Fresno City Council
December 5, 2024

Noise Ascent Environmental
City of Fresno

4.12-24 South Central Specific Plan Draft EIR
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Ascent Environmental Population, Employment, and Housing City of Fresno
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4.13 POPULATION AND HOUSING
This section describes the existing population, employment, and housing supply in the Plan Area and the City of Fresno, and the plan’s potential contributions to population growth, employment opportunities, and housing.

Comments pertaining to population and housing that were received in response to the notice of preparation relate to the potential changes to population distribution and concentration, and potential physical displacement. Additionally, comments express the need for additional housing outside of the Plan Area and the immediate surrounding communities.

4.13.1 Regulatory Setting

FEDERAL
No federal plans, policies, regulations, or laws applicable to population and housing apply to the proposed plan.

STATE
California Housing Element Law
The State Housing Element Law (Government Code Chapter 1143, Article 10.6, §§ 65580 and 65589) requires each city and county to adopt a general plan for future growth. This plan must include a housing element that identifies housing needs for all economic segments and provides opportunities for housing development to meet that need.

The amount of housing that must be accounted for in a local housing element is determined through a process called the Regional Housing Needs Allocation (RHNA). In the RHNA process, the State gives each region a number representing the amount of housing needed, based on existing need and expected population growth.

At the State level, the California Department of Housing and Community Development (HCD) estimates the relative share of the State’s anticipated population growth that would occur in each county in the State, based on CDF population projections and historic growth trends. Where there is a regional Council of Governments (COG), such as the Fresno Council of Governments (FCOG), the HCD provides the regional housing need to the council. The council then assigns a share of the regional housing need to each of its cities and counties. The process of assigning shares provides cities and counties the opportunity to comment on the proposed allocations. The HCD oversees the process to ensure that the COG distributes its share of the State’s projected housing need.

Each city and county must update its general plan housing element on a regular basis pursuant to the requirements of Government Code Section 65580, et seq. Among other things, the housing element must incorporate policies and identify potential sites that would accommodate a city’s share of the regional housing need. Before adopting an update to its housing element, a city or county must submit the draft to the HCD for review. The HCD will advise the local jurisdiction whether its housing element complies with the provisions of California Housing Element Law. The regional COGs are required to assign regional housing shares to the cities and counties within their region on a similar schedule. At the beginning of each cycle, the HCD provides population projections to the regional COGs, who then allocate shares to their cities and counties. The shares of the regional need are allocated before the end of the cycle so that the cities and counties can amend their housing elements by the deadline.

Population, Employment, and Housing Ascent Environmental City of Fresno

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LOCAL
City of Fresno General Plan
The City of Fresno General Plan: 2015-2023 Housing Element contains the following policies related to population and housing that apply to the proposed plan. These policies are contained in Chapter 6, “Housing Plan” (City of Fresno 2017).
 Policy H-1-a: Implement land use policies and standards that allow for a range of residential densities and products that will enable households of all types and income levels the opportunity to find suitable ownership or rental housing.
 Policy H-1-b: Encourage development of residential uses in strategic proximity to employment, recreational facilities, schools, neighborhood commercial areas, and transportation routes .  Policy H-1-c: Promote the development of affordable and special needs housing near transit and/or smart growth areas.
 Policy H-2-a: Facilitate housing development that is affordable to extremely low-, very low-, low-, and moderate- income households by providing technical assistance, regulatory incentives and concessions, and financial resources as funding permits.
 Policy H-2-b: Encourage both the private and public sectors to produce or assist in the production of housing, with particular emphasis on housing affordable to persons with disabilities, elderly, large families, female -headed households with children, and people experiencing homelessness.  Policy H-3-e: Encourage the new construction of housing in the Central City, Inner City, and other targeted areas.  Policy H-5-g: Create equitable and affordable housing options throughout the City that provide incentives to residents for finding housing in high opportunity areas and to developers for building affordable housing in high opportunity areas.
 Policy H-5-h: Consult with a wide range of groups throughout the community and consider environmental justice issues in the development and update of regulations, guidelines and other local programs.

Fresno Council of Governments
The Fresno Council of Governments (FCOG) is an association of local governments from cities within Fresno County.

The member agencies include the Cities of Clovis, Coalinga, Firebaugh, Fowler, Fresno, Huron, Kerman, Kingsburg, Mendota, Orange Cove, Parlier, Reedley, San Joaquin, Sanger, and Selma and Fresno County. FCOG is mainly responsible for transportation planning and programming for the region . Furthermore, FCOG is responsible for and oversees the Regional Housing Needs Allocation, a process mandated by California state law that requires each city and county to have land zoned to accommodate a fair share of the regional housing need.

Adopted on July 28, 2022, the Fresno County RHNA Plan covers an 8-year planning period that is between June 30, 2023 and December 31, 2031 (FCOG 2023). The Plan includes housing at four different income levels, including very low, low, moderate, and above-moderate. As determined by Fresno COG, the City of Fresno’s total housing unit capacity allocation is 36,866. This allocation translates into sites that could accommodate housing affordable to households that fall within the various income categories as follows:
 Very Low Income: 9,440 dwelling units
 Low Income: 5,884 dwelling units
 Moderate Income: 5,638 dwelling units
 Above-Moderate: 15,904 dwelling units
The City is not required to make development occur; however, the City must facilitate housing production by ensuring that land is available and that unnecessary development constraints have been removed. The City is Ascent Environmental Population, Employment, and Housing City of Fresno
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currently in the process of preparing the 2023-2031 Housing Element to show how it will accommodate the RHNA.

The Public Review Draft Housing Element, published in July 2023, showed capacity for over 46,000 housing units and a surplus of capacity for all income levels. However, the Housing Element is still in the process of being updated and the capacity numbers are subject to change.

4.13.2 Environmental Setting
This section describes the existing population and housing conditions within the Plan Aea, as well as in the City of Fresno as a whole, to provide context for the analysis of the proposed plan.

POPULATION
The city as a whole experienced moderate population growth from 1990 to 2000, increasing from 354,091 to 427,719 persons at an annual average increase of 2.1 percent (Table 4.13-1). During the decade from 2000 to 2010, the rate of growth slowed to an annual average of 1.6 percent, reaching a total population of 494,665 in 2010. The City’s population growth rate has slowed since 2010 to a population of 542,829 in 2022.

Table 4.13-1 Population Growth - Fresno
Year Population Annual Average Change
1990 354,091 --
2000 427,719 2.1%
2010 494,665 1.6%
2015 522,016 1.1%
2017 530,523 0.8%
2019 540,180 0.9%
2020 543,451 0.6%
2022 542,829 -0.01%
Sources: DOF 2010a.

Currently, the Plan Area consists of a population of approximately 1,130 residents (City of Fresno 2024). The General Plan does not project any new housing in the Plan Area. Therefore, no population growth is expected for the Plan Area. However, the City is projected to add an estimated 176,000 to 216,000 new residents between 2022 to 2040 (City of Fresno 2024).

HOUSING STOCK
As described in Section 3.2.2, the Plan Area has only a small residential population, residing in approximately 400 housing units. Residential uses in the planning area are largely characterized by rural residential and small subdivisions. Housing stock in the city as a whole has increased from 171,288 housing units in 2010 to 186,993 units in 2022, an average annual increase of 0.8 percent. According to the DOF, the average number of persons residing in a dwelling unit in Fresno is 3.441.

1 Calculated by Ascent Environmental in 2023.

Population, Employment, and Housing Ascent Environmental City of Fresno

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Table 4.13-2 Housing Unit Growth – City of Fresno
Year Housing Units Annual Average Change
2000 149,053 --
2010 171,288 1.5%
2015 176,915 0.7%
2017 178,819 0.5%
2019 180,632 0.5%
2020 184,226 2.0%
2022 186,993 0.8%
Sources: DOF 2010b.

EMPLOYMENT
According to the California Employment Development Department, there are 224,000 people employed in the City of Fresno in 2023 (EDD 2023). As of September 2023, the unemployment rate in the City is 6.8 percent. The City is projected to add nearly 70,000 employees between 2022 and 2040 (Fresno 2024 ).

4.13.3 Environmental Impacts and Mitigation Measures

METHODOLOGY
Impacts on population and housing were assessed by reviewing existing and anticipated population and housing projections provided by the City of Fresno (Fresno General Plan), DOF, and FCOG, and determining the project’s consistency with these estimates and growth projections. Population and employment growth, as an economic or social change, is not considered a significant effect on the environment pursuant to State CEQA Guidelines Section 15131. Growth that is consistent with planning documents that have u ndergone environmental evaluation would generally result in similar potential for environmental impacts and the requisite demand for infrastructure would typically be incorporated into the plans of the respective utility providers. However, where growth could lead to physical environmental changes, the potential for environmental effects is evaluated.

THRESHOLDS OF SIGNIFICANCE
A population, employment, and housing impact would be significant if implementation of the proposed plan would:
 induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure) , or  displace substantial numbers of existing people or homes, necessitating the construction of replacement housing elsewhere.

ISSUES NOT DISCUSSED FURTHER
All the issues identified in the thresholds of significance are addressed in the following analysis.

Ascent Environmental Population, Employment, and Housing City of Fresno
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ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
Impact 4.13-1: Directly or Indirectly Induce Substantial Unplanned Population Growth and Housing Demand
The proposed plan has the potential to generate future development of approximately 12,021,744 square feet (sf) of non-residential uses (including industrial, retail, and office) and 91 new residential dwelling units. Resulting in a minimal population increase of approximately 313 net new persons by 2040. Consistent with the General Plan, the purpose of the proposed plan is to create jobs for the City. The City is projected to add nearly 70,000 employees between 2022 and 2040. Therefore, implementation of the proposed plan will create jobs for the City’s projected growth in population and employment. The proposed plan would not induce substantial unplanned population growth, either directly (i.e., by proposed new unplanned homes) or indirectly (i.e., by the extension of roads or other infrastructure). Therefore, this impact would be less than significant.

The proposed plan has the potential to generate future development of approximately 12,021,744 square feet (sf) of non-residential uses (including industrial, retail, and office) and 91 new residential dwelling units. Based on the proposed 91 new dwelling units and the development capacity calculation of approximately 3. 44 persons per dwelling unit, the proposed plan is estimated to result in the addition of approximately 313 new residents in the City of Fresno by 2040. Population growth by itself is not considered a significant environmental impact.

The purpose of the proposed plan is to create jobs for the City and accommodate industrial, commercial and office development, and a minimal amount of residential units. As discussed above, the City is projected to add nearly 70,000 employees between 2022 and 2040. Therefore, implementation of the proposed plan will create jobs for the City’s projected growth in population and employment. Consistent with the General Plan, the proposed plan would promote balance of jobs and housing within the City. The additional growth of industrial, office, and retail and the minimal amount of residential units is consistent with citywide planning efforts. The proposed plan would not induce substantial unplanned population growth, either directly (i.e., by proposed new unplanned homes) or indirectly (i.e., by the extension of roads or other infrastructure). Therefore, this impact would be less than significant.

Mitigation Measures
No mitigation is required for this impact.

Impact 4.13-2: Displace Substantial Numbers of People or Existing Housing Although some existing housing may be demolished and/or renovated as a result of the proposed plan, the addition of 91 new dwelling units would offset the potential loss of existing housing. Additionally, the proposed plan does not involve any actions that would permanently displace substantial numbers of people. Therefore, implementing the proposed plan would not displace substantial numbers of people or housing. As a result, there would be no new significant effect, and the impact would not be more severe than the impact identified in the General Plan EIR. This impact would be less than significant.

The proposed plan focuses new development primarily on vacant and/or existing light and heavy industrial sites and would not result in displacements of residents or the loss of existing dwelling units. New development in the Plan Area could result in the loss of a limited number of dwelling units as future sites are redeveloped to a more efficient mixed use or residential project. However, any loss of existing units that may occur as a result of future deve lopment is not expected to be significant. Overall, implementation of the proposed plan includes approximately 91 additional residential units (an approximate increase of 313 residents) in the Plan Area, primarily complementary in nature to existing single family residential homes currently existing in the Plan Area. Overall, implementation of the proposed plan, including potential development/redevelopment of areas in the Plan Area, would not displace substantial numbers of existing housing or people. Therefore, this impact would be less than significant.

Mitigation Measures
No mitigation is required for this impact.

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Ascent Environmental Public Services and Recreation
City of Fresno
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4.14 PUBLIC SERVICES AND RECREATION
This section provides an overview of existing public services and recreation in the City of Fresno and evaluates the potential for implementation of the proposed plan to affect availability, service level, and/or capacity of public services, including fire protection services, law enforcement services, public schools, and parks and recreation, and, if such an effect is determined to occur, whether new or expanded facilities would be required that could result in a potentially significant impact to the environment.

Comments received in response to the NOP that pertain to public services and recreation suggest evaluation of greenspace availability, particularly for children. Greenspace, which provides recreational value, is evaluated below in the discussion of Impact 4.14-4 as part of the overall discussion related to recreation.

4.14.1 Regulatory Setting

FEDERAL
No federal plans, policies, regulations, or laws are applicable to the provision of public services for th e proposed plan.

STATE
California Fire Code
The 2016 California Fire Code, which incorporates by adoption the 2015 International Fire Code, contains regulations related to construction, maintenance, and use of buildings. Topics addressed in the California Fire Code include fire department access, fire hydrants, automatic sprinkler systems, fire alarm systems, fire and explosion hazards safety, hazardous materials storage and use, provisions intended to protect and assist fire responders, industrial processes, and many other general and specialized fire-safety requirements for new and existing buildings and the surrounding premises. The California Fire Code contains specialized technical regulations related to fire and life safety.

California Health and Safety Code
State fire regulations are set forth in Section 13000 et seq. of the California Health and Safety Code, which includes regulations for building standards (as set forth in the California Building Code), fire protection and notification systems, fire protection devices such as extinguishers, smoke alarms, high-rise building and childcare facility standards, and fire-suppression training.

Quimby Act
The Quimby Act (California Government Code Section 66477) states that “the legislative body of a city or county may, by ordinance, require the dedication of land or impose a requirement of the payment of fees in lieu thereof, or a combination of both, for park or recreational purposes as a condition to the approval of a tentative or parcel map.” Requirements of the Quimby Act apply only to the acquisition of new parkland and do not apply to the physical development of new park facilities or associated operations and maintenance costs. The Quimby Act seeks t o preserve open space needed to develop parkland and recreational facilities; however, the actual development of parks and other recreational facilities is subject to discretionary approval and is evaluated on a case -by-case basis with new residential development.

Leroy F. Greene School Facilities Act of 1998 (Senate Bill 50) The Leroy F. Greene School Facilities Act of 1998, also known as Senate Bill ( SB) 50 Proposition 1A (Chapter 407, Statutes of 1998), governs a school district’s authority to levy school impact fees. This comprehensive legislation reformed methods of school construction financing in California. SB 50 instituted a new school facility program by which school districts can apply for State construction and modernization funds. It imposed limitations on the power Public Services and Recreation Ascent Environmental
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of cities and counties to require mitigation of school facilities impacts as a condition of approving new development and provided the authority for school districts to levy fees based on justification studies, for the purposes of funding construction of school facilities, subject to established limits.

LOCAL
City of Fresno General Plan
The City of Fresno General Plan contains the following objectives and policies that are relevant to public services and recreation:

Public Utilities and Services Element
 Objective PU-1: Provide the level of law enforcement and crime prevention services necessary to maintain a safe, secure, and stable urban living environment through a Police Department that is dedicated to providing professional, ethical, efficient and innovative service with integrity, consistency and pride.  Policy PU-1-c: Safety Considerations in Development Approval . Continue to identify and apply appropriate safety, design and operational measures as conditions of development approval, including, but not limited to, street access control measures, lighting and visibility of access points and common areas, functional and secure on-site recreational and open space improvements within residential developments, and use of State licensed, uniformed security.
 Policy PU-1-d: New Police Station Locations. Consideration will be given to collocating new police station facilities with other public property including, but not limited to, schools, parks, playgrounds, and community centers to create a synergy of participation in the neighborhood with the potent ial result of less vandalism and promotion of a better sense of security for the citizens using these facilities.  Policy PU-1-g: Plan for Optimum Service. Create and adopt a program to provide targeted police services and establish long-term steps for attaining and maintaining the optimum levels of service - 1.5 unrestricted officers per 1,000 residents.
 Objective PU-2: Ensure that the Fire Department’s staffing and equipment resources are sufficient to meet all fire and emergency service level objectives and are provided in an efficient and cost -effective manner.  Policy PU-2-b: Maintain Ability. Strive to continually maintain the Fire Department’s ability to provide staffing and equipment resources to effectively prevent and mitigate emergencies in existing and new high- rise buildings and in other high-density residential and commercial development throughout the city.  Policy PU-2-d: Station Siting. Use the General Plan, community plans, Specific Plans, neighborhood plans, and Concept Plans, the City’s Geographic Information Systems (GIS) database, and a fire station location program to achieve optimum siting of future fire stations.  Policy PU-2-e: Service Standards. Strive to achieve a community wide risk management plan that includes the following service level objectives 90 percent of the time:
• First Unit on Scene – First fire unit arriving with minimum of three firefighters within 5 minutes and 20 seconds from the time the unit was alerted to the emergency incident. • Effective Response Force – Provide sufficient number of firefighters on the scene of an emergency within 9 minutes and 20 seconds from the time of unit alert to arrival. The effective response force is measured as 15 firefighters for low risk fire incidents and 21 firefighters for high risk fire incidents and is the number of personnel necessary to complete specific tasks required to contain and control fire minimizing loss of life and property.
 Policy PU-2-f: Plan for Optimum Service. Create and adopt a program to provide appropriate number of employees to effectively respond to call volume and type; and establish a long-term plan to attain a level of service of 0.81 firefighters per 1,000 residents.

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 Objective PU-3: Enhance the level of fire protection to meet the increasing demand for services from an increasing population.
 Policy PU-3-d: Review Development Applications. Continue Fire Department review of development applications, provide comments and recommend conditions of approval that will ensure adequate on -site and off-site fire protection systems and features are provided.  Policy PU-3-f: Adequate Infrastructure. Continue to pursue the provision of adequate water supplies, hydrants, and appropriate property access to allow for adequate fire suppression throughout the City.  Policy PU-3-h: Annexations. Develop annexation strategies to include the appropriate rights-of-way and easements necessary to provide cost effective emergency services.  Policy PU-3-i: New Fire Station Locations. Consideration will be given to co-locating new Fire Station facilities with other public property including, but not limited to, police substations, schools, parks, playgrounds, and community centers to create a synergy of participation in the neighborhood with the potential result of less vandalism and promotion of a better sense of security for the citizens using these facilities.

Urban Form, Land Use, and Design Element
 Objective D-4: Preserve and strengthen Fresno’s overall image through design review and create a safe, walkable, and attractive urban environment for the current and future generations of residents.  Policy D-4-d: Design for Safety. Continue to involve the City’s Police Department in the development review process to ensure new buildings are designed with security and safety in mind.

Fresno Parks Master Plan
The Fresno Parks Master Plan was adopted in December 2017 (City of Fresno 2017). The plan articulates a vision for improving Fresno’s park and open space system based on robust community engagement and thorough analysis.

The Parks Master Plan is an update to the 1989 Master Plan for Parks and Recreation, which was a component of the 1984 General Plan Open Space and Recreation Element. The 2017 plan accounts for changes that have occurred since the 1984 General Plan was drafted and reflects a vision for improving the City’s park and recreation system so that it better serves current and future needs of the people of Fresno.

City of Fresno Impact Fees
The City includes a development impact fee schedule to fund public services and facilities, including but not limited to fees to fund police and fire, library, and recreation services. The fees are established in Chapter 12, “ Impact Fees, Historic Resources, and Other Miscellaneous Topics,” of the Fresno Municipal Code. Article 4.6 – Payment of Development Fees and Charges, notes that the development of real property within the c ity creates demands on existing municipal facilities, improvements, and services. Various development fees and charges are imposed upon new development to mitigate such demands. Payment of those fees and charges is required at various stages of the development process, including the amendment of applicable land use plans, rezoning, tentative tract map, tentative parcel map, Urban Growth Management permit, the issuance of special permits, building permits, certificates of occupancy, and similar entitlements. To facilitate the orderly collection and administration of such development fe es and charges, Article 4.6 sets forth the terms and conditions upon which the payment thereof may be deferred and paid simultaneously upon the issuance of a certificate of occupancy for the buildings or structures within such development.

Article 4.8 (Police Facilities Fee) notes that to implement the goals and objectives of the City’s General Plan, and to mitigate the impacts caused by future development in the city, certain police facilities must be constructed. The City Council has determined that a Police Facilities Fee is needed to finance these public facilities and to pay for each development’s fair share of the construction and acquisition costs of these improvements.

Article 4.9 (Fire Facilities Fee) notes that to implement the goals and objectives of the City’s General Plan, and to mitigate the impacts caused by future development in the city, certain fire department facilities must be constructed.

The City Council has determined that a Fire Facilities Fee is needed to finance these public facilities and to pay for each development’s fair share of the construction and acquisition costs of these improvements.

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4.14.2 Environmental Setting

LAW ENFORCEMENT
The Fresno Police Department is responsible for enforcement of state and City laws, investigation of crimes, apprehension of criminals, reducing traffic collisions, maintenance of ongoing crime prevention programs, and building ties with the community and other local law enforcement agencies. The Police Department is divided into four divisions—the patrol division, the investigation division, the administrative division, and the support division. The Chief of Police supervises all divisions. As of 2021, there were 776 sworn officers and 308 professional staff (Fresno Police Department 2021) The Police Department Patrol Division is divided into five policing districts, two of which serve the Plan Area: Southwest Policing District and Southeast Policing District. The Police Department operates five police stations and one headquarters office, none of which are located in the Plan Area. The nearest Police Station to the Plan Area is in Southwest Fresno, located at 1211 Fresno Street, two miles north of the northern edge of the Plan Area near Downtown Fresno, and the other station is approximately 3.7 miles of northeast of the Plan Area boundary at 224 S. Argyle Avenue According to the Fresno Police Department, the existing law enforcement staffing and infrastructure are not meeting the current service load (Gross, pers. comm., 2023). To accommodate projected growth, the City is planning to develop a new centralized police headquarters and communications center building, two new substations, and a new 911 emergency operations dispatch center by 2035 (EPS 2022). Figure 4.14-1 depicts the existing law enforcement facilities within and surrounding the Plan Area.

Ascent Environmental Public Services and Recreation
City of Fresno
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Source: 2023 City of Fresno South Central Specific Plan, adapted by Ascent in 2023.

Figure 4.14-1 Law Enforcement

Public Services and Recreation Ascent Environmental
City of Fresno

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FIRE PROTECTION
The Fresno City Fire Department (FCFD) provides fire prevention, suppression and investigation services, airport fire and rescue, urban search and rescue, response to medical emergencies, and response to hazardous materials incidents. Resources attributed to FCFD include 19 engine companies, five truck companies, and four squads. Three fire stations are designated for specialty teams addressing hazardous materials, water rescue, and urban search and rescue services. In 2022, firefighter staff included 103 on-duty personnel (FCFD 2023a). There are two fire stations located within the Plan Area: City of Fresno Station 7, located at 2571 South Cherry Avenue, and Fresno County Fire Station 87, located at 4706 E Drummond Avenue just southeast of the intersection of Jensen and Maple Avenues . Fire Station 8 is located outside the Plan Area at 1428 S. Cedar Avenue but provides services to its northern portion.

Station 7 houses a single-engine company, an ICS/FIRESCOPE type 6 patrol, and a water tender (FCFD 2023b); Station 87 houses two-engine company, rescue boat, large rescue unit; and Station 8 houses an engine company and is home of the FCFD Communications Team.

According to FCFD, several factors are used to determine the need for new fire facilities. Based on communications with FCFD, the southern industrial area of the city currently experiences reduced response reliability. The City has considered development of a new fire station near North Avenue and Orange Avenue; however, project-level planning has not begun (Semonious, pers. comm., 2023). Figure 4.14-2 depicts the existing fire protection facilities within and surrounding the Plan Area.

SCHOOLS
The Plan Area includes portions of the Fresno Unified School District (FUSD), Washington Unified School District (WUSD), Orange Center School District, Sanger Unified School District, and Fowler Unified School District. There is one elementary school in the Plan Area. Orange Center Elementary School is located on the east side of Cherry Avenue, between Central and North Avenues. Figure 4.14-3 shows the school district boundaries within the Plan Area.

RECREATION
There are several types of parks in the city of Fresno, including pocket parks, neighborhood parks, community parks, regional parks, special-use parks, greenbelts/trails, and open space/natural areas. To ensure that park and open space recreation needs of Fresno residents are being met, the General Plan identifies level of service goals by park type: 3 acres per 1,000 residents for pocket parks, neighborhood parks, and community parks and 2 acres per 1,000 residents for regional parks, open space/natural areas, and special use parks. Currently, there are no parks within the Plan Area. Outside the Plan Area there are four parks within 0.5 mile of the Plan Area. The closest park is Almy Park, located at 255 West Almy Avenue, in Fresno, southeast of the Fig Avenue/North Avenue intersection. This approximately half-acre neighborhood park is consistent with the Fresno Parks Master Plan. Other parks located near but outside the Plan Area include Hinton Park (2385 South Fairview Avenue, Fresno), Regional Sports Complex (1707 W Jesen Avenue, Fresno), and Mary Ella Brown Park (1350 East Annadale Avenue, Fresno). As shown in Figure 3-14 approximately three acres of planned park space is identified near the neighborhoods of Roy and Almy. The rest of the open space is limited to existing and planned ponding basins dispersed through the Plan Area and are inaccessible to the public. Figure 4.14-4 shows the existing and planned ponding basin locations within the Plan Area.

Ascent Environmental Public Services and Recreation
City of Fresno
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Source: 2023 City of Fresno South Central Specific Plan, adapted by Ascent in 2023.

Figure 4.14-2 Fire Protection

Public Services and Recreation Ascent Environmental
City of Fresno

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Source: 2023 City of Fresno South Central Specific Plan, adapted by Ascent in 2023.

Figure 4.14-3 Existing Schools and School District Boundaries

Ascent Environmental Public Services and Recreation
City of Fresno
South Central Specific Plan Draft EIR 4.14-9

Source: 2023 City of Fresno South Central Specific Plan, adapted by Ascent in 2023.

Figure 4.14-4 Existing and Planned Parks and Ponding Basins

Public Services and Recreation Ascent Environmental
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4.14.3 Environmental Impacts and Mitigation Measures

METHODOLOGY
Evaluation of potential public service and recreation impacts was based on a review of documents pertaining to the SCSP, including the City’s General Plan, and consultation with public service providers, such as FCFD and Fresno Police Department. Impacts related to public services that would result from the proposed plan were identified by comparing existing service capacities and facilities against future demand associated with plan implementation, determining the possible need for new or physically altered facilities, and assessing the potential for construction of those facilities to result in significant effects. The Police and Fire Departments consider other factors including population, response times, allocated personnel and budget to determine the need to construct new facilities Student generation rates were based on information provided in the Fresno Unified School District Development Fee Justification Study (Odell Planning & Research 2022), which provides the following student generation rates for single- family homes in FUSD:
 elementary (transitional kindergarten [TK]–6): 0.346,  middle school (7–8): 0.083,
 high school (9–12): 0.625, and
 total (TK–12): 0.625.

THRESHOLDS OF SIGNIFICANCE
An impact related to public services or recreation would be significant if implementation of the proposed plan would:
 result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
 fire protection,
 police protection,
 schools,
 parks, and/or
 other public facilities;
 increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated; or  include recreational facilities or require the construction or expansion of recreational facilities that might have an adverse physical effect on the environment.

ISSUES NOT DISCUSSED FURTHER
Result in Substantial Adverse Physical Impacts Associated with the Provision of New or Physically Altered School Facilities
Based on applicable student generation factors, the estimated 91 dwelling units developed by 2040 would generate approximately 57 students, including 31 TK-6 students, 8 middle school students, and 18 high school students. While the future distribution of students in terms of enrollment location and grade level is unknown, students would attend one of 19 nearby schools across three school districts. This small increase over such a large number of schools and Ascent Environmental Public Services and Recreation
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school districts would represent a minor increase in enrollment in any one school and would not represent substantial growth that would require acquisition, modernization, or modification of school sites. Therefore, there would be no impacts related to new or physically altered school facilities and this topic is not discussed further.

Increase the Use of Existing Neighborhood and Regional Parks or Other Recreational Facilities Such That Substantial Physical Deterioration Would Occur or be Accelerated, or Require the Construction or Expansion of Recreational Facilities That Might Have an Adverse Physical Effect on the Environment
As discussed above, the projected future development of the proposed plan would include an estimated 91 dwelling new residential units by 2040, which is anticipated to support approximately 279 new residents at buildout. As indicated in Policy POSS-1-a, the City has established a standard of 3 acres of public parkland per 1,000 residents.

Based on this standard, less than one acre of parkland would be necessary to support the anticipated population growth in the Plan Area through 2040. Consistent with Figure 3-14 of Chapter 3, “Project Description,” there are no parks within the Plan Area, but there are several parks located nearby as noted above under Section 4.14.2, “Environmental Setting.” The projected number of residents in the Plan Area would be relatively small and dispersed and would not require the construction or expansion of recreational facilities beyond those included within the Parks Master Plan. Therefore, there would be no impact and this topic is not discussed further.

ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
Impact 4.14-1: Result in Substantial Adverse Physical Impacts Associated with the Provision of New or Physically Altered Fire Facilities
Under the proposed plan, development would be intensified within the Plan A rea and may increase demand for fire protection services that could require new or expanded facilities. Expansion of an existing fire station or construction of a new facility would involve minor land clearing, grading, installation of utilities, and building construction, generally on a modest-sized lot (approximately 2.5 acres). Construction activities and duration would be typical of such facilities and would be required to comply with applicable City policies and regulatory requirements to reduce adverse environmental effects. For these reasons, there is no evidence to suggest that such construction would result in unmitigable, adverse effects on the environment. Therefore, this impact would be less than significant.

The proposed plan is estimated to result in the future development of approximately 91 new residential dwelling units and approximately 12 million square feet (sf) of non-residential (industrial, retail, and office) uses by 2040 (see Chapter 3, “Project Description”). Development would be intensified in the Plan Area through the horizon year and may increase demand for fire protection service that could require development of new or expanded facilities.

Funding for fire protection services would come from a number of different sources. New development in the Plan Area would be required to pay development fees to assist in funding public services, including fire protection, fire facilities, and related services in the city. Additionally, all development associated with implementation of the proposed plan would be required to meet FCFD standards related to access, fire hydrants, automatic sprinkler systems, fire alarm systems, water flow, and other requirements. As applicable, F CFD would review project construction plans and inspect the construction work as it progresses to ensure that future projects in the Plan Area meet State and local Building and Fire Code requirements.

Development of new fire facilities would include construction activities that are typical of other allowable land use types within the Plan Area (e.g., industrial, retail, office), including such things as clearing and grading, utility installation, and construction of new structures. Construction would result in impacts that are similar to those discussed throughout this EIR, including temporary traffic, noise, and air quality impacts from construction. Generally, fire facilities are small (e.g., on the order of 2.5 acres) and their construction and operation would be required to comply with applicable City policies and regulatory requirements to reduce adverse environmental effects. There is no evidence to suggest that expansion of a fire station or construction of a new facility would result in unmitigable, adverse effects on the environment. Therefore, this impact would be less than significant.

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Mitigation Measures
No mitigation is required for this impact.

Impact 4.14-2: Result in Substantial Adverse Physical Impacts Associated with the Provision of New or Physically Altered Police Facilities
Development under the SCSP (e.g., industrial, retail, office uses), would result in an increased demand for law enforcement services. A new centralized police headquarters and communications center building, two new police substations, and a new 911 emergency operations dispatch center are proposed in the city, but it is not clear if these would be sufficient to meet the demand for law enforcement services associated with the proposed plan. If new or physically altered police facilities are required to adequately serve development within the Plan Area, expansion of an existing police station or construction of a new facility could involve minor land clearing, grading, installation of utilities, and building construction, generally on a modest-sized parcel. Construction activities and duration would be typical of such facilities and would be required to comply with applicable City policies and regulatory requirements to reduce adverse environmental effects. For these reasons, there is no evidence to suggest that such construction would result in unmitigable, adverse effects on the environment. Therefore, this impact would be less than significant.

Development in the Plan Area would result in approximately 12 million square feet of non-residential (industrial, retail, and office) uses and approximately 91 new residential dwelling units by 2040 (see Chapter 3, “Project Description”).

The City has established a service ratio of 1.5 unrestricted officers per 1,000 residents (General Plan Policy PU-2-g).

Residential growth in the plan area would result in a relatively small population increase (approximately 279 new residents by 2040), which would create an additional demand of less than one new officer. However, the proposed plan consists primarily of land use types other than residential uses, including industrial, retail, and office uses.

Development of such uses may also increase demand for police services due to the related increase in employment and urban activity in the Plan Area.

Similar to fire protection, funding for police protection services in the city comes from a number of different sources.

New development in the Plan Area would be required to pay development fees to assist in funding public services, including police protection services. Additionally, operation of non-residential uses such as industrial, retail, and office uses may include on-site security provisions. A new centralized police headquarters and communications center building, two new police substations, and a new 911 emergency operations dispatch center are proposed in the city (EPS 2022), but it is not clear if these would be sufficient to meet demand for law enforcement services in the Plan Area. If new or expanded facilities are necessary to provide adequate police service, development of such facilities would include construction activities that are typical of other allowable land use types within the Plan Area (e.g., industrial, retail, office), including such things as clearing and grading, utility installation, and construction of new structures. Construction would result in impacts that are similar to those discussed throughout this EIR, including temporary traffic, noise, and air quality impacts from construction. Generally, law enforcement facilities are small (e.g., less than 10,000 square feet on a parcel of 2.5 acres) and their construction and operation would be required to comply with applicable City policies and regulatory requirements to reduce adverse environmental effects. There is no evidence to suggest that expansion of a police station or construction of a new facility would result in unmitigable, adverse effects on the environment. Therefore, this impact would be less than significant.

Mitigation Measures
No mitigation is required for this impact.

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4.15 TRANSPORTATION AND CIRCULATION
This section describes applicable federal, state, and local transportation regulations and policies; discusses the existing roadway network and transportation facilities in the vicinity of the Plan Area; and evaluates the potential transportation impacts from implementation of the proposed plan. Data and analysis in this section was derived primarily from Transportation Impact Analysis: South Central Specific Plan (SCSP TIA) (TJKM 2023), which is included as Appendix D of this EIR and incorporated herein.

Pursuant to SB 743, PRC Section 21099, and CCR Section 15064.3(a), generally, vehicle miles traveled (VMT) is the most appropriate measure of transportation impacts, and a project’s effect on automobile delay shall no longer constitute a significant impact under CEQA. Therefore, the transportation analysis herein evaluates impacts using VMT and does not include level of service (LOS) analysis as it pertains to vehicle delay. Although not addressed in this EIR for purposes of CEQA, the analysis of traffic operations (i.e., intersection and freeway LOS analysis) for the proposed plan was conducted by TJKM at the direction of the City and is included in the SCSP TIA (TJKM 2023) attached as Appendix D. Additionally, PRC Section 21099(b)(3) states that “This subdivision does not relieve a public agency of the requirement to analyze a project's potentially significant transportation impacts related to air quality, noise, safety, or any other impact associated with transportation.” Therefore, impacts associated with these environmental issue areas are discussed in Sections 4.3, “Air Quality,” 4.8, “Greenhouse Gas Emissions,” 4.12, “Noise,” and 4.9, “Hazards and Hazardous Materials”. Potential impacts related to transportation safety hazards are discussed under Impact 4.15-3, below.

Comments received regarding transportation in response to the notice of preparation include safety concerns during construction and operations, road surface conditions, truck routing and traffic, and increased VMT. See Appendix A for all comments received in response to the notice of preparation.

4.15.1 Regulatory Setting

FEDERAL
Federal Highway Administration
The Federal Highway Administration (FHWA), an agency of the U.S. Department of Transportation, provides stewardship over the construction and preservation of the nation’s highways, bridges, and tunnels. FHWA also conducts research and provides technical assistance to state and local agencies to improve safety, mobility, and livability and to encourage innovation in these areas. FHWA also provides regulation and guidance related to work zone safety, mobility, and temporary traffic control device implementation.

STATE
California Department of Transportation
The California Department of Transportation (Caltrans) is the state agency responsible for the design, construction, maintenance, and operation of the California State Highway System, as well as the segments of the Interstate Highway System that lie within California. Caltrans District 6 is responsible for the operation and maintenance of State Route (SR) 99 and SR 41 in the vicinity of the Plan Area. Caltrans requires a transportation permit for any transport of heavy construction equipment or materials that necessitates the use of oversized vehicles on state highways.

The Caltrans Transportation Impact Study Guide (TISG) was prepared to provide guidance to Caltrans d istricts, lead agencies, tribal governments, developers, and consultants regarding Caltrans’ review of a land use project or plan’s transportation analysis using a VMT metric. This guidance is not binding on public agencies, and it is intended to be a reference and informational document. The TISG replaces the Guide for the Preparation of Traffic Impact Studies and is for use with local land use projects, not for transportation projects on the State Highway System (Caltrans 2020).

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Senate Bill 743
SB 743, passed in 2013, required the California Governor’s Office of Planning and Research (OPR) to develop a new guideline that addresses transportation metrics under CEQA. Enacted as part of SB 743 (2013), PRC S ection 21099(b)(1), directed OPR to prepare, develop, and transmit to the Secretary of the Natural Resources Agency for certification and adoption proposed CEQA Guidelines addressing “criteria for determining the significance of transportation impacts of projects within transit priority areas. Those criteria shall promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses. In developing the criteria, [OPR] shall recommend potential metrics to measure transportation impacts t hat may include, but are not limited to, vehicle miles traveled, vehicle miles traveled per capita, automobile trip generation rates, or automobile trips generated.”
PRC Section 21099(b)(2) further provides that “[u]pon certification of the guidelines by the Secretary of the Natural Resources Agency pursuant to this section, automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion shall not be considered a significant impact on the environment pursuant to [CEQA], except in locations specifically identified in the guidelines, if any” (emphasis added). As noted above, however, the emphasis on VMT analysis does not relieve a public agency of the requirement to analyze a project's potentially significant transportation impacts related to air quality, noise, safety, or any other impact associated with transportation (PRC Section 21099(b)(3)).

OPR published its proposal for the comprehensive updates to the CEQA Guidelines in November 2017 which included proposed updates related to analyzing transportation impacts pursuant to SB 743. The updated CEQA Guidelines were adopted on December 28, 2018; and according to the new CEQA Guidelines Section 15064.3, VMT replaced congestion as the metric for determining transportation impacts. The guidelines state that “lead agencies may elect to be governed by these provisions of this section immediately. Beginning July 1, 2020, the provisions of this section shall apply statewide.”
To provide guidance to agencies implementing the new CEQA requirements, OPR published the Technical Advisory on Evaluating Transportation Impacts in CEQA (OPR Technical Advisory) in December 2018. The OPR Technical Advisory describes considerations agencies may use in selecting VMT metrics, calculation methodologies, and significance thresholds. The OPR Technical Advisory does not mandate the use of specific metrics, methodologies, or significance thresholds, because agencies have discretion to select those that are appropriate for the local land use and transportation context (OPR 2018).

The OPR Technical Advisory also provides guidance on impacts to transit. Specifically, the OPR Technical Advisory suggests that lead agencies generally should not treat the addition of new transit users as an adverse impact. As an example, the OPR Technical Advisory suggests the following:
[An] infill development may add riders to transit systems and the additional boarding and alighting may slow transit vehicles, but it also adds destinations, improving proximity and accessibility. Such development also improves regional vehicle flow by adding less vehicle travel onto the regional network.

REGIONAL
Fresno Council of Governments
The Fresno County Council of Governments (FCOG) is a voluntary association of local governments and a regional planning agency composed of 16 member agencies, including the City of Fresno. F COG is one of 18 metropolitan planning organizations (MPOs) across California. The primary functions of FCOG involve transportation planning and programming. FCOG is responsible for developing and adopting the regional transportation plan (RTP) and sustainable communities strategy (SCS) in an effort to meet state goals t o reduce greenhouse gas emissions through coordinated land use and transportation planning.

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City of Fresno
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Regional Transportation Plan
The most recent RTP was adopted by the FCOG board of directors in July 2022. The RTP serves as a blueprint establishing long term goals and policies to meet a regional vision for the future transportation system. The SCS is a state-mandated component of the RTP which requires MPOs to determine an approach to meet greenhouse gas emission reductions through land use and transportation planning strategies. The 2022 RTP includes goals and policies streamlined to focus on five key policy areas: equity, sustainability and resiliency, infrastructure and safety, economy, and innovation (FCOG 2022).

Fresno County SB 743 Implementation Regional Guidelines The Fresno County SB 743 Implementation Regional Guidelines was developed as a guide for FCOG’s 16 member agencies choosing to establish their own VMT guidance and thresholds as appropriate for their individual jurisdictions (FCOG 2021a). The document contains recommended project screening criteria, threshold and VMT analysis for development projects, transportation projects, and land use plans, and potential mitigation strategies.

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

Fresno County Regional Active Transportation Plan
The Fresno County Regional Active Transportation Plan (ATP) was adopted in January 2018. The Fresno County ATP serves as a guide for planning and program development involving biking, walking, and other human- powered transportation in the region (FCOG 2018: ES-1). The Fresno County ATP proposed several projects to build out the active transportation network and meet regional goals to increase safety and walking and bicycling trips. The Fresno County ATP recommends specific improvements for jurisdictions without their own adopted active transportation plans and reproduces the planned bicycle and pedestrian network maps for the four jurisdictions that had already developed their own active transportation plans at the time the FCOG ATP was adopted. The City’s planned bicycle and pedestrian networks are included in Chapter 18 of the FCOG ATP .

Fresno County Regional Long-Range Transit Plan 2019-2050 The Fresno County Regional Long-Range Transit Plan (LRTP), adopted by FCOG in May 2019, is intended to guide transit and related multimodal investments and services in the Fresno region through the year 2050. The LRTP was built on the FCOG 2018 RTP and SCS and prior transit planning studies to inform the public transportation element of the RTP/SCS adopted in 2022. The LRTP seeks to integrate public transportation planning and projects into the fabric of the region’s overall circulation networks and systems – to make transit a more integral part of the community (FCOG 2019).

Fresno County Regional Safety Plan
The Fresno County Regional Safety Plan (RSP), adopted by FCOG in December 2021, sets forth a roadway safety vision for Fresno County and provides information and strategies to help FCOG and its member agencies make decisions that will improve roadway safety through projects, policies, programs, and funding decisions. The RSP formalizes safety planning for FCOG and aligns its efforts with the State of California’s Strategic Highway Safety Plan.

It was developed in partnership with FCOG member agencies through engagement with a Regional Safety Steering Committee (FCOG 2021b).

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LOCAL
City of Fresno Municipal Code
Chapter 10 of the City Municipal Code provides regulations related to Fire Prevention including the City’s adoption of the 2022 California Fire Code, which contains road design standards for fire apparatus circulation and emergency access regulations during construction. Chapter 13 addresses the general provisions for sidewalks streets, parkways, and underground utilities. Chapter 14 addresses traffic and circulation. Chapter 15 includes the citywide development code.

City of Fresno General Plan
The General Plan, adopted in December 2014, is the City’s blueprint for future growth and development. The General Plan’s Mobility and Transportation Element identifies objectives and policies to meet goals for the local transportation and circulation system (City of Fresno 2014). The following policies from the Mobility and Transportation Element pertain to the proposed plan:
 Policy MT-1-a: Transportation Planning Consistent with the General Plan. Continue to review local, regional, and inter-regional transportation plans and capital improvement plans, and advocate for the approval and funding of State highway and rail projects, consistent with the General Plan and discourage projects inconsistent with the General Plan.
 Policy MT-1-b: Circulation Plan Diagram Implementation. Design and construct planned streets and highways that complement and enhance the existing network, as well as future improvements to the network consistent with the goals, objectives and policies of the General Plan, as shown on the Circulation Diagram ( Figure MT-1), to ensure that each new and existing roadway continues to function as intended.  Policy MT-1-d: Integrate Land Use and Transportation Planning. Plan for and maintain a coordinated and well integrated land use pattern, local circulation network and transportation system that accommodates planned growth, reduces impacts on adjacent land uses, and preserves the integrity of established neighborhoods.  Policy MT-1-f: Match Travel Demand with Transportation Facilities. Designate the types and intensities of land uses at locations such that related travel demands can be accommodated by a variety of viable transportation modes and support Complete Neighborhoods while avoiding the routing of excessive or incompatible traff ic through local residential streets.
 Policy MT-1-g: Complete Streets Concept Implementation. Provide transportation facilities based upon a Complete Streets concept that facilitates the balanced use of all viable travel modes (pedestrians, bicyclists, motor vehicle and transit users), meeting the transportation needs of all ages, income groups, and abilities and providing mobility for a variety of trip purposes, while also supporting other City goals.  Policy MT-1-i: Local Street Standards. Establish and implement local roadway standards addressing characteristics such as alignment, width, continuity and traffic calming, to provide efficient neighborhood circulation; to allow convenient access by residents, visitors, and public service and safety providers; and to promote neighborhood integrity and desired quality of life by limiting intrusive pass-through traffic.  Policy MT-1-j: Transportation Improvements Consistent with Community Character. Prioritize transportation improvements that are consistent with the character of surrounding neighborhoods and supportive of safe, functional and Complete Neighborhoods; minimize negative impacts upon sensitive land uses such as residences, hospitals, schools, natural habitats, open space areas, and historic and cultural resources. In implementing this policy, the City will design improvements to:
 Facilitate provision of multi-modal transportation opportunities;  Provide added safety, including appropriate traffic calming measures;  Promote achievement of air quality standards;
 Provide capacity in a cost effective manner; and
 Create improved and equitable access with increased efficiency and connectivity.

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 Policy MT-2-a: Intensification of Bus Rapid Transit Corridors. Where traffic has previously been diverted to freeways, encourage incentives for more intense development along transportation corridors, such as the Blackstone Corridor, where there is now additional capacity.  Policy MT-2-b: Reduce Vehicle Miles Traveled and Trips. Partner with major employers and other responsible agencies, such the San Joaquin Valley Air Pollution Control District and the Fresno Council of Governments, to implement trip reduction strategies, such as eTRIP, to reduce total vehicle miles traveled and the total number of daily and peak hour vehicle trips, thereby making better use of the existing transportation system.  Policy MT-2-c: Reduce VMT through Infill Development. Provide incentives for infill development that would provide jobs and services closer to housing and multi-modal transportations corridors in order to reduce citywide vehicle miles travelled (VMT).
 Policy MT-2-d: Street Redesign where Excess Capacity Exists. Evaluate opportunities to reduce right of way and/or redesign streets to support nonautomobile travel modes along streets with excess roadway capacity where adjacent land use is not expected to change over the planning period.  Policy MT-2-e: Driveway and Access Consolidation. Take advantage of opportunities to consolidate driveways, access points, and curb cuts along designated major roadways when a change in development or a change in intensity occurs or when traffic operation or safety warrants.  Policy MT-2-i: Transportation Impact Studies. Require a Transportation Impact Study (currently named Traffic Impact Study) to assess the impacts of new development projects on existing and planned streets for projects meeting one or more of the following criteria, unless it is determined by the City Traffic Engineer that the project site and surrounding area already has appropriate multi-modal infrastructure improvements.  When a project includes a General Plan amendment that changes the General Plan Land Use Designation.  When the project will substantially change the off-site transportation system (auto, transit, bike, or pedestrian) or connection to the system, as determined by the City Traffic Engineer.  Transportation impact criteria are tiered based on a project’s location within the City’s Sphere of Influence.

This is to assist with areas being incentivized for development.  Policy MT-2-l: Region-Wide Transportation Impact Fees. Continue to support the implementation of metropolitan-wide and region-wide transportation impact fees sufficient to cover the proportional share of a development's impacts and need for a comprehensive multi-modal transportation system that is not funded by other sources. Work with the Council of Fresno County Governments, transportation agencies (e.g. , Caltrans, Federal Transportation Agency) and other jurisdictions in the region to develop a method for determining:
 Regional transportation impacts of new development;
 Regional highways, streets, rail, trails, public transportation, and goods movement system components, consistent with the General Plan, necessary to mitigate those impacts and serve projected demands;  Projected full lifetime costs of the regional transportation system components, including construction, operation, and maintenance; and
 Costs covered by established funding sources.
 Policy MT-2-m: Use VMT Analysis for CEQA. Use VMT as the criteria for evaluating transportation impacts under the CEQA, pursuant to Senate Bill 743. LOS may still be used for planning purposes and implementation of Capital Improvement Projects, however VMT shall be used for determining mitigation under CEQA beginning in July of 2020.
 Policy MT-4-b: Bikeway Improvements. Establish and implement property development standards to assure that projects adjacent to designated bikeways provide adequate right-of-way and that necessary improvements are constructed to implement the planned bikeway system shown on Figure MT-2 to provide for bikeways, to the extent feasible, when existing roadways are reconstructed; and alternative bikeway alignments or routes where inadequate right-of-way is available.

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 Policy MT-4-c: Bikeway Linkages. Provide linkages between bikeways, trails and paths, and other regional networks such as the San Joaquin River Trail and adjacent jurisdiction bicycle systems wherever possible.  Policy MT-4-d: Prioritization of Bikeway Improvements. Prioritize bikeway components that link existing separated sections of the system, or that are likely to serve the highest concentration of existing or potential cyclists, particularly in those neighborhoods with low vehicle ownership rates, or that are likely to serve destination areas with the highest demand such as schools, shopping areas, recreational and park areas, and employment centers.
 Policy MT-4-e: Minimum Bike Lane Widths. Provide not less than 10 feet of street width (five feet for each travel direction) to implement bike lanes for designated Class II bikeways along roadways. Strive for 14 feet of street width (seven feet for each travel direction) for curbside bike lanes where right-of-way is available.  Policy MT-4-f: Bike Detection Devices. Include bicycle detection devices when new intersection traffic control signals are installed and strive to retrofit existing traffic control signals to provide bicycle detection and retiming of signal phases to make them more bicycle friendly.
 Policy MT-4-g: Advocacy for Bike Accommodation. Advocate for the accommodation of bike facilities in new or upgraded State Route interchanges and railroad construction projects, and construction of bicycle crossings of freeways and railroads.
 Policy MT-4-h: Bicycle Parking Facilities. Promote the installation of bicycle locking racks and bicycle parking facilities at public buildings, transit facilities, public and private parking lots, and recreational facilities. Establish standards for bicycle parking in the Development Code.
 Policy MT-5-a: Sidewalk Development. Pursue funding and implement standards for development of sidewalks on public streets, with priority given to meeting the needs of persons with physical and vision limitations; providing safe routes to school; completing pedestrian improvements in established neighborhoods with lower vehicle ownership rates; or providing pedestrian access to public transportation routes.  Policy MT-5-b: Sidewalk Requirements. Assure adequate access for pedestrians and people with disabilities in new residential developments per adopted City policies, consistent with the California Building Code and the Americans with Disabilities Act.
 Policy MT-5-c: New Subdivision Design. Do not approve new single-family residential subdivisions with lots that front and access onto a major roadway, unless the City Traffic Engineer determines that no other feasible alternative means of vehicle access can be provided and that sufficient desi gn measures can be implemented, such as an on-site driveway turnaround, landscaped buffering, or an on-street parking lane to assure a desirable and enduring residential environment.
 Policy MT-5-d: Pedestrian Safety. Minimize vehicular and pedestrian conflicts on both major and non-roadways through implementation of traffic access design and control standards addressing street intersections, median island openings and access driveways to facilitate accessibility while reducing congestion and increasing safety.

Increase safety and accessibility for pedestrians with vision disabilities through the installation of Accessible Pedestrian Signals at signalized intersections.
 Policy MT-5-e: Traffic Management in Established Neighborhoods. Establish acceptable design and improvement standards and provide traffic planning assistance to established neighborhoods to identify practical traffic management and calming methods to enhance the pedestrian environment with costs equitably assigned to properties receiving the benefits or generating excessive vehicle traffic.  Policy MT-5-f: Modifications to Street Standards. Continue to evaluate and adopt modifications to City street standards to achieve overall objectives of providing good access and travel opportunities while calming traffic, promoting pedestrian and other transportation options, and reducing the amount of land devoted to streets.  Policy MT-6-a: Link Residences to Destinations. Design a pedestrian and bicycle path network that links residential areas with Activity Centers, such as parks and recreational facilities, educational institutions, employment centers, cultural sites, and other focal points of the city environment.

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 Policy MT-6-c: Link Paths and Trails and Recreational Facilities. Strive to provide path or trail connections to recreational facilities, including parks and community centers where appropriate, and give priority to pathway improvements within neighborhoods characterized by lower vehicle ownership rates and lower per ca pita rates of parks and public open space.
 Policy MT-6-g: Path and Trail Development. Require all projects to incorporate planned multi-purpose path and trail development standards and corridor linkages consistent with the General Plan, applicable law and case -by- case determinations as a condition of project approval.  Policy MT-6-i: Path and Trail Design Standards. Designate and design paths and trails in accordance with design standards established by the City that give consideration to all path and trail users (consistent with design, terrain and habitat limitations) and provide for appropriate widths, surfacing, drainage, design speed, barriers, fences, signage, visibility, intersections, bridges, and street cleaning.  Policy MT-6-j: Variety in Path and Trail Design. Provide for different levels and types of usable pedestrian and bicycle corridors, including broad, shaded sidewalks; jogging paths; paved and all terrain bicycle paths; through block passageways; and hiking trails. Where a designated multipurpose path route is adjacent to a public right - of-way which accommodates bike lane, allow for flexibility in path design, so that bike lanes may be substituted for the bicycle component of the multipurpose path where it is safe and appropriate to do so.  Policy MT-6-k: Path and Trail Buffers. Use landscaping with appropriate and adequate physical and visual barriers (e.g., masonry walls, wrought iron, or square-tube fencing) to screen path and trail rights-of ways and separate paths and trails from mining operations, drainage facilities, and similar locations as warranted.  Policy MT-6-l: Environmentally Sensitive Path and Trail Design. Develop paths and trails with minimum environmental impact by taking the following actions:
 Surface paths and trails with materials that are conducive to maintenance and safe travel, choosing materials that blend in with the surrounding area;
 Design paths and trails to follow contour lines where the least amount of grading (fewest cuts and fills) and least disturbance of the surrounding habitat will occur;  Beautify path and trail rights-of-way in a manner consistent with intended use, safety, and maintenance;  Use landscaping to stabilize slopes, create physical or visual barriers, and provide shaded areas; and  Preserve and incorporate native plant species into the landscaping.  Policy MT-6-m: Path and Trail Crossings. Limit vehicle access, to the extent feasible, where paths or trails are designated parallel and adjacent to roadways, with consideration given to other transportation, land use, and site design priorities and constraints.
 Policy MT-6-n: Emergency Vehicle Access along Paths and Trails. Provide points of emergency vehicle access within the path and trail corridors, via parking areas, service roads, emergency access gates in fencing, and firebreaks.
 Policy MT-8-b: Transit Serving Residential and Employment Nodes. Identify the location of current and future residential and employment concentrations and Activity Centers throughout the transit service area in order to facilitate planning and implementation of optimal transit services for these uses. Work with Califor nia State University, Fresno to determine locations within the campus core for bus stops.  Policy MT-8-c: New Development Facilitating Transit. Continue to review development proposals in transportation corridors to ensure they are designed to facilitate transit. Coordinate all projects that have residential or employment densities suitable for transit services, so they are located along existing or planned transit corridors or that otherwise have the potential for transit orientation to FAX, and consider FAX’s comments in decision-making.

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City of Fresno CEQA Guidelines for Vehicle Miles Traveled Thresholds In 2020, City Council adopted the City of Fresno CEQA Guidelines for VMT Thresholds. The CEQA Guidelines for VMT Thresholds was developed to provide guidance for analyzing transportation impacts of proposed projects to comply with CEQA pursuant to SB 743 as well as to ensure alignment with local policies and regulations established in the General Plan (City of Fresno 2020). This document serves as a detailed guideline for preparing VMT analysis for development projects, transportation projects, and plans consistent with SB 743 requirements.

City of Fresno Active Transportation Plan
The City of Fresno’s ATP, adopted in March 2017, provides a comprehensive guide outlining the vision for active transportation in the City. The plan lays out the following goals to improve bicycle access and connectivity in Fresno:
 Equitably improve the safety and perceived safety of walking and bicycling in Fresno;  Increase walking and bicycling trips in Fresno by creating user-friendly facilities;  Improve the geographical equity of access to walking and bicycling facilities in Fresno; and  Fill key gaps in Fresno’s walking and bicycling networks (City of Fresno 2016).

Complete Streets Policy
The City’s Complete Streets Policy was adopted by the City Council on October 10, 2019, to guide the implementation of the City’s complete streets and multimodal objectives and policies within the Fresno General Plan. The Complete Streets policy aids the planning, design, and construction of transportation facilities that balance safety, access, and mobility for users of all abilities and ages (City of Fresno 2019a). The City has integrated complete streets designs into its policies in compliance with AB 1358.

City of Fresno Public Works Department Policies and Procedures Policy 210.01, “Traffic Control Policies and Procedures,” was issued in June 2019 to govern the preparation and submittal of a temporary traffic control plan (TCP). This policy was enacted to ensure consistent and efficient submittal and review of TCPs and ensure that they are prepared and submitted in accordance with the current edition of the California Manual on Uniform Traffic Control Devices, the City of Fresno Standard Specifications, and City of Fresno Policies (City of Fresno 2019b).

Policy number 210.1, “Conditions for Roadway Closures and Lane Closures,” was issued in March 2019 to govern the issuance of Street Work and TCPs to close roadways to through traffic or close travel lanes on roadways within the City of Fresno. This policy was enacted pursuant to Article 2 of Chapter 13 of the Fresno Municipal Code which requires applicants seeking to encroach upon, or work within, a public right-of-way to first obtain a permit from the Director of Public Works and comply with the applicable terms, conditions, and restrictions (City of Fresno 2019c).

City of Fresno Systemic Local Roadway Safety Plan
The City of Fresno adopted the Systemic Local Roadway Safety Plan in September 2020. Kittelson & Associates, Inc., Toole Design Group, and JLB Traffic Engineering, Inc. worked with the City to analyze transportation safety data and identify roadway improvements to reduce collision risk in the city (City of Fresno 2020). The Systemic Local Roadway Safety Plan identifies citywide collision patterns and trends, including risks to bicyclists and pedestrians, and presents engineering safety countermeasures identified to address the systemic collision trends.

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4.15.2 Environmental Setting

ROADWAY SYSTEM
The roadway system in the City is made up of freeways, expressways, superarterials, arterials, collectors, local streets, and drives. A description of each is provided below.

Freeway
Freeways are multiple-lane divided (median island separation) roadways on adopted state route alignments servicing through and crosstown traffic, with no access to abutting property and no at -grade intersections. They are under the jurisdiction of the state, and outside the control of the City. In the Plan Area, SR 99, also known as Golden State Highway, is a north-south freeway traversing the Central Valley. SR 99 connects to Interstate 5 near Wheeler Ridge to the south and ends at SR 36 near Red Bluff to the north. In the City of Fresno, SR 99 has six lanes. Additionally, SR 41 is a northeast-southwest freeway that traverses the Plan Area. SR 41 connects the Central Coast on the south end to the San Joaquin Valley and the Sierra Nevada in the north. In the vicinity of the Plan Area, SR 41 has two to four lanes in each direction of travel.

Expressway
Expressways are four- to six-lane divided (median island separation) roadways primarily serving through and crosstown vehicle traffic, with at-grade major street intersections located at approximately one-half mile intervals and no driveways for direct motor vehicle access to abutting property.

Superarterial
Superarterials are four- to six-lane divided (median island separation) roadways with a primary purpose of moving multiple modes of travel traffic to and from major traffic generators and among subregions. A select number of motor vehicle access points to adjacent properties or local streets between the major street intersections may be approved by the City. Access points will be limited to right-turn entrance and exit vehicular movements, as well as select left-turn partial openings in medians from the superarterials to surrounding properties or neighborhoods, limited to one location per half-mile. No left turns are allowed out of local streets or properties.

Arterial
Arterials are four- to six-lane divided (median island separation) roadways with somewhat limited motor vehicle access to abutting properties, and with the primary purpose of moving traffic within and between neighborhoods and to and from freeways and expressways. In addition to major street intersections, appropriately designed and spaced local street intersections may allow left-turn movements to and from the arterial streets.

Collector
Collectors are two- to four-lane undivided (opposing travel lanes generally not separated by a median island) roadways, with the primary function of connecting local streets and arterials and neighborhood traffic generators and providing access to abutting properties. Local street intersections and motor vehicle access points from abutting properties are allowed consistent with the City’s engineering standards and accepted traffic engineering practices.

Collectors typically have a center two-way left-turn lane.

Local
Local roads are two- to three-lane roadways designed to provide direct access to properties, while discouraging excessive speeds and volumes of motor vehicle travel incompatible with neighborhoods being served through the implementation of multiple, well-connected routes and traffic calming measures. The alignments of future local streets are typically not specified by the General Plan Circulation Diagram, but existing local streets may be depicted for informational purposes. In specific circumstances, local streets are designated where necessary to assure adequate access and implementation of Complete Neighborhoods with well-connected routes for motor vehicle, bicycle and pedestrian travel.

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Drive
A drive is a street that in addition to its transportation function provides opportunities for the enjoyment of natural and human-made scenic resources. The aesthetic values of scenic drives may be protected.

Regional access to the Plan Area is generally provided by SR 99 and SR 41. Local access to and within the Plan Area is provided by various arterials and connectors. Relevant roadways in the vicinity of the Plan Area are discussed below:
 SR 99 is a six-lane freeway that runs from the northern end of the Plan Area at Church Avenue to the southern end at Central Avenue. It is the main thoroughfare for the Central Valley region and has high volumes of passenger vehicles and truck traffic. The posted speed limit is 65 miles per hour (mph).  SR 41 is a four-lane freeway that runs on the western portion of the Plan Area from Church Avenue to Central Avenue. It connects SR 99, near downtown Fresno, to the Pacific Ocean at Morro Bay. The posted speed limit is 65 mph in the Plan Area.
 Church Avenue is a two- to four-lane, east-west collector. The roadway runs through the northern portion of the Plan Area and has a posted speed limit of 45 mph.
 Jensen Avenue is a two- to six-lane roadway that runs east-west. The roadway is classified as an arterial west of SR 99 and as a super arterial east of SR 99. The speed limit along the roadway ranges from 40 mph to 55 mph within the Plan Area.
 Annadale Avenue is a two-lane, east-west collector in the center of the Plan Area. It has a posted speed limit of 40 mph.
 North Avenue is a four-lane, east-west arterial running through the center of the Plan Area and has an interchange junction with SR 99. It has a speed limit of 45 mph within the P lan Area.  Central Avenue is a two-lane, east-west arterial on the south end of the Plan Area and has an interchange junction with SR 99. It has a posted speed limit of 45 mph within the Plan Area.  American Avenue is a two-lane, east-west arterial on the southern border of the Plan Area with an interchange to SR 99. It has a speed limit of 45 mph.
 Fig Avenue/Martin Luther King Jr. Boulevard is a two-lane, north-south collector that runs on the western border of the Plan Area. It has a posted speed limit of 40 mph.  Elm Avenue is a four-lane arterial that runs north-south on the western portion of the Plan Area. It has a posted speed limit of 45 mph.
 Cherry Avenue is a two-lane, north-south collector that goes through the center of the Plan Area. It has a speed limit of 45 mph within the Plan Area.
 East Avenue is a two-lane, north-south collector that goes through the center of the Plan Area. It has a two-way left-turn lane south of North Avenue. It is truncated by SR 99 at its northern end. It has a speed limit of 45 mph within the Plan Area.
 Orange Avenue is a two-lane, north-south arterial that goes through the center of the Plan Area. It connects Central Avenue and North Avenue near SR 99. It has a two-way left-turn lane between Central and North. It has a speed limit of 45 mph within the Plan Area.
 Cedar Avenue is a two-lane, north-south arterial that has an interchange with SR 99 in the center of the Plan Area. It has a speed limit of 45 mph within the Plan Area.  Maple Avenue is a four-lane, north-south collector that has two sections, north of SR 99 and south of SR 99. It has a speed limit of 45 mph within the Plan Area.
 Chestnut Avenue is a two-lane, north-south collector on the eastern portion of the Plan Area. It has a speed limit of 45 mph within the Plan Area.
 Willow Avenue is a two-lane, north-south collector in the central portion of the Plan Area. It has a speed limit of 45 mph within the Plan Area.

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 Peach Avenue is a two-lane, north-south collector in the eastern portion of the Plan Area. It has a speed limit of 45 mph within the Plan Area.

TRANSIT SYSTEM
Public transportation in the City consists of public buses, express bus service, demand-response paratransit, and passenger rail. Fresno Area Express (FAX) is the principal transit provider in the C ity operated by the Fresno Department of Transportation. FAX operates 18 routes with a fleet of over 100 buses. Handy Ride is a demand - response service for seniors and persons with disabilities, as required by the Americans with Disabilities Act. FAX is the largest transit provider in the region with over 10 million annual boardings (FCOG 2019: 21).

FAX bus Routes 32 (North Avenue), 38 (Jensen Avenue), and 41 (Maple and North Avenues) are located immediately adjacent to and within the Plan Area. Bus Route 32 service frequency is approximately every 30 minutes between 5:45 a.m. and 11:20 p.m. on weekdays, 6:45 a.m. and 11:20 p.m. on Saturdays, and 6:45 a.m. and 7:30 p.m. on Sundays. Bus Route 38 operates on approximately 15-minute headways from 5:30 a.m. to 6:00 P.M. and at 30-minute headways from 6:00 p.m. to 12:00 a.m. on weekdays and 6:40 a.m. and 7:20 p.m. on weekends, with extended service on Saturday nights until approximately 12:00 a.m. Bus Route 41 runs between approximately 5:40 a.m. and 9:15 p.m. on weekdays and 7:00 a.m. and 7:30 p.m. on the weekends with 30-minute headways.

The Fresno County Rural Transit Agency (FCRTA) and Amtrak also provide services for regional travel outside the Fresno-Clovis Metropolitan Area. FCRTA provides service to 13 rural incorporated cities as well as 28 unincorporated rural communities within Fresno County. The San Joaquin Line is one of Amtrak’s passenger rail services with connections between the San Joaquin Valley, Sacramento Valley, San Francisco Bay Area, and Los Angeles.

Greyhound provides similar bus service to these regions. BNSF, Union Pacific, and spur rail lines serve industrial uses in the area.

Additionally, a portion of the future California High-Speed Rail (HSR) line runs through the Plan Area. There is a planned HSR stop in Downtown Fresno, just north of the Plan Area.

In addition to services offered by FAX, Fresno County voters passed the Measure C one -half-cent transportation sales tax in November 2006, providing the resources needed to create the Measure C Carpool Incentive program and Measure C Commuter Vanpool Subsidy Program. These programs were created to encourage commuters to share a ride with other commuters rather than drive alone. The program is open to c arpool and vanpool participants who rideshare to or from locations throughout Fresno County and who are 18 years old or older. Employers are also able to partner with existing programs to comply with the eTRIP Rule that was adopted by the San Joaquin Valley Air Pollution District to reduce VMT from private vehicles used by employees commuting to and from work. The trip reduction and administrative requirements of this rule apply to each employer in the San Joaquin Valley Air Basin with at least 100 eligible employees.

BICYCLE SYSTEM
The bicycle and pedestrian transportation system in the City of Fresno is composed of bikeways and trails. The C ity is generally flat, which provides a favorable environment for bicycling and walking as a mode of transportation. The General Plan classifies bicycle facilities into the following four types:
 Class I Bikeway (Bike Path): Bike paths, often referred to as shared-use paths or trails, are off-street facilities that provide exclusive use for non-motorized travel, including bicyclists and pedestrians. Bike paths have minimal cross flow with motorists and are typically located along landscaped corridors.  Class II Bikeway (Bike Lane): Class II bike lanes are on-street facilities that use striping, stencils, and signage to denote preferential or exclusive use by bicyclists. On-street bikes lanes are located adjacent to motor vehicle traffic. Bike lanes are intended to alert drivers about the predictable movements of bicyclists and provide adequate space for comfortable riding. Current City standards require bike lanes on all new collectors and arterials; many existing collectors are already constructed with Class II bike lanes.

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 Class III Bikeway (Bike Route): Class III bike routes are on-street pavement markings or signage that connect the bicycle roadway network. Class III bike routes can be utilized to connect bicycle lanes or paths along corridors that do not provide enough space for dedicated lanes on low-speed and low-volume streets. Shoulders are useful but not required on streets with Class III bike routes.  Class IV Bikeways (Separated Bikeways): Class IV separated bikeways, commonly known as “cycle tracks,” are physically separated bicycle facilities that are distinct from the sidewalk and designed for exclusive use by bicyclists. They are located within the street right-of-way, but provide similar comfort when compared to Class I multi-use paths. The key feature of a separated bikeway is a vertical element that provides further separation from motor vehicle traffic (City of Fresno 2016).

As of 2016, the City’s bicycle system was composed of 38 miles of Class I, 431 miles of Class II, and 22 miles of Class III bicycle facilities (City of Fresno 2016: 61). The Plan Area contains only Class III facilities, and these are on portions of Church Avenue, Jensen Avenue, Elm Avenue, Cherry Avenue, East Avenue, and North Avenue. No other facilities are present in the vicinity of the Plan Area.

PEDESTRIAN SYSTEM
Pedestrian facilities are comprised of crosswalks, sidewalks, pedestrian signals, and off-street paths, which provide safe and convenient routes for pedestrians to access the destinations such as institutions, businesses, public transportation, and recreation facilities.

As of 2016, the City of Fresno pedestrian system consisted of 1,984 miles of sidewalks (City of Fresno 2016). The Plan Area is located in a rural area, thus, there are currently very limited pedestrian facilities in the vicinity of the project site. Sidewalks do exist on portions of East Avenue, North Avenue, Central Avenue, Church Avenue, and Jensen Avenue but are disconnected from one another or are disjointed (TJKM 2023).

4.15.3 Environmental Impacts and Mitigation Measures

METHODOLOGY
State CEQA Guidelines Section 15064.3 was added December 28, 2018, to address the determination of significance for transportation impacts. The guideline s require that , beginning July 1, 2020, CEQA analyses and significance determinations be based on VMT instead of congestion metrics, such as LOS. The change in the focus of transportation analysis is the result of legislation (SB 743) and is intended to shift the emphasis from congestion to, among other things, reducing greenhouse gas emissions, promoting a diversity of land uses, and developing multimodal transportation networks.

The City has developed and adopted VMT guidelines and thresholds (i.e., CEQA Guidelines for VMT Thresholds) to meet the State requirements set by SB 743 and address CEQA Guidelines Section 15064.3. Therefore, the VMT analysis herein relies primarily on the City’s VMT guidance and CEQA Guidelines Section 15064.3.

The City’s recommended methodology for conducting VMT assessments for land use plans is to compare the existing VMT per capita and/or VMT per employee for the region with the expected horizon year VMT per capita and/or VMT per employee for the land use plan. If there is a net increase in VMT under horizon year conditions, then the project would result in a significant impact (City of Fresno 2020: 38). The SCSP TIA analyzing potential impacts to the transportation system was prepared by TJKM, which used the FCOG Activity-Based Model (ABM) for travel demand forecasting and VMT analysis. The FCOG ABM simulates the County’s population, based on detailed census data, and models the daily activity patterns of each simulated individual along with resulting travel demand. The Fresno ABM has a base year of 2015 and a forecast year of 2035, and the count data collected from the City’s count database is from 2018.

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Additionally, the loaded network volumes from the FCOG ABM include trucks as part of the calculation in the form of passenger car equivalents (PCE) based on truck weight and class to account for the increase in heavy vehicle trips anticipated by the development of predominately industrial uses that would be implemented by the proposed plan.

See Appendix D for a detailed description of the SCSP TIA methodology, including the FCOG ABM.

THRESHOLDS OF SIGNIFICANCE
The significance criteria used to evaluate the impacts of the proposed plan on 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. An impact on the transportation system would be significant if implementation of the proposed plan would:
 conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities;
 conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b);  substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); or
 result in inadequate emergency access.

PROPOSED SCSP POLICIES AND DEVELOPMENT STANDARDS
The following policies are relevant to transportation:
 T-1: Establish and enforce truck routes to avoid neighborhoods and consider existing roadway capacities and conditions.
 T-2: Ensure truck routes are safe for pedestrians and bicyclists.  T-3: Limit truck idling times.
 T-4: Expand bus area service and frequency.
 T-5: Provide van shuttles, transit and carpool incentives, and bicycle parking for employees.  T-6: Help school districts implement a “safe routes to school” program.  T-7: Build, repair and maintain roads in good condition.  T-8: Consider traffic calming studies.
 T-9: Install traffic control or traffic safety measures to include bike lanes.  T-10: Install street lighting for public safety and visibility.  T-11: Install crosswalks and traffic calming measures near schools.  T-12: Consider a funding mechanism to pre-fund infrastructure improvements prior to allowing development to occur.
 T-13: Improve and maintain sidewalks.

In addition, the SCSP includes transportation related development standards that would serve to reduce circulation and safety hazards within the Plan Area. These include locating loading docks, truck entries and drive aisles away from nearby sensitive receptors; verifying safe truck turning movements at entrance and exit driveways; and establishing a truck route plan that includes measures such as signage, pavement markings, and queuing analyses and enforcement to prevent truck queuing, circling, stopping, and parking on public streets.

ISSUES NOT DISCUSSED FURTHER
All the issues identified in the thresholds of significance are addressed in the following analysis.

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ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
Impact 4.15-1: Conflict with a Program, Plan, Ordinance, or Policy Addressing the Circulation System, Including Transit, Roadway, Bicycle, and Pedestrian Facilities The proposed plan is estimated to result in the future development of approximately 12 million square feet (sf) of non-residential (industrial, retail, and office) uses and approximately 91 new residential dwelling units by 2040 . While no specific developments are currently proposed, individual projects would be reviewed for consisten cy with the City’s General Plan, ATP, and Municipal Code, and requirements established within those regulatory documents would be implemented, as applicable. Proposed SCSP policies would encourage the construction of bicycle and pedestrian safety improvements and transportation demand management strategies for employees to support the use of alternative modes of transportation. There is no evidence to suggest that the SCSP or future development under the plan would conflict with any applicable program, plan, ordinance, or policy addressing the circulation system. The impact would be less than significant.

Implementation of the proposed plan would result in the development of predominantly industrial uses as well as moderate retail, office, and minor residential uses. The City of Fresno’s circulation system is guided by the City’s General Plan, ATP, and FCOG’s RTP as detailed above in the Methodology section.

The City’s ATP identifies planning goals aimed at improving pedestrian and bikeway connectivity and continuity throughout the City through design, community resources, and plan support. The ATP details principles for prioritizing projects based on several criteria including proximity to key destinations, population and employee density, level of traffic stress, and most frequent locations of vehicle-bicycle collision. Additionally, the Mobility and Transportation Element of the General Plan identifies various policies to encourage the use and increase the safety of bicycle, pedestrian, and transit facilities. General Plan Policies MT-1-a and MT-1-b call for the implementation of transportation improvements that are consistent with the goals, objectives, and policies of the General Plan and discourage those that are not.

Development under the proposed plan and their associated transportation improvements would be required to comply with regional and local programs, policies, and plans to maintain existing and accommodate planned alternative transportation facilities within the Plan Area. For example, development under the plan would be required to be consistent with General Plan policies that address transit, roadway, bicycle, and pedestrian travel. As detailed in Chapter 2, “Project Description,” implementation of the proposed plan would be consistent with other Citywide efforts to enhance the environment for alternative modes of transportation including the Complete Streets Policy, Safe Routes to Schools programs, planned transit routes, participation in transportation demand management programs, and bicycle and pedestrian improvements identified in the ATP . Additionally, individual developments would be required to provide bicycle parking and amenities as detailed in Section 15-2429 of the City Municipal Code. Development associated with the implementation of the proposed plan may increase circulation activity of all types in the Plan Area, including from employment opportunities and residences, thus, increasing the demand for transit, bicycle, and pedestrian facilities. However, as detailed in the Regulatory Setting section, above, the OPR Technical Advisory suggests that lead agencies generally should not treat the addition of new transit users as an adverse impact as infill development improves proximity and accessibility to destinations. The proposed plan includes policies which would enhance transit, bicycle, and pedestrian travel in a manner which is consistent with the goals and policies established in the City’s General Plan and Active Transportation Plan. Proposed plan policies T-2, T-6, T- 7, T-8, T-9, T-11, and T-13 would promote the safe movement of bicyclists and pedestrians, and policies T-4 and T-5 would encourage increased use of transit and decreased use of single occupancy vehicle s through expanded bus service and transportation demand management strategies, respectively.

Implementation of the proposed plan would improve the existing bicycle and pedestrian circulation infrastructure in the Plan Area over time by requiring future development to provide multimodal circulation improvements in compliance with General Plan and ATP policies and recommendations. Additionally, individual development projects and transportation improvements would not damage or alter any existing facilities serving alternative modes of Ascent Environmental Transportation and Circulation
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transportation. Therefore, the proposed plan would not conflict with a program, plan, ordinance, or policy addressing bicycle, pedestrian, or transit facilities. This impact would be less than significant.

Mitigation Measures
No mitigation is required for this impact.

Impact 4.15-2: Conflict or Be Inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b) Regarding Vehicle Miles Traveled
The proposed plan would substantially increase industrial uses within the Plan Area and some commercial and minor residential development. The industrial and commercial uses would increase employment opportunities, likely improving proximity between new jobs within the Plan Area and surrounding housing by reducing commute distances between them. The SCSP TIA found that under horizon year with project conditions, the proposed plan would result in a VMT per service population of 29.87 as compared to 44.88 VMT per service population under existing conditions. Because the proposed plan would result in a 33 percent decrease in VMT, the proposed plan would not conflict or be inconsistent with CEQA Guidelines Section 15064.3. The impact would be less than significant.

As detailed in Chapter 2, “Project Description,” implementation of the proposed plan would facilitate opportunities for economic growth and job creation and promote development of underutilized lands within the P lan Area. While total development of the Plan Area would not change substantially from what would occur under the City’s General Plan, the proposed plan would alter land uses in portions of the Plan Area, generally resulting in less acreage of heavy industrial uses and more acreage of commercial and residential uses. See Table 3-4 in Section 3, “Project Description,” for assumed development under the proposed plan compared to existing conditions.

This analysis is based on the findings of the SCSP TIA prepared by TJKM in August 2023, which evaluates and compares the VMT effects of the proposed plan to the existing VMT per service population and to the 2035 VMT per service population without the project. The SCSP TIA is included as Appendix D and provides additional detailed data, modeling, and information related to the VMT analysis.

The FCOG ABM was used to forecast the change in trip generation and VMT associated with buildout of the P lan Area, and to estimate existing and horizon year average VMT per service population for the Plan Area. The number of dwelling units and employment for the Plan Area were calculated for the horizon year and used to run a population synthesizer to generate land use input files for running the activity-based model. These land use input files were then run through the ABM to develop horizon year (2035) forecasts with the buildout of the Plan Area. Although the planning horizon year for the SCSP is 2040, the Fresno ABM has been calibrated and validated for 2035 and not 2040; therefore, the SCSP TIA used the latest available version of the Fresno ABM. While these horizon years differ, i t is reasonable to infer that an additional 5 years of development in the Plan Area (i.e., 2035 to 2040) could further reduce VMT because additional development with the potential to reduce employment commute distances would occur over that period.

Table 4.15-1 presents VMT per service population findings for 2015 existing conditions, 2035 no project conditions, and 2035 with project conditions. Based on the City of Fresno VMT Guidelines, a land use plan would have a significant impact if the VMT per service population of the Plan Area exceeded the same metrics for existing conditions in all of Fresno County.

Table 4.15-1 SCSP VMT Analysis
VMT per Service Population
2015 Existing Conditions 44.88
2035 No Project 46.44
2035 With Project 29.87
Source: TJKM 2023.

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As detailed in Table 4.15-1, the project is anticipated to generate 29.87 VMT per service population, a decrease from both 2015 existing conditions and 2035 no project conditions. Under the 2035 proposed plan scenario, VMT per service population would be approximately 15 VMT per service population lower, or 33 percent lower, than 2015 existing conditions. The decrease in VMT is partially the result of the proposed land use mix within the Plan Area, but is also affected by the fact that the Plan Area would be a major employment center. Although the proposed plan would only increase residential uses by 91 dwelling units, it would create increased employment opportunities through the implementation of industrial and commercial development leading to improved proximity between the jobs in the Plan Area and surrounding housing by shortening driving distance and, therefore, reducing VMT.

Additionally, as described in the discussion of Impact 4.15-1, the proposed plan would be required to be consistent with the General Plan policies that address transit, roadway, bicycle, and pedestrian travel which could help reduce VMT. Furthermore, the proposed plan contains policies that would encourage increased use of alternative modes of transportation (i.e., proposed plan policies T-2, T-4 through T-11, and T-13).

As detailed above, the City of Fresno CEQA Guidelines for VMT Thresholds states that a net increase in VMT under horizon year conditions as compared to existing conditions would result in a significant impact for land use plans (City of Fresno 2020: 38). Because implementation of development under the plan would result in reduced VMT per service population than existing conditions or future conditions without the project, the SCSP would neither conflict nor be inconsistent with CEQA Guidelines Section 15064.3. This impact would be less than significant.

Mitigation Measures
No mitigation is required for this impact.

Impact 4.15-3: Substantially Increase Hazards Due to a Geometric Design Feature (e.g., Sharp Curves or Dangerous Intersections) or Incompatible Uses (e.g., Farm Equipment) Although the nature and location of specific development projects under the proposed plan cannot be known, the plan would substantially increase industrial uses in the Plan Area and implement commercial and minor residential development. Thus, the industrial and other uses would substantially increase traffic, including truck traffic, in the Plan Area. Subsequent projects under the plan would be required to comply with all applicable design standards and would be subject to review by City staff to ensure these requirements are met. Individual project contractors would be required to develop and implement a TCP in accordance with policy 210.01 (“Traffic Control Policies and Procedures”) of the City of Fresno Public Works Department Policies and Procedures to minimize hazards during construction. Chapter 5 of the SCSP identifies development standards with which individual projects would be required to comply. These include provisions for truck routing, parking, and internal project site signage and wayfinding. Finally, the City is engaged in a truck reroute study for the portion of Fresno subject to AB 617, which includes the Plan Area. The study is designed to address, among other things, truck transportation conflicts, accidents, and residential and school impacts. With implementation of existing requirements, there is no evidence to suggest that implementation of the proposed plan would substantially increase transportation hazards from design features or incompatible uses. While the truck reroute study is not yet complete, it is anticipated that its recommendations will be implemented by the City and would further reduce the potential for such hazards. This impact would be
less than significant.

Construction
Construction of future developments in the Plan Area would require use of trucks and heavy equipment and generate other vehicle trips from workers traveling to and from work sites. Depending on the scale and location of construction activities and the proximity and number of sites under construction at one time, Plan Area roadways could be disrupted and introduce sources of hazard. However, construction transportation impacts, including hazards, would be localized and temporary, and construction associated with the implementation of proposed plan developments would be required to comply with City standards and regulations, including protocols that address safety and minimize traffic disturbance during construction activities.

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Before construction of an individual project, the project contractor would be required to obtain a Street Work Permit to allow any construction work within a public right-of-way. A TCP would be prepared by the contractor in accordance with policy number 210.01 (“Traffic Control Policies and Procedures”) of the City of Fresno Public Works Department Policies and Procedures. The TCP would demonstrate appropriate traffic handling during construction activities for all work that could impact the traveling public. Additionally, if off-site construction activities necessitate travel lane closures, each project would be required to follow protocol as described in policy number 210.1 (“Conditions for Roadway Closures and Lane Closures”) in the City of Fresno Public Works Department Policies and Procedures. Therefore, implementation of the proposed plan would not result in substantial increases in transportation hazards during construction.

Operations
The City of Fresno has well-established roadway and site design standards that guide the design and construction of transportation facilities to minimize design hazards for all users of the circulation system. City policies require evaluation of safety conditions as part of the project review process. Therefore, individual projects developed under the proposed plan would be subject to City of Fresno review processes which would require that that the project design comply with all applicable City and industry roadway/driveway design standards, such as driver sight distance requirements. As needed, improvements to meet safety standards are identified by the City and required as part of project approval.

The Traffic Planning Section of the City’s Planning and Development Department provides Conditions of Approval, site plan review, and design guidelines for development projects. Projects developed under plan would be required to meet all applicable regulations within the City Municipal Code, including those in Chapter 13 for off-site roadway, intersection, and sidewalk improvements. On-site design would comply with the circulation and safety standards as detailed in Chapter 15 of the City of Fresno Municipal Code (Section 15-2423). Additionally, roadway improvements would be required to meet design guidelines such as the accessibility requirements of Title 24 (California Building Code), Americans with Disabilities Act standards, California Manual on Uniform Traffic Control Devices, and the Caltrans Roadway Design Manual.

Although individual development projects would be required to comply with the standards and regulations detailed above, the proposed plan could result in increased transportation safety hazards. Project-generated vehicles and trucks, including heavy trucks, would use local roadways to access development sites and regional transportation facilities such as SR 99 and SR 41, railways, or other destinations within and beyond the Plan Area during operation.

Substantial vehicle and heavy truck traffic could increase safety hazards for other vehicles, bicycles, and pedestrians, particularly through residential communities including rural residential, low, and medium residential neighborhoods.

Currently, many roadways within the Plan Area are relatively narrow, lack pedestrian facilities, and are not suitable for the type of vehicles that would be used to transport goods and equipment to and from the Plan Area.

As described in Impacts 4.15-1 and 4.15-2, consistency with the City’s General Plan policies would be required, and policies T-1, T-2, T-7 through 11, and T-13 of the SCSP are intended to preclude transportation hazards. Policies T-1 and T-2 would be implemented by the City’s Public Works Department through the South Central Fresno AB 617 Community Truck Reroute Study. Policy outcomes and recommendations that result from the truck reroute study shall be adopted by reference in the SCSP. Additionally, the City Public Works Department and subsequent developments within the SCSP would implement policies T-7 through T-11 and T-13. These policies would be addressed as new land is annexed into the city, new development is proposed within the Plan Area, funding is sought/granted, and ATP and Complete Streets Policy improvements are implemented. Repair and maintenance of roads will occur on a life-cycle basis and as funding is available.

Chapter 5 of the proposed plan also establishes development standards with which each individual project would be required to comply. Following the adoption of the proposed plan, the City’s Development Code would be amended to include the following standards related to transportation safety:
 Unless physically impossible, loading docks and truck entries shall be oriented away from abutting sensitive receptors.

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 To the greatest extent feasible, loading docks, truck entries, and truck drive aisles shall be located away from nearby sensitive receptors. In making feasibility decisions, the City must comply with existing laws and regulations and balance public safety and the site development’s potential impacts to nearby sensitive receptors. Therefore, loading docks, truck entries, and drive aisles may be located near sensitive receptors at the discretion of the Planning Director, but any such site design shall include measures designed to minimize overall impacts to nearby sensitive receptors.
 For any warehouse building larger than 400,000 square feet in size, the building’s loading docks shall be located a minimum of 300 feet away, measured from the property line of the sensitive receptor to the nearest dock door which does not exclusively serve electric trucks, using a direct straight-line method.  Entry gates into the loading dock/truck court area shall be positioned after a minimum of 140 feet of total available stacking depth inside the property line. The stacking distance shall be increased by 70 feet for every 20 loading docks beyond 50 docks. Queuing, or circling of vehicles, on public streets immediately pre- or post-entry to an industrial commerce facility is strictly prohibited unless queuing occurs in a deceleration lane or right turn lane exclusively serving the facility.
 Applicants shall obtain approval of all turning templates to verify truck turning movements at entrance and exit driveways and street intersection adjacent to industrial buildings prior to entitlement approval.  Prior to issuance of certificate of occupancy, facility operators shall establish and submit for approval a Truck Routing Plan to and from the State Highway System based on the City’s latest Truck Route Map.  The plan shall describe the operational characteristics of the use of the facility operator, including, but not limited to, hours of operations, types of items to be stored within the building, and proposed truck routing to and from the facility to designated truck routes that avoids passing sensitive receptors, to the greatest extent possible.
 The plan shall include measures, such as signage and pavement markings, queuing analysis and enforcement, for preventing truck queuing, circling, stopping, and parking on public streets.  The facility operator shall be responsible for enforcement of the plan.  A revised plan shall be submitted prior to a business license being issued by the City for any new tenant of the property.
 The Planning Director shall have discretion to determine if changes to the plan are necessary, including any additional measures to alleviate truck routing and parking issues that may arise during the life of the facility.  Signs and drive aisle pavement markings shall clearly identify the onsite circulation pattern to minimize unnecessary on-site vehicular travel.
 Facility operators shall post signs in prominent locations inside and outside of the building indicating that off -site parking for any employee, truck, or other operation related vehicle is strictly prohibited. The City may require facility operators to post signs on residential streets indicating that off-site truck parking is prohibited.  Signs shall be installed at all truck exit driveways directing truck drivers to the truck route as indicated in the Truck Routing Plan and State Highway System.
 Signs shall be installed in public view with contact information for a local designated representative who works for the facility operator and who is designated to receive complaints about excessive dust, fumes, or odors, and truck and parking complaints for the site, as well as contact information for the SJVAPCD’s complaint call- line: 1- 800-870-1037. Any complaints made to the facility operator’s designee shall be answered within 72 hours of receipt.

Implementation of SCSP policies and development standards and compliance with the City’s policies, design standards and regulations would reduce the potential for conflict between passenger vehicles, trucks, bicycles, and pedestrians. In the context of these safeguards, there is no evidence to suggest that plan development would result in substantial increases in transportation hazards during operations. The City of Fresno Systemic Local Roadway Ascent Environmental Transportation and Circulation
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Safety Plan identifies 32 Tier I countermeasures applicable to locations where collisions have occurred and in locations with similar characteristics to proactively reduce collision risk (City of Fresno 2020). See Table 8.2, “Summary of the Prioritized Systemic Treatments and Related Information,” of the Systemic Local Roadway Safety Plan for details. Although, none of the top 20 high risk corridors and intersections in the city are located within the Plan Area, there were half mile segments and intersections within the Plan Area that scored high for vehicle crash severity.

Therefore, subsequent development in the Plan Area would be subject to the improvements established in the Systemic Local Roadway Safety Plan.

In addition, as mentioned above, the City and the SJVAPCD are engaged in a truck reroute study (and companion health impact assessment) for the South Central Fresno AB 617 Community, which includes the Plan Area (see Section

4.3, “Air Quality” for discussion of AB 617 and Chapter 1, “Introduction” of the SCSP for discussion of the Truck Reroute Study). The study is designed to address, among other things, truck transportation conflicts, accidents, and residential and school impacts. The truck reroute study is not yet complete, but it is anticipated that its recommendations will be implemented by the City and would further reduce the potential for transportation conflicts and hazards from incompatible land uses.

Summary
Transportation hazards related to construction would be temporary. The construction contractor s for individual projects would be required to develop and implement TCPs to minimize any potential hazards during construction.

Individual projects would be required to meet all City design standards and other regulations and would be subject to review by the City’s Traffic Operations and Planning Division, Traffic Planning Section. Additionally, the proposed plan includes policies and development standards specific to the Plan Area, the implementation of which would minimize risks of safety hazards related to vehicle and truck circulation. With implementation of existing requirements, there is no evidence to suggest that implementation of the proposed plan would substantially increase transportation-related hazards due to a geometric design feature or incompatible uses. While the truck reroute study is not yet complete, it is anticipated that its recommendations will be implemented by the City and would further reduce the potential for such hazards. Therefore, this impact would be less than significant.

Mitigation Measures
No mitigation is required for this impact.

Impact 4.15-4: Result in Inadequate Emergency Access
Subsequent projects and transportation improvements that would be developed under the proposed plan would be required to meet State and local standards pertaining to emergency access including design and safety regulations provided in the 2022 California Fire Code and City Municipal Code. Additionally, individual projects associated with the proposed plan would be subject to review by City and responsible emergency service staff ensuring all standards are met during construction and operations. There is no evidence to suggest that development under the proposed plan would result in inadequate emergency access. This impact would be less than significant.

As discussed in Impact 4.15-3 above, all development under the proposed plan would be required to meet City of Fresno design standards and safety protocols during construction. Individual projects would also be required to comply with the City of Fresno Municipal Code Section 15-2423, “Circulation and Safety,” which provides that parking lots shall be “designed so that sanitation, emergency, and other public service vehicles can provide service without backing unreasonable distances or making other dangerous or hazardous turning movements, as determined by the Review Authority” (City of Fresno Municipal Code Section 15-2423). Subsequent projects under the proposed plan would also be required to adhere to standards set forth in the 2022 California Fire Code as adopted by the City of Fresno Section 10-50100, “Adoption of the California Fire Code,” of the Municipal Code which establishes minimum widths of 24 feet for fire apparatus roads to allow adequate access. Section 3310.1 of the 2019 California Fire Code identifies minimum requirements to provide required emergency access during construction activities.

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With adherence to local and State emergency access and design standards and regulations, implementation of the proposed plan would not adversely affect emergency vehicle access or response times. Therefore, the proposed plan would not result in inadequate emergency access. This impact would be less than significant.

Mitigation Measures
No mitigation is required for this impact.

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4.16 UTILITIES AND SERVICE SYSTEMS
This section evaluates the availability of existing utility and infrastructure systems (including water, wastewater, stormwater, electricity, natural gas, and telecommunications) to serve future development in the Plan Area and the impact of the proposed plan on these systems. The analysis is based on documents obtained from the City of Fresno and technical reports prepared to address water supply and sewer conveyance adequacy related to implementation of the proposed plan. Please refer to Section 4.6, “Energy,” for a discussion of energy demand.

During the public scoping period for the Draft EIR, comments were received that expressed concerns related to financial support for utilities infrastructure, sufficient water supply, and consistency with Fresno Metropolitan Flood Control District (FMFCD) requirements. This section contains a discussion of water supply sufficiency as evaluated in a water supply assessment (WSA) (Appendix E) prepared for the proposed plan. FMFCD requirements are discussed below as they relate to storm water drainage. Financial issues, unless there is a clear and direct link to a physical environmental effect, are beyond the scope of CEQA analysis and are not discussed in this Draft EIR.

4.16.1 Regulatory Setting

FEDERAL
Water
Safe Drinking Water Act
As mandated by the Safe Drinking Water Act (Public Law 93 ‐523), passed in 1974, EPA regulates contaminants of concern to domestic water supply. Such contaminants are defined as those that pose a public health threat or that alter the aesthetic acceptability of the water. These types of contaminants are regulated by the US Environmental Protection Agency (EPA) primary and secondary maximum contaminant levels (MCLs). MCLs and the process for setting these standards are reviewed triennially. Amendments to the Safe Drinking Water Act enacted in 1986 established an accelerated schedule for setting drinking water MCLs. EPA has delegated responsibility for California’s drinking water program to the State Water Resources Control Board (SWRCB) Division of Drinking Water. SWRCB Division of Drinking Water is accountable to EPA for program implementation and for adoption of standards and regulations that are at least as stringent as those developed by EPA.

Stormwater
Refer to Section 4.10, “Hydrology and Water Quality,” for a discussion of the Clean Water Act (CWA), including CWA Section 401, Water Quality Certification and 402, National Pollutant Discharge Elimination System.

STATE
Water
Safe Drinking Water Quality Regulations
The California Department of Public Health (DPH) establishes “primary” and “secondary” Domestic Water Quality Standards for drinking water supplied by public water systems such as the city. The standards are required by state law to meet or exceed standards adopted by EPA. The concentrations of specified constituents are limited to maximum contaminant levels and are established on a constituent basis for bacteriological contaminants (such as coliform), organic chemicals (such as benzene), inorganic chemicals (such as total dissolved solids), and radioactivity (such as gross alpha particle activity). Primary standards are set at levels necessary to protect public health and may not be exceeded. Secondary standards are based on aesthetic criteria, such as tast e and odor, and are composed of (1) recommended limits that may be exceeded but are not recommended to be exceeded; (2) upper limits that may Utilities and Service Systems Ascent Environmental
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be exceeded for a limited duration with prior DPH approval; and (3) short term limits that may not be exceeded.

Public water systems also must obtain a domestic water supply permit from DPH that must be amended to reflect changes to the water supply system.

Urban Water Management Planning Act
The Urban Water Management Planning Act (California Water Code [CWC] Sections 10610-10610.4) requires urban water suppliers that provide water for municipal purposes to more than 3,000 customers, or more than 3,000 acre - feet per year (afy) of water, to prepare an urban water management plan (UWMP). UWMPs assist water supply agencies in water resource planning given existing and anticipated future demands and must include a water supply and demand assessment comparing total water supply available to the water supplier with the total projected water use over a 20-year period. The Act requires that the plans be updated every five years and submitted to the California Department of Water Resources (DWR). The purpose of the plans is to support long-term resource planning and ensure adequate water supplies are available to meet existing and future water demands. The City’s 2020 UWMP is discussed below.

Sustainable Groundwater Management Act
The Sustainable Groundwater Management Act (SGMA) became law on January 1, 2015 and applies to all groundwater basins in the state (Water Code Section 10720.3). (The SGMA is composed of three separate bills:

SB 1168, SB 1319, and AB 1739. All three were signed into law by the Governor on September 16, 2014.) By enacting SGMA, the legislature intended to provide local agencies with the authority and the technical and financial assistance necessary to sustainably manage groundwater within their jurisdiction (CWC Section 10720.1).

Pursuant to SGMA, any local agency that has water supply, water management, or land use responsibilities within a groundwater basin may elect to be a groundwater sustainability agency (GSA) for that basin (Water Code Section 10723). All GSAs were required to complete and begin implementing a groundwater sustainability plan (GSP) by January 31, 2022. The GSP must outline how the GSA will implement, manage, and measure specific actions for the health and viability of the basin. DWR will evaluate the GSP and provide the GSA with an assessment of the plan and any necessary recommendations within 2 years for initial establishment. The DWR will also review plans as updated by GSAs every 5 years.

Water Supply Assessment
PRC Section 21151.9 requires that a water supply assessment (WSA) be prepared for proposed projects as defined in the statute to ensure that long term water supplies are sufficient to meet the project’s demands in normal, single dry, and multiple dry years for a period of 20 years. Preparation of a WSA is required if a proposed action meets the statutory definition of a “water-demand project,” which means (CWC Section 20912[a]):
 a proposed residential development of more than 500 dwelling units;  a proposed shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet (sq. ft.) of floor space;
 a proposed commercial office building employing more than 1,000 persons or having more than 250,000 sq. ft. of floor space;
 a proposed industrial, manufacturing, or processing plant, or industrial park planned to house more than 1,000 persons, occupying more than 40 acres of land, or having more than 650,000 sq. ft. of floor area;  a mixed-use project that includes one or more of the projects specified in the above bullets; or  a project that would demand an amount of water equivalent to, or greater than, the amount of water required by a 500-dwelling unit project.

Completion of a WSA requires collection of proposed water supply data and information relevant to the project in question, an evaluation of existing/current use, a projection of anticipated demand sufficient to serve the project for a period of at least 20 years, delineation of proposed water supply sources, and an evaluation of water supply sufficiency under normal, single-dry year and multiple-dry year conditions.

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A WSA is required to be prepared by the public water system that will serve the project, unless there is no public water system, in which case the WSA is prepared by the CEQA lead agency. A “ public water system” is defined in Section 15155 as a system that provides piped water for human consumption and has at least 3,000 connections.

Stormwater
See Section 4.10, “Hydrology and Water Quality,” for a discussion of the requirements of NPDES permits as they relate to stormwater discharge, which includes design and operational best management practices for drainage facility design.

Wastewater
Porter-Cologne Water Quality Control Act
The Porter-Cologne Water Quality Control Act (Porter-Cologne Act) is California’s statutory authority for the protection of water quality. Under the Porter-Cologne Act, the state must adopt water quality plans, policies, and objectives that will provide protection to the state’s waters for the use and enjoyment of the people of California. In California, the SWRCB has authority and responsibility for establishing policy for water quality control issues for the state. Regional authority for planning, permitting, and enforcement is delegated to the nine regional water quality control boards (RWQCBs). The Porter-Cologne Act authorizes the SWRCB and RWQCB to issue NPDES permits containing WDRs, and to enforce these permits. SWRCB and RWQCB regulations implementing the Porter -Cologne Act are in Title 27 of the CCR.

General Waste Discharge Requirements for Sanitary Sewer Systems The General Waste Discharge Requirements for Sanitary Sewer Systems (SWRCB Order No 2006 -0003-DWQ) apply to sanitary sewer systems that are greater than 1 mile long and collect or convey untreated or partially treated wastewater to a publicly owned treatment facility. The goal of Order No. 2006-0003 is to provide a consistent statewide approach for reducing Sanitary Sewer Overflows (SSOs), accidental releases of untreated or partially treated wastewater from sanitary sewer systems, by requiring that:

1. In the event of an SSO, all feasible steps be taken to control the released volume and prevent untreated wastewater from entering storm drains, creeks, etc.

2. If an SSO occurs, it must be reported to the SWRCB using an online reporting system developed by the SWRCB.

3. All publicly owned collection system agencies with more than 1 mile of sewer pipe in the state must develop a Sewer System Management Plan (SSMP), which must be updated every 5 years.

Solid Waste
California’s Integrated Waste Management Act of 1989
The California Integrated Waste Management Act (CIWMA) of 1989 created the California Integrated Waste Management Board, now known as the California Department of Resources Recycling and Recovery (CalRecycle).

CalRecycle is the agency designated to oversee, manage, and track California’s 92 million tons of waste generated each year. CalRecycle provides grants and loans to help cities, counties, businesses, and organizations meet the state’s waste reduction, reuse, and recycling goals. CalRecycle promotes a sustainable environment in which these resources are not wasted but can be reused or recycled. In addition to many programs and incentives, CalRecycle promotes the use of new technologies to divert resources away from landfills. CalRecycle is responsible f or ensuring that waste management programs are carried out primarily through local enforcement agencies.

The CIWMA is the result of two pieces of legislation: AB 939 and SB 1322. The CIWMA was intended to minimize the amount of solid waste that must be disposed of through transformation and land disposal by requiring all cities and counties to divert 25 percent of all solid waste from landfill facilities by January 1, 1995, and 50 percent by January 1, 2000.

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The 50 percent diversion requirement is measured in terms of per capita disposal expressed as pounds per day per resident and per employee. The per capita disposal and goal measurement system uses an actual disposal measurement based on population and disposal rates reported by disposal facilities, and it evaluates program implementation efforts.

Mandatory Recycling Requirements
AB 341 (2011) amended the California Integrated Waste Management Act of 1989 to include a provision declaring that it is the policy goal of the state that not less than 75 percent of solid waste generated be source -reduced, recycled, or composted by the year 2020, and annually thereafter. In addition, AB 341 required CalRecycle to develop strategies to achieve the state’s policy goal.

Mandatory Commercial Organics Recycling Requirements
In October 2014, AB 1826 Chesbro (Chapter 727, Statutes of 2014) was signed into law, requiring businesses to recycle their organic waste on and after April 1, 2016, depending on the amount of waste they generate per week. This law also requires that on and after January 1, 2016, local jurisdictions across the state implement an organic waste recycling program to divert organic waste generated by businesses, including multifamily residential dwellings of five or more units (multifamily dwellings are not required to have a food waste diversion program, however). Organic waste means food waste, green waste, landscape and pruning waste, nonhazardous wood waste, and food- soiled paper waste that is mixed in with food waste.

SB 1374, Construction and Demolition Waste Materials Diversion Requirements, mandates that jurisdictions summarize their progress realized in diverting construction and demolition waste from the waste stream in their annual AB 939 reports. SB 1374 required CalRecycle to adopt a model construction and demolition ordinance for voluntary implementation by local jurisdictions.

Short-Lived Climate Pollutant Reduction Strategy
In September 2016, SB 1383 (Lara, Chapter 395, Statutes of 2016) was signed into law, establishing methane emissions reduction targets in a statewide effort to reduce emissions of short-lived climate pollutants in various sectors of California's economy. Actions to reduce short-lived climate pollutants are essential to address the many impacts of climate change on human health, especially in California's most at-risk communities, and on the environment.

As it pertains to solid waste, SB 1383 establishes targets to achieve a 50-percent reduction in the volume of statewide disposal of organic waste from 2014 levels by 2020 and a 75-percent reduction by 2025. The law grants CalRecycle the regulatory authority required to achieve the organic waste disposal reduction targets and establishes an additional target that not less than 20 percent of currently disposed edible food is recovered for human consumption by 2025. SB 1383 requires that, by January 1, 2022, every jurisdiction provide organic waste collection services to residents and businesses.

Electricity and Natural Gas
California Code of Regulations, Energy Efficiency Standards Energy consumption in new buildings in California is regulated by the state’s Building Energy Efficiency Standards, part of the California Building Standards Code (CALGreen), contained in the CCR, Title 24, Part 2, Chapter 2-53. Title 24 applies to all new construction of both residential and nonresidential buildings, and regulates energy consumed for heating, cooling, ventilation, water heating, and lighting. Updated every 3 years, the 2019 Building Energy Efficiency Standards were most recently approved and adopted by the California Building Standards Commission in 2022 and became effective in January 2023 and have improved efficiency requirements from previous codes.

PG&E Gas Rules
PG&E’s Gas Rules 15 and 16 provide policies and procedures for the extension of gas services and distribution mains necessary to furnish permanent services to customers. It outlines responsibilities for installation and extension of gas lines, as well as financial contributions by project applicants.

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LOCAL
Water
Fresno General Plan
The following policies are applicable to water supplies and facilities in the Plan Area (City of Fresno 2022).

Public Utilities Element
Objective PU-8: Manage and develop the City’s water facilities on a strategic timeline basis that recognizes the long life cycle of the assets and the duration of the resources, to ensure a safe, economical, and reliable water supply for existing customers and planned urban development and economic diversification.  Policy PU-8-a: Forecast Need. Use available and innovative tools, such as computerized flow modeling to determine system capacity, as necessary to forecast demand on water production and distribution systems by urban development, and to determine appropriate facility needs.  Policy PU-8-b: Potable Water Supply and Cost Recovery. Prepare for provision of increased potable water capacity (including surface water treatment capacity) in a timely manner to facilitate planned urban development consistent with the General Plan. Accommodate increase in water demand from the existing com munity with the capital costs and benefits allocated equitably and fairly between existing users and new users, as authorized by law, and recognizing the differences in terms of quantity, quality and rel iability of the various types of water in the City’s portfolio.
 Policy PU-8-c: Conditions of Approval. Set appropriate conditions of approval for each new development proposal to ensure that the necessary potable water production and supply facilities and water resources are in place prior to occupancy.
 Policy PU-8-d: CIP Update. Continue to evaluate Capital Improvement Programs and update them, as appropriate, to meet the demands of both existing and planned development consistent with the General Plan.  Policy PU-8-e: Repairs. Continue to evaluate existing water production and distribution systems and plan for necessary repair or enhancement of damaged or antiquated facilities.  Policy PU-8-f: Water Quality. Continue to evaluate and implement measures determined to be appropriate and consistent with water system policies, including prioritizing the use of groundwater, installing wellhead treatment facilities, constructing above-ground storage and surface water treatment facilities, and enhancing transmission grid mains to promote adequate water quality and quantity.  Policy PU-8-g: Review Project Impact on Supply. Mitigate the effects of development and capital improvement projects on the long-range water budget to ensure an adequate water supply for current and future uses.

Fresno Urban Water Management Plan
The City’s 2020 UWMP was adopted in 2021, as required by the California Urban Water Management Planning Act, which requires all urban water suppliers with more than 3,000 connections or distributing more than 3,000 afy to complete an UWMP every five years. As of the close of the 2020 calendar year, the City had over 139,500 residential, commercial, industrial, and institutional water service connections and produced nearly 122,000 acre -feet (af) of water. As a result, the City prepared and adopted a UWMP and submitted it to DWR, as required.

Wastewater
The following policies are applicable to wastewater services in the Plan Area.

Fresno General Plan
Public Utilities Element
Objective PU-4: Ensure provision of adequate trunk sewer and collector main capacities to serve existing and planned urban development, consistent with the Wastewater Master Plan.

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 Policy PU-4-a: Plan for Regional Needs. Coordinate and consult with the City of Clovis, pursuant to the Fresno- Clovis Sewerage System Joint Powers Agreement, so that planning and construction of sewer collection facilities will continue to meet the regional needs of the Metropolitan Area.  Policy PU-4-b: New Trunk Facilities. Pursue construction of new or replacement sewer trunk facilities or other alternatives consistent with the Wastewater Master Plan to accommodate the uses as envisioned in this General Plan.
 Policy PU-4-c: System Extension and Cost Recovery. Pursue enlargement or extension of the sewage collection system where necessary to serve planned urban development, with the capital costs and benefits allocated equitably and fairly between the existing users and new users.  Policy PU-4-d: Capacity Modeling. Continue development and utilization of citywide sewer flow monitoring and computerized flow modeling to determine availability of sewer collection system capacity to serve planned urban development.
 Policy PU-4-e: Evaluate and Maintain Infrastructure. Promote the health and safety of the community, and preserve the longevity and sound condition of the sewer collection system through evaluation and maintenance of the sewer infrastructure.
 Continue assessments of existing infrastructure and facilitate necessary repair to damaged and worn- out pipelines.
 Continue routine sewer line maintenance and cleaning programs to prevent line blockages caused by root intrusion, grease buildup, and pipe failure.
 Continue a sewer line replacement program and funding to repair or replace sewer lines damaged or worn beyond useful life.

Objective PU-5: Preserve groundwater quality and ensure that the health and safety of the entire Fresno community is not impaired by use of private, onsite disposal systems.  Policy PU-5-a: Mandatory Septic Conversion. Continue to evaluate and pursue where determined appropriate the mandatory abatement of existing private wastewater disposal (septic) systems and mandatory connection to the public sewage collection and disposal system.

Parks, Open Space, and School Element
Objective PU-7: Promote reduction in wastewater flows and develop facilities for beneficial reuse of reclaimed water and biosolids for management and distribution of treated wastewater.  Policy POSS-7-b: Reduce Stormwater Leakage. Reduce storm water infiltration into the sewer collection system, where feasible, through a program of replacing old and deteriorated sewer collection pipeline; eliminating existing stormwater sewer cut-ins to the sanitary sewer system; and avoiding any new sewer cut-ins except when required to protect health and safety.

Stormwater
Fresno General Plan
The following policies are applicable to stormwater in the Plan Area.

Parks, Open Space, and School Element
Objective POSS-3: Ensure that park and recreational facilities make the most efficient use of land; that they are designed and managed to provide for the entire Fresno community; and that they represent positive examples of design and energy conservation.
 Policy POSS-3-i: Joint Use with Drainage Facilities. Continue to seek joint use agreements for use of FMFCD stormwater drainage facilities.

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Noise and Safety Element
Objective NS-3: Minimize the risks to property, life, and the environment due to flooding and stormwater runoff hazards.
 Policy NS-3-a: Stormwater Drainage and Flood Control Master Plan. Support the full implementation of the FMFCD Storm Drainage and Flood Control Master Plan, the completion of planned flood control and drainage system facilities, and the continued maintenance of stormwater and flood water retention and conveyance facilities and capacities. Work with the FMFCD to make sure that its Storm Drainage and Flood Control Master Plan is consistent with the General Plan.
 Policy NS-3-b: Curb and Gutter Installation. Coordinate with Fresno Metropolitan Flood Control District (FMFCD) to install curbing, gutters, and other drainage facilities with priority to existing neighborhoods with the greatest deficiencies and consistent with the Storm Drainage and Flood Control Master Plan.  Policy NS-3-c: Dual Use Facilities. Support multiple uses of flood control and drainage facilities as follows:
 Use, wherever practical, FMFCD facilities for groundwater management and recharge; and  Promote recreational development of ponding basin facilities located within or near residential areas, compatible with the stormwater and groundwater recharge functions.  Policy NS-3-d: Landscaped Buffer. City will support the development of FMFCD ponding basins including the landscaping and irrigation for the top one third of the side sloped areas consistent with the FMFCD Basin Design Criteria.
 Policy NS-3-e: Pollutants. Work with FMFCD to prevent and reduce the existence of urban stormwater pollutants pursuant to the requirements of the National Pollution Discharge Elimination Systems Act.  Policy NS-3-h: Runoff Controls. Implement grading regulations and related development policies that protect area residents from flooding caused by urban runoff produced from events that exceed the capacity of the Storm Drainage and Flood Control Master Plan system of facilities. Place all structures and/or flood -proofing in a manner that does not cause floodwaters to be diverted onto adjacent property, increase flood hazards to other property, or otherwise adversely affect other property.  Policy NS-3-i: New Development Must Mitigate Impact. Require new development to not significantly impact the existing storm drainage and flood control system by imposing conditions of approval as project mitigation, as authorized by law. As part of this process, closely coordinate and consult with the FMFC D to identify appropriate conditions that will result in mitigation acceptable and preferred by FMFCD for each project.

Fresno Municipal Code
Chapter 6, Municipal Services and Utilities, Article 7, Urban Storm Water Quality Management and Discharge Control, of the Fresno Municipal Code establishes provisions regarding stormwater discharges. The purpose of the City’s Urban Storm Water Quality Management and Discharge Control Ordinance is to ensure the health, safety, and general welfare of citizens and protect the water quality of watercourses and water bodies in a manner pursuant to and consistent with the CWA (33 U.S.C. Section 1251, et seq.) by reducing pollutants in urban stormwater discharges to the maximum extent practicable and by effectively prohibiting non-stormwater discharges to the storm drain system.

Fresno Metropolitan Flood Control District Stormwater Quality Management Plan The Storm Water Quality Management Program (SWQMP) was developed pursuant to Order No. R5 -2013-0080. The municipal National Pollutant Discharge Elimination System stormwater permit was issued to the Fresno Metropolitan Flood Control District, the cities of Fresno and Clovis, Fresno County, and the California State University at Fresno by the Central Valley Regional Water Quality Control Board (Regional Board) on May 31, 2013. The SWQMP represents the 5-year management strategy for controlling the discharge of pollutants in stormwater and urban runoff from the Fresno-Clovis metropolitan area to the during the third permit term (2013-2018).

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The SWQMP includes specific pollution prevention and control practices for Fresno- Clovis urban drainage system planning, design, construction, and maintenance. The Program also includes public education to prevent stormwater pollution; specifies construction, industrial/commercial, municipal, and new development control practices; procedures to prevent and respond to illicit discharges and connections; monitoring to assess stormwater impacts on receiving waters; and program effectiveness assessments to evaluate the effectiveness of best management practices.

Solid Waste
Fresno General Plan
The following policies are applicable to solid waste services in the Plan Area.

Public Utilities Element
Objective PU-9: Provide adequate solid waste facilities and services for the collection, transfer, recycling, and disposal of refuse.
 Policy PU-9-a: New Techniques. Continue to collaborate with affected stakeholders and partners to identify and support programs and new techniques of solid waste disposal, such as recycling, composting, waste to energy technology, and waste separation, to reduce the volume and toxicity of solid wastes that must be sent to landfill facilities.
 Policy PU-9-b: Compliance with State Law. Continue to pursue programs to maintain conformance with the Solid Waste Management Act of 1989 or as otherwise required by law and mandated diversion goals.

Resource Conservation and Resilience Element
Objective RC-11: Strive to reduce the solid waste going to landfills to zero by 2035.  Policy RC-11-a: Waste Reduction Strategies. Maintain current targets for recycling and reuse of all types of waste material in the city and enhance waste and wastewater management practices to reduce natural resource consumption, including the following measures:
 Continue to require recyclable material collection and storage areas in all residential development.  Establish recycling collection and storage area standards for commercial and industrial facilities to size the recycling areas according to the anticipated types and amounts of recyclable material generated.  Provide educational materials to residents on how and what to recycle and how to dispose of hazardous waste.  Provide recycling canisters and collection in public areas where trash cans are also provided.  Institute a program to evaluate major waste generators and identify recycling opportunities for their facilities and operations.
 Continue to partner with the California Integrated Waste Management Board on waste diversion and recycling programs and the CalMax (California Materials Exchange) program.  Evaluate the feasibility of a residential, restaurant, and institutional food waste segregation and recycling program, to reduce the amount of organic material sent to landfill and minimize the emissions generated by decomposing organic material.
 Evaluate the feasibility of “carbon footprinting” for the City’s wastewater treatment facilities, biomass and composting operations, solid waste collection and recycling programs.  Expand yard waste collection to divert compostable waste from landfills.  Study the feasibility and cost-benefit analysis of a municipal composting program to collect and compost food and yard waste, including institutional food and yard waste, using the resulting compost matter for City park and median maintenance.
 Policy RC-11-b: Zero Waste Strategy. Create a strategic and operations plan for fulfilling the City Council resolution committing the City to a Zero Waste goal.

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4.16.2 Environmental Setting

WATER SUPPLY
As described above, the City’s 2020 UWMP includes water demand projections for current water demands within the City and anticipated water demands associated with future development projects and planning areas within the City’s General Plan Sphere of Influence through 2045. Future development includes the Plan Area; however, the land uses in the City’s General Plan are not the same as those proposed in the SCSP. Thus, the WSA prepared for the SCSP evaluated whether adequate water supplies would be available for the Plan Area, as proposed in the SCSP. The WSA is summarized below (City of Fresno 2023).

Surface Water
The City currently receives potable water supplies from surface and groundwater sources. Surface water is delivered to the City by two separate sources: Fresno Irrigation District (FID) Agreement for Kings River water and US Bureau of Reclamation (Reclamation) Central Valley Project (CVP) Friant Division Contract for San Joaquin River water. Surface water is either treated and delivered to customers or delivered to groundwater recharge basins. Surface water supply is summarized in the following sections (City of Fresno 2023).

Surface Water Supplies through FID Agreement
In May 1976, the City and FID executed an agreement that stipulated that as land is annexed to the City, the City will receive a pro rata share of FID’s Kings River entitlement; this agreement was revised, amended, and restated in December 2016. The pro rata share is based on the area annexed to the City, and within FID’s boundaries, as compared to the total area of FID’s water service area. The 2016 FID Agreement sets the maximum at 29 percent, although the City’s service area is anticipated to expand and encompass more than 29 percent of FID’s service area between 2025 and 2030. In 2020, the City’s percentage of overall FID Kings deliveries was 25.79 percent (City of Fresno 2023).

The agreement stipulates that the allocation amount will be reviewed each year by the two agencies to address new annexations to the City. As the City annexes new areas, the allocation will increase up to the limits stipulated in the 2016 agreement. During normal hydrologic water years, the City estimates it will receive 131,600 af of water from FID in 2045 based on the City’s projected future water service area (City of Fresno 2023).

Surface Water Supplies through Reclamation Contract
The City, through an agreement originally executed in January of 1961, secured a surface water supply from the CVP- Friant Division of Reclamation. This agreement for an annual water supply of 60,000 af of Class 1 water was last renewed in 2010 as a Section 9(d) Contract that provides water from the San Joaquin River in perpetuity. The Reclamation CVP-Friant Division facilities generally include the following: Friant Dam (Millerton Reservoir), the Friant Kern Canal, and the Madera Canal. The Friant-Kern Canal is maintained and operated by the Friant Water Authority.

The Reclamation water supply is a wholesale supply (City of Fresno 2023).

Class 1 water was intended to be a supply that would be dependable in practically every year, regardless of the type of hydrologic water year. Class 2 water is essentially excess water available as determined by Reclamation and less reliable than Class 1 water. Class 1 water has historically been very reliable until the 2006 San Joaquin River Restoration Settlement and, more recently, by the restrictions on diversions from the Sacramento-San Joaquin Delta (Delta) due to concerns over the declining health of Delta ecosystem. Since 2006, the City has assumed 100 percent of its annual allocation in normal and normal-wet years, and between 0 and 75 percent of its annual allocation in critical, dry, and normal-dry years (City of Fresno 2023).

Groundwater
The City pumps groundwater from a portion of the Kings Subbasin underlying the City. Per the City’s 2020 UWMP, the City has over 270 municipal wells and is actively operating approximately 202 of those wells. Groundwater quality is a concern because the groundwater basin has several major contaminant plumes involving organic compounds, Utilities and Service Systems Ascent Environmental
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inorganic compounds, solvents, pesticides, and other contaminants. Several City wells are currently being treated or blended to address various contaminants. When the City’s 2014 Water Master Plan was prepared, the total well capacity was approximately 460 million gallons per day (mgd) (City of Fresno 2023).

The Kings Subbasin is managed by the North Kings Groundwater Sustainability Agency (NKGSA). As a high priority basin, the NKGSA was required to complete and file a Groundwater Sustainability Plan (GSP) meeting SGMA requirements by January 2020. The GSP was submitted in January 2020 and was in corporated into the City’s 2020 UWMP, which shows the City’s water supply is sufficient to meet projected demands. The GSP was then revised and resubmitted in 2022 following DWR’s 2-year review and determination. The revised GSP was recommended by DWR staff for approval in March 2023 (City of Fresno 2023).

The City’s 2020 UWMP addresses the sufficiency of the City’s groundwater supplies, in conjunction with the City’s other existing and additional water supplies, to meet the City’s existing and planned future uses. Based on the information provided above and included in the City’s 2020 UWMP and in the NKGSA GSP, the City’s groundwater supply, together with the City’s other existing and additional planned future water supplies, is sufficient to meet the water demands of the SCSP and the City’s existing and planned future uses (City of Fresno 2023).

The City has a number of future capital improvement projects planned to maintain and upgrade existing water supply and distribution facilities. The City completed construction on the 80-mgd Southeast Surface Water Treatment Facility (SESWTF) in 2018, while the City’s Northeast Surface Water Treatment Facility (NESWTF) currently has a 30-mgd capacity and the capability to expand up to 60 mgd. The City is also planning to develop additional groundwater recharge facilities that would optimize use of available surface water supplies in normal and wet years. The timing for the NESWTF expansion and the development of additional groundwater recharge facilities will be examined as part of the City’s future Metro Plan update and determined based on need as the City grows and demands increase. The City also plans to continue expanding its recycled water distribution system to offset potable water demands (City of Fresno 2023).

Table 4.16-1 summarizes the City’s 2020 actual water supply deliveries and projected future water supply available through 2045.

Table 4.16-1 City of Fresno Historical and Projected Water Supplies (in acre-feet/year)

2020 2025 2030 2035 2040 2045
Groundwater Production 55,028 138,090 143,630 149,100 154,490 159,820 Surface Water 108,739 185,030 191,600 191,600 191,600 191,600 Potable Water Subtotal 163,767 323,120 335,230 340,700 346,090 351,420 Notes: af/yr = acre-feet per year
Groundwater production in 2020 is actual, while the supplies listed for 2025-2045 is available supplies inclusive of banked recharged supplies.

Source: City of Fresno 2023.

Water Supply Reliability
The City’s surface water supply could face constraints during dry years. Water supplied from the FID contract is most susceptible to variable hydrologic conditions; however, the City recently constructed a dedicated 13 -mile, 72-inch diameter raw water pipeline to deliver Kings River water to the SESWTF to allow for year -round operations and prevent shutdowns due to FID maintenance. The City also has a contract for 60,000 afy of Class 1 water from Reclamation’s CVP, which is affected by required downstream flows for the San Joaquin River and the imposed restrictions on water diversions from the Delta. These restrictions have resulted in years where the CVP -Friant Division contractors, such as the City, receive zero allocations. The water supply is also restricted by maintenance of infrastructure, which results in termination of water supply during November and/or December. To improve delivery reliability and to protect source water quality, the City constructed a 4.6-mile long raw water pipeline that will allow for the delivery of Reclamation water from the Friant-Kern Canal directly to the NESWTF (City of Fresno 2023).

Groundwater has long been the primary water supply source for the City. The continued use of groundwater is key to the sustainable use of all supplies, including surface water and recycled water. The groundwater supply has declined Ascent Environmental Utilities and Service Systems
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over the last 80 years, requiring new deeper wells and the lowering of pumps in existing wells. A constraint to lowering the pumps in existing wells is the limited depth of numerous existing municipal water wells. If the declining groundwater trend is not reversed, it may reduce the City’s pumping capacity (City of Fresno 2023).

Another constraint to the use of groundwater is existing contaminant plumes throughout the subbasin. To ensure the continued beneficial use of the groundwater supply, the City will have to remain proactive in pursuing responsible party(ies) to conduct the proper remediation to preserve the groundwater system as a viable and sustainable resource in perpetuity. Despite these concerns, the City does not expect hydrologic conditions to affect groundwater supplies (City of Fresno 2023).

Table 4.16-2 summarizes the projected availability of the City’s existing and planned future potable water supplies and the City’s projected water demands in normal, single dry and multiple dry years through 2045. This table indicates that the demand within the City’s service area is not expected to exceed the City’s supplies in any normal, single dry, or multiple dry year between 2025 and 2045 (City of Fresno 2023). The table does list potential surplus during drought years. Local and state regulations moderate conversation in drought years, which drop the demand.

In addition, any surplus is unpumped groundwater supplies that needs to remain in the ground for resilience against an ongoing drought (City of Fresno 2023).

Table 4.16-2 City of Fresno Water Demand Versus Water Supply During Hydrologic Normal, Single Dry, and Multiple Dry Years (in acre-feet/year)
Hydrologic Condition 2025 2030 2035 2040 2045
Normal Year(a)
Available Water Supply 329,030 341,140 346,610 352,000 357,330 Total Water Demand 199,204 212,756 222,310 231,876 241,447 Potential Surplus (Deficit) 129,826 128,384 124,300 120,124 115,883 Percent Shortfall of Demand - - - - -
Single Dry Year(b)
Available Water Supply 189,852 195,392 200,862 206,252 211,582 Total Water Demand 164,092 176,132 184,174 192,228 200,287 Potential Surplus (Deficit) 25,760 19,260 16,688 14,024 11,295 Percent Shortfall of Demand - - - - -
Multiple Dry Year 1
Available Water Supply 273,725 279,265 284,735 290,125 295,455 Total Water Demand 199,204 212,756 222,310 231,876 241,447 Potential Surplus (Deficit) 74,521 66,509 62,425 58,249 54,008 Percent Shortfall of Demand - - - - -
Multiple Dry Year 2
Available Water Supply 274,626 280,166 285,636 291,026 296,356 Total Water Demand 199,204 212,756 222,310 231,876 241,447 Potential Surplus (Deficit) 75,422 67,410 63,326 59,150 54,909 Percent Shortfall of Demand - - - - -
Multiple Dry Year 3
Available Water Supply 217,568 223,108 228,578 233,968 239,298 Total Water Demand 190,267 193,637 197,736 201,753 205,708 Potential Surplus (Deficit) 27,301 29,471 30,842 32,215 33,589 Percent Shortfall of Demand - - - - -
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Hydrologic Condition 2025 2030 2035 2040 2045
Multiple Dry Year 4
Available Water Supply 189,852 195,392 200,862 206,252 211,582 Total Water Demand 162,551 165,920 170,020 174,036 177,992 Potential Surplus (Deficit) 27,301 29,471 30,842 32,215 33,589 Percent Shortfall of Demand - - - - -
Multiple Dry Year 5
Available Water Supply 314,840 320,380 325,850 331,240 336,570 Total Water Demand 199,204 212,756 222,310 231,876 241,447 Potential Surplus (Deficit) 115,636 107,624 103,540 99,364 95,123 Percent Shortfall of Demand - - - - -
Notes: af/yr = acre-feet per year
Source: City of Fresno 2023.

Emergency Water Supply Conditions
The City’s 2020 UWMP includes a water shortage contingency plan (WSCP) to address droughts and catastrophic water supply interruptions due to regional power outage, earthquake, or other disasters. The WSCP defines five water shortage levels and the specific water supply conditions associated with each shortage level. M oving from one stage to the next is based on water supply conditions, including reductions in surface water from Reclamation and FID, reductions in treatment or distribution capacity, decrease in groundwater levels in 30 key wells, or climate or state political conditions that would impact the allotment of water supply (City of Fresno 2023).

Consumption reduction methods outlined in the WSCP include limiting or prohibiting the watering of lawns and other landscape areas, prohibiting the use of potable water for construction and dust control, and prohibiting vehicle washing except at facilities using water recycling equipment. Rate changes and fees may be implemented to penalize excessive water use or violation of water use ordinances. If the City were to implement its WSCP, all City customers, including those within the Plan Area, would be subject to the same water conservation measures and water use restrictions as included in City’s WSCP (City of Fresno 2023).

WATER INFRASTRUCTURE
Water Conveyance
Water infrastructure within the City of Fresno is addressed in the Fresno Metropolitan Water Resources Management Plan (Metro Plan). The Metro Plan contains a comprehensive and integrated water supply plan to manage water supplies within the City’s sphere of influence, including the Plan Area. The 2014 Metro Plan Update identifies various improvements that would be required to adequately serve a portion of the buildout of the General Plan.

The City is currently updating its Metro Plan, which will recommend programs and projects to improve the City’s water supply portfolio and continue providing a safe, reliable, and sustainable water supply. While the outcomes of the Metro Plan update are currently being developed, the City’s ongoing and future projects to improve its supply portfolio include:
 expansion of recycled water distribution system,
 expansion of groundwater recharge program,
 expansion of surface water treatment capacity, and
 beneficial transfers and exchanges.

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The water conveyance system associated with the Plan Area and nearby portions of the City is depicted in Figure 3-13 in Chapter 3, “Project Description.” As shown in this figure, the existing system generally consists of 10-inch and 12- inch pipelines within the northern portion of the Plan Area and 14-inch pipelines within the southern portion of the Plan Area. Several wells are located within Plan Area (Figure 3-13).

Potable Water Treatment
The City operates three potable water treatment facilities: the Northeast Surface Water Treatment Facility (NESWTF), the SESWTF, and the T3 Surface Water Treatment Facility. The NESWTF can treat up to 24 mgd and the T3 Surface Water Treatment can treat up to 3.2 mgd. The SESWTF is currently permitted to produce up to 54 mgd; however , with the subsequent rerating of the media filters, will be capable of operating at a rated capacity of 80 mgd. The timing for the SESWTF expansion will be examined as part of the Metro Plan update and determined based on need as the City grows and demands increase (City of Fresno 2021).

WASTEWATER
Wastewater Collection System
The City of Fresno owns and maintains the majority of the wastewater collection systems that convey wastewater to the Fresno/Clovis Regional Wastewater Reclamation Facility (RWRF), and all of the wastewater collection system that conveys wastewater to the North Fresno Water Reclamation Facility (NFWRF). Wastewater generated from the Plan Area would be conveyed to and treated at the RWRF.

The wastewater collection system conveys wastewater primarily by gravity to the RWRF located southwest of the City limits. Generally, wastewater flows from the northeast to the southwest. The City also conveys wastewater from Clovis and two unincorporated areas: Pinedale Public Utility District and the Pinedale County Water District. Clovis has purchased capacity in specific pipelines. The City has over 20,000 manholes, 13 permanent and 4 temporary lift stations, nearly 13 miles of force mains, and almost 1,400 miles of gravity sewer pipes (City of Fresno 2006).

The wastewater collection system associated with the Plan Area is depicted in Figure 3-14 in Chapter 3, “Project Description.” As shown, pipelines are throughout the Plan Area and a lift station is located near Cherry Avenue and North Avenue. No gravity mains are considered deficient within the Plan Area.

Wastewater Treatment
The RWRF is located southwest of the City in the area generally bounded by Jensen, Cornelia, Central , and Chateau Fresno Avenues. The RWRF is a biological, secondary level treatment plant, which treats approximately 68 mgd of wastewater. The RWRF produces secondary treated water that meets Title 22 California Code of Regulations and may be used to irrigate fields with alfalfa, silage corn, Sudangrass, and other fiber crops not used for human consumption.

Approximately 12 to 15 percent of the total af of wastewater that is treated at the reclamation facility goes for direct reuse to farmers leasing land within the RWRF boundaries or to neighboring farmers. Up to 5 mgd is also treated to disinfected tertiary recycled water standards as defined by Title 22 of the California Code of Regulations. This recycled water can be used for farming or landscape irrigation. The remaining treated wastewater is conveyed to 1,700 acres of ponds to percolate into the ground (City of Fresno 2023).

The permitted wastewater treatment capacity of the RWRF is currently 91.5 mgd annual monthly average flow, and 101 mgd as a maximum monthly average flow. In 2017, Phase I of a tertiary treatment system was completed at the RWRF.

The current design flow for the tertiary treatment system is 5 mgd but can be expanded in two subsequent phases to 15 mgd (Phase II) and ultimately 30 mgd (Phase III). The City of Clovis maintains the rights and capacity to discharge 9.3 mgd to the facility. The City of Fresno maintains the rights to the remaining capacity (City of Fresno 2020).

The following upgrades would be completed to accommodate future development associated with continued implementation of the approved General Plan (City of Fresno 2020):
 Construct 70 mgd expansion at the RWRF, prior to flows of the RWRF reaching 80 percent of rated capacity, in accordance with the City of Fresno 2006 Wastewater Master Plan.

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 Construct a 25,000 AF/year recycled water facility as an expansion to the RWRF in accordance with the January 2014 City of Fresno Metropolitan Water Resources Management Plan. This improvement is required after the year 2025 and is identified as a required facility as part of the Mitigation Measure UTL -1.2.1 in the City’s General Plan EIR.
 Construct a 0.49 mgd expansion of the NFWRF.
 Construct 24 mgd wastewater treatment facility within the Southeast Development Area, in accordance with the City of Fresno 2006 Wastewater Master Plan.
 Additional 9.6 mgd expansion at the RWRF.

STORMWATER
The Fresno Metropolitan Flood Control District (FMFCD) provides stormwater collection and disposal, and flood control to the north-central portion of Fresno County, between the San Joaquin and Kings Rivers, covering 164 adopted or proposed drainage areas. FMFCD’s local stormwater drainage system consists of interconnected surface conveyances, storm drains, retention basins, pump stations and ou tfalls, which discharge to groundwater, irrigation canals, creeks, and the San Joaquin River. The system is designed to retain and infiltrate as much runoff as possible into the underlying groundwater aquifer. Under FMFCD requirements, development proposals must elevate building pads so that finished floor levels are above the anticipated high-water elevation and establish an outlet flow path for the runoff of major storms through the use of street improvements, easements, or other public rights- of-way to consider the flow path and potential flooding resulting from major storms (FMFCD 2017).

ELECTRIC POWER, NATURAL GAS, AND TELECOMMUNICATIONS
Electric Power
Fresno receives its electricity from Pacific Gas and Electric Company (PG&E). PG&E provides electrical service to business and residents throughout the Plan Area via underground and aboveground service lines. PG&E owns and maintains all service and transmission lines in the Plan Area and operates several electrical substations throughout the Plan Area.

Natural Gas
PG&E is the natural gas service provider in the Plan Area. PG&E owns and maintains several natural gas transmission lines in the Plan Area that feed local distribution lines that connect to individual service lines.

Telecommunications
Several providers provide telecommunication services to the Plan Area. AT&T is the largest provider of cellular and fixed telephone services. Telephone lines are located throughout the Plan Area.

SOLID WASTE
Residential solid waste in the City is collected in three bins for green waste, garbage, and recyclables. The City has granted exclusive franchise agreements for the collection of commercial solid waste, recyclables and green waste to two franchises. Allied Waste Services (formally Republic) is responsible for all commercial services north of Ashlan Avenue, north of the Plan Area, and Mid Valley has all commercial locations south of Ashlan, including the Plan Area.

Both haulers are responsible for commercial, multifamily, and industrial collections, up to 8 cubic yards, which fall into City of Fresno jurisdiction. The refuse from customers’ garbage bins is collected by the City of Fresno Solid Waste Division and is taken to the Cedar Avenue Receiving and Transfer Station (CARTS) facility for sorting and transfer.

Once off-loaded at the transfer station, the garbage is then loaded onto large trucks and taken to the American Avenue Landfill. Fresno County operates the American Avenue Disposal Site, which serves as the county’s regional landfill (City of Fresno 2020). As of June 2022, the American Avenue Landfill has a maximum permitted capacity of Ascent Environmental Utilities and Service Systems
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32,700,000 cubic yards and a remaining capacity of 17,459,683 cubic yards, with an estimated closure date of August 31, 2031. The maximum permitted throughout is 2,200 tons per day (CalRecycle 2023).

One other active disposal site is located in Fresno County. The City of Clovis Landfill (SWIS Number 10-AA-0004) has a maximum permitted capacity of 7,800,000 cubic yards and a remaining capacity of 7,740,000 cubic yards, with an estimated closure date of April 30, 2047. The maximum permitted throughout is 2,000 tons per day (CalRecycle 2023).

Green waste hauled by the residential solid waste operations is delivered to one of two locations: Kochergen/Green Valley Recycling located at 2365 North Avenue and West Coast Waste located at 30777 Golden State Frontage Road.

Both of these facilities are within one-quarter mile of one another in southwest Fresno. Commercial green waste and organics delivered to Mid Valley Disposal Elm Avenue Recycling and Transfer Station are then transferred to the Kerman facility and composted with organic compost, which is then used by organic farms in the region. Commercial green waste and organics delivered by Allied Waste are taken to Rice Road Transfer Station, which are then trans-loaded into trucks, which are delivered to Kochergen Farms for composting and land application (City of Fresno 2020).

Recycling collected from residential customers is delivered to both CARTS and Elm Ave. Both facilities have Material Recovery Facilities (MRFs), which sort through the co-mingled recycling stream to sort the materials. Commercial franchises deliver recycling to Elm Avenue only. The City’s diversion rate has fluctuated over the last decade from 63 to 74 percent (City of Fresno 2020).

The City of Fresno and Fresno County, as members of the AB 939 MOU 16-jurisdiction committee, hold two household hazardous waste (HHW) drop-off events each year, one in the spring and one in the fall. Additionally, Fresno County provides a door-to-door program that provides household hazardous waste pickup for individuals who, because of special circumstances, cannot participate in the household hazardous waste drop off events held twice a year (City of Fresno 2020). Fresno recently opened an environmental compliance facility to receive free household hazardous waste from the public.

4.16.3 Environmental Impacts and Mitigation Measures

METHODOLOGY
Expansion of New Infrastructure
The potential impacts of the proposed plan related to utilities and service systems infrastructure was evaluated qualitatively. Impacts were assessed by evaluating the projected capacity demand of plan development in the context of current service commitments and capacities of public service providers within the Plan Area.

Water Supply
The analysis of water supply is based on information included in South Central Specific Plan Water Supply Assessmen t (West Yost 2023). The methodology is intended to identify increases in water demand and the capacity of existing and proposed water sources to accommodate that demand. Several standard factors were used to identify future demand and resultant impacts based on the proposed plan elements compared to existing water demand. The water conveyance adequacy analysis is based on information included in South Central Specific Plan Water and Sewer Hydraulic Analysis Technical Memorandum (Akel 2022).

Wastewater Treatment
The wastewater analysis is based on information included in South Central Specific Plan Water and Sewer Hydraulic Analysis Technical Memorandum (Akel 2022). Future wastewater generation from proposed plan land uses is calculated and compared to the capacity of the City’s sewer collection system . This study relied on design criteria established in the City’s 2015 Sewer System Master Plan (SSMP) and was used to identify any capacity deficiencies in the City’s existing sewer system. Fresno Municipal Code Section 6-303 – Sewer Connection Required, requires properties to connect to the City sewer system when available. As such is it assumed that all future development would connect to the City’s sewer system.

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Solid Waste Capacity and Compliance
The potential for increased waste generation was based on generation rates established in the General Plan EIR as reported in Estimated Solid Waste Generation Rates (CalRecycle 2019).

THRESHOLDS OF SIGNIFICANCE
A utilities and service systems impact would be significant if implementation of the proposed plan would:
 require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects;
 have insufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years;
 result in a determination by the wastewater treatment provider that serves or may serve the project that it has inadequate capacity to serve the project’s projected demand, in addition to the provider’s existing commitments ;  generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals; or  fail to comply with federal, state, and local management and reduction statutes and regulations related to solid waste.

PROPOSED SCSP POLICIES AND DEVELOPMENT STANDARDS
The following policies are relevant to utilities and service systems:
 W-1: Protect groundwater and surface water by regulating sewage disposal facilities and preventing contaminating uses.
 W-2: Implement a periodic water quality testing program in areas where contamination has been an issue.  W-3: Provide supplemental water resources to areas already impacted by groundwater quality and quantity degradation.
 W-4 Identify funding tools to expand water system access in and near the Plan Area.  W-5: Require new development to implement water conservation measures and to contribute towards expanded and upgraded facilities.
 W-6: Reduce water consumption through education, conservation standards, landscaping standards, retrofit programs, and incentive programs.
 W-7: Seek funding to expand water facilities to neighbors within the Plan Area.

ISSUES NOT DISCUSSED FURTHER
All the issues identified in the thresholds of significance are addressed in the following analysis.

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ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES
Impact 4.16-1: Require or Result in the Relocation or Construction of New or Expanded Water, Wastewater Treatment or Storm Water Drainage, Electric Power, Natural Gas, or Telecommunications Facilities, the Construction or Relocation of Which Could Cause Significant Environmental Effects
Implementation of the proposed plan would require relocation or construction of new or expanded water, wastewater treatment, stormwater drainage, electric power, natural gas, and telecommunications facilities. New infrastructure would generally be constructed within existing roadways or would consist of short connections to existing pipelines and would be developed as part of buildout of the proposed p lan. The impacts associated with such infrastructure connections would be typical of such construction and would result in are generally assessed as part of the proposed development under the SCSP (e.g., construction-related air, noise, GHG, and transportation effects), within the context of this EIR, and there is no evidence to suggest that such construction would result in additional significant environmental effects. This impact would be less than significant.

The Plan Area consists of a variety of land use types, including industrial, commercial, public, neighborhood mixed- use, rural- and medium-density residential, and agricultural. Substantial new development is anticipated in the Plan Area, including new industrial, business park, commercial, and residential uses that would require extension of utilities infrastructure.
 Water: The increase in water demand would require the installation of new 16-inch transmission grid mains and approximately six new wells within the Plan Area. These improvements are depicted in Figure 3 -13 in Chapter 3, “Project Description.”
 Sewer: A network of sewer collection infrastructure would be installed throughout the Plan Area to serve future development. The SCSP wastewater collection system would include installation of new transmission grid mains, and upsizing of conveyance pipelines located along North Avenue between Cedar Avenue and Parkway Drive.

New pipelines are depicted in Figure 3-14 in Chapter 3, “Project Description.”  Stormwater: Storm drainage facilities within the Plan Area are planned, implemented, operated, and maintained by the FMFCD. Specific upgrades may include new streets and gutters, storm drain inlets, storm drain pipelines, detention and retention basins, pump stations, and outfall facilities that collect and drain runoff from developed land areas. Future development would be planned in accordance with requirements set forth under the SWQMP.  Electric Power, Natural Gas, and Telecommunication Facilities: Expanded electric power, natural gas, and telecommunications facilities would be necessary to support new development under the SCSP, as described in Chapter 3, “Project Description.

A discussion of relevant operational and construction impacts of SCSP development, which includes supporting utility infrastructure, is provided within each respective section of this EIR. In some cases, the direct and indirect impacts are potentially significant and warrant mitigation measures, while in other cases there are significant and unavoidable impacts. The future infrastructure would fall within the range of environmental impacts disclosed in this EIR, and would be subject to relevant mitigation measures included in this EIR. Construction and operation of utility infrastructure in the Plan Area would be typical of such facilities, and there is no evidence to suggest that it would result in any additional significant effects not evaluated herein. Thus, this impact would be less than significant.

Mitigation Measures
No mitigation is required for this impact.

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Impact 4.16-2: Have Insufficient Water Supplies Available to Serve the Project and Reasonably Foreseeable Future Development During Normal, Dry, and Multiple Dry Years As discussed in the Water Supply Assessment (Appendix E) prepared for the proposed plan, the City’s 2020 UWMP relied upon the City’s General Plan to project future water supply and demand and indicates that there would be surplus water during normal, dry, and multiple dry years through 2045. Future development of the proposed plan would demand less water than the currently approved General Plan land uses within the P lan Area. As such, there would be a greater surplus of water supply for the City during normal, dry, and multiple -dry years through 2045 with implementation of the proposed plan compared with the existing approved land uses considered in the 2020 UWMP.

Thus, this impact would be less than significant.

The land uses associated with the City’s General Plan informed the water demand forecasted in the City’s 2020 UWMP for the plan area. The SCSP proposes a different mix of land uses than the City’s General Plan within the plan area (i.e., South Industrial Area as presented in the City’s General Plan). As shown in Table 4.16 -3, the land uses proposed for the SCSP would reduce water demand relative to those of the General Plan.

Table 4.16-3 Projected Average Day Water Demand for the Proposed Plan versus General Plan Land Use Classifications Water Use Factor
(gpd/ac)
General Plan Proposed Plan
Acreage Estimated Water
Demand (mgd) Acreage Estimated Water
Demand (mgd)
Residential
Single-Family Residential 2,800 30 0.08 270 0.76
Neighborhood Mixed Use 2,900 0.25 0.00 0.25 0.00
Non-Residential
Business Park 2,800 144 0.40 653 1.83
General Commercial 2,500 10 0.02 47 0.12
Regional Business Park 2,000 351 0.70 334 0.67
Heavy Industrial 3,900 3,486 13.59 2,650 10.33
Light Industrial 1,900 685 1.30 715 1.36
Open Space - Ponding Basin 1,300 158 0.20 158 0.20 Open Space - Neighborhood Park 3,500 2 0.01 2 0.01 Public 1,900 42 0.08 78 0.15
Rail - 32 - 32 -
Total - 4,940 acres 16.40 mgd
18,400 af/yr
4,940 acres 15.43 mgd
17,300 af/yr
Source: City of Fresno 2023.

Notes: ac = acre; af = acre-feet; gpd = gallon per day; mgd = million gallons per day; yr = year As discussed above under “Water Supply,” in Section 4.16.2, “Environmental Setting,” the 2020 UWMP indicates that surplus water supply is projected for the City’s water service area, including the plan area, in normal, dry, and multiple dry years through 2045. Water demand included in the 2020 UWMP includes demand that would be generated by the currently approved land uses in the Plan Area, as provided in the City’s General Plan. As indicated in Table 4.16-3, the proposed plan would result in less water demand than the currently approved land uses (17,300 af/yr versus 18,400 af/yr) (City of Fresno 2023). As a result, there would be a greater surplus of water supply during normal, dry, and multiple-dry years through 2045 with implementation of the proposed plan compared with the existing approved land uses considered in the 2020 UWMP. Therefore, this impact would be less than significant.

Mitigation Measures
No mitigation is required for this impact.

Ascent Environmental Utilities and Service Systems
City of Fresno
South Central Specific Plan Draft EIR 4.16-19
Impact 4.16-3: Result in a Determination by the Wastewater Treatment Provider That Serves or May Serve the Project That It Has Inadequate Capacity to Serve the Project’s Projected Demand, in Addition to the Provider’s Existing Commitments Wastewater generation from development anticipated under the proposed plan would be approximately 11.6 mgd average annual flows (AAF), 13.4 mgd peak day dry weather flows, and 15.1 mgd for peak month wet weather flows.

The RWRF, which has a remaining capacity of 23.5 mgd, would be able to accommodate these wastewater flow rates in addition to existing commitments. Furthermore, wastewater flows from the Plan Area would be less than those estimated for the currently approved land uses under the General Plan, which would contribute 12.8 mgd for AAF,

14.7 mgd for peak day dry weather flows, and 16.6 mgd for peak month wet weather flows. Thus, this impact would be less than significant.

The permitted wastewater treatment capacity of the RWRF is currently 91.5 mgd as an annual monthly average flow and 101 mgd as a maximum monthly average flow. Given that the RWRF currently treats approximately 68 mgd, there is a remaining treatment capacity of 23.5 mgd. Increased wastewater flows attributed to the future development associated with the proposed plan were assessed in a technical memorandum prepared for the City. The technical memorandum considered sewer system capacity based on design criteria established in the City’s SSMP , and attributed to the proposed land uses within the proposed plan. Based on this evaluation, wastewater flows were estimated to be 11.6 mgd AAF, 13.4 mgd peak day dry weather flows, and 15.1 mgd for peak month wet weather flows (Akel 2022). These flow rates would be less than the remaining capacity at the RWRF, which as noted above is 23.5 mgd. Furthermore, wastewater flows from the Plan Area would be less under the proposed plan than under the currently approved land uses, which would contribute 12.8 mgd for AAF, 14.7 mgd for peak day dry weather flows, and 16.6 mgd for peak month wet weather flows. As described in Section 4.16.2, “Environmental Setting,” above, the General Plan EIR assumes that several upgrades would be completed to accommodate future development associated with continued implementation of the approved General Plan. These upgrades include expansion of the RWRF, construction of a recycled water facility at the RWRF, expansion of the NFWRF, and construction of a wastewater treatment facility within the Southeast Development Area.

Therefore, because adequate treatment capacity is available at the RWRF for wastewater flows associated with the proposed plan, and upgrades to the overall wastewater treatment system in the City are planned to accommodate General Plan buildout, this impact would be
less than significant.

Mitigation Measures
No mitigation is required for this impact.

Impact 4.16-4: Generate Solid Waste in Excess of State or Local Standards, or in Excess of the Capacity of Local Infrastructure, or Otherwise Impair the Attainment of Solid Waste Reduction Goals; or Fail to Comply with Federal, State, and Local Management and Reduction Statutes and Regulations Related to Solid Waste Implementation of the proposed plan would allow for development of industrial, commercial office, retail, and residential uses, which would generate solid waste. Development related to the proposed plan would implement programs to reduce landfill contributions, consistent with CIWMA, AB 341, SB 1374, AB 1826, and SB 1383. While General Plan Policy RC-11-b requires the City to develop a strategic and operations plan for fulfilling the City Council resolution committing the City to a Zero Waste goal, it is not clear if zero waste goals will be met. Without attainment of zero waste goals, development under the proposed plan may generate waste in excess of capacity at the American Avenue Landfill, which is planned for closure in 2031. This impact would be potentially significant.

Implementation of the proposed plan would allow for development of industrial, commercial office, retail, and residential uses. Based on generation rates assumed in the City’s General Plan EIR, as compiled by CalRecycle, the annual municipal solid waste generation by new development in the Plan Area would be approximately 36.5 tons per day, which equates to approximately 13,330 tons per year (Table 4.16-4). Commercial/industrial waste generally weighs 450 pounds per cubic yard (EPA 2023). Therefore, the plan would contribute approximately 59,200 cubic yards of waste per year.

Utilities and Service Systems Ascent Environmental
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4.16-20 South Central Specific Plan Draft EIR
Table 4.16-4 Solid Waste Generation Anticipated under the Proposed Plan Land Use Assumed Development
under the Proposed Plan Solid Waste Generation Rate Solid Waste Generation Residential 91 units 10 lbs/unit/day 910 lbs/day
Commercial/Office/Public Facility 1,445,466 sq ft 6 lbs/1,000 sq ft/day 8,670 lbs/day Industrial 10,576,278 sq ft 6 lbs/1,000 sq ft/day 63,460 lbs/day Total Waste Generated at Buildout 73,040 lbs/day
(36.5 tons/day)
Notes: lbs = pounds; sq ft = square feet
Source: CalRecycle 2019.

As discussed in Section 4.16.2, “Environmental Setting,” above, the American Avenue Landfill has a maximum permitted capacity of 32,700,000 cubic yards and a remaining capacity of 17,459,683 cubic yards, with an estimated closure date of August 31, 2031. The City of Clovis Landfill is anticipated to close in 2047. Under existing conditions, solid waste continues to be disposed of at American Avenue Landfill, and with the remaining capacity and lifespan at the landfills identified above, solid waste disposal at American Avenue Landfill would not be available through buildout of the proposed plan (i.e., 2040). The City of Clovis Landfill would not provide a longer-term solution for waste disposal, as it expected to close in 2047. However, the City is implementing diversion programs and the Fresno City Council passed a resolution that commits the City to the goal of a Zero Waste goal by 2025 (City of Fresno 2020). On-going programs would continue to reduce landfill contributions, consistent with CIWMA, AB 341, SB 1374, AB 1826, and SB 1383. While General Plan Policy RC-11-b requires the City to develop a strategic and operations plan for fulfilling the City Council resolution committing the City to a Zero Waste goal, it is not clear when zero waste goals will be met. Without attainment of zero waste goals, development under the proposed plan may generate waste in excess of capacity at the American Avenue Landfill, which is planned for closure in 2031. Thus, this impact would be potentially significant.

Mitigation Measures
Mitigation Measure 4.16-4: Verify Landfill Capacity on a Project-by-Project Basis and Restrict Development Accordingly Consistent with the Fresno General Plan, the City shall evaluate additional landfill locations at the time individual projects are submitted within the Plan Area and shall not approve development that could contribute to solid waste to a landfill that is at capacity until additional capacity is identified.

Significance after Mitigation
As discussed above, the City continues to implement waste reduction activities to reduce landfill contributions, consistent with CIWMA, AB 341, SB 1374, AB 1826, and SB 1383. Although, American Avenue Landfill is planned for closure in 2031, at which time it would no longer accommodate solid waste disposal from the Plan Area, consistent with the Fresno General Plan, the City will need to increase disposal capacity. Implementation of Mitigation Measure

4.16-4 would require the City to identify additional available landfill capacity for future development before approval of individual development projects. In addition, the policies in the General Plan are designed to reduce the potential effect associated with solid waste disposal include those associated with the proposed plan. Furthermore, all future development under the proposed plan would be required to comply with State and local requirements for reduction of solid waste going to landfills. Therefore, implementation of mitigation measure 4.16-4 and compliance with existing regulations and policies, the impact would be reduced to a less-than-significant level.

City of Fresno
South Central Specific Plan Draft EIR 5-1
5 CUMULATIVE IMPACTS

5.1 CEQA REQUIREMENTS
Section 15130(a) of the State CEQA Guidelines requires a discussion of the cumulative impacts of a project when the project’s incremental effect is cumulatively considerable. Cumulatively considerable, as defined in State CEQA Guidelines Section 15065(a)(3), means that the “incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.” The State CEQA Guidelines Section 15355 defines a cumulative impact as two or more individual effects that, when considered together, are considerable or that compound or increase other environmental impacts. Cumulative impacts can result from individually minor but collectively signif icant projects taking place over a period of time.

5.2 CUMULATIVE IMPACT APPROACH
State CEQA Guidelines Section 15130 identifies two basic methods for establishing the cumulative environment in which a project is considered: the use of a list of past, present, and probable future projects or the use of development projections from an adopted general plan, other regional planning document, or a certified EIR for such a planning document. This cumulative analysis uses the “plan” approach to identify the cumulative setting. The cumulative analysis considers the development anticipated to occur in accordance with the Fresno General Plan, encompassing the Plan Area and beyond.

In the case of the SCSP, the Plan Area has been modified from its natural conditions by human activity, primarily urban development, actual and planned. Heavy industrial, open space, vacant land, and light industrial are the predominant existing land uses in the Plan Area, with smaller areas of commercial and residential development (see Table 3-1 in Chapter 3, “Project Description”). Agriculture makes up most of the open space area with the remainder consisting of canals and ponding basins for surface water runoff detention and groundwater recharge. The remainder of the Plan Area is composed of residential, commercial, and public facilities land uses. South Central Fresno is an area that has long been planned for growth. Beginning as early as 1918, the City of Fresno has recognized the Plan Area’s economic importance and from 1956 onward has planned for industrial development through the Fresno General Plan.

The analysis also considers planning efforts that address regional environmental issues, such as water quality improvement programs, and potential effects associated with climate change. These plans, programs, and effects are discussed in relevant resource discussions below.

5.3 CUMULATIVE SETTING

5.3.1 Geographic Scope
The geographic area that could be affected by the proposed plan and is appropriate for a cumulative impact analysis varies depending on the environmental resource topic, as presented in Table 5-1.

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Table 5-1 Geographic Scope of Cumulative Impacts
Resource Topic Geographic Area
Aesthetics Local (Plan Area and surrounding public viewpoints) Agriculture and Forestry Resources Fresno County
Air Quality San Joaquin Valley Air Basin
Biological Resources Fresno County/Central Valley Region of California Cultural and Tribal Cultural Resources Local (individual project sites within the Plan Area where ground -disturbing activities would occur and where new structures would be developed ), with regional implications
Energy Pacific Gas and Electric Company service area
Geology, Soils, and Mineral Resources Local (individual project sites within the Plan Area where ground-disturbing activities would occur and where new structures would be developed) Greenhouse Gas Emissions and Climate Change Global
Hazards and Hazardous Materials Local (individual project sites within the Plan Area where ground -disturbing activities would occur and where new structures would be developed) Hydrology and Water Quality City of Fresno, Fresno County, San Joaquin Valley Basin Land Use and Planning Local (individual project sites within the Plan Area where ground -disturbing activities would occur and where new structures would be developed) Noise Local (immediate vicinity of the Plan Area where proposed plan -generated noise could be heard concurrently with noise from other sources) Population and Housing City of Fresno, Fresno County
Public Services and Recreation Regional and local service areas Transportation and Circulation Regional and local roadways and freeways where the project could contribute traffic that could alter traffic conditions
Utilities and Service Systems Local service areas
Source: Compiled by Ascent Environmental in 2023.

5.3.2 Regional Planning Environment
The Fresno General Plan, adopted by the City Council on December 18, 2014 and most recently amended on October 13, 2022, establishes the land use pattern and goals for development and growth in the City of Fresno .

Additionally, the City has nine community plan areas, nine specific plan areas, and two neighborhood plan areas that have been planned for urban development. These plans were relied upon in preparing the cumulative impact analysis. The documents are available for review online at https://www.fresno.gov/planning/general-plan- development-code/ and at the City of Fresno at 2600 Fresno Street, Fresno, CA 93721.

5.4 ANALYSIS OF CUMULATIVE IMPACTS
The following sections contain a discussion of the cumulative effects anticipated from implementation of the proposed plan, together with related projects and planned development in the City of Fresno, for each of the 16 environmental issue areas evaluated in this Draft EIR. The analysis conforms with Section 15130(b) of the State CEQA Guidelines, which specifies that the “discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of occurrence, but the discussion need not provide as great detail as is provided for the effects attributable to the project alone. The discussion should be guided by the standards of practicality and reasonableness, and should focus on the cumulative impact to which the identified other projects contribute rather than the attributes of other projects which do not contribute to the cumulative impact.” Ascent Environmental Cumulative Impacts
City of Fresno
South Central Specific Plan Draft EIR 5-3
When considered in relation to other reasonably foreseeable projects, cumulative impacts to some resources would be significant and more severe than those caused by the proposed plan alone.

For purposes of this EIR, the proposed plan would result in a significant cumulative effect if:
 the cumulative effects of related projects (past, current, and probable future projects) are not significant and the incremental impact of implementing the proposed plan is substantial enough, when added to the cumulative effects of related projects, to result in a new cumulatively significant impact; or  the cumulative effects of related projects (past, current, and probable future projects) are already significant and implementation of the proposed plan makes a considerable contribution to the effect. The standards used herein to determine a considerable contribution are that either the impact must be substantial or must exceed an established threshold of significance.

Significance criteria, unless otherwise specified, are the same for cumulative impacts and proposed plan impacts for each environmental topic area. This cumulative analysis assumes that all mitigation measures identified in Chapter 4 to mitigate impacts of the proposed plan are adopted. The analysis herein analyzes whether, after adoption of mitigation, the residual impacts of the proposed plan would cause a cumulatively significant impact or would contribute considerably to existing/anticipated (without the proposed plan) cumulatively significant effects.

5.4.1 Aesthetics
Aesthetic and visual resources impacts are project-specific and highly localized. Aesthetic impacts of projects visible from the same areas where the proposed plan would be visible were evaluated to determine whether there would be significant cumulative aesthetic impacts. The geographic extent for considering cumulative impacts on aesthetics includes all projects within the same viewshed (i.e., area visible from viewer’s location) of the proposed plan , which is a conservative estimate of the likely maximum distance from which the proposed plan would be visible, particularly considering the flat terrain of the Plan Area that does not afford elevated viewpoints with very expansive views.

The Plan Area is predominantly industrial, with undeveloped agricultural areas bounding the Plan Area to the south.

Future cumulative development would include new residential, commercial, and industrial development consistent with the General Plan or the applicable General Plans of each of the surrounding municipalities. Future development would be subject to the design review processes of the individual jurisdiction, and the applicable land use plans contain policies and implementing actions to preserve visual character, land use compatibility, and views in those jurisdictions. Cumulative development within the City would be required to comply with applicable City General Plan policies and programs and adhere to development and design standards in the Municipal Code that address aesthetics, including lighting and glare, the alteration of scenic resources and natural features, the alteration of views of scenic resources and natural features. However, consistent with the findings of the General Plan EIR, cont inued buildout of the General Plan and nonagricultural development in the surrounding communities identified by the geographic scope would continue to significantly change the visual character of the area and the amount of nighttime illumination, even with adherence to General Plan policies and project -specific design review. For these reasons, cumulative impacts to aesthetics or nighttime lighting and daytime glare would be significant.

As discussed in Section 4.1, “Aesthetics,” there are no designated scenic vistas or state-designated scenic highways in the Plan Area or the City. The proposed plan and cumulative development would be subject to specific regulations and guidelines related to building heights, setbacks, undergrounding of utilities, landscaping, signage, and permitted land uses. However, the proposed plan would result in increases of densities and intensification primarily of industrial and commercial land uses within the Plan Area, which would result in substantial changes in the existing visual character. The proposed plan’s contribution to the conversion of rural and agricultural uses to urban uses would be significant and, combined with cumulative development, would result in a substantial alteration of the existing visual character of the area, for which there is no available mitigation. Therefore, the proposed plan’s contribution to cumulative visual character or quality impacts would be cumulatively considerable. This impact would be significant and unavoidable.

Cumulative Impacts Ascent Environmental
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Additionally, the proposed plan would add new sources of light and glare associated with new buildings and facilities, and such lighting could contribute to indirect lighting/glare on adjacent land uses that could adversely affect daytime or nighttime views and result in additional skyglow. Implementation of Mitigation Measures 4.1-1 and 4.1-2, however, would reduce this impact to a less-than-significant level and the proposed plan’s contribution to cumulative light and glare impacts would not be considerable. Cumulative impacts related to light and glare would be less than significant.

5.4.2 Agriculture and Forestry Resources
The cumulative context for agriculture and forestry impacts is Fresno County . There are no forestry resources located within the geographic scope. Therefore, there would be no cumulative impacts to forestry resources.

As described in Section 4.2, “Agriculture and Forestry Resources,” Fresno County has approximately 1.88 million acres of farmland and is considered one of the most diverse and productive farming areas in the world. Cumulative development in the cities of Fresno, Clovis, and Sanger, as well as the unincorporated area of Fresno County and Madera County, has and would continue to convert grazing and other agricultural uses to non-agricultural uses, as well as conflict with existing agricultural zoning and Williamson Act contracts. The regional conversion of Important Farmland by urban development and regional conflicts with Williamson Act contracts are significant cumulative impacts.

The proposed plan would result in the conversion of approximately 982 acres of Prime Farmland and Farmland of Statewide Importance, as well as the conversion of approximately 153 acres of lands enrolled in Williamson Act contracts to non-agriculture uses. This is a considerable contribution to the significant cumulative impact associated with overall Farmland conversion in the region and regional conflicts with Williamson Act contracts. To reduce potential cumulative impacts on agriculture uses, the approved General Plan includes Objective RC-9 and Policies RC- 9-a through RC-9-c, which would reduce cumulative impacts to agricultural resources. In addition, for the proposed plan, implementation of Mitigation Measure 4.2-1 would require future development to mitigate the loss of Important Farmland on a project-by-project basis before construction or ground-disturbing activities, to address the conversion of farmland to non-farmland uses. There is no feasible mitigation that would reduce conflicts with Williamson Act contracts to a less-than-significant level. However, even with incorporation of the approved General Plan mitigation and project-specific mitigation, cumulative impacts related to conversion of agricultural land and conflicts with Williamson Act contracts would remain significant. Therefore, the proposed plan’s contribution to cumulative impacts related to farmland conversion and conflicts with Williamson Act contracts would be cumulatively considerable. These impacts would be significant and unavoidable.

5.4.3 Air Quality
The geographic scope of the cumulative impact analysis for air quality is the San Joaquin Valley Air Basin (SJVAB) .

Each project in the SJVAB is required to comply with San Joaquin Valley Air Pollution Con trol District (SJVAPCD) rules and regulations and is subject to independent review.

CONSTRUCTION EMISSIONS
The SJVAB is currently designated as a nonattainment area for the federal ozone standard and fine particulate matter with aerodynamic diameter of 2.5 micrometers or less (PM

2.5) standard and as a nonattainment area for the state ozone, respirable particulate matter with aerodynamic diameter of 10 micrometers or less (PM 10), and PM2.5 standard.

Thus, the SJVAB has not met the federal and state standards for these air pollutants. Construction activities in the region would add particulate matter and ozone emissions into the SJVAB that may conflict with attainment efforts.

Cumulative development, while required to mitigate for adverse air quality impacts, will contribute to regional emissions, resulting in a significant adverse cumulative impact.

As described in Section 4.3, “Air Quality,” and shown in Table 4.3-5, annual and daily emissions of reactive organic gases (ROG), oxides of nitrogen (NO
X), carbon monoxide (CO), sulfur oxides (SOX), PM10, and PM2.5 would not exceed Ascent Environmental Cumulative Impacts
City of Fresno
South Central Specific Plan Draft EIR 5-5
SJVAPCD’s annual mass emissions threshold of significance or daily screening criteria for most of the duration of plan implementation. This level of emissions would not conflict with long-term regional air quality planning in the SJVAB, would not result in a cumulative contribution to air pollution, and would not conflict with SJVAPCD’s relevant air quality plans. However, under a worst-case construction period, daily mass emissions would exceed SJVAPCD’s daily mass emissions screening criteria, which could result in an exceedance of an ambient air quality standard (AAQS), but SJVAPCD’s annual emissions thresholds would not be exceeded. Nevertheless, given the programmatic nature of this analysis, and the current nonattainment status of the SJVAB for ozone, PM10, and PM2.5, this analysis conservatively concludes that the proposed plan could contribute construction emissions that would interfere with the attainment status for these pollutants. Therefore, construction of future development implemented under the proposed plan could conflict with long-term regional air quality planning tied to attainment of the National AAQS (NAAQS) and California AAQS (CAAQS). As such, the proposed plan’s contribution of criteria air pollutants and ozone precursors could result in high concentrations of air pollution that could result in an adverse health outcome . Implementation of Mitigation Measures 4.3-1a through 4.3-1m would reduce the proposed plan’s emissions to a less-than-significant level. However, because of the scale and extent of construction activities that would occur, as well as the uncertainty of specific construction activities and timing, construction activities could overlap, resulting in emissions that would interfere with the attainment status for these pollutants. Therefore, the proposed plan’s contribution to cumulative construction emission impacts would be
cumulatively considerable. Because no additional mitigation is available beyond what is identified in this EIR, the cumulative impact would be significant and unavoidable.

LONG-TERM OPERATIONAL EMISSIONS
Ozone impacts are the result of cumulative emissions from numerous sources in the region and transport from outside the region. Cumulative development will add urban development on primarily undeveloped land in the region, resulting in substantial residential, commercial, office, and industrial development. All of this regional development will increase emissions that contribute to ozone impacts. Ozone is formed in chemical reactions involving NO
X, ROG, and sunlight. All but the largest individual sources emit NOX and ROG in amounts too small to have a measurable effect on ambient ozone concentrations by themselves. However, when all sources throughout the region are combined, they can result in ambient concentrations of ozone that exceed the NAAQS and CAAQS, resulting in a significant adverse cumulative impact.

As described in Section 4.3, “Air Quality,” and shown in Table 4.3-6, emissions of ROG, NOX, CO, PM10, and PM2.5 would exceed SJVACPD’s annual CEQA mass emissions thresholds as well as its daily screening criteria for all pollutants except SO
X. Future development under the proposed plan would be subject to SJVAPCD’s Rule 9510 for NOX and PM10 resulting in 33.3 and 50 percent reductions in these pollutants, respectively. Notwithstanding, because the thresholds would be exceeded, the contribution of criteria air pollutants by development in the Plan Area would conflict with SJVAPCD’s long-term regional air quality planning; interfere with the SJVAB’s capacity to attain the NAAQS and CAAQS for ozone, PM10, and PM2.5; and result in potential adverse health outcomes from exposure to air pollution. Mitigation Measures 4.3-1a through 4.3-1l would reduce the proposed plan’s on-site emissions, and 4.3-1m would further reduce the proposed plan’s emissions to a less-than-significant level through the contractual agreement between future project applicants and the air district in the form of a Voluntary Emissions Reduction Agreement. Nevertheless, in consideration of the cumulative nature of air pollution (i.e., regional attainment status determined by the combined emissions of past, present, and future projects), it cannot be assured that Mitigation Measures 4.3-1a through 4.3-1m would not cumulatively combine to create a significant impact. Therefore, the proposed plan’s contribution to the nonattainment status of the SJVAB with respect to the CAAQS and NAAQS would be cumulatively considerable. Because no additional mitigation is available beyond what is identified in this EIR, the cumulative impact would be significant and unavoidable.

TOXIC AIR CONTAMINANTS
Toxic air contaminants (TACs), which are examined under Impact 4.3-3 in Section 4.3, “Air Quality,” are also pollutants of localized concern. Diesel particulate matter emissions are the primary TAC of concern regarding the construction Cumulative Impacts Ascent Environmental
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5-6 South Central Specific Plan Draft EIR
and operation of new urban land uses and infrastructure. The health risk -based significance criteria used to evaluate TACs under Impact 4.3-3 are also inherently cumulative. This impact examines whether implementing the project would result in the exposure of sensitive receptors to TAC emissions that would result in cancer risk of 20 in 1 million or a hazard index greater than 1.0. Thus, the analysis focuses on the incremental increase in health risk from project - related sources of TAC emissions. Although Mitigation Measures 4.3-3a through 4.3-3d would reduce TACs generated from development of the proposed plan, its contribution is significant because of the scale of development; the uncertainty in the number, type, and location of TAC sources; and the level of associated health risk exposure that would result at any one location. It cannot be determined with certainty that future TAC concentrations would not expose any receptors to levels that exceed 20 in 1 million when combined with other projects.

Consequently, the proposed plan’s contribution to cumulative TACs impacts would be cumulatively considerable.

Because no additional mitigation is available beyond what is identified in this EIR , the cumulative impact would be significant and unavoidable.

ODORS
The creation of objectionable odors affecting a substantial number of people, which is examined under Impact 4.3 -4 in Section 4.3, “Air Quality,” is also an impact of localized concern. Construction and operation of development under the proposed plan would not result in the development of new odor sources atypical of developed urban areas and odor-generating construction activity would be temporary. Any new odor sources would be subject to future environmental review, and to SJVACPD’s Rule 4102 (“Nuisance”), which prohibits the discharge of air contaminants or other materials that would cause detriment, nuisance, or annoyance to any number of people . Implementation of the proposed plan would generate odors from construction activities which would be temporary and operational activities would generate odors from a variety of potential land uses. Because no specific projects or sites have been identified for such future uses, however, the degree of impact with respect to potential odors associated with future projects and their effects on adjacent receptors is uncertain. Due to the rapid dissipation of the odor with distance, the proposed plan would not contribute to cumulative odor impacts and, therefore, the cumulative impact would be less than significant.

5.4.4 Biological Resources
Generally, the geographic extent of cumulative impacts on biological resources consists of Fresno County and the Central Valley region of California that supports similar biological resource values and functions to those of the project area.

Sensitive habitats for biological resources in the Plan Area and in the region have been modified, removed, and fragmented over time as land has been developed and converted to agricultural, urban, and residential uses. Historic development in the region has resulted in substantial loss of sensitive habitats, much of which was likely not permitted or mitigated, including riparian habitat, which has been dramatically reduced from its historical extent in the region. This represents an existing significant cumulative impact. Future cumulative development in the region could continue to result in losses of sensitive habitats and sensitive species. Although individual projects would be required to mitigate for significant impacts on a project-by-project basis, they may result in residual impacts that combine with the existing adverse condition to create a significant cumulative impact related to special-status species and sensitive habitats.

Much of the Plan Area is farmland or rural residential lots with large, uneven, and underutilized/underdeveloped parcels. The Plan Area also contains substantial urban and developed land in the north and east, with increasing vacant lots and agricultural land in the central, south, and west. Irrigation ditches are located throughout the Plan Area near these active agricultural lands. Implementation of the proposed plan could result in adverse effects on special-status plants, special-status wildlife, riparian habitat (also considered a sensitive natural community), and waters of the United States and state. Mitigation Measures 4.4-1a through 4.4-1e, 4.4-2, and 4.4-3 would avoid or minimize adverse effects on these resources and would reduce impacts to a less- than-significant level. Additionally, individual development projects would be subject to future, project-level CEQA analysis, which would further identify project-specific impacts and mitigation measures to protect biological resources.

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Because the proposed plan would either have no impact or a very limited impact on biological resources after mitigation, it would not contribute to cumulative impacts to biological resources and , therefore, the cumulative impact would be less than significant.

5.4.5 Cultural and Tribal Cultural Resources
The cumulative context for the cultural resources analysis considers a broad regional system of which the resources are a part. The cumulative context for historical resources is Fresno and the San Joaquin Valley where common patterns of historic-era settlement have occurred over roughly the past two centuries. The cumulative context for archaeological resources, human remains, and tribal cultural resources is the former territory of the Northern Valley Yokuts. Yokuts primarily occupied the lands along the San Joaquin River, starting in the north at the Calaveras River and extending southward to the upper San Joaquin River, and from the crest of the Coast (Diablo) Range in the east to the Sierra Nevada foothills in the west.

Because all significant cultural resources are unique and nonrenewable members of finite classes, meaning there are a limited number of significant cultural resources, all adverse effects erode a dwindling resource base. The loss of any one archaeological site could affect the scientific value of others in a region because these resources are best understood in the context of the entirety of the cultural system of which they are a part. The cultural system is represented archaeologically by the total inventory of all sites and other cultural remains in the region. As a result, a meaningful approach to preserving and managing cultural resources must focus on the likely distribution of cultural resources, rather than on a single project or parcel boundary.

The historic lands of the Northern Valley Yokuts people have been affected by development since the arrival of the first Spanish settlers in the late 1770s. Agricultural development beginning in the mid-1850s was soon followed by railroad and commercial development and the establishment of Fresno County by 1856. Development of the Northern Valley Yokuts lands continued with residential growth which increased after World War I and then greatly intensified after World War II. These activities have resulted in an existing significant adverse effect on archaeological resources, tribal cultural resources, and human remains. Similarly, continual development in Fresno and the San Joaquin Valley has resulted in the demolition of the area’s historical resources related to its early development. Cumulative development continues to contribute to the disturbance of cultural resources.

Future development in the Plan Area could result in the loss or modification of buildings or structures that have not yet been evaluated for historical significance. Therefore, the cumulative loss of historic resources within the Plan Area is considered significant. Also, the proposed plan, in combination with other development in the region, could contribute to ongoing substantial adverse changes in the significance of unique archaeological resources, human remains, and tribal cultural resources resulting from urban development and conversion of natural lands. Cumulative development could result in potentially significant archaeological resources, human remains, and tribal cultural resources impacts.

Proper planning and appropriate mitigation can help to capture and preserve knowledge of such resources and can provide opportunities for increasing our understanding of the past environmental conditions and cultures by recording data about sites discovered and preserving artifacts found. Federal, state, and local laws are also in place that protect these resources in most instances. Even so, it is not always feasible to protect these resources, particularly when preservation in place would make projects infeasible, and for this reason the cumulative effects of past and present projects in the San Joaquin Valley could result in a potentially significant cumulative impact on cultural resources. Compliance with California Health and Safety Code Section 7050.5 and Public Resources Code Section 5097, as well as CEQA Section 21080.3.2 and Section 21084.3(a) and the City’s continuing notifications to the local tribes of all projects, would ensure that treatment and disposition of the cultural and tribal cultural re sources, including human remains occurs in a manner consistent with the California Native American Heritage Commission guidance. Thus, the proposed plan’s contribution to cumulative impacts to human remains would not be cumulatively considerable, and this cumulative impact would be
less than significant. With implementation of Mitigation Measures

4.5-2a, 4.5-2b, and 4.5-2c, adverse effects on currently known archeological resources and potentially newly discovered archeological resources would be avoided or mitigated. With implementation of these measures, the Cumulative Impacts Ascent Environmental
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proposed plan would not contribute to a cumulative loss of archaeological resources , and this cumulative impact would be less than significant. Regarding historic resources, implementation of Mitigation Measure 4.5-1 would require a historic structure report and evaluation of resources prior to ground-disturbing activities and would require all report recommendations be implemented to offset the SCSP’s contribution. However, it is possible that a historic building would need to be demolished or altered in such a way that it would no longer convey its historic significance. Therefore, the proposed plan’s potential contribution to cumulative historic resource impacts would be cumulatively considerable. Because no additional mitigation is available beyond what is identified in this EIR, the cumulative impact would be significant and unavoidable.

5.4.6 Energy
The geographic area considered for cumulative impacts related to energy use includes the Pacific Gas and Electric (PG&E) service area. PG&E employs various programs and mechanisms to support provision of gas and electricity services to new development; to recoup costs of new infrastructure, connection fees are typically charged through standard billings for services.

Cumulative development would receive electricity and natural gas service provided by PG&E. These projects would also consume energy related to transportation and construction. These projects would be required to implement energy-efficiency measures in accordance with Title 24 to reduce energy demand. Given the large amount of development identified in the region, it is possible that even with implementation of Title 24 measures, inefficient and wasteful energy consumption could occur. Given that cumulative development would be required to adhere to Title 24 measures and General Plan policies, cumulative development would not contribute to potential cumulative impacts associated with the potential inefficient, wasteful, and unnecessary consumption of energy within other parts of the PG&E service area. As described in Impact 4.6-1, in Section 4.6, “Energy,” according to Appendix F of the State CEQA Guidelines, the means to achieve the goal of conserving energy include decreasing overall per capita energy consumption, decreasing reliance on natural gas and oil, and increasing reliance on renewable energy sources. As described in Impact 4.6-1, the proposed plan would not result in wasteful or inefficient use of energy. Therefore, the proposed plan would not contribute to cumulative impacts related to energy use, and the cumulative impact would be
less than significant.

As described in Impact 4.6-2, in Section 4.6, “Energy,” the proposed plan would result in a reduction in vehicle miles traveled (VMT) per service population relative to existing conditions and 2040 no project conditions. Additionally, the proposed plan would meet the mandatory electric vehicle (EV) charging requirements of the CALGreen Code and, therefore, promote the use of EVs. Implementing the proposed plan would also result in new development that would, at minimum, comply with 2022 California Energy Code Standards, and with the progressively more stringent requirements of future Energy Code standards. However, the proposed plan does not include any policies that address building zero net energy (ZNE) for future land uses. Therefore, the proposed plan would conflict with the energy-related measures of the City’s Greenhouse Gas Reduction Plan, which requires that commercial projects achieve ZNE electricity. While the City cannot guarantee future industrial businesses would source their natural gas from renewable resources due to limitations regarding enforceability and availability of renewable natural gas to power heavy industrial processes, which could comprise the majority of the proposed plan, implementation of Mitigation Measures 4.3-1b, 4.3-1c, 4.3-1g, 4.3-1h, 4.3-1i, 4.3-1j, 4.3-1k, and 4.3-1l, 4.6-1a, 4.6-1b, 4.6-1c, and 4.6-1d would be sufficient to reduce this impact to a less-than-significant level if otherwise not prescribed. Therefore, the proposed plan would not contribute to cumulative impacts related to a conflict with the City’s GHGRP and the cumulative impact would be
less than significant.

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5.4.7 Geology, Soils, and Mineral Resources

SEISMIC AND GEOLOGIC HAZARDS
The geographic context for cumulative impacts related to seismic and geologic hazards include the Plan Area and the City of Fresno.

Seismic hazards affecting cumulative projects are expected to be moderate due to the low to moderate historic ground shaking in the region, and the distance to known active faults. As described in Section 4.7 , “Geology, Soils, and Mineral Resources,” Fresno, like much of California, is within a seismically active region, which could be susceptible to strong seismic ground shaking. Surface fault rupture, landslides, lateral spreading, subsidence, collapse, and expansive soils, however, are not likely to occur in the region because of the distance to active faults. The County has not been specifically evaluated for the potential for liquefaction. Impacts related to seismic and geologic hazards would not be cumulatively considerable because the geographic context is generally site -specific, rather than cumulative in nature. Notwithstanding, development in Fresno and the greater region has been regulated by the California Building Code (CBC) and local building codes, which ensure that structures are designed and engineered to site-specific conditions. Each site where present and reasonably foreseeable projects would occur has unique geologic considerations that would also be subject to uniform site development and construction standards consistent with the CBC and local building codes. Accordingly, cumulative impacts would be less than significant.

As discussed in Section 4.7, a site-specific geotechnical report would be prepared for individual projects that would be implemented under the proposed plan. Future development under the proposed plan would incorporate the design and engineering recommendations contained in the site-specific geotechnical report, which would account for the unique geotechnical factors affecting individual project sites and conform to the requirements of the CBC and local building code requirements. Therefore, the proposed plan would not contribute to cumulative impacts related to seismic and geologic hazards; the impact would be less than significant.

EROSION AND LOSS OF TOPSOIL
As described in Section 4.7, “Geology, Soils, and Mineral Resources,” the Plan Area is not within an area of steep slopes or within a generalized erosion hazard area. However, development in the Plan Area involving substantial ground disturbance and earth-moving activities or changes to drainage patterns would have potential to result in soil erosion or the loss of topsoil.

Cumulative projects would likely involve ground-disturbing construction activities, which may contribute to erosion and loss of topsoil throughout the Plan Area. Under the National Pollutant Discharge Elimination System (NPDES) permit program, projects that disturb more than 1 acre of land are required to prepare a storm water pollution prevention plan (SWPPP) and implement associated best management practices (BMPs) that are specifically designed to reduce construction-related erosion. The SWPPP and BMPs would be submitted to the Central Valley Regional Water Quality Control Board in compliance with the statewide National Pollutant Discharge Elimination System General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities (Construction General Permit) (Order 2009-009-DWQ as amended by Order 2012-0006-DWQ). In addition, construction activities would be subject to SJVAPCD rules regarding dust control, which would reduce the potential for erosion and sedimentation. Once operational, the potential for erosion would be reduced because areas of bare ground would be landscaped or hardscaped and projects would be required to incorporate post -construction stormwater management strategies to reduce the potential for erosion from new development and redevelopment . Therefore, the contribution to cumulative erosion impacts from present and reasonably foreseeable projects would be negligible.

In combination with cumulative development, development under the proposed plan would not exacerbate the potential for erosion and loss of topsoil within the Plan Area. Impacts related to erosion and loss of topsoil would be negligible because the development under the proposed plan would be subject to the NPDES permit program and SJVAPCD requirements described above. The proposed plan would not involve operational activities with potential to result in erosion or loss of topsoil. Therefore, implementation of the proposed plan would not contribute to cumulative impacts related to erosion and loss of topsoil; the cumulative impact would be less than significant.

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PALEONTOLOGICAL RESOURCES
As described in Section 4.7, “Geology, Soils, and Mineral Resources,” geologic deposits that underlie the Plan Area may be considered to have a high paleontological sensitivity. Construction of development projects within the Plan Area could require ground disturbance within previously undisturbed soils and in areas of high sensitivity for paleontological resources.

Prior to the adoption of regulations pertaining to the protection of paleontological resources (e.g., California Public Resources Code sections 5097.5 and 30244), past development within the Plan Area has contributed to the loss of important paleontological resources. Cumulative development continues to contribute to the disturbance and loss of paleontological resources. This represents an existing significant cumulative impact.

Development under the proposed plan would increase the potential for destruction of paleontological resources within the Plan Area. However, development under the proposed plan would be required to comply with Mitigation

4.7-5, which specifies procedures to protect paleontological resources. Under Mitigation Measure 4.7-5, any paleontological resources of significance that are recovered during construction activities would be provided to an institution or person who is capable of providing long-term preservation to allow future scientific study. Other future development would be required to implement similar measures in compliance with California Public Resources Code Sections 5097.5 and 30244 and other local regulations governing the protection of paleontological resources.

Therefore, implementation of the proposed plan would not contribute to cumulative impacts related to paleontological resources; the cumulative impact would be less than significant.

5.4.8 Greenhouse Gas Emissions and Climate Change
The discussion of greenhouse gas (GHG) emissions associated with the project and related infrastructure for Impacts

4.8-1 and 4.8-2 in Section 4.8, “Greenhouse Gas Emissions and Climate Change,” is inherently a cumulative impact analysis. GHG emissions from one project cannot, on their own, result in changes in climatic conditions; therefore, the emissions from one project must be considered in the context of their contribution to cumulative global emissions.

The analysis of Impacts 4.8-1 and 4.8-2 concluded that the proposed plan would result in GHG emissions during both construction and operation of plan development implemented over the planning period. It would result in a less- than-significant VMT impact (i.e., 33 percent below a 2015 baseline), which would align with the California Air Resources Board’s (CARB) direction in Appendix D of the 2022 Scoping Plan to reduce VMT statewide. However, the proposed plan would allow for natural gas usage for commercial, residential, and industrial land uses and does not provide a standard for future land uses to meet the Tier 2 voluntary requirements of the CALGreen Code. Therefore, the proposed plan would not align with CARB’s direction to decarbonize buildings or electrify the mobile source sector. For these reasons, the proposed plan would not be consistent with the 2022 Scoping Plan and would generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment or conflict with state GHG reduction goals. Implementation of Mitigation Measures 4.3-1b, 4.3-1c, 4.3-1g, 4.3-1h, 4.3-1i,

4.3-1l, 4.3-1m, 4.6-2a, 4.6-2b, 4.6-2c, 4.6-2d, 4.8-1a, and 4.8-1b would reduce the proposed plan’s operational GHG emissions; however, the City cannot guarantee future industrial businesses would source their natural gas from renewable resources due to limitations regarding enforceability. Given that heavy industrial uses comprise the majority of the Plan Area and would generate substantial emissions during operation, the proposed plan’s contribution to cumulative GHG impacts would be
cumulatively considerable. Because no additional mitigation is available beyond what is identified in this EIR, the cumulative impact would be significant and unavoidable.

5.4.9 Hazards and Hazardous Materials
The geographic area considered for cumulative impacts related to hazards and hazards materials is the Plan Area. As described in Section 4.9, “Hazards and Hazardous Materials,” the proposed plan would result in no impact related to airport hazards or wildland fires. Therefore, it would not contribute to any cumulative impacts related to these topics .

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construction activities would be managed consistent with applicable federal, state, and local laws to limit exposure and clean up the contamination. In addition, the use, storage, transport, and disposal of hazardous materials would be managed in accordance with applicable federal and state requirements to limit risk of exposure. Cumulative development in the vicinity of the proposed plan would create similar hazardous material effects during standard construction activities. Current and reasonably foreseeable projects would also be required to comply with measures that would minimize and/or avoid exposure of hazardous materials to people or the environment (similar to Mitigation Measures 4.9-1a through 4.9-1i) recommended for the proposed plan). Therefore, there would be no cumulative impact associated with hazardous materials use, storage, transport, or accidental spills.

Implementation of the proposed plan would not impair an adopted emergency response plan or emergency evacuation plan; however, construction activities associated with future development within the Plan Area would involve truck traffic and temporary land/shoulder closures in work zones that could result in temporary land closures on certain roads, increased traffic, and other roadway conditions that could interfere with or slow down emergency vehicle access and services. Implementation of Mitigation Measure 4.9-4 would reduce potential impacts to emergency access such that they would not be cumulatively considerable. Current and reasonably foreseeable projects would also be required to comply with measures that would minimize and/or avoid impacts related to emergency access.

Therefore, the proposed plan would not contribute to cumulative impacts related to hazards and hazardous materials. The cumulative impact would be less than significant.

5.4.10 Hydrology and Water Quality
Cumulative impacts on hydrology and water quality need to be considered in the context of the San Joaquin Valley Basin. Previous, on-going, and future development in the City of Fresno and Fresno County have contributed to additional demands on groundwater resources and available water supply, surface and groundwater water quality impacts, and regional increases in peak drainage flows from increased impervious surfaces associated with development.

SURFACE WATER AND GROUNDWATER QUALITY
As identified in Impact 4.10-1 in Section 4.10, “Hydrology and Water Quality,” construction and operational activities associated with future development under the proposed plan could degrade the quality of stormwater flows and potentially degrade downstream water quality. Development under the proposed plan would be required to comply with applicable requirements related to water quality, including on-site stormwater detention/retention and materials handling, during construction and operation. Compliance with these regulations would reduce the potential for construction and operation of development associated with the proposed plan to violate water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality. Similarly, cumulative development projects would be required to comply with state and local water quality laws and regulations implemented to protect surface water and groundwater resources, including the Fresno Metropolitan Flood Control District’s (FMFCD) Storm Water Quality Management Plan, NPDES permit, General Plan policies, and Fresno Municipal Code requirements. Therefore, the proposed plan would not contribute to cumulative water quality impacts and the cumulative impact would be
less than significant.

GROUNDWATER RECHARGE
The City overlays the Kings Subbasin, a high-priority and critically overdrafted basin managed by North Kings Groundwater Sustainability Agency (NKGSA). A groundwater sustainability plan (GSP) for the Kings Subbasin was adopted in 2023 and contains projects and management actions that would bring the subbasin into sustainability by 2040. Future development in the Plan Area would not impede implementation of projects or management actions included in the NKGSA GSP. Additionally, land uses included in the proposed plan would demand less water supply, including groundwater, than the land uses assumed in the 2014 General Plan, which was used to develop assumptions included within the NKGSA GSP. In addition, as described above, future development within the Plan Cumulative Impacts Ascent Environmental
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Area would be required to comply with FMFCD’s Storm Water Quality Management Plan, NPDES p ermit, General Plan policies, and Fresno Municipal Code requirements, which would provide for infiltration of stormwater and reduce the potential for Plan Area development to adversely affect groundwater resources. Cumulative development projects would also be required to comply with these state and local water quality laws and regulations to protect groundwater resources. Therefore, the proposed plan would not contribute to cumulative groundwater depletion and the cumulative impact would be less than significant.

DRAINAGE AND SURFACE RUNOFF
Implementation of development under the proposed plan would increase impervious surfaces in the Plan Area, which could subsequently increase stormwater runoff volumes and velocities, exceed capacity of existing drainageways, and create downstream flooding. The protective General Plan policies and Municipal Separate Storm Sewer System Permit for Fresno County would require any future development in the Plan Area as well as cumulative development projects to implement stormwater management measures to reduce stormwater runoff such that peak runoff flow rates are reduced; stormwater runoff is infiltrated, evapotranspired, and/or captured and used on- site to reduce site runoff for smaller storm events into municipal systems; and increases in volumetric runoff would be retained to prevent increased downstream flooding. Additionally, the SCSP storm drain system would be designed to accommodate buildout conditions, so that new development would not generate runoff that could exceed the capacity of the system. With implementation of these measures, the proposed plan would not contribute to cumulative drainage impacts and the cumulative impact would be
less than significant.

FLOOD HAZARD
The Plan Area contains flood hazard and dam inundation areas. However, compliance with the Fresno Flood Plain Ordinance, General Plan policies, and existing safety regulations would be required for the implementation of development under the proposed plan, resulting in low-risk release of pollutants due to inundation. Cumulative development projects would also be required to comply with these state and local laws and regulations. Therefore, the proposed plan would not contribute to cumulative flood hazards and the cumulative impact would be less than
significant.

5.4.11 Land Use and Planning
The cumulative context for land use and planning is the Plan Area and portions of the City of Fresno and unincorporated Fresno County adjacent to the Plan Area. Impacts related to consistency with land use plans or policies would generally be localized and would not generally combine to result in cumulative impacts. The thresholds of significance for land use impacts consider whether a project would physically divide an established community or conflict with any applicable land use plan or policy adopted for the purpose of reducing or avoiding environmental impacts. Such conflicts are inherently site specific and are addressed by individual projects.

As discussed in Impact 4.11-1 in Section 4.11, “Land Use and Planning,” development under the proposed plan would not physically divide an established community. Approximately 5 percent of the Plan Area is occupied by residential uses, and the residences are located primarily in pockets of development along the outer edges of the area. The locations and extent of residences in the Plan Area would not change substantially under the proposed plan. No major roadways or any other development that could divide a community is proposed under the plan. In addition, the network of bicycle paths and trails and the network of sidewalks would be expanded under the plan, providing greater connectivity throughout the Plan Area. Additionally, the General Plan EIR concluded that continued implementation of the approved General Plan would ensure there is not an existing cumulative impact related to division of established communities. Therefore, the proposed plan would not contribute to cumulative division of an established community and the cumulative impact would be less than significant.

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reduce potential impacts on sensitive uses located adjacent to industrial areas. Further , the SCSP would not conflict with a habitat conservation plan or natural community conservation plan. Therefore, the proposed plan would not contribute to cumulative conflicts with land use plans and policies and the cumulative impact would be less than significant.

5.4.12 Noise
The geographic scope of the cumulative noise analysis is limited by the range of potential noise impacts. Noise impacts tend to be localized; therefore, noise impacts for traffic and stationary noise sources are limited to approximately 500 feet from the source.

CONSTRUCTION NOISE
Noise dissipates rapidly from its source; however, cumulative impacts from construction-generated noise could result if construction activities of other planned projects were to take place in close enough proximity to proposed plan- generated construction such that noise effects would combine to result in substantial increases in noise at the same sensitive receptors. With regards to cumulative construction noise, and noise in general, the addition of two similar noise levels results in a 3-decibel (dB) increase, which is considered perceptible by most people. And, when a louder noise level is combined with a lower noise level, a less than 3-dB increase would occur (i.e., 65 dB plus 60 dB equals 66 dB).

Thus, for a perceptible increase in cumulative construction noise to occur, similar noise levels from two different construction sites would need to combine at the same sensitive receptor to result in a cumulative increase in noise.

Because details of individual development projects adjacent to the Plan Area are currently unknown, it is not possible to quantify future cumulative construction noise impacts that could occur if multiple developments were to be constructed simultaneously, which could constitute a significant cumulative noise impact. The proposed plan’s construction noise could combine with other nearby anticipated development such that a considerable cumulative increase in noise would occur. Development of the proposed plan would occur over the next 15 or more years (buildout by 2040) and would result in various levels of construction throughout the Plan Area. Implementation of Mitigation Measure 4.12-1a would provide substantial reductions in daytime and nighttime construction noise levels; however, construction noise could nonetheless temporarily reach high levels and disrupt sensitive receptors, depending on their proximity throughout buildout of the proposed plan. Consequently, while the construction activities would follow various noise mitigation measures and ordinances, the proposed plan’s contribution to cumulative construction noise impacts would be
cumulatively considerable. Because no additional mitigation is available beyond what is identified in this EIR, the cumulative impact would be significant and unavoidable.

VIBRATION
Cumulative impacts from construction-generated vibration could result if other future planned construction activities were to take place very close to other construction activities and cumulatively combine with construction vibration from the proposed plan. Operational vibration sources include operations on the Union Pacific Railroad (UPRR) and BNSF tracks. However, impacts would be isolated to new receptors constructed close to these existing sources. In addition, depending on the specific land use at industrial sites, operational activities could result in vibration sources such as from heavy-duty trucks traveling on truck routes or from new stationary equipment.

Vibration associated with construction and operational activities is of primary concern within proximity (e.g., 550 feet) of sensitive land uses. At increasing distances from the source, vibration levels dissipate rapidly and have less potential to cause disturbance to people or damage to structures. In addition, vibration generated from construction is typically associated with pile-driving activities that only occur during discrete phases of construction and for intermittent and brief periods at a time. For these reasons, even with additional large development projects and plans anticipated for future development, vibration impacts would remain local and would not combine with vibration source from other construction activities even if construction activities at other future development were to occur simultaneously with proposed plan construction activities. Further, project-generated vibration levels would be Cumulative Impacts Ascent Environmental
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reduced to the extent feasible with implementation of Mitigation Measure 4.12-2a, which limits vibration activities to less sensitive times of the day and requires the use of quieter alternatives to impact pile driving. Therefore, because vibration levels generated by cumulative development projects would be limited to the vicinity of construction activities for those projects, and because vibration impacts of development proposed under the proposed plan would be minimized to the extent feasible, cumulative construction-generated vibration impacts would be less than significant.

Operation of future projects could result in truck-generated vibration impacts on existing sensitive receptors and— though unlikely—future sensitive uses could be developed within the small areas of land in the proposed Business Park and Residential land use designations adjacent to existing railroad tracks . Implementation of Mitigation Measure

4.12-2b through 4.12-2d would reduce operational vibration impacts to the extent feasible and require future development to be designed and located in a manner that minimizes vibration exposure to existing and new sensitive receptors. However, given that the details of future developments under the plan and potential truck routes are yet unknown, it is possible that such uses, even with mitigation, could disrupt sensit ive receptors. Therefore, the proposed plan’s contribution to cumulative operational vibration noise impacts would be cumulatively considerable.

Because no additional mitigation is available beyond what is identified in this EIR, the cumulative impact would be significant and unavoidable.

OPERATIONAL NOISE (STATIONARY AND TRANSPORTATION)
Cumulative noise levels could be affected by additional buildout of surrounding land uses and increases in vehicular traffic on affected roadways.

Regarding stationary noise increases, the proposed plan would result in land use development that typically includes stationary noise sources such as noise from mechanical equipment, such as heating, ventilation, and air conditioning (HVAC) units; backup emergency generators; vehicular and human activity; parking lots; loading docks; and delivery activities at commercial/industrial land uses. As discussed in Impact 4.12-3 in Section 4.12, “Noise,” the proposed plan is designed to buffer residentially designated areas with less intensive land uses (e.g., Business Park) such that new industrial uses would not be located within distances that could expose existing sensitive receptors to excessive stationary noise levels. However, exact types of development, locations, building footprints, and building orientations are yet unknown; therefore, it is possible that new stationary noise sources could result in excessive noise levels at sensitive receptors and exceed applicable City of Fresno standards. Implementation of Mitigation Measures 4.12-3a through 4.12-3e would reduce noise exposure from existing and new stationary sources; however, the impact would remain significant and unavoidable and could combine with other off-site stationary sources to result in considerable increases in noise. Thus, the proposed plan’s contribution to cumulative operational noise impacts from stationary sources would be
cumulatively considerable. Because no additional mitigation is available beyond what is identified in this EIR, the cumulative impact would be significant and unavoidable.

In addition, traffic generated by future planned development in the region would result in additional traffic -related noise on surrounding roadways. Development of the Plan Area could result in new and expanded roadways to serve future development as well as increases in long-term traffic and associated noise increases on existing affected roadways. Existing and future development within and near the Plan Area could be exposed to substantial increases in traffic noise levels that exceed City residential noise standards of 65 A-weighted decibels (dBA) day-night average noise level Community Equivalent Noise Level (dBA Ldn/CNEL). Future development could result in the construction of sensitive uses (e.g., houses, schools, churches, hospitals) near existing or future roads that generate substantial traffic noise. In addition, new development of sensitive uses could occur near the existing UPRR and BNSF tracks, exposing these new receptors to noise levels that exceed applicable noise standards. Implementation of Mitigation Measures

4.12-2b, 4.12-3a, and 4.12-3b would reduce noise exposure from transportation sources; however, the proposed plan could nonetheless result in exceedance of the 65 dBA Ldn/CNEL transportation noise standard for sensitive uses on many roads. Further, combined with traffic from other development in the area, additional increases in transportation noise could occur. Thus, the proposed plan’s contribution to cumulative traffic volumes in the area would result in additional substantial increases in noise as well as additional noise sources within the vicinity. The proposed plan’s contribution would be cumulatively considerable. Because no additional mitigation is available beyond what is identified in this EIR, the impact would be significant and unavoidable.

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5.4.13 Population and Housing
For population and housing, the cumulative setting includes the City of Fresno, including the Plan Area, and Fresno County. Currently, the Plan Area consists of a population of approximately 1,130 residents (City of Fresno 202 4). The General Plan does not project any new housing in the Plan Area; therefore, no population growth is expected for the Plan Area. However, the City is projected to add an estimated 176,000 to 216,000 new residents between 2022 to 2040 (City of Fresno 2024). As described in Section 4.13, “Population and Housing,” development of the proposed plan would generate 313 new residents by 2040, which represents 0.14 to 0.17 percent of the City’s forecasted growth.

Cumulative development would result in the continued development of Fresno and surrounding areas, including residential, commercial, and industrial development. The general plans and other planning documents prepared by the jurisdictions within Fresno County would be required to develop land use plans that comply with state law and that would accommodate the existing and forecasted population. Consistent with stat e law, these planning documents would be required to provide adequate housing to accommodate fo recasted numbers of people within the jurisdiction, and displaced development, if any, would be replaced primarily within the jurisdiction. Further, new development would be required to address potential environmental impacts as part of individual project review. As such, cumulative development would not induce substantial unplanned population growth, either directly or indirectly. Because cumulative projects would comply with applicable land use plans to provide adequate development within a jurisdiction, cumulative impacts would be less than significant.

As described in Section 4.13, “Population and Housing,” the proposed plan would not induce substantial unplanned population growth, either directly (i.e., by proposed new unplanned homes) or indirectly (i.e., by the extension of roads or other infrastructure), or displace substantial numbers of people or housing . The proposed plan has the potential to generate future development of approximately 12,021,744 square feet (sf) of non -residential uses and 91 new residential dwelling units, resulting in a minimal population increase of approximately 313 new residents by 2040.

Consistent with the General Plan, the purpose of the proposed plan is to create jobs for the City. The City is projected to add nearly 70,000 employees between 2022 and 2040 (City of Fresno 2024). Therefore, implementation of the proposed plan will create jobs for the City’s projected growth in population and employment. Consistent with the General Plan, the proposed plan would promote a better balance of jobs and housing within the City. The additional growth of industrial, office, and retail and the small number of assumed residential units is consistent with citywide planning efforts. Thus, the proposed plan would not contribute to a cumulative impact related to population and
housing and the cumulative impact would be less than significant.

5.4.14 Public Services and Recreation
As described in Section 4.14, “Public Services and Recreation,” the proposed plan would result in no impact related to new or physically altered school facilities or the increased use of parks and recreational facilities. Therefore, it would not contribute to any cumulative impacts related to these facilities.

FIRE PROTECTION
The geographic scope for the analysis of cumulative impacts related to fire protection facilities includes the Fresno Fire Department (FFD) service area. FFD conducts a regular budgeting process where future facility and staffing needs are identified and addressed. All cumulative projects within the FFD service area would be required to comply with the Municipal Code, General Plan policies and actions, and applicable specific plan policies that address fire protection services, including payment of public safety impact fees to provide funding for adequate fire equipment, vehicles, and facilities to meet the needs of Fresno residents and employees. Because past and present development will comply with all ordinances and policies, and there are mechanisms in p lace to ensure provision of adequate service, there would be no significant cumulative condition with respect to fire protection services. Therefore, cumulative impacts would be less than significant.

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As discussed under Impact 4.14-1, in Section 4.14, “Public Services and Recreation,” implementation of the proposed plan may increase demand for fire protection services that could require new or expanded facilities. Expansion of an existing fire station or construction of a new facility would involve minor land clearing, grading, installation of utilities , and building construction, generally on a modest-sized lot (approximately 2.5 acres). Construction activities and duration would be typical of such facilities and would be required to comply with applicable City policies and regulatory requirements to reduce adverse environmental effects. For these reasons, there is no evidence to suggest that such construction would result in unmitigable, adverse effects on the environment. As noted above, new development in the Plan Area would be required to comply with the policies and actions in the General Plan and Specific Plan as well as the Municipal Code, specifically impact fire facilities fees, to ensure that fire protection services are adequate as future development is proposed. Therefore, the proposed plan would not contribute to a cumulative impact related to fire protection and emergency response facilities and services and the cumulative impact would be less than significant.

POLICE PROTECTION
The geographic context for the analysis of cumulative impacts related to police protection facilities includes the Fresno Police Department (FPD) service area. All cumulative projects within the FPD service area would be required to comply with City ordinances and the General Plan and applicable specific plan policies and actions that address police protection services, including payment of police facilities impact fees to provide funding for adequate police equipment, vehicles, and facilities to meet the needs of Fresno residents and employees. Therefore, cumulative impacts would be less than significant.

As discussed under Impact 4.14-2, in Section 4.14, “Public Services and Recreation,” development of the proposed plan would result in an increased demand for law enforcement services. A new centralized police headquarters and communications center building, two new police substations, and a new 911 emergency operations dispatch center are proposed in the City, but it is not clear if these would be sufficient to meet the demand for law enforcement services associated with the proposed plan. If new or physically altered police facilities are required to adequately serve development within the Plan Area, expansion of an existing police station or construction of a new facility could involve minor land clearing, grading, installation of utilities, and building construction, generally on a modest -sized parcel. Construction activities and duration would be typical of such facilities and would be required to comply with applicable City policies and regulatory requirements to reduce adverse environmental effects. For these reasons, there is no evidence to suggest that such construction would result in unmitigable, adverse effects on the environment. As noted above, new development in the Plan Area would be required to comply with the policies and actions in the General Plan and Specific Plan as well as the Municipal Code, specifically police facilities fees, to ensure that police protection services are adequate as future development is proposed. Therefore, the proposed plan would not contribute
to a cumulative impact related to police protection facilities and services and the cumulative impact would be less than significant.

5.4.15 Transportation and Circulation
The geographic scope of analysis for cumulative impacts related to VMT includes Fresno County, the City of Fresno, and the Plan Area. This cumulative VMT analysis does not rely on a list of specific pending, reasonably foreseeable development proposals in the vicinity of the Plan Area; rather, it relies on planned transportation improvement projects as well as projected demographic growth built into the Fresno Activity Based Travel Demand Model (Fresno ABM). The geographic scope for the analysis of the impacts related to a program, plan, ordinance, or policy addressing the circulation system, substantially increasing hazards due to geometric features or incompatible uses, and inadequate emergency access, would be different than the geographic scope for the V MT analysis, and would include past, present, and reasonably foreseeable future projects that would that would have the potential to affect the same transit, roadway, bicycle, and pedestrian facilities surrounding the Plan Area and the interconnected circulation system of Fresno County.

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TRANSIT SERVICE AND FACILITIES, BICYCLE FACILITIES, AND PEDESTRIAN

FACILITIES
Combined with other cumulative development in the area, the demand for transit service and facilities, bicycle facilities, and pedestrian facilities is anticipated to increase. As described under Impact 4.15 -1 in Section 4.15, “Transportation and Circulation,” implementation of the proposed plan would be consistent with City General Plan and Active Transportation Plan policies as well as Municipal Code requirements applicable to transit, bicycle, and pedestrian facilities and services. Additionally, proposed SCSP policies would encourage the implementation of pedestrian safety improvements and transportation demand management strategies for employees to support the use of alternative modes of transportation. Therefore, the proposed plan would not contribute to a cumulative impact related to transit service and facilities, bicycle facilities, and pedestrian facilities and the cumulative impact would be less than significant.

VEHICLE MILES TRAVELED
The travel demand model used to analyze the proposed plan reflects the changes to future growth patterns assumed as part of the proposed plan. The discussion of VMT impacts associated with the proposed plan in Impact 4.15-2 addresses VMT generated by the proposed plan based on an efficiency threshold that is aligned with long-term goals and relevant plans. As detailed in the Governor’s Office of Planning and Research Technical Advisory, “A project that falls below an efficiency-based threshold that is aligned with long-term environmental goals and relevant plans would have no cumulative impact distinct from the project impact. Accordingly, a finding of a less -than-significant project impact would imply a less than significant cumulative impact, and vice versa (OPR 2018: 6).” Therefore, the VMT impacts identified in Section 4.15, are inherently cumulative. As shown in Table 4.15-1, the SCSP Transportation Impact Analysis found that VMT would be reduced under 2035 with project conditions as compared to both 2035 no project and 2015 existing conditions due to the proposed plan’s creation of employment opportunities. The proposed plan would result in a VMT per service population of 29.87 as compared to 44.88 VMT per service population under existing conditions, which is a 33 percent decrease in VMT. Therefore, the proposed plan would not contribute to a
cumulative impact related to VMT and the cumulative impact would be less than significant.

TRANSPORTATION HAZARDS
In general, transportation hazards are site-specific and not cumulative in nature. As detailed in Section 4.15, “Transportation and Circulation,” the proposed plan’s industrial and other uses, which would be developed incrementally over time, would substantially increase traffic, including truck traffic, in the Plan Area. All transportation related infrastructure improvements constructed under the proposed plan would be subject to and designed in accordance with all applicable design standards and would be reviewed by City staff before implementation.

Additionally, Chapter 5 of the SCSP identifies development standards with which individual projects would be required to comply. These include provisions for truck routing, parking, and internal project site signage and wayfinding. Therefore, compliance with these standards would ensure that development associated with the proposed plan would not result in transportation hazards or incompatible uses. Additionally, individual project contractors would be required to develop and implement a traffic control plan in accordance with policy 210.01 (“Traffic Control Policies and Procedures”) of the City of Fresno Public Works Department Policies and Procedures to minimize hazards during construction. Other nearby projects within the public right-of-way would also be required to comply with the City’s construction standards, thus, minimizing the potential for cumulative transportation-related hazards. Therefore, the proposed plan would not contribute to a cumulative impact related to transportation hazards and the cumulative impact would be less than significant.

EMERGENCY ACCESS
In general, emergency access impacts are site-specific and not cumulative in nature. As detailed in Section 4.15, “Transportation and Circulation,” subsequent projects and transportation improvements that would be developed under the proposed plan incrementally over time would be required to meet State and local standards pertaining to Cumulative Impacts Ascent Environmental
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emergency access, including design and safety regulations provided in the 2022 California Fire Code and City Municipal Code and subject to review by emergency service agencies. Other nearby projects would also be required to comply with the applicable fire apparatus access standards, thus, minimizing the potential for cumulative impacts to emergency access. Therefore, the proposed plan would not contribute to a cumulative impact related to emergency access and the cumulative impact would be less than significant.

5.4.16 Utilities and Service Systems
For utilities and service systems, the cumulative context includes the service areas of the various service providers.

Past and present development in the geographic context has resulted in an increase in demand for water, wastewater treatment, stormwater capacity, landfill capacity, and energy facilities to adequately serve development. The respective service providers have responded to these increasing demands by constructing new infrastructure. In addition, each utility type has a management plan in place that addresses future projected demands for planned development. These management plans are routinely updated to account for new development. Construction of individual infrastructure projects has likely resulted in discrete impacts in various issue areas, such as aesthetics, air quality, biological resources, etc. Therefore, there could be a cumulatively significant impact from con struction of past and present infrastructure projects. Future development could contribute to this cumulative impact.

UTILITY INFRASTRUCTURE
Future development in Fresno would increase the demand for new and expanded utility infrastructure, the relocation or construction of which could cause significant environmental effects. As described under Impact 4.16-1 in Section

4.16, “Utilities and Service Systems,” implementation of the proposed plan would require relocation or construction of new or expanded water, wastewater treatment, stormwater drainage, electric power, natural gas, and telecommunications facilities. New infrastructure would generally be constructed within existing roadways or would consist of short connections to existing pipelines, and impacts associated with construction of new or extended utility infrastructure are analyzed throughout this EIR. The project’s anticipated demands would be within the capacity of the existing utility infrastructure. Similarly, cumulative development would be required to demonstrate an adequate capacity of utilities and services before project approval. Cumulative development would be required to con tribute fair share funding to fund necessary expansion of utility infrastructure and conduct appropriate CEQA analyses to evaluate potential environmental impacts of utility relocation, construction, or expansion. Because of these requirements and the proposed plan’s small percent of the remaining capacity of the existing utility infrastructure, the proposed plan would not contribute
to a cumulative impact related to utility infrastructure and, therefore, the cumulative impact would be less than significant.

WATER SUPPLY
The geographic scope for the cumulative water supply analysis is the City of Fresno, including the Plan Area, and the groundwater basins from which the Plan Area derives water. Population growth and local regulation of associated development within the City prevent the occurrence of existing cumulative utilities and service system impacts by implementing the Fresno General Plan that includes a policy framework that ensures adequate capacity exists to support proposed development.

Cumulative development in the Plan Area and beyond would result in increased demand for water supply. The City’s 2020 Urban Water Master Plan (UWMP) includes water demand projections for current water demands within the City and anticipated water demands associated with future development projects and planning areas within the City’s General Plan Sphere of Influence through 2045 (City of Fresno 2021). As described in Section 4.16, “Utilities and Service Systems,” and shown in Table 4.16-2, water demand within the City’s service area is not expected to exceed the City’s supplies in any normal, single dry, or multiple dry year between 2025 and 2045 (City of Fresno 2023).

Future development considered in the 2020 UWMP includes the Plan Area; however, the land uses in the City’s General Plan are not the same as those proposed in the SCSP. Thus, a water supply assessment was prepared for the Ascent Environmental Cumulative Impacts
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SCSP to evaluate whether adequate water supplies would be available for the Plan Area (City of Fresno 2023). As described under Impact 4.16-2 in Section 4.16, “Utilities and Service Systems,” future development of the proposed plan would demand less water than the currently approved General Plan land uses within the Plan Area (17,300 acre- feet per year [af/yr] versus 18,400 af/yr). As such, there would be a greater surplus of water supply for the City during normal, dry, and multiple-dry years through 2045 with implementation of the proposed plan compared with the existing approved land uses considered in the 2020 UWMP. Therefore, the proposed plan would not contribute to a cumulative impact related to water supply and the cumulative impact would be less than significant.

WASTEWATER TREATMENT
The geographic area that is considered for cumulative impacts on wastewater treatment services consists of the Fresno/Clovis Regional Wastewater Reclamation Facility (RWRF) service area boundary. The permitted wastewater treatment capacity of the RWRF is currently 91.5 million gallons per day (mgd) annual monthly average flow, and 101 mgd as a maximum monthly average flow (City of Fresno 2020). Given that the RWRF currently treats approximately 68 mgd, there is a remaining treatment capacity of 23.5 mgd.

Cumulative projects that would contribute demand for wastewater treatment at the RWRF include development projects within the service area boundary. As described in Section 4.16.2, “Environmental Setting,” the General Plan EIR assumes that several upgrades to the RWRF would be completed to accommodate future development associated with continued implementation of the approved General Plan. These upgrades include expansion of the RWRF, construction of a recycled water facility at the RWRF, expansion of the N orth Fresno WRF, and construction of a wastewater treatment facility within the Southeast Development Area.

Wastewater generation from development anticipated under the proposed plan would be approximately 11.6 mgd average annual flows, 13.4 mgd peak day dry weather flows, and 15.1 mgd for peak month wet weather flows. The RWRF, which has a remaining capacity of 23.5 mgd, would be able to accommodate these wastewater flow rates in addition to existing commitments. Therefore, because adequate treatment capacity is available at the RWRF for wastewater flows associated with the proposed plan, and upgrades to the ove rall wastewater treatment system in the City are planned to accommodate General Plan buildout, the proposed plan would not contribute to a cumulative
impact related to wastewater treatment and the cumulative impact would be less than significant.

SOLID WASTE
The cumulative setting for solid waste services consists of the American Avenue Landfill and City of Clovis Landfill service areas, which includes Fresno County. As discussed in Section 4.16.2, “Environmental Setting,” the American Avenue Landfill has a maximum permitted capacity of 32,700,000 cubic yards and a remaining capacity of 29,358,535 cubic yards, with an estimated closure date of August 31, 2031. The City of Clovis Landfill is anticipated to close in 2047. Future development in Fresno County would further increase the amount of waste processed and disposed of at these landfills. Although the capacity of the landfills are anticipated to serve existing and future development within the County, cumulative development could reduce the life of the landfills, which would require expansion of these facilities. Because cumulative development would contribute to the need to expand the landfills or solid waste would need to be transported elsewhere, cumulative demand for solid waste services would be a potent ially significant cumulative impact.

Individual cumulative development projects would be required to comply with state and local statutes and regulations related to solid waste. Additionally, the City is implementing diversion programs and the Fresno City Council passed a resolution that commits the City to the goal of a Zero Waste goal by 2025 (City of Fresno 2020).

On-going programs would continue to reduce landfill contributions, consistent with the California Integrated Waste Management Act, Assembly Bill (AB) 341, Senate Bill (SB) 1374, AB 1826, and SB 1383. While General Plan Policy RC-11- b requires the City to develop a strategic and operations plan for fulfilling the City Council resolution committing the City to a Zero Waste goal, it is not clear when zero waste goals will be met. With out attainment of zero waste goals, development under the proposed plan may generate waste in excess of capacity at the American Avenue Landfill, which is planned for closure in 2031. Implementation of Mitigation Measure 4.16-4 would require the City to identify Cumulative Impacts Ascent Environmental
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additional available landfill capacity for future development before approval of individual development projects. Thus, the proposed plan would not contribute to a cumulative impact related to solid waste disposal and the cumulative impact would be less than significant.

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6 ALTERNATIVES

6.1 INTRODUCTION
The California Code of Regulations (CCR) Section 15126.6(a) (State CEQA Guidelines) requires EIRs to 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 range of potentially feasible alternatives that will avoid or substantially lessen the significant adverse impacts of a project, and foster informed decision making and public participation. An EIR is not required to consider alternatives that 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.” This section of the State CEQA Guidelines also provides guidance regarding what the alternatives analysis should consider.

Subsection (b) further states the purpose of the alternatives analysis is as follows:

Because an EIR must identify ways to mitigate or avoid the significant effects that a project may have on the environment (Public Resources Code [PRC] Section 21002.1), the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly.

The State CEQA Guidelines require that the EIR include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed project. If an alternative would cause one or more significant effects in addition to those that would be caused by the project as proposed, the significant effects of the alternative must be discussed, but in less detail than the significant effects of the proje ct as proposed (CCR Section 15126.6[d]).

The State CEQA Guidelines further require that the “no project” alternative be considered (CCR Section 15126.6[e]).

The purpose of describing and analyzing a no project alternative is to allow decision makers to compare the impacts of approving a proposed project with the impacts of not approving the proposed project. If the no project alternative is the environmentally superior alternative, CEQA requires that the EIR “…shall also identify an environmentally superior alternative among the other alternatives.” (CCR Section 15126[e][2]).

In defining “feasibility” (e.g., “… feasibly attain most of the basic objectives of the project …”), CCR Section 15126.6(f) (1) states, in part:

Among 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). No one o f these factors establishes a fixed limit on the scope of reasonable alternatives.

In addition, PRC, Section 210181(a)(3) provides factors for the decision maker to consider in determining whether an alternative is feasible. For example, it states “Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR.”
In determining what alternatives should be considered in the EIR, it is important to consider the objectives of the project, the project’s significant effects, and unique project considerations. These factors are crucial to the development of alternatives that meet the criteria specified in Section 15126.6(a). Although, as noted above, EIRs must contain a discussion of “potentially feasible” alternatives, the ultimate determination as to whether an alternative is Alternatives Ascent Environmental
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feasible or infeasible is made by the lead agency’s decision-making body, here the City Council. (See PRC Sections 21081.5, 21081[a] [3].)

6.2 CONSIDERATIONS FOR SELECTION OF ALTERNATIVES

6.2.1 Attainment of Project Objectives
As described above, one factor that must be considered in selection of alternatives is the ability of a specific alternative to attain most of the basic objectives of the project (CCR Section 15126.6[a]). Chapter 3, “Project Description,” identifies the project objectives, which are also described below.

The overarching vision of the South Central Specific Plan (SCSP) is to improve the City’s overall economic competitiveness, support employment opportunities for residents, and maintain and improve community livability.

The objectives that would help realize this vision are as follows:
 Stimulate economic development. Promote inclusive and sustainable economic growth and attract development that focuses on emerging markets and new technologies.
 Provide diverse employment. Create diverse employment opportunities, including an accessible and resilient employment zone.
 Minimize environmental and neighborhood impacts. Consider project-specific environmental effects (e.g., truck traffic, air emissions, noise and vibration) on existing and potential future sensitive receptors and impose measures to minimize such impacts.

 Preserve existing operations: Preserve the viability of existing industrial and manufacturing operations in the Plan Area.
 Protect against incompatible uses. Protect existing and future development from adverse impacts associated with incompatible uses.
 Implement infrastructure improvement: Improve Plan Area infrastructure (e.g., transportation, sewer, water) to expand the supply of “shovel-ready” sites.
 Be a good neighbor. Participate in “good neighbor” policies to provide residents with clear and transparent access to information regarding community development and assist in addressing disputes and concerns.  State Routes 99 and 41 as Gateways. Transform State Routes 99 and 41 as gateways into the City. Utilize landscaping and architectural design to improve the visual quality when entering the P lan Area.

6.2.2 Environmental Impacts of the South Central Specific Plan The proposed plan would result in development of a variety of land use types, primarily industrial and commercial/business park. Sections 4.1 through 4.16 of this Draft EIR address the environmental impacts of implementation of the proposed plan. Consistent with State CEQA Guidelines Section 15126.6, potentially feasible alternatives were developed with consideration of avoiding or lessening the significant , and potentially significant, adverse impacts of the plan, as identified in Chapter 4 of this Draft EIR and summarized below. If an environmental issue area analyzed in this Draft EIR is not addressed below, it is because no significant impacts were identified for that issue area. In summary, the significant impacts of the proposed plan are:
 Aesthetics: Implementation of the proposed plan would result in increases of densities and intensification primarily of industrial and commercial land uses within the Plan Area, which would result in substantial changes in the existing visual character. No feasible mitigation measures are available to mitigate the impact to a less -than- significant level; therefore, the impact of the proposed plan and its considerable contribution to the cumulative impact on the existing visual character would be significant and unavoidable. The proposed plan would introduce Ascent Environmental Alternatives
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new sources of light and glare associated with new buildings and facilities. Although residential development is relatively sparse in the Plan Area and the SCSP assumes relatively little new residential development that could be affected by additional light and glare, such lighting could nonetheless contribute to indirect lighting/glare on adjacent land uses that could adversely affect daytime or nighttime views and result in additional skyglow, resulting in a significant impact. After mitigation, light/glare impacts would be less than significant.  Agriculture and Forestry Resources: Implementation of the proposed plan would result in conversion of Prime Farmland and Farmland of Statewide Importance to non-agricultural uses. This impact would be significant.

Mitigation measures are included in the EIR to require compensatory farmland to be preserved. However, the mitigation measure would not replace the farmland that is converted; therefore, this proposed plan and cumulative impact would be
significant and unavoidable. Additionally, implementation of the proposed plan is likely to result in conversion of existing Farmlands that are enrolled in Williamson Act contracts to non -agriculture uses. Because future development could result in conflict with a Williamson Act contract and no feasible mitigation is available, the impact of the proposed plan and its considerable contribution to the cumulative impact would be significant and unavoidable.
 Air Quality: The proposed plan, which comprises many future development projects, would generate construction and operational emissions of criteria air pollutants and ozone precursors exceeding the San Joaquin Valley Air Pollution Control District’s (SJVAPCD) thresholds of significance. In addition, implementation of the proposed plan would result in significant impacts related to exposure of sensitive receptors to toxic air contaminants (TACs) and resultant cancer risk. After mitigation, air quality impacts would be less than significant, except for TAC impacts. The impact of the proposed plan and its considerable contribution to the cumulative impact would be significant and unavoidable.
 Biological Resources: Future development under the proposed plan may include ground disturbance, vegetation removal, and overall conversion of land cover, which would have potentially adverse effects on biological resources. This would include potentially significant impacts related to the disturbance, injury, or mortality of several special-status plant and wildlife species, if present; reduced reproductive productivity of these species; and contribution to loss of species habitat. Development under the proposed plan could also result in potentially significant impacts related the degradation or loss of riparian habitat (e.g., reduction of vegetation cover, trampling, alteration of root structure), if it is present on a particular project site; and the loss of state or federally protected wetland habitat, which includes seasonal wetlands. After implementation of mitigation measures, impacts to biological resources would be
less than significant.
 Cultural and Tribal Cultural Resources: Because the Plan Area could contain unrecorded historic sites, implementation of the proposed plan could result in a significant impact related to historic resources if such a resource exists and damage to or destruction of the resource occurred. After implementation of mitigation measures, the impact of the proposed plan and its considerable contribution to the cumulative impact would remain
significant and unavoidable. Additionally, ground-disturbing activities could result in discovery or damage of yet undiscovered archaeological resources and previously unknown human remains, which would result in potentially significant impacts. After implementation of mitigation measures, impacts to these resources would be less than significant.
 Energy: The proposed plan would reduce vehicle miles traveled (VMT) per service population relative to existing conditions and 2040 no project conditions, meet the mandatory electric vehicle (EV) charging requirements of the CALGreen Code and promote the use of EVs, and result in new development that would comply with 2022 California Energy Code Standards and with the progressively more stringent requirements of future Energy Code standards. However, because the proposed plan does not include any policies that address building zero net energy (ZNE) for future land uses, the proposed plan would conflict with the energy -related measures of the City’s Greenhouse Gas Reduction Plan (GHGRP), which requires that commercial projects achieve ZNE electricity.

After implementation of mitigation measures, this impact would be less than significant.
 Geology, Soils, and Mineral Resources: Construction of future development under the proposed plan could require ground disturbance within previously undisturbed soils and in areas of high sensitivity for paleontological Alternatives Ascent Environmental
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resources. Such development has the potential to destroy a unique paleontological resource or site or unique geologic feature, which would be a potentially significant impact. After mitigation, impacts to paleontological resources would be less than significant.
 Greenhouse Gas Emissions and Climate Change: The proposed plan would result in greenhouse gas (GHG) emissions during both construction and operation of plan development. Because neither the City nor SJVAPCD have recommended thresholds for determining the significance of GHG emissions, consistency with the 2022 Scoping Plan is used to determine whether implementing the proposed plan would result in a cumulatively considerable contribution to climate change. The proposed plan would not align with the Transportation Electrification and Building Decarbonization Priority Areas included in the 2022 Scoping Plan. Therefore, the proposed plan would generate GHG emissions that may have a significant impact on the environment, would conflict with state GHG reduction goals, and would cumulatively contribute to global climate change. After implementation of mitigation measures, the greenhouse gas emissions impact of the proposed plan and its considerable contribution to the cumulative impact would remain significant and unavoidable.  Hazards and Hazardous Materials: Construction and operation of development under the proposed plan would result in potentially significant impacts related to the routine transport, use, and disposal of hazardous materials and reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment; potential for hazardous emissions or handling of hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school; potential to be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, create a significant hazard to the public or the environment; and potential to impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. After implementation of mitigation measures, impacts related to hazards and hazardous materials would be less than
significant.
 Hydrology and Water Quality: Future development under the proposed plan could degrade the quality of stormwater flows and potential downgrade downstream surface water quality, and result in an increase of impervious surface and runoff. In addition, the Plan Area contains flood hazard and dam inundation areas.

Development under the proposed plan would be required to comply with applicable requirements related to water quality, groundwater, flood hazards. With compliance with existing regulations and applicable plans such as the Basin Plan, hydrology and water quality impacts would be less than significant.
 Land Use and Planning: Development under the proposed plan would not physically divide an established community. Implementing the proposed plan would require a general plan amendment to allow for the proposed land use changes, as some of the proposed land uses differ from the general plan. With the approval of the amendment, the SCSP would be consistent with the City of Fresno General Plan and would not conflict with any other plans or policies. Therefore, land use impacts would be less than significant.
 Noise: Future construction activities could result in a substantial (i.e., 5 dB) temporary or periodic increase in noise during daytime or nighttime hours at existing and future sensitive land uses. Depending on the specific location of future land development and specific land uses located close to high -volume roads, exterior and interior noise limits could be exceeded at existing and future sensitive land uses. In addition, operation of future projects could result in truck-generated vibration impacts on sensitive receptors and—though unlikely—sensitive uses could be developed within the small areas of land in the proposed Business Park and Residential land use designations adjacent to existing railroad tracks, operational vibration impacts would be significant. After implementation of mitigation measures, the noise impact of the proposed plan and its considerable contribution to the cumulative impact would remain significant and unavoidable.  Population and Housing: Implementation of the proposed plan would create jobs for the City’s projected growth in population and employment. The proposed plan would not induce substantial unplanned population growth, either directly (i.e., by proposed new unplanned homes) or indirectly (i.e., by the extension of roads or other infrastructure) or displace substantial numbers of people or housing. Therefore, population and housing impacts would be less than significant.

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 Public Service and Recreation: Under the proposed plan, development would be intensified within the Plan Area and may increase demand for fire protection services and law enforcement services that could require new or expanded facilities. Construction activities and duration would be typical of such facilities and would be required to comply with applicable City policies and regulatory requirements to reduce adverse environmental effects. For these reasons, there is no evidence to suggest that such construction would result in unmitigable, adverse effects on the environment. The projected future development of the proposed plan would include an estimated 91 new residential dwelling units by 2040, which is anticipated to support approximately 279 new residents at buildout.

The projected number of residents in the Plan Area would be relatively small and dispersed and would not require the construction or expansion of school or recreations facilities. Therefore, public services and recreation impacts would be
less than significant.
 Transportation and Circulation: The proposed SCSP policies would encourage the construction of bicycle and pedestrian safety improvements and transportation demand management strategies for employees to support the use of alternative modes of transportation. There is no evidence to suggest that the SCSP or future development under the plan would conflict with any applicable program, plan, ordinance, or policy addressing the circulation system. The SCSP TIA found that under horizon year with project conditions, the proposed plan would result in a VMT per service population of 29.87 as compared to 44.88 VMT per service population under existing conditions. Because the proposed plan would result in a 33 percent decrease in VMT, the proposed plan would not conflict or be inconsistent with CEQA Guidelines Section 15064.3. Although the nature and location of specific development projects under the proposed plan cannot be known, the plan would substantially increase industrial uses in the Plan Area and implement commercial and minor residential devel opment. Thus, the industrial and other uses would substantially increase traffic, including truck traffic, in the Plan Area. Subsequent projects under the plan would be required to comply with all applicable design standards and would be subject to review by City staff to ensure these requirements are met. In addition, with adherence to local and State emergency access and design standards and regulations, implementation of the proposed plan would not adversely affect emergency vehicle access or response times. Therefore, the proposed plan would not result in inadequate emergency access. With compliance with existing regulations and applicable plans transportation and circulation impacts would be
less than significant.
 Utilities and Service Systems: Implementation of the proposed plan would require relocation or construction of new or expanded water, wastewater treatment, stormwater drainage, electric power, natural gas, and telecommunications facilities. New infrastructure would generally be constructed within existing roadways or would consist of short connections to existing pipelines and would be developed as part of buildout of the proposed plan. The impacts associated with such infrastructure connections would be typical of such construction and would result in are generally assessed as part of the proposed development under the SCSP (e.g., construction-related air, noise, GHG, and transportation effects), within the context of this EIR, and there is no evidence to suggest that such construction would result in additional significant environmental effects . Future development of the proposed plan would demand less water than the currently approved General Plan land uses within the Plan Area. As such, there would be a greater surplus of water supply for the City during normal, dry, and multiple-dry years through 2045 with implementation of the proposed plan compared with the existing approved land uses considered in the 2020 UWMP. In addition, Implementation of the proposed plan would allow for development of industrial, commercial office, retail, and residential uses, which would generate solid waste. Without attainment of zero waste goals, development under the proposed plan may generate waste in excess of capacity at the American Avenue Landfill, which is planned for closure in 2031. After implementation of mitigation measures, impacts related to utilities and service systems would be less than significant.

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6.3 ALTERNATIVE CONSIDERED BUT NOT EVALUATED FURTHER

6.3.1 Off-Site Alternative
Off-site alternatives generally involve moving a project to another location. As a land use plan and not a defined project, an off-site alternative to the SCSP is infeasible. Implementation of the SCSP cannot occur within an area completely outside the existing Plan Area. Further, one of the primary project objectives is to create diverse employment opportunities, including an accessible and resilient employment zone, that take advantage of the Plan Area’s central location in California and the San Joaquin Valley as well as its proximity to Fresno’s downtown, railway lines, and State Routes 99 and 41. Other project objectives include preserving the viability of existing industrial and manufacturing operations in the Plan Area and transforming State Routes 99 and 41 as gateways into the City. Finding a suitable alternative site with a comparable geographic footprint, which also maintains similar access to existing highways, roadways, utilities, services, and population centers, is not feasible. Furthermore, South Central Fresno is an area that has long been planned for growth. Beginning as early as 1918, the City of Fresno recognized the Plan Area’s economic importance and from 1956 onward has planned for industrial development through the Fresno General Plan.

Proximity to downtown Fresno is critical to support the proposed employment-generating uses and preservation of existing industrial and manufacturing operations. For these reasons, the off-site alternative is infeasible and dismissed from further evaluation.

6.4 ALTERNATIVES SELECTED FOR DETAILED ANALYSIS
The following discussion summarizes the alternatives evaluated and then includes a detailed description of each alternative followed by a discussion that compares each of the proposed plan’s significant impacts to the relative impact that would likely result from the alternative. Because these alternative discussions are comparative, they do not necessarily identify significance conclusions (such as “significant” or “less than significant”); rather, they identify the level of impact relative to the proposed plan’s significant impact. These comparisons use the following conclusions:
 “Avoids” is used when an alternative avoids the proposed plan’s significant impact by reducing the effect below the threshold of significance.
 “Less” is used when an alternative reduces the proposed plan’s significant impact, but not below the threshold of significance.
 “Similar” is used when the alternative’s impact is approximately the same as the proposed plan’s impact.  “Greater” is used when the alternative increases the severity of the proposed plan’s significant impact, or results in a new significant impact that would not occur as a result of proposed plan implementation.

The following alternatives are evaluated in this Draft EIR:
 No Project/General Plan Land Use Alternative. This alternative assumes that the SCSP would not be approved and that buildout of the planned land uses in the adopted General Plan occurs. The total level/acreage of development for this alternative would be the same as the SCSP, but the mix of land uses would be different. No residential uses are included in this alternative.
 Farmland Conservation Alternative. This alternative would reduce the proposed plan’s significant impact related to conversion of farmland by conserving specific parcels of farmland within the Plan Area. No future development would be permitted on farmland designated for conservation. This would reduce the total amount of development allowed in the Plan Area by about 18 percent compared with the SCSP and would include a similar mix of land uses, including some residential.
 Reduced Plan Area Alternative. This alternative would reduce the Plan Area acreage and not provide for development within the sphere of influence outside the existing City boundary. The acreage of the Plan Area would be reduced by approximately 2,343 acres, for a total of 3,224 acres, instead of 5,567 acres as compared to Ascent Environmental Alternatives
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South Central Specific Plan Draft EIR 6-7
the proposed plan, resulting in a commensurate reduction in development capacity. This would reduce the total amount of development allowed in the Plan Area by about 42 percent compared with the SCSP and would include a similar mix of land uses, including some residential.

In addition to the CEQA alternatives, the alternatives section includes analysis of two project options put forward by various community members and businesses. The following options are provided to compare the impacts from these options to the project for purposes of full disclosure:
 Community Plan Alternative. This alternative reflects the community’s desire to increase quality of life in the Plan Area by decreasing land use intensity. This alternative would include more residential units (739 units compared with 91 units under the SCSP) and would decrease land use intensity surrounding sensitive uses. Additional ly, this alternative would increase the amount of office and retail, while reducing the amount of industrial land use.  Business Plan Alternative. This alternative reflects the business community’s desire to maximize economic growth in the Plan Area by designating industrial as the primary land use. No residential uses are included in this alternative.

Further details on the alternatives and an evaluation of their environmental effects relative to the SCSP are provided below.

ALTERNATIVES DEVELOPMENT PROCESS
As described in Chapter 3, “Project Description,” a community outreach and engagement process was conducted for the SCSP in 2020 to produce a vision and guiding principles centered around balancing the needs of industrial users, ensuring a diverse employment base, and minimizing impacts on the environment and neighborhoods. The outcome of the engagement process was development of three alternative land use maps: one reflecting a plan focused on residential and community-serving development (Community Alternative), a second focused almost exclusively on industrial development (Business Alternative), and a third that represents a blending of the Community and Business alternatives (Blended Alternative and the proposed plan). As described above, however, these options were not developed for purposes of CEQA, that is, to reduce the potential for significant environmental effects. Therefore, they are identified as “options” rather than “alternatives” for purposes of this analysis.

During preparation of this Draft EIR, the No Project Alternative was defined and included to comply with CEQA requirements, and the Farmland Conservation Alternative and Reduced Plan Area Alternative were developed to address the significant impacts identified for the SCSP as proposed.

DEVELOPMENT DENSITY
As in Chapter 3, “Project Description,” Economic Planning Systems, Inc. (EPS) was retained by the City to conduct a market analysis of demand for non-residential development in the plan area by 2040 to help inform the development assumptions to be used in the specific plan and alternatives. Growth projections were calculated using development assumptions and floor area ratios outlined in the General Plan for various land use types (see Table 3-5 in Chapter 3, “Project Description”).

Table 6-1 shows potential development anticipated to be generated within the Plan Area for the proposed plan and alternatives by 2040. As shown in Table 6-1, the proposed plan and alternatives would primarily generate growth for retail, office, industrial, and (for some alternatives) residential units. Other land uses would be permitted in accordance with the General Plan land use designations, including, for example, mixed use, open space, and public facilities; however, these are not shown in Table 6-1 because they are not the focus of the SCSP. While the total development estimated under the proposed plan and alternatives would be the same (12,021,744 square feet), the mix of land uses would be different, as shown in Table 6-1 and in the figures in this chapter. For all alternatives except the No Project/General Plan Land Use Alternative, the City would be required to amend the General Plan to allow for the proposed land use changes.

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Table 6-1 Development Projections for the Proposed Plan, Alternatives, and Options (2022-2040) Land Use
No Project/ General
Plan Land Use
Alternative (sq. ft.)
Proposed Plan
(sq. ft.)
Farmland
Conservation
Alternative
Reduced Plan
Alternative
Community Plan
Option (sq. ft.)
Business Plan
Option (sq. ft.)
Retail 340,492 866,676 710,674 502,672 3,871,826 277,375 Office 578,790 578,790 474,608 335,698 4,008,553 578,790 Industrial 11,102,462 10,576,278 8,672,548 6,134,241 4,141,365 11,165,579 Total Non-
Residential 12,021,744 12,021,744 9,857,830 6,972,612 12,021,744 12,021,744 Residential Units 0 91 units 75 units 53 units 739 units 0 Source: Prepared by Ascent Environmental in 2024.

Table 6-2 shows the residential and job growth anticipated to occur within the Plan Area with implementation of the proposed plan and alternatives.

Table 6-2 Anticipated Population and Job Growth for the Proposed Plan and Alternatives (2022-2040) Land Use
No
Project/General
Plan Land Use
Alternative
Proposed Plan
Farmland
Conservation
Alternative
Reduced Plan
Alternative
Community Plan
Option
Business Plan
Option
Total Residential
Growth 0 313 persons 258 persons 182 persons 2,262 persons 0 Food
(Restaurants) 18 employees 183 employees 33 employees 106 employees 2,650 employees 19 employees Industrial 11,102 employees 10,576
employees 8,673 employees 6,134 employees 4,141 employees 11,166 employees Office 1,929 employees 1,928 employees 1,582 employees 1,118 employees 13,010 employees 1,929 employees Retail 670 employees 1,624 employees 1,421 employees 942 employees 6,154 employees 543 employees Total Job Growth 13,702
employees 14,311 employees 11,709 employees 8,300 employees 25,955 employees
13,657
employees
Source: Prepared by Ascent Environmental in 2024.

6.4.1 No Project/General Plan Land Use Alternative
Under CEQA, the No Project Alternative must consider the effects of forgoing the project altogether. The purpose of analyzing the No Project Alternative is to allow decision makers to compare the impacts of the proposed project versus no project. The No Project Alternative can consist of either a “no development” alternative, under which no development occurs in the project area, or an alternative under which development is assumed to occur consistent with the presiding development plan and according to existing land use designations, or both.

The Plan Area has already been slated for growth per the approved Fresno General Plan. As such, this Draft EIR analyzes a no project alternative that assumes development consistent with the land use designations in the existing General Plan. Figure 6-1 shows the planned land uses under the No Project/General Plan Land Use Alternative.

Table 6-3 presents a side-by-side comparison of the projected buildout (to 2040) for the General Plan versus the proposed plan.

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Table 6-3 Development Projections for the No Project/General Plan Land Use Alternative and Proposed Plan (2022-2040)
Land Use Proposed Plan (sq. ft.) No Project/General Plan Land Use Alternative (sq. ft.) Difference (sq. ft.)
Retail 866,676 340,492 -526,184
Office 578,790 578,790 0
Industrial 10,576,278 11,102,462 526,184
Total Non-Residential 12,021,744 12,021,744 0
Residential Units 91 units 0 -91 units
Source: Prepared by Ascent Environmental in 2024.

The No Project/General Plan Land Use Alternative differs from the proposed plan with respect to the types of urban land uses identified. The General Plan does not include residential land uses in the Plan Area. Further, the General Plan designates a majority of the Plan Area for industrial uses, whereas the proposed plan would reallocate 526,184 square feet of proposed industrial land use to retail. The General Plan includes less than half of the amount of retail than would be developed under the proposed plan. Notwithstanding these differences, the total development under the General Plan and the proposed plan would be the same (12,021,744 square feet) .

Table 6-4 shows the residential and job growth anticipated to occur within the Plan Area with implementation of the General Plan versus the proposed plan. This alternative would generate no residential growth and less job growth than the proposed plan (4 percent less [609/14,311]).

Table 6-4 Anticipated Population and Job Growth for the No Project/General Plan Land Use Alternative and Proposed Plan (2022-2040)
Land Use Proposed Plan No Project/General Plan Land
Use Alternative Difference
Total Residential Growth 313 persons 0 -313 persons
Food (Restaurants) 183 employees 18 employees -165 employees Industrial 10,576 employees 11,102 employees 526 employees Office 1,928 employees 1,929 employees 1 employees
Retail 1,624 employees 670 employees -954 employees
Total Job Growth 14,311 employees 13,702 employees -609 employees Source: Prepared by Ascent Environmental in 2024.

Alternatives Ascent Environmental
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Source: Image produced and provided by the city of Fresno, Adapted by Ascent Environmental in 2023.

Figure 6-1 No Project/General Plan Land Use Alternative: Planned Land Use

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COMPARISON OF NO PROJECT/GENERAL PLAN LAND USE ALTERNATIVE AND

PROPOSED PLAN IMPACTS
The General Plan designates the entire Plan Area for future development. Therefore, because the No Project/General Plan Land Use Alternative includes the same amount of land identified for development, it would require a similar amount of construction and would result in a similar amount of conversion of undeveloped land to urban use, compared with the proposed plan. The following discussion focuses on the potential for this alternative to reduce the proposed plan’s significant impacts.

Aesthetics
Implementation of the No Project/General Plan Land Use Alternative would result in development of urban land uses within the same footprint as the proposed plan. The primary difference between the No Project/General Plan Land Use Alternative and the proposed plan is the types of land uses. Unlike the proposed plan, the No Project/General Plan Land Use Alternative does not specifically include residential land uses—the land use designations are nonresidential. Regarding the proposed plan’s significant impacts related to visual character and light and glare, this alternative would result in similar impacts due to the same footprint being developed with similar land uses and a large number of new light sources. For these reasons, the impacts to aesthetics would be similar between the proposed plan and this alternative, and this alternative would not eliminate the proposed plan’s significant and unavoidable impact related to visual character.

Agriculture and Forestry Resources
As described in Section 4.2, “Agriculture and Forestry Resources,” the Plan Area includes approximately 992 acres of Prime Farmland and Farmland of Statewide Importance as well as approximately 153 acres (located outside the existing City limits but within the City’s sphere of influence) under Williamson Act contracts. Because the total amount of future development (5,567acres) and the Plan Area footprint would remain unchanged between the No Project/General Plan Land Use Alternative and the proposed plan, this alternative would result in a similar amount of conversion of Important Farmland and farmland under Williamson Act contracts compared to the proposed plan, which are considered significant impacts. The impacts to agricultural resources would be similar between the proposed plan and this alternative, and this alternative would not eliminate the proposed plan’s significant and unavoidable impacts related to the conversion of farmland and conflicts with Williamson Act contracts.

Air Quality
Implementing the No Project/General Plan Land Use Alternative would result in a similar level of development within the same footprint as the proposed plan. Therefore, construction-related air pollutant emissions would be similar.

However, due to the different mix of urban land uses (less residential, less retail, more industrial), operational emissions would be greater due to the greater amount of industrial development compared to the proposed plan.

The overall impact related to air quality would be greater.

Biological Resources
Under the No Project/General Plan Land Use Alternative, the same amount of land would be developed with urban uses within the Plan Area as the proposed plan. Therefore, this alternative would have similar impacts compared to the proposed plan related to the disturbance, injury, or mortality of several special-status plant and wildlife species, if present; reduced reproductive productivity of these species; and contribution to loss of species habitat. Development under this alternative could also result in the degradation or loss of riparian habitat (e.g., reduction of vegetation cover, trampling, alteration of root structure), if it is present on a particular project site; and the loss of state or federally protected wetland habitat, which includes seasonal wetlands. The No Project/General Plan Land Use Alternative would generally result in similar impacts and would require similar mitigation measures compared to the proposed plan. Overall, impacts to biological resources would be similar.

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Cultural and Tribal Cultural Resources
The No Project/General Plan Land Use Alternative would result in development of the Plan Area , which could contain unrecorded historic sites. Thus, implementation of the No Project/General Plan Land Use Alternative could result in a significant impact related to historic resources if such a resource exists and damage to or destruction of the resource occurred. This impact would be similar to the proposed plan’s impact, and this alternative would not eliminate the proposed plan’s significant and unavoidable impacts to cultural resources.

Energy
Unlike the proposed plan, this alternative would not reduce VMT per service population relative to existing conditions and 2040 no project conditions (see discussion under “Transportation and Circulation,” below). This alternative would result in a similar level of development compared with the proposed plan; however, because less industrial land uses would be developed, energy demands would be less than those of the proposed plan. Similar to the proposed plan, it is assumed that this alternative would meet the mandatory EV charging requirements of the CALGreen Code and comply with 2022 California Energy Code Standards; however, also similar to the proposed plan, this alternative may conflict with the energy-related measures of the City’s GHGRP, which requires that commercial projects achieve ZNE electricity. This impact would be similar to the proposed plan’s impact, and this alternative would not eliminate the proposed plan’s significant and unavoidable impact related to energy.

Geology, Soils, and Mineral Resources
Implementation of this alternative would involve grading and other ground-disturbing activities similar to the proposed plan and on the same footprint. Therefore, this alternative would have similar impacts associated with seismic ground-shaking, soil erosion, geological hazards, expansive soils, and paleontological resources. The same mitigation measures required for the proposed plan would also be required for this alternative. Overall, impacts to geology, soils, and mineral resources would be similar.

Greenhouse Gas Emissions and Climate Change
Operational emissions of GHG generally correlate to the size and intensity of a project and the associated energy consumed and VMT. Implementation of the proposed plan would generate a considerable amount of GHG.

Implementation of mitigation measures identified in the EIR would substantially reduce on-site emissions; however, emissions levels would still be high (there is no City or SJVAPCD significance threshold). This alternative would result in a similar level of overall development as the proposed plan; however, operational GHG emissions would be greater than those of the proposed plan due to the greater amount of industrial development. Even assuming the same mitigation measures apply, the overall GHG emissions associated with operation of this alternative would likely be substantial. For these reasons, the GHG impact associated with the No Project/General Plan Land Use Alternative would be
greater compared to the impact resulting from the proposed plan.

Hazards and Hazardous Materials
Implementation of this alternative would involve the routine transport, use, and disposal of hazardous materials; potential for hazardous emissions or handling of hazardous materials within 0.25 mile of an existing or proposed school; potential to be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5; and potential to impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. The No Project/General Plan Land Use Alternative would generally result in similar impacts and would require similar mitigation measures compared to the proposed plan .

Overall, impacts related to hazards and hazardous materials would be similar.

Hydrology and Water Quality
The No Project/General Plan Land Use Alternative would have the same development footprint as the proposed plan, and construction associated with this alternative would require compliance with the same water quality regulations as the proposed plan. In addition, although there are differences between the land use types identified for this alternative compared to the proposed plan, the overall level of development would be similar, and this alternative Ascent Environmental Alternatives
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would also be required to comply with the same construction and operational regulations as the proposed plan.

Overall, impacts related to hydrology and water quality would be similar.

Land Use and Planning
Implementation of the No Project/General Plan Land Use Alternative would result in development of urban land uses within the same footprint as the proposed plan. Similar to the proposed plan, the No Project/General Plan Land Use Alternative would not divide an established community, nor would it conflict with plans adopted for the purpose of avoiding or mitigating a significant effect (including the City of Fresno General Plan and the City of Fresno Zoning Ordinance). No new residential land uses are proposed. Additionally, no major roadways or other development that could divide a community is proposed. Finally, implementation of the No Project/General Plan Land Use Alternative would not require a general plan amendment. No significant impacts related to land use and planning were identified for the proposed plan; therefore, this alternative would not reduce or avoid any significant impacts related to land use and planning associated with the proposed plan. Impacts would be similar between the proposed plan and this alternative.

Noise
Implementing the No Project/General Plan Land Use Alternative would result in a similar level of development within the same footprint as the proposed plan. Therefore, construction-related noise would be similar. Even though this alternative would include a different mix of urban land uses (less residential, less retail, more industrial), operational noise and traffic noise would also be similar to the proposed plan due to the development of over 12 million sq. ft. of nonresidential development, which is the same amount of development under this alternative and the proposed plan .

Overall, noise impacts would be
similar.

Population and Housing
The No Project/General Plan Land Use Alternative would not add as many jobs as the proposed plan and would not add any residences. Therefore, although the No Project/General Plan Land Use Alternative would result in substantial employment growth (although not as much as the proposed plan), it would result in no direct population growth associated with adding new residences to the area. Further, similar to the proposed plan, implementation of this alternative is not likely to displace substantial numbers of existing housing or people. No significant impacts related to population and housing were identified for the proposed plan; therefore, this alternative would not reduce or avoid any significant impacts related to population and housing associated with the proposed plan. Overall, impacts associated with the No Project/General Plan Land Use Alternative would be similar to those of the proposed plan.

Public Services and Recreation
The proposed plan would result in less-than-significant impacts related to public services and recreation. There is nothing peculiar about the land uses or overall development identified in the No Project/General Plan Land Use Alternative that differs from the proposed plan in a way that would change the potential impact to fire or police services. Overall, impacts related to public services and recreation would be similar.

Transportation and Circulation
Implementation of the No Project/General Plan Land Use Alternative would result in the development of less residential, less retail, and more industrial land uses compared with the proposed plan , all of which would generate vehicle trips. Regarding VMT, Table 4.15-1 in Section 4.15, “Transportation and Circulation,” indicates that the No Project/General Plan Land Use Alternative (which is shown in the table as “2035 no project” conditions) would generate 46.44 VMT per service population, which is an increase of 1.56 VMT or 3.5 percent from 2015 existing conditions (44.88 VMT) (TJKM 2023a). By comparison, the proposed plan is anticipated to generate 29.87 VMT per service population, a decrease from both 2015 existing conditions and 2035 no project conditions (TJKM 2023a). The decrease in VMT under the proposed plan is partially the result of the proposed land use mix within the Plan Area, but is also affected by the fact that the Plan Area would be a major employment center. Although the proposed plan would only increase residential uses by 91 dwelling units, it would create increased employment opportunities through the implementation of industrial and commercial development leading to improved proximity between the jobs in the Plan Area and surrounding housing by shortening driving distance and, therefore, reducing VMT . No Alternatives Ascent Environmental
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residential units would be included in this alternative; thus, it would not provide the same benefit of placing housing closer to jobs. Resulting VMT could be higher under this alternative compared to the proposed plan.

Similar to the proposed plan, there is no evidence to suggest that this alternative would conflict with any applicable program, plan, ordinance, or policy addressing the circulation system; substantially increase transportation hazards from design features or incompatible uses; or result in inadequate emergency access .

Overall, the impact related to transportation and circulation would be greater than the impact associated with the proposed plan and would likely result in a new significant impact related to VMT.

Utilities and Service Systems
Because of the slightly different mix of urban land uses (less residential, less retail, more industrial), implementation of the No Project/General Plan Land Use Alternative would result in greater demands for water and wastewater treatment, and a slightly reduced demand for solid waste disposal compared with the proposed plan.

As shown in Table 4.16-3 in Section 4.16, “Utilities and Service Systems,” implementation of the currently approved General Plan land uses within the Plan Area would result in greater water demand than the proposed plan ( 18,400 acre-feet/year [af/yr] versus 17,300 af/yr). The water supply assessment (WSA) prepared for the SCSP indicates that the water demand within the City’s service area is not expected to exceed the City’s supplies in any normal, single dry, or multiple dry year between 2025 and 2045 (City of Fresno 2023). Therefore, the City has sufficient water supplies to meet the water demands of either the No Project/General Plan Land Use Alternative or the proposed plan. With implementation of the proposed plan, however, there would be a greater surplus of water supply for the City during normal, dry, and multiple-dry years through 2045 compared with the existing approved land uses in the General Plan.

Wastewater generation from development anticipated under the proposed plan would be approximately 11.6 million gallons per day (mgd) average annual flows (AAF), 13.4 mgd peak day dry weather flows, and 15.1 mgd for peak month wet weather flows. Under the No Project/General Plan Land Use Alternative, wastewater flows from the Plan Area would be 12.8 mgd AAF, 14.7 mgd for peak day dry weather flows, and 16.6 mgd for peak month wet weather flows, which would be greater than those estimated for the proposed plan (Akel Engineering Group 2022). The Fresno/Clovis Regional Wastewater Reclamation Facility (RWRF), which has a remaining capacity of 23.5 mgd, would be able to accommodate the wastewater flow rates of either the No Project/General Plan Land Use Alternative or the proposed plan.

Under the proposed plan, annual municipal solid waste generation by new development in the Plan Area would be approximately 36.5 tons per day (Table 4.16-4). By comparison, the No Project/General Plan Land Use Alternative would generate approximately 32.7 tons per day given the different mix of land uses . Similar to the proposed plan, attainment of the City’s zero waste goals is uncertain and development may generate waste in excess of capacity at the American Avenue Landfill, which is planned for closure in 2031. Mitigation would be required to reduce this impact to a less-than-significant level.

Due to the greater demands for water and wastewater treatment, overall impacts related to utilities and service systems would be greater under the No Project/General Plan Land Use Alternative compared to those resulting from the proposed plan.

6.4.2 Farmland Conservation Alternative
Section 4.2, “Agriculture and Forestry Resources,” identifies significant impacts related to the loss of Important Farmland and potential conflicts with farmland under Williamson Act contracts. These significance determinations relate to the potential conversion of approximately 992 acres of Prime Farmland and Farmland of Statewide Importance as well as potential conflicts with approximately 153 acres (located outside the existing City limits but within the City’s sphere of influence) under Williamson Act contracts. The Farmland Conservation Alternative addresses these issues.

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The Farmland Conservation Alternative would reduce the proposed plan’s significant impacts related to agricultural resources by conserving specific parcels of farmland within the Plan Area. This alternative would conserve a total of approximately 992 acres of Important Farmland that would not be conserved under the proposed plan (Figure 6-2).

No future development would be permitted on farmland designated for conservation. The land identified for conservation was considered to balance highest value agricultural land, while providing a functional land use plan, and also maintaining contiguous agricultural parcels. It is important to note that although development would not be allowed in the land identified for conservation, ground disturbing activity consistent with agricultural uses would still be permitted.

This alternative would reduce the total amount of development allowed in the Plan Area by approximately 18 percent, compared with the proposed plan (4,575 acres vs. 5,567 acres), and would include a similar mix of land uses, including residential (Table 6-5).

Table 6-5 Development Projections for the Farmland Conservation Alternative and Proposed Plan (2022-2040)
Land Use Proposed Plan (sq. ft.) Farmland Conservation
Alternative (sq. ft.)1 Difference (sq. ft.)
Retail 866,676 710,674 156,002
Office 578,790 474,608 104,182
Industrial 10,576,278 8,672,548 1,903,730
Total Non-Residential 12,021,744 9,857,830 2,163,914
Residential Units 91 units 75 units 16 units
1 Estimates for the Farmland Conservation Alternative were generated using the assumption that the same mix of land uses included in the proposed plan would be developed on a smaller footprint (5,567-992=4,575). Thus, it is conservatively assumed that the Farmland Conservation Alternative would result in 18 percent less development (in all land use categories) compared to the proposed plan.

Source: Prepared by Ascent Environmental in 2024.

Table 6-6 shows the residential and job growth anticipated to occur within the Plan Area with implementation of the Farmland Conservation Alternative versus the proposed plan. This alternative would generate less residential growth (18 percent less [55/313]) and job growth (18 percent less [2,602/14,311]) than the proposed plan . The use regulations, permit requirements, and development standards for this alternative would be the same as the proposed plan.

Table 6-6 Anticipated Population and Job Growth for the Farmland Conservation Alternative and Proposed Plan (2022-2040)
Land Use Proposed Plan Farmland Conservation
Alternative1 Difference
Total Residential Growth 313 persons 258 persons 55 persons Food (Restaurants) 183 employees 33 employees 150 employees Industrial 10,576 employees 8,673 employees 1,903 employees Office 1,928 employees 1,582 employees 346 employees
Retail 1,624 employees 1,421 employees 203 employees
Total Job Growth 14,311 employees 11,709 employees 2,602 employees 1 Estimates for the Farmland Conservation Alternative were generated using the same growth assumptions used for the proposed plan. Thus, it is conservatively assumed that the Farmland Conservation Alternative would result in 18 percent less population and job growth compared to the proposed plan.

Source: Prepared by Ascent Environmental in 2024.

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Source: 2018 Fresno County data downloaded from the CA Department of Conservation in 2020; adapted by Ascent in 2023.

Figure 6-2 Farmland Conservation Alternative

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COMPARISON OF FARMLAND CONSERVATION ALTERNATIVE AND PROPOSED PLAN

IMPACTS
The Farmland Conservation Alternative includes approximately 992 acres that would remain in agricultural use, whereas the proposed plan would develop the entire Plan Area and would not designate any land for conservation.

Therefore, because the Farmland Conservation Alternative includes less land identified for development, it would require less construction and would result in less conversion of undeveloped land to urban use. The Farmland Conservation Alternative would result in an 18-percent reduction in the amount of development compared to the proposed plan. The following discussion focuses on the potential for this alternative to reduce the proposed plan’s significant impacts.

Aesthetics
Although the overall level of development would be less than under the proposed plan , the density of new development would be similar under the Farmland Conservation Alternative, resulting in a visual character that, although generally be consistent with the urbanized portions of the Plan Area. Would still be substantially altered.

This alterative would provide 992 acres of preserved farmland, which would reduce impacts related to the change in the character of the site (because less of the site would be developed); however, it would not substantially reduce the aesthetic impacts of development. Areas of abrupt transition from preserved farmland/open space land to developed land would still occur under this alternative. In addition, although the reduced level of potential development would result in a reduced level of night lighting, the extent of night lighting would still be considerable and would not avoid the proposed plan’s significant impact related to light and glare (although mitigation is available to reduce this impact to a less-than-significant level). However, less development under the alternative would result in moderately less light pollution than would occur under the proposed plan. Overall, impacts on aesthetics would be less than under the proposed plan.

Agriculture and Forestry Resources
The Farmland Conservation Alternative would conserve specific parcels of Important Farmland within the Plan Area, totaling approximately 992 acres, that would not be conserved under the proposed plan. Of this conserved farmland, approximately 153 acres are under Williamson Act contracts and, thus, no conflicts with this land would occur under this alternative. No future development would be permitted on farmland designated for conservation. Because Important Farmland would be conserved and no conflicts with lands under Williamson Act contracts would occur, the impacts of the Farmland Conservation Alternative
avoids the impact compared to those resulting from the proposed plan. Further, this alternative would eliminate the proposed plan’s significant and unavoidable impacts related to the conversion of farmland and conflicts with Williamson Act contracts.

Air Quality
Implementing the Farmland Conservation Alternative would result in a smaller development footprint and therefore substantially less development than would occur under the proposed plan. Construction- and operation-related air pollutant emissions would be considerably reduced. While agricultural operations also generate emissions of concern (e.g., dust, diesel, agricultural chemicals), the locations, quantities, and effects of such emissions in the areas assumed to be conserved under this alternative are unknown, so the net effect of displacement of agricultural by industrial uses is also unknown and therefore speculative. However, the development-related emissions associated with the Farmland Conservation Alternative would still be substantial for both construction and operation. Regarding exposure to TACs, the Farmland Conservation Alternative would result in less industrial development to which existing residents would be exposed, and both the proposed plan and Farmland Conservation Alternative would include few, if any, new residential units. Therefore, compared to the proposed plan, it would expose fewer sensitive receptors to substantial sources of TACs. The overall impact related to air quality would be less.

Biological Resources
Implementation of the proposed plan would result in significant, but mitigable, impacts related to the permanent loss of habitat for special-status-species and other sensitive habitat. Implementation of the Farmland Conservation Alternatives Ascent Environmental
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Alternative would result in fewer acres of developed land and the preservation of approximately 992 acres of farmland, which would result in benefits to special status species and their habitats . Implementation of this alternative would also involve less construction than the proposed plan (because of the smaller development footprint) and would therefore result in less likelihood that special-status species could be affected during construction. Mitigation measures required for this alternative would be similar to those required for the proposed plan. Overall, the biological resource-related impacts of the Farmland Conservation Alternative would be less compared to those resulting from the proposed plan.

Cultural and Tribal Cultural Resources
Implementation of the Farmland Conservation Alternative would result in fewer acres of developed land, and, therefore, there would be a minor reduction in the potential to damage unrecorded historic sites, but given the large amount of land that would still be developed under this alternative, the reduction would be inconsequential. Overall, the impacts of the Farmland Conservation Alternative would be similar to those under the proposed plan, and this alternative would not eliminate the proposed plan’s significant and unavoidable impacts to cultural resources.

Energy
As discussed under “Transportation and Circulation,” below, VMT from cars and light trucks c ould be higher under this alternative compared to the proposed plan because employment centers in the preserved agricultural areas would be smaller, potentially increasing commute distances for workers living farther from the region, but because this alternative would include less industrial development, truck traffic would be reduced. Because to its reduced area, this alternative would have lower energy demands compared with those of the proposed plan. Similar to the proposed plan, it is assumed that this alternative would meet the mandatory EV charging requirements of the CALGreen Code and comply with 2022 California Energy Code Standards; however, also similar to the proposed plan, this alternative may conflict with the energy-related measures of the City’s GHGRP, which requires that commercial projects achieve ZNE electricity. Although VMT may be somewhat higher and energy demands would be less under this alternative, the energy-related impact would be
less compared to that of the proposed plan; however,
implementing this alternative would not avoid the proposed plan’s significant and unavoidable impact related to energy that would occur under the proposed plan.

Geology, Soils, and Mineral Resources
Implementation of the Farmland Conservation Alternative would involve similar grading and other ground-disturbing activities as the proposed plan, but over a smaller footprint. Therefore, this alternative would have impacts that are similar in nature but reduced in magnitude in the following areas: seismic ground-shaking, soil erosion, geological hazards, expansive soils, and paleontological resources. The same mitigation measures required for the proposed plan would also be required for this alternative. Overall, the impacts of the Farmland Conservation Alternative would be
less compared to those resulting from the proposed plan.

Greenhouse Gas Emissions and Climate Change
Operational emissions of GHGs generally correlate to the size and intensity of a project and the associated energy consumed and VMT. Implementation of the proposed plan would generate a considerable amount of GHG emissions. Implementation of mitigation measures identified in the EIR would substantially reduce on -site emissions; however, emission levels would still be high (there is no City or SJVAPCD significance threshold) . Implementing the Farmland Conservation Alternative would result in less overall development than would occur under the proposed plan. With implementation of the same mitigation measures identified for the proposed plan, the overall GHG emissions associated with operation of this alternative would likely still be substantial, although not as substantial as under the proposed plan. For these reasons, the GHG impact associated with the Farmland Conservation Alternative would be
less compared to the impact resulting from the proposed plan.

Hazards and Hazardous Materials
Although a smaller amount of land would be developed under the Farmland Conservation Alternative, implementation of the alternative would still involve the routine transport, use, and disposal of hazardous materials; Ascent Environmental Alternatives
City of Fresno
South Central Specific Plan Draft EIR 6-19
potential for hazardous emissions or handling of hazardous materials within 0.25 mile of an existing or proposed school; potential to be located on a site included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5; and potential to impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. Implementing the Farmland Conservation Alternative would generally result in impacts that are smaller in nature to those of the proposed project but over a small area.

Mitigation measures similar to those identified for the proposed plan would still be required. Overall, impacts related to hazards and hazardous materials would be less than those of the proposed plan.

Hydrology and Water Quality
Although the Farmland Conservation Alternative would have a smaller overall development footprint and overall less development compared to the proposed plan, the development types would be similar, and construction and operation of this alternative would require compliance with the same water quality regulations required for the proposed plan. In addition, while agricultural operations also consume water and result in potential water quality impacts through erosion and use of agricultural chemicals, the variability, intensity, and locations of agricultural operations in the areas assumed to be conserved under this alternative are unknown, so the net water supply and quality effects of displacement of agricultural by industrial uses—which are also yet undefined—cannot be known and are therefore speculative. Overall, because levels of industrial development would be substantially reduced under the Farmland Conservation Alternative, impacts related to hydrology and water quality are considered to be less than
those of the proposed plan.

Land Use and Planning
Implementation of the Farmland Conservation Alternative would result in development of urban land uses within a smaller footprint compared to the proposed plan. As under the proposed plan, this alternative would not divide an established community, nor would it conflict with plans adopted for the purpose of avoiding or mitigating a significant effect (including the City of Fresno General Plan and the City of Fresno Zoning Ordinance). Fewer new residential units are proposed (75 units versus 91 units). Additionally, no major roadways or other development that could divide a community is proposed. Finally, as for the proposed plan, implementation of the Farmland Conservation Alternative would require a general plan amendment. No significant impacts related to land use and planning were identified for the proposed plan; therefore, implementing this alternative would not reduce or avoid any significant impacts related to land use and planning associated with the proposed plan. The land use and planning impacts of this alternative and the proposed plan therefore would be
similar.

Noise
Implementing the Farmland Conservation Alternative would result in a smaller development footprint and substantially less development than would occur under the proposed plan. Therefore, construction- and operation- related noise would be considerably slightly reduced compared with the proposed plan. Overall, noise impacts would be
less under this alternative than under the proposed plan.

Population and Housing
The Farmland Conservation Alternative would generate 18 percent less population and job growth than the proposed plan. As under the proposed plan, implementation of this alternative would not displace substantial numbers of existing housing or people. No significant impacts related to population and housing were identified for the proposed plan; therefore, implementing this alternative would not reduce or avoid any significant impacts related to population or housing associated with the proposed plan. Overall, population and housing impacts would be similar under this alternative than under the proposed plan.

Public Services and Recreation
The Farmland Conservation Alternative would generate fewer residential, and lower population and job growth than the proposed plan. Therefore, this alternative would have a lesser potential to increase demand for fire and police services, which nonetheless could result in the need for new or expanded fire and police facilities. Nonetheless, similar to the proposed plan, there is no evidence to suggest that construction or expansion of such facilities would result in Alternatives Ascent Environmental
City of Fresno
6-20 South Central Specific Plan Draft EIR
unmitigable, adverse effects on the environment. No significant impacts related to public services or recreation were identified for the proposed plan; therefore, implementing this alternative would not reduce or avoid any significant impacts related to public services or recreation associated with the proposed plan. For these reasons, impacts related to public services and recreation would be less under this alternative than under the proposed plan.

Transportation and Circulation
Implementation of the Farmland Conservation Alternative would result in less development than under the proposed plan (with an overall 18-percent reduction in development and less residential, retail, office, and industrial uses). It is expected that VMT could be higher under this alternative compared to the proposed plan because a reduced amount of development (especially job-generating uses) would occur under this alternative; it is unknown whether VMT under this alternative would be reduced compared to 2015 existing conditions and 2035 no project conditions.

The decrease in VMT under the proposed plan would be the result of creating increased employment opportunities (industrial and commercial development) in areas a shorter driving distance from surrounding housing. Both the proposed plan and Farmland Conservation Alternative would include job-generating uses; however, because this alternative would include less development, it may not achieve the same VMT reduction as the proposed plan, and it is unknown whether VMT would be reduced compared to 2015 existing conditions and 2035 no project conditions.

With less industrial development under the Farmland Conservation Alternative, plan-generated truck traffic could be less compared to the proposed plan.

Similar to the proposed plan, there is no evidence to suggest that this alternative would conflict with any applicable program, plan, ordinance, or policy addressing the circulation system; substantially increase transportation hazards from design features or incompatible uses; or result in inadequate emergency access.

Overall, the impact related to transportation and circulation under this alternative would be similar to those associated with the proposed plan.

Utilities and Service Systems
Overall development would be less intense under the Farmland Conservation Alternative than under the proposed plan (with less residential, retail, office, and industrial uses) , thereby reducing overall demand for water, wastewater treatment, and solid waste disposal compared with the proposed plan. No significant impacts related to utilities and service systems were identified for the proposed plan; therefore, implementing this alternative would not reduce or avoid any significant impacts related to utiliti es and service systems associated with the proposed plan.

Overall, impacts on utilities and service systems would be less under this alternative than under the proposed plan.

6.4.3 Reduced Plan Area Alternative
The City explored alternatives that would reduce the intensity and overall amount of industrial development described for the proposed plan. It was determined that downward adjustments to allowable floor area ratios of individual parcels, beyond those assumed in the proposed plan, would not be feasible because they would limit development potential to such a degree that parcels would not be able to support industrial development. For example, lowering the floor area ratio may limit the feasibility to develop uses such as warehouse, office, and research and development. In addition, this change may encourage heavy industrial uses, because these use do not require as much building square footage. The only feasible option was to reduce the number of overall acres designated for industrial development. One reasonable alternative is to consider an alternative that focuses development fully within the Fresno city limits. Therefore, this alternative removes any development potential currently within the county and within the City’s sphere of influence (Figure 6-3). Although it is possible that some or all of this excluded land area could be proposed for development either with the County as lead agency or in the future by the City after annexation of land, the specifics of such development would be speculative, and it is reasonable to assume that removing the area within the sphere of influence from the SCSP would have a dampening effect on the rate and intensity of development in those areas.

Ascent Environmental Alternatives
City of Fresno
South Central Specific Plan Draft EIR 6-21
This alternative would reduce the size of the Plan Area by approximately 42 percent (3,224 acres versus 5,567 acres for the proposed plan), have a commensurate reduction in development, and include a similar mix of land uses (Table 6-7).

Table 6-7 Development Projections for the Reduced Plan Area Alternative and Proposed Plan (2022–2040) Land Use Proposed Plan (sq. ft.) Reduced Plan Area Alternative (sq. ft.)1
Difference
(sq. ft.)
Retail 866,676 502,672 364,004
Office 578,790 335,698 243,092
Industrial 10,576,278 6,134,241 4,442,037
Total Non-Residential 12,021,744 6,972,612 5,049,132
Residential Units 91 units 53 units 38 units
1 Estimates for the Reduced Plan Area Alternative were generated assuming proportionate reductions of the same mix of land uses included in the proposed plan on a smaller footprint.

Source: Prepared by Ascent Environmental in 2024.

Table 6-8 shows the population and job growth anticipated to occur in the Plan Area with implementation of the Reduced Plan Area Alternative compared with growth under the proposed plan. Assuming proportionate reductions, this alternative would generate 42 percent less population and job growth than the proposed plan. The use regulations, permit requirements, and development standards for this alternative would be the same as the proposed plan.

Table 6-8 Anticipated Population and Job Growth for the Reduced Plan Area Alternative and Proposed Plan (2022–2040)
Land Use Proposed Plan Reduced Plan Area Alternative1 Difference Total Residential Growth 313 persons 182 persons 131 persons Food (Restaurants) 183 employees 106 employees 77 employees Industrial 10,576 employees 6,134 employees 4,442 employees Office 1,928 employees 1,118 employees 810 employees
Retail 1,624 employees 942 employees 682 employees
Total Job Growth 14,311 employees 8,300 employees 6,011 employees 1 Estimates for the Reduced Plan Area Alternative were generated using the same growth assumptions used for the proposed plan. Thus, it is conservatively assumed that implementing the Reduced Plan Area Alternative would result in 42 percent less residential and job growth compared to the proposed plan.

Source: Prepared by Ascent Environmental in 2024.

Alternatives Ascent Environmental
City of Fresno
6-22 South Central Specific Plan Draft EIR

Source: Adapted by Ascent in 2024
Figure 6-3 Reduced Plan Area Alternative

Ascent Environmental Alternatives
City of Fresno
South Central Specific Plan Draft EIR 6-23

COMPARISON OF REDUCED PLAN AREA ALTERNATIVE AND PROPOSED PLAN

IMPACTS
The Reduced Plan Area Alternative would occupy approximately 3,224 acres, or 2,343 fewer acres than under the proposed plan. With less land identified for development, subsequent projects under the alternative plan would have proportionately reduced construction- and operation-related impacts. The following discussion focuses on the potential for this alternative to reduce the proposed plan’s significant impacts.

Aesthetics
Although the overall level of development would be less than under the proposed plan , the density of new development would still be substantial in the alternative plan area, resulting in a visual character that, although generally consistent with the urbanized portions of the Plan Area, would still be substantially altered. The substantial reduction in development would reduce impacts related to the change in the character of the site (because less of the site would be developed); however, it would not substantially reduce the aesthetic impacts of development. Areas of abrupt transition from preserved farmland/open space land to developed land would still occur under this alternative. In addition, although the reduced level of potential development would result in a reduced level of night lighting, the extent of night lighting would still be considerable and would not avoid the proposed plan’s significant impact related to light and glare (although mitigation is available to reduce this impact to a less -than-significant level). However, less development under this alternative would result in less light pollution than would occur under the proposed plan. Overall, impacts on aesthetics would be less than under the proposed plan.

Agriculture and Forestry Resources
The Reduced Plan Area Alternative would remove 2,343 acres of land from development compared with the proposed plan. Implementation of this alternative would affect fewer acres of land, which would also likely result in less farmland conversion. Implementation of this alternative would also involve less construction than the proposed plan (because of the smaller footprint for potential development) and would therefore result in slightly less likelihood that existing farmland would be converted to urban development. Mitigation measures required for this alternative would be similar to those required for the proposed plan. Overall, the agriculture impacts of the Reduced Plan Area Alternative would be less compared to those resulting from the proposed plan.

Air Quality
Implementing the Reduced Plan Area Alternative would result in a smaller development footprint and therefore substantially less development than would occur under the proposed plan. Construction- and operation-related air pollutant emissions would be considerably reduced. However, the emissions associated with the Reduced Plan Area Alternative would still be substantial for both construction and operation. Regarding exposure to TACs, the Reduced Plan Area Alternative would include fewer residential units; therefore, compared to the proposed plan, it would expose fewer sensitive receptors to substantial sources of TACs. The overall impact related to air quality would be less.

Biological Resources
Implementation of the proposed plan would result in significant, but mitigable, impacts related to the permanent loss of habitat for special-status-species and other sensitive habitat. Implementation of the Reduced Plan Area Alternative would result in fewer acres of developed land, which would result in benefits to special- status species and their habitats. Implementation of this alternative would also involve less construction than the proposed plan (because of the smaller development footprint) and would therefore result in less likelihood that special-status species could be affected during construction. Mitigation measures required for this alternative would be similar to those required for the proposed plan. Overall, the biological resource–related impacts of the Reduced Plan Area Alternative would be less compared to those resulting from the proposed plan.

Alternatives Ascent Environmental
City of Fresno
6-24 South Central Specific Plan Draft EIR
Cultural and Tribal Cultural Resources
Implementation of the Reduced Plan Area Alternative would result in fewer acres of developed land, and, therefore, there would be a reduction in the potential to damage unrecorded historic sites, but given the large amount of land that would still be developed under this alternative, the reduction would be inconsequential. Overall, the impacts of the Reduced Plan Area Alternative would be
similar to those under the proposed plan, and this alternative would not eliminate the proposed plan’s significant and unavoidable impacts to cultural resources.

Energy
As discussed under “Transportation and Circulation,” below, VMT from cars and light trucks could be higher under this alternative compared to the proposed plan because employment centers in the reduced area of development would be smaller, potentially increasing commute distances for workers living farther from the region, but because this alternative would include less industrial development, truck traffic would be reduced. Because of its reduced area, this alternative would have lower energy demands compared with those of the proposed plan. Similar to the proposed plan, it is assumed that this alternative would meet the mandatory EV charging requirements of the CALGreen Code and comply with 2022 California Energy Code Standards; however, also similar to the proposed plan, this alternative may conflict with the energy-related measures of the City’s GHGRP, which requires that commercial projects achieve ZNE electricity. Although VMT may be somewhat higher and energy demands would be less under this alternative, the energy-related impact would be
less compared to that of the proposed plan; however,
implementing this alternative would not avoid the significant and unavoidable impact related to energy that would occur under the proposed plan.

Geology, Soils, and Mineral Resources
Implementation of the Reduced Plan Area Alternative would involve similar grading and other ground-disturbing activities as the proposed plan but over a smaller footprint. Therefore, this alternative would have impacts that are similar in nature but reduced in magnitude in the following areas: seismic ground-shaking, soil erosion, geological hazards, expansive soils, and paleontological resources. The same mitigation measures required for the proposed plan would also be required for this alternative. Overall, the impacts of the Reduced Plan Area Alternative would be less compared to those resulting from the proposed plan.

Greenhouse Gas Emissions and Climate Change
The amount of operation-related emissions of GHGs generally correlate to the size and intensity of a project and the associated energy consumed and VMT. Implementation of the proposed plan would generate a considerable amount of GHG emissions. Implementation of mitigation measures identified in the EIR would substantially reduce on -site emissions; however, emission levels would still be high (there is no City or SJVAPCD significance threshold).

Implementing the Reduced Plan Area Alternative would result in less overall development than would occur under the proposed plan. With implementation of the same mitigation measures identified for the proposed plan , the overall GHG emissions associated with operation of this alternative would likely still be substantial, although not as substantial as under the proposed plan. For these reasons, the GHG emission impact associated with the Reduced Plan Area Alternative would be
less compared to the impact resulting from the proposed plan.

Hazards and Hazardous Materials
Although a smaller amount of land would be developed under the Reduced Plan Area Alternative, implementation of the alternative would still involve the routine transport, use, and disposal of hazardous materials; potential for hazardous emissions or handling of hazardous materials within 0.25 mile of an existing or proposed school; potential to be located on a site included on a list of hazardous material sites compiled pursuant to Government Code Section 65962.5; and potential to impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. Implementing the Reduced Plan Area Alternative would generally result in impacts that are similar in nature to those of the proposed plan, but over a smaller area. Mitigation measures similar to those identified for the proposed plan would still be required. Overall, impacts related to hazards and hazardous materials would be
less than those of the proposed plan.

Ascent Environmental Alternatives
City of Fresno
South Central Specific Plan Draft EIR 6-25
Hydrology and Water Quality
Although the Reduced Plan Area Alternative would have a smaller overall development footprint and overall less development compared with the proposed plan, the development types would be similar, and construction and operation of this alternative would require compliance with the same water quality regulations required for the proposed plan. Overall, impacts related to hydrology and water quality would be less to those of the proposed plan.

Land Use and Planning
Implementation of the Reduced Plan Area Alternative would result in development of urban land uses within a smaller footprint compared to the proposed plan. As under the proposed plan, this alternative would not divide an established community, nor would it conflict with plans adopted for the purpose of avoiding or mitigating a significant effect (including the City of Fresno General Plan and the City of Fresno Zoning Ordinance). Fewer new residential units are proposed (53 units versus 91 units). Additionally, no major roadways or other development that could divide a community is proposed. Finally, as for the proposed plan, implementation of the Reduced Plan Area Alternative would require a general plan amendment. No significant impacts related to land use and planning were identified for the proposed plan; therefore, implementing this alternative would not reduce or avoid any significant impacts related to land use and planning associated with the proposed plan. The land use and planning impacts of this alternative and the proposed plan therefore would be similar.

Noise
Implementing the Reduced Plan Area Alternative would result in a smaller development footprint and substantially less development than would occur under the proposed plan. Therefore, construction- and operation-related noise would be considerably reduced compared with the proposed plan. Overall, noise impacts would be less under this alternative than under the proposed plan.

Population and Housing
The Reduced Plan Area Alternative would generate 42 percent less population and job growth than the proposed plan. As under the proposed plan, implementation of this alternative would not displace substantial numbers of existing housing or people. No significant impacts related to population and housing were identified for the proposed plan; therefore, implementing this alternative would not reduce or avoid any significant impacts related to population or housing associated with the proposed plan. Overall, population and housing impacts would be similar under this alternative than under the proposed plan.

Public Services and Recreation
The Reduced Plan Area Alternative would generate fewer residential units, and lower population and job growth than the proposed plan. Therefore, this alternative would have a lesser potential to increase demand for fire and police services, which nonetheless could result in the need for new or expanded fire and police facilities. Nonetheless, similar to the proposed plan, there is no evidence to suggest that construction or expansion of such facilities would result in unmitigable adverse effects on the environment. No significant impacts related to public services or recreation were identified for the proposed plan; therefore, implementing this alternative would not reduce or avoid any significant impacts related to public services or recreation associated with the proposed plan. For these reasons, impacts related to public services and recreation would be
less under this alternative than under the proposed plan.

Transportation and Circulation
Implementation of the Reduced Plan Area Alternative would result in less development than under the proposed plan (with an overall 42-percent reduction in development and less residential, retail, office, and industrial uses). It is expected that VMT could be higher under this alternative compared to the proposed plan because a reduced amount of development (especially job-generating uses) would occur under this alternative; it is unknown whether VMT under this alternative would be reduced compared to 2015 existing conditions and 2035 no project conditions.

The decrease in VMT under the proposed plan would be the result of creating increased employment opportunities (industrial and commercial development) in areas a shorter driving distance from surrounding housing. Both the proposed plan and Reduced Plan Area Alternative would include job-generating uses; however, because this Alternatives Ascent Environmental
City of Fresno
6-26 South Central Specific Plan Draft EIR
alternative would include less development, it may not achieve the same VMT reduction as the proposed plan, and it is unknown whether VMT would be reduced compared to 2015 existing conditions and 2035 no project conditions.

With less industrial development under the Reduced Plan Area Alternative, plan -generated truck traffic could be less compared with the proposed plan.

Similar to the proposed plan, there is no evidence to suggest that this alternative would conflict with any applicable program, plan, ordinance, or policy addressing the circulation system; substantially increase transportation hazards from design features or incompatible uses; or result in inadequate emergency access.

Overall, the impacts related to transportation and circulation under this alternative would be similar to those associated with the proposed plan.

Utilities and Service Systems
Overall development would be less intense under the Reduced Plan Area Alternative than under the proposed plan (with less residential, retail, office, and industrial uses) , thereby reducing overall demand for water, wastewater treatment, and solid waste disposal compared with the proposed plan. No significant impacts related to utilities and service systems were identified for the proposed plan; therefore, implementing this alternative would not reduce or avoid any significant impacts related to utilities a nd service systems associated with the proposed plan.

Overall, impacts on utilities and service systems would be less under this alternative than under the proposed plan.

6.4.4 Community Plan Option
The Community Plan Option reflects the community’s desire to increase quality of life in the Plan Area by decreasing land use intensity. This alternative would reclassify parcels with a Heavy Industrial planned land use designation to a Commercial-General or Light Industrial planned land use designation to decrease land use intensity throughout the Plan Area, including surrounding sensitive uses (Figure 6-4). The Community Plan Option would designate as Residential lands that currently support those uses and would substantially increase the amount of office and retail uses while substantially reducing the amount of industrial land uses (Table 6 -9). Further, this alternative would include 739 residential units, an increase of 648 units from the proposed plan. Figure 6-5 shows the parcels that would change planned land use designations from the adopted General Plan under this alternative.

Table 6-9 Development Projections for the Community Plan Option and Proposed Plan (2022-2040) Land Use Proposed Plan (sq. ft.) Community Plan Option (sq. ft.) Difference (sq. ft.) Retail 866,676 3,871,826 3,005,150
Office 578,790 4,008,553 3,429,763
Industrial 10,576,278 4,141,365 -6,434,913
Total Non-Residential 12,021,744 12,021,744 0
Residential Units 91 units 739 units 648 units
Source: Prepared by Ascent Environmental in 2024.

Consistent with the General Plan, planned parks, open space, and public facilities on vacant land carry dual land use designations. If the facility is not needed, alternative private or public development consistent with zoning and development standards may be approved. The Community Plan Option dual planned land use designations are identified by an asterisk (*) on the map. The Community Plan Option would double the size of public facilities northeast of Elm and Cherry Avenues, which could be meant for an expansion of Orange Center Elementary School.

The Community Plan Option also eliminates public facilities and open space on vacant land elsewhere for commercial land uses, which do not need a dual designation.

Ascent Environmental Alternatives
City of Fresno
South Central Specific Plan Draft EIR 6-27

Source: Image produced and provided by the city of Fresno, Adapted by Ascent Environmental in 2023.

Figure 6-4 Community Plan Option: Proposed Land Use

Alternatives Ascent Environmental
City of Fresno
6-28 South Central Specific Plan Draft EIR

Source: Image produced and provided by the City of Fresno, Adapted by Ascent Environmental in 2023.

Figure 6-5 Parcels Changing Under Community Plan Option

Ascent Environmental Alternatives
City of Fresno
South Central Specific Plan Draft EIR 6-29
The use regulations, permit requirements, and development standards proposed for the Community Plan Option are listed below. These regulations, requirements, and standards would govern all future private development actions in the Plan Area, including new construction, additions, and renovations to existing structures and/or new land uses proposed for existing facilities. These regulations would not, however, govern legal non-conforming uses, structures, site features or lots, as described in Chapter 15, Article 4 of the Fresno Municipal Code. Figure 6-6 identifies the proposed buffer zones that would be implemented under the Community Plan Option to protect sensitive uses, including residential, school, park, and day care facilities.

The following development regulations would apply to the Community Plan Option :

1. Prohibit the following use classifications within 2,500 feet of sensitive uses within and, where applicable, immediately outside the SCSP boundary lines:
 Service Station
 Towing and Impound
 Motorcycle/Riding Club
 Shooting/Archery Range
 Maintenance and Repair Services
 Retail Sales: Building Materials and Services
 Construction and Material Yards
 Custom Manufacturing
 Limited Industrial
 General Industrial
 Intensive Industrial
 Recycling Processing Facility
 Salvage and Wrecking
 Freight/Truck Terminals and Warehouses
 Warehousing, Storage, and Distribution:

Chemical and Mineral Storage
 Warehousing, Storage, and Distribution:

Indoor Warehousing and Storage
 Warehousing, Storage, and Distribution:

Outdoor Storage
 Warehousing, Storage, and Distribution:

Wholesaling and Distribution
 Light Fleet-Based Services
 Utilities, Major
 Waste Transfer Facility
 Mining and Quarrying
 Rendering
 Slaughterhouse

2. Truck entrances and docking stations shall be placed away from sensitive uses so that tailpipe emissions are as far away as possible.

3. Vegetative barriers design standards must require native vegetative plants that mitigate the pollution, heat island effects, noise, and light. Landscape must be able to reach maturity to provide the most protection within five to seven years.

Table 6-10 shows the residential and job growth anticipated to occur within the Plan Area with implementation of the Community Plan Option versus the proposed plan. This alternative would generate substantially more residential growth (86 percent more [1,949/2,262]) and job growth than the proposed plan (45 percent more [11,644/25,955]).

Table 6-10 Estimated Population and Employment for the Community Plan Option, as compared to the Proposed Plan (2022-2040)
Land Use Proposed Plan Community Plan Option Difference Total Residential Growth 313 persons 2,262 persons 1,949 persons Food (Restaurants) 183 employees 2,650 employees 2,467 employees Industrial 10,576 employees 4,141 employees -6,435 employees Office 1,928 employees 13,010 employees 11,082 employees Retail 1,624 employees 6,154 employees 4,530 employees Total Job Growth 14,311 employees 25,955 employees 11,644 employees Source: Prepared by Ascent Environmental in 2024.

Alternatives Ascent Environmental
City of Fresno
6-30 South Central Specific Plan Draft EIR

Source: Image produced and provided by the city of Fresno, Adapted by Ascent Environmental in 2023.

Figure 6-6 Community Plan Option with Proposed Buffers

Ascent Environmental Alternatives
City of Fresno
South Central Specific Plan Draft EIR 6-31

COMPARISON OF COMMUNITY PLAN OPTION AND PROPOSED PLAN IMPACTS Because the Community Plan Option includes the same development footprint, it would require a similar amount of construction and would result in a similar amount of conversion of undeveloped land to urban use, compared with the proposed plan. However, this option would involve a different mix of land uses, with substantially more retail and office uses and substantially less industrial uses. Further, this option would generate substantially more residential and job growth than the proposed plan. The following discussion focuses on the potential for this alternative to reduce the proposed plan’s significant impacts.

Aesthetics
Implementation of the Community Plan Option would result in development of urban land uses within the same footprint as the proposed plan. The primary difference between the Community Plan Option and the proposed plan is the types of land uses. Unlike the proposed plan, the Community Plan Option has a greater number of residential and would substantially increase the amount of office and retail uses while substantially reducing the amount of industrial land uses. Regarding the proposed plan’s significant impacts related to visual character and light and glare, this alternative would result in similar impacts due to the same footprint being developed with similar land uses and a large number of new light sources. For these reasons, the impacts to aesthetics would be similar between the proposed plan and this option, and this option would not eliminate the proposed plan’s significant and unavoidable impact related to visual character.

Agriculture and Forestry Resources
As described in Section 4.2, “Agriculture and Forestry Resources,” the Plan Area includes approximately 992 acres of Prime Farmland and Farmland of Statewide Importance as well as approximately 153 acres (located outside the existing City limits but within the City’s sphere of influence) under Williamson Act contracts. Because the total amount of future development (5,567acres) and the Plan Area footprint would remain unchanged between the Community Plan Option and the proposed plan, this alternative would result in a similar amount of conversion of Important Farmland and farmland under Williamson Act contracts compared to the proposed plan , which are considered significant impacts. The impacts to agricultural resources would be similar between the proposed plan and this
option, and this alternative would not eliminate the proposed plan’s significant and unavoidable impacts related to the conversion of farmland and conflicts with Williamson Act contracts.

Air Quality
Implementing the Community Plan Option would result in a similar level of development within the same footprint as the proposed plan. Therefore, construction-related air pollutant emissions would be similar. However, due to the different mix of urban land uses (substantially more residential, retail, and office uses and substantially less industrial uses), operational emissions would be less than those of the proposed plan due to the substantial reduction in industrial development. Regarding exposure to TACs, the Community Plan Option would include more residential units compared to the proposed project; therefore, it would result in a slightly greater potential to place sensitive receptors near high-volume roadways or other substantial sources of TACs. The overall impact related to air quality would be
less.

Biological Resources
Under the Community Plan Option, the same amount of land would be developed with urban uses within the Plan Area as the proposed plan. Therefore, this option would have similar impacts compared to the proposed plan related to the disturbance, injury, or mortality of several special-status plant and wildlife species, if present; reduced reproductive productivity of these species; and contribution to loss of species habitat. Development under this option could also result in the degradation or loss of riparian habitat (e.g., reduction of vegetation cover, trampling, alteration of root structure), if it is present on a particular project site; and the loss of state or federally protected wetland habitat, which includes seasonal wetlands. The Community Plan Option would generally result in similar impacts and would require similar mitigation measures compared to the proposed plan. Overall, impacts to biological resources would be
similar.

Alternatives Ascent Environmental
City of Fresno
6-32 South Central Specific Plan Draft EIR
Cultural and Tribal Cultural Resources
The Community Plan Option would result in development of the Plan Area, which could contain unrecorded historic sites. Thus, implementation of the Community Plan Option could result in a significant impact related to historic resources if such a resource exists and damage to or destruction of the resource occurred. This impact would be similar to the proposed plan’s impact, and this option would not eliminate the proposed plan’s significant and unavoidable impacts to cultural resources.

Energy
As discussed under “Transportation and Circulation,” below, VMT would be slightly lower under this option compared to the proposed plan. Energy demands would be substantially less than those of the proposed plan due to the substantial reduction in industrial land uses. Similar to the proposed plan, it is assumed that this option would meet the mandatory EV charging requirements of the CALGreen Code and comply with 2022 California Energy Code Standards; however, also similar to the proposed plan, this option may conflict with the energy-related measures of the City’s GHGRP, which requires that commercial projects achieve ZNE electricity. Although VMT would be slightly lower and energy demands would be less, this impact would be similar to the proposed plan’s impact, because this
option would not eliminate the proposed plan’s significant and unavoidable impact related to energy .

Geology, Soils, and Mineral Resources
Implementation of this option would involve grading and other ground-disturbing activities similar to the proposed plan and on the same footprint. Therefore, this option would have similar impacts associated with seismic ground- shaking, soil erosion, geological hazards, expansive soils, and paleontological resources. The same mitigation measures required for the proposed plan would also be required for this option. Overall, impacts to geology, soils, and mineral resources would be
similar.

Greenhouse Gas Emissions and Climate Change
Operational emissions of GHG generally correlate to the size and intensity of a project and the associated energy consumed and VMT. Implementation of the proposed plan would generate a considerable amount of GHG.

Implementation of mitigation measures identified in the EIR would substantially reduce on-site emissions; however, emissions levels would still be high (there is no City or SJVAPCD significance threshold). This option would result in a similar level of overall development as the proposed plan; however, operational GHG emissions would be less than those of the proposed plan due to the substantial reduction in industrial development. Even assuming the same mitigation measures apply, the overall GHG emissions associated with operation of this option would likely be substantial. For these reasons, the GHG impact associated with the Community Plan Option would be less compared
to the impact resulting from the proposed plan.

Hazards and Hazardous Materials
Implementation of this option would involve the routine transport, use, and disposal of hazardous materials; potential for hazardous emissions or handling of hazardous materials within 0.25 mile of an existing or proposed school; potential to be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5; and potential to impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. The Community Plan Option would generally result in similar impacts and would require similar mitigation measures compared to the proposed plan . Overall, impacts related to hazards and hazardous materials would be similar.

Hydrology and Water Quality
The Community Plan Option would have the same development footprint as the proposed plan, and construction associated with this alternative would require compliance with the same water quality regulations as the proposed plan. In addition, although there are differences between the land use types identified for this option compared to the proposed plan, the overall level of development would be similar, and this option would also be required to comply with the same construction and operational regulations as the proposed plan. Overall, impacts related to hydrology and water quality would be
similar.

Ascent Environmental Alternatives
City of Fresno
South Central Specific Plan Draft EIR 6-33
Land Use and Planning
Implementation of the Community Plan Option would result in development of urban land uses within the same footprint as the proposed plan. Similar to the proposed plan, the Community Plan Option would not divide an established community, nor would it conflict with plans adopted for the purpose of avoiding or mitigating a significant effect (including the City of Fresno General Plan and the City of Fresno Zoning Ordinance). Additionally, no major roadways or other development that could divide a community is proposed. No significant impacts related to land use and planning were identified for the proposed plan; therefore, this option would not reduce or avoid any significant impacts related to land use and planning associated with the proposed plan. Impacts would be similar between the proposed plan and this alternative.

Noise
Implementing the Community Plan Option would result in a similar level of development within the same footprint as the proposed plan. Therefore, construction-related noise would be similar. Even though this option would include a different mix of urban land uses (more residential, more retail, less industrial), operational noise and traffic noise would also be similar to the proposed plan due to the development of over 12 million sq. ft. of nonresidential development, which is the same amount of development under this option and the proposed plan. Overall, noise impacts
similar.

Population and Housing
The Community Plan Option would generate 86 percent more residential and 45 percent more job growth than the proposed plan. Similar to the proposed plan, implementation of this option would not displace substantial numbers of existing housing or people. Overall, impacts associated with the Community Plan Option would be greater than those of the proposed plan, but only in that it would induce currently unplanned population growth in the Plan Area.

Public Services and Recreation
The Community Plan Option would generate substantially more residential and job growth than the proposed plan .

As such, this option would have a greater potential to increase demand for fire and police services, which could result in the need for new or expanded fire and police facilities. Nonetheless, similar to the proposed plan, there is no evidence to suggest that construction or expansion of such facilities would result in unmitigable, adverse effects on the environment. No significant impacts related to public services and recreation were identified for the proposed plan; therefore, this option would not reduce or avoid any significant impacts related to public services and recreation associated with the proposed plan. Therefore, impacts would be similar.

Transportation and Circulation
Implementation of the Community Plan Option would result in the development of substantially more residential, retail, and office uses and substantially less industrial uses compared with the proposed plan, all of which would generate vehicle trips. Regarding VMT, the Transportation Impact Analysis prepared for the SCSP (TJKM 2023b) indicates that the Community Plan Option would generate 22.76 VMT per service population, which is a decrease of

22.12 VMT or almost 50 percent from 2015 existing conditions (44.88 VMT) and 2035 no project conditions (46.44 VMT). By comparison, the proposed plan is anticipated to generate 29.87 VMT per service population, which is also a decrease from both 2015 existing conditions and 2035 no project conditions. The decrease in V MT under both the proposed plan and the Community Plan Option is the result of creating increased employment opportunities through the implementation of industrial and commercial development leading to improved proximity between the jobs in the Plan Area and surrounding housing by shortening driving distance and, therefore, reducing VMT. Resulting VMT would be slightly lower under this alternative compared to the proposed plan.

Similar to the proposed plan, there is no evidence to suggest that this option would conflict with any applicable program, plan, ordinance, or policy addressing the circulation system; substantially increase transportation hazards from design features or incompatible uses; or result in inadequate emergency access.

Overall, the impact related to transportation and circulation would be similar to the impact associated with the proposed plan.

Alternatives Ascent Environmental
City of Fresno
6-34 South Central Specific Plan Draft EIR
Utilities and Service Systems
Because of the different mix of urban land uses (substantially more residential, retail, and office uses and substantially less industrial uses), implementation of the Community Plan Option would result in greater demands for water, wastewater treatment, and solid waste disposal compared with the proposed plan. No significant impacts related to utilities and service systems were identified for the proposed plan; therefore, this option would not reduce or avoid any significant impacts related to utilities and service systems associated with the proposed plan. Overall, impacts would be greater.

6.4.5 Business Plan Option
The Business Plan Option honors the community’s desire to maximize economic growth and would maintain General Plan planned land use designations for most parcels. This option would reclassify some parcels with a Heavy Industrial planned land use designation to a Light Industrial planned land use designation, thus maintaining the majority of the Plan Area land for industrial uses (Figure 6-7). Like the SCSP and Community Plan Alternative, the Business Plan Option would designate lands that currently support residential uses as “Residential.” Although the Business Plan Option planned land use designations primarily envision industrial development, they would allow ancillary retail uses and light industrial uses such as warehousing, distribution, and manufacturing, increasing the total capacity for potential industrial uses (Table 6-11). Figure 6-8 show the parcels that would change planned land use designations from the adopted General Plan under the Business Plan Option .

Table 6-11 Development Projections for the Business Plan Option and Proposed Plan (2022-2040) Land Use Proposed Plan (sq. ft.) Business Plan Option (sq. ft.) Difference Retail 866,676 277,375 -589,301
Office 578,790 578,790 0
Industrial 10,576,278 11,165,579 589,301
Total Non-Residential 12,021,744 12,021,744 0
Residential Units 91 units 0 -91 units
Source: Prepared by Ascent Environmental in 2024.

Consistent with the General Plan, planned parks, open space, and public facilities on vacant land carry dual land use designations. If the facility is not needed, alternative private or public development consistent with zoning and development standards may be approved. The Business Plan Options matches the dual planned land use designations of the General Plan. The use regulations, permit requirements, and development standards proposed for the Business Plan Option are listed below. Similar to the Community Plan Option, these regulations, requirements, and standards would govern all future private development actions in the Plan Area, including new construction, additions, and renovations to existing structures and/or new land uses proposed for existing facilities. Thes e regulations would not, however, govern legal non-conforming uses, structures, site features or lots, as described in Chapter 15, Article 4 of the Fresno Municipal Code. Figure 6-9 identifies the proposed buffer zones that would be implemented under the Business Plan Option to protect sensitive uses, including residential, school, park, and day care facilities.

Ascent Environmental Alternatives
City of Fresno
South Central Specific Plan Draft EIR 6-35

Source: Image produced and provided by the city of Fresno, Adapted by Ascent Environmental in 2023.

Figure 6-7 Business Plan Option: Proposed Land Use

Alternatives Ascent Environmental
City of Fresno
6-36 South Central Specific Plan Draft EIR

Source: Image produced and provided by the city of Fresno, Adapted by Ascent Environmental in 2023.

Figure 6-8 Parcels Changing Under Business Plan Option

Ascent Environmental Alternatives
City of Fresno
South Central Specific Plan Draft EIR 6-37

Source: Image produced and provided by the city of Fresno, Adapted by Ascent Environmental in 2023.

Figure 6-9 Business Plan Option with Proposed Buffers

Alternatives Ascent Environmental
City of Fresno
6-38 South Central Specific Plan Draft EIR
The following development regulations would apply to the Business Plan Option :

1. Prohibit the following use classifications:
a. Rendering
b. Slaughterhouse

2. Require a CUP for the following use classifications that fall within 1,000 feet of a sensitive use (residential, school, park, and daycare):
a. Motorcycle/Riding Club
b. Shooting/Archery Range
c. Salvage and Wrecking
d. Warehousing, Storage, and Distribution: Chemical and Mineral Storage e. Exception for those uses related to the pharmaceutical industry or are ancillary to the primary use f. Waste Transfer Facility
g. Mining and Quarrying

3. Require enhanced screening conditions for the following use classifications that fall within 1,000 feet of a sensitive use (residential, school, park, and daycare):
a. Construction and Material Yards
b. Limited Industrial
c. Recycling Processing Facility
d. Warehousing, Storage, and Distribution: Indoor Warehousing and Storage e. Warehousing, Storage, and Distribution: Outdoor Storage f. Warehousing, Storage, and Distribution: Wholesaling and Distribution

4. Enhanced screening standards:
a. Outdoor storage areas, service yards, and truck docks should be screened so as not to be visible from sensitive uses.
b. Screening walls and fences shall be architecturally compatible with the main structure on the site. c. Earth berms (minimum of 3ft) or plant materials may serve to satisfy screening requirements as alternative materials.

Table 6-12 shows the residential and job growth anticipated to occur within the Plan Area with implementation of the Business Plan Option versus the proposed plan. This alternative would generate no residential and slightly less job growth than the proposed plan (4.5 percent less [654/14,311]).

Table 6-12 Anticipated Population and Job Growth for the Business Plan Option and Proposed Plan (2022- 2040)
Land Use Proposed Plan Business Plan Option Difference
Total Residential Growth 313 persons 0 -313 persons
Food (Restaurants) 183 employees 19 employees -164 employees Industrial 10,576 employees 11,166 employees 590 employees Office 1,928 employees 1,929 employees 1 employees
Retail 1,624 employees 543 employees -1,081 employees Total Job Growth 14,311 employees 13,657 employees -654 employees Source: Prepared by Ascent Environmental in 2024.

Ascent Environmental Alternatives
City of Fresno
South Central Specific Plan Draft EIR 6-39

COMPARISON OF BUSINESS PLAN OPTION AND PROPOSED PLAN IMPACTS Because the Business Plan Option includes the same development footprint, it would require a similar amount of construction and would result in a similar amount of conversion of undeveloped land to urban use, compared with the proposed plan. However, this option would involve a different mix of land uses, with no residential, substantially less retail, similar office, and more industrial uses. Further, this option would generate no residential and slightly less job growth than the proposed plan. The following discussion focuses on the potential for this option to reduce the proposed plan’s significant impacts.

Aesthetics
Implementation of the Business Plan Option would result in development of urban land uses within the same footprint as the proposed plan. The primary difference between the Business Plan Option and the proposed plan is the types of land uses. Unlike the proposed plan, the Business Plan Option does not specifically include residential land uses—the land use designations are nonresidential. Regarding the proposed plan’s significant impacts related to visual character and light and glare, this option would result in similar impacts due to the same footprint being developed with similar land uses and a large number of new light sources. For these reasons, the impacts to aesthetics would be similar between the proposed plan and this option, and this option would not eliminate the proposed plan’s significant and unavoidable impact related to visual character.

Agriculture and Forestry Resources
As described in Section 4.2, “Agriculture and Forestry Resources,” the Plan Area includes approximately 992 acres of Prime Farmland and Farmland of Statewide Importance as well as approximately 153 acres (located outside the existing City limits but within the City’s sphere of influence) under Williamson Act contracts. Because the total amount of future development (5,567acres) and the Plan Area footprint would remain unchanged between the Business Plan Option and the proposed plan, this option would result in a similar amount of conversion of Important Farmland and farmland under Williamson Act contracts compared to the proposed plan, which are considered significant impacts.

The impacts to agricultural resources would be
similar between the proposed plan and this option, and this option would not eliminate the proposed plan’s significant and unavoidable impacts related to the conversion of farmland and conflicts with Williamson Act contracts.

Air Quality
Implementing the Business Plan Option would result in a similar level of development within the same footprint as the proposed plan. Therefore, construction-related air pollutant emissions would be similar. However, due to the different mix of urban land uses (substantially less retail, similar office, and more industrial), operational emissions would be slightly greater than those of the proposed plan due to the increase in industrial development. Regarding exposure to TACs, the Business Plan Option does not identify residential land uses; therefore, unlike the proposed plan, it would not place sensitive receptors near high-volume roadways or other substantial sources of TACs. The overall impact related to air quality would be greater.

Biological Resources
Under the Business Plan Option, the same amount of land would be developed with urban uses within the Plan Area as the proposed plan. Therefore, this option would have similar impacts compared to the proposed plan related to the disturbance, injury, or mortality of several special-status plant and wildlife species, if present; reduced reproductive productivity of these species; and contribution to loss of species habitat. Development under this option could also result in the degradation or loss of riparian habitat (e.g., reduction of vegetation cover, trampling, alteration of root structure), if it is present on a particular project site; and the loss of state or federally protected wetland habitat, which includes seasonal wetlands. The Business Plan Option would generally result in similar impacts and would require similar mitigation measures compared to the proposed plan . Overall, impacts to biological resources would be similar.

Alternatives Ascent Environmental
City of Fresno
6-40 South Central Specific Plan Draft EIR
Cultural and Tribal Cultural Resources
The Business Plan Option would result in development of the Plan Area, which could contain unrecorded historic sites. Thus, implementation of the Business Plan Option could result in a significant impact related to historic resources if such a resource exists and damage to or destruction of the resource occurred. This impact would be similar to the proposed plan’s impact, and this option would not eliminate the proposed plan’s significant and unavoidable impacts to cultural resources.

Energy
As discussed under “Transportation and Circulation,” below, VMT would be slightly higher under this option compared to the proposed plan. Energy demands would also be higher than those of the proposed plan due to the slight increase in industrial land uses. Similar to the proposed plan, it is assumed that this option would meet the mandatory EV charging requirements of the CALGreen Code and comply with 2022 California Energy Code Standards; however, also similar to the proposed plan, this option may conflict with the energy-related measures of the City’s GHGRP, which requires that commercial projects achieve ZNE electricity. Although VMT would be slightly higher and energy demands would be higher, this impact would be similar to the proposed plan’s impact, and this
option would not eliminate the proposed plan’s significant and unavoidable impact related to energy .

Geology, Soils, and Mineral Resources
Implementation of this option would involve grading and other ground-disturbing activities similar to the proposed plan and on the same footprint. Therefore, this option would have similar impacts associated with seismic ground- shaking, soil erosion, geological hazards, expansive soils, and paleontological resources. The same mitigation measures required for the proposed plan would also be required for this option. Overall, impacts to geology, soils, and mineral resources would be
similar.

Greenhouse Gas Emissions and Climate Change
Operational emissions of GHG generally correlate to the size and intensity of a project and the associated energy consumed and VMT. Implementation of the proposed plan would generate a considerable amount of GHG.

Implementation of mitigation measures identified in the EIR would substantially reduce on-site emissions; however, emissions levels would still be high (there is no City or SJVAPCD significance threshold). This option would result in a similar level of overall development as the proposed plan; however, operational GHG emissions would be slightly greater than those of the proposed plan due to the increase in industrial development. Even assuming the same mitigation measures apply, the overall GHG emissions associated with operation of this option would likely be substantial. For these reasons, the GHG impact associated with the Business Plan Option would be greater compared
to the impact resulting from the proposed plan.

Hazards and Hazardous Materials
Implementation of this option would involve the routine transport, use, and disposal of hazardous materials; potential for hazardous emissions or handling of hazardous materials within 0.25 mile of an existing or proposed school; potential to be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5; and potential to impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. The Business Plan Option would generally result in similar impacts and would require similar mitigation measures compared to the proposed plan . Overall, impacts related to hazards and hazardous materials would be similar.

Hydrology and Water Quality
The Business Plan Option would have the same development footprint as the proposed plan, and construction associated with this alternative would require compliance with the same water quality regulations as the proposed plan. In addition, although there are differences between the land use types identified for this option compared to the proposed plan, the overall level of development would be similar, and this option would also be required to comply with the same construction and operational regulations as the proposed plan. Overall, impacts related to hydrology and water quality would be
similar.

Ascent Environmental Alternatives
City of Fresno
South Central Specific Plan Draft EIR 6-41
Land Use and Planning
Implementation of the Business Plan Option would result in development of urban land uses within the same footprint as the proposed plan. Similar to the proposed plan, the Business Plan Option would not divide an established community, nor would it conflict with plans adopted for the purpose of avoiding or mitigating a significant effect (including the City of Fresno General Plan and the City of Fresno Zoning Ordinance). No new residential land uses are proposed. Additionally, no major roadways or other development that could divide a community is proposed. No significant impacts related to land use and planning were identified for the proposed plan; therefore, this alternative would not reduce or avoid any significant impacts related to land use and planning associated with the proposed plan. Impacts would be similar between the proposed plan and this option.

Noise
Implementing the Business Plan Option would result in a similar level of development within the same footprint as the proposed plan. Therefore, construction-related noise would be similar. Even though this option would include a different mix of urban land uses (more industrial, less retail), operational noise and traffic noise would also be similar to the proposed plan due to the development of over 12 million sq. ft. of nonresidential development, which is the same amount of development under this option and the proposed plan. Overall, noise impacts would be similar.

Population and Housing
The Business Plan Option would generate no residential growth and 4.5 percent less job growth than the proposed plan. Similar to the proposed plan, implementation of this option would not displace substantial numbers of existing housing or people. No significant impacts related to population and housing were identified for the proposed plan; therefore, this option would not reduce or avoid any significant impacts related to population and housing associated with the proposed plan. Overall, impacts associated with the Business Plan Option would be less than those of the proposed plan.

Public Services and Recreation
The Business Plan Option would generate no residential growth and less job growth than the proposed plan . As such, this option would have a lesser potential to increase demand for fire and police services, which nonetheless could result in the need for new or expanded fire and police facilities. Nonetheless, similar to the proposed plan , there is no evidence to suggest that construction or expansion of such facilities would result in unmitigable, adverse effects on the environment. No significant impacts related to public services and recreation were identified for the proposed plan; therefore, this option would not reduce or avoid any significant impacts related to public services and recreation associated with the proposed plan. Therefore, impacts would be similar.

Transportation and Circulation
Implementation of the Business Plan Option would result in the development of no residential, substantially less retail, similar office, and more industrial uses compared with the proposed plan, all of which would generate vehicle trips.

Regarding VMT, the Transportation Impact Analysis prepared for the SCSP (TJKM 2023b) indicates that the Business Plan Option would generate 31.99 VMT per service population, which is a decrease of 12.89 VMT or almost 29 percent from 2015 existing conditions (44.88 VMT) and 2035 no project conditions (46.44 VMT). By comparison, the proposed plan is anticipated to generate 29.87 VMT per service population, which is also a decrease from both 2015 existing conditions and 2035 no project conditions. The decrease in VMT under both the proposed plan and the Business Plan Option is the result of creating increased employment opportunities through the implementation of industrial and commercial development leading to improved proximity between the jobs in the Plan Area and surrounding housing by shortening driving distance and, therefore, reducing VMT. Resulting VMT would be slightly higher under this alternative compared to the proposed plan but would still be a decrease from 2015 existing conditions and 2035 no project conditions.

Similar to the proposed plan, there is no evidence to suggest that this option would conflict with any applicable program, plan, ordinance, or policy addressing the circulation system; substantially increase transportation hazards from design features or incompatible uses; or result in inadequate emergency access.

Alternatives Ascent Environmental
City of Fresno
6-42 South Central Specific Plan Draft EIR
Overall, the impact related to transportation and circulation would be greater than the impact associated with the proposed plan.

Utilities and Service Systems
Because of the different mix of urban land uses (no residential, substantially less retail, similar office, and more industrial), implementation of the Business Plan Option would result in greater demands for water, wastewater treatment, and solid waste disposal compared with the proposed plan. No significant impacts related to utilities and service systems were identified for the proposed plan; therefore, this option would not reduce or avoid any significant impacts related to utilities and service systems associated with the proposed plan. Overall, impacts would be greater.

6.5 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
Table 6-13 provides a summary of the impacts of the proposed plan compared to the alternatives and options.

Implementing the No Project/General Plan Land Use Alternative would reduce impacts related to population growth associated with the proposed plan, but only insofar as residential development is not currently planned in the SCSP area. It would result in greater impacts related to air quality and GHG emissions due to the greater amount of industrial development compared to the proposed plan. Regarding utilities and service systems, the No Project/General Plan Land Use Alternative would result in greater demands for water and wastewater treatment compared to the proposed plan. This alternative would not avoid or substantially reduce any of the significant impacts of the proposed plan and it would not meet most of the project objectives as presented above in Section 6.2.

The Reduced Plan Area Alternative would result in a reduction of impacts specifically for air quality, greenhouse gas emissions and noise due to its reduced footprint and reduced level of development. However, this alternative would not avoid or substantially reduce any of the significant impacts of the proposed plan .

The Farmland Conservation Alternative is considered environmentally superior because it would result in the reduction of impacts due to its reduced footprint and reduced level of development. Further, it would eliminate the proposed plan’s significant and unavoidable impacts related to the conversion of farmland and conflicts with Williamson Act contracts.

Table 6-14 identifies whether or not an alternative or option meets the objective of the proposed plan.

Table 6-13 Summary of Environmental Effects of the Alternatives Relative to the Proposed South Central Specific Plan
Environmental Topic Proposed
Plan
No
Project/General
Plan Land Use
Alternative
Farmland
Conservation
Alternative
Reduced Plan
Area Alternative Community Plan
Option
Business Plan
Option
Aesthetics SU Similar Less Less Similar Similar
Agriculture and Forestry Resources SU Similar Avoids Less Similar Similar Air Quality SU Greater Less Less Less Greater
Biological Resources LTS/M Similar Less Less Similar Similar Cultural and Tribal Cultural
Resources SU Similar Similar Similar Similar Similar
Energy LTS/M Similar Less Less Similar Similar
Geology, Soils, and Mineral
Resources LTS/M Similar Less Less Similar Similar
Greenhouse Gas Emissions and
Climate Change SU Greater Less Less Less Greater
Ascent Environmental Alternatives
City of Fresno
South Central Specific Plan Draft EIR 6-43
Environmental Topic Proposed
Plan
No
Project/General
Plan Land Use
Alternative
Farmland
Conservation
Alternative
Reduced Plan
Area Alternative Community Plan
Option
Business Plan
Option
Hazards and Hazardous Materials LTS/M Similar Less Less Similar Similar Hydrology and Water Quality LTS Similar Less Less Similar Similar Land Use and Planning LTS Similar Similar Similar Similar Similar Noise SU Similar Less Less Similar Similar
Population and Housing LTS Similar Similar Similar Greater Less Public Services and Recreation LTS Similar Less Less Similar Similar Transportation and Circulation LTS
Greater (results in
new significant
impact)
Similar
Similar
Similar Greater
Utilities and Service Systems LTS/M Greater Less Less Greater Greater Notes: LTS = less than significant; LTS/M = less than significant with mitigation; SU = significant and unavoidable.

Source: Data compiled by Ascent Environmental in 2024.

Table 6-14 Summary of Project Objectives Compared to the Proposed Plan Alternatives and Options Proposed Plan Objectives No Project/General Plan
Land Use Alternative
Farmland Conservation
Alternative
Reduced Plan Area
Alternative
Would the alternative meet the objective to:

Stimulate economic development? Yes, to a lesser extent Yes, to a lesser extent Yes, to a lesser extent Provide diverse employment? No Yes, to a lesser extent Yes, to a lesser extent Minimize environmental and neighborhood
impacts? No Yes, to a lesser extent Yes, to a lesser extent Preserve existing operations? Yes Yes Yes
Protect against incompatible uses? Yes Yes Yes
Implement infrastructure improvement ? Yes Yes, to a lesser extent Yes, to a lesser extent.

Be a good neighbor? No Yes, to a lesser extent Yes, to a lesser extent.

Source: Data compiled by Ascent Environmental in 2024.

Alternatives Ascent Environmental
City of Fresno
6-44 South Central Specific Plan Draft EIR
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City of Fresno
South Central Specific Plan Draft EIR 7-1
7 OTHER CEQA-MANDATED SECTIONS

7.1 SIGNIFICANT AND UNAVOIDABLE IMPACTS
The State CEQA Guidelines (Section 15126[b]) require that EIRs identify the significant environmental effects of a proposed project that cannot be reduced to a less-than-significant level. All the significant and unavoidable impacts that would occur under the proposed plan are listed below.

7.1.1 Aesthetics
Impact 4.1-3: Substantially degrade the existing visual character or quality of public views of the site and its surroundings.

7.1.2 Agricultural Resources
Impact 4.2-1: Convert prime farmland, unique farmland, or farmland of statewide importance (farmland) to non- agricultural use.

Impact 4.2-2: Conflict with existing zoning for agricultural use, or a Williamson Act contract.

7.1.3 Air Quality
Impact 4.3-3: Expose Sensitive Receptors to Substantial Pollutant Concentrations.

7.1.4 Biological Resources
No significant and unavoidable impacts.

7.1.5 Cultural and Tribal Cultural Resources
Impact 4.5-1: Cause a substantial adverse change in the significance of a historical resource.

7.1.6 Energy
No significant and unavoidable impacts.

7.1.7 Geology and Soils
No significant and unavoidable impacts.

7.1.8 Greenhouse Gas Emissions
Impact 4.8-1: Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment.

Impact 4.8-2: Conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of GHGs.

Other CEQA-Mandated Sections Ascent Environmental
City of Fresno
7-2 South Central Specific Plan Draft EIR

7.1.9 Hazards and Hazardous Materials
No significant and unavoidable impacts.

7.1.10 Hydrology and Water Quality
No significant and unavoidable impacts.

7.1.11 Land Use
No significant and unavoidable impacts.

7.1.12 Noise
Impact 4.12-1: Substantial temporary (construction) noise levels that exceed City noise control ordinance standards.

Impact 4.12-2: Substantial permanent stationary or area noise sources that exceed the City residential noise control ordinance standards
Impact 4.12-3: Substantial permanent traffic noise levels that exceed City traffic noise standards.

Impact 4.12-4: Construction or operational vibration levels that exceed FTA’s recommended standards with respect to the prevention of structural damage and human response.

7.1.13 Population and Housing
No significant and unavoidable impacts.

7.1.14 Public Services and Recreation
No significant and unavoidable impacts.

7.1.15 Transportation and Circulation
No significant and unavoidable impacts.

7.1.16 Utilities and Service Systems
No significant and unavoidable impacts.

7.2 SIGNIFICANT AND IRREVERSIBLE ENVIRONMENTAL CHANGES
The State CEQA Guidelines (Section 15126) requires a discussion of any significant irreversible environmental changes which would be caused by the proposed plan should it be implemented. The irreversible and irretrievable commitment of resources is the permanent loss of resources for future or alternative purposes. Irreversible and irretrievable resources are those that cannot be recovered or recycled or those that are consumed or reduced to unrecoverable forms. Specifically, the State CEQA Guidelines section 15126.2(c) states:

Uses of nonrenewable resources during the initial and continued phases of the project may be irreversible, since a large commitment of such resources makes removal or nonuse thereafter unlikely. Primary impacts and, particularly, secondary impacts (such as highway improvement which provides access to a previously inaccessible area) generally commit future generation to similar uses. Also, irreversible damage can result Ascent Environmental Other CEQA-Mandated Sections
City of Fresno
South Central Specific Plan Draft EIR 7-3
from environmental accidents associated with the project. Irretrievable commitments of resources should be evaluated to assure that such current consumption is justified.

Implementation of the proposed plan would result in the irreversible and irretrievable commitment of energy and material resources during construction and operation, including the following:
 construction materials, including such resources as soil, rocks, wood, concrete, glass, roof shingles, and steel;  land area committed to new project facilities;
 water supply for project operation; and
 energy expended in the form of electricity, gasoline, diesel fuel, and oil for equipment and transportation vehicles that would be needed for project construction and operation.

The use of these nonrenewable resources is expected to account for a small portion of the resources from which they’re ultimately sourced and would not affect the availability of these resources for other needs within the region and beyond. Mitigation measures identified in this EIR to reduce greenhouse gas (GHG) emissions would also reduce petroleum consumed during construction. As discussed in Section 4.6, “Energy,” there is no evidence to suggest that construction activities for future development within the Plan Area would result in inefficient use of energy or natural resources. Also, mitigation measures identified in this EIR to reduce operations -related GHG emissions require efficient use of energy during project construction and operation, including requirements fo r providing onsite renewable energy generation (during operation). Therefore, long-term project operation would not result in substantial long-term consumption of energy and natural resources. Irreversible changes associated with accidental release of hazardous materials near resources (such as waterways) are also addressed in the EIR. Mitigation Measures

4.91a through 4.9-1i, as well as compliance with federal, state, and local regulations, require future projects to reduce potential impacts associated with accidental release of hazardous materials. Therefore, accidental spills and rele ase of hazardous materials during construction would not result in irreversible changes to natural resources.

7.3 GROWTH INDUCEMENT
An EIR must discuss the ways in which a proposed project could foster economic or population growth or the construction of additional housing, directly or indirectly, in the surrounding environment (State CEQA Guidelines Section 15126.2[d]). Growth can be induced in several ways, such as through elimination of obstacles to growth, stimulation of economic activity in the region, and establishment of policies or other precedents that directly or indirectly encourage additional growth.

Section 15126.2(d) of the State CEQA Guidelines provides the following guidance for assessing growth- inducing impacts of a project:

Discuss the ways in which the proposed project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. Included in this are projects which would remove obstacles to population growth (a major expansion of a wastewater treatment plant might, for example, allow for more construction in service areas). Increases in the population may tax existing community service facilities, requiring construction of new facilities t hat could cause significant environmental effects. Also, discuss the characteristics of some projects which may encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively. It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment.

A project can induce growth directly, indirectly, or both. Direct growth inducement would result if a project involved construction of new housing. Indirect growth inducement would result, for instance, if implementing a project resulted in any of the following:
 substantial new permanent employment opportunities (e.g., commercial, industrial, or governmental enterprises); Other CEQA-Mandated Sections Ascent Environmental
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 substantial short-term employment opportunities (e.g., construction employment) that indirectly stimulates the need for additional housing and services to support the new temporary employment demand; and/or  removal of an obstacle to additional growth and development, such as removing a constraint on a required public utility or service (e.g., construction of a major sewer line with excess capacity through an undeveloped area).

Growth inducement itself is not an environmental effect but may foreseeably lead to environmental effects. If substantial growth inducement occurs, it can result in secondary environmental effects, such as increased demand for housing, demand for other community and public services and infrastructure capacity, increased traffic and noise, degradation of air or water quality, degradation or loss of plant or animal habitats, conversion of agricultural and open-space land to urban uses, and other effects.

7.3.1 Elimination of Obstacles to Growth
The elimination of either physical or regulatory obstacles to growth is considered a growth -inducing impact. A physical obstacle to growth typically involves the lack of public infrastructure. The extension of public infrastructure, including roadways, water mains, and sewer lines, into areas not currently provided with roads and utilities would be expected to support new development. Similarly, the elimination of or a change to a regulatory obstacle, including growth and development policies, could result in new growth.

The Plan Area, located in the southern portion of the City of Fresno, is made up of a mix of land uses including industrial, warehouse, commercial, residential, religious, educational, and public. Major transportation networks such as State Route (SR) 41, SR 99, and Burlington Northern Santa Fe (BNSF) and Union Pacific (UP) rail lines traverse the Plan Area, and land has been cleared and construction is underway for the future state high speed rail line. Obstacles to growth in the Plan Area include limited roadway access in some areas (e.g., narrow roads or absence of roads), stormwater drainage capacity, potable water infrastructure, and wastewater conveyance infrastructure. As discussed in Section 3, “Project Description,” industrial, retail, office and potential some residential would be developed in the Plan Area, and would be accompanied by infrastructure improvements necessary to serve development, removing these obstacles to growth. These effects are evaluated in this EIR.

Also, the Plan Area includes some land in unincorporated Fresno County outside the City of Fresno that is anticipated to become part of the City in the future. Upon a proposal to annex this unincorporated land, the City would prezone the land in a manner consistent with the General Plan land use designation. Once annexation occurs, County zoning would no longer apply, and the zoning established in the prezoning would take effect. This process would remove an obstacle to growth.

As discussed in Section 3, “Project Description,” development associated with the proposed plan, would require new on-site and off-site infrastructure to accommodate future development, including the installation of new transmission grids, new wells, and upsizing of pipelines. The proposed infrastructure is sized to serve the proposed plan and is not sized to serve additional unplanned development outside the Plan Area. These infrastructure improvements are evaluated in this EIR as part of the proposed plan’s other supporting infrastructure.

Finally, the SCSP proposes land use designation changes for certain areas, requiring a General Plan amendment. The changes are proposed primarily to 1) reconcile land use designations with existing conditions, 2) to buffer sensitive uses (e.g., residential areas, Orange Center School) with less intensive uses (e.g., business park instead of industrial), and 3) to provide more opportunities for neighborhood-serving general commercial uses near residential areas.

Amending the General Plan to accommodate these changes would remove obstacles to growth. The potential impacts of the General Plan amendment are evaluated in this EIR.

For these reasons the proposed plan does not extend any infrastructure or otherwise eliminate any existing obstacles to growth beyond the growth anticipated by implementation of the proposed plan, which is consistent with the adopted General Plan.

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7.3.2 Stimulation of Economic Activity
A primary impetus for the SCSP is economic development and job growth. More than 14,000 new jobs would be created by 2040 with anticipated development, primarily in the industrial sector, with lesser but still substantial growth in office and retail jobs (Table 7-1).

Table 7-1 Anticipated Job Growth 2022-2040
Land Use Designations Proposed Job Growth
Food (Restaurants) 183 persons
Industrial 10,576 employees
Office 1,928 employees
Retail 1,624 employees
Source: prepared by Ascent Environmental in 2023.

Implementation of the SCSP is expected to create new jobs based on proposed land uses in the Plan Area. The purpose of the proposed plan is to create jobs for the City and accommodate industrial, commercial and office development, and a minimal amount of residential units. Consistent with the General Plan, the proposed plan would promote balance of jobs and housing within the City. Therefore, the environmental implications associated with the stimulation of economic activity would not lead to significant growth-inducing impacts.

SUMMARY OF GROWTH-INDUCING IMPACTS
Although economic and employment growth in the Plan Area is an intended consequence of the proposed plan, growth inducement directly or indirectly by the proposed plan also could affect the greater Fresno region. Potential effects caused by induced growth in the region would include loss of agricultural land, increased light and glare, increase in surface runoff, environmental impacts attributable to increases in regional water use, impacts of surface water quality, loss of cultural resources, transportation safety impacts, air quality impacts, increases in GHG emissions, increase in noise, and increases in demand for public services and utilities.

However, the purpose of the proposed plan is to create jobs for the City and accommodate industrial, commercial and office development, and a minimal amount of residential units. The proposed plan has the potential to generate future development of approximately 12,021,744 square feet (sf) of non-residential uses (including industrial, retail, and office) and 91 new residential dwelling units. As discussed in Section 4.13, “Population and Housing ,” the proposed plan is estimated to result in the addition of approximately 313 new residents and add nearly 14,000 jobs in the City of Fresno by 2040. The City is projected to add nearly 70,000 employees between 2022 and 2040. Therefore, implementation of the proposed plan will create jobs for the City’s projected growth in population and employment.

Consistent with the General Plan, the proposed plan would promote greater balance between jobs and housing in the City. The additional growth of industrial, office, and retail and the small amount of residential units is consistent with citywide planning efforts. Therefore, the proposed plan would not induce substantial unplanned population growth, either directly (i.e., by proposed new unplanned homes) or indirectly (i.e., by the extension of roads or other infrastructure).

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8 LIST OF PREPARERS
City of Fresno (Lead Agency)
Jennifer Clark .............................................................................................................................................................................................. Director Sophia Pagoulatos ................................................................................................................................................................Planning Manager Michelle Zumwalt .................................................................................................................................................................................... Architect Jill Gormley .................................................................................................................................................... Public Works Assistant Director Andreina Aguilar .................................................................................................................. Public Works Chief Engineering Technician Ann Kloos ............................................................................................................................................................ Sustainable Fresno Manager Peter Maraccini ...................................................................................................................... Public Utilities Licensed Engineer Manager Theodore Semonious ............................................................................................................................................................Fire Deputy Chief Robert Beckwith ............................................................................................................................................................................ Police Captain Jeff Long .............................................................................................................................................................. FAX Senior Regional Planner Ed Chinevere .............................................................................................................................................................PARCS Assistant Director Lance Lippincott ....................................................................................................................................... Economic Development Director Lorenzo Nadora ............................................................................................................................................................. Solid Waste Manager Casey Lauderdale ...............................................................................................................................................................Planning Supervisor Lisha Chen ....................................................................................................................................................... Historic Preservation Specialist Karlo Guillermo and Maeketah Sayasane ............................................................................................................................... GIS Specialist Talia Kolluri ................................................................................................................................................ Supervising Deputy City Attorney Kristi Costa........................................................................................................................................................... Senior Deputy City Attorney Ascent Environmental, Inc. (CEQA Compliance)
Sydney Coatsworth ................................................................................................................................................................................. Principal Kathie Washington .................................................................................................................................................................. Project Manager Bryn Kirk ................................................................................................................................................ Aesthetics, Population and Housing Jacklyn Bottomley ....................... Agricultural Resources, Hazards and Hazardous Materials, Hydrology and Water Quality Julia Wilson ........................................................................................... Air Quality, Greenhouse Gas Emissions and Climate Change Grace Mannell ................................................................................................................................................................... Biological Resources Linda Leeman .............................................................................................................................................................................. Senior Biologist Roberto Mora ........................................................................................................................................................................ Cultural Resources Alta Cunningham ................................................................................................................................ Senior Cultural Resources Specialist Nicole Greenfield .......................................................................................................................................................................... Geology/Soils Jim Merk ..................................................................................................................................................................................................... Land Use Marianne Lowenthal .................................................................................................................................................. Public Services, Utilities Eric Cohen ........................................................................................................................................................................................................Noise Jazmin Amini ................................................................................................................................................................... Transportation/Traffic Dimitri Antoniou and Honey Walters ................................................................................. Senior Air Quality/GHG/Noise Specialist Sarah Henningsen ...................................................................................................................................... Senior Environmental Specialist Lisa Merry, Phi V. Ngo ................................................................................................................................................................... GIS Specialist Gayiety Lane ....................................................................................................................................................................... Publishing Specialist Michele Mattei ................................................................................................................................................................... Publishing Specialist Tracy Prybyla ...................................................................................................................................................................... Publishing Specialist Riley Smith ........................................................................................................................................................................... Publishing Specialist Brian Perry ................................................................................................................................................................................ Graphic Specialist TJKM – Transportation Consultant
Chris Kinzel, PE............................................................................................................................................................................... Vice President Arthur Chen ...................................................................................................................................................................Transportation Planner Report Preparers Ascent Environmental
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8-2 South Central Specific Plan Draft EIR
West Yost – Water Supply Assessment
Elizabeth Drayer ............................................................................................................................................................................ Vice President Bonnie Robinson ..................................................................................................................................................................... Senior Engineer I

City of Fresno
South Industrial Priority Area Specific Plan Draft EIR 9-1 9 REFERENCES
Chapter 1 Introduction
City of Fresno. 2024. City of Fresno South Central Specific Plan. Available: https://www.fresno.gov/planning/plans- projects-under-review/#south-central-specific-plan-scsp.

Chapter 2 Executive Summary

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Chapter 3 Project Description
Akel Engineering Group, Inc. 2022. South Central Specific Plan Water and Sewer Hydraulic Analysis Technical Memorandum. Prepared for City of Fresno. Fresno, CA.

City of Fresno. 2023. South Central Specific Plan.

Economic & Planning Systems, Inc. 2022 (October). City of Fresno South Central Specific Plan Nonresidential Real Estate Market Study.

EPS. See Economic & Planning Systems, Inc.

Chapter 4 Environmental Impacts and Mitigation Measures No references used in this chapter.

Section 4.1 Aesthetics
California Department of Transportation. 2023a. Scenic Highways – Frequently Asked Questions. Available:
https://dot.ca.gov/programs/design/lap-landscape-architecture-and-community-livability/lap-liv-i-scenic- highways/lap-liv-i-scenic-highways-faq2. Accessed April 6, 2023. ———. 2023b. California State Scenic Highway System Map. Available:
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa.

Accessed April 24, 2023.

Caltrans. See California Department of Transportation.

City of Fresno. 2020. Fresno General Plan Program Environmental Impact Report. Available:
https://www.fresno.gov/darm/wp-content/uploads/sites/10/2020/03/Fresno-GP-Public-Review-Draft- Program-EIR.pdf. Accessed April 25, 2023.
———. 2022. Fresno General Plan. Originally adopted December 18, 2014. Last amended October 13, 2022. Available:
https://www.fresno.gov/darm/wp-content/uploads/sites/10/2022/12/upload_temp_Consolidated-GP-10-13- 2022.pdf. Accessed April 6, 2023.

Section 4.2 Agricultural Resources
California Department of Conservation, Division of Land Resources Protection, Farmland Mapping and Monitoring Program. 2023. California Important Farmland Finder. Available:
https://maps.conservation.ca.gov/DLRP/CIFF/.

City of Fresno. 2014 (December 18). City of Fresno General Plan. Available: https://www.fresno.gov/darm/general- plan-development-code/. Adopted December 18, 2014.
———. 2020 (March). Fresno General Plan Public Review Draft Program Environmental Impact Report . Available:
https://www.fresno.gov/darm/wp-content/uploads/sites/10/2020/03/Fresno-GP-Public-Review-Draft- Program-EIR.pdf.

References Ascent Environmental
City of Fresno
9-2 South Industrial Priority Area Specific Plan Draft EIR ———. 2022 (April). Official Zoning Map. Available: https://www.fresno.gov/darm/wp - content/uploads/sites/10/2022/04/Official-Zoning-Map_20220411.pdf. ———. 2023. Municipal Code of Ordinances. Available at:
https://library.municode.com/ca/fresno/codes/code_of_ordinances.

County of Fresno. 2021. 2021 Crop Report. Available:
https://www.co.fresno.ca.us/home/showpublisheddocument/70296/638022856069870000. ———. 2023. County of Fresno-Zoning. Available: https://gisportal.co.fresno.ca.us/portal/apps/webappviewer/ index.html?id=b921843d343d4df998b5b3c6a301756a.

DOC. See California Department of Conservation.

Section 4.3 Air Quality
California Air Resources Board. 2003. HARP User Guide. Sacramento, CA. ———. 2005. Air Quality and Land Use Handbook: A Community Health Perspective . Available:
https://ww2.arb.ca.gov/sites/default/files/2023-05/Land%20Use%20Handbook_0.pdf. Access September 27, 2023.
———. 2016 (May 4). Ambient Air Quality Standards. Available: https://ww2.arb.ca.gov/sites/default/files/2020 - 07/aaqs2.pdf. Accessed September 27, 2023.
———. 2023a. Overview: Diesel Exhaust & Health. Available: https://ww2.arb.ca.gov/resources/overview -diesel- exhaust-and-health. Accessed September 27, 2023.
———. 2023b. Air Quality Standards homepage. Available: https://ww2.arb.ca.gov/resources/background -air-quality- standards. Accessed September 27, 2023.

California Department of Transportation. 2022. 2015 Traffic Volumes for ALL vehicles on CA State Highways. Available:
http://www.dot.ca.gov/trafficops/census/volumes2015/. Accessed September 27, 2023.

CalEPA. See California Environmental Protection Agency.

California Environmental Protection Agency. 2023. CalEnviroScreen 4.0 Modeling Tool. Available:
https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40. Accessed September 27, 2023.

Caltrans. See California Department of Transportation.

CARB. See California Air Resources Board.

EPA. See US Environmental Protection Agency.

OEHHA. See Office of Environmental Health Hazard Assessment.

Office of Environmental Health Hazard Assessment. 2015. Air Toxics Hot Spots Program: Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments. Available:
https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. Accessed September 27, 2023.

Sacramento Metropolitan Air Quality Management District. 2021 (April). Guide to Air Quality Assessment in Sacramento County. Originally released in 2009. Available: https://www.airquality.org/businesses/ceqa-land- use-planning/ceqa-guidance-tools. Accessed September 27, 2023.

San Joaquin Valley Air Pollution Control District. 2015a. Guidance for Assessing and Mitigating Air Quality Impacts .