to be constructed on Marks Avenue, Nielsen Avenue, Belmont Avenue, and Hughes Avenue within the study area.

The proposed project would construct sidewalks along the project frontage on Marks Avenue, Nielsen Avenue, and Hughes Avenue. Sidewalks would be constructed pursuant to City standards and would increase pedestrian access and safety in the study area. Therefore, the commenter is incorrect that the Recirculated Draft EIR does not discuss bicycle and transit linkages with surrounding land uses and neighborhoods.
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3 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\3.0 Responses.docx (09/01/23) -262 In addition, as discussed in Response A4-18, the proposed project would comply with all required SJVAPCD rules and regulations. In addition, as identified in Appendix H, Greenhouse Gas Reduction Plan Update Checklist, of the Recirculated Draft EIR, the project would have over 100 employees and would be required to comply with SJVAPCD Rule 9410.

Response B3-67: This comment includes the commenter’s resume. The comment is noted, but it does not raise any significant environmental issues related to the project or the analysis contained in the Recirculated Draft EIR.
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4.0 RECIRCULATED DRAFT EIR TEXT REVISIONS
This chapter presents specific changes to the text of the Recirculated Draft EIR that are being made to clarify any errors, omissions, or misinterpretation of materials in the Recirculated Draft EIR in response to comments received during the public review period and clarifications that are Cityinitiated. In no case do these revisions result in a greater number of impacts or impacts of a greater severity than those set forth in the Recirculated Draft EIR. Further, the clarifications and corrections provided in the following revisions do not constitute significant new information requiring recirculation of the Recirculated Draft EIR. Where revisions to the main text are called for, the page and paragraph are set forth, followed by the appropriate revision. Added text is indicated with double‐ underlined text, and deleted text is shown in strikeout.

4.1 SECTION 4.2, AIR QUALITY
The following text revision is made to page 4.2-35 of the Recirculated Draft EIR:

For this HRA, the truck travel emissions were modeled as a series of volume sources along the on-site driveway, and along EastNorth Marks Avenue going north and south of the site driveway, and along West Nielsen Avenue going east and west of the site driveway consistent with standard methodology.

4.2 SECTION 4.8, HYDROLOGY AND WATER QUALITY
The following text revision was made to page 4.8-13 of the Recirculated Draft EIR:

Project-specificThe City’s projected future water demand was calculated using the methodology from the 2020 UWMP, as described above, based on the following assumptions:
• Figure 4-3 of the 2020 UWMP indicates there will be 5,201 acres of industrial uses in Fresno in 2025.
• Table 4-6 of the 2020 UWMP indicates the projected water demand for industrial land uses in 2025 will be 7,410 AFY.

Therefore, it isthe 2020 UWMP assumed that industrial land uses, such as the proposed project, will demand approximately 1.42 AFY per acre in 2025. The total project site is 48.03 acres.; tTherefore, based on the assumptions for water demand associated with industrial land uses identified above, the proposed project is2020 UWMP estimated to demand approximately 68.2 AFY for the project site.

The project would result in the construction of four office/warehouse buildings that would be configured for heavy industrial uses by tenants that have not been identified. In addition, at this time, the specific number of employees is not yet known. As such, the proposed project’s water demand was calculated based on the 2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

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4 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\4.0 DEIR Text Revisions.docx (09/01/23) -2 Water Study Demand Manual1, which estimates that industrial uses demand approximately 0.9 acre-feet per year (AFY) per acre. The proposed project site is 48.03 acres; therefore, the proposed project is estimated to demand approximately 43.23 AFY. As such, the proposed project’s water demand is below the 68.2 AFY planned for the project site in the 2020 UWMP.

4.3 SECTION 4.11, UTILITIES AND SERVICE SYSTEMS
The following text revision is made to page 4.11-5 of the Recirculated Draft EIR:

The FMFCD drainage area for stormwater from the project site is bBasin Drainage Areas “AS” and “ZZ”, located southwest from the site.

The following text revision is made to page 4.11-14 of the Recirculated Draft EIR:

Once operational, water service to the project site would be provided by the City.

New water within the project site would connect to the existing 14-inch main located on North Marks Avenue, and the 16-inch main on North Hughes Avenue, and the 14- inch main on West Nielsen Avenue. The project would also include an on-site private 12-inch water main. Extension of the water infrastructure from the adjacent streets into the project site would be a routine part of the construction process analyzed in this EIR and would not have a material environmental impact. The water facility improvements would be limited to the project site and connection points to the adjacent, existing facilities. In addition, as described further in Threshold 4.11.2 below, the City has concluded that the City of Fresno’s water system has sufficient capacity to supply the proposed project and other projected demands within the City’s service area through the year 2045. Therefore, the proposed project would not require or result in the construction of new water facilities, or the expansion of existing facilities, which could cause a significant environmental impact, and the impact would be less than significant.

The following text revision is made to page 4.11-14 of the Recirculated Draft EIR:

Once operational, the City would provide wastewater collection and treatment for the proposed project, and maintains an existing 12- to 18-inch line located inon West Nielsen Avenue, a 36-inch main on North Marks Avenue, and an 8-inch main on North Hughes Avenue. The proposed project includes the installation of a new on-site private 8-inch wastewater line that would connect to the City’s existing line. Any sewer improvements associated with the proposed project would be designed and constructed to City standards. In addition, the City of Fresno Department of Public Utilities has determined that adequate sanitary sewer and wastewater services would be available to serve the proposed project subject to the 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 1 Sacramento, City of. 2018. Water Study Demand Manual. January. 4-3

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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\4.0 DEIR Text Revisions.docx (09/01/23) policies. In addition, as described further in Threshold 4.11.2 below, the City has concluded that the City of Fresno’s wastewater system has sufficient capacity to supply the proposed project and other projected demands within the City’s service area through the year 2045. As such, the proposed project would result in less than significant impacts related to the construction or expansion of wastewater treatment facilities. Therefore, the proposed project would not require or result in the construction of new wastewater treatment or collection facilities, or the expansion of existing facilities, which could cause a significant environmental impact. Therefore, the impact would be less than significant.

The following text revision is made to page 4.11-18 of the Recirculated Draft EIR:

Project-specificThe City’s projected future water demand was calculated using the methodology from the 2020 UWMP, as described above, based on the following assumptions:
• Figure 4-3 of the 2020 UWMP indicates there will be 5,201 acres of industrial uses in Fresno in 2025.
• Table 4-6 of the 2020 UWMP indicates the projected water demand for industrial land uses in 2025 will be 7,410 AFY.

Therefore, it isthe 2020 UWMP assumed that industrial land uses, such as the proposed project, will demand approximately 1.42 AFY per acre in 2025. The total project site is 48.03 acres.; tTherefore, based on the assumptions for water demand associated with industrial land uses identified above, the proposed project is2020 UWMP estimated to demand approximately 68.2 AFY for the project site.

The project would result in the construction of four office/warehouse buildings that would be configured for heavy industrial uses by tenants that have not been identified. In addition, at this time, the specific number of employees is not yet known. As such, the proposed project’s water demand was calculated based on the Water Study Demand Manual1, which estimates that industrial uses demand approximately 0.9 acre-feet per year (AFY) per acre. The proposed project site is 48.03 acres; therefore, the proposed project is estimated to demand approximately 43.23 AFY. As such, the proposed project’s water demand is below the 68.2 AFY planned for the project site in the 2020 UWMP.

4.4 APPENDIX K, WATER SUPPLY ASSESSMENT
The following text revision is made to page 1 of Appendix K, Water Supply Assessment, of the Recirculated Draft EIR:
1 Sacramento, City of. 2018. Water Study Demand Manual. January. 2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

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EXECUTIVE SUMMARY
The proposed project would result in the construction of four office/warehouse buildings that would be configured for heavy industrial uses by tenants that have not been identified. As such, the project-specific water usage is not yet known. Projectspecific water demand was calculated based on the Water Study Demand Manual1 ,
which estimates that industrial uses demand approximately 0.9 acre-feet per year (AFY) per acre. The proposed project site is 48.03 acres; therefore, the proposed project is estimated to demand approximately 43.23 AFY.

The project water demand evaluated in this WSA will be compared to the water service planned for future industrial uses in the City using the City’s adopted 2020 UWMP methodologies, which was calculated on the basis of the following assumptions:
• Figure 4-3 of the 2020 UWMP indicates there will be 5,201 acres of industrial uses in Fresno in 2025.
• Table 4-6 of the 2020 UWMP indicates the projected water demand for industrial land uses in 2025 will be 7,410 AFY.

Therefore, is the 2020 UWMP assumed that industrial land uses, will demand approximately 1.42 AFY per acre in 2025. The total project site is 48.03 acres; therefore, based on the assumptions for water demand associated with industrial land uses identified above, the 2020 UWMP estimated approximately 68.2 AFY for the project site.

As identified above, the proposed project is estimated to demand approximately

43.23 AFY. As such, the proposed project’s water demand is below the 68.2 AFY planned for the project site in the 2020 UWMP.

Since land use acreages and water demand in the 2020 UWMP were based on the City’s General Plan land use designations for 2020 and buildout in 2056 and since the acreage associated with the proposed project was assumed Industrial in the 2020 UWMP, this WSA assumes that demand for water was accounted for in the 2020 UWMP. There is no evidence, in consideration of the calculated project water demand, that such demand exceeds that estimated in the 2020 UWMP. The adequacy of the water supply for the project is thus consistent with the basis of the analysis of the City’s water supply in the adopted 2020 UWMP.

As such, this WSA concluded that the City of Fresno’s water system has sufficient capacity to supply the proposed project and other projected demands within the City’s service area through the year 2045.
1 Sacramento, City of. 2018. Water Study Demand Manual. January. 4-5

RESPONSE TO COMMENTS DOCUMENT
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2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

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\\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\4.0 DEIR Text Revisions.docx (09/01/23) The following text revision is made to page 5 of Appendix K, Water Supply Assessment, of the Recirculated Draft EIR:

The project site is located in an urban area and is currently served by existing utilities, including: water, sanitary sewer, storm drainage, electricity, and natural gas infrastructure. Water service to the project site would be provided by the City. New water within the project site would connect to the existing 14-inch main located on North Marks Avenue, and the 16-inch main on North Hughes Avenue, and the 14-inch main on West Nielsen Avenue. The project would also include an on-site private 12- inch water main. The City would provide wastewater collection and treatment for the proposed project, and maintains an existing 12- to 18-inch line located inon West Nielsen Avenue, a 36-inch main on North Marks Avenue, and an 8-inch main on North Hughes Avenue. The proposed project includes the installation of a new on-site private 8-inch wastewater line that would connect to the City’s existing lines. The proposed project would include construction of a new curb and gutter along North Marks Avenue, West Nielsen Avenue, and North Hughes Avenue that would connect to the existing Fresno Metropolitan Flood Control District (FMFCD) stormwater system.

The following text revision is made to page 6 of Appendix K, Water Supply Assessment, of the Recirculated Draft EIR:

The City of Fresno relies on groundwater from the North Kings Subbasin; surface water from the Central Valley Project (CVP), through a contract with the United States Bureau of Reclamation (USBR); Kings River water, through a contract with Fresno Irrigation District (FID); and recycled water to meet current and future water demands. The information provided on the following pages areis extracted directly from the 2020 UWMP (Pages 6-1 through 6-32) in satisfaction of Water Code sections 10910(A)(1) and 10910(D)(2). This information is applicable to the entire City of Fresno municipal water service area, including the project site.

The following text revision is made to page 18 of Appendix K, Water Supply Assessment, of the Recirculated Draft EIR:

As such, the supply projections in this plan limit the City’s FID supply with the 29.0 percent cap, but if the agreement were revised in the future the City’s FID allocation percentage could grow beyond 29.0 percent as the water service area expands.

The following text revision is made to page 45 of Appendix K, Water Supply Assessment, of the Recirculated Draft EIR:

Assumptions
Project-specificThe City’s projected future water demand was calculated using the methodology from the 2020 UWMP, as described above, based on the following assumptions:
2740 WEST NIELSEN AVENUE OFFICE /WAREHOUSE P ROJECT

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S EPTEMBER 2023
4 \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Final\4.0 DEIR Text Revisions.docx (09/01/23) -6 • Figure 7 above (Figure 4-3 of the 2020 UWMP) indicates there will be 5,201 acres of industrial uses in Fresno in 2025.
• Table M above (Table 4-6 of the 2020 UWMP) indicates the projected water demand for industrial land uses in 2025 will be 7,410 AFY.

Therefore, it isthe 2020 UWMP assumed that industrial land uses, such as the proposed project, will demand approximately 1.42 AFY per acre in 2025. The total project site is 48.03 acres; therefore, based on the assumptions for water demand associated with industrial land uses identified above, the 2020 UWMP estimated approximately 68.2 AFY for the project site.

Proposed Project Water Demand
The total project site is 48.03 acres. Therefore, based on the assumptions identified above, the proposed project is estimated to demand approximately 68.2 AFY.The project would result in the construction of four office/warehouse buildings that would be configured for heavy industrial uses by tenants that have not been identified. In addition, at this time, the specific number of employees is not yet known. As such, the proposed project’s water demand was calculated based on the Water Study Demand Manual1, which estimates that industrial uses demand approximately 0.9 AFY per acre. The proposed project site is 48.03 acres; therefore, the proposed project is estimated to demand approximately 43.23 AFY. As such, the proposed project’s water demand is below the 68.2 AFY planned for the project site in the 2020 UWMP.
1 Sacramento, City of. 2018. Water Study Demand Manual. January. \\lsaazfiles.file.core.windows.net\projects\SNN2102 2740 W. Nielsen\PRODUCTS\Final EIR\Admin\Appendix A Comments.docx (06/08/23)

APPENDIX A
COMMENT LETTER B3 ATTACHMENTS

RESPONSE TO COMMENTS DOCUMENT
S EPTEMBER 2023
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RESPONSE TO COMMENTS DOCUMENT
S EPTEMBER 2023

EXECUTIVE DEPARTMENT

STATE OF CALIFORNIA

PROCLAMATION OF A STATE OF EMERGENCY
WHEREAS beginning on June 16, 2021, a significant heat wave struck California, bringing widespread near-record temperatures well in excess of 100 degrees throughout the State (the "Extreme Heat Event"); and WHEREAS as a result of this Extreme Heat Event, the National Weather Service issued an Excessive Heat Warning within the State; and WHEREAS the Extreme Heat Event has and will continue to put significant demand and strain on California's energy grid; and WHEREAS on June 16, 2021, the California Independent System Operator (CAISO) issued a Flex Alert, calling for voluntary electricity conservation from 5:00 PM to 10:00 PM on June 17, 2021 to mitigate impact to energy supplies during this Extreme Heat Event; and WHEREAS the Extreme Heat Event is expected to last through at least June 18, 2021; and
WHEREAS it is necessary to take action to reduce the strain on the energy infrastructure and increase energy capacity during the Extreme Heat Event; and
WHEREAS it is critical that power plants in the State generate as much power as possible to satisfy the increased demand created by the Extreme Heat Event; and
WHEREAS under the provisions of Government Code section 8558, subd. (b}, I find that conditions of extreme peril to the safety of persons and property exist due to the Extreme Heat Event throughout California; and
WHEREAS. under the provisions of Government Code section 8625, subd. (c), I find that local authority is inadequate to cope with the magnitude and impacts of the Extreme Heat Event; and
WHEREAS under the provisions of Government Code section 8571, I find that strict compliance with various statutes and regulations specified in this Order would prevent, hinder, or delay appropriate actions to prevent and mitigate the effects of the Extreme Heat Event.

NOW, THEREFORE, I, GAVIN NEWSOM, Governor of the State of California, in accordance with the authority vested in me by the State Constitution and statutes, including the California Emergency Services Act, and in particular, Government Code sections 8567, 8571, 8625, and 8627, HEREBY PROCLAIM A STATE OF EMERGENCY to exist in California.

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IT IS HEREBY ORDERED THAT:
l. In preparing for and responding to the Extreme Heat Event, all agencies of state government use and employ state personnel, equipment, and facilities or perform any and all activities consistent with the direction of the Governor's Office of Emergency Services and the State Emergency Plan. Also, all residents are to obey the direction of emergency officials with regard to this emergency in order to protect their safety.

2. For purposes of regulations concerning stationary generators, use of stationary generators during the Extreme Heat Event shall be deemed an "emergency use" under California Code of
Regulations (CCR), title 17, section 93115.4, subd. (a}(30}(A}(2).

3. For purposes of regulations concerning portable generators, the Extreme Heat Event shall be deemed an "emergency event" under CCR, title 17, section 93116.1, subd. (b}( 14), and a loss of electrical service shall be deemed "beyond the reasonable control of the owner or operator" under CCR, title 17, section 93116.2, subd. ( a}( 12}(A)(2). In addition, the Extreme Heat Event shall be deemed an "emergency event" under CCR, title 13, section 2452, subd. (j), and interruptions caused by the Extreme Heat Event shall be deemed an "unforeseen interruption of electrical power from the serving utility" under CCR, title 13, section 2453, subd. (m)(4)(E)( 1).

4. In regulations concerning the use of auxiliary engines by oceangoing vessels berthed in California ports, the Extreme Heat Event shall be deemed an "emergency event" under CCR, title 17, section 93118.3, subd. ( c)( 14).

5. This Order shall be deemed to provide notice to reduce use of grid-based electrical power under CCR, title 17, section 93118.3, subd. (c)( l 4)(C), and notice under that same section that reduction is no longer necessary at 11 :59 p.m. on June 19, 2021.

Ships that are berthed at California ports between June 16, 2021 and June 19, 2021 shall not be required to use shore power until after 11 :59 pm on June 22, 2021.

6. A ship operating on auxiliary engines pursuant to an "emergency event" under Paragraph 4 of this Order shall be deemed to qualify for an exemption under CCR, title 17, section 93118.3, subd. (d)( 1 )(E)( 1 )(a), and any visit occurring during the period described in Paragraph 5 of this Order shall be counted towards compliance under CCR, title 17, section 93118.3, subd. (d)(l}(F)(l).

7. The Air Resources Board shall exercise maximum discretion to permit the use of stationary and portable generators or auxiliary ship engines to reduce the strain on the energy infrastructure and increase energy capacity during the Extreme Heat Event.

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8. The provisions of Water Code section 13385, subd. (i) ( 1) (A) as they pertain to daily average and instantaneous temperature limitations in waste discharge requirements for thermal power plants are suspended for any thermal power plant that maintains operations to abate the effects of the Extreme Heat Event. Any exceedance of the daily average or instantaneous temperature limitations resulting from maintaining operations during this time shall not constitute a violation for purposes of calculating mandatory minimum penalties under Water Code section 13385, subd. (i).

9. Permitting requirements or conditions of certification adopted by the Energy Commission pursuant to Public Resources Code, sections 25216.5, subd. (a) and 25500 et seq., as well as related permitting requirements adopted by local air quality
management districts, that restrict the amount of power that a facility may generate, restrict the amount of fuel that a facility may use, or impose air quality requirements that prevent the facility from generating additional power during peak demand hours, from 3:00 p.m. to 10:00 p.m. or as otherwise needed to respond to the Extreme Heat Event, are suspended.

10. Any facility that operates in violation of permitting requirements or conditions of a certificate suspended by Paragraph 9 shall:
(i) notify the relevant local air quality management district, the Energy Commission, and the Air Resources Board of its actions within 48 hours; and
(ii) report additional fuel use, additional hours of operation, and energy produced by that additional use and
operation to the relevant local air quality management
district, the Energy Commission, and the Air Resources
Board within 30 days of this Order.
11 . Any permit, regulation or law prohibiting, restricting or penalizing the use of stationary or portable generators or auxiliary ship engines or other conduct allowed by this Order during the Extreme Heat Event is suspended.

12. The provisions in Paragraphs 2-9 of this Order shall expire at 11 :59 p.m. on June 19, 2021, with the exception that, as provided in Paragraph 5, ships that are berthed at California ports between June 16, 2021 and June 19, 2021 shall not be required to use shore power until after 11 :59 pm on June 22, 2021.

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I FURTHER DIRECT that as soon as hereafter possible, this proclamation be filed in the Office of the Secretary of State and that widespread publicity and notice be given of this proclamation.

IN WITNESS WHEREOF I have hereunto
set my hand and caused the Great
Seal of the State of California to be
affixed this 17th day of June 2021 .

GAVIN NEWSOM
Governor of California
ATTEST:

SHIRLEY WEBER
Secretary of State
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5/19/23, 10:41 AM 2740 West Nielsen Avenue Office/Warehouse Project (Development Permit Application No. P21-02699 and Tentative Parcel Map No. P21-05930) https://ceqanet.opr.ca.gov/2022050265/3 1/3
2740 West Nielsen Avenue Office/Warehouse Project (Development Permit Application No. P21-02699 and Tentative Parcel Map No. P21- 05930)
Summary
Contact Information
SCH Number 2022050265
Lead Agency City of Fresno
Document Title 2740 West Nielsen Avenue Office/Warehouse Project (Development Permit Application No. P21-02699 and Tentative Parcel Map No. P21-05930)
Document Type EIR - Draft EIR
Received 2/24/2023
Present Land Use IH (Heavy Industrial) / Heavy Industrial Document Description The proposed project would result in the construction of four office/warehouse buildings that would be configured for heavy industrial uses by tenants that have not been identified. The proposed buildings would result in a total gross floor area of approximately 901,438 square feet. The buildings’ exterior would be up to 44 feet high with an interior height of up to 36 feet and designed with a total of 201 loading dock doors on the north and south sides of the buildings. The four buildings would be comprised of the following: Building 1 would be 468,812 square feet and would provide 122 loading dock doors; Building 2 would be 248,786 square feet and would provide 46 loading dock doors; Building 3 would be 93,074 square feet and would provide 18 loading dock doors; and Building 4 would be 90,766 square feet and would provide 15 loading dock doors. A total of 594 on-site parking spaces would be provided for vehicles and trucks.

Name Steven Martinez
Agency Name City of Fresno, Planning and Development Department Job Title Planner
Contact Types Lead/Public Agency
Address 2600 Fresno Street, Room 3043
Fresno, CA 93721
Phone (559) 621-8047
B3 Attach #1 of 3
5/19/23, 10:41 AM 2740 West Nielsen Avenue Office/Warehouse Project (Development Permit Application No. P21-02699 and Tentative Parcel Map No. P21-05930) https://ceqanet.opr.ca.gov/2022050265/3 2/3
Location
Notice of Completion
Email [email protected]
Coordinates 36°44'39.408"N 119°50'23.964"W
Cities Fresno
Counties Fresno
Regions Southern California
Cross Streets northeast of intersection of North Marks Avenue and West Nielsen Avenue Zip 93722
Total Acres 48.03
Parcel # 458-020-71 & 458-020-72
State Highways 180
Township 06
Range 14S
Section 20E
State Review Period
Start
2/24/2023
State Review Period End 5/19/2023
State Reviewing
Agencies
California Air Resources Board (ARB), California Department of Fish and Wildlife, Central Region 4 (CDFW), California Department of Parks and Recreation, California Department of Transportation, District 6 (DOT), California Department of Water Resources (DWR), California Highway Patrol (CHP), California Native American Heritage Commission (NAHC), California Natural Resources Agency, California Regional Water Quality Control Board, Central Valley Fresno Region 5 (RWQCB), Central Valley Flood Protection Board, Office of Historic Preservation, State Water Resources Control Board, Division of Drinking Water
Development Types Industrial (Number of employees is unknown)(Sq. Ft. 901438, Acres 48.03, Employees 1) Local Actions Site Plan, Land Division (Subdivision, etc.) Project Issues Aesthetics, Agriculture and Forestry Resources, Air Quality, Biological Resources, Cultural Resources, Cumulative Effects, Energy, Flood Plain/Flooding, Geology/Soils, Greenhouse Gas Emissions, Hazards & Hazardous Materials, Hydrology/Water Quality, Land Use/Planning, Noise, Solid Waste, Transportation, Tribal Cultural Resources, Utilities/Service Systems
Local Review Period
Start
2/24/2023
B3 Attach #1 of 3
5/19/23, 10:41 AM 2740 West Nielsen Avenue Office/Warehouse Project (Development Permit Application No. P21-02699 and Tentative Parcel Map No. P21-05930) https://ceqanet.opr.ca.gov/2022050265/3 3/3
Attachments
Disclaimer: The Governor’s Office of Planning and Research (OPR) accepts no responsibility for the content or accessibility of these documents. To obtain an attachment in a different format, please contact the lead agency at the contact information listed above. You may also contact the OPR via email at [email protected] or via phone at (916) 445-0613. For more information, please visit OPR’s Accessibility Site.

Local Review Period End 5/19/2023
Draft Environmental
Document [Draft IS,
NOI_NOA_Public
notices, OPR Summary
Form, Appx,]
__Memo _2740 Nielsen_NOA
_2740 W Nielsen Recirculated Public Review Draft EIR
_City of Fresno Memo - 2740 W Nielsen Ave Project Recirculated DEIR 2740 Nielsen Summary_Form 2740 Nielsen_NOA
2740 W Nielsen Appendices Vol 1_A - I
2740 W Nielsen Appendices Vol 2_J - M
2740 W Nielsen Public Review Draft EIR
PDF 97 K PDF 172 K
PDF 504 K
PDF 469 K
PDF 612 K PDF 164 K
PDF 45864 K
PDF 47112 K
PDF 13595 K
Notice of Completion
[NOC] Transmittal form
2740 Nielsen_NOC SIGNED 02 PDF 826 K
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P ROGRAM ENVIRONMENTAL I MPACT REPORT

P UBLIC REVIEW DRAFT
MARCH 2020

GENERAL P LAN

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APPENDIX G

GREENHOUSE GAS REDUCTION PLAN UPDATE
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GENERAL P LAN

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P ROGRAM ENVIRONMENTAL I MPACT REPORT

P UBLIC REVIEW DRAFT
MARCH 2020
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March 2020

GREENHOUSE GAS REDUCTION PLAN UPDATE

CITY OF FRESNO, CALIFORNIA
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March 2020

GREENHOUSE GAS REDUCTION PLAN UPDATE

CITY OF FRESNO, CALIFORNIA
Submitted to:

City of Fresno
2600 Fresno Street #3043
Fresno, California 93721
Prepared by:

LSA
7086 North Maple Avenue, Suite 104
Fresno, California 93720
559.490.1210
Project No. CFO1802
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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) i

EXECUTIVE SUMMARY
The City of Fresno (City) is committed to providing a livable, equitable, and economically vibrant community through the reduction of greenhouse gas (GHG) emissions. By using energy more efficiently, harnessing renewable energy to power buildings, recycling waste, and enhancing access to sustainable transportation modes, the City will keep dollars in the local economy, create jobs, and improve the community’s quality of life. To that end, the City has implemented a number of sustainability and conservation efforts and seeks to continue those efforts through local planning and partnerships. This GHG Reduction Plan Update (GHG Plan Update) integrates the City’s past and current efforts with its future efforts to grow and thrive sustainably.

The City adopted its first GHG Reduction Plan (GHG Plan) in December 2014.1 The GHG Plan established a target of reducing per capita GHG emissions in the city by 21.7 percent below 2020 business-as-usual (BAU) levels by 2020 and includes GHG reduction measures designed to achieve the reduction target. The GHG Plan is considered a “Qualified Plan,” according to California Environmental Quality Act (CEQA) Guidelines §15183.5.2 Since adoption of the GHG Plan, two significant regulations/decisions have been established. First, on September 28, 2016, Governor Brown signed Senate Bill (SB) 32 into law that sets a Statewide goal of reducing GHG emissions to 40 percent below 1990 levels by 2030. Additionally, on November 30, 2015, the California Supreme Court published its decision on the Newhall Ranch Specific Plan invalidating the Environmental Impact Report (EIR) for a variety of reasons, including the use of 29 percent below business-as-usual (BAU) as a threshold to determine significance of GHG emissions under CEQA without any supporting evidence. The GHG Plan Update ensures conformity with the mandates of California Supreme Court in the Newhall Ranch case and the State of California’s latest GHG regulations. The GHG Plan Update re-evaluates the City’s GHG reduction targets and existing reduction strategies from the 2014 GHG Plan. New goals and supporting measures are proposed to reflect and ensure compliance with changes in the local and State policies and regulations such as SB 32 and California’s 2017 Climate Change Scoping Plan. The City’s GHG inventory, based on the most recent data available for the year 2016 is evaluated and the future growth in emissions for the BAU and adjusted BAU (ABAU) scenarios (the ABAU scenario takes into account the State policies) for the years 2020, 2030, and 2035 are projected. The 2020 and 2030 forecast years are consistent with the goals identified in Assembly Bill (AB) 32 and SB 32, which identify Statewide GHG reduction targets by 2020 and 2030. The 2035 forecast year correspond to the City’s General Plan horizon year and will allow the City to develop long-term strategies to continue GHG reductions. 1 FirstCarbon Solutions. 2014. Fresno General Plan Update, Greenhouse Gas Reduction Plan, prepared for the City of Fresno. July. Website: https://www.fresno.gov/darm/wp-content/uploads/sites/10/2016/11/F2-Greenhouse-Gas-Reduction-Plan.pdf (accessed December 2019). 2 CEQA Guidelines 15183.5 describes requirements of a GHG Reduction Plan that would mitigate cumulative levels of GHG emissions within a jurisdiction to a less-than-significant level and allows development project tiering from the GHG Reduction Plan.

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C ITY OF F RESNO GHG REDUCTION PLAN UPDATE
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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) ii The City’s total GHG emissions in 2016 were 2,923,633 metric tons of carbon dioxide equivalent (MT CO2e) (Table ES-A). Under the BAU scenario, in the absence of regulations and other measures to reduce GHG emissions, the City’s BAU emissions in 2020 are estimated to be 3,092,486 MT CO2e, or a 5.8 percent increase from 2016 emissions. By 2030, emissions are estimated to increase 19.7 percent from the 2016 level to 3,500,204 MT CO2e. By 2035, emissions are estimated to increase

26.5 percent from the 2016 level to 3,697,738 MT CO2e.

Table ES-A: City of Fresno 2016 Inventory Update and Business-as-Usual (BAU) Projections
Sector
2016
(MT CO2e)
Percent
of Total
2020
(MT CO2e)
Percent
of Total
2030
(MT CO2e)
Percent
of Total
2035
(MT CO2e)
Percent
of Total
Transportation 1,520,052 52 1,594,888 52 1,798,498 51 1,909,852 52 Commercial Energy 524,838 18 557,142 18 627,373 18 657,379 18 Residential Energy 479,371 16 514,053 17 579,546 17 603,951 16 Fugitive Emissions 270,130 9 288,573 9 335,316 10 357,008 10 Solid Waste 119,167 4 127,303 4 147,923 4 157,493 4
Industrial Energy 10,055 <1 10,506 <1 11,528 <1 12,035 <1 Agriculture Energy 20 <1 20 <1 20 <1 20 <1
Total 2,923,633 100 3,092,486 100 3,500,204 100 3,697,738 100 Source: City of Fresno 2016 Inventory Update (ICLEI Local Governments for Sustainability (2018). Compiled by LSA Associates, Inc. (2019).

Notes:
– Residential Energy Includes emissions from both electricity and natural gas. – Commercial Energy includes emissions from both electricity and natural gas. – Industrial Energy includes emissions associated with electricity. – Agriculture Energy includes emissions associated with electricity.MT CO2e = metric tons of carbon dioxide equivalent Under the ABAU forecast (which represents State efforts in reducing GHG emissions within the city), emissions will be 2,132,326 MT CO2e in 2020; 1,939,325 MT CO2e in 2030; and 1,801,137 MT CO2e in 2035 (Table ES-B).

Table ES-B: City of Fresno Adjusted Business-as-Usual (ABAU) Emissions Sector 2016 2020 2030 2035
Transportation 1,520,052 1,170,329 1,131,034 1,072,955
Commercial Energy 524,838 355,121 290,950 255,226
Residential Energy 479,371 324,760 190,210 124,904
Fugitive Emissions 270,130 144,287 167,658 178,504
Solid Waste 119,167 127,303 147,923 157,493
Industrial Energy 10,055 10,506 11,528 12,035
Agriculture 20 20 20 20
Total 2,923,633 2,132,326 1,939,325 1,801,137
Source: Compiled by LSA Associates, Inc. (2019)
This GHG Plan Update assesses the previous GHG reduction targets identified in the 2014 GHG Plan and proposes new targets that are consistent with State policies. In order to bring the City of Fresno GHG Plan in-line with the State’s GHG reduction goals, emission reduction targets have been B3 Attach #1 of 3
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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) iii identified as shown in Table ES-C and Figure ES-1. Based on the City’s ABAU Inventory, the City would meet the reduction target in 2020. In 2030 and 2035, the City would need to reduce emissions by 29,316 MT CO2e and 209,463 MT CO2e below the ABAU scenario, respectively, to meet the State-aligned target.

Table ES-C: State-Aligned GHG Emission Reduction Targets By Year Sector 2010 1 2016 2020 2030 2035
BAU Emissions (MT CO2e) 3,745,115 2,923,633 3,092,486 3,500,204 3,697,738 Adjusted BAU Emissions (MT CO2e) 3,745,115 2,923,633 2,132,326 1,939,325 1,801,137 State-Aligned Target (Percent change from 1990) — — 0 -40 -50 State-Aligned Target (Percent change from 2010) — — -15 -49 -58 State-Aligned Emissions Goal (MT CO2e) — — 3,183,348 1,910,009 1,591,674 Reductions from Adjusted BAU needed to meet
the State-Aligned Target (MT CO2e) — — Target Met 29,316 209,463 Source: Compiled by LSA Associates, Inc. (2019) 1
Baseline (2010) emissions are from the City’s 2014 GHG Reduction Plan.

BAU = Business-as-Usual
GHG = greenhouse gas
MT CO2e = metric tons carbon dioxide equivalent
Figure ES-1: City of Fresno GHG Emissions Inventory, Forecast, and Targets This GHG Plan Update provides a description of General Plan policies that support a reduction in GHGs from all sources within the City’s ability to control or influence. These strategies enhance the effectiveness of State strategies by ensuring that the city is developed in ways that minimize emissions. In order to reach the long-term reduction targets, the City would also need to implement local reduction measures. These measures encourage Vehicle Miles Travel (VMT) reductions through mixed use and infill development, transportation demand management, development and penetration of electric vehicles (EVs), energy efficiency enhancement, water conservation, and B3 Attach #1 of 3

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Analysis of GHG emissions and potential climate change impacts for new development is required under CEQA. The GHG Plan Update provides strategies and guidelines for the reduction of GHG emissions in accordance with CEQA Guidelines Section 15183.5. A GHG Reduction Plan Consistency Checklist (Checklist) is presented to provide a streamlined review process for proposed new development projects that are subject to discretionary review and trigger environmental review pursuant to CEQA.

Finally, the GHG Plan Update in itself is not enough to meet the reduction goals without a commitment to implementation and recurring monitoring. The GHG Plan Update identifies the process for implementing and monitoring the GHG reduction strategies. Through successful implementation of this GHG Plan Update, the City will demonstrate the potential economic, social, and environmental benefits of reducing GHG emissions and providing environmental stewardship within the community.

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TABLE OF CONTENTS
EXECUTIVE SUMMARY............................................................................................................................. i TABLE OF CONTENTS .............................................................................................................................. v FIGURES AND TABLES ........................................................................................................................... viii LIST OF ABBREVIATIONS AND ACRONYMS.............................................................................................ix

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

1.1 PURPOSE ........................................................................................................................... 1-1

1.2 RELATIONSHIP TO THE GENERAL PLAN............................................................................. 1-2

1.3 ORGANIZATION AND PLAN CONTENT............................................................................... 1-2

1.4 BUILDING ON PRIOR ACTIONS .......................................................................................... 1-3

1.4.1 Fresno Green 2007 Sustainability Strategy......................................................................... 1-3

1.4.2 Zero Waste Strategic Action Plan ....................................................................................... 1-3

1.4.3 City of Fresno Urban Water Management Plan ................................................................. 1-4

1.4.4 Water Efficient Landscape Standards................................................................................. 1-4

1.4.5 Sustainable Groundwater Management Act...................................................................... 1-4

1.4.6 Recharge Fresno ................................................................................................................. 1-4

1.4.7 General Plan Air Quality Update 2009................................................................................ 1-5

1.4.8 Fresno General Plan............................................................................................................ 1-5

1.5 CEQA TIERING AND STREAMLINING ANALYSIS OF GREENHOUSE GAS EMISSIONS.......... 1-5

1.6 HOW DOES THE PLAN REDUCE GREENHOUSE GAS EMISSIONS? ..................................... 1-6

1.7 RELATIONSHIP TO STATE AND FEDERAL ACTIONS TO REDUCE GREENHOUSE GAS EMISSIONS......................................................................................................................... 1-7

1.8 COMMUNITY REDUCTION TARGETS ................................................................................. 1-7

1.8.1 2020 Reduction Target ....................................................................................................... 1-7

1.8.2 Targets After 2020.............................................................................................................. 1-8

1.9 CHALLENGES AND OPPORTUNITIES .................................................................................. 1-8

2.0 BACKGROUND INFORMATION.......................................................................... 2-1

2.1 CITY OF FRESNO BACKGROUND........................................................................................ 2-1

2.1.1 Location and Constraints to Growth................................................................................... 2-1

2.1.2 Transportation Facilities..................................................................................................... 2-1

2.1.3 General Plan Footprint and Buildout Statistics................................................................... 2-2

2.2 CLIMATE CHANGE BACKGROUND..................................................................................... 2-3

2.2.1 Global Warming Potential .................................................................................................. 2-3

2.2.2 Global Climate Change Trends............................................................................................ 2-4

2.2.3 Greenhouse Gas Emission Inventories............................................................................... 2-5

2.3 EFFECTS OF CLIMATE CHANGE ON FRESNO...................................................................... 2-6

2.3.1 Wildfire ............................................................................................................................... 2-7

2.3.2 Water.................................................................................................................................. 2-7

2.4 FEDERAL, STATE, AND REGIONAL ACTIONS TO ADDRESS CLIMATE CHANGE................... 2-9

2.4.1 United States Environmental Protection Agency ............................................................... 2-9

2.4.2 State of California ............................................................................................................. 2-10

2.4.3 Fresno County Council of Governments........................................................................... 2-12

2.4.4 San Joaquin Valley Air Pollution Control District.............................................................. 2-15 B3 Attach #1 of 3

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3.0 EMISSION INVENTORY...................................................................................... 3-1

3.1 INVENTORY METHODS AND ASSUMPTIONS .................................................................... 3-1

3.1.1 Inventory Protocols ........................................................................................................... 3-1

3.1.2 Baseline Inventory Source Categories............................................................................... 3-1

3.2 BASELINE INVENTORY SELECTION CRITERIA..................................................................... 3-2

3.3 BASELINE INVENTORY....................................................................................................... 3-2

3.4 BASELINE INVENTORY UPDATE......................................................................................... 3-2

3.5 INVENTORY PROJECTIONS ................................................................................................ 3-4

3.5.1 BAU Inventory.................................................................................................................... 3-4

4.0 REDUCTIONS FROM STATE REGULATIONS......................................................... 4-1

4.1 MOTOR VEHICLES ............................................................................................................. 4-1

4.2 ENERGY ............................................................................................................................. 4-2

4.2.1 Renewable Portfolio Standard (RPS) ................................................................................. 4-2

4.2.2 Title 24, Part 6 Building Energy Efficiency Standards ........................................................ 4-2

4.2.3 California's Green Building Standard Code........................................................................ 4-2

4.3 REFRIGERANTS.................................................................................................................. 4-3

4.4 REDUCTIONS FROM STATE REGULATIONS ....................................................................... 4-3

4.4.1 Adjusted Business-as-Usual ............................................................................................... 4-3

4.4.2 Target Analysis................................................................................................................... 4-4

5.0 GREENHOUSE GAS REDUCTION STRATEGY........................................................ 5-1

5.1 GHG PLAN REDUCTION STRATEGY ................................................................................... 5-1

5.1.1 Land Use Strategies ........................................................................................................... 5-2

5.1.2 Transportation Facilities Strategies ................................................................................... 5-8

5.1.3 Transportation Demand Strategies.................................................................................. 5-12

5.1.4 Energy Conservation Strategies for New and Existing Buildings ..................................... 5-14

5.1.5 Water Conservation Strategies........................................................................................ 5-17

5.1.6 Waste Diversion and Recycling and Energy Recovery ..................................................... 5-19

5.1.7 Municipal Strategies........................................................................................................ 5-22

5.1.8 Strategies for Existing Development................................................................................ 5-24

5.2 REDUCTION POTENTIAL FROM LOCAL MEASURES......................................................... 5-26

5.2.1 Mobile Source Reductions............................................................................................... 5-26

5.2.2 Energy Efficiency Reductions........................................................................................... 5-28

5.2.3 Water Conservation......................................................................................................... 5-28

5.2.4 Waste Diversion and Recycling Reductions..................................................................... 5-30

5.2.5 Summary of Reductions from Local Measures................................................................ 5-30

6.0 DEVELOPMENT PROJECT REQUIREMENTS......................................................... 6-1

6.1 PROJECTS EXEMPT FROM CEQA....................................................................................... 6-1

6.1.1 City Development Code ..................................................................................................... 6-1

6.1.2 State Regulations............................................................................................................... 6-1

6.2 PROJECTS REQUIRING A DISCRETIONARY APPROVAL ...................................................... 6-1

6.2.1 New Discretionary Development Approval Process to Determine Consistency with GHG Reduction Plan Update...................................................................................... 6-1

6.2.2 New Discretionary Development requiring a General Plan Amendment.......................... 6-2 B3 Attach #1 of 3
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7.0 GHG PLAN UPDATE IMPLEMENTATION MONITORING ...................................... 7-1

7.1 GHG PLAN UPDATE IMPLEMENTATION............................................................................ 7-1

7.1.1 Administration and Staffing................................................................................................ 7-1

7.1.2 Financing and Budgeting .................................................................................................... 7-2

7.1.3 Timelines for GHG reduction strategies Implementation .................................................. 7-2

7.2 MONITORING THE GHG PLAN UPDATE............................................................................. 7-3

7.3 GHG PLAN UPDATE TRACKING TOOL ................................................................................ 7-3

8.0 REFERENCES..................................................................................................... 8-1

APPENDICES
A: GENERAL PLAN POLICY LIST
B: GHG REDUCTION PLAN UPDATE: PROJECT CONSISTENCY CHECKLIST C: GHG REDUCTION MEASURE FUNDING SOURCES
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FIGURES AND TABLES

FIGURES
Figure 2-1: Global Atmospheric Concentration of CO2 ....................................................................... 2-4 Figure 2-2: Carbon Dioxide Concentrations 1960 to 2019 ................................................................. 2-5 Figure 2-3: Increases in Global Carbon Dioxide Emissions from Fossil Fuels 1900 to 2014 ............... 2-6 Figure 2-4: Fresno County Blueprint Preferred Scenario.................................................................. 2-14 Figure 3-1: City of Fresno 2016 Inventory Update and Business-as-Usual Projections...................... 3-4 Figure 4-1: City of Fresno GHG Emissions Inventory, Forecast, and Targets...................................... 4-5 Figure 5-1: City of Fresno Growth Areas and Proposed BRT Corridors.............................................. 5-5 TABLES
Table 2-A: General Plan Statistics....................................................................................................... 2-2 Table 2-B: General Plan Buildout Statistics......................................................................................... 2-3 Table 2-C: Global Warming Potentials................................................................................................ 2-4 Table 2-D: United States, California, and World GHG Emission Inventory (CO2e) ............................. 2-6 Table 3-A: GHG Emissions by Sector for 2010 .................................................................................... 3-2 Table 3-B: Source Categories Comparison Between 2010 and 2016 Inventories ............................. 3-3 Table 3-C: City of Fresno 2016 Inventory Update and Business-as-Usual Projections....................... 3-3 Table 4-A: Reductions from Statewide Measures .............................................................................. 4-3 Table 4-B: City of Fresno Adjusted Business-as-Usual Emissions....................................................... 4-4 Table 4-C: State-Aligned GHG Emission Reduction Targets By Year................................................... 4-4 Table 5-A: General Plan Chapter Cross Reference.............................................................................. 5-1 Table 5-B: Strategies for Existing Development ............................................................................... 5-25 Table 5-C: Emissions Reductions from Local Measures.................................................................... 5-31 Table 5-D: GHG Emissions and Targets Comparison ........................................................................ 5-31 B3 Attach #1 of 3
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LIST OF ABBREVIATIONS AND ACRONYMS
AB Assembly Bill
ABAU adjusted business-as-usual
APS Alternative Planning Strategy
BAU business-as-usual
BMP best management practices
BRT Bus Rapid Transit
CALGreen California’s Green Building Standard Code
CAPCOA California Air Pollution Control Officers Association CAFE Corporate Average Fuel Economy
CARB California Air Resources Board
CBSC California Building Standards Commission
CCAP Climate Change Action Plan
CCR California Code of Regulations
CEC California Energy Commission
CEQA California Environmental Quality Act
CERP Community Emission Reduction Plan
CH4 methane
Checklist GHG Reduction Plan Consistency Checklist
City City of Fresno
CNG compressed natural gas
CNRA California Natural Resources Agency
CO2 carbon dioxide
CO2e carbon dioxide equivalent
COG Council of Governments
CPUC California Public Utilities Commission
DWR Department of Water Resources
EIR Environmental Impact Report
EPA United States Environmental Protection Agency
EVs electric vehicles
FAX Fresno Area Express
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FEMA Federal Emergency Management Agency
GHG greenhouse gas
GHG Plan Greenhouse Gas Reduction Plan
GHG Plan Greenhouse Gas Reduction Plan Update
Update
GHGRx Greenhouse Gas Reduction Exchange
GSP Groundwater Sustainability Plan
GVWR gross vehicle weight rating
HFCs hydrofluorocarbons
ICT Innovative Clean Transit
IPCC Intergovernmental Panel on Climate Change
LCFS Low Carbon Fuel Standard
LEV Low Emission Vehicle (Standards)
LOS level of service
MEIR Master Environmental Impact Report
MMT CO2e million metric tons of carbon dioxide equivalents MMTCO2e Million metric tons of carbon dioxide equivalents MPO Metropolitan Planning Organization
MT CO2e metric tons of carbon dioxide equivalent
MTCO2e Metric tons of carbon dioxide equivalents: a measure of greenhouse gas emissions N2O nitric oxide
ODS ozone depleting substances
OPR Office of Planning and Research
PEIR Program EIR
PG&E Pacific Gas and Electric
PV photovoltaic
RPS Renewable Portfolio Standard
RTP Regional Transportation Plan
RWRF Regional Wastewater Reclamation Facility
SAFE Safer Affordable Fuel-Efficient
SB Senate Bill
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SCS Sustainable Community Strategy
SGMA Sustainable Groundwater Management Act
SJVAPCD San Joaquin Valley Air Pollution Control District SR-168 State Route 168
SR-180 State Route 180
SR-41 State Route 41
SR-99 State Route 99
TDM Transportation Demand Management
UWMP 2010 Urban Water Management Plan
VMT vehicle miles traveled
VOC volatile organic compound
ZEB zero-emission bus
ZEV Zero-Emission Vehicles
ZNE zero net energy
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1.0 INTRODUCTION

1.1 PURPOSE
The City of Fresno (City) prepared its first Greenhouse Gas Reduction Plan (GHG Plan) in 2014 as a part of its General Plan and Master Environmental Impact Report (MEIR), which provided a clear mandate for actions on reducing GHG emissions with GHG specific policies and an implementation measure for the City to prepare a GHG Plan. The GHG Plan set a target to reduce GHG emissions by

21.7 percent below 2020 business-as-usual (BAU) levels of emissions by 2020 and included a suite of reduction measures designed to achieve the reduction target. In addition, the GHG Plan also suggested a monitoring program designed to monitor progress by annually documenting the 19 key indicators and citywide vehicle miles traveled (VMT) every 3 years. The GHG Plan discussed “interim” targets for years 2035 and 2050, pursuant to Executive Order S-03-053 and the Fresno Green Sustainability Strategy4
. The GHG Plan included projections to show the amount of emission reductions needed to achieve State-aligned targets, but the GHG Plan did not include comprehensive strategies to meet the targets beyond 2020, because of the pending adoption of Statewide regulations for later years. The GHG Plan was considered a “Qualified Plan,” using the criteria found in California Environmental Quality Act (CEQA) Guidelines §15183.5.

Since the adoption of the GHG Plan in December 2014, several events within the California legislature and a decision of the California Supreme Court that affects the GHG Plan have occurred.

These events include the California Supreme Court’s published decision on the Newhall Ranch Specific Plan, Governor Brown signing into law Senate Bill (SB) 32, and the California adoption of the 2017 Climate Change Scoping Plan.

On November 30, 2015, the California Supreme Court published its decision on the Newhall Ranch Specific Plan invalidating the Environmental Impact Report (EIR) for a variety of reasons, including the use of 29 percent below BAU as a threshold level of significance for GHG emissions. In this case, the Court found that the EIR did not contain any evidence supporting the threshold. On September 28, 2016, Governor Brown signed SB 32 into law. SB 32 sets a Statewide goal of reducing GHG emissions 40 percent below 1990 levels by 2030. The California Air Resources Board (CARB) was directed to develop a climate change scoping plan update that would provide the regulations and policies to achieve the 2030 reduction target. On December 14, 2017, the CARB finalized “California’s 2017 Climate Change Scoping Plan,” providing quantitative summaries of the regulations needed to achieve the 2030 reduction target.

This GHG Reduction Plan Update (GHG Plan Update) re-evaluates the City’s existing GHG reduction targets and strategies, provides new goals and supporting measures to reflect and ensure compliance with changes in local and State policies, and strives to encourage economic growth to 3 Executive Order S-3-05 laid out GHG reduction targets for State of California: by 2010 reduce GHG emissions to 2000 levels, by 2020 reduce GHG emissions to 1990 levels and by 2050 reduce emissions to 80 percent below 1990 levels. 4 The Fresno Green Sustainability Strategy included a commitment to meet the 2020 AB 32 goal and to meet a reduction target of 80 percent below 1990 levels by 2050.

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1.2 RELATIONSHIP TO THE GENERAL PLAN
The City of Fresno General Plan and the MEIR were adopted in 2014. The General Plan provides a clear mandate for action on GHG emissions with GHG policies and an implementation measure for the City to prepare a Climate Action Plan as part of the General Plan and MEIR. The City developed the GHG Plan, which was concurrently approved with the General Plan and included as an appendix to the MEIR. The intent of the GHG Plan was to achieve compliance with State mandates by focusing on feasible actions the City can take to minimize the adverse impacts of growth and development on climate change and air quality. Since the General Plan was adopted and the MEIR was certified in 2014, some new local, State, and/or federal regulations have been enacted. In order to bring the General Plan into technical conformance with current local and State law, the City is also updating and converting the existing General Plan MEIR to a Program EIR (PEIR) with the goal of extending the life of the Fresno General Plan and the accompanying environmental document by up to 10 years.

This update is intended to streamline implementation of the General Plan’s programs and policies by supporting them with updated environmental analysis, a current regulatory framework, and mitigation measures, pursuant to CEQA. As part of the General Plan MEIR Update, the City’s existing GHG Plan is also being updated to comply with current State regulations including SB 32, which has a Statewide goal of reducing emissions 40 percent below 1990 levels by 2030. This GHG Plan Update also reflects the changes in local policies to ensure these changes are accounted for and included in the City’s GHG reduction measures and strategy.

1.3 ORGANIZATION AND PLAN CONTENT
The GHG Plan Update includes the following sections:
• A Background section that describes the environmental and regulatory setting for GHGs; • An Emission Inventory and Forecasts section that accounts for the sources of emissions and forecasts to year 2020, 2030, and 2035;
• A Statewide Reduction Strategy section that summarizes the reductions from State regulations as outlined in the 2017 Climate Change Scoping Plan, and the reduced 2020, 2030, and 2035 emission forecasts that take into account State and local GHG reduction strategies; • A Local Reduction Strategy section that includes the updates and refinements to the GHG reduction strategies from the 2014 GHG Plan, and new measures to meet the 2020, 2030, and 2035 reduction targets;
• A Development Project Requirements section that outlines the development review process used to ensure that future proposed development projects are consistent with the GHG Plan Update. A GHG Reduction Plan Update Consistency checklist to determine future project consistency with GHG Reduction Plan Update; and
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1.4 BUILDING ON PRIOR ACTIONS

1.4.1 Fresno Green 2007 Sustainability Strategy
The City of Fresno has taken several important steps to improve the City’s sustainability and reduce impacts that include GHG emissions. The Sustainability Strategy includes five Green Visions:
• New City Beautiful: Fresno will be nationally recognized for the innovative integration of buildings within their neighborhood context; good urban design; and giving priority to public health, open spaces, public art, historic preservation, urban forests, and the protection of natural habitats.
• Sierra View 2025: The Sierra Nevada mountain range will be clearly visible to all Valley residents by 2025. Public health will be improved by having cleaner air, enhanced public transportation, and additional opportunities for walking and cycling.
• Solar Valley: Fresno will become a leader in renewable energy use by maximizing new renewable sources as well as increasing the efficiency of its existing uses. Fresno will lead the State in the creation of related innovative technology and new business enterprises. With its abundant sunshine and population growth, the opportunity exists to improve air quality, reduce dependence on foreign energy, and provide attractive new jobs by harnessing solar and other types of renewable energy.
• Green Enterprises and Economic Development: The City of Fresno will become a center for innovative business enterprises that focus on the “triple bottom line” of providing environmental, economic, and social benefits.
• City as Good Steward: The City of Fresno will lead by example by greening up its facilities and practices, embracing a zero waste initiative, providing appropriate staff resources, and collaborating with other municipalities and agencies to develop regionally based Green programs.

1.4.2 Zero Waste Strategic Action Plan
The City of Fresno Zero Waste Strategic Action Plan, approved February 11, 2008, aims to achieve 75 percent diversion by 2012 and zero waste status by 2025. 5 Zero Waste is a philosophy and a design
principle for the 21st Century that includes recycling but goes beyond recycling by taking a “whole system” approach to the vast flow of resources throughout society. It is a goal and guide for people to emulate sustainable natural cycles, where all discarded materials are resources for others to use. 5 Fresno, City of. 2008. City of Fresno – Zero Waste Strategic Action Plan. Available online at: swalco.org/ DocumentCenter/View/955/Zero-Waste-and-Sustainability---Fresno-CA---Zero-Waste-PDF?bidId= (accessed October 23, 2019).

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1.4.3 City of Fresno Urban Water Management Plan
The Water Conservation Act of 2009 (SBX7‐7) was enacted in November 2009. SBX7‐7 requires urban retail water suppliers, such as the City of Fresno, to develop per capita water use targets to be met by 2015 and 2020. The overall statewide objective of SBX7‐7 is to reduce per capita water use by 20 percent by the year 2020. The 2010 Urban Water Management Plan (UWMP) was adopted by the Fresno City Council on November 29, 2012 to meet this requirement. The UWMP contains water conservation best management practices (BMP) to achieve the required reductions in water use.

The 2010 UWMP was updated in 20156 and describes the City’s water demands and supplies, reliability and water conservation strategies. The 2015 UWMP includes data covering the years from 2011 to 2015 and was adopted by the City Council on June 23, 2016.

1.4.4 Water Efficient Landscape Standards
The City has adopted water conserving landscape requirements that are specified in the City Municipal Code (Section 6‐522. Water Efficient Landscape Standards). These requirements define standards and procedures for the design, installation, and management of landscapes in order to utilize available plant, water, land, and human resources to the greatest benefit of the people of the city.

1.4.5 Sustainable Groundwater Management Act
In September 2014, Governor Brown signed legislation requiring that California’s critical groundwater resources be sustainably managed by local agencies. The Sustainable Groundwater Management Act (SGMA) provides a framework for the sustainable management of groundwater supplies by local agencies, with a role for State intervention when necessary to protect the resource.

The SGMA requires that Groundwater Sustainability Plans (GSPs) be developed for medium- and high-priority groundwater basins identified within the Department of Water Resources (DWR) Bulletin 118 report. Fresno county overlies five groundwater subbasins; Kings, Madera, DeltaMendota, Westside, and Pleasant Valley. With the exception of Pleasant Valley, the four other basins are currently designated by DWR as high priority and subject to a condition of critical overdraft. The SGMA does not apply outside of mapped groundwater basins. The SGMA defines a process and timeline for local agencies to achieve the goal of sustainable management of groundwater basins. It also provides tools and authorities to take the necessary steps to achieve that goal. For local agencies involved in implementation, the requirements are significant and can be expected to take years to accomplish. As a first step, in March 2015, the Fresno County Board of Supervisors formed a workgroup to advise the Board of Supervisors regarding items relating to the SGMA.

1.4.6 Recharge Fresno
Recharge Fresno is the City’s program to improve the pipelines and water system facilities that will capture, treat, and deliver water to Fresno homes and businesses, including surface water from the Sierra Nevada Mountains. This program has the following objectives: ensure a reliable and sustainable water supply for Fresno’s present and future prosperity by increasing the available 6 Fresno, City of. 2016. 2015 Urban Water Management Plan. Available online at: www.fresno.gov/ publicutilities/wp-content/uploads/sites/16/2016/11/CityofFresno2015UWMP_adopted.pdf (accessed October 23, 2019).

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1.4.7 General Plan Air Quality Update 2009
The Air Quality Update satisfied the requirements of AB 170 that mandated cities and counties of the San Joaquin Valley to address air quality in their General Plans. Many of the goals, policies, and implementation measures that reduce air pollutant emissions also reduce GHGs. In addition, the Air Quality Update included GHG specific policies that are carried forward into the General Plan and formed the basis of the strategy defined in the existing GHG Plan. The GHG Plan Update is built upon the strategies identified in the existing GHG Plan.

1.4.8 Fresno General Plan
The Fresno General Plan was adopted in 2014 and includes the Resource Conservation Element that has objective RC-5, which requires the City to take the necessary and cost-effective actions to achieve and maintain reductions in GHG emissions. The General Plan specifies implementing policies (RC-5-a to RC-5-g) to achieve this objective. The policy RC-5-a requires the City to “Support State Goal to Reduce Statewide GHG Emissions” and RC-5-b requires developing a “GHG Plan” that should be periodically updated to reflect the State GHG regulations. Policy RC‐5‐b provides the following outlines to achieve objective RC-5:
• A baseline inventory of all known or reasonably discoverable sources of greenhouse gases (GHGs) that currently exist in the city and sources that existed in 1990 (Updated to 2010). • A projected inventory of the GHGs that can reasonably be expected to be emitted in the city in the year 2035 in accordance with discretionary land use decisions pursuant to 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 whose purpose shall be to meet the established local reduction 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.

1.5 CEQA TIERING AND STREAMLINING ANALYSIS OF GREENHOUSE GAS EMISSIONS New development that would occur with the buildout of the General Plan must address GHG impacts to comply with CEQA. The California legislature has adopted tiering and streamlining provisions in SB 97 that encourage cities to adopt GHG reduction plans as a mechanism to assist with project CEQA B3 Attach #1 of 3

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meet the following criteria in order to use CEQA tiering and streamlining provisions:

A. Quantify GHG emissions, both existing and projected over a specified time period, resulting from activities within a defined geographic area;
B. Establish a level, based on substantial evidence, below which the contribution to GHG emissions from activities covered by the plan would not be cumulatively considerable; C. Identify and analyze the GHG emissions resulting from specific actions or categories of actions anticipated within the geographic area;
D. Specify measures or a group of measures, including performance standards, that substantial evidence demonstrates, if implemented on a project‐by‐project basis, would collectively achieve the specified emissions level;
E. Establish a mechanism to monitor the plan's progress toward achieving the level and to require amendment if the plan is not achieving specified levels; F. Be adopted in a public process following environmental review.

This GHG Plan Update is structured to meet the streamlining criteria listed above. Project compliance with the applicable General Plan policies and strategies identified in the Checklist would result in less-than-significant impacts related to GHG emissions.

1.6 HOW DOES THE PLAN REDUCE GREENHOUSE GAS EMISSIONS?
The largest source of GHGs is the combustion of carbon containing fuels resulting in carbon dioxide (CO2). Although there are many other GHGs, the GHG Plan Update emphasizes actions under the City’s control or influence that can reduce CO2 emissions. Other GHGs such as methane (CH4), nitric oxide (N2O) and refrigerants such as hydrofluorocarbons (HFCs) are addressed in the plan, but have fewer sources and fewer control opportunities at the City level.

Strategies to reduce Citywide GHG emissions include:
• Improve the efficiency of the vehicles so they can achieve the same amount of work using less fuel (e.g., improve aerodynamics in cars and trucks/low friction oils). • Move to low carbon power generation with zero or low GHG facilities such as solar, wind, biofuels.
• Improve the efficiency of the combustion process in the City-owned facilities to obtain more energy from the fuel being burned (e.g., high-efficiency burners, better fuels). 7 CEQA Guidelines 15183.5 describes requirements of a GHG Reduction Plan that would mitigate cumulative levels of GHG emissions within a jurisdiction to a less-than-significant level and allows development project tiering from the GHG Reduction Plan.

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The GHG Plan Update provides a comprehensive approach utilizing different GHG reduction strategies to achieve emission reductions sufficient to demonstrate consistency with State of California targets. The GHG Plan Update builds on the General Plan policies and implementation measures. Where needed, the GHG Plan Update provides more details to clarify and focus action and to streamline implementation.

1.7 RELATIONSHIP TO STATE AND FEDERAL ACTIONS TO REDUCE GREENHOUSE GAS

EMISSIONS
Efforts by cities to reduce GHGs are an important part of larger effort implemented by the State of California and to a lesser degree the federal government. Limited action has taken place on the federal level to reduce GHG emissions, making State of California actions the most important to the City. California has implemented ambitious control strategies to reduce GHG emissions. The State recognizes the magnitude of the challenge of reducing GHGs to the extent needed to prevent catastrophic effects of climate change is such that reductions throughout the state, including those at the local level, are required. Climate change is a global problem that will take unprecedented cooperation and action at international, national, state, and local levels. California has chosen to be a leader in this effort and a model for others to follow.

1.8 COMMUNITY REDUCTION TARGETS
Future development anticipated by the City of Fresno creates challenges and opportunities for reducing GHG emissions sufficiently to ensure that growth will not hinder or obstruct the implementation of State GHG regulations including AB 32 and SB 32. Cities with relatively high rates of growth, such as Fresno will produce a larger share of GHG emissions in the future compared with slow‐growing and built‐out parts of the State. However, new development presents opportunities, with its ability to incorporate the latest technologies into buildings to reduce energy use and its ability to build complete neighborhoods and commercial areas in ways that reduce vehicle travel.

The policy mechanisms such as SB 743 further support environmentally beneficial development by allowing CEQA to facilitate the implementation of transit-oriented infill development.

1.8.1 2020 Reduction Target
AB 32 requires CARB to reduce Statewide GHG emissions to 1990 levels by 2020. As part of this legislation, CARB was required to prepare a “Scoping Plan” that demonstrates how the State will achieve this goal. The Scoping Plan was first adopted in 2011 and in it local governments were described as “essential partners” in meeting the Statewide goal, recommending a GHG reduction level of 15 percent below 2005 to 2008 level, depending on when a full emissions inventory is available, by 2020.

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This is because of greater energy efficiency in new structures and lower motor vehicle travel resulting from the project designs and higher development densities anticipated from General Plan implementation.

1.8.2 Targets After 2020
The CARB released the First Update to the Climate Change Scoping Plan on February 10, 2014 (CARB 2014). The draft update emphasized the need for a mid‐term target between 2020 and 2050 to provide a continuum of action to reduce cumulative emissions. The EO B-30-15 and SB 32 required CARB to reduce Statewide GHG emissions to 40 percent below 1990 levels by 2030. The EO B-30-15 further stated that the emission reduction target of 40 percent below 1990 levels by 2030 is an interim-year goal to make it possible to reach the ultimate goal of reducing emissions 80 percent under 1990 levels by 2050. The order directs CARB to provide a plan with specific regulations to reduce Statewide sources of GHG emissions. The Executive Order does not include a specific guideline for local governments. The 2017 Scoping Plan recommends local plan level GHG emissions reduction goals (CARB 2017).

At the growth rates projected for General Plan buildout, the city could continue to grow through 2050 without designating additional land for development. The General Plan and the GHG Plan Update ensure that the City of Fresno will do its part of reducing GHG emissions for the short‐term (2020) and the long term (2050).

1.9 CHALLENGES AND OPPORTUNITIES
The effects of GHG emissions are cumulative. Global warming is the result of emissions from every source on the globe that combine to increase GHG concentrations in the atmosphere. Scientific evidence supports the need for drastic worldwide reductions to prevent catastrophic climate change. According to the Intergovernmental Panel on Climate Change (IPCC) to limit the global warming to 1.5 degree Celsius above pre-historic levels the world would have to curb its carbon emissions by at least 49 percent of 2017 levels by 2030 and then achieve carbon neutrality by 2050 (Nature 2018). This leads to the following questions:
• What is California’s responsibility for reducing emissions? • What is local government’s responsibility for reducing emissions? • What is an individual development project’s responsibility for reducing emissions? • What is each person’s responsibility for reducing emissions? The government structure in the United States with its checks and balances limits the power of the states to take action to reduce GHGs. For example, states are not allowed to interfere with interstate and international commerce; however, powers that are not vested in the federal government are reserved for the states. Individual rights for people to live how and where they want are also highly prized. This structure creates challenges for reducing GHG emissions that touch every sector of the economy and that are greatly influenced by individual choices and actions. With uneven action among the states and nations, the potential exists for regulations to cause businesses simply to relocate their emissions to nations, states, or cities with weak or no regulations. Fortunately, many B3 Attach #1 of 3
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However, it must be recognized that individuals or organizations implementing the action may not directly benefit from cost savings or may have difficulty with initial capital costs.

A thorough discussion of regulatory authority for GHG emissions is provided in Section 2. In short, the State has broad authority to regulate GHG emission sources. It has authority to regulate GHGs from motor and transit vehicles, power generation, and industrial processes, and sets efficiency standards for buildings, lighting, appliances, water use, and waste management/recycling. On the other hand, local government’s role is mostly a supportive one. Local government is called upon to support state programs and to use its land use authority and police power to reduce GHG impacts.

For example, local government is authorized by the State to adopt ordinances that exceed energy standards for buildings and exceed water conservation and recycling mandates. Through the development review process and CEQA, local government can require or encourage project designs that produce fewer vehicle trips and miles traveled and include mitigation measures with which projects must comply as conditions of approval.

Individual choice plays an important role in reducing GHG emissions. The State can mandate increasing numbers of EVs to be sold in California to meet emission standards, but it cannot force people to buy them. It can mandate energy efficient appliances and buildings but cannot make people turn out the lights and turn down the thermostat to save energy. It cannot prevent people from buying more and bigger televisions. However, the State and the City can provide incentives and disincentives that affect choice to align with the goal of reducing GHG emissions.

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2.0 BACKGROUND INFORMATION
GHG emissions and climate change are complex issues that are the topics of hundreds of books, research papers, and policy documents. This section of the GHG Plan Update provides a brief overview of climate change and the local factors that affect the GHG emission inventory. The following information provides a discussion in a city of Fresno context.

2.1 CITY OF FRESNO BACKGROUND
The GHG Plan Update uses population, employment, and housing statistics as the basis for estimating current and future year emissions and reduction targets.

2.1.1 Location and Constraints to Growth
The city of Fresno is located in Fresno county, which is generally located in the center of the San Joaquin Valley, the most productive agricultural region in the nation and the world. Fresno’s central location in California between San Francisco (184 miles) to the north and Los Angeles (222 miles) to the southwest has made it an important regional center.

There are no significant physical barriers to Fresno’s future growth; however, political boundaries and policy considerations are very important in shaping future growth. The San Joaquin River and the Fresno/Madera County line run along the northern edge of the city. The city of Clovis abuts Fresno to the northeast and east, preventing growth in that direction. The land southeast, south and west are mostly prime farmland. The southeast area is a long‐term growth area in the General Plan.

No expansion of the sphere of influence is planned in the General Plan.

2.1.2 Transportation Facilities
The city of Fresno is crossed by two important State highways used for regional travel and commerce. State Route 99 (SR‐99) runs northwest/southeast through the city, connecting Fresno to northern and southern California. State Route 41 (SR‐41) connects Fresno to the Central Coast and is a main route to Yosemite National Park. SR‐41 also acts as a primary commuter facility between northern and southern parts of Fresno. State Route 168 (SR‐168) runs north/east to Clovis acting as a commute facility and beyond to the Sierra Nevada. SR‐168 intersects with State Route 180 (SR‐180), which runs east/west through the city, connecting Fresno with the communities of western Fresno county and with Kings Canyon and Sequoia National Parks.

Fresno is on the California High Speed Rail route and a station is planned for downtown Fresno. High Speed Rail is anticipated to be a major catalyst for development and redevelopment in Fresno, although the General Plan is not reliant on it to achieve its stated infill, development, and redevelopment goals. Fresno currently receives rail service from Amtrak. The City of Fresno’s Transportation Department, via Fresno Area Express (FAX), provides bus transit service. FAX offers B3 Attach #1 of 3

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2.1.3 General Plan Footprint and Buildout Statistics
The city of Fresno has a substantial development footprint. The General Plan Planning Area is 166 square miles (106,027 acres), which includes the 162 square miles (103,570 acres) sphere of influence, and the 4 square miles (2,486 acres) North Area, located at the northern tip of the city.

The sphere of influence consists of both the incorporated 113 square mile city (72,224 acres) and the 49 square mile unincorporated county (33,803 acres) land. Some of the unincorporated land is completely surrounded by the city of Fresno and is referred to as a “county island,” whereas other unincorporated land lies adjacent to the outer fringe of the city.

The sphere of influence is a boundary that encompasses lands that are expected to ultimately be annexed into the city. Until annexed, the lands are unincorporated and fall under the jurisdiction of the County of Fresno.

In accordance with the requirements of the State of California, the Local Agency Formation Commission (LAFCO) authorizes a “sphere of influence” around municipalities as the probable physical boundary and ultimate service area of that government.

Table 2-A shows the acreage within the General Plan Planning Area when the General Plan was approved.

Table 2-A: General Plan Statistics
Land Use Designations General Plan Acreage
Residential 46,043
Commercial 6,913
Industrial 9,578
Mixed use 4,223
Public facilities 17,671
Open space 3,001
Other 18,598
TOTAL 106,027
Projected Population at Build-out 970,000
Source: City of Fresno Planning and Development Department (2019) Table 2-B provides additional detail in terms of land use type for existing development and development anticipated with the continued implementation of the General Plan. The General Plan envisions an increase in the amount of multi‐family residential compared with single‐family residential development. The City assumes buildout of the General Plan Planning Area would occur after 2056.
8 Fresno, City of, 2019. Department of Transportation, Fresno Area Express Routes. Website:
www.fresno.gov/transportation/fax/routes (accessed October 23, 2019).

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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 2-3 Table 2-B: General Plan Buildout Statistics
Land Use Existing Development General Plan
Implementation Incremental Increase
MSF Acres MSF Acres MSF Acres
Single‐Family Residential 109,000 26,147 169,626 38,961 60,626 12,814 Multiple‐Family Residential 62,288 3,496 146,826 6,605 84,538 3,109 Commercial/Office/Public Facility 66.4 14,804 129.7 26,517 63.3 11,712 Mixed Use 0.1 10 20.9 4,213 20.8 4,223
Industrial 72.8 6,765 113.3 9,578 40.5 2,813
Open Space — 12,288 — 1,546 — ‐10,742
Agriculture — 11,714 — 736 — ‐10,978
Vacant — 12,522 — 0 — ‐12,522
Other — 18,281 — 17,861 — ‐420
Total — 106,027 — 106,027 — 0
Population (persons) 545,000 970,000 425,000
Source: City of Fresno Development and Resource Management Department (2012). msf = million square feet
The growth statistics reveal two important points. First, substantial growth is projected for Fresno over the coming decades and that growth will increase GHG emissions. Second, the proposed mix of land uses that would accommodate the growth in population will increase development density.

Increased density when combined with a strong pedestrian and transit orientation can reduce motor vehicle travel and related GHG emissions.

2.2 CLIMATE CHANGE BACKGROUND
Climate scientists refer to gases that trap heat in the atmosphere as greenhouse gases. The effect is analogous to the way a greenhouse retains heat. The energy influx is maintained by three main factors: the amount of energy coming in, which depends on the earth’s distance from the sun and solar activity; the albedo (the ability of the earth’s surface to reflect light); and the chemical composition of the atmosphere. The presence of GHGs in the atmosphere regulates the earth’s temperature.

The chemical composition of the atmosphere changes over time. Natural processes and human activities emit GHGs. As shown in Figure 2-1, carbon dioxide concentrations in the atmosphere have increased over time. The global atmospheric concentration of carbon dioxide (CO2) data in Figure 2-1 prior to 1958 is from ice core measurements and post‐1958 data are from the Mauna Loa, Hawaii site (NOAA 2019).

2.2.1 Global Warming Potential
GHGs have varying global warming potential and atmospheric lifetimes. Carbon dioxide, the reference gas for global warming potential, has a global warming potential of 1. The calculation of the carbon dioxide equivalent (CO2e) is a consistent methodology for comparing emissions, since it normalizes various emissions to a consistent metric. Methane’s warming potential of 21 indicates that methane has a 21 times greater warming effect than carbon dioxide on a molecule per B3 Attach #1 of 3

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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 2-4 Figure 2-1: Global Atmospheric Concentration of CO2
molecule basis. A carbon dioxide equivalent is the mass emissions of an individual GHG multiplied by its global warming potential. Emissions are typically shown in MT CO2e or a million times that, million metric tons of carbon dioxide equivalents (MMT CO2e). Global warming potentials are shown in Table 2-C.

Table 2-C: Global Warming Potentials
Greenhouse Gas Global Warming Potential
Carbon dioxide (CO2) 1
Methane (CH4) 21
Nitrous oxide (N2O) 310
Source: Intergovernmental Panel on Climate Change (2007).

2.2.2 Global Climate Change Trends
Figure 2-2 provides a more detailed look of concentrations since 1960 showing continuing steady increases even with international actions that have been taken to date. The National Oceanic and Atmospheric Administration reported that the global average CO2 concentration was 410 parts per million (ppm) in 2019 (NOAA 2019).

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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 2-5 Figure 2-2: Carbon Dioxide Concentrations 1960 to 2019
Source: NOAA 2019: Trends in Atmospheric Carbon Dioxide. Full Mauna Loa CO2 Record.

2.2.3 Greenhouse Gas Emission Inventories
Emission inventories are databases that list by source and pollutant the amount of air pollutants discharged into the atmosphere during a given period of time. Inventories can range from individual businesses, cities, counties, states, nations, to global in scope. Emission inventories are used to help determine significant sources of air pollutants, establish emission trends over time, and target regulatory actions.

Emissions of GHGs are a true cumulative impact. Emissions anywhere and everywhere in the world contribute to increased concentrations of GHGs in the atmosphere and the potential for climate change. Viewing the emissions output at global, national, state, and local levels is important to understanding the scale of the problem and the relative contribution of each level of government organization.

Global carbon emissions from fossil fuels have increased rapidly since 1900 and continue to increase at an even faster pace since the year 2000 (EPA 2018). Figure 2-3 shows this trend with particularly dramatic increases after World War II and more recently with rapid increases in China and other rapidly industrializing nations in the last decade. Emissions have increased over 600 percent since 1950. The increases in emissions are consistent with the atmospheric concentrations shown in Figure 2-2 and Figure 2-3.

GHG 2017 inventory for all sources in the United States and California is shown in Table 2-D. The percentage of emissions for the United States is 12.2 percent of the global total yet accounts for only 4.4 percent of the world’s population. This places extra responsibility for the United States to take a leadership role and to act as a model for other nations to follow. Although previous international efforts have not made substantial progress in slowing the growth in GHG emissions, B3 Attach #1 of 3

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Source: EPA (2018).

Table 2-D: United States, California, and World GHG
Emission Inventory (CO2e)
Inventory MMT CO2e Percent of Total
California (2017) 424.1 0.8
United States (2017) 6,457 13.09
World (2016) 49,300 100
Sources: CARB 2019, EPA 2018, and PBL 2017.

CO2e = carbon dioxide equivalent
GHG = greenhouse gas
MMT = million metric tons
the United States has many reasons to change to lower carbon economy. For example, reducing energy imports and increased energy security, cost savings from efficiency, employment in renewable energy.

2.3 EFFECTS OF CLIMATE CHANGE ON FRESNO
Scientific research indicates that an increase in global average temperature of 2 degrees Centigrade (°C) (3.6 degrees Fahrenheit [°F]) above pre‐industrial levels poses risks to natural systems and human health and well‐being. This is only 1.1°C (2.0°F) above present levels. In order to avoid temperatures above those levels, studies indicate that a concentration at or below 450 ppm CO2e must be achieved. Other studies indicate a stable concentration of about 400 ppm CO2e will be needed to prevent the 2.0°C (3.6°F) increase. As shown in Figure 2-2 above, readings at the Mauna Loa monitoring station have already exceeded 410 ppm CO2e and the international average is likely to exceed 400 ppm in a few years. The existing trend is likely to cause substantial harm to future generations and nature (CARB 2014).

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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 2-7 Despite efforts to reduce GHG emissions, these gases can remain in the atmosphere for hundreds of years and emissions are expected to continue to increase globally for some time. Therefore, it is probable that climate change impacts will be observed. The impacts are predicted to vary by region.

In California, climate change may result in a decreased water supply, sea level rise, and increased wildfires, to name a few. In order to manage these impacts, the city’s vulnerability to these impacts is assessed and strategies have been developed to adapt to the projected changes.

Determining potential future impacts from climate change is an evolving process. The 2009 California Climate Adaptation Strategy provides a proactive foundation for an ongoing adaptation process within California for the sectors with the greatest risks. The document provides strategies for state and local governments to adapt to climate change (CNRA 2009). By incorporating applicable strategies as Implementation Strategies, the City is taking a proactive approach to ensure that impacts to the city are minimized.

The following discussion describes the main risks from climate change that could be experienced in the city of Fresno. The General Plan sections related to safety, public utilities, hydrology, and resource conservation contain policies that would decrease the risks to residents of the city. In general, City programs and policies to respond to existing levels of risk may need to be implemented more frequently or expanded to protect city residents and resources from potential impacts from climate change. Response to more or bigger events can be expected to demand more city resources.

2.3.1 Wildfire
The city of Fresno is surrounded by irrigated agricultural lands, rural residential development, and the city of Clovis that are not subject to wildfire to any great extent. Fallow farmland and vacant land with weedy growth can become a fire hazard if not maintained. The San Joaquin River bluff area along the city’s northern boundary could experience longer dry seasons and greater threats from wildfire.

2.3.2 Water
One of the potential impacts of climate change is a loss of natural snowpack, particularly the Sierra Nevada snowpack. Snowmelt provides an annual average of 15 million acre‐feet of water, released between April and July each year (Department of Water Resources 2008). The California Department of Water Resources projects that the Sierra snowpack will experience at least a 25 percent reduction from its historic average by 2050 (DWR 2014). Climate change is also anticipated to bring warmer storms that result in less snowfall at lower elevations, reducing the total snowpack.

Changes in precipitation patterns are expected to cause increased flooding. For the purposes of federal flood insurance, the Federal Emergency Management Agency (FEMA) has traditionally used the 100‐year flood event, which refers to the level of flood flows that has a 1 percent chance of being exceeded in any single year. As California’s hydrology changes, what is currently considered a 100‐year flood may strike more often, leaving many communities at greater risk. Moreover, as peak flows and precipitation change over time, climate change calls into question assumptions of “stationarity” that are used in flood‐related statistical analyses such as the 100‐year flood. That is, the probable area of inundation does not change from year to year.

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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 2-8 The California Department of Water Resources
(2008) recommends that local governments
implement land use policies that decrease flood
risk. These following recommendations are
included as GHG Plan implementation policies
where applicable and feasible.
• Local land use agencies should update General
Plans to address increased flood risks posed by
climate change. General Plans should consider
an appropriate risk tolerance and planning
horizon for each locality.
• Local governments should site new
development outside of undeveloped
floodplains unless the floodplain has at least a
sustainable, 200‐year level of flood protection.
• Local governments should use low‐impact
development techniques to infiltrate and store
runoff.
• Local governments should include
flood‐resistant design requirements in local
building codes. State, federal, and local
agencies should develop conjunctive use
management plans that integrate floodplain
management, groundwater banking, and surface storage. Such plans could help facilitate system reoperation and provide a framework for the development of local projects that are beneficial across regions.
• Local land use agencies should adopt ordinances that protect the natural functioning of groundwater recharge areas.

As precipitation falls in the form of rain rather than snow with greater storm intensity, high‐ frequency flood events are projected to increase. There is currently no known literature that suggests an increase in flooding from climate change in the Fresno area; however, it is possible that there could be changing weather patterns that would result in heavy downpours of rain in the area, which could cause street flooding. In addition, the potential for increased wildfires in foothill and mountain areas upstream from Fresno resulting from climate change could increase floods following fire if reservoirs had insufficient capacity to capture the runoff at that time.

San Joaquin River Bluffs
San Joaquin River
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2.4 FEDERAL, STATE, AND REGIONAL ACTIONS TO ADDRESS CLIMATE CHANGE

2.4.1 United States Environmental Protection Agency
The United States Environmental Protection Agency (EPA) is responsible for implementing federal policy to address global climate change. The federal government’s early efforts have focused on public‐private partnerships to reduce GHG intensity through energy efficiency, renewable energy, methane and other non‐CO2 gases, agricultural practices, and implementation of technologies to achieve GHG reductions.

The EPA is required to regulate carbon dioxide and other GHGs as pollutants under Section 202(a)(1) of the federal Clean Air Act. The first step in implementing its authority was the Mandatory Reporting Rule that required inventory data collection commencing on January 1, 2010 with first reports due March 2011. Effective January 2, 2011, the EPA requires new and existing sources of GHG emissions of 75,000 tons per year to obtain a permit under the New Source Review Prevention of Significant Deterioration and Title V Operating Permit Program.

The main federal regulatory program for automobiles is the Corporate Average Fuel Economy (CAFE) program, which has been in place since 1975. Under previous administrations, CAFE was the primary means of limiting mobile source carbon emissions. Rules finalized in 2012 put in place binding standards through Model Year 2021 and offered estimated standards through 2024. The federal light‐duty vehicle standards were developed in two phases that harmonized with California standards through 2016 (Phase 1) and 2025 (Phase 2) and developed the first ever federal GHG standards for medium‐duty and heavy‐duty vehicles. At the time, the EPA estimated that the new standards in this rule would reduce CO2 emissions by approximately 270 MMT and save 530 million barrels of oil over the life of vehicles sold during the 2014 through 2018 model years.

In 2018, however, the EPA proposed a new, less-stringent set of standards called the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021–2026 Passenger Cars and Light Trucks. The SAFE Vehicles Rule would amend 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. The standards have yet to be finalized.

In June 2013, President Obama approved the nation’s first Climate Action Plan that lays out a series of executive actions to reduce carbon pollution, prepare the nation for the impacts of climate change, and lead international efforts to address global climate change. The Plan reiterated the President’s 2009 pledge to reduce United States GHG emissions by 17 percent below 2005 levels by 2020. Under the President Trump administration, the nation’s stance on climate change has shifted from being a part of global action to policy stagnation and deregulation. In June 2017, the U.S. decided to withdraw from the Paris Climate Agreement, which was an agreement among countries to reduce global GHG emissions resulting from the 2015 United Nations Climate Change Conference.

Currently, the EPA has been engaged in research into approaches to reduce the U.S. contribution to climate change. Areas of climate research include economic analyses of regulatory policy instruments (e.g., emissions trading, estimation of GHG reduction benefits, the role of uncertainty, and modeling the economic impacts of ocean acidification). In the meantime, many U.S. States and B3 Attach #1 of 3

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2.4.2 State of California
California has adopted a variety of regulations aimed at reducing the State’s GHG emissions. While state actions alone cannot stop climate change, the adoption and implementation of this legislation demonstrates California’s leadership in addressing climate change. Key legislation and Executive Orders pertaining to the State’s reduction targets are described below.

2.4.2.1 Executive Order S‐3‐05
California Governor Arnold Schwarzenegger announced on June 1, 2005, through Executive Order S-3‐05, the following reduction targets for GHG emissions:
• By 2010, reduce GHG emissions to 2000 levels.
• By 2020, reduce GHG emissions to 1990 levels.
• By 2050, reduce GHG emissions to 80 percent below 1990 levels.

The State achieved the first goal of reducing emissions to 2000 levels by 2010. Total GHG emissions were reduced by 2.9 percent during that period even though population increased by 10.9 percent in the same period (CARB 2014). The State also appears to be on track for achieving the 2020 target.

2.4.2.2 Executive Order B-30-15
On April 29, 2015, California Governor Jerry Brown announced through EO B-30-15 the following GHG emissions target:
• By 2030, California shall reduce GHG emissions to 40 percent below 1990 levels.

The emissions reduction target of 40 percent below 1990 levels by 2030 is an interim-year goal to make it possible to reach the ultimate goal of reducing emissions 80 percent below 1990 levels by 2050. The order directs CARB to provide a plan with specific regulations to reduce Statewide sources of GHG emissions. EO B-30-15 does not include a specific guideline for local governments.

2.4.2.3 Assembly Bill 32 (AB 32) and Senate Bill 32 (SB 32), California Global Warming Solutions Act AB 32 requires CARB to reduce Statewide GHG emissions to 1990 levels by 2020. As part of this legislation, CARB was required to prepare a “Scoping Plan” that demonstrates how the State will achieve this goal. The Scoping Plan was adopted in 2011, and in it, local governments were described as “essential partners” in meeting the Statewide goal, recommending a GHG reduction level of 15 percent below 2005 to 2008 levels (depending on when a full emissions inventory is available) by 2020.

CARB released the 2017 Scoping Plan in November 2017. The 2017 Scoping Plan provides strategies for achieving the 2030 target established by EO B-30-15 and codified in SB 32 (40 percent below 1990 levels by 2030). The 2017 Scoping Plan recommends local plan-level GHG emissions reduction goals.

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2.4.2.4 SB 375
SB 375 aligns regional transportation planning efforts, regional GHG reduction targets, and affordable housing allocations. Metropolitan Planning Organizations (MPOs) are required to adopt a Sustainable Communities Strategy, which allocates land uses in the Metropolitan Planning Organization’s Regional Transportation Plan. Qualified projects consistent with an approved Sustainable Communities Strategy or Alternative Planning Strategy and categorized as “transit priority projects” would receive incentives under new provisions of CEQA. SB 375 requires regional reduction targets for light duty passenger vehicle CO2 emissions for each MPO.

2.4.2.5 AB 1493 (Pavley)
The Pavley Bill enacted in 2002 requires the maximum feasible and cost‐effective reduction of GHGs from automobiles and light‐duty trucks. In 2004, CARB approved the “Pavley I” regulations that applied to new passenger vehicles beginning with model year 2009 through 2016. Pavley I is expected to reduce GHG emissions from regulated vehicles by 30 percent from 2002 levels by 2016. Pavley II was incorporated into Amendments to the Low‐ Emission Vehicle Program referred to as LEV III.

The amendments, effective August 7, 2012, apply to vehicles for model years 2017 through 2025.

The regulation will reduce GHGs from new cars by 34 percent from 2016 levels by 2025 (CARB 2011).

2.4.2.6 Title 24 Energy Efficiency Standards
The State has adopted several other major regulations that will provide substantial reductions in GHGs. Title 24, Part 6 California’s Energy Efficiency Standards for Residential and Nonresidential Buildings were first established in 1978 to reduce California’s energy consumption. The California Energy Commission revises Title 24 about every three years to incorporate cost‐effective energy efficiency technological advancements into the construction of new buildings. The latest version is the 2019 Title 24 update, which will go into effect January 1, 2020. The 2019 Title 24 standards include the requirement by the California Public Utilities Commission (CPUC) Energy Efficiency Strategic Plan for net zero energy consumption for new residential development starting in 2020 and will ultimately incorporate requirements for net zero in new non-residential development by 2030.

2.4.2.7 Green Building Code
The California Green Building Standard Code (CALGreen) was adopted in 2010 and went into effect January 2011 (CGBSC 2010). CALGreen is a mandatory green building code that sets minimum environmental standards for new buildings including standards for volatile organic compound (VOC) emitting materials, water conservation, and construction waste recycling.

2.4.2.8 Senate Bill 97
SB 97, enacted in 2007, amends the CEQA statute to clearly establish that GHG emissions and the effects of GHG emissions are appropriate subjects for CEQA analysis. The legislation directed the California Office of Planning and Research to develop draft CEQA Guidelines “for the mitigation of GHG emissions or the effects of GHG emissions” and directed the California Natural Resources B3 Attach #1 of 3

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2.4.2.9 Senate Bill x7-7
SB x7-7 requires water suppliers to reduce urban per capita water consumption 20 percent from a baseline level by 2020.

2.4.2.10 Renewable Portfolio Standard
The Renewable Portfolio Standard (RPS) requires energy providers to derive 33 percent of their electricity from qualified renewable sources by 2020. In 2018, the State Assembly passed and Governor Jerry Brown signed SB 100, which requires energy providers to derive 60 percent of their electricity from qualified renewable sources by 2030 and 100 percent by 2045. The RPS is anticipated to lower emission factors (i.e., fewer GHG emissions per kilowatt-hour used) from utilities across the State, including Pacific Gas and Electric (PG&E).

2.4.2.11 Innovative Clean Transit (ICT) Regulation
The ICT regulation was adopted in December 2018 and requires all public transit agencies to gradually transition to a 100 percent zero-emission bus (ZEB) fleet. Beginning in 2029, 100 percent of new purchases by transit agencies must be ZEBs, with a goal for full transition by 2040. It applies to all transit agencies that own, operate, or lease buses with a gross vehicle weight rating (GVWR) greater than 14,000 pounds. It includes standard, articulated, over-the-road, double-decker, and cutaway buses.

2.4.2.12 Other Regulations
The CARB has adopted numerous regulations on sources of GHGs since the approval of the Climate Change Scoping Plan. Some of the more notable regulations include the Low Carbon Fuel Standard (LCFS) and regulations affecting vehicle efficiency such as the Tire Pressure Program, Low Friction Oil, and Heavy Duty Vehicle Aerodynamic Efficiency Standards. Also important are CARB regulations that apply to high global warming potential consumer products and refrigerants. SB 734, which requires the Governor’s Office of Planning and Research (OPR) to amend the CEQA Guidelines to provide an alternative to level of service (LOS) for evaluating transportation impacts. The law requires that those alternative criteria promote the reduction of GHG, the development of multimodal transportation networks, and a diversity of land uses.

2.4.3 Fresno County Council of Governments

2.4.3.1 SB 375 Regional Targets and Sustainable Community Strategy (SCS) SB 375 aligns regional transportation planning efforts, regional GHG reduction targets, and affordable housing allocations. Metropolitan Planning Organizations (MPO) are required to adopt a Sustainable Communities Strategy (SCS), which allocates land uses in the Metropolitan Planning Organization Regional Transportation Plan (RTP). Qualified projects consistent with an approved SCS B3 Attach #1 of 3
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In 2010, as part of its mandate under SB 375, the CARB set specific GHG emission reduction targets for cars and light trucks for each of the State’s 18 metropolitan planning organizations from a 2005 base year. The GHG targets set for the Fresno region in 2010 called for a 5 percent per capita reduction by 2020 and a 10 percent per capita reduction by 2035. SB 375 requires that Fresno Council of Governments (COG) demonstrate in its SCS that GHG emission reduction targets will be met for 2020 and 2035. If not, then an Alternative Planning Strategy (APS) shall be prepared to demonstrate how the targets can be met through the alternative strategies in the APS. These numbers are subject to changes due to model validation, calibration, and ongoing local coordination efforts. The MPO growth scenario focuses on existing core areas without expansion of the city of Fresno sphere of influence (CARB 2010). Under the General Plan, growth would be distributed along major corridors and activity centers supported by the Bus Rapid Transit (BRT) system, and has a theme of complete neighborhoods to provide convenient access to different uses at the neighborhood level. The strategy relies on a combination of increasing density, mixed uses, and infill.

The Fresno COG developed an SCS to implement SB 375 requirements. The SCS, adopted by the Fresno COG on June 26, 2014 demonstrated that Fresno County will be able to achieve the GHG targets for light‐duty vehicle travel adopted by the CARB for this area. In July 2018, the Fresno COG adopted a second SCS based on the previous SCS adopted in 2014. The Fresno COG would be able to meet the CARB GHG targets through 2018 RTP/SCS (Fresno COG 2018).

2.4.3.2 San Joaquin Valley Blueprint
The San Joaquin Valley Blueprint Planning Process is an effort by agencies, organizations, and individuals, including the Fresno COG, to identify visions, values, guiding principles, and alternative growth scenarios for development over a 20‐year planning horizon. The 2018 RTP/SCS continues the blueprint development process that started in 2006.

The adopted 12 Blueprint Smart Growth Principles from this process are:

1. Create a range of housing opportunities and choices.

2. Create walkable neighborhoods.

3. Encourage community and stakeholder collaboration.

4. Foster distinctive, attractive communities with a strong sense of place.

5. Make development decisions predictable, fair, and cost‐effective.

6. Mix land uses.

7. Preserve open space, farmland, natural beauty, and critical environmental areas.

8. Provide a variety of transportation choices.

9. Strengthen and direct development towards existing communities.

10. Take advantage of compact building design.

11. Enhance the economic vitality of the region.

12. Support actions that encourage environmental resource management.

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• Fresno County will be composed of unique cities, communities and a diverse population in a connected high quality environment that accommodates anticipated population growth and is supported by:
○ A vibrant economy built on competitive strength and world class education ○ A healthy and sustainable environment where air, aquifers, surface waters, forests, soil, agriculture, open space and wildlife resources are enhanced and protected ○ A focus on cultural and community stewardship where all people enjoy fundamental rights as members of a free society, and where the community takes ownership of problems and their solutions.

The form of the Fresno region blueprint recognizes its economic, environmental, and cultural connectedness while maintaining a system of high‐capacity multimodal transportation corridors that link the metro area to the rural areas and the State while preserving and maintaining the character of individual communities and the vital agricultural and natural resources between and around them (Fresno COG 2009). Figure 2-4 shows the Fresno County Blueprint preferred scenario.

Figure 2-4: Fresno County Blueprint Preferred Scenario
Source: Fresno Council of Governments (2009).

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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 2-15 The Blueprint preferred scenario would result in a countywide average of 8.0 dwelling units/acre residential density for new growth between now and 2050. The density of new growth in the Fresno Clovis Metropolitan Areas (FCMA) will be 9.0 units/acre, while the average density of new development in the non‐FCMA areas will be around 5.7 units/acre. This is comparable with the current trend density for Fresno county of 3.8 dwelling units/acre (Fresno COG 2009).

2.4.4 San Joaquin Valley Air Pollution Control District The city of Fresno is within the San Joaquin Valley Air Basin, which is under the jurisdiction of the San Joaquin Valley Air Pollution Control District (SJVAPCD). The District 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. District initiatives related to GHGs are described below.

2.4.4.1 Climate Change Action Plan
The District Governing Board approved the SJVAPCD Climate Change Action Plan (CCAP) on August 21, 2008. The CCAP began a public process to bring together stakeholders, land use agencies, environmental groups, and business groups, and to conduct public workshops to develop comprehensive policies for CEQA Guidelines, a carbon exchange bank, and voluntary GHG emissions mitigation agreements for the Governing Board’s consideration. The CCAP contains the following goals and actions:

Goals.

1. Assist local land‐use agencies with California Environmental Quality Act (CEQA) issues relative to projects with GHG emissions increases.

2. Assist Valley businesses in complying with mandates of AB 32 (Global Warming Solutions Act of 2006).

3. Ensure that climate protection measures do not cause increases in toxic or criteria pollutants that adversely impact public health or environmental justice communities.

Actions.

1. Develop GHG significance threshold(s) or other mechanisms to address CEQA projects with GHG emissions increases.

2. Develop necessary regulations and instruments for establishment and administration of the San Joaquin Valley Carbon Exchange Bank for voluntary GHG reductions created in the Valley.

3. Enhance the District’s existing criteria pollutant emissions inventory reporting system to allow businesses subject to AB 32 emission reporting requirements to submit simultaneous streamlined reports to the District and the state of California with minimal duplication.

4. Develop and administer voluntary GHG emission reduction agreements to mitigate proposed GHG increases from new projects.

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2.4.4.2 CEQA Greenhouse Gas Guidance
The District developed several resource documents that were used as guidance for developing the GHG Plan. The most important is the Guidance for Valley Land‐use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA, which is intended to assist local agencies in complying with CEQA and which contains a GHG threshold approach that has been widely accepted for use in the San Joaquin Valley and in other parts of the State. The District concluded that the existing science is inadequate to support quantification of the impacts that project‐specific GHG emissions have on global climatic change. The District found that the effects of project‐specific emissions to be cumulative, and without mitigation, their incremental contribution to global climatic change could be considered cumulatively considerable. The District found that this cumulative impact is best addressed by requiring all projects to reduce their GHG emissions, whether through project design elements or mitigation. Many San Joaquin Valley local jurisdictions, including Fresno, have used the District guidance for CEQA compliance.

The primary features of the District’s approach include:
• Projects exempt from the requirements of CEQA, and projects complying with an approved plan or mitigation program would be determined to have a less than significant cumulative impact.

The GHG Plan is intended to meet the criteria as an approved plan or mitigation program. • Projects for which there is no applicable approved plan or program, or those projects not complying with an approved plan or program, the lead agency would evaluate the project against a performance‐based standards and would require the adoption of design elements, known as a Best Performance Standard, to reduce GHG emissions. • Projects incorporating Best Performance Standards would not require specific quantification of GHG emissions, and automatically would be determined to have a less than significant cumulative impact for GHG emissions.

2.4.4.3 San Joaquin Valley Carbon Exchange and Rule 2301 The District 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 District 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.
• Provide an administrative mechanism for sources to transfer banked GHG emission reductions to others for any use.

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The District 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 District is one of the first to have offsets available for trading on the Exchange.

2.4.4.4 Community Emissions Reductions Program: Assembly Bill 617 (AB 617) AB 617 requires the 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 and the City of Shafter are the first Valley communities selected by the California Air Resources Board for investment of additional resources under AB 617. The Valley Air District has 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.

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3.0 EMISSION INVENTORY
Emission inventories are compilations of emissions generated by sources in a geographic area at a given time. GHG emission inventories are reported in units of MT CO2e emissions per year. Emission inventories identify the contribution of each type or category of emissions to the total inventory of pollutants of interest. Emission inventories help rank sources by size to determine those that are most important to control.

Inventories are required to determine existing conditions and to forecast emissions in future years to account for the effects of growth.

3.1 INVENTORY METHODS AND ASSUMPTIONS

3.1.1 Inventory Protocols
Emission inventory protocols have been developed for many emission sources by governmental and independent agencies, and professional associations. The U.S. Community Protocol for Accounting and Reporting of Greenhouse Gas Emissions, developed by ICLEI Local Governments for Sustainability, provides guidance for developing community inventories prepared in the United States. The U.S.

Community Protocol is not entirely applicable to inventories in California communities. For some inventory categories, a more detailed inventory may be required to ensure its adequacy for use in a CEQA context. California specific emission factors and data are available for many sources that when used produce a more accurate inventory. The inventory prepared for the City of Fresno GHG Plan Update follows the U.S. Community Protocol as modified for use in California.

3.1.2 Baseline Inventory Source Categories
The City developed its year 2010 baseline GHG inventory, which included the following source sectors:
• Motor Vehicles
• Electricity Use (Residential and Commercial)
• Natural Gas Use (Residential and Commercial)
• Waste
• Off-Road Equipment
• Refrigerants
The inventory did not include sources that comprise less than 3 percent of the inventory and sources that are not within the control or influence of the City of Fresno. One exception is off‐road equipment, which is less than 1 percent but is commonly included in project level GHG analyses.

Large industrial sources of emissions that are subject to CARB’s reporting regulation and Cap-andTrade regulation were not included in the inventory. The inventory did not include impacts of upstream emissions (e.g., emissions associated with an extraction process for purchased fuels— extraction, production, and transportation of fuels) because those sources are not within the control or influence of the City.

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3.2 BASELINE INVENTORY SELECTION CRITERIA
The baseline inventory year is important because it forms the starting point for setting emission reduction targets in future years. Several criteria were considered in selecting the best year for the baseline inventory, including:
• Data availability;
• Relationship with State inventories and targets; and
• Recommended practices from other agencies and organizations.

Since the AB 32 target is based on returning emissions to 1990 levels by 2020, some jurisdictions include a 1990 inventory. The 1990 baseline represents Statewide emissions and not the emissions of individual cities and counties. Growth rates vary widely from city to city since 1990. A 1990 inventory and target that do not account for variations in growth from community to community do not provide a valid comparison of the effectiveness or stringency of a GHG reduction program. In addition, the City cannot go back in time and change the amount and type of development that has occurred since 1990; it can only work from existing conditions. Therefore, the City had determined that a 2010 baseline provides the most recent year with complete data available suitable for describing existing conditions.

3.3 BASELINE INVENTORY
The City of Fresno baseline inventory year for the GHG Plan is 2010. The CARB has prepared an updated inventory for 2010 that accounts for regulations adopted to that point in time. Therefore, 2010 provides the best available baseline for the GHG Plan and can be compared directly with State progress to date and targets. Table 3-A shows the baseline inventory.

Table 3-A: GHG Emissions by Sector for 2010
Sector 2010 (MT CO2e) Percent of Total
Motor Vehicles 1,899,799 51
Electricity - Residential 327,813 9
Electricity - Commercial 361,836 10
Natural Gas - Residential 362,832 10
Natural Gas - Commercial 394,417 11
Waste 123,945 3
Off-road Equipment 1,051 <1
Ozone Depleting Substance (ODS) Substitutes 273,422 7
Total 3,745,115 100
Source: City of Fresno Greenhouse Gas Reduction Plan (2014).

MT CO2e = metric tons of carbon dioxide equivalent

3.4 BASELINE INVENTORY UPDATE
In September 2018, ICLEI Local Governments for Sustainability developed an inventory update for the year of 2016 for the City through the Statewide Energy Efficiency Collaborative. This inventory update is more recent and captures the GHG reductions from Statewide and local measures since 2010, therefore better reflects the current GHG emission levels in the city. The inventory update has B3 Attach #1 of 3
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Therefore, the 2016 inventory update is more complete. Table 3-B shows the source categories comparison between 2010 baseline inventory and 2016 inventory update.

Table 3-B: Source Categories Comparison Between
2010 and 2016 Inventories
2010 Baseline Inventory Sector 2016 Inventory Update Sector Motor Vehicles Transportation
Electricity - Residential Residential Energy
Electricity - Commercial Commercial Energy
Natural Gas - Residential Residential Energy
Natural Gas - Commercial Commercial Energy
Waste Solid Waste
Off-road Equipment Transportation
Ozone Depleting Substance (ODS) Substitutes Fugitive Emissions Not Included Agriculture
Not Included Industrial Energy
Source: Compiled by LSA Associates, Inc. (2019).

The City’s total emissions in 2016 were 2,923,633 MT CO2e. As shown in Table 3-C and Figure 3-1, the Transportation sector was the largest contributor to emissions in the 2016 inventory, with 52 percent of the City’s total GHG emissions. Commercial and residential energy use were the second and third largest contributor of GHG emissions with 18 percent and 16 percent of total emissions, respectively. Fugitive emissions accounted for 9 percent of total emissions, solid waste accounted for 4 percent of total emissions, and industrial energy and agriculture sectors emitted less than 1 percent.

Table 3-C: City of Fresno 2016 Inventory Update and Business-as-Usual Projections Sector 2016
(MT CO2e)
Percent
of Total
2020
(MT CO2e)
Percent
of Total
2030
(MT CO2e)
Percent
of Total
2035
(MT CO2e)
Percent
of Total
Transportation 1,520,052 52 1,594,888 52 1,798,498 51 1,909,852 52 Commercial Energy 524,838 18 557,142 18 627,373 18 657,379 18 Residential Energy 479,371 16 514,053 17 579,546 17 603,951 16 Fugitive Emissions 270,130 9 288,573 9 335,316 10 357,008 10 Solid Waste 119,167 4 127,303 4 147,923 4 157,493 4
Industrial Energy 10,055 <1% 10,506 <1% 11,528 <1% 12,035 <1% Agriculture Energy 20 <1% 20 <1% 20 <1% 20 <1%
Total 2,923,633 100 3,092,486 100 3,500,204 100 3,697,738 100 Source: ICLEI Local Governments for Sustainability, City of Fresno 2016 Inventory Update, 2018. Complied by LSA Associates, Inc.

MT CO2e = metric tons of carbon dioxide equivalent
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Business-as-Usual Projections
Source: Compiled by LSA Associates, Inc. (2019).

3.5 INVENTORY PROJECTIONS
The GHG Plan includes inventory projections for 2020, 2030, and 2035. The 2020 and 2030 forecast years are consistent with the goals identified in AB 32 and the 2017 Scoping Plan, which identify Statewide GHG reduction targets by 2020 and 2030. The 2035 forecast year correspond to the General Plan horizon and will allow the City to develop long-term strategies to continue GHG reductions.

3.5.1 BAU Inventory
BAU scenarios are commonly used in climate action planning to ensure that control measures are adequate to overcome the effects of cumulative growth in emissions by a target year. BAU is defined in the CARB AB 32 Scoping Plan as the forecasted GHG emissions through 2030 with existing policies and programs, but without any further action to reduce GHGs. BAU inventories allow for separate accounting of the benefits of regulations, strategies, and programs on future emissions.

The City’s BAU GHG emissions for 2020, 2030, and 2035 were projected based on 2016 Inventory Update data using population, households, and employment growth rate from the Fresno County 2050 Growth Projections developed by Fresno County Council of Governments.9 The BAU inventory for each forecast year is provided in Table 3-C and Figure 3-1. 9 Applied Development Economics. 2017. Fresno County 2050 Growth Projections. Prepared for Fresno County Council of Governments. Website: www.fresnocog.org/wp-content/uploads/publications/ Demographics/Fresno_COG_2050_Projections_Final_Report_050417.pdf (accessed March 4, 2019).

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26.5 percent from the 2016 level to 3,697,738 MT CO2e.

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4.0 REDUCTIONS FROM STATE REGULATIONS
The State has enacted many regulations pursuant to the requirements in AB 32 that would reduce emissions within the city. The State’s strategy is detailed in the Climate Change Scoping Plan adopted by the CARB in November 2017. Scoping Plan strategies are primarily implemented through the adoption of regulations. The most important and applicable strategies from the previous iterations and most recent 2017 Scoping Plan are discussed below.

4.1 MOTOR VEHICLES
The CARB has adopted many Scoping Plan measures for mobile sources as regulations both in the previous versions and most recent Scoping Plan (CARB 2008, 2014 and 2017). Only the measures that have been adopted or put into practice are included in this assessment. The following regulations are included:
• Pavley and Low Carbon Fuel Standard: EMFAC2017 emission factors that include Pavley and the LCFS were used to estimate the impact of those regulations. In this way, the reductions from those measures are more specific than simply applying the statewide reduction estimates because the reductions in EMFAC take into account the variations between vehicle classes and region.
• Low Emission Vehicle (LEV) III Standards: The LEV III standards amend the exhaust and evaporative emission standards for passenger cars and light‐ and medium‐duty trucks. The standards provide requirements for model years 2017 to 2025. The regulation applies to both criteria pollutant and GHG emissions. The standard drops GHG emission to 166 grams per mile, a reduction of 34 percent compared with 2016 levels. LEV III implements the Pavley II standards described in the Scoping Plan.
• Tire Pressure Program: This regulation is categorized under vehicle efficiency measures in the Scoping Plan. This regulation applies to automotive service providers performing or offering to perform automotive maintenance or repair services in California. This applies to passenger cars, light‐duty trucks, medium‐duty vehicles, and light heavy‐duty trucks with gross vehicle weight ratings of less than or equal to 10,000 pounds (CARB 2010). This measure is anticipated to reduce emissions by 0.5 percent for those vehicle types. • Low Friction Oil: CARB indicates that this measure has been achieved in practice. It is assumed that this measure would apply to the same vehicle types as in the tire pressure program. This measure is anticipated to reduce emissions by 2.2 percent. • Aerodynamic Efficiency: This regulation improves the fuel efficiency of heavy‐duty tractors that pull 53‐foot or longer box‐type trailers. Fuel efficiency is improved through improvements in tractor and trailer aerodynamics and the use of low rolling-resistance tires. This measure would reduce emissions by 2.1 percent from heavy-duty vehicles.

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4.2 ENERGY
The State's strategy for reducing energy-related GHGs targets electric power utilities on the production side and energy efficiency on the consumer side. Two regulations are in place to reduce emissions from this source. The Renewable Portfolio Standard requires electric utilities to provide an increasing share of their energy from renewable sources with 33 percent by 2020, 60 percent by 2030, and 100 percent by 2045. Title 24 Energy Efficiency Standards for Residential and NonResidential Buildings requires new structures to meet increasingly stringent energy efficiency standards. California's Green Building Code mandates increased water conservation that results in less electricity consumed to pump and transport water.

4.2.1 Renewable Portfolio Standard (RPS)
The electricity emission factor was decreased to account for the renewable energy regulations, which require 33 percent renewable energy by the year 2020, 60 percent by 2030, and 73 percent by 2035, which is interpolated from the 100 percent by 2045 requirement. The average renewable energy use for 2005-2009 for PG&E was calculated as 12.6 percent (California Public Utilities Commission 2013). Based on an approximation of electric generation from RPS-eligible sources divided by forecasted electricity retail sales for the year 2018, the Energy Commission estimates that 34 percent of California’s retail electricity sales in 2018 will be provided by RPS-eligible renewable resources. This shows that the State is already ahead of its 2020 goal (CEC 2018).

4.2.2 Title 24, Part 6 Building Energy Efficiency Standards Building energy efficiency standards are designed to ensure that new and existing buildings achieve energy efficiency and preserve outdoor and indoor environmental quality. These standards are contained in the California Code of Regulations (CCR) Title 24, Part 6. The California Energy Commission (CEC) is required by State law to update energy efficiency standards every 3 years. The 2019 Standards, which will become effective in January 2020, are focused on achieving zero net energy (ZNE) homes by increasing energy efficiency and requiring solar photovoltaic (PV) systems for new homes (CEC 2019).

The reductions from Title 24 are applied to the energy consumption related emissions for new development and remodeling projects at existing buildings subject to the regulations. The benefits of the standards accrue as buildings subject to the standards are constructed to meet the standard applicable at the time. PG&E provided actual electricity and natural gas usage for 2008 through 2010, which reflect the benefits of all development subject to previous versions of the Title 24 standards. New development would provide additional reductions as buildings are constructed to comply with the latest standards.

4.2.3 California's Green Building Standard Code
CCR Title 24, Part 11 (California Green Building Standard Code [CALGreen]), was adopted on January 12, 2010. The State Building Standards Commission unanimously adopted updates to the California Green Building Standards Code, which went into effect on January 1, 2011. The Code is a comprehensive and uniform regulatory code for all residential, commercial, and school Buildings.

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4.3 REFRIGERANTS
The State has adopted several refrigerant management regulations that are anticipated to achieve substantial reductions. For example, CARB predicts that the regulations that will apply to large commercial refrigeration units will reduce emissions by more than 50 percent.

4.4 REDUCTIONS FROM STATE REGULATIONS
The predicted reduction in emissions from State measures on city of Fresno emissions is shown in Table 4-A.

Table 4-A: Reductions from Statewide Measures
Sector State Measures Emission Reductions (MT CO2e/year) 2020 2030 2035
Transportation Pavley and Low Carbon Fuel Standard; Low Emission Vehicle Program III; Tire Tread Program; Tire Pressure
Program; Low Friction Oil; HD Aerodynamic/MHD
Hybridization
424,559 667,463 836,897
Residential
Energy
Renewable Portfolio Standards 164,477 299,049 363,843
Title 24 – Electricity 16,833 79,525 102,708
Title 24 – Natural Gas 7,983 10,762 12,496
Commercial
Energy
Renewable Portfolio Standards 174,877 317,958 386,849
Title 24 – Electricity 9,614 5,532 4,196
Title 24 – Natural Gas 17,530 12,933 11,108
Fugitive
Emissions
Limit High GWP Use in Consumer Products; Motor Vehicle
Air Conditioning; High GWP Refrigerant Management
Program for Stationary Sources
144,287 167,658 178,504
Total 960,160 1,560,880 1,896,602
Source: Compiled by LSA Associates, Inc. (2019).

GWP = global warming potential
HD = Heavy Duty
MHD = Medium Heavy Duty
MT CO2e/year = metric tons of carbon dioxide equivalent per year

4.4.1 Adjusted Business-as-Usual
The adjusted business-as-usual (ABAU) inventory applies emission reductions achieved by Statewide regulations, programs, and measures. This inventory identifies the base from which reductions are needed from local strategies and measures to demonstrate consistency with the State-aligned targets. Table 4-B shows the emission inventories for each year after the application of State regulatory measures.

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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 4-4 Table 4-B: City of Fresno Adjusted Business-as-Usual Emissions Sector 2016 2020 2030 2035
Transportation 1,520,052 1,170,329 1,131,034 1,072,955
Commercial Energy 524,838 355,121 290,950 255,226
Residential Energy 479,371 324,760 190,210 124,904
Fugitive Emissions 270,130 144,287 167,658 178,504
Solid Waste 119,167 127,303 147,923 157,493
Industrial Energy 10,055 10,506 11,528 12,035
Agriculture Energy 20 20 20 20
Total 2,923,633 2,132,326 1,939,325 1,801,137
Source: Compiled by LSA Associates, Inc. (2019).

4.4.2 Target Analysis
The State has set goals for reducing GHG emissions by 2020, 2030, and 2050 through AB 32, SB 32, and EO B-30-15, respectively. The State has also provided guidance to local jurisdictions as “essential partners” in achieving the State’s goals by identifying a 2020 recommended reduction goal. That goal, stated in the AB 32 Scoping Plan, was for local governments to achieve a 15 percent reduction below baseline levels by 2020, which aligns with the State’s goal of not exceeding 1990 emissions levels by 2020. The State’s long-term target is to emit no more than 20 percent of 1990 levels by 2050 (or, a reduction of 80 percent below 1990 levels by 2050). The State has also provided an interim target, which is 40 percent below 1990 levels by 2030. It is clear that the issue of climate change will not end in 2030 and continued reduction goals should be implemented to keep the State on a path toward the 2050 goal. A straight-line projection from the 2030 to 2050 goals would result in a reduction goal of 58 percent below baseline levels by 2035.

In order to keep the City of Fresno GHG Reduction Plan in line with the State’s reduction goals, the targets, as shown in Table 4-C, have been identified. Based on these targets, the City would meet the reduction target from an ABAU forecast in 2020. In 2030 and 2035, the City would need to reduce 29,316 MT CO2e and 209,463 MT CO2e emissions below the ABAU scenario, respectively, to meet the State-aligned target (Table 4-C and Figure 4-1).

Table 4-C: State-Aligned GHG Emission Reduction Targets By Year Sector 20101 2016 2020 2030 2035
BAU Emissions (MT CO2e) 3,745,115 2,923,633 3,092,486 3,500,204 3,697,738 Adjusted BAU Emissions (MT CO2e) 3,745,115 2,923,633 2,132,326 1,939,325 1,801,137 State-Aligned Target (Percent change from 1990) 0 -40 -50 State-Aligned Target (Percent change from 2010) -15 -49 -58 State-Aligned Emissions Goal (MT CO2e) 3,183,348 1,910,009 1,591,674 Reductions from Adjusted BAU needed to meet the
State-Aligned Target (MT CO2e) Target Met 29,316 209,463 Source: Compiled by LSA Associates, Inc. (2019). 1 Baseline (2010) emissions are from the City’s 2014 GHG Reduction Plan.

BAU = business-as-usual GHG = greenhouse gas MT CO2e = metric tons of carbon dioxide equivalent B3 Attach #1 of 3
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5.0 GREENHOUSE GAS REDUCTION STRATEGY
The GHG Reduction Plan is a comprehensive vision of the City’s plan to reduce GHG emissions. The City is already on a path toward lower emissions through its prior actions. The City has adopted a several goals, policies, and programs from the General Plan that contributed towards reducing GHG emissions. The General Plan provides a comprehensive strategy to reduce GHG emissions from all sources within the City’s ability to control or influence. The strategies enhance the effectiveness of State strategies by ensuring that the city is developed in ways that minimize emissions and by application to City‐owned facilities. The relevant General Plan objectives and policies are listed throughout the following section. For convenience, a compilation of the General Plan objectives and policies is provided as Appendix A to this GHG Plan Update. Table 5-A provides a listing of General Plan Elements/Chapters and the associated letter designations to enable the reader to identify the General Plan Element/Chapter associated with the objectives and policies listed in this section.

Table 5-A: General Plan Chapter Cross Reference
General Plan Element and Chapter Policy Prefix
Urban Form (Chapter 3) UF
Land Use (Chapter 3) LU
Design (Chapter 3) D
Mobility and Transportation (Chapter 4) MT
Park and Open Space (Chapter 5) POSS
Public Utilities and Services (Chapter 6) PU
Resource Conservation and Resilience (Chapter 7) RC
Healthy Communities (Chapter 10) HC
Economic Development and Fiscal Sustainability (Chapter 2) ED Source: FirstCarbon Solutions. 2014. Fresno General Plan Update, Greenhouse Gas Reduction Plan, prepared for the City of Fresno.

July. Website: https://www.fresno.gov/darm/wp-content/uploads/sites/10/2016/11/F-2-Greenhouse-Gas-Reduction-Plan.pdf (accessed December 2019).

5.1 GHG PLAN REDUCTION STRATEGY
The City can control or influence GHG emissions in several ways. The City has direct control over its own fleet vehicles and buildings where it can use its budgeting authority and purchasing decisions for high efficiency/low emission options. The City has influence over emissions from development and redevelopment projects through its land use authority and its responsibilities as a Lead Agency under CEQA. The City can also provide leadership and education to the community to encourage voluntary actions to reduce GHG emissions. The General Plan provides the comprehensive objectives and policies that direct development in the city. The GHG Plan Update relies upon the General Plan as the basis of the development related strategies to reduce GHG emissions.

Greenhouse gas emissions are generated by a multitude of sources and activities. There is no single technology or individual program that provides a silver bullet for addressing this problem.

Comprehensive solutions on multiple fronts are required to make the progress needed to achieve reduction targets for 2020, 2030 and beyond.

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follows:
• Land Use and Transportation
• Transportation Facilities Strategies
• Transportation Demand Strategies
• Energy Conservation Strategies for New and Existing
Buildings
• Water Conservation Strategies
• Waste Diversion and Recycling and Energy Recovery
• Strategies for Existing Development
• Municipal Strategies
As described in the previous section, motor vehicle emissions dominate the City’s emission inventory. The City has control over the emissions from its government fleet vehicles through its purchasing decisions, but no control over the emissions from other vehicles that operate in and pass through the city. However, the City’s authority over land use provides opportunities to influence the amount people drive and their choice of travel mode. In planning circles, this is called the land use, transportation, air quality connection.

Land use and transportation strategies are supported by the General Plan land use and circulation plans and policies that provide the City’s vision of future development in the planning area to the extent that they reduce vehicle trips and miles traveled compared with alternative development plans and patterns. The City’s General Plan includes many land use and transportation policies that when implemented result in lower greenhouse gas emissions through the promotion of smart growth; jobs/housing balance; transit‐oriented development; and infill development through that application of land use designations, and zoning, and the use of public‐private partnerships to encourage action.

The following are land use strategies utilizing goals and policies in the General Plan that with application to individual projects will achieve GHG emission reductions. Key GHG Plan Update indicators associated with the applicable General Plan policies are also identified to help the individual projects account for GHG emission reductions.

5.1.1 Land Use Strategies
Development that is more dense and compact places people closer to destinations that can be accessed by walking or bicycling, and transit. Higher densities near transit routes and facilities also increases the potential for more frequent high‐quality transit service such as BRT. The General Plan includes the following related policy.

Policy RC‐2‐a Link Land Use to Transportation. Promote mixed‐use, higher density infill development in multi‐modal corridors. Support land use patterns that make more efficient use of the transportation system and plan future transportation investments in areas of higher‐intensity development. Discourage investment in infrastructure that would not meet these criteria.

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5.1.1.1 Compact and Infill Development
The General Plan provides for a substantial increase in development density in new growth areas compared to
existing development. In addition, development trends
show that more project developers can be expected to
propose higher‐density, single‐ and multi‐family
development than was constructed in the past. The
General Plan land use designations provide density ranges that allow for higher average densities than experienced in the past for land already designated by the General
Plan. The General Plan provide an increase in density in new growth areas.

Higher‐density development tends to produce fewer vehicle trips per dwelling unit and more intense commercial development increases opportunities for walking, bicycling, and transit use for some trips. Although higher density is a prerequisite for achieving compact development, the design of the new projects is critical for maximizing reductions from being more compact related to walking, bicycling, and transit use. Approved but undeveloped subdivisions would comply with existing General Plan designations; however, market forces could result in requests for revisions to these subdivisions that would increase development density. Another way to increase density is to allow second units on residential lots. This practice increases overall development density and promotes more compact development that brings more people closer to commercial development.

Relevant General Plan Policies.

Policy UF‐1‐c Identifiable City Structure. Focus integrated and ongoing planning efforts to achieve an identifiable city structure, comprised of a concentration of buildings, people, and pedestrian‐oriented activity in Downtown; along a small number of transit‐oriented, mixed‐use corridors and strategically located Activity Centers; and in existing and new neighborhoods augmented with parks and connected by multi‐purpose trails and tree-lined bike lanes and streets.

Objective UF‐12 Locate roughly one‐half of future residential development in infill areas— defined as being within the City on December 31, 2012—including the Downtown core area and surrounding neighborhoods, mixed‐use centers and transit‐oriented development along major BRT corridors, and other non‐corridor infill areas, and vacant land.

Policy UF‐12‐b Activity Centers. Mixed‐use designated areas along BRT and/or transit corridors are appropriate for more intensive concentrations of urban uses. Typical uses could include commercial areas; employment centers; schools; compact residential development; religious institutions; parks; and other gathering points where residents may interact, work, and obtain goods and services in the same place.

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Policy LU‐2‐b Infill Development for Affordable Housing. Establish a priority infill incentive program for residential infill development of existing vacant lots and underutilized sites within the City as a strategy to help to meet the affordable housing needs of the community.

Policy LU‐3‐b Mixed‐Use Urban Corridors that Connect the Downtown Planning Area.

Support the development of mixed‐use urban corridors that connect the Downtown Planning Area with the greater Fresno‐Clovis Metropolitan Area with functional, enduring, and desirable urban qualities along the Blackstone Avenue, Shaw Avenue, California Avenue, and Ventura Avenue/Kings Canyon corridors, as shown on Figure LU‐1: General Plan Land Use Diagram.

Policy LU‐3‐c Zoning for High Density on Major BRT Corridors. Encourage adoption of supportive zoning regulations for compact development along BRT corridors leading to the Downtown Core that will not diminish long‐term growth and development potential for Downtown.

Policy LU‐5‐f High Density Residential Uses. Promote high‐density residential uses to support Activity Centers and BRT corridors, and walkable access to transit stops.

Policy RC‐2‐a Link Land Use to Transportation. Promote mixed‐use, higher density infill development in multi‐modal corridors. Support land use patterns that make more efficient use of the transportation system and plan future transportation investments in areas of higher‐intensity development. Discourage investment in infrastructure that would not meet these criteria.

Figure 5-1 illustrates the conceptual location for the city of Fresno growth areas and the proposed BRT corridor. Compact development and infill provide the supporting base that maximizes the potential reductions in GHG emissions from the Plan strategy. Increased density, strategically located near quality transit and activity centers, is critical to successful implementation.

Key GHG Plan Indicators.
• Change in development density with time.
• Number of infill and redevelopment projects proposed. • Changes in transit service and ridership.
• Compile ongoing development statistics for comparison with General Plan Policy objectives. • Projects comply with General Plan policies.

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5.1.1.2 Mixed‐Use Development
Mixed‐use projects provide opportunities for walking
between uses for some trips. Trips are reduced when
visitors can park once at the development and obtain
services, shopping, or go to a restaurant during a single trip. There are a variety of mixed‐use development types with different mixes of uses and designs. Infill projects that provide residential development close to existing
commercial development or vice versa can produce many
of the same mixed‐use benefits if done in a walkable
environment.

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Policy RC‐2‐a Link Land Use to Transportation. Promote mixed‐use, higher density infill development in multi‐modal corridors. Support land use patterns that make more efficient use of the transportation system and plan future transportation investments in areas of higher‐intensity development. Discourage investment in infrastructure that would not meet these criteria.

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.

Policy UF‐12‐d Appropriate Mixed‐Use. Facilitate the development of vertical and horizontal mixed‐uses to blend residential, commercial, and public land uses on one or adjacent sites. Ensure land use compatibility between mixed‐use districts in Activity Centers and the surrounding residential neighborhoods.

Policy UF‐12‐f Mixed‐Use in Activity Centers. Update the Development Code which includes use regulations and standards to allow for mixed uses and shared parking facilities.

Key GHG Plan Indicators.
• The number of mixed use projects proposed.
• The number of mixed use project constructed.

5.1.1.3 Pedestrian-Oriented Development
Providing pedestrian‐friendly infrastructure such as
sidewalks, paths, and direct connections to neighboring uses such as shopping, schools, libraries, and parks
increase the potential for people to make trips on foot instead of making a car trip.

This strategy is consistent with the Complete Streets
concept that aims to make streets safe for walking and
bicycling.

Relevant General Plan Policies.

Policy UF‐12‐e Access to Activity Centers. Promote adoption and implementation of standards supporting pedestrian activities and bicycle linkages from surrounding land uses and neighborhoods into Activity Centers and to transit stops. Provide for priority transit routes and facilities to serve the Activity Centers.

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Objective UF‐14 Create an urban form to facilitate multi‐modal connectivity.

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.

Policy UF‐14‐b Local Street Connectivity. Design local roadways to connect throughout neighborhoods and large private developments with adjacent major roadways and pathways of existing adjacent development. Create access for pedestrians and bicycles where a local street must dead end or be designed as a cul‐de‐sac to adjoining uses that provide services, shopping, and connecting pathways for access to the greater community area.

Policy UF‐14‐c Block Length. Create development standards that provide desired and maximum block lengths in residential, retail, and mixed‐use districts in order to enhance walkability.

Policy D‐3‐c Local Streets as Urban Parkways. Develop local streets as “urban parkways”, where appropriate, with landscaping and pedestrian spaces.

Policy D‐4‐b Incentives for Pedestrian‐Oriented Anchor Retail. Consider adopting and implementing incentives for new pedestrian‐friendly anchor retail at intersections within Activity Centers and along corridors to attract retail clientele and maximize foot traffic.

Policy MT‐1‐h Update Standards for Complete Streets. Update the City’s Engineering and Street Design Standards to ensure that roadway and streetscape design specifications reflect the Complete Streets concept, while also addressing the needs of through traffic, transit stops, bus turnouts, passenger loading needs, bike lanes, pedestrian accommodation, and short‐ and long‐term parking.

Key GHG Plan Indicators.
• Project compliance with General Plan Policies

5.1.1.4 Transit-Oriented Development
Long‐term development trends for increasing density and mixes of uses can lead to improved transit service in key areas of Fresno over time. Higher densities when combined with pedestrian orientation encourage transit use. A key factor is that both ends of the transit trip must be walkable and have the potential to serve reasonably large numbers of transit riders. The City’s existing BRT B3 Attach #1 of 3

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Relevant General Plan Policies.

Objective UF‐12 Locate roughly one‐half of future residential development in infill areas— defined as being within the City on December 31, 2012—including the Downtown core area and surrounding neighborhoods, mixed‐use centers and transit‐oriented development along major BRT corridors, and other non‐corridor infill areas, and vacant land.

Policy UF‐12‐a BRT Corridors. Design land uses and integrate development site plans along BRT corridors, with transit‐oriented development that supports transit ridership and convenient pedestrian access to bus stops and BRT station stops.

Policy UF‐12‐b Activity Centers. Mixed‐use designated areas along BRT and/or transit corridors are appropriate for more intensive concentrations of urban uses. Typical uses could include commercial areas; employment centers; schools; compact residential development; religious institutions; parks; and other gathering points where residents may interact, work, and obtain goods and services in the same place.

Key GHG Plan Indicators.
• Comparison of development approved in infill areas versus non‐infill areas such as comparison of development approved within 0.5 mile of BRT stations and 0.25 mile of transit stations versus non-BRT/non-transit station areas.
• Project designs consistent with General Plan policies.

5.1.2 Transportation Facilities Strategies
The following are strategies related to transportation infrastructure and facilities that encourage the use of alternative modes of transportation such as walking, bicycling, and transit use. This strategy would be implemented through support for and funding of transit, bicycle, and pedestrian connections, through transit and trail planning, and with regional cooperation among relevant agencies.

5.1.2.1 Transit Facilities
Transit facilities include bus stops, bus turnouts,
multimodal transfer centers, and information kiosks.

These facilities increase the comfort and convenience
of using transit and minimize impacts on traffic flow
from buses stopping for riders and re‐entering traffic.

Overall increases in transit service through the addition of new buses, new routes, and more frequent stops can
also provide increased transit mode share. Transit
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Relevant General Plan Policies.

Objective MT‐8 Provide public transit options that serve existing and future concentrations of residences, employment, recreation and civic uses and are feasible, efficient, safe, and minimize environmental impacts.

Policy MT‐8‐a Street Design Coordinated with Transit. Coordinate the planning, design, and construction of the major roadway network with transit operators to facilitate efficient direct transit routing throughout the Planning Area.

Policy MT‐8‐b Transit Serving Residential and Employment Nodes. Identify the location of current and future residential and employment concentrations and Activity Centers throughout the transit service area in order to facilitate planning and implementation of optimal transit services for these uses. Work with California State University, Fresno to determine locations within the campus core for bus stops.

Policy MT‐8‐g High Speed Train. If the State moves forward with HST, ensure it is constructed through Fresno in a manner that minimizes impacts to surrounding property owners and creates the most opportunity for redevelopment around the HST station.

Objective MT‐9 Provide public transit opportunities to the maximum number and diversity of people practicable in balance with providing service that is high in quality, convenient, frequent, reliable, cost effective, and financially feasible.

Key GHG Plan Indicators.
• Transit route expansions
• Transit ridership trends
• Transition toward zero emission vehicles

5.1.2.2 Bicycle and Pedestrian Infrastructure
Adequate pedestrian infrastructure connecting frequently accessed destinations is critical to an increase in walking trips.

Pedestrian infrastructure should be incorporated into project designs for new development, but also can be retrofitted in existing neighborhoods with barriers to walking such as lack of sidewalks or dangerous crossings.

Bicycle infrastructure including separate bicycle paths and bicycle lanes on roadways can increase the safety of cyclists and B3 Attach #1 of 3

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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 5-10 encourage the use of this travel mode. Bicycle paths designed to provide more direct connections shorten travel distances and maximize safety. Bicycle lanes are less costly and can more easily connect multiple destinations for cyclists. The City of Fresno has an aggressive program in place to construct bike lanes and paths throughout the city. All new development is required to comply with the Bicycle, Pedestrian, and Trails Master Plan. Most arterials are now equipped with striped bike lanes. The City has also been installing sensors in the bike lanes that will trigger traffic lights to change when no motor vehicles are present.

Relevant General Plan Policies.

Objective MT‐4 Establish and maintain a continuous, safe, and easily accessible bikeways system throughout the metropolitan area to reduce vehicle use, improve air quality and the quality of life, and provide public health benefits.

Policy MT‐4‐a Active Transportation Plan. To the extent consistent with this General Plan, continue to implement and periodically update the Active Transportation Plan to meet State standards and requirements for recommended improvements and funding proposals as determined appropriate and feasible.

Policy MT‐4‐b Bikeway Improvements. Establish and implement property development standards to assure that projects adjacent to designated bikeways provide adequate right‐of‐ way and that necessary improvements are constructed to implement the planned bikeway system shown on Figure MT‐2 to provide for bikeways, to the extent feasible, when existing roadways are reconstructed; and alternative bikeway alignments or routes where inadequate right‐of‐way is available.

Policy MT‐4‐c Bikeway Linkages. Provide linkages between bikeways, trails and paths, and other regional networks such as the San Joaquin River Trail and adjacent jurisdiction bicycle systems wherever possible.

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.

Policy MT‐5‐a Sidewalk Development. Pursue funding and implement standards for development of sidewalks on public streets, with priority given to meeting the needs of persons with physical and vision limitations; providing safe routes to school; completing pedestrian improvements in established neighborhoods with lower vehicle ownership rates; or providing pedestrian access to public transportation routes.

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MARCH 2020 C ITY OF F RESNO GHG REDUCTION PLAN UPDATE

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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 5-11 Objective MT‐6 Establish a network of multi‐purpose pedestrian and bicycle paths, as well as limited access trails, to link residential areas to local and regional open spaces and recreation areas and urban Activity Centers in order to enhance Fresno’s recreational amenities and alternative transportation options.

Policy MT‐6‐a Link Residences to Destinations. Design a pedestrian and bicycle path network that links residential areas with Activity Centers, such as parks and recreational facilities, educational institutions, employment centers, cultural sites, and other focal points of the city environment.

Policy MT‐6‐g Path and Trail Development. Require all projects to incorporate planned multi‐purpose path and trail development standards and corridor linkages consistent with the General Plan, applicable law and case‐by‐case determinations as a condition of project approval.

Policy POSS‐7‐h Interlink City and San Joaquin River Parkway Trail Networks. Strive to connect the parkway trail network to other trails in the vicinity, in order to create a community and regional trail system that offers a variety of different route combinations and enhances public access to the parkway.

Key GHG Plan Indicators.
• Active Transportation Plan implementation progress (projects funded and constructed). • Developer funded and constructed bicycle and pedestrian projects. • Compliance with General Plan policies and Development Code.

5.1.2.3 Traffic Calming Features
Design features and strategies to reduce vehicle speeds and reduce conflicts with pedestrians encourage more
walking. Slower speeds encouraged by traffic calming can also improve safety and increase bicycling. Providing
on‐street parking, or street trees and landscaping to
separate vehicles from pedestrians improve walkability.

Relevant General Plan Policies.

Policy MT‐1-i Local Street Standards. Establish and implement local roadway standards addressing characteristics such as alignment, width, continuity and traffic calming, to provide efficient neighborhood circulation; to allow convenient access by residents, visitors, and public service and safety providers; and to promote neighborhood integrity and desired quality of life by limiting intrusive pass-through traffic.

Policy MT‐1-j Transportation Improvements Consistent with Community Character. Prioritize transportation improvements that are consistent with the character of surrounding neighborhoods and supportive of safe, functional and Complete B3 Attach #1 of 3

C ITY OF F RESNO GHG REDUCTION PLAN UPDATE
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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 5-12 Neighborhoods; minimize negative impacts upon sensitive land uses such as residences, hospitals, schools, natural habitats, open space areas, and historic and cultural resources.

In implementing this policy, the City will design improvements to:
• Facilitate provision of multi-modal transportation opportunities; • Provide added safety, including appropriate traffic calming measures; • Promote achievement of air quality standards;
• Provide capacity in a cost effective manner; and
• Create improved and equitable access with increased efficiency and connectivity.

Policy MT‐5-e Traffic Management in Established Neighborhoods. Establish acceptable design and improvement standards and provide traffic planning assistance to established neighborhoods to identify practical traffic management and calming methods to enhance the pedestrian environment with costs equitably assigned to properties receiving the benefits or generating excessive vehicle traffic.

Key GHG Plan Indicators.
• Project compliance with General Plan Policies

5.1.3 Transportation Demand Strategies
These strategies provide programs and facilities that encourage employees to use alternative modes for commute trips.

5.1.3.1 Transportation Demand Management
Transportation Demand Management (TDM) refers to measures designed to reduce the demand for transportation facilities that are usually implemented at employment sites and event centers. These include programs targeting employee commute trips at the worksite such as vanpools, and incentives for alternative transportation and government‐operated programs such as rideshare matching and outreach and incentives. Event center TDM measures involve the use of shuttles, encouraging carpooling, and staggering arrival and departure times to reduce congestion.

Large existing and new employers are required by existing regulations to implement TDM programs.

The SJVAPCD has adopted Rule 9410 Employer Based Trip Reduction, which requires employers with over 100 employees to implement trip reduction programs. (SJVAPCD 2009) The rule targets employee commute trips and requires large employers to implement measures that reduce VMT by increasing transit use, carpooling, vanpooling, bicycling, or other measures to reduce trips. The SJVAPCD estimates that the rule will reduce light‐duty mobile source criteria pollutants by approximately 6.8 percent by 2023 (SJVAPCD 2009). Similar reductions in greenhouse gas emissions would also be achieved with the reduction in trips and vehicle miles traveled from the rule.

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MARCH 2020 C ITY OF F RESNO GHG REDUCTION PLAN UPDATE

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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 5-13 End‐of‐trip facilities include items such as showers and lockers for people who bicycle to work, secure bike parking, onsite services such as dry cleaning pick‐up and cafeterias, and break rooms to reduce trips for errands and lunch. These are measures intended to increase the convenience and reduce potential negatives associated with bicycling to work and to eliminate the need for some trips during the workday. End‐of‐trip facilities are often included as design features in large projects to attract employees and may be selected by businesses as compliance options for Rule 9410.

Relevant General Plan Policies.

Policy MT‐10‐c Transportation Demand Management Guidelines. Establish transportation demand management guidelines to allow for reduced off‐street parking requirements.

5.1.3.2 Parking Measures
Providing limited parking is one of the most effective
transportation measures. Use of parking structures and
paid parking provide a strong incentive to use alternative modes and to take advantage of carpools and vanpools.

This measure would only apply in higher‐density
development areas, downtown, and mixed‐use projects
specifically designed for this strategy.

Relevant General Plan Policies.

Policy MT‐10‐a Updating Parking Standards. Update off‐street parking standards to reflect the context and location within activity areas of multiple uses and reductions appropriate for mixed residential and non‐residential uses and proximity to existing or planned transit service.

Policy MT‐10‐b Shared Parking. Establish a strategy to promote the sharing of excess parking between uses within Activity Centers and BRT corridors, including specific provisions for this in the Development Code.

Policy MT‐10‐d Parking Maximums. Explore maximum off‐street parking limits within Activity Centers proximate to BRT corridors, if such an Activity Center is determined compatible with promotion of a healthy and vigorous business environment.

Policy MT‐10‐f Parking Benefit Districts. Establish parking benefit districts to fund consolidated public parking where supported by local businesses.

Key GHG Plan Indicators.
• Completion of parking standards update incorporating the policies • Projects with shared parking approved
• Employers and educational facilities participating in subsidized transit programs B3 Attach #1 of 3

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5.1.3.3 Electric Vehicle Charging Stations
Infrastructure to charge electric vehicles while at work or other destinations would allow longer distance commuters and other drivers to use electric vehicles without concern for running out of charge on the return trip. Quick‐charge technologies are in development that can partially charge a car battery in 15 minutes. Once quick‐charging stations are widely available, the range impediment of electric vehicles will be much less important.

The interim solution to battery range is hybrid vehicles that can run on electricity or conventional fuels. Plug‐in hybrids have larger battery packs that allow vehicles to travel greater distances under battery power prior to use of the gasoline engine.

Relevant General Plan Policies.

Policy RC‐8‐j Alternative Fuel Network. Support the development of a network of integrated charging and alternate fuel station for both public and private vehicles, and if feasible, open up municipal stations to the public as part of network development.

Key GHG Plan Indicators.
• Completion of EV charging stations and alternative fuel stations

5.1.4 Energy Conservation Strategies for New and Existing Buildings Improving energy efficiency in new and existing buildings and facilities provides one of the most cost‐effective strategies for reducing greenhouse gases. The energy savings from improved energy efficiency can often pay for the cost of the upgrades and retrofits over time. These strategies are implemented through the promotion of energy‐ and water‐efficient buildings (e.g., LEED buildings and/or exceeding Title 24 standards) through green building ordinances, project timing, prioritization, and other implementing tools.

5.1.4.1 Energy Efficiency in New Buildings
New projects can exceed Title 24 Energy Efficiency Standards for new residential and non‐residential buildings. The amount of reductions in energy use can be related to voluntary tier levels contained in Title 24 or through use of outside certifying programs such as LEED, EnergyStar or Greenpoint Rating systems. It should be noted that meeting LEED standards does not necessarily mean that a project would comply with Title 24, so additional measures may still be required for some projects to meet regulatory requirements. The state’s ultimate goal is for new buildings to achieve “net zero” energy consumption. Net zero requires a combination of high efficiency buildings and energy self‐ generation through solar power or other means. Once net zero buildings become the norm, opportunities for reductions from new building energy efficiency become limited. Locations and building designs that are not suitable for onsite generation will not be able to achieve net zero energy consumption with currently available technologies. For those sites, offsite generation in common areas or through purchase of energy generated by zero emission facilities may be used.

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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 5-15 Relevant General Plan Policies.

Objective RC‐8 Reduce the consumption of non‐renewable energy resources by requiring and encouraging conservation measures and the use of alternative energy sources.

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 nonresidential 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.

Policy RC‐8‐d Incentives. Establish an incentive program for residential developers who commit to building all of their homes to ENERGY STAR performance guidelines.

Policy RC‐8‐e Energy Use Disclosure. Promote compliance with State law mandating disclosure of a building’s energy data and rating of the previous year to prospective buyers and lessees of the entire building or lenders financing the entire building.

Key GHG Plan Indicators.
• Title 24 compliance reports demonstrating projects meet or exceed regulatory requirements. • Project CEQA documents include discussion of energy conservation design features. • Periodic compilation of building energy efficiency reports for comparison with Plan goals.

5.1.4.2 Energy Efficiency in Existing Buildings
Older buildings that were constructed prior to the adoption of Title 24 or that were constructed when early versions of Title 24 were in place provide significant opportunities for cost‐effective energy retrofits. Most current energy retrofit programs are voluntary incentive based programs. The State of California and the federal government have from time to time offered tax credits and deductions for energy retrofits. Public utilities also offer energy efficiency rebates for projects such as whole‐house fans, insulation, weatherization, and other actions that reduce energy consumption in residential and commercial buildings. Some jurisdictions have proposed mandatory energy efficiency retrofits at time of sale; however, those programs are currently considered by many to be infeasible because of the loss of equity experienced by many homeowners at the time of sale, especially when housing values are low.

In January 2011, the City Council unanimously approved the adoption of the California Property Assessed Clean Energy (PACE) program administered by figtreecompany.com for the City of Fresno.

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C ITY OF F RESNO GHG REDUCTION PLAN UPDATE
F RESNO , C ALIFORNIA MARCH 2020
P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 5-16 PACE utilizes bond financing to provide property owners fixed‐rate, property‐based, no‐money‐down financing for energy and water efficiency retrofits to their properties, significantly reducing energy bills and expenses with instant cost savings. The City no longer has an active PACE program; however, in partnership with PG&E, the City has implemented programs to achieve reductions in electricity usage, particularly in the municipal sector.

Relevant General Plan Policies.

Policy RC‐7‐i PACE Financing. Develop a residential Property Assessed Clean Energy (PACE) program, if it is determined to be a feasible option, to help finance water efficiency and energy efficiency upgrades for property owners.

Key GHG Plan Indicators.
• Progress in implementing the PACE program.
• Report on types and numbers of projects funded.

5.1.4.3 Self-Generation Using Solar Panels and Solar Hot Water Systems The city of Fresno’s location and climate is excellent for solar electric generation and hot water systems with an average of 262 sunny days per year. Residential and commercial projects can include solar‐ready roofs to allow future installation of solar panels or provide solar panels at the time of construction. Solar panel technology is becoming increasingly efficient in terms of power production and costs have declined substantially in recent years. Not all locations and project settings are conducive to solar power production, and cost‐effectiveness is currently dependent on the receipt of incentives in most cases. Sites with the potential for other structures or trees shading the panel location greatly reduce feasibility. The projects also often require net metering where surplus power generated by the panels is sold to the utility and power is purchased from the grid during periods of low production or high usage. The utilities are only required to accept a limited amount of solar photovoltaic (PV) distributed generation into their systems each year. If limits are exceeded and net metering is not allowed, the systems become less feasible.

Solar hot water systems have been used for residential water heating for many years and are especially popular for residences with swimming pools to extend the days per year when the pool can be used. Another option for hot water is to use tankless, electric water heaters. These are increasingly used in new development. Tankless heating saves water and energy because it is not necessary to run the water for long periods for the water to arrive from the hot water tank to the faucet as is the case with the conventional water heaters.

Relevant General Plan Policies.

Policy RC‐8‐h Solar Assistance. Identify and publicize information about financial mechanisms for private solar installations and provide over‐the‐counter permitting for solar installations meeting specified standards, which may include maximum size (in kV) of units that can be so approved.

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MARCH 2020 C ITY OF F RESNO GHG REDUCTION PLAN UPDATE

F RESNO , C ALIFORNIA
P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 5-17 Key GHG Plan Indicators.
• Projects permitted

5.1.5 Water Conservation Strategies
Water pumping and transport
consumes approximately 20
percent of all energy used in
California. Measures to reduce
water consumption through
improved efficiency in
plumbing fixtures and
landscaping can result in
substantial savings compared
to past practices. In some
cases, it may be feasible to go
beyond the water efficiency standards in the California Green Building Standards Code and the State Model Water Efficient Landscape Ordinance with new construction. Water reuse and recycling through non‐potable “purple pipe” systems may reduce energy consumption for water transport.

The City has started installing purple pipes through implementation of the Recycled Water Ordinance. The Ordinance requires that new developments within planned major recycled water distribution mains to install purple pipe. As the City’s capital projects construct distribution infrastructure, these segments will be in place to facilitate connections to new customers. The City’s initial implementation of the recycled water distribution system from the Recycled Water Reclamation Facility is currently under construction. The City plans to use 25,000 acre-feet per year of recycled water to irrigate open spaces, parks, street medians, and golf courses, and at groundwater recharge facilities. The City is constructing an advanced treatment facility at the Fresno-Clovis Regional Water Reclamation Facility (RWRF) to process and clean the water to meet State and federal standards and regulations for non-potable use. The initial capacity of the facility will be 5 million gallons per day with a future capacity of 30 million gallons per day. The new treatment facility will pump water into the new network of recycled water pipelines that will convey recycled water across the city. The route begins in a rural and agricultural area in Fresno county and moves to high traffic city streets. High traffic volumes, businesses, agriculture, cemeteries and residences are immediately adjacent to project route (Recharge Fresno 2018).

The use of recycled water focuses on new and existing large green spaces, industrial uses, and new development. However, the development of a gray water policy for the residential reuse of wastewater for household gardening and landscape irrigation on site may be feasible. Water users that implement these measures or purchase buildings and homes that include these features will benefit from savings in their water bills.

5.1.5.1 Relevant General Plan Policies
Policy RC‐6‐d Recycled Water. Prepare, adopt, and implement a City of Fresno Recycled Water Master Plan.

Northeast Fresno Surface Water Treatment Plant
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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 5-18 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 that reduces 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 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-d Update Standards for New Development. Continue to refine water saving and conservation standards for new development.

Policy RC-7-f Implementation and Update Conservation Program. Continue to implement the City of Fresno Water Conservation Program, as may be updated, and periodically update restrictions on water uses, such as lawn and landscape watering and the filling of fountains and swimming pools, and penalties for violations. Evaluate the feasibility of a 2035 conservation target of 190 gpcd in the next comprehensive update of the City of Fresno Water Conservation Program.

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.

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MARCH 2020 C ITY OF F RESNO GHG REDUCTION PLAN UPDATE

F RESNO , C ALIFORNIA
P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 5-19 • 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.

Key GHG Plan Indicators.
• Track per capita water use with collected meter data and normal reporting. • Progress in updating the Water Conservation Program.

5.1.6 Waste Diversion and Recycling and Energy Recovery Programs and actions that promote recycling and diversion of waste from landfills can reduce energy consumed in the transport and handling of the waste material and can reduce the greenhouse gases that are emitted during the decomposition of organic waste.

The State of California has adopted increasingly stringent mandates for the percentage of solid waste that can be disposed in landfills. Programs that require or encourage further reductions in waste beyond mandates will result in greenhouse gas reductions from this source. Certain landfills are mandated to install methane capture systems. Methane is a powerful greenhouse gas that is 21 times more effective than carbon dioxide in retaining heat in the atmosphere. The methane can be flared, producing mainly carbon dioxide or used in combustion devices to generate heat or power that can be used for productive purposes displacing the use of fossil fuels.

Relevant General Plan Policies.

Policy PU‐9‐a New Techniques. Continue to collaborate affected stakeholders and partners to identify and support programs and new techniques of solid waste disposal, such as recycling, composting, waste to energy technology, and waste separation, to reduce the volume and toxicity of solid wastes that must be sent to landfill facilities.

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.

Policy RC‐11‐a Waste Reduction Strategies. Maintain current targets for recycling and re‐use of all types of waste material in the city and enhance waste and wastewater management practices to reduce natural resource consumption, including the following measures:
• Continue to require recyclable material collection and storage areas in all residential development.

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C ITY OF F RESNO GHG REDUCTION PLAN UPDATE
F RESNO , C ALIFORNIA MARCH 2020
P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 5-20 • Establish recycling collection and storage area standards for commercial and industrial facilities to size the recycling areas according to the anticipated types and amounts of recyclable material generated.
• Provide educational materials to residents on how and what to recycle and how to dispose of hazardous waste.
• Provide recycling canisters and collection in public areas where trash cans are also provided.
• Institute a program to evaluate major waste generators and identify recycling opportunities for their facilities and operations. • Continue to partner with the California Integrated Waste Management Board on waste diversion and recycling programs and the CalMax (California Materials Exchange) program.
• Evaluate the feasibility of a residential, restaurant and institutional food waste segregation and recycling program, to reduce the amount of organic material sent to landfill and minimize the emissions generated by decomposing organic material.
• Evaluate the feasibility of “carbon footprinting” for the City’s wastewater treatment facilities, biomass and composting operations, solid waste collection and recycling programs.
• Expand yard waste collection to divert compostable waste from landfills. • Study the feasibility and cost‐benefit analysis of a municipal composting program to collect and compost food and yard waste, including institutional food and yard waste, using the resulting compost matter for City park and median maintenance.

Policy RC‐11‐b Zero Waste Strategy. Create a strategic and operations plan for fulfilling the City Council resolution committing the City to a Zero Waste goal.

Policy RC‐4‐i Methane Capture. Continue to pursue opportunities to reduce air pollution by using methane gas from the old City landfill and the City’s wastewater treatment process.

Key GHG Plan Indicators.
• Progress reports on achieving State mandated waste reduction and diversion goals. • Adoption of commercial and industrial recycling area and storage standards. • Adoption of the Zero Waste Strategy.

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5.1.6.2 Wastewater
Wastewater treatment can produce methane
emissions that are a powerful greenhouse gas,
but it also provides a valuable renewable energy
source when scrubbed of harmful components.

Fresno currently operates a major regional
secondary treatment plant and reuses water
primarily for agricultural purposes. The City has
one tertiary treatment facility at the Copper
River development in north Fresno that provides
water for a golf course and shared landscaped
areas. Tertiary treatment of wastewater can allow its use for safely watering landscaped areas such as highway medians, parks, and golf courses using so‐called “purple pipe” systems. Tertiary treatment systems can use substantial amounts of energy, so energy savings from less water pumping must be balanced with the energy costs of treating the water and pumping to where it is used. Wastewater treatment plants such as the Fresno/Clovis Regional Wastewater Reclamation Facility (RWRF) with anaerobic digesters capture the methane produced during the treatment process for productive use such as generation of electricity or process heat to offset some of the plant’s power consumption.

Relevant General Plan Policies.

Objective PU‐7 Promote reduction in wastewater flows and develop facilities for beneficial reuse of reclaimed water and biosolids for management and distribution of treated wastewater.

Policy PU‐7‐a Reduce Wastewater. Identify and consider implementing water conservation standards and other programs and policies, as determined appropriate, to reduce wastewater flows.

Policy PU‐7‐d Wastewater Recycling. 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.

Key GHG Plan Indicators.
• Progress in adopting wastewater reduction programs.
• Feasibility studies regarding future tertiary treatment/recycling options.

5.1.6.3 Community Involvement and Outreach
Many of the strategies listed above will be more effective if there is community involvement and outreach to engage the citizens. This strategy requires public awareness of the measures available for them to take effective action at reducing their energy use and carbon footprint.

Fresno/Clovis RWRF
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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 5-22 Measures and programs that reduce greenhouse gas emissions are often operated at the regional level. Many modes of transportation operate at the regional level, because people travel throughout the region. Regional cooperation provides a venue for sharing knowledge and resources to help address a variety of issues, including climate change and greenhouse gas emissions.

Relevant General Plan Policies.

Policy RC‐7‐g Educate on State Requirements. Educate the residents and businesses of Fresno on the requirements of the California Water Conservation Act of 2009.

Policy RC‐8‐h Solar Assistance. Identify and publicize information about financial mechanisms for private solar installations and provide over‐the‐counter permitting for solar installations meeting specified standards, which may include maximum size (in kV) of units that can be so approved.

Policy RC‐8‐k Energy Efficiency Education. Provide long‐term and ongoing education of homeowners and businesses as to the value of energy efficiency and the need to upgrade existing structures on the regular basis as technology improves and structures age.

Key GHG Plan Indicators.
• Progress reports on education and outreach programs.
• Number of solar panel installation permits issued.

5.1.7 Municipal Strategies
The City of Fresno has a comprehensive set of strategies specifically targeted at greenhouse gas emissions generated at City‐owned facilities and from City operations. The strategies identified by the City include the following measures intended to improve energy efficiency in buildings and equipment owned by the City, alternative fuels for City vehicles and equipment, and water conservation:
• Improve energy efficiency in City operations.
• New City buildings exceed Title 24 energy efficiency standards. • Install renewable energy systems on City facilities.
• City operated transportation demand management for City employees. • Purchase green vehicles for City fleets.
• Enhance reduction, recycling, and reuse efforts at City facilities. • Implement water efficient landscaping in city parks and facilities.

Relevant General Plan Policies.

Policy RC‐7‐c Best Practices for Conservation. Require all City facilities and all new private development to follow U.S. Bureau of Reclamation Best Management Practices for water conservation, as warranted and appropriate.

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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 5-23 Policy RC‐7‐e Retrofit City Facilities, and Consider Incentives Programs to Encourage Retrofitting of Other Existing Public and Private Residential and NonResidential Facilities and Sites. Reduce water use in municipal buildings and City operations by developing a schedule and budget for the retrofit of existing municipal buildings with water conservation features, such as auto shut‐off faucets and water saving irrigation systems. Prepare a comprehensive incentive program for other existing public and private residential and non‐residential buildings and irrigation systems.

Policy RC‐8‐f City Heating and Cooling. Reduce energy use at City facilities by updating heating and cooling equipment and installing “smart lighting” where feasible and economically viable.

Policy RC‐8‐g Revolving Energy Fund. Create a City Energy Fund which uses first year savings and rebates from completed City‐owned energy efficiency projects to provide resources for additional energy projects. Dedicate this revolving fund to the sole use of energy efficiency projects that will pay back into the fund.

Key GHG Plan Indicators.
• Progress reports from responsible departments on conservation efforts. • Progress on creating a City Energy Fund.
• Identification and recognition of major individual conservation projects.

5.1.7.2 Regional Urban Forestry Program
Trees provide shade that can reduce the urban heat island effect caused when pavement and other open surfaces absorb solar radiation and re‐radiate heat to the surrounding environment. The shade can reduce energy required for cooling. Trees also store carbon as they grow, in a process referred to as sequestration. Emission reductions from urban forestry projects must consider the life cycle emissions such as tree maintenance and the ultimate disposition of trees at the end of their lives to ensure that they produce a net decrease in greenhouse gas emissions.

The City maintains trees in parks and other publicly owned landscaped areas. These areas may provide an opportunity for new tree planting or replacement of tree species that possess a low potential to store carbon, with tree species that possess higher carbon storage potential. Guidance for managing urban forests is available from a number of sources. The Climate Action Reserve, Urban Forest Project Reporting Protocol (CAR 2019) provides criteria for generating greenhouse gas emission offsets with tree planting along with procedures for project monitoring. ICLEI’s Urban Forestry Toolkit for Local Governments provides a series of fact sheets and case studies that communities can use to design an effective urban forestry program (ICLEI 2006).

Relevant General Plan Policies.

Policy POSS‐1‐g Regional Urban Forest. Maintain and implement incrementally, through new development projects, additions to Fresno’s regional urban forest to delineate B3 Attach #1 of 3

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Key GHG Plan Indicators.
• Track change in urban tree cover over time.

5.1.7.3 Other Municipal Strategies
Energy Savings from Traffic and Street Lighting. The City plans to replace lighting fixtures with more efficient LED or other technology whenever possible. According to a report prepared by PG&E, Phase II LED luminaires provided power savings of 36 percent compared with high‐pressure sodium luminaires, and the newer Phase III LED luminaires provided 52 percent savings (PG&E 2008).

Low‐Emission City Fleet Vehicles. The City operates vehicles used by the FAX bus fleet, the Solid Waste Division, the Police Department and for maintenance and other purposes. The City has already converted all buses to compressed natural gas (CNG). FAX currently operates 110 alternatively fueled CNG buses. In 2014, the CARB approved a regulation setting a Statewide goal for public transit agencies to transition to 100 percent zero-emission bus fleets by 2040, and requiring that all new bus procurements be carbon-free by 2029. FAX’s most recent bus order included two Proterra all-electric battery 40-foot buses, anticipated to arrive in mid-2020 with an additional order of seven scheduled for revenue service in 2020. Through these investments, FAX continues to showcase its commitment to cleaner vehicles and a cleaner environment.

Green Purchasing. The City makes purchases typical for city government operations such as vehicles, computers, paper, and materials required to maintain the City’s infrastructure. The City’s compressed natural gas (CNG) fleet vehicles provide good examples of its past green purchasing practices.

Municipal Water Conservation. The City has implemented water saving measures at most public parks, and other landscaped areas maintained by the City. The General Plan Policies listed in the Water Conservation Strategies section apply to municipally operated facilities.

5.1.8 Strategies for Existing Development
The GHG Plan Update strategies described above are implemented in two ways. New development projects would be constructed consistent with the General Plan and GHG Plan Update. Existing residents and businesses would comply with regulations that apply to everyone and participate in new and existing programs and measures. People living in existing residential development also share the benefits of the land use strategies applied at work places and commercial areas that are walkable and transit oriented. The strategies that apply directly and indirectly to existing development are shown in Table 5-B.

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Strategy How it Applies
Transportation Demand
Management (TDM)
TDM is implemented at existing and new businesses and can also reduce trips from new and existing housing where employees live.

Expanded Transit Service Improved transit service will encourage increased ridership from new and existing development.

Improved Connections to Transit
Stations
Transit stations service a wider community area that includes connections to new and existing development through sidewalks and bike lanes.

Traffic Calming Retrofits Traffic calming designs can be retrofitted on existing roads or built in new development.

Complete Streets Program Complete streets connect existing and new areas.

Parking Management Parking management at new and existing employment centers encourages trip reductions from all residential development
Energy Retrofits Educational and incentive programs encourage existing residents and business owners to install energy retrofits providing large benefits in older structures.

Bicycle and Pedestrian Improvements
on Existing Roads and near transit
stations
Bicycle paths and lanes can be retrofitted on existing roads, near transit stations. Sidewalks and pedestrian paths can connect existing neighborhoods with appropriate destinations including transit stations.

Bicycle Parking Facilities Bicycle parking can be added to existing businesses if needed to satisfy demand by employees and customers.

Water Conservation Programs Educational and incentive programs encourage existing residents and businesses to conserve water.

Recycled Water Use in Existing Parks Recycled water can be piped to any area retrofitted or initially developed with a “purple pipe” system to distribute recycled water.

Energy Retrofits Educational and incentive programs encourage existing residents and business owners to install energy retrofits providing large benefits in older structures.

Bicycle Parking Facilities Bicycle parking can be added to existing businesses if needed to satisfy demand by employees and customers.

Recycling Programs Operational programs such as recycling apply to all residents and businesses in the city.

Electric Vehicle Charging Charging stations can be installed in existing development as a retrofit or in new development.

Measures That Apply to New Development but Indirectly Benefit Existing Development Transit and Pedestrian Oriented
Development
Transit and pedestrian oriented development provides destinations that encourage transit use from existing development and walking once people arrive.

Mixed Use Development Mixed‐use development creates a more walkable environment conducive to transit use for trips from existing development.

Compact Development Making the city more compact shortens average trip lengths for residents and creates more opportunities for transit.

Traffic Flow Improvements Transportation improvements that reduce congestion and improve flow can reduce emissions from both existing and new development.

Recycling Programs Operational programs such as recycling apply to all residents and businesses in the city.

Electric Vehicle Charging Charging stations can be installed in existing development as a retrofit or in new development.

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5.2 REDUCTION POTENTIAL FROM LOCAL MEASURES
Reductions beyond State regulations will be achieved through the development of the land use pattern and transportation system envisioned by the General Plan, enforcement of City ordinances and design standards, and direct reductions from energy conservation projects, and alternative fuels use.

The effectiveness of the GHG land use strategy is dependent on several factors. The first factor is the rate of population growth. Rapid population growth has two contradictory effects. First, the overall growth in emissions will increase substantially in high growth areas; however, the per capita emissions in high growth areas will be lower. This is because a larger percentage of the population will live in areas of the city with energy efficient homes and businesses, and better transportation options than the slow growing or built out counterparts. On a citywide basis, faster‐growing cities will build out neighborhoods and shopping centers more rapidly, providing more work and shopping opportunities close to home and shorter travel distances.

The second factor is economic. The type and scale of development projects will vary depending on market forces and the state of the economy in future years. Market forces affect the amount of single‐family development compared to multi-family development. A vibrant economy will tend to create more jobs and increase in migration.

The amount of trips and miles traveled varies substantially between highly urban areas and suburban and rural areas. Frequent bus, light rail, or commuter train service requires high development densities to provide adequate ridership to support the service. The reductions that can be achieved by pedestrian orientated development and transit oriented development vary widely based the density and design at both ends of the trip.

5.2.1 Mobile Source Reductions

5.2.1.1 Land Use Strategy
SB 375 required the CARB to set regional targets for reductions from light duty passenger vehicle emission. After a lengthy review process and input from the regional transportation planning agencies, the CARB adopted a Fresno County target reduction in passenger vehicle CO2e per capita of 4.7 percent by 2020 and 7.6 percent by 2035. The key strategies envisioned include:
• Combination of density increase, mixed uses, and infill • Growth along major transit corridors and activity centers The land use strategies are expected to reduce trip generation and vehicle miles traveled to achieve the percentage reductions based on modeling results from the regional transportation model for the General Plan land use scenario. The City of Fresno is participating in the SB 375 SCS process to more closely define the growth areas that would be part of the SCS and qualify for CEQA streamlining provisions.

Emission reductions at the individual project level would be substantially larger than the amounts estimated for as the overall reduction for SB 375 compliance. CAPCOA estimates that land use and B3 Attach #1 of 3
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5.2.1.2 Transportation Demand Management
The General Plan encourages transportation demand management (TDM) at projects that are large employers. The SJVAPCD Rule 9410 – Employer Trip Reduction would provide at 1.6 percent emission reduction in 2020 and 2035 through reduced trips and vehicle miles traveled.

The land use strategy and transportation demand management would provide a combined 45,184 MT CO2e/year in emission reductions by 2020, a 66,191 MT CO2e/year reduction by 2030, and a 80,114 MT CO2e/year reduction by 2035. The assumptions used for these calculations are based on the 2014 GHG Plan with the adoption of General Plan land use strategy and compliance with SJVAPCD Rule 9410.

5.2.1.3 Implement Support for Electric Vehicles
Hybrid EVs, plug-in hybrid EVs, and all-EVs produce lower emissions than conventional vehicles. Any type of electrified vehicle emits less GHG than conventional vehicles by at least 40 percent. The City could promote EVs by establishing EV incentive programs, installing EV chargers within residential units and commercial building parking lots and providing streamlined permitting ordinance for EV charging stations. Based upon the historic trends in EV ownership and the CARB Zero-Emission Vehicles (ZEV) Action Plan, it is assumed that by 2030 EV ownership in the city would reach 8.7 percent, and by 2035, 13 percent of the vehicle trips would be made by EVs.

CALGreen, the State green building code (California Code of Regulations [CCR], Title 24, Part 11), sets requirements for installing EV-capable infrastructure in new residential and nonresidential buildings. CALGreen contains minimum requirements that apply statewide as well as reach codes that can be adopted by local governments. Starting January 1, 2020, CALGreen requires that new construction of single-family residences, duplexes, and townhouses with private garages must have raceway and panel capacity to support the future installation of level 2 charging stations (CEC 2019, ICC 2019). The City supports increased EVs within the city by encouraging the installation of EV chargers within new and existing multi-family residential and commercial parking areas within the city.

5.2.1.4 Implementation Support for Zero Emission Buses
To implement the State of California’s Innovative Clean Transit regulation10 of 100 percent zeroemission buses by 2040 (CARB 2019), FAX needs regulatory and financial support to determine the 10 To transition successfully to an all zero-emission bus fleet by 2040, each transit agency will submit a rollout plan under the regulation demonstrating how it plans to purchase clean buses, build out necessary infrastructure and train the required workforce. The rollout plans are due in 2020 for large transit agencies and in 2023 for small agencies. Agencies will then follow a phased schedule from 2023 until 2029, by which date 100 percent of annual new bus purchases will be zero-emission.

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• Traditional financing methods, such as municipal bonds and local option transportation taxes to finance the purchase and/or operation of new ZEBs.
• Collaboration with local utilities to obtain beneficial rate structures to reduce charging costs and work with utilities to secure charging infrastructure investments. • Federal, State, regional, and local grant and incentive programs to reduce the initial purchase price of ZEBs.

In addition to funding, building the infrastructure necessary to deploy the ZEBs, and procuring electricity, hydrogen, or other alternative fuel sources to operate them pose challenges for FAX that will require innovative approaches and best practices to operate a full fleet of ZEBs in the City by 2040. FAX is currently working on its rollout plan to meet all requirements by 2040.

5.2.2 Energy Efficiency Reductions

5.2.2.1 Building Energy Efficiency
The City supports the State’s efforts to achieve net zero energy consumption in new residential and non‐residential buildings. Achieving net zero is currently possible in some buildings with the use of onsite solar to offset the electricity consumption from the grid. The 2019 Title 24 standards that will go into effect in January 2020 are substantially more stringent than the 2016 Title 24 standards and focus on achieving zero net energy homes.

The City encourages developers to achieve the voluntary tier levels from the CPUC Energy Efficiency Strategic Plan, which ultimately lead to net zero energy consumption for residential development by 2020 and non‐residential development by 2030. GHG emission reductions from net zero energy homes have been accounted for under State regulations in Chapter 4 as the 2019 Title 24 standards include this requirement. By achieving net zero energy consumption for non-residential development by 2030, the City would reduce GHG emissions by 70,230 MT CO2e/year by 2030, and 100,237 MT CO2e/year by 2035. Once Title 24 mandates net zero energy consumption, no further reductions beyond regulation can be achieved by projects.

5.2.3 Water Conservation
The California Water Conservation Act mandates a 20 percent reduction in water usage by 2020.

The City has a reduction target of per capita water usage in the City’s water service area to 230 gallons per day per capita (25 percent below the current consumption rate) in 2035. The City will meet the reduction target with measures applicable to new and existing development. Reductions beyond the state mandated 20 percent are possible with the use of building and landscaping water conservation features. The reductions from buildings can be achieved with high‐efficiency toilets, low‐flow showers and faucets, and water‐efficient appliances such as clothes washers and dishwashers. Water savings from landscaping would be achieved primarily through the use of synthetic (‘turf’) lawns, drought‐tolerant landscaping or xeriscaping. The City is also proposing B3 Attach #1 of 3
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Indoor Water Conservation Measures.
• Hot Water Pipe Insulation: Insulate hot‐water pipes, and separation of hot and cold piping to avoid heat exchange. Water savings: 2,400 gallons per residential unit per year. Cost: $50/unit. • Pressure Reducing Valves. Pressure reducing valves maintain pressure below 60 psi reducing volume of any leakage present and preventing excessive flow from all appliances and fixtures.

Water savings: 30,000 gallons approximately per residential unit per year. Cost: $100-$150 per unit11.
• Water‐Efficient Dishwashers. Install Energy Star‐certified units. Water savings: 5000 gallons per residential unit per year12.
• Dual Flush Toilets: Provides option to flush with partial (0.8 gallon) flow of water or with a full (1.6 gallons) flow depending on need. Water savings: 13,000 gallons per year per toilet13. Cost:
$200 per toilet; however, retrofit kits are available for under $20. • High‐Efficiency Washing Machines: Use front loading and top loading Energy Star‐qualified clothes washers that use 35 to 50 percent less water than conventional washing machines.

Water savings: 7,000 gallons per year14. Cost: $800 for a high‐efficiency washing machine. • Point‐of‐Use or Tankless Water Heaters: Install small water heaters close to the point of use, such as bathrooms, kitchen, and laundry area. Water savings: 5,300 gallons per residential unit per year15. Cost: $700 for point of use water heaters. However, the cost is approximately the same for one large unit or three smaller ones.

Outdoor Water Conservation Measures.
• Evapotranspiration (ET) Controllers: Irrigation scheduled by actual plant ET rates. Water savings: 20,000 gallons per single‐family unit per year. Cost: $175 per controller and $48 per year in maintenance.
11 Water Pressure Reducing Valves: Frequently Asked Questions. Website: www.watts.com/resources/ references-tools/waterpressurereducingvalvesfaq (accessed August 10, 2019). 12 Energy Star Appliances: Dishwashers Vs. Handwashing Dishes. Website: www.energystar.gov/products/ appliances/dishwashers/dishwasher_hand_washing (accessed August 10, 2019). 13 Energy Efficient Toilets Comparison: Constellation Energy. Website: www.blog.constellation.com/2017/ 09/25/energy-efficient-toilets-comparison/ (accessed August 10, 2019). 14 Energy Star High Efficiency Clothes Washers. Website: www.energystar.gov/products/appliances/ clothes_washers (accessed August 10, 2019). 15 Energy Star Point of Contact Heaters. Website: www.energystar.gov/products/water_heaters/ point_use_pou_water_heaters (accessed August 10, 2019).

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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) 5-30 • Water‐Efficient Landscaping: Use drought tolerant plants and compliant irrigation systems and controllers. Water Savings: Up to 50 percent of outdoor use (12,000 gallons/year from a 2,100‐ square foot landscaped area. Cost: similar to conventional landscaping. • Xeriscape: Xeriscaping is a combination of seven principles, planning and design, practical turf areas, efficient irrigation, soil analysis and improvement, mulching, low‐water‐use plants, and appropriate maintenance. Water savings: 30 percent reduction in irrigation demand or about 16,000 gallons per year on a typical single‐family lot. Cost: similar to conventional landscaping.

Estimates of water savings and costs are from the City of Chula Vista Water Conservation Plan Guidelines adopted in 2003.

5.2.3.2 Energy Savings from Water Conservation
The combined benefits of indoor and outdoor water conservation program are estimated at 20 percent in 2020 to achieve compliance with state‐mandated reductions and 25 percent by 2035 to meet the General Plan target, which are consistent with the assumptions in 2014 GHG Plan.

Reductions in water use reduce electricity consumed for pumping, treatment, and transport of water by proportional amounts. Reductions in water use by these amounts would provide emission reductions of 5,975 MT CO2e/year by 2020 and 8,891 MT CO2e/year by 2035. Assuming a constant reduction rate, the emission reductions in 2030 would be 7,840 MT CO2e/year.

5.2.4 Waste Diversion and Recycling Reductions
The City of Fresno will meet or exceed the state‐mandated 75 percent diversion target in the future.

The CARB estimates that statewide reductions of 20 to 30 MMT CO2e will be achieved through this strategy. The City of Fresno has achieved substantial progress to date. The city per capita baseline based on the 2002 to 2004 average is 6.6 pounds per day per person. The 2018 per capita rate was

4.8 pounds per day per person, which was assumed to be consistent through 2020. The 75 percent diversion target would require a per capita rate of 1.65 pounds per person per day. Achieving net zero waste would provide additional reductions from this sector; however, no reductions are estimated pending adoption of a state mandate. The estimated emission reductions from achieving the 75 percent mandated diversion target are 84,677 MT CO2e/year in 2030, and 90,043 MT CO2e/year in 2035.

5.2.5 Summary of Reductions from Local Measures
Table 5-C summarizes the local reductions from the measures described above.

Table 5-D summarizes the baseline 2010 and updated 2016 GHG emissions, the projected 2020, 2030, and 2035 emission inventories, as well as the reduced 2020, 2030, and 2035 inventories after implementation of the State and local reduction measures.

By 2020, the Statewide and local measures together would reduce the city’s GHG emissions from the 2020 BAU level to 2,081,167MT CO2e, which would exceed the 15 percent below baseline levels reduction target of 3,183,348 MT CO2e for 2020. By 2030, the Statewide and local measures together would reduce emissions to 1,710,386 MT CO2e, which would exceed the 49 percent below B3 Attach #1 of 3
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Sector Local Measures
Emissions Reductions (MT
CO2e/year)
2020 2030 2035
Transportation Land Use Strategy and Transportation Demand Management 45,184 66,191 80,114
Commercial Energy Net Zero Energy Commercial Building - 70,230 100,237 Industrial Energy (Water) Water Conservation 5,975 7,840 8,981 Solid Waste Waste Diversion and Recycling - 84,677 90,043 Total 51,159 228,938 279,375
Source: Compiled by LSA Associates, Inc. (2019).

Table 5-D: GHG Emissions and Targets Comparison
2010
(MT CO2e)1
2016
(MT CO2e)
2020
(MT CO2e)
2030
(MT CO2e)
2035
(MT CO2e)
BAU Emissions 3,745,115 2,923,633 3,092,486 3,500,204 3,697,738 State Reductions - - 960,160 1,560,880 1,896,602
ABAU Emissions 3,745,115 2,923,633 2,132,326 1,939,325 1,801,137 Local Measures Reductions - - 51,159 228,938 279,375
Total Adjusted Emissions - - 2,081,167 1,710,386 1,521,761 Reduction Target - - 3,183,348 1,910,009 1,591,674
Additional Reductions Needed - - Target Met Target Met Target Met Source: Compiled by LSA Associates, Inc. (2019).
1 Baseline (2010) emissions are from the City’s 2014 GHG Reduction Plan.

GHG = greenhouse gas
ABAU = Adjusted Business-as-Usual
BAU = Business-as-Usual
MT CO2e = metric tons of carbon dioxide equivalent
baseline levels reduction target of 1,910,009 MT CO2e for 2030. In 2035, implementation of Statewide and local measures together would reduce emissions from the 2035 BAU level to 1,521,761 MT CO2e, which would exceed the 58 percent below baseline levels reduction target of 1,591,674 MT CO2e for 2035.

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6.0 DEVELOPMENT PROJECT REQUIREMENTS
This section describes the actions that individual development projects would be required to implement in order to qualify for California Environmental Quality Act (CEQA streamlining) and to demonstrate that the project would not result in significant GHG impacts. Projects that have completed all environmental review prior to adoption of the GHG Plan Update must comply with regulations in effect at the time of construction and with conditions of approval that were required during review of the tract map, development permit, or conditional use permit approved by the City. This means that all development will help meet the City’s GHG reduction targets.

6.1 PROJECTS EXEMPT FROM CEQA
Projects that have already completed the CEQA process and only require building permits have no requirements beyond applicable regulations such as the California Building Code, Title 24 Energy Efficiency Standards, the City Development Code, and other City Ordinances.

6.1.1 City Development Code
Consult the Development Code for requirements for each type of project. Examples include:
• Street Design (complete streets and bus stops) (applies if project involves street improvements) • Pedestrian Improvements (sidewalks, paths, connections, etc.) • Bicycle Lanes and Paths (consistent with the Active Transportation Plan) • Bicycle Parking (Commercial)
• Enforce Building Code Requirements (Green Building Code)

6.1.2 State Regulations
Project buildings must meet the California Energy Code and the California Green Building Standard Code.

6.2 PROJECTS REQUIRING A DISCRETIONARY APPROVAL
Projects requiring a discretionary approval from the City must comply with CEQA provisions related to GHG emissions. Projects that are consistent with the GHG Plan Update by demonstrating consistency with the GHG Plan Update Consistency Checklist (checklist) are considered CEQA‐compliant for GHG impacts. The following review process is proposed:

6.2.1 New Discretionary Development Approval Process to Determine Consistency with GHG Reduction Plan Update

1. Review the GHG Reduction Plan Project Update CEQA Consistency Checklist (Appendix B) that lists the local GHG reduction strategies identified in the GHG Plan Update to determine applicability to the project.

2. Incorporate design features or mitigation measures into the project as needed to demonstrate consistency.

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3. Implement project design features suitable for the development type and location.

Proposed development projects that are consistent with the GHG Plan Update as determined through the use GHG Plan Update CEQA Consistency Checklist may rely on the GHG Plan Update for the cumulative impacts analysis of GHG emissions. Projects that are not consistent with the GHG Plan Update must prepare a comprehensive project-specific analysis of GHG emissions, including quantification of existing and projected GHG emissions and apply appropriate GHG reduction mitigation measures based on the GHG reduction strategies identified in the GHG Plan Update and listed in the checklist.

6.2.2 New Discretionary Development requiring a General Plan Amendment

1. Comply with all of the applicable measures listed above for ministerial and discretionary projects.

2. Ensure that change in land use designation would not result in a significant increase in GHG emissions compared to the existing designation (would require a GHG technical study to quantify GHG emissions and benefits of project design features).

3. Projects currently designated for residential or commercial development that increase development densities and intensities and comply with the relevant GHG reduction strategies in the General Plan, or provide quantified GHG emission reduction calculations which demonstrates that the project would mitigate the cumulative GHG emissions, are considered to have a less than significant GHG impact.

4. Emissions from stationary sources for new industrial projects are not considered in the significance determination; however, emissions from motor vehicles trips generated by the project and energy efficiency of the building are considered.

5. Projects that propose decreases in development densities or intensities requiring a General Plan amendment will require analysis of GHG emissions to determine the impacts on the General Plan land use strategy and must identify mitigation measures to reduce greenhouse gas emissions beyond those required by regulation if needed.

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7.0 GHG PLAN UPDATE IMPLEMENTATION MONITORING
This chapter describes the steps for implementing the GHG Plan Update to support achievement of GHG reduction goals for the community at large. Success in meeting the City’s GHG emission reduction goals will depend on cooperation, innovation, and participation by the City, residents, businesses, and local government entities. This section outlines key steps that the City could follow for the implementation of this GHG Plan Update. The GHG Plan Update is designed so that it can be monitored, updated, and its effectiveness measured on an annual basis towards meeting a target for reduction of greenhouse gas emissions in 2020 and 2030 to measure further progress through horizon of the General Plan in 2035. The reporting required for the General Plan provides a good venue for monitoring the GHG Plan. California Government Code Section 65400 requires the City to prepare and submit an annual report on the status of the General Plan and progress in its implementation to the City Council, the Governor’s Office of Planning and Research, and the Department of Housing and Community Development. This section provides a guide the City could use to implement the GHG Plan.

7.1 GHG PLAN UPDATE IMPLEMENTATION
Successful implementation of the GHG Plan Update will require implementation and monitoring which could incorporate the following components, which are described in more detail in the sections below:
• Administration and staffing;
• Financing and budgeting;
• Timelines for GHG reduction strategies implementation; • Community outreach and education; and
• Monitoring, reporting, and adaptive management.

These are basic steps that any City might take or that other California communities have taken to implement a GHG reduction plan. These are suggested—not required—and are intended to guide a City in its implementation planning.

7.1.1 Administration and Staffing
Implementation of the GHG Plan Update will involve coordination with other regional agencies. The City may designate staff to oversee the successful implementation and the tracking of all selected GHG reduction strategies. The City could coordinate with contacts across departments to gather data, to report on progress, to track completed projects, and to ensure that scheduling and funding of upcoming projects is discussed at key City meetings. The City may identify one or more staff to act as the Plan Implementation Administrator(s) to guide monitoring, reporting, and dissemination of information to the public. Where possible, the City may use assistants from programs such as CivicSpark, an AmeriCorps program designed to build capacity for local governments to address climate change.

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• Serve as the external communication hub to local and regional agencies in coordinating the implementation of the GHG Reduction Plan
• Investigate methods to use existing resources and harness community support to better streamline implementation of the Plan
• Monitor implementation of reduction strategies and success of the GHG Plan Update • Establish guidelines for reporting and documenting emission-reduction progress. • Track State and federal legislation and its applicability to the City In general, the goal in implementing the GHG Plan Update is not to create new administrative tasks or new staff positions necessarily, but rather to leverage existing programs and staff to the maximum extent feasible. Cities may seek to fold GHG planning and long-term reduction into their existing procedures, institutional organization, reporting, and long-term planning.

7.1.2 Financing and Budgeting
Implementation of the local GHG reduction strategies may require investment for the capital improvements and other investments, and increased operations and maintenance costs. However, in some cases operating costs are anticipated to decrease, resulting in offset savings. Table C-1 in Appendix C, Potential Funding Sources to Support GHG Reduction Strategies, presents a summary of potential funding and financing options available at the time of writing this document. Some funding sources are not necessarily directed towards a city, but to a larger regional agency such as the SJVAPCD. The City could monitor private and public funding sources for new grant and rebate opportunities and to better understand how larger agencies are accessing funds that can be used for GHG reductions in their areas. Leveraging financing sources is one of the most important roles a local government can play in helping the community to implement many of the GHG reduction strategies. A study commissioned by the City,
16 Energize Fresno Funding Market Study, March 2017,
provides a detailed analysis of potential funding mechanisms that could also support the implementation of the GHG reduction strategies identified in the GHG Plan Update.

7.1.3 Timelines for GHG reduction strategies Implementation After taking into account the reductions in energy and water usage and the GHG emissions resulting from statewide measures, presently it would appear that without future State action the City would need to implement the local reduction strategies to reach its reduction targets for 2035. The City could prioritize the implementation of GHG reduction strategies based on following criteria:
• Cost effectiveness
• GHG reduction efficiency
• Availability of funding
• Level of City Control
16 Energize Fresno Funding Market Study. 2017. Website: www.lgc.org/wordpress/wpcontent/uploads/2018/02/Energize-Fresno-Funding-Market-Study.pdf (accessed August 14, 2019).

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• Time to implement
To encourage implementation of all reduction strategies, City staff could develop a GHG Plan Update Implementation Timeline. GHG reduction Strategy prioritization could be based on the factors shown in Appendix C.

7.2 MONITORING THE GHG PLAN UPDATE
Regular monitoring is important to ensure programs function as they were originally intended. Early identification of effective strategies and potential issues would enable the City to make informed decisions on future priorities, funding, and scheduling. Moreover, monitoring provides concrete data to document the City’s progress in reducing GHG emissions. The City would be responsible for developing a protocol for monitoring the effectiveness of emission reduction programs as well as for undertaking emission inventory updates. Below are some of the key components of a GHG Plan monitoring program.
• Update GHG Inventory: The City could update the inventory emissions prior to 2030 to ensure they meet their GHG reduction goals. This includes regular data collection in each of the primary inventory sectors (utility, regional VMT, waste, wastewater, and water), and comparing the inventory to the City’s baseline GHG emissions in 2010 and 2016. The City would consolidate information in a database or spreadsheet that could be used to evaluate the effectiveness of individual reduction strategies.
• Track State Progress: The GHG Plan Update relies heavily on Statewide measures. The City should track the State’s progress on implementing Statewide programs. Close monitoring of the reductions achieved by State programs would allow the City to adjust its GHG Plan Update, if needed.
• Track Completion of GHG Reduction Strategies: The City could keep track of strategies implemented as scheduled in the GHG Plan Update, including progress reports on each strategy, funding, and savings. This would allow at least a rough attribution of gains when combined with regular GHG inventory updates.
• Regular Progress Reports: The City may report on the GHG Plan Update implementation progress annually to the City Council as a part of the annual report on progress in implementing General Plan. If annual reports, periodic inventories, or other information indicates that the GHG reduction strategies are not as effective as originally anticipated, the GHG Plan Update may need to be adjusted, amended, or supplemented.

7.3 GHG PLAN UPDATE TRACKING TOOL
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The City is currently using an online Accela-based system to track permit applications for development projects. This permit tracking system could be transformed into a GHG reduction monitoring tool, where the City would be able to track GHG reductions achieved through implementation of the GHG reduction strategies within the GHG Plan Update. This would help the City to monitor the GHG Plan Update’s implementation progress without added administrative burden, and to share findings with stakeholders, partners, and the community.

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8.0 REFERENCES
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California Air Resources Board (CARB). 2008. Scoping Plan. Website: https://ww3.arb.ca.gov/ cc/scopingplan/document/scopingplandocument.htm (accessed June 21, 2012).

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California Air Resources Board (CARB). 2011. LEV III Staff Report and Initial Statement of Reasons.

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California Air Resources Board (CARB). 2010 Tire Inflation Regulation. Website:
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California Green Building Standards Commission (CGBSC). 2010. California Green Building Standards Code, January 2010.

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California Energy Commission (CEC). 2007. Full Fuel Cycle Assessment: Well-to-Wheels Energy Inputs, Emissions, and Water Impacts. Website: https://ww2.energy.ca.gov/ 2007publications/CEC-600-2007-004/CEC-600-2007-004-REV.PDF.

California Energy Commission (CEC). 2018. California Energy Commission: Tracking Progress.

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California Energy Commission. (CEC) 2019. Building Energy Efficiency Standards for Residential and Non Residential Buildings for the 2019 Building Energy Efficiency Standards, Title 24, Part 6 and Associated Administrative Regulations. Website: https://ww2.energy.ca.gov/ 2018publications/CEC-400-2018-020/CEC-400-2018-020-CMF.pdf (accessed August 8, 2019).

California Natural Resources Agency (CNRA). 2009. California Climate Adaptation Strategy. Website:
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City of Fresno Greenhouse Gas Reduction Plan 2014. Website: https://www.fresno.gov/darm/wpcontent/uploads/sites/10/2016/11/F-2-Greenhouse-Gas-Reduction-Plan.pdf (accessed March-December 2019)
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Constellation. Home Energy Savings: High Efficiency Toilets vs. Regular Toilets. Website:
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Energy Star. Energy Efficient Appliances: Dishwashers Vs. Handwashing Dishes. Website:
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Energy Star. Energy Efficient Clothes Washers. Website: www.energystar.gov/products/ appliances/clothes_washers (accessed August 10, 2019).

Energy Star. Point of Use (POU) Water Heaters. Website: https://www.energystar.gov/products/ water_heaters/point_use_pou_water_heaters (accessed August 10, 2019).

FirstCarbon Solutions. 2014. Fresno General Plan Update, Greenhouse Gas Reduction Plan, prepared for the City of Fresno. July. Website: https://www.fresno.gov/darm/wp-content/uploads/ sites/10/2016/11/F-2-Greenhouse-Gas-Reduction-Plan.pdf (accessed December 2019).

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Fresno, City of. 2011. Working Paper 2: Urban Form and Land Use.

Fresno, City of. 2016. 2015 Urban Water Management Plan. Website: www.fresno.gov/ publicutilities/wp-content/uploads/sites/16/2016/11/CityofFresno2015UWMP_adopted.pdf (accessed February 26, 2019).

Fresno, City of. 2019. General Plan Land Use and Circulation Map. Website:
https://www.fresno.gov/publicworks/wp-content/uploads/sites/17/2017/10/5-City-ofFresno-General-Plan-Land-Use-and-Circulation-Map.pdf (accessed August 11, 2019).

Fresno, City of. Fresno’s Strategy for Achieving Sustainability Website: https://www.fresnocog.org/ project/san-joaquin-valley-blueprint/ (accessed June 15, 2019).

Fresno Council of Governments. 2009. San Joaquin Valley Blueprint, Fresno County Progress Report.

Prepared for Council of Fresno County Governments. Website: www.fresnocog.org/wpcontent/uploads/files/Blueprint/ProgressReport/Fresno%20County%20BP%20 Document%20Revised%20Final%2007_27_09.pdf.

Fresno Council of Governments. 2017. Fresno County 2050 Growth Projections. Prepared for Fresno County Council of Governments. Website: www.fresnocog.org/wp-content/uploads/ publications/Demographics/Fresno_COG_2050_Projections_Final_Report_050417.pdf (accessed March 4, 2019).

Fresno Council of Governments. Sustainable Community Strategy. RTP/SCS 2018. Website:
https://www.fresnocog.org/project/regional-transportation-plan-rtp/ (accessed March 6, 2019).

Governor’s Interagency Working Group on Zero Emission Vehicles. 2018. ZEV Action Plan Priorities Update. Website: http://business.ca.gov/Portals/0/ZEV/2018-ZEV-Action-Plan-PrioritiesUpdate.pdf (accessed on January 7, 2019).

ICLEI. 2006. Talking trees: An Urban Forestry Toolkit for Local Governments. Website:
https://www.milliontreesnyc.org/downloads/pdf/talking_trees_urban_forestry_toolkit.pdf.

Intergovernmental Panel on Climate Change (IPCC). 2007. Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change (Solomon, S., D. Qin, M. Manning, Z. Chen, M.

Marquis, K.B. Averyt, M.Tignor, and H.L. Miller [eds.]). Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. Website: www.ipcc.ch/ publications_and_data/ar4/wg1/en/contents.html (accessed June 23, 2012).

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11. Chapter 4. Residential Mandatory Measures. Website: https://codes.iccsafe.org/ content/CAGBSC2019/chapter-4-residential-mandatory-measures (accessed February 24, 2020).

Local Government Commission. 2017. Energize Fresno Funding Market Study. Website:
www.lgc.org/wordpress/wp-content/uploads/2018/02/Energize-Fresno-Funding-MarketStudy.pdf (accessed August 14, 2019).

National Oceanic and Atmospheric Administration (NOAA). 2019. National Centers for Environmental Information. Website: www.ncdc.noaa.gov/data-access/paleoclimatologydata/datasets/ice-core (accessed, July 6 2019).

Nature. 2018. IPCC Says limiting global warming to 1.5°C will require drastic action. Nature International Journal of Science. 8 October 2018. Website: https://www.nature.com/ articles/d41586-018-06876-2 (accessed, October 10, 2019).

Pacific Gas and Electric (PG&E). 2008. Street Light Replacement Program.

PBL Netherlands Environmental Assessment Agency. 2017. Trends in Global CO2 and Total Greenhouse Gas Emissions: 2017 Report. Website: https://www.pbl.nl/en/ publications/trends-in-global-co2-and-total-greenhouse-gas-emissions-2017-report (accessed December 20, 2019).

Recharge Fresno. 2018. Recycled Water System. Website: http://rechargefresno.wpengine.com/ water-recycling-facilities/ (accessed January 24, 2020) San Joaquin Valley Air Pollution Control District (SJVAPCD 2009). Rule 9410 Employer Based Trip Reduction. Adopted December 17, 2009. Website: https://www.valleyair.org/rules/ currntrules/r9410.pdf (accessed December 2019).

United States Environmental Protection Agency (EPA). 2018. Global Greenhouse Gas Emissions Data.

Website: https://www.epa.gov/ghgemissions/global-greenhouse-gas-emissions-data (accessed October 21, 2019).

Water Pressure Reducing Valves: Frequently Asked Questions. Website: https://www.watts.com/ resources/references-tools/waterpressurereducingvalvesfaq (accessed August 10, 2019).

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APPENDIX A

GENERAL PLAN POLICY LIST
The General Plan is the foundation of the City of Fresno’s strategy to reduce development related greenhouse gas emissions. The City’s land use authority provides its most effective means of limiting the impact of growth predicted for the City. The Greenhouse Gas Reduction Plan (GHG Plan) relates the benefits of the General Plan and the City’s strategy for achieving greenhouse gas (GHG) reduction targets. Table A-1 is a list of General Plan Policies that provide GHG reductions or support GHG Reduction Plan Update (GHG Plan Update) strategies.

Table A-1: General Plan Objectives and Policies
Urban Form Element
Policy UF‐1‐c Identifiable City Structure. Focus integrated and ongoing planning efforts to achieve an identifiable city structure, comprised of a concentration of buildings, people, and pedestrian‐oriented activity in Downtown; along a small number of transit‐oriented, mixed‐use corridors and strategically located Activity Centers; and in existing and new neighborhoods augmented with parks and connected by multi‐purpose trails and tree lined bike lanes and streets.

Objective UF‐12 Locate roughly one‐half of future residential development in infill areas — defined as being within the City on December 31, 2012—including the Downtown core area and surrounding neighborhoods, mixed‐use centers and transit‐oriented development along major BRT corridors, and other non‐corridor infill areas, and vacant land.

Policy UF‐12‐a BRT Corridors. Design land uses and integrate development site plans along BRT corridors, with transit‐oriented development that supports transit ridership and convenient pedestrian access to bus stops and BRT station stops.

Policy UF‐12‐b Activity Centers. Mixed‐use designated areas along BRT and/or transit corridors are appropriate for more intensive concentrations of urban uses. Typical uses could include commercial areas; employment centers; schools; compact residential development; religious institutions; parks; and other gathering points where residents may interact, work, and obtain goods and services in the same place.

Policy UF‐12‐d Appropriate Mixed‐Use. Facilitate the development of vertical and horizontal mixed‐uses to blend residential, commercial, and public land uses on one or adjacent sites. Ensure land use compatibility between mixed‐use districts in Activity Centers and the surrounding residential neighborhoods.

Policy UF‐12‐e Access to Activity Centers. Promote adoption and implementation of standards supporting pedestrian activities and bicycle linkages from surrounding land uses and neighborhoods into Activity Centers and to transit stops. Provide for priority transit routes and facilities to serve the Activity Centers.

Policy UF‐12‐f Mixed‐Use in Activity Centers. Adopt a new Development Code which includes use regulations and standards to allow for mixed uses and shared parking facilities.

Objective UF‐14 Create an urban form to facilitate multi‐modal connectivity.

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.

Policy UF‐14‐b Local Street Connectivity. Design local roadways to connect throughout neighborhoods and large private developments with adjacent major roadways and pathways of existing adjacent development. Create access for pedestrians and bicycles where a local street must dead end or be designed as a cul‐de‐sac to adjoining uses that provide services, shopping, and connecting pathways for access to the greater community area.

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Urban Form Element (Continued)
Policy UF‐14‐c Block Length. Create development standards that provide desired and maximum block lengths in residential, retail, and mixed‐use districts order to enhanced walkability.

Land Use Element
Objective LU‐2 Plan for infill development that includes a range of housing types, building forms, and land uses to meet the needs of both current and future residents.

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 LU‐2‐b Infill Development for Affordable Housing. Establish a priority infill incentive program for residential infill development of existing vacant lots and underutilized sites within the City as a strategy to help to meet the affordable housing needs of the community.

Policy LU‐3‐b Mixed‐Use Urban Corridors that Connect the Downtown Planning Area. Support the development of mixed‐use urban corridors that connect the Downtown Planning Area with the greater Fresno‐Clovis Metropolitan Area with functional, enduring, and desirable urban qualities along the Blackstone Avenue, Shaw Avenue, California Avenue, and Ventura Avenue/Kings Canyon corridors, as shown on Figure LU‐1:

General Plan Land Use Diagram.

Policy LU‐3‐c Zoning for High Density on Major BRT Corridors. Encourage adoption of supportive zoning regulations for compact development along BRT corridors leading to the Downtown Core that will not diminish long‐term growth and development potential for Downtown.

Policy LU‐5‐f High Density Residential Uses. Promote high‐density residential uses to support Activity Centers and BRT corridors, and walkable access to transit stops.

Design Element
Policy D‐3‐c Local Streets as Urban Parkways. Develop local streets as "urban parkways", where appropriate, with landscaping and pedestrian spaces.

Policy D‐4‐b Incentives for Pedestrian‐Oriented Anchor Retail. Consider adopting and implementing incentives for new pedestrian‐friendly anchor retail at intersections within Activity Centers and along corridors to attract retail clientele and maximize foot traffic.

Transportation Element
Policy MT‐1‐h Update Standards for Complete Streets. Update the City’s Engineering and Street Design Standards to ensure that roadway and streetscape design specifications reflect the Complete Streets concept, while also addressing the needs of through traffic, transit stops, bus turnouts, passenger loading needs, bike lanes, pedestrian accommodation, and short‐ and long‐term parking.

Policy MT-1-i Local Street Standards. Establish and implement local roadway standards addressing characteristics such as alignment, width, continuity and traffic calming, to provide efficient neighborhood circulation; to allow convenient access by residents, visitors, and public service and safety providers; and to promote neighborhood integrity and desired quality of life by limiting intrusive pass-through traffic.

Policy MT-1-j Transportation Improvements Consistent with Community Character. Prioritize transportation improvements that are consistent with the character of surrounding neighborhoods and supportive of safe, functional and Complete Neighborhoods; minimize negative impacts upon sensitive land uses such as residences, hospitals, schools, natural habitats, open space areas, and historic and cultural resources.

In implementing this policy, the City will design improvements to:
 Facilitate provision of multi-modal transportation opportunities;  Provide added safety, including appropriate traffic calming measures;  Promote achievement of air quality standards;
 Provide capacity in a cost effective manner; and
 Create improved and equitable access with increased efficiency and connectivity.

Objective MT‐4 Establish and maintain a continuous, safe, and easily accessible bikeways system throughout the metropolitan area to reduce vehicle use, improve air quality and the quality of life, and provide public health benefits.

Policy MT‐4‐a Active Transportation Plan. To the extent consistent with this General Plan, continue to implement and periodically update the Active Transportation Plan to meet State standards and requirements for recommended improvements and funding proposals as determined appropriate and feasible B3 Attach #1 of 3
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Transportation Element (Continued)
Policy MT‐4‐b Bikeway Improvements. Establish and implement property development standards to assure that projects adjacent to designated bikeways provide adequate right‐of‐way and that necessary improvements are constructed to implement the planned bikeway system shown on Figure MT‐2 to provide for bikeways, to the extent feasible, when existing roadways are reconstructed; and alternative bikeway alignments or routes where inadequate right‐of‐way is available Policy MT‐4‐c Bikeway Linkages. Provide linkages between bikeways, trails and paths, and other regional networks such as the San Joaquin River Trail and adjacent jurisdiction bicycle systems wherever possible.

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.

Policy MT‐5‐a Sidewalk Development. Pursue funding and implement standards for development of sidewalks on public streets, with priority given to meeting the needs of persons with physical and vision limitations; providing safe routes to school; completing pedestrian improvements in established neighborhoods with lower vehicle ownership rates; or providing pedestrian access to public transportation routes.

Policy MT-5-e Traffic Management in Established Neighborhoods. Establish acceptable design and improvement standards and provide traffic planning assistance to established neighborhoods to identify practical traffic management and calming methods to enhance the pedestrian environment with costs equitably assigned to properties receiving the benefits or generating excessive vehicle traffic.

Objective MT‐6 Establish a network of multi‐purpose pedestrian and bicycle paths, as well as limited access trails, to link residential areas to local and regional open spaces and recreational areas and urban Activity Centers in order to enhance Fresno's recreational amenities and alternative transportation options.

Policy MT‐6‐a Link Residences to Destinations. Design a pedestrian and bicycle path network that links residential areas with Activity Centers, such as parks and recreational facilities, educational institutions, employment centers, cultural sites, and other focal points of the city environment.

Policy MT‐6‐g Path and Trail Development. Require all projects to incorporate planned multi‐purpose path and trail development standards and corridor linkages consistent with the General Plan, applicable law and case‐by‐case determinations as a condition of project approval.

Objective MT‐8 Provide public transit options that serve existing and future concentrations of residences, employment, recreation and civic uses and are feasible, efficient, safe, and minimize environmental impacts.

Policy MT‐8‐a Street Design Coordinated with Transit. Coordinate the planning, design, and construction of the major roadway network with transit operators to facilitate efficient direct transit routing throughout the Planning Area.

Policy MT‐8‐b Transit Serving Residential and Employment Nodes. Identify the location of current and future residential and employment concentrations and Activity Centers throughout the transit service area in order to facilitate planning and implementation of optimal transit service area in order to facilitate planning and implementation of optimal transit services for these uses. Work with California State University, Fresno to determine locations within the campus core for bus stops.

Policy MT‐8‐g High Speed Train. If the State moves forward with HST, ensure it is constructed through Fresno in a manner that minimizes impacts to surrounding property owners and creates the most opportunity for redevelopment around the HST station.

Objective MT‐9 Provide public transit opportunities to the maximum number and diversity of people practicable in balance with providing service that is high in quality, convenient, frequent, reliable, cost-effective and financially feasible.

Policy MT‐10‐a Updating Parking Standards. Update off‐street parking standards to reflect the context and location within activity areas of multiple uses and reductions appropriate for mixed residential and non‐residential uses and proximity to existing or planned transit service.

Policy MT‐10‐b Shared Parking. Establish a strategy to promote the sharing of excess parking between uses within Activity Centers and BRT corridors, including specific provisions for this in the Development Code.

Policy MT‐10‐c Transportation Demand Management Guidelines. Establish transportation demand management guidelines to allow for reduced off‐street parking requirements.

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Transportation Element (Continued)
Policy MT‐10‐d Parking Maximums. Explore maximum off‐street parking limits within Activity Centers proximate to BRT corridors, if such an Activity Center is determined compatible with promotion of a healthy and vigorous business environment.

Policy MT‐10‐f Parking Benefit Districts. Establish parking benefit districts to fund consolidated public parking where supported by local businesses.

Park and Open Space
Policy POSS‐1‐g Regional Urban Forest. Maintain and implement incrementally, through new development projects, additions to Fresno’s regional urban forest to delineate corridors and the boundaries of urban areas, and to provide tree canopy for bike lanes, sidewalks, parking lots, and trails.

Policy POSS‐7‐h Interlink City and San Joaquin River Parkway Trail Networks. Strive to connect the parkway trail network to other trails in the vicinity, in order to create a community and regional trail system that offers a variety of different route combinations and enhances public access to the parkway.

Public Utilities
Objective PU‐7 Promote reduction in wastewater flows and develop facilities for beneficial reuse of reclaimed water and biosolids for management and distribution of treated wastewater.

Policy PU‐7‐a Reduce Wastewater. Identify and consider implementing water conservation standards and other programs and policies, as determined and appropriate, to reduce wastewater flows.

Policy PU-7-d Wastewater Recycling. 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‐9‐a New Techniques. Continue to collaborate affected stakeholders and partners to identify and support programs and new techniques of solid waste disposal, such as recycling, composting, waste to energy technology, and waste separation, to reduce the volume and toxicity of solid wastes that must be sent to landfill facilities.

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.

Resource Conservation and Resilience
Objective RC‐2 Promote land uses that conserve resources Policy RC‐2‐a Link Land Use to Transportation. Promote mixed‐use, higher density infill development in multi‐modal corridors. Support land use patterns that make more efficient use of the transportation system and plan future transportation investments in areas of higher‐intensity development. Discourage investment in infrastructure that would not meet these criteria.

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.

Policy RC‐4‐i Methane Capture. Continue to pursue opportunities to reduce air pollution by using methane gas from the old City landfill and the City’s wastewater treatment process.

Objective RC-5 In cooperation with other jurisdictions and agencies in the San Joaquin Valley Air Basin, take timely, necessary, and the most cost-effective actions to achieve and maintain reductions in greenhouse gas emissions and all strategies that reduce the causes of climate change in order to limit and prevent the related potential detrimental effects upon public health and welfare of present and future residents of the Fresno community.

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.

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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) A-5 Table A-1: General Plan Objectives and Policies
Resource Conservation and Resilience (Continued)
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 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 reduction 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-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 Efficient 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.
 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-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-5-f Toolkit. Provide residents and project applicants with a “toolkit” of generally feasible measures that can be used to reduce GHG emissions, including educational materials on energy-efficient and “climatefriendly” products.

Policy RC-5-g Evaluate Impacts with Models. Continue to use computer models such as those used by SJVAPCD to evaluate greenhouse gas impacts of plans and projects that require such review.

Policy RC‐6‐d Recycled Water. Prepare, adopt, and implement a City of Fresno Recycled Water Master Plan.

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Resource Conservation and Resilience (Continued)
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 that reduces 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 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‐c Best Practices for Conservation. Require all City facilities and all new private development to follow U.S.

Bureau of Reclamation Best Management Practices for water conservation, as warranted and appropriate Policy RC‐7‐d Update Standards for New Development. Continue to refine water saving and conservation standards for new development
Policy RC‐7‐e Retrofit City Facilities, and Consider Incentives Programs to Encourage Retrofitting of Other Existing Public and Private Residential and Non‐Residential Facilities and Sites. Reduce water use in municipal buildings and City operations by developing a schedule and budget for the retrofit of existing municipal buildings with water conservation features, such as auto shut‐off faucets and water saving irrigation systems. Prepare a comprehensive incentive program for other existing public and private residential and non‐residential buildings and irrigation systems.

Policy RC‐7‐f Implementation and Update Conservation Program. Continue to implement the City of Fresno Water Conservation Program, as may be updated, and periodically update restrictions on water uses, such as lawn and landscape watering and the filling of fountains and swimming pools, and penalties for violations. Evaluate the feasibility of a 2035 conservation target of 190 gpcd in the next comprehensive update of the City of Fresno Water Conservation Program.

Policy RC‐7‐g Educate on State Requirements. Educate the residents and businesses of Fresno on the requirements of the California Water Conservation Act of 2009.

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.

Policy RC‐7‐i PACE Financing. Develop a residential Property Assessed Clean Energy (PACE) program, if it is determined to be a feasible option, to help finance water efficiency and energy efficiency upgrades for property owners.

Objective RC‐8 Reduce the consumption of non‐renewable energy resources by requiring and encouraging conservation measures and the use of alternative energy sources.

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 nonresidential 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.

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P:\CFO1802 Fresno GP EIR Update\PRODUCTS\4.0_GHG_Reduction_Plan\PUBLIC REVIEW DRAFT\Greenhouse Gas Reduction Plan Update.docx (03/03/20) A-7 Table A-1: General Plan Objectives and Policies
Resource Conservation and Resilience (Continued)
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.

Policy RC‐8‐d Incentives. Establish an incentive program for residential developers who commit to building all of their homes to ENERGY STAR performance guidelines.

Policy RC‐8‐e Energy Use Disclosure. Promote compliance with State law mandating disclosure of a building’s energy data and rating of the previous year to prospective buyers and lessees of the entire building or lenders financing the entire building.

Policy RC‐8‐f City Heating and Cooling. Reduce energy use at City facilities by updating heating and cooling equipment and installing “smart lighting” where feasible and economically viable.

Policy RC‐8‐g Revolving Energy Fund. Create a City Energy Fund which uses first year savings and rebates from completed City‐owned energy efficiency projects to provide resources for additional energy projects.

Dedicate this revolving fund to the sole use of energy efficiency projects that will pay back into the fund.

Policy RC‐8‐h Solar Assistance. Identify and publicize information about financial mechanisms for private solar installations and provide over‐the‐counter permitting for solar installations meeting specified standards, which may include maximum size (in kV) of units that can be so approved.

Policy RC‐8‐j Alternative Fuel Network. Support the development of a network of integrated charging and alternate fuel station for both public and private vehicles, and if feasible, open up municipal stations to the public as part of network development.

Policy RC‐8‐k Energy Efficiency Education. Provide long‐term and ongoing education of homeowners and businesses as to the value of energy efficiency and the need to upgrade existing structures on the regular basis as technology improves and structures age.

Policy RC‐11‐a Waste Reduction Strategies. Maintain current targets for recycling and re‐ use of all types of waste material in the city and enhance waste and wastewater management practices to reduce natural resource consumption, including the following measures:
 Continue to require recyclable material collection and storage areas in all residential development.  Establish recycling collection and storage area standards for commercial and industrial facilities to size the recycling areas according to the anticipated types and amounts of recyclable material generated.  Provide educational materials to residents on how and what to recycle and how to dispose of hazardous waste.
 Provide recycling canisters and collection in public areas where trash cans are also provided.  Institute a program to evaluate major waste generators and identify recycling opportunities for their facilities and operations.
 Continue to partner with the California Integrated Waste Management Board on waste diversion and recycling programs and the CalMax (California Materials Exchange) program.  Evaluate the feasibility of a residential, restaurant and institutional food waste segregation and recycling program, to reduce the amount of organic material sent to landfill and minimize the emissions generated by decomposing organic material.
 Evaluate the feasibility of “carbon footprinting” for the City’s wastewater treatment facilities, biomass and composting operations, solid waste collection and recycling programs.  Expand yard waste collection to divert compostable waste from landfills.  Study the feasibility and cost‐benefit analysis of a municipal composting program to collect and compost food and yard waste, including institutional food and yard waste, using the resulting compost matter for City park and median maintenance.

Policy RC‐11‐b Zero Waste Strategy. Create a strategic and operations plan for fulfilling the City Council resolution committing the City to a Zero Waste goal.

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APPENDIX B
GHG REDUCTION PLAN UPDATE: PROJECT CONSISTENCY CHECKLIST B3 Attach #1 of 3

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FRESNO GREENHOUSE GAS (GHG)

REDUCTION PLAN UPDATE

CEQA PROJECT CONSISTENCY CHECKLIST
March 2020
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