Cities Index.
9:25 AM ID 24-487 Additional supplement

Fresno City Council
April 18, 2024

Document
9:25 AM ID 24-487 Additional supplement
Meeting
April 18, 2024
Body
Fresno City Council
Pages
6
Original file
2.9 MB
Text extracted from the city's file for reading and search. Open the original on legistar2.granicus.com. That file is the official record.

Memo
455 Capitol Mall, Suite 300
Sacramento, CA 95814
916.444.7301

Date: April 8, 2024
To: Steven Martinez, City of Fresno
From: Jessica Babcock and Mike Parker, Ascent
Subject: Costco Commercial Center: Responses to Comments Received after Publication of the Final Environmental Impact Report

Costco has proposed a new commercial center that would replace the existing Shaw Avenue Costco warehouse location. The project would be located on an approximately 22-acre parcel located at the northeast corner of the intersection of West Herndon Avenue and North Riverside Drive in the C ity 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. The development would include a warehouse building, gas station, and car wash.

The City has prepared an environmental impact report (EIR) to evaluate the potential effects of project implementation. The Draft EIR was released for public review on July 11, 2023. The City received 107 unique comment submittals during the public review period for the Draft EIR, which concluded on A ugust 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 and the Final EIR was published in January 2024.

The City of Fresno has received 13 public comments related to the proposed Costco Commercial Center since publication of the Final EIR. This memo briefly summarizes the comments received and provides responses to address the concerns raised therein.

Andres Jauregui, California State University, Fresno
March 12, 2024
The comment requests data about the processing of Costco’s development application to inform research into the effects that a separate Costco location in the City of Clovis had on commercial real estate prices in the area. The comment does not address the content, analysis, or conclusions in the EIR. N o response is required on this issue pursuant to CEQA Guidelines Section 15088(a).

Autumn Simpson, Holiday Inn Express
March 6, 2024
The comment is a voicemail from the Holiday Express Inn regarding a proposition to serve as the “preferred hotel” for individuals that are temporarily in town due to work on the project. The comment does not address the content, Costco Commercial Center
Comment Response Memo
April 8, 2024

Page 2 ends

analysis, or conclusions in the EIR. No response is required on this issue pursuant to CEQA Guidelines Section 15088(a).

Cathy Caples
March 6, 2024
The comment expresses support for the project and suggests that nighttime truck traffic should access the site via North Arthur Avenue. 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. Refer to Response I5-1 in the Final EIR for further discussion.

Darrel Vincent
March 12, 2024
The comment expresses opposition to the project and concerns related to traffic 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. Refer to Responses I4-1 and I5-1 in the Final EIR for further discussion.

Renee Nealy
March 8, 2024
The comment expresses opposition to the project and concerns related to traffic congestion, including potential conflicts with existing bus stops and children walking to school. 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. Refer to Responses I4-1 and I5-1 in the Final EIR for further discussion. Note that the Central Unified School District has been consulted 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 correlates the four significant and unavoidable impacts identified in the EIR to safety concerns in the immediate neighborhood. The EIR identified significant and unavoidable impacts related to noise from construction because limited work could occur at night (Impact 3.11-1), vehicle miles traveled (VMT) because there would be a net increase in the amount people drive (Impact 3.13-2), safety hazards at the intersection of North Golden State Boulevard and West Herndon Avenue (1/3-mile southwest of the project site) due to a projected volume of traffic that exceeds the turn pockets (Impact 3.13-3), and due to the cumulative increase in VMT (Impact 4-13).

The comment suggests that the proposed Costco Commercial Center would increase the potential for unhoused individuals and thieves in the surrounding neighborhood and requests consideration of alternative sites in the El Paseo Marketplace. As discussed further in the Final EIR (see Response I4-1), CEQA does not include provisions for consideration of unhoused populations separate and distinct from the analysis of a project’s impacts on the environment. In accordance with State CEQA Guidelines Section 15126.6(a), the Draft EIR evaluates a range of Costco Commercial Center
Comment Response Memo
April 8, 2024

Page 3 ends

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. 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.

James Fleck
March 7, 2024
The comment expresses opposition to the project and concerns related to traffic congestion, noise, pollution, and lights. 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. In the Final EIR, 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 of the proposed project’s impacts related to noise and lighting.

Joseph Lee
March 23, 2024
The comment asks when the project will be constructed. The comment does not address the content, analysis, or conclusions in the EIR. No response is required on this issue pursuant to CEQA Guidelines Section 15088(a).

Loretta Hanson
March 9, 2024
The comment expresses opposition to the project and concerns related to traffic congestion, including potential conflicts with existing bus stops and children walking to school. 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. Refer to Response I4 -1 in the Final EIR for further discussion.

The comment suggests an alternate location near existing shopping centers and closer to SR 99. 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. 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.

Costco Commercial Center
Comment Response Memo
April 8, 2024

Page 4 ends

Patricia Yaralian
March 6, 2024 (three emails) and March 7, 2024
The comment expresses opposition to the project and concerns related to traffic congestion, including potential conflicts with children walking to school. 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. Refer to Response I4-1 in the Final EIR for further discussion.

The comment also raises the potential inconveniences of construction and the potential to affect community character. The effects of construction are described throughout Chapter 3, “Environmental Impacts and Mitigation Measures,” of the Draft EIR. The proposed project’s potential to affect the existing visual character of the area is evaluated in Draft EIR Section 3.1, “Aesthetics” (Impact 3.1-1).

Sandra Velasquez
March 7, 2024 (voicemail and email)
The comment expresses opposition to the project and concerns related to traffic congestion and safety, including potential conflicts with existing bus stops and children walking to school. 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. Refer to Responses I4-1 and I5-1 in the Final EIR for further discussion.

Sehaj Sabharwal
March 28, 2024
This comment expressed interest in partnering with Costco to open a smog/mechanic shop. 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 does not address the content, analysis, or conclusions in the EIR. N o response is required on this issue pursuant to CEQA Guidelines Section 15088(a).

Xavier Flores
February 27, 2024
The comment expresses concerns related to the completion of West Spruce Avenue north of the project site and traffic generated by the proposed project. 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. Refer to Response I15-1 in the Final EIR for information about the extension of Spruce Avenue adjacent to the northern boundary of the project site and anticipated effects on traffic patterns and Responses I4-1 and I5-1 in the Final EIR for further discussion of traffic and transportation effects in general.

Costco Commercial Center
Comment Response Memo
April 8, 2024

Page 5 ends

Daniel Brannick
March 6, 2024
The comment expresses concerns related to land use, the relationship between greenhouse gas (GHG) emissions and transportation, and alternatives. The comment refers to previously submitted comments, which are addressed in the Final EIR (pages 2-160 through 2-175) and reiterates support for an alternate project location on Veterans Boulevard.

The comment provides an opinion that the GHG emissions impacts should be identified as significant and unavoidable in the EIR due to generation of VMT. The Draft EIR and Appendix F (the Greenhouse Gas Technical Report) fully evaluate and assess the potential for GHG impacts and, as part of that analysis, fully address the concern raised in the comment. Regarding the interplay between VMT and GHG, a significant VMT impact does not automatically equate to a significant GHG impact for multiple reasons. First, these are two distinct criteria to be specifically analyzed in two different EIR discussions (i.e., transportation and GHG); the VMT criteria was not intended, nor is it required, to be applied as suggested by the commenter. Second, while the City acknowledges that VMT is a variable and assumption used in the GHG analysis, the assessment of GHG includes an evaluation that considers emission factors based on the vehicle type and fuel type to arrive at an understanding of the GHG emissions. The GHG analysis in the Draft EIR properly discloses and acknowledges the VMT impact from the transportation section, and then analyzes the Project’s GHG impact appropriately in the context of GHG emissions. Thus, the evaluation provided in the EIR is valid and recirculation of the Draft EIR is not required , pursuant to State CEQA Guidelines Section 15088.5.

The comment reiterates an opinion that the proposed MDO element of the Costco warehouse is inconsistent with the proposed zoning. As explained in Response I30-2 in the Final EIR, the City has determined that the MDO falls within the accessory use classification. As an accessory use to the retail warehouse, the MDO is allowable in the General Commercial designation.

The comment suggests that a transportation queuing analysis should be prepared for an offsite alternative to understand if significant and unavoidable queuing impacts could be avoided by relocating the proposed development. EIRs are required to describe and evaluate a range of reasonable alternatives to the proposed project that would feasibly attain most of the basic objectives of the project and would avoid or substantially lessen the significant effects of the project, and to evaluate the comparative merits of the alternatives (State CEQA Guidelines 15126.6[a]). The evaluation, analysis, and comparison with the proposed project that is provided in the EIR is conducted at a lesser level of detail than the evaluation for the project (State CEQA Guidelines 15126.6[d]).

Preparation of transportation studies that include offsite intersection queuing analyses is outside the scope of a typical evaluation of alternatives. However, it can be reasonably surmised that any alternative location that is West of Golden State Boulevard and would be primarily accessed via SR 99 and Herndon Avenue could contribute to similar queuing effects at the North Golden State Boulevard/West Herndon Avenue intersection. There is also no evidence in the record that this location would reduce the potential for nighttime construction noise or generation of VMT. As explained in the Draft EIR, alternative project sites near Riverside Drive and Veterans Boulevard would also be near existing residences. Further, an EIR is not required to consider alternatives that are infeasible (State CEQA Guidelines 15126.6[a]). As explained in detail in Response I30-8 in the Final EIR, the alternative sites identified by the commenter were dismissed from detailed evaluation due to infeasibility. Thus, the evaluation provided in the EIR is valid and recirculation of the Draft EIR is not required, pursuant to State CEQA Guidelines Section 15088.5.

With respect the scope of the transportation analysis conducted for the proposed project , the Transportation Impact Analysis (Appendix D to the Draft EIR) explains that future (2042) conditions were projected using the travel model developed by the Fresno Council of Governments. The transportation modeling for the cumulative scenario considers Costco Commercial Center
Comment Response Memo
April 8, 2024

Page 6 ends

regional volumes. Individual uses within shopping centers are not specifically modeled, but the traffic generation projections from the center overall would be captured in the model. The commenter’s support for a mitigation measure that would prohibit development of the Costco Commercial Center Project until the California High Speed Rail Authority completes grade separation at West Herndon Avenue is noted. The Merced to Fresno portion of the California Highspeed Rail has been in development for a long time. The Final EIR for the project, which included this grade separation, was certified in May 2012. Continued construction is dependent on many factors, including on - going state funding. As explained further in Response I103-8 in the Final EIR, the City can only require mitigation that is feasible, which is defined as capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors (PRC 210610.1). The determination of feasibility and appropriateness is made in consideration of multiple factors, including the relative time for completion and the lead agencies authority over the project that would serve as mitigation. Therefore, although the City can reasonably expect that the significant and unavoidable queuing impact at the North Golden State Boulevard/West Herndon Avenue intersection may be eliminated in the future due to planned roadway improvements, the City does not believe this is a feasible mitigation requirement for the project at hand.

From: Jose Valenzuela
To: Andres Jauregui
Cc: Steven Martinez
Subject: RE: Research on Costco"s relocation impact
Date: Wednesday, March 13, 2024 8:17:49 AM
Dr. Jauregui,

I have transferred out of the Planning and Development Dept. I am looping in Steven Martinez the current planner on the project. Please work with him moving forward.

Best,

Jose Valenzuela
Project Manager – Utilities and On-Site Project Management Capital Projects Department
747 “R” Street, 2
nd Floor
Fresno, CA 93721
Main Office: (559) 621-8880
Direct Line: (559) 621-8830
www.fresno.gov
Building a Better Fresno

From: Andres Jauregui
Sent: Tuesday, March 12, 2024 10:19 PM
To: Jose Valenzuela <[email protected]>
Subject: Research on Costco's relocation impact

External Email: Use caution with links and attachments

Hello Jose! This is AJ, real estate professor and Director of the Gazarian Real Estate Center at Fresno State. I hope this email finds you well!

I'm currently doing research on the impact of Costco's
relocation in Clovis back in 2019. I'm looking at how the relocation impacted commercial
land prices. I am presenting
the preliminary research results at the American Real Estate

Society's annual conference in Orlando in two weeks. I have been working with Andrew Haussler from the City of Clovis to recreate the timeline of events.

I wanted to incorporate into the analysis the news about the relocation of the West Shaw Costco location in Fresno. I was wondering if you could provide me with a timeline of events, please? Of course, the location
is not yet open, but I would
assume that real estate prices have been already impacted by the news.

So far, I know that there was a notice of preparation of an EIR in October 2021, which was completed in July 2023. Is it possible to know when the Conditional Use Permit was
submitted? I also believe the Planning Commission has already approved the CUP, but the City County is delaying voting on it.

I hope you can help me. This will definitely enrich the analysis and give us more accurate results. Please feel free to call my cell 334-332-9683 if you'd like to discuss this further.

I hope to hear from you soon.

Best regards,

AJ

Andres Jauregui, Ph.D.

Professor of Real Estate and Director
Gazarian Real Estate Center
Department of Finance, Real Estate, and Business Law
Craig School of Business
California State University, Fresno

From: Erik Young
To: Steven Martinez
Subject: FW: City of Fresno VM: Voice msg from DAY MAIN MENU 5592770004.

Date: Wednesday, March 6, 2024 9:52:11 AM
Attachments: f2c1df20-4d75-4d61-ab31-02826e2e5955.WAV
Hey Steven,
I received the attached voicemail this morning pertaining to your Costco. Do you mind following up with Autumn when you have a chance?
Erik Young | Supervising Planner
Current Planning | Planning & Development
2600 Fresno Street | Fresno CA 93721
559.621.8009
[email protected]
Resources:

Planning & Development | GIS Data Hub – Interactive Zoning Map | Fresno Municipal Code Accela Citizens Access (ACA) Online Plans/Permits/Inspections | ACA Instruction Videos -----Original Message-----
From: [email protected] <[email protected]>
Sent: Wednesday, March 6, 2024 8:59 AM
To: Erik Young <[email protected]>
Subject: City of Fresno VM: Voice msg from DAY MAIN MENU 5592770004.

Please call (559) 621-7200 to listen to your messages over the telephone.

From: PublicCommentsPlanning
To: Steven Martinez
Cc: Phillip Siegrist
Subject: FW: Agenda item 24-245 new Costco
Date: Wednesday, March 6, 2024 4:22:49 PM
FYI
Rob Holt | Supervising Planner
Current Planning | Planning & Development
2600 Fresno Street | Fresno CA 93721
559.621.8056
[email protected]
Resources:

Planning & Development | GIS Data Hub | Citywide Development Code Accela Citizens Access (ACA) | ACA “How To” Videos
-----Original Message-----
From: Cathy Caples
Sent: Wednesday, March 06, 2024 4:12 PM
To: PublicCommentsPlanning <[email protected]> Subject: Agenda item 24-245 new Costco
External Email: Use caution with links and attachments
This letter is in support of building a new Costco on Herndon across from El Paseo. This mixed use area of NW Fresno was planned before houses were built across the street. I’m sorry the builder did not inform buyers that there would be retail across the street. With 40% of Fresno’s population members of Costco, it’s only fair to build Costco is all sectors of Fresno so that every member has access to all products.

With easy access from new Veteran’s Blvd,
this Costco will serve the entire west side until Costco decides to build another store in Southeast or West. I do believe to support the residents, truck traffic should not have during sleeping hours unless there is an entrance for the trucks from Herndon on the Derek’s Mini Storage side of the building. But minor changes shouldn’t prevent building.

Thank you
Cathy Caples

Sent from my iPhone

From: Darrell Vincent
To: PublicCommentsPlanning; PublicCommentsPlanning
Cc: Steven Martinez
Subject: Oppose the new Costco
Date: Tuesday, March 12, 2024 11:59:00 AM
External Email: Use caution with links and attachments
Hello City Councilman Mike Karbassi,
I am sending you this message to strongly urge you to oppose the new build of Costco in Northwest Fresno.

Marketplace at El Paseo is an already busy area with somewhat manageable traffic. If a Costco is built there this will create a huge traffic congestion. People who live in the surrounding areas, myself included, do not want to detour or sit in traffic just to get home after a long day of work. I am sure that a lot of the people in these neighborhoods would agree.

Why does Fresno want to build another Costco in North Fresno when there are already two (Shaw and Abby)? Costco should be built in a commercial area in South Fresno where it could be more accessible to the rest of the community and away from residences in an already busy area.

Thank you for your time.

Respectfully,
Darrell Vincent

From: Alyssa Stevens
To: Steven Martinez
Subject: FW: Northwest Costco
Date: Friday, March 8, 2024 1:27:51 PM
Attachments: image001.png
Hi Steven:

We received this e-mail, I just wanted to forward this so it is included in the public record for the project.

Thank you so much!! Our office super appreciates your work on this item!!

Alyssa Stevens
Chief of Staff
Council Vice President Mike Karbassi
559-621-8000

From: Renee Nealy
Sent: Friday, March 8, 2024 1:22 PM
To: Mike Karbassi
Cc: Nelson Esparza >; Annalisa Perea
Tyler Maxwell ; Luis Chavez >; Garry Bredefeld
Subject: Northwest Costco

External Email: Use caution with links and attachments

We live in the neighborhood where the proposed Costco is being considered to be built and have lived in our neighborhood for 18 years.

We are vehemently opposed to having a Costco literally in the middle of our neighborhood!! The proposed new Costco will be across the street from an elementary school and middle school. In the mornings and in the afternoon there are several kids waiting for the school bus and there are many school buses along the streets picking up kids for school and dropping them off after school.

The amount of traffic and
congestion that this Costco will bring to our neighborhood will be

unprecedented! It is already congested with school buses and traffic with people traveling to work. The Environmental Impact Report cited four unavoidable impacts, which include an increase in construction noise and the most important of overall transportation impacts. It will not be safe for the children living in our neighborhood traveling to and from school; they have to walk to the bus stops in the morning and walk home from the bus stops in the afternoon.

It is not safe for our children due to the
increase in traffic this Costco will cause!

The neighborhood is quiet and safe; having the Costco at the proposed site will bring unwanted homeless people and thieves wandering into our neighborhood.

Why can't the Costco be built on one of the many empty fields near the Marketplace at El Paseo on Riverside Drive; that seems more like an optimal location near the shopping center instead of in the middle of a neighborhood.

Please reconsider moving the Costco to a more industrial or commercial area, not in a neighborhood!!

From: Planning
To: Steven Martinez
Cc: PublicCommentsPlanning
Subject: FW: Costco in NW Fresno Disapproval
Date: Thursday, March 7, 2024 1:48:13 PM

Pam Mariano | Administrative Clerk II
Planning & Development Department
2600 Fresno Street | Fresno CA 93721
559.621.8487
[email protected]

Resources: Planning & Development | GIS Data Hub | Citywide Development Code Accela Citizens Access (ACA) | ACA “How To” Videos

From: James Fleck
Sent: Thursday, March 7, 2024 12:59 PM
To: Planning <[email protected]>
Subject: Costco in NW Fresno Disapproval

External Email: Use caution with links and attachments

I'm writing this to inform the council of my disappruoval of the Costco project in NW fresno for many reasons.

First, the huge increase in traffic in the area, which is allready congested most of the day because of the new strip mall in the same location. The access to the homes that now exist across the street will be comprimised,
along with the constant noise,pollution,and lights that will degrade the environment even more. What about access to the Golf Course? The increase in noise,pollution,lights and traffic congestion to name a few of my concerns is why I disapprove of "The worlds Largest CostCo" be located at the proposed sight.

Life long resident of NW Fresno, Thank You, James Fleck

From: Joseph Lee
To: Jose Valenzuela
Subject: largest Costco built
Date: Saturday, March 23, 2024 2:14:13 PM
External Email: Use caution with links and attachments
When is the largest size Costco being built in the city of Fresno? - Joseph Lee
From: Loretta Hanson
To: PublicCommentsPlanning
Cc: Steven Martinez
Subject: Costco
Date: Saturday, March 9, 2024 11:59:36 AM
External Email: Use caution with links and attachments
Please vote against the Costco moving to Herndon and Riverside Drive. It will create such a mess in our neighborhood!! It is too close to homes and the traffic will be out of control. Seems like properties farther south on Riverside Drive next to the shopping center and Highway 99 would be much more accessible and appropriate Loretta Hanson
Sent from my iPhone
From: Jose Valenzuela
To: Steven Martinez
Cc: Phillip Siegrist
Subject: FW: Costco Proposal Thursday Meeting
Date: Wednesday, March 6, 2024 8:13:50 AM
FYI.

Jose Valenzuela
Project Manager – Utilities and On-Site Project Management Capital Projects Department
747 “R” Street, 2
nd Floor
Fresno, CA 93721
Main Office: (559) 621-8880
Direct Line: (559) 621-8830
www.fresno.gov
Building a Better Fresno

From: Patricia Yaralian
Sent: Wednesday, March 6, 2024 2:05 AM
To: Jose Valenzuela <[email protected]>
Subject: Costco Proposal Thursday Meeting

External Email: Use caution with links and attachments

Greetings Mr. Valenzuela,

I just have the hardest time understanding the mentality of Fresno's leadership as I once again am writing
to voice my disapproval of the proposed location of a new Cosco site on Herndon and 99.

Traffic congestion and safety of the local school children are my main concerns. I drive eastbound to work on Herndon and I assure you that the traffic is already chaotic. I'm sad for the people that live in the area and the fact Fresno planners think a new Costco will be a healthy addition to the area.

Gas stations, 24/7 truck deliveries, and people migration from nearby towns to shop is not a nice thing to FORCE on residents and commuters in that area.

There is a very busy train track to contend
with also. The freight trains are long and slow along Golden State Boulevard. Traffic backup is comparable to the starting line of a drag race. It's madness...come on. REALLY?

Mental health of Fresno residents should be a top priority. This proposed Costco site and the years of development disruption doesn't support a healthy environment. We have had to endure High

Speed Rail, Veterans Boulevard and El Paseo Shopping Center construction. We have lost our hometown feel. No one belongs anymore. I mourn.

Please share my concerns against this plan at Thursday's meeting. And please feel free to contact me IF my voice will matter. That's a BIG "IF".

Thank you.

Regretfully,

Pat Yaralian

From: Jose Valenzuela
To: Steven Martinez
Cc: Phillip Siegrist
Subject: FW: Costco proposal Thursday Meeting
Date: Wednesday, March 6, 2024 8:13:30 AM
FYI.

Jose Valenzuela
Project Manager – Utilities and On-Site Project Management Capital Projects Department
747 “R” Street, 2
nd Floor
Fresno, CA 93721
Main Office: (559) 621-8880
Direct Line: (559) 621-8830
www.fresno.gov
Building a Better Fresno

From: Patricia Yaralian
Sent: Wednesday, March 6, 2024 12:44 AM
To: Jose Valenzuela <[email protected]>
Subject: Costco proposal Thursday Meeting

External Email: Use caution with links and attachments

R

Yahoo Mail: Search, Organize, Conquer

From: Patricia Yaralian
To: Steven Martinez
Cc: Phillip Siegrist
Subject: Costco Plan Herndon/99
Date: Wednesday, March 6, 2024 3:01:11 PM
External Email: Use caution with links and attachments
Good Afternoon Gentlemen,
Please check your email from prior plan manager Jose Valenzuela to read my disapproval (2) emails of planned Costco sight. Due to lack of my knowledge, I was unaware you are the new contacts.

I worked hard writing my concerns in regards to this project. Please take the time to read them and to fairly present them at the meeting tomorrow night.

Feel free to contact me if you have any questions or concerns.

Thank you.

Patricia Yaralian

From: Patricia Yaralian
To: Steven Martinez
Subject: RE: Costco Plan Herndon/99
Date: Thursday, March 7, 2024 3:17:20 PM
External Email: Use caution with links and attachments
I just was informed the project has been temporarily put on hold. I can't express my relief enough. It just might help renew my faith in Fresno leadership. Thank you for sharing my concerns. It means alot because we were listened to and heard. Patricia Yahoo Mail: Search, Organize, Conquer
On Thu, Mar 7, 2024 at 2:57 PM, Steven Martinez
<[email protected]> wrote:

Greetings,

Thank you for the submission of your comment. The comment has been added to the administrative record for review.

Thank You.

Steven Martinez | Planner
Current Planning | Planning & Development
2600 Fresno Street | Fresno CA 93721
559.621.8047
[email protected]

From: Patricia Yaralian

Sent: Wednesday, March 6, 2024 3:01 PM
To: Steven Martinez <[email protected]>
Cc: Phillip Siegrist <[email protected]>
Subject: Costco Plan Herndon/99

External Email: Use caution with links and attachments

Good Afternoon Gentlemen,

Please check your email from prior plan manager Jose Valenzuela to read my disapproval (2) emails of planned Costco sight. Due to lack of my knowledge, I was unaware you are the new contacts.

I worked hard writing my concerns in regards to this project. Please take the time to read them and to fairly present them at the meeting tomorrow night.

Feel free to contact me if you have any questions or concerns.

Thank you.

Patricia Yaralian

From: Steven Martinez
To:

Cc: PublicCommentsPlanning
Subject: RE: Planning and development of proposed new NEW Fresno Costco Date: Thursday, March 7, 2024 5:20:51 PM
Attachments: 78153da7-1fa4-43f0-97d1-f21b6395d7af.WAV
Greetings,

Thank you for the submission of your comments. The comments has been added to the administrative record for review.

In Public Service,
Steven Martinez | Planner
Current Planning | Planning & Development
2600 Fresno Street | Fresno CA 93721
559.621.8047
[email protected]

From: Sandra Velazquez
Sent: Thursday, March 7, 2024 4:20 PM
To: OCC Customer Service
new NEW Fresno Costco

External Email: Use caution with links and attachments

First Name Sandra
Last Name Velazquez
Email
Phone
Number
Subject Planning and development of proposed new NEW Fresno Costco Message Hi
I live in the neighborhood of the proposed Costco and am very concerned About it being built. As it is I already feel it’s very congested with the new veterans blvd abd shopping center, I’ve lived in the area for 22 years and I miss the quiet

neighborhood I once had. Please don’t let it be built im against it IP Address 107.77.213.56
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Referrer https://www.fresno.gov/contact/
From: Jose Valenzuela
To: Steven Martinez
Subject: FW: Smog shop @ Costco
Date: Thursday, March 28, 2024 11:15:41 AM
Steven,

For your reference.

Thank you,

Jose Valenzuela
Project Manager – Utilities and On-Site Project Management Capital Projects Department
747 “R” Street, 2
nd Floor
Fresno, CA 93721
Main Office: (559) 621-8880
Direct Line: (559) 621-8830
www.fresno.gov
Building a Better Fresno

From: Sehaj Sabharwal
Sent: Thursday, March 28, 2024 10:59 AM
To: Jose Valenzuela <[email protected]>
Subject: Smog shop @ Costco

External Email: Use caution with links and attachments

Hi Jose,

We are interested to collaborate with you in opening a Smog shop/machanic shop in the New comming Costco site.

You are going to have a Carwash, Tire shop the only thing you are missing is a Smog/machanic shop.

It would also help in bringing more people and we would give every customer a 5 star customer experience.

My Uncle has its own workshop from the past 20+ years . With that experience and customer satisfaction sky I'd the limit

We can put more downpayment to.

Please let me know.

Appreciate
Sage
From: Steven Martinez
To: Xavier Flores; PublicCommentsPlanning
Subject: RE: costco on herndon
Date: Tuesday, February 27, 2024 1:40:04 PM
Greetings.

Thank you for the submission of your comment. It will be added to the administrative record for review.

As far as Spruce Avenue:

Currently Spruce terminates at two intersections: Spruce Avenue and Riverside Drive; Spruce Avenue and Strother Avenue. Spruce does not have a segment across the project site. The applicant (Costco) will extend and enhance West Spruce Avenue from North Riverside Drive to the intersection with North Sandrini Avenue. The connection will be consistent with the City of Fresno Active Transportation Plan. The asphalt roadway will include curb, gutter, sidewalk, Class II bicycle facilities, and streetlights.

Thank You.

Steven Martinez | Planner
Current Planning | Planning & Development
2600 Fresno Street | Fresno CA 93721
559.621.8047
[email protected]

From: Xavier Flores
Sent: Tuesday, February 27, 2024 1:33 PM
To: PublicCommentsPlanning <[email protected]> Cc: Steven Martinez <[email protected]>
Subject: costco on herndon

External Email: Use caution with links and attachments

Hello , I've been a resident off of Spruce and Hayes since 1993 and after looking at the map and roads going in and out of that Costco its a big concern if you open that dead end at Spruce.

That's if I am reading it right !
The amount of folks and kids on Spruce everyday along with the elderly that are on there power chairs, the traffic from Costco is gonna destroy our neighborhood , School buses also

picking up and dropping off kids on Spruce is another issue.

I am all in for New Business in Fresno but not at the expense of losing our peaceful setting, that neighborhood has been a Great place to live and raise a family.

Hoping for the best for us all ,
Xavier Flores

1 Steven Mar�nez, Planner
City of Fresno
2600 Fresno Street, Third Floor, Room 3043
Fresno, CA 93721

Subject: Costco Commercial Center Project (CEQA State Clearinghouse # 2021100443) Response to Final EIR Informa�on and Comments

Dear Mr. Mar�nez,
Presented in this leter are comments addressing the Response to Comments and other informa�on provided as part of the Final EIR for the proposed Costco Commercial Center Project. The comments are organized into essen�ally the same three topic areas from my DEIR comment leter, which are:
1) Comments regarding inconsistency between the operational characteristics identified in the proposed project description and the uses allowed by the proposed General Plan Amendment and Rezone.
2) Comments addressing issues and deficiencies in the analysis of specific categories of environmental effects (For this letter, the comments are particularly focused on Greenhouse Gas Emissions and Transportation impacts).
3) Comments on the adequacy of the Draft EIR’s Alternatives analysis.

I appreciate that at least some informa�on was provided in the Final EIR which helped provide clarity on the content and analysis from the DEIR. However, as I stated during my public comments in opposi�on to the proposed project at its Planning Commission hearing, “Responses are not always answers.” The zoning consistency issue has not been resolved, and inadequacies in the environmental analysis persist.

Some of these issues and inadequacies pertain to environmental planning and CEQA topics that are par�cularly technical in nature, while others involve issues that are plainly recognized – such as those related to the transporta�on and safety concerns expressed in numerous DEIR comments.

The comments presented in this leter are primarily intended to refer back to issues that have already been raised where addi�onal discussion is appropriate, but a por�on of the comments also address informa�on that was discovered months a�er the DEIR review and comment period was completed. I men�on this because I do not want these comments to be characterized as a “last-minute document dump” (and I should note I have been on the other side of that situa�on).

I want to reiterate that I am generally in favor of the development of a new Costco in northwest Fresno, but I have major reserva�ons with the proposed project site loca�on due to adverse environmental impacts that are specifically atributable to the site. I sincerely believe that developing the proposed Costco project at a nearby alterna�ve site such as at Veterans Boulevard would have an equal or superior overall outcome for the City, its residents, and Costco itself. Every benefit sought by the proposed reloca�on of the west Shaw Costco would be either fully or substan�ally realized. At the same �me, a number of significant nega�ve externali�es to surrounding residents would be avoided (such as noise and traffic safety issues in neighborhoods), and being located at a major roadway that is already grade- separated will reduce or avoid transporta�on safety issues as well as opera�onal challenges that are 2 likely to arise (both in the near-team while Herndon is not grade-separated and in the intermediate period when Herndon undergoes construc�on to become grade-separated).

I am also well aware that there is mo�va�on to simply get this project completed and opera�onal at the proposed site despite its drawbacks so that the benefits of the project can be realized sooner rather than later. I would also generally prefer that outcome, but not at the expense of an inadequate evalua�ve process.

Short of developing the project at a different loca�on, this is what I believe should be done:
• The EIR should be recirculated in order to properly iden�fy and disclose that the project will result in a significant and unavoidable impact regarding GHG emissions, in par�cular because informa�on in the EIR (despite presen�ng a conclusion otherwise) demonstrates that the project will conflict with exis�ng GHG emissions plans, policies, and regula�ons due to its high levels of Vehicle Miles Traveled (VMT) in excess of the thresholds iden�fied in the City’s VMT Guidelines. • Along with/as part of the process of recircula�ng the EIR, the land use applica�on and project descrip�on should be revised to include a GPA and Rezone that is consistent with all of the proposed uses included as part of the project (par�cularly the MDO/Last Mile Delivery facility).

Alterna�vely, the project component triggering the conflict with the currently proposed Land Use and Zoning designa�ons (the MDO/Last Mile Delivery facility) could be removed from the project.
• As part of the process of recircula�ng the EIR, the Alterna�ves analysis should be revised to more precisely evaluate at least one of the alterna�ve sites iden�fied in the DEIR comments (either in my comments or other comments). Specifically, a transporta�on queuing analysis should be prepared so that the proposed project’s significant and unavoidable queuing impacts can be adequately and meaningfully contextualized (i.e., to provide understanding of whether the queuing impacts are especially site-specific and could be avoided by developing the project at another site, or if significant and unavoidable queuing impacts would s�ll be likely to occur if the project was developed elsewhere in the vicinity).

I appreciate your considera�on of these comments and their inclusion in the record.

Sincerely,

Daniel Brannick

3 1. Comments regarding inconsistency between the operational characteristics identified in the proposed project description and the uses allowed by the proposed General Plan Amendment and Rezone.

Response I103-2 presents addi�onal informa�on about the details of the proposed Market Delivery Opera�on (“MDO”) component of the project (also referred to at �mes as a “Last Mile Delivery” facility in project documents and during public mee�ngs). The response indicates that the City determined the MDO/Last Mile Delivery component falls within the accessory use classifica�on (i.e., an accessory to the large-format retail Costco store). The response also provides further details about how the MDO/Last Mile Delivery facility will be related to and complement opera�on of the large-format retail por�on of the proposed Costco project.

The informa�on provided in the response does not resolve the issue of whether the Development Code was properly applied, primarily because it ignores or sidesteps considera�on whether the MDO/Last Mile Facility component of the project is already defined and regulated in the Development Code.

As men�oned in earlier comments, the proposed MDO/Last Mile Delivery facility falls under the defini�on of what the City of Fresno’s Development Code defines as a “Warehousing, Storage, and Distribu�on” use (herea�er abbreviated as “WSD”). The defini�on from the Development Code is as follows:

Warehousing, Storage, and Distribution. Storage and distribution facilities without sales to the public on-site or direct public access except for public storage in small individual spaces exclusively and directly accessible to specific tenants.

The MDO fits this defini�on because it will be used for storage and distribu�on, and it will not offer direct public access or be used for public on-site sales. See text below for reference:
“… This approximately 47,000-square-foot relocated market delivery opera�on (MDO) is a last- mile facility for delivery of large and bulky items and is not open to visita�on by Costco members. At MDO facili�es, large goods are dropped off, organized, and loaded for daily deliveries to Costco members’ homes. Services would be the same scale as the exis�ng program but would be consolidated into the proposed warehouse facility.” (DEIR, p. 2-13) As also previously men�oned, the Development Code lists several sub-types of WSD uses (see Sec�on 15-6705), including “Indoor Warehousing and Storage” and “Wholesaling and Distribu�on”, and the proposed MDO/Last Mile Delivery Facility falls under the defini�on of these sub-types.

It is also noted that WSD uses are listed under the “Industrial Use Classifica�ons” in 15-6705 rather than “Commercial Use Classifica�ons” in 15-6704. The only type of WSD use allowed in Commercial Zone Districts is Personal (Mini) Storage. While there is one type of WSD allowed in Commercial districts, the fact that WSD uses are listed under the “Industrial Use Classifica�ons” rather than “Commercial Use Classifica�ons” implies that the Development Code considers such uses to be predominantly industrial in nature.

As demonstrated here and in earlier comments, the MDO/Last Mile Delivery facility is not some special undefined or previously uncontemplated use but rather one that is already defined in the 4 code and a type of which already exists locally. The Amazon warehouse located near SR-180 and Clovis Avenue in the City of Fresno is an example of a last-mile delivery facility use. The site of that facility (APN 456-030-56) is zoned Light Industrial, which is both consistent with the Development Code and reflec�ve of the physical/opera�onal nature of that use. Even if the footprint of the project’s proposed MDO/Last Mile Delivery facility is not as large as a typical standalone last-mile facility, the use is s�ll the use.

To further illustrate this point, I would like to call aten�on to the treatment of the Car Wash component of the subject project. According to informa�on presented by both the Applicant’s representa�ves and City staff in presenta�ons, the inclusion of the GPA and Rezone as part of the project’s applica�on for en�tlements was necessary to allow the development of the Car Wash.

Specifically, the Car Wash was not a permited use (either by-right or through a CUP) in the exis�ng “Community Commercial” (“CC”) zone district, thus the project applica�on includes a GPA and Rezone to the “Commercial General” (“CG”) zone district which condi�onally allows for development of a Car Wash.

If the Car Wash cannot be considered an “accessory use”, then the MDO/Last Mile Delivery facility similarly cannot be considered an “accessory use”. The Applicants’ public statements and the Response to Comments have gone to great length to highlight details about opera�onal synergies and similar advantages between the MDO/Last Mile Delivery facility and the large-format retail store. Many of the same points could be raised about the Car Wash and the store. A�er all, offering car washes alongside the large-format retail store would also likely be considered a reflec�on of “members’ evolving shopping paterns and demands.”
Even though the Car Wash’s footprint would be rela�vely small compared to the size of the large- format retail building and parking areas, and its opera�on would be subordinate to that of the retail store area, the GPA and Rezone is required because the use is still the use.

Further, in case it needs to be stated, the absence of WSD uses other than “Personal Storage” from the Use Table reflects that they are prohibited from all Commercial zone districts. “Personal Storage” is the only WSD use listed because it is the only such use allowed in at least some of the Commercial zone districts. When a use is prohibited from all districts listed under a zoning category, it is not listed in the table with all dashes (‘-‘) but rather is omited en�rely from the use table for that category. (For a visual reference, refer to Use Tables in the Citywide Development Code or which were atached to my DEIR comment leter.)
As an example, if I wanted to open an auto dealership at my residence and went to the City for a zone clearance, I would presumably be denied because auto dealerships are not allowed in Residen�al designa�ons. While the Use Table for Residen�al Districts does not expressly list auto dealerships as a prohibited use, it is their complete absence from the Use Table for Residen�al Districts which indicates they are not allowed uses in that district.

The Applicant’s representa�ves men�oned on at least one occasion that the proposed MDO/Last Mile Delivery facility was added to the project a�er the land use applica�on was ini�ally submited to the City. This would at least par�ally explain why the proposed Land Use and Zoning associated with the project applica�on does not align with inclusion of the MDO/Last Mile Delivery facility.

Whether the inconsistency has persisted due to an oversight or a more inten�onal decision to carry 5 on contrary to the provisions of the Development Code, it is not appropriate for the project to be able to skip directly to a “Director’s Determina�on” and shoehorn the MDO/Last Mile Delivery facility component into the prior applica�on when doing so means it no longer conforms to the underlying land use and zoning designa�on.

The fact of the mater is that the MDO/Last-Mile Delivery facility use is one that is expressly defined in the Development Code 15-6705 among the list of Industrial Use Classifica�ons. Since the Development Code lists the use in ques�on, Sec�on 15-5020 is not triggered. Such uses are only listed under the Use Table for Employment Districts (Table 15-1302). The only type of WSD use listed at all in the Use Table for Commercial Districts (Table 15-1202) is Personal Storage, and the MDO/Last Mile Delivery facility is absolutely not that.

By proceeding in this manner, adop�on of the project would be in conflict with the zoning regula�ons set forth in the City’s Development Code. It raises ques�ons about the overall integrity of the City’s planning and development processes. It also sets an unsetling precedent of the City allowing logis�cs and warehousing uses in areas designated for Commercial use when those uses are absent from the Use Table and thus should be considered excluded from/not allowed in Commercial Districts.

As indicated in my DEIR comments (and not challenged in the Response to Comments), there would not be a consistency issue present if the subject land use applica�on involved a GPA and Rezone to one of the “Employment” designa�ons (e.g., “Employment – Light Industrial”). Therefore, to remedy the zoning inconsistency, the land use applica�on and project descrip�on should be revised to include a GPA and Rezone that is consistent with all of the proposed uses included as part of the project (par�cularly the MDO/Last Mile Delivery facility). Alterna�vely, the project component triggering the conflict with the currently proposed Land Use and Zoning designa�ons (the MDO/Last Mile Delivery facility) could be removed from the project so that it is consistent with CG zoning.

2. Comments addressing issues and deficiencies in the analysis of specific categories of environmental effects.

Part 2 of my Dra� EIR comments raised ques�ons and expressed concerns regarding the analysis of several categories of environmental effects in the DEIR. Responses I103-3 through I103-7 address the comments in Part 2 of my DEIR comment leter. The comments here are focused on Transporta�on and Greenhouse Gas Emissions impacts.

Transportation
The Dra� EIR iden�fies three significant and unavoidable environmental impacts involving transporta�on effects: 1) VMT above SB 743 thresholds; 2) transporta�on safety issues due to poten�ally hazardous queuing condi�ons at three loca�ons in the vicinity of the site (Fir and Riverside, Herndon and Riverside, and Herndon and Golden State); and 3) cumula�ve impacts associated with VMT above thresholds. The comments here are related to the second impact (transporta�on safety).
6 Response I103-7 provides more detailed informa�on concerning transporta�on queuing condi�ons and proposed improvements/measures that would help reduce poten�al risks, including risks related to the proximity of the railroad tracks that run parallel to Golden State Boulevard.

As emphasized elsewhere and in my DEIR comments, the project’s transporta�on safety impacts remain significant and unavoidable, and it is highly likely that the adverse project impact is atributable to the specific site being proposed for development.

Regarding the fourth paragraph of the response, it is unclear whether this statement was intended to specifically rebut some aspects of the concerns raised or to beter demonstrate the validity of the analysis. I just want to note that from a plain reading it appears to corroborate concerns that were iden�fied related to project-related transporta�on ac�vity on Herndon.

The fi�h (and final) paragraph of this response states:
“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 [sic] 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.”
First, it is slightly unclear whether the men�on of “rail crossing improvements” men�oned in the last sentence refers to the full-on future grade separa�on of Herndon or to the rail crossing improvements men�oned earlier in this comment (e.g., “Do Not Block” signage and/or road paint).

Either way, the risks associated with vehicles being queued near the railroad tracks (not just train-to- vehicle but vehicle-to-vehicle and even vehicle-to-pedestrian) are regularly observed and experienced by people who travel along this segment of Herndon Avenue. When the subject traffic- safety queuing impacts occur, the effects will occur in this same segment, including where the railroad tracks are proximate. It should also be plainly evident how physically separa�ng the roadway from directly interac�ng with the rail corridor would avoid or reduce said impacts.

To reiterate what was already stated in the DEIR comments, the deferral of development should not be considered infeasible or unreasonable given the precedent of Granville’s Parc West residen�al project (a subdivision with 800+ homes on 160 acres), which required deferring the project’s buildout un�l the comple�on of Veterans Boulevard (which like Herndon, entailed a roadway/grade- separa�on project undertaken to allow for HSR buildout) and a fire sta�on to serve the area. Further, the �ming of Veterans’ construc�on was considerably affected by local budgetary and grant-seeking ac�vi�es (i.e., ini�al delays due to de-priori�za�on of Measure C funding, and later advances due to the City applying for and being awarded federal transporta�on money). In other words, the same 7 general considera�ons apply to the Herndon grade separa�on, so it is not accurate to characterize the �ming or comple�on as totally out of the control of local interests.

There are two addi�onal items related to informa�on which came up a�er the end of the DEIR comment period that I want to make sure are noted for the record:
1) During the community mee�ng held by the Applicant’s representa�ves on February 2, 2024, at River Bluff Elementary School, a representa�ve from Kitleson indicated that supplemental traffic analysis was either being conducted or had been completed during January 2024. However, no informa�on regarding a supplemental traffic analysis or similar content appears to have been included as part of the Final EIR or available for public review. My primary concern is that if such informa�on (assuming it does exist) is u�lized or referenced as part of the ul�mate decision to be made by City Council on the subject project, it absolutely would need to have been made available for public review for a reasonable amount of �me ahead of the public hearing and decision. 2) Following submital of my DEIR comment leter, I became aware that a Raisin’ Canes drive-thru restaurant is under construc�on at the north end of the El Paseo shopping center. Raisin’ Canes is among the class of drive-thru restaurants that are known for drawing large crowds and having especially long drive-thru lines.

While it appears that a substan�al amount of drive-thru and parking space has been incorporated as part of the Raisin’ Canes project, the concern here is that addi�onal volume of traffic resul�ng from that new development (in combina�on with exis�ng traffic from vehicles accessing El Paseo) could exacerbate an exis�ng circula�on botleneck within El Paseo and lead to backups of vehicles atemp�ng to enter El Paseo from eastbound Herndon Avenue using southbound Weber Avenue (the roadway that runs between the Raisin’ Canes loca�on and the McDonald’s).

The “Weber Avenue-Weber Avenue” intersec�on inside El Paseo (about 350 feet south of Herndon) is Stop sign-controlled. The Target crosswalk area immediately south of this intersec�on is very ac�ve, so southbound cars are o�en wai�ng at the Stop sign (or just past it) while pedestrians cross to and from the entrance to Target. During high-volume �mes like holiday shopping days, one can see cars backed up from Weber onto Herndon Avenue.

Since Raisin’ Canes appears to be imminently close to opening, I am very interested to see how this will play out – if it does result in backups onto Herndon (akin to the backups on west Shaw that were happening at the In-N-Out loca�on, which is currently undergoing site renova�on in order to address that issue), then it appears likely this condi�on will exacerbate the queuing-related transporta�on safety impacts of the Costco project (that is, the context in which the queuing impacts occur will be worse than expected). More specifically, if vehicles are queued out onto the far right lane of Herndon, it will reduce available space for eastbound thru-traffic on Herndon to navigate around the traffic queuing issues which the EIR indicates will occur in the vicinity of the project site.

From review of the DEIR, it appears that the development of new high-volume drive-thru restaurant uses like Raisin’ Canes in the vicinity of the project site was not an�cipated or considered as part of the EIR’s analysis. If this type of development ac�vity was accounted for, it would be appreciated it the Applicant’s representa�ves and/or the City could clarify how so.

8 Greenhouse Gas Em issions
Response I103-5 addresses comments regarding GHG emissions and in par�cular purports to jus�fy the EIR’s differing significance determina�ons regarding the project’s VMT-related transporta�on effects and its GHG emissions effects. This response here along with the determina�on regarding GHG Emissions impacts in the DEIR is simply baffling and infuria�ng. For reasons previously discussed in my DEIR comments, the determina�on that the project will have significant and unavoidable VMT-related impacts while having no significant impact regarding GHG emissions is irreconcilable.

The following addi�onal comments are intended to further clarify the comments previously presented in my DEIR comment leter:
1) Conflicts and inconsistencies atributable to the project’s VMT in excess of established thresholds are already iden�fied in the EIR and its GHG Appendix (see atached pages at the end of this leter). In addi�on to the very direct inconsistency with Item 1(h) in the GHGRP checklist, the overall amount of references made to VMT in the consistency checklists is very demonstra�ve at a holis�c level of how significant and important reducing VMT is to reducing GHG emissions and achieving climate goals. It is also noted that the consistency analysis seems to arbitrarily imply that the consistency items are all of equal weight and that inconsistency/conflict with an item can be offset simply by demonstra�ng consistency with a majority of other items. This line of apples-to-oranges reasoning is improper. 2) While the CEQA Guidelines Appendix G Checklist is organized such that 15061.4(b) (which was implemented by SB 743) is directly presented in the list of ques�ons for Transporta�on impacts, SB 743 and the policies and regula�ons implemented via its adop�on are absolutely about GHG emissions. This is demonstrated by the fact that SB 743 is specifically iden�fied and discussed in the DEIR’s Regulatory Se�ng for the Greenhouse Gas Emissions sec�on as well as in the Greenhouse Gas Emissions Technical Report (DEIR Appendix F). This should be viewed as a complete refuta�on of the narrow-minded asser�on in the FEIR/Response to Comments that VMT in excess of threshold levels referenced by 15061.4(b) is somehow not also in conflict/inconsistent with applicable policy and regula�ons intended to reduce GHG emissions, and/or that this impact should only be looked at or called out as a “Transporta�on” impact because of how the Appendix G Checklist is organized. This project – a large-format Costco retail store featuring 36 gas pumps that largely deters or precludes low-VMT development in its proximity due to its inherent physical and opera�onal characteris�cs – is an extremely apt example of the type of project which the enactment of SB 743 sought to target through its mul�faced aim which includes reducing GHG emissions through encouragement of infill development and a diversity of uses instead of sprawl.
3) In addi�on to failing to appropriately iden�fy the significant and unavoidable impact as required by CEQA, the ra�onale and comments demonstrate what arguably amounts to an atempt to willfully confuse the meaning of and/or downplay the significance of the EIR’s own significant- and-unavoidable determina�on regarding the project’s threshold-exceeding VMT levels. The approach being taken in the EIR func�onally serves to keep the project’s VMT impacts in the realm of “technical minu�ae” and cuts against the provision of adequate informa�on to the public and fostering of meaningful public par�cipa�on.
9 4) The comment below is meant to clean up a typo/omission from my DEIR comments, specifically in the parenthe�cal part of the comment.

On p. 3.7-13:

Additionally, the use of CAP consistency for CEQA determinations is still supported by CARB
in Appendix D of the 2022 Scoping Plan (CARB 2022: 7-10). The 2022 Scoping Plan does not explicitly state that the new reduction goals of AB 1279 disqualify existing CAPs that align with the state’s previous target of reducing emissions by 40 percent from the 1990 inventory.
(Note: The appearance of this statement leads me to believe it is strongly suggested by the 2022 CARB Scoping Plan that older plans not accoun�ng for AB 1279 such as the City’s GHGRP are actually now out of compliance.)
Again, CEQA does not ban projects with significant and unavoidable impacts from ul�mately being carried out when there are compelling reasons to do so, and the range of legi�mate reasons is broad and can be for non-environmentally-centric reasons. What CEQA does require though is disclosure of informa�on in order to allow informed understanding and meaningful public par�cipa�on.

The Dra� EIR’s failure to iden�fy policy and regulatory conflicts and inconsistencies resul�ng from the project’s GHG-related impacts (which stem from its acknowledged threshold-exceeding VMT levels) as being significant and unavoidable impact is a major analy�cal and informa�onal deficiency.

Since recircula�on is required in situa�ons involving subsequent iden�fica�on of a significant and unavoidable impact which was not previously iden�fied as such, recircula�on of this EIR with the necessary updated informa�on should be required in order for the environmental review process to comply with CEQA.

3. Comments on the Draft EIR’s Alternatives analysis
Response I103-8 provided further informa�on and discussion about why the considera�on of alterna�ve project sites would be infeasible and how the EIR has sa�sfied requirements for alterna�ves analysis under CEQA.

The response does not sufficiently refute the need for analyzing alterna�ves nor does it provide informa�on amoun�ng to substan�al evidence that specified alterna�ve loca�ons (par�cularly those at Veterans) would be infeasible.

For reasons already discussed, the proposed alterna�ve loca�ons (specifically the two loca�ons at Veterans) are substan�ally similar in terms of loca�on, overall area, roadway access, physical site characteris�cs, etc. that they are capable of mee�ng most if not all of the iden�fied project objec�ves. Poten�al constraints like the presence of the FMFCD easement are capable of being feasibly reconciled, which is demonstrated through observa�on of the amount of exis�ng development in the area and in comparison to the types of constraint responses entailed in the project as currently proposed (e.g. construc�ng a long new private drive, redesigna�ng a roadway). 10 Zoning and SB 330 considera�ons are not an issue at one or possibly both of the alterna�ve sites on Veterans because the land is (or now appears to be) zoned for Light Industrial, which as explained previously would allow all project components to be developed (see atached GIS figure at the end of this leter; note the apparent revisions that have occurred or are underway at the proposed alterna�ve site area south of Veterans).

The only notable dis�nc�ons are that the proposed alterna�ve sites consist of mul�ple parcels (i.e., 2-3 parcels apiece) and they are not under the immediate control of the applicant. However, not only are the parcels for each area under common ownership, each of the areas was previously and is now ac�vely being adver�sed as for sale (see site images with “For Sale” signs included at the end of this comment leter). Based on these factors, and given that Costco is a mul�-billion dollar corpora�on and a highly sophis�cated developer of property (and likely highly desirable to sellers), it is highly evident that the proponent would readily have the capacity to “reasonably acquire, control or otherwise have access to the alterna�ve site.”
Two addi�onal principles of CEQA to keep in mind: Alterna�ves are at the heart of the EIR’s analysis, and CEQA is interpreted broadly, as in “to be interpreted in such manner as to afford the fullest possible protec�on to the environment within the reasonable scope of the statutory language.” While there could ul�mately be jus�fiable reasons to pursue development of the proposed project at the proposed site rather than one of the proposed alterna�ve sites, the analysis and ra�onale presented in the EIR (both the DEIR and FEIR/RTC) to jus�fy excluding alterna�ve sites from the EIR’s more comprehensive alterna�ves analysis is inadequate, arbitrary, and self-serving to a degree that aims to make approval of the project at proposed the site a forgone conclusion.

I want to note that my comment leter was one of 103 comments provided from 102 individuals in response to the DEIR. Of those, 50 comments (49 commentors) were in opposi�on to the project, 32 comments (32 commentors) were in favor of the project, and 21 comments (21 commentors) did not have a clear sen�ment or were highly focused on a specific issue. While many of the comments in favor of the project iden�fy how a new Costco can resolve site-specific issues at the exis�ng Costco (e.g., constrained site capacity, traffic issues, safety issues), these comments offer less discussion and less specific detail about site-specific benefits (the ones that do mostly include comments indica�ng that the roads serving the proposed site will be able to handle traffic much beter than Shaw Avenue, and that having a more northerly site would make it easier to reach for people traveling from places in far northwest Fresno and areas beyond such as Madera). In contrast, many of the comments in opposi�on to the project (including ones that express support for the general idea of a new Costco) iden�fy site-specific issues and problems as the basis for opposing the project (e.g., concerns about things like air quality, noise, and traffic causing dispropor�onately adverse effects to the immediate area and community). Mul�ple comments submited in response to the DEIR (along with comments presented during community mee�ngs) ques�oned why this specific loca�on was selected and offered sugges�ons of alterna�ve sites or specified areas where the project could sensibly be developed and result in less community and environmental conflict.

The sites iden�fied included the vacant areas near Veterans Boulevard as well as areas further to the west, including the site where the former Klein’s Truck Stop was located (southwest corner of Herndon Avenue and Golden State Boulevard).
11 From this informa�on, it legi�mately seems that pursuing development of the project at a nearby alterna�ve site could substan�ally address many of the concerns that are the basis of opposi�on while s�ll providing the changes and outcomes that are the basis of public support for the project.

This further reinforces that as a mater of public concern the Dra� EIR should have included evalua�on of an alterna�ve site such as one of the proposed Veterans Boulevard loca�ons in order to determine if the significant and unavoidable queuing impacts are capable of being mi�gated to a less than significant level or at least substan�ally reduced through developing the site at a different loca�on in the same general vicinity.

Table C-1. Consistency with 2022 CARB Scoping Plan Update Costco Commercial Center
Fresno, California
Priority Areas Priority GHG Reduction Strategies Consistency Convert local government fleets to ZEVs and provide EV charging at public sites Create a jurisdiction-specific ZEV ecosystem to support deployment of ZEVs statewide (such as building standards that exceed state building codes, permit streamlining, infrastructure siting, consumer education, preferential parking policies, and ZEV readiness plans) Reduce or eliminate minimum parking standards
Implement Complete Streets policies and investments, consistent with general plan circulation element requirements
Increase access to public transit by increasing density of development near transit, improving transit service by increasing service frequency, creating bus priority lanes, reducing or eliminating fares, microtransit, etc.

Increase public access to clean mobility options by planning for and investing in electric shuttles, bike share, car share, and walking
Implement parking pricing or transportation demand management pricing strategies Amend zoning or development codes to enable mixed-use, walkable, transit-oriented, and compact infill development (such as increasing the allowable density of a neighborhood) Preserve natural and working lands by implementing land use policies that guide development toward infill areas and do not convert “greenfield” land to urban uses (e.g., green belts, strategic conservation easements)
Adopt all-electric new construction reach codes for residential and commercial uses Adopt policies and incentive programs to implement energy efficiency retrofits for existing buildings, such as weatherization, lighting upgrades, and replacing energy-intensive appliances and equipment with more efficient systems (such as Energy Star-rated equipment and equipment controllers)
Adopt policies and incentive programs to electrify all appliances and equipment in existing buildings such as appliance rebates, existing building reach codes, or time of sale electrification ordinances Facilitate deployment of renewable energy production and distribution and energy storage on privately owned land uses (e.g., permit streamlining, information sharing) Deploy renewable energy production and energy storage directly in new public projects and on existing public facilities (e.g., solar photovoltaic systems on rooftops of municipal buildings and on canopies in public parking lots, battery storage systems in municipal buildings) Abbreviations:

CalGreen - California Green Building Standards Code
CARB - California Air Resources Board
EV - electric vehicle
GHG - greenhouse gas
PG&E - Pacific Gas & Electric
VMT - vehicle miles traveled
ZEV - zero emission vehicle
Transportation Electrification
VMT Reduction
Building Decarbonization
Consistent. Although this goal is not applicable to an individual commercial development project, the Project is implementing neighborhood design improvements such as pedestrian network improvements and constructing bikeway facilities as part of the project. The Project also includes a redesignation from Expressway Area to Superarterial, which allows for multiple modes of travel traffic, including pedestrian and bikes. This could lead to further development of these types of non- vehicular facilities, including bike lanes and sidewalks, which are not currently allowed under the Expressway Area designation.

In addition, the Project plans to encourage employee commute trip reduction through a variety of strategies. The project will provide carpool incentives, partner with local agencies to provide vanpool services, subsidize transit passes and provide bicycle storage and locker rooms for employees who bike to work. This will reduce the employee VMT and provide incentives for employees to commute to work alternative ways.

Consistent. Although this goal is not applicable to an individual commercial development project, the Project includes an EV parking requirement and includes 45 installed EV spaces.

Consistent. Although this goal is not applicable to an individual commercial development project, the Project plans to use PG&E's Solar Choice program, which provides 100% solar energy to customers.

In addition, to the extent applicable to the Project, the Project would meet the CalGreen Building Standards Code in effect at the time of building permit application, which would include a number of energy saving requirements.

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# Confidential Ramboll
Table C-2. Consistency with Fresno Regional Transportation Plan/Sustainable Communities Strategy Costco Commercial Center
Fresno, California
# Goal Policy Consistency Analysis
Encourage and prioritize full, fair, and equitable
participation by all affected communities in transportation decision-making and planning processes.

Actively work to ensure equitable distribution of the benefits and burdens of transportation projects.

Promote the improvement and expansion of accessible transportation options to serve the needs of all residents, especially those who have historically faced disproportionate transportation burdens.

Encourage alternatives to single-occupancy vehicles that reduce vehicle miles traveled (VMT) and greenhouse gas emissions.

Support investment in and promotion of active transportation and transit to improve public health and mobility, especially in historically underinvested areas.

Encourage sustainable development that focuses growth near activity centers and mobility options that achieve greater location efficiency.

Support local jurisdictions’ efforts to minimize the loss of farmland, environmentally sensitive areas, and natural resources
Support local jurisdictions’ efforts to facilitate the development of diverse housing choices for all income groups.

Facilitate and promote interagency coordination and consistency across planning efforts.

Incentivize and support efforts to improve air quality and minimize pollutants from transportation.

Prioritize investment in and promote multimodal safety measures to reduce traffic fatalities and incidents in the region.

Promote enhanced Transportation Systems Management (TSM) and Transportation Demand Management (TDM) strategies to reduce congestion and vehicle miles traveled.

Encourage improvements in travel connections across all modes to create an integrated, accessible, and seamless transportation network.

Maximize the cost-effectiveness of transportation improvements.

Encourage investments that increase the system’s resilience to extreme weather events, natural disasters, and pandemics.

Preserve and maintain existing multimodal transportation assets in a state of good repair Support local and regional economic development by leveraging planning and transportation funds that foster public and private investment.

Facilitate efficient, reliable, resilient, and sustainable goods movement.

Support innovative mobility solutions that are accessible, affordable, reduce greenhouse gas emissions, and improve air quality.

Consistent. Although this goal is not applicable to an individual commercial development project, the Project would be located nearby to transit stops and thus would allow for utilization of existing transit facilities to visit the Project. In addition, the Project includes an EV parking requirement and includes 45 installed EV spaces.

Support efforts to expand broadband access throughout the region. Not Applicable.

Abbreviations:

EV - electric vehicle
NW - northwest
TDM - Transportation Demand Management
TSM - Transportation Systems Management
VMT - vehicle miles traveled
Consistent. Although this goal is not applicable to an individual commercial development project, the Project will facilitate goods movement to the Fresno area and provide approximately 165 to 175 jobs. 1 Improved mobility and accessibility for all
Consistent. Although this goal is not applicable to an individual commercial development project, it is envisioned that Project's location will provide convenient access for nearby residences for additional retail shopping experiences. In addition, the project is implementing neighborhood design improvements such as pedestrian network improvements and constructing bikeway facilities as part of the project, and will be located in close proximity to transit stops (e.g., NW Herndon-Hayes transit stop).

Consistent. Per the Transportation Impact Analysis, the Project would be consistent with the applicable plans, policies, and programs and would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.

The Project plans to encourage commute trip reduction through a variety of strategies. The Project will provide carpool incentives, partner with local agencies to provide vanpool services, subsidize transit passes and provide bicycle storage and locker rooms for employees who bike to work. This will reduce the employee VMT and provide incentives for employees to commute to work alternative ways.

The Project is implementing neighborhood design improvements such as pedestrian network improvements and constructing bikeway facilities as part of the project. In addition, the Project would be located nearby to transit stops and thus would allow for utilization of existing transit facilities to visit the Project.

Consistent. Although this goal is not applicable to an individual commercial development project, the Project includes a redesignation from Expressway Area to Superarterial, which allows for multiple modes of travel traffic, including pedestrian and bikes. This could lead to further development of these types of non-vehicular facilities, including bike lanes and sidewalks, which are not currently allowed under the Expressway Area designation.

In addition, the project is implementing neighborhood design improvements such as pedestrian network improvements and constructing bikeway facilities as part of the project. The Project will be located nearby transit facilities such as the NW Herndon-Hayes transit stop, thus allowing for alternatives to single-occupancy vehicle visits to the Project that would support efforts to improve air quality and minimize pollutants from transportation.

A region embracing clean transportation,
technology, and innovation5
Vibrant communities that are accessible by
sustainable transportation options2
A safe, well-maintained, efficient, and climate-
resilient multimodal transportation network3
A transportation network that supports a
sustainable and vibrant economy4

Page 1 of 1 ends

3. Greenhouse Gas (GHG) Reduction Plan Update - CEQA Project Consistency Checklist GHG Reduction Plan Update consistency review involves the evaluation of project consistency with the applicable strategies of the GHG Reduction Plan Update. The GHG reduction strategies identified in the GHG Reduction Plan Update relies upon the General Plan and additional local measures as the basis of the development related strategies to reduce GHG emissions. This checklist is developed based on the key local GHG reduction strategies and actions identified in the GHG Reduction Plan Update that are applicable to proposed development projects. Note that not all strategies listed below will apply to all projects. For example, not all projects will meet mixed-use related policies of the General Plan, because not all projects are required to be mixed use.

Checklist Item
(Check the appropriate box and provide an explanation for your answer) Relevant General Plan
Policy Yes No Not Applicable
(NA) Explanation
1: Land Use and Transportation Demand Strategies
a. Does the project include mixed-use, development? For GHG Reduction Plan consistency, mixed-use development is defined as pedestrian-friendly development that blends two or more residential, commercial, cultural, or institutional, uses, one of which must be residential
Policy UF-1-c, LU-3-b,
Objective-UF 12, UF-12-a,
UF-12-b, UF-12-d,
Policy RC-2-a
b. Is the project high density? For GHG Reduction Plan consistency, is the project developed at 12 units per acre or higher?
LU-5-f
c. Is the project infill development, pursuant to the General Plan definition of location within the City limits as of December 31, 2012? LU-2-a, Objective-12,
UF-12-a, UF-12-b, UF-12-d
d. Does the project implement pedestrian bicycle, and transit linkages with surrounding land uses and neighborhoods? For GHG Reduction Plan consistency, the project must include all sidewalks, paths, trails, and facilities required by the General Plan and Active Transportation Plan, as implemented through the Fresno Municipal Code and project conditions of approval.

Policy UF-1-c, UF-12-e,
Policy RC-2-a, Objective
MT-4,5,6, Policy MT-4-c,
Policy MT-6-a, Policy POSS-
7-h Objective MT 8, Policies
MT-8-a, MT-8-b
e. If the project includes mixed-use or high density development, is it located within ½ mile of a High Quality Transit Area as defined in the City’s CEQA Guidelines for Vehicle Miles Traveled? Or, is the project located within 500 feet of an existing or planned transit stop?
Policy UF-12-a,
UF-12-b, LU-3-b, Objective
MT 8, Policies MT-8-a,
MT-8-b
f. Will the project accommodate a large employer (over 100 employees) and will it implement trip reduction programs such as increasing transit use, carpooling, vanpooling, bicycling, or other measures to reduce vehicle miles traveled pursuant to San Joaquin Valley Air Pollution Control District Rule 9410?
See the SJVAPCD website for details: https://www.valleyair.org/rules/ currntrules/r9410.pdf
Policy MT-8-b, Objective
MT-9, Policy MT-10-c, San
Joaquin Valley Air Pollution
Control District Rule 9410
NA
NA
NA The project is not a mixed-use
or high density development
The project is not a mixed-use de-
velopment as it does not include
residential development.

The project is not high density.
yes
The project implements pedes-
trian, bicycle, and transit linkages
to surrounding land uses and
neighborhoods consistent with
Fresno's General Plan and Active
Transportation Plan.
yes
The project will implement trip re-
duction programs to encourage
carpooling and other measures to
reduce employee VMT.
yes
Checklist Item
(Check the appropriate box and provide an explanation for your answer) Relevant General Plan
Policy Yes No Not Applicable
(NA) Explanation
g. If the project includes modifications to the transportation network, do those improvements meet the requirements of the City of Fresno’s Complete Streets Policy, adopted in October 2019? According to the policy, a complete street is a transportation facility that is planned, designed, operated, and maintained to provide safe mobility for all users - including bicyclists, pedestrians, transit vehicles, trucks, and motorists - appropriate to the function and context of the facility while connecting to a larger transportation network.

See City of Fresno website for details: https://www.fresno.gov/publicworks/wp- content/uploads/sites/17/2019/10/Complete-Streets-091119.pdf MT-1-g, MT-1-h
h. Does the project have a less than significant VMT impact, either through satisfying screening criteria or mitigating VMT impacts, pursuant to the City’s adopted VMT thresholds?
See City of Fresno website for details: https://www.fresno.gov/darm/wp- content/uploads/sites/10/2021/01/CEQA-Guidelines-for-Vehicle-Miles-Traveled- Final-Adopted-Version.pdf
MT-2-b, MT-2-c
2: Electric Vehicle Strategies
a. For new multi-family dwelling units with parking, does the project provide EV charging spaces capable of supporting future EV supply equipment (EV capable) at 10% of the parking spaces per 2019 California Green Building Standards Code (CALGREEN, Title 24, Part 11), Section 4.106.4 Policy RC-8-j
b. For new commercial buildings, does project provide EV charging spaces capable of supporting EV capable spaces at 4% to 10% of the parking spaces per 2019 California Green Building Standards Code (CALGREEN, Title 24, Part 11), Section 5.106.5.3
Policy RC-8-j
3: Energy Conservation Strategies
a. Does the project meet or exceed mandatory state building energy codes? If yes, does the project follow any other GreenPoint ratings such as LEED, Energy Star or others? If yes, indicate level of certification-Silver, gold, platinum if applicable?
Policy RC-5-c, Objective
RC-8, Policy RC 8-a

b. For commercial projects, does the project achieve net zero emissions electricity?
Mark NA if project will be permitted before 2030. Mark Yes if voluntary. Add source and capacity in explanation.

Additional Recommended
GHG Plan Measure,
supports Objective RC-8
NA
Of 889 parking spaces, WKHUHZLOOEH
 LQVWDOOHG(9VSDFHV which is %
of the parking spaces (in range).

Project buildout is in 2023.

The project meets mandatory build-
ing energy codes; Costco's ware-
house designs are consistent with
the requirements of LEED.
yes
The project does not consist
of multi-family dwelling units.
yes
NA
yes
The project includes modifications
to the transportation network con-
sistent with the City's Complete
Streets Policy. Such improve-
ments include constructing side-
walk along the project frontage,
constructing a multi-use path, and
installing striping to better delin-
eate the roadway cross section for
different users.
no The project has a significant
VMT impact.

Checklist Item
(Check the appropriate box and provide an explanation for your answer) Relevant General Plan
Policy Yes No Not Applicable
(NA) Explanation
4: Water Conservation Strategies
a. Does the project meet or exceed the mandatory outdoor water use measures of the 2019 California Green Building Standards Code (CALGREEN, Title 24, Part 11), Section 4.304?
If the project exceeds CalGreen Code mandatory measures provide methods in excess of requirements in the explanation.

Examples include outdoor water conservation measures such as; drought tolerant landscaping plants, compliant irrigation systems, xeriscape, replacing turf etc. Provide the conservation measure that the project will include in the explanation.

Objective RC-7,
Policy RC-7-a, RC-7-h

b. Does the project meet or exceed the mandatory indoor water use measures of the 2019 California Green Building Standards Code (CALGREEN, Title 24, Part 11), Section 4.303?
If the project exceeds CalGreen Code, mandatory measures provide methods in excess of requirements in the explanation. Examples may include water conserving devices and systems such as water leak detection system, hot water pipe insulation, pressure reducing valves, energy efficient appliances such as Energy Star Certified dishwashers, washing machines, dual flush toilets, point of use and/or tankless water heaters.

Objective RC-7,
Policy RC-7-a, RC-7-e

5: Waste Diversion and Recycling Strategies
a. Does the project implement techniques of solid waste segregation, disposal and reduction, such as recycling, composting, waste to energy technology, and/or waste separation, to reduce the volume of solid wastes that must be sent to landfill facilities?
Policy PU-9-a, RC-11-a
b. During construction will the project recycle construction and demolition waste?
Policy RC-11-a
c. Does the project provide recycling canisters in public areas where trashcans are also provided?
Policy RC-11-a
Note: The GHG reduction strategies included in this checklist are based on the GHG reduction strategies identified in the Chapter 5 of the GHG Reduction Plan Update.

yes
yes
The project meets the mandatory
indoor water use measures. High-
efficiency restroom fixtures save
40% more water.

The project meets the
mandatory outdoor water
use measures.
yes
Costco prefers full metal buildings
in order to use the maximum
amount of recycled material.
yes
yes The project will recycle construction
and demolition waste.

The project will provide recycling
canisters.
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