Exhibit I - Public Comments — Fresno City Council, June 12, 2025

Complicating the flow of traffic further at N. Prospect and Herndon by adding additional traffic from an 82 unit apartment complex will lead to undue congestion and innumerable fenderbender accidents along N. Prospect.

One must expect that most of the target clientele (senior citizens) of the proposed project will be moving into the apartments to “down-size” their remaining years and will have two vehicles or the residents will be working parents with two vehicles. The proposed apartment complex does not have adequate parking facilities to accommodate even 150 vehicles, much less 164 cars and trucks. Local street parking lacks the capacity to support more than a few extra vehicles.

May I suggest that several changes be made to either or both the proposed complex or the surrounding street traffic infrastructure. Certainly, anticipating the numerous problems noted above and providing solutions prospectively would seem wise. I remember that the traffic signal at Marks and Herndon Avenue was constructed to replace the 4-way stop signs only after a Supervisor’s teenage daughter was killed in a traffic accident at that intersection.

Prospectively dealing with the above mentioned problems might save lives in the future.

I humbly suggest several potential solutions:

1. Down-size the proposed project to a maximum of two-story buildings

2. Move the entrance and exit from the proposed complex to W. Fir Avenue instead of N.

Prospect Avenue.

3. Widen the frontage road portion of N. Valentine Avenue that parallels Herndon Avenue and add a sidewalk along the northern portion of that road and along N. Prospect Avenue while widening N. Prospect Avenue itself along with the construction of a larger traffic turning circle to N. Prospect Avenue.

4. Maintain or increase the number of parking spaces in the proposed complex despite downsizing the number of proposed housing units themselves.

These corrective suggestions surely might be implemented by either the city or the developer of Parcel Number P24-00794 if the City of Fresno were concerned for any future residents of any development project on the aforementioned parcel of land.

In conclusion, I strenuously object to the Notice of Intent to Adopt a Mitigated Negative Declaration as a city wide code amendment and more specifically for application of any such declaration in regard to Parcel Number P24-00794 for the reasons stated above because development of the parcel per Building App. No. P21-00989 without significant corrective measures would place future resident adults and their children at significant risk of injury.

Yours Sincerely,
Virgil M. Airola
From:

To: Adrienne Asadoorian
Subject: Object to the Notice of Intent to Adopt a Mitigated Negative Declaration listed with Parcel Number P24-00794 Date: Thursday, December 19, 2024 6:27:33 AM
External Email: Use caution with links and attachments
We would like to object to the Notice of Intent to Adopt a Mitigated Negative Declaration listed with Parcel Number P24-00794 even though it is a city wide text code amendment.

This would affect three parcels in our neighborhood that are currently zoned for office and potentially a number of existing offices. We already have one parcel zoned for high density multi family. This parcel at Prospect and Herndon was rezoned as part of the 2030 rezone.

We object to the ministerial zoning that "meets the City's development code." There is no planning involved with this code. The Planning Department does not consider any existing or future problems that might be exacerbated by the development. The planners and city council do not consider the preservation and character of the neighborhood.

The City has created the problems that make multi family development in this neighborhood impractical. We have made the City aware of these problems on NUMEROUS occasions starting with emails to Councilman Karbassi in 2019. We have attended numerous meetings. We delivered 929 signatures to the Planning Department on 9/20/21 and again in May 2024. These signatures were attached to a document that noted:
1) Inadequate parking for Orchid Park. The parking was inadequate for what they planned the park to be from day 1. It should be noted that original property owners paid park fees and had to wait 10 or more years for the park to be finally built. Councilman Karbassi has acknowledged this problem but it hasn't been fixed. Mayor Jerry Dyer has said that these "neighborhood parks have become regional parks." It should be noted that the Pickleball courts at Orchid Park are one of the most popular in the city. The parking lot often barely accommodates this. 2) No street parking for the vehicles that will be generated by new developments. The parking requirements listed by a state code used by the Planning Department are totally inadequate for multi family housing:
3) The small short street (Prospect) with the POORLY DESIGNED ROUNDABOUT and unworkable traffic flow on one of the two access roads into the neighborhood. 4) Altered traffic patterns throughout the neighborhood as a result of people avoiding Prospect and using Brawley Avenue instead. Again the city is adding higher density on each parcel leading to roads through the neighborhood that were not designed to handle that traffic. With each new development the quality of life in the existing neighborhood has deteriorated. 5) School safety. There should be a direct path from both the existing new developments and the proposed new ones for children to walk to their elementary school.It is not safe for children to navigate alone which generates even more traffic.
6) Public Safety Vehicles. Ambulance and Fire Department vehicles have trouble navigating the roundabout and when Valentine is clogged with traffic, they cannot access the neighborhood. 7) Noise and Air Pollution. Herndon is exponentially busier than it was when the neighborhood was developed. There is a lot more noise that can be heard from blocks away. Sirens, gunning engines, and just the heavier traffic can be heard blocks away. 8) Ingress and egress. The City is allowing ingress and egress on the two main feeder streets on proposed plans for new developments. This will exacerbate the congestion on these streets at peak times and cause traffic to back up onto Herndon Avenue.

We object to the Notice of Intent to Adopt a Mitigated Negative Declaration listed in the subject line We object to the text
code amendment that would allow ministerial zoning for multi-family in our neighborhood. Please consider these our official signatures for objection.

Kellie Romero
Paul Romero
Sent from my iPhone

From:

To: Adrienne Asadoorian
Subject: Objection letter
Date: Thursday, December 19, 2024 3:28:57 PM
External Email: Use caution with links and attachments
I object to the NOTICE OF INTENT TO ADOPT A MITIGATED NEGATIVE DECLARATION with application number P24-00794 for a citywide text code amendment.

We have been fighting multi family development in our neighborhood for the past four years. A parcel was rezoned for multi family in 2015 during a citywide rezone. This was also done during the Christmas holiday season and approved by the city council in early 2015.

The public was only notified of this amendment in a small ad in the classified section of the Fresno Bee. This may comply with the Municipal Code, but as was pointed out at the City Council meeting last July, most of us do not subscribe to the Bee and fewer read the public notices. The City uses many forms of communication when they want the public to know about something. The Municipal Code should be updated. My husband found this in the Planning Department notices only because he checked on the listed notice. If we had not specifically requested to receive the notices by going down to city hall we never would have known about this.

I further object to the fact that our elected city representatives were aware of this text amendment when we were at the City Council hearing on July 25th of this year. This amendment would totally undermine all of our neighborhood objections on the parcel in question.

We are citizens who have to try to keep track of these things ourselves. We do not have community activists from non profit organizations or non profit legal firms representing us.

I doubt it is just luck that these proposals and meetings almost always coincide with the holidays when they think the public will be busy.

This text amendment went out to the various Project Review Committees in August and September which was shortly after the City Council voted in July. It certainly appears that our elected officials and city management do not want us to find out about these things until it is too late.

We have repeatedly outlined the issues with traffic, parking, inadequate and unworkable roads, and public safety access into the existing neighborhood at peak times. This amendment would eliminate any opposition to zoning changes without consideration of the impact on the neighborhood.

We also highly object to having the representation process eliminated. We worked very hard for our homes. We want our government to be transparent and have our voices heard.

Many recent state policies have been responsible for billions of wasted taxpayer dollars. Many more have not worked. We do not want our neighborhood to be the victim of an unproven state policy that will be PERMANENT once it is adopted. When the obvious problems arise the city officials will throw up their hands and claim unforeseen circumstances.

I would ask you to not approve this text amendment which eliminates the voice of the people in the development process which is already secretive enough.

If this amendment is adopted I would ask that the undeveloped parcels between Marks and Milburn on Herndon Ave be removed or excluded from this amendment.

Thank you for your consideration.

Debbie Nard
Sent from my iPad

From:

To: Adrienne Asadoorian
Subject: Objection to Notice of Intent to Adopt a Mitigated Negative Declaration P-2400794 Date: Thursday, December 19, 2024 9:48:32 PM
External Email: Use caution with links and attachments
I am objecting to this proposal as it will remove the opportunity to voice our legitimate concerns regarding infrastructure, traffic, parking and public safety on the parcels deemed eligible by the proposal.

The community where my husband and I have lived for several years has recently navigated the process of having a property rezoned without our community's knowledge. When the proposed development for the rezoned property was made public, the neighbors voiced their concerns regarding infrastructure, traffic and public safety in front of the Fresno Planning Commission and The Fresno City Council. Both voted against the proposed development.

During this process, the city management refused to come out to look at the traffic congestion after being asked to do so by the neighbors.

The public's input is necessary to ensure responsible development and those neighbors living in the potentially impacted communities have their voices heard!!!! I would ask that this proposal be denied in total, or at least remove the properties on Herndon between Marks and Millburn from the list of properties eligible for this action.

Respectfully submitted,
Paula Moradian
From:

To: Adrienne Asadoorian
Cc:

Subject: Objection to Notice of Intent to Adopt a Mitigated Negative Declaration P-2400794 Date: Wednesday, December 18, 2024 8:51:10 PM
External Email: Use caution with links and attachments
I am objecting to this proposal as it is yet another measure that will reduce local control over building in the various parts of the city. This proposal would effectively eliminate the input from neighboring properties on the parcels deemed eligible by this proposal.

Just in my neighborhood there are parcels that have been requested for rezone to build housing. The neighbors have raised their objections due to lack of infrastructures in the area. There is currently litigation over one development.

This proposal would effectively overturn the decision from the Project Review Committee, the Planning Commission, and the City Council.

The Planning Department never considers the impact on the surrounding properties in making their determinations.

By allowing housing development on property zoned office invites a multitude of problems with traffic, parking, and public safety.

I would ask that this proposal be denied in total, or at least remove the properties on Herndon between Marks and Milburn from the list of properties eligible for this action.

Thank you for your consideration.

Dennis Nard.

Sent from my iPad

From:

To: Adrienne Asadoorian
Subject: Objection to the Notice of Intent to Adopt a Mitigated Negative Declaration listed with Parcel Number P24-00794 Date: Friday, December 20, 2024 2:30:47 PM
External Email: Use caution with links and attachments
Dear Adrienne
My wife and I are objecting to the Notice of Intent to Adopt a Mitigated Negative Declaration listed
with Parcel Number P 2 4 - 0 0 7 9 4 even though it is a city wide text code amendment.

This text code amendment would affect three parcels in our neighborhood that are currently zoned for office space.

We already have one parcel zoned for high density, multi family. This parcel at Prospect and Herndon was rezoned as part of the 20-30 rezone
during the Holiday Season in 2015 with no input from nearby residents.

We object to the ministerial zoning that "meets the City's development code."
There is no planning involved with this code.

The Planning Department does not consider any existing or future problems that might be exacerbated by the
development.

The planners and city council do not consider the preservation and character of the neighborhood.

The City has created the problems that make multifamily development in our neighborhood
impractical.

The following issues were pointed out to the Planning Department regarding proposed high density housing on Parcel Number P24 – 00794:
1) Inadequate parking for Orchid Park. The parking was inadequate for what they planned the
park to be from day 1. It should be noted that original property owners paid park fees and had to
wait 10 or more years for the park to be finally built. Councilman Karbassi has acknowledged
this problem but it hasn't been fixed. Mayor Jerry Dyer has said that these "neighborhood parks
have become regional parks." It should be noted that the Pickleball courts at Orchid Park are
one of the most popular in the city. The parking lot often barely accommodates this.
2) No street parking for the vehicles that will be generated by new developments. The parking
requirements listed by a state code used by the Planning Department are totally inadequate for
multifamily housing:
3) The small short street (Prospect) with the POORLY DESIGNED ROUNDABOUT and
unworkable traffic flow on one of the two access roads into the neighborhood. The city has long
promised to run Fir through to Valentine Avenue when they build the park. It was promised again
when Leo Wilson built a large housing development adjacent to the park. Just this year it was
considered but then cancelled by Councilman Karbassi at the budget hearing. Jerry Dyer now
says those promises from the city are "too old."
4) Altered traffic patterns throughout the neighborhood as a result of people avoiding Prospect
and using Brawley Ave instead. Again, the city is adding higher density on each parcel
leading to roads through the neighborhood that were not designed to handle that traffic. With
each new development the quality of life in the existing neighborhood has deteriorated.
5) School safety. There should be a direct path from both the existing new developments and
the proposed new ones for children to walk to their elementary school.

The City Manager,
Georgeanne White says that, "they are not required to provide one." The neighborhood is
already choked with traffic at peak pick up and drop off times. It is not safe for children to
navigate alone which generates even more traffic.
6) Public Safety Vehicles . Ambulance and Fire Department vehicles have trouble navigating the
roundabout and when Valentine is clogged with traffic, they cannot access the neighborhood
NOW.
7) Noise and Air Pollution. Herndon is exponentially busier than it was when the neighborhood
was developed. There is a lot more noise that can be heard from blocks away. Sirens, gunning
engines, and just the heavier traffic can be heard blocks away. 8) Ingress and egress. The City is allowing ingress and egress on the two main feeder streets on
proposed plans for new developments. This will exacerbate the congestion on these streets at
peak times and cause traffic to back up onto Herndon Avenue.

We are aware that the STATE OF CALIFORNIA is pushing this along with many other policies that
DO NOT WORK. These proposed developments will be permanent once they are built no matter
what problems they cause.

December 11, 2024
Larry Fleming
To; Adrienne Asadoorian, City of Fresno

I would like to object to the Notice of Intent to Adopt a Mitigated Negative Declaration listed with Parcel Number P24-00794 even though it is a city-wide text code amendment.

Sierra Sky Park is unique. It is the first community in the United States, ever built around aviation. It was built in 1946, far north of Fresno, with wide open spaces and farmland surrounding it. The founders of Sierra Sky Park built a community that safely promoted aviation and prevented any potential problems with a densely populated urban area. It is important to remember that Sierra Sky Park was there first. Fresno has grown over the many years and now borders Sierra Sky Park, slowly and surely encroaching on its way of life; aviation. Although I do not live at Sierra Sky Park, I like airplanes. I love seeing them land and take-off and so do many of my friends. We enjoy the day-to-day operation and events sponsored by the community of Sierra Sky Park. Sierra Sky Park is not just a place for pilots; it is also a place for the general public to watch and enjoy flying; a place where mom and dad take the kids to show them real airplanes, up close. My two sons were even invited to take a flight there when they were young. Sierra Sky Park is one of Fresno’s jewels.

I am concerned to hear that there is a proposal to rezone land around Sierra Sky Park, which may threaten its operations. If this new zoning plan is approved, I believe it will set the scene for future conflict; expensive lawsuits, complaints, and possible safety issues. It will be a lose/lose situation for the Sky Park, for the residences of any new development, and for the City of Fresno. Why would the City of Fresno consider changing an already adopted land use plan; a costly plan that had been thoroughly studied, agreed upon and makes sense? There are plenty of other places in our city to build apartments, but there is only one Sierra Sky Park.

The Community of Sierra Sky Park realizes that the city will continue to grow and that stuff is going to be built around the airport. They only want to make sure that development goes according to the existing land use plan and will not threaten the core of the neighborhood; flying. I urge the City of Fresno to work with the people of Sierra Sky Park and only allow development around the airport that is consistent with the its ability to operate.

Sincerely,
Larry Fleming

Subject: Formal Objection to Proposed Zoning Changes (Parcel Number P24-00794) To: [email protected]
I am writing to formally object to the Notice of Intent to Adopt a Mitigated Negative Declaration related to Parcel Number P24-00794, which is part of a citywide text code amendment. While this amendment affects multiple areas, its implications for our neighborhood are particularly concerning.

This amendment targets three parcels currently zoned for office use and potentially others, in addition to the one parcel already rezoned for high-density multifamily housing at Prospect and Herndon. That rezoning occurred during the 2015 holiday season with little to no input from affected residents. Unlike other districts, such as District 6, this area lacks adequate protections for parking and density concerns, leaving the community vulnerable to overdevelopment.

Specific Concerns:

1. Lack of Planning and Neighborhood Consideration:
• Ministerial zoning that "meets the City’s development code" disregards the unique needs and existing challenges in our neighborhood.
• There has been no effort to consider how this amendment exacerbates ongoing issues such as traffic congestion, safety, and quality of life.

2. Broken Promises and Community Frustration:
• Despite numerous emails, meetings, and petitions—most notably 929 signatures submitted in September 2021 and May 2024—the City has not addressed longstanding issues, including inadequate parking at Orchid Park, poor road infrastructure, and insufficient traffic mitigation measures.

3. Traffic and Safety Concerns:
• The poorly designed roundabout on Prospect Street, coupled with inadequate access roads, already causes significant congestion. Increased density will only worsen these conditions. • There is no safe path for children walking to the local elementary school, further endangering students during peak traffic times.
• Emergency vehicles such as ambulances and fire trucks struggle to navigate the neighborhood's current infrastructure.

4. Environmental and Quality-of-Life Impacts:
• Increased noise and air pollution due to heavy traffic on Herndon Avenue directly affect residents’ well-being.
• The City's allowance for ingress and egress onto main feeder streets will further congest these roads and create backups onto Herndon.

5. Lack of Transparency and Public Engagement:
• The City has failed to provide clear and timely communication about this amendment, raising concerns about its commitment to transparency.
• High-density housing proposals have previously been rejected by the Project Review Committee, Planning Commission, and City Council. This amendment would overturn those decisions, disregarding the will of the community.

Conclusion: This amendment undermines the public’s right to participate in decisions about their neighborhoods and disregards the valid concerns of residents who have fought for responsible development. The proposed changes would impose permanent, detrimental impacts on our community; further eroding trust in the City’s planning process.

I respectfully urge the City to reject this amendment. It is imperative that community voices are considered, and that thoughtful, transparent planning takes precedence over rushed policies.

Thank you for your attention to this matter.

Sincerely,
Name: Peter Nunez Address:

From:

To: Adrienne Asadoorian
Subject: I Object to the city"s intent about Parcel Number P24-00794 Date: Tuesday, December 10, 2024 9:48:31 PM
External Email: Use caution with links and attachments
I couldn't say it better than the Objections listed below, written by my neighbor.

I agree with all these points.

Particularly, I find it unscrupulous to try to push these zoning issues through at holiday time. I think "Shame on you."

OBJECTIONS
We would like to object to the Notice of Intent to Adopt a Mitigated Negative Declaration listed
with Parcel Number P24-00794 even though it is a city wide text code amendment.

This would affect three parcels in our neighborhood that are currently zoned for office and
potentially a number of existing offices. We already have one parcel zoned for high density
multi family. This parcel at Prospect and Herndon was rezoned as part of the 2030 rezone
during the Holiday Season in 2015 with no input from nearby residents.

Steve Brandau did not protect his constituents with provisions to revisit parking and density like
were done in District 6.

We object to the ministerial zoning that "meets the City's development code." There is no
planning involved with this code. The Planning Department does not consider any existing or
future problems that might be exacerbated by the development. The planners and city council
do not consider the preservation and character of the neighborhood.

The parking
requirements listed by a state code used by the Planning Department are totally inadequate for
multi family housing:
3) The small short street (Prospect) with the POORLY DESIGNED ROUNDABOUT and
unworkable traffic flow on one of the two access roads into the neighborhood. The city has long
promised to run Fir through to Valentine Avenue when they build the park. It was promised again
when Leo Wilson built a large housing development adjacent to the park. Just this year it was
considered but then cancelled by Councilman Karbassi at the budget hearing. Jerry Dyer now
says those promises from the city are "too old."
4) Altered traffic patterns throughout the neighborhood as a result of people avoiding Prospect
and using Brawley Avenue instead. Again the city is adding higher density on each parcel
leading to roads through the neighborhood that were not designed to handle that traffic. With
each new development the quality of life in the existing neighborhood has deteriorated.
5) School safety. There should be a direct path from both the existing new developments and
the proposed new ones for children to walk to their elementary school. The City Manager,
Georgeanne White says that, "they are not required to provide one." The neighborhood is
already choked with traffic at peak pick up and drop off times. It is not safe for children to
navigate alone which generates even more traffic.
6) Public Safety Vehicles. Ambulance and Fire Department vehicles have trouble navigating the
roundabout and when Valentine is clogged with traffic, they cannot access the neighborhood
NOW.
7) Noise and Air Pollution. Herndon is exponentially busier than it was when the neighborhood
was developed. There is a lot more noise that can be heard from blocks away.

Sirens, gunning
engines, and just the heavier traffic can be heard blocks away. 8) Ingress and egress. The City is allowing ingress and egress on the two main feeder streets on
proposed plans for new developments. This will exacerbate the congestion on these streets at
peak times and cause traffic to back up onto Herndon Avenue.

If this amendment is such a good idea, why has the City gone to such great lengths to keep this
from the public. When Councilman Karbassi was asked about this notice the response was "was
this something you received in the mail?" We never received any answer as to what this was
going to do.

The City has refused to keep their promises. They refuse to fix the problems brought forth to
them. They definitely are not transparent in their actions.

High density multi family housing has already been rejected by the Project Review Committee,
the Planning Commission, and by the City Council. This amendment would basically overturn
those decisions and ruin a neighborhood that already has all types of housing. This amendment
would negate the will of the people who have already prevailed on this issue despite a secretive,
abusive, and uneven playing ground.

As this amendment will further erode the public's right to participate in addressing development
in their own communities it should be denied.
--
Nadine Brubaker Howell
Fresno, CA
From:

To: Adrienne Asadoorian
Subject: Notice of Intent to Adopt a Mitigated Negative Declaration regarding Parcel P24-00794 Date: Saturday, December 14, 2024 10:46:01 AM
External Email: Use caution with links and attachments
December 14, 2024
RE: Notice of Intent to Adopt a Mitigated Negative Declaration regarding Parcel P24-00794 Dear Ms. Asadoorian:

I am writing to object to the Notice of Intent to Adopt a Mitigated Negative Declaration regarding Parcel P24-00794 and the reconsideration of Building App. No. P21-00989 that previously failed to gain approval by Project Review Committee, the Fresno Planning Commission, and the City Council for numerous problematic issues.. The 82 unit 3 and 4 story apartment complex at Herndon Avenue and N. Prospect Avenue as proposed should not be built as currently planned for a number of significant reasons that present several potential risks and liability for future residents of the facility.

These include:

1. Building evacuation in case of fire,

2. Access to the proposed project off Prospect by the fire department,

3. Safe pedestrian pathways from the proposed project to the H. Roger Tatarian elementary school,

4. Increased traffic thru the poorly configured and too small traffic circle on Prospect, north of Herndon, and

5. Inadequate parking spaces for the proposed complex.

The developer’s representative at the Planning Commission meeting stated that the target clientele of the proposed project would be senior citizens. Many elderly individuals have limited mobility and some seniors are easily confused when placed in stressful situations, particularly if they have mild dementia. During a building evacuation because of fire when elevator use is prohibited, many senior citizens may be unable to quickly negotiate third and fourth floor stairways to move to safety outside the buildings. In addition , the four-story portion will not have windows on the eastern side of the building thereby limiting rescue access by firefighters using ladder trucks.

N. Prospect Avenue itself is too narrow at the level of the tiny turn-around circle to accommodate a pickup truck towing a moderate-sized trailer. I question the ability of a fire ladder truck to negotiate a turn into the proposed complex especially if and when facility residents are attempting to move their vehicles to safety. These difficulties would certainly delay both fire fighter evacuations of facility residents and delay implementation of fire fighting efforts.

Despite the developer’s belief that the proposed complex would be largely inhabited by senior citizens, one must assume that given its proximity to an elementary school, any number of families with children would also be residents of the complex. Safe pedestrian pathways do not exist currently between the proposed complex and H. Roger Tatarian elementary school; rather children would need to either walk along the gravel shoulder of the narrow two lane portion of N. Valentine Avenue that parallels Herndon Avenue or traverse the open field north of that side road. Placing those young children at risk from drivers hurrying to work along the already congested road seems unwise when increased traffic along N. Prospect from the proposed complex must be assumed.

The poorly designed connection of N. Valentine Avenue to Herndon Avenue, where N. Valentine becomes a frontage road that enters Prospect Avenue from the West, has already created a significant obstacle to the smooth flow of traffic from N. Valentine onto Herndon Avenue. Complicating the flow of traffic further at N. Prospect and Herndon by adding additional traffic from an 82 unit apartment complex will lead to undue congestion and innumerable fender-bender accidents along N. Prospect.

One must expect that most of the target clientele (senior citizens) of the proposed project will be moving into the apartments to “downsize” their remaining years and will have two vehicles or the residents will be working parents with two vehicles. The proposed apartment complex does not have adequate parking facilities to accommodate even 150 vehicles, much less 164 cars and trucks. Local street parking lacks the capacity to support more than a few extra vehicles.

May I suggest that several changes be made to either or both the proposed complex or the surrounding street traffic infrastructure.

Certainly, anticipating the numerous problems noted above and providing solutions prospectively would seem wise. I remember that the traffic signal at Marks and Herndon Avenue was constructed to replace the 4-way stop signs only after a Supervisor’s teenage daughter was killed in a traffic accident at that intersection. Prospectively dealing with the above mentioned problems might save lives in the future.

I humbly suggest several potential solutions:

1. Down-size the proposed project to a maximum of two-story buildings

2. Move the entrance and exit from the proposed complex to W. Fir Avenue instead of N. Prospect Avenue.

4. Maintain or increase the number of parking spaces in the proposed complex despite down-sizing the number of proposed housing units themselves.

Yours Sincerely,
Virgil M. Airola
From:

To: Adrienne Asadoorian
Cc:

Subject: Objection to the Notice of Intent re:Parcel#P24-00794 Date: Saturday, December 14, 2024 2:38:00 PM
External Email: Use caution with links and attachments
Please see attached letter. Thank you for your assistance and consideration.

From:

To: Adrienne Asadoorian
Cc:

Subject: Objection to the Notice of Intent to Adopt a Mitigated Negative Declaration Date: Tuesday, December 17, 2024 1:54:44 PM
Attachments: Objection Signatures.pdf
External Email: Use caution with links and attachments
We would like to object to the Notice of Intent to Adopt a Mitigated Negative Declaration listed with Parcel Number P24-00794 even though it is a city wide text code amendment. This would affect three parcels in our neighborhood that are currently zoned for office and potentially a number of existing offices. We already have one parcel zoned for high density multi family. This parcel at Prospect and Herndon was rezoned as part of the 2030 rezone during the Holiday Season in 2015 with no input from nearby residents. Steve Brandau did not protect his constituents with provisions to revisit parking and density like were done in District 6. We object to the ministerial zoning that "meets the City's development code." There is no planning involved with this code. The Planning Department does not consider any existing or future problems that might be exacerbated by the development. The planners and city council do not consider the preservation and character of the neighborhood. The City has created the problems that make multi family development in this neighborhood impractical. We have made the City aware of these problems on NUMEROUS occasions starting with emails to Councilman Karbassi in 2019. We have attended numerous meetings. We delivered 929 signatures to the Planning Department on 9/20/21 and again in May 2024. These signatures were attached to a document that noted: 1) Inadequate parking for Orchid Park. The parking was inadequate for what they planned the park to be from day 1. It should be noted that original property owners paid park fees and had to wait 10 or more years for the park to be finally built. Councilman Karbassi has acknowledged this problem but it hasn't been fixed. Mayor Jerry Dyer has said that these "neighborhood parks have become regional parks." It should be noted that the Pickleball courts at Orchid Park are one of the most popular in the city.

The parking lot often barely accommodates this. 2) No street parking for the vehicles that will be generated by new developments. The parking requirements listed by a state code used by the Planning Department are totally inadequate for multi family housing:
3) The small short street (Prospect) with the POORLY DESIGNED ROUNDABOUT and unworkable traffic flow on one of the two access roads into the neighborhood. The city has long promised to run Fir through to Valentine Avenue when they build the park. It was promised again when Leo Wilson built a large housing development adjacent to the park. Just this year it was considered but then cancelled by Councilman Karbassi at the budget hearing. Jerry Dyer now says those promises from the city are "too old.") Altered traffic patterns throughout the neighborhood as a result of people avoiding Prospect and using Brawley Avenue instead. Again, the city is adding higher density on each parcel leading to roads through the neighborhood that were not designed to handle that traffic. With each new development the quality of life in the existing neighborhood has deteriorated. 5) School safety. There should be a direct path from both the existing new developments and the proposed new ones for children to walk to their elementary school. The City Manager, Georgeanne White says that, "they are not required to provide one." The neighborhood is already choked with traffic at peak pick up and drop off times. It is not safe for children to navigate alone which generates even more traffic. 6) Public Safety Vehicles. Ambulance and Fire Department vehicles have trouble navigating the roundabout and when Valentine is clogged with traffic, they cannot access the neighborhood NOW. 7) Noise and Air Pollution. Herndon is exponentially busier than it was when the neighborhood was developed. There is a lot more noise that can be heard from blocks away. Sirens, gunning engines, and just the heavier traffic can be heard blocks away. 8) Ingress and egress. The City is allowing ingress and egress on the two main feeder streets on proposed plans for new developments. This will exacerbate the congestion on these streets at peak times and cause traffic to back up onto Herndon Avenue. We are aware that the STATE OF CALIFORNIA is pushing this along with many other policies that DO NOT WORK. These proposed developments will be permanent once they are built no matter what problems they cause. If this amendment is such a good idea, why has the City gone to such great lengths to keep this from the public. When Councilman Karbassi was asked about this notice the response was "was this something you received in the mail?" We never received any answer as to what this was going to do. The City has refused to keep their promises. They refuse to fix the problems brought forth to them.

They definitely are not transparent in their actions.

We are aware that the STATE OF CALIFORNIA is pushing this along with many other policies that DO NOT WORK.

These proposed developments will be permanent once they are built no matter what problems they cause. If this amendment is such a good idea, why has the City gone to such great lengths to keep this from the public. When Councilman Karbassi was asked about this notice the response was "was this something you received in the mail?" We never received any answer as to what this was going to do. The City has refused to keep their promises. They refuse to fix the problems brought forth to them. They definitely are not transparent in their actions. High density multi family housing has already been rejected by the Project Review Committee, the Planning Commission, and by the City Council. This amendment would basically overturn those decisions and ruin a neighborhood that already has all types of housing. This amendment would negate the will of the people who have already prevailed on this issue despite a secretive, abusive, and uneven playing ground. As this amendment will further erode the public's right to participate in addressing development in their own communities it should be denied.

Please see the attached signature page.

Thank you,
Ulysses Caiati, President
Sierria Sky Park Property Owners Association
From:

To: Adrienne Asadoorian
Subject: Parcel Number P24-00794
Date: Monday, December 9, 2024 3:39:15 PM
Attachments: San Joaquin Neighbors Comments.docx
External Email: Use caution with links and attachments
Subject: Formal Objection to Proposed Zoning Changes (Parcel Number P24-00794) To: [email protected]
I am writing to formally object to the Notice of Intent to Adopt a Mitigated Negative Declaration related to Parcel Number P24-00794, which is part of a citywide text code amendment. While this amendment affects multiple areas, its implications for our neighborhood are particularly concerning.

Specific Concerns:

1. Lack of Planning and Neighborhood Consideration:

Ministerial zoning that "meets the City’s development code" disregards the unique needs and existing challenges in our neighborhood.

There has been no effort to consider how this amendment exacerbates ongoing issues such as traffic congestion, safety, and quality of life.

2. Broken Promises and Community Frustration:

Despite numerous emails, meetings, and petitions—most notably 929 signatures submitted in September 2021 and May 2024—the City has not addressed longstanding issues, including inadequate parking at Orchid Park, poor road infrastructure, and insufficient traffic mitigation measures.

3. Traffic and Safety Concerns:

The poorly designed roundabout on Prospect Street, coupled with inadequate access roads, already causes significant congestion. Increased density will only worsen these conditions.

There is no safe path for children walking to the local elementary school, further endangering students during peak traffic times.

Emergency vehicles such as ambulances and fire trucks struggle to navigate the neighborhood's current infrastructure.

4. Environmental and Quality-of-Life Impacts:

Increased noise and air pollution due to heavy traffic on Herndon Avenue directly affect residents’ well-being.

The City's allowance for ingress and egress onto main feeder streets will further congest these roads and create backups onto Herndon.

5. Lack of Transparency and Public Engagement:

The city has failed to provide clear and timely communication about this amendment, raising concerns about its commitment to transparency.

High-density housing proposals have previously been rejected by the Project Review Committee, Planning Commission, and City Council. This amendment would overturn those decisions, disregarding the will of the community.

Conclusion:

This amendment undermines the public’s right to participate in decisions about their neighborhoods and disregards the valid concerns of residents who have fought for responsible development. The proposed changes would impose permanent, detrimental impacts on our community; further eroding trust in the City’s planning process.

I respectfully urge the city to reject this amendment. It is imperative that community voices are considered, and that thoughtful, transparent planning takes precedence over rushed policies.

Thank you for your attention to this matter.

Sincerely,
Name: Peter Nunez (signed copy is attached) Address:

Peter Núñez
President
General Teamsters Local 431

From:

To: Adrienne Asadoorian
Subject: COMMENT - Development Code Text Amendment No. P24-00794 Date: Wednesday, December 11, 2024 1:35:51 PM
Attachments: O proposal.pages
External Email: Use caution with links and attachments
Dear Adrienne Asadoorian,
I’d like to submit a comment in opposition of Development Code Text Amendment No. P24-00794. I have added it as an attachment and also pasted a copy below in case the attachment does not open.

Please let me know if I need to send the comment somewhere else or if you have any questions.

Thanks,
Kimberly Sabree
December 11, 2024
Dear Planning Commission,
I am writing today in opposition of amendment P24-00794. I commend Fresno’s work to increase housing overall and increase city infill, however I do not agree that changing O zoning regulations to include RM-3 units to be best for the city. On Page 1, I will outline my concerns in general and on Page 2, I will demonstrate how a blanket conversion could play out in my neighborhood.

I would love to see Fresno transformed from a sprawling, car-reliant society to a walkable city so much so I even dream about our canal banks being transformed into beautiful walking trails. I do not believe that changing zoning of O to allow RM-3 achieves this goal.

One question I have is, why was the decision made to change O to RM-3 instead of RM-1 or RM-2 or allowing the owner to decide RM-1, 2 or 3 based on lot size and location? Why wasn’t CMX or RMX chosen instead? RM-3 adds only more housing to neighborhoods. It does not make a neighborhood more walkable. Using CMX or RMX would encourage decreased reliance on cars as people living above, and in close neighborhoods, could easily walk to offices and businesses below. By allowing bars and restaurants under housing, Fresno could also decrease incidence of DUI.

When I think about office-to-dwelling conversions or allowing new stand-alone multi-unit residential development in O zoned parcels, I immediately have many concerns.

One concerns is the safety of families living in these units. Some O lots/buildings are among other currently undeveloped O lots. While the new residential units may have some parking and sidewalks, will the adjoining lots continue the sidewalks? If only a small lot is converted, will any changes be made to roads and crosswalks? I worry about parks—or lack thereof. These O zoned areas also tend to have fewer parks. If lots are converted to RM-3, there will be a lot of people, including families with children, added to the neighborhood. Will the developer be required to set apart space for a park? Will children be forced to play in parking areas, streets or vacant lots near the converted O lot/business? I worry about schools. Are the districts prepared for the influx of students and traffic that this blanket conversion could allow? Are the roads in O zones ready for school foot traffic, again, do they have sidewalks, crosswalks, etc? I worry about traffic and congestion. One office lot may have a little to a lot of traffic, but adding 30-45 units per acre surely will increase traffic. Is every conversion or new project required consider this or will it be left for the city to figure out after the fact? It seems the proposal only requires traffic considerations for larger projects, but multiple small project could be done at once and have the same effect on traffic and congestion as one large project.

I also wonder how this plays out for office complexes that are composed of multiple parcels sometimes owned by different entities. Can one office building in an existing complex decide to convert to multiunit residential? Complex bylaws likely wouldn’t have provisions for this as it was not previously allowed.

A Neighborhood Consideration:

To understand the effect the proposal may have on neighborhoods, I started first in near my own neighborhood. Here I have selected several parcels to illustrate:
50020034S is a 7.41 acre parcel zoned O at 7080 N. Valentine. This is between Herndon Ave on the south and Tatarian Elementary on the north. 50114201S, 50114207S and 50115201S are vacant O-zoned vacant lots along Beechwood Ave between Brawley and Valentine. They are each between 1-1.5 acres. There are 4 additional O zoned lots with current office buildings along Beechwood as well. (See attachment 1) The 7.41 acre lot alone could add 222-333 housing units. (Blue) Together the vacant O lots along Beechwood could add 139 - 208 housing units. (Blue) The 4 current office lots could be converted doubling this to 278- 416 units. (Purple) All of these lots could turn into a total of 500-749 units.

This is in addition to the 3.65 acres at Fir/Prospect which is already slated to become 82 apartment units pending the outcome of the lawsuit with Huelskamp.

The points of entry to these lots are either from Brawley avenue on the west and from Valentine on the east. (See attachment 2). Beechwood avenue itself is lined with tree islands down the center and is already very narrow with street parking. Valentine/Prospect traffic is directed north to a very small roundabout which directs traffic back south to a narrow two-lane frontage road along Herndon before turning north where traffic is congested by Tatarian Elementary and can also turn left onto Beechwood.

Unlikely most other areas of Fresno, neighborhoods north of Herndon and west of Palm have unreliable east-west connecting roads and instead rely on connectors to funnel traffic down to Herndon.

Brawley is already the main entry point to homes to 275 homes to the north, plus 74 homes, 68 apartments and the office of United Health Care to the west on Beechwood. It is the ONLY entry point to the homes, apartments and business along Beechwood as well as the eastern half of Sierra Skypark.

Valentine/Prospect would be the main point of entry to another 150-200 homes north of Tatarian Elementary (this is only half of the homes north of Tatarian and Orchid Park, the other half of traffic could more easily enter from Marks). Huelskamp’s project on Fir/Prospect will also increase traffic exiting Valentine to Herndon.

Allowing the conversion of O lots between Brawley and Valentine could more than double the number of families living in this area.

Here are my concerns with the conversion of just these lots alone:

Increased traffic.
a. Without the addition of RM-3 multifamily units, traffic is already congested and limited on Beechwood and Valentine due to existing housing and Tatarian elementary school. There are no “main arteries” or collectors through this neighborhood. b. The frontage road of Valentine funnels into south Prospect at the light at Herndon. Traffic waiting at the light to go south on Valentine/Prospect backs up onto the frontage road. The frontage road’s location already cannot handle current residential and school traffic. i. A new road would need to be constructed south of the school and existing home to make Beechwood run through connecting to Fir. (Attachment 1– red line). There is no way the existing roads could accommodate this amount of traffic. Does the current proposal contain guardrails that would require roads to be improved (in this case to move roads completely)? ii. WHO WOULD ENSURE the roads can accommodate increased traffic? WHO WOULD PAY for construction or improvement of new or current roads? c. Increased vehicle and foot traffic to school.
i. Traffic around Tatarian Elementary is already more congested than most schools due to its position off a main artery road, meaning traffic cannot easily enter and exit during drop-off and pick-ups.

Decreased or compromised emergency response time and evacuation a. With the increase in traffic, emergency response time for fire, police, ambulance could be delayed. b. In the case of a natural disaster requiring evacuation— ie a large fire along the river, which could easily spread into the neighborhood— would people be able to evacuate? i. As stated above, there are no main arteries or collectors through this neighborhood, some streets have only one outlet. Allowing conversion of O lots could more than double the amount of families and cars making a disaster unsafe for current residents.

Increased school enrollment.
a. What number of families would be added to this neighborhood? Could Tatarian Elementary accommodate this increased number of students? Could Tatarian Elementary and the neighborhood to the north accommodate the increased amount of traffic? As stated above, converting just these 8 O lots could more than double the current population.

As you can see from the above considerations, there are already multiple issues that arise with changing the zoning ordinance to allow RM-3 multi-family housing on all existing “O” zoned lots. I’ve only had time to look at one neighborhood, but I can imagine that neighborhoods all around Fresno would have some of the same issues as well as other issues of their own. I worry that making a blanket statement to change the zoning could cause unexpected problems and undue stress on existing neighborhoods.

To conclude, I strongly oppose allowing office-to-dwelling conversions or new standalone multi-unit residential developement in the O zoned district. I believe changes to the O zoning would be best made on a case-by-case basis or one neighborhood at a time.

Thank you for your time and service,
Kimberly Sabree
Attachment 1:

Map view of area north of Herndon between Brawley and Valentine/Prospect.

Blue: Vacant Lots currently zoned as O
Purple: Lots currently zoned O with office buildings
Red Line: My proposed route for new road to accommodate existing and future traffic Attachement 2:

Map area north of Herndon between Blythe and Marks.

Yellow: Roads that outlet mainly to Brawley
Green: Roads that outlet mainly to Valentine/Prospect
Note that there are no main arteries or connectors in this area.

Arizona | California | Colorado | Nevada | Washington
50843266/070675.0001
Christopher A. Brown
Director
[email protected]
8080 N Palm Avenue, Third Floor
Fresno, California 93711
PH (559) 446-3222 | FX (559) 432-4590
fennemorelaw.com
January 14, 2024
VIA EMAIL AND CERTIFIED MAIL/ [email protected] Adrienne Asadoorian-Gilbert
City of Fresno
2600 Fresno Street
Fresno, CA 93721
Re: Public Comment on Project Application P24-00794 Development Code Text Amendment and the corresponding Mitigated Negative Declaration.

Dear Ms. Asadoorian-Gilbert:

On behalf of the Northwest Neighbors for Safe Development, we submit this comment letter in opposition to the City Development Code Text Amendment Project Application P24- 00794 and the corresponding Mitigated Negative Declaration, (“Project”).

The Northwest Neighbors for Safe Development oppose this Development Code Text Amendment because it would make certain projects in the City of Fresno ministerial and thereby exempt from CEQA despite the fact that projects of certain sizes as contemplated in the MND having significant unmitigated impacts on the environment and public health.

On November 20, 2024, the City of Fresno (“City”) circulated the Project’s Mitigation Negative Declaration (“MND”) for public comment through submission to the State Clearing House.1 The reasons for the opposition are set forth herein.

The Northwest Neighbors for Safe Development earlier in 2024 opposed Fresno City Council July 25, 2024 Agenda Item ID 24-899: Appeal of Project at 7056 North Prospect Avenue, Development Permit Application No. P21-00989, and CEQA determination under Class 32 Categorical Exemption (“7065 North Prospect Project”). While the City Council denied that 1 Initial Study/Mitigated Negative Declaration (IS/MND) on behalf of the City of Fresno (City) to address the environmental effects of the Development Code Text Amendment Application No. P24-00794 (Project, proposed Project, or Text Amendment) available at Text-Amendment-P24-00794-Public-Review-Draft-ISMND-10w300.pdf January 14, 2024

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Project, this 7056 North Prospect Avenue Project, was to be located on the northeast corner of West Herndon and North Prospect Avenues in Fresno. Under the proposed Development Code Text Amendment (which includes the northeast corner of West Herndon and North Prospect Avenues) projects of similar size to the 7056 North Prospect Project would not be required to undergo any CEQA analysis, despite the fact that Northwest Neighbors for Safe Development submitted substantial evidence to the City that projects of that size at that location would cause significant impacts on the environment and public health.

The City now attempts to avoid CEQA for projects of this size throughout the City by making them ministerial.

Our opposition previously was supported by technical comments provided by air quality and hazards expert James Clark, Ph.D,2and noise expert Derek Watry3 submitted in conjunction with the 7056 North Prospect Project. They are attached here to provide substantial evidence that the Development Code Text Amendment is making projects of a similar size, which cause significant impacts, ministerial and thereby avoiding CEQA. Additionally, the MND lacks proper mitigation to avoid these impacts.

Approval of this Development Code Text would allow the 7056 North Prospect Project to be submitted again without any changes, and the City would be required to approve the project ministerially despite substantial evidence that these types of projects have unmitigated environmental impacts.

Specifically, the Development Code Text does not address potential project construction emissions, which may result in emissions of toxic air contaminants (“TACs”) that would increase health risks to significant levels. Additionally, construction includes noise-generating activities that may result in significant noise impacts on nearby receptors. These impacts are especially severe due to the proximity of residential receptors to certain sites which now would permit ministerial residential development.

As a result, an EIR is the correct form of environmental review for the Project, because the MND failed to: (1) properly analyze certain impacts like TACs and construction noise, in addition to (2) not properly mitigating impacts that are likely to occur given the size of projects which will be ministerial under the Development Code Text Amendment.

Northwest Neighbors for Safe Development respectfully requests that the Planning Commission require the Project to undergo an EIR or recirculate the MND after adding inappropriate levels of mitigation to reduce impact levels to insignificant. 2 Dr. Clark’s technical comments and curriculum vitae are attached hereto as Exhibit A (“Clark Comments”). 3 Mr. Watry’s technical comments and curriculum vitae are attached hereto as Exhibit B (“Watry Comments”).

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I. STANDING AND STATEMENT OF INTEREST
Northwest Neighbors for Safe Development is an unincorporated association of individuals that may be adversely affected by the potential public health and safety hazards, and the environmental and public service impacts of the Project. The coalition includes City of Fresno residents Matt Nutting, Brandon Smittcamp, Kirk Cernigli, J.T. Contrestano, Pat Cornaggia, Rodney J. De Luca, Gary H. Rushing, Peter Nunez, David Scott, Mike Shirinian, Vicki Allen-Westburg, Debbie Nard, Dennis Nard, Rick Martin, along with their families, and other individuals who live and work in the City of Fresno.

Individual members of Northwest Neighbors for Safe Development live, work, recreate, and raise their families in the City of Fresno and surrounding communities. Accordingly, they would be directly affected by the Project’s environmental, health, and safety impacts.

Northwest Neighbors for Safe Development and its members could be aggrieved by the Project allowing ministerial residential development, without proper mitigation of environmental impacts those projects could create.

II. AN EIR IS REQUIRED
CEQA requires that lead agencies analyze any project with potentially significant environmental impacts in an EIR.4 “Its purpose is to inform the public and its responsible officials of the environmental consequences of their decisions before they are made. Thus, the EIR protects not only the environment, but also informed self-government.”5 The EIR has been described as “an environmental ‘alarm bell’ whose purpose it is to alert the public and its responsible officials to environmental changes before they have reached ecological points of no return.”6 CEQA’s purpose and goals must be met through the preparation of an EIR, except in certain limited circumstances.7 CEQA contains a strong presumption in favor of requiring a lead agency to prepare an EIR. This presumption is reflected in the “fair argument” standard. Under that standard, a lead agency “shall” prepare an EIR whenever substantial evidence in the whole record before the agency supports a fair argument that a project may have a significant effect on the environment.8
4 See Pub. Resources Code, § 21000; CEQA Guidelines, § 15002. 5 Citizens of Goleta Valley v. Bd. of Supervisors (1990) 52 Cal.3d 553, 564 (Goletta Valley), internal citations omitted.
6 County of Inyo v. Yorty (1973) 32 Cal.App.3d 795, 810. 7 See Pub. Resources Code, § 21100.
8 Pub. Resources Code, §§ 21080, subd. (d), 21082.2, subd. (d); CEQA Guidelines, §§ 15002, subd. (k)(3), 15064, subds. (f)(1), (h)(1); Laurel Heights Improvement Assn. v. Regents of the Univ. of Cal. (1993) 6 Cal.4th 1112, 1123 (Laurel Heights II); No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.3d January 14, 2024

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In contrast, a mitigated negative declaration may be prepared only when, after preparing an initial study, a lead agency determines that a project may have a significant effect on the environment, but:
(1) revisions in the project plans or proposals made by, or agreed to by, the applicant before the proposed negative declaration and initial study are released for public review would avoid the effects or mitigate the effects to a point where clearly no significant effect on the environment would occur, and (2) there is no substantial evidence in light of the whole record before the public agency that the project, as revised, may have a significant effect on the environment.9
Courts have held that if “no EIR has been prepared for a nonexempt project, but substantial evidence in the record supports a fair argument that the project may result in significant adverse impacts, the proper remedy is to order preparation of an EIR.”10 The fair argument standard creates a “low threshold” favoring environmental review through an EIR rather than through the issuance of a negative declaration.11 An agency’s decision not to require an EIR can be upheld only when there is no credible evidence to the contrary.12 “Substantial evidence” required to support a fair argument is defined as “enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached.”13 According to the CEQA Guidelines, when determining whether an EIR is required, the lead agency is required to apply the principles set forth in Section 15064, subdivision (f):
[I]n marginal cases where it is not clear whether there is substantial evidence that a project may have a significant effect on the environment, the lead agency shall be guided by the following principle: If there is disagreement among expert opinion supported by facts over the significance of an effect on the environment, the 68, 75, 82; Stanislaus Audubon Society, Inc. v. County of Stanislaus (1995) 33 Cal.App.4th 144, 150-151; Quail Botanical Gardens Found., Inc. v. City of Encinitas (1994) 29 Cal.App.4th 1597, 1601-1602 (Quail Botanical). 9 Pub. Resources Code, § 21064.5 (emphasis added).
10 See, e.g., Communities for a Better Environment v. South Coast Air Quality Management Dist. (2010) 48 Cal.4th 310, 319-320.
11 Citizens Action to Serve All Students v. Thornley (1990) 222 Cal.App.3d 748, 754. 12 Sierra Club v. County of Sonoma (1992) 6 Cal.App.4th, 1307, 1318; see also Friends of B Street v. City of Hayward (1980) 106 Cal.App.3d 988, 1002 (Friends of B Street) (“If there was substantial evidence that the proposed project might have a significant environmental impact, evidence to the contrary is not sufficient to support a decision to dispense with preparation of an EIR and adopt a negative declaration, because it could be ‘fairly argued’ that the project might have a significant environmental impact”). 13 CEQA Guidelines, § 15384, subd. (a).

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Lead Agency shall treat the effect as significant and shall prepare an EIR.

Furthermore, CEQA documents, including EIRs and MNDs, must mitigate significant impacts through measures that are “fully enforceable through permit conditions, agreements, or other legally binding instruments.”14 Deferring formulation of mitigation measures to postapproval studies is generally impermissible.15 Mitigation measures adopted after project approval deny the public the opportunity to comment on the project as modified to mitigate impacts.16 If identification of specific mitigation measures is impractical until a later stage in the project, specific performance criteria must be articulated and further approvals must be made contingent upon meeting these performance criteria.17 Courts have held that simply requiring a project applicant to obtain a future report and then comply with the report’s recommendations is insufficient to meet the standard for properly deferred mitigation.18 With respect to this Project, the MND fails to satisfy the basic purposes of CEQA. The MND fails to adequately disclose, investigate, and analyze the Project’s potentially significant impacts, and fails to provide substantial evidence to conclude that impacts will be mitigated to a less than significant level. Because the MND lacks basic information regarding the Project’s potentially significant impacts, the MND’s conclusion that the Project will have a less than significant impact on the environment is unsupported.19 The City failed to gather the relevant data to support its finding of no significant impacts. Moreover, substantial evidence shows that the Project may result in potentially significant impacts. Therefore, a fair argument can be made that the Project may cause significant impacts requiring the preparation of an EIR.

III. THE DEVELOPMENT CODE TEXT AMENDMENT WOULD ALLOW

PROJECTS OF A SIZE THAT MAY CREATE SIGNIFICANT IMPACTS BY

COMPARING THOSE MINISTERIAL PROJECTS AGAINST IDENTIFIED IMPACTS OF THE DENIED 7056 NORTH PROSPECT PROJECT
One primary purpose of the Development Code Text Amendment is to allow ministerial approval regarding certain types of residential developments. For projects of certain sizes, certain expected impacts, etc., such projects can be permitted ministerially. This letter provides substantial evidence that supports a fair argument of significant impacts by comparing characteristics of the 14 CEQA Guidelines, § 15126.4, subd. (a)(2).
15 Sundstrom v. County of Mendocino (1988) 202 Cal.App.3d 296, 308-309; Pub. Resources Code, § 21061.
16 Gentry v. City of Murrieta (1995) 36 Cal.App.4th 1359, 1393; Quail Botanical, supra, 29 Cal.App.4th at p. 1604, fn. 5
17 Id.
18 Id.
19 Pub. Resources Code, § 21064.5.

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denied 7056 North Prospect Project to projects that would now be allowed ministerially under the Development Code Text Amendments.

The 7056 North Prospect Project contained the following characteristics. It was located on approximately 3.7 acres located at 7056 North Prospect Avenue. The applicant proposed to construct an 82-unit multi-family residential development located at the northeast corner of West Herndon and North Prospect Avenues. The project proposed on-site and off-site improvements including, but not limited to, three (3) three-story multifamily residential buildings and one (1) four-story multifamily residential building consisting of 74 two-bedroom/two bathroom dwelling units and eight (8) two-bedroom/one-bathroom dwelling units, one (1) approximately 1,907 square-foot one-story community center building, one (1) swimming pool area, one (1) dog park area, 154 parking spaces (27 single-car garages, 72 covered carport parking spaces, and 55 uncovered parking spaces), and 6 long-term bicycle parking spaces. A Class 1 Trail for bicycle and pedestrian pathway exists along the Herndon Avenue property frontage and would serve the prospective residents. Direct access to the development would only be provided from North Prospect Avenue via a private gated entrance. One (1) emergency vehicle access approach was proposed along West Fir Avenue. Three (3) private pedestrian gates were to be provided along West Fir Avenue and two (2) private pedestrian gates were to be provided along North Prospect Avenue. The property is zoned RM-2/EA/UGM/cz (Residential Multi-Family, Urban Neighborhood/Expressway Overlay/Urban Growth Management/conditions of zoning).

Because site-specific analysis has been performed on the 7056 North Prospect Project, it provides a useful benchmark for potential impact projects that could be submitted under the proposed Development Code Text Amendment.

IV. THERE IS A FAIR ARGUMENT THAT THE PROJECT MAY RESULT IN

SIGNIFICANT IMPACTS THAT REQUIRE THE CITY TO PREPARE AN EIR Under CEQA, a lead agency must prepare an EIR whenever substantial evidence in the whole record before the agency supports a fair argument that a project may have a significant effect on the environment.20 The fair argument standard creates a “low threshold” favoring environmental review through an EIR, rather than through issuance of a negative declaration.21 An agency’s decision not to require an EIR can be upheld only when there is no credible evidence to the contrary.22 Substantial evidence can be provided by technical experts or members 20 Pub. Resources Code, § 21082.2; CEQA Guidelines, § 15064, subds. (f), (h); Laurel Heights II, supra, 6 Cal. 4th at p. 1123; No Oil, Inc. v. City of Los Angeles (1974) 13 Cal. 3d 68, 75, 82; Stanislaus Audubon Society, Inc. v. County of Stanislaus (1995) 33 Cal.App.4th 144, 150-151; Quail Botanical, supra, 29 Cal.App.4th at pp. 1601-1602.
21 Citizens Action to Serve All Students v. Thornley (1990) 222 Cal.App.3d 748, 754. 22 Sierra Club v. County of Sonoma (1992) 6 Cal.App.4th, 1307, 1318; see also Friends of B Street, supra, 106 Cal.App.3d at p. 1002 (“If there was substantial evidence that the proposed project might have a significant environmental impact, evidence to the contrary is not sufficient to support a decision to dispense with preparation of an [environmental impact report] and adopt a negative declaration, January 14, 2024

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of the public.23 “If a lead agency is presented with a fair argument that a project may have a significant effect on the environment, the lead agency shall prepare an EIR even though it may also be presented with other substantial evidence that the project will not have a significant effect.”24
As discussed below, there is a fair argument supported by substantial evidence that the Project may result in significant impacts relating to air quality, noise, and transportation. The City is required to prepare an EIR to evaluate the Project’s impacts and propose mitigation measures to reduce those impacts to a less-than-significant level.

A. There is Substantial Evidence Supporting a Fair Argument that the MND Underestimates and Fails to Properly Mitigate Air Quality Impacts There is substantial evidence supporting a fair argument that the City failed to analyze the health risk impacts of potential project construction and operation on nearby sensitive receptors, which could occur under future projects that would now be ministerial.

1. The MND Threshold for Unit and Floor Counts To Screen Out of Air Quality Analysis Is Far Above the Level Where Smaller Projects have Found Air Quality Impacts
First, the MND notes projects up to the following size will be ministerial, and once they exceed the following sizes the project will be discretionary and be required to perform some environmental review:

If the Project would exceed 224 units for low-rise (1-2 levels), 225 units for mid-rise (3-10 levels), or 340 units for high-rise (10+ levels) apartments, and generate more than 800 average daily oneway trips [ministerial approval is not permitted]. If the project exceeds this threshold but a technical assessment for operational and construction emissions determines the project will be below applicable air district thresholds, then the project can be processed as a zone clearance.25
because it could be ‘fairly argued’ that the project might have a significant environmental impact”). 23 See, e.g., Citizens for Responsible and Open Government v. City of Grand Terrace (2008) 160 Cal.App.4th 1323, 1340 (substantial evidence regarding noise impacts included public comments at hearings that selected air conditioners are very noisy); see also Architectural Heritage Assn. v.

County of Monterey, 122 Cal.App.4th 1095, 1117-1118 (substantial evidence regarding impacts to historic resource included fact-based testimony of qualified speakers at the public hearing); Gabric v.

City of Rancho Palos Verdes (1977) 73 Cal.App.3d 183, 199. 24 CEQA Guidelines, § 15062, subd. (f).
25 MND pg. 54.

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For context, the 7056 North Prospect Project was 88 units at 4 levels. Any project under the above standard could have significantly more units and significantly more floors than the 7056 North Prospect Project without any level of environmental review.

While it is true that more units and floors do not inherently mean environmental impacts at levels that are significant, Dr. Clark presented substantial evidence there will be significant effects on public health in the 7056 North Prospect Project.

The 7056 North Prospect Project would have increased health risks in the surrounding community by contributing TACs such as Diesel Particulate Matter (“DPM”) during construction.26 During the 7056 North Prospect Project’s construction, heavy equipment and diesel trucks would emit DPM. DPM has been linked to a range of serious health problems including an increase in respiratory disease, lung damage, cancer, and premature death.27 The 7056 North Prospect Project’s emissions of DPM would impact numerous sensitive receptors, including residents in residential buildings located within 25 feet of the 7056 North Prospect Project site.28
CEQA requires an analysis of human health impacts. CEQA Guidelines Section 15065(a)(4) provides that the City is required to find a project will have a significant impact on the environment and require an EIR if the environmental effects of a project will cause a substantial adverse effect on human beings.29 The Supreme Court has also explained that CEQA requires the lead agency to disclose the health consequences that result from exposure to a project’s air emissions.30
For development projects like 7056 North Prospect Project, and ministerial ones under the Project, the Office of Environmental Health Hazard Assessment’s (“OEHHA”) risk assessment guidelines recommend a formal health risk analysis (“HRA”) for short-term construction exposures to TACs lasting longer than 2 months and exposures from projects lasting more than 6 months should be evaluated for the duration of the project.31 In an HRA, lead agencies must first quantify the concentration released into the environment at each of the sensitive receptor locations through air dispersion modeling, calculate the dose of each TAC at that location, and quantify the 26 Clark Comments, pg. 5.
27 Clark Comments, pg. 6.
28 Clark Comments, pg. 9.
29 14 CCR § 15065(a)(4); PRC § 21083(b)(3), (d).
30 Sierra Club v. County of Fresno (2018) 6 Cal.5th 502, 516, 523. 31 Office of Environmental Health Hazard Assessment (OEHHA), Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments, February 2015 (OEHHA 2015), Section 8.2.10: Cancer Risk Evaluation of Short Term Projects, pp. 8-17/18; https://oehha.ca.gov/air/crnr/notice adoption air toxics hot spots program guidance manual preparation-health-risk-0
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cancer risk and hazard index for each of the chemicals of concern.32 Following that analysis, then the City can make a determination of the relative significance of the emissions.

The City did not conduct this analysis. Here, the MND concludes that the Project would not result in significant health risk impacts without conducting any of the above analytical steps.

The City fails to disclose or analyze that the actual construction of residential units as described in the Project construction and operation would result in emissions of TACs. For example, the MND’s analysis regarding TACs only focuses on not siting residential units near certain uses33 The City fails to analyze that construction from 4,868 units could, in and of itself, result in TACs from construction.34 Next, the City fails to disclose or analyze the health impacts of exposure to certain concentrations of TACs. Then the City fails to quantify the magnitude of TACs emitted by the Project. Lastly, the City fails to model the concentrations of TACs at sensitive receptors.35 In sum, there is no evidence that the City considered health risks from TACs due to the construction of residential units themselves when determining that the Project’s ministerial developments would not result in significant impacts on air quality and public health.

2. The City’s Significance Standards Rely on the Small Project Analysis Level to Screen Out Projects Based On Size, But The MND Does Not Then Require Projects to Perform Site Specific Analysis Despite the San Joaquin Valley Air Pollution Control District Requiring It for TACs and Sensitive Receptors
The City reasons that because of the scale and scope of the residential units under the Project, if the residential projects qualify under the Small Project Analysis Level (“SPAL”), there would be no contributions to air quality impacts.36 The SPAL specifically notes that the significance standards for dwelling units and trip counts are to quantify significance standards for “criteria pollutant emissions for CEQA purposes.”37 It does not address significance standards for TACs.
32 Id.
33 MND pgs. 58-59.
34 Id.; MND pg. 53.
35 The City’s failure to analyze the magnitude and concentration of the Project’s TACs also conflicts with the OEHHA recommendations for HRAs. The OEHHA guidelines recommend an HRA be prepared for this Project’s construction and operation because its 24-month construction schedule exceeds 2 months, and its operations would last over 6 months.
36 MND, pg. 54.
37 SJVAPCD. (2015). Air Quality Thresholds of Significance-Criteria Pollutants. Accessed on December 27, 2024, https://ww2.valleyair.org/media/m2ecyxiw/1-cms-format-ceqa-air-quality-thresholds-of-significance-criteriapollutants.pdf January 14, 2024

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When reviewing the Guidance for Assessing and Mitigating Air Quality Impacts (“GAMAQI”) put forth by the San Joaquin Valley Air Pollution Control District (“SJVAPCD”).38 This guidance notes that:

When a project falls under the SPAL, the Lead Agency should use the information in the initial study checklist, or whatever format used, to justify a finding of less than significant air quality impacts. The initial study should also verify that no sensitive receptors would be exposed to substantial pollutant concentrations as a result of the project. Project size, as identified in the SPAL, is not a threshold of significance. SPAL is a screening tool. The Lead Agency has the responsibility to identify and avoid potential land use conflicts, such as potential exposure of sensitive receptors to sources of toxic air contaminants, sources of hazardous materials, and potential odors. (emphasis added).39
While the SPAL has since 2015 been adopted as a significance standard for criteria pollutants, it has not been adopted for TACs. The City clearly ignored the guidance’s recommendations on TACs, and therefore, its conclusions are not supported by substantial evidence and do not mitigate the specific adverse impacts identified below. As SJVAPCD notes, just because a project qualifies as a SPAL, does not mean the project will have no environmental impacts. GAMAQI notes that the Lead Agency is responsible for identifying and avoiding potential exposure of TACs to sensitive receptors. Here, the MND analyzes TACs, but only so far as where to site residential units, not whether the construction of those units can create TACs themselves. Therefore, the City failed to analyze health risk impacts from exposure to TACs during the Project’s expected construction of residential units and thus failed to support its finding of a less-than-significant health risk impact.

3. The Project has Potentially Significant Health Risk Impacts from Projects Which Will Now Be Ministerial
Dr. Clark calculated that the 7056 North Prospect Project’s emissions of DPM would exceed applicable significance thresholds for health risks set by the SJVAPCD.

Using OEHHA’s HARP 2 Standalone Risk software, Dr. Clark calculated the cancer risk to the most sensitive population – infants less than 3 years old.40 The maximum risk for exposure during construction is 21.5 in 1,000,000, which is greater than the 20 in 1,000,000 threshold set 38 Id at p. 6.
39 Guidance for Assessing and Mitigating Air Quality Impacts, San Joaquin Valley Air Pollution Control District, p. 86, available at https://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT-GAMAQI.PDF#page=86 40 Clark Comments, pg. 10.

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forth by the SJVAPCD for the maximally exposed individual. Dr. Clark’s modeling even shows which receptors will be subject to these potentially significant impacts.41 As a result of these significant effects, the 7056 North Prospect Project did not qualify for any CEQA exemption, including a Class 32 exemption. Here, the Project would allow projects the same size as the 7056 North Prospect Project and up to 2.5 times larger to not undergo any sitespecific analysis. Thus, it is fair to conclude those projects also could create significant impacts that must be disclosed and mitigated in an EIR.

B. There is Substantial Evidence Supporting a Fair Argument that the MND Underestimates and Fails to Properly Mitigate Noise Impacts

1. The City Lacks Substantial Evidence to Conclude That the Project’s Noise Impacts From Construction are Less Than Significant
The MND states that the Project would result in less-than-significant construction noise impacts, because “[i]t is not anticipated that future residential development would generate substantial temporary or permanent increase in existing ambient noise levels within the Project Area in excess of standards established in the General Plan or FMC, or in other applicable local, state, or federal standards.”42 This is the extent of the City’s analysis regarding construction impacts and the basis for its significance determination. The City fails to provide why it believes 41 Id.
42 MND, pg. 139.

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construction impacts are not anticipated, what assumptions that belief is based upon, or a supporting factual basis for this conclusion.

Courts have held that compliance with noise regulations alone is not substantial evidence of a less-than-significant impact.43 In Oro Fino Gold Mining Corp. v. County of El Dorado (“Oro Fino”),44 a mining company applied for a special use permit for drilling holes to explore for minerals.45 The mining company argued the proposed mitigated negative declaration prohibited noise levels above the applicable county general plan noise standard maximum of 50 dBA and, therefore, there could be no significant noise impact. The court rejected this argument: “we note that conformity with a general plan does not insulate a project from EIR review where it can be fairly argued that the project will generate significant environmental effects.”46 Thus, the court concluded an EIR was required.

In Citizens for Responsible & Open Government v. City of Grand Terrace (“Grand Terrace”),47 the city approved a 120-unit senior housing facility based on a mitigated negative declaration.48 The noise element of the city’s general plan stated exterior noise levels in residential areas should be limited to 65 dB CNEL.49 The initial study concluded the facility's air conditioner units would cause noise impacts, but with mitigating measures the project would operate within the general plan's noise standard. But the court cited Oro Fino for the principle that “‘conformity with a general plan does not insulate a project from EIR review where it can be fairly argued that the project will generate significant environmental effects.’”50 A citizen’s group provided substantial evidence supporting such a fair argument. This evidence included testimony from an individual in the HVAC industry that the type of air conditioning units proposed by the project “sound like airplanes.”51 And at a city council public hearing, community and city council members expressed concern that the air conditioners would be noisy.52 The court considered the testimony about the noise generated by the proposed air conditioners, took into account the mitigation measures, and concluded “there is substantial 43 King & Gardiner Farms, LLC v. Cnty. of Kern (2020) 45 Cal.App.5th 814, 865. 44 (1990) 225 Cal.App.3d 872.
45 Id. at pg. 876; see also Keep our Mountains Quiet v. County of Santa Clara (2015) 236 Cal.App.4th 714; Citizens for Responsible & Open Government v. City of Grand Terrace (2008) 160 Cal.App.4th 1323, 1338; Gentry v. City of Murrieta (1995) 36 Cal.App.4th 1359, 1416 (project’s effects can be significant even if “they are not greater than those deemed acceptable in a general plan”); Environmental Planning & Information Council v. County of El Dorado (1982) 131 Cal.App.3d 350, 354, (“CEQA nowhere calls for evaluation of the impacts of a proposed project on an existing general plan”).
46 Id. at pp. 881–882.
47 (2008) 160 Cal.App.4th 1323.
48 Id. at 1327.
49 Grand Terrace, 160 Cal.App.4th at 1338.
50 Grand Terrace, supra, at pg. 1338.
51 Id. at 1338-1339.
52 Id. at 1338.

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evidence that it can be fairly argued that the Project may have a significant environmental noise impact.”53
Here the City’s conclusions regarding impacts from Construction Noise are not supported by substantial evidence because the City did not perform any analysis to reach said conclusions.

Mr. Watry notes that it is possible for a project to cause significant environmental noise impacts regardless of whether the Fresno Municipal Code makes this type of noise a violation.54 The City merely assumed that compliance with the City’s noise ordinance means it is impossible for there to also be construction noise impacts. This conflation is wrong and violates CEQA.

2. The Project has Potentially Significant Construction Noise Impacts To further demonstrate this, Mr. Watry performed a construction noise analysis for the 7056 North Prospect Project and found that construction noise would exceed the residential noise thresholds of 55 dB from 7:00 p.m. to 10:00 p.m. and 60 dB from 7 a.m. to 7 p.m.55 Mr. Watry recited the City’s noise ordinance which described what noise levels are usually prima facie noise violations:

Any noise or sound exceeding the ambient noise level at the property line of any person offended thereby, or, if a condominium or apartment house, within any adjoining living unit, by more than five decibels shall be deemed to be prima facie evidence of a violation of Section 8-305.56
Mr. Watry used this value combined with a significant buffer of an additional 5 dBA to determine what level of noise impacts could constitute potentially significant noise impacts for the 7056 North Prospect Project.57 Using the Environmental Protection Agency’s values for Residential Construction Noise, Mr. Watry concluded that every phase of construction for the 7056 North Prospect Project would exceed the residential thresholds by at least 10 dBA significance threshold for residential. While every phase of construction will exceed 70 dBA, some will significantly exceed this based on the average EPA Noise Levels for each phase of construction:58
53 Id. at p. 1341.
54 Watry Comments, p. 2.
55 Watry Comments, p. 5.
56 FMC sec. 10-106.
57 Watry Comments, p. 4.
58 Watry Comments, p. 3.

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As such the MND’s conclusions regarding impacts from Construction Noise are not supported by substantial evidence because the City failed to analyze construction noise impacts or present substantial evidence that there will not be potentially significant construction noise impacts.

Presumably, there will be many sites in the Project Area that have similar amounts of sensitive receptors as the 7056 North Prospect Project. This amount of proposed residential development means many current residents will face significant impacts that are not accounted for in this MND.

As a result of these significant effects, the Project’s impacts on Noise are significant and not mitigated. The Project’s significant impacts must be disclosed and mitigated in an EIR.

C. There is Substantial Evidence Supporting a Fair Argument that the MND Underestimates and Fails to Properly Mitigate Transportation Impacts There is substantial evidence supporting a fair argument that the City failed to analyze transportation risk impacts of potential project construction and operation on nearby sensitive receptors, which could occur under future projects that would now be ministerial.

Here, the City also failed to review the Project’s pedestrian and bicycle safety impacts, for Projects of less than 200 units. For instance, given 7056 North Prospect Project’s density and proximity to the Tatarian Elementary School and Orchard Park, many existing neighbors, with eye-witness experience, and the Fresno Unified School District President Susan Wittrup commented on present traffic and pedestrian safety issues that would be exacerbated by the 7056 North Prospect Project.59
These comments were for a development that only envisioned 88 units, far below the City’s now proposed 200-unit threshold which could occur without analyzing these issues. The City provides no basis or analysis on why 200 units is an appropriate threshold for providing no analysis on pedestrian and bicycle safety impacts. As such the City’s conclusions regarding 59 Fresno City Council Agenda for July 25, 2024 Meeting Agenda Item ID 24-899, Exhibit O, pg. 8-9, available at ID 24-899 - Exhibit O - Correspondence Received (legistar.com).

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Transportation impacts are not supported by substantial evidence and do not support the use of an exemption.

V. CONCLUSION
Northwest Neighbors for Safe Development respectfully requests that the Planning Commission require the Project to undergo an EIR or recirculate the MND after adding inappropriate levels of mitigation to reduce impact levels to insignificant.

Sincerely,

FENNEMORE DOWLING AARON
Christopher A. Brown
CBRO/mrh
Attachments
cc: Andrew Janz ([email protected])

EXHIBIT A
X z 2 July 19.2024
Fennemore Law
1111 Broadway, 24,h Floor
Oakland. CA 94607
i
0 10 Atln: Mr. Chris Brown 10J
Subject: Comment Letter on Categorical Exemption For The 7056 North Prospect Avenue Project Categorical Exemption
_________(CE) From The City Of Fresno, California____________ Clark & Associates
Environmental Consulting, Inc.

OFFICE Dear Mr. Brown:
12405 Venice Blvd
Suite 331
Los Angeles, CA 90066
At the request of Fennemore Law (FL), Clark and Associates (Clark) hasreviewed materials related to the February 9, 204 Categorical Exemption (CE) from the City of Fresno (the City) of the above referenced project. The Class 32 CE is proposed for the Project without consideration ofthe substantial air quality impacts that will be placed on the surrounding neighborhood. The project involves the construction of an 82-unit private gated multi-family development immediately adjacent to existing single-family residential neighborhood located east of the Project Site.

PHONE
310-907-6165
FAX
310-398-7626
EMAIL
[email protected]
Clark’sreview ofthe materialsin no way constitutes a validation ofthe conclusions or materials contained within the CE. If we do not comment on a specific item, this does not constitute acceptance of the item.

The project proposes on-site and off-site improvements
including, but not limited to. three (3) three-story multifamily residential buildings and one (1)four-story building multifamily residential building consisting of74 two-bedroom/two bathroom dwelling units and eight (8) two-bedroom/one bathroom dwelling units, one (1) approximately 1,907 square-foot one-story community center building, one (1) swimming pool area, one (1) dog park area, 154 parking spaces (27 single-car garages, 72 covered carport parking spaces, and 55 uncovered parking 1 | Page
spaces), and 6 long-term bicycle parking spaces. Direct access to the development will only be provided from North Prospect Avenue via a private gated entrance. One (1) emergency vehicle access approach is proposed along West Fir Avenue. Three (3) private pedestrian gates will be provided along West Fir Avenue and two (2) private pedestrian gates will be provided along North Prospect Avenue.

Existing Conditions
The Project Site is currently vacant and undeveloped. The proposed project is located within City limits, occurs on a vacant site of approximately 3.7 acres, which is less than the five-acre maximum, and is surrounded by other urban uses. An existing single-family residential neighborhood is located east of the project site. The property to the west is currently vacant and planned and zoned for Employment- Offices uses. The property to the north has been developed with a neighborhood park (Orchid Park). Properties further to the northwest and northeast have been developed with an elementary school (H. Roger Tatarian Elementary School) and single-family residential neighborhoods.
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General Comments:

No attempt has been made to quantify the emissions from the construction and operational phases ofthe Project. The City argues that using the project type, size, and number of vehicle trips, the San Joaquin Valley Air Pollution Control District (SJV-APCD) has prequantified emissions and determined values below which it is reasonable to conclude that a project would not exceed applicable thresholds of significance for criteria pollutants. The goes on to state that according to the Small Project Analysis Level (SPAL) Table 1 Residential, Apartment, Mid- Rise with a size of225 dwelling units and 800 or less average daily one-way trips for all fleet types of800 or less are deemed to be less than significant. Using the ITE Trip Generation Rates 11th Edition, the subject project (82-unit apartments) would generate 461 average daily trips(two-way trips). Thus, it is lessthan the SPAL 800 average daily one-way trip threshold. The project as described will not occur at a scale or scope with potential to contribute substantially or cumulatively to existing or projected air quality violations or impacts. This analysis fails to considerthe impacts from construction activities at the Project Site and the release oftoxic air contaminants(TACs), primarily in the form ofdiesel particulate matter (DPM) from the construction equipment, onto the adjacent homes. The City's failure to analyze forthe health risks associated with the Project ignores the potentially significant impacts which must be analyzed in an environmental impact report (EIR).

Specific Comments:

1. The City Failed To Perform An Air Quality Analysis Of The Project's Construction And Operational Phases.

Using the current version ofthe CalEEMOD (Version 2020.4.0) software I have calculated the unmitigated emissions from the construction phase and operational of the Project. The results are attached as Exhibit A to this letter. Using the data contained in the project description and attached drawings (available from the City's website ). The modeled Project is outlined in the figure below. 3 | P a g e

1.2. Land Use lypes
sandUseSubtype LrtAcreage BulCirvq Area (sg R) LardscapeArea(sg Spebal Landscape PoputalKm Area(aqft)
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fti
AparSne'ilBMkJ 82.0
Riee
Oaeling Unit 3.70 54.263 64.835 262
Parting Lot 40.6 lOCOsgn 063 OCO
Figure 2: Project Description For CalEEMOD Analysis
Using the default settings from CalEEMOD, a Project construction schedule was derived. The schedule included 5 distinct phases ofwork including site preparation, grading, building construction, paving of parking, and application ofarchitectural coatings. Each phase was assumed to be distinct and no overlapping ofemissions was assumed.

5.1. Construction Schedule
hnn- Name Rune lyfie nd IXate l»a»» PerWert Wert Day*per Hhn*e PhaseI)e«np0cn SflePrepareDcn &te Preparation 8/30/2024 9/&2024 SOD 500 S-Mng
Building Construction
Gradng
BuidngConstruction
9/7/2024 9/18/2024 5.00 8.00
9/19/2024 B///202S 600 730
Pavng Pa.ing 8/8/2025 9/2/2025 500 180
Archfcctumi Cooling A/ctutecturai coawig 9/3/2025 D/28/2025 500 180 Figure 3: Default Construction Schedule
The CalEEMOD model allows users to select the types of construction equipment available for each phase, hours ofoperation, along with the emission controls that may be in place. The modeled construction equipment was assumed to be the averaged value ofthe lleet available currently.

The CalEEMOD analysis generates daily and annual emission values oftotal organic gases (TOGs), reactive organic gases (ROGs), oxides ofnitrogen (NOx), carbon dioxide (CO), sulfur dioxide (S02), particulate matter less than ten microns as exhaust (PMioe), particulate matter less than ten microns as dust (PMiod), total PMio, particulate matter less than 2.5 microns as exhaust (PMise), particulate matter less than 2.5 microns as dust (PM2: 5d), total PM2.5, and greenhouse gases. Based on the CalEEMOD analysis, the Project would not exceed the regulatory thresholds for the criteria pollutants listed by SJV-APCD.
4 | P a g e
Operational Emissions
Permitted
Equipment and Equipment and
Activities
Construction
Emissions Non-Permitted
Pollutant/Precursor
Activities
Emissions
(tpy)
Emissions
(tpy) Emissions (tpy)
CO 100 100 100
NOx 10 10 10
ROG 10 10 10
SOx 27 27 27
PM,o 15 15 15
PM2.5 15 15 15
Figure 4: SJV-APCD Significance Thresholds For Pollutants The results ofthe model’s output ofPMioe though was used in the next part ofmy analysisto determine ifthe emissions would exceed the SJV-APCD's risk threshold (a cancer risk of20 in 1,000,000).

2. Diesel Exhaust From Construction Equipment Is Toxic And Must Be Evaluated Quantitatively To Determine The Health Impacts On The Nearest Sensitive Receptor(s) Diesel exhaust, in particular DPM, is classified by the State ofCalifornia as a TAC. TACs, including DPM1, contribute to a host of respiratory impacts and may lead to the development of various cancers. Failing to quantify the carcinogenic and other health risk impacts places the community at risk for unwanted adverse health impacts. Even brief exposures to the TACs could lead to the development of adverse health impacts over the life ofan individual.

Diesel exhaust contains nearly 40 toxic substances, including TACs, and may pose a serious public health risk for residents in the vicinity ofthe Project. TACs are airborne substances that are capable ofcausing short-term (acute) and/or long-term (chronic or carcinogenic, i.e., cancer causing) adverse human health effects (i.e., injury or illness). TACs include both organic and inorganic 1 Because DPM is a TAC. it is a different air pollutant than criteria particulate matter (PM) emissions such as PM 10, PM2.5. and fugitive dust. DPM exposure causes acute health effects that are different from the effects of exposure to PM alone.
5 | P a g e
chemical substances. The current California list of TACs includes approximately 200 compounds, including particulate emissions from diesel-fueled engines.

Diesel exhaust has been linked to a range ofserious health problems including an increase in respiratory disease, lung damage, cancer, and premature death.2'3'4 Fine DPM is deposited deep in the lungs in the smallest airways and can result in increased respiratory symptoms and disease; decreased lung function, particularly in children and individuals with asthma; alterations in lung tissue and respiratory tract defense mechanisms; and premature death.5 Exposure to DPM increases the risk of lung cancer. It also causes non-cancer effects including chronic bronchitis, inflammation of lung tissue, thickening ofthe alveolar walls, immunological allergic reactions, and airway constriction/' DPM is a TAC that is recognized by state and federal agencies as causing severe health risk because it contains toxic materials, unlike PM2.5 and PM10.7
Nearby sensitive receptors would be exposed to TACs released during Project construction and operation, including DPM. The nearest sensitive receptorsto the Project include the single-family residential neighborhood is located east ofthe Project Site, the elementary school to the west ofthe Project Site, and the remaining residences to the southwest and southeast ofthe Project Site.

The City must assess the air quality impacts for all TACs that will be released during the construction and operational phases ofthe project. CARBS defines diesel exhaust as a complex mixture 2 California Air Resources Board. Initial Statement ofReasons for Rulemaking. Proposed Identification ofDiesel Exhaust as a Toxic AirContaminant. StaffReport, June 1998; see also California Air Resources Board. Overview:

Diesel Exhaust & Health. https:/yww2.arb.ca.gov/rcsources/overview-diesel-exhaust-andheahh#:-:text=Dicscl%20Particulate%20Matter%20and%20Hcallh&text=ln%201998%2C%20CARB%20identified%2 0DPM.and%20oiher%20adverse%20health%20efrccts.
l U.S. EPA, Health Assessment Document for Diesel Engine Exhaust, Report EPA/600/8-90/057F, May 2002. ; Environmental Defense Fund. Cleaner Diesel Handbook, Bring Cleaner Fuel and Diesel Retrofits into Your Neighborhood, April 2005: http://www.edf.org/documents/4941_cleanerdieselhandbook.pdf, accessed July 5, 2020. 5 California Air Resources Board, Initial Statement ofReasons for Rulemaking. Proposed Identification ofDiesel Exhaust as a Toxic AirContaminant. StaffReport. June 1998. f' Findings ofthe Scientific Review Panel on The Report on Diesel Exhaust as adopted at the Panel’s April 22, 1998 Meeting.
7 Health & Safety Code § 39655(a) (defining “toxic air contaminant" as air pollutants "which may cause or contribute to an increase in mortality or in serious illness, orwhich may pose a present or potential hazard to human health. A substance that is listed as a hazardous air pollutant pursuant to subsection (b) ofSection 112 ofthe federal act (42 U.S.C.

Sec. 7412 (b)) is a toxic air contaminant.”)
s CARB. 1998. Report to the Air Resources Board on the Proposed Identification ofDiesel Exhaust as a Toxic Air Contaminant. Part A. Public Exposure To. Sources and Emissions of Diesel Exhaust In California. April 22. 1998. Pg A-l.
6 | P a g e
ofinorganic and organic compounds that exists in gaseous, liquid, and solid phases. CARB and U.S.

EPA identify 40 components ofthe exhaust assuspected human carcinogens, including formaldehyde, 1,3-butadicne, and bcnzo[a]pyrcne. The inhalation unit risk factor identified by OEHHA for use in risk assessments is forthe particulate matter(DPM) fraction ofdiesel exhaust and not the vapor phase components identified by CARB and U.S. EPA.

There is notable precedent requiring a quantitative analysis of TACs from diesel exhaust in CEQA documents. Moreover, the absence of this analysis renders the CE’s Air Quality Analysis incomplete. For example, in a 2017 Notice of Preparation ofa CEQA Document For the Los Robles Apartments Project, from the SCAQMD9 noted that:
*in the event that the proposed project generates or attracts vehicular trips, especially heavyduty diesel-fueled vehicles, it is recommended that the lead agency perform a mobile source health risk assessment. Guidance for performing a mobile source health risk assessment (“Health Risk Assessment Guidance for Analyzing Cancer Risk from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis") can be found at: http://www.aqmd.gov/home/regulations/ceqa/airquality-analysishandbook/mobile-source-toxics-analysis. An analysis of all toxic air contaminant impacts due to the use ofequipment potentially generating such air pollutantsshould also be included." This is a common and feasible analysis that is routinely performed for development projects like the 7056 North Prospect Project.

No effort is made in the CE to quantify the potential health impacts from DPM generated by construction activities or operational activitiesfrom the Project on nearby receptors. The City'sfailure to perform such an analysis is clearly a major flaw in the CE and may be placing the nearby residents at risk from the construction and operational phases ofthe Project.

3. Using The Results OfThe CalEEMOD Analysis I Have Constructed An Air Dispersion Model Of The Emissions And Calculated That The Health Risk From DPM Emissions Will Exceed The SJC-APCD’s Risk Significance Threshold Of20 In One Million.

Using the model described above, a total of 123.6 pounds ofDPM were calculated to be emitted from the construction phase ofthe Project. The Project construction phase will last approximately 279 9 SCAQMD. 2017. Comment LetterTo David Sanchez, Senior Planner City ofPasadena from Jillian Wong, Planning and Rules Manager. SCAQMD.
7| Page
work days and would last a total of 1.03 years (workdays plus holidays, plus weekends).

Phase Total Emissions
For Phase
Year Emissions Duration
Ibs/day days lbs
Site Preparation 2024 1.6 5 8
Grading 2024 0.84 8 6.72
Building Construction 2024 0.5 68 34
Building Construction 2025 0.43 162 69.66
Paving
2025 0.29 18 5.22
Architectural Coating
2025 0.03 18 0.54
Total 279 123.6
The construction site is assumed to be approximately 3.7 acres or approximately 1.61 E+05 square feet. Limiting the emissions to an 8-hour period during weekdays, the time weight averaged emission rate for 2024 through 2025 was calculated to be 3.46 x 10 lbs per hour ofoperation per square feet.

AERMOD is an acronym for the American Meteorological Society/Environmental Protection Agency Regulator)' Model Improvement Committee's Dispersion Model. AERMOD contains the necessary algorithms to model air concentrations from a wide range of emission source types, including stack-based pointsources, fugitive area sources, and volume sources. The modeling domain with the Project Site are indicated in the figure below. The green area is the source area of DPM from construction ofthe Project.
8 | Page
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Figure 5: Model Domain And Receptors
Using the 5-year meteorological data from SJV-APCD for the Fresno Airport monitoring station (closest met station to the Project site), limiting the emissionsto an 8-hour period on weekdays, the concentrations at the nearest receptors were calculated and arc summarized below. The results are presented in Exhibit B to this letter.

Table 2: Annual Average DPM Concentrations Modeled For Construction Phase 2018 2019 2020 2021 2022
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1.27E-01 I.09E-0I 1.06E-01 1.21E-01 | I.26E-01
Assuming that emissions will be limited to an eight-hour period during weekdays, it is possible to calculate an averaged emissions over the whole construction site. Using AERMOD, the US EPA’s 9 | P a g e
preferred air dispersion model, it is possible to calculate the concentrations of DPM from the construction area at the closest receptors near the construction site. 4081095
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4080607 A
C
1 4080485
-x.'-
/. ugfm*^
1 69E-02
7 75E-03
3 68E 03

2.82E-03
1 01E-03
1 09E-03
ii. 4080363
r. ’ .*
^_245455^^4
V
r.fc
t _J' *1.1 '•Sic
245211 245333 _-r_7_7- ti>xo9 245821 245943 246065 160 ir.

Figure 6: Model output showing DPM concentrations from 2024 through 2025 Based on the assumptions detailed above, the maximum averaged concentration ofDPM from the construction phase ofthe project is 0.127 ug/nr!. The median value ofthe concentrations modeled at the same location is 0.121 ug/m\
Using the algorithms from OEHHA’s HARP 2 Standalone Risk software, the cancer risk to the most sensitive population, infants less than 3 years old was calculated. The risk for exposure of infants during the 1 years of construction is 21.5 in 1,000,000 using the maximum concentration modeled, much greater than the 20 in 1,000,000 significance threshold outlined by SJV-APCD, resulting in a significant impact. The risk for exposure ofinfants during the 1 years ofconstruction is 10 | P a g e

20.5 in 1,000,000 using the median concentration modeled, much greater than the 20 in 1,000,000 significance threshold outlined by SJV-APCD, resulting in a significant impact.

It is clear from the results above that the unmitigated emissions from the construction phase of the Project represent a significant risk ifthe CE were signed. The City must quantify and disclose these significant impacts in an EIR forthe Project.

Conclusion
The facts identified and referenced in this comment letter lead me to reasonably conclude that the Project could result in significant impacts ifallowed to proceed. The City must prepare an EIR to address these substantial concerns and to address the errors presented in the CE.

Sincerely,
c.

II | Page
Exhibit A
CalEEMOD Analysis
7056 North Prospect Ave Detailed Report, 7/17/2024
7056 North Prospect Ave Detailed Report
Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds

2.2. Construction Emissions by Year, Unmitigated

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

3. Construction Emissions Details

3.1. Site Preparation (2024) - Unmitigated

3.3. Grading (2024) - Unmitigated

3.5. Building Construction (2024) - Unmitigated

3.7. Building Construction (2025) - Unmitigated

3.9. Paving (2025) - Unmitigated
1 / 46
7056 North Prospect Ave Detailed Report, 7/17/2024

3.11. Architectural Coating (2025) - Unmitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated

4.8. Stationary Emissions By Equipment Type
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7056 North Prospect Ave Detailed Report, 7/17/2024

4.8.1. Unmitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
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7056 North Prospect Ave Detailed Report, 7/17/2024

5.6.2. Construction Earthmoving Control Strategies

5.7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.9. Operational Mobile Sources

5.9.1. Unmitigated

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated

5.13. Operational Waste Generation

5.13.1. Unmitigated

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
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7056 North Prospect Ave Detailed Report, 7/17/2024

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

6. Climate Risk Detailed Report

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

6.3. Adjusted Climate Risk Scores

6.4. Climate Risk Reduction Measures
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7056 North Prospect Ave Detailed Report, 7/17/2024

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores

7.2. Healthy Places Index Scores

7.3. Overall Health & Equity Scores

7.4. Health & Equity Measures

7.5. Evaluation Scorecard

7.6. Health & Equity Custom Measures

8. User Changes to Default Data
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7056 North Prospect Ave Detailed Report, 7/17/2024

1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name 7056 North ProspectAve
Construction Start Date 8/1/2024
Operational Year 2025
Lead Agency
Land Use Scale Project/site
Analysis Level for Defaults
Windspeed (m/s)
Precipitation (days)
County

2.70 22.6
Location 36.83816901498409. -119.85291402629232
County Fresno
City Fresno
Air District San Joaquin Valley APCD
Air Basin San Joaquin Valley
TAZ 2425
EDFZ 5
Electric Utility
Gas Utility
App Version
Pacific Gas & Electric Company
Pacific Gas & Electric
2022.1.1.26

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) | Landscape Area (sq | Special Landscape Population Area (sq ft)
Description
ft)
Apartments Mid
Rise

82.0 Dwelling Unit 3.70 54,293 64,835 262
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7056 North Prospect Ave Detailed Report, 7/17/2024
Parking Lot 40.6 lOOOsqft 0.93 0.00

1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx £ S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e Daily.

Summer
(Max)
Unmit. 19.7 19.7 36.0 33.6 0.05 1.60 19.8 21.4 1.47 10.1 11.6 5,404 5,404 0.22 0.05 1.76 5,424 Daily,
Winter
(Max)
Unmit. 1.70 1.44 11.6 15.1 0.02 0.50 0.35 0.85 0.46 0.08 0.54 2,840 2,840 0.12 0.05 0.05 2,858 Average
Daily
(Max)
Unmit. 1.71 1.60 4.99 6.94 0.01 0.20 0.50 0.64 0.19 0.23 0.36 1,300 1,300 0.05 0.02 0.32 1,308 Annual
(Max)
Unmit 0.31 0.29 0.91 1.27 <0.005 0.04 0.09 0.12 0.03 0.04 0.07 215 215 0.01 <0.005 0.05 217 Exceeds
(Annual)
Threshol — 10.0 10.0 100 27.0 15.0 15.0
d
Unmit. No No No No No No
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7056 North Prospect Ave Detailed Report, 7/17/2024

2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Year TOG ROG NOx S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e Daily -
Summer
(Max)
2024 4.42 3.73 36.0 33.6 0.05 1.60 19.8 21.4 1.47 10.1 11.6 5,404 5.404 0.22 0.05 1.76 5,424 2025 19.7 19.7 10.8 15.3 0.02 0.43 0.35 0.78 0.40 0.08 0.48 2,871 2.871 0.11 0.05 1.64 2,891 Daily -
Winter
(Max)
2024 1.70 1.44 11.6 15.1 0.02 0.50 0.35 0.85 0.46 0.08 0.54 2,840 2,840 0.12 0.05 0.05 2,858 2025 1.60 1.35 10.8 14.9 0.02 0.43 0.35 0.78 0.40 0.08 0.48 2,831 2,831 0.11 0.05 0.04 2,849 Average —
Daily
2024 0.46 0.39 3.25 3.97 0.01 0.14 0.50 0.64 0.13 0.23 0.36 721 721 0.03 0.01 0.16 725 2025 1.71 1.60 4.99 6.94 0.01 0.20 0.16 0.36 0.19 0.04 0.22 1,300 1.300 0.05 0.02 0.32 1,308 Annual
2024 0.08 0.07 0.59 0.72 < 0.005 0.03 0.09 0.12 0.02 0.04 0.07 119 119 0.01 < 0.005 0.03 120 2025 0.31 0.29 0.91 1.27 <0.005 0.04 0.03 0.07 0.03 0.01 0.04 215 215 0.01 < 0.005 0.05 217

2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e Daily.

Summer
(Max)
Unmit. 7.81 5.53 2.88 34.8 0.09 2.76 1.91 4.67 2.66 0.48 3.14 485 4,249 4,733 6.23 0.15 9.40 4,943 Daily.

Winter
(Max)
9/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Unmil. 7.16 4.89 3.03 29.0 0.09 2.76 1.91 4.67 2.66 0.48 3.14 485 4,033 4,518 6.25 0.16 0.62 4,722 Average —
Daily
(Max)
Unmit. 4.06 3.44 2.13 16.1 0.04 0.67 1.79 2.46 0.64 0.45 1.10 139 3,313 3.452 4.60 0.15 4.09 3,615 Annual
(Max)
Unmit. 0.74 0.63 0.39 2.93 0.01 0.12 0.33 0.45 0.12 0.08 0.20 23.0 549 572 0.76 0.02 0.68 598 Exceeds —
(Annual)
Threshol — 10.0 10.0 100 27.0 15.0 15.0
Unmit No No No No No No

2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Sector TOG ROG NOx S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e Daily,
Summer
(Max)
Mobile 1.84 1.74 1.34 11.1 0.02 0.02 1.91 1.93 0.02 0.48 0.50 2,458 2,458 0.12 0.13 9.01 2,507 Area 5.90 3.76 1.03 23.4 0.06 2.70 2.70 2.60 2.60 446 876 1,321 2.10 < 0.005 1,374 Energy 0.06 0.03 0.52 0.22 < 0.005 0.04 0.04 0.04 0.04 906 906 0.10 0.01 911 Water 6.33 8.74 15.1 0.65 0.02 36.0
Waste 32.6 0.00 32.6 3.26 0.00 114
Refrig. 0.39 0.39
Total 7.81 5.53 2.88 34.8 0.09 2.76 1.91 4.67 2.66 0.48 3.14 485 4,249 4.733 6.23 0.15 9.40 4,943 Daily,
Winter
(Max)
Mobile 1.64 1.52 1.53 9.95 0.02 0.02 1.91 1.93 0.02 0.48 0.50 2,255 2,255 0.14 0.14 0.23 2,299 10/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Area 5.46 3.34 0.98 18.8 0.06 2.70 2.70 2.60 2.60 446 863 1,309 2.10 <0.005 1,362 Energy 0.06 0.03 0.52 0.22 < 0.005 0.04 0.04 0.04 0.04 906 906 0.10 0.01 911 Water 6.33 8.74 15.1 0.65 0.02 36.0
Waste 32.6 0.00 32.6 3.26 0.00 114
Refrig. 0.39 0.39
Total 7.16 4.89 3.03 29.0 0.09 2.76 1.91 4.67 2.66 0.48 3.14 485 4,033 4,518 6.25 0.16 0.62 4,722 Average —
Daily
Mobile 1.58 1.48 1.36 9.32 0.02 0.02 1.79 1.81 0.02 0.45 0.47 2,198 2,198 0.12 0.12 3.70 2.241 Area 2.42 1.93 0.24 6.51 0.01 0.61 0.61 0.58 0.58 100 200 300 0.47 < 0.005 312 Energy 0.06 0.03 0.52 0.22 < 0.005 0.04 0.04 0.04 0.04 906 906 0.10 0.01 911 Water 6.33 8.74 15.1 0.65 0.02 36.0
Waste 32.6 0.00 32.6 3.26 0.00 114
Refrig. 0.39 0.39
Total 4.06 3.44 2.13 16.1 0.04 0.67 1.79 2.46 0.64 0.45 1.10 139 3,313 3,452 4.60 0.15 4.09 3,615 Annual
Mobile 0.29 0.27 0.25 1.70 <0.005 <0.005 0.33 0.33 <0.005 0.08 0.09 364 364 0.02 0.02 0.61 371 Area 0.44 0.35 0.04 1.19 <0.005 0.11 0.11 0.11 0.11 16.6 33.1 49.7 0.08 <0.005 51.7 Energy 0.01 0.01 0.10 0.04 <0.005 0.01 0.01 0.01 0.01 150 150 0.02 <0.005 151 Water 1.05 1.45 2.50 0.11 <0.005 5.96
Waste 5.40 0.00 5.40 0.54 0.00 18.9
Refrig. 0.06 0.06
Total 0.74 0.63 0.39 2.93 0.01 0.12 0.33 0.45 0.12 0.08 0.20 23.0 549 572 0.76 0.02 0.68 598

3. Construction Emissions Details

3.1. Site Preparation (2024) - Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) 11/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Location TOG ROG NOx £ S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e Onsite
Daily.

Summer
(Max)
Off-Roa 4.34 3.65 36.0 32.9 0.05 1.60 1.60 1.47 1.47 5,296 5,296 0.21 0.04 5,314 d
Equipm
ent
Dust
From
Material
Movement

19.7 19.7 10.1 10.1
Onsite 0.00
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily.

Winter
(Max)
Average —
Daily
Off-Roa 0.06 0.05 0.49 0.45 < 0.005 0.02 0.02 0.02 0.02 72.5 72.5 < 0.005 < 0.005 72.8 d
Equipm
ent
Dust
From
Material
Movement

0.27 0.27 0.14 0.14
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Off-Roa 0.01 0.01 0.09 0.08 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 12.0 12.0 < 0.005 < 0.005 12.1 d
Equipm
ent
12/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Dust
From
Material
Movement

0.05 0.05 0.03 0.03
Onsite 0.00
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite
Daily,
Summer
(Max)
Worker 0.08 0.08 0.04 0.71 0.00 0.00 0.10 0.10 0.00 0.02 0.02 108 108 0.01 < 0.005 0.43 110 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily.

Winter
(Max)
Average —
Daily
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 1.36 1.36 <0.005 <0.005 <0.005 1.39 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.23 0.23 < 0.005 < 0.005 < 0.005 0.23 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3.3. Grading (2024) - Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG ROG NOx S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e Onsite
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7056 North Prospect Ave Detailed Report, 7/17/2024
Daily,
Summer
(Max)
Off-Roa 2.26 1.90 18.2 18.8 0.03 0.84 0.84 0.77 0.77 2,958 2.958 0.12 0.02 2.969 :1
Equipm
ent
Dust
From
Material
Movement

7.08 7.08 3.42 3.42
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 truck

0.00 0.00 0.00 0.00 0.00 0.00
Daily.

Winter
(Max)
Average —
Daily
Off-Roa 0.05 0.04 0.40 0.41 <0.005 0.02 0.02 0.02 0.02 64.8 64.8 <0.005 <0.005 65.1 J
Equipm
ent
Dust
From
Material
Movement

0.16 0.16 0.08 0.08
Onsite 0.00
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Off-Roa 0.01 0.01 0.07 0.08 <0.005 <0.005 < 0.005 < 0.005 < 0.005 10.7 10.7 <0.005 <0.005 10.8 a
Equipm
ent
Dust
From
Material
Movement

0.03 0.03 0.01 0.01
14/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 truck

0.00 0.00 0.00 0.00 0.00 0.00
Offsite
Daily.

Summer
(Max)
Worker 0.07 0.07 0.04 0.61 0.00 0.00 0.08 0.08 0.00 0.02 0.02 92.9 92.9 0.01 < 0.005 0.37 94.6 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily.

Winter
(Max)
Average —
Daily
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 1.87 1.87 <0.005 <0.005 <0.005 1.90 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.31 0.31 < 0.005 < 0.005 < 0.005 0.32 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3.5. Building Construction (2024) - Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG ROG NOx £ S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e Onsite
Daily.

Summer
(Max)
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7056 North Prospect Ave Detailed Report, 7/17/2024
Off-Roa 1.44 1.20 11.2 13.1 0.02 0.50 0.50 0.46 0.46 2,398 2,398 0.10 0.02 2,406 d
Equipm
enl
Onsite 0.00
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
Off-Roa 1.44 1.20 11.2 13.1 0.02 0.50 0.50 0.46 0.46 2,398 2.398 0.10 0.02 2,406 d
Equipm
ent
Onsite 0.00
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average —
Daily
Off-Roa 0.29 0.24 2.28 2.67 <0.005 0.10 0.10 0.09 0.09 488 488 0.02 < 0.005 490 d
Equipm
ent
Onsite 0.00
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Off-Roa 0.05 0.04 0.42 0.49 <0.005 0.02 0.02 0.02 0.02 80.8 80.8 < 0.005 < 0.005 81.1 d
Equipm
ent
Onsite 0.00
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite
Daily,
Summer
(Max)
Worker 0.29 0.27 0.15 2.40 0.00 0.00 0.32 0.32 0.00 0.08 0.08 366 366 0.02 0.02 1.46 372 Vendor 0.01 0.01 0.19 0.09 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 117 117 < 0.005 0.02 0.30 123 16/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
Worker 0.25 0.23 0.19 1.94 0.00 0.00 0.32 0.32 0.00 0.08 0.08 324 324 0.02 0.02 0.04 329 Vendor 0.01 0.01 0.20 0.09 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 118 118 < 0.005 0.02 0.01 123 Hauling 0.00
Average —
Daily

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Worker 0.05 0.05 0.03 0.40 0.00 0.00 0.06 0.06 0.00 0.02 0.02 68.4 68.4 <0.005 <0.005 0.13 69.6 Vendor <0.005 <0.005 0.04 0.02 <0.005 <0.005 0.01 0.01 <0.005 <0.005 <0.005 23.9 23.9 < 0.005 < 0.005 0.03 25.0 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Worker 0.01 0.01 0.01 0.07 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 11.3 11.3 <0.005 <0.005 0.02 11.5 Vendor <0.005 <0.005 0.01 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 - 3.96 3.96 <0.005 <0.005 <0.005 4.14 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3.7. Building Construction (2025) - Unmitigated
Criteria Po11 utants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG ROG NOx £ S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e Onsite
Daily.

Summer
(Max)
Off-Roa 1.35 1.13 10.4 13.0 0.02 0.43 0.43 0.40 0.40 2,398 2,398 0.10 0.02 2,406 d
Equipm
ent
Onsite 0.00
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 17/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Daily,
Winter
(Max)
Off-Roa 1.35 1.13 10.4 13.0 0.02 0.43 0.43 0.40 0.40 2,398 2.398 0.10 0.02 2,406 :1
Equipm
ent
Onsite 0.00
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average —
Daily
Off-Roa 0.58 0.48 4.48 5.59 0.01 0.19 0.19 0.17 0.17 1,028 1,028 0.04 0.01 1,031 ri
Equipm
ent
Onsite 0.00
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Off-Roa 0.11 0.09 0.82 1.02 <0.005 0.03 0.03 0.03 0.03 170 170 0.01 <0.005 171 a
Equipm
ent
Onsite 0.00
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite
Daily,
Summer
(Max)
Worker 0.27 0.25 0.13 2.20 0.00 0.00 0.32 0.32 0.00 0.08 0.08 358 358 0.01 0.02 1.34 364 Vendor 0.01 0.01 0.19 0.08 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 115 115 < 0.005 0.02 0.30 121 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily.

Winter
(Max)
Worker 0.24 0.22 0.16 1.78 0.00 0.00 0.32 0.32 0.00 0.08 0.08 318 318 0.01 0.02 0.03 323 18/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Vendor 0.01 0.01 0.20 0.09 <0.005 <0.005 0.03 0.03 <0.005 0.01 0.01 116 116 <0.005 0.02 0.01 121 Hauling 0.00
Average —
Daily

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Worker 0.10 0.10 0.06 0.78 0.00 0.00 0.14 0.14 0.00 0.03 0.03 141 141 0.01 0.01 0.25 143 Vendor < 0.005 < 0.005 0.08 0.04 <0.005 <0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 49.5 49.5 <0.005 0.01 0.06 51.7 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Worker 0.02 0.02 0.01 0.14 0.00 0.00 0.02 0.02 0.00 0.01 0.01 23.3 23.3 < 0.005 < 0.005 0.04 23.7 Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 8.19 8.19 <0.005 <0.005 0.01 8.56 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3.9. Paving (2025) - Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG ROG NOx S S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e Onsite
Daily,
Summer
(Max)
Off-Roa 0.85 0.71 6.52 8.84 0.01 0.29 0.29 0.26 0.26 1,351 1,351 0.05 0.01 1,355 d
Equipm
ent
Paving 0.14 0.14
Onsite 0.00
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily.

Winter
(Max)
Average —
Daily
19/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Off-Roa 0.04 0.04 0.32 0.44 <0.005 0.01 0.01 0.01 0.01 66.6 66.6 < 0.005 < 0.005 66.8 d
Paving 0.01 0.01
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Off-Roa 0.01 0.01 0.06 0.08 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 11.0 11.0 < 0.005 < 0.005 11.1 i
Equipm
ent
Paving < 0.005 < 0.005
Onsite 0.00
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite
Daily.

Summer
(Max)
Worker 0.09 0.09 0.05 0.74 0.00 0.00 0.11 0.11 0.00 0.03 0.03 121 121 <0.005 0.01 0.45 123 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
Average —
Daily
Worker <0.005 <0.005 <0.005 0.03 0.00 0.00 0.01 0.01 0.00 <0.005 <0.005 5.50 5.50 < 0.005 < 0.005 0.01 5.59 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Worker <0.005 <0.005 <0.005 0.01 0.00 0.00 <0.005 <0.005 0.00 <0.005 <0.005 0.91 0.91 < 0.005 < 0.005 < 0.005 0.93 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 20/46
7056 North Prospect Ave Detailed Report, 7/17/2024

3.11. Architectural Coating (2025) - Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG ROG NOx S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e Onsite
Daily.

Summer
(Max)
Off-Roa 0.15 0.13 0.88 1.14 < 0.005 0.03 0.03 0.03 0.03 134 134 0.01 < 0.005 134 Equipm
ent
Architect 19.5 19.5
ural
Coating
s
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily.

Winter
(Max)
Average —
Daily
Off-Roa 0.01 0.01 0.04 0.06 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 6.58 6.58 < 0.005 < 0.005 6.61 J
Equipm
ent
Architect 0.96 0.96
ural
Coating
s
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 truck

0.00 0.00 0.00 0.00 0.00 0.00
Annual
21 / 46
7056 North Prospect Ave Detailed Report, 7/17/2024
Off-Roa <0.005 <0.005 0.01 0.01 <0.005 <0.005 < 0.005 < 0.005 < 0.005 1.09 1.09 <0.005 <0.005 1.09 d
Equipm
enl
Architect 0.18 0.18
ural
Coating
s
Onsite 0.00
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite
Daily,
Summer
(Max)
Worker 0.05 0.05 0.03 0.44 0.00 0.00 0.06 0.06 0.00 0.02 0.02 71.6 71.6 < 0.005 < 0.005 0.27 72.8 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily.

Winter
(Max)
Average —
Daily
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 3.25 3.25 < 0.005 < 0.005 0.01 3.30 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.54 0.54 < 0.005 < 0.005 < 0.005 0.55 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

4. Operations Emissions Details
22/46
7056 North Prospect Ave Detailed Report, 7/17/2024

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Land TOG ROG NOx £ S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e Use
Daily,
Summer
(Max)
Apartme 1.84 1.74 1.34 11.1 0.02 0.02 1.91 1.93 0.02 0.48 0.50 2.458 2.458 0.12 0.13 9.01 2,507 nts
Mid Rise
Parking 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Lot
Total 1.84 1.74 1.34 11.1 0.02 0.02 1.91 1.93 0.02 0.48 0.50 2,458 2,458 0.12 0.13 9.01 2,507 Daily,
Winter
(Max)
Apartme 1.64 1.52 1.53 9.95 0.02 0.02 1.91 1.93 0.02 0.48 0.50 2,255 2,255 0.14 0.14 0.23 2,299 nts
Mid Rise
Parking 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Lot
Total 1.64 1.52 1.53 9.95 0.02 0.02 1.91 1.93 0.02 0.48 0.50 2,255 2.255 0.14 0.14 0.23 2,299 Annual
Apartme 0.29 0.27 0.25 1.70 < 0.005 < 0.005 0.33 0.33 < 0.005 0.08 0.09 364 364 0.02 0.02 0.61 371 nts
Mid Rise
Parking 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Lot
Total 0.29 0.27 0.25 1.70 <0.005 <0.005 0.33 0.33 <0.005 0.08 0.09 364 364 0.02 0.02 0.61 371

4.2. Energy
23/46
7056 North Prospect Ave Detailed Report, 7/17/2024

4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Land TOG ROG NOx £ S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e Use
Daily,
Summer
(Max)
Aparlme 225 225 0.04 < 0.005 228
nts
Mid Rise
Parking 19.9 19.9 <0.005 <0.005 20.1
Lot
Total 245 245 0.04 < 0.005 248
Daily,
Winter
(Max)
Apartme 225 225 0.04 < 0.005 228
nts
Mid Rise
Parking 19.9 19.9 <0.005 <0.005 20.1
Lot
Total 245 245 0.04 < 0.005 248
Annual
Apartme 37.3 37.3 0.01 < 0.005 37.7
nts
Mid Rise
Parking 3.29 3.29 < 0.005 < 0.005 3.32
Lot
Total 40.6 40.6 0.01 < 0.005 41.0

4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) 24/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Land TOG ROG NOx £ S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T B0O2 NBC02 C02T CH4 N20 C02e Use
Daily.

Summer
(Max)
Apartme 0.06 0.03 0.52 0.22 <0.005 0.04 0.04 0.04 0.04 661 661 0.06 < 0.005 663 nls
Mid Rise
Parking 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Lot
Total 0.06 0.03 0.52 0.22 < 0.005 0.04 0.04 0.04 0.04 661 661 0.06 < 0.005 663 Daily,
Winter
(Max)
Apartme 0.06 0.03 0.52 0.22 < 0.005 0.04 0.04 0.04 0.04 661 661 0.06 < 0.005 663 nts
Mid Rise
Parking 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Lot
Total 0.06 0.03 0.52 0.22 < 0.005 0.04 0.04 0.04 0.04 661 661 0.06 < 0.005 663 Annual
Apartme 0.01 0.01 0.10 0.04 < 0.005 0.01 0.01 0.01 0.01 109 109 0.01 < 0.005 110 nts
Mid Rise
Parking 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Lot
Total 0.01 0.01 0.10 0.04 <0.005 0.01 0.01 0.01 0.01 109 109 0.01 <0.005 110

4.3. Area Emissions by Source

4.3.1. Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Source TOG ROG NOx £ S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e 25/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Daily,
Summer
(Max)
Hearths 4.20 2.08 0.98 18.8 0.06 2.70 2.70 2.60 2.60 446 863 1.309 2.10 < 0.005 1.362 Consum 1.17 1.17
er
Product
s
Architect 0.10 0.10
ural
Coating
s
Landsca 0.44 0.42 0.05 4.64 <0.005 <0.005 < 0.005 < 0.005 < 0.005 12.4 12.4 <0.005 <0.005 12.5 pe
Equipm
ent
Total 5.90 3.76 1.03 23.4 0.06 2.70 2.70 2.60 2.60 446 876 1,321 2.10 <0.005 1,374 Daily,
Winter
(Max)
Hearths 4.20 2.08 0.98 18.8 0.06 2.70 2.70 2.60 2.60 446 863 1.309 2.10 < 0.005 1,362 Consum 1.17 1.17
er
Product
s
Architect 0.10 0.10
ural
Coating
s
Total 5.46 3.34 0.98 18.8 0.06 2.70 2.70 2.60 2.60 446 863 1,309 2.10 <0.005 1,362 Annual
Hearths 0.17 0.09 0.04 0.77 <0.005 0.11 0.11 0.11 0.11 16.6 32.1 48.7 0.08 <0.005 50.7 Consum 0.21 0.21
er
Product
s
26/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Architect 0.02 0.02
ural
Landsca 0.04 0.04 < 0.005 0.42 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.02 1.02 < 0.005 < 0.005 1.02 pe
Equipm
ent
Total 0.44 0.35 0.04 1.19 <0.005 0.11 0.11 0.11 0.11 16.6 33.1 49.7 0.08 <0.005 51.7

4.4. Water Emissions by Land Use

4.4.1. Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Land TOG ROG NOx a S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e Use
Daily.

Summer
(Max)
Apartme — 6.33 8.74 15.1 0.65 0.02 36.0
nts
Mid Rise
Parking 0.00 0.00 0.00 0.00 0.00 0.00
Lot
Total 6.33 8.74 15.1 0.65 0.02 36.0
Daily,
Winter
(Max)
Apartme — 6.33 8.74 15.1 0.65 0.02 36.0
nts
Mid Rise
Parking 0.00 0.00 0.00 0.00 0.00 0.00
Lot
Total 6.33 8.74 15.1 0.65 0.02 36.0
Annual
27/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Apartme 1.05 1.45 2.50 0.11 <0.005 5.96
nts
Parking 0.00 0.00 0.00 0.00 0.00 0.00
Lot
Total 1.05 1.45 2.50 0.11 < 0.005 5.96

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Land TOG ROG NOx S S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e Use
Daily,
Summer
(Max)
Apartme 32.6 0.00 32.6 3.26 0.00 114
nts
Mid Rise
Parking 0.00 0.00 0.00 0.00 0.00 0.00
Lot
Total 32.6 0.00 32.6 3.26 0.00 114
Daily.

Winter
(Max)
Apartme 32.6 0.00 32.6 3.26 0.00 114
nts
Mid Rise
Parking 0.00 0.00 0.00 0.00 0.00 0.00
Lot
Total 32.6 0.00 32.6 3.26 0.00 114
Annual
Apartme 5.40 0.00 5.40 0.54 0.00 18.9
nts
Mid Rise
28/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Parking 0.00 0.00 0.00 0.00 0.00 0.00
Lot
Total 5.40 0.00 5.40 0.54 0.00 18.9

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Land TOG ROG NOx £ S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e Use
Daily.

Summer
(Max)
Apartme 0.39 0.39
nts
Mid Rise
Total 0.39 0.39
Daily.

Winter
(Max)
Apartme 0.39 0.39
nts
Mid Rise
Total 0.39 0.39
Annual
Apartme 0.06 0.06
nts
Mid Rise
Total 0.06 0.06

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated
29/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Equipm TOG ROG NOx S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e en!
Type
Daily,
Summer
(Max)
Total
Daily.

Winter
(Max)
Total
Annual
Total

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Equipm TOG ROG NOx S S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e ent
Type
Daily.

Summer
(Max)
Total
Daily,
Winter
(Max)
Total
Annual
Total
30/46
7056 North Prospect Ave Detailed Report, 7/17/2024

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) •IK TOG ROG NOx £ S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e Type
Daily,
Summer
(Max)
Total
Daily.

Winter
(Max)
Total
Annual
Total

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Vegetati TOG ROG NOx S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e on
Daily.

Summer
(Max)
Total
Daily,
Winter
(Max)
Total
31 / 46
7056 North Prospect Ave Detailed Report, 7/17/2024
Annual
Total

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Land TOG ROG NOx S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BC02 NBC02 C02T CH4 N20 C02e Use
Daily.

Summer
(Max)
Total
Daily,
Winter
(Max)
Total
Annual
Total

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Species TOG ROG NOx £ S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T B0O2 NBC02 C02T CH4 N20 C02e Daily.

Summer
(Max)
Avoided
Subtotal
Sequest
ered
Subtotal
Remove
d
32/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Subtotal
Daily,
Winter
(Max)
Avoided
Subtotal
Sequest
ered
Subtotal
Remove
Subtotal
Annual
Avoided
Subtotal
Sequest
ered
Subtotal
Remove
J
Subtotal

5. Activity Data

5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Site Preparation Site Preparation 8/30/2024 9/6/2024 5.00 5.00 33/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Grading Grading 9/7/2024 9/18/2024 5.00 8.00
Building Construction Building Construction 9/19/2024 8/7/2025 5.00 230 Paving
Architectural Coating
Paving
Architectural Coating
8/8/2025 9/2/2025 5.00 18.0
9/3/2025 9/28/2025 5.00 18.0

5.2. Off-Road Equipment

5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Site Preparation
Site Preparation
Rubber Tired Dozers Diesel Average
Average

3.00 8.00 367 0.40
Tractors/Loaders/Back Diesel
hoes

4.00 8.00 84.0 0.37
Grading
Grading
Grading
Grading
Excavators Diesel Average
Average
Average
Average

1.00 8.00 36.0 0.38
Graders Diesel 1.00 8.00 148 0.41
Rubber Tired Dozers Diesel 1.00 8.00 367 0.40
Tractors/Loaders/Back Diesel
hoes

3.00 8.00 84.0 0.37
Building Construction Cranes Diesel Average
Average
Average
Average

1.00 7.00 367 0.29
Building Construction Forklifts Diesel 3.00 8.00 82.0 0.20 Building Construction Generator Sets
Building Construction Tractors/Loaders/Back Diesel
hoes
Diesel 1.00 8.00 14.0 0.74

3.00 7.00 84.0 0.37
Building Construction Welders Diesel Average
Average

1.00 8.00 46.0 0.45
Paving Cement and Mortar Diesel
Mixers

2.00 6.00 10.0 0.56
Paving
Paving
Paving
Paving
Pavers Diesel Average
Average
Average
Average

1.00 8.00 81.0 0.42
Paving Equipment Diesel 2.00 6.00 89.0 0.36
Rollers Diesel 2.00 6.00 36.0 0.38
Tractors/Loaders/Back Diesel
hoes

1.00 8.00 84.0 0.37
34/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Site Preparation
Site Preparation
Site Preparation
Site Preparation
Site Preparation
Worker 17.5 7.70 LDA.LDT1.LDT2
Vendor 4.00 HHDTMHDT
Hauling 0.00 20.0 HHDT
Onsite truck HHDT
Grading
Grading
Grading
Grading
Grading
Worker 15.0 7.70 LDA.LDT1.LDT2
Vendor 4.00 HHDTMHDT
Hauling 0.00 20.0 HHDT
Onsite truck HHDT
Building Construction
Building Construction
Building Construction
Building Construction
Building Construction
Worker 59.0 7.70 LDA.LDT1.LDT2
Vendor 8.77 4.00 HHDTMHDT
Hauling 0.00 20.0 HHDT
Onsite truck HHDT
Paving
Paving
Paving
Paving
Paving
Architectural Coating
Architectural Coating
Worker 20.0 7.70 LDA.LDT1.LDT2
Vendor 4.00 HHDTMHDT
Hauling
Onsite truck

0.00 20.0 HHDT
HHDT
Worker 11.8 7.70 LDA.LDT1.LDT2
35/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Architectural Coating
Architectural Coating
Architectural Coating
Vendor 4.00 HHDT.MHDT
Hauling 0.00 20.0 HHDT
Onsite truck HHDT

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.

5.5. Architectural Coatings
Phase Name Residential Interior Area
Coated (sq ft)
Residential ExteriorArea
Coated (sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential ExteriorArea Parking Area Coated (sq ft) Coated (sq ft)
Architectural Coating 109,943 36,648 0.00 0.00 2,436

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (cy) Material Exported (cy) Acres Graded (acres) Material Demolished (sq. ft.) Acres Paved (acres) Site Preparation 7.50 0.00
Grading
Paving

8.00 0.00

0.00 0.00 0.00 0.00 0.93

5.6.2. Construction Earthmoving Control Strategies
Non-applicable. No control strategies activated by user.

5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Apartments Mid Rise
Parking Lot
0%

0.93 100%
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7056 North Prospect Ave Detailed Report, 7/17/2024

5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (Ib/MWh)
Year kWh per Year C02 CH4 N20
2024 0.00 204 0.03 < 0.005
2025 0.00 204 0.03 < 0.005

5.9. Operational Mobile Sources

5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Apartments Mid 446 403 335 154,781 2,699 2,436 2,029 936,388 Rise
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated
Hearth Type Unmitigated (number)
Apartments Mid Rise
Wood Fireplaces j
Gas Fireplaces
Propane Fireplaces
41 0
Electric Fireplaces 0
No Fireplaces 41
Conventional Wood Stoves j
CatalyticWood Stoves 4
37/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Non-Catalytic Wood Stoves 4
Pellet Wood Stoves 0

5.10.2. Architectural Coatings
Residential Interior Area Coated (sq | Residential Exterior Area Coated (sq | Non-Residential Interior Area Coated | Non-Residential Exterior Area Coated (sq ft)
Parking Area Coated (sq ft)
ft) ft) (sq ft)
109943.325 36,648 0.00 0.00 2,436

5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr
day/yr

0.00 Summer Days 180

5.11. Operational Energy Consumption

5.11.1. Unmitigated
Electricity (kWh/yr) and CQ2 and CH4 and N20 and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) C02 CH4 N20 Natural Gas (kBTU/yr) Apartments Mid Rise 403,341 204 0.0330 0.0040 2.062,851 Parking Lot 35,572 204 0.0330 0.0040 0.00

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
Land Use IndoorWater (gal/year) Outdoor Water (gal/year) Apartments Mid Rise
Parking Lot
3,304,272 1,087,782

0.00 0.00
38/46
7056 North Prospect Ave Detailed Report, 7/17/2024

5.13. Operational Waste Generation

5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Apartments Mid Rise
Parking Lot

60.5 0.00

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Apartments Mid Rise Average room A/C &
Other residential A/C
and heat pumps
Apartments Mid Rise Household
refrigerators and/or
freezers
R-410A 2.088 < 0.005 2.50 2.50 10.0
R-134a 1,430 0.12 0.60 0.00 1.00

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor

5.16.2. Process Boilers
39/46
7056 North Prospect Ave Detailed Report, 7/17/2024
EquipmentType Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr)

5.17. User Defined
EquipmentType Fuel Type

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

5.18.2. Sequestration

5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

6. Climate Risk Detailed Report

6.1. Climate Risk Summary
Cal-Adapt midcentury 2040-2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.

Climate Hazard Result for Project Location Unit
40/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Temperature and Extreme Heat
Extreme Precipitation

30.9 annual days of extreme heat
annual days with precipitation above 20 mm
meters of inundation depth

1.35 Sea Level Rise
Wildfire 0.00 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040-2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about V* an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al.. 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events. Users may select from four scenarios to view the range in potential inundation depth forthe grid cell. The four scenarios are: No rise. 0.5 meter, 1.0 meter, 1.41 meters Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040-2059 average under RCP 8.5). and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat
Extreme Precipitation
4 0 0 N/A

N/A N/A N/A N/A
Sea Level Rise N/A N/A N/A N/A
Wildfire N/A N/A N/A N/A
Flooding
Drought
Snowpack Reduction
0 0 0 N/A
0 0 0 N/A

N/A N/A N/A N/A
Air Quality Degradation 0 0 0 N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5. with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.

6.3. Adjusted Climate Risk Scores
41 / 46
7056 North Prospect Ave Detailed Report, 7/17/2024
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 4 1 1 4
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise N/A N/A N/A N/A
Wildfire N/A N/A N/A N/A
Flooding
Drought
Snowpack Reduction
Air Quality Degradation
1 1 1 2
1 1 1 2

N/A N/A N/A N/A
1 1 1 2
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures,

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.

Indicator Result for Project Census Tract
Exposure Indicators
AQ-Ozone 82.5
AQ-PM 94.6
AQ-DPM 19.6
Drinking Water
Lead Risk Housing

96.0 12.2
Pesticides 75.3
Toxic Releases 71.9
42/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Traffic 53.3
Effect Indicators
Cleanup Sites 19.9
Groundwater 2.11
Haz Waste Facilities/Generators 35.6
Impaired Water Bodies 23.9
Solid Waste 0.00
Sensitive Population
Asthma 55.9
Cardio-vascular 23.1
Low Birth Weights 25.4
Socioeconomic Factor Indicators
Education 7.40
Housing
Linguistic

23.4 14.3
Poverty 6.08
Unemployment 7.14

7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

Indicator Result for Project Census Tract
Economic
Above Poverty 85.05068651
Employed 83.80597973
Median HI 87.12947517
Education
Bachelor's or higher 84.97369434
High school enrollment 17.31040678
43/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Preschool enrollment 41.72975747
Transportation
Auto Access 48.06877967
Active commuting 7.596561016
Social
2-parent households
Voting
Neighborhood
Alcohol availability

29.20569742

90.79943539

76.44039523
Park access 18.23431284
Retail density 29.44950597
Supermarket access
Tree canopy
Housing
Homeownership

61.94020275

85.16617477

89.86269729
Housing habitability 81.05992557
Low-inc homeowner severe housing cost burden
Low-inc renter severe housing cost burden
Uncrowded housing

72.02617734

31.52829462

96.93314513
Health Outcomes
Insured adults 93.81496215
Arthritis 2.7
Asthma ER Admissions 53.8
High Blood Pressure
Cancer (excluding skin)

3.1 1.8
Asthma 76.7
Coronary Heart Disease
Chronic Obstructive Pulmonary Disease

6.2 37.6
44/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Diagnosed Diabetes 44.3
Life Expectancy at Birth
Cognitively Disabled
Physically Disabled

20.4 25.4

17.3 Heart Attack ER Admissions 69.8
Mental Health Not Good 91.8
Chronic Kidney Disease 20.1
Obesity 77.3
Pedestrian Injuries 19.6
Physical Health Not Good 71.4
Stroke 26.0
Health Risk Behaviors
Binge Drinking 83.4
Current Smoker 96.7
No Leisure Time for Physical Activity
Climate Change Exposures

76.1 Wildfire Risk 0.0
SLR Inundation Area 0.0
Children 92.2
Elderly
English Speaking

3.1 68.5
Foreign-born 6.6
Outdoor Workers 80.2
Climate Change Adaptive Capacity
Impervious Surface Cover
Traffic Density

75.3 36.4
Traffic Access 0.0
Other Indices
45/46
7056 North Prospect Ave Detailed Report, 7/17/2024
Hardship 7.5
Other Decision Support
2016 Voting 84.2

7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a)
Healthy Places Index Score for Project Location (b)

23.0 75.0
Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

7.4. Health & Equity Measures
No Health & Equity Measures selected.

7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.

7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.

8. User Changes to Default Data
Screen Justification
Land Use From Design Exhibit H
Construction: Construction Phases no demolition required, open field 46/46
Exhibit B
Air Dispersion Model and HRA Spreadsheets
Emissions of DPM During Construction
Phase Year Emissions* Duration Total Emissions
For Phase
Total Hours Emissions Per Day Emission Rate Per Site Wide Hourly Weighted Site Emission Rate Wide Annual
Emission Rate
Averaged Over
Project Duration
Hour
Ibs/day days lbs Ibs/day Ibs-hour Ibs-hr/ft2
Site Preparation 2024 1.6 5 8 40 2.87E-02 2.00E-01 1.24E-06 2.23E-08 Grading 2024 0.84 8 6.72 64 2.41E-02 1.0SE-01 6.53E-07 1.87E-08 Building Construction 2024 0.5 68 34 544 1.22E-01 6.25E-02 3.89E-07 9.48E-08 Building Construction 2025 0.43 162 69.66 1296 2.50E-01 5.38E-02 3.35E-07 1.94E-07 Paving
2025 0.29 18 5.22 144 1.87E-02 3.63E-02 2.26E-07 1.46E-08 Architectural Coating
2025 0.03 18 0.54 144 1.94E-03 3.75E-03 2.33E-08 1.51E-09 Total 279 123.6 2232 0.443010753 2.87E-06 3.46E-07
•* BREEZE AERMOD
** Trinity Consultants
•* VERSION 11.0

CO STARTING

CO TITLEONE

CO TITLETUO

CO MODELOPT

CO RUNORNOT

CO AVERTIME

CO POLLUTID

CO FINISHED
Construction Phase Of 7056 North Prospect Ave Project
DPM Emissions From Off-Road Construction Equipment - Only Weekday Work

DFAULT CONC NODRYDPLT NOWETDPLT
RUN
ANNUAL
DPM

SO STARTING

SO ELEVUNIT

SO LOCATION
** SRCDESCR

SO SRCPARAM

SO AREAVERT

SO EMISFACT

SO SRCGROUP

SO FINISHED
METERS
J00601AS AREAPOLY 245661.2 4080774.5 99.19
7056 Project Site
J00601AS 3.46E-07 4.3 12 2.15
J00601AS 245661.2 4080774.5 245549.4 4080775.9 245542.8 4080768.7 245546.5 4080731.5 300601AS 245549.4 4080725.7 245557.7 4080723.1 245557.7 4080705.7 245554.5 4080701.3 300601AS 245552.6 4080690 245555.9 4080643 245662.6 4080641.2 245661.2 4080774.5 J00601AS HRDOW 00000001111011110000000000
D00601AS HRDOW 00000000000000000000000000
D00601AS HRDOW 00000000000000000000
ALL

RE STARTING

RE ELEVUNIT

RE DISCCART
** RCPDESCR

RE DISCCART
— RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
** RCPDESCR

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** RCPDESCR

RE DISCCART
** RCPDESCR
METERS
245689.9 4080671.2
homes to east
245714.9 4080671.2
homes to east
245739.9 4080671.2
homes to east
245764.9 4080671.2
homes to east
245789.9 4080671.2
homes to east
245814.9 4080671.2
homes to east
245839.9 4080671.2
homes to east
245864.9 4080671.2
homes to east
245689.9 4080696.2
homes to east
245714.9 4080696.2
homes to east
245739.9 4080696.2
homes to east
245764.9 4080696.2
homes to east
245789.9 4080696.2
homes to east
245814.9 4080696.2
homes to east
245839.9 4080696.2
homes to east
245864.9 4080696.2
homes to east
245689.9 4080721.2
homes to east
245714.9 4080721.2
homes to east
245739.9 4080721.2
homes to east
245764.9 4080721.2
homes to east

99.06 99.06

99.14 99.14

99.28 99.28

99.06 99.06

99.1 99.1

99.23 99.23

99.28 99.28

99.36 99.36

99.11 99.11

99.22 99.22

99.36 99.36

RE DISCCART

RCPDESCR

RE DISCCART
** RCPDESCR

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•• RCPDESCR

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** RCPDESCR

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RCPDESCR

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** RCPDESCR

RE DISCCART
245789.9 4080721.2
homes to east
245814.9 4080721.2
homes to east
245839.9 4080721.2
homes to east
245864.9 4080721.2
homes to east
245689.9 4080746.2
homes to east
245714.9 4080746.2
homes to east
245739.9 4080746.2
homes to east
245764.9 4080746.2
homes to east
245789.9 4080746.2
homes to east
245814.9 4080746.2
homes to east
245839.9 4080746.2
homes to east
245864.9 4080746.2
homes to east
245689.9 4080771.2
homes to east
245714.9 4080771.2
homes to east
245739.9 4080771.2
homes to east
245764.9 4080771.2
homes to east
245789.9 4080771.2
homes to east
245814.9 4080771.2
homes to east
245839.9 4080771.2
homes to east
245864.9 4080771.2
homes to east
245764.9 4080796.2
homes to east
245789.9 4080796.2
homes to east
245814.9 4080796.2
homes to east
245839.9 4080796.2
homes to east
245864.9 4080796.2
homes to east
245789.9 4080821.2
homes to east
245814.9 4080821.2
homes to east
245839.9 4080821.2
homes to east
245864.9 4080821.2
homes to east
245814.9 4080846.2
homes to east
245839.9 4080846.2
homes to east
245864.9 4080846.2
homes to east
245685.3 4080822.7
Homes to NE
245710.3 4080822.7
Homes to NE
245735.3 4080822.7

99.36 99.36

99.22 99.22

99.36 99.36

99.43 99.43

99.53 99.53

99.36 99.36

99.36 99.36
•* RCPDESCR

RE DISCCART
** RCPDESCR

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«* RCPDESCR

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** RCPDESCR

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•• RCPDESCR

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*• RCPDESCR
Homes to NE
245685.3 4080847.7
Homes to NE
245710.3 4080847.7
Homes to NE
245735.3 4080847.7
Homes to NE
245760.3 4080847.7
Homes to NE
245685.3 4080872.7
Homes to NE
245710.3 4080872.7
Homes to NE
245735.3 4080872.7
Homes to NE
245760.3 4080872.7
Homes to NE
245785.3 4080872.7
Homes to NE
245810.3 4080872.7
Homes to NE
245835.3 4080872.7
Homes to NE
245860.3 4080872.7
Homes to NE
245685.3 4080897.7
Homes to NE
245710.3 4080897.7
Homes to NE
245735.3 4080897.7
Homes to NE
245760.3 4080897.7
Homes to NE
245785.3 4080897.7
Homes to NE
245810.3 4080897.7
Homes to NE
245835.3 4080897.7
Homes to NE
245860.3 4080897.7
Homes to NE
245685.3 4080922.7
Homes to NE
245710.3 4080922.7
Homes to NE
245735.3 4080922.7
Homes to NE
245760.3 4080922.7
Homes to NE
245785.3 4080922.7
Homes to NE
245810.3 4080922.7
Homes to NE
245835.3 4080922.7
Homes to NE
245860.3 4080922.7
Homes to NE
245685.3 4080947.7
Homes to NE
245710.3 4080947.7
Homes to NE
245735.3 4080947.7
Homes to NE
245760.3 4080947.7
Homes to NE
245785.3 4080947.7
Homes to NE
245810.3 4080947.7
Homes to NE

99.22 99.22

99.36 99.36

99.13 99.13

99.36 99.36

99.44 99.44

99.67 99.67

99.13 99.13

99.36 99.36

99.44 99.44

99.67 99.67

99.12 99.12

99.33 99.33

99.36 99.36

99.44 99.44

99.67 99.67

99.06 99.06

99.08 99.08

99.29 99.29

99.36 99.36

RE DISCCART

RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•“ RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART

RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•“ RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART

RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART

RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•“ RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART

RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•“ RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART

RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
245835.3 4080947.7
Homes to NE
245860.3 4080947.7
Homes to NE
245835.3 4080972.7
Homes to NE
245860.3 4080972.7
Homes to NE
245299.3 4080786.2
elementary school
245324.3 4080786.2
elementary school
245349.3 4080786.2
elementary school
245374.3 4080786.2
elementary school
245399.3 4080786.2
elementary school
245424.3 4080786.2
elementary school
245449.3 4080786.2
elementary school
245474.3 4080786.2
elementary school
245499.3 4080786.2
elementary school
245299.3 4080811.2
elementary school
245324.3 4080811.2
elementary school
245349.3 4080811.2
elementary school
245374.3 4080811.2
elementary school
245399.3 4080811.2
elementary school
245424.3 4080811.2
elementary school
245449.3 4080811.2
elementary school
245474.3 4080811.2
elementary school
245499.3 4080811.2
elementary school
245299.3 4080836.2
elementary school
245324.3 4080836.2
elementary school
245349.3 4080836.2
elementary school
245374.3 4080836.2
elementary school
245399.3 4080836.2
elementary school
245424.3 4080836.2
elementary school
245449.3 4080836.2
elementary school
245474.3 4080836.2
elementary school
245499.3 4080836.2
elementary school
245324.3 4080861.2
elementary school
245349.3 4080861.2
elementary school
245374.3 4080861.2
elementary school
245399.3 4080861.2

99.44 99.44

99.67 99.67

99.38 99.38

99.45 99.45

98.45 98.45

98.61 98.61

98.76 98.76

98.78 98.78

98.9 98.9

98.45 98.45

98.53 98.53

98.67 98.67

98.76 98.76

98.77 98.77

98.45 98.45

98.51 98.51

98.68 98.68

98.76 98.76

98.77 98.77

98.47 98.47

98.48 98.48

98.72 98.72

98.76 98.76
elementary school
245424.3 4080861.2
elementary school
245449.3 4080861.2
elementary school
245474.3 4080861.2
elementary school
245499.3 4080861.2
elementary school
245299.3 4080886.2
elementary school
245324.3 4080886.2
elementary school
245349.3 4080886.2
elementary school
245374.3 4080886.2
elementary school
245399.3 4080886.2
elementary school
245424.3 4080886.2
elementary school
245449.3 4080886.2
elementary school
245474.3 4080886.2
elementary school
245499.3 4080886.2
elementary school
245299.3 4080911.2
elementary school
245324.3 4080911.2
elementary school
245349.3 4080911.2
elementary school
245374.3 4080911.2
elementary school
245399.3 4080911.2
elementary school
245424.3 4080911.2
elementary school
245449.3 4080911.2
elementary school
245474.3 4080911.2
elementary school
245499.3 4080911.2
elementary school
245299.3 4080936.2
elementary school
245324.3 4080936.2
elementary school
245349.3 4080936.2
elementary school
245374.3 4080936.2
elementary school
245399.3 4080936.2
elementary school
245424.3 4080936.2
elementary school
245449.3 4080936.2
elementary school
245474.3 4080936.2
elementary school
245499.3 4080936.2
elementary school
245499.3 4080961.2
elementary school
245564.6 4080447.7
Homes to SE
245589.6 4080447.7
Homes to SE
•* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
«* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
«* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
«* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
*• RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
" RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•" RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
— RCPDESCR

RE DISCCART
’• RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
— RCPDESCR

98.76 98.76

98.72 98.72

98.75 98.75

98.76 98.76

97.54 97.54

RE DISCCART

RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•“ RCPDESCR

RE DISCCART
“ RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART

RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•“ RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART

RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART

RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
245614.6 4080447.7
Homes to SE
245639.6 4080447.7
Homes to SE
245664.6 4080447.7
Homes to SE
245689.6 4080447.7
Homes to SE
245714.6 4080447.7
Homes to SE
245739.6 4080447.7
Homes to SE
245564.6 4080472.7
Homes to SE
245589.6 4080472.7
Homes to SE
245614.6 4080472.7
Homes to SE
245639.6 4080472.7
Homes to SE
245664.6 4080472.7
Homes to SE
245689.6 4080472.7
Homes to SE
245714.6 4080472.7
Homes to SE
245739.6 4080472.7
Homes to SE
245764.6 4080472.7
Homes to SE
245789.6 4080472.7
Homes to SE
245564.6 4080497.7
Homes to SE
245589.6 4080497.7
Homes to SE
245614.6 4080497.7
Homes to SE
245639.6 4080497.7
Homes to SE
245664.6 4080497.7
Homes to SE
245689.6 4080497.7
Homes to SE
245714.6 4080497.7
Homes to SE
245739.6 4080497.7
Homes to SE
245764.6 4080497.7
Homes to SE
245789.6 4080497.7
Homes to SE
245564.6 4080522.7
Homes to SE
245589.6 4080522.7
Homes to SE
245614.6 4080522.7
Homes to SE
245639.6 4080522.7
Homes to SE
245664.6 4080522.7
Homes to SE
245689.6 4080522.7
Homes to SE
245714.6 4080522.7
Homes to SE
245739.6 4080522.7
Homes to SE
245764.6 4080522.7

97.54 97.54

97.55 97.55

97.57 97.57

97.54 97.54

97.69 97.69

97.82 97.82

97.77 97.77

97.94 97.94

98.04 98.04

98.07 98.07

98.07 98.07
•* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
«* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
’• RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
«* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
— RCPDESCR

RE DISCCART
’• RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
— RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
*’• RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
*• RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
«* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
*• RCPDESCR
Homes to SE
245789.6 4080522.7
Homes to SE
245564.6 4080547.7
Homes to SE
245589.6 4080547.7
Homes to SE
245614.6 4080S47.7
Homes to SE
245639.6 4080547.7
Homes to SE
245664.6 4080547.7
Homes to SE
245689.6 4080547.7
Homes to SE
245714.6 4080547.7
Homes to SE
245739.6 4080547.7
Homes to SE
245764.6 4080547.7
Homes to SE
245789.6 4080547.7
Homes to SE
245564.6 4080572.7
Homes to SE
245589.6 4080572.7
Homes to SE
245614.6 4080572.7
Homes to SE
245639.6 4080572.7
Homes to SE
245664.6 4080572.7
Homes to SE
245689.6 4080572.7
Homes to SE
245714.6 4080572.7
Homes to SE
245739.6 4080572.7
Homes to SE
245764.6 4080572.7
Homes to SE
245789.6 4080572.7
Homes to SE
245221.9 4080419.4
homes to SW
245246.9 4080419.4
homes to SW
245271.9 4080419.4
homes to SW
245221.9 4080444.4
homes to SW
245246.9 4080444.4
homes to SW
245271.9 4080444.4
homes to SW
245296.9 4080444.4
homes to SW
245321.9 4080444.4
homes to SW
245221.9 4080469.4
homes to SW
245246.9 4080469.4
homes to SW
245271.9 4080469.4
homes to SW
245296.9 4080469.4
homes to SW
245321.9 4080469.4
homes to SW

98.07 98.07

98.02 98.02

98.24 98.24

98.33 98.33

98.46 98.46

98.41 98.41

98.53 98.53

98.58 98.58

98.71 98.71

97.23 97.23

97.25 97.25

97.31 97.31

97.23 97.23

97.32 97.32

97.53 97.53

RE DISCCART

RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•“ RCPDESCR

RE DISCCART
“ RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART

RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•“ RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART

RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART

RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
245346.9 4080469.4
homes to SW
245371.9 4080469.4
homes to SW
245396.9 4080469.4
homes to SW
245421.9 4080469.4
homes to SW
245221.9 4080494.4
homes to SW
245246.9 4080494.4
homes to SW
245271.9 4080494.4
homes to SW
245296.9 4080494.4
homes to SW
245321.9 4080494.4
homes to SW
245346.9 4080494.4
homes to SW
245371.9 4080494.4
homes to SW
245396.9 4080494.4
homes to SW
245421.9 4080494.4
homes to SW
245446.9 4080494.4
homes to SW
245471.9 4080494.4
homes to SW
245496.9 4080494.4
homes to SW
245521.9 4080494.4
homes to SW
245221.9 4080519.4
homes to SW
245246.9 4080519.4
homes to SW
245271.9 4080519.4
homes to SW
245296.9 4080519.4
homes to SW
245321.9 4080519.4
homes to SW
245346.9 4080519.4
homes to SW
245371.9 4080519.4
homes to SW
245396.9 4080519.4
homes to SW
245421.9 4080519.4
homes to SW
245446.9 4080519.4
homes to SW
245471.9 4080519.4
homes to SW
245496.9 4080519.4
homes to SW
245521.9 4080519.4
homes to SW
245221.9 4080544.4
homes to SW
245246.9 4080544.4
homes to SW
245271.9 4080544.4
homes to SW
245296.9 4080544.4
homes to SW
245321.9 4080544.4

97.54 97.54

97.48 97.48

97.5 97.5

97.54 97.54

97.73 97.73

97.79 97.79

97.67 97.67

97.54 97.54

97.78 97.78

97.84 97.84

97.79 97.79

97.68 97.68

97.54 97.54

97.69 97.69

97.54 97.54

97.55 97.55
homes to SW
245346.9 4080544.4
homes to SW
245371.9 4080544.4
homes to SW
245396.9 4080544.4
homes to SW
245421.9 4080544.4
homes to SW
245446.9 4080544.4
homes to SW
245471.9 4080544.4
homes to SW
245496.9 4080544.4
homes to SW
245521.9 4080544.4
homes to SW
245221.9 4080569.4
homes to SW
245246.9 4080569.4
homes to SW
245271.9 4080569.4
homes to SW
245296.9 4080569.4
homes to SW
245321.9 4080569.4
homes to SW
245346.9 4080569.4
homes to SW
245371.9 4080569.4
homes to SW
245396.9 4080569.4
homes to SW
245421.9 4080569.4
homes to SW
245446.9 4080569.4
homes to SW
245471.9 4080569.4
homes to SW
245496.9 4080569.4
homes to SW
245521.9 4080569.4
homes to SW
•* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
«* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
’• RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
«* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
— RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
•* RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
— RCPDESCR

RE DISCCART
•• RCPDESCR

RE DISCCART
** RCPDESCR

RE DISCCART
«* RCPDESCR

RE DISCCART
** RCPDESCR

RE FINISHED

97.68 97.68

97.81 97.81

97.84 97.84

97.8 97.8

97.69 97.69

97.93 97.93

97.63 97.63

97.66 97.66

97.83 97.83

97.84 97.84

97.9 97.9

97.94 97.94

97.95 97.95

98.03 98.03

98.28 98.28

ME STARTING

ME SURFFILE
•• SURFFILE

ME PROFFILE
** PROFFILE

ME SURFDATA

ME UAIRDATA
ME PR0F8ASE

ME FINISHED
"C:\USERS\3CLAR\ONEDRIVE\CLARKA~1\PRDA0S~1\FRESNO_18-22.SFC" -C:\USERS\3CLAR\ONEDRIVE\CLARKA~1\PRDA05~1\FRESNO_18-22.SFC" MC:\USERS\XLAR\ONEDRIVE\CLARKA~1\PRDA05~1\FRESNO 18-22.PFL“ MC:\USERS\3CLAR\ONEDRIVE\CLARKA*-1\PRDA05-1\FRESNO_18-22.PFL“ 93193 2018
23230 2018
10 METERS

DU STARTING

OU FILEFORM

OU PLOTFILE

OU POSTFILE

OU FINISHED
FIX
ANNUAL ALL ALL*ANNUAL.pit 10000
ANNUAL ALL UNFORM ALL*ANNUAL.bin 10001
*** Message Summary For AERMOD Model Setup ***
Summary of Total Messages
A Total of
A Total of
A Total of
0 Fatal Error Message(s)
4 Warning Message(s)
0 Informational Message(s)
«••••**• FATAL ERROR MESSAGES
*** NONE ***
«***•>«> WARNING MESSAGES •■«***«•
ME W186
ME W187
OU W56S
OU WS6S
606 MEOPEN: THRESH_1MIN 1-min ASOS wind speed threshold used MEOPEN: AD3_U* Option for Stable Low Winds used in AERMET PERPLT: Possible Conflict With Dynamically Allocated FUNIT PERPST: Possible Conflict With Dynamically Allocated FUNIT

9.50 606
610 PLOTFILE
611 POSTFILE
»•#******»»»»*******»»•*********«»»
SETUP Finishes Successfully *** ••*••«••••••*•***••*«••*****•*•*•»• »**
*** AERMOD VERSION 22112 ***
07/17/24
*** AERMET VERSION 21112 ***
16:49:31
*** Construction Phase Of 7056 North Prospect Ave Project *** ««» DPM Emissions From Off-Road Construction Equipment - Only Weekday W *** PAGE 1
MODELOPTs: RegDFAULT CONC ELEV NODRYDPLT NOWETDPLT RURAL ADD_U* *** MODEL SETUP OPTIONS SOWARY •**
** Model Options Selected:
* Model Uses Regulatory DEFAULT Options
* Model Is Setup For Calculation of Average CONCentration Values. * NO GAS DEPOSITION Data Provided.
* NO PARTICLE DEPOSITION Data Provided.
* Model Uses NO DRY DEPLETION. DDPLETE
* Model Uses NO WET DEPLETION. WETDPLT
* Stack-tip Downwash.
* Model Accounts for ELEVated Terrain Effects.
:
:
* Use Calms Processing Routine.
* Use Missing Data Processing Routine.
* No Exponential Decay.
* Model Uses RURAL Dispersion Only.
* ADD U* - Use ADJ_U* option for SBL in AERMET
* CCVR_Sub - Meteorological data includes CCVR substitutions * TEMP_Sub - Meteorological data includes TEMP substitutions * Model Assumes No FLAGPOLE Receptor Heights.
* The User Specified a Pollutant Type of: DPM
"Model Calculates ANNUAL Averages Only
•‘This Run Includes: 1 Source(s); 1 Source Group(s); and 283 Receptor(s) with: 0 POINT(s), including
0 POINTCAP(s) and
0 VOLUME source(s)
1 AREA type source(s)
0 LINE source(s)
0 RLINE/RLINEXT source(s)
0 OPENPIT source(s)
0 BUOYANT LINE source(s) with a total of
0 SWPOINT source(s)
0 POINTHOR(s)
and:
and:
and:
and:
and:
and:
and:
0 line(s)
“Model Set To Continue RUNning After the Setup Testing. “The AERMET Input Meteorological Data Version Date: 21112 '•Output Options Selected:

Model Outputs Tables of ANNUAL Averages by Receptor
Model Outputs External File(s) of Concurrent Values for Postprocessing (POSTFILE Keyword) Model Outputs External File(s) of High Values for Plotting (PLOTFILE Keyword) •'NOTE: The Following Flags May Appear Following CONC Values: c for Calm Hours m for Missing Hours
b for Both Calm and Missing Hours
"Misc. Inputs:

0.0 Base Elev. for Pot. Temp. Profile (m MSL) = 10.00 ; Decay Coef. = 0.000 ; Rot. Angle Emission Units = GRAMS/SEC ; Emission Rate Unit Factor =

0.10000E+07
Output Units = MICROGRAMS/M--3
••Approximate Storage Requirements of Model = 3.5 MB of RAM. “Input Runstream File: aermod.inp
“Output Print File: aermod.out
*** AERMOD VERSION 22112
07/17/24
AERMET VERSION 21112 ***
16:49:31
*** Construction Phase Of 7036 North Prospect Ave Project *»« DPM Emissions From Off-Road Construction Equipment - Only Weekday W ••• ••• PAGE 2
»** MODELOPTs: RegDFAULT CONC ELEV NODRYDPLT NOWETDPLT RURAL ADD_U* *“ AREAPOLY SOURCE DATA “*

NUMBER EMISSION RATE LOCATION OF AREA BASE
PART. (GRAMS/SEC
CATS. /METER**2) (METERS) (METERS) (METERS) (METERS)

RELEASE NUMBER
HEIGHT OF VERTS.

INIT. URBAN EMISSION RATE

SZ SOURCE SCALAR VARY
(METERS)
SOURCE X Y ELEV.

ID BY
J00601AS
♦ •**
0 0.34600E-06 245661.2 4080774.S 99.2
AERMOD - VERSION 22112
07/17/24
AERMET VERSION 21112 *** DPM Emissions From Off-Road Construction Equipment Only Weekday 16:49:31

4.30 Construction Phase Of 7056 North Prospect Ave Project 12 2.IS NO HRDOW *** ***
PAGE 3
“* MODELOPTs: RegDFAULT CONC ELEV NODRYDPLT NOWETDPLT RURAL AD3_U* ••• SOURCE IDs DEFINING SOURCE GROUPS •••
SRCGROUP ID SOURCE IDs
I00601AS
AERMOD VERSION 22112 ***
07/17/24
AERMET VERSION 21112 ***
16:49:31
ALL 1 ♦** Construction Phase Of 7056 North Prospect Ave Project *** *** DPM Emissions From Off-Road Construction Equipment - Only Weekday W *** PAGE 4
“* MODELOPTs: RegDFAULT CONC ELEV NODRYDPLT NOWETDPLT RURAL ADD_U* • SOURCE EMISSION RATE SCALARS WHICH VARY DIURNALLY AND BY DAY OF WEEK (HRDOW) * SOURCE ID ■ J00601AS

HOUR SCALAR HOUR

HOUR SCALAR
; SOURCE TYPE • AREAPOLY :

SCALAR HOUR SCALAR HOUR SCALAR HOUR SCALAR HOUR SCALAR HOUR SCALAR DAY OF WEEK = WEEKDAY
1 .0000E*00
8 .1000E*01
9 .1000E-01
16 .1000E*01
17 .0000E*00
24 .0000E.00
2 .0000E«00 3 .0000E*00 4 .0000E*00 5 .0000E*00 6 .0000E*00 7 .0000E*00 10 .1000E*01 11 .1000E»01 12 .0000E*00 13 .1000E*01 14 .1000E»01 15 .1000E*01 18 .0000E*00 19 .0000E*00 20 .0000E*00 21 .0000E*00 22 .0000E*00 23 .0000E*00 DAY OF WEEK = SATURDAY
1 .0000E+00 3 .0000E*00 4 .0000E+00 5
8 .0000E*00
9 .0000E+00
16 .0000E*00
17 .0000E*00
24 .0000E*00
2 .0000E+00 .0000E+00 6 .0000E*00 7 .0000E+00
10 .0000E+00 11 .0000E*00 12 .0000E+00 13 .0000E+00 14 .0000E*00 15 .0000E+00 18 .0000E+00 19 .0000E*00 20 .0000E*00 21 .0000E*00 22 .0000E*00 23 .0000E*00

DAY OF WEEK - SUNDAY
1 .0000E*00 2 .0000E*00 3 .0000E*00 4 .0000E*00 5
8 .0000E*00
9 .0000E*00 10 .0000E*00
16 .0000E.00
17 .0000E»00 18 .0000E+00
24 .0000E*00
♦ *** AERMOD - VERSION 22112 ”*
07/17/24
AERMET - VERSION 21112 ***
16:49:31
.0000E*00 6 .0000E*00 7 .0000E-00
11 .0000E*00 12 .0000E*00 13 .0000E*00 14 .0000E*00 15 .0000E*00 19 .0000E*00 20 .0000E+00 21 .0000E+00 22 .0000E*00 23 .0000E*00 *** Construction Phase Of 70S6 North Prospect Ave Project »*» ••• DPM Emissions From Off-Road Construction Equipment - Only Weekday W PAGE 5
»** MODELOPTs: RegDFAULT CONC ELEV NODRYDPLT NOWETDPLT RURAL ADJ_U* *** DISCRETE CARTESIAN RECEPTORS ***
(X-COORD, Y-COORD, ZELEV, ZHILL, ZFLAG)
(METERS)
( 24S689.9,

0.0);
( 245739.9,

0.0);
( 245789.9,

0.0);
( 245839.9,

0.0);
( 245689.9,

0.0);
( 245739.9,

0.0);
( 245789.9,

0.0);
( 245839.9,

0.0);
( 245689.9,

0.0);
( 245739.9,

0.0);
( 245789.9,

0.0);
( 245839.9,

0.0);
( 245689.9,

0.0);
( 245739.9,

0.0);
( 245789.9,

0.0);
( 245839.9,

0.0);
( 245689.9,

0.0);
( 245739.9,

0.0);
( 245789.9,
4080671.2, 99.1, 99.1, 0.0) ( 245714.9, 4080671.2, 99.1, 99.1, 4080671.2, 99.1, 99.1, 0.0) ( 245764.9, 4080671.2, 99.1, 99.1, 4080671.2, 99.1, 99.1, 0.0) ( 245814.9, 4080671.2, 99.1, 99.1, 4080671.2, 99.1, 99.1, 0.0) ( 245864.9, 4080671.2, 99.3, 99.3, 4080696.2, 99.1, 99.1, 0.0) ( 245714.9, 4080696.2, 99.1, 99.1, 4080696.2, 99.2, 99.2, 0.0) ( 245764.9, 4080696.2, 99.2, 99.2, 4080696.2, 99.2, 99.2, 0.0) ( 245814.9, 4080696.2, 99.2, 99.2, 4080696.2, 99.3, 99.3, 0.0) ( 245864.9, 4080696.2, 99.4, 99.4, 4080721.2, 99.1, 99.1, 0.0) ( 245714.9, 4080721.2, 99.2, 99.2, 4080721.2, 99.4, 99.4, 0.0) ( 245764.9, 4080721.2, 99.4, 99.4, 4080721.2, 99.4, 99.4, 0.0) ( 245814.9, 4080721.2, 99.4, 99.4, 4080721.2, 99.4, 99.4, 0.0) ( 245864.9, 4080721.2, 99.4, 99.4, 4080746.2, 99.2, 99.2, 0.0) ( 245714.9, 4080746.2, 99.4, 99.4, 4080746.2, 99.4, 99.4, 0.0) ( 245764.9, 4080746.2, 99.4, 99.4, 4080746.2, 99.4, 99.4, 0.0) ( 245814.9, 4080746.2, 99.4, 99.4, 4080746.2, 99.4, 99.4, 0.0) ( 245864.9, 4080746.2, 99.4, 99.4, 4080771.2, 99.4, 99.4, 0.0) ( 245714.9, 4080771.2, 99.4, 99.4, 4080771.2, 99.4, 99.4, 0.0) ( 245764.9, 4080771.2, 99.4, 99.4, 4080771.2, 99.4, 99.4, 0.0) ( 245814.9, 4080771.2, 99.4, 99.4,

0.0);
( 245839.9, 4080771.2,

0.0);
( 245764.9, 4080796.2,
0-0);
( 245814.9, 4080796.2,

0.0);
( 245864.9, 4080796.2,

0.0);
( 245814.9, 4080821.2,

0.0);
( 245864.9, 4080821.2,

0.0);
( 245839.9, 4080846.2,

0.0);
( 245685.3, 4080822.7,

0.0);
( 245735.3, 4080822.7,

0.0);
( 245710.3, 4080847.7,

0.0);
( 245760.3, 4080847.7,

0.0);
( 245710.3, 4080872.7,

0.0);
( 245760.3, 4080872.7,

0.0);
( 245810.3, 4080872.7,

0.0);
( 245860.3, 4080872.7,

0.0);
( 245710.3, 4080897.7,

0.0);
( 245760.3, 4080897.7,

0.0);
( 245810.3, 4080897.7,

0.0);
( 245860.3, 4080897.7,

0.0);
( 245710.3, 4080922.7,

0.0);
( 245760.3, 4080922.7,

0.0);
( 245810.3, 4080922.7,

0.0);
( 245860.3, 4080922.7,

0.0);
( 245710.3, 4080947.7,

0.0);
( 245760.3, 4080947.7,

0.0);
( 245810.3, 4080947.7,

0.0);
♦ **’ AERWD - VERSION 22112 *»*
07/17/24
*** AERMET - VERSION 21112 ***
16:49:31

99.4, 99.4, 0.0) ( 245864.9, 4080771.2, 99.4, 99.4,

99.4, 99.4, 0.0) ( 245789.9, 4080796.2, 99.4, 99.4,

99.4, 99.4, 0.0) ( 245839.9, 4080796.2, 99.4, 99.4,

99.4, 99.4, 0.0) ( 245789.9, 4080821.2, 99.4, 99.4,

99.4, 99.4, 0-0) ( 245839.9, 4080821.2, 99.4, 99.4,

99.4, 99.4, 0.0) ( 245814.9, 4080846.2, 99.4, 99.4,

99.4, 99.4, 0.0) ( 245864.9, 4080846.2, 99.5, 99.5,

99.4, 99.4, 0.0) ( 245710.3, 4080822.7, 99.4, 99.4,

99.4, 99.4, 0.0) ( 245685.3, 4080847.7, 99.2, 99.2,

99.4, 99.4, 0.0) ( 245735.3, 4080847.7, 99.4, 99.4,

99.4, 99.4, 0-0) ( 245685.3, 4080872.7, 99.1, 99.1,

99.4, 99.4, 0.0) ( 245735.3, 4080872.7, 99.4, 99.4,

99.4, 99.4, 0.0) ( 245785.3, 4080872.7, 99.4, 99.4,

99.4, 99.4, 0.0) ( 245835.3, 4080872.7, 99.4, 99.4,

99.7, 99.7, 0.0) ( 245685.3, 4080897.7, 99.1, 99.1,

99.4, 99.4, 0.0) ( 245735.3, 4080897.7, 99.4, 99.4,

99.4, 99.4, 0-0) ( 245785.3, 4080897.7, 99.4, 99.4,

99.4, 99.4, 0.0) ( 245835.3, 4080897.7, 99.4, 99.4,

99.7, 99.7, 0.0) ( 245685.3, 4080922.7, 99.1, 99.1,

99.3, 99.3, 0.0) ( 245735.3, 4080922.7, 99.3, 99.3,

99.4, 99.4, 0.0) ( 245785.3, 4080922.7, 99.4, 99.4,

99.4, 99.4, 0.0) ( 245835.3, 4080922.7, 99.4, 99.4,

99.7, 99.7, 0-0) ( 245685.3, 4080947.7, 99.1, 99.1,

99.1, 99.1, 0.0) ( 245735.3, 4080947.7, 99.1, 99.1,

99.3, 99.3, 0.0) ( 245785.3, 4080947.7, 99.4, 99.4,

99.4, 99.4, 0.0) ( 245835.3, 4080947.7, 99.4, 99.4,
*** Construction Phase Of 7056 North Prospect Ave Project *** *** DPM Emissions From Off-Road Construction Equipment - Only Weekday W *** PAGE 6
•** MODELOPTs: RegDFAULT CONC ELEV NODRYDPLT NONETOPIT RURAL ADD_U* *** DISCRETE CARTESIAN RECEPTORS
(X-COORD, Y-COORD, ZELEV, ZHILL, ZFLAG)
(METERS)
***
( 245860.3, 4080947.7,

0.0);
( 245860.3, 4080972.7,

0.0);

99.7, 99.7, 0.0); ( 245835.3, 4080972.7, 99.4, 99.4,

99.5, 99.5, 0.0); ( 245299.3, 4080786.2, 98.5, 98.5,
( 245324.3,

0.0); ( 245374.3,

0.0); ( 245424.3,

0.0); ( 245474.3,

0.0); ( 245299.3,

0.0); ( 245349.3,

0.0); ( 245399.3,

0.0); ( 245449.3,

0.0); ( 245499.3,

0.0); ( 245324.3,

0.0); ( 245374.3,

0.0); ( 245424.3,

0.0); ( 245474.3,

0.0); ( 245324.3,

0.0); ( 245374.3,

0.0); ( 245424.3,

0.0); ( 245474.3,

0.0); ( 245299.3,

0.0); ( 245349.3,

0.0); ( 245399.3,

0.0); ( 245449.3,

0.0); ( 245499.3,

0.0); ( 245324.3,

0.0); ( 245374.3,

0.0); ( 245424.3,

0.0); ( 245474.3,

0.0); ( 245299.3,

0.0); ( 245349.3,

0.0); ( 245399.3,

0.0); ( 245449.3,

0.0); ( 245499.3,

0.0); ( 245564.6,

0.0); ( 245614.6,

0.0); ( 245664.6,

0.0); ( 245714.6,
4080786.2, 98.5, 98.5, 0.0)( 245349.3, 4080786.2, 98.5, 98.5, 4080786.2, 98.5, 98.5, 0.0)( 245399.3, 4080786.2, 98.5, 98.5, 4080786.2, 98.6, 98.6, 0.0)( 245449.3, 4080786.2, 98.8, 98.8, 4080786.2, 98.8, 98.8, 0.0)( 245499.3, 4080786.2, 98.9, 98.9, 4080811.2, 98.5, 98.5, 0.0)( 245324.3, 4080811.2, 98.5, 98.5, 4080811.2, 98.5, 98.5, 0.0)( 245374.3, 4080811.2, 98.5, 98.5, 4080811.2, 98.5, 98.5, 0.0)( 245424.3, 4080811.2, 98.7, 98.7, 4080811.2, 98.8, 98.8, 0.0)( 245474.3, 4080811.2, 98.8, 98.8, 4080811.2, 98.8, 98.8, 0.0)( 245299.3, 4080836.2, 98.5, 98.5, 4080836.2, 98.5, 98.5, 0.0)( 245349.3, 4080836.2, 98.5, 98.5, 4080836.2, 98.5, 98.5, 0.0)( 245399.3, 4080836.2, 98.7, 98.7, 4080836.2, 98.8, 98.8, 0.0)( 245449.3, 4080836.2, 98.8, 98.8, 4080836.2, 98.8, 98.8, 0.0)( 245499.3, 4080836.2, 98.8, 98.8, 4080861.2, 98.5, 98.5, 0.0)( 245349.3, 4080861.2, 98.5, 98.5, 4080861.2, 98.7, 98.7, 0.0)( 245399.3, 4080861.2, 98.8, 98.8, 4080861.2, 98.8, 98.8, 0.0)( 245449.3, 4080861.2, 98.8, 98.8, 4080861.2, 98.8, 98.8, 0.0)( 245499.3, 4080861.2, 98.8, 98.8, 4080886.2, 98.7, 98.7, 0.0)( 245324.3, 4080886.2, 98.7, 98.7, 4080886.2, 98.7, 98.7, 0.0)( 245374.3, 4080886.2, 98.8, 98.8, 4080886.2, 98.8, 98.8, 0.0)( 245424.3, 4080886.2, 98.8, 98.8, 4080886.2, 98.8, 98.8, 0.0)( 245474.3, 4080886.2, 98.8, 98.8, 4080886.2, 98.8, 98.8, 0.0)( 245299.3, 4080911.2, 98.8, 98.8, 4080911.2, 98.8, 98.8, 0.0)( 245349.3, 4080911.2, 98.8, 98.8, 4080911.2, 98.8, 98.8, 0.0)( 245399.3, 4080911.2, 98.8, 98.8, 4080911.2, 98.8, 98.8, 0.0)( 245449.3, 4080911.2, 98.8, 98.8, 4080911.2, 98.8, 98.8, 0.0)( 245499.3, 4080911.2, 98.8, 98.8, 4080936.2, 98.8, 98.8, 0.0)( 245324.3, 4080936.2, 98.8, 98.8, 4080936.2, 98.8, 98.8, 0.0)( 245374.3, 4080936.2, 98.8, 98.8, 4080936.2, 98.8, 98.8, 0.0)( 245424.3, 4080936.2, 98.8, 98.8, 4080936.2, 98.8, 98.8, 0.0)( 245474.3, 4080936.2, 98.8, 98.8, 4080936.2, 98.8, 98.8, 0.0)( 245499.3, 4080961.2, 98.8, 98.8, 4080447.7, 97.5, 97.5, 0.0)( 245589.6, 4080447.7, 97.5, 97.5, 4080447.7, 97.5, 97.5, 0.0)( 245639.6, 4080447.7, 97.5, 97.5, 4080447.7, 97.5, 97.5, 0.0)( 245689.6, 4080447.7, 97.5, 97.5, 4080447.7, 97.5, 97.5, 0.0)( 245739.6, 4080447.7, 97.5, 97.5,

0.0);
( 245564.6, 4080472.7,

0.0);
( 245614.6, 4080472.7,
0-0);
( 245664.6, 4080472.7,

0.0);
( 245714.6, 4080472.7,

0.0);
( 245764.6, 4080472.7,

0.0);
( 245564.6, 4080497.7,

0.0);
( 245614.6, 4080497.7,

0.0);
( 245664.6, 4080497.7,

0.0);
♦ **’ AERWD - VERSION 22112 *»*
07/17/24
*** AERMET - VERSION 21112 ***
16:49:31

97.5, 97.5, 0.0) ( 245589.6, 4080472.7, 97.5, 97.5,

97.5, 97.5, 0.0) ( 245639.6, 4080472.7, 97.S, 97.5,

97.5, 97.5, 0.0) ( 245689.6, 4080472.7, 97.6, 97.6,

97.6, 97.6, 0.0) ( 245739.6, 4080472.7, 97.6, 97.6,

97.6, 97.6, 0-0) ( 245789.6, 4080472.7, 97.6, 97.6,

97.5, 97.5, 0.0) ( 245589.6, 4080497.7, 97.S, 97.5,

97.5, 97.5, 0.0) ( 245639.6, 4080497.7, 97.5, 97.5,

97.7, 97.7, 0.0) ( 245689.6, 4080497.7, 97.8, 97.8,
*** Construction Phase Of 7056 North Prospect Ave Project *** *** DPM Emissions From Off-Road Construction Equipment - Only Weekday W *** PAGE 7
•** MODELOPTs: RegDFAULT CONC ELEV NODRYDPLT NONETOPIT RURAL ADD_U* *** DISCRETE CARTESIAN RECEPTORS
(X-COORD, Y-COORD, ZELEV, ZHILL, ZFLAG)
(METERS)
***
( 245714.6,

0.0);
( 245764.6,

0.0);
( 245564.6,

0.0);
( 245614.6,

0.0);
( 245664.6,

0.0);
( 245714.6,

0.0);
( 245764.6,

0.0);
( 245564.6,

0.0);
( 245614.6,

0.0);
( 245664.6,

0.0);
( 245714.6,

0.0);
( 245764.6,

0.0);
( 245564.6,

0.0);
( 245614.6,

0.0);
( 245664.6,

0.0);
( 245714.6,

0.0);
( 245764.6,

0.0);
( 245221.9,

0.0);
( 245271.9,

0.0);
( 245246.9,

0.0);
4080497.7, 97.8, 97.8, 0.0) ( 245739.6, 4080497.7, 97.8, 97.8, 4080497.7, 97.8, 97.8, 0.0) ( 245789.6, 4080497.7, 97.8, 97.8, 4080522.7, 97.8, 97.8, 0-0) ( 245589.6, 4080522.7, 97.8, 97.8, 4080522.7, 97.8, 97.8, 0.0) ( 245639.6, 4080522.7, 97.9, 97.9, 4080522.7, 98.0, 98.0, 0.0) ( 245689.6, 4080522.7, 98.1, 98.1, 4080522.7, 98.1, 98.1, 0.0) ( 245739.6, 4080522.7, 98.1, 98.1, 4080522.7, 98.1, 98.1, 0.0) ( 245789.6, 4080522.7, 98.1, 98.1, 4080547.7, 98.0, 98.0, 0.0) ( 245589.6, 4080547.7, 98.0, 98.0, 4080547.7, 98.0, 98.0, 0-0) ( 245639.6, 4080547.7, 98.2, 98.2, 4080547.7, 98.3, 98.3, 0.0) ( 245689.6, 4080547.7, 98.3, 98.3, 4080547.7, 98.3, 98.3, 0.0) ( 245739.6, 4080547.7, 98.3, 98.3, 4080547.7, 98.3, 98.3, 0.0) ( 245789.6, 4080547.7, 98.5, 98.S, 4080572.7, 98.4, 98.4, 0.0) ( 245589.6, 4080572.7, 98.4, 98.4, 4080572.7, 98.4, 98.4, 0.0) ( 245639.6, 4080572.7, 98.5, 98.5, 4080572.7, 98.6, 98.6, 0-0) ( 245689.6, 4080572.7, 98.6, 98.6, 4080572.7, 98.6, 98.6, 0.0) ( 245739.6, 4080572.7, 98.6, 98.6, 4080572.7, 98.6, 98.6, 0.0) ( 245789.6, 4080572.7, 98.7, 98.7, 4080419.4, 97.2, 97.2, 0.0) ( 245246.9, 4080419.4, 97.2, 97.2, 4080419.4, 97.2, 97.2, 0.0) ( 245221.9, 4080444.4, 97.2, 97.2, 4080444.4, 97.2, 97.2, 0.0) ( 245271.9, 4080444.4, 97.2, 97.2, ( 245296.9, 4080444.4,

0.0);
( 245221.9, 4080469.4,

0.0);
( 245271.9, 4080469.4,

0.0);
( 245321.9, 4080469.4,

0.0);
( 245371.9, 4080469.4,

0.0);
( 245421.9, 4080469.4,

0.0);
( 245246.9, 4080494.4,

0.0);
( 245296.9, 4080494.4,

0.0);
( 245346.9, 4080494.4,

0.0);
( 245396.9, 4080494.4,

0.0);
( 245446.9, 4080494.4,

0.0);
[ 245496.9, 4080494.4,

0.0);
( 245221.9, 4080519.4,

0.0);
( 245271.9, 4080519.4,

0.0);
( 245321.9, 4080519.4,

0.0);
( 245371.9, 4080519.4,

0.0);
( 245421.9, 4080519.4,

0.0);
( 245471.9, 4080519.4,

0.0);
( 245521.9, 4080519.4,

0.0);
( 245246.9, 4080544.4,

0.0);
( 245296.9, 4080544.4,

0.0);
( 245346.9, 4080544.4,

0.0);
( 245396.9, 4080544.4,

0.0);
[ 245446.9, 4080544.4,

0.0);
( 245496.9, 4080544.4,

0.0);
♦ *** AERMOD - VERSION 22112 **»
07/17/24
*** AERMET - VERSION 21112 ***
16:49:31

97.2, 97.2, 0.0) ( 245321.9, 4080444.4, 97.3, 97.3,

97.2, 97.2, 0.0) ( 245246.9, 4080469.4, 97.2, 97.2,

97.2, 97.2, 0.0) ( 245296.9, 4080469.4, 97.3, 97.3,

97.5, 97.5, 0.0) ( 245346.9, 4080469.4, 97.5, 97.5,

97.5, 97.5, 0.0) ( 245396.9, 4080469.4, 97.5, 97.5,

97.5, 97.5, 0.0) ( 245221.9, 4080494.4, 97.5, 97.5,

97.5, 97.5, 0.0) ( 245271.9, 4080494.4, 97.5, 97.5,

97.5, 97.5, 0.0) ( 245321.9, 4080494.4, 97.S, 97.5,

97.5, 97.5, 0.0) ( 245371.9, 4080494.4, 97.7, 97.7,

97.8, 97.8, 0.0) ( 245421.9, 4080494.4, 97.7, 97.7,

97.5, 97.5, 0.0) ( 245471.9, 4080494.4, 97.5, 97.5,

97.5, 97.5, 0.0) ( 245521.9, 4080494.4, 97.5, 97.5,

97.5, 97.5, 0.0) ( 245246.9, 4080519.4, 97.5, 97.5,

97.5, 97.5, 0.0) ( 245296.9, 4080519.4, 97.5, 97.5,

97.5, 97.5, 0.0) ( 245346.9, 4080519.4, 97.5, 97.5,

97.8, 97.8, 0.0) ( 245396.9, 4080519.4, 97.8, 97.8,

97.8, 97.8, 0.0) ( 245446.9, 4080519.4, 97.7, 97.7,

97.5, 97.5, 0.0) ( 245496.9, 4080519.4, 97.5, 97.5,

97.7, 97.7, 0.0) ( 245221.9, 4080544.4, 97.5, 97.5,

97.5, 97.5, 0.0) ( 245271.9, 4080544.4, 97.5, 97.5,

97.5, 97.5, 0.0) ( 245321.9, 4080544.4, 97.5, 97.5,

97.7, 97.7, 0.0) ( 245371.9, 4080544.4, 97.8, 97.8,

97.8, 97.8, 0.0) ( 245421.9, 4080544.4, 97.8, 97.8,

97.8, 97.8, 0.0) ( 245471.9, 4080544.4, 97.7, 97.7,

97.7, 97.7, 0.0) ( 245521.9, 4080544.4, 97.9, 97.9,
*** Construction Phase Of 7056 North Prospect Ave Project *** **« DPM Emissions From Off-Road Construction Equipment - Only Weekday W *** PAGE 8
•** MODELOPTs: RegOFAULT CONC ELEV NOORYDPLT NOWETDPLT RURAL ADJ_U* DISCRETE CARTESIAN RECEPTORS ♦**
(X-COORD, Y-COORD, ZELEV, ZHILL, ZFIAG)
(METERS)
*••
( 245221.9, 4080569.4,

0.0);
( 245271.9, 4080569.4,

0.0);
[ 245321.9, 4080569.4,

0.0);
( 245371.9, 4080569.4,

97.6, 97.6, 0.0) ( 245246.9, 4080569.4, 97.6, 97.6,

97.6, 97.6, 0.0) ( 245296.9, 4080569.4, 97.6, 97.6,

97.7, 97.7, 0.0) ( 245346.9, 4080569.4, 97.8, 97.8,

97.8, 97.8, 0.0) ( 245396.9, 4080569.4, 97.9, 97.9,

0.0);
( 245421.9, 4080569.4,

0.0);
( 245471.9, 4080569.4,
0-0);
( 245521.9, 4080569.4,

97.9, 97.9, 0.0); ( 245446.9, 4080569.4, 97.9, 97.9,

98.0, 98.0, 0.0); ( 245496.9, 4080569.4, 98.0, 98.0,

98.3, 98.3, 0.0);
♦ *** AERMOD - VERSION 22112
07/17/24
AERMET - VERSION 21112 ***
16:49:31
*** Construction Phase Of 7056 North Prospect Ave Project *»« DPM Emissions From Off-Road Construction Equipment - Only Weekday W ••• ••• PAGE 9
»** MODELOPTs: RegDFAULT CONC ELEV NODRYDPLT NOWETDPLT RURAL ADD_U* *** METEOROLOGICAL DAYS SELECTED FOR PROCESSING ***
(1-YES; 0-NO)
1111111111 1111111111 111111111 1111111111 11111111
1 1
1111111111 1111111111 111111111 1111111111 11111111
1 1
1111111111 1111111111 111111111 1111111111 11111111
1 1
1111111111 1111111111 111111111 1111111111 11111111
1 1
1111111111 1111111111 111111111 1111111111 11111111
1 1
1111111111 1111111111 111111111 1111111111 11111111
1 1
1111111111 1111111111 111111111 1111111111 11111111
1 1
1111111111 11111
NOTE: METEOROLOGICAL DATA ACTUALLY PROCESSED WILL ALSO DEPEND ON WHAT IS INCLUDED IN THE DATA FILE.
**' UPPER BOUND OF FIRST THROUGH FIFTH WIND SPEED CATEGORIES *** (METERS/SEC)

1.S4, 3.09, S.14, 8.23, 10.80,
♦ *** AERMOD - VERSION 22112 Construction Phase Of 7056 North Prospect Ave Project 07/17/24
AERMET - VERSION 21112 ***
16:49:31
*** *»«
DPM Emissions From Off-Road Construction Equipment - Only Weekday W ••• ••• PAGE 10 »** MODELOPTs: RegDFAULT CONC ELEV NODRYDPLT NOWETDPLT RURAL ADD_U* ’“** UP TO THE FIRST 24 HOURS OF METEOROLOGICAL DATA *** Surface file: C:\USERS\3CLAR\ONEDRIVE\CLARKA~1\PRDA05~1\FRESNO_18-22.SFC Met Version:
21112
Profile file:

Surface format: FREE
C:\USERS\3CLAR\ONEDRIVE\CLARKA-1\PRDA05-1\FRESNO_18-22.PFL Profile format: FREE
Surface station no.: 93193
Name: UNKNOWN
Year: 2018
Upper air station no.: 23230
Name: UNKNOWN
Year: 2018
First 24 hours of scalar data
YR MO DY DDY HR H0 U* W* DT/DZ ZICNV ZIMCH M-0 LEN Z0 BOWEN ALBEDO REF WS WD HT REF TA HT
18 01 01 1 01 -6.0 0.108 -9.000 -9.000 -999. 85. 18.7 0.17 1.06 1.00 1.20 347. 10.0 280.9

2.0 18 01 01 1 02 -2.0 0.062 -9.000 -9.000 -999. 38. 10.9 0.02 1.06 1.00 0.91 174. 10.0 279.2

2.0 18 01 01 1 03 -3.4 0.076 -9.000 -9.000 -999. 50. 11.8 0.03 1.06 1.00 1.20 265. 10.0 279.2

2.0 18 01 01 1 04 -5.1 0.095 -9.000 -9.000 -999. 71. 15.2 0.06 1.06 1.00 1.35 316. 10.0 278.1

2.0 18 01 01 1 05 -8.8 0.123 -9.000 -9.000 -999. 104. 19.1 0.04 1.06 1.00 1.87 96. 10.0 277.0

2.0 18 01 01 1 06 -2.6 0.067 -9.000 -9.000 -999. 43. 10.7 0.02 1.06 1.00 1.08 177. 10.0 277.5

2.0 18 01 01 1 07 -3.7 0.078 -9.000 -9.000 -999. 52. 11.5 0.02 1.06 1.00 1.33 181. 10.0 277.5

2.0 18 01 01 1 08 -15.2 0.167 -9.000 -9.000 -999. 164. 30.7 0.06 1.06 0.65 2.32 76. 10.0 276.4

2.0 18 01 01 1 09 -3.5 0.149 -9.000 -9.000 -999. 139. 86.8 0.04 1.06 0.36 2.15 109. 10.0 278.1

2.0 18 01 01 1 10 56.2 0.204 0.651 0.006 177. 221. -13.6 0.04 1.06 0.26 2.37 134. 10.0 281.4

2.0 18 01 01 1 11 92.0 0.233 1.067 0.016 477. 270. -12.4 0.04 1.06 0.22 2.62 105. 10.0 283.1

2.0 18 01 01 1 12 116.8 0.202 1.234 0.018 581. 219. -6.4 0.04 1.06 0.21 2.11 102. 10.0 285.9

2.0 18 01 01 1 13 112.5 0.144 1.280 0.019 673. 132. -2.4 0.02 1.06 0.21 1.55 183. 10.0 287.5

2.0 18 01 01 1 14 84.0 0.122 1.190 0.019 723. 103. -2.0 0.02 1.06 0.22 1.28 200. 10.0 289.2

2.0 18 01 01 1 15 57.9 0.161 1.059 0.019 738. 155. -6.5 0.03 1.06 0.26 1.81 262. 10.0 290.4

2.0 18 01 01 1 16 16.8 0.124 0.702 0.019 742. 105. -10.3 0.03 1.06 0.35 1.47 259. 10.0 289.9

2.0 18 01 01 1 17 -2.5 0.068 -9.000 -9.000 -999. 44. 11.3 0.02 1.06 0.62 1.14 297. 10.0 287.5

2.0 18 01 01 1 18 -7.4 0.111 -9.000 -9.000 -999. 89. 16.9 0.03 1.06 1.00 1.84 239. 10.0 286.4

2.0 18 01 01 1 19 -4.0 0.085 -9.000 -9.000 -999. 60. 13.8 0.06 1.06 1.00 1.21 83. 10.0 284.9

2.0 18 01 01 1 20 -10.4 0.137 -9.000 -9.000 -999. 122. 22.3 0.06 1.06 1.00 1.93 76. 10.0 283.8

2.0 18 01 01 1 21 -4.7 0.090 -9.000 -9.000 -999. 65. 14.0 0.04 1.06 1.00 1.38 109. 10.0 283.1

2.0 18 01 01 1 22 -4.1 0.084 -9.000 -9.000 -999. 58. 13.0 0.04 1.06 1.00 1.30 127. 10.0 281.4

2.0 18 01 01 1 23 -11.7 0.145 -9.000 -9.000 -999. 133. 23.6 0.06 1.06 1.00 2.04 70. 10.0 280.9

2.0 18 01 01 1 24 -3.4 0.079 -9.000 -9.000 -999. 54. 13.0 0.06 1.06 1.00 1.09 80. 10.0 281.4

2.0 First
YR MO
18 01
hour of profile data

DY HR HEIGHT F WDIR
01 01
WSPD AMB_TMP sigmaA

1.20 281.0 99.0
sigmaW sigmaV

10.0 1 347. -99.00 -99.00
F indicates top of profile (=1) or below (-0)
♦ *** AERMOD
07/17/24
AERMET - VERSION 21112 ***
16:49:31
VERSION 22112 *** Construction Phase Of 7056 North Prospect Ave Project *»« DPM Emissions From Off-Road Construction Equipment - Only Weekday W ••• ••• PAGE 11 »** MODELOPTs: RegDFAULT CONC ELEV NODRYDPLT NOWETDPLT RURAL ADD_U* THE ANNUAL AVERAGE CONCENTRATION VALUES AVERAGED OVER 5 YEARS FOR SOURCE GROUP: ALL *•* INCLUDING SOURCE(S): 300601AS 1
*** DISCRETE CARTESIAN RECEPTOR POINTS ***
IN MICROGRAMS/M**3 *» CONC OF DPM *«

X-COORD (M) Y-COORD (M) CONC X-COORD (M) Y-COORD (M) CONC 245689.99 4080671.20 0.11757 245714.90 4080671.20 0.07252 245739.90 4080671.20 0.04710 245764.90 4080671.20 0.03210 245789.90 4080671.20 0.02278 245814.90 4080671.20 0.01672 245839.90 4080671.20 0.01264 245864.90 4080671.20 0.00980 245689.90 4080696.20 0.11503 245714.90 4080696.20 0.06783 245739.90 4080696.20 0.04241 245764.90 4080696.20 0.02819 245789.90 4080696.20 0.01974 245814.90 4080696.20 0.01443 245839.90 4080696.20 0.01092 245864.90 4080696.20 0.00851 245689.90 4080721.20 0.10227 245714.90 4080721.20 0.05707 245739.90 4080721.20 0.03465 245764.90 4080721.20 0.02286 245789.90 4080721.20 0.01609 245814.90 4080721.20 0.01190 245839.90 4080721.20 0.00914 245864.90 4080721.20 0.00723 245689.90 4080746.20 0.07687 245714.90 4080746.20 0.04157 245739.90 4080746.20 0.02564 245764.90 4080746.20 0.01740 245789.90 4080746.20 0.01261 245814.90 4080746.20 0.00958 245839.90 4080746.20 0.00753 245864.90 4080746.20 0.00608 245689.90 4080771.20 0.04405 245714.90 4080771.20 0.02676 245739.90 4080771.20 0.01796 245764.90 4080771.20 0.01294 245789.90 4080771.20 0.00979 245814.90 4080771.20 0.00768 245839.90 4080771.20 0.00619 245864.90 4080771.20 0.00510 245764.90 4080796.20 0.00971 245789.90 4080796.20 0.00765 245814.90 4080796.20 0.00619 245839.90 4080796.20 0.00510 245864.90 4080796.20 0.00428 245789.90 4080821.20 0.00606 245814.90 4080821.20 0.00502 245839.90 4080821.20 0.00422 245864.90 4080821.20 0.00360 245814.90 4080846.20 0.00415 245839.90 4080846.20 0.00354 245864.90 4080846.20 0.00305 245685.30 4080822.70 0.01741 245710.30 4080822.70 0.01269 245735.30 4080822.70 0.00968 245685.30 4080847.70 0.01232 245710.30 4080847.70 0.00943 245735.30 4080847.70 0.00746 245760.30 4080847.70 0.00607 245685.30 4080872.70 0.00921 245710.30 4080872.70 0.00731 245735.30 4080872.70 0.00594 245760.30 4080872.70 0.00494 245785.30 4080872.70 0.00417 245810.30 4080872.70 0.00357 245835.30 4080872.70 0.00308 245860.30 4080872.70 0.00268 245685.30 4080897.70 0.00717 245710.30 4080897.70 0.00583 245735.30 4080897.70 0.00484 245760.30 4080897.70 0.00409 245785.30 4080897.70 0.00351 245810.30 4080897.70 0.00305 245835.30 4080897.70 0.00267 245860.30 4080897.70 0.00235 245685.30 4080922.70 0.00576 245710.30 4080922.70 0.00477 245735.30 4080922.70 0.00402 245760.30 4080922.70 0.00344 245785.30 4080922.70 0.00299 ♦ *** AERMOD - VERSION 22112 ***
07/17/24
*** AERMET - VERSION 21112 ***
16:49:31
*** Construction Phase Of 7056 North Prospect Ave Project *** ««» DPM Emissions From Off-Road Construction Equipment - Only Weekday W *** PAGE 12
MODELOPTs: RegDFAULT CONC ELEV NOORYDPLT NOWETDPLT RURAL ADD_U* **« THE ANNUAL AVERAGE CONCENTRATION VALUES AVERAGED OVER 5 YEARS FOR SOURCE GROUP: ALL »** INCLUDING SOURCE(S): J00601AS
*** DISCRETE CARTESIAN RECEPTOR POINTS ***
** CONC OF DPM IN MICR0GRAMS/N**3 **

X-COORD (M) Y-COORD (M) CONC X-COORD (M) Y-COORD (M) CONC 245810.30 4080922.70 0.00263 245835.30 4080922.70 0.00233 245860.30 4080922.70 0.00208 245685.30 4080947.70 0.00474 245710.30 4080947.70 0.00398 245735.30 4080947.70 0.00339 245760.30 4080947.70 0.00293 245785.30 4080947.70 0.60257 245810.30 4080947.70 0.00228 245835.30 4080947.70 0.00204 245860.30 4080947.70 0.00184 245835.30 4080972.70 0.00179 245860.30 4080972.70 0.00163 245299.30 4080786.20 0.00772 245324.30 4080786.20 0.00922 245349.30 4080786.20 0.01120 245374.30 4080786.20 0.01386 245399.30 4080786.20 0.01749 245424.30 4080786.20 0.02261 245449.30 4080786.20 0.02998 245474.30 4080786.20 0.04103 245499.30 4080786.20 0.05904 245299.30 4080811.20 0.00811 245324.30 4080811.20 0.00967 245349.30 4080811.20 0.01168 245374.30 4080811.20 0.01431 245399.30 4080811.20 0.01778 245424.30 4080811.20 0.02242 245449.30 4080811.20 0.02867 245474.30 4080811.20 0.03715 245499.30 4080811.20 0.04842 245299.30 4080836.20 0.00838 245324.30 4080836.20 0.00991 245349.30 4080836.20 0.01183 245374.30 4080836.20 0.01424 245399.30 4080836.20 0.01725 245424.30 4080836.20 0.02095 245449.30 4080836.20 0.02541 245474.30 4080836.20 0.03056 245499.30 4080836.20 0.03603 245324.30 4080861.20 0.00990 245349.30 4080861.20 0.01159 245374.30 4080861.20 0.01361 245399.30 4080861.20 0.01590 245424.30 4080861.20 0.01845 245449.30 4080861.20 0.02114 245474.30 4080861.20 0.02382 245499.30 4080861.20 0.02621 245299.30 4080886.20 0.00839 245324.30 4080886.20 0.00960 245349.30 4080886.20 0.01097 245374.30 4080886.20 0.01245 245399.30 4080886.20 0.01399 245424.30 4080886.20 0.01552 245449.30 4080886.20 0.01698 245474.30 4080886.20 0.01828 245499.30 4080886.20 0.01926 245299.30 4080911.20 0.00805 245324.30 4080911.20 0.00901 245349.30 4080911.20 0.00999 245374.30 4080911.20 0.01097 245399.30 4080911.20 0.01189 245424.30 4080911.20 0.01274 245449.30 4080911.20 0.01350 245474.30 4080911.20 0.01412 245499.30 4080911.20 0.01449 245299.30 4080936.20 0.00751 245324.30 4080936.20 0.00819 245349.30 4080936.20 0.00883 245374.30 4080936.20 0.00941 245399.30 4080936.20 0.00993 245424.30 4080936.20 0.01038 245449.30 4080936.20 0.01078 245474.30 4080936.20 0.01108 245499.30 4080936.20 0.01120 245499.30 4080961.20 0.00888 245564.60 4080447.70 0.00232 245589.60 4080447.70 0.00261 245614.60 4080447.70 0.00296 245639.60 4080447.70 0.00340 ♦ **• AERMOD - VERSION 22112
07/17/24
AERMET - VERSION 21112
16:49:31
••• Construction Phase Of 7056 North Prospect Ave Project ««a ••• ««« *** •aa DPM Emissions From Off-Road Construction Equipment - Only Weekday W •** PAGE 13
*** MODELOPTs: RegDFAULT CONC ELEV NODRYDPLT NOWETDPLT RURAL AD3_U* *** THE ANNUAL AVERAGE CONCENTRATION VALUES AVERAGED OVER 5 YEARS FOR SOURCE GROUP: ALL •a*
INCLUDING SOURCE(S): 300601AS '
DISCRETE CARTESIAN RECEPTOR POINTS ••• *••
IN MICROGRAMS/M**3 »» CONC OF DPM *»

X-COORD (M) Y-COORD (M) CONC X-COORD (M) Y-COORD (M) CONC 245664.60 4080447.70 0.00397 245689.60 4080447.70 0.00466 245714.60 4080447.70 0.00543 245739.60 4080447.70 0.00619 245564.60 4080472.70 0.00283 245589.60 4080472.70 0.00324 245614.60 4080472.70 0.00377 245639.60 4080472.70 0.00445 245664.60 4080472.70 0.00531 245689.60 4080472.70 0.00632 245714.60 4080472.70 0.00737 245739.60 4080472.70 0.00830 245764.60 4080472.70 0.00897 245789.60 4080472.70 0.00928 245564.60 4080497.70 0.00355 245589.60 4080497.70 0.00416 245614.60 4080497.70 0.00498 245639.60 4080497.70 0.00607 245664.60 4080497.70 0.00742 245689.60 4080497.70 0.00890 245714.60 4080497.70 0.01027 245739.60 4080497.70 0.01130 245764.60 4080497.70 0.01180 245789.60 4080497.70 0.01175 245564.60 4080522.70 0.00461 245589.60 4080522.70 0.00556 245614.60 4080522.70 0.00694 245639.60 4080522.70 0.00877 245664.60 4080522.70 0.01091 245689.60 4080522.70 0.01302 245714.60 4080522.70 0.01467 245739.60 4080522.70 0.01551 245764.60 4080522.70 0.01546 245789.60 4080522.70 0.01470 245564.60 4080547.70 0.00629 245589.60 4080547.70 0.00789 245614.60 4080547.70 0.01038 245639.60 4080547.70 0.01362 245664.60 4080547.70 0.01701 245689.60 4080547.70 0.01981 245714.60 4080547.70 0.02133 245739.60 4080547.70 0.02129 245764.60 4080547.70 0.01998 245789.60 4080547.70 0.01799 245564.60 4080572.70 0.00922 245589.60 4080572.70 0.01231 245614.60 4080572.70 0.01726 245639.60 4080572.70 0.02311 245664.60 4080572.70 0.02822 245689.60 4080572.70 0.03127 245714.60 4080572.70 0.03128 245739.60 4080572.70 0.02876 245764.60 4080572.70 0.02507 245789.60 4080572.70 0.02124 245221.90 4080419.40 0.00129 245246.90 4080419.40 0.00131 245271.90 4080419.40 0.00132 245221.90 4080444.40 0.00147 245246.90 4080444.40 0.00150 245271.90 4080444.40 0.00153 245296.90 4080444.40 0.00156 245321.90 4080444.40 0.00157 245221.90 4080469.40 0.00167 245246.90 4080469.40 0.00173 245271.90 4080469.40 0.00178 245296.90 4080469.40 0.00182 245321.90 4080469.40 0.00187 245346.90 4080469.40 0.00190 245371.90 4080469.40 0.00191 245396.90 4080469.40 0.00192 245421.90 4080469.40 0.00193 245221.90 4080494.40 0.00190 245246.90 4080494.40 0.00198 245271.90 4080494.40 0.00206 245296.90 4080494.40 0.00214 245321.90 4080494.40 0.00221 245346.90 4080494.40 0.00228 245371.90 4080494.40 0.00233 245396.90 4080494.40 0.00237 245421.90 4080494.40 0.00240 ♦ *** AERMOD - VERSION 22112
07/17/24
AERMET - VERSION 21112 ***
16:49:31
*** Construction Phase Of 7056 North Prospect Ave Project *»« DPM Emissions From Off-Road Construction Equipment - Only Weekday W ••• ••• PAGE 14 »** MODELOPTs: RegDFAULT CONC ELEV NODRYDPLT NOWETDPLT RURAL ADD_U* THE ANNUAL AVERAGE CONCENTRATION VALUES AVERAGED OVER 5 YEARS FOR SOURCE GROUP: ALL *•* INCLUDING SOURCE(S): 300601AS 1
*** DISCRETE CARTESIAN RECEPTOR POINTS ***
** CONC OF DPM IN MICROGRAMS/M**3 ••

X-COORD (M) Y-COORD (M) CONC X-COORD (M) Y-COORD (M) CONC 245446.90 4080494.40 0.00242 245471.90 4080494.40 0.00247 245496.90 4080494.40 0.00258 245521.90 4080494.40 0.00279 245221.90 4080519.40 0.00213 245246.90 4080519.40 0.00225 245271.90 4080519.40 0.00237 245296.90 4080519.40 0.00250 245321.90 4080519.40 0.00262 245346.90 4080519.40 0.00274 245371.90 4080519.40 0.00285 245396.90 4080519.40 0.00295 245421.90 4080519.40 0.00302 245446.90 4080519.40 0.00308 245471.90 4080519.40 0.00315 245496.90 4080519.40 0.00328 245521.90 4080519.40 0.00355 245221.90 4080544.40 0.00237 245246.90 4080544.40 0.00253 245271.90 4080544.40 0.00271 245296.90 4080544.40 0.00289 245321.90 4080544.40 0.00308 245346.90 4080544.40 0.00328 245371.90 4080544.40 0.00349 245396.90 4080544.40 0.00368 245421.90 4080544.40 0.00385 245446.90 4080544.40 0.00401 245471.90 4080544.40 0.00415 245496.90 4080544.40 0.00434 245521.90 4080544.40 0.00470 245221.90 4080569.40 0.00261 245246.90 4080569.40 0.00283 245271.90 4080569.40 0.00306 245296.90 4080569.40 0.00332 245321.90 4080569.40 0.00360 245346.90 4080569.40 0.00391 245371.90 4080569.40 0.00424 245396.90 4080569.40 0.00458 245421.90 4080569.40 0.00493 245446.90 4080569.40 0.00528 245471.90 4080569.40 0.00563 245496.90 4080569.40 0.00601 245521.90 4080569.40 0.00657
♦ *** VERSION 22112 *** Construction Phase Of 7056 North Prospect Ave Project AERMOD *** 07/17/24
'*** AERMET - VERSION 21112 ***
16:49:31
*«* DPM Emissions From Off-Road Construction Equipment - Only Weekday W *** PAGE 15
•** MOOELOPTs: RegOFAULT CONC ELEV NODRYDPLT NOWETDPLT RURAL AD3_U* THE SUf-'mRY OF MAXIMUM ANNUAL RESULTS AVERAGED OVER 5 YEARS *** IN MICROGRAMS/M**3 »» CONC OF DPM ••

NETWORK

GROUP ID

GRID-ID

AVERAGE CONC RECEPTOR (XR, YR, ZELEV, ZHILL, ZFLAG) OF TYPE ALL 1ST HIGHEST VALUE IS 0.11757 AT ( 245689.90, 4080671.20, 99.06, 99.06, 0.00) DC 2ND HIGHEST VALUE IS 0.11503 AT ( 245689.90, 4080696.20, 99.06, 99.06, 0.00) DC 3RD HIGHEST VALUE IS 0.10227 AT ( 245689.90, 4080721.20, 99.11, 99.11, 0.00) DC 4TH HIGHEST VALUE IS 0.07687 AT ( 245689.90, 4080746.20, 99.22, 99.22, 0.00) DC 5TH HIGHEST VALUE IS 0.07252 AT ( 245714.90, 4080671.20, 99.06, 99.06, 0.00) DC 6TH HIGHEST VALUE IS 0.06783 AT ( 245714.90, 4080696.20, 99.10, 99.10, 0.00) DC 7TH HIGHEST VALUE IS 0.05904 AT ( 245499.30, 4080786.20, 98.90, 98.90, 0.00) DC 8TH HIGHEST VALUE IS 0.05707 AT ( 245714.90, 4080721.20, 99.22, 99.22, 0.00) DC 9TH HIGHEST VALUE IS 0.04842 AT ( 245499.30, 4080811.20, 98.77, 98.77, 0.00) DC 10TH HIGHEST VALUE IS 0.04710 AT ( 245739.90, 4080671.20, 99.06, 99.06, 0.00) DC •** RECEPTOR TYPES: GC = GRIDCART
GP = GRIDPOLR
DC = DISCCART
DP = DISCPOLR
♦ *•* ••• Construction Phase Of 7056 North Prospect Ave Project AERMOD - VERSION 22112 ••• 07/17/24
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EXHIBIT B
23 July 2024
Christopher A. Brown, Director
Fennemore Law
8080 N. Palm Avenue, Third Floor
Fresno, California 93711
Subject: Lincoln Park Apartments, 7056 North Prospect Avenue, Fresno, California City of Fresno Permit Application P21-00989
Review of Categorical Exemption Environmental Assessment – Noise Dear Mr. Brown:

I have reviewed documents pertaining to the Categorical Exemption of the subject project, in particular the document identified as Exhibit J on the City of Fresno’s Legislation website page that pertains to this project:1
City of Fresno Categorical Exemption
Environmental Assessment for Development Permit Application No. P21-00989 (“Environmental Assessment”)
This letter presents our comments on Noise section of this document.

Wilson Ihrig, Acoustical Consultants, has practiced exclusively in the field of acoustics since 1966. During our 58 years of operation, we have prepared hundreds of noise studies for Environmental Impact Reports and Statements. We have one of the largest technical laboratories in the acoustical consulting industry. We also regularly utilize industry-standard acoustical programs such as Environmental Noise Model (ENM), Traffic Noise Model (TNM), SoundPLAN, and CADNA. In short, we are well qualified to prepare environmental noise studies and review studies prepared by others.

Comments Regarding Construction Noise
The Environmental Assessment takes the position that because the Fresno municipal code exempts construction noise during specified time periods from the quantitative noise standards that otherwise apply, construction noise from the project will technically comply with the local 1 City of Fresno - File #: ID 24-651 (legistar.com)
Lincoln Park Apartments Project
Review of Cat Ex Noise Assessment
2 standards and, therefore, is incapable of causing any sort of environmental impact. The fallacy of this argument is plain when one considers that it would allow noise levels that could cause hearing loss and still lead to the conclusion that those levels do not cause a significant environmental noise impact. CEQA is not focused on the application of local regulations.

Rather, it is focused on the determination of actual environmental degradation and disclosure of any degradation that is reasonably found to cause a significant impact on the environment.

While the CEQA Appendix G guidelines for noise assessment do call for comparison of project noise levels to local standards, they also call for comparison to the existing ambient, specifically stating:

Would the project result in . . . [g]eneration of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project . . .

This aspect of a thorough CEQA noise assessment is completely disregarded in the Environmental Assessment document.

An assessment based on the existing ambient is all the more important in this situation because the Fresno noise ordinance’s prima facia noise limit is itself based on the ambient noise level:

There is nothing in the record for this project that suggests that ambient measurements have been made in the surrounding neighborhoods. However, the Fresno Noise Ordinance contains statutory minimum ambient noise levels for various zoning districts, and given a lack of any other information, it is reasonable to assume these for the areas surrounding the project site. For residential districts, these statutory ambient levels are:
7:00 am to 7:00 pm 60 dBA
7:00 pm to 10:00 pm 55 dBA
Construction is a noisy endeavor. The Environmental Protection Agency (EPA) has published typical ranges of noise levels at construction sites for a variety of building types.2 For domestic housing, the EPA noise levels for each major phase of construction with all pertinent equipment present at site are reproduced in Table I.
2 Noise from Construction Equipment and Operations, Building Equipment, and Home Appliances, U. S.

Environmental Protection Agency, NTID300.1, 31 December 1971.

Lincoln Park Apartments Project
Review of Cat Ex Noise Assessment
3 TABLE I EPA NOISE LEVELS FOR RESIDENTIAL CONSTRUCTION Phase Average Range
‡

Ground clearing 83 dBA 75 to 91 dBA
Excavation 88 80 to 96
Foundations 81 71 to 91
Erection 81 71 to 91
Finishing 88 81 to 95
‡ The range is the average plus/minus one standard deviation. For a “normal” (bell-shaped) distribution, the noise level will be within the range 68% of the time and higher than the low end of the range 84% of the time.

The values given in Table I are based on the loudest piece of equipment being located at a distance of 50 feet. Construction equipment noise spreads as a point source (as opposed to roadway noise which is a line source), and point source noise attenuates at a rate of 6 decibels per every doubling of distance (which means it also increases 6 dB for every halving of distance). So, for example, if the noise is 88 dBA at 50 feet, it will be 82 dBA at 100 feet and 76 dBA at 200 feet. The noise level does not attenuate linearly with distance because the decibel scale is logarithmic (like the Richter scale for earthquakes).

According to F.M.C. Sec. 10-106, the prima facia noise limit for most noises is 5 dB over the ambient. Using the statutory daytime (7:00 am – 7:00 pm) ambient of 60 dBA, the prima facia limit is 65 dBA. However, as noted above, construction noise levels are exempted by the F.M.C. from the normal prima facia noise limit, so what is a reasonable threshold of significance? I believe a reasonable limit is the prima facia limit plus another 5 dB., i.e., the ambient plus 10 dB.

Given the statutory ambient, this is 70 dBA between 7:00 am and 7:00 pm.

Returning to Table I, one can see that not only is the average noise level for every construction phase well over 70 dBA, the lower end of the expected range is also over 70 dBA for every phase. This is direct evidence that unmitigated construction noise will cause a significant impact on residents immediately adjacent to the project site (namely, residents of the 11 homes between 7003 and 7063 Harmony Drive, inclusive).

Another way to look at this is to consider how far away the construction will have to be for the noise level to drop to 70 dBA. If the noise level at 50 feet is 88 dBA, the construction would have to be 400 feet away for the level to attenuate to 70 dBA. However, the width of the site from east to west is only 350 feet. So, if the average construction noise level is 88 dBA at 50 feet, it will be greater than 70 dBA for the entire period of the phase.3 Focusing on the first four phases of construction, Table II shows the percentage of the 350-foot wide site for which the noise level will be greater than 70 dBA.
3 This is strictly true for the Ground Clearing, Excavation, and Foundation phases. Potentially less so for the Erection phase if some built portions block noise from other portions being built. For the Finishing phase the noise levels would only match the levels shown in Table I for areas that have a direct line of sight to the off-site receptor.

Lincoln Park Apartments Project
Review of Cat Ex Noise Assessment
4 TABLE II PERCENT OF SITE ON WHICH NOISE WILL EXCEED 70 dBA Phase Average Range
Ground clearing 64% 25% to 100%
Excavation 100% 45% to 100%
Foundations 51% 16% to 100%
Erection 51% 16% to 100%
For each of the first four phases of construction, the noise level is expected to exceed 70 dBA for more than 50% of the site. This indicates the longevity of time that residences of Harmony Drive will be subjected to construction noise levels at least 10 dB higher than the statutory ambient and 5 dB higher than the prima facia noise limit established by the F.M.C.

Concluding Comments
The Environmental Assessment upon which the Categorical Exemption for this project is based concludes that there will not be a temporary noise impact based on a legal technicality, disregarding the intent and spirit of CEQA. Using construction noise level estimates published by the EPA, an ambient noise level based on the Fresno municipal code, and a reasonable threshold of significance also founded upon the municipal code, I have demonstrated by simple analysis that, in fact, the residents of Harmony Drive will be likely be subjected to a temporary, significant noise impact by the construction of the Lincoln Park Apartments project. * * * * *
Please let me know if you have any questions about these comments on Lincoln Park Apartments environmental noise assessment that was produced to support a Categorical Exemption for the project.

Very truly yours,

WILSON IHRIG
Derek L. Watry
Principal
From:

To: Adrienne Asadoorian
Cc: Jerry Dyer; [email protected]
Subject: Letter against Text Amendment Application P24-00794 and Mitigated Negative Declaration (SCH NO. 2024110662)
Date: Tuesday, February 11, 2025 8:43:52 AM
External Email: Use caution with links and attachments
TO:

Adrienne Asadoorian-Gilbert,
Supervising Planner,
City of Fresno
Planning and Development Dept.,
2600 Fresno St.

Fresno CA 93721-3604
Dear Ms. Asadoorian-Gilbert,
We are writing in opposition to the proposed Text Amendment Application P24-00794 and Mitigated Negative Declaration (SCH NO. 2024110662) for the City of Fresno. Although these proposals affect the whole city, my comments are in reference to the current vacant lots bordering the North and South sides of Herndon Avenue between the streets of North Marks Avenue and North Milburn Avenue.

Please
enter these comments into the public record regarding these proposals.

Specifically:

We are against the repeal of Fresno Municipal Code Section 15-1106 as proposed in the Text Amendment Application P24-00794. Removal of this section of the Municipal Code would give the City a green light to ignore required road, parking, pedestrian/bicycle route and traffic signal upgrades under the Fresno Complete Street Policy dated Sept 26, 2019 with new RM-1, RM-2 and RM-3 developments. Fresno Municipal Code Section 15-1106 also requires the City to do traffic impact studies for all development with 300 or more peak hour new vehicle trips. This would be done away with if this section is repealed.

In regards to the Text Amendment Application P24-00794, I have the following concerns/comments specifically relating to the vacant lots running along both the North and South sides of Herndon Avenue, between N. Marks Avenue and N. Milburn Avenue:

Section 4.1a “Aesthetics”. The study is flawed when it states that there would be less than significant impacts to scenic vistas with RM-3 developments. RM-3 allows for the construction of up to 45 living units per acre (which could easily house 4 people per unit) and up to 60 feet in height. Apartment units that are 60 feet in height would be a blight on a neighborhood that consists of primarily single story dwellings (houses, apartments, condos and townhomes). If any of the vacant lots along both sides of Herndon Avenue between Marks and Milburn Avenues were converted to RM-3, it would create an aesthetically unpleasant situation for current residents and for the city. As an example, I will refer the Planning Commission to how much the Clinton Avenue Apartments (at 1538 E. Clinton) stand out like a sore thumb when compared to the surrounding neighborhood of single family homes, and they are only 4 stories high (see attached photo).

Section 4.11. “Land Use Planning”. If RM-3 development is allowed in these lots along the Herndon corridor, it would physically constrict travel between the already established neighborhoods along the North side of Herndon Avenue with access to Herndon Avenue along Marks, Valentine and Brawley Avenues. RM-3 development in these lots would introduce new, incompatible uses that are inconsistent with the current land use planning. I specifically note that the Text Amendment Application P24-00794 does not propose the construction of any new roadways which may be needed to handle increased traffic flow if RM-3 zoning is allowed.

Section 4.13. “Noise”. The study is flawed in that there would be a significant negative impact due to increased traffic noise, especially during key commute hours.

Section 4.14. “Population and Housing”. The Text Amendment Application P24-00794 would significantly negatively impact the inducement of unplanned population growth in an area originally planned for offices.

Section 4.15. “Public Services”. The allowance of RM construction in these lots currently zoned for office space would exasperate overcrowding in Tatarian Elementary School. Impaired access of Ladder Fire Trucks at the traffic circle along N. Prospect Avenue has already been addressed in earlier hearings.

Sections 4.17 a, c and d. “Transportation”. As pointed out above, there already is inadequate emergency vehicle access along the traffic circle on North Prospect Avenue. Large fire ladder trucks would have a difficult time negotiating the current traffic flow along North Prospect and the frontage road (called North Valentine Ave). If RM3 is approved for this street, traffic flow will be impeded during peak traffic hours, including any emergency vehicles coming into the area during these times. The finding in Section 4.17 (a) is flawed in that there are no sidewalks (or bike path) along the Herndon frontage road between North Prospect Ave and N. Valentine Avenue allowing for safe passage of pedestrians and bicyclists.

Bottom line, we understand that we need more housing in Fresno. I’m OK with the addition of single-story townhomes, apartments and condos along the Herndon Corridor. But, high density RM3 units that are 60 feet tall? No!! those are totally incompatible all neighborhoods in Fresno with the exception of downtown where there are other high rise buildings. Let’s keep the buildings along this section of the Herndon avenue corridor to two stories or less.

We are asking the Planning Commission to use some common sense when developing land for new housing that works for ALL of our residents. Bypassing years of thoughtful planning with the Development Code is not what the residents of the City of Fresno expect nor deserve from their leaders. We recommend we continue to abide by the current 2024 Zoning Standards and to NOT adopt the Text Amendment Application P24-00794 and the Mitigated Negative Declaration (SCH NO. 2024110662) for the City of Fresno.

IMPORTANT PLANNING COMMISSION MEETING
Wednesday, February 19, 2025
6 p.m. CITY HALL
2600 Fresno Street, 2'° Floor
There is going to be a Public Hearing on Text Amendment Application No. P24-00794 and
Mitigated Negative Declaration SCH NO. 2024110662
This will allow ministerial re-zoning of developed and undeveloped parcels zoned for office within a half-mile of an existing bus stop to multi-family. This can be ministerially approved up to 45 Units per acre and SIXTY feet tall, subject to the city development code.

You can google City of Fresno Parking rules for information on parking and the meters.

This is a VERY IMPORTANT MEETING. We need YOU and every adult in your household to attend.

If you wish to speak, you will need to fill out a card and the clerk will call you. You will need to get there early to go through security and register to speak. If we FILL THE CHAMBERS and we MUST, comments will likely be limited to 2 minutes.

Please DO NOT speak about school redistricting, crime, declining home values, or Section 8.

DO NOT disparage renters.

Focus on SAFETY, INFRASTRUCTURE, and QUALITY of LIFE ISSUES. PARKING, TRAFFIC, PUBLIC SAFETY ACCESS during school drop-off and pick-up, safety for children and parents walking to and from school are relevant issues.

ASK TO HAVE OUR PARCELS REMOVED FROM THE MAP from Marks to Milburn.

ASK FOR US TO BE EXEMPTED from the Mitigated Negative Declaration.

WE need to SHOW UP in FORCE in the same RESPECTFUL AND UNITED MANNER that we displayed last year. We have worked so hard to protect the neighborhood and this is the worst proposal yet.

WE NEED YOU ALL TO ATTEND THIS MEETING
If you work out of town, have a planned vacation or physical limitation that prevents your attendance, you may sign the attached and email to Supervising Planner Adrienne AsadoorianGilbert: [email protected] Cc: Fresno Planning Commission c/o: [email protected] Cc:

You may also email your own comments if you wish. COMMENTS MUST BE DONE at least 24 Hours prior to the meeting. No later than 4 p.m. on February 18th.

WE MUST PREVAIL and we need EVERYONE to attend this meeting

SEE YOU THERE
We are Unable to Attend the February 19, 2025 Planning Commission meeting. However, we would like to voice our objection to the Text Amendment Application No. P24-00794 and Mitigated Negative Declaration Sch. No. 2024110662. We respectfully ask that you remove the developed and undeveloped properties on Herndon Ave from Marks to Milburn from this Text Amendment Application No. P24-00794. We would also ask that these properties be exempted from Mitigated Negative Declaration Sch. No. 2024110662.

Signature Print
Send your "Unable to Attend" Objection Signature Sheet to Supervising Planner Adrienne Asadoorian-Gilbert:

[email protected]
Cc: Fresno Planning Commission c/o: [email protected] Cc:

Before 4 p.m.
o n
February 18th, 2025
Carla Johnson
William Johnson

CITY OF FRESNO

PLANNING AND DEVELOPMENT DEPARTMENT

NOTICE OF PUBLIC HEARING
TEXT AMENDMENT APPLICATION NO. P24-00794
AND
MITIGATED NEGATIVE DECLARATION (SCH NO. 2024110662)
NOTICE IS HEREBY GIVEN that the Fresno City Planning Commission, in accordance with Sections 15- 4902, 15-4903, 15-5809 and 15-5810 of the Fresno Municipal Code and in accordance with the procedures of Article 50, Chapter 15, of the Fresno Municipal Code, will conduct a public hearing to consider the items below, filed by the City of Fresno. At the hearing, the following will be considered:

1. Mitigated Negative Declaration Sch No. 2024110662: In accordance with the California Environmental Quality Act (CEQA), a Mitigated Negative Declaration (MND) was prepared by the City to consider potential impacts associated with implementation of the project, and to provide mitigation measures that would reduce impacts to less than significant levels. The Draft MND was released for a 30-day public review period beginning on November 20, 2024 and ending on December 20, 2024.

2. Text Amendment Application No. P24-00794 consideration of a citywide text amendment that would amend Sections 15-1302, 15-4907, 15-5102, 15-6702, 15-6802 of the Fresno Municipal Code, repeal Section 15-1106 of the Fresno Municipal Code, and establish Section 15-2742.5 of the Fresno Municipal Code, to permit ministerial approval of housing projects in the following instances as noted below:
•a. Ministerial approval of office to dwelling conversions in the Office zone district; and b. Ministerial approval of multi-unit residential development in the RM-1, RM-2, and RM-3 zone districts on parcels within one-half mile of an existing bus stop; and c. Ministerial approval of multi-unit residential uses in the NMX, CMX, RMX, CMS and CR zone districts on parcels within the City's Infill Priority Area; and d. Ministerial approval of new multi-unit residential development in the Office zone district. *The above documents are available for public review via e-mail (noted below) and within the upcoming Planning Commission identified webpage https://www.fresno.gov/planning/plans-projects-under-review/#mixed-use-text-amencment for additional information.

FRESNO PLANNING COMMISSION
Date: Wednesday, February 19, 2025
Time: 6:00 p.m., or thereafter
Place: City Hali Council Chamber, Second Floor, 2600 Fresno Street, Fresno, CA 93721; or watch the live broadcast via the Zoom link located on the Planning Commission agenda found here: https://fresno.legistar.com/Calendar.aspx
Any interested person may appear at the public hearing and present written testimony, or speak in favor or against the project proposal. However, all documents submitted to the Planning Commission for its consideration shall be submitted to the Planning and Development Department at least 24 hours prior to the Planning Commission Agenda item being heard, pursuant to Article 4(3), or they may be excluded from the administrative record of proceedings. If an individual challenges the above applications in court, they may be limited to raising only those issues that were raised at the public hearing described in this notice, or in written correspondence delivered to the Development Services Division of the Planning and Development Department and/or Planning Commission consistent with their respective rules of procedure at, or prior to, the public hearing. The Planning Commission recommendation on the proposed Text Amendment and Environmental Assessment will be considered by the City Council.

NOTE: This public hearing notice is being published in the Fresno Bee pursuant to the requirements of Fresno Municipal Code Section 15-5007.

For additional information regarding this project, contact Adrienne Asadoorian-Gilbert, Supervising Planner, Planning and Development Department, 2600 Fresno Street, Fresno, California 93721-3604, by phone at (559) 621-8339 or via e-mail at [email protected]. Si necesita información en Español, comuniquese con Yamilex Nava al teléfono (559) 621-8028 o por correo electrónico a [email protected].

Sunnyside Property Owners Association
Serving Sunnyside for 75 Years
February 28, 2025
Adrienne Asadoorian-Gilbert
Supervising Planner
Long Range Planning & Development Department
City of Fresno
2600 Fresno Street
Fresno, CA 93721

ATT: Ms. Asadoorian-Gilbert

RE: Text Amendment Application No. P24-00794
The Board of Directors of the Sunnyside Property Owners Association offer the following comments on the above referenced Text Amendment Application allowing multi-family in the Office Zone District and ministerial approval of:
• Office to dwelling conversion within the Office Zone District • New standalone multi-unit residential development in the Office District • Multi-Unit Residential development within 1/2 mile of an existing bus stop • Multi-Unit Residential uses in Mixed-Use Districts within the City’s Infill Priority Area This text amendment should be denied for a host of reasons: it replaces those office uses that are essential to neighborhoods, defaults to the greatest density allowed in Residential Multi-Family Zone Districts on vacant or underdeveloped parcels in the Office District, prevents the public from providing input for Multi-Family in Office Zone Districts, next to transit stops and Mixed Use Districts in the City’s Priority Infill Area, and contributes only a fraction of additional housing unit capacity that is neither necessary or required.

While the Project could result in a buildout of 22,425 units over the next thirty years, Office-to-Dwelling Conversions and New Residential Development on Office Parcels will yield only 4,868 additional units. The other 17,557 units are currently allowable uses consistent with the General Plan land use designation and underlying zone district. The Sixth Cycle Housing Element allocation for the City of Fresno is 37,000 new homes by 2031. The city has stated that the inventory of property zoned or planned for residential development already provides sufficient capacity for the allocated number of homes, with a surplus of 6,800 units.

This text amendment would allow ministerial approval of all multi-unit residential units in the Office District, within 1/2 miles of an existing bus stop and in mixed-use districts within the City’s Infill Priority Area. Ministerial approval not only eliminates a hearing before the Planning Commission and City Council, but prevents all advisory and Project Review Committees from reviewing projects as well. Most importantly, the most egregious aspect of replacing discretionary with ministerial review, for projects that have in some cases, no density cap or parking requirements, is the inability for the public to provide comment on development proposals that impact their neighborhoods the most.

The City’s Mixed Use Text Amendment (MUTA), adopted by Council in 2022, removed the maximum density caps for multi-family in all mixed-use districts within the City’s Priority Areas for Development, raising the allowed density by 200 to 500%. This amendment also proposed ministerial review, but the provision was not included in the final text.

That same year, the state adopted Assembly Bill 2097 which prohibits a public agency from imposing minimum parking requirements on any residential, commercial or other development project located within one-half mile of a major transit stop.

Collectively, these two actions resulted in open-ended density for multi-family development, absent parking when located next to a major transit stop, for all mixed use districts within the City’s Infill Priority Areas.

TA P24-00794 builds on the MUTA; adding multi-family development to Office Districts and allowing ministerial review for all multi-family units next to transit stops and the City’s Infill Priority Areas.

As defined by FMC Section 15-6704, an “office” use means offices of firms or organizations providing professional, executive, management, administrative or design services such as accounting, architectural, computer software design, engineering, graphic design, interior design, investment, insurance, and legal offices, excluding banks and savings and loan associations. This classification also includes offices where medical and dental services are provided by physicians, dentists, chiropractors, acupuncturists, optometrists, and similar medical professionals including medical/ dental laboratories within medical office buildings but excluding clinics or independent research laboratory facilities and hospitals. Further classifications of “office” use includes business and professional, medical, dental and walk-in clientele.

The Office District is often the most cohesive neighbor to single family residential zoning, providing a buffer from more intense commercial offerings and traffic on street classifications other than Local.

While the number of multi-family units on developed parcels in the Office District would be limited by the square footage of existing buildings, new multi-family would default to the most intense density allowed per the City of Fresno’s Development Code for Multi-Family Districts at 30-45 dwelling units per acre.

Introducing multi-family to the Office District, exposes existing neighborhoods to greatly disparate densities and much greater traffic. And if located next to a transit stop, could be developed without any parking.

While the Sunnyside area does not currently enjoy any Office District Zoning, despite the need for medical and dental facilities, we do have substantial acreage east of Clovis Avenue, north and south of Kings Canyon Road, that was rezoned to Corridor Center Mixed Use during the last General Plan Update. These developed, underdeveloped and vacant parcels are within the City’s Priority Infill District adjacent to the City’s Bus Rapid Transit “Q” Line. Per the Mixed Use Text Amendment already adopted by Council, there is no limit to the number of multi-family units that could be developed (estimated at 50 du/A for purposes of the Mitigated Negative Declaration completed for this Project). This will be the second attempt by the city to eliminate public input in the planning process.

We urge the members of the Planning Commission and City Council to deny Text Amendment Application No. P24-00794. It is both unnecessary and an egregious misuse of power. Instead of eliminating the right to comment, the public should be encouraged to become a bigger part of the discussion through planning, advocacy and politics.

People have a right to influence what affects them. This amendment removes that right.

Respectfully,
Sue Williams
For the Board of Directors of the Sunnyside Property Owners Association

Host’s desire, as stated in the Contract (City Zoning and Land use plan).

The Host agrees to the Contract, signs it and asks the Party Coordinator to oversee the Contract to make sure it is followed through.

To make a long story shorter: the Caterer decides to do a CHANGE UP on the food and services that are nowhere close to what is in the Contract.

This CHANGE UP is supposedly based on outside influence (State Government, Developers and Friends) and is not his fault. He is now asking the Coordinator to revise the signed Contract. The Caterer is saying that they will not service the Contract AS IS.

The Host of the Party is saying “no to the revisions to the Contract.” They are paying for the Contract AS IS. It is the duty of the Party Coordinator to say “NO TO THE REVISIONS.” The Caterer will service the Contract AS IS on behalf of the Host. The power play by the Caterer will not happen.

I respectfully request that the Planning Commission DENY the power play by the City of Fresno on behalf of the people who pay their wages.

Sincerely,
William D. Stevens
1972 Bachelor of Architecure
1979 Registered Architect, California
1981 NCARB Certificate
Please confirm receipt by return e-mail.

INVESTFresnoCA.com
March 3, 2025
Peter Vang, Chairman Submitted Electronically
Planning Commission
City of Fresno
2600 Fresno Street, Room 3043
Fresno, CA 93721
ATTN: Jennifer Clark, Planning Director
[email protected]
RE: SUPPORT – Text Amendment Application No. P24-00794 – Ministerial Approval Dear Chairman Vang, Commissioners, and Staff:

I write today on behalf of INVEST Fresno, a coalition of residents, businesses, and community organizations committed to building a diverse and sustainable economy in Fresno, to express our support for Text Amendment P24-00794 – ministerial approval for office-to-dwelling conversions in the office zone, housing near bus stops in multi-family zones, infill residential development in mixed-use zones, and new residential in office zones.

As detailed in the City’s Housing Element, it is estimated that Fresno needs to add roughly 37,000 new housing units by 2031 to keep up with the demand of a growing population. With Fresno’s prime location and growing workforce, we must shape Fresno into a city where housing availability keeps pace with demand, reduces costs, and strengthens neighborhoods.

Ministerial approvals are a practical, common-sense solution to ensure that various projects can move forward efficiently and timely, without unnecessary delays that drive up costs and limit supply. It is important to note projects that undergo a ministerial approval process must still comply with all applicable state and local development standards and meet all zoning, building, and environmental regulations.

But this isn’t just about policy, it’s about people. Rising rents and home prices affect everyone.

When housing is out of reach, so is opportunity, making it harder for workers, students, and seniors to find stable, affordable places to live. Particularly in recent years, slow-moving red tape processes have created significant barriers to Fresno’s growth. The implementation of a ministerial approval process will serve as a step toward building a stronger, more inclusive Fresno, where families can afford to put down roots, invest in their future, and grow in the city we all love.

We have made real progress in increasing housing production and expanding opportunity, but that momentum is not guaranteed. Delays and uncertainty in the approval process only make it harder and more expensive to build the homes Fresno families need, and if we do not act, families will be forced to leave. We cannot afford to lose our workforce, our small business owners, and our next generation of leaders to neighboring cities that are moving faster to meet housing demand.

The path forward is clear: Fresno must embrace policies that accelerate residential development and ensure that future generations can build their futures right here at home.

Ministerial approvals are a vital part of this strategy, giving homebuilders the confidence to invest while ensuring new housing meets Fresno’s high standards for design, sustainability, and community benefit.

Additionally, to bolster our local economy, we encourage the City to extend ministerial approvals to job-creation projects, including industrial uses. Similar policies for both small and large-scale projects in neighboring communities are crippling Fresno’s natural competitive advantage. Just as we might remove barriers to housing production, the growth of both existing and new businesses and industries is critical for local residents – providing good-paying jobs close to home, sustaining Fresno’s working families, and bolstering our economic vitality.

We appreciate your time and consideration and respectfully urge the Planning Commission to approve Text Amendment Application No. P24-00794. By doing so, Fresno is taking a positive step toward creating a thriving, affordable, and economically resilient city that supports families, strengthens neighborhoods, and secures Fresno’s future for generations to come.

Sincerely,
Ben Granholm
Executive Director
cc: Jerry Dyer, Mayor
Georgeanne White, City Manager
Councilmembers, City of Fresno
Planning Commission, City of Fresno
From:

To: Adrienne Asadoorian
Subject: Text Amendment Application No. P24-00794
Date: Monday, March 10, 2025 11:35:51 AM
External Email: Use caution with links and attachments
March 10, 2025
RE: Notice of Intent to Adopt a Mitigated Negative Declaration regarding Text Amendment P24-00794 Dear Ms. Asadoorian:

I am writing to object to the Notice of Intent to Adopt a Mitigated Negative Declaration regarding Text Amendment P24-00794 and any reconsideration of Building App. No. P21-00989 that previously failed to gain approval by the Fresno Planning Commission and the City Council for numerous problematic issues.

Regarding the proposed Mitigated Negative Declaration Application of Text Amendment P24-00794, I am concerned this amendment in large measure bypasses the numerous safeguards provided our community through the current Planning Commission project review process. The requirement for notice of proposals and notice of public hearings provides citizens of Fresno the opportunity to voice their support and/or concerns regarding any and all projects in our community. This proposal in large measure bypasses that process and thereby bypasses the community safeguards for uncontrolled and potentially hazardous building projects provided by formal Planning Commission project review.

In my Fresno district, Councilman Karbassi’s District 2, the Project Review Committee, staffed by citizen volunteers, hasn’t met for over a year. Loss of this preliminary review committee has already weakened citizen input into development of potentially unsafe project development in Fresno District 2. I’m hopeful not only that the proposed Text Amendment P24-00794 will be voted down, but also that the District 2 Project Review Committee will be reformed and begin meeting on a regular basis in the near future.

One example of an unsafe proposed project in District 2 is contained in Building Application No. P21-00989. Happily, that building application was denied several times by the Fresno Planning Commission and subsequently by the Fresno City Council. That proposal for an 82 unit 3 and 4 story apartment complex at Herndon Avenue and N. Prospect Avenue should not be built as initially planned for a number of significant reasons that present several potential risks and liability for future residents of the facility.

These include:

1. Building evacuation in case of fire,

2. Access to the proposed project off Prospect by the fire department,

3. Safe pedestrian pathways from the proposed project to the H. Roger Tatarian elementary school,

4. Increased traffic thru the poorly configured and too small traffic circle on Prospect, north of Herndon, and

5. Inadequate parking spaces for the proposed complex.

The developer’s representative at one of the Planning Commission meetings stated that the target clientele of the proposed project would be senior citizens. Many elderly individuals have limited mobility and some seniors are easily confused when placed in stressful situations, particularly if they have mild dementia. During a building evacuation because of fire when elevator use is prohibited, many senior citizens may be unable to quickly negotiate third and fourth floor stairways to move to safety outside the buildings. In addition , the four-story portion will not have windows on the eastern side of the building thereby limiting rescue access by firefighters using ladder trucks.

If that building application for this parcel were to be reconsidered or reactivated, may I suggest that several changes be made to either or both the proposed complex and the surrounding street traffic infrastructure. Certainly, anticipating the numerous problems noted above and providing solutions prospectively would seem wise. I remember that the traffic signal at Marks and Herndon Avenue was constructed to replace the 4-way stop signs only after a Supervisor’s teenage daughter was killed in a traffic accident at that intersection.

Prospectively dealing with the above mentioned problems might save lives in the future.

I humbly suggest several potential solutions if the building application for this parcel were to be reconsidered or reactivated:

1. Down-size the proposed project to a maximum of two-story buildings

2. Move the entrance and exit from the proposed complex to W. Fir Avenue instead of N. Prospect Avenue.

4. Maintain or increase the number of parking spaces in the proposed complex despite down-sizing the number of proposed housing units themselves.

Yours Sincerely,
Virgil M. Airola
From: Laura Rios
To: Clerk Agendas; Todd Stermer
Cc: Alyssa Stevens; Mike Karbassi
Subject: FW: LOS City Council Ministerial Approval
Date: Wednesday, April 30, 2025 2:35:36 PM
Attachments: LOS City Council Ministerial Approval.pdf
Can this be sent out to Council?
From: Darren Rose
Sent: Wednesday, April 30, 2025 2:33 PM
To: Laura Rios <[email protected]>
Cc: Kristle Garton
Subject: LOS City Council Ministerial Approval
External Email: Use caution with links and attachments
Laura,
Please see attached letter.

Darren Rose
President/ CEO
Building Industry Association of Fresno/ Madera Counties Darren C. Rose
President & CEO
Building Industry Association of Fresno/Madera Counties April 30, 2025
Fresno City Council
City Hall
2600 Fresno Street
Fresno, CA 93721
Dear Fresno City Council Members,
On behalf of the Building Industry Association of Fresno/Madera Counties, I am writing to express our strong support for ministerial approval of residential housing projects in Fresno. As our community continues to face a critical housing supply shortage, it is imperative that we take proactive steps to streamline the development process and encourage the construction of affordable and diverse housing options.

The need for additional housing in Fresno is more pressing than ever. With our population steadily increasing and the demand for quality living spaces on the rise, the current housing stock is insufficient to meet the needs of our residents. Delays in the approval process only exacerbate this issue, leading to increased costs and missed opportunities for our community.

By implementing a ministerial approval process, the city can expedite housing development, allowing us to bring much-needed homes to market more swiftly.

Ministerial approval would not only facilitate faster development but also provide a clear framework for builders, ensuring that projects align with local zoning laws and community standards. This approach promotes transparency and accountability while helping to eliminate unnecessary bureaucratic hurdles. As a result, we can foster a more conducive environment for housing development that prioritizes the well-being of our residents and the growth of our community.

Furthermore, supporting residential housing projects is an investment in our future. These developments will create jobs, stimulate the local economy, and provide families with the secure and stable housing they need to thrive. Each new home built is a step toward alleviating the housing crisis and enhancing the quality of life for all Fresno residents.

In conclusion, we urge the Fresno City Council to prioritize ministerial approval for residential housing projects. This critical initiative will serve as a catalyst for addressing the housing supply shortage, promoting economic development, and ensuring that Fresno remains a desirable place to live and work.

Thank you for your attention to this vital issue. We look forward to your leadership in fostering a thriving, sustainable future for our community.

Sincerely,
Darren C. Rose
President and CEO
Building Industry Association of Fresno/Madera Counties

From: Jovana Morales-Tilgren
To: Laura Rios; Clerk
Cc: Miguel Arias; Karla Martinez-Arias; Tyler Maxwell; Nelson Esparza; Annalisa Perea; Mike Karbassi; Nicole DeMera; Emma De La Rosa
Subject: Fresno Housing Streamlining Ordinance
Date: Wednesday, April 30, 2025 4:53:49 PM
Attachments: 05.01.2025.CL.docx.pdf
External Email: Use caution with links and attachments
Hello,
We are attaching this comment letter for item ID 25-597. Consideration of Text Amendment Application No. P24-00794 and related Environmental Finding for Environmental Assessment No. P24-00794, amending Sections 15-1302, 15-4907, 15-5102, 15-6702, 15-6802 of the Fresno Municipal Code, repealing Section 15-1106 of the Fresno Municipal Code, and establishing Section 15-2742.5 of the Fresno Municipal Code.

Thank you.

Best,
Jovana Morales Tilgren, MA | Housing & Land Use Policy Manager Leadership Counsel for Justice and Accountability
Pronouns: She/Her/Ella
April 30, 2025
Fresno City Council
2600 Fresno Street
Fresno, CA 93721
Subject: Support if Amend, Fresno Housing Streamlining Ordinance (Development Code Text Amendment No. P24-00794)
Dear Members of the Fresno City Council,
On behalf of the undersigned organizations below, we are writing to express our support if additional amendments are included in the proposed Fresno Housing Streamlining Ordinance, also known as Development Code Text Amendment No. P24-00794. In order for the City’s Housing Element to be found compliant and in adherence to affirmatively furthering fair housing (AFFH) by the California Department of Housing and Community Development (HCD), Program 2– Variety of Housing Opportunities in High Resource Areas, was included.

The adopted Housing Element includes Program 2 that states, “the City will present potential sites or rezoning options for land in high and relatively higher resource and income areas, including RCAAs, for Council consideration to provide opportunities for higher density development in all areas of the city and reduce concentrations of poverty.” To ensure the implementation of Program 2 facilitates the development of high density housing in areas of high opportunity, and does not inadvertently oversaturate Racial and Ethnic Concentrated Areas of Poverty (R/ECAPs) with high density housing developments, we recommend edits to the proposed text amendments as well as including a complementary zoning ordinance. Our recommendations aim to support the City’s duty to affirmatively further fair housing by preventing the overconcentration of affordable housing in R/ECAPs and preventing the ministerial approval of housing near polluting sources. Our recommendations are underlined. [SECTION 15-2742.5 – OFFICE-TO-DWELLING CONVERSION.

D. Definitions.

1. "Eligible Office" shall be defined as an existing office building(s) located in the O District which does not abut heavy or light industrial zones, polluting sources, or major state highways. [(E.) Additional Housing Streamlining

2. Exceptions

1. Permitted Uses. The following types of projects shall be permitted with a Zone Clearance if the additional standards within the section are met:
…
c. Multi-unit residential development in the RM-1, RM-2, and RM-3 Districts on parcels that are within ½ mile of an existing bus stop, and at least 1000 ft from a polluting source, light industrial and heavy industrial zones, and major state highways
d. Multi-unit residential uses in NMX, CMX, RMX, CMS, and CR Districts on parcels within the City’s Infill Priority Area, and at least 1000 ft from a polluting source, light industrial and heavy industrial zones, and major state highways
c. New residential development is prohibited on vacant or underutilized parcels located in the Office Zone district within 1000 feet from a polluting source, light industrial and heavy industrial zones, and major state highways
Additionally, in order to ensure affordable housing is equitably distributed throughout the City, not just in low resourced areas, we strongly recommend additional measures added by including a complementary inclusionary zoning ordinance. There are no mitigation measures to ensure that affordable housing will be built in high resourced areas or racially concentrated affluent areas (RCAAs), therefore inclusionary zoning will provide the ability to set aside affordable units if market rate housing is built in high resourced areas. This is a crucial step toward addressing Fresno’s pressing housing needs, improving the efficiency and accessibility of housing development throughout the City, and remaining in compliance with Housing Element law.

Elm Avenue Rezone
Throughout the last few years, the City has received requests from developers to rezone a number of sites on Elm Avenue located in Southwest Fresno. The proposed rezone sites are currently zoned Neighborhood Mixed Use (NMX) which provides 3,540 housing sites. The City has clearly stated the need to replace the 3,540 sites at the same time the proposed rezone is considered. In approving the text amendment to allow office to residential conversions, the City will be adding land capacity for housing, perhaps more or just enough to replace the 3,540 sites at risk of being lost through the Elm Avenue rezone. While we support the implementation of program 2, we continue to oppose the Elm Avenue proposed rezone and condemn any actions by the City to approve the text amendment to undermine the Southwest Fresno Specific Plan and community’s desire to maintain the Elm Avenue sites as NMX. The City’s duty to affirmatively further fair housing must also be upheld in land use decisions to prevent the same patterns of segregation, disinvestment, and concentration of polluting sources in low income and low income communities of color. Specifically, the City must incorporate AFFH into land use and funding decisions beginning in January of 2025.1 The City must analyze project alternatives and recommend the option that will AFFH to council.

Additionally, the City must adhere to the Housing Crisis Act, Government Code 66300.5 and 66300.6. and Program 35– Replacement Units. The City must ensure that the standards the City is applying for both ministerial and discretionary approvals complies with these requirements where new development is happening on sites that have existing housing units or had housing units in the recent past.

As a reminder, this housing streamlining ordinance is included in the City’s adopted Housing Element, HCD may review a jurisdiction’s failure to implement a housing element program or any action it takes that is inconsistent with the housing element. If HCD finds that the locality’s actions do not substantially comply with the Housing Element Law it may revoke any previous findings that the housing element is in compliance with the law, and it may notify the Attorney General that the City is in violation of the law. (§ 65585(i) & (j).) We strongly urge the City to incorporate measures to ensure equitable distribution of affordable housing particularly in high resource areas and we appreciate the City of Fresno for taking meaningful steps to promote housing affordability and choice while enhancing the quality of life for current and future residents.

Sincerely,
Jovana Morales Tilgren
Housing & Land Use Policy Manager
Leadership Counsel for Justice and Accountability
Marisa Moraza
Political Director
Power California
Dez Martinez
Chief Executive Officer
1 FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024. Pg 1E-1-11. https://fresnomjhe.com/wp-content/uploads/2025/01/FresnoHE_AdptdHE_12.12.24.pdf We Are Not Invisible
Dez Martinez
Fresno Homeless Union

From:

To:

Subject: UPholdings Letter of Support - Streamlining Ordinance Date: Friday, April 25, 2025 1:31:23 PM
Attachments: image001.png
UPholdings Letter of Support.pdf
External Email: Use caution with links and attachments
Good Afternoon,
On behalf of UPholdings, attached is a letter of support for the Streamlining Ordinance to be discussed next Thursday, May 1st.

Best,
Sarah
Sarah Ritten
Associate Project Manager
w: upholdings.net
Statement of Confidentiality
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this email. Please notify the sender immediately by email if you have received this email by mistake and delete this email from your system. Email transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of email transmission. If verification is required please request a hard-copy version.

UPHOLDINGS - Lincolnwood, IL 60712

April 28, 2024
Fresno City Council
2600 Fresno Street
Fresno, CA 93721
Attn: Fresno City Clerk’s Office at [email protected]
Subject: Support for Fresno Housing Streamlining Ordinance (Development Code Text Amendment No. P24-00794)
Dear Members of the Fresno City Council,
On behalf of Regenerate California Innovation and Better Blackstone Community Development Corporation, I am writing to express our strong support for the proposed Fresno Housing Streamlining Ordinance, also known as Development Code Text Amendment No. P24-00794. This forward-thinking initiative is a crucial step toward addressing Fresno’s pressing housing needs and improving the efficiency and accessibility of housing development throughout our city.

The ordinance offers a strategic, equitable approach to increasing housing availability by streamlining the development process for a diverse range of housing types. We are especially encouraged by the ordinance’s key components and impacts, including:
• Providing an additional tool for implementing the City of Fresno’s Housing Element and the State of California’s Housing Accountability Act. • Ministerial approval for office-to-residential conversions, unlocking underutilized space and creating approximately 2,692 new units over 30 years. • Facilitating housing near public transit, supporting sustainability and accessibility with up to 5,525 potential new units.
• Streamlined infill development in mixed-use zones, providing the opportunity for 12,032 additional homes while preserving open space and enhancing urban vitality. • New residential opportunities on office-zoned parcels, contributing approximately 2,176 new units and promoting efficient land use.

These provisions align with the broader goal of promoting equitable, affordable, and sustainable housing for all Fresno residents. We also commend the ordinance’s thoughtful inclusion of traffic and community safety measures for larger projects, as well as its potential to foster economic revitalization and social inclusivity.

Regenerate California Innovation and Better Blackstone Community Development Corporation commend the City of Fresno for taking meaningful steps to promote housing affordability and choice while enhancing the quality of life for current and future residents.

We urge you to adopt the Fresno Housing Streamlining Ordinance now scheduled before you on May 1, 2025.

Sincerely,
Keith Bergthold, CEO
Regenerate California Innovation, Inc (RCI) and Better Blackstone Community Development Corporation (BBCDC)

From:

To:

Subject: Letter in support of housing text amendment
Date: Sunday, April 27, 2025 3:00:07 PM
Attachments: City of Fresno Infill housing support letter Chinatown.pdf External Email: Use caution with links and attachments
Please find attached a letter from the Chinatown Fresno Foundation in support of a text amendment that will benefit the neighborhood housing initiatives for City Council members.

Thank you.

Jan
Jan Minami
Project Director, Chinatown Fresno Foundation
resno CA 93706

From:

To:

Cc:

Subject: Letter of Support - Fresno Housing Streamlining Ordinance Date: Monday, April 28, 2025 11:12:13 AM
Attachments: Letter of Support - Fresno Housing Streamline Ordinance.pdf External Email: Use caution with links and attachments
Good morning,
Please find attached our letter of support for the Fresno Housing Streamlining Ordinance.

Thank you,
Fernando
Fernando Alvarez
Government Affairs Specialist
Fresno Chamber of Commerce
Fresno, CA 93721

From:

To:

Subject: Letter of Support for the Fresno Housing Streamlining Ordinance Date: Monday, April 28, 2025 11:29:48 AM
Attachments: image001.png
Letter of Support for Fresno Housing Streamlining Ordinance.pdf External Email: Use caution with links and attachments
Dear City Clerk,
Attached is a letter of Letter of Support for the Fresno Housing Streamlining Ordinance. I would like to have this letter included in the record.

Thank you for your assistance.

Tyrone Roderick Williams
Chief Executive Officer

to give ministerial approval power to deviate from existing land uses supported by zoning districts with minimal to no knowledge of said change by the Community. The Planning Director’s total disrespect to the Communities Representatives is reflected in her “word salad” explanations and examples. We do not need more DEI (Director’s Empowerment Initiatives) in the Planning Department. Let us outline the players involved in the power play and keep it simple:

1. Community Servants paid by taxes (Mayor to Trash Collector).

2. Community Land Owners are the Taxpayers (Rentals, Owners, Landlords).

3. City Council (People in place to represent the Community Land Owners).

Setting:

1. Caterer

2. Host

3. Party Coordinator
The Host hires a Party Coordinator to coordinate all aspects of the Party to the Host’s best interests. The Host hires a Caterer to provide all nourishment based on the Host’s desire, as stated in the Contract (City Zoning and Land Use Plan).

The Host agrees to the Contract, signs it and asks the Party Coordinator to oversee the Contract to make sure it is followed through.

To make a long story shorter: the Caterer decides to do a CHANGE UP on the food and services that are nowhere close to what is in the Contract.

The Host of the Party is saying “NO to the revisions to the Contract.” They are paying for the Contract AS IS. It is the duty of the Party Coordinator to say “NO TO THE REVISIONS.” The Caterer will service the Contract AS IS on behalf of the Host. The power play by the Caterer will not happen.

I respectfully request that the City Council DENY the power play by the City of Fresno on behalf of the people who pay their wages.

Sincerely,
William D. Stevens
1972 Bachelor of Architecure
1979 Registered Architect, California
1981 NCARB Certificate
Please confirm receipt by return e-mail.

From:

To:

Subject: Support for Fresno Housing Streamlining Ordinance (Development Code Text Amendment No. P24-00794) Date: Wednesday, April 30, 2025 10:24:33 AM
Attachments: City Of Fresno Housing Supoort Letter 4.2025.pdf External Email: Use caution with links and attachments
Dear Fresno City Clerk,
Please include the attached letter of support from Highway City Community Development, Inc. for the Fresno Housing Streamlining Ordinance (Development Code Text Amendment No. P24-00794) in the City Council agenda packet for this item's public hearing now scheduled for May 1, 2025.

Thank you.
--
April Henry
Executive Director/CEO
Highway City Community Development, Inc - a local, place-based nonprofit Teague Community Resource Center - a "HUB" of resources, services & events for our community!
Information: or find us on Facebook
Helping People Help Themselves
"A failure's only a fail when you don't take the lesson and learn from it..."

April 30, 2024
Fresno City Council
2600 Fresno Street
Fresno, CA 93721
Subject: Support for Fresno Housing Streamlining Ordinance (Development Code Text Amendment No. P24-00794)
Dear Members of the Fresno City Council,
On behalf of Lowell CDC I am writing to express our support for the proposed Fresno Housing Streamlining Ordinance, also known as Development Code Text Amendment No.

P24-00794. This forward-thinking initiative is a crucial step toward addressing Fresno’s pressing housing needs and improving the efficiency and accessibility of housing development throughout our city. It encourages housing development in areas that already have vital city infrastructure, access to transportation and close to jobs and built communities.

The ordinance offers a strategic, equitable approach to increasing housing availability by streamlining the development process for a diverse range of housing types. While we are especially encouraged by the ordinance’s key components, we are also concerned that these changes alone are not enough. These changes will most deeply affect communities in the north of Fresno while doing very little to focus development in downtown and in existing older neighborhoods. We encourage housing development across Fresno to serve a wide variety of household sizes and affordability needs. We encourage the City to further create opportunities for approving office and commercial conversions that maybe zoned NMX to residential as well.

Thank you for taking meaningful steps to promote housing affordability and choice while enhancing the quality of life for current and future residents. We urge you to adopt the Fresno Housing Streamlining Ordinance before you on April 24, 2024.

Sincerely,
Esther Carver
Executive Director, Lowell Community Development Corporation.

Fresno City CouncilJune 12, 2025

Fresno City Council
June 12, 2025