Exhibit D-1 – Draft Environmental Impact Report with Appendices — Fresno City Council, March 7, 2024 (part 5 of 6)

Table F-2. Operational Health Risk Assessment Results for All Receptors Costco Commercial Center
Fresno, California
Receptor ID
X-Coordinate
(m)
Y-Coordinate
(m) Receptor Type
Acute Hazard
Index
Cancer Risk
(in a million)
Chronic
Hazard Index
562 240000.00 4082000.00 Worker 0.03 3.06E-04 1.40E-02
563 241500.00 4082000.00 Residential 0.07 1.17E-04 4.59E-03 564 242000.00 4082000.00 Residential 0.05 8.31E-05 4.64E-03 565 239500.00 4082500.00 Worker 0.02 1.54E-04 8.74E-03
566 240000.00 4082500.00 Worker 0.01 1.60E-04 9.83E-03
567 240500.00 4082500.00 Worker 0.01 1.39E-04 1.09E-02
568 241000.00 4082500.00 Worker 0.01 1.09E-04 5.67E-03
569 241500.00 4082500.00 Worker 0.01 7.84E-05 3.99E-03
570 242000.00 4082500.00 Worker 0.01 5.47E-05 2.37E-03
571 240000.00 4083000.00 Worker 0.01 9.94E-05 6.33E-03
572 240500.00 4083000.00 Worker 0.01 8.30E-05 6.25E-03
573 241000.00 4083000.00 Worker 0.01 6.95E-05 3.76E-03
574 240982.00 4080428.00 Sensitive 1.57 1.33E-03 2.03E-02 575 241114.00 4080505.00 Sensitive 1.29 1.86E-03 2.12E-02 576 241812.00 4080393.00 Sensitive 0.38 6.92E-04 9.51E-03 577 239709.00 4079647.00 Sensitive 0.20 1.68E-04 7.28E-03 578 239709.00 4079647.00 Sensitive 0.20 1.68E-04 7.28E-03 579 242094.00 4081102.00 Sensitive 0.11 1.85E-04 7.31E-03 580 242489.00 4081376.00 Sensitive 0.06 9.66E-05 4.68E-03 581 241998.00 4079399.00 Sensitive 0.25 2.98E-04 4.83E-03 582 242523.00 4080146.00 Sensitive 0.16 2.87E-04 4.45E-03 583 240160.00 4078896.00 Sensitive 0.11 1.08E-04 4.84E-03 584 242576.00 4081764.00 Sensitive 0.05 7.56E-05 3.92E-03 585 242632.00 4080241.00 Sensitive 0.14 2.39E-04 4.28E-03 Abbreviations:
m - meter

Page 8 of 8 ends

Costco Commercial Center
Air Quality Technical Report
Fresno, California
Ramboll

APPENDIX G

CO HOTSPOTS

Appendix D
Transportation Impact Analysis

May 2023

FRESNO COSTCO

RELOCATION

TRANSPORTATION IMPACT

ANALYSIS

FRESNO, CA
Inside front cover
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Fresno Costco Relocation
Transportation Impact
Analysis
Fresno, CA
Prepared for:

Costco Wholesale
999 Lake Dr
Issaquah, WA
Prepared by:

Kittelson & Associates, Inc.
155 Grand Ave, Suite 505
Oakland, CA 94612
510.839.1742
Project Manager:

Amy Lopez
Associate Planner
Reviewed by:

Fernando Sotelo, PE
Associate Engineer
Project Principal:

Christopher Brehmer
Senior Principal Engineer
Project Number 26784
May 2023
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CONTENTS
Introduction..................................................................................................................................................................1 Project Description..............................................................................................................1 Scope of the Report............................................................................................................1 General Plan Consistency Assessment ......................................................................................................................6 Existing Conditions...............................................................................................................6 Proposed Project...............................................................................................................13 Existing Plus Project Conditions ........................................................................................20 Future Conditions ..............................................................................................................28 Future Plus Project Conditions..........................................................................................31 Future Plus Project Conditions without Reclassification of W Herndon Ave................37 CEQA Compliance Assessment ...............................................................................................................................47 CEQA Significance Criteria ..............................................................................................47 Consistency with Plans and Programs ............................................................................47 Change in Regional VMT..................................................................................................49 Potential Hazards Resulting from Queues.......................................................................64 Emergency Access ...........................................................................................................64 Conclusions ................................................................................................................................................................65 Recommended Off-Site Improvements..........................................................................65 Project Environmental Impacts........................................................................................65 Fresno Costco Relocation Transportation Impact Analysis May 2023 List of Figures
Kittelson & Associates ii

LIST OF FIGURES
Figure 1: Project Vicinity Map ..................................................................................................................................... 3 Figure 2: Site Plan prepared by MG2 ......................................................................................................................... 4 Figure 3. Existing Traffic Volumes .............................................................................................................................. 11 Figure 4. Project Trip Distribution ............................................................................................................................... 18 Figure 5. Project Trip Volumes ................................................................................................................................... 19 Figure 6. Existing Plus Project Traffic Volumes .......................................................................................................... 22 Figure 7. Recommended Off-Site Geometric Improvements ............................................................................... 27 Figure 8: Future Peak Hour Volumes ........................................................................................................................ 30 Figure 9: Future Plus Project Peak Hour Volumes Weekday AM, Weekday PM, and Saturday Midday – W Herndon Ave Reclassification ................................................................................................................................... 32 Figure 10: Project without Reclassification of W Herndon Ave, Peak Hour Volumes Weekday AM, Weekday PM, and Saturday Midday ........................................................................................................................................ 40 Figure 11: Future Plus Project without Reclassification of W Herndon Ave, Peak Hour Volumes Weekday AM, Weekday PM, and Saturday Midday ...................................................................................................................... 41 Figure 12: Member Household VMT, Existing Costco Warehouse ......................................................................... 50 Figure 13: Member Household VMT, Relocated Costco Warehouse ................................................................... 51 Figure 14: Existing Costco Diversion Routes, To/From SR 99 ................................................................................... 55 Figure 15: Existing Costco Diversion Routes, To/From N Golden State Blvd ......................................................... 56 Figure 16: Existing Costco Diversion Routes, To/From N Brawley Ave ................................................................... 57 Figure 17: Relocated Costco Diversion Routes, To/From SR 99 ............................................................................. 58 Figure 18: Relocated Costco Diversion Routes, To/From N Golden State Blvd ................................................... 59 Figure 19: Relocated Costco Diversion Routes, To/From Marketplace at El Paseo ............................................ 60 Fresno Costco Relocation Transportation Impact Analysis May 2023 List of Tables
Kittelson & Associates iii

LIST OF TABLES
Table 1: Signalized Intersection Level of Service Definitions .................................................................................... 8 Table 2: Stop-Controlled Intersection Level of Service Definitions .......................................................................... 8 Table 3: Existing Conditions, Intersection Operations ............................................................................................. 12 Table 4: Crashes by Location and Severity, 2016-2020 .......................................................................................... 13 Table 5: Trip Characteristics for Costco Warehouse with Fuel Station and Car Wash, Weekday AM, Weekday PM & Weekend Midday Peak Hours ........................................................................................................................ 14 Table 6: Trip Generation Estimates for MDO, MDO Operations-Based and ITE Warehouse Comparison ........ 15 Table 7: Project Trip Generation Estimate ............................................................................................................... 16 Table 8: Existing Plus Project Conditions, Intersection Operations ........................................................................ 21 Table 9: Existing Plus Project, Turn Lane Analysis Results ......................................................................................... 23 Table 10: Existing Plus Project Conditions, Signal Warrants .................................................................................... 24 Table 11: Existing Plus Project Conditions, 95th Percentile Queues ...................................................................... 25 Table 12: Existing Plus Project Conditions with Off-Site Improvements, Intersection Operations ....................... 26 Table 13: Future Conditions, Intersection Operations ............................................................................................ 29 Table 14: Future Plus Project Conditions, Intersection Operations ........................................................................ 33 Table 15: Future Plus Project Conditions, Turn Lane Analysis Results ..................................................................... 34 Table 16: Future Plus Project Conditions, Signal Warrants ...................................................................................... 34 Table 17: Future Plus Project Conditions, 95th Percentile Queues ........................................................................ 36 Table 18: Future Plus Project with Reclassification Conditions with Off-Site Improvements, Intersection Operations .................................................................................................................................................................. 37 Table 19: Future Plus Project Conditions without Reclassification of W Herndon Ave, Intersection Operations ..................................................................................................................................................................................... 39 Table 20: Future Plus Project Conditions without Reclassification of W Herndon Ave, Turn Lane Analysis Results .......................................................................................................................................................................... 42 Table 21: Future Plus Project Conditions without Reclassification of W Herndon Ave, Signal Warrants ............ 42 Table 22: Future Plus Project Conditions without Reclassification of W Herndon Ave, 95th Percentile Queues ..................................................................................................................................................................................... 44 Table 23: Future Plus Project Conditions without Reclassification of W Herndon Ave with Off-Site Improvements, Intersection Operations .................................................................................................................. 45 Table 24: Shaw Building Trip Generation (Shopping Center) ................................................................................ 53 Table 25: Shaw Costco Fuel Station Trip Generation ............................................................................................. 54 Table 26: Diverted Trip Lengths, Shaw Costco Fuel Station ................................................................................... 54 Table 27: Existing Costco VMT Summary.................................................................................................................. 61 Table 28: Shaw Building Backfill Retail Use Daily VMT ............................................................................................. 61 Table 29: Shaw Costco Fuel Station Daily VMT ....................................................................................................... 62 Table 30: Relocated Herndon Costco Daily VMT ................................................................................................... 62 Table 31: Overall Change in Regional Daily VMT with Relocated Costco Warehouse...................................... 62 Table 32: Trip Reduction Programs for Employees (Project/Site) .......................................................................... 63 Fresno Costco Relocation Transportation Impact Analysis May 2023 List of Appendices
Kittelson & Associates iv

LIST OF APPENDICES
Appendix A – Scoping Agreement Memorandum
Appendix B – Existing Conditions Synchro Reports
Appendix C – Existing Plus Project Conditions Synchro Reports Appendix D – Existing Plus Project Conditions Turn Lane Analysis Appendix E – Existing Plus Project Conditions Signal Warrant Analysis Appendix F – Existing Plus Project Conditions with Recommended Off-Site Improvements Synchro Reports Appendix G – Future Conditions Synchro Reports
Appendix H – Future Plus Project Conditions Synchro Reports Appendix I – Future Plus Project Conditions Turn Lane Analysis Appendix J – Future Plus Project Conditions Signal Warrant Analysis Appendix K – Future Plus Project Conditions with Recommended Off-Site Improvements Synchro Reports Appendix L – Future Plus Project Conditions without Reclassification of W Herndon Ave Synchro Reports Appendix M – Future Plus Project Conditions without Reclassification of W Herndon Ave Turn Lane Analysis Appendix N – Future Plus Project Conditions without Reclassification of W Herndon Ave Signal Warrant Analysis
Appendix O – Future Plus Project Conditions without Reclassification of W Herndon Ave with Recommended Off-Site Improvements Synchro Reports
Appendix P – Emergency Vehicle Access Routes
Appendix Q – Travel Demand Model Output
Fresno Costco Relocation Transportation Impact Analysis May 2023 List of Appendices
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Section 1
Introduction
Fresno Costco Relocation Transportation Impact Analysis Introduction May 2023
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INTRODUCTION
This report summarizes the transportation impacts associated with the relocation of a Costco warehouse currently in operation at 4500 W Shaw Ave to a vacant site in the northeast corner of N Riverside Dr and W Herndon Ave in the City of Fresno, CA. Figure 1 illustrates the site vicinity.

PROJECT DESCRIPTION
Costco Wholesale Corporation (Costco) is proposing to relocate their existing wholesale retail facility situated at 4500 W Shaw Ave in Fresno, CA (project). The project would consist of a 191,346-square-foot (sf) relocated retail facility with an attached tire center, 49,996-sf relocated market delivery operation (MDO), 32-position fuel station, and drive-through car wash with approximately 987 parking stalls on a 22.4-acre parcel located at the northeast corner of the intersection of N Riverside Dr and W Herndon Ave. The project would construct a second northbound vehicle travel lane on N Riverside Dr along the project frontage as well as a multiuse path along the southern and western project frontages (W Herndon Ave and N Riverside Dr, respectively). Figure 2 shows the proposed site plan.

The wholesale retail facility is open to Costco members only. The MDOs is a last-mile facility for delivery of large and bulky items and is not open to visitation by Costco members. At MDO facilities, there is a drop off of large goods, organization of the goods, and loading of last-mile trucks for daily deliveries to Costco members’ homes.

The project also includes a proposed re-zone and General Plan amendment to reclassify the adjacent portion of W Herndon Ave from expressway to super arterial to allow for appropriate vehicle access. The project site is currently undeveloped and is designated by both the zoning and General Plan as Community Commercial. The project would have its main access points along N Riverside Dr, with secondary access on W Spruce Ave and Arthur Ave (a planned public street on the east side of the site, which would connect to W Herndon Ave).

SCOPE OF THE REPORT
The scope of the report was developed in coordination with the City of Fresno (City) and Caltrans. The analysis performed for this study determines the expected transportation-related effects of the project.

Appendix A includes the scoping agreement memorandum.

The transportation analyses documented in this report were performed to establish consistency with the City of Fresno General Plan, as implemented through the City’s Traffic Impact Study Report Guidelines,1 and to comply with the California Environmental Quality Act (CEQA), as implemented through the City’s CEQA Guidelines for Vehicle Miles Traveled Thresholds.2 An analysis based on automobile delay (i.e., level of service or LOS) can no longer be used for assessing CEQA impacts. Therefore, the LOS evaluation is not assigned significance levels and is presented in this report regarding consistency with the general plan as a factor for consideration by the decision-makers in acting on the project. 1 City of Fresno Traffic Impact Study Report Guidelines, updated February 2, 2009 2 City of Fresno Guidelines for Vehicle Miles Traveled Thresholds, adopted June 25, 2020 Fresno Costco Relocation Transportation Impact Analysis Introduction May 2023
Kittelson & Associates Page 2
This report evaluates the following transportation issues:
x General Plan Consistency
o Traffic Operations for Five Scenarios
Existing Conditions
Trip generation and distribution estimates for the project Existing Plus Project Conditions
Future Conditions (Year 2042)
Future Plus Project Conditions
Future Plus Project Conditions, without Functional Classification Change of W Herndon Ave
x CEQA Compliance
o Consistency with existing programs, plans, ordinances, or policies, including those associated with transit, pedestrian, and bicyclist access o Change in regional daily vehicle miles traveled (VMT) due to the project o Potential hazards resulting from queues
o Emergency access around and near the project site
© 2021 Microsoft Corporation © 2021 Maxar©CNES(2021) Distribution Airbus DS SITE
C:\Users\bhelm\appdata\local\temp\AcPublish_27348\26784_Fresno Costco Figures.dwg Nov 11, 2021 - 5:53pm - bhelm Layout Tab: Fig01_Vicinity Site Vicinity Map
Fresno, California 1
Figure ## - Study Intersections
- Site Accesses
SITE
6 5
4 3
1 2
99 180
168
145 41
33 99
250 125
0 250
Scale: 1" = 250'
## - Study Intersections
- Site Accesses
N
C:\Users\bhelm\appdata\local\temp\AcPublish_27348\26784_Fresno Costco Figures.dwg Nov 11, 2021 - 5:53pm - bhelm Layout Tab: Fig02_Site Proposed Site Plan Fresno, California 2 Figure
Recieved From: MG2 Engineering August 10, 2021
Section 2
General Plan Consistency Assessment
Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
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GENERAL PLAN CONSISTENCY

ASSESSMENT
The general plan consistency, or non-CEQA, section of this report includes analyses for the following:
x Existing Conditions
x Trip generation and distribution estimates for the project x Existing Plus Project Conditions
x Future Conditions (Year 2042)
x Future Plus Project Conditions
x Future Plus Project Conditions, without Functional Classification Change of W Herndon Ave The following study intersections were selected for traffic operations evaluation based on land use and circulation conditions near the project site and access to the proposed development:

1. N Riverside Dr & W Spruce Ave

2. N Riverside Dr & W Fir Ave (Plus Project scenarios only)

3. N Riverside Dr & W Herndon Ave

4. N Golden State Blvd & W Herndon Ave

5. SR 99 NB off-ramp & W Herndon Ave

6. N Parkway Dr & W Herndon Ave

EXISTING CONDITIONS
The Existing Conditions analysis identifies the site conditions and current operational and geometric characteristics of the study intersections as well as transit services, bicycle, and pedestrian facilities near the project site.

ROADWAY NETWORK
State Route 99 (SR 99), or Golden State Highway, is a north-south freeway traversing the Central Valley. It connects to I-5 near Wheeler Ridge to the south and ends at SR 36 near Red Bluff to the north. In Fresno, SR 99 has six lanes. In the study area, the nearest interchange is at W Herndon Ave.

W Herndon Ave is an east-west super arterial with four to six lanes and a raised planted median. The posted speed limit is 45 mph.

N Riverside Dr is a north-south roadway with two lanes north of W Herndon Ave (collector) and four lanes south of W Herndon Ave (arterial). Adjacent to the project frontage, a raised median exists to the south of W Fir Ave, and a two-way left-turn lane exists to the north of W Fir Ave. The posted speed limit is 40 mph. N Riverside Dr becomes W Bullard Ave south of N Veteran Blvd.

W Spruce Ave is an east-west collector street with two lanes west of N Riverside Dr and four lanes within the residential development east of the project site. The road does not connect through from N Riverside Dr, along the north perimeter of the project site, to the residential development to the east. The road may connect through in the future, contingent up on development of other parcels. The posted speed limit is 40 miles per hour (mph) to the east with unposted speed limit to the west. W Spruce Ave provides access to residential areas around the project site.

Pedestrian Facilities
A multiuse path is available on the north side of W Herndon Ave starting east of the project site and continuing to the east, but sidewalk is not present on the north side of the street along the project site to N Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 7
Riverside Dr. No sidewalk is present on the south side of W Herndon Ave to the east of N Riverside Dr. West of N Riverside Dr, sidewalk is present on the north side of W Herndon Ave for approximately 350’, then discontinues. Sidewalk is continuously present on the south side of W Herndon Ave west of N Riverside Dr in the vicinity of the project site.

Sidewalks area present on the west side of N Riverside Dr, both north and south of W Herndon Dr. Sidewalks are nor present along the project frontage (east side) of N Riverside Dr. They are present on the east side of N Riverside Dr to the south of W Herndon Ave for approximately 500’.

The N Riverside Dr/W Herndon Ave signalized intersection has marked crosswalks on the west and south legs with pedestrian signal heads serving those crosswalks. These two crosswalks feature curb ramps with highvisibility truncated dome pads.

Bicycle Facilities
Bicycle facilities are categorized into four types, as described below:

Class I Bikeway (Bike Path). Also known as a shared path or multi-use path, a bike path is a paved right-ofway for bicycle travel that is completely separate from any street or highway.

Class II Bikeway (Bike Lane). A striped and stenciled lane for one-way bicycle travel on a street or highway.

This facility could include a buffered space between the bike lane and vehicle lane and the bike lane could be adjacent to on-street parking.

Class III Bikeway (Bike Route). A signed route along a street where the bicyclist shares the right-of-way with motor vehicles. This facility can also be designated using a shared-lane marking (sharrow).

Class IV Bikeway (Separated Bike Lane). A bikeway for the exclusive use of bicycles including a separation required between the separated bikeway and the through vehicular traffic. The separation may include, but is not limited to, grade separation, flexible posts, inflexible physical barriers, or on-street parking.

Existing bicycle facilities in the study area include:
x Class I bikeway on Herndon Ave from Spruce Ave to west of Hayes Ave x Class I bikeway on Herndon Ave west of Riverside Dr
x Class II bike lane on N Riverside Dr from W Herndon Ave to the Carnegie Ave x Class II bike lane on N Hayes Ave from W Herndon Ave to W Spruce Ave x Class II bike lane on W Spruce Ave from N Sandrini Ave to W Herndon Ave x Class II bike lane on Veterans Blvd from W Wathen Ave to N Hayes Ave Transit Service
The Fresno Department of Transportation (DOT) provides public bus service known as FAX in Fresno. Two bus lines operate near the project site: 3 and 20. The 3 line runs between the Marketplace at El Paseo (the commercial development on the southwest quadrant of the N Riverside Dr/W Herndon Ave intersection) and the Clovis Community College/Herndon area, which is east of the project site. Service frequency is approximately every 15 minutes between 5:00 AM and 9:00 PM on weekdays and 9:30 AM to 7:00 PM on weekends. The 20 line operates between the Marketplace at El Paseo and Fresno City College, which is just north of downtown. Buses operate on approximately 45 minutes headways between 5:30 AM and 10:00 PM on weekdays and 6:30 AM to 7:30 PM on weekends. Relative to the project site, the closest bus stops for both lines are located on N Riverside Dr in front of the Marketplace at El Paseo.

ANALYSIS METHODOLOGY
Intersection Operations Analysis Methodology and Levels of Service “Level of service” describes the operating conditions experienced by users of a facility. LOS is a quantitative stratification of a performance measure or measures representing quality of service. The Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 8
measures used to determine LOS for transportation system elements are called service measures. The Highway Capacity Manual (HCM) defines six levels of service, ranging from A to F, for each service measure or combination of service measures. The service measures to define the LOS of intersections are control delay and volume-to-capacity (V/C) ratio. Control delay alone is used to characterize LOS for the entire intersection or an approach. Control delay and volume-to-capacity ratio are used to characterize LOS for a lane group (e.g., all northbound lanes approaching an intersection).

Table 1 and Table 2 present the relationship of average delay to level of service for signalized intersections and stop control intersections, respectively.

Table 1: Signalized Intersection Level of Service Definitions Source: Transportation Research Board, Highway Capacity Manual 6th Edition, Washington, D.C., 2016.

Table 2: Stop-Controlled Intersection Level of Service Definitions Average Delay Per Vehicle (Seconds) LOS
≤10.0 A
>10.0 and ≤15.0 B
>15.0 and ≤25.0 C
>25.0 and ≤35.0 D
>35.0 and ≤50.0 E
>50.0 F
Source: Transportation Research Board, Highway Capacity Manual 6th Edition, Washington, D.C., 2016.

All intersection level of service evaluations used the peak 15-minute flow rate during the weekday AM and PM and Saturday midday peak hours. Using the peak 15-minute flow rate ensures that this analysis is based on a reasonable worst-case scenario. For this reason, the analysis reflects conditions that are only likely to occur for 15 minutes out of each peak hour. Intersection analysis was conducted using the operational methodology outlined in the HCM 6th Edition (Transportation Research Board, Washington, D.C., 2016) at all intersections, as operationalized by Synchro software version 10.

Average Delay Per
Vehicle (Seconds)
LOS Description of Traffic Conditions
≤10.0 A This level is typically assigned when the volume-to-capacity ratio is low and either progression is exceptionally favorable, or the cycle length is very short.
>10.0 and ≤20.0 B This level is typically assigned when the volume-to-capacity ratio is low and either progression is highly favorable, or the cycle length is short.

More vehicles stop than with LOS A.
>20.0 and ≤35.0 C This level is typically assigned when progression is favorable, or the cycle length is moderate. Individual cycle failures (i.e., one or more queued vehicles are not able to depart as a result of insufficient capacity during the cycle) may begin to appear at this level. The number of vehicles stopping is significant, although many vehicles still pass through the intersection without stopping.
>35.0 and ≤55.0 D This level is typically assigned when the volume-to-capacity ratio is high and either progression is ineffective, or the cycle length is long. Many vehicles stop and individual cycle failures are noticeable. >55.0 and ≤80.0 E This level is typically assigned when the volume-to-capacity ratio is high, progression is unfavorable, and the cycle length is long. Individual cycle failures are frequent.
≤80.0 F This level is typically assigned when the volume-to-capacity ratio is very high (greater than 1.0), progression is very poor, and the cycle length is long. Most cycles fail to clear the queue.

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
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The City of Fresno has a level of service standard of LOS D for signalized and stop-controlled intersections, as implemented by the City’s Traffic Impact Study Report Guidelines.3 Analysis Inputs
Synchro 10 software was used to conduct the traffic operations analysis. The following inputs were utilized in this analysis:

Signal Timing
The City and Caltrans provided signal timing on August 16, 2021 for the following intersections:

1. N Riverside Dr & W Herndon Ave (City)

2. N Golden State Blvd & W Herndon Ave (City)

3. SR 99 NB off-ramp & W Herndon Ave (Caltrans)

4. N Parkway Dr & W Herndon Ave (City)
For all analysis scenarios, the existing signal timing was utilized. Signal optimization was applied only under mitigation scenarios, as outlined under the mitigation description.

Pedestrian Volumes
Vehicular turning movement and pedestrian counts were collected at the study intersections on September 23 and 25, 2021. The pedestrian volumes collected were utilized in Synchro as conflicting pedestrian movement volumes and number of pedestrians calls for signalized intersections. In addition to utilizing the pedestrian volumes, the pedestrian signal timing was utilized to model traffic signal operations.

Peak Hour Factor
Existing and Existing Plus Project analyses used intersection-specific peak hour factors (PHFs) collected in the field. For all future year scenarios, the PHF was increased to 0.92 if the existing PHF was lower than 0.92. PHFs observed at or above 0.92 were maintained for future year scenarios. As traffic patterns change and volumes increase, a more consistent traffic flow can be expected. Increasing the PHF provides a conservative analysis of the future traffic flow being more consistent across the entirety of a peak hour.

Future Volume Development
Future volumes for 2042 cumulative conditions without the project were developed using the Fresno COG travel demand model. The land uses in the travel model were checked to ensure that the project was not already included in the 2042 model forecast. Volumes for the AM and PM peak hours on each intersection approach were extracted from the model for the years 2019 and 2042. The 2042 adjusted forecasts were calculated for each intersection approach by adding the growth increment between the 2019 and 2042 model volumes to the counts collected in September 2021. If this incremental adjustment would result in a negative forecast on an intersection approach, the forecast volume was instead calculated as the traffic count times the ratio of the 2042 model volume to the 2019 model volume Then, the approach growth rate was calculated using the adjusted 2042 model volumes and the 2021 turning movement counts. For each intersection approach, the 2042 turn movements were calculated by multiplying the turning movement counts by the adjusted approach growth rates. The turn movements were then checked for continuity of flow between adjacent intersections. Model volume output files are included as Appendix Q. 3 City of Fresno Traffic Impact Study Report Guidelines, updated February 2, 2009 Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 10

EXISTING TRAFFIC CONDITIONS
Peak hour intersection turning movement counts were collected on September 23, 2021 during weekday AM and PM peak periods (7:00 AM – 9:00 AM and 4:00 PM – 6:00 PM, respectively) and September 25, 2021 during the Saturday midday peak period (11:00 AM – 2:00 PM) while local schools were in session and there were no inclement weather conditions. As coordinated with the City during the scoping process for this transportation study, the 2021 collected counts were used to develop Existing Conditions traffic volumes for the study. The peak hours were identified as the worse four consecutive 15-minute periods during the AM and PM peak periods on weekdays and Saturdays described above. The existing intersection turn movement peak hour traffic volumes are shown in Figure 3. The figure also depicts the intersection lane configurations and traffic controls at each intersection.

C:\Users\bhelm\appdata\local\temp\AcPublish_27348\26784_Fresno Costco Figures.dwg Nov 11, 2021 - 5:53pm - bhelm Layout Tab: Fig03_Existing Volumes Year 2021 Existing Lane Configurations, Traffic Control Devices and Traffic Volumes Weekday AM, Weekday PM and Weekend Midday Peak Hours
Fresno, California
3 - STOP SIGN Figure
- TRAFFIC SIGNAL

LANE CONFIG AM VOLUME PM VOLUME SAT VOLUME

LANE CONFIG AM VOLUME PM VOLUME SAT VOLUME
FUTURE

INTERSECTION
FUTURE

INTERSECTION

N RIVERSIDE DR &

W SPRUCE AVE

N RIVERSIDE DR &

W FIR AVE

N RIVERSIDE DR &

W HERNDON AVE

N GOLDEN STATE BLVD &

W HERNDON AVE
SR 99 NB OFF-RAMP &

W HERNDON AVE

N PARKWAY DR &

W HERNDON AVE

N RIVERSIDE DR &

SITE ACCESS A

N RIVERSIDE DR &

SITE ACCESS C

SITE ACCESS D &

W HERNDON AVE

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
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Table 3 presents the existing traffic operations at the study intersections. The results indicate that all study intersections are operating at LOS D or better for all peak hours, except the N Riverside Dr/W Herndon Ave intersection (#3), which operates at LOS E during the weekday PM peak hour.

Appendix B includes the Synchro reports for Existing Conditions.

Table 3: Existing Conditions, Intersection Operations
No. Location Control Peak Hour Delay LOS
1 N Riverside Dr/W Spruce St AWSC AM 7.9 A
PM 8.0 A
SAT 7.9 A
2 N Riverside Dr/W Fir Ave TWSC AM 9.0 A
PM 8.7 A
SAT 8.7 A
3 N Riverside Dr/W Herndon Ave Signal AM 28.8 C
PM 72.7 E
SAT 31.8 C
4 N Golden State Blvd/
W Herndon Ave
Signal AM 28.7 C
PM 33.6 C
SAT 29.3 C
5 SR 99 NB Off-Ramp/
W Herndon Ave
Signal AM 15.0 B
PM 24.0 C
SAT 19.4 B
6 N Parkway Dr/W Herndon Ave Signal AM 25.4 C
PM 22.3 C
SAT 18.7 B
Source: Kittelson & Associates, Inc., 2023
Note:
- Synchro Version 10 and HCM 6th Edition methodology were used. - City of Fresno LOS Standard D for Signalized and Unsignalized Intersections - Bolded and italicized indicate intersections operating beyond the City of Fresno standard. - AWSC: All-Way Stop Control
- TWSC: Two-Way Stop Control
- Average delay in seconds/vehicle is reported for signalized and stop control intersections. For TWSC intersections the worst approach delay is reported.

Crash History Evaluation
Kittelson investigated the history of crashes at the study intersections. In reviewing crash data for the fiveyear period of 2016-2020,4 Kittelson found there were nine reported crashes in total amongst the six study intersections. Four crashes caused property damage only, four crashes caused minor injuries, and one crash caused severe injury. Table 4 presents a summary of reported crashes by severity and location. None of the reported crashes involved a pedestrian or bicyclist. 4 Transportation Injury Mapping System online crash database, https://tims.berkeley.edu/, Statewide Integrated Traffic Records System (SWTIRS) online crash database Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
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Table 4: Crashes by Location and Severity, 2016-2020
No. Location PDO* Minor Injury Severe Injury
1 N Riverside Dr/W Spruce St
2 N Riverside Dr/W Fir Ave
3 N Riverside Dr/W Herndon Ave 2 2
4 N Golden State Blvd/W Herndon Ave 1
5 SR 99 NB Off-Ramp/W Herndon Ave 1
6 W Herndon Ave/N Parkway Dr 2 1
Source: TIMS and SWITRS, 2022
*PDO = property damage only

PROPOSED PROJECT
As described above, the proposed project is the relocation of an existing Costco wholesale retail facility situated at 4500 W Shaw Ave. The project would consist of a relocated retail facility, relocated market delivery operation (MDO), 32-position fuel station, and car wash in a 22.4-acre parcel located at the northeast corner of the intersection of N Riverside Dr and W Herndon Ave.

SITE CIRCULATION ANALYSIS
Costco warehouse and MDO delivery truck inbound access is accommodated at Site Access C on N Riverside Dr. Outbound access is accommodated at Site Access D on W Herndon Ave. If Site Access D were not approved as part of the project, then outbound warehouse and MDO trucks would circulate north along the private drive east of the warehouse to W Spruce Ave. Fuel delivery truck inbound access is accommodated at the private drive from W Spruce Ave. Outbound access is accommodated at Site Access A on N Riverside Dr. The proposed site plan provides adequate lane width and curb radii to accommodate warehouse, MDO, and fuel delivery trucks within the site and at the above-named site access points.

COSTCO WAREHOUSE TRIP CHARACTERISTICS
Costco Warehouse facilities are open to members only and operate seven days a week. Typically, the warehouse building is open to members on weekdays between the hours of 10:00 AM and 8:30 PM.

Weekend operating hours open to members are typically from 9:30 or 10:00 AM to 6:00 PM. The warehouses are typically closed on major holidays. Costco Gasoline fuel stations co-located on the site are typically open seven days a week between 5:00 AM and 10:00 PM.

Trip data has been collected at Costco Warehouses across the United States and documented that they typically generate higher traffic volumes than other commercial land uses with similar building sizes. In addition to the number of trips, the Costco trip generation database also documents trip type based on member survey information that provides the percentage of primary, pass-by, and diverted trips, as further described below.
x Primary Trips: an entirely new trip on the roadway system for the express purpose of driving to and from Costco
x Pass-by Trips: existing trips that are on roadways adjacent to the site, which allow motorists to turn into the Costco development and continue to their ultimate destination when their shopping is concluded
x Diverted Trips: existing trips on nearby roadways in which a motorist decides to drive out-ofdirection for a distance to stop at Costco, and when their shopping is concluded, continues to their trip to the ultimate destination.

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 14
This report assesses the impacts of pass-by and diverted trip impacts at the study intersections. Typically, pass-by trips have an impact only at the site-access driveways, whereas the impact of diverted trips could extend through additional study area intersections beyond the site access points (diverted trips are typically modeled similar to net new trips at many or all of the study area intersections). Diverted and passby trips were considered together with engineering judgment to identify how these two trip characteristics should be applied to the project. Recognizing the context of the project site relative to key transportation corridors, this study assumes that all diverted trips would divert from SR 99, N Golden State Blvd, or the Marketplace shopping center at the southwest quadrant of the N Riverside Dr/W Herndon Ave intersection, thereby utilizing the same distribution pattern as net new trips at the site.

Warehouse, Fuel Station, and Car Wash Trip Generation
The warehouse with fuel station and car wash trip rates summarized herein rely on data collection conducted at Costco sites located across the western region of the United States. The trip studies were completed using industry standard engineering practices consistent with guidance within the Institute of Transportation Engineers (ITE) standard reference, Trip Generation Manual, 10th Edition. These cordon surveys were conducted between 2011 and 2021 and include 16 surveys of Costco warehouses with fuel stations in California, Arizona, Oregon, Utah, and Washington. The Costco buildings surveyed range in size between 144,252 sf and 166,451 sf, with an average size of 152,719 square feet, had fuel stations with 20 to 30 fueling positions, and one of which had a car wash. As a result, the Costco trip generation rates inherently account for Costco fuel station and car wash trips within the overall rate. Table 5 summarizes trip characteristics for the weekday AM, weekday PM, and weekend midday peak hours.

Table 5: Trip Characteristics for Costco Warehouse with Fuel Station and Car Wash, Weekday AM, Weekday PM & Weekend Midday Peak Hours
Source: Kittelson & Associates, Inc., 2023
MDO Trip Generation
MDOs are Costco’s last-mile facilities for big and bulky items. At these facilities, there is a daily morning delivery of large goods, organization of the goods, and loading of last-mile trucks for delivery to members’ homes. Delivery of goods using larger trucks dispatched to the MDO occurs well before 6:00 AM daily. Two MDO on-site employee shifts are utilized: one from 6:00 AM to 2:00 PM, the other from 12:00 PM to 8:00 PM.

Delivery teams arrive at the MDO site in a personal vehicle around 6:45 AM, load their last-mile trucks, and depart. The delivery teams return to the MDO site between 3:00 PM and 6:00 PM, depending on the time required to complete all deliveries, to unload remaindered materials for recycling, and depart after concluding their workday. The MDO delivery trucks are stored on-site overnight.

Costco’s existing MDO serving the greater Fresno area operates today at 3688 E Central Ave and is served by 23 on-site employees and approximately 10 delivery trucks with two-person teams, each of which makes one daily roundtrip of deliveries to members’ homes. Two days per week, the MDO has one additional truck make three round trips to another warehouse.

Land Use
Weekday
Daily Trip
Rate
(per KSF)
Weekday AM Peak
Hour of Adjacent Street
Traffic Trip Rate
(trips/1,000 sf)
Weekday PM Peak
Hour of Adjacent Street
Traffic Trip Rate
(trips/1,000 sf)
Weekend
Daily Trip
Rate
(per KSF)
Weekend Midday Peak
Hour of Adjacent Street
Traffic Trip Rate
(trips/1,000 sf)
Total In Out Total In Out Total In Out
Costco
Warehouse W/
Fuel Station
and Car Wash

95.18 2.29 54% 46% 8.23 46% 54% 118.31 11.13 49% 51%
Primary Trips No Data No Data 57% No Data 62%
Pass-by Trips No Data No Data 21% No Data 23%
Diverted Trips No Data No Data 22% No Data 15%
Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 15
The project includes relocating the MDO operations to a 49,996-sf space on the project site. The relocated MDO will be served by the same on-site and delivery employees working at the existing MDO location. No measured trip data were available for the existing MDO facility at the time this report was prepared.

Accordingly, MDO trips were estimated two ways: considering anticipated MDO operations and using nationally available trip data.

The operations of an MDO translate to the following trips generated during weekday AM, weekday PM, and weekend midday peak hours:
x Weekday AM Peak Hour
o Delivery employees arriving (22 inbound trips)
o Delivery trucks departing for last-mile deliveries and to other warehouse (11 outbound trips) x Weekday PM Peak Hour
o Delivery trucks returning (11 inbound trips)
o On-site employees return from potential break off-site (conservatively estimate 23 inbound trips)
o Delivery truck to other warehouse departing (1 outbound trip) x Weekend Midday Peak Hour
o On-site employees arriving (23 inbound trips)
o Delivery truck to other warehouse arriving (1 inbound trip) o On-site employees leaving (23 outbound trips)
o Delivery truck to other warehouse departing (1 outbound trip) Table 6 presents the sum of these trips based on MDO operations. For comparison purposes, Kittelson also estimated trips for the MDO using ITE Trip Generation Manual, 10th Edition trip generation rates for Warehouse, Land Use Code 150, also summarized in Table 6.

Table 6: Trip Generation Estimates for MDO, MDO Operations-Based and ITE Warehouse Comparison Source: Kittelson & Associates, Inc., 2023
As presented in the table, use of ITE warehouse trip rates would underestimate the amount of trip expected to be generated by the MDO when the facilities operations are taken into consideration. Therefore, this study assumed the MDO operations-based trip generation to conduct the transportation analyses.

Land Use ITE
Code Size
Weekday
Daily Trip
Rate
(per KSF)
Weekday AM Peak
Hour of Adjacent
Street Traffic Trip
Rate (trips/1,000 sf)
Weekday PM Peak
Hour of Adjacent
Street Traffic Trip
Rate (trips/1,000 sf)
Weekend
Daily Trip
Rate
(per KSF)
Weekend Midday
Peak Hour of
Adjacent Street
Traffic Trip Rate
(trips/1,000 sf)
Total In Out Total In Out Total In Out
Costco MDO - 49,996
SF
230 33 22 11 35 34 1 230 48 24 24
Warehouse 150 87 8 7 1 9 2 7 8 2 2 0
Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 16
Project Trip Generation
Table 7 presents the overall project trip generation estimates based on proprietary Costco-specific data.

Table 7: Project Trip Generation Estimate
Source: Kittelson & Associates, Inc., 2023
*No data are available for daily and weekday AM peak hour pass-by and diverted trips through the Costco database.

Kittelson applied the weekday PM rates to the weekday AM and daily trips and applied the weekend midday rates to the weekend daily trips.

As shown in Table 7, the project is estimated to generate 10,616 weekday daily net new trip ends. Of these, 284 are estimated to occur in the weekday AM peak hour (159 inbound / 125 outbound), 934 are estimated to occur in the weekday PM peak hour (452 inbound / 482 outbound). The project is estimated to generate 14,266 weekend daily net new trip ends. Of these, 1,369 are estimated to occur in the weekend midday peak hour (669 inbound / 700 outbound).

Warehouse Deliveries
Costco anticipates an average of about 10-13 Costco trucks a day delivering goods to the Costco warehouse. Costco fleet trucks typically measure up to approximately 70 feet long for double-axle trailers.

Typical receiving time is from 2:00 AM to 1:00 PM, averaging two to three trucks per hour, with most of the deliveries completed before the mid-morning warehouse opening time. Deliveries to the warehouse are made primarily in Costco trucks from its freight consolidation facility (depot) in Tracy, CA. In addition to the Costco depot trucks, deliveries such as bread are expected to be made by local vendors using single unit trucks and/or single-axle trailers.

MDO Deliveries
Costco anticipates one daily delivery of large goods to the MDO facility. Typical receiving time is before 6:00 AM made primarily in Costco trucks from its freight consolidation facility (depot) in Tracy, CA.

Costco Gasoline Deliveries
Costco anticipates that the Costco Gasoline fuel station will receive five to seven fuel deliveries per day on average. During busy holiday weeks, an additional delivery is often required during the day. These deliveries typically occur any time when the fuel station is open.

PROJECT TRIP DISTRIBUTION
The relocated Costco would be situated approximately 2.9 miles northwest of the existing Costco location on W Shaw Ave and 7.8 miles west of the North Fresno Costco, located on N Abby St. The project trip Land Use Size
Weekday
Daily Trip
Rate
(per KSF)
Weekday AM Peak
Hour of Adjacent
Street Traffic Trip
Rate (trips/1,000 sf)
Weekday PM Peak
Hour of Adjacent
Street Traffic Trip Rate
(trips/1,000 sf)
Weekend
Daily Trip
Rate
(per KSF)
Weekend Midday
Peak Hour of
Adjacent Street
Traffic Trip Rate
(trips/1,000 sf)
Total In Out Total In Out Total In Out
Costco Warehouse w/
Fuel Station & Car Wash 191,346 18,212 439 238 201 1,576 732 844 22,638 2,130 1,040 1,090 Pass-by Trips* (3,788) (91) (49) (42) (328) (152) (176) (5,297) (498) (243) (255) Diverted Trips* (4,038) (97) (52) (45) (349) (162) (187) (3,305) (311) (152) (159) Net New Trips 10,386 251 137 114 899 418 481 14,036 1,321 645 676 MDO 49,996 230 33 22 11 35 34 1 230 48 24 24
Net New Trips 10,616 284 159 125 934 452 482 14,266 1,369 669 700 Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 17
distribution utilizes proprietary Costco transaction data for the existing warehouses at W Shaw Ave and N Abby St, proprietary market area data for the relocated warehouse, and Costco membership data, and it considers the roadway network.

Figure 4 presents the project trip distribution. Figure 5 presents project trip volumes.

SITE
C:\Users\bhelm\appdata\local\temp\AcPublish_27348\26784_Fresno Costco Figures.dwg Nov 11, 2021 - 5:53pm - bhelm Layout Tab: Fig04_Dist Project Trip Distribution
Fresno, California
4 Figure ## - Study Intersections
XX% Trip Distribution Percentage 25%
30%
99 30%
5%
10%

- STOP SIGN
- TRAFFIC SIGNAL
C:\Users\bhelm\appdata\local\temp\AcPublish_27348\26784_Fresno Costco Figures.dwg Nov 11, 2021 - 5:53pm - bhelm Layout Tab: Fig05_Project Trips Project Trip Volumes
Weekday AM, Weekday PM and Weekend Midday Peak Hours
Fresno, California
5 Figure

LANE CONFIG AM VOLUME PM VOLUME SAT VOLUME

N RIVERSIDE DR &

W SPRUCE AVE

N RIVERSIDE DR &

W FIR AVE

N RIVERSIDE DR &

W HERNDON AVE

N GOLDEN STATE BLVD &

W HERNDON AVE
SR 99 NB OFF-RAMP &

W HERNDON AVE

N PARKWAY DR &

W HERNDON AVE

N RIVERSIDE DR &

SITE ACCESS A

N RIVERSIDE DR &

SITE ACCESS C

SITE ACCESS D &

W HERNDON AVE

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
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EXISTING PLUS PROJECT CONDITIONS
The potential effects of the project on existing traffic operations at the study intersections are discussed in this section. This analysis includes the reclassification of W Herndon Ave from an expressway to a super arterial. As an expressway, no direct site access is permitted onto the roadway. Under the reclassification scenario the site proposes an additional left-in, right-in, right-out intersection onto W Herndon Ave.

INTERSECTION OPERATIONS
Kittelson developed traffic volumes for Existing Plus Project conditions using an additive approach. Kittelson estimated vehicle trips generated by the project and added those trips to existing volumes on the roadway network to develop the volumes for the Existing Plus Project conditions. Existing Plus Project turning movement volumes are presented in Figure 6.

As shown in Table 8, all study intersections would operate within City standard of LOS D or better under Existing Plus Project conditions, except for the following:
x N Riverside Dr/W Fir Ave (Intersection 2)
o PM Peak Hour (LOS F)
o Saturday Midday Peak Hour (LOS F)
x N Riverside Dr/W Herndon Ave (Intersection 3)
o AM Peak Hour (LOS E)
o PM Peak Hour (LOS F)
o Saturday Midday Peak Hour (LOS F)
x N Golden State Blvd/W Herndon Ave (Intersection 4)
o PM Peak Hour (LOS E)
o Saturday Midday Peak Hour (LOS E)
Appendix C includes Synchro output reports for Existing Plus Project conditions.

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 21
Table 8: Existing Plus Project Conditions, Intersection Operations No. Location Control Peak
Hour
Delay LOS
1 N Riverside Dr/
W Spruce Ave AWSC
AM 8.7 A
PM 10.3 B
SAT 12.1 B
2 N Riverside Dr/
W Fir Ave TWSC
AM 14.8 B
PM >50 F
SAT >50 F
3 N Riverside Dr/
W Herndon Ave Signal
AM 63.1 E
PM >80 F
SAT >80 F
4 N Golden State Blvd/
W Herndon Ave Signal
AM 34.2 C
PM 66.5 E
SAT 70.8 E
5 SR 99 NB Off-Ramp/
W Herndon Ave Signal
AM 16.6 B
PM 37.2 D
SAT 26.3 C
6 N Parkway Dr/
W Herndon Ave Signal
AM 26.1 C
PM 25.8 C
SAT 22.4 C
A N Riverside Dr/
Site Access A TWSC
AM <1 A
PM <1 A
SAT <1 A
C N Riverside Dr/
Site Access C TWSC
AM <1 A
PM <1 A
SAT <1 A
D Site Access D/
W Herndon Ave TWSC
AM 14.5 B
PM 19.2 C
SAT 16.4 C
Source: Kittelson & Associates, Inc., 2023
Note:
- Synchro Version 10 and HCM 6th Edition methodology were used. - City of Fresno LOS Standard D for Signalized and Unsignalized Intersections - Bolded and italicized indicate intersections operating beyond the City of Fresno standard. - AWSC: All-Way Stop Control
- TWSC: Two-Way Stop Control
- Average delay in seconds/vehicle is reported for signalized and stop control intersections. For TWSC intersections the worst approach delay is reported.

- STOP SIGN
- TRAFFIC SIGNAL
C:\Users\bhelm\appdata\local\temp\AcPublish_27348\26784_Fresno Costco Figures.dwg Nov 11, 2021 - 5:53pm - bhelm Layout Tab: Fig06_Existing + Proj Year 2021 Existing Plus Project Lane Configurations, Traffic Control Devices and Traffic Volumes Weekday AM, Weekday PM and Weekend Midday Peak Hours
Fresno, California 6
Figure

LANE CONFIG AM VOLUME PM VOLUME SAT VOLUME

N RIVERSIDE DR &

W SPRUCE AVE

N RIVERSIDE DR &

W FIR AVE

N RIVERSIDE DR &

W HERNDON AVE

N GOLDEN STATE BLVD &

W HERNDON AVE
SR 99 NB OFF-RAMP &

W HERNDON AVE

N PARKWAY DR &

W HERNDON AVE

N RIVERSIDE DR &

SITE ACCESS A

N RIVERSIDE DR &

SITE ACCESS C

SITE ACCESS D &

W HERNDON AVE

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 23

DRIVEWAY OPERATIONS
Traffic operations were evaluated at the Costco site driveways on N Riverside Dr adjacent to the proposed site accesses using Synchro, applying HCM 6th Edition methodologies. In addition, left-turn and right-turn lane needs were analyzed with project volumes utilizing guidance from the National Cooperative Highway Research Program's (NCHRP) Report 279: Intersection Channelization Design Guide and NCHRP Report 457:

Evaluating Intersection Improvements: An Engineering Study Guide. The analyses were conducted using Saturday midday volumes as they represented the highest volumes at the driveways.

Turn Lane Assessment
Turn lane opportunities were analyzed for the site accesses along N Riverside Dr and W Herndon Ave with the findings summarized in Table 9. Appendix D contains the turn lane analysis worksheets.

Table 9: Existing Plus Project, Turn Lane Analysis Results No. Intersection Proposed Access
Type Turn Lane Threshold Met
2 N Riverside Dr/
W Fir Ave
Full-Movement
Two-Way StopControlled
NB Right Turn Lane Yes
SB Left Turn Lane No
A N Riverside Dr/
Site Access A
Right-In Right-Out
Stop-Controlled NB Right Turn Lane No
C N Riverside Dr/
Site Access C
Right-In, Right-Out
Stop-Controlled NB Right Turn Lane Yes
D Site Access D/
W Herndon Ave
Left-In, Right-In,
Right-Out
Stop Controlled
WB Right-Turn Lane Yes
EB Left-Turn Lane Yes
Source: Kittelson & Associates, Inc., 2023
N Riverside Dr at W Fir Ave and at Site Access C satisfy the right-turn thresholds with Existing Plus Project traffic volumes.

The curb-to-curb width at N Riverside Dr for the northbound approach at W Fir Ave is about 60 feet, with a 5-foot bike lane, two 11-foot southbound travel lanes, an 11.5-foot northbound left turn lane, and an 18.5- foot northbound lane. A northbound right-turn lane can be accommodated if the roadway is widened onto the project site.

The curb-to-curb width at N Riverside Dr for the northbound approach at Site Access C is about 65 feet, with a 5-foot bike lane, 11-foot southbound travel lanes, a concrete median, and about 30 feet of asphalt in the northbound direction. A northbound right-turn lane may be accommodated if the median is moved, and/or the roadway is widened onto the project site.

While Site Accesses A and C meet the threshold for a right-turn lane, the project already will construct a second northbound travel lane along the project frontage between W Herndon Ave and W Spruce Ave. At W Spruce Ave, there is not a second receiving lane to the north of the intersection. Therefore, the second northbound lane would function as a right-turn lane at the intersection and would not carry through traffic.

Given the lower speeds expected on the section of N Riverside Dr along the project frontage and the absence of a second receiving lane to the north of W Spruce Ave, the second northbound lane constructed as part of the project could accommodate right-turn traffic entering the project site while through traffic uses the inner lane.

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
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SIGNAL WARRANTS
The Manual on Uniform Traffic Control Devices (MUTCD) identifies nine warrants for traffic signal installation.

The first three volume-based warrants (#1-Eight Hour, #2-Four Hour, #3-Peak Hour) were evaluated based on traffic volumes for Existing Plus Project conditions. Appendix E contains the signal warrants worksheets.

Table 10: Existing Plus Project Conditions, Signal Warrants Source: Kittelson & Associates, Inc., 2023
For N Riverside Dr/W Fir Ave, the threshold for warrants 1, 2, and 3 are met on a weekday and Saturday.

Based on this finding and the proposed location of the primary full-access driveway to the project site at this intersection, it is recommended that a signal be installed at this location.

For Site Access D on W Herndon Ave, the threshold for warrant 3 is met on a weekday and the threshold for warrants 1, 2, and 3 are met on Saturday. Given the proximity of Site Access D to the signalized N Riverside Dr/W Herndon Ave intersection (800’ to the east), the minor access characterization of Site Access D, and that the intersection is expected to operate within City standard, installation of a signal is not recommended at this location.
95TH PERCENTILE QUEUES
An analysis of 95th percentile queue lengths was performed using Synchro software version 10. Queue lengths are presented in Table 11 for the Existing peak hours. The longest queue present during any of the three peak hours is shown in the table. The study intersections were found to mostly have sufficient storage to contain the 95th percentile queue lengths. Exceptions to this are:
x N Riverside Dr/W Fir Ave (Intersection 2): The queue for exiting the project site (westbound approach) is predicted to extend well within the site during the Saturday midday peak hour. x N Riverside Dr/W Herndon Ave (Intersection 3): Northbound left, southbound left, southbound right, and eastbound left movements are predicted to exceed available capacity during the PM peak hour.
x N Golden State Blvd/W Herndon Ave (Intersection 4): Southbound left, eastbound through, and westbound right are predicted to exceed available capacity during the PM peak hour.

Appendices B, C, and F contain queue length summary reports for the different scenarios.

No. Intersection Proposed Access Type Warrant Threshold Met 1 N Riverside Dr/ W
Spruce Ave
PM
#1 - Eight-Highest No
#2 – Four-Hour No
#3 – Peak Hour No
SAT
#1 - Eight-Highest No
#2 – Four-Hour No
#3 – Peak Hour No
2 N Riverside Dr/ W Fir
Ave
PM
#1 - Eight-Highest Yes
#2 – Four-Hour Yes
#3 – Peak Hour Yes
SAT
#1 - Eight-Highest Yes
#2 – Four-Hour Yes
#3 – Peak Hour Yes
D Site Access D/
W Herndon Ave
PM
#1 – Eight Highest No
#2 – Four-Hour No
#3 – Peak Hour Yes
SAT
#1 – Eight Highest Yes
#2 – Four Hour Yes
#3 – Peak Hour Yes
Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 25
Table 11: Existing Plus Project Conditions, 95th Percentile Queues No. Intersection Scenario
Northbound Southbound Eastbound Westbound
Left Thru Right Left Thru Right Left Thru Right Left Thru Right 1 N Riverside
Dr/
W Spruce Ave
Storage 150 375 100 - 80 225 575
Existing SAT 25 25 - 25 25 25 -
Existing +
Project SAT 25 25 25 25 25 25 125
2 N Riverside
Dr/
W Fir Ave
Storage 225 250 375 225 700
Existing SAT 25 - 25 25 -
Existing +
Project SAT 25 25 25 25 >1,000
Existing +
Project SAT
with
Improvements
25 175 125 25 575
3 N Riverside
Dr/
W Herndon
Ave
Storage 225 - 225 325 - 100 225 - 275 225 -
Existing PM 275 75 50 100 25 25 250 300 50 100 600
Existing +
Project PM 275 50 50 625 25 625 1,325 375 50 150 950
Existing +
Project PM
with
Improvements
275 75 50 450 25 500 450 375 50 150 875 25
4 N Golden
State Blvd/
W Herndon
Ave
Storage 150 300 150 275 600 175 250 500 350 150 325 325 Existing PM 50 50 75 300 75 50 50 300 25 75 450 275
Existing +
Project PM 50 50 100 425 75 50 50 425 25 100 700 550
Existing +
Project PM
with
Improvements
50 75 100 475 100 50 75 500 25 150 750 400
5 SR 99 NB Off
Ramp/
W Herndon
Ave
Storage 275 - 650 - 500 550
Existing PM 125 - 175 - 200 325
Existing +
Project PM 100 - 300 - 200 375
6 N Parkway Dr/
W Herndon
Ave
Storage - 500 150 125 300 - - 500 - 175
Existing PM - 25 50 250 50 - - 150 - 25
Existing +
Project PM - 25 50 250 50 - - 375 - 150
A
N Riverside
Dr/
Site Access A
Storage - - - 700
Existing SAT - - - -
Existing +
Project SAT - - - 25
C
N Riverside
Dr/
Site Access C
Storage - - - 300
Existing SAT - - - -
Existing +
Project SAT - - - 25
D
Site Access D/
W Herndon
Ave
Storage - - - 1000 100 - - -
Existing SAT - - - - - - - -
Existing +
Project SAT - - - 25 25 - - -
Source: Kittelson & Associates, Inc. 2023
Intersections analyzed using HCM 6 methodologies
Queue lengths reported in feet (rounded to the nearest vehicle length) Intersections shaded in gray represent locations where queue lengths would exceed storage.

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RECOMMENDED OFF-SITE IMPROVEMENTS
The following improvements in conjunction with site development would mitigate the Existing Plus Project traffic operations to a level that satisfies City intersection performance requirements. x N Riverside Dr/W Fir Ave (Intersection 2): Signalize intersection. x N Riverside Dr/W Herndon Ave (Intersection 3): Restripe existing eastbound approach to include second eastbound left turn lane. Extend eastbound left-turn lane an additional 150 feet, repurposing the raised median in the roadway cross section. Add southbound right-turn overlap to traffic signal.
o Note: A revision of the signal timing to change all left turns from protected only to protected-permitted would mitigate the intersection to a level that satisfies performance requirements. However, the City does not support protected-permitted left-turns for this location.
x N Golden State Blvd/W Herndon Ave (Intersection 4): Revise signal phasing to optimize greentime allocation relative to anticipated volumes. For the westbound approach, the queue would extend past the N Weber Ave intersection. To reduce queue blockage of the intersection, “DO NOT BLOCK” pavement markings are recommended for the full width of N Weber Ave. On the north leg, reconstruct the median to extend the southbound dual left-turn pocket as far north as possible without interfering with the existing northbound left-turn pocket at W Kathryn Ave.

Table 12 presents the operations at the intersections with the recommended improvements. Figure 7 illustrates the resultant lane configurations and traffic control devices at the intersections with recommended geometric improvements. Appendix F contains Synchro output reports for the Existing Plus Project Conditions.

Table 12: Existing Plus Project Conditions with Off-Site Improvements, Intersection Operations No. Location Control Peak Hour Delay LOS
2 N Riverside Dr/W Fir Ave Signal
AM 4.8 A
PM 15.7 B
SAT 44.3 D
3 N Riverside Dr/W Herndon Ave Signal
AM 51.9 D
PM 86.0 F
SAT 76.5 E
4 N Golden State Blvd/W Herndon Ave Signal
AM 34.2 C
PM 45.2 D
SAT 46.3 D
Source: Kittelson & Associates, Inc., 2023
Note:
- Synchro 10th Edition and HCM 6th Edition methodology were used. - City of Fresno LOS Standard D for Signalized and Unsignalized Intersections - Average delay in seconds/ vehicle is reported for signalized and stop control intersections.

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FUTURE CONDITIONS
The future traffic conditions analysis forecasts how the study intersections would operate in the Year 2042 with the traffic generated by regional growth and development in the area assuming completion of planned transportation projects. regional growth and planned transportation improvements in the project area. Future volumes were developed using the Fresno Council of Governments (FCOG) transportation system model. The model provides expected future AM and PM traffic volumes. In the study area an additional State Highway interchange is planned to the south of W Herndon Ave and north of W Shaw Ave.

This planned interchange results in lower traffic volumes within the immediate project vicinity. The future PM volumes from the model were used to develop the future Saturday midday volumes by applying the projected trip growth factors realized in the PM peak hour to the Saturday volumes.

INTERSECTION OPERATIONS
Traffic volumes for Future Conditions prior to project site development were developed using a compounded growth rate approach. Specifically, existing traffic volumes were multiplied by a compounded growth rate developed using the Fresno Coalition of Governments (Fresno COG) countywide travel demand model. Future peak hour turning movement volumes are presented in Figure 8.

As shown in Table 13, all study intersections are projected to operate acceptably at LOS D or better under Future Conditions, except under the following scenario:
x N Riverside Dr/W Herndon Ave (Intersection 3)
o PM Peak Hour (LOS E)
Appendix G includes Synchro output reports for Future Conditions.

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 29
Table 13: Future Conditions, Intersection Operations
No. Location Control Peak Hour Delay LOS
1 N Riverside Dr/W Spruce Ave AWSC
AM 7.9 A
PM 8.1 A
SAT 7.9 A
2 N Riverside Dr/W Fir Ave TWSC
AM 8.9 A
PM 8.8 A
SAT 8.7 A
3 N Riverside Dr/W Herndon Ave Signal
AM 25.8 A
PM 76.6 E
SAT 32.2 C
4 N Golden State Blvd/W Herndon Ave Signal
AM 28.4 C
PM 42.1 D
SAT 34.6 C
5 SR 99 NB Off Ramp/W Herndon Ave Signal
AM 15.1 B
PM 10.5 B
SAT 9.9 A
6 N Parkway Dr/W Herndon Ave Signal
AM 26.1 C
PM 16.5 B
SAT 15.2 B
Source: Kittelson & Associates, Inc., 2023
Note:
- Synchro Version 10 and HCM 6th Edition methodology were used. - City of Fresno LOS Standard D for Signalized and Unsignalized Intersections - Bolded and italicized indicate intersections operating beyond the City of Fresno standard. - AWSC: All-Way Stop Control
- TWSC: Two-Way Stop Control
- Average delay in seconds/vehicle is reported for signalized and stop control intersections. For TWSC intersections the worst approach delay is reported.

- STOP SIGN
- TRAFFIC SIGNAL
C:\Users\bhelm\appdata\local\temp\AcPublish_27348\26784_Fresno Costco Figures.dwg Nov 11, 2021 - 5:53pm - bhelm Layout Tab: Fig08_Background Year 2042 Future Lane Configurations, Traffic Control Devices and Traffic Volumes Weekday AM, Weekday PM and Weekend Midday Peak Hours
Fresno, California
8 Figure

LANE CONFIG AM VOLUME PM VOLUME SAT VOLUME

LANE CONFIG AM VOLUME PM VOLUME SAT VOLUME
FUTURE

INTERSECTION
FUTURE

INTERSECTION

N RIVERSIDE DR &

W SPRUCE AVE

N RIVERSIDE DR &

W FIR AVE

N RIVERSIDE DR &

W HERNDON AVE

N GOLDEN STATE BLVD &

W HERNDON AVE
SR 99 NB OFF-RAMP &

W HERNDON AVE

N PARKWAY DR &

W HERNDON AVE

N RIVERSIDE DR &

SITE ACCESS A

N RIVERSIDE DR &

SITE ACCESS C

SITE ACCESS D &

W HERNDON AVE

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 31

FUTURE PLUS PROJECT CONDITIONS
The potential effects of the project on future traffic operations at the study intersections are discussed in this section. This analysis includes the reclassification of W Herndon Ave from an expressway to a major arterial.

As an expressway, no direct site access is permitted onto the roadway. Under the reclassification scenario the site proposes an additional left-in, right-in, right-out intersection onto W Herndon Ave.

INTERSECTION OPERATIONS
Traffic volumes for Future Plus Project conditions were developed using an additive approach. Project trips were added to Future Conditions traffic on the roadway network to develop the volumes for the Future Plus Project with reclassification conditions. Future Plus Project with reclassification turning movement volumes for weekday AM, PM and Saturday peak hours are presented in Figure 9.

As shown in Table 14, the following study intersections would operate at unacceptable LOS during the analysis periods listed:
x N Riverside Dr/W Fir Ave (Intersection 2)
o PM Peak Hour (LOS F)
o Saturday Midday Peak Hour (LOS F)
x N Riverside Dr/W Herndon Ave (Intersection 3)
o AM Peak Hour (LOS E)
o PM Peak Hour (LOS F)
o Saturday Midday Peak Hour (LOS F)
x N Golden State Blvd/W Herndon Ave (Intersection 4)
o PM Peak Hour (LOS E)
o Saturday Midday Peak Hour (LOS E)
Appendix H includes Synchro output reports for Future Plus Project conditions.

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 33
Table 14: Future Plus Project Conditions, Intersection Operations No. Location Control Peak Hour Delay LOS
1 N Riverside Dr/W Spruce Ave AWSC
AM 8.5 A
PM 10.5 B
SAT 11.7 B
2 N Riverside Dr/W Fir Ave TWSC
AM 13.0 B
PM >50 F
SAT >50 F
3 N Riverside Dr/W Herndon Ave Signal
AM 56.9 E
PM >80 F
SAT >80 F
4 N Golden State Blvd/W Herndon Ave Signal
AM 31.4 C
PM 76.2 E
SAT 68.9 E
5 SR 99 NB Off Ramp/W Herndon Ave Signal
AM 16.1 B
PM 14.7 B
SAT 15.6 B
6 N Parkway Dr/W Herndon Ave Signal
AM 23.9 C
PM 16.4 B
SAT 16.9 B
A N Riverside Dr/Site Access A TWSC
AM <1 A
PM <1 A
SAT <1 A
C N Riverside Dr/Site Access C TWSC
AM <1 A
PM <1 A
SAT <1 A
D Site Access D/W Herndon Ave TWSC
AM 14.5 B
PM 15.4 C
SAT 13.9 B
Source: Kittelson & Associates, Inc., 2023
Note:
- Synchro Version 10 and HCM 6th Edition methodology were used. - City of Fresno LOS Standard D for Signalized and Unsignalized Intersections - Bolded and italicized indicate intersections operating beyond the City of Fresno standard. - AWSC: All-Way Stop Control
- TWSC: Two-Way Stop Control
- Average delay in seconds/vehicle is reported for signalized and stop control intersections. For TWSC intersections the worst approach delay is reported.

FUTURE DRIVEWAY OPERATIONS
Traffic operations at the Costco site driveways on N Riverside Dr and W Herndon Ave adjacent to the proposed site accesses were also evaluated with the revised site access for the weekday AM, PM and Saturday midday peak hours.

Turn Lane Assessment
Turn lane opportunities were analyzed for the site accesses along N Riverside Dr and W Herndon Ave. The warrant analysis used the AASHTO Green Book. The warrants were developed using Saturday midday volumes as they represented the highest volumes at the driveways. Appendix I contains the turn lane warrants worksheets.

Table 15 shows the results of the turn lane analysis at the site access locations.

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 34
Table 15: Future Plus Project Conditions, Turn Lane Analysis Results No. Intersection Proposed Access Type Turn Lane Threshold Met 2 N Riverside Dr/
W Fir Ave
Full-Movement
Two-Way Stop-Controlled
NB Right Turn Lane Yes
SB Left Turn Lane No
A N Riverside Dr/
Site Access A
Right-In Right-Out
Two-Way Stop-Controlled NB Right Turn Lane No
C N Riverside Dr/
Site Access C
Right-In, Right-Out
Two-Way Stop-Controlled NB Right Turn Lane Yes
D Site Access A/
W Herndon Ave
Left-In, Right-In, Right-Out
Two-Way Stop-Controlled
WB Right Turn Lane Yes
EB Left Turn Lane Yes
Source: Kittelson & Associates, Inc., 2023
Like the Existing Plus Project condition, N Riverside Dr at W Fir Ave and at Site Access C meet the right-turn assessment with Future Plus Project traffic volumes.

In addition, westbound right turn and eastbound left turn lane warrants are also met at Site Access A and W Herndon Ave. Currently, the curb-to-curb right of way on W Herndon Ave at the proposed site access is approximately 95 feet, with 5 12-foot travel lanes (3 eastbound and 2 westbound lanes) and a 25-foot median. Turn lanes can likely be accommodated on W Herndon Ave while maintaining current lane widths if the median is removed.

SIGNAL WARRANTS
The MUTCD 8-hour, 4-hour and peak hour traffic signal warrants were analyzed for the Future Plus Project conditions. Results are presented in Table 16. Appendix J contains the signal warrants worksheets.

Table 16: Future Plus Project Conditions, Signal Warrants No. Intersection Peak
Hour Warrant Threshold Met
1 N Riverside Dr/W Spruce Ave
PM
#1 - Eight-Highest No
#2 – Four-Hour No
#3 – Peak Hour No
SAT
#1 - Eight-Highest No
#2 – Four-Hour No
#3 – Peak Hour No
2 N Riverside Dr/W Fir Ave
PM
#1 - Eight-Highest Yes
#2 – Four-Hour Yes
#3 – Peak Hour Yes
SAT
#1 - Eight-Highest Yes
#2 – Four-Hour Yes
#3 – Peak Hour Yes
D Site Access D/W Herndon Ave
PM
#1 - Eight-Highest No
#2 – Four-Hour No
#3 – Peak Hour Yes
SAT
#1 - Eight-Highest Yes
#2 – Four-Hour Yes
#3 – Peak Hour Yes
Source: Kittelson & Associates, Inc., 2023
Like the Existing Plus Project conditions, warrants 1, 2, and 3 are met for N Riverside Dr and W Fir Ave under Future Plus Project conditions. Therefore, it is recommended that a signal be installed at this location.

Warrants are not met at any additional locations.

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 35
For Site Access D on W Herndon Ave, the threshold for warrant 3 is met on a weekday and the threshold for warrants 1, 2, and 3 are met on Saturday. Given the proximity of Site Access D to the signalized N Riverside Dr/W Herndon Ave intersection (800’ to the east), the minor access characterization of Site Access D, and that the intersection is expected to operate within City standard, installation of a signal is not recommended at this location.
95TH PERCENTILE QUEUES
An analysis of 95th percentile queue lengths was performed using Synchro software version 10. Queue lengths presented in Table 17 for the Existing peak hours. The longest queue present during any of the three peak hours is shown in the table. The study intersections were found to mostly have sufficient storage to contain the 95th percentile queue lengths. Exceptions to this are:
x N Riverside Dr/W Fir Ave (Intersection 2): Westbound approach: expected to exceed available capacity on Saturdays
x N Riverside Dr/W Herndon Ave (Intersection 3): Northbound left, southbound left, southbound right, and eastbound left movements: expected to exceed available capacity during the PM peak hour x N Golden State Blvd/W Herndon Ave (Intersection 4): Southbound left, eastbound through, and westbound right: expected to exceed available capacity during the PM peak hour All intersections and movements that exceed the storage capacity under Future Conditions with reclassification also exceed the storage capacity under Existing Plus Project conditions. No new movements exceed the storage capacity.

Appendices G, H and K contain queue length summary reports for the different scenarios.

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 36
Table 17: Future Plus Project Conditions, 95th Percentile Queues No. Intersection Scenario
Northbound Southbound Eastbound Westbound
Left Thru Right Left Thru Right Left Thru Right Left Thru Right 1 N Riverside
Dr/ W Spruce
Ave
Storage 150 375 100 - 80 225 575
Future SAT 25 25 25 25 25 25 -
Future +
Project SAT 25 25 25 25 25 25 75
2 N Riverside
Dr/
W Fir Ave
Storage 225 250 375 225 700
Future SAT 25 - - 25 -
Future +
Project SAT 25 - 25 25 >1000
Future +
Project SAT
with
Improvements
25 150 125 25 525
3 N Riverside
Dr/
W Herndon
Ave
Storage 225 - 225 325 - 100 225 - 275 225 -
Future PM 325 75 75 125 50 25 175 175 50 50 475
Future +
Project PM 325 75 75 675 25 650 1225 225 50 75 775
Future +
Project PM
with
Improvements
175 75 75 400 25 550 675 200 50 50 700 25
4 N Golden
State Blvd/
W Herndon
Ave
Storage 150 300 150 275 600 175 250 400 350 150 325 325 Future PM 75 100 125 400 100 50 25 75 25 50 325 50
Future +
Project PM 75 100 200 550 100 50 25 150 25 100 500 325
Future +
Project PM
with
Improvements
75 125 150 450 100 50 25 150 25 100 500 125
5 SR 99 NB OffRamp/
W Herndon
Ave
Storage 275 - 650 - 500 550
Future PM 50 - 50 - 25 25
Future +
Project PM 50 - 50 - 25 150
6 N Parkway
Dr/
W Herndon
Ave
Storage - 500 150 125 300 - - 500 - 175
Future PM - 25 25 175 25 - - 50 - 25
Future +
Project PM - 25 25 175 50 - - 275 - 75
A
N Riverside
Dr/
Site Access A
Storage - - - 700
Existing SAT - - - -
Existing +
Project SAT - - - 25
B
N Riverside
Dr/
Site Access C
Storage - - - 300
Existing SAT - - - -
Existing +
Project SAT - - - 25
C
Site Access D/
W Herndon
Ave
Storage - 1000 100 - -
Existing SAT - - - - -
Existing +
Project SAT - 25 25 - -
Source: Kittelson & Associates, Inc. 2023
Intersections analyzed using HCM 6 methodologies
Queue lengths reported in feet (rounded to the nearest vehicle length) Intersections shaded in gray represent locations where queue lengths would exceed storage.

RECOMMENDED OFF-SITE IMPROVEMENTS
To improve upon intersection operations at locations that would operation beyond the standard, Kittelson recommends the following improvements:
x N Riverside Dr/W Fir Ave (Intersection 2): Signalize intersection.

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 37
x N Riverside Dr/W Herndon Ave (Intersection 3): Restripe existing eastbound approach to include second eastbound left turn lane. Extend eastbound left-turn lane an additional 150 feet, repurposing the raised median in the roadway cross section. Add southbound right-turn overlap to traffic signal.
o Note: A revision of the signal timing to change the northbound and southbound left turns from protected only to protected-permitted would mitigate the intersection to a level that satisfies performance requirements. However, the City does not support protected-permitted left-turns for this location.
x N Golden State Blvd/W Herndon Ave (Intersection 4): Revise signal phasing to optimize greentime allocation relative to anticipated volumes. For the westbound approach, the queue would extend past the N Weber Ave intersection. To reduce queue blockage of the intersection, “DO NOT BLOCK” pavement markings are recommended for the full width of N Weber Ave. On the north leg, reconstruct the median to extend the southbound dual left-turn pocket as far north as possible without interfering with the existing northbound left-turn pocket at W Kathryn Ave.

Table 18 presents the operations at the intersections with the recommended improvements. Appendix K contains Synchro output reports.

Table 18: Future Plus Project with Reclassification Conditions with Off-Site Improvements, Intersection Operations
No. Location Control Peak Hour Delay LOS
2 N Riverside Dr/W Fir Ave Signal
AM 4.5 A
PM 15.7 B
SAT 29.9 C
3 N Riverside Dr/W Herndon Ave Signal
AM 32.3 C
PM 73.7 E
SAT 78.4 E
4 N Golden State Blvd/W Herndon Ave Signal
AM 31.4 C
PM 49.4 D
SAT 48.4 D
Source: Kittelson & Associates, Inc., 2023
Note:
- Synchro Version 10 and HCM 6th Edition methodology were used. - City of Fresno LOS Standard D for Signalized and Unsignalized Intersections - Average delay in seconds/vehicle is reported for signalized and stop control intersections.

FUTURE PLUS PROJECT CONDITIONS WITHOUT

RECLASSIFICATION OF W HERNDON AVE
The Future Plus Project conditions without reclassification of W Herndon Ave analysis forecasts how the study intersections would operate with the traffic generated by the proposed project development and assumes no direct access were provided to W Herndon Ave. If W Herndon Ave remained an expressway, no direct site access would be permitted onto the roadway. Therefore, this analysis excludes the reclassification of W Herndon Ave from an expressway to a major arterial (which is assumed for the plus project conditions), and project trips that were routed to/from the Site Access D and W Herndon Ave location were redistributed to the other site accesses. The analysis includes quantification of the potential affects to traffic operations due to project traffic without the roadway reclassification.

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 38

INTERSECTION OPERATIONS
Traffic volumes for Future Plus Project conditions without reclassification of W Herndon Ave were developed using an additive approach. Project trips shown in Table 7 were added to Future Conditions traffic on the roadway network to develop the volumes for the Future Plus Project conditions without Reclassification of W Herndon Ave. Project-only volumes for this scenario for weekday AM, PM and Saturday peak hours are presented in Figure 10. Turning movement volumes for Future Plus Project conditions without reclassification of W Herndon Ave are presented in Figure 11.

As shown in Table 19, the following study intersections would operate at unacceptable LOS during the analysis periods listed under Future Plus Project conditions without reclassification of W Herndon Ave:
x N Riverside Dr/W Fir Ave (Intersection 2)
o PM Peak Hour (LOS F)
o Saturday Midday Peak Hour (LOS F)
x N Riverside Dr/W Herndon Ave (Intersection 3)
o AM Peak Hour (LOS E)
o PM Peak Hour (LOS F)
o Saturday Midday Peak Hour (LOS F)
x N Golden State Blvd/W Herndon Ave (Intersection 4)
o PM Peak Hour (LOS E)
o Saturday Midday Peak Hour (LOS E)
Appendix L includes Synchro output reports for Future Plus Project conditions without reclassification of W Herndon Ave.

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 39
Table 19: Future Plus Project Conditions without Reclassification of W Herndon Ave, Intersection Operations No. Location Control Peak Hour Delay LOS
1 N Riverside Dr/W Spruce Ave AWSC
AM 8.7 A
PM 11.4 B
SAT 13.8 B
2 N Riverside Dr/W Fir Ave TWSC
AM 16.1 C
PM >50 F
SAT >50 F
3 N Riverside Dr/W Herndon Ave Signal
AM 72.9 E
PM >80 F
SAT >80 F
4 N Golden State Blvd/W Herndon Ave Signal
AM 31.4 C
PM 76.2 E
SAT 68.9 E
5 SR 99 NB Off Ramp/W Herndon Ave Signal
AM 16.1 B
PM 14.7 B
SAT 15.6 B
6 N Parkway Dr/W Herndon Ave Signal
AM 23.9 C
PM 16.4 B
SAT 16.9 B
A N Riverside Dr/Site Access A TWSC
AM <1 A
PM <1 A
SAT <1 A
C N Riverside Dr/Site Access C TWSC
AM <1 A
PM <1 A
SAT <1 A
Source: Kittelson & Associates, Inc., 2023
Note:
- Synchro Version 10 and HCM 6th Edition methodology were used -City of Fresno LOS Standard D for Signalized and Unsignalized Intersections - Bolded and italicized indicate intersections operating beyond the City of Fresno standard - AWSC: All-Way Stop Control
- TWSC: Two-Way Stop Control
- Average delay in seconds/vehicle is reported for signalized and stop control intersections. For TWSC intersections the worst approach delay is reported.

- STOP SIGN
- TRAFFIC SIGNAL
C:\Users\bhelm\appdata\local\temp\AcPublish_27348\26784_Fresno Costco Figures.dwg Nov 11, 2021 - 5:53pm - bhelm Layout Tab: Fig10_Project Trips No Reclass Project Trip Volumes Without Reclassification of W Herndon Ave Weekday AM, Weekday PM and Weekend Midday Peak Hours
Fresno, California 10
Figure

LANE CONFIG AM VOLUME PM VOLUME SAT VOLUME

N RIVERSIDE DR &

W SPRUCE AVE

N RIVERSIDE DR &

W FIR AVE

N RIVERSIDE DR &

W HERNDON AVE

N GOLDEN STATE BLVD &

W HERNDON AVE
SR 99 NB OFF-RAMP &

W HERNDON AVE

N PARKWAY DR &

W HERNDON AVE

N RIVERSIDE DR &

SITE ACCESS A

N RIVERSIDE DR &

SITE ACCESS C

SITE ACCESS D &

W HERNDON AVE
FUTURE

INTERSECTION
FUTURE

INTERSECTION

- STOP SIGN
- TRAFFIC SIGNAL
C:\Users\bhelm\appdata\local\temp\AcPublish_27348\26784_Fresno Costco Figures.dwg Nov 11, 2021 - 5:53pm - bhelm Layout Tab: Fig11_Future+Proj Year 2042 Future Plus Project Without Reclassification of W Herndon Ave, Lane Configurations, Traffic Control Devices and Traffic Volumes Weekday AM, Weekday PM and Weekend Midday Peak Hours
Fresno, California 11
Figure

LANE CONFIG AM VOLUME PM VOLUME SAT VOLUME

LANE CONFIG AM VOLUME PM VOLUME SAT VOLUME
FUTURE

INTERSECTION
FUTURE

INTERSECTION

N RIVERSIDE DR &

W SPRUCE AVE

N RIVERSIDE DR &

W FIR AVE

N RIVERSIDE DR &

W HERNDON AVE

N GOLDEN STATE BLVD &

W HERNDON AVE
SR 99 NB OFF-RAMP &

W HERNDON AVE

N PARKWAY DR &

W HERNDON AVE

N RIVERSIDE DR &

SITE ACCESS A

N RIVERSIDE DR &

SITE ACCESS C

SITE ACCESS D &

W HERNDON AVE

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 42

FUTURE DRIVEWAY CONSIDERATIONS
In addition to the operations analysis results presented in Table 14, the potential need for right and left turn lanes as well as signalization was evaluated for the three project driveways using the methodologies cited earlier in this report.

Turn Lane Assessment
Turn lane opportunities were analyzed for the site accesses along N Riverside Dr and W Herndon Ave using Saturday midday peak hour volumes as they represented the highest volumes projected at the driveways.

Appendix M contains the turn lane analysis worksheets.

Table 20 shows the results of the turn lane analysis at the site access locations.

Table 20: Future Plus Project Conditions without Reclassification of W Herndon Ave, Turn Lane Analysis Results
No. Intersection Proposed Access Type Turn Lane Threshold Met 2 N Riverside Dr/
W Fir Ave
Full-Movement
Two-Way Stop-Controlled
NB Right Turn Lane Yes
SB Left Turn Lane No
A N Riverside Dr/
Site Access A
Right-In Right-Out
Two-Way Stop-Controlled NB Right Turn Lane Yes
C N Riverside Dr/
Site Access C
Right-In, Right-Out
Two-Way Stop-Controlled NB Right Turn Lane Yes
Source: Kittelson & Associates, Inc., 2023
Like the Existing Plus Project condition, N Riverside Dr at W Fir Ave and at Site Access C meet the right-turn warrant threshold under Future Plus Project conditions without reclassification of W Herndon Ave. Under Future Plus Project without Reclassification of W Herndon Ave conditions N Riverside Dr at Site Access A meet the right-turn warrant.

SIGNAL WARRANTS
The MUTCD 8-hour, 4-hour and peak hour traffic signal warrants were analyzed for the Future Plus Project conditions without reclassification of W Herndon Ave. Appendix N contains the signal warrants worksheets.

Table 21: Future Plus Project Conditions without Reclassification of W Herndon Ave, Signal Warrants No. Intersection Proposed Access Type Warrant Threshold Met 1 N Riverside Dr/
W Spruce Ave
PM
#1 - Eight-Highest No
#2 – Four-Hour No
#3 – Peak Hour No
SAT
#1 - Eight-Highest No
#2 – Four-Hour No
#3 – Peak Hour No
2 N Riverside Dr/
W Fir Ave
PM
#1 - Eight-Highest Yes
#2 – Four-Hour Yes
#3 – Peak Hour Yes
SAT
#1 - Eight-Highest Yes
#2 – Four-Hour Yes
#3 – Peak Hour Yes
Source: Kittelson & Associates, Inc., 2023
Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 43
Like the Existing Plus Project conditions, warrants 1, 2, and 3 are met for N Riverside Dr and W Fir Ave under Future Plus Project conditions without reclassification of W Herndon Ave. Based on this finding and the proposed location of the primary full-access driveway to the project site at this intersection, it is recommended that a signal be installed at this location. 95TH PERCENTILE QUEUES
Projected 95th percentile queues are presented in Table 22 for the Existing Plus Project conditions. The longest queue projected during the three peak hours is shown in the table for each movement reported.

The following projected 95th percentile queues exceed the available storage:
x N Riverside Dr/W Fir Ave (Intersection 2): Westbound approach: expected to exceed available capacity on Saturday midday peak hour
x N Riverside Dr/W Herndon Ave (Intersection 3): Northbound left, southbound left, southbound right, and eastbound left movements: expected to exceed available capacity during the PM peak hour x N Golden State Blvd/W Herndon Ave (Intersection 4): Southbound left, eastbound through, and westbound right: expected to exceed available capacity during the PM peak hour All intersections and movements that exceed the storage capacity under Future Conditions also exceed the storage capacity under Existing Plus Project conditions. No new movements exceed the storage capacity relative to Existing Plus Project conditions.

Appendices G, L and O contain queue length summary reports for the different scenarios.

Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 44
Table 22: Future Plus Project Conditions without Reclassification of W Herndon Ave, 95th Percentile Queues No. Intersection Scenario
Northbound Southbound Eastbound Westbound
Left Thru Right Left Thru Right Left Thru Right Left Thru Right 1 N Riverside
Dr/Spruce Ave
Storage 150 375 100 - 80 225 575
Future SAT 25 25 25 25 25 25 -
Future +
Project SAT 25 25 25 25 25 25 100
2 N Riverside
Dr/Fir Ave
Storage 225 250 375 225 700
Future SAT 25 - - 25 -
Future +
Project SAT 25 25 25 25 >1,000
Future +
Project SAT
with
Improvements
25 150 100 25 600
3 N Riverside
Dr/Herndon
Ave
Storage 225 - 225 325 - 100 225 - 275 225 -
Future PM 325 75 75 125 50 25 175 175 50 50 475
Future +
Project PM 325 75 75 650 25 825 >1,000 200 50 65 850
Future +
Project PM
with
Improvements
175 75 75 400 25 650 400 175 50 75 650 150
4 Golden State
Blvd/Herndon
Ave
Storage 150 300 150 275 600 175 250 400 350 150 325 325 Future PM 75 100 125 400 100 50 25 75 25 50 325 50
Future +
Project PM 75 100 200 550 100 50 25 150 25 100 500 325
Future +
Project PM
with
Improvements
75 125 150 450 100 50 25 150 25 100 500 125
5 SR 99 NB OffRamp/Herndon
Ave
Storage 275 - 650 - 500 550
Future PM 50 - 50 - 25 25
Future +
Project PM 50 - 50 - 25 150
6 N Parkway
Dr/Herndon
Ave
Storage - 500 150 125 300 - - 500 - 175
Future PM - 25 25 175 25 - - 50 - 25
Future +
Project PM - 25 25 175 50 - - 275 - 75
Source: Kittelson & Associates, Inc. 2020
Intersections analyzed using HCM 6 methodologies
Queue lengths reported in feet (rounded to the nearest vehicle length) Intersections shaded in gray represent locations where queue lengths would exceed storage.

RECOMMENDED OFF-SITE IMPROVEMENTS
The following improvements are recommended in conjunction with project development to address project trip effects to traffic operations and to restore acceptable operations to respective intersections:
x N Riverside Dr/W Fir Ave (Intersection 2): Signalize intersection. x N Riverside Dr/W Herndon Ave (Intersection 3): Restripe existing eastbound approach to include second eastbound left turn lane. Extend eastbound left-turn lane an additional 150 feet, repurposing the raised median in the roadway cross section. Add southbound right-turn overlap to traffic signal.
o Note: A revision of the signal timing to change the northbound and southbound left turns from protected only to protected-permitted would mitigate the intersection to a level that satisfies performance requirements. However, the City does not support protected-permitted left-turns for this location.
x N Golden State Blvd/W Herndon Ave (Intersection 4): Revise signal phasing to optimize greentime allocation relative to anticipated volumes. For the westbound approach, the queue Fresno Costco Relocation Transportation Impact Analysis General Plan Consistency Assessment May 2023
Kittelson & Associates Page 45
would extend past the N Weber Ave intersection. To reduce queue blockage of the intersection, “DO NOT BLOCK” pavement markings are recommended for the full width of N Weber Ave. On the north leg, reconstruct the median to extend the southbound dual left-turn pocket as far north as possible without interfering with the existing northbound left-turn pocket at W Kathryn Ave.

Table 23 presents the operations at the intersections with the recommended improvements.

Appendix O contains Synchro output reports.

Table 23: Future Plus Project Conditions without Reclassification of W Herndon Ave with Off-Site Improvements, Intersection Operations
No. Location Control Peak Hour Delay LOS
2 N Riverside Dr/W Fir Ave Signal
AM 5.2 A
PM 20.7 C
SAT 47.4 D
3 N Riverside Dr/W Herndon Ave Signal
AM 33.7 C
PM 73.2 E
SAT 78.2 E
4 N Golden State Blvd/W Herndon Ave Signal
AM 30.6 C
PM 49.4 D
SAT 48.4 D
Source: Kittelson & Associates, Inc., 2023
Note:
- Synchro Version 10 and HCM 6th Edition methodology were used. - City of Fresno LOS Standard D for Signalized and Unsignalized Intersections - Bolded and italicized indicate intersections operating beyond the City of Fresno standard. - AWSC: All-Way Stop Control
- TWSC: Two-Way Stop Control
- Average delay in seconds/vehicle is reported for signalized and stop control intersections. For TWSC intersections the worst approach delay is reported.

Section 3
CEQA Compliance Assessment
Fresno Costco Relocation Transportation Impact Analysis CEQA Compliance Assessment May 2023
Kittelson & Associates Page 47

CEQA COMPLIANCE ASSESSMENT
The transportation impact analysis identifies the degree to which regional vehicle miles traveled may change and how the study area’s transportation system is expected to operate when the project is operational. The expected transportation-related effects of the project were examined considering the following:
x Consistency with existing programs, plans, ordinances, or policies x Change in regional daily vehicle miles traveled (VMT) due to the project x Transit, pedestrian, and bicyclist access to and near the project site x Emergency access around and near the project site
This analysis includes both effects that would result in potentially significant impacts under CEQA guidelines and non-CEQA effects associated with traffic operations on the transportation network.

CEQA SIGNIFICANCE CRITERIA
The project’s impact is not considered to be significant unless it would:
a. Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.
b. Conflict or be inconsistent with CEQA Guideline section 15064.3, subdivision (b). c. Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment). d. Result in inadequate emergency access.

Significance criterion “b” is related to the implementation of vehicle-miles traveled (VMT) as the primary performance metric.

The City of Fresno’s CEQA guidelines for VMT thresholds identify the following threshold for significant impacts for developments such as the project:
x A retail project that results in a net increase of regional VMT

CONSISTENCY WITH PLANS AND PROGRAMS
The City of Fresno has jurisdiction over City streets and City-operated traffic signals. Caltrans has jurisdiction over State facilities and on- and off-ramp intersections with local streets. The County of Fresno has jurisdiction over streets in unincorporated areas, as well as County expressways. Kittelson reviewed the applicable programs, plans, ordinances, and policies that pertain to the project’s potential impacts on the transportation system.

STATE REGULATORY FRAMEWORK
Senate Bill 743
Adopted on September 27, 2013, SB 743 directs the California Office of Planning and Research (OPR) to administer new CEQA guidance for jurisdictions that removes automobile vehicle delay and LOS from CEQA analysis and replaces it with VMT analysis or other measures that “promote the reduction of Fresno Costco Relocation Transportation Impact Analysis CEQA Compliance Assessment May 2023
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greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses,” to be used as a basis for determining significant transportation impacts.

REGIONAL REGULATORY FRAMEWORK
Fresno County Council of Governments
The Fresno County Council of Governments (Fresno COG) is a voluntary association of local governments and a regional planning agency composed of 16 member agencies, including the City of Fresno. The purpose of the Fresno COG is to establish a consensus on the transportation and land use needs of the Fresno County area and to further action plans for issues in the region. The current regional transportation plan (RTP) was adopted in 2018. The 2022 RTP is under development at the time this report is being prepared. The RTP addresses GHG emission reductions and other air emissions related to transportation, with the goal of preparing for future growth sustainably.

Fresno County Transportation Authority and Measure C
The Fresno County Transportation Authority (FCTA) is a regional agency that was created to administer the voter-passed Measure C program in 1986. Measure C was a 20-year program that achieved a half-cent sales tax for transportation expenditures and infrastructure. After its 20-year duration, the program was extended in 2006 for another 20 years. The FCTA established goals and core values for using these funds for building roads, expanding the bicycling network, expanding the transit network and transit services, and supporting vanpools and ride hailing services.

Fresno County Congestion Management Process
The Fresno County Congestion Management Process (CMP) is an effective systematic and regionally acceptable approach for managing congestion. Its responsibilities are to provide information on transportation system performance and assess alternative strategies for alleviating congestion and improving mobility. The CMP has identified a CMP network that includes SR 41 from the SR 99 interchange to the Madera/Fresno County line, SR 99 from the Madera/Fresno County line to the Jensen Ave interchange, SR 168 from the SR 180 interchange to the W Herndon Ave interchange, and SR 180 from the SR 99 interchange to the SR 168 interchange.

LOCAL REGULATORY FRAMEWORK
City of Fresno Active Transportation Plan
The City of Fresno’s Active Transportation Plan, adopted in March 2017, provides a comprehensive guide outlining the vision for active transportation in Fresno. The plan lays out specific goals to improve bicycle access and connectivity in Fresno. These goals include the following:
x Equitably improve the safety and perceived safety of walking and bicycling in Fresno x Increase walking and bicycling trips in Fresno by creating user-friendly facilities x Improve the geographical equity of access to walking and bicycling facilities in Fresno x Fill key gaps in Fresno’s walking and bicycling network Complete Streets Policy
The City’s Complete Streets Policy was adopted by the City Council on October 10, 2019, to guide the implementation of the City’s complete streets and multimodal objectives and policies within the Fresno General Plan. The City has integrated complete streets designs into its policies in compliance with Assembly Bill 1358.

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SB 743 Implementation Policies
The City has initiated its incorporation of SB 743 goals into transportation policies in the in-progress General Plan update. Policies that address development of multimodal networks, reductions in greenhouse gases, and increasing diversity of land use have been developed in the General Plan.

IMPACT FINDING
The project would be consistent with the applicable plans policies and programs and would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. Therefore, the impact of the project would be less than significant.

CHANGE IN REGIONAL VMT
This section discusses the analysis methodologies, data, and findings associated with the expected change in regional VMT that would result from the project.

ANALYSIS METHODOLOGIES AND DATA
The VMT analysis includes:
x Assessment of project trip generation
o Including: members (accounting for primary and diverted member trips), warehouse employees, and fuel station employees for the existing and relocated Costcos, as well as car wash employees, MDO on-site employees, and MDO delivery employees for the relocated Costco
o Excluding: members making pass-by trips, warehouse delivery trucks and fuel delivery trucks for the existing and relocated Costcos as well as MDO delivery truck from the depot and MDO delivery-to-members/other warehouse trucks for the relocated Costco x Calculation of member average primary trip length based on Costco member approximate home locations
x Calculation of member diverted trip lengths based on expected diversion routes for the Costco site x Calculation of employee average trip lengths based on the Fresno COG VMT Calculation Tool average employee trip lengths for the relevant transportation analysis zones (TAZs) x Calculation of MDO on-site and delivery employee average trip length based on the Fresno COG VMT Calculation Tool average employee trip length for the relevant TAZs x Calculation of trips for an eventual shopping center use that would backfill the vacated Shaw Costco warehouse
x Calculation of average trip length for an eventual shopping center use x Calculation of Shaw Costco fuel station trips that would remain with the existing fuel station x Calculation of Shaw Costco fuel station average primary and diverted trip lengths x Calculation of overall expected change in regional VMT that would result from the project Costco provided the following data for a typical month of sales at the existing Costco:
x Approximate home locations of Costco members who shopped during September 2019, grouped in 1-square-mile zones
x Number of visits to Costco in September 2019 by members in each 1-square-mile zone x Market area of the existing Costco and projected market area of the relocated Costco Member Average Primary Trip Lengths
Based on the trip generation of the existing Costco and relocated Costco, a portion of trips are made between Costco members’ homes and Costco. These are characterized as primary trips. ArcGIS Online software was used to develop trip lengths between each 1-square-mile zone and the existing and proposed Costco locations. These zones and the travel routes to the existing and proposed Costco locations are presented in Figure 12 and Figure 13, respectively. 5 99
1 41
33 180
101
152
H:\26\26784 - Fresno Costco Warehouse TIA\gis\vmt_figures.mxd Date: 11/10/2021 Figure 12
Travel Routes to Existing Costco (W Shaw Ave)
Fresno Costco Relocation
[ Legend 0 21Miles
Existing Fresno Costco (W Shaw Ave)
! Approximate Location of Member Households
Routes to Existing FresnoFresno Market Area
Fresno Costco Relocation
5 99
1 41
33 180
101
152
H:\26\26784 - Fresno Costco Warehouse TIA\gis\vmt_figures.mxd Date: 11/10/2021 Figure 13
Travel Routes to After Costco Relocation
Fresno Costco Relocation
[ Legend 0 21Miles Relocated Costco (N Riverside Ave)
North Fresno Costco
Travel Routes to Relocated Costco
! Approximate Location of Member Households for Relocated Costco ! Approximate Location of Member Households, Members Shifting from Existing Costco (W Shaw Ave) to North Fresno Costco Travel Routes to North Fresno Costco
Relocated Fresno Market Area
Existing Fresno Costco (W Shaw Ave)
Fresno Costco Relocation
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Upon developing the trip lengths between the zones and the two Costco sites, a weighted average trip length to the existing Costco and a weighted average trip length to the proposed Costco were developed based on the number of member visits made to the existing Costco in September 2019 by members in each zone. In essence, the trip length from a zone with several member visits during the month would carry more “weight” than the trip length from a zone with few member visits when developing the weighted average trip length.

Costco membership projections forecast that nearly all existing members will shop at the new site. The exception is a small set of members of the existing Costco on W Shaw Ave who are expected to transition to shopping at the North Fresno warehouse on N Abby St following the relocation of the W Shaw Ave Costco to the N Riverside Dr location. These few member households that are expected to shift to North Fresno are shown in magenta on Figure 13. The respective 1-square-mile zones were excluded from developing the weighted average trip lengths of primary trips to the relocated Costco.

Member Diverted Trip Lengths
Based on the trip generation of the existing Costco and relocated Costco, a portion of trips to and from Costco are made by members who are traveling on the surrounding street network for some other primary travel purpose and who travel a short distance out of their way to access the site while en route to their primary destination. These are characterized as diverted trips. ArcGIS Online software was used to develop trip lengths for the following expected diversion routes to the existing and proposed Costco locations:

Existing Costco Relocated Costco
x SR 99 (Golden State Highway) x SR 99 (Golden State Highway) x N Golden State Blvd x N Golden State Blvd
x Brawley Avenue x Marketplace at El Paseo
Diversion distances were calculated based on the path a vehicle would need to travel beyond their primary route to access the warehouse and then return to their original path to continue to their destination. Figure 14, Figure 15, and Figure 16 illustrate expected diversion routes for the existing Costco while Figure 17, Figure 18, and Figure 19 illustrate the expected diversion routes for the relocated Costco.

Warehouse, Fuel Station, and Car Wash Employee Average Trip Lengths Based on the trip generation of the existing Costco and relocated Costco, a portion of trips to and from Costco are made by warehouse and fuel station employees for both locations, as well as by car wash employees for the relocated Costco. These are considered home-based trips and are not associated with where members live. The average employee trip lengths provided for the relevant TAZs in the Fresno COG VMT Calculation Tool were used for the analysis.

Costco provides a robust commute benefit to its employees. Costco provides carpool incentives, partners with local agencies to provide vanpool services, subsidizes transit passes, and provides secure bicycle storage and locker rooms for employees who bike to work.

MDO On-Site and Delivery Employee Average Trip Length
Based on the trip generation of the relocated Costco, a portion of trips to and from the new location are made by MDO on-site and delivery employees. Additionally, the same MDO on-site and delivery employees work today at the existing MDO facility. These are considered home-based trips and are not associated with where members live. The average employee trip lengths provided for the relevant TAZs in the Fresno COG VMT Calculation Tool were used for the analysis.

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Shaw Building Backfill Retail Use Trips
Once Costco vacates the building in the shopping center on W Shaw Avenue (Shaw building) to relocate to the new building on W Herndon Avenue (Herndon building), the Shaw building will be available for another retail use. Since the Shaw building is part of an existing development that already has undergone environmental review, the next retail use to occupy and operate from the building would not undergo environmental review. Therefore, the trips and VMT being generated today at the Shaw building by the existing Costco are trips and VMT that exist in the region and, in essence, already have been approved to be generated by a use at this location in Fresno. To determine the anticipated change in regional VMT resulting from the project – which entails the relocation of the Shaw Costco warehouse and development of a new fuel station and car wash – the difference in VMT generated by the Shaw building use after another retail use occupies and operates from it must be computed.

The Shaw building comprises 133,944 square feet and is part of a shopping center with WinCo Foods and another strip commercial building with several smaller commercial businesses. Since a future retail use has not been identified for the Shaw building, the ITE Shopping Center (LU 820) trip rates would apply. The shopping center indeed is larger than 150,000 square feet, as the Shaw building alone comprises more than 130,000 square feet. Therefore, daily trip generation for a future retail use is computed using Shopping Center rates.

Table 24 presents the trip generation for additional shopping center use at the Shaw building after another retail use occupies and operates from the vacated Costco warehouse. As shown, a future retail use would be expected to generate 4,238 daily primary trips.

Table 24: Shaw Building Trip Generation (Shopping Center) Land Use Size Unit Weekday Daily
Rate ADT
Shopping Center (ITE LU 820) 133.944 KSF 37.01 4,957
Pass-By Trips* 14.5% 719
Primary Trips 4,238
Source: Kittelson & Associates, Inc., 2023
Notes:

Source: ITE Trip Generation Manual, 11th Ed.
- Pass-by trips information from Trip Generation Manual appendices. * Daily pass-by trip rate is assumed based on the ITE-provided PM peak hour pass-by trip rate of 29% divided by two since the PM peak hour may not as accurately represent pass-by activity over the course of the day.

Shaw Building Backfill Retail Use Average Trip Length
Kittelson used the Fresno COG countywide travel demand model to estimate the average length of trips to and from the future retail use at the Shaw building. Transportation analysis zone (TAZ) 559 comprises the shopping center. The travel demand model estimates 10,515 daily trips in TAZ 559 generating 78,580 VMT.

These values correspond to an average trip length of 7.47 miles (78,580 ÷ 10,515 = 7.47). This average trip length is used to estimate the anticipated VMT of the future retail use at the Shaw building.

Shaw Costco Fuel Station Trips
As previously discussed, Kittelson maintains a database of trip characteristics for Costco Wholesale sites throughout North America, including specific trip information for Costco fuel stations. Kittelson developed a daily trip generation estimate for the Costco fuel station at the Shaw building based on trip data for nine representative Costco fuel stations in California. Table 25 presents the daily trip generation for the Shaw Costco fuel station after the warehouse relocation.

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Table 25: Shaw Costco Fuel Station Trip Generation
Trip Type Daily Trips
Total Trips 4,282
Pass-by 1,884
Diverted 728
Primary 1,670
Source: Kittelson & Associates, Inc., 2023
As presented in Table 25, the Shaw Costco fuel station is expected to generate 4,282 total daily trips, of which 1,670 would be primary trips and 728 would be diverted trips.

Shaw Costco Fuel Station Average Primary and Diverted Trip Lengths The same member household location information used to develop member average primary trip lengths for the Herndon warehouse was used to develop average primary trip lengths to the Shaw Costco fuel station. ArcGIS Online software was used to develop trip lengths between each 1-square-mile zone and the Shaw Costco location.

Likewise, the same method used to develop member diverted trip lengths for the Herndon warehouse was used to develop diverted trip lengths to the Shaw location. ArcGIS Online software was used to develop trip lengths for the following expected diversion routes to the existing locations:
x SR 99 (Golden State Highway)
x N Golden State Blvd
x Brawley Avenue
Table 26 presents the primary and diverted trip lengths to the Shaw Costco fuel station.

Table 26: Diverted Trip Lengths, Shaw Costco Fuel Station Trip Type Miles
Primary 15.3
Pass-by 0.0
Diverted 1.6
Source: Kittelson & Associates, Inc., 2023
H:\26\26784 - Fresno Costco Warehouse TIA\gis\diversion_figures.mxd Date: 11/10/2021 Figure 14A
Existing Costco Diversion Routes
To/From CA-99
Fresno Costco Relocation
[ Legend 0 0.3 Miles
Diverted RouteRoute Without DiversionExisting Costco (W Shaw Ave) Figure 14
Fresno Costco Relocation
To/From SR 99
Fresno Costco Relocation
H:\26\26784 - Fresno Costco Warehouse TIA\gis\diversion_figures.mxd Date: 11/10/2021 Figure 14B
Existing Costco Diversion Routes
To/From Golden State Boulevard
Fresno Costco Relocation
[ Legend 0 0.3 Miles
Diverted RouteRoute Without DiversionExisting Costco (W Shaw Ave) Figure 15
Fresno Costco Relocation
H:\26\26784 - Fresno Costco Warehouse TIA\gis\diversion_figures.mxd Date: 11/10/2021 Figure 14C
Existing Costco Diversion Routes
To/From Brawley Avenue
Fresno Costco Relocation
[ Legend 0 0.3 Miles
Diverted RouteRoute Without DiversionExisting Costco (W Shaw Ave) Figure 16
Fresno Costco Relocation
H:\26\26784 - Fresno Costco Warehouse TIA\gis\diversion_figures.mxd Date: 11/10/2021 Figure 15A
Relocated Costco Diversion Routes
To/From CA-99
Fresno Costco Relocation
[ Legend 0 0.3 Miles
Diverted RouteRoute Without DiversionRelocated Costco (N Riverside Ave) Figure 17
Fresno Costco Relocation
To/From SR 99
Fresno Costco Relocation
H:\26\26784 - Fresno Costco Warehouse TIA\gis\diversion_figures.mxd Date: 11/10/2021 Figure 15B
Relocated Costco Diversion Routes
To/From Golden State Boulevard
Fresno Costco Relocation
[ Legend 0 0.3 Miles
Diverted RouteRoute Without DiversionRelocated Costco (N Riverside Ave) Figure 18
Fresno Costco Relocation
"
H:\26\26784 - Fresno Costco Warehouse TIA\gis\diversion_figures.mxd Date: 11/10/2021 Figure 15C
Relocated Costco Diversion Routes
To/From Marketplace
Fresno Costco Relocation
[ Legend 0 0.3 Miles
Diverted RouteRelocated Costco (N Riverside Ave)
" Marketplace Figure 19
Fresno Costco Relocation
El Paseo Marketplace
Fresno Costco Relocation
Marketplace at El Paseo
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CHANGE IN REGIONAL VMT
VMT for the existing and relocated Costcos are computed by multiplying the number of each trip type by its associated trip length.

Existing Shaw Costco Daily VMT
Table 27 presents the weekday daily trips for each trip type for the existing Costco, the associated trip lengths, VMT for each trip type, and total daily VMT. As shown in the table, total daily VMT estimated for the existing Shaw Costco site is 120,083 miles.

Table 27: Existing Costco VMT Summary
Trip Type Weekday Daily Trips Trip Length (miles) Daily VMT Members, Primary 7,001 15.3 106,943
Members, Pass-by 2,651 0.0 0
Members, Diverted 2,827 1.6 4,636
Warehouse & Fuel Station Employees 240 17.3 4,152
MDO Warehouse Employees 92 32.0 2,944
MDO Driver Employees 44 32.0 1,408
MDO Deliveries1 20 - -
Fuel Truck Delivery1 10 128.0 -
Warehouse Truck Delivery1 20 128.0 -
Total 12,749 - 120,083
Source: Kittelson & Associates, Inc., 2023
1 Delivery truck trips are excluded from the VMT calculation as good movement is not evaluated for identifying transportation impacts pursuant to CEQA.

Shaw Building Backfill Retail Use Daily VMT
Since the proposed project entails the Costco warehouse vacating the Shaw building to relocate to the Herndon building, the VMT associated with Costco at the Shaw building will be eliminated and a future unknown retail use is assumed to backfill the Shaw building, generating its own VMT. Table 28 presents the weekday daily primary trips for the Shaw building backfill retail use. As shown in the table, total daily VMT estimated for the existing Shaw building backfill retail use is 31,673 miles.

Table 28: Shaw Building Backfill Retail Use Daily VMT
Weekday Daily Trips Trip Length (miles) Daily VMT
Total 4,238 7.47 31,673
Source: Kittelson & Associates, Inc., 2023
Shaw Costco Fuel Station Daily VMT
The existing Shaw Costco fuel station is assumed to remain operational after the Costco warehouse vacates the building on the site and a future unknow retail use occupies and operates on the site.

Table 29 presents the weekday daily trips for the Shaw Costco fuel station. As shown in the table, total daily VMT estimated for the existing Shaw Costco fuel station is 26,704 miles.

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Table 29: Shaw Costco Fuel Station Daily VMT
Weekday Daily Trips Trip Length (miles) Daily VMT
Primary 1,670 15.3 25,510
Diverted 728 1.6 1,194
Fuel Station Total 4,282 26,704
Source: Kittelson & Associates, Inc., 2023
Relocated Herndon Costco Daily VMT
Table 30 presents the weekday daily trips for each trip type for the relocated Costco, the associated trip lengths, VMT for each trip type, and total daily VMT. As presented in the table, total daily VMT anticipated for the relocated Herndon Costco site is 191,032 miles.

Table 30: Relocated Herndon Costco Daily VMT
Trip Type Weekday Daily Trips Trip Length (miles) Daily VMT Member Primary 10,046 17.3 173,528
Member Pass-by 3,788 0.0 0
Member Diverted 4,038 1.0 4,119
Warehouse, Fuel Station, + Car Wash Employees 300 30.7 9,210 MDO Warehouse Employees 92 30.7 2,824
MDO Driver Employees 44 30.7 1,351
MDO Deliveries1 20 - -
Fuel Truck Delivery1 14 125.0 -
Warehouse Truck Delivery1 26 125.0 -
Total 18,368 - 191,032
Source: Kittelson & Associates, Inc., 2023
1 Delivery truck trips are excluded from the VMT calculation as good movement is not evaluated for identifying transportation impacts pursuant to CEQA.

Net Change in Regional VMT
The anticipated VMT would be the difference in daily VMT at the Shaw property with the associated off-site MDO operations, due to changes in the retail use of the Shaw building and the Costco fuel station remaining operational, and the relocated Costco with on-site MDO operations. Table 31 presents the change in regional daily VMT resulting from the project. The change in regional daily VMT resulting from the project is 129,326 miles.

Table 31: Overall Change in Regional Daily VMT with Relocated Costco Warehouse Scenario Daily VMT
Difference in Shaw Property VMT -61,706
Existing Shaw Costco Daily VMT -120,083
Shaw Building Backfill Retail Use 31,673
Shaw Costco Fuel Station 26,704
Relocated Herndon Costco Daily VMT 191,032
Change in Regional Daily VMT (Project VMT) 129,326
Source: Kittelson & Associates, Inc., 2023
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IMPACT FINDING
With construction and operation of the Costco warehouse, regional daily VMT is estimated to increase by 129,326 miles. Therefore, the project impact would be significant.

VMT MITIGATION
The California Air Pollution Control Officers Association (CAPCOA) first published a handbook in 2010 titled Quantifying Greenhouse Gas Mitigation Measures Handbook (GHG Handbook). The GHG Handbook was updated by the Sacramento Metropolitan Air Quality Management District and adopted by CAPCOA in December 2021.

The GHG Handbook is provided as a planning resource for agencies and developers. It includes a transportation section that discusses solutions to mitigate VMT by shifting modes of travel from singleoccupancy vehicles to shared or active modes of transportation.

Most of the VMT mitigation measures that Costco can implement will be geared towards reducing employee trips. However, employee trips account for 436 daily trips (less than 2% of the total daily trips) and 13,385 VMT (approximately 7% of the daily VMT). Thus, VMT reductions from mitigation measures will be minimal.

Table 32: Trip Reduction Programs for Employees (Project/Site) # VMT Mitigation
Measure
Percent Reduction Notes
T-5,
T-6
Implement Commute
Trip Reduction Program
Up to 4% (voluntary)
Up to 26% (mandatory)
CTR can be voluntary or mandatory. This
must include measures T-7 through T-11.

T-7 Commute Trip
Reduction Marketing
Up to 4%
T-8 Provide Ridesharing
Program
Up to 8% Designate parking spaces for rideshare
vehicles.

Designated passenger loading and
unloading and waiting areas.

T-9 Implement Subsidized
or Discount Transit
Program
Up to 5.5%
T-10 Provide End-of-Trip
Bicycle Facilities
Up to 4.4%
T-11 Provide EmployerSponsored Vanpool Up to 20.4%
Source: GHG Handbook
Costco provides a voluntary commute trip reduction program for employees that includes marketing, endof-trip bicycle facilities, vanpool, and discounted transit. This can result in a 4% reduction in employee vehicle trips, reducing the project daily VMT by 535 miles or less than 0.5%. Even if Costco implemented a mandatory commute reduction program and 100% of employees were eligible, this would only result in a 3,480-mile decrease or less than 2% of project daily VMT.

The bulk of the daily VMT is driven by members shopping at the warehouse. While Costco is implementing neighborhood design improvements such as pedestrian network improvements and constructing bikeway facilities as part of the project, and in theory could implement bike-share or scooter-share on-site or implement transit-supportive roadway treatments, the nature of Costco’s land use and business model has been shown to be auto-oriented. Members purchase items in bulk at Costco, making walking, biking, or transit trips to the warehouse impractical.

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Costco will encourage employee carpooling, subsidize transit passes, and provide end-of-trip bicycle facilities for employees, which will mitigate a small share of employee VMT. However, the project VMT impact will remain significant.

POTENTIAL HAZARDS RESULTING FROM QUEUES
Per the City’s Traffic Impact Study Report Guidelines, the City does not have formally adopted guidelines on queuing criterion that establishes thresholds of significance for vehicle queues at intersections. For the purposes of this study, a vehicle queue that overflows the available storage for a turn pocket and blocking the adjacent travel lane or that queues to an upstream signal blocking through traffic is considered a potential safety hazard and would be considered a significant impact. Therefore, this study identifies a significant impact as occurring at locations where the project traffic would cause the queue length for a turn pocket to overflow its available storage compared to no project conditions or cause a queue to spillback into an upstream signalized intersection.

An analysis of 95th percentile queue lengths was performed using Synchro software version 10. Queue lengths for the AM, PM and Saturday midday peak hours were analyzed for all conditions. Most study intersections were found to have sufficient storage to contain 95th percentile queues with implementation of recommended off-site improvements. Exceptions to this are N Riverside Dr/W Herndon Ave (Intersection 3) and N Golden State Blvd/W Herndon Ave (Intersection 4). The recommended improvements at these locations are:
x N Riverside Dr/W Herndon Ave (Intersection 3): Restripe existing eastbound approach to include second eastbound left turn lane. Extend eastbound left-turn lane an additional 150 feet, repurposing the raised median in the roadway cross section. Add southbound right-turn overlap to traffic signal.
x N Golden State Blvd/W Herndon Ave (Intersection 4): Revise signal phasing to optimize greentime allocation relative to anticipated volumes. For the westbound approach, the queue would extend past the N Weber Ave intersection. To reduce queue blockage of the intersection, “DO NOT BLOCK” pavement markings are recommended for the full width of N Weber Ave. On the north leg, reconstruct the median to extend the southbound dual left-turn pocket as far north as possible without interfering with the existing northbound left-turn pocket at W Kathryn Ave.

IMPACT FINDING
Following construction of project off-site improvements, the southbound right-turn queue at N Riverside Dr/ W Herndon Ave would continue to exceed the available storage for the right-turn pocket and spill into the adjacent travel lane. This spillback condition would occur during the most congested period of the day and would not be a continuous condition. Constraints in the roadway cross section preclude widening the roadway to extend the right-turn pocket while also maintaining the upstream bike lane. Following construction of project off-site improvements, the southbound left-turn queue at the N Golden State Blvd/W Herndon Ave intersection may extend beyond the turn pocket and spill into the adjacent travel lane by approximately 50’, depending on final construction of the improvement. This spillback condition would occur during the most congested period of the day and would not be a continuous condition. Therefore, the project impact would be less than significant.

EMERGENCY ACCESS
Emergency vehicle access to the project site is accommodated at the driveways on N Riverside Dr and within the drive aisles in the parking lot and to the queue storage area of the fuel station. The intersection of N Riverside Dr/W Fir Ave serves as the primary access point for emergency vehicles to service the Fresno Costco Relocation Transportation Impact Analysis Conclusions May 2023
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warehouse and MDO facility. The intersection of N Riverside Dr/Site Access A provides emergency access to the northern portion of the site including the car wash and fuel station. The proposed site plan provides adequate lane width and curb radii to accommodate emergency vehicles. Appendix P provide turning templates for emergency vehicles on the site.

IMPACT FINDING
The project provides emergency access to and within the site via the driveways on N Riverside Dr, existing on-site easements, and on-site drive aisles. Therefore, the impact of the project on emergency access would be less than significant.

CONCLUSIONS
Recommended project off-site improvements to the transportation network and environmental impacts are discussed in this section.

RECOMMENDED OFF-SITE IMPROVEMENTS
The project would result in traffic operations below the City’s standard of LOS D at the N Riverside Dr/W Fir Ave two-way stop-controlled intersection, the N Riverside Dr/W Herndon Ave signalized intersection and the N Golden State Blvd/W Herndon Ave signalized intersection. Therefore, Kittelson recommends the following improvements in conjunction with project development to provide operations that satisfy City General Plan LOS standards:
x N Riverside Dr/W Fir Ave (Intersection 2): Signalize intersection. x N Riverside Dr/W Herndon Ave (Intersection 3): Restripe existing eastbound approach to include second eastbound left turn lane. Extend eastbound left-turn lane an additional 150 feet, repurposing the raised median in the roadway cross section. Add southbound right-turn overlap to traffic signal.
o Note: A revision of the signal timing to change the northbound and southbound left turns from protected only to protected-permitted would mitigate the intersection to a level that satisfies performance requirements. However, the City does not support protected-permitted left-turns for this location.
x N Golden State Blvd/W Herndon Ave (Intersection 4): Revise signal phasing to optimize greentime allocation relative to anticipated volumes. For the westbound approach, the queue would extend past the N Weber Ave intersection. To reduce queue blockage of the intersection, “DO NOT BLOCK” pavement markings are recommended for the full width of N Weber Ave. On the north leg, reconstruct the median to extend the southbound dual left-turn pocket as far north as possible without interfering with the existing northbound left-turn pocket at W Kathryn Ave.

PROJECT ENVIRONMENTAL IMPACTS
The CEQA compliance analysis resulted in the following impact findings.

Consistency with Plans, Policies, and Programs
The project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. Therefore, the project impact would be less than significant.

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Regional VMT
With construction and operation of the Costco warehouse, regional daily VMT is estimated to be 129,326 miles. Costco provides a voluntary commute trip reduction program for employees that includes marketing, end-of-trip bicycle facilities, vanpool, and discounted transit. This can result in a 4% reduction in employee vehicle trips, reducing the project daily VMT by 535 miles or less than 0.5%. Therefore, the project impact would be significant.

Potential Hazards Resulting from Queues
Following construction of project off-site improvements, the southbound right-turn queue at N Riverside Dr/ W Herndon Ave would continue to exceed the available storage for the right-turn pocket and spill into the adjacent travel lane. This spillback condition would occur during the most congested period of the day and would not be a continuous condition. Constraints in the roadway cross section preclude widening the roadway to extend the right-turn pocket while also maintaining the upstream bike lane. Following construction of project off-site improvements, the southbound left-turn queue at the N Golden State Blvd/W Herndon Ave intersection may extend beyond the turn pocket and spill into the adjacent travel lane by approximately 50’, depending on final construction of the improvement. This spillback condition would occur during the most congested period of the day and would not be a continuous condition. Therefore, the project impact would be less than significant.

Emergency Access
The project provides emergency access to and within the site via the driveways on N Riverside Dr, existing on-site easements, and on-site drive aisles. Therefore, the impact of the project on emergency access would be less than significant.

Appendix E
Energy Technical Report

Prepared for
Ascent Environmental, Inc.

Sacramento, California
Project Number
1690023335
Date
June 2023

COSTCO COMMERCIAL CENTER

ENERGY TECHNICAL REPORT

FRESNO, CALIFORNIA
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Contents Ramboll

CONTENTS

1. INTRODUCTION 1

1.1 Existing Conditions 1

1.2 Project Analysis 1

2. ENERGY ENVIRONMENTAL AND REGULATORY OVERVIEW 2

2.1 General Setting 2

2.1.1 Energy Production and Distribution 2

2.1.2 Energy Consumption 3

2.2 Regulatory Overview 4

2.2.1 Federal Programs 4

2.2.2 State Programs 6

2.2.3 Local Programs 16

3. SIGNIFICANCE THRESHOLDS 17

4. METHODOLOGY FOR DEVELOPMENT OF ENERGY PROJECTIONS 19

4.1 Construction Equipment & Activities 19

4.2 Operational Energy Requirements 20

4.2.1 Electricity 20

4.2.2 Natural Gas 20

4.2.3 Fuel Usage 20

5. PROJECT INVENTORY IN CONTEXT 22

5.1 Threshold 1 22

5.1.1 Energy Requirements and Energy Use Efficiencies 22

5.1.2 Local and Regional Energy Supplies 23

5.1.3 Peak and Base Period Demands 24

5.1.4 Existing Energy Standards 25

5.1.5 Energy Resources 26

5.1.6 Transportation Energy Use 26

5.1.7 Summary 27

5.2 Threshold 2 27
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CONTENTS (CONTINUED)
TABLES
Table 4-1: Construction Off-Road Equipment Fuel Consumption Table 4-2: Construction On-Road Fuel Consumption
Table 4-3: Electricity Consumption
Table 4-4: Natural Gas Consumption
Table 4-5: Gasoline Consumption
Table 4-6: Diesel Consumption
Table 4-7: Electricity Consumption from Vehicles
Table 5-1: Construction Energy Resource Summary
Table 5-2: Operation Energy Resource Summary

APPENDICES
Appendix A – CalEEMod Output
Appendix B – State and Local Consistency Analyses
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Acronyms and Abbreviations Ramboll

ACRONYMS AND ABBREVIATIONS
Acronym Definition
AB Assembly Bill
ACC Advanced Clean Cars
AEI annual emissions inventory
ATC Authority to Construct
ATCM Airborne Toxic Control Measure
CalEEMod® California Emissions Estimator Model®
CalGreen California Green Building Standards Code
CARB California Air Resources Board
CCR California Code of Regulations
CEC California Energy Commission
CEQA California Environmental Quality Act
COG Council of Governments
CO2 carbon dioxide
CO2e carbon dioxide equivalent
CPUC California Public Utilities Commission
CUP conditional use permit
CY cubic yard
CVRP Clean Vehicle Rebate Project
DOT U.S. Department of Transportation
EIR Environmental Impact Report
EPA U.S. Environmental Protection Agency
EV Electric vehicle
GHG greenhouse gas
GHS grid harmonization strategies
GWh gigawatt hours
hp horsepower
HOV high-occupancy vehicle
HVAC Heating, Ventilation and Air Conditioning
IEPR Integrated Energy Policy Report
ISTEA Intermodal Surface Transportation Efficiency Act
kWh kilowatt hours
LCFS Low Carbon Fuel Standard
LEED Leadership in Energy and Environmental Design
LLC Limited Liability Company
LPG liquefied petroleum gas
MCY million cubic yards
mpg miles per gallon
MPO Metropolitan Planning Organization
MSW municipal solid waste
MWh megawatt hours
NEMA National Electric Manufacturers Association
NHTSA National Highway Traffic Safety Administration
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ACRONYMS AND ABBREVIATIONS (CONTINUED)
Acronym Definition
NOX oxides of nitrogen
MM Mitigation measure
PG&E Pacific Gas and Electric Company
PM particulate matter
RCRA Resource Conservation and Recovery Act
RPS Renewables Portfolio Standard
RTPs regional transportation plans
SAFE Safer Affordable Fuel-Efficient
SB Senate Bill
SCE Southern California Edison
SCS Sustainable Communities Strategy
SDG&E San Diego Gas & Electric
SUVs sport utility vehicles
TDV time dependent valuation
TEA Transportation Efficiency Act
tpd tons per day
VDECS Verified Diesel Emission Control Strategies
VMT vehicle miles travelled
VW Volkswagen
ZEV zero emission vehicle
ZNE zero net energy
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1. INTRODUCTION
Ramboll US Consulting, Inc. (Ramboll) was retained to prepare an Energy Technical Report for the proposed Costco Commercial Center (Project).

This Energy Technical Report analyzes the Project’s energy impacts from construction and operations. In particular, this report describes the existing setting of the Project site, describes the relevant regulatory background, discusses the methodology used to evaluate energy impacts related to the Project, and evaluates potential impacts related to energy that would be affected as a result of implementation of the Project.

1.1 Existing Conditions
The existing 22.4-acre site is currently undeveloped, located within the Bullard Community Plan Area, and designated by both the General Plan and zoning as Community Commercial.

The location of the site is in Fresno, California at West Herndon Avenue and North Riverside Drive.

1.2 Project Analysis
The Costco Wholesale Corporation (Costco) proposes to construct the Costco Commercial Center, which comprises a new Costco facility (including loading docks and internal space to provide last-mile home delivery of big and bulky items) with an attached tire center and a detached gas station and drive-through car wash in the City of Fresno.

The project would develop a new Costco retail building; gas station; car wash; and associated parking areas, driveways, and other supporting infrastructure. Costco Wholesale is proposing to construct a wholesale retail facility with approximately 178,000 square feet (sq. ft.); of which approximately 57,000 sq. ft. would be reserved for storage and receiving at the northeast corner of W. Herndon Ave. and N. Riverside Dr (APN 50302012). The project involves the construction of a Costco retail facility that includes an attached tire center, as well as a detached gas station and a drive-through car wash. The project would include a Costco members-only gas station on the northern portion of the project site adjacent to West Spruce Avenue. The gas dispensing facility would include an approximately 11,500 square-foot canopy and a 125 square-foot controller enclosure. There would be four covered fueling islands, each with four two-sided fuel dispensers to provide for the fueling of eight cars at each island, for a total of 32 fueling positions. A Costco members-only automated carwash would be located at the northeastern corner of the project site, adjacent to the gas station. The car wash structure would be approximately 4,800 sq. ft. The project would have its main access points along North Riverside Drive and include approximately 889 parking stalls. The project is requesting conditional use permits for Large-Format Retail and alcohol sales, as well as a General Plan Amendment to reclassify the portion of W. Herndon Ave. fronting the project site from Expressway to Superarterial.

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2. ENERGY ENVIRONMENTAL AND REGULATORY

OVERVIEW

2.1 General Setting

2.1.1 Energy Production and Distribution
Among the states, California ranks seventh in the nation in production of crude oil, 14th in production of natural gas, second in generation of hydroelectric power, and first as a producer of electricity from biomass, geothermal, and solar energy.1 California produces approximately 10% of the natural gas used in the state; approximately 90% of the natural gas used in California is imported from Canada, the Southwest, and the Rocky Mountains region of the United States. Over half of the crude oil refined in California is from foreign countries, including Saudi Arabia, Iraq, Ecuador, and Colombia. Additional crude oil is imported from Alaska. Over one-fourth of California’s electricity is from out-of-state locations in the Pacific Northwest and the Southwest.2
Electricity Supply
The production of electricity requires the combustion, consumption, or conversion of other energy resources, including water, wind, oil, natural gas, coal, solar, geothermal, and nuclear. Of the electricity that is generated within the state in 2020, 48.4% is generated by natural gas-fired power plants, 15.4% by solar, 11.2% by hydroelectric, 8.5% by nuclear power plants, 7.2% by wind, and a remaining 9.3% by other renewables.3 For Fresno County, Pacific Gas and Electric Company (PG&E) is the primary supplier of electricity to businesses and residents of the area. PG&E’s 70,000-square-mile service area covers both Northern and Central California. By the end of 2020, about 30.6 percent of the energy delivered to PG&E’s customers came from eligible renewable energy-related projects.4
Transportation Fuels Supply
Most petroleum fuel refined in California is for use in on-road motor vehicles and is refined within California to meet state-specific formulations required by the California Air Resources Board (CARB). The major categories of petroleum fuels are gasoline and diesel for passenger vehicles, transit, and rail vehicles; and fuel oil for industry and emergency electrical power generation. Other liquid fuels include kerosene, jet fuel, and residual fuel oil for marine vessels.

California’s oil fields make it the third-largest petroleum-producing state in the United States, behind Texas and North Dakota (federal offshore production is the biggest producer 1 U.S. Energy Information Administration. 2021. California State Profile and Energy Estimates: Profile Overview.

Available online at: http://www.eia.gov/state/?sid=CA. Accessed: January 2022. 2 U.S. Energy Information Administration. 2021. California State Profile and Energy Estimates: Profile Analysis.

Available online at: https://www.eia.gov/state/analysis.cfm?sid=CA. Accessed: January 2022. 3 California Energy Commission. 2020. 2020 Total System Electric Generation in Gigawatt Hours. Available online at: https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/2020-total-systemelectric-generation. Accessed: January 2022. 4 Pacific Gas and Electric Company. 2021. Corporate Responsibility and Sustainability Report 2021. Executive Summary. Available online at:
https://www.pgecorp.com/corp_responsibility/reports/2021/assets/PGE_CRSR_2021_Executive_Summary.pdf.

Accessed: January 2022.

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in the United States). Crude oil is moved from area to area within California through a network of pipelines that carry it from both onshore and offshore oil wells to the refineries that are located in the San Francisco Bay Area, the Los Angeles area, and the Central Valley.

Currently, 14 petroleum refineries operate in California, processing approximately 1.8 million barrels per day of crude oil.5
Other transportation fuel sources are alternative fuels, such as methanol and denatured ethanol (alcohol mixtures that contain no less than 70% alcohol), natural gas (compressed or liquefied), liquefied petroleum gas (LPG), hydrogen, and fuels derived from biological materials (i.e., biomass).

2.1.2 Energy Consumption
Electricity Consumption
Californians consumed 279,510 gigawatt hours (GWh) of electricity in 2020.6 Of this total, Fresno County consumed 8,018 GWh.7
Transportation Sector Fuels Consumption
The transportation sector is a major end use of energy in California, accounting for approximately 39.3% of total state-wide energy consumption in 2019, the most recent year for which data is available.8 In addition, energy is consumed in connection with construction and maintenance of transportation infrastructure, such as streets, highways, freeways, rail lines, and airport runways. California’s 28.4 million vehicles consume more than 12.9 billion gallons of gasoline and more than 3 billion gallons of diesel each year.9 In Fresno County, about 313 million gallons of gasoline and 131 million gallons of diesel are consumed each year by approximately 708,000 vehicles.10
5 U.S. Energy Information Administration. 2021. Petroleum & Other Liquids. Number and Capacity of Petroleum Refineries. Available online at: https://www.eia.gov/dnav/pet/PET_PNP_CAP1_DCU_SCA_A.htm. Accessed:

January 2022.
6 A watt hour is a unit of energy equivalent to one watt of power expended for one hour. For example, a typical light bulb is 60 watts, meaning that if it is left on for one hour, 60-watt hours have been used. One kilowatt equals 1,000 watts. The consumption of electrical energy by homes and businesses is usually measured in kilowatt hours (kWh). Some large businesses and institutions also use megawatt hours (MWh), where one MWh equals 1,000 kWh. One gigawatt equals one thousand (1,000) megawatts, or one million (1,000,000) kilowatts.

The energy output of large power plants over long periods of time, or the energy consumption of jurisdictions, can be expressed in gigawatt hours (GWh).
7 Electricity data for Fresno County and the State of California in 2020 are obtained from the California Energy Commission, electricity consumption by county. Available at: https://ecdms.energy.ca.gov/elecbycounty.aspx.

Accessed: January 2022.
8 U.S. Energy Information Administration. 2020. California State Profile and Energy Estimates: California Energy Consumption by End-Use Sector, 2019. Available online at: http://www.eia.gov/state/?sid=CA#tabs-2.

Accessed: January 2022.
9 CARB. EMFAC2021. Emissions Inventory - State-wide for Calendar Year 2020. Available online at:
https://arb.ca.gov/emfac/. Accessed: January 2022.
10 CARB. EMFAC2021. Emissions Inventory – Fresno County for Calendar Year 2020. Available online at:
https://arb.ca.gov/emfac/. Accessed: February 2022.

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2.2 Regulatory Overview

2.2.1 Federal Programs

2.2.1.1 Energy Policy and Conservation Act
The Energy Policy and Conservation Act of 1975 was established in response to the oil crisis of 1973, which increased oil prices due to a shortage of reserves. The Act requires that all vehicles sold in the U.S. meet certain fuel economy goals, known as the Corporate Average Fuel Economy standards. The National Highway Traffic Safety Administration (NHTSA) of the U.S. Department of Transportation (DOT) administers the Corporate Average Fuel Economy program, and the U.S. Environmental Protection Agency (EPA) provides the fuel economy data.

In April 2010, the EPA and NHTSA issued a final rulemaking establishing new federal fuel economy standards for model years 2012 to 2016 passenger cars and light-duty trucks. For model year 2012, the fuel economy standards for passenger cars, light trucks, and combined cars and trucks were 33.3 miles per gallon (mpg), 25.4 mpg, and 29.7 mpg, respectively.11 These standards increase progressively up to 37.8 mpg, 28.8 mpg, and 34.1, respectively, for model year 2016. In subsequent rulemakings, the agencies extended the national program of fuel economy standards to passenger vehicles and light-duty trucks of model years 2017-2025, culminating in fuel economy of 54.5 mpg by model year 2025,12 as well as to medium- and heavy-duty vehicles of model years 2014-2018, including large pickup trucks and vans, semi-trucks, and all types and sizes of work trucks and buses. 13 In August 2016, the EPA and NHTSA adopted the next phase (Phase 2) of the fuel economy and GHG standards for medium- and heavy-duty trucks, which apply to vehicles with model year 2018 and later.14 In response to the EPA’s adoption of the Phase 2 standards, CARB staff brought a proposed California Phase 2 program before its Board in 2017; and the Board approved the program in March 2018.15
In 2018, the EPA and NHTSA proposed to amend certain existing Corporate Average Fuel Economy standards for passenger cars and light trucks and establish new standards, covering model years 2021-2026. Compared to maintaining the post-2020 standards now in place, the proposal would increase U.S. fuel consumption.16 11 United States Environmental Protection Agency (EPA) and United States Department of Transportation (DOT). 2010. Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards.

Final Rule. 75 Fed. Reg. 25324-25728.
12 United States Environmental Protection Agency (EPA) and United States Department of Transportation (DOT). 2012. 2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy Standards; Final Rule. 77 Fed. Reg. 62623.
13 United States Environmental Protection Agency (EPA) and United States Department of Transportation (DOT). 2011. Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles. 76 Fed. Reg. 57106.
14 USEPA. Available at: https://www.epa.gov/regulations-emissions-vehicles-and-engines/final-rule-greenhousegas-emissions-and-fuel-efficiency. Accessed: January 2022. 15 CARB. CA Phase 2 GHG webpage: https://ww2.arb.ca.gov/our-work/programs/greenhouse-gas-standardsmedium-and-heavy-duty-engines-and-vehicles/phase2. Accessed: January 2022. 16 Federal Register. 2018. The Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021-2026 Passenger Cars and Light Trucks. Available at: https://www.federalregister.gov/documents/2018/08/24/2018- 16820/the-safer-affordable-fuel-efficient-safe-vehicles-rule-for-model-years-2021-2026-passenger-cars-and.

Accessed: January 2022.

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In 2019, the EPA and NHTSA announced the One National Program Rule, which allows the federal government to set the standard for uniform fuel economy and greenhouse gas emissions of automobiles and light duty trucks. This rule pre-empts state and local programs from setting the national standard, which includes California’s GHG and ZEV programs.17 In December 2021, EPA finalized revised national greenhouse gas emissions standards for passenger cars and light trucks for Model Years 2023-2026.18

2.2.1.2 Energy Policy Act of 2005 and Energy Independence and Security Act of 2007
The Energy Policy Act of 2005 seeks to reduce reliance on non-renewable energy resources and provide incentives to reduce current demand on these resources. For example, under the Energy Policy Act, consumers and businesses can attain federal tax credits for purchasing fuel-efficient appliances and products. Because driving fuel-efficient vehicles and installing energy-efficient appliances can provide many benefits, such as lower energy bills, increased indoor comfort, and reduced air pollution, businesses are eligible for tax credits for buying hybrid vehicles, building energy-efficient buildings, and improving the energy efficiency of commercial buildings. Additionally, tax credits are given for the installation of qualified fuel cells, stationary microturbine power plants, and solar power equipment.

The Energy Policy Act of 2005 also established the first renewable fuel volume mandate in the United States. The original Renewable Fuel Standard program required 7.5 billion gallons of renewable fuel to be blended into gasoline by 2012. Under the Energy Independence and Security Act of 2007, the Renewable Fuel Standard program was expanded to include diesel and to increase the volume of renewable fuel required to be blended into transportation fuel from 9 billion gallons in 2008 to 36 billion gallons by 2022.

2.2.1.3 American Recovery and Reinvestment Act
The American Recovery and Reinvestment Act of 2009 was passed in response to the economic crisis of the late 2000s, with the primary purpose of maintaining existing jobs and creating new jobs. Among the secondary objectives of the American Recovery and Reinvestment Act was investment in “green” energy programs, including funding the following through grants, loans, or other mechanisms: private companies developing renewable energy technologies; local and state governments implementing energy efficiency and clean energy programs; research in renewable energy, biofuels, and carbon capture; and development of high efficiency or electric vehicles. 19

2.2.1.4 Intermodal Surface Transportation Efficiency Act The Intermodal Surface Transportation Efficiency Act (ISTEA) of 1991 promotes the development of inter-modal transportation systems to maximize mobility as well as address national and local interests in air quality and energy. The Intermodal Surface Transportation Efficiency Act contains factors that metropolitan planning organizations (MPO), such as the 17 EPA. 2019. Trump Administration Announces One National Program Rule on Federal Preemption of State Fuel Economy Standards. Available at: https://www.epa.gov/newsreleases/trump-administration-announces-onenational-program-rule-federal-preemption-state-fuel. Accessed: January 2022. 18 United States Environmental Protection Agency. 2021. Regulations for Greenhouse Gas Emissions from Passenger Cars and Trucks. Available at: https://www.epa.gov/regulations-emissions-vehicles-andengines/regulations-greenhouse-gas-emissions-passenger-cars-and. Accessed: January 2022. 19 United States Environmental Protection Agency (EPA). 2009. Recovery: EPA Gets Involved. Available at:
https://archive.epa.gov/recovery/web/html/. Accessed: January 2022.

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Kern Council of Governments (Kern COG), are to address in developing transportation plans and programs, including some energy-related factors. To meet the ISTEA requirements, MPOs have adopted explicit policies defining the social, economic, energy, and environmental values that guide transportation decisions in their respective metropolitan areas. The planning process for specific projects would then address these policies. Another requirement of the ISTEA is to consider the consistency of transportation planning with federal, state, and local energy goals. Through this requirement, energy consumption is expected to be a decision criterion, along with cost and other values to determine the best transportation solution.

2.2.1.5 Transportation Equity Act for the 21st Century
The Transportation Equity Act for the 21st Century (“TEA-21”) was signed into law in 1998 and builds upon the initiatives established in the ISTEA legislation discussed above. TEA-21 authorizes highway, highway safety, transit, and other efficient surface transportation programs. TEA-21 continues the program structure established for highways and transit under ISTEA, such as flexibility in the use of funds, emphasis on measures to improve the environment, and focus on a strong planning process as the foundation of good transportation decisions. TEA-21 also provides for investment in research and its application to maximize the performance of the transportation system through, for example, deployment of Intelligent Transportation Systems, to help improve operations and management of transportation systems and vehicle safety.

2.2.2 State Programs

2.2.2.1 AB 32 and SB 32 (State-wide GHG Reductions with Energy Co-Benefits) The California Global Warming Solutions Act of 2006 (AB 32) was signed into law in September 2006.20 The law instructed CARB to develop and enforce regulations for the reporting and verification of state-wide GHG emissions. The bulk of GHG emissions in California are carbon dioxide that result from fossil fuel consumption. Therefore, a reduction in GHG emissions typically translates into reduced fuel and increased energy efficiency. The bill directed CARB to set a state-wide GHG emission limit based on 1990 levels, to be achieved by 2020.

AB 32 requires CARB to adopt rules and regulations in an open public process to achieve the maximum technologically feasible and cost-effective GHG reductions. In December 2008, CARB adopted its Climate Change Scoping Plan: A Framework for Change (Scoping Plan), which included the state’s strategies for achieving AB 32’s reduction targets. These strategies are implemented with additional rules and regulations of relevance to energy analysis, such as the Advanced Clean Cars Program, the low carbon fuel standard (LCFS), Title 24 building efficiency standards, and the Renewable Portfolio Standard (RPS). These are discussed further below.

Enacted in 2016, Senate Bill (SB) 32 (Pavley, 2016) codifies a 2030 GHG emissions reduction goal and requires CARB to ensure that state-wide GHG emissions are reduced to 40 percent below 1990 levels by 2030. Similar to AB 32, a reduction in GHG emissions typically corresponds with a reduction in energy usage as the bulk of GHGs result from the combustion of fossil fuel.
20 CARB. Assembly Bill 32 Overview. 2006a. Available at: http://www.arb.ca.gov/cc/ab32/ab32.htm. Accessed:

January 2022.

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2.2.2.2 SB 350 (Clean Energy and Pollution Reduction Act of 2015) The Clean Energy and Pollution Reduction Act of 2015 (SB 350) increases California's renewable electricity procurement goal from 33 percent by 2020 to 50 percent by 2030. This bill requires the State Energy Resources Conservation and Development Commission to establish annual targets for state-wide energy efficiency savings and demand reduction that will achieve a cumulative doubling of state-wide energy efficiency savings in electricity and natural gas final end uses of retail customers by January 1, 2030.

2.2.2.3 2020 Integrated Energy Policy Report Update
The 2020 Integrated Energy Policy Report (IEPR) Update provides an assessment of major energy trends and issues for a variety of energy sectors, as well as policy recommendations.21 Prepared by the California Energy Commission (CEC), this report details the key energy issues facing California and develops potential strategies to address these issues. The 2020 IEPR Update includes a discussion of several strategies to reduce climate change impacts and lessen energy consumption and recommendations for each topic.

Examples include a discussion of California’s transportation future and the transition to zeroemission vehicles, the potential of microgrids to contribute to a clean and resilient energy system, and California’s energy demand outlook updated to reflect the global pandemic. The assessments and forecasted energy demand within this report will be used by the CEC to develop future energy policies.

2.2.2.4 Title 24 Building Energy Efficiency Standards
The California Green Building Standards Code, as specified in Title 24, Part 11 of the California Code of Regulations, commonly referred to as CalGreen Building Standards (CalGreen), establishes voluntary and mandatory standards to improve public health, safety, and general welfare by enhancing the design and construction of buildings through the use of building concepts having a positive environmental impact and encouraging sustainable construction practices in five categories: planning and design, energy efficiency, water efficiency and conservation, material conservation and resource efficiency, and environmental quality. The provisions of this code apply to the planning, design, operation, construction, replacement, use and occupancy, location, maintenance, removal and demolition of every building or structure or any appurtenances connected or attached to such building structures throughout California. Examples of CalGreen provisions include reducing indoor water use, moisture sensing irrigation systems for landscaped areas, construction waste diversion goals, and energy system inspections. CalGreen is periodically amended; the most recent 2019 standards became effective on January 1, 2020.

The Energy Efficiency Standards for Residential and Nonresidential Buildings, as specified in Title 24, Part 6, of the California Code of Regulations, were established in 1978 in response to a legislative mandate to reduce California’s energy consumption. The standards are updated periodically to allow consideration and possible incorporation of new energy efficiency technologies and methods for building features such as space conditioning, water heating, lighting, and whole envelope. The 2005, 2008, and 2013 updates to the efficiency standards included provisions such as cool roofs on commercial buildings, increased use of skylights, and higher efficiency lighting, HVAC, and water heating systems. Additionally, 21 California Energy Commission. 2020. 2020 Integrated Energy Policy Report Update. Available at:
https://www.energy.ca.gov/data-reports/reports/integrated-energy-policy-report/2020-integrated-energypolicy-report-update. Accessed: January 2022.

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some standards focused on larger energy saving concepts such as reducing loads at peak periods and seasons and improving the quality of such energy-saving installations. Past updates to the Title 24 standards have proven very effective in reducing building energy use, with the 2013 update estimated to reduce energy consumption in residential buildings by 25% and energy consumption in commercial buildings by 30%, relative to the 2008 standards.22 The 2016 updates included additional high efficiency lighting requirements, high performance attic and walls, and higher efficiency water and space heaters. The 2016 standards were expected to reduce residential electricity consumption by 28% and nonresidential electricity by 5%.23 The CEC has developed and adopted 2019 standards, which went into effect on January 1, 2020.

The 2019 Title 24 standards are the currently applicable building energy efficiency standards, and became effective on January 1, 2020.24 The 2019 updates include a requirement for solar photovoltaic systems for new homes, requirements for newly constructed healthcare facilities, additional high efficiency lighting requirements, high performance attic and walls, higher efficiency water and space heaters, and high efficiency air filters. Relative to the 2016 standards, the 2019 standards are expected to reduce high-rise residential and nonresidential electricity consumption by approximately 10.7% and natural gas consumption by 1% and require new low-rise residential buildings to achieve zero net electricity consumption using a combination of building efficiency and on-site renewable electricity generation.25 As the Project phasing schedule anticipates build out as late as 2035, further reductions can be anticipated from future Title 24 code cycles. Thus, this analysis represents a conservative estimate of energy-related emissions. Estimated Project energy use rates for both the unmitigated and mitigated case are based on data provided by ConSol, which is described in more detail in Section 4.2 below.

The California Public Utilities Commission, CEC, and CARB also have a shared, established goal of achieving Zero Net Energy (ZNE) for new construction in California. The key policy timelines include: (1) all new residential construction in California will be ZNE by 2020, and (2) all new commercial construction in California will be ZNE by 2030. The ZNE goal generally means that new buildings must use a combination of improved efficiency and renewable energy generation to meet 100 percent of their annual energy need, as specifically defined by the CEC:
“A ZNE Code Building is one where the value of the energy produced by on-site renewable energy resources is equal to the value of the energy consumed annually by the building, at the level of a single ‘project’ seeking development entitlements and building code permits, measured using the [CEC]’s Time Dependent Valuation (TDV) metric. A ZNE Code Building meets an Energy Use Intensity value designated in the 22 CEC. 2012. Energy Commission Approves More Efficient Buildings for California's Future. Available at:
https://planning.lacity.org/eir/CrossroadsHwd/deir/files/references/C17.pdf. Accessed: January 2022. 23 CEC. 2015. 2016 Building Energy Efficiency Standards Adoption Hearing. Available at:
https://web.archive.org/web/20190602115405/http://www.energy.ca.gov/title24/2016standards/rulemaking/do cuments/2015-06-10_hearing/2015-06-10_Adoption_Hearing_Presentation.pdf. Accessed: January 2022. 24 CEC. 2019. California’s Energy Efficiency Standards for Residential and Nonresidential Buildings. Available online at: https://www.energy.ca.gov/title24/2019standards/. Accessed: January 2022. 25 CEC. 2018. 2019 Title 24 Impact Analysis. June. Available at:
https://web.archive.org/web/20190601203553/https://www.energy.ca.gov/title24/2019standards/post_adoptio n/documents/2019_Impact_Analysis_Final_Report_2018-06-29.pdf. Accessed: January 2022.

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Building Energy Efficiency Standards by building type and climate zone that reflect best practices for highly efficient buildings.”26
While the adopted 2019 Title 24 standards do not achieve the 2020 Zero Net Energy goal, they do move the State further along the path to achieving this goal. The CEC has more recently focused on grid harmonization strategies (GHS), to bring maximum benefits to the grid, environment, and occupants; and GHG emissions reductions.27 At the time of this writing, the CEC had adopted the 2022 Energy Code. In December 2021, the California Building Standards Commission approved the code for inclusion into the California Building Standards Code. The Energy Code encourages efficient electric heat pumps, establishes electric-ready requirements for new homes, expands solar photovoltaic and battery storage standards, strengthens ventilation standards, and more. Buildings whose permit applications are applied for or after January 1, 2023, must comply with the 2022 Energy Code.

2.2.2.5 Renewables Portfolio Standard
SB 1078 (2002) requires retail sellers of electricity, including investor-owned utilities and community choice aggregators, to obtain at least 20 percent of their energy supply from renewable sources by 2017. SB 107 (2006) changed that target date to 2010. In November 2008, then-Governor Schwarzenegger signed Executive Order S-14-08, which expanded the state’s Renewable Portfolio Standard to 33 percent renewable power by 2020. In April 2011, then-Governor Brown signed SB 2X, which legislated the prior Executive Order S-14-08 renewable standard. SB 350 (2015) set an additional RPS goal of 50 percent renewables by 2030. And SB 100 (2018) accelerated and extended again the RPS – requiring achievement of a 50 percent RPS by 2026 and a 60 percent RPS by 2030. SB 100 also established a state policy goal to achieve 100 percent carbon-free electricity by 2045.

2.2.2.6 Mobile Source Regulations
SB 743 (Transportation Analysis under CEQA)
Public Resources Code Section 21099(c)(1), as codified through enactment of SB 743, was enacted with the intent to change the focus of transportation analyses conducted under the California Environmental Quality Act (CEQA). SB 743 reflects a legislative policy to balance the needs of congestion management with state-wide goals related to infill development, promotion of public health through active transportation, and reduction of GHG emissions. As finalized in December 2018, amendments to the State CEQA Guidelines adopted in furtherance of SB 743 establish vehicle miles travelled (VMT), in lieu of level of service, as the new metric for transportation analysis. Implementation of SB 743 is anticipated to improve the efficiency of transportation fuels consumption.

SB 375 (Land Use Planning)
SB 375, the Sustainable Communities and Climate Protection Act of 2008, supports the State’s climate action goals to reduce GHG emissions through coordinated transportation and land use planning. SB 375 required CARB to establish GHG emission reduction targets (Regional Targets) for each metropolitan planning region. On September 23, 2010, CARB 26 CEC, 2015 Integrated Energy Policy Report (2015), p. 41. 27 CEC. 2018. The 2019 Building Energy Efficiency Standards ZNE Strategy. September 11. Available at:
https://www.cesa.org/wp-content/uploads/CESA-webinar-slides-9.11.2018.pdf. Accessed: January 2022.

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10 Energy Environmental and Regulatory Overview Ramboll adopted Regional Targets applying to the years 2020 and 2035. In 2011, CARB adopted Regional Targets of 5% for 2020 and 10% for 2035 for the area under the jurisdiction of Fresno COG. These targets were in place through September 30, 2018. In March 2018, CARB approved updated regional targets of 6% for 2020 and 13% for 2035 for Fresno COG, which will be applied by Fresno COG in future planning cycles.

SB 375 requires MPOs, including Fresno COG, to incorporate a “sustainable communities strategy” (SCS) in their regional transportation plans (RTPs) that will achieve the GHG emission Reduction Targets set by CARB, primarily by reducing VMT from light-duty vehicles through development of more compact, complete, and efficient communities. Fresno COG most recently prepared the 2018 Regional Transportation Plan and Sustainable Communities Strategy28 to fulfill this requirement; and the CARB accepted Fresno COG’s GHG quantification demonstration for that plan, which demonstrates achievement of the targets set prior to 2018.29 At this time, the Fresno COG is working towards a Regional Transportation Plan Update, which is expected to be adopted in mid-2022.

Clean Cars
In January 2012, CARB approved the Advanced Clean Cars Program, which established an emissions control program for cars and light-duty trucks (such as SUVs, pickup trucks, and minivans) of model years 2017-2025. When the program is fully implemented, new vehicles would emit 75% less smog-forming pollutants than the average new car sold today, and greenhouse gas emissions would be reduced by nearly 35%. This Program would help reduce fossil fuel usage for internal combustion engine powered vehicles.

Commercial Motor Vehicle Idling Regulation
In July 2004, CARB initially adopted an Airborne Toxic Control Measure (ATCM) to limit idling of diesel-fueled commercial motor vehicles (idling ATCM) and subsequently amended it in October 2005, October 2009, and December 2013. This ATCM is set forth in Title 13, California Code of Regulations, Section 2485, and requires, among other things, that drivers of diesel-fueled commercial motor vehicles with gross vehicle weight ratings greater than 10,000 pounds, including buses and sleeper berth equipped trucks, not idle the vehicle’s primary diesel engine longer than five minutes at any location. This anti-idling regulation helps to reduce fuel consumption by reducing engine usage. The ATCM also requires owners and motor carriers that own or dispatch these vehicles to ensure compliance with the ATCM requirements. The regulation consists of new engine and in-use truck requirements and emission performance requirements for technologies used as alternatives to idling the truck’s main engine. Under the new engine requirements, 2008 and newer model year heavy-duty diesel engines need to be equipped with a non-programmable engine shutdown system that automatically shuts down the engine after five minutes of idling or optionally meet a stringent oxides of nitrogen idling emission standard.
28 Fresno Council of Governments. 2018. The 2018 Regional Transportation Plan and Sustainable Communities Strategy. Available at: https://www.fresnocog.org/project/regional-transportation-plan-rtp/. Accessed: January 2022.
29 CARB. 2020. Technical Evaluation of the Greenhouse Gas Emissions Reduction Quantification for Fresno Council of Governments’ SB 375 2018 Sustainable Communities Strategy. Available at:
https://ww2.arb.ca.gov/sites/default/files/2020-
06/Technical_Evaluation_of_the_GHG_Emissions_Reduction_Quantification_for_the_FCOG_SB_375_SCS_Septe mber_2019.pdf. Accessed: January 2022.

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11 Energy Environmental and Regulatory Overview Ramboll In-Use Off-Road Diesel Fueled Fleets Regulation
In May 2008, CARB approved the In-Use Off-Road Diesel Fueled Fleets Regulation (Off-Road Regulation), which was later amended in December 2009, July 2010, and December 2011.

The overall purpose of the Off-Road Regulation is to reduce emissions of oxides of nitrogen (NOX) and particulate matter (PM) from off-road diesel vehicles operating within California.

The regulation applies to all self-propelled off-road diesel vehicles 25 horsepower (hp) or greater used in California and most two-engine vehicles. The Off Road Regulation:
x Imposes limits on idling (i.e., fleets must limit unnecessary idling to 5 minutes), requires a written idling policy, and requires a disclosure when selling vehicles; x Requires all vehicles to be reported to CARB (using the Diesel Off-Road Online Reporting System, DOORS) and labelled;
x Restricts the adding of older vehicles into fleets starting on January 1, 2014; and x Requires fleets to reduce their emissions by retiring, replacing, or repowering older engines, or installing Verified Diesel Emission Control Strategies (VDECS) (i.e., exhaust retrofits).

The anti-idling component of this Off-Road Regulation helps to reduce fuel consumption by reducing engine usage.

Tractor-Trailer Greenhouse Gas Regulation
CARB’s Tractor-Trailer Greenhouse Gas regulation reduces the energy consumption of large trucks. CARB developed this regulation to make heavy-duty tractors more fuel efficient. Fuel efficiency is improved by requiring the use of aerodynamic tractors and trailers that are also equipped with low rolling resistance tires. The tractors and trailers subject to this regulation must either use EPA’s SmartWay (SmartWay) certified tractors and trailers or retrofit their existing fleet with SmartWay verified technologies. The SmartWay certification process is part of their broader voluntary program called the SmartWay Transport Partnership Program.

The regulation applies primarily to owners of 53-foot or longer box-type trailers, and owners of the heavy-duty tractors that pull them on California highways. These owners are responsible for replacing or retrofitting their affected vehicles with compliant aerodynamic technologies and low rolling resistance tires. All owners regardless of where their vehicle is registered must comply with the regulation when they operate their affected vehicles on California highways. Besides the owners of these vehicles, drivers, motor carriers, California-based brokers and California-based shippers that operate or use them also share in the responsibility for compliance with the regulation.

Zero Emission Vehicles
Zero emission vehicles (ZEVs) include hydrogen fuel cell electric vehicles and plug-in electric vehicles, such as battery electric vehicles and plug-in hybrid electric vehicles.

In 2012, Governor Brown issued EO B-16-2012, which calls for the increased penetration of ZEVs into California’s vehicle fleet in order to help California achieve a reduction of GHG emissions from the transportation sector equalling 80 percent less than 1990 levels by 2050.

In furtherance of that state-wide target for the transportation sector, the EO also calls upon CARB, the CEC and the California Public Utilities Commission to establish benchmarks that will: (1) allow over 1.5 million ZEVs to be on California roadways by 2025, and (2) provide the State’s residents with easy access to ZEV infrastructure. EO B-16-2012 specifically Costco Commercial Center
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In 2018, Governor Brown also issued EO B-48-18, which launched an eight-year initiative to accelerate the sales of ZEVs through a mix of rebate programs and infrastructure improvements. The EO also sets a new target of five million ZEVs in California by 2030 and includes funding for multiple state agencies to increase EV charging infrastructure and provide purchase rebates/incentives.

In furtherance of the State’s ZEV penetration goals, in February 2013, the Governor’s Interagency Working Group on Zero-emission Vehicles issued the 2013 ZEV Action Plan: A roadmap toward 1.5 million zero-emission vehicles on California roadways by 2025.31 The 2013 ZEV Action Plan identifies four broad goals for State government to advance ZEVs:
1) Complete needed infrastructure and planning; 2) Expand consumer awareness and demand; 3) Transform fleets; and 4) Grow jobs and investment in the private sector. As part of these goals, some highlighted strategies and actions include: i) supporting ZEV infrastructure planning and investment by private entities; ii) enabling universal access to ZEV infrastructure for California drivers; iii) reducing upfront purchase costs for ZEVs; iv) promoting consumer awareness of ZEVs; and v) helping to expand ZEVs in bus fleets.

The Action Plan discusses the challenges of ZEV expansion, which include the need to enable electric vehicle chargers in homes, increase consumer awareness, address up-front costs and operational limitations, and address that ZEVs are not commercially available for all categories of vehicles.

In October 2016, the Governor's Interagency Working Group on Zero-Emission Vehicles issued the 2016 ZEV Action Plan: A roadmap toward 1.5 million zero-emission vehicles on California roadways by 2025.32 This report provides an update on progress toward achieving the 2013 goals and highlights the following four top priorities for the upcoming years:
1) Raise consumer awareness and education about ZEVs; 2) Ensure ZEVs are accessible to a broad range of Californians; 3) Make ZEV technologies commercially viable in targeted applications in the medium-duty, heavy-duty, and freight sectors; and 4) Aid ZEV market growth beyond California. The broad goals to advance ZEV adoption are: i) achieve mainstream consumer awareness of ZEV options and benefits; ii) make ZEVs an affordable and attractive option for drivers; iii) ensure convenient charging and fueling infrastructure for greatly expanded use of ZEVs; iv) maximize economic and job opportunities from ZEV technologies; v) bolster ZEV market growth outside of California; and vi) lead by example by integrating ZEVs into State government. The goals and strategies proposed in the 2013 Action Plan will continue to be implemented; however, additional strategies are proposed to help achieve the new goals, including setting targets to increase home charging stations in multiunit dwellings and disadvantaged communities and for public transit and school bus electrification. The 2016 Action Plan describes challenges toward achieving the 2025 goal of 30 Executive Order B-16-2012. Available at: https://www.ca.gov/archive/gov39/2012/03/23/news17472/.

Accessed: January 2022.
31 Governor’s Interagency Working Group on Zero-emission Vehicles. 2013. Available at:
http://opr.ca.gov/docs/Governors_Office_ZEV_Action_Plan_(02-13).pdf. Accessed: January 2022. 32 Governor’s Interagency Working Group on Zero-emission Vehicles. 2016. Available at:
https://www.ca.gov/archive/gov39/wp-content/uploads/2018/01/2016_ZEV_Action_Plan-1.pdf. Accessed:

January 2022.

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1.5 million ZEVs in California, such as that most consumers are still not aware of the benefits of passenger ZEVs and that over 1,000,000 charge points will be needed at homes, workplaces, and public locations but only 11,000 non-home charge points are installed as stated in the 2016 ZEV Action Plan.

In September 2018, the Governor’s Interagency Working Group on Zero-Emission Vehicles published the 2018 ZEV Action Plan Priorities Update.33 This update is the result of Governor Brown’s directive to update the 2016 Zero-Emission Vehicle Action Plan to help expand private investment in zero-emission vehicle infrastructure, particularly in low income and disadvantaged communities. The 2018 Priorities Update serves three fundamental purposes:
1) Provide direction to state agencies on the most important actions to be executed in 2018 to enable progress toward the 2025 targets and 2030 Vision; 2) Give stakeholders transparency into the actions state agencies plan to take (or are taking) this year to further the ZEV market; and 3) Create a platform for stakeholder engagement, feedback, and collaboration. As of July 2018, over 410,000 ZEVs have been sold in California, which is approximately 150,000 ZEVs since the publication of the 2016 Action Plan in October 2016.

In July 2020, CARB prepared an Assessment of CARB’s Zero-Emission Vehicles Programs Per Senate Bill 498. In this report, CARB staff reviews its programs that affect the adoption of light, medium, and heavy-duty ZEVs, including identifying each program’s goals and status in meeting those goals, performing a cost-benefit analysis where data are available, and comparing CARB’s ZEV programs with those of other jurisdictions. Additionally, pursuant to SB 498, CARB provides policy recommendations for increasing the use of ZEVs in the State, as well as recommendations for vehicle fleet operators to increase the use of ZEVs.34 The California Zero-Emission Vehicle Market Development Strategy was published in February 2021.35 This strategy was prepared to meet the targets identified by Governor Newsom in Executive Order N-79-20, which include the following zero-emission vehicle targets for California:
x 100% of in-state sales of new passenger cars and light-duty trucks will be zero-emission by 2035,
x 100% zero-emission medium and heavy-duty vehicles in the state by 2045 where feasible and by 2035 for drayage trucks, and
x 100% zero-emission off-road vehicles and equipment operations by 2035, where feasible.

A document prioritizing near-term actions for the next year was prepared in August 2021 called the ZEV Pillar Priorities.36 This annual implementation document identifies the 33 Governor’s Interagency Working Group on Zero-emission Vehicles. 2018. Available at:
https://static.business.ca.gov/wp-content/uploads/2019/12/2018-ZEV-Action-Plan-Priorities-Update.pdf.

Accessed: January 2022.
34 CARB. 2020. Assessment of CARB’s Zero-Emission Vehicles Programs Per Senate Bill 498. Available at:
https://ww3.arb.ca.gov/programs/zev/SB-498-Report-072320.pdf. Accessed: January 2022. 35 CARB. 2021. California Zero-Emission Vehicle Market Development Strategy. Available at:
https://static.business.ca.gov/wp-content/uploads/2021/02/ZEV_Strategy_Feb2021.pdf. Accessed: January 2022.
36 CARB. 2021. ZEV Pillar Priorities. Available at: https://static.business.ca.gov/wpcontent/uploads/2021/08/ZEVPillarPriority.pdf. Accessed: January 2022.

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In June 2020, CARB approved the Advanced Clean Trucks regulation, which has requirements for manufacturer ZEV sales and a one-time reporting requirement for large entities and fleets.37 The Advanced Clean Truck Regulation is part of a holistic approach to accelerate a large-scale transition of zero-emission medium-and heavy-duty vehicles from Class 2b to Class 8. Manufacturers who certify Class 2b-8 chassis or complete vehicles with combustion engines are required to sell zero-emission trucks as an increasing percentage of their annual California sales from 2024 to 2035. By 2035, zero-emission truck/chassis sales need to be 55% of Class 2b – 3 truck sales, 75% of Class 4 – 8 straight truck sales, and 40% of truck tractor sales. Large employers including retailers, manufacturers, brokers, and others are required to report information about shipments and shuttle services. Fleet owners, with 50 or more trucks, are required to report about their existing fleet operations.

This information helps to identify future strategies to ensure that fleets purchase available zero-emission trucks and place them in service where suitable to meet their needs.

California is incentivizing the purchase of ZEVs through implementation of the Clean Vehicle Rebate Project (CVRP), which is administered by a non-profit organization (The Center for Sustainable Energy) for CARB and currently subsidizes the purchase of passenger near-zero and zero emission vehicles as follows:
x Hydrogen Fuel Cell Electric Vehicles: $5,000;
o Battery Electric Vehicles: $2,500;
o Plug-In Hybrid Electric Vehicles: $1,500; and
o Neighborhood Electric Vehicles and Zero Emission Motorcycles: $900.

In March 2017, CARB received Volkswagen’s (VW) first 30-month ZEV Investment Plan (Plan).38 This Plan is required by California’s partial settlement with VW resulting from VW’s use of illegal devices in its 2.0-liter (2.0L) diesel cars sold in the State from model years 2009 to 2015. The Plan describes how VW is proposing to spend the first $200 million in California on ZEV charging infrastructure (including the development and maintenance of ZEV charging stations), public awareness, increasing ZEV access, and a green city demonstration. In June 2017, Electrify America (a subsidiary of VW) provided CARB with additional information on the Plan.39 CARB approved the first of the four plans in July 2017.40 37 CARB. 2020. Advanced Clean Trucks. Available at: https://ww2.arb.ca.gov/our-work/programs/advanced-cleantrucks. Accessed: January 2022. 38 VOLKSWAGEN, Group of America. 2017. California ZEV Investment Plan: Cycle 1, March 8, 2017. Available at:
https://www.electrifyamerica.com/assets/pdf/California%20ZEV%20Investment%20Plan%20Cycle%201.3bc672 a3.pdf. Accessed: January 2022.
39 Electrify America. 2017. Supplement to the California ZEV Investment Plan, Cycle 1, June 29, 2017. Available at:
https://www.electrifyamerica.com/assets/pdf/Cycle%201%20CA%20ZEV%20Invest%20Plan%20Supplement.a9 2e7705.pdf. Accessed: January 2022.
40 CARB, 2017. CARB Approves $200 Million VW Zero-Emission Vehicle Investment in California, July, 27. Available at: https://ww2.arb.ca.gov/news/carb-approves-200-million-vw-zero-emission-vehicle-investment-california.

Accessed: January 2022.

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15 Energy Environmental and Regulatory Overview Ramboll In its 2014 First Update, CARB recognized that the light-duty vehicle fleet “will need to become largely electrified by 2050 in order to meet California’s emission reduction goals.”41 Accordingly, CARB’s ACC program – summarized above – requires about 15 percent of new cars sold in California in 2025 to be a plug-in hybrid, battery electric or fuel cell vehicle.42 Other state-wide and regional initiatives that spur ZEV uptake include the following:
x CARB currently subsidizes the purchase of passenger near-zero and zero emission vehicles and provides access to high-occupancy vehicle (HOV) lanes to ZEV drivers. x The VW settlement will result in $800 million in ZEV projects in California over the next ten years, with a focus on increasing public awareness and infrastructure in the first funding cycle.43
x The CalGreen standards require new residential and non-residential construction to be pre-wired to facilitate the future installation and use of electric vehicle chargers (see Section 4.106.4 and Section 5.106.5.3 of 2016 CalGreen standards for the residential and nonresidential pre-wiring requirements, respectively).

In January 2017, three of California’s largest utilities submitted proposals to the California Public Utilities Commission (CPUC) to electrify the State’s transportation sector through more than $1 billion in investments:
x Southern California Edison (SCE) filed an application to expand electric transportation in its service area. Some of SCE’s proposals include monetary rewards to rideshare drivers who use an electric vehicle, additional fast charge infrastructure at targeted locations within the region, and rates that are designed to incentivize electric vehicle adoption.44 x Pacific Gas and Electric (PG&E) submitted an application that aims to expand the electrification of medium- and heavy-duty vehicle fleets, expand fast-charging stations that can refuel EVs in 20-30 minutes, and explore new uses for vehicle electrification.45 x San Diego Gas & Electric (SDG&E) submitted an application to install tens of thousands of charging stations in its service area to boost the transition to zero-emission vehicles, trucks, shuttles, and delivery fleets.46
41 CARB, First Update to the Climate Change Scoping Plan: Building on the Framework (May 2014), p. 48. 42 Id. at p. 47.
43 CARB, Volkswagen Settlement – California ZEV Investments webpage, available at:
https://www.arb.ca.gov/msprog/vw_info/vsi/vw-zevinvest/vw-zevinvest.htm. Accessed: January 2022. 44 SCE, Application of Southern California Edison Company (U 338-E) for Approval of Its 2017 Transportation Electrification Proposals (January 20, 2017).
45 PG&E, In the Matter of the Application of Pacific Gas and Electric Company for Approval of its Senate Bill 350 Transportation Electrification Program (January 20, 2017). 46 SDG&E, Application of San Diego Gas & Electric Company (U902E) for Approval of SB 350 Transportation Electrification Proposals (January 20, 2017).

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2.2.3 Local Programs

2.2.3.1 City of Fresno General Plan
The City of Fresno’s General Plan was adopted in December 2014.47 As part of a General Plan Update, the City of Fresno prepared a Program Environmental Impact Report for the continued implementation of the approved Fresno General Plan, text changes to the Mobility and Transportation Element related to Vehicle Miles Traveled (VMT) analysis, and an update to the Greenhouse Gas Reduction Plan. The Greenhouse Gas Reduction Plan Update includes measures related to energy conservation strategies for new and existing buildings and energy efficiency reductions.48
47 City of Fresno. 2014. Fresno General Plan. Available at: https://www.fresno.gov/darm/wpcontent/uploads/sites/10/2019/07/ConsolidatedGP6182020.pdf. Accessed: January 2022. 48 LSA. 2021. Appendix G Greenhouse Gas Reduction Plan Update. Available at: https://www.fresno.gov/darm/wpcontent/uploads/sites/10/2021/03/Link4AppendixGGHGRPUpdate.pdf. Accessed: January 2022.

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3. SIGNIFICANCE THRESHOLDS
The analysis provided in this report evaluates the significance of the Project’s energy by reference to the following questions from Section VI, Energy, of Appendix G of the CEQA Guidelines:

Threshold 1. Would the Project result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during Project construction or operation?
Threshold 2. Would the Project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
While no quantitative thresholds related to energy are included in the CEQA Guidelines, Part I of Appendix F of the CEQA Guidelines states as follows:
“The goal of conserving energy implies the wise and efficient use of energy. The means of achieving this goal include:

1. decreasing overall per capita energy consumption,

2. decreasing reliance on fossil fuels such as coal, natural gas and oil, and

3. increasing reliance on renewable energy resources.”
Appendix F of the CEQA Guidelines states that an Environmental Impact Report (EIR) should include a discussion of the potential energy impacts of a project, with particular emphasis on avoiding or reducing inefficient, wasteful, and unnecessary consumption of energy.

For purposes of this analysis, impacts to energy resources will be considered to be significant if the project would result in the wasteful, inefficient or unnecessary consumption of fuel or energy, and conversely if the project would not incorporate renewable energy or energy efficiency measures into building design, equipment use, transportation or other project features.

To determine whether a project would result in the wasteful, inefficient or unnecessary consumption of fuel or energy, and conversely whether the project would fail to incorporate renewable energy or energy efficiency measures into building design, equipment use, transportation or other project features, Appendix F of the CEQA Guidelines identifies six categories of potential energy-related environmental impacts:

1. The project’s energy requirements and its energy use efficiencies by amount and fuel type for each stage of the project including construction, operation, maintenance and/or removal. If appropriate the energy intensiveness of materials may be discussed.

2. The effects of the project on local and regional energy supplies and on requirements for additional capacity.

3. The effects of the project on peak and base period demands for electricity and other forms of energy.

4. The degree to which the project complies with existing energy standards.

5. The effects of the project on energy resources.

6. The project’s projected transportation energy use requirements and its overall use of efficient transportation alternatives.

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This report, relative to Threshold 1, assesses the Project’s electricity, natural gas, and fossil fuel consumption during construction and operation by way of the six questions above. This report, relative to Threshold 2, evaluates the Project for consistency with applicable plans related to renewable energy and energy efficiency (see Appendix B, Table B-1: State Plan Level Consistency Analysis and Appendix B, Table B-2: Local Plan-Level Consistency Analysis). The Local Plan-Level Consistency Analysis is based on the City of Fresno’s Greenhouse Gas Reduction Plan Update49 and the applicable City of Fresno General Plan50 policies and objectives.
49 City of Fresno. 2021. Greenhouse Gas Reduction Plan Update. Available at: https://www.fresno.gov/darm/wpcontent/uploads/sites/10/2021/03/Link4AppendixGGHGRPUpdate.pdf. Accessed: February 2022. 50 City of Fresno. 2014. Fresno General Plan. Available at: https://www.fresno.gov/darm/wpcontent/uploads/sites/10/2019/07/ConsolidatedGP6182020.pdf. Accessed: February 2022.

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4. METHODOLOGY FOR DEVELOPMENT OF ENERGY

PROJECTIONS
This section describes the methodology that Ramboll used to develop the regulatory compliance-based energy projections associated with the Project, which include one-time demand from construction and annual operational demand. This section also identifies the results of the energy projections for the Project based on compliance with applicable regulatory requirements.

Additional information regarding methodology can be found in the Greenhouse Gas Emissions Technical Report and Air Quality Technical Report for the Project; only the methodology specific to energy usage is discussed in this report.

4.1 Construction Equipment & Activities
Project construction is planned to begin in 2023, with full build out expected in 2023.

Construction of the Project is not anticipated to require natural gas fuel. As such, natural gas related to construction of the Project is not discussed further.

Construction of the Project requires the use of transportation fuel, including gasoline and diesel use in construction equipment, material transport via hauling trucks, delivery via vendor trucks, and construction worker vehicles. Fuel consumed by construction equipment would be the primary energy resource expended over the course of construction, while VMT associated with the transportation of construction materials and construction worker commutes would also result in fuel consumption. Heavy-duty construction equipment associated with construction activities would use diesel fuel. Construction workers would travel to and from the project site throughout the duration of construction; this analysis assumed that construction workers would primarily use gasoline-powered passenger vehicles.

Heavy-duty construction equipment of various types would be used during each phase of construction. CalEEMod® was used to estimate construction equipment usage, and results are included in Appendix A. Fuel consumption from construction equipment was estimated by converting the total carbon dioxide (CO2) emissions from each construction phase to gallons using conversion factors for CO2 to gallons of diesel. The estimated diesel fuel usage from off-road construction sources, which totals 55,154 gallons of diesel over the course of the project construction period, is shown in Table 4-1.

Fuel consumption from worker, vendor, and hauling trips are estimated by converting the total CO2 emissions from each construction phase to gallons using conversion factors for CO2 to gallons of gasoline or diesel. Worker vehicles are assumed to include light-duty automobiles and trucks, vendor vehicles are assumed to include an equal mix of medium heavy-duty trucks and heavy heavy-duty trucks, and hauling vehicles are assumed to include heavy heavy-duty trucks. Estimated fuel usage, which totals 17,539 gallons of gasoline and 29,805 gallons of diesel over the course of the project construction period, is shown in Table 4-2.

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4.2 Operational Energy Requirements
Energy requirements are evaluated for the first year of Project operations (2023).

4.2.1 Electricity
Operation of the Project will result in electricity demand for the car wash, warehouse, gas station, and parking lot. The annual electricity usage for each land use is presented in Table 4-3. The total electricity use for the Project incorporates 2019 Title 24 standards.

4.2.2 Natural Gas
The Project will require natural gas, mainly for building heating and hot water. Natural gas is estimated using CalEEMod® defaults based on averages for the climate zone for the car wash, warehouse, and gas station. The annual natural gas usage for each land use is presented in Table 4-4. Estimates for the project are conservative because they assume the project would be built to existing Title 24, Part 6 standards, even though subsequent, more energy efficient iterations of the code will apply.

4.2.3 Fuel Usage

4.2.3.1 Gasoline
Gasoline fuel consumption for Project operation is shown in Table 4-5. Operational gasoline fuel usage occurs due to member trips and employee trips when commuting to work at the warehouse, car wash, and gas station and is calculated based on gasoline vehicle VMT. The development of the member and employee VMT is described in detail in the Greenhouse Gas Emissions Technical Report and Air Quality Technical Report. Gasoline fuel consumption for the Project is calculated by dividing total member and employee VMT by average fuel efficiency of gasoline vehicles in Fresno County from the EMFAC2021 database for calendar year 2023. The analysis also reflects the reasonably foreseeable change based on the discontinued operation of the Costco Warehouse located at 4500 W Shaw Avenue. For purposes of this analysis, 4500 W Shaw Avenue is assumed to be backfilled by a shopping center use resulting in less fuel use. The methodology to account for this change is described in detail in the Air Quality Technical Report.

4.2.3.2 Diesel
Diesel fuel consumption for Project operation is shown in Table 4-6. Operational diesel fuel usage occurs due to warehouse truck, fuel delivery truck, and MDO delivery truck trips to the site.

Warehouse truck, fuel delivery truck, and MDO delivery truck fuel consumption is based on total VMT, which described in detail in the Greenhouse Gas Emissions Technical Report and Air Quality Technical Report. Diesel fuel consumption for the Project is calculated by dividing total diesel truck VMT by the average fuel efficiency of diesel vehicles in Fresno County from the EMFAC2021 database for calendar year 2023.

4.2.3.3 Electricity
Electricity consumption from electric vehicles (EVs) and plug-in hybrid electric vehicles (PHEVs) for Project operation is shown in Table 4-7. Operational transportation-related electricity usage occurs due to member trips and employee trips when commuting to work at the warehouse, car wash, and gas station and is calculated based on gasoline vehicle VMT.

The development of the member and employee VMT is described in detail in the Greenhouse Gas Emissions Technical Report and Air Quality Technical Report.

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21 Methodology for Development of Energy Projections Ramboll Electricity consumption for the Project is calculated by dividing total electric-powered VMT by the average energy efficiency of electric vehicles and plug-in hybrid electric vehicles in Fresno County from the EMFAC2021 database for calendar year 2023. The analysis also reflects the reasonably foreseeable change based on the discontinued operation of the Costco Warehouse located at 4500 W Shaw Avenue. The methodology to account for this change is described in detail in the Air Quality Technical Report.

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5. PROJECT INVENTORY IN CONTEXT
This section assesses the significance of the Project’s energy demand for purposes of CEQA.

Project impacts – i.e., energy use beyond existing Baseline conditions – are assessed against the thresholds.

5.1 Threshold 1
Would the Project Result in a Potentially Significant Environmental Impact Due to Wasteful, Inefficient, or Unnecessary Consumption of Energy Resources, during Project Construction or Operation?

5.1.1 Energy Requirements and Energy Use Efficiencies
This section addresses the following category of environmental impact described in Appendix F of the CEQA Guidelines:

The project’s energy requirements and its energy use efficiencies by amount and fuel type for each stage of the project including construction, operation, maintenance and/or removal. If appropriate the energy intensiveness of materials may be discussed.

5.1.1.1 Construction
Construction of the proposed project would result in fuel usage as shown in Table 5-1.

There are no unusual project characteristics or construction processes that would require the use of equipment that would be more energy intensive than is used for comparable activities, or equipment that would not conform to current emissions standards (and related fuel efficiencies).

5.1.1.2 Operations
Operation of the Project would result in electricity, natural gas, gasoline, and diesel fuel usage, as shown in Table 5-2. There are no unusual project characteristics that would require consumption that would be more energy intensive than is used for comparable activities, or equipment that would not conform to current emissions standards (and related fuel efficiencies).

Over the lifetime of the project, the fuel efficiency of the vehicles being used for Project operation is expected to improve. The amount of fuel consumption from vehicular trips to and from the project site during operation would correspondingly decrease over time as vehicles become more efficient. Numerous regulations have been adopted that encourage, and require, increased fuel efficiency. For example, CARB has adopted an approach to passenger vehicles that combines the control of smog-causing pollutants and GHG emissions into a single coordinated package of standards. The approach also includes efforts to support and accelerate the numbers of plug-in hybrids and zero-emissions vehicles in California. As such, operation of the Project is expected to use decreasing amounts of fuel over time, due to advances in fuel economy.

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5.1.2 Local and Regional Energy Supplies
This section addresses the following category of environmental impact described in Appendix F of the CEQA Guidelines:

The effects of the project on local and regional energy supplies and on requirements for additional capacity.

5.1.2.1 Construction
The Project’s fuel consumption during construction is discussed in Section 4.1. Relative to total electricity and fuel comparison countywide, Project construction would use approximately 0.005% of gasoline and 0.04% of diesel fuel over the duration of construction (Table 5-1). In comparison to State-wide usage, construction of the Project would equate to approximately 0.0001% of gasoline usage and less than 0.002% of diesel fuel usage (Table 5-1). Therefore, fuel use during construction would be temporary and negligible. Fuel consumption in 2023 (the year of full build-out of the Project) was estimated using EMFAC2021 for Fresno County and California State-wide.

5.1.2.2 Operations
Electricity
The Project’s electricity demand during operation is discussed in Section 4.2.1. For comparison, based on 2020 consumption, operation of the Project would equate to 0.029% of the total electricity demand countywide and 0.001% of the total electricity demand state-wide (Table 5-2). Therefore, the Project is not expected to have an impact on the local utility.

In 2020, total in-state electricity consumption was 279,510 GWh.51 The CEC estimates that state-wide energy demand will increase to 354,209 GWh in 2030.52 The Project’s anticipated electricity usage of 2,292,337 kWh/year is approximately 0.0008% of the state-wide demand in 2020. Given that the state is growing annually, the anticipated state-wide energy demand for the Project Operational build-out year of 2023 will likely be greater than that in 2020, and thus the project’s relative percentage contribution to the state-wide energy demand would be even less.

The Project’s electricity use projections also represent a small percentage of regional estimates for PG&E. The CEC estimates that PG&E energy demand will increase to about 114,000 GWh in 2023.53 The project’s anticipated electricity usage of 2,292,337 kWh/year is approximately 0.002% of the projected PG&E planning area demand in 2023.

Overall, the Project’s projected electricity demand is consistent with, and a small percentage of, state and regional projections. Therefore, the Project will not require additional generation capacity beyond more general state-wide expansion. 51 California Energy Commission. 2020. Electricity consumption by county. Available at:
https://ecdms.energy.ca.gov/elecbycounty.aspx Accessed: January 2022. 52 California Energy Commission. 2018. California Energy Demand 2018-2030 Revised Forecast. Available online at: https://efiling.energy.ca.gov/getdocument.aspx?tn=223244. Accessed: January 2022. 53 California Energy Commission. 2018. Electricity and Natural Gas Demand Forecast. Available online at:
https://efiling.energy.ca.gov/getdocument.aspx?tn=223244. Accessed: January 2022.

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Natural Gas
The Project’s natural gas demand during operation is described in Section 4.2.2. For comparison, based on 2020 consumption, operation of the Project would equate to 0.008% of the total natural gas demand countywide and 0.0002% of the total natural gas demand state-wide (Table 5-2).

Overall, the Project’s natural gas consumption is a small percentage of state and regional consumption. Therefore, the Project is not expected to have an impact on the local natural gas resources.

Fuel Usage
The Project’s fuel usage during operation is discussed in Section 4.2.3. As discussed in Section 4.2.3.1, Project gasoline consumption due to mobile VMT is approximately 2,001,579 gallons/year, which is 0.522% of the gasoline that would be used countywide in and 0.013% of the gasoline used state-wide in 2023. Project operational diesel consumption is approximately 344,953 gallons/year, which is 0.161% of the total diesel that would be used countywide in 2023. Operation of the Project would result in about 0.007% of the total diesel that would be used state-wide each year (Table 5-2).

5.1.2.3 Summary
The Project will not have a substantial impact on the local or regional energy supplies or require additional capacity to be constructed. The Project’s impacts are less than significant.

5.1.3 Peak and Base Period Demands
This section addresses the following category of environmental impact described in Appendix F of the CEQA Guidelines:

The effects of the project on peak and base period demands for electricity and other forms of energy.

5.1.3.1 Construction
The Project’s base energy consumption compared to regional and state-wide energy consumption is discussed above in Section 5.1.2. The electricity demand associated with construction of the Project will be supplied by existing on-site power poles when available. In the event of an emergency or during a power outage, the use of generator sets is permissible, which are comprised of a generator and diesel engine used to produce power off-grid. Therefore, relatively negligible impacts to energy demand are expected as a result of construction activities.

5.1.3.2 Operation
The Project Operation will not have a substantial impact on the peak and base period demands for electricity or other forms of energy. The Project’s base energy consumption compared to regional and state-wide energy consumption is discussed above in Section

5.1.2. Further details and reasoning on the peak demand are described below.

In 2020, California’s peak grid demand was 47,236 MW. On August 14, 2020, PG&E reached a maximum demand of 21,103 MW.54 In comparison, the Project’s maximum demand is expected to be approximately 0.6 MW in 2023. This is a conservative estimate since it was 54 California ISO. 2021. 2020-2021 Transmission Plan. Available online at:
http://www.caiso.com/Documents/BoardApproved2020-2021TransmissionPlan.pdf. Accessed: January 2022.

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derived by dividing the total electricity energy required for Project Operation by the annual number of working hours, though some sources of electricity would operate 24 hours per day for every day of the year. Thus, the Project will have a relatively negligible effect on statewide and PG&E peak demands.

5.1.3.3 Summary
As described above, the Project will not have a substantial impact on peak and base period demands for electricity and other forms of energy. The Project’s impacts are less than significant.

5.1.4 Existing Energy Standards
This section addresses the following category of environmental impact described in Appendix F of the CEQA Guidelines:

The degree to which the project complies with existing energy standards.

5.1.4.1 Construction
Project construction requires use of on-road trucks for soil hauling and deliveries, and off-road equipment such as excavators, tractors/loaders/backhoes, forklifts, and graders.

The construction activities would comply with state requirements designed to minimize idling and associated emissions, which also minimizes use of fuel. Specifically, idling of commercial vehicles and off-road equipment would be limited to five minutes in accordance with the Commercial Motor Vehicle Idling Regulation and the Off-Road Regulation, and the trucks used would be compliant with the requirements of the Tractor-Trailer Greenhouse Gas Regulation.

5.1.4.2 Operation
Electricity
The Project’s anticipated electricity use is discussed in Section 4.2.1.

The electricity demand estimate for the Project incorporates the 2019 Title 24 standards. If the application for the Project is applied for on or after January 1, 2023, then the Project will comply with the 2022 Title 24 Standards.

Natural Gas
The Project’s anticipated natural gas use is discussed in Section 4.2.2.

The natural gas demand for the Project is estimated in accordance with the Title 24 standards. For this analysis, the Project is assumed to meet 2019 Title 24 standards. If the application for the Project is applied for on or after January 1, 2023, then the Project will comply with the 2022 Title 24 Standards.

Fuel Usage
The Project’s anticipated fuel use is discussed in Section 4.2.3. There are no unusual project characteristics that would require the use of gasoline and diesel that would be more energy intensive than is used for comparable activities, or equipment that would not conform to current emissions standards (and related fuel efficiencies).

Vehicle use for the proposed project also has been evaluated pursuant to the technical advisory the Governor’s Office of Planning and Research published under SB 743, which Costco Commercial Center
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created a process to change the methods used for transportation impacts analyses under CEQA from focusing on level of service to VMT. (See 14 CCR 15064.3.)

5.1.4.3 Summary
As described above, the Project will comply with all applicable energy standards. The Project’s impacts are less than significant.

5.1.5 Energy Resources
This section addresses the following category of environmental impact described in Appendix F of the CEQA Guidelines:

The effects of the project on energy resources.

The Project’s energy use is discussed in Section 4 above, including electricity, natural gas, gasoline, and diesel consumption associated with on-site equipment, mobile operations, and construction activities. The Project’s use of energy will not have a substantial effect on statewide or regional energy resources. Total operational energy use requirements for the Project are summarized in Table 5-2. Programs and measures relevant to energy resources are discussed in detail above.

The Project will not significantly impact energy resources and the Project’s impacts are less than significant.

5.1.6 Transportation Energy Use
This section addresses the following category of environmental impact described in Appendix F of the CEQA Guidelines:

The project’s projected transportation energy use requirements and its overall use of efficient transportation alternatives.

Conventional gasoline and diesel vehicles consume gasoline or diesel fuel, whereas EVs consume electricity that can be sourced by fossil fuels or renewables. EVs, including battery-electric vehicles and plug-in hybrid electric vehicles, comprise a growing fraction of the passenger vehicles on the roads in California. EV adoption is expected to increase over the upcoming decades due in part to improvements in battery technology and public initiatives and goals. This increase in EV adoption will decrease the fuel requirements due to transportation.

New state-wide regulations. such as Truck and Bus Rule (Title 13 CCR Section 2025), On-Road Heavy-Duty Vehicle Program (Title 13, CCR Section 1956.8), Pavley Clean Car Standards and the Advanced Clean Cars (ACC) program have been instated which reduce emissions and fuel requirements from trucks and cars.

Gasoline fuel usage for the Project shown in Table 4-5 will decrease over time as fleets become more fuel efficient and switch to more electric vehicles. While there is a growth in diesel fuel usage, the growth rate is slower than the increase in VMT due to enhanced fuel efficiency of heavy-duty vehicles in the Project year as shown in Table 4-6.

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5.1.7 Summary
Based on the above analysis of each of the environmental impact factors identified in CEQA Guidelines Appendix F, the potential for the Project to result in wasteful, inefficient, or unnecessary consumption of fuel or energy, and conversely to fail to incorporate energy efficiency measures into equipment use, transportation or other project features is less than significant.

5.2 Threshold 2
Would the Project Conflict with or Obstruct a State or Local Plan for Renewable Energy or Energy Efficiency?
The Proposed Project would comply with any applicable state plans for renewable energy or energy efficiency to the extent required by law. Further, the Project would be consistent with the renewable energy and energy efficiency provisions of the City of Fresno General Plan55.

This plan is described in more detail in Section 2.2.3 and the relevant provisions of each plan are listed in Appendix B. The Project has been evaluated for consistency with state plans and has been concluded to be consistent; the assessment for state plan measures is found in Appendix B, Table B-1. Additionally, the Project has been evaluated for consistency with the relevant provisions and has been concluded to be consistent; the assessment for individual local plan measures is found in Appendix B, Table B-2. As such, Project impacts are less than significant.
55 City of Fresno. 2014. Fresno General Plan. Available at: https://www.fresno.gov/darm/wpcontent/uploads/sites/10/2019/07/ConsolidatedGP6182020.pdf. Accessed: January 2022.

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TABLES
Table 4-1. Construction Off-road Equipment Fuel Consumption Costco Commercial Center
Fresno, California
Year
CO2 Emissions1
(MT/yr)
Diesel Consumption2
(gallons/yr)
2023 563 55,154
Conversions:

10.21 kg CO2/gallon diesel
1,000 kg CO2/MT CO2
Notes:

Abbreviations:

CO2 - carbon dioxide
kg - kilograms
MT - metric ton
yr - year
1 Offroad emissions estimated using CalEEMod® guidance as presented in the CalEEMod® User's Guide, Appendix A. Available at:
www.caleemod.com. Accessed: January 2022.
2 The conversion factor for diesel is 10.21 kg CO2/gallon per The Climate Registry, 2021. Available at: https://www.theclimateregistry.org/wpcontent/uploads/2021/05/2021-Default-Emission-Factor-Document.pdf.

Accessed: January 2022.

CalEEMod® - CALifornia Emissions Estimator MODel

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Table 4-2. Construction On-Road Fuel Consumption
Costco Commercial Center
Fresno, California
Year
Gasoline
Consumption1,2
(gallons/yr)
Diesel Consumption1,2
(gallons/yr)
2023 17,539 29,805
Conversions:3

8.78 kg CO2/gallon gasoline

10.21 kg CO2/gallon diesel
1,000 kg CO2/MT CO2
Notes:

Abbreviations:

CO2 - carbon dioxide
EMFAC - EMission FACtors model
kg - kilograms
HHDT - heavy heavy-duty trucks
LDA - light-duty automobile
LDT - light-duty truck
MHDT - medium heavy-duty trucks
MT - metric ton
yr - year
1 Onroad CO2 emissions are calculated using emission factors from EMFAC2017 based on fleet wide totals, including worker, vendor, and hauling trips. Worker vehicles are assumed to include light duty automobiles and trucks (50% LDA, 25% LDT1, 25% LDT2). Vendor vehicles are assumed to include medium heavyduty trucks and heavy heavy-duty trucks (50% MHDT, 50% HHDT). Hauling vehicles are assumed to include heavy heavy-duty trucks (100% HHDT). Onroad CO2 emissions can be referenced in the CalEEMod output.
2 CO2 emissions for worker, vendor, and hauling trips were split based on gasoline or diesel fuel consumption. The fuel consumption breakdown was derived using fuel consumption in Fresno County using EMFAC2021.
3 The conversion factors for gasoline and diesel are 8.78 kg CO2/gallon and 10.21 kg CO2/gallon, respectively, per The Climate Registry, 2021. Available at: https://www.theclimateregistry.org/wpcontent/uploads/2021/05/2021-Default-Emission-Factor-Document.pdf. Accessed: January 2022.

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Table 4-3. Electricity Consumption
Costco Commercial Center
Fresno, California
Land Use
Electricity Demand
(kWh/yr)1
Automobile Care Center 41,328
Discount Club 1,911,410
Gasoline/Service Station 38,897
Parking Lot 124,460
Project 2,116,095
Notes:

Abbreviations:

CalEEMod® - CALifornia Emissions Estimator MODel
kWh - kilowatt hours
yr - year
1 Project electricity demand is obtained from CalEEMod® outputs.

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Table 4-4. Natural Gas Consumption
Costco Commercial Center
Fresno, California
Land Use
Natural Gas Demand
(kBTU/yr)1
Automobile Care Center 99,360
Discount Club 2,560,620
Gasoline/Service Station 93,514
Parking Lot 0
Project 2,753,494
Notes:

Abbreviations:

CalEEMod® - CALifornia Emissions Estimator MODel
kBTU - kilo British Thermal Unit
yr - year
1 Project natural gas demand is obtained from CalEEMod® outputs.

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Table 4-5. Gasoline Consumption
Costco Commercial Center
Fresno, California
Mobile Source Activity
VMT
(miles/yr)1
Gasoline Consumption
(gallons/yr)2
Gasoline Vehicles 22,315,831 955,908
Gasoline Vehicles 69,043,050 2,957,487
Constants:

Average efficiency in 2023 23.35 miles per gallon3
Notes:

Abbreviations:

EMFAC - EMission FACtors model
VMT - vehicle miles traveled
yr - year
1 Vehicle miles traveled are based on data provided by Kittelson & Associates, 2023. 2 Gasoline consumption is calculated by assuming an average fuel efficiency and the reported VMT. The portion of the VMT that is gasoline vehicles is determined using the project-specific fleet mix. 3 The average fuel efficiency is obtained from EMFAC2021 for Fresno County based on the fuel consumption and vehicle miles traveled for 2023.

Herndon/Riverside
4500 W. Shaw Ave

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Table 4-6. Diesel Consumption
Costco Commercial Center
Fresno, California
Mobile Source Activity
Annual Diesel-Related
Activity1
Diesel Consumption
(gallons/yr)2
Diesel Vehicles (VMT per year)3 0 0
Transportation Refrigeration Units (hours per year) 7,382 5,655 Diesel Vehicles (VMT per year)3 2,440,575 339,298
Constants:

Average efficiency in 2023 7.19 miles per gallon4
TRU fuel consumption rate4 0.77 gallons per hour
60 minutes per hour
Notes:

Abbreviations:

EMFAC - EMission FACtors model
TRU - Transport Refrigeration Units
VMT - vehicle miles traveled
yr - year
4 TRU fuel consumption rate is obtained from the OFFROAD2021 emissions output for Calendar Year 2023, Transportation Refrigeration Unit - Instate Trailer and Transportation Refrigeration Unit - Out-Of-State Trailer in Fresno County.
4500 W. Shaw Ave
Herndon/Riverside
1 Diesel VMT are based on data provided by Kittelson & Associates, 2023. TRU Cycle Duration is based on 2 hours of loading time plus the duration of the on-site and off-site transit. Assumptions based on Table II.G.1 of CARB Proposed Amendments to the Airborne Toxic Control Measure for In-Use Diesel-Fueled Transport Refrigeration Units (TRU) and TRU Generator Sets, and Facilities Where TRUs Operate. Available at:
https://ww2.arb.ca.gov/sites/default/files/barcu/board/rulemaking/tru2021/appi.pdf. Accessed: June 2022. 2 Diesel consumption for diesel vehicles is calculated by assuming an average fuel efficiency and the reported VMT. The portion of the VMT that is diesel vehicles is determined using the project-specific fleet mix. TRU diesel consumption is calculated based on OFFROAD2021 fuel consumption rate and the annual operation. 4 The average fuel efficiency is obtained from EMFAC2021 for Fresno County based on the fuel consumption and vehicle miles traveled for 2023.
3 Vehicle miles traveled are based on data provided by Kittelson & Associates, 2023.

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Table 4-7. Electricity Consumption from Vehicles
Costco Commercial Center
Fresno, California
Mobile Source Activity
VMT
(miles/yr)1
Electricity Consumption2
(kWh/yr)
Plug-in Hybrid Electric Vehicles3 206,859 62,478
Electric Vehicles 116,874 45,420
Plug-in Hybrid Electric Vehicles3 640,004 193,300
Constants:

Average efficiency in 2023
Electric Vehicles 2.57 mi/kWh4
Plug-in Hybrid Electric Vehicles 3.31 mi/kWh4
Notes:

Abbreviations:

CalEEMod® - CALifornia Emissions Estimator MODel
EMFAC - EMission FACtors model
eVMT - electric vehicle miles traveled
kWh - kilowatt-hour
mi - mile
VMT - vehicle miles traveled
yr - year
1 Vehicle miles traveled are based on data provided by Kittelson & Associates, 2023. 2 Electricity consumption from electric miles driven is calculated by assuming an average energy economy and the reported VMT. The portion of the VMT that is electric-powered is determined using the project-specific fleet mix.
4 The average fuel efficiency is obtained from EMFAC2021 for Fresno County based on the energy consumption and electric vehicle miles traveled for 2023. 3 The VMT from plug-in hybrid electric vehicles accounts for electric vehicle miles traveled, also known as eVMT.
4500 W. Shaw Ave
Herndon/Riverside

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Table 5-1. Construction Energy Resource Summary
Costco Commercial CenterFresno, California
Annual
Consumption
Project's Construction
Contribution4
(%)
Annual
Consumption
Project's Construction
Contribution4
(%)
Gasoline (gallons)2 17,539 383,581,859 0.005% 15,688,627,269 0.00011% Diesel (gallons)3 84,959 214,135,125 0.040% 5,000,677,060 0.00170%Notes:

Abbreviations:% - percentCalEEMod® - CALifornia Emissions Estimator MODel EMFAC - California Air Resources Board Emissions Factor Model 2 Gasoline data for Fresno County and the State of California are obtained from EMFAC2021 for calendar year 2023.3 Diesel data for Fresno County and the State of California are obtained from EMFAC2021 and OFFROAD2021 for calendar year 2023.4 The project's construction contribution was calculated based on the maximum annual construction energy consumption.

Energy Resource
Total
Construction1
Fresno County California
1 Offroad and onroad emissions are calculated using methodology consistent with CalEEMod® version 2020.4.0. Offroad emission factors are fromOFFROAD whereas onroad emission factors are from EMFAC2017. See Tables 4-1 and 4-2 for detailed fuel consumption of the Off-Road Equipment and OnRoad Vehicles categories, respectively.

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Table 5-2. Operation Energy Resource Summary
Costco Commercial Center Fresno, California
Consumption
Project's
Contribution
(%)8 Consumption
Project's
Contribution
(%)8
Electricity (kWh/yr)2,3 2,292,337 8,017,830,742 0.029% 279,510,007,246 0.0008% Natural Gas (kBtu/yr)4,5 2,753,494 32,583,736,325 0.008% 1,232,858,294,229 0.0002%Gasoline (gallons/yr)6 2,001,579 383,581,859 0.522% 15,688,627,269 0.013% Diesel (gallons/yr)7 344,953 214,135,125 0.161% 5,000,677,060 0.007% Conversions:
99,976.1 Btu/therm
1,000 Btu/kBtu
1,000,000 kWh/GWh
1,000 kWh/MWh
Notes:
1 Project data are based on CalEEMod® output.3 Electricity data for the State is obtained for all counties in 2020 from http://www.ecdms.energy.ca.gov/elecbycounty.aspx.5 Natural gas data for the State is obtained for all counties in 2020 from http://www.ecdms.energy.ca.gov/gasbycounty.aspx.

Abbreviations:

Btu - British thermal unitCalEEMod® - CALifornia Emissions Estimator MODel EMFAC - EMission FACtors modelGWh - gigawatt hourskWh - kilowatt hourskBtu - kilo-British thermal unitMWh - megawatt hoursyr - year 7 Diesel data for Fresno County and the State of California are obtained from EMFAC2021 and OFFROAD2021 for calendar year 2023.6 Gasoline data for Fresno County and the State of California are obtained from EMFAC2021 for calendar year 2023.8 The project's construction contribution was calculated based on the maximum annual operational energy consumption.

Energy Resource Operation1
Fresno County California
2 Electricity data for Fresno County in 2020 from http://www.ecdms.energy.ca.gov/elecbycounty.aspx.4 Natural gas data for Fresno County in 2020 from http://www.ecdms.energy.ca.gov/gasbycounty.aspx.

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Costco Commercial Center
Energy Technical Report
Fresno, California

APPENDIX A

CALEEMOD OUTPUT

Costco Commercial Center
Energy Technical Report
Fresno, California

APPENDIX B

STATE AND LOCAL CONSISTENCY ANALYSES
Table B-1. Consistency with Applicable State Renewable Energy and Energy Efficiency Strategies Costco Commercial Center
Fresno, California
# Plan Category Description Consistency Analysis
1 California Renewables
Portfolio Standard
(RPS) and SB 100
As most recently amended by SB 100 (2018),
California’s RPS increases the proportion of electricity from renewable sources to 33 percent renewable power
by 2020; 50 percent renewable power by 2026; and,
60 percent renewable power by 2030. SB 350 (2015)
also requires the State Energy Resources Conservation
and Development Commission to double (by 2030) the
energy efficiency savings in electricity and natural gas final end uses of retail customers through energy
efficiency and conservation.

Consistent. The Project would be consistent with and
not impair implementation of the state's RPS. The
electricity for the operation of the Project would be
supplied by Pacific Gas & Electric, which is composed of 30% renewable resources as of 2020.
2 California Code of
Regulations, Title 24,
Part 6
Title 24, Part 6 of the California Code of Regulations
establishes energy and water efficiency requirements
for residential and non-residential new construction,
additions to existing buildings, and alterations to
existing buildings.

Standards include requirements for water heating,
HVAC, lighting, electrical systems, and solar design.

Consistent. The Project would meet or exceed the
Title 24 energy efficiency standards in effect at the
time of building permit application.
3 Assembly Bill 1109
The Lighting Efficiency And Toxics Reduction Act (AB
1109) requires a reduction in average statewide
electrical energy consumption by not less than 50
percent from the 2007 levels for indoor residential
lighting and not less than 25 percent from the 2007
levels for indoor commercial and outdoor lighting by
2018.

Consistent. The Project would meet the applicable
requirements from AB 1109.
4 California Green
(CalGreen) Building
Standards Code
Requirements
CalGreen establishes green building standards to meet
the goals of AB 32. CalGreen includes standards for
residential and nonresidential structures such as new
buildings or portions of new buildings, additions and
alterations, and all occupancies where no other state
agency has the authority to adopt green building
standards applicable to those occupancies. Standards
include requirements for site development, indoor and
outdoor water use, construction waste reduction,
disposal and recycling and building maintenance and
operation.

Consistent. To the extent applicable to the Project,
the Project would meet the CalGreen Building
Standards Code in effect at the time of building permit application.
5 AB 1493 (Pavley
Regulations)
Reduces GHG emissions in new passenger vehicles
from model years 2012-2016 (Phase I) and model
years 2017–2025 (Phase II). Also reduces gasoline
consumption to a rate of 31 percent of 1990 gasoline
consumption (and associated GHG emissions) by 2020.

Consistent. The Project would not impair
implementation of the AB 1493 regulations.
6 Low Carbon Fuel
Standard (LCFS)
Establishes protocols for measuring and reducing the
life-cycle carbon intensity of transportation fuels and helps to establish use of alternative fuels.

Consistent. The Project would not conflict with
implementation of the LCFS.
7 Advanced Clean Cars
(ACC) Program
In 2012, the California Air Resources Board (CARB)
adopted the ACC program to reduce criteria pollutant
emissions and GHG emissions for model year vehicles
2015 through 2025. ACC includes the Low-Emission
Vehicle (LEV) regulations that reduce criteria pollutants and GHG emissions from light- and medium-duty
vehicles, and the Zero-Emission Vehicle (ZEV)
regulations that require manufacturers to produce an
increasing number of pure ZEVs (meaning battery
electric and fuel cell electric vehicles), with provisions to also produce plug-in hybrid electric vehicles (PHEV) in the 2018 through 2025 model years.

Consistent. The Project would not conflict with
implementation of the ACC program.
8 SB 375
SB 375 establishes mechanisms for the development of
regional targets for reducing passenger vehicle GHG
emissions. Under SB 375, CARB is required, in
consultation with the state’s Metropolitan Planning
Organizations, to set regional GHG reduction targets
for the passenger vehicle and light-duty truck sector
for 2020 and 2035.

Consistent. The Project would not conflict with the
implementation of SB 375. Furthermore, the Project
would be consistent with the goals of the Fresno
Council of Government's (Fresno COG's) Regional
Transporation Plan/Sustainable Communities Strategy,
which demonstrates how the Fresno region under
Fresno COG's jurisdiction will meet the emission
reduction targets of SB 375.

Abbreviations:

AB - Assembly Bill
CalGreen - California Green Building Standards Code
RPS - Renewable Portfolio Standard
SB - Senate Bill
Mobile Sources

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Table B-2. Consistency with Applicable City of Fresno Renewable Energy and Energy Efficiency Strategies Costco Commercial CenterFresno, California
# Category General Plan Policy or Objective Category Description Consistency Analysis 2b Electric Vehicle Strategies
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.

For new commercial buildings, does project provide EV charging spaces capable of supporting EV capable spaces at 4% to 10% of the parking spaces per 2019 California Green Building Standards Code (CALGREEN, Title 24, Part 11), Section 5.106.5.3 Consistent. The Project would be
consistent with this code with 45 installed EV spaces, which is 5% of the parking spaces at the site.

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.Objective RC-8: Reduce the consumption of non-renewable energy resources by requiring and encouraging conservation measures and the use of alternative energy sources.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.

Abbreviations:

AB - Assembly BillCalGreen - California Green Building Standards CodeEV - electric vehicleGHG - greenhouse gasLEED - Leadership in Energy and Environmental Design Does the project meet or exceed mandatory state building energy codes? If yes, does the project follow any other GreenPoint ratings such as LEED, Energy Star or others? If yes, indicate level of certification-Silver, gold, platinum if applicable? Consistent. The Project would be consistent with this by meeting mandatory building energycodes. Costco's warehouse designs are consistent with the requirements of LEED.

Energy Conservation Strategies
3a

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Appendix F
Greenhouse Gas Emissions
Technical Report

Prepared for
Ascent Environmental, Inc.

Sacramento, California
Project Number
1690023335
Date
June 2023

COSTCO COMMERCIAL CENTER

GREENHOUSE GAS EMISSIONS

TECHNICAL REPORT

FRESNO, CALIFORNIA
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Contents

CONTENTS

1. Introduction 1

1.1 Existing Conditions 1

1.2 Project Analysis 1

2. Scientific and Regulatory Backgrounds 2

2.1 Scientific Background 2

2.1.1 Science of Global Climate Change 2

2.1.2 Potential Effects of Human Activity on Global Climate Change 4

2.1.3 Potential Effects of Climate Change on the State of California 5

2.1.3.1 Air Quality 6

2.1.3.2 Water Supply 6

2.1.3.3 Hydrology 7

2.1.3.4 Agriculture 8

2.1.3.5 Ecosystems and Wildfire 8

2.2 Regulatory Background 8

2.2.1 Federal 8

2.2.1.1 Clean Air Act 8

2.2.1.2 Federal Plan to Reduce GHG Emissions by 2025 9

2.2.1.3 Executive Order 14008 9

2.2.1.4 Paris Climate Agreement 10

2.2.1.5 Federal Vehicle Standards 10

2.2.1.6 Energy Independence and Security Act 12

2.2.2 State 13

2.2.2.1 Executive Order S-3-05 13

2.2.2.2 Assembly Bill 32 13

2.2.2.3 SB 605 - Short-lived Climate Pollutants (SLCP) 17

2.2.2.4 Executive Order B-30-15 17

2.2.2.5 Senate Bill 32 and Assembly Bill 197 18

2.2.2.6 Executive Order B-55-18 18

2.2.2.7 Energy Sources 18

2.2.2.8 Mobile Sources 19

2.2.2.9 Water 25

2.2.2.10 Solid Waste Diversion 25

2.2.2.11 Draft Climate Adaptation Strategy 25

2.2.3 Regional 26

2.2.3.1 Fresno COG Regional Transportation Plan and Sustainable Communities Strategy 26

2.2.3.2 San Joaquin Valley Air Pollution Control District 26

2.2.4 Local 28

2.2.4.1 City of Fresno General Plan 28

2.2.4.2 City of Fresno GHG Reduction Plan 28

2.2.5 Other CEQA Guidance 29

2.2.5.1 CAPCOA 29

2.2.5.2 Association of Environmental Professionals 30

3. Significance Thresholds 31

3.1 CEQA Guidelines on GHG Emissions 31

3.2 Other Guidance 31
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3.3 Project Approach to Significance 32

4. Project GHG Emissions Inventory 33

4.1 Measurement, Resources and Baseline Condition 33

4.1.1 Units of Measurement: Tonnes of CO2 and CO2e 33

4.1.2 Resources 33

4.1.2.1 CalEEMod® Methodology 33

4.1.2.2 OFFROAD2017 34

4.1.2.3 Other Resources 35

4.1.3 Indirect GHG Emissions from Electricity Use 35

4.2 One-Time Emissions 35

4.2.1 Construction Emissions 36

4.2.1.1 Emissions from On-Road Construction Trips 36

4.2.1.2 Emissions from Construction Equipment 37

4.2.1.3 Total Construction Emissions 37

4.2.2 Vegetation Changes 37

4.3 Annual Operational Emissions 37

4.3.1 Area Sources 38

4.3.2 Mobile Sources 38

4.3.2.1 Estimating Mobile Source Emissions 39

4.3.2.2 Mobile Source Emissions 39

4.3.3 Water Supply, Treatment and Distribution 40

4.3.4 Energy Use 40

4.3.5 Solid Waste 40

4.4 Total Annual Operational Emissions 41

5. Project Inventory in Context 42

5.1 Project Emissions Inventory 42

5.1.1 GHG Inventory 42

5.2 Consistency Analysis 42

5.2.1 Statewide Emissions Reduction Targets 42

5.2.2 Fresno Council of Governments (Fresno COG) 43

5.2.3 City of Fresno GHG Reduction Plan 44

5.3 Impact Determination 46
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Contents (Continued)

CONTENTS (CONTINUED)
TABLES
Table 4-1: Construction Schedule
Table 4-2: Construction Equipment
Table 4-3: Construction Material Movement
Table 4-4: Construction Demolition Assumptions
Table 4-5: Utility GHG Emission Factor Associated with Renewable Portfolio Standard Table 4-6: TRU Greenhouse Gas Emission Calculations
Table 4-7: Summary of GHG Emissions
Table 5-1: Summary of ABAU and Project GHG Emissions in 2030 and 2035 Table 5-2: Local Measures Reductions Table for 2030 and 2035

APPENDICES
Appendix A – CalEEMod® Output
Appendix B – Mobile Source Emission Calculations
Appendix C – GHG Consistency
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Acronyms and Abbreviations Ramboll

ACRONYMS AND ABBREVIATIONS
Acronym Definition
AB Assembly Bill
ACC Advanced Clean Cars
ACE Affordable Clean Energy
AEP Association of Environmental Professionals
AP-42 United States Environmental Protection Agency’s Compilation of Air Pollutant Emission Factors
APCD Air Pollution Control District
APR Application Review
AQMD Air Quality Management District
AR4 Fourth Assessment Report
AR5 Fifth Assessment Report
AvgHP Maximum rated average horsepower
BAU Business-As-Usual
BPS Best Performance Standards
CAA Clean Air Act
CAFE Corporate Average Fuel Economy
CalEEMod® California Emission Estimator Model®
CalEPA California Environmental Protection Agency
CalRecycle California Department of Resources Recycling and Recovery CAMX California and Mexico
CAPCOA California Air Pollution Control Officers Association CARB California Air Resources Board
CAT Climate Action Team
CCCC California Climate Change Center
CCR California Code of Regulations
CEC California Energy Commission
CEQA California Environmental Quality Act
CFCs Chlorofluorocarbons
CFR Code of Federal Regulations
CH4 Methane
CO2 carbon dioxide
CO2e carbon dioxide equivalent
COG Council of Governments
CPUC California Public Utilities Commission
CY cubic yard
DOE Department of Energy
DTSC Department of Toxic Substances Control
DWR Department of Water Resources
EF emission factor
EISA Energy Independence and Security Act
EMFAC EMission FACtors model
EO Executive Order
EPA Environmental Protection Agency
EVs Electric vehicles
FR Federal Register
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Acronyms and Abbreviations (Continued) Ramboll

ACRONYMS AND ABBREVIATIONS (CONTINUED)
Acronym Definition
GAMAQI Guidance for Assessing and Mitigating Air Quality Impacts GHG greenhouse gas
GW Gigawatt
GWP global warming potential
HFCs hydrofluorocarbons
IPCC Intergovernmental Panel on Climate Change
lbs Pounds
LCFS Low Carbon Fuel Standard
LLC Limited Liability Company
MCY million cubic yards
MDO Market delivery operation
MRR Mandatory Reporting Rule
MSW Municipal solid waste
MT metric tons
N2O nitrogen dioxide
NHTSA National Highway Traffic Safety Administration
OFFROAD Off-road Emissions Inventory Program model
OPR Office of Planning and Research
PFCs perfluorocarbons
PG&E Pacific Gas and Electric
ppm parts per million
PUP Power/Utility Protocol
RCP Representative Concentration Pathways
RCRA Resource Conservation and Recovery Act
RPS Renewables Portfolio Standards
RTP Regional Transportation Plan
SAFE Safer Affordable Fuel-Efficient
SB Senate Bill
SCAQMD South Coast Air Quality Management District
SCE Southern California Edison
SCS Sustainable Communities Strategy
SDG&E San Diego Gas & Electric
SF6 Sulfur hexafluoride
SJVAPCD San Joaquin Valley Air Pollution Control District SLCPs short-lived climate pollutants
TRU transportation refrigeration unit
USDOT the Department of Transportation
USEPA United States Environmental Protection Agency
VMT vehicle miles travelled
VW Volkswagen
ZEVs Zero emission vehicles
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1. INTRODUCTION
Ramboll US Consulting, Inc. (Ramboll) was retained to prepare a Greenhouse Gas (GHG) Emissions Technical Report for the proposed Costco warehouse and gasoline dispensing facility in Fresno, California (Project).

This GHG Emissions Technical Report analyzes the Project’s impacts on GHGs from construction and operations. In particular, this report describes the existing setting of the Project site, describes the relevant regulatory setting, discusses the methodology used to evaluate GHG emissions related to the Project, and evaluates potential impacts related to GHGs that would result with implementation of the Project.

The location of the site is in Fresno, California at West Herndon Avenue and North Riverside Drive (Figure 1).

The project would develop a new Costco retail building; gas station; car wash; and associated parking areas, driveways, and other supporting infrastructure. Costco Wholesale is proposing to construct a wholesale retail facility with approximately 178,000 square feet (sq. ft.); of which approximately 57,000 sq. ft. would be reserved for storage and receiving at the northeast corner of W. Herndon Ave. and N. Riverside Dr (APN 50302012). The project involves the construction of a Costco retail facility that includes an attached tire center, as well as a detached gas station and a drive-through car wash. The project would include a Costco members-only gas station on the northern portion of the project site adjacent to West Spruce Avenue. The facility would include an approximately 11,500 squarefoot canopy and a 125 square-foot controller enclosure. There would be four covered fueling islands, each with four two-sided fuel dispensers to provide for the fueling of eight cars at each island, for a total of 32 fueling positions. A Costco members-only automated carwash would be located at the northeastern corner of the project site, adjacent to the gas station.

The car wash structure would be approximately 4,800 sq. ft. The project would have its main access points along North Riverside Drive and include approximately 889 parking stalls. The project is requesting conditional use permits for Large-Format Retail and alcohol sales, as well as a General Plan Amendment to reclassify the portion of W. Herndon Ave. fronting the project site from Expressway to Superarterial.

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2. SCIENTIFIC AND REGULATORY BACKGROUNDS

2.1 Scientific Background

2.1.1 Science of Global Climate Change
There is a general scientific consensus that global climate change is occurring, caused in whole or in part by increased emissions of GHGs that keep the Earth’s surface warm by trapping heat in the Earth’s atmosphere, in much the same way as glass traps heat in a greenhouse. The Earth’s climate is changing because human activities, primarily the combustion of fossil fuels, are altering the chemical composition of the atmosphere through the buildup of GHGs. GHGs allow the sun’s radiation to penetrate the atmosphere and warm the Earth’s surface, but do not let the infrared radiation emitted from the Earth escape back into outer space. As a result, global temperatures are predicted to increase over the century.

In particular, if climate change remains unabated, surface temperatures in California are expected to increase anywhere from 4.1 to 8.6 degrees Fahrenheit by the end of the century. Not only would higher temperatures directly affect the health of individuals through greater risk of dehydration, heat stroke, and respiratory distress, the higher temperatures may increase ozone formation, thereby worsening air quality. Rising temperatures could also reduce the snowpack, which would increase the risk of water shortages. Higher temperatures along with reduced water supplies could reduce the quantity and quality of agricultural products. In addition, there could be an increase in wildfires and a shift in distribution of natural vegetation throughout the State. Global warming could also increase sea levels and coastal storms resulting in greater risk of flooding.

Emissions of carbon dioxide (CO2) are the leading cause of global warming, with other pollutants such as methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons, and sulfur hexafluoride also contributing. The magnitude of the impact on global warming differs among the GHGs. For example, HFCs, perfluorocarbons, and sulfur hexafluoride have a greater “global warming potential” than CO2. In other words, these other GHGs have a greater contribution to global warming than CO2 on a per mass basis. The effect each GHG has on climate change is measured as a combination of the volume of its emissions and its global warming potential (GWP), and is expressed as a function of how much warming would be caused by the same mass of CO2. Thus, GHG emissions are typically measured in terms of megagrams or metric tons (MT) of carbon dioxide equivalent (CO2e).

CO2 has the greatest impact on global warming because of the relatively large quantities of CO2 emitted into the atmosphere.

Globally, CO2 concentrations, which ranged from 265 parts per million (ppm) to 280 ppm over the last 10,000 years, only began rising in the last 200 years to current levels of 410 ppm,1 a 46 percent increase.

In 2019, the United States emitted about 6.6 billion MT of CO2e or about 20 MT/person/year, calculated by dividing the emissions total by the U.S. Census Bureau 2019 population 1 Intergovernmental Panel on Climate Change (IPCC). Climate Change 2021, The Physical Science Basis. 2021.

Available at: https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Full_Report.pdf. Accessed:

January 2022.

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estimate. 2, 3 This represents a 12 percent reduction below 2005 total emission levels. Of the five major sectors nationwide -- residential, commercial, industrial, electric power generation, and transportation - transportation accounts for the highest fraction of GHG emissions (approximately 29 percent of emissions from these five sectors). These emissions are entirely generated from direct fossil fuel combustion. Fifty-eight percent of these transportation emissions resulted from passenger car and light-duty truck use. The remaining emissions came from other transportation activities, including the combustion of diesel fuel in medium- and heavy-duty vehicles, and jet fuel in aircraft. According to the Inventory of U.S. Greenhouse Gas Emissions and Sinks,4 from 1990 to 2019 as a whole, transportation emissions from fossil fuel combustion rose, “due, in large part, to increased demand for travel”.

In 2019, California emitted approximately 418 million tonnes of CO2e, or about 6 percent of the U.S. emissions.5 California’s percentage contribution is due primarily to the sheer size of California, as compared to other states. For example, in 2018 (the most recent year of state rankings for energy-related CO2 emissions per capita), California had the third lowest per capita energy-related CO2 emission rates in the country (including Washington DC),6 due to the success of its energy efficiency and renewable energy programs and commitments that have lowered the State’s GHG emissions rate of emissions growth.7 California’s per capita GHG emissions in 2019 were 10.5 metric tons per person8, while the U.S. per capita GHG emissions in that same year were 20.0 metric tons per person.9, 10 Another factor that has reduced California’s fuel use and GHG emissions is its mild climate compared to that of many other states. The emissions for the City of Fresno were approximately 2.9 million metric tons of CO2e in 2016. The projected 2020 emissions for the City of Fresno are about 2.1 million 2 USEPA. 2021. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2019. Available at:
https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks-1990-2019. Accessed:

January 2022.
3 U.S. Census Bureau. Annual Estimates of the Resident Population for the United States, Regions, States, and Puerto Rico: April 1, 2010 to July 1, 2019. (NST-EST2020). Available at: https://www2.census.gov/programssurveys/popest/tables/2010-2020/state/totals/nst-est2020.xlsx. Accessed: January 2022. 4 USEPA. 2021. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2019. Available at:
https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks-1990-2019. Accessed:

January 2022.
5 CARB. 2021. California Greenhouse Gas Emissions for 2000 to 2019 Trends of Emissions and Other Indicators.

Available at: https://ww3.arb.ca.gov/cc/inventory/pubs/reports/2000_2019/ghg_inventory_trends_00-19.pdf.

Accessed: January 2022.
6 US EIA. 2021.Table 5: Per capita energy-related carbon dioxide emissions by state. Available at:
https://www.eia.gov/environment/emissions/state/. Accessed: January 2022. 7 The Center for Resource Efficient Communities. 2013. Residential Energy Use and GHG Emissions Impact of Compact Land Use Types. Report to ARB, Contract No. 10-323. Available at:
http://www.arb.ca.gov/research/apr/past/10-323h.pdf. Accessed: January 2022. 8 CARB. 2021. California Greenhouse Gas Emissions for 2000 to 2019 Trends of Emissions and Other Indicators.

Available at: https://ww3.arb.ca.gov/cc/inventory/pubs/reports/2000_2019/ghg_inventory_trends_00-19.pdf.

Accessed: January 2022.
9 USEPA. 2021. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2019. Available at:
https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks-1990-2019. Accessed:

January 2022.
10 U.S. Census Bureau. Annual Estimates of the Resident Population for the United States, Regions, States, and Puerto Rico: April 1, 2010 to July 1, 2019. (NST-EST2020). Available at: https://www2.census.gov/programssurveys/popest/tables/2010-2020/state/totals/nst-est2020.xlsx. Accessed: January 2022.

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metric tons of CO2e when accounting for emission reductions achieved by state-wide regulations, programs, and measures.11
The California Energy Commission (CEC) found that transportation is the source of approximately 40 percent of the State’s GHG emissions, followed by industrial sources at 21 percent, and electricity generation (both in-state and out-of-state) at 14 percent. Residential and commercial activities comprised approximately 11 percent of the inventory. Agriculture and forestry is the source of approximately 8 percent of the State’s GHG emissions.12

2.1.2 Potential Effects of Human Activity on Global Climate Change Globally, climate change has the potential to impact numerous environmental resources through anticipated, though uncertain, impacts related to future air temperatures and precipitation patterns. Scientific modeling predicts that continued GHG emissions at or above current rates would induce more extreme climate changes during the 21st century than were observed during the 20th century. At the end of the 21st century, global surface temperature change is likely to exceed 1.5°C (relative to 1850-1900 levels) in all four assessed climate model projections but one.13
The understanding of GHG emissions, particulate matter, and aerosols on global climate trends is complex and involves varying uncertainties and a balance of different effects. In addition to uncertainties about the extent to which human activity rather than solar or volcanic activity is responsible for increasing warming, there is also evidence that some human activity has cooling, rather than warming, effects, as discussed in detail in numerous publications by the Intergovernmental Panel on Climate Change (IPCC), such as the Fifth Assessment Report (AR5) Synthesis Report.14, 15 Nonetheless, when all effects and uncertainties are considered together, there is a strong scientific consensus that human activity has contributed significantly to global warming. As stated in the executive summary for the Working Group I contribution to the Sixth Assessment Report, “The evidence for human influence on recent climate change strengthened from the IPCC Second Assessment Report to the IPCC Fifth Assessment Report, and is now even stronger in this assessment.”16 11 LSA. 2021. Greenhouse Gas Reduction Plan Update for the City of Fresno. Available at:
https://www.fresno.gov/darm/wp-content/uploads/sites/10/2021/03/Link4AppendixGGHGRPUpdate.pdf.

Accessed: March 2022.
12 CARB. 2021. California Greenhouse Gas Emissions for 2000 to 2019 Trends of Emissions and Other Indicators.

Available at: https://ww3.arb.ca.gov/cc/inventory/pubs/reports/2000_2019/ghg_inventory_trends_00-19.pdf.

Accessed: January 2022.
13 IPCC. Intergovernmental Panel on Climate Change (IPCC) Fifth Assessment Report. Climate Change 2014:

Synthesis Report. 2014. SPM.2.2. Available at:
https://www.ipcc.ch/site/assets/uploads/2018/02/SYR_AR5_FINAL_full.pdf. Accessed: January 2022. 14 The IPCC was established in 1988 by the World Meteorological Organization and the United Nations Environment Programme to assess scientific, technical, and socio-economic information relevant for the understanding of climate change, its potential impacts, and options for adaptation and mitigation. The IPCC has produced a series of Assessment Reports comprised of full scientific and technical assessments of climate change. The first assessment report was developed in 1990. The Fifth Assessment Report was completed in November 2014 with the Synthesis Report.
15 Intergovernmental Panel on Climate Change (IPCC) Fifth Assessment Report. Climate Change 2014: Synthesis Report. 2014. Figure SPM.3. Available at:
https://www.ipcc.ch/site/assets/uploads/2018/02/SYR_AR5_FINAL_full.pdf. Accessed: January 2022. 16 IPCC. 2021. Climate Change 2021 The Physical Science Basis, Working Group I contribution to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change. Available at:

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Acknowledging uncertainties regarding the rate at which anthropogenic GHG emissions would continue to increase (based upon various factors under human control, such as future population growth and the locations of that growth; the amount, type, and locations of economic development; the amount, type, and locations of technological advancement; adoption of alternative energy sources; legislative and public initiatives to curb emissions; and public awareness and acceptance of methods for reducing emissions), and the impact of such emissions on climate change, the IPCC devises emission scenarios which utilize various assumptions about the rates of economic development, population growth, and technological advancement over the course of the next century. For the AR5, Representative Concentration Pathways (RCPs) were developed to describe four different 21st century scenarios of greenhouse gas emissions, atmospheric concentrations, air pollutant emissions, and land use. RCPs are based on a combination of integrated assessment models, simple climate models, atmospheric chemistry, and global carbon cycle models. x The projected effects of global warming are assessed under each of the five scenarios.17 x It is, at a minimum, more likely than not a 1.5oC increase in globally averaged surface area temperature (GSAT) will occur between 2021-2045 relative to the average over the period of 1850-1900.
x It is virtually certain that global mean sea level (GMSL) will continue to rise through the 21st century.
x It is likely the Arctic Ocean in September, the month of annual minimum sea ice area, will become practically ice free averaged over 2081-2100 and all available simulations. x It is very likely that the cumulative uptake of carbon by the ocean and by land will increase through the end of the 21st century.

Potential secondary effects from global warming include impacts to agriculture, changes in disease vectors, and changes in habitat and biodiversity.

2.1.3 Potential Effects of Climate Change on the State of California According to the California Air Resources Board (CARB), some of the potential impacts in California of global warming may include loss in snowpack, sea level rise, more extreme heat days per year, more high ozone days, more large forest fires, and more drought years.18 The California Climate Change Center (CCCC) has released four assessment reports on climate change in California, the most recent in 2018. California’s Fourth Climate Change Assessment projects an increase by 5.6-8.8°F from 2070 to 2100 depending on greenhouse gas emission reductions (at a moderate rate or continuing at current rates).19 https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Full_Report.pdf. Accessed: January 2022.
17 Intergovernmental Panel on Climate Change (IPCC) Fifth Assessment Report. Climate Change 2014: Synthesis Report. 2014. Available at: https://www.ipcc.ch/site/assets/uploads/2018/02/SYR_AR5_FINAL_full.pdf.

Accessed: January 2022.
18 California Air Resources Board (CARB), 2006. Public Workshop to Discuss Establishing the 1990 Emissions Level and the California 2020 Limit and Developing Regulations to Require Reporting of Greenhouse Gas Emissions, Sacramento, CA. December 1.
19 California Climate Change Center, 2018. California’s Changing Climate 2018. A Summary of Key Findings from California’s Fourth Climate Change Assessment.

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Below is a summary of some of the potential effects reported in an array of studies that could be experienced in California as a result of global warming and climate change.

2.1.3.1 Air Quality
Higher temperatures, conducive to air pollution formation, could worsen air quality in California. Climate change may increase the concentration of ground-level ozone, but the magnitude of the effect, and therefore its indirect effects, are uncertain. For other pollutants, the effects of climate change and/or weather are less well studied, and even less well understood.

If higher temperatures are accompanied by drier conditions, the potential for large wildfires could increase, which, in turn, would further worsen air quality. Studies have been conducted to evaluate the potential impacts of climate change on wildfire frequency based on lower and higher emissions scenarios. Per California’s Fourth Climate Change Assessment, under a higher emissions scenario, the average area burned statewide could increase by 77 percent above historic levels by 2100.20 Per California’s Third Climate Change Assessment, the estimated burned area is projected to increase between 57 and 169 percent, depending on location.21 However, if higher temperatures are accompanied by wetter, rather than drier conditions, the rains would tend to temporarily clear the air of particulate pollution and reduce the incidence of large wildfires, thus ameliorating the pollution associated with wildfires. Additionally, severe heat accompanied by drier conditions and poor air quality could increase the number of heat-related deaths, illnesses, and asthma attacks throughout the State.22
It is estimated that over the next decade, higher temperatures could increase the demand for electricity by 1 Gigawatt (GW) during summer months, which would require purchase of costly peak power from external sources or the construction of one new large power plant in California.23 During periods of extreme heat, efficiency of electricity generation is reduced at natural gas plants; hydropower generation is reduced; and increased losses occur at substations; all while electricity demands are increased. These factors are projected to result in the need for more than 17 GW, or 38 percent of additional capacity, needed by 2100.

Additionally, transmission lines lose 7 to 8 percent of transmitting capacity in higher temperatures, which also results in a need for increased power generation.24

2.1.3.2 Water Supply
Uncertainty remains with respect to the overall impact of global climate change on future water supplies in California. For example, models that predict drier conditions suggest decreased reservoir inflows and storage, and decreased river flows, relative to current 20 Ibid.
21 California Climate Change Center, 2012. Our Changing Climate 2012: Vulnerability and Adaptation to the Increasing Risks from Climate Change in California. CEC-500-2012-007. July, 2012. 22 California Climate Change Center (CCCC), 2006. Our Changing Climate: Assessing the Risks to California, CEC500-2006-077, Sacramento, CA. July. Available at: https://www.engr.scu.edu/~emaurer/papers/CEC-500- 2006-077.pdf. Accessed: January 2022.
23 California Climate Change Center, 2012. Our Changing Climate 2012: Vulnerability and Adaptation to the Increasing Risks from Climate Change in California. CEC-500-2012-007. July, 2012. 24 California Climate Change Center, 2012. Our Changing Climate 2012: Vulnerability and Adaptation to the Increasing Risks from Climate Change in California. CEC-500-2012-007. July, 2012.

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conditions. By comparison, models that predict wetter conditions project increased reservoir inflows and storage, and increased river flows.25
A July 2006 technical report prepared by the California Department of Water Resources (DWR) addresses the State Water Project, the Central Valley Project, and the SacramentoSan Joaquin Delta. Although the report projects that, “[c]limate change will likely have a significant effect on California’s future water resources … [and] future water demand,” it also reports that, “there is much uncertainty about future water demand, especially those aspects of future demand that will be directly affected by climate change and warming. While climate change is expected to continue through at least the end of this century, the magnitude and, in some cases, the nature of future changes is uncertain. This uncertainty serves to complicate the analysis of future water demand, especially where the relationship between climate change and its potential effect on water demand is not well understood,”26 DWR adds that “[i]t is unlikely that this level of uncertainty will diminish significantly in the foreseeable future.”27 Still, changes in water supply are expected to occur, and many regional studies have shown that large changes in the reliability of water yields from reservoirs could result from only small changes in inflows.28
California’s Third Climate Change Assessment outlines the State’s urgent water management challenges brought on as a result of climate change. These include increasing demand from a growing population as temperatures rise, earlier snowmelt and runoff, and faster-thanhistorical sea-level rise threatening aging coastal water infrastructure and levees in the Sacramento-San Joaquin Delta.29 Additionally, they predict that competition between urban and agriculture water users and environmental needs will increase due to effects on water supply and stream flows. The Fourth Climate Change Assessment concludes that by 2100, water supply from snowpack is projected to decline by two-thirds, and that by 2050, California’s agricultural production could face climate-related water shortages of up to 16 percent in certain regions.30

2.1.3.3 Hydrology
As discussed above, climate change could potentially affect the following: the amount of snowfall, rainfall, and snowpack; the intensity and frequency of storms; flood hydrographs (flash floods, rain or snow events, coincidental high tide, and high runoff events); sea level rise and coastal flooding; coastal erosion; and the potential for saltwater intrusion. Sea level rise can be a product of global warming through two main processes -- expansion of sea water as the oceans warm and melting of ice over land. A rise in sea levels could result in coastal flooding and erosion and could also jeopardize California’s water supply. In particular, 25 Brekke, L.D., et al, 2004. ȸClimate Change Impacts Uncertainty for Water Resources in the San Joaquin River Basin, California. Journal of the American Water Resources Association. 40(2): 149–164. Malden, MA, Blackwell Synergy for AWRA.
26 California Department of Water Resources (DWR), 2006. Progress on Incorporating Climate Change into Management of California Water Resources, Sacramento, CA. July. 27 California Department of Water Resources (DWR), 2006. Progress on Incorporating Climate Change into Management of California Water Resources, Sacramento, CA. July. 28 Kiparsky 2003, op. cit; DWR, 2005, op. cit.; Cayan, D., et al, 2006. Scenarios of Climate Change in California:

An Overview (White Paper, CEC-500-2005-203-SF), Sacramento, CA. February. 29 California Climate Change Center, 2012. Our Changing Climate 2012: Vulnerability and Adaptation to the Increasing Risks from Climate Change in California. CEC-500-2012-007. July, 2012. 30 California Climate Change Center, 2018. California’s Changing Climate 2018. A Summary of Key Findings from California’s Fourth Climate Change Assessment.

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saltwater intrusion would threaten the quality and reliability of the State’s major fresh water supply that is pumped from the southern portion of the Sacramento/San Joaquin River Delta.

Increased storm intensity and frequency could affect the ability of flood-control facilities, including levees, to handle storm events. Assuming the rate of sea level rise continues to follow global trends, sea level along California’s coastline in 2050 could be 10-18 inches higher than in 2000, and 31-55 inches higher by the end of this century.31 Based on these current projections, the current 100-year storm could occur once every year. California’s Fourth Climate Change Assessment projects that without implementation of protective measures, airports in major urban areas will be susceptible to major flooding from a combination of sea-level rise and storm surge by 2040 to 2080 and that the miles of highways susceptible to coastal flooding from a 100-year storm will triple from current levels by 2100.32

2.1.3.4 Agriculture
California has a $30 billion agricultural industry that produces half the country’s fruits and vegetables. The CCCC notes that higher CO2 levels can stimulate plant production and increase plant water-use efficiency. However, if temperatures rise and drier conditions prevail, water demand could increase, crop-yield could be threatened by a less reliable water supply, and greater ozone pollution could render plants more susceptible to pest and disease outbreaks. In addition, temperature increases could change the time of year that certain crops, such as wine grapes, bloom or ripen, and thus affect their quality.33

2.1.3.5 Ecosystems and Wildfire
Increases in global temperatures and the potential resulting changes in weather patterns could have ecological effects on a global and local scale. In 2004, the Pew Center on Global Climate Change released a report examining the possible impacts of climate change on ecosystems and wildlife.34 The report outlines four major ways in which it is thought that climate change could affect plants and animals: (1) timing of ecological events, (2) geographic range, (3) species’ composition within communities, and (4) ecosystem processes such as carbon cycling and storage.

2.2 Regulatory Background

2.2.1 Federal

2.2.1.1 Clean Air Act
In April 2007, in Massachusetts v. EPA, the U.S. Supreme Court directed the Administrator of the U.S. Environmental Protection Agency (USEPA) to determine whether GHG emissions from new motor vehicles cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare, or whether the science is too uncertain to make a reasoned decision. In making these decisions, the USEPA Administrator was directed to follow the language of Section 202(a) of the Clean Air Act (CAA). In December 2009, the 31 California Climate Change Center, 2012. Our Changing Climate 2012: Vulnerability and Adaptation to the Increasing Risks from Climate Change in California. CEC-500-2012-007. July, 2012. 32 California Climate Change Center, 2018. California’s Changing Climate 2018. A Summary of Key Findings from California’s Fourth Climate Change Assessment.
33 California Climate Change Center (CCCC), 2006, op. cit. 34 Parmesan, C. and H. Galbraith, Observed Impacts of Global Climate Change in the U.S., Arlington, VA: Pew Center on Global Climate Change, November 2004.

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Administrator signed a final rule with two distinct findings regarding GHGs under Section 202(a) of the CAA:
x Elevated concentrations of GHGs—CO2, CH4, N2O, HFCs, perfluorocarbons (PFCs), and sulfur hexafluoride (SF6)—in the atmosphere threaten the public health and welfare of current and future generations. This is referred to as the “endangerment finding.” x The combined emissions of GHGs—CO2, CH4, N2O, and HFCs—from new motor vehicles and new motor vehicle engines contribute to the GHG air pollution that endangers public health and welfare. This is referred to as the “cause or contribute finding.” These two findings were necessary to establish the foundation for regulation of GHGs from new motor vehicles as air pollutants under the CAA.

2.2.1.2 Federal Plan to Reduce GHG Emissions by 2025
In 2015, President Obama signed Executive Order 13693 (EO 13693), which was intended to reduce the federal government’s GHG emissions by 40 percent by 2025 by requiring the following:
x Ensuring that 25 percent of total energy consumption is from clean energy sources. x Reducing energy use in federal buildings by 2.5 percent per year between 2015 and 2025.
x Reducing per-mile GHG emissions from federal fleets by 30 percent (from 2014 levels) by 2025 and increasing the percentage of zero-emissions and plug-in hybrid vehicles in federal fleets.
x Reducing water intensity in federal buildings by 2 percent per year through 2025.

This executive order was revoked by President Trump’s Executive Order 13834 in May 2018.

President Biden’s Executive Order 13990 revoked Executive Order 13834 except for sections 6 (Duties of the Federal Chief Sustainability Officer), 7 (Duties of Heads of Agencies), and 11 (General Provisions).35

2.2.1.3 Executive Order 14008
On January 27, 2021, President Biden issued an Executive Order on Tackling the Climate Crisis at Home and Abroad (Executive Order 14008).36 Part I of the Order highlights putting the climate crisis at the center of United States foreign policy and national security.

Addressing the climate crisis will require significant short-term global reductions in GHG emissions and net-zero global emissions by mid-century or sooner. The United States will pursue green recovery efforts and initiatives to advance the clean energy transition.

Part II of the Order relays the government-wide approach to the climate crisis, which involves reducing climate pollution in every sector of the economy, especially through innovation, commercialization, and deployment of clean energy technologies and 35 White House Briefing Room. 2021. Executive Order on Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis. January 20. Available at: https://www.whitehouse.gov/briefingroom/presidential-actions/2021/01/20/executive-order-protecting-public-health-and-environment-andrestoring-science-to-tackle-climate-crisis/. Accessed: March 2022. 36 White House Briefing Room. 2021. Executive Order on Tackling the Climate Crisis at Home and Abroad.

January 27. Available at: https://www.whitehouse.gov/briefing-room/presidentialactions/2021/01/27/executive-order-on-tackling-the-climate-crisis-at-home-and-abroad/. Accessed: January 2022.

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infrastructure. A National Climate Task Force is established to focus on addressing the climate crisis through key federal actions to reduce climate change impacts. A 100% carbon pollution-free electricity sector is targeted by no later than 2035 and a net-zero emissions economy is to be achieved by no later than 2050. Offshore wind is aimed to be doubled by 2030. Opportunities for federal funding of clean energy technology and infrastructure shall be identified. Federal permitting decisions need to consider the effects of GHG emissions and climate change.

2.2.1.4 Paris Climate Agreement
On June 1, 2017, President Trump withdrew the United States from the Paris Agreement.37 The Paris Agreement was negotiated within the United Nations Framework Convention on Climate Change in 2015 to reduce GHG emissions internationally. The goal of the Paris Agreement was to keep the global temperature rise this century to below 2 degrees Celsius above pre-industrial standards, with efforts to limit temperature increase even further to

1.5 degrees Celsius. The Paris Agreement became effective on November 4, 2016. As of October 5, 2016, 155 of 197 parties had ratified the Paris Agreement.38 On January 20, 2021, President Biden signed an Executive Order formally rejoining the United States to the Paris Agreement.39

2.2.1.5 Federal Vehicle Standards
In response to the Massachusetts v. EPA decision discussed above, in 2007, President Bush directed the USEPA, the Department of Transportation (USDOT), and the Department of Energy (DOE) to establish regulations that reduce GHG emissions from motor vehicles, nonroad vehicles, and non-road engines by 2008. In 2009, the National Highway Traffic Safety Administration (NHTSA) issued a final rule regulating fuel efficiency for and GHG emissions from cars and light-duty trucks for model year 2011; and in 2010, the USEPA and NHTSA issued a final rule regulating cars and light-duty trucks for model years 2012–2016.

In 2010, President Obama issued a memorandum directing the same federal agencies to establish additional standards regarding fuel efficiency and GHG reduction, clean fuels, and advanced vehicle infrastructure. In response to this directive, the USEPA and NHTSA proposed stringent, coordinated federal GHG and fuel economy standards for model year 2017–2025 light-duty vehicles. The proposed standards are projected to achieve 163 grams/mile of CO2 in model year 2025, on an average industry fleet-wide basis, which is equivalent to 54.5 miles per gallon if this level were achieved solely through fuel efficiency.

The final rule was adopted in 2012 for model years 2017–2021.

In August 2017, the USEPA asked for additional information and data relevant to assessing whether the GHG emissions standards for model years 2022-2025 remain appropriate. In early 2018, the USEPA Administrator announced that the midterm evaluation for the GHG emissions standards for cars and light-duty trucks for model years 2022-2025 was completed and stated his determination that the current standards should be revised in light 37 USEPA. 2017. Administrator Scott Pruitt Speech on Paris Accord, As Prepared. June 1. Available at:
https://archive.epa.gov/epa/speeches/administrator-scott-pruitt-speech-paris-accord-prepared.html. Accessed:

January 2022.
38 United Nations Framework Convention on Climate Change. 2017. The Paris Agreement. July 27. Available at:
http://unfccc.int/paris_agreement/items/9485.php. Accessed: January 2022. 39 White House Briefing Room. 2021. Paris Climate Agreement. January 20. Available at:
https://www.whitehouse.gov/briefing-room/statements-releases/2021/01/20/paris-climate-agreement/.

Accessed: January 2022.

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of recent data. Subsequently, in 2018, the USEPA and NHTSA proposed to amend certain existing Corporate Average Fuel Economy (CAFE) standards and tailpipe carbon dioxide emissions standards for passenger cars and light trucks and establish new standards, covering model years 2021-2026. Compared to maintaining the post-2020 standards now in place, the pending proposal would increase U.S. fuel consumption.40 California and other states have announced their intent to challenge federal actions that would delay or eliminate GHG reductions. In April 2020, NHTSA and EPA amended the CAFE and GHG emissions standards for passenger cars and light trucks and established new less stringent standards, covering model years 2021 through 2026.

In addition to the regulations applicable to cars and light-duty trucks described above, in 2011, the USEPA and NHTSA announced fuel economy and GHG standards for medium- and heavy-duty trucks for model years 2014–2018. The standards for CO2 emissions and fuel consumption are tailored to three main vehicle categories: combination tractors, heavy-duty pickup trucks and vans, and vocational vehicles.

In August 2016, the USEPA and NHTSA announced the adoption of the phase two program related to the fuel economy and GHG standards for medium- and heavy-duty trucks. The phase two program will apply to vehicles with model year 2018 through 2027 for certain trailers, and model years 2021 through 2027 for semi-trucks, large pickup trucks, vans and all types of sizes of buses and work trucks. The final standards are expected to lower carbon dioxide emissions by approximately 1.1 billion MT and reduce oil consumption by up to two billion barrels over the lifetime of the vehicles sold under the program.41 On September 27, 2019, the USEPA and NHTSA published the SAFE Rule (Part One).42 The SAFE Rule (Part One) went into effect in November 2019, and revoked California’s authority to set its own GHGs standards and set zero emission vehicle mandates in California. The SAFE Rule (Part One) freezes new zero emission vehicles (ZEV) sales at model year 2020 levels for year 2021 and beyond, and will likely result in a lower number of future ZEVs and a corresponding greater number of future gasoline internal combustion engine vehicles. In response to the USEPA’s adoption of the SAFE Rule (Part One), CARB has issued guidance regarding the adjustment of vehicle emissions factors to account for the rule’s implications on criteria air pollutant and greenhouse gas emissions.43,44 The SAFE Rule is subject to ongoing litigation and on February 8, 2021, the D.C. Circuit Court of Appeals granted the Biden Administration’s motion to stay litigation over Part 1 of the SAFE Rule. On April 22 and 40 Federal Register. 2018. The Safer Affordable Fuel-Efficient (SAFE) Vehicles Final Rule for Model Years 2021- 2026 Passenger Cars and Light Trucks. Available at: https://www.epa.gov/regulations-emissions-vehicles-andengines/safer-affordable-fuel-efficient-safe-vehicles-final-rule. Accessed: January 2022. 41 USEPA and NHTSA, 2016. Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium and Heavy-Duty Engines and Vehicles – Phase 2. Available at: https://www.gpo.gov/fdsys/pkg/FR-2016-10-25/pdf/2016- 21203.pdf. Accessed: January 2022.
42 USEPA and NHTSA. 2019. Federal Register, Vol. 84, No. 188, The Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule Part One: One National Program. September 27. Available at: https://www.govinfo.gov/content/pkg/FR2019-09-27/pdf/2019-20672.pdf. Accessed: January 2022. 43 CARB. 2019. EMFAC Off-Model Adjustment Factors to Account for the SAFE Vehicle Rule Part One. November 20.

Available at: https://ww3.arb.ca.gov/msei/emfac_off_model_adjustment_factors_final_draft.pdf. Accessed:

January 2022.
44 CARB. 2020. EMFAC Off-Model Adjustment Factors for Carbon Dioxide Emissions to Account for the SAFE Vehicles Rule Part One and the Final SAFE Rule. June 26. Available at:
https://ww3.arb.ca.gov/msei/emfac_off_model_co2_adjustment_factors_06262020-final.pdf. Accessed: January 2022
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April 28, 2021, respectively, NHTSA and USEPA formally announced their intent to reconsider the Safe Rule (Part One).45,46 A virtual public hearing for EPA’s Notice of Reconsideration of SAFE I was held on June 2, 2021. The NHTSA finalized the Corporate Average Fuel Economy Pre-emption rulemaking to withdraw its portions of the SAFE I Rule on December 21, 2021.47 On March 9, 2022, USEPA reinstated California’s authority under the Clean Air Act to implement its own GHG emission standards and ZEV sales mandate and entirely rescinded the SAFE Rule (Part One).

In December 2021, the USEPA finalized federal GHG emissions standards for passenger cars and light trucks for Model Years 2023 through 2026. These standards are the strongest vehicle emissions standards ever established for the light-duty vehicle sector and are based on sound science and grounded in a rigorous assessment of current and future technologies.

The updated standards will result in avoiding more than 3 billion tons of GHG emissions through 2050.48

2.2.1.6 Energy Independence and Security Act
The Energy Independence and Security Act of 2007 (EISA) facilitates the reduction of national GHG emissions by requiring the following:
x Increasing the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard that requires fuel producers to use at least 36 billion gallons of biofuel in 2022. x Prescribing or revising standards affecting regional efficiency for heating and cooling products, procedures for new or amended standards, energy conservation, energy efficiency labeling for consumer electronic products, residential boiler efficiency, electric motor efficiency, and home appliances.
x Requiring approximately 25 percent greater efficiency for light bulbs by phasing out incandescent light bulbs between 2012 and 2014; requiring approximately 200 percent greater efficiency for light bulbs, or similar energy savings, by 2020. x While superseded by the USEPA and NHTSA actions described above, (i) establishing miles per gallon targets for cars and light trucks and (ii) directing the NHTSA to establish a fuel economy program for medium- and heavy-duty trucks and create a separate fuel economy standard for trucks.

Additional provisions of EISA address energy savings in government and public institutions, promote research for alternative energy, additional research in carbon capture, international energy programs, and the creation of “green jobs.”
45 NHTSA. 2021. NHTSA Advances Biden-Harris Administration’s Climate & Jobs Goals. April 22. Available at:
https://www.nhtsa.gov/press-releases/nhtsa-advances-biden-harris-administrations-climate-jobs-goals.

Accessed: January 2022.
46 USEPA. 2021. Federal Register, Vol. 86, No. 80, California State Motor Vehicle Pollution Control Standards; Advanced Clean Car Program; Reconsideration of a previous Withdrawal of a Waiver of Preemption; Opportunity for Public Hearing and Public Comment. April 28. Available at: https://www.epa.gov/regulations-emissionsvehicles-and-engines/notice-reconsideration-previous-withdrawal-waiver. Accessed: January 2022. 47 NHTSA. Available at: https://www.nhtsa.gov/laws-regulations/corporate-average-fuel-economy. Accessed: May 2022.
48 USEPA. 2021. Final Rule to Revise Existing National GHG Emissions Standards for Passenger Cars and Light Trucks Through Model Year 2026. Available at: https://www.epa.gov/regulations-emissions-vehicles-andengines/final-rule-revise-existing-national-ghg-emissions. Accessed: January 2022.

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2.2.2 State
The State of California considers GHG emissions and the impacts of climate change to be a serious threat to the public health, environment, economic well-being, and natural resources of California, and has taken an aggressive stance to mitigate the State’s impact on climate change through the adoption of policies and legislation. CARB is responsible for the coordination and oversight of State and local air pollution control programs in California.

California has numerous regulations aimed at reducing the State’s GHG emissions. Some of the major initiatives are summarized below.

2.2.2.1 Executive Order S-3-05
In 2005, Governor Schwarzenegger issued EO S-3-05, which identifies Statewide GHG emission reduction targets to achieve long-term climate stabilization as follows. x Reduce GHG emissions to 1990 levels by 2020; and
x Reduce GHG emissions to 80 percent below 1990 levels by 2050.

In response to EO S-3-05, California Environmental Protection Agency (CalEPA) created the Climate Action Team (CAT), which in March 2006 published the Climate Action Team Report (the “2006 CAT Report”).49 The 2006 CAT Report identified a recommended list of strategies that the State could pursue to reduce GHG emissions. These are strategies that could be implemented by various State agencies to ensure that the emission reduction targets in EO S-3-05 are met and can be met with existing authority of the State agencies. The strategies include, but are not limited to, the reduction of passenger and light-duty truck emissions, the reduction of idling times for diesel trucks, an overhaul of shipping technology/infrastructure, increased use of alternative fuels, increased recycling, and landfill methane capture.

2.2.2.2 Assembly Bill 32
Assembly Bill (AB) 32 (Nunez, 2006), the California Global Warming Solutions Act of 2006, was enacted after considerable study and expert testimony before the Legislature. The heart of AB 32 is the requirement that statewide GHG emissions be reduced to 1990 levels by 2020. In order to achieve this reduction mandate, AB 32 requires California Air Resources Board to adopt rules and regulations in an open public process that achieve the maximum technologically feasible and cost-effective GHG reductions.

In 2007, CARB approved a statewide limit on the GHG emissions level for year 2020 consistent with the determined 1990 baseline. CARB’s adoption of this limit is in accordance with Health & Safety Code Section 38550, as codified through enactment of AB 32.

Per Health & Safety Code Section 38561(b), CARB also is required to prepare, approve and amend a scoping plan that identifies and makes recommendations on “direct emission reduction measures, alternative compliance mechanisms, market-based compliance mechanisms, and potential monetary and nonmonetary incentives for sources and categories of sources that [CARB] finds are necessary or desirable to facilitate the achievement of the maximum feasible and cost-effective reductions of greenhouse gas emissions by 2020.” 49 California Environmental Protection Agency (CalEPA), March 2006. Climate Action Team Report to Governor Schwarzenegger and the Legislature. Available at: http://s3-us-west-2.amazonaws.com/ucldc-nuxeo-refmedia/0bdec21c-ca2b-4f4d-9e11-35935ac4cf5f. Accessed: January 2022.

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In 2008, CARB adopted the Climate Change Scoping Plan: A Framework for Change (2008 Scoping Plan) in accordance with Health & Safety Code Section 38561. During the development of the 2008 Scoping Plan, CARB created a planning framework that is comprised of eight emissions sectors: (1) transportation; (2) electricity; (3) commercial and residential; (4) industry; (5) recycling and waste; (6) high GWP gases; (7) agriculture; and (8) forest net emissions. The 2008 Scoping Plan establishes an overall framework for the measures that will be adopted to reduce California’s GHG emissions from the eight emissions sectors to 1990 levels by 2020.

In the 2011 Final Supplement to the AB 32 Scoping Plan Functional Equivalent Document (2011 Final Supplement), CARB revised its estimates of the projected 2020 emissions level in light of the economic recession and the availability of updated information about GHG reduction regulations.
a) 2014 First Update to the Scoping Plan
In 2014, CARB adopted the First Update to the Climate Change Scoping Plan: Building on the Framework (2014 First Update).50 The stated purpose of the 2014 First Update is to “highlight […] California’s success to date in reducing its GHG emissions and lay […] the foundation for establishing a broad framework for continued emission reductions beyond 2020, on the path to 80 percent below 1990 levels by 2050.”51 The 2014 First Update found that California is on track to meet the 2020 emissions reduction mandate established by AB 32, and noted that California could reduce emissions further by 2030 to levels squarely in line with those needed to stay on track to reduce emissions to 80 percent below 1990 levels by 2050 if the State realizes the expected benefits of existing policy goals.52 In conjunction with the 2014 First Update, CARB identified “six key focus areas comprising major components of the State’s economy to evaluate and describe the larger transformative actions that will be needed to meet the State’s more expansive emission reduction needs by 2050.”53 Those six areas are: (1) energy; (2) transportation (vehicles/equipment, sustainable communities, housing, fuels, and infrastructure); (3) agriculture; (4) water; (5) waste management; and (6) natural and working lands. The 2014 First Update identifies key recommended actions for each sector that will facilitate achievement of the 2050 reduction target.

Based on CARB’s research efforts, it has a “strong sense of the mix of technologies needed to reduce emissions through 2050.”54 Those technologies include energy demand reduction through efficiency and activity changes; large-scale electrification of on-road vehicles, buildings, and industrial machinery; decarbonizing electricity and fuel supplies; and the rapid market penetration of efficient and clean energy technologies.

As part of the 2014 First Update, CARB recalculated the State’s 1990 emissions level using more recent global warming potentials identified by the IPCC. Using the recalculated 1990 emissions level and the revised 2020 emissions level projection identified in the 2011 Final Supplement, CARB determined that achieving the 1990 emissions level by 2020 would 50 Health & Safety Code Section 38561(h) requires CARB to update the Scoping Plan every five years. 51 CARB, First Update to the Climate Change Scoping Plan: Building on the Framework (May 2014), p. 4. 52 Id. at p. 34.
53 Id. at p. 6.
54 Id. at p. 32.

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require a reduction in GHG emissions of approximately 15.3 percent (instead of 28.5 percent or 16 percent) from the business-as-usual (BAU) conditions.

The 2014 First Update included a strong recommendation from CARB for setting a mid-term statewide GHG emissions reduction target. CARB specifically recommended that the midterm target be consistent with: (i) the United States’ pledge to reduce emissions 42 percent below 2005 levels (which translates to a 35 percent reduction from 1990 levels in California); and (ii) the long-term policy goal of reducing emissions to 80 percent below 1990 levels by 2050.

The 2014 First Update discussed new residential and commercial building energy efficiency improvements, specifically identifying progress towards zero net energy buildings as an element of meeting mid-term and long-term GHG reduction goals. The 2014 First Update expressed CARB’s commitment to working with the California Public Utilities Commission (CPUC) and CEC to facilitate further achievements in building energy efficiency. b) 2017 Scoping Plan
In November 2017, CARB published California’s 2017 Climate Change Scoping Plan (2017 Scoping Plan), which was subsequently adopted by CARB’s Board in December 2017.55 The 2017 Scoping Plan identifies CARB’s strategy for achieving the State’s 2030 GHG target as established in Senate Bill (SB) 32 (discussed below).The strategy includes continuation of the Cap-and-Trade Program through 2030, and incorporates a Mobile Source Strategy that includes strategies targeted to increase zero emission vehicle fleet penetration and a more stringent target for the Low Carbon Fuel Standard by 2030. The 2017 Scoping Plan also incorporates approaches to cutting short-lived climate pollutants (SLCPs) under the Short-Lived Climate Pollutant Reduction Strategy (a planning document that was adopted by CARB in March 2017), and acknowledges the need for reducing emissions in agriculture and highlights the work underway to ensure that California’s natural and working lands increasingly sequester carbon.

When discussing project-level GHG emissions reduction actions and thresholds, the 2017 Scoping Plan states:
“Project-Level Greenhouse Gas Emissions Reduction Actions and Thresholds Beyond plan-level goals and actions, local governments can also support climate action when considering discretionary approvals and entitlements of individual projects through CEQA [California Environmental Quality Act]. Absent conformity with an adequate geographically-specific GHG reduction plan …, CARB recommends that projects incorporate design features and GHG reduction measures, to the degree feasible, to minimize GHG emissions. Achieving no net additional increase in GHG emissions, resulting in no contribution to GHG impacts, is an appropriate overall objective for new development.

Achieving net zero increases in GHG emissions, resulting in no contribution to GHG impacts, may not be feasible or appropriate for every project, however, and the inability of a project to mitigate its GHG emissions to net zero does not imply the project results in a substantial contribution to the cumulatively significant environmental impact of climate change under CEQA.
55 CARB. 2017. California’s 2017 Climate Change Scoping Plan. November. Available at:
https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf. Accessed: January 2022.

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California’s future climate strategy will require increased focus on integrated land use planning to support liveable, transit-connected communities, and conservation and other lands. Accommodating population and economic growth through travel- and energy-efficient land use provides GHG-efficient growth, reducing GHGs from both transportation and building energy use. GHGs can be further reduced at the project level through implementing energy-efficient construction and travel demand management approaches.” c) 2022 Scoping Plan Update
The 2022 Scoping Plan Update assesses progress towards achieving the Senate Bill 32 2030 target and lays out a path to achieve carbon neutrality no later than 2045. This plan update was approved by the Board in December 2022.56 The 2022 Scoping Plan Update outlines a sector-by-sector roadmap for California to achieve carbon neutrality by 2045 or earlier. It aims to reduce anthropogenic emissions to 85% below 1990 levels by 2045 using technically feasible and cost-effective solutions. The 2022 Scoping Plan Update focuses on electrification of transportation, homes and buildings, and phasing out fossil fuels. In hard-to-electrify sectors, new solutions such as renewable hydrogen and biomethane are leveraged to achieve emissions reductions.

CARB’s 2022 Scoping Plan Update outlines a number of actions for the Scoping Plan Scenario in Table 2-1. The list below represents the actions which are most relevant to the Project:
• GHG Emissions Reductions Relative to the SB 32 Target - 40% below 1990 levels by 2030.
• Smart Growth / Vehicle Miles Traveled (VMT) - VMT per capita reduced 25% below 2019 levels by 2030, and 30% below 2019 levels by 2045.
• Light-duty Vehicle (LDV) Zero Emission Vehicles (ZEVs) - 100% of LDV sales are ZEV by 2035.
• Truck ZEVs - 100% of medium-duty (MDV)/HDV sales are ZEV by 2040 (AB 74 University of California Institute of Transportation Studies [ITS] report). • Freight and Passenger Rail - 100% of passenger and other locomotive sales are ZEV by 2030; 100% of line haul locomotive sales are ZEV by 2035; Line haul and passenger rail rely primarily on hydrogen fuel cell technology, and others primarily utilize electricity. • New Residential and Commercial Buildings - All electric appliances beginning 2026 (residential) and 2029 (commercial), contributing to 6 million heat pumps installed statewide by 2030.
• Construction Equipment - 25% of energy demand electrified by 2030 and 75% electrified by 2045.
• Low Carbon Fuels for Transportation - Biomass supply is used to produce conventional and advanced biofuels, as well as hydrogen.
• Low Carbon Fuels for Buildings and Industry - In 2030s biomethane blended in pipeline; Renewable hydrogen blended in fossil gas pipeline at 7% energy (~20% by volume), ramping up between 2030 and 2040.
56 CARB. 2022. Final 2022 Scoping Plan Update and Appendices. December. Available at:
https://ww2.arb.ca.gov/our-work/programs/ab-32-climate-change-scoping-plan/2022-scoping-plan-documents.

Accessed: February 2023.

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• Non-combustion Methane Emissions - Moderate adoption of enteric strategies by 2030; Divert 75% of organic waste from landfills by 2025.

In addition to the previous focus areas, the 2022 Scoping Plan Update developed a table of priority GHG reduction strategies that can be utilized by local governments. This is Table 1 in Appendix D of the 2022 Scoping Plan Update.57 When discussing this table, the 2022 Scoping Plan Update notes:
“To assist local jurisdictions with developing local climate plans, measures, policies, and actions aligned with the State’s climate goals, Table 1 presents a non-exhaustive list of impactful GHG reduction strategies that can be implemented by local governments. The strategies in Table 1 are not applicable to all local jurisdictions, nor are they the only strategies that local governments can adopt, but they represent the core strategies that most jurisdictions in California can implement to reduce GHG emissions regardless of whether they have developed a CEQA-qualified CAP. Reaching the outcomes of these priority GHG reduction strategies requires a locally appropriate, comprehensive adoption of policies in support of these objectives. When developing local climate plans, measures, policies, and actions, local jurisdictions should incorporate the recommendations described in Table 1 to the extent appropriate to ensure alignment with State climate goals.”

2.2.2.3 SB 605 - Short-lived Climate Pollutants (SLCP)
Short-lived climate pollutants (i.e., black carbon, fluorinated gases, and methane) are powerful climate forcers that remain in the atmosphere for a much shorter period of time than longer-lived climate pollutants. Their relative potency, when measured in terms of how they heat the atmosphere, can be tens, hundreds, or even thousands of times greater than that of CO2. The impacts of short-lived climate pollutants are especially strong over the short term. Reducing these emissions can make an immediate beneficial impact on climate change.58 Governor Brown signed SB 605 on September 21, 2014, directing CARB to develop a Short-Lived Climate Pollutant Strategy by January 1, 2016. On May 7, 2015, CARB released a concept paper for reducing emissions of these substances. In September 2015, CARB released a draft of their Short-Lived Climate Pollutant Strategy. Several updates to the draft have been made since September 2015, with the most current version dated March 2017. The Strategy aims for a 40 percent reduction in methane and HFC emissions below 2013 levels by 2030 and a 50 percent reduction in anthropogenic emissions of black carbon below 2013 levels by 2030.59

2.2.2.4 Executive Order B-30-15
In April 2015, Governor Brown signed EO B-30-15, which established the following GHG emission reduction goal for California: by 2030, reduce GHG emissions to 40 percent below 1990 levels. This EO also directed all state agencies with jurisdiction over GHG-emitting sources to implement measures designed to achieve the new interim 2030 goal, as well as the pre-existing, long-term 2050 goal identified in EO S-3-05 (see discussion above). 57 CARB. 2022. Final 2022 Scoping Plan Update and Appendices. December. Available at:
https://ww2.arb.ca.gov/our-work/programs/ab-32-climate-change-scoping-plan/2022-scoping-plan-documents.

Accessed: February 2023.
58 CARB. 2016. Reducing Short-Lived Climate Pollutants in California. Available at:
https://www.arb.ca.gov/cc/shortlived/shortlived.htm. Accessed: January 2022. 59 CARB. 2017. Short-Lived Climate Pollutant Reduction Strategy. Available at:
https://ww2.arb.ca.gov/sites/default/files/2020-07/final_SLCP_strategy.pdf. Accessed: January 2022.

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Additionally, the EO directed CARB to update its Scoping Plan (see discussion above) to address the 2030 goal.

2.2.2.5 Senate Bill 32 and Assembly Bill 197
Enacted in 2016, SB 32 (Pavley, 2016) codifies the 2030 emissions reduction goal of EO B-30-15 by requiring CARB to ensure that statewide GHG emissions are reduced to 40 percent below 1990 levels by 2030.

SB 32 was coupled with a companion bill: AB 197 (Garcia, 2016). Designed to improve the transparency of CARB’s regulatory and policy-oriented processes, AB 197 created the Joint Legislative Committee on Climate Change Policies, a committee with the responsibility to ascertain facts and make recommendations to the Legislature concerning statewide programs, policies, and investments related to climate change. AB 197 also requires CARB to make certain GHG emissions inventory data publicly available on its web site; consider the social costs of GHG emissions when adopting rules and regulations designed to achieve GHG emission reductions; and include specified information in all Scoping Plan updates for the emission reduction measures contained therein.

2.2.2.6 Executive Order B-55-18
In September 2018, Governor Brown signed EO B-55-18, which established a new statewide goal “to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net negative emissions thereafter.” This EO directs CARB to “work with relevant state agencies to ensure future Scoping Plans identify and recommend measures to achieve the carbon neutrality goal.”
In January 2019, CARB kicked off workshops regarding carbon neutrality in California,60 during which CARB staff explained that the definitional parameters and meaning of the term – carbon neutrality – are still being explored. CARB held additional workshops throughout 2019 and 2020 to explore specific topics related to the pursuit of carbon neutrality, engage with other experts in the field and stakeholders, and conduct research to ensure that any path to carbon neutrality balances scientific, economic and social justice principles.

2.2.2.7 Energy Sources
a) Renewables Portfolio Standard
As most recently amended by SB 100 (2018), California’s Renewables Portfolio Standard requires retail sellers of electric services and local publicly-owned electric utilities to increase procurement from eligible renewable energy resources to 50 percent of total retail sales by 2026, and 60 percent of total retail sales by 2030. SB 100 also established a State policy goal to achieve 100 percent renewables by 2045.

In March 2021, CEC, CPUC, and CARB released a joint-agency report evaluating the current feasibility of achieving the energy resource and GHG reductions goals of SB 100. The report finds that SB 100 is technically feasible when analyzed under scenarios of varying timelines, advancements in energy generation technology, and energy source portfolios. Under the 60 CARB. Carbon Neutrality in California Context Webinar. January 2019. Available at:
https://www.arb.ca.gov/cc/scopingplan/meetings/012319/cneutrality_ca_script.pdf. Accessed: January 2022.

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SB 100 Core Scenario, it is anticipated that California will need to triple its current electricity power capacity.61
b) Building Energy Efficiency Standards
Title 24, Part 6 of the California Code of Regulations regulates the design of building shells and building components. The standards are updated periodically to allow for consideration and possible incorporation of new energy efficiency technologies and methods.

The CEC’s 2019 Building Energy Efficiency Standards (2019 Building Standards), which became effective January 1, 2020, are the currently applicable version of these standards. In general, single-family homes built to the 2019 standards are anticipated to use about 7% less energy due to energy efficiency measures than those built to the 2016 standards, and nonresidential buildings built to the 2019 standards will use an estimated 30% less energy than those built to the 2016 standards.62
In addition to the CEC’s efforts, in 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (Part 11 of Title 24) is commonly referred to as CalGreen Building Standard (CalGreen), and establishes voluntary and mandatory standards pertaining to the planning and design of sustainable site development, energy efficiency, water conservation, material conservation, and interior air quality. Like Part 6 of Title 24, the CalGreen standards are periodically updated, with increasing energy savings and efficiencies associated with each code update.

At the time of this writing, the CEC has adopted the 2022 Energy Code, which improves upon the 2019 standards for construction of residential and non-residential buildings. The standards will be effective on January 1, 2023.63
c) Appliance Standards
The CEC periodically amends and enforces Appliance Efficiency Regulations contained in Title 20 of the California Code of Regulations. The regulations establish water and energy efficiency standards for both federally-regulated appliances and non-federally regulated appliances. The regulations cover numerous categories of appliances (e.g., refrigerators; plumbing fixtures; dishwashers; clothes washer and dryers; televisions) and apply to appliances offered for sale in California.64

2.2.2.8 Mobile Sources
a) Sustainable Communities Strategy Plans
SB 375 (Steinberg, 2008), the Sustainable Communities and Climate Protection Act, coordinates land use planning, regional transportation plans, and funding priorities to reduce 61 CEC. 2021. 2021 SB 100 Joint Agency Report, Achieving 100 Percent Clean Electricity in California: An Initial Assessment. Available at: https://www.energy.ca.gov/publications/2021/2021-sb-100-joint-agency-reportachieving-100-percent-clean-electricity. Accessed: January 2022. 62 CEC. 2018. 2019 Building Energy Efficiency Standards – Frequently Asked Questions. Available at:
https://www.energy.ca.gov/sites/default/files/2020-03/Title_24_2019_Building_Standards_FAQ_ada.pdf.

Accessed: January 2022.
63 CEC. 2022 Building Energy Efficiency Standards. Available at: https://www.energy.ca.gov/programs-andtopics/programs/building-energy-efficiency-standards/2022-building-energy-efficiency. Accessed: January 2022.
64 CEC. Title 20 Appliance Efficiency Program. Available at: https://www.energy.ca.gov/rules-andregulations/appliance-efficiency-regulations-title-20. Accessed: January 2022.

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GHG emissions from passenger vehicles through better-integrated regional transportation, land use, and housing planning that provides easier access to jobs, services, public transit, and active transportation options. SB 375 specifically requires the Metropolitan Planning Organization relevant to the Project area (here, the Fresno Council of Governments [Fresno COG]) to include a Sustainable Communities Strategy in its Regional Transportation Plan (RTP) that, if implemented, will achieve GHG emission reduction targets set by CARB by reducing vehicle miles traveled from light-duty vehicles through the development of more compact, complete, and efficient communities.

For the area under Fresno COG’s jurisdiction, including the Project site, CARB originally adopted regional targets for reduction of mobile source-related GHG emissions of 5 percent for 2020 and 10 percent for 2035. The targets are expressed as a percentage change in per capita passenger vehicle GHG emissions relative to 2005 emissions levels. These original targets were in place through September 30, 2018. In March 2018, CARB approved updated regional targets of 6% for 2020 and 13% for 2035 for Fresno COG, which apply to future RTP/SCS planning cycles beginning October 1, 2018.65
b) Senate Bill 743
Public Resources Code Section 21099(c)(1), as codified through enactment of SB 743 (Steinberg, 2013), authorized the Governor’s Office of Planning and Research (OPR) to establish “alternative metrics to the metrics used for traffic levels of service for transportation impacts outside transit priority areas.” SB 743 reflects a legislative policy to balance the needs of congestion management with statewide goals related to infill development, promotion of public health through active transportation, and reduction of GHG emissions. As finalized in December 2018, amendments to the State CEQA Guidelines adopted in furtherance of SB 743 establish vehicle miles traveled (VMT), in lieu of level of service, as the new metric for transportation analysis. c) Pavley Regulations
AB 1493 (Pavley, 2002) required CARB to adopt regulations to reduce GHG emissions from non-commercial passenger vehicles and light-duty trucks for model years 2009–2016. CARB obtained a waiver from the USEPA that allows for implementation of these regulations notwithstanding possible federal pre-emption concerns.
d) Low Carbon Fuel Standard
EO S-1-07, as issued by Governor Schwarzenegger, called for a 10 percent or greater reduction in the average fuel carbon intensity for transportation fuels in California regulated by CARB by 2020.66 In response, CARB approved the Low Carbon Fuel Standard (LCFS) regulations in 2009, which became fully effective in April 2010. Thereafter, a lawsuit was filed challenging CARB’s adoption of the regulations; and in 2013, a court order was issued compelling CARB to remedy substantive and procedural defects of the LCFS adoption process under CEQA.67 However, the court allowed implementation of the LCFS to continue pending correction of the identified defects. In September 2015, CARB re-adopted the LCFS regulations. The LCFS would reduce GHG emissions by reducing the carbon intensity of 65 CARB. Regional Plan Targets. Available at: https://ww2.arb.ca.gov/our-work/programs/sustainablecommunities-program/regional-plan-targets. Accessed: January 2022. 66 Carbon intensity is a measure of the GHG emissions associated with the various production, distribution, and use steps in the “lifecycle” of a transportation fuel.
67 POET, LLC v. CARB (2013) 217 Cal.App.4th 1214.

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transportation fuels used in California by at least 10% by 2020 and, as most recently amended in 2018, by at least 20% by 2030.
e) Advanced Clean Cars Program
In 2012, CARB approved the Advanced Clean Cars (ACC) program, a new emissions-control program for non-commercial passenger vehicles and light-duty truck for model years 2017- 2025. The program combines the control of smog, soot, and GHGs with requirements for greater numbers of zero emission vehicles. By 2025, when the rules will be fully implemented, new automobiles will emit 34 percent fewer global warming gases and 75 percent fewer smog-forming emissions. In August 2022, CARB adopted Advanced Clean Cars II (ACC II) regulations which “will seek to reduce criteria and greenhouse gas emissions from new light- and medium-duty vehicles beyond the 2025 model year, and increase the number of zero emission vehicles (ZEVs) for sale”.68
f) Zero Emission Vehicles
ZEVs include hydrogen fuel cell electric vehicles and plug-in electric vehicles, such as battery electric vehicles and plug-in hybrid electric vehicles.

In furtherance of that statewide target for the transportation sector, the EO also calls upon CARB, the CEC, and the California Public Utilities Commission to establish benchmarks that will: (1) allow over 1.5 million ZEVs to be on California roadways by 2025, and (2) provide the State’s residents with easy access to ZEV infrastructure. EO B-16-2012 specifically directed California to “encourage the development and success of zero-emission vehicles to protect the environment, stimulate economic growth, and improve the quality of life in the State.”69
In 2018, Governor Brown also issued EO B-48-18, which launched an eight-year initiative to accelerate the sales of ZEVs through a mix of rebate programs and infrastructure improvements. The EO also sets a new target of five million ZEVs in California by 2030, and includes funding for multiple state agencies to increase electric vehicle (EV) charging infrastructure and provide purchase rebates/incentives.

In furtherance of the State’s ZEV penetration goals, in February 2013, the Governor’s Interagency Working Group on Zero-emission Vehicles issued the 2013 ZEV Action Plan:

A roadmap toward 1.5 million zero-emission vehicles on California roadways by 2025.70 The 2013 ZEV Action Plan identifies four broad goals for State government to advance ZEVs:
1) Complete needed infrastructure and planning; 2) Expand consumer awareness and demand; 3) Transform fleets; and 4) Grow jobs and investment in the private sector. As part of these goals, some highlighted strategies and actions include: i) supporting ZEV infrastructure planning and investment by private entities; ii) enabling universal access to ZEV infrastructure for California drivers; iii) reducing upfront purchase costs for ZEVs; 68 Advanced Clean Cars II Program. Available at: https://ww2.arb.ca.gov/advanced-clean-cars-ii-meetingsworkshops. Accessed: January 2022. 69 Executive Order B-16-2012. Available at: https://www.ca.gov/archive/gov39/2012/03/23/news17472/.

Accessed: January 2022.
70 Governor’s Interagency Working Group on Zero-emission Vehicles. 2013. Available at:
http://opr.ca.gov/docs/Governors_Office_ZEV_Action_Plan_(02-13).pdf. Accessed: January 2022.

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iv) promoting consumer awareness of ZEVs; and v) helping to expand ZEVs in bus fleets.

In October 2016, the Governor's Interagency Working Group on Zero-emission Vehicles issued the 2016 ZEV Action Plan: A roadmap toward 1.5 million zero-emission vehicles on California roadways by 2025.71 This report provides an update on progress toward achieving the 2013 goals and highlights the following four top priorities for the upcoming years:
1) Raise consumer awareness and education about ZEVs; 2) Ensure ZEVs are accessible to a broad range of Californians; 3) Make ZEV technologies commercially viable in targeted applications in the medium-duty, heavy-duty, and freight sectors; and 4) Aid ZEV market growth beyond California. The broad goals to advance ZEV adoption are: i) achieve mainstream consumer awareness of ZEV options and benefits; ii) make ZEVs an affordable and attractive option for drivers; iii) ensure convenient charging and fueling infrastructure for greatly expanded use of ZEVs; iv) maximize economic and job opportunities from ZEV technologies; v) bolster ZEV market growth outside of California; and vi) lead by example by integrating ZEVs into State government. The goals and strategies proposed in the 2013 Action Plan will continue to be implemented; however, additional strategies are proposed to help achieve the new goals, including setting targets to increase home charging stations in multiunit dwellings and disadvantaged communities and for public transit and school bus electrification. The 2016 Action Plan describes challenges toward achieving the 2025 goal of

In September 2018, the Governor’s Interagency Working Group on Zero-Emission Vehicles published the 2018 ZEV Action Plan Priorities Update.72 This update is the result of Governor Brown’s directive to update the 2016 Zero-Emission Vehicle Action Plan to help expand private investment in zero-emission vehicle infrastructure, particularly in low income and disadvantaged communities. The 2018 Priorities Update serves three fundamental purposes:
1) Provide direction to state agencies on the most important actions to be executed in 2018 to enable progress toward the 2025 targets and 2030 Vision; 2) Give stakeholders transparency into the actions state agencies plan to take (or are taking) this year to further the ZEV market; and 3) Create a platform for stakeholder engagement, feedback, and collaboration. As of July 2018, over 410,000 ZEVs have been sold in California, which is approximately 150,000 ZEVs since the publication of the 2016 Action Plan in October 2016.

In June 2020, CARB approved the Advanced Clean Trucks regulation, which has requirements for manufacturer ZEV sales and a one-time reporting requirement for large 71 Governor’s Interagency Working Group on Zero-emission Vehicles. 2016. Available at:
https://www.ca.gov/archive/gov39/wp-content/uploads/2018/01/2016_ZEV_Action_Plan-1.pdf. Accessed:

January 2022.
72 Governor’s Interagency Working Group on Zero-emission Vehicles. 2018. Available at:
https://static.business.ca.gov/wp-content/uploads/2019/12/2018-ZEV-Action-Plan-Priorities-Update.pdf.

Accessed: January 2022.

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entities and fleets.73 The Advanced Clean Truck Regulation is part of a holistic approach to accelerate a large-scale transition of zero-emission medium-and heavy-duty vehicles from Class 2b to Class 8. Manufacturers who certify Class 2b-8 chassis or complete vehicles with combustion engines are required to sell zero-emission trucks as an increasing percentage of their annual California sales from 2024 to 2035. By 2035, zero-emission truck/chassis sales need to be 55% of Class 2b – 3 truck sales, 75% of Class 4 – 8 straight truck sales, and 40% of truck tractor sales. Large employers including retailers, manufacturers, brokers, and others are required to report information about shipments and shuttle services. Fleet owners, with 50 or more trucks, are required to report about their existing fleet operations.

This information helps to identify future strategies to ensure that fleets purchase available zero-emission trucks and place them in service where suitable to meet their needs.

California is incentivizing the purchase of ZEVs through implementation of the Clean Vehicle Rebate Project, which is administered by a non-profit organization (The Center for Sustainable Energy) for CARB and currently subsidizes the purchase of passenger near-zero and zero emission vehicles as follows:
x Hydrogen Fuel Cell Electric Vehicles: $5,000;
x Battery Electric Vehicles: $2,500;
x Plug-In Hybrid Electric Vehicles: $1,500; and
x Neighborhood Electric Vehicles and Zero Emission Motorcycles: $900.

In March 2017, CARB received Volkswagen’s (VW) first 30-month ZEV Investment Plan (Plan).74 This Plan is required by California’s partial settlement with VW resulting from VW’s use of illegal devices in its 2.0-liter (2.0L) diesel cars sold in the State from model years 2009 to 2015. The Plan describes how VW is proposing to spend the first $200 million in California on ZEV charging infrastructure (including the development and maintenance of ZEV charging stations), public awareness, increasing ZEV access, and a green city demonstration. In June 2017, Electrify America (a subsidiary of VW) provided CARB with additional information on the Plan.75 CARB approved the first of the four plans in July 2017.76 In its 2014 First Update, CARB recognized that the light-duty vehicle fleet “will need to become largely electrified by 2050 in order to meet California’s emission reduction goals.”77 Accordingly, CARB’s ACC program – summarized above – requires about 15 percent of new cars sold in California in 2025 to be a plug-in hybrid, battery electric or fuel cell vehicle.78 73 CARB. 2020. Advanced Clean Trucks. Available at: https://ww2.arb.ca.gov/our-work/programs/advanced-cleantrucks. Accessed: January 2022. 74 VOLKSWAGEN, Group of America. 2017. California ZEV Investment Plan: Cycle 1, March 8, 2017. Available at:
https://www.electrifyamerica.com/assets/pdf/California%20ZEV%20Investment%20Plan%20Cycle%201.3bc67 2a3.pdf. Accessed: January 2022.
75 Electrify America. 2017. Supplement to the California ZEV Investment Plan, Cycle 1, June 29, 2017. Available at:
https://www.electrifyamerica.com/assets/pdf/Cycle%201%20CA%20ZEV%20Invest%20Plan%20Supplement.a 92e7705.pdf. Accessed: January 2022.
76 CARB, 2017. CARB Approves $200 Million VW Zero-Emission Vehicle Investment in California, July, 27. Available at: https://ww2.arb.ca.gov/news/carb-approves-200-million-vw-zero-emission-vehicle-investment-california.

Accessed: January 2022.
77 CARB, First Update to the Climate Change Scoping Plan: Building on the Framework (May 2014), p. 48. 78 Id. at p. 47.

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Other statewide and regional initiatives that spur ZEV uptake include the following:
x CARB currently subsidizes the purchase of passenger near-zero and zero emission vehicles, and provides access to high-occupancy vehicle lanes to ZEV drivers. x The VW settlement will result in $800 million in ZEV projects in California over the next ten years, with a focus on increasing public awareness and infrastructure in the first funding cycle.79
x The CalGreen standards require new residential and non-residential construction to be pre-wired to facilitate the future installation and use of electric vehicle chargers (see Section 4.106.4 and Section 5.106.5.3 of 2016 CalGreen standards for the residential and nonresidential pre-wiring requirements, respectively).

In January 2017, three of California’s largest utilities submitted proposals to the CPUC to electrify the State’s transportation sector through more than $1 billion in investments:
x Southern California Edison (SCE) filed an application to expand electric transportation in its service area. Some of SCE’s proposals include monetary rewards to rideshare drivers who use an electric vehicle, additional fast charge infrastructure at targeted locations within the region, and rates that are designed to incentivize electric vehicle adoption.80 x Pacific Gas and Electric (PG&E) submitted an application that aims to expand the electrification of medium- and heavy-duty vehicle fleets, expand fast-charging stations that can refuel EVs in 20-30 minutes, and explore new uses for vehicle electrification.81 x San Diego Gas & Electric (SDG&E) submitted an application to install tens of thousands of charging stations in its service area to boost the transition to zero-emission vehicles, trucks, shuttles and delivery fleets.82
On September 23, 2020, California Governor Gavin Newsom issued Executive Order N-79-20, which entails the following actions:
x All new passenger vehicles sold in California be zero-emission by 2035 x All medium- and heavy-duty vehicles be zero-emission where feasible by 2045 x All off-road vehicles and equipment be zero-emission where feasible by 2035 Governor Newsom ordered extensive inter-agency efforts to support the Executive Order, including evaluations of technological feasibility and cost effectiveness, expansion of EV charging options and affordable fueling, as well as identification of near-term strategies to increase zero-emission public transportation options.

The Executive Order was generally aimed at transitioning away from fossil fuel dependence in the State, with emphasis on transportation initiatives. However, Governor Newsom 79 CARB, Volkswagen Settlement – California ZEV Investments webpage, available at:
https://www.arb.ca.gov/msprog/vw_info/vsi/vw-zevinvest/vw-zevinvest.htm. Accessed: January 2022. 80 SCE, Application of Southern California Edison Company (U 338-E) for Approval of Its 2017 Transportation Electrification Proposals (January 20, 2017).
81 PG&E, In the Matter of the Application of Pacific Gas and Electric Company for Approval of its Senate Bill 350 Transportation Electrification Program (January 20, 2017). 82 SDG&E, Application of San Diego Gas & Electric Company (U902E) for Approval of SB 350 Transportation Electrification Proposals (January 20, 2017).

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addressed efforts to repurpose oil production facilities and extraction sites while continuing the State’s existing goals to reduce the carbon intensity of fuels.83

2.2.2.9 Water
In January 2014, Governor Brown signed EO B-29-15, which directed the State Water Resources Control Board to impose restrictions to reduce residential potable urban water usage; to implement water efficiency measures at commercial, industrial, and institutional properties; and to prohibit irrigation with potable water for certain uses. In addition, this directed the California Department of Water Resources to lead a statewide initiative to replace laws and ornamental turfs with drought tolerant landscapes.

Pursuant to the EO B-29-15, water-related standards were adopted as amendments to the 2013 CalGreen Code and carried over into the 2016 code.

Following EO-B-29-2015, Governor Brown signed EO-B-37-16 in May 2016 to promote more conscious consumer water use and to improve agricultural water use efficiency and drought planning.

2.2.2.10 Solid Waste Diversion
The California Integrated Waste Management Act of 1989, as modified by AB 341 (Chesbro, 2011), requires each jurisdiction’s source reduction and recycling element to include an implementation schedule that shows: (1) diversion of 25 percent of all solid waste by January 1, 1995, through source reduction, recycling, and composting activities; (2) diversion of 50 percent of all solid waste on and after January 1, 2000; and (3) source reduction, recycling and composting of 75 percent of all solid waste on or after 2020, and annually thereafter. CalRecycle is required to develop strategies, including source reduction, recycling, and composting activities, to achieve the 2020 goal.

CalRecycle published a discussion document, entitled California’s New Goal:
75 Percent Recycling, which identified concepts that would assist the State in reaching the 75 percent goal by 2020. Subsequently, in August 2015, CalRecycle released the AB 341 Report to the Legislature, which identifies five priority strategies for achievement of the 75 percent goal: (1) moving organics out of landfills; (2) expanding recycling/ manufacturing infrastructure; (3) exploring new approaches for State and local funding of sustainable waste management programs; (4) promoting State procurement of post-consumer recycled content products; and (5) promoting extended producer responsibility.

2.2.2.11 Draft Climate Adaptation Strategy
The Draft California Climate Adaptation Strategy, dated October 18, 2021, outlines the state's key climate resilience priorities, includes specific and measurable steps, and serves as a framework for action across sectors and regions in California.84 The priorities outlined in the Strategy are as follows: 1) Strengthen Protections for Climate Vulnerable Communities, 2) Bolster Public Health and Safety in Light of Increasing Climate Risks, 3) Build a Climate Resilient Economy, 4) Accelerate Nature-Based Climate Solutions 83 State of California. 2020. Executive Order N-79-20. Available at: https://www.gov.ca.gov/wpcontent/uploads/2020/09/9.23.20-EO-N-79-20-Climate.pdf. Accessed: January 2022. 84 California Natural Resources Agency. 2021. Draft California Climate Adaptation Strategy. Available at:
https://resources.ca.gov/-/media/CNRA-Website/Files/Initiatives/Climate-Resilience/SAS-Workshops/Draft-CAClimate-Adaptation-Strategy-ada.pdf. Accessed: January 2022.

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and Strengthen Climate Resilience of Natural Systems, 5) Make Decisions based on the Best Available Climate Science, and 6) Partner and Collaborate to Leverage Resources.

2.2.3 Regional

2.2.3.1 Fresno COG Regional Transportation Plan and Sustainable Communities Strategy
As previously discussed, SB 375 requires Fresno COG to incorporate a Sustainable Communities Strategy into its RTP that achieves the GHG emission reduction targets set by CARB. Fresno COG’s Sustainable Communities Strategy was first included in the 2014 Regional Transportation Plan & Sustainable Communities Strategy (RTP/SCS), which was adopted by Fresno COG in June 2014. The original plan has since been superseded by the RTP/SCS adopted by Fresno COG in July 2018, and more recently in July 2022.

In general, the goals and policies of the Sustainable Communities Strategy are to improve mobility, accessibility, reliability, efficiency, liveability, sustainability, and equity. The Sustainable Communities Strategy adopted by Fresno COG is expected to reduce per capita transportation emissions by 6% by 2020 and by 13% by 2035, as compared to 2005 baseline levels.

In July 2018, CARB accepted Fresno COG’s determination that the 2018 Sustainable Communities Strategy would meet the region’s GHG reduction targets per Government Code Section 65080(b)(2)(J)(ii), as memorialized in CARB’s Resolution 2018-26.85 As of February 2023, CARB has not yet performed this review of the 2022 Fresno COG RTP/SCS.

Pursuant to Government Code Section 65080(b)(2)(K), a Sustainable Communities Strategy does not: (i) regulate the use of land; (ii) supersede the land use authority of cities and counties; or (iii) require that a city’s or county’s land use policies and regulations, including those in a general plan, be consistent with it.

2.2.3.2 San Joaquin Valley Air Pollution Control District While CARB is responsible for the regulation of mobile emission sources within the State, local air quality management districts (AQMDs) and air pollution control districts (APCDs) are responsible for enforcing standards and regulating stationary sources. The Project area is located within the San Joaquin Valley Air Basin and is subject to the San Joaquin Valley Air Pollution Control District (SJVAPCD) guidelines and regulations. 85 CARB. Executive Order G-19-092. Fresno Council of Governments (FCOG) 2018 Sustainable Communities Strategy CARB Acceptance of GHG Quantification Determination. Available at:
https://ww2.arb.ca.gov/sites/default/files/2020-
06/FCOG_2018_SCS_ARB_Acceptance_of_GHG_Quantification_Determination_Executive_Order.pdf. Accessed:

January 2022.

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In December 2009, SJVACPD issued its Guidance for Valley Land-use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA (Guidance). In its Guidance, the District recommends determining the significance of project-specific GHG emissions by using Best Performance Standards (BPS). Under the Guidance, a project’s impacts on global climate change would be less than significant if the project implements BPS, or if the project reduces or mitigates its GHG emissions by 29 percent, consistent with the statewide GHG emission reduction targets established in the 2008 Scoping Plan. The District also adopted the District Policy: Addressing GHG Emission Impacts for Stationary Source Projects Under CEQA When Serving as the Lead Agency. This policy aligns with the Guidance process for evaluating GHG significance, specific to stationary source projects.

Also, in June 2014, the District released APR – 2025, CEQA Determinations of Significance for Projects Subject to [CARB]’s GHG Cap-and-Trade Regulation (APR – 2025). In APR - 2025, the District concluded that GHG emissions increases that are otherwise covered under CARB’s Cap-and-Trade Program cannot constitute significant increases in emissions under CEQA for two separate reasons: (1) the Cap-and-Trade Program is an adopted statewide regulation for reducing GHG emissions from targeted industries/sources; and (2) GHG emissions addressed by the Cap-and-Trade Program are subject to an industry-wide, decreasing emissions cap. More specifically, the District concluded that “all GHG emission increases resulting from the combustion of any fuel produced, imported, and/or delivered in California are mitigated under Cap-and-Trade. Therefore, GHG emission increases caused by fuel use (other than jet fuels) are determined to have a less than significant impact on global climate change under CEQA.” In March 2015, the District issued its Guidance for Assessing and Mitigating Air Quality Impacts (GAMAQI), which provides technical guidance for the review of air quality impacts from proposed projects within the boundaries of the District.86 This guidance recommends an approach for evaluating the significance of a proposed project’s GHG emissions; specifically, whether a proposed project would have reduced or mitigated GHG emissions by 29%, consistent with GHG emission reduction targets established in the CARB’s Scoping Plan. The guidance recommends the following hierarchy for evaluating a proposed project’s impact with respect to its GHG emissions:
x Projects complying with an approved GHG emission reduction plan or GHG mitigation program which avoids or substantially reduces GHG emissions within the geographic area in which the project is located would be determined to have a less-than-significant individual and cumulative impact for GHG emissions. Such plans or programs must be specified in law or approved by the lead agency with jurisdiction over the affected resource and supported by a CEQA-compliant environmental review document adopted by the lead agency. Projects complying with an approved GHG emission reduction plan or GHG mitigation program would not be required to implement Best Performance Standards.
x Projects implementing Best Performance Standards would not require quantification of project-specific GHG emissions. Consistent with the CEQA Guidelines, such projects 86 San Joaquin Valley Unified Air Pollution Control District. 2015. Guidance for Assessing and Mitigating Air Quality Impacts (GAMAQI). Available at: http://www.valleyair.org/transportation/GAMAQI.pdf. Accessed: January 2022.

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would be determined to have a less-than-significant individual and cumulative impact for GHG emissions.

While the GAMAQI discussions include a comparison to a BAU approach, the Center for Biological Diversity v. California Department of Fish and Wildlife Court Decision established additional standards for such an approach. Due to that court decision, the comparison to BAU approach will not be relied upon in this analysis.

2.2.4 Local

2.2.4.1 City of Fresno General Plan
The current City of Fresno General Plan, adopted originally in 2014, has a Resource Conservation and Resilience section which addresses both air quality and GHG emissions.87 The City’s General Plan notes that SJVAPCD authority to regulate air emissions is restricted to stationary sources, while mobile sources emissions reductions are only incentivized by SJVAPCD. The City acknowledges its role in improving air quality can come from efforts to reduce mobile vehicle emissions, which is summarized in Policy RC-4-a. The same policy to control mobile vehicle emissions additionally addresses GHG reduction efforts. An additional policy that is compatible with mobile vehicle emissions reductions is Policy RC-2-a, which aims to promote higher density land use developments, thereby decreasing vehicle travel and emissions. Other policies aimed at reducing GHG emissions include Policy RC-5-a and Policy RC-5-b, which set GHG reduction targets in line with AB 32 and adopt a GHG Reduction Plan for the City, respectively. The latter is outlined below.

2.2.4.2 City of Fresno GHG Reduction Plan
In December 2014, the City of Fresno adopted a GHG Reduction Plan, also referred to as the Climate Action Plan, as its primary strategy for reducing GHG emissions under the control or influence of the City.88 The GHG Reduction Plan was later updated in March 2020 to re-evaluate the City’s GHG reduction targets and existing reduction strategies from the 2014 GHG Reduction Plan.89 The latest version of the GHG Reduction Plan Update was finalized in March 2021.90 The GHG Reduction Plan Update provides more details on GHG reduction measures mentioned in the City’s General Plan. These details largely highlight land use strategies for increased population density and mobile vehicle travel reductions like the City’s General Plan but provide indicators for the effectiveness of such measures. The GHG Reduction Plan provides a review process for projects that require discretionary approval from the City to ensure adherence to the streamlined CEQA review process and nonsignificant GHG impacts. Significance thresholds for GHG emissions are discussed in more detail below.

City of Fresno. 2014. Resource Conservation and Resilience. Available at: https://www.fresno.gov/darm/wpcontent/uploads/sites/10/2019/07/General-Plan-7-Resources-Conservation-and-Resilience-7-19.pdf. Accessed:

January 2022.
88 FirstCarbon Solutions. 2014. DRAFT Fresno General plan Update, Greenhouse Gas Reduction Plan, City of Fresno California. Available at: https://www.fresno.gov/darm/wp-content/uploads/sites/10/2016/11/F-2-GreenhouseGas-Reduction-Plan.pdf. Accessed: January 2022. 89 LSA. 2020. DRAFT Greenhouse Gas Reduction Plan Update. Available at: https://www.fresno.gov/darm/wpcontent/uploads/sites/10/2020/03/Appendix_G-GHG_Reduction_Plan_Update.pdf. Accessed: January 2022. 90 LSA. 2021. Greenhouse Gas Reduction Plan Update. Available at: https://www.fresno.gov/darm/wpcontent/uploads/sites/10/2021/03/Link4AppendixGGHGRPUpdate.pdf. Accessed: January 2022.

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2.2.5 Other CEQA Guidance

2.2.5.1 CAPCOA
a) CAPCOA 2008 CEQA & Climate Change White Paper
In January 2008, the California Air Pollution Control Officers Association (CAPCOA) published its CEQA & Climate Change white paper.91 In the white paper, CAPCOA surveyed three options available to CEQA lead agencies for purposes of evaluating the significance of a project’s GHG emissions, including identifying no significance thresholds for GHG emissions, setting a zero emissions threshold, or setting a non-zero emissions threshold. As to the non-zero thresholds, CAPCOA’s white paper considered two approaches, one grounded in statute and executive order with four possible options, and one grounded in a tiered framework. As for the approach grounded in statute and executive order, CAPCOA identified four threshold concepts:
x Threshold 1.1: AB 32/S-3-05 Derived Uniform Percentage-Based Reduction; x Threshold 1.2: Uniform Percentage-Based (e.g., 50 percent) Reduction for New Development;
x Threshold 1.3: Uniform Percentage-Based Reduction by Economic Sector; and x Threshold 1.4: Uniform Percentage-Based Reduction by Region.

For purposes of the tiered framework approach, a project’s GHG emissions would result in a less-than-significant impact provided one of the following criteria were achieved:
(1) compliance with a general or regional plan in alignment with AB 32; (2) application of a CEQA exemption; (3) inclusion on the “green list;” (4) consistency with a qualified GHG reduction strategy; or (5) demonstration that quantified GHG emissions are less than significant. Tables 4 and 5 of the white paper identified advantages and disadvantages associated with all of the options presented for consideration. b) CAPCOA 2010 Quantifying Greenhouse Gas Mitigation Measures In August 2010, CAPCOA published its Quantifying Greenhouse Gas Mitigation Measures report, which presents information and analysis regarding the quantification of project-level mitigation of GHG emissions associated with land use, transportation, energy use, and other related project areas. CAPCOA and its contractors conducted an extensive literature review in order to provide reliable and substantiated evidentiary bases for the quantification protocols presented in the report; as such, individual GHG reduction measures are accompanied by “fact sheets” that set forth the relevant parameters for the quantification calculations.
c) CAPCOA 2021 Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity
In December 2021, CAPCOA published the final draft of the Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity report, which builds upon CAPCOA’s previous efforts to provide accurate 91 CAPCOA is a non-profit association of the air pollution control officers from all 35 local air quality agencies throughout California.

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and reliable quantification measures.92 This Handbook identifies and evaluates new and emerging GHG reduction measures and removed outdated measures from the 2010 Handbook. The purpose of the Handbook is to provide local governments with accurate, reliable, and standardized emission reduction quantification methods for land use, climate action, and long-term planning. It also aims to support and enhance the consideration of climate vulnerabilities, health, and equity during the planning process.

2.2.5.2 Association of Environmental Professionals
a) AEP Beyond 2020 White Paper
In March 2015, the Association of Environmental Professionals (AEP) released its draft Beyond 2020: The Challenge of Greenhouse Gas Reduction Planning by Local Governments in California (Beyond 2020) white paper.93 In the white paper, AEP presented evidence showing that it is infeasible for a local jurisdiction to achieve EO S-3-05’s 2050 reduction target (i.e., 80 percent below 1990 levels) absent a real post-2020 State plan of action. As such, AEP recommended assessing project significance in relation to the 2050 reduction target by asking whether a project would “impede substantial progress in local, regional, and State GHG emissions reductions over time toward long-term GHG reduction targets.” b) AEP Beyond 2020 and Newhall White Paper
In April 2016, AEP released its draft Beyond 2020 and Newhall: A Field Guide to New CEQA Greenhouse Gas Thresholds and Climate Action Plan Targets for California (Beyond 2020 and Newhall) white paper. In the white paper, AEP surveyed the following significance threshold concepts for utilization in CEQA-oriented GHG emissions analysis: consistency with qualified GHG reduction plans; bright line values; efficiency metrics; hybrid metrics that separate transportation and non-transportation emissions; best management practices; regulatory compliance; and percent reductions from business as usual. In doing so, AEP identified the present circumstances as a “transitional period” due to the absence of comprehensive State planning for post-2020, non-legislatively adopted, statewide targets. 92 CAPCOA. 2021. Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity. Available at:
http://www.airquality.org/ClimateChange/Documents/Final%20Handbook_AB434.pdf. Accessed: January 2022. 93 AEP is a non-profit association of public and private sector professionals with a common interest in serving the principles underlying CEQA.

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3. SIGNIFICANCE THRESHOLDS

3.1 CEQA Guidelines on GHG Emissions
In 2007, SB 97 was enacted and directed OPR and the California Natural Resources Agency to prepare amendments to the CEQA Guidelines addressing the analysis of GHG emissions under CEQA. Following formal rulemaking, a series of amendments to the CEQA Guidelines were adopted to provide the general framework for the analysis of GHG emissions, and became effective in 2010. The amendments do not provide a mandatory, quantitative rubric for GHG emissions analysis, but instead provide general guidance and recognize long-standing CEQA principles regarding the discretion afforded to lead agencies where supported by substantial evidence. More specifically, CEQA Guidelines Section 15064.4(a) recognizes that the “determination of the significance” of GHG emissions “calls for careful judgment by the lead agency” in accordance with the more general provisions of CEQA Guidelines Section 15064; each agency “shall have discretion to determine” whether to conduct quantitative or qualitative analysis, provided its determination is supported by substantial evidence. Section 15064.4 was most recently amended by OPR and the California Natural Resources Agency in December 2018.

The analysis provided in this report evaluates the significance of the Project’s GHG emissions by reference to the following questions from Section VIII, Greenhouse Gases, of Appendix G of the CEQA Guidelines:

Threshold 1. Would the project generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment?
Threshold 2. Would the project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs?

3.2 Other Guidance
The City of Fresno has not developed a quantitative threshold of significance for GHG emissions. As of the most recent version of the City of Fresno’s Greenhouse Gas Reduction Plan, the City developed a GHG checklist to assist CEQA projects in evaluating significance.94 SJVAPCD has adopted guidance documents for assessing and mitigating GHG impacts on global climate change. Rather than establishing specific numeric thresholds of significance (as in the case of criteria pollutant emissions), the SJVAPCD guidance utilizes a tiered approach to assess cumulative impacts on global climate change. Notably, the SJVAPCD establishes that a project can demonstrate compliance with an approved GHG emissions reduction program (such as CARB’s statewide GHG Cap-and-Trade Program). Furthermore, SJVAPCD’s December 2009 CEQA GHG policies and its 2015 GAMAQI states that a project whose emissions have been reduced or mitigated consistent with the California Global Warming Solutions Act of 2006 (AB 32) should be considered to have a less than significant impact on global climate change.95 SJVAPCD and the City of Fresno have not adopted a numerical GHG threshold.
94 LSA. 2021. Greenhouse Gas Reduction Plan Update. Available at: https://www.fresno.gov/darm/wpcontent/uploads/sites/10/2021/03/Link4AppendixGGHGRPUpdate.pdf. Accessed: January 2022. 95 SJVAPCD. 2015. Final Draft Guidance for Assessing and Mitigating Air Quality Impacts. Available at:
http://www.valleyair.org/transportation/GAMAQI.pdf. Accessed: January 2022.

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The City of Fresno’s Greenhouse Gas Reduction Plan Update (GHGRP) is considered a “Qualified Plan” which allows project-level CEQA tiering and streamlining. As a qualified plan, the plan must include a community-wide inventory of GHG emissions, forecasted future emissions, targets for GHG reductions in line with State goals, quantifiable GHG reduction measures, established monitoring procedures, an environmental review, and adoption through a public process (CEQA Guidelines § 15183.5(b)).

The GHGRP establishes the City’s GHG inventory based on the most recent data available for the year 2016. Forecasted emissions with future growth are developed for the business-asusual (BAU) and adjusted BAU (ABAU) scenarios (the ABAU scenario includes State policies) for the years 2020, 2030, and 2035. The 2020 and 2030 forecast years are consistent with the goals identified in Assembly Bill (AB) 32 and Senate Bill (SB) 32, which identify Statewide GHG reduction targets by 2020 and 2030. The 2035 forecast year corresponds to the City’s General Plan horizon year and will allow the City to develop long-term strategies to continue GHG reductions. The GHGRP analysis establishes a basis and criteria for project level land use development in the City of Fresno.

The City of Fresno GHGRP’s analysis is based on specific land uses for the City of Fresno.

Fresno’s GHGRP includes general plan buildout that accounts for an incremental increase of 40.5 million square feet of industrial use, 20.8 million square feet of mixed use, and

63.3 million square feet of commercial/office/public facility use. For 2030 and 2035, the City of Fresno establishes a reduction from the adjusted BAU emissions that will meet the state targets. For 2030 this is a 1.5% reduction from the ABAU emissions and for 2035 this reduction is an 11.6% reduction from the ABAU. The GHGRP has thus established a City and land use specific criteria for individual Projects to demonstrate consistency with.

3.3 Project Approach to Significance
This report, relative to Threshold 1, quantifies the Project’s GHG emissions during operation and construction for disclosure and in the absence of a numerical GHG significance threshold will evaluate consistency with the City of Fresno GHG Reduction Plan Update to determine significance of the Project’s GHG emissions. This report, relative to Threshold 2, evaluates the Project for consistency with applicable plans related to GHG emissions at the state, regional, and local levels.

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4. PROJECT GHG EMISSIONS INVENTORY
This section describes the methodology that Ramboll used to develop the GHG emission inventories associated with the Project, which include one-time emissions (construction emissions and emissions due to vegetation changes), and operational emissions. Subcategories of GHG operational emissions include: area sources, energy use, water supply and wastewater, solid waste, and mobile sources. The emissions inventory reflects the reasonably foreseeable change based on the discontinued operation of the Costco Warehouse located at 4500 W Shaw Avenue. For purposes of this analysis, 4500 W Shaw Avenue is assumed to be backfilled by a shopping center use.

4.1 Measurement, Resources and Baseline Condition

4.1.1 Units of Measurement: Tonnes of CO2 and CO2e
In this report, the term “GHGs” includes gases that contribute to the natural greenhouse effect, such as CO2, CH4, N2O, and water, as well as gases that are only man-made and that are emitted through the use of modern industrial products, such as HFCs and chlorofluorocarbons (CFCs). GHG emissions are typically measured in terms of mass of CO2e.

CO2e are calculated as the product of the mass of a given GHG and its specific GWP, as described in Section 2.1. GWPs of 25 and 298 were used for CH4 and N2O, respectively, for this analysis. In many sections of this report, including the final summary sections, emissions are presented in units of CO2e either because the GWPs of CH4 and N2O were accounted for explicitly, or the CH4 and N2O are assumed to contribute a negligible amount of GWP when compared to the CO2 emissions from that particular emissions category.

In this report, a tonne refers to MT (1,000 kilograms). Additionally, exact totals presented in all tables and report sections may not equal the sum of components due to independent rounding of numbers.

4.1.2 Resources

4.1.2.1 CalEEMod® Methodology
Ramboll primarily utilized the California Emissions Estimator Model (CalEEMod®) version 2020.4.096 methodology to assist in quantifying the GHG emissions in the inventories presented in this report for the Project. CalEEMod® provides methodology to calculate both construction emissions and operational emissions from a land use development project. It calculates total or annual GHG emissions. Specifically, the model methodology aids the user in the following calculations:
x One-time short-term construction emissions associated with demolition, site preparation, grading, building, and paving from off-road construction equipment, and on-road mobile equipment associated with workers, vendors, and hauling. x One-time vegetation sequestration changes, such as permanent vegetation land use changes and new tree plantings.
x Operational emissions associated with the fully built out land use development, such as on-road mobile vehicle traffic generated by the land uses, off-road emissions from 96 SCAQMD. 2021. California Emissions Estimator Model®. Available at: https://www.aqmd.gov/caleemod/.

Accessed: January 2022.

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landscaping equipment, natural gas usage in the buildings, electricity usage in the buildings, water usage by the land uses, and solid waste disposal by the land uses.

CalEEMod® is a statewide program designed to calculate both criteria pollutant and GHG emissions from development projects in California developed under the auspices of the South Coast Air Quality Management District (SCAQMD), with input from other California air districts, and is currently supported by numerous lead agencies for use in quantifying the emissions associated with development projects undergoing environmental review.

CalEEMod® utilizes widely accepted models for emission estimates combined with appropriate default data that can be used if site-specific information is not available. These models and default estimates use sources such as the USEPA AP-42 emission factors,97 CARB’s on-road and off-road equipment emission models such as the EMission FACtor model (EMFAC) and the Emissions Inventory Program model (OFFROAD), and studies commissioned by California agencies such as the CEC and CalRecycle.

As mentioned above, CalEEMod® is based upon the CARB-approved OFFROAD and EMFAC models. OFFROAD98 is an emission factor model used to calculate emission rates from off-road mobile sources (e.g., construction equipment, agricultural equipment). The off-road diesel emission factors used by CalEEMod® are based on the CARB OFFROAD2011 program.

EMFAC is an emission factor model used to calculate emissions rates from on-road vehicles (e.g., passenger vehicles). CalEEMod® 2020.4.0 contains EMFAC2017 emission factors. The latest version of EMFAC is the CARB EMFAC2021 program.99 In addition, CalEEMod® contains default values and existing regulation methodologies to use in each specific local air district region. Appropriate statewide default values can be utilized if regional default values are not defined. Ramboll used default factors for the Fresno County area (within the SJVAPCD’s jurisdiction) for the emissions inventory, unless otherwise noted in the methodology descriptions below.

Details regarding the specific methodologies used by CalEEMod® can be found in the CalEEMod® User’s Guide and associated appendices.100

4.1.2.2 OFFROAD2017
OFFROAD2017 is CARB’s most current off-road emissions inventory model. The exhaust emission factors for each equipment at each horsepower range were back-calculated from total daily emissions reported in the model output files and annual usage in terms of horsepower-hours for each equipment type in the specified region and calendar year. These emission factors are then used in the calculation of Baseline and Project emissions for each type of equipment utilized at the Facility.
97 The USEPA maintains a compilation of Air Pollutant Emission Factors and process information for several air pollution source categories. The data is based on source test data, material balance studies, and engineering estimates. Available at: https://www.epa.gov/air-emissions-factors-and-quantification/ap-42-compilation-airemissions-factors. Accessed: January 2022. 98 CARB. 2011. Off Road Mobile Source Emission factors. Available at: https://ww2.arb.ca.gov/ourwork/programs/mobile-source-emissions-inventory. Accessed: January 2022. 99 CARB. 2021. EMFAC2021. Available at: https://ww2.arb.ca.gov/our-work/programs/mobile-source-emissionsinventory/msei-modeling-tools-emfac-software-and. Accessed: January 2022. 100 SCAQMD. 2021. California Emissions Estimator Model User’s Guide. Version 2020.4.0. Available at:
https://www.aqmd.gov/caleemod/. Accessed: January 2022.

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4.1.2.3 Other Resources
Ramboll directly or indirectly relied on emissions estimation guidance from government-sponsored organizations, government-commissioned studies of energy use patterns, Project-specific studies (e.g., Kittelson’s Fresno Costco Relocation Transportation Impact Analysis101), and emission estimation software as described above. In cases noted below, third-party studies were also relied upon to support analyses and assumptions made outside of the approach described above.

4.1.3 Indirect GHG Emissions from Electricity Use
Project-related electricity use results in indirect emissions, due to electricity generation activities occurring at off-site power plant locations. For the Project, electrical power will be supplied by PG&E. The indirect GHG emissions created as a result of Project-related electricity use are calculated through application of the following methodology.

For purposes of electricity use, intensity factors are GHG emission rates from a given source relative to the energy generation activities, and are expressed in terms of the amount of GHG released per megawatt of energy produced. The default electricity intensity factors for PG&E in CalEEMod® for CO2, CH4, and N2O are 203.983, 0.033, and 0.004 pounds (lbs) of GHG per megawatt-hour, respectively. The CalEEMod® CO2 default factor is based on the emission factor provided to Sacramento Metro Air Quality Management District by PG&E. The CH4 and N2O default factors are based on E-Grid values for the Western Electricity Coordinating Council California and Mexico (CAMX) region. PG&E’s Power/Utility Protocol (PUP) reports show that renewable energy sources do not result in any new CO2 emissions.

While CalEEMod®’s emission factors for CH4 and N2O conservatively were used for this project, CalEEMod®'s CO2 intensity factor was modified based on PG&E’s 2019 Corporate Sustainability Report, to account for the Renewables Portfolio Standard’s (RPS) requirement for 2030 (i.e., 60 percent RPS). The 2017 and 2018 mix of renewable and non-renewable energy sources in PG&E’s energy supply were both used to calculate the intensity factors for PG&E’s non-renewable energy. (For disclosure purposes, PG&E’s current RPS is 30.6 percent.)102 The PG&E data provides the basis for the estimate of the intensity factors for the non-renewable energy; and this data is used to project what the intensity factors will be when the Project reaches build-out. The intensity factor for CO2 is calculated by multiplying the percentage of energy delivered by PG&E from non-renewable energy resources with the intensity factor for non-renewable energy as calculated (see Section 4.3.4 below).

4.2 One-Time Emissions
One-time emissions are those emissions that are not reoccurring over the life of the Project.

This includes emissions associated with construction and emissions associated with land use changes.
101 Kittelson & Associates, Inc. 2023. Fresno Costco Relocation Transportation Impact Analysis. May. 102 PG&E. 2021 Corporate Responsibility and Sustainability Report. Available at:
https://www.pgecorp.com/corp_responsibility/reports/2021/pf04_renewable_energy.html. Accessed: June 2022.

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4.2.1 Construction Emissions
This section describes the estimation of GHG emissions from construction activities at the Project site. While the exact construction schedule and equipment mix may vary from the current analysis, the GHG emissions are not expected to be higher than that calculated given the conservative assumptions included in this analysis.

The major construction phases included in this analysis are:
x Demolition: involves removing buildings or structures. x Site Preparation: involves clearing vegetation (grubbing and tree/stump removal) and removing stones and other unwanted material or debris prior to grading. x Grading: involves the cut and fill of land to ensure the proper base and slope for the construction foundation.
x Building Construction: involves the construction of structures and buildings. x Paving: involves the laying of concrete or asphalt such as in parking lots or roads. x Architectural Coating: involves the application of coatings to both the interior and exterior of buildings or structures, the painting of parking lot or parking garage striping, associated signage and curbs, and the painting of the walls or other components such as stair railings inside parking structures.

GHG emissions from these construction phases are attributable to fuel use from construction equipment usage onsite and from on-road worker, vendor, and hauling trips.

Ramboll primarily used CalEEMod® to quantify the construction emissions. The modeled construction schedule is shown in Table 4-1. The construction off-road equipment list is a Project-specific estimate; the off-road equipment specifications are based on CalEEMod® model defaults.

The construction-related equipment mix assumptions are shown in Table 4-2. Table 4-3 presents the material handling volumes which are anticipated to be imported and exported.

Table 4-4 includes the Project-specific demolition assumptions.

4.2.1.1 Emissions from On-Road Construction Trips
Construction generates on-road vehicle GHG emissions from personal vehicles for worker and vendor commuting, and trucks for soil and material hauling. These emissions are based on the number of trips and VMT, along with emission factors from EMFAC. Default model trip rates were used for construction. The emissions from mobile sources were calculated in CalEEMod® with the trip rates, trip lengths, and emission factors for running exhaust from EMFAC as follows:103
Emissions pollutant = VMT * EF running, pollutant
Where:

Emissions pollutant = emissions from vehicle running for each pollutant VMT = vehicle miles traveled
103 SCAQMD. 2021. California Emissions Estimator Model® User’s Guide, Appendix A. Available at:
https://www.aqmd.gov/caleemod/. Accessed: January 2022.

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EF running, pollutant = emission factor for running emissions On-road construction trip emissions are presented in the CalEEMod® output in Appendix A.

4.2.1.2 Emissions from Construction Equipment
The emissions associated with construction equipment are from off-road equipment engine use based on the equipment list and phase length, and on-road vehicle trips and phase length.

Since the majority of the off-road construction equipment used for construction projects are diesel fueled, CalEEMod® assumes all of the equipment operates on diesel fuel. The calculations include the running exhaust emissions from off-road equipment. Since the equipment is assumed to be diesel, there are no starting emissions associated with the equipment, as these are de minimis for diesel-fueled equipment. The exhaust emissions are calculated based on CARB’s OFFROAD2011 methodology using the equation presented below.104
EmissionsDiesel=෍൫EFi×Popi
×AvgHPi×Loadi×Activityi൯
i
Where:

EF = Emission factor in grams per horsepower-hour (g/bhp-hr) as processed from OFFROAD2011
Pop = Population, or the number of pieces of equipment
AvgHp = Maximum rated average horsepower
Load = Load factor
Activity = Hours of operation
i = equipment type
Emissions for off-road construction equipment for each phase of construction are detailed in Appendix A.

4.2.1.3 Total Construction Emissions
The Project construction emissions were run within CalEEMod® to generate the annual emissions. The total emissions from construction from all phases for off-road and on-road emissions in 2023 are summarized in Appendix A.

4.2.2 Vegetation Changes
Vegetation changes that occur as a result of land use development constitute a one-time change in the carbon sequestration capacity of a project site. In this case, the land the Project will occupy is vacant.

4.3 Annual Operational Emissions
This section describes the estimation of GHG emissions from operational activities at the Project site. The operational emissions were calculated with CalEEMod® and separately for mobile source emissions. Operational GHG emissions are calculated for landscaping, natural 104 SCAQMD. 2018. California Emissions Estimator Model® User’s Guide, Appendix A. Available at:
https://www.aqmd.gov/caleemod/. Accessed: January 2022.

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gas and electricity usage, on-road mobile trips, water usage, and solid waste generated.

Operational emissions are evaluated for the first year of Project Operation in 2023.

4.3.1 Area Sources
Area sources are direct sources of GHG emissions, such as emissions from landscaping activities. The area source GHG emissions included in this analysis are landscaping-related fuel combustion sources, such as lawn mowers.

4.3.2 Mobile Sources
The GHG emissions associated with on-road mobile sources are generated from workers, vendors, and haul trucks travelling to and from the Project site. The GHG emissions associated with on-road mobile sources include running and starting exhaust emissions.

Running emissions are dependent on VMT. Starting emissions are associated with the number of starts or time between vehicle uses and the assumptions used in determining these values are described below. Ramboll calculated mobile source emissions using trip rates and trip length information based on analyses conducted by Kittelson.

The analysis includes the benefit of reductions from some adopted regulatory programs, which are accounted within EMFAC2021 as follows:
x AB 1493 (“the Pavley Standard”) required CARB to adopt regulations by January 1, 2005, to reduce GHG emissions from non-commercial passenger vehicles and light-duty trucks of model year 2009 and thereafter. EMFAC2021 includes emission reductions for non-commercial passenger vehicles and light-duty trucks of model year 2017 – 2025.
x The ACC program adopted by CARB, introduced in 2012, combines the control of smog, soot causing pollutants and GHG emissions into a single coordinated package of requirements for model years 2015 through 2025. EMFAC2021 includes reductions associated with this regulation that are represented in this analysis. x The USEPA/NHTSA advanced fuel economy and GHG standards (Phase 1) were adopted in 2011 for medium and heavy-duty trucks for model years 2014-2018.105 This Heavy-Duty National Program is intended to reduce fuel use and GHG emissions from medium- and heavy-duty vehicles, semi-trucks, pickup trucks and vans, and all types and sizes of work trucks and buses in between. EMFAC2021 includes reductions associated with this regulation that are represented in this analysis. x The USEPA/NHTSA advanced fuel economy and GHG standards (Phase 2) were adopted in 2016 for medium- and heavy-duty trucks for model years 2018 and beyond.106 The Phase 2 program includes technology-advancing standards that substantially reduce GHG emissions and fuel consumption resulting in an ambitious, yet achievable, program that will allow manufacturers to meet the applicable standards over time, at reasonable cost, 105 USEPA, Office of Transportation and Air Quality. 2011. Available at: https://www.gpo.gov/fdsys/pkg/FR-2011- 09-15/pdf/2011-20740.pdf. Accessed: January 2022.
106 USEPA, Office of Transportation and Air Quality. 2016. Available at: https://www.gpo.gov/fdsys/pkg/FR-2016- 10-25/pdf/2016-21203.pdf. Accessed: January 2022.

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through a mix of different technologies. The Phase 2 program’s standards will be phased in, beginning with model year 2021 and culminating with model year 2027.107 In June 2020, CARB released EMFAC off-model adjustment factors to account for the Final Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule.108 The SAFE Rule has been incorporated into this analysis as it is incorporated in EMFAC2021.

4.3.2.1 Estimating Mobile Source Emissions
Mobile source emissions calculation requires trip rates and trip lengths for each different trip type in the Project (e.g., employee, vendor, and haul truck).

The following sections describe the methodology to derive the necessary inputs. a) Trip Generation Rates
The trip generation rates for the Project were based on Kittelson data. The trips for the northeast corner of W. Herndon Ave. and N. Riverside Dr (Herndon/Riverside) and 4500 W Shaw Ave are shown in Appendix B in Table B-1a and Table B-1b. b) Trip Lengths
The Project trip lengths were based on Kittelson analysis, other than the MDO delivery truck trip length, which was based on the average routed round trip length for Fresno MDO deliveries. These trip lengths for Herndon/Riverside and 4500 W Shaw Ave are represented in Appendix B, Table B-1a and Table B-1b, respectively. c) Fleet Mix
The fleet mixes derived based on CalEEMod® and EMFAC2021 were used to determine the mix of light-duty vehicles used for member vehicles and employee vehicles. The MDO delivery trucks, fuel delivery trucks, and warehouse delivery trucks were assumed to be heavy-heavy-duty trucks. The fleet mixes for the operational mobile trips are shown in Table B-2 of Appendix B.
d) Transport Refrigeration Units
The Project includes Transport Refrigeration Units (TRUs), which 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. These TRUs account for approximately 15% of the warehouse delivery trucks. This analysis assumes that TRUs are plugged in at the loading dock. OFFROAD2021 has emission factors for TRUs, which were obtained for Fresno County in 2023. Emissions of CO2 from TRUs were estimated, as shown in Table 4-6.

4.3.2.2 Mobile Source Emissions
The weighted emission factors from running exhaust for each vehicle type are presented in Appendix B, Table B-3. Starting exhaust emission factors for each vehicle type are 107 The emission reductions attributable to Phase 2 of the regulations for medium- and heavy-duty trucks were not included in the Project's emissions inventory due to the difficulty in quantifying the reductions. Excluding these reductions results in a more conservative (i.e., higher) estimate of emissions for the Project. 108 CARB. 2020. EMFAC Off-Model Adjustment Factors for Carbon Dioxide (CO2) Emissions to Account for the SAFE Vehicles Rule Part One and the Final SAFE Rule. Available at:
https://ww3.arb.ca.gov/msei/emfac_off_model_co2_adjustment_factors_06262020-final.pdf. Accessed:

January 2022.

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displayed in Appendix B, Table B-4. Idling emission factors for passenger vehicles and delivery trucks are presented in Appendix B, Table B-5. The overall mobile source emissions from running, starting, and idling are shown in Appendix B, Table B-6a and B-6b, along with the VMT, trips, and idling durations.

4.3.3 Water Supply, Treatment and Distribution
Indirect GHG emissions result from the production of electricity used to convey, treat, and distribute the Project's water and wastewater. The amount of electricity required to convey, treat, and distribute water depends on the volume of water as well as the sources of the water. Additionally, direct CH4 and N2O emissions result from the treatment of wastewater.

Water demand and wastewater generation values were based on CalEEMod® defaults.

The water usage and associated GHG emissions are shown in Appendix A.

4.3.4 Energy Use
Energy usage within buildings (e.g., electricity and natural gas fuelled equipment) contribute to the facility’s GHG inventory. Combustion of any type of fuel emits CO2 and other GHGs directly into the atmosphere; these emissions are considered direct emissions associated with a building. GHGs are also emitted during the generation of electricity from fossil fuels; these emissions are considered to be indirect emissions.

To estimate GHG emissions from the natural gas and electricity usage for the Project, Ramboll utilized CalEEMod® default assumptions, which incorporate Title 24 2019 Standards.

Table 4-5 identifies the emission factors for electricity (i.e., pounds of CO2 per megawatthour delivered) used in this analysis. As illustrated in Table 4-5, an PG&E-specific emission factor that accounts for interpolation between the 33 percent RPS required by 2020 and 60 percent RPS required by 2030, as discussed in Section 4.1.3, was calculated based on 41.1 percent RPS in 2023.

The annual natural gas and electricity use and corresponding GHG emissions for the Project are shown in Appendix A.

4.3.5 Solid Waste
Municipal solid waste (MSW) is the amount of material that is disposed of by landfilling, recycling, or composting. CalEEMod® calculates the indirect GHG emissions associated with waste that is disposed of at a landfill. The program uses annual waste disposal rates from the CalRecycle data for individual land uses. CalEEMod® uses the overall California Waste Stream composition to generate the necessary types of different waste disposed into landfills. The program quantifies the GHG emissions associated with the decomposition of the waste, which generates methane based on the total amount of degradable organic carbon.

The program quantifies the CO2 emissions associated with the combustion of methane, if applicable. Default landfill gas concentrations were used as reported in Section 2.4 of AP-42.

The IPCC has a similar method to calculate GHG emissions from MSW in its 2006 Guidelines for National Greenhouse Gas Inventories.

Solid waste generation associated with the Project is based on default values for waste generation in CalEEMod®. The Project’s solid waste generation and GHG emissions associated with solid waste are provided in Appendix A.

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4.4 Total Annual Operational Emissions
As shown in Table 4-7, the Project emissions are 22,428 MT CO2e per year. The total GHG emissions from Project construction are 1,047 MT CO2e and are summarized in Appendix A for construction off-road equipment and mobile trips. When amortized over a period of 30 years, the emission estimates for the Project construction become 35 MT CO2e/yr.109 The total GHG emissions include the amortized construction emissions. 109 This approach to one-time construction and vegetation change GHG emissions is based on the GHG Threshold Working Group Meeting #13 Minutes from August 26, 2009. Available at: http://www.aqmd.gov/docs/defaultsource/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance-thresholds/year-2008-2009/ghg-meeting13/ghg-meeting-13-minutes.pdf. Accessed: January 2022.

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5. PROJECT INVENTORY IN CONTEXT
This section assesses the significance of the Project’s emissions for purposes of CEQA.

5.1 Project Emissions Inventory
This section evaluates the significance of the Project’s GHG emissions by reference to Threshold 1 from Section VIII, Greenhouse Gases, of Appendix G of the CEQA Guidelines:

Threshold 1. Would the project generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment?

5.1.1 GHG Inventory
The Project GHG emissions were calculated to be 22,428 MT CO2e/yr for the buildout year (2023). The City of Fresno’s Greenhouse Gas Reduction Plan Update provides a 2016 inventory consisting of 2,923,633 MT CO2e. The projected 2020 emissions for the City are 2,132,326 MT CO2e when accounting for emission reductions achieved by state-wide regulations, programs, and measures. In the absence of a numerical GHG threshold, the significance of these emissions will be based on consistency with the City of Fresno GHG Reduction Plan Update as discussed below.

5.2 Consistency Analysis
This section evaluates the significance of the Project’s GHG emissions by reference to Threshold 2 from Section VIII, Greenhouse Gases, of Appendix G of the CEQA Guidelines:

Threshold 2. Would the project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs?

5.2.1 Statewide Emissions Reduction Targets
As discussed in Section 2.2.2, the 2022 Scoping Plan Update has priority GHG reduction strategies that are the focus for the state to achieve its statewide emission reduction targets.

The three main priorities areas are “Transportation Electrification”, “VMT Reduction”, and “Building Decarbonization”. These measures represent the core strategies that local jurisdictions in California can implement to reduce GHGs in alignment with State goals.

The Project will be consistent with the state’s GHG reduction goals as discussed in the 2022 CARB Scoping Plan. The Project will serve the needs of consumers in California and provide an effective and efficient means to shop at the warehouse, fill up a gasoline vehicle, and get a car wash all in the same location. The Project’s emissions sources are regulated (and are foreseeably expected to continue to be regulated in the future) in furtherance of the State’s environmental policy objectives and the Project will continue to meet those regulations to continually improve and reduce GHG emissions. Costco has a focus on sustainability, with specific measures being implemented to manage energy use across its warehouses. Costco's warehouse designs are consistent with the requirements of Leadership in Energy and Environmental Design (LEED), an internationally accepted benchmark for green building design and construction. Costco continues to improve the design and construction of its buildings, as technological advancements in these areas and building materials improve.

Improved engineering and design has resulted in the use of less materials, such as columns and I-beams, while providing more strength. Costco prefers full metal buildings in order to use the maximum amount of recycled material.

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As demonstrated in Table C-1 in Appendix C, the Project would be consistent with applicable 2022 California Scoping Plan strategies for the reduction of GHG emissions.

5.2.2 Fresno Council of Governments (Fresno COG)
The Project will be consistent with the state’s GHG reduction goals and strategies as discussed in the Fresno COG’s 2022 Regional Transportation Plan/Sustainable Communities Strategy110 (the current RTP/SCS for the region), which contains four key elements:

1. Policy Element– Sets forth Fresno COG’s transportation goals, objectives, and policies for each transportation mode.

2. Sustainable Communities Strategy – Integrates land use and transportation planning efforts to meet Fresno County’s greenhouse gas emission reduction targets, improve accessibility to major employment and other regional activity centers.

3. Action Element – Describes the existing transportation system, discusses recent accomplishments, provides a transportation needs assessment, and proposes shortterm and long-term actions for both transportation planning and actual transportation project improvements.

4. Financial Element – Identifies both existing and anticipated revenue sources as well as the financing techniques available for the region’s planned transportation investments, ongoing operations, and maintenance.

The RTP/SCS is based on an analysis that considers the entire County, and includes all projects involving changes in regional growth and land use in Fresno County, as well as the countywide vehicle traffic projections. Cumulative GHG emissions analyzed in the RTP were compared to regional GHG thresholds and analyzed under statewide plans and regulations.

This analysis concluded that there would be a decrease in GHG emissions from existing conditions to 2046, which are primarily be due to focusing growth in developed areas, moderately increasing residential densities, encouraging infill development, protecting open space and agricultural land, and providing alternatives to single-occupancy vehicle trips.

As shown in Table C-2 in Appendix C, the Project would be consistent with applicable Fresno COG strategies for the reduction of GHG emissions.

5.2.3 City of Fresno GHG Reduction Plan
The City of Fresno’s 2021 GHG Reduction Plan Update contains a Greenhouse Gas Reduction Strategy in Section 5. The strategies are organized into the following categories: 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; and municipal strategies.

Section 6 of the Reduction Plan Update describes actions for individual development projects.

Individual projects are tasked with reviewing the GHG Reduction Plan Project Update CEQA Consistency Checklist that lists the local GHG reduction strategies identified in the GHG Plan Update to determine applicability to the project.
110 Fresno COG. 2018 Regional Transportation Plan and Sustainable Communities Strategy. Available at:
https://www.fresnocog.org/project/regional-transportation-plan-rtp/. Accessed: January 2022.

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Proposed development projects that are consistent with the GHG Plan Update as determined through the 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. The GHG Reduction Plan Update includes the GHG reduction strategies that individual projects review to determine applicability.

In the GHG Plan Update CEQA Consistency Checklist, the first step in determining the consistency with the GHG Reduction Plan is to determine land use consistency. The Project is asked whether it is consistent with the approved General Plan, Specific Plan, and Community Plan planned land use and zoning designations. The project is requesting a zoning change to change the site’s General Plan Land Use Designation from Community Commercial111 to General Commercial112. The Project includes a wholesale club, which is classified under the General Commercial designation. Based on the allowable floor to area ratio under these two designations and the relatively similar allowable uses under these two designations, the potential emissions at maximum buildout for the proposed designation would be greater than that for maximum buildout of the existing designation. Per the checklist, the Project's unmitigated GHG impact is significant.

The checklist provides two options based on this determination. The Project must either show consistency with applicable General Plan objectives and policies or provide analysis and measures to incorporate into the project to bring the GHG emissions to a level that is less than or equal to the estimated project emission at maximum buildout of the existing designation(s). The Project will demonstrate consistency with applicable General Plan objectives and policies through an evaluation of the Project’s alignment with General Plan objectives and policies relative to the GHGRP. The Project is quantitatively evaluated using the same methodology as the GHGRP to demonstrate this consistency. Given that there is a proposed development project associated with this rezone, the GHG Plan Update Consistency Checklist has been completed and applicable measures incorporated.

As shown in the GHG Consistency Checklist in Appendix C, the Project meets 11 of the total 12 applicable items listed. However, the project would not meet ‘item h.’ due to a significant VMT impact. As required by the City of Fresno GHG reduction plan, the Project has prepared a full GHG emissions inventory and applied appropriate GHG reduction strategies as demonstrated by the 11 categories of the checklist which the project is consistent with. The Project will meet the applicable GHG reduction strategies for non-residential projects identified in the GHG Plan Update and listed in the checklist, other than ‘item h’.

Due to the inconsistency with ‘item h’, a Project emissions inventory for 2030 and 2035 was calculated to demonstrate how the Project still aligns with the GHG reduction goals of the GHGRP. The Project operational emissions were calculated for 2030 and 2035 for the 111 Community Commercial is intended for commercial development that primarily serves local needs such as convenience shopping and small offices. Specific uses allowed include medium-scale retail, office, civic and entertainment uses, supermarkets, drug stores and supporting uses. The maximum Floor Area Ratio is 1.0. 112 The General Commercial designation is intended for a range of retail and service uses that are not appropriate in other areas because of higher volumes of vehicle traffic and potential adverse impacts on other uses.

Development such as strip malls fall into this designation. Examples of allowable uses include: building materials, storage facilities with active storefronts, equipment rental, wholesale businesses, and specialized retail not normally found in shopping centers. The maximum Floor Area Ratio is 2.0.

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adjusted BAU scenario to align with the City of Fresno’s GHGRP adjusted BAU analysis (Table 5-1). Based on those calculated emission inventories, the Project would be required to achieve an additional reduction of 381 MT CO2e in 2030 and 2,711 MT CO2e in 2035 as identified in the City of Fresno’s GHGRP (see Table 4-C of the GHGRP which identifies the reduction needed from an adjusted BAU scenario to meet the City’s goals. The calculated reductions for the Project are the same percentage reduction required, i.e., 1.5% reduction in 2030 and 11.6% in 2035.). As identified in the GHGRP, the Project would realize GHG reductions due to project commitments in line with the local measures established by the GHGRP, which includes Land Use Strategies and Transportation Demand Management, Electric Vehicle Charging Stations, Net Zero Energy Commercial Building, Water Conservation, and Waste Diversion and Recycling. Specifically, the Project includes:
x Transportation Demand Management for employees via a voluntary commute trip reduction program for employees Costco provides that includes marketing, end-of-trip bicycle facilities, vanpool, and discounted transit. This can result in a 4% reduction in employee vehicle trips (This is VMT mitigation per the Fresno Costco Relocation Transportation Impact Analysis).
x EV chargers that meet the 2022 California Green Building Standards Code, Title 24, Part 11 that are beyond the adjusted BAU assumptions for the City. x Commitments to renewable energy through PG&E’s Solar Choice program (This is a project design feature to align with the local measure from the GHG Reduction Plan). x Achieving waste diversion goals as identified in the GHGRP.

In addition, since the City’s GHGRP was developed, there have been additional efforts by the state that will increase the expected presence of electric trucks and electric vehicles through the Advanced Clean Truck Rule113 and Advanced Clean Cars II114. Advanced Clean Cars II was proposed to support Governor Newsom’s 2020 Executive Order N-79-20 that requires all new passenger vehicles sold in California to be zero emissions by 2035. Advanced Clean Cars II was approved in August 2022. The 2022 Scoping Plan Update was approved in December 2022 and the proposed scenario for achieving this executive order provides data on year-toyear expected populations of zero-emission light-duty vehicles that exceed the assumptions made in EMFAC2021. Reductions in 2030 and 2035 have been calculated to account for this increased penetration of electric vehicles expected in the future (Table 5-2). The combined GHG reductions from these project specific commitments and state regulations demonstrate that the Project will achieve the same level of reductions as the City of Fresno GHGRP expects. The GHGRP has established a City and land use specific criteria for individual Projects to demonstrate consistency with. As such, the Project would align with the City’s GHGRP GHG reduction goals, and thus is consistent with the City’s GHGRP.

5.3 Impact Determination
While the Project would represent an increase in GHG emissions when compared to the existing conditions on the vacant site, the Project would not conflict with the Fresno COG’s RTP/SCS or statewide emission reduction targets in the 2022 CARB Scoping Plan Update.

The Project’s significant VMT impact means that the Project would not meet “item h.” on the 113 Available at: https://ww2.arb.ca.gov/our-work/programs/advanced-clean-trucks. Accessed: August 2022. 114 Available at: https://ww2.arb.ca.gov/our-work/programs/advanced-clean-cars-program/advanced-clean-cars-ii.

Accessed: August 2022.

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City of Fresno’s GHG Consistency Checklist. Because the Project does not meet all of the GHG reduction strategies identified in the GHG Reduction Plan Update Consistency Checklist, the Project has disclosed the Project emissions inventory and has demonstrated consistency with the GHG Reduction Plan by demonstrating the Project GHG reductions align with those expected for the City in the GHG Reduction Plan. Therefore, the Project’s GHG emissions will be less than significant in the context of Threshold 1 and Threshold 2, as discussed in Section 3.3.

Further, the SJVAPCD’s GAMAQI observes that: “It is widely recognized that no single project could generate sufficient GHG emissions to noticeably change global climate temperature.

However, the combination of GHG emissions from past, present, and future projects could contribute substantially to global climate change. Thus, project specific GHG emissions should be evaluated in terms of whether or not they would result in a cumulatively significant impact on global climate change.”115 In this context, and based on the analysis above, the Project’s GHG emissions are not cumulatively considerable. 115 SJVAPCD. 2015. Final Draft Guidance for Assessing and Mitigating Air Quality Impacts. Available at: http://www.valleyair.org/transportation/GAMAQI.pdf. Accessed: January 2022.

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TABLES
Table 4-1. Construction Schedule
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CalEEMod®
Phase Type1 Start Date1 End Date1
Phase
Duration2
(days)
Demolition 5/1/2023 5/8/2023 7
Site Preparation 5/1/2023 5/8/2023 7
Grading 5/9/2023 6/12/2023 30
Grading/BC Overlap 6/13/2023 7/5/2023 20
Building Construction 7/6/2023 11/10/2023 110
Paving 7/29/2023 9/13/2023 40
Architectural Coating 9/14/2023 11/10/2023 50
Notes:
1 Construction phases and duration are based on Project-specific estimates. 2 The construction work week was assumed to be 6 days per week.

Abbreviations:

CalEEMod® - California Emissions Estimator Model

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Fresno City CouncilMarch 7, 2024

Fresno City Council
March 7, 2024