Fresno City Council
March 7, 2024

Exhibit D-2
Draft Environmental Impact Report
Response to Comments
&LW\&RXQFLO:

Costco Commercial Center Project
Final Environmental Impact Report
Fresno Costco
Commercial Center
Project
State Clearinghouse No. 2021100443
Prepared for:

Planning and Development Department
January 2024
Final Environmental Impact Report
Fresno Costco Commercial Center Project
State Clearinghouse No. 2021100443
Prepared for:

Planning and Development Department
2600 Fresno Street, Third Floor, Room 3043
Fresno, California 93721
Contact:

Jose Valenzuela
Supervising Planner
559.621.8070
Prepared by:

Ascent Environmental
455 Capitol Mall, Suite 300
Sacramento, CA 95814
Contact:

Jessica Babcock
Project Manager
916.444.7301
January 2024
20210052.01

City of Fresno
Costco Commercial Center Project Final EIR i

TABLE OF CONTENTS
SSectionn Page
LISTT OFF ABBREVIATIONSS ............................................................................................................................................................................ II 11 INTRODUCTIONN ......................................................................................................................................................................... 1-1 22 RESPONSESS TOO COMMENTSS .................................................................................................................................................2-1 33 REVISIONSS TOO THEE DRAFTT EIRR .............................................................................................................................................. 4-1 44 REFERENCESS ...............................................................................................................................................................................5-1 55 LISTT OFF PREPARERSS ..................................................................................................................................................................6-1 Appendices
A Urban Decay Impact Memorandum
B Netting Report
Figures
Figure 1-1 Project Location ..................................................................................................... ............................................................1-2 Figure 1-2 Revised Site Plan.................................................................................................... ............................................................1-5 Figure 2-1 Photometric Plan..................................................................................................... .....................................................2-163 Tables
Table 2-1 List of Commenters.................................................................................................... .......................................................2-1

City of Fresno
ii Costco Commercial Center Project Final EIR

LIST OF ABBREVIATIONS
Caltrans California Department of Transportation
CAPCOA California Air Pollution Control Officers Association CARB California Air Resources Board
CCR California Code of Regulations
CDFW California Department of Fish and Wildlife
Central Valley RWQCB Central Valley Regional Water Quality Control Board CEQA California Environmental Quality Act
COG Council of Governments
dB decibels
Draft EIR draft environmental impact report
EV electric vehicle
Final EIR final environmental impact report
FMFCD Fresno Metropolitan Flood Control District
GHG greenhouse gas
GHGRP City of Fresno Greenhouse Gas Reduction Plan
ITP incidental take permit
L
eq Equivalent Continuous Sound Level
PG&E Pacific Gas and Electric Company
PRC Public Resources Code
project Costco Commercial Center
RTP/SCS Regional Transportation Plan/Sustainable Communities Strategy SB Senate Bill
SENL single-event noise level
SJVAPCD San Joaquin Valley Air Pollution Control District SR State Route
SWRCB State Water Resource Control Board
TDM Transportation Demand Management
TIA transportation impact analysis
UWMP urban water management plan
VMT vehicle miles traveled
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Costco Commercial Center Project Final EIR 1-1
1 INTRODUCTION
This final environmental impact report (Final EIR) has been prepared by the City of Fresno, as lead agency, in accordance with the requirements of the California Environmental Quality Act (CEQA) and the State CEQA Guidelines (CCR Section 15132). This Final EIR contains responses to comments received on the draft environmental impact report (Draft EIR) for the Costco Commercial Center (project). The Final EIR consists of the Draft EIR and this document (response to comments document), which includes comments on the Draft EIR, responses to those comments, and revisions to the Draft EIR.

1.1 PURPOSE AND INTENDED USES OF THIS FINAL EIR
CEQA requires a lead agency that has prepared a Draft EIR to consult with and obtain comments from responsible and trustee agencies that have jurisdiction by law with respect to the project, and to provide the public with an opportunity to comment on the Draft EIR. The Final EIR is the mechanism for responding to these comments. This Final EIR has been prepared to respond to comments received on the Draft EIR, which are reproduced in this document; and to present corrections, revisions, and other clarifications and amplifications to the Draft EIR, including project updates, made in response to these comments and as a result of the applicant’s ongoing planning and design efforts. The Final EIR will be used to support the City’s decision regarding whether to approve the Costco Commercial Center project.

This Final EIR will also be used by CEQA responsible and trustee agencies to ensure that they have met their requirements under CEQA before deciding whether to approve or permit project elements over which they have jurisdiction. It may also be used by other state, regional, and local agencies that may have an interest in resources that could be affected by the project or that have jurisdiction over portions of the project.

Responsible, trustee, and interested agencies may include:

X State Water Resource Control Board,
X Central Valley Regional Water Quality Control Board,
X San Joaquin Valley Air Pollution Control District, and X Fresno Metropolitan Flood Control District.

1.2 SUMMARY DESCRIPTION OF THE PROJECT

1.2.1 Project Location
The project site is a 22.4-acre parcel located at the northeast corner of the intersection of West Herndon Avenue and North Riverside Drive in the city of Fresno. The project site is bordered by the unbuilt right-of way of West Spruce Avenue to the north, the right-of-way of (currently unbuilt) North Arthur Avenue to the east, West Herndon Avenue to the south, and North Riverside Drive to the east (Figure 1-1).

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Source: Adapted by Ascent Environmental in 2021.

FFigure 1-1 Project Location

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1.2.2 Project Objectives
The State CEQA Guidelines require that an EIR include a statement of objectives for the project and that the objectives include the underlying purpose of the project. The following is a list of project objectives:

X Construct and operate a new membership-only Costco Commercial Center northwest Fresno that serves the local community with a wide variety of goods and services from both nationally known businesses and regional and local businesses.

X Locate the new membership-only Costco Commercial Center in a location that is convenient for its members, the community, and employees to travel to for shopping and working.

X Locate the new membership-only Costco Commercial Center in an area serviced by adequate existing infrastructure, including roadways and utilities.

X Establish a facility of sufficient size to provide a state-of-the-art facility that integrates several services, including home and/or business delivery service, under one roof.

X Meet demand for automobile services, including gasoline, car wash, and tire center.

X Create a commercial use with architecture designed to facilitate integration with the overall design context for an area, including the surrounding community.

X Reduce energy consumption by incorporating sustainable design features and systems with enhanced energy efficiencies meeting State and federal requirements.

X Continue and increase big-box retail store sales tax revenues received by the City.

X Improve availability of integrated retail sales of goods and services in the northwest area of Fresno.

X Minimize circulation conflicts between automobiles and pedestrians for retail stores and gas stations.

1.2.3 Characteristics of the Project

COSTCO WAREHOUSE BUILDING
The proposed Costco building would occupy 219,126 square feet, of which approximately 24,000 square feet would be reserved for storage and receiving. The sales floor area would include a tire center, optical exams and optical sales, hearing aid testing and sales, pharmacy, food service preparation and sales, meat preparation and sales, bakery and sales of baked goods, and alcohol sales. In addition to the general sales floor, the southwest portion of the warehouse would contain an area for receiving, storing, and loading big and bulky items for Costco’s home delivery program.

COSTCO GAS STATION
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 13,000 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. The gas station would also have eight stacking lanes, allowing approximately 40 cars to wait for pumps at any given time in addition to the 32 cars at the dispensers. The dispensers would be fully automated and self-service. Four underground fuel tanks would also be installed at the southern edge of the gas station. Lights would be recessed into the canopy to provide both lighting during operating hours and a lower level of security lighting after hours.

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COSTCO CAR WASH
A Costco members-only automated carwash would be located at the northwest corner of the project site, adjacent to the gas station. The car wash facility would include only the automated car wash within the structure. Wash water would be recycled. No self-service car vacuum stations would be provided.

PEDESTRIAN TRAILS AND BIKE PATHS
The project would include construction of 12-foot-wide pedestrian and bicycle paths along the project’s frontage with West Herndon Avenue and North Riverside Drive. These facilities would be consistent with the City’s Active Transportation Plan.

OFF-SITE ROADWAY IMPROVEMENTS
The project would include adjustments to the configuration of the southbound turn lanes on North Riverside Drive and North Golden State Boulevard to accommodate additional vehicle traffic turning onto West Herndon Avenue.

The project would also include the construction of North Arthur Avenue along the eastern edge of the project site and the construction of West Spruce Avenue from North Riverside Drive to the intersection with North Sandrini Avenue.

PROPOSED DESIGN REFINEMENTS
Since publication of the Draft EIR, the applicant has proposed several minor refinements to the project design.

Overall, the changes result in a reduced building footprint for the warehouse retail and car wash components of the project, as described in further detail below. The revised site plan is provided as Figure 1-2.

X RReduced Warehouse Size: The size of the warehouse would be reduced by 22,216 square feet by adjusting the northern wall of the warehouse structure approximately 54 feet south of the plan lines shown in Figure 2-8 of the Draft EIR. As revised, the total warehouse retail building footprint would be 219,126 square feet.

X Design of Warehouse Entry: The entry canopy at the northwestern corner of the building would be designed with a 45-degree angle, rather than a 90-degree angle as depicted in previous plans.

X Shorter Car Wash Tunnel: The layout of the car wash building would also be refined, including a reduction of the proposed tunnel length, from 170 feet to 140 feet.

X Parking Lot Design Changes: Finally, the curb cuts on North Arthur Avenue would be revised to reduce potential for cut-through traffic between North Arthur Avenue and North Riverside Avenue in front of the warehouse entrance. As a result of these changes, the number of parking stalls would increase from 869 to 873.

The proposed changes to the project design do not affect the analysis or conclusions in the Draft EIR and the potential environmental effects of the project are unaffected.

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Source: Adapted by Ascent Environmental in 2021.

FFigure 1-2 Revised Site Plan

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1.3 MAJOR CONCLUSIONS OF THE ENVIRONMENTAL ANALYSIS
The Draft EIR identified the following significant impacts related to the project:

X Impact 3.11-1: Generation of a substantial temporary increase of construction noise levels in excess of applicable standards
X Impact 3.13-2: Conflict or Be Inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b) Regarding Vehicle Miles Traveled
X Impact 3.13-3: Substantially Increase Hazards Due to a Geometric Design Feature (e.g., Sharp Curves or Dangerous Intersections) or Incompatible Uses (e.g., Farm Equipment) X Impact 4-13: Cumulative Transportation Impacts

1.4 CEQA PUBLIC REVIEW PROCESS
On July 11, 2023, the City released the Draft EIR for public review and comment. The Draft EIR was submitted to the State Clearinghouse for distribution to reviewing agencies; posted on the City’s website (https://www.fresno.gov/planning/plans-projects-under-review/#tab-14); and was made available at the Planning and Development Department (2600 Fresno Street, Room 3043). The document was also available for review at the Teague Branch Library (4718 N Polk Avenue). A notice of availability of the Draft EIR was published in the Fresno Bee.

As a result of these notification efforts, written and verbal comments were received from two state agencies (California Department of Fish and Wildlife and California Department of Transportation) and one local agency (San Joaquin Valley Air Pollution Control District), an organization representing the project applicant, and individuals.

Chapter 2, “Responses to Comments,” identifies these commenting parties, their respective comments, and provides responses to these comments. None of the comments received, or the responses provided, constitute “significant new information” by CEQA standards (State CEQA Guidelines CCR Section 15088.5).

1.5 ORGANIZATION OF THE FINAL EIR
This Final EIR is organized as follows:

CChapter 1, “Introduction,” describes the purpose of the Final EIR, summarizes the Costco Commercial Center project and the major conclusions of the Draft EIR, provides an overview of the CEQA public review process, and describes the content of the Final EIR.

Chapter 2, “Responses to Comments,” contains a list of all parties who submitted comments on the Draft EIR during the public review period, copies of the comment letters received, and responses to the comments.

Chapter 3, “Revisions to the Draft EIR,” presents revisions to the Draft EIR text made in response to comments, or to amplify, clarify or make minor modifications or corrections. Changes in the text are signified by strikeouts where text is removed and by underline where text is added.

Chapter 4, “References,” identifies the documents used as sources for the analysis.

Chapter 5, “List of Preparers,” identifies the lead agency contacts as well as the preparers of this Final EIR.

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2 RESPONSES TO COMMENTS
This chapter contains comment letters received during the public review period for the Draft EIR, which concluded on August 28, 2023. In conformance with Section 15088(a) of the State CEQA Guidelines, written responses were prepared addressing comments on environmental issues received from reviewers of the Draft EIR.

2.1 LIST OF COMMENTERS ON THE DRAFT EIR
Table 2-1 presents the list of commenters, including the numerical designation for each comment letter received, the author of the comment letter, and the date of the comment letter.

Table 2-1 List of Commenters
LLetter No. CCommenter DDate

AAGENCIES
A1 California Department of Fish and Wildlife August 14, 2023 A2 California Department of Transportation August 15, 2023 A3 San Joaquin Valley Air Pollution Control District August 23, 2023

OORGANIZATIONS
O1 Burke, Williams & Sorensen, LLP, on behalf of Costco Wholesale August 28, 2023 1

IINDIVIDUALS
I1 Matthew Schellenberg July 21, 2023
I2 Teresa Sanchez July 21, 2023
I3 Dolores Davidian July 19, 2023
I4 Vernon Valmonte July 18, 2023
I5 Denise King July 17, 2023
I6 Sharon Ross July 17, 2023
I7 Susan Hansen July 17, 2023
I8 Claudia Readwright July 17, 2023
I9 Shahzaib Zaman July 17, 2023
I10 Tj Atwal July 17, 2023
I11 Rey Alvarez July 17, 2023
I12 Agnes Habellion July 16, 2023
I13 Linnea and David Faeth July 16, 2023
I14 Alana L. Lewis July 16, 2023
I15 Sharon Henson July 16, 2023
I16 Jeannette Correa July 16, 2023
I17 Dantenello Velasquez July 15, 2023
I18 Randy Ames July 15, 2023
I19 Kiersten Winrow July 14, 2023
I20 Joseph Pulido July 14, 2023
I21 Jeremy Bruno July 14, 2023
I22 Bob Eurich July 14, 2023
I23 Sukhi Dhillon July 14, 2023
I24 Sakit Bibra July 14, 2023
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LLetter No. CCommenter DDate
I25 Anya Ellis July 14, 2023
I26 Michael and Joan Paine July 14, 2023
I27 Bekah Bryant July 14, 2023
I28 Randy Mills July 13, 2023
I29 William and Melody Hardaway July 13, 2023
I30 Geoff J. July 13, 2023
I31 Birdevinder July 13, 2023
I32 Bryan Miller July 13, 2023
I33 Colton Metzler July 13, 2023
I34 Ty Murphy July 13, 2023
I35 Jax Ward July 13, 2023
I36 Elizabeth Mendoza July 13, 2023
I37 J. Chmielewski July 13, 2023
I38 Kent Yamaguchi July 13, 2023
I39 Nick Quisenberry July 13, 2023
I40 Don Marshall July 13, 2023
I41 Jerry Montejano July 13, 2023
I42 William Duane Peverill July 21, 2023
I43 Lorraine Arrington July 21, 2023
I44 Dr. Danielle Biggs July 21, 2023
I45 Holden Markwith July 21, 2023
I46 David Scott July 22, 2023
I47 Amy Siliznoff July 22, 2023
I48 Betty Williams July 22, 2023
I49 Jensen Vang July 22, 2023
I50 Melody Wolverton July 22, 2023
I51 Joseph Pulido July 22, 2023
I52 John Olszowka July 23, 2023
I53 Justin Latham July 23, 2023
I54 Charles Ognibene July 23, 2023
I55 Jamey Schmidt July 24, 203
I56 William Duane Peverill July 24, 2023
I57 Lorraine Arrington July 24, 2023
I58 Pat Yaralian July 25, 2023
I59 Michael Van July 25, 2023
I60 Sabrina Hernandez July 26, 2023
I61 Javier Morales July 27, 2023
I62 James and Louisa Weyant July 27, 2023
I63 Shirley Hutchison July 27, 2023
I64 Maria Leon July 27, 2023
I65 Norman S. Stahl July 27, 2023
I66 Jesus Diaz July 27, 2023
I67 Anthony Scheideman July 27, 2023
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LLetter No. CCommenter DDate
I68 Rick and Kathy Haskill July 28, 2023
I69 Kevin Cartwright July 28, 2023
I70 Adalino July 28, 2023
I71 Juan Duran July 28, 2023
I72 Miguel Duran July 28, 2023
I73 Fabrizio Robalino July 31, 2023
I74 Celso “Sal” Romero, Jr. July 31, 2023
I75 Cindy Diaz August 1, 2023
I76 Joy Hinrichsen August 2, 2023
I77 Garrett Schaefer August 3, 2023
I78 Lynda Allison Doty August 8, 2023
I79 Tom Basset August 8, 2023
I80 Beth Durbin August 9, 2023
I81 Sandra J. Iley August 9, 2023
I82 Stephanie S. August 10, 2023
I83 Thomas Coppin August 10, 2023
I84 Dawn Mathews August 10, 2023
I85 Larry Rodriguez August 11, 2023
I86 Sylvia Fernandez August 11, 2023
I87 Jens Andersen August 13, 2023
I88 Richee Xavonglianekham August 14, 2023
I89 Janet Bergman August 15, 2023
I90 Robin Snowden August 17, 2023
I91 Shauna Sandin August 18, 2023
I92 Charles Yuvienco August 19, 2023
I93 Darius Assemi August 21, 2023
I94 Noel Delgado August 21, 2023
I95 Ray Gonzales August 24, 2023
I96 Jennifer Airheart August 24, 2023
I97 Amy Zehring August 25, 2023
I98 Brian and Sherryl Kellogg August 24, 2023
I99 Rodger B. Jensen August 25, 2023
I100 James Fleck August 28, 2023
I101 Gabriel Ledesma August 28, 2023
I102 Lauryn Medina September 1, 20231
I103 Daniel Brannick August 31, 2023 1
1 The comment was received after the close of the public comment period.

2.2 COMMENTS AND RESPONSES
The written individual comments received on the Draft EIR and the responses to those comments are provided below. The comment letters are reproduced in their entirety and are followed by the response(s). Where a commenter has provided multiple comments, each comment is indicated by a line bracket and an identifying number in the margin of the comment letter.

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2.2.1 Agencies

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Letter A1 California Department of Fish and Wildlife
Julie A. Vance, Regional Manager
August 14, 2023
Response A1-1
The comment provides introductory remarks and states that the California Department of Fish and Wildlife (CDFW), by law, may be required to carry out or approve through the exercise of its own regulatory authority under Fish and Game Code. Page 2-21 of the Draft EIR identifies CDFW as a trustee agency that has jurisdiction over resources potentially affected by the project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response A1-2
The comment states that CDFW concurs with the analysis related to biological resources and determined that the mitigation measures identified in the Draft EIR are sufficient to mitigate impacts to listed species. In addition, the comment states that consultation with CDFW is recommended and an incidental take permit (ITP) would be required if take of listed species cannot be avoided. Mitigation Measure 3.5-1b, described on pages 3.5-15 and 3.5-16 of the Draft EIR, requires the project proponent to retain a qualified biologist to implement avoidance buffers around active nest sites of listed or fully protected species (e.g., Swainson’s hawk and white-tailed kite) in consultation with CDFW and conduct periodic monitoring of these sites during project construction. Implementation of Mitigation Measure

3.5-1b would avoid incidental take of Swainson’s hawk, white-tailed kite, and other nesting raptors; therefore, it is not anticipated that an ITP would be needed for the project. No revisions to the Draft EIR are necessary in response to this comment.

Response A1-3
The comment recommends that surveys for Swainson's Hawk, white-tailed kite, and other raptors be conducted by a qualified biologist with knowledge of Swainson’s hawk natural history and behaviors and following the survey methods developed by the Swainson’s Hawk Technical Advisory Committee. Mitigation Measure 3.5-1b, described on pages 3.5-15 and 3.5-16 of the Draft EIR, states that nesting bird surveys will be conducted by a qualified biologist familiar with birds of California and with experience conducting nesting bird surveys. The qualified biologist would be required to follow survey protocols promulgated by CDFW. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response A1-4
The comment provides closing remarks, resources with additional information, and the CDFW contact for coordination in connection with the project. This comment is not related to the adequacy of the CEQA document. No further response is required.

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Letter A2 California Department of Transportation
Dave Padilla, Branch Chief
August 15, 2023
Response A2-1
The comment provides introductory remarks, a summary of the proposed project, and a description of the California Department of Transportation’s (Caltrans’) mission and review process. The comment is not related to the adequacy of the CEQA document. No further response is required.

Response A2-2
The comment summarizes the findings of the transportation impact analysis (TIA), stating that the project would not have a significant safety impact on state facilities and that there is adequate length on existing facilities for project- related queuing. The comment does not offer any specific concern related to the adequacy of the TIA or Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response A2-3
The comment identifies a new interchange that is being constructed along State Route 99 at Veterans Boulevard, which is projected to reduce traffic volumes in the project vicinity. This comment does not address the adequacy of the Draft EIR analysis; therefore, no further response is required. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response A2-4
The comment recommends that the project proponent contribute to a local impact fee program to fund future infrastructure improvements “necessary to complement future SR 99 facility safety improvements” being completed by Caltrans (see Comment A2-3). The City of Fresno’s citywide development impact fees include funds for transportation projects. This comment does not address the adequacy of the Draft EIR analysis; therefore, no further response is required.

Response A2-5
The comment identifies the net increase in vehicle miles traveled (VMT) that would result from the project and restates the conclusion from the TIA and Draft EIR that the project will have a significant and unavoidable impact related to VMT. This comment does not offer any specific concern related to the adequacy of the TIA or Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response A2-6
The comment recommends that alternative transportation policies be applied to the project and an assessment of multi-modal facilities be conducted to identify improvements to alleviate traffic congestion caused by the project. As described below in Response A2-7, the project would include construction of the elements of the City of Fresno Active Transportation Plan that are planned adjacent to the project site and all applicable alternative transportation policies would be applied to the project.

For a full discussion of the project’s consistency with programs, plans, and ordinances related to transit, bicycle, and pedestrian facilities, refer to Impact 3.13-1 in Section 3.13, “Transportation and Circulation,” of the Draft EIR. As summarized on page 3.13-12:

The nature of bulk shopping and auto-oriented services at the Costco facility does not lend itself to substantially increased transit ridership. Additionally, the proposed project would not conflict with any existing transit stops. Furthermore, off-site bicycle and pedestrian improvements could enhance first/last mile connections for transit riders using the bus stops in the vicinity of the proposed project. The proposed project would provide short-term bicycle parking as required by the City Municipal Code (Article 24, Section 15-2429). Consistent with the City of Fresno’s ATP, the proposed project involves the construction of off-site Class I bicycle facilities along the proposed project frontage on West Herndon Avenue and North Riverside Drive and Class II bicycle facilities along newly constructed Spruce Avenue.

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This comment does not raise issues related to the adequacy of the Draft EIR analysis; therefore, no further response is required. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response A2-7
The comment recommends that the project installs the bike paths along Herndon Avenue and Riverside Avenue as identified in the City of Fresno Active Transportation Plan 2016. As indicated in Chapter 2, “Project Description,” of the Draft EIR, the project would include construction of these facilities. This comment does not address the adequacy of the Draft EIR analysis; therefore, no further response is required. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response A2-8
The comment recommends that the project coordinate connections to regional pathways. As indicated above in Responses A2-6 and A2-7, the project would provide connections to regional bikeways. This comment does not address the adequacy of the Draft EIR analysis; therefore, no further response is required. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response A2-9
The comment recommends that the project implement multimodal strategies such as those associated with transit- oriented development, to reduce traffic-related impacts. The comment does not specify any potential strategies.

Transit-oriented development strategies are typically integrated at the plan or community scale and are not applicable to individual commercial projects. Further, as explained in the Draft EIR (see page 3.13-18), the nature of the proposed Costco as a bulk good seller further limits the applicability and effectiveness of transit as a proposed mode of transportation to reduce traffic and VMT because the primary source of daily VMT is warehouse shopping by Costco members and the nature of Costco’s land use and business model is auto oriented. Members purchase items in bulk at Costco facilities, making walking, biking, or transit trips to the warehouse impractical. This comment does not address the adequacy of the Draft EIR analysis; therefore, no further response is required. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response A2-10
The comment recommends that the project “implement ‘smart growth’ principles regarding parking solutions, providing alternative transportation choices to residents and employees.” As examples of such programs, the comment identified “parking for carpools/vanpools, car-share, and/or ride-share programs.” The project does not include a residential component, and no residential parking is planned.

Through application of Mitigation Measure 3.13-2, the project applicant would be required to develop a commute reduction program for employees. Specific actions that may be incorporated into this program include designating a certain percentage of desirable parking spaces for ridesharing vehicles. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response A2-11
The comment recommends that the project proponent continue to work with the City to implement further improvements to reduce VMT and offer alternate transportation modes for employees. Through application of Mitigation Measure 3.13-2, the project applicant would implement a commute reduction program for employees.

Refer to Impact 3.13-2 (Draft EIR pages 3.13-13 through 3.13-18) for further information. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Response A2-12
The comment recommends that the project provide electric vehicle parking. As stated on page 2-14 of the Draft EIR, the project includes 53 electric vehicle-ready parking stalls. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response A2-13
The comment states that the City should consider requiring the project proponent to provide charging stations for freight trucking to reduce greenhouse gas (GHG) emissions, reduce freight parking shortages, and maintain the Federal Hours of Service regulations. As described on pages 3.7-11 through 3.7-13 of the Draft EIR, the project would not generate GHG emissions in a manner that would have a significant impact on the environment or that would conflict with the applicable GHG reduction plan adopted by the City or result in significant and unavoidable air quality impacts. Therefore, mitigation requiring the provision of charging stations for freight trucking is not warranted and no revisions to the Draft EIR are necessary in response to this comment.

Response A2-14
The comment states that the City should consider requiring the project proponent to provide on-site parking for freight trucks. The operation of the project would involve both smaller box trucks associated with the market delivery operations (MDO) delivery program and semi-trucks that deliver goods to the warehouse. Approximately 17 to 20 box trucks would regularly park on-site and there are approximately 30 parking spots along Herndon Avenue that are sized for these vehicles. Semi-trucks would not park on-site. Costco’s standard operating procedure is to load and unload trucks as soon as they arrive onsite; therefore, no additional on-site truck parking would be necessary for semi-trucks. This suggestion is unrelated to the analysis and conclusions in the Draft EIR. However, it is noted for the record and will be provided to decision makers for consideration.

Response A2-15
The comment recommends that the project proponent contribute to the City’s Traffic Impact Fee program. This comment is similar to Comment A2-4. Please refer to Response A2-4 above.

Response A2-16
The comment expresses Caltrans’ support for reducing VMT and GHG emissions in a manner that increases the likelihood that people will benefit from a multimodal transportation network. No comment on the analysis or conclusions in the Draft EIR is provided and no further response is required.

Response A2-17
The comment provides the Caltrans contact for coordination in connection with the project. This comment is not related to the adequacy of the CEQA document. No further response is required.

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Letter A3 San Joaquin Valley Air Pollution Control District Mark Montelongo, Program Manager
August 23, 2023
Response A3-1
The comment provides introductory statements summarizing the nature of the project. No response is required.

Response A3-2
The comment recommends that the project use the cleanest available offroad construction equipment, including the latest tier equipment (e.g., tier 4, when available) to further reduce impacts from construction-related diesel exhaust emissions. As described in Section 4.2.1 of Appendix C of the Draft EIR, the project analysis assumes construction equipment greater than 50 horsepower used at the site would meet US Environmental Protection Agency Tier 3 emission standards for PM10 and PM2.5 and include particulate matter emissions control equivalent to the California Air Resources Board (CARB) Level 3 verifiable diesel emission control devices. Based on the proposed construction practices and equipment mix, and as shown in Table 3.3-5 and Table 3.3-7 of the Draft EIR, the project impact level is less than significant for construction emissions and health-risk impacts during the construction phase. Mitigation is only required if there are significant environmental effects. (Public Resources Code [PRC] § 21100(b)(3).) An EIR is not required to discuss mitigation measures for impacts when the EIR had determined that such impacts would be less than significant. (North Coast Rivers Alliance v. Marin Municipal Water District (2013) 216 Cal.App.4th 614, 649.) Therefore, these recommendations are noted and will be provided to the decision-making body for consideration.

However, because project impacts are less than significant, there is no nexus for the City to require San Joaquin Valley Air Pollution Control District’s (SJVAPCD’s) recommendations as mitigation in this EIR.

Response A3-3
The comment summarizes review of the Air Quality Technical Report (Draft EIR Appendix C) and identifies an apparent inconsistency between the technical data and the summarized conclusions in the appendix and Draft EIR.

The City subsequently met with SJVAPCD to discuss these concerns and provide additional technical modeling data.

On September 25, 2023, SJVAPCD issued a supplemental comment letter that concurs with the finding reported in the Draft EIR that the project is not expected to have a significant impact on police health.

The analysis in Appendix C and Draft EIR Section 3.3, “Air Quality,” are based on a project commitment to use equipment with diesel particulate filters, which result in a reduction in produced particulate matter. Although the project commitment was included in the Draft EIR’s analyses, this commitment was inadvertently left out of the Draft EIR’s project description. To clarify this commitment, the following text has been added to the second paragraph of Section 2.2.4, “Construction,” (Draft EIR page 2-19) in Chapter 2, “Project Description.” This text clarifies the information provided in the Draft EIR for greater consistency with the technical analysis.

Table 2-2 lists equipment anticipated to be used during construction. All equipment used for construction would have Tier 3 engines with diesel particulate filters. In addition, approximately 325 loads of aggregate base would be imported onto the project site and approximately 3,000 cubic yards of utility and foundation spoils would be off hauled. Grading of the project site would be otherwise balanced and would not require additional import or export of soils. All staging would occur on the project site. Trucks would enter the project site from North Riverside Drive and exit the site via North Arthur Avenue.

In addition, one table in Draft EIR Appendix C reported an incorrect construction equipment mix. The corrected version of Table F-1 in the Air Quality Technical Report is provided in Chapter 2 of this Final EIR.

As documented in the supplemental comment letter, based on SJVAPCD’s review of all technical data in the record there would not be a new or more severe impact to human health risk than disclosed in the Draft EIR. No further response or revision to the Draft EIR is required.

Response A3-4
The comment provides industrial warehouse emission reduction strategies that SJVAPCD recommends to reduce the potential for harmful health effects. The project would comply with all state and local regulations for the gas station Responses to Comments Ascent
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and heavy-duty trucks. As discussed in Section 2.3 of Appendix C of the Draft EIR, the Advanced Clean Trucks regulation, Airborne Toxic Control Measures for on-road diesel vehicles and idling, and the Truck and Bus Regulation (13 California Code of Regulations [CCR] 2025) will require truck fleets to become cleaner over time and electrify as the technology becomes feasible to support it. The project would also comply with applicable SJVAPCD and state regulations for the gasoline service station, such as Rule 4622 and installation of Phase I and Phase II vapor recovery control equipment. In addition, note that the project has been designed to incorporate the following features:

X Delivery truck travel and site entry on designated truck routes that use major roadways and avoid traversing through residential communities.

X Availability of transportation refrigeration unit (TRU) plug-ins at loading docks.

X Loading dock operating protocols to minimize truck idling and associated emissions would require that all regulations concerning idling are followed, each is unloaded efficiently, and trucks do not linger at the loading docks.

X Bicycle parking as required in the City’s Municipal Code.

X Non-emergency diesel powered generators would be prohibited during project construction.

Based on modeling that assumes these project commitments, the Draft EIR Section 3.3.3, “Environmental Impacts and Mitigation Measures,” (page 3.3-19) concludes that the project would generate less-than-significant air quality and health risk impacts during construction and operation of the project. Therefore, SJVAPCD’s recommendations are noted and will be provided to the decision-making body for consideration. However, because project impacts are less than significant, there is no nexus for the City to require SJVAPCD’s recommendations as mitigation in this EIR.

Response A3-5
The comment recommends the City evaluate Heavy Heavy-Duty truck routing patterns for the project, with the aim of limiting exposure of residential communities and sensitive receptors to emissions. The Draft EIR includes a health risk assessment that evaluates the emissions from trucks as they approach and depart the project site. The truck routes utilize the most efficient truck routes wherever possible, taking into consideration City-designated truck routes, intersection traffic controls, turn radii at intersections and site accesses, and direction of approach to destinations within the site. The truck routes are identified to minimize impact to surrounding residential areas or sensitive receptors, and to efficiently enter and exit the project site. As shown in Table 3.3-7 of the Draft EIR, the project would result in less-than-significant health risk impacts, demonstrating that there will not be a significant impact resulting from the trucks entering and exiting the project site. The travel routes are shown in Figure 2 of Appendix C of the Draft EIR.

Response A3-6
The comment recommends that the City consider two measures to reduce project-generated operational emissions:
use of the cleanest available truck fleet and on-site service equipment. As explained in Response A3-4, Advanced Clean Trucks regulation, Airborne Toxic Control Measures for on-road diesel vehicles and idling, and the Truck and Bus Regulation (13 CCR 2025) will require truck fleets to become cleaner over time and electrify as the technology becomes feasible to support it. In addition, the project would employ electric forklifts, mobility carts, pallet jacks, scissor lifts, floor scrubbers, lift trucks, and combilifts consistent with the recommendation.

Further, any additional mitigation measures in the form of requiring low and zero emission trucks is not required, as operation of these vehicles has not been determined to result in an environmental impact. Mitigation is only required if there are significant environmental effects. (PRC § 21100(b)(3).) An EIR is not required to discuss mitigation measures for impacts when the EIR had determined that such impacts would be less than significant. (North Coast Rivers Alliance v. Marin Municipal Water District (2013) 216 Cal.App.4th 614, 649.) Therefore, SJVAPCD’s recommendations are noted and will be provided to the decision-making body for consideration. However, because project impacts are less than significant, there is no nexus for the City to require SJVAPCD’s recommendations as mitigation in this EIR.

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Response A3-7
The comment recommends that the Draft EIR “include measures to ensure compliance of the state anti-idling regulation (13 CCR § 2485 and 13 CCR § 2480) and discuss the importance of limiting the amount of idling, especially near sensitive receptors. In addition, the District recommends the City consider the feasibility of implementing a more stringent 3-minute idling restriction and requiring appropriate signage and enforcement of idling restrictions.” See Response A3-4. The project would comply with the CARB Air Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling, which is also referred to as 13 CCR § 2485 as referenced by the comment. More specifically, in order to meet the required truck idling limit of 5 minutes, the project includes measures such as posting of appropriate signage at docks delivery areas, each truck to be unloaded efficiently, trucks to not linger at the loading docks, and truck routes that result in efficient traffic flow through the project site to limit truck idling.

The project would result in less-than-significant operational emissions. An EIR is not required to discuss mitigation measures for impacts when the EIR had determined that such impacts would be less than significant. (North Coast Rivers Alliance v. Marin Municipal Water District (2013) 216 Cal.App.4th 614, 649.) Therefore, these recommendations are noted and will be provided to the decision-making body for consideration. However, because project impacts are less than significant, there is no nexus for the City to require SJVAPCD’s recommendations as mitigation in this EIR.

Response A3-8
The comment “recommends the City consider the feasibility of incorporating vegetative barriers and urban greening as a measure to further reduce air pollution exposure on sensitive receptors.” The Draft EIR Section 3.3.3, “Environmental Impacts and Mitigation Measures,” (page 3.3-19) concludes that the project would result in less than significant air quality and health risk impacts during construction and operation of the project. Mitigation is only required if there are significant environmental effects. (PRC § 21100(b)(3).) An EIR is not required to identify mitigation measures for impacts when the EIR had determined that such impacts would be less than significant. (North Coast Rivers Alliance v. Marin Municipal Water District (2013) 216 Cal.App.4th 614, 649.) Further, the project would incorporate vegetation and tree canopy improvements for the site. These include perimeter landscaping along the edges of the project site, as well as landscaping within the parking field. Therefore, the project has incorporated this recommendation, and further mitigation is not required.

Response A3-9
The comment suggests that the City consider incorporating solar power systems as an emission reduction strategy for the project. Costco participates in the PG&E Solar Choice program, which provides 100 percent solar energy to customers, as discussed in Section 3.6 and Section 3.7 of the Draft EIR. The project would also comply with energy efficiency standards of the State’s Title 24 California Building Code, which includes a solar-ready roof of the proposed Costco warehouse.

Beyond this specific project, Costco is investing in a sustainable future and implements many measures and programs to that end (see https://www.costco.com/sustainability-introduction.html). For example, Costco owns and operates more than 100 on-site solar systems around the world, with an intention to expand on-site solar operations; having a solar-ready roof on the warehouse of the Costco warehouse will ensure that Costco can install solar panels here in the future.

As shown in Table 3.3-8 of the Draft EIR, the project’s air quality impacts during operation would be less than significant (see Impact 3.3-5, page 3.3-25). In addition, the Draft EIR determines in Impact 3.6-1 related to inefficient and unnecessary consumption of energy and Impact 3.6-2 related to conflict with a plan for renewable energy or energy efficiency that the project would have less-than-significant impacts related to energy consumption. Therefore, these recommendations are noted and will be provided to the decision-making body for consideration. However, because project impacts are less than significant, there is no nexus for the City to require SJVAPCD’s recommendations as mitigation in this EIR.

Response A3-10
The comment notes that SJVAPCD recommends installation of electric vehicle chargers at project sites, generally, and identifies that the Draft EIR indicates that the project would include electric vehicle charging stations. The project is Responses to Comments Ascent
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committed to constructing and maintaining electric vehicle (EV) chargers in accordance with Part 11 of the 2022 Title 24 California Building Code, as noted on page 3.7-11 of the Draft EIR. A total of 45 EV chargers will be installed, which aligns with the 2022 Title 24 standard of 5 percent of all parking stations equipped with a Level 2 charging station at a minimum. This comment does not address the adequacy of the Draft EIR analysis; therefore, no further response is required. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response A3-11
The comment notes that the project includes construction of bikeways and may be eligible for funding through the District’s Bikeway Incentive Program. Because the comment does not raise a substantive issue or provide a recommendation on the content of the Draft EIR, no further response is warranted. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response A3-12
The comment summarizes district rules and regulations that reduce the effect of projects on air quality. Costco will be required to comply with all applicable District rules and regulations governing construction and operation of the project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no further response is required. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response A3-13
The comment recommends that a copy of this letter is provided to the project proponent. All letters received on the Draft EIR have been posted to the City’s website (https://www.fresno.gov/planning/plans-projects-under-review/) and are available for public review and download. This comment does not address the adequacy of the Draft EIR analysis; therefore, no further response is required.

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2.2.2 Organizations

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Letter O1 Burke, Williams & Sorensen, LLP, on behalf of Costco Wholesale Anna C. Shimko, Partner
August 28, 2023
Response O1-1
The comment provides introductory remarks. This comment includes a statement that supports the adequacy of the CEQA document. No further response is required.

Response O1-2
The comment summarizes the mitigation approach in the Draft EIR and requests refinement to the language in Mitigation Measure 3.13-2 to clarify that the applicant’s obligation to ensure VMT trip reduction through the employee trip reduction measures. The requested addition of “designed to” has been added to the mitigation measure. See Response O1-3 for the full text of the revised mitigation measure.

This revision clarifies the City’s intended approach to implementation of Mitigation Measure 3.13-2 and does not affect the severity of the impact disclosed in the Draft EIR. Pursuant to State CEQA Guidelines Section 15088.5, recirculation of the Draft EIR is not required.

Response O1-3
The comment asserts that an employer-sponsored vanpool cannot be included as a component of the Transportation Demand Management (TDM) program required in Mitigation Measure 3.13-2 because of concerns related to insurance liability, equality, and policing the parameters of use. The comment also questions the applicability of the program because it is described as a form of “public” transportation in the Draft EIR and requests that less VMT reduction is required based on the infeasibility of the vanpool.

As explained in the Draft EIR (page 3.13-18):

Mitigation Measure 3.13-2 would implement Measure T-6 (Mandatory Commute Reduction Program), as identified in the Handbook for Analyzing Greenhouse Gas Emissions Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (CAPCOA 2021). The implementation of Mitigation Measure

3.13-2 would reduce employee trips. However, employee trips account for 436 daily trips (less than 2 percent of the total daily trips) and 13,385 VMT (approximately 7 percent of the daily VMT). Based on the California Air Pollution Control Officers Association’s estimates in the Quantifying Greenhouse Gas Mitigation Measures Handbook, Mitigation Measure 3.13-2 could achieve up to a 26 percent reduction in project employee commute VMT (CAPCOA 2021: 86). Implementation of a mandatory commute reduction program with 100 percent employee participation would only result in a 3,480-mile decrease, or less than 2 percent of the proposed project’s total daily regional VMT.

The City based the mitigation strategy and language on the California Air Pollution Control Officers Association (CAPCOA) Handbook. The CAPCOA Handbook describes employer-sponsored vanpool (Measure T-11) as “a flexible form of public transit” that can be applied at the project site scale and is best implemented and monitored by the building occupant or employer. Therefore, the wording in the Draft EIR is consistent with applicable guidance and does not improperly characterize the vanpool as a service for the general public. No revision to the Draft EIR is necessary.

Table 3.13-5 of the Draft EIR presents the most recent CAPCOA measures for reducing greenhouse gas emissions within the transportation sector and identifies potentially feasible mitigation to reduce VMT that were derived from the Handbook. The City established the target of a 26 percent reduction in employee VMT based on the maximum potential VMT reduction provided in the CAPCOA Handbook for Commute Trip Reduction Programs (Measure T-6).

As explained in the CAPCOA Handbook, this total amount accounts for the potential reductions that could be achieved through the implementation of Measures T-7 through T-11.

Based on the information provided in Comment O1-3, the City has determined that revisions to Table 3.13-5 are required to reflect measures that may be feasibly implemented. As revised, the measure excludes CAPCOA Responses to Comments Ascent
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Handbook TDM Measure T-11 – Provide Employer-Sponsored Vanpool, and, therefore, excludes CAPCOA Handbook TDM Measure T-6 – Implement Commute Trip Reduction Program (Mandatory), of which Measure T-11 is a component. However, the City has identified other project requirements that would be equally effective at reducing VMT. The City concludes that the established 26 percent reduction in employee VMT can be achieved and has not revised this benchmark for compliance as requested in the comment.

The discussion of Mitigation Measure 3.13-2 in the Draft EIR is, therefore, revised as follows:

Mitigation Measures
Table 3.13-3 presents the most recent California Air Pollution Control Officers Association (CAPCOA) Handbook for Analyzing GHG Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (Handbook) measures for reducing greenhouse gas emissions within the transportation sector.

Most of the measures quantified in the CAPCOA Handbook aim to reduce VMT and encourage mode shifts from single-occupancy vehicles to shared (e.g., transit) or active modes of transportation (e.g., bicycle) (CAPCOA 2021). Although all transportation measures are provided below, not all are applicable or feasible given the implementation scale, nature of the proposed project, and/or limited jurisdictional authority of Costco, the applicant, to implement particular measures. The following mitigation measures have been proposed is based on the analysis of feasibility and applicability included in Table 3.13-5.

Table 3.13-5 Transportation Sector Measures to Reduce VMT MMitigation Measure MMaximum Potential VMT
RReduction11
Feasible/Applicable
to the project? Notes
T-1 Increase Residential
Density
30% from project VMT N/A The proposed project does not include residential uses.

T-2 Increase Job Density 30% from project VMT N/A This is a plan/communitywide strategy and is not applicable.

T-3 Provide Transit-Oriented
Development
31% from project VMT N/A This is a plan/communitywide strategy and is not applicable.

T-4 Integrate Affordable and
Below Market Rate
Housing

28.6% from project/site
multifamily residential VMT
N/A The proposed project does not include
residential uses.

T-5 Implement Commute Trip
Reduction Program
(Voluntary)
4% project/site employee
commute VMT
Yes No See Mitigation Measure 3.13-2 below.

Measures T-7 through T-11 must be
implemented as part of T-5 to achieve the
maximum employee commute VMT
reduction. Because T-11 would not be
feasible, the commute trip reduction
program would not meet the full list of
CAPCOA parameters.

T-6 Implement Commute Trip
Reduction Program
(Mandatory
Implementation and
Monitoring)
26% from project/site
employee commute VMT
Yes No
See Mitigation Measure 3.13-2 below.

Measures T-7 through T-11 must be
implemented as part of T-6 to achieve the
maximum employee commute VMT
reduction. Because T-11 would not be
feasible, the commute trip reduction
program would not meet the full list of
CAPCOA parameters.

T-7 Implement Commute Trip
Reduction Marketing
4% project/site employee
commute VMT
Yes See Mitigation Measure 3.13-2 below.

T-8 Provide Ridesharing
Program
8% project/site employee
commute VMT
Yes See Mitigation Measure 3.13-2 below.

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MMitigation Measure MMaximum Potential VMT
RReduction11
Feasible/Applicable
to the project? Notes
T-9 Implement Subsidized or
Discounted Transit
Program

5.5% from
employee/resident
Yes See Mitigation Measure 3.13-2 below.

T-10 Provide End-of-Trip Bicycle
Facilities

4.4% project/site employee
commute VMT
Yes See Mitigation Measure 3.13-2 below.

T-11 Provide Employer-
Sponsored Vanpool

20.4% project/site
employee commute VMT
Yes No See Mitigation Measure 3.13-2 below. A
private vanpool program would involve
the capital cost of purchasing vas plus the
operating cost of insurances, would raise
liability concerns, and would pose
logistical challenges such as equal
treatment of employees and rules
regarding private use of the vans. This
measure cannot be feasibly implemented
to reduce VMT.

T-12 Price Workplace Parking 20% project/site employee
commute VMT
N/A Measure ineffective due to readily
available, uncontrolled and free parking in
the immediate vicinity of the proposed
project.

T-13 Implement Employee
Parking Cash-Out
12% project/site employee
commute VMT
N/A Measure ineffective due to readily
available, uncontrolled and free parking in
the immediate vicinity of the proposed
project.

T-14 Provide Electric Vehicle
Charging Infrastructure
-- N/A See Mitigation Measure 3.3-2a. This
measure does not affect VMT.

T-15 Limit Residential Parking
Supply

13.7% from residences’ VMT N/A The proposed project does not include residential uses.

T-16 Unbundle Residential
Parking Costs from
Property Cost

15.7% from project VMT N/A The proposed project does not include residential uses.

T-17 Improve Street
Connectivity
30% from vehicle travel in
the plan/community
Yes The proposed project would construct
West Spruce Avenue along the northern
project site boundary improving street
connectivity. Additionally, the project
would construct North Arthur Avenue
along the eastern project site boundary,
connecting West Spruce Avenue and
West Spruce Herndon Avenue. See
Chapter 2, “Project Description.,” and
Mitigation Measure 3.13-2 below.

T-18 Provide Pedestrian
Network Improvement

6.4% from vehicle travel in
the plan/community
Yes Pedestrian facility improvements provided
as part of the proposed project. See
Chapter 2, “Project Description.,” and
Mitigation Measure 3.13-2 below.

T-19-A Construct or Improve Bike
Facility

0.8% from vehicles parallel
roadways
Yes Bicycle facility improvements provided as
part of the proposed project. See Chapter
2, “Project Description.,” and Mitigation
Measure 3.13-2 below.

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MMitigation Measure MMaximum Potential VMT
RReduction11
Feasible/Applicable
to the project? Notes
T-19-B Construct or Improve Bike
Boulevard

0.2% from vehicles on
roadway
Yes Bicycle facility improvements provided as
part of the proposed project. See Chapter
2, “Project Description.,” and Mitigation
Measure 3.13-2 below.

T-20 Expand Bikeway Network 0.5% from vehicles on
roadway
Yes Bicycle facility improvements provided as
part of the proposed project. See Chapter
2, “Project Description.,” and Mitigation
Measure 3.13-2 below.

T-21-A Implement Conventional
Carshare Program

0.15% from vehicle travel in
the plan/community
No This is a plan/communitywide strategy
and is not feasible.

T-21-B Implement Electric
Carshare Program
VMT reduction not
quantified—see CAPCOA
handbook
No This is a plan/communitywide strategy
and is not feasible.

T-22-A Implement Pedal (Non-
Electric) Bikeshare Program

0.2% from vehicle travel in
the plan/community
No This is a plan/communitywide strategy
and is not feasible.

T-22-B Implement Electric
Bikeshare Program

0.06% from vehicle travel in
the plan/community
No This is a plan/communitywide strategy
and is not feasible.

T-22-C Implement Scootershare
Program

0.07% from vehicle travel in
the plan/community
No This is a plan/communitywide strategy
and is not feasible.

T-23 Provide Community-Based
Travel Planning

2.3% from vehicle travel in
the plan/community
N/A The proposed project does not include
residential uses. This measure applies to
residences.

T-24 Implement Market Price
Public Parking (On-Street)
30% from vehicle travel in
the plan/community
No The applicant, Costco, does not have
jurisdiction over public on-street parking
facilities and operation.

T-25 Extend Transit Network
Coverage or Hours

4.6% from vehicle travel in
the plan/community
No The applicant, Costco, does not have
jurisdiction over the operation of transit
service.

T-26 Increase Transit Service
Frequency

11.3% from vehicle travel in
the plan/community
No The applicant, Costco, does not have
jurisdiction over the operation of transit
service.

T-27 Implement Transit-
Supportive Roadway
Treatments

0.6% from vehicle travel in
the plan/community
No This is a plan/communitywide strategy
and is not feasible.

T-28 Provide Bus Rapid Transit 13.8% from vehicle travel in the plan/community
No The applicant, Costco, does not have
jurisdiction over the operation of transit
service.

T-29 Reduce Transit Fares 1.2% from vehicle travel in
the plan/community
No This is a plan/communitywide strategy
and is not feasible.

T-30 Use Cleaner-Fuel Vehicles -- N/A This measure does not affect VMT.

Notes:
1: The CAPCOA Handbook identifies the maximum potential GHG reduction associated with identified measures; however, the CAPCOA Handbook concludes that for the particular measures selected, the percent reduction in VMT would be the same as the percent reduction in GHG emissions. For clarity, this table reports reductions in relation to VMT.

VMT = Vehicle Miles Traveled; N/A = not applicable
Source: Mitigation Measures and VMT Reduction Potential provided by CAPCOA 2021 Handbook for Analyzing Greenhouse Gas Emissions Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity Ascent Responses to Comments
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MMitigation Measure 3.13-2: Provide a Mandatory Commute Reduction Program for to Reduce Costco Employees’ VMT by at least 26 Percent
Costco shall provide a Mandatory Commute Reduction program for employees that is designed to achieves at least a 26 percent reduction in employee VMT. The commute reduction program shall be provided to the City for approval acceptance prior to issuance of a certificate of occupancy. Specific actions may must include the following measures described in the California Air Pollution Control Officers Association’s 2021 Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity Quantifying Greenhouse Gas Mitigation Measures Handbook:

X Commute Trip Reduction Marketing (estimated to result in up to 4 percent employee VMT reduction):

Costco shall implement a marketing strategy to promote Costco’s commute reduction program.

Information sharing and marketing promote and educate employees about their travel choices to the employment location beyond driving such as carpooling, taking transit, walking, and biking, thereby reducing VMT and greenhouse gas emissions. The following features (or similar alternatives) shall be provided:
ƒ on-site or online commuter information services,
ƒ employee transportation coordinators,
ƒ on-site or online transit pass sales, and
ƒ guaranteed ride home service.

X Provide Ridesharing Program (estimated to result in up to 8 percent employee VMT reduction): Costco shall develop and implement a ridesharing program. Ridesharing encourages carpooled vehicle trips in place of single-occupied vehicle trips, thereby reducing the number of trips, VMT, and greenhouse gas emissions. The following strategies provide examples of a multifaceted approach for promoting a rideshare program:
ƒ designating a certain percentage of desirable parking spaces for ridesharing vehicles, ƒ designating adequate passenger loading and unloading and waiting areas for ridesharing vehicles, and
ƒ providing an app or website for coordinating rides.

X Implement Subsidized or Discount Transit Program (estimated to result in up to 5.5 percent employee VMT reduction): Costco shall provide free transit passes for employees. Reducing the out-of-pocket cost for choosing transit improves the competitiveness of transit against driving, increasing the total number of transit trips and decreasing vehicle trips. This decrease in vehicle trips results in reduced VMT and, thus, a reduction in greenhouse gas emissions.

X Provide End-of-Trip Bicycle Facilities (estimated to result in up to 4.4 percent employee VMT reduction):

Costco shall install and maintain end-of-trip facilities for employee use. End-of-trip facilities include elements such as bike parking, bike lockers, showers, and personal lockers. The provision and maintenance of secure bike parking and related facilities encourages commuting by bicycle, thereby reducing VMT and greenhouse gas emissions.

X Provide Employer-Sponsored Vanpool (estimated to result in up to 20.4 percent employee VMT reduction): Costco shall implement an employer-sponsored vanpool program. Vanpooling is a flexible form of public transportation that provides groups of 5 to 15 people with a cost-effective and convenient rideshare option for commuting. The mode shift from long-distance, single-occupied vehicles to shared vehicles reduces overall commute VMT, thereby reducing greenhouse gas emissions (CAPCOA 2021).

X Improve Street Connectivity (estimated to result in up to 30 percent employee VMT reduction): Costco shall construct West Spruce Avenue along the northern site boundary, creating new connections Responses to Comments Ascent
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between West Spruce Avenue and North Aurther Avenue. The increased connectivity and intersection density that would result from these improvements would facilitate shorter trips, thereby reducing VMT.

X PProvide Pedestrian Network Improvements/Construct Bike Facilities/Expand Bikeway Network (estimated to result in up to 10 percent employee VMT reduction1): Costco shall construct new, 12-foot-wide pedestrian and bicycle paths along West Herndon Avenue and North Riverside Drive to improve pedestrian access and connect to a larger bicycle network. This encourages a mode shift from automobiles to biking and walking, resulting in VMT reduction.

As revised, Mitigation Measure 3.13-2 continues to include CAPCOA Handbook TDM Measures T-7 through T-10, which are the other components of TDM Measure T-6 – Implement Commute Trip Reduction Program (Mandatory), and it further incorporates CAPCOA Handbook TDM Measure T-17 – Improve Street Connectivity, T-18 – Provide Pedestrian Network Improvement, Measure T-19-A – Construct or Improve Bike Facility, T-19-B – Construct or Improve Bike Boulevard, and Measure T-20 – Expand Bikeway Network, none of which were accounted for in the Draft EIR’s calculation of project VMT or potential VMT reductions.

The set of TDM measures in the revised Mitigation Measure 3.13-2 together would facilitate VMT reductions that are equal to or greater than the reductions expected from the original set of transportation measures derived from CAPOA Handbook Measure T-6 (i.e., 26 percent) because the additional measures facilitate walking and further facilitate bicycling through infrastructure improvements and can shorten travel distances to the project site by providing vehicle network connections. Therefore, the proposed revision would not result in the potential for a substantial increase in the severity of an environmental impact. Moreover, the revised mitigation incorporates attributes of the project that were evaluated in the Draft EIR but not accounted for in the VMT evaluation. For this reason, the revised mitigation would not generate a new significant impact not disclosed in the Draft EIR.

The proposed revisions constitute a clarification of the approach to reducing employee VMT and the revisions identified above are designed to provide equivalent or greater employee VMT reduction. As a category, employee VMT constitutes less than 2 percent of the overall VMT generated by the project. Therefore, any enhanced reduction would not meaningfully affect the level of VMT generated by the project. The project’s overall impact would remain significant and unavoidable, consistent with the conclusion presented on page 3.13-17 of the Draft EIR. No new significant environmental impact or substantial increase in the severity of an environmental impact would occur as a result of these revisions. Therefore, these revisions do not constitute significant new information, as defined by State CEQA Guidelines Section 15088.5. Thus, pursuant to State CEQA Guidelines Section 15088.5, recirculation of the Draft EIR is not required.

1 Measures T-18 through T-22-C are in the Neighborhood Design subsector. The VMT reduction from the combined implementation of all measures within this subsector is capped at 10 percent (CAPCOA 2021: 135).

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3.2.3 Individuals
Letter I1 Matthew Schellenberg
July 21, 2023
Response I1-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.Letter I2 Teresa Sanchez
July 21, 2023
Response I2-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I3 Dolores Davidain
July 19, 2023
Response I3-1
This comment expresses concern about the size and location of the proposed project, primarily due to accessibility for senior citizens. The comment notes that the new location may benefit nearby residents and supports retention of the gas station existing gas station on Shaw Avenue.

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The scale of the Costco facilities is integral to the bulk warehouse business model and creates the potential for various shopping efficiencies. For clarification, page 2-10 the Draft EIR states that the warehouse retail building footprint would occupy an overall footprint of 241,342 square feet; however, the total retail area would only occupy 162,264 square feet and the remaining space would primarily be used for Costco loading, storage, and receiving operations. As revised (see Chapter 1), the warehouse portion of the footprint would be reduced by 22,216 square feet to 140,048 square feet and the total warehouse retail building footprint would be 219,126 square feet. In comparison, the existing Costco warehouse at 4500 West Shaw Avenue has a footprint of 134,000 square feet, which is approximately 6,000 square feet smaller than the portion of the proposed Costco warehouse that would be accessible to the general public.

This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Letter I4 Vernon Valmonte
July 18, 2023
Response I4-1
This comment expresses concerns about traffic violations on local roadways, existing traffic conditions, and the proposed project's contributions to traffic. CEQA does not include provisions for evaluating impacts related to traffic violations. Further, although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, this topic is addressed outside of the CEQA review process.

On December 28, 2018, the California Resources Agency certified and adopted updates to the CEQA Guidelines which included the adoption of CCR Section 15064.3, “Determining the Significance of Transportation Impacts.” Pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion were eliminated as the basis for determining significant impacts, effectively being replaced with VMT as the primary metric to identify transportation-related impacts under CEQA. Accordingly, traffic congestion is not considered a significant impact on the environment under CEQA.

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As stated on page 3.13-11 of the Draft EIR, the significance criteria used to evaluate the proposed project’s impacts to transportation under CEQA are based on Appendix G of the CEQA Guidelines, City of Fresno CEQA Guidelines for VMT Thresholds, and CEQA Guidelines Section 15064.3. The Draft EIR identified the following impacts related to transportation that would remain significant and unavoidable, even with implementation of mitigation measures:

X Impact 3.13-2: Conflict or Be Inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b) Regarding Vehicle Miles Traveled (refer to pages 3.13-13 through 3.13-18 of the Draft EIR); and X Impact 3.13-3: Substantially Increase Hazards Due to a Geometric Design Feature (e.g., Sharp Curves or Dangerous Intersections) or Incompatible Uses (e.g., Farm Equipment) (refer to pages 3.13-19 through 3.13-21 of the Draft EIR).

CEQA does not preclude a public agency from approving or carrying out a project that has potential to result in significant and unavoidable impacts on the environment. Rather, CEQA is intended to: (1) inform government decisionmakers and the public about the potential environmental effects of proposed activities; (2) identify the ways that environmental damage can be avoided or significantly reduced; (3) prevent significant, avoidable environmental damage by requiring changes in projects, either by the adoption of alternatives or imposition of mitigation measures; and (4) disclose to the public why a project was approved if that project has significant environmental impacts that cannot be mitigated to a less than significant level. CEQA Guidelines Section 15091 and Public Resources Code Section 21081 require a public agency to identify the significant impacts of a project and make one or more written findings for each impact. When significant and unavoidable impacts are identified, the public agency is also required to issue a statement of overriding considerations. The statement of overriding considerations is a written statement explaining the specific reasons why the social, economic, legal, technical, or other beneficial aspects of the proposed project outweigh the unavoidable adverse environmental impacts and why the lead agency is willing to accept such impacts.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response I4-2
The comment expresses concerns that the proposed project would increase the presence of unhoused populations in the project vicinity. CEQA does not include provisions for consideration of unhoused populations separate and distinct from the analysis of a project’s impacts on the environment. CEQA requires lead agencies to consider the effects of a proposed project on the physical environment. Specifically, CEQA Guidelines Section 15131 states:

Economic or social effects of a project shall not be treated as significant effects on the environment. An EIR may trace a chain of cause and effect from a proposed decision on a project through anticipated economic or social changes resulting from the project to physical changes caused in turn by the economic or social changes. The intermediate economic or social changes need not be analyzed in any detail greater than necessary to trace the chain of cause and effect. The focus of the analysis shall be on the physical changes.

As explained on page 1-5 of the Draft EIR, the project would not remove any existing housing and would not displace any people or housing. Therefore, there is no evidence to support the concern that the project would increase the unhoused population in the area. The issue raised by the commenter is considered speculative and beyond the scope of CEQA; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I5 Denise King
July 17, 2023
Response I5-1
The comment expresses opposition to the proposed project. The comment states that the proposed project would result in environmental impacts related to increased traffic and pedestrian safety hazards, including school-aged children and the elderly. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation, including VMT and safety hazards. As described in Section 3.13, “Transportation and Circulation,” in the Draft EIR (see Impact 3.13-1, page 3.13-12):

There are no existing bicycle or pedestrian facilities along the proposed project site boundary. Trail improvements provided by the proposed project would include Class I bicycle facilities along the project’s frontage on West Herndon Avenue and North Riverside Drive which is consistent with future facilities identified in the City of Fresno’s ATP (City of Fresno 2016) adjacent to the proposed project site. The proposed project also involves the construction of West Spruce Avenue along the northern proposed project site boundary. The City has identified the construction of Spruce Avenue, including Class II bicycle facilities, as a condition of approval (City of Fresno 2022), which would be consistent with the City of Fresno’s ATP.

Therefore, pedestrian mobility in the vicinity may be improved through development of the project. Based on the lack of existing public facilities and the proposed public pedestrian infrastructure, the Draft EIR concludes that the proposed project would not conflict with planned pedestrian facilities. Further, the City of Fresno has met with the Central Unified School District regarding the proposed project to ensure that project-related truck deliveries do not pose a safety hazard for students at school bus drop-off/pick-up locations.

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Regarding delivery trucks, the Draft EIR (see page 2-20) describes an anticipated delivery schedule between approximately 2:00 and 10:00 a.m. at a rate of two to three trucks per hour and a total of approximately 10 to 13 trucks per day for the warehouse. Fuel would be delivered to the gas station in two to three trucks per day, and the tire center would receive shipments once or twice a week. As disclosed in Chapter 2, “Project Description,” of the Draft EIR (see page 2-14), the primary truck access route would be the southernmost driveway along North Arthur Avenue, with a secondary truck route using the southernmost driveway along North Riverside Drive, minimizing exposure of existing residents to truck traffic. The truck loading dock would be located on the southern facade of the warehouse building.

As explained in Response I4-1, the Draft EIR evaluates the potential for the project to generate VMT. CEQA Guidelines Section 15064.3(a) states that VMT refers to the amount and distance of a automobile travel attributable to a project.

The City’s CEQA Guidelines and the OPR Technical Advisory describe that the term “automobile” as used in Section 15064.3(a), refers to on-road passenger vehicles, specifically cars and light trucks; heavy vehicles are not included in the definition. Therefore, heavy-duty trucks (i.e., delivery trucks) were not included in the VMT analysis. However, it should be noted that the LOS analysis presented in the Fresno Costco Relocation Transportation Impact Analysis, which is included as Appendix D to the Draft EIR, does include truck traffic. In addition, truck traffic is evaluated as a component of the project in Section 3.3, “Air Quality,” and Section 3.11, “Noise and Vibration,” of the Draft EIR.

The comment states that the proposed project would result in hazardous fumes, vehicle emissions, pollution, and dust. Pages 3.3-19 through 3.3-25 in Section 3.3, “Air Quality,” of the Draft EIR address the proposed project’s impacts related to criteria air pollutants, including exhaust and fugitive dust from construction (Impact 3.3-1) and operation (Impact 3.3-2); toxic air contaminants (Impact 3.3-3); carbon monoxide concentrations (Impact 3.3-4); and odors (Impact 3.3-4). The analysis incorporates the project-specific traffic modeling performed for the project. The Draft EIR concludes that each of these impacts would be less than significant, and no mitigation measures are required.

Heavy vehicle noise associated with loading and delivery is evaluated in Impact 3.11-3. The analysis found that interior noise levels at the nearest surrounding residences would be approximately 35 decibels (dB) L eq, which is below the City’s interior noise standard of 45 dB. However, because noise generated by the loading dock would potentially exceed exterior noise standards, Mitigation Measure 3.11-3 has been identified. Through application of this mitigation, the project applicant would be required to construct a sound wall or other noise attenuating feature west of the loading docks with a demonstrated ability to result in a 4 dB noise decrease at the existing residences along North Riverside Drive. Specifically, for all outdoor construction activity that is to take place outside of the City of Fresno construction noise exception timeframes (i.e., 10:00 p.m. and 7:00 a.m., Monday through Saturday, and all hours of the day on Sunday), and that is anticipated to generate interior noise levels at sensitive receptors that exceed the City of Fresno General Plan interior noise standard of 45 dB for residential land uses, the construction contractor would:

X obtain an exception to Article 1, “Noise Regulations,” through the Chief Administrative Officer; X install temporary noise curtains as close as possible to the noise-generating activity such that the curtains obstruct the direct line of sight between the noise-generating construction activity and the nearby sensitive receptors;
X use noise-reducing enclosures and techniques around stationary noise-generating equipment; X operate heavy-duty construction equipment at the lowest operating power possible; X equip construction equipment with back-up alarms that are either audible self-adjusting backup alarms or alarms that only sound when an object is detected; and
X provide a minimum of one week of advanced notice to owners of all residential located within 350 feet of where nighttime construction activity would take place.

With application of the mitigation, the City’s noise standards would be achieved, and the impact would be less than significant.

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Finally, the comment indicates that there are other locations in the Fresno area that may be more appropriate for the proposed project based on proximity to residential uses. No Specific sites are identified. Please refer to Chapter 6, “Alternatives,” in the Draft EIR, which provides a brief analysis of three potential site alternatives.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Letter I6 Sharon Ross
July 17, 2023.

Response I6-1
The comment expresses concerns related to project-generated traffic congestion and pollution. Section 3.3, “Air Quality,” and Section 3.13, “Transportation and Circulation,” of the Draft EIR include analyses related to these topics.

This comment is similar to Comments I4-1 and I5-1. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation and Response I5-1 for a discussion regarding the proposed project’s impacts related to air quality. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I7 Susan Hansen
July 17, 2023
Response I7-1
The comment expresses support for the proposed project. The comment also provides suggestions related to site access and asks if site access will connect to the State Route (SR) 99 freeway ramps. Pages 2-13 through 2-14 of the Draft EIR provide a description of the proposed access points to the project site, which include driveways along North Riverside Drive, West Herndon Avenue, and North Arthur Avenue. Regional access to the project site from SR 99 would be provided from West Herndon Avenue. The Veterans Boulevard interchange on SR 99 that is under construction may also provide access. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I8 Claudia Readwright
July 17, 2023
Response I8-1
This comment requests that bicyclists are considered in project planning and that the project include bicycle facilities for customers. As discussed on page 3.13-12 of the Draft EIR, the proposed project would provide short-term bicycle parking as required by the City Municipal Code (Article 24, Section 15-2429) and Class I and II bicycle facilities along the proposed project frontages. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I9 Shahzaib Zaman
July 17, 2023
Response I9-1
The comment expresses concerns related to school buses, students, traffic, student theft, and congestion. This comment is similar to Comments I4-1 and I5-1. Please refer to Responses I4-1 and I5-1 for a discussion regarding the proposed project’s impacts related to transportation, including VMT and safety hazards. In addition, CEQA does not include provisions for evaluating impacts related to theft. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I10 Tj Atwal
July 17, 2023
Response I10-1
The commenter expresses concerns related to rezoning. Rezoning, in and of itself, is not necessarily a significant impact under CEQA; however, CEQA is concerned with whether a project would result in a significant environmental impact due to a conflict with relevant plans, policies, and zoning regulations adopted for the purpose of avoiding or mitigating an environmental effect. The environmental effects that would result from the proposed changes to the general plan land use designations, zoning, and parking lot standards are evaluated throughout the Draft EIR. Refer to Impact 3.10-1 in Section 3.10, “Land Use and Planning,” (pages 3.10-5 through 3.10-7 of the Draft EIR) for a discussion of the potential for the project to cause a significant environmental impact due to a conflict with zoning adopted for the purpose of avoiding or mitigating an environmental effect. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment.

Please refer to Response I4-1 for a response to concerns regarding traffic.

The commenter also expresses concerns that the project would result in the foreclosure or bankruptcy of established businesses resulting in “eye sores or hard to redevelop sites.” As discussed in Response I4-2, CEQA requires lead agencies to consider the effects of a proposed project on the physical environment. The proposed project’s economic effects on local gas stations in the vicinity of the project site is not, in and of itself, a significant impact under CEQA.

Further, the potential for the proposed project to result in the closure of established gas station businesses and consequently result in indirect environmental impacts, such as urban blight, is largely speculative. The commenter does not support the opinion that the proposed Costco gas station would substantially affect operations of the eight gas stations noted in the vicinity of the project, nor is there justification provided for the assumption that individuals would choose to wait “hours” for gas at the proposed station. Notably, the Costco gas station would be a member- only facility offset from the main thoroughfare (Herndon Avenue) with limited hours that would not offer auxiliary attractions such as convenience store products and customer restrooms. It is anticipated that trips to the proposed gas station would be combined with visits to the Costco warehouse.

An evaluation of the potential for the Costco relocation and gas station to result in urban decay impacts was conducted by ALH Urban and Regional Economics in 2023. This analysis concludes that the proposed Costco gas

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station would have minimal effects on existing gas stations and would not result in strong sales declines. No existing gas stations were identified as likely to close and urban decay is not anticipated to result (see Appendix A).

Therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Letter I11 Rey Alvarez
July 17, 2023
Response I11-1
The comment expresses opposition to the proposed project and concerns related to project-generated traffic.

Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA.

Please refer to Response I4-1.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response I11-2
The comment generally states that the proposed project may cause environmental issues, including pollution.

Section 3.3, “Air Quality,” of the Draft EIR includes an analysis related to this topic. Pages 3.3-19 through 3.3-25 address the proposed project’s impacts related to criteria air pollutants, including exhaust and fugitive dust, from construction (Impact 3.3-1) and operation (Impact 3.3-2); toxic air contaminants (Impact 3.3-3); carbon monoxide

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concentrations (Impact 3.3-4); and odors (Impact 3.3-4). The Draft EIR concludes that each of these impacts would be less than significant, and no mitigation measures are required.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Letter I12 Agnes Habellion
July 16, 2023
Response I12-1
The comment does not pertain to the proposed project; therefore, no response is required.

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Letter I13 Linnea and David Faeth
July 16, 2023
Response I13-1
The comment expresses concerns related to the local climate and provides design recommendations to reduce carbon emissions. Section 3.7, “Greenhouse Gas Emissions and Climate Change,” of the Draft EIR includes a discussion of the proposed project’s impacts related to GHG emissions and climate change. As described on pages 3.7-11 through 3.7-13 of the Draft EIR, the proposed project includes various design features that mirror the GHG reduction measures in the City’s adopted greenhouse gas reduction plan, which include participating in Pacific Gas and Electric Company’s (PG&E’s) Solar Choice program to procure 100 percent of its electricity from solar resources, implementing a solid waste diversion program, and installing electric vehicle chargers. In addition, as noted on page 2-17, the proposed project would provide landscaping in accordance with the City’s shading requirements. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I14 Alana L. Lewis
July 16, 2023
Response I14-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I15 Sharon Henson
July 16, 2023
Response I15-1
The comment expresses concern related to the effect of the proposed completion of Spruce Avenue on the character of surrounding neighborhoods. As evaluated in the Draft EIR, the applicant would extend West Spruce Avenue from North Riverside Drive to the intersection with North Sandrini Avenue. As discussed on page 3.13-19 of the Draft EIR, extending West Spruce Avenue would be consistent with the City’s planned roadway system depicted on Figure MT-1 of the City’s General Plan Mobility and Transportation Element. Accordingly, the City’s Traffic Planning Section would require the project proponent to extend West Spruce Avenue as a condition of project approval. The asphalt roadway would be a City street and would include curb, gutter, sidewalk, Class II bicycle facilities, and streetlights.

Section 3.11, “Noise and Vibration,” and Section 3.13, “Transportation and Circulation,” of the Draft EIR include analyses related to these topics. Specifically, Impact 3.11-4 evaluates the potential trip redistribution that would result from the completion of Spruce Avenue. For the purpose of the Draft EIR analysis, it is assumed that the residential development north of West Spruce Avenue between North Hayes Avenue and North Sandrini Avenue (approximately 155 single family homes) would be the primary source of traffic on the roadway. This is conservative because the West Spruce Avenue extension would not provide the shortest or most direct route for trips headed south or east from the existing residential development. The proposed roadway segment could be used by cut through traffic during peak travel times when roadway facilities along West Herndon Avenue in the vicinity of the project site are experiencing increases in delay, but use of the roadway by nonresidents is not anticipated to be a major source of traffic due to the location of the road relative to other regional attractants and thoroughfares.

The comment also expresses concerns related to air quality associated with idling cars at the gas station and car wash. Section 3.3, “Air Quality,” of the Draft EIR includes an analysis related to these topics. As explained therein, the City quantified the emissions from the permitted gas station based on anticipated throughput and included these emissions in the calculations of maximum annual emissions of criteria pollutants and precursors associated with operation of the project (see Table 3.3-6). The project would not generate operational emissions of criteria air pollutants and ozone precursors exceeding SJVAPCD’s annual mass emissions thresholds of significance or daily screening criteria for permitted and non-permitted sources.

The comment also expresses concerns related to wildlife and an existing ponding basin. Section 3.5, “Biological Resources,” of the Draft EIR includes a discussion of the proposed project’s impacts related to wildlife. As noted on

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page 3.5-12, the project site does not contain wetlands and does not provide an important connection between any areas of natural habitat outside of the project site. The referenced ponding basin may be the stormwater basin located northwest of the project site (Fresno Metropolitan Flood Control District’s Basin EG). This basin captures stormwater runoff from the developed area east of North Arthur Avenue for groundwater recharge or release of the settled water into the San Joaquin River. As discussed on pages 3.15-13 through 3.5-16, three special-status wildlife species (burrowing owl, Swainson’s hawk, and white-tailed kite) and protected common native nesting birds have potential to occur on the project site; however, mitigation measures would be implemented to reduce potential impacts to these wildlife species from project implementation to a less-than-significant level.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Letter I16 Jeannette Correa
July 16, 2023
Response I16-1
The comment expresses concerns related to traffic. Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I17 Dantenello Velasquez
July 15, 2023
Response I17-1
The comment expresses concerns related to traffic and the presence of transients. This comment is similar to Comments I4-1 and I4-2. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation and Response I4-2 for a discussion of unhoused populations.

The comment also expresses concerns related to views from the Riverside Golf Course. Section 3.1, “Aesthetics,” of the Draft EIR includes a discussion of the proposed project’s impacts related to public views. As described on page

3.1-4 of the Draft EIR, landscaping on the golf course prevents direct line of sight to the project site and existing fencing and netting along North Riverside Drive create visual separation. Page 3.1-8 of the Draft EIR states that the project would reduce the vacant land visible from vantage points on the golf course, but would not substantially degrade the existing visual quality and would be consistent with the visual character of the existing development in the vicinity of the project site. The Draft EIR concludes that the impact on public views would be less than significant.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I18 Randy Ames
July 15, 2023
Response I18-1
The comment expresses opposition to the proposed project and concerns related to traffic, specifically related to operation of West Herndon Avenue and the existing railroad. This comment is similar to Comment I4-1. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation. Refer also to Section 3.13, “Transportation and Circulation,” in the Draft EIR (Impact 3.13-3) that addresses potential queuing impacts along West Herndon. As described therein, the City has identified modification to the intersection of West Herndon Avenue and North Riverside Drive as conditions of approval for the proposed project. The Draft EIR also includes Mitigation Measure 3.13-3 to revise signal phasing to optimize green-time allocation relative to anticipated volumes at North Golden State Boulevard and West Herndon Avenue near the alignment of the existing railway and the California High Speed Rail.

The comment also offers the opinion that a new traffic light is not needed to provide access to the proposed Costco site. For clarification, there is an existing traffic light at the intersection of West Herndon Avenue and North Riverside

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Avenue. No traffic lights are proposed along West Herndon Avenue. The project includes a general plan amendment to reclassify the portion of West Herndon Avenue between North Riverside Drive and North Hayes Avenue from expressway to superarterial to allow the construction of an intersection where West Herndon Avenue meets the private North Arthur Avenue right-of-way. Construction of the intersection of West Herndon Avenue and North Arthur Avenue to allow right-in/right-out and left-in turning would require a median cut on West Herndon Avenue.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.Letter I19 Kiersten Winrow July 14, 2023
Response I19-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no further response is required. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-57
Letter I20 Joseph Pulido
July 14, 2023
Response I20-1
The comment expresses concern that the project activities have been initiated without the necessary project approvals. Any roadwork observed in the project vicinity is part of a separate action (mitigation for the El Paseo Shopping Center) that was subject to separate discretionary approval by the City. The project is currently undergoing environmental review and would not be allowed to undergo construction until the applicable permits and approvals listed on pages 2-21 through 2-22 of the Draft EIR are obtained.

The comment also expresses concerns about the project location, including proximity to adjacent recreational and residential land uses, rezoning, and traffic congestion and safety. Section 3.10, “Land Use and Planning,” and Section 3.13, “Transportation and Circulation,” of the Draft EIR include analyses related to these topics. This comment is similar to Comments I4-1 and I10-1. Please refer to Responses I4-1 for a discussion regarding the proposed project’s impacts related to transportation and Response I10-1 for a discussion of the environmental effects that would result from the proposed changes to the general plan land use designations, zoning, and parking lot standards.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I21 Jeremy Bruno
July 14, 2023
Response I21-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Letter I22 Bob Eurich
July 14, 2023
Response I22-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-59
Letter I23 Sukhi Dhillon
July 14, 2023
Response I23-1
The comment expresses concerns regarding traffic, pollution, and views from the Riverside Golf Course. Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation, and Response I5-1 for a discussion regarding the proposed project’s impacts related to air quality.

The comment also expresses concerns related to views from the Riverside Golf Course. Section 3.1, “Aesthetics,” of the Draft EIR includes a discussion of the proposed project’s impacts related to public views. As described on page

3.1-4 of the Draft EIR, landscaping on the golf course prevents direct line of sight to the project site and existing fencing and netting along North Riverside Drive create visual separation. Page 3.1-8 of the Draft EIR states that the project would reduce the vacant land visible from vantage points on the golf course, but would not substantially degrade the existing visual quality and would be consistent with the visual character of the existing development in the vicinity of the project site. The preliminary landscape plans include trees throughout the site, including along the extension of West Spruce Avenue, which would create a visual barrier between the golf course and the proposed development. The Draft EIR concludes that the impact on public views would be less than significant.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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City of Fresno
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Letter I24 Sakit Bibra
July 14, 2023
Response I24-1
The comment expresses opposition to the proposed project but does not raise any specific issues related to the physical environment or address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Letter I25 Anya Ellis
July 14, 2023
Response I25-1
The comment requests clarification regarding the project size. The overall project site encompasses 22 acres. As revised, the footprint of the warehouse retail building would be 219,126 square feet; however, the total retail area would only occupy 140,048 square feet and the remaining space would primarily be used for Costco loading, storage, and receiving operations. An additional 12,885 square feet would be developed with fuel canopy and 4,800 square feet would be developed with a car wash. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-61
Letter I26 Michael and Joan Paine
July 14, 2023
Response I26-1
The comment expresses opposition to the proposed project and raises concerns related to traffic conditions, including congestion, violations, and accidents. Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA. Please refer to Response I4-1 for a general discussion regarding the proposed project’s impacts related to transportation and Response I18-1 for additional detail related to traffic on West Herndon Avenue. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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City of Fresno
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Letter I27 Bekah Bryant
July 14, 2023
Response I27-1
The comment expresses concerns related to existing and future traffic conditions. Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation and Response I18-1 for additional detail related to traffic on West Herndon Avenue. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-63
Letter I28 Randy Mills
July 13, 2023
Response I28-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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City of Fresno
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Letter I29 William and Melody Hardaway
July 13, 2023
Response I29-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-65
Letter I30 Geoff J.

July 13, 2023
Response I30-1
The comment expresses opposition to the proposed project and raises concerns related to several topics addressed below.

The comment expresses concerns related to traffic congestion. This comment is similar to Comment I4-1. Please refer to Responses I4-1 for a discussion regarding the proposed project’s impacts related to transportation.

The comment expresses concerns related to zoning conflicts. Section 3.10, “Land Use and Planning,” of the Draft EIR includes an analysis related to this topic. This comment is similar to Comment I10-1. Please refer to Response I10-1 for a discussion of the environmental effects that would result from the proposed changes to the general plan land use designations, zoning and parking lot standards.

The comment expresses concerns related to trash and pollution near waterways. Section 3.9, “Hydrology and Water Quality,” of the Draft EIR includes a discussion of the proposed project’s impacts related to water quality. As discussed on pages 3.9-8 and 3.9-9 of the Draft EIR (Impact 3.9-1), project construction and operation would be subject to various regulations, including the National Pollutant Discharge Elimination System Permit Program; underground storage tank regulations contained in CCR, Title 23, Water, Division 3, Chapter 16; Central Valley Regional Water Quality Control Board’s General Permit for stormwater discharges from municipal separate storm sewer systems (Order R5-2016-0040); and Fresno Metropolitan Flood Control District’s (FMFCD’s) Storm Drainage and Flood Control Master Plan. Best management practices would be implemented during project construction and incorporated into the project design to ensure that the project would not degrade water quality. The Draft EIR concluded that the project’s impact on water quality would be less than significant.

The comment expresses concerns related to lighting at nearby residential neighborhoods. Section 3.1, “Aesthetics,” of the Draft EIR includes a discussion of the proposed project’s impacts related to lighting. As discussed on page 3.1-9 (Impact 3.1-2), all light fixtures would be downcast and would not exceed the City’s 0.5-foot-candle1 standard for light 1 A foot-candle is defined as one lumen per square foot.

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spillover onto adjacent residential areas. The Draft EIR concluded that the project’s impact related to lighting would be less than significant.

The comment expresses concerns related to noise at nearby residential neighborhoods. Section 3.11, “Noise and Vibration,” of the Draft EIR includes a discussion of the proposed project’s impacts related to noise. As discussed on pages 3.11-22 through 3.11-29, the proposed project would result in permanent new noise sources from stationary equipment and on-site activities, traffic, and truck trips; however, the Draft EIR concluded that these impacts would be less than significant or less than significant with mitigation incorporated (Impacts 3.11-4 and 3.11-5). As discussed on pages 3.11-16 through 3.11-20, project construction activities may be required during evening and nighttime hours and the Draft EIR concluded that this impact would remain significant and unavoidable, even with implementation of mitigation (Impact 3.11-1). As discussed in Response I4-1, CEQA does not preclude a public agency from approving or carrying out a project that has potential to result in significant and unavoidable impacts on the environment; however, the public agency must make findings for each impact and issue a statement of overriding considerations in order to approve the project.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Letter I31 Birdevinder
July 13, 2023
Response I31-1
The comment expresses general concerns related to traffic and safety. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation. As explained in Section 2.2.1 of the Draft EIR, Costco has proposed the store location because the customer base has outgrown the capacity of the current facility, which opened in 1985. The project would allow Costco to expand services in the area to include an additional gas station and a car wash, as well as a loading area to facilitate delivery of purchases directly to homes in the Fresno area. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-67
Letter I32 Bryan Miller
July 13, 2023
Response I32-1
The comment expresses support for the proposed project and provides suggestions related to site access. Pages 2-13 through 2-14 of the Draft EIR provide a description of the proposed access points to the project site. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I33 Colton Metzler
July 13, 2023
Response I33-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-69

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Letter I34 Ty Murphy
July 13, 2023
Response I34-1
The comment expresses concerns that nearby residents and recreationists at the Riverside Golf Course will experience increased traffic from the project. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation. Additionally, as discussed on page 3.12-4 of the Draft EIR, the project would not preclude access to existing recreational facilities, including the Riverside Golf Course. Rather, as noted on page 3.13-11 of the Draft EIR, the proposed intersection at West Herndon Avenue/North Arthur Avenue may result in easier travel for southbound drivers along North Riverside Drive, including nearby residents and visitors to the Riverside Golf Course. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response I34-2
The comment states that modifications to the golf course would be required to accommodate the project and expresses concern that these improvements would increase fees and interfere with events at the golf course. Page

3.12-4 of the Draft EIR describes the modifications to the Riverside Golf Course, which include modifications to the existing irrigation system, relocation of the golf cart path, and installation of a new fence and nets. The project applicant would be responsible for implementing and funding these improvements. These minor modifications would be implemented in coordination with the City to ensure that construction activities do not interfere with the use of the golf course. The environmental impacts from these improvements have been evaluated in the Draft EIR. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-71
Letter I35 Jax Ward
July 13, 2023
Response I35-1
This comment states that there is a lack of safe bike lanes and bike parking. The comment also requests that the project consider alternate forms of transportation, including safe routes to schools. This comment is similar to Comment I8-1. Please refer to Response I8-1, above. As explained further in Response I5-1, pedestrian mobility in the vicinity may be improved through development of the project and the Draft EIR concludes that the proposed project would not conflict with planned pedestrian facilities. Further, the City of Fresno has met with the Central Unified School District regarding the proposed project to ensure that project-related truck deliveries do not pose a safety hazard for students at school bus drop-off/pick-up locations. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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City of Fresno
2-72 Costco Commercial Center Project Final EIR
Letter I36 Elizabeth Mendoza
July 13, 2023
Response I36-1
The comment expresses concerns related to the noise, traffic, and safety hazards that would result from the proposed project. Section 3.11, “Noise and Vibration,” and Section 3.13, “Transportation and Circulation,” of the Draft EIR include analyses related to these topics. Refer to Response I15-1 for information about the extension of Spruce Avenue adjacent to the northern boundary of the project and anticipated effects on traffic patterns.

Please also refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation and safety and Response I30-1 for a discussion regarding the project’s impact related to noise.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-73
Letter I37 J. Chmielewski
July 13, 2023
Response I37-1
The comment expresses concerns related to traffic. Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA. Please refer to Response I4-1 for further discussion. The comment also suggests an alternative location for the proposed project that could reduce traffic on Herndon Avenue, compared to the proposed site. As explained in Section 3.13, “Transportation and Circulation,” of the Draft EIR, traffic generation is not considered an impact on the environment. Therefore, CEQA does not require the evaluation of alternatives to reduce perceived effects.

In accordance with State CEQA Guidelines Section 15126.6(a), the Draft EIR evaluates a range of reasonable alternatives to the proposed project. As discussed on pages 6-3 through 6-5 of the Draft EIR, the City considered off- site locations, but dismissed these alternatives from further analysis due to a variety of reasons including (but not limited to) likely infeasibility and because they would not clearly address the project’s significant environmental effects.

The flooring store referenced in the comment is assumed to be the Floor & Décor on North Riverside Drive, northwest of Veterans Boulevard. One of the offsite alternatives considered in the Draft EIR is located on three undeveloped parcels of approximately 8 acres, 6 acres, and 9 acres that are zoned for light industrial use in the area west of North Riverside Drive and north of Veterans Boulevard. This appears to be the same location suggested by the commenter. See Chapter 6, “Alternatives,” of the Draft EIR for further discussion of this alternative project site and reasons for dismissal.

Because this comment does not offer any specific concern related to the adequacy of the Draft EIR, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I38 Kent Yamaguchi
July 13, 2023
Response I38-1
The comment expresses concerns related to traffic and general concerns related to the environment. The comment also expresses opposition to the proposed relocation. Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation and Appendix A for an evaluation of the potential for the project to contribute to urban decay. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-75
Letter I39 Nick Quisenberry
July 13, 2023
Response I39-1
The comment expresses concerns related to traffic and air quality. Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation and Response I5-1 for a discussion regarding the proposed project’s impacts related to air quality. The comment also suggests that continued operation of the existing Costco on Shaw Avenue would reduce these impacts. Please refer to the discussion of Alternative 1b: No Project Alternative – No Development in Chapter 6, “Alternatives,” of the Draft EIR.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I40 Don Marshall
July 13, 2023
Response I40-1
The comment expresses support for the proposed project, stating that it would result in economic benefits for the City. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.Letter I41 Jerry Montejano July 13, 2023
Response I41-1
The comment expresses support for the proposed project, stating that it would alleviate traffic problems. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-77
Letter I42 William Duane Peverill
July 21, 2023
Response I42-1
The comment is a request to review the Draft EIR and have an opportunity to make comments. In accordance with Section 15105 of the CEQA Guidelines, the Draft EIR was circulated for a 45-day public review period from July 11, 2023 to August 25, 2023. The Draft EIR was available for review by appointment at the Planning and Development Department at 2600 Fresno Street, Room 3043, Fresno, CA 93721. Electronic copies of the Draft EIR were available on request by contacting Jose Valenzuela via e-mail or by phone. The Draft EIR was also available for review on the City’s website at the following link: https://www.fresno.gov/planning/plans-projects-under-review/#tab-14. The City provided the commenter with access to the Draft EIR, as requested, on July 24, 2023. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment.

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City of Fresno
2-78 Costco Commercial Center Project Final EIR
Letter I43 Lorraine Arrington
July 21, 2023
Response I43-1
The comment expresses opposition to the proposed project and raises concerns about local businesses. As discussed in Response I4-2, CEQA requires lead agencies to consider the effects of a proposed project on the physical environment. Comment I10-1 raises a similar issue pertaining to gas stations. Similar to the response provided for comment I10-1, the proposed project’s economic effects on local grocery stores in the vicinity of the project site is not, in and of itself, a significant impact under CEQA.

An evaluation of the potential for the Costco relocation and gas station to result in urban decay impacts was conducted by ALH Urban and Regional Economics in 2023. This analysis indicates that food sales are strong in the City of Fresno. Further, because the Costco store is being relocated, it is anticipated that "existing Costco shoppers will transfer their purchases to the new store, such that diversions from existing area food stores will be at a minimum.” The analysis concludes that “sales impacts are not likely to be high enough to contribute to closure of existing food stores” (see Appendix A).

Therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-79
Letter I44 Dr. Danielle Biggs
July 21, 2023
Response I44-1
The comment expresses opposition to the proposed project and raises concerns related to existing issues faced in the neighborhood. The comment also raises concerns about project-generated traffic. Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation. This comment does not offer any

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specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Letter I45 Holden Markwith
July 21, 2023
Response I45-1
The comment expresses opposition to the proposed project and raises concerns related to existing issues faced in the neighborhood. The comment also raises concerns about the project’s proximity to residences and schools, but does not identify any specific environmental issues and does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-81
Letter I46 David Scott
July 22, 2023
Response I46-1
The comment expresses opposition to the proposed project and raises concerns related to traffic, noise, and pollution. Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA.

Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation, Response I5-1 for a discussion regarding the proposed project’s impacts related to air quality, and Response I30-1 for a discussion regarding the proposed project’s impacts related to noise.

Finally, the comment indicates that there are other locations in the Fresno area that may be more appropriate for the proposed project. Specifically, the comment suggests a site along Highway 41 along the San Joaquin River. This location is approximately 10 miles east of the proposed project site and 2 miles north of the existing Costco at 7100 N Abby Street in Fresno. Please refer to Chapter 6, “Alternatives,” in the Draft EIR, which provides a brief analysis of three potential site alternatives.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I47 Amy Siliznoff
July 22, 2023
Response I47-1
The comment expresses concerns related to traffic. Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation and Response I18-1 for a response to concerns related to traffic and operation of the existing railroad. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-83
Letter I48 Betty Williams
July 22, 2023
Response I48-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I49 Jensen Vang
July 22, 2023
Response I49-1
The comment expresses concerns related to traffic and student safety. This comment is similar to Comments I4-1 and I5-1. Please refer to Responses I4-1 and I5-1 for a discussion regarding the proposed project’s impacts related to transportation, including VMT and safety hazards. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-85
Letter I50 Melody Wolverton
July 22, 2023
Response I50-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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City of Fresno
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Letter I51 Joseph Pulido
July 22, 2023
Response I51-1
The comment expresses concern that the proposal is final. As discussed on page 1.5 of the Draft EIR, the proposed project is currently undergoing environmental review. Before, adopting the project, the lead agency is required to certify that the EIR has been completed in compliance with CEQA, that the decision-making body reviewed and considered the information in the EIR, and that the EIR reflects the independent judgement of the lead agency. Other permits and approvals that may be required for project implementation are listed on pages 2-21 and 2-22 of the Draft EIR.

The comment also expresses concerns related to traffic and student safety. This comment is similar to Comments I4-1 and I5-1. Please refer to Responses I4-1 and I5-1 for a discussion regarding the proposed project’s impacts related to transportation, including VMT and safety hazards. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-87
Letter I52 John Olszowka
July 23, 2023
Response I52-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Responses to Comments Ascent
City of Fresno
2-88 Costco Commercial Center Project Final EIR
Letter I53 Justin Latham
July 23, 2023
Response I53-1
The comment expresses concern that the proposed project would cause local businesses in the area to close, resulting in increased presence of unhoused populations, crime, and trash and reduced property values. This comment is similar to Comment I10-1. Please refer to Response I10-1 for a discussion regarding the proposed project’s impacts related to urban decay.

The comment also expresses concerns that the proposed project would remove Herndon Avenue. The proposed project would not result in the removal of any existing roadways. As discussed on page 2-6 of the Draft EIR, the proposed project includes a proposed General Plan amendment and rezoning to reclassify West Herndon Avenue from North Riverside Drive to North Hayes Avenue from an expressway to a superarterial. The reclassification would allow construction of a new intersection where West Herndon Avenue meets the private North Arthur right-of-way, which would allow access to the project site.

The comment also expresses concern that the proposed project would ultimately be abandoned and “create more blight and sprawl.” The future closure of the proposed project is speculative, and the resulting potential for urban blight would not be considered a reasonably foreseeable indirect effect of the project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-89
Letter I54 Charles Ognibene
July 23, 2023
Response I54-1
The comment is a request to review the project proposal. This comment is similar to Comment I42-1. Please refer to Response I42-1 regarding circulation of the Draft EIR for the proposed project. The City provided the commenter with access to the Draft EIR, as requested. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. Letter I55 Jamey Schmidt July 24, 203
Response I55-1
The comment expresses concern regarding the water source for the proposed car wash. As discussed on pages 3.9- 10, 3.14-12, and 3.14-13 of the Draft EIR, the project, including the car wash, would be supplied water through the City of Fresno Department of Public Utilities. As explained in the Draft EIR (see page 2-13) wash water would be recycled.

A description of the City’s water supply sources is provided on pages 3.14-4 through 3.14-7 of the Draft EIR. The City's 2020 Urban Water Management Plan (UWMP) projects that the City would have an excess of water through 2045 during normal, dry, and multiple dry years. The project's water demand, which considers the water demand for the car wash, is accounted for within the City's 2020 UWMP projections for future development. The Draft EIR concludes that there would be sufficient water to serve the project and reasonably foreseeable development during normal, dry, and multiple dry years (see Impact 3.14-2, Draft EIR pages 3.14-12 and 3.14-13). This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment.

Responses to Comments Ascent
City of Fresno
2-90 Costco Commercial Center Project Final EIR
Letter I56 William Duane Peverill
July 24, 203
Response I56-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-91
Letter I57 Lorraine Arrington
July 24, 203
Response I57-1
The comment is a follow-up response to a previously submitted comment (Comment I43-1) and does not raise any significant environmental issues; therefore, no response is required.

Responses to Comments Ascent
City of Fresno
2-92 Costco Commercial Center Project Final EIR

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-93
Letter I58 Pat Yaralian
July 25, 2023
Response I58-1
The comment describes existing traffic issues in the project vicinity. The comment also expresses concerns that the proposed project would pose roadway safety issues. This comment is similar to Comments I4-1 and I5-1. Please refer to Responses I4-1 and I5-1 for a discussion regarding the proposed project’s impacts related to transportation, including traffic and safety hazards. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project. Letter I59 Michael Van
July 25, 2023
Response I59-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Responses to Comments Ascent
City of Fresno
2-94 Costco Commercial Center Project Final EIR
Letter I60 Sabrina Hernandez
July 26, 2023
Response I60-1
The comment expresses concern about pedestrian safety in relation to the proposed project and other nearby development. Please refer to Responses I4-1 and I5-1 for a discussion regarding the proposed project’s impacts related to transportation, including traffic and safety hazards. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response I60-2
The comment raises concerns about pollution and poor air quality in the area. Please refer to Response I5-1 regarding the proposed project’s impacts related to air quality. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-95
Response I60-3
The comment raises concerns about the proposed project’s effects on small businesses. This comment is similar to I10-1 and I43-1. Please refer to Responses I10-1 and I43-1 regarding the economic effects of the proposed project. No revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Letter I61 Javier Morales
July 27, 2023
Response I61-1
The comment expresses concerns about the proposed project’s contribution to traffic congestion and opposition to the proposed project’s location. Although the topic of traffic congestion is a factor for consideration by the decision- makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation and Response I18-1 for a response to concerns related to traffic and operation of the existing railroad. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Responses to Comments Ascent
City of Fresno
2-96 Costco Commercial Center Project Final EIR
Letter I62 James and Louisa Weyant
July 27, 2023
Response I62-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-97
Letter I63 Shirley Hutchison
July 27, 2023
Response I63-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Responses to Comments Ascent
City of Fresno
2-98 Costco Commercial Center Project Final EIR
Letter I64 Maria Leon
July 27, 2023
Response I64-1
The comment expresses opposition to the location selected for the proposed project and raises concerns related to traffic. Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA.

Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation. The comment suggests an alternative location at Golden State Boulevard and West Herndon Avenue. As described in Section 3.13, “Transportation and Circulation,” in the Draft EIR, modification of this area is limited by existing and proposed developments, including the alignment of the California High Speed Rail project. Please refer to Chapter 6, “Alternatives,” in the Draft EIR, which provides a brief analysis of three potential site alternatives. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-99
Letter I65 Norman S. Stahl
July 27, 2023
Response I65-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Responses to Comments Ascent
City of Fresno
2-100 Costco Commercial Center Project Final EIR
Letter I66 Jesus Diaz
July 27, 2023
Response I66-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Letter I67 Anthony Scheideman
July 27, 2023
Response I67-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-101
Letter I68 Rick and Kathy Haskill
July 28, 2023
Response I68-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Responses to Comments Ascent
City of Fresno
2-102 Costco Commercial Center Project Final EIR
Letter I69 Kevin Cartwright
July 28, 2023
Response I69-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Letter I70 Adalino
July 28, 2023
Response I70-1
The comment suggests an alternative location for the proposed project. This comment is similar to Comment I37-1.

Please refer to Response I37-1 regarding alternatives to the proposed project. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-103
Letter I71 Juan Duran
July 28, 2023
Response I71-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Responses to Comments Ascent
City of Fresno
2-104 Costco Commercial Center Project Final EIR
Letter I72 Miguel Duran
July 28, 2023
Response I72-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-105
Letter I73 Fabrizio Robalino
July 31, 2023
Response I73-1
The comment is a request to review the Draft EIR. This comment is similar to Comment I42-1. Please refer to Response I42-1 regarding circulation of the Draft EIR for the proposed project. The City provided the commenter with access to the Draft EIR, as requested. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment.

Responses to Comments Ascent
City of Fresno
2-106 Costco Commercial Center Project Final EIR
Letter I74 Celso “Sal” Romero, Jr.

July 31, 2023
Response I74-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-107
Letter I75 Cindy Diaz
August 1, 2023
Response I75-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Responses to Comments Ascent
City of Fresno
2-108 Costco Commercial Center Project Final EIR
Letter I76 Joy Hinrichsen
August 2, 2023
Response I76-1
The comment expresses concerns related to traffic, freeway access, and student safety. This comment is similar to Comments I4-1 and I5-1. Please refer to Responses I4-1 and I5-1 for a discussion regarding the proposed project’s impacts related to transportation. The comment also expresses concerns related to property values. The proposed project’s effect on property values in the vicinity of the project site is not, in and of itself, a significant impact under CEQA. The potential for indirect environmental impacts to occur as a result of the proposed project’s contribution to social or economic changes in the project vicinity is addressed in Response I10-1. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. See also Chapter 6, “Alternatives,” in the Draft EIR, which considers potential offsite alternatives to the proposed project. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response I76-2
The comment expresses concerns regarding food vendors. The comment does not pertain to the proposed project; therefore, no response is required.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-109
Letter I77 Garrett Schaefer
August 3, 2023
Response I77-1
The comment expresses interest in future employment opportunities related to the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no response is required.

Responses to Comments Ascent
City of Fresno
2-110 Costco Commercial Center Project Final EIR
Letter I78 Lynda Allison Doty
August 8, 2023
Response I78-1
The comment expresses opposition to the proposed project and raises concerns related to traffic and congestion.

Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA.

Please refer also to Response I4-1. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-111
Letter I79 Tom Basset
August 8, 2023
Response I79-1
The comment expresses opposition to the location for the proposed project and requests a more central location.

This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment and no further response is required.

Responses to Comments Ascent
City of Fresno
2-112 Costco Commercial Center Project Final EIR
Letter I80 Beth Durbin
August 9, 2023
Response I80-1
The comment expresses opposition to the proposed project and raises concerns related to trucks, traffic, pollution, and noise. Section 3.3, “Air Quality,” Section 3.11, “Noise and Vibration,” and Section 3.13, “Transportation and Circulation,” of the Draft EIR include analyses related to these topics. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation, Response I5-1 for a discussion regarding the proposed project’s impacts related to air quality, and Response I30-1 for a discussion regarding the proposed project’s impacts related to noise. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-113
Letter I81 Sandra J. Iley
August 9, 2023
Response I81-1
The comment expresses opposition to the extension of Spruce Avenue and location of the proposed project, raising concerns related to traffic, noise, and pollution. As discussed on page 3.13-19 of the Draft EIR, extending West Spruce Avenue would be consistent with the City’s planned roadway system depicted on Figure MT-1 of the City’s General Plan Mobility and Transportation Element. Accordingly, the City’s Traffic Planning Section would require the project proponent to extend West Spruce Avenue as a condition of project approval.

The environmental effects of extending West Spruce Avenue (including effects on transportation, noise, and air quality) have been evaluated in the Draft EIR. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to traffic and Response I5-1 for a discussion regarding the proposed project’s impacts related to air quality. With respect to noise, page 3.11-27 of the Draft EIR includes a discussion of project-generated traffic noise levels on the extended West Spruce Avenue. The Draft EIR concludes that traffic noise levels would not exceed the City’s noise standard at nearby residential uses and concludes the impact would be less than significant (Impact 3.11-4). Pages 3.11-28 and 3.11-29 of the Draft EIR include a discussion of intermittent single-event noise levels from trucks operating in the project vicinity. The Draft EIR identifies mitigation that would require the project applicant to construct a sound wall and/or pave North Riverside Drive with a surface treatment with noise-reducing properties and concludes that mitigation would reduce the noise impact at nearby residences to a less-than- significant level (Impact 3.11-5). See also Response I30-1 for additional discussion regarding the proposed project’s impacts related to noise and Response I15-1 for information about the extension of Spruce Avenue adjacent to the northern boundary of the project and anticipated effects on traffic patterns.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Responses to Comments Ascent
City of Fresno
2-114 Costco Commercial Center Project Final EIR
Letter I82 Stephanie S.

August 10, 2023
Response I82-1
The comment expresses opposition to the location of the proposed project, raising concerns related to traffic and safety. Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA.

Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation. The comment also recommends improvements to the roadway network that are outside the scope of the project; accordingly, no further response is required.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-115
Letter I83 Thomas Coppin
August 10, 2023
Response I83-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Responses to Comments Ascent
City of Fresno
2-116 Costco Commercial Center Project Final EIR
Letter I84 Dawn Mathews
August 10, 2023
Response I84-1
The comment indicates a preference for the proposed Costco location. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment and no further response is required.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-117
Letter I85 Larry Rodriguez
August 11, 2023
Response I85-1
The comment expresses concerns related to traffic and pedestrian safety. The comment provides observations of other Costco locations as examples and recommends roadway improvements to accommodate the traffic. Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA. Please also refer to Response I4-1.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Responses to Comments Ascent
City of Fresno
2-118 Costco Commercial Center Project Final EIR
Letter I86 Sylvia Fernandez
August 11, 2023
Response I86-1
The comment expresses interest in future employment opportunities related to the project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no response is required.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-119
Letter I87 Jens Andersen
August 13, 2023
Response I87-1
The comment expresses reservations about the location of the proposed project, raises concerns related to zoning and traffic, and recommends an alternative location. Section 3.10, “Land Use and Planning,” Section 3.13, “Transportation and Circulation,” and Section 6, “Alternatives,” of the Draft EIR include analyses related to these topics. This comment is similar to Comments I4-1, I10-1, and I37-1. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation, Response I10-1 for a discussion of the environmental effects that would result from the proposed changes to the general plan land use designations and zoning, and Response I37-1 regarding alternatives to the proposed project. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Responses to Comments Ascent
City of Fresno
2-120 Costco Commercial Center Project Final EIR

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-121
Letter I88 Richee Xavonglianekham
August 14, 2023
Response I88-1
The comment expresses opposition to the proposed project, raising concerns related to traffic conditions, including congestion, violations, and accidents, as well as air pollution. Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation and Response I5-1 for a discussion regarding the proposed project’s impacts related to air quality. The comment also expresses concerns related to parking. As described on page 1-4 of this Final EIR, the proposed project would include 873 parking stalls, which meets the City’ of Fresno’s minimum parking requirements and would be sufficient to accommodate the project’s parking demand.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response I88-2
The comment recommends the construction of residential land uses on the project site and suggests alternative locations for the proposed project. In accordance with State CEQA Guidelines Section 15126.6(a), the Draft EIR evaluated a range of reasonable alternatives to the proposed project. As discussed on pages 6-3 through 6-5, the City considered off-site locations, but dismissed these alternatives from further analysis because of their feasibility and because they would not clearly address the project’s significant environmental effects. As discussed on pages 6-11 through 6-13, the Draft EIR also evaluated a Mixed-Use Costco Center Alternative (Alternative 3) that would adjust the land use mix on the project site to include high-density residential development. As shown in Table 6-1 of the Draft EIR, the environmental effects of this alternative would be largely similar to those of the proposed project.

As explained in the Draft EIR (page 2-1), the project site is designated Community Commercial in the City’s General Plan. The City has planned the area for commercial development that serves the nearby residents. The comment does not provide evidence to support the conclusion that developing the project site with strictly residential land uses or developing the proposed project at an alternative location would avoid or substantially lessen any of the significant effects of the proposed project; therefore, there is no basis for considering such alternatives in the Draft EIR. In addition, the comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Responses to Comments Ascent
City of Fresno
2-122 Costco Commercial Center Project Final EIR
Letter I89 Janet Bergman
August 15, 2023
Response I89-1
The comment expresses opposition to the proposed project, raising concerns related to traffic and safety hazards for school-aged children. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation, including safety hazards. The comment also mentions a local park, which may be a reference to the stormwater retention basin east of Riverside Golf Course, but does not identify specific environmental concerns related to this facility.

The Draft EIR includes a discussion related to access to recreational facilities on page 3.12-4. The Draft EIR explains that the project would not physically obstruct access to existing recreational opportunities. As explained further in Response I5-1, pedestrian mobility in the vicinity may be improved through development of the project because it includes connections to planned pedestrian infrastructure. Further, the City of Fresno has met with the Central Unified School District regarding the proposed project to ensure that project-related truck deliveries do not pose a safety hazard for students at school bus drop-off/pick-up locations.

The comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-123

Responses to Comments Ascent
City of Fresno
2-124 Costco Commercial Center Project Final EIR
Letter I90 Robin Snowden
August 17, 2023
Response I90-1
The comment expresses opposition to the proposed project and raises concerns related to several topics discussed in detail below.

The comment raises concerns related to aesthetics and lighting. Section 3.1, “Aesthetics,” of the Draft EIR includes an analysis related to these topics. As explained in the Draft EIR, the City analyzed both the potential for degradation of views of the site and potential for conflict with applicable regulations that govern scenic quality; private views from personal residences are not evaluated pursuant to CEQA. The Draft EIR determined that these impacts would be less than significant. As described in Impact 3.1-1 (page 3.1-8):

Implementation of the project would alter views by adding built-environment elements on a vacant parcel, but would not substantially degrade existing views of the project site or the surrounding areas. Elements of the project’s design (such as building height, color, massing, architectural detailing, landscaping, and setback requirements) would be consistent in visual character with the surrounding development, and consistent with applicable regulations pertaining to aesthetics. These established standards would result in a development that would not detract from or degrade the existing visual character or quality of public views of the site and its surroundings.

As discussed on page 3.1-9 (Impact 3.1-2), all light fixtures would be downcast and would not exceed the City’s 0.5- foot-candle standard for light spillover onto adjacent residential areas. The Draft EIR concluded that the project’s impact related to lighting would be less than significant.

The comment raises concerns related to traffic and pedestrian safety. Section 3.13, “Transportation and Circulation,” of the Draft EIR includes an analysis related to these topics. This comment is similar to Comment I4-1 and I5-1. Please refer to Responses I4-1 and I5-1 for a discussion regarding the proposed project’s impacts related to transportation, including safety hazards.

The comment also raises concerns related to property values and security. As discussed in Response I4-2, CEQA requires lead agencies to consider the effects of a proposed project on the physical environment. The proposed project’s economic and social effects on in the vicinity of the project site is not, in and of itself, a significant impact under CEQA. The potential for indirect environmental impacts to occur as a result of the proposed project’s contribution to social or economic changes in the project vicinity is addressed in Response I10-1. An evaluation of the potential for the Costco relocation and gas station to result in urban decay impacts was conducted by ALH Urban and Regional Economics in 2023. This analysis concludes that the proposed Costco Commercial Center is not anticipated to cause or contribute to conditions of urban decay in the City of Fresno (see Appendix A).

The comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Ascent Responses to Comments
City of Fresno
Costco Commercial Center Project Final EIR 2-125
Letter I91 Shauna Sandin
August 18, 2023
Response I91-1
The comment expresses opposition to the location of the proposed project and suggests an alternative location based on anticipated traffic. Please refer to Response I4-1 related to the discussion of traffic in CEQA documents.

The comment identifies an area “over the railroad tracks” as a potential alternative project site. The exact location is unclear; however, this area is currently under development for the California Highspeed Rail and may not be a feasible location for the project. Moreover, as explained in Response I37-1, the City is not obligated to evaluate alternatives that would reduce traffic impacts because generating traffic is not an impact under CEQA. The comment does not provide evidence to support the conclusion that developing the proposed project at an alternative location would avoid or substantially lessen any of the significant effects of the proposed project; therefore, there is no basis for considering such alternatives in the Draft EIR. In addition, the comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I92 Charles Yuvienco
August 19, 2023
Response I92-1
The comment expresses opposition to the project and states that the project would result in negative social and environmental impacts. This comment does not identify specific issues related to the adequacy of the Draft EIR.

Specific concerns expressed by the commenter are addressed in Responses I92-2 through I92-6.

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Response I92-2
The comment states that the proposed project would result in environmental consequences, including traffic congestion, pollution, noise levels, loss of green space, and harm to local ecosystems. Section 3.3, “Air Quality,” Section 3.5, “Biological Resources,” Section 3.9, “Hydrology and Water Quality,” Section 3.12, “Public Services and Recreation,” and Section 3.13, “Transportation and Circulation,” of the Draft EIR include analyses related to these topics. The comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response I92-3
The comment states that the proposed project would exacerbate traffic issues on local roadways. Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation. As explained further in Response I5-1, pedestrian mobility in the vicinity may be improved through development of the project because it includes connections to planned pedestrian infrastructure. The comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment.

The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response I92-4
The comment speculates that the proposed project would threaten local businesses and result in economic hardship.

This comment is similar to Comment I10-1. Please refer to Response I10-1 for a discussion regarding the proposed project’s impacts related to the proposed project’s contribution to economic effects. No revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response I92-5
The comment states that the project would disrupt quality of life within the neighborhood, raising environmental concerns related to noise. Section 3.11, “Noise and Vibration,” of the Draft EIR includes an analysis related to this topic. This comment is similar to Comment I30-1. Please refer to Response I30-1 for a discussion related to the project’s impact related to noise.

The comment also raises concerns related to community disturbance. As discussed in Response I4-2, CEQA requires lead agencies to consider the effects of a proposed project on the physical environment. The proposed project’s social effects on neighborhoods in the vicinity of the project site is not, in and of itself, a significant impact under CEQA. However, the Draft EIR evaluates physical environmental effects that may indirectly relate to this topic. For example, Section 3.1, “Aesthetics,” evaluates potential impacts related to changes in visual character and quality of the project site and surroundings and Section 3.10, “Land Use and Planning,” evaluates potential impacts related to the physical division of existing communities.

The comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response I92-6
The comment provides closing remarks and suggests that alternative locations be considered. This comment is similar to Comment I37-1. Please refer to Response I37-1 for a discussion related to alternative locations. The comment does not provide evidence to support the conclusion that developing the proposed project at an alternative location would avoid or substantially lessen any of the significant effects of the proposed project. In addition, the comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I93 Darius Assemi
August 21, 2023
Response I93-1
The comment expresses support for the proposed project. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I94 Noel Delgado
August 21, 2023
Response I94-1
The comment expresses opposition to the location for the proposed project, raising concerns related to traffic and safety. This comment is similar to Comments I4-1 and I5-1. Please refer to Responses I4-1 and I5-1 for a discussion regarding the proposed project’s impacts related to transportation, including safety hazards. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I95 Ray Gonzales
August 24, 2023
Response I95-1
The comment requests information about the traffic patterns on West Spruce and Hayes Avenues. Pages 2-13 and 2- 14 of the Draft EIR include a description of site access and circulation relative to the proposed project. The proposed project would result in the extension of West Spruce Avenue from North Riverside Drive to the intersection with North Sandrini Avenue, which would consist of an asphalt roadway with curb, gutter, sidewalk, Class II bicycle facilities, and streetlights. The proposed project would not result in improvements on Hayes Avenue itself, but is proposing to reclassify a portion of West Herndon Avenue between north Riverside Drive and North Hayes Avenue from expressway to superarterial. The proposed reclassification would allow the construction of an intersection where West Herndon Avenue meets the private North Arthur Avenue right-of-way. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment.

The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I96 Jennifer Airheart
August 24, 2023
Response I96-1
The comment expresses concerns related to traffic delay and odors from operation of the gas station. Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA. Please refer to Responses I4-1 for further discussion regarding the proposed project’s impacts related to transportation.

Regarding odor from operation of the proposed gas station, the Draft EIR (Impact 3.3-5) concludes that this potential impact would be less than significant because “odors from gasoline and diesel fuel transfer would be concentrated on the site.” Fuel pumps “are not considered significant sources of odor to nearby receptors due to the high dissipation rates of benzene, the chemical component of gasoline associated with its notable odor. Additionally, SJVAPCD’s Rule 4622 would limit emissions of gasoline vapors from the transfer of gasoline into motor vehicle tanks, which would also serve to reduce odors from gasoline dispensing.” The comment also expresses concerns about operating hours and, but does not identify any specific environmental issues.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I97 Amy Zehring
August 25, 2023
Response I97-1
The comment expresses concerns related to the significant and unavoidable impact related to project-generated VMT. Further, as discussed on pages 3.13-15 through 3.13-18, the Draft EIR considered all applicable and feasible measures to reduce project-generated VMT from the most recent California Air Pollution Control Officers Association Handbook for Analyzing GHG Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity .

The proposed project includes mitigation to reduce VMT associated with employee commutes (Mitigation Measure

3.13-2); however, the primary source of the proposed project’s daily VMT is warehouse shopping by Costco members.

As noted on page 3.13-18 of the Draft EIR, the nature of Costco’s land use and business model is auto-oriented.

Members purchase items in bulk at Costco facilities, making walking, biking, or transit trips to the warehouse impractical for many. Therefore, the Draft EIR determined that no additional feasible mitigation measures are available to reduce the proposed project’s VMT impact to a less-than-significant level. As discussed in Response I4-1, CEQA does not preclude a public agency from approving or carrying out a project that has potential to result in significant and unavoidable impacts on the environment; however, the public agency must make findings for each impact and issue a statement of overriding considerations in order to approve the project. Further, although the proposed Costco relocation is anticipated to result in increased VMT, the project includes pedestrian infrastructure and trail connections that are anticipated to support reduced VMT in the area. For further discussion of project attributes that support VMT reduction, refer to Response O1-3 and Response I5-1.

The comment also raises concerns related to air pollution and noise. Section 3.3, “Air Quality,” and Section 3.11, “Noise and Vibration,” of the Draft EIR include an analysis related to these topics. Please refer to Response I5-1 for a discussion regarding the proposed project’s impacts related to air quality and Response I30-1 for a discussion regarding the proposed project’s impacts related to noise.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I98 Brian and Sherryl Kellogg
August 24, 2023
Response I98-1
The comment expresses concerns related to traffic, circulation, access, pedestrian safety, and unhoused populations.

Please refer to Responses I4-1 and I5-1 regarding transportation and pedestrian safety and unhoused populations, and Response I32-1 regarding site access and circulation. This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response I98-2
The comment requests information regarding the number of jobs the proposed project would create. As stated on page 1-5 of the Draft EIR, the project would not create new employment positions because it is assumed that the employees working at the existing Costco facility would relocate to the new facility.

The comment also expresses concerns that the project site would not be developed with residential land uses. As noted on page 3.10-3 of the Draft EIR, the existing City of Fresno General Plan designation for the project site is Community Commercial (CC), which allows for a variety of commercial facilities including medium-scale retail, office, civic and entertainment uses, supermarkets, drug stores, and supporting uses. The project site is zoned CC/EA/UGM/cz, which allows for the development of medium-scale retail, office, civic and entertainment uses, supermarkets, drug stores, and supporting uses. Section 3.10, “Land Use and Planning,” of the Draft EIR includes an analysis related to the topic of land use. As discussed on pages 3.10-5 through 3.10-7 of the Draft EIR, a general plan amendment, rezone, and conditional use permit would be needed to ensure that the proposed project is consistent with the land use and zoning for the project site. The Draft EIR concludes that the proposed general plan amendment and zoning change would not conflict with City policies adopted for the purposes of avoiding or mitigating an environmental effect and the impact would be less than significant (Impact 3.10-1).

The comment also expresses concerns related to property values. The proposed project’s effects on property values in the vicinity of the project site is not, in and of itself, a significant impact under CEQA. The potential for indirect environmental impacts to occur as a result of the proposed project’s contribution to social or economic changes in the project vicinity is addressed in Response I10-1.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response I98-3
The comment summarizes concerns previously stated in Comment I98-1 related to traffic and access. Refer to Response I98-1.

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Letter I99 Rodger B. Jensen
August 25, 2023
Response I99-1
The comment provides a description of the history of the project site, including previous land use designations and zoning, and states that the history of the site should be taken into account. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment.

The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response I99-2
The comment describes transportation improvements that are projected to reduce vehicle traffic in the project vicinity. The comment also states that the Draft EIR provides adequate analysis regarding project-generated traffic and provides effective mitigation measures. No revisions to the Draft EIR are necessary in response to this comment.

The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response I99-3
The comment expresses support for the proposed project and states that the proposed project would result in benefits to the local economy and nearby communities. This comment does not address the adequacy of the Draft EIR analysis; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I100 James Fleck
August 28, 2023
Response I100-1
The comment expresses opposition to the location for the proposed project, raising concerns related to traffic, air pollution, noise, and light pollution. Although the topic of traffic congestion is a factor for consideration by the decision-makers in acting on the proposed project, pursuant to CCR Section 15064.3, automobile delay and similar metrics relating to vehicular roadway capacity and traffic congestion are not considered a significant impact on the environment under CEQA. Please refer to Response I4-1 for a discussion regarding the proposed project’s impacts related to transportation, Response I5-1 for a discussion regarding the proposed project’s impacts related to air quality, and Response I30-1 for a discussion regarding the proposed project’s impacts related to noise and lighting.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

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Letter I101 Gabriel Ledesma
August 28, 2023
Response I101-1
The comment notes that the project site is near FMFCD’s Basin EG. Basing EG is an existing basin of approximately 7 acres that is located northeast of the project site, north of Spruce Avenue and east of Riverside Golf Course. Because Basin EG discharges into the San Joaquin River, the comment indicates that stormwater from the project site has the potential to affect water quality in the San Joaquin River and federally listed Spring-Run Chinook Salmon (Oncorhynchus tshawytscha). As explained further in Response I101-2, the project site would not contribute substantial stormwater runoff to FMFCD’s Basin EG.

Response I101-2
The comment asks whether stormwater from the project site would be discharged to FMFCD’s Basin EG during or after construction. Referencing the description of the existing stormwater infrastructure in Section 3.8, “Hydrology and Water Quality,” (page 3.9-7) the comment also requests update of the description of the EG drainage basin to reflect discharge into the San Joaquin River if the project would contribute stormwater to the basin.

The Draft EIR acknowledges that the FMFCD “system is designed to move water from a basin and discharge to other FMFCD facilities, or to irrigation canals, creeks, and the San Joaquin River” (page 3.9-6). Further, as explained in Impact 3.9-1 (page 3.9-9) of the Draft EIR, “the project would be designed in a matter consistent with FMFCD’s Storm Drainage and Flood Control Master Plan.” As part of the Spruce Avenue extension that would be constructed to complete the City’s planned transportation infrastructure, an inlet that would connect to Basin EG would be constructed northeast of the project site. This inlet is shown in the Storm Drainage and Flood Control Master Plan and was identified as a necessary infrastructure improvement in early consultation with FMFCD. This inlet would serve the transportation infrastructure but would not convey stormwater drainage from the project site.

As described on page 3.9-6 of the draft EIR, “[t]he project site is located within the EH local stormwater drainage area.” Stormwater from the project site would be conveyed to the west and would not contribute runoff to Basin EG.

Therefore, the draft EIR does disclose the connectivity of the FMFCD system to the San Joaquin River and explains that the project would not contribute stormwater to Basin EG. For these reasons, no revisions have been made to the draft EIR in response to this comment.

Response I101-3
The comment notes that storm drainage infrastructure would be constructed in conjunction with the Spruce Avenue extension from North Arthur Avenue west to North Riverside Avenue. As explained above and in the Draft EIR, the project site and all development west of North Arther Avenue “would be directed to existing FMFCD drainage facilities in North Riverside Drive, West Spruce Avenue, and West Herndon Avenue, located within the EH local stormwater drainage area” (see Draft EIR page 3.9-11) while the “area east of North Arthur Avenue is in the EG basin and drainage is directed to Spruce Avenue (Chapman, pers. comm., 2021)” (Draft EIR pages 3.9-6 and 3.9-7). An inlet would be constructed as part of the extension of Spruce Road that would convey stormwater from the area east of North Arther Avenue to Basin EG.

Response I101-4
The comment suggests that the City contact the Central Valley Regional Water Quality Control Board if the project would result in runoff to Basin EG during construction. As explained in Section 3.8, “Hydrology and Water Quality” (page 3.9-8), “earth-disturbing activities during construction would be subject to the NPDES Permit Program, administered by the Central Valley RWQCB. As required by NPDES, the project would be required to obtain coverage under the General Permit for Discharges of Storm Water Associated with Construction Activity (Construction General Permit Order 2009-0009-DWQ).” The Construction General Permit requires development and implementation of a stormwater pollution prevention plan and best management practices such as maintaining or creating drainages to convey and direct surface runoff away from bare areas, and installing physical barriers such as berms, silt fencing, waddles, straw bales, and gabions. Risk level is determined as part of this process; it is calculated based on location Ascent Responses to Comments
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and soil conditions and effects monitoring and reporting requirements. No revision to the Draft EIR is required in response to this comment.

Response I101-5
The comment suggests that the City contact FMFCD about post-development requirements if the project would result in runoff to Basin EG after construction. The City engaged with FMFCD early in the environmental review process and has included the inlet to Basin EG at the express request of FMFCD, which indicated that existing and planned infrastructure have been designed to serve buildout of this area. The City of Fresno, FMFCD, Fresno County, the City of Clovis, and California State University Fresno are covered under the region-wide Central Valley RWQCB General Permit for Stormwater Discharges from MS4s (Order R5-2016-0040). This Region-wide MS4 Permit requires that the City and its co-permittees implement water quality and watershed protection measures for all development projects. See Impact 3.9-1 (Draft EIR page 3.9-9) for further discussion.

As further explained in Section 3.14, “Utilities,” (Draft EIR page 3.14-12) FMFCD’s Post-Development Standards Technical Manual describes the stormwater management requirements for “Priority Projects,” which includes commercial developments greater than 100,000 square feet, automotive repair shops, parking lots 5,000 square feet or greater with 25 or more parking spaces and potentially exposed to urban runoff, streets and roads; and retail gasoline outlets. All Priority Projects must mitigate the Stormwater Quality Design Volume or Stormwater Quality Design Flow through low-impact development or treatment-based stormwater quality best management practice or a combination thereof. The Draft EIR concludes that development of the proposed on-site stormwater facilities would adequately minimize the effect of the additional impervious area on peak runoff volumes and additional stormwater facilities would not be required.

Response I101-6
The comment provides conclusory remarks about the sensitivity of biological resources in the San Joaquin River and the importance of disclosing potential impacts. As described above in Responses I101-1 through I101-5, the project site would not discharge untreated stormwater runoff to the San Joaquin River via FMFCD’s Basin EG. The project is not anticipated to impact aquatic species.

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Letter I102 Lauryn Medina
September 1, 2023
Response I102-1
The comment expresses concerns related to traffic, congestion, safety, and noise. Section 3.11, “Noise and Vibration,” and Section 3.13, “Transportation and Circulation,” of the Draft EIR include analyses related to these topics. This comment is similar to Comments I4-1, I5-1, and I30-1. Please refer to Responses I4-1 and I5-1 for a discussion regarding the proposed project’s impacts related to transportation and safety and Response I30-1 for a discussion regarding the project’s impacts related to noise. This comment does not offer any specific concern related to the analysis and conclusions in the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response I102-2
The comment expresses concerns related to air pollution and associated health effects. Section 3.3, “Air Quality,” of the Draft EIR includes an analysis related to these topics. This comment is similar to Comment I5-1. Please refer to Response I5-1 for a discussion regarding the proposed project’s impacts related to air quality. Further, health risks associated with construction and operation of the proposed project are summarized in Table 3.3-7 of the Draft EIR.

The Draft EIR states that the proposed project would not expose receptors to a cancer risk or a noncancer chronic and acute hazard index above applicable thresholds established by the San Joaquin Valley Air Pollution Control District and concludes that the impact would be less than significant (Impact 3.3-3).

The comment also offers an opinion about the potential for the proposed project to generate “loose trash” that could end up in the San Joaquin River. The comment incorrectly characterizes the San Joaquin River as “directly behind the proposed Costco.” The project site is approximately 0.35 mile south of the San Joaquin River; the Riverside Golf Course is located between the project site and the San Joaquin River.

This comment does not offer any specific concern related to the adequacy of the Draft EIR; therefore, no revisions to the Draft EIR are necessary in response to this comment. The comment is included in the record, which will be considered by the decision makers in their deliberations over potential approval of the proposed project.

Response I102-3
The comment summarizes concerns previously stated in Comments I102-1 and I102-2 related to public health. Refer to Responses I102-1 and I102-2.

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Letter I103 Daniel Brannick
August 31, 2023
Response I103-1
The comment expresses opposition to the location for the proposed project and provides introductory remarks summarizing the content of the letter, which are responded to in Responses I130-2 through I130-8, below. The comment expresses a desire to identify an alternative project site that would avoid “significant costs” while substantially fulfilling the stated project objectives. No details about the perceived costs or alternatives are provided.

Response I103-2
The comment raises several questions related to the inclusion of the MDO component of the project on a site that is proposed for redesignation as General Commercial through a General Plan amendment and rezone. The proposed land use and zoning designations were determined as the most appropriate for the application by City staff; a Director’s determination was not made. The purpose of the CG zoning designation is stated in the Fresno Development Code (Section 15-1202) as follows:

The CG district is intended to accommodate a range of retail and service uses that are not appropriate in other areas because of higher volumes of vehicle traffic and potential impacts on other uses. 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.

Permitted uses within the CG district include General Retail and Large Format Retail. Costco is a Large Format Retail use, defined to mean:

Retail establishments (over 80,000 square feet of sales area) that sell merchandise and bulk goods for individual consumption, including membership warehouse clubs.

Therefore, the Costco retail warehouse is permissible as the primary use on the site.

The comment expresses an opinion that the MDO may not meet the definition of an accessory use. Fresno Development Code section 15-2703 defines “accessory uses” as follows:

An accessory use shall be incidental, related, appropriate, and clearly subordinate to the principal use or building to which it relates; under the same regulations applied to the principal use in any zoning district; and where the accessory use does not alter the principal use.

The MDO element of the building would facilitate efficient delivery of big and bulky items, including furniture, major appliances, patio furniture, televisions, fitness equipment, mattresses, and grills. The MDO activities are subordinate to the typical Costco layout and experience and would not alter the principal commercial use (Holliday, pers. comm., 2023). For this reason, the City determined that the MDO falls within the accessory use classification and an “employment" designation was not pursued. As an accessory use to the retail warehouse, the MDO is allowable in the General Commercial designation.

By way of background, Costco purchased Innovel Solutions in 2020 to bring in-house the last-mile logistics capability for delivering such items to members, complete with “white glove” installation of appliances. Innovel’s assets included numerous free-standing MDOs. Costco plans to integrate this business model to reflect members’ evolving shopping patterns and demands. The proposed project would be one of 17 new, integrated MDO locations planned by the end of 2024. Costco already has eight existing warehouses that include MDOs: Ankeny, Iowa; Tulsa, Oklahoma; Gypsum, Colorado; Warrenton, Oregon; Ridgeland, Mississippi; Springfield, Missouri; Duluth, Minnesota; and Billings, Montana.

Nearly all of these sites are zoned within some type of commercial district and have a related commercial designation in that state’s version of a general plan (Holliday, pers. comm., 2023).

Costco describes the MDO component of the building as integral to Costco’s move to an omnichannel retail experience, where members can better interact with Costco to shop, buy, and return goods through multiple locations or platforms (Holliday, pers. comm., 2023). Whether members purchase items online or in the warehouse, Ascent Responses to Comments
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large goods can be delivered to them from the MDO space. The MDO space functions much like the storage/warehousing element of a typical home improvement or furniture store, allowing these types of activities:

X Costco can pull in-stock items from the MDO and display them on the sales floor in a vignette to allow members in-person visibility to online inventory. For example, displaying a sofa sectional that is only available for purchase online allows members to see/touch/sit in the item before they make their purchase.

X Members can view and then purchase “big and bulky” items from the sales floor and have them delivered out of the MDO space.

X Members who purchase items online that are in-stock at the MDO can receive delivery in as soon as two days, much quicker than if items were stored in a large regional distribution center.

X Member home delivery issues can be handled in-person at the MDO within the building rather than directing members to a national call center for resolution.

Furthermore, the MDO is physically and functionally unified with the other activities within the Costco structure, providing operational efficiencies, such as:

X Employee continuity: Employees are shared among the building activities when needed (e.g., to cover sick calls and vacations and to assist during periods of unexpected high volume). There are cross-training opportunities for employees within the different focus areas within the Costco building. Having Costco’s various activities within the building facilitates daily opening and closing management coverage.

X Building synergy: All elements reside within one contiguous building that shares lighting, HVAC, security and utility systems, as well as employee facilities like restrooms, breakrooms, quiet rooms, and meeting rooms.

X Operational efficiencies: Equipment is shared throughout the entire warehouse building, including forklifts, compactors, cardboard balers, time clocks, and more.

X Transportation efficiencies: There is a shared receiving area to serve the sales floor and the MDO. Mixed load transportation/distribution allows Costco to combine in a single trailer merchandise destined for the sales floor or the MDO to deliver full trailers to the location, reducing the need to distribute “less-than-load” shipments. Not only does this make for a more efficient commercial operation, but it also minimizes truck miles and emissions.

After careful review and consideration, City staff reaffirms the determination that the General Commercial designation is appropriate application of the Development Code. The operation of the entire facility, including the MDO component, is fully and accurately described in the Draft EIR, providing the public with an opportunity to understand and provide meaningful comment on the proposal. No revisions to the Draft EIR are necessary in response to this comment.

Response I103-3
The comment states that there is not adequate information provided in the Draft EIR “to fully ascertain the project’s potential lighting- and glare-related impacts.” The comment acknowledges the analysis based upon the City’s lighting regulations and modeled light trespass as reference points in evaluating and measuring effects on existing residents but suggests that additional information should be presented to more comprehensively evaluate the proposed change from existing conditions. As explained below, the analysis in the Draft EIR meets the standards for adequacy and enables a decision on the project that accounts for environmental consequences.

The comment indicates that more specific information about the type of lighting equipment is necessary to inform public review and allow a comparison to “normal” lighting. As noted in the comment Chapter 2, “Project Description,” (page 2-10) of the Draft EIR, provides the following explanation of the lighting plan, which includes information about illumination intensity, light standard size compared to fixtures typically permitted in commercial districts, and restrictions within the PG&E easement.

The project applicant has applied for a PD Permit to request deviations from Section 15-2015 of the Municipal Code, which specifies that lighting fixtures in commercial districts have a maximum height of 25 feet. Costco aims to achieve 2.5 foot-candles of light throughout the parking area to maximize safety within Responses to Comments Ascent
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the parking lot. This level of lighting is intended to provide security and safety for drivers and pedestrians navigating the parking lot at night. The project would include light fixtures with a maximum height of approximately 36.5 feet instead of the allowed 25-foot-tall fixtures to reduce the number of lights needed to achieve the desired light levels within the parking field. The proposed 36.5-foot-tall light poles also allow a more diffuse distribution of light, reducing the difference in light levels in the areas between poles. The taller lighting also ensures that the area beneath the PG&E easement that runs directly through the parking field has adequate lighting. (No structures, including light poles, are allowed within this overhead easement.) Off- site glare and light spillover from parking lot light fixtures would be minimized by using less powerful lights on fixtures at the edge of the property.

The analysis in Section 3.1, “Aesthetics,” provides a similar summary of these proposed conditions. The impact analysis in this section evaluates the potential for the project to create a new source of substantial light or glare that would adversely affect nighttime views of the area. The threshold is appropriately based on the sample questions provided in Appendix G to the State CEQA Guidelines and is informed by the City’s standards for light and glare. The Draft EIR (page 3.1-2) summarizes the various elements of the Fresno Municipal Code related to lighting. These standards prevent illumination spillover or glare onto adjoining properties and prohibit interference with normal operation of adjacent property. As explained in the analysis of Impact 3.1-2 (Draft EIR page 3.1-9), the applicant would be required to demonstrate that all fixtures would be downcast and would not exceed the 0.5-foot-candle standard established in Section 15-2420 of the Fresno Municipal Code and the Bullard Community Plan for light spillover onto adjacent residential areas.

The comment does not provide evidence to support the claim that the Draft EIR does not provide adequate information or analysis of potential impacts. The analysis in the Draft EIR meets the standards for adequacy and enables a decision on the project that accounts for environmental consequences. There is no obligation for the City to perform exhaustive evaluation where the standard approach to analysis is determined sufficient and appropriate.

Further, although the comment states that projects with “substantial lighting components,” such as athletic fields, often conduct separate technical analyses to model light impacts, it also concedes that the “Costco project likely does not entail as intense lighting impacts as a high school football stadium.” Nonetheless, the applicant has prepared Figure 2-1, below, which provides the detailed site lighting plan, including pole detail, requested in the comment.

Figure 2-1 demonstrates that no lighting spillover is anticipated onto adjacent residential areas and supports the analysis and conclusions in the Draft EIR. The grid of light intensity indicates light levels below the 0.5 foot-candle threshold on adjacent roadways.

The comment also indicates that the effect of lighting on wildlife should be evaluated in the Draft EIR. As evidence, a link to an article about the effects of light pollution on migratory birds is provided. Specifically, the article suggests turning off exterior lights during peak migration season. As explained in the Draft EIR (see Section 3.1, “Aesthetics”), the proposed lighting is required for safety and cannot be turned off. Where lights must remain on, limiting light pollution minimizes the potential for effects on migratory birds. The proposed exterior lights would be compliant with established Fresno Municipal Code requirements related to shielding and minimizing the illumination of the surrounding landscape. As indicated in the Draft EIR “[s]hielding requirements in Section 15-2015 of the Fresno Municipal Code would also prohibit light pollution associated with upcast light…” (see page 3.1-9).

Furthermore, Section 3.5, “Biological Resources,” includes information about the presence of migratory birds on and around the project site. As explained on page 3.5-12 of the Draft EIR:

According to the California Essential Habitat Connectivity Project, the project site is not located within a Natural Landscape Block or Essential Habitat Connectivity area (Spencer et al. 2010). Project development would not interfere substantially with the movement of any native resident or migratory wildlife species because the project site does not currently provide an important connection between any areas of natural habitat that would otherwise be isolated. While wildlife may use the project site for nesting and roosting or may pass through the site occasionally, it is unlikely that the project site functions as a significant wildlife movement corridor or wildlife nursery site due to the lack of high-quality natural habitat and extensive residential and commercial development surrounding the site.

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Source: Image produced and provided by TE Inc, 2022, adapted by Ascent in 2023.

FFigure 2-1 Photometric Plan

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Response I103-4
The comment raises issues associated with biological resources. The first issue raised relates to the proximity of the project site to the San Joaquin River. The comment suggests that the Draft EIR leaves the impression that the analysis focuses primarily on the project site, and not the river. As stated in the Draft EIR (page 3.5-2) the project site is located 0.35 mile from the south of the San Joaquin River. The golf course is located between the project site and the river; moreover, a paved parking lot and several structures associated with the golf course intervene between the river and the project site. There is existing fencing between the golf course and the project site. The project site is surrounded by existing development and the golf course. There is no riparian habitat or other habitat associated with the river on or near the project site. The project site does not provide an important wildlife movement corridor. As stated in the Draft EIR (page 3.5-12), according to the California Essential Habitat Connectivity Project, the project site is not located within a Natural Landscape Block or Essential Habitat Connectivity area. Project development would not interfere substantially with the movement of any native resident or migratory wildlife species because the project site does not currently provide an important connection between any areas of natural habitat that would otherwise be isolated. While wildlife may use the project site for nesting and roosting or may pass through the site occasionally, it is unlikely that the project site functions as a significant wildlife movement corridor or wildlife nursery site due to the lack of high-quality natural habitat and extensive residential and commercial development surrounding the site. Note also that CDFW has reviewed the Draft EIR and indicated concurrence with the results of the biological resources analysis. See Comment A1-2.

The comment expresses concern about the cumulative effects of development in proximity to the San Joaquin River.

It is important to note that this project site was designated in the City’s General Plan for commercial development.

The cumulative effects of implementing the General Plan land use diagram, including urban designations near the San Joaquin River, were previously evaluated for development in the City’s Geneal Plan Program EIR (City of Fresno 2020). Consistent with the conclusions of the Draft EIR prepared for the proposed project, the City’s General Plan Program EIR, which evaluated implementation of planned development in this area, concludes that impacts associated with interference of wildlife movement are less than significant. (See Impact BIO-4 of the City’s General Plan Draft Program EIR.) In addition, the Draft EIR includes an analysis of cumulative effects to biological resources based on known and reasonably foreseeable development in the project area. Impact 4-5 (Draft EIR pages 4-9 and 4- 10) concludes that the project would not result in a considerable contribution to any significant cumulative impact related to biological resources.

The comment also raises the question whether the surveys or sections were prepared by a qualified biologist.

Although Draft EIR Chapter 7, “Report Preparers,” identifies the Biologist and Senior Biologist that contributed to preparation of the Draft EIR, the commenter is correct that Section 3.5, “Biological Resources,” does not specify who prepared the section and who conducted the survey. Therefore, to provide clarity, text revisions are made to Section 3.5 of the Draft EIR.

This section was prepared by an Ascent biologist and addresses biological resources known or with potential to occur on or near the project site and describes potential effects of implementation of the project on those resources.

An Ascent biologist conducted reconnaissance-level surveys of the project site on November 1, 2021 and June 20, 2022. The project site consists of an undeveloped parcel in the northwestern portion of the city of Fresno, approximately 0.35 mile south of the San Joaquin River. The site is surrounded by the Riverside Golf Course to the north; residential development to the west; industrial and residential development to the east; and West Herndon Avenue, commercial development, some undeveloped parcels, and the Rio Vista Middle School to the south. There is a large transmission tower in the northwest corner of the project site. No raptor nests were observed on this tower; however, several owl pellets (likely attributed to a barn owl [ Tyto alba] or great horned owl [Bubo virginianus]) and California ground squirrel (Otospermophilus beecheyi) bones were observed under Responses to Comments Ascent
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the tower during the reconnaissance-level survey on November 1, 2021, indicating that owls and likely other raptors use the tower as a roost site. California ground squirrel burrows are present throughout the project site and several squirrels were observed during the reconnaissance-level surveys on November 1, 2021, and June 20, 2022. There is a mound of soil directly adjacent to the northern boundary of the project site with many California ground squirrel burrows.

The commenter raises potential impacts of the proposed golf course netting on biological resources and generally references other CEQA documents prepared for projects requiring “similar netting.” According to information prepared by Tanner Consulting Group, which specializes in golf course design, golf barrier netting is a woven poly material that is installed tautly, making it safe for birds to land on and making it difficult for birds to become trapped.

Tanner Consulting Group has surveyed and monitored numerous golf course and driving range locations, including netting installed at the San Jose State University Men’s and Woman’s Golf Training Center, and reported no evidence of bird entrapment or death (see Appendix B). Importantly, the golf course already includes nets on a large stretch of its property along Riverside Drive. The City, which operates Riverside Golf Course, has not had any issues with bird or bat entanglement in the existing golf course nets along North Riverside Avenue (Berry, pers. comm., 2023). Based on experience with existing nets at this location and the testimony of industry experts with experience in other locations, the City does not anticipate significant impacts to migratory birds from the proposed netting along the Spruce Avenue extension.

Response I103-5
The comment includes a summary and discussion of background related to GHG and CEQA and suggests that the Draft EIR approach to assessing consistency with the City of Fresno Greenhouse Gas Reduction Plan (GHGRP) is flawed. The comment reaches two main points, which are 1) there are other GHG plans, policies, and regulations that the GHGRP may not address and 2) language in the Draft EIR suggests there is a conflict and/or inconsistency in the approach to assessing GHG.

Regarding the scope of the plans evaluated in the Draft EIR, the approach to evaluate the consistency with the GHGRP is reasonable and substantiated. The GHGRP is considered a “Qualified Plan,” according to CEQA Guidelines Section 15183.5(b), and is the latest qualified plan available by the City of Fresno. Thus, it is appropriate for the City to assess whether the project complies with the requirements in the GHGRP as the measure of GHG impacts. In certain circumstances, consistency with a qualified GHG reduction plan can be used as a basis for dismissal of a project from detailed GHG emissions modeling and evaluation pursuant to CEQA Guidelines Section 15183.5. However, to do so a project must be consistent with the land use designations in the City’s adopted General Plan (which are the basis for the emissions forecasts in the GHGRP). Because the project involves a General Plan amendment, the Draft EIR conservatively assumes that GHG emissions from the project could be greater with the General Plan amendment as compared to the land use designation currently adopted in the General Plan. As such, the GHGRP consistency checklist was not used in the analysis and the EIR does not streamline the evaluation of GHG emissions per Section 15183.5 of the State CEQA Guidelines.

Instead of employing the GHGRP checklist, a detailed evaluation of GHG impacts, including emissions modeling, was conducted to determine whether the project would comply with the reduction goals of the GHGRP. This modeling applies the same modeling approach as used in the GHGRP to quantifiably demonstrate that the project's design features and resulting emissions reductions would be sufficient to meet or exceed the GHGRP’s reduction targets.

Given the technical work and data that underlies the GHGRP, the City’s decision to use this Fresno-specific threshold is supported by substantial evidence. Further, due to this demonstrated consistency, the EIR evaluation can tier from the existing programmatic review of the GHGRP’s consistency with other State and local plans and regulations.

In addition, the Draft EIR includes a consistency evaluation of the 2022 Scoping Plan Update and Fresno Council of Governments (COG) 2022 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) in Appendix F of the Draft EIR. Specifically, page 42 of Appendix F includes the following discussion of consistency with statewide emissions reduction targets:

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 Ascent Responses to Comments
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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.

Similarly, the project would be consistent with the GHG reduction goals established in the RTP/SCS (Appendix F, page 43). The analysis concludes (Appendix F, page 45):

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.

As support for this conclusion, Tables C-1 and C-2 from Appendix F of the Draft EIR and provided below for reference, include detailed matrices of plan consistency.

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Thus, the concern expressed in the comment that these other plans are not addressed is unfounded. The GHG section also includes discussion of the current long-term goals of the state. The Draft EIR discusses statewide GHG emission targets, the CARB 2022 Scoping Plan, transportation-related standards and regulations in California, legislation associated with electricity generation, California Building Energy Efficiency Standards, California Integrated Waste Management Act, and California’s Climate Adaptation Strategy in Section 3.7.1.

Regarding the suggestion that the Draft EIR includes logically inconsistent and/or misleading explanations regarding the GHG and VMT analyses, there is a distinction between exceeding established VMT thresholds set by the City to implement Senate Bill (SB) 743 related to transportation and conflicting with GHG reduction programs derived from SB 375 and Fresno COG’s RTP/SCS. As explained further below, Appendix F of the Draft EIR properly evaluates consistency with both the CARB Scoping Plan Update (and related VMT priorities) and the Fresno COG RTP/SCS.

The evaluation of VMT in Section 3.13, “Transportation and Circulation,” is based upon the City’s adopted VMT threshold, which was developed to meet the State requirements set by SB 743 and address CEQA Guidelines Section 15064.3. As explained in the “Methodology,” subsection (page 3.13-9), using this threshold, any net increase in total VMT would indicate a significant impact. Therefore, the transportation analysis appropriately evaluates the VMT per the City’s VMT guidelines and thresholds of significance.

The GHG analysis assesses how the project is consistent with the Fresno COG RTP/SCS because this plan includes aspects that are focused on addressing GHG and climate change. As discussed above, however, the VMT analysis is not a specific criterion to this consistency analysis. The Draft EIR addresses consistency with the RTP/SCS in Table C-2 (Appendix F of Draft EIR) and finds that the project will be consistent with the overall goals of the RTP/SCS, and would not impede the implementation of the RTP/SCS. More specifically, the comment claims the Draft EIR includes a double standard in assessing consistency of the Fresno COG RTP/SCS and 2022 Scoping Plan Update. This is not accurate, as the Draft EIR fully and consistently addresses impacts and benefits within the transportation and GHG sections. What the comment claims as a double standard is a conflation of a transportation impact with GHG emissions that are inconsistent with state and local planning.

While there is a well-understood relationship between VMT and generation of GHG emissions, and generation of certain levels of VMT is used in some jurisdictions as a trigger for a detailed GHG analysis, it is not uncommon for projects that have a significant VMT impact to not exceed established GHG emissions thresholds through the application of project elements or other commitments that address sources of GHG emissions beyond VMT. In these circumstances, detailed GHG emissions modeling is conducted to forecast emissions and identify whether the total emissions would exceed GHG thresholds adopted to align with state and regional GHG reduction targets. In some cases, as with the proposed project, this detailed modeling demonstrates compliance with adopted GHG standards.

In summary, the environmental topics of VMT within a transportation analysis and of GHG emissions in a GHG section are two different things judged by two different thresholds of significance. If they were synonymous, they would not be separately evaluated. A significant VMT impact (based on local/regional travel patterns) does not equate to a significant GHG impact (based on a broader scale). The detailed modeling provided in Appendix F of the Draft EIR provides the appropriate connections between the VMT and the generation of GHG emissions. VMT as a metric does not account for vehicle characteristics, fuel type, emission standards, and fleet-level standards, all of which directly influence GHG emissions. For example, VMT generated by a gasoline vehicle is not equal to VMT by an electric vehicle because electric vehicles have zero tailpipe emissions. A similar argument can be made for hybrid vehicles and other near zero or zero emission vehicles (e.g., plug-in hybrid vehicles and fuel cell vehicles) in terms of GHG production. Thus, the GHG analysis incorporates evaluation of VMT in the GHG emissions inventory. This approach in the GHG section properly addresses the GHG emissions, not just the VMT, which is a metric to assess transportation issues as discussed above.

Similarly, the consistency analysis to the 2022 CARB Scoping Plan is an analysis specific to itself without a specific correlation to the result of the VMT analysis. As shown in the Draft EIR, the consistency with the 2022 CARB Scoping Plan assesses the project’s consistency with three areas: Transportation Electrification, VMT Reduction, and Building Decarbonization. The project demonstrates consistency with these three areas through installation of 45 EV spaces, project mitigation measures and design features related to transportation, and commitment to using renewable solar Ascent Responses to Comments
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energy for the operational electricity required by the Project (see Appendix F of the Draft EIR). While the 2022 Scoping Plan notes that the State should establish guidance for regional and local agencies regarding administration of SB 743 mitigation banking/exchanges and how revenue is spent, it does not specifically note that projects must align with SB 743 in order to meet the State’s emission reduction targets.

The Sierra Club v. County of Fresno case established that a reasonable effort should be made to explain the connection between exceeding a numerical threshold and effects on sensitive receptors or the environment. This relationship is not analogous to the relationship between VMT and GHG emissions. As explained above and in the Draft EIR, VMT is a component of GHG emissions modeling. The Draft EIR is compliant with the decision in the Sierra Club v. County of Fresno case.

Thus, the comment’s suggestion to conflate the various criteria and issues together and insinuation of conflict between the analyses included in the Draft EIR is not correct, nor is it substantiated. For the reasons summarized above, the Draft EIR fully and adequately discloses the project’s GHG impacts, including potential for policy and regulatory conflicts and inconsistencies. The Draft EIR fulfills the City’s obligation under CEQA to disclose potential effects of the project and to provide the public with a meaningful opportunity to comment on the project’s potential for substantial adverse environmental effects. There is no unidentified significant impact as suggested by the comment; therefore, the Draft EIR does not need to be recirculated for additional public review.

Response I103-6
The commenter indicates that requiring sound wall upgrades at existing residences may not be enforceable. Mitigation Measure 3.11-5 (Draft EIR page 3.11-29) states “sound wall construction would only be implemented if all of the property owners on the west side of North Riverside Drive between West Herndon Avenue and West Spruce Avenue collectively agree to the mitigation.” As pointed out by the commenter, the sound wall upgrade is one of two options in the Draft EIR for mitigating the impact to a level that is below the threshold of significance. The other mitigation option reduces traffic noise via installation of rubberized pavement. The analysis explains that "the interior SENL [single-event noise level] at the sensitive receptor nearest to where the heavy vehicle activity could occur would be approximately 66.4 SENL. Thus, SENL’s at the nearest noise-sensitive receptors would exceed 65 SENL" by 1.4 SENL.

Either of the two mitigation options in Mitigation Measure 3.11-5 would result in greater reductions than required to achieve consistency with the City’s noise threshold: rubberized hot-mix asphalt reduced by an average of 4 to 6 dB, while a barrier that breaks the line of sight between a source and a receiver will typically result in at least 5 dB.

It is reasonably foreseeable that affected residents would be amenable to a sound wall upgrade, which requires very little ongoing maintenance; therefore, there is good reason to include this measure. However, if affected residents decline the sound wall upgrade, the rubberized asphalt is an effective and feasible (albeit likely more expensive in the long-term) alternative mitigation measure identified in the Draft EIR. It is not uncommon or otherwise prohibited in CEQA to include multiple mitigation options, including some options where feasibility cannot be guaranteed, as long as there are equally effective feasible alternative mitigation options identified.

The text of Mitigation Measure 3.11-5 clearly states that the “project proponent shall implement noise reduction measures to ensure that exterior noise levels at residential land uses near the west side of North Riverside Drive do not exceed the City’s current noise standard of 65 dB L dn/CNEL. This performance standard can be achieved using either of the following measures.” The required noise reduction is, therefore, fully enforceable because the mitigation measure provides two paths to achieving the standard if one is determined to be infeasible. Nonetheless, the following language has been added to Mitigation Measure 3.11-5 to further clarify implementation.

MMitigation Measure 3.11-5: Implement Traffic Noise Reduction Measures along North Riverside Drive The project proponent shall implement noise reduction measures to ensure that exterior noise levels at residential land uses near the west side of North Riverside Drive do not exceed the City’s current noise standard of 65 dB L
dn/CNEL under existing-plus-project conditions. This measure is consistent with General Plan Policy NS-1-I, which recommends the use of design alterations to reduce noise impacts. This performance standard can be achieved using either of the following measures. Therefore, if one option is not implemented, the other would be required.:

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X Pave the roadway segment with rubberized hot-mix asphalt or equivalent surface treatment with known noise-reducing properties on top of the roadway surface. The rubberized hot-mix asphalt overlay shall be designed with appropriate thickness and rubber component quantity (typically 15 percent by weight of the total blend), such that traffic noise levels are reduced by an average of 4 to 6 dB (noise levels vary depending on travel speeds, meteorological conditions, and pavement quality) as compared to noise levels generated by vehicle traffic traveling on standard asphalt. Rubberized hot-mix asphalt has been found to achieve this level of noise reduction in other parts of California (Sacramento County 1999).

Pavement will require more frequent than normal maintenance and repair to maintain its noise attenuation effectiveness. The applicant shall fund the incremental cost for maintaining the roadway segment with the surface treatment.

X Construct a sound barrier taller than the 6-foot cinderblock wall that is currently present from West Spruce Avenue to West Herndon Avenue. The sound barrier shall be constructed of solid material (e.g., wood, brick, adobe, an earthen berm, boulders, or combination thereof). The reflectivity of each sound barrier shall be minimized to ensure that traffic noise reflected off the barrier does not contribute to an exceedance of applicable L
eq standards at other receptors. The level of sound reflection from a barrier can be minimized with a textured or absorptive surface or with vegetation on or next to the barrier. A barrier that breaks the line of sight between a source and a receiver will typically result in at least 5 dB of noise reduction (Caltrans 2013: 2-41; FTA 2018: 42). Barriers higher than the line of sight provide increased noise reduction (FTA 2018: 16). Scenic quality factors shall be taken into account during design, such as using more natural materials (e.g., berms and boulders) to reduce the visible mass of a wall. All barriers shall be designed to blend into the landscape along the roadway, to the extent feasible. Ensuring a character consistent with the surrounding area may involve the use of strategically placed native trees or other vegetation; the addition of special materials (e.g., wood or stonework) on the façade of the sound wall; and/or a sound wall that is covered in vegetation. Additionally, the sound barrier shall meet the standards established in General Plan Policy NS-1-o which establishes aesthetic considerations for sound walls including a maximum allowable height of 15 feet. If the sound barriers ensure that exterior traffic noise levels on the residential properties would not exceed 60 dB L eq, then the applicant shall not
be required to pave the roadway with a special low-noise surface treatment. Sound wall construction would only be implemented if all of the property owners on the west side of North Riverside Drive between West Herndon Avenue and West Spruce Avenue collectively agree to the mitigation.

Response I103-7
The comment summarizes the transportation impacts identified as significant and unavoidable in the draft EIR, and reiterates comments regarding the relationship between VMT and GHG emissions, which are addressed above in Response I130-5.

Regarding transportation safety impacts, the comment speculates that the impact could be more severe than disclosed in the Draft EIR due to the proximity of railroad tracks to the intersection North Golden State Boulevard and West Herndon Avenue and the “heightened risk on train-on-car collisions.” Existing and proposed rail infrastructure was considered in the Transportation Impact Analysis (Draft EIR Appendix D). Additional traffic generated by the proposed Costco is anticipated to result in vehicle queues that extend from the intersection of North Golden State Boulevard and West Herndon Avenue to the east, past the intersection of West Herndon Avenue and Webber Avenue. The traffic modeling accounted for the railroad tracks and existing cross protection at the at-grade crossing of West Herndon Avenue. There is a space for approximately three cars between the North Golden State Boulevard and West Herndon Avenue intersection and the arm gates; as a result, traffic queues east of the arm gates in the current condition. The arm gates provide advanced warning and lower to restrict vehicular access when activated by an approaching train. The proposed Costco Commercial center would not include design features or incompatible uses that would increase the potential for motorists to queue within the arm gates for the railroad track such that a substantial increase in the potential for train-on-car collisions would occur. As explained in the Transportation Impact Analysis and summarized in the Draft EIR, the potential for increased safety hazards would occur east of the railroad tracks at the intersection of West Herndon Avenue and Weber Avenue. To address the potential for westbound traffic Ascent Responses to Comments
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to queue through the intersection, “DO NOT BLOCK” pavement markings would be added along the full width of Weber Avenue and signal phasing would be revised to optimize green-time allocation.

The comment suggests that an offsite alternative should have been evaluated for potential to reduce the identified queuing impacts. As discussed further in Response I130-8, the Draft EIR discusses three off-site alternatives. The offsite locations evaluated at North Riverside Drive and Veterans Boulevard and at Bullard Avenue and Veterans Boulevard would not have primary access from West Herndon Avenue. This may address the queuing impacts at the intersection North Golden State Boulevard and West Herndon Avenue identified in the Draft EIR. However, these locations would also be proximate to the existing rail line, and queuing impacts could occur in the alternative locations.

The comment suggests that West Herndon Avenue would be the primary roadway used to access the proposed Costco site, assumed to be preferred over Veterans Boulevard due to distance. The Transportation Impact Analysis also reflects this assumption (see Appendix D to the Draft EIR).

Finally, the comment suggests consideration of a mitigation measure that would condition operation of the proposed Costco on completion of the grade-separated rail crossing of West Herndon Avenue between North Golden State Boulevard and North Webber Avenue, which the comment suggests may improve circulation and reduce the queuing concerns identified in the Draft EIR. As acknowledged in the comment, this work is being completed by the California High Speed Rail Authority; the City and applicant have no control over the timing or outcome. This is not feasible mitigation for the City to impose because it would introduce unreasonable uncertainty given that the City has no jurisdiction over the implementation of the rail crossing and cannot ensure that it is completed in a timely fashion (or completed at all). Further, there is no clear evidence that the rail crossing improvements would improve the roadway operations impacts identified in the Draft EIR.

Response I103-8
The comment raises issues with the Draft EIR’s alternatives analysis, specifically related to the evaluation of off-site alternatives. The Draft EIR includes a discussion of off-site alternatives, including those identified in a previous correspondence submitted by the commenter, starting on page 6-4. The Draft EIR examines three potential off-site alternative locations for the project: Southeast Corner of West Herndon Avenue and Hayes Avenue; Area West of North Riverside Drive and North of Veterans Boulevard; and Area West of Bullard Avenue and South of Veterans Boulevard. The Draft EIR concludes (page 6-4) that, due primarily to potential infeasibility and because they would not clearly address the project’s significant environmental effects, none of these off-site alternative locations are carried forward into the full evaluation of project alternatives.

The commenter suggests that dismissal of these off-site alternatives was “improper” because it “precluded the opportunity to meaningfully contextualize at least one of the significant and unavoidable impacts (transportation safety hazards from queuing) and illustrate the ability and feasibility of reducing or avoiding significant and unavoidable impacts associated with the project.” The commenter then provides several selections from the CEQA Guidelines with various phrases underlined for emphasis. However, nearly all of the commenter’s arguments are contingent on the assumption that the off-site alternatives are appropriate for inclusion in the detailed alternatives evaluation. As mentioned above, the Draft EIR includes substantial evidence that these off-site alternatives are infeasible. CEQA requires project alternatives to be feasible. CEQA defines “feasible” in California Public Resources Code (PRC) Section 210610.1: “Feasible” means capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors. Once an alternative is determined to be infeasible, it is not required to be evaluated in the EIR, and all other arguments for why it should be included become moot. Several examples where CEQA requires alternatives to be feasible are provided below (with underlines added for emphasis):

X PPRC Section 21002. The Legislature finds and declares that it is the policy of the state that public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects, and that the procedures required by this division are intended to assist public agencies in systematically identifying both the significant effects of proposed projects and the feasible alternatives or Responses to Comments Ascent
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feasible mitigation measures which will avoid or substantially lessen such significant effects. The Legislature further finds and declares that in the event specific economic, social, or other conditions make infeasible such project alternatives or such mitigation measures, individual projects may be approved in spite of one or more significant effects thereof.

X PPRC Section 21003. The Legislature further finds and declares that it is the policy of the state that: (c) Environmental impact reports omit unnecessary descriptions of projects and emphasize feasible mitigation measures and feasible alternatives to projects.

X California Code of Regulations (CCR) Section 15126.6(a). Alternatives to the Proposed Project. An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation. An EIR is not required to consider alternatives which are infeasible. The lead agency is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason.

X CCR Section 15126.6(c). Selection of a range of reasonable alternatives. The range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen one or more of the significant effects.

The EIR should briefly describe the rationale for selecting the alternatives to be discussed. The EIR should also identify any alternatives that were considered by the lead agency but were rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency’s determination.

Additional information explaining the choice of alternatives may be included in the administrative record.

Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are:(i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts.

The commenter disputes the Draft EIR’s infeasibility conclusions, suggesting that an off-site alternative should be “considered feasible enough” to be included in the detailed alternatives evaluation, rather than being rejected. “Feasible enough” is not a concept in CEQA—alternatives are considered either “potentially feasible” or “infeasible.” The commenter refutes several reasons for infeasibility identified in the Draft EIR, including site access issues, physical obstacles such as power lines, incompatible general plan designations and zoning, State restrictions on downzoning residentially designated property, as well as site ownership and acquisition issues. The commenter minimizes these issues by suggesting, in many cases, that the proposed project site shares similar constraints; however, the comparison with the project site is not thorough enough to draw the conclusions reached by the commenter. For example, the commenter equates the power line constraints associated with the site located at the southeast corner of West Herdon Avenue and Hayes Avenue with the power line constraints at the proposed project site. The constraints posed by the power lines at these two sites are not equivalent. Whereas the power lines at the proposed project site pass through a small section of the northeast corner of the rectangular site leaving the vast majority of the site unconstrained, the power lines at the alternative site completely bisect the oblong, triangular site, creating significant constraints for placement of large buildings and other tall structures, such as light standards. Another example is the commenter’s suggestion that the City could avoid violating SB 330 by “rebalancing housing unit allocations,” suggesting that the City of Freno already “facilitates SB 330 musical chairs,” and that this process would be similar to the proposed General Plan amendment and Rezone. This is far oversimplified. In order to “rebalance” the housing allocations, the City would need to rezone other properties, which would involve other property owners and stakeholders and potential unknown environmental impacts associated with changes in allowed use and/or intensity. Such a proposal for a single private development would be highly unusual. Finally, the commenter cites CEQA Guidelines Section 15126.6 and suggests that cost and lack of ownership should not be reasons to dismiss alternatives; however, Section 15126.6(f)(1) describes the considerations for feasibility of alternatives and states among Ascent Responses to Comments
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Costco Commercial Center Project Final EIR 2-175
the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries (projects with a regionally significant impact should consider the regional context), and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site (or the site is already owned by the proponent). The same section also stipulates that “no one of these factors establishes a strict limit on the scope of reasonable alternatives.” It should be noted that multiple reasons for infeasibility are provided in the Draft EIR for each of the offsite alternatives. Furthermore, the commenter does not address many of the other reasons for infeasibility identified in the Draft EIR, including parcels on the same site being under different ownership, including by FMFCD; FMFCD easements bisecting a site; and obstacles to site access associated with a grade- separated overpass.

Interestingly, the commenter offers a court case to substantiate the critique of the Draft EIR’s alternatives analysis: We Advocate Through Environmental Review, et al v. County of Siskiyou. The commenter indicates that this case relates to narrowly defined objectives; however, the commenter then admits that the Draft EIR’s objectives are not written narrowly but suggests that the Draft EIR’s off-site alternatives analysis has the same “end-effect” in that the outcome was a “mere formality.” The Draft EIR follows CEQA’s guidance for consideration of alternatives, including CEQA’s specific guidance for alternative locations as provided in State CEQA Guidelines Section 15126[f][2], as follows:
(A) Key question. The key question and first step in analysis is whether any of the significant effects of the project would be avoided or substantially lessened by putting the project in another location. Only locations that would avoid or substantially lessen any of the significant effects of the project need be considered for inclusion in the EIR.
(B) None feasible. If the lead agency concludes that no feasible alternative locations exist, it must disclose the reasons for this conclusion, and should include the reasons in the EIR. For example, in some cases there may be no feasible alternative locations for a geothermal plant or mining project which must be in close proximity to natural resources at a given location.
(C) Limited new analysis required. Where a previous document has sufficiently analyzed a range of reasonable alternative locations and environmental impacts for projects with the same basic purpose, the lead agency should review the previous document. The EIR may rely on the previous document to help it assess the feasibility of potential project alternatives to the extent the circumstances remain substantially the same as they relate to the alternative. (Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 573).

First, regarding item “A,” the Draft EIR considers the “key question”: would any of the project’s significant effects be avoided? Each of the Draft EIR’s off-site alternatives discussions include a robust discussion on this point. Second, regarding item “B,” the Draft EIR considers the feasibility of these off-site alternatives, as described in detail above.

Finally, regarding item “C,” no previous document evaluated a range of reasonable alternative locations. Not only does the referenced court case (by the commenter’s own admission) have nothing to do with the off-site alternatives issue, but the commenter’s attempt to tie the general lesson from the case—that alternatives evaluation should not be a mere formality—to the Draft EIR does not work as the Draft EIR follows CEQA’s requirements for considering off-site alternatives.

Importantly, in addition to considering and dismissing three off-site alternatives and two additional alternatives, the Draft EIR includes a detailed alternatives evaluation that considers a reasonable range of alternatives, including two No Project Alternatives and two alternatives to the project focused specifically on reducing significant impacts of the project.

It should also be noted that the commenter indicates that his comments were not included in Appendix A of the Draft EIR. The NOP was released October 22, 2021 for a 30-day comment period. The referenced correspondence was an email dated March 30, 2022 (4 months after the close of the comment period). Although the letter was not included in the appendix with the comments received on the NOP, the comments provided were considered during preparation of the Draft EIR, as stated on page 6-4 of the Draft EIR.

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City of Fresno
Costco Commercial Center Project Final EIR 3-1
3 REVISIONS TO THE DRAFT EIR
This chapter presents specific text changes made to the Draft EIR since its publication and public review. The changes are presented in the order in which they appear in the original Draft EIR and are identified by the Draft EIR page number. Text deletions are shown in strikethrough, and text additions are shown in underline.

The information contained within this chapter clarifies and expands on information in the Draft EIR and does not constitute “significant new information” requiring recirculation. (See also Public Resources Code Section 21092.1; CEQA Guidelines Section 15088.5.)
Revisions to “Executive Summary”
The first sentence in Section ES.2.4, “Characteristics of the Project,“ on page ES-2 is revised as follows to reflect the revised site plan:

The proposed Costco building would occupy 241,342 219,126 square feet, of which approximately 24,000 square feet would be reserved for storage and receiving.

Revisions to Chapter 2, “Project Description”
Table 2-1 on page 2-10 is revised as follows to reflect the revised site plan:

Table 2-1 Project Elements
SStructure AArea (square feet)
WWarehouse Retail Building Footprint 2241,342 2219,216 Warehouse/Retail 162,264 163,539
Loading/Back of house/Storage/Receiving 23,881 4,422
Market delivery operation 46,834
Open canopy space 5,126 3,233
Building envelope 2,9555 1,188
FFuel canopy 112,885
CCar wash 44,800
Source: Data provided by Urban Planning Partners in 2022 and 2023.

The first sentence on page 2-13 under the heading “Costco Warehouse Building” is revised as follows to reflect the revised site plan:

The proposed warehouse would occupy 241,342 219,126 square feet of which approximately 24,000 square feet would be reserved for storage and receiving.

The description under the heading “Parking” on page 2-14 is revised as follows to reflect the revised site plan:

The project includes 889 873 total parking stalls, which meets the City of Fresno’s minimum parking requirements for the project. These parking stalls would include a total of 21 25 accessible spaces and 53 92 electric vehicle-ready parking stalls. The design would be in compliance with City and Americans with Disabilities Act (ADA) requirements. The project also would provide bicycle parking in accordance with the City’s Citywide Development Code.

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3-2 Costco Commercial Center Project Final EIR
To provide clarification, the second paragraph of Section 2.2.4, “Construction,” on page 2-19 of the Draft EIR is revised as follows:

Table 2-2 lists equipment anticipated to be used during construction. All equipment used for construction would have Tier 3 engines with diesel particulate filters. In addition, approximately 325 loads of aggregate base would be imported onto the project site and approximately 3,000 cubic yards of utility and foundation spoils would be off hauled. Grading of the project site would be otherwise balanced and would not require additional import or export of soils. All staging would occur on the project site. Trucks would enter the project site from North Riverside Drive and exit the site via North Arthur Avenue.

The first bullet on page 2-22, which describes the entitlements requested from the City is revised to read:

X Approve a Conditional Use Permit to construct a ±241,342 219,126 square-foot, warehouse retail building with a ±4,800 square-foot car wash; and an ±13,000 square-foot, 32-station fuel canopy.

Revisions to Section 3.1, “Aesthetics”
The first sentence under Impact 3.1-1 on page 3.1-6 is revised as follows to reflect the revised site plan:

The project would construct an approximately 241,342 219,126-square-foot single story, contemporary-style retail building in the southeast corner of the project site, and a car wash and fueling stations along the northern portions of the site.

Revisions to Section 3.5, “Biological Resources”
To provide clarification, the first paragraph on page 3.5-1 of the Draft EIR is revised as follows:

This section was prepared by an Ascent biologist and addresses biological resources known or with potential to occur on or near the project site and describes potential effects of implementation of the project on those resources.

In addition, the fourth paragraph on page 3.5-2 of the Draft EIR is revised as follows:

An Ascent biologist conducted reconnaissance-level surveys of the project site on November 1, 2021 and June 20, 2022. The project site consists of an undeveloped parcel in the northwestern portion of the city of Fresno, approximately 0.35 mile south of the San Joaquin River. The site is surrounded by the Riverside Golf Course to the north; residential development to the west; industrial and residential development to the east; and West Herndon Avenue, commercial development, some undeveloped parcels, and the Rio Vista Middle School to the south. There is a large transmission tower in the northwest corner of the project site. No raptor nests were observed on this tower; however, several owl pellets (likely attributed to a barn owl [ Tyto alba] or great horned owl [Bubo virginianus]) and California ground squirrel (Otospermophilus beecheyi) bones were observed under the tower during the reconnaissance-level survey on November 1, 2021, indicating that owls and likely other raptors use the tower as a roost site. California ground squirrel burrows are present throughout the project site and several squirrels were observed during the reconnaissance-level surveys on November 1, 2021, and June 20, 2022. There is a mound of soil directly adjacent to the northern boundary of the project site with many California ground squirrel burrows.

Revisions to Section 3.11, “Noise and Vibration”
The first sentence under the subheading “Parking and Gas Station” on page 3.11-23 is revised as following to reflect the revised site plan:

Based on the current conceptual plan the proposed project would include 829 873 parking spaces to accommodate Costco members and employees.

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Costco Commercial Center Project Final EIR 3-3
The following language has been added to Mitigation Measure 3.11-5 on page 3.11-29 to further clarify implementation.

MMitigation Measure 3.11-5: Implement Traffic Noise Reduction Measures along North Riverside Drive The project proponent shall implement noise reduction measures to ensure that exterior noise levels at residential land uses near the west side of North Riverside Drive do not exceed the City’s current noise standard of 65 dB L
dn/CNEL under existing-plus-project conditions. This measure is consistent with General Plan Policy NS-1-I, which recommends the use of design alterations to reduce noise impacts. This performance standard can be achieved using either of the following measures. Therefore, if one option is not implemented, the other would be required.:

X Pave the roadway segment with rubberized hot-mix asphalt or equivalent surface treatment with known noise-reducing properties on top of the roadway surface. The rubberized hot-mix asphalt overlay shall be designed with appropriate thickness and rubber component quantity (typically 15 percent by weight of the total blend), such that traffic noise levels are reduced by an average of 4 to 6 dB (noise levels vary depending on travel speeds, meteorological conditions, and pavement quality) as compared to noise levels generated by vehicle traffic traveling on standard asphalt. Rubberized hot-mix asphalt has been found to achieve this level of noise reduction in other parts of California (Sacramento County 1999).

Pavement will require more frequent than normal maintenance and repair to maintain its noise attenuation effectiveness. The applicant shall fund the incremental cost for maintaining the roadway segment with the surface treatment.

X Construct a sound barrier taller than the 6-foot cinderblock wall that is currently present from West Spruce Avenue to West Herndon Avenue. The sound barrier shall be constructed of solid material (e.g., wood, brick, adobe, an earthen berm, boulders, or combination thereof). The reflectivity of each sound barrier shall be minimized to ensure that traffic noise reflected off the barrier does not contribute to an exceedance of applicable L
eq standards at other receptors. The level of sound reflection from a barrier can be minimized with a textured or absorptive surface or with vegetation on or next to the barrier. A barrier that breaks the line of sight between a source and a receiver will typically result in at least 5 dB of noise reduction (Caltrans 2013: 2-41; FTA 2018: 42). Barriers higher than the line of sight provide increased noise reduction (FTA 2018: 16). Scenic quality factors shall be taken into account during design, such as using more natural materials (e.g., berms and boulders) to reduce the visible mass of a wall. All barriers shall be designed to blend into the landscape along the roadway, to the extent feasible. Ensuring a character consistent with the surrounding area may involve the use of strategically placed native trees or other vegetation; the addition of special materials (e.g., wood or stonework) on the façade of the sound wall; and/or a sound wall that is covered in vegetation. Additionally, the sound barrier shall meet the standards established in General Plan Policy NS-1-o which establishes aesthetic considerations for sound walls including a maximum allowable height of 15 feet. If the sound barriers ensure that exterior traffic noise levels on the residential properties would not exceed 60 dB L eq, then the applicant shall not
be required to pave the roadway with a special low-noise surface treatment. Sound wall construction would only be implemented if all of the property owners on the west side of North Riverside Drive between West Herndon Avenue and West Spruce Avenue collectively agree to the mitigation.

Revisions to Section 3.13, “Transportation and Circulation” The text of Mitigation Measure 3.13-2 beginning on page 3.13-15 of the Draft EIR is revised as follows:

Mitigation Measures
Table 3.13-3 presents the most recent California Air Pollution Control Officers Association (CAPCOA) Handbook for Analyzing GHG Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (Handbook) measures for reducing greenhouse gas emissions within the transportation sector.

Most of the measures quantified in the CAPCOA Handbook aim to reduce VMT and encourage mode shifts from single-occupancy vehicles to shared (e.g., transit) or active modes of transportation (e.g., bicycle) Revisions to the Draft EIR Ascent
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3-4 Costco Commercial Center Project Final EIR
(CAPCOA 2021). Although all transportation measures are provided below, not all are applicable or feasible given the implementation scale, nature of the proposed project, and/or limited jurisdictional authority of Costco, the applicant, to implement particular measures. The following mitigation measures have been proposed is based on the analysis of feasibility and applicability included in Table 3.13-5.

Table 3.13-5 Transportation Sector Measures to Reduce VMT MMitigation Measure Maximum PPotential
VMT Reduction1
Feasible/Applicable
to the project? Notes
T-1 Increase Residential
Density
30% from project VMT N/A The proposed project does not
include residential uses.

T-2 Increase Job Density 30% from project VMT N/A This is a plan/communitywide strategy and is not applicable.

T-3 Provide Transit-Oriented
Development
31% from project VMT N/A This is a plan/communitywide
strategy and is not applicable.

T-4 Integrate Affordable and
Below Market Rate
Housing

28.6% from project/site
multifamily residential VMT
N/A The proposed project does not
include residential uses.

T-5 Implement Commute Trip
Reduction Program
(Voluntary)
4% project/site employee
commute VMT
Yes No See Mitigation Measure 3.13-2 below.

Measures T-7 through T-11 must be
implemented as part of T-5 to
achieve the maximum employee
commute VMT reduction. Because T-
11 would not be feasible, the
commute trip reduction program
would not meet the full list of
CAPCOA parameters.

T-6 Implement Commute Trip
Reduction Program
(Mandatory
Implementation and
Monitoring)
26% from project/site
employee commute VMT
Yes No
See Mitigation Measure 3.13-2 below.

Measures T-7 through T-11 must be
implemented as part of T-6 to
achieve the maximum employee
commute VMT reduction. Because T-
11 would not be feasible, the
commute trip reduction program
would not meet the full list of
CAPCOA parameters.

T-7 Implement Commute Trip
Reduction Marketing
4% project/site employee
commute VMT
Yes See Mitigation Measure 3.13-2 below.

T-8 Provide Ridesharing
Program
8% project/site employee
commute VMT
Yes See Mitigation Measure 3.13-2 below.

T-9 Implement Subsidized or
Discounted Transit
Program

5.5% from
employee/resident
Yes See Mitigation Measure 3.13-2 below.

T-10 Provide End-of-Trip
Bicycle Facilities

4.4% project/site
employee commute VMT
Yes See Mitigation Measure 3.13-2 below.

T-11 Provide Employer-
Sponsored Vanpool

20.4% project/site
employee commute VMT
Yes No See Mitigation Measure 3.13-2 below.

A private vanpool program would
involve the capital cost of purchasing
vas plus the operating cost of
insurances, would raise liability
concerns, and would pose logistical
challenges such as equal treatment of
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Costco Commercial Center Project Final EIR 3-5
MMitigation Measure Maximum PPotential
VMT Reduction1
Feasible/Applicable
to the project? Notes
employees and rules regarding
private use of the vans. This measure
cannot be feasibly implemented to
reduce VMT.

T-12 Price Workplace Parking 20% project/site
employee commute VMT
N/A Measure ineffective due to readily
available, uncontrolled and free
parking in the immediate vicinity of
the proposed project.

T-13 Implement Employee
Parking Cash-Out
12% project/site employee
commute VMT
N/A Measure ineffective due to readily
available, uncontrolled and free
parking in the immediate vicinity of
the proposed project.

T-14 Provide Electric Vehicle
Charging Infrastructure
-- N/A See Mitigation Measure 3.3-2a. This
measure does not affect VMT.

T-15 Limit Residential Parking
Supply

13.7% from residences’
VMT
N/A The proposed project does not
include residential uses.

T-16 Unbundle Residential
Parking Costs from
Property Cost

15.7% from project VMT N/A The proposed project does not include residential uses.

T-17 Improve Street
Connectivity
30% from vehicle travel in
the plan/community
Yes The proposed project would
construct West Spruce Avenue along
the northern project site boundary
improving street connectivity.

Additionally, the project would
construct North Arthur Avenue along
the eastern project site boundary,
connecting West Spruce Avenue and
West Spruce Herndon Avenue. See
Chapter 2, “Project Description.,” and
Mitigation Measure 3.13-2 below.

T-18 Provide Pedestrian
Network Improvement

6.4% from vehicle travel in
the plan/community
Yes Pedestrian facility improvements
provided as part of the proposed
project. See Chapter 2, “Project
Description.,” and Mitigation Measure

3.13-2 below.

T-19-A Construct or Improve Bike
Facility

0.8% from vehicles parallel
roadways
Yes Bicycle facility improvements
provided as part of the proposed
project. See Chapter 2, “Project
Description.,” and Mitigation Measure

3.13-2 below.

T-19-B Construct or Improve Bike
Boulevard

0.2% from vehicles on
roadway
Yes Bicycle facility improvements
provided as part of the proposed
project. See Chapter 2, “Project
Description.,” and Mitigation Measure

3.13-2 below.

T-20 Expand Bikeway Network 0.5% from vehicles on
roadway
Yes Bicycle facility improvements
provided as part of the proposed
project. See Chapter 2, “Project
Description.,” and Mitigation Measure

3.13-2 below.

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3-6 Costco Commercial Center Project Final EIR
MMitigation Measure Maximum PPotential
VMT Reduction1
Feasible/Applicable
to the project? Notes
T-21-A Implement Conventional
Carshare Program

0.15% from vehicle travel
in the plan/community
No This is a plan/communitywide
strategy and is not feasible.

T-21-B Implement Electric
Carshare Program
VMT reduction not
quantified—see CAPCOA
handbook
No This is a plan/communitywide
strategy and is not feasible.

T-22-A Implement Pedal (Non-
Electric) Bikeshare
Program

0.2% from vehicle travel in
the plan/community
No This is a plan/communitywide
strategy and is not feasible.

T-22-B Implement Electric
Bikeshare Program

0.06% from vehicle travel
in the plan/community
No This is a plan/communitywide
strategy and is not feasible.

T-22-C Implement Scootershare
Program

0.07% from vehicle travel
in the plan/community
No This is a plan/communitywide
strategy and is not feasible.

T-23 Provide Community-
Based Travel Planning

2.3% from vehicle travel in
the plan/community
N/A The proposed project does not
include residential uses. This measure
applies to residences.

T-24 Implement Market Price
Public Parking (On-Street)
30% from vehicle travel in
the plan/community
No The applicant, Costco, does not have
jurisdiction over public on-street
parking facilities and operation.

T-25 Extend Transit Network
Coverage or Hours

4.6% from vehicle travel in
the plan/community
No The applicant, Costco, does not have
jurisdiction over the operation of
transit service.

T-26 Increase Transit Service
Frequency

11.3% from vehicle travel
in the plan/community
No The applicant, Costco, does not have
jurisdiction over the operation of
transit service.

T-27 Implement Transit-
Supportive Roadway
Treatments

0.6% from vehicle travel in
the plan/community
No This is a plan/communitywide
strategy and is not feasible.

T-28 Provide Bus Rapid Transit 13.8% from vehicle travel in the plan/community
No The applicant, Costco, does not have
jurisdiction over the operation of
transit service.

T-29 Reduce Transit Fares 1.2% from vehicle travel in
the plan/community
No This is a plan/communitywide
strategy and is not feasible.

T-30 Use Cleaner-Fuel Vehicles -- N/A This measure does not affect VMT.

Notes:
1: The CAPCOA Handbook identifies the maximum potential GHG reduction associated with identified measures; however, the CAPCOA Handbook concludes that for the particular measures selected, the percent reduction in VMT would be the same as the percent reduction in GHG emissions. For clarity, this table reports reductions in relation to VMT.

VMT = Vehicle Miles Traveled; N/A = not applicable
Source: Mitigation Measures and VMT Reduction Potential provided by CAPCOA 2021 Handbook for Analyzing Greenhouse Gas Emissions Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity Mitigation Measure 3.13-2: Provide a Mandatory Commute Reduction Program for to Reduce Costco Employees’ VMT by at least 26 Percent
Costco shall provide a Mandatory Commute Reduction program for employees that is designed to achieves at least a 26 percent reduction in employee VMT. The commute reduction program shall be provided to the City for approval acceptance prior to issuance of a certificate of occupancy. Specific actions may m ust include the following measures described in the California Air Pollution Control Officers Association’s 2021 Handbook Ascent Revisions to the Draft EIR
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Costco Commercial Center Project Final EIR 3-7
for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity Quantifying Greenhouse Gas Mitigation Measures Handbook:

X CCommute Trip Reduction Marketing (estimated to result in up to 4 percent employee VMT reduction):

Costco shall implement a marketing strategy to promote Costco’s commute reduction program.

Information sharing and marketing promote and educate employees about their travel choices to the employment location beyond driving such as carpooling, taking transit, walking, and biking, thereby reducing VMT and greenhouse gas emissions. The following features (or similar alternatives) shall be provided:
ƒ on-site or online commuter information services,
ƒ employee transportation coordinators,
ƒ on-site or online transit pass sales, and
ƒ guaranteed ride home service.

X Provide Ridesharing Program (estimated to result in up to 8 percent employee VMT reduction): Costco shall develop and implement a ridesharing program. Ridesharing encourages carpooled vehicle trips in place of single-occupied vehicle trips, thereby reducing the number of trips, VMT, and greenhouse gas emissions. The following strategies provide examples of a multifaceted approach for promoting a rideshare program:
ƒ designating a certain percentage of desirable parking spaces for ridesharing vehicles, ƒ designating adequate passenger loading and unloading and waiting areas for ridesharing vehicles, and
ƒ providing an app or website for coordinating rides.

X Implement Subsidized or Discount Transit Program (estimated to result in up to 5.5 percent employee VMT reduction): Costco shall provide free transit passes for employees. Reducing the out-of-pocket cost for choosing transit improves the competitiveness of transit against driving, increasing the total number of transit trips and decreasing vehicle trips. This decrease in vehicle trips results in reduced VMT and, thus, a reduction in greenhouse gas emissions.

X Provide End-of-Trip Bicycle Facilities (estimated to result in up to 4.4 percent employee VMT reduction):

Costco shall install and maintain end-of-trip facilities for employee use. End-of-trip facilities include elements such as bike parking, bike lockers, showers, and personal lockers. The provision and maintenance of secure bike parking and related facilities encourages commuting by bicycle, thereby reducing VMT and greenhouse gas emissions.

X Provide Employer-Sponsored Vanpool (estimated to result in up to 20.4 percent employee VMT reduction): Costco shall implement an employer-sponsored vanpool program. Vanpooling is a flexible form of public transportation that provides groups of 5 to 15 people with a cost-effective and convenient rideshare option for commuting. The mode shift from long-distance, single-occupied vehicles to shared vehicles reduces overall commute VMT, thereby reducing greenhouse gas emissions (CAPCOA 2021).

X Improve Street Connectivity (estimated to result in up to 30 percent employee VMT reduction): Costco shall construct West Spruce Avenue along the northern site boundary, creating new connections between West Spruce Avenue and North Aurther Avenue. The increased connectivity and intersection density that would result from these improvements would facilitate shorter trips, thereby reducing VMT.

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X PProvide Pedestrian Network Improvements/Construct Bike Facilities/Expand Bikeway Network (estimated to result in up to 10 percent employee VMT reduction1): Costco shall construct new, 12-foot-wide pedestrian and bicycle paths along West Herndon Avenue and North Riverside Drive to improve pedestrian access and connect to a larger bicycle network. This encourages a mode shift from automobiles to biking and walking, resulting in VMT reduction.

Revisions to Section 3.14, “Utilities”
The text under “Water Demand and Wastewater Output” on page 3.14-9 is revised as follows to reflect the revised site plan:

CEQA Guidelines Section 15155 requires preparation of a water supply assessment (WSA) when a project is of sufficient size to be defined as a “water-demand project.” Several characteristics can deem a project a “water-demand project” including:

X A shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space (CEQA Guidelines Section 15155(a)(1)(B).

The project is estimated to employ approximately 300 individuals, and the warehouse and gas station would encompass approximately 241,342 232,101 square feet. It does not meet the definition of a “water demand project” pursuant to Section 15155 of the State CEQA Guidelines. Preparation of a WSA is not required for the project.

Revisions to the Air Quality Technical Report (Draft EIR Appendix C) The following table replaces Table F-1 in Appendix F, HARP Outputs, in Appendix C: Air Quality Technical Report of the Draft EIR:

Receptor ID X--Coordinate
(m)
Y--Coordinate
(m)
Receptor
Type
Cancer Risk
(in a million)
Chronic
Hazard Index
Acute
Hazard Index
1 240425.00 4080650.00 Worker 0.01 7.73E-04 0.00E+00
3 240475.00 4080650.00 Worker 0.01 9.28E-04 0.00E+00
4 240500.00 4080650.00 Worker 0.01 1.03E-03 0.00E+00
13 240725.00 4080650.00 Worker 0.02 1.94E-03 0.00E+00
14 240750.00 4080650.00 Worker 0.02 1.91E-03 0.00E+00
15 240400.00 4080675.00 Worker 0.01 8.49E-04 0.00E+00
16 240425.00 4080675.00 Worker 0.01 9.37E-04 0.00E+00
18 240475.00 4080675.00 Worker 0.02 1.17E-03 0.00E+00
19 240500.00 4080675.00 Worker 0.02 1.35E-03 0.00E+00
28 240725.00 4080675.00 Worker 0.03 2.43E-03 0.00E+00
29 240750.00 4080675.00 Worker 0.03 2.31E-03 0.00E+00
30 240775.00 4080675.00 Worker 0.03 2.12E-03 0.00E+00
32 240400.00 4080700.00 Worker 0.01 1.03E-03 0.00E+00
33 240425.00 4080700.00 Worker 0.01 1.16E-03 0.00E+00
35 240475.00 4080700.00 Worker 0.02 1.55E-03 0.00E+00
36 240500.00 4080700.00 Worker 0.02 1.91E-03 0.00E+00
67 240375.00 4080750.00 Residential 0.51 1.18E-03 0.00E+00 75 240375.00 4080775.00 Residential 0.58 1.33E-03 0.00E+00

1 Measures T-18 through T-22-C are in the Neighborhood Design subsector. The VMT reduction from the combined implementation of all measures within this subsector is capped at 10 percent (CAPCOA 2021: 135).

Ascent Revisions to the Draft EIR
City of Fresno
Costco Commercial Center Project Final EIR 3-9
RReceptor ID XX--CCoordinate
((m)
YY--CCoordinate
((m)
RReceptor
TType
CCancer Risk
((in a million)
CChronic
HHazard Index
AAcute
HHazard Index
76 240400.00 4080775.00 Residential 0.70 1.61E-03 0.00E+00 77 240425.00 4080775.00 Residential 0.89 2.04E-03 0.00E+00 83 240375.00 4080800.00 Residential 0.64 1.48E-03 0.00E+00 84 240400.00 4080800.00 Residential 0.79 1.83E-03 0.00E+00 85 240425.00 4080800.00 Residential 1.03 2.37E-03 0.00E+00 91 240375.00 4080825.00 Residential 0.70 1.61E-03 0.00E+00 92 240400.00 4080825.00 Residential 0.88 2.02E-03 0.00E+00 93 240425.00 4080825.00 Residential 1.15 2.65E-03 0.00E+00 99 240375.00 4080850.00 Residential 0.75 1.73E-03 0.00E+00 100 240400.00 4080850.00 Residential 0.94 2.16E-03 0.00E+00 101 240425.00 4080850.00 Residential 1.23 2.83E-03 0.00E+00 108 240400.00 4080875.00 Residential 0.98 2.26E-03 0.00E+00 109 240425.00 4080875.00 Residential 1.28 2.93E-03 0.00E+00 115 240375.00 4080900.00 Residential 0.81 1.85E-03 0.00E+00 116 240400.00 4080900.00 Residential 1.01 2.31E-03 0.00E+00 117 240425.00 4080900.00 Residential 1.30 2.99E-03 0.00E+00 123 240375.00 4080925.00 Residential 0.82 1.88E-03 0.00E+00 124 240400.00 4080925.00 Residential 1.02 2.34E-03 0.00E+00 125 240425.00 4080925.00 Residential 1.31 3.01E-03 0.00E+00 139 240375.00 4080975.00 Residential 0.81 1.85E-03 0.00E+00 140 240400.00 4080975.00 Residential 1.00 2.30E-03 0.00E+00 141 240425.00 4080975.00 Residential 1.29 2.97E-03 0.00E+00 147 240375.00 4081000.00 Residential 0.78 1.80E-03 0.00E+00 148 240400.00 4081000.00 Residential 0.98 2.24E-03 0.00E+00 149 240425.00 4081000.00 Residential 1.26 2.90E-03 0.00E+00 156 240400.00 4081025.00 Residential 0.93 2.14E-03 0.00E+00 157 240425.00 4081025.00 Residential 1.21 2.78E-03 0.00E+00 163 240375.00 4081050.00 Residential 0.70 1.61E-03 0.00E+00 164 240400.00 4081050.00 Residential 0.87 1.99E-03 0.00E+00 165 240425.00 4081050.00 Residential 1.13 2.59E-03 0.00E+00 171 240375.00 4081075.00 Residential 0.64 1.46E-03 0.00E+00 172 240400.00 4081075.00 Residential 0.78 1.79E-03 0.00E+00 173 240425.00 4081075.00 Residential 1.00 2.29E-03 0.00E+00 189 240375.00 4081125.00 Residential 0.50 1.14E-03 0.00E+00 190 240400.00 4081125.00 Residential 0.57 1.31E-03 0.00E+00 191 240425.00 4081125.00 Residential 0.66 1.51E-03 0.00E+00 192 240450.00 4081125.00 Worker 0.02 1.72E-03 0.00E+00
193 240475.00 4081125.00 Worker 0.02 1.91E-03 0.00E+00
Revisions to the Draft EIR Ascent
City of Fresno
3-10 Costco Commercial Center Project Final EIR
RReceptor ID XX--CCoordinate
((m)
YY--CCoordinate
((m)
RReceptor
TType
CCancer Risk
((in a million)
CChronic
HHazard Index
AAcute
HHazard Index
194 240500.00 4081125.00 Worker 0.03 2.11E-03 0.00E+00
195 240525.00 4081125.00 Worker 0.03 2.24E-03 0.00E+00
196 240550.00 4081125.00 Worker 0.03 2.27E-03 0.00E+00
197 240575.00 4081125.00 Worker 0.03 2.24E-03 0.00E+00
207 240375.00 4081150.00 Residential 0.43 9.80E-04 0.00E+00 208 240400.00 4081150.00 Residential 0.47 1.09E-03 0.00E+00 209 240425.00 4081150.00 Residential 0.52 1.20E-03 0.00E+00 210 240450.00 4081150.00 Worker 0.02 1.31E-03 0.00E+00
211 240475.00 4081150.00 Worker 0.02 1.41E-03 0.00E+00
212 240500.00 4081150.00 Worker 0.02 1.49E-03 0.00E+00
213 240525.00 4081150.00 Worker 0.02 1.52E-03 0.00E+00
214 240550.00 4081150.00 Worker 0.02 1.52E-03 0.00E+00
215 240575.00 4081150.00 Worker 0.02 1.48E-03 0.00E+00
216 240600.00 4081150.00 Worker 0.02 1.40E-03 0.00E+00
217 240625.00 4081150.00 Worker 0.02 1.29E-03 0.00E+00
218 240650.00 4081150.00 Worker 0.01 1.15E-03 0.00E+00
219 240675.00 4081150.00 Worker 0.01 9.87E-04 0.00E+00
220 240700.00 4081150.00 Worker 0.01 8.14E-04 0.00E+00
221 240725.00 4081150.00 Worker 0.01 6.67E-04 0.00E+00
222 240750.00 4081150.00 Worker 0.01 5.56E-04 0.00E+00
223 240775.00 4081150.00 Worker 0.01 4.73E-04 0.00E+00
224 240425.00 4081175.00 Residential 0.42 9.69E-04 0.00E+00 225 240450.00 4081175.00 Worker 0.01 1.03E-03 0.00E+00
226 240475.00 4081175.00 Worker 0.01 1.07E-03 0.00E+00
227 240500.00 4081175.00 Worker 0.01 1.10E-03 0.00E+00
228 240525.00 4081175.00 Worker 0.01 1.10E-03 0.00E+00
229 240550.00 4081175.00 Worker 0.01 1.09E-03 0.00E+00
230 240575.00 4081175.00 Worker 0.01 1.04E-03 0.00E+00
231 240600.00 4081175.00 Worker 0.01 9.82E-04 0.00E+00
232 240625.00 4081175.00 Worker 0.01 9.03E-04 0.00E+00
233 240650.00 4081175.00 Worker 0.01 8.09E-04 0.00E+00
234 240675.00 4081175.00 Worker 0.01 7.08E-04 0.00E+00
235 240700.00 4081175.00 Worker 0.01 6.10E-04 0.00E+00
236 240725.00 4081175.00 Worker 0.01 5.24E-04 0.00E+00
237 240750.00 4081175.00 Worker 0.01 4.53E-04 0.00E+00
238 240775.00 4081175.00 Worker 0.01 3.95E-04 0.00E+00
239 240525.00 4081200.00 Worker 0.01 8.40E-04 0.00E+00
240 240550.00 4081200.00 Worker 0.01 8.18E-04 0.00E+00
Ascent Revisions to the Draft EIR
City of Fresno
Costco Commercial Center Project Final EIR 3-11
RReceptor ID XX--CCoordinate
((m)
YY--CCoordinate
((m)
RReceptor
TType
CCancer Risk
((in a million)
CChronic
HHazard Index
AAcute
HHazard Index
241 240575.00 4081200.00 Worker 0.01 7.83E-04 0.00E+00
242 240600.00 4081200.00 Worker 0.01 7.35E-04 0.00E+00
243 240625.00 4081200.00 Worker 0.01 6.78E-04 0.00E+00
244 240650.00 4081200.00 Worker 0.01 6.14E-04 0.00E+00
245 240675.00 4081200.00 Worker 0.01 5.48E-04 0.00E+00
246 240700.00 4081200.00 Worker 0.01 4.84E-04 0.00E+00
247 240725.00 4081200.00 Worker 0.01 4.28E-04 0.00E+00
248 240750.00 4081200.00 Worker 0.00 3.79E-04 0.00E+00
249 240400.00 4080500.00 Worker 0.00 3.27E-04 0.00E+00
250 240450.00 4080500.00 Worker 0.00 3.58E-04 0.00E+00
251 240500.00 4080500.00 Worker 0.01 3.94E-04 0.00E+00
256 240750.00 4080500.00 Worker 0.01 6.90E-04 0.00E+00
257 240800.00 4080500.00 Worker 0.01 7.37E-04 0.00E+00
258 240300.00 4080550.00 Worker 0.00 3.40E-04 0.00E+00
259 240350.00 4080550.00 Worker 0.00 3.70E-04 0.00E+00
260 240400.00 4080550.00 Worker 0.01 4.06E-04 0.00E+00
261 240450.00 4080550.00 Worker 0.01 4.51E-04 0.00E+00
267 240750.00 4080550.00 Worker 0.01 9.40E-04 0.00E+00
268 240800.00 4080550.00 Worker 0.01 9.74E-04 0.00E+00
269 240850.00 4080550.00 Worker 0.01 9.58E-04 0.00E+00
270 240300.00 4080600.00 Worker 0.01 4.26E-04 0.00E+00
271 240350.00 4080600.00 Worker 0.01 4.70E-04 0.00E+00
272 240400.00 4080600.00 Worker 0.01 5.25E-04 0.00E+00
274 240500.00 4080600.00 Worker 0.01 6.88E-04 0.00E+00
279 240750.00 4080600.00 Worker 0.02 1.32E-03 0.00E+00
280 240800.00 4080600.00 Worker 0.02 1.30E-03 0.00E+00
281 240850.00 4080600.00 Worker 0.02 1.20E-03 0.00E+00
282 240900.00 4080600.00 Worker 0.01 1.06E-03 0.00E+00
283 240250.00 4080650.00 Worker 0.01 4.90E-04 0.00E+00
284 240300.00 4080650.00 Worker 0.01 5.44E-04 0.00E+00
285 240350.00 4080650.00 Worker 0.01 6.18E-04 0.00E+00
286 240400.00 4080650.00 Worker 0.01 7.14E-04 0.00E+00
287 240800.00 4080650.00 Worker 0.02 1.70E-03 0.00E+00
288 240850.00 4080650.00 Worker 0.02 1.43E-03 0.00E+00
289 240900.00 4080650.00 Worker 0.02 1.19E-03 0.00E+00
297 240300.00 4080750.00 Residential 0.35 7.97E-04 0.00E+00 298 240350.00 4080750.00 Residential 0.44 1.02E-03 0.00E+00 299 240850.00 4080750.00 Worker 0.02 1.66E-03 0.00E+00
Revisions to the Draft EIR Ascent
City of Fresno
3-12 Costco Commercial Center Project Final EIR
RReceptor ID XX--CCoordinate
((m)
YY--CCoordinate
((m)
RReceptor
TType
CCancer Risk
((in a million)
CChronic
HHazard Index
AAcute
HHazard Index
300 240900.00 4080750.00 Worker 0.02 1.26E-03 0.00E+00
301 240950.00 4080750.00 Worker 0.01 9.82E-04 0.00E+00
302 240250.00 4080800.00 Residential 0.31 7.24E-04 0.00E+00 303 240300.00 4080800.00 Residential 0.40 9.21E-04 0.00E+00 305 240850.00 4080800.00 Worker 0.02 1.63E-03 0.00E+00
306 240900.00 4080800.00 Worker 0.02 1.21E-03 0.00E+00
307 240950.00 4080800.00 Worker 0.01 9.18E-04 0.00E+00
308 240250.00 4080850.00 Residential 0.34 7.92E-04 0.00E+00 309 240300.00 4080850.00 Residential 0.45 1.03E-03 0.00E+00 311 240850.00 4080850.00 Worker 0.02 1.54E-03 0.00E+00
312 240900.00 4080850.00 Worker 0.01 1.11E-03 0.00E+00
313 240950.00 4080850.00 Worker 0.01 8.23E-04 0.00E+00
314 240250.00 4080900.00 Residential 0.36 8.38E-04 0.00E+00 315 240300.00 4080900.00 Residential 0.48 1.10E-03 0.00E+00 317 240850.00 4080900.00 Worker 0.02 1.37E-03 0.00E+00
318 240900.00 4080900.00 Worker 0.01 9.64E-04 0.00E+00
319 240950.00 4080900.00 Worker 0.01 7.04E-04 0.00E+00
321 240300.00 4080950.00 Residential 0.49 1.12E-03 0.00E+00 323 240850.00 4080950.00 Worker 0.01 1.15E-03 0.00E+00
324 240900.00 4080950.00 Worker 0.01 7.89E-04 0.00E+00
325 240950.00 4080950.00 Worker 0.01 5.73E-04 0.00E+00
326 240250.00 4081000.00 Residential 0.36 8.23E-04 0.00E+00 327 240300.00 4081000.00 Residential 0.47 1.08E-03 0.00E+00 329 240850.00 4081000.00 Worker 0.01 8.84E-04 0.00E+00
330 240900.00 4081000.00 Worker 0.01 6.07E-04 0.00E+00
331 240950.00 4081000.00 Worker 0.01 4.48E-04 0.00E+00
332 240250.00 4081050.00 Residential 0.33 7.64E-04 0.00E+00 333 240300.00 4081050.00 Residential 0.43 9.84E-04 0.00E+00 335 240850.00 4081050.00 Worker 0.01 6.24E-04 0.00E+00
336 240900.00 4081050.00 Worker 0.01 4.48E-04 0.00E+00
337 240950.00 4081050.00 Worker 0.00 3.44E-04 0.00E+00
338 240250.00 4081100.00 Residential 0.30 6.86E-04 0.00E+00 339 240300.00 4081100.00 Residential 0.37 8.59E-04 0.00E+00 340 240350.00 4081100.00 Residential 0.49 1.12E-03 0.00E+00 341 240850.00 4081100.00 Worker 0.01 4.33E-04 0.00E+00
342 240900.00 4081100.00 Worker 0.00 3.33E-04 0.00E+00
343 240950.00 4081100.00 Worker 0.00 2.67E-04 0.00E+00
344 240250.00 4081150.00 Residential 0.26 5.99E-04 0.00E+00 Ascent Revisions to the Draft EIR
City of Fresno
Costco Commercial Center Project Final EIR 3-13
RReceptor ID XX--CCoordinate
((m)
YY--CCoordinate
((m)
RReceptor
TType
CCancer Risk
((in a million)
CChronic
HHazard Index
AAcute
HHazard Index
345 240300.00 4081150.00 Residential 0.31 7.21E-04 0.00E+00 346 240350.00 4081150.00 Residential 0.38 8.82E-04 0.00E+00 347 240800.00 4081150.00 Worker 0.01 4.09E-04 0.00E+00
348 240850.00 4081150.00 Worker 0.00 3.18E-04 0.00E+00
349 240900.00 4081150.00 Worker 0.00 2.57E-04 0.00E+00
350 240950.00 4081150.00 Worker 0.00 2.14E-04 0.00E+00
351 240250.00 4081200.00 Residential 0.22 5.08E-04 0.00E+00 352 240300.00 4081200.00 Residential 0.25 5.83E-04 0.00E+00 353 240350.00 4081200.00 Residential 0.29 6.68E-04 0.00E+00 354 240400.00 4081200.00 Residential 0.33 7.54E-04 0.00E+00 355 240450.00 4081200.00 Worker 0.01 8.22E-04 0.00E+00
356 240500.00 4081200.00 Worker 0.01 8.48E-04 0.00E+00
357 240800.00 4081200.00 Worker 0.00 3.02E-04 0.00E+00
358 240850.00 4081200.00 Worker 0.00 2.46E-04 0.00E+00
359 240900.00 4081200.00 Worker 0.00 2.06E-04 0.00E+00
360 240300.00 4081250.00 Residential 0.20 4.62E-04 0.00E+00 361 240350.00 4081250.00 Residential 0.22 5.04E-04 0.00E+00 362 240400.00 4081250.00 Residential 0.23 5.38E-04 0.00E+00 363 240450.00 4081250.00 Worker 0.01 5.56E-04 0.00E+00
364 240500.00 4081250.00 Worker 0.01 5.50E-04 0.00E+00
365 240550.00 4081250.00 Worker 0.01 5.20E-04 0.00E+00
366 240600.00 4081250.00 Worker 0.01 4.69E-04 0.00E+00
367 240650.00 4081250.00 Worker 0.01 4.03E-04 0.00E+00
368 240700.00 4081250.00 Worker 0.00 3.37E-04 0.00E+00
369 240750.00 4081250.00 Worker 0.00 2.81E-04 0.00E+00
370 240800.00 4081250.00 Worker 0.00 2.34E-04 0.00E+00
371 240850.00 4081250.00 Worker 0.00 1.97E-04 0.00E+00
372 240900.00 4081250.00 Worker 0.00 1.69E-04 0.00E+00
373 240350.00 4081300.00 Residential 0.17 3.85E-04 0.00E+00 374 240400.00 4081300.00 Residential 0.17 3.98E-04 0.00E+00 375 240450.00 4081300.00 Worker 0.01 4.00E-04 0.00E+00
376 240500.00 4081300.00 Worker 0.00 3.88E-04 0.00E+00
377 240550.00 4081300.00 Worker 0.00 3.64E-04 0.00E+00
378 240600.00 4081300.00 Worker 0.00 3.32E-04 0.00E+00
379 240650.00 4081300.00 Worker 0.00 2.93E-04 0.00E+00
380 240700.00 4081300.00 Worker 0.00 2.54E-04 0.00E+00
381 240750.00 4081300.00 Worker 0.00 2.19E-04 0.00E+00
382 240800.00 4081300.00 Worker 0.00 1.89E-04 0.00E+00
Revisions to the Draft EIR Ascent
City of Fresno
3-14 Costco Commercial Center Project Final EIR
RReceptor ID XX--CCoordinate
((m)
YY--CCoordinate
((m)
RReceptor
TType
CCancer Risk
((in a million)
CChronic
HHazard Index
AAcute
HHazard Index
383 240850.00 4081300.00 Worker 0.00 1.63E-04 0.00E+00
384 240500.00 4081350.00 Worker 0.00 2.90E-04 0.00E+00
385 240550.00 4081350.00 Worker 0.00 2.73E-04 0.00E+00
386 240600.00 4081350.00 Worker 0.00 2.50E-04 0.00E+00
387 240650.00 4081350.00 Worker 0.00 2.25E-04 0.00E+00
388 240700.00 4081350.00 Worker 0.00 2.00E-04 0.00E+00
389 240750.00 4081350.00 Worker 0.00 1.78E-04 0.00E+00
390 240300.00 4080300.00 Worker 0.00 1.53E-04 0.00E+00
391 240400.00 4080300.00 Worker 0.00 1.73E-04 0.00E+00
392 240500.00 4080300.00 Worker 0.00 1.93E-04 0.00E+00
393 240600.00 4080300.00 Worker 0.00 2.15E-04 0.00E+00
395 240800.00 4080300.00 Residential 0.13 2.94E-04 0.00E+00 396 240900.00 4080300.00 Residential 0.15 3.37E-04 0.00E+00 397 240100.00 4080400.00 Worker 0.00 1.61E-04 0.00E+00
398 240200.00 4080400.00 Worker 0.00 1.77E-04 0.00E+00
399 240300.00 4080400.00 Worker 0.00 2.00E-04 0.00E+00
400 240400.00 4080400.00 Worker 0.00 2.31E-04 0.00E+00
401 240500.00 4080400.00 Worker 0.00 2.65E-04 0.00E+00
404 240800.00 4080400.00 Worker 0.01 4.46E-04 0.00E+00
405 240900.00 4080400.00 Worker 0.01 4.97E-04 0.00E+00
406 241000.00 4080400.00 Worker 0.01 4.97E-04 0.00E+00
409 240300.00 4080500.00 Worker 0.00 2.78E-04 0.00E+00
410 240900.00 4080500.00 Worker 0.01 7.46E-04 0.00E+00
411 241000.00 4080500.00 Worker 0.01 6.59E-04 0.00E+00
412 241100.00 4080500.00 Worker 0.01 5.39E-04 0.00E+00
413 240000.00 4080600.00 Worker 0.00 2.40E-04 0.00E+00
415 240200.00 4080600.00 Worker 0.00 3.63E-04 0.00E+00
416 241000.00 4080600.00 Worker 0.01 7.89E-04 0.00E+00
417 241100.00 4080600.00 Worker 0.01 5.76E-04 0.00E+00
418 240000.00 4080700.00 Worker 0.00 2.83E-04 0.00E+00
419 240100.00 4080700.00 Worker 0.00 3.63E-04 0.00E+00
420 240200.00 4080700.00 Worker 0.01 4.88E-04 0.00E+00
424 240000.00 4080800.00 Worker 0.00 3.10E-04 0.00E+00
425 240100.00 4080800.00 Residential 0.18 4.15E-04 0.00E+00 426 240200.00 4080800.00 Residential 0.26 5.88E-04 0.00E+00 427 241000.00 4080800.00 Worker 0.01 7.11E-04 0.00E+00
428 241100.00 4080800.00 Residential 0.20 4.50E-04 0.00E+00 429 241200.00 4080800.00 Residential 0.13 3.04E-04 0.00E+00 Ascent Revisions to the Draft EIR
City of Fresno
Costco Commercial Center Project Final EIR 3-15
RReceptor ID XX--CCoordinate
((m)
YY--CCoordinate
((m)
RReceptor
TType
CCancer Risk
((in a million)
CChronic
HHazard Index
AAcute
HHazard Index
430 240000.00 4080900.00 Worker 0.00 3.20E-04 0.00E+00
431 240100.00 4080900.00 Residential 0.19 4.43E-04 0.00E+00 432 240200.00 4080900.00 Residential 0.29 6.61E-04 0.00E+00 433 241000.00 4080900.00 Worker 0.01 5.32E-04 0.00E+00
434 241100.00 4080900.00 Residential 0.14 3.33E-04 0.00E+00 435 241200.00 4080900.00 Residential 0.10 2.28E-04 0.00E+00 438 240200.00 4081000.00 Residential 0.28 6.50E-04 0.00E+00 439 241000.00 4081000.00 Worker 0.00 3.48E-04 0.00E+00
440 241100.00 4081000.00 Residential 0.10 2.31E-04 0.00E+00 441 241200.00 4081000.00 Residential 0.07 1.67E-04 0.00E+00 442 240000.00 4081100.00 Worker 0.00 2.99E-04 0.00E+00
443 240100.00 4081100.00 Residential 0.17 4.01E-04 0.00E+00 444 240200.00 4081100.00 Residential 0.25 5.63E-04 0.00E+00 445 241000.00 4081100.00 Worker 0.00 2.21E-04 0.00E+00
446 241100.00 4081100.00 Residential 0.07 1.61E-04 0.00E+00 447 241200.00 4081100.00 Residential 0.05 1.24E-04 0.00E+00 448 240000.00 4081200.00 Worker 0.00 2.70E-04 0.00E+00
449 240100.00 4081200.00 Residential 0.15 3.42E-04 0.00E+00 450 240200.00 4081200.00 Residential 0.19 4.43E-04 0.00E+00 451 241000.00 4081200.00 Residential 0.07 1.53E-04 0.00E+00 452 241100.00 4081200.00 Residential 0.05 1.19E-04 0.00E+00 453 240000.00 4081300.00 Worker 0.00 2.29E-04 0.00E+00
454 240100.00 4081300.00 Residential 0.12 2.71E-04 0.00E+00 455 240200.00 4081300.00 Residential 0.14 3.18E-04 0.00E+00 456 240300.00 4081300.00 Residential 0.16 3.65E-04 0.00E+00 457 240900.00 4081300.00 Worker 0.00 1.42E-04 0.00E+00
458 241000.00 4081300.00 Residential 0.05 1.11E-04 0.00E+00 459 241100.00 4081300.00 Residential 0.04 9.09E-05 0.00E+00 460 240100.00 4081400.00 Residential 0.09 2.04E-04 0.00E+00 461 240200.00 4081400.00 Residential 0.10 2.22E-04 0.00E+00 462 240300.00 4081400.00 Residential 0.10 2.37E-04 0.00E+00 463 240400.00 4081400.00 Residential 0.11 2.42E-04 0.00E+00 464 240500.00 4081400.00 Worker 0.00 2.27E-04 0.00E+00
465 240600.00 4081400.00 Worker 0.00 1.96E-04 0.00E+00
466 240700.00 4081400.00 Worker 0.00 1.63E-04 0.00E+00
467 240800.00 4081400.00 Worker 0.00 1.33E-04 0.00E+00
468 240900.00 4081400.00 Worker 0.00 1.06E-04 0.00E+00
469 241000.00 4081400.00 Residential 0.04 8.51E-05 0.00E+00 Revisions to the Draft EIR Ascent
City of Fresno
3-16 Costco Commercial Center Project Final EIR
RReceptor ID XX--CCoordinate
((m)
YY--CCoordinate
((m)
RReceptor
TType
CCancer Risk
((in a million)
CChronic
HHazard Index
AAcute
HHazard Index
470 241100.00 4081400.00 Residential 0.03 7.10E-05 0.00E+00 471 240200.00 4081500.00 Residential 0.07 1.60E-04 0.00E+00 472 240300.00 4081500.00 Residential 0.07 1.65E-04 0.00E+00 473 240400.00 4081500.00 Residential 0.07 1.64E-04 0.00E+00 474 240500.00 4081500.00 Worker 0.00 1.51E-04 0.00E+00
475 240600.00 4081500.00 Worker 0.00 1.32E-04 0.00E+00
476 240700.00 4081500.00 Worker 0.00 1.15E-04 0.00E+00
477 240800.00 4081500.00 Worker 0.00 9.95E-05 0.00E+00
478 240900.00 4081500.00 Worker 0.00 8.34E-05 0.00E+00
479 241000.00 4081500.00 Residential 0.03 6.89E-05 0.00E+00 480 240500.00 4081600.00 Worker 0.00 1.09E-04 0.00E+00
481 240600.00 4081600.00 Worker 0.00 9.66E-05 0.00E+00
482 240700.00 4081600.00 Worker 0.00 8.64E-05 0.00E+00
483 240800.00 4081600.00 Worker 0.00 7.75E-05 0.00E+00
484 240500.00 4079750.00 Worker 0.00 6.31E-05 0.00E+00
485 240750.00 4079750.00 Worker 0.00 7.34E-05 0.00E+00
486 240000.00 4080000.00 Residential 0.03 6.55E-05 0.00E+00 487 240250.00 4080000.00 Worker 0.00 8.18E-05 0.00E+00
489 240750.00 4080000.00 Worker 0.00 1.17E-04 0.00E+00
490 241000.00 4080000.00 Residential 0.07 1.53E-04 0.00E+00 491 241250.00 4080000.00 Residential 0.08 1.79E-04 0.00E+00 492 239750.00 4080250.00 Worker 0.00 8.98E-05 0.00E+00
493 240000.00 4080250.00 Worker 0.00 1.05E-04 0.00E+00
494 240250.00 4080250.00 Worker 0.00 1.27E-04 0.00E+00
495 241000.00 4080250.00 Residential 0.13 3.09E-04 0.00E+00 496 241250.00 4080250.00 Residential 0.13 2.94E-04 0.00E+00 501 241250.00 4080500.00 Worker 0.00 3.77E-04 0.00E+00
506 241500.00 4080750.00 Residential 0.06 1.42E-04 0.00E+00 507 239500.00 4081000.00 Worker 0.00 1.09E-04 0.00E+00
508 239750.00 4081000.00 Worker 0.00 1.71E-04 0.00E+00
510 241500.00 4081000.00 Residential 0.04 8.22E-05 0.00E+00 511 239500.00 4081250.00 Worker 0.00 1.05E-04 0.00E+00
512 239750.00 4081250.00 Worker 0.00 1.56E-04 0.00E+00
513 241250.00 4081250.00 Residential 0.03 7.88E-05 0.00E+00 514 241500.00 4081250.00 Residential 0.02 5.37E-05 0.00E+00 515 239750.00 4081500.00 Worker 0.00 1.18E-04 0.00E+00
516 240000.00 4081500.00 Worker 0.00 1.44E-04 0.00E+00
517 241250.00 4081500.00 Residential 0.02 4.69E-05 0.00E+00 Ascent Revisions to the Draft EIR
City of Fresno
Costco Commercial Center Project Final EIR 3-17
RReceptor ID XX--CCoordinate
((m)
YY--CCoordinate
((m)
RReceptor
TType
CCancer Risk
((in a million)
CChronic
HHazard Index
AAcute
HHazard Index
518 241500.00 4081500.00 Residential 0.02 3.65E-05 0.00E+00 519 239750.00 4081750.00 Worker 0.00 6.76E-05 0.00E+00
520 240000.00 4081750.00 Worker 0.00 7.22E-05 0.00E+00
521 240250.00 4081750.00 Worker 0.00 7.62E-05 0.00E+00
522 240500.00 4081750.00 Worker 0.00 6.55E-05 0.00E+00
523 240750.00 4081750.00 Worker 0.00 5.81E-05 0.00E+00
524 241000.00 4081750.00 Worker 0.00 4.57E-05 0.00E+00
525 241250.00 4081750.00 Worker 0.00 3.29E-05 0.00E+00
526 240250.00 4082000.00 Worker 0.00 4.99E-05 0.00E+00
527 240500.00 4082000.00 Worker 0.00 4.19E-05 0.00E+00
528 240750.00 4082000.00 Worker 0.00 3.42E-05 0.00E+00
529 241000.00 4082000.00 Worker 0.00 3.13E-05 0.00E+00
531 240000.00 4079000.00 Residential 0.01 2.60E-05 0.00E+00 532 240500.00 4079000.00 Residential 0.01 2.72E-05 0.00E+00 534 241500.00 4079000.00 Worker 0.00 4.22E-05 0.00E+00
535 239000.00 4079500.00 Worker 0.00 2.66E-05 0.00E+00
536 239500.00 4079500.00 Residential 0.01 3.00E-05 0.00E+00 537 240000.00 4079500.00 Residential 0.02 3.74E-05 0.00E+00 538 240500.00 4079500.00 Residential 0.02 4.53E-05 0.00E+00 539 241000.00 4079500.00 Worker 0.00 6.06E-05 0.00E+00
540 241500.00 4079500.00 Worker 0.00 8.16E-05 0.00E+00
541 242000.00 4079500.00 Residential 0.04 8.13E-05 0.00E+00 542 239000.00 4080000.00 Worker 0.00 4.32E-05 0.00E+00
543 239500.00 4080000.00 Residential 0.02 5.33E-05 0.00E+00 544 241500.00 4080000.00 Residential 0.07 1.70E-04 0.00E+00 545 242000.00 4080000.00 Residential 0.05 1.08E-04 0.00E+00 546 242500.00 4080000.00 Residential 0.03 5.90E-05 0.00E+00 547 238500.00 4080500.00 Worker 0.00 3.80E-05 0.00E+00
548 239000.00 4080500.00 Worker 0.00 5.87E-05 0.00E+00
549 242000.00 4080500.00 Residential 0.03 7.85E-05 0.00E+00 550 242500.00 4080500.00 Residential 0.02 4.11E-05 0.00E+00 551 238500.00 4081000.00 Worker 0.00 3.72E-05 0.00E+00
552 239000.00 4081000.00 Worker 0.00 5.84E-05 0.00E+00
553 242000.00 4081000.00 Residential 0.02 3.88E-05 0.00E+00 554 242500.00 4081000.00 Residential 0.01 2.35E-05 0.00E+00 555 238500.00 4081500.00 Worker 0.00 3.39E-05 0.00E+00
556 239000.00 4081500.00 Worker 0.00 5.34E-05 0.00E+00
557 239500.00 4081500.00 Worker 0.00 9.03E-05 0.00E+00
Revisions to the Draft EIR Ascent
City of Fresno
3-18 Costco Commercial Center Project Final EIR
RReceptor ID XX--CCoordinate
((m)
YY--CCoordinate
((m)
RReceptor
TType
CCancer Risk
((in a million)
CChronic
HHazard Index
AAcute
HHazard Index
558 242000.00 4081500.00 Residential 0.01 2.43E-05 0.00E+00 559 242500.00 4081500.00 Residential 0.01 1.69E-05 0.00E+00 560 239000.00 4082000.00 Worker 0.00 3.90E-05 0.00E+00
561 239500.00 4082000.00 Worker 0.00 4.55E-05 0.00E+00
562 240000.00 4082000.00 Worker 0.00 4.98E-05 0.00E+00
563 241500.00 4082000.00 Residential 0.01 2.01E-05 0.00E+00 564 242000.00 4082000.00 Residential 0.01 1.44E-05 0.00E+00 565 239500.00 4082500.00 Worker 0.00 2.75E-05 0.00E+00
566 240000.00 4082500.00 Worker 0.00 2.85E-05 0.00E+00
567 240500.00 4082500.00 Worker 0.00 2.28E-05 0.00E+00
568 241000.00 4082500.00 Worker 0.00 1.90E-05 0.00E+00
569 241500.00 4082500.00 Worker 0.00 1.39E-05 0.00E+00
570 242000.00 4082500.00 Worker 0.00 1.01E-05 0.00E+00
571 240000.00 4083000.00 Worker 0.00 1.80E-05 0.00E+00
572 240500.00 4083000.00 Worker 0.00 1.45E-05 0.00E+00
573 241000.00 4083000.00 Worker 0.00 1.27E-05 0.00E+00
574 240982.00 4080428.00 Sensitive 0.24 5.48E-04 0.00E+00 575 241114.00 4080505.00 Sensitive 0.23 5.25E-04 0.00E+00 576 241812.00 4080393.00 Sensitive 0.05 1.20E-04 0.00E+00 577 239709.00 4079647.00 Sensitive 0.02 3.64E-05 0.00E+00 578 239709.00 4079647.00 Sensitive 0.02 3.64E-05 0.00E+00 579 242094.00 4081102.00 Sensitive 0.01 3.07E-05 0.00E+00 580 242489.00 4081376.00 Sensitive 0.01 1.80E-05 0.00E+00 581 241998.00 4079399.00 Sensitive 0.03 7.42E-05 0.00E+00 582 242523.00 4080146.00 Sensitive 0.02 5.26E-05 0.00E+00 583 240160.00 4078896.00 Sensitive 0.01 2.46E-05 0.00E+00 584 242576.00 4081764.00 Sensitive 0.01 1.39E-05 0.00E+00 585 242632.00 4080241.00 Sensitive 0.02 4.37E-05 0.00E+00

City of Fresno
Costco Commercial Center Project Final EIR 4-1
4 REFERENCES
Berry, Keith. General Manager. Riverside Golf Course, Fresno, CA. November 2023—email correspondence with Jose Valenzuela of City of Fresno Current Planning regarding bird and bat entanglements in existing netting at the Riverside Golf Course.

California Air Pollution Control Officers Association. 2021. California Emissions Estimator Model. Available:
https://www.caleemod.com/. Accessed July 20, 2022.

Chapman, Gary. Engineering Technician III. Fresno Metropolitan Flood Control District, Fresno, CA. March and April 2021—email correspondence with Andrew Delia of Kimley-Horn regarding drainage requirements.

City of Fresno. 2020 (March). Draft General Plan Program Environmental Impact Report. Available at:
https://files.ceqanet.opr.ca.gov/251381-3/attachment/JsvsQ9T4pAdj4Lj9OPIuO2sgMySq5NAm9i9yd JNaS_htKcRHJhCmMopYXWJuNe5Z20ymjoTsSkL7xUyk0. Accessed September 20, 2023.

Dayton Daily News 2016. West Chester's new Topgolf almost county's tallest 'building.' Available at:
https://www.daytondailynews.com/news/local/west-chester-new-topgolf-almost-county-tallest-building/ bNxanFgh8tF65HdQrsZbRO/. Accessed September 20, 2023.

Fresno Council of Governments. 2022 2022 Regional Transportation Plan and Sustainable Communities Strategy.

Adopted July 28, 2022. Available: https://www.planfresno.com/sustainable-communities-strategies-fall- outreach/.

Holliday, Pari. Real Estate Development Director. Costco, Irvine, CA. November 15, 2023—Letter to Jose Valenzuela of City of Fresno Current Planning regarding the elements of the proposed Costco Commercial Center.

San Bernardino County. 2019 (April). Initial Study for Development of a TopGolf Entertainment Facility. Available at:
https://www.sbcounty.gov/Uploads/LUS/Environmental/TopGolf_Website/ Topgolf%20Entertainment%20IS%20April%202019.pdf. Accessed: September 20, 2023.

Spencer, W.D., P. Beier, K. Penrod, K. Winters, C. Paulman, H. Rustigian-Romsos, J. Strittholt, M. Parisi, and A. Pettler. 2010. California Essential Habitat Connectivity Project: A Strategy for Conserving a Connected California .

Available: https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18366. Accessed November 17, 2021.

References Ascent
City of Fresno
4-2 Costco Commercial Center Project Final EIR
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City of Fresno
Costco Commercial Center Project Final EIR 5-1
5 LIST OF PREPARERS
City of Fresno (Lead Agency)
Phillip Siegrist .........................................................................................................................................................................Planning Manager Jose Valenzuela .................................................................................................................................................................. Supervising Planner Steven Martinez ......................................................................................................................................................................................... Planner Ascent Environmental, Inc. (CEQA Compliance)
Mike Parker, AICP .................................................................................................................................................................................... Principal Jessica Babcock......................................................................................................................................................................... Project Manager Nicole Greenfield ......................................................................................................................................................... Environmental Planner Gayiety Lane ....................................................................................................................................................................... Publishing Specialist Michele Mattei ................................................................................................................................................................... Publishing Specialist Ramboll US Consulting (Air Quality, Greenhouse Gas, Energy) Eric Lu...................................................................................................................................................................................... Managing Principal Haley Ozcan ..................................................................................................................................................................... Managing Consultant Kittleson & Associates (Transportation)
Amy R. Lopez .......................................................................................................................................................................... Associate Planner Urban Planning Partners (Applicant Representative)
Lynette Dias ............................................................................................................................................................................................. President

List of Preparers Ascent
City of Fresno
5-2 Costco Commercial Center Project Final EIR
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Appendix A
Urban Decay Impact Memorandum

ALH|ECON
ALH Urban & Regional Economics

1 2239 Oregon Street
Berkeley, CA 94705
510.704.1599
[email protected]

MEMORANDUM

To: Pari Holliday, Director, Real Estate Development, Costco Wholesale

From: Amy L. Herman, Principal

Re: Costco Fresno Relocation and Gas Station Urban Decay Impacts

Date: December 15, 2023

Introduction

ALH Urban & Regional Economics (“ALH Economics”) understands that Costco Wholesale has proposed development of a relocated Costco store in northwest Fresno, CA at the northeast corner of North Riverside Drive and West Herndon Avenue (the “Project”). The proposed Costco store would relocate the existing store at 4500 Shaw Avenue, Fresno, CA, which has an existing gas station. While the Shaw Avenue Costco store would close, the existing gas station would continue to operate along with the proposed new gas station. Thus, Project development would result in the net addition of 32 fueling stations (i.e., 16 pumps) to Fresno’s supply of gas stations, plus a drive-through car wash. There is yet another Costco gas station in Fresno located at 7100 N Abby Street.

A Draft Environmental Impact Report has been prepared for the Project. As part of the public review process of the DEIR, a limited number of comments were submitted expressing concern about the impact of the new gasoline pumps on the existing base of gas stations, as well as food store impacts. ALH Economics has prepared many studies examining the local urban decay impacts of Costco stores, Costco gas stations, or other large-scale general merchandise stores with food sales. These studies have been prepared for highly urbanized locations such as northwest Fresno. A typical definition of urban decay is as follows:

[U]rban decay is defined as, among other characteristics, visible symptoms of physical deterioration that invite vandalism, loitering, and graffiti that is caused by a downward spiral of business closures and multiple long term vacancies. This physical deterioration to properties or structures is so prevalent, substantial, and lasting for a significant period of time th at it impairs the proper utilization of the properties and structures, or the health, safety, and welfare of the surrounding community. The manifestations of urban decay include such visible conditions as plywood-boarded doors and windows, parked trucks and long term unauthorized use of the properties and parking lots, extensive gang and other graffiti and ALH|ECON
ALH Urban & Regional Economics

2 offensive words painted on buildings, dumping of refuse on site, overturned dumpsters, broken parking barriers, broken glass littering the site, dead trees and shrubbery together with weeds, lack of building maintenance, abandonment of multiple buildings, homeless encampments, and unsightly and dilapidated fencing.” These visible conditions are often characterized as “urban blight.” 1 This memorandum provides some select insights into prospective urban decay impacts assessed in other California communities with Costco gas stations and their applicability to the current proposed Costco gas station and relocated store, as well as additional analysis pertinent to Fresno.

There are exhibits cited in this memorandum. These exhibits are included as Appendix A.

Appendix B includes firm qualifications for ALH Economics, especially relative to urban decay analyses for retail projects, as well as a resume for the firm Principal, Amy L. Herman.

Gas Station Impact Analysis

Of most relevancy to Fresno, in 2020 ALH Economics assessed the prospective economic impacts, or urban decay impacts, of Costco Wholesale’s proposed development of a 32-pump fuel facility next to an existing Costco Business Center. In the process of preparing this analysis, ALH Economics conducted case study analysis of three California cities where a Costco gas station was recently added to the community. These case studies were prepared for the cities of Santa Maria (Santa Barbara County), Eastvale (Riverside County), and Ukiah (Mendocino County). The gas stations in these communities were developed in 2017, 2018, and 2018, respectively. In seeking to analyze the impacts of these gas stations, ALH Economics examined a trend in quarterly gasoline sales and the number of outlets selling gasoline in each community, focusing on the trend both before and after introduction of the new Costco gas station and after.

The gasoline sales changes in each community were compared to gasoline sector sales throughout the State of California. These data are presented in Exhibit 1.

The findings of this analysis indicated that each community’s initial response was a short-term downward trend in gasoline sales, then a re-stabilization within six months after a period of market adjustment, marked by no decline in the number of gas stations, with some cities even increasing the number of gas stations or planning expansions. Subsequent to the preparation of this analysis, the COVID-19 pandemic significantly impacted the gasoline sector in all of these case study cities, as well as throughout the State of California, as automobile-based work commutes and other automobile trips diminished greatly. Examination of taxable retail sales data published by the State of California Department of Tax and Fee Administration indicates that gasoline sales in California declined by almost 30% from 2019 to 2020, with very similar 1 See Chico Advocates for a Responsible Economy v. City of Chico (Chico Advocates) (2019), 40 Cal.App.5th 839, 843, and Joshua Tree Downtown Bus. All. v. County of San Bernardino (Joshua Tree) (2016) 1 Cal. App. 5th 677, 685.

ALH|ECON
ALH Urban & Regional Economics

3 percentage declines in the case study cities. However, as the economy recovered, two of the case study cities experienced year to year percent sales increases greater than the State of California.

And by 2022, all three cities achieved annual gasoline sales significantly greater than pre- pandemic (see Exhibit 1). Moreover, by 2022, all three cities had more gas stations than they did prior to the opening of the Costco gas station under study, with the percentage increase in the number of gas stations greatly exceeding the percentage population growth over the same time period.

The annual trend data applicable to these case study cities and the State of California is also presented in Exhibit 1. For each case study city, this exhibit includes the annual number of permitted outlets selling gasoline, annual taxable gasoline sales, and the year-to-year percent change in sales, benchmarked to the annual percent change throughout the State. Exhibit 2 presents population trend data for each case study city over the 2016 to 2022 period, including a gas sales per capita metric. Thus, some of the poignant findings from the data in Exhibits 1 and 2 include the following:

x In Santa Maria, where the Costco gas station opened in 2017, the number of gasoline outlets grew 29% from 2016 to 2022, compared to a scant 3% population growth. Over the same period, gasoline sales increased by 83%.

x In Eastvale, where the Costco gas station opened in 2018, the number of gasoline outlets grew 33% from 2017 to 2022, while population increased by a much lower 10%. Over the same period, gasoline sales increased by 71%; and

x In Ukiah, where the Costco gas station also opened in 2018, the number of gasoline outlets grew 20% from 2017 to 2022, with gasoline sales increasing by a comparable 18%, while the already low population base increased by a nominal 1%.

While some of these sales changes can be tied to the volatility in gasoline pricing, they nevertheless indicate an increasing trend in the number of gasoline stations and gross amount of gasolines sales after the opening of a Costco gas station. Thus, these findings strongly suggest the base of gas stations existing prior to the development of the Costco gas stations are not negatively impacted by the Costco gas station, and thus do not result in closed gas stations potentially leading to urban decay.

This bodes well for the base of existing gas stations in northwest Fresno, as the case study data indicate that both in the near-term of six months and more long-term, gas sales in communities with new Costco gas stations rebound and grow, indicating a lack of economic impact associated with the Costco gas station. The likelihood this will also be the case in Fresno is further suggested by the per capita gasoline sales data presented in Exhibit 2, which also includes the City of Fresno. As these data indicate, per capita gasoline sales in the case study cities in 2022 ranged from a low of $989 in Eastvale to a high of $2,830 in Ukiah. The per capita figure of $2,183 in Santa Maria was also at the high end. These fi gures compare to $1,824 throughout the State of California. The comparable figure for Fresno in 2022 was $1,445. This suggests that Fresno’s ALH|ECON
ALH Urban & Regional Economics

4 gasoline sales are underperforming relative to the State as a whole, as well as other cities with Costco gas stations. Accordingly, these trends point to the potential for Fresno to be able to absorb additional gasoline sales, raising the per capita average. In addition, the percent increase in gas sales per capita metric shown in Exhibit 2 indicates that this measure has not increased in Fresno as much as most of the other cited locations, including the State of California. Specifically, from 2016 to 2022, gas sales per capita increased by 41% in Fresno, which is significantly lower than the 65% increase in the State of California and the 69% and 78% increases in Eastvale and Santa Maria, respectively. Only Ukiah had a lower percentage increase over the same time period, of 34%.

There are at least two other factors that suggest the impact on existing Fresno gas stations will be minimal, especially over time. First, only Costco members can purchase gas at Costco gas stations. In contrast, any consumer can purchase gas at the existing base of gasoline stations, many of which likely offer a wider range of fuel products, are open longer hours and for more days of the week, sell on-site convenience store products, have customer restrooms (which are not a Costco gas station feature), and in some cases provide expanded automobile care services.

Thus, all or most of the existing gas stations have more customer service offerings than Costco and they all have access to a broader customer base because they do not have a customer membership requirement. Lastly, because the proposed new Costco gas station will be about 3.4 miles from the existing Costco gas station, as well as about 7.0 miles from the other Costco gas station in Fresno, it is likely to draw some demand away from these stations. This is attributable to proximity, since gas is often a purchase of convenience, based on need and easy access, including pass-by demand en route to home, work, or other destinations. Costco members who live or work closer to the proposed gas station, may very well shift their demand away from the existing Costco gas stations in favor of the new gas station for this reason.

In summary, many factors suggest that the proposed Costco gas station at the northeast corner of North Riverside Drive and West Herndon Avenue will have minimal impact on existing Fresno gas stations, especially beginning six months or so after the new gas station opens. As a result, the opening of the new gas station is not likely to result in strong sales declines at existing gas stations, and none of the existing gas stations are likely to close. Consequently, urban decay, which can result from conditions associated with closed retail outlets, is not anticipated to result from development of the new Costco gas station.

Food Store Impacts

ALH Economics has prepared numerous urban decay studies for food stores or general merchandise stores with a significant food sales component. This includes EIR’s prepared for developments featuring stores such as Safeway, Whole Foods, Grocery Outlet Bargain Market, Walmart, Costco, and Target. Many of these projects are identified in Appendix B: Firm Qualifications and Principal Resume. As part of the process of preparing these studies, ALH Economics inventoried existing competitive food stores and estimated the sales impact of the store under study on these competitive stores. This analysis takes into consideration the market niches ALH|ECON
ALH Urban & Regional Economics

5 of each competitive store, the likely market area from which study stores will attract shoppers, and demographic growth trends.

Generally, in communities with a strong retail sector and demographic growth, the findings pertaining to the food sales components of the proposed new stores typically found there to be only a negligible impact on existing food store sales, not sufficient to put stores at risk of closure, and recouped over time depending upon the community’s anticipated population and household growth. ALH Economics believes these generalized findings will equally pertain to the relocated Costco Wholesale store and its food sales component. This belief is supported by a consistent upward trend in the City of Fresno’s taxable food sales, dating back to at least 2016. As shown in Table 1, the City of Fresno’s taxable food sales annually increased by a low of 3.1% to a high of

12.6% over the 2016-2022 time period. This indicates that food sales are strong in Fresno, with consistently increasing demand.

TTaxable
YYear Food Sales Amount Percent
2016 $375,394,312 - -
2017 $400,190,134 $24,795,822 6.6%
2018 $422,475,761 $22,285,627 5.6%
2019 $439,513,698 $17,037,937 4.0%
2020 $453,009,159 $13,495,461 3.1%
2021 $509,955,408 $56,946,249 12.6%
2022 $535,468,780 $25,513,372 5.0%
A
Annual Increase
TTable 1. Annual Taxable Foods Sales
CCity of Fresno, 2016-2022
Sources: State of California, Department of Tax and
Fee Administration, Annual Taxable Sales Reports;
and ALH Urban & Regional Economics.

This future growth in food store sales is likely to continue into the future, consistent with future population and household growth. While it is not specific to the City of Fresno, the demographic projections in Table 2 indicate that Fresno County population is projected to grow consistently on an annual basis. Projections prepared by the State of California Department of Finance (DOF) suggest annual growth of about 0.4% to 0.5% per year up to the year 2030 (further growth is projected by DOF beyond this time period).

Other data prepared by DOF suggest that the City of Fresno’s population consistently comprises 53% to 54% of the County’s population.
2 Thus, a significant portion of the countywide population growth will likely occur in Fresno assuming this trend continues into the future. This growth will continue to fuel demand for food store sales, thus offsetting any prospective negative food store sales impacts associated with the Costco relocation.
2 This finding is based on population data prepared by DOF, spanning the 2010’s and beyond.

ALH|ECON
ALH Urban & Regional Economics

6 PProjected
YYear Population Amount Percent
2020 1,007,344 -
2021 1,010,453 3,109 0.3%
2022 1,012,350 1,897 0.2%
2023 1,015,793 3,443 0.3%
2024 1,019,575 3,782 0.4%
2025 1,023,586 4,011 0.4%
2026 1,027,816 4,230 0.4%
2027 1,031,968 4,152 0.4%
2028 1,036,474 4,506 0.4%
2029 1,042,150 5,676 0.5%
2030 1,047,382 5,232 0.5%
T
Table 2. Fresno County Population Projections
22020-2030
AAnnual Increase
Sources: State of California, Department of Finance,
Report P-2C: Population Projections by Sex and 5-
year Age Group, 2020-2060; and ALH Urban &
Regional Economics.

The most substantial factor contributing to minimal food store sales impacts will be the fact that the Costco store is being relocated, rather than the Project comprising a net new Costco store in the Fresno market. In all likelihood existing Costco shoppers will transfer their purchases from the existing store to the new store, such that diversions from existing area food stores will be at a minimum. Thus, sales impacts are not likely to be high enough to contribute to the closure of existing food stores, and urban decay is not likely to result.

Summary Conclusion

In summary, past findings in other communities and existing and projected data for the City of Fresno all suggest that the gas station and food store retail sectors in Fresno are not likely to be significantly impacted by the relocation of the Shaw Avenue Costco store and opening of a net new gas station in association with this relocated store. Accordingly, the Project is not anticipated to cause or contribute to conditions of urban decay in the City of Fresno.

This memorandum is subject to the following Assumptions and General Limiting Conditions.

Projects\2023\Costco Fresno\2310\2310.m01

ASSUMPTIONS AND GENERAL LIMITING CONDITIONS

ALH Urban & Regional Economics has made extensive efforts to confirm the accuracy and timeliness of the information contained in this study. Such information was compiled from a variety of sources, including interviews with government officials, review of City and County documents, and other third parties deemed to be reliable. Although ALH Urban & Regional Economics believes all information in this study is correct, it does not warrant the accuracy of such information and assumes no responsibility for inaccuracies in the information by third parties. We have no responsibility to update this report for events and circumstances occurring after the date of this report. Further, no guarantee is made as to the possible effect on development of present or future federal, state or local legislation, including any regarding environmental or ecological matters.

The accompanying projections and analyses are based on estimates and assumptions developed in connection with the study. In turn, these assumptions, and their relation to the projections, were developed using currently available economic data and other relevant information. It is the nature of forecasting, however, that some assumptions may not materialize, and unanticipated events and circumstances may occur. Therefore, actual results achieved during the projection period will likely vary from the projections, and some of the variations may be material to the conclusions of the analysis.

Contractual obligations do not include access to or ownership transfer of any electronic data processing files, programs or models completed directly for or as by-products of this research effort, unless explicitly so agreed as part of the contract.

APPENDIX A: EXHIBITS
Exhibit 1
Gas Station Establishments and Taxable Sales, Before and After Opening of Costco Gas Stations (1) Cities of Santa Maria, Eastvale, and Ukiah, Compared to State of California Change in Gas Station Sales (2) 2016 through Second Quarter 2019; and 2016 through 2022 Annually City City City City City City
Year Qrtr Permits Sales (3) Permits Sales (3) Permits Sales (3) 2016 Q1 $9.8 22 $28,753,344 - - 5 $6,931,734 - - 13 $8,025,415 - - 2016 Q2 $11.2 21 $34,229,152 19% 14% 5 $9,327,188 35% 14% 13 $8,602,327 7% 14% 2016 Q3 $11.4 22 $35,705,963 4% 1% 5 $9,326,994 0% 1% 13 $8,682,997 1% 1% 2016 Q4 $10.9 21 $32,275,056 -10% -4% 5 $8,937,192 -4% -4% 13 $8,085,814 -7% -4% 2017 Q1 $10.8 22 $31,899,587 -1% 0% 6 $7,975,912 -11% 0% 13 $9,151,355 13% 0% 2017 Q2 $12.1 21 $37,752,870 18% 12% 6 $9,860,201 24% 12% 12 $9,707,151 6% 12% 2017 Q3 $12.4 21 $39,433,674 4% 2% 6 $10,220,107 4% 2% 11 $9,798,948 1% 2% 2017 Q4 $12.1 22 $34,962,172 -11% -2% 6 $10,283, 603 1% -2% 10 $9,745,262 -1% -2% 2018 Q1 $12.4 22 $32,843,761 -6% 2% 6 $11,950, 950 16% 2% 10 $9,986,917 2% 2% 2018 Q2 $14.1 23 $41,298,199 26% 14% 5 $13,540,070 13% 14% 10 $10,469,821 5% 14% 2018 Q3 $14.2 23 $35,995,544 -13% 0% 5 $10,030,173 -26% 0% 10 $9,908,776 -5% 0% 2018 Q4 $13.6 23 $34,041,181 -5% -4% 4 $8,774, 641 -13% -4% 10 $8,847,462 -11% -4% 2019 Q1 $11.7 23 $33,074,430 -3% -14% 5 $7,396,867 -16% -14% 10 $6,071,999 -31% -14% 2019 Q2 $14.6 23 $43,416,205 31% 25% 5 $9,944, 539 34% 25% 11 $10,116,866 67% 25% City City City City City City
Year Permits Sales (3) Permits Sales (3) Permits Sales (3) 2016 $43.3 21 $130,963,515 - 5 $34,523,108 - 13 $33,396,553 - 2017 $47.4 22 $144,048,303 10% 10% 6 $38,339,823 11% 10% 10 $38,402,716 15% 10% 2018 $54.3 23 $150,025,076 4% 14% 4 $47,072,735 23% 14% 10 $39,212,976 2% 14% 2019 $54.1 23 $160,472,181 7% 0% 5 $35,085,275 -25% 0% 13 $34,569,499 -12% 0% 2020 $38.3 22 $113,308,111 -29% -29% 5 $23,392,845 -33% -29% 12 $33,245,337 -4% -29% 2021 $56.2 22 $178,407,693 57% 47% 5 $46,741, 916 100% 47% 11 $39,524,382 19% 47% 2022 $71.3 27 $239,294,794 34% 27% 8 $65,684,000 41% 27% 12 $45,424,981 15% 27% 29% 83% 33% 71% 20% 18%
(2) The trend analysis for each city includes the State of Calfiornia trend in gas station sales on a quarter over quarter basis. (3) All dollars are in current year dollars, and have not been adjusted for inflation. in $bil Change Change Change Change Change Change
CA State
Sales City Sales State Sales City Sale s State Sales City Sales State Sales (1) Each Costco gas station opening date is identified in the column headings by City. For each city, the figures corresponding to the quarter during which the Costco gas station opened are shaded in light gray.

Sources: State of California Department of Tax and Fee Administration, First Quarter 2016 through Third Quarter 2019, Taxable Quarterly Reports; Costco Wholesale Corporation; and ALH Urban & Regional Economics.

City of Santa Maria & CA City of Eastvale & CA City of Ukiah & CA CA State
Sales
in $bil
2016 - 2022 Percent
Increase
2017 - 2022 Percent
Increase
2017 - 2022 Percent
Increase
Date Costco Gas Station Opened: 9/13/2017 Date Costco Gas Stat ion Opened: 6/5/2018 Date Costco Gas Station Opened: 7/18/2018 Change
City Sales State Sales City Sales S tate Sales City Sales State Sales Change Change Change Change Change
Exhibit 2
Population and Gas Sales Per Capita (1)
Cities of Santa Maria, Eastvale, Ukiah, Fresno and the State of California (2) 2016 through 2022 (2)
Gas Sales Gas Sales Gas Sales Gas Sales Gas Sales
Year Population Per Capita Population Per Capita Populati on Per Capita Population Per Capita Population Per Capita 2016 106,744 $1,227 62,147 $556 15,796 $2,114 529,552 $1,027 39,179,627 $1,104 2017 107,978 $1,334 63,720 $602 15,889 $2,417 533,670 $1,106 39,500,973 $1,201 2018 108,470 $1,383 64,855 $726 16,226 $2,417 538,330 $1,142 39,809,693 $1,364 2019 107,356 $1,495 66,078 $531 16,296 $2,121 536,683 $1,095 39,927,315 $1,356 2020 109,660 $1,033 69,742 $335 16,604 $2,002 542,081 $858 39,538,223 $970 2021 110,672 $1,612 70,457 $663 16,220 $2,437 541,652 $1,223 39,286,510 $1,431 2022 109,617 $2,183 69,978 $939 16,052 $2,830 542,829 $1,445 39,078,674 $1,824 3% 78% 13% 69% 2% 34% 3% 41% 0% 65%
(1) All dollars are in current year dollars, and have not been adjusted for inflation.

City of Santa Maria City of Eastvale City of Ukiah City of Fresno State of California Sources: Exhibit 1; State of California Department of Finance, Table 2: E-5 City/County Population and Housing Estimates, 1/1/2018, 1/1/2019; and 1/1/2023; and ALH Urban & Regional Economics.
(2) The shaded lines indicate the year corresponsing with a Costco gas station opening date. Some locations are presented for general reference. 2016 - 2022 Percent Increase 2016 - 2022 Percent Increase 2016 - 2022 Percent Increase 2016 - 2022 Percent Increase 2016 - 2022 Per cent Increase

APPENDIX B

FIRM QUALIFICATIONS AND PRINCIPAL RESUME

FIRM INTRODUCTION
ALH Urban & Regional Economics (ALH Economics) is a sole proprietorship devoted to providing urban and regional economic consulting services to clients throughout California. The company was formed in June 2011. Until that time, Amy L. Herman, Principal and Owner (100%) of ALH Economics, was a Senior Managing Director with CBRE Consulting in San Francisco, a division of the real estate services firm CB Richard Ellis. CBRE Consulting was the successor firm to Sedway Group, in which Ms. Herman was a part owner, which was a well-established urban economic and real estate consulting firm acquired by CB Richard Ellis in late 1999.

ALH Economics provides a range of economic consulting services, including:

x fiscal and economic impact analysis
x CEQA-prescribed urban decay analysis
x economic studies in support of general plans, specific plans, and other long-range planning efforts
x market feasibility analysis for commercial, housing, and industrial land uses x economic development and policy analysis
x other specialized economic analyses tailored to client needs

Since forming ALH Economics, Ms. Herman’s client roster includes California cities, counties, and other public agencies; educational institutions; architectural, environmental, and other real estate-related consulting firms; commercial and residential developers; non-profits; and law firms. A select list of ALH Economics clients includes the following:

x the cities of Concord, Pleasanton, Tracy, Dublin, Inglewood, Petaluma, and Los Banos, the Office of Community Investment and Infrastructure as Successor Agency to the Redevelopment Agency of the City and County of San Francisco, Alameda County Community Development Agency, the Alameda County Fair, Bay Area Rapid Transit District, East Bay Community Energy, and The Presidio Trust; x the University of California at Berkeley, Stanford Real Estate, The Primary School, The Claremont Colleges Services, and the University of California at Riverside; x Environmental Science Associates (ESA), Dudek, Group 4 Architecture, Research + Planning, Inc., Paul Halajian Architects, LSA Associates, Raney Planning and Management, Inc., First Carbon Solution s - Michael Brandman Associates, and Infrastructure Management Group, Inc.;
x Catellus Development Corporation, Maximus Real Estate Partners, New West Communities, Build, Inc., Arcadia Development Co., KB Home, Howard Hughes Corporation dba Victoria Ward LLC, Blu Homes, Inc., Kimco Realty, Align Real Estate LLC, Centercal, Carvana Co., and Trammell Crow Residential;
x Costco Wholesale Corporation, One Medical, Golden State Lumber, Public Storage, Home Depot, and Lifetime Fitness;
x Gresham Savage Nolan & Tilden, PC, Remy Moose Manley, Pelosi Law Group, Sedgwick LLP, Coblentz Patch Duffy & Bass LLP

Throughout her more than 30-year career, Ms. Herman has managed real estate consulting assignments for hundreds of additional clients, including many California cities, corporations, residential, commercial, and industrial real estate developers, and Fortune 100 firms.

RELEVANT EXPERIENCE: RETAIL URBAN DECAY STUDIES

Description of Services
The Principal of ALH Economics, Amy L. Herman, has performed economic impact and urban decay studies for a number of retail development projects in California. These studies have generally been the direct outcome of the 2004 court ruling Bakersfield Citizens for Local Control (“BCLC”) v. City of Bakersfield (December 2004) 124 Cal.App.4th 1184, requiring environmental impacts analyses to take into consideration the potential for a retail project as well as other cumulative retail projects to contribute to urban decay in the market area served by the project.

Prior to the advent of the Bakersfield court decision, Ms. Herman managed these studies for project developers or retailers, typically at the request of the host city, or sometimes for the city itself. Following the Bakersfield decision, the studies have most commonly been directly commissioned by the host cities or environmental planning firms conducting Environmental Impact Reports (EIRs) for the projects. Studies are often conducted as part of the EIR process, but also in response to organized challenges to a city’s project approval or to Court decisions ruling that additional analysis is required.

The types of high volume retail projects for which these studies have been conducted include single store developments, typically comprising a Walmart Store, The Home Depot, Target store, Costco, and other club-like retail stores. The studies have also been conducted for large retail shopping centers, typically anchored by one or more of the preceding stores, but also including as much as 300,000 to 400,000 square feet of additional retail space with smaller anchor stores and in-line tenants.

The scope of services for these studies includes numerous tasks. The basic tasks common to most studies include the following:

x defining the project and estimating sales for the first full year of operations; x identifying the market area;
x identifying and touring existing competitive market area retailers; x evaluating existing retail market conditions at competitive shopping centers and along major commercial corridors in the market area;
x conducting retail demand, sales attraction, and spending leakage analyses for the market area and other relevant areas;
x forecasting future retail demand in the market area;
x researching the retail market’s history in backfilling vacated retail spaces; x assessing the extent to which project sales will occur to the detriment of existing retailers (i.e., diverted sales);
x determining the likelihood existing competitive and nearby stores will close due to sales diversions attributable to the project;
x researching planned retail projects and assessing cumulative impacts; and

x identifying the likelihood the project’s economic impacts and cumulative project impacts will trigger or cause urban decay.

Many studies include yet additional tasks, such as assessing the project’s impact on downtown retailers; determining the extent to which development of the project corresponds with city public policy, redevelopment, and economic development goals; projecting the fiscal benefits relative to the host city’s General Plan; forecasting job impacts; analyzing wages relative to the existing retail base; and assessing potential impacts on local social service providers.

Representative Projects

Many high volume retail projects for which Ms. Herman has prepared economic impact and urban decay studies are listed below. These include projects that are operational, projects under construction, projects approved and beyond legal challenges but not yet under construction, and project currently engaged in the public process. By category, projects are listed alphabetically by the city in which they are located.

Projects Operational

x Alameda, Alameda Landing, totaling 285,000 square feet anchored by a Target (opened October 2013), rest of center opening starting in 2015
x American Canyon, Napa Junction Phases I and II, 239,958 square feet, anchored by a Walmart Superstore, prepared in response to a Court decision; project opened September 2007
x Bakersfield, Gosford Village Shopping Center, totaling 700,000 square feet, anchored by a Walmart Superstore, Sam’s Club, and Kohl’s; Walmart store opened March 18, 2010, Sam’s Club and Kohl’s built earlier
x Bakersfield, Panama Lane, Shopping Center, totaling 434,073 square feet, anchored by a Walmart Superstore and Lowe’s Home Improvement Warehouse; Walmart store opened October 2009, Lowe’s store built earlier
x Bakersfield, Silver Creek Plaza, anchored by a WinCo Foods, totaling 137,609 square feet, opened February 28, 2014
x Cameron Park (El Dorado County), Grocery Outlet Bargain Market, 16,061 square feet, opened November 2023
x Carlsbad, La Costa Town Square lifestyle center, totaling 377,899 square feet, anchored by Steinmart, Vons, Petco, and 24 Hour Fitness, opened Fall 2014 x Citrus Heights, Stock Ranch Walmart Discount Store with expanded grocery section, 154,918 square feet; store opened January 2007
x Clovis, Clovis-Herndon Shopping Center, totaling 525,410 square feet, anchored by a Walmart Superstore, opened March 2013
x Concord, Lowe’s Commercial Shopping Center, totaling 334,112 square feet, anchored by a Lowe’s Home Improvement Warehouse and a national general merchandise store; EIR Certified December 2008 with no subsequent legal challenge; store opened January 2010
x Concord, Veranda Shopping Center, a 375,000-square foot center anchored by a Whole Foods 365 Market, Movie Theater, and upscale apparel retail, opened October 2017, with 365 Market opening December 2017

x Cool, Dollar General, proposed store on a 1.69-acre site totaling 9,100 square feet, opened 2023
x Dublin, Persimmon Place, 167,200 square feet, anchored by Whole Foods, opened 2015 x Folsom, Lifetime Fitness Center, a 116,363-square-foot fitness center including an outdoor leisure and lap pool, two water slides, whirlpool, outdoor bistro, eight tennis courts, outdoor Child Activity Area, and outdoor seating, opened April 2017 x Fresno, Park Crossing (formerly Fresno 40), totaling 209,650 square feet, July 2015 x Gilroy, 220,000-square-foot Walmart Superstore , replaced an existing Discount Store; store opened October 2005, with Discount Store property under new ownership planned for retail redevelopment of a 1.5-million-square-foot mall x Gilroy, Lowe’s Home Improvement Warehouse, 166,000 square feet; store opened May 2003
x Hayward, Costco Gas Station, addition to existing Costco Business Center, opened mid- 2023
x Hesperia, Main Street Marketplace, totaling 465,000 square feet, anchored by a Walmart Superstore and a Home Depot, Walmart under construction, opened September 2012 x Madera, Commons at Madera, totaling 306,500 square feet, anchored by a Lowe’s Home Improvement Warehouse; project opened July 2008
x Oakland, Safeway expansion, College & Claremont Avenues, 51,510 square feet total, comprising a 36,787 square-foot expansion, opened January 2015 x Oakland, Rockridge Safeway expansion and shopping center redevelopment (The Ridge), including total net new development of 137,072 square feet, opened September 2016 x Oroville, Walmart Superstore, 213,400 square feet, replacing existing Walmart Discount Store, opened April 2017
x Rancho Cordova, Capital Village, totaling 273,811 square feet, anchored by a Lowe’s Home Improvement Warehouse; phased project opening, January 2008 – July 2008 x Sacramento, Delta Shores, 1.3- to 1.5-million square feet, anchored by a lifestyle center; phased project opening beginning September 2017
x Sacramento, Downtown Commons, mixed-use entertainment complex with 682,500 square feet of retail space adjoining new Golden 1 Center for the Sacramento Kings; initial tenant 2016, additional tenants beginning November 2017 x Sacramento, Land Park Commercial Center, proposed commercial center with a 55,000- square-foot relocated and expanded full service Raley’s grocery store and pharmacy and seven freestanding retail buildings comprising 53,980 square feet, Raley’s opened April 2020
x San Francisco, Chase Center, prepared response to comments regarding impacts on Oakland Arena, opened September 2019
x San Jose (East San Jose), Home Depot Store, 149,468 square feet; store opened October 2007
x San Jose, Lowe’s Home Improvement Warehouse (redevelopment of IBM site), up to 180,000 square feet, store opened March 2010
x San Jose, Almaden Ranch, up to 400,000 square feet, anchor tenant Bass Pro Shop opened October 2015
x Sonora, Lowe’s Home Improvement Warehouse, 111,196 square feet; store opened December 2010
x Sonora, Sonora Crossroads, Walmart Discount Store expansion to a Superstore, net increase of 30,000 square feet, groundbreaking May 2017

x Tracy, Tracy Hills Specific Plan, Specific Plan area including 5,499 residential units, 875,300 square feet of commercial retail space, 624,200 square feet of office space, and 4,197,300 square feet of industrial space
x Ukiah, Costco, 148,000-square-foot warehouse membership store, groundbreaking September 2017, opened July 2018
x Victorville, The Crossroads at 395, totaling 303,000 square feet, anchored by a Walmart Superstore, opened May 2014
x Victorville, Dunia Plaza, totaling 391,000 square feet, anchored by a Walmart Superstore and a Sam’s Club, replacing existing Walmart Discount Store, opened September 2012 x West Sacramento, Riverpoint Marketplace, totaling 788,517 square feet, anchored by a Walmart Superstore, Ikea, and Home Depot; phased openings beginning March 2006 x Willows, Walmart Superstore totaling 196,929 square feet, replacing existing Walmart Discount Store (subsequently scaled back to a 54,404-square-foot expansion to existing 86,453-square-foot store), opened March 2012
x Walnut Creek, The Orchards at Walnut Creek, mixed-use project including up to 225,000 square feet of retail space, opened September 2016
x Woodland, Home Depot Store, 127,000 square feet; store opened December 2002 x Yuba City, Walmart Superstore, 213,208 square feet, replacing existing Discount Store; store opened April 2006. Discount Store site backfilled by Lowe’s Home Improvement Warehouse

Projects in Progress/Engaged in the Public Process

x Folsom, Westland-Eagle Specific Plan Amendment, Folsom Ranch, a 643-acre portion of the larger 3,585-acre Folsom Ranch Master Plan area including 977,000 square feet of retail space, along with residential, office, and industrial space (update on status required) x Oakland, Oakland Waterfront District Park, prepared gentrification, displacement, and urban decay study for the proposed new Oakland A’s multi-purpose Major League Baseball ballpark at the Howard Terminal, totaling approximately 55 acres, with a capacity of up to 35,000 persons and additional land uses, including up to 3,000 residential units, 1.5 million square feet of office, a 400-room hotel, up to 270,000 square feet of mixed retail, cultural and civic uses, a 50,000-square-foot performance center, and parking for all Project uses
x San Francisco, Whole Foods, 49,825-square-foot store in the City Center shopping center x Seaside, Campus Town Specific Plan, a proposed 122.23-acre mixed-use development project developed on a portion of the former Fort Ord Army Base, planned to include maximum buildout of 1,485 housing units, a 250-room hotel, 75 youth hostel beds, 150,000 square feet of retail, dining, and entertainment space, and 50,000 square feet of office, flex, makerspace, and light industrial uses.

Projects Approved and Beyond Legal Challenges

x Bakersfield, Bakersfield Commons, totaling 1.2 million square feet of lifestyle retail space and 400,000 square feet of community shopping center space (project engaged in revisioning)
x Bakersfield, Crossroads Shopping Center, totaling 786,370 square feet, anchored by a Target

x Chico, Walmart expansion, expansion of an exis ting Walmart store plus addition of three development parcels including a fueling station, restaurant, and retail space. In Chico Advocates for a Responsible Economy v. City of Chico (2019) 40 Cal.App.5th 839, 849, Court of Appeal found that Urban Decay study adequately evaluated the Project’s urban decay impacts.
x Davis, Mace Ranch Innovation Center, an innovation center with 2,654,000 square feet of planned space, including research, office, R&D, manufacturing, ancillary retail, and hotel/conference center. FEIR completed January 2016 and Certified September 2017 x Fairfield, Green Valley Plaza, totaling 465,000 square feet x Fort Bragg, Grocery Outlet Bargain Market, approved June 2023 x Lincoln, Village 5 Specific Plan, area including 8,200 residential units, 3.1 million square feet of commercial retail space, 1.4 million square feet of office space, a 100-room hotel, and a 71-acre regional sports complex. Final EIR completed 2017. Specific Plan Approved January 2018. Groundbreaking anticipated 2019/2020. x Kern County, Rosedale and Renfro, totaling 228,966 square feet, anchored by a Target x Novato, Hanna Ranch, mixed-use project including 44,621 square feet of retail space, 21,190 square feet of office space, and a 116-room hotel x Pleasanton, Johnson Drive Economic Development Zone, including 189,037 square feet of new general retail space, 148,000 square feet of club retail space, and a 150- or 231- room hotel.
x Roseville, Hotel Conference Center, a 250-room hotel with a 20,000-square-foot conference facility and a 1,200-seat ballroom
x San Francisco, Candlestick Point, 635,000 square feet of regional retail and Hunters Point, with two, 125,000-square-foot neighborhood shopping centers (urban decay study not part of the legal challenge)

PRINCIPAL INTRODUCTION
Ms. Amy Herman , Principal of ALH Economics, has directed assignments for corporate, institutional, non-profit, and governmental clients in key service areas, including commercial market analysis, fiscal and economic impact analysis, economic development and redevelopment, location analysis, strategic planning, and policy analysis. During her career spanning over 30 years, Ms. Herman has supported client goals in many ways, such as to assess supportable real estate development, demonstrate public and other project benefits, to assess public policy implications, and to evaluate and maximize the value of real estate assets. In addition, her award-winning economic development work has been recognized by the American Planning Association, the California Redevelopment Association, and the League of California Cities.

Prior to forming ALH Economics, Ms. Herman worked for 20 years as an urban economist with Sedway Group and then CBRE Consulting’s Land Use and Economics practice. Her prior professional work experience included 5 years in the Real Estate Consulting Group of the now defunct accounting firm Laventhol & Horwath (L&H), preceded by several years with the real estate consulting firm Land Economics Group, which was acquired by L&H. During the course of her career, Ms. Herman has established a strong professional network and client base providing access to contacts and experts across a wide spectrum of real estate and urban development resources.

Ms. Herman holds a Master of Community Planning degree from the University of Cincinnati and a Bachelor of Arts degree in urban policy studies from Syracuse University. She pursued additional post-graduate studies in the Department of City and Regional Planning at the University of California at Berkeley. A professional resume for Ms. Herman follows.

ALH|ECON
ALH Urban & Regional Economics

PROFESSIONAL PROFILE

AMY L. HERMAN

PRINCIPAL
ALH Urban & Regional
Economics
Berkeley, California

T 510.704.1599
[email protected]

SELECT OTHER CLIENTS
– Alameda County Fair
– Arcadia Development
Company
– Catellus Development
Corporation
– CenterCal Properties
– Claremont University
Consortium
– City of Dublin
– Dudek
– Environmental Science
Associates
– Equity One
– First Carbon Solutions
(formerly Michael
Brandman Associates)
– Gresham Savage Nolan
& Tilden
– Howard Hughes
Corporation
– City of Inglewood
– LSA Associates
– Maximus Real Estate
Partners
– The Primary School
– Remy Moose Manley
– Ronald McDonald House
– Signature Flight Support
– Syufy Enterprises
– City of Tracy
Amy L. Herman, Principal of ALH Urban & Regional Economics, has provided urban and regional consulting services for approximately 40 years. During this time, she has been responsible for directing assignments for corporate, institutional, non-profit, and governmental clients in key service areas, including fiscal and economic impact analysis, economic development and redevelopment, feasibility analysis, location analysis, strategic planning, policy analysis, and transit-oriented development. Her award-winning economic development work has been recognized by the American Planning Association, the California Redevelopment Association, and the League of California Cities.

Prior to forming ALH Urban & Regional Economics in 2011, Ms. Herman’s professional tenure included 20 years with Sedway Group, inclusive of its acquisition by CB Richard Ellis and su b se q u en t n a m e c h a n g e t o C B R E C o n su l t i n g . H er prior professional work experience includes five years in the Real Estate Consulting Group of the now defunct accounting firm Laventhol & Horwath (L&H), preceded by several years with the land use consulting firm Land Economics Group, which was acquired by L&H.

Following are descriptions of select consulting assignments managed by Ms. Herman.

ECONOMIC IMPACT ANALYSIS
Alameda County. Prime consultant for a complex team that prepared a Local Development Business Plan for the newly launched East Bay Community Energy Community Choice Aggregation program for Alameda County. ALH Economics components included economic impact and financial analysis of the local development program components.

University of California. Conducted economic impact studies and frequent updates for five University of California campuses: Berkeley, Davis, Riverside, San Francisco, and San Diego.

Prepared models suitable for annual updates by campus personnel.

Hospital Council of Northe rn and Central California. Prepared an analysis highlighting the economic impacts of hospitals and long-term care facilities in Santa Clara County. The analysis included multiplier impacts for hospital spending, county employment, and wages. Completed a similar study for the Monterey Bay Area Region.

Bay Area Rapid Transit District. Completed economic impact analysis of BART’s operations in the San Francisco Bay Area region.

Various EIR Firms. Managed numerous assignments analyzing the potential for urban decay to result from development of major big box stores, shopping centers, and sports venues. The analysis comprises a required Environmental Impact Report component pursuant to CEQA.

FISCAL IMPACT ANALYSIS
Stanford Research Park. Analyzed historic and current fiscal contributions generated by the S t a n f o r d R e s e a r c h P a r k r e a l e s t a t e b a s e a n d b u s i n e s s e s t o t h e C i t y o f P a l o A l t o , S a n t a C l a r a County, and the Palo Alto Unified School District.

City of Concord. Structured and managed fiscal impact analysis designed to test the net fiscal impact of multiple land use alternatives pertaining to the reuse of the 5,170-acre former Concord Naval Weapons Station, leading to possible annexation into the City of Concord, California.

Kimco Realty. Prepared fiscal impact analysis of pl ans to renovate and redevelop part of Westlake Shopping Center and infill development of a 179-unit apartment project adjoining the shopping center.

Sycamore Real Estate Investments, LLC. Prepared a fiscal impact model for client implementation, to test the General Fund net fiscal impacts of alternative land use mixes.

Residential and Commercial Developers. Prepared fiscal impact studies for new development projects, including residential, office, and mixed-use projects, demonstrating the net fiscal impact on the respective city’s General Fund and local school districts.

ALH|ECON
ALH Urban & Regional Economics

PROFESSIONAL PROFILE

AMY L. HERMAN
Principal ECONOMIC DEVELOPMENT AND PUBLIC FINANCE
Infrastructure Management Group. Contributed to due diligence analysis of the proposed Transbay Transit Center to support evaluation of requested bond loan adjustment requests to support project construction.

Alameda County. Managed numerous assignments helping Alameda County achieve its economic development goals for the County’s unincorporated areas through surplus site disposition assistance, including market analysis and financial due diligence for residential and commercial mixed-use developments.

Office of Community Investment and Infrastructure as Successor Agency to the Redevelopment Agency of the City and County of San Francisco. Managed financial analysis estimating the tax payments in lieu of property taxes associated with UCSF development of medical office space in the former Mission Bay Redevelopment Project area.

LAND USE POLICY
Union City Property Owner. Provided an independent analysis regarding the reasonableness of the City of Union City continuing to reserve a key development area for office and/or R&D development in the context of the General Plan Update.

Alameda County Community Development Agency. Provided analysis and input regarding the Ashland and Cherryland Business District Specific Plan requirements for non-residential floor space in mixed-use development sites over 10,000 square feet DCT Industrial Trust (Subsequently acquired by ProLogis, Inc.). Performed economic analysis on a proposed change to the Newark Zoning Ordinance regarding permitted industrial uses. The analysis demonstrated the market, fiscal, and economic impacts that could result from the proposed zoning ordinance change.

City and County of San Francisco . Under direction of the San Francisco Planning Department, conducted analysis and literature review regarding residential and commercial displacement, especially they pertained to two planned Mission District mixed-income apartment projects.

DEVELOPMENT FEASIBILITY
China Harbour Engineering Company Ltd. (CHEC). Prepared a market assessment and development feasibility analysis for the potential development of a 5.54-acre parking lot at the West Oakland BART Station in Oakland, CA for CHEC, the development entity selected by BART to pursue joint development of the site pursuant to an Exclusive Right to Negotiate Agreement.

Align Real Estate, LLC. Prepared independent economic analysis of a proposed residential development in San Francisco on the site of several buildings, including one considered an historic resource pursuant to CEQA. The analysis tested several project alternatives, focusing on net developer margin as an indicator of financial feasibility.

Build, Inc. Conducted financial analysis comparing the development of a prospective San Francisco residential site as a “stand-alone” project compared to a larger “combined lot” project that would incorporate unused floor-area-ratio from an adjacent property.

Various Residential Developers. In support of fiscal impact studies, prepared residential market analysis examining historical development and pricing trends, absorption, and forecasting demand by product type. Prepared achievable pricing estimates by residential unit type and size.

EDUCATION
ƒ Bachelor of Arts degree in urban studies, magna cum laude, Syracuse University. ƒ Master of Community Planning degree from the University of Cincinnati. ƒ Advanced graduate studies in City and Regional Planning at the University of California at Berkeley.

Appendix B
Netting Report
 

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Ascent Environmental
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Sacramento, CA 95814
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